June 17, 2010

MEMORANDUM TO: To Those on the Attached List

FROM: R. W. Borchardt /RA/

Executive Director for Operations

SUBJECT: SENIOR MANAGEMENT REVIEW OF GROUNDWATER TASK 

FORCE REPORT

On March 5, 2010, I established a Groundwater Task Force (GTF) to evaluate the 

completeness of U.S. Nuclear Regulatory Commission (NRC) actions to address recent 

incidents of radioactive contamination of groundwater wells and soils. As described in the 

charter (ML100640188), the purpose of the GTF was to determine whether the actions we have 

taken, or plan to take, in response to recent events and to the recommendations made in the 

Liquid Radioactive Release Lessons Learned Task Force Final Report should be augmented.

For several months, the GTF worked independent of Commission and NRC management 

direction to complete its review. On June 11, 2010, the GTF issued its final report 

(Enclosed - ML101740509). It is important to note that the findings, conclusions, and

recommendations discussed in the GTF final report have not received Commission or NRC 

management review, nor have they been shared with other Federal agencies.

The GTF identified 16 conclusions and four recommendations which are now available for NRC

review and consideration. By this memorandum, I am appointing you as a member of a senior 

management review group (SMRG) to be chaired by Martin J. Virgilio. The purpose of this

SMRG is to decide whether the NRC agrees with the findings of the GTF and how best to act 

upon the conclusions and recommendations contained in the final report.

The SMRG is tasked with the following activities:

1. Review the GTF final report including the conclusions, recommendations, and their 

bases.

2. Identify the policy issues associated with the NRC‟s groundwater protection 

regulatory framework. Develop options for addressing the policy issues and prepare 

a paper presenting the options to the Commission. 

3. Identify the conclusions and recommendations that do not involve policy issues. 

Determine actions the staff should take to address them and timeframe for 

completion.

4. Determine whether the GTF conclusions or recommendations should be expanded.

5. Seek feedback from external stakeholders, including appropriate Federal 

departments and agencies, on how the NRC should address the conclusions and 

recommendations of the GTF
Those on the attached List -2-

The SMRG should convene within two weeks of the date of this memorandum. Interim 

milestones (i.e., identification of conclusions and recommendations that do not involve policy 

issues and outreach to external stakeholders) should be completed by August, 2010. The final 

deliverable, a Commission paper(s) presenting options for addressing the policy issues, should 

be completed by end of November, 2010.

Support for the SMRG will be provided by staff from the Office of Nuclear Reactor Regulation

(NRR). In addition, the SMRG should conduct its activities such that there is coordination with 

ongoing work in NRR to address buried piping issues.

Enclosure:

As Stated

cc: Chairman Jaczko

 Commissioner Svinicki

Commissioner Apostolakis

Commissioner Magwood

Commissioner Ostendorff

SECY

OPA

OCA

OGC
MEMORANDUM TO THOSE ON THE ATTACHED LIST DATED: June 17, 2010

SUBJECT: SENIOR MANAGEMENT REVIEW OF GROUNDWATER TASK FORCE REPORT

Mail Stop

Martin J. Virgilio, Deputy Executive Director for Reactors O-16 E-15

 and Preparedness Programs, OEDO

Stephen G. Burns, General Counsel O-15 D21

Charles L. Miller, Director, Office of Federal and State Materials T-8 D22

 and Environmental Management Programs

Michael R. Johnson, Director, Office of New Reactors T-6 F15

Catherine Haney, Director, Office of Nuclear Material Safety and Safeguards EBB 1D2M

Eric J. Leeds, Director, Office of Nuclear Reactor Regulation O-13 H16M

Mark A. Satorius, Regional Administrator, Region III RIII
U.S. Nuclear Regulatory Commission

Groundwater Task Force 

Final Report

June 2010

ENCLOSURE
(Intentionally left blank)
Table of Contents

1. Background ........................................................................................................................1

2. Themes ..............................................................................................................................1

2.1. Theme 1 – Reassess the Regulatory Framework for Groundwater Protection..................2

2.2. Theme 2 – Maintain Barriers as Designed to Confine Licensed Material ..........................4

2.3. Theme 3 – More Reliable NRC Response.........................................................................4

2.4. Theme 4 – Strengthen Trust ..............................................................................................5

3. Analysis and Recommendations........................................................................................6

3.1. NRC Mission Analysis........................................................................................................6

3.2. Recommendations .............................................................................................................7

4. Summary of Appendices ....................................................................................................8

4.1. Summary of Appendix A – Response to Recent Groundwater Incidents...........................8

4.2. Summary of Appendix B – Agency Actions........................................................................8

4.3. Summary of Appendix C – Regulatory Framework for Groundwater Incidents

Involving NRC Licensees ...................................................................................................9

4.4. Summary of Appendix D – Communications on Groundwater Incidents ...........................9

4.5. Summary of Appendix E – Summary of International Input on Groundwater Incidents ... 10

4.6. Summary of Appendix F – Acronyms............................................................................... 11

5. Task Force Membership .................................................................................................. 11

Appendix A. Response to Recent Groundwater Incidents A-1

Appendix B. Agency Actions B-1

Appendix C. Regulatory Framework for Groundwater Incidents Involving NRC 

Licensees C-1

Appendix D. Communications on Groundwater Incidents D-1

Appendix E. Summary of International Input on Groundwater Incidents E-1

Appendix F. Acronyms F-1
(Intentionally left blank)
GROUNDWATER TASK FORCE 

FINAL REPORT

1. Background

Recent incidents1at Oyster Creek, Oconee, and Vermont Yankee nuclear power plants 

resulting in the detection of tritium in groundwater monitoring wells have caused U.S. 

Nuclear Regulatory Commission (NRC) licensees and 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. NRC actions in each individual case have been successful in identifying 

the source and assuring that the licensee investigates the source of contamination. 

Nevertheless, some stakeholders believe these incidents raise questions regarding NRC 

actions to date and whether those actions needed to be augmented.

In order to answer these two questions, NRC‟s Executive Director for Operations

established a Groundwater Task Force (GTF) in a memorandum to Bruce Mallett and 

Charles Casto dated March 5, 2010 (ADAMS Accession No. ML100640188). The GTF 

Charter is included in that memorandum.

The GTF has reviewed the specific items contained in the Charter. The GTF has also 

compiled facts and developed observations, conclusions, themes, and recommendations. It 

should be noted that this report is primarily focused on NRC‟s programs for operating 

reactor oversight. 

2. Themes

After a thorough review, the GTF determined that NRC is accomplishing its stated mission of 

protecting public health, safety, and protection of the environment through its response to 

groundwater leaks/spills. Within the current regulatory structure, NRC is correctly applying 

requirements and properly characterizing the relevant issues. In doing so, NRC is adhering 

to its mission, principles of good regulation and organizational values. Although the 

leaks/spills seen to date have not posed a hazard to human health, they have impacted 

public confidence for some stakeholders and led them to question NRC‟s interest in 

environmental protection.

 

1

“List of Historical Leaks and Spills at U.S. Commercial Nuclear Power Plants,” ADAMS Accession No. 

ML101270439. Note: The GTF reviewed selected events since 2006.
2

There are further observations, conclusions, and recommendations that NRC should 

consider in its oversight of licensed material outside of its design confinement.

2

 While 

completing the actions required by the Charter, the GTF identified the following four major 

crosscutting themes that provide focus for the conclusions (which are described in greater 

detail in the appendices):

Theme 1 – Reassess NRC‟s Regulatory Framework for Groundwater Protection

Theme 2 – Maintain Barriers as Designed to Confine Licensed Material

Theme 3 – More Reliable NRC Response

Theme 4 – Strengthen Trust

2.1. Theme 1 – Reassess NRC‟s Regulatory Framework for Groundwater Protection

As an independent regulatory agency, NRC‟s stated mission to “...license and regulate the 

Nation‟s civilian use of byproduct, source, and special nuclear materials to ensure adequate 

protection of public health and safety, promote the common defense and security, and 

protect the environment,” is key in ensuring that NRC‟s regulations and actions are designed 

to protect the public‟s health and safety. This responsibility is crucial to formulating 

regulations, policies, guidance, and enforcement on groundwater incidents, and in 

effectively communicating these issues to NRC stakeholders. NRC regulates exposure 

pathways that can result in a dose, regardless of whether the pathway is ingestion, 

inhalation or exposure, through 10 CFR Part 20. Specific to reactors, the requirements in 

10 CFR Part 50, including the General Design Criteria in Appendix A to Part 50, and the 

numerical objectives for limiting radiation releases in Appendix I to 10 CFR Part 50, set out 

general design and operational objectives for controlling and limiting potential exposure 

pathways. 

During this review, the issue of environmental protection was raised by stakeholders with

many different perspectives. Some external stakeholders were concerned with NRC‟s 

regulation of radioactive contamination in groundwater, while others indicated that, because 

the releases to the environment were far below regulatory limits, increased regulatory 

actions were not necessary. The issue of environmental protection, as mentioned in NRC‟s 

mission statement, is addressed through NRC‟s implementation of NEPA to assure that 

agency decision makers are fully aware of the environmental impacts of the agency‟s 

decisions in making individual licensing actions and adopting regulations.

There are divergent views on how NRC should regulate licensed material that could enter 

groundwater. Although not a human health hazard, due to the very low levels of 

radioactivity found in recent incidents involving tritium leaks, it is a challenging issue from 

the perspective of communications around environmental protection. The stimulus for this

 

2 As used in this report and defined by the International Atomic Energy Agency (IAEA), the term 

“confinement” is defined as prevention or control of releases of radioactive material to the environment in 

operation or in accidents [(IAEA 2008); see references, Appendix E].
3

challenge has been the pressure from various stakeholders for explicit demonstrations of 

protection of the environment, separate from demonstrations of protection of individuals. 

Challenges to NRC‟s authority to protect the environment from inadvertent releases of 

licensed materials exist with respect to the interplay between NRC regulations and existing 

State and Federal regulations. Several States have become more active in their desire to 

enforce their regulations on NRC licensees. Although these challenges have existed for 

years, the issue became most evident after the Braidwood groundwater contamination event

identified in 2005 when the State of Illinois pursued enforcement for “degradation” of a 

natural resource. State officials questioned the GTF on why NRC would not step aside in 

areas where they thought it was unclear whether NRC has statutory authority. This is 

especially the case when the State has delegated authority for groundwater protection from 

the Environmental Protection Agency (EPA). 

In an effort to reach out to interested stakeholders, the NRC conducted public meetings. 

During the April 19-20, 2010, public meetings, the GTF heard from several State 

representatives, local officials, and members of the public regarding their disagreement and 

concern with NRC‟s human, dose-based approach to protecting groundwater. NRC‟s 

statutory authority in the Atomic Energy Act of 1954, as amended, is limited to regulation 

based on “health and safety of the public” and “common defense and security” (See Sec. 3 

of the AEA). Regulation based solely on environmental protection is generally not within 

NRC‟s statutory authority, with limited exceptions, such as with respect to uranium mill 

tailings (commonly referred to as 11(e)(2) material). In addition, the backfit rule3for reactors 

further complicates changes to the regulatory framework. Promulgation of any rule that 

would result in a change to an existing system or structure would need to meet the standard 

of the backfit rule such that any backfitting would achieve a substantial increase in the 

overall protection of the public health and safety or common defense and security and that 

the costs of the backfitting, both direct and indirect, are justified in light of the overall 

increased protection. These factors impact NRC‟s ability to respond to leaks/spills to 

groundwater as some members of the public would like. These issues will likely become 

more significant as the nation‟s environmental stewardship increases and some countries 

adopt more direct approaches to protecting the environment from the effects of radiation.

4

 

NRC‟s regulatory framework for oversight of licensed material confinement appears to 

contribute to the distrust and dissatisfaction of NRC by some stakeholders. 

NOTE: This is supported by the conclusions A.3.1, A.3.2, C.3.1, C.3.2, C.3.3, and E.3.4 in 

the attached appendices.

 

3 Specifically, 10 CFR 50.109 defines a backfit as "the modification of or addition to systems, structures, 

components, or design of a facility; or the design approval or manufacturing license for a facility; or the 

procedures or organization required to design, construct or operate a facility; any of which may result 

from a new or amended provision in the Commission's regulations or the imposition of a regulatory staff 

position interpreting the Commission's regulations that is either new or different from a previously 

applicable staff position."

4 Refer to the International Committee for Radiation Protection (ICRP) Publication 103 and the 2007 ICRP 

Recommendations at http://www.icrp.org/annals_list.asp.
4

2.2. Theme 2 – Maintain Barriers as Designed to Confine Licensed Material 

The GTF heard many comments from stakeholders in public meetings regarding a desire for 

NRC to ensure that licensees prevent leaks/spills to groundwater and soil contamination. In 

their view, NRC‟s approach has been reactive rather than proactive. 

Most incidents since 2006, and those reviewed by the GTF, involved fluids containing 

radioactive tritium leaking from non-safety related underground structures and pipes. 

Because these leaks/spills are not likely to result in doses that approach NRC radiation 

protection limits, NRC has not placed an emphasis on preventing these types of leaks/spills. 

While licensees are required to design systems to confine radioactive material, NRC‟s 

regulatory framework does not explicitly state that all activities under a licensee's control 

must be accomplished with no leakage. Instead, when applying for a license from NRC, the 

applicant describes in its application how radioactive material will be used, secured and 

controlled. For example, power reactor licensees are required by 10 CFR § 50.34(b)(3) to 

describe the kinds and quantities of radioactive materials expected to be produced and the 

means for controlling and limiting radioactive effluents and radiation exposures within the 

limits set forth in 10 CFR Part 20 in their Final Safety Analysis Reports. In addition, 10 CFR

Part 50, Appendix I, requires specific information on the description of criterion “As Low As 

Reasonably Achievable” for control radioactive material in light-water cooled nuclear power 

reactor effluents. The license granted by NRC only permits the licensee to engage in 

activities authorized in the license, and specific effluent points are included in the licensing 

bases. There may be additional State and Federal permits, licenses or approvals required 

for effluent discharges. In addition to the general licensing bases there are specific license 

conditions related to effluent discharges in reactor and non-reactor NRC licenses. A 

thorough review of the licensing bases, both general and specific conditions, should be 

performed by NRC staff whenever a leak not associated with an approved discharge occurs

as it may be a violation of applicable requirements, e.g., 10 CFR Part 50, Appendix I.

NOTE: This is supported by conclusions C.3.1, C.3.3, and B.3.1 in the attached 

appendices.

2.3. Theme 3 – More Reliable NRC Response

The GTF received input from many stakeholders including the public, industry, and NRC 

staff. Because any leakage of radioactive material, regardless of the hazard to individuals is 

of significant public interest, the GTF concludes that NRC response to incidents could be 

enhanced to be more reliable. The GTF identified the following three elements that 

comprise this theme: event response guidance, performance indicators (PI)5, and 

dissemination of information (internal/external).

 

5

For further discussion of NRC‟s Performance Indicators, see 

http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/cornerstone.html
5

With regard to the first element (event response guidance), the GTF reviewed existing NRC

guidance related to the response and monitoring of leaks/spills of radioactive material and 

determined that the guidance could be enhanced to ensure a more reliable response when 

leaks/spills are identified at licensed facilities. The current approach has resulted in a 

significant variation of expenditures of inspection resources from follow-up by the resident 

inspection staff to a team of health physics inspectors, hydrologists, and/or materials 

engineers independently assessing the licensee‟s performance. Additionally, the reporting 

of NRC inspection results also varied greatly with stand alone inspection reports, “quicklook” letters, or reporting the results in the next quarterly inspection report.

The second element was determined to be the lack of predictive PIs. An effective PI should 

provide a meaningful distinction when there is a change in performance. The Public 

Radiation Safety Cornerstone has one PI – Radioactive Effluent Technical 

Specifications/Offsite Calculation Dose Manual. This PI assesses the performance of the 

licensee‟s radiological effluent control program for both liquid and gaseous effluents. It is 

not a robust indicator of licensee performance with respect to groundwater and does not 

measure out-of-normal performance unless the release is large enough to challenge safety 

limits. For example, this PI did not change as a result of the leak identified at Braidwood in 

2005. Additionally, the GTF noted that the industry has never had one reportable 

occurrence under this indicator. This PI also does not address leaks/spills. An effective PI 

for groundwater protection would change as a function of the number, quantity, and type(s) 

of radionuclide, and/or locations of leaks/spills for groundwater protection. Some of the 

recent responses to incidents have resulted in the staff working from the extreme edges of 

the Reactor Oversight Process (i.e., taking no actions for some leaks while issuing Demands 

for Information or Reactor Oversight Deviations for others). This has resulted in a significant 

range of NRC responses and stakeholder confusion. 

The third element identified was access to, and timely dissemination of information 

(internal/external). The information on NRC‟s Knowledge Management Center and 

Operating Experience (OpE) web pages related to leaks/spills that could affect groundwater 

contamination is limited, difficult to locate, and in some cases, dated. The low risk to public 

health and safety from these incidents has resulted in a failure to address the trends in 

groundwater incidents in internal NRC information. The information contained on the public 

website is provided through a complex set of links that has frustrated many users. 

Additionally, some of the information has not been updated in several years and contains 

outdated or incorrect information. 

NOTE: This is supported by conclusions A.3.1, B.3.1, B.3.2, B.3.3, B.3.4, D.3.1, D.3.2, and 

E.3.3 in the attached appendices.

2.4. Theme 4 – Strengthen Trust

The GTF observed and received input from some members of the public, media, licensees, 

and domestic and international regulators on the need to communicate promptly, effectively, 
6

and clearly regarding NRC‟s response and assessment of unplanned, unmonitored releases 

to the environment. There exists a misalignment of viewpoints between NRC and some 

stakeholders. Some stakeholders view leaks as an indication of inadequate maintenance of 

the entire facility. NRC‟s regulatory framework treats confinement of licensed material as a 

design rather than an operational or maintenance consideration. Also, during the past 

several years, when leaks occurred, they have been of very low risk and dose to individuals. 

NRC uses a risk communication method as described in NUREG/BR-0308, “Effective Risk 

Communications” to describe consequences of releases to individuals.6 This risk 

communications framework does not directly address the primary concerns of some NRC 

stakeholders. Some view any radiological releases as a public health issue rather than an 

issue of risk. Furthermore, instead of waiting to remediate onsite contamination when the 

facility is decommissioned, they see a need for immediate cleanup and enforcement.

As a result, a belief by some that NRC fails to require adequate maintenance fosters doubt 

and uncertainty over NRC‟s and licensee‟s ability to protect people and the environment. 

Some stakeholders have fear and anxiety regarding their health. The overall impacts of 

leaks to the environment are viewed by some stakeholders as an environmental insult, 

which results in an increased sense of anger, frustration and distrust. 

Those stakeholders tend to seek third-party validation of NRC‟s assessments regarding 

groundwater incidents. They expect a discussion of the public health perspective when 

communicating the risks and consequences of leaks to groundwater. 

NOTE: This is supported by conclusions D.3.3, E.3.1, E.3.2, E.3.3, and E.3.4 in the 

attached appendices.

3. Analysis and Recommendations

3.1. NRC Mission Analysis

Loss of licensed material confinement incidents represents a significant challenge to NRC. 

Policies that protect public health and safety and policies that protect the environment are 

not always consistent with each other. One instance where policies designed to protect 

public health and safety may not coincide with policies to protect the environment is when 

leaks from non-safety-related components occur that have low dose consequences. Such 

incidents may impact the environment but pose little or no health and safety concern. 

Fundamentally, NRC‟s regulatory framework covers these incidents as situations to monitor, 

document, and remediate, if necessary at decommissioning. From a public health and 

safety perspective, these incidents are acceptable if the doses are within NRC regulatory 

limits. However, some stakeholders view leaks/spills as indicative of a failure to maintain 

the plant, a risk to public health, and requiring immediate remediation. This disagreement 

over how a release should be handled undermines trust in NRC among those stakeholders. 

 

6

http://www.internal.nrc.gov/communications/riskcommunication.html
7

Further complicating this challenge is the issue of the interplay between State and Federal 

regulations. The EPA and some States regulate groundwater differently than NRC. Their 

regulations seek to protect the environment as a natural resource in contrast to NRC‟s 

approach of protecting the environment through protection of public health. The EPA uses 

its authority under the Safe Drinking Water Act to set the Federal legal limits for 

contaminants in drinking water and to protect underground sources of drinking water. Water 

suppliers must provide water that meets these standards, known as “maximum contaminant 

levels.” EPA‟s drinking water standards do not apply to private drinking water wells, such as 

those that may be impacted by tritium that is inadvertently released (within NRC regulatory 

limits) from nuclear power plants. However, many State authorities have adopted the EPA‟s 

drinking water standards as legally enforceable standards, and those standards are often 

used in assessing laboratory test results of water from private wells.7

Going forward, incidents involving a loss of confinement of licensed material may increase. 

Because of power uprates and longer life reactor cores, the inventory of tritium in the fleet 

has been and is increasing. These facilities will likely have more losses of confinement from 

non-safety related systems, and with a low reporting threshold established by the voluntary 

industry initiative NEI-07-07 (ADAMS Accession No. ML072600295), more leaks/spills may 

be reported and stakeholder interest will remain high. 

