March 5, 2010 

MEMORANDUM TO: Bruce S. Mallett 

 Deputy Executive Director 

 for Reactor and Preparedness Programs 

 Executive Director for Operations 

 Charles A. Casto 

 Deputy Regional Administrator 

 Region IV 

FROM: R. W. Borchardt /RA/

 Executive Director for Operations 

SUBJECT: GROUNDWATER CONTAMINATION TASK FORCE 

The purpose of this memorandum is to task the Deputy Executive Director for Reactor 

and Preparedness Programs (DEDR) to convene a team of U.S. Nuclear Regulatory 

(NRC) leaders and experts to reevaluate the recommendations made in the Liquid 

Radioactive Release Lessons Learned Task Force Final Report dated September 1, 

2006, review the actions taken in SECY-09-0174 (Staff Progress in Evaluation of Buried 

Piping at Nuclear Reactor Facilities) (ML093160004), and review the actions taken in 

response to recent releases of tritium into groundwater by nuclear facilities. The team 

will be led by Charles A. Casto and will report day to day status to the DEDR. The 

purpose of the review is to determine whether the actions we have or that we plan to 

take in response to recent events and to the recommendations made in the 2006-Liquid 

Radioactive Release Lessons Learned Task Force Report (ML062650312) need to be 

augmented. 

Recent incidents at Oyster Creek, Oconee, and Vermont Yankee with tritium 

contamination of groundwater wells and soil have caused NRC licensees and the NRC 

to take actions to address the source of the tritium (e.g., buried piping leaks) and to 

communicate the impact to the public and other external stakeholders. Each Regional 

Office has addressed the individual licensee actions; the Office of Nuclear Reactor 

Regulation has taken actions to address buried piping leaks; and the nuclear industry 

has undertaken additional initiatives to address buried piping leaks. While the actions in 

each individual case have been successful in identifying the source and seeing that the 

licensee corrects the problem, the incidents raise questions regarding the completeness 

of the NRC actions to date and whether those actions need to be augmented. Some 

actions are still being implemented as outlined in SECY-09-0174 on buried piping. 

CONTACT: Steve L. Baggett, OEDO 

 301-415-0534 
B. Mallett, et. al. -2- 

The attached charter defines the objective, scope, expected product, schedule, staffing, 

and senior management interface. The scope of the task force effort should include, but 

not be limited to the following areas: industry experience; health impacts; the regulatory 

framework; NRC inspection; enforcement and reporting aspects; industry actions; 

international perspectives; and communications with external stakeholders. 

Our current practice is to use a threshold when assessing licensee and NRC actions in 

response to unplanned and unmonitored release of radioactive material to groundwater 

incidents. The threshold we use for buried piping is discussed in detail in SECY-09-

0174 and we also use the 10 CFR Part 20 release limits to determine acceptability of 

licensee and NRC response to groundwater events. Additionally, in conjunction with the 

NRC threshold, industry has implemented a Groundwater Protection Initiative to address 

detection and remediation of inadvertent releases that may have resulted in radioactive 

materials in the soil and groundwater. The Groundwater Contamination Task Force 

should review the current practice and assess whether a different threshold should be 

used for groundwater contamination incidents. 

The task force will provide its observations, findings, and recommendations in the form 

of a written report consistent with the guidance provided in the charter. The task force 

activities should be complete and a written report provided to the Deputy Executive 

Director for Reactor and Preparedness Programs no later than May 15, 2010. 

Enclosure: 

As stated
B. Mallett, et. al. -2- 

The attached charter defines the objective, scope, expected product, schedule, staffing, 

and senior management interface. The scope of the task force effort should include, but 

not be limited to the following areas: industry experience; health impacts; the regulatory 

framework; NRC inspection; enforcement and reporting aspects; industry actions; 

international perspectives; and communications with external stakeholders. 

Our current practice is to use a threshold when assessing licensee and NRC actions in 

response to unplanned and unmonitored release of radioactive material to groundwater 

incidents. The threshold we use for buried piping is discussed in detail in SECY-09-

0174 and we also use the 10 CFR Part 20 release limits to determine acceptability of 

licensee and NRC response to groundwater events. Additionally, in conjunction with the 

NRC threshold, industry has implemented a Groundwater Protection Initiative to address 

detection and remediation of inadvertent releases that may have resulted in radioactive 

materials in the soil and groundwater. The Groundwater Contamination Task Force 

should review the current practice and assess whether a different threshold should be 

used for groundwater contamination incidents. 

The task force will provide its observations, findings, and recommendations in the form 

of a written report consistent with the guidance provided in the charter. The task force 

activities should be complete and a written report provided to the Deputy Executive 

Director for Reactor and Preparedness Programs no later than May 15, 2010. 

