International Decommissioning Regulatory Initiatives and U.S. Nuclear Regulatory Commission Involvement 

Giorgio N. Gnugnoli 

U.S. Nuclear Regulatory Commission, 11545 Rockville Pike, Rockville, Maryland 20852-2738, gng@nrc.gov

Abstract – The U.S. Nuclear Regulatory Commission (NRC) plays a significant international role with respect to the 

decommissioning of nuclear facilities. In its international involvement, NRC has participated in technical and regulatory 

information exchanges, assisted in writing international safety guidance documents, and advocated positions that it felt were 

in the best interest of all parties in the international community. 

The primary international organizations with which the NRC interacts in decommissioning topics are the International 

Atomic Energy Agency (IAEA) and the Nuclear Energy Agency (NEA). Some examples of the NRC’s involvement with these 

organizations include the IAEA Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive 

Waste Management (Joint Convention) and the NEA’s Working Party on Decommissioning and Dismantling (WPDD). Both 

of these activities include cooperation with the U.S. Environmental Protection Agency (EPA) and the U.S. Department of 

Energy (DOE). 

In the case of the Joint Convention, this is an official international treaty. As such, a major part of the NRC’s activities 

is the peer review process of other ratifying states’ radiological waste safety programs. The preparation of the National 

Report addressing the U.S. program for civilian spent fuel and radioactive waste management, including decommissioning, 

is a major undertaking by the NRC, DOE and the EPA. 

With respect to decommissioning, the approaches and organizational strategies vary from organization to organization, 

and from country to country, but the fundamental criteria tend to be sufficiently comparable when evaluating progress in the 

diverse international decommissioning activities. By working with the international community on this matter, the NRC 

provided the benefit of its experience in active decommissioning and preserved flexibility within the U.S. decommissioning 

regime by dissuading the adoption of overly prescriptive approaches to decommissioning. 

The NRC has been actively involved in the preparation of international safety standards and guidance in the area of 

decommissioning. Examples of publications on this topic include: WS-R-3 Remediation of Areas Contaminated by Past 

Activities and Accidents and DS332 Release of Sites from Regulatory Control upon Termination of Practices (draft). 

The NRC also has arrangements with many foreign countries which include import/export, expert advice, information 

exchanges, and site visits. These are done on bilateral and on multi-lateral bases. NRC has had a longstanding, biannual 

exchange with its French counterpart. Specific issues include polluted sites, which are equivalent to NORM sites. 

Perspectives regarding the implications of the Joint Convention’s triennial review meetings were also exchanged. Similar 

exchanges have been conducted with the United Kingdom, Japan, Taiwan, and Spain. 

The primary multi-lateral exchange involving the NRC is with Mexico and Canada. Decommissioning is the usual waste 

management topic. Recent meetings addressed decommissioning experience and regulatory developments and the Joint 

Convention. 

Topics that are discussed with the international community include the feasibility of regional waste repositories and the 

impacts of the ICRP recommendations on restoration of contaminated sites. 

I. INTRODUCTION 

The NRC is actively engaged with the international 

community to achieve the following decommissioning 

objectives: 

a. Ensure the dissemination of information on 

approaches and techniques to achieve 

decommissioning through the sharing and 

transfer of technology and experience. 

b. Establish realistic, risk-informed goals for 

decommissioning, as well as performance 

based implementation of such goals. 
c. Ensure U.S. security by encouraging and

supporting accountability of materials that 

result from decommissioning. An example 

is the cooperation with the DOE’s foreign

research reactor fuel take back program.

 There are a number of initiatives dedicated to

enhance safeguards in the international “nuclear” 

community. The NRC’s international activities provide 

an overall strategy, which is compatible with these other 

specific programs to account for radioactive materials that 

are approaching the end of their usefulness in peaceful 

applications throughout the world. Additionally, the U.S. 

benefits from the experience of others that may have had

to deal with facility cleanups and other decommissioning

considerations. By participating in international activities, 

the NRC is able to put forth its own approach and policy 

that, to some degree, affects international approaches and 

policies. 

II. NRC’S INTERNATIONAL PROGRAM

ACTIVITIES RELATING TO DECOMMISSIONING

The NRC maintains expertise in the area of 

commercial application of nuclear energy and materials. 

