EVALUATION REPORT

Evaluation of NRC’s Oversight of Tritium Production at 

Commercial Nuclear Power Plants

OIG-11-A-19 September 21, 2011

All publicly available OIG reports (including this report) are accessible through

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

September 21, 2011

MEMORANDUM TO: R. William Borchardt

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: EVALUATION OF NRC’S OVERSIGHT OF TRITIUM 

PRODUCTION AT COMMERCIAL NUCLEAR POWER 

PLANTS (OIG-11-A-19)

Attached is the Office of the Inspector General’s (OIG) audit report titled, Evaluation of 

NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants. 

The report presents the results of the subject evaluation. Agency comments provided at 

the September 9, 2011, exit conference have been incorporated, as appropriate, into 

this report.

We appreciate the cooperation extended to us by members of your staff during the 

evaluation. If you have any questions or comments about our report, please contact me 

at 415-5915 or Sherri Miotla, Team Leader, Nuclear Materials and Waste Safety Audit 

Team, at 415-5914. 

Attachment: As stated 
Electronic Distribution

Edwin M. Hackett, Executive Director, Advisory Committee 

 on Reactor Safeguards

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety 

 and Licensing Board Panel

Stephen G. Burns, General Counsel

Brooke D. Poole, Director, Office of Commission Appellate Adjudication

James E. Dyer, Chief Financial Officer

Margaret M. Doane, Director, Office of International Programs

Rebecca L. Schmidt, Director, Office of Congressional Affairs

Eliot B. Brenner, Director, Office of Public Affairs

Annette Vietti-Cook, Secretary of the Commission

R. William Borchardt, Executive Director for Operations

Michael F. Weber, Deputy Executive Director for Materials, Waste,

 Research, State, Tribal, and Compliance Programs, OEDO

Darren B. Ash, Deputy Executive Director 

 for Corporate Management, OEDO

Martin J. Virgilio, Deputy Executive Director for Reactor

 and Preparedness Programs, OEDO

Nader Mamish, Assistant for Operations, OEDO

Kathryn O. Greene, Director, Office of Administration

Patrick D. Howard, Director, Computer Security Office

Roy P. Zimmerman, Director, Office of Enforcement

Cynthia Carpenter, Acting Director, Office of Federal and State Materials

 and Environmental Management Programs

Cheryl L. McCrary, Director, Office of Investigations

Thomas M. Boyce, Director, Office of Information Services

Miriam L. Cohen, Director, Office of Human Resources

Michael R. Johnson, Director, Office of New Reactors

Catherine Haney, Director, Office of Nuclear Material Safety

 and Safeguards

Eric J. Leeds, Director, Office of Nuclear Reactor Regulation

Brian W. Sheron, Director, Office of Nuclear Regulatory Research

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights

James T. Wiggins, Director, Office of Nuclear Security

 and Incident Response

William M. Dean, Regional Administrator, Region I

Victor M. McCree, Regional Administrator, Region II

Mark A. Satorius, Regional Administrator, Region III

Elmo E. Collins, Jr., Regional Administrator, Region IV
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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EXECUTIVE SUMMARY

BACKGROUND

The Nuclear Regulatory Commission (NRC) is responsible for ensuring 

that nuclear power plant licensees operate nuclear power plants in a 

manner that protects public health and safety and the environment. 

Tritium is a radioactive isotope of hydrogen used in U.S. nuclear weapons. 

In 1999, Federal law authorized tritium production at two commercial 

nuclear power plants owned by the Tennessee Valley Authority (TVA).

The Department of Energy (DOE) works with the Department of Defense 

to maintain the quantity and quality of the U.S. nuclear weapons stockpile. 

Tritium production at commercial nuclear power plants involves the 

redesign of an important reactor core component as well as coordination

between NRC and DOE. To produce tritium, the normal absorbing 

material in the reactor core, boron, is replaced by an isotope of lithium, 

requiring a redesign of the absorber rods. That isotope of lithium is an 

absorber like boron, but the nuclear reaction it undergoes during the 

absorption process also produces tritium. Such rods are called tritium 

producing burnable absorber rods (TPBARs). 

