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Regulatory Issues and Challenges in Preparing for the Regulation of New Reactor Siting: Malaysia’s Experience CNRA International Workshop on “New Reactor Siting, Licensing & Construction Experience”; 15-17 September 2010, Prague, Czech Republic Azlina Mohammad Jais a,b a Atomic Energy Licensing Board (AELB) Malaysia b Universiti Kebangsaan Malaysia (UKM) Halimah Hassan Department of Environmental (DOE) Malaysia Muhamad Samudi Yasir Universiti Kebangsaan Malaysia (UKM)

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Page 1: Regulatory Issues and Challenges in Preparing for the ... · PDF fileRegulatory Issues and Challenges in Preparing for the Regulation of New ... and Hire Purchase) ... Regulatory Issues

Regulatory Issues and Challenges in Preparing for the Regulation of New Reactor Siting: Malaysia’s Experience

CNRA International Workshop on “New Reactor Siting, Licensing & Construction Experience”;

15-17 September 2010, Prague, Czech Republic

Azlina Mohammad Jaisa,b a Atomic Energy Licensing Board (AELB) Malaysia

b Universiti Kebangsaan Malaysia (UKM)

Halimah Hassan

Department of Environmental (DOE) Malaysia

Muhamad Samudi Yasir

Universiti Kebangsaan Malaysia (UKM)

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OUTLINE

Atomic Energy Licensing Board (AELB), Acts and Regulations

Overview on the status of nuclear power development

Licensing Process for NPP

Regulatory Issues and Challenges

Approach to facilitate Licensing Process for a Site License

Siting Criteria and guidelines

Selection and Evaluation for NPP Site

Radiological and Environmental Impact Assessment (RIA/EIA)

Social Impact Assessment (SIA)

Human Resources

Summary

Conclusion

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Atomic Energy Licensing Board (AELB)- A Regulatory Body for Radiation and Nuclear Activities in Malaysia

AELB HQ

Branch

Branch

Branch

Branch

No Staff: 165

Licensee: > 1000

Medical and non-

medical activities, I

Research Reactor

(Triga Mark II),

1 mWt

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AELB - Independent RB Ministry of Science, Technology

& Innovation Minister of Science, Technology

& Innovation

Director General AELB Department

Executive Secretary

Nuclear Installation Division

Policy, Code & Standard Division

Technical Support Division

Licensing Division

Enforcement Division Administrative Services Division

Standing Safety Committee

Sub-standing Safety

Committee

The Board (5 Members)

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Atomic Energy Licensing Act, 1984 (Act 304) and its Regulations

Appointment of date of coming into force [P.U.(B) 44/85]

Radiation Protection (Licensing) Regulations 1986 [P.U.(A) 149/86]

CORRIGENDUM to Radiation Protection (Licensing) Regulations 1986 [P.U.(A) 355/86]

Radiation Protection (Basic Safety Standard) Regulations 1988 [P.U.(A) 61/88]

Atomic Energy Licensing (Exemption) Order 1988 [P.U.(A) 189/89]

Atomic Energy Licensing (Exemption) Order 1989 [P.U.(A) 50/89]

Atomic Energy Licensing (Exemption) (Smoke Detectors) Order 1989 [P.U.(A) 422/89]

Radiation Protection (Transport) Regulations 1989 [P.U.(A) 456/89]

Atomic Energy Licensing (Exemption) (Lightning Arrestor) Order 1990 [P.U.(A) 12/90]

Atomic Energy Licensing (Exemption) (Leasing and Hire Purchase) Order 1990 [P.U.(A) 205/90]

Atomic Energy Licensing (Appeal) Regulations 1990 [P.U.(A) 206/90]

Radiation Protection (Transport) (Amendment) Regulations 1991 [P.U.(A) 145/91]

CORRIGENDUM to Radiation Protection (Transport) Regulations 1989 [P.U.(A) 146/91]

Atomic Energy Licensing (Small Amang Factory) (Exemption) Order 1994 [P.U.(A) 435/94]