The NRC’s Office of International Programs (OIP) is 

responsible for overall coordination of NRC's 

international activities. [1] OIP plans, develops and

implements programs, in concert with other NRC offices, 

to carry out policies in the international arena, including

export and import licensing responsibilities. It also

establishes and maintains working relationships with

individual countries and international nuclear 

organizations. Some of the interactions require liaison

with the U.S. State Department; which maintains points of 

contact with U.S. Missions overseas. 

II.A. Individual Country Interactions

The most basic level of international activity is on a 

country to country basis; i.e., bilateral exchanges. The 

NRC has historically encouraged such opportunities over 

the years. Programs involving mixed-oxide fuels with

Russia and the disposition of solid materials with Japan

and France have lead to a common understanding in 

dealing with these issues.

II.B. International Organizations 

On a higher level are the formal interactions with the 

International Atomic Energy Agency (IAEA), the Nuclear 

Energy Agency (NEA), and to some limited extent the 

European Commission. Representatives of the U.S. 

Government; i.e., experts from NRC, DOE, and EPA, 

participate in drafting guidance documents, reviewing 

IAEA publications, performing peer reviews, and 

reviewing Member States programs as part of the IAEA’s 

Technical Co-operation Program. Although many such

activities are done on an ad hoc basis, some standing 

venues exist. These include:

II.B.1. International Atomic Energy Agency 

Although there are other IAEA safety standards 

committees, decommissioning is primarily within the 

scope of the Waste Safety Standards Committee 

(WASSC). This committee meets twice per year (in the 

Spring and the Fall) to endorse action plans and review 

and approve IAEA safety standards series documents. 

The NRC’s Division of Waste Management and 

Environmental Protection (DWMEP) has been the U.S.

representative to this committee in recent years. 

Documents reviewed within WASSC have significant

impacts on many Member States, which use the standards 

as their own national criteria for regulating

decommissioning, as well as other parts of the nuclear 

fuel cycle. 

When standards are approved at the WASSC level, 

they are submitted to the Commission on Safety 

Standards (CSS), which compares and objectively 

reviews the standards provided by the WASSC and its

sister committees. See Fig 1. 

CSS

Commission on 

Safety

Standards

NUSSC

Nuclear 

Safety

Standards

Committee

RASSC

Radiation 

Safety

Standards

Committee

TrRANSSC

Transport

Safety

Standards

Committee

WASSC

Waste

Safety

Standards

Committee

Fig. 1. IAEA Advisory Committees 

The approved standards then are passed along to the 

higher diplomatic bodies of the IAEA, such as the 

General Conference and the Board of Governors. Within

this framework, Member States are provided drafts of the 

documents, for their review and comment, prior to the 

official publication. These documents are not generally

mandatory for any Member State, but serve the purpose of 

a good point of reference to use in their own national

program. However, if a Member State is receiving 

technical assistance from the IAEA, then it is bound to 
accept these IAEA standards within its own regulatory 

system. 

The IAEA Member States are refining the regulatory 

approach in the IAEA safety standards to disengage 

decommissioning from the present perspective of 

considering it as a part of predisposal management. The 

current safety requirement, Safety Standards Series No. 

WS-R-2 Predisposal Management of Radioactive Waste, 

Including Decommissioning will be revised to generate a 

new safety requirement on decommissioning, now under 

preparation as DS-333 Decommissioning of Nuclear 

Facilities. A related Safety Guide DS-332 addresses 

release of sites from regulatory control upon termination 

of practices. However, it should be noted that the IAEA, 

like many individual Member States, treat land or site 

cleanup, referred to as Rehabilitation of Contaminated 

Areas, under its own separate safety requirement: Safety 

Standards Series No. WS-R-3 Remediation of Areas 

Contaminated by Past Activities and Accidents.

Additional information about the IAEA’s Safety 

Standards program on all safety topical areas, including 

decommissioning and clearance can be found at URL: 

http://www-ns.iaea.org/standards/

 

II.B.2. Nuclear Energy Agency 

The Organization for Economic Development and 

Cooperation has a suborganization, which is the Nuclear 

Energy Agency. Much of the NRC interaction with the 

NEA on decommissioning is focused within the 

Radioactive Waste Management Committee (RWMC), 

which is currently chaired by the Deputy Director of the 

NRC Office of Nuclear Material Safety and Safeguards. 

