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NUREG-1700, Revision 2, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans.
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Issue date:	04/30/2018
From:	Stephen Giebel, Bruce Watson; Office of Nuclear Material Safety and Safeguards
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	Meyd, Donald
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NUREG-1700 Revision 2 Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans Office of Nuclear Material Safety and Safeguards

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NUREG-1700 Revision 2 Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans Manuscript Completed: July 2016 Date Published: April 2018 Prepared by:

S. Giebel B. Watson Stephen Giebel, NRC Project Manager Office of Nuclear Material Safety and Safeguards

ABSTRACT This standard review plan (SRP) guides the staff of the U.S. Nuclear Regulatory Commission (NRC) in conducting safety reviews of license termination plans (LTPs). The principal purpose of this SRP is to ensure the quality and uniformity of NRC staff reviews and to present a well-defined base from which to evaluate the requirements for terminating the license of a nuclear power plant. It is also the purpose of this SRP to make information about regulatory matters widely available, so that interested members of the public and the nuclear industry can gain a better understanding of the NRC staffs review process. Specific guidance for licensees is included in Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors.

Licensees may also use this SRP to assist in developing an LTP. The SRP presents the acceptance criteria for all areas of review for license termination, and identifies the matters to be reviewed, the basis for the review, and the conclusions that are sought. For example, NUREG-1757, Consolidated Decommissioning Guidance offers additional guidance on how to demonstrate compliance with the unrestricted release, restricted release, and alternative criteria for license termination, in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 20, Standards for Protection against Radiation, Subpart E, Radiological Criteria for License Termination. To avoid duplication of information, this SRP references applicable sections of NUREG-1757 for additional guidance. In addition, the NRC has issued supplemental guidance that will subsequently be consolidated into NUREG-1757 to address partial site release before LTP approval, and compliance with 10 CFR Part 20, Subpart E. It should be noted that the memorandum of understanding (MOU) between the Environmental Protection Agency and NRC may contain consultation triggers for some radionuclides that may be lower than the NUREG-1757 Vol. 2 Revision 1, Appendix H screening values.

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TABLE OF CONTENTS ABSTRACT ............................................................................................................................... iii ABBREVIATIONS AND ACRONYMS ...................................................................................... vii 1 INTRODUCTION .................................................................................................................1-1 1.1 Purpose ........................................................................................................................1-1 1.2 Regulations and Related Guidance ..............................................................................1-2 1.3 LTP Applicable Requirements ......................................................................................1-3 1.4 Organization of this SRP ..............................................................................................1-3 2 LTP STANDARD REVIEW PLAN AND ACCEPTANCE CRITERIA ...................................2-1 2.1 General Information ......................................................................................................2-1 2.1.1 Acceptance Criteria .............................................................................................2-1 2.2 Site Characterization ....................................................................................................2-2 2.2.1 Acceptance Criteria ............................................................................................2-2 2.3 Identification of Remaining Site Dismantlement Activities .............................................2-3 2.3.1 Acceptance Criteria ............................................................................................2-3 2.4 Remediation Plans .......................................................................................................2-3 2.4.1 Acceptance Criteria ............................................................................................2-3 2.5 Final Radiation Survey Plan .........................................................................................2-4 2.5.1 Acceptance Criteria ............................................................................................2-4 2.6 Compliance with the Radiological Criteria for License Termination ...............................2-5 2.7 Update of the Site Specific Decommissioning Costs.....................................................2-6 2.7.1 Acceptance Criteria ............................................................................................2-7 2.8 Supplement to the ER ..................................................................................................2-7 2.8.1 Acceptance Criteria ............................................................................................2-8 3 EVALUATION FINDINGS ...................................................................................................3-1 4 REFERENCES ....................................................................................................................4-1 APPENDIX A ACCEPTANCE REVIEW CHECKLIST FOR UNRESTRICTED OR RESTRICTED RELEASE OF THE SITE ..................................................... A-1 APPENDIX B LTP AREAS THAT CANNOT BE CHANGED WITHOUT NRC APPROVAL ................................................................................................ B-1 v

ABBREVIATIONS AND ACRONYMS ALARA as low as is reasonably achievable CFR Code of Federal Regulations DCGL derived concentration guideline level DG draft regulatory guide EA environmental assessment EIS environmental impact statement ER environmental report FONSI finding of no significant impact FR Federal Register FSAR final safety analysis report ISFSI independent spent fuel storage installation LTP license termination plan MOU memorandum of understanding NEPA National Environmental Policy Act NMSS Office of Nuclear Material Safety and Safeguards (NRC)

