INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN 

FY 2007-2009 

Revision 2

April 2007

Decommissioning and Uranium Recovery Licensing Directorate

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental Management Programs

U.S. Nuclear Regulatory Commission
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TABLE OF CONTENTS

1 Introduction 4 

1.1 Purpose and Scope 4

1.2 Content 4

2 Background 5

3 Summary of Integrated Key Improvements 6

4 Description of Regulatory Improvements 7

4.1 Followup work on revised decommissioning guidance 7

4.2 Develop new rule and supporting guidance 8

4.3 Revise inspection procedures and enforcement guidance 10

4.4 Groundwater monitoring guidance for the decommissioning phase 11

4.5 Evaluate potential revisions to guidance for restricted use 

cost benefit analyses 12

4.6 Knowledge management initiative and guidance on engineered barriers 

and erosion controls 13

4.7 Other LTR Analysis recommendations approved by the Commission 13

5 Description of Program Management Improvements directed by the Commission 15

5.1 Capture and share lessons learned and best practices 15

5.2 Radiological monitoring 15

5.3 Finality of decommissioning process 15

5.4 Consistency among State and Federal regulators 16

5.5 Enhance guidance on flexibility and institutional controls 16

5.6 Evaluate further consolidation of decommissioning activities 17

6 Description of Other Program Management Improvements 17

6.1 Improvements related to the Program Evaluation and IG independent

review 17

6.1.1 Evaluate methods to measure decommissioning efficiency 17

6.2 Improvements related to the FY2005 internal OMB PART review 18

6.2.1 Conduct formal PART review 18
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6.2.2 Prepare new procedure for program performance measures 19

6.2.3 Conduct independent reviews by ACNW 19

6.3 Other staff improvements 19

6.3.1 Comprehensive decommissioning program 19

6.3.2 Evaluate stakeholder recommended improvements 20

6.3.3 Conduct a stakeholder workshop on improvements to the 

regulations, guidance, and licensing process 21

6.3.4 Conduct a program evaluation of dose modeling 21

6.3.5 Develop web-based dose modeling training 21

Attachment 1: DWMEP Procedure 2.1: Program Improvement Planning and Development
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INTEGRATED DECOMMISSIONING IMPROVEMENT PLAN 

FY 2007-2009 

1.0 Introduction

1.1 Purpose and scope

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

Decommissioning Improvement Plan (IDIP) is to:

1) describe a “continuous improvement” plan for decommissioning and

2) integrate and document general plans for regulatory improvements and

program management improvements during FY 2007-2009 into one plan,

regardless of the source.

IDIP documents the first and second steps in the staff’s continuous improvement

process that is described in the new procedure 2.1, Integrated Improvement Planning

and Assessment Process included in the Division of Waste Management and

Environmental Protection (DWMEP) Operations Manual (Attachment 1). IDIP Rev. 1

included planned improvements for FY 2005-2007. IDIP Rev. 2 includes an update

for planned improvements for FY 2007 and adds planned improvements for FY 2008-

2009. These new improvements are based on program assessments in step one of

the continuous improvement process. Specifically, these assessments include the

Commission’s annual program review, the NRC Inspector General’s (IG’s)

independent review, the staff’s internal Office of Management and Budget’s (OMB)

Program Assessment Rating Tool (PART) review, and the staff decommissioning

licensing experience. 

The scope of IDIP Rev. 2 only includes ongoing and new improvements. 

Implementation of completed past improvements are not included in IDIP Rev. 2. 

For example, during FY 2005, numerous improvements were completed and

documented as new procedures in the DWMEP Operations Manual. The ongoing

activities to implement these procedures are not included in the scope of IDIP Rev. 2. 

Completed improvements are not included in IDIP Rev. 2., but are documented in the

annual report for the Decommissioning Program (NUREG-1814, Rev. 1).