Atomic Energy Licensing (Exemption) (Ceramic Factory) Order 1998 [P.U.(A) 431/98]

Note: This Order has been repealed by P.U.(A) 182/2002

Atomic Energy Licensing (Exemption) (Scanning Electron Microscope) Order 1998 [P.U.(A) 432/98]

Atomic Energy Licensing (Exemption) (Irradiating Apparatus Below 5 Kilo Electron Volt) Order 2002 [P.U.(A) 181/2002]

Atomic Energy Licensing (Exemption) (Low Activity Radioactive Material) Order 2002 [P.U.(A) 182/2002]

Atomic Energy Licensing Act 1984 (Act 304)

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Industrial participation

Ready to make a

knowledgeable

decision

Ready to

commission

Phase 1 Phase 2 Phase 3

Ready to

invite bids

Ready to make a knowledgeable

commitment to a nuclear

programme

Ready to commission

and operate the first

NPP

Operating Organization

Regulatory Body

Government Policy &

Public Acceptance

Strengthening

Legal framework-

AELB, EC etc

International

commitment (45

Instruments identified)

M2 M1 M3

Source: IAEA

Preparation for NPP- Roles & Responsibilities of Key Players

Potential

developer/operator

Cabinet

Decision 26th

June 2009-

Nuclear energy

as an option)

40 relevant national

laws & regulations

identified

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CABINET COMMITTEE ON ENERGY

PROGRAM DEVELOPMENT

WORKING COMMITTEE

Nuclear Malaysia Agency

PROJECT DEVELOPMENT

WORKING COMMITTEE

Tenaga Nasional Bhd. (TNB)

REGULATORY DEVELOPMENT COORDINATION

WORKING COMMITTEE

Atomic Energy Licensing Board (AELB)

and Energy Commission (ST)

NUCLEAR POWER DEVELOPMENT STEERING COMMITTEE (Cabinet Decision 26th June 2009)

Ministry of Energy, Green Technology and Water

• Educational Program and Public Awareness

• Human Capital Development

• Technology Assessment

• Site Identification • Nuclear Fuel Procurement Planning • Nuclear Power Plant Conceptual Design,

including Project Management and Quality Assurance

• Regulation and Licensing of Electricity Generation • Regulation and Licensing of Nuclear Power Plant • International Legal Instruments & Governance

Contribute in the

development of

Nuclear Power

Infrastructure

Development

Programme (NPIDP)

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National and

International Nuclear

Legislation and

Regulations Assessment

Study 2010-2012 Implementation of Strategy and

Action Plan 2013-2021

(Output from assessment studies)

NPP Site License NPP construction

License

NPP Operation

License

Strengthening Regulatory Infrastructure for NPP

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Authorities Involved In Regulating The Nuclear Power Plant in Malaysia

9

“Nuclear Island” – AELB ( & DOE, DOSH)

“Non-Nuclear Island” – EC ( & DOE, DOSH, MHLG etc.)

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LICENSING PROCESS OF NUCLEAR POWER PLANTLICENSING PROCESS OF NUCLEAR POWER PLANT 3 STEPS LICENSE 3 STEPS LICENSE

Class F

Class A

& B

Class G

Site

Licence

Te

mp

ora

ry

op

era

tio

n

Operation Licence

Construction

licence Full Operation

(fuel loading)

Decom.

Licence

Radiation Protection (Licensing) Regulation, 1986Radiation Protection (Licensing) Regulation, 1986

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Licensing Process of NPP- Technical Information Required

Site Licence Construction Licence

Operation Licence

Temporary Full

Site Evaluation Report Description of the

proposed installation and activities

Physical characteristic of the site Population distribution Present land use Radiological ,

Environmental & social impact assessment

Pre-operational radiological monitoring programme

A description of storage facilities for radioactive materials or nuclear materials on the site

Decommissioning plan Any additional

information required by appropriate authority

Preliminary Safety Analysis Report

General layout and detail plan and design of the facility

Updated EIA & RIA Postulated initiating

event (A statement with respect to potential accidents and unscheduled releases of wastes and hazardous materials from the facility)