The RWMC continues to review and direct the NEA work 

in the area of radioactive waste management, including 

the activities of three working parties under its purview, 

i.e., the Integration Group for the Safety Case (IGSC), the 

Forum on Stakeholder Confidence (FSC), and the 

Working Party on Management of Materials from 

Decommissioning and Dismantling (WPDD). The 

WPDD operates at the policy and regulatory level and 

complements the technical work of the International Cooperative Programme for the Exchange of Scientific and 

Technical Information Concerning Nuclear Installation 

Decommissioning Programmes (CPD). The CPD 

provides a forum for ensuring that safe, economic, and 

environmentally-protective options for decommissioning 

are employed. The CPD also reports to the RWMC, but 

does not involve site projects in the USA. [2] Most of the 

NRC’s activities involving decommissioning in the NEA 

context are related to annual meetings and specialized 

workshops. The NEA publishes the proceedings and the 

brochures produced during these exchanges, as an aid to 

its Member States seeking to maintain or improve their 

decommissioning regulatory systems. These proceedings 

are usually joint publications with the IAEA, the NEA 

and other organizations, such as the European 

Commission. [3] 

II.C. Specific Examples of NRC’s International Program 

Activities Relating To Decommissioning

Examples of the NRC’s international involvements 

include the Joint Convention on the Safety of Spent Fuel 

Management and on the Safety of Radioactive Waste 

Management (Joint Convention), and bilateral and other 

exchanges. 

II.C.1. Joint Convention 

The Joint Convention is a treaty between the IAEA 

and Member States, which requires ratification at the 

highest national level. The 2 main foci of the Joint 

Convention are 1) the preparation of the national report 

and 2) the active participation in the review process. The 

next revision of the national report is due in October 

2005, and the review meeting is scheduled in May 2006. 

It was initiated as an outgrowth of the Convention on 

Nuclear Safety for nuclear power plants. The United 

States of America ratified the Joint Convention in May of 

2003, and participated in the first national report review 

meeting held in November 2003. Thirty three Member 

States had ratified the Joint Convention and participated 

in a review meeting, which consisted of separate sessions 

in which each ratifier’s national spent fuel and radioactive 

waste management programs were reviewed in detail. 

The overall process and experience was considered a 

success; however, there are 138 Member States, and many 

significant ones have not yet ratified the Joint 

Convention, including Russia, the People’s Republic of 

China, and India. In fact, only 1 Latin American country 

(Argentina), 2 Asian countries (Japan, and the Republic of 

Korea) and 1 African country (Morocco) have ratified so 

far. This leaves the Joint Convention as mostly a North 

American and European enterprise. 

The IAEA and the ratifying Member States have 

acknowledged this shortcoming and are planning a series 

of regional workshops in the under-represented 

continents. Expert assistance in setting up safety 

regulatory infrastructures, as well as assistance in the 

form of technology and resources, is planned as part of 

this promotional strategy. 

The national report process consists of textual 

presentation of a ratifying country’s national program for 

spent fuel and radioactive waste management. Defense 

and NORM wastes are excluded, unless voluntarily 

provided by that country. Information on active 

decommissioning, waste disposal and storage, and 
management of disused sealed sources are required as part 

of the reporting process. The first U.S. National Report 

can be accessed at: 

http://web.em.doe.gov/integrat/National_Report_05-02-

03_1.pdf. The combined effort of the DOE, EPA and 

NRC is currently directed to revise the report for 

submittal and consideration during the 2nd review meeting 

in May 2006. The closing plenary from the 1st review 

meeting recommended some improvements and 

clarifications in the next round. [4] Those specifically 

focused on decommissioning include: 

• there was a growing recognition of the need for 

the development and implementation of 

integrated decommissioning and radioactive 

waste management plans; 

• there was the need to make adequate financial 

provision to cover the costs; 

• there was the need to ensure that adequate 

records were kept by the operators, of 

inventories and activities, throughout the 

operating period of the facility; 

• there was the need to incorporate considerations 

of decommissioning into the design of a nuclear 

facility; and 

• provisions are needed for the disposal of waste 

produced in the decommissioning process. 

