INTERIM STAFF GUIDANCE FOR ESTIMATING DECOMMISSIONING COSTS FOR 

URANIUM ENRICHMENT FACILITIES 

Background 

On February 5, 2009, the U.S. Nuclear Regulatory Commission (NRC) was briefed on the status 

of uranium enrichment in the United States by the NRC staff, industry representatives and a 

representative from the New Mexico Environment Department. Transcripts and exhibits from 

the briefing are available to the public at http://www.nrc.gov/reading-rm/doccollections/commission/tr/2009/ or through Agencywide Documents Access and Management 

System (ADAMS) Accession Nos. ML090410464, ML090410578, and ML090370266, 

respectively. 

 

Discussions on decommissioning costs during the February 5, 2009, Commission briefing were 

focused primarily on depleted uranium and the uncertainties associated with its disposal. 

Industry stated that they supported moving forward with rulemaking on depleted uranium in 

order for the licensing process to continue to be predictable and efficient. 

Following the briefing, the Commission directed the staff in a Staff Requirements Memorandum 

(SRM), dated February 17, 2009, to, in part; look for ways to improve the guidance on financial 

assurance for decommissioning as it pertains to estimating decommissioning costs associated 

with uranium enrichment facilities (Meeting SRM M090205, ADAMS Accession No. 

ML090490032). 

Purpose and Scope 

The purpose of this interim staff guidance (ISG) is to provide industry with guidance on 

developing decommissioning costs estimates that are unique to commercially licensed uranium 

enrichment facilities. Cost estimates are needed for determining sufficient financial assurance 

for these facilities as part of a license application. This guidance addresses industry concerns 

and should contribute to a clear and stable regulatory framework and an effective process for 

applicants to follow. The ISG provides an effective method for providing improvements until it 

can be incorporated into existing NRC guidance. Staff intends to add this ISG to its 

decommissioning guidance in NUREG-1757, Volume 3, “Consolidated NMSS Decommissioning 

Guidance – Financial Assurance, Recordkeeping, and Timeliness,” dated September 2003, 

when it is updated in the future. 

The scope of this guidance is limited to ways to improve decommissioning cost estimates, 

specifically, estimating decommissioning costs for uranium enrichment facilities. This scope is 

based on the comments, questions and discussions made during the Commission briefing and 

the Commission SRM directing staff to focus their efforts on uranium enrichment facilities. 

Detailed information on decommissioning cost estimates provided by licensees and/or 

applicants are, for the most part, considered to be company proprietary and/or security related 

information and have historically been withheld from public disclosure. Consequently, cost 

estimates that are discussed in this document have been taken from the publicly available 

versions of uranium enrichment facility applications and contain no sensitive, unclassified, 

classified, or safeguards information. 
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Discussion

 

This section is divided into two topical areas because: (1) the major cost factors for physical 

site decommissioning facilities with low enriched uranium are well established within the 

industry (excluding depleted uranium tails) and constitutes a relatively small portion of the total 

decommissioning costs; and (2) the major cost factors for uranium deconversion and depleted 

uranium disposition is still evolving and constitutes the largest and most important area for 

estimating decommissioning costs. This is illustrated by the breakdown of the $9.2 billion total 

decommissioning costs for the four licensed and/or proposed enrichment facilities (Louisiana 

Energy Services LLC (LES), Areva Enrichment Services LLC (AES), USEC Inc., and GE-Hitachi 

Global Laser Enrichment). Of the total estimated decommissioning cost proposed by these 

entities, $8.1 billion or 88% was associated with de-conversion and dispositioning of the 

uranium tails and only $1.1 billion or 12% was associated with facility decommissioning. 

 

Cost of Facility Decommissioning Excluding Deconversion Costs

A facility decommissioning cost estimate is comprised of three basic parts: (1) a facility 

description that includes a discussion on the extent and nature of contamination at the 

facility; (2) the estimated cost including labor costs, non-labor costs and a contingency 

factor to remediate the facility; and (3) key assumptions used in the cost estimate. 

The principal guidance documents used by staff in their review of decommission cost 

estimates for the purpose of determining adequate financial assurance are found in the 

“References” section at the end of this document. 

Applicants have consistently followed the decommissioning cost estimating format 

detailed in Appendix A of NUREG-1757, Volume 3. The appendix provides information 

on preparing site specific cost estimates with example tables. Although the tables 

shown are universal in nature, applicants have adapted them to their specific needs and 

have been able to take advantage of the modular design of an enrichment facility when 

combined with the universal list of components found in Appendix A Table A.3.5, 

“Number and Dimension of Facility Components.” With the proper supporting 

documentation, the NRC has found this approach to be acceptable when a component 

listed in the table was not present or notated that the total dimensions were not used. 

The applicants have included a 25 percent contingency fee in their cost estimates. The 

NRC has found this to be acceptable for those decommissioning costs associated with 

the facility decommissioning and that the level of detail provided in approved 

applications is consistent with the guidance found in Appendix A, §A.3.1.2.3, NUREG1757, Volume 3. It is recommended that applicants include any supporting 

documentation in instances when it is not possible to provide the level of detail 

requested in Table A.3.5. 

