COMMISSION BRIEFING SLIDES/EXHIBITS

BRIEFING ON DECOMMISSIONING

ACTIVITIES AND STATUS

OCTOBER 13, 2004
Moomc~

OCTOBER 2004

MOLYCORP EXPERIENCE IN DECOMMISSIONING

1. OVERVIEW

Molvcorp

Molycorp is a producer of specialty metals and metallic compounds. Molycorp has

extracted metals and metallic compounds from ore concentrates at two facilities in

Pennsylvania. Some contained low concentrations of uranium and thorium, enough to

require an NRC materials license.

Molycorp has mining operations in Questa, New Mexico, Mountain Pass, California,

and has a joint venture in a niobium (aka columbium) mine in Brazil.

York Site Decommissioning

Molycorp's site near York, Pennsylvania has been decommissioned under the NRC's

Site Decommissioning Management Plan (SDMP). Recently, the NRC staff acknowledged

completion of decommissioning for unrestricted use and terminated the license.

Washington Site Decommissioning

Molycorp's Washington Facility is located about 35 miles southwest of Pittsburgh,

Pennsylvania. This facility is being decommissioned under the NRC SDMP in a phased

approach.

Corporate Responsibility

Molycorp's philosophy is to do the Right Thing for the community and our

stakeholders. That is, Molycorp intends to do what is socially and environmentally

responsible based on the use of good science and sound engineering through a collaborative

process with the regulatory authorities and community.

2. YORK SITE DECOMMISSIONING EXPERIENCE

Experience at York Site

Some ore concentrates processed at the York site contained minor amounts of natural

uranium series and thorium series nuclides. Considering the complexity of the site, with

land and structures to be decommissioned, the York site was listed and was

decommissioned under the SDMP.

During remediation, unsuspected conditions were encountered. Relative to initial

estimates, the amount of waste material shipped to disposal off-site was greater by ten-fold.

Material of unknown origin was also found near the site boundary to be trending on or offsite.

1
The regulatory agencies allowed temporary cessation of remediation for Molycorp to

assess remediation experience. Results were that:

*The initial characterization survey had been inadequate.

*As decommissioning progressed it became evident that some soil below the soil

radioactivity concentration release criterion had been shipped to regulated disposal offsite.

*With NRC staff acceptance, Molycorp revised excavation and final status survey

strategies to complete site remediation.

*The AAR method contained within the approved decommissioning plan was selected to

evaluate remaining areas requiring excavation. This method accounts for potential

exposures from subsurface as well as distributed residues as opposed to point by point

assessments.

*Soil containing radioactivity concentration well below unrestricted release limit was

returned to excavation cavities as backfill material.

*Molycorp performed radiological dose modeling to confirm acceptable potential exposure

for material of unknown origin trending offsite under road and rail embankments.

Molycorp, NRC staff, and State DEP staff agreed on the method of resolution.

*The NRC project manager facilitated a Memorandum of Understanding between

Molycorp, the NRC, and the State of Pennsylvania providing that State radiation

technicians could provide confirmatory survey support with Oak Ridge Institute of

Science and Technology oversight in order to speed confirmatory surveys.

*Accommodated State request to excavate a trench in area of site to address expressed

concerns of contamination. This was beyond required characterization effort.

*Molycorp agreed to perform post-confirmatory sampling excavation in area of site rather

than addressing through surface averaging with adjacent survey units.

*Decommissioning is complete and acceptable to the NRC staff and the State of

Pennsylvania Department of Environmental Protection.

Molycorp is also seeking liability relief under Pennsylvania Act 2 (brownfield)

legislation to return the York property to beneficial commercial and or industrial use.

Lessons Learned At York

Experience gained while decommissioning the York facility provided many lessons

that are applicable to ongoing decommissioning at Molycorp's Washington facility. Among

valuable lessons learned at York are:

1. Good characterization is worthwhile to plan decommissioning. It enables planners

to have confidence in developing a decommissioning plan and in estimating time and

costs to implement it.

2. While there were some bumps in the road, relations among Molycorp, NRC, and

PADEP staffs were cooperative and positive. Molycorp wants this spirit to carry on

to decommissioning at our Washington site.

3. Excavation cavities must await independent survey to confirm compliance. While

waiting, open cavities sometimes accumulated water, in turn impeding confirmatory

survey. An arrangement with the NRC or the PADEP to minimize delay of

2
Mo~yco; XF

confirmation and backfilling an excavation cavity would be helpful. Such an

arrangement was worked out with NRC at York to expedite confirmatory procedures

to accommodate timely release of survey units where public safety concerns existed.

Whereas the NRC might have ORISE perform a confirmatory survey, the NRC, the

State of Pennsylvania, and Molycorp were able to cooperate to enable the State

PADEP to do some confirmatory sampling and surveying. That reduced travel

logistics and time to confirm compliance in order to reduce delay before backfilling

excavation cavities.

4. The NRC staff worked with Molycorp to adjust the decommissioning plan

implementation to unexpected circumstances. A large volume of soil that was

excavated was well below the maximum radioactivity concentration acceptable for

unrestricted release. NRC, the State, and Molycorp worked to resolve the

management of that soil by developing a procedure to return below criteria soil to an

excavation cavity.

3. WASHINGTON SITE DECOMMISSIONING PLANNING AND PROGRESS

Washington Site History

Industrial operations at the Washington site pre-date the 1900's. Nearby, a

prominent process in early years was coal gasification to supply gas to a glass factory near

the site. The predecessor to Molycorp acquired the original site in 1916. About 20 acres of

the 73 acre Washington site were used for manufacturing operations at some time.

Molycorp has extracted metals and metallic compounds from ore concentrates on the

Washington site. Among the products were molybdenum, tungsten, columbium, boron, and

other rare earth metals and their compounds. Some ore concentrates received as feed

materials contained low concentrations of natural uranium and thorium series

radionuclides. The uranium and thorium series tended to deposit in the slags from the

high temperature reduction processes. Those slags tend to be relatively insoluble.

Remedial Action

The Washington Site had natural uranium and thorium series material residues in

buildings and soil on-site, and is considered a complex site, it was listed for

decommissioning under the SDMP. In response, Molycorp has submitted to the NRC:

. A plan for site characterization

. A site characterization report

. A decommissioning plan in accordance with the SDMP

. An environmental report

Molycorp is decommissioning the Washington facility in logical phases and has

already done a lot of clean-up on the site.

