INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN 

FY 2004-2007 

Revision 1

March 29, 2005

Decommissioning Directorate

Division of Waste Management and Environmental Protection

U.S. Nuclear Regulatory Commission
2

TABLE OF CONTENTS

1 Introduction 4 

1.1 Purpose 4

1.2 Content 4

2 Background 4

2.1 LTR Analysis and Commission direction 4 

2.2 Decommissioning Program Evaluation recommendations 5

2.3 Commission direction resulting from the annual decommissioning 5

briefing

3 Summary of Integrated Key Components 6

4 Description of Regulatory Improvements from the LTR Analysis 9

4.1 Revise guidance for institutional controls 9

4.2 Revise inspection and enforcement guidance 10

4.3 Develop new rule and supporting guidance 11

4.4 Other LTR Analysis recommendations approved by the Commission 12

5 Description of Program Management Improvements from the 

Decommissioning Program Evaluation 12 

5.1 Establish a comprehensive decommissioning perspective 12

5.2 Implement the new consolidated decommissioning guidance 14

5.3 Improve staff availability and efficient utilization 15

5.4 Expand management reviews of all decommissioning plans 16

5.5 Compare and evaluate NRC’s decommissioning program 16

5.6 Revise annual budget output measures 17

5.7 Consider using incentives 18

5.8 Integrated Decommissioning Improvement Plan 18

5.9 Communication strategy 19

6 Description of Program Management Improvements from Commission SRM 19

6.1 Capture and share lessons learned and best practices 20

6.2 Radiological monitoring 20

6.3 Finality of decommissioning process 20

6.4 Consistency among State and Federal regulators 20

6.5 Enhance guidance on flexibility and institutional controls 20
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7 Project Management of IDIP 21

7.1 Products 21

7.2 Assignments 21

7.3 General Schedule of Activities 22

7.4 Budget, Resource Estimates, and TAC numbers 23

Attachment 1: LTR Analysis and Program Evaluation Recommendations 24

Attachment 2: IDIP Product Matrix 32

Attachment 3: IDIP Assignment Matrix 35

Attachment 4: IDIP Budget and TAC Numbers 38
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INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN 

FY 2004-2007 

1.0 Introduction

1.1 Purpose 

The purpose of the U.S. Nuclear Regulatory Commission’s (NRC’s) Integrated

Decommissioning Improvement Plan (IDIP) is to:

describe a “continuous improvement” plan for decommissioning during FY 2004-2007

and

integrate and track regulatory improvements from the License Termination Rule

(LTR) Analysis and program management improvements resulting from the

Decommissioning Program Evaluation, Commission’s direction resulting from the

annual briefing in October 2004, and other staff improvements.

1.2 Content

Section 2.0 provides relevant background. Section 3.0 is a integrated summary of

key improvements to make the program more effective resulting from: 1)

Commission approved recommendations from the LTR Analysis; 2)

recommendations from the Decommissioning Program Evaluation; and 3)

Commission direction from the Staff Requirement Memorandum (SRM) from the

annual program briefing to the Commission. A full set of improvements are

integrated and listed by fiscal year, including improvements completed in FY 2004

and improvements planned for FY 2005-2007. Section 4.0 provides a description of

the LTR Analysis improvements planned for FY 2005-2007, and Section 5.0 provides

a description of the program management improvements planned for FY 2005-2007. 

Section 6.0 provides other improvements including the Commission’s direction in the

SRM on the annual briefing and other staff improvements. Finally, Section 7.0

provides project management information including a general schedule; products;

and budget and resource information. 

2.0 Background

2.1 LTR Analysis and Commission Direction

NRC staff experience with the LTR has revealed some important implementation

issues impacting the decommissioning of sites. The Commission directed the staff,

in June 2002, to conduct an analysis of LTR issues, with particular emphasis on

resolving the restricted release and institutional control issues . The staff’s analysis

and recommendations for eight issues were provided to the Commission on May 2,

2003 (SECY-03-0069), and the Commission approved the staff’s recommendations

with comments on November 17, 2003. Subsequently, on March 1, 2004, the staff
5

provided the Commission with its analysis of a ninth issue on intentional mixing

(SECY-04-0035), and the Commission approved the staff’s recommendation, with

comments on May 11, 2004. The Commission-approved recommendations and

comments are the basis for the planned actions conducted during FY 2004 and

planned during FY 2005-2007 as identified in this Plan. Attachment 1 provides the

recommendations.

2.2 Decommissioning Program Evaluation Recommendations

NRC’s Strategic Plan for FY 2000-2005 identified a program evaluation entitled

Changes to the Decommissioning Process to be conducted in FY 2003. On

September 29, 2003, the NRC staff completed its evaluation. In this report, the staff

evaluated the effectiveness of NRC’s Division of Waste Management (DWM)

Decommissioning Program and recommended future improvements. The staff

evaluated overall program effectiveness with: 1) NRC’s Strategic Plan measures and

targets; 2) the Office of Nuclear Material Safety and Safeguards (NMSS) Operating

Plan accomplishments; and 3) the Office of Management and Budget (OMB)

Program Assessment Rating Tool (PART). The staff used the PART questions as an

independent methodology to systematically and comprehensively evaluate its

program to identify areas of the program’s effectiveness that might need further

improvement. The staff also evaluated the effectiveness of 18 specific

changes/improvements that were made to the program during the FY 2001–FY 2003

evaluation period.

The staff concluded in the Program Evaluation that the Decommissioning Program

has been effective in meeting the Agency’s strategic and performance measures and

removing sites from the Site Decommissioning Management Plan (SDMP) list after

completion of decommissioning and license termination. The program also

effectively used many types of self-assessments and program changes to improve

the regulatory framework, decommissioning processes, internal program

management processes, and public involvement. 

The Program Evaluation also noted that although significant improvements have

been completed, future improvements would be beneficial. In particular, the

recommendations in the LTR Analysis (SECY-03-0069) to resolve the LTR policy

issues, when implemented as directed by the Commission, offer potentially significant

future improvements for the program. To complement these regulatory and policy

improvements, the Program Evaluation made additional recommendations that

primarily would improve internal program management (see Attachment 1). The IDIP

identifies the improvements completed in FY 2004 and planned for FY 2005-2006 to

address the recommendations in the Program Evaluation. 

2.3 Commission Direction Resulting from the Annual Decommissioning Briefing

The staff presented its annual briefing on the Decommissioning Program in October

2004. In addition to the staff, invited stakeholders representing industry and a State

also presented their views on the Decommissioning Program. As a result of this
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briefing, the Commission directed the staff to address the five items listed below

(October 22, 2004, SRM-M041013A). 

- Capture lessons learned and best practices and share

- Improve radiological monitoring 

- Establish measures to provide finality in decommissioning

- Improve consistency among State and Federal regulators 

- Enhance guidance to better address issues of flexibility and institutional controls for

 restricted release

The staff has incorporated these five items into the IDIP. The third item is being

addressed under staff activities that implement the U.S. Environmental Protection

Agency (EPA)-NRC Memorandum of Understanding (MOU).

