Regulatory Guide 1.202

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Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors.
ML050230008
Person / Time
Issue date: 02/14/2005
Revision: 0
From:
Office of Nuclear Regulatory Research
To:
PITTIGLIO C L, NRR/DRIP, 415-1199
References
DG-1085 RG-1.202
Download: ML050230008 (20)
v • d • e


The U.S. Nuclear Regulatory Commission (NRC) issues regulatory guides to describe and make available to the public methods that the NRC staff considers acceptablefor use in implementing specific parts of the agency's regulations, techniques that the staff uses in evaluating specific problems or postulated accidents, and data that thestaff need in reviewing applications for permits and license Regulatory guides are not substitutes for regulations, and compliance with them is not require Methods andsolutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance ofa permit or license by the Commission.This guide was issued after consideration of comments received from the publi The NRC staff encourages and welcomes comments and suggestions in connection withimprovements to published regulatory guides, as well as items for inclusion in regulatory guides that are currently being develope The NRC staff will revise existing guides,as appropriate, to accommodate comments and to reflect new information or experienc Written comments may be submitted to the Rules and Directives Branch,Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.Regulatory guides are issued in 10 broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting;5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.Requests for single copies of draft or active regulatory guides (which may be reproduced) should be made to the U.S. Nuclear Regulatory Commission, Washington, DC20555, Attention: Reproduction and Distribution Services Section, or by fax to (301) 415-2289; or by email to Distribution@nrc.go Electronic copies of this guide and otherrecently issued guides are available through the NRC's public Web site under the Regulatory Guides document collection of the NRC's Electronic Reading Roomat http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC's Agencywide Documents Access and Management System (ADAMS)at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML05023000 Note, however, that the NRC has temporarily suspended public access to ADAMS sothat the agency can complete security reviews of publicly available documents and remove potentially sensitive informatio Please check the NRC's Web site for updatesconcerning the resumption of public access to ADAMS.U.S. NUCLEAR REGULATORY COMMISSIONFebruary 2005REGULATORY GUIDEOFFICE OF NUCLEAR REGULATORY RESEARCHREGULATORY GUIDE 1.202(Draft was issued as DG-1085, dated November 2001)STANDARD FORMAT AND CONTENTOF DECOMMISSIONING COST ESTIMATESFOR NUCLEAR POWER REACTORS INTRODUCTIONDecommissioning means permanently removing a nuclear facility from service and reducing radioactivematerial on the licensed site to levels that would permit termination of the license issued by the U.S. Nuclear Regulatory Commission (NRC). The NRC amended its regulations on decommissioning procedures that lead to termination of an operating license for nuclear power reactors, as specified in Title 10, Section 50.82, of the Code of Federal Regulations (10 CFR 50.82). The amended regulations became effective on July 29, 1996. This rulemaking included changes to 10 CFR Part 2, "Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders"; Part 50, "Domestic Licensing of Production and Utilization Facilities"; and Part 51,

"Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Among other relevant topics, these regulations contain requirements related to submission of decommissioning cost estimate The purpose of this regulatory guide is to provide licensees with guidance on a method that the NRC staff finds acceptable for use in preparing the following required cost estimates as specified in the regulations:*The preliminary decommissioning cost estimate (hereinafter referred to as the preliminary cost estimate)is to be submitted at or about 5 years prior to the projected end of operations [10 CFR 50.75(f)(2)].*The expected cost estimate contained in the Post-Shutdown Decommissioning Activities Report (PSDAR)is required to be submitted (with the PSDAR) prior to or within 2 years of permanent cessation of operations [10 CFR 50.82(a)(4)(i)].

