A nuclear power plant client needed to decontaminate and decommission (D&D) a New England plant. The billion-dollar project included decontaminating and dismantling all structures above grade and backfilling the deep basements. This would terminate the site’s U.S. Nuclear Regulatory Committee (NRC) license and achieve site closure under the state’s Agency of Natural Resources. The project involved many stakeholders and phases, including the remediation of soil with non-radiological (or chemical) issues, which requires geological, hydrogeological, and permitting expertise.
Although the NRC regulates all nuclear electric generation plants, this project is also regulated by the state and U.S. Environmental Protection Agency (EPA) for non-radiological constituents, particularly non-radiological constituents (fuel oils, per-and polyfluorinated substances, metals, etc.) in soil, groundwater, sediments, and surface water. Any missed permit or regulatory deadline could impact schedules and progress, making this phase fit on the operation’s critical path.
Haley & Aldrich has a longstanding relationship as a trusted advisor to the client. They sought our expertise due to our understanding of how crucial timely permitting and compliance were to this project’s critical path and meeting the site closure deadline.
We used our knowledge of the nuclear decommissioning process to develop a proactive approach based on the client’s risk tolerance. In this case, the client’s most significant risk was safety – all work needed to be done safely. Second, we needed to provide high-quality deliverables, on time. Our client’s critical path could not be disrupted and our team knew that in order to do so, it was vital to meet all permit deadlines.
Even though nuclear-decommissioning projects operate under NRC oversight, our team’s part of the project, the non-radiological portion, was under EPA and the state’s site cleanup regulations. For this project, remediation focused on fuel oils and inorganics. Meeting the state’s regulations required us to get ahead of and identify ways to dovetail the radiological and non-radiological activities to avoid duplication during characterization efforts. We used our compliance expertise to support permit transfers, including National Pollutant Discharge Elimination System (NPDES), portable drinking water compliance, residual management, Stormwater Protection Prevention Plan (SWPPP), and additional construction permits.
“We had to do one part of this huge project – but if we didn’t do it right, we could derail the whole thing. Our focus was to be precise and stay out of the critical path.”Nadia Glucksberg, Senior Associate
Additionally, Haley & Aldrich’s staff attended biweekly regulatory meetings in support of the project. Our fact-based approach bolstered the client’s public relations. Our team had a high-touch relationship with our client, including attending daily construction meetings, to assure everyone that we were compliant and safely remediating the site. Using our technical and permitting expertise along with transparent communication, Haley & Aldrich staff hit deadlines seamlessly, staying out of the critical path during the site’s D&D program.
- Used technical expertise to stay out of the critical path and keep the large project on track
- Represented the client with the state regulators to work through opposition by using transparency and supportive facts
- Collected defensible data to demonstrate compliance to meet the project goals and meet the residential soil criteria
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