Radioactive Waste Management and Decommissioning
2018

Preparing for

Decommissioning During
Operation and After Final
Shutdown

Radioactive Waste Management and Decommissioning

Preparing for Decommissioning During Operation
and After Final Shutdown© OECD 2018
NEA No. 7374
NUCLEAR ENERGY AGENCY
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENTORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENTThe OECD is a unique forum where the governments of 35 democracies work together to address the
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NUCLEAR ENERGY AGENCYThe OECD Nuclear Energy Agency (NEA) was established on 1 February 1958. Current NEA membershipconsists of 33 countries: Argentina, Australia, Austria, Belgium, Canada, the Czech Republic, Denmark,Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Korea, Luxembourg, Mexico, theNetherlands, Norway, Poland, Portugal, Romania, Russia, the Slovak Republic, Slovenia, Spain, Sweden,
Switzerland, Turkey, the United Kingdom and the United States. The European Commission and theInternational Atomic Energy Agency also take part in the work of the Agency.
The mission of the NEA is:–

to assist its member countries in maintaining and further developing, through international
co-operation, the scientific, technological and legal bases required for a safe, environmentally soundand economical use of nuclear energy for peaceful purposes;–

to provide authoritative assessments and to forge common understandings on key issues as input togovernment decisions on nuclear energy policy and to broader OECD analyses in areas such asenergy and the sustainable development of low-carbon economies.

Specific areas of competence of the NEA include the safety and regulation of nuclear activities,
radioactive waste management and decommissioning, radiological protection, nuclear science, economic
and technical analyses of the nuclear fuel cycle, nuclear law and liability, and public information. The NEA
Data Bank provides nuclear data and computer program services for participating countries.

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© OECD 2018
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Cover photos: Whiteshell Laboratories (Provided courtesy of CNL).

FOREWORD

Foreword

The transition from an operating nuclear facility to the implementation of thedismantling phase is critical in every decommissioning project. A number oforganisational and technical modifications are needed to adapt the facility so that it canmeet new objectives and requirements. A variety of activities need to be planned andperformed both to support the transition and to prepare the dismantling of the facility.
Experience has shown that it is essential to start with preparations fordecommissioning at a very early stage, at best already during the design stage of the
facility, and at least during the operational stage. The preparation of the transition todecommissioning and dismantling (D&D) is a key issue for the success of the global D&D
project in order to minimise delays and undue costs; to optimise personnel and otherresources; and to initiate preparatory activities for decommissioning in a planned, timely
and cost-effective manner, with the overall objective of ensuring safe and efficient
decommissioning.
With a growing number of nuclear facilities reaching the decommissioning stage, theWorking Party on Decommissioning and Dismantling (WPDD) formed the Task Group on
Preparing for Decommissioning during Operation and after Final Shutdown (TGPFD),
which involves regulators, nuclear operators and independent experts who review
strategic aspects to optimise preparations for decommissioning from the last years ofoperation onwards.
The present report summarises work carried out by TGPFD between March 2015 andDecember 2017. It supports ongoing and new decommissioning projects by providing
observations and recommendations relating to the development and optimisation ofstrategies, as well as plans to prepare for the decommissioning of nuclear facilities. In
doing so, it ensures value for money, safety of workers and improvements in project
management consistent with good practices and the timely delivery of decommissioning
targets.
Rather than providing detailed descriptions of the relevant methods or technologies,
the report focuses on strategic approaches, different issues that might arise, risks andobservations of good practice.

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3

ACKNOWLEDGEMENTS

Acknowledgements

The NEA would like to thank the following contributors for their review and drafting of
the report.

4

CanadaKOSTOVA, Milena
PAPAZ, Dan
POTTELBERG, Paul

Canadian Nuclear Safety Commission (CSNC)
Canadian Nuclear Safety Commission (CNSC)
Canadian Nuclear Laboratories (CNL)

France

CLEMENT, Gilles
FALCONE, Jean-Luc
GOUHIER, Eric
LAURENT, Gérard
RONDEAU, Jean-Marie
SIEFRIDT, Camille

Orano (former Areva)
Electricité de France (EDF)
Commissariat à l’énergie atomique et auxénergies renouvelables (CEA)
Consultant
Electricité de France (EDF)
Autorité de Sûreté Nucléaire (ASN)

Germany

BRENDEBACH, Boris(chair)
KNAACK, Michael

Bundesministerium für Umwelt, Naturschutz
und nukleare Sicherheit (BMU)TÜV Nord

Korea

AHN, Sangmyeon

Korea Institute of Nuclear Safety (KINS)Spain

CORREA SAINZ, Cristina

Empresa Nacional de Residuos Radiactivos
S.A (Enresa)

SwedenCARROLL, Simon
LARSSON, Arne
NORBERG, Thomas
STRIDSMAN, HenrikStrålsäkerhetsmyndigheten (SSM)
Cyclife EDF
Vattenfall
Sydkraft Vattenfall Forsmark Oskarshamn(SVAFO)Switzerland

MINGES, Jürgen

Eidgenössisches
Nuklearsicherheitsinspektorat (ENSI)

United Kingdom

BONIFACE, SimonDUNLOP, Alister
JASSAL, Raj
MOAKES, Joanna

Nuclear Decommissioning Authority (NDA)
Sellafield Ltd.
EDF Energy
Environment Agency

United States

ABU-EID, Rateb
DEVGUN, Jas
McGRATH, Richard
WATSON, Bruce

Nuclear Regulatory Commission (NRC)
Consultant
Electric Power Research Institute (EPRI)
Nuclear Regulatory Commission (NRC)

IAEA

GLORENNEC, Christian

NEA

WEBER, Inge
PREPARING FOR DECOMMISSIONING DURING OPERATION AND AFTER FINAL SHUTDOWN, NEA No. 7374, © OECD 2018

TABLE OF CONTENTS

Table of contents

List of abbreviations and acronyms ............................................................................................7
Chapter 1. Introduction ..................................................................................................................91.1. Objective...............................................................................................................................10
1.2. Scope.....................................................................................................................................121.3. Organisation of the report. ................................................................................................12
Chapter 2. Setting the strategy for decommissioning............................................................132.1. Introduction .........................................................................................................................132.2. Key enablers and constraints ............................................................................................132.3. Objectives of the strategic decisions. ...............................................................................15
2.4. References ............................................................................................................................24
Chapter 3. Technical activities to prepare decommissioning and dismantling ...............25
3.1. Introduction .........................................................................................................................25
3.2. Asset management. ............................................................................................................26
3.3. Fissile material and spent fuel removal ..........................................................................27
3.4. Shutdown of redundant systems .....................................................................................28
3.5. Characterisation ..................................................................................................................29
3.6. Materials and waste management ...................................................................................32
3.7. Decontamination activities ...............................................................................................34
Chapter 4. Regulatory framework and authorisation for decommissioning .....................37
4.1. Responsibilities during the transition .............................................................................37
4.2. Application documents and preparation for decommissioning. .................................41
4.3. Regulatory oversight...........................................................................................................44
4.4. References. ...........................................................................................................................44
Chapter 5. External stakeholders ...............................................................................................45
Chapter 6. Organisation transition ............................................................................................47
6.1. Introduction. ........................................................................................................................47
6.2. The transition in terms of organisational change .........................................................47
6.3. Decommissioning project management .........................................................................50
6.4. Transition risk management ............................................................................................52
6.5. Management system ..........................................................................................................52
6.6. Supply chain. .......................................................................................................................55
6.7. References ............................................................................................................................57
Chapter 7. Conclusions, observations and recommendations .............................................59
7.1. Conclusions and recommendations ................................................................................59
7.2. Areas for further work .......................................................................................................61
Chapter 8. Glossary .......................................................................................................................63
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TABLE OF CONTENTS

List of annexes
A1.

Canada – Case study: Whiteshell Laboratories decommissioning
management system documentation ..........................................................................65
A.2. France – Case study 1: CEA decommissioning organisation adapted to
Grenoble Nuclear Centre Nuclear Decommissioning Organisation ........................73
A.3. France – Case study 2: EDF-FBR 1 240 MW ..................................................................81
A.4. France – Case study 3: EDF-PWR 305 MW ....................................................................87
A.5. Sweden – Case study: Decommissioning in Vattenfall .............................................91
A.6. Switzerland – Case study: Muehleberg NPP, BWR 390 MWe.....................................95
A.7. United Kingdom – Case study: THORP Transition from operations,post-operations clean-out ...........................................................................................103
A.8. Spain – Case study: Decommissioning of José Cabrera NPP ...................................107
A.9. United States – Case study 1: Connecticut Yankee NPP decommissioning .........123
A.10. United States – Case study 2: Vermont Yankee NPP decommissioning ...............129
B.
Contracting methods ....................................................................................................135
C.
Comparison of requirements for the regulatory framework and authorisation
process for decommissioning in various NEA member countries ...........................137
D.
Systematic approach to training (SAT) ......................................................................151
E.
Bibliography – National and international guidance documents ..........................155

List of figures
1.1:

1.2:
1.3:
2.1:
2.2:
3.1:
3.2:
6.1:
6.2:
A.2.1:
A.2.2:
A.2.3:
A.2.4:
A.2.5:
A.2.6:
A.2.7:

6

A top-level overview of key enablers, constraints and strategic decisions
influencing a smooth transition from operations to decommissioning,
and the decommissioning planning ............................................................................10
Evolution of the uncertainty of knowledge needed during the planning andconducting of a decommissioning project ..................................................................11
Transition in relation to operation and decommissioning .......................................11
Stakeholders’ map: Stakeholders concerned and how they might
influence the decommissioning strategy ....................................................................15
Life cycle of a nuclear power plant as an example of a nuclear
facility’s life cycle ............................................................................................................18
Typical preparatory activities .......................................................................................25
Decrease of a nuclear power plant’s activity inventory ............................................27
Typical organisation transition .....................................................................................48
Example of a governance model ...................................................................................51
Facility timeline...............................................................................................................73
Organisational chart: CEA Nuclear Energy Division ..................................................75
Global overview of the PASSAGE project .....................................................................77
CEA Grenoble project organisation...............................................................................78
Organisation of the PASSAGE project ..........................................................................79
CEA human resource planning .....................................................................................80
CEA licensee/facilities management and project management ..............................80

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LIST OF ABBREVIATIONS AND ACRONYMS

List of abbreviations and acronyms

ALARA

As low as reasonably achievable

ALARP

As low as reasonably practicable

ASN

French Nuclear Safety Authority

BWR

Boiling water reactor

CANDU

Canada Deuterium Uranium

CEA

French Alternative Energies and Atomic Energy Commission

CNL

Canadian Nuclear Laboratories

CNSC

Canadian Nuclear Safety Commission

CSA

Canadian Standards Association

CSN

Spanish Nuclear Safety Council

D&D

Decommissioning and dismantling

DECON

Immediate dismantling option in the United States

DETEC

Department of the Environment, Transport, Energy and Communications(Switzerland)

DQAP

Decommissioning quality assurance plan

DQO

Data quality objectives

ENSI

Swiss Federal Nuclear Safety Inspectorate

GTCC

Greater-than-class C

IAEAInternational Atomic Energy Agency

IDP

Initial decommissioning plan

ILW

Intermediate-level waste

INB

Regulated nuclear installation

ISFSI

Independent spent fuel storage installation

LILW

Low- and intermediate-level radioactive waste

LLW

Low-level waste

MOU

Memorandum of understanding

NDA

Nuclear Decommissioning Authority (United Kingdom)

NEA

Nuclear Energy Agency

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LIST OF ABBREVIATIONS AND ACRONYMS

8

NPP

Nuclear power plant

NRC

Nuclear Regulatory Commission (United States)

OECD

Organisation for Economic Co-operation and Development

PSDAR

Post-shutdown activity report

SAFSTOR

Safe storage, deferred dismantling (United States)

SAT

Systematic approach to training

SCA

Safety and control area

SFP

Spent fuel pool

SSCs

Structures, systems and components

TGPFD

Task Group on Preparing for Decommissioning during Operation and after
Final Shutdown (NEA)

VLLWVery low-level waste

WPDD

Working Party on Decommissioning and Dismantling (NEA)

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INTRODUCTION

Chapter 1. Introduction

The preparation for decommissioning and dismantling (D&D) is a key issue for the
successful conduct of a decommissioning project; to initiate preparatory activities fordecommissioning in a planned, timely and cost effective manner, to optimise personnel
and other resources and to plan dismantling activities. All these aspects contribute toensure the safe and efficient decommissioning of a facility, and to minimise delays andundue costs.
A set of strategic decisions needs to be taken early in the preparatory phase. These
decisions are mainly driven by the anticipated end state of the decommissioning project(continued regulatory supervision, e.g. on a multi-facility site or release of the site from
regulatory control with or without restrictions on its future use) and culminate in the
choice of the decommissioning strategy to be followed. This choice is made between
either immediate dismantling (DECON option in the United States) or preparation of the
facility for deferred dismantling (SAFSTOR option in the United States).
The approach to decommissioning strongly hinges on internal and external factors
which are key enablers or constraints for a decommissioning project and may include:•

the funding situation;•

the policy and regulatory framework;•

the facility design and status;•

the available routes for the radioactive waste;•

good practices and experience;•stakeholder perceptions.

The strategic decisions that must be taken in relation to these key enablers andconstraints include:•the nuclear material and/or spent fuel management strategy;•

the materials and waste management strategy;•

the remediation/site clean-up strategy;•

the dismantling strategy;•

the facility modification strategy;•

the technological strategy;•

corporate strategies;•

the authorisation process.

Figure 1.1 illustrates the key enablers, constraints and strategic decisions leading to
the chosen decommissioning planning, which forms the basis for initiating the planningof preparatory activities.

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INTRODUCTION

Figure 1.1: A top-level overview of key enablers, constraints and strategic decisions
influencing a smooth transition from operations to decommissioning,
and the decommissioning planning

Funding
situation

Policy andregulatory
framework

Facility
design andstatusAvailable
waste routes

Good practices
and experience

Stakeholders

Setting the strategy for decommissioning
Nuclearmaterial andspent fuelmanagement
strategy

Materials
and wastemanagement
strategy

Remediation/site clean-up
strategy

Dismantling
strategy

Facility
modification
strategy

Potential options:
Immediate
decommissioning,deferred dismantlingTechnologicalstrategy

Corporate
strategies

Authorisation
process

Potential end states:
Unrestricted or
restricted reuse

Decommissioning
planning

As a number of changes need to be initiated to prepare the facility for D&D,
preparation for transition from operations through to decommissioning should be started
as soon as possible. It is considered good practice for the preparation of this phase tostart well before cessation of operations. Ideally, decommissioning should already havebeen considered during the design stage of the facility, although this requires
anticipating a given situation decades ahead. As a consequence, the knowledge relevant
for decommissioning bears substantial uncertainties during the design stage.
Preparations for decommissioning require active monitoring and tracking of the internaland external constraints in order to gradually decrease the level of uncertainty ofknowledge relevant to decommissioning, and the level of uncertainty during facility
operations and after commencing dismantling activities, as outlined in Figure 1.2, toincrease the maturity of the decommissioning planning.

1.1. Objective
With a growing number of facilities reaching the end of their operational stage, it isimportant to gather and consolidate experiences available in NEA member countries on
the topic of preparing for decommissioning during operation and after final shutdown.
The objective of this report is thus to inform decision makers in decommissioning,decommissioning planners, as well as regulatory bodies, on the key aspects of such a“transition” and of preparing for decommissioning during the last years of operation andafter cessation of operation. The aim is to ensure that these activities begin early, andwhere possible, during the operational stage. Starting early will ensure that the transition

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INTRODUCTION

from operation to decommissioning is carried out effectively and efficiently so as tooptimise time, and human and financial resources.
The report applies the terminologies as set out in Figure 1.3.
Figure 1.2: Evolution of the uncertainty of knowledge needed during the planningand conducting of a decommissioning project (not true to scale)

Uncertainty of knowledge
related to decommissioning

Authorisation for
operation

Decision to shut
down
Siting/designstage

Date of final
shutdown

Operatingstage

Authorisation fordecommissioning
Release from
regulatory control
Decommissioning stage

Lifetime of a facility

Figure 1.3: Transition in relation to operation and decommissioning
Shutdown
Cessation of operation

Operation

End state

Decommissioning

Transition
Post-operation

DismantlingSiteclean-up

Decommissioning planning,
Preparatory activities

The term “transition period” (sometimes referred to as the “transition phase”) isintentionally not used in this report as its understanding and use varies from country tocountry. Although the term can be found in many national and international documents,
and is used in most countries to describe the phase starting with the cessation ofoperation (final shutdown) and ending with granting the authorisation fordecommissioning, or by the date of approval of the final decommissioning plan, thisreport introduces the term “transition” in order to emphasise the broader character of theconsiderations, shifts and activities that are involved with the change from operation todecommissioning.
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INTRODUCTION

1.2. Scope
This report draws on experience of NEA member countries in preparing fordecommissioning and dismantling so as to identify considerations that need to be made,decisions to be taken and activities to be carried out, as well as interrelations between
certain aspects and key issues so as to prepare and plan for the decommissioning of a
nuclear facility.
It summarises observations, good examples and recommendations relating to thedevelopment and optimisation of planning for the decommissioning of a nuclear facility.
This, in particular, is in order to support new decommissioning projects. The reportfocuses on strategic approaches, different issues that might arise, risks and observationsof good practice, rather than providing detailed descriptions of the relevant methods ortechnologies.
The considerations in this report are intended to cover and be applicable to any
nuclear facility undergoing decommissioning, although some differences in the planning,
preparations and/or procedures may occur for specific types of facilities, such as fuelcycle facilities. Users of this report may select certain parts of this report as applicable totheir particular decommissioning situation.
The report mainly discusses the “immediate decommissioning” strategy, but theapproach is also applicable to the initial phase of the “deferred dismantling” strategy.

1.3. Organisation of the report
The observations and findings presented in this report are based on the experiences of
NEA member countries, as well as on a review of international publications.
The constraints/key enablers and strategic decisions that lead to and set the course
for decommissioning planning, which forms the basis for preparatory activities, aredescribed in Chapter 2.
Chapters 3 to 6 provide detailed information on aspects that have been identified as
key factors enabling the effective and efficient conduct of a decommissioning projectwith timely preparation and planning:•

pre-dismantling and post-operation activities;•

regulatory framework and authorisation for decommissioning;•

external stakeholders;•organisation transition.

Chapter 7 summarises the findings of the report, and the annexes provide further
information on individual aspects described in the report, as well as case studies
reflecting experiences in individual NEA member countries.
Annex A presents several case studies from different NEA member countries toillustrate aspects related to the preparation of decommissioning and transition.
Annex B highlights the more common contracting models for the supply chain.
Annex C provides a comparative summary of different requirements fordecommissioning, preparatory activities and responsibilities in various NEA member
countries.
Annex D provides further information on the training programmes of nuclear
facilities that are based on a systematic approach to training (SAT).
Annex E contains a bibliography of international standards and guidance, as well as
national documents related to the transition from operation to decommissioning.

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SETTING THE STRATEGY FOR DECOMMISSIONING

Chapter 2. Setting the strategy for decommissioning

2.1. Introduction
The focus of this chapter is to define the strategic decisions that need to be taken as partof preparing for decommissioning. These decisions should ideally be taken well before
the date of the final shutdown.
Section 2.2 describes the key enablers and constraints influencing the setting of astrategy for decommissioning, and Section 2.3 describes the main elements that need tobe addressed in the definition of strategic approaches that form the basis for thedecommissioning planning.
The strategic decisions taken are to be reviewed regularly in the light of the overall
decommissioning project, its progress and other decisions made and refined or adjusted
if necessary.

2.1.1. Implementation of the strategies
Once the strategies have been determined, decommissioning planning needs to be
developed that takes into consideration these strategies as a basis for conducting thedecommissioning project. This planning should be approved by the responsibleorganisations and its implementation should be kept under review.

2.2. Key enablers and constraints
A number of key enablers and constraints need to be considered when setting thestrategy for decommissioning. These include:•available funding;•policy and regulatory framework;•

facility design and status;•

available waste routes;•

good practices/experience;•stakeholders.

Such key enablers and constraints are further discussed in the following sections.

2.2.1. Available funding
In most countries, mechanisms for providing decommissioning funding are in place andbased in national law or regulation (NEA, 2016a). However, different approaches are takenwith respect to the way that the funds are accumulated, the level of oversight and theconditions of qualification for funding.
The decommissioning funds might be controlled by a state body or managed by theutility itself.

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SETTING THE STRATEGY FOR DECOMMISSIONING

The availability of the funds has a significant impact on the planning and conduct ofdecommissioning activities.
For example, when availability of funds is limited, the strategy may prioritise on
safety-related considerations, which means activities and projects that reduce the risks
to the public and the environment.

2.2.2. Policy and regulatory framework
A variety of requirements need to be fulfilled to obtain the required authorisation toundertake decommissioning activities. Such requirements are defined not only by the
nuclear regulator, but also by other authorities focusing on workers’ safety, environmental
safety, waste management and transportation.
The respective legal and regulatory requirements have to be identified and analysedwhen setting the strategy. This is critical, as the time for obtaining an authorisation can besignificant; it has to be carefully taken into account while preparing for decommissioning
in order to avoid delaying the subsequent steps.

2.2.3. Facility design and facility status knowledge
A key part of the transition is the transfer of the facility knowledge from the operation
organisation to the decommissioning organisation. The facility knowledge is held by theentire operation organisation and therefore knowledge management is not just aboutproviding layout and drawings of the facility but includes access to any additional
records and information that are judged necessary for a detailed understanding of theactual status of the facility. It is important to capture the operational background which
includes changes made to the plant design and operational incidents/events that may
not be adequately documented within formal records, but instead may be confined into
individuals’ memory.
In addition, complementary knowledge may be acquired from other internalorganisations – such as the supply chain, for example – and therefore learning from theirexperiences should be part of the strategy.

2.2.4. Available waste routes
Although waste policies exist in all NEA member countries, it is possible that not all
waste types are covered. Existing routes for disposal may not be available/compatible toaddress all the waste categories that are anticipated to be produced through the future
dismantling activities.
Ideally, one should secure the necessary waste routes before undertaking dismantling
activities. But it is advisable to also consider interim solutions, such as interim storage
on-site or using off-site capacities. This approach allows for the separation of the processof generating waste via dismantling, from its transfer to a disposal site, and hence avoids
bottlenecking and delays during dismantling operations – due to materials and waste
management logistics – and provides more time for establishing missing waste routes forproblematic waste streams. However, any measures and approaches should be in balancewith avoiding a double handling of waste and potential repacking due to waste
acceptance criteria of the repository.
An analysis of available waste routes and opportunities of radioactive waste
reduction – such as recycling or clearance, if permitted by the country’s regulations – hasto be conducted when setting the strategy for decommissioning and reviewed regularly.

2.2.5. Good practices and past experience
Regardless of the level of experience of the team in charge of decommissioning, one of
the first activities to be undertaken is to collect the available feedback of experience

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SETTING THE STRATEGY FOR DECOMMISSIONING

nationally and internationally. This will help the project team to recognise the criticalaspects of a decommissioning project and will provide some benchmarking information.

2.2.6. Stakeholders
Many stakeholders could influence the process of setting the decommissioning strategy
or the procedures to receive an authorisation. These include the utilities staff andworker’s unions, national and local government bodies, as well as non-governmentalorganisations (NGOs), regulators (nuclear regulator, environmental protection regulator,etc.), local communities and residents. A systematic and consistent approach is therefore
required to ensure that all the key enablers of the project are appropriately identified andinformation is provided in a timely manner.
A stakeholders’ map is presented in Figure 2.1 below. The approach with stakeholders
has to be flexible, as there are many variables associated with transition itself.
Figure 2.1: Stakeholders’ map: Stakeholders concerned and how
they might influence the decommissioning strategy(local)Government

Regulatory
authorities

Policy makers
International
stakeholders

PublicDecommissioning
organisation

Media

Operator
Local
community

Supplier
participants

Supply chain

Waste management
organisation

Industry

UnionsEnvironmental
interest groups
Nuclearopponents

Employees

Stakeholders will have different interests and this should be taken into account in theplanned engagement. For example, in most countries environmental aspects will be
addressed under an environmental impact assessment which will be discussed with thestakeholders. Local communities may also be concerned, in particular about losing asource of taxes, jobs, supply chains and other socio-economic factors, as well as theforeseen end state of the site.

2.3. Objectives of the strategic decisions
Setting the strategy for decommissioning has to address the following aspects:•

nuclear material and/or spent fuel management strategy;

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SETTING THE STRATEGY FOR DECOMMISSIONING•

materials and waste management strategy;•

dismantling strategy;•

corporate strategies;•

authorisation strategy;•

remediation/site clean-up strategy;•

technological strategy.

Each of these aspects is discussed hereafter and further details are provided in
Chapter 3.

2.3.1. Nuclear material and/or spent fuel management strategy
This strategy needs to cover all types of fissile material that may occur in a nuclear
facility: spent fuel, damaged fuel and other fissile nuclear material (e.g. in researchfacilities, reprocessing plants, etc.), as well as non-irradiated fuel (fresh fuel). A major aim
during the transition is to remove all fissile material from the facility for two main
reasons:•

Reduction of fixed costs: The surveillance of the nuclear facility, which stillcontains fissile material and/or fuel, causes significant costs in order to maintainall necessary safety-related measures. The removal allows a reduction of thesafety and security measures in accordance with the licence requirements.
Consequently there is a clear motivation to remove such material from the facility
as early as practicable.

•

Start of decommissioning and dismantling: In most countries, the removal of all
fissile material from the facility marks the end of the transition from operation todecommissioning and is at the same time a prerequisite according to national law
for starting the D&D. However, D&D may commence with fresh fuel still on-site.

Strategy for spent fuel, damaged fuel and other fissile material
This strategy has to provide support for the retrieval, management, interim storage or
predisposal of such material. This will depend on national policies, as well as theavailability of capacities, equipment and casks. Regarding spent fuel the options are as
follows:•

sending for reprocessing/recycling;•storing in casks in an interim storage at the site or an off-site storage facility, forexample the independent spent fuel storage installation (ISFSI), to await disposal;•

establish a “spent fuel pool island” (SFP island). The SFP island approach consistsof isolating the spent fuel in a self-contained storage area, i.e. existing pool. Suchan approach allows for segregation of the area that shall remain in full safetycontrol.

For damaged fuel and other fissile nuclear material, special solutions may need to be
developed when options for their handling are not available.

Fresh fuelIn particular, in the case of an unplanned shutdown of a nuclear facility, fresh fuel might
be on-site. Available options for the fresh fuel could be:16•

reuse in other nuclear facilities;•

recycling in a fuel fabrication.
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It is recommended to have plans for the further use of fresh fuel, if it cannot be
avoided, as early as possible during the operational stage of the nuclear facility. The
removal of fresh fuel from the facility is not a prerequisite for starting D&D.

2.3.2. Materials and waste management strategy
When developing a materials and waste management strategy it is recommended toconsider the overall process from generation (during D&D) up to its clearance, if
applicable, and/or disposal. A materials and waste management strategy needs to cover
all types of materials and waste flow even though certain streams, such as theradioactive or potentially radioactive materials and wastes, will need more attention.
Decommissioning projects are waste driven projects to a large extent. Each and every
one of the main steps in a decommissioning project involves or needs to consider
material and waste management aspects. The material and waste issues have a strong
influence on the decommissioning activities and, in many cases, also the schedule.
When forming the materials and waste management strategy, it is important to
identify and secure the potential end states, to have a good understanding of the initialstate and, based upon that, plan for the waste routes. The full understanding andconsideration of waste acceptance criteria for disposal and, if applicable, the clearance
criteria, when planning for and implementing characterisation, decontamination,
dismantling and waste treatment, are key success factors.
The strategy should – in line with the above – take into account the presence ofpotentially recoverable material or equipment (reuse or recycle within or outside thenuclear sector). Most nuclear facilities contain large volumes of material subject toclearance or classified as conventional material.
Other strategic decisions to be taken are:•the extent of on-site waste treatment;•

localisation of the local waste treatment centre (see also Sections 2.3.5 and 3.6.4);•

contracting the waste handling activities or build an organisation for selfperformance.

The decision on the level of on-site waste treatment is closely related to the waste
acceptance criteria for storage and disposal, clearance criteria (if applicable),transportation limitations and whether there are service providers in radioactive waste
treatment.
Waste management is of such an importance that most national regulations require a
waste strategy to be clearly described in the final decommissioning plan (see Section 4.2).
The materials and waste management strategy should address the following:•

inventory of solid/aqueous/gaseous materials and waste (in nuclear andconventional areas of the facility);•a waste management plan for the radioactive and potentially radioactive waste;•

waste management infrastructure for handling, interim storage and transportation
including reviewing the capability of existing on-site treatment facilities andcapabilities;•

material and waste disposal routes (and their availability).

The waste management plan enables understanding of the supply chain requirements,
as well as facilitating development and implementation of:•treatment technologies and concepts;

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innovative treatment and packaging techniques;•

new disposition options (reuse, recycling and disposal).

Operational waste
Operational waste, i.e. waste from the operational phase, may be included in theconsideration for the materials and waste management strategy, but it is in generalrecommended to remove most of it during the transition (see Section 3.6.2). Particularattention should be paid to those wastes from operation that occur only in small
quantities but are very active – such as calibration sources, detectors and probes.

2.3.3. Remediation and site clean-up strategy
In the context of the life cycle of nuclear facility (shown in Figure 2.2), a critical part ofdetermining the optimal decommissioning strategy is to clearly understand the intended
end state that is to be achieved. The end state is the point at which the decommissioning
and remediation mission is complete, although there may be a period of institutional
control following this point. The end state will be dependent upon local and national
factors and in particular what the intended next use is to be for the site, but may not
involve the removal of all radioactive material from the site. Therefore, the next use may
result in restricted or unrestricted use depending on the nature of the end state and how
much material has been removed.
A key component of the decommissioning strategy is consideration of the actions
that are required to be taken to ensure that the land itself is suitable for the intended
next use and the achievement of the end state. This phase is generally executed in thelatter phases of the decommissioning mission and is referred to in this report as
remediation.
Figure 2.2: Life cycle of a nuclear power plant as an example of a nuclear facility’s life cycle
Cessation ofoperations

Design andconstruction phase

Operatingphase

Start ofdecommissioning
Defueling, clean out
following operations

DismantlingphaseLand remediation phase,administrative controls

Time

Transition from operations
to decommissioning

As part of the optimisation process associated with deriving the end state, it may be
determined that although all radioactive material can be removed from the site it may not
be optimal to do this. For example, if a site has no identified options for reuse, the removalof all subsurface concrete structures, which will require significant resources, may haveno benefit, and therefore does not represent an optimal end state.

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The process of justifying the proposed end state will require engagement with many
competent bodies, such as environmental regulators, as well as other stakeholders suchas the public. The optimisation approach will require the consideration of many factors,
such as radiological, environmental and conventional safety, as well as financial andsocio-economic factors. The output of this process will be a justification to the competentbody – generally the regulators – that the proposed approach has reduced risks (including
those associated with radiological and conventional safety) to as low as reasonably
practical/achievable (ALARP or ALARA).
Once the end state is clearly understood, the progressive delivery of thedecommissioning mission can be expressed by a series of interim states which are
typically stable points within the mission – such as the removal of all fissile material
from the facility. The use of interim states is particularly useful for a lengthy
decommissioning project or programme as they allow focusing on near-term goals which
can also be used to inform stakeholders.
The remediation phase is intended to implement measures to ensure that overall
radiation doses are ALARA following the end state. The remediation strategy needs to beaware of the initial state to ensure any remediation actions are justified and beneficial.
There are several options for land remediation, and these could include in situ
remediation techniques such as those employing monitored natural attenuation. As
shown in Figure 2.2, after the end state has been achieved and potentially the site is
being reused, there may be a period of institutional control for radiological protection
which includes controls such as monitoring to determine if remaining contamination is
behaving as expected in terms of decay and spread.
The NEA report “Strategic Considerations for Sustainable Remediation of Nuclear
Installations” (NEA, 2016b) describes good practice in this area, includes a strategic
approach on how to address long timescales involved in decommissioning andremediation, and helps in decision making on site end states and interim states.

2.3.4. Dismantling strategy
The dismantling strategy should consider optimisation opportunities for thesegmentation and removal of structures, systems and components (SSCs), which take
into account both the physical and the radiological status of the facility at the end of its
operational phase or when the dismantling is intended to start.
The dismantling strategy should take into account the following aspects andapproaches:•sequencing of the dismantling, e.g.:– “hot to cold” vs. “cold to hot”;– “room by room” vs. “system by system”.

•

in situ dismantling vs. rip and ship approach;•support systems (e.g. replacement of electrical systems, etc.);•

segmentation approaches (e.g. larger parts vs. cutting in small pieces);•

implications for materials and waste management facilities suitable for D&D
activities (e.g. logistics, availability and location of radioactive waste treatment
facility, interim storage facilities, etc.);•

withdrawal from the facility and site, including decontamination, clearance,
demolition or reuse of building or structures.

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2.3.5. Facility modification strategy
The facility modification strategy aims to facilitate the overall decommissioning project
execution and the dismantling activities and thus may contribute to the reduction of
fixed costs. It ensures that the infrastructure and supporting systems (auxiliary systems
and installations) of the facility are adapted and provided for decommissioning which:•commensurate to decommissioning needs, progress and risks;•

allow flexibility to accommodate possible changes during decommissioning;•

reduce interferences between auxiliary systems and installations with dismantlingand decontamination activities.

Therefore, it should to be closely co-ordinated with the other aspects of thedecommissioning planning and strategy definitions (such as materials and waste
management, dismantling, authorisation process, etc.) in order to achieve thedecommissioning optimum in terms of time and costs.
For sites with more than one nuclear facility, the facility modification strategy also
needs to take into consideration site-specific aspects including, among others:•

necessary decoupling of the facility to undergo decommissioning;•a site-wide strategy for auxiliary systems and installations.

Auxiliary systems
These systems, mainly for electrical supply, ventilation, fire protection, treatment ofliquid effluents, conditioning/processing of radioactive waste, etc., can be either modified
and adapted or be replaced by new supporting systems. In both cases, they need to be
designed in a way that they fulfil their function, in particular with respect to their safetyfunctions, and do not interfere with the dismantling activities. Good practice in thiscontext is:•use of modular and mobile systems;•

introduction of wireless systems and new technologies;•

continued maintenance of handling equipment for large components (e.g. polar
crane).