On May 22, 1996, the Secretary of Energy and the NRC Chairman signed 

a memorandum of understanding that established the basis for NRC 

review and consultation regarding DOE’s use of commercial nuclear 

reactors for producing tritium. NRC reviewed DOE’s proposal to test fuel 

assemblies containing TPBARs in a commercial nuclear reactor and 

DOE’s safety assessments on tritium production. In May 1999, NRC

issued its own safety evaluation. Subsequently, NRC also issued license 

amendments to TVA allowing loading of TPBARs at Watts Bar Nuclear 

Power Plant Unit 1 and Sequoyah Nuclear Power Plant Units 1 and 2, 

although tritium production has only occurred at Watts Bar Unit 1.

RESULTS IN BRIEF 

NRC’s oversight of tritium production at commercial nuclear power plants 

is generally effective. The Office of the Inspector General (OIG) also 

concluded that NRC’s licensing of tritium production at two nuclear power 

plants owned by TVA is permitted under Federal law and although tritium 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

ii

effluents have increased from TVA’s Watts Bar Unit 1 during tritium 

production, they are still well below regulatory limits. However, there are 

some areas that merit management’s consideration. OIG determined that:

It is unclear to stakeholders whether TVA needs subsequent NRC 

authorization to produce tritium at Sequoyah Units 1 and 2.

NRC’s communication with stakeholders regarding tritium production 

could be improved. 

AGENCY COMMENTS

Agency comments provided during a September 9, 2011, exit conference 

have been incorporated, as appropriate, into this report. The agency 

declined to provide formal comments. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

iii

ABBREVIATIONS AND ACRONYMS

Ci Curie 

CFR Code of Federal Regulations

DOE Department of Energy

OIG Office of the Inspector General

mrem millirem

NRC Nuclear Regulatory Commission

μCi/ml Micro curries per milliter

TVA Tennessee Valley Authority 

TPBARs Tritium Producing Burnable Absorber Rods 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ......................................................................i

ABBREVIATIONS AND ACRONYMS ................................................. iii

I. BACKGROUND.................................................................... 1

II. PURPOSE ........................................................................... 7

III. RESULTS ............................................................................ 7

A. NRC’s Licensing of Tritium Production Is 

Permitted Under Federal Law.......................................8

B. Watts Bar Unit 1 Tritium Effluents Increased, 

and Are Below Regulatory Limits....................................... 8

C. It Is Unclear to Stakeholders Whether TVA Is 

Authorized To Produce Tritium at 

Sequoyah Units 1 and 2 ..................................................11

D. NRC’s Communication Regarding Tritium

Production Could Be Improved ........................................13

IV. AGENCY COMMENTS .......................................................15

APPENDIX

SCOPE AND METHODOLOGY..........................................16
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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I. BACKGROUND

The Nuclear Regulatory Commission (NRC) is responsible for ensuring 

that nuclear power plant licensees operate nuclear power plants in a 

manner that protects public health and safety and the environment. 

Tritium is a radioactive isotope1of hydrogen used in U.S. nuclear 

weapons. Traditionally, U.S. commercial nuclear power production has 

been independent of the Nation’s nuclear weapons program. However, in 

1999, Federal law authorized tritium production at two commercial nuclear 

power plants owned by the Tennessee Valley Authority (TVA).2 As NRC 

continues to provide oversight of tritium production, the agency may need 

to identify new approaches to licensing and communications.

NRC’s Mission

NRC’s mission is to regulate the Nation’s civilian use of nuclear materials 

to ensure adequate protection of public health and safety, promote the 

common defense and security, and protect the environment. NRC’s 

regulatory mission covers regulation of commercial reactors generating 

electric power and research and test reactors used for research, testing, 

and training. Currently, there are 104 nuclear power reactors licensed to 

operate in the United States, and these reactors generate about 20 

percent of the Nation’s electrical use. 

What is Tritium? 

Tritium, a radioactive isotope of hydrogen, is produced naturally in the 

upper atmosphere when cosmic rays strike nitrogen molecules in the air. 