NRC U.S. Nuclear Regulatory Commission PSDAR post-shutdown decommissioning activities report QA quality assurance RAI requests for additional information ROC radionuclide of concern RG regulatory guide SE safety evaluation SOC statement of considerations SRP standard review plan vii

1 INTRODUCTION 1.1 Purpose This standard review plan (SRP) is intended to guide the staff of the U.S. Nuclear Regulatory Commission (NRC) in conducting safety reviews of license termination plans (LTPs) for nuclear power reactors. The principal purpose of this SRP is to ensure the quality and uniformity of NRC staff reviews and to present a well-defined base from which to evaluate the requirements for approving an LTP. It is also the purpose of this SRP to make information about regulatory matters widely available, so that interested members of the public and the nuclear industry can gain a better understanding of the NRC staffs review process. Licensees may also use this SRP to assist in developing an LTP. SRPs are not substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in this SRP will be acceptable if they provide a basis for concluding that the LTP is in compliance with the Commissions regulations.

In general, the NRC staff bases its license termination review primarily on the information that the applicant submits. Consequently, the LTP should contain sufficient detail to enable the NRC staff to independently verify (a) the adequacy of the licensees decommissioning funding plan to assure that sufficient funding is available to complete the remaining radiological remediation activities; (b) the radiation-release criteria for license termination; and (c) the adequacy of the design of the final survey to verify that the release criteria have been met. The specific information that the NRC staff needs to evaluate an LTP is identified in Regulatory Guide (RG) 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors (Ref. 1). Because the LTP must be submitted 2 years or more before license termination, the level of detail required in the LTP will vary depending on when the LTP is submitted.

To implement NRCs approach for licensing actions, when a licensee submits an LTP to the NRC for review and approval, the NRC staff will use this SRP to evaluate the information submitted by a licensee to support evaluation of the LTP. The NRC staffs evaluation will include: (1) acceptance reviews, (2) detailed safety reviews, (3) requests for additional information (RAIs) if needed, and (4) environmental report (ER) reviews. In addition to the safety reviews, NRC staff will also conduct an environmental review of the LTP in accordance with the National Environmental Policy Act (NEPA). The environmental review will consider NUREG-0586, Final Generic Environmental impact Statement on Decommissioning of Nuclear Facilities (EIS), and any site-specific EIS.

The NRC staff will determine if the application is complete by conducting an acceptance review, and if it is not, return it to the licensee. The LTP may include NRC screening values for the identified Radionuclides of Concern (ROCs). Appendix 1, Acceptance Review Checklist for Unrestricted or Restricted Release of the Site provides a checklist of information that needs to be addressed in the LTP, and is used by the NRC staff to determine if the licensee has included all the information required in the LTP. The information identified in the checklist will vary depending upon the amount of decommissioning that has been completed at the time the LTP is submitted. If the application is complete, NRC staff will then conduct a detailed review, and prepare its preliminary technical evaluation. Through this process, NRC staff will be able to identify areas where issues need to be addressed. This approach will help ensure that questions are limited to those areas where additional information is needed, and should help reduce the number of questions.

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1.2 Regulations and Related Guidance On July 29, 1996, the Commission published a Federal Register notice of a final rule amending its regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 2, Agency Rules of Practice and Procedure; Part 50, Domestic Licensing of Production and Utilization Facilities; and Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions (61 FR 39278) (Ref. 2). This ruleby eliminating, revising, or extending operating reactor requirements to be commensurate with the necessary level of safety during decommissioningspecifies requirements for reactors that present a significantly reduced risk to the public because they are permanently shut down and no longer have fuel in the reactor vessel.

Decommissioning activities for power reactors may be divided into three phases: (1) initial activities, (2) major decommissioning and storage activities, and (3) license termination activities. Regulatory Guide 1.184, Decommissioning of Nuclear Power Reactors (Ref. 3) describes acceptable methods and procedures for implementing the rules that relate to Phases 1 and 2.

For Phase 3, 10 CFR 50.82(a)(9) specifies that an application for license termination must be accompanied or preceded by an LTP, which is subject to NRC review and approval. According to 10 CFR 50.82(a)(9), the licensee must submit an LTP at least 2 years before termination of the license, and the NRC must hold a public meeting near the site.

In accordance with 10 CFR 50.82(a)(10), the LTP is approved by license amendment.

Recognizing that there may be a need to make changes to the LTP following its approval by the NRC, the licensee should include a provision in the LTP that concerns such changes. Appendix 2, LTP Areas That Cannot Be Changed Without NRC Approval, sets out such a provision that the NRC finds acceptable.

