ML24227A987
| ML24227A987 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/2024 |
| From: | Amy Snyder Reactor Decommissioning Branch |
| To: | |
| References | |
| Download: ML24227A987 (1) | |
Text
Regulatory Analysis for Draft Interim Staff Guidance (DUWP-ISG-03) on Contamination Control, Radiological Survey, and Dose Modeling Considerations to Support License Termination at Sites with Environmental Discrete Radioactive Particle Contamination U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Rulemaking, Environmental, and Financial Support September 2024
ii Abstract One form of non-diffuse contamination, discrete radioactive particles (DRPs), has been sporadically problematic during active decommissioning at some NRC licensed power plants. The issues related to DRPs observed during decommissioning have involved DRP containment and contamination control, performance of adequate surveys for DRPs, and approaches to demonstration of compliance with 10 CFR 20, Subpart E, when taking into consideration past DRP environmental contamination. Available guidance for decommissioning is focused on addressing diffuse residual radioactivity with respect to performing surveys and assessing potential public exposure after license termination, rather than focusing on DRP contamination. Because the current radiological environmental survey and dose assessment guidance to support license termination does not address DRP contamination, the NRC staff have approached each past instance of DRP contamination on a case-by-case basis. This draft Interim Staff Guidance is expected to increase consistency across the industry and demonstrates the NRCs willingness to support the use of the most up-to-date and technically sound methodologies and techniques available to adequately protect public health and safety.
This document is a regulatory analysis for the draft Interim Staff Guidance (ISG) on radiological survey and dose modeling of DRPs to support license termination (DUWP-ISG-03). The ISG supplements guidance in Revision 2 of NUREG-1757, Volume 2, Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria - Final Report (NUREG-1757, Volume 2, Revision 2.) Comments received on the draft document will be addressed in a comment response document and a final ISG will be issued. Ultimately the ISG will be folded into the next revision (Revision 3) of NUREG-1757, Volume 2. The NRCs analysis demonstrates that the revision of the NUREG through ISG results in negligible costs and considerable benefits to licensees and the NRC.
iii Table of Contents Section Page Abstract............................................................................................................................................................ii List of Tables.................................................................................................................................................v List of Figures................................................................................................................................................v Executive Summary.....................................................................................................................................vi Abbreviations and Acronyms.....................................................................................................................vii 1.0 Introduction..............................................................................................................................................9 2.0 Statement of the Problem and Objective................................................................................................9 2.1 Background..............................................................................................................................................9 2.2 Statement of the Problem.........................................................................................................................9 2.3 Objective..................................................................................................................................................9 3.0 Identification and Preliminary Analysis of Alternative Approaches...................................................10 3.1 Alternative 1No Action........................................................................................................................10 3.2 Alternative 2Develop and Issue ISG...................................................................................................10 4.0 Estimation and Evaluation of Costs and Benefits...............................................................................11 4.1 Identification of Affected Attributes.........................................................................................................11 4.2 Analytical Methodology..........................................................................................................................12 4.2.1 Regulatory Baseline........................................................................................................................12 4.2.2 Affected Entities..............................................................................................................................12 4.2.3 Base Year.......................................................................................................................................13 4.2.4 Sign Conventions............................................................................................................................13 4.2.5 Analysis Horizon.............................................................................................................................13 4.3 Data.......................................................................................................................................................13 5.0 Results....................................................................................................................................................13 5.1 NRC Implementation..............................................................................................................................14 5.2 Industry Operation..................................................................................................................................14 5.3 NRC Operation.......................................................................................................................................15 5.4 Total Costs.............................................................................................................................................15 5.5 Improvements in Knowledge..................................................................................................................15 5.6 Regulatory Efficiency..............................................................................................................................16 5.7 Other ConsiderationsIncreased Public Confidence.............................................................................16 5.8 Uncertainty Analysis...............................................................................................................................16 5.9 Summary...............................................................................................................................................17 5.9.1 Quantified Net Cost.........................................................................................................................17 5.9.2 Non-quantified Benefits...................................................................................................................17 5.9.3 Safety Goal Evaluation...................................................................................................................17 6.0 Decision Rationale.................................................................................................................................17
iv 7.0 Implementation Schedule......................................................................................................................19 8.0 References.............................................................................................................................................20
v List of Tables Page Table ES-1 Net Cost and Benefit-viii -
Table 1 NRC Implementation Costs..................................................................................... Table 2 Industry Averted Costs from a Reduction in RAIs............................................... Table 3 NRC Averted Costs from a Reduction in RAIs.....................................................