1.2 Content

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

key improvements planned for FY 2007-2009. Section 4.0 describes planned

regulatory improvements, Section 5.0 describes planned program management

improvements directed by the Commission, Section 6.0 describes other program

management improvements resulting from the IG’s independent review, the staff’s

internal PART review, and other staff activities. 
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2.0 Background

An initial IDIP was prepared in FY 2004 and Rev. 1 was completed in March 2005 to

integrate all the staff’s regulatory and program management improvements into one

plan. In February 2006, the staff completed Rev. 0 of the DWMEP Operations Manual,

which included procedure 2.1 Integrated Improvement Planning and Assessment

Process (Attachment 1). As already mentioned, this new procedure describes an

iterative four step process for continuous improvement of the Decommissioning

Program. Step one is to conduct program assessments, such as self assessments

using the PART methodology, Commission annual program reviews, Advisory

Committee on Nuclear Waste (ACNW) independent reviews, and the IG’s independent

review to identify areas for possible improvements. Based on these assessments, the

second step of planning improvements is conducted and documented in a revision to

the IDIP. Using IDIP, improvement efforts are undertaken and results are summarized

in an annual Continuous Improvement Report under step three. Step four is to reassess

the program on a schedule established by the Agency, such as for the OMB PART

review or future independent evaluations, or a staff assessment on a schedule that

would result in a meaningful assessment considering many improvements need time to

be implemented before their resulting efficiencies can be measured or reassessed. This

includes periodically reassessing the regulations, guidance, and implementing licensing

process to ensure consistency, completeness, and implementability. This step starts

over the iterative process. The staff plans to implement this four step procedure and

therefore, revise IDIP as needed, to include results of future reviews such as the OMB

PART review scheduled for FY 2007. After completion of an IDIP revision,

improvements are incorporated and tracked in the DWMEP Operations Plan. 

Additional background is given below for regulatory and program management

improvements to provide some continuity with past improvement activities.

Completed and ongoing regulatory improvements have been primarily initiated by the

results of the staff’s License Termination Rule (LTR) Analysis and the related

Commission’s direction. In June 2002 the Commission directed the staff to conduct an

analysis of LTR implementation 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 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. Regulatory improvements, including the ongoing decommissioning guidance and

rulemaking/guidance for preventing future legacy sites are a result of the LTR Analysis

and these improvements are included in IDIP.

Some ongoing program management improvements also have been directed by the

Commission as a result of the staff’s annual briefings to the Commission. As a followup

to the October 2004 annual briefing, the Commission directed the staff to address the

five items listed below (October 22, 2004, SRM-M041013A). 
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- Capture and share lessons learned and best practices 

- 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

Similarly, as a result of the staff’s October 2005 briefing, the Commission directed the

staff to: 

- Evaluate options to further consolidate elements of the Comprehensive 

Decommissioning Program into a single organization.

Program management improvements have also resulted from the staff’s internal PART

review that was conducted to prepare for the formal OMB PART review that had

originally been scheduled for FY 2006. However, OMB rescheduled the review until 

FY 2007. The staff’s preparations for the PART review resulted in draft answers to the

31 PART questions and recommended some follow-up improvements.

3.0 Summary of Key Planned Improvements

Improvements Planned in FY 2007

Complete responses to public comments on the draft decommissioning guidance for

LTR Analysis issues and other issues addressed in the final guidance completed in 

FY 2006.

Continue work on proposed rulemaking/supporting guidance for changes in financial

assurance and operations for preventing future legacy sites, including groundwater

monitoring during facility operations. 

Continue work on internal draft inspection procedures and enforcement guidance to

implement the proposed rulemaking for preventing future legacy sites.

Continue development of lessons learned collaboration with industry and Agreement

States

Prepare a new procedure for obtaining and documenting the data for the program’s

performance measures

Evaluate potential revisions to guidance for restricted use cost benefit analyses

Conduct OMB PART review and identify commitments to further improve the program
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Conduct a program evaluation of decommissioning dose modeling

Evaluate stakeholder recommended decommissioning improvements

Complete proposed rulemaking to prevent future legacy sites to EDO

Improvements Planned in FY 2008

Consistent with Commission direction, publish proposed rulemaking/supporting draft

guidance to prevent future legacy sites for public comment. 

Develop draft guidance on selected issues and publish as draft guidance for public

comment along with draft guidance for rulemaking (e.g., cost benefit analysis for

restricted use sites, groundwater monitoring for the decommissioning phase)

Revise IDIP based on PART results and OMB committments, licensing experience for

decommissioning sites (including research and test reactors) and uranium mill tailings

sites, evaluation of stakeholder recommended improvements, evaluations of dose

modeling and cost benefit guidance

Update methods to measure decommissioning efficiency, including cost and time

savings, completed in FY 2006

Complete final rulemaking to prevent future legacy sites to EDO

Improvements Planned in FY 2009

Consistent with Commission direction, publish final rulemaking/supporting final guidance

to prevent future legacy sites 

Complete final guidance on selected issues (e.g. cost benefit analysis for restricted 

use sites)

