DI-29 The licensee shall define and
implement an appropriate program
(e.g. through R&D, investigations,
modelling, testing and monitoring
activities) with the purpose of providing 
anunderstanding ofthe evolution of
the disposal system adequate forthe
safety case./Ref 19/ §9 (1), §3 (2), §20 (1),(2),(3)
/Ref 19/ §9 (1)
(1) When exploring the disposal site, the data on the properties of the site, which are essential for the safety of the 
disposal facility, collected in a quality-assured manner and to an extent sufficient for the safety analysis report. The 
proposed quality assurance must correspond to the state of the art in science and technology. The range of variation of 
the data collected shall be determined and its possible change during construction, operation and closure of the disposal 
facility as well as during the assessment period estimated.A /Ref 19/ §9 (1), §3 (2), §20 (1),(2),(3) comply with DI-
29. 
A monitoring and exploring programme shall be 
used during construction, operation, closure and a 
limited time after closure to verify the adequacy of 
the underlying safety cases.
The expected and deviating developments of the 
disposal system and the geological situation at the 
disposal site relevant for the design of the disposal 
facility and the assessment of long-term safety 
within the assessment period have to be 
determined systematically.
/Ref 19/ §3 (2)
(2) The developments of the disposal system and the geological situation at the disposal site relevant for the design of the 
disposal facility and the assessment of long-term safety within the assessment period shall be systematically determined, 
described and classified as
1. expected developments or
2. deviating developments.
The classification shall be justified.
/Ref 19/ §20 (1),(2),(3)
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In 
particular, monitoring shall control those observable parameters that can indicate early deviations from the expected 
developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary 
safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site 
Selection Act, as well as the foreseeable future information needs.(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the 
disposal site according to § 9. The results of the monitoring shall be documented.
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the 
Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the 
existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered. Each update shall also show what development needs exist for the used and possible new monitoring methods and how this should be considered
/Ref 17/ Chapter 2.1 and 2.4, /Ref 19/ §17, §19 (2)
/Ref 17/ Chapter 2.1
... For safe performance of the operational processes, the entire operation shall be structured and organised appropriately. 
For this purpose, the following requirements are to be met:
• All operational  processes  shall be clearly described,
• interactions  between  the individual  operational  processes  shall be considered,
• ...
/Ref 17/ Chapter 2.4
Particular consideration is to be given to aspects relating to operational safety due to the parallel excavation of underground cavities and the emplacement of waste packages.
Underground cavities are to be driven in a manner designed to minimise any damage to the host rock. When conducting 
excavation and mine support work, is should be ensured that the barrier effectiveness of later sealing structures is not 
affected by, for example, damage to the rock.
/Ref 19/ §17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be systematically determined , described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or
4. beyond design basis accidents and events.
(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part of 
the safety concept.
(3) The safety concept shall provide for
1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence of 
other facility conditions,
2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal operation,
3. measures for design basis accidents in accordance with § 104(1) sentence 1 and 2 of the Radiation Protection Ordinance 
of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal facility in a 
safe facility condition,4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.
/Ref 19/ §19 (2)
(2) The closure of the disposal facility shall include, in particular, the complete backfilling of all underground cavities and 
their sealing as well as the dismantling of the technical facilities that impair long-term safety.
DI-31 The licensee shall ensure that any
measures necessary forthe purpose of
accounting forand control ofnuclear
material shall not unacceptably affect
operational and post -closure safety./Ref 6/ Article 7, /Ref 19/ §11 (1), (4) and (5), §20 (3), (4)
/Ref 6/ Article 7
1. Each Contracting Party shall establish and maintain a legislative and regulatory framework to govern the safety of nuclear 
installations.2. The legislative and regulatory framework shall provide for:
(i) the establishment of applicable national safety requirements and regulations;
(ii) a system of licensing with regard to nuclear installations and the prohibition of the operation of a nuclear installation 
without a licence;
(iii) a system of regulatory inspection and assessment of nuclear installations to ascertain compliance with applicable 
regulations and the terms of licences;(iv) the enforcement of applicable regulations and of the terms of licences, including suspension, modification or 
revocation.A
/Ref 19/ §11 (1), (4) and (5)
(1) The technical design of the disposal facility shall be derived and optimised from the safety concept. In particular, it shall 
include the following:
1. the definition of the main barriers according to § 4(3), considering the waste packages, the emplacement technology and 
the emplacement geometry, anda) in the case of § 4(3) no. 1, location and dimensions of the containment-providing rock zone orb) in the case of § 4(3) no. 2, specifications of the main technical and geotechnical barriers,
2. the definition of other barriers of the disposal system, considering the waste packages, the emplacement technology and 
the emplacement geometry,3. the positioning and technical execution of all underground cavities, in particular of the areas intended for the emplacement of waste packages, as well as of all accesses to the disposal mine,
4. the specification of the installations and devices used for the handling of waste packages,5. the safety requirements for the waste packages as well as the provisions for the treatment of the waste contained 
therein according to § 3(1) sentence 2 of the Nuclear Waste Management Ordinance of 29 November 2018 (BGBI I p. 2034, 2172) as amended,
6. the emplacement concept, in particular the arrangement, handling and control of the waste packages,
7. the measures to ensure the retrievability of already emplaced waste packages, and
8. the closure measures including the sealing measures.
(4) The impact on the host rock in the disposal zone and in the case of § 4(3) no. 1 in particular the intended containment-
providing rock zone with shafts, excavations or bores shall be restricted to an unavoidable extent for the safe 
construction, safe operation and safe closure of the disposal facility.
(5) For all intended technical components of the disposal facility, the conditions for safe operation shall be documented, 
justified and considered when designing the disposal facility.
/Ref 19/ §20 (3), (4)
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered . Each update shall also show what development needs exist for the used and possible new 
monitoring methods and how this should be considered.
(4) The monitoring measures must not lead to any safety-relevant impairment of the disposal system.
2.2.2 Safety issue: Site characterization/Ref 6/ Article 7, /Ref 19/ §11 (1), (4) and (5), §20 
(3), (4) comply with DI-31. Especially /Ref 19/ §20 (4) refers to the aspect that taken measures must not lead to any safety-relevant impairment of the 
disposal system.DI-30 If construction, operation,
decommissioning orclosure activities
take place concurrently, the licensee
shall perform the works sothat they
will nothave anunacceptable effect on
operational or post- closure safety.A /Ref 17/ Chapter 2.1 and 2.4, /Ref 19/ §17, §19 (2) 
comply with DI-30.
OECD-NEA IGSC Expert Group on Operational Safety 
(EGOS) questionary on Co-activties, answers from 
BfS, DBE Tec and GRS regarding regulatory framework on Co-activity: 
In Germany there is no special regulatory framework 
dealing with the management of such co-activities. But the stipulations and requirements of existing 
laws and ordinances (e.g. Atomic Energy Act /Ref 1/, 
Radiation Protection Ordinance /Ref 4/, mining law etc.) have to be met.
Seite 7 von 28