3.0 Summary of Integrated Key Improvements

Improvement activities completed in FY 2004

Received Commission approval of staff recommendations for eight LTR issues in

SECY-03-0069

Analyzed LTR issue for intentional mixing of soils; received Commission approval of

recommendations (SECY-04-0035) 

Published a Regulatory Issue Summary (RIS) to inform licensees and stakeholders of

NRC’s plans to resolve the LTR Analysis of nine issues (RIS 2004-08)

Completed interim guidance on Long-Term Control (LTC) license for Shieldalloy

Metallurgical Corporation (SMC) site 

Restructured into comprehensive decommissioning program 

Reorganized DWM, hired critical disciplines in health physics 

Established a risk-informed procedure to prioritize site resources 

Began developing a communication strategy with new tools to exchange

knowledge/lessons (U.S. Department of Energy (DOE) Interagency Agreement (IA),

Annual Report, lessons web page) 

Started staff training to implement Consolidated Guidance and LTR issues with training

on Vols 1-3 
7

Enhanced management review of decommissioning progress in Decommissioning

Board meetings 

Approved additional resources during the budget process for program improvements

and additional dose assessment critical skills

Shared guidance on LTR Analysis issues with stakeholders (Waste Management (WM)

05 Symposia papers, National Mining Association annual meeting)

Prepared initial IDIP 

Improvement activities planned in FY 2005 

Prepare draft revised guidance for public comment on LTR Analysis issues: restricted

use; onsite disposal; realistic scenarios; removal of material after license termination;

intentional mixing of soil

Develop a risk-informed approach to revised inspection and enforcement procedures to

reduce risk of decommissioning problems at operating sites

Begin proposed rulemaking/supporting guidance for changes in financial assurance and

operations to prevent future legacy sites

Continue to implement new guidance by training staff on dose modeling, risk-informed

approaches, LTR Analysis issues (as draft guidance is developed).

Further enhance dose modeling staff skills with budget increase and DOE reimbursable

work

Continue consultations with licensees on new guidance and LTR issues

Develop resource expenditure tracking procedures

Revise performance measures for new Strategic Plan

Complete independent review of program by Inspector General (IG) 

Complete independent review of key issues and guidance by the Advisory Committee

on Nuclear Waste (ACNW)

Continue to implement communication strategy by holding stakeholder workshop to

obtain early input on guidance, lessons learned, and suggestions for further program

improvements as well as web page enhancements and decommissioning brochure

Evaluate incentives to facilitate decommissioning progress
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Begin sharing guidance and lessons with DOE, Agreement States, and technical

community (Stakeholder workshop, WM 05 Symposia, American Nuclear Society (ANS)

05 Conference)

Revise IDIP based on IG review, staff lessons learned, and stakeholder workshop

Coordinate/integrate with Regions and other offices and divisions

Finalize and implement prioritization procedure to manage resources

Document the status of improvements in Improvement Summary Report

Implement program management improvements by documenting procedures in revised

Decommissioning Operations Manual

Improvements Planned in FY 2006

Publish final revised guidance on LTR issues: restricted use; onsite disposal; realistic

scenarios; removal of material after license termination; intentional mixing

Publish proposed rulemaking/supporting guidance for changes in financial assurance

and operations to prevent future legacy sites. This includes revised inspection and

enforcement procedures to reduce risk of decommissioning problems at operating sites

Continue to implement new guidance by training staff on new guidance for LTR analysis

issues

Implement new inspection and enforcement procedures by training staff

Continue to share guidance and lessons with DOE and Agreement States

Revise IDIP based on IG review and decommissioning lessons 

Conduct OMB PART review, including reevaluation of program and effectiveness of

improvements

Improvements Planned in FY 2007

Re-evaluate program and revise IDIP based on PART results and decommissioning

lessons learned 

Publish final rulemaking/supporting guidance for changes in financial assurance and

operations to prevent future legacy sites

Continue to implement new rule/guidance by training staff on LTR Analysis issues,

guidance, and rulemaking.
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4.0 Description of LTR Analysis Improvements

4.1 Revise guidance for institutional controls; onsite disposal; removal of material after

license termination; realistic scenarios; and intentional mixing

4.1.1 Description

New guidance or revised guidance will be developed for the issues listed below; this

guidance will be included in the revision to the Consolidated Decommissioning

Guidance in NUREG-1757. The guidance will be prepared for the following LTR

Analysis issues listed below and should address the specific recommendations

approved by the Commission (see Attachment 1 and SRM-SECY-03-0069)

- Restricted use/institutional controls

- On-site disposal

- Realistic Scenarios

- Removal of material after license termination (relationship of LTR and control of 

 disposition of solid material)

- Intentional mixing of soil

- Other non-LTR Analysis topics (e.g., groundwater monitoring, engineered barriers)

The staff will use a process similar to the process used to develop NUREG-1757,

including: management team reviews; ACNW reviews; Agreement State 

participation/review; and stakeholder input from a workshop. Draft guidance for public

comment is planned for FY 2005 and final guidance planned for FY 2006. The

Commission requested that it be informed of stakeholder comments on the restricted

use/institutional control issue before guidance is finalized. 

New internal guidance in the Manual Chapter for possession only specific license will also

be developed to include a description of the new Long-Term Control possession only

specific license. 

4.1.2 Milestones, schedules, and assignments

Identify guidance development team assignments 12/04

Develop scope, schedule, and support assignments 02/05

Conduct stakeholder workshop to seek early input 04/05 

Prepare internal draft guidance summary for ACNW review 05/05

Obtain ACNW comments in working group meeting 06/05

Prepare external draft guidance for public comment 09/05

Prepare Commission paper on public comments FY06
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Prepare internal final guidance for ACNW review FY06

Prepare final guidance in revision to NUREG-1757 09/06

Train staff on final guidance FY07

Assignments:

- Project Management (PM) (Schmidt/Banovac) 

- Restricted use/institutional controls (Johnson/Banovac)

- On-site disposal (Youngblood)

- Realistic Scenarios (McKenney)

- Removal of material after license termination (Schmidt/Buckley) 

- Intentional mixing of contaminated soil (Widmayer)

- Office of the General Counsel (OGC) legal review (Smith)

4.2 Revise inspection and enforcement guidance to enhance monitoring, reporting, and

remediation to prevent future legacy sites

4.2.1 Description

New or revised inspection and enforcement guidance/procedures for operating

licensees (not decommissioning licensees) will be prepared for the following LTR

Analysis issues and should address the specific recommendations approved by the

Commission (see Attachment 1 and SRM-SECY-03-0069). 

Measures to prevent future legacy sites

- Changes to licensee operations

- Chronic releases

- Reporting deficiencies

This work will be conducted in two steps. The first step for FY 2005 will scope the

inspection and enforcement guidance, including developing a risk-informed approach

to identify operating sites with a high potential for subsurface contamination that

could cause future decommissioning problems, identifying types of sites or specific

sites and activities at these sites for heightened inspection, and identifying the types

of inspection activities that would be completed at these sites. The second step will

develop specific inspection and enforcement guidance for the types of sites and

inspections identified in the first step. The second step will be developed along with

the rulemaking and supporting guidance during FY 2006-2007 to ensure consistency

between the rulemaking and guidance (see section 4.3 below). Coordination or

participation with Regions and the Office of Enforcement (OE) will be necessary.

