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| Rod McCullum |
In November 2015, the Nuclear Regulatory Commission (NRC) issued an Advanced Notice of Proposed Rulemaking (ANPR) to consider potential new regulations governing the decommissioning of nuclear power reactors. This action came at a time of increasing interest in decommissioning as many reactors are reaching the end of their operating lifespan. Yet, while interest in this topic may be peaking, it is certainly not a new subject. Industry and NRC have, over several decades, established a proven track record of safely taking power reactors out of service. Interest in new regulations at this time stems mainly from a desire to improve efficiency – and not from any identified safety need. This interest will be a topic of discussion at NRC’s upcoming Regulatory Information Conference (RIC), with an entire session on Thursday morning devoted to the potential rulemaking.
In the United States, 11 power reactors have already completed decommissioning. At these sites, radioactive systems and structures have been decontaminated and dismantled, with any remaining low-level radioactive waste shipped off to disposal sites. High-level radioactive waste, in the form of used nuclear fuel, is transferred to independent storage installations where it is kept safe and secure in robust concrete and steel dry cask storage systems. In most cases, dry cask storage is located at the site where the reactor used to be until a permanent disposal facility can be developed. NRC’s regulations have provided outstanding public health and safety protection at these sites. In every case, decommissioning was completed in a safe and environmentally sound manner with funds that had been previously set aside by the owners of the plants when they were operating (as required by NRC financial assurance regulations).
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| The recently shutdown Crystal River 3 Reactor prepares for decommissioning. |
Between 1998 and 2012, no U.S. power reactors reached the end of lifespan. But in the last three years, five reactors have shut down. While NRC’s regulations for decommissioning had not changed during this time, the regulations for many other things like security and emergency preparedness did – becoming much more complex in the wake of the events of September 11, 2001 and the 2011 Fukushima accident. These changes caused the transition from operating plant to decommissioning status to become more difficult. Plant owners now must seek multiple exemptions from operating plant requirements before they can implement plant changes reflecting the fact that many systems, processes, and procedures are no longer operational. These exemptions typically take 12 to 18 months to obtain at a cost of over $1.5 million and, while exemption requests are under review at NRC, plant owners typically incur over $1 million per month in unnecessary compliance costs.
Ironically, concerns about increased regulatory workload and costs when shutting down nuclear reactors come at a time when NRC is being called upon to become a leaner and more efficient regulator as the number of operating reactors declines (three more reactors are scheduled to shut down by 2020). The proposed rulemaking is being offered as a potential solution to this problem that could make the decommissioning transition more efficient. But a rulemaking could also be a costly and time consuming process itself. A variety of perspectives on the potential rulemaking are likely to be aired in Thursday’s RIC session. It should be interesting.
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