Conduct stakeholder workshop on improvements to the regulations, guidance, and

licensing process

4.0 Description of Regulatory Improvements

4.1 Followup work on revised decommissioning guidance 

Description: 

The final revised guidance was completed in FY 2006 for the LTR Analysis issues

and published as a revision to the Consolidated Decommissioning Guidance in

NUREG-1757. Followup work during FY 2007 will include completing the responses

to public comments and staff training on the revised final guidance.
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Milestones and schedules:

Complete responses to public comments and make 

available on web site 12/06 C

Train staff on final LTR guidance 03/07 C

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 (Watson)

- Engineered barriers (Esh/T. Johnson/R. Johnson)

- Long-term monitoring (Johnson)

- Radiological surveys (McLaughlin)

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

Description:

The work that started during FY 2006 will continue on preparing a new rule and

supporting new guidance/revised guidance for the following LTR Analysis issues. 

This work should address the specific recommendations approved by the

Commission in SRM-SECY-03-0069 and other related topics: 

- Changes to financial assurance

- Initial underestimation of decommissioning cost

- Earlier provisions for soil and groundwater remediation costs

- Unavailability of funds in bankruptcy

- Inadequate financial disclosure

- Reaching assets after corporate reorganization

- Investment losses reduce trust account balance

- Changes to licensee operations

- Chronic releases

- Reporting inadequacies

The staff will use the Office of Federal and State Materials and Environmental

Management Programs (FSME) rulemaking process including stakeholder

involvement (e.g., ACNW, industry, working group with State participation, and

public). Stakeholder involvement began with a Decommissioning Workshop in FY

2005 and the ACNW meeting during FY 2006. These meetings and additional
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stakeholder meetings planned for FY 2007 should provide opportunities for input to

preparing the proposed rule and guidance. 

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 necessary information. A proposed rule and

draft supporting guidance would be published for public comment in FY 2008 and the

final rule and guidance planned to be published in FY 2009. The financial assurance

guidance will be added to NUREG-1757 Vol. 3, Part II on Financial Assurance. 

The portion of the rulemaking on the issue Changes to Licensee Operations will be

supported with guidance development for monitoring and reporting during facility

operations for both inside facilities and outside facilities, including groundwater

monitoring. This guidance is coordinated with and will make use of related NRC

activities including: 1) the Office of Research project on developing a groundwater

monitoring strategy; 2) the Lessons Learned task force for liquid releases from

nuclear power plants; and 3) the portion of the Standard Review Plan guidance for

new reactors related to 10 CFR 20.1406. Although the focus of the RES project is

on the decommissioning and subsequent phases of plant life, the principles of a

sound monitoring strategy apply throughout plant life, as does collection of the basic

site hydrologic and geologic data. Some of the recommendations from the task force

for liquid releases are closely related to the intent of the proposed rulemaking efforts. 

The resulting guidance will be documented in a NUREG report that can be

referenced by the appropriate NRC guidance for operating facilities. 

The related work on Revising the Inspection Procedures and Enforcement Guidance

for this issue is described in Section 4.3. 

Milestones and schedules:

Working Group completes review of internal draft rulemaking 10/06 C

Conduct stakeholder/public meeting 01/07 C

Revise schedule (below) based on input from public meeting 01/07 C

Complete technical basis document 02/07 C

EDO approval and draft rulemaking package to Commission 09/07

EDO approval and final rulemaking package to Commission 09/08

Assignments:

FSME rulemaking PM: O’Sullivan 

DWMEP technical PM: Fredrichs

Financial assurance changes: Fredrichs, ICF contractor

Operational changes: Shepherd
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Office of Nuclear Regulatory Research (RES)/monitoring: Nicholson, internal

Technical Advisory Group on hydro geology

Office of Nuclear Regulatory Research (NRR): Pittiglio

FCSS: T. Johnson

SFST: Wharten

MSSA: Siurano 

OGC legal review: Hull

Region-III: G. McCann

OAST: Conley (KS)

4.3 Revise inspection procedures and enforcement guidance to enhance monitoring,

reporting, and remediation to prevent future legacy sites

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 SRM-SECY-03-0069). 