One of the observations from the meeting was the 

diversity in the manner in which each Member State 

implemented the decommissioning regulatory 

infrastructure. Many countries have a centralized 

authority for dealing with the decommissioning of nuclear 

facilities and practices. The U.S. situation was not typical 

of the mainstream. Under the Atomic Energy Act of 

1954, as amended, decommissioning of materials sites has 

been split between Agreement States and the NRC. The 

Federal relinquishment of licensing authority often 

confuses our international counterparts. This has also 

made the collection and centralization of the data and 

information for the U.S. National Report more of a 

challenge, because the information required by the Joint 

Convention is maintained by numerous entities, some of 

whom are very protective of the information. 

Currently, the EPA, DOE and NRC are preparing the 

U.S. National Report and will be addressing the major 

improvement areas, not only for decommissioning, but 

also for other areas such as emergency preparedness, 

inspection and enforcement, and staffing and human 

resource trends. 

The clear message to most of the Contracting Parties 

was that more needed to be done in the planning, 

implementing and completion of decommissioning in the 

overall national program of nuclear safety. 

It remains to be seen how well the participants in the 

Joint Convention process have taken the message to heart. 

II.C.2. Bilaterials, Trilaterals and Other Exchanges 

The NRC has hosted numerous foreign delegations to 

the U.S. over the years, which have included former 

Soviet Block countries trying to recover from the cold 

war nuclear buildup (not only in weapons, but also in 

power generation and other materials uses). However, 

there are a few relationships that have lasted over a 

number of years. 

These include a bi-annual exchange with the French 

nuclear safety authority, DSIN, which usually covers 

decommissioning topics, such as the DSIN’s extension of 

regulatory authority over “polluted sites,” which refers to 

a class of waste legacy sites. The NRC shared its 

experiences with the West Valley Demonstration Project 

and other Complex Decommissioning Site experiences. 

[6] In fact, the NRC participated in a French workshop in 

May 2004 on decommissioning, which was hosted by the 

Direction Générale de la Sûreté Nucléaire et de la 

Radioprotection - DGSNR. The NRC discussed its 

efforts to evaluate previously licensed sites from uranium 

mills to nuclear reactors to determine if the sites met the 

release criteria in effect at the time of license termination. 

The result was that 42 formerly licensed sites were found 

to have residual contamination levels exceeding USNRC's 

criteria for unrestricted release. The NRC and its 

Agreement States moved to address those sites. [7] NRC 

staff benefited from a site visit to Brennelis, a 73 MWe, 

heavy water reactor undergoing decommissioning. Issues 

such as clearance and recycle, transparency and 

disposition of waste from decommissioning were 

discussed. 

The trilateral between Canada, Mexico and the U.S., 

specifically the NRC, has been useful in the past in 

promoting exchange of information regarding security, 

decommissioning and the impacts of ratification of the 

Joint Convention. To date, Canada and the U.S. have 

ratified and participated in the first round of activities 

associated with the provisions of the Joint Convention. In 

recent exchanges, there has been continued sharing of 

information on decommissioning programs and site 

selection. As a result of our increased security concern, 

more emphasis has been placed on export/import issues, 

radiological material tracking and transportation issues. 

Lastly, the NRC’s Decommissioning Program 

support of the Office of International Programs’ 

workshops in decommissioning has been a successful 

means of disseminating NRC’s decommissioning 

approach to other nations helping to achieve the first 2 
objectives cited in the introduction. In March 2004, the 

NRC provided a decommissioning workshop to the 

Taiwan Atomic Energy Council and Fuel Cycle and 

Materials Administration. In June 2005 a similar 

decommissioning workshop is planned for the Russian 

Rostekhnadzor. The NRC has also recently hosted a 

foreign assignee in decommissioning from the Peoples’ 

Republic of China. 

II.D. Decommissioning and the International Setting 

USNRC regulates (10 CFR Part 20) the 

decommissioning of materials and fuel cycle facilities, 

research and test reactors, and power reactors, with the 

ultimate goal of license termination. The current USNRC 

dosed-based unrestricted release limit is 0.25 mSv/a (25 

mRem/y) (Total Effective Dose Equivalent) to the 

average member of the critical group from all exposure 

pathways and demonstration that the residual 

contamination levels are ALARA. 

However, many other countries use a fraction of 1 

mSv/a (100 mRem/y) to the average member of the 

critical group, but this is the effective dose as cited in the 

International Commission on Radiological Protection 

(ICRP) publications (e.g., Publication 60 and 82). 

