A Study on the Licensing Process for the Floating Nuclear Power Plant in Indonesia: A Suggestion for the Revision of Government Regulation Regarding Nuclear Power Plant Licensing

Abstract

Indonesia is currently revising some Government Regulations regarding the licensing process of the nuclear power plant. In the current revision process, the latest technology such as small modular reactors and floating nuclear power plants are also considered to be regulated specifically. In current regulations, regardless of the type and technology, the licensing for nuclear power plants is regulated generally. Considering its unique nature and character, the floating nuclear power plant should have more specific requirements for the licensing process. This paper is carried out to analyze the specific requirements that should be considered for the licensing process of the floating nuclear power plant in Indonesia. The results of this study are expected to be a suggestion for the Government Regulations revision.

1. Introduction

In 2023, the International Atomic Energy Agency (IAEA) held the International Symposium on the Deployment of Floating Nuclear Power Plants (FNPP)—Benefits and Challenges in Vienna. This event indicates the exaggerated interest in the FNPP around the world. As mentioned in the symposium, some member states are known to be interested in building the FNPP, including China, Denmark, and the Republic of Korea [1]. The increasing interest in FNPPs is due to their capacity to supply energy to remote regions, offshore locations, and development activities [2]. To date, the only commercial FNPP in the world is Russia’s Akademik Lomonosov [3].

On the other hand, in 2015, through ATOMEXPO, Indonesia stated its interest in building an FNPP in the future [4]. As an archipelagic country with many small islands, the FNPP will be suitable for Indonesia. Currently, Indonesia has more than 17,000 small islands [5]. Furthermore, there is an interest from certain consortiums to deploy an FNPP in Indonesia, namely Thorcon Power Indonesia Ltd. (Jakarta, Indonesia) [6]. Using a thorium molten salt reactor, this reactor will produce 500 MWe [7]. In the policy context, the challenge posed by the FNPP is the licensing process based on its different nature and characteristics of the FNPP compared to the land-based NPP.

In Indonesia, the highest level of law regarding nuclear energy is Act Number 10 Year 1997 on Nuclear Energy and Act Number 6 Year 2023 on the Stipulation of Government Regulation (GR) in Lieu of Act Number 2 Year 2022 on Job Creation into Act. While Act Number 10 Year 1997 regulates nuclear energy in general, Act Number 6 Year 2023 regulates in detail on commercial purposes of nuclear energy. Related to the licensing process, as the second highest level of regulation under the Act, the Indonesian government developed GR Number 2 Year 2014 on the Licensing of Nuclear Installation and Nuclear Material Utilization, and GR Number 5 Year 2021 on Risk-Based Business Licensing Implementation. Using the same approach as the Acts, GR Number 2 Year 2014 regulates the licensing process of the nuclear installation in general while GR Number 5 Year 2021 regulates in detail on commercial purposes of a nuclear installation. However, these regulations do not have any detailed requirements for the FNPP. Considering the interest previously mentioned, Indonesia needs to have a regulation regarding the FNPP, particularly on the licensing process.

Meanwhile, the Indonesian Nuclear Energy Regulatory Agency (Bapeten) has been developing revisions to Act Number 10 Year 1997, GR Number 2 Year 2014, and GR Number 5 Year 2021 recently. These revisions consider the latest technology developments including the FNPP. Generally, most of the requirements in the regulations will be practicable for the FNPP. However, several adjustments and details should be carried out to compensate for the different nature and characteristics of the FNPP compared to the land-based NPP. This study focuses on the revision of the GRs and will exclude the revision of the Act as the Act is the highest level of law in Indonesia and will not give any details about the licensing process.

Among the regulations related to marine-based nuclear facilities is The Merchant Shipping (Nuclear Ships) Regulations 2022 from the United Kingdom. However, this regulation focuses on nuclear ships rather than the FNPP [8]. On the other hand, there have been many studies regarding the FNPP, yet the studies do not focus on the licensing process. Cusmanri focused studies on the impact of external hazards [9] and emergency preparedness and response [10], Standring et al. focused the study on the environmental impact of the FNPP [11], and Fajri et al. studied the reactor core neutronic parameter of the FNPP [12]. Although the studies do not focus on the licensing process, the information provided by the papers is beneficial for further consideration.