Measures to prevent future legacy sites

- Changes to licensee operations

- Chronic releases

- Reporting inadequacies

This work consists of two steps. The first step, a report completed during FY 2005,

helped scope the inspection and enforcement guidance, including developing a riskinformed approach to identify operating sites with a higher likelihood for subsurface

contamination that could cause future decommissioning problems, identifying types of

sites or specific sites and activities at these sites for heightened inspection,

identifying the types of inspection activities that would be completed at these sites,

and the potential inspection procedures that could be revised. This report which is

documented in a memorandum (ML052630421), provided the results of the staff

review of 82 decommissioning sites. The staff documented which sites had known

groundwater and/or subsurface contamination and the sources and causes of

contamination. The staff also provided commentary on existing inspection

procedures, the extent to which sources and causes of subsurface contamination are

the subject of these procedures, and new inspection approaches and general

guidance that address sources and causes of contamination. 

The second step will develop specific inspection procedures (or revised existing

procedures) 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 2007-2008 to ensure consistency

between the rulemaking and guidance (see section 4.2). Coordination or

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

ACNW update 11/06 C

Revise schedule (below) based on revised rulemaking schedule 01/07 C

Complete draft inspection procedures and enforcement guidance 09/07

Complete final inspection procedures and enforcement guidance 09/08

Assignments:

PM: Shepherd

Region reps: G. McCann Region III

OGC legal review: Hull

4.4 Groundwater monitoring guidance for the decommissioning phase 

Description: 

Guidance for groundwater monitoring is planned for the two phases of a licensed

facility lifetime: operations and decommissioning. Section 4.2 addresses the

groundwater monitoring for facility operations associated with the rulemaking to

prevent future legacy sites. The groundwater monitoring guidance for the

decommissioning phase, described in this section, will be included in the guidance

developed under Section 4.2. It will also include the results of the RES project for

developing a monitoring strategy for confirmation of site conceptual models. The

schedule below will be consistent with guidance development support for the

rulemaking for preventing future legacy sites. This approach will result in more

efficient guidance production and public comment.

Milestones and schedules:

See section 4.2

Assignments: 

PM: Shepherd 

Office of Research (RES) support: Nicholson
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4.5 Evaluate potential revisions to guidance for restricted use cost benefit analyses

(CBA)

Description: 

As a result of the Decommissioning Plan acceptance review for the Shieldalloy site

and the Predecisional Draft Environmental Impact Statement (EIS) review of the

West Valley site, the staff recommended that the existing decommissioning guidance

for CBA for restricted use sites required by the LTR in 10 CFR 1403(a) and 10 CFR

1403(e)(i), be evaluated to determine how the guidance would be implemented at

these two sites. Based on the evaluation, the staff could recommend clarifications or

revisions to the existing guidance. A work plan and team assignments were

completed during FY 2006. The staff’s work will be coordinated by the NRC

contractor, Ecology and Environment, for the Shieldalloy EIS.

Milestones and schedule:

Team kickoff meeting and review of plan 11/06 C

Develop background 01/07 C

Conduct Shieldalloy review of CBA 04/07

Consider West Valley PDEIS CBA and NRC comments 06/07

Recommend staff conducting example CBAs and revising 07/07

guidance

Management decision on recommendations 09/07

Assignments: 

PM: R. Johnson

DWMEP technical support: 

West Valley health physics: Watson

Shieldalloy health physics: Schmidt

West Valley dose modeling: Esh

CBA guidance: McKenney

FSME technical support:

CBA: O’Sullivan

DWMEP site project managers: Glenn, Kalman, Suber

Office of the General Counsel (OGC): Hull, Jensen
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Contractor coordination: E&E contractor for Shieldalloy EIS

4.6 Knowledge management initiative and additional guidance on erosion controls

Description: 

Staff technical reviews during FY 2006 and guidance development during FY 2006

identified potential future improvements. This task would make recommendations for

a knowledge management initiative and additional guidance for documenting erosion

control lessons learned. Include lessons learned from approved U.S. Department of

Energy (DOE) erosion control designs that would be particularly relevant for future

erosion control reviews at decommissioning sites such as West Valley and

Shieldalloy and uranium mill tailings sites. The task could document how challenging

erosion and rock durability issues were addressed by past NRC reviews as well as

some relevant State and Federal studies. The task could also evaluate the use of

natural and archeological/historical analogues as evidence for long-term stability of

erosion control designs and durability of rock selected for erosion covers. The

product could be a NUREG report or revisions to the Consolidated Decommissioning

Guidance in NUREG-1757, depending on the management decision. If guidance is

developed, it would be coordinated and prepared along with guidance for other topics

identified in 

IDIP Rev. 2

Milestones and schedules:

Recommend scope of new guidance and lessons learned 08/07

Management decision and schedule for approved recommendations 09/07

Potential development of NUREG and/or draft guidance 09/08

Potential development of final guidance 09/09

Assignments:

PM: T. Johnson, R. Johnson

4.7 Other LTR Analysis recommendations approved by the Commission

4.7.1 Restricted Use–reevaluate potential for site transfers to the DOE under the Nuclear

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

There is no need to evaluate this item at this time because the staff plans on continuing

to implement the Commission’s direction for the LTC license or NRC Legal

Agreement/Restrictive Covenant (LA/RC). 
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4.7.2 Restricted Use–continue to monitor agency activities (DOE Legacy Management,

U.S. Environmental Protection Agency (EPA) , Ohio) (Johnson)

Description:

Continue to monitor and exchange information from DOE, EPA, and Ohio regarding use

of institutional controls (ICs). Activities might include attending meetings and reviewing

new EPA guidance or participating in future agency exchanges on IC. For example

during FY 2006, the staff participated in the EPA, DOE, NRC workshop sponsored by

The Consortium for Risk Evaluation with Stakeholder Participation (CRESP) or the EPA

workshop on IC, and the EPA workshop on IC. 

Milestones and schedule:

DOE/NAS workshop on DOE cleanup 03/07 C

Review new EPA guidance and workshop papers on IC 09/07

State of Ohio meeting on status of the Shieldalloy site in Ohio 09/07

Assignments: Johnson, Banovac, Hull/Jensen (OGC)

4.7.3 Restricted Use–Long-Term Control (LTC) license: Frequently asked questions and

new internal guidance

Description:

Prepare frequently asked questions (FAQs) for restricted use, LTC license, and LA/RC,

and make available on the Decommissioning web site. Use information from the

NUREG-1757 comment responses, staff experience from the Shieldalloy public

meetings, NJ petitions, and Shieldalloy DP hearing requests. The FAQs will improve

stakeholder understanding, particularly for the Shieldalloy, NJ and West Valley, NY

sites. 

Prepare a new section for the NRC Manual Chapter for possession-only specific

licenses. Describe the new LTC possession only specific license to distinguish it from

the existing possession only license for storage. Use existing descriptions from the

revised NUREG-1757. 

Milestones and schedule:

Frequently asked questions 09/07

Develop scope, outline of new section and schedule for Manual Chapter 09/07

for the LTC license.

Assignments: R. Johnson
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5.0 Description of Program Management Improvements directed by the Commission

These improvements resulted from the Commission’s direction in the SRMs from the

annual briefings for the Commission. 

5.1 Capture and share lessons learned and best practices 

Description: 

Continue the development started in FY 2006, of a collaborative approach with

industry and Agreement States to identify, document, and make decommissioning

lessons learned available. Continue to add NRC lessons learned from licensing

actions to the Decommissioning Web page. Plan, conduct, or participate in lessons

learned sessions at conferences.

Milestones and schedules:

ACNW review of Lessons Learned 11/06 C

Participate in International Atomic Energy Agency (IAEA) meeting on

decommissioning lessons learned 12/06 C

ACNW presentation on IAEA lessons learned meeting 02/07 C

Evaluate potential for redesign of Lessons Learned (LL) web page 09/07

Publication of new NRC LL from ongoing decommissioning projects 09/07 

Assignments:

PM: Rodriguez

5.2 Radiological monitoring (McLaughlin)

This improvement was part of the final revised guidance under section 4.1 and was

completed in FY 2006. The only FY 2007 action is the staff training listed under

section 4.1.

5.3 Finality of decommissioning process 

Description: 

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

the EPA-NRC Memorandum of Understanding (MOU) as was done during FY 2005

and FY 2006. 
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Milestones and schedule:

Prepare Level 2 Consultation Letter to EPA for Kaiser 12/06 C

Prepare Level 2 Consultation Letter for Battelle 03/07 C

Evaluate EPA’s Response on Cabot and prepare response 06/07

letter to EPA

Provide periodic training to project managers, Regions on MOU periodic

Assignments:

PM: Rodriguez and site Project Managers

5.4 Consistency among State and Federal regulators 

Description: 

Update Agreement States on NRC decommissioning issues at annual Organization

of Agreement States (OAS) meeting, including inform/provide Agreement States with

the Final Decommissioning Guidance for LTR issues. Continue OAS working group

participation with rulemaking to prevent future legacy sites.