Table 4 Total Averted Costs (Industry and the NRC) for Alternative 2............................
Table 5 Summary of Totals.................................................................................................. List of Figures Figure 1 Total costs (industry and the NRC) for Alternative 27-percent NPV.............
vi Executive Summary The NRC revised NUREG-1757, Volume 2, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria, Revision 1, issued September 2006. Between 2006 and 2022, lessons learned from decommissioning reviews and changes in technology provided the NRC with valuable experience and insights, which were captured in Revision 2 to NUREG-1757. Revision 2 was published in July 2022. This guidance (and other available guidance for decommissioning) is focused on addressing diffuse residual radioactivity with respect to performing surveys and assessing potential public exposure after license termination; it does not focus on discrete radioactive particle (DRP)1 contamination.
Draft DUWP-ISG-03 (the ISG) addresses contamination control, radiological surveys, and dose modeling regarding DRPs that were found in the environment due to an unplanned release or that potentially could be released to the environment during decommissioning.
The final ISG is planned to be incorporated into the next revision (Revision 3) of NUREG-1757, Volume 2. The NRCs commitment to continuous improvement in updating its key decommissioning guidance documents helps ensure consistency across the industry and demonstrates the NRCs willingness to support the use of the most up-to-date and technically sound methodologies and techniques available to adequately protect public health and safety. This ISG provides guidance when a licensee either has DRPs as a site characteristic (DRP contamination in the on-site environmental media) or chooses to conditionally address DRPs in its License Termination Plan (LTP) or Decommissioning Plan (DP). Doing so may avoid the need to amend the LTP or DP, which could delay license termination.
This regulatory analysis evaluates the costs and benefits associated with the issuance of the ISG relative to the baseline case (i.e., the no-action alternative). The staff makes the following key findings based on this analysis:
Cost Benefit Analysis. Issuance of the ISG is estimated to result in some averted costs to the NRC and licensees. The primary source of averted costs is an expected reduction in requests for additional information (RAIs) as a result of more transparent and clear guidance. There are other potential sources of reduced costs that are difficult to quantify and the extent to which they would apply to each licensee is uncertain. These are therefore considered qualitative benefits. The staff did not quantify any costs to licensees because of this ISG; however, revising and finalizing the ISG in response to comments is expected to result in estimated costs of $40,000 to the NRC.
Table ES-1 shows the net averted costs to licensees and the NRC. These averted costs are conservative and do not consider those from any potential rework that may be avoided (e.g.,
additional dose modeling or radiological surveys). Due to the difficulty of estimating licensee costs associated with rework, the staff only quantified averted costs associated with RAI responses. These averted costs are approximately $324,000 using a 7 percent discount rate.
Uncertainty Analysis. The staff conducted an uncertainty analysis that estimated averted costs to 1 DRPs, or hot particles, have historically been considered small, high activity particles less than 1mm in any dimension that are insoluble in water. These have historically been small pieces of activated metal from reactor internal fixtures released due to wear or spent fuel particles released from fuel rod failures. However, from a decommissioning perspective, particles could also include larger pieces of activated metal or concrete generated by segmentation efforts. DRPs are relatively small, high activity particles or objects (for example large concrete chips) that approximate a photon-emitting point source when surveying is conducted in open land areas. DRPs are generally insoluble in water and have characteristics and potential exposure scenarios that are inconsistent with diffuse residual radioactivity in soil or on structural surfaces.
vii industry and the NRC of $320,000 using a 7-percent discount rate, with a greater than 99%
confidence level that the ISG will be cost beneficial, effectively meaning that issuing the ISG is cost beneficial in all simulations.