3.2. Recommendations

In the Appendices to this report, the GTF developed 16 conclusions on issues associated 

with the oversight of groundwater incidents. While those conclusions also provide some 

recommended approaches to strengthening the NRC oversight of groundwater, a policy 

analysis should be completed before developing specific recommendations/actions. 

Nevertheless, the GTF suggests the staff consider the following recommendations to

strengthen NRC response to groundwater incidents:

Identify the policy issues associated with an assessment of the NRC‟s groundwater 

protection regulatory framework

Once the policy issues are addressed, implement conforming changes to incorporate 

appropriate enhancements in the Reactor Oversight Program 

Consider development of specific actions to address the key themes and conclusions 

in this report

Conduct a focused dialogue with EPA, States and international regulators8to 

develop a collaborative approach for an enhanced groundwater protection strategy 

For further details on the conclusions refer to Appendices A through E of this report.

 

7

For more information on drinking water and health, visit http://www.epa.gov/safewater/dwh/index.html

8 As the GTF completed its report, the Canadian Nuclear Safety Commission published “Tritium Studies 

Project Synthesis Report,” that provides an extensive review of Canadian regulatory oversight of tritium 

processing and tritium releases in Canada. Reference: CMD-07-M34; E-DOCS #3533394, May 21, 2010. 
8

4. Summary of Appendices

During its work to complete the Charter, the GTF reviewed material related to NRC‟s oversight 

on groundwater incidents, and documented this review in five appendices. This work is 

summarized below.

4.1. Appendix A – Response to Recent Groundwater Incidents

Groundwater incidents occurring since 2006 were reviewed by the GTF to better understand 

the approaches used by the Regions under the auspices of the Reactor Oversight Program. 

The results of this review are detailed in Appendix A. The GTF concluded that NRC 

inspection response to incidents of leaks/spills has varied widely. As a result, NRC‟s 

response has been inconsistent and unpredictable, and expenditures of inspection 

resources have varied significantly. Consequently, NRC‟s credibility in the view of some 

stakeholders has suffered.

The implementation of the industry voluntary groundwater initiative has resulted in increased 

reporting by licensees of the discovery of leaks/spills that could affect groundwater. 

However, the reports only identify the initial indications of incidents and do not provide 

information describing the results of activities to identify and resolve leaks/spills, the root 

causes of the leaks/spills and corrective actions or conclusions with respect to the 

consequences. Thus, the limited public information leads to distrust by some stakeholders. 

The increased numbers of incident reports lead some stakeholders to believe that the 

nuclear industry has serious maintenance issues that need enforcement action. NRC‟s 

ability to take enforcement action based on a voluntary industry initiative is limited to 

enforcing those items in the industry initiative that are required by NRC rules.

4.2. Appendix B – Agency Actions 

The GTF reviewed many of the incidents since 2006 to determine if gaps exist or additional 

NRC actions are needed for responding to groundwater incidents. That review is detailed in 

Appendix B. 

The GTF concludes that the current Reactor Oversight Program Performance Indicator does 

not provide a meaningful distinction in licensee performance with respect to groundwater 

protection. Further, the GTF concludes that because of the low risk of these events, 

Operating Experience information is limited. Finally, the GTF concludes that there is an 

inconsistency between the Public Radiation Safety Cornerstone in the reactor oversight 

program significance determination process and the associated technical basis document 

regarding the use of “public confidence” factor. Consideration of public confidence in this 

part of the reactor oversight process would result in a higher level of significance than would 

be warranted based solely on the risk from exposure to the radioactive material.
9

4.3. Appendix C – Regulatory Framework for Groundwater Incidents Involving NRC Licensees

The GTF reviewed the existing regulatory framework for addressing leak/spills. Appendix C 

details the results of this review. Maintaining system integrity is a fundamental principle in 

minimizing leaks/spills and groundwater contamination. For systems outside the scope of 

license renewal, existing regulations for inspection, maintenance, and aging management 

issues do not adequately address preventing leakage from non-safety systems containing 

licensed material.

NRC‟s regulatory framework with respect to groundwater varies for different licensees (e.g., 

reactors, fuel cycle, and in-situ leach facilities). NRC has been regulating groundwater 

quality using projected dose calculations for some licensees and by measurements of 

groundwater concentration for other licensees consistent with applicable regulations. 

Furthermore, some licensees are regulated with respect to both radiological and nonradiological constituents. Some licensees are required to conduct groundwater 

characterization and implement ongoing close-in monitoring while others are not. NRC‟s 

regulatory framework among licensed facilities, which is consistent with Federal law, can be 

a source of both internal and external stakeholder confusion. As a result, NRC may be 

perceived as a less effective regulator by some stakeholders. 

The requirements for groundwater monitoring for non-reactor facilities are specific to each 

type of license and may not be consistent. Additionally, the NEI Voluntary Groundwater 

Protection Initiative is not applicable to all types of licensees; it is only applicable to power 

reactors. The effectiveness of groundwater monitoring programs across all types of licenses 

has not been thoroughly evaluated for consistency. 

The proposed final decommissioning rule now before the Commission (SECY-09-0042) 

would require licensees to identify and evaluate subsurface contamination, maintain records 

of contamination, and account for the cost of remediation of residual contamination for sitespecific decommissioning cost estimates. This rule is directed at decommissioning planning 

and would not alter the regulatory framework for confinement of licensed material, 

incorporate the voluntary industry initiative or require immediate remediation.

4.4. Appendix D – Communications on Groundwater Incidents

The issue of leaks/spills at operating nuclear power plants has generated considerable 

attention by the public, media, and Congress. Recognizing this, and consistent with its 

charter, the GTF reviewed the results of the April 19 and 20, 2010, public meetings, media 

reports, Congressional correspondence issued between 2006 and 2010, and the content of 

NRC‟s public website. Further, the GTF sought public comments. Appendix D details this 

review and provides the GTF, facts observations, and conclusions. 

Themes from Congressional correspondence indicate interest both in the House of 

Representatives and in the Senate (Congressional Members). They expressed concern that 
10

NRC enforce its rules and regulations when incidents occur and that NRC issue effective 

“punishment.” Some Congressional Members want “continued independent audits” of 

licensee activities. In the area of communications, some Congressional Members insisted 

that we share information quickly after an event with Congress and the public. They want to 

be “warned” of the health and safety impacts and would want NRC to provide detailed 

descriptions for each event. 

Themes from press clippings reviewed by the GTF were focused primarily on the public‟s 

lack of trust with licensees and NRC‟s ability to effectively respond to tritium incidents.

The public workshops focused on the consequences resulting from tritium leaks from pipes 

at nuclear power plants. The GTF concluded that the main challenge was how to 

communicate those consequences with external stakeholders (i.e., the public and interest 

groups) to strengthen public trust, confidence, and respect. For some stakeholders, public 

trust of NRC as a regulator is being eroded as result of continuing leaks/spills. Some 

members of the public expressed their concerns and distrust of NRC‟s response and 

enforcement of groundwater incidents.

In the opinion of some stakeholders, NRC‟s communications have been insufficient in 

assuring them of NRC‟s interest in their health. Public health experts have suggested that 

NRC engage the public in a dialogue on the potential health effects of radiation before 

entering into a discussion of comparable risks with those stakeholders.

4.5. Appendix E – Summary of International Input on Groundwater Incidents 

A review of the regulatory approaches used by NRC‟s international counterparts is detailed 

in Appendix E. Although the majority of the countries contacted by the GTF did not have an 

official policy for regulatory responses to incidents involving reports of releases of 

radioactivity below the regulatory limits, all countries did have licensee (operator) reporting 

requirements for periodic environmental effluent monitoring. In addition, international 

regulatory authorities effectively communicated licensee‟s radiological monitoring results

annually in a report to their legislative body, which was also made available to the public on 

their websites. International regulatory staff contacted by the GTF emphasized the need to 

monitor migration of radioactivity into the public domain before decommissioning, and 

consequently encouraged the emphasis on specific programs for groundwater monitoring 

and investigation.

The GTF noted that the issues concerning recent U.S. tritium contamination events have 

raised similar questions worldwide. Recently, one international regulator received an inquiry 

from their applicable Ministry regarding concerns over the control of tritium with respect to 

nuclear power plants in their country. These questions have been raised by the Ministry 

because of the Vermont Yankee tritium contamination issues and the possible applicability 

of similar issues in their country.
11

As illustrated by other international regulators, establishing a position statement and key 

objectives on buried piping activities and groundwater initiatives would be helpful in 

providing clear communication to stakeholders on the actions taken by both NRC and 

licensees at the affected sites.

In order to promptly and more effectively communicate the safety significance of incidents to 

the public, the GTF noted that more than 65 countries use the IAEA‟s INES to explain 

incidents associated with various sources of radiation. Use of INES in communicating the 

safety significance of incidents such as leaks from underground piping may aid in third-party

validation of NRC‟s assessment of groundwater incidents and in helping strengthen public 

trust.

Several international regulators commented on the need to cooperatively investigate, 

through an international expert meeting, corrosion incidents that have caused leaks in 

buried pipes and related systems at nuclear power plants in order to obtain international 

consensus on approaches to communicate the safety significance of such incidents

effectively and to share experiences on related issues.

4.6. Appendix F – Acronyms 

For convenience, Appendix F contains a list of acronyms used in this report and its 

appendices.

5. Task Force Membership

Subsequent to the issuance of the EDO memorandum, the GTF was established with the 

following membership:

Team Leader – Charles A. Casto, Region IV

Assistant Team Leader – Mark Cunningham, Office of Nuclear Reactor Regulation

Team Members

o William Ford, Office of Nuclear Materials Safety and Safeguards

o James Shepherd, Office of Federal and State Materials and Environmental 

Management Programs

o Thomas Nicholson, Office of Nuclear Regulatory Research

o Cynthia Jones, Office of Nuclear Security and Incident Response

o Lisa London, Office of the General Counsel

o Ronald LaVera, Office of New Reactors

o Mel Gray, Region I

o Mark Lesser, Region II

o George Kuzo, Region II

o John Cassidy, Region III

o Michael Shannon, Region IV
(Intentionally left blank)
Appendix A

Response to Recent Groundwater Incidents
(Intentionally left blank)
A-1

Appendix A

Response to Recent Groundwater Incidents

A.1. Overview of U.S. Nuclear Regulatory Commission’s (NRC) Response to Recent 

Groundwater Incidents

NRC‟s requirements associated with leaks/spills establish the basis for its oversight of 

licensee operations with respect to groundwater incidents. Recognizing this, the 

Groundwater Task Force (GTF) reviewed this regulatory framework in Appendix C for 

operating reactors as well as those for other NRC-licensed facilities. This appendix 

describes recent leaks/spills and NRC‟s response to these incidents. 

In response to leaks/spills of radionuclides by nuclear power plants NRC implemented the 

inspection and assessment activities described in the Reactor Oversight Process (ROP). 

Regional managers were informed of incidents typically through resident inspector daily 

plant status activities and by public notification reports made by licensees to NRC. In 

response to these leaks/spills, resident inspectors and regional health physics (HP) 

specialist inspectors gathered information regarding the potential impact of the leaks/spills 

on the health and safety of onsite staff and the public. Inspectors reviewed licensee 

evaluations of the consequences of the leakage and independently assessed whether the 

projected doses to the public, if any, were within regulatory requirements. As licensees 

determined the leak sources, NRC inspectors assessed the technical adequacy of the 

licensee‟s operational and functionality assessments of the leaking component‟s capability 

to accomplish their intended function. Staff further independently assessed the adequacy of 

licensee actions to identify and resolve the leaks/spills. 

Regional staff and managers reported these leak/spill incidents to NRC headquarters 

stakeholders through formal morning plant status meetings and through informal 

communications. These internal discussions were accompanied in some cases by 

significant activities to convey NRC‟s safety perspectives to external stakeholders including 

Congressional, State, and local government officials, and the public. These activities were 

coordinated with personnel from the Office of Congressional Affairs (OCA), Office of Public 

Affairs (OPA), Office of the Executive Director for Operations (OEDO), and the Regional 

State Liaison Officers.

The staff‟s assessments formed the technical basis for determining the appropriate 

inspection response to these groundwater incidents in accordance with the Management 

Directive 8.3, “NRC Incident Investigation Program,” (MD 8.3) (ADAMS Accession No. 

ML031250592) and the guidance in Inspection Manual Chapter (IMC) 0309, 
A-2

“Reactive Inspection Decision Basis for Reactors” (ADAMS Accession No. ML092790408). 

Staff considered whether the leakage incidents were significant operational events that 

required further review using the guidance in IMC 0309. For leakage incidents that were 

considered significant operational events as defined in IMC 0309, evaluations were 

documented and completed to develop recommendations for either the Reactor Oversight 

Process (ROP) baseline inspections or augmented inspections. Senior regional managers 

provided oversight for the implementation of the IMC 0309 process and determined the 

appropriate inspection response. The majority of leak/spill incidents were inspected through 

ROP baseline inspections.

The ROP Action Matrix as described in IMC 0305, “Operating Reactor Assessment 

Program” (ADAMS Accession No. ML0305206111), provides a risk-informed, objective, and 

predictable framework that guides NRC inspection and oversight for licensee safety and 

security performance. The ROP recognizes there may be rare instances in which the 

regulatory actions dictated by the Action Matrix may not be appropriate. In a few instances,

senior regional managers in consultation with the NRC program office managers considered 

whether the leaks/spills warranted NRC regulatory inspection and oversight actions that 

deviated from the Action Matrix. In regards to two plant sites with leaks, NRC issued an 

internal ROP Deviation Memorandum that identified additional NRC inspections and 

oversight tailored to address the unique underlying technical and performance issues 

related to the leaks. 

Communications of these incidents were consistent with ROP guidance on report issuance. 

The licensees notified NRC of their report to the State as required by the industry voluntary 

initiative. 

A.2. Facts and Observations 

A.2.1. Vermont Yankee

On January 7, 2010, Entergy personnel at the Vermont Yankee (VY) nuclear plant provided 

a voluntary report to NRC that a routine sample result from a groundwater monitoring well 

indicated tritium levels of 17,000 pCi/L [Event Notification 45613]9. The samples were taken 

as part of VYs implementation of the voluntary industry groundwater monitoring program

(NEI-07-07) ADAMS Accession No. ML072600295). The monitoring well is located outside 

the protected area but within the owner controlled area and about 30 feet from the 

Connecticut River. Entergy managers established an evaluation team to determine the 

source of the tritium and developed enhanced sampling plans that included installation of 

additional groundwater monitoring wells. Entergy staff conducted further hydro-geological 

surveys and data collection to better characterize groundwater behavior on the site including 

 

9 Event notifications (ENs) are available via NRC‟s website at http://www.nrc.gov/reading-rm/doccollections/event-status/event/. 
A-3

the potential to affect drinking water wells on- and off-site. Entergy staff also conducted 

bounding analysis to confirm that the consequence of this leakage would not (a) affect 

public health and safety or (b) exceed any NRC regulatory requirements. Subsequently, in 

February 2010, Entergy personnel determined that the groundwater contamination was the 

result of a leak from an underground concrete pipe vault associated with the Advanced OffGas (AOG) system. The vault contained pipe that conveyed steam used in the hydrogen 

recombiners. A pipe leak in the vault occurred and a vault drain line was found clogged. As 

the vault subsequently filled with water, a release to the environment resulted. Entergy staff 

took action to terminate the leakage from this location and initiated actions to repair the 

degraded piping. At the drafting of this GTF report, Entergy is conducting a root cause 

evaluation to confirm the causes of the leak and develop further corrective actions. Entergy 

has continued to sample and analyze the Connecticut River and several on- and off-site 

drinking water wells for the presence of any plant-related radioactivity. There has been no 

activity distinguishable from normal background detected from these sites. To date, only 

shallow groundwater monitoring wells in the vicinity of the known leak source have produced 

groundwater with tritium levels above background. 

In response to the VY notification of the presence of tritium in a groundwater sample, NRC 

regional staff independently reviewed the information and closely monitored Entergy‟s 

investigation and analytical dose assessments. Regional staff completed a review of the 

available information in accordance with IMC 0309 and developed a recommendation that 

baseline inspections be performed. Health Physics (HP) inspectors conducted ROP 

baseline inspections related to follow-up activities and reviewed Entergy‟s actions to 

implementing the industry voluntary groundwater initiative. These inspection activities were 

accompanied by a very high level of internal and external stakeholder communication and 

outreach activities. 

Although tritium was identified in on-site groundwater monitoring wells, NRC staff to date 

has not identified a hazard to public health and safety, and the staff expects any off-site 

radiological releases to be very small (i.e., offsite doses, if any, would be negligible with 

respect to normal background radiation levels). However, considering the extraordinary 

level of interest and concern by stakeholders, including numerous congressional, state, and 

local officials, NRC concluded that increased NRC oversight of the characterization, 

mitigation, and remediation of the tritium contamination is warranted. As a result, a ROP 

Deviation Memorandum, dated April 5, 2010, was issued to provide for increased inspection 

and oversight to, in part, help address stakeholder concerns and improve public confidence

(ADAMS Accession No. ML100960321).

NRC preliminary inspection results were documented in a letter dated April 16, 2010

(ADAMS Accession No. ML101060419). NRC determined (a) that Entergy appropriately 

evaluated the contaminated groundwater with respect to off-site effluent release limits and 

the resulting radiological impact to public health and safety and (b) that Entergy complied 

with all applicable regulatory requirements and standards pertaining to radiological effluent 
A-4

monitoring, dose assessment, and radiological evaluation. NRC also determined that, as of 

the end of 2009, Entergy had completed certain essential elements of the industry voluntary 

initiative program. However, some aspects of the industry voluntary initiative had not been 

completed within the timeframe specified. 

A.2.2. Oyster Creek

On April 15, 2009, Oyster Creek personnel performing unrelated maintenance activities 

observed approximately twelve inches of standing water in an emergency service water 

cable vault. Sampling results indicated tritium concentrations in this water. Oyster Creek 

personnel pumped the water from the cable vault into drums for planned and controlled 

monitoring and release to the environment. Oyster Creek reported the condition to NRC in 

EN 44993 because notification was being made to another government agency (State of 

New Jersey as required by the industry voluntary initiative) for a situation related to the 

health and safety of the public. Oyster Creek staff completed sampling of monitoring wells 

and concluded there was likely a leak from underground or vaulted condensate storage tank 

related pipes. Oyster Creek personnel subsequently identified and replaced two carbon 

steel non-safety related buried pipes associated with the condensate system that had 

experienced localized corrosion resulting in a leak to the environment. 

Regional staff reviewed the available information in accordance with IMC 0309 and 

recommended that baseline inspections be performed. This recommendation was accepted 

and inspectors completed baseline inspections related to initial event response by Oyster 

Creek and documented the results in the next quarterly integrated inspection report dated 

July 30, 2009 (ADAMS Accession No. ML092110491). A team of NRC inspectors with 

specialties in HP and materials completed additional baseline inspections in August 2009 

and documented the results in a stand-alone inspection report dated September 8, 2009 

(ADAMS Accession No. ML092510218). The inspectors concluded that in one instance the 

leak was due to improper application of underground pipe coatings and in the other instance

an erroneous assumption on the part of Oyster Creek staff regarding the pipe material. The 

team did not identify any radiological public health and safety consequences associated with 

the leaks, or violation of NRC requirements or standards. Although tritium contaminated 

groundwater was detected on-site in the vicinity of the leaks, this condition did not, nor was 

it expected to, result in exceeding any regulatory dose limit to the public. Additionally, the 

GTF noted that plant-related radioactivity (including tritium) has not been detected at any 

off-site environmental monitoring location. Finally, the GTF concluded that, while some 

performance deficiencies in the early 1990s contributed to the cause of the leaks, these 

deficiencies had minor significance on operational and radiological safety. As a result, there 

were no findings of significance identified. 

A second unrelated pipe leak at Oyster Creek was identified in August 2009 when Oyster 

Creek personnel observed increased water levels in the turbine building perimeter sump. 

Investigation identified a leak in a 6-inch non-safety related condensate storage tank (CST) 
A-5

pipe in a location where the pipe passed through the turbine building foundation. Oyster 

Creek personnel replaced the leaking pipe. NRC inspectors reviewed the licensee‟s 

bounding radiological public dose calculations, root cause analysis report, and 

environmental sampling activities and concluded there was no radiological impact to the 

public. There were no findings of significance identified, and this inspection was 

documented in an NRC inspection report dated January 26, 2010 (ADAMS Accession No. 

ML100260020). 

As the GTF was finalizing this report, the State of New Jersey reported that tritium from 

Oyster Creek may have migrated off-site. Because of the late-breaking nature of this 

information, the GTF was unable to consider it in formulating its conclusions and 

recommendations.