Enclosure: 

As stated 

DISTRIBUTION:

SCollins, RI LReyes, RII MSatorius, RIII ECollins, RIV 

ELeeds, NRR MWeber, NMSS CMiller, FSME MDoane,OIP 

BShearon, RES HBell, OIG EBrenner, OPA SBurns, OGC 

BSchmidt, OCA 

 (list to be augmented once charter members are identified) 

ADAMS: ML100640188

OFFICE: DAO:sc RGN IV/Task Force Lead EDO/DEDR EDO 

NAME: JAndersen /RA/ CCasto/RA by BM for/ BMallett/RA/ RWBorchardt/RA/ 

DATE: 03/05/10 03/05/10 03/05/10 03/5/10 

 OFFICIAL RECORD COPY 
CHARTER FOR THE 

GROUNDWATER CONTAMINATION TASK FORCE

Objective

The objective of this Task Force is to reevaluate the staff’s actions in response to recent 

incidents with tritium released into groundwater at Oyster Creek, Oconee, and Vermont 

Yankee, and the staff’s response to recommendations made in the Liquid Radioactive 

Release Lessons Learned Task Force Final Report dated September 1, 2006 to 

determine whether the actions need to be augmented. The Task Force, should, as 

appropriate, identify and recommend actions that need to be augmented in order for the 

NRC to remain effective. When this task is complete, the Task Force may remain in 

effect to serve as a Steering Committee for the implementation of any identified 

recommendations. 

Scope

The task force review should include the following: 

a. Known inadvertent releases of radioactive liquid to the environment at 

power reactor sites, including power reactors in decommissioning that 

have occurred since the Lessons Learned Task Force Final Report 2006. 

b. The additional actions included in the agency follow up to recent incidents 

where tritium has been found in the ground water, monitoring wells and 

soil at the Vermont Yankee nuclear power plant. Below is a summary of 

those actions that the Task Force should review: 

1. Conduct two Workshops with External Stakeholders. One 

locally in Vermont near Vermont Yankee with the purpose of 

answering questions, putting the tritium in perspective with 

what we regulate and the potential for radiation exposure to 

the public, and listening to concerns from the external 

stakeholders. This one would be held in conjunction with the 

State Department of Public Service. The second one would 

be held near the NRC, Headquarters Office, with the purpose 

of answering questions regarding tritium and NRC follow up, 

and to discuss whether further actions should be taken in view 

of the recent tritium incidents and buried pipe leaks at nuclear 

power plants. 

2. Specific inspection actions taken at each site where tritium 

contamination has been found in groundwater wells. 

ENCLOSURE 
3. NRR guidance for follow up inspections to buried piping leaks, 

resulting in radioactive contamination of groundwater. The 

guidance can be used to direct inspections in this area for 

routine, baseline ROP and for license renewal inspections. 

The guidance will build on that used in the past to follow up on 

the industry ground water initiative and that used in license 

renewals. It will cover guidance for what should be considered 

as agency action in cases where a licensee's operating 

experience includes recent groundwater contamination 

incidents. 

4. The staff’s response to the proposed December 2009 Industry 

Initiative on Buried Piping regarding inspection and response 

to incidents. 

5. The Interface and alignment with DHS, EPA and the States to 

discuss NRC actions in response to provide information and to 

achieve alignment. 

6. Meetings with Congressional Stakeholders to discuss NRC 

actions in response to Vermont Yankee and to tritium 

contamination from buried piping problems or other sources 

throughout the United States. 

c. The existing regulatory framework, including both the health physics 

aspects, the licensee reporting requirements (including making reports to 

state and local officials), and the regulatory requirements associated with 

the structures and systems from which the releases have originated. 

d. Implications for decommissioning and decommissioning funding 

assurance. 

e. International practices for similar incidents. 

f. Communications method with external stakeholders, public, state and 

local officials, and other federal agencies to best convey the risk of these 

type incidents. 

The scope of subjects considered by the task force should not necessarily be limited to 

those noted. The task force activities should not interfere with the agency’s immediate 

response to the incidents being reviewed. 
Expected Product and Schedule

The task force will provide its observations, findings, and recommendations in the form 

of a written report to the Deputy Executive Director for Reactor and Preparedness 

Programs. The task force review activities should be completed by May 15, 2010. 

Staffing

The task force will consist of the following members. 

 Team Leader: Charles A. Casto 

 Assistant Team Leader: Ho Neih 

Team Members: NRR to be identified later 

 NMSS to be identified later 

 FSME to be identified later 

 RES to be identified later 

 OCA to be identified later 

 OGC to be identified later 

 Region I identify a point of contact only 

 Region II identify a point of contact only 

 Region III to be identified later 

 Region IV identify a point of contact only 

 

Senior Management Interface

The task force will keep senior management informed on the status of the effort and 

provide early identification of significant findings. In addition, the task force will regularly 

interface with the cognizant OEDO staff to keep them abreast of progress.