ML23061A053

Watermarked - RG 1.184 Revision 2 - Decommissioning of Nuclear Power Reactors (02-14-24)

ML23061A053
Person / Time
Issue date:	01/31/2024
From:	Marlayna Vaaler Doell Reactor Decommissioning Branch
To:
References
DG-1347 Rev 1, NRC-2015-0070, RIN 3150-AJ59 RG 1.184, Rev 2
Download: ML23061A053 (31)

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DISCLAIMER:

This document is a pre-decisional draft for information purposes only.

The U.S. Nuclear Regulatory Commission (NRC) is making this document publicly available concurrent with the Commissions review of SECY-24-0011, Final Rule: Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning (ADAMS Accession No. ML23258A200).

The NRC is not seeking public comment on this document.

Please note that direction from the Commission related to the final rule may result in changes to this document.

U.S. NUCLEAR REGULATORY COMMISSION REGULATORY GUIDE 1.184, REVISION 2 Issue Date: Month 20XX Technical Lead: Marlayna Doell Written suggestions regarding this guide may be submitted through the NRCs public website in the NRC Library at https://www.nrc.gov/reading-rm/doc-collections/reg-guides/index.html, under Document Collections, in Regulatory Guides, at https://www.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html, and will be considered in future updates and enhancements to the Regulatory Guide series. During the development process of new guides suggestions should be submitted within the comment period for immediate consideration. Suggestions received outside of the comment period will be considered if practical to do so or may be considered for future updates.

Electronic copies of this RG, previous versions of RGs, and other recently issued guides are also available through the NRCs public website in the NRC Library at https://www.nrc.gov/reading-rm/doc-collections/reg-guides/index.html/ under Document Collections, in Regulatory Guides.

This RG is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at https://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession No. ML23061A053. The regulatory analysis is associated with a rulemaking and may be found in ADAMS under Accession No. ML23258A202. The associated draft guide DG-1347, Revision 1, may be found in ADAMS under Accession No. ML21347A080, and the staff responses to the public comments on DG-1347, Revision 1, may be found under ADAMS Accession No. ML23258A201.

DECOMMISSIONING OF NUCLEAR POWER REACTORS A. INTRODUCTION Purpose This regulatory guide (RG) provides guidance on specific topics related to the actions required of U.S. Nuclear Regulatory Commission (NRC) licensees to decommission nuclear power reactors.

Additional guidance on decommissioning actions and strategies is available in other NRC guidance documents, which are referenced in this RG as appropriate.

Applicability This guide applies to holders of operating licenses for nuclear power reactors subject to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities (Ref. 1), and combined licenses subject to 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants (Ref. 2).

The fact that a licensee has permanently ceased operations and removed the fuel from the reactor vessel, or that a final legally effective order to permanently cease operations has come into effect, or that the licensed facility has been modified to be incapable of making use of special nuclear material without significant further alterations to restore the capability to do so, does not reduce or alter the requirement that the licensee comply with the applicable regulations, its NRC license, and its technical specifications.

Some regulations no longer apply when the licensee is no longer authorized to operate, and some regulations no longer apply when the facility is no longer a utilization facility. If a licensee wishes to reduce its regulatory burden for those requirements that still apply, it must do so by requesting an exemption in accordance with 10 CFR 50.12, Specific exemptions, or 10 CFR 52.7, Specific exemptions, or a license amendment in accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, or by making changes in accordance with 10 CFR 50.59, Changes, tests, and experiments, as appropriate.

Pre-Decisional

RG 1.184, Rev. 2, Page 2 Applicable Regulations 10 CFR Part 20, Standards for Protection against Radiation (Ref. 3), provides the radiological release criteria and radiological protection requirements that apply during decommissioning.

10 CFR Part 50 provides the regulations for licensing production and utilization facilities, including specific requirements related to the decommissioning of such facilities.

o 10 CFR 50.2, Definitions, provides definitions.

o 10 CFR 50.4, Written communications, provides the requirements for written communications.

o 10 CFR 50.47, Emergency plans, provides emergency planning requirements.

o 10 CFR 50.54, Conditions of licenses, provides the conditions for a license.

o 10 CFR 50.59 provides the requirements for making changes to a facility without prior NRC approval under certain circumstances.

o 10 CFR 50.71, Maintenance of records, making of reports, provides the requirements for maintaining records and making reports.

o 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning, provides the requirements for reporting and recordkeeping for decommissioning planning, including the requirements for reporting on decommissioning funding assurance.

o 10 CFR 50.82, Termination of license, provides the requirements for terminating a license, including a requirement for nuclear power reactor licensees to submit a post-shutdown decommissioning activities report (PSDAR).

o 10 CFR 50.200, Power reactor decommissioning emergency plans, provides alternative emergency planning requirements for a facility that is transitioning from operations to decommissioning.

10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions (Ref. 4), provides the requirements for environmental protection.

o 10 CFR 51.53, Postconstruction environmental reports, provides the requirements for the content of postconstruction environmental reports.

o 10 CFR 51.95, Postconstruction environmental impact statements, provides the requirements for the content of postconstruction environmental impact statements.

10 CFR Part 52 governs the issuance of early site permits, standard design certifications, combined licenses, standard design approvals, and manufacturing licenses for nuclear power facilities.

o 10 CFR 52.1, Definitions, provides definitions.

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RG 1.184, Rev. 2, Page 3 o 10 CFR 52.110, Termination of license, provides the requirements for terminating a license, including a requirement for nuclear power reactors licensees to submit a PSDAR.

10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste (Ref. 5),

provides, in part, the regulatory requirements for licensing independent spent fuel storage installations (ISFSIs).

10 CFR Part 73, Physical Protection of Plants and Materials (Ref. 6), provides, in part, the physical protection requirements for decommissioning facilities.

10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements (Ref. 7),

provides, in part, the financial protection requirements for decommissioning facilities.

Related Guidance RG 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors (Ref. 8),

provides guidance on estimating the amount of funds for decommissioning and methods acceptable for demonstrating decommissioning financial assurance.

RG 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors (Ref. 9), provides guidance on the license termination plan requirements.

RG 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report (Ref. 10), identifies the type of information that the PSDAR must contain and establishes a standard set of contents and level of detail for the PSDAR.

RG 1.191, Fire Protection Program for Nuclear Power Plants during Decommissioning and Permanent Shutdown (Ref. 11), provides guidance on a fire protection program for licensees that have certified that their nuclear power plants have permanently ceased operations and that the fuel has been permanently removed from the reactor vessels.

RG 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Ref. 12), identifies the type of information that the decommissioning cost estimate (DCE) must contain and establishes a standard set of contents and level of detail for the DCE.

RG 1.235, Emergency Planning for Decommissioning Power Reactors (Ref. 13), provides guidance on an emergency preparedness program for licensees implementing the requirements of 10 CFR 50.200.

RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination)Effluent Streams and the Environment (Ref. 14), provides guidance on designing and implementing programs to ensure the quality of the results of measurements of radioactive materials in the effluents from, and environment outside of, facilities that process, use, or store radioactive materials, during all phases of a facilitys life cycle.

RG 4.21, Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning (Ref. 15), provides guidance to licensees on the steps they can take to minimize contamination and facilitate decommissioning using a risk-informed approach.

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RG 1.184, Rev. 2, Page 4 RG 4.22, Decommissioning Planning during Operations (Ref. 16), provides guidance on determining whether changes to operations or monitoring programs are needed to comply with 10 CFR Part 20; conducting appropriate radiological surveys, including surveys of the subsurface; and providing adequate funding to complete decommissioning.

RG 4.25, Assessment of Abnormal Radionuclide Discharges in Ground Water to the Unrestricted Area at Nuclear Power Plant Sites (Ref. 17), provides guidance on assessing abnormal discharges of radionuclides in ground water from the subsurface to the unrestricted area at a nuclear power plant site.

NUREG-1577, Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance (Ref. 18), describes how the NRC staff will review power reactor licensees financial qualifications and methods of providing decommissioning funding assurance.

NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans (Ref 19), describes how the NRC staff will review license termination plans for decommissioning nuclear power reactors.

NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors (Ref. 20), describes how the NRC staff will review site-specific DCEs.

NUREG-1757, Consolidated Decommissioning Guidance (Ref. 21), covers the following topics:

o Volume 1, Decommissioning Process for Materials Licensees, contains guidance for decommissioning of materials facilities.

o Volume 2, Characterization, Survey, and Determination of Radiological Criteria, provides guidance on compliance with the radiological criteria for license termination in 10 CFR Part 20, Subpart E, Radiological Criteria for License Termination.

o Volume 3, Financial Assurance, Recordkeeping, and Timeliness, provides guidance on the requirements for financial assurance for decommissioning, and on the recordkeeping requirements related to eventual decommissioning of materials facilities.

Purpose of Regulatory Guides The NRC issues RGs to describe methods that are acceptable to the staff for implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific issues or postulated events, and to describe information that the staff needs in its review of applications for permits and licenses. Regulatory guides are not NRC regulations and compliance with them is not required. Methods and solutions that differ from those set forth in RGs are acceptable if supported by a basis for the findings required for the issuance or continuance of a permit or license by the Commission.