. Residues in eight surface impoundments were removed during June 1995.

. In 1996, Molycorp excavated about 4000 cubic yards of thorium-bearing slag. In 2000,

that slag was disposed at Envirocare in Utah.

3
. In 2000 and 2001, a slag pile of about 10,000 cubic yards was disposed by shipment to

Envirocare in Utah.

. In 2002, 21 buildings were decommissioned, demolished, and disposed. This included

all above-ground structures except the guardhouse and weigh scales. Wastes were

shipped to appropriate waste disposal facilities.

Based on lessons learned at York, Molycorp requested and was granted time to do

additional characterization of the Washington site. Subsequent to the characterization

effort, Molycorp developed an integrated site closure plan that incorporates both

radiological and non-radiological remediation at the site.

Molycorp is continuing to decommission its Washington site, with regulation and

oversight by the NRC, the EPA, and the State of Pennsylvania. We want the spirit of

cooperation developed thus far with the NRC and PADEP staffs to continue as we

decommission our Washington site.

4. OBSERVATIONS TO FACILITATE DECOMMISSIONING

Major Costs of Decommissioning Land

Major costs of decommissioning land are time and resources used to:

1. Develop and obtain approval of a decommissioning plan.

2. Perform final radiation status surveys and obtain approval.

3. Dispose of waste at a regulated facility offsite. Fostering competition by

encouraging additional disposal opportunities would be helpful. (Note: Senator

Domenicci (NM) has recently expressed the need to have more low level sites in the

U.S.)

a. The process of disposing of unimportant concentration source material in

regulated sites, including WCS in Texas and USEcology in Idaho has been safe

and cost-effective.

b. Acceptance of disposal of source material, byproduct material, and of uranium

posing no criticality risk into a uranium mill tailings impoundment would be

helpful. We would encourage the Commission to consider this as a disposal

option.

c. Due to the high cost related with transportation, it would be helpful to have

acceptable disposal sites in the Eastern United States where they would be in

closer proximity to many of the decommissioning sites.

Ability to Apply NRC-approved Options

Flexibility to apply NRC-approved options is desirable, for instance, to do final status

surveys on an SDMP site in accordance with the MARSSIM. A key to effectively managing

project related decommissioning costs is ability of the licensee to select the appropriate

"tools' from approved guidance documents. For example, at our Washington site, it would

be desirable to be able to apply MARSSIM final status survey methodology with existing

concentration based clean-up criteria. MARSSIM statistical-based surveys are in line with

the current thinking on best practices and provide the benefit of clearing areas in a timely

4
Molymi

manner with reduced analytical costs, in contrast with sampling methodology applied

earlier in SDMP clean-ups.

Constructive working relationships need to be in place to work through any issue that

might compromise the flexibility of a licensee to use appropriate "tools" that have been

previously accepted by the NRC. For instance, water management and flooding issues may

be important during excavation activities. If so, Molycorp will need to work out

arrangements with NRC and the State in advance to minimize time and effort associated

with confirmatory sampling.

Realistic Environmental Modeling

The NRC has moved toward acceptance of realistic radiological modeling. It might be

helpful if the NRC staff would work with states and licensees to improve consensus on

radiological modeling.

Cooperation

It would be beneficial for Molycorp, the NRC, and the Pennsylvania DEP to build

upon positive working relationships established at York. Frequent constructive meetings

with NRC and State to work through tactical and operational issues associated with

implementation of decommissioning are helpful. Dan Gillen and the NRC staff and the

DEP should be commended on taking practical, solutions oriented approach in working

through decommissioning issues with licensees. Dan and his staff have been open for

discussion and very approachable. Not always in agreement but through use of sound

science and technical-based discussions we reached workable solutions.

5
Molycorp's "SDMP" Sites

Ray Cherniske

Manager Remediation Sites

Questa, NM

Molycorp Background

* Pennsylvania Processing Sites

- Status

* Current Operations

* Corporate Responsibility

2

1
York, PA Reflections

* Unsuspected Conditions Encountered

* Assessment Conducted

* DP Implementation Adjusted

3

York, PA Reflections

Positives

* Soil Averaging - AAR Methodology

* Over Excavated Material as Fill

* Offsite Dose Modeling

* State Involvement

What's Left

* Act 2 - Brownsfield Legislation

4

2
Washington, PA

Translate Lessons Learned

* Supplemental Characterization

-Use existing DP

-Utilize AAR method

* Constructive Working Relationships

-NRC

- State

- Molycorp

5

Washington, PA

Translate Lessons Learned

* Flexibility Applying Decommissioning

Tools

-Survey Approach

* Timely confirmatory surveys

- Realistic Site Models

-Soil mixing

* Disposal Options

6

3
October 13, 2004

Presentation materials for the NRC Commissioners' briefing on

Decontamination and Decommissioning Activities in

Pennsylvania

Presented by - David J. Allard, CHP, Director

Prepared by - Robert C. Malers, PE, Division Chief,

Jeff Whitehead and Bryan Werner of the

Decommissioning & Environmental Surveillance Division

PA DEP - Bureau of Radiation Protection

P.O. Box 8469

Harrisburg, PA 17105-8469

TEL: 717-787-2480

FAX: 717-783-8965

E-mail: djallard @state.pa.us and rmaiers@state.pa.us

http://www.dep.state.pa.us search key word "radiation"

http://www.dep.state.pa.us/dep/deputate/airwaste/rp/rp.htm

Attachment: Complete "Decontamination and Decommissioning Activities in

Pennsylvania" ppt presentation*

* Note: The actual presentation will not include all slides in this handout; only key

slides will be used to profile example sites for this briefing.
Decontamination and

Decommissioning Activities in

Pennsylvania

David J. Allard, CHP

Presented at the

NRC Decommissioning Briefing

October 13, 2004

7 0>PETRI I ie'"

PA Dept. of Environmental Protection

Bureau of Radiation Protection (BRP)

P.O. Box 8469

Harrisburg, PA 17105-8469

Tel: 717-787-2480

http://www.dep.state.pa.us

Acknowledgements:

Robert Malers, PE, and all the DEP & BRP staff

that work on these sitesl 2

Pennsylvania D&D

Background

* Pennsylvania industry has historically used

radioactive materials and generated waste in

a wide variety of applications.

* Some of these early activities have resulted in

sites with contaminated equipment, structures

and buildings or sites with large volumes of

contaminated soil, slag and contaminated

groundwater.

