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PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France EPRI Guidance for Transition from Operations to Decommissioning Richard McGrath* Richard Reid Electric Power Research Institute 3420 Hillview Ave Palo Alto, California 94504 *corresponding author: [email protected] Keywords: decommissioning, transition, regulatory framework Abstract A wide range of key activities are necessary after permanent shutdown of a nuclear power plant before active dismantlement of the plant can begin. This period is typically referred to as the transition period. In some cases these activities are prescribed by regulation and in others they may be more practically driven or even optional. In either case, planning for transition activities should optimally take place prior to final shutdown. Additionally, execution of some transition period activities, such as filing required regulatory submittals, may be performed prior to plant shut down. In addition to general transition period activities such as defueling, management of operational wastes, fulfilling regulatory requirements and changes to plant technical specifications, there are a number of optional activities that may have a long-range impact on future decommissioning activities. This includes activities such as the timing of staff reductions and performance of chemical decontamination. EPRI is nearing completion of a project to develop guidance for transitioning a nuclear power plant to decommissioning. This project includes the following elements: A review of required and recommended transition period activities. For countries where a clear regulatory framework exists, this includes country-specific requirements; A review of pending regulatory activities in the US and other countries where there is currently no clear regulatory framework for transitioning to decommissioning; A summary of activities that have been performed during the transition period for past and current decommissioning sites, as well as current sites that are actively planning decommissioning activities; and Guidance for development of a transition plan for changing from an operational to decommissioning status. Informed planning of the transition period activities will provide immediate benefits in reducing costs and minimizing the duration of the transition period, as well as longer-term benefits throughout plant decommissioning. Although the EPRI guidance will provide a greater benefit for plants that will shut down in the near future, recently shut down plants and plants currently in safe storage may also benefit from consideration of industry-wide guidance.

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Page 1: EPRI Guidance for Transition from Operations to

PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

EPRI Guidance for Transition from Operations to Decommissioning

Richard McGrath* Richard Reid

Electric Power Research Institute

3420 Hillview Ave

Palo Alto, California 94504

*corresponding author: [email protected]

Keywords: decommissioning, transition, regulatory framework

Abstract

A wide range of key activities are necessary after permanent shutdown of a nuclear power plant

before active dismantlement of the plant can begin. This period is typically referred to as the

transition period. In some cases these activities are prescribed by regulation and in others they

may be more practically driven or even optional. In either case, planning for transition activities

should optimally take place prior to final shutdown. Additionally, execution of some transition

period activities, such as filing required regulatory submittals, may be performed prior to plant

shut down.

In addition to general transition period activities such as defueling, management of operational

wastes, fulfilling regulatory requirements and changes to plant technical specifications, there are

a number of optional activities that may have a long-range impact on future decommissioning

activities. This includes activities such as the timing of staff reductions and performance of

chemical decontamination.

EPRI is nearing completion of a project to develop guidance for transitioning a nuclear power

plant to decommissioning. This project includes the following elements:

A review of required and recommended transition period activities. For countries where a

clear regulatory framework exists, this includes country-specific requirements;

A review of pending regulatory activities in the US and other countries where there is currently no clear regulatory framework for transitioning to decommissioning;

A summary of activities that have been performed during the transition period for past and current decommissioning sites, as well as current sites that are actively planning

decommissioning activities; and

Guidance for development of a transition plan for changing from an operational to

decommissioning status.

Informed planning of the transition period activities will provide immediate benefits in reducing

costs and minimizing the duration of the transition period, as well as longer-term benefits

throughout plant decommissioning. Although the EPRI guidance will provide a greater benefit

for plants that will shut down in the near future, recently shut down plants and plants currently in safe storage may also benefit from consideration of industry-wide guidance.

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PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

Introduction and Background

Transition Period Regulations in the US

Unlike some other countries, the US does not have a formal period for transitioning from

operating to decommissioning. The decommissioning process in the US is structured around

several regulatory submittals, including:

Certification of Permanent Cessation of Operations and Permanent Removal of Fuel

Post Shutdown Decommissioning Activities Report (PSDAR)

Site-Specific Decommissioning Cost Estimate

Revisions to Plant Licensing Design Basis Documents

Defueled Safety Analysis Report

These submittals have been made by the power plant sites currently in transition in the US, each

with multiple exemption requests (NRC regulation concerning each exemption also shown) for:

Emergency Preparedness (Part 50, Appendix E)

Security Plan and Procedures (CFR Part 73)

Use of Decommissioning Trust Fund (CFR 50.82)

Insurance and Financial Protection (CFR 50.54 an Part 140)

Submittal of these documents permits utilities to access portions of the decommissioning trust

fund and permits utilities to begin certain dismantling activities.