This paper is carried out to review the current GRs regarding the licensing process of the NPP, analyze the requirements that should be revised to compensate for the nature of the FNPP, and provide suggestions for the revision. This study started with a review of the GR Number 2 Year 2014 and GR Number 5 Year 2021. The review was focusing on the requirements that might need to be adjusted for the FNPP. Lastly, the review will be performed on references related to FNPP technology, nuclear safety, and maritime safety. These references include reports, research papers, and IAEA publications. The review of the references will give information on the real practice and concept of the operation and deployment of the FNPP. For example, the report by Lobner about the Akademik Lomonosov will give information on the deployment process of an FNPP [3], the research paper performed by Cusmanri on the impact of external hazards on the FNPP will give insight into how external hazards will impact the safety of the FNPP [9], and the IAEA Publication regarding Advances of Small Modular Reactor provides the information of several design information of FNPPs [13]. Other references will be described in the next sections. Based on the review of the references, suggestions will be provided to fulfill the requirements needed specifically for the FNPP. The suggestion will focus more on the specific regulations for the FNPP and will not change the general requirements of the NPP unless it will affect the FNPP project safety or economy.

2. Overview of the FNPP

An FNPP can be defined as an NPP unit in which the reactor and its auxiliary system are mounted on a ship and using the water surface as the site. This definition is based on the design information of various FNPPs [9]. According to the IAEA, by 2022, at least 10 FNPP reactor designs had been compiled worldwide [9]. These reactors consist of various types, including pressurized water reactors (PWRs) and molten salt reactors (MSRs).

Table 1. Recent status of the FNPP in the world in 2022.

Name	Reactor Type	Electrical Capacity (MWe)	Origins	Status
KLT-40S	PWR	2 × 35	Russia	In Operation
RITM-200M	Integral PWR	50	Russia	Basic Design
ACPR50S	PWR	50	China	Detailed Design
ACP100S	Integral PWR	125	China	Basic Design
BANDI-60	PWR	60	Korea	Conceptual Design
VBER-300	Integral PWR	325	Russia	Licensing Stage
SHELF-M	Integral PWR	up to 10	Russia	Basic Design
ABV-6E	PWR	6–9	Russia	Final Design
CMSR	MSR	100	Denmark	Conceptual Design
ThorCon	MSR	250	USA and Indonesia	Preliminary Design

shows the recent status of the FNPP worldwide in 2022 [13].

As mentioned in Table 1, the Akademik Lomonosov with the KLT-40S reactor is the only commercial FNPP in operation. The emerging interest in the FNPP is due to its flexible functions related to its ability to distribute energy to remote areas, offshore locations, and support development activities [2].

Based on references, the FNPP can be grouped into onshore and offshore FNPP [4]. While the onshore FNPP concept has been extensively developed in some countries, the offshore FNPP is still in the research phase. The offshore FNPP is researched at the Massachusetts Institute of Technology and is developing in China [14,15]. While Figure 1 shows the layout of the onshore FNPP, the offshore FNPP is placed far from the coastline.

As mentioned, the only commercial FNPP to date is the Akademik Lomonosov. This FNPP is a type of onshore FNPP. The barge-mounted FNPP used the small modular reactor (SMR) of KLT-40S and was launched commercially in 2020. The reactor is placed inside a ship called a floating power unit (FPU). Located in Pevek, Russia, the Akademik Lomonosov can also be converted for purposes other than electricity production, namely desalination plant and district heating [16]. Figure 1 shows the common layout of the onshore FNPP.