4.2.2 Milestones, schedules, and assignments

Identify guidance development team assignments 12/04
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Prepare internal draft summary of scope for ACNW review 05/05

Obtain ACNW comments in working group meeting 06/05

Prepare scope of guidance (approach, operating sites/activities, 

inspection activities 09/05

Develop draft inspection and enforcement guidance FY 2006

Develop final inspection and enforcement guidance FY 2007

Assignments:

PM: Shepherd

Brown, McKenney, Peckenpaugh, Nalluswami

Office of Research (RES) rep: TBD

Region rep: TBD

Office of Nuclear Reactor Regulation (NRR) rep: TBD

OE rep: TBD

OGC legal review: Smith

4.3 Develop new rule and supporting guidance for preventing future legacy sites

4.3.1 Description

A new rulemaking and supporting new guidance/revised guidance will be developed The

rule and guidance will be prepared for the following LTR Analysis issues listed below and

should address the specific recommendations approved by the Commission (see

Attachment 1 and SRM-SECY-03-0069): 

- Measures to prevent future legacy sites

- Changes to financial assurance

- Initial underestimation of decommissioning cost

- Unavailability of funds in bankruptcy

- Inadequate financial disclosure

- Reaching assets after corporate reorganization

- Investment losses reduce trust account balance

- Accidental release increases decommissioning cost

- Changes to licensee operations

- Chronic releases

- Reporting Deficiencies

The staff will use the NMSS rulemaking process. The Commission directed the staff in

SRM-COMSECY-04-0031 to proceed directly to the proposed rule stage, bypassing the

development of a separate rulemaking plan because SECY-03-0069 contained the
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necessary information. A proposed rule and draft supporting guidance for public comment

is planned for FY 2006 and the final rule and guidance planned for FY 2007. The

rulemaking work on the issue Changes to Licensee Operations links to the work on

Revising the Inspection and Enforcement Guidance for this issue (see Section 4.2). 

4.3.2 Milestones, schedules, and assignments

Identify guidance development team assignments 12/04

Conduct stakeholder workshop to seek early input 04/05

Prepare proposed rule/draft guidance for public comment 09/06

Prepare final rule/guidance 09/07

Assignments

PM: Kerr

Financial assurance changes: Fredrichs, contractor to be identified

Operational changes: Shepherd, Nalluswami, Peckenpaugh, Brown

RES/monitoring: TBD

OGC legal review: Smith

4.4 Other LTR Analysis recommendations approved by the Commission

4.4.1 Restricted Release–reevaluate potential for site transfers to DOE under the Nuclear 

Waste Policy Act (NWPA), Section 151(b) (Johnson)

4.4.2 Restricted Release–continue to monitor agency activities (DOE End States, DOE 

Legacy Management, EPA , Ohio) (Johnson)

4.4.3 Restricted Release–continue to implement options at specific decommissioning sites 

(SMC, AAR Manufacturing, West Valley) (Johnson)

4.4.4 Realistic scenarios–continue to implement option at specific decommissioning sites 

(SMC, AAR Manufacturing, West Valley, etc.) (McKenney)

4.4.5 Realistic Scenarios--Continue dose modeling improvements (Thaggard)

5.0 Description of Program Management Improvements fro the Decommissioning

Program Evaluation 

5.1 Establish a Comprehensive Decommissioning Program Perspective

5.1.1 Description
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Develop and Document Roles of Program Participants

Recommendations 1. (a), (b), and c) in Section 2.0 of Attachment 1 relate to aspects of

refining and documenting the roles and the decommissioning activities of various NRC

organizations making up the Comprehensive Decommissioning Program. This

restructuring was largely accomplished in FY 2004 as reported in the June 17, 2004,

Notice in the Federal Register (69 Federal Register 33946) that announced that NRC has

decided to eliminate the SDMP designation for sites and manage the SDMP sites as

“complex sites” under a comprehensive decommissioning program. Further

implementation of the comprehensive program is planned for FY 2005 to document in the

Decommissioning Operation Manual the roles of the Offices and Divisions involved with the

Comprehensive Decommissioning Program. 

Roles will also be coordinated with other NRC organizations regarding operating licensed

facilities to identify and address potential future decommissioning issues (NMSS/FCSS and

NRR). Development of these roles should be derived from the risk-informed approach to

identify operating sites with a high potential for subsurface contamination that will also be

used to revised inspection guidance (see Section 4.2). 

Develop a risk-informed approach to prioritize/manage site decommissioning work

Recommendation 1. (d) in Section 2.0 of Attachment 1 involves developing a risk-informed,

prioritization approach to manage the resources allocated to all site-specific NRC staff

licensing and inspection activities as well as oversight of operating sites. The goal is to

more explicitly consider risk and other decommissioning challenges in allocating an

appropriate amount of resources to specific sites and resolving work priorities. 

The approach would be used in the budget process as well as budget execution to manage

staff expenditure during the operating year and when resource reallocations might be are

needed or management decisions on work priority and staff assignments. 

An initial approach was developed in FY 2004 to support the budget process. 

Implementation of this approach will be revised as appropriate during 

FY 2005 as part of program execution through Operating Plan development and review. 

 5.1.2 Milestones, Schedules, and Assignments

Restructure and coordinate program

Define/implement roles of organizations (Orlando) 09/05

Risk informed prioritization approach for resources (Orlando) 09/05

Update approach developed in FY 04

Train NMSS and Region staff 
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5.2 Implement the new Consolidated Decommissioning Guidance

5.2.1 Description

The approach is to combine a variety of training products such as informal training

sessions/seminars, tailored licensee meetings, a web site giving case studies and

lessons learned, and a stakeholder workshop to discuss and share lessons learned. 

Initial staff training on the new guidance in NUREG-1757 was completed for NMSS

and Regions during FY 2004. Continuing training with more specific training on dose

modeling and risk informed approaches as well as new LTR guidance as it is

developed will continue during FY 2005-2007. Training staff on new draft guidance

will test the practicality of the guidance for use by staff as well as provide earlier

implementation of LTR Analysis issues. Case studies and lessons learned provide

examples of “best practices” for staff and licensees to follow or adjust for their use. 

The approach also will tailor training and meetings to meet the specific needs of the

staff and licensees at specific decommissioning sites and to emphasize key topics,

including LTR implementation issues from SECY-03-0069 and topics from 

NUREG-1757.

5.2.2 Milestones, Assignments, and Schedules

Staff training

Develop and conduct periodic seminars on selected topics including (Rodriquez)

LTR Analysis and LTC license

Risk-informed performance based approaches

Flexibility and examples

Lessons Learned 

Multi-Agency Radiation Laboratory Protocols (MARLAP)

Develop and conduct training on dose modeling (McKenney) 02/05 05/05

Conduct training for new guidance for LTR Analysis issues 11/05

(Schmidt)

Licensee consultations

Each PM, as part of their ongoing consultations with their licensees, should

determine the need and conduct tailored meetings with licensees for new guidance

and LTR issues important to the licensee 09/05 FY 2006
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Lessons learned web page (Rodriguez/Nalluswami)

Continue to update web page with NRC lessons learned 09/05

Discuss with Agreements States and industry how to collect, preserve, and provide

lessons learned (NRC’s web site or a separate web site) 09/05

5.3 Improve staff skills and efficient utilization 

5.3.1 Description

Improve staff availability in critical disciplines

Reorganization of the Division of Waste Management, reassignment of staff, and

hiring critical skills in health physics was completed during FY 2004 and were major

improvements. Additional full time equivalents (FTE) in FY 2005, primarily for dose

modeling, were approved in the budget process and through signing two

Reimbursable Interagency Agreements with DOE for Risk-Based End States and

Hanford Tank Reviews and as a result of new legislation for Waste Incidental to

Reprocessing. These new activities will provide additional resources to hire dose

modeling staff during FY 2005. Hiring these new staff and training them are the key

improvements planned for FY 2005. In addition, dose modeling training during FY

2005 will extend the review capability of NRC project managers to conduct selected

dose modeling reviews.