1.202-2*The site-specific decommissioning cost estimate is to be submitted within 2 years followingpermanent cessation of operations [10 CFR 50.82(a)(8)(iii)].*The updated site-specific cost estimate for remaining decommissioning activities is to beincluded in the License Termination Plan (LTP), which must be submitted at least 2 years before termination of the license [10 CFR 50.82(a)(9)(ii)(F)].The NRC staff suggests that licensees use the standard format described in this regulatory guideto facilitate preparation and NRC review of the required cost estimates.This regulatory guide applies only to power reactor licensee The regulations for non-powerreactor licensees are given in 10 CFR 50.82(b).The 1996 amendment to the NRC's regulations on decommissioning procedures requiresthat power reactor licensees who were engaged in decommissioning at the time the regulation became effective must convert to, and comply with, the amended regulatio All power reactor licensees are required to comply with the decommissioning procedures specified in these regulations, and no "grandfathering" considerations are applicable.The NRC's decommissioning regulations address the minimum decommissioning fundingrequirements necessary to achieve termination of the license issued under 10 CFR Part 5 The NRC's definition of decommissioning does not include other activities related to facility deactivation and site closure, including operation of the spent fuel storage pool, construction and/or operation of an independent spent fuel storage installation (ISFSI), demolition of decontaminated structures, and/or site restoration activities after residual radioactivity has been remove Accordingly, this regulatory guide does not address such "non-NRC decommissioning costs"; nonetheless, this regulatory guide does address the cost to decontaminate an ISFSI licensed under the General License.Rules applicable to managing and providing funding for the management of irradiated fuelfollowing shutdown are contained in 10 CFR 50.54(bb). Regulations applicable to an ISFSI facilityare contained in 10 CFR Part 72, "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste." Site restoration activities that do not involve the removal of residual radioactivity necessary to terminate the NRC license are outside the scope of NRC regulation.This regulatory guide contains information collections that are covered by the requirementsof 10 CFR Part 50, which the Office of Management and Budget (OMB) approved under OMB control number 3150-001 The NRC may neither conduct nor sponsor, and a person is not required to respond to,an information collection request or requirement unless the requesting document displays a currently valid OMB control numbe .202-3 DISCUSSIONDECOMMISSIONING OPTIONSThe three basic methods for decommissioning are DECON, SAFSTOR, and ENTOMB. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities,"and NUREG-0586, Supplement 1 (Ref. 1), evaluated the environmental impact of these three methods,which are summarized as follows:(1)DECON: The equipment, structures, and portions of the facility and site that contain radioactivecontaminants are promptly removed or decontaminated to a level that permits termination of the license after cessation of operation (Decontamination is initiated within a couple of years after shutdown and continues until completed, usually within 7 to 10 years.)(2)SAFSTOR: The facility is placed in a safe, stable condition and maintained in that state(safe storage). The facility is decontaminated and dismantled at the end of the storage period to levels that permit license terminatio Therefore, the SAFSTOR determination includes consideration of those activities necessary for final decontamination and dismantlement of the facilit During SAFSTOR, a facility is left intact or may be partially dismantled, but the fuel is removed from the reactor vessel and radioactive liquids are drained from systems and component Radioactive decay occurs during the SAFSTOR period, thereby reducing the quantity of contamination and radioactivity that must be disposed of during decontamination and dismantlement (D&D). The SAFSTOR determination also includes D&D of the facility at the end of the storage period.(3)ENTOMB: Radioactive structures, systems, and components are encased in a structurallylong-lived substance, such as concret The entombed structure is appropriately maintained, and monitored (through continued surveillance) until the radioactivity decays to a level that permits termination of the licens Because most power reactors will have radionuclides in concentrations exceeding the limits for unrestricted use even after 100 years, and because current regulations require decommissioning to be completed within 60 years of cessation of operation, the NRC will handle entombment requests on a case-by-case basis.Although the selection of the decommissioning option is up to the licensee, the NRC requiresthe licensee to reevaluate its selection if the option (1) cannot be completed as described, (2) cannot be completed within 60 years of the permanent cessation of plant operations, (3) includes activities that would endanger the health and safety of the public by being outside of the NRC's health and safety regulations, or (4) will result in a significant impact to the environmen .202-4DECOMMISSIONING COST ESTIMATESThe following regulatory requirements relate to submitting a decommissioning cost estimate:*10 CFR 50.75(f)(2) requires that a licensee "-shall at or about 5 years prior to the projected endof operations submit [to the NRC] a preliminary decommissioning cost estimate which includes an up-to-date assessment of the major factors that could affect the cost to decommission."

10 CFR 50.75(f)(4) requires a licensee to include plans to adjust funding levels to demonstrate a reasonable level of financial assurance, if necessary, in the preliminary cost estimate.In addition, 10 CFR 50.75(c) specifies that the initial certification amount of fundsfor decommissioning must be based on the amounts specified in 10 CFR 50.75(c), which represents the minimum funding level that applicants and licensees must mee However to meet the requirements of 10 CFR 50.75(c), a power reactor licensee may submit a certification based on a site-specific cost estimate, which may be more (but not less) than the amount specified in 10 CFR 50.75(b)(1) when a higher funding level than 10 CFR 50.75(c) is desire The basis for any increases should be provide Although this site-specific cost estimate is not the same site-specific cost estimate required by 10 CFR 50.82(a)(8)(iii), it should address many areas identified in Section 3 of this document; however, the level of detail will be less and the level of uncertainty may vary.*10 CFR 50.82(a)(4)(i) requires a licensee to provide "-an estimate of expected costs-"for the activities being proposed in the PSDA As previously stated, the PSDAR is to be submitted prior to or within 2 years following permanent cessation of operation Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report" (Ref. 2), identifies the types of information to be included in the PSDA The cost estimate may be a site-specific cost estimate or the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c), as currently reported to the NRC on a calendar-year basis at least once every 2 years in accordance with 10 CFR 50.75(f)(1).*10 CFR 50.82(a)(8)(iii) requires a licensee to provide a site-specific decommissioning costestimate within 2 years following permanent cessation of operation (This requirement may be satisfied by including a site-specific cost estimate as part of the PSDAR.)In addition, 10 CFR 50.75(c) specifies that the initial certification amount of fundsfor decommissioning must be based on the amounts specified in 10 CFR 50.75(c)(1), which represents the minimum funding level that applicants and licensees must mee The site-specific cost estimate submitted within 2 years following permanent cessation of operations may be significantly larger than the funding level based on the formul If the site-specific cost estimate results in a funding level that differs from the amount specified in 10 CFR 50.75(c), the licensee must provide the basis for the change.*10 CFR 50.82(a)(9)(ii)(F) requires a licensee to provide "an updated site-specific estimateof remaining decommissioning costs-" as part of a license termination plan (LTP).