DI-32 The licensee shall prepare and
implement a program for site
characterization ofthe selected site.
The program shall provide the
information necessary tosupport the
safety case./Ref 5/ § 3(1), /Ref 19/ §9
/Ref 5/ § 3(1) 
(1) Projectdelivery organisation shall be the third party pursuant to § 9a(3) second half of sentence 2 of the Atomic Energy 
Act. The projectdelivery organisation has the task of carrying out the site selection procedure, in particular,
1. determining subareas pursuant to § 13,
2. drawing up proposals for the selection of the siting regions  and the sites to be explored pursuant to § 14(2) and § 16(3),
3. drawing up exploration programmes  pursuant to § 14(1) and § 16(2) and assessment criteria pursuant to § 16(2),
4. carrying out the surface and underground exploration pursuant to §§ 16 and 18,
5. conducting the respective preliminary safety analyses  pursuant to § 14(1), § 16(1), § 18(1) and § 26,
6. proposing the site for a disposal facility to the Federal Office for the Safety of Nuclear Waste Management pursuant to § 
18(3).A /Ref 5/ § 3(1), /Ref 19/ §9 comply with DI-32.
/Ref 19/ §9
(1) When exploring the disposal site, the data on the properties of the site, which are essential for the safety of the 
disposal facility, collected in a quality-assured manner and to an extent sufficient for the safety analysis report. The 
proposed quality assurance must correspond to the state of the art in science and technology. The range of variation of 
the data collected shall be determined and its possible change during construction, operation and closure of the disposal 
facility as well as during the assessment period estimated.
(2) All underground cavities shall be excavated with as little impact as possible on the surrounding rock and sealed after 
use in such a way that the properties of the rock relevant for the safe containment of radioactive waste in the disposal zone, in particular the containment-providing rock zone in the case of § 4(3) no. 1, are retained.(3) All created or existing cavities and bores shall be documented. This shall also apply to cavities and bores that only exist 
temporarily or that are only marginal in scope.
(4) The work shall be carried out as quickly as possible while ensuring the necessary safety.
DI-33 The licensee shall conduct site
characterisation of the selected site:•
Toestablish baseline conditions for
the site and the environment;
•Tosupport the understanding ofthe
normal evolution;
•Toidentify any events and processes
associated with the site that might
disturb the normal evolution ofthe
disposal system;•
Tosupport the understanding ofthe
effect onsafety ofany features, events
and processes associated with the
disposal system./Ref 5/ §14 (1), /Ref 19/ §11 (3)
/Ref 5/ §14 (1) 
(1) From the subareas pursuant to § 13(1), the project delivery organisationshall identify siting regions for surface 
exploration.  The project delivery organisation shall conduct representative preliminary safety analyses pursuant to § 27 
for the subareas.  On the basis of the results determined from this, the project delivery organisationshall identify favourable 
siting regions applying again the geoscientific weighing criteria pursuant to § 24. Planning-scientific weighing criteria shall be applied in accordance with the provisions in § 25. For the siting regions pursuant to (2), the project delivery 
organisationshall develop site-specific exploration programmes for surface exploration in accordance with the requirements 
and criteria pursuant to § 22 to 24 and for conducting the further developed preliminary safety analyses pursuant to § 16(1).A /Ref 5/ §14 (1), /Ref 19/ §11 (3) comply with DI-33.The selection process for a suitable site requires the 
investigation of baseline conditions and environmental impacts.
/Ref 19/ §11 (3)
(3) When designing the underground areas of the disposal facility, in particular when defining the boundaries of the containment-providing rock zone or in the case of § 4(3) no. 2 of the emplacement zone, all results of the exploration of 
the disposal site shall be considered, in particular the geological findings of the underground exploration, including their 
uncertainties and their relevance for the safety and robustness of the disposal system.
2.2.3 Safety issue: Design
DI-34 The licensee shall design the disposal
facility toestablish adisposal system
which provides operational and
post -closure safety. The licensee shall
take into account the characteristics of
the wastes tobedisposed of(e.g.:
radioactivity, heat and gasgeneration),
the feasibility ofthe technical options
and the characteristics ofthe selected
site./Ref 5/ § 18 (1), /Ref 19/ §11
/Ref 5/ § 18 (1) 
(1) The project delivery organisation shall explore the sites selected by federal law from underground in accordance with the exploration programmes. Based on the exploration results, the project delivery organisation shall conduct comprehensive preliminary safety analyses and prepare the EIA report pursuant to § 16 of the Environmental Impact 
Assessment Act.A /Ref 5/ § 18 (1), /Ref 19/ §11 generally comply with 
DI-34. Especially /Ref 19/ §11 refers to the 
consideration of waste packages and emplacement 
tecnology.
/Ref 19/ §11
(1) The technical design of the disposal facility shall be derived and optimised from the safety concept. In particular, it 
shall include the following:
1. the definition of the main barriers according to § 4(3), considering the waste packages, the emplacement technology 
and the emplacement geometry, and
a) in the case of § 4(3) no. 1, location and dimensions of the containment-providing rock zone orb) in the case of § 4(3) no. 2, specifications of the main technical and geotechnical barriers,
2. the definition of other barriers of the disposal system, considering the waste packages, the emplacement technology 
and the emplacement geometry,
3. the positioning and technical execution of all underground cavities, in particular of the areas intended for the emplacement of waste packages, as well as of all accesses to the disposal mine,
4. the specification of the installations and devices used for the handling of waste packages,
5. the safety requirements for the waste packages as well as the provisions for the treatment of the waste contained therein according to § 3(1) sentence 2 of the Nuclear Waste Management Ordinance of 29 November 2018 (BGBI I p. 2034, 
2172) as amended,
6. the emplacement concept, in particular the arrangement, handling and control of the waste packages,
7. the measures to ensure the retrievability of already emplaced waste packages, and8. the closure measures including the sealing measures.
(2) It shall be shown that the optimisation of the design of the disposal facility has been completed in accordance with § 
12(2).
(3) When designing the underground areas of the disposal facility, in particular when defining the boundaries of the containment-providing rock zone or in the case of § 4(3) no. 2 of the emplacement zone, all results of the exploration of 
the disposal site shall be considered, in particular the geological findings of the under-ground exploration, including their 
uncertainties and their relevance for the safety and robustness of the disposal system.(4) The impact on the host rock in the disposal zone and in the case of § 4(3) no. 1 in particular the intended containment-providing rock zone with shafts, excavations or bores shall be restricted to an unavoidable extent for the safe 
construction, safe operation and safe closure of the disposal facility.
                  DI-35 The licensee shall establish adesign
basis forthefacility taking into account
normal operational conditions,
anticipated operational occurrences
and possible accidents derived from a
relevant set ofpostulated initiating
events (PIEs). /Ref 19/ § 17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be 
systematically determined, described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or4. beyond design basis accidents and events.(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part 
of the safety concept.(3) The safety concept shall provide for
1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence of other facility conditions,
2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal operation,
3. measures for design basis accidents in ac-cordance with § 104(1) sentence 1 and 2 of the Radiation Protection Ordinance of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal 
facility in a safe facility condition,
4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.
(4) The measures must not significantly and no more than inevitably impair the long-term safety of the disposal system.A /Ref 19/ § 17 comply with DI-35. 
Seite 8 von 28

DI-36 The licensee shall design the disposal
facility giving due consideration toboth
normal evolution of the disposal system 
after closure and scenarios involving
events and processes that might
disturb the normal evolution ofthe
disposal system. /Ref 19/ § 17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be 
systematically determined, described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or
4. beyond design basis accidents and events.
(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part 
of the safety concept.
(3) The safety concept shall provide for
1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence 
of other facility conditions,
2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal operation,
3. measures for design basis accidents in ac-cordance with § 104(1) sentence 1 and 2 of the Radiation Protection 
Ordinance of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal 
facility in a safe facility condition,
4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.
(4) The measures must not significantly and no more than inevitably impair the long-term safety of the disposal system.A /Ref 2/ chapter 6 and Par. 7.2 comply with DI-36.
DI-37 The licensee shall design the disposal
facility giving due consideration to
disturbances ofthe disposal system
during operation whose consequences
may affect post -closure safety./Ref 19/ §11 (4), (5), §12 (1), (2), §9 (2) 
/Ref 19/ §11 (4), (5)
(4) The impact on the host rock in the disposal zone and in the case of § 4(3) no. 1 in particular the intended containment-
providing rock zone with shafts, excavations or bores shall be restricted to an unavoidable extent for the safe construction, 
safe operation and safe closure of the disposal facility.
(5) For all intended technical components of the disposal facility, the conditions for safe operation shall be documented, 
justified and considered when designing the disposal facility.A /Ref 19/ §11 (4), (5), §12 (1), (2), §9 (2) comply with 
DI-37.The expected range of possible developments 
affecting the disposal system and events that might 
affect its performance, including those of low 
probability, have to be considered in the safety case and during operation. 
/Ref 19/ §12 (1), (2)
(1) The safety concept and the technical design of the disposal facility shall be optimised considering all circumstances of the individual case and respecting the balance of measures to achieve the following objectives:
1. the long-term safety of the disposal facility, in particular the quality of the safe containment of radioactive waste and 
the robustness of the disposal system, and
2. the operational safety of the disposal facility.
(2) The optimisation is complete when a further improvement of safety can only be achieved with disproportionate effort.
/Ref 19/ §9 (2)
(2) All underground cavities shall be excavated with as little impact as possible on the surrounding rock and sealed after 
use in such a way that the properties of the rock relevant for the safe containment of radioactive waste in the disposal 
zone, in particular the containment-providing rock zone in the case of § 4(3) no. 1, are retained.
DI-38 The licensee shall design the disposal
facility tofulfil the following safety
functions during the operational and
post -closure phases:
•Control oftheexposure ofpeople and
the environment;•
Containment and isolation of
radioactive material;•
Control ofsub-criticality, ifapplicable;
Ifburnup credit isadopted forcriticality
management, thelicensee shall confirm
compliance with the limiting minimum
burnup level with respect toinitial
enrichment by administrative and
operational controls;
• Heat or gas removal,  if applicable./Ref 4/ § 1, /Ref 19/ §4 (1), (2), §7 (1), §8 (1), §6 (2),(3), §11 (1)
/Ref 4/ § 1 
The purpose of this Ordinance is to regulate principles and requirements of preventive and protective measures which apply to the use and effects of man-made and naturally occurring radioactive substances and ionizing radiation in order to 
protect man and the environment from the harmful effects of ionizing radiation. A /Ref 4/ §1 provides the general provisions and 
purpose of the Radiation Protection Ordinance to 
regulate the handling of radioactive substances. 
/Ref 19/ §4 (1), (2), §7 (1), §8 (1), §6 (2),(3), §11 (1) 
comply with DI-38 with regard to safety fuctions 
during the post-closure phases.
/Ref 19/ §4 (1), (2)
(1) The radioactive waste to be emplaced shall be concentrated in the disposal system with the aim of safely enclosing the 
radionuclides contained therein from the biosphere at least in the assessment period.
(2) The intended disposal system shall ensure the safe containment of the radioactive waste passively and maintenance-
free through a robust, graded system of different barriers with different safety functions.
/Ref 19/ §7 (1)
(1) It shall be examined and shown that exposures due to discharges of radionuclides from the emplaced radioactive 
waste are marginal compared to the natural radiation exposure. For this purpose, it shall be shown in which area 
additional radiation exposure can occur. As an indicator, the additional effective annual dose for individuals of the 
population shall be estimated that can occur during the assessment period due to discharges of radionuclides from the 
emplaced radioactive waste. The living conditions at the time of application shall be assumed for the entire assessment 
period.
/Ref 19/ §8 (1)
(1) It shall be examined and shown that self-sustaining chain reactions during the operation and closure of the disposal 
facility as well as for the expected and deviating developments in the assessment period are excluded.
/Ref 19/ §6 (2), (3)
(2) With regard to the integrity of the system of the main technical and geotechnical barriers, it shall be examined and shown that the safety functions of the main technical and geotechnical barriers are not significantly affected by
1. the hydraulic, chemical and physical processes that may occur in the emplacement zone, particularly corrosion and erosion,
2. tensions, pressures and possible rock movements occurring in the surrounding rock, and
3. the temperature development.
(3) The geological and hydrogeological environment, the properties of other barriers of the disposal system and the 
properties of the waste to be emplaced shall be considered in the examination and presentation.
DI-39 The licensee shall identify and classify 
engineered structures, systems and 
components (SSCs) in accordance with their importance for operational and 
post -closure safety./Ref 17/ Chapter 2.1, /Ref 19/ §6, §11 (1)
/Ref 17/ Chapter 2.1
The documentation of the operational phase of the disposal facility includes all the information and evidence 
demonstrating the safe operation of the facility and compliance with the safety functions in terms of radiological safety and 
mining safety. It includes, in particular,• mine book/operating  manual, testing manual including test reports for safety-relevant  structures,  systems and 
components, radiation protection instructions, • ...B /Ref 17/ Chapter 2.1 requires the relevant 
documentation requiring test reports for SSCs. 
/Ref 19/ §6 and §11 (1) cover essential technical and 
geotechnical barriers.
/Ref 19/ §6
(1) In the case of § 4 Paragraph 3 Number 2, the integrity of the system of essential technical and geotechnical barriers must be examined and presented for the expected developments during the evaluation period, and its robustness 
justified. The properties of the further barriers of the disposal system, and particularly of the containment-providing rock zone, which are relevant for the safe containment of radioactive waste, must be specified. It must be examined and 
shown that these properties are retained at least in the period in which they are required according to the safety concept.(2) With regard to the integrity of the system of essential technical and geotechnical barriers, it must be examined and 
shown that the safety functions of the essential technical and geotechnical barriers are not significantly affected by1. the hydraulic, chemical and physical processes that may occur in the emplacement zone, particularly corrosion and 
erosion,
2. tensions, pressures and possible rock movements occurring in the surrounding rock and
3. the temperature development.
(3) The geological and hydrogeological environment, the properties of the further barriers of the disposal system and the 
properties of the waste to be emplaced must be considered when testing and presenting.
(4) The properties of the essential technical and geotechnical barriers required for long-term safety must be specified in 
the safety concept. It must be examined and shown that the production and construction of the barriers according to 
these specifications is possible in the required number in a quality-assured manner. The proposed quality assurance must 
correspond to the state of the art in science and technology. The manufacture and construction of the barriers must be 
successfully tested under realistic conditions. Their function under these conditions must be examined and shown.
Seite 9 von 28