It is recommended that the licensee has early engagement with the regulators aschanges to systems may require new aqueous/gaseous discharge points.

Auxiliary installations
The following types of areas may need to be created in support of selected strategies of
dismantling and materials and waste management: areas for system cutting,conditioning/processing areas for materials and radioactive waste arising fromdismantling as well as storage areas for materials and radioactive waste. Taking into
consideration the existing infrastructures at the nuclear facility and logisticalconsiderations for tackling the materials and waste streams (see Section 3.6.4) and basing
on good practice, the strategy may include:20•

To use an auxiliary building for accommodating centralised systems and auxiliary
facilities and infrastructures: cutting workshops, decontamination workshops,
waste conditioning areas, zone for waste storage, etc. An existing building can beadapted to this function.

•

To install confined cutting areas into the buildings to be dismantled.

•

To distribute storage areas for dismantled materials and waste along the site.
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Further considerations in the development of auxiliary installations strategy include:•

specific requirements for the handling of highly activated wastes;•

buffer storage areas for dismantled materials and waste with sufficient capacities
to accommodate large volumes.

Modifications and adaptations in this context should be implemented during thetransition as part of the preparatory activities provided they are allowed under theoperating licence.
However, it is noted that facility modifications, in particular in case of replacement by
a new system or refurbishment of an existing building, may cause additional amounts ofmaterials and waste when they have to be dismantled, and these amounts need to be
included in the materials and waste management strategy.

2.3.6. Technological strategy
The technological strategy aims to provide a framework for decisions on the choice oftechnologies to be deployed and utilised in the decommissioning projects andprogrammes, taking into account potential needs for and benefits through R&D for
decommissioning. This includes fundamental decisions such as whether to rely on
proven technologies or techniques (for which performance is better known andpredictable), or on innovative technologies or techniques (which may offer significant
advantages for its specific use, but for which there are greater uncertainties due to lessexperience in their use).
Overarching considerations in this context include:•the need to maintain and enhance decommissioning safety, and to make projectdelivery more predictable and more efficient;•

the benefits from an early introduction of innovative technologies;•

the knowledge and awareness of (facility-)specific decommissioning challenges
which might be better tackled using innovative technologies;•

the given time frame until the technology or technique needs to be deployed.

In addition, there may be significant opportunities to reduce the cost, duration, andenvironmental impact of decommissioning projects through innovation, provided that
adequate lead time is allowed for technology insertion into the project. Finaldecommissioning plans should, where possible, retain the flexibility for recognition andincorporation of new technologies.
To enable suitable new or innovative technologies to be in place and able to be used
when needed, actions will be required preferably before the end of operations, among them:•

identification of areas in an upcoming decommissioning project or in a
decommissioning programme with multiple nuclear facilities that may benefit
from R&D activities;•

initiation R&D activities in line with the needs of the decommissioning project andfitting into its planned purpose;•qualification of innovative technologies to prove that its deployment meets thesafety requirements;•

interaction with stakeholders involved in the introduction and deployment of thetechnology, such as the regulatory body.

Areas for technology development include:•

new techniques and instrumentation for characterisation to underpin nuclide
vectors prior to decommissioning;

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development of means of deployment of suitable technologies and techniques fordecontamination, dismantling and demolition of facilities;•

robotics and automation, including remote handling equipment and systems;•

development of material and waste treatment and/or final conditioning processes.

However, developments and innovations can also address more general and global
decommissioning issues such as leaving facility and equipment in place following theoperational phase, i.e. a deferred dismantling strategy and whether change inenvironmental conditions will cause issues for asset management and decommissioning
in the future.
The recent NEA report, “R&D and Innovation Needs for Decommissioning Nuclear
Facilities” (NEA, 2014), provides an extensive overview and the status in this field andhighlights areas with greatest potential for future improvements through research anddevelopment.

2.3.7. Corporate strategies
Generally, the licensee (organisation in charge of facility operation) has the responsibility
for all aspects of the safe decommissioning of the facility. However, some NEA member
countries have specialised organisations which can undertake the entire process (e.g. theNuclear Decommissioning Authority [NDA] in the United Kingdom and Enresa in Spain).
The corporate strategies should focus on the following, which are described in moredetail in Chapter 6.

Organisation
Organisation needs to evolve when transitioning from the operational stage to thedecommissioning stage. The first objective of this organisation transition is to ensurethat – throughout the transition and the whole decommissioning – an effective andcompetent organisation remains in place and in charge of the facility.
When responsibilities are transferred from one organisation to other (i.e. fromoperational organisation to a decommissioning organisation) records of information
about the facility should be made available to the successor organisation. The
information to be transferred between organisations should be set out in an interface
document or contract that describes and specifies the type of the documents andinteractions between the organisations.

Human resources strategy
Comprehensive management of former operating staff is a key condition for the successof a decommissioning project. This staff will have to safely operate the facility until the
final shutdown and beyond (residual operation) and will also have a key role to play insome of the post-operation activities such as defueling or full system decontamination.
At the same time, personnel might be concerned and disturbed by questions related totheir own employment (mainly: “what will be my future after shutdown”).
Operation personnel’s knowledge and experience gained during the operation life of
the facility is very valuable for the D&D planning and conduct. Activities such as theremoval of spent fuel, primary circuit decontamination and shutdown of redundant
systems require the expertise of the facility’s operating personnel. At the same time,
operating personnel who will continue working during the D&D must be trained withregard to the new risks and the changes that the facility will go through.
Decommissioning requires an appropriate mixture of experienced workers with
operational memory and new workers with decommissioning experience.

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The human resources strategy is to ensure a predictable management of employeeswith a view:•to maintain the necessary competences and skills as necessary for the nuclear
facility and its remaining lifetime until decommissioning completion;•

to ensure the retraining of employees by anticipating the needs of the site;•

to promote the transfer of skills and also “experience feedback” within theorganisation.

Human resources aspects are further specified in Section 6.2.

Governance model and management system
The governance model refers to the mechanisms, processes and relations by which
licensees are controlled and directed. Usually the governance model is in place alreadyduring the transition and should be considered for establishing the decommissioning
planning.
The integrated management system should be adapted to the new stage of the facility.
However, management system generic requirements (e.g. document control, work
management, change control, assessments and improvements) and management systemprinciples are the same during operation and decommissioning.
Further information is provided in Chapter 6.

Organisational knowledge management
A key part of the transition is the transfer of the required facility knowledge from theoperational to the decommissioning organisation. In this context knowledge
management is not restricted to the layout of the facility but includes operational records
that are judged necessary for successful decommissioning. Attention should be paid tothe fact that changes made to the facility design and operational incidents/events might
not be adequately captured within operational records.
In addition to the internal knowledge, knowledge can be gained also based on
external learning experience. A key lesson from some NEA member countries is that
often older facilities are not as well-indicated in drawings, and that modifications havebeen made during phases such as active commissioning that perhaps were notadequately recorded.

Supply chain strategy
The supply chain strategy needs to define the approach and methods followed whencontracting for goods and services for the decommissioning activities. This is a criticalaspect for enabling effective delivery of decommissioning activities as the choice ofcontract negotiated between the licensee and contractors is a powerful mechanism tofacilitate delivery of essential goods and services, control costs, and maintain a project
within budget and schedule.
Underpinning the supply chain strategy are more fundamental decisions about how
the decommissioning project will be managed, i.e. whether this will be undertaken by thelicensee as a self-directed project, or managed by a decommissioning operations
contractor under the oversight of a licensee Such decisions also have implications for
project risk and the choice of contract model to be used. For example, in a self-directed
project implementation scenario, the full responsibility of costs and risks lies with thelicensee, but for a decommissioning contractor implementation scenario, risk may beshared to a varying degree depending on the contract model chosen. The owner/licensee
balances the benefits of putting a contractor at risk, versus sharing the risk to ensure theproject is completed successfully.
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Accordingly, the supply chain strategy includes decisions on the following:•

The nature of the relationship between the decommissioning organisation and the
suppliers of goods and services. This may range from a simple purchaser-supplier
relationship, to closer forms of co-operation including partnership in ensuring theeffective delivery of the project.

•

The choice of specific contract models to be used (some of the more common
models are described in the IAEA report Financial Aspects of Decommissioning [IAEA,
2005] and an experiences from NEA member countries is provided in Annex B).

•

Risk sharing (i.e. between the decommissioning organisation and suppliers ofgoods and services).

•

Performance-related incentives and penalties related to fulfilment of the contract
conditions.

Supply chain issues are further discussed in Section 6.6.

Fleet or programmatic approach
For utilities/owners or licensee having a fleet of several facilities, the fleet approachallows optimisation of decommissioning costs in mutualising some phases of thedecommissioning projects such as:•conceptual and basic engineering;•

waste management approach;•special tools or special process management.

2.3.8. Authorisation process
In line with the requirements of NEA member countries, the authorisation strategy fordecommissioning should be determined based on the selected decommissioning strategy.
A multi-phased strategy could be adopted in the following cases:•

for large and complex projects;•

in the case when a deferred dismantling is selected;•

when detailed information in support of the final decommissioning plan for thelater phases are not yet available.

The licensee should plan during the end of operation or very early in the transition
process how to interact with the competent authorities.
The application for decommissioning authorisation should be submitted in a timely
manner in order to avoid delays in the decommissioning. For example, depending on theregulatory framework, the decommissioning authorisation application can already besubmitted during the operational life of the facility.

2.4. References
IAEA (2005), Financial Aspects of Decommissioning, IAEA, Vienna.
NEA (2016a), Financing the Decommissioning of Nuclear Facilities, OECD, Paris.
NEA (2016b), Strategic Considerations for the Sustainable Remediation of Nuclear Installations,OECD, Paris.
NEA (2014), R&D and Innovation Needs for Decommissioning Nuclear Facilities, OECD, Paris.

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TECHNICAL ACTIVITIES TO PREPARE DECOMMISSIONING AND DISMANTLING

Chapter 3. Technical activities to prepare
decommissioning and dismantling

3.1. Introduction
This section addresses a range of key technical activities that may be conducted during
operation and after final shutdown to prepare for decommissioning and dismantling(D&D). Such activities supporting the transition from operation to decommissioning are
typically performed under the operation licence with its associated safety documentationand technical specifications, and they are usually performed by the operating organisation.
Figure 3.1 shows the typical preparatory activities that aim to reduce the risks or areusually envisaged to prepare for D&D. Annex C provides an overview about what
preparatory activities are allowed in various NEA member countries.
Figure 3.1: Typical preparatory activities
Shutdown
Cessation of operation

Operation

End state

Decommissioning

Transition
Post-operation

DismantlingSiteclean-up

Preparatory activities:

 Asset management
 Fissile material and spent fuel removal
 Shutdown of redundant systems
 Characterisation
 Material and waste management
 Decontamination activities

Most of these preparatory activities require a great deal of planning and in manycases also engineering activities. In order to facilitate and enable the timely
commencement of these activities, most of these planning and other necessary
preparations are recommended to be started and carried out in the last years of operation
prior to the final shutdown, although some of these activities can only be performed after
final shutdown during the post-operation phase. These preparatory activities may
continue and be completed in the dismantling phase.
In order to perform these tasks effectively, they need to be underpinned by validated
characterisation information supported by an appropriate organisational structure sothat knowledge is managed and transferred. In preparing for decommissioning,
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opportunities can also be taken from a review of the assets, a review of operational
instructions and maintenance requirements, as well as exploring technologicaldevelopment including research.

3.2. Asset management
Asset management and investment planning during the final years of operation should
consider the full life cycle needs of the asset along with the overall site plan,i.e. understand and reflect the decommissioning requirements, both in needs and intimescales. Clarity of the facility’s timeline is a key enabler to making asset investment
decisions, whatever the phase of life. This will ensure that the most appropriate
decisions are made, mitigating unplanned asset failures by identifying the true lifespanrequirements and understanding and managing obsolescence.
Examples of the future asset requirements that should be planned for during the final
years of operations are:•immediate risk and hazard reduction activities after cessation of operations;•final shutdown of equipment no longer required;•complex equipment or systems can be considered for replacement by simpler
systems more suited to the new demands;•

in case of deferred dismantling strategy, the facility should establish a system for
managing equipment ageing.

The conditions of systems needed during the transition and D&D are usually assessed
during regular in-service inspections. Knowledge of existing or anticipated obsolescenceof systems and equipment should be considered.
For the asset management, it is also important to have an understanding of theoperational background of the facility which includes any changes made to the facility
design and operational incidents/events that might not be adequately captured within
operational records, but instead may be confined to other local records. These may
include unofficial records such as those held by the operators themselves within
personal notes or their own knowledge. For example, the location of any areas of highradiation fields, damaged areas or items and additional information associated with theoperational history and that are vital for the subsequent efficient decommissioning thatmight be lost with the disappearance of the operating teams. This aspect feeds into
adequate waste and operational characterisation during the transition.
Wider site services and infrastructure requirements should be considered to ensurethat they are available and maintained for as long as is necessary to support the main
facility. There may be a point at which it becomes more cost effective to shut down site
services and install local systems instead, e.g. for steam or compressed air (see also
Section 2.3.5).
In general, systems can be categorised as: 1) those that are required to continue tooperate or need to be modified to support decommissioning; 2) those that can beremoved; and 3) those to be installed to facilitate decommissioning. Corresponding
activities may follow after the cessation of operation of the facility.
Also the facility maintenance regime needs to be reviewed to reflect the change infocus. This needs to be considered in respect to saving energy, material and humanresources while still ensuring that the safety requirements are met. This is particularly
important for the deferred dismantling strategy where the facility is left in a shutdown
condition for a considerable length of time before the start of dismantling activities. In
this case, it is recommended that the licensee performs at regular intervals a review of

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the facility as a whole. At any time, the facility maintenance has to be carried out
according to the requirements of the extant safety case.
In a nuclear facility undergoing transition from operation to decommissioning, SSCs
are being modified and/or retired and their mode of operation may be changing. The
operators of these systems need to understand these changes and how they might
mitigate any challenges to normal system operation. As such, it is very important that on
a continuous basis:•

facility and system drawings are updated;•system and facility operating procedures are revised accordingly;•

approval and authorisation controls are established and documented;•

scheduling and sequencing of systems to be changed, modified or retired areco-ordinated so as to have no impact on the systems and processes required for
operations during the decommissioning project;•

quality controls to ensure the above activities are developed and implemented.

3.3. Fissile material and spent fuel removal
Spent fuel represents more than 99% of the radiological inventory of a nuclear power
plant (NPP) and its removal leads to a first significant decrease of radioactive inventory
during the decommissioning (see Figure 3.2). The second main decrease of the activity
inventory is a result of the dismantling of activated materials, such as the reactor
pressure vessel internals.
Figure 3.2: Decrease of a nuclear power plant’s activity inventory (exemplary depiction)
1.0E+22
1.0E+211.0E+211.0E+20
Activity in Bq

1.0E+19
1.0E+18
1.0E+17

1.0E+17
1.0E+16
1.0E+15

1.0E+141.0E+141.0E+13
Activity after shutdown

After spent fuel removal

After dismantling of activatedmaterials

Early transfer of the spent fuel to interim storage or an off-site storage facility may
facilitate decommissioning activities and significantly contribute to cost reduction, due tothe reduced requirements to maintain dedicated resources and facility systems.
Therefore, the preliminary activities are:•unloading of the reactor vessel (hot spent fuel, damaged fuel) in power reactors;

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emptying the cooling pools containing older spent fuel elements (cooled spent fuel)and damaged fuel;•at other nuclear facilities, removing the nuclear fissile material from the facility
storage to an appropriate interim storage.

The removal and transfer of spent fuel are part of standard operations under theoperation licence. Where there is no fuel reprocessing facility available or where national
regulatory framework does not foresee spent fuel reprocessing, the transfer of the spent
fuel to disposal is the preferred option. However, the repositories for spent fuel are not
yet available in NEA member countries and thus international practices and approaches
vary from country to country, e.g. with respect to their interim storage (see case studies).
If no repository exists, alternative solutions must be studied by the utility such as:•storage at site in dry conditions (transport and storage casks);•

storage in wet conditions (pool);•storage in a centralised area.

For other fissile material different solutions may have to be considered taking into
consideration the national policies and the condition of the material.

Spent fuel island concept
In order to facilitate removal of SSCs that have formed part of the original facility forspent fuel handling and storage, a decision needs to be taken whether they can be
modified to properly cope with the new situation. Some operators have elected to install
a completely new spent fuel pool (SFP) support system, sometimes referred to as an SFP
island. The SFP island is functionally and operationally equivalent to the original
subsystems. However, the SFP island is typically much smaller, because there are lower
requirements to manage the heat load represented by the spent fuel as this has alreadyhad time to cool and no new spent fuel is being produced. As the SFP support systemfootprint is a lot smaller than the original plant it is more versatile and therefore can beremoved more easily after use. Modified SFP support systems require thorough review
and approval before they are put into regular service.
The IAEA safety report, “Safety Considerations in the Transition from Operation todecommissioning of Nuclear Facilities” (IAEA, 2004) gives more guidance on activities
associated with safe management of spent fuel at the end of NPP operations.

3.4. Shutdown of redundant systems
Systems that are not required anymore to maintain the safety of the facility can bede-energised or shut down after cessation of operation, i.e. corresponding systems will beswitched off and remain unpressurised and cold.
This also includes the drainage of circuits which may reduce the fire load within thefacility or reduce the hazards from spills and internal flooding. However, the drainage ofcircuits may also generate new varieties of waste, which may be different (in volume or
chemical composition) from waste known from facility operation. This new waste
inventory needs to be included in the waste management strategy and the integrated
waste management plan (see Sections 2.3.2 and 3.6).
These kinds of activities are preferably to be planned and carried out by experienced
operational staff.

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3.5. Characterisation
Characterisation is one of the key activities in decommissioning preparation but also
throughout the entire decommissioning project. It plays a key role in providing thenecessary confidence and understanding about the initial/current state of the facility. It
also provides important input for both the dismantling and waste management planning.
A well-performed characterisation supports the “no surprises” outcome, or at least
reduced uncertainties, associated with the execution of the decommissioning mission.
Characterisation refers to the process of gathering information to support decision making
or underpinning of assumptions through the application of measurement or analysis
techniques. Characterisation should be based on clear objectives and only be done when
there is a demonstrated benefit, i.e. a clear need for information to make decisions, reduce
uncertainties or underpin assumptions. Wherever practically possible, data quality
objectives (DQO) should be defined.
The outcomes of characterisation are:•understand conditions of facility – radiometric, chemo-toxic, biological, physicaland structural;•

define amount, location and composition of contaminants (radiological and nonradiological) and the associated physical parameters;•

support a categorisation of SSCs and site areas (including ground water) incontaminated, potentially contaminated and non-contaminated areas as a basis
for zoning or implementation of a graded approach for clearance.

Good knowledge about the physical properties is important when it comes todecontamination (in situ or during waste treatment) prior to clearance or downgrading
from, for example, intermediate-level waste (ILW) to low-level waste (LLW). This isfurther discussed in the materials and waste management section below.

Categorisation of SSCs and site areas
Prior to implementing the characterisation sampling and measurement campaign fordecommissioning, it is recommended to make an initial categorisation of the facility
based on the evaluation of available historical information as discussed above. The
purpose of this categorisation is to define SSCs and site areas as contaminated,
potentially contaminated and non-contaminated. The number and definition of thedifferent categories need careful attention to address the different needs for future work.

Planning and carrying out characterisation
Already during the final years of operation several important characterisation activities
can be performed. Typical activities are:•Determining the volume and the radiological properties of operational waste held
up within the facility.

•

Reviewing historical information of importance to understand the conditions of
the facility and changes in the operational conditions and procedures, which inparticular include: operational records, incidents/events and abnormal operation(broken barriers, etc.), and facility modifications like changes in the usage of the
facility.

•

Assessment of historical characterisation data collection in the light of current
requirement.

•

Physical inventory of systems and structures.

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Early identification of potentially problematic wastes arising duringdecommissioning to allow the development of management options so that theirimpact on the decommissioning is minimised.

•

Definition of the chemo-toxic and other non-radiological hazards throughout thefacility.

•

Characterisation for decommissioning of remote areas not expected to be affectedby the remaining operation. Identification of the extent of contamination in soil,
subsurface and groundwater is essential for decommissioning planning andtherefore collection of the information should be started during the operation of
the facility and expanded after the final shutdown.

After final shutdown and especially when all operational waste has been removed
further characterisation activities can be performed. The outcome of thesecharacterisation activities is of major impact for the planning of the dismantling andwaste management activities. The data, as well as the overall conclusions drawn, play animportant role in the planning of other activities like the health physics activities.
It is important that characterisation activities are planned and delivered in a
structured way at each step of decommissioning. Characterisation will need to beprioritised with a clear objective and defined output (i.e. doing only the characterisationthat is needed and avoiding the temptation to gather additional information that has noclear purpose in order to ensure effective use of resources). Where possible, it is worth
integrating characterisation into other tasks, combining different types of characterisation
within a single project and making full use of the operational status of the facility. Ifcharacterisation activities are planned in parallel, like radiological and non-radiological,
they should be cross-checked and combined, if this could mean avoiding double work andresource constraints.
The management of the information is crucial. A qualified database system should betaken into operation early and a quality plan should be mandatory to secure thecredibility of the data.
A good co-ordination of the characterisation activities with the decontamination anddismantling planning activities is recommended. A detailed radiological characterisation
aiming at detecting very low radiation levels in rooms in which contaminated systems
will be exposed during dismantling will partly be a waste of resources.
As well as careful planning and dedicated infrastructure, the different characterisation
activities need a knowledgeable staff with the right profile for its implementation.
Opportunities should be sought to combine characterisation tasks with other activities.
Characterisation information can be gathered during planned inspections and certain
activities in areas not accessible during normal operation can be performed during outages.
It is also essential to have a framework in place so that characterisation informationis recorded and maintained in a secure, retrievable and understandable manner.
Experience has demonstrated that a lack of thorough and validated information will leadto a significant rework and introduce pessimisms and delays into the subsequentdecommissioning and unclear safety case requirements.

Definition of nuclide vectors by material source and time
Nuclide vectors, sometimes referred to as “fingerprints” or “scaling factors”, are commonlyused to consign radioactive waste for treatment and disposal during decommissioning.
The main objective with the nuclide vectors is to define the relation between easy tomeasure nuclides like Co-60 and Cs-137 and nuclides which cannot be determined in a
simple way (in situ and/or a laboratory environment). The latter can be, for example, lowenergy betas like Cl-36.

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Typically, total gamma or the nuclide specific gammas are measured when waste
packages or structures are measured for clearance, to gather transportation informationor when waste is qualified for disposal. The other nuclides are determined by correlation
using the nuclide vector.
For the decommissioning project, all areas considered as contaminated (i.e. it has acontamination history and is expected to be contaminated) or potentially contaminated(i.e. it can be contaminated but no known contamination) should be sampled to get anunderstanding of the radiological status. Some of these samples should be analysed for alonger series of nuclides aiming to define or validate the nuclide vectors fordecommissioning. For the majority of the samples, less sophisticated analyses can beused. It is recommended to develop specific nuclide vectors for decommissioning.
Although these vectors can be similar to the operational ones, experience shows thatimportant differences can occur since operational vectors reflect the current situation of
the nuclear facility. Whereas for decommissioning, the various additional aspects have tobe taken into consideration when determining nuclide vectors, such as average decay orconditions when historical events took place.
Special attention should be paid to the location of samples and the sampling andanalysis process, which involves the necessity of advanced radiochemical analysis.
A way of sampling optimisation should be developed with the aim of saving costs andimproving the results. A progressive approach used in Spain comprises:•

Classify the samples by both origin and the simplest or easiest values measured,
like dose rate, total alpha or beta.

•

For every origin, perform composite samples from the ones that are inside ofpredefined interval ranges.

•

Send for radiochemical analysis the lowest possible number of those composite
samples trying to cover a wide range of values and with enough activity to be
assured that higher values than minimum detectable activity (MDA) will beobtained.

The definition of nuclide vectors is a very important part of the characterisation fordecommissioning. It typically involves non-destructive and destructive sampling, proper
analyses in line with defined DQO.
The DQO for individual nuclides may be largely dependent on the further use of theinformation and the specific end state. Certain nuclides are of large importance for
qualifying waste for disposal but are more or less not of interest when it comes toclearance (due to high clearance levels).
Typically, a decommissioning project requires very few nuclide vectors for activatedmaterial (if applicable) while contaminated materials, which are distributed over asignificantly larger area, may need in the order of ten vectors.
It is likely that additional surveys and measurements will need to be carried out
during conduct of D&D in order to reconfirm the validity and applicability of the nuclide
vectors or to update them. A typical example when an update of a nuclide vector isneeded is after having performed a chemical decontamination.
Further guidance on planning for characterisation is provided by the NEA report“Radiological Characterisation for Decommissioning of Nuclear Installations” (NEA, 2013).
Upon completion of the different characterisation activities the categorisation may
have to be updated/corrected.

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3.6. Materials and waste management
3.6.1. Planning and preparations
The planning of the materials and waste management strongly hinges on thecharacterisation (see Section 3.5) with regards to radiological content as well as physical,
chemical and, when applicable, biological properties. As discussed earlier in thisdocument, it is of fundamental importance to have a materials and waste management
strategy and a waste management plan for the radioactive or potentially radioactive
waste (see Sections 2.3.2 and 4.2).
The waste management plan may not be limited to just solid radioactive waste fromdecommissioning but also waste from residual operation as well as aqueous and gaseous
wastes accruing throughout the decommissioning. The decommissioning radioactive waste
inventory must adequately identify the quantities and types per category of radioactive
waste and potentially radioactive waste that are to be generated during decommissioning.
Through the drainage of the system during the post-operation phase, various liquid
wastes are generated that may need special attention. Depending on the type of facility
the potentially problematic waste will vary. Common for all types of facilities is thatwaste with multiple hazards, such as radiological and toxic hazards, should be avoided. If
not possible this type of waste should be given special attention. Some reactor types
contain large amounts of waste which can be problematic to dispose. A few examples are
sodium from fast neutron reactors, heavy water from heavy water reactors and/orgraphite from, for example, MAGNOX reactors.
There is a legal requirement in most countries for the licensee (the plant operator) toreport, on a regular basis, the inventory of radioactive waste. All countries in theEuropean Union and those who are signed up to the IAEA must provide radioactive waste
inventory data.
The radioactive waste inventory data is an important input in, for example, theplanning of national repository programmes.
Experience has demonstrated that if a waste management plan (evaluating waste
volume, variety, composition, treatment and conditioning) covering remaining
operational waste and the forecasted decommissioning waste is developed andimplemented prior to final shutdown, there is a greater likelihood that operational waste
will be adequately conditioned in time and by then the dismantling not delayed.
Furthermore, it will also reduce the risk for delays of the decommissioning due to waste
management issues.

3.6.2. Conditioning and removal of operational waste
The conditioning and removal of operational waste is important during transition due toits potential to adversely affect safe decommissioning and to reduce source
term/background levels. Removal of most operational waste during transition isrecommended in IAEA Safety Standards (IAEA, 2000, 1999a, 1999b and 1999c). But there
may also be other reasons and purposes for early removal of operational waste such as
freeing up space for buffer storage of waste from D&D.
The objective is to evacuate such waste to a disposal site, including treatment
packaging and transportation. The decommissioning project organisation has to ensurethat waste generated during preparatory activities, such as decontamination wastes,liquid waste drained from the systems or solid waste as a part of pre-dismantling
activities, can be accepted at storage or disposal facilities.
If it is not possible to remove it during the transition, for example because the wasteroute is not available at that time, it should be stored at a location and in a form with aminimum impact on the decommissioning process.

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When operational or legacy wastes are to be managed during the dismantling phaseas opposed to being exported during transition or clean-out, the facility operator has toensure that sufficient information is retained in a retrievable format to provide thedecommissioning organisation with sufficient information to make accurate decisions
about how to treat these kinds of waste.

3.6.3. Partial dismantling during the post-operation phase
In some countries, piping and system heat insulation is removed early after final
shutdown to improve the accessibility of equipment. Although this practice may generatevery high volumes of LLW, asbestos or insulating material requiring temporary storage, it
is considered good practice as it helps to enhance characterisation of both the insulationmaterials and the equipment. It may also save time on the critical path which results incost savings. Similarly, because the risks associated with non-radiological hazards – suchas asbestos – do not decrease with time, the removal of conventional waste may result inan overall decrease in risk to facility operators and workers conducting the dismantling
activities. Consequently, in some countries, waste containing asbestos, oils or otherchemicals is removed as soon as possible from buildings containing radioactive material.
A fire protection programme should be implemented for managing the oils andchemicals. After waste removal, the fire protection system needs to be assessed
according to the remaining risk and some fire protection features may be retired or
require modification.

3.6.4. Logistics of material and waste management
There are many logistical issues with managing the materials and radioactive waste in a
decommissioning project. The main purpose of a logistic and waste stream concept is to
avoid bottlenecks during the decommissioning caused by dismantled materials andwaste that hinder the dismantling activities and thus decommissioning progress.
It is highly recommended to develop a logistic and waste stream concept inaccordance with the materials and waste management strategy (see Section 2.3.2), thedismantling strategy (see Section 2.3.4) and the facility modification strategy (seeSection 2.3.5). Preferably, and where possible, the planning of the logistics should begin to
be explored when the facility is still in operation.
One of the key challenges in materials and waste management is how especially large
components and components with high dose rates can be removed. These parameters
were not in focus when facilities were designed and built. This causes a number ofchallenges during decommissioning which may be partly mitigated if identified early.
A basic decision in the context of the logistic and waste stream concept is directly
linked to:•

decoupling material and waste treatment from the dismantling activities;•

ensuring sufficient storage capacities including buffer storage capacities;•

definition of a quality standard for the treated waste (in compliance withregulatory framework and the waste acceptance criteria of a repository);•transport regulations for radioactive waste;•location of waste and materials treatment (within existing facilities or in a new
facility on-site, sending off-site to a specialised facility or centre, fleet or
programmatic approach to optimise the location and capacity of treatment
facilities).

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3.6.5. Waste processing capabilities
Very important input parameters for planning on-site waste processing capabilities aretypes and quantities, both in total but also per day or week, of radioactive waste that is tobe treated and processed. Iteration with the logistics is important to make an overall
optimisation.
In order to identify requirements for adaptation/development of the radioactive waste
infrastructure, to ensure it is appropriate for the decommissioning need, it is importantto understand:•the radioactive waste management requirements of the programme
forthcoming decontamination or clean-out and decommissioning activities;•

the current capability of the existing waste management infrastructure on the site;•

the available off-site alternatives;•

the available radioactive waste technologies and techniques that may be installedor can be provided by external contractors.

for

It might be of advantage to share processing infrastructure across a number ofnuclear facilities or to use external service providers rather than constructing a facility oneach of the sites.
For this evaluation it is important to analyse:•

value of early removal of waste in terms on decommissioning progress;•

overall life cycle costs including investments in buildings, equipment, organisation,
etc.;

•

decommissioning liabilities for new facilities;•

how an in-house waste treatment facility will affect the decommissioning project;•transport safety constraints including stakeholders’ sensibility on nuclear transport;•

national waste management strategy.

An investment in a separate waste treatment facility will separate dismantling fromthe waste management which may be a significant advantage for a decommissioning
project (see Section 2.3.5).

3.7. Decontamination activities
In some countries, cleaning and/or decontamination efforts have been strongly
influenced by the cost of such undertakings. The licensee has to consider performing
cost-benefit studies to evaluate the time, capital and resources needed to conductcleaning and/or decontamination and to determine whether there is a benefit (IAEA, 2004)
while ensuring a same level of safety of workers and environment throughout the D&D.
In general, the benefits of commencing cleaning and decontamination as early as
possible for a facility that has elected an immediate decommissioning strategy arevarious as they lead to:34•

reduced doses for workers;•

reclassification of material and structures;•

reduced efforts in required shielding for dismantling work and associated waste
management;•

reduced dismantling efforts, e.g. by enabling work to be performed directly byworker instead of remote controlled works. This may also shorten working time.

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Furthermore, performing the cleaning and decontamination shortly after shutdown
enables the use of systems and components from operations during and for the systemdecontamination activities. Whereas, for a facility that has chosen a deferred dismantling
strategy, the benefits of a full system decontamination may be reduced, as decay of thesite source term during the deferral phase will result in lower worker doses when theactive decommissioning is carried out.
Several NPPs have decontaminated the highly contaminated systems (mainly primarycircuit) to facilitate D&D operations by lowering the risk of airborne radionuclides,
reducing radiation fields and simplifying radioactive waste disposal.
However, attention needs to be paid during the planning of cleaning and/or
decontamination to negative side effects or impacts of such activities that may also
influence D&D activities later on. Experience has shown that the cleaning and/or
decontamination (both radiological and non-radiological) of systems and components
during transition may result in unsafe conditions if not properly planned andimplemented. Such operations may: i) cause changes in radiological or non-radiologicalconditions, e.g. displacement of the nuclide vector towards the alpha-branch, resulting inhigher than normal exposure or unplanned exposures, or ii) generate flammable, noxious
or deadly gases or conditions that may affect workers without their being aware of
exposure. To prevent negative side effects, it is recommended that the operator of the
facility determines which SSCs can be cleaned and/or decontaminated and when.

3.7.1. Facility cleaning and decontamination
Radioactive inventories in the form of liquid inventories within process vessels andpipework and in the form of deposited and adsorbed solid materials can be foundthroughout the facility. Facility cleaning and decontamination forms a key part of a
facility’s hazard management strategy during the post-operation phase, removing
inventory so that:•criticality hazard is removed;•radiation hazard is reduced;•

no heat generating material remains;•there is no significant flammable gas generation;•

chemo-toxic hazards are minimised;•

the potential for environmental damage from a leak is reduced;•

dose rates are reduced in areas to limit the need for full remote dismantling and to
reduce the dose rates for future decommissioning activities.