10 CFR 50.82(a)(9)(i) requires a licensee to submit its LTP at least 2 years before termination of the licens .202-5As provided in 10 CFR 50.82(a)(8)(ii), a licensee may withdraw funds from the decommissioningtrust fund up to a cumulative total of 3 percent of the generic amount calculated under 10 CFR 50.75(c)

for decommissioning planning purposes at any time without prior notification to the NR After submittal of the certifications of permanent shutdown and fuel removal required under 10 CFR 50.82(a)(1)

and commencing 90 days after the NRC has received the PSDAR, the licensee may use up to an additional 20 percent of the decommissioning funds prescribed in 10 CFR 50.75(c) for decommissioning purpose The licensee is prohibited from using the remaining 77 percent of the generic decommissioning funds until a site-specific decommissioning cost estimate is submitted to the NR In addition, 10 CFR 50.82(a)(8)(i) limits use of the decommissioning funds to legitimate radiological decommissioning expenses that neither reduces the value of the trust fund below that necessary to place and maintain the reactor in a safe storage condition, nor impacts the licensee's ability to complete funding of the trust to ultimately release the site and terminate the licens REGULATORY POSITIONThe major types of cost estimates affecting the licensee are (1) the preliminary cost estimate,(2) the estimate of expected costs presented in the PSDAR, (3) the site-specific decommissioning cost estimate, and (4) the updated site-specific estimate of remaining decommissioning costs.The licensee is reminded that 10 CFR 50.2 defines decommissioning as the safe removalof a facility or site from service and the reduction of residual radioactivity to levels that permit release of the site and termination of the licens For example, removing uncontaminated material, such as soil or a wall, to gain access to contamination to be removed would be a legitimate decommissioning cos However, the costs of demolition of decontaminated structures, site restoration activities, or other activities not involved with removing the facility from service or reducing residual radioactivity are not included within the NRC's definition of decommissioning costs, and are not included in the amount of funds that 10 CFR 50.75 requires to be placed in the plant's decommissioning fun If a licensee sets aside funds in the trust that are supporting non-NRC decommissioning activities, the sub-accountsunder the trust must be clearly designated.1.PRELIMINARY COST ESTIMATE PRIOR TO THE END OF OPERATIONSThe preliminary cost estimate, required by 10 CFR 50.75(f)(2), must be submitted at or about5 years before the projected end of operation The intent of the preliminary estimate is to provide the NRC with an up-to-date estimate of decommissioning costs and identify major factors that would impact the cost of the decommissionin The licensee will already have submitted a cost estimate for establishing a fund for decommissioning as required by 10 CFR 50.75(b). This estimate will have been revised periodically during operation and may be used in preparing the preliminary cost estimat For the preliminary cost estimate, the NRC will compare the estimated costs with the minium decommissioning trust fund amount derived from the formula and, if the preliminary cost estimate is greater than the amount in the decommissioning trust fund, the licensee should include a discussion of the mechanism for adjusting the level of funds to demonstrate that funds will be available for use at the time of permanent shutdown.The preliminary cost estimate may be a new or previously developed site-specific cost estimate,provided that the estimate contains the information specified in 10 CFR 50.75(f)(2) and represents the cost to decommission the facilit The preliminary cost estimate information may be in summary form, as long as the supporting basis has previously been submitted and is reference .202-6The projected end of operations need not be the same as the expiration date of the operating licenseif a licensee chooses to permanently cease operations at an earlier dat In some cases, a licensee may shut down prematurely and submit its certification of permanent cessation of operations, as required by 10 CFR 50.82(a)(1), more than 5 years prior to the expiration date of the operating licens In this event, the requirement of 10 CFR 50.75(f)(2) to submit a preliminary cost estimate is not applicabl If a prematurely shutdown licensee chooses to submit its PSDAR along with its certification of permanent shutdown, it could choose to submit its preliminary cost estimate as the estimate of expected costs required for the PSDA This action would satisfy the requirements of 10 CFR 50.82(a)(4)(i).The information in the preliminary cost estimate should be similar to that submittedfor the site-specific cost estimate; however, the level of detail will be less and the level of uncertainty may var For example, the NRC recognizes that many items (such as waste disposal cost) are difficult to estimate and may vary during the 5 years prior to shutdow The preliminary cost estimate should include the following:*a detailed discussion of the decommissioning option anticipated to be implemented (DECON,SAFSTOR, or some combination thereof), with major factors that could impact the cost of decommissioning, including major technical actions and waste disposal site availability*a discussion of the potential for known or suspected contamination at the site that may affectthe cost of decommissioning [This discussion should include an evaluation of the records of information important to decommissioning required by 10 CFR 50.75(g). Although the requirements described in 10 CFR 50.75(g) for keeping records of spills or other unusual occurrences are outside the scope of this regulatory guide, the licensee should evaluate the anticipated extent of contamination on the facility and site, based on information available in the decommissioning file This evaluation should include descriptions of known instances of releases of contaminated materials into the facility and the external environment, along with the possible impact on decommissionin Known environmental contamination (e.g., contamination in soil, groundwater, or surface water) should be identified.]*a preliminary schedule that shows the major decommissioning phases and the time periodover which each of the phases extends*a summary of the total estimated decommissioning costs by decommissioning activity[This summary should include the anticipated cost of low-level waste (LLW) disposa Table 1 of this document presents a suggested format for providing this information.]*a comparison of the estimated cost with the minimum decommissioning fund requirement