Major Pennsylvania

D&D Site Groupings

* NRC Site Decommissioning Management Plan

(SDMP) Sites; now "Complex Sites" (14)

* State Radium Decommissioning Sites (3)

* Reactor and Navy Nuclear Sites (5)

* Formerly Utilized Site Remedial Action Plan

(FUSRAP) Sites (3)

* The Uranium Mill Tailings Radiation Control Act

(UMTRCA) Sites (2)

* Unlicensed STPs Requiring Decontamination (2)

Example Sites for Briefing

* Complex sites overview

* Safety Light Corp. (US Radium)

* Quehanna

* Reactor sites

* UMTRCA / Radium sites

* FUSRAP sites

* Flannery building

* Two contaminated STPs

"Complex" D&D / SDMP Sites in PA

( Removed from SDMP list)

* Safety Light Corp

* B&W SLDA

* B&W Parks

Township*

* B&W Apollo'

* Molycorp York'

* Molycorp

Washington

* Budd Company'

Pesses/Metcoa '

Whittaker Corp

* Quehanna

* Waltz Mill

* Schott Glass -

* Cabot Boyertown ^,

Revere, Reading

3

1
Safety Light Facility Safety Light Corporation

* Safety Light Corporation's NRC (-08)

tritium license renewal is the subject an

ASLB hearing request by DEP/BRP.

* DEP/BRP must respectfully refrain from

commenting in detail on the SLC site due

to pending litigation with NRC.

* We can note SLC (the former US Radium)

is also a DEP/BRP NARM licensee for

onsite radium-226 contamination

* EPA has proposed listing SLC on the NPL

B&W Parks Township

* Located next to B&W SLDA

* Composed of 3 buildings and adjacent

property

* Predominate radionuclides Am-241, Pu-241,

Co-60, Cs-137, uranium

* Waste volume estimated at 43,000 ft3 of

LLRW and small amount of > Class C

* Cost estimate $7 million to decommission

* D&D completed, license terminated

Demolition at B&W Parks Facility

B&W Shallow Land Disposal

Area (SLDA)

* Consists of ten waste disposal trenches

* Waste consists of enriched uranium,

thorium, americium, plutonium, and

chemicals (e.g., TCE)

* Waste volume estimated at 700,000 ft3

* Remediation costs range from $8 million

to $60 million depending on which

remediation option is chosen It

B&W Shallow Land Disposal

Area (SLDA) cont.

* Congressional action requires US Army

Corps of Engineers (USACE) to

determine appropriate response actions

and initiate remediation activities under

FUSRAP

* $5 million appropriated for USACE to

begin activities, e.g., Preliminary

Assessment completed
Former Parks Facility and Adjacent

Shallow Land Disposal Area B&W Apollo

* Used as fuel fabricating facility from 1957 to

1983

* Extensive characterization and

decontamination performed from 1984 to

1992

* Decommissioning activities performed from

1992 to 1995

* License terminated and removed from SDMP

in April 1997

* Site still the subject of ongoing litigation by locals residents for alleged health impact

,.

Molycorp Washington Facility

Molycorp, Washington

* Produced metals from ores containing

Th and U

* Resulted in concentrated wastes

* Waste volume estimated at 120,000 yd3

* Licensee previously proposed onsite

disposal cell and "restricted release"

* Licensee changed D-Plan to remediate

to "unrestricted release" criteria

,, 16

Molycorp, York

* Formerly produced rare earth chemicals

from materials containing Th and U

* Production activities ceased in 1992

* Characterization indicated primarily

surface contamination

* Contrary to characterization, large areas

of contamination down to bedrock

* NRC license recently terminated

Molycorp York Pit Excavation

I q t4e re- I

i,

3

Co0
Whittaker Corporation

* Metal production operations generated

waste containing Th and U

* Contamination consists mainly of slag

mixed with rubble and other waste

* Volume of slag estimated at 29,700 m3

* Innovative metal recovery planned

* D&D activities expected to begin shortly

19

Whittaker Slag Pile

I. 11 il Ji. 1'-.:

20

Quehanna

* In late 1950's Curtis-Wright used for research

in nucleonics, metallurgy; included a pooltype research reactor; donated to Penn State

* In early / mid-1 960's research reactor was

dismantled, hot cells used by Martin-Marietta

to manufacture SNAP generators using Sr-90

* M-M had license for 6 MCi of Sr-90!!

* Large Co-60 irradiator was installed in pool

* PermaGrain business failure in 2002; EPA

recently removed 90,000 curies of Co-60

21

Quehanna cont.

* Facility is now owned by Commonwealth of

Pennsylvania

* Portions of the facility were contaminated with

Sr-90, and - 2,000 Ci of old Co-60 sealed

sources were stored in two hot cells

* Much D&D has been completed

* Hot cell 4 interior dismantled by robot

* Hot cell complex structure w/ minor Sr-90

contamination was diamond wire cut

22

Robot Used for Hot Cell 4 - Quehanna Hot Cells

24

4

QO37~_
Waltz Mill TR-2 and Support Buildings

Waltz Mill

* Licensed activities include possession only

license for test reactor

* Most contamination attributed to fuel failure in

test reactor that occurred in April 1960

* Contaminated buildings and former lagoons

(soil and GW contaminated)

* Soil remediation complete, GW quality greatly

improved

25 26

TR-2 Reactor Tank Removal Cabot Corp Reading

* Processed ores containing U and Th

* Process resulted in slag containing

concentrated levels of U and Th

* Pennsylvania has documented concerns with

exposure scenarios, and that site is poorly

characterized

* Licensee proposes leaving waste on site and

terminating license with an unrestricted

release

* Environmental Justice area?

