Safety and security interface challenges for Clink the

Safety and security interface challenges for Clink, the integrated spent nuclear fuel storage facility in Sweden

Safety and security interface challenges for Clink, the integrated spent nuclear fuel storage facility in Sweden Swedish Radiation Safety Authority (SSM) Clab and its extension to Clink Conclusions and suggested actions for SSM

Swedish Radiation Safety Authority (SSM) SSM & Legal and regulatory code framework Nuclear Facilities in Sweden Elements of Swedish security coordination

SSM - Legal and regulatory code framework ~ 300 employees Licensing and oversight, radiation & natural radiation Nuclear Act 1984: 3 Radiation Protection Act (1988: 220) Swedish Environmental Code (1998: 808) ~ 40 regulatory codes - currently being restructured International legal framework ~ 30 (e. g. Euratom…)

Nuclear Facilities in Sweden SFR 1988 Short lived radioactive waste repository SFK ~ 2020 to 2080 ? Spent nuclear fuel repository Clab 1985 Spent nuclear fuel storage Clink ~ 2020 to 2030, integrated facility Spent nuclear fuel storage and encapsulation

Elements of Swedish security coordination National cooperation • Military Intelligence and Security Directorate (MUST) • National Defence Radio Establishment (FRA) International cooperation • Sweden has signed ~ 20 international conventions • Bilateral relations with various countries • Multinational bodies* *CGT – The EU Counter-Terrorist Group, TWG – The EU Terrorism Working Group, PWGT – The EU Police Working Group on Terrorism

Elements of Swedish security coordination The Counter-Terrorism Cooperation Council • • The National Defence Radio Establishment The Swedish: o Armed Forces o Civil Contingencies Agency o Coast Guard o Customs o Defence Research Agency o Economic Crime Authority o Migration Agency o Police Authority o Prison and Probation Service o Prosecution Authority o Radiation Safety Authority o Security Service o Transport Agency • Work group: National Centre for Terrorist Threat Assessment

Clab and its extension to Clink Facility overview Nuclear Facilities in Sweden – a comparison Vulnerable interface factors

Facility overview • • Clab fuel pools 8 m deep, 30 m below the surface Storage capacity 8000 tonnes (future capacity 11000 tonnes) Above ground portion of Clab Licensee: The Swedish Nuclear Fuel and Waste Management Co - SKB

Facility overview • Encapsulation facility ~ 60 years • Capacity ~ 200 capsules / year • 4500 capsules total

Facility overview • Safety functions: o criticality prevention, o heat removal and o containment

Facility overview Legacy issues with the safety regime* • Clab, built in 1985 Considerable improvements for Clab safety case Security as Clink will be commissioned • License applications also for o repository o extension of waste handling facility SFR *In INSAG-24 it is stated that Nuclear Power Plants (NPP: s) benefit from a sophisticated and comprehensive safety regime, INSAG-24 The Interface Between Safety and Security at Nuclear Power Plants.

Facility overview Can safety and security interface still be improved? “Preparation program” Clink & repository 2018 – security? • Early notification on organizational changes - FSG & PSG review teams • Regular notification: Dept D – Operation and maintenance & PSG New emergency response center 2018 – good example • FSG & PSG find a delay: OR controls for reserve power to security

Nuclear Facilities in Sweden – a comparison Comparative factor Inventory Complexity of operation Driving force for dispersal Residual heat Time from onset of event to potential release Clab/Clink NPP Nuclear Fuel Fabrication Plant FA – Nuclear Fuel Pool Westinghouse E. S. AB Studsvik Nuclear AB Very large Large Small Intermediate to high Very high High Low pressure High pressure Criticality, events Low pressure Moderate High None Low Long Short Long • The pivotal factor of Clab/Clink is its very large inventory o overlapping projects may compound complexity

Nuclear Facilities in Sweden – a comparison Compounding factors • Need of increased cooling capacity for the Clab storage pools, pools • Need of increased storage capacity in Clab, • Safety analysis report (SAR) update projects

Vulnerable interface factors A prudent regulatory strategy is needed – 1. 1. Identifying vulnerable interface positions or operations o oversight and possible licence conditions o new regulatory codes

Vulnerable interface factors Items important for Clab or Clink • Cooling chain, • Back-up and redundant power supply systems, • Above ground portion of Clab where spent nuclear fuel casks are taken in and handled, o relative building structural vulnerability and o emergency lowering of spent nuclear fuel.

Vulnerable interface factors Encapsulation facility • • Lifting equipment, Operation and production systems for copper capsules, Fire detection and protection systems. Siting o location above ground, o increased on- and off-site transports.

Vulnerable interface factors Ability to counter malicious acts • Critical restore operations, o manual start of back-up diesel generator if automatic start fails, o connection of mobile auxiliary power supply, o the utilization of fuel and lube oil supplies, o reconnecting and resupply of make-up water from different sources, o critical component replacements.

Vulnerable interface factors Further compounding factors • Possibly the most vulnerable time when Clink is commissioned, • Clink availability important to back end & front end fuel cycle, • Risk of sudden lack of resources for safety & security interface. o Clink start-up project 2018 lacked security considerations, contradicting security committments in license application. A prudent regulatory strategy is needed – 2. & 3. 2. Oversight of new SKB instructions for graded reviews o strategies for modifications and commissioning, 3. Analyzing potential threats to the overall organizational ability of SKB.

Conclusions and suggested actions for SSM Oversight of vulnerable interface positions of Clab/Clink Safety and security reviews and commissioning Challenges to the overall organizational ability of SKB

Oversight of vulnerable interface positions of Clab/Clink All interface weaknesses need to be considered • general statements about overall congruency of updates & modifications à Suggested action 1: SSM to require also some itemized reviews. Enables • managable “chunks” of reviews easier for the regulator to handle • better project control and timeliness for the licensee

Safety and security reviews and commissioning SKB instructions for graded safety and security reviews • consideration of both safety and security in an integrated manner • appropriate guidance for reviews of organizational changes included. à Suggested action 2: SSM oversight, specifically or contextually. Enables: • reduced likelihood of unwanted systemic errors, • greater defence in depth.

Challenges to the overall organizational ability of SKB Adequate resources for security during Clink commissioning • Front end needs should not cause override of security provisions à Suggested action 3: Ensure enough resources for safety and security. Enables: • Adequate regulatory oversight and more experience • Organizational ability for SKB to co-function with national security entities

Summary New regulatory codes project Clab and Clink safety and security interfaces Item based reviews, oversight of instructions & resources

Questions? Image reference: SKB International AB.