  • a discussion of the plans for adjusting the level of funds in the trust to demonstrate that fundswill be available for use when needed should be included if the decommissioning trust is not fully funded 1.202-7Table Suggested Format for Tabulating Expected CostsEstimated Decommissioning Cost (Millions of Estimate-Year Dollars)Period 1(X.X Years)Period 2(X.X Years)Period 3(X.X Years)Period 4(X.X Years)Duration(X.X Years)DecommissioningActivityPlanning &PreparationPlantDeactivationSafe StorageOperationsDismantle-mentTotal CostRadioactive Component Removal Decontamination andDismantlementManagement and Support LLW Costs including packaging,shipping and burial/vendor costsTotal Cost2.ESTIMATE OF EXPECTED COSTS IN THE PSDARPrior to or within 2 years following permanent cessation of operations, the licensee is required[by 10 CFR 50.82(a)(4)(i)] to submit a PSDAR to the NR In addition to other prescribed content, this report must include an estimate of cost Regulatory Guide 1.185 (Ref. 2) identifies the types of information to be contained in the PSDA The cost estimate may be satisfied by either of the following methods and supporting information:(1)the amount of decommissioning funds estimated to be required by 10 CFR 50.75(b) and (c),as currently reported to the NRC on a calendar-year basis at least once every 2 years in accordance with 10 CFR 50.75(f)(1)(2)a site-specific cost estimateOther related but non-NRC decommissioning costs (e.g., spent fuel storage, site restoration)may be included in the estimate of costs if desired; however, the cost of radiological decommissioning as defined by 10 CFR 50.2 should be listed separatel As a separate item, the cost of placing and maintaining the facility in safe storage should be identified, along with a plan to ensure that sufficient funds will be available for this purpose, if necessary, until such time as the radioactively contaminated material is placed in an authorized waste disposal sit It should be noted that, as with the PSDAR, 10 CFR 50.82(a)(8)(iii) requires a licensee to provide a site-specific decommissioning cost estimate within 2 years following permanent cessation of operation If the estimate of costs provided withthe PSDAR is a site-specific cost estimate, this requirement can be satisfied with the PSDAR submitta .202-82.1Cost Estimate Based on Financial Assurance Amounts [10 CFR 50.75(b) and (c)]Licensees of operating pressurized-water reactors (PWRs) and boiling-water reactors (BWRs)must provide reasonable assurance that funds will be available to accomplish decommissioning within 60 years from the date of permanent cessation of operations, as required by 10 CFR 50.82(a)(3).

Reasonable assurance may be demonstrated by compliance with the requirements of 10 CFR 50.75(b),

(c), (e), and (f). These requirements ensure that a licensee has financial assurance in effect for an amount that may be more (but not less) than the amount stated in the table in 10 CFR 50.75(c)(1). A licensee is required [by 10 CFR 50.75(f)(1)] to report, on a calendar-year basis at least once every 2 years, the status of its decommissioning fundin Specifically, this table demonstrates that if P equalsthe thermal power of a reactor in megawatts (MWt), the minimum financial assurance (MFA) funding amount (in millions, January 1986 dollars) is calculated as follows:*for a PWR: MFA = (75 + 0.0088P)*for a BWR: MFA = (104 + 0.009P)For either a PWR or a BWR, if the thermal power of the reactor is less than 1,200 MWt,the value of P to be used in these equations is 1,200, whereas if the thermal power is greater than3,400 MWt, the value of P to be used is 3,400.The financial assurance amounts calculated in the above equations are based on January 1986dollar To account for inflation from 1986 to the current year, these amounts must be adjusted annually by multiplying by an escalation factor (ESC) described in 10 CFR 50.75(c)(2), as follows:ESC (current year) = (0.65L + 0.13E + 0.22B)where L and E are the ESC from 1986 to the current year for labor and energy, respectively, and are to betaken from regional data of the U.S. Department of Labor, Bureau of Labor Statistics (Refs. 3 and 4),

and B is an annual ESC from 1986 to the current year for waste burial and is to be taken from the mostrecent revision of NUREG-1307, "Report on Waste Disposal Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities" (Ref. 5). The NRC updates NUREG-1307from time to time to account for disposal charge change In January 1986 (the base year), using disposal costs from DOE's Hanford Reservation waste disposal site, L, E, and B all equaled unity; thus, the ESCitself equaled unit (Reference 2 discusses the origin of the 0.65L, 0.13E, and 0.22B terms.) Thus,MFA (in millions, current year dollars) = MFA x ESC (current year)2.2Site-Specific Cost Estimates in the PSDARThe estimate of expected decommissioning costs required for the PSDAR can be the sameas the site-specific cost estimate required by 10 CFR 50.82(a)(8)(iii). The site-specific cost estimate is a detailed assessment that incorporates the cost impact of site-specific factor (Section 3 of thisdocument discusses the site-specific estimate.)