On July 21, 1997, the Commission amended its regulations under 10 CFR Parts 20, Standards for Protection against Radiation, Part 30, Rules of General Applicability to Domestic Licensing of Byproduct Material; Part 40, Domestic Licensing of Source Material; Part 50; Part 51; Part 70, Domestic Licensing of Special Nuclear Material; and Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste (62 FR 39058) (Ref. 4), prescribing specific radiological criteria for license termination. The license termination rule (i.e., 10 CFR Part 20, Subpart E, Radiological Criteria for License Termination) requires the licensee to evaluate the entire site for compliance with Subpart E at the time of license termination. To ensure that the entire site meets the radiological release requirements of 10 CFR Part 20, Subpart E, at the time the license is terminated, and to avoid licensees taking a piecemeal approach to license termination, the LTP should consider the entire site as defined in the original license or final safety analysis report (FSAR), along with any subsequent additions to the site boundary. In addition, licensees should be aware of the specific recordkeeping requirements in 10 CFR 50.75, Reporting and Recordkeeping for Decommissioning Planning when planning a partial release before license termination to ensure that the dose contribution will not impair future partial release plans or the final release at license termination.

To avoid duplication of information, this SRP references applicable sections of NUREG-1757, Consolidated NMSS Decommissioning Guidance (Ref. 6), which offer additional guidance on how to demonstrate compliance with the unrestricted release, restricted release, and alternative criteria for license termination in accordance with Subpart E of 10 CFR Part 20.

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1.3 LTP Applicable Requirements As discussed in the statements of considerations (SOC) that accompanied the 1996 Final Rule on Decommissioning of Nuclear Power Reactors, the Commission must make decisions regarding the licensee-proposed actions described in the LTP. In particular, the Commission must evaluate: (1) the licensees plan for ensuring that sufficient funds will be available to complete the remaining radiological remediation activities (2) the radiation release criteria for license termination, and (3) the adequacy of the design of the final survey to verify that the release criteria have been met. In addition, the NRC staff must prepare an environmental assessment, and if necessary an EIS or a mitigated FONSI if theres a significant impact beyond those identified in NUREG-0586, Supplement 1, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (2002) (Ref. 12) or if there is a significant impact that has not otherwise been previously reviewed (e.g., in a previous site-specific EIS).

To support the Commissions findings, the LTP must contain a dose assessment, a final survey plan, an updated site specific decommissioning cost estimate, and a supplement to the ER.

The information submitted in the LTP should reflect the current status of the decommissioning at the facility. The regulations in 10 CFR 50.82(a)(9)(ii) require that the LTP must include the following information:

site characterization

identification of the remaining dismantlement activities

plans for site remediation

detailed plans for the final radiation survey

description of the end use of the site, if restricted

an updated site-specific estimate of remaining decommissioning costs

a supplement to the ER describing any new information or significant environmental change associated with the licensees proposed termination activities

identification of parts, if any, of the facility or site that were released for use before approval of the license termination The LTP must be submitted as a supplement to the licensees FSAR or as an equivalent document. A licensee may submit the LTP concurrently with the post-shutdown decommissioning activities report (PSDAR).

Guidance on the content of the PSDAR can be found in Regulatory Guide 1.185, Standard Format and Content Guide for Post-Shutdown Decommissioning Activities Report (Ref. 7).

Currently, the Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP) of the Office of Nuclear Material Safety and Safeguards (NMSS) is responsible for reviewing the LTP.

1.4 Organization of this SRP The SRP is written to cover a variety of license termination conditions. Each section of the SRP presents the acceptance criteria for all areas of review for license termination. It identifies the matters to be reviewed, the basis for the review, and how the staff will formulate its conclusions.

For an LTP application, the NRC staff reviewers will select appropriate aspects of each section based on the status of the decommissioning. In some cases, a facility feature may be sufficiently similar to a previously reviewed feature so that a complete new review is not needed.

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The remainder of this SRP is divided into the three sections including: LTP Standard Review Plan and Acceptance Criteria, Evaluation Findings, and References.

LTP Standard Review Plan and Acceptance Criteria Each subsection in Section B, LTP Standard Review Plan and Acceptance Criteria, summarizes the purpose of the review and the applicable NRC requirements. The initial summary is not designated Area of Review, as described in detail in RG 1.179 (Ref. 1) because the Area of Review and Acceptance Criteria sections are combined into one section.

Each subsection includes applicable acceptance criteria, which contain the technical bases for assessing the acceptability of the analysis or program. The technical bases include references such as NRC regulatory guides, industry codes and standards, and branch technical positions.