27 26l

Cabot Reading Aerial Photo Cabot Reading Slag Disposal

29 30

5

COW
Pennsylvania Reactor and

Federal Facility D&D

* Three Mile Island Unit 2 (PWR)

* Shippingport Atomic Power Station

(PWR)

* Saxton Experimental Reactor (PWR)

* Peach Bottom Atomic Power Station

Unit 1 (HTGR)

* Navy's Bettis Atomic Power Laboratory

31

Three Mile Island Unit 2

* Post-accident cleanup of Unit 2 began in

August 1979 and ended in December 1993

* Approximately 100 tons of damaged fuel

removed to IN EL, approximately 1% of fuel

and debris remain in vessel

* Total cost of cleanup $973 million

* Final decommissioning deferred until Unit 1 is

ready to be decommissioned

32

Three Mile Island Nuclear Power Station

_ _ TINENO=NI-1

Shippingport Atomic Power

Station

* 1957 PWR demo plant, converted in 1977 to

a light water breeder, operated until 1982

* Shippingport was the nation's first large-scale

nuclear power plant decommissioning project

* The decommissioning project provided

relevant information for decommissioning

PWRs throughout the world

* Decommissioning completed in June 1989 at

a cost of $91.3 million

Shippingport Atomic Power Station

- I' -eA,, A

, _r o -_b 

Shippingport After Decommissioning

S&..1kq::.,Ipl.t AVf-,O P.---v Slat;0a

35

S.S'l:,1;/::1V:1-:? S...v rl-vy

36

6

Go;5
Saxton Facility Saxton Experimental Reactor

* Completed in 1962 for research, testing and

demonstration of nuclear power production

* Pressurized water reactor rated at 35 MW(t) powering an old coal-fired plant

* Operated until 1972, fuel shipped to

Savannah River Site

* Total decommissioning cost estimated at over

$50 million

* ANS Historical Marker recently placed on the

site

* License termination expected in 2005 37 38

Peach Bottom Atomic

Power Station Unit 1

* A prototype high temperature gascooled reactor

* Operated from March 1966 to October

1974

* Decommissioning work began in

January 1976 and ended February 1978

* Fuel was removed, and now the plant is

in monitored "safe-store" condition

Peach Bottom Unit 1 Reactor Installation

3/26/64

40

Formerly Utilized Site Remedial

Action Plan (FUSRAP) Sites

* DOE program shifted to Army Corps of

Engineers by Congress

* Aliquippa Forge Site

- In 1940's used for a uranium-rolling operation

- DOE started cleanup in 1988, completed 1994 - Waste shipped to Hanford, Washington

* C.H. Schnoor

- Provided uranium metal fabrication services

for Manhattan Project in the 1940's - DOE began and completed cleanup in 1994

* Superbolt facility (former Superior Steel)?

Uranium Mill Tailings Radiation Control

Act (UMTRCA), old Radium-226 Processing

and Other Sites

* Canonsburg disposal cell

* Burrell disposal cell (Blairsville, PA)

* Sellersville

* Lansdowne

* Austin Avenue

* Flannery Building (Parkvale Bank)

* Others?

42
Canonsburg

(Standard Chemical)

* Facility used for extraction of radium from

carnotite ore from 1911 to 1942

• From 1942 to 1957 operations turned to

recovery of uranium from ores and scrap

• Between 1984 and 1986, approx. 172,000

yd3 of contaminated soil and materials

stabilized in on-site disposal cell by DOE

43

Standard Chemical Facility

I .R W.: ,4%1. He 

Circa 1921

Canonsburg's circa 1978 Canonsburg Site Before Remediation

Documentary Film

45 46

Canonsburg Cell After Remediation Canonsburg Disposal Cell

7?
Parkvale Bank

(Flannery Building)

* Refined radium from the Canonsburg facility

concentrates; first commercial production of

radium in the U.S.; produced - 180 g Ra-226

* Madame Curie likely visited to tour radium

production operations in early 1920's

* Building decontaminations ci 960 and c 970

neglected drains, vents, sewer lines and

other inaccessible floor / ceiling areas

* Contamination detected ci 998; final cleanup

action taken under BRP license 49

Flannery Building

so

Sellersville Landfill Remediation Sellersville

* Site included an inactive landfill used by

several manufacturing companies, including

the c1 915 Radium Company of America

* DEP performed a cleanup in 1996-97

* Approximately 6,400 yd 3 of radium

contaminated soil sent to Envirocare

* Total cost of cleanup over $6 million

51

Lansdowne

* From 1924-1944 a physics professor

operated a radium source processing

laboratory in the basement of a duplex

* Contamination spread to both sides of

the house and adjacent properties

* Placed on EPA NPL in 1985

* EPA completed cleanup in 1991 at a

cost of $11.6 million

Austin Avenue

* Centered around properties near a

radium refining facility

* Involved same principle as in the

Lansdowne site

* Tailings from the refining facility were

discovered in 40 houses on Austin

Avenue (in the Philadelphia area)

53 54
Sewage Treatment Plants

Requiring Decontamination

* Kiski Valley Water Pollution Control

Authority (KVWPCA)

* Royersford Wastewater Treatment

Facility (RWTF)

55

Kiski Valley Water Pollution

Control Authority (KVWPCA)

* Received effluents from nearby B&W

Apollo nuclear fuel fabrication facilities

* Sludge ash lagoon contains - 9,000 m3

of contaminated ash and is located

within floodplain

* After nearly 10 years of evaluation,

NRC dose assessment indicates

unrestricted release is acceptable

56

KVWPCA Sludge Ash Lagoon Royersford Wastewater

Treatment Facility (RWTF)

* Received effluent containing Co-60, Cs-I 37, and

other fission products from local nuclear laundry

* Radioactive materials were reconcentrated in the

sewage sludge

* Contaminated sludge land-applied in past, and

pumped to reed beds for volume reduction

* Sludge is now sent to RCRA D landfills

* Nuclear laundry responsible for reed bed under

NRC regulations?

57 5,

RWTF Reed Bed

RWTF - plant systems

59

10

cog
Conclusions Comments and Concerns

* Pennsylvania has a wealth of

experience in a wide variety of

decommissioning projects

* Pennsylvania has decommissioning

experience as a licensee as well as

being a regulator

* Pennsylvania has worked closely with

NRC, other federal agencies and

licensees on D&D projects

Al

* Some regulatory inconsistencies noted in NRC

Headquarters and Regions

* LTR offers greater flexibility to licensees, but is

more challenging for state regulators

* Large discrepancies between characterization

and actual conditions may result in inefficient or

incomplete decommissioning

* Use of limited exposure scenarios to achieve

unrestricted release (e.g., industrial, trespasser)

Thank you.

Questions?

'3

11
Decontamination and

Decommissioning Activities in

Pennsylvania

David J. Allard, CHP

Presented at the

NRC Decommissioning Briefing

October 13, 2004

N .11' ,. I

AllI

PA Dept. of Environmental Protection

Bureau of Radiation Protection (BRP)

P.O. Box 8469

Harrisburg, PA 17105-8469

Tel: 717-787-2480

http://www.dep.state.pa.us

Acknowledgements:

Robert Maiers, PE, and all the DEP & BRP staff

that work on these sites!

