Regulatory Harmony and the License Termination Process
H.J. Newman (NEXTEP Environmental, Inc.)
The Memorandum of Understanding (MOU) between the Environmental Protection Agency (EPA) and Nuclear Regulatory Commission (NRC) establishes guidelines for interaction of the two agencies at NRC licensed sites undergoing decommissioning. The current regulatory process for NRC license termination may involve the EPA or other agencies at various stages of the decommissioning process. In order to reduce the risk of unexpected regulatory intervention, an integrated approach involving consideration of important regulatory factors is needed at the front end of the decommissioning process. Although a noble effort, the MOU in practice has not served to provide license termination certainty to NRC licensees. Licensee attention to this matter could serve to reduce risk from EPA intervention at the tail end of the decommissioning process, or at a minimum allow for appropriate risk consideration.  C. T. Whitman, R. A. Meserve, "Memorandum of Understanding Between the Environmental Protection Agency and the Nuclear Regulatory Commission. Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites," U.S. Environmental Protection Agency and U.S. Nuclear Regulatory Commission (2002).