As shown in Figure 1, among the notable differences between the FNPP and the land-based NPP is the location of the reactor and auxiliary systems. While the land-based NPP has the whole system on the land, the locations of the systems for the FNPP are on the FPU. In addition, the FPU in the Akademik Lomonosov has several compartments including the reactor compartment, the control room, the fuel handling compartment, and the turbine compartment [17]. The FPU is also anchored to the dock with a mooring system to ensure its stability to overcome the impact of the wave. However, the FNPP still has several structures and systems on the land, namely the transmission system. Compared with the land-based NPP, the FNPP has advantages and disadvantages. Advantages of the FNPP include [18,19]:

• Transportable and moveable;
• Free from the limitation of water depth;
• Manufactured and tested at shipyards, utilizing industrial technologies to enhance quality and reduce costs efficiently;
• The design meets nonproliferation requirements as repairs, refueling, and waste handling occur at specialized facilities during the FNPP overhaul;
• Can be decommissioned and replaced with new FNPPs while preserving existing shore-based infrastructure; and can eventually be disposed of at the supplier’s designated facilities.

Meanwhile, the disadvantages of the FNPP include [18]:

• Easily affected by the ocean environment;
• Requires tranquil sea areas.

3. Overview of NPP Licensing Regulation in Indonesia

Act Number 10 Year 1997 and Act Number 6 Year 2023 are the highest level of regulations related to nuclear energy. These regulations state that any nuclear energy utilization should have a license through Bapeten as the regulatory body [20,21]. Furthermore, the licensing process of any nuclear power plant (NPP) including the FNPP, is regulated in the second highest level of regulations, the GR. To date, the GRs that regulate the licensing of the NPP in Indonesia are GR Number 2 Year 2014 and GR Number 5 Year 2021. In Indonesia, the GR is developed in a more general approach and is less technical. This means that the requirements of the GRs will be discussed on the simplification of the process, coordination and roles between the institutions, economic efficiency, administration, etc. The more technical requirements such as design requirements will be detailed in the lower level of regulations. The lower level of regulation for nuclear energy is the Bapeten Regulation (BR). The hierarchy of nuclear energy regulation in Indonesia is described in Figure 2.

Based on the GRs, the basic licensing process of the NPP in Indonesia includes several stages, namely the deployment, operation, and decommissioning license [22,23]. Furthermore, the deployment license includes the siting and construction license, and the operation license includes the commissioning and operating license. Overall, the licenses of nuclear installations in Indonesia include siting, construction, commissioning, operating, and decommissioning, respectively.

To get into the context, every license phase will be described based on the regulations as follows. The siting process includes the site evaluation and reactor design information provision. This phase is performed to obtain information on the site information and the site-specific risk that might be received by the reactor. Construction is the activity of building a nuclear installation at a designated site, which includes architectural, civil, mechanical, electrical, environmental management work, installation, and testing of structures, systems, and components (SSC) of the nuclear installation without nuclear material. Commissioning is the testing activity to demonstrate that the installed structures, systems, and components of a nuclear installation operated with nuclear material meet the design requirements and criteria. Operating is the normal operation stage, where the reactor operates according to its purpose. Decommissioning is an activity to permanently cease the operation of a nuclear reactor, which includes, among other things, the removal of nuclear fuel from the reactor core, dismantling of reactor components, decontamination, and final securing of the site. These phases might be different from other regulations in different countries. Additionally, in Indonesia, the nuclear reactor is categorized as a powered and nonpowered reactor. The NPP is included as the powered reactor.

4. Discussion

From the study of the current GRs and the references, the parts that need to be adjusted and the suggestions that might be considered for the revisions of the GRs will be described based on the licensing phase of an NPP.

4.1. Siting Phase

Commonly, any GRs will start with the definitions chapter, which includes any terms that must be explained before the detailed requirements. This explanation is important to clarify the meaning of terms, limit the scope of the regulation, and avoid ambiguity. Based on the review, it is found that the definition of “site” in the GRs does not consider the FNPP technology. Recently, a “site” has been defined as “a location on land used for the construction, operation, and decommissioning of one (1) or more nuclear installations along with other related systems”. The using of “a location on land” sentence in the definition will generate many problems in the future in relation to FNPP development as the FNPP has a water surface as its site. Revising the definition should be easier as the definition is not stated in the Acts.