Like hydrogen, tritium reacts with oxygen to form water. However, when 

tritium reacts with oxygen, it forms tritiated water. Tritiated water is water 

in which some of the non-radioactive hydrogen atoms in the water are 

replaced by tritium. Tritium can enter the human body when people 

swallow tritiated water. People are exposed to small amounts of tritium 

every day since it is widely dispersed in the environment and in the food 

chain. As with all ionizing radiation, exposure to tritium increases the risk 

 

1

Atoms that have the same number of protons but different numbers of neutrons are isotopes. 

2

TVA is a Federal corporation set up by Congress and is the Nation’s largest public power company, 

supplying electricity to people in parts of seven southeastern States. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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of developing cancer. However, because tritium emits very low energy 

ionizing radiation and leaves the human body relatively quickly, tritium is 

one of the least dangerous radioactive isotopes.

Tritium is a crucial component of U.S nuclear weapons; it is used in U.S. 

nuclear warheads to enhance the explosive yield. Tritium has a relatively 

short half-life3of approximately 12 years – it decays at a rate of about 5 

percent per year. Tritium’s relatively short half-life makes it necessary for 

routine replenishing in U.S. nuclear weapons. 

Tritium Production

Although tritium occurs naturally in the environment and as a byproduct of 

electricity production at commercial nuclear reactors, the amounts of 

tritium from these sources are too small for practical use. Therefore, 

tritium must be produced in larger quantities. The production of tritium 

requires the generation of energetic neutrons. One way of producing 

these neutrons is through the use of a nuclear reactor. 

To produce tritium in a nuclear reactor for use in nuclear weapons, a 

redesign of an important reactor core component is required. Some 

commercial nuclear reactors contain burnable absorber rods in the reactor 

core that control the production and distribution of heat in the core by 

absorbing excess neutrons that would otherwise produce fission reactions. 

To produce tritium in a nuclear reactor, the normal absorbing material, 

boron, is replaced by an isotope of lithium, requiring a redesign of the 

absorber rods. That isotope of lithium is an absorber like boron, but the 

nuclear reaction it undergoes during the absorption process also produces 

tritium. Such rods are called tritium producing burnable absorber rods 

(TPBARs). 

The National Nuclear Security Administration, a semi-autonomous agency 

within the Department of Energy (DOE), works with the Department of 

Defense to maintain the quantity and quality of the U.S. nuclear weapons 

stockpile. On December 5, 1995, DOE issued a Record of Decision in 

which it committed to ensuring adequate tritium production capability for 

 

3 Half-life is the time in which one half of the atoms of a particular radioactive substance disintegrate into 

another nuclear form. Measured half-lives can vary from millionths of a second to billions of years. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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the Nation’s nuclear weapons.4 The decision initiated DOE’s lease of 

irradiation services from an existing commercial nuclear reactor. On May 

7, 1999, DOE selected commercial nuclear power plants, TVA’s Watts Bar 

Unit 1 and Sequoyah Units 1 and 2, as its long-term sources for tritium 

production.

NRC Oversight of Tritium Production 

Commercial nuclear power plants are required to operate in accordance 

with NRC regulations and their NRC operating licenses. NRC licenses 

contain technical specifications that are derived from a nuclear power 

plant’s safety analysis and NRC regulations. Technical specifications 

impose safety limits on power plant operations and require certain 

surveillance activities, design features, and administrative controls under 

which a licensee must operate its nuclear power plant. Changes to 

technical specifications require NRC approval via a license amendment. 

Tritium production at commercial nuclear reactors involves coordination

between NRC and DOE. On May 22, 1996, the Secretary of Energy and 

the NRC Chairman signed a memorandum of understanding that 

established the basis for NRC review and consultation regarding DOE’s 

use of commercial nuclear reactors for producing tritium. As such, NRC 

assisted DOE in assessing and resolving technical and licensing issues 

involved in using commercial reactors for tritium production. More 

specifically, NRC reviewed DOE’s proposal to test irradiation of a limited 

number of fuel assemblies containing TPBARs in a commercial nuclear 

reactor. NRC documented its safety review of DOE’s proposal to test a 

limited number of fuel assemblies in NUREG-1607,

5 which was published 

in 1997. NRC also reviewed DOE’s safety assessments on tritium 

production and issued its safety evaluation6in May 1999. 