Decision Rationale. Relative to the no-action baseline, the NRC concludes that issuing the ISG is acceptable when considering all costs and benefits because of the non-quantified benefits and the averted costs. The analysis quantifies the current staff practice to issue RAIs when the basis for the demonstration of compliance with the license termination rule criteria is unclear or not adequately supported.
Table ES-1 Net Costs and Benefits Costs Attribute Undiscounted 7% NPV 3% NPV Industry Costs
$0
$0
$0 NRC Costs
($50,000)
($40,000)
($40,000)
Total
($50,000)
($40,000)
($40,000)
Benefits Attribute Undiscounted 7% NPV 3% NPV Industry Benefits
$235,000
$174,000
$206,000 NRC Benefits
$250,000
$190,000
$220,000 Total
$485,000
$364,000
$426,000 Net Benefits (Costs)
Attribute Undiscounted 7% NPV 3% NPV Industry Net
$235,000
$174,000
$206,000 NRC Net
$200,000
$150,000
$180,000 Total Net
$435,000
$324,000
$386,000
- There may be differences between tables due to rounding
viii Abbreviations and Acronyms ADAMS Agencywide Documents Access and Management System DP Decommissioning Plan DRP Discrete Radioactive Particle BLS Bureau of Labor Statistics CFR Code of Federal Regulations CPI-U Historical Consumer Price Index for All Urban Consumers ISG interim staff guidance LTP License Termination Plan NPV net present value NRC U.S. Nuclear Regulatory Commission PERT program evaluation and review technique RAI request for additional information SRM Staff Requirements Memorandum
9 1.0 Introduction This document presents the regulatory analysis for the issuance of an ISG to supplement Revision 2 of NUREG-1757, Volume 2, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria.
2.0 Statement of the Problem and Objective
2.1 Background
Since 2002, the NRC has used NUREG-1757 to detail expected decommissioning actions and standards for licensees, as described below. Issuing this ISG to address an area in which NRC has little or no guidance on the recent NUREG revision continues that practice.
2.2 Statement of the Problem The NRC originally published NUREG-1757, Volume 2, in September 2003 to provide decommissioning guidance to licensees and the NRC staff (NUREG, 2003). Volume 2 of the NUREG specifically details dose modeling and radiological survey approaches associated with demonstrating compliance with the radiological criteria for license termination. The NRC issued Revision 1 to Volume 2 in 2006 (NRC, 2006). Between 2006 and 2022, lessons learned from decommissioning reviews and changes in technology provided the NRC with valuable experience and insights, which were captured in Revision 2 to NUREG-1757 published in July 2022. While significant improvements to the guidance document were made in Revision 2, NRC staff took additional time to address stakeholder comments on the need for additional detailed guidance in key technical areas. As a result, DUWP-ISG-02, Interim Staff Guidance (DUWP-ISG-02) on Radiological Survey and Dose Modeling of the Subsurface to Support License Termination was developed. However, DRP contamination in the environment was not addressed in that ISG. Staff identified the need to address this topic based on lessons learned from recent LTP review and the prolonged delays experienced in the final status survey and confirmation survey phases of decommissioning at several sites. Guidance was needed on DRP contamination in the environment covering the following areas:
methods to provide further support for risk-significant parameters, assessment of risk from DRP contamination, and lessons learned related to DRP surveys and dose modeling.
Considering these new findings and knowledge, the NRC staff determined that it was appropriate to update the NUREG using a phased approach. Given the complexity associated with DRP surveys, NRC staff developed this ISG, which will be issued for public comment and finalized prior to incorporation into the next revision of NUREG-1757, Volume 2. The ISG will better inform licensees on decommissioning best practices when DRP contamination in the environment is present, reducing the need for the staff to issue RAIs, and may reduce unplanned costs associated with rework and associated inspection costs. This analysis considers the rework and inspection averted costs qualitatively. Section 2.3 of this document discusses proposed changes to decommissioning guidance that address these and other issues.
2.3 Objective The objective of this regulatory action is to issue a draft ISG that will be finalized based on public
10 comments and then folded into the next revision of NUREG-1757, Volume 2. The ISG incorporates lessons learned and best practices related to environmental DRP contamination investigations from recent reviews of decommissioning plans, license termination plans, and final status surveys for reactor decommissioning sites where guidance was previously lacking. This ISG includes numerous changes to address issues discovered from this experience, including those identified in Section 2.2.
