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."
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
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