A.2.3. Oconee

On February 9, 2010, Oconee voluntarily notified the NRC in EN 45690 that groundwater 

monitoring samples taken from two wells, in support of the industry groundwater initiative, 

indicated tritium levels of 24,400 pCi/L and 35,400 pCi/L. The levels triggered the reporting 

threshold of the voluntary industry groundwater initiative of 20,000 pCi/L. The monitoring 

wells are located on the site property and are not drinking water wells. The licensee issued 

a press release stating that the results from 52 other wells sampled on the site did not show 

tritium levels above the industry voluntary initiative reporting threshold criteria. Samples 

from surrounding monitoring wells indicated the tritium has not migrated off the plant site in 

groundwater. The licensee is continuing to try to determine the leak source.

The regional staff determined that the issue did not warrant a reactive inspection because 

NRC guidance thresholds were not met in IMC 0309, “Reactive Inspection Decision Basis 

for Reactors.” Media interest in the issue was very low. The regional staff and the senior 

resident inspector continue to monitor the licensee‟s actions through routine plant meetings 

and observations. 

A.2.4. Other Plants with Groundwater Contamination Conditions Since 2006

The GTF determined that there were six other plants since 2006 that had identified 

inadvertent releases of radioactive liquid to the environment (Indian Point, Millstone, Fort 

Calhoun, Fitzpatrick, Brunswick and Monticello). The GTF considered whether there were 

significant additional insights to be gained from our inspection, assessment, and oversight of 

licensee performance related to groundwater incidents at these plants. This review 

concluded the NRC experience related to groundwater contamination at the Indian Point site 

provides significant insights into the effectiveness of the ROP. Additionally, an NRC 

inspection finding of very low safety significance at the Brunswick plant was illustrative of 

inspection and assessment activities related to licensee response to a leak/spill. The GTF 

noted event reports were submitted by licensees for leaks/spills at other nuclear power 
A-6

plants (Millstone, Fort Calhoun, Fitzpatrick, and Monticello). The GTF concluded the 

implementation of the ROP oversight, inspection, and enforcement processes for these 

issues did not provide significant additional insights beyond that gained in considering 

NRC‟s oversight at Oyster Creek, Vermont Yankee, Oconee, Brunswick, and Indian Point.

A.2.4.1. Indian Point Units 1 and 2 Spent Fuel Pools 

NOTE: The 2006 Liquid Radioactive Release Lessons Learned Task Force (ADAMS 

Accession No. ML0626503120) considered the Indian Point Unit 1 and 2 spent fuel 

pool leakage conditions prior to 2006. The following discussion includes NRC 

inspections and observations from 2006 to the present. 

Leakage from the Indian Point Unit 2 (IP2) spent fuel pool (SFP) was identified in 

August 2005, when Entergy personnel began excavating an area adjacent to the IP2 SFP 

south wall. The excavation revealed a hairline crack with moisture along the south wall of 

the spent fuel pool. Initial samples did not detect any radioactivity and spent fuel pool 

leakage was not suspected. On September 1, 2005, contamination was first detected on a 

sample from the crack. A second crack was discovered two weeks later and Entergy 

personnel installed a collection device to capture leaking liquid. Analyses of the moisture 

indicated that the material had the same radiological and chemical properties as spent fuel 

pool water. In September 2005, Entergy personnel sampled water from an existing 

monitoring well in the IP2 transformer yard, and the results indicated an unexpected 

concentration of tritium in onsite groundwater. Prior to this sample, the well was last 

analyzed for tritium in 2000 and none was detected. In addition to the detection of tritium, 

the radionuclides nickel-63, cesium-137, strontium-90, and cobalt-60 were detected onsite 

at Indian Point. Entergy suspected these isotopes were the result of leakage from the 

Indian Point Unit 1 (IP1) SFP which resulted in the contamination of onsite groundwater.

NRC initiated a special inspection team (SIT) in September 2005 to (a) better understand 

the source of the radiological contamination, the causes, the extent of the condition, and any 

potential impact on spent fuel pool integrity and (b) confirm that public health and safety was 

being maintained as required by the regulatory requirements (ADAMS Accession No. 

ML0526400030).

Because the available information indicated that the leakage had been ongoing for some 

time and that the leakage included other radionuclides in addition to tritium, NRC issued a 

ROP Deviation Memorandum in October 2005 (ADAMS Accession No. ML053010404). 

This Deviation Memorandum authorizes the regional office to provide for increased 

inspections beyond the baseline required by the ROP. The Deviation Memorandum 

provided for oversight of Entergy‟s performance and progress in implementing its action 

plans for, in part, determining the location of the IP2 SFP leakage, effecting repairs, 

characterizing the on-site contamination, determining the sources, and establishing 
A-7

appropriate monitoring and control. The Deviation Memorandum also provided for 

coordination with New York State and local government officials regarding split sampling of 

on-site and off-site groundwater samples and results to enhance confidence in the sampling 

process.

As directed by the ROP Deviation Memorandum, the SIT continued into 2006 and closely 

monitored Entergy‟s actions to identify, evaluate and correct the leaks. The SIT‟s report 

dated March 16, 2006 (ADAMS Accession No. ML060750842), concluded that (a) that the 

existence of onsite groundwater contamination as well as the underlying source of leakage 

warranted continued efforts to achieve resolution, and (b) that, to date, the conditions do not 

present significant risk to public health and safety or to the environment. NRC staff

determined that (a) public health and safety had not been, nor was likely to be, adversely 

affected, and (b) the dose consequence to the public that can be attributed to current onsite 

conditions was negligible with respect to established NRC regulatory limits.

Subsequent to the SIT report, NRC‟s independent on-site groundwater sample analysis 

results demonstrated that strontium-90 was also a contaminant in the onsite groundwater, 

and further analyses by Entergy and the State of New York confirmed these analyses. This 

determination resulted in a significant expansion of the on-site groundwater characterization 

effort because the source of the strontium-90 contaminant was traced to leakage from the 

IP1 SFP. A full site-wide hydro-geologic investigation was subsequently instituted to include

the IP1 and IP3 SFPs. 

NRC continued augmented inspections (inspections beyond the required baseline), split 

groundwater sampling, and increased oversight of Entergy's activities in accordance with 

successive approved Deviation Memoranda through 2009 (ADAMS Accession No. 

ML063480016, ML073480290, ML083590057). During this period, NRC staff closely 

monitored Entergy's groundwater characterization efforts, performed independent 

inspections and testing, and independently evaluated radiological and hydrological 

conditions affecting groundwater onsite. NRC quarterly integrated inspection reports 

describe the results of augmented inspections under these Deviation Memorandums. 

In January 2008, Entergy submitted the results of its comprehensive groundwater 

investigation, and included its plan for remediation and long-term monitoring of the on-site 

groundwater conditions (ADAMS Accession No. ML0803205390). Entergy described the 

sources of the groundwater contamination to be the IP1 and IP2 SFPs. While both pools 

contributed to the tritium contamination of groundwater, the leaks from the IP1 SFP was 

determined to be the source of other contaminants such as strontium-90, cesium-137, and 

nickel-63. Entergy described the repairs and assessment of the IP2 SFP and plans to 

remove all fuel from the IP1 SFP to an on-site dry storage location and drain the IP1 SFP by 

the end of 2008, thereby essentially eliminating the source of the groundwater 

contamination from IP1.
A-8

NRC completed a team inspection under the Deviation Memorandum and concluded in their 

inspection report dated May 13, 2008 (ADAMS Accession No. ML081340425), that 

Entergy‟s response to the identified leaks was reasonable and technically sound. This team 

reviewed the circumstances surrounding the causes of the leaks and previous opportunities 

for identification and intervention and did not identify significant findings. This team further 

determined that (a) public health and safety has not been, nor is likely to be, adversely 

affected and (b) the dose consequence to the public that can be attributed to the leaks is 

negligible. The inspection report noted that Entergy planned to incorporate the 

implementation requirements of their Long Term Monitoring Program (LTMP) as additional 

actions to be taken under their Off-site Dose Calculation Manual, which assures that the 

LTMP is an extension of their other radiological monitoring programs. 

NRC followed Entergy‟s actions to remove all fuel from the IP1 SFP and drain the pool in 

2008. In September 2009, NRC completed a team inspection under the ROP Deviation 

Memorandum to, in part, assess the establishment, implementation, and maintenance of the 

LTMP and inspect and assess radiological effluents monitoring and control activities. The 

team concluded that Entergy‟s LTMP for the Indian Point units was effectively implemented 

and maintained in a manner that provided continued radiological monitoring of the 

groundwater conditions to confirm conformance with NRC regulatory requirements. In 

February 2010, NRC concluded that, based on these inspection results and split sampling 

results, the baseline inspection and oversight provided by the ROP were adequate to 

monitor Entergy‟s performance at the Indian Point site and a Deviation Memorandum was 

not warranted in 2010 (ADAMS Accession No. ML1006208631).

A.2.4.2. Indian Point Unit 2 Condensate Storage Tank Pipe Leak

On February 15, 2009, IP2 staff observed indications of wetness in a floor pipe sleeve 

where an underground pipe from the condensate storage tank entered the IP2 auxiliary 

feedwater pump building. Staff sampled the wetness and determined that the results 

indicated approximately 2000 pCi/L of tritium, which was consistent with water in the CST 

return line from the suction of the auxiliary feedwater (AFW) pumps. This carbon steel pipe 

is classified as safety-related and American Society of Mechanical Engineers (ASME) 

Class 3 material and subject to the regulatory requirements in the IP2 technical 

specifications (TS) for the CST. Entergy informed the resident inspectors of this leak. The 

resident inspectors completed baseline inspections and verified that Entergy operators 

entered the applicable TS 7-day action statement for this condition and took required actions 

to administratively determine that the back-up on-site city water tank was available, if 

needed, to provide water to the AFW pumps. Entergy personnel excavated a portion of the 

AFW pump building floor and identified the CST return pipe was leaking through a localized 

one and a 1⁄2-inch diameter hole where a small area of a protective coating was missing. 

Entergy staff replaced this section in accordance with ASME code requirements and 

returned the CST to operability within the time required in the associated TS action 
A-9

statement. Subsequent evaluation of the removed pipe section indicated structural integrity 

had been maintained.

NRC resident inspectors completed baseline inspections reviewing Entergy‟s operability 

evaluations, post maintenance testing, and temporary modifications related to the leak 

identification and pipe replacement activities. Regional inspectors also reviewed chemistry 

and radiological sample results and determined the releases were below regulatory 

requirements. Subsequent baseline inspections utilizing the problem identification and 

resolution inspection procedure were completed to review the Entergy root cause analysis 

and corrective actions and determine if there were prior opportunities to identify the leak. 

Entergy determined the leak occurred due to original construction specifications that allowed 

for large rocks in the backfill surrounding the pipe that likely damaged the pipe coating 

during installation of the pipe and allowed corrosion to occur on the surface of the pipe. 

Entergy staff determined the excavated pipes were found to be in good condition where the 

coating was intact. Entergy personnel planned actions to further monitor and inspect this 

piping. The inspectors did not identify any significant findings or violations of regulatory 

requirements (ADAMS Accession No. ML0922240592). 

A.2.4.3. Brunswick

Prior to 2007, the Brunswick nuclear plant utilized an unlined storm drain stabilization pond 

(SDSP) to receive turbine building (TB) chiller condensate containing elevated tritium 

concentrations exceeding 1.0×106(1,000,000) pCi/L (resulting from extensive steam leaks 

to the TB atmosphere). The chiller condensate was routed through storm drain piping (nonradioactive waste piping) and ultimately to the SDSP. Brunswick voluntarily reported (via 

EN 43420 in June 2007) that elevated tritium concentrations were identified in two manholes 

in close proximity to the SDSP. 

NRC completed an inspection and identified documents indicating unanticipated tritium 

contamination in liquids sampled from onsite structures (i.e., electrical manholes), in 

seepage from the SDSP to the intake canal, in shallow groundwater monitoring wells 

installed adjacent to the SDSP, and in shallow groundwater wells installed to monitor a 

previous spill from a degraded radioactive waste (radwaste) line near the onsite switchyard. 

In 2008, an NRC inspection reviewing Brunswick‟s implementing procedure related to 

monitoring of elevated tritium concentrations in groundwater led the inspectors to conclude 

that Brunswick personnel did not properly evaluate and initiate actions to address increasing 

tritium concentrations reported from 2003 through 2007 for quarterly samples collected from 

onsite monitoring wells established to monitor previously identified radioactive waste line 

leaks (ADAMS Accession No. ML0821300890). Specifically, the inspectors identified a 

performance deficiency, the licensee continued to attribute the tritium increases to a 

previous radioactive liquid effluent waste line break and not investigate the potential for 

releases resulting from the Brunswick Unit 2 storm drain piping leaks. This resulted in 

delayed actions by the licensee to address and correct abnormal liquid releases within the 
A-10

switchyard area. The inspectors identified a finding of very low safety significance (Green 

finding) because the performance deficiency did not result in offsite releases or result in 

offsite doses to members of the public. The inspectors determined the performance 

deficiency involved a “cross-cutting aspect” (a safety culture assessment feature of the 

ROP) in the area of human performance related to work practices and supervisory oversight 

because Brunswick staff did not properly evaluate monitoring well sample data to determine 

the possible radiological effects of plant operation on groundwater.

A.3. Conclusions 

A.3.1. Conclusion

The NRC inspection response to leaks/spills has varied widely and has been case specific. 

In some cases the staff only monitored leak/spill incidents while in other comparable 

incidents significant deviations to the baseline inspection program were approved.

 

A.3.2. Conclusion

Event Reports created through the NRC (Event Notifications) in response to State reporting 

required by the industry‟s voluntary groundwater initiative do not provide information 

describing the results of activities to identify and resolve leaks, the root causes of the leaks, 

corrective actions, or dose consequences. The public is informed of the leaks. However, 

they are not updated on the progress of identification of the final root cause of the leaks.

A.4. References 

MD 8.3. Management Directive 8.3, “NRC Incident Investigation Program,” March 27, 2001, 

ADAMS Accession No. ML031250592.

IMC 0309. NRC Inspection Manual Chapter 0309, “Reactive Inspection Decision Basis for 

Reactors,” February 2, 2010, ADAMS Accession No. ML092790408.

IMC 0305. NRC Inspection Manual Chapter 0305, “Operating Reactor Assessment 

Program,” December 24, 2009, ADAMS Accession No. ML0305206111.

NUREG-1022. Event Reporting Guidelines: 10 CFR §§ 50.72 and 50.73, Rev. 2, 

October 2000, ADAMS Accession No. ML0037625950.

EN 45613. Event Notification 45613 related to Vermont Yankee dated January 7, 201010.

 

10 Event notifications are available via NRC‟s website at http://www.nrc.gov/reading-rm/doccollections/event-status/event/.
A-11

NEI 07-07. Nuclear Energy Institute, “Industry Ground-Water Protection Initiative – Final 

Guidance Document,” Washington, DC, August 2007, ADAMS Accession No. 

ML072600295.

EN 44993. Event Notification 44993 related to Oyster Creek dated April 15, 2009, NRC 

Public website.

NRC Inspection Report (IR) -- Integrated Inspection Report 05000219/2009003, July 30, 

2009, ADAMS Accession No. ML092110491.

NRC IR 05000219/2009008, September 8, 2009, ADAMS Accession No. ML092510218.

NRC IR 05000219/2009005, January 26, 2010, ADAMS Accession No. ML100260020.

EN 45690. Event Notification 45690 related to Oconee dated February 9, 2010 

EN 43813. Event Notification 43813 related to Millstone dated November 29, 2007 

EN 43355. Event Notification 43355 related to Fort Calhoun dated May 10, 2007 

EN 45593. Event Notification 45593 related to Fitzpatrick dated December 28, 2009 

EN 45338. Event Notification 45338 related to Monticello dated September 9, 2010 

LRRLLTF. NRC Liquid Radioactive Release Lessons Learned Task Force Final Report, 

September 1, 2006, ADAMS Accession No. ML0626503120.

Memorandum to John R. White, Manager Special Inspection and James D. Noggle, Senior 

Inspector, Special Inspection, from A. Randolph Blough, Director, Division of Reactor Safety, 

Special Inspection Charter – Indian Point Unit No. 2, September 20, 2005, ADAMS 

Accession No. ML0526400030.

ROP Deviation Memorandum – Request for Deviation from the Reactor Oversight Process 

Action Matrix to Provide Increased Oversight of Specific Issues at Indian Point Energy 

Center, dated October 28, 2005,” ADAMS Accession No. ML053010404.

NRC IR 05000247/2005011, March 16, 2006, ADAMS Accession No. ML060750842.

ROP Deviation Memoranda -- Request for Deviation from the Reactor Oversight Process 

Action Matrix to Provide Increased Oversight of Specific Issues at Indian Point Energy 

Center dated December 11, 2006; Adams Accession No. ML063480016, December 19, 
A-12

2007; Adams Accession No. ML073480290, and December 16, 2008; ADAMS Accession 

No. ML083590057.

Letter from J.E. Pollock, Entergy Indian Point Energy Center, to U.S. NRC Document 

Control Desk, Results of Ground Water Contamination Investigation, ADAMS Accession No. 

ML0803205390. 

NRC IR 05000003/2007010, 05000247/2007010, May 13, 2008, ADAMS Accession No.

ML081340425.

Letter to J.E. Pollock, Entergy Indian Point Energy Center, from David C. Lew, Director, 

Division of Reactor Projects, March 3, 2010, ADAMS Accession No. ML1006208631.

NRC IR 05000247/2009003, August 12, 2009, ADAMS Accession No. ML0922240592.

EN43420. Event Notification 43420 related to Brunswick dated June 13, 2007. 

NRC IR 05000325/2008003 and 05000324/2008003, July 30, 2008, ADAMS Accession No. 

ML0821300890. 
Appendix B

Agency Actions
(Intentionally left blank)
B-1

Appendix B

Agency Actions

B.1. Introduction

The Groundwater Task Force (GTF) reviewed the following documents to assess whether 

additional staff actions are needed regarding groundwater at nuclear power plants. These 

items were selected as a direct result of the charter or they may be used by the NRC to 

review, inspect, and assess groundwater contamination incidents:

Liquid Radioactive Release Lessons Learned Task Force Final Report

Management Directive 8.3 and Inspection Manual Chapter 0309 

Public Radiation Safety Cornerstone Performance Indicator

Knowledge Management and Operating Experience 

Temporary Instruction 2515/173 

Public Radiation Safety Significance Determination Process

The results of these reviews and the ADAMS Accession numbers for each of these 

documents are provided below.

B.2. Reviews

B.2.1. Liquid Radioactive Release Lessons Learned Task Force (2006)

B.2.1.1. Overview

The focus of the September 2006 Liquid Radioactive Release Lessons Learned Task Force

(LRRLLTF) was on releases of radioactive liquids that were neither planned nor monitored

(ADAMS Accession No. ML062650312). Most of the incidents that occurred before 

LRRLLTF had involved tritium. However, the GTF did not limit its review to tritium-related 

incidents as other radioactive isotopes had been also inadvertently been released to the 

environment. An example included leaks from spent fuel pools, particularly where the pool 

contained fuel with degraded outer cladding material, which allowed some fission products 

to be released from the fuel into the pool water.

The most significant conclusion of the LRRLLTF regarded public health impacts. Although 

there had been a number of industry events where radioactive liquid was released to the 

environment in an unplanned and unmonitored fashion, based on the data available, the 

LRRLLTF did not identify any instances where the health of the public was impacted. When 

considering recommendations to be made as the result of the review, the LRRLLTF 

members were challenged to weigh the likely benefit of implementing recommendations 
B-2

against the cost. The LRRLLTF concluded that the potential for long-term undetected 

radioactive leaks resulting in a more than a minor radiation dose to members of the public 

was low. However, as illustrated by the Braidwood and Indian Point incidents, the LRRLLTF

concluded that the positive benefit to the NRC‟s goal of openness could be significant. The 

recommendations contained in the report reflected that judgment.

B.2.1.2. Facts and Observations

The LRRLLTF generated a report contained 26 recommendations that were intended to 

generally: enhance regulations or regulatory guidance for unplanned, unmonitored releases; 

review areas of decommissioning funding and license renewal; and enhance public 

communications. LRRLLTF prompted the revision of two guidance documents, Regulatory 

Guide (RG) 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in Liquid and 

Gaseous Effluents and Solid Waste” (ADAMS Accession No. ML091170109) and 

Regulatory Guide 4.1, “Environmental Monitoring For Nuclear Power Plants” (ADAMS 

Accession No. ML091310141).

LRRLLTF recommendations implementation status as of July 10, 2009 (ADAMS Accession 

No. ML091900252), provided a summary of the activities that closed each of the 26 

recommendations in the LRRLLTF report. This document shows Regulatory Guides 1.21 

and 4.1 were used as the basis to close 12 of the 26 recommendations. The LRRLLTF

report included one recommendation on the development of a consensus standard on the 

evaluation of radionuclide transport in groundwater. This standard was developed and is 

identified as American National Standard (ANSI/ANS) 2.17 (ADAMS Accession No. 