To streamline the decommissioning licensing process, the NRC is considering rulemaking to

establish new regulations to replace the current process of using exemptions such as those listed

above. The following list of NRC notices describes the NRC conclusions concerning this

proposed rulemaking:

SRM SECY-14-0066, Commission directed staff to report its views on the need for an integrated rulemaking for decommissioning.

SRM SECY-14-0118, Commission directed staff to complete rulemaking in 2019.

SECY-15-0014, NRC Staff Responded to both SRMs and provided high-level schedule and resource needs.

The commission requested the NRC staff to address the following issues in the rulemaking:

Graded approach to emergency preparedness

o Fuel in fuel pool

o Fuel in dry storage

Lessons Learned

NRC approval of Post-Shutdown Decommissioning Activity Report

Maintaining three existing decommissioning options and associated timeframes

Role of state and local governments and non-governmental stakeholders

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PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

The NRC has established a goal for the completion of this rulemaking process in 2019. The NRC

will be seeking public participation and comment throughout the rulemaking process.

Experiences in Countries outside the US

In many cases in Europe, dismantlement activities have not been started until all of the spent fuel

is removed from the spent fuel pool. Using optimized canister loading which mixes freshly off-

loaded fuel with older fuel with lower heat output, it may still be as long as 4 to 5 years after the

final shutdown of the plant until all spent fuel can be moved to dry fuel storage.

Canada, France, Germany, Spain and Sweden allow preparatory activities under the operating

license during the Transition Period although in the case of France some of them are subject to

French Safety Authority information or authorization. These preparatory activities are aimed at

reducing the risks or contributing to the preparation of the dismantling phase include: fuel

removal from site, radiological characterization, systems decontamination, management of

radioactive waste from the operational phase, replacement of systems and components and

deactivation of equipment not required. The United Kingdom allows very limited

decommissioning activity during the Transition Period.

Spain

Only preparatory activities such as full system chemical decontamination and radiological

characterization work were performed at the José Cabrera plant before all the spent fuel had been

moved out of the spent fuel pool and into dry fuel storage. After this relocation had been

accomplished, the plant operating license was transferred to ENRESA, with approval by the

Spanish regulator to begin dismantlement activities.

Germany

The major document governing decommissioning of nuclear power plants in Germany is the

Atomic Energy Act (AtG). This document states that after permanent shutdown of a plant, all

normal requirements and regulations still apply, with the exception of those concerning power

generation. Further, this document states that the normal plant operating licenses still apply

during decommissioning. Since decommissioning is typically not covered by the operating

license, after permanent shutdown, German plants cannot begin major decommissioning

activities (i.e., dismantling) until a new decommissioning-specific license is obtained. Therefore,

after permanent shutdown, German plants enter a “post-operational phase” (i.e., a transition

phase). This post-operational phase continues until the plant has applied for and received a

decommissioning license from the appropriate Länder1 authority.

During the post-operational phase, the normal plant operating license is still in effect and thus

German plants may still conduct activities covered by the normal operating license. These

activities include:

Defueling of nuclear fuel from the reactor

1 The Länder are the 16 Federal States of Germany.

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PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

Loading of nuclear fuel into storage containers and storage in the onsite interim storage facilities (similar to ISFSI in US plants)

Utilization of radioactive substances and disposal of operational wastes

Decontamination of the facility and systems

Sampling of systems and components

Dismantling of non-nuclear facilities (e.g., office buildings, parking lots, etc.)

Switzerland

The Mühleberg NPP, a BWR with the Spent Fuel Pool located in the Reactor Building is

scheduled for permanent shutdown in 2019. This will be the first power plant to be

decommissioned in Switzerland. Regulations and regulatory guidance for the transition from

operations to active decommissioning is being developed in Switzerland.