 

4 Historically, tritium for replenishment of existing nuclear weapons was produced in a nuclear reactor –

the K reactor, at DOE’s Savannah River Site in South Carolina. In 1988, the reactor was shut down for 

safety reasons and no additional tritium was produced by DOE for weapons purposes. 

5 NUREG-1607 is titled, “Safety Evaluation Report related to the Department of Energy’s proposal for the 

irradiation of lead test assemblies containing tritium-producing burnable absorber rods in commercial 

light-water reactors.” 

6 NUREG-1672 is titled, “Safety Evaluation Report related to the Department of Energy’s topical report on 

the tritium production core.” 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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NRC Licensing of Tritium Production at Watts Bar Unit 1 

Watts Bar Nuclear Plant, Unit 1, is located near Spring City, Tennessee –

60 miles southwest of Knoxville, Tennessee. Watts Bar Unit 1 is a 

Westinghouse four-loop pressurized water reactor. Watts Bar Unit 1’s 

operating license was issued February 7, 1996, and expires November 9, 

2035. Watts Bar Unit 1, the last commercial nuclear unit in the United

States to come online in the 20th century, began commercial operation in 

May 1996. 

Since Watts Bar Unit 1 came online, NRC has issued multiple license 

amendments allowing irradiation of TPBARs. In August 2001, TVA filed 

an application to amend the Watts Bar Unit 1 operating license to allow for 

irradiation of up to 2,304 TPBARs in the reactor core each fuel cycle.

NRC issued a license amendment in September 2002 approving 

irradiation of 2,304 TPBARs as requested by TVA in the Watts Bar Unit 1 

reactor. In its May 1999 safety evaluation on DOE’s tritium production 

program, NRC explained that DOE established a permeation goal of less 

than 1 curie7per year per TPBAR. However, the actual permeation rate8 

was up to 4.2 curies per year per TPBAR. Therefore, if Watts Bar Unit 1 

irradiated 2,304 TPBARs, the permeation of tritium might have been 

approximately 9,600 curies into the reactor coolant annually. There are no 

regulatory requirements governing the amount of tritium allowed in the 

reactor coolant. In May 2003, TVA requested another license amendment 

to reduce the amount of TPBARs to be irradiated to 240 TPBARs per 

cycle in Watts Bar Unit 1. NRC approved that request in October 2003. In 

May 2009, NRC issued another license amendment, number 77, which 

authorized TVA to irradiate up to 704 TPBARs at Watts Bar Unit 1. Table 

1 depicts the license amendments issued by NRC to TVA allowing 

irradiation of TPBARs at Watts Bar Unit 1. 

 

7

A curie (Ci) is a unit used to measure the intensity of radioactivity. It refers to the amount of ionizing 

radiation released when an element spontaneously emits energy as a result of the radioactive decay (or 

disintegration) of an unstable atom. Radioactivity is also the term used to describe the rate at which 

radioactive material emits radiation, or how many atoms in the material decay (or disintegrate) in a given 

time period. One Ci is equal to 37 billion (3.7 x 1010) disintegrations per second.

8

The permeation rate is the amount of tritium that leaks into the reactor coolant annually. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Table 1: NRC License Amendments Allowing TPBARs at Watts Bar Unit 1

Date License Amendment

Number

Number of TPBARs

(upper limit permitted)

September 15, 1997 8

9

32

September 23, 2002 40 2,304

October 8, 2003 48 240

January 18, 2008 67 400

May 4, 2009 77 704

Source: Office of the Inspector General (OIG) analysis of NRC documents. 

NRC issued a violation to TVA because TVA did not inform NRC of the 

higher than expected permeation rate in a license amendment request for 

Watts Bar Unit 1. In March 2010, NRC inspectors reported that TVA failed 

to submit complete and accurate information for the license amendment.

The failure to submit complete and accurate information was determined 

to be a minor violation because TVA configured the core TPBAR loading 

in a conservative manner. According to NRC, this lack of information 

resulted in NRC giving TVA allowance to change the configuration of the 

core, which NRC may not have otherwise permitted. The higher than 

expected permeation rate of tritium from TPBARs into the reactor coolant 

at Watts Bar Unit 1 and the actual number TPBARs were not known by 

NRC until the program was reviewed by the Government Accountability 

Office.10

 

9

License amendment number 8 permitted Watts Bar Unit 1 to load 32 lead test assemblies containing 

TPBARs in the reactor core. 