3.7.2. System cleaning or decontamination
System cleaning or decontamination de-risk future dismantling activities throughreduction of chemo-toxic and radiological hazards. A wide range of risks and operational
considerations should be taken into account when developing a decontamination plan:•justifying doses to the workforce, environment and public and maintaining them
ALARP/ALARA;•

ensuring that effluents will be subject to appropriate monitoring;•ensuring that any proposed decontamination is appropriate and justified based ona balance of benefits versus disadvantages;•

reducing overall facility hazards to enable swifter decommissioning tasks;•

using a delay and a decay approach either for decontamination or fordecommissioning activities if the decommissioning timescales allow.

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Decontamination activities should be benefit-driven, informed by characterisation
and balanced against safety, cost and the potential environmental impact. A cleaning or
decontamination plan should be developed that:•

identifies any benefits from the use of novel processes and reagents to deliver thefacility cleaning (note that use of new reagents or novel use of existing reagents
may trigger the need for regulatory approval or disposal challenges);•

identifies where enhanced cleaning could offer earlier hazard reduction and longterm realisation of efficiency gains and cost savings across the facility life cycle;•

ensures that any effluents generated can be treated using existing facilities, tocreate discharges that are within permitted limits and meet the regulatory
requirements;•

ensures that such activities are not implemented in such a way as to cause unsafe
conditions;•defines a pragmatic balance between trying to get the facility as clean as possible
and delivering a reasonable level of risk and hazard reduction for the cost andeffort required;•seeks to effectively remove radiological and chemo-toxic inventory. If possible trial
cleaning should be undertaken during plant outages in the final years of operation;•

uses the incumbent nuclear trained workforce, established principles and operating
practices, as far as possible, to deliver the cleaning or decontamination goals;•

maximises use of in-house systems and native reagents to deliver process system
washouts.

3.8. References
IAEA (2004), Safety Considerations in the Transition from Operation to Decommissioning of
Nuclear Facilities, Safety Reports Series No. 36, IAEA, Vienna.
IAEA (2000), Predisposal Management of Radioactive Waste, Including Decommissioning, Safety
Standards Series No. WS-R-2, IAEA, Vienna.
IAEA (1999a), Decommissioning of Medical, Industrial and Research Facilities, Safety Standards
Series No. WS-G2.2, IAEA, Vienna.
IAEA (1999b), Decommissioning of Nuclear Fuel Cycle Facilities, Safety Standards Series No.
WS-G2.4, IAEA, Vienna.
IAEA (1999c), Decommissioning of Nuclear Power Plants and Research Reactors, Safety
Standards Series No. WS-G2.1, IAEA, Vienna.
NEA (2013), “Radiological Characterisation for Decommissioning of Nuclear Installations”,
NEA/RWM/WPDD(2013)2.

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Chapter 4. Regulatory framework and authorisation
for decommissioning

This chapter describes the typical aspects of the regulatory process to authorise
decommissioning activities. An early engagement of the licensee with the regulatory
authority facilitates this process. Authorisation processes potentially have a verysignificant impact on the decommissioning schedule.
The requirements for decommissioning in various NEA member countries are
summarised in Annex C.
To meet the objectives and needs of decommissioning, a number of modifications
might be required to adapt the regulatory framework and authorisation process. All NEA
member countries contributing to this report have reported having an establishedregulatory framework for decommissioning. This framework typically requires that theregulator grant an authorisation for decommissioning before dismantlement work can
begin.
To ensure successful transition to decommissioning, the following key aspects should
be considered:•An early engagement of the licensee with all regulatory authorities.

•

Clarifying the roles of all regulatory authorities involved in the authorisation of
decommissioning and harmonisation of regulatory requirements and criteria
between them.

•

The licensee is responsible for clearly understanding the regulator’s expectations
for the regulatory process so that regulatory submittals can be made and go
through the authorisation process in an efficient manner.

•

Both the regulatory authorities and the licensee are recommended to initiate an
early engagement of all stakeholders.

•During the transition, the regulatory authorities should adjust their approaches tothe changing risk profile during decommissioning and remain flexible toadequately address this change.

4.1. Responsibilities during the transition
Decommissioning of nuclear facilities involves several organisations, the licensee, its
contractors, regulatory authorities and governmental institutions. The requirements forresponsibilities associated with decommissioning as well as typical responsibilities ofeach main party involved are described in Section 3 of the IAEA GSR Part 6 (IAEA, 2014).
The present report highlights only key responsibilities which are considered vital for asmooth transition.
During the transition to decommissioning, the main responsibilities should beassumed by the regulatory authorities and the licensee:•

The regulatory body should provide proportioned regulatory response by
establishing the requirements for the transition to decommissioning.

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The licensee should ensure that the facility is maintained in a safe way at any time.

•

The regulatory authority and the licensee should initiate the process of culturechanges and/or transfer of responsibilities.

The regulatory authorities and the licensee will also have a role in harmonising theregulatory approach with other institutions (see also Section 4.1.2).
The regulatory authority should establish the safety requirements fordecommissioning, including requirements for management of the resulting radioactive
waste, and adopt associated regulations and guides. Some key responsibilities are:•establishing the need and the requirements for a decommissioning authorisation;•

establishing the expectation for the content of the final decommissioning plan andsupporting documents (or other submittals) and the process for review or approval;•

establishing requirements relating to the decommissioning of facilities, including
criteria for clearance of material from regulatory control, in accordance withnational policy;•

establishing requirements and criteria for termination of the authorisation fordecommissioning and especially when facilities and/or sites are released withrestrictions on their future use;•

providing stakeholders with an opportunity to comment on the final
decommissioning plan before their approval, as required by national regulations.

The licensee plans for decommissioning and conducts the decommissioning actions
in compliance with the authorisation for decommissioning and with requirements
derived from the national legal and regulatory framework. Some key licensee
responsibilities concerning the regulatory process are:•notifying the regulatory body (or the government, if so required) prior to the final
shutdown of the facility;•

performing safety assessments and environmental impact assessments in supportof decommissioning actions;•ensuring that properly trained, qualified and competent staff are available for thedecommissioning project;•submitting a final decommissioning plan and supporting documents for review
and approval by the regulatory body, in accordance with national regulations, inorder to obtain an authorisation to conduct decommissioning.

In relation to preparatory activities (see Annex C), most NEA member countries(Canada, France, Germany, Spain, Sweden and Switzerland) allow preparatory activities
under the operating licence, but having some kind of approval or an amendment ofoperating licence. In France, activities to reduce risk and hazards should be defined andsubmitted to the French Nuclear Safety Authority (ASN) prior to authorisation for
shutdown.
In the case of Spain, an amended of operating licence is required for the postoperation phase. The United Kingdom allows decommissioning activities and preparatory
activities under the nuclear site licence conditions and, in the case of the United States,
all the pre-dismantling and decommissioning activities are carried out under theoperating licence.
In Switzerland and France, some particular preparatory works are possible uponrequest and in accordance with existing authorisation or permission regulations(e.g. provided by the operation licence), such as installation of decommissioning and

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supply facilities (but in France it is forbidden to put them into operation) or thedismantling of equipment in the turbine hall.
So as to enable planning and execution of preparatory activities without any approvalof decommissioning in an effective way, NEA member countries are advised to have inplace and provide an appropriate framework in national regulations and guides, such as
definitions for major, minor or preparatory activities.

4.1.1. Authorisation process for decommissioning
Authorisations for decommissioning are granted in accordance with the national legal
and governmental framework. All participating NEA member countries confirmed having
established regulatory frameworks for decommissioning. Decommissioning is a stage ofthe life cycle of the facility and the authorisation process for decommissioning should
follow the basic licensing principles. A set of requirements to be met prior toauthorisation of decommissioning should be established by the regulatory body as earlyas possible before the post-operation phase.
Depending on the size and the complexity of the facility, the decommissioning may
be divided into one or more phases. Each of these phases may be then subject to a
separate regulatory approval.
Having an established post-operation phase will help with the adaptation of
decommissioning “pre-authorisation” processes, for example, steps of early approval ofactivities, minimisation of duplication of effort through the different steps and may allow
for some steps to be conducted in parallel.
It also provides for a clear division of responsibilities, gives the public opportunities
for early participation and ensures that the most important safety issues are dealt withproperly in the post-operation phase.
The authorisation process may also include agreements and commitments madebetween the regulatory authorities and the licensee (e.g. in the form of letters exchanged
or statements made in technical meetings). To streamline the authorisation process,memorandums of understanding (MOU) could be signed between the regulatory
authorities to address specific cases of overlapping jurisdictions.
In the case of fleet or programmatic approaches to decommissioning, as described in
Section 2.3.7, an optimisation of the authorisation process could be considered. The
regulatory body and the licensee could agree that the major application documents insupport of the final decommissioning plan could be developed at the corporate level andsubmitted to the regulatory body as common for all fleet facilities.
As the regulatory body’s approval of decommissioning activities is of criticalimportance to the decommissioning, licensees should ensure that regulatory
requirements are reviewed and submittals made as early in the decommissioning
planning process as possible to facilitate the beginning of dismantlement.

Type of authorisation
Authorisations should cover all stages of the lifetime of a nuclear facility. As such, thedecommissioning should be authorised in accordance with the national regulatory
framework.
Most countries require a decommissioning licence or some kind of authorisation fordecommissioning. In Canada, France, Germany, Spain and Switzerland, a decommissioning
licence is required prior to decommissioning. While in Korea, the United Kingdom and theUnited States, the decommissioning is conducted under the operational licence, which iseither amended to modify the conditions or else a specific approval for decommissioning is

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REGULATORY FRAMEWORK AND AUTHORISATION FOR DECOMMISSIONING

required. In Sweden, D&D is conducted under the operational licence according to Nuclear
Law, but a new licence for D&D is required according to the Environmental Act.

Authorisation time frames
Time frames relating to the authorisation process, the facility status and activities
performed at the facilities are not always specified in the regulations and vary fromcountry to country. Most countries use the term “transition period” for the phase startingwith the cessation of operation (final shutdown) and ending with the granting of theauthorisation for decommissioning or at the date of approval of the final
decommissioning plan. Some countries use the term “transition period” to define theperiod starting with notification of final shutdown, or the starting time of the transition
is not specifically defined. In France, the licensee must declare its intention to shut down
at least two years before the effective shutdown. Then it has a maximum of two years to
submit an application for decommissioning. In the case of the United States, the licensee
shall, within 30 days after the decision to permanently shut down the plant, submit awritten certification of completing the defueling and permanent cessation of operation to
the regulator. Furthermore, the licensee will typically submit a post-shutdown
decommissioning activities report (PSDAR) at the same time as the above mentioned
certifications, which basically allows major decommissioning activities to begin within 90
days of submitting the PSDAR.
The time frame for authorisation of decommissioning is either defined in thenational regulations or established on a case-by-case basis. Some countries, for example
France, have established timelines for the deliverables and the approval steps of thelicensing process. The decree authorising decommissioning should come into effect four
years after the submission of the licence application. In Korea, the licensee should apply
for approval of decommissioning within five years of final shutdown. In the majority ofother NEA member countries, the authorisation process is rather based on achieving
milestone activities and submissions leading to approval of decommissioning than on
specific time frames.
In conclusion, there are several time frames for submitting the application documents(depending on the country) such as:•at the date of final shutdown;•no later than two years after the final shutdown announcement;•

on a case-by-case basis (no set time frame).

4.1.2. Harmonisation between decision-making authorities
Harmonisation between decision-making authorities (jurisdictions) within theauthorisation process of a decommissioning project regard a variety of legal andregulatory aspects, which might be governed by different competent regulatory bodies
within a single country. These aspects might comprise of:•environmental protection;•

occupational health and safety;•

building legislation.

The leading authority, i.e. the nuclear and radiological safety authority, therefore
should identify, at an early stage during preparation for decommissioning, the relevant
competent authorities. These might be:

40•

environmental protection agency;•

health authority;

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REGULATORY FRAMEWORK AND AUTHORISATION FOR DECOMMISSIONING•

building authority;•

local authorities.

The leading authority should set up adequate communication channels with alldecision-making authorities involved in the authorisation process in order to:•create awareness of the coming project, scheduling aspects and timescales inorder to provide adequate resources;•

clarify the roles, including limitations of each authority within the authorisation
procedure;•

inform about the technical aspects of decommissioning in general and withrespect to the actual project;•resolve and/or reach agreement between agencies when criteria differ. These
agreements may take the form of MOU signed by the authorities involved.

A formal involvement procedure of the relevant competent authorities is often
governed by a procedural step within the environmental impact assessment. This step
might also include a scoping procedure, which:•should be regarded as a consultation appointment between the licensee and therelevant competent authorities;•

might be used to define which environmental impacts need to be assessed;•

is not meant to decide on individual aspects of the environmental impact
assessment;•

cannot replace a formal public hearing.

4.2. Application documents and preparation for decommissioning
The specific application documentation to be submitted by the licensee as well as theauthorisation process differs in each country. While there is no general consensus on thenaming and content of these documents, some general lines of similarity can be found,
specifically the information required by the regulatory authorities in support of theapproval of decommissioning.
In most countries, the documentation submissions must be reviewed and accepted by
the competent authorities prior to the start of decommissioning, while in other cases,
some documentation is for informational purposes. A summary of the documentation
requirements for authorisation of decommissioning in some NEA member countries isprovided in Annex C of this report.
Although the information provided in the application documents varies among NEA
member countries, the majority of topics that are covered are common to most NEA
member countries. Basic documentation for decommissioning and its content may be thefollowing.

4.2.1. Final decommissioning plan
The initial decommissioning plan, which is required in some countries already as early asat the siting and design stage of the facility’s life cycle or at the latest during its operation
and which has been regularly updated, forms the basis of the final decommissioning plan.
Once a decision to permanently shut down the facility is made, a final decommissioning
plan is to be developed and submitted to the regulatory authority.

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The final decommissioning plan aims to demonstrate the feasibility ofdecommissioning in accordance with the radiation protection requirements, estimationof waste quantities, costs and schedules. The detail and complexity of a final
decommissioning plan should be commensurate with the complexity of the facility being
decommissioned. It should be supported by the safety assessment covering the planned
decommissioning activities, and identifying major systems and equipment that may be
used during decommissioning.
The final decommissioning plan could be a stand-alone document containing all theinformation required by the regulatory authorities or supporting documents are to beprovided in addition. In some NEA member countries, there is not a specific document
called “final decommissioning plan” required, but independent documents are drawn up
with specific content.
The final decommissioning plan typically includes the following elements:•

Decommissioning strategy and the rationale for the preferred decommissioning
option.

•Regulatory framework and radiological criteria for decommissioning.

•

Facility description, site and life history of the facility.

•

Description of the initial state and radiological characterisation of the site,
including radiological historical data.

•

Description of facilities, SSCs needed to perform the decommissioning project.

•

General decommissioning project, time frame and end state. Scope of each phasein the proposed decommissioning, if a phase approach is applied.

•

Safety assessments and environmental impact assessments, including theradiological and non-radiological hazards to workers, the public and theenvironment.

•

Description of the proposed environmental monitoring programme.

•

Description of the organisation and responsibilities of personnel involved in thedecommissioning activities, including the number of technical qualified personnel(personnel involved in radiation protection and safety). Skills and qualifications of
personnel.

•

Description of the quality assurance programme.

•

Waste management plan based on the strategy for managing all waste andmaterials from decommissioning, as described in Section 3.6 of this report.

•

A provision of the programme of the final radiation survey.

•

Description of the estimated cost of decommissioning and the source of funds.

4.2.2. Safety report
The safety report (sometimes referred to as safety case, safety assessment or safety
analysis report) includes the applicable safety and radiological regulations and criteria, as
well as the identification and analysis of risks under normal operational and accident
conditions, and preventative measures to be adopted. The content of this document may
be as follows:

42•

Safety criteria: radiological criteria for public and workers in normal operation andin accident condition. Radiological criteria for the release of materials, buildings
and site from regulatory control according to national strategy.

•

Facility description including the radioactive inventory.

•

Design criteria, safety functions and their associated SSCs.

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Safety assessment:– normal operationassessment;(workers andpublic):radiologicalhazards

andrisk– accident condition (public): postulated initiating events and consequenceassessment;•

Description of the radiation protection programme.

•

Description of the emergency programme.

4.2.3. Environmental assessment
If required by national regulations, an environmental assessment should be conductedprior to developing the final decommissioning plan. The purpose of the environmental
assessment is to support the development of the final decommissioning plan bydemonstrating that the decommissioning project will not cause adverse effects on theenvironment. The impact of any mitigation measures that may need to be applied should
be assessed in the safety report.

4.2.4. Decommissioning technical specifications
The requirements for technical specifications for some of the safety systems could be
downgraded to reflect the risk level of the decommissioning. If there is a significant
reduction of safety-related systems, some specifications could be removed.

4.2.5. Regulatory programmes
When not yet included in the safety report, several programmes and concepts providing
details on supporting processes for decommissioning performance to ensure the overall
safety of a decommissioning project need to be submitted as part of the authorisation
process. These programmes include:•

emergency programme: detailing the organisation, responsibilities and measuresplanned to address accident situations during decommissioning;•radiation protection programme:– occupational: includes the organisation, standards and criteria for radiation
protection and protective measures;– public: radiological criteria, airborne andprogramme and dose calculation to the public;

liquidreleases,monitoring•

quality assurance programme: a description of the quality assurance programme
including documentation and record keeping requirements;•

physical security programme, which is confidential and includes measures fororganisation, equipment, systems and physical security components;•

materials and waste management programme(s):– identification of types, masses and volumes of materials and waste, criteria forsegregating materials, type of conditioning for each type of waste, acceptancecriteria for storage and disposal for destination according with the national
strategy;– potential reuse or recycling of materials. Criteria and methodology for clearance
materials and buildings according with the national strategy.

•

environmental monitoring programme (radiological and non-radiological);•programme of the final radiation survey (radiological criteria, methodology andequipment to perform the final radiological survey).

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4.2.6. Details on financing the decommissioning project
For decommissioning authorisation, some countries may also require an update on thefinancing situation in order to ensure that adequate funding is available to complete thedecommissioning project. Therefore, a detailed cost estimate for decommissioning basedon the final decommissioning plan is expected.

4.3. Regulatory oversightThe broad range of safety, environmental and public policy issues that arise indecommissioning a nuclear facility are quite different from those during operation, andthey produce corresponding new challenges for the regulator. The regulatory body will
want to review its overall staffing and inspection plans for the facility to focus more on
the new organisational, human factors and dismantling issues and may augment staff
expertise in these areas.
Because of the organisational and human factor issues that will inevitably arise in thewake of cessation of operation of a nuclear facility, the regulator should be prepared to
conduct regular inspections to look for possible adverse trends in the overall safety
culture at the site.
Since the public health risks posed by a shutdown facility are substantially reduced
from those of an operating facility, the regulatory inspection programme should betailored to address the new regulatory challenges. For example, many of the challenges
involve regulatory policy questions rather than operator performance issues. Those
regulatory bodies that utilise resident inspectors at operating facilities may want toreplace the resident inspectors with periodic team inspections focused on special areas
such as ALARA programme implementation, worker radiation protection, site security,
operator’s contractor oversight, and looking for signs of deteriorating safety culture.
As decommissioning progresses, there may be periods of only routine activities in thefacility and the regulatory inspections can be scaled back accordingly. On the contrary,
there might be periods with activities in need of an intensified inspection programme,
like activities bearing a high radiation risk for the work force or periods with numerous
clearance campaigns of materials or site areas.
If the licensee chooses to place the facility in a safe storage mode for an extended
period, there will be reduced need for inspections to observe that safety and security
systems are not degrading. The regulator should continue to assure that the licenceconditions are maintained, including adequate funding for subsequent dismantlement.

4.4. Reference
IAEA (2014), Decommissioning of Facilities, General Safety Requirements Part. 6, IAEA,
Vienna.

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EXTERNAL STAKEHOLDERS

Chapter 5. External stakeholders

The final shutdown of a nuclear facility is often significant in terms of the socioeconomic factors. Early and effective stakeholder engagement is mandatory to build trust
within the community and establish early confidence in the decommissioning project. A
clear definition of the intended interim states and the end state of the decommissioning
project is the basis in order to communicate to the stakeholders the strategic decisions
taken to prepare for the decommissioning of the facility.
“External stakeholders” in decommissioning projects are manifold (see also Figure 2.1),
among them:•members of the public, directly or indirectly affected by strategic decisions taken;•(local) government;•

industry;•environmental interest groups;•

international stakeholders.

A stakeholder information plan should be established, which includes a strategy forthe identification of stakeholders and a stakeholder management plan based on a clear
communications strategy. Managed and structured communication with all stakeholders
will ensure that varying groups of stakeholders are kept informed of the strategic
decisions taken to set up the decommissioning project and have the opportunity toprovide input to the planning phase. In addition, this approach helps to identify
stakeholders that may jeopardise the decommissioning project delivery and timely
responses can be therefore be provided.
The stakeholder information plan should foresee public information programmes
using different media, like newspapers, brochures, online publications, etc. to:•inform the stakeholders about the authorisation process;•inform the stakeholders about the later supervision of the actual decommissioning
activities;•

explain technical aspects of decommissioning projects in general and the actual
decommissioning project.

Open communication should be promoted and exercised at all levels of theorganisation preparing for decommissioning and with all stakeholders as outlined by the
stakeholder information plan and associated communication strategy. Working closelywith all stakeholders during preparation for decommissioning will build relationships
and foster closer understanding of issues, which will, in turn, facilitate more effective
and closer interactions to resolve issues as they arise. This approach ensures that thequality of the decommissioning project planning will be improved. As part of the wider
communications strategy, communications would be expected to cover aspects such as:•

management policy, objectives and strategy;•

the management system and associated processes and procedures for conducting
decommissioning activities;

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EXTERNAL STAKEHOLDERS•

the current status of decommissioning planning and waste management activities;•

technical and quality issues (e.g. problems having long-term implications and theirresolution, planned improvements and innovations);•

radiological issues (e.g. trends in doses and in releases to the environment,
evaluation of accidents and other incidents);•

regulatory and statutory issues;•present status of the facility;•

health and safety issues;•environmental, security and economic impacts of the decommissioning activities;•changes in management arrangements and the continuity of responsible
management;•

maintenance of adequate financial resources to support the decommissioning
activities;•

opportunities for, and results from public involvement in decision making;•responses to questions and concerns.

These measures might also be useful to prepare for the public hearing to be held as aformal step within the authorisation process if such a hearing is required by national law
or subordinate legislation.
Nevertheless, it is also important to clearly explain that stakeholder engagement islimited and that the licensee, who is bearing the responsibility of conducting a
decommissioning project according to the regulatory requirements, has the right to takedecision in their entrepreneurial responsibility (no representative participation without
accountability).

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ORGANISATION TRANSITION

Chapter 6. Organisation transition

The objective of the organisation transition is to ensure that a suitably competent corporate
organisation is established in order to safely execute the decommissioning project.
This chapter describes various organisational changes that are recommended to beplanned and implemented during the transition of a facility from operation todecommissioning. In addition, it describes which main measures and procedures of theoperational stage need to be reviewed and adapted in order to follow, respond to andsupport D&D.

6.1. Introduction
As procedures for maintenance, radiation protection, operation, engineering, supply
chain, administration, waste management, performance improvement organisations, etc.,
differ from operation to decommissioning, a change in the organisation is required that isforeseen to implement the chosen strategy for decommissioning.
The intended decommissioning organisation structure should be clearly defined bymeans of an organisational chart, which can be used to clearly describe the key positions,management units and their respective interfaces. The responsibilities for different
activities, such as managing the waste, training, assessments, radiation protection,
procurement, surveillance, inspection, control of records, etc. are described in this section.
The authority held by managers and staff is defined in their respective job description.
The intended decommissioning organisation would be expected to have an integrated
management system in place, which includes work management processes that areappropriate to perform D&D activities. For example, the focus of the decommissioning
organisation is likely to rely far more on contactors than an operational organisation.
During the transition, the required decommissioning organisation needs to be set up in a
managed and structured manner.

6.2. The transition in terms of organisational change
The nature of the organisation transition will itself depend upon the chosen strategies fordecommissioning as discussed in Chapter 2. As an example, it might be intended that theorganisation that held the licence to operate the facility is chosen to continue throughthe post-operation phase and to deliver the D&D activities. In this case, the potential
overlap between operational and decommissioning functions will need to be managed
within the organisation as it is being transitioned.
A more common approach within NEA member countries is that decommissioning is
executed by specialist contractors under the oversight of a small management
organisation, which generally would hold the relevant authorisation for decommissioning.
In this case, the organisation transition would focus on aspects such as the competence ofthe chosen organisation, its internal processes for the delivery of work and maintaining
staff competence, as well as its record keeping in general. The management organisation
should keep resources for key positions such as radiation protection and safety, quality
assurance, engineering, waste management, project management and maintenance.

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ORGANISATION TRANSITION

There are NEA member countries (i.e. Spain and at some facilities in the United States)
where the site licence is transferred to a new organisation. However, there are still
contracts with the former operator.
The transition of the organisation has the overall objective of providing an overall
organisation capable and competent to execute the final decommissioning plan. The
overall organisation could include multiple specialised sub-organisations (e.g. residual
operation, radiation protection, engineering, maintenance, etc.). Based on the experiencein different NEA member countries, the previous operating organisation should be
reorganised and integrated into the overall organisation for decommissioning. The
following Figure 6.1 is an illustration of the organisation transition.
Figure 6.1: Typical organisation transition
Operation

Shutdown, cessation of operation

Decommissioning

Operating organisation

Decommissioning
organisation/contractors

Management system

Management system

Contractors

Operating licence

Decommissioning authorisation

The decommissioning organisation has to ensure that regulatory requirements aremet, that adequate processes are in place to assure and maintain a safe residual
operation of the facility and to conduct D&D activities safely and that a sufficient numberof qualified workers is present to carry on the decommissioning and residual operation
activities.
In the context of the organisation transition there are a number of areas that require
specific management to ensure success:•organisational changes, staff competence and management of resources;•

work control.

6.2.1. Organisational changes, staff competence and management of resources
This aspect is linked to the management systems area, as the skills required are morevaried and accompanied by more unknowns and different safety issues (e.g. radiological).
In this respect, a decommissioning organisation will feature a management system thatassists in driving innovation within a framework of competence assessment.
A significant change to organisational structure and purpose is a stressful time forthose within the organisation, and to be successful the process will require carefulmanagement to ensure that the required functionality of the organisation is maintained
during the transition. A plan to document the downsizing and other changes in theorganisation should be created and monitored continually to ensure that the plan is both

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on track and its objectives remaining valid. The changes to the organisation should bemade in accordance with a defined change management process which includes routine
stakeholder communication. In order to ensure the adequacy of staffing levels and otherfunctions during the transition, it is important to develop key performance indicators or
metrics to help define and measure both performance and organisational effectiveness toenable the prompt identification of any issues or risks that may require mitigation.
Various aspects of the decommissioning stage, such as early analysis and planning or
dismantling activities, can be generally subcontracted to specialised companies as
required. In this manner, the decommissioning organisation can subcontract some
aspects of the decommissioning to specialised firms and companies, and therefore theorganisational transition must assess this feature.
The new legal entity charged with delivery of the decommissioning mission willusually (but not always) separate from the previous operational organisation. In somecircumstances there may be some operational activities remaining on the site, whileother parts of the site are undergoing decommissioning. In this instance, the organisationtransition would proceed as normal, but with additional caveats associated with thepotential overlaps with operational areas of the site, such as at Sellafield in the United
Kingdom. A case study is presented in Annex A of this report.
The competence and leadership of the senior management play a key role in safe andefficient performance of a decommissioning project and as such there should be
sufficient oversight of the decommissioning project to ensure adequate corporate
performance and not just performance of the decommissioning activities themselves. In
this respect, during the organisation transition, assurance needs to be gained that the
managers and other leaders in the new organisation have the required competences toensure that the organisation can both execute its function and drive the required levels
of innovation. The competence of the organisation needs to include the ability toadequately oversee the appointment and management of subcontractors required todeliver various specialist phases of the project.

Management resources
Senior management should determine the amount of necessary resources, meaning
individuals, infrastructure, information and knowledge, suppliers, material and financial
resources. Information and knowledge should be managed as a resource.
It is important that the final shutdown preparation phase allows an optimum
preparation of the facility for its decommissioning, taking full advantage of the presenceof the operating personnel, with their extensive knowledge of the facility: operating
history, incidents, familiarity with the premises and the various equipment items, etc.
However, some activities will require outsourcing and/or recruitment.
The number of people involved in the organisation is likely to be reduced in NPP
decommissioning projects, usually after the fuel has been removed and primarydecontamination has been completed. Different approaches can be adapted to suit thefacility decommissioning and take into account the social aspects. If the decommissioningis performed on a site with other nuclear facilities still in operation, there could evolve asituation with a lack of human resources for the decommissioning project in general,since experienced people are usually more attracted to the facility still in operation.
The competences and skills of people required will be different from those in theoperation organisation. The variety of skills required for decommissioning is potentiallyextensive, including remediation/decommissioning projects with several areas such as:
safety/security, radiation protection, environmental protection, engineering, construction,
maintenance, site clean-up and materials and waste management. This factor influences
the reliance on contractors to deliver specialist functions during decommissioning,
meaning that the controlling mind organisation needs to be specifically skilful in their

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ORGANISATION TRANSITION

management. Thus, in this instance, the focus of the decommissioning organisation will
not be on the execution of work, but rather on its management by contract withassociated procurement and project management skills. Thus, the availability of qualified
and experienced personnel should be addressed by senior management as key forsuccess and should be planned adequately. Maintaining previous operating staff will
necessitate that new skills and behaviours are developed.

6.2.2. Work control
The operation organisation will have work control processes suitable for an operating
facility. Such processes are generally relatively repetitive, such as fuel loading andmaintenance, whereas a decommissioning mission will be associated by a series of “oneoff” or complex tasks, and as such, the decommissioning organisation should haveeffective management systems that are sufficiently flexible and robust to manage thesafe delivery of a series of different tasks, often using different organisations by means of
the use of contractors. It is essential that there is thorough oversight of the whole project
as tasks will need to be phased to enable further tasks to be completed. Any slippage intimescales will need to be considered carefully as they will impact on task delivery – it istherefore important to build in some flexibility with contract delivery where specialists
are used to deliver tasks.
Every time a significant activity is undertaken, a pre-job briefing should be
conducted. This generally contains a quick review of the safety precautions in order toensure that employees conducting the task are qualified, aware of the risks and that risk
is minimised.
Preparatory activities during the transition contain aspects such as changes of thedesign basis of the facility, removal of fuel, completion of clean-out activities. This
includes draining of the systems, final export of fissile material, transfer of waste using
extant waste routes, preliminary radiation and characterisation surveys, review ofoperational records, planning of decommissioning activities, as well as preparation of
decommissioning documentation. To ensure transition is effective, changes to theoperational documentation may be required. For example, work control arrangements
may need to change during transition as more bespoke tasks are delivered.

6.3. Decommissioning project management
In practice, a detailed project schedule must be maintained during transition with
sufficient detail and oversight to enable defined metrics and key performance indicators
to be measured such that the organisation gains assurance that it is on track to deliver
the required outcomes.
Such an organisation normally has a dedicated project controls function within theorganisational structure for this purpose, which includes responsibility for themonitoring of performance, deliverables as well as production of the required
documentation and other records for the purposes of quality assurance. Planning for theapproved projects is accomplished through the gradual implementation of project
management documentation. It is recommended to develop a project management planthat would describe the requirements for planning, processes, tools and resources. Workpackages are the final outputs of the project organisation. The organisation would
provide the control and monitoring of the projects, such as scope, schedule, cost, quality,changes and phase review.
The decommissioning project manager is a key position that should be set during thetransition. The decommissioning project manager would be responsible for ensuring thatthe project is being delivered safely and as expected by the organisation. For this role,

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project managers should be chosen with previous relevant project management experiencein the nuclear environment. An effective project manager should have the following skills:•

technical knowledge of nuclear facilities;•risk management;•

decommissioning knowledge;•

integration skills.

The project team is a combination of the project manager, assistant project managers,functional managers and functional employees. The line managers usually are thetechnical experts. Functional units, such as engineering, maintenance, radiation
protection, contractors, etc. should be integrated and work under the same management
system. The line managers are responsible for the resources (human and equipment)
used in the project. All these should be reflected in the organisational chart.
Annex A presents case studies related to the organisational project management, inparticular:•

France, CEA decommissioning organisation adapted to Grenoble Nuclear Centre
Nuclear Decommissioning Organisation.

•

Sweden, Vattenfall Ringhals 1 and Ringhals 2 organisational approach fordecommissioning.

•

UK THORP transition from operations, post-operations clean-out.

•

Spain, Enresa, José Cabrera NPP decommissioning.

There are many stakeholders involved in the project. The project roles could be
defined in different levels: project governance, project management and project
execution. In the below chart (Figure 6.2) is a generic illustration of the governance model
used for Vattenfall decommissioning (i.e. the case study from Sweden).
Figure 6.2: Example of a governance model
Corporate
governance

Project
governance

Projectmanagement

Project
execution

Corporatedecision making

Project portfolio
owner (PPO)

Project Review
Board (PRB)

Project sponsor(PS)

Project SteeringGroup (PSG)

Project Manager(PM)

Project Management
Team (PMT)

ReceiverLinemanager inrole asresource
owner

Project
member

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6.4. Transition risk management
In the transition to decommissioning, risks are managed no differently than for risks
associated with the delivery of any project and generally are defined as managing
uncertain and unexpected events or conditions, which, should they occur, may have apositive or negative impact on the project outcomes. Risk management is an importantfunction of project management and a key function of the decommissioning project
manager, especially for old nuclear facilities. Depending on the project, a risk
management document should be initiated.
Good practice suggests that effective risk management is integrated within the
project management function. Risk management is an interactive process and involves
the early identification of risks followed by the identification and implementation of
mitigation measures, the effectiveness of which are continually measured.
The inputs to the process of managing risk are based on information such as records,
experience (internal and external), documentation, stakeholder feedback and expert
judgement. The risk analysis concerns the operations performed by the operators withthe help of the decommissioning project manager. The risk analysis has three principal
co-ordinates:•

the state of the archives, documentation and knowledge of the facility to be
dismantled (the state as constructed and modified, if necessary; operating history);•

the physical and radiological states of the facilities set at the end of operation;•

the cleanliness of the facilities (presence or absence of historical waste for disposal,
best radiological state).