Discussion

A wide range of key activities are necessary after permanent shutdown of a nuclear power plant

before active dismantlement of the plant can begin. For example, defueling, management of

operational wastes, fulfilling regulatory requirements, staffing plan, changes to plant technical

specifications and full-system chemical decontamination to name a few. In some cases these

activities are prescribed by regulation and in others they may be more practically driven or even

optional. Planning for transition should optimally take place prior to final shutdown and

execution of some transition period activities, such as filing required regulatory submittals, may

be performed prior to plant shutdown.

An EPRI project is in progress which will be developing guidance for transitioning from

operational to decommissioning status. An overview and the goals of the project are:

Compile country-specific transition period regulations

Countries will be selected to provide a wide range of regulations (i.e., structured vs. unstructured transition)

Compile industry transition period operating experience

Identify activities that can be performed/planned for before shutdown

Identify long-lead activities that should be prioritized

Identify cost-saving activities that should be performed early after shutdown

Provide guidance for the development of a plan to transition from operational to decommissioning status

Motivation for the EPRI Project

The cost of decommissioning is highly influenced by overall staffing costs, which is related to

the overall length of decommissioning. Figure 1 from EPRI report # 1023025, show that staffing

costs make up, on the average, 43.5 % of the total decommissioning costs in the US. It is

anticipated that the guidance developed in this EPRI work will help shorten the length of the

transition period, and thus shorten the overall length and cost of decommissioning.

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PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

Figure 1: Breakdown of Decommissioning Costs in the US

Figure 2: Status of Permanently Shutdown Plants in the US

Reactor TypeCommercial

OperationShutdown

Years

OperationalStatus a Fuel Onsite

GE VBWR BWR Oct-57 Dec-63 6.1 SAFSTOR No

Pathfinder Superheat BWR Jul-66 Sep-67 1.1 License Terminated No

Saxton PWR Mar-67 May-72 5.2 License Terminated No

Fermi 1 Fast Breeder Aug-66 Sep-72 6.1 SAFSTOR No

Indian Point 1 PWR Oct-62 Oct-74 12.1 SAFSTOR Yes

Peach Bottom 1 HTGR Jun-67 Oct-74 7.4 SAFSTOR No

Humboldt Bay 3 BWR Aug-63 Jul-76 12.9 DECON Yes

Dresden 1 BWR Jul-60 Oct-78 18.3 SAFSTOR Yes

Three Mile Island 2 PWR Dec-78 Mar-79 0.2 SAFSTOR b No

LaCrosse BWR Nov-69 Apr-87 17.5 DECON Yes

Millstone 1 BWR Mar-71 Jul-88 17.4 SAFSTOR Yes

Rancho Seco PWR Apr-75 Jun-89 14.2 ISFSI Only c Yes

Shoreham BWR Aug-86 Jun-89 2.9 License Terminated No

Fort St. Vrain HTGR Jul-79 Aug-89 10.1 ISFSI Only Yes

Yankee Rowe PWR Jul-61 Oct-91 30.3 ISFSI Only Yes

Trojan PWR May-76 Nov-92 16.5 ISFSI Only Yes

San Onofre 1 PWR Jan-68 Nov-92 24.9 DECON Yes

Zion 2 PWR Sep-74 Sep-96 22.0 DECON Yes

Maine Yankee PWR Dec-72 Dec-96 24.0 ISFSI Only Yes

Connecticut Yankee PWR Jan-68 Dec-96 29.0 ISFSI Only Yes

Zion 1 PWR Dec-73 Feb-97 23.2 DECON Yes

Big Rock Point BWR Mar-63 Aug-97 34.4 ISFSI Only Yes

Crystal River 3 PWR Mar-77 Feb-13 36.0 SAFSTOR Yes

Kewaunee PWR Jun-74 May-13 38.9 SAFSTOR Yes

San Onofre 2 PWR Aug-83 Jun-13 29.9 DECON Yes

San Onofre 3 PWR Apr-84 Jun-13 29.2 DECON Yes

Vermont Yankee BWR Nov-72 Dec-14 29.2 SAFSTOR Yes

Decomissioning Completed

c) Some low-level waste is also stored at Rancho Seco in addition to its ISFSI.

a) ISFSI = Independent spent fuel storage installation, which is a stand-alone facility within the plant constructed for the

interim storage of spent nuclear fuel. "ISFSI Only" means the plant license has been reduced to include only the ISFSI.

b) TMI 2 is in a post-defueling monitored storage (PDMS) state, where the plant is in SAFSTOR but the fuel has been removed.