2

1
Pennsylvania D&D

Background

* Pennsylvania industry has historically used

radioactive materials and generated waste in

a wide variety of applications.

* Some of these early activities have resulted in

sites with contaminated equipment, structures

and buildings or sites with large volumes of

contaminated soil, slag and contaminated

groundwater.

3

Major Pennsylvania

D&D Site Groupings

* NRC Site Decommissioning Management Plan

(SDMP) Sites; now "Complex Sites" (14)

* State Radium Decommissioning Sites (3)

* Reactor and Navy Nuclear Sites (5)

* Formerly Utilized Site Remedial Action Plan

(FUSRAP) Sites (3)

* The Uranium Mill Tailings Radiation Control Act

(UMTRCA) Sites (2)

* Unlicensed STPs Requiring Decontamination (2)

2
/

Example Sites for Briefing

* Complex sites overview

* Safety Light Corp. (US Radium)

* Quehanna

* Reactor sites

* UMTRCA / Radium sites

* FUSRAP sites

* Flannery building

* Two contaminated STPs

5

"Complex" D&D / SDMP Sites in PA

(* Removed from SDMP list)

* Safety Light Corp

* B&W SLDA

* B&W Parks

Township*

* B&W Apollo*

* Molycorp York*

* Molycorp

Washington

* Budd Company*

* Pesses/Metcoa *

* Whittaker Corp

* Quehanna

* Waltz Mill

* Schott Glass *

* Cabot Boyertown *,

Revere*, Reading

6

3
Safety Light Corporation

* Safety Light Corporation's NRC (-08)

tritium license renewal is the subject an

ASLB hearing request by DEP/BRP.

* DEP/BRP must respectfully refrain from

commenting in detail on the SLC site due

to pending litigation with NRC.

* We can note SLC (the former US Radium)

is also a DEP/BRP NARM licensee for

onsite radium-226 contamination

* EPA has proposed listing SLC on the NPL

7

Safety Light Facility

8
Quehanna

* In late 1950's Curtis-Wright used for research

in nucleonics, metallurgy; included a pooltype research reactor; donated to Penn State

* In early / mid-1 960's research reactor was

dismantled, hot cells used by Martin-Marietta

to manufacture SNAP generators using Sr-90

* M-M had license for 6 MCi of Sr-90!!

* Large Co-60 irradiator was installed in pool

* PermaGrain business failure in 2002; EPA

recently removed 90,000 curies of Co-60

Quehanna cont.

* Facility is now owned by Commonwealth of

Pennsylvania

* Portions of the facility were contaminated with

Sr-90, and - 2,000 Ci of old Co-60 sealed

sources were stored in two hot cells

* Much D&D has been completed

* Hot cell 4 interior dismantled by robot

* Hot cell complex structure w/ minor Sr-90

contamination was diamond wire cut

,0

5
Robot Used for Hot Cell 4 -

Quehanna Hot Cells

12

6

C\\
Cabot Corp Reading

* Processed ores containing U and Th

* Process resulted in slag containing

concentrated levels of U and Th

* Pennsylvania has documented concerns with

exposure scenarios, and that site is poorly

characterized

* Licensee proposes leaving waste on site and

terminating license with an unrestricted

release

* Environmental Justice area?

1 3

Cabot Reading Aerial Photo

14

7
Cabot Reading Slag Disposal asr Cub tS-., .s . ho~9' .9*0 ak w. 4* Ea Ad _Fte arm _

c d* is 4 cn.S C. x.. 5 W.. S~l**.' Ca.. ... F.

ah_ e C i a S n flt*'~ CU . 9 4. -b~~_lftM,* 4 9 5

~15

Pennsylvania Reactor and

Federal Facility D&D

* Three Mile Island Unit 2 (PWR)

* Shippingport Atomic Power Station

(PWR)

* Saxton Experimental Reactor (PWR)

* Peach Bottom Atomic Power Station

Unit 1 (HTGR)

* Navy's Bettis Atomic Power Laboratory

16

8
-------

Formerly Utilized Site Remedial

Action Plan (FUSRAP) Sites

* DOE program shifted to Army Corps of

Engineers by Congress

* Aliquippa Forge Site

- In 1940's used for a uranium-rolling operation

- DOE started cleanup in 1988, completed 1994

- Waste shipped to Hanford, Washington

* C.H. Schnoor

- Provided uranium metal fabrication services

for Manhattan Project in the 1940's

- DOE began and completed cleanup in 1994

* Superbolt facility (former Superior Steel)? 17

Uranium Mill Tailings Radiation Control

Act (UMTRCA), old Radium-226 Processing

and Other Sites

* Canonsburg disposal cell

* Burrell disposal cell (Blairsville, PA)

* Sellersville

* Lansdowne

* Austin Avenue

* Flannery Building (Parkvale Bank)

* Others?

18

9
Parkvale Bank

(Flannery Building)

* Refined radium from the Canonsburg facility

concentrates; first commercial production of

radium in the U.S.; produced 180 g Ra-226

* Madame Curie likely visited to tour radium

production operations in early 1920's

* Building decontaminations cl 960 and ci 970

neglected drains, vents, sewer lines and

other inaccessible floor / ceiling areas

* Contamination detected ci 998; final cleanup

action taken under BRP license

19

Flannery Building

20

10

013
Sewage Treatment Plants

Requiring Decontamination

* Kiski Valley Water Pollution Control

Authority (KVWPCA)

* Royersford Wastewater Treatment

Facility (RWTF)

21

Kiski Valley Water Pollution

Control Authority (KVWPCA)

* Received effluents from nearby B&W

Apollo nuclear fuel fabrication facilities

* Sludge ash lagoon contains - 9,000 m3

of contaminated ash and is located

within floodplain

* After nearly 10 years of evaluation,

NRC dose assessment indicates

unrestricted release is acceptable

22

11
KVWPCA Sludge Ash Lagoon

a' pi X A_

i'' ' IA_ &

A L..

i _

23

Royersford Wastewater

Treatment Facility (RWTF)

* Received effluent containing Co-60, Cs-1 37, and

other fission products from local nuclear laundry

* Radioactive materials were reconcentrated in the

sewage sludge

* Contaminated sludge land-applied in past, and

pumped to reed beds for volume reduction

* Sludge is now sent to RCRA D landfills

* Nuclear laundry responsible for reed bed under

NRC regulations?