Resource tracking process and cost baseline

Develop an FTE expenditure tracking system to compare actual expenditure to

budget FTE. Develop a procedure to review the resulting data in operating plans

reviews and to reallocate resources as priorities change or unbudgeted work

emerges. 

Improve the quality of FTE expended by aligning budget C-3 activities and technical

activity codes (TAC), deleting inactive TAC numbers, and reporting FTE expenditures

from the tracking system to PM s and section chiefs for review. 

Train staff and supervisors on improvements.

Use available historical expenditure data to develop a baseline for costs of

decommissioning complex sites. Using this baseline cost information, explore the

feasibility of a method to measure efficiency and cost effectiveness for

decommissioning sites.

5.3.2 Milestones, schedules, and assignments

Improve staff availability/hire (Persinko, Craig, Gruss, 

Thaggard) 09/05
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Expenditure tracking and cost baseline (Orlando) 09/05

Explore the feasibility of a method to measure efficiency and cost 

effectiveness (Orlando) 09/05

5.4 Expand management performance reviews of all decommissioning site progress

5.4.1 Description

Staff coordinated more in FY 2004 during Decommissioning Board meetings with

Regions and FCSS. Based on this experience, develop procedures to use in

Decommissioning Board meetings , other meetings, and Quarterly Operating Plan

reviews to report/review the progress of work at all decommissioning sites in both

DWMEP/DCD and the Regions. Also report progress at operating sites in FCSS and

Regions, based on the result of FY 2005 work on an approach to identify operating

sites with a high potential of subsurface contamination that could result in future

decommissioning problems (see Section 4.2 above).

5.4.2 Milestones, schedules, and assignments

Develop management progress review procedures 09/05

(Orlando/Nelson)

5.5 Compare and evaluate NRC’s Decommissioning Program

5.5.1 Description

Sharing Information

Use the Decommissioning lessons learned web page developed in FY 2005 (see 5.2)

and work with the Office of State and Tribal Programs (STP) to inform the Agreement

States (AS) about the availability of the web page through discussions at the

stakeholder workshop. Invite the AS to share with NRC their lessons learned

implementing the LTR and possibly add to the web page or possibly work with

Organization of Agreement States (OAS) to establish its own lessons learned web

page. Discuss with STP and AS other methods of sharing information about

decommissioning such as agenda items on OAS calls or meetings to exchange

decommissioning issues or lessons learned or questions about NRC guidance and

LTR analysis issues.

During FY 2004, NRC and DOE completed a reimbursable IA to assist DOE with

implementing its End States approach to cleanup. The purpose of the IA is to share

with DOE NRC’s Risk-Informed, Performance-Based approaches to

decommissioning, learn about DOE’s approach, and exchange information about

common decommissioning issues, such as institutional controls, and realistic

scenarios. Implementing the IA during FY 2005-2006 could provide lessons about

cleanup of very large complex sites.
17

During FY 2004 NRC staff agreed to help organize decommissioning sessions at the

ANS conference in Denver. Sessions on materials decommissioning and legacy

management provide opportunities to seek papers that will address decommissioning

lessons learned to share with both US and international stakeholders. Staff will

continue to plan and conduct the sessions during FY 2005.

Independent Review

During FY 2004, the staff evaluated the potential of using NRC’s Inspector General

(IG) to conduct an independent review of the program and requested the review to be

conducted during FY 2005 in preparation for the PART review scheduled during FY

2006. The IG agreed to conduct a review of the Decommissioning Program and the

staff will provide information requested by the IG. 

Continue ACNW independent review of key issues and develop with ACNW its

suggestion to schedule working group meetings to support its independent reviews of

staff guidance.

5.5.2 Milestones, Schedules, and Assignments

Share lessons learned (Johnson, Rodriguez) 

Notify AS of web page, discuss and recommend other AS information 

sharing 04/05

Share information with DOE by implementing DOE IA 09/05

Organize and conduct decommissioning sessions at 09/05

conferences (WM 05, ANS, etc.) 

Independent review (Johnson)

Obtain IG response to NMSS request for IG review 01/05

Provide input as requested for IG review 09/05

ACNW reviews of draft guidance 06/05

5.6 Revise annual budget output measures

5.6.1 Description

During FY 2004, revised budget output measures for FY 2005-2006 to be key

outcome measures to improve the program. During FY 2005, as part of developing

the budget request, use NRC’s new FY 2004-2009 Strategic Plan and the

Performance Institute’s procedure for developing performance measures to consider

new outcome and output measures for FY 2006.
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5.6.2 Milestones, Schedules, and Assignments

Develop potential new outcome and output measures 

(Orlando/Johnson) 05/05 

5.7 Consider using incentives

5.7.1 Description

During FY 2005, identify and describe recent examples of the use of incentives in the

decommissioning program such as Fansteel, Kiski Valley, and approval of intentional

mixing of soil.

Interview DWMEP project managers to identify potential incentives for their sites.

Evaluate the examples used and potential new incentives to identify options for types

and purpose of incentives as well as criteria for deciding when incentives could be

appropriate. Make recommendations to NMSS management.

5.7.2 Milestones, Schedules, and Assignments

Evaluate and recommend incentives (Widmayer) 09/05

5.8 Integrated Decommissioning Improvement Plan (IDIP) 

5.8.1 Description 

Prepare IDIP (i.e., this document) that describes how the staff plans on implementing

each of the recommendations from the Decommissioning Program Evaluation, the

LTR Analysis recommendations approved by the Commission, and other

improvements. The plan includes a description of each improvement and associated

milestones, schedules, and staff assignments. Schedules and assignments will be

revised as needed during the year and also included in FY 2005 Decommissioning

Operating Plan is prepared. The Operating Plan will be used to track the key

milestones and schedules.

An initial IDIP was prepared in FY 2004. An early revision in FY 2005 was completed

to coordinate schedules and assignments with other decommissioning work when the

FY 2005 Operating Plan was completed. The IDIP will be periodically revised as

needed and late in FY 2005 based on results from the IG review and updated again

in FY 2007 as a result of the OMB PART conducted in FY 2006. Each update will

revise or add improvements resulting from the program assessments as well as the

staff decommissioning experience and lessons during this time period. This iterative

approach to program assessment followed by improvements documents a

commitment for seeking “continuous” improvement of the Decommissioning Program. 