Any additional information required by appropriate authority

Any change, in the material used or in the design

Radiation Protection Programme (A description of proposed measures to control radiation exposures)

A detail medical surveillance programme

A programme for initial and periodic training

Operational radiological monitoring programme (quality and quantity of effluents to be discharge or emission from the facility)

Design Basis Accident (proposed procedures to prevent accident and the proposed contingency plan in the event of an accident)

Design basis Threat (plan and procedures to prevent loss, theft, or unauthorized used)

Any additional information

required by appropriate authority

Final Safety Analysis Report

Any additional information required by appropriate authority

Note: Preliminary SAR – Siting, Intermediate SAR – Construction Final SAR - Operation

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Regulatory Issues and Challenges [1] Approach to facilitate Licensing Process for a Site License

12

AP

PL

ICA

NT

(U

tili

ty

Pro

vid

er)

AE

LB

E

XT

ER

NA

L

EX

PE

RT

G

OV

T.

AG

EN

CIE

S

GO

VE

RN

ME

NT

P

UB

LIC

Public feedback

Prepare licence

Letter of Intent

Prepare and submit

document

Advice applicant on license

requirement

Form inter agencies comm. to

review

Conform regulatory

requirement

Additional information

Decision (accept/ reject)

Decision (issue

license)

License notification

Issue report to minister

Report review

Public participation (JPBD, DOE)

SIA, EIA, LCP

Consult expert

“One Gate Licensing

Process with Multiple

Regulatory

Authorities”

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Act 304,

1984

Radiation Protection (Transport)

Regulations 1989

Radiation Protection (Appeal)

Regulations 1990

Atomic Energy Licensing (Basic

Safety Radiation Protection)