The NRC provides decommissioning guidance primarily to address contamination control, radiological surveys, and dose modeling regarding DRPs that were found in the environment due to an unplanned release or that potentially could be released to the environment during decommissioning. This ISG contains no substantive changes to the review criteria for diffuse contamination in the main chapters of NUREG-1757, NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Revision 2, issued April 2018 (ML18116A124), and NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Revision 1, issued August 2000 (ML003761445). This ISG provides new review criteria for DRPs in the form of guidance for licensees to consider when a licensee either has DRPs as a site characteristic (DRP contamination in the on-site environmental media) or chooses to conditionally address DRPs in its LTP or DP. Doing so may avoid the need to amend the LTP or DP which may delay license termination and will result in reduced RAIs to licensees.
The additional guidance is expected to lead to more efficient decommissioning (i.e., lead to fewer RAIs and reworks associated with inadequate methods). The following topics are included in the draft ISG:
DRP contamination control practices Applicability of as low as reasonably possibly (ALARA) to DRPs DRP Survey Objectives, Methods, Documentation and Approach to New Technologies Assessing Potential Exposure from DRPs Addressing DRPs in LTPs and DPs Example of Dose Assessment for Potential Exposure to Inform Decision about License Termination.
3.0 Identification and Preliminary Analysis of Alternative Approaches This section analyzes the two alternatives that the NRC considered related to ISG development:
(1) no-action (i.e., do not develop and issue ISG), or (2) develop and issue ISG to incorporate decommissioning lessons learned and best practices.
3.1 Alternative 1No-Action Under this alternative, the NRC would not develop and issue the ISG, and licensees undergoing decommissioning would be subject to a DRP case-by-case regulatory review. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed. This alternative would not leverage the additional lessons learned and best practices from decommissioning experience, and licensees would not benefit from the improvements and changes to the guidance that are discussed in the ISG.
3.2 Alternative 2Develop and Issue ISG Under this alternative, the NRC would develop and issue the ISG. This revision would incorporate lessons learned and best practices, resulting in the changes described in Section 2.
11 By doing so, the NRC would ensure that its decommissioning guidance relies upon the best available information and practices.
Based on this regulatory analysis, the NRC staff concludes that issuance of an ISG to support the next revision of NUREG-1757, Volume 2, is warranted because this alternative does the following:
results in averted costs to industry and the NRC, provides numerous qualitative benefits related to surveys and modeling, and incorporates lessons learned and best practices from industry and NRC experience with decommissioning.
Section 5 of this analysis discusses the costs and benefits of this alternative compared to the regulatory baseline (Alternative 1).
4.0 Estimation and Evaluation of Costs and Benefits This section describes the process for evaluating the costs and benefits expected to result from Alternative 2 relative to the regulatory baseline (Alternative 1). This regulatory analysis monetizes costs and benefits where meaningful quantification is possible.
4.1 Identification of Affected Attributes This section identifies the components of the public and private sectors, commonly referred to as attributes, that the staff expects the alternatives identified in Section 3 to affect. The alternatives would apply to licensees preparing for or undergoing decommissioning activities.
The NRC developed an inventory of the impacted attributes using the list provided in Section 5 of NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission. (NRC, 2020).
Revision of decommissioning guidance would affect the following attributes:
NRC Implementation. This attribute accounts for the projected net economic effect on the NRC due to completing the regulatory action. Responding to public comments and finalizing the ISG are implementation costs for the NRC.
Industry Operation. This attribute accounts for the projected net economic effect on new applications and applicants caused by routine and recurring activities required by the alternative. Fewer RAIs and fewer inspection activities are examples of averted industry operation costs that could result from this ISG.
NRC Operation. This attribute accounts for the projected net economic effect on the NRC after the guidance is implemented. If the NRC submits fewer RAIs and performs fewer inspection activities because of the ISG, that will result in a reduction in NRC operation costs.
Improvements in Knowledge. This attribute accounts for improvements in knowledge as industry and the NRC staff gain experience with surveys and modeling as a result of issuing the ISG.