Typical risks associated with decommissioning of nuclear facilities include:•

Poor or incomplete knowledge of the facility (e.g. poor configuration management,
loss of documentation and history of facility) leading to delays and additional
unforeseen engineering. Mitigation is an effective knowledge management strategy.

•

Identification of items of waste with no identified or available waste routes; lack ofqualified suppliers and worker shortage.

•

Delays related to understanding of regulatory framework, financial decisions anddefueling activities.

The organisation, including contractors, could develop sequencing risk process/tools
oriented to waste generation reduction, footprint reduction forecast, maintenanceoptimisation, etc. The process would include the risk factors with direct stakeholder
input. Project risk management risks techniques (Nelson et al., 2016) are developed toaddress the problems with decommissioning of large nuclear facilities.

6.5. Management system
NEA member countries have implemented quality assurance or specific changes to an
existing management system during the transition to ensure success. A management
system is typically modelled on a standard, which identifies various requirements thatfacilitate an organisation delivering its assigned mission. A management system
integrates many elements of the system, such as human and organisational factors,
quality, health, security and economics.
The management system includes processes for the safe and effective delivery ofwork control, project plans, documentation control, records control, communication,
learning from operational experience, establishment and maintenance of organisational
competence, training, maintenance of the required safety cases and other assessments,

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management reviews, problem identification, and resolution and improvement. The
management system is based on process view both on core activities of the organisationand supporting processes including managerial processes. The core processes aredescribed by the NEA member countries’ regulatory standards and international safety
standards, such as (IAEA, 2006).
The organisation should have a management system and leadership that promotes
safety. The organisation needs also to consider the new safety issues that will arise fromthe decommissioning and that were not present during stable and routine operation.
A safety culture action plan could be launched every time a new relevant
decommissioning activity begins. Safety culture changes, linked to the organisationalchanges, should be implemented as necessary.
The management system/quality assurance needs to be adapted to the new stage inthe life cycle of the nuclear facility. The management system documentation andimplementation for the transition to decommissioning is built on previous
implementation of the management system when the same organisation that wasinvolved in operation will also perform decommissioning. The information should bemanaged to preserve the waste processing, handling and storage, as well as disposal ofwaste. All relevant documentation retaining the design, construction, commissioning,
operation and decommissioning stages of the facility should be retained through theentire decommissioning period.
The integrated management system is designed to manage all decommissioning
objectives, adopted standards and stakeholder requirements. An integrated management
system is a means by which an organisation, through the systems approach, implements
practices that are applied across an organisation to achieve all of its objectives and meetrequirements. The IAEA adopted this integration approach to management systems in2006 (IAEA, 2006). The organisations are benefiting from the integrated approach to
manage decommissioning activities by viewing performance against all objectives
holistically (EC, 2008).
Sharing the experience among different nuclear facilities, including the competencies,
resources, programmes and lesson learnt, will ensure the better planning ofdecommissioning and lean transition to dismantling. This practice is highlighted by
Ytournel et al. (2016).
Some organisations may decide to document the management system requirements
for decommissioning by a specific quality assurance plan. The plan is integrated into theoverall management system of the organisation. In the case study from Canada in Annex
A, this experience is presented. The quality assurance plan herein described constitutes alicence basis document.
All the elements of the management system are important during transition. This
chapter describes documentation and record control and training.

6.5.1. Documentation and record management
Under international (IAEA, 2006) and specific NEA member countries’ regulatory
frameworks, it is specified that documentation be developed and controlled, readable andavailable at the point of use. The records have to be maintained and the organisation will
specify the permanent records in accordance with the licence requirements. Examinationof the organisational track record is critical for establishing the decommissioning
organisation.
The transfer of necessary documentation, including the operating experience,
configuration management, records, documents, etc., should be performed by the new
decommissioning organisation or the operator should control those to be used duringdecommissioning.
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During the life cycle of the facility, many documents are created to describe the siteand ensure the facility meets defined requirements. Environmental impacts, design basis
reports, and safety reports are relevant to decommissioning and dismantling. For thetransition, management of knowledge requires the tools (records, archives andrepositories) and information management systems (processes). The facility implements
the requirements regarding the control and retention of the documentation.
Documents may include policies, procedures, instructions, specifications anddrawings, training materials, etc. The document user should have enough information tounderstand what is available to them so that informed decommissioning decisions canbe made. Particular attention should be paid to documents used to control the work
processes to ensure that they remain relevant, current, understandable and available todifferent units (organisations) involved in the project.
The documents should be periodically reviewed as data from internal and external
experience is evolving, new research is available or corrections have to be made as aresult of the assessments.
The IAEA publication, Transition from Operation to Decommissioning of Nuclear
Installations (IAEA, 2004) does already conclude that “the availability of relevant data andrecords is essential for smooth progress into and implementation of decommissioning. A
database containing all relevant data needs to be established and maintained. This
database should be kept up-to-date through the lifetime of the facility”.
During the operation, information is recorded and retained on the physicalcharacteristics of facilities as designed, constructed, commissioned and operated.
Design details should include specifications, manuals, drawings and photographs that
describe the as-built facility and provide the foundation for configuration control.
Records also include data from design changes. For components likely to become
activated, material analysis reports, which are useful in defining quantities of traceelements, should be retained.
Prior to the final shutdown, all relevant design, construction, commissioning,
operating and maintenance documentation and history should be collected and archived.
Records of final shutdown should include the detailed shutdown plans, a description of
final shutdown state achieved, and a plan for managing spent fuel and radioactive andhazardous wastes from final shutdown activities. Sources of information to assess thestate of the facility after shutdown may include:•

operating history;•

configuration management;•

geophysical assessment;•

operating knowledge of facility;•

investigations;•non-destructive examinations.

It is recommended to start performing a review (e.g. self-assessment, audit, etc.) of
existing records for decommissioning preparation as early as possible. A process toreview the relevant archived records and documentation should be implemented. The
safety authority could also review the licensee’s records.
In the case where the site records or documentation is not available, this will driveincreased investigation and characterisation activities. It may also require additional orhigh levels of personal protective equipment (PPE) to guard against unknown hazards(Nelson et al., 2016).

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If the facility will not be decommissioned soon, then the organisation should
implement measures to maintain the records for a long time. Inspection of the records
should be organised periodically to verify the integrity and completeness of the records
and ensure that records are not lost and are still in good condition. If the records are inelectronic format, the media should be appropriate to ensure that the records can beaccessed over the long term. This could be a challenge as the actual media cannot be kept
forever. Additionally, the hardware and software for future reading might not be
available. If dismantling starts a long time after the shutdown, this may require updated
software or the use of a controlled non-proprietary system/form.
The records should be stored to minimise the likelihood and consequence of loss,
damage, deterioration due to unpredictable events such as fire or floods or humaninitiated occurrences. The storage arrangements should meet the requirements
established by the national authorities. If an event occurs that leads to the destruction ofrecords, the status of the surviving records should be examined and their retention mightneed to be re-evaluated.

6.5.2. Training of staff for decommissioning and dismantling activities
During the transition and implementation of the decommissioning project, there are avariety of skills required as described in Section 6.2.1 (i.e. managers, project managers,
engineers, safety managers, technical staff, surveillance staff and transport staff). The
training activities should be tailored to the specific competences necessary fordecommissioning activities.
The training system provides the basis for the analysis, design, development,
implementation, evaluation, documentation and management of training for works at
nuclear facilities. With a training system, it can be demonstrated that all required
knowledge, skills and safety-related attributes have been attained, through the process of
performance-based assessment and programme evaluation.
It is good practice nowadays to develop and implement training systems based on asystematic approach, known as systematic approach to training (SAT) processes, as they
are used during operation of a nuclear facility. Annex D describes the SAT process duringtransition from operation to decommissioning and the experience of NEA member
countries related to training. The SAT process also includes training for the new
documentation developed during transition.
In the report “Education and Training in Decommissioning Needs, Opportunities andChallenges” (Kockerols et al., 2016), the followings key messages were highlighted:•

Specific attention goes into long-term strategic planning of recruitment andtraining needs, with an appropriate profile in terms of both time and scale.

•

In Europe, there are several training programmes focused on collaborating withindustries and co-operating for shared education and training programmes.

•

The training programmes include knowledge transfer on specific projects andequipment.

6.6. Supply chain
Various aspects of the decommissioning execution, such as dismantling activities, can begenerally subcontracted to specialised companies as required.
The licensee should ensure an adequate oversight of the supply chain management
and the major aspects of supply chain management. The oversight should include
verification that work is placed with contractors that are qualified to perform the work,
assessment and reassessment of the contractor’s management system, records’

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maintenance, review of non-conformance, surveillance, inspections, witnessing ofactivities, review of the contractor’s qualifications, review of the organisations’ roles andresponsibilities, and means to inform the safety authority about relevant information.
The preparation of requisitions and contracts is part of the transition. The contract
document issued by the licensee should state the need for a proper quality plan andmanagement system with which any contractor or subcontractor should adhere. The
contract could include information about safety, technical requirements, subcontractor
obligations, regulatory requirements, hold points, qualifications requirements, rightaccess, change control, documentation and records, etc.
In order to develop the industrial strategy for decommissioning and dismantling andeventually the contracts, the main questions raised by the decommissioning organisation
prior to developing the purchasing strategy are:•Is nuclear decommissioning a growing market; is there a business for everyone
including foreign companies?

•

Are companies able to invest and is there an opportunity for future market
renewal of the nuclear fleet?

•Is the regulatory environment evolving/changing, which will put the operator in asituation to increase the control of the specifications and ultimately the risks
provisions?

•

Are the contracted companies’ businesses at the same level of knowledge,
including foreign companies?

•

Is it difficult to renew the skills of the participants?

•

Is it easy to find dismantling expertise and competences on the market?

•

Can risk be transferred or shared?

The licensee should develop supply chain policies. The fundamental elements of the
supply chain policy are:56•

for complex dismantling operations, it is preferable to involve suppliers on overall
global services in order to gain experience from similar activities performed
elsewhere and take into consideration that this should be achievable without extra
cost for the owner/licensee;•

the risk has to be assumed by both licensee/owner and supplier at the lowest cost;•the supplier should commit to performance results, combined with cost-plusincentive-fee related to achieving terms of results;•

motivate the supplier on finding innovative solutions to shared earnings(incentive);•

apply integrated services combining several specialties to reduce the involvementof the owner/licensee in the management of interfaces;•

determine the number of qualified suppliers and the number of affected
employees of these companies at the national level for nuclear activities;•

specify the proposed dismantling schedules and potential amounts involved, sothat companies can prepare for these markets;•

possess a contracting policy by applying the principle of “best bidder” in theselection of companies (and not the “lowest bidder”);•

avoid competing technical offers that are not balanced with respect to these
expectations.
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Formal requirements for procuring goods and services
NEA member countries developed and implemented a regulatory approach regarding thecontrol of the supply chain for decommissioning projects. The safety authority shouldverify that the licensee establishes and implements a contracting process that would
ensure that all the procured goods and services meet the regulatory requirements. The
safety authority should perform compliance activities to confirm that the licensee
verifies the performance of the contractor’s processes to assure quality and safety.
The typical following supply chain processes are:•purchasing requirements;•

supplier acceptability;•

provisions of the purchasing requirements to suppliers;•

supplier selection and award;•

supplier-customer relationship and monitoring;•verification of services;•

receipt and inspection of items;•

disposition of problems.

NEA member countries implemented measures to verify the contractor’s activities(technical and quality). For example, in France, in order to ensure the quality of executionof clean-up and decommissioning of nuclear facilities, which it entrusts to the contractor
companies, in 1989 the CEA implemented a mandatory acceptance procedure. Only acompany that meets the CEA requirements can be included in the call for tender fordecommissioning services.

6.7. References
EC (2008), “Project Management and Planning”, Final Report, European Commission
Research and Technological Development.
IAEA (2006), The Management System for Facilities and Activities, GS-R-3, IAEA, Vienna.
IAEA (2004), Transition from Operation to Decommissioning of Nuclear Installations, Technical
Reports Series no. 420, IAEA, Vienna.
Kockerols, P., M. Freer and H. Schneider (2016), “Education and Training in
Decommissioning Needs, Opportunities and Challenges”, PREDEC 2016, 16-18 February
2016, Lyon, France.
Nelson, J.G. et al. (2016), “Top 10 Decommissioning Planning Lesson Learned andRecommendations”, J.G Nelson Delphi Group Inc.
Ytournel, B. et al. (2016), “Applicability of learning from experience to Sellafield postoperation clean out and decommissioning programmes”, PREDEC2016, 16-18 February
2016, Lyon, France.

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CONCLUSIONS, OBSERVATIONS AND RECOMMENDATIONS

Chapter 7. Conclusions, observations and recommendations

The transition from an operating nuclear facility to the implementation of thedismantling phase is critical in every decommissioning project. A number oforganisational and technical changes and modifications are necessary to adapt thefacility so that it can meet the new objectives and requirements. A variety of activities
need to be planned and performed both to support the transition and to prepare thedismantling of the facility.
Preparations for the transition to decommissioning and dismantling (D&D) is a key
issue for the success of global D&D projects so as to minimise delays and undue costs; tooptimise personnel and other resources; and have preparatory activities initiated early sothat decommissioning takes place in a planned, timely and cost effective manner toensure safe and efficient decommissioning.

7.1. Conclusions and recommendations
7.1.1. Setting the strategy for decommissioning
A set of strategic decisions needs to be taken by the top-level management of anorganisation in order to prepare for the decommissioning of a nuclear facility, including:•a nuclear material and/or spent fuel management strategy;•

a materials and waste management strategy;•

a remediation/site clean-up strategy;•

a dismantling strategy;•a facility modification strategy;•

a technological strategy;•

a corporate strategy;•

an authorisation process.

These strategic decisions are influenced and constrained by several factors, namely:•

the funding situation;•

the policy and regulatory framework;•

the facility design and status;•

the available routes for the transport of radioactive waste;•

the available good practices and experience;•stakeholder perceptions.

It is recommended therefore that detailed strategy making begin at least five years
before the anticipated date of final shutdown. Installing a project organisation initiates
and facilitates the change from a process-driven organisation found in nuclear facilities

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during operation to a project organisation for decommissioning. National andinternational experiences may help to prepare the strategic decisions which, once taken,
need to be reviewed regularly and refined/changed as necessary.

7.1.2. Preparatory activities
In the last years of operation, and early after the cessation of operation, preparatory
activities should be planned and initiated in order to reduce the hazards associatedwith dismantling activities. In addition, conducting preparatory activities as much as
possible immediately following shutdown reduces the fixed costs and thus bears thepotential of saving resources for the overall decommissioning project. Typicalpreparatory activities are:•asset management;•

fissile material and spent fuel removal;•

shutdown of redundant systems;•

characterisation;•material and waste management;•

decontamination activities.

It is recommended in particular that a holistic analysis of radiological and nonradiological hazards and risks be carried out. Preparatory activities should also focus on
preventing surprises in D&D while at the same time preparing for them.

7.1.3. Authorisation for decommissioning
During the transition from operation to decommissioning, both the operator and theregulator through their supervision and inspection programme have the responsibility ofensuring that the facility is maintained in a safe condition and that adequate provisions
to protect the health and safety of the public and the environment are in place.
To ensure the safe transition to decommissioning, the following key aspects should
be considered:•ensuring an early engagement of the operator with all regulatory authorities;•

setting clear regulatory expectations and defining the approval process prior totransitioning to decommissioning;•

clarifying the roles of all regulatory authorities involved in authorisation of
decommissioning, and harmonising regulatory requirements and criteria between
them;

•

initiating an early engagement of all stakeholders;•adjusting the regulatory approach to changing risk profiles during transition fromoperation to decommissioning and remaining flexible to adequately address thischange.

7.1.4. Stakeholder engagement
Early and effective stakeholder engagement and informing of other interested parties ismandatory to build trust within the community and establish early confidence in thedecommissioning project.
A clear definition of the intended interim states and end states of thedecommissioning project is the basis for communicating with stakeholders, as well as formaking the strategic decisions to prepare for decommissioning of the facility.

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A stakeholder information plan should be established, which includes a strategy forthe identification of stakeholders and a stakeholder management plan based on a clear
communications strategy. The stakeholder information plan should foresee public
information programmes using different media, like newspapers, brochures, online
publications, etc.
Nevertheless, it is also important to clearly explain that stakeholder engagement islimited and that the licensee, who bears responsibility for conducting a decommissioning
project according to the regulatory requirements, has the right to take decisions in its
entrepreneurial responsibility (i.e. no representative participation without accountability).

7.1.5. Organisation transition
The purpose of organisation transition is to ensure that an effective and competentorganisation is in place to deliver the decommissioning mission. The organisation’s
purpose should fit the decommissioning strategy. Several models have been developed in
NEA member countries. The organisation that will conduct D&D is typically either theowner/licensee (self-performing the work) or a qualified contractor (sometimes referred
to as a decommissioning operations contractor). However, the operator should always bepart of the transition.
The preparation for organisation transition should begin well before the facility has
shut down in order to allow optimum preparation of the facility for its subsequentdecommissioning. Full advantage should be taken of the operating personnel, with theirextensive knowledge of the facility: operating history, incidents, familiarity with thepremises and the various equipment items, such that knowledge can be transferred tothe decommissioning organisation. Maintaining previous operating staff will require thatnew skills and behaviours be developed. Training activities should be tailored to thespecific competencies necessary for decommissioning activities.
The intended decommissioning organisation should have appropriate management
systems in place. These include work management processes for the delivery ofdecommissioning (as opposed to the delivery of operations). The transition in thiscontext is intended to deliver the required skills to decommissioning organisation in a
managed and structured manner. Some organisations may decide to document the
management system requirements for decommissioning through a specific quality
assurance plan. This plan should be integrated into the overall management system of
the organisation.
The management system’s documentation should be reviewed and adapted to therequirements established by the national regulators for the decommissioning stage. Allelements of the management system are important during transition. The delineation
between decommissioning and operating governance should be ensured, for example,
and existing documents should be revised as necessary. For instance, changes tooperational documentation may be required, such as work control arrangements,
equipment procedures and documentation updates applicable to new tasks, particularly
as the shift occurs during the transition from operation to decommissioning, or fromrequirements on the reliability and availability of safety equipment to requirements on
the reliability and availability of safety measures. The organisation, including contractors,
could also develop sequencing risk process/tools oriented to waste generation reduction.

7.2. Areas for further work
This report’s intention is to provide a comprehensive overview of considerations to betaken into account, decisions to be made and activities to be carried out, as well as theinterrelations between key issues so as to prepare and plan for decommissioning of a
nuclear facility based on experience and good practice in NEA member countries.

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CONCLUSIONS, OBSERVATIONS AND RECOMMENDATIONS

Within their activities and observations, the task group has identified several areas in
the context of the transition of a facility from operation to decommissioning that would
merit further attention and where the international community would benefit fromfurther study via international experience sharing. Among the topics are:62•

knowledge management: keep, transfer and maintain;•

training and qualifications;•communications;•human performance and demonstration of continuous improvement;•

integrated management and organisational change from the stakeholders’perspective;•

safety culture;•

programme and project management;•

supply chain management and the development of contracting models.

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GLOSSARY

Chapter 8. Glossary

Within the context of the report the following terms are used in the described context:
Authorisation

The granting by a regulatory body or other governmental body of
written permission for a licensee to perform specified activities.
Depending on the regulatory framework this may take the form of alicence, permit or approval.

End state

A predetermined criterion defining the point at which a specific taskor process is to be considered completed. Used in relation todecommissioning activities as the final state of decommissioning.

Facility

A nuclear facility, where radioactive material is produced, processed,
used, handled or stored on such a scale that consideration ofprotection and safety is required.

Licensee

The licensee is the operating licence holder (or also referred to as
operator), who may also be the owner of the nuclear installation(NEA/RWM(2015)9)Site

A licensed or regulated location that includes one or more facilities
designated for the use of radioactive materials.

Stakeholder

Any actor – institution, group or individual – with an interest or with arole to play in the process (Webster, 2000), “Deliberations of Working
Group 3 – Stakeholders and the Public: Who are they”, in Stakeholder
Confidence and Radioactive Waste Disposal, pp. 117-119, www.oecdnea.org/rwm/reports/2000/nea2829.pdf (NEA, 2004).

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Annex A1. Canada – Case study:
Whiteshell Laboratories decommissioning
management system documentation

Introduction
The decommissioning of Canadian Nuclear Laboratories Limited (CNL) Whiteshell
Laboratories is currently described by the licence issued by the Canadian Nuclear Safety
Commissioning that expires 31 December 2018. The laboratories are located in Pinawa,
Province of Manitoba, Canada.
The Whiteshell Laboratories site was established by Atomic Energy of Canada Limited(now Canadian Nuclear Laboratories Limited) to carry out research and development
activities for higher temperature versions of the CANDU reactor. Over time other research
programmes were added. The organically cooled reactor WR-1 began operation in 1965
but the programme was discontinued in the early 1970s in favour of the heavy watercooled reactor CANDU system. The reactor was operated until 1985 in support of theother research programmes. They included the Nuclear Fuel Management Program,
SLOWPOKE Demonstration Reactor Project and various accelerator activities. Atomic
Energy of Canada Limited (AECL) took the decision to discontinue research programmes
and operations at Whiteshell Laboratories and received the federal government
acceptance in 1998 to close the site.
Whiteshell Laboratories’s decommissioning licence was first issued in 2003. Since
then there has been a gradual progression in the number of decommissioning activities
being performed. During the transition phase to decommissioning AECL prepared thedecommissioning quality assurance documentation and technical documentation, suchas detailed decommissioning plans.
The original decommissioning plan estimated decommissioning to be completed by
2062. In 2008, AECL provided an accelerated schedule to 2037 from 2062, primarily related
to cancelling the extended storage with surveillance state for the WR-1 reactor.
AECL’s Nuclear Laboratories (which are responsible for implementing
decommissioning activities) were restructured to implement a government-owned,
contractor-operated (GoCo) model, similar to that being used in the United States andUnited Kingdom. As part of this restructuring, AECL’s employees and operations werereorganised into CNL. In 2014, CNL became the licence holder due to the government
moving to a government-owned, contractor-operated model. CNL now operates thefacilities while AECL retains ownership of the assets and liabilities.
CNL is now proposing to further accelerate Whiteshell’s decommissioning to 2025. Itshould be noted that institutional controls are expected for at least 200 years past site
closure.
The decommissioning programme is unique since it addresses the entire research site,
nuclear and non-nuclear. The site facilities were placed in a safe shutdown state; plans
were initiated to place the facilities in a secure monitoring and surveillance state.

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Licence and Licence Condition Handbook regarding the management system
The Canadian Nuclear Safety Commission’s (CNSC) Regulatory Framework consists oflaws passed by Parliament that govern the regulation of Canada’s nuclear industry, andregulations, licences and documents that the CNSC uses to regulate the industry.
Canadian Nuclear Safety Commissioning requires that persons or organisations subject
to the Nuclear and Safety Act and the associated regulations are directly responsible formanaging the decommissioning activities and implement the measures to protect thehealth and safety of persons and the environment. Prior to any nuclear activity occurring,a licence for decommissioning facilities must be issued by the CNSC. The licensee needs
to demonstrate that it has fulfilled the requirements under the Nuclear Safety andControl Act and the associated regulations.
For major nuclear facilities, such as decommissioning facilities, in accordance withClass I Nuclear Facilities Regulations, an application for a licence shall contain a quality
assurance programme for the activity to be licensed. If a licence is issued, the licence will
require that “The licensee shall implement and maintain a management system”. The
Licence Condition Handbook associated to the licence provides the details and specifies
the reference standards as the compliance verification criteria.
As per licence requirements, CNL will conduct the decommissioning activities inaccordance with the submitted detailed decommissioning plans. The licence requires thelicensee to (among other items):•

Implement and maintain decommissioning polices, programmes and procedures.

•

Not deviate from the design operating conditions, purposes, methods, proceduresor limits described in the safety analysis reports and/or operational limits andconditions documents that would result in an impact on health, safety or
environment that is different in nature or greater in magnitude or probability thanthat described in those documents without prior approval of the commission or aperson authorised by the commission.

•

Implement and maintain a public information and disclosure programme.

•

Implement and report on the progress of the Environmental Assessment Followup programme.

The Licence Condition Handbook contains, compliance verification criteria, information
on delegation of authority to CNSC staff, references to licensee’s documentation, references
to standards and CNSC regulatory documents and commitments made by the licensee toensure compliance with regulatory requirements.
In addition to describing the licence conditions and their compliance verification
criteria, recommendation and guidance, the Canadian Nuclear Safety Commission’s
Licence Condition Handbook is organised according to the Safety and Control Area (SCA)
framework. A SCA is a technical topic used by the CNSC to assess, review, verify andreport on regulatory requirements and performance across all regulated facilities andactivities. The SCAs listed in the Licence Condition Handbook for Whiteshell cover:66•

management system;•

human performance management;•

operating performance;•

safety analysis;•

physical design;•

fitness for service;

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radiation protection;•

conventional health and safety;•

environmental protection;•

emergency management and fire protection;•

waste management;•

security;•safeguards and non-proliferation;•

packaging and transport.

CNSC amended its regulatory framework in 2009 to evolve from having quality
assurance requirements for the activity licensed to a broader set of management system
requirements. Today, the CNSC requirement refers to a Canadian Standard Association
nuclear standard N286 for management systems, developed and accepted by a crosssection of Canadian industry representatives including CNSC staff.
Safe and reliable decommissioning requires a commitment and adherence to a set ofmanagement system principles and, consistent with those principles, the establishment
and implementation of a planned and systematic patter of actions that achieve theexpected results. An adequately established and implemented management system by alicensee provides CNSC staff confidence and evidence that the legal bases under which
the CNSC made its decisions and had issued a licence remain valid.
The Management System SCA Covers the framework that establishes the processes
and programmes required to ensure an organisation achieves its safety objectives,
continuously monitors its performance against these objectives, and fosters a healthysafety culture. The specific areas for management system are:•organisation;•

performance assessment, improvement and management review;•

operating experience (OPEX);•

change management;•

safety culture;•

configuration management;•

records management;•

management of contractors;•

business continuity.

The requirements to implement and maintain a training system are under SCA
Human Performance Management. The licence also states that the licensee shall ensurethat every contractor working at the facility complies with the licence and thecompliance criteria are described by the Licence Condition Handbook.
CNSC staff verify the licence condition pertinent to the management system througha review of information as described in Licence Condition Handbook Compliance
Verification Framework (e.g. inspections, technical assessments, event reviews), in
association with Licensing Basis documents and in accordance with CSA N286.6-98
Decommissioning Quality Assurance of Nuclear Power Plants. The Licence Condition
Handbook lists Whiteshell Laboratories Decommissioning QA Plan WLD-01913-QAP-001
and CNL Management Manual CW-5141000-MAN-001.

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WHITESHELL LABORATORIES DECOMMISSIONING MANAGEMENT SYSTEM DOCUMENTATIONCNSC requirements regarding the management system for Whiteshell Laboratories
decommissioning
CSA N286.6 Decommissioning Quality Assurance for Nuclear Power Plants specifies
requirements applicable to the decommissioning phase of the nuclear plant life cycle.
Clause 3 of this standard contains the generic requirements for managing thedecommissioning of a nuclear power plant. These generic requirements are derived fromthe requirements of CSA Standard CAN/CSA-N286.0. Clauses 4, 5 and 6 which address theperformance of specific work activities that are necessary during the decommissioning
and that complement the requirements of Clause 3.
Each second-tier standard, such as CSA N286.6, embodies the principles set forth in
the first-tier CSA N286.0 Overall Quality Assurance Program Requirements for Nuclear
Power Plants. Each one includes specific programme requirements, limits of
responsibility, authority, and application of criteria as they apply to the specific needs ofeach of the constituent phases of a nuclear power plant life cycle. There are the following
second-tier standards that also are linked to the decommissioning standard:•

CSA N286.1 Procurement.

•

CSA N286.2 Design.

•

CSA N286.3 Construction.

•

CSA N286.4 Commissioning.

•

CSA N286.5 Operations. CSA Standard N286.5 has specific applicability during thedecommissioning phase, because it is often difficult to distinguish adecommissioning activity from an operations activity. Depending on the stage ofdecommissioning, many activities described in CSA Standard N286.5 must be
performed.

Clause 3 of N286.6 defines the requirements for the following generic activities suchas programme definition (e.g. issuing a quality manual and identification of theparticipants), personnel capability, accountability, organisation and responsibilities,
personnel capability, Use of experience, control of items processes and practices,
verification, non-conformance and corrective action, change control, record andprogramme assessments (self-assessments and independent assessments).
Clause 4 of N286.6 defines:

68•

decommissioning authority;•

decommissioning documents (conceptual decommissioning plans, detailed
decommissioning plans, hazards assessment, waste assessment, end-state
documentation, decommissioning procedures);•work control (procedure adherence, changes to inadequate procedures, inadequate
emergency procedures, procedure implementation, work authorisation);•materiel control: identification of systems, structures, and components;•

turnovers (systemdecommissioning);•

status of systems, structures, and components;•

decommissioning surveillance;•

communication;•

radiological and non-radiological hazardous material control;

turnovertodecommissioning,systemturnoverfrom

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WHITESHELL LABORATORIES DECOMMISSIONING MANAGEMENT SYSTEM DOCUMENTATION•

contamination control;•

hazardous waste management;•

effluent control;•

worker safety;•

housekeeping;•security.

Clause 5 addresses the link with the other N286 series standards.
Clause 6 describes:•

emergency classification;•

emergency response organisation;•

emergency plan;•

emergency facilities, equipment, and resources;•

personal protection;•

public information programme;•

evaluation of emergency program effectiveness.

N286-05 Management System Requirements for Nuclear Power Plants replaced CSA
N286.0 Overall Quality Assurance Program Requirements for Nuclear Power Plants andsub-tier CSA Standards N286.1 through N286.6. The standards applies to all life cycles of a
nuclear power plant and their overlap, eliminate duplication and inconsistencies among
sub-tier standards, focusing on the management role in controlling and managing work
processes.
In June of 2012, the Canadian Standards Association published the standard CSA
N286-12 Management system requirements for nuclear facilities. The standard also
applies to all the life cycle activities as in the previous versions but is now applicablebeyond the power reactors to other licensed facilities. It is aligned with the principles of
IAEA guidance and integrates the requirements from other management systemstandards such as quality, health and safety, environment, economics and security. The
CSA N286 standard represents the industry current best practice for the principles
fundamental to management processes and features important to the overall objective ofsafety. CSA N286-12 is becoming the licence condition standard for decommissioning.
N286-12 refers to the management system as: “The management system brings
together in a planned and integrated manner the processes necessary to satisfy therequirements that must be met to achieve business success and sustainability”.
The CSA group published a commentary document (N286.0.1-14) to the standard
N286-12 in July of 2014. The commentary document covers some of the genericrequirements and provides background information helpful for the implementation of amanagement system in line with the intent of the standard.

CNL (AECL) quality assurance documentation
The Whiteshell Laboratories Decommissioning Quality Assurance Plan (DQAP) was
written following the guidelines of the company wide Quality Assurance Manual CW5141000-MAN-001 and describes the programme applied to decommissioning activities at
Whiteshell Laboratories. The programme applies to all facilities listed in the licence. The
Decommissioning Quality Assurance Plan is supported by the procedures and operation
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WHITESHELL LABORATORIES DECOMMISSIONING MANAGEMENT SYSTEM DOCUMENTATION

instructions. Corporate wide procedures provide the overall directives while local
procedures provide specific requirements and details. DQAP provides a cross reference
between programme documentation and the CSA standard. This approach is a generalpractice used in the nuclear industry in Canada.
The document was submitted as part of the licence application. CNSC staff performed
a technical review of the document and its referenced documentation and accepted theplan. The plan met CSA N286.6 requirements.
Whiteshell Laboratories has extensive and complex documentation fordecommissioning activities and for the transition to decommissioning. The adherence tothe requirements in those procedures is required by CNL senior management.
The Decommissioning Quality Assurance Plan presents and references the applicable
documentation. DQAP contains the following sections:1.

organisation, authority, andfunctional responsibilities);

responsibilities

2.

personnel capability;3.

accountability;

4.

communication;5.

use of experience;

6.

work planning and control;

7.

control of items, processes and practices;8.

verification;

9.

non-conformance;(organisational

structureand10. corrective action;
11. change control;
12. document control;
13. records;
14. programme assessment (self-assessment and independent assessments);
15. requirements for decommissioning;
16. links with other quality assurance standards such as procurement, design etc.

Section “Requirements for Decommissioning” describes the specific activities andreferences all the documents. The section contains the following subsections:70

1.

decommissioning authority;2.

decommissioning documents (preliminary decommissioning plan, detailed
decommissioning plans, work plans, hazard assessments, waste assessment,
environmental assessment, end of state documentation, decommissioning
procedures);3.

work control (procedure adherence, changes to inadequate procedures (stop workwhen procedure cannot be followed), inadequate emergency procedures (staff
perform a safe back out and put the facility in safe statement when emergency
procedure is inadequate), procedure implementation, and work authorisation);

4.

material control;

5.

turnovers;

6.

status of systems, structures and components;

7.

decommissioning surveillance;

8.

communication;

9.

radiological and non-radiological hazardous material control;

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10. contamination control;
11. hazardous waste management;
12. effluent control;
13. worker safety;
14. housekeeping;
15. security.

The following examples present the content of some subsections of the DQAP:•“Hazardous waste management” specifies among others that waste shall be
segregated into radioactive and non-radioactive categories and waste shall beminimised thorough good housekeeping, appropriate practice and decontamination.
CNL has generic documentation regarding the management of radioactive and nonradioactive wastes, packaging and low waste storage facility.

•

The “decommissioning surveillance” section states that facility staff shall inspectdaily any permanent shutdown nuclear facility or part of permanent shutdown
nuclear facility to ensure that the shutdown state is maintained. Staff shall also
perform routine housekeeping inspections in each facility. For facilities in “storage
with surveillance” phases of the decommissioning, Storage with Surveillance Plans
shall be prepared including details of facility specific inspection programmes
specifying the frequency and responsibilities for physical inspections, equipment
testing and monitoring of operating systems. Facilities for which Storage with
Surveillance Plans have not been approved shall be inspected daily.

