ML22154A016

R. Turtil - Presentation on Decommissioning Funding Requirements and Oversight - Decommissioning Strategy Forum, Las Vegas, Nevada, June 6-8, 2022

ML22154A016
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Issue date:	06/07/2022
From:	Richard Turtil NRC/NMSS/DREFS/FAB
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Decommissioning Funding Requirements and Oversight June 7, 2022 Decommissioning Strategy Forum Richard Turtil, Senior Financial Analyst Office of Nuclear Material Safety and Safeguards 1

Decommissioning Funding Overview

• Reactor Licensee Requirements

• Minimum Funding Requirements and Formula Calculation - initial and throughout operations

• Methods of Financial Assurance

• Transition to Site-Specific Cost Estimate

• Decommissioning Funding Lifecycle

• Current NRC Rulemaking 2

10 CFR 50.75 - Reporting and Recordkeeping for Decommissioning Planning

• Purpose Provides reasonable assurance that funds will be available for decommissioning after a reactor ceases operations.

• Initial Funding Provided by licensee prior to authorization for initial fuel load and operation.

• Licensee Accumulates Funds over Life of Operating Reactor Reported to the NRC at least every two years.

Reported annually if within 5 years of cessation of operations and while in decommissioning.

3

Minimum Decommissioning Funding Requirement

• NRC Minimum Funding Amount (MFA) adjusted for changes in Labor, Energy, and LLW Burial costs over life of reactor.

• MFA varies by reactor based on:

- Size of Reactor (MWt) - Type of Reactor (BWR vs. PWR)

• MFA is not a site-specific cost estimate.

• MFA covers Radiological Decommissioning only.

Does not consider spent fuel management, site restoration, and other non-radiological costs.

4

NRC Minimum Formula Amount =

(Regulatory Formula Amount) x (Adjustment Factor)

Example Calculations (approximate estimates):

PWR and BWR of 3,400 MWt Capacity or Greater (Data as of December 31, 2020)

PWR ($105 million) x (labor, energy, and LLW burial adjustment factor of ~ 4.00 - 5.00)

= ~$420 - $525 million $US 2020 BWR ($135 million) x (labor, energy, and LLW burial adjustment factor of ~ 5.00)

= ~$685 million $US 2020

Funding Methods

• Prepayment

• External sinking fund

• Surety method, insurance, or other guarantee

• Statement of intent

• Contractual obligations

• Other mechanism or combination 6

Transition to Site-Specific Cost Estimate

• At or about 5 years of the projected end-of-life, a site-specific cost estimate (SSCE) is required which includes a complete up-to-date assessment of major factors that could affect anticipated radiological decommissioning costs.

• The SSCE must be greater than or equal to the NRC Minimum Formula Amount.

7

Decommissioning Fund Lifecycle

• Initial Certification of Financial Assurance.

• Maintain the NRC MFA throughout operating life of reactor; replaced by SSCE near end of operations and into decommissioning.

• Monitoring and Updating of Decommissioning Funding -

Licensee provides Decommissioning Fund Status Report to the NRC (every 2 years); annually in decommissioning.

Licensee Provides SSCE 5 years prior to permanent cessation of operations & in Post-Shutdown Decommissioning Activities Report.

NRC Inspectors coordinate decommissioning oversight with the technical decommissioning and financial assessment staff.

8

Transition to Decommissioning Rulemaking -

Decommissioning Funding Assurance

• Current GUIDANCE -

o Non-rate-regulated licensees should make up shortfalls in decommissioning funding within 2 years and electric utility licensees within 5 years.

• Proposed RULE would -

o Clarify that when a licensee identifies a shortfall in biennial report, must obtain additional financial assurance to cover the shortfall in the next report.

o Modify biennial reporting frequency for operating reactors to 3-year frequency.

• The 3/3/2022 notice announcing the proposed RULE seeks public comment on four decommissioning funding issues -

o Financial Assurance and the Minimum Formula Approach/Bulk o Site-Specific Cost Analysis o Decommissioning Trust Fund Assets for Spent Fuel Management and Other Uses o Timing of Decommissioning Fund Assurance Reporting 9

Thank You!

Rich Turtil U.S. NRC 10