Regulatory Efficiency. This attribute accounts for regulatory and compliance
12 improvements resulting from the issuance of the ISG. Issuing the ISG would constitute a best practice by improving NRC regulations with lessons learned and best practices, and providing licensees undergoing decommissioning with regulatory certainty through a path for compliance that is more flexible and predictable.
Other Considerations. This attribute accounts for considerations not captured in the preceding attributes. Specifically, it accounts for how issuing the ISG would improve public confidence.
Attributes with No Effects. Attributes not expected to be affected under either alternative, include industry implementation, considerations of public health (accident and routine),
occupational health (accident and routine), offsite property, on-site property, other governments, the public, safeguards and security, and the environment.
4.2 Analytical Methodology This section describes the process used to evaluate costs and benefits associated with the alternatives. The benefits include any desirable changes in affected attributes (e.g., monetary savings and improved safety and security). The costs include any undesirable changes in affected attributes (e.g., monetary costs and increased exposures).
The analysis evaluates NRC implementation, industry operation, and NRC operation on a quantitative basis. It evaluates the remaining three of the five affected attributes on a qualitative basis because those benefits are not quantifiable or because the data necessary to quantify and monetize the impacts on these attributes are not available. The staff documents its assumptions throughout this regulatory analysis.
4.2.1 Regulatory Baseline This regulatory analysis identifies the incremental impacts of Alternative 2 compared to a baseline that reflects anticipated behavior if the NRC does not undertake regulatory or nonregulatory action. The regulatory baseline assumes full compliance with existing NRC requirements, including current regulations and relevant orders. This is consistent with NUREG/BR-0058, which states that in evaluating a new requirement the staff should assume that all existing NRC and Agreement State requirements have been implemented.
Section 5 of this regulatory analysis presents the estimated incremental costs and benefits of Alternative 2 compared to this baseline.
4.2.2 Affected Entities The ISG is applicable to all licensees subject to 10 CFR Part 20, Subpart E. Most of the complex sites that would benefit from this ISG are operating reactors. This ISG will affect 94 operating reactors that will eventually be undergoing decommissioning. Several licensees are in the process of submitting or have submitted a LTP for review. Currently, there are 24 nuclear power and early demonstration reactors that are either in active decommissioning (15) or in SAFSTOR (9), 2 research and test reactors, and four complex materials facilities (30 entities in total) that are undergoing decommissioning or are in long-term safe storage.
This regulatory analysis used these entities, including the related RAIs that the NRC has issued each year specific to DPR issues, as the basis for the quantitative calculations. Beyond these
13 known entities, it is difficult to speculate about specific other entities that may enter decommissioning in the future; therefore, this analysis uses only the aforementioned entities in quantified cost and benefit calculations. In addition, based on recent reviews involving DRP contamination in the environment, staff conducted headquarters audits (approximately 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />) during the final status survey. Additionally, an extensive NRC confirmatory survey that covered more than the typical survey due to DRP contamination was performed, costing the licensee approximately $200K per facility at the end of decommissioning. The staff believes this type of additional work during final status surveys and before license termination likely may be needed if this ISG is not issued; however, the analysis treats these additional averted costs qualitatively.
4.2.3 Base Year The NRC assumes that the ISG will be effective in 2025, and the base year of the analysis is 2023 to match the Bureau of Labor Statistics (BLS) data used. The staff assumes that the ongoing costs of operation related to the alternative being analyzed begin no earlier than 30 days after issuing the ISG, unless otherwise stated, and models these costs on a per-applicant basis. One-time NRC implementation costs related to the draft ISG development are considered sunk costs at this stage, but the finalization and issuance of the ISG are included as costs to the NRC.
4.2.4 Sign Conventions The sign conventions used in this analysis are that all favorable consequences for the alternative are positive and all adverse consequences for the alternative are negative. Negative values are shown using parentheses (e.g., negative $500 is displayed as ($500)).
4.2.5 Analysis Horizon The final ISG will remain in effect until the staff incorporates it into the next revision of NUREG-1757, Volume 2. This analysis assumes that all licensees will use the final ISG supplementing NUREG-1757, Volume 2, Rev. 2, after publication. The quantitative estimates in this analysis run through 2030, after which the number of sites entering decommissioning becomes too uncertain. Furthermore, the NRC may issue another revision to the NUREG in or soon after 2030; therefore, the staff chose to end quantitative estimates in that year.