ML101310455). Since completion of the LRRLLTF report, development of this standard 

continued, and as of the writing of this GTF report, the draft standard has been completed, 

comments solicited and addressed. On March 31, 2010, a proposed final standard was 

provided to ANS for approval by the parent committee. Additionally, nine other 

recommendations were closed without any changes to NRC practices. These 

recommendations were developed for NRC to review programs, policies, and regulations 

related to activities that could impact groundwater protection in the following areas:

1. Spent fuel pool (SFP) telltale drains

2. Impact of SFP leakage (boric acid) on safety significant structures (concrete and 

rebar)

3. Applicability of Maintenance Rule for SSC that contain radioactive liquids

4. License renewal process for SSCs that contain liquid radioactive material.

5. Dialogue with State officials regarding application of the National Pollutant Discharge 

Elimination System (NPDES) for discharges of radioactive materials

6. Inspection guidance to review contamination incidents that could impact groundwater

7. Decommissioning funding

8. Immediate notification process
B-3

9. Policies to recommend licensees to consider agreement with state/local officials to 

voluntarily report radioactive liquid releases.

The creation of the ANSI/ANS standard and revisions to Regulatory Guides are not 

substitutes for regulations, as compliance with these documents is not required. In most 

cases, licensees may use previously established, acceptable alternative methods for 

complying with specified portions of the NRC‟s regulations. Consequently, there has been 

no impact on operating reactors from these LRRLLTF recommendations. 

B.2.2. MD 8.3 – NRC Incident Investigation Program

B.2.2.1. Overview

Management Directive (MD) 8.3, “NRC Incident Investigation Program” (ADAMS Accession 

No. ML031250592) is the policy that NRC uses, in part, to ensure that significant operational 

incidents involving reactor and material licensees regulated by the NRC are investigated in a 

timely, objective, systematic, and technically sound manner; that the factual information 

pertaining to each event is documented; and that the cause or causes of each event are 

ascertained. The incidents may involve responses by an incident investigation team (IIT), 

less formal responses by an augmented inspection team (AIT), or a special inspection team 

(SIT), depending upon the level of response required. The objectives of MD 8.3 are to 

promote public health and safety, instill public confidence, and provide for the common 

defense and security by understanding the cause or causes of incidents and preventing 

accidents.

Inspection Manual Chapter (IMC) 0309 provides guidance to the Office of Nuclear Reactor 

Regulation (NRR) and the Regional staff for implementing the requirements prescribed in 

MD 8.3.

B.2.2.2. Facts and Observations

MD 8.3 discusses an objective of instilling public confidence. Stakeholder response to 

groundwater contamination incidents suggests that this objective has not been fully met. 

Currently MD 8.3 states, in part that an: (1) IIT should be considered for a significant 

radiological release (levels of radiation or concentrations of radioactive material in excess of 

10 times any applicable limit in the license or 10 times the concentrations specified in 

10 CFR Part 20, Appendix B11, Table 2, when averaged over a year) of byproduct, source, 

or special nuclear material to unrestricted areas; and (2) AIT should be considered for a 

radiological release of byproduct, source, or special nuclear materials to unrestricted areas 

that resulted in an occupational exposure or exposure to a member of the public in excess 

of the applicable regulatory limit (except for shallow-dose equivalent to the skin or 

extremities from discrete radioactive particles). MD 8.3 does not have predefined criteria for 

 

11 http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-appb.html
B-4

when a special inspection is warranted for incidents that involve leaks/spills of radioactive 

material that are below the regulatory limits. However, Section 04.05 (Radiation Safety) of 

IMC 0309, issued February 2, 2010, does establish criteria for conducting a special 

inspection. This criterion is: [a release] that led to a large (typically greater than 100,000 

gallons), unplanned release of radioactive liquids inside the restricted area that has the 

potential for groundwater, or offsite, contamination. 

B.2.3. Public Radiation Safety Cornerstone Performance Indicator

B.2.3.1. Overview

The NRC assessment program collects information from inspections and performance

indicators (PIs) in order to enable NRC to arrive at objective conclusions about a licensee‟s 

safety performance. Based on this assessment information, the NRC determines the 

appropriate level of NRC response, including supplemental inspection and pertinent 

regulatory actions. The purpose of the Radiation Safety Cornerstone PI is to assess the 

performance of the licensee‟s radiological effluent control program for both liquid and 

gaseous effluents. As with any PI, licensees have volunteered to report the needed 

information quarterly to the NRC. In accordance with NEI 99-02 Revision 6, (ADAMS 

Accession No. ML092931123), a radiological occurrence is when dose to a member of the 

public exceeds any or all of the following values: (1) Liquid radiological effluents release in 

excess of, 1.5 mrem/quarter (whole body) and 5 mrem/quarter (organ); and (2) gaseous 

radiological effluents released in excess of, 5 mrads/quarter (gamma dose), 

10 mrads/quarter (beta dose), and 7.5 mrem/quarter (organ dose from I-131, I-133, H-3, and 

particulates). 

B.2.3.2. Facts and Observations

An effective PI should provide a meaningful distinction when there is a change in 

performance. The Public Radiation Safety Cornerstone has one PI - RETS/ODCM 

(Radiological Environmental Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluents). From a review of the PI data submitted since the beginning of 

Reactor Oversight Process (ROP) (calendar year 2000), the GTF noted that the industry has 

never had one reportable occurrence even though there have been various levels of 

performance, as evidenced by the number of previously unmonitored leaks/spills that were 

identified when the industry groundwater protection initiative was implemented. The GTF

identified that the effectiveness of this PI was questioned previously in an open Reactor 

Oversight Process Feedback Form that requests some changes to the Public Radiation 

Safety Cornerstone Performance Indicator. Specifically, Feedback Form 0308.1-1140 

submitted in May 2007 stated: “The Performance Indicator for the Public Radiation Safety 

Cornerstone does not appear to be a robust indicator of licensee performance and does not 

appear effective in identifying out-of-normal performance.”
B-5

B.2.4. Knowledge Management and Operating Experience Program

B.2.4.1. Overview

NRC‟s Operating Experience (OpE) program supports NRC‟s mission to protect public 

health, safety, and the environment by administering an effective, coordinated program to 

systematically collect, communicate, and evaluate domestic and international reactor 

operating experience, and apply the lessons learned. This effort is designed to support 

rulemaking, licensing, oversight, and incident response programs. This program functions 

as the focal point of NRC‟s reactor operating experience program and is designed to ensure 

operating experience information is processed effectively and efficiently in a risk-informed 

manner. The stated goals of the program are:

OpE information is collected, evaluated, communicated, and applied to support the NRC

goal of ensuring safety.

OpE is used to improve the effectiveness, efficiency, and realism of NRC decisions.

The public, Congress, and other external stakeholders are provided with accurate, 

timely, and balanced information regarding OpE, including actual or potential hazards to 

health and safety.

In addition, NRC‟s Knowledge Management Center has been built as an interactive internal 

webpage to assist NRC to collect, capture, and share knowledge/information relevant to 

functions within NRC to create an organizational library readily available to all and which is 

designed to serve the staff. The Knowledge Management Center is overseen by a group of 

technical staff drawn from across NRC.

B.2.4.2. Facts and Observations

NRC Actions. A search of the internal OpE webpage by the GTF using the terms “tritium” or 

“groundwater,” between May 2004 and May 2010, retrieved six documents related to 

domestic and international communications of buried piping issues or leaks/spills that could 

result in groundwater contamination. 

The OpE program includes an annual review of industry events. In 2008, NRC‟s Technical 

Review Group (TRG) identified that the number of plants with on-site tritium leaks had 

increased. It also stated that the number of plants reporting tritium leaks would continue to 

increase as plants begin to implement the NEI voluntary groundwater protection initiative. In 

2009, the TRG confirmed that the initiative identified additional leaks/spills and correctly 

reported that leaks/spills have received a high level of public and political interest. The 

2009 report also stated that groundwater protection issues became an issue of NRC-wide 

attention. However, these reviews did not provide context to the events, an evaluation of 

the events, nor any conclusion regarding NRC decisions regarding the previously unplanned 

and unmonitored leaks/spills. 
B-6

The GTF also reviewed the NRC‟s Knowledge Management Center to determine the value 

of the Knowledge Management (KM) information regarding groundwater. There is one 

“thread” or “conversation” registered on the KM website regarding groundwater. This thread 

lists one NUREG document and several presentations. Otherwise, there is no thorough 

description of groundwater or the associated regulatory history. Three NRC staff members 

are registered on the thread with a total of 512 page views. The webpage has not been 

updated in the past 5 years.

The NRC commissioned NUREG/CR-6805, “A Comprehensive Strategy of Hydrogeologic 

Modeling and Uncertainty Analysis for Nuclear Facilities and Sites,” (ADAMS Accession No. 

ML032470827) in 2003 which was used by the staff to better understand groundwater flow. 

The NRC has also revised inspections of nuclear power plants to evaluate licensees‟ 

programs to inspect, assess and repair equipment and structures that could potentially leak. 

In 2005, several presentations on groundwater flow and nuclide transport were given to 

NRC‟s Advisory Committee on Nuclear Waste.

The NRC has conducted lessons learned on groundwater events; nevertheless, in terms of 

OpE and Knowledge Management for groundwater incidents, due to its low safety/risk 

significance, NRC has not fully developed a learning environment that ensures lessons are 

captured and communicated within NRC.

Industry Actions. The industry has also taken actions to communicate lessons learned from 

leaks and spills. The annual RETS/REMP Workshop is a forum to exchange practical 

experiences and issues related to the Radioactive Effluent Technical Specifications (RETS) 

and Radiological Environmental Monitoring Programs (REMP) at commercial nuclear power 

plants. Groundwater contamination presentations have become a regular event at these 

workshops since 2005. Just as the public concern of groundwater contamination has risen 

over the years, so to have the number of presentations and knowledge exchange on this 

topic at this annual forum. For example, in 2005, there were two presentations at the 

RETS/REMP Workshop (approximately one hour each); however, in 2009, there were two 

days of presentations on loss of licensed material confinement and the lessons-learned.

B.2.5. Temporary Instruction 2515/173 “Review of the Implementation of the Industry Ground 

Water Protection Voluntary Initiative”

B.2.5.1. Overview

The objective of this Temporary Instruction (TI) (ADAMS Accession No. ML082770349) is to 

assess ground water protection programs to determine whether licensees have 

implemented the voluntary industry Groundwater Protection Initiative (GPI) (i.e., the 

objective is not to perform an assessment of the adequacy of the licensee‟s ground water 

monitoring program). The 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 (ADAMS Accession No. ML062260198). The GPI 
B-7

identifies the actions the industry deems necessary for implementation of a timely and 

effective ground water protection program. The information collected through the TI 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. 

B.2.5.2. Facts and Observations

At the time of the GTF‟s evaluation, NRC had completed TI 2515/173 at 47 of the 104 (45%) 

power reactors in the United States. The results indicate that 19 reactors satisfied all the 

requirements outlined in NEI 07-07, “Industry Ground Water Protection Initiative – Final 

Guidance Document" (ADAMS Accession No. ML072600295). An additional 7 reactors 

were only lacking the independent review performed under the auspices of NEI, but these 

reviews had already been scheduled for all 7 reactors. Objective 2.3 of NEI 07-07, “Thirty 

Day Reports” was successfully completed at all 47 reactors that were inspected. 

Although no findings were identified in inspection reports, the inspectors identified 

discrepancies at 21 (40%) of the reactors where the TI was completed. The results indicate 

that 13 reactor sites had discrepancies associated with Objective 1.4,” Remediation 

Process.” Eleven reactor sites had a discrepancy with Objective 1.2,”Site Risk 

Assessment.” As background information, a finding is identified when a licensee fails to 

meet a requirement or a standard (either a regulatory required standard or a self-imposed 

standard). The voluntary industry initiative is neither a requirement nor standard; therefore, 

the inspection reports used the term discrepancy to identify areas of incomplete 

implementation of the voluntary initiative. 

The TI is scheduled to be completed in August 2010 and a full NRC report is planned to be 

issued in late Fall 2010.

B.2.6. Public Radiation Safety Significance Determination Process

B.2.6.1. Overview

When the ROP was first developed, it was recognized that probabilistic risk assessment 

techniques could not generally be applied to the ROP cornerstones of physical security, 

emergency preparedness, and radiation safety. Therefore, to establish the thresholds for 

categorizing the significance of findings, expert panels were formed during the ROP 

development in the late 1990's to define those thresholds. In part, these panels were guided 

by what the expected NRC response should be for various types of licensee performance 

deficiencies. These deterministic principles applied to the development of the Public 

Radiation Safety Significance Determination Process (SDP). 
B-8

B.2.6.2. Facts and Observations

IMC 0308 Attachment 3, Appendix D

12 (Technical Basis for Public Radiation Safety 

Significance Determination Process), provides the technical basis for the public radiation 

safety significance determination process. In addition to the regulatory requirements, this 

cornerstone contains a "public confidence" factor that is used to define the significance of a 

finding. It was recognized by the NRC and stakeholders that a licensee‟s control of its 

radioactive material is a significant issue for members of the public; even when very low 

levels of radioactive material are involved. Because of this, the Public Radiation Safety SDP 

was developed with a "public confidence" factor, which provides for a higher level of 

significance than would be warranted based solely on the risk from exposure to the 

radioactive material.

In May 2006, the Commission directed the staff to engage stakeholders using existing ROP 

change guidelines to update the SDP in the public radiation cornerstone to ensure that it is 

consistent with the ROP program goals, including an appropriate risk-informed approach to 

radiation protection. From these efforts, the staff concluded that the radioactive 

environmental monitoring program branch would be better aligned with the risk-informed 

goals of the ROP by reducing the significance of a licensee‟s failure to assess the 

environmental impacts to very low significance (Green finding) because this program is a 

verification of the effluent release program. The SDP, contained in IMC 0609 Appendix D 

(ADAMS Accession No. ML072970802) was revised in 2007 to reflect this decision. 

However, the GTF identified that the basis document for the public radiation safety 

significance determination process retained the concept that control of its radioactive 

material is a significant issue for members of the public; even when very low levels of 

radioactive material are involved.

B.3. Conclusions

B.3.1. Conclusion

The current radiological effluent PI reporting requirement does not provide meaningful data. 

The staff could consider adopting the recommendations stated in Reactor Oversight 

Process Feedback Form 0308.1-1140 (2007) for the Public Radiation Safety Cornerstone 

Performance Indicator: 

(1) Revise NRC IMC 0308 to more accurately explain the public radiation cornerstone PI, its 

basis, and the NRC‟s benchmarking. Review and revise baseline inspection procedure 

71124.06 to ensure that it provides adequate inspection of areas that were deleted from 

the original PI, including radiation monitor reliability/availability.

 

12 http://www.nrc.gov/reading-rm/doc-collections/insp-manual/manual-chapter/mc0308-att3-appd.pdf
B-9

(2) Revising the PI to include a more leading indicator of program degraded performance 

(e.g., radiation monitor performance, system availability, and unplanned/unmonitored 

releases). 

Another option could involve changing the PI to track the number of incidents of leaks/spills 

based upon the voluntary notification process of NEI 07-07, making any event that triggers 

the threshold an occurrence. Three or more occurrences in a two-year cycle might be a 

reasonable threshold, which would represent a deficiency in licensee performance of 

enough significance to warrant additional follow-up inspection above the baseline program 

to independently review and evaluate licensee corrective actions. 

B.3.2. Conclusion 

In the areas of OpE and Knowledge Management for groundwater incidents, the staff should 

consider reassessing its processes to ensure that OpE associated with groundwater 

incidents collected at a lower threshold and is disseminated appropriately. A revision to its 

internal OpE procedure could improve management of emergent issues with high external 

interest that involve non-risk systems or issues of low safety significance. However, this 

would not be consistent with the existing risk-informed framework. 

B.3.3. Conclusion 

There is an inconsistency between the Public Radiation Safety Cornerstone SDP in IMC 

0609 Appendix D and the associated technical basis document in IMC 0308, Attachment 3, 

Appendix D regarding the use of “public confidence” factor which provides for a higher level 

of significance than would be warranted based solely on the risk from exposure to the 

radioactive material. Consideration could be given to evaluating a deterministic 

assessment technique that recognizes loss of confinement is a concern even when very low 

levels of radioactive material are involved. Additionally, NRC should consider aligning the 

SDP in IMC 0609 Appendix D and the technical basis stated in IMC 0308 Attachment 3, 

Appendix D.

B.3.4. Conclusion 

Incorporation of the voluntary industry initiative into any revised groundwater protection 

framework should be considered. 

B.4. References

LLRLLTF. Liquid Radioactive Release Lessons Learned Task Force Final Report (ADAMS 

Accession No. ML062650312).
B-10

Liquid Release Task Force Recommendations Implementation Status as of July 10, 2009 

(ADAMS Accession No. ML091900252).

Regulatory Guide 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in 

Liquid and Gaseous Effluents and Solid Waste,” Revision 2 (ADAMS Accession No.

ML091170109).

Regulatory Guide 4.1, “Radiological Environmental Monitoring For Nuclear Power Plants,” 

Revision 2, June 2009 (ADAMS Accession No. ML091310141).

ANSI/ANS-2.17-20xx, “Evaluation of Subsurface Radionuclide Transport at Commercial 

Nuclear Power Production Facilities,” Draft Rev. 11 (ADAMS Accession No. ML101310455).

MD 8.3, Management Directive 8.3, “NRC Incident Investigation Program,” March 27, 2001

(ADAMS Accession No. ML031250592).

IMC 0309. Inspection Manual Chapter 0309, “Reactive Inspection Decision Basis For 

Reactors,” February 2, 2010, (ADAMS Accession No. ML092790408).

NEI 99-02. Regulatory Assessment Performance Indicator Guideline; Revision 6 (ADAMS 

Accession No. ML092931123).

NUREG/CR-6805, “A Comprehensive Strategy of Hydrogeologic Modeling and Uncertainty 

Analysis for Nuclear Facilities and Sites,” July 2003 (ADAMS Accession No. ML032470827).

NEI 07-07. “Industry Ground Water Protection Initiative – Final Guidance Document,” August 

2007, (ADAMS Accession No. ML072600295).

TI 2515/173. Temporary Instruction 2515/173, “Review of the Implementation of the Industry 

Ground Water Protection Voluntary Initiative,” Revision 1 (ADAMS Accession No.

ML082770349).

NEI 08-08. Nuclear Energy Institute NEI-08-08A, Rev. 0, “Guidance for Life Cycle 

Minimization of Contamination”, October 2009, (ADAMS Accession No. ML093480532).

SECY-07-0112, “Staff Evaluation and Proposed Revision to the Public Radiation Safety 

Significance Determination Process to Address Radioactive Liquid Spills and Leaks,” July 6, 

2007 (http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2007/secy2007-

0112/2007-0112scy.pdf).

IMC 0308. Inspection Manual Chapter 0308, Attachment 3, Appendix D, “Technical Basis for 

Public Radiation Safety Significance Determination Process,” June 25, 2004
B-11

(http://www.nrc.gov/reading-rm/doc-collections/insp-manual/manual-chapter/mc0308-att3-

appd.pdf).

IMC 0609. Inspection Manual Chapter 00609, Appendix D, “Public Radiation Safety 

Significance Determination Process,” February 2, 2008 (ADAMS Accession No.

ML072970802).

NUREG/CR-6948, Vol. 1 Integrated Ground-Water Monitoring Strategy for NRC-Licensed 

Facilities and Sites: Logic, Strategic Approach and Discussion, U.S. NRC, Washington, DC, 

November 2007. (http://www.nrc.gov/reading-rm/doccollections/nuregs/contract/cr6948/v1/index.html)

NUREG/CR-6948, Vol. 2 Integrated Ground-Water Monitoring Strategy for NRC-Licensed 

Facilities and Sites: Case Study Applications, U.S. NRC, Washington, DC, November 

2007. (http://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr6948/v2/index.html)
(Intentionally left blank)
Appendix C

Regulatory Framework for Groundwater 

Incidents Involving NRC Licensees
(Intentionally left blank)
C-1

Appendix C

Regulatory Framework for Groundwater Incidents Involving NRC Licensees

C.1. Overview

The regulations found in 10 CFR Part 20 establish standards for protection against ionizing 

radiation resulting from activities of NRC licensees and are intended to control, amongst 

other things, the possession and use of licensed material such that that the total dose to an 

individual does not exceed radiation protection standards. These regulations are issued 

under the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 

1974, as amended. Recognizing this, the Groundwater Task Force (GTF) reviewed the 

regulatory framework with regard to groundwater for operating reactors as well as those for 

other NRC-licensed facilities (NRC 1986). In addition, the GTF reviewed SECY-09-0042 

(ADAMS Accession No. ML090500143), which proposes a final rule impacting, to some 

degree, NRC‟s regulation of subsurface contamination. The following sections summarize 

the key aspects of the operating reactor regulatory framework and identify important 

differences between that framework and those established for other licensing programs. 

Based upon this review, the GTF derived conclusions regarding regulatory framework 

issues. 

C.2. Facts and Observations

The overarching requirements regulating radiological impacts for facility operations are in 

10 CFR Part 20. The framework of regulations that address losses of licensed material 

confinement may be best understood by first reviewing what the regulations require to 

restore and release a site at decommissioning.