1.202-93.SITE-SPECIFIC COST ESTIMATEA licensee is required [by 10 CFR 50.82(a)(8)(iii)] to submit a site-specific cost estimatewithin 2 years following permanent cessation of operation The licensee may include this cost estimate with the PSDAR [10 CFR 50.82(a)(4)(i)]. In addition, a site-specific estimate may be submitted, at the discretion of the licensee, when a funding level differs from that calculated in the formula in 10 CFR 50.75(c). The site-specific cost estimate must clearly identify and provide the basis for the funding level if it differs from the formul The site-specific cost estimate information, as well as the update of the site-specific cost, may be in summary form, as long as the supporting basishas previously been submitted and is reference If the cost estimate was prepared for the rate regulator, it may contain additional costs that the NRC does not consider part of the radiological decommissioning costs; however, the cost estimate is acceptable provided the costs are separated and easily distinguishabl Sections 3.1-3.4 discuss the types of information that the licensee should provide to help the NRC staff properly assess the estimate.3.1General Information*Discuss the chosen decommissioning option (DECON, SAFSTOR, or some combinationthereof).*Discuss the methodology used to derive the cost estimates.*Summarize total decommissioning costs by perio (Table 2 of this document presentsa suggested format for providing this information.) Provide a separate list of the costs of items not considered part of decommissioning (such as site restoration and spent nuclear fuel storage/management).*Compare the estimated cost with the minimum financial assurance (MFA) funding requirement.

  • Discuss the plans for adjusting the level of funds in the trust should be included to demonstratethat funds will be available for use when needed if the decommissioning trust is not fully funded.*Summarize the costs of services, supplies, and special equipmen This category should includecost estimates for protective clothing and equipment services supplied by an outside vendo Also included under this category would be costs of purchasing or leasing specialized decommissioning equipment.*Summarize undistributed costs, such as property taxes, consultancy costs, nuclear liabilityinsurance costs, energy costs, annual maintenance costs for SAFSTOR phases, site termination survey costs, and regulatory costs (inspections, miscellaneous fees, etc.).Table Suggested Format for Tabulating Decommissioning Costs by PeriodDecommissioningOption ChosenDECON or SAFSTORDecommissioning Period Duration (Years) /Decommissioning Cost (Millions of Estimate-Year Dollars)Period 1Planning &PreparationPeriod 2Plant Deacti-vationPeriod 3Safe Storage OperationsPeriod 4Dismantle-mentTotalPeriod YearsPeriod Cost 1.202-10For the DECON option, the total decommissioning costs should be separated into the followingactivities:*major radioactive component removal (reactor vessel and internals, steam generators,pressurizers, large-bore reactor coolant system piping, and other large components)*radiological decontamination and dismantlement (D&D, which involves removing remainingradioactive plant systems, including radiological decontamination) (Tables 3 and 4 of this document present suggested formats for providing this information.)*management and support [labor costs of support staff and decommissioning operationscontractors (DOCs), energy costs, regulatory costs, small tools, insurance, etc.]*low-level waste (LLW) costs (including packaging, shipping, and burial/waste vendor costs)*groundwater and soil remediation, if any*final radiological survey costs
  • contingency (allowance for unexpected costs)Table Suggested Format for Listing Contaminated Equipment and PipingEquipment Category(a)Length of Piping in Feet or Number of Items in EachCategoryPiping diameter > 3 inchesPiping diameter 3 inchesValves > 3 inches Valves 3 inchesTanks of all sizes Pumps > 100 pounds Pumps 100 poundsHeat exchangers > 100 pounds Heat exchangers 100 poundsElectrical components > 100 pounds Electrical components 100 poundsMiscellaneous components > 100 pounds Miscellaneous components 100 poundsLarge piping hanger for pipes > 4 inches in diameter Small piping hanger for pipes 4 inches in diameter(a)The equipment categories shown here as example Any reasonable method of categorization is acceptable.Table Suggested Format for Listing Concrete and Metal Surfaces that Require Radiological Decontamination or RemovalBuilding orLocationArea of ConcreteDecontaminated (ft2)Volume of ConcreteRemoved (ft3)Area of Metal SurfacesDecontaminated (ft2)Volume of Metal SurfacesRemoved (ft3)