4.3 Data Analysts obtained qualitative (i.e., non-quantified) information on attributes affected by the alternatives from the staff and from public comments on the prior NUREG revision. The NRC considered the potential differences between the new guidance and the current guidance and incorporated the incremental changes into this regulatory analysis. Subject matter experts provided information on current quantities and level of effort estimates for RAIs. The labor rate for the NRC is based on a calculation the NRC performs annually, and the labor rate for industry is a blended labor rate from the most recent data from the BLS (BLS, 2023). This regulatory analysis shows the data inputs.
5.0 Results This section presents the qualitative and quantitative results by attribute for Alternative 2, relative to the regulatory baseline (Alternative 1). As described in the previous sections, costs and
14 benefits are quantified when possible and are shown to be either positive or negative, depending on whether the alternative has a favorable or adverse effect compared to the regulatory baseline.
Those attributes that are not presented with monetary values are discussed in qualitative terms.
5.1 NRC Implementation This attribute accounts for the projected net economic effect on the NRC issuing the ISG. The staff estimates that responding to public comments on the draft ISG, and revising and issuing the final ISG, would take approximately 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. This results in estimated costs to the NRC ranging from ($40,000) using a 7 percent NPV to ($43,000) using a 3 percent NPV, as shown in Table 1.
Table 1 NRC Implementation Costs Benefits (Costs)
Year Activity Number of Actions Hours Weighted Hourly Rate Undiscounted 7% NPV 3% NPV 2025 Finalize and Issue ISG 1
300
$152
($46,000)
($40,000)
($43,000)
Total:
($46,000)
($40,000)
($43,000) 5.2 Industry Operation This attribute accounts for the projected net economic effect of routine and recurring activities resulting from the issuance of the ISG. The additional clarity in the ISG may obviate the need to generate RAIs on various decommissioning activities and reports. Additionally, decreased NRC inspection activity to verify the adequacy of licensee decommissioning activities may result.
Examples of areas where the staff update current guidance to include alternative methods that might reduce costs or to increase transparency on acceptable methods to demonstrate compliance with release criteria are detailed in Section 2.
The NRC estimates the averted costs of licensees no longer submitting as many decommissioning RAIs will range from $174,000 (using a 7-percent net present value [NPV]
[discount rate]) to $207,000 (using a 3-percent NPV). Table 2 shows this estimate using a mean hourly labor rate for industry of $143 (based on BLS data) and a mean hourly estimate of 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> to respond to RAIs. This is a conservative estimate, because increased transparency in guidance may also obviate the need for costly rework and additional inspections, and those averted costs are considered qualitatively due to their uncertainty. As discussed in Section 4.2.5, the staff considered data beyond 2030 too uncertain and ended the quantitative estimate in that year. The staff considered the current number of annual RAIs related to Volume 2 of NUREG-1757 and assumed that on average the issuance of the ISG would avert 11 RAIs annually.
Table 2 Industry Averted Costs from a Reduction in RAIs Cost Year Activity Averted RAIs per Year Average Labor Hours per Request Weighted Hourly Rate Undiscounted 7% NPV 3% NPV 2025 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$34,000
$37,000 2026 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$32,000
$36,000 2027 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$30,000
$35,000 2028 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$28,000
$34,000
15 2029 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$26,000
$33,000 2030 Responding to a Reduced Number of RAIs from the NRC 11 26
$143
$39,000
$24,000
$32,000 Total:
$234,000
$174,000
$207,000 5.3 NRC Operation Many of the benefits to licensees discussed in Section 5.2 in terms of industry operation could also result in benefits for the NRCs review activities. The NRC is expected to experience incremental averted costs due to a reduction in RAIs and inspection actions due to the additional clarity in the ISG. The staff estimates the averted costs to the NRC will range from
$186,000 (using a 7-percent NPV) to $219,000 (using a 3-percent NPV), at an NRC labor rate of $152 per hour and 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> for generating and reviewing responses to the RAIs. Table 3 shows this calculation. Inspection actions associated with these RAIs were not quantified yet should be considered qualitatively as an additional averted cost.