10 GAO-11-100, “Nuclear Weapons: National Nuclear Security Administration Needs to Ensure Continued 

Availability of Tritium for the Weapons Stockpile” (October 2010).
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Table 2 depicts the actual number of TPBARs irradiated at Watts Bar Unit 

1. Watts Bar Unit 1 had 240 TPBARs installed from fall 2003 to spring

2008. That number was increased to 368 in spring 2008, and then 

reduced to 240 again in fall 2009, then increased to 544 in the fuel cycle

that started in spring 2011.

Table 2: Actual TPBARs Irradiated at Watts Bar Unit 1 Per Cycle

Approximate Fuel 

Cycle Dates Fuel Cycle Number ofTPBARs Irradiated

Fall 1997 - Spring 1999 2 32

Spring 1999 - Fall 2000 3 0

Fall 2000 - Spring 2001 4 0

Fall 2001 - Fall 2003 5 0

Fall 2003 - Spring 2005 6 240

Spring 2005 - Fall 2006 7 240

Fall 2006 - Spring 2008 8 240

Spring 2008 - Fall 2009 9 368

Fall 2009 - Spring 2011 10 240

Spring 2011 - Present 11 544

Source: OIG analysis of TVA documents.

NRC Licensing of Tritium Production at Sequoyah Units 1 and 2

Sequoyah Nuclear Power Plant Units 1 and 2 are located near SoddyDaisy, Tennessee – 9.5 miles northeast of Chattanooga, Tennessee. 

Both Sequoyah Units 1 and 2 are Westinghouse four-loop pressurized 

water reactors. Sequoyah Unit 1’s operating license was issued 

September 17, 1980, and expires September 17, 2020. Sequoyah Unit 

2’s operating license was issued September 15, 1981, and expires 

September 15, 2021.
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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In September 2001, TVA filed an application to amend the Sequoyah 

Units 1 and 2 plant licenses to allow for the irradiation of up to 2,256 

TPBARs in the reactor core each fuel cycle. In September 2002, NRC 

issued license amendment numbers 278 and 269, to Sequoyah Units 1 

and 2, respectively, approving irradiation of up to 2,256 TPBARs. On 

December 1, 2003, NRC issued license amendment numbers 289 and 

279 for the Sequoyah Units 1 and 2, respectively, revising the plants’ 

technical specifications, but still allowing up to 2,256 TPBARs to be 

irradiated each fuel cycle. Tritium production has not commenced at 

either of the Sequoyah units. 

II. PURPOSE

The evaluation objective was to determine the effectiveness of NRC’s 

oversight of tritium production at commercial nuclear reactors. 

III. RESULTS

NRC’s oversight of tritium production at commercial nuclear power plants 

is generally effective. However, there are some areas that merit 

management’s attention. OIG determined that:

NRC’s licensing of tritium production is permitted under Federal 

law.

Tritium effluents from Watts Bar Unit 1 have increased during 

tritium production, although they are still well below regulatory 

limits.

It is unclear to stakeholders whether TVA needs subsequent NRC 

authorization to produce tritium at Sequoyah Nuclear Power Plant

Units 1 and 2. 

NRC’s communication with stakeholders regarding tritium 

production could be improved. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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A. NRC’s Licensing of Tritium Production Is Permitted Under Federal 

Law

On October 5, 1999, President Clinton signed the National Defense 

Authorization Act for Fiscal Year 2000, Public Law 106-65, into law. Of 

particular significance to NRC are the provisions authorizing and 

appropriating funds for DOE’s use of commercial light water reactors for 

the production of tritium for weapons purposes. The act expressly 

requires DOE to meet its tritium production needs by using TVA’s Watts 

Bar and Sequoyah nuclear sites, commercial facilities licensed by NRC. 

Specifically, section 3134(a) of subtitle C provides that the Secretary of 

Energy “shall produce new tritium to meet the requirements of the DOE at 

the TVA Watts Bar and Sequoyah nuclear power plants.” By specifically 

authorizing and appropriating funds for DOE’s production of tritium at TVA 

facilities, Congress has eliminated any prior statutory ambiguity as to 

whether these particular commercial facilities may be used for tritium 

production for nuclear weapons purposes. NRC license amendments 

were required to reconfigure the TVA facilities to allow for the production 

of tritium. 

