The important thing to remember is that decommissioning has effectively been deregulated for the past twenty years. The current regs only categorize the licensee’s approach to decommissioning in the broadest possible terms, and they are not mutually exclusive. And none of them have anything to do with the storage of irradiated fuel.
DECON means starting decommissioning soon after permanently ceasing operation of the reactor.
SAFSTOR means mothballing the reactor for an extended period of time before starting decommissioning.
ENTOMB means never removing the reactor components from the site, securing them in place.
There is no hard and fast rule about what DECON or SAFSTOR entail. The regulations state that licensees may use a combination of these approaches. So the decom plan can incorporate some immediate decommissioning activities, and then mothballing the site and completing decommissioning later. It is entirely up to the licensee.
Timing of removal of fuel from pools to dry casks can be done at any time, under any of the decom approaches. In the decommissionings of Yankee Rowe and Connecticut Yankee, which were done under DECON, loading of casks was one of the last things they did. The industry is expediting transfer to dry casks now purely for economic reasons. It allows them to reduce staffing more quickly, rationalizes cessation of emergency planning, and, for sites utilizing SAFSTOR, enables them to enter the mothballing period more quickly and eliminate staffing and operating expenses associated with the fuel pool.
NRC’s approval of the decommissioning plan is entirely pro forma: just verifying that the documentation provided by the licensee meets the regulatory requirements. The forthcoming changes to decommissioning regulations are only going to make the deregulation of decommissioning more complete, by precluding licensees from having to seek exemptions that NRC already grants routinely anyway.
Tim Judson
Director
Nuclear Information Resource Service