5.8.2 Milestones, schedule, and assignments
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Complete initial IDIP (Johnson) 09/04

Revise initial IDIP based with FY 05 Ops Plan schedules 

(Johnson) 11/04

Revise IDIP based on further planning (Johnson) 03/05

Prepare for OMB PART (Johnson/Orlando) 11/05

Participate in SFPO PART (Johnson)

Develop PART documentation notebook (Johnson)

Develop specific decommissioning PART plan (Johnson/Orlando)

Update IDIP based on IG review (Johnson) 10/05

Update IDIP based on OMB PART review (Johnson) 12/06

5.9 Communication Strategy (Buckley, Nalluswami, Rodriguez)

5.9.1 Description

The staff plans to enhance its communications with all stakeholders involved with the

decommissioning program. During FY 2005, this approach consists of: enhancing

the Annual Update to the Decommissioning Program; enhancing the

Decommissioning Web Page; developing a Decommissioning Brochure; and

conducting periodic stakeholder workshops and meetings.

5.9.2 Milestones, Schedules, and Assignments

Enhance Annual Update (Buckley) 09/05

Enhance the Decommissioning web page (Nalluswami) 09/05

Develop Decommissioning Brochure (Rodriguez) 09/05

Conduct stakeholder workshop (Widmayer) 04/05

6.0 Description of Program Management Improvements from Commission SRM

These improvements resulted from the Commission’s direction in the SRM for the October

2004 annual briefing to the Commission as well as other miscellaneous staff generated

improvements. Approaches for these topics are described below, recognizing that the

scope and specific plans for these items are in a developmental stage.
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6.1 Capture and share lessons learned and best practices (Rodriguez) 

This activity involves identifying approaches for collecting, preserving, and making

available NRC’s decommissioning lessons learned. The activities in this area are

also addressed in sections 5.2 and 5.5 regarding developing a lessons learned web

page, conducting a stakeholder workshop to discuss and obtain lessons learned,

asking for suggestions from States, industry groups, licensees, and interested

stakeholders about exchanging decommissioning lessons learned in the future. 

6.2 Radiological monitoring (McLaughlin)

Guidance will be developed to describe coordination and flexibility in conducting

licensee and NRC (Regions, ORISE) radiological surveys. Also include an overview

of the recently completed MARLAP manual and how it can be use to improve

radiological monitoring and efficiency, planning, and implementation of final status

surveys. Training will also be provided to the staff (see section 5.2).

6.3 Finality of decommissioning process (Widmayer)

This activity involves staff continuing to work with EPA and licensees to implement

the EPA-NRC MOU. In addition, guidance for implementing the MOU will be added

to the Consolidated Decommissioning Guidance in NUREG-1757. The staff also will

consider additional measures to achieve effective finality, such as discussing with

industry the possibility of seeking legislative changes. Discussions will be held with

EPA and suggestions from stakeholders will be obtain at a stakeholder workshop.

6.4 Consistency among State and Federal regulators (Widmayer)

This activity will involve first seeking suggestions from licensees and other

stakeholders at a stakeholder workshop and then considering if guidance in NUREG1757 or other program documents should be added to include approaches for

seeking consistency.

6.5 Enhance guidance on flexibility and institutional controls for restricted use

(Schmidt/Johnson)

Guidance on flexibility in the decommissioning process will be enhanced by

developing the guidance for the following LTR Analysis issues: risk informed graded

approach for institutional controls; on-site disposal approval options; removal of

material after license termination; realistic scenarios; and intentional mixing of soil. 

Thus, no new additional guidance is planned at this time, but the existing guidance

describing flexibility will be enhanced to include how the above issues contribute to

flexibility.

Guidance on institutional controls for restricted use is described in section 4.1 above

and no additional guidance is planned at this time. 
21

7.0 Project Management of IDIP

7.1 Products 

The regulatory and program management improvements will be documented in the

products described below, and Attachment 2 is a matrix that tracks how each

improvement will be documented in one or more of the NRC products.

IDIP and Improvement Status Report

Rulemaking for Preventing Future Legacy Sites

Revised Consolidated Decommissioning Guidance

Revised Inspection/Enforcement Guidance

Decommissioning Operations Manual Sections

Input to Budget and Operating Plan

Communication Strategy

Staff skills

7.2 Assignments

The lead staff assignments for the IDIP products are listed below. Attachment 3

provides a listing of all IDIP staff assignments for DWMEP, NRC supporting offices,

and involvement by other parties such as ACNW and Agreement States. This

includes assignments for each LTR Analysis issue and staff assigned to the program

management improvements.

IDIP Project Management (Johnson)

IDIP and Improvement Status Report (Johnson/Gnugnoli)

Rulemaking for Preventing Future Legacy Sites (Kerr/Fredrichs/Shepherd)

Revised Consolidated Decommissioning Guidance (Schmidt/Banovac)

Revised Inspection/Enforcement Guidance (Shepherd)

Decommissioning Operations Manual Sections (Yin/Kalman)

Inputs to Budget, Operating Plan (Orlando)

Communication Strategy (Buckley/Nalluswami/Rodriquez)
22

Staff skills (Section Chiefs)

7.3 General Schedule of Activities

The general schedule for IDIP activities is summarized below and specific dates are

also given for key milestones. 

December 2004

Initial IDIP 

Team lead assignments

IDIP kickoff meeting

January 2005

Planning guidance and workshop 

Planning LTR issue activities

D Board and DD Counterparts briefings

February 2005

Develop IDIP detailed schedule

Refine IDIP scope of LTR/regulatory and program management improvements

Determine supporting assignments for IDIP team

Workshop plan and location decision

Workshop announcement

Workshop agenda and assignments

March 2005

Revise IDIP

Continue scoping issues and topics with management

Prepare for workshop presentations

Arrange State working group to assist with draft guidance
23

April 2005

Conduct workshop 04/20-21

Prepare draft guidance and ACNW guidance summaries

May 2005

Prepare workshop summary

Draft guidance summaries to ACNW 05/31

June 2005

ACNW review/working group meeting 06/15-17

July 2005

Draft guidance for management review 07/14

August 2005

Draft Improvement Summary Report for 

management review 08/31

September 2005

Complete all scheduled program management improvements

and update Operations Manual for improvements 09/30

Draft guidance release for public comment 09/30

October 2005

Final Improvement Summary Report to support

 Annual Commission Briefing and Annual Update

Revise IDIP based on IG review

7.4 Budget, Resource Estimates, and TAC numbers

Current budget estimates and TAC numbers are given in Attachment 4.
24

ATTACHMENT 1

LTR ANALYSIS AND PROGRAM EVALUATION RECOMMENDATIONS

The full text of the recommendations from both the LTR Analysis and the Decommissioning

Program Evaluation are provided in this attachment as a convenient reference for those using

the IDIP.

1.0 LTR Analysis Recommendations from SECY-03-0069, Attachment 10

Restricted Release/Alternate Criteria and Institutional Control

1.1. Clarify the existing risk-informed graded approach for restricting use. Implement with

revised guidance and a Regulatory Issue Summary (RIS).

1.2. Emphasize the availability of the option for restricting use with layered and redundant

institutional controls with a independent third party that is also responsible for one of

the institutional controls. Implement with revised guidance and a RIS.

1.3. Add a new option for restricting use by U. S. Nuclear Regulatory Commission (NRC)

monitoring and enforcement of institutional controls, after license termination using

either the regulation or legal agreement. Implement with revised guidance (that

includes a model restrictive covenant) and a RIS.