Table 3 NRC Averted Costs from a Reduction in RAIs Benefits (Costs)
Year Activity Requests Reviewed per Year Average NRC Staff Hours per Request Weighted Hourly Rate Undiscounted 7% NPV 3% NPV 2025 Reduced Number of RAIs Generated 11 26
$152
$42,000
$36,000
$39,000 2026 Reduced Number of RAIs Generated 11 26
$152
$42,000
$34,000
$38,000 2027 Reduced Number of RAIs Generated 11 26
$152
$42,000
$32,000
$37,000 2028 Reduced Number of RAIs Generated 11 26
$152
$42,000
$30,000
$36,000 2029 Reduced Number of RAIs Generated 11 26
$152
$42,000
$28,000
$35,000 2030 Reduced Number of RAIs Generated 11 26
$152
$42,000
$26,000
$34,000 Total:
$252,000
$186,000
$219,000 5.4 Total Costs The staff estimates averted costs to industry and the NRC ranging from $320,000 (using a 7-percent NPV) to $390,000 (using a 3-percent NPV).
Table 4 Total Averted Costs (Industry and the NRC) for Alternative 2 Net Benefits (Costs)
Attribute Undiscounted 7% NPV 3% NPV Industry Implementation
$0
$0
$0 Industry Operation
$230,000
$170,000
$210,000 Net Industry Cost
$230,000
$170,000
$210,000 NRC Implementation
($50,000)
($40,000)
($40,000)
NRC Operation
$250,000
$190,000
$220,000 Net NRC Cost
$200,000
$150,000
$180,000 Net Cost:
$430,000
$320,000
$390,000
- There may be differences between tables due to rounding 5.5 Improvements in Knowledge Compared to the regulatory baseline (Alternative 1), Alternative 2 would improve guidance based on lessons learned and best practices from recent decommissioning experience. The updates reflect improvements in science, with additional flexibility in several areas related to
16 dose modeling to derive cleanup levels and radiological survey approaches.
5.6 Regulatory Efficiency By incorporating lessons learned and best practices from recent decommissioning experience, the ISG is expected to improve regulatory efficiency. As a result, licensees undergoing decommissioning activities will better understand the NRCs expectations and should experience greater efficiencies from a resultant decrease in RAIs from the NRC. This leads to a qualitative benefit in addition to the quantitative benefit evaluated in Section 5.1.
5.7 Other ConsiderationsIncreased Public Confidence Public confidence will increase because of the NRC being responsive to stakeholder comments and using lessons learned and best practices to improve the effectiveness and efficiency of licensee review actions, as detailed above. Issuing this ISG will reassure the public that the NRC continues to improve and transform into a modern, risk-informed regulator.
5.8 Uncertainty Analysis The NRC conducted an uncertainty analysis based on the costs and averted costs of Alternative 2, using a Monte Carlo analysis. The uncertainty analysis showed that the alternative has a greater than 99-percent chance of resulting in averted costs to industry and the NRC, with a mean estimate of $320,000 using a 7-percent NPV. The inputs for the uncertainty analysis are shown below. This mean may differ from the previous totals due to the simulation and rounding in the model.
Figure 1 Total costs (industry and the NRC) for Alternative 27-percent NPV 100.0%
0.000
+
0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 Values in Millions Total Cost 7% NPV Minimum 40,406 Maximum 1,230,953 Mean 319,887 Std Dev 147,863 5%
117,804 95%
593,567
17 5.9 Summary This regulatory analysis identifies both quantifiable and nonquantifiable costs and benefits that would result from the issuance of the ISG supplementing NUREG-1757, Volume 2, Revision 2.
5.9.1 Quantified Net Cost The staff estimates a quantified averted cost of $320,000 (using a 7-percent NPV) to both the NRC and industry as a result of issuing the ISG.
5.9.2 Non-quantified Benefits The ISG would produce a number of non-quantified benefits for industry and the NRC under the attributes of improvements in knowledge, regulatory efficiency, and other considerations (increased public confidence). Sections 5.5, 5.6, and 5.7 detail these benefits.
