1. NRC Staff Byproduct Material Financial Scoping Study Analysis and Overview
James Shaffner, Project Manager
Division of Decommissioning, Uranium Recovery, and Waste Programs
U.S. Nuclear Regulatory Commission
A presentation to the
Low-Level Waste Forum
April 21, 2015
Alexandria, VA 4

2. Crux of the Issue
Threshold for Financial Assurance requirements in 10 CFR for Decommissioning Radioactive Sealed Sources is higher than most Category 1 and 2 (or lower) RSS
Therefore, there is no standing requirement for decommissioning financial assurance for these sources
Financial burden for decommissioning/disposal of these sources can be consequential
Issue was identified in 2006 Radiation Source Protection and Security Task Force (RSPSTF) Report

3. Early Follow-up 2007 Low-Level Waste Strategic Assessment
identified byproduct financial scoping has high priority
resource limitations/ higher priorities postponed action
Interagency Working Group Report on Financial Assurance for Disposition of Category 1,2, and 3 Radioactive Sealed Sources
completed to support 2010 RSPSTF report
summary recommendations included in 2010 RSPSTF Report
report never made public

4. Recent Background
Current focus arose from Commission briefing on Radioactive Waste Issues on September 18, 2014
Staff stressed timeliness of completing a Byproduct Material Financial Scoping Study identified in 2007 LLW Programmatic Assessment citing:
March 2014 Report by LLW Forum Disused Sources Working Group
2014 Radiation Source Protection and Security Task Force Report
Resulting Staff Requirements Memorandum September 24, 2014
“provide results of the byproduct financial scoping study and recommendations for next steps”

5. Staff Proposed Approach
Quick Turnaround – April 2015
SECY paper with scoping study results and recommendations
Accomplished by NRC internal working group
Work informed by three reports
2010 Interagency WG report
2014 LLW Forum DSWG report
2014 RSPSTF report
Further identify issues relevant to Byproduct Financial Planning

6. Shortcomings of Proposed Approach
Identified during senior management alignment process
Cited reports had only state and federal government perspective
Scoping would benefit from broader stakeholder perspective (manufacturers, licensees, use beneficiaries, public, others)
Staff requested and was granted more time to complete scoping study in order to solicit input from additional key stakeholders .

7. Primary Considerations in Expanded Scoping Study
Reports needing broader review
National activities that could affect byproduct material financial planning
International perspective relevant to byproduct financial planning
Issues identified by staff 7 7 7

8. Reports Needing Broader Review
Interagency Working Group Report on Financial Assurance for Disposition of Category 1,2, and 3 Radioactive Sealed Sources (Mar non-public)
Various insights re: disposition challenges
Specific recommendations re: financial planning w/state specific examples
Report by LLW Forum Disused Sources Working Group (Mar. 2014)
Specific recommendations re: financial assurance for sealed sources
Report of the Radiation Source Protection and Security Task Force (Aug. 2014)
Recommendation re: financial planning for Category 1 and 2
sources

9. National Activities with Relevance to Byproduct Financial Scoping
National Nuclear Security Administration source collection program
Source Collection and Threat Reduction Program (administered by the Conference of Radiation Control Program Directors (CRCPD))
Development and availability of sealed source transportation containers
Availability of new disposal capacity
NRC revised branch technical position on concentration averaging
CRCPD initiative to revisit criteria for financial surety for RAM 9 9 9

10. International Perspective
Joint Convention on the Safety Spent Fuel and on the Safety of Radioactive Waste Management
Article 28 “Disused Sealed Sources”
International Nuclear Energy Series No. NW-T-1.3 – Management of Disused Radioactive Sources
cost distribution
cost uncertainty
financial implications of no transfer path
Numerous other initiatives and reports

11. Issues Identified by Staff
Amount Adequate for Dispositioning
funding mechanism
Timeliness
licensee declaration of disused or unwanted source
Source Characteristics
as a consideration in disposition cost
Compatibility
required Agreement State implementation
Applicability to General Licensees
how imposed 11 11 11

12. Issues Identified by Staff (cont.)
Orphan Source Management
funding mechanism
Fund Custodian
disinterested party; inviolate designation
Tracking
adaptation of existing or de novo
Issues are consequential but hardly exhaustive

13. Expansion of Byproduct Material Financial Scoping Study
Federal Register Notice
define the issue
solicit perspective from stakeholders
Topic Specific Public Meeting
Presentations at Stakeholder meetings/feedback
Inform/develop issues paper
Results/recommendations to Commission by 3/16 .

14. Overarching Considerations
Safety (Part 30) vs. Security (Part 37) issue
Is there a problem/deficiency not addressed by
Part 37 requirements
License requirements
Enforcement
If so, is byproduct financial planning the best solution…a workable solution
If so, what is the best implementation strategy

15. Jim Shaffner, PE, Project Manager
Questions
Contact Information:
Jim Shaffner, PE, Project Manager