Paperwork Reduction Act This RG provides voluntary guidance for implementing mandatory information collections covered by 10 CFR Parts 20, 50, 51, 52, 72, 73, and 140 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Pre-Decisional

RG 1.184, Rev. 2, Page 5 Management and Budget (OMB), under control numbers 3150-0014, 3150-0011, 3150-0021, 3150-0151, 3150-0132, 3150-0002, and 3150-0039, respectively. Send comments regarding this information collection to the FOIA, Library, and Information Collections Branch, (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs, (3150-0014, 3150-0011, 3150-0021, 3150-0151, 3150-0132, 3150-0002, and 3150-0039), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW, Washington, DC 20503; email:

oira_submission@omb.eop.gov.

Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB control number.

Pre-Decisional

RG 1.184, Rev. 2, Page 6 B. DISCUSSION Reason for Revision This revision of RG 1.184 (Revision 2) was issued as part of a rulemaking to amend the Commissions regulations on decommissioning for production and utilization facilities, such as nuclear power reactors. The rulemaking, titled Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning (Volume XX of the Federal Register (FR), page XXXXX (XX FR XXXXX); MM DD, 2024), amended 10 CFR 50.82 and 10 CFR 52.110, along with numerous other regulations, to provide a more efficient process for transitioning from operations to decommissioning, to reduce the need for license amendments and exemptions from existing regulations, and to address other issues identified by the NRC staff so as to streamline and improve the overall decommissioning process.

Scope of This Regulatory Guide This RG describes methods and procedures that are acceptable to the NRC staff for implementing regulations related to both the initial activities and the major phases of the decommissioning process. It also includes suggested best practices and lessons learned based on the decommissioning activities the NRC has overseen to date. It does not contain guidance on the license termination process, which is addressed in RG 1.179.

The regulations in 10 CFR Part 72 address the requirements for the licensing and decommissioning of facilities for the independent storage of spent nuclear fuel. This RG addresses certain aspects of decommissioning general license ISFSIs subject to 10 CFR Part 72, because licensees must decommission these ISFSIs in accordance with 10 CFR 50.82 or 10 CFR 52.110. This RG does not address the shipment of these materials or the disposal of low-level, high-level, or greater-than-Class-C waste. The regulations in 10 CFR Part 71, Packaging and Transportation of Radioactive Material (Ref. 22), cover the shipment of the materials and 10 CFR Part 60, Disposal of High-Level Radioactive Wastes in Geologic Repositories (Ref. 23), and 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste (Ref. 24), address the disposal of waste.

This RG applies only to power reactor licensees. The decommissioning regulations for nonpower production or utilization facilities and fuel reprocessing plants appear in 10 CFR 50.82(b). The NRC staff discusses the procedures for decommissioning these facilities, in part, in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors (Ref. 25), and in the interim staff guidance augmenting NUREG-1537 for licensing radioisotope production facilities and aqueous homogeneous reactors (Ref. 26).

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Background===

As defined by 10 CFR 50.2 and 10 CFR 52.1, decommission means to remove a facility or site safely from service and reduce residual radioactivity to a level that permits (1) release of the property for unrestricted use and termination of the license or (2) release of the property under restricted conditions and termination of the license. The general regulations on decommissioning, codified, in part, in 10 CFR 50.54, 50.71, 50.75, 50.82, 50.200, 51.53, 51.95, and 52.110, contain technical and financial criteria for decommissioning, including requirements for planning, timing, funding mechanisms, environmental review, emergency preparedness, staffing, recordkeeping, and reporting. After a licensee permanently ceases operations at a power reactor facility and the facility enters decommissioning, there is a transition period to reconfigure the licensing basis and operational approach to reflect the differences Pre-Decisional

RG 1.184, Rev. 2, Page 7 between an operating power reactor facility and a power reactor facility in decommissioning.

Decommissioning is governed by the termination-of-license regulations in 10 CFR 50.82 and 10 CFR 52.110, which establish a timeframe for completion of decommissioning, determine which types of activities require NRC approval before being implemented, state the radiological release criteria that the site must meet to qualify for license termination, outline the appropriate use of decommissioning funds, and set up the enveloping environmental considerations for decommissioning, among other items.

Risk-Informed Application Reactors that have permanently ceased operations and have no fuel in the reactor vessel present significantly reduced but different risks to public health and safety as compared to operating reactors. The NRC has amended its regulations to specify applicable requirements for such facilities by eliminating, revising, or extending the requirements applicable to operating reactors commensurate with their importance to the safety and security of permanently shutdown reactors.

Specifically, the NRC amended its regulations to provide an efficient regulatory framework during decommissioning using a graded approach in several technical areas. This graded approach is commensurate with the reductions in radiological risk at four levels of decommissioning: (Level 1) permanent cessation of operations and permanent removal of all fuel from the reactor vessel; (Level 2) sufficient decay of fuel in the spent fuel pool (SFP) such that it would not reach ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> under adiabatic heat up conditions; (Level 3) transfer of all spent fuel to dry storage; and (Level 4) removal of all fuel from the site. These levels are discussed further as follows.

1.

Level 1 Licensees in Level 1 include nuclear power reactor licensees that have docketed certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel pursuant to 10 CFR 50.82 or 10 CFR 52.110. In this level, a decommissioning nuclear power reactor is defueled and permanently shut down, but the spent fuel in the SFP is still susceptible to a zirconium fuel cladding fire within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> under adiabatic heat up conditions.

2.

Level 2 In Level 2, the reactor is defueled and permanently shut down, and spent fuel in the SFP has decayed and cooled sufficiently such that it cannot heat up to the zirconium cladding ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> under adiabatic conditions. The NRC has determined that this condition is reached after spent fuel has decayed for a minimum of either 10 months for a boiling-water reactor or 16 months for a pressurized-water reactor, or upon reaching an alternative site-specific timeframe approved by the NRC.

The decay period could begin when the fuel is still in the reactor vessel but the reactor has permanently ceased operations. In order to verify that a licensee has met the conditions for entering Level 2, the NRC will rely upon the date of permanent cessation of operations provided by the licensee under 10 CFR 50.4(b)(8) or 10 CFR 52.3(b)(8), updated as necessary under 10 CFR 50.9 or 10 CFR 52.6, both entitled Completeness and accuracy of information.

Because the identified date of permanent cessation of operations would determine the date of transition from Level 1 to Level 2, the NRC will consider a change in the planned date initially certified to the NRC for permanent cessation of operations to the actual date as information having a significant implication for public health and safety or common defense and security under 10 CFR 50.9 or 10 CFR 52.6. At this point in time, the site may also possess a radioactive inventory of liquid radiological waste, Pre-Decisional

RG 1.184, Rev. 2, Page 8 radioactive reactor components, and contaminated structural materials. The radioactive inventory may change, depending on the licensees proposed shutdown activities and schedule.

3.

Level 3 In Level 3, all spent nuclear fuel (SNF) is in dry cask storage pursuant to the terms and conditions of a license granted under 10 CFR Part 72, including the general license issued in 10 CFR 72.210, General license issued. However, the licensee may still hold a 10 CFR Part 50 or 10 CFR Part 52 license, and the site may still contain a radioactive inventory of liquid radiological waste, radioactive reactor components, and contaminated structural materials.

4.

Level 4 At this point in the facilitys life cycle, all SNF has been removed from the site. The site may possess a radioactive inventory of liquid radiological waste, radioactive reactor components, and contaminated structural materials. The radioactive inventory during this configuration may change, depending on the licensees proposed decommissioning activities and schedule.

As a facility transitions from being operational to having all SNF removed from the site, the NRCs regulatory requirements are graded to provide for reasonable assurance of the health and safety of the public commensurate with the risk profile of the facility. Table 1 below summarizes the changes to requirements in the technical areas that use aspects of this graded approach.

LEVEL 1 (Permanent cessation of operations and permanent removal of all fuel from the reactor vessel)

LEVEL 2 (Sufficient decay of fuel in the SFP such that it would not reach ignition temperature for the zirconium alloy cladding of the fuel within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> under adiabatic heat up conditions)

LEVEL 3 (Transfer of all fuel to dry storage)

LEVEL 4 (Removal of all fuel from the site)

Emergency Preparedness Post-Shutdown Emergency Plan (PSEP)

Permanently Defueled Emergency Plan (PDEP)

ISFSI-Only Emergency Plan (IOEP)

Licensee may terminate EP program Physical Security Allow certain physical security plan changes without prior NRC approval Allow transition from 10 CFR 73.55 to 10 CFR 73.51 requirements Cybersecurity Removal of cybersecurity requirements Onsite/Offsite Insurance Reduction of onsite insurance to $50 million Reduction of offsite insurance to $100 million Table 1. Summary of the graded approach Pre-Decisional

RG 1.184, Rev. 2, Page 9 Decommissioning Phases To facilitate understanding of the overall decommissioning process, and separate from the levels of decommissioning requirements established by the graded approach, the NRC staff has divided the decommissioning activities for power reactors into three general phases. The first phase of decommissioning includes the initial planning and transition activities, which start on either the effective date of permanent cessation of operations or upon the submittal of the PSDAR, whichever occurs first.

The first phase encompasses the activities that take place before the licensee either places the power reactor into a storage mode or begins major decommissioning activities (as defined in 10 CFR 50.2 and 10 CFR 52.1), including the transition of the licensing basis to reflect the decommissioning status of the facility. The second phase of decommissioning encompasses the conduct of activities during the storage period or the undertaking of major decommissioning activities (i.e., decontamination and dismantlement),

or some combination of the two. The third phase consists of the activities that the licensee undertakes to reduce the remaining radioactivity at the site to a level that permits release of the site. The amendments to 10 CFR Part 2, Agency Rules of Practice and Procedure (Ref. 27), and 10 CFR Part 51 in the 1996 decommissioning rule (61 FR 39278; July 29, 1996) pertain to this third phase of decommissioning.