B. Watts Bar Unit 1 Tritium Effluents Increased, and Are Below 

Regulatory Limits

During the time tritium has been produced at Watts Bar Unit 1, levels of 

tritium being released into the environment have increased, although the 

levels remain below regulatory limits.

Tritium Effluent Releases from Watts Bar Unit 1 Have Increased

Effluent releases are the controlled, monitored radioactive liquid or 

gaseous discharges from nuclear power plants. Licensees are required to 

submit annual effluent release reports to NRC. These reports are publicly 

available. 

The trend of tritium effluents released each year by Watts Bar Unit 1 has 

generally increased over the 10-year period beginning in 2001. Although 

tritium effluents are increasing, this cannot be attributed only to the

irradiation of TPBARs at Watts Bar Unit 1 because tritium is a byproduct at 

all nuclear power plants, including those without TPBARs. According to 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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OIG analysis of TVA effluent reports, the average of annual tritium 

releases from 2001 through 2005 was 971 curies per year, and the 

average of annual tritium releases from 2006 through 2010 was 1,565 

curies per year, an increase of about 61 percent. Table 3 shows the total 

curies of tritium annual liquid effluents released from Watts Bar Unit 1. 

Table 3:

Source: OIG analysis of TVA reports. 

Tritium effluent releases from nuclear power plants generally do not cause 

ground water contamination. Tritium in ground water at or near nuclear 

power plants has been of increased concern at some plants in the United 

States. Typically, tritium ground water contamination at commercial 

nuclear power plants is a result of a leak in a below-ground system, such 

as a pipe, tank, or valve. Normally, liquid effluents, including diluted 

tritium from nuclear power plants, are released into bodies of water, such 

as the Tennessee River in the case of Watts Bar Unit 1, and do not 

contaminate ground water. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Watts Bar Effluents Are Below Regulatory Limits

NRC incorporated into its regulations the dose recommendations from the 

International Commission on Radiological Protection.11 The International 

Commission on Radiological Protection’s recommendation was 100 

millirem (mrem)12 per year for dose to members of the public, and nuclear 

power plants must now meet that requirement. For liquid effluents, 

including tritiated water, licensees can demonstrate compliance with the 

100 mrem per year dose standard by not exceeding the concentration 

values specified in Title 10 of the Code of Federal Regulations (CFR), Part 

20, Appendix B, Table 2. These concentration values, if inhaled or 

ingested over the course of a year, would produce a total effective dose of 

50 mrem.

Nuclear power plants are also required to report the average 

concentrations of diluted effluents. The regulatory limit for liquid tritium 

effluent releases, as stated in Table 2 of Appendix B to 10 CFR Part 20, is 

1E-3 micro curies per milliliter (μCi/ml), or 0.001 μCi/ml.

13

 Table 4 in this 

report depicts the tritium annual average diluted concentration liquid

effluents, according to TVA reports for Watts Bar Unit 1, for 2001 through 

2010. The annual effluent releases ranged from 0.00001125 μCi/ml, to

0.00005347 μCi/ml, well below the regulatory limit of 0.001 μCi/ml.

 

11 The International Commission on Radiological Protection is an organization of international scientists 

who provide recommendations regarding radiation protection activities, including doses. 

12 A millirem is a unit of radiation dose. One millirem is one thousandth of a rem. The rem is a standard 

unit used to measure the dose equivalent (or effective dose), which combines the amount of energy (from 

any type of ionizing radiation that is deposited in human tissue), along with the medical effects of the 

given type of radiation.

13 1E-3 is a value expressed in engineering notation. 1E-3 equals 1.0 times 10 to the exponent negative 

3, or 1.0 x 10-3.
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Table 4:

Source: OIG analysis of TVA reports.