These approaches are listed in the SRP so the NRC staff can take consistent positions on similar problems as they arise. Branch Technical Positions and Regulatory Guides present approaches that are acceptable to the NRC staff for demonstrating compliance with the NRC regulatory requirements, but are not considered to be the only possible approaches. However, licensees proposing approaches other than those described in the Branch Technical Positions or Regulatory Guides may expect longer review times and the NRC staff may need additional justification/analysis before approving the proposed approach.

Evaluation Findings This section presents the findings in each particular review area that the NRC must make in its review of the LTP. For each area of review, the safety evaluation (SE) will include a description of the review, including aspects of the review that were selected or emphasized, and the bases for any deviation from the SRP.

References The section presents the references used as part of the supporting basis for the technical conclusion reached.

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2 LTP STANDARD REVIEW PLAN AND ACCEPTANCE CRITERIA 2.1 General Information The LTP must address each of the areas delineated in 10 CFR 50.82(a)(9) as well as Subpart E of 10 CFR Part 20. The regulations applicable to this review are 10 CFR 50.82(a)(9),

10 CFR 50.82(a)(10), and Subpart E of 10 CFR Part 20.

2.1.1 Acceptance Criteria

The LTP is submitted in the form of a supplement to the FSAR or equivalent and the LTP has preceded or is accompanied by an application for license termination.

The LTP is submitted 2 years or more before the proposed termination date of the license.

The LTP is submitted in the form of a license amendment request.

The LTP lists the name and address of the licensee; license number; docket number; facility name and address; size of the site in acres or square meters; the State and county in which the site is located; the names of and distances to nearby communities, towns, and cities; a description of the contours and features of the site; the elevation of the site; a description of property surrounding the site, including the location of all off-site wells used by nearby communities or individuals; the location of the site relative to prominent features such as rivers and lakes; a map that shows the detailed topography of the site using a contour interval; the location of the nearest residences and all significant facilities or activities near the site; and a description of the facilities (buildings, parking lots, fixed equipment, etc.) at the site.

The LTP identifies all changes to the site boundaries (as defined in 10 CFR 20.1003, Definitions) that have occurred. 10 CFR 50.75(g) requires licensees to keep records that document any changes to the original site boundary such as any partial site release.

The LTP addresses each of the following 10 CFR 50.82(a)(9) areas as well as the radiological criteria for unrestricted or restricted release of the site as defined in Subpart E of 10 CFR Part 20:

- site characterization

- identification of remaining site dismantlement activities

- plans for site remediation

- detailed plans for final radiation surveys for release of the site

- method for demonstrating compliance with the radiological criteria for license termination. For restricted release, the LTP should also describe the sites end use, and provide documentation demonstrating compliance with the public consultation, institutional controls, and financial assurance requirements of 2-1

10 CFR 20.1403, Criteria for License Termination under Restricted Conditions, or 10 CFR 20.1404, Alternate Criteria for License Termination.

- updated site-specific estimate of remaining decommissioning costs

- supplement to the ER, under 10 CFR 51.53(d), which describes any new information or significant environmental changes associated with the licensees proposed termination activities

- identification of parts, if any, of the facility that were released for use before approval of the license termination plan under 10 CFR 50.82(a)(9)(ii)(H) 2.2 Site Characterization Site characterization information is provided to determine the extent and range of radioactive contamination on site, including structures (on a structure by structure basis and as necessary on a room by room basis), systems, components, residues, soils, and surface and ground water. On the basis of the site characterization, the licensee designs final radiation surveys to evaluate all areas in which contamination previously existed, remains, or has the potential to remain.

The licensee should also use the site characterization information to develop input for use in the dose modeling such as ROCs. As part of the review, the NRC staff should review the licensees site characterization plans and site records (required under 10 CFR 50.75(g)). The purpose of this review is twofold. First, the NRC staff seeks to ensure that the site characterization presented in the LTP is complete. Second, the NRC staff verifies that the licensee obtained the data using sufficiently sensitive instruments and proper quality assurance procedures to obtain reliable data that are relevant to determining whether the site will meet the decommissioning limits if characterization data is used as final survey data. The regulation applicable to this area of review is 10 CFR 50.82(a)(9)(ii)(A).

Additional guidance on site characterization and characterization surveys can be found in Section 4 of NUREG-1757, Volume 2 (Ref. 6). In addition, if the licensee proposes site-specific derived concentration guidelines (DCGLs), the hydrogeologic information described in NUREG-1757 will likely be required to support the parameters used in the site-specific dose assessment.