Page 6: EPRI Guidance for Transition from Operations to

PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

US Transition Period Experience

Figure 2 show the status of the permanently shutdown plant in the US. The EPRI Transition

Period Guidance Report will summarize the experiences at the ten plant sites outlined in purple.

Additionally, although the Oyster Creek plant has not been shutdown, transition plans have been

made for that plant.

Figure 3: Transition & Early Decommissioning Activities at the Connecticut Yankee Plant

Figure 3 shows the transition period and early decommissioning activities at the Connecticut

Yankee plant. Although the transition was almost 3 years, this period was extended somewhat by

an NRC required improvement of the Health Physics Department. The experience for San

Onofre Units 2 & 3 is that similar transition period activities were accomplished in 2 years.

Page 7: EPRI Guidance for Transition from Operations to

PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

Figure 4: Exelon Nuclear Management Model – Transition Period Timeline

Exelon operates a fleet of nuclear power plants in the US and has recognized the importance of

early decommissioning planning. Figure 4 illustrates the Exelon management timeline for

performance of decommissioning planning activities and the preparation of decommissioning

licensing documents. It is noteworthy that this time line starts 5 years before the planned

shutdown of a power plant.

The following is a listing of typical transition period activities in the US:

Cost estimating

Preparation/submittal of regulatory submittals

Systems, Structures and Component (SSCs) Rr-categorization

Revised Technical Specifications

Cold and Dark Program (repower certain systems)

Project Management Model

Re-design Work Control Process

Develop Communications Plan o Both internal and external

Human Resources o Retention of key staff

o Labor agreement impacts

Page 8: EPRI Guidance for Transition from Operations to

PREDEC 2016: EPRI Guidance for Transition from Operations to Decommissioning, February 16-18, Lyon, France

o Relocation of other staff

Perform Historical Site Assessment and Initial Site Characterization

Disposal of Operational (Legacy) Wastes

Fuel Building modifications to isolate from other plant systems

Certified Fuel Handler Program

Transfer of spent fuel to dry casks o Design of the Dry Fuel Storage System

o Building and system modifications to support the Dry Fuel Storage System

o Fabrication of Dry Fuel Storage Canisters, Storage Cells and other related equipment

o Design and construction of the ISFSI

Dismantling of non-nuclear facilities

Upgrade plant/infrastructure (e.g. rail) to facilitate removal of wastes

Full System Chemical Decontamination

Hot Spot Reduction

Asbestos and flammable materials removal

Preparation for post-transition decommissioning activities o Major component removal planning

o Reactor Vessel and Internals Segmentation planning

o Balance of plant dismantlement

Summary and Conclusions

Informed planning of the transition period activities will provide immediate benefits in reducing

costs and minimizing the duration of the transition period, as well as longer-term benefits

throughout plant decommissioning. EPRI is nearing completion of a project to develop guidance

for transitioning a nuclear power plant to decommissioning. In addition to summarizing

experiences with completed transition periods in the US, The EPRI Transition Period Guidance

Report will:

Continue to compile transition period operating experience

Summarize German, French, Spanish, and Swiss transition period regulations

Evaluate regulations and operating experience to develop guidance for transitioning from

operating to decommissioning

The EPRI Transition Period Guidance Report is scheduled to be completed in the middle of

2016.

References

EPRI Report #1023025, Decommissioning Experiences and Lessons Learned: Decommissioning

Costs, 2011

EPRI Report # 1000093, Preparation for Decommissioning – The Oyster Creek Experience, June

2000

Page 9: EPRI Guidance for Transition from Operations to

© 2016 Electric Power Research Institute, Inc. All rights reserved.