5.9.3 Safety Goal Evaluation The NRCs safety goal evaluation applies only to regulatory initiatives considered to be generic safety enhancement backfits subject to the substantial additional protection standard at Title 10 of the Code of Federal Regulations (10 CFR) 50.109(a)(3). The NRC does not regard the issuance of this ISG to be backfitting or to represent an inconsistency with any issue finality provisions in 10 CFR Part 52, Licensees, Certifications, and Approvals for Nuclear Power Plants. Based on the reasons described, a safety goal evaluation is not appropriate for this regulatory analysis.
6.0 Decision Rationale Table 5 provides the quantified and qualified costs and benefits for Alternative 2. The quantitative analysis used best estimate values.
18 Table 5 Summary of Totals Net Monetary Savings or (Costs)
Total Present Value Non-quantified Benefits or (Costs)
Alternative 1: No-Action
$0 None Alternative 2: Issue ISG supplementing NUREG-1757, Volume 2, Revision 2 Industry:
$170,000 using a 7% discount rate
$210,000 using a 3% discount rate NRC:
$150,000 using a 7% discount rate
$180,000 using a 3% discount rate Net Benefit (Cost):
$320,000 using a 7% discount rate
$390,000 using a 3% discount rate Benefits:
Improvements in Knowledge: Alternative 2 would improve guidance by providing additional information based on lessons learned and best practices from recent decommissioning experience. The updates also reflect improvements methods for DRPs used to perform radiological surveys and dose modeling.
Regulatory Efficiency: By incorporating lessons learned and best practices from recent decommissioning experience, the updated guidance is expected to improve regulatory efficiency. As a result of this updated guidance, licensees undergoing decommissioning activities will better understand the NRCs expectations and should experience greater efficiencies from a resultant decrease in RAIs from the NRC.
Net Monetary Savings or (Costs)
Total Present Value Non-quantified Benefits or (Costs)
This leads to a qualitative benefit in addition to the quantitative benefit evaluated in Section 5.1.
Increased Public Confidence: Public confidence will increase as a result of the NRC using lessons learned and best practices gained from experience with the review of complex material and reactor decommissioning to improve the effectiveness and efficiency of licensee review actions, as detailed above. Issuing this ISG will reassure the public that the NRC continues to improve and transform into a modern, risk-informed regulator.
Issuing the ISG to supplement guidance in Revision 2 of NUREG-1757, Volume 2, (Alternative
- 2) will avert costs due to fewer RAIs and inspection actions, affecting both licensees and the NRC. Industry and the NRC are expected to have net averted costs of approximately $320,000 (7-percent NPV) from Alternative 2. Alternative 2 would also have the qualitative benefits of an
19 improvement in knowledge, regulatory efficiency, and public confidence.
Considering quantified and non-quantified costs and benefits, the regulatory analysis shows that issuing the ISG is cost justified and supports the issuance the ISG.
7.0 Implementation Schedule The draft ISG will be available for use upon publication, as announced in the Federal Register.
However, the draft ISG is being published for comment, and the NRC staff may make revisions and corrections based on those comments in the final ISG. The final ISG, which is expected to be published in mid-2025, will be effective upon publication and will also be announced in the Federal Register.
20 8.0 References Bureau of Labor Statistics (BLS), 2023. Occupational Employment and Wage Statistics, U.S. Department of Labor, May 2023. Available at https://www.bls.gov/oes/tables.htm; last accessed on May 12, 2024.
U.S. Nuclear Regulatory Commission (NRC), 2000. NUREG-1575. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Revision 1, issued August 2000 (ML003761445).
NRC, 2003. NUREG-1757, Volume 2, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria, September 2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14093A221).
NRC, 2006. NUREG-1757, Volume 2, Revision 1, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria, September 2006 (ADAMS Accession No. ML14093A221).
NRC 2018. NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Revision 2, issued April 2018 (ML18116A124).
NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission.
NRC, 2022. NUREG-1757, Volume 2, Revision 2, Consolidated Decommissioning Guidance:
Characterization, Survey, and Determination of Radiological Criteria, July 2022 (ADAMS Accession No. ML22194A859).