2.2.1 Acceptance Criteria

The LTP identifies all locations, both inside and outside the facility, where radiological spills, disposals, operational activities, or other radiological accidents and or incidents occurred and could have resulted in contamination. This identification should be done on a room-by-room or area-by-area basis as necessary, including equipment, laydown areas, or soils (subfloor and outside area).

The LTP describes, in summary form, the original shutdown, and current radiological and non-radiological status of the site.

The LTP site characterization is sufficiently detailed to allow the NRC staff to determine the extent and range of radiological contamination of structures, systems (including sewer systems and waste management systems), floor drains, ventilation ducts, piping 2-2

and embedded piping, rubble, ground water and surface water, components, residues, and environment, including maximum and average contamination levels and ambient exposure rate measurements of all relevant areas (structures, equipment, and soils) of the site (including contamination on and beneath paved parking lots).

The LTP identifies the survey instruments and supporting quality assurance practices used in the site characterization program.

The LTP identifies the background levels used during scoping or characterization surveys.

The LTP describes in detail the areas and equipment that need further remediation to allow the reviewer to estimate the radiological conditions that will be encountered during remediation of equipment, components, structures, and outdoor areas.

2.3 Identification of Remaining Site Dismantlement Activities The LTP describes the remaining site dismantlement activities. The regulation applicable to this area of review is 10 CFR 50.82(a)(9)(ii)(B).

2.3.1 Acceptance Criteria

The LTP discusses the remaining tasks associated with decontamination and dismantlement, estimates the quantity of radioactive material to be shipped for disposal or processing, describes the proposed control mechanisms to ensure that areas are not re-contaminated, and contains occupational exposure estimates and radioactive waste characterization.

The LTP describes the remaining dismantlement activities in sufficient detail for the NRC staff to identify any associated inspection or technical resources that will be needed.

The LTP is sufficiently detailed to provide data for use in planning further decommissioning activities. As such, the LTP includes decontamination techniques, projected schedules, costs, waste volumes, dose assessments (including groundwater assessments), and health and safety considerations.

The LTP lists the remaining activities that do not require any additional licensing action.

2.4 Remediation Plans The LTP discusses in detail how facility and site areas will be remediated to meet the NRCs release criteria. The regulations applicable to this area of review are 10 CFR 50.82(a)(9)(ii)(C) and Subpart E of 10 CFR Part 20 (Ref. 3).

Additional guidance on this topic can be found in Section 4 of NUREG-1757, Vol. 2 (Ref. 6).

2.4.1 Acceptance Criteria

The LTP addresses any changes in the radiological controls to be implemented to control radiological contamination associated with the remaining decommissioning and remediation activities.

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The LTP discusses in detail how facility and site areas will be remediated to meet the proposed residual radioactivity levels (DCGLs) for license termination. Discussions should focus on any unique techniques or procedures used to evaluate whether the DCGLs have been met including the following:

- summarize the techniques that will be used to remediate building structures and components (e.g., scabbling, hydrolazing, grit blasting, etc.).

- summarize the equipment that will be decontaminated and how the decontamination will be accomplished.

- summarize the radiation protection methods and control procedures that will be employed including a summary of the procedures already authorized under the existing license.

- commit to conduct decommissioning activities in accordance with approved written procedures.

- include a detailed description of the techniques that will be employed to remove or remediate surface and subsurface soils, groundwater, and surface water and sediments.

- describe plans, if any, for onsite disposal of decommissioning waste.

The LTP includes a schedule that demonstrates how and in what time frames the licensee will complete the interrelated decommissioning activities. The regulation in 10 CFR 50.82(a)(3) requires completion of decommissioning within 60 years of permanent cessation of operations.

If the completion of decommissioning is delayed beyond the 60 year deadline, the LTP can contain a description of the exemption granted to the licensee.

2.5 Final Radiation Survey Plan The LTP describes the final radiation survey plan for demonstrating that the plant and site will meet the proposed release limits. The regulations applicable to this area of review are 10 CFR 50.82(a)(9)(ii)(D) and 10 CFR 20.1501(a) and (b). The final status survey is the radiation survey performed after an area has been fully characterized, remediation has been completed, and the area is ready to be released. The purpose of the final status survey is to demonstrate that the area conforms to the radiological criteria for license termination. The final status survey is not conducted for the purpose of locating residual radioactivity; the historical site assessment and the characterization survey perform that function.