•“Work authorisation” states that prior to execution all decommissioning work shallbe reviewed and authorised. The specific procedure provides a mechanism forverification by the Facility Manager, Subject Matter experts of the compliance,
safety, engineering and operations disciplines that all requirements and supporting
documentation have been identified. The decommissioning work performed by
non-CNL personnel shall be assessed, controlled and authorised according to a
specific documentation approved by CNL. Decommissioning will be performed as
per Work Permit System that will be used by all, including the contractors.

CNSC compliance activities/lesson learnt
To ensure that licensee is complying with the conditions set in the licence CNSC staff isperforming different type of compliance activities:•

audit (type I inspection);•type II inspection base line compliance activities;•

review of annual compliance reports;•

review of reportable events pursuant to general nuclear safety and control
regulations;•review of non-reportable events submitted to CNSC;•

reactive inspections;•review of changes to the documentation.

CNSC staff conducted an audit in 2008 to verify the Decommissioning Quality
Assurance Program work in progress and activities implemented as per
Decommissioning Quality Assurance Plan WLD-01913-QAP-001. The inspection assessed
the records associated with decommissioning activities. The audit criteria were thelicence, CSA N286.6 Decommissioning Quality Assurance for Nuclear Power Plants and
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WLD-01913-QAP-001 (including the procedures) requirements. The audit inspected work
activities in progress for different facilities and different decommissioning plans. It
should be noted that this audit was performed when many of the decommissioning
activities were at the initial stage or in planning stage since CNL is implementing aphased approach to decommissioning and is conducting physical decommissioning
activities in discrete work packages. For the on-site inspection activities, the CNSC
inspection team used a combination of document sample reviews and interviewed
selected personnel to make observations.
Based on a no-surprise approach, the observations, which could result in findings,
were then communicated to the Whiteshell Laboratories’ single point of contact and CNL
staff at daily morning briefings. The meetings provided the Whiteshell Laboratories staff
with an opportunity to present clarification regarding the observations made.
The audit found some non-conformances with the audit criteria:•

Lack of a list with all records to be delivered to Records Office, project record kept
by different groups and engineering files were not properly controlled. The statusof records kept by different groups was not “indeterminate”.

•

The documents used for specifying and controlling the decommissioning activities
did not define all steps necessary for accomplishing the work objectives safely. For
example, the removal of manipulators and collar from a Cell required rigging andspecial contamination methods but the steps were not described by the work plan.

•

The handling and storage of hazardous solid and liquid waste was not controlled
to ensure safety. For example the temporary room for the storage of chemicalmaterials was unsafely kept, with a fire potential.

•

Boundaries were not clearly identified in the field for systems/areas turned over todecommissioning.

•

Safety-related items and services were obtained from some vendors without aquality programme to assure the necessary quality and required performance.

CNL issued a corrective action plan to address CNSC enforcement actions. The
corrective action plan contained the complete dates including checking for effectivenessof the corrective actions issued. The plan was reviewed by CNSC staff and accepted.
CNSC staff performed a follow-up inspection to verify the implementation of thecorrective actions.
In 2010 CNSC staff presented to the commission the information about the corrective
action plan to improve the quality assurance implementation at Whiteshell Laboratories
and about the status of the corrective actions for the enforcement actions from the CNSC
staff audit performed in 2008. During the hearing, CNL provided information regarding
the progress it has made especially on record control and job scope and safety analysis.
The commission was satisfied with the progress made. All the CNSC enforcements
actions were closed in 2011 after the review of their effectiveness.
In addition, during regular type II inspections performed yearly after 2011 by CNSC
staff the elements of management system were also reviewed. CNSC staff observed theadherence to the quality assurance requirements stated in the WLD-01913-QAP-001. The
management system implementation was rated as “satisfactory” by CNSC staff.
The status of the facility was changed from a research facility, which followed a set ofoperational quality assurance requirements, to a facility in decommissioning stage
adhering to the requirements of CSA N286.6. The decommissioning requirements set in
N286.6 were new for the staff; some staff was requalified to perform those activities. The
early presence of CNSC staff helped for a more effective transition to decommissioning
activities and provided valuable feedback to ensure compliance to the requirements.

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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATION

A.2. France – Case study 1:
CEA decommissioning organisation adapted to Grenoble Nuclear
Centre Nuclear Decommissioning Organisation

Introduction
The operations performed between the closure of the facility and the issue of the final
shutdown and decommissioning authorisation (“pre-decommissioning” phase, see
Figure A.2.1), must comply with the provisions of the facility’s creation authorisation
decree and its operating safety requirements.
The final shutdown preparation phase must allow optimum preparation of the facility
for its decommissioning, taking full advantage of the presence of the operating personnel,
with their extensive knowledge of the facility: operating history, incidents, familiarity
with the premises and the various equipment items, etc.
Figure A.2.1: Facility timeline

Facility operation

CreationdecreeServiceauthorisation

Pre-decommissioning
phase

Dismantlingphase

Decommissioning
decreeHow such operations are conducted? Everything starts with the definition of the
scenario and the means of intervention to be implemented by collecting initial data on
the facility (plans, equipment ...) and evaluating its radiological condition (radiation levels,
contaminated premises ...). This scenario is made according to the facility safety
document, for a basic nuclear facility in shutdown phase, changing the status from“operation to dismantling”. It specifies the desired end state, the analysis of new risks
arising from the operations, the waste generated, gas release, dosimetry, etc.
Consequences: a new mapping of radiological hazards is made with the individual at
the heart of the scenario to ensure its protection against contamination or irradiation
during operations. In parallel, an administrative record on waste management isdeveloped, assessing their environmental impact to ensure that they will be accepted by
the National Agency for Radioactive Waste Management (Andra). From the chosen
scenario, and once the permits issued by the competent French Nuclear Safety Authority(ASN), follows the entry into pre-decommissioning phase: defining the scope ofoperations, installation of a ventilation system to protect the working environment,
implementation of radiation protection equipment
Finally, work began, first to evacuate materials, then clean-up operations, (eliminate
radioactive equipment and parts of facilities). This work is done upstream of dismantlingphase.
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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATION

Pre-decommissioning phase should be limited to the performance of the following
operations:•

recent operations relating to the operation of the installation (phasing out
experiments in a research facility for example);•ordering the installation;•

preparation of the decommissioning operations (development of local, site
preparation, staff training, installation of necessary equipment for dismantling);•

characterisation of the installation (production of radiological maps, especially on
the basis of intrusive sampling and/or destructive collection of relevant elements
for the decommissioning);•

modification, adaptation or improvement of utility networks (electricity, fluids,
ventilation, etc.);•

discharge hazardous or radioactive substances in the installation (radioactives,
chemical, fluid, waste, etc.).

Limited operations irreversible dismantling of equipment for the evacuation ofradioactive and hazardous substances can be made during the preparation phase to
making the final judgement.
Exceptionally, smaller pilot projects can also be made during this phase as part of the
preparation for decommissioning.
During the decommissioning phase, the operator may need to implement new
facilities or equipment in its regulated nuclear installation (INB), especially to maketreatment and conditioning of waste operations.
The construction of a new plant or new equipment that will be used fordecommissioning operations can optionally be carried out before obtaining thedecommissioning authorisation.
When construction of the equipment requires a building permit or when work isreportable or outline planning permission, construction can start, however, after
obtaining the building permit and after the closure of the public inquiry the marketing
authorisation application file for the final shutdown and dismantling. In all cases,
permission to build does not prejudge the authorisation to operate the equipment, which
is issued by the decree making authorisation for final shutdown and dismantling or,
where applicable, authorisation or approval of the regulator.

Nuclear Energy Division
Under the authority of the General Directorate, the Nuclear Energy Division fixed thestrategic orientation and missions of the nuclear division. It fixes the means necessary
for achieving the objectives and controls the different programmes.
CEA’s strategy under the regulatory framework: nuclear laws 2006 TSN and waste:

74•

Immediate and total decommissioning when feasible. Technical and economical
optimisation pursuit.

•

End state: removal of all dangerous material (in particular radioactive ones). If
impossible: decommissioning with constraints, with an impact always less than
300 μSv/yr.

•

Solid and liquid waste: minimisation, optimisation of categorisation, on-site
evacuation.

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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATION

The main missions are:•Take responsibility for the implementation of research programmes on futuresystems of production of nuclear power and, correspondingly, those relating tofuels aspects, nuclear safety, spent fuel processing and optimised nuclear waste
management.

•

Provide, upon request, support to industry and organisations for the current
nuclear fleet t and fuel cycle facilities and develop in its field of activities,
co-operation at national and international level.

•

Ensure responsibility for waste management facilities and waste treatment of theentire CEA and the remediation and decommissioning of facilities (Nuclear CEA
civil and the UP1 plant at Marcoule site).

•

Maintenance of its nuclear facilities and installations at the level required by
nuclear safety requirements and through careful management of resources
available as well, in the same spirit, the management of its real estate trivialised.

•

Contribute to the development of generic technologies in the program transversal
advanced materials.

Two nuclear centres are under the direct responsibility of the Nuclear Energy Division:
Cadarache and Marcoule (see Figure A.2.2).
For two others centres (Saclay and Grenoble) only the nuclear activity within thecentres are under the Nuclear Energy Division responsibility, the management of thecentre is under the responsibility of other Divisions.
Figure A.2.2: Organisational chart: CEA Nuclear Energy Division
Nuclear Energy Division

Supportdivisions

Programme
divisions

QualityInnovation
nuclear supports

Human
resources

Nuclear clean-up
and dismantling

Financial

Saclay Center(nuclear activity)

Cadarache
CenterGrenoble Center(nuclear activity)

Marcoule
CenterNuclearFacilities
SectionClean-up
Dismantling
Projects
Department

Nuclear Clean-up and Dismantling Division (up to end 2016)
The Nuclear Energy Division has the responsibility firstly to carry out all of thedecommissioning programmes of the CEA and on the other hand to ensure themanagement of waste, materials and spent fuel for all CEA civilian sites, including themanagement of transport and associated packaging.

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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATIONThe Nuclear Clean-up and Dismantling Division missions are organised in eightprogrammes:•

Marcoule decommissioning;•

Cadarache and Grenoble decommissioning;•

Saclay decommissioning;•

Waste, materials management;•

Nuclear support facilities;•

Transports and outlets;•

ITER decommissioning and tritiated waste;•

R&D valorisation and decommissioning.

Within the Nuclear Clean-up and Dismantling Division, each programme is assigned
to a programme manager who is the strategic driver.
The strategic driver, sets the objectives and ensures the strategic management of the
projects (performance, cost, time), the management rules, financial resources and staff
budgeted.

Decommissioning Project Department
The department (depending from Marcoule Center) ensures the operational managementof decommissioning projects and waste retrieval and packaging on behalf of the Strategic
Pilot (Nuclear Clean-up and Dismantling Division). The department is particularly
responsible for the consolidation and optimisation of load plans, resources and budgets
required for current and future performance of its operations. It must also guarantee thestandardisation of working methods and the capitalisation of experience indecommissioning projects.
In this framework, each project is assigned to a Project Manager, responsible forproject management and reporting to the Nuclear Clean-up and Dismantling Division
programme manager.
The project organisation is based on a matrix operation of “business” leaders are
assigned on a project or set of projects as required, to bring the project manager technicalsupport and methodological contribution:•

project management (risk analysis, planning, monitoring cost estimates);•

safety/decommissioning;•

waste/transport;•

technical studies, technical expertisechemical engineering, ventilation);•interfaces/facilities.

(remoteoperation,

characterisation,

Organisation set-up for the decommissioning of Grenoble nuclear site
The PASSAGE project
Created in 1956, the CEA Grenoble is one of the civilian centres of the Commissariat àl’énergie atomique.

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Since January 2001, the centre has been engaged in a remediation and dismantlingplan of its nuclear facilities. The project, entitled PASSAGE, last 15 years. The final
decommissioning was finalised in 2015.
The centre includes six basic nuclear facilities:•

INB 19 (Melusine) reactor shut down since 1988;•

INB 20 (Siloé), reactor shut down since 1997;•

INB 21 (Siloette) reactor shut down since 2002;•

INB 61 (LAMA) laboratory analysis of radioactive materials;•

INB 36 (Sted), solid storage facility;•

INB 79 (Sted), decay storage facility.

The PASSAGE project (decommissioning of the six nuclear facilities) symbolises theevolution of the CEA Centre in Grenoble, from its nuclear origins to the recognised
position it occupies today in the fields of microelectronics and micro andnanotechnologies. The objective of this project was to enable the reuse of
decommissioned buildings and their integration into the new life of the centre.
A dedicated organisation has been set to control the project. A steering committee
consisting of representatives of the main directions of CEA most involved, which meets
twice a year to check the progress, decide on possible new directions and check the rightthe means used and objectives.
Figure A.2.3: Global overview of the PASSAGE project

Project organisation
The Nuclear Clean-up and Dismantling Division as project owner delegates its function to
the Decommissioning Project Department represented by a project manager (DD&R
project manager).

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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATION

By delegation, the Director of the Grenoble Centre (Technology Research Division) is
in charge of all activities on the site. The operator (facility manager) is responsible forsafety and the safety of all operations in within the nuclear facilities and is under the
responsibility of the Nuclear Energy Division
Units of the CEA of Cadarache or Marcoule centres provide technical support,
expertise safety and security of the decommissioning operations and operating. In
addition, an entity of the Grenoble Centre responsible for supervising the activities
involved in nuclear safety and security (as control of 2nd level).
The denuclearisation of the CEA/Grenoble is designed globally:•

the facilities are all complementary;

Examples:– Siloé is used for cutting objects from Melusine reactor;– Lama is used for reconditioning of containers High Activity from STED facility.
•

the hierarchical organisation is by profession (not facility):– optimisation of manpower;– rationalisation of operating modes between the different facilities.

•

whenever possible, contracts are “cross” and multi-facilities:– assistance in project management;– support for operation;– decommissioning.

This organisation has been set for efficiency and exploitation of skills and resources
with high level of delegation and project control. It has been adapted to the needs whichmean the constant evolution of the project, based on macroscopic risk analysis.
The steering of the project is provided by the steering committee involving
stakeholders from CEA Grenoble and management representatives of the CEA (seeFigure A.2.4). It meets twice a year to check the progress, decide on eventual new
directions and check the adequacy of the means used and goals.
Figure A.2.4: CEA Grenoble project organisation
Steering
Committee

Strategic management
Director Nuclear Clean-up
and dismantling

Director CEA
Grenoble

Operational management
Director Nuclear Clean-up
and dismantling

Regulatory aspect

78

Human
resource aspect

Director CEA
Grenoble

Nuclear Energy Division
CEA Grenoble
Clean-up Division
Grenoble Research Division
CEA quality
CEA safety
CEA communication
CEA Human Resources

Technical
economical aspect

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CEA DECOMMISSIONING ORGANISATION ADAPTED TO GRENOBLE NUCLEAR CENTRE NUCLEAR DECOMMISSIONING ORGANISATIONThis type of organisation needs mutual respect and complementarity between actorsof the project: (see Figure A.2.5 below):•

responsibilities and respective missions:– simplified, explicit, readable in the hierarchical structure;– described in the management plan (no need of interface procedure).

•

management of decommissioning projects:– Chief Operating Officer (Deputy Leader facility) member of the project team;– Binomial Project Manager – Deputy Facility Manager;•

Steering PASSAGE:– head of facilities manager member of PASSAGE project team.
Figure A.2.5: Organisation of the PASSAGE project
Nuclear Facilities Section

PASSAGEManagement (Nuclear
Energy Division Grenoble)
Cost,
Human Resources

Facilities Operation
Manager

Clean-up
Manager

Melusine

Melusine

Siloette

Siloette

Siloe

Siloe

Lama

Lama

STED

STED

Waste Management
Manager

Human resources
Initially (during pre-commissioning activities see Figure A.2.6 below), the CEA relied on its
own personal operating the facilities to control the security and the clean-up of
experimental means. Gradually, companies specialised in dismantling took in charge alltechnical operations with CEA continuing to ensure the project steering and control of
security.
At the same time, an internal conversion plan for employees was developed andimplemented aiming at involving the workers in the project but also providing an outlook
and perspective for the future for them. As such, discussions with the social partners
were undertaken to ensure them a repositioning in a new sector of activity at the end of
their planned involvement in the project.
Moreover, an important work of collecting the “feedback” accumulated by theemployees of the project was done on a continuous basis, so that all CEA dismantling
actors can benefit from it.

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Figure A.2.6: CEA human resource planning
CEA Passage Project

Other contracts

Sub-contractors

300

250

Workforce

200

150

100

50

0
2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

Year
Main POCO Phase

Subcontracting aspects
During pre-decommissioning activities, the contracts were mostly used for preliminary
studies or small clean-up operations in the facilities. Global project management
assistance (see Figure A.2.7) was already used, as well as support contracts for waste
management, transport, co-ordination and safety. These contracts are turned later on
into a global contract when the time for dismantling operations comes.
Figure A.2.7: CEA licensee/facilities management and project management
CEA
Licensee/facilities management and project management
Dismantling

Cleaning/POCO

Global contracts

Contracts

CEA

Studies
Equipment procurement
Implementation of work

Studies orsmall work
packages

Fuel andspecific
materials

Global assistancecontract• Planning, budget• Preparation of contracts• Data, records andreports• Specification of work
packages

Support contracts for site
Waste management – Transport – Studies for regulatory bodies – Co-ordination

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EDF-FBR 1 240 MW

Annex A.3. France – Case study 2:
EDF-FBR 1 240 MW

Background
Decommissioning strategy:
Immediate decommissioning.

Schedule:
30 years.

Actual status:
Vessel internal part (fuel supporting plate) dismantling phase will start in 2019:• sodium has been drained from primary and secondary circuits;• secondary circuits are dismantled (except secondary heat exchangers);• main primary equipment has been dismantled from the vessel (heat exchangers andpumps).

Experience in transition from operations to decommissioning in other projects:
Nine reactors in dismantling phase.

Decommissioning preparatory activities
Summary•

The first decommissioning engineering activities studies started just a few months
after the final shutdown (1998) with the aim to prepare the request fordecommissioning decree and to undertake as soon as possible the transition
period activities.

•

Activities have been first concentrated on turbine hall dismantling, chimneys
dismantling, removal of large steam pipes in order to give visible signs that
decommissioning has started. The main transformer and the high voltage lines
have been also dismantled at that time.

•

Then some ancillaries systems were customised to suit dismantling needs:– commissioning of a new pumping station to suit lower needs: from
150 000 m3/h to 1 500 m3/h;– new demineralisation unit: from 5 000 m3: H per day to 40 m3/day;– site electrical supply: from 225 kV to 20 kV.

In parallel, conceptual and basic designs were developed to prepare the ground forthe dismantling licence request file. Finally, the NOAH process was selected for sodium

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EDF-FBR 1 240 MW

treatment. After a risks analysis it was concluded that two small sodium treatment units
would be better than a larger one.
The waste route for soda (produced by NOAH process) was really innovative as thesoda is concentrated in a cement matrix within 1 m3 big bags.
•

Safety diesel engines were sold and diesel building emptied from their equipment.

•

No buildings were demolished during the decommissioning preparatory activity as
the decommissioning funds were allocated in priority to the sodium risk reduction.

Regulatory framework (plant/site history “previous characterisation data”)
Regulator/types of licences required
In operation from 1986 to 1998. The request for decommissioning licence was issued in
April 2003. The decommissioning licence was granted on 21 March 2006 with anenvironmental target reducing drastically the releases to atmosphere in august 2017
linked to the end of the sodium treatment (sodium traps). This decree authorised thesodium treatment using different technologies (hydrolyse, carbonatation, etc.).

Licensing strategy used
A request for dismantling decree has been submitted to the regulatory body covering thecomplete dismantling phase. The dismantling decree contains some hold points for somespecific milestones (for example the commissioning of the sodium treatment unit andthe filing of the reactor vessel with water after sodium drainage and treatment).

Licensing documents for submittal to regulator (including support documents needed)•

description of the plant;•

environmental impact study;•

waste management plan;•dismantling plan;•safety analysis report;•

operating and surveillance rules.

Regulatory oversight during transition period
The regulatory body has inspected and continue to inspect regularly the site.

Public involvement/stakeholder engagements
See social economic section.

Decommissioning planning
Main strategies and approaches used
The strategy was first to show to the public that the dismantling phase was reallyengaged. Then the strategy for sodium disposal was set up.
Concerning waste treatment and storage, the policy was to keep existing buildings. So
the turbine hall was used to house the sodium treatment facility, but some constraints
against seismic risk were raised and lead to extensive reinforcement works.

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Due to the need to monitor permanently the sodium risk using the relevant operatingprocedures, it has not been possible to have a cold and dark approach for systems
shutdown. Systems were progressively decommissioned under specific and somehow
complicated procedures.

Decommissioning scope, start and end point
It can be considered that the transition period lasted from final shutdown (1998) todecommissioning decree issuance (03/2006). During this transition period, non-nuclear
equipment has been dismantled. The dismantling of the first nuclear components started
just after the DEC decree issuance

Defueling and fuel logistics strategy
Fuel removal from the vessel started immediately after shutdown as it was authorised in
the decree stating the plant final shutdown issued in 12/1998.

Waste management strategy
The waste management strategy for this site is part of a global strategy linked to a “nonrelease threshold” national approach. The waste classification is based on the waste
zoning, it means that any equipment located in a nuclear zoning is considered as anuclear waste. Then characterisation measures help to determine what is theappropriate waste route (such as ILW-MLW waste repository or very low-level waste[VLLW] repository).
The waste packaging is done on-site and then wastes are transported to existing
intermediate-level waste and VLL waste national repositories.
The concrete blocks containing soda are temporary stored on-site.

Social/economic impact
Special funds were allocated from 1998 to 2005 for mitigating social aspects in order toease the economic and social transition. The objectives were to assist people that had
lost their jobs and support development projects involving private companies,
associations and local communities
About 208 signed agreements were signed with companies and around 1 300 jobs
were created and maintained).
The social/economic plan has been eased thanks to a very dynamic area located at
50 km from the plant.
Public acceptance: Implication of the plant owner and local economical actors in
addition to a good communication about the technical solutions proposed by the plantowner have contributed to obtain a good public acceptance for the dismantling.

Business strategy and financial provisions
The breakdown of responsibilities and contract allotment was the following:•

nuclear safety and licensing responsibility: operating owner of the plant;•

project management: operating owner of the plant through its dedicatedengineering unit;•

basic design responsibility: the initial designer for the core systems and the ownerfor the rest (through internal engineering unit);•

procurement management: owner with the support of internal procurement
division;

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activities during “transition period”:– post-operation clean-up, draining , operational wastes: former operating team;– progressive shutdown activities: mainly dedicated contract and support fromformer operating team;– fuel handling: former operating team with the support of specialised company;– turbine hall dismantling: dedicated contract;– construction of temporary waste storage areas: dedicated contract;•

decommissioning funds were available at the time of shutdown.

Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
The responsibility of the dismantling project remains within the operator/owner. In early
2000, a dedicated structure was created to co-ordinate, prepare and follow up all the
dismantling activities for GEN 1 and fast breeder reactors.
Concerning the site staff:•

1999: 650 owner staff + 450 subcontractors staff;•

2006: 110 owner staff + 300 subcontractors staff;•

2016: 85 owner staff + 3 500 subcontractors staff.

Planning, implementation and project management approach for optimisation
The planning and implementation is under the responsibility of the Project Manager.
According to dismantling plan and project risk analysis, the project manager has
proposed the following allotment.

Services contracts
Overall operating of safety systems needed for dismantling: owner through a dedicatedteam.
•

ancillaries systems operations and maintenance: dedicated contract;•

radioprotection support: dedicated contract;•logistic for waste management at site: dedicated contract.

At site work contracts•

turbine hall dismantling: “fixed-price” contract;•

dismantling of miscellaneous nuclear systems and equipment: several “fixed-price”
contract;•

vessel and internal segmentation: dedicated contract including basic design
withhold point before to engage detailed design.

Comments: due to the unique character of the plant, it has been found suitable in arisk mitigation approach to keep the know-how of the designer and to contract with him
the basic and detailed design for the dismantling of the reactor vessel and major
components and cold traps.

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Experience and knowledge management methods
Some recruitment of young engineers at the beginning of the decommissioning project
has been done to train them on sodium technology. This has been considered as a goodpractice to maintain the know-how until the end of sodium risk.
The design documentation kept at site was very helpful to build the dismantlingscenario and to prepare the work on-site.

Preparation and training of decommissioning staff
Specific training courses were organised to train some former operators staff todecommissioning/dismantling projects specificities.

Projects conducted during transition period
Initial site characterisation
Circuits characterisation in view of preparing the acceptance files for final disposal.

System and building decontaminations
The plant was in good shape and no special action towards decontamination has been
engaged for the time being on the civil works.
Draining and treating sodium can be considered as part of the decontamination
process.

Asset management
Special attention is paid continuously to building maintenance through dedicatedmaintenance plan.

Disposition of operational waste•

nothing special to report;•

installation of a waste temporary storage area in the turbine hall.

Technology and technical requirements – preparations for dismantlement projects•

The key point for fast neutron reactors is the treatment of sodium. A dedicatedteam has been set just after the final shutdown to find a solution for sodium
treatment. Among the few available technologies, the hydrolyse technology has
been retained. The sodium treatment workshop was installed in the turbine hall
after removal of all equipment in the turbine hall.

•

Due to the high level of radiation in the vessel and unfriendly atmosphere in thereactor vessel (Argon gaz and sodium residues), specific laser remote tools havebeen developed to cut pipes inside the vessel.

Lessons learnt
Positive results•

Wide experience gained in sodium treatment through hydrolyse (5 900 m3).

•

Experience in remote laser cutting in unfriendly atmosphere.

•

The dedicated funds for social and economic aspects efficiency have been proven.

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As the decommissioning activities and basic design started immediately after
shutdown the access to a well-organised documentation is part of the success of
this project.

Difficult challenges

86•

Need to maintain significant and motivated operating team until final removal andtreatment of sodium.

•

The management of the contract for progressive shutdown of systems is very
heavy in terms of preparation of works due to a too detailed approach per systems.
The opportunity to have a cold and dark strategy has to be considered.

•

Operating staff reduction has been a real challenge as the final shutdown of theplant was not expected; therefore, there was no time for preparation.

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EDF-PWR 305 MW

Annex A.4. France – Case study 3:
EDF-PWR 305 MW

Background
Project:
PWR 305 MW.

Decommissioning strategy:
Initially safe store approach then moving to immediate decommissioning in 2001.

Schedule:
30 years.

Actual status:
Vessel segmentation in progress.
Steam generator moved to VLL wastes repository after decontamination.

Experience in transition from operations to decommissioning in other projects:
Nine reactors in dismantling phase.

Decommissioning preparatory activities
Summary•

1998 1999: shutdown activities, circuits draining, surveillance of the installation.

•

1999-2007: partial dismantling of the installation.

•

2007-2008: layout works (ventilation, waste management).

•

2008-2013: heavy dismantling activities.

Regulatory framework (plant/site history “previous characterisation data”)
Regulator/types of licences required•

In operation from 1967 to 1991, final shutdown in 1993.

•

End of fuel removal: December 1995.

•

Dismantling decree in 09/2007.

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Licensing strategy used
Until early 2000, the strategy was safe store. This strategy changed in 2001 for a prompt
dismantling. Then a request for dismantling decree has been submitted to the regulatory
body covering the complete dismantling phase.

Licensing documents for submittal to regulator (including support documents needed)•

description of the plant;•

environmental impact study;•

waste management plan;•dismantling plan;•safety analysis report

Regulatory oversight during transition period
The regulatory body has inspected regularly the site.

Public involvement/stakeholder engagements:
No special concerns as there are two other NPP in operation on the site.

Decommissioning planning
Main strategies and approaches used
Initially safe store approach with long-term surveillance.

Defueling and fuel logistics strategy
Fuel removal from the vessel immediately after shutdown.

Waste management strategy
Waste packaging on-site. Temporary storage of waste on-site as a buffer before
transportation to existing M-L waste and VLL waste national repositories.

Social/economic impact
Very limited impact as there are two other NPP in operation on this site that were incapacity to absorb staff coming from the shutdown plant.

Business strategy and financial provisions
N/A (decommissioning funds available at the time of shutdown).

Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
The responsibility of the dismantling project remains with the operator/owner. A
dedicated structure was created, in early 2000, to co-ordinate, prepare and follow up all of
the dismantling activities for GEN 1 reactors.

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Planning, implementation and project management approach for optimisation
The planning and implementation is under the responsibility of the Project Manager.
According to dismantling plan and project risk analysis, the project manager has
proposed the following allotment.

Allotment for dismantling period
Services contracts•

safety systems needed for dismantling overall operating: owner through a
dedicated team supported by the neighbouring NPP;•

ancilliaries systems operations and maintenance: owner through dedicated teamsupported by services contracts and by the neighbouring NPP;•

radioprotection support: part owner through dedicated team supported by services
contracts and by the neighbouring NPP;•

logistic for waste management at site: owner through dedicated team supported
by services contracts and by the neighbouring NPP

At site work contracts•

dismantling of miscellaneous nuclear systems and equipment: dedicated contract;•

vessel and internal segmentation: dedicated contract;•demolition of conventional buildings (turbine hall): dedicated contract.

Experience and knowledge management methods
Experienced operators were no more available when it was decided to cease the safe
store approach.

Preparation and training of decommissioning staff
Specific training courses were organised.

Projects conducted during transition period
Initial site characterisation
Turbine hall demolishing in order to have place for construction of a waste temporarystorage area. Circuits characterisation in view of preparing the acceptance files for final
disposal.

System and building decontaminations
NSSS equipment decontamination has been done just before SG dismantling with theview of transportation of the complete SG to VLLW repository (not during the transition
period).

Asset management
Special attention is paid to building maintenance through dedicated maintenance plan

Disposition of operational waste
Nothing special to report.

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Technology and technical requirements – preparations for dismantlement projects
Due to initial safe store approach, no decontamination after shutdown was undertaken.
However, decontamination has been implemented for SG just before their dismantling inorder to send them to VLL waste repository.

Lessons learnt
Positive results
Decontamination of SG leads to consider them as VLLW. Logistic support from therunning plants on-site is beneficial.

Difficult challenges
Insufficient documentation and preservation of special tools during transition period
have led to some costs overrun during dismantling period.

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DECOMMISSIONING IN VATTENFALL

Annex A.5. Sweden – Case study: Decommissioning in Vattenfall

Introduction
Ringhals Nuclear Power Plants (NPP) consists of four reactors; one boiling water reactor(BWR) (Ringhals 1) and three PWR (Ringhals 2-4). Ringhals NPP company (Ringhals AB) is
co-owned by Vattenfall AB (70.4%) and Uniper (29.6%) but due to a historic government
approved settlement, Vattenfall has the full financial responsibility for thedecommissioning.
In 2015, due to economic reasons a decision was taken to shut down permanently in2020 and 2019 the two oldest reactors Ringhals 1 and Ringhals 2. The two newer reactors
Ringhals 3 and 4 will continue operation until the first half of 2040.
Up to this point, the decommissioning planning of Vattenfall Group and its majority
owned NPPs has been carried out separately, with minor co-ordination between plants.
However, in conjunction with the decision to shut down of Ringhals 1 and 2, Vattenfall
decided to create a decommissioning organisation (Business Unit Nuclear
Decommissioning) with the sole task of co-ordinating all of the Vattenfall
decommissioning programmes. The current plan for the decommissioning in Ringhals isfor Vattenfall to apply for the nuclear licence for Ringhals 1 and 2 for a defueled plantstatus. This is however pending a recommendation from Swedish Safety Radiation
Authority (SSM) after an extensive review and finally pending an approval from theSwedish government. If the nuclear licence for Ringhals 1 and 2 for any reason cannot be
obtained by Vattenfall as described above, the current intention is then to achieve thesame organisational separation between decommissioning of Ringhals 1 and 2 and theoperation of Ringhals 3 and 4, but within the Ringhals AB organisation.
The following two sections describe the current plans for the final shutdown,
defueling and decommissioning in Ringhals. Finally, a summary of arguments on themain approach taken for decommissioning set-up is provided.

Final shutdown and defueling in Ringhals
A project (STURE) was initiated as a consequence of the decision to shut down Ringhals 1
and 2 with the primary goal of completion of the final shutdown and the following
defueling of Ringhals 1 and 2 and prepare for the coming decommissioning. The project
STURE should also serve as the counterpart to specific decommissioning projects.
The project STURE has been organised in subprojects with the following main tasks:

Organisation•

Secure key staff and competence within the Ringhals 1 and 2 organisations toenable safe and secure operation until planned final shutdown and through thedefueling period.

•

Maintain an effective safety culture through the completion of defueling.

•

Facilitate the organisational transition from four units to two units.

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Technical arrangements•

Plan for and carry out defueling activities.

•

Physically separate common support systems between Ringhals 1 and 2 andRinghals 3 and 4 to enable decommissioning and continuous operation.

•

Identify, assemble and, if necessary, develop plant documentation to support
shutdown, carry out defueling activities and facilitate the licence transfer to thedecommissioning company.

•

Execute necessary pre-decommissioning activities on behalf of thedecommissioning organisation before possible licence transfer (e.g. preparatorysite work, carry out full system decontamination after shutdown etc.)•

Ensure that all legal conditions are met to close down Ringhals 1 and 2 and enablea transfer of the licence to the decommissioning organisation after defueling if so
is decided.

Financial optimisation•

Financial management to maintain the competitiveness of Ringhals and to
manage impacts on the Ringhals business plan due to closing down of Ringhals 1
and 2.

•

Optimise management of the nuclear waste fund and manage financial
arrangements involving the decommissioning company.

•

Ensure optimal management of investments, fixed assets and inventory.

Decommissioning programme and organisation in Ringhals
All the decommissioning tasks in Ringhals are currently planned to be organised in a
programme that will consist of both decommissioning projects and line activities. The
organisation for all the decommissioning tasks will consists of two main parts: a line
organisation and a programme and project organisation.

