ML20034D203

Reactor Decommissioning Financial Assurance Working Group Webex Presentation for 2/5/2020

ML20034D203
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Issue date:	02/05/2020
From:	Tanya Smith Division of Decommissioning, Uranium Recovery and Waste Programs
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Smith T
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Download: ML20034D203 (17)

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Dial-in: 888-791-4689 Passcode: 4605059 The meeting is scheduled to begin shortly

February 5, 2020

Agenda Reactor Decommissioning Financial Assurance Working Group (WG)

Presentation WG Process and Progress Public Comments 2

Working Group 3

Organizations Office of Nuclear Material Safety and Safeguards Division of Decommissioning, Uranium Recovery and Waste Programs Division of Rulemaking, Environmental and Financial Support Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Region I - Division of Nuclear Materials Safety Region III - Division of Nuclear Materials Safety Region IV - Division of Nuclear Materials Safety Office of General Counsel Chairman: Ted Smith, Reactor Decommissioning Branch

WG Charter In September 2019, the Reactor Decommissioning Financial Assurance Working Group was formed and directed to:

1. Review the current decommissioning financial assurance processes

2. Identify potential regulatory gaps or policy issues

3. Identify potential program enhancements

4. Identify planning or resource considerations

5. Make recommendations 4

Decommissioning Business Models Historically, decommissioning has been managed by former operator Recently, plants have been transferred for decommissioning Transfers require a financial qualification evaluation 5

Typical Decommissioning License Transfer Accelerated Decommissioning Accelerated Decommissioning Trust Fund (DTF) expenditures Reduces time for DTF growth Dedicated limited liability companies (LLCs)

Financial assurance requirements continue Different financial assurance instruments 6

Regulations Governing Decommissioning Financial Assurance 1988, General Requirements for Decommissioning Nuclear Facilities 10 CFR 50.75 1996 Decommissioning of Nuclear Power Reactors 10 CFR 50.82 1998 Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75 (f)(1) and (2) 2002 Decommissioning Trust Provisions

Corrected in 2003

Additional financial assurance requirements for licensees that are not traditional regulated electric utilities 7

NRC Perspective The risk of a licensee not having adequate decommissioning resources is low because:

1.

Extensive regulations 2.

Transfer requires NRC approval of financial resources 3.

NRC inspection program 4.

Atomic Energy Act authority 8

Summary of Decommissioning Financial Assurance Requirements (1 of 3)

Assurance of sufficient funding for decommissioning is provided by:

1. Calculated decommissioning cost estimate cost updated annually

2. Decommissioning cost must be covered

3. Trustee manages the decommissioning trust fund (DTF) with NRC oversight 9

Summary of Decommissioning Financial Assurance Requirements (2 of 3)

Assurance of sufficient funding for decommissioning is provided by:

4. Withdrawal notification requirements while operating

5. Withdrawals limited to radiological decommissioning

6. Periodic reports with obligation to make up shortfalls 10

Summary of Decommissioning Financial Assurance Requirements (3 of 3)

Assurance of sufficient funding for decommissioning is provided by:

7. Preliminary and site-specific decommissioning cost estimates

8. Obligation to make up shortfalls immediately when in decommissioning

9. 60 years to complete decommissioning 10.Ability to revoke exemptions for other use of DTFs 11

Applicable Guidance NUREG-1307, Rev 17 ML19037A405 Regulatory Guide 1.159 ML112160012 Regulatory Guide 1.202 ML050230008 NRR Office Instruction LIC-205 ML17075A095 Inspection Procedure 36801/71801 https://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/

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WG Progress Summary No regulatory gaps or policy issues have been identified Recommendations developed to improve FA licensing and oversight processes Four guidance initiatives Training for inspectors, program office and financial analysts 13

Recommended Guidance Initiatives 1.

Revise Inspection Procedures Integrate decommissioning activity inspections with the program office and financial analysts activities 2.

Revise Reporting Guidance to allow more detail in annual reports for improved oversight of DTF expenditures 3.

Revise Reporting Guidance to allow more detail in the 30-day pre-withdrawal notices for improved oversight of DTF expenditures 4.

Develop guidance for a spot check program for power reactors in decommissioning 14

Next Steps Obtain your input today Final Report March 2020 15

Thanks Comment period instructions Please be mindful of the scope of this Webex-Financial Assurance for Decommissioning Please provide general comments that may help us in our deliberations as opposed to questions about specific plants Please be brief, so as to allow others to comment You may also use the Webex Q&A dialogue box to leave comments 16