In addition, Volumes 1 and 2 of Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, to NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, issued November 2002 (Ref. 28) (the Decommissioning GEIS), as well as the supplemental information to the 1988 decommissioning rule (53 FR 24018; June 27, 1988), evaluate the environmental impact of the following three decommissioning methods: DECON, SAFSTOR, and ENTOMB.1 In 2018, the NRC determined that ENTOMB should be removed from guidance as a standard decommissioning strategy because the use of entombment should be considered only in special circumstances for the decommissioning of nuclear power reactors for release for unrestricted use. The use of the ENTOMB decommissioning method would be evaluated on a case-by-case basis. The remaining two decommissioning methods are described below:

(1) DECON. The equipment, structures, and portions of the facility and site that contain radioactive contaminants are promptly removed or decontaminated to a level that permits termination of the license shortly after cessation of operations. The Decommissioning GEIS found DECON to be an acceptable decommissioning method.

(2) SAFSTOR. The facility is placed in a safe, stable condition (safe storage) and maintained in that condition until it is subsequently decontaminated and dismantled to levels that permit license termination. During SAFSTOR, a facility is left largely intact; however, the fuel has been removed from the reactor vessel, and radioactive liquids have been drained from systems and components and then processed. Radioactive decay occurs during the SAFSTOR period, reducing 1

ENTOMB is a decommissioning method in which the radioactive structures, systems, and components (SSCs) are encased in a structurally long-lived substance such as concrete. The entombed structure is appropriately maintained and kept under continued surveillance until the radioactivity decays to a level that permits termination of the license. Because most power reactors will have radionuclides in concentrations that exceed the limits for unrestricted use even after 100 years, this option is not considered feasible for U.S. nuclear power reactor facilities, where the general goal of the decommissioning process is unrestricted release of the site for future beneficial use. However, entombment might be acceptable for other types of production and utilization facilities where radionuclide levels will decay to unrestricted use levels in about 100 years.

Entombment is to be considered only as a last resort for decommissioning. Licensees should select or consider this method only under unique circumstances, where it would provide more benefit than harm to public health and safety and the environment and would not create a legacy situation for future generations to manage. If the ENTOMB method is used, the provisions in 10 CFR Part 20, Subpart E, related to unrestricted or restricted use still apply. Any NRC approval of an entombment approach would be predicated on institutional controls and other measures remaining in place that would protect public health and safety.

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RG 1.184, Rev. 2, Page 10 the quantity of contaminated and radioactive material that must be disposed of during subsequent decontamination and dismantlement. The definition of SAFSTOR also includes the decontamination and dismantlement of the facility at the end of the storage period. The safe storage period is considered to be any length of time greater than that needed for prompt decommissioning under the DECON method for a similar facility. The Decommissioning GEIS found SAFSTOR to be an acceptable decommissioning method.

Supplement 1 to NUREG-0586 recognizes that some combination of the DECON and SAFSTOR methods would also be an acceptable decommissioning approach. For example, a licensee could conduct a partial decontamination of the plant followed by a storage period and then complete the decontamination and dismantlement in preparation for license termination.

Figure 1. Simple decommissioning timeline As shown in figure 1, the decommissioning regulations require a licensee to a submit written certification to the NRC within 30 days of deciding to permanently shut down a power reactor. Before or within 2 years after permanent cessation of operations, the licensee is required to submit a PSDAR. No major decommissioning activities may be performed until 90 days after the NRC has received the PSDAR and until the submittal of the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel. Major decommissioning activities are defined in 10 CFR 50.2 and 10 CFR 52.1 as any activities that result in permanent removal of major radioactive components, that irreversibly modify the structure of the containment, or that result in the dismantling of components for shipment containing greater-than-Class-C waste. The regulations at 10 CFR 50.82(a)(3) and 10 CFR 52.110(c) state that decommissioning of the site (including a general license ISFSI facility, if Pre-Decisional

RG 1.184, Rev. 2, Page 11 present) must be completed within 60 years of permanent cessation of operations, unless the NRC approves an extended timeline when this is necessary to protect public health and safety.

Decommissioning Funding The 1996 decommissioning rule changed licensees ability to access the trust funds set aside for radiological decommissioning under 10 CFR 50.75. A licensee can use the trust funds only upon reaching certain milestones in the decommissioning process. This limitation is designed to ensure that sufficient funds are always available to place the facility in a safe, stable condition that ultimately leads to decontamination of the site and license termination. The licensee may use up to 23 percent of the amount (specified in 10 CFR 50.75(c)) in the decommissioning trust funds (DTFs) for decommissioning activities before submitting a site-specific DCE, which is required to be submitted as part of the PSDAR. Included in this 23 percent is an initial 3 percent that the licensee can use, even before permanent cessation of operations, for decommissioning planning, which does not include planning for the management of spent fuel. The licensee may use the remaining 20 percent for active decommissioning activities (DECON) or to ready the facility for a period of safe storage (SAFSTOR). This 20 percent may be used only after the licensee has submitted the certifications specified by 10 CFR 50.82(a)(1) or 10 CFR 52.110(a), and after the 90-day period following submission of the PSDAR. The remaining DTFs are available for use for decommissioning activities, consistent with 10 CFR 50.82(a)(8)(i) and 10 CFR 52.110(h)(1), after the licensee submits a site-specific DCE.

The following documents contain information that may help licensees develop site-specific decommissioning cost estimates:

NUREG/CR-0672, Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station, issued June 1980 (including Addenda 1-4) (Ref. 29)

NUREG/CR-0130, Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, issued June 1978 (including Addenda 1-4)

(Ref. 30)

NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized Water Reactor Power Station, issued November 1995 (Ref. 31)

NUREG/CR-6174, Revised Analyses of Decommissioning for the Reference Boiling Water Reactor Power Station, issued July 1996 (Ref. 32)

NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities The NRC staff recognizes that, during the planning process for decommissioning while in operation, the licensee must consider activities related to the storage of spent fuel. Accordingly, the licensee may choose to commingle the funding for spent fuel planning, maintenance, and storage required by 10 CFR 50.82(a)(4)(i)(D) and 10 CFR 50.82(a)(8)(vii), and by 10 CFR 52.110(d)(1)(iv) and 10 CFR 52.110(a)(5), in the same trust fund that it uses for radiological decommissioning. However, funds set aside for decommissioning planning (up to 3 percent of the DTF) must not be used for spent fuel management planning during operation; this is not allowed without an exemption from the NRC requirements, and these funds must remain separate and accounted for as such unless approved otherwise.

The licensee must be able to identify and track the amounts in the trust fund applicable to radiological decommissioning activities and the amounts set aside for spent fuel management and other uses.

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RG 1.184, Rev. 2, Page 12 Pursuant to 10 CFR 50.75(h)(1)(iv) and 10 CFR 50.75(h)(2), until final decommissioning has been completed, unless otherwise approved through a regulatory exemption, funds collected and set aside in the DTF for decommissioning are exclusively for radiological decommissioning as defined in 10 CFR 50.2 and 10 CFR 52.1. Therefore, expenses for which these funds can be used include expenses directly related to removing a facility or site safely from service and reducing residual radioactivity to a level that permits license termination and release of the property for unrestricted or restricted use. These expenses may include, but are not limited to, the following:

expenses directly related to activities that satisfy the definition of decommission in 10 CFR 50.2 or 10 CFR 52.1 expenses directly related to decommissioning planning and execution, including consulting and paper studies, environmental assessments, engineering, and licensing activities, as well as legal expenses associated with these areas expenses directly related to the decontamination and dismantling of SSCs (labor, materials, and equipment), including disposal of waste generated from these activities expenses directly related to the disposal of contaminated SSCs (labor, materials, and equipment) expenses directly related to radiological soil remediation (labor, materials, and equipment),

including disposal of waste expenses directly related to overhead costs (i.e., emergency planning and security) and energy (e.g., electricity and fuel) used in support of decommissioning activities and to maintain site safety and security expenses directly related to undistributed costs, such as property taxes and nuclear insurance, required while in decommissioning and until license termination expenses directly related to improving the efficiency and effectiveness of the decommissioning process (demonstrated through a cost-benefit analysis to reduce expenses and preserve the DTF),

and to improving site safety and security While in operation, the licensee should not reallocate or use the DTF amount set aside for radiological decommissioning, as required by 10 CFR 50.75, for (1) the maintenance and storage of spent fuel in the SFP, (2) the design, construction, or operation of spent fuel storage facilities (e.g., an ISFSI) on the reactor site, or (3) other activities not directly related to radiological decontamination or dismantlement of the facility or site. Again, licensees must obtain an exemption from the NRC requirements in order to spend DTF funds on anything other than radiological decommissioning activities, except as allowed in 10 CFR 50.82 or 10 CFR 52.110. Additional information about the appropriate use of funds during decommissioning is available in RG 1.159.

Consideration of International Standards The International Atomic Energy Agency (IAEA) works with member states and other partners to promote the safe, secure, and peaceful use of nuclear technologies. The IAEA develops Safety Requirements and Safety Guides for protecting people and the environment from harmful effects of ionizing radiation. This system of safety fundamentals, safety requirements, safety guides, and other relevant reports, reflects an international perspective on what constitutes a high level of safety. To inform Pre-Decisional

RG 1.184, Rev. 2, Page 13 its development of this RG, the NRC considered IAEA Safety Requirements and Safety Guides pursuant to the Commissions International Policy Statement (Ref. 33) and Management Directive and Handbook 6.6, Regulatory Guides (Ref. 34).