Recently, a few applications for licenses to construct and operate an enrichment facility 

have requested exemption from 10 CFR §§ 40.36(d) and 70.25(e) in order to seek 

approval to ramp up the level of decommissioning funding as the construction of each 

modular production unit is completed rather than fund the entire decommission cost at 

the time of licensing. In other words, the decommissioning funding would increase 

incrementally when a modular production unit came online just prior to the receipt of 
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each shipment of licensed material. Both LES and USEC have obtained approval for 

this approach. The NRC has determined, on a case by case basis, that the approach 

approved for these two specific facilities is reasonable. See In the Matter of USEC Inc, 

(American Centrifuge Plant), ASLBP No. 05-838-01-ML, 65 NRC 429 (2007); see also

NRC staff Approval of Amendment 6 to LES Materials License SNM-2010, ADAMS 

Accession No. ML080530351. It should be noted, as recommended in NUREG-1757, 

Vol. 3, that both of these cost estimates applied a 25 percent contingency factor to the 

grand total (bottom line number) of the cost estimate in order to provide reasonable 

assurance that the decommissioning would be adequately funded. 

Use of Classified Equipment and Information

If classified equipment requires disposition, the applicant should obtain estimates from 

entities knowledgeable in processing classified equipment and/or those records 

necessary for the purposes of decommissioning in accordance with the requirements 

found in 10 CFR Part 95, “Facility Security Clearance and Safe-Guarding of National 

Security Information and Restricted Data.” Also the applicant should provide sufficient 

information in the Decommissioning Funding Plan (DFP) (in a classified section, if 

needed) for the NRC staff to understand the basis for the decommissioning costs. The 

submittal should identify the equipment and the applicable unit processing and labor 

costs for the classified items (including all classified documents). 

 

Cost of Deconversion and Disposal of Depleted Uranium

 

Applicants can use the methods documented in prior licensing proceedings for uranium 

enrichment facility decommissioning and depleted uranium disposition costs. For 

example, one method that has been found to be acceptable is the cost and methodology 

detailed by the Department of Energy (DOE) in a response dated March 1, 2005 to an 

inquiry made by LES. (DOE, 2005). See Louisiana Energy Service, L.P. (National 

Enrichment Facility), CLI-06-22, 64 NRC 37 (2006). As with the costs associated with 

facility decommissioning, a 25 percent contingency factor was applied to the grand total 

(bottom line number) of the cost estimate in order to provide reasonable assurance that 

the decommissioning would be adequately funded. Commercially available cost 

estimates may be acceptable if they are of sufficient detail such that the NRC can 

evaluate their reasonableness. LES’s materials license, SNM-2010, includes a 

requirement to update the DFP prior to startup and to include, at that time, funding that 

would be adequate for dispositioning three years worth of depleted uranium tails. A 

further requirement is that after three years they will provide an annual update that 

includes revised calculations from the DOE for the dispositioning of the depleted 

uranium tails. 
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References 

(DOE, 2005) U.S. Department of Energy (DOE), letter to Louisiana Energy Services, 

“Conversion and Disposal of Depleted Uranium Hexafluoride (DUF6) Generated by Louis 

Energy Services, LP (LES),” March 1, 2005 (ADAMS Accession Nos. ML052910303 and 

ML060030362). 

 (NRC/PNNL, 2002) NUREG/CR-6477 Revised Analyses of Decommissioning Reference NonFuel-Cycle Facilities,” dated December 2002. 

(NRC, 2003) NUREG-1748, “Environmental Review Guidance for Licensing Actions Associated 

with NMSS Programs,” dated August 2003. 

(NRC, 2003) NUREG-1757, Volume 3, “Consolidated NMSS Decommissioning Guidance – 

Financial Assurance, Recordkeeping, and Timeliness,” dated September 2003. 

(NRC, 2005) NUREG-1827, “Safety Evaluation Report for the National Enrichment Facility in 

Lea County New Mexico, Louisiana Energy Services,” dated June 2005. 

(NRC, 2009) Staff Requirements Memorandum (SRM), Meeting SRM M090205 (ADAMS 

Accession No. ML090490032). 

(NRC, 2009) Commission Meeting Transcripts and Briefing Package, “Briefing on Uranium 

Enrichment,” February 5, 2009 (ADAMS Accession Nos. ML090410464, ML090410578, and 

ML090370266). 

(NRC, 2010) NUREG-1520, Rev. 1 “Standard Review Plan for the Review of a License 

Application for a Fuel Cycle Facility,” dated May 2010. 

10 CFR Part 40 “Domestic Licensing of Source Material.” 

10 CFR Part 70 “Domestic Licensing of Special Nuclear Material.” 

10 CFR Part 95 “Facility Security Clearance and Safe-Guarding of National Security Information 

and Restricted Data.”