24

12

Cut -F
RWTF - plant systems

25

RWTF Reed Bed

26

13

CuIŽ
Conclusions

* Pennsylvania has a wealth of

experience in a wide variety of

decommissioning projects

* Pennsylvania has decommissioning

experience as a licensee as well as

being a regulator

* Pennsylvania has worked closely with

NRC, other federal agencies and

licensees on D&D projects

27

Comments and Concerns

* Some regulatory inconsistencies noted in NRC

Headquarters and Regions

* LTR offers greater flexibility to licensees, but is

more challenging for state regulators

* Large discrepancies between characterization

and actual conditions may result in inefficient or

incomplete decommissioning

* Use of limited exposure scenarios to achieve

unrestricted release (e.g., industrial, trespasser)

28

14
Thank you.

Questions?

29

15
Briefing to the Commissioners

of the

U.S. Nuclear Regulatory

Commission

by:

David G. Culberson, Chairman

Fuel Cycle Facilities Forum

October 13, 2004 Fuel Cycle Facilities Forum 1

Purpose:

* Overview of Fuel Cycle Facilities Forum

(FCFF)

* Recent accomplishments

* Decommissioning issues of importance to

fuel cycle facilities

October 13, 2004 Fuel Cycle Facilities Forum 2

1
Overview of the Fuel Cycle

Facilities Forum (FCFF)

* SNM and source material licensees (fuel

processors and specialty metal refiners)

* Decommissioning focus

* Sites/facilities that require special NRC

consideration (those "few difficult sites")

* Industry advocate for decommissioning

* Resource to NRC staff

October 13,2004 Fuel Cycle Facilities Forum 3

Accomplishments

* Excellent working relationship with NRC

* White Papers on key D&D issues: - Phased approach to decommissioning

- Direct disposal of non-1 1e(2) material in Mill tailings impoundments

* Forum for sharing industry D&D experience, lessons learned, obstacles, and issues

* 16 years history representing industry on most

challenging D&D issues

* Submitted comments on numerous proposed rulemaking and guidance initiatives

October 13, 2004 Fuel Cycle Facilities Forum 4

2
Issues of Importance to Fuel Cycle

Facilities

* Additional cost-effective disposal options

* Flexibility in applying criteria and guidance

for interim cleanup and partial site release

* Consistency among and between State

agencies and NRC

* Increased assurance of finality

* Prioritization of site-specific information

required for decommissioning planning

October 13. 2004 Fuel Cycle Facilities Forum 5

Issues of Importance to Fuel Cycle

Facilities

* Continuation of workshops and tabletop

exercises to share implementation experience,

lessons learned, obstacles, and alternative

solutions

* improved efficiency in the development,

approval, and implementation of FSS's and

site/facility release

* Additional NRC guidance regarding S&S,

emergency planning, and NCS required during

decommissioning

October 13, 2004 Fuel Cycle Facilities Forum 6

3
Briefing to the Commissioners

of the

U.S. Nuclear Regulatory Commission

October 13, 2004

Presented at:

The Commission's Conference Room

NRC Headquarters

One White Flint North

11555 Rockville Pike

Rockville, MID

Presented by:

David G. Culberson, Chairman

Fuel Cycle Facilities Forum
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

Presented by:

David G. Culberson, Chairman

Fuel Cycle Facilities Forum

W'hat is the Fuel Cycle Facilities Forum?

The Fuel Cycle Facilities Forun (FCFF) is a consortium of licensees whose purpose is to

provide a forum for addressing technical and regulatory issues that affect the

decommissioning of fuel cycle facilities and specialty metal refiners whose feed ore contains

source material. The FCFF represents a broad range of source and special nuclear material

licensees, including many who are actively involved in the remediation and/or

decommissioning of portions of their sites. The FCFF represents fuel cycle licensees at

public workshops and meetings, seeks to involve the fuel cycle industry in the rulemaking and

draft regulatory guidance development process by offering comments on issues that will

impact industry, and facilitates communication between affected licensees and the NRC.

To a large extent, the facilities represented by the FCFF are of a size and/or complexity as to

frequently require special NRC consideration in regard to decommissioning. This not only

applies to final decommissioning for license termination, but also to decommissioning

required to meet the Timeliness Rule requirements for separate buildings or outdoor areas

during the period when licensed operations will continue (i.e., "partial" decommissioning).

For fuel cycle licensees, the major costs and challenges of decommissioning are time and

resources associated with disposal of solid wastes (primarily soil and building debris),

preparation and review of decommissioning plans and procedures, development and approval

of release criteria, and final status surveys. Hence, these tend to be the primary issues

addressed by the FCFF.

The FCFF strives to focus its efforts solely on these and other decommissioning issues,

thereby enabling the group to be more effective and to maintain an active and loyal following

of member companies. The FCFF has been effective in achieving real results for the

Fuel Cvcle Facilities Forna October 13. 2004

Page 2 of 8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

industry, has been a successful and effective advocacy group for licensees who are

undergoing decommissioning, and has been an effective facilitator for communication and

interaction between NRC and the fuel cycle industry on important decommissioning issues.

The FCFF focuses its efforts largely on implementation issues, which has enabled the group

to be an effective sounding board for the NRC on rulemaking, guidance and inspection issues.

W1hat are some of the notable recent accomplishments of the FCFF?

1. One of the most noteworthy accomplishments of the FCFF over its 16-year history has

been the establishment of an excellent working relationship with the decommissioning and

waste management staffs of the NRC. This has led to open and constructive dialogue

between the NRC and the fuel cycle industry on many important issues, has enabled both

the NRC and industry to make meaningful progress on decommissioning fronts, has led to

more streamlined efforts (and presumably cost savings) for both NRC and industry, and

has led to a better understanding of the issues impacting regulators and licensees. In

recent years, the FCFF has observed improvements in the manner in which the staff

interacts with stakeholder groups on decommissioning matters, and specifically the

manner in which the agency has supported, encouraged and involved fuel cycle

representatives on important issues affecting that industry. As result, there is evidence

that the feedback and comments of the fuel cycle industry have been genuinely been

accepted and considered by the staff, as evidenced by overall improvements in the

rulemaking, licensing, and inspection processes. The Decommissioning and Waste

Management staffs continue to seek the input and involvement of the FCFF, specific fuel

cycle licensees and this industry's experts on emerging issues affecting decommissioning,

and the FCFF would encourage the Commission to continue and support that practice.