Under 10 CFR § 20.1003, 

"Residual radioactivity means radioactivity in structures, materials, soils, groundwater, 

and other media at a site resulting from activities under the licensee's control. This 

includes radioactivity from all licensed and unlicensed sources used by the licensee, but 

excludes background radiation. It also includes radioactive materials remaining at the 

site as a result of routine or accidental releases of radioactive material at the site and 

previous burials at the site, even if those burials were made in accordance with the 

provisions of 10 CFR Part 20." 

Thus, radioactivity in groundwater is considered by, and regulated by, NRC. It does not 

matter if the material was licensed or unlicensed. Similarly, it does not matter if the release 

was accidental (e.g., a leak) or intentional (e.g., a planned discharge). It does not matter if 

the material is in a safety-related pipe or a non-safety related pipe, if it is associated with the 

licensee's activities; it is regulated by the NRC. It also makes no difference if the licensee is 
C-2

a complex power plant or a single source material licensee; the same definition of residual 

radioactivity applies. The level of residual radioactivity is most relevant when a licensee 

decides to cease operations and must satisfy NRC‟s decommissioning requirements.

In addition to NRC requirements, NRC has entered into a Memorandum of Understanding13

(MOU) with EPA on cleanup of radioactively contaminated sites. This MOU includes 

provisions for NRC and EPA consultation for certain sites including when, at the time of 

license termination, contamination exceeds EPA-permitted levels. Under 10 CFR

§ 20.1402, "Radiological criteria for unrestricted use," for a site to be restored and released 

by the NRC for unrestricted use, the residual radioactivity, including activity in groundwater, 

must meet the following:

"A site will be considered acceptable for unrestricted use if the residual radioactivity that 

is distinguishable from background radiation results in a TEDE14 to an average member 

of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that 

from groundwater sources of drinking water, and the residual radioactivity has been 

reduced to levels that are as low as reasonably achievable (ALARA). Determination of 

the levels which are ALARA must take into account consideration of any detriments, 

such as deaths from transportation accidents, expected to potentially result from 

decontamination and waste disposal."

Thus, there are two controlling requirements on subsurface radioactivity that determine if a 

site may be released: 1) a 25 mrem per year limit for all pathways, including from drinking 

water and/or groundwater, and 2) reducing the residual radioactivity, which includes activity 

in groundwater, to as low as reasonably achievable (ALARA). ALARA means making every 

reasonable effort to maintain exposures to radiation as far below the dose limits as is 

practical consistent with the purpose for which the licensed activity is undertaken, taking into 

account the state of technology, the economics of improvements in relation to state of 

technology, the economics of improvements in relation to benefits to the public health and 

safety, and other societal and socioeconomic considerations, and in relation to utilization of 

nuclear energy and licensed materials in the public interest. See 10 CFR § 20.1003.

Under 10 CFR § 20.1501, licensees are required, at all times including both operations and 

decommissioning, to conduct surveys to determine, among other things, concentrations or 

quantities of radioactive material, and potential radiological hazards. These surveys must 

be reasonable under the circumstances to evaluate groundwater radioactivity to the extent 

that it may be necessary for the licensee to comply with the regulations 10 CFR Part 20. 

Additionally, licensees are also required to maintain records for purposes of tracking spills 

and leaks.

At all times, licensees must practice ALARA with respect to doses to both the members of 

the public and with workers. See 10 CFR § 20.1101(b), § 20.1301, and § 20.1302. The 

 

13 http://www.nrc.gov/reading-rm/doc-collections/news/2002/mou2fin.pdf

14 TEDE is the Total Effective Dose equivalent, as defined in 10 CFR Part 20.
C-3

methods used by the licensee to achieve ALARA are reviewed at least annually. See 

10 CFR § 20.1101(c). 

As previously discussed, ALARA principles apply to doses associated with groundwater 

contamination. See 10 CFR § 20.1402. 

C.2.1. Operating Reactors

Licensing Bases. Today's operating reactors were licensed under a multi-step process 

under 10 CFR Part 50. In brief, a preliminary design in the form of a Preliminary Safety 

Analysis Report (PSAR) is submitted as part of a request for a construction permit, as 

discussed in 10 CFR § 50.34(a). The PSAR includes the principal design criteria (PDC) for 

a proposed facility. The PDC establish the necessary design, fabrication, construction, 

testing, and performance requirements for structures, systems, and components important 

to safety; that is, structures, systems, and components that provide reasonable assurance 

that the facility can be operated without undue risk to the health and safety of the public. 

Thus, the PSAR addresses how licensees plan to control liquids, and provides that 

information to NRC staff to review in order to decide if it is appropriate to issue a 

construction permit. 

Within 10 CFR Part 50, Appendix A, the General Design Criteria (GDC) is described, which 

establishes minimum requirements for the principal design criteria. Included among these 

criteria are several related to controlling effluents. For example, GDC 60, "Control of 

releases of radioactive materials to the environment," states that the facility‟s design shall 

include means to control suitably the release of radioactive materials in gaseous and liquid 

effluents, and requires consideration of any unfavorable site environmental conditions that 

can be expected to impose unusual operational limitations upon the release of such 

effluents to the environment. GDC 64, "Monitoring radioactivity releases," requires that a

means shall be provided for monitoring, among other things, the facility environs for 

radioactivity that may be released from normal operations, including anticipated operational 

occurrences, and from postulated accidents. 

Subsequently, the applicant submits its Final Safety Analysis Report (FSAR) as part of the 

application for an operating license, as described in 10 CFR § 50.34(b). The FSAR updates 

the information in the PSAR, which includes information as to how the facility will meet its 

GDC or PDC. Under 10 CFR § 50.34(b)(3) the FSAR must include the kinds and quantities 

of radioactive materials expected to be produced in the operation. Further, under 10 CFR

§ 50.34(b)(3), the FSAR must include the means for controlling and limiting radioactive 

effluents and radiation exposures within the limits set forth in 10 CFR Part 20. Thus, 

controls and means to limit radioactive effluent are part of the application and part of the 

licensing basis of operating reactors. 

The discussion above is by no means all-inclusive; and additional regulations have been 

added to the regulatory framework over the years was promulgated that affected later 
C-4

applications. For example, the Commission promulgated 10 CFR § 50.34a, which includes 

a reference to Appendix I, requiring more specific information on the description of the 

equipment and procedures for the control of gaseous and liquid effluents and for the 

maintenance and use of equipment installed in radioactive waste systems. 

The regulations are not as prescriptive in telling licensees how to maintain their licensing 

basis for systems that are not directly associated with protecting the reactor core. Thus, the 

maintenance of piping and tanks that contain radioactive fluid may not be directly addressed 

by any specific paragraph in 10 CFR Part 50.

License Renewal. The License Renewal Rule, 10 CFR Part 54, also targeted core 

protection and requires licensees to demonstrate that systems designed for core protection 

are maintained consistent with the current licensing basis during the period of extended 

operations. 

C.2.2. Decommissioning Reactors

Release of all or part of the site, after decommissioning, makes it available to members of 

the public for use with or without restrictions. NRC has requirements for areas to be 

released from the license in 10 CFR §§ 50.82 and 50.83 (which incorporate §§ 20.1402 and 

20.1403). In order to comply with these regulations, the licensee conducts sampling and 

monitoring to accurately define all radioactivity remaining on the site. Following remediation, 

as defined in the License Termination Plan (LTP), or request for partial site release, 

sampling of groundwater for residual radioactivity must be conducted according to an 

approved scheme, to demonstrate compliance with release criteria.

In addition to NRC requirements, as mentioned earlier, NRC has entered into a MOU with 

EPA on cleanup of radioactively contaminated sites. This MOU includes provisions for NRC 

and EPA consultation for certain sites including when, at the time of license termination,

contamination exceeds EPA-permitted levels.

C.2.3. Proposed Final Rule on Decommissioning Planning (SECY-09-0042)

In SECY-09-0042, currently before the Commission, NRC staff recommended that a new 

clarifying rule be adopted that would require licensees to conduct their operations to 

minimize the introduction of residual radioactivity into the site, including subsurface soil and 

ground water (i.e., proposed 10 CFR § 20.1406(c)). Staff noted in 62 FR 39058 (July 21, 

1997), the intent of § 20.1406 is to emphasize the importance, in an early stage of planning, 

for facilities to be designed and operated in a way that would minimize the amount of 

radioactive contamination generated at the site during its operating lifetime. More 

specifically, a new section (§ 20.1406(c)) would be added such that operating facilities, 

including reactors “shall, to the extent practical, conduct operations to minimize the 

introduction of residual radioactivity into the site, including the subsurface, in accordance 

with the existing radiation protection requirements...” The longer subsurface contamination 
C-5

continues at a site, the larger the area contaminated with residual radioactivity may be. This 

may result in increased cleanup costs, longer periods of time to clean up and potentially 

more public concern.

In SECY-09-0042, NRC staff concluded that new or amended regulations for this final rule 

either clarify existing requirements, require the collection of information using existing 

equipment and procedures, or are administrative matters outside the scope of the backfitting 

rule (i.e., 10 CFR § 50.109). Actions undertaken by licensees during facility operations to 

comply with these new and amended requirements are expected to establish a technical 

basis for licensees and the NRC to understand the effects of significant residual radioactivity 

on decommissioning costs, and will help to determine whether existing financial assurance 

provided for site specific decommissioning is adequate. This rule would require licensees to 

identify and evaluate subsurface contamination, maintain records of contamination, and 

account for the cost of remediation of residual contamination for site-specific 

decommissioning cost estimates. This rule is directed at decommissioning planning and 

would not alter the regulatory framework for confinement of licensed material, incorporate 

the voluntary industry initiative or require early remediation. However, in response to the 

Staff Requirements Memorandum (SRM) for SECY-07-0177, staff is separately pursuing 

further improvements to the decommissioning planning process with the objective of 

avoiding complex decommissioning challenges that can lead to legacy sites. The GTF 

determined that the staff is developing a technical basis to address the need for immediate

remediation of spills at NRC-licensed facilities. This technical basis, in conjunction with 

stakeholder engagement and development of dose limits and criteria, may lead to a decision 

on the need for a rulemaking.

At its 183rd Meeting, in 2007, the Advisory Committee on Nuclear Waste and Materials15

(ACNW&M) received a presentation from the NRC staff on the proposed rulemaking

approach to prevent legacy sites. The ACNW&M offered the Commission the following 

recommendations on early remediation:

The Committee believes that legacy sites can be prevented through: (1) prevention 

of unplanned releases; (2) unplanned release detection; and (3) prompt remediation 

of unplanned releases rather than delaying remediation until final decommissioning. 

The Committee recommends that the NRC require licensees to promptly assess and

remediate unplanned releases. The staff should develop criteria specifying the

assessments and actions a licensee should take to characterize and mitigate the

impacts of unplanned releases. These criteria should preclude most licensees from

deferring action until eventual decommissioning. These criteria should also 

emphasize the application of the ALARA principle to fully account for the impacts of 

contamination if remediation is deferred.

 

15 In 2007, the ACNW&M was a separate Committee from the Advisory Committee on Reactor 

Safeguards. Currently the Committees are merged as one, titled the Advisory Committee on Reactor 

Safeguards.
C-6

The Committee recommends that the Commission consider gathering additional

stakeholder input regarding prevention of legacy sites from a broad range of

stakeholders including licensees, advisory or community groups, and State and local

governments that participate in decommissioning.

C.2.4. New Reactors

New applicants are required to comply with § 20.1406, which states:

(a) Applicants for licenses, other than early site permits and manufacturing licenses

under Part 52 of this chapter and renewals, whose applications are submitted after 

August 20, 1997, shall describe in the application how facility design and procedures for 

operation will minimize, to the extent practicable, contamination of the facility and the 

environment, facilitate eventual decommissioning, and minimize, to the extent 

practicable, the generation of radioactive waste.

(b) Applicants for standard design certifications, standard design approvals, and 

manufacturing licenses under Part 52 of this chapter, whose applications are submitted 

after August 20, 1997, shall describe in the application how facility design will minimize, 

to the extent practicable, contamination of the facility and the environment, facilitate 

eventual decommissioning, and minimize, to the extent practicable, the generation of 

radioactive waste.

DC/COL-ISG-06 “The Evaluation and Acceptance Criteria for 10 CFR § 20.1406 to Support 

Design Certification and Combined License Applications” (ISG-06)16 provides guidance to 

the staff for review of the design features and operation of system, structures, or 

components (SSCs) that contain or handle radioactive material, but does not provide the 

level of detail contained in other SRP sections. Regulatory Guide (RG) 4.21, “Minimization 

of Contamination and Radioactive Waste Generation: Life-Cycle Planning,” provides 

guidance on an acceptable method of demonstrating compliance with § 20.1406.17 Both 

documents contain examples of non-safety related components, including radioactive waste 

tanks and piping, condensate storage tanks and piping, buildings sumps, seams and joints. 

In November 2009, the Nuclear Energy Institute (NEI) notified NRC that industry had 

adopted the NEI Buried Piping Industry Initiative (BPII) and the supporting Electric Power 

Research Institute (EPRI) technical basis document related to the minimization of leakage 

from buried piping. 

 

16 http://www.nrc.gov/reading-rm/doc-collections/isg/digital-instrumentation-ctrl.html

17 http://nrc-stp.ornl.gov/special/reg_guide4-21.pdf
C-7

C.2.5. Research and Test Reactors

 

The Office of Nuclear Reactor Regulation (NRR) staff provided the GTF with a brief 

overview of Research and Test Reactor (RTR) operations related to groundwater 

contamination. RTRs share the same regulatory framework discussed in Section C.2.1, with 

the exception of requirements outlined in 10 CFR Part 50, Appendices A and B. GDC 

requirements to control and monitor liquid releases to the environment and quality 

assurance program requirements do not apply to RTRs. Historically, RTRs have promptly 

informed the NRC whenever a leak has been detected. RTRs are also required to provide 

annual reports to the NRC that summarize the nature and amount of radioactive effluents 

released to the environment, including primary coolant leakage. RTR pool leaks are 

identified primarily through pool water inventory balance calculations with the radionuclides 

being released (primarily tritium and sodium-24) identified by means of periodic pool water 

sample analysis. During normal operation, maximum concentrations of radionuclides in the 

primary coolant remain relatively constant and in some cases, these facilities use primary 

coolant radiation monitors to detect any sudden increase in radionuclide concentration of the 

reactor pool water. There are no requirements for groundwater samples of the environment 

surrounding RTR facilities. As part of the RTR license renewal process, NRC staff does 

request that these facilities analyze the radiological impact of any primary coolant leakage to 

the environment, if applicable.

C.2.6. Uranium In-Situ Recovery and Conventional Milling Program

The uranium recovery program is unique in both the extent to which groundwater is 

regulated and the fact that in certain cases, NRC‟s requirements for groundwater restoration 

are more stringent than some individual States. It is also unique because the NRC 

regulatory program regulates hazardous constituents; both radiological and non-radiological 

constituents (e.g. methylated keytones). NRC‟s regulatory authority over groundwater 

contamination related to uranium in-situ recovery or conventional milling is primarily 

described in 10 CFR Part 40, Appendix A. NRC regulations are based on the standards 

established for uranium mill facilities by EPA regulations (40 CFR Part 192) for protecting 

the groundwater at uranium recovery operations. While the requirements of 10 CFR 

Part 40, Appendix A apply principally to conventional mills, they have been applied to in-situ 

uranium recovery facilities via license conditions. 

NRC regulations are based on parallel EPA regulations (40 CFR Part 192, subparts D & E) 

for protecting the groundwater at uranium recovery operations. Compliance with 10 CFR

Part 40, Appendix A does not depend on a dose analysis, but on the concentrations of 

specified hazardous constituents in the groundwater. 10 CFR Part 40, Appendix A requires

a point of compliance beyond which the groundwater quality in the aquifer will not be 

significantly degraded. To determine the point of compliance, a three-dimensional 

hydrologic analysis of groundwater flow at the site is commonly used. Regulatory criteria at 
C-8

the point of compliance are specified in terms of contaminant concentrations to determine if 

performance thresholds are exceeded, which would require corrective action.

These regulations also require pre-operational, operational, and post-operational 

groundwater quality monitoring. Close-in monitoring of regulated activities are used to 

prevent contamination of groundwater resources at greater distances. NRC‟s regulatory 

authority over groundwater contamination related to uranium in-situ recovery or conventional 

milling is primarily described in 10 CFR Part 40, Appendix A. Licensees are required to 

maintain documentation of unplanned releases and spills and evaluate the consequences of 

and report those releases/spills as appropriate. Environmental monitoring of groundwater 

similar to that described for operating reactors is also performed for the plant operations.

The inspection criterion for “In-Situ Leach Facilities,” (IP 89001)18 provides additional focus 

for all areas of groundwater protection. Much of the guidance in IP 89001 is in place to 

ensure that NRC recognizes areas of vulnerability if a leak were to occur, while “Radioactive 

Gases and Liquid Effluent Treatment,” (IP 71124.06)

19 identifies actions to be taken after a

leak is identified. For example, the procedure requires inspection to verify that pipelines 

have been appropriately monitored for breakage and that appropriate corrective actions and 

regulatory notification occurred. Furthermore, IP 71124.06 requires inspections to verify that 

any ongoing excursions (solutions moving beyond the well field) are being monitored and 

cleaned up, that NRC is being appropriately informed, and that the licensee is following its 

cleanup plan.

C.2.7. Fuel Cycle Facilities

Similar to reactor facilities, operating fuel cycle facilities are regulated under 10 CFR 

Parts 70 and 20. Within 60 days after January 1 and July 1 of each year, Part 70 licensees 

are required to submit a report to NRC specifying the quantity of each of the principal 

radionuclides released to unrestricted areas in liquid and gaseous effluents during the 

previous six months of operation (per 10 CFR §70.59). Part 70 licensees are subject to 

various reporting and notification requirements including §§ 70.50 and 70.52. 

With respect to monitoring for on-site contamination:

A pre-operational program that documents background levels of radioactivity may not 

be required. Additionally, specific off-site environmental pathways may not be 

routinely sampled at the site boundary.

For spills, licensees are required (per 10 CFR § 20.1406) to keep records of 

information important to the safe and effective decommissioning of the facility.

 

18 Inspection Procedures can be found at: http://www.nrc.gov/reading-rm/doc-collections/inspmanual/inspection-procedure/

19 Ibid.
C-9

With respect to performance requirements for facilities for which Subpart H applies of Part 

70 (10 CFR § 70.61):

Protection of the environment only involving human interaction is considered.

A dose assessment will be conducted, should a spill occur and if a viable pathway to 

members of public is identified, in order to:

o Provide data on quantities of radioactive material released in liquid and gaseous 

effluents,

o Provide data on measurable levels of radiation and radioactive materials in the 

environment, and

o Identify needed changes in the use of unrestricted areas (e.g., for agricultural 

purposes) to permit modifications in monitoring programs for evaluating doses to 

individuals from the principal pathways of exposure.

Also, just as with reactors, and other operations that are a part of the nuclear fuel cycle, 

pursuant to § 20.2203(a)(4), fuel cycle licensees are subject to the provisions of EPA‟s 

generally applicable standards in 40 CFR Part 190, and are required to submit a report for 

levels of radiation or releases of radioactive material in excess of those standards, or of 

license conditions related to those standards.

C.2.8. NRC‟s Mission and Environmental Protection 

Comments from stakeholders. Throughout the GTF review, the issue of environmental 

protection was raised by stakeholders from many different backgrounds. Some external 

stakeholders were concerned with NRC‟s regulation of radioactive contamination in 

groundwater, while others at public meetings indicated that since the releases to the 

environment were far below regulatory limits, that no increased regulatory actions were 

necessary. 

Because of these opposing views, the regulation of groundwater is challenging. Although 

many of the leaks seen to date have not posed a hazard to human health, they have posed 

significant issues with respect to public confidence in NRC‟s interest in environmental 

protection by some stakeholders. The stimulus for this GTF has been the pressure from 

various stakeholders for explicit demonstrations of protection of the environment, separate 

from demonstrations of protection of individuals. 

Challenges to the portion of the NRC‟s mission statement addressing protection of the 

environment exist with respect to the interplay between State and Federal regulation. Other 

Federal agencies are regulating the licensees in new areas. Several Federal agencies such 

as Federal Aviation Administration, Occupational Safety and Health Administration, 

Environmental Protection Agency, Federal Bureau of Investigation, Department of 

Homeland Security, Federal Energy Regulatory Commission, and others, are increasingly 

more active in pursuing their statutory authority over NRC-licensed material. Some, but not 
C-10

all of this activity, is due to increased security concerns. However, questions continue to be 

raised about NRC‟s ability to adequately protect the environment within the boundaries of 

NRC‟s statutory authority. However, over the years questions have been raised, and 

continue to be raised, about NRC‟s ability to adequately protect the environment within the 

boundaries of NRC‟s statutory authority. Recently, States have become more active in their 

desire to enforce their regulations on NRC licensees. This became most evident in the 2005

Braidwood groundwater event where the State of Illinois pursued enforcement for 

“degradation” of a natural resource. The GTF heard comments from State and local 

legislators who were frustrated with NRC‟s “change of regulatory positions” (i.e. why the 

Braidwood finding had regulatory significance and now other findings are minor) and 

questioned why NRC would not step aside in areas where it is unclear if NRC has statutory 

authority over environmental protection of groundwater, especially when the State has been 

delegated authority for groundwater protection from EPA to impose standards on NRC 

licensees. 