1.4. Add a new option for restricting use by an NRC possession- only specific license. 

Implement with revised guidance and a RIS. 

1.5 Note that the staff plans on continuing to monitor the U. S. Department of Energy’s

(DOE’s) Long-Term Stewardship Program changes and reevaluate the potential for

restricting use through future site transfers to DOE under the Nuclear Waste Policy

Act, section151(b).

1.6 Note that the staff plans on continuing to monitor and participate, where beneficial to

the staff, with cooperative, interagency activities to share information and develop

solutions to long-term stewardship/institutional control issues (e.g., Environmental

Council of States Long-Term Stewardship Subcommittee, DOE Long-Term

Stewardship Roadmap development).

1.7 Note that the staff will continue to explore with licensees the use of the recommended

approaches for restricted release, pending the Commission’s deliberations. The staff

will inform the Commission if a licensee is willing to adopt any of these approaches. 

In addition, if the Commission approves one or more of the options, the staff will seek

to implement the option(s) in advance of the RIS and guidance, if it will further the

decommissioning process.
25

Relationship between LTR Release Limits and Other Release Limits

Unimportant Quantities under 10 CFR 40.13(a)

2.1 As the elimination or resolution of inconsistency between the LTR and 

10 CFR 40.13(a) is not a current possibility, the staff recommends clarifying that 

10 CFR 40.13(a) should not be used as a decommissioning criterion. Implement 

with a RIS.

Appropriateness of Developing a Separate Unrestricted Release Standard for Uranium 

and Thorium

3.1 The staff acknowledges that there are some significant inconsistencies in the

potential exposures allowed between 10 CFR 20.1402 and other regulations in 10

CFR Part 40. Although the staff is reevaluating some of these 10 CFR Part 40

regulations, the staff does not believe that they are applicable as unrestricted release

criteria for source material specific licensees.

3.2 The staff has also found that there are only a limited number of existing source

material sites that have not already sought unrestricted release that may find it

necessary to cleanup to requirements other than those in 10 CFR 20.1402. If NRC

jurisdiction of non-purposefully-used uranium and thorium is transferred to other

agencies, as discussed in the JWG’s paper, the number of existing NRC and

Agreement State source material sites licensed under the AEA, and potential future

licensees, would be further reduced. However, because the staff believes that it may

be necessary to retain the SDMP/complex decommissioning sites under NRC

jurisdiction, the recommendation of the JWG will not result in a significant reduction in

the number of overall sites that would benefit from a separate unrestricted standard.

3.3 In summary, the staff believes that the opportunity provided by the existing LTR

allows complex source material sites the flexibility to reduce burden through a graded

approach (unrestricted use to restricted use to alternate criteria) that can be based on

risk. Continued use of the LTR would also maintain 10 CFR 20.1402 as an

unrestricted release standard for source material sites that are not so complex so that

public confidence is not impacted. As a result, the staff believes that given the

flexibility in the existing regulations in 10 CFR 20.1402, 20.1403, and 20.1404,and in

conjunction with the limited number of sites that may require cleanup to criteria other

than those in 10 CFR 20.1402, it is not appropriate at this time to develop a separate

unrestricted release standard for source material licensees. This issue should be

discussed in a RIS.

On-Site Disposal under 10 CFR 20.2002

4.1 Continue the current practice of approving on-site disposals with a dose criterion of a

“few millirem.” This is consistent with staff’s goal of preventing future legacy sites,

and not unnecessarily creating restricted release sites. This option should be

implemented with revised guidance and a Regulatory Issue Summary.
26

4.2 Permit burial requests with a dose criterion of 1 mSv/yr (100 mrem/yr), as long as

such requests are approved contingent on providing additional financial assurance to

cover the cost of decommissioning the burial site for license termination. The

additional financial assurance satisfies staff's concern with preventing future legacy

sites, while leaving this option available provides licensees with maximum flexibility

under the existing regulation. Note that this issue is addressed in Attachment 7 as an

indicator of the need for increased financial assurance.

Controlling the Disposition of Solid Materials (renamed in IDIP as “removal of material 

after license termination”)

5.1 Describe the relationship between the LTR’s unrestricted-release dose constraint and

the existing case-by-case approach for controlling the disposition of solid materials. 

The staff’s qualitative judgment, at this time, is that the LTR is protective of public

health if materials are removed from a site after license termination for unrestricted

use, mainly due to the conservatism in the LTR technical basis and current dosemodeling assumptions, ALARA considerations, and the effects of mixing when

residual radioactivity is moved to other locations. This should be clarified in a

Regulatory Issue Summary.

5.2 Note that insights from the ongoing technical development associated with the

rulemaking effort on controlling the disposition of solid materials can be used in the

development of a rationale to further explain the relationship between criteria in the

LTR and those for controlling the disposition of solid materials, and support the

current view that the LTR is protective of offsite releases after license termination for

unrestricted use.

Realistic Exposure Scenarios

6.1 Clarify that more realistic exposure scenarios can be justified by licensees assuming

reasonable foreseeable (e.g., a few decades and possibly up to 100 years) land use

for the 1,000 year analysis time period. Implement in revised guidance and a RIS.

6.2 Note that the staff will provide to the Commission cases that may implement this

approach in the near future for the AAR, Cabot-Revere, Michigan Department of

Natural Resources, and Fansteel sites. In addition, if the Commission approves the

recommended opinion, the staff will seek to implement the option in advance of the

RIS and guidance, if it will further the decommissioning process.

6.3 Tthe staff continues to be committed to improving the other technical areas of dose

modeling for decommissioning. These include improving the guidance, pursuing

computer model improvements and development, and improving the state of

knowledge on individual parameters and processes involved.

Measures to Prevent Future Legacy Sites

Changes to Financial Assurance
27

Initial Underestimation of Decommissioning Cost:

7.1 Revise regulation to provide for NRC approval of the decommissioning funding plan

(DFP) and to require licensees to provide a DFP and financial assurance based on

unrestricted release. Provide existing licensees with the option to provide financial

assurance for restricted release if the licensee submits and receives NRC approval of

a decommissioning plan (DP) demonstrating its ability to meet restricted use criteria,

or alternatively, if the licensee implements institutional controls and obtains third party

oversight for a restricted release. Implement with a rulemaking, new guidance, and a

RIS.

Operational Indicators of Increasing Costs

7.2 Revise regulation to require a licensee to re-evaluate its decommissioning cost

estimate, and, if necessary, provide additional financial assurance to cover higher

costs, within a reasonable time after an operational event that indicates a potential for

increasing decommissioning costs. Operational indicators would include: spills and

spread of contamination, groundwater contamination, and other events. Implement

with a rulemaking, new guidance, and a RIS.

7.3 Revise regulation, for sites with large radioactive material throughput or liquid

processes, to require licensee to periodically obtain subsurface soil and groundwater

contamination data to update its decommissioning cost estimate. Implement with a

rulemaking, new guidance, and a RIS.

Unavailability of Funds in Bankruptcy Where Financial Assurance Is Provided by Parent

Company or Self-guarantee

7.4 Request comments on options under consideration for changing the parent company

and self-guarantee mechanisms in a notice of proposed rulemaking, beyond the

option in 7.6. Implement in the Federal Register Notice of a proposed rulemaking

and a RIS.