/Ref 19/ §11 (1)
(1) The technical design of the disposal facility shall be derived and optimised from the safety concept. In particular, it 
shall include the following:
1. the definition of the main barriers according to § 4(3), considering the waste packages, the emplacement technology 
and the emplacement geometry, and
a) in the case of § 4(3) no. 1, location and dimensions of the containment-providing rock zone or
b) in the case of § 4(3) no. 2, specifications of the main technical and geotechnical barriers,
2. the definition of other barriers of the disposal system, considering the waste packages, the emplacement technology 
and the emplacement geometry,
3. the positioning and technical execution of all underground cavities, in particular of the areas intended for the 
emplacement of waste packages, as well as of all accesses to the disposal mine,
4. the specification of the installations and devices used for the handling of waste packages,
5. the safety requirements for the waste pack-ages as well as the provisions for the treatment of the waste contained therein according to § 3(1) sentence 2 of the Nuclear Waste Management Ordinance of 29 November 2018 (BGBI I p. 2034, 
2172) as amended,
6. the emplacement concept, in particular the arrangement, handling and control of the waste packages,
7. the measures to ensure the retrievability of already emplaced waste packages, and
8. the closure measures including the sealing measures.
/Ref 12/ § 55, /Ref 1/ § 7(2) 3., § 19a (3), (4), /Ref 4/ Par. 49 (1) and 49 (2), /Ref 19/ §5 (4), §6 (4), §9 (1), §12 (4)
/Ref 12/ § 55
(1) The authorization of an operation plan referred to in § 52 is to be granted if the necessary precautions against threats to life, health and the protection of material goods, workers and third parties during the operation, in particular by the 
corresponding measures of the generally recognized rules of safety technology
, is to ensure that the existing rules or those 
enacted under this law for the construction and the operation are complied with other health and safety regulations, ...
/Ref 1/ § 7(2) 3.
(2) A licence may only be granted if
... 
3. the necessary precautions have been taken in the light of the state-of-the-art of science and technology to prevent 
damage resulting from the erection and operation of the installation.
/Ref 1/ § 19a (3), (4)
(3) Anyone who operates any nuclear installation pursuant to § 2, para. (3a), subpara. 1 shall perform a verification and evaluation of the nuclear safety of the respective installation every ten years and shall improve nuclear safety of the 
installation continuously. The results ot the verification and evaluation shall be submitted to the supervisory authority.
(4) The evaluation according to para. (1) or (3) shall encompass the verification that measures are taken to prevent 
accidents and to attenuate the effects of accidents including the verification of the physical barriers as well as of the 
administrative preventions of the licencee which would have to fail before life, health and material assets are damaged by 
the effect of ionising radiation. The competent supervisory authority can issue orders concerning the extent of the verification and evaluation by the licencee.
/Ref 4/ Par. 49 (1) and Par. 49 (2)
(1) […] The state of the art shall determine sufficient precautions against design basis accidents in accordance with the first 
sentence. […](2) Para. (1), first and second sentences shall also apply ... for federal facilities for the safeguard and final disposal of 
radioactive waste.
/Ref 19/ §5 (4)
(4) The properties of technical or geotechnical barriers required for long-term safety shall be specified in the safety concept. It shall be examined and shown that the required number of barriers can be manufactured and constructed in 
accordance with these specifications in a quality-assured manner. The proposed quality assurance must correspond to the 
state of the art in science and technology. The manufacture, construction and function of the barriers must be successfully 
tested, provided that their robustness cannot be proven by other means and there are no safety margins to an extent that 
testing can be dispensed with.
/Ref 19/ §6 (4)
(4) The properties of the main technical and geotechnical barriers required for long-term safety shall be specified in the safety concept. It shall be examined and shown that the production and construction of the barriers according to these 
specifications is possible in the required number in a quality-assured manner. The proposed quality assurance must 
correspond to the state of the art in science and technology. The man-ufacture and construction of the barriers must be 
successfully tested under realistic conditions. Their function under these conditions shall be examined and shown.
/Ref 19/ §9 (1)
(1) When exploring the disposal site, the data on the properties of the site, which are essential for the safety of the disposal facility, collected in a quality-assured manner and to an extent sufficient for the safety analysis report. The proposed quality assurance must correspond to the state of the art in science and technology. The range of variation of 
the data collected shall be determined and its possible change during construction, operation and closure of the disposal facility as well as during the assessment period estimated.
/Ref 19/ §12 (4)
(4) As part of the periodic safety reviews according to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) and 
(4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety analyses. The safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and 
technology and an examination of possible alternatives to the current disposal system and its components shall be carried out. Possible measures to improve the safety of the disposal facility shall be derived from the results of the review and 
examination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.
DI-41 The licensee shall have aprocess for
identifying any conflicting design
requirements from different regulatory
regimes, and seeking to resolve them./Ref 19/ §12
(1) The safety concept and the technical design of the disposal facility shall be optimised considering all circumstances of 
the individual case and respecting the balance of measures to achieve the following objectives:1. the long-term safety of the disposal facility, in particular the quality of the safe containment of radioactive waste and 
the robustness of the disposal system, and2. the operational safety of the disposal facility.
(2) The optimisation is complete when a further improvement of safety can only be achieved with disproportionate effort.
(3) In addition to the expected and deviating de-velopments according to § 3(3) and (4), the hy-pothetical developments 
and developments based on future human activities according to § 3(6) and (7) shall also be considered when op-timising the disposal facility. It shall be ensured that measures to optimise the disposal system which are derived from deviating 
developments, do not significantly impair the safety of the dis-posal facility for the expected developments. Measures 
derived from hypothetical develop-ments must not significantly impair the safety of the disposal facility for the expected 
and for the deviating developments. Optimisation to reduce the possible effects of future human activities on the disposal system shall be performed as a matter of secondary priority.
(4) As part of the periodic safety reviews accord-ing to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety anal-yses. 
The safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and 
technology and an examination of possible alternatives to the current disposal system and its components shall be carried out. Possible measures to im-prove the safety of the disposal facility shall be derived from the results of the review and ex-
amination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.
(5) § 8 of the Radiation Protection Act of 27 June 2017 (BGBl. I p. 1966), last amended by Article 11 of the Act of 12 
December 2019 (BGBl. I p. 2510), as amended, shall remain un-affected.B There is no explicit process for identifying any 
conflicting design requirements from different 
regulatory regimes  but possible conflicting design 
requirements will be resolved due to the underlying 
optimization process of the disposal facility. /Ref 19/ §12 complies indirectly with DI-41.DI-40 The licensee shall base the design of
the facility on applicable standards,
appropriately proven techniques and
the use ofappropriate materials to
ensure that the safety requirements
will bemet, throughout operation and
post -closure.A /Ref 12/ § 55 Federal Mining Act contains the safety 
requirements to authorize operation of a facilitiy in 
geological formations. 
Seite 10 von 28