Decommissioning line organisation
The line organisation includes functions necessary for holding a licence for an NPP
cleared of nuclear fuel, including an adapted management system with functions forsafety management and operation management. The line organisation is also responsible
for securing key competences for the organisation, developing their skills and managing
experience feedback from the decommissioning projects, international experiences etc.
The line organisation develops the generic decommissioning concepts/models anddefines the overall framework and requirements for the decommissioning projects, basedon Vattenfall’s and Ringhals’ strategic direction, external requirements etc. The line
organisation will follow up on the project’s progress and provides support if necessary.
Contacts with the safety authorities are co-ordinated by the safety manager. The
documents submitted to the authorities are reviewed by the line organisation.

Decommissioning programme and project organisation
The programme and project organisation plans and executes all decommissioning
activities and projects. Key competences necessary for the projects should be positioned
within the programme and project organisation. Other competences needed in thespecific projects are assigned full- or part time from the line organisation, the old plant

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DECOMMISSIONING IN VATTENFALL

operator, Vattenfall or from contractors. The overall strategy is to execute thedecommissioning and dismantling activities to large extent with experienced contractors.
The programme and project organisation perform the general planning, licensing
work, procurement and finally provide management and support to the contractors
carrying out the decommissioning plan. The detailed planning is done side by side withqualified contractors.
In contacts with the authorities concerning planning and progress the program andproject organisation is working in close co-operation with line organisation and thedecommissioning safety manager.

Arguments for selected organisational approach
There are from a generic Vattenfall perspective many advantages of separating
decommissioning organisation from NPP operation organisation preferably using an
existing and specialised decommissioning organisation.
•

The proposed set-up makes it easier for the organisations to maintain full focus on
the core business. The operating organisation can focus on safe and secure
operation and the decommissioning organisation on how to optimise
decommissioning. In an organisation responsible for both actions, thedecommissioning will always come in second place.

•

International experience has shown that it is hard to carry out an effective
decommissioning project in an organisational structure and with a management
system that is adapted for power operation. A specific decommissioning
organisation makes it possible to customise the organisational structure andmanagement systems to support the decommissioning activities.

•

A specialised decommissioning organisation makes it easier to focus on the safety
aspects that are relevant for decommissioning which differ significantly from aplant in operation.

•

When building a new organisation it is possible to employ competences needed forthe decommissioning work instead of using the available staff in the operator’sorganisation, regardless of competence. A specialised decommissioning
organisation also makes it easier to build expertise and gain the management
experience in the long term.

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MUEHLEBERG NPP, BWR 390 MWe

Annex A.6. Switzerland – Case study:
Muehleberg NPP, BWR 390 MWe

Background of the test case
Decommissioning strategy:
Prompt decommissioning

Schedule:
2020-2031

Actual status:
The board of the company came to the decision in Oct., 2013 to shut down the plant at the end of
2019.
Final decommissioning plan submitted to the granting authority (Federal Department of theEnvironment, Transport, Energy and Communications, DETEC) in December 2015. Applying forthe decommissioning order coming into force at the end of 2019. Dismantling strategy is definite.
Expertise from several institutions for granting the order are expected at the end of 2017.

Experience in transition from operations to decommissioning in other projects:
Only some research reactors and conditioning facilities have been decommissioned respectively
are in the decommissioning stage. All of them had a transition phase of some years without
preparatory work for decommissioning.
This case (prompt decommissioning with fuel on-site) is a new approach.

Decommissioning preparatory activities
Summary
Planning of the project (licensing) has started six years before shutdown, and engineering
four years before shutdown.
An extensive set of decommissioning preparatory activities within the force of theoperation licence (during the last years of operation and the first months of the transition
period) is getting underway:•

Radiological Characterisation will be continued and updated before and after
shutdown.

•

Conditioning of operational waste will continued in the operation period andfinished in the second dismantling phase (phase after defueling).

•

Backfitting of the spent fuel pool cooling systems.

•

Transfer spent fuel from reactor vessel into the spent fuel pool during the firstmonths after shutdown.

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MUEHLEBERG NPP, BWR 390 MWe•

Unloading (packaging and transfer to intermediate storage) spent fuel from thespent fuel pool as soon as reasonably possible.

•

Decontamination of primary system is not preferred (low radiological level), but
decontamination of some auxiliary systems and components are planned.

•

Declassification, abandonment, discharge of systems and equipment, structuresand modifications to existing systems will be conducted as soon as possible after
shutdown.

•

Removal of hazardous waste.

•

Construction/renovation of auxiliary facilities (e. g. for waste treatment) andpreparation of work areas to support dismantling and treatment activities will
start promptly after shutdown

Regulatory framework (plant/site history “previous characterisation data”)
Regulator/types of licences required
With the decision of the owner for prompt decommissioning an inter-institutional
monitoring group for the preparation of decommissioning lawsuit was installed.

Members•

Swiss Federal Office of Energy (SFOE), authority for the lawsuit.

•

Swiss Federal Nuclear Safety Inspectorate (ENSI).

•

Federal Office for the Environment (FOEN).

•

BKW Energy Ltd as owner of NPP Mühleberg.

•

Canton of Bern.

Subgroups on•

technical aspects;•

legal procedure;•

communication.

The owner needs a decommissioning order from the granting authority (DETEC) for
start-up the dismantling work.
Assessment of the decommissioning project (all documents for obtaining thedecommissioning licence) by this institutions:•

Swiss Federal Nuclear Safety Inspectorate (ENSI).

•

Federal Office for the Environment (FOEN).

•

Occupational regulator (State Secretariat for Economic Affairs [SECO]).

•

Canton of Bern.

The SFOE, authority for the lawsuit, requests for an expertise from every institution.
The expertises are respected and get involved in the decommissioning order.

Licensing strategy used
The owner of a nuclear facility is to be obliged to decommission the nuclear facility if it
has been definitively taken out of operation. The department orders the96

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decommissioning and specifies which tasks require a permit to be obtained from thesupervisory authorities.
The owner decided to dismantle the plant in three phases:
1.

with fuel on-site (five years)

2.

from fuel-free up to freedom of radioactivity (clearance level achieved andgranted, 5 years)

3.

documentation of performed dismantling and state of the plant and area forrelease from the Nuclear Energy Act (1 year)

Licensing documents for submittal to regulator (including support documents needed)
In relation to the decommissioning project pursuant to the Nuclear Energy Act, these
documents must be submitted:•

phases and timetable for decommissioning work, decommissioning variants;•

individual steps of decommissioning work;•

procedure for separating radioactive and non-radioactive waste and managementof radioactive waste;•measures for radiological protection;•

security measures;•

accident analyses and emergency preparedness measures;•

human and organisational factors;•

management system;•

environmental impact report;•

total costs and securing of the financing.

Regulatory oversight during transition period
In accordance with the operation licence the regulator supervises the facility andassesses the measures for transferring the plant in a safe and stable condition for startup of dismantling.

Public involvement/stakeholder engagements
PublicDecommissioning project (application document, final decommissioning plan, safety
analysis and environmental compatibility report) is undergoing public consultation.

Federal Nuclear Safety Commission (NSC)
The NSC advises the Federal Council, the Federal Department of the Environment,
Transport, Energy and Communications (DETEC) and the nuclear supervisory authorities
on issues relating to the safety of nuclear facilities.

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MUEHLEBERG NPP, BWR 390 MWe

Decommissioning planning
Main strategies and approaches used
At the Nuclear-safety-regulator (ENSI) side:In preparation for the huge decommissioning project the following implementations andmeasures were conducted:•

a new section for decommissioning was established;•comprehensive supervisory concept of regulatory activities was implemented;•

technical guideline for decommissioning (ENSI G17) was implemented;•

monitoring group for external co-ordination of different stakeholders wasestablished at the licensing authority;•

resource planning and training activities were updated;•international co-operation was intensified.

ENSI ordered the owner after the shutdown-decision to submit a documentation by
the end of 2014 about the planned measures for the transition period to transfer the plantin a safe state before dismantling can begin (supervisory procedures with ENSI).

At the plant owner side
A project team, which specifies the final decommissioning plan and worked out thedecommissioning project (all documents for obtaining the decommissioning licence), wasestablished.
Decommissioning strategy was worked out and decided: Prompt decommissioning
with fuel on-site in the spent fuel pool.
A project for personnel management including staff-impact and staff-perspectives isconducted since 2015 (change management).

GeneralRegulator and operator get together frequently in technical meetings to talk about actualand planned activities.

Decommissioning scope, start and end point
Decommissioning scope is to dismantle all equipment of the plant in the technicalbuildings. The shell of the buildings will remain on the area. Further use of the buildings
and the area will be concerned in a second lawsuit.
Dismantling can start after establishing of the measures for transferring the plant in asafe and stable condition (in transition period). Spent fuel can remain on-site in the firstdecommissioning phase.
The end of the decommissioning is reached, if the plant no longer presents aradiological hazard.

Requirement
Decommissioning includes all necessary activities for the plant to be used for otherpurposes, no longer presents a radiological hazard, and is thus no longer subject tonuclear supervisory.

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MUEHLEBERG NPP, BWR 390 MWe

Defueling and fuel logistics strategy
Defueling of the plant has the highest priority. The schedule for defueling is five years,
because the fuel of the last core has to cool down in sufficient manner. The fuel will bepackaged and transported in dry casks to the intermediate storage centre.

Guideline requirement
After the final shutdown, the nuclear materials shall be transported to another suitable
nuclear installation. In particular, the fuel elements (or other forms of nuclear fuel in thecase of research facilities) shall be transported to such a location as soon as reasonably
possible.
In Switzerland exists a central intermediate storage for spent fuel and radioactive
waste from all nuclear facilities.

Waste management strategy
The applicant has to describe the procedure for separating radioactive and nonradioactive waste and the management of radioactive waste, e.g.:•

The choice of decontamination methods must be assessed in terms of radiation
protection, utilisation (recycling) of materials, reduction of the volume ofradioactive substances and the production of secondary waste. The planned
methods for clearance measurement must be presented in detail.

•The volumes of generated waste shall be estimated, for both types of radioactive
and non-radioactive waste. In the case of inactive and cleared materials,
conventional waste must be distinguished from hazardous waste.

The radioactive waste will be stored in the central intermediate storage centre up to
the commissioning of the deep geological repository.

Social/economic impact
Human and organisational factors have to be addressed in the decommissioning project•In particular, human resources required in the dismantling and for the necessary
operation of the installation must be determined in the decommissioning project.
These must be shown on a function-specific basis with the help of the planned
decommissioning sequence. A concept for dealing with any delay in the timeschedule must be provided.

•

The organisational structure and the planned procedures must be described. The
programme to take account of human and organisational factors must bepresented, including methods for the design of working equipment, the work
environment and processes.

Business strategy and financial provisions
Total costs and securing of the financing in accordance with Article 45, Nuclear Energy
Ordinance•

The costs of decommissioning and waste management as per Article 2 and Article
3 of the Ordinance of Decommissioning and the Nuclear Waste Disposal Fund,
respectively, must be determined in the decommissioning project underconsideration of internationally recognised methods.

Financial provisions have to be done in accordance of the Ordinance on theDecommissioning Fund and the Waste Disposal Fund for Nuclear Installations.

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MUEHLEBERG NPP, BWR 390 MWe

Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
Responsibility remains at the plant owner. The plant manager remains in the position
with the highest responsibility (safety-oriented). It’s foreseen to conduct the dismantlingby both, staff and contractors (for special tasks)

Planning, implementation and project management approach for optimisation
A dismantling project division, responsible for execution of dismantling, will be
implemented in the plant organisation.

Experience and knowledge management methods
Not applicable at this juncture

Preparation and training of decommissioning staff
Not applicable at this juncture

Projects conducted during transition period
Initial site characterisation
Characterisation data from the operation period exists. The site characterisation is goingon and will be updated before and after shutdown of operation. Especially the data fromdifficult accessible structures and components will be analysed and recorded after
shutdown.

System and building decontaminations
Partly decontamination of some systems and components are foreseen (full systemdecontamination is probably not required). This depends on the radiological level after
shutdown.
Up to now the plant have only a small damage of one fuel element. Therefore theprimary system operates in a low radiological level.
Buildings (controlled area) will be decontaminated up to the level for clearance.
Buildings (non-controlled area) and the surrounding area will be measured by random
sampling

Asset management
The costs for transition phase and operational waste are borne by the owner. The ownershould set up accruals.
The costs for decommissioning are covered by the decommissioning fund. This fundis controlled by an independent commission. The owner has to pay yearly contribution to
the fund.

Disposition of operational waste
The disposition is going on in the last years of operation and during the dismantlingphase. Treatment of the waste is possible at the plant and at the intermediate storage
centre.

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Technology and technical requirements – preparations for dismantlement projects
Not applicable at this juncture, planning is going on

Lessons learnt
Positive
The implementations and measures in preparation for the decommissioning of the plant
were very helpful to clear most questions and problems on both sides – regulator andoperator.
The requirements from the regulator side could be discussed and explained, which
was helpful for planning the decommissioning project and finalising the final
decommissioning plan.
The operator was able to present its actual planning and discuss the handling ofthese.

Negative
Will come after start of the dismantling phase.

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THORP TRANSITION FROM OPERATIONS, POST-OPERATIONS CLEAN-OUT

Annex A.7. United Kingdom – Case study:
THORP Transition from operations, post-operations clean-out

Plant description
The Thermal Oxide Reprocessing Facility (THORP) is located on the Sellafield site andstarted operations in 1997. It is currently operational although its owners are planningnow for its final shutdown in 2018.

Spent fuel from the UK advanced gas reactors (AGRs) and other materials are
reprocessed within THORP with the objective of extracting the materials such as Uranium
and Plutonium which can then be reused as required. The cooled oxide fuel is chopped
into pieces (sheared) before the fuel is dissolved in nitric acid and chemically separatedusing solvent extraction. The facility is complex, and has many connected facilities both
upstream and downstream such as effluent and other waste treatment facilities andthese need to be decoupled as part of transition.
The transition phase in this context is intended to end with a handshake to the startof the decommissioning programme. Historically, the management of such transition
phases on the Sellafield site has been sub-optimal, and to ensure this is not repeated a
dedicated team has been established with the objective of planning the transition phase.

The transition approach
It is intended that the incumbent plant operators will be used to complete as much of the
post-operations clean-out as possible to make use of their plant knowledge, experienceand skills. This part of transition has the objective of the removal of as much of theradioactivity, chemical and other hazardous materials as possible from the facility. The
objective of this phase of transition is to leave the plant in a safe, quiescent and wellunderstood configuration in preparation for decommissioning, as well as making best useof the normal established plant processes, waste routes and reagents.
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THORP TRANSITION FROM OPERATIONS, POST-OPERATIONS CLEAN-OUT

Preparations for transition have started, and the primary aims have been established as:•

risk and hazard reduction;•

enabling redeployment of resource and capability from THORP to other locations;•

reduction in life cycle costs;•

looking for opportunities to maximise the reduction in inventory during transitionby making best use of the operational systems, processes and procedures and theknowledge of the plant operators.

A key output of transition is judged to be knowledge in the form of plantconfiguration which will enable the safe and efficient decommissioning of the facility.
The operator has developed an outline transition plan with the objective of enabling asmooth transition from operations through to the start of decommissioning. A key part oftransition will be the post-operations clean-out, which has the following objectives:•

remove as much of the radioactive inventory from the plant as possible;•

remove chemical and other hazardous materials from the plant;•

leave the plant in a passively safe condition suitable for optimal decommissioning
to start;•

define the detailed sequence of decoupling the plant from other site facilities;•

define and implement a managed reduction of manpower suitable for both an
initial surveillance and maintenance phase, followed by further reductions as
required in preparation for the decommissioning phase.

It is expected that the operational safety case will need to be modified duringtransition to support operations associated with the post-operations clean-out.
To enable successful transition, a number of success factors have been defined, which
can be measured at the end of transition:

104•

Plant configuration is known, documentation and recorded in such a way thatenables efficient decommissioning.

•

The Plant Safety Case has been reduced in scope to reflect cessation of operations(including the post-operations clean-out), the technical specification has been issued.

•

All wastes from the post-operations clean-out phase have been removed from thefacility, or waste routes as required for their complete removal are in place.
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THORP TRANSITION FROM OPERATIONS, POST-OPERATIONS CLEAN-OUT•

The knowledge management process has been completed.

•

The organisational transition has been completed, probably in a phased manner,such that it is suitable for surveillance and maintenance and the start ofdecommissioning if required.

•

Regulators and other stakeholders support the post operational status for eachfacility, and support the handshake to the decommissioning phase.

•

Any systems not required by the safety case have been deactivated.

Regulatory process
In the United Kingdom, a nuclear site licence is issued to the owner of a nuclear site (the“body corporate”) which permits the defined site to be used for specified activities. As
such, the licence remains in force from operations through to the completion of
decommissioning and ultimate revocation of the licence, and a specific decommissioning
licence is not required. The regulatory process is based on UK primary legislation
requiring that risks are reduced to as low as is reasonably practicable which is termed the
ALARP principle. This requirement ensures that relevant good practice and appropriate
standards are applied throughout the nuclear life cycle, including transition through todecommissioning.
A number of conditions are attached to each site licence, and under these conditions
arrangements and actions by the licensee which are judged by the regulator to havenuclear safety significance may require prior regulatory permission before workcommences or changes are implemented. The UK nuclear regulatory regime is therefore
described as a permissioning regime, and as such the regulator may impose regulatory
hold points at key life cycle points such as the commencement of decommissioning.
Such a hold point would normally be accompanied by the submission by the licensee of asafety case, and the licensee cannot proceed beyond without formal regulatory
permission which would be based on a regulatory view of the adequacy of the safety case.

Safety case
It is expected that the operational safety case will need to be modified during phases ofpost-operations clean-out to accommodate additional activities. Following completion of
the post-operations clean-out the safety case will be further modified and reduced inscope with accompanying changes to the technical specification, engineering schedules
and safe operating envelope which will reflect the reduction in hazardous inventory.

Management of radioactive wastes
During transition, waste export and processing routes are intended to be as if the plant
were fully operational. A key success factor of the transition phase is that the waste
remaining within the facility at the handshake to the start of decommissioning ischaracterised such that its properties and required waste route is known. This reduces
the potential for the generation of ‘orphan’ wastes, those waste processing routes areeither unavailable or unknown.

Reference
MacPherson, I. and A. Dunlop (2016), “Development of a Systematic Approach to Post
Operations Clean Out (POCO) at Sellafield”, Sellafield Limited as presented at PREDEC
2016, 16-18 February 2016, Lyon, France.
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DECOMMISSIONING OF JOSÉ CABRERA NPP

Annex A.8. Spain – Case study:
Decommissioning of José Cabrera NPP

Background
Decommissioning strategy:
Immediate dismantling

Schedule:
Operation: From 1969 to 2006*
Transition: From 2006 to 2010
Decommissioning: Since 2010

Actual status:
Dismantling of systems. Reactor vessel internals and large components have been dismantled.
Currently works are focused on the decontamination of concretes, the demolition of buildings
and the site restoration.

Waste “interim” storage/national repository (available or not):El Cabril National Repository, for LILW and VLLW and the on-site independent spent fuel storage
installation for special waste class and spent fuel.

Experience in transition from operations to decommissioning in other projects:
Vandellós 1 NPP. The Vandellós I gas cooled-graphite reactor was decommissioned in about five
years (from 1998 to 2003) to what was known as level 2 of IAEA.
* October 2002: Publication of permanent shutdown in 2006.

José Cabrera NPP site

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DECOMMISSIONING OF JOSÉ CABRERA NPP

Decommissioning preparatory activities
Summary
Organised decommissioning planning. Start-up of an extensive set of decommissioning
preparatory activities under both the operational license (operation and transition
periods) and decommissioning licence.
Operational
licence

Decommissioning
licence

Operational
stage

Transition
stage

Decommissioning
stage

Planning, engineering and licensing of project

X

X

--

Radiological characterisation and radiological database

X

X

X

Conditioning operational waste

X

X

--

On-site independent spent fuel storage installation (ISFSI) and spent
fuel cask licensing. Unloading spent fuel from reactor pool and storage
at the ISFSI

X

X

--

Decontamination of primary system

--

X

--

Discharge of systems, equipment and structures not required fordismantling, including removal of hazardous waste and drainage systems

--

X

X

Personnel training and adapting organisation to D&D

--

X

X

Modifications of existing systems or design of new ones to support
dismantling activities (ventilation, fire protection and electrical systems)

--

--

X

Construction/renovation of auxiliary facilities and preparation of work
areas to support dismantling activities (refurbishment of the turbine hallbuilding as the decommissioning auxiliary building, upgrade in the
radwaste storage area)

--

--

X

Dismantling of conventional elements (cooling towers, diesel generator
building, transformers and disassembling of the control room)

--

--

X

Planning, engineering and licensing of project
The planning for decommissioning began in 2003, once the date for the José Cabrera's
permanent was known. During this period the following tasks were carried out:•

Basic strategy study for the facility to be dismantled: the Study included thephysical and radiological inventories, costs of dismantling and proposed thepreferred decommissioning option.

•

Basic engineering and licensing documentation: Preparation of the basic
engineering and licensing documentation required by Spanish law for theauthorisation for decommissioning, considering the strategy chosen.

•

Detail engineering: engineering tasks and design activities for specifying thevarious tasks involved in site preparation, and setting out their tendering
requirements.

In parallel to this, the licensing process for obtaining the authorisation fordecommissioning was carried out with the competent authorities. This included a reviewof the mandatory documents.

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Radiological characterisation and radiological database
One of the most important steps in decommissioning planning was the radiologicalcharacterisation of the facility. Characterisation activities began when the plant was inoperation, and they have continued during the decommissioning period. The scope ofcharacterisation activities included not only the installation but also the environmentthat may have been affected by the facility´s operation. A radiological database wasdeveloped to store all radiological data from the beginning of the site radiologicalcharacterisation.

On-site independent spent fuel storage installation (ISFSI)In 2009 spent fuel was removed from the pool and it is currently stored in 12 casks at an
on-site independent spent fuel storage installation (ISFSI).
José Cabrera ATI

Loading spent fuel into the cask.

Independent spent fuel storage installation.

Decontamination of primary system
During the shutdown stage decontamination of the primary circuit was carried out inorder to reduce worker exposure during decommissioning activities. Duringdecommissioning, after the disassembly of the large components at the José Cabrera
plant, it was shown that there was a highly significant dose reduction to the workers.

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Primary system decontamination.

Modifications of existing systems or design of news to support dismantling activities
During 2010 and 2011, modifications of existing systems or design of new systems to
support dismantling activities were carried out. These activities were performed
according to the system modification plan.
The electrical system was modified. This included the installation of a new electricalsupply adapted to the needs of the decommissioning process. The water supplies (fireprotection system, general services and dilution effluents system) and the ventilation
system of the reactor and auxiliary building were also adapted to the new situation.

110

New fire protection pumps.

Fire protection system modification.

Ventilation system adaptation.

New portable filtration unit.

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Electric supply system modifications.

New electrical building.

Discharge of systems, equipment and structures not required for dismantling, including
removal of hazardous waste and drainage systems
All systems were deactivated (drained and/or de-energised) prior to equipment removal
and the potential isolation point of others systems required to support decommissioning
activities. These activities were performed according to the discharging system plan.
Discharging of system started during shutdown period and continued during thedecommissioning stage.
According to the reduction of risks plan, inflammable or toxic products that mightpose a problem during the works were removed from the plant.

Discharge of components prior to dismantling.
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Construction/renovation of auxiliary facilities and preparation of work areas to support
dismantling activities
At the beginning of decommissioning period, all the components from the turbine hall
were removed and several civil works were carried out to transform the building as the
new Decommissioning auxiliary building for the treatment and storage of the radioactive
wastes to be generated during the dismantling of radiological areas. Subsequently cutting
and decontamination workshop has been set up in this building.
Warehouses to store wastes arising from dismantling activities were improved andadapted. Likewise, an area was enabled for the clearance of materials.
These works were carried out according to the conditioning auxiliary facilities plan.
Refurbishment of the turbine hall building as the decommissioning auxiliary building

112

Initial status of the operational plant.

Dismantling of the turbine components.

Dismantling of the turbine components.

Current status of the decommissioning auxiliary building.

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DECOMMISSIONING OF JOSÉ CABRERA NPP

Waste storage modifications and clearance area preparation

Waste storage upgrading.

Clearance area.

Dismantling of conventional elements
According to the disassembly of non-radiological systems plan, some conventional
dismantling activities relating to infrastructures that did not have any radiologicalconnotation were performed.
Among the most significant buildings and facilities in this group were the diesel
building, the electrical transformers and the cooling towers. Cooling towers weredemolished to reuse this zone as a temporary storage area for conventional scrap before
dispatching it from site.
Demolition of cooling towers

Diesel generator building

Dismantling of components.

Diesel generator building converted into
an auxiliary storage area.

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Disassembly of the control room

New control room for decommissioning

Regulatory framework
Regulator/types of licences required
Responsibility for decommissioning of nuclear facilities in Spain lies with the National
Radioactive Waste Company (Enresa).
When a nuclear facility ceases operation, the holder of the operating licence is
responsible for the post-shutdown activities. These may include preparatory activities fordecommissioning. For the purposes of Spanish legislation, the permanent shutdown
phase constitutes an amendment of the operating permit.
In order to be granted with the authorisation for decommissioning, the holder of theoperating licence must already have conditioned the operational radioactive waste
generated. They must also have unloaded the fuel from the reactor and spent fuel storage
pools or, at least, have a plan for spent fuel management approved by the Ministry ofEnergy, subject to a report from the Nuclear Safety Council (CSN).
Enresa’s responsibility is to draft and submit for approval to the Ministry of Energy
the decommissioning plan for each nuclear power plant, following shutdown, in order toobtain the authorisation for decommissioning and the transference of the licence fromthe operator to Enresa.

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DECOMMISSIONING OF JOSÉ CABRERA NPP

Transferof licence

Operator

Operational
licence

Shutdown period
Amendment ofoperational licence

Operation

Transition
periodEnresaLicencetermination

Decommissioning
licence

Return site toownerOperator

EnresaOperator

Hold licence
Maintain records
Remove spent fuel from pools to safe storage
Condition operational waste

Prepare plans for D&D
Provide spent fuel storage
Perform preparatory
activities for D&D

José Cabrera main licensing dates
1963

1969

Construction

2010

2006
Operation

Transition

Decommissioning

Authorisations required for decommissioning and dates for José Cabrera NPP
Competent authority

National

European

Licence

Date

Nuclear Safety Council

Decommissioning authorisationand ownership transference toEnresaFebruary 2010

Nuclear Safety Council
Ministry of the Interior

Physical protection nuclear
material authorisation

February 2010

Ministry of Environment

Environmental impact
statement

December 2009

Local authority

Work licence projectFebruary 2010

European Commission

Data required Art. 37 and 41
Euratom

Ministry ofEnergyJuly 2009

Licensing strategy used•

Amendment to the operating licence for the transition period: included some
preparatory activities for D&D (decontamination of the primary system, radiologicalcharacterisation, discharge of systems, dismantling of conventional components)
and construction of the independent spent fuel storage installation (ISFSI).

•

Before shutdown, draft of licensing documents for decommissioning was
submitted to the Regulatory Authority in 2005 Final version of licensing documents
was submitted in 2008, two years after final shutdown.

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Licensing documents for submittal to regulator (including support documents needed):
Decommissioning authorisation

Ministry of Energy and CSN:•

Safety report, including the following information:– Selected strategy and plan for decommissioning. Facility and site description.
– Description of the radiological initial state and radiological characterisation of
the site. Physical and Radiological inventory.
– Design criteria, safety functions and their associated structures, systems andcomponents.
– Description of facilities, structures and systems needed to carry out thedecommissioning project.
– General decommissioning project and end state. Activities and Plans
description.
– Safety assessment, including the applicable safety and radiological regulations
and criteria, as well as the identification of risks under normal operational andaccident conditions, and preventative measures to be adopted.
– Industrial Risks. Prevention measurements and Emergency measurements.
– Assessment of the Environmental radiological impact and radiologicalmonitoring programme for implementation during the dismantling.
– Organisation and responsibilities,
procedures and quality assurance.

116

qualificationsofpersonnel,

training,•

Technical specifications, for the equipment and systems which were to be kept
operational and which were significant for nuclear safety. The requirements fortechnical specifications of some of the safety system were downgraded to reflect
the risk level of the decommissioning and some specifications were removed.
Systems that were important for radiological protection purposes were regulated
by means of surveillance programmes, which were referenced in this document.
Only technical specification referred to ISFSI remained in this document.

•

Operating Regulations, which included description of the organisation andresponsibilities of personnel involved in the dismantling activities, including thenumber of required operating licences.

•

Quality assurance manual establishing the scope and content of the quality
assurance programme designed for the project.

•

Radiological protection manual, including the organisation, standards and criteria
for radiation protection.

•

On-site emergency plan detailing the organisation and measures planned toaddress potential accident situations during decommissioning.

•

Radioactive waste management and spent fuel management plan, including themanagement criteria and strategy for all radioactive waste generated duringdecommissioning.

•

Plan for material clearance, a specific document to the decommissioning process,which contains the guidelines and methodology for verifying compliance with
criteria for clearance of the materials generated during decommissioning.

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DECOMMISSIONING OF JOSÉ CABRERA NPP•Site restoration plan, a dedicated document that should include the initialradiological site characterisation, the projected final scenario, radiological criteria
for the site release and the methodology for the final radiological survey.

•

Economic study including the cost estimates for the decommissioning project.

CSN:•

Monitoring programmes, ventilation system, fire protection system, other systems–Electrical, Radwaste management, Meteorological and Seismic systems-), Off-Site
Dose Calculation Manual and Environmental Radiological Surveillance Program.

•Environmental impact report (Ministry of Energy and MAGRAMA): Assessment of
conventional environmental impact (non-radiological), monitoring programme
and preventative measures to be implemented during the decommissioning works.
Impacts are: noise, dust, vibration, environmental impact on flora and fauna
caused by dismantling works.

•

EURATOM requirements: Data required by art. 37 and 41. Nuclear Safeguards.

•

Others permits: work licence permit (Town Hall), physical protection authorisation(Ministry of Energy and Ministry of the Interior) and water discharge permit(MAGRAMA).

•

CSN: Nuclear Safety Council, MAGRAMA: Ministry of Agriculture, Food andEnvironment, MI: Ministry of the Interior.

Regulatory oversight during transition period:•

Monitoring activities: 1 On-site inspector (resident inspector), baseline inspection
programme (annual) and specific inspection programme depending on thesignificance of the ongoing activities.

•

Evaluation activities: licensing documents and requirements involved in theauthorisation process.

Public involvement/stakeholder engagements:•

The decommissioning project and the draft environmental impact report are madeavailable to the public before the approval. The public is allowed to comment on
the environmental issues of the project.

•

Environmental authorisation was subjected to public consultation. Scoping was
made by the MAGRAMA with consultation to stakeholders, local, regional andnational authorities.

Decommissioning planning
Main strategies and approaches used
Complete and immediate dismantling to be initiated four years after a shutdown(transition period including the decontamination of the primary system).

Decommissioning scope, start and end point
Complete dismantling of the facility after the removal of the spent fuel from the pool andconditioning of operational waste by the operator. Restricted site release as industrial
scenario.

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Activities were grouped as follows:•

preparatory activities;•

dismantling and decontamination of:– large components;– radiological systems.

•

decontamination and demolition of buildings and structures (pool and biologicalshielding);•site restoration;•

waste management.

Plans were developed to carry out the above activities:•discharging system plan, reduction of risks plan, system modification plan,
conditioning auxiliary facilities plan, disassembly of non-radiological systems plan
(preparatory activities);•

radioactive systems dismantling plan;•large components dismantling plan;•

decontamination of building plan;•

demolition and filling plan;•site restoration plan;•

waste management plan (radwaste, material clearance and hazardous waste).

Licence termination: last licensing action will be the application of the licencetermination.

Defueling and fuel logistics strategy
Construction of an on-site independent spent fuel storage installation (ISFSI). Duringtransition period the spent fuel was removed from the pool, transferred to 12 casks HISTORM 100Z and stored at the ISFSI. During decommissioning, four additional casks for
special waste – similar to the US GTCC class – have been stored next to spent fuel at the
ISFSI.

Waste management strategy
On-site conditioning of LILW and VLLW to be later dispatched to El Cabril Spanish
Repository.
Waste conditioning is based on the results of the characterisation and its compliancewith the acceptance criteria: El Cabril’s Waste Acceptance Criteria, RP-89 and RP-113 forclearance, DCGL for soils at the moment of site release.
Waste minimisation and volume reduction are considered as good practices.

Social/economic impact
An average workforce of 200 professionals during decommissioning, this to be adapted to
the needs of the project.

Business strategy and financial provisions
Decommissioning costs covered by the financial resources of the fund managed by
Enresa (sources for contribution to the fund are regulated).

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Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
Enresa manages the project having taken over the nuclear licence from the operator andhaving its own team/staff on-site.

Enresa(on-site)

Operator

Services
contract

Enresa(head office)Project manager
Quality assurance
OthersRadiological protection/
quality assurance/
operation/maintenanceof systems

Enresa controls key positions of on-site organisation (Site Manager, TechnicalManager, Radiation Protection and Safety Head, Administration head, Quality Assurance
Head, Engineering Head and Communication and Training Head) by having a highly
specialised and limited in number team. The project has intensive support from Enresa
head office.
Enresa set out a services contract with the former operator, under whichapproximately 50 personnel of the former operator continued working. Also, Enresa hires
services as radiation protection, maintenance, waste management, and hires specialist
companies for specialised activities (internals segmentation, decontamination anddemolition works). Personnel who continue working from operation to the dismantlingmust be trained with regard to the new positions and duties.
Decommissioning site organisation is based on a Site Manager and TechnicalManager and some technical services that depend on either. On-site organisationinteracts with the corporate one through the Project Manager who co-ordinates with theTechnical Manager.

Site Manager
Administrationand systems

Training andcommunication

Quality assurance
and environment

Health physics
and safety
Technical
ManagerEngineering

Operation andmaintenanceTechnical
officeExecution

Control andmanagement ofmaterials

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Planning, implementation and project management approach for optimisation
Look D&D as a project. Use project management tools to monitor and control progress ofactivities:•

design of the organisation during decommissioning (organisation chart, functionsof the areas, personnel required, engagement process, etc.);•“implementation plan” with the participation of several departments of Enresa inorder to be prepared to become the licensee of the site;•

preparation of operational procedures;•planning and update of decommissioning schedule and programme;•

use of specialised contractors to implement the dismantling activities.