The following IAEA Safety Requirements and Safety Guides were considered in the update of this RG:

IAEA Safety Standard Series No. GSR Part 6, Decommissioning of Facilities, issued July 2014 (Ref. 35)

IAEA Safety Standard Series No. SSG-47, Decommissioning of Nuclear Power Plants, Research Reactors, and Other Nuclear Fuel Cycle Facilities, issued October 2018 (Ref. 36)

IAEA Safety Standard Series No. SSG-49, Decommissioning of Medical, Industrial and Research Facilities, issued May 2019 (Ref. 37)

IAEA Safety Standard Series No. WS-G-5.2, Safety Assessment for the Decommissioning of Facilities Using Radioactive Material, issued December 2008 (Ref. 38)

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RG 1.184, Rev. 2, Page 14 C. STAFF REGULATORY GUIDANCE This section describes in detail the methods, approaches, or data that the NRC staff considers acceptable for meeting the requirements of 10 CFR Part 50, 10 CFR Part 51, and 10 CFR Part 52 for the decommissioning of nuclear power reactors.

1.

Certification of Permanent Cessation of Operations As stated in 10 CFR 50.82(a)(1)(i) and 10 CFR 52.110(a)(1), when a licensee has decided to permanently cease operations at a nuclear power reactor unit, it must submit a written certification to the NRC within 30 days of that determination. Note that the rule requires the licensee to submit the certification within 30 days of the decision to permanently cease operations, rather than within 30 days of actual facility shutdown. The NRC considers the 30-day clock to start on the day that the licensee publicly announces the date on which the facility will permanently cease operations. If the facility has already been shut down, the date of permanent cessation of operations corresponds to the day that the decision is made not to seek to return to power-generation operation. If the NRC issues an order to permanently cease operations at a facility, the certification is required within 30 days of the effective date of the order.

According to 10 CFR 50.4(b)(8) and 10 CFR 52.3(b)(8), the certification must state the date on which operations permanently ceased, or will permanently cease, and must be submitted under oath or affirmation. This certification is deemed to have already been submitted for licensees whose licenses were permanently modified before the effective date of the 1996 decommissioning rule to allow for possession, but not operation, of the facility, as stated in 10 CFR 50.82(a)(1)(iii). Following submission of the certification of permanent cessation of operations, the facility license continues in effect beyond the expiration date until the NRC notifies the licensee in writing that the license has been terminated (in accordance with 10 CFR 50.51(b) and 10 CFR 52.109, Continuation of combined license). The continuation of the license is specifically intended to allow a decommissioning licensee to take the actions necessary to dismantle and decontaminate the plant, maintain the safety of the facility and the spent fuel, and conduct activities in accordance with all other restrictions applicable to the facility, pursuant to the NRC regulations and the provisions of the facilitys specific 10 CFR Part 50 or 10 CFR Part 52 license. A permanently shutdown facility does not require an amendment to the facility license to extend the expiration date of the operating license.

The NRC views the certification of permanent cessation of operations as a commitment by the licensee to cease operations on the specified date. Following submission of the certification of permanent cessation of operations, but before the facility ceases operation for the final time, if the licensee desires to change the date for permanent cessation of operations it must notify the NRC of its intentions in writing.

Licensees that have only submitted a written notification of the intent to decommission a facility at some point in the future, but have not established or certified the date by which the facility will permanently cease operations, should also consider notifying the NRC in writing of any changes.

2.

Certification of Permanent Removal of Fuel Once the fuel is permanently removed from the reactor vessel, 10 CFR 50.82(a)(1)(ii) and 10 CFR 52.110(a)(2) require the licensee to submit a written certification to the NRC, consistent with 10 CFR 50.4(b)(9) and 10 CFR 52.3(b)(9), respectively, stating the date on which the fuel was permanently removed from the reactor vessel and the disposition of the fuel. For example, the licensee should state whether the spent fuel was transferred to another 10 CFR Part 50 or 10 CFR Part 52 licensee, placed in the facilitys SFP, or stored in an ISFSI. This certification of the permanent removal of fuel from the reactor vessel must be submitted under oath or affirmation.

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RG 1.184, Rev. 2, Page 15 Although in certain situations the regulations may require the licensee to submit the certification of permanent cessation of operations before it permanently shuts down the facility, the licensee may submit the certification of permanent removal of fuel only after all the fuel has been removed from the reactor vessel. In 10 CFR 50.2 and 10 CFR 52.1, the NRC defines permanent fuel removal for a nuclear power reactor facility as a certification by the licensee to the NRC that it has permanently removed all fuel assemblies from the reactor vessel. This certification is deemed to have already been submitted for licensees whose licenses were permanently modified before the effective date of the 1996 decommissioning rule to allow for possession, but not operation, of the facility, as stated in 10 CFR 50.82(a)(1)(iii).

There are no requirements on the time interval between the decision to permanently cease operations and the submittal of the certification of permanent removal of fuel. However, until the NRC has received the certification of permanent fuel removal, the licensee does not qualify for the removal of those regulatory requirements that the nonoperational status of the facility renders unnecessary to protect public health and safety, nor does it qualify for a reduction in the fees required by 10 CFR 171.15, Annual fees: reactor licenses and independent spent fuel storage licenses (Ref. 39).

The NRC staff expects to receive the certification to permanently cease operations before the certification of permanent fuel removal, although the staff would also find it acceptable to receive a combined certification (e.g., if the reactor core was offloaded before the licensee decided to permanently shut down the facility). According to 10 CFR 50.82(a)(2) and 10 CFR 52.110(b), when the NRC has docketed both the certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations at the facility comes into effect, the 10 CFR Part 50 or 10 CFR Part 52 license no longer authorizes the operation of the reactor or emplacement of fuel into or retention of fuel in the reactor vessel.

Following submission of the certification of permanent fuel removal, or at any time during the decommissioning process, if the licensee desires to operate the facility again, it must notify the NRC of its intentions in writing. The NRC will handle review and approval activities to return the facility to operation on a case-by-case basis, and the extent of review, inspection oversight, and approval will depend on the facilitys status at the time that the licensee submits the notification regarding its intent to return to operation. The prohibition on continuing reactor operation does not apply to licensees that have submitted only the certification of permanent cessation of operations but not the certification of permanent removal of fuel from the reactor vessel.

3.

Post-Shutdown Decommissioning Activities Report The regulations at 10 CFR 50.82(a)(4)(i) and 10 CFR 52.110(d)(1) require the licensee to submit a PSDAR to the NRC, and to send a copy to the affected State(s), before or within 2 years after permanent cessation of operations. In general, the PSDAR must contain a description of the planned decommissioning activities, a schedule for their accomplishment, a discussion of whether the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate federally issued environmental review documents and the reasons for reaching that conclusion, and a description of any decommissioning activities whose environmental impacts will not be so bounded and will be evaluated before the activities are performed. The PSDAR must also contain a discussion of the licensees planned actions for managing spent fuel and a site-specific DCE, including the projected cost of managing spent fuel. RG 1.185 provides additional guidance on the content and level of detail to be included in the PSDAR.

If the licensee identifies decommissioning activities with significant environmental impacts that are not bounded by appropriate federally issued environmental review documents, it should state how it Pre-Decisional

RG 1.184, Rev. 2, Page 16 intends to comply with 10 CFR 50.82(a)(6)(ii) or 10 CFR 52.110(f)(2) before undertaking the decommissioning activity. For certain decommissioning activities planned to occur in the future, the licensee may not be able to conclude definitively at the PSDAR stage that all significant environmental impacts will be bounded. The licensee should identify all such activities in the PSDAR and address all potential unbounded impacts closer to, but still before, the time at which it undertakes these activities.

4.

PSDAR Public Meeting Once the NRC receives the PSDAR, it will docket the report, publish a notice acknowledging the receipt and availability of the PSDAR in the Federal Register, and solicit public comments in accordance with 10 CFR 50.82(a)(4)(ii) and 10 CFR 52.110(d)(2). A copy of the PSDAR will be made available to the public in the NRCs Public Document Room and electronically through the NRCs Agencywide Documents Access and Management System (ADAMS) at https://www.nrc.gov/reading-rm/adams.html.

The NRC will schedule a public meeting near the site to discuss the licensees plans for decontamination and dismantlement of the facility, and the decommissioning timeframe, as well as to hear public comments on the decommissioning activities described in the PSDAR. Whenever possible, the public meeting should be held within 90 days of the NRCs receipt of the licensees PSDAR submittal; normally, the NRC will hold the meeting at least 30 days before the 90-day period ends.

The NRC will publish a notice of this public meeting in the Federal Register and in a place or places readily available to individuals near the site, such as a local newspaper. The notice will include the date, time, and location of the meeting and will briefly describe the purpose of the meeting. Comments received by the NRC staff on the PSDAR will be addressed at the public meeting, and a question-and-answer period will follow the presentations. The NRC will prepare a written transcript of the meeting and make it available to the public through the Public Document Room and electronically in ADAMS. In addition, the NRC staffs standard practice for reviewing the PSDAR is to provide an acknowledgment letter to the licensee that summarizes the staffs understanding of the PSDAR, provides highlights from the PSDAR public meeting, and categorizes the stakeholder comments received on the PSDAR during both the public meeting and the comment period.