The GTF heard from several State representatives, local officials and the public regarding 

their disagreement and concern with NRC‟s dose-based approach to regulating groundwater 

issues. However, NRC does not generally have authority under the AEA to promulgate 

regulations based solely on environmental protection without a public health and safety 

basis (there are limited exceptions such as regulations regarding uranium mill tailings 

(commonly referred to as 11(e)(2) material)). 

For many years, the EPA and NRC disagreed about the proper approach to setting radiation 

protection standards. Much of the disagreement was attributable to specific restrictions 

placed on each agency by different statutory requirements. On March 16, 1992, NRC and 

EPA signed an MOU to foster cooperation between the two agencies to provide a 

framework to resolve issues, avoid duplication, and focus priorities (57 FR 54127; November

16, 1992). The MOU established that the agencies will actively explore ways to harmonize 

risk goals and will cooperate in developing a mutually agreeable approach to risk 

assessment methodologies for radionuclides. 

The Charter requested the GTF review NRC‟s relationship with the Department of Homeland 

Security (DHS). We believe it is premature to review this relationship at this time. After 

NRC determines any changes to policies or procedures, then a review of this relationship 

would be beneficial. 

C.3. Conclusions 

C.3.1. Conclusion 

The regulations are not prescriptive for maintaining the licensing basis for non-safety related 

systems. Thus, the maintenance of piping and tanks that contain radioactive fluid may not 

be directly addressed by any specific paragraph in 10 CFR Part 50. Because NRC 

regulations in this area are not prescriptive, confusion may be created over enforcement of 
C-11

the requirement for operations to be consistent with design and licensing basis and broad 

requirements of 10 CFR Part 20. NRC could consider and explore the potential to enforce 

compliance with licensing bases when leaks occur. As an alternative, NRC could consider 

conducting rulemaking to clarify existing requirements of 10 CFR Part 50. Additionally, NRC 

could consider issuing a generic communication reminding licensees to maintain their 

operations and designs consistent with their licenses.

C.3.2. Conclusion

NRC‟s regulatory framework with respect to radiological impacts of facility operations vary

for different licensed facilities (e.g., power and research reactors, fuel cycle, in-situ 

recovery). NRC has been regulating groundwater quality using projected dose calculations 

for some licensees and by measurements of groundwater concentration for other licensees. 

Furthermore, some programs have regulated both radiological and non-radiological 

constituents. Some programs require groundwater characterization and ongoing close-in 

monitoring while some do not. Variation in NRC‟s regulatory frameworks among licensed 

facilities can be a source of both internal and external stakeholder confusion. NRC should 

consider ensuring that offices responsible for regulating facilities with these issues 

coordinate and communicate to strive for consistency in NRC response. 

C.3.3. Conclusion 

The final decommissioning rule now before the Commission (SECY-09-0042) is not 

intended to, and would not require immediate remediation, if there exists a potential for 

contamination to migrate to potable aquifers and/or subsurface-water bodies. NRC staff is 

developing a technical basis to address the need for immediate remediation of spills at 

NRC-licensed facilities. This technical basis, in conjunction with stakeholder engagement 

and development of dose limits and criteria, may lead to a decision on the need for a 

rulemaking.

C.4. References

Generic Aging Lessons Learned (GALL) report (NUREG 1801), http://www.nrc.gov/readingrm/doc-collections/nuregs/staff/sr1801/. 

Inspection Procedure 89001, “In-Situ Leach Facilities,” http://www.nrc.gov/reading-rm/doccollections/insp-manual/inspection-procedure/. 

Inspection Procedure 71124.06, “Radioactive Gaseous and Liquid Effluent Treatment,” 

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/. 
C-12

SECY-09-0042, “Proposed Final Rule on Decommissioning Planning” (ADAMS Accession 

No. ML090500143)

NUREG 0800, “Standard Review Plan for the Review of Safety Analysis Reports for Nuclear 

Power Plants: LWR Edition,” http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr0800/.

NEI 07-07. Nuclear Energy Institute, “Industry Ground-Water Protection Initiative – Final 

Guidance Document,” Washington, DC, August 2007 (ADAMS Accession No. 

ML072600295).

NRC 1986. “Groundwater Protection Activities of the Nuclear Regulatory Commission,” 

NUREG-1243, 1986. (ADAMS Accession No. ML 101550111).

ANSI/ANS-2.17-20xx, “Evaluation of Subsurface Radionuclide Transport at Commercial 

Nuclear Power Production Facilities,” Draft Rev. 11 (ADAMS Accession No. ML101310455).

Electric Power Research Institute (EPRI), “Ground-Water Protection Guidelines for Nuclear 

Power Plants,” EPRI Report No. 1016099, Palo Alto, CA, January 2008. (ADAMS Accession 

No. ML080450056).

Advisory Committee on Nuclear Waste and Materials, ACNWMR-0272, November 20, 2007, 

SUBJECT: Proposed Rulemaking to Prevent Legacy Sites1. (ADAMS Accession No. ML.

073170715).
Appendix D

Communications on Groundwater Incidents
(Intentionally left blank)
D-1

Appendix D

Communications on Groundwater Incidents

D.1. Overview

The issue of groundwater contamination at operating nuclear power plants has generated 

considerable attention in the public, States, the media, and Congress. Recognizing this, 

and consistent with its charter, the Groundwater Task Force (GTF) has reviewed the results 

of two recent public meetings, additional public comment, media reports, Congressional 

correspondence issued between 2006 and 2010, and the content of the U.S. Nuclear 

Regulatory Commission (NRC) public website. This appendix summarizes this review and 

provides the GTF‟s observations. It should be noted that the GTF sought specific and 

focused input from only a limited range of stakeholders. Broad surveys of stakeholder 

opinion were not conducted across the licensed community.

D.2. Facts and Observations

D.2.1. Public Meetings

On April 19 and 20, 2010, NRC held two public meetings on particular aspects of 

groundwater contamination and loss of licensed material confinement issues. NRC‟s 

summary of the two meetings was issued on May 12, 2010 (ADAMS Accession No. 

ML101320047).

The first meeting, held in Brattleboro, Vermont, was an open house meeting to discuss 

groundwater contamination at Vermont Yankee, NRC's perspective on potential public 

health and safety impact, regulatory requirements related to tritium, and how the NRC fulfills 

its mission. Key points made by public participants included the following:

Consider or revisit NRC's policy on conducting independent split samples in response to 

ongoing tritium leaks.

Conduct another public meeting when the results of the GTF are complete.

NRC appears to not be responsive to issues raised by the public at these meetings.

The NEI Initiative is too weak. There should be a better way of detecting leaks rather 

than waiting for the water to make its way to a monitoring well. There need to be more 

wells, more frequent sampling, and the samples need to be processed more quickly.

The reactor oversight process (ROP) is flawed. It didn't anticipate leaks at Vermont 

Yankee, despite years of "low risk," high profile events at the plant because it doesn't 

trend issues over a longer period of time. The ROP is not predictive and does not look 

at long-term trends.

NRC relies too much on self-reporting in lieu of direct observation/inspection.
D-2

NRC oversight of tritium released to groundwater is inadequate since this is a public 

health issue.

NRC regulations don't require preventing leaks/accidental discharges and NRC doesn't 

enforce the regulations it has.

NRC should not allow natural attenuation as a remediation alternative.

NRC should have better requirements for detecting or preventing leaks.... better than 

detecting the leak in wells after they've occurred. 

Less than detectable amounts of tritium in the Connecticut River do not mean that the 

release is safe. NRC should understand the exact amount of radioisotopes going into 

the river.

NRC knew about the underground pipes and did nothing. This is a trust and confidence 

issue.

There is a lack of transparency with NRC and there is no trust in NRC or its regulations.

Information [specifically licensee Radiological Control Areas] regarding health and safety 

are withheld from the public.

Trust has been broken. We can't believe you [NRC] when you tell us there's no risk from 

the tritium since you didn't correct the information about underground piping. NRC 

doesn't believe the research that shows all radiation is bad. 

NRC is too closely tied to the nuclear industry.

Profits trump over safety and as a mature industry, the nuclear industry should be better 

run and regulated.

The Vermont State legislature cannot make informed and irreversible decisions because 

Federal preemption20 allows the rules to be changed after the legislature has made their 

decisions. Examples include:

o The legislature was told that high level waste would only be stored onsite for 20 

years, but license extension for the Independent Spent Fuel Storage Installation 

appears likely.

o The legislature was told that the plant site would be returned to a greenfield after 

cessation of operations, but it appears that the plant can be entombed for 60 

years in SAFESTOR.

The April 20 meeting, held at NRC‟s headquarters, was intended to obtain the perspectives 

of external stakeholders regarding NRC‟s regulatory framework (i.e., regulations, guidance, 

inspection, and enforcement) and planned activities involving groundwater contamination at 

nuclear power plants. Key points made by public participants included the following:

Reporting of contamination incidents needs to be required, timely, and public.

Tritium is mildly radioactive; the consequences of additional regulation may be 

counterproductive.

NRC‟s regulatory framework should focus more on environmental protection, rather than 

just public health.

 

20 Preemption is a judicial principle asserting the supremacy of Federal legislation over State legislation 

on a particular issue.
D-3

Monitoring should be more extensive (e.g., more wells), better planned (using 

hydrogeological modeling) and closer to the potential sources of contamination.

Remediation should occur as contamination occurs, not at the end of the facility‟s use.

NRC needs to enforce its regulations.

Voluntary industry initiatives should not be used as a substitute for NRC regulations.

D.2.2. Public Comment

The GTF solicited public comment via an NRC Press Release,21 “NRC Seeks Additional 

Public Input on Groundwater Contamination Issue,” issued on May 6, 2010. The public 

comments received (ADAMS Accession No. ML101320375) are similar to the public 

comments discussed during the two public meetings. 

D.2.3. Media Coverage

Between 2006 and 2010, there has been considerable press coverage of groundwater 

contamination issues at operating nuclear power plants. This coverage, includes a number 

of key messages. Recent reports of tritium leaks at commercial nuclear power plants and a

research reactor have garnered lots of media attention and present the NRC with an 

ongoing communications challenge.

These messages included:

NRC‟s inspection process isn‟t working to ensure prevention or early detection of such 

leaks.

Current monitoring isn‟t sufficient (e.g., more wells are needed).

NRC‟s license renewal process is flawed, since it doesn‟t account for aging equipment 

that has caused leaks.

Independent verification of groundwater contamination levels is needed.

NRC needs to be more transparent and timely in providing information on leaks.

When leaks are found, they need to be stopped and cleanup undertaken promptly.

In an article published in the March 2010 issue of Psychology Today magazine, a risk 

communications specialist at the Harvard School of Public Health, said that when it comes 

to nuclear power and risk “It‟s not about the facts; it‟s our feelings that count.”

From a GTF perspective, it might be useful for NRC to supplement its risk communications 

strategy, one designed to instill greater trust among those who are concerned. In addition to 

using a risk communications model, it might be helpful to incorporate a public health 

discussion and turn to the medical community for assistance with communication. 

 

21 http://www.nrc.gov/reading-rm/doc-collections/news/2010/10-083.html
D-4

D.2.4. Congressional Correspondence

Between 2006 and 2010, NRC also received a number of letters from members of Congress 

on the groundwater contamination issue. This correspondence (compiled in ADAMS 

Accession No. ML101310326) provided a number of important perspectives. These 

perspectives included the following:

NRC needs to enforce its regulations more strongly on energy companies. (Weller „06, 

Olver ‟10)

When there is a problem, both Congress and the public should be warned of any 

possible implications to health, environment. (Feinstein ‟06)

[NRC needs to] ensure that the public is fully aware of both the nature of the problem, 

and the steps that are being taken to resolve it. (Weller „06, Markey „06, 

Hall/Hinchey/Lowey/Engel ‟09)

NRC should be insisting upon access to buried pipes. (Markey/Hall „06, Adler ‟09)

Current inspection processes must be inadequate if licensees can miss the development 

of such large problems. (Markey/Hall „06, Adler „09)

One failure may indicate a systemic failure of the licensee to guarantee public health and 

safety. (Markey/Hall „06, Leahy/Sanders/Welch ‟10)

NRC should perform independent audits or additional inspections wherever problems 

have been discovered. If the licensees can‟t catch the problems before they manifest, 

then they can‟t be trusted to adequately inspect their properties. (Weller „06, 

Leahy/Sanders/Welch „10, Olver „10)

In the light of these issues, NRC should review license renewal applications to ensure 

they do not contain falsified information. (Olver ‟10)

NRC should provide Congress with detailed descriptions of all laws and regulations 

applicable in each problem situation. (Markey ‟06)

NRC needs to assure Congress and the public that disciplinary actions it assigns will be 

reasonable and effective punishment. (Olver ‟10)

D.2.5. NRC‟s Public Website

NRC‟s public website contains prominent links to information related to groundwater 

contamination. High-level “fact sheets,” more detailed “backgrounders,” lists of key 

documents and correspondence, and “frequently asked questions” are provided. The GTF 

notes that NRC‟s public website should be an important mechanism for communicating key 

facts and NRC‟s perspectives on groundwater contamination. The website contains 

considerable information on groundwater contamination. However, some of the linked 

pages are also several years old and contain outdated information.
D-5

D.2.6. Key Messages

The GTF did not attempt to obtain comprehensive stakeholder opinion. The two public 

meetings held on April 19-20, 2010, were largely attended by stakeholders with concerns 

regarding recent groundwater incidents. In addition to these two public meetings, the GTF 

reviewed media reports, public comments and Congressional correspondence 

communications. This input included the following key messages to NRC:

Stakeholders viewed NRC‟s current regulatory framework and its reliance on the 

voluntary industry initiative as inadequate.

Stakeholders valued independent information on contamination incidents.

Stakeholders indicated that NRC‟s licensees should be held appropriately accountable 

for groundwater contamination incidents.

Stakeholders indicated the importance of finding leaks early, ensuring that the source of 

the leaks is quickly identified, and performing prompt cleanup.

Stakeholders indicated that NRC needs to provide prompt information on the nature of 

groundwater contamination incidents and what NRC is doing in response. 

The low risk associated with tritium contamination needs to be placed in the proper 

context and communicated effectively with stakeholders. 

D.3. Conclusions

D.3.1. Conclusion 

Further consideration should be given by staff to more effectively communicate information 

on incidents involving a loss of confinement. As an example, information obtained in OpE 

reviews could be provided on a near-real-time basis to the public via NRC‟s website. The 

importance of particular incidents could be conveyed by including information such as the 

amount of material introduced into the environment, the type and quantity of radioactive 

material involved the safety significance of the release, and the proximity to the site 

boundary. In addition, staff could consider posting the Radiation Exposure Information and 

Reporting System22 NRC public website page devoted to radiation exposure information for 

workers webpage.

D.3.2. Conclusion

At present, the public website information is fragmented and, in some cases, out of date. It 

focuses on tritium and buried pipe, but in general, does not give a clear general message of 

how we protect public health and safety as well as protect the environment. 

 

22 http://www.reirs.com/
D-6

D.3.3. Conclusion 

As gleaned from stakeholder input, dissatisfaction by some stakeholders with NRC‟s 

regulatory approach and incident response has appeared to result in a lack of trust. 

Sometimes NRC communication methods are not timely in relaying information about the 

staff‟s assessment of groundwater incidents. Consideration should be given to using thirdparty validation methods following NRC assessment of groundwater incidents. This could 

include development of a standard protocol for when split samples should be taken and 

cooperative strategic alliances with public health officials and international counterparts. 

D.4. References

“Summary Notes of the NRR Public Meetings on Groundwater Contamination at Nuclear Power 

Plants, April 19 and 20, 2010,” (ADAMS Accession No. ML101320047).

NRC Press Release, “NRC Seeks Additional Public Input on Groundwater Contamination 

Issue,” http://www.nrc.gov/reading-rm/doc-collections/news/2010/10-083.html.

Public Input on Groundwater Contamination Issues (ADAMS Accession No. ML101320375).

David Ropeik, "Nuclear Power and Risk; It's Not About the Facts. It's Our Feelings" March 29, 

2010; http://www.psychologytoday.com/blog/how-risky-is-it-really/201003/nuclear-power-andrisk-it-s-not-about-the-facts-it-s-our-feelings

Groundwater Contamination Congressional Letters (ADAMS Accession No. ML101310326).
Appendix E

Summary of International Input on 

Groundwater Incidents 
(Intentionally left blank)
E-1

Appendix E

Summary of International Input on Groundwater Incidents

E.1. Overview 

In order to obtain information from the international community as to how other Regulatory 

Authorities have responded to groundwater contamination incidents or leaks of underground 

piping (both below and within regulatory limits), the Groundwater Task Force (GTF) 

contacted 13 international representatives to the International Atomic Energy Agency‟s 

(IAEA‟s) International Nuclear and Radiological Event Scale (INES) Advisory Committee to 

request their assistance. Specifically, these country contacts were asked to briefly 

summarize how their regulatory authority and/or licensees (operators) respond to such 

incidents, or if they have experienced such incidents at nuclear power plants in their country, 

how the level of contamination and safety significance was communicated. In addition, 

observations from a visit to a nuclear power plant in Canada which had experienced tritium 

issues have also been added to the country summaries.

In response to this request, nine organizations responded with an overview of their 

experience on the issues. The following section provides a more detailed overview of the 

responses from the following countries: Belgium, Bulgaria, Canada, France, Luxembourg

(European Commission), Netherlands, South Africa, Spain, United Kingdom (Sellafield).

E.2. Facts and Observations: Detailed Country Summaries

E.2.1. Belgium Federal Agency for Nuclear Control (FANC)

The Belgium Federal Agency for Nuclear Control (FANC) has not developed an official 

policy for regulatory response to events involving releases of radioactivity that are measured 

below the regulatory limits, because they are extremely rare in practice. However, FANC 

staff provided several examples of where radiological monitoring results are effectively 

communicated annually as required by the 1957 EURATOM Directive.23 FANC produces a 

yearly report that is published on their website [an English version of this report has also 

been published (FANC 2008)]. Part of the data that is included in these reports comes from 

the nuclear power plant operators, since they are required to maintain a radiological survey 

program of the site and its surroundings. FANC‟s environmental monitoring program 

includes background dosimetry, impact to people and the environment of releases of 

radioactive material (airborne and liquid), as well as regular sampling and measuring of 

drinking water, milk, and food crops.

 

23 The 1957 European Atomic Energy Community (EURATOM) Directive brings together knowledge, 

infrastructure and funding of nuclear energy. It ensures the security of atomic energy supply within the 

framework of a centralised monitoring system for a specialist market for nuclear power.
E-2

In addition, FANC also issues short communications on its website, in a NEWS section, on 

sources or suspicious objects that are found outside nuclear facilities. In one case last year, 

FANC had an event involving trace quantities of uranium in a water well that was used for 

the sanitary installations of a nearby college. FANC investigated this thoroughly (and 

prohibited the use of this water until the environmental report was issued). After a series of 

tests and monitoring, FANC concluded that the uranium was of natural origin with activities 

that were in accordance with the regulations and that these were levels that could be 

expected in that particular water. After the report was final, FANC informed the public 

extensively on the results of their investigation and finding through its website and pressreleases.

In Belgium, the IAEA International Nuclear and Radiological Event Scale24 (INES) has been 

used for the past 20 years for events involving major nuclear facilities such as nuclear power 

plants, fuel fabrication, and research reactors. The use of the scale is done in coordination 

with the operators and the regulatory authority. Most recently, in April 2010, FANC has 

extended the use of this INES convention to other facilities such as accelerators for medical 

isotope production, research and development facilities and large irradiators. FANC 

anticipates that they will use INES to communicate the safety significance of events in the 

future to the public for all events related to ionizing sources (except medical applications). 

FANC also stated that when INES is used for future non-reactor events, it will be used in the 

same way as is currently used now, in close collaboration with the concerned stakeholders 

in order to have an open process of communication of the issues before publishing eventrelated information through INES.

E.2.2. Bulgarian Nuclear Regulatory Agency (BNRA)

The BNRA staff stated that they have not observed any incidents concerning groundwater 

contamination at their nuclear power plants. Releases or leaks are monitored and are well 

below the regulatory limits. Any observations of this type have been several orders of 

magnitude below the regulatory limits and are not reportable. No events of this type have 

been reported via IAEA‟s INES, due to the low safety significance of these types of events.

E.2.3. Canada: Pickering Nuclear Station (PNS) 

The Pickering Nuclear Station (PNS) has eight CANDU (CANada Deuterium Uranium) 

reactors which uses heavy water (deuterium oxide) for moderator and coolant, and natural 

uranium for fuel. Although heavy water is relatively immune to neutron capture, a small 

amount of the deuterium turns into tritium via this process. Tritium is extracted from some 

CANDU plants in operation in Canada, primarily to improve safety in case of heavy-water 

leakage. At PNS, there has been a groundwater monitoring program in place since 1998.