Experience and knowledge management methods
D&D requires an appropriate combination of experienced workers with operational
memory and new workers with D&D experience. Transfer of key personnel fromoperational staff to decommissioning staff and use of specialised contractors.
To hold Meetings of “lessons learnt” and to perform operational experience reports
To adapt and reuse methodologies developed in previous projects.
To participate in international groups (NEA, IAEA, bilateral, etc.) to share experiences
and benchmarking.

Preparation and training of decommissioning staff
New organisation integrating new competences and operating personnel requires acomplete training programme during transition period. General Training, Occupational
Training (based on-the-job qualification) and retraining programmes.
Besides, an specific training program is continuously being adapted to the progress ofthe decommissioning project.

Projects conducted during transition period
Planning, Engineering and Licensing of Project (O&T), radiological characterisation(O,T&D), conditioning operational waste (T), removal of spent fuel from reactor and pool(T), discharge of systems, equipment and structures not required (T&D), decontaminationof the Primary Circuit (T), Defueling (construction of ISFSI and transfer of 12 casks withspent fuel to ISFSI) (T), personnel training and adapting organisation to D&D (T&D),
modifications existing systems or design of news to support dismantling (D) andconstruction/renovation of auxiliary facilities and preparation of work areas (D).
O: Operation Period; T: Transition Period and D.: Decommissioning Period

Initial site characterisation
Six campaigns for radiological characterisation were carried out covering both operation,transition and decommissioning stages.
Radiological results and applications:120•

radiological inventory;•

dismantling activities;•

radiological impact;
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DECOMMISSIONING OF JOSÉ CABRERA NPP•

parameters for final survey;•

assessment residual activity.

System and building decontaminations
Chemical decontamination of the primary system.

Lessons learnt
Positive:•start planning and preparation of D&D already under the last years of operation.

•

co-operation with the operator facilitates the transition to the D&D;•

fluid and transparent communication with the authorities may shorten approvaltimes;•

new challenges must be addressed (relocation and integration of personnel,
knowledge retain and transference);•

radiological characterisation “prior” and “during” the transition period is a key
element for planning the decommissioning project.

Negative:•

regulations on decommissioning have to be adapted to the risks duringdecommissioning;•plant records and as-built documentation are generally not complete;•

old incidents are usually not well reported.

References
Correa, C. (2016), “Decommissioning Licensing Process of Nuclear Installations in Spain”,
PREDEC 2016, 16-18 February 2016, Lyon, France.
Ondaro, M. and Correa, C. (2013), “Marco normativo y licenciamiento
desmantelamiento. La visión del titular”, Revista Radioprotección nº 76, Vol. XX.

delRodríguez, M. (2012), “Organizational and contractual approach: Decommissioning of José
Cabrera NPP”, SNF Meeting, December 2012.
Santiago, J.L., Martín, N. and Correa, C. (2013) “Marco general y bases de losdesmantelamientos de las instalaciones de las instalaciones nucleares”, Revista
Radioprotección nº 76, Vol. XX.

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Annex A.9. United States – Case study 1:
Connecticut Yankee NPP decommissioning

Reference: Guidance for Transition from an Operational to Decommissioning Status for
Nuclear Power Plants (2016) EPRI # 3002007551, 3412 Hillview Avenue, Palo Alto California,
94304.

Background
Decommissioning strategy:
Prompt Dismantlement

Schedule:
December 1996 to November 2007

Actual status:
Final plant shutdown in December 1996. Transition activities took approximately three years tocomplete. Plant site released from NRC licence in a greenfield state except for a small dry fuelstorage facility (1 hectare).

Experience in transition from operations to decommissioning in other projects:
Shutdown was unexpected and premature and so no planning for decommissioning had been
done. This delayed the start of active decommissioning.

Decommissioning preparatory activities
Summary
Table below shows major decommissioning activities including regulatory submittals.
Other major tasks during transition period are shown in Section 2.4.

PeriodOperation

Transition period

Dates

Key event22 July 1996

Last day of power operations

15 November 1996

Defueling complete

4 December 1996

Decision to permanently cease operations

5 December 1996

Shutdown announced/defueled certification to NRC

January 1997 to July 1998

Initial decommissioning planning/site scoping survey

May 1997 to July 1998

Improved health physics programme development

August 1997

PSDAR submitted

Late 1997

Decommissioning public meeting

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PeriodDecommissioning
periodDates

Key event

Late 1997 to late 1999

Initial site characterisation and historical site assessment

1998-1999

Bulk asbestos insulation removal

January 1998

DSAR submitted

May 1998 to September 1998

Full system chemical decontamination

June 1998

Operating licence amended to reflect permanent shutdown

1998

Fuel building upgrade complete

April 1999 to July 2003

Subcontracted to decommissioning operations contractor

October 1999

Operating licence amended to reflect decommissioning

Late 1999

Steam generator and pressuriser removals

March 2000 to August 2002

Reactor vessel internals segmentation project

July 2000

Licence termination plan submitted

November 2000

Site characterisation report submitted to NRC

November 2003

Licence termination plan approved

July 2003 to January 2004

Reactor pressure vessel package preparation and shipment

April 2004 to March 2005

Transfer fuel and GTCC to ISFSI pad

September 2004 to July 2006

Major building demolition

December 2005

Subsurface soil remediation complete

December 2005 to January 2007

18-month groundwater monitoring period for NRC

March 2007

Final status survey/physical work complete

November 2007

NRC licence terminated for all non-ISFSI areas

Regulatory framework
Regulator/types of licences required
NRC is lead regulator for radiological site release but state authorities can be more
restrictive. The US Environmental Protection Agency or state agency oversees nonradiological site release.
No decommissioning licence but other submittals that must be submitted and/or
approved by NRC:•

PSDAR – High-level description of the decommissioning – No NRC approval needed.

Major revisions or new documents which require NRC approval:

124•

safety analysis report – decommissioning accidents and new plant design basis;•

technical specifications;•emergency plan;•

security plan;•

spent fuel management plan;•licence termination plan – basis for radiological release of the site and funding
adequacy.
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Licensing strategy used
Prepare licensing documents as quickly as possible by using personnel with experienceduring other power plant decommissioning.

Regulatory oversight during transition period
On-site resident NRC inspector until shortly after final shutdown. Then periodic visits forinspections. Periodic visits by State regulators.

Public involvement/stakeholder engagements
Established a Community Decommissioning Activities Council consisting of local
community stakeholders and held frequent meetings.

Decommissioning planning
Main strategies and approaches used
Minimise cost by completing decommissioning as quickly as possible. Created a Spent
Fuel Pool Island so that other dismantle work could be conducted while the fuel was stillin the fuel pool.

Decommissioning scope, start and end point
Dismantle and decontaminated site to a greenfield state.

Defueling and fuel logistics strategy
Fuel Building modified to be a Spent Fuel Island. Fuel moved to dry storage as soon as
decay allowed meeting of dry fuel storage canister heat load limits. No repository or offsite storage currently available.

Waste management strategy
Waste disposal sites available so waste was shipped off-site as quickly as possible. Ripand ship of contaminated systems and structures. Little decontamination of equipment
or above ground structures performed. One piece disposal of reactor vessel at Barnwellsite accomplished.

Social/economic impact
Significant economic impact of community. Loss of jobs and property tax revenue.

Business strategy and financial provisions
Minimise cost by completing the decommissioning as quickly as possible.

Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
As this was a single power plant utility, all of the decommissioning organisation wason-site. Primary departments were: Decommissioning Project, Radiation Protection,
Oversight, Finance, Industrial Safety, Security.

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Planning, implementation and project management approach for optimisation
Use detailed schedule and Earned Value Management System to control cost andschedule.

Experience and knowledge management methods
Hire experienced persons for key management and staff positions. Retain key employees.
Conduct exit interviews as long-term employees leave the site.

Preparation and training of decommissioning staff
Utilise staff with experience at other sites to mentor retained operating plant staff and/or
benchmark/compare notes with other decommissioning plants.

Projects conducted during transition period
Initial site characterisation
A historical site assessment (HSA) was developed to serve as a basis for the initial sitecharacterisation. The HSA development effort took about four (4) person-years tocomplete. It is very important to perform this assessment early in decommissioning todirect characterisation efforts and to help determine how certain aspects of thedecontamination should be conducted. The initial characterisation effort began in late1997 and was completed in late 1999. The initial characterisation was performed to theguidelines of MARSSIM.

System and building decontaminations•

A full system decontamination was conducted during the transition period.
Systems included in the decontamination include the reactor coolant system (RCS),
Chemical and Volume Control System, Residual Heat Removal System and RCS fill
and drain system. The internal surfaces of the Reactor Pressure Vessel and about
85-90% of the Steam Generator tubing were not included in the decontamination.

•

Little decontamination was done to above ground Radiological Control Area
structures as they were totally demolished and all debris shipped as radioactive
waste.

Asset management
Unknown by typically little sale of plant items due to contamination.

Cold and dark
Establishing “cold and dark” conditions refers to de-energising, depressurising, anddraining all systems of the plant that are no longer needed for decommissioning. These
activities were conducted during the Connecticut Yankee transition period.
Experiences at previous decommissioning sites with establishment of cold and dark
conditions indicated that immediate shutdown of all plant systems could lead toproblems. For example, shutdown of all plant systems led to condensation insidecontainment at a different plant, which resulted in unsafe work conditions. To reduce thepotential for such issues, Connecticut Yankee repowered certain systems that wereneeded for decommissioning. This included repowering the heating, ventilation and air
conditioning (HVAC) systems. To supply power to these systems, a new power source
was brought to the plant. Bright orange striped cabling was used to help identify whichpower cabling was energised.

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Emergency powerNo emergency power after early portion of the transition period. Power for site activities
provided by standard “Street power”.

Disposition of operational waste
Disposal sites available. Waste shipped to these sites as they had been during plant
operation.

Technology and technical requirements – preparations for dismantlement projects
Preparations for projects such as large components shipments and reactor vesselinternals segmentation begun during transition period.

Asbestos removal
Approximately 500 000 lbs of asbestos were removed during the Connecticut Yankee
decommissioning. A large portion of this removal occurred during the transition period. It
is beneficial to conduct asbestos removal early in decommissioning because asbestos
removal generally requires the use of enclosures.

Hot spot reduction
Hot spot reduction consists of identification and subsequent removal of components orparts of components with high dose rates. Like full system chemical decontamination, it
is beneficial to conduct hot spot reduction early during decommissioning to maximise
dose savings from later decommissioning activities. Hot spots were identified and, where
possible, removed during the transition period after the decontamination application.
However, many hot spots were located in components/systems required to maintain thereactor cavity water boundary. These hot spots could not be removed until many othercomponents had been removed, including the reactor vessel internals.

Lessons learnt
Positive results
Transition activities after permanent shutdown:•

The human resource issues related to the shutdown of a nuclear plant need to beaddressed immediately after the decision has been made to permanently shut
down a plant. This will help to avoid personnel errors and injuries that could
result from distracted workers.

•

A plan needs to be developed to retain key employees that have the institutional
knowledge of the plant needed during the decommissioning. Additionally, thedecommissioning
organisation
needs
to
bring
in
individuals
withdecommissioning experience.

•

The transition period is the most efficient time to perform early decommissioning
projects such as Asbestos Abatement and Full System Chemical Decontamination.

•

It is critical to prepare the historical site assessment for the facility at this time if it
has not already been prepared.

•

It is advised that the chemical decontamination be conducted shortly after the last
shutdown while maintenance schedules have continued to be followed on
equipment to be utilised and experienced operations personnel are still present

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on-site. This early application also maximises the benefit of the chemical
decontamination.
•

The ratio of alpha radionuclides to the beta and gamma radionuclides in thecontamination at a plant can greatly increase the complexity and cost ofcontrolling exposures during a decommissioning.

Difficult challenges
Preplanning for decommissioning (before permanent shutdown):

128•

Many of the planning activities for the decommissioning of a plant can be
conducted well in advance of the actual permanent shutdown. The high-levelstrategy for the decommissioning should begin when the possibility ofdecommissioning is being considered.

•

Maintain a comprehensive historical site assessment (10 CRF 50.75 [g]) file ofcontamination events during operation. This will facilitate planning once thedecommissioning is scheduled.

•

Once the permanent shutdown is scheduled, the detailed planning, engineeringand early project specifications should begin in earnest approximately one year
before permanent shutdown. This will avoid the delays in beginning
dismantlement activities that was experienced at Connecticut Yankee.

•

Perform high-level strategic planning for the major decommissioning projects
such as reactor internal/vessel segmentation and full system decontamination.
This will avoid a delay in beginning the decommissioning activities at the start ofthe decommissioning.

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Annex A.10. United States – Case study 2:
Vermont Yankee NPP decommissioning

Reference
Guidance for Transition from an Operational to Decommissioning Status for Nuclear
Power Plants (2016) EPRI # 3002007551, 3412 Hillview Avenue, Palo Alto California, 94304.

Background
Decommissioning strategy:
Safe Storage then Decom

Schedule:
Complete by December 2074

Actual status:
Final Plant Shutdown in December 2014. Transition activities are essentially complete. Aftertransition, plant will be in safe storage status until sufficient decommissioning funds arecollected to complete the decommissioning but decommissioning will be completed no later than
60 years after the final shutdown date per NRC regulations. Spent fuel transfer to dry fuel storage
will be completed by the end of 2018. Sale of the plant to the Northstar partnership has been
proposed and is pending regulator approval. Under this proposed sale, dismantlement would
begin after completion of fuel transfer and be completed within 10 years of closing the sale.

Experience in transition from operations to decommissioning in other projects:
Site knew the permanent shutdown date 16 months prior to the actual final shutdown. This
allowed many transition activates to be completed prior to the final shutdown and reduced thepost-shutdown transition period to only 16 months. Plant is positioned to move into active
decommissioning when sufficient funding is achieved or the proposed sale is finalised.

Decommissioning preparatory activities
Summary
Table in Section A.7.2.1 below shows all of the regulatory submittals made by Vermont
Yankee. Much of the preparatory activities that have been done to date are thepreparation of these submittals.
Additional preparations for safe storage period:•

expansion of the dry fuel storage facility to accept all the fuel by the end of 2018;•

developed a plan for human resources for entire decommissioning;•established a nuclear decommissioning community advisory panel.

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Regulatory framework
Regulator/types of licences required
NRC is lead regulator for radiological site release but state authorities can be more
restrictive. The US Environmental Protection Agency or state agency oversees nonradiological site release.
No decommissioning licence, but other submittals that must be submitted and/or
approved by the NRC:•

Post-shutdown decommissioning activities report (PSDAR) – High-level description
decommissioning – No NRC approval needed.

Major revisions or new documents which require the NRC approval:•safety analysis report – decommissioning accidents and new plant design basis;•

technical specifications (TS);•emergency plan;•

security plan;•

spent fuel management plan (SFMP);•

licence termination plan – Basis for radiological release of the site and funding
adequacy.

Licensing strategy used
Prepare and submit many licensing documents prior to final shutdown to minimise
length of post-shutdown transition period.

Licensing documents for submittal to regulator (including support documents needed)

130

Regulatory submittals

Date submitted

Date approved

Certification of permanent shutdown

September 2013

Not applicable

Security exemption – suspension of security
during an emergency or severe weather

October 2013

February 2015

Request for approval of certified fuel handler
training programme

October 2013

October 2014

TS amendment request – admin controls section

October 2013

December 2014

TS amendment – remove certain engineered
safeguard features during fuel management

November 2013

February 2015

Cyber security milestone 8 – implementation
date extension

December 2013

November 2014

Emergency plan exemption request

March 2014

December 2015

TS amendment permanently defueled (PDTS)

March 2014

October 2015

On-site insurance exemption request

April 2014

Not applicableOff-site insurance exemption request

April 2014

Not applicable

Permanently defueled emergency plan (PDEP)

June 2014

December 2015

Vermont Yankee quality assurance programmemanualOctober 2014

Not applicable

Post-shutdown activity report

December 2014

Not applicable

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Site-specific decommissioning cost estimate(DCE)

December 2014

Not applicable

Integrated fuel management plan (IFMP)

December 2014

October 2015

Request to cancel lines of credit

December 2014

April 2015

Request to cancel parental company agreement

December 2014

April 2015

Certification of permanent removal of fuelJanuary 2015

Not applicable

Trust fund exemption request

January 2015

June 2015

Security plan revision

April 2015

Not available

February 2015

December 2015

Permanent shutdown: December 2014

Records retention requirement exemption

Decommissioning planning
Main strategies and approaches used
Plant to be place into safe storage condition until sufficient decommissioning funds areavailable or sale of plant currently being proposed.

Decommissioning scope, start and end point
After up to a 50-year safe storage period, the plant will be dismantled anddecontaminated and the buildings demolished to a greenfield state.

Defueling and fuel logistics strategy
Spent fuel will be moved to a dry fuel storage facility by the end of 2018. No repository or
off-site storage currently available for spent nuclear fuel.

Waste management strategy
Disposal site access is currently available.

Social/economic impact
Significant economic impact of community. Loss of jobs and property tax revenue.

Business strategy and financial provisions
As plant was shut down prematurely, the decommissioning fund was not fully funded.
Strategy is to delay D&D until sufficient funds have accumulated through investment of
the decommissioning fund. Strategy will be changed if proposed sale of plant is finalised.

Decommissioning organisation and staffing
Corporate and decommissioning site organisations and interactions
Most of the decommissioning organisation is on-site with some support from corporate
organisations. Primary departments are: decommissioning project, dry fuel storage,
radiation protection, oversight, finance and industrial safety.

Planning, implementation and project management approach for optimisation
Use detailed schedule and Earned Value Management System to control cost andschedule.
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Experience and knowledge management methods
Retain key employees, Conduct exit interviews as long-term employees leave the site.

Preparation and training of decommissioning staff
Utilise staff with experience at other sites to mentor retained operating plant staff and/or
benchmark/compare notes with other decommissioning plants.

Projects conducted during transition period
Initial site characterisation
Perform a site assessment study which is a comprehensive summary of the current
environmental and radiological conditions of the site and to document the plans toterminate the plant licence.

System and building decontaminations
As of May 2015, seven structures had been dismantled at the plant site. These structures
were dismantled to improve the security plan.
One interim waste storage pad has also been dismantled.

Asset management
Targeted asset recovery actions to reduce spares inventory systems that have beenabandoned. Outsources asset recovery to a speciality auction firm.

Cold and dark
By May of 2015, 24 out of 50 systems had been drained and put into layup and an
additional 11 were systems scheduled to be drained and put into layup by the end of 2015.
Expected to complete cold and dark conditions by the end of April 2016. Unlike theactivities to establish cold and dark conditions at several other plants, temporary powersource will not be installed at the plant to repower the plant systems until the end of thesafe storage period.

Emergency power
Install a new larger capacity diesel generator to replace the old diesel generator.

Disposition of operational waste
Disposal sites available. Waste shipped to these sites as they have been during plant
operation.

Technology and technical requirements – Preparations for dismantlement projects
As most D&D will be done after 50 years, little preparations are made other than to movespent fuel to dry storage. If the proposed sale is finalised, the new licensee will perform
preparatory activities.

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Lessons learnt
Positive results
The decision to permanently shut down Vermont Yankee was made 16 months before
the actual date of permanent shutdown. During these 16 months, many regulatory
submittals were prepared and submitted to the NRC. Early submittal of these documents
is expected to have significantly reduced the duration of the transition to SAFSTOR (withwet fuel storage). The schedule in the PSDAR indicates that the duration from permanent
shutdown to SAFSTOR status will only take ~16 months. Further, early submittal of these
documents has helped minimise the duration to implement cost saving measures(e.g. implementation of reduced emergency plan requirements).
The emergency plan exemption and the permanently defueled emergency plan were
submitted to the NRC together (as two separate enclosures to a single transmittal letter).
This is expected to be a best practice to help ensure that the documents are consistent
with each other and to help minimise the duration of the NRC review.

Difficult challenges
State of Vermont intervention in virtually every licensing action has resulted in several
Atomic Safety Licensing Boards (ASLBs) with associated costs and uncertainties. NRC
staff has consistently granted exemptions in requested time frames, but ASLB
proceedings may continue for up to one year after licensing action is approved by staff.

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Annex B. Contracting methods

Decommissioning activities are often contracted to the supply chain. Depending on theindustrial strategy, the owner/licensee might choose one of the following contracting
models:•fixed-price (lump sum) contracts;•

time and material contract;•cost-plus-fixed fee contracts;•

target cost-plus-incentive-fee;•target cost-plus-incentive-fee with shared savings.

The IAEA report “Financial Aspects of Decommissioning” (IAEA 2005) provides
descriptions of these contracting models. For decommissioning fixed-price (lump sum)contracts is one of the preferred options in some NEA member country, such as France.
This fixed-price (lump sum) model of contracting assumes that the contracts should
be based on a set of essentially functional specifications, defining the expected functional
requirements in terms of safety, security, radiation protection, environment, waste,
process, performance etc., to allow the supplier to have enough initiative margin. In thisarrangement, the reference scenario is therefore not a requirement of the specification. It
is provided in the call for tender file as a possible scenario which is judged by thecontracting authority as meeting the functional requirements specifications. The
candidates have an opportunity to make an offer based on this scenario and / or an offer
based on a variant or alternative scenario they consider also meeting the functional
requirements specifications. The technical assessment of bids by the contracting
authority is on the fulfilment of functional requirements and not the judgement ofdeviations from the reference solution.
During the contract, the monitoring by the contracting authority only concerns therespects of the requirements of the specifications and on the regulatory requirements,
not on the details of implementation, which remains the full responsibility of supplier.
Although this model of contracting is the preferred solution for dismantlingoperations, the choice should be made only after ensuring:•That there available an industrial panel that agrees to be involved. In particular,
the preparation of an offer in such an arrangement requires a strong investment
studies. The simplicity and reliability of input data actually could transfer the
majority of risks to the provider. Complex input data and unreliable (typecalculated radiological inventories) leave in fact an important part of risk on the
project owner which, if it becomes dominant, makes this type of contract lessinteresting.

•Compatibility with the elements mentioned in the public inquiry.

•

Consistency with the regulatory requirements.

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CONTRACTING METHODS

Depending on the size or the nature of the operation to be performed, several
variations of this contract model can be implemented at the early stage of the buying
process.
This type of contract has some disadvantages, such as:•

The major drawback is to transfer a maximum of risks to contractor, which in theprinciple of fixed price, requires them to make provision in their offer, more or less,to cover these risks and, ultimately leads to potential claims.

•

It requires a strong investment in design studies for call tender submission, andcould lead the owner/licensee to pay the offers (if they are technically acceptable).

•

Alliances are necessary to cover all specialties with the risk to put in minority
small firms towards large groups.

Difficulties for assessing the target price from a functional specification and subject toclaims from the contractor in most of the cases.

Reference
IAEA (2005), Financial Aspects of Decommissioning, IAEA-TECDOC-1476, IAEA, Vienna.

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COMPARISON OF REQUIREMENTS FOR THE REGULATORY FRAMEWORK AND AUTHORISATION PROCESS FOR DECOMMISSIONING

Annex C. Comparison of requirements for the regulatory framework
and authorisation process for decommissioningin various NEA member countries

During its activities, the Task Group on Preparing for Decommissioning during Operation
and after Final Shutdown (TGPFD) has carried out a survey among its members to collectinformation on national requirements, preparatory activities and responsibilities duringtransition from operation to decommissioning. It was determined that the requirements
for maintaining an organisation and manage the changes are contained in the specificstate regulatory regime (framework).
The responses from Canada, France, Germany, Japan, Korea, Spain, Sweden,
Switzerland, the United Kingdom and the United States are provided in this annex in acomparative way starting with a summary of the conclusions and detail responses
afterward.

C1. Summary of conclusions
Regulatory framework for decommissioning
All NEA participating countries reported to have an established regulatory framework fordecommissioning.

Requirements for decommissioning authorisation
In all NEA member countries a licence to decommission or some kind of approval isrequired prior to decommissioning.
In most countries, more than one regulatory authority is responsible for the approvalof decommissioning. The regulatory body and environmental authorities have a key role
while the regional, local authorities and other stakeholders might be involved at different
stages of approval process.

Preparatory activities under operation licence
Most of participating countries allow preparatory activities, reducing the hazards andpreparing the facility for transition to decommissioning, to be conducted prior toauthorising decommissioning. In most countries, those activities are performed under
the operation licence and procedures and include: unloading of fuel assemblies,
managing
radioactive
waste
from
operation,
radiologicalcharacterisation,
decontamination of the facility and systems.

Responsibility for decommissioning
In most participating countries, the operator is responsible for conducting
decommissioning. In Spain, the responsibility and the licence is transferred to a
decommissioning organisation. In United States and Sweden, the responsibility could betransferred to a third, contracting party.

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Licence documentation submitted for decommissioning
In most participating countries, similar information is required by the regulatory
authorities in support of application for decommissioning. The submitted documentation
may vary by title or structure but should provide information on decommissioning
strategy, schedule, scope, project description and risk analysis for the decommissioning
project.
Decommissioning plan and safety assessment report are the key documents required
prior to decommissioning.
Additional information in relation to organisation, radiation protection, radiologicalcharacterisation, decommissioning technical specifications, material and waste
management, emergency measurements, cost estimation, final survey plan and public
information is also commonly required.

Timeframes relating to decommissioning authorisation process
No particular time frame has been established for transition to decommissioning. In mostcountries “the transition period” is considered from cessation of operation to obtaining
an authorisation to decommission.
Most participating countries, with the exception of France, reported not to havestrictly established timelines for documentation submissions and authorisation of
decommissioning. The timelines are established on a case-by-case basis and triggered
mainly by achieving a milestone activity rather than specifying the time. The decision to
shut down and shutting down the facility defines most of the timelines. Some countries,
e.g. France and South Korea, are more time prescriptive than another.

Initial decommissioning plan (IDP)
In all participating countries, with the exception of United States, an initial
decommissioning plan (IDP) is required. The scope and the requirements for maintaining
and updating the IDP vary from country to country. In most countries the IDP should bemaintained through the life cycle of the facility.

C.2. Information from comparison of the regulatory framework and authorisation
process for decommissioning
Regulatory framework for decommissioning
All countries have reported to have an established regulatory framework fordecommissioning.

Requirement of a decommissioning authorisation
CanadaA decommissioning licence is required.

FranceA decommissioning licence is required.

Germany
A decommissioning licence is required.

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COMPARISON OF REQUIREMENTS FOR THE REGULATORY FRAMEWORK AND AUTHORISATION PROCESS FOR DECOMMISSIONINGJapan
No decommissioning licence is required. But a decommissioning plan has to be approved
and the confirmation of decommissioning completion is required at the final stage ofdecommissioning.

Korea
No decommissioning licence is required, but a decommissioning plan has to be approved
before the start of decommissioning. Decommissioning is under the effective operating
licence.

Spain
A decommissioning licence is required.

SwedenA licence according to the Environmental Code is required. A specific decommissioning
licence is not required according to the Act on Nuclear Activities, but approval of certain
documents by the Swedish Radiation Safety Authority (SSM) is needed.

Switzerland
A decommissioning licence is required as the operation licence expires.

United Kingdom
No decommissioning licence required.

United States
No specific decommissioning licence is required. Decommissioning is performed under
the plant operating licence (more information can be found below in the section“Decommissioning activities under the operating licence”). The NRC is working on arevision to these regulations.
In the United States, some decommissioning activities can begin without regulatory
approval as long as the SSCs involved do not involve documents for which changes
require regulator’s approval, such as technical specifications for nuclear safety-related
systems. In these cases the basis for the downgrading of the nuclear safety-related
system would need to be supported by documentation and the changes approved by theregulator before the system could be declared available for dismantlement(i.e. abandoned).

Licence documentation submitted for decommissioning
CanadaApplication for a decommissioning licence including detailed decommissioning plan
supported by documentation covering 14 Safety and Control Areas (SCA):•

management system, human performance management, Operating performance;•

safety analysis, physical design;•

environmental protection;•

radiation protection;•

conventional health and safety;

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fitness for service, packaging and transport, waste management;•

security, safeguards and non-proliferation;•

emergency management and fire protection.

Additional areas as:•

environmental assessment;•

CNSC consultation – Aboriginal, CNSC consultation – other;•cost recovery, Financial guarantees;•

improvement plans and significant future activities;•

licensee public information programme;•

nuclear liability insurance is also assessed.

FranceThe dismantling licence decree requests a documentation to be submitted that includes:•

description of the initial status of the plan before dismantling operations starts;•

update of the dismantling plan (milestones, hold points if any, structures and soils
decontamination strategy, future use of the site);•environmental impact study including waste management policy;•

plant safety analysis report (PSAR);•

risks analysis;•

non-technical summary for the purpose of public enquiry;•

notice describing the operator financial capacities.

Germany
A letter of application for a decommissioning licence needs to be submitted along withthe following documents:

140•

safety report;•

supplementary plans, drawings and descriptions of the facility and the planned
decommissioning techniques and procedures;•

report on physical protection;•

reliability and technical qualification of plant personnel;•

know-how and reliability of other personnel;•

list of measures relevant for safety;•

financial security measures;•radioactive residues;•

overriding public interests, environmental impact;•

documents for environmental impact assessment;•

brief description;•

list of documents submitted;
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adaptation of operating manual and testing manual;•details of licensing decisions, conditions and permits to be suspended or modified;•

documents required by building regulations;•documents required by the Federal Immission Control Act;•

documents relating to water rights.

Japan
After shutdown, the decommissioning plan has to be submitted that includes:•

facility to be dismantled;•

dismantling method;•management or transfer of nuclear fuel materials;•

removal of contamination by nuclear fuel materials;•

disposal of nuclear fuel materials or materials contaminated by nuclear fuelmaterials;•

decommissioning schedule;•

radiation control, safety assessment and systems;•

final stage of decommissioning:

At a final stage of decommissioning, a document has to be submitted describing
status implementation of:•

dismantling;•transfer of nuclear fuel material;•

removal of contamination with nuclear materials;•

management of materials contaminated with nuclear fuel material and the final
distribution of contamination with nuclear materials.

Korea
•

construction permit and operating licence stage: IDP;•

during the operation period: IDP shall be updated every ten years;•

for decommissioning approval:– final decommissioning plan (FDP);– quality assurance programme (QAP) for decommissioning;– public consultation records.

Spain
Letter of application decommissioning licence including the decommissioning plan
supported by:•safety analysis;•

operating regulations;•

technical specifications applicable during the dismantling phase;

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quality assurance manual;•radiological protection manual;•on-site emergency plan;•management plan for radioactive waste and spent fuel;•site restoration plan;•

economic study of the dismantling process and its associated financial provisions;•plan for the control of clearable materials;•

physical protection plan;•

environmental analysis.

Sweden•Application to the Land and Environmental Court with environmental impact
assessment.

•

To the Radiation Safety Authority:– Analysis and assessment of how safety is to be maintained during the timeremaining until closure, changes in organisation during the closure period andpersonnel requirements during decommissioning.
– Updated decommissioning plan with description of which parts of the facility
and which equipment will be required during decommissioning as well as
which preparatory actions will need to be undertaken before dismantling anddemolition can commence.
– Updated safety analysis report in accordance with the revised decommissioning
plan.

Switzerland

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decommissioning project;•phases and timetable for decommissioning work, decommissioning variants;•

individual step for decommissioning work;•

updated safety analysis report;•

procedure for separating radioactive and non-radioactive waste and radioactive
waste management;•

radiological protection measures;•

security measures;•

accident analysis and emergency measures;•

human and organisational factors;•

management system;•

environmental impact report;•

total cost and securing of the financing.

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United Kingdom
Decommissioning plan and safety case are required to meet with the nuclear site licenceconditions.

United States
No decommissioning plan, the post-shutdown decommissioning activities report (PSDAR)
and licence termination plan have to be submitted.
Other major documents submitted are listed below under the section “Requirements
for initial decommissioning plan and its orientation”.

Timeframes relating to decommissioning authorisation process
CanadaNo specific timeline is established for submission of decommissioning licence application.
Recommended to start discussion with CNSC as early as possible.

France•Operator informs the Ministry in charge of the Nuclear Safety (currently
Sustainable Development and Energy Ministry) of the date of final shutdown – Twoyears before final shutdown.

•

Within two years after the letter announcing final shutdown, operator must
submit the request for dismantling licence decree.

•

Within three years after issuing the request for dismantling licence decree the
Ministry in charge of the nuclear safety must have completed the review of thedismantling plan.

•

The French Nuclear Safety Authority would accept a delay of 6 to 12 months to put
in force the dismantling licence decree.

•Conclusion: Transition period duration would be at least three to four years.

Note: it might be possible for the operator to ask an extension of the two years delay
for submitting the request for dismantling licence decree (this extension is anyway
limited to two years).

Germany
Not established. Shutdown of nuclear power plants required by political decision.

Japan
After permanent shutdown and prior to start of decommissioning work. Plan is to berevised as progress is made. Operational safety programme can also be changed asprogress is made.

Korea
•

Construction permit and operating licence stage: IDP shall be submitted to theregulatory body as one of application documents.

•

During the operation period: IDP shall be updated every ten years.

•

Approval of decommissioning: in case of NPP, the licensee shall apply for theapproval of decommissioning within five years after the permanent shutdown.

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Spain
Case by case, but is planned to establish two years after shutdown.

Sweden•To Environmental Court: no established time but licence is required prior todecommissioning.

•

To Radiation Safety Authority:– First rapport on changes in organisation shall be submitted without delay after
a decision on final shutdown.
– Within a year of final shutdown the updated decommissioning plan and safety
analysis report shall be submitted.
– Rapport according to Euratom Art. 37 shall be submitted at least one year
previous dismantling.
– A further developed decommissioning plan and updated safety analysis reportshall be submitted before dismantling may be initiated. Where thedecommissioning plan is divided up into a series of smaller work sequences orpartial projects, a review of the planned measures during each sequence shallbe communicated before these activities commence.

Switzerland
Case by case, but at the latest two years after final shutdown.

United Kingdom
The final decommissioning plan should be available before decommissioning starts. The
safety case needs to be submitted before the start of decommissioning operations.

United States•

Licensee shall within 30 days after the decision to permanently shut down theplant, submit to the NRC a written certification of completing the defueling andthe permanent cessation of operation of the reactor.