Additional guidance for final survey plans is contained in Section 4, NUREG-1757, Vol. 2 (Ref. 6) 2.5.1 Acceptance Criteria

The LTP includes the Information To Be Submitted, as described in Section 4 of NUREG-1757 Vol 2. In addition, the LTP includes the following information:

- identification of the major radiological contaminants

- methods used for addressing hard-to-detect radionuclides 2-4

- access control procedures to control recontamination of clean areas

- description of the quality assurance (QA) program, to support both field survey work and laboratory analysis, which addresses the QA organization; training and qualification requirements; survey instructions and procedures, including water, air, and soil sampling procedures; document control; control of purchased items; inspections; control of survey equipment; handling, storage, calibration, and response checks; shipping of survey equipment and laboratory samples; nonconformance items; corrective action; QA records; and the survey audits, including methods to be used for reviewing, analyzing, and auditing data

- methods for surveying embedded and buried piping

The final survey plan meets the evaluation criteria defined in Section 4 of NUREG-1757, Vol. 2 (Ref. 6).

2.6 Compliance with the Radiological Criteria for License Termination The licensee must clearly present in the LTP the radiological criteria proposed for license termination. If a licensee desires an unrestricted release in accordance with the requirements of 10 CFR 20.1402, Radiological Criteria for Unrestricted Use, the LTP should describe the methods used to demonstrate compliance.

If a licensee requests license termination under the restricted release criteria, the LTP should describe in detail how the requirements of 10 CFR 20.1403 and 10 CFR 50.82(a)(9)(ii)(E) will be met. If a licensee requests license termination under the alternative radiological criteria, the LTP should describe how the requirements in 10 CFR 20.1301(a)(1), 20.1404, and 50.82(a)(9)(ii)(E) will be met.

The information that should be submitted in the LTP and the associated evaluation criteria are described in NUREG-1757 (Ref. 6). The following table identifies the applicable portions of this NUREG.

Appropriate Sections Application of NUREG-1757, Vol. 2 Unrestricted release using screening criteria 5.1 and Appendix H Unrestricted release using site-specific 5.2 and Appendix I information Restricted release 5.3, and Appendices I and J Alternative criteria 5.4, and Appendices I and J As Low As Is Reasonably Achievable (ALARA) 6.0 and Appendix N 2-5

2.7 Update of the Site Specific Decommissioning Costs In accordance with 10 CFR 50.75, licensees are required to indicate to NRC how they will provide reasonable assurance that funds will be available for the decommissioning process.

The decommissioning financial assurance method primarily relied upon by power reactor licensees is to establish an external trust using funds set aside for decommissioning, which is segregated from the licensees assets and outside the administrative control of the licensee and its subsidiaries or affiliates. During decommissioning, licensees may use funds from this decommissioning trust if the withdrawals are for legitimate decommissioning activities consistent with the definition of decommissioning in 10 CFR 50.2 (i.e., removing a facility or site safely from service and reducing residual radioactivity to a level that permits release of the property). The licensee must continue to annually submit to the NRC, a financial status report until the licensee has completed its final radiation survey and demonstrated that residual radioactivity has been reduced to a level that permits termination of its license. The status report should discuss the amount provided by the decommissioning financial assurance methods being relied upon by the licensee. If the balance of the amount provided by these decommissioning financial assurance methods does not cover the site-specific decommissioning cost estimate, then the must discuss additional financial assurance to cover the cost estimate (10 CFR 50.82(a)(8)(vi)).

Although 10 CFR 50.54(bb) requires licensees to obtain the Commissions preliminary approval of the licensees program to manage and provide funding for the management of all spent fuel at the decommissioning reactor, funds from the decommissioning trust may not be used to pay for spent fuel management. However, licensees have applied for, and the Commission has granted, on a case-by-case basis, exemptions allowing licensees to use funds from the decommissioning trust in excess of those funds needed for radiological decommissioning for spent fuel management. In all cases, though, under 10 CFR 50.82(a)(8)(i), decommissioning trust funds may not be used if their withdrawal would reduce the value of the decommissioning trust below an amount necessary to place and maintain the reactor in a safe storage condition if unforeseen conditions or expenses arise or their withdrawal would inhibit the ability of the licensee to complete funding of any shortfalls in the decommissioning trust needed to ensure the availability of funds to ultimately release the site and terminate the license. The financial assurance requirements associated with the decommissioning of independent spent fuel storage installations (ISFSIs) is governed by 10 CFR 72.30.

Pursuant to 10 CFR 50.82(a)(9)(ii)(F), the LTP must include an updated site-specific estimate of remaining decommissioning costs. The NRC has revised this section of NUREG-1700 to make it consistent with NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors (Ref. 8) and Regulatory Guide 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (Ref. 9) as they are related to developing a detailed site-specific decommissioning cost estimate required by 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii). The licensee will be required to update only that site-specific cost estimate to reflect any changes that occurred since it was initially submitted.

