**NRC INSPECTION MANUAL** IRIB

TEMPORARY INSTRUCTION 2515/173

REVIEW OF THE IMPLEMENTATION OF THE INDUSTRY GROUND WATER PROTECTION
VOLUNTARY INITIATIVE

CORNERSTONE: PUBLIC RADIATION SAFETY

APPLICABILITY: This Temporary Instruction (TI) applies to all holders of
operating licenses for nuclear power reactors, including those plants
which have permanently ceased operations.

NRR inspection staff will inspect operating plants (i.e. all holders of
operating licenses for nuclear power reactors), and plants in
decommissioning (i.e. those that have permanently ceased operations) if
they are on the same site as those with operating reactors.

2515/173-01 OBJECTIVES

The objective of this TI is to assess ground water protection programs
to determine whether licensees have implemented the voluntary industry
Ground Water Protection Initiative (i.e., the objective is not to
perform an assessment of the adequacy of the licensee's ground water
monitoring program). The Ground Water Protection Initiative (GPI) was
unanimously approved by a formal vote of the Nuclear Energy Institute
(NEI) member utility chief nuclear officers, which establishes the
industry's commitment to implement the initiative. (Ref: ML062260198).
The GPI identifies the actions the industry deems necessary for
implementation of a timely and effective ground water protection
program.

The NEI GPI is described in the document, "Industry Ground Water
Protection Initiative -- Final Guidance Document, August 2007\" (Ref:
ML072600292 and ML072610036). The information will be used to validate
industry's implementation of the voluntary industry initiative and to
aid in evaluating whether additional NRC regulatory actions are
warranted.

2515/173-02 APPLICABILITY

This TI applies to all holders of operating licenses for nuclear power
reactors, including nuclear power reactors that have permanently ceased
operations.

2515/173-03 BACKGROUND

There have been multiple recent and historical groundwater contamination
incidents of heightened NRC and public interest. As a result, the
industry has taken action as specified in the NEI documents, "Industry
Ground Water Protection Action Plan Development Interim Guidance
Document -- June 2006: Action Plan Development (ML061950017) and
Voluntary Communication Section (ML061950015)" and "Industry Ground
Water Protection Initiative -- Final Guidance Document, August 2007
(ML072600292 and ML072610036).\"

Under the Interim GPI, each site was to develop a site-specific/company
ground water protection program and implement voluntary communication
programs by July 31, 2006. Under the final GPI, each site is to have
developed an effective, technically sound ground water protection
program by August 2008. In accordance with NUREG-BR-0075, Rev 4, Item
14, the purpose of this TI is to assess the licensee's implementation of
the industry GPI. Note: These industry actions are voluntary and
generally beyond NRC requirements.

2515/173-04 INSPECTION REQUIREMENTS

Inspection staff should assess the licensee's response to the questions
in the GPI as provided in this section. These inspection requirements
are to be conducted in part at NRC Regional Offices and in part at
operating power reactor facilities.

1.  [Inspection Criteria for Ground Water Protection
    Program]{.underline}.

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a.  Review and verify the implementation of the licensee's written
    ground water protection (GPI) program based upon the groundwater
    protection criteria described in "Industry Ground Water Protection
    Initiative -- Final Guidance Document, August 2007\" (NEI-GPI).

b.  Improve management of situations involving inadvertent radiological
    releases that get into ground water.

[GPI Objective 1.1 - Site Hydrology and Geology]{.underline}.

Perform a site characterization of the geology and hydrology that
provides an understanding of predominant ground water gradients based
upon current site conditions.

Note: Technical questions related to site hydrology and geology should
be referred to NRC Headquarters.

a.  Have (new or updated) hydrogeologic and geologic studies been
    performed to determine the predominant ground water flow
    characteristics and gradients?

b.  As appropriate, have existing hydrogeologic and geologic studies,
    historical environmental studies, and permit or license related
    reports been reviewed (by knowledgeable utility or contractor staff?
    If practical, document the qualifications of the utility or
    contractor staff performing the reviews).

c.  Have potential pathways been identified for ground water migration
    from on-site locations to off-site locations through ground water?

d.  Has a frequency been established for periodic review of
    hydrogeologic studies (e.g., whenever there is substantial on-site
    construction, disturbance of site property, changes in on-site or
    nearby off-site use of water, or changes in on-site or nearby
    off-site pumping rates of ground water)?

e.  As appropriate, has the Final Safety Analysis Report been revised to
    include changes to the characterization of hydrology and/or geology?