A site-specific risk-based generic screening criterion for tritium in groundwater that is not 

used as drinking water has been developed by Ontario Power Generation (OPG) and 

 

24 See http://www-pub.iaea.org/MTCD/publications/PubDetails.asp?pubId=8120
E-3

approved by the Canadian Nuclear Safety Commission (CNSC) and Ontario Ministry of the 

Environment. The generic screening criterion is 3 ×106 Bq/L (8.1×107pCi/L). Groundwater 

behavior is routinely monitored and water samples are obtained. This is part of a site-wide 

monitoring and modeling program to determine if there are any abnormally high values that 

need to be investigated. The licensee program results are reported in an annual report 

which is submitted for review by the CNSC.

The groundwater investigations at PNS began in 1998 when a higher than normal tritium 

level was detected in the sanitary sewer effluent discharged to the local municipal sewage 

treatment facility (PNS has 8 CANDU reactors, 6 of which are presently operating). The 

tritium source was traced back to a damaged sewer pipe that inadvertently served as a 

conduit for elevated tritium concentration [2.6 × 108 Bq/L (7 ×109pCi/L)] under Units 1 and 2. 

Based on a series of exploration well drilling activities in which boreholes were drilled 

through the concrete floor of the auxiliary turbine building, the center of the tritium plume 

was determined to be in the reactor auxiliary bay corridor. Permanent groundwater wells of 

25 to 30 foot depths adjacent to sumps in the reactor auxiliary bay were installed and are 

routinely sampled. During the 10 years of sampling, trends indicate a decrease of tritium 

concentration. PNS states that there are no indications of adverse, off-site migration of 

tritium at the perimeter of the site in the shallow groundwater flow system.

Since the discovery of the abnormal tritium releases, over 300 wells have been installed in 

the shallow backfill and glacial till deposits surrounding the reactor buildings as well as upand down-gradient of the station. PNS installed many of these monitoring wells to serve as 

early detectors for offsite migration and evaluation of any remediation activities following 

analysis of groundwater/surface-water site behavior. Following the detection of high 

concentrations of tritium, a remediation program was developed. In addition, these wells 

serve to evaluate the efficacy of remediation activities following analysis of groundwater and 

surface-water site behavior. Remediation consists of: (1) pumping eight deep foundation 

drain sumps below the turbine auxiliary building to re-direct tritiated water; and (2) extensive 

monitoring of the contaminant plume that is naturally attenuating due to very slow groundwater movement in the shallow backfill and glacial till units enabling significant time for 

radioactive decay. Tritiated water from the foundation drain sumps is mixed with plant 

cooling water discharge, monitored and released to Lake Ontario at levels far below 

regulatory limits. The remediation and monitoring program have been ongoing since 2000. 

In 2009, NRC staff met with hydrogeologists from OPG to discuss their Radiological 

Environmental Monitoring Program (REMP) in the vicinity of the PNS. In particular, the 

groundwater monitoring program was reviewed to understand the detection and distribution 

of abnormal tritium releases to the subsurface and monitoring trends. Staffs also discussed 

their environmental monitoring and modeling program to better understand how the normal 

and abnormal releases are assessed for potential impacts to public health and the 

environment. Technical discussions focused on the ground-water monitoring program of 

background tritium levels, tritium releases and migration to the accessible environment. 

Information and insights were obtained from the OPG hydrogeologists concerning discovery 
E-4

and identification of multiple abnormal release sources, formulation of a Conceptual Site 

Model and development and implementation of a long-term ground-water monitoring 

program. Details on their ongoing ground-water monitoring program which includes a 

network of shallow and deep wells to measure hydraulic gradients, sample tritium 

concentrations and assess seasonal trends were also discussed.

The CNSC has published a series of research reports on tritium releases in Canada to 

expand the body of knowledge on the subject and to further enhance regulatory oversight of 

tritium-related activities. The CNSC references at the end of this Appendix provide 

information on standards and guidelines for tritium in drinking water, tritium releases from 

CANDU reactors and other nuclear and chemical facilities, characterization of public 

exposure to tritium in garden produce, and information on health effects (including dose 

consequences), dosimetry and radiological protection of tritium.

E.2.4. France: Autorité de Sûreté Nucléaire (ASN)

Information obtained from the staff of the French regulator, ASN, stated that radiological 

contamination of groundwater has been observed at some nuclear power plant sites in 

France. These incidents are not as a result of the normal discharge operations in the 

environment. The tritium found in groundwater in some locations is due to occasional 

incidents of operation leading to spillage of radioactive liquid into the soil, followed by a 

transfer in the ground. Such contamination incidents have been limited to the perimeter of 

the plant and the operator is responsible for reducing and limiting the spread of 

contamination. For example, water accumulated in this space can be regularly pumped out 

by licensees to maintain an efficient hydraulic gradient to ensure the radionuclide retention 

within a limited volume. Furthermore, French nuclear power plants have “geotechnical 

containments,” which are engineered and designed construction areas built at the same 

time as the reactors, which contributes to limiting the spread of groundwater contamination.

ASN Regulatory Requirements for Groundwater Issues. To prevent accidental releases 

resulting from NPP operation, ASN has specific legal and regulatory requirements. For 

example, the French Transparency and Nuclear Security Act (TSN Act) No. 2006-686, June 

13, 2006, identifies three distinct categories of installations present within the perimeter of a 

NPP, according to their use and the nature and scale of the risks they create:

The NPP itself, according to the definition given in Article 28 of the act;

The equipment and installations required for its operation;

The other installations entered on one of the lists specified in Articles L. 214-2 (water) 

and L. 511-2 of the Environment Code.

The installations in the first two categories are required to meet specific rules covering public 

health and safety as well as protection of nature and the environment. The general 

technical regulations that apply to them are defined by orders from the ministers responsible 

for nuclear safety, clarified by ASN general decisions (ministerial Order of December 31, 

1999). Each installation is also subject to individual requirements defined by ASN. The 
E-5

third category of installations remains subject to the provisions implementing the 

Environment Code. ASN is responsible for individual decisions and for regulation as 

specified in these provisions.

This requirement of the TSN Act enables the specific characteristics of nuclear activities to 

be taken into account. The December 31, 1999, Order sets measures designed to prevent 

or, in the event of an accident, to minimize direct or indirect release of toxic, radioactive, 

flammable, corrosive or explosive liquids into the natural environment and the sewers. It led 

to:

Review of the design of storage, loading and unloading zones, with effective leak 

collection areas being required;

Implementing an organization able to deal with accidental liquid spills before they can 

migrate into the natural environment;

Installation of containment tanks in particular for collecting and treating fire-fighting 

water.

Application of these measures by the licensees led to significant progress in preventing 

accidental releases of contaminated effluents. Pipeline routes and conditions were 

checked, as was the condition of retention areas. 

SOCATRI Event, INES Level 1. On July 7, 2008, ASN had an event that occurred in the 

uranium effluent treatment plant (STEU) in the SOCATRI nuclear installation that led to a 

leak of about 20 m3of uranium effluent outside the storage and leak tanks (see two Areva 

press releases at the end of this section). Some of this effluent flowed into the rainwater 

network and then into the la Gaffière river, while some infiltrated the soil of the area 

undergoing construction work.

Following notification of the ASN on 8 July 2008, immediate precautionary measures were 

taken by the licensee, jointly with ASN, to protect the population by the préfets of the Drôme, 

Ardèche and Vaucluse départements. The incident was rated Level 1 on the INES scale.

Following an ASN inspection on 10 July 2008, two decisions were issued requiring that 

emergency measures be taken for securing the installation and surveillance of the 

environment (described in Decision 2008-DC-0104 of 11 July 2008 and Decision 2008-DC0105 of 11 July 2008). Compliance with the requirements of these decisions was 

subsequently checked by an ASN inspection on 12 July 2008.

Extensive environmental surveillance around the site of the incident was taken by the 

licensee and by the French l‟Institut de Radioprotection et de Sûreté Nucléaire (IRSN) 

(French Institute for Radiological Protection and Nuclear Safety), which provided an 

analyses of the surface water, ground water and sediments, enabling the regulatory 

authority to take action, if needed. In the light of the results of these analyses, which were 

presented to the High Committee for Nuclear Transparency and Security, this incident had 

no consequences for the health of the workers and populations. ASN also had an additional 
E-6

series of samples taken by the BRGM (an organization for the establishment of reference for 

resources and risks of soil and subsoil and measurements) on water, sediments and aquatic 

plants by the SUBATECH laboratory of Nantes. The additional samples taken to date show 

no significant degradation of the environment as a result of this event.

After examining a safety analysis report (SAR) transmitted by SOCATRI, ASN authorized 

restart of the new STEU. During the first operating phase, priority was given to draining the 

old storage tanks which caused the incident. In December 2008, the old storage tanks were 

drained and testing of the new effluent treatment plant commenced and is currently ongoing. 

The purpose of the steps currently being taken by the licensee is to mobilize the personnel 

with regard to the necessary conformity of the installation with the order of 31 December 

1999 and the requirements of the discharge license. Finally, the available data concerning 

the causes of this incident led ASN on 31 July 2008 to ask the various BNI licensees for 

initial operating feedback concerning this incident with regard to their own installations, in 

particular the condition of the piping.

Two of the press releases related to this event are shown below. In both cases, the use of 

an INES rating (Level 1) was used to describe the safety significance of the event to the 

public. Per the INES User‟s Manual, ASN has been using this scale to communicate the 

safety significance of events that also attract public interest, including those that may be 

rated at INES Level 0 or 1. 

_____________________________________________________________________________

PRESS RELEASE ON THE SOCATRI INCIDENT 

ACCESSED AT HTTP://WWW.AREVA.COM/EN/NEWS-771/UPDATE-ON-SOCATRI-INCIDENT.HTML

Press release

July 11, 2008 

Confirmation of Level 1 classification

Unscheduled halt in the use of old storage tanks

SOCATRI has acted on the decisions made by the French Nuclear Safety Authority (ASN), and will pursue its recovery 

operations undertaken since the incident occurred. 

In accordance with the ASN's request, it has halted the use of former industrial waste effluent tanks, which, as part of a 

€13 million modernization plan launched in 2005, will be definitively shut down over the coming weeks. SOCATRI is 

now performing its activity on new installations. 

The incident was partly due to the modernization work being carried out on the industrial effluent treatment station, 

which should soon be complete. 

The most recent series of environmental measurements has confirmed the situation is returning to normal. 

SOCATRI invited a number of associations to participate in the sampling taken as part of the reinforced environmental 

monitoring. 
E-7

SOCATRI once more offers its apologies for the inconvenience that the incident and its media consequences have 

caused.

_____________________________________________________________________________

PRESS RELEASE 2: TRICASTIN: SOCATRI REPLIES TO CRIIRAD’S ALLEGATIONS

ACCESSED AT HTTP://WWW.AREVA.COM/EN/NEWS-6664/TRICASTIN-SOCATRI-REPLIES-TO-CRIIRAD-SALLEGATIONS.HTML

Press release

July 16, 2008 

The incident that occurred on July 8 at a SOCATRI treatment station has been the subject of numerous 

communications made public by stakeholders from industry, elected and public authorities, and action groups. 

All of which are legitimate.

SOCATRI, for its part, kept the authorities and media fully abreast of developments throughout last week. The time 

taken on the morning of July 8 between discovering the incident, to understanding the situation and informing the 

authorities, is currently being audited internally. The aim is to establish whether this time was justified, given the time 

taken to complete the analyses and mobilize the teams. Furthermore, SOCATRI invited those experts and associations 

wishing to do so to take part in the sampling and analysis processes carried out as part of the stepped-up 

environmental surveillance on its site.

The debate over the past few days on communications should not overlook the essential fact that the incident has been 

classified INES level 1 out of a maximum 7, and that – according to the institute for radiation protection and nuclear 

safety – the consequences for the people living nearby are negligible. Moreover, WHO standards for drinking water are 

now fully complied with.

SOCATRI regrets that CRIIRAD has decided to mix in other phenomena and deliberately play on people‟s concerns. 

The accusations levied at the group on its managing of “Tricastin hill” are unjustified; this issue, which has nothing to do 

with SOCATRI, has been known for several decades and has been the topic of a recent presentation to a local 

information committee:

From 1964 to 1976, items from diffusion barriers used in the uranium enrichment process were stored to the northeast of the site.

The storage location, a small hill some several meters high, was built on a layer of clay that isolated the stored 

material from the water table.

Since the 1980s, annual pumping operations have been performed systematically to drain and monitor this water 

table. In 1998, these observations were supplemented by an examination by engineering firm Dames & Moore, which 

concluded that the storage hill in no way represented a risk to people‟s health.

This matter was made public in a presentation to a local information committee in 1990, compiled in the first ANDRA 

inventory in 1993, and presented to the Committee for information on major energy equipment (CIGEET) on July 4, 

2008.

In 2006, the CEA agreed to give AREVA ownership of this hill, which also contains military waste that the group did 

not generate.

Results have been presented in various reports (Guillaumont, Dames & Moore).

The installation is monitored using piezometers and is inspected by the French defense security authorities. 
E-8

Results indicate an average uranium concentration that is half the level recommended by the WHO (15 μg/L).

A study in 1998 revealed that the hill was stable and caused no environmental impacts; the recommendation was to leave it 

as is[1].

The French defense security authorities declared to local authorities on July 4 that (on July 10, during an on-site visit): “this 

matter is controlled by the operator and perfectly known by the authorities.”

 

The communications issued by CRIIRAD lack the very clarity they claim to demand. With its exaggerated emotional tone, 

CRIIRAD is once more diverting people‟s attention to its anti-nuclear agenda. Ultimately, public information and the necessary 

debate on energy are what suffer from this method.

[1] The “Guillaumont” public report recommended an impact study be made.

A study by Dames & Moore in 1998 showed there to be no health risk, but recommended piezometric monitoring.

_________________________________________________________________________________

E.2.5. European Commission (EC), Luxembourg, Radiation Protection Section/ Environmental 

Radioactivity

In the European Union there is no specific legislation on nuclear installation groundwater 

issues and, in particular, none on groundwater contamination caused by leaking pipes. 

However, a potential impact by groundwater contamination is covered in the procedures of 

Article 37 of the EURATOM Treaty, an article dealing with plans for installations both in 

normal operation and in foreseeable accidental situations (by determining the possible 

radiation exposure of members of the population in the most effected Member State(s)). For 

these cases, each Member State (country) of the European Union is required to provide the 

EC with such general data relating to any plan for the disposal of radioactive waste to 

determine whether implementing such a plan may result in the radioactive contamination of 

the water, soil or airspace of another Member State. An update of a Recommendation 

defining general data to be supplied to the EC in this context is currently being drafted.

Member States, via specific authorizations to a licensee, may set up a specific monitoring 

program and may require specific actions if deemed needed or useful.

In addition, Article 35 of the EURATOM Treaty stipulates that each Member State shall 

require that their facilities carry out continuous monitoring of radioactivity in the air, water 

and soil to ensure compliance with the basic standards. The EC shall have the right of 

access to such facilities and may also verify their operation and efficiency.

The EC staff also stated that in their view, a leaking pipe could certainly be seen as an 

uncontrolled release, and the groundwater flow could probably reach beyond the boundary 

of the nuclear installation. Thus, within Article 35 verification missions, the EC may (and 

does, if applicable) verifies that facilities (including the sampling and measuring laboratories) 

are conducting monitoring of radioactivity in the air, water and soil. This could include 

looking at specific studies with regard to groundwater flow. 

Article 35 verifications usually comprise the discharge monitoring (gaseous and liquid) from 

nuclear installations (on-site and off-site, by the plant operator and the control of discharges 
E-9

by, or on behalf of, the regulating authority), as well as parts of the country‟s nationwide 

monitoring network for environmental radioactivity.

E.2.6. Netherlands Regulator, KFD MINVROM 

In the Netherlands, staff of the Nuclear Safety Department, within the Ministry for Housing 

Spatial Planning and the Environment (Kernfysische Dienst, Ministerie van Volkshuisvesting, 

Ruimtelijke Ordening en Milieubeheer, or KVD) responded to our inquiry by stating that they 

have no formal policy on “below regulatory limits” for groundwater contamination, although 

they noted that several incidents in the Netherlands have attracted media attention. The 

most notable groundwater contamination incidents were: (1) increased tritium levels; (2) 

cesium contamination along the shores of the river Waal downstream of the now closed 

Dodewaard BWR; (3) higher uranium ground water contamination levels near a waste dump 

/ scrap yard; and (4) a heavy and radioactive metals contamination area near a former tin 

and lead smelter. In this latter case, contaminated soil has been removed and is still being 

stored at the COVRA (Centrale Organisatie Voor Radioactief Afval) Dutch nuclear waste 

processing and storage facility for radioactive waste treatment and storage. In all the above 

cases, INES was not used to rate the irregularity, however KVD has used INES to rate 

incidents below Level 2 if they attract public or media interest. 

KVD recommended that it might be worthwhile to hold an expert meeting on this topic to get 

some international consensus and related experience on the issues.

E.2.7. South African National Nuclear Regulator (NNR)

Dose Assessment and Environmental Monitoring Program. In accordance with NNR 

regulatory requirements, the operator (licensee) has instituted an Annual Authorised 

Discharge Quantity (AADQ) system whereby the maximum release limits from the nuclear 

power plants (NPPs) are derived in order to control effluent discharges (gaseous and liquid) 

to the environment. This ensures that the applicable regulatory public dose constraint and 

dose limits per the NNR regulations are not exceeded. 

The mentioned AADQ system makes provisions for deriving and determining the maximum 

discharge activities in becquerel (Bq) on a nuclide-specific basis based on the activity 

migration of radioactivity in the actual plant originating from the fuel (source) to the point of 

effluent discharge. The Activity Migration “Model” makes provisions for As Low As 

Reasonably Achievable (ALARA) (plant design and operation) and subsequently provides a 

basis for optimized discharge activities. 

In conjunction with the Activity Migration Model, Dose Conversion Factors (DCFs) are 

derived using appropriate computer software modeling (i.e., dilution, pathways, activity 

transport) to determine the Public Dose to the “critical group” prospectively due to the 

derived AADQ`s. Both the above mentioned applications are a prospective assessment and 

control of dose to the critical group. A complementary Environmental Surveillance / 
E-10

Monitoring program is required to be implemented by the NPP to provide verification and 

confirmation that the activity discharges and subsequent doses as per the AADQ Model, are 

met and are ALARA. An Environmental Surveillance Report is issued by the operator on a 

quarterly basis for scrutiny by the Regulator. The report also includes trending analyses. 

Before the start-up of the South African nuclear power plants, a baseline monitoring 

program was instituted and implemented in order to determine the radioactivity in the 

environment (soil, vegetables, feed crop, surface water, borehole water, etc). This 

radioactivity monitoring also included naturally occurring radioactive materials (NORM). 

Groundwater (Boreholes) Monitoring for Radioactivity. NNR has no formal policy or specific 

requirements related to groundwater or borehole contamination. The NNR approves the 

licensing standards of the operator, in this case the Radiation Protection Environmental 

Surveillance Standard (Standard), which, for groundwater, specifically provides for preoperational baseline monitoring as well as routine operational borehole sampling and 

frequencies on-site and off-site, together with reporting. With regards to off-site sampling, 

the regulatory requirements in the Standard focus on those groundwater and boreholes 

samples where the source is tapped for drinking water or irrigation purposes in area where 

the hydraulic gradient or recharge properties are suitable for contamination.

In South Africa, the operator has installed a number of boreholes on site to form part of, inter 

alia, the Baseline Monitoring Program as mentioned above. The intent of sinking boreholes 

is to determine the chemical/corrosion impact and attack on NPP systems, structures and 

components (SSCs) regarding equipment failure. The operator has a permanent contract 

with one of the national universities which is capable of measuring very low levels of 

radionuclides (e.g. tritium). Samples are collected routinely and analyzed for 

contamination/radioactivity and compared to expected southern hemisphere values. The 

results are then compared with pre-operational ground monitoring values.

The off-site boreholes are used to determine the migration of radioactivity to the public 

domain affecting public dose. Monitoring of radioactivity in groundwater (via boreholes) offsite essentially aims to verify the levels of fission products such as 137Cs, corrosion products 

such as 60Co and tritium of which the latter is perceived to be the most important indicator of 

radioactivity/contamination migration in groundwater. All nuclide specific activities detected 

as part of the environmental program are included in quarterly reports. This includes all 

pathways and media including groundwater. The frequency of off-site groundwater 

monitoring is linked to the land use census, and observations of specific locations and levels 

can be formally requested from the operator. 

For the intended new power plant construction at the present nuclear power plant site, a 

borehole study has been performed to identify locations for new borehole positions at and 

around the proposed site. In addition to the 6 existing boreholes at the NPP Site, the 

borehole study recommended an additional 8 new boreholes, some of which will be placed 

between the two plants. 
E-11

The new borehole positions will serve for both baseline and operational environmental 

monitoring similar to the present NPP monitoring strategy. The intent of sinking boreholes is 

to determine the chemical/corrosion impact and attack on NPP SSCs (equipment failure) 

and the migration of radioactivity to the public domain effecting public dose. The eight 

additional boreholes should provide a more comprehensive picture of groundwater in terms 

of radioactivity migration as well as ground water chemistry. 