Based on the GRs, one of the reports that needs to be provided in this phase is the site evaluation report. Among the aspects of site evaluation are the impact of natural and human-induced events on the safety of nuclear reactors and the characteristics of the site and surrounding areas that influence the transfer of radioactive materials released by the nuclear reactor to humans and the environment. Several natural events such as tsunamis and extreme weather might have direct impacts on the FPU. The possible accident scenario should be assessed to understand the impacts of these hazards. On the other hand, as the FPU is placed on the water surface, the dispersion through the water in an accident condition should be analyzed. These details should have a different focus compared with the land-based NPP. However, even though the details of the reports will be different from the land-based NPP, the process is still similar. Therefore, the revision on the GRs for this does not have to be changed. The detailed requirements can be stated in the BR.

According to the report by Lobner, the deployment phase of the Akademik Lomonosov started in 2007 when the construction was held in Severodvinsk before being transferred to the Baltic Shipyard in St. Petersburg in 2008. Once the work on the vessel and reactor systems was finished in April 2018, the Akademik Lomonosov was towed around Norway to reach Murmansk for the fueling and testing phase. Finally, in 2019, after the completion of the test, the Akademik Lomonosov then transferred to its designated site in Pevek.

From here, it is understood that the FNPP has the possibility of having more than one site through the phases. In the Akademik Lomonosov case, the construction sites were Severodvinsk and St. Petersburg, the commissioning site was Murmansk, and the operation site was Pevek. The possibility of deploying an FNPP in more than one site is also in line with the basic advantages offered by the FNPP technology due to its ability to distribute energy to remote areas, offshore locations, and construction activities [2]. Other designs such as ACPR50S also mentioned the possibility of the FNPP having more than one site [24].

The current GRs do not specify this phenomenon. As the unique nature of the FNPP, the possibility of having more than one site should be considered to be addressed and regulated in the GRs revision. The graded approach should be performed to regulate the siting process based on the possible scenarios. Based on the Akademik Lomonosov case and the concept of ACPR50S, the siting scenarios can be categorized as:

• Same site for the whole NPP phase (from the construction to the decommissioning phase). In this scenario, the siting phase follows the current process in the GRs.
• Different sites for the different phases. As mentioned, the example case of different sites for the different phases is the Akademik Lomonosov FNPP deployment. The common case for the SMR is that the modular assembly will be performed at the factory site and then delivered to the importing countries. In the Akademik Lomonosov case, the commissioning was also carried out at a different site. In this scenario, if there is a phase performed in different sites in Indonesia, the siting license should be proposed for every site used. Even though the operation has not taken place, the presence of nuclear material in the site starting from the commissioning phase will raise the concern of nuclear safety. However, China General Nuclear Power Group explained that different phases in different sites might have different siting requirements [24]. One of the purposes of the site evaluation is to understand the risks that might be sustained in nuclear activity.
• Different sites during the operating phase. In this scenario, the FNPP is already constructed and has the purpose of supplying power to several places at a different time. This scenario might happen if the FNPP is constructed to support the refinery or exploration activity. In this case, the purpose of the FNPP should be stated from the beginning by the license applicant. The license applicant should then make the site evaluation of the whole sites that will be used. The other site-specific documents in the next phases such as Safety Analysis Reports (SAR), nuclear emergency documents, and safeguards system documents should be prepared to accommodate the whole site. Despite that, the revision of the GRs should also provide the opportunity for the license applicant to add more sites after the operating phase through the license update process.

These scenarios along with their requirements can be included in the technical requirements to obtain the siting license in the revised GRs. The license applicant should state the siting scenario that they will use. Furthermore, the site definition of the GRs should also accommodate the possibility of the site only functioning in some phases. Thus, the definition of the site should be changed to “a location used for the construction, operation, and/or decommissioning of one (1) or more nuclear installations along with other related systems”. The “and/or” words will give the flexibility of the site to utilize for only one phase. This policy will be beneficial related to the purpose of the FNPP to deliver electricity to the remote islands. As the remote islands do not have the proper technology and infrastructure to perform the construction and commissioning phases, the two might be performed outside the operation site. Economically, this scenario might also be beneficial as the contractor does not have to move heavy equipment to the remote islands which could be very far from the main island.