Michael Snyder Senior Technical Leader

Richard McGrath Principal Technical Leader

Richard Reid, PhD Program Manager

PREDEC 2016: International Symposium on Preparation for Decommissioning

16-18 February 2016, Lyon, France

EPRI Project: Guidance

for Transition from

Operations to

Decommissioning

Page 10: EPRI Guidance for Transition from Operations to

2 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Overview

US Transition Period Regulations

EPRI Transition Project

Experiences

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3 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Decommissioning Technology Program Membership

EDF - France

ENRESA -

Spain

E.On - Germany

Electrabel - Belgium

Chubu, TEPCO -

Japan

TaiPower - Taiwan

KHNP – S. Korea

Southern California

Edison, Pacific Gas

and Electric,

Dominion, Exelon -

US

Page 12: EPRI Guidance for Transition from Operations to

4 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Current US Decommissioning Transition

Period Regulations

Page 13: EPRI Guidance for Transition from Operations to

5 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Source: US NRC Website

5

Power Reactors Decommissioning Status

D

S

I

T

Four Sites

Twelve Sites

Seven Sites

Three Sites

Page 14: EPRI Guidance for Transition from Operations to

6 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Plants in Transition

Unplanned Reactor Shutdowns

– Crystal River Unit 3 - Crystal River, Florida (February 2013)

– Kewaunee Power Station - Kewaunee Wisconsin (May 2013)

– San Onofre Nuclear Generating Station, Units 2 & 3 - San

Clemente, California (June 2013)

– Vermont Yankee Nuclear Power Station - Vernon, Vermont

(December 2014)

Planned Reactor Shutdown

– Fitzpatrick Nuclear Station - Oswego, New York (Announced

Shutdown for 2017)

– Oyster Creek Nuclear Generating Station - Forked River, New

Jersey (Announced Shutdown for 2019)

– Pilgrim Nuclear Power Station - Plymouth, MA (Announced

Shutdown for 2019)

Page 15: EPRI Guidance for Transition from Operations to

7 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Regulations

The US does not have a formal period for transitioning from operating to decommissioning, unlike some other countries

The decommissioning process in the US is structured around several regulatory submittals, including: – Certification of Permanent Cessation of Operations

– Post Shutdown Decommissioning Activities Report (PSDAR)

– Site-Specific Decommissioning Cost Estimate

– Revisions to Plant Licensing Design Basis Documents

Defueled Safety Analysis Report

Submittals have been made by the four sites currently in transition each with multiple exemption requests for

– Emergency Preparedness (Part 50, Appendix E)

– Security Plan and Procedures (CFR Part 73)

– Use of Decommissioning Trust Fund (CFR 50.82)

– Insurance and Financial Protection (CFR 50.54 an Part 140)

Submittal of these documents permits utilities to access their decommissioning fund and to begin certain dismantling activities

Page 16: EPRI Guidance for Transition from Operations to

8 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Nuclear Regulatory Commission Direction

on Decommissioning Rulemaking

SRM SECY-14-0066, Commission directed staff to report

its views on the need for an integrated rulemaking for

decommissioning.

SRM SECY-14-0118, Commission directed staff to

complete rulemaking in 2019.

SECY-15-0014, NRC Staff Responded to both SRMs and

provided high-level schedule and resource needs.

Page 17: EPRI Guidance for Transition from Operations to

9 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Scope of NRC Decommissioning

Rulemaking

The Commission Requested Staff to Address the Following Issues in the Rulemaking, as Discussed in SECY-00-0145: – Graded Approach to Emergency Preparedness;

Fuel in pool

Fuel in Dry Storage

– Lessons Learned;

– NRC Approval of Post-Shutdown Decommissioning Activity Report;

– Maintaining Three Existing Decommissioning Options (i.e., SAFSTOR, DECON, ENTOMB) and Associated Timeframes;

– Role of State and Local Governments and Non-Governmental Stakeholders;

– Other Issues Deemed Relevant by Staff.

Page 18: EPRI Guidance for Transition from Operations to

10 © 2016 Electric Power Research Institute, Inc. All rights reserved.

NRC Milestones Associated with

Decommissioning Rulemaking

Major Milestones

– Advance Notice of Proposed Rulemaking: Request for Comment

(published November 2015)

– Regulatory Basis

– Proposed Rule/Draft Regulatory Guidance

– Final Rule/Final Regulatory Guidance (2019)

Public Participation

Page 19: EPRI Guidance for Transition from Operations to

11 © 2016 Electric Power Research Institute, Inc. All rights reserved.

EPRI Transition Project

Page 20: EPRI Guidance for Transition from Operations to

12 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Background

A wide range of key activities are necessary after permanent shutdown of a nuclear power plant before active dismantlement of the plant can begin

– For example, defueling, management of operational wastes, fulfilling regulatory requirements, staffing plan, changes to plant technical specifications, full-system chemical decontamination, etc.