For example, the licensee could be required to update the LTP cost estimate to reflect completed decommissioning activities, inflation, and changes in radioactive waste disposal cost.

If little decommissioning has been completed, and inflation and disposal costs have not changed, the cost estimate required by 10 CFR 50.82(a)(4)(i) and 10 CFR 50.82(a)(8)(iii) may be acceptable.

The NRC is not requiring the licensee to submit contractual documents or agreements that exist between the licensee and its decommissioning contractor, and the cost estimate should not be 2-6

affected by the licensees election to decommission the facility itself or to contract the decommissioning of the facility to another party. The licensee is required by 10 CFR 50.82(a)(9)(ii)(F) to submit an update to the site-specific decommissioning cost estimate. The update should reflect the current status of the facility, and the licensees plans for how the actions will be completed. Because the financial assurance methods required under 10 CFR 50.75 must be funded to the amount of the cost estimate, and because the licensee has been allowed to withdraw the allocated funds during decommissioning, the updated site-specific cost estimate must address the remaining activities necessary to complete decommissioning to ensure that sufficient funds are available.

2.7.1 Acceptance Criteria

The LTP decommissioning cost estimate includes an evaluation of the following cost elements:

- cost assumptions used, including a contingency factor (normally 25 percent)

- major decommissioning activities and tasks

- unit cost factors

- estimated costs of decontamination and removal of equipment and structures

- estimated costs of waste disposal, including applicable disposal site surcharges and transportation costs

- estimated final survey costs

- estimated total costs

The LTP focuses on detailed activity by activity cost estimates.

The LTP also compares the funds available for decommissioning with the calculated total cost from the licensees detailed cost analysis. In addition, Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors (Ref. 10), explains in detail the methods for estimating decommissioning costs, as well as accepted financial assurance mechanisms.

The LTP cost estimate is based on credible engineering assumptions, and the assumptions are related to all major remaining decommissioning activities and tasks and are consistent with the information identified in Sections B3 and B4 of this SRP.

The LTP cost estimate includes the cost of the remediation action being evaluated, the cost of transportation and disposal of the waste generated by the action, and other costs that are appropriate for the specific case. The current version of NUREG-1307, Report on Waste Burial Charges (Ref. 11), provides guidance on estimating waste disposal costs.

2.8 Supplement to the ER NRC regulation 10 CFR 50.82(a)(9)(ii)(G) requires that the licensee submit a supplement to the ER, pursuant to 10 CFR 51.53, describing any new information or significant environmental 2-7

changes associated with the proposed termination activities. The licensee should describe in detail the proposed termination activities from the time the LTP is submitted until the license is terminated. The review should focus, but not be limited to, activities associated with the radiological decontamination of the facility. The ER supplement should include a detailed description of remaining activities, including any rubblization activity and the extent to which any radioactive material may be spread around the site to meet the release criteria of 10 CFR Part 20, Subpart E. The ER supplement should also describe the interaction between the remaining activities and the environment, and the likely environmental impact of those activities.

In addition, the ER supplement should describe the likely condition of the site at license termination, such as remaining buildings and structures and residual radioactive material. The ER supplement should also state the licensees determination regarding whether the activities and effects are bounded by the potential impacts described by any site-specific EIS or EA developed in support of licensing the facility, NUREG-0586 as supplemented (Ref. 12), or the PSDAR.

2.8.1 Acceptance Criteria

The ER supplement describes changes to the data that have arisen since the licensee submitted its Applicants Environmental ReportOperating License Stage or its Applicants Environmental ReportOperating License Renewal Stage, as appropriate.

The ER supplement describes the potential environmental impacts associated with site-specific termination activities from the time the LTP is submitted until the license is terminated.

The ER supplement states the licensees determination regarding whether the activities and effects are bounded by the potential impacts described by any site-specific EIS or EA developed in support of licensing the facility, NUREG-0586 as supplemented, or the PSDAR. The ER supplement should also describe any proposed mitigation measures the licensee will take to avoid significant impact.

The ER supplement identifies the parts, if any, of the facility or site that were released for use before approval of the license termination plan.

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3 EVALUATION FINDINGS In reviewing an LTP, the NRC staff will consider whether the licensee has met each of the requirements set out below and whether the plan provides an adequate basis for each of the following findings identified below and these findings are founded on the Acceptance Criteria defined in Sections B. 1- 8 of this SRP.

The Evaluation Findings are as follows:

The licensee submitted the LTP as a supplement to the facilitys FSAR or its equivalent in accordance with 10 CFR 50.82(a)(9)(i).