Regulations 2010

Radiation Protection (Nuclear

Installation Licensing) Regulations

201_

GS-G-1.6Regulato Issues ry

Seismic Design and Qualification for NPP

GS-G-3.3

Evaluation of Seismic Hazard for NPP

GS-G-4.1

Format and Content of SAR for NPP

NS-G-1.1

Software for Computer Based System

Important to Safety in NPP

NS-G-1.2

Safety Assessment and Verification for NPP

NS-G-1.4

Design of Fuel Handling and Storage

System For NPP

NS-G-1.5

External Event Excluding Earthquake

NS-G-1.7

Protection Against Internal Fires and

Explosion In the Design of NPP

NS-G-1.8

Design of Emergency Power System for NPP

NS-G-1.9

Design of Reactor Coolant System and

Associated System in NPP

NS-G-1.10

Design of Reactor Containment System for NPP

NS-G-1.11

Protection against Internal Hazard Other than

Fire and Explosion Design of NPP

NS-G-1.12

Design of Reactor Core for NPP

NS-G-1.13

Radiation Protection Aspect of Design for NPP

NS-G-2.1

Fire Safety in the Operation of NPP

NS-G-2.2

Operation Limit & Condition and Operating

Procedures For NPP

NS-G-2.3

Modification to NPP

NS-G-2.4

The Operating Organization for NPP

NS-G-2.5

Core Management and Fuel Handling for NPP

NS-G-2.7

Radiation Protection and Radioactive Waste

Management in the Operation of NPP

NS-G-2.8

Recruitment, Qualification & Training of

Personnel for NPP

NS-G-2.9

Commissioning for NPP

NS-R-1

Safety for NPP Design

NS-G-2.10

Periodic Safety Review for NPP

NS-G-2.11

A System for the Feedback of Experience

From Events in Nuclear Installation

NS-G-3.1

External Human Induce Event in Site

Evaluation for NPP

NS-G-3.2

Dispersion of Radioactive Material in Air and

Water and Consideration of Population

Distribution in Site Evaluation

For NPP

NS-G-3.4

Meteorological Event in Site Evaluation for NPP

NS-G-3.5

Flood Hazard for NPP on Coastal and River Site

NS-G-3.6

Geotechnical Aspect of Site Evaluation and

Foundation for NPP

WS-G-2.1

Decommissioning for Research Reactor and NPP

NS-R-3

Site Evaluation for Nuclear Installation

NS-R-2

Safety of NPP Operation

Guidance Documents

Regulatory Issues and Challenges [2]- Siting Criteria and Guidelines

Guideline for Assessment of

Reactor Modification

Guideline on Nuclear Emergency

Preparedness Program

Guideline on Physical Protection

of Nuclear Installation

National Guideline on Safety

Assessment And Preparation of SAR

Guideline on the Site Evaluation

For Nuclear Installation

Legend

In Preparation/Drafting

In Revision

Under Planning

Act- 1984

Standard for Certification and

Re-certification of RR Operator

Radiation Protection (Radioactive

Waste Management) Regulations

201_

Atomic Energy Licensing (Security of

Radioactive Sources) Regulations

201_

Atomic Energy Licensing (Security of

Nuclear Materials) Regulations

201_

Atomic Energy Licensing (Safeguards

Of Nuclear Activities) Regulations

201_

Radiation Protection (Medical

Dental and Veterinary Usage of

Radiation) Regulations 201_

Radiation Protection (Licensing)

Regulations 1986

Guideline for Approval Application of

Nuclear Material Transit

Guideline for IAEA Safeguard

Inspector Designation and Issuance of

Multiple Entry Visa

Guideline for Inspection Procedure

For Research Reactors

Guideline for Approval Application

Of Transshipment of NM

Standard for Certification of Inspector

And Assessor

Guidelines on Security of Radioactive

Sources

Adopted by Board

Published

Approved by Board

Atomic Energy Licensing (Transport

Security) Regulations 201_

In addition, Nuclear Siting Guidelines of

Finland, Canada, RO Korea, USA & were adopted by

the Board

To date, a total of over 100 IAEA

standards & guidance

documents on NPP were

adopted by the Board

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IAEA Standards and Guidelines Adopted by AELB

GS-R-1

Legal and Governmental Infrastructure for Nuclear, Radiation, Radioactive Waste and Transport Safety

INSAG-5 The Safety of Nuclear Power

INSAG-12 Basic Safety Principles for Nuclear Power Plants

INSAG-22 Nuclear Safety Infrastructure for a National Nuclear Power Programme Supported by the IAEA Fundamental Safety Principles

INSAG-21 Strengthening the Global Nuclear Safety Regime

- IAEA Handbook on Nuclear Law

GS-G-1.1 Organization and Staffing of the Regulatory Body for Nuclear Facilities

GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body

GS-G-1.3 Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body

DS416 Licensing Process for Nuclear Installations

GS-G-1.5 Regulatory Control of Radiation Sources

WS-G-2.3 Regulatory Control of Radioactive Discharges to the Environment

INSAG-17 Independence in regulatory decision making

INSAG-20 Stakeholder Involvement in Nuclear Issues

GSR Part 5 Predisposal Management of Radioactive

WS-R-5 Decommissioning of Facilities Using Radioactive Material

DS429 External Expert Support on Safety issues

GS-G-3.2 The Management System for Technical Services in Radiation Safety

DS349 The Management System for Nuclear Installations

INSAG-18 Managing Change in the Nuclear Industry: the Effects on Safety

GS-G-3.3 The Management System for the Processing, Handling and Storage of Radioactive Waste

GS-G-3.4 The Management System for the Disposal of Radioactive Waste

TS-G-1.4 Management System for the Safe Transport of Radioactive Material

INSAG-13 Management of Operational Safety in Nuclear Power Plants

INSAG-15 Key Practical Issues in Strengthening Safety Culture

RS-G-1.4 Building Competence in Radiation Protection and the Safe Use of Radiation Sources

INSAG-16 Maintaining Knowledge, Training and Infrastructure for Research and Development in Nuclear Safety

RS-G-1.1 Occupational Radiation Protection

RS-G-1.2 Assessment of Occupational Exposure due to Intakes of Radionuclides

RS-G-1.3 Assessment of Occupational Exposure due to External Sources of Radiation

RS-G-1.4 Building Competence in Radiation Protection and the Safe Use of Radiation Sources