The public meeting will be informational and should be chaired by a senior member of the NRC staff involved in the decommissioning of the facility. During the public meeting, the NRC will invite the licensee to present its plans for decommissioning the facility. During the public meeting or during a preceding government-to-government meeting on the same topic, the NRC will offer a representative from each affected State the opportunity to discuss any State regulations or oversight roles that may apply during decommissioning. Other representatives from the affected States, local officials, and the general public will be invited to comment on the licensees PSDAR during the public meeting.

5.

Initial Decommissioning Activities As stated in 10 CFR 50.82(a)(5) and 10 CFR 52.110(e), the licensee may not perform any major decommissioning activities, as defined in 10 CFR 50.2 and 10 CFR 52.1, until 90 days after the NRC has received the licensees PSDAR submittal, and until the licensee has submitted its certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel. The NRC staff may use this 90-day period to conduct pre-decommissioning inspections to verify that the licensees programs and controls are adequate to ensure the safe conduct of decommissioning activities, and the protection of public health and safety and the environment.

After 90 days, the licensee may proceed with the major decommissioning activities allowed under 10 CFR 50.82 and 10 CFR 52.110 unless the Commission issues an order prohibiting or limiting any major decommissioning activities because of, for example, a deficiency in the PSDAR. To minimize any Pre-Decisional

RG 1.184, Rev. 2, Page 17 delay in major decommissioning activities resulting from the 90-day waiting period, licensees may opt to submit the PSDAR before permanent cessation of operations or permanent removal of fuel from the reactor vessel. However, licensees must submit their certifications of permanent cessation of operations and permanent removal of fuel before initiating any major decommissioning activities. Additionally, as stated in 10 CFR 50.82(a)(4)(i)(C) and 10 CFR 52.110(d)(1)(iii), licensees may not start to decommission SSCs needed for moving, unloading, and shipping spent fuel that is stored in a general license ISFSI until the NRC has received the licensee's submittal of its PSDAR.

6.

Major Decommissioning Activities As long as fuel remains in the reactor core, facility modifications under 10 CFR 50.59 and 10 CFR 52.63(b)(2) must be consistent with continued facility operation. Once the licensee has certified that the facility has permanently ceased operations and that the fuel has been permanently removed from the reactor vessel, and the 90-day period has passed, it may begin major decommissioning activities, as defined in 10 CFR 50.2 and 10 CFR 52.1 (e.g., permanent removal of major radioactive components).

The licensees decommissioning activities are prescribed by the regulations in 10 CFR 50.59, 10 CFR 50.82, and 10 CFR 52.110. In addition, as stated in 10 CFR 50.82(a)(6) and 10 CFR 52.110(f),

licensees of permanently shutdown reactors may not perform any decommissioning activities that foreclose the release of the site for possible unrestricted use, result in significant environmental impacts not bounded by appropriate federally issued environmental review documents, or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning.

If significant environmental impacts are identified that are not bounded by appropriate federally issued environmental review documents, the licensee should state in the PSDAR how it intends to comply with 10 CFR 50.82(a)(6)(ii) or 10 CFR 52.110(f)(2) before undertaking the associated decommissioning activity. Licensees should maintain documentation of their analyses showing compliance with 10 CFR 50.82(a)(6)(ii) or 10 CFR 52.110(f)(2) for any identified site-specific environmental impacts from decommissioning activities. For example, the demolition or physical modification of a structure greater than 50 years old could be considered an adverse effect on a historic property under the National Historic Preservation Act. In this case, the licensee should consult with the State Historic Preservation Officer and contact the NRC. This may be considered a significant environmental impact that is not bounded and should be evaluated according to 10 CFR 50.82(a)(6)(ii) or 10 CFR 52.110(f)(2). RG 1.185 provides additional information on incorporating a discussion of the environmental impacts of site-specific decommissioning activities into the PSDAR.

Performing decommissioning activities that result in significant environmental impacts not bounded by appropriate federally issued environmental review documents may constitute a violation of 10 CFR 50.82(a)(6) or 10 CFR 52.1010(f).

7.

Technical Regulations and Requirements 7.1 Technical Specifications The NRC regulations explicitly extend requirements for specific portions of the technical specifications that will cover decommissioning activities. Decommissioning technical specifications are developed on a case-by-case basis, as stated in 10 CFR 50.36(c)(6). The licensee reviews the operational technical specifications and determines which ones no longer apply during decommissioning and which ones should remain in force. Most of the specifications, associated surveillance requirements, and bases related to SSCs that will no longer be in service once the facility enters decommissioning are eligible for removal from the technical specifications. The licensee will make the appropriate submittals to the NRC to request changes to the technical specifications as required by the regulations, and the NRC will Pre-Decisional

RG 1.184, Rev. 2, Page 18 approve the proposed changes if the revised technical specifications continue to meet the NRCs requirements for reasonable assurance of protection of public health and safety and the environment, given the reduced radiological risks at a decommissioning facility.

7.2 Effluent Releases and Reporting Technical specifications for effluent releases are specified in 10 CFR 50.36a, Technical specifications on effluents from nuclear power reactors. In addition to complying with the applicable provisions of 10 CFR 20.1301, Dose limits for individual members of the public, the licensee should develop technical specifications that require it to establish and follow operating procedures for the control of effluents as outlined in 10 CFR 50.34a(c), when applicable, and to maintain and use the radioactive waste system under 10 CFR 50.34a(a). This applies during both plant operation and decommissioning.

The regulation in 10 CFR 50.36a(a)(1) requires the licensee to retain these operating procedures as a record until the NRC terminates the license and to keep all superseded revisions to the procedures for 3 years from the date they were superseded.

Licensees must continue to meet the requirements of 10 CFR 50.36a(a)(2) to submit an annual report to the NRC that specifies the quantity of each of the principal radionuclides released from the facility to unrestricted areas in liquid and gaseous effluents during the previous 12 months. The report must include any other information that the NRC may need to estimate the maximum potential annual radiation doses to the public resulting from effluent releases. The time between submittal of the reports must be no longer than 12 months. If the quantities of radioactive materials released during the reporting period are significantly greater than the design objectives for the facility when it was operating, or if they are outside the scope of what would be expected based on the ongoing decommissioning activities at the site, the report must specifically discuss the reasons for this discrepancy.

Based on these annual reports, along with any additional information provided, the NRC will require the licensee to take actions that the agency deems appropriate to control and monitor offsite liquid and gaseous effluent releases. Licensees may continue to use the values in Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable (ALARA) for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, to 10 CFR Part 50. Appendix I provides numerical guidance for meeting the requirements on radioactive materials in effluents released to unrestricted areas.

The controlled release of effluents within specified limits is an established part of normal nuclear facility operations and decommissioning, and the NRCs regulations and licensing reviews take into account such releases as part of the NRCs safety and environmental determinations. Both NRC regulations and facility license conditions require the licensee to ensure that the releases of gaseous and liquid effluents meet the applicable NRC and U.S. Environmental Protection Agency requirements. The NRC also requires the licensee to maintain a radiological environmental monitoring program (REMP) to provide data on measurable levels of radiation and radioactive materials in the local environment.

The licensee also must notify the NRC if any of the NRCs regulatory limits, or certain limits established in the Offsite Dose Calculation Manual (ODCM) related to ALARA goals, are exceeded. In such an instance, the licensee must prepare and submit a special report to the NRC, as described in the ODCM. This report should, in part, identify why any limits were exceeded and describe the corrective actions planned and taken. Upon receiving such a report, the NRC staff will conduct inspections or other investigations to determine any necessary enforcement actions.

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RG 1.184, Rev. 2, Page 19 In addition, the licensee is required to submit to the NRC an annual radiological environmental operating report containing the results of the REMP and an annual radioactive effluent release report, both of which are made publicly available.

7.3 Maintenance Rule The maintenance rule (10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants) requires licensees to monitor the performance or condition of certain SSCs that could affect safety. For licensees that have submitted certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel, as specified in 10 CFR 50.82(a)(1) and 10 CFR 52.110(a), this requirement applies only to the extent that the licensee monitors the performance or condition of the SSCs associated with the storage, control, and maintenance of spent fuel in a safe condition within the SFP. The monitoring activities must be sufficient to provide reasonable assurance that SSCs related to the storage of spent fuel are capable of fulfilling their intended functions, as specified in 10 CFR 50.65(a)(1).

7.4 Final Safety Analysis Report Content The final safety analysis report (FSAR), or another comparable document, provides a licensing-basis document for use in the evaluation of licensee activities under 10 CFR 50.59. The licensee must update and periodically adjust this licensing-basis document to cover decommissioning activities.

According to 10 CFR 50.71(e)(4), nuclear power facility licensees that have submitted certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel must file subsequent revisions that update the FSAR and its associated licensing basis with the NRC at least every 24 months. (Although some licensees choose to refer to the FSAR as the decommissioning safety analysis report (DSAR) during decommissioning, the requirements of 10 CFR 50.71(e) continue to apply to a DSAR, as that term is not defined or recognized in the NRCs regulations.) In addition, the license termination plan must be submitted as a supplement to the FSAR or equivalent in accordance with 10 CFR 50.82(a)(9)(i) or 10 CFR 52.110(i)(1). The subsections below describe specific sections of the FSAR that the licensee should continue to update periodically during decommissioning.