•

PSDAR must be submitted within two years of Certification of Permanent Closure.

•

Licence termination plan must be submitted at least two years before licencetermination.

•

Other submittals are listed below in the section “Requirements for initial
decommissioning plan and its orientation”.

Decommissioning activities under the operating licence
CanadaSome preparatory activities are in place as long as they do not deviate from theoperational licence conditions and the safety case. For example removal of the fuel,draining the systems, transfer of waste, preliminary surveys could be allowed under theoperational licence since many of those activities are routinely performed during theoperation of the facility and the necessary safety and procedure documents are in place.

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COMPARISON OF REQUIREMENTS FOR THE REGULATORY FRAMEWORK AND AUTHORISATION PROCESS FOR DECOMMISSIONINGFranceNo dismantling activity is authorised before the dismantling licence decree is put in force,but preparatory activities aiming to reduce the risks or contributing to the preparation of
the dismantling phase allowed such as:•fuel removal from site;•waste characterisation;•

nuclear circuits decontamination;•

shut down of unnecessary systems;•

dismantling of equipment in turbine hall;•

preparation of workshop for waste treatment (but forbidden to put them inoperation);•hazardous fluids or materials removal from site;•

only very few equipment could be dismantled.

Most of these operations will be subject to the French Nuclear Safety Authority
information or authorisation.

Germany
Only preparatory activities, which are covered by the operating licence:•

Unloading of fuel assemblies, handling of radioactive substances and disposal ofradioactive waste from the operational phase, replacement of systems andcomponents, decontamination of the facility and systems.

•

Radiological characterisation is necessary for the decommissioning licenceapplication and thus allowed including sampling.

Japan
Removal of spent fuel from reactor core is performed during operational phase.
No decommissioning work can be performed until the decommissioning plan isapproved.

Korea
Yes.

Spain
•

no decommissioning activities;•

preparatory activities:– spent fuel removal;– radiological characterisation, preparation of decommissioning plan andlicensing;– documentation;– conditioning of radioactive waste from the operational phase;– decontamination of system.

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SwedenNo decommissioning activities.
Preparatory works covered by the operating license (unloading of fuel assemblies,
handling of radioactive substances and disposal of radioactive waste from theoperational phase, replacement of systems and components, decontamination of the
facility and systems, etc.).

Switzerland
Only preparatory activities:•

Measures to transfer the facility into transition phase (unloading of fuelassemblies, handling of radioactive substances and disposal of radioactive waste
arising from the operation, radiological characterisation, decontamination of the
facility and systems).

•

Some particular preparatory works on extra application
decommissioning and supply facilities, unload turbine hall, etc.).

(installationof

United Kingdom
No. Decommissioning is regulated via the nuclear site licence conditions, which cover all
stages of the life cycle. Under license conditions the licensee must seek agreement fromthe safety regulator to start decommissioning. Further agreements may be required forlater decommissioning stages. The operator also needs to submit an environmental
impact assessment to the safety regulators (Office for Nuclear Regulation) which issues
consent. The safety regulators ask for comments from various stakeholders including theenvironmental regulators.

United States
Yes. All decommissioning performed under the operational licence. If storing spent fuelon-site, the operational licence can be amended to include only the ISFSI and theremainder of the site is released from the licence or the ISFSI can be licensed under a
new NRC 10 CFR Part 72 licence and the operational licence terminated.

Requirements for initial decommissioning plan and its orientation
CanadaYes. Planning for decommissioning and financial guarantees are required throughout thelife cycle of the facility for site, construction, operation and decommissioning licences.

FranceYes. Together with the letter informing the Ministry in charge of the Nuclear Safety thatthe plant will be definitively shut down, the operator sends an update of the dismantlingplan. This update describes:

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the operations that will be conducted before the dismantling decree is put in force;•the equipment that will be necessary for the dismantling activities (existing or
new equipment);•

anticipated waste routes;•

operator organisation during transition period and dismantling period.

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Germany
Yes. Initial plan demonstrating the feasibility of decommissioning in accordance with theradiation protection requirements and periodic review generally specified in operating
licence.

Japan
Yes. Plan to be revised and resubmitted for review as decommissioning progress is made.
Application for confirmation of decontamination completion is to be submitted forreview and approval prior to completion of decommissioning.

Korea
Yes. IDP shall be required at the construction permit and operating licence application
stage of NPP. And IDP shall be updated every ten years during the operating period.

Spain
Yes, but only for forecast purposes:•

construction licence: technological, cost estimation and funding aspects ofdecommissioning;•

operation licence: waste management, cost estimation and funding aspects ofdecommissioning (financial guarantees required).

SwedenYes.
•a preliminary plan for the future decommissioning of the facility is to be compiled
before construction of a facility;•

safety and radiation protection at the time of decommissioning shall be taken into
account during the construction of a facility and before changes are made in anexisting facility;•

the preliminary plan shall be supplemented and kept up to date for the duration of
the facility’s operation and shall be reported to the regulatory authority every ten
years;•

during the operation of a facility, observations and events that have significancefor planning and execution of decommissioning shall be documented on an
ongoing basis.

The information to be contained in the decommissioning plan includes requirements
relating to documentation of the facility, prerequisites for planning and thedecommissioning activity itself.

SwitzerlandYes.
•

decommissioning concept (initial plan) for general licence;•

decommissioning plan for construction licence (NPP) or a project for themonitoring period and a plan for the closure of the installation (other facilities);•

updating of plan or project concerning decommissioning and closure every ten
years and periodic review.

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content:– choice and motivation of decommissioning variant;– measures during operation in order to facilitate subsequent dismantling;– safety systems and installation components that will still be needed or adapted;– additional systems required for dismantling and waste management;– safety assessment;– quantity and schedule of expected radioactive waste and cleared materials;– transport and storage casks for the removal of fuel elements after shutdown;– interactions of systems and organisation with other nuclear installations in thesame site;– report on evaluation of experience gained from current decommissioning
projects of comparable nuclear installations in Switzerland and abroad.

United Kingdom
Yes. An initial decommissioning plan is required at the planning and design stage underlicence condition 35. This demonstrates that decommissioning can be achieved, informs
the design process, and is used as the basis of initial waste and cost estimates.
For new nuclear power stations, a funded decommissioning programme is required tobe submitted and approved before construction starts.

United StatesNo, but there are other regulatory submittals.
For information:•

PSDAR – high-level description decommissioning.

Revised major documents for NRC approval:•safety analysis report – new plant design basis;•

technical specifications;•emergency plan;•

security plan;•

spent fuel management plan;•licence termination plan – basis for radiological release of the site and funding
adequacy.

Dealing with different competent authorities involved in the decommissioning
authorisation process
CanadaYes. Although the nuclear sector is subject to federal jurisdiction through the Nuclear
Safety and Control Act, the CNSC utilises a harmonised or joint review approach withother federal, provincial or territorial departments in such areas as health, environment,
transport and labour. The CNSC expects nuclear facilities to comply with all applicable
federal and provincial regulations.

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As a lead agency, the CNSC invites other federal and provincial regulatory agencies toparticipate in the licensing process when their areas of responsibility could impact the
proposed nuclear facility. Those that choose to participate become members of a sitespecific joint regulatory group.

FranceYes.

GermanyYes.

JapanNo, only Nuclear Regulation Authority (NRA).

Korea
Yes. NSSC (Nuclear Safety and Security Commission, governmental organisation) and
KINS (Korea Institute of Nuclear Safety, regulatory body).
Considering opinion of local government and local public citizen.

Spain
Yes. Regulatory body (CSN) with ministries involved (industry, environment and interior).
Regional and local authorities.

SwedenYes. Mainly the Land and Environmental Court and Radiation Safety Authority.

Switzerland
Yes. Regulatory body (ENSI) with/and departments (DETEC, granting authority) andcantons (federal states) involved (environmental impact assessment).

United Kingdom
Yes. The Office for Nuclear Regulation is responsible for the regulation of nuclear safety,
security and transport on nuclear licensed sites. The environmental regulators are
responsible for regulating radioactive waste discharges during operations anddecommissioning.

United States
Yes. NRC is lead regulator for radiological, but state authorities can be more restrictive.
The US Environmental Protection Agency or state agency oversees non-radiological site
release.

Operator is the decommissioning responsible
CanadaYes.

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COMPARISON OF REQUIREMENTS FOR THE REGULATORY FRAMEWORK AND AUTHORISATION PROCESS FOR DECOMMISSIONINGFranceYes.

Germany
Yes.

Japan
Yes.

Korea
Yes.

Spain
No. Transfer of licence to Enresa.

SwedenYes, the licence holder is the responsible, but in principle it is possible to transfer the
licence to another company or organisation.

Switzerland
Yes

United Kingdom
The implementation of decommissioning is the responsibility of the licensee. UK civil
public sector nuclear sites are strategically managed by the Nuclear Decommissioning
Authority (NDA).

United States
Normally yes, but licence can be transferred to another company such as at Zion plant
where the operating licence has been transferred to ZionSolutions. NRC is responsible foroversight and inspection of the decommissioning activities.

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Annex D. Systematic approach to training (SAT)

During operations, the nuclear facilities developed and implemented systematic
approach to training (SAT) based (SAT-based) training programmes. If a new organisation
will decommission the nuclear facility, then the new organisation will develop andimplement the SAT process utilising the job and task analysis processes associated withthe analysis functions, to identify all the tasks that must be perform by each work groupor job family and to identify knowledge, skills and safety-related attributes that theworkers must have to perform each task effectively.
The training process during the transition to decommissioning should have asystematic approach with similar phases as for the operation of the nuclear facility.
However, the process needs to adapt to the changes. The training process shall be
synchronised with the new configuration of the facility. In general, the external
contractors bring new skills and competencies. The training process is applicable to all,including contractors.
If the same organisation that operated the nuclear facility will perform thedecommissioning, some regular training programmes for tasks that have not beenchanged (e.g. conventional health and safety) will be the same. In the first phase, thecompetence of staff of the operating facility is used or the competence is acquired byprofessional conversion. If the operators are already qualified for routine operations thatwere performed during operation and during the shutdown and after shutdown, then no
additional training and qualification is performed. Some activities require additional
skills and new training programmes. Personnel are necessary to develop multi-skilling if
it is necessary. As new technologies are developed to produce less waste and safer
environment, new skills are necessary to be planned and implemented.
The importance of training during the transition to decommissioning is highlighted indifferent NEA, IAEA and EC documents (IAEA, 2008, 2004, 2000; EC, 2008). The
qualification of the decommissioning/dismantling staff is required by the state members
and the NEA member countries’ regulatory framework has the specific requirements.

Training process during transition
All training systems, that base on a systematic approach, features a loop of theinterdependent functions of analysis, design, development, implementation andevaluation. It is this cyclic process that enables training to meet extant operational
requirements, but also to react quickly to changes in those requirements. These changes
in requirements may result from ongoing engineering and/or procedural changes or froma change in the state of the facility.
Each phase of training base should be documented and implemented during thetransition to decommission. The process is applicable in a graded manner,commensurate with risk. When a few worker categories are in place, a simplified training
is developed and implemented. The radiological risk associated with the activities always
needs to be assessed.
The analysis phase is the foundation of any training course or training programme
and includes inputs from operational and decommissioning staff, users including

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contractors, subject matter experts and training development experts. The analysis
phase is the key step for the transition phase for decommissioning and dismantling andcontains the following steps:•

Training needs analysis. The analysis is used to assess the skills and knowledge
gaps and transfer of knowledge created by the changes in the configuration of
nuclear facilities, operational changes after shutdown (e.g. transfer of activities
from operation to maintenance and surveillance), revised operational procedures,
issuing new procedures for decommissioning and dismantling, research anddevelopment activities and new regulatory requirements. The knowledge isretained during the transition to decommissioning (e.g. surveillance andmaintenance).

•

During job and task analysis phase are identified all the tasks involved in the newstate of the nuclear facility and transition to decommissioning and dismantling,including performing some decommissioning work, accident conditions andemergency. The jobs with radiological risks always shall be identified. If the futureplanned activities will be performed by a contractor, then the analysis should takein consideration that the contractors should have the necessary operational skills
including the operation into the radiological environment. In practice, a list withall the tasks that need to be completed is issued. The list is a controlled documentthat should be updated with sufficient frequency to ensure the processeffectiveness. Task difficulty, importance and frequency are considered todetermine which tasks need to be part of training and to determine the initial andcontinuing training content. A task analysis is conducted to determine the methodof task performance and associated knowledge, skills and safety attributes. The
analysis includes the frequency of the tasks to be performed. The outputs of thisphase include the identification of job requirements, performance expectations
and tasks required the training and selection of the appropriate training.

•

Learning objectives should be defined. Terminal learning objectives are statementsof the tasks that the workers must be able to demonstrate after completing thetraining.

•

During target audience analyses it is determined the number and categories ofworkers to be trained, and where possible, the characteristics of the individuals
who will receive training.

During the Design phase, the training is organised into discrete topics and needs toensure a logical sequence. The knowledge, skills and safety-related attributes lead to
documentation of the enabling training objectives. The appropriate training delivery
methods (classroom, on-the-job, computer base) are developed. The organisation will
determine the method of assessment (i.e. written, practical) and the training plan.
For development phase, the lesson plans for each topic are created. The existing
training material is reviewed to determine suitability. Training materials are developed.
The training could include generic training (radiation protection, work permit
authorisation, confine space entry, emergency first aid, fall protection), process specifictraining (e.g. reactivity determination, use of tools underwater) and project specifictraining (e.g. configure the facility for core removal, irradiated core removal, response to
emergencies, hazard assessment). Feedback forms are created once training is complete.
During the implementation phase, qualified instructors are assigned and training isdelivered in according to the plans. The training is continually assessed and theassessments are reviewed.
In the evaluation phase feedback is gathered from trainees and supervisors, regarding
training and worker performance. Any change should be regularly inputted into analysis
phase.

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It can take a long period of training and experience for some specialised staff(e.g. radiation protection) to develop competency in carrying out their duties. Therefore,
the senior management of the operating nuclear facility or the organisation in charge fordecommissioning must plan ahead and ensure that any changes in staffing levels
through downsizing or hiring will address future staffing needs. When reductions in staff
are considered, the risk in delaying, reducing, reorganising or eliminating tasks or
projects is assessed and the management should consider options for replacing staff withspecial expertise. The IAEA (2008) highlighted that longer the time between plant
shutdown and start of decommissioning “there is a greater need for un active policy ofretention of the knowledge and training, in order to capture the experience andknowledge of the outgoing personnel”.
During the transfer to a new model of organisation for decommissioning, the ownerorganisation should take advantage of the key previous organisation representatives, if
available, to provide support to share transfer including the training programme. During
the transition to the decommissioning, the training programmes enhanced with theparticipation of specialised personnel from the operation of the facility. Operating
personnel who will continue working during the decommissioning and dismantling mustbe also trained. In general, during the decommissioning there is a mixture of experienced
personnel having operating experience and knowledge and personnel withdecommissioning experience and knowledge. The training programme should be adapted
to the field situation.
Training of all staff in all aspects of decommissioning and waste management should
ensure the capability of staff in addressing an unexpected event is known and thepersonnel are able to deal with it. The training programme should aim to respond to
unexpected events. If an unexpected event happened, and the event was caused byinadequate training, the corrective action should include the training programme (IAEA,
2016).

Experience in the state members related to training
In Canada, during the recent shutdown of Hydro Quebec CANDU Nuclear Power Plant
Gentilly-2 (G2), the licensee’s training programme and associated procedures wererevised to reflect the new state of the plant. The training programme meets theregulatory requirements. Some activities necessary to put the plant in a safe storage state,such as resins transfer, required development of specific training. This was completedwith the help from qualified and experienced personnel from the engineering
department in addition to the operation department personnel. Pre-job briefings wereused as a training tool for other activities for which the workers were already qualified.
Furthermore, G2 kept ex-qualified operators in the new permanent organisational
structure for the operation of the remaining active systems, such as heating, ventilation
or electrical distribution and for the waste management. These staff will get support fromthe five maintenance units on-site (civil, electric, mechanic, chemistry, andinstrumentation) for surveillance activities of the systems. Training was developed andprovided to the maintenance personnel and included three phases: classroom training,
field training which was familiarisation training in the field and was performed
immediately following the classroom training, and finally, co-piloting training with exqualified operators which consisted of hands-on training in the field. Ex-G2 subject
matter experts, including ex-qualified operators with experience in training andevaluation of operating personnel, were involved in the analysis, design, development
and delivery of training for the maintenance personnel. Training programme for waste
management personnel and for radiation protection were also revised or developed.
In some countries (i.e. United Kingdom), specific training programmes were
established to provide a career in the field of decommissioning. A brief description isstated in the IAEA report Decommissioning of Nuclear Facilities: Training and Human Resources
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SYSTEMATIC APPROACH TO TRAINING

Considerations (IAEA, 2008). Kockerols et al. (2016) also provides a general assessment of
the training in the decommissioning.

References
EC (2008), “Project Management and Planning”, Final Report, European Commission
Research and Technological Development.
IAEA (2016), Managing the Unexpected in Decommissioning, Nuclear Energy Series No. NW-T2.8, IAEA, Vienna.
IAEA (2008), Decommissioning of Nuclear Facilities: Training andConsiderations, Nuclear Energy Series, No NG-T-2.3, IAEA, Vienna.

Human

Resources

IAEA (2004), Transition from Operation to Decommissioning of Nuclear Installations, Technical
Reports series No. 420, IAEA, Vienna.
IAEA (2000), Organisation and Management for Decommissioning of large Nuclear Facilities,
Technical Report Series No. 399, IAEA, Vienna.
Kockerols, P., M. Freer and H. Schneider (2016), “Education and Training in
Decommissioning Needs, Opportunities and Challenges”, PREDEC2016, 16-18 February
2016, Lyon, France.

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Annex E. Bibliography – National and international guidance
documents

Nuclear Energy Agency
NEA (2016), Strategic Considerations for the Sustainable Remediation of Nuclear Installations, OECD,
Paris.
NEA (2013), “Radiological Characterisation for Decommissioning of Nuclear Installations,Radioactive Waste Management”, NEA/RWM/WPDD(2013)2, www.oecd-nea.org/rwm/
docs/2013/rwm-wpdd2013-2.pdf.
NEA (2010a), Applying Decommissioning Experience to the Design and Operation of New Nuclear
Power Plants, OECD, Paris.
NEA (2010b), Decommissioning Considerations for New Nuclear Power Plants, OECD, Paris.
NEA (2008), Regulating the Decommissioning of Nuclear Facilities, OECD, Paris, www.oecdnea.org/rwm/reports/2008/ne6401-decommissioning.pdf.
NEA (2006), Selecting Strategies for the Decommissioning of Nuclear Facilities, OECD, Paris,
www.oecd-nea.org/rwm/reports/2006/nea6038-decommissioning.pdf.
NEA (2003), The regulatory challenges of decommissioning nuclear reactors, OECD, Paris,
www.oecd-nea.org/nsd/reports/nea4375-decommissioning.pdf.

International Atomic Energy Agency
IAEA (2016), Managing the unexpected in decommissioning, IAEA Technical Report, IAEA, Vienna,
www-pub.iaea.org/MTCD/Publications/PDF/Pub1702_web.pdf.
IAEA (2014), Decommissioning of Facilities, Safety Standards GSR Part 6, IAEA, Vienna, wwwpub.iaea.org/MTCD/publications/PDF/Pub1652web-83896570.pdf.
IAEA (2013), Use of External Experts by the Regulatory Body, Safety Standards Series No. GSG-4,
IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/Pub1583_web.pdf.
IAEA (2013), Planning, Management and Organizational Aspects of the Decommissioning of Nuclear
Facilities, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/TE-1702_web.pdf.
IAEA (2011), Policies and Strategies for the Decommissioning of Nuclear and Radiological Facilities,
NW-G-2.1, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/Pub1525_web.pdf.
IAEA (2010), Licensing Process for Nuclear Installations, Safety Standard Series No. SSG-12, IAEA,
Vienna, www-pub.iaea.org/MTCD/publications/PDF/Pub1468_web.pdf.
IAEA (2009), Determining and Use of Scaling Factors for Waste Characterisation in Nuclear Power
Plants, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/Pub1363_web.pdf.
IAEA (2008a), Decommissioning of Nuclear Facilities: Training and Human Resource Considerations,
IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/P1332_web.pdf.
IAEA (2008b), Long Term Preservation of Information for Decommissioning Projects, IAEA, Vienna,
www-pub.iaea.org/MTCD/publications/PDF/trs467_web.pdf.
IAEA (2008c), Safety Assessment for the Decommissioning of Facilities Using Radioactive Material,
IAEA, Vienna, www-pub.iaea.org/MTCD/publications/PDF/Pub1372_web.pdf.
IAEA (2007), Considerations for Waste Minimization at the Design Stage of Nuclear Facilities, IAEA,
Vienna, www-pub.iaea.org/MTCD/publications/PDF/trs460_web.pdf.
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BIBLIOGRAPHY – NATIONAL AND INTERNATIONAL GUIDANCE DOCUMENTS

IAEA (2005), Financial Aspects of Decommissioning, IAEA, Vienna, www-pub.iaea.org/
MTCD/publications/PDF/te_1476_web.pdf.
IAEA (2004a), Safety Considerations in the Transition from Decommissioning of Nuclear Facilities,
IAEA, Vienna, www-pub.iaea.org/MTCD/publications/PDF/pub1184_web.pdf.
IAEA (2004b), Transition from Operation to Decommissioning of Nuclear Installations, IAEA,
Vienna, www-pub.iaea.org/MTCD/publications/PDF/TRS420_web.pdf.
IAEA (2003), Managing the Early Termination of Operation of Nuclear Power Plants, IAEA, Vienna,
www-pub.iaea.org/MTCD/publications/PDF/Pub1163_web.pdf.
IAEA (2002a), Record Keeping for the Decommissioning of Nuclear Facilities: Guidelines andExperience, IAEA, Vienna, www-pub.iaea.org/MTCD/publications/PDF/TRS411_scr.pdf.
IAEA (2002b), Safe and Effective Nuclear Power Plant Life Cycle Management Towards
Decommissioning, TECDOC-1305, IAEA, Vienna, www-pub.iaea.org/MTCD/publications/PDF/te_1305_web.pdf.
IAEA (2000a), Organization and Management for Decommissioning of Large Nuclear Facilities, IAEA,
Vienna, www-pub.iaea.org/MTCD/publications/PDF/TRS399_scr.pdf.
IAEA (2000b), Predisposal Management of Radioactive Waste, Including Decommissioning, Safety
Standards Series No. WS-R-2, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/
P089_scr.pdf.
IAEA (1999a), Decommissioning of Medical, Industrial and Research Facilities, Safety Standards
Series No. WS-G2.2, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/
P078_scr.pdf.
IAEA (1999b), Decommissioning of Nuclear Fuel Cycle Facilities, Safety Standards Series No. WSG2.4, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/Pub1110_web.pdf.
IAEA (1999c), Decommissioning of Nuclear Power Plants and Research Reactors, Safety Standards
Series No. WS-G2.1, IAEA, Vienna, www-pub.iaea.org/MTCD/Publications/PDF/
P079_scr.pdf.

Western European Nuclear Regulators’ Association
WENRA (2015), “Decommissioning Safety Reference Levels”, Working Group on Waste
and Decommissioning, www.wenra.org/media/filer_public/2015/10/14/wgwd_report_
decommissioning_srls_v2_2.pdf.

Electric Power Research Institute (EPRI)EPRI (2006), “Decommissioning Planning”, Report 1013510, www.epri.com.
EPRI (2001), “Decommissioning Pre-Planning Manual”, Report 1003025, www.epri.com.
EPRI (2000), “Preparing for Decommissioning – The Oyster Creek Experience”, Report
1000093, www.epri.com.
EPRI (1998), “Guide to Regulatory Process for Decommissioning Power Plants”, Report TR109031, www.epri.com.

CanadaCNSC (2000a), Regulatory Guide G-219: Decommissioning Planning for Licensed Activities,
CNSC, Ottawa.
CNSC (2000b), Regulatory Guide G-206: Financial Guarantees for the Decommissioning ofLicensed, CNSC, Ottawa.

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BIBLIOGRAPHY – NATIONAL AND INTERNATIONAL GUIDANCE DOCUMENTS

CSA (2009), CSA Standard N294-09: Decommissioning of Facilities Containing Nuclear
Substances, CSA.Government of Canada (1997), “Nuclear Safety and Control Act (NSCA)”,
http://nuclearsafety.gc.ca.
Environment Canada (2012), “Canadian Environmental Assessment Act”, CEAA 2012,
http://nuclearsafety.gc.ca.
Natural Resources Canada (2015), Nuclear Liability Act (NLA), http://nuclearsafety.gc.ca.
NaturalResources
Canadahttp://nuclearsafety.gc.ca.

(2002),

Nuclear

Fuel

Waste

Act

(NWFA),Natural Resources Canada (1985), “Nuclear Energy Act (NEA)”, http://nuclearsafety.gc.ca.

FranceAndra (2015), “Radioactive Waste Management and Decommissioning in France”, ASN, CEA,IRSN Andra Report, April 2015.
ASN (2016a), “Guide nº 6 de l´ASN. Arrêt définitif, démantèlement et déclassement desinstallations nucléaires de base”.
ASN (2016b), “Méthodologies d’assainissement complet acceptables dans les installations
de base en France (Guide n° 14 de l’ASN)”.
ASN (2015), “Mise à l’arrêt définitif démantèlement et déclassement des INB Guide ASN n°6
du 16/07/2015”.
ASN (2009), “ASN Policy Concerning the Decommissioning and Delicensing of Basic Nuclear
Facility in France Rev 03”, April 2009.
French Government (2015), “LOI no 2015-992 du 17 août 2015 relative à la transitionénergétique pour la croissance verte”.
French Government (2008), “Décret n°2007-1557 du 2 novembre 2007 relatif aux
installations nucléaires de base et au contrôle, en matière de sûreté nucléaire, dutransport de substances radioactives”.
French Government (2006), “Environmental Code”.

Germany
BMU (2016), “Guide to the Decommissioning, the Safe Enclosure and the Dismantling ofFacilities or Parts thereof as Defined in § 7 of the Atomic Energy Act”,
Decommissioning Guide, www.bfe.bund.de/SharedDocs/Downloads/BfE/EN/hns/a1english/A1-DecommGuide.html.
BMU (2015), “Safety Requirements for Nuclear Power Plants as Amended and Publishedon 3 March 2015”, www.bfe.bund.de/SharedDocs/Downloads/BfE/EN/hns/a1english/A1-03-15-SiAnf.pdf?__blob=publicationFile&v=1
ESK (2015), “Recommendation of the Nuclear Waste Management Committee (ESK):
Guidelines for the Decommissioning of Nuclear Facilities as of 16 March 2015”,
www.entsorgungskommission.de/sites/default/files/reports/empfllstesk46hpen.pdf.
Atomic Energy Act.
Nuclear Licensing Procedures Ordinance (AtVfV).
Radiation Protection Ordinance (StrlSchV).
Nuclear Financial Security Ordinance (AtDeckV).
Cost Ordinance under the Atomic Energy Act (AtKostV).
Nuclear Safety Officer and Reporting Ordinance (AtSMV).
Nuclear Reliability Verification Ordinance (AtZüV).

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Japan
Tachibana, M., M. Murata and T. Tasaki (forthcoming), “Experiences of Preparation of
Decommissioning of Reactor Facilities in the JAEA”, October 2015.

Korea
Atomic Energy Promotion Act.
Nuclear Safety Act.
Act on Physical Protection and Radiological Emergency.
Nuclear Liability Act.
Electricity Business Act.

Spain
CSN (2015), “Royal Decree 1836/1999, of 3rd December. Regulation on Nuclear andRadioactive Installations”, latest modification on 26 March 2015 (RNRF).
CSN (2001), “Royal Decree 783/2001, of the 6th of July, which Approves the Regulation on
Sanitary Protection against Ionising Radiations”.
CSN (2014), “Real Decreto 102/2014, de 21 de febrero, para la gestión responsable y seguradel combustible nuclear gastado y los residuos radiactivos”.
CSN (2003), “Instruction IS-04, of 5th February 2003, of the Nuclear Safety Council
Regulating the Transference, Filing and Custody of Documents Relating to the Radiation
Protection of the Workers, the General Public and the Environment Prior to theTransference of the Licence Ownership of the Nuclear Power Plants for Dismantling andDecommissioning”.
CSN (2007), “Instruction IS-13, dated 21 March 2007, on the Radiological Criteria for theRelease of Nuclear Installation Sites”.
CSN (2008), “Instruction IS-19, of October 22nd 2008, on the Requirements of the Nuclear
Facilities Management System”.
CSN (2010), “Instruction IS-24, of 19th May 2010, Regulating the Filing and Periods ofRetention of the Documents and Records of Nuclear Facilities”.
CSN (2011), “Instruction IS-31, of 26 Jun 2011, on the Criteria for the Radiological Control of
Residual Materials Generated in Nuclear Facilities”.
CSN (2013), Guía de Seguridad 10.13. Garantía de calidad para el desmantelamiento yclausura de instalaciones nucleares.
Enresa (2007), Vandellós I: Decommissioning Report, Enresa, Madrid, www.enresa.es/eng/
index/about-enresa/publications.
Enresa (2015), Dismantling and Decommissioning of the José Cabrera Nuclear Power Plant,
www.enresa.es/eng/index/about-enresa/publications/category/10-divulgation.
Correa Sáinz, C. (2016), “Decommissioning Licensing Process of Nuclear Installations in
Spain”, PREDEC 2016, 16-18 February 2016, Lyon, France, www.oecdnea.org/rwm/wpdd/predec2016/docs/S-5-2___ppt__CORREA-SAINZ__.pdf
SEPR (2013), “Revista Radioprotección de la Sociedad Española de Protección Radiológica”,
Desmantelamiento, nº 76 Vol. XX, www.sepr.es/recursos/revista/RP76.

SwedenAct on Nuclear Activities (1984:3).
Radiation Protection Act (1988:220).

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BIBLIOGRAPHY – NATIONAL AND INTERNATIONAL GUIDANCE DOCUMENTS

Act on Financial Measures for the Management of Residual Products from Nuclear
Activities (2006:647).
Environmental Code (1998:808).

Switzerland
ENSI (2014), “Decommissioning Guideline”, ENSI-G17, www.ensi.ch/en/document/g17decommissioning-of-nuclear-installations.
Supervisory Concept for the Decommissioning of a Nuclear Power Plant (AUKOS), April
2014 (not publicly available).
Swiss Government (2003), “Nuclear Energy Act (NEA)”, SR 732.1, March 2003,
www.admin.ch/opc/en/classified-compilation/20010233/index.html.
Swiss Government (2004), “Nuclear Energy Ordinance (NEO)”, SR 732.11, December 2004,
www.admin.ch/opc/en/classified-compilation/20042217/index.html.
Swiss Government (2007), “Ordinance on the Decommissioning Fund and the Waste
Disposal Fund for Nuclear Installations” (only available in German, Italian and French),
SR 732.17, www.admin.ch/opc/de/classified-compilation/20070457/index.html.

United Kingdom
EA (2010a), “Radioactive Substances Regulation – Environmental Principles”, Regulatory
Guidance Series, No RSR 1, www.gov.uk/government/uploads/system/uploads/
attachment_data/file/296388/geho0709bqsb-e-e.pdf.
EA (2010b), “Radioactive Substances Regulation: Management Arrangements at Nuclear
Sites”, Environment Agency, www.gov.uk/government/uploads/system/uploads/attachment_data/file/299652/RSR_Management_arrangements_at_nuclear_sites.pdf.
EA/Natural Resources Wales (2013), “The Decommissioning of Nuclear Facilities”, Joint
guidance from the Environment Agency and Natural Resources Wales,
www.gov.uk/government/uploads/system/uploads/attachment_data/file/296510/LIT_8
828_c654b3.pdf.
ONR (2015), “The Management of Higher Activity Radioactive Waste on Nuclear Licensed
Sites”, Revision 2, February 2015, www.onr.org.uk/wastemanage/waste-managementjoint-guidance.pdf.
ONR (2013), “Decommissioning Nuclear Safety Technical Assessment Guide 26”, Office for
Nuclear Regulation, May 2013, www.onr.org.uk/operational/tech_asst_guides/ns-tastgd-026.pdf.
UK Government (2010), “Environmental Permitting (England and Wales) Regulations 2010”,
www.legislation.gov.uk/ukdsi/2010/9780111491423/contents
UK Government (2008), “Energy Act 2008”, www.legislation.gov.uk/ukpga/2008/32/contents.
UK Government (2006), “Nuclear Reactors (Environmental Impact Assessment for
Decommissioning) Regulations 1999 (as amended 2006)”.
UK

Government(1965),“Nuclear
Installations
www.legislation.gov.uk/ukpga/1965/57.

asamendedAct1965”,

United States
NRC (2012), “Decommissioning Planning During Operations”, Regulatory Guide 4.22,
December 2012, http://pbadupws.nrc.gov/docs/ML1215/ML12158A361.pdf.
NRC (n.d.), “Termination of license”, Title 10 Code of Federal Regulations Part 50.82(10CFR50.82), www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0082.html.

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Preparing for Decommissioning During
Operation and After Final Shutdown

The transition from an operating nuclear facility to the decommissioning phase is critical in the life
cycle of every facility. A number of organisational and technical modifications are needed in orderfor the facility to meet new objectives and requirements, and a certain number of activities must
be initiated to support the transition and preparation for the dismantling of the facility. Thoroughpreparation and planning is key for the success of global decommissioning and dismantling projects,
both to minimise delays and undue costs and to ensure a safe and efficient decommissioning process.
The aim of this report is to inform regulatory bodies, policy makers and planners about the relevant
aspects and activities that should begin during the last years of operation and following the end ofoperation. Compiling lessons learnt from experiences and good practices in NEA member countries,
the report supports the further optimisation of transition strategies, activities and measures that will
ensure adequate preparation for decommissioning and dismantling.

Nuclear Energy Agency (NEA)
46, quai Alphonse Le Gallo
92100 Boulogne-Billancourt, France
Tel.: +33 (0)1 45 24 10 15
nea@oecd-nea.org www.oecd-nea.org

NEA No. 7374