SSK: No new findings on the safe decommissioning of the Asse mine

The work required for the safe decommissioning of the Asse mine with which the Federal Office for Radiation Protection (BfS) has been tasked since 2009, has been oriented towards the protection goals laid down in the Atomic Energy Act and in the Radiation Protection Ordinance. The goal of the measures and plans that have been implemented so far and will be implemented in future is to ensure the safety of the staff and the local residents.

In 2009, BfS compared what decommissioning options were in compliance with the legal requirements for a nuclear licence. For this purpose, the necessary precaution against damage according to the state of the art of science and technology must be demonstrated. Also by today's standards, the only way to demonstrate the necessary precaution is by retrieving the radioactive wastes. Therefore, this option must be pursued. Besides, the option of retrieving the wastes prior to decommissioning the mine has also been laid down in the so-called "Lex Asse" since 2013. According to the law, retrieval operations must stop "… if their implementation cannot be justified for the population or the staff for radiological or other safety-related reasons".

Under the heading "Radiation Protection in the Context of Decommissioning the Asse II Mine", the German Commission on Radiological Protection (SSK) mainly criticises the act concerning the retrieval of radioactive wastes ("Lex Asse"). In 2013, the act was adopted by the Bundestag by a very large political majority. The Commission recommends a long-term safety analysis for the wastes remaining in the mine be conducted and conveys the impression that this option can be taken up successfully. The concrete basis of this hope remains unknown to the responsible facility operator and is in direct conflict with the legal order to safely close the facility through retrieving the wastes. On the one hand, the recommendations of the SSK have already been answered by the act and represent generally applicable radiation protection requirements that simply state the obvious for BfS and have already been applied for years. On the other hand, they refer to allegedly latest findings without facts being provided.

Thus, the recommendations do not provide any new approaches to improve the safety of man and environment and do not add any new aspects to the discussions conducted in the past ten years.

Statement was already available as draft version in 2014

Basically, the recommendations now published by the SSK are not new. Already in 2014, the SSK had drawn up a draft. At that time, the Federal Ministry for the Environment, Nature Conservation, Building and Nuclear Safety (BMUB), for whom the SSK is acting as counsel, did not appropriate these draft recommendations and did not take part in further deliberations on this topic.

Asse mine is being stabilised and prepared for retrieval by BfS and Asse-GmbH

The SSK mentions repeatedly an increasingly instable situation of the Asse mine. It does not mention that the BfS has been stabilising the facility with salt concrete for several years, in order to improve the mine's state for the long term. Examinations inside the mine verify the positive effect of these measures. Furthermore, it is planned to construct new areas such as infrastructure rooms and a new shaft.

The recommendations on radiation protection largely represent the current legal practice and radiation protection principles, e.g. optimisation and dose limitation. This is neither new information and nor is it a basis for the work of BfS as operator of the facility and highest federal radiation protection authority.

With regard to the effects of the Asse II mine it is said that two studies of 2009 were excessively conservative. Basically, the following applies to the operator of a nuclear facility: To be able to guarantee the necessary precaution against damages according to the state of the art of science and technology, experts have to work with covering and conservative assumptions if the available data situation (e.g. uncertainties as to the waste inventory of the Asse mine) is insufficient. This procedure is compulsory for the operator. Irrespective of this, the quoted studies are not documents on which the decision to retrieve the waste is based in view of the preliminary long-term safety assessment.