C. It Is Unclear to Stakeholders Whether TVA Is Authorized To Produce 

Tritium at Sequoyah Units 1 and 2

It is not clear to stakeholders whether Sequoyah Nuclear Power Plant 

Units 1 and 2 would need subsequent license amendments to produce 

tritium.14 Sequoyah Units 1 and 2 license amendment numbers 278, 269, 

289, and 279 each contained a clause that the license amendments were 

effective as of the date of issuance, but are to be implemented no later 

than the startup from an outage in which TPBARs are loaded into the 

reactor core. The clause in the license amendments also provided that if 

changes are made to the reactor that materially affect the basis of the 

approval of the license amendments, then TVA is not authorized to 

irradiate TPBARs in the reactor core. 

 

14 On October 22, 2003, TVA advised NRC that the production of tritium in the Sequoyah reactors had 

been delayed indefinitely. 

0.000000

0.000010

0.000020

0.000030

0.000040

0.000050

0.000060

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

micro curies 

per millilter

Watts Bar Unit 1

Tritium Annual Average Diluted Concentration 

Liquid Effluents
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Since TPBARs have not been installed in either Sequoyah Unit 1 or 2, the 

provisions authorizing the loading of TPBARs in license amendment 

numbers 278, 269, 289, and 279 have not been implemented in 

Sequoyah’s technical specifications. However, NRC’s permission allowing 

up to 2,256 TPBARs to be installed at both Sequoyah units is still in 

place – as long as TVA determines that no changes have occurred that 

materially affect the basis for the approval of the license amendment. 

Because the change in the technical specifications that incorporates the 

license amendment cannot be made until TPBARs are installed, it is not 

evident to stakeholders from reading the Sequoyah technical 

specifications that these nuclear reactors have NRC approval to install up 

to 2,256 TPBARs in their core.

15

 Assuming that TVA has not made any 

changes to the Sequoyah units that materially affect the basis of approval 

of the amendments, then TVA has NRC approval to load up to 2,256 

TPBARs into Sequoyah Units 1 and 2.

Some NRC and TVA staff have said that to produce tritium at either 

Sequoyah unit, TVA would need to seek another license amendment. 

However, other NRC staff stated that Sequoyah is authorized to produce 

tritium, by irradiating up to 2,256 TPBARs. To know whether Sequoyah is 

authorized to produce tritium at Sequoyah Units 1 and 2, a stakeholder 

would need to be aware of the clause in the license amendments and 

whether TVA has made any changes to Sequoyah that materially affect 

the basis for NRC approval of the amendments.

Issue for management consideration:

NRC management should consider clarifying to stakeholders whether 

Sequoyah Nuclear Power Plant Units 1 and 2 would need a subsequent 

license amendment to be authorized to produce tritium. 

 

15 In contrast, the Watts Bar Unit 1 technical specifications include language making it clear to a 

stakeholder that tritium production at the plant is permissible.
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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D. NRC’s Communication Regarding Tritium Production Could Be 

Improved

NRC’s communication with stakeholders regarding tritium production 

could be improved. A communication plan for Watts Bar Unit 1 and 

Sequoyah Units 1 and 2 tritium production was issued August 28, 2001,

but it has not been updated and is not an active communication plan. 

NRC’s communication plan Web page states that a communication plan 

should be kept up to date, referred to routinely, and revised if necessary. 

A communication plan is the strategy component that outlines what tools 

to use to ensure a consistent and accurate message to all stakeholders 

regarding a response, action, or initiative. 

NRC guidance states that there are several circumstances when a 

communication plan may be needed, for example, when an NRC project, 

program, or event is controversial or highly visible, which may provoke a 

reaction from stakeholders such as Congress or the public, or when the 

results of the decisions will affect the environment or public health and 

safety.

The purpose of the communication plan for oversight of tritium production 

is to ensure that internal and external stakeholders understand NRC’s

licensing role and its responsibility to ensure that TVA maintains reactor 

safety while providing irradiation services. The secondary goal of the 

communication plan is to assist DOE in its efforts to increase public 

confidence in DOE use of commercial nuclear power reactors as 

irradiation facilities to produce tritium. This plan helps ensure that NRC 

informs internal and external stakeholders about the program to produce 

tritium.