Inadequate Financial Disclosure

7.5 Revise regulation to require licensee with a parent or self-guarantee to provide

additional certification that its financial statements do not omit off-balance sheet

liabilities that would prevent it from meeting the financial test. Implement with a

rulemaking, new guidance, and a RIS.

Reaching Assets after Corporate Reorganization If Financial Assurance Proves Inadequate

7.6 Revise regulation to require licensees to provide NRC with agreements that allow

NRC to hold parent companies and subsidiaries liable for decommissioning costs. As

part of the rulemaking, consider requiring the parent company of licensee

subsidiaries to be a co-licensee. Implement with a rulemaking, new guidance, and a

RIS.
28

 Investment Losses Reduce Trust Account Balance

7.7 Where decommissioning funds are held in investments that may suffer market

losses, revise regulation to require licensee to perform periodic comparison of actual

amount of funds in trust to its decommissioning funding requirement, make up any

shortfall, and report the funding addition to NRC. Implement in a rulemaking, new

guidance, and a RIS.

Accidental Release Increases Decommissioning Cost

7.8 Revise regulation to require certain licensees to obtain onsite property damage

insurance to cover the cost of cleaning up accidental releases. Implement in a

rulemaking, new guidance, and a RIS.

Changes in Licensee Operations

Chronic Releases

8.1 Revise requirement (10 CFR 20.1406) to remove the “other than renewals”

statement, so that both current licensees and new applicants are required to design

and operate facilities to minimize contamination. For existing licensees, the

emphasis should be on procedural changes. Physical changes to the facility should

be made only when procedures fail to reduce releases. There should be a cost-riskbenefit analysis evaluating effects of potential contamination. For example,

contamination that impacts groundwater could migrate through large volumes of the

subsurface, and potentially beyond the site boundary. This would result in a large

cost to remediate, that could be avoided by an investment in prevention. Implement

in a rulemaking, revised guidance, and a RIS.

8.2 Increase emphasis on the potential for enforcement sanctions for non-compliance

with the requirements related to surveys and monitoring, records of operational and

environmental releases, reporting, etc. (i.e., 10 CFR Sections 20.1500, 20.2100,

20.2200, and 40.36). Take enforcement actions, as appropriate, to better focus

licensee response to environmental contamination problems resulting from such noncompliance. Implement in revised enforcement guidance and a RIS.

Reporting Deficiencies

8.3 Develop a risk-informed approach that includes requiring definition of sites with “high

risk” of subsurface contamination as those with large volumes of long-lived

radionuclides, large throughput, or liquid processes. Implement in a rulemaking,

revised guidance, and a RIS.

8.4 Implement the risk-informed approach (Recommendation 8.3) to require specific

monitoring and reporting programs including subsurface characterization, monitoring,

and reporting under two conditions:
29

1) For sites with “high risk”, at license application or renewal, a minimum plan to

define and monitor the subsurface (e.g., three to five wells to identify geologic and

hydrologic characteristics of the site), and an annual report of the concentrations

of contaminants of concern;

2) For all sites, on experiencing events(s) that contaminate the subsurface, an

expanded monitoring and reporting program that adds wells to fully characterize

the extent and migration of resultant plume(s), and more frequent monitoring and

reporting, approximately quarterly. This would be done in conjunction with

financial assurance requirements. Implement in a rulemaking, revised guidance,

and RIS.

8.5 Implement the risk-informed approach (Recommendation 8.3) to increase NRC’s

inspection focus on sites with “high risk” of environmental contamination concerns by: 

1) Increasing inspector qualifications in hydrology, geology, etc.; 

2) Increasing inspections and inspector evaluations of record keeping requirements

[i.e., 10 CFR 20.1501 (Surveys and Monitoring); 10 CFR 20.2103 (Records of

Surveys); 10 CFR 20.2203 (Reports of radioactive material exceeding constraints

or limits)]; 

3) Increasing inspections and inspector evaluations of record keeping requirements

of 10 CFR 40.36 and others to identify potential problems early; and

4) Modifying Manual Chapter 2600, to include performance- and risk-informed

evaluations, using those in Manual Chapter 2500 as examples. 

Implement in revised inspection procedures and a RIS.

2.0 LTR Analysis Recommendations from SECY-04-0035

 

The use of Intentional Mixing of Contaminated Soil

Allow intentional mixing to meet LTR release criteria in limited circumstances, on a caseby-case basis, while continuing the current practice of allowing intentional mixing for

meeting waste acceptance criteria at off-site disposal facilities and for limited waste

disposals.

3.0 Decommissioning Program Evaluation Recommendations

1. Establish a Comprehensive Decommissioning Program Perspective

a) Redefine the objectives and scope of the Decommissioning Program for all

decommissioning sites and subsume the SDMP sites.
30

b) Redefine the roles of organizations involved with the Comprehensive

Decommissioning Program (DWMEP, Regions, other NRC Divisions, Commission). 

No longer require Commission approval role for removing sites from the SDMP list.

c) Consider centralizing DP project management and review for complex materials sites.

d) Define and manage all decommissioning sites using a graded approach to prioritize,

allocate, and track both licensing and inspection activities and resources in both

Headquarters and all the Regions. The graded approach could be based on sitespecific risk insights and decommissioning challenges (see types of licensee and

external challenges identified in section 4.2.2).

2. Implement the new Consolidated Decommissioning Guidance tailored to staff and

licensee needs. Emphasize key topics such as using flexibility, risk informed pproaches,

and realistic dose modeling (PART Q 4.RG1)

a) Develop case histories and lessons learned as examples of flexibility, risk informed

approaches, realistic dose modeling, and prioritization of sites/activities using risk;

b) Train staff in DWMEP, Regions, other divisions on the Consolidated Guidance and

key topics tailored to their decommissioning roles, sites, and decommissioning

phase. Share lessons learned and case studies for implementing the guidance at

specific sites, especially for issues cross cutting many sites (realistic scenarios,

restricted release, engineered barriers, use of risk insights):

c) Conduct frequent and in-depth consultations with individual licensees to implement

guidance and share lessons learned/case studies tailored to specific sites.

d) Establish a Decommissioning Lessons Learned Page on the Decommission Web site

to share among all licensees site-specific lessons learned; issues, and example case

studies.