1.202-11For the SAFSTOR option, the decommissioning costs should also be separated into the followingtime periods, or a similar set of decommissioning time periods:*pre-decommissioning engineering and planning/plant deactivation (all activities fromengineering and planning through defueling and layup to complete the placement of the reactor into permanent shutdown condition)*extended safe storage operations (safe storage monitoring of the facility until dismantlementbegins); if storage or monitoring of spent fuel is included in the cost estimate, it should be shown separately*final radiological D&D (radiological D&D of radioactive systems and structures requiredfor license termination, including demolition for the purposes of reducing residual radioactivity);

if demolition of decontaminated structures and site restoration activities are included in the cost estimate, they should be shown separatelyTable 1 provides an example of a format for tabulating costs for either DECON or SAFSTOR.Tables 5 and 6 provide suggested formats for tabulating decommissioning cost for both PWR and BWR component cos .202-12Table Suggested Format for Tabulating PWR Decommissioning Costs by PeriodDecommissioning Cost (Thousands of Estimate-Year Dollars)Period 1Period 2Period 3Period 4Duration(X.X Years)(X.X Years)(X.X Years)(X.X Years)(X.X Years)Decommissioning ActivityPlanning &PreparationPlantDeactivationSafe StorageOperationsDismantlementTotal CostRadioactive Component RemovalRemoval of RPV InternalsRemoval of Reactor Pressure Vessel Steam Generator--Direct Removal Costs Steam Generator--Cascading Costs RCS Piping Large Miscellaneous RCS Piping Small Miscellaneous RCS Piping RCS Insulation Pressurizer Pressurizer Relief Tank Primary Pumps Spent Fuel Racks Biological ShieldSubtotalDecontamination and DismantlementDecontamination of Site BuildingsRemoval of Contaminated Plant SystemsSubtotalManagement and SupportSupport StaffDOC Staff Consultant/Other Staff Termination Survey Costs Regulatory Costs Special Tools and Equipment Environmental Monitoring Costs Laundry Services Small Tools and Minor Equipment Nuclear Liability Insurance Property Taxes DOC Mobilization/Demobilization Costs Steam Generator--Undistributed Costs Chemical Decon Plant Power UsageSubtotalLLW Costs including packing,shippingand vendor/burial costsTotal 1.202-13Table Suggested Format for Tabulating BWR Decommissioning Costs by PeriodDecommissioning Cost (Thousands of Estimate-Year Dollars)Period 1Period 2Period 3Period 4Duration ( X.X Years)(X.X Years) (X.X Years)(X.X Years)(X.X Years)Decommissioning ActivityPlanning &PreparationPlant DeactivationSafe StorageOperations Dismantle-mentTotal CostRadioactive Component RemovalRPV InternalsReactor Pressure Vessel and Insulation Shielding Recirculation Pumps RCS Piping RCS Piping Insulation Main Turbine Main Turbine Condenser Moisture Separator Reheaters Feed Water Heaters Turbine Feed Pumps Structural Beams, Plates, & Cable Trays Spent Fuel RacksSubtotalDecontamination and DismantlementDecontamination of Site BuildingsRemoval of Contaminated Plant SystemsSubtotalManagement and SupportSupport StaffDOC Staff Consultant/Other Staff Termination Survey Costs Regulatory Costs Special Tools and Equipment Environmental Monitoring Costs Laundry Services Small Tools and Minor Equipment Nuclear Liability Insurance DOC Mobilization/Demobilization Costs Chemical Decontamination Plant Power UsageSubtotalLLW Costs including packaging,shipping,and burial/vendor costsTotal 1.202-143.2Cost Estimate for the Removal or Radiological Decontaminationof Major Radioactive ComponentsFor a PWR, major radiological components should include, but not be limited to, the following:*reactor vessel and internals *reactor coolant loops

  • reactor coolant pumps
  • bioshield
  • pressurizer
  • steam generators
  • spent fuel racks
  • other large contaminated componentsFor a BWR, major radiological components should include, but not be limited to, the following:*reactor vessel and internals*reactor coolant piping
  • main turbines/generators
  • turbine condensers
  • moisture separator reheaters
  • feedwater heaters
  • feedwater pumps
  • spent fuel racks
  • other large contaminated components3.3Burial Cost and VolumesThe licensee should provide tabulations of expected waste volumes, packaging costs, shippingcosts, and burial costs by decommissioning activit Table 7 provides a suggested forma The licensee should also submit plans for radwaste disposition, including radwaste disposal sites to be used, if availabl If a vendor will process the waste, the radwaste information after processing should be provided to show the results of the waste minimizatio The licensee may also elect to provide descriptions of the methods and technologies used to achieve the improved waste characteristic The licensee should also provide radwaste volumes by class expected to be generated during decommissionin Table 8 provides a suggested format.Table Typical Waste Burial Cost and VolumesDecommissioning ActivityWaste Volume(ft3)Packaging Cost(Estimate-Year $millions)Shipping Cost(Estimate-Year $millions)Burial Cost(Estimate-Year$millions)Removal of Nuclear Steam SupplySystemRemoval of Contaminated PlantSystemsRadiological Decontamination ofSite BuildingsDry Active WasteTotal 1.202-15Table Burial Volumes by Waste ClassWaste ClassVolume (ft3)PercentClass AClass B&C Greater-Than-Class-CTotal3.4Other ItemsThe licensee should provide the following additional information:*a brief discussion of contingency costs and the methods used to calculate them*a brief discussion of how inflation is accounted for in the cost estimate
  • a schedule for the accumulation and expenditure of decommissioning funds
  • an estimate of the cost to support safe storage, if it becomes necessary
  • labor requirements (person-years) and labor costs by time period; Table 9 providesa suggested formatTable Labor Requirements and Labor CostsLabor Requirements (person-yrs) and Labor Costs(Estimate-Year $millions)Phase 1Phase 2Phase 3Phase 4Total(LaborReq)(LaborCost)(LaborReq)(LaborCost)(LaborReq)(LaborCost)(LaborReq)(LaborCost)(LaborReq)(LaborCost)Decommissioning CrewsManagement/Support Staff Total 1.202-164.LICENSE TERMINATION COST ESTIMATEAccording to 10 CFR 50.82(a)(9)(ii)(F), a licensee must submit an "updated site-specific estimateof remaining decommissioning costs" as part of an LT According to 10 CFR 50.82(a)(9)(i),

