It Is Not Just About the LTP: Integrating Regulatory Programs and Securing Approvals to Support Site Closure at Yankee Nuclear Power Station

摘要

Regulatory-driven radiological closure programs at decommissioned nuclear power facilities are based largely on a License Termination Plan (LTP) and associated activities prescribed by Nuclear Regulatory Commission (NRC) regulations and managed closely by the NRC, accompanied by less direct involvement from state regulators on radiologicalrnissues. Non-radiological environmental closure activities are often regulated by a welter of federal, state and localrnprograms, which can lead to internally uncoordinated, circular or even conflicting regulatory directives and which arerngenerally even less coordinated with the radiological regulatory structures. Unlike the NRC decommissioning context, nonernof the non-radiological regulatory programs provide a clear regulatory pathway to a final multi- agency-approved site closure, especially one that addresses both radiological and non-radiological site closure requirements. The business value of, and the stakeholder need for, an integrated approach is most compelling when viewed from the perspective of a successfulrnpotential post-closure transferee of the property. At YNPS, the post-closure transfer perspective became the controllingrninfluence in designing and carrying out the integrated site characterization and remediation. Understanding the complexityrnand interdependency of the environmental permitting activities, as illustrated in the SCPP, has proven essential inrnestablishing and managing an achievable project schedule.