Precondition for construction licence: Exceptionally comprehensive planning
Posiva submitted the construction licence application for the encapsulation plant and disposal facility for spent nuclear fuel to the Ministry of Employment and the Economy at the end of 2012. The permit process has progressed as planned. However, requests for additional reports are to be expected on almost the entire material.
About 20 full-time inspectors, or more when necessary. Researchers, experts, officials. Municipalities and civic organizations. Regulations, instructions, assessments, interpretations and statements. Close cooperation, independent parties, discussion. All this is needed to take care of the plant's permit process, the only one of its kind in the world. For all its diversity, the entire "machine" has a simple goal: to make sure that spent nuclear fuel is safely disposed of.
Clarification as a result of review
The construction permit licence application of the repository comprises the actual application and appendices submitted to the Finnish Government, and the extensive safety material submitted to STUK for review. Tasks are clearly divided between the inspectors: the Ministry of Employment and Economy focuses on hearing different parties and on processing matters pointed out in statements, whereas STUK focuses on safety technology solutions.
"STUK provided us with the first set of feedback on the material in late April. The feedback said that, based on the prepared coverage assessment, a detailed review may commence on the majority of the material. Some things need to be reviewed more comprehensively, and we will be implementing related clarifications throughout the permit process," says Posiva Safety Manager Vesa Ruuska.
According to Ruuska, a few dozen more reports are on the task list, but the detailed review means that many more will be added. "My view is that before we reach actual construction, the entire permit material has been specified once, some when our plans will have been specified further, and some on the basis of feedback obtained from STUK. This means that there will be enough work and writing next year," says Ruuska.
Stricter conditions the cause behind all this
Not that Posiva would have intentionally submitted an incomplete application. The material contains very detailed information, even more detailed than ever before required at the construction licence stage of nuclear plants. Not that the safety level views of STUK and Posiva are different. Posiva and the authorities have a very similar view on the concept of indicating long-term safety.
Some of the required clarifications are due to applying the rules. The unique nuclear plant package of a totally new kind is subject to rules which were initially drawn up for nuclear plants. When applying the rules, they must be interpreted, and they are sometimes ambiguous. This requires good, deep dialog between Posiva and the authorities.
However, the fact that the STUK rule renewal is in progress and that draft versions of the instructions have changed during the application preparation have caused specific consequences for the already challenging licence process. The material will now be updated to match the instructions (some of which have changed) specified further after the application is submitted. Finally, the requirement level and supervision procedures are quite close to what is required in the construction of new nuclear plants today. "The starting point is that the plant will be very comprehensively designed before a licence is granted," says Ruuska.
Text and photo: Johanna Aho