ML12166A159

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Letter to EPA Regarding Notification of the Decommissioning of the National Aeronautics and Space Administration Plum Brook Reactor Facility
ML12166A159
Person / Time
Site: Plum Brook
Issue date: 06/22/2012
From: Camper L
NRC/FSME/DWMEP
To: Patricia Anderson
Environmental Protection Agency
Orlando D
References
Download: ML12166A159 (3)


Text

June 22, 2012 Ms. Phyllis Anderson, Acting Director Assessment and Remediation Division Office of Superfund Remediation and Technology Innovation U.S. Environmental Protection Agency M.S. 5204P 1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

SUBJECT:

NOTIFICATION OF THE DECOMMISSIONING OF THE NATIONAL AERONAUTICS AND SPACE ADMINISTRATION PLUM BROOK REACTOR FACILITY

Dear Ms. Anderson:

This letter is intended to notify you of the decommissioning oversight actions that the U.S. Nuclear Regulatory Commission (NRC) has taken and intends to take for the National Aeronautics and Space Administration (NASA) Plum Brook Reactor Facility (PBRF) located in Sandusky, Ohio.

On October 9, 2002, the NRC and the U.S. Environmental Protection Agency (EPA) entered into a Memorandum of Understanding (MOU) on Consultation and Finality on Decommissioning and Decontamination of Contaminated Sites. Under the MOU, EPA agreed to continue its Comprehensive Environmental Response, Compensation, and Liability Act deferral policy of not listing sites on the National Priorities List that are subject to NRCs licensing authority. The MOU provides that, unless an NRC-licensed site exceeds any of three trigger criteria contained in the MOU (groundwater contamination in excess of EPAs maximum contaminant levels (MCLs); exceedance of MOU Table 1 soil values; use of restricted release or alternate criteria for license termination), EPA agrees to a policy of deferral to NRC decision making on decommissioning without the need for consultation.

For sites that trigger the criteria in the MOU, NRC will consult with EPA at two points in the decommissioning process: (1) prior to NRCs approval of the license termination plan (LTP) or decommissioning plan (DP), which NRC terms a Level 1 consultation; and (2) following completion of the Final Status Survey (FSS), which NRC terms a Level 2 consultation. Although the NRCs plan for consulting with EPA calls for the initial Level 1 consultation to occur early in the decommissioning process, at the time the MOU was signed NRC had several sites which were in the latter stages of the LTP/DP process. Since these sites were further along in the decommissioning process, the next opportunity to consult with EPA would be a Level 2 consultation following the completion of the FSS.

P. Anderson 2 The PBRF is a 27-acre site that formerly housed two research reactors for testing materials to be used in space program applications. The PBRF operated from 1961 to 1973, completing 152 reactor cycles. In January 1973, the PBRF was shut down and placed in a standby condition. In 1998, NASA decided to start the decommissioning process and subsequently submitted a DP for the release of the site for unrestricted use. In 2002, prior to the execution of the MOU, NRC approved NASAs DP and decommissioning activities have been ongoing since that time.

The NASA PBRF completed remediation activities in 2011 and submitted the FSS Report for NRC review and approval. The NRC has reviewed the information contained in the FSS Report and compared actual levels of residual radioactivity to the MOU trigger levels and determined that all the PBRF FSS measurements are below the MOU trigger levels. Therefore, no further consultation pursuant to the MOU is necessary.

At the time the MOU was signed, the NRC informed EPA about sites that had approved decommissioning plans but had not yet completed decommissioning. The NASA PBRF was inadvertently omitted from the list. However, the NRC believes that it is in the spirit of the MOU to notify the EPA of sites that would have been subject to the MOU.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions regarding this letter or the remediation activities at NASA PBRF, please contact Mr. Keith I. McConnell, Deputy Director, Decommissioning and Uranium Recovery Licensing Directorate, at 301-415-7295.

Sincerely,

/RA/

Larry W. Camper, Director Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket Nos.: 50-30 and 50-185 License Nos.: TR-3 and R-93 cc: NASA PBRF Service List

P. Anderson 2 The PBRF is a 27-acre site that formerly housed two research reactors for testing materials to be used in space program applications. The PBRF operated from 1961 to 1973, completing 152 reactor cycles. In January 1973, the PBRF was shut down and placed in a standby condition. In 1998, NASA decided to start the decommissioning process and subsequently submitted a DP for the release of the site for unrestricted use. In 2002, prior to the execution of the MOU, NRC approved NASAs DP and decommissioning activities have been ongoing since that time.

The NASA PBRF completed remediation activities in 2011 and submitted the FSS Report for NRC review and approval. The NRC has reviewed the information contained in the FSS Report and compared actual levels of residual radioactivity to the MOU trigger levels and determined that all the PBRF FSS measurements are below the MOU trigger levels. Therefore, no further consultation pursuant to the MOU is necessary.

At the time the MOU was signed, the NRC informed EPA about sites that had approved decommissioning plans but had not yet completed decommissioning. The NASA PBRF was inadvertently omitted from the list. However, the NRC believes that it is in the spirit of the MOU to notify the EPA of sites that would have been subject to the MOU.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions regarding this letter or the remediation activities at NASA PBRF, please contact Mr. Keith I. McConnell, Deputy Director, Decommissioning and Uranium Recovery Licensing Directorate, at 301-415-7295.

Sincerely,

/RA/

Larry W. Camper, Director Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs Docket Nos.: 50-30 and 50-185 License Nos.: TR-3 and R-93 cc: NASA PBRF Service List ML12166A159 Office DWMEP DWMEP DWMEP DWMEP DWMEP DWMEP DWMEP Name CGlenn SAchen PMichalak DOrlando LChang KMcConnell LCamper Date 6/14/12 6/14/12 6/20/12 6/21/12 6/21/12 6/22 /12 6/22/12 OFFICIAL RECORD COPY