The licensee met the objective of providing an adequate site characterization as required by 10 CFR 50.82(a)(9)(ii)(A).

The licensee identified the remaining site dismantlement activities that are necessary to complete the decommissioning of the facility, as required by 10 CFR 50.82(a)(9)(ii)(B).

The licensee adequately described its plans for site remediation, as required by 10 CFR 50.82(a)(9)(ii)(C).

The licensees final radiation survey plan adequately demonstrates that the plant and site will meet the radiological release criteria for license termination as defined in 10 CFR 50.82(a)(9)(ii)(D).

The licensee adequately described how it will meet the requirements of 10 CFR 50.82(a)(9)(ii)(E), with respect to the end-use of the site, if the licensee requests license termination under the restricted release criteria.

The licensee met the requirements of 10 CFR 50.82(a)(9)(ii)(F) by providing an updated site-specific estimate of the remaining decommissioning costs, and plans for ensuring the availability of adequate funds for decommissioning.

The licensee met the requirements of 10 CFR 50.82(a)(9)(ii)(G) and 10 CFR 51.53, Post-Construction Environmental Reports, by providing acceptable updates to the Environmental Report Operating License Stage.

The licensee met the requirements of 10 CFR 50.82(a)(9)(ii)(H) by identifying the parts, if any, of the facility or site that were released before approval of the license termination plan.

For unrestricted release, the licensee met the requirements of 10 CFR 20.1402, and NUREG-1757, Appendix H, screening values in that the LTP demonstrates the radiological criteria for unrestricted release will be met.

For restricted release, the licensee met the requirements of 10 CFR 20.1403(a), in that the LTP demonstrates that further reductions in residual radioactivity to allow the site to be released for unrestricted use either (a) would result in net public or environmental harm, or (b) are not being made because the residual levels are ALARA.

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For restricted release, the licensee met the requirements of 10 CFR 20.1403(b), in that the LTP demonstrates that with the institutional controls in place, the dose criteria for restricted release will be met.

For restricted release, the licensee met the requirements of 10 CFR 20.1403(c), in that the LTP demonstrates that sufficient financial assurance is available to enable a third party to assume and carry out any necessary maintenance of the site.

For restricted release, the licensee met the requirements of 10 CFR 20.1403(d), in that the LTP demonstrates the requirements for public involvement have been met.

For restricted release, the licensee met the requirements of 10 CFR 20.1403(e), in that the LTP demonstrates that the dose criteria for restricted release will still be met in the event that the institutional controls should fail.

For license termination using alternative criteria, the licensee met the requirements of 10 CFR 20.1404(a), in that the LTP demonstrates the dose criteria for license termination using alternative criteria will be met.

For license termination using alternative criteria, the licensee met the requirements of 10 CFR 20.1404(a)(4), in that the LTP demonstrates the requirements for public involvement criteria have been met.

The LTP contains a description of the exemption granted to the licensee to allow more than 60 years for completion of decommissioning under 10 CFR 50.82(a)(3), if applicable.

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4 REFERENCES

1. U.S. Nuclear Regulatory Commission (NRC), Regulatory Guide (RG) 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, June 2017.

2. NRC, Decommissioning of Nuclear Power Reactors (Title 10 of the Code of Federal Regulations (10 CFR) Parts 2, 50, and 51), Federal Register, Vol. 61, pp. 39278-39296 (61 FR 39278), July 29, 1996.

3. NRC, RG 1.184, Decommissioning of Nuclear Power Reactors, October 2013.

4. NRC, Radiological Criteria for License Termination, 10 CFR Parts 20, 30, 40, 50, 51, 70, and 72, Federal Register, Vol. 62, pp. 39058-39092 (62 FR 39058), July 21, 1997.

5. NRC, Releasing Part of Power Reactor a Facility or Site for Unrestricted Use Before the NRC Approves the License Termination Plan, 10 CFR Parts 2, 20, and 50, Federal Register, Vol. 66, pp. 46230-46239 (66 FR 46230), September 4, 2001.

6. NRC, NUREG-1757, Consolidated NMSS Decommissioning Guidance, Vols. 1, and 2, September 2006.

7. NRC, RG 1.185, Standard Format and Content Guide for Post-Shutdown Decommissioning Activities Report, July 2000.

8. NRC, NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors, December 2004.

9. NRC, RG 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors, February 2005.

10. NRC, RG 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, October 2003.

11. NRC, NUREG-1307, Report on Waste Burial Charges, Rev. 9, January 2013.

12. NRC, NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, November 2002 4-1