[GPI Objective 1.2 - Site Risk Assessment]{.underline}.

a.  On a sampling basis (3-5 samples), have SSCs and work practices been
    identified that involves or could reasonably be expected to involve
    licensed material and for which there is a credible mechanism for
    licensed material to reach ground water?\
    \
    Note: Some examples of SSCs are outdoor refueling water storage
    tanks, spent fuel pools, spent fuel pool leak detection systems,
    outdoor tanks, outdoor storage of contaminated equipment, buried
    piping, retention ponds, basins, or reservoirs, and steam lines.
    Some examples of leak detection methods for the SSCs are ground
    water monitoring, operator rounds, engineering walk downs or
    inspections, leak-detection systems, or periodic integrity testing.

b.  Have existing leak detection methods been identified for each SSC
    and work practice that involves or could reasonably be expected to
    involve licensed material and for which there is a credible
    mechanism for licensed material to reach ground water?

c.  Have potential enhancements been identified to leak detection
    systems or programs (e.g., increased frequency of rounds or walk
    downs, inspections, or integrity testing)?

d.  Have potential enhancements been identified to prevent spills or
    leaks from reaching ground water (e.g., resealing or paving surfaces
    or installing spill containment measures)?

e.  Has the mechanism or site process been identified for tracking
    corrective actions?

f.  Has a long term program been established to perform preventative
    maintenance or surveillance activities to minimize the potential for
    inadvertent releases of licensed materials due to equipment failure?
    Note: A detailed review of this long-term program is not required.

g.  Has a frequency been established for periodic reviews of SSCs and
    work practices?

[GPI Objective 1.3 - On-Site Ground Water Monitorin]{.underline}.

Establish an on-site ground water monitoring program to ensure timely
detection of inadvertent radiological releases to ground water.

a.  Based on the hydrology and geology studies, did the licensee
    consider placement of ground water monitoring wells down gradient
    from the plant but within the site boundary?

b.  Did the licensee consider, as appropriate, placing sentinel wells
    closer to SSCs that have the highest potential for inadvertent
    releases that could reach ground water or SSCs where leak detection
    capability was limited?

c.  Has the licensee established sampling and analysis protocols,
    including analytical sensitivity requirements for ground water and
    soil?

d.  Has a formal, written program been established for long term ground
    water monitoring? Was the site's ODCM/ODAM revised to include ground
    water monitoring locations that are included in the REMP?

e.  Have analytical capabilities (station or contract lab) been
    periodically reviewed or is there a plan to perform a periodic
    review?

f.  Has a long-term program been established for preventative
    maintenance of ground-water wells?

g.  Has a frequency been established for the periodic review of the
    ground water monitoring program?

[GPI Objective 1.4 - Remediation Process]{.underline}.

a.  Have written procedures been established outlining the decision
    making process for the remediation of leaks and spills or other
    instances of inadvertent releases, and does the process consider
    migration pathways?

b.  Has an evaluation been made of the potential for detectible levels
    of licensed material from planned releases of liquids and/or
    airborne materials (e.g., rain-out and condensation)?

c.  As appropriate, has an evaluation been performed and documented on
    the decommissioning impacts resulting from remediation activities or
    the absence thereof (e.g., do licensee procedures include a decision
    making process to evaluate prompt remediation or delayed remediation
    and its impact on decommissioning)?

[GPI Objective 1.5 - Record Keeping]{.underline}.

Ensure that records of leaks, spills, and remediation efforts are
retained and retrievable to meet the requirements of 10 CFR 50.75(g).

a.  Has a record keeping program been established to meet the
    requirements of 10 CFR 50.75(g)? (see RIS 2002-02, "Lessons Learned
    Related to Recently Submitted Decommissioning Plans and License
    Termination Plans, Attachment 1, paragraph 8).\
    \
    Note: During operations, residual radioactivity that would be
    significant for decommissioning planning would be a quantity of
    radioactive material that would later require remediation during
    decommissioning in order to terminate the license by meeting the
    unrestricted use criteria stated in 10 CFR 20.1402.

    1.  [Inspection Criteria for Communication]{.underline}. Improve
        communication with external stakeholders to enhance trust and
        confidence on the part of the local communities, States, NRC,
        and the public in the nuclear industry's commitment to a high
        standard of public radiation safety and protection of the
        environment.

        [GPI Objective 2.1 - Stakeholder Briefing]{.underline}.

        Each licensee should conduct initial and periodic briefings of
        their site specific GPI program with the designated State/Local
        officials.