Usually 0.3 mSv/a (30 mRem/y) above background as the 

dose constraint for decommissioning or environmental 

rehabilitation of sites is typically used. Other countries 

maintain that the same dose constraint should be applied 

to both release of decommissioned or rehabilitated sites, 

as well as for the control of the disposition of solid 

materials (CDSM) (e.g., recycle of metals and 

equipment. The NRC has espoused a graded approach 

that accounts for the need to reasonably apply scarce 

resources when dealing with small numbers to avert doses 

that lie far below the recommended safe range. [5] 

Another aspect in which the NRC differs from other 

international counterparts, including the IAEA is that 

NRC groups decommissioning and environmental 

rehabilitation together from the regulatory perspective. 

Other countries distinguish between the two, although this 

does not necessarily present a fundamental inconsistency; 

rather an administrative distinction. 

Perhaps the main areas in which NRC has been trying 

to foster some international harmony are in the 

decommissioning versus CDSM topic mentioned 

previously and in the concept of adjusting the baseline 

background for subsequent practices. The NRC has 

cautioned its international counterparts with respect to the 

approach to revise the baseline background, in the case 

that the terminated practice has not been able to return to 

the pre-operational levels. Of course, it is unrealistic to 

expect that the post-operational levels would not reflect 

some degree of residual effect from a terminated practice. 

However, to add this residual contamination to the 

original background to result in a “new” background is of 

concern, as this could lead to a sequence of “adjustments” 

over time, which could very well lead to a resultant 

background much higher than the original one. This 

chain of incremental deterioration is in conflict with the 

applicable NRC regulations as stipulated in 10 CFR Part 

20, Subpart E. 

III. CONCLUSIONS 

The advantages of the international interface 

provided in the area of decommissioning have long been 

recognized by the NRC as a 2-way path. We learn from 

our international counterparts, and we share our 

experiences in likewise fashion. 

In our continued international interactions, we find 

common ground in areas where we still have work to do 

in the specific decommissioning context. These areas 

include: 

• securing adequate institutional controls; 

• complexity of site/dose modeling; 

• influence from diverse stakeholders; and 

• decommissioning funding.

Broader topics, which require national and 

international attention, that also influence 

decommissioning decisions include: 

• feasibility of regional waste repositories;

• impacts of ICRP recommendations on 

rehabilitation of contaminated sites (ICRP 82);

• progress and incentives to initiate 

decommissioning planning early in the life cycle 

of a proposed activity; and

• promoting full participation in the Joint 

Convention process. 

The NRC needs to continue its participation in these 

international venues to preserve our leadership role in 

decommissioning. In this manner, we can promote the 

NRC’s decommissioning approach and benefit from 

others’ decommissioning experiences. 

ACKNOWLEDGMENTS 

Support and advice from colleagues of the NRC’s 

DWMEP have been invaluable in preparation of this 

paper. D. Orlando, A. Persinko and D. Gillen are only a 

few of the DWMEP staff who have provided their 

invaluable perspective and criticism, which have 

immeasurably improved this paper. 
REFERENCES 

1. NRC Website. URL: http://www.nrc.gov/who-weare/organization/oipfuncdesc.html

2. OECD/NEA Website URL: 

http://www.nea.fr/html/rwm/wpdd/

3. Joint NEA/IAEA/EC Workshop on the Regulatory 

Aspects of Decommissioning. Agenzia Nationale per 

la Protezione dell’ Ambiente. Rome, Italy. (19-21 

May, 1991). 

4. IAEA Web site URL: http://wwwns.iaea.org/downloads/rw/conventions/summaryreport-first-rev-meeting-e.pdf

5. NRC Web site URL: 

http://www.nrc.gov/materials/decommissioning/deco

m-sites.html

6. J. GREEVES, D. ORLANDO, J. BUCKLEY, G. 

GNUGNOLI, R. JOHNSON. “NRC’s Program for 

Remediating Polluted Sites.” DGSNR Workshop on 

Polluted Sites. Paris, France. (May 2004) 

7. J. GREEVES, D. ORLANDO, G. GNUGNOLI, 

“Removal of Controls for Decommissioning: A 

Graded Approach.” International Conference on the 

Safe Decommissioning for Nuclear Activities: 

Assuring The Safe Termination of Practices Involving 

Radioactive Materials, Berlin , Germany, 14-18 

October 2002.