Note that it should not be expected that this work will achieve consistency where

some States prefer more stringent requirements, but it will keep Agreement States

informed. 

Milestones and schedules:

Annual CRCPD meeting 05/07

Assignments:

PM: Rodriguez

5.5 Enhance guidance on flexibility and institutional controls for restricted use 

Final guidance was completed in FY 2006 (see section 4.1 above) that included

enhancing flexibility in the decommissioning process for use of restricted

use/institutional controls and engineered barriers. The remaining activity in FY 2007

is to provide staff training on the final revised guidance. 
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5.6 Evaluate further consolidation of decommissioning activities 

Description: 

As a followup to the October 2005 annual briefing to the Commission, on November

7, 2005, the Commission directed the staff (SRM M051018) to review various aspects

of NRC’s decommissioning program and provide the Commission with possible

options for further consolidation of the program in one division.

During FY 2006, this task involved evaluating options and preparing a Commission

paper to inform the Commission of staff actions to further consolidate the

decommissioning program, including transfer of research and test reactor

decommissioning (RTRs) from NRR and uranium recovery site decommissioning

from FCSS. The transfer of uranium recovery site decommissioning is part of the

larger reorganization. Also included under this task are transition plans and activities

to implement the approved transfers such as staff training, PM knowledge transfer,

and informing licensees and key stakeholders of the organizational changes and new

NRC contacts. The transfers of RTRs and uranium recovery sites was completed in

FY 2006 and the changes were presented at the TRTR Annual Meeting in September

2006.

The remaining work in FY 2007 is to continue implementing the expanded

organization and managing the decommissioning of more sites. 

Milestones and schedule:

Update Management Directives 06/07

Assignments: 

Hayes

6 Description of Other Program Management Improvements 

6.1 Improvements related to the Program Evaluation and IG independent review

This activity is a continuation of one of the improvements the staff completed and that was

tracked by the IG independent review. Although completed, the staff believes updating this

activity is beneficial for the program.

6.1.1 Evaluate methods to measure decommissioning efficiency

Description: 

This task continues the work started during FY 2005 to explore the feasibility of

quantitative approaches for determining efficiencies within the decommissioning

program. The task includes analysis of DP and LTP review time, Full Time

Equivalent (FTE) expenditure for DP reviews, and quality of DPs and LTPs as
18

measured by the number and sets of Requests for Additional Information (RAIs). 

Results documented in the initial evaluation based on FY 2003-FY 2005 data will be

updated with new data from FY 2006. This task will help address PART question 4.3:

Does the program demonstrate improved efficiencies or cost effectiveness in

achieving program goals each year?

Milestones and schedules:

Update evaluation with FY 2006 and FY 2007 data 12/07

Assignments: Orlando, Chang

6.2 Improvements related to the FY 2005 internal OMB PART review

6.2.1 Conduct formal OMB PART review

Description: 

Prepare for and conduct the formal OMB PART review rescheduled for FY 2007. 

Preparations would include: FY 2007 work plan; review and revise FY 2006 answers

based on new information about PART and the program; and collect and organize

supporting evidence with ADAMS links. 

Milestones and schedules:

Work plan 11/06 C

Review/revise FY 2006 answers 03/07 C

Complete draft submittal to OMB 03/07 C

Complete final submittal to OMB 04/07

Complete potential improvement plans 06/07

Revise IDIP based on results of PART review 11/07

Assignments: 

SES manager/champion: Flanders

Johnson, Orlando, J. Davis

OCFO: Smolik, Coyle
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6.2.2 Prepare new procedure for program performance measures

Description:

Prepare new procedure for performance measures that includes: 1) identifying the

applicable performance measures for decommissioning and low level waste; 2)

identifying organizational responsibilities for collecting and reporting data on the

applicable measures; and 3) describing how to use NRC’s NMED data base and

other agency sources to collect and document program performance data that is

provided to NMSS as input to the NRC’s Performance and Accountability Report.

A draft of the procedure was prepared in FY 2006 and the procedure will be

completed in FY 2007.

Milestones and schedules:

Prepare final procedure 4/07

Assignments: Kennedy 

6.2.3 Conduct independent reviews by ACNW

Description:

This improvement includes the ongoing independent reviews conducted periodically

by ACNW members and ACNW working groups of decommissioning rulemaking,

guidance development, lessons learned, and other selected key issues for the

decommissioning program. ACNW working groups include decommissioning experts

from industry and State regulators external to ACNW members and NRC.