DI-42 The licensee shall design the disposal
facility so that the engineered
components (including barriers) are, to
an adequate extent, physically and
chemically compatible with each other,
with the waste disposed ofand with
the host environment. /Ref 19/ §11, §12, §5 (1), (2), (3), §6 (1), (2), (3)
/Ref 19/ §11
(1) The technical design of the disposal facility shall be derived and optimised from the safety concept. In particular, it 
shall include the following:
1. the definition of the main barriers according to § 4(3), considering the waste packages, the emplacement technology 
and the emplacement geometry, and
a) in the case of § 4(3) no. 1, location and dimensions of the containment-providing rock zone orb) in the case of § 4(3) no. 2, specifications of the main technical and geotechnical barriers,2. the definition of other barriers of the disposal system, considering the waste packages, the emplacement technology 
and the emplacement geometry,
3. the positioning and technical execution of all underground cavities, in particular of the areas intended for the 
emplacement of waste packages, as well as of all accesses to the disposal mine,
4. the specification of the installations and devices used for the handling of waste packages,
5. the safety requirements for the waste packages as well as the provisions for the treatment of the waste contained therein according to § 3(1) sentence 2 of the Nuclear Waste Management Ordinance of 29 November 2018 (BGBI I p. 2034, 
2172) as amended,
6. the emplacement concept, in particular the arrangement, handling and control of the waste packages,
7. the measures to ensure the retrievability of already emplaced waste packages, and
8. the closure measures including the sealing measures.
(2) It shall be shown that the optimisation of the design of the disposal facility has been completed in accordance with § 12(2).(3) When designing the underground areas of the disposal facility, in particular when defining the boundaries of the 
containment-providing rock zone or in the case of § 4(3) no. 2 of the emplacement zone, all results of the exploration of 
the disposal site shall be considered, in particular the geological findings of the under-ground exploration, including their 
uncertainties and their relevance for the safety and robustness of the disposal system.
(4) The impact on the host rock in the disposal zone and in the case of § 4(3) no. 1 in particular the intended containment-
providing rock zone with shafts, excavations or bores shall be restricted to an unavoidable extent for the safe 
         B  /Ref 19/ §11, §12, §5 (1), (2), (3), §6 (1), (2), (3) 
comply with DI-42.The design of the disposal facility considers a range 
of engineered components (barriers) with different 
effects and their interactions are optimized in terms 
of redundancy and diversity. 
The physical and chemical compatibility with each 
other, with the waste disposed of and with the host 
environment are addressed explicitly in /Ref 19/ §5 
(1), (2), (3) and §6 (1), (2), (3).
/Ref 19/ §12
(1) The safety concept and the technical design of the disposal facility shall be optimised considering all circumstances of the individual case and respecting the balance of measures to achieve the following objectives:
1. the long-term safety of the disposal facility, in particular the quality of the safe containment of radioactive waste and 
the robustness of the disposal system, and
2. the operational safety of the disposal facility.
(2) The optimisation is complete when a further improvement of safety can only be achieved with disproportionate effort.
(3) In addition to the expected and deviating de-velopments according to § 3(3) and (4), the hy-pothetical developments and developments based on future human activities according to § 3(6) and (7) shall also be considered when op-timising the disposal facility. It shall be ensured that measures to optimise the disposal system which are derived from deviating 
developments, do not significantly impair the safety of the dis-posal facility for the expected developments. Measures 
derived from hypothetical develop-ments must not significantly impair the safety of the disposal facility for the expected 
and for the deviating developments. Optimisation to reduce the possible effects of future human activities on the disposal system shall be performed as a matter of secondary priority.
(4) As part of the periodic safety reviews accord-ing to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) 
and (4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety anal-yses. 
The safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and 
technology and an examination of possible alternatives to the current disposal system and its components shall be carried 
out. Possible measures to im-prove the safety of the disposal facility shall be derived from the results of the review and ex-
amination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.(5) § 8 of the Radiation Protection Act of 27 June 2017 (BGBl. I p. 1966), last amended by Article 11 of the Act of 12 
December 2019 (BGBl. I p. 2510), as amended, shall remain un-affected.
/Ref 19/ §5 (1), (2), (3)
(1) In the case of § 4(3) no. 1, the integrity of the containment-providing rock zone shall be exam-ined and shown for the 
expected developments in the assessment period and its robustness justified. The containment-providing rock zone shall be 
clearly defined spatially, taking the expected developments into account. It shall be examined and shown that the 
properties of the technical and geotechnical barriers relevant for the safe containment of the radioactive waste are 
retained at least in the period in which these barriers are required according to the safety concept.
(2) With regard to the integrity of the containment-providing rock zone, it shall be examined and shown that
1. the formation of fluid pathways, which can lead to the penetration or leakage of substantial quantities of liquids or gases, 
within the contain-ment-providing rock zone is excluded; thus,a) the dilatancy strengths of the rock formations of the containment-providing rock zone outside the excavation-damaged 
zone due to expected loads must not be exceeded, and
b) the expected fluid pressures must not exceed the fluid pressure load capacities of the rock formations of the containment-providing rock zone in a manner that leads to a significant increase of fluid pathways in the containment-
providing rock zone,
2. the barrier effect of the containment-providing rock zone must not significantly be affected by the temperature 
development, and
3. the possible changes in the chemical condi-tions in the emplacement zone, particularly due to the materials brought into 
the disposal mine, must not significantly impair the barrier effect of the containment-providing rock zone.
(3) All cavities to be excavated or existing in the disposal zone and the technical and geotech-nical barriers provided for 
their sealing and plugging shall be considered during examina-tion and presentation.
/Ref 19/ §6 (1), (2), (3)
(1) In the case of § 4(3) no. 2, the integrity of the system of the main technical and geotechnical barriers shall be examined 
and shown for the expected developments during the assessment period and its robustness justified. The proper-ties of 
other barriers of the disposal system, and particularly of the containment-providing rock zone, which are relevant for the 
safe contain-ment of radioactive waste, shall be specified. It shall be examined and shown that these prop-erties are 
retained at least in the period in which they are required according to the safety con-cept.(2) With regard to the integrity of the system of the main technical and geotechnical barriers, it shall be examined and 
shown that the safety functions of the main technical and geotechnical barriers are not significantly affected by
1. the hydraulic, chemical and physical pro-cesses that may occur in the emplacement zone, particularly corrosion and 
erosion,2. tensions, pressures and possible rock move-ments occurring in the surrounding rock, and
3. the temperature development.
(3) The geological and hydrogeological environ-ment, the properties of other barriers of the dis-posal system and the 
properties of the waste to be emplaced shall be considered in the exami-nation and presentation.
/Ref 1/ § 19a (3), /Ref 13/ Par. 5.2.1, /Ref 19/ §16, §5, §6, §20
/Ref 1/ § 19a (3)
(3) Anyone who operates any nuclear installation pursuant to § 2, para. (3a), subpara. 1 shall perform a verification and 
evaluation of the nuclear safety of the respective installation every ten years and shall improve nuclear safety of the installation continuously. The results of the verification and evaluation shall be submitted to the supervisory authority.
/Ref 13/ Par. 5.2.1
(1) Maintenance measures, together with the point in time they are to be performed, shall be specified for all systems, 
components and facilities in order to help prevent safety related systems and components from failing and to enable early 
detection of their possible ageing.
(2) The maintenance measures for systems, components and facilities that are essential to safe operation shall be specified 
within a maintenance schedule. These maintenance measures shall be performed only on the basis of written instructions (e.g., maintenance instruction, work assignment sheet).
(3) Based on current findings (e.g., from the surveillance of highly stressed technical facilities, from results gained by 
diagnoses, from failure statistics and operation experience), the maintenance schedule shall be reviewed in regular intervals 
with regard to the extent and type of the listed tests and, insofar as necessary, shall be modified.
/Ref 19/ §16
(1) The operation of the disposal facility must have been successfully tested before the first acceptance of radioactive waste for the purpose of disposal.
(2) When testing the operation,1. the construction of the disposal facility must be completed in accordance with § 15,
2. the handling and emplacement of waste packages must be carried out without radioactive loading,3. the functionality of all technical facilities that are necessary for a possible retrieval of emplaced waste packages must 
be ensured and
4. the proposed technical closure and sealing measures must be available in accordance with § 11(1) no. 8.
(3) At the end of the test, the safety analysis report shall be examined.
(4) § 9(2) to (4) shall apply accordingly.DI-43 The licensee shall make design
provisions for maintenance, testing,
inspection and monitoring of
structures, systems and components
(SSCs), addressing also their ageing.A /Ref 1/ § 19a (3), /Ref 13/ Par. 5.2.1, /Ref 19/ §16, 
§5, §6, §20 comply with DI-43.
In reviewing saftey-relevant changes and assessing the safety in regulary intervals the licensee makes 
provisions for maintenance, testing, inspection and 
monitoring of structures, systems and components 
(SSCs), addressing also their ageing.
Since operation of the repository shall be measured 
against similar requirements as the operation of 
other nuclear facilities, the relevant  rule is KTA 
1402 /Ref 13/.
Seite 11 von 28