2. Discussions with NRC Waste Management Division staff during an industry-led tabletop

exercise in February 2001 led to a consensus that some of the obstacles that have

previously prevented timely start and completion of decommissioning could be

eliminated, or mitigated by applying a phased (streamlined) performance-based, riskFutel Cycle Facilities Forum October 13, 2004

Page 3 of 8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

informed approach to decommissioning. This was summarized in a Draft TW1ite Paperj,

submitted to the NRC in May 2001, which summarizes the key aspects and issues of such

an approach, and the preliminary conclusions by those in attendance. Need to establish

specific guidance to implement a "phased approach" to decommissioning.

3. For over 8 years, the FCFF and the National Mining Association (NMA)2 Uranium

Environmental Subcommittee have been discussing the benefits of utilizing existing

uranium mill tailings impoundments for the disposal of certain fuel cycle materials that

are chemically, physically and radiologically similar to the material already in the

impoundment. In response to the Environmental Protection Agency's (EPA's) Advance

Notice of Proposed Rulemaking (ANPR) titled Approaches to an Integrated Framework

for Management and Disposal of Low-Activity Radioactive Waste, the FCFF and the

NMA recently jointly submitted a White Paper to NRC, lWhite Paper on Direct Disposal

of Non-lIe.(2) Byproduct Materials in Uranium Mill Tailings Impoundments, that

espouses the merits of disposal of non-1 le(2) materials in Mill tailings impoundments.

The White Paper provides a complete and compelling regulatory basis for the option and

proposes generic acceptance criteria for acceptance of certain nonl 1e2 materials. Several

licensees, including fuel cycle and uranium mining/milling, have expressed an interest in

pursuing such an approach but need assistance from NRC in determining the best path

forward.

4. The identification and sharing of decommissioning experiences, lessons learned,

obstacles, and stakeholder issues continues to be principle focus and success of the FCFF.

The FCFF has successfully developed and nurtured an environment of candor, trust and

confidence among its member companies in matters pertaining to decommissioning, and

thus has successfully garnered the support of its member companies and the NRC for over

16 years.

White Paper Discussion: Phased Approach to the Decommissioning of Fuel Cycle Facilities. Prepared by the

Fuel Cycle Facilities Forum. May 2001.

2 The National Mining Association (NMA) represents producers of most of America's coal, metals, industrial and

agricultural minerals; manufacturers of mining and mineral processing machinery and supplies; transporters;

financial and engineering firms; and other businesses related to coal and hardrock mining. NMA has member

companies who are NRC licensees with uranium mill tailings facilities.

Fuel Cvcle Facilities Fonrzn October 13, 2004

Page 4 of 8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

What are the issues of greatest concern to fuel cyclefacilities?

* There is an urgent need for additional cost-effective disposal alternatives for high-volume,

low-activity bulk decommissioning wastes. One excellent example of a technically sound,

safe, and cost-effective alternative that has been identified by the FCFF and the NMA is

the use of uranium mill tailings impoundments for fuel cycle decommissioning wastes.

The FCFF and NMA have identified several existing uranium mining and milling sites

that have sufficient capacity to accept most, if not all of the anticipated decommissioning

waste generated by fuel cycle facilities for the foreseeable future, and several fuel cycle

licensees have expressed an interest in utilizing this alternative under the proper

regulatory controls and framework. Other viable examples of disposal alternatives

include: use of RCRA Subtitle C landfills, as addressed in EPA's ANPR; the conditional

use provisions of NRC's rulemaking for Controlling the Disposition of Solid Materials;

and, allowing unrestricted release of inherently safe sources, as contained in the

rulemaking for Controlling the Disposition of Solid Materials. Further, without

diminishing environmental protection, the costs of solid waste disposal for fuel cycle

licensees may be controlled more effectively by allowing near-background radionuclide

concentration in soil to be returned to an excavation cavity, by allowing near-background

radionuclide concentration in soil or building debris to be disposed in an EPA Class C

landfill or an industrial waste landfill, and by enabling additional disposal facilities, which

would promote economic competition. It is worth noting that licensees that do not belong

to the Rocky Mountain, Northwest or Atlantic Compacts will not be able to dispose of

Class B/C LLW after 2008. Although fuel cycle facilities primarily generate Class A

waste, this will affect all license that wish to dispose of sealed sources (since EOU can't

accept these sources).

* There is a need for moreflexibility in applying decommissioning guidance when

addressing interim site cleanup, partial site remediation, or partial site release when a

facility operating license will not being terminated and the area/facility will not be

released for unrestricted use. The current definition of "decommissioning" as contained

in the NRC's regulations is overly prescriptive for those situations. Based on recent

Fuel Cycle Facilities Fortun October 13, 2004

Page 5 of 8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

favorable discussions between the FCFF and NRC, a phased (streamlined) performancebased, risk-informed approach to decommissioning, which would allows many

decommissioning-related activities to be conducted under an operating license, makes

sense. Specific NRC guidance for implementing such an approach would be useful.

* There is a need for continued NRC attention to consistency in application of

decommissioning requirements and guidance, particularly among Agreement and NonAgreement State regulatory agencies and between individual licensees. Fuel cycle

licensees have encountered inconsistencies in the regulatory process among State agencies

(both Agreement States and Non-Agreement States), between State agencies and the

NRC, and within the NRC, in areas such as decommissioning planning, cleanup criteria,

timeliness, and grandfathering. It is worth noting that not all Agreement States have

adopted a License Termination Rule that incorporates a 25 mrem/year dose standard, thus

it is important that consensus between licensee and regulatory agencies be reached early in

the process regarding development of cleanup criteria.

* With respect to fuel cycle facilities, the establishment of the MOU between NRC and EPA

concerning residual radioactivity levels at sites undergoing decommissioning has not

resolved the issue of finality. The FCFF anticipates that the majority of fuel cycle

facilities will most likely be included on the MOU action list even though they can

demonstrate that they meet the 25 mrem per year dose standard. This leaves a number of

fuel cycle facilities with difficult decisions as to how and when to proceed with

decommissioning, since there is a perceived real possibility (and likelihood?) that the

licensee cannot reach finality even if they meet restrictive NRC criteria. Some licensees

are already faced with the dilemma of choosing between delaying cleanup until finality

can be assured, versus proceeding with a costly cleanup effort under a perceived risk that

there is no end in sight.

* The NMSS Decommissioning Standard Review Plan has largely removed the uncertainty

of what the NRC staff expects to review and that a licensee should address in their

decommissioning plan. The staff and licensees now have enough experience with the

guidance to work toward prioritizing what is likely to be needed in a plan for a given site.