In some cases these activities are prescribed by regulation and in others they may be more practically driven or even optional

Planning for transition should optimally take place prior to final shutdown and execution of some transition period activities, such as filing required regulatory submittals, may be performed prior to plant shutdown

In the EPRI project, guidance is being developed for transitioning from operational to decommissioning status

Page 21: EPRI Guidance for Transition from Operations to

13 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Goals of Project / Project Overview

Compile country-specific transition period regulations

– Countries will be selected to provide a wide range of regulations

(i.e., structured vs. unstructured transition)

Compile industry transition period operating experience

– Identify activities that can be performed / planned for before shutdown

– Identify long-lead activities that should be prioritized

– Identify cost-saving activities that should be performed early after

shutdown

Provide guidance for the development of a plan to transition

from operational to decommissioning status

Page 22: EPRI Guidance for Transition from Operations to

14 © 2016 Electric Power Research Institute, Inc. All rights reserved.

Motivation for Project

The cost of decommissioning is highly influenced by overall

staffing costs, which is related to the overall length of

decommissioning

It is anticipated that the guidance developed in this work will

help shorten the length of the transition period, and thus

shorten the overall length and decrease the cost for

decommissioning

Ref. EPRI 1023025

Page 23: EPRI Guidance for Transition from Operations to

15 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Period Experience Selected Plants

Recent transition period

experiences from the 11

plant sites outlined in

purple will be summarized

Oyster Creek experience

will also be summarized

– Not shutdown, but

transition plans have

been made

Distribution of selected

experiences

Reactor TypeCommercial

OperationShutdown

Years

OperationalStatus a Fuel Onsite

GE VBWR BWR Oct-57 Dec-63 6.1 SAFSTOR No

Pathfinder Superheat BWR Jul-66 Sep-67 1.1 License Terminated No

Saxton PWR Mar-67 May-72 5.2 License Terminated No

Fermi 1 Fast Breeder Aug-66 Sep-72 6.1 SAFSTOR No

Indian Point 1 PWR Oct-62 Oct-74 12.1 SAFSTOR Yes

Peach Bottom 1 HTGR Jun-67 Oct-74 7.4 SAFSTOR No

Humboldt Bay 3 BWR Aug-63 Jul-76 12.9 DECON Yes

Dresden 1 BWR Jul-60 Oct-78 18.3 SAFSTOR Yes

Three Mile Island 2 PWR Dec-78 Mar-79 0.2 SAFSTOR b No

LaCrosse BWR Nov-69 Apr-87 17.5 DECON Yes

Millstone 1 BWR Mar-71 Jul-88 17.4 SAFSTOR Yes

Rancho Seco PWR Apr-75 Jun-89 14.2 ISFSI Only c Yes

Shoreham BWR Aug-86 Jun-89 2.9 License Terminated No

Fort St. Vrain HTGR Jul-79 Aug-89 10.1 ISFSI Only Yes

Yankee Rowe PWR Jul-61 Oct-91 30.3 ISFSI Only Yes

Trojan PWR May-76 Nov-92 16.5 ISFSI Only Yes

San Onofre 1 PWR Jan-68 Nov-92 24.9 DECON Yes

Zion 2 PWR Sep-74 Sep-96 22.0 DECON Yes

Maine Yankee PWR Dec-72 Dec-96 24.0 ISFSI Only Yes

Connecticut Yankee PWR Jan-68 Dec-96 29.0 ISFSI Only Yes

Zion 1 PWR Dec-73 Feb-97 23.2 DECON Yes

Big Rock Point BWR Mar-63 Aug-97 34.4 ISFSI Only Yes

Crystal River 3 PWR Mar-77 Feb-13 36.0 SAFSTOR Yes

Kewaunee PWR Jun-74 May-13 38.9 SAFSTOR Yes

San Onofre 2 PWR Aug-83 Jun-13 29.9 DECON Yes

San Onofre 3 PWR Apr-84 Jun-13 29.2 DECON Yes

Vermont Yankee BWR Nov-72 Dec-14 29.2 SAFSTOR Yes

Decomissioning Completed

c) Some low-level waste is also stored at Rancho Seco in addition to its ISFSI.

a) ISFSI = Independent spent fuel storage installation, which is a stand-alone facility within the plant constructed for the

interim storage of spent nuclear fuel. "ISFSI Only" means the plant license has been reduced to include only the ISFSI.

b) TMI 2 is in a post-defueling monitored storage (PDMS) state, where the plant is in SAFSTOR but the fuel has been removed.