RS-G-1.7 Application of the Concepts of Exclusion, Exemption and Clearance

RS-G-1.8 Environmental and Sources Monitoring for Purposes of Radiation Protection

DS427 Radiological Environmental Impact Analysis for the verification of Radiological Protection

INSAG-9 Potential Exposure in Nuclear Safety

DS365

Risk-Informed Decision Making

GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body

DS 395 Deterministic Safety Analyses and their Application for Nuclear Power Plants

111-G-1.1 Classification of Radioactive Waste

→ DS390 Classification of Radioactive Waste

WS-G-2.5 Predisposal Management of Low and Intermediate

Level Radioactive Waste

WS-G-2.6 Predisposal Management of High Level Radioactive

Waste

WS-G-6.1 Storage of Radioactive Waste

DS284 Safety Assessment for Radioactive Waste Predisposal

Facilities and Activities

WS-R-5 Decommissioning of Facilities Using Radioactive

Material

DS354 Disposal of Radioactive Waste (to become new SSR5)

GS-G-3.3 The Management System for the Processing, Handling

and Storage of Radioactive Waste

NS-R-5 Safety of Nuclear Fuel Cycle Facilities

DS371 Storage of Spent Fuel

GS-G-2.1 Arrangements for Preparedness for a Nuclear or

Radiological Emergency

SS109 Intervention Criteria in a Nuclear or Radiation

Emergency

→ DS44 Criteria for Use in Planning Response to Nuclear and Radiological Emergencies

TS-G-1.2 Planning and Preparing for Emergency Response to Transport Accidents Involving Radioactive Material

NS-G-2.12 Ageing Management for Nuclear Power Plants

NS-G-2.14 Conduct of Operations at Nuclear Power Plants

DS385 Severe Accident Management Programme for Nuclear

Power Plants

DS388 Chemistry Programme for Water Cooled Nuclear

Power Plants

INSAG-23 Improving the International System for Operating

Experience Feedback

50-SG-S9 Site survey for Nuclear Power Plants (under update

and revision process)

DS405 Volcanic hazards for nuclear installations

DS367 Safety Classification of Structures, Systems and

Components in Nuclear Power Plants

DS393 Development and Application of Level 2 PSA for

Nuclear Power Plants

DS394 Development and Application of Level 1 PSA for

Nuclear Reactors

DS395 Deterministic Safety Analyses and their

Application for Nuclear Power Plants

SS79 Design of Radioactive Waste Management

Systems at Nuclear Power Plants

GSR Part 4 Safety Assessment for Facilities and Activities

INSAG-6 Probabilistic Safety Assessment

INSAG-10 Defence in Depth in Nuclear Safety

TS-G-1.1 (Rev.1) Advisory Material for the IAEA Regulations for

the Safe Transport of Radioactive Material TS-G-1.2

Planning and Preparing for Emergency Response to Transport Accidents Involving

Radioactive Material TS-G-1.3

Radiation Protection Programmes for Transport Radioactive Material

TS-G-1.4 Management System for the Safe Transport of

Radioactive Material TS-G-1.5

Compliance Assurance for the Safe Transport of Radioactive Material

INSAG-24 Safety and Security Interface in Nuclear

Installations

Additional 56 IAEA

Std. & 16 draft Std.

adopted in 2010

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National Standards and Guidelines Adopted by AELB

•USNRC :

•Reactor Site Criteria (10 Code of Federal Regulation, Part 100),

•Standards For Protection Against Radiation (10 Code of Federal Regulation, Part 20),

•Domestic Licensing Of Production And Utilization Facilities (10 Code of Federal Regulation, Part 50)

•Physical Protection Of Plants And Materials (10 Code of Federal Regulation, Part 73)

•Site Investigations For Foundations Of Nuclear Power Plants (Regulatory Guide 1.132), 2003

•Laboratory Investigations Of Soils And Rocks For Engineering Analysis And Design Of Nuclear Power Plants (Regulatory Guide 1.138), 2003

