Analyzing the allowable uses of nuclear decommissioning trust funds

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To expense, or not to expense?
That is the question

Ever since the US Nuclear Regulatory Commission (NRC) raised concerns regarding allowable uses of decommissioning trust funds for certain already- and to-be-incurred decommissioning expenses, some organizations have been struggling to determine which expenditures are regulation-compliant.

Our analysis aims to help organizations assess the basis for justifying allowable decommissioning expenses.

"Prudent financial management is essential for a decommissioning project. This means managing emergent issues and achieving annual financial targets while preserving Nuclear Decommissioning Trust (“NDT”) growth and meeting NRC and IRS requirements."

Brooke Traynham MorrisonDirector, Capital Projects & Infrastructure

NRC regulatory guidance review

  • Applicable NRC regulations at 10 CFR 50.2, 10 CFR 20.82 (a), 10 CFR 10 50.75(h)(1)iv)
  • Applicable NRC guidance
    • NUREG/CR-5884, Revised Analyses of Decommissioning for the Reference Pressurized Water Reactor Power Station
    • NUREG/CR6174, Revised Analyses of Decommissioning for the Reference Boiling Water Reactor Station
    • NUREG-1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors
    • NUREG-1757, Consolidated Decommissioning Guidance
    • NRC Regulatory Guides (Reg. Guides) 1.159, 1.184. 1.185, 1.202
  • NRC staff review of 10 CFR 50.75 formula amounts for decommissioning funding assurance
  • NRC past practice in
    • Reviewing decommissioning cost estimates
    • Approving licensee expenditures
  • IRS and allowable decommissioning costs
    • Regulations for licensees to establish tax-qualified decommissioning trust funds at 26 CFR 1.468(A)
    • IRS definition of decommissioning costs at 26 CFR 1.468(A(-1(b)(6)

Did you know?

NRC has suggested that these expenditures should not be paid from decommissioning trust funds under 10 CFR 50.2, 50.75 and/or 50.82:


Nuclear Energy Institute (NEI) annual fees

Property taxes

NRC is considering whether or not to allow these expenditures:

Security Phase I & II staff costs

Payments in lieu of taxes

Emergency plan and licencing contractors

Asbestos shipments, legal, (other) security staff costs

2018 spent fuel pool cleanup

Removal and disposal of spent fuel pool racks

Bituminuous roof replacement

Contact us

Daryl  Walcroft

Daryl Walcroft

Principal, Capital Projects & Infrastructure Leader, PwC US

Brooke Traynham Morrison

Brooke Traynham Morrison

Director, Capital Projects & Infrastructure, Nuclear Energy, PwC US

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