On the other hand, the possibility of employing more than one site will also raise a concern regarding the safeguards and the security aspects. Several phases such as the construction, the commissioning, and the operating phase require documents, namely the safeguards system documents and physical protection plan documents. While the documents should include the site-specific risks, the risks when the FNPP is transported from one site to another should also be regulated. Basically, Indonesia also has another GR regarding the transportation of nuclear material. However, in the case of the FNPP having more than one site, this phenomenon should be excluded from the transportation regime in order to simplify the licensing process. Therefore, in this case, the license applicant should provide the safeguards system documents and physical protection plan documents that include the pathway, strategy, and plan when the FNPP is transferred from one site to another.

4.2. Construction and Commissioning Phase

The FNPPs developed recently are categorized as small modular reactors (SMRs). One of the most promising features of a SMR is the modularity and the possibility of the reactor being partially constructed outside the operation site or even in a different country, making the construction process inside the site less complicated and reducing the overall construction time. This issue is not considered in the current GRs. In the case of the FNPP, based on the experience of the Akademik Lomonosov, the FPU of the FNPP was already built and tested outside the operation site. The only additional work needed to be performed is the construction of the grid system and other supporting systems [3].

Based on this information, there are several scenarios for the FNPP regarding the construction phase:

• The FNPP will be constructed on the same site as the other phases. In this scenario, the construction phase follows the current process in the GRs. Due to the process effectiveness, it is assumed that the commissioning phase will also be performed on the same site.
• The FNPP will be constructed and commissioned outside the operation site in Indonesia. This is the scenario used by the Akademik Lomonosov, regardless of the travel path around Norway. The construction and the commissioning phase can be performed on the same site or a different site. If they are using the same site, it should be considered to combine those phases into one phase to simplify the process. If they are performed on a different site from each other, the site-specific documents should be provided for the commissioning phase only as the construction phase has not included the nuclear material. These site-specific documents will be important to understand the challenge to nuclear safety from the site. However, the high number of documents required and its repetition through the phases has been a concern for years in the licensing process around the world, including in Indonesia. In the GRs, it can be found that documents such as SAR, management system documents, and nuclear emergency programs are stated in the construction, commissioning, and operating phases. The repetition of the same documents should be reduced to increase the effectiveness of a nuclear program.
• The FNPP will be constructed and/or commissioned outside the operation site in a foreign country. In this scenario, the construction and commissioning licensing process might be neglected and combined into one additional phase containing important information regarding safety and project sustainability. The documents mentioned in the GRs should still be required, excluding the construction program and the commissioning program. In the case that only the construction phase is performed in a foreign country, the existing phases still follow the current process in the GRs with the exclusion of the construction program document.

These scenarios along with their requirements can be included in the technical requirements to obtain the construction and commissioning license in the revised GRs. The license applicant should state the scenario that they will use. Regarding this, the definition of construction should also be changed to “the activity of building a nuclear installation at a designated site, partially or completely, which includes architectural, civil, mechanical, electrical, environmental management work, installation, and testing of SSC of the Nuclear Installation without Nuclear Material”.

The addition of “partially or completely” sentence will give more flexibility to certain scenarios such as scenarios 2 and 3, since several SSCs such as the foundation, support, and other safety systems such as the anchoring system might be constructed separately from the reactor.

4.3. Operating Phase

In the operating phase, there are some documents and reports related to safety that need to be submitted in the operating licensing process. These documents include SAR, nuclear emergency documents, safeguards system documents, etc. As mentioned before, these documents are also required for the previous phases. For the FNPP, the additional required documents do not have to be carried out since they are the basic documents that need to be provided by the utility to ensure safety. However, the details regarding the FNPP should be mentioned.