•Identification And Characterization Of Seismic Sources And Determination Of Safe Shutdown Earthquake Ground Motion (Regulatory Guide 1.165), 1997

•Procedures And Criteria For Assessing Seismic Soil Liquefaction At Nuclear Power Plant Sites (Regulatory Guide 1.198), 2003

•A Performance-Based Approach To Define Te Site-Specific Earthquake Ground Motion (Regulatory Guide 1.208), 2007

•Preparation Of Environmental Reports For Nuclear Power Stations (Regulatory Guide 4.2), 1976

•General Site Suitability Criteria For Nuclear Power Stations (Regulatory Guide 4.7), 1998

•Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant (NUREG 654). November

1980

•Standard Format and Content of Safety Analysis Report for Nuclear Power Plants: LWR Edition (Regulatory Guide 1.70, Revision 3). November 1978

•Assumption Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors (Regulatory Guide 1.3, Revision

2). June 1974

•Assumption Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized Water Reactors (Regulatory Guide 1.4,

Revision 2). June 1974

•Assumption Used for Evaluating the Potential Radiological Consequences of a Steam Line Break Accident for Boiling Water Reactors (Regulatory Guide 1.4,

Revision 2). June 1974

•Meteorological Monitoring Programs for Nuclear Power Plants (Regulatory Guide 1.23, Revision 1). March 2007

•Assumption Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel handling and Storage Facility for Boiling and

Pressurized Water Reactors (Regulatory Guide 1.25, Revision 0). March 1972

•Ultimate Heat Sink for Nuclear Power Plants (Regulatory Guide 1.27, Revision 2). January 1976

•Seismic Design Classification (Regulatory Guide 1.29, Revision 4). March 2007

•Design Basis Flood for Nuclear Power Plants (Regulatory Guide 1.59, Revision 2). August 1977

•Evaluating the Habitability of a Nuclear Power Plants Control Room during a Postulated Hazardous Chemical Releases (Regulatory Guide 1.78, Revision 1).

December 2001

•Atmospheric Dispersion Models for Potential Accident Consequences Assessment at Nuclear Power Plants (Regulatory Guide 1.145, Revision 1). February 1983

Canada:

Site Evaluation for New Nuclear Power Plants. Canadian Nuclear Safety Commission. Regulatory Documents (RD) No. 346, 2008

EPRI,USA

Siting Guide: Site Selection and Evaluation Criteria for an Early Site Permit Application. Electric Power Research Institute, Inc. (EPRI)

2002

Finland:

Safety Criteria For Siting A Nuclear Power Plant. Radiation and Nuclear Safety Authority (STUK). Guide YVL No. 1.10, July 2000

Adopted by Board in 2010 for reference purposes

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Regulatory Issues and Challenges [3] Site Selection and Evaluation Criteria

Site Selection Site Evaluation

External Natural & Human Induced Event

Population Density & Distribution

Uses of Land & Water in the Region

Atmospheric, Surface & Groundwater Dispersion

Health & Safety Criteria

Environment Protection

Current Land Use and Socioeconomics

Public Participation

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Regulatory Issues and challenges [4] Radiological and Environmental Impact

Assessment (RIA & EIA)

RIA- Requirements under Atomic Energy Licensing Act, 1984

EIA- Requirements under Environmental Quality Act 1974

Construction of a nuclear fueled power station is a prescribed activity under the EIA Order

Undergo a Detailed EIA procedure, including public display and public comments on the EIA

Report

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Regulatory Issues and challenges [5]

Social Impact Assessment (SIA)

required during application for Planning Approval by the Local Authority

submitted together with the Proposed Project Development

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CONCLUSION

A clear political decision on NPP is important-regulatory body need more trained human resources, adequate financial, independent, effective and competent.

Development of regulatory procedures and guidelines for the site evaluation, licensing process and inspection programme is important to perform effective regulatory reviews and inspection in an efficient and timely manner at the beginning stage of NPP development- possible areas of cooperation and partnership among the Regulatory Authority of newcomers & advance NPP countries need to be identified and strengthened .

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Thank You