7.4.1 Facility Description The licensee must describe, primarily in the PSDAR, the facilitys status at the time the facility is shut down and before any decommissioning or dismantlement activities occur, and must subsequently make the accompanying changes to the FSAR. The licensee should update only the descriptions of those facility SSCs that are included in the technical specifications after the transition to decommissioning, or that directly affect the safe storage of spent fuel. However, during decommissioning, the licensee should make general updates to the FSAR to reflect the current condition of SSCs that were in the operating-plant version of the FSAR, to maintain an overall understanding of the configuration basis of the plant. The updates should identify changes as systems are decontaminated, inactivated, mothballed for later use, or reconfigured to support changes to their previous functions. Even though a given SSC may no longer have a direct safety function, there is an overall safety benefit in documenting its status or design function while the plant is in decommissioning.

For example, a cooling water system may no longer be required to provide a safety-related heat sink. However, if the system continues to be functional, then the operation of the wrong valve, a system fault or breakage, or a misalignment of interfaces to the system could cause accidents such as flooding, personnel injury, or flushing of potentially radioactive material into an uncontaminated location.

Therefore, at a minimum, the licensee should maintain enough detail in the FSAR to give the status of all operating licensing-basis SSCs until they are no longer mechanically or electrically active, are no longer Pre-Decisional

RG 1.184, Rev. 2, Page 20 radioactively contaminated, have no fluid content or other materials that require special handling considerations, or have been physically removed during dismantlement. System disablement for mechanical and electrical systems should rely on physical controls difficult to reverse, such as removal of piping spool pieces and electrical breakers, rather than valve and breaker positioning and tagging.

7.4.2 Licensee Organization The FSAR or comparable document should describe the licensees corporate and site organization during decommissioning. It should describe the structure, functions, and responsibilities of the onsite organization established to decommission, and provide oversight of the decommissioning of, the facility, including the use of a decommissioning general contractor if applicable.

7.4.3 Radioactive Waste Management The scope remains the same as in the operating-phase FSAR.

7.4.4 Radiation Protection The scope remains the same as in the operating-phase FSAR.

7.4.5 Conduct of Operations The scope remains the same as in the operating-phase FSAR.

7.4.6 Site Characteristics The licensee should update any sections of the FSAR that discuss the site characteristics that support the safe storage of spent fuel or that could directly affect the design basis of the facility.

7.4.7 Accident Analysis The licensee should evaluate any new or different design-basis accidents identified during 10 CFR 50.59 evaluations of the changes planned during decommissioning and include them in FSAR updates, if appropriate (e.g., accidents involving a newly installed gas pipeline within or near the facility).

Conversely, as decommissioning progresses, the licensee may remove any design-basis accidents that are no longer possible from the FSAR or comparable document (e.g., the design basis of a facility where the spent fuel has been transferred from the SFP to an ISFSI would be significantly changed; therefore, the licensee should update the FSAR to reflect this change).

7.5 Record Retention Requirements Nuclear power reactor licensees that have certified that they have permanently ceased operations and permanently removed the fuel from the reactor vessel can eliminate records associated with SSCs that no longer serve any NRC-regulated function. This is allowed as long as the licensee uses appropriate change mechanisms, such as the 10 CFR 50.59 evaluation process or NRC-approved technical specification changes, to determine that elimination of the records will not adversely impact public health and safety, and as long as there are no other site-specific requirements necessitating the retention of certain records, such as a Commission order or the provisions of 10 CFR 50.75(g).

The records eligible for elimination are those associated with SSCs that were important to safety during power operation or operation of the SFP, but that can no longer cause an event, incident, or Pre-Decisional

RG 1.184, Rev. 2, Page 21 condition that would adversely impact public health and safety, as evidenced by their removal from the licensing-basis documents (e.g., the FSAR). If the SSCs no longer have the potential to cause such scenarios, it is reasonable to conclude that the NRC will not need the records associated with them to determine compliance or noncompliance, take action on possible noncompliance, or examine facts following an incident. Therefore, retention of such records would not serve the underlying purpose of the recordkeeping requirements.

The following regulations ensure that records associated with SSCs will be captured, indexed, and stored in an environmentally suitable and retrievable condition: 10 CFR 50.59(d)(3);

10 CFR 50.71(c); 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion 1, Quality Standards and Records; and 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion XVII, Quality Assurance Records. Although licensees must retain the records required by their license as the plant transitions from operating conditions to a fully decommissioned state, plant dismantlement will obviate the regulatory and business need for the maintenance of most records. The 2024 decommissioning rulemaking amended many of the above-cited regulations, in addition to 10 CFR 52.63(b)(2) and Section X.A.3 of 10 CFR Part 52, Appendices A through G, to reflect this recordkeeping approach during decommissioning.

As the SSCs already removed from the licensing basis are subsequently dismantled and as the associated records become (on a practical basis) unnecessary, licensees can dispose of these records, as well as records of historical activities that are no longer relevant, and thereby eliminate the regulatory and economic burdens of creating alternative storage locations, relocating the records, and retaining the records. Considering the content of these records, their elimination at this stage has no reasonable potential to present any undue risk to public health and safety. In addition, upon dismantlement of the relevant SSCs, the records have no functional purpose in maintaining the safe operation of the SSCs, maintaining conditions that would affect the ongoing health and safety of workers or the public, or informing decisions related to nuclear safety.

Furthermore, as part of the 2024 decommissioning rulemaking, the NRC amended the portion of 10 CFR 72.72(d) that requires records for spent fuel in storage to be kept in duplicate for the ISFSI. The change allows such records to be stored in a single location, as long as it is controlled by an NRC-approved quality assurance program (QAP). Specifically, 10 CFR 72.140(d) states that the NRC will accept a QAP that the agency has approved as meeting the applicable requirements of 10 CFR Part 50, Appendix B, as satisfying the requirements of 10 CFR 72.140(b) for establishing an ISFSI QAP. However, the licensee must also meet the recordkeeping provisions of 10 CFR 72.174, Quality assurance records. This change does not affect the record content, retrievability, or retention requirements in 10 CFR 72.72, Material balance, inventory, and records requirements for stored materials, or 10 CFR 72.174.

In making these recordkeeping changes, the NRC determined that the process and procedures used to store the ISFSI records (i.e., their storage in accordance with the QAP at a facility designed for protection against degradation mechanisms such as fire, humidity, and condensation) will help ensure that the licensee will adequately maintain the required spent fuel information. Therefore, the changes to the duplicate record requirement of 10 CFR 72.72(d) will not affect public health and safety or endanger life or property. Furthermore, storing the ISFSI records in the same manner as all other quality assurance records will be more efficient once the facility enters the final stages of decommissioning, since only the ISFSI facility will remain after license termination. The use of separate storage methods for certain ISFSI records would unnecessarily divert resources from decommissioning activities.

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RG 1.184, Rev. 2, Page 22 7.6 Fire Protection Requirements The fire protection regulations in 10 CFR 50.48(f) require licensees that have certified the permanent cessation of operations and permanent removal of fuel from the reactor vessel to maintain a fire protection program to address the potential for fires that could result in a radiological hazard. The objectives of the fire protection program delineated in 10 CFR 50.48(f)(1) are to (1) reasonably prevent such fires from occurring, (2) rapidly detect, control, and extinguish fires that could result in a radiological hazard, and (3) minimize the risk of fire-induced hazards to the public, the environment, and plant personnel.

Further, 10 CFR 50.48(f)(2) requires licensees to assess the fire protection program regularly and revise it as needed throughout the various stages of decommissioning. The requirements of 10 CFR 50.48(f)(3) permit licensees to make changes to the fire protection program without NRC approval if these changes do not reduce the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, taking into account the conditions and activities of decommissioning at the facility. RG 1.191 presents additional guidance.

7.7 Certified Fuel Handler Staffing and Management Role The provisions of 10 CFR 50.51(b) and 10 CFR 52.109 state that each license for a production or utilization facility that has permanently ceased operations continues in effect beyond the expiration date until the Commission notifies the licensee in writing that the license is terminated. During this period of continued effectiveness, 10 CFR 50.51(b) or 10 CFR 52.109, as applicable, requires the licensee to do the following:

(1)

Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, to store, control, and maintain the spent fuel in a safe condition.

(2)

Conduct activities in accordance with all other restrictions applicable to the facility, in accordance with NRC regulations and the provisions of the specific facility license.

To comply with these requirements, licensees should designate one or more individuals to perform the following key functions during decommissioning: (1) safe conduct of decommissioning activities, (2) safe handling and storage of spent fuel, (3) response to emergencies, and (4) command and control over functions (1)-(3). To perform these functions, the decommissioning staff should have training, knowledge, and understanding of the following:

a.

radiological safety principles and monitoring;

b.

the facility/system design and function;

c.

facility administrative and safety procedures (i.e., normal, abnormal, and emergency procedures, accident analysis, and the facilitys emergency plan), as appropriate for the current plant status;

d.

the facility license;

e.

the content, bases, and importance of the facilitys technical specifications; and

f.

thermodynamics, heat transfer, fluid mechanics, electrical theory, and mechanical component operation as related to the monitoring, handling, storage, and cooling of nuclear fuel.

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RG 1.184, Rev. 2, Page 23 Furthermore, the decommissioning staff should be able to perform the following additional functions:

a.

shift turnover;

b.

shift recordkeeping;

c.

removal and return of equipment to service;

d.

watch-standing activities;

e.

monitoring, handling, storage, and cooling of nuclear fuel; and

f.

response to emergencies.