The new groundwater monitoring strategy will supplement the current groundwater 

monitoring and will serve as a baseline for any additional NPPs that may be built in the 

future at the present site. The current Environmental Surveillance Program will be altered 

accordingly and more emphasis will be placed on the monitoring and detection of 14C.

NNR Position and Response. The NPP operator has a formal system of internal reporting for 

occurrences which provides for reporting in the event of elevated contamination levels (and 

trends) in the environment, including in the groundwater. On-site groundwater is not used 

for drinking or irrigation purposes. This report includes documented data contained in the 

Environmental Surveillance Reports, together with a retrospective dose assessment. 

Detected quantities of radionuclides in groundwater (low levels) are being compared to 

expected and derived reporting levels and ALARA dose targets. In case of elevated levels 

of radioactivity in boreholes on- and off-site, NNR would require the operator to perform an 

investigation in accordance with approved procedures. The origin, impact and 

recommended corrective actions are then submitted to the regulator. Results of all 

environmental analyses, deviations from trends, and doses to the public are reported in both 

operator and regulatory reports. NNR‟s annual report is a public document and is also 

presented in Parliament. Presently observed quantities of radioactivity in groundwater are 

not reported to the international forums.

E.2.8. Spanish Regulator, CSN (Consejo de Seguridad Nuclear) 

CSN requires that their NPPs establish a radiological control program in which NPPs must 

identify radioactive materials in both the liquid and gaseous effluent streams. NPPs are also 

required to provide information about actual releases on a monthly basis to the CSN and to 

establish a sample environmental monitoring program. The aim of this program, amongst 

others, is to verify the adequacy of effluent monitoring and models of transfer of 

radionuclides in the environment so that any inadvertent leaks can be detected. The 

monitoring program for environmental radiation is defined in the Technical Specifications 

and the operation of the program is discussed in detail in the Manual of Dose Calculations. 

CSN also manages an independent national environmental monitoring network called 

REVIRA (Environmental Radiation Monitoring Network) which covers all of Spain and 

provides surveillance of the radiological quantity of the environment in accordance with the 

requirements of 2000/473/EURATOM the European Commission. It consists of a network of 

sampling stations as well as an automated station network for the continuous measurement 
E-12

of effluents. The network provides REVIRA radiological information on the radioactivity in 

air, soil, water (drinking water and marine) and foodstuffs. 

Additionally, each NPP has implemented a new surveillance program for monitoring and 

control of surface water, groundwater and drinking water, and the results are collected and 

analyzed in the annual reports to the CSN. The specific objectives of the groundwater and 

surface water surveillance program are:

Radiochemical water quality (chemical and radiological) of water surface and 

groundwater, in anticipation of potential accidental releases of radioactive wastes, 

including tritium;

Detection of abnormal levels and possible radioactive contamination in the water to 

serve as an early indicator or degradation of structures, systems or components and the 

need for possible mitigative actions (repairs, cleaning, etc.)

Detailed knowledge of the hydro-geological behavior of each NPP site and the possible 

conditions of groundwater to building structures of the plant.

As for the discharge criteria, NPPs are required to meet the operational dose limits of 

100 μSv (10 millirem) per year due to releases during operation. This criterion takes into 

account all type of discharges (gaseous and liquid) and all the possible different types of 

radionuclides, but there are no specific regulatory discharge limits for tritium. There is 

however, a notification criterion for activity concentration in environmental samples, which is 

discussed in the Dose Calculation Manual. This criterion is based on the estimated dose 

(dose constraint) if one person ingested that concentration of water for one full year. If this 

criterion is exceeded, CSN requires the NPP to submit a report including the corrective 

actions to be implemented in order to avoid a potential dose in excess of dose limits to a 

member of the public.

The results obtained from these programs have allowed the CSN to conclude that the 

quality of the environment is acceptable from a radiological point of view and that there is no 

risk for the members of the public around NPPs due to the discharges during operation.

Although the REVIRA program results have shown an increase of tritium levels downstream 

from NPPs, CSN staff stated that these values are not significant and do not represent a 

risk. Regarding communication of these results to the public, the CSN submits an annual 

regulatory report (which includes a summary of environmental releases) to the Spanish 

Parliament, which is also available on their website. 

The official CSN event communication policy is to review and issue an INES rating for all 

reported events from licensees to communicate the safety significance of the event to the 

public. Nationally, events are reviewed and given an INES rating, regardless of the Level

(0-7). CSN staff stated that for Level 0 events, they may also include a short event 

description of the event on their public website, and for Level 1 events and above, an official

press release. In summary, CSN uses INES mainly as a domestic (national) tool for rating 
E-13

all events. In addition, for those events rated at Level 2 or above, CSN also transmits the 

event information internationally to the IAEA, who posts it electronically via its NEWS web 

server. 

E.2.9. United Kingdom: Sellafield Groundwater Monitoring25

Nuclear licensed sites in the United Kingdom (UK) are regulated by the Nuclear Installations 

Inspectorate (NII) which is part of the Health and Safety Executive (HSE)

26 and the 

Environment Agency (EA)27. Under the Nuclear Installations Act 1965 (NIA 1965), NII is 

responsible for regulating operations on a nuclear licensed site. NII does this by granting 

licenses to the operators of the sites and is able to attach conditions to the licenses which it 

considers necessary or desirable in the interests of safety. In addition NII may attach such 

conditions as it sees fit for handling and treatment and disposal of nuclear matter. NII 

regards radioactively contaminated land and emplaced radioactive substances on nuclear 

licensed sites as accumulations of nuclear matter, unless they are, or arise from, authorized 

disposals, which requires licensees to manage it as such. The license conditions require 

that licensees control or contain nuclear matter, to record the amount of radioactive material 

and its location, and justify and demonstrate the arrangements to maintain safety by means 

of a safety case. 

Safety Assessment Principles (SAPs) for managing radioactively contaminated land on 

nuclear facilities are published on the HSE Nuclear Website and have requirements for 

strategy, characterization, control and remediation, record keeping, safety cases and 

redevelopment. They define "radioactively contaminated land" as "land containing 

radioactive contamination that would preclude HSE giving notice in writing that in its opinion 

there ceases/has ceased to be any danger from ionizing radiations on the site, or part of the 

site". The criterion for delicensing (decommissioning) is that the risk of death to an 

individual should not be more than one in a million per year (10-6). The overarching 

requirements of the Health and Safety at Work Act which, in part, reduces risks to "as low as 

reasonably practicable" (ALARP) also apply, but if risks are below one in a million per year, 

licensees are only expected to show that there are no other, inexpensive clean-up activities 

that could be carried out.

With regards to the use of INES, both the Sellafield operator and regulator use this scale to 

communicate the safety significance of events that are reported to the regulator or may 

attract public interest, including those that may be rated at INES Level 0 or 1. 

EA Position Statement and Key Objectives on Contaminated Land and Groundwater. In 

January 2004, the UK‟s EA issued a position statement on contaminated land and 

 

25 See http://www.sellafieldsites.com/land/pages/groundwater_monitoring.html

26 http://www.hse.gov.uk/nuclear/

27 http://www.environment-agency.gov.uk/business/sectors/32517.aspx
E-14

groundwater at Sellafield. This document concluded with listing the EA‟s ten key regulatory 

objectives with respect to contaminated land and groundwater at Sellafield:

1. A Site policy with the goal of early cleanup of ground contamination and groundwater, 

avoiding and minimizing future ground and groundwater contamination spread.

2. The Site should develop groundwater protection principles and a groundwater protection 

strategy consistent with over-arching environmental protection principles and a Site 

integrated waste strategy.

3. Remediation options appraisals for each significant source (carried out according to a 

prioritized program) that includes consideration of the actual and potential risks. Risks 

here include those of significant dose to man, environmental harm, contamination of 

groundwater, or migration of contamination, which would make future remediation more 

difficult or costly. The Agency considers that options should include interim hydraulic 

isolation or groundwater treatment consistent with the site‟s integrated waste 

management strategy and plan.

4. Development of Site targets to: a) reduce the sources and b) to reduce the level of 

groundwater contamination.

5. A validated and verified conceptual model that includes a geological/hydro-geological 

and contaminant model with detailed development of source term understanding.

6. A mature quality assured groundwater monitoring program underpinned by clear 

monitoring strategy objectives.

7. A detailed radiological and environmental risk assessment of the individual and 

combined actual and potential source terms for current and future generations.

8. A detailed knowledge of the rate of leakage of radioactive waste to environmental 

receptors (to groundwater, to the atmosphere by aerial re-suspension and to rivers and 

the sea via groundwater discharge) from individual source terms and hence the rate of 

generation of secondary radioactive waste.

9. A developed communication strategy and plan, which facilitates early, open and 

transparent operator dialogue with appropriate stakeholders regarding these 

contaminated land and groundwater legacies. Recognition of the hazard and 

environmental risk of this legacy within a prioritized site restoration program to 

implement the recognized best options.

10. A public annual report to stakeholders detailing progress with the above.

Objectives of Groundwater Monitoring at Sellafield. The primary objective of the 

groundwater monitoring network at Sellafield is to monitor the groundwater quality and the 

hydrogeological features and processes that control it. There are a number of key 

components of the site that influence the design of the network, including the site 

boundaries, sources of contamination, migration pathways and potential receptors, i.e. the 

River Calder, the River Ehen and the Irish Sea. The groundwater monitoring program 

provides time series data which not only provide early warning of the movement of 

contaminants off-site, but provide data to validate the codes modeling contaminant 

transport. 
E-15

The groundwater monitoring regime was significantly revised in 2006 following the findings 

and recommendations of a 2005 review (050268_02 First Issue)

28 by Westlake Scientific 

Consulting. The Sellafield Ltd. groundwater monitoring program was changed to adopt an 

integrated approach across the whole of the Sellafield site, rather than being restricted to 

the Site perimeter. This resulted in the total number of boreholes included in the site 

monitoring program being increased to more than 150, with many of these boreholes 

containing multi-level monitoring installations. The objectives of the Sellafield Ltd. 

groundwater monitoring program are:

1. To provide data to enable current impact on humans and non-human species from 

contaminants in groundwater to be determined.

2. Monitor changes in the groundwater quality between the points that groundwater enters 

the Sellafield site to the points it leaves the site. 

o Determine the nature, scale and location of activity and other contaminants in the 

groundwater entering the Sellafield site

o Determine the nature, scale and location of activity and other contaminants in the 

groundwater leaving the Sellafield site and/or available to human and non-human 

species.

3. Provide details of the groundwater quality across the Sellafield site. 

o Determine the nature, scale and extent of contamination in the groundwater beneath 

the Sellafield site.

4. Facilitate planning and prioritization of remedial action. 

o Provide data to assess the direction and rate of migration of contamination entering 

the groundwater from contaminated land and other sources.

o Provide data (contaminant concentrations, groundwater flows and directions) with 

which to assess the impact of contaminants in groundwater on actual or potential 

receptors including the sea or adjacent water courses (River Ehen and river Calder).

o Provide data to assess the rate of discharge to groundwater from contaminated land.

o Provide data to assess the rate of generation of waste.

5. Provide information to improve the conceptual hydrogeological model of the Sellafield 

site. 

o Monitor groundwater heads and hydraulic gradients across the site and provide 

information with which to improve the groundwater conceptual model.

o Provide data to contribute to any routine water balance calculations for the site.

In addition to the above objectives, the program has also been expanded to: 

6. Provide information to identify the role of colloids, particles and dissolved salts in the 

migration of contaminants within groundwater.

The sampling methodologies and the analytical limits of detection have also been changed 

following the reviews. These changes have resulted in a number of boreholes now having 

detectable concentrations of radionuclides within the groundwater. 

 

28 http://www.sellafieldsites.com/land/documents/050268_02%20First%20Issue.pdf
E-16

An example of this is from the analysis of total alpha in groundwater which had a reduction 

in the limit of detection from 200 Bq/m3to 30 Bq/m3(5400 pCi/m3to 810 pCi/m3). This 

reduction has resulted in a number of locations where activity has been detected between 

the old and current detection limits. To further investigate the sources of the elevated Alpha 

activity changes have been made to the frequency of sampling and the analytical suite. 

Each year the schedule for groundwater monitoring is developed in conjunction with the 

Environment Agency. Part of this process includes the review of the previous year data and 

the development of the program in line with the monitoring objectives. This annual review is 

submitted to the Environment Agency at the end of September.

29

Leak Detection Program. The Contaminated Land Project Leak Management and Detection 

Program was issued in 2006 and updated in 2008. The program is designed to minimize 

the impact of ongoing operations and structures on the subsurface environment and 

characterize and minimize further additions to the contaminated land store.

The program includes the following actions:

Prioritize plants with respect to potential risk of leaks to land in order to focus 

Contaminated Land Project attention and resources upon the most important plants.

Establish interfaces, regular communications, information transfer, and agreement of 

responsibilities with the prioritized plants.

Recognize the importance of leaking drains with respect to transmitting subsurface 

contamination; establish interfaces, regular communications, information transfer, and 

agreement of responsibilities with the Plant Services Utilities – Civil Group and with the 

Low Active Effluent Management Group.

Use a continuing program of audits and surveillances on plants and drain systems to 

assess compliance with relevant regulations pertaining to leaks to land, adequacy of 

leak to land management systems, and plant and drainage system vulnerabilities with 

respect to potential risks of leaks to land.

Integrate the applicable portions of the Sellafield Contaminated Land and Groundwater 

Management Project (SCL&GMP) into the leak management and detection program.

Transmit results of leak detection technology identification to plants and drain groups.

Consult with plants on the placement and rehabilitation of boreholes in the Separation 

Area relative to optimizing locations with respect to possible future leaks.

Use the results from the trench investigation as a model for processes for handling 

future leaks from plants or drains.

Establish the Contaminated Land Project in a key role as an integrator in the exchange 

and dissemination of information and knowledge relative to leaks to ground so that all 

involved parties are operating from a common knowledge basis.

Perform routine modeling and visualization of leaks to assess impact on the existing 

subsurface inventory.

 

29 http://www.sellafieldsites.com/land/documents/TECH000221-Rev-2-Annual-Report-09.pdf
E-17

The contaminated land team currently manages an annual audit program to monitor the leak 

detection measure in high risk plants. By the end of 2009, this program had run for five 

years and the plan is to continue running it in the future. 

External Stakeholders. As the focus of Sellafield's activities switches from an operating site 

to greater emphasis on the decommissioning and clean-up of the site, the possible end-uses 

and end-state of the site will come under greater scrutiny. Sellafield believes that their 

stakeholders need to have the necessary information on the merits and constraints of the 

various strategic and technical options available and they are able to provide informed views 

on the long term remediation of the site. Accordingly, a stakeholder plan has been prepared 

and will be updated as required to reflect any changes in stakeholder needs. 

Sellafield Ltd. believes it is important to ensure that stakeholders have information on 

current contaminated ground and groundwater management and input into future decisions 

on the management and remediation of the site. A stakeholder plan has been formulated 

taking into account company guidance and policy as well as SAFEGROUNDS30 guidance.

E.2.10. International Developments in Protection of the Environment

The international community has for some years been working to develop and benchmark 

modeling and assessment approaches for protection of the environment. These have 

centered upon developing and understanding radionuclide transport through environmental 

pathways, and calculations of doses to various receptor animals and plants in the 

environment. The stimulus for these efforts has been the pressure from various 

stakeholders for explicit demonstrations of protection of the environment, separate from 

demonstrations of protection for humans. 

There are three key issues that continue to be examined internationally. First, is the 

question of what will be considered significant impacts in an animal or plant species. Unlike 

with protection of humans, protection of animals and plants in the environment is not 

necessarily the protection of each individual plant or animal, but rather considerations of 

populations, reproductive viability, and continued viability of the species. The second 

question is the levels of dose that are necessary to cause the effect of interest. There are 

significant differences between the radiosensitivity of different animals and plants. The third 

issue then becomes the modeling and dosimetry necessary to take the calculation of a 

radionuclide in a particular environment, and particular plant or animal, and calculate the 

dose from the presence of that radionuclide. 

In addition to the work of ICRP, work continues at the International Atomic Energy Agency 

(IAEA), updating safety guidance on environmental assessment, and considering for the first 

time, in the draft Basic Safety Standards, explicit requirements for the conduct and use of 

environmental assessments. Similar work is being performed by the European Commission 

which is considering specific requirements for environmental protection, and for reference 

 

30 http://www.safegrounds.com/
E-18

animals and plants, in a revision of the European Directive. Finally, a number of 

coordinated efforts have been undertaken to benchmark various computer codes for 

assessment of the movement of radionuclides and projected doses. 

E.3. Conclusions 

E.3.1. Conclusion

International regulatory authorities effectively communicate radiological monitoring results 

annually in a public report to their parliament or Congress. While the majority of the 

countries contacted did not have an official policy for responding to events involving reports 

for releases of radioactivity below the regulatory limits for members of the public, all 

countries did have licensee (operator) reporting requirements for periodic environmental 

effluent monitoring as well as a more formal process for the regulatory authority to effectively 

communicate radiological monitoring results annually in a report to their parliament or 

Congress (and also made available to the public on their website). The GTF notes that 

NRC previously issued annual NUREG environmental reports between 1972 and 1993. 

However, in recent discussions with staff, it appears that as a result of Commission SRM for 

SECY-06-0212, a new type of annual environmental report is currently under development, 

which is anticipated to be published by staff in late 2010. In light of the increased public and 

Congressional interest on tritium issues, as well as to complete the response to the SRM for 

SECY-06-0212, NRC could consider re-issuing an annual environmental effluent report that 

is voluntarily transmitted to Congress and made available to the public on the NRC website. 

E.3.2. Conclusion 

The GTF notes that more than 65 countries (including the U.S.) use IAEA‟s International 

Nuclear and Radiological Event Scale (INES) to explain the safety significance of events 

associated with various sources of radiation. Since 1993 NRC has participated in INES by 

transmitting event information for events rated at Level 2 and above to IAEA (SECY-01-

0071; RIS 2002-01; IN 2009-27). The IAEA‟s INES User Manual states that “all countries 

are strongly encouraged to communicate events (within 24 hours if possible) for events 

rated at Level 2 or above, or events attracting international31 public interest” (IAEA 2008). 

Because of the high level of public interest in events involving the discovery of radioactive 

materials in areas not expected by design, NRC staff could consider the use of INES for 

communicating the non-safety significance of events (at Level 0 or 1) that attract domestic 

or international public interest. Helping the public better understand the safety significance 

of events that attract significant public interest aids in independent validation of the 

regulatory authority‟s assessment and helps to strengthen public trust. 

 

31 The INES Advisory Committee will make a determination at its next meeting in June 2010 if the term 

“international” in the 2008 Users Manual should also clarified to state: “national or international public 

interest,” which would recommend communicating events below Level 2 if they attract significant public 

interest.
E-19

E.3.3. Conclusion 

Timely exchange of information and cooperative efforts on NPP operational events would be 

of great value in assisting regulatory authorities worldwide to deal with emergent issues, 

such as the recent buried piping tritium leaks that are far below regulatory limits.

Several international regulators commented on the need to cooperatively investigate 

corrosion or other incidents that have caused leaks in buried pipes and related systems at 

NPPs. NRC should consider initiating dialogue with international regulators to discuss, via 

an international expert meeting, collaborative approaches for effective resolution of these 

situations. This would assist in strengthening NRC‟s independent validation of the safety 

significance of such incidents and proactively work towards international consensus in this 

area. NRC could work through the OECD‟s Nuclear Energy Agency (NEA) and the IAEA‟s 

International Nuclear Safety Group (INSAG) in order to collect advice and generate 

guidance to address nuclear safety issues concerning buried piping and develop a collective 

strategy to communicate their safety significance.

E.3.4. Conclusion

The international community has been working to develop and benchmark modeling and 

assessment approaches for protection of the environment. NRC should consider 

conducting cooperative efforts with international regulators to focus on developing and 

understanding radionuclide transport through environmental pathways.

E.4. References

CNSC 2008. Canadian Nuclear Safety Commission, “Standards and Guidelines for Tritium in 

Drinking Water – Part of the Tritium Studies Project,” Catalogue number: INFO-0766, Ottawa, 

Canada, January 2008.

CNSC 2009. Canadian Nuclear Safety Commission, “Tritium Releases and Dose 

Consequences in Canada in 2006 – Part of the Tritium Studies Project,” Catalogue number:

INFO-0793, Ottawa, Canada, December 2009.

CNSC 2010a. Canadian Nuclear Safety Commission, “Tritium Activity in Garden Produce from 

Pembroke in 2007 and Dose to the Public – Part of the Tritium Studies Project,” Catalogue 

number: INFO-0798, Ottawa, Canada, April 2010.

CNSC 2010b. Canadian Nuclear Safety Commission, “Health Effects, Dosimetry and 