Fuel Cycle Facilities Foruam October 13, 2004

Page 6of8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

Prioritizing to include material of substantial importance to a given site, instead of

developing content for all items on the planning and review checklist, could help make

both preparation and review of a decommissioning plan more efficient, take less time, and

cost less.

* Workshops that the NRC has sponsored and tabletop exercises that the FCFF has

sponsored have been useful to examine lessons learned and implementation of NRC

regulations and regulatory guidance and the FCFF encourages the continued use of both.

With the experience gained experience in implementing the decommissioning regulations

and guidance, it would be useful to have a focused work-shop-like forum to share

decommissioning experiences and lessons learned to date, and to learn of pertinent NRC

guidance on problematic issues. Prospective participants could be licensees, the FCFF,

the NRC, NEI, EPRI, State agencies, and the NRC confirmatory survey contractor,

ORISE. A workshop concerning quality assurance in final status surveys, data

management, and reporting could be useful to enable all stakeholders to improve

knowledge of expectations and confidence in final status surveys. Workshops to air

regulatory development and licensee experience have been useful during development of

the decommissioning regulation and of implementation guidance documents. Continued

public discussion and opportunity for feedback during development of such guidance

documents as the Multi-agency Radiation Survey and Analysis of the Subsurface manual

or of the Multi-agency Radiation Survey of Material and Equipment manual could be

useful.

* The FCFF has found that performing final radiation status surveys, preparing the reports,

confirmatory surveys, and Agency review prominently consume time and resources of

both licensee and regulatory agencies. Some effort to improve efficiencies of interaction

between agencies and licensee could be useful. In addition, when excavation cavities are

open, improved coordination between NRC staff, NRC confirmatory survey contractor

(ORISE), the State environmental protection agency, and the licensee is needed for

confirmatory surveillance and to minimize time a cavity must remain open.

Fuel Cvcle Facilities Forum October 13, 2004

Page 7 of 8
Briefing to the Commissioners of the U.S. Nuclear Regulatory Commission

October 13, 2004

* Additional specific NRC guidance is needed regarding required security, safeguards,

emergency planning and nuclear criticality safety controls when decommissioning

involves large quantities of low concentration of enriched uranium.

For further information concerning the FCFF, contact:

David Culberson, Chairman

Fuel Cycle Facilities Forum

c/o Nuclear Fuel Services, Inc.

1205 Banner Hill Road

Erwin, TN 37650

Phone: (423) 743-1756

Fax: (423) 743-1780

Fuel Cvcle Facilities Forum October 13, 2004

Page 8 of 8
A{t A A ft nl

BREG& u6 u D i

204 DECOMMISSIONI

PRGRAV BRIEFING

Daniel Gillen

Div. of Waste Mgnt. & Environmental Protection

Office of Nuclear Material Safety & Safeguards

BLeau

1
l~troduc ion

* Decommissioning Program

* Evolution of Program

o Accomplishments

e Specific Commission Interests

- West Valley Demonstration Project

- EPA Memorandum of Understanding

0 On the Horizon

* Challenges

2
s mecoissioning

Program

* Office of Nuclear Material Safety and Safeguards

- Division of Waste Management and

Environmental Protection - Division of Fuel Cycle Safety and Safeguards

* Office of Nuclear Reactor

Regulation

* Regions

o Office of Research

3
atalysts for Program

Change

e Fiscal Constraints

* Timeliness Concerns

e Strategic Goals

* License Termination Rule

Implementation Difficulties

* Self Assessments

4
Evolution of Scope

e Power Reactor Transfers

* Elimination of the Site

Decommissioning Management

Plan

* Comprehensive Decommissioning

Program

e Monitoring/Support Role

5
Evolulio of Framewor

* License Termination Rule

o 2003 Financial Assurance

Rulemaking

0 NUREG 1 757 r."' B

o NUREG 1700

II

> -. i-N - er7 C /tt'/;J,?a / n I/I0

6
Evoluti of orocess

e 90-day Acceptance reviews

e "6Proactive" Interactions

* Realistic Scenarios

* Focused Inspections

7
LTP Approval Rates

Site (LTP submitted)

40/

35-

30-

25m

20k

c,,_ _ _ _ _ _ _ _ _ _ _ _ _

1 5k

/010.~OA 4

:9

8
Site Specific

A<:omlish ents;

o 5 Decommissioning Plan/License

Termination Plan Acceptance

Reviews

o I Decommissioning Plan Revier

o 2 Final Status Survey Reviews

o 20 Licensing Actions

o 2 Sites Terminated

9
Parks Township site

1 995

10
Parks Township site

20041

11
Programmatic

* Comprehensive Decommissioning

Program

e License Termination Rule Analysis

Recommendations

o Mixing Policy

o Program Evaluation

o International Activities

12
Innovative Approaches

* Kiski Valley Water Pollution

Control Authority

* Fansteel

e Shieldalloy

rJefferson Proving Ground

13
Radionuclide Transport Research

in Support of Decommissioning

Accomplishment: More realistic analyses of doses from residual radioactivity to reduce conservatism in license termination reviews.

Barrier

Reactive

Transport Model

Transport

Calculations

-U -

N

Dose Assessment

14
Accomplish ents - Regions

* 4 Decommissioning Plan

Acceptance Reviews

o 9 Final Status Survey Reviews

o 96 Inspections

o 30 Licensing Actions

9 2 Sites Terminated

15
* Policy Statement

* Dept. of Energy/New York State

Energy Research and

Development Authority: Differing

Interests

e Schedules/Future Activities

16
EANRCO

* Criteria for Consultation

* Site-Specific Consultation

Continues

* Revising Guidance

* Outreach Efforts

* Future Activities

17
on the Horizon

* Continue Implementation of

License Termination Rule

Recommendations

* Implement Program Improvement

Plan

* Communication Strategy

* 2006 Office of Management and

Budget Performance Assessment

Rating Tool Evaluation

18
Challenges

* Sites: Safetylight, Fansteel, West

Valley, Non-licensees

* Issues: Restricted Use, Soil Mlixing,

Multiple Regulators

* Resources: Estimating Resources

Given the Uncertainty of Licensee

Plans

19
Summary

o Decommissioning Program

Continues to Mature

- Improvements and Efficiencies

- Complex Sites

-Technical/policy Issues

- Increased Flexibility

-Program Improvements

20