Among the documents or reports that need the details regarding the FNPP are the SAR, safeguards system documents, physical protection plan documents, decommissioning program, and nuclear emergency documents. The decommissioning program will be discussed in the decommissioning phase subsection. These documents and reports contain a few chapters that are described in the appendix section of the GRs. Thus, the revision of the chapters should be stated in the appendix section.

4.3.1. SAR

The SAR contains the chapters that need to be provided by the license applicant. Within these chapters, the chapters that need to provide more detailed regulations regarding the FNPP are site characteristics, building and structure, operation implementation, environmental management and monitoring plan, safety analysis, decommissioning, and emergency preparedness and response.

The site characteristics, building and structure, operation implementation, environmental management and monitoring plan, safety analysis, decommissioning, and emergency preparedness and response chapters are related to the possibility of the FNPP having more than one site. If the operation is running in more than one site, each chapter needs to mention and explain the consequences of having more than one site for safety in each chapter.

In more detail, the building and structure chapter should require the license applicant to provide the structure to ensure the stability of the FPU. The FPU is placed next to an anchoring system and docks [13,17,24]. The anchoring system and the docks must be designed well to ensure that the FPU is not significantly affected, even under extreme wave and weather conditions. As the FPU is placed on the seabed, the probability of having a high wave should be measured, especially in bad weather.

In the safety analysis chapter, the analysis needs to be carried out considering the potential instability of the FNPP. The instability might be caused by either natural hazards such as extreme weather, tsunamis, and earthquakes, or human-induced events such as ship collisions. In Indonesian regulation, the safety analysis includes the deterministic safety analysis and Probabilistic Safety Assessment (PSA). As for the PSA, the GRs stated that the PSA is performed for the commercial NPP. Along with this study, it is suggested to include in the revision that the PSA should be performed either by the commercial or noncommercial NPP considering that the PSA is important to NPP safety apart from the purpose. Back to the main issue, the instability of the FPU will lead to a change in the angle of the FNPP. The study performed by Cusmanri (2024) described that in a tsunami event, one of the scenarios that might happen to an FNPP is capsizing [9]. Figure 3 shows the capsizing scenario. The deterministic analysis should be performed to analyze the influence of the angle on thermal–hydraulic aspects.

On the other hand, the unique nature of the FNPP, as common as the regular ship, is the possibility of sinking. Unlike the land-based NPP, the FNPP has the risk of sinking if hazards happen. The sinking usually happens due to severe damage to the ship’s body. In the case of the FNPP, the damage might happen either by an internal or external hazard that has the scenario of direct contact with the FPU, namely a tsunami, ship collisions, missiles, etc. The concern about the sinking phenomena is raised due to the complexity of the mitigation process once it occurs. More equipment and arrangements should be provided to capture the FPU underwater. In addition to the safety analysis chapter, this situation should also be addressed in the emergency preparedness and response chapter. The safety analysis should consider this phenomenon either for deterministic analysis or the PSA. Regarding the PSA, based on the sinking risk, the revision of the GRs should introduce the requirement of providing the sinking frequency (SF) to the PSA. As the common PSA outputs are the core damage frequency and large early release frequency, the introduction of the SF to the nuclear industry will be a revolutionary step taken by a regulatory body. The study of sinking probability is commonly performed in the maritime sector [25].

4.3.2. Safeguard System Documents

The concern regarding the safeguard is related to the possibility of utilizing more than one site as the safeguard system documents include the material balance area and the receipt and shipment of nuclear material. The license applicant must cover the whole site regarding the material balance area and the movement of nuclear material between the sites.

4.3.3. Physical Protection Plan Documents

The concern regarding the physical protection plan is related to the possibility of utilizing more than one site as the physical protection plan documents include the design and division of physical protection areas and the contingency plan. The license applicant must cover the whole site regarding the physical protection areas. Additionally, the applicant should provide a contingency plan to anticipate emergencies or threats for each site.