The NRC staff considers these qualifications to be met by individuals who are designated as certified fuel handlers (CFHs). Such an individual can provide reasonable assurance that a licensee will meet the requirements of 10 CFR 50.51(b) or 10 CFR 52.109 for a permanently shutdown and defueled nuclear power reactor.

A CFH is defined in 10 CFR 50.2, for a nuclear power reactor facility, as a nonlicensed operator (NLO) who has qualified in accordance with a fuel handler training program approved by the Commission. Alternatively, per 10 CFR 50.2, a CFH can also be an NLO who has qualified in accordance with a fuel handler training program that meets the same requirements as training programs for NLOs required by 10 CFR 50.120, Training and qualification of nuclear power plant personnel, and who is responsible for decisions regarding the key decommissioning functions described above.

Safe Conduct of Decommissioning Activities The training and responsibilities of the CFH support the safe conduct of decommissioning activities at a facility that has permanently ceased operations. Specifically, the NRC staff has found that the systems approach to training, as defined in 10 CFR 55.4, Definitions, and the use of 10 CFR 50.120(b)(3) are appropriate and applicable for the training of NLOs for nuclear power reactors during decommissioning; this includes those NLOs who are also qualified as CFHs. A systems approach to training includes a systematic analysis of the jobs to be performed, and evaluation and revision of the training based on the performance of the trained personnel in the job setting. Accordingly, as plant conditions change (i.e., as the job setting changes), training programs will be revised to reflect these changes. Such revisions could include the development of new programs, such as the CFH training and retraining program, or the elimination of obsolete programs. The systems approach to training process ensures that the modification of the program to reflect the changed environment during the conduct of decommissioning activities is performed in an orderly fashion.

Safe Handling and Storage of Spent Fuel The CFH is also responsible for decisions related to the safe handling and storage of spent fuel at a decommissioning facility. As well as being responsible for the overall safety of any decommissioning-related activities at the facility, the CFH is intended to be the on-shift licensee representative who is responsible for safe fuel handling operations and for ensuring the safe maintenance and storage of spent fuel.

Response to Emergencies The CFH plays a significant role in determining the actions needed to respond to an emergency that could affect plant operations. During emergency conditions, as discussed in 10 CFR 50.54(x) and 10 CFR 73.55(p), a licensee may take reasonable action that departs from license conditions or technical specifications to protect public health and safety or, for severe weather emergencies, to protect the health Pre-Decisional

RG 1.184, Rev. 2, Page 24 and safety of security force personnel, provided that no immediately apparent action consistent with license conditions or technical specifications can provide adequate or equivalent protection.

Before the spent fuel at a permanently shutdown and defueled reactor has been transferred to dry storage (i.e., when fuel is still present in the SFP), the regulations require that such emergency actions may be approved only by a licensed senior operator, a CFH, or an organizationally senior individual, as these individuals have the requisite facility knowledge and plant experience to evaluate plant conditions and make emergency decisions. When all spent fuel is in dry storage (i.e., during the ISFSI-only level of decommissioning), the CFH is no longer necessary, since the fuel is then in a passive, static, and cool state. However, in an emergency during the ISFSI-only phase, a designated individual who is responsible for site safety is still needed to direct command and control. Therefore, when all spent fuel is in dry storage, an individual who has been designated by the facility licensee or an organizationally senior individual may make emergency decisions that depart from license conditions or technical specifications, regardless of whether that individual is a CFH. During severe weather, the decision to suspend security measures requires input from the security supervisor or manager.

Command and Control At a decommissioning facility, the shift manager often occupies the senior technical position on site and typically has overall command and control responsibilities for the key decommissioning functions discussed above. Because a CFH is also required to have training on, and is responsible for decisions related to, these functions, the shift manager is typically also qualified as a CFH. Because of their management responsibilities, the shift manager/CFH may also be one of the parties responsible for meeting the communication requirements in 10 CFR 73.55(j) in order to ensure effective command and control during both normal and emergency situations, as well as to support security personnel.

Staffing Previously, in response to license amendment requests from decommissioning licensees, the NRC staff has approved changes to the minimum levels for staff on shift in the administrative controls section of a plants technical specifications. These changes involved replacing the licensed senior operator and licensed operator positions, respectively, with one CFH and one NLO to perform activities involving the key decommissioning functions discussed above. The NRC staff recognizes that these prior approvals addressed only a few of the potential staffing scenarios at a decommissioning reactor and were generally for a single-unit plant with one SFP.2 Adequate staffing levels are expected to vary based on (1) the number of permanently shutdown reactor units on site, (2) whether any operating reactor units are on site, (3) how many active SFPs are on site, (4) whether and when all spent fuel has been relocated to an ISFSI, and (5) the organizational structure approved in the license. As noted earlier, the CFH qualification is unnecessary after all spent fuel has been transferred to dry storage (i.e., during the ISFSI-only level), because at that stage the spent fuel is all stored in a static condition. As stated in 10 CFR 50.51(b)(2), the licensee must conduct its activities in accordance with its license. Therefore, in some instances, a licensee might wish to submit a license amendment request to set appropriate site-specific staffing levels that meet 10 CFR 50.51(b).

2 On August 1, 2014, the NRC approved the Safe Storage Shift Manager/Certified Fuel Handler Training Program for the San Onofre Nuclear Generating Station, Units 2 and 3 (ML13268A165).

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RG 1.184, Rev. 2, Page 25 7.8 Changes to Emergency Planning, Physical Security, and Quality Assurance Requirements The NRC does not require details in the PSDAR on the radiation protection plan, the emergency plan, the security plan, or the quality assurance plan related to decommissioning; however, this information may be required in periodic updates to the FSAR, the QAP, the emergency plan, or other documents applicable to decommissioning. In addition, several of these areas undergo significant changes during decommissioning, which may be captured under different regulatory processes. RG 1.235 provides guidance to licensees on establishing an emergency preparedness program commensurate with the changing levels of radiological risk at a decommissioning nuclear power reactor.

8.

Changes to the PSDAR The regulation at 10 CFR 50.82(a)(7) or 10 CFR 52.110(g), as appropriate, requires the licensee to notify the NRC in writing, with a copy to the affected States, before it performs any decommissioning or spent fuel management activity inconsistent with, or that entails a significant schedule change from, the planned decommissioning activities or schedules described in the PSDAR or any previously submitted irradiated fuel management plan, including any change that significantly increases the cost of decommissioning or of managing spent fuel. A change to the PSDAR may be made through a written letter to the NRC describing the change or through an actual revision to the PSDAR.

The NRC staff will use changes to the milestone schedule in the PSDAR to schedule inspections of the licensees decommissioning activities and to verify that the licensee is conducting decommissioning safely and in accordance with the applicable regulatory requirements. Examples of changes in decommissioning activities and schedule include, but are not limited to, the following:

(1) changing from a period of safe storage (SAFSTOR) to active dismantlement (DECON), (2) changing the method used to remove the reactor vessel or steam generators from cutting and segmenting to intact removal, and (3) changing the schedule in a way that affects major milestones (e.g., shortening the overall term to complete decommissioning). Licensees do not need to report changes related to the removal of SSCs that are not contaminated or in immediate proximity to contaminated systems that could result in a worker dose. Examples of changes in spent fuel management activities and schedule include, but are not limited to, the following: (1) changing the dry storage system design, and consequently changing certain SSCs that are relied upon to safely load and store spent fuel, (2) changing the ISFSI capacity, (3) changing plans to transfer spent fuel offsite (e.g., to a consolidated interim storage facility), and (4) changing the timing of the movement of spent fuel to dry storage.

Examples of significant increases in the costs associated with decommissioning include (1) a revised cost estimate that is more than 20 percent greater than the site-specific DCE, and (2) a 25 percent increase in the funding needed to complete any major milestone activity. For any significant increase in the cost of decommissioning, the licensee must notify the NRC in writing. Notification should be made only if the cost changes are due to changes in the timing of decommissioning activities or to changes in the activities planned. Notification is not necessary if the cost increases are due solely to inflation.

However, the licensee should describe such increases in the annual report submitted in accordance with 10 CFR 50.82(a)(8)(v) or 10 CFR 52.110(h)(5).

9.

Use of Funds The regulation at 10 CFR 50.75(f)(2) requires licensees at or about 5 years before the projected end of operations to submit a preliminary site-specific DCE that includes an up-to-date assessment of the major factors that could affect the cost to radiologically decommission the facility. Before or within 2 years after permanent cessation of operations, 10 CFR 50.82(a)(4)(i) and 10 CFR 52.110(d)(1) require Pre-Decisional

RG 1.184, Rev. 2, Page 26 licensees to submit a PSDAR, which must contain a site-specific DCE, including the projected cost of managing spent fuel.

The regulations at 10 CFR 50.82(a)(8)(ii) and 10 CFR 52.110(h)(2) allow the licensee to use 3 percent of the generic amount of the decommissioning funds specified in 10 CFR 50.75(c) for decommissioning planning, and this amount may be expended during the plants operating life without any written notice to the NRC. The initial 3 percent of the decommissioning funds may be spent on activities such as engineering design development, work package preparation, and licensing activities to transition the licensing basis from operations to decommissioning. Activities for which it would not be appropriate to use these planning funds include decontamination and dismantlement activities, draining of systems, removal of filters, projects designed to demonstrate the feasibility of a particular decommissioning activity, and spent fuel management planning. As an example, it is not appropriate to use planning funds for the decontamination of a building that is no longer in use and would ultimately have to be decontaminated before license termination.