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a.  Have initial briefings been conducted with designated State and
    Local officials of the site specific GPI program? This determination
    can be accomplished by discussions with licensee staff.

b.  Have licensees considered including additional information or
    updates on ground water protection in periodic discussions with
    State/Local officials?

c.  For licensees that are in States where multiple nuclear power plants
    are located and multiple-owner companies have licensees coordinated
    efforts and communicated with each other?

    [GPI Objective 2.2 - Voluntary Communications]{.underline}.

    Make informal communication as soon as practical to appropriate
    State/Local officials, with follow-up notification to the NRC,
    regarding significant (i.e., of interest to public or stakeholders
    per NEI) on-site leaks and spills into ground water and on-site or
    off-site water sample results exceeding the criteria in the REMP.

d.  Leaks or spills - Have communications been made to designated
    State/Local officials before the end of the next business day?

    1.  For spills or leaks exceeding 100 gallons from a source
        containing licensed material?

    2.  If the volume of a spill or leak cannot be quantified but is
        likely to exceed 100 gallons from a source containing licensed
        material?

    3.  For any leak or spill, regardless of volume or activity, deemed
        by the licensee to warrant voluntary communication?

e.  Water sample results -- Have communications been made to local
    authorities before the end of the next business day?

    1.  Of off-site ground water or surface water samples exceeding REMP
        reporting criteria for water as described in the ODCM/ODAM?

    2.  Of on-site ground water, that is hydrologically connected to
        ground water, or ground water that is or could be used as a
        source of drinking water that exceeds any of the REMP reporting
        criteria for water as described in the ODCM/ODAM?

f.  When communicating with the State/Local officials, are licensees
    clear and precise in quantifying the actual release information as
    it applies to appropriate regulatory criteria (i.e., put into
    perspective)?

g.  As appropriate, has the NRC been notified of voluntary
    communications to State and/or Local officials under 10 CFR
    50.72(b)(2)(xi)?

    [GPI Objective 2.3 - Thirty Day Reports]{.underline}.

    Submit a written 30-day report to the NRC for any water sample
    results for [on-site]{.underline} ground water that may be used as a
    source of drinking water that exceeds an of the criteria in the
    licensee's existing REMP as described in the ODCM/ODAM for 30-day
    reporting of [off-site]{.underline} water sample results. Copies of
    the written 30-day reports for both on-site and off-site water
    samples should also be provided to the appropriate State/Local
    officials.

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a.  Are ground water samples analyzed and compared to the standards and
    limits contained in the station's REMP as described in the
    ODCM/ADAM?

b.  Have any 30 day special reports been submitted to the NRC?

c.  Were any 30 day reports submitted to NRC also submitted to
    designated State/Local officials?

[GPI Objective 2.4 Annual Reporting]{.underline}.

Document all on-site ground water sample results and a description of
any significant on-site leaks/spills into ground water for each calendar
year in the Annual Radiological Environmental Operating Report (AREOR)
for REMP or the Annual Radiological Effluent Release Report (ARERR) for
the RETS as contained in the appropriate reporting procedure, beginning
with the report for calendar year 2006.

a.  Documentation

    1.  Were appropriate changes made to the ODCM/ODAM or to the
        appropriate procedures to support the 2007 report of 2006
        performance for plants that were operating or decommissioning
        when the GPI was adopted?

    2.  Were all on-site ground water sample results and a description
        of any significant on-site leaks/spills into ground water for
        each calendar year reported in the AREOR or ARERR beginning with
        the report for calendar year 2006?

b.  Sample Results

    1.  Have on-site ground water sample results taken in support of the
        GPI but are not part of the REMP program (e.g., samples obtained
        during the investigatory phase of the Action Plan circa
        year 2006) been reported in the ARERR as required by 10 CFR
        50.36a(a)(2)? Note to Inspectors: Sampling data from long term,
        permanent wells that are put into the REMP program are reported
        in the Environmental Report. Similarly, data from test wells not
        placed into the REMP program are reported in the Effluent
        Report.

    2.  Have on-site ground water sample results taken in support of the
        GPI that are part of the REMP program as described in the
        ODCM/ODAM been reported in the AREOR?

c.  Have annual reports (see
    <http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html>)
    included the following:

    1.  For leaks and spills that were communicated to local/State
        authorities -- does the ARERR contain a description of these
        spills and leaks?

    2.  For water sample results -- have all on-site and off-site sample
        results that exceeded REMP reporting thresholds that were
        communicated to State/local officials also included in the ARERR
        and/or in the AREOR?

04.03 [Inspection Criteria for Program Oversight]{.underline}.

Perform program oversight to ensure effective implementation of the GPI
program.