Number Description

4 PWRs that have completed decommissioning

3 PWRs that recently entered SAFSTOR

1 PWR that recently entered DECON from a period of SAFSTOR

1 PWR that recently entered DECON from operation

1 BWR that has completed decommissioning

1 BWR that has developed decommissioning plans before shutdown

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16 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Period Experience Example – Connecticut Yankee Transition Period Timeline

Page 25: EPRI Guidance for Transition from Operations to

17 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Period Experience Example – SONGS Unit 2/3 Transition (2 years) & Decon Period

Timeline

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18 © 2016 Electric Power Research Institute, Inc. All rights reserved.

*Initial Plant Only – Management Model Addition

** PSDAR Submission Tied to Strategy Approvals; PSDAR Does Not Require

NRC Approval, DCE (Decommissioning Cost Estimate) for PSDAR plan will

be submitted with or shortly after PSDAR submittal. No approval required for

DCE.

US Transition Period Experience Example – Exelon Nuclear Mgmt. Model Transition Period Timeline

1

8

Develop Scoping & Screening

Process

Implement Scoping & Screening

Process

Identify, Develop & Submit Regulatory

Actions

Develop Modification Packages & Work Packages

Develop Decommissioning Management

Model *

Pro-forma Implement Regulatory Approvals

Gather Information & Implement Decision Making

Framework

Develop & Submit PSDAR & DCE

**

Implement Governance Changes *

Implement Commercial Aspects of Strategy

(ie., bids)

Review & Approve Strategic Plan

Develop Decision Making Framework

Identify key Decisions

T – 5 yrs.

Staff Corporate Decommissioning Transition Manager

Position

Identify Site Decommissioning Lead

Identify Scoping & Screening

Team

Decommissionin

g Announcement

Shutdown

Date

T – 4 yrs T – 3

yrs.

T – 2

yrs. T – 1

yrs.

Identify Mod

Resources

Identify Corporate Team Leads

Assemble Site DC Transition

Team

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19 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Period Experience Example – List of Decommissioning Transition Activities (1/2)

Cost Estimating

Preparation/submittal of Regulatory Submittals

Systems, Structures and Component (SSCs) Re-Categorization

Revised Technical Specifications

Cold and Dark Program (repower certain systems)

Project Management Model

Re-design Work Control Process

Develop Communications Plan

– Both internal and external

Human Resources

– Retention of key staff

– Labor agreement impacts

– Relocation of other staff

Perform Historical Site Assessment and Initial Site Characterization

Disposal of Operational (Legacy) Wastes

Page 28: EPRI Guidance for Transition from Operations to

20 © 2016 Electric Power Research Institute, Inc. All rights reserved.

US Transition Period Experience Example – List of Decommissioning Transition Activities (2/2)

Fuel Building Modifications to Isolate from Other Plant Systems

Certified Fuel Handler Program

Transfer of Spent Fuel to Dry Casks / ISFSI

– Design of the Dry Fuel Storage System

– Building and System Modifications to support the Dry Fuel Storage System

– Fabrication of Dry Fuel Storage Canisters, Storage Cells and Other Related Equipment

– Design and Construction of the ISFSI

Dismantling of Non-Nuclear Facilities

Upgrade Plant /Infrastructure (e.g. rail) to Facilitate Removal of Wastes

Full System Chemical Decontamination

Hot Spot Reduction

Asbestos and Flammable Materials Removal

Preparation for Post-Transition Decommissioning Activities

– Major Component Removal Planning

– Reactor Vessel and Internals Segmentation Planning

– Balance of plant dismantlement

Page 29: EPRI Guidance for Transition from Operations to

21 © 2016 Electric Power Research Institute, Inc. All rights reserved.

EPRI Transition Project – Ongoing/Future Work

Continue to compile transition period operating experience

Summarize French, German, Spanish, and Swiss transition

period regulations

Evaluate regulations and operating experience to develop

guidance for transitioning from operating to

decommissioning

Schedule for completion: Draft report Q1 2016

Page 30: EPRI Guidance for Transition from Operations to

22 © 2016 Electric Power Research Institute, Inc. All rights reserved.

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