Milestones and schedules:

ACNW review of lessons learned status 11/06 C

ACNW review of performance monitoring and legacy rulemaking 11/06 C

Assignments: 

Rulemaking: Fredrichs, Shepherd

Lessons learned: Rodriquez

6.3 Other staff improvements

6.3.1 Comprehensive Decommissioning Program (CPD)
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Description: 

Currently, staff reports on complex materials sites for which it has jurisdiction in site

summaries on it website, in the staff’s annual decommissioning report and in an annual

Commission paper that discusses sites that may have financial assurance problems. In

order to present a national perspective of decommissioning of complex sites, staff will

also include the same information in its reports listed above for sites for which

Agreement States have jurisdiction.

Milestones and schedules:

OAS conference call 02/07 C

Develop actions and schedules 04/07

Develop list of information needed from Agreement States 05/07

Develop OMB clearance package 05/07

Present CPD at CRCPD meeting 05/07

Send Questionnaire to Agreement States 08/07

Assignment: Gnugnoli, Chang

6.3.2 Evaluate available stakeholder recommended improvements

Description:

The staff can obtain recommendations for improvements from a variety of sources, such

as individual licensees, industry associations, public interest groups, members of the

public, and the ACNW. The staff will review stakeholder recommended improvements

received during FY 2006 and the first quarter of FY 2007 and determine which, if any,

should be pursued. Example stakeholder recommendations include recommendations

obtained at the ACNW meeting on decommissioning lessons learned in November 2007

and the Annual Decommissioning Briefing with the Commission in December 2007. 

Initially, develop a plan and schedule for the evaluation, including criteria for evaluating

recommended improvements and regulatory products or actions to address the

improvements 

Milestones and Schedules:

Develop evaluation plan and schedule 07/07

Assignments: Rodriguez
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6.3.3 Conduct a stakeholder workshop on improvements to the regulations, guidance, and

licensing process

Description:

Conduct a stakeholder workshop in FY 2009 to identify potential improvements to the

regulations, guidance, and implementing licensing process (i.e., regulatory framework). 

The workshop should address: 1) emerging issues that are not addressed in the existing

regulatory framework (gaps); 2) effectivenss of the regulatory framework including

implementation of the LTR Analysis issue resolutions for institutional controls and

realistic scenarios; and 3) improvements to the efficiency of existing regulatory

framework. Based on stakeholder feedback at the workshop, the staff should schedule

further assessment, as needed. 

Milestones and Schedules:

Conduct a stakeholder workshop FY 2009

Assignments: Rodriguez

6.3.4 Conduct a program evaluation of decommissioning dose modeling 

Description: 

Conduct a program evaluation of DWMEP dose modeling approaches, methodologies,

and tools used for decommissioning. This activity will focus on assessment of

codes/models used, input parameters, as well as scenarios to demonstrate compliance

with NRC’s decommissioning dose criteria. This evaluation is intended for improvement

in efficiency, approaches, and methodology, as well as use of lessons learned. 

Milestones and schedules:

Complete evaluation 09/07

Assignments: Abu-Eid

6.3.5 Develop web-based dose modeling training

Description:

Currently, project managers take a dose modeling class when offered. To make the

class more readily available, staff will develop a web-based dose modeling class.

Milestone and schedule:

Develop web-based dose modeling training 04/07

Assignment: C. Barr
Attachment 1

PROCEDURE DWMEP 2.1

PROGRAM IMPROVEMENT PLANNING AND DEVELOPMENT

(Taken from the DWMEP Operations Manual)

PURPOSE

The purpose of this section is to describe the general process for “continuous improvement” of

the Decommissioning Program. This process includes four steps to assess and improve and

reassess the Decommissioning Program. It applies to the Comprehensive Decommissioning

Program as defined in NRC Budget Request and, therefore, it includes activities of many NRC

organizations including: NMSS/DWMEP/DCD; NMSS/DWMEP/EPAD; Regions; and Office of

Nuclear Regulatory Research (RES).

PROCEDURES

2.1.1 Integrated Improvement Planning and Assessment Process

The Integrated Decommissioning Improvement Plan (IDIP) continuous improvement process

consists of a repeating a cycle of four steps:

• Assess program

• Plan improvements

• Conduct improvements

• Measure and reassess program

2.1.1.1 Program Assessment

The following types of program assessments or reviews should be conducted as

appropriate. Methods are described below for both self assessments and independent

assessments. Frequency and scheduling of assessments should be done each year in 

the annual update to the IDIP and the Operating Plan.