[GPI Objective 3.1 - Perform a Self Assessment of the GPI
program]{.underline}.

a.  Has an independent, knowledgeable individual performed the initial
    self assessment within one year of implementation (no later than
    December 31, 2008)?

b.  Are periodic self assessments of the GPI program planned for at
    least once every five years after the initial self assessment?

c.  Does the self assessment include an evaluation of the implementation
    of all of the GPI objectives?

d.  Is the self assessment documented in accordance with station
    procedures and programs?

[GPI Objective 3.2 - Review the Program Under the Auspices of
NEI]{.underline}

Conduct a review of the GPI program, including at a minimum the
licensee's self assessments, under the auspices of NEI.

a.  Has an independent, knowledgeable individual performed the initial
    review within one year of the initial self assessment per Objective
    3.1.a above?

b.  Have plans been established to perform a periodic review of the GPI
    program every 5 years, subsequent to the licensee's periodic
    self-assessment performed per Objective 3.1.b above?

    2515/173-05 REPORTING REQUIREMENTS

The results of the inspection should be reported similarly to findings
from the routine reactor inspection program in accordance with IMC 0612,
"Power Reactor Inspection Reports" (i.e., the results are documented in
the quarterly integrated inspection report, Section 4OA5). The report
should include the dates of the inspection and a short discussion of the
results to include deviations from the NEI-GPI protocols.

2515/173-06 COMPLETION SCHEDULE

This TI is to be initiated September 1, 2008 and completed by August 30,
2010.

2515/173-07 EXPIRATION

This TI will remain in effect for 24 months (August 30, 2010).

2515/173-08 CONTACT

Any technical questions regarding this TI should be addressed to Steven
Garry, at telephone 301-415-2766 or steven.garry@nrc.gov.

2515/173-09 STATISTICAL DATA REPORTING

All direct inspection effort expended on this TI is to be charged to
2515/173 for reporting by the HRMS system with an IPE code of TI.

2515/173-10 ORIGINATING ORGANIZATION INFORMATION

10.01 [Organizational Responsibility]{.underline}. This TI was initiated
by the Reactor Inspection Branch (NRR/ADRO/DIRS/IRIB).

10.02 [Resource Estimate]{.underline}. It is anticipated that the
resources needed to implement the TI requirements are estimated to be up
to 40 hours of office and direct inspection. This TI can be performed in
conjunction with the performance of the periodic baseline inspections
performed for the radioactive liquid effluent treatment monitoring
systems and the radiological environmental monitoring program (IP
71122.01 and 71122.03). Completion of this TI can be used to take credit
for up to 16 hours of required baseline inspection for IP 71122.01 and 8
hours of required baseline inspection for IP 71122.03.

10.03 [Training]{.underline}. Inspectors performing this inspection must
meet the basic training for inspectors specified in IMC 1245,
\"Inspector Qualifications.\" However, if technical support is needed
during the inspection, contact Steven Garry, at telephone 301-415-2766
or steven.garry@nrc.gov.

.

END

ATTACHMENT 1

Revision History for TI 2515/173

REVIEW OF THE IMPLEMENTATION ON GROUNDWATER PROTECTION INITIATIVE

+--------+-------+--------------------+-----+----------+-------------+
| Comm   | Issue | Description of     | Tr  | Training | Comment     |
| itment | Date  | Change             | ain | Co       | Resolution  |
| Tr     |       |                    | ing | mpletion | Accession   |
| acking |       |                    | Nee | Date     | Number      |
| Number |       |                    | ded |          |             |
+--------+-------+--------------------+-----+----------+-------------+
| N/A    | 05/   | This TI is being   | N/A | N/A      | ML081090425 |
|        | 29/08 | issued to collect  |     |          |             |
|        |       | information on     |     |          |             |
|        | CN    | Industry's         |     |          |             |
|        | 0     | adherence to the   |     |          |             |
|        | 8-016 | Industry Ground    |     |          |             |
|        |       | Water Protection   |     |          |             |
|        |       | Initiative and     |     |          |             |
|        |       | verify if actions  |     |          |             |
|        |       | have been in       |     |          |             |
|        |       | accordance with    |     |          |             |
|        |       | the Initiative.    |     |          |             |
+--------+-------+--------------------+-----+----------+-------------+
| N/A    | 10/   | Change of          | N/A | N/A      | ML082770339 |
|        | 31/08 | reporting          |     |          |             |
|        |       | requirements and   |     |          |             |
|        | CN    | documentation.     |     |          |             |
|        | 0     |                    |     |          |             |
|        | 8-031 |                    |     |          |             |
+--------+-------+--------------------+-----+----------+-------------+