4.3.4. Emergency Preparedness and Response

The concern regarding emergency preparedness and response is related to the possibility of utilizing more than one site. The license application should provide a plan to arrange the emergency response for each site. The related infrastructure must also be provided in each site including the emergency control center. Periodic rehearsal also needs to be held at every site.

4.4. Decommissioning Program

In the GRs, decommissioning is defined as “an activity to permanently cease the operation of a nuclear reactor, which includes, among other things, the removal of nuclear fuel from the reactor core, dismantling of reactor components, decontamination, and final securing”. There has been a discussion among the references regarding the options of returning the reactor as it is without dismantling the reactor components [26]. In this case, the safeguards and physical protection plan must cover the pathway of the returning reactor until it leaves the state border including the transit plant, if any. Recently, the GRs have not stated the option of performing the decommissioning outside the site. However, other activities such as environmental management and monitoring, radioactive waste management, final radiological survey, and other activities related to the site still need to be performed. In conclusion, the definition of decommissioning should be revised to accommodate this scenario.

The concern regarding the decommissioning is also related to the possibility of utilizing more than one site. The license application should declare which site will be the final site and the decommissioning program will be performed on the site. Nonetheless, the decommissioning program still needs to be carried out at other sites, as it includes environmental management and monitoring and a final radiological survey.

4.5. Derivative Regulations Regarding the FNPP

In Indonesia’s regulation system, the GR is developed with a more general approach and less technical. To regulate more technical requirements, the GR usually includes clauses stating that the more detailed requirements will be regulated at lower regulation levels. For the nuclear energy sector, the lower regulation level is the Bapeten Regulation (BR).

Through the years, Bapeten has published many BRs related to the NPP, namely the Safety Requirements for Power Reactor Design, Design Provisions for Fire and Internal Explosion Protection Systems in Power Reactors, Safety of Power Reactor Core Design, etc. Most of the requirements in these BRs are practicable for most of the reactor design. However, several aspects need to be adjusted to make it more appropriate for the FNPP, considering the difference in the nature and characteristics of the FNPP. For example, the common understanding of the Emergency Planning Zone (EPZ) area is the horizontal radius from the reactor. In the case of the FNPP, the axial radius should be included in the regulation due to the EPZ’s role in food sampling activities [10]. Moreover, as the FNPP might have different sites for each phase, the siting requirements will be different. For example, in the construction site, the water intake and outlet are required while they are not required for the operation site [24]. However, for the BR to accommodate the technical requirements of the FNPP, Bapeten can consider compiling the specific requirements in one BR and does not have to revise the related BRs. This approach will lead to regulation simplification. The other BRs can be used as general guidance as long as it is not specified in the FNPP regulation.

5. Conclusions

The review of the GRs regarding the licensing process of the nuclear power plant has been performed. The review of the references related to nuclear safety, FNPP technology, and maritime safety was also completed. From the review of the GRs, it is understood that the general stages of the NPP licensing process in Indonesia are the siting, construction, commissioning, operating, and decommissioning phases. This study provides suggestions that need to be considered in the revision of the GRs regarding specific requirements for the FNPP. The suggestions are delivered based on the stages of the licensing process.

For the siting phase, the suggestion was made for the definition of “site”. The possibility of using more than one site should be also addressed in the GR revision. Related to this, the using of more than one site is also the finding of this study for the construction and commissioning phase, as the construction and commissioning phase might be performed on a different site from the other phases based on the case of the Akademik Lomonosov.

The concern of utilizing more than one site was also discussed in the operating phase. With the possibility of the FNPP being operated in more than one site, the documents related to safety, security, safeguards, and emergency preparedness and response must include the whole site used. Additionally, the unique nature and characteristics of the FNPP should also be addressed in the safety analysis. The unique nature and characteristics include the specific infrastructure, sinking probability, and instability of the ship during extreme conditions.

Lastly, a specific lower regulation specifically for the FNPP as the more technical requirements for the FNPP should be developed. To simplify the regulation, the BR for the FNPP can be developed in one BR only, as the other requirements for the general NPP are practicable for the FNPP and only need some more specific requirements.