Staff Self Assessments

Staff self assessments can be either self initiated or Agency required (e.g., FY 2003

Program Evaluation of Changes to the Decommissioning Program required by the

Government Performance Results Act (GPRA)). However, the assessment is conducted

by the staff. The scope can be either broad and cover the total program, a focused

“vertical slice” of part of the program or an important issue, or the implementation of the

regulations (e.g., License Termination Rule (LTR) Analysis of implementation issues).

The results of self assessments should be documented in a report that is publically

available. The assessment report should include findings and recommendations. The

recommendations will be considered each year when the IDIP is updated. 
Staff Assessments of Stakeholder Views 

Periodically, the staff conducts a Decommissioning Workshop for licensees and other

stakeholders. During these workshops, the staff should invite stakeholder comments and

suggestions regarding program effectiveness and ways to improve the program. The staff

should evaluate the stakeholder comments and recommend program improvements that

will be considered along with other recommended program improvements when the staff

updates its IDIP each year. 

Advisory Committee on Nuclear Waste (ACNW) Independent Technical Reviews

The ACNW is an independent advisory committee to the Commission. Periodically, ACNW

conducts reviews during the year on a variety of topics related to the staff’s ongoing

decommissioning work. These reviews are more technical and usually focus on regulatory

products under development (rulemakings, guidance, policy issues) or technical issues

being addressed by the staff as it implements the program (e.g., institutional controls,

intentional mixing of soils). These technical reviews can be requested by the staff, initiated

by the ACNW, or requested by the Commission.

The ACNW reviews are documented in official transcripts of ACNW meetings and letters to

the Commission. The staff’s responds to the ACNW letters and includes actions, as

appropriate. Most of the recommendations are relevant to specific regulatory products and

would be considered in developing specific regulatory products. However, some

comments or recommendations may have broader applicability to Decommissioning

Program and could be considered in planning program improvements.

Typically, many ACNW reviews are conducted each year on a schedule developed and

updated periodically during the year to support the staff’s products. 

Commission Annual Program Reviews

Annually, the staff provides the Commission with an annual report of the Decommissioning

Program and a Commission briefing. Through this regular and formal process, the

Commission provides oversight of the effectiveness and issues of importance to the

Decommissioning Program. These annual reviews are open to the public and include

participation by selected stakeholders to provide their independent views to the

Commission.

In response to these annual program reviews, the Commission provides direction, as

appropriate, to the staff for improvements to the program. 

NRC Inspector General Independent Program Reviews

The Inspector General (IG) can schedule a program reviews as was done for the

Decommissioning Program during FY 2005 to help prepare for the FY 2006 OMB PART

review. The IG is considered independent by OMB. These reviews would be documented

in an IG Report. The staff would prepare a response to the IG recommendations and

determine if improvements are needed and include them in the annual update to the IDIP.
OMB Program Assessment Rating Tool (PART) Reviews

OMB has been implementing the PART for all Federal programs. An OMB PART is

currently schedule for the Decommissioning Program in FY 2006. Essentially, the PART

review has two steps: 1) NRC provides OMB with answers to 39 questions and 2) OMB

reviews NRC’s answers and prepare the OMB answers to the 39 questions, scores the

overall program, and requests NRC to make specific improvements. 

2.1.1.2 Plan improvements

The staff will update the IDIP each year and include plans for new improvements directed

by OMB or the Commission and new improvements recommended by other assessments

and approved by NRC management.

2.1.1.3 Conduct improvements

Improvements planned in IDIP will be conducted as scheduled (e.g., develop new or

revised guidance or develop a work prioritization process). 

When completed improvements will be implemented by the program through the

appropriate mechanism (e.g., guidance, Operations Manual, Op Plan)

2.1.1.4 Measure and reassess program

Periodically reassess the program on a schedule established by the Agency, such as for

the OMB PART, or on a schedule that would result in a meaningful assessment

considering many improvements need time to implement before the their resulting

efficiencies can be measured or reassessed.

Periodically reassess the regulatory framework for Decommissioning (rules, guidance,

procedures) to ensure consistency and implementabilty (e.g., LTR Analysis of

implementation issues).

Periodically “measure” the efficiencies gained by the program improvements.