the licensee must submit the LTP at least 2 years before termination of the licens The estimated remaining costs of decommissioning must be compared with the present funds set aside for decommissionin The financial assurance instrument required by 10 CFR 50.75 must be funded at least to the amount of the cost estimat If there is a deficit in present funding, the LTP must indicate the means to ensure that adequate funds will be available to complete the decommissionin Licensees should be aware that 10 CFR 50.82(a)(8)(i)(B) requires that expenditures are not to 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 aris Information on the preparation of an LTP may be found in Regulatory Guide 1.179, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors" (Ref. 10), and NUREG-1700, "Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans" (Ref. 11).The cost estimate portion of the LTP is an updated version of the site-specific estimate thatthe licensee previously submitted to the NR The LTP cost estimate should contain refined estimates of the remaining decommissioning activities, including the cost to remediate surface and groundwater, soil contamination, waste transportation and disposal costs, and license termination survey cost If the site is to be released for restricted use, the LTP cost estimate should also include estimated costs for controls and a description of the financial assurance mechanisms used to ensure the availability of funds when they are neede Cost estimates for restricted release or entombment will be handled on a case-by-case basis.5.FORMAT OF THE DECOMMISSIONING COST ESTIMATESGraphic presentations such as charts, drawings, maps, diagrams, sketches, and tables should beemployed when the information may be presented more adequately or conveniently by such mean Care should be taken to ensure that all information so presented is legible in the original documents and reproduced copie Also, ensure that symbols are defined and scales are not reduced to the extent that visual aids are necessary to interpret items of informatio These graphic presentations should be located in the section where the subject matter is primarily addresse References should appear as footnotes on the page they were discussed or at the end of each chapter.Decommissioning cost estimates may be submitted to the NRC in electronic or paper format,as described in Regulatory Issue Summary (RIS) 2001-05, "Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM" (Ref.12).

1.202-175.1Physical Format5.1.1Paper Size*Text pages: 81/2 x 11 inches.*Drawings and graphics: 81/2 x 11 inche A larger size is acceptable provided the finished copy,when folded, does not exceed 81/2 x 11 inches.5.1.2Paper Stock and InkUse suitable quality in substance, paper color, and ink density for handling and reproduction.5.1.3Page MarginsA margin of no less than 1 inch should be maintained on the top, bottom, and binding sideof all pages submitted.5.1.4Printing*Composition: Text pages should be single spaced.*Type Face and Style: Should be suitable for image-copying equipment, including computerscanning.*Reproduction: Copies may be mechanically or photographically reproduced.5.1.5BindingNo requirements.5.1.6Page NumberingPages should be numbered sequentially.5.1.7Procedures for Updating or Revising PagesData and text should be updated or revised by replacing page The changed or revised portionof each page should be highlighted by a "change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margi The line should be of the same length as the portion actually changed.All pages submitted to update, revise, or add information to the report should show the dateof change and a change or amendment numbe A guide page listing the pages to be inserted and/or removed should accompany the revised page When major changes or additions are made, a revised table of contents should be provided.5.1.8Exceptions to Physical SpecificationsSubmittals may be made over the Internet or electronically; for guidance, see Regulatory IssueSummary 2001-05 (Ref. 12).

1Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC20402-9328 (telephone (202) 512-1800); or from the National Technical Information Service (NTIS) by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; telephone (703) 487-465 Copies areavailable for inspection or copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike,Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737or (800) 397-4209; fax (301) 415-3548; email is PDR@nrc.gov.2Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of chargeby writing the Reproduction and Distribution Services, USNRC, Washington, DC 20555-0001, or by fax to (301) 415-2289, or by email to DISTRIBUTION@nrc.go Active guides may also be purchased from the NationalTechnical Information Service on a standing order basi Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161; telephone (703) 487-4650; online at http://www.ntis.go Copies ofactive and draft guides are available for inspection or copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555;telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.1.202-18REFERENCES1.U.S. Nuclear Regulatory Commission, "Final Generic Environmental Impact Statementon Decommissioning of Nuclear Facilities," NUREG-0586, Supplement 1, October 2002.12.U.S. Nuclear Regulatory Commission, "Standard Format and Content for Post-ShutdownDecommissioning Activities Report," Regulatory Guide 1.185, August 2000.23.U.S. Department of Labor, Bureau of Labor Statistics, Monthly Labor Review,currently Table 24, updated periodically.4.U.S. Department of Labor, Bureau of Labor Statistics, Producer Price Index, currently Table 6,updated periodically.5.U.S. Nuclear Regulatory Commission, "Report on Waste Disposal Charges: Changes inDecommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities," NUREG-1307,Rev. 9, September 2000.16.R.I. Smith, G J. Konzek, and W.E. Kennedy, Jr., "Technology, Safety and Costs ofDecommissioning a Reference Pressurized-Water Reactor Power Station," NUREG/CR-0130 (Prepared for the U.S. NRC by Pacific Northwest Laboratory, Richland, Washington), June 1978 (Addendum 1, July 1979; Addendum 2, July 1983; Addendum 3, September 1984; Addendum 4, July 1988).17.H.D. Oak et al., "Technology, Safety and Costs of Decommissioning a Reference Boiling-WaterReactor Power Station," NUREG/CR-0672 (Prepared for the U.S. NRC by Pacific Northwest Laboratory, Richland, Washington), June 1980 (Addendum 1, July 1983; Addendum 2, September 1984; Addendum 3, July 1988; Addendum 4, December 1990).18.G.J. Konzek et al., "Revised Analyses of Decommissioning for the Reference Pressurized-WaterReactor Power Station," NUREG/CR-5884 (Prepared for the U.S. NRC by Pacific Northwest Laboratory, Richland, Washington), November 1995.19.R.I. Smith et al., "Revised Analyses of Decommissioning for the Reference Boiling-WaterReactor Power Station," NUREG/CR-6174 (Prepared for the U.S. NRC by Pacific Northwest National Laboratory, Richland, Washington), July 199 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of chargeby writing the Reproduction and Distribution Services, USNRC, Washington, DC 20555-0001, or by fax to (301) 415-2289, or by email to DISTRIBUTION@nrc.go Active guides may also be purchased from the NationalTechnical Information Service on a standing order basi Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161; telephone (703) 487-4650; online at http://www.ntis.go Copies ofactive and draft guides are available for inspection or copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555;telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.4Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC20402-9328 (telephone (202) 512-1800); or from the National Technical Information Service (NTIS) by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; telephone (703) 487-465 Copies areavailable for inspection or copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike,Rockville, MD; the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737or (800) 397-4209; fax (301) 415-3548; email is PDR@nrc.gov.5The NRC's regulatory issue summaries are available electronically on the agency's public Web siteat http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issue Copies are also available for inspectionor copying for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD;the PDR's mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209;fax (301) 415-3548; email PDR@nrc.gov.1.202-1910.U.S. Nuclear Regulatory Commission, "Standard Format and Content of License TerminationPlans for Nuclear Power Reactors," Regulatory Guide 1.179, January 1999.311.U.S. Nuclear Regulatory Commission, "Standard Review Plan for Evaluating Nuclear PowerReactor License Termination Plans," NUREG-1700, April 2000.412.U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2001-05, "Guidance onSubmitting Documents to the NRC by Electronic Information Exchange or on CD-ROM,"

January 25, 200 .202-20 IMPLEMENTATIONThe purpose of this section is to provide information to applicants and licensees regardingthe NRC staff's plans for using this guid No backfitting is intended or approved in connection withthe issuance of this guide.Except when an applicant or licensee proposes or has previously established an acceptablealternative method for complying with specified portions of the NRC's regulations, the methods described in this guide will be used in evaluating (1) submittals for licensing-basis documents, and (2) revisions or updates to the decommissioning cost estimates that are submitted in accordance with applicable regulations.REGULATORY ANALYSISThe NRC staff did not prepare a separate regulatory analysis for this regulatory guide. The regulatory analysis prepared for the amendments to 10 CFR Parts 2, 50, and 51,

"Decommissioning of Nuclear Power Reactors," which the NRC issued on July 29, 1996 (61 FR 39278),

provides the regulatory basis for this guide and examines the costs and benefits associated with implementing the rule as described in this guid A copy of this regulatory analysis is available for inspection and copying (for a fee) at the NRC's Public Document Room (PDR), which is located at 11555 Rockville Pike, Rockville, Marylan The PDR's mailing address is USNRC PDR,Washington, DC 20555-000 The PDR can also be reached by telephone at (301) 415-4737or (800) 397-4205, by fax at (301) 415-3548, and by email to PDR@nrc.gov.BACKFIT ANALYSISThis regulatory guide describes a voluntary method that the NRC staff considers acceptablefor submitting the decommissioning cost estimates required by amendments to 10 CFR Parts 2, 50, and 51, "Decommissioning of Nuclear Power Reactors," which the NRC issued on July 29, 1996 (61 FR 39278). During the rulemaking process associated with those amendments, the NRC staff carefully considered the reasons for collecting the required informatio Compliance with this regulatory guide is not a requirement, and a licensee may choose this or another method to achieve compliance with these rule Thus, this regulatory guide does not require a backfit analysis, as described in 10 CFR 50.109(c), because it does not impose a new or amended provision in the NRC's rules, does not present a regulatory staff position that interprets the NRC's rules in a manner that is either new or different from a previous staff position; and does not require the modification of or addition to the systems, structures, components, or design of a facility, or the procedures or organization required to design, construct, or operate a facility.


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