NRC’s Office of Nuclear Reactor Regulation16 would consider the 

communication plan on tritium production complete when NRC issues the 

license amendments and completes any other tritium production program 

licensing reviews for Watts Bar and Sequoyah, or when DOE determines 

that it no longer wants to use a commercial power reactor as part of its 

 

16 The Office of Nuclear Reactor Regulation supports the NRC mission to protect public health, safety, 

and the environment by developing and implementing rulemaking, licensing, oversight, and incident 

response programs for reactors. 
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

14

tritium production program. Although the communication plan is inactive, 

these licensing and production activities were still ongoing as of July 2011.

Changes Since the Communication Plan Was Issued

Much has changed with respect to DOE’s tritium production program since 

the 1996 memorandum of understanding was approved and the 2001 

communication plan was written:

Public interest has increased, especially regarding tritium leaks at 

nuclear power plants.

Due to the permeation rate per TPBAR being higher than originally 

anticipated, TVA chose to request a lower limit of TPBARs to be 

irradiated at Watts Bar than initially approved. 

DOE tritium requirements have been reduced due to the reduction 

in the number of nuclear weapons. 

Additionally, according to TVA staff, DOE plans to supplement the 

Environmental Impact Statement for its continued tritium production at 

commercial nuclear power plants. This will likely result in public meetings 

and other regulatory and licensing activities of interest to stakeholders. 

Due to the revised Environmental Impact Statement, there will likely be 

increased stakeholder interest in regulatory activities related to tritium 

production over the next few years, and NRC would benefit from an 

updated tritium production communication plan.

Issue for management consideration:

NRC management should consider updating and reissuing a 

communication plan for the tritium production program.
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

15

IV. AGENCY COMMENTS 

On August 25, 2011, OIG issued a discussion draft to the Executive 

Director for Operations. On September 8, 2011, Agency staff provided 

informal comments to the draft report. OIG subsequently met with NRC 

management on September 9, 2011, for an exit conference. On 

September 12, 2011, OIG provided the agency a revised discussion draft 

and on September 15, 2011, the agency declined to provide formal 

comments. The final report incorporates revisions made, as appropriate, 

as a result of comments provided by NRC and meetings with NRC staff.
Evaluation of NRC’s Oversight of Tritium Production at Commercial Nuclear Power Plants

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Appendix

SCOPE AND METHODOLOGY

OIG conducted this evaluation to determine the effectiveness of NRC’s 

oversight of tritium production at commercial nuclear power plants. OIG 

reviewed law applicable to NRC’s oversight of tritium production at 

commercial nuclear reactors, including the Atomic Energy Act of 1954, as 

amended; the Energy Reorganization Act of 1974; and the National 

Defense Authorization Act for Fiscal Year 2000. OIG also reviewed all 

license amendments allowing insertion of TPBARs in Watts Bar Unit 1 and 

Sequoyah Units 1 and 2; the Core Operating Limits Reports for those fuel 

cycles at Watts Bar Unit 1 in which TPBARs were irradiated; and Watts 

Bar Nuclear Power Plant Annual Radioactive Effluent Release Reports for 

2001 to 2010. OIG also reviewed NRC’s Safety Evaluation Reports –

NUREGs 1607 and 1672 – relative to the insertion of TPBARs into a 

commercial nuclear reactor. Additionally, OIG reviewed NRC’s 

“Communication Plan for NRC’s Role in DOE’s Program to Produce 

Tritium” and a 1996 Memorandum of Understanding between NRC and 

DOE. 

OIG interviewed NRC staff in the Office of Nuclear Reactor Regulation, 

Region II, and the Office of the General Counsel. OIG also interviewed 

staff from TVA. On April 28, 2011, OIG attended a meeting in Athens, 

Tennessee, to discuss the 2010 performance assessment for Watts Bar 

Unit 1 Nuclear Power Plant and construction inspections for Watts Bar 

Unit 2. On June 7, 2011, OIG observed a pre-submittal meeting on 

TPBARs for Watts Bar Unit 1 between TVA staff and NRC staff.

We conducted this evaluation at NRC headquarters and Athens, 

Tennessee, from April 2011 through July 2011. The evaluation work was 

conducted by Sherri Miotla, Team Leader; Michael Zeitler, Audit Manager; 

Kevin Nietmann, Senior Technical Advisor; Mitzi Lorette, Senior Auditor; 

and Kristen Lipuma, Management Analyst.