Finding Harmony - Developing Cleanup Criteria to Address Multiagency Requirements

By John Peters, Jeffrey W. Lively, and Nelson Walter

Increasingly, the U.S. Environmental Protection Agency (EPA) and states' environmental regulatory agencies are holding a stake in facility decommissioning and cleanup requirements at sites seeking to close or terminate their U.S. Nuclear Regulatory Commission license. For example, in October 2002 NRC and EPA entered into a Memorandum of Understanding (MOU) regarding conditions under which EPA can act under its Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) authority at NRC-licensed sites that are in the process of, or have completed, decommissioning in support of license termination. This MOU identifies specific conditions under which EPA can require additional evaluation and potential cleanup of radioactive residues that would otherwise be satisfactorily addressed under NRC regulation and authority. In addition, EPA or state environmental agencies often require that a facility demonstrate that postdecommissioning conditions associated with chemicals regulated under federal or state agencies, and radionuclides regulated under the NRC, do not pose unacceptable risks to public health.

Copyright by WM Symposia, Inc. All Rights Reserved. Reprinted with Permission. Posted with permission of RADWASTE SOLUTIONS magazine, published by the American Nuclear Society.

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