After the licensee has submitted the certifications required by 10 CFR 50.82(a)(1) or 10 CFR 52.110(a), and 90 days after the NRC has received the PSDAR, which includes a site-specific DCE, the licensee may use an additional 20 percent of the decommissioning funds prescribed in 10 CFR 50.75(c), provided that doing so does not adversely affect the licensees ability to fully fund the decommissioning trust. The licensee must ensure the availability of funds to ultimately release the site and terminate the license, and must promptly address any potential shortfalls.

The licensee is prohibited from using the remaining 77 percent of the decommissioning funds until it has submitted a site-specific DCE to the NRC. The licensee must submit this estimate with the PSDAR, before or within 2 years after permanent cessation of operations. Site-specific DCEs should include an outline of the expected costs for activities specified in the PSDAR. RG 1.185 provides further information on the level of detail to include in the PSDAR on the use of decommissioning funds.

RG 1.159 provides guidance on estimating the amount of funds for decommissioning and methods acceptable for demonstrating financial assurance.

Licensees may provide site-specific DCEs sooner than 2 years after permanent cessation of operations. A licensee that has submitted a preliminary site-specific DCE about 5 years before the projected end of operations may expand and update the preliminary estimate and submit it as the site-specific DCE. Licensees may also submit the site-specific DCE with the PSDAR; in this case, they should identify it as the site-specific DCE. This approach would eliminate the 23 percent hold point for spending the decommissioning funds, so long as the licensee has submitted the certifications required by 10 CFR 50.82(a)(1) or 10 CFR 52.110(a). Licensees that plan to begin major decommissioning activities shortly after permanent cessation of operations should consider early submission of the site-specific DCE and the PSDAR to begin the 90-day period before such activities can commence.

If the licensees PSDAR specifies a delayed completion of decommissioning, the licensee must provide a means of adjusting cost estimates and associated funding levels over the storage or surveillance period to ensure that sufficient funding will be available to terminate the license (10 CFR 50.82(a)(8)(iv) and 10 CFR 52.110(h)(4)). NUREG-1713 provides additional guidance on site-specific DCEs. In particular, it specifies the level of detail required in the financial plan on adjusting cost estimates and associated funding levels.

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RG 1.184, Rev. 2, Page 27 D. IMPLEMENTATION The NRC staff may use this regulatory guide as a reference in its regulatory processes, such as licensing, inspection, or enforcement. However, the NRC staff does not intend to use the guidance in this regulatory guide to support NRC staff actions in a manner that would constitute backfitting as that term is defined in 10 CFR 50.109, Backfitting, or 10 CFR 72.62, Backfitting, and as described in NRC Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests (Ref. 40), nor does the NRC staff intend to use the guidance to affect the issue finality of an approval under 10 CFR Part 52. The staff also does not intend to use the guidance to support NRC staff actions in a manner that constitutes forward fitting as that term is defined and described in Management Directive 8.4. If a licensee believes that the NRC is using this regulatory guide in a manner inconsistent with the discussion in this Implementation section, then the licensee may file a backfitting or forward fitting appeal with the NRC in accordance with the process in Management Directive 8.4.

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RG 1.184, Rev. 2, Page 28 REFERENCES3

1.

U.S. Code of Federal Regulations (CFR), Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.4

2.

CFR, Licenses, Certifications, and Approvals for Nuclear Power Plants, Part 52, Chapter I, Title 10, Energy.

3.

CFR, Standards for Protection against Radiation, Part 20, Chapter I, Title 10, Energy.

4.

CFR, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, Part 51, Chapter I, Title 10, Energy.

5.

CFR, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, Part 72, Chapter I, Title 10, Energy.

6.

CFR, Physical Protection of Plants and Materials, Part 73, Chapter I, Title 10, Energy.

7.

CFR, Financial Protection Requirements and Indemnity Agreements, Part 140, Chapter I, Title 10, Energy.

8.

U.S. Nuclear Regulatory Commission (NRC), Regulatory Guide (RG) 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Washington, DC.

9.

NRC, RG 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, Washington, DC.

10.

NRC, RG 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Washington, DC.

11.

NRC, RG 1.191, Fire Protection Program for Nuclear Power Plants during Decommissioning and Permanent Shutdown, Washington, DC.

12.

NRC, RG 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, Washington, DC.

13.

NRC, RG 1.235, Emergency Planning for Decommissioning Power Reactors, Washington, DC.

3 Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public website at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html. For problems with ADAMS, contact the Public Document Room staff at 301-415-4737 or (800) 397-4209, or email pdr.resource@nrc.gov. The NRC Public Document Room (PDR), where you may also examine and order copies of publicly available documents, is open by appointment. To make an appointment to visit the PDR, please send an email to pdr.resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time, Monday through Friday, except Federal holidays.

4 The Code of Federal Regulations may be obtained electronically from the U.S. Government Printing Office at:

http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR.

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RG 1.184, Rev. 2, Page 29

14.

NRC, RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination)Effluent Streams and the Environment, Washington, DC.

15.

NRC, RG 4.21, Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning, Washington, DC.

16.

NRC, RG 4.22, Decommissioning Planning during Operations, Washington, DC.

17.

NRC, RG 4.25, Assessment of Abnormal Radionuclide Discharges in Ground Water to the Unrestricted Area at Nuclear Power Plant Sites, Washington, DC.

18.

NRC, NUREG-1577, Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance, Washington, DC.

19.

NRC, NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Washington, DC.

20.

NRC, NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors, Final Report, Washington, DC.

21.

NRC, NUREG-1757, Consolidated Decommissioning Guidance, Washington, DC.

22.

CFR, Packaging and Transportation of Radioactive Material, Part 71, Chapter I, Title 10, Energy.

23.

CFR, Disposal of High-Level Radioactive Wastes in Geologic Repositories, Part 60, Chapter I, Title 10, Energy.

24.

CFR, Licensing Requirements for Land Disposal of Radioactive Waste, Part 61, Chapter I, Title 10, Energy.

25.

NRC, NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Parts 1 and 2, Washington, DC.

26.

NRC, Interim Staff Guidance Augmenting NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors, Washington, DC, October 17, 2012 (ML12156A069); Interim Staff Guidance Augmenting NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors, Washington, DC, October 17, 2012 (ML12156A075).

27.

CFR, Agency Rules of Practice and Procedure, Part 2, Chapter I, Title 10, Energy.

28.

NRC, NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors, Volumes 1 and 2, Washington, DC, November 2002 (ML023470327 and ML023500310).

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RG 1.184, Rev. 2, Page 30

29.

NRC, NUREG/CR-0672, Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station, Pacific Northwest Laboratory, Richland, WA, June 1980 (Legacy Library Accession No. 8006250171 (including Addendum 1, July 1983, Legacy Library Accession No. 8308180441; Addendum 2, September 1984, Legacy Library Accession No. 8410170289; Addendum 3, July 1988, Legacy Library Accession No. 8808120112; and Addendum 4, February 1991, Legacy Library Accession No. 9102280246)).

30.

NRC, NUREG/CR-0130, Technology, Safety, and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, Pacific Northwest National Laboratory, Richland, WA, June 1978 (Legacy Library Accession No. 7909260338 (including Addendum 1, August 1979, Legacy Library Accession No. 7909260338; Addendum 2, July 1983, Legacy Library Accession No. 8308170163; Addendum 3, September 1984, Legacy Library Accession No. 8410170293; and Addendum 4, July 1988, Legacy Library Accession No. 8808120069)).

31.

NRC, NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized Water Reactor Power Station, Volumes 1 and 2, Pacific Northwest National Laboratory, Richland, WA, November 1995 (ML14008A187).

32.

NRC, NUREG/CR-6174, Revised Analyses of Decommissioning for the Reference Boiling Water Reactor Power Station, Volumes 1 and 2, Pacific Northwest National Laboratory, Richland, WA, July 1996 (ML14008A186).

33.

NRC, Nuclear Regulatory Commission International Policy Statement, Federal Register, Vol. 79, No. 132, July 10, 2014, pp. 39415-39418.

34.

NRC, Management Directive 6.6, Regulatory Guides, Washington, DC.

35.

International Atomic Energy Agency (IAEA), Safety Standard Series No. GSR Part 6, Decommissioning of Facilities, Vienna, Austria, July 2014.5

36.

IAEA, Safety Standard Series No. SSG-47, Decommissioning of Nuclear Power Plants, Research Reactors, and Other Nuclear Fuel Cycle Facilities, Vienna, Austria, October 2018.

37.

IAEA, Safety Standard Series No. SSG-49, Decommissioning of Medical, Industrial and Research Facilities, Vienna, Austria, May 2019.

38.

IAEA, Safety Standard Series No. WS-G-5.2, Safety Assessment for the Decommissioning of Facilities Using Radioactive Material, Vienna, Austria, December 2008.

39.

CFR, Annual Fees for Reactor Licenses and Fuel Cycle Licenses and Materials Licenses, Including Holders of Certificates of Compliance, Registrations, and Quality Assurance Program Approvals and Government Agencies Licensed by the NRC, Part 171, Chapter I, Title 10, Energy.

40.

NRC, Management Directive 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests, Washington, DC.

5 Copies of IAEA documents may be obtained through the IAEA website at https://www.iaea.org/, or by writing the International Atomic Energy Agency, P.O. Box 100, Wagramer Strasse 5, A-1400 Vienna, Austria. Telephone (+431) 2600-0; fax (+431) 2600-7; or email Official.Mail@IAEA.org.

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