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Title: Memorandum of Understanding Between U.S. EPA Superfund and U.S. NRC

Conference ·
OSTI ID:21144235
 [1]
  1. U.S. Environmental Protection Agency (EPA), Office of Superfund Remediation and Technology Innovation - OSRTI, Science and Policy Branch, 1200 Pennsylvania Avenue, NW, 5204 P, Washington, D.C. 20460 (United States)

The Environmental Protection Agency (EPA) Office of Superfund Remediation and Technology Innovation (OSRTI) and the Nuclear Regulatory Commission (NRC) are responsible for implementing the 'Memorandum of Understanding Between the Environmental Protection Agency and the Nuclear Regulatory Commission: Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites'. This paper provides a brief overview of the origin of the Memorandum of Understanding (MOU), the major features of the MOU, and how the MOU has been implemented site specifically. EPA and NRC developed the MOU in response to direction from the House Committee on Appropriations to EPA and NRC to work together to address the potential for dual regulation. The MOU was signed by EPA on September 30, 2002 and NRC on October 9, 2002. The two agencies had worked on the MOU since March 2000. While both EPA and NRC have statutory authority to clean up these sites, the MOU provides consultation procedures between EPA and NRC to eliminate dual regulation. Under the MOU, EPA and NRC identified the interactions of the two agencies for the decommissioning and decontamination of NRC-licensed sites and the ways in which those responsibilities will be exercised. Except for Section VI, which addresses corrective action under the Resource Conservation and Recovery Act (RCRA), this MOU is limited to the coordination between EPA, when acting under its CERCLA authority, and NRC, when a facility licensed by the NRC is undergoing decommissioning, or when a facility has completed decommissioning, and the NRC has terminated its license. EPA believes that implementation of the MOU between the two agencies will ensure that future confusion about dual regulation does not occur regarding the cleanup and reuse of NRC-licensed sites. NRC and EPA have so far exchanged MOU consultation letters on eight NRC-licensed sites. EPA has responded to each consultation request with a letter expressing its views on actions that NRC should consider that address the site-specific matter that triggered consultation. Over the course of consultations on the eight sites, there have been some reoccurring themes to EPA's views. Primarily, these are EPA: 1. Recommending that NRC consider selecting institutional controls to ensure that NRC's assumptions about future human exposure at the site are not exceeded. 2. Recommending that NRC consider using more site-specific information when conducting dose assessment modeling. 3. Recommending that NRC consider a flexible approach to groundwater protection that still ensures the public is not exposed to contamination levels over drinking water limits. 4. Recommending that NRC consider an approach similar to how EPA implements supplemental standards under 40 CFR 192 as an ARAR when the UMTRCA soil standard of 5 pCi/g is not being met.

Research Organization:
American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60526 (United States)
OSTI ID:
21144235
Resource Relation:
Conference: DD and R 2007: ANS Topical Meeting on Decommissioning, Decontamination, and Reutilization 2007, Chattanooga, TN (United States), 16-19 Sep 2007; Other Information: Country of input: France; Related Information: In: Proceedings of the 2007 ANS Topical Meeting on Decommissioning, Decontamination, and Reutilization - DD and R 2007, 336 pages.
Country of Publication:
United States
Language:
English