3. Improve staff availability and efficient utilization 

a) Reorganize/reassign/add staff so that the Decommissioning Program and specific

sites have sufficient resources, especially for critical disciplines (e.g., health physics,

dose modeling, hydrogeology)

b) Improve the resource tracking process and system to allocate budgeted resources

and then track actual staff resource expenditures for individual sites/projects. Use

the new process to support management decisions to reallocate resource loading to

respond to emerging issues, changing licensee schedules, and approved unbudgeted

work. (PART Q 3.4, 4.3)

c) Establish a baseline for decommissioning costs for specific sites and explore the

feasibility of a method to measure efficiency and cost effectiveness (PART Q 3.4,

4.3)
31

4. Expand management reviews of all decommissioning sites among all NRC

organizations involved with existing and future decommissioning (PART Q 3.1)

a) Coordinate and review information from Headquarters and Regions for existing

decommissioning sites to monitor progress, consistency, and efficiency of resolving 

common policy and technical issues

b) Coordinate and review information with currently operating licensed sites to identify

and resolve conditions or events that could complicate future decommissioning 

5. Compare and evaluate NRC’s Decommissioning Program to similar programs (PART Q

2.6, 4.4, 4.5)

a) Share decommissioning lessons learned among NRC and Agreement States.
32

ATTACHMENT 2: INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN: IMPROVEMENTS AND PRO

IMPROVEMENTS PLANNED PRODUCTSStrategic Plan Goals S–safety O–openness E–effectiveness  M–management

Improvement Summary Report9/05

Rulemaking9/06 P 9/07 F

ConsolidatedDecomGuidance9/05 D9/06 F

Inspection/EnforcementGuidance9/05 scope9/06 D, 9/07 F

OperationsManual9/05

CommunicationStrategy9/05

Budget/Operating Pla

RegulatoryImprovements1. Institutional Controls SE

U U

2.UnimportantQuantities E

U

3.Separate Standard U,Th E

U

4.On-site Disposal SE 

U U

5.Removal of Material E U

U

6.RealisticScenarios SE U

U

7.Financial Assurance SEChanges

U UU

8.OperationalChanges SE

U U

U

U

9.IntentionalMixing E U

U
33

IMPROVEMENTS PLANNED PRODUCTS

Improvement Summary Report

Rulemaking Consolidated

Guidance

Inspection/EnforcementGuidance

Operations Manual

Communication

Strategy

Budget/Operating Pla

ProgramManagementImprovements1.Comprehensive Program –roles,prioritization EM

U U U

2. ImplementGuidance–training,licensee meetings EM

U

3.Critical SkillsAvailability, ResourceTracking EM

U U U 

4.Expand Management EMReviews

U U

5.Compare,Evaluate EMProgram

U U

6.Revise ProgramMeasures M

U U

7.ConsiderIncentives E

U

8.ImprovementPlan EM U

U

9.Lessons Learned EMO

U U 

10.Rad MonitoringCoordination E

U
34

11.Finality/State Consistency E

U U

12. Enhance guidanceon flexibility andinstitutional controls  E

U U

13. CommunicationEnhancements–webpage, brochure,annual update EO

U U U
35

ATTACHMENT 3: INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN: IMPROVEMENTS AND ASS

IMPROVEMENTS ASSIGNMENTSStrategic Plan Goals S–safety O–openness E–effectiveness  M–management

DWMEP Lead DWMEP Support Other NRC Support NRC Technical

Review 

NRC Legal Review 

RegulatoryImprovements

Johnson

Consolidated Guidance Schmidt/BanovacInstitutional Controls SE

Johnson Banovac

Esh

FCSS VonTillRES

DWMEP KennedyFCSS VonTill

Smith 

Intentional Mixing  E

Widmayer Smith 

On-site Disposal SE 

Youngblood NRR Klementowicz Smith 

Removal of Material E

Schmidt Buckley Smith 

RealisticScenarios SE

McKenney Thaggard Smith 

Inspection and EnforcementGuidance

Shepherd 

Operational Changes SE 

Shepherd McKenney

PeckenpaughNalluswami, Brown

NRRFCSSRegions

Smith 

Rulemaking Kerr IMNSFinancialAssurance SE Frederichs NRC contractor SmithOperationalChanges SE

Shepherd NRR Issacs

FCSS

Smith
36

IMPROVEMENTS PLANNED PRODUCTS

DWMEP Lead DWMEP Support Other NRC Support NRC Technical

Review

NRC Legal Review 

ProgramManagementImprovements

Johnson

1.Comprehensive Program –roles, prioritization  EM

Orlando Johnson Regions

2. ImplementGuidance–training, licenseemeetings EM

Rodriguez Schmidt

PersinkoCraigGruss,ThaggardMcKenney

3.Critical SkillsAvailability, Resource Tracking  EM

Section ChiefsOrlando

4.Expand Management EMReviews

Orlando Nelson

5.Compare,Evaluate EMProgram

Johnson Rodriguez

6.Revise ProgramMeasures M

Orlando Johnson Whited

7.ConsiderIncentives E

Widmayer

8.ImprovementPlan EM 

Johnson

9.Lessons Learned EMO

Rodriguez Nalluswami OIS

10.Rad MonitoringCoordination E

McLaughlin Boby Abu-Eid ORISE contract
37

IMPROVEMENTS PLANNED PRODUCTS

DWMEP Lead DWMEP Support Other NRC Support NRC Technical

Review

NRC Legal Review 

11.Finality/State Consistency E

Widmayer

12. Enhance guidance onflexibility and institutionalcontrols E

Schmidt Johnson

13. CommunicationEnhancements–webpage, brochure, annual update  EO

RodriguezNalluswamiBuckley

OIS 
38

ATTACHMENT 4: IDIP BUDGET AND RESOURCE TRACKING/TAC NUMBERS 

Planned accomplishment: 355260 Materials and Fuel Cycle Decommissioning Licensing ActionsSub PA: 355260M Policy and Issue ResolutionIntegrated Decommissioning Improvement Plan (IDIP) Activities 

Title of Activity

Other sub activities

TAC number Budget

FY05

BudgetFY06

BudgetFY07

Assigned 

IDIP Project Management IDIP project management L60612 Robert JoLTR RegulatoryImprovements

3.0/150K 2.0/100K 1.0/50K

Proposed rulemaking/guidanceReduce likelihood of funding shortfalls fordecommissioning under the licensetermination rule

Changes to financial assuranceChanges to licensee operations

LA0056 1.4/150K 1.3/100K Leslie Ke

Tom FredJim Shep

Final rulemaking/guidanceReduce likelihood of funding shortfalls fordecommissioning under the licensetermination rule

LA0057 0.7/50 same as 

Draft Decommissioning guidanceResolve LTR implementation issues

Institutional controls/restricted use/POLOn-site disposalsRemoval of material Realistic scenariosIntentional mixing of soilOther

LA0086 1.2/0K

Duane SKris BanoRobert JoDave EshJohn PecSam NalTom YouJohn BucChris McDerek W
39

Integrated Decommissioning Improvement Plan (IDIP) Activities 

Title of Activity TAC number Budget

FY05

BudgetFY06

BudgetFY07

Assigned 

Final Decommissioning guidanceResolve LTR implementation issues

LA0087 0.7/0K 0.3/0K same as 

Revised inspection and enforcement guidance LA0088 0.4/0K Jim Shep

Chris McRobert JoDave Bro

Program ManagementImprovements

LA0089 0.8 (1.5) 1.3 TBD

Program management improvements

Comprehensive program implementationGuidance implementation/trainingCritical skillsExpand management reviewsCompare, evaluate programRevise program measuresConsider incentivesImprovement planLessons learnedRad monitoring coordinationFinalityState consistencyCommunication strategy

Robert JoNick OrlaDave NeRafael RDuane SChris McKris BanoSam NalGiorgio GDerek WTom McLBoby Abu

Prepare for Decommissioning PART LA0090 Robert Jo

Nick OrlaJohn Buc
40

Conduct Decommissioning PART LA0091 Robert Jo

Nick OrlaJohn Buc