/Ref 19/ §5
(1) In the case of § 4 Paragraph 3 Number 1, the integrity of the containment-providing rock zone must be examined and 
presented for the expected developments in the evaluation period, and its robustness justified. The containment-
providing rock zone is to be clearly defined spatially taking the expected developments into account. It must be checked 
and shown that the properties of the technical and geotechnical barriers relevant for the safe containment of the 
radioactive waste are retained at least in the period in which these barriers are required according to the safety concept.
(2) With regard to the integrity of the containment-providing rock zone, it must be examined and shown that
1. the formation of fluid pathways, which can lead to the penetration or leakage of substantial quantities of liquids or 
gases, within the containment-providing rock zone is excluded; for that
a) the dilatancy strengths of the rock formations of the containment-providing rock zone outside the excavation-damaged 
zone are not exceeded due to expected loads and
b) the expected fluid pressures do not exceed the fluid pressure load capacities of the rock formations of the containment-
providing rock zone in a manner that leads to a considerable increase of fluid pathways in the containment-providing rock zone,
2. the barrier effect of the containment-providing rock zone is not significantly affected by the temperature development 
and
3. the possible changes in the chemical conditions in the emplacement zone, particularly due to the materials brought into 
the disposal mine, do not significantly impair the barrier effect of the containment-providing rock zone.
(3) All cavities to be excavated or existing in the disposal zone and the technical and geotechnical barriers provided for 
their sealing and their closure are to be considered during testing and presentation.
(4) The properties of technical or geotechnical barriers required for long-term safety must be specified in the safety 
concept. It must be examined and shown that the required number of barriers can be manufactured and constructed in 
accordance with these specifications in a quality-assured manner. The proposed quality assurance must correspond to the 
state of the art in science and technology. The manufac-ture, construction and function of the barriers must be 
successfully tested, provided that their robustness cannot be proven by other means and there are no safety margins to 
an extent that allows the abandonment of testing.
/Ref 19/ §5
(1) In the case of § 4(3) no. 1, the integrity of the containment-providing rock zone shall be examined and shown for the 
expected developments in the assessment period and its robustness justified. The containment-providing rock zone shall 
be clearly defined spatially, taking the expected developments into account. It shall be examined and shown that the 
properties of the technical and geotechnical barriers relevant for the safe containment of the radioactive waste are 
retained at least in the period in which these barriers are required according to the safety concept.
(2) With regard to the integrity of the containment-providing rock zone, it shall be examined and shown that
1. the formation of fluid pathways, which can lead to the penetration or leakage of substantial quantities of liquids or gases, within the containment-providing rock zone is excluded; thus,a) the dilatancy strengths of the rock formations of the containment-providing rock zone outside the excavation-damaged 
zone due to expected loads must not be exceeded, and
b) the expected fluid pressures must not exceed the fluid pressure load capacities of the rock formations of the 
containment-providing rock zone in a manner that leads to a significant increase of fluid pathways in the containment-providing rock zone,
2. the barrier effect of the containment-providing rock zone must not significantly be affected by the temperature 
development, and
3. the possible changes in the chemical conditions in the emplacement zone, particularly due to the materials brought into 
the disposal mine, must not significantly impair the barrier effect of the containment-providing rock zone.
(3) All cavities to be excavated or existing in the disposal zone and the technical and geotechnical barriers provided for 
their sealing and plugging shall be considered during examination and presentation.(4) The properties of technical or geotechnical barriers required for long-term safety shall be specified in the safety 
concept. It shall be examined and shown that the required number of barriers can be manufactured and constructed in 
accordance with these specifications in a quality-assured manner. The proposed quality as-surance must correspond to 
the state of the art in science and technology. The manufacture, construction and function of the barriers must be 
successfully tested, provided that their robustness cannot be proven by other means and there are no safety margins to 
an extent that testing can be dispensed with.
/Ref 19/ §6
(1) In the case of § 4(3) no. 2, the integrity of the system of the main technical and geotechnical barriers shall be examined 
and shown for the expected developments during the assessment period and its robustness justified. The properties of 
other barriers of the disposal system, and particularly of the containment-providing rock zone, which are relevant for the 
safe containment of radioactive waste, shall be specified. It shall be examined and shown that these properties are 
retained at least in the period in which they are required according to the safety concept.(2) With regard to the integrity of the system of the main technical and geotechnical barriers, it shall be examined and 
shown that the safety functions of the main technical and geotechnical barriers are not significantly affected by
1. the hydraulic, chemical and physical processes that may occur in the emplacement zone, particularly corrosion and 
erosion,2. tensions, pressures and possible rock movements occurring in the surrounding rock, and
3. the temperature development.
(3) The geological and hydrogeological environment, the properties of other barriers of the disposal system and the 
properties of the waste to be emplaced shall be considered in the examination and presentation.(4) The properties of the main technical and geotechnical barriers required for long-term safety shall be specified in the 
safety concept. It shall be examined and shown that the production and construction of the barriers according to these 
specifications is possible in the required number in a quality-assured manner. The proposed quality assurance must 
correspond to the state of the art in science and technology. The man-ufacture and construction of the barriers must be 
successfully tested under realistic conditions. Their function under these conditions shall be examined and shown.
/Ref 19/ §20
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In 
particular, monitoring shall control those observable parameters that can indicate early deviations from the expected 
developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary 
safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site Selection Act, as well as the foreseeable future information needs.
(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the 
disposal site according to § 9. The results of the monitoring shall be documented.
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the 
existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered. Each update shall also show what development needs exist for the used and possible new monitoring methods and how this should be considered.
(4) The monitoring measures must not lead to any safety-relevant impairment of the disposal system.
DI-44 The licensee shall establish design
provisions for monitoring the host
environment./Ref 19/ §20
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In particular, monitoring shall control those observable parameters that can indicate early deviations from the expected developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary 
safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site Selection Act, as well as the foreseeable future information needs.
(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the disposal site according to § 9. The results of the monitoring shall be documented.
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered. Each update shall also show what development needs exist for the used and possible new 
monitoring methods and how this should be considered.
(4) The monitoring measures must not lead to any safety-relevant impairment of the disposal system.A /Ref 19/ §20 complies with DI-44.
A monitoring programme has to be set up as early as 
possible. The environment of the disposal facility 
has to be continuously controlled.
DI-45 The licensee shall incorporate passive
safety features for operational safety
into the design ofthe disposal facility
as far as reasonably practicable./Ref 19/ §18, §8 (1)
/Ref 19/ §18(1) Only those waste packages may be brought into the disposal mine whose disposal capacity has been determined in 
accordance with § 3(1) sentence 2 of the Nuclear Waste Management Ordinance.
(2) The zone of the disposal mine used for the emplacement of radioactive waste shall be limited to the necessary extent. 
This zone shall be excavated, loaded, filled and sealed respectively without delay against the residual part of the disposal mine in accordance with the sealing concept.
(3) The handling of waste packages shall be separated from the mining work in the disposal mine and other construction 
work on the premises of the disposal facility.
(4) During operation, it must be guaranteed that the personnel requirements for a possible partial implementation of the 
closure concept, which puts the disposal facility in a passively safe state, are met at all times. The technical facilities 
required for this shall be kept available.A /Ref 19/ §18, §8 (1) require specific passive safety 
measures for the operation, e.g. limitation of used 
emplacement zone and exclusion of self-sustaining 
chain reactions.
Seite 12 von 28

/Ref 19/ §8 (1)
(1) It shall be examined and shown that self-sustaining chain reactions during the operation and closure of the disposal 
facility as well as for the expected and deviating developments in the assessment period are excluded.
/Ref 17/ Chapter 1.3, 2.1 and 2.4, /Ref 19/ §17
/Ref 17/ Chapter 1.3
On this basis, the following requirements can be derived for operation:• Shielding of the ionising radiation  in the surface and underground  facilities,
• design and construction  of the facilities such as to meet the requirements  for operation  and maintenance,
• safety-oriented  organisation  and performance  of operation,
• safe handling  and safe transport  of the waste packages,
• design against accidents  (design basis accidents),  
• measures  to mitigate the consequences  of beyond design basis accidents,
• handleability  of the waste packages according  to the requirements  of the concept for retrieval during the operational  
phase. 
/Ref 17/ Chapter 2.1
Operation also includes maintenance and repair of structures, systems, and components as well as installations for the detection and control of operational occurrences and design basis accidents, including the elimination of their 
consequences. In particular, the following operational processes have to be planned and considered for operation of the 
disposal facility:
• Above ground
- delivery of the waste packages to the disposal facility,- acceptance and handling of the waste packages in the reception area,- incoming inspection,- preparation for transport to underground, and
- handling of retrieved waste/waste packages. 
  ...
• all installations necessary for safe performance of operation shall be specified,   ...
• Maintenance  and repair
All installations of the disposal facility, such as cranes above ground, accesses to the underground area with the respective conveyor systems or mechanical equipment underground (including vehicles), requiring inspections, maintenance or 
repair have to be readily accessible or have to be made readily accessible by technical means. The spatial conditions have 
to be such that there is sufficient space available for inspections, maintenance and repair. This also involves the 
requirement that any shielding required for reasons of radiation protection can be installed and used temporarily. For the preparation, performance and documentation of this work, a maintenance and repair concept is to be developed whose 
specifications and provisions are to be included in the mine book/operating manual. 
/Ref 17/ Chapter 2.4
The installations underground are to be designed such that risks of transport processes are minimised.  The drift from the 
shaft or from the ramp to the emplacement areas and back is to be planned and designed without intersections as far as 
possible.  The traffic management and routing of the transport vehicles must ensure that the transport routes for 
emplacement can only be used in one direction to avoid accidents.Size and equipment of infrastructure facilities must ensure that all work necessary for safe operation can be performed. 
Since it may be required to establish supervised and controlled areas in the mine workings, it is to be defined in the 
planning at an early stage whether individual facilities (e.g. workshops) have to be provided separately for each area. This 
also applies to the establishment of appropriate areas within the framework of retrieval of waste/waste packages. 
/Ref 19/ §17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be 
systematically determined, described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or
4. beyond design basis accidents and events.(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part 
of the safety concept.
(3) The safety concept shall provide for
1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence 
of other facility conditions,
2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal 
operation,
3. measures for design basis accidents in accordance with § 104(1) sentence 1 and 2 of the Radiation Protection Ordinance 
of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal facility in a 
safe facility condition,
4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.
2.2.4 Safety issue: Information gathering and monitoring
/Ref 10/ § 3(1d) and /Ref 11/ § 6 Par. 3 (4) and § 14g, /Ref 19/ §20 (1), (2)
/Ref 10/ § 3(1d)
§ 3 Type and scope of the documents(1) The application shall include the documents necessary to check the preconditions for licensing, in particular...
(1d) a description of the environment and its components;...
/Ref 11/ § 6 Par. 3 (4)
(3) The documents pursuant to para. 1 shall contain at least the following information:
1. a description of the project giving details on the site, design and size of the project as well as the amount of land required,
2. a description of the type and the quantity of the emissions and residual substances to be expected, in particular of the air 
pollutants, wastes and waste water as well as other information which is necessary for determining and assessing 
significant impacts on the environment by the project,
3. a description of measures by which significant impacts on the environment may be prevented, reduced or set off as far as 
possible, as well as of substituting measures in the case of interventions in the natural surroundings and landscape which 
cannot be set off but which have priority nonetheless,4. a description of the significant effects of the project on the environment which pays regard to the general level of 
knowledge and the generally acknowledged assessment methods.
/Ref 11/ § 14g
(1) The competent authority shall prepare an environmental report at an early stage. The likely significant environmental 
effects of implementing the plan or program and reasonable alternatives are identified, described and evaluated.
(2) The environmental report under paragraph 1 shall in accordance with § 14f include the following information:
...
3. Summary of the characteristics of the environment, of the current environmental status and the likely evolution thereof without implementation of the plan or program .
/Ref 19/ §20 (1), (2)
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In 
particular, monitoring shall control those observable parameters that can indicate early deviations from the expected 
developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site 
Selection Act, as well as the foreseeable future information needs.
(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the 
disposal site according to § 9. The results of the monitoring shall be documented.
/Ref 14/ § 52a and /Ref 18/ Appendix C.2, /Ref 19/ §20
/Ref 14/ § 52a
(1) monitoring plans have to include the following:1. the geographical scope of the plan,
2. a general assessment of major environmental issues within the scope of the plan,3. a list of facilities covered within the scope of the plan,
4. a procedure for the preparation of programs for regular monitoring,
5. a method for monitoring for a specific reason, and
6. where necessary, provisions for cooperation between different supervisory authorities.
The monitoring plans should be reviewed by the competent authorities regularly and, where necessary, be updated.
(2) On the basis of monitoring plans, the competent authorities regularly create or update monitoring programs, wherein 
the periods are indicated, in which on-site visits must take place. ... DI-46 The licensee shall design the
equipment ofthe disposal facility to
take account ofradiation protection
aspects, ease of maintenance and
inspection, and minimization ofthe
probability and consequences of
anticipated operational occurrences
and, asfar aspracticable, possible
accidents during handling.A /Ref 19/ §17 comply partly with DI-46. Specific 
radiation protection aspects and ease of 
maintenance and inspection of equipment as well as 
operational safety provisions are addressed in /Ref 
17/ Chapter 1.3, 2.1 and 2.4.
DI-47 Before starting construction, the
licensee shall establish abaseline state
oftheenvironment both forsupporting
the monitoring program and for
evaluating theimpact ofthe facility on
the environment.A /Ref 10/ § 3 and /Ref 11/ § 6 and § 14g comply with 
DI-47. An EIA is a component of the licensing 
procedure. The establishment of a baseline state is a 
requirement of the EIA.
DI-48 Before starting construction, the
licensee shall define and document a
systematic monitoring program tobe
implemented during construction,
commissioning, operation,
decommissioning and closure, and as
appropriate after closure.A /Ref 19/ §20 complies with DI-48. The monitoring 
shall be set up as early as possible. It shall begin at 
the latest with the exploration of the disposal site. 
Monitoring shall be systematically updated every 
ten years from the start. Therewith the requirement 
covers the different phases of the disposal facility like construction, commissioning, operation, 
decommissioning, closure, and also after closure. 
A systematic monitoring program of the 
environment to be implemented during 
construction and commissioning (of e.g. a disposal 
facility) is required in the Federal Pollution Control 
Act /Ref 14/ § 52a.
        
      
      
       
     
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/Ref 18/ Appendix C.2
The technical concept of the disposal of radioactive waste is based on the emplacement in deep geological formations 
(repository-mines). Solid or solidified (conditioned) radioactive wastes for disposal are transported to the underground 
disposal site packed either in disposable containers or in reusable special containers. Details are concretised in site-specific 
emplacement conditions. With the barrier in waste packages and the barriers in the disposal facility, which are 
characterized by the backfilling and/or sealing systems, provision is made that emissions of radioactive substances from the 
mine and from above-ground premises are limited.  Based on these facts the regulations specified in sections C.2.1 to C.2.4 
apply to the different operating phases of disposal facilities in terms of emission monitoring, parameters influencing dispersion of radioactive substances and immission monitoring. The regulations apply to emissions from the mine 
(monitoring the discharge of radioactive substances with the waste air/wastewater), to emissions from the above-ground 
premises (monitoring the discharge of radioactive substances with exhaust air or wastewater), as well as to environmental monitoring.
...
/Ref 19/ §20
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In 
particular, monitoring shall control those observable parameters that can indicate early deviations from the expected 
developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary 
safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site 
Selection Act, as well as the foreseeable future information needs.(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the 
disposal site according to § 9. The results of the monitoring shall be documented.
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the 
Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the 
existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered. Each update shall also show what development needs exist for the used and possible new monitoring methods and how this should be considered.
(4) The monitoring measures must not lead to any safety-relevant impairment of the disposal system.
 /Ref 18/ Appendix C.2, /Ref 14/ § 52a, /Ref 19/ § 20
/Ref 18/ Appendix C.2
The technical concept of the disposal of radioactive waste is based on the emplacement in deep geological formations 
(repository-mines). Solid or solidified (conditioned) radioactive wastes for disposal are transported to the underground 
disposal site packed either in disposable containers or in reusable special containers. Details are concretised in site-specific 
emplacement conditions. With the barrier in waste packages and the barriers in the disposal facility, which are 
characterized by the backfilling and/or sealing systems, provision is made that emissions of radioactive substances from the mine and from above-ground premises are limited. Based on these facts the regulations specified in sections C.2.1 to 
C.2.4 apply to the different operating phases of disposal facilities in terms of emission monitoring, parameters influencing 
dispersion of radioactive substances and immission monitoring. The regulations apply to emissions from the mine 
(monitoring the discharge of radioactive substances with the waste air/wastewater), to emissions from the above-ground 
premises (monitoring the discharge of radioactive substances with exhaust air or wastewater), as well as to 
environmental monitoring.
...
/Ref 14/ § 52a
(1) monitoring plans have to include the following:
1. the geographical scope of the plan,
2. a general assessment of major environmental issues within the scope of the plan,
3. a list of facilities covered within the scope of the plan,
4. a procedure for the preparation of programs for regular monitoring,
5. a method for monitoring for a specific reason, and6. where necessary, provisions for cooperation between different supervisory authorities.
The monitoring plans should be reviewed by the competent authorities regularly and, where necessary, be updated.
(2) On the basis of monitoring plans, the competent authorities regularly create or update monitoring programs, wherein 
the periods are indicated, in which on-site visits must take place. ...
/Ref 19/ §20
(1) The disposal facility and its surroundings shall be continuously controlled as part of a monitoring programme. In particular, monitoring shall control those observable parameters that can indicate early deviations from the expected developments of the disposal system. When determining the parameters to be monitored, the results of the preliminary 
safety analyses shall be considered pursuant to § 14(1) sentence 2, § 16(1) sentence 2 and § 18(1) sentence 2 of the Site Selection Act, as well as the foreseeable future information needs.
(2) Monitoring shall be set up by the operator as early as possible. It shall begin at the latest with the exploration of the 
disposal site according to § 9. The results of the monitoring shall be documented.
(3) Monitoring shall be systematically updated every ten years from the start. After approval according to § 9b(1a) of the Atomic Energy Act has been granted, the update shall be carried out as part of the periodic safety review in accordance 
with § 9h of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act. In each update, the 
existing access options to radioactive waste as well as possible further developments of cognition methods and cognition 
options shall be considered. Each update shall also show what development needs exist for the used and possible new monitoring methods and how this should be considered.
(4) The monitoring measures must not lead to any safety-relevant impairment of the disposal system.
2.2.5 Safety issue: Construction
DI-50 The licensee shall construct the
disposal facility inaccordance with the
design asdescribed inthe safety case
and by application ofappropriately
proven techniques./Ref 1/ §9b, /Ref 19/ §5 (4), §6 (4)
/Ref 1/ §9b
(1) The erection, operation and decommissioning of the federal installations referred to in § 9a, para. (3) as well as any 
major alteration of such installations or their operation shall be subject to a plan approval procedure. Upon application, 
the project may be performed step by step and partial plan approval decisions may be granted correspondingly, if a 
preliminary evaluation shows that the requirements pursuant to para. (4) regarding the erection, the operation of the 
whole installation and the decommissioning will be fulfilled . § 74, para. (6) of the Administrative Procedures Act shall apply 
to the extent that the competent authority may grant on application or ex officio a planning licence instead of a plan 
approval only, if the major alteration of the installations mentioned in sentence 1 or of their operation is applied for, and if 
this alteration has no material adverse effects on the objects to be protected according to § 2, para. (2), sentence 2 of the 
Act on the Assessment of Environmental Impacts. § 76 of the Administrative Procedures Act shall not apply.
...A /Ref 1/ §9b, /Ref 19/ §5 (4), §6 (4)  comply with DI-
50. The construction has to follow specifications in 
the safety concept. The safety concept is an 
essential part of the safety case. Furthermore ist has 
to be examined and shown that the construction complies with these specifications in a quality-
assured manner. In addition the proposed quality assurance must correspond to the state of the art in 
science and technology. 
/Ref 19/ §5 (4)
(4) The properties of technical or geotechnical barriers required for long-term safety shall be specified in the safety 
concept. It shall be examined and shown that the required number of barriers can be manufactured and constructed in 
accordance with these specifications in a quality-assured manner. The proposed quality assurance must correspond to the 
state of the art in science and technology. The manufacture, construction and function of the barriers must be successfully 
tested, provided that their robustness cannot be proven by other means and there are no safety margins to an extent that 
testing can be dispensed with.
/Ref 19/ §6 (4)
(4) The properties of the main technical and geotechnical barriers required for long-term safety shall be specified in the 
safety concept. It shall be examined and shown that the production and construction of the barriers according to these 
specifications is possible in the required number in a quality-assured manner. The proposed quality assurance must 
correspond to the state of the art in science and technology. The man-ufacture and construction of the barriers must be 
successfully tested under realistic conditions. Their function under these conditions shall be examined and shown.DI-49 The licensee shall ensure that the
monitoring program contributes to:
•Demonstrating adequate protection
ofpeople and the environment and
demonstrating compliance with the
regulatory requirements and licence
conditions;
•Confirming that the disposal facility
and system behaves and evolves as
expected in the safety case;
•Building confidence inand refining
the key assumptions and models made
in the safety case;•Enhancing understanding of the
environmental conditions and ofthe
functioning of the disposal system;
•Acquiring information forsupporting
decision- making and;
•Providing background information for
any post -closure surveillance program./Ref 19/ § 20 comply with DI-49. The demonstration 
of adequate protection of people and the 
environment, compliance with the regulatory 
requirements and licence conditions will be covered 
by the requirement of controlling those observable 
parameters that can indicate early deviations from the expected developments of the disposal system. 
This applies also to the confirmation that the 
disposal facility and system behaves and evolves as 
expected in the safety case. Furthermore the 
aspects of building confidence, enhancing 
understanding and supporting decisison-making are 
covered by the requirement that monitoring shall be 
systematically updated every ten years from the 
start. The update shall be carried out as part of the 
periodic safety review.  
/Ref 18/ Appendix C.2 requires the implementation 
of a systematic monitoring program.           
            
         
      
        
        
    
      
      
     
       
        
    
The licensee has to take measures for monitoring 
the environment of disposal facilities before 
commissioning, during normal operation and after 
completion of emplacement in accordance with the 
general provisions of directive /Ref 18/.
A
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DI-51 The licensee shall construct the 
disposal facility in such a way as to 
preserve the post -closure safety 
functions of the host environment./Ref 19/ §15 (3), §9 (2), (3), (4), §11 (4)
/Ref 19/ §15 (3)
(3) § 9(2) to (4) shall apply accordingly.A /Ref 19/ §15 (3), §9 (2), (3), (4), §11 (4) comply with 
DI-51. 
The §15 (3) construction of the disposal facility 
indicates that §9 (2), (3), (4) apply accordingly. The 
§9 (2), (3), (4) states that excavation of the 
underground cavities shall have as little impact as 
possible on the surrounding rock and that the 
properties of host rock have to be retained. 
According to this requirement the post -closure 
safety functions of the host environment can be preserved. In addition §11 (4) supports the 
requirement of gentle excavation and construction 
techniques with no or little consequences on the host rock.
/Ref 19/ §9 (2), (3), (4)
(2) All underground cavities shall be excavated with as little impact as possible on the surrounding rock and sealed after use in such a way that the properties of the rock relevant for the safe containment of radioactive waste in the disposal 
zone, in particular the containment-providing rock zone in the case of § 4(3) no. 1, are retained.
(3) All created or existing cavities and bores shall be documented. This shall also apply to cavities and bores that only exist 
temporarily or that are only marginal in scope.
(4) The work shall be carried out as quickly as possible while ensuring the necessary safety.
/Ref 19/ §11 (4)
(4) The impact on the host rock in the disposal zone and in the case of § 4( 3 no. 1 in particular the intended containment-providing rock zone with shafts, excavations or bores shall be restricted to an unavoidable extent for the safe 
construction, safe operation and safe closure of the disposal facility.
DI-52 Inorder torefine the assumptions of
the safety case, the licensee shall
gather information during construction
to improve the knowledge of:•
The intrinsic properties ofthe host
environment•
The response of the host
environment tothe presence ofthe
disposal facility./Ref 19/ §12 (4), §9 (1)
/Ref 19/ §12 (4)(4) As part of the periodic safety reviews according to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) and 
(4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety analyses. The 
safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and 
technology and an examination of possible alternatives to the current disposal system and its components shall be carried 
out. Possible measures to improve the safety of the disposal facility shall be derived from the results of the review and 
examination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.A /Ref 19/ §12 (4), §9 (1) comply with DI-52.
The basic stipulation is a stepwise optimisation of 
the disposal system. Prior to major decisions the 
increase of knowledge has to be taken into account 
for optimisation and updated safety assessments. 
This also refers to improved information on the 
intrinsic properties of the host environment and 
interdependencies between host environment and 
the disposal facility.
/Ref 19/ §9 (1)
(1) When exploring the disposal site, the data on the properties of the site, which are essential for the safety of the disposal facility, collected in a quality-assured manner and to an extent sufficient for the safety analysis report. The 
proposed quality assurance must correspond to the state of the art in science and technology. The range of variation of 
the data collected shall be determined and its possible change during construction, operation and closure of the disposal 
facility as well as during the assessment period estimated.
DI-53 The licensee shall plan, assess,
document and implement any
modifications ofdesign, construction
procedures and methods using
arrangements consistent with the
importance to safety of the
modification. These arrangements shall
ensure that the modifications will not
have an unacceptable effect on
operational and post -closure safety./Ref 19/ §12 (1), (3)
(1) The safety concept and the technical design of the disposal facility shall be optimised considering all circumstances of the individual case and respecting the balance of measures to achieve the following objectives:
1. the long-term safety of the disposal facility, in particular the quality of the safe containment of radioactive waste and 
the robustness of the disposal system, and
2. the operational safety of the disposal facility.
(3) In addition to the expected and deviating developments according to § 3(3) and (4), the hypothetical developments 
and developments based on future human activities according to § 3(6) and (7) shall also be considered when optimising 
the disposal facility. It shall be ensured that measures to optimise the disposal system which are derived from deviating 
developments, do not significantly impair the safety of the disposal facility for the expected developments. Measures derived from hypothetical developments must not significantly impair the safety of the disposal facility for the expected 
and for the deviating developments. Optimisation to reduce the possible effects of future human activities on the disposal system shall be performed as a matter of secondary priority.A /Ref 19/ §12 (1), (3) comply with DI-53. Major 
decisions could be related to the need of modifications of the repository layout. In this case 
comprehensive optimisation measures are 
stipulated aiming at an improvement of operational 
and post-closure safety. Furthermore, it has to be 
ensured that taken measures for optimisation do 
not significantly impair the safety of the disposal 
facility.
2.2.6 Safety issue: Operation
DI-54 The licensee shall operate thefacility in
accordance with the conditions ofthe
licence and the relevant regulatory
requirements soastomaintain safety
during theoperational phase, and soas
to establish and preserve the
post -closure safety functions claimed in
the safety case./Ref 19/ §17, §18 (2), (3), §19
/Ref 19/ §17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be systematically determined, described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or4. beyond design basis accidents and events.
(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part 
of the safety concept.
(3) The safety concept shall provide for1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence 
of other facility conditions,2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal 
operation,
3. measures for design basis accidents in accordance with § 104(1) sentence 1 and 2 of the Radiation Protection Ordinance 
of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal facility in a 
safe facility condition,
4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.A /Ref 19/ §17, §18 (2), (3), §19 comply with DI-54. 
Especially §18 (2), (3), §19 include measures in the context of  preserving the post- closure safety 
functions claimed in the safety case.
/Ref 19/ §18 (2), (3)
(2) The zone of the disposal mine used for the emplacement of radioactive waste shall be limited to the necessary extent. This zone shall be excavated, loaded, filled and sealed respectively without delay against the residual part of the disposal 
mine in accordance with the sealing concept.
(3) The handling of waste packages shall be separated from the mining work in the disposal mine and other construction 
work on the premises of the disposal facility.
/Ref 19/ §19
(1) After the emplacement of radioactive waste has been completed, the disposal facility shall be closed in such a way that the disposal system ensures the safe containment of the radioactive waste according to § 4 passively and maintenance-
free during the assessment period.
(2) The closure of the disposal facility shall include, in particular, the complete backfilling of all underground cavities and 
their sealing as well as the dismantling of the technical facilities that impair long-term safety. (3) § 9(2) to (4) shall apply accordingly.
DI-55 The licensee shall make and implement
arrangements todetect and respond to
anticipated operational occurrences
and possible accidents. Provisions for
doing soshall not unacceptably affect
operational or post- closure safety./Ref 1/ Par. 7 (2) No. 3, Par. 19a (3), (4), /Ref 19/ §17
/Ref 1/ Par. 7 (2) No. 3
A licence may only be granted if the necessary precautions have been taken in the light of the state-of-the-art of science and technology to prevent damage resulting from the erection and operation of the installation.A /Ref 1/ Par. 7(2) No.3 and Par. 19a (3,4) comply with 
DI-55. R&D implies the requirements for the 
precaution against damage.
/Ref 19/ §17 comply with DI-55, as well. This 
requirement includes the systematically determination of the facility condition in form of 
described and classified normal operation,abnormal operation, design basis accidents, or 
beyond design basis accidents and events.
/Ref 1/ Par. 19a (3), (4)
(3) Anyone who operates any nuclear installation pursuant to § 2, para. (3a), subpara. 1 shall perform a verification and 
evaluation of the nuclear safety of the respective installation every ten years and shall improve nuclear safety of the 
installation continuously. The results ot the verification and evaluation shall be submitted to the supervisory authority.
(4) The evaluation according to para. (1) or (3) shall encompass the verification that measures are taken to prevent 
accidents and to attenuate the effects of accidents including the verification of the physical barriers as well as of the administrative preventions of the licencee which would have to fail before life, health and material assets are damaged by 
the effect of ionising radiation. The competent supervisory authority can issue orders concerning the extent of the 
verification and evaluation by the licencee.
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/Ref 19/ §17
(1) The facility conditions relevant for the safety of the disposal facility during construction, operation and closure shall be 
systematically determined, described and classified as
1. normal operation,
2. abnormal operation,
3. design basis accidents, or
4. beyond design basis accidents and events.
(2) For these facility conditions, graduated defence and protective measures shall be developed and implemented as part 
of the safety concept.
(3) The safety concept shall provide for
1. measures for normal operation that ensure the intended operation of the disposal facility and prevent the occurrence 
of other facility conditions,
2. measures for abnormal operation that prevent the occurrence of accidents and return the disposal facility to normal operation,
3. measures for design basis accidents in accordance with § 104(1) sentence 1 and 2 of the Radiation Protection Ordinance 
of November 29, 2018 (BGBl. I p. 2034, 2036), as amended, which control the accident and return the disposal facility in a 
safe facility condition,
4. measures for beyond design basis accidents and events that limit the effects of the event on the environment as far as 
possible.
DI-56 In order to refine the assumptions of the safety case, the licensee shall 
continue to gather information during 
operation to improve the knowledge of:
• The intrinsic properties  of the host 
environment
• The response  of the host 
environment to the presence of the disposal facility./Ref 19/ §12 (4), §9 (1)
/Ref 19/ §12 (4)
(4) As part of the periodic safety reviews according to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) and (4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety analyses. The 
safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and 
technology and an examination of possible alternatives to the current disposal system and its components shall be carried 
out. Possible measures to improve the safety of the disposal facility shall be derived from the results of the review and examination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.A /Ref 19/ §12 (4), §9 (1) comply with DI-56.
The basic stipulation is a stepwise optimisation of the disposal system. This also refers to improved 
information on the intrinsic properties of the host 
environment and interdependencies between host 
environment and the disposal facility. In addition to 
this step-wise optimisation requirement there is a 
stipulation of a permantent monitoring program 
during the operational phase and also after closure.
/Ref 19/ §9 (1)
(1) When exploring the disposal site, the data on the properties of the site, which are essential for the safety of the 
disposal facility, collected in a quality-assured manner and to an extent sufficient for the safety analysis report. The 
proposed quality assurance must correspond to the state of the art in science and technology. The range of variation of 
the data collected shall be determined and its possible change during construction, operation and closure of the disposal 
facility as well as during the assessment period estimated.
DI-57 The licensee shall establish,
substantiate, document and implement
operational limits and conditions (OLCs)
tooperate the disposal facility safely,
tomaintain the waste inasafe state
during operation and to ensure
compliance with the requirements for
post -closure safety./Ref 17/ Chapter 2.1, /Ref 19/ §10 (6), §18
/Ref 17/ Chapter 2.1
... All changes provided during operation are also to be examined with regard to their potential impact on long-term 
safety. 
... For safe performance of the operational processes, the entire operation shall be structured and organised 
appropriately. For this purpose, the following requirements are to be met:
• All operational processes shall be clearly described,
• interactions between the individual operational processes shall be considered, 
• all installations necessary for safe performance of operation shall be specified, 
• the parameters relevant for safe operation shall be defined, Moreover, the necessary administrative prerequisites relating to personnel, organisation and safety have to be 
established, maintained and documented. For the operating states normal operation, abnormal operation, design basis 
accidents, beyond design basis accidents/events as well as their management, clear instructions are to be drawn up for 
the mine book/operating manual. Competencies and responsibilities are clearly to be defined. In the mine book/operating 
manual, experiences from other facilities are to be considered and the mine book/operating manual is to be updated at 
regular intervals or after an event. A /Ref 19/ §10 (6), §18 comply with DI-57. These 
requirements cover provisions in the context of 
operational limits ad conditions.
/Ref 17/ Chapter 2.1 establishes the requirement to 
define the operating conditions.
/Ref 19/ §10 (6)
(6) The safety concept shall also contain:
1. a schedule for the construction, operation and closure of the disposal facility which explains how the safety of the disposal facility can be ensured in accordance with § 17 and how the radioactive waste can be kept in a safe state,2. a description of the measures to ensure the retrievability of the radioactive waste emplaced according to § 13 until the 
commencement of closure, and
3. a description of the precautions that are taken to enable recovery of the emplaced radioactive waste in accordance with 
§ 14.
/Ref 19/ §18
(1) Only those waste packages may be brought into the disposal mine whose disposal capacity has been determined in 
accordance with § 3(1) sentence 2 of the Nuclear Waste Management Ordinance.
(2) The zone of the disposal mine used for the emplacement of radioactive waste shall be limited to the necessary extent. This zone shall be excavated, loaded, filled and sealed respectively without delay against the residual part of the disposal 
mine in accordance with the sealing concept.
(3) The handling of waste packages shall be separated from the mining work in the disposal mine and other construction 
work on the premises of the disposal facility.
(4) During operation, it must be guaranteed that the personnel requirements for a possible partial implementation of the 
closure concept, which puts the disposal facility in a passively safe state, are met at all times. The technical facilities 
required for this shall be kept available.
DI-58 The licensee shall make adequate
arrangements for commissioning and
operation of the disposal facility
including arrangements for receiving,
handling and emplacement ofwaste
before these activities are commenced./Ref 19/ §16
(1) The operation of the disposal facility must have been successfully tested before the first acceptance of radioactive 
waste for the purpose of disposal.(2) When testing the operation,
1. the construction of the disposal facility must be completed in accordance with § 15,2. the handling and emplacement of waste packages must be carried out without radioactive loading,
3. the functionality of all technical facilities that are necessary for a possible retrieval of emplaced waste packages must 
be ensured and
4. the proposed technical closure and sealing measures must be available in accordance with § 11(1) no. 8.(3) At the end of the test, the safety analysis report shall be examined.
(4) § 9(2) to (4) shall apply accordingly.A /Ref 19/ §16 complies with DI-58. Before the 
dispsoal facility goes into operation it is required that the disposal facility inclusive the components and respective equipment for operation will be 
tested thoroughly.
DI-59 Before starting theemplacement ofany
waste, the licensee shall review the
plan fordecommissioning, closure and
post- closure activities./Ref 19/ §16
(1) The operation of the disposal facility must have been successfully tested before the first acceptance of radioactive waste for the purpose of disposal.
(2) When testing the operation,
1. the construction of the disposal facility must be completed in accordance with § 15,
2. the handling and emplacement of waste packages must be carried out without radioactive loading,
3. the functionality of all technical facilities that are necessary for a possible retrieval of emplaced waste packages must be 
ensured and
4. the proposed technical closure and sealing measures must be available in accordance with § 11(1) no. 8.
(3) At the end of the test, the safety analysis report shall be examined.
(4) § 9(2) to (4) shall apply accordingly.A /Ref 19/ §16 complies with DI-59. Before operation 
starts the disposal facility has to be tested. It is 
further reqired, that at the end of the testing phase, 
the safety analysis report shall be examined. This 
indicates that the plan for decommissioning, closure 
and post- closure activities will be reviewed.
DI-60 The licensee shall ensure that any
modifications tothe disposal facility
will nothave anunacceptable effect on
operational and post -closure safety./Ref 19/ §12 (1), (3)
(1) The safety concept and the technical design of the disposal facility shall be optimised considering all circumstances of the individual case and respecting the balance of measures to achieve the following objectives:
1. the long-term safety of the disposal facility, in particular the quality of the safe containment of radioactive waste and 
the robustness of the disposal system, and
2. the operational safety of the disposal facility.
(3) In addition to the expected and deviating developments according to § 3(3) and (4), the hypothetical developments 
and developments based on future human activities according to § 3(6) and (7) shall also be considered when optimising 
the disposal facility. It shall be ensured that measures to optimise the disposal system which are derived from deviating 
developments, do not significantly impair the safety of the disposal facility for the expected developments. Measures 
derived from hypothetical developments must not significantly impair the safety of the disposal facility for the expected and for the deviating developments. Optimisation to reduce the possible effects of future human activities on the disposal 
system shall be performed as a matter of secondary priority.A /Ref 19/ §12 (1), (3) comply with DI-60. Major 
decisions could be related to the need of modifications of the dispsoal facility. In this case 
comprehensive optimisation measures are 
stipulated aiming at an improvement of operational 
and post-closure safety.
DI-61 The licensee shall plan, assess,
document and implement any
modifications of design, waste
acceptance criteria, structures, systems
and components (SSCs), operational
limits and conditions (OLCs) and
operational procedures and methods
using arrangements consistent with the
importance to safety of the
modifications./Ref 19/ §12 (4)
(4) As part of the periodic safety reviews according to § 9h no. 1 of the Atomic Energy Act in conjunction with § 19a(3) and 
(4) of the Atomic Energy Act, further optimisation shall be carried out on the basis of comprehensive safety analyses. The 
safety concept of the disposal system shall be reviewed fundamentally according to the state of the art in science and technology and an examination of possible alternatives to the current disposal system and its components shall be carried 
out. Possible measures to improve the safety of the disposal facility shall be derived from the results of the review and 
examination. Knowledge from the construction, operation and closure of the disposal facility shall be considered.A /Ref 19/ §12 (4) complies with DI-61. Major 
decisions could be related to the need of 
modifications of of design, waste acceptance 
criteria, structures, systems and components (SSCs), operational limits and conditions (OLCs) and 
operational procedures and methods. In this case 
comprehensive optimisation measures are 
stipulated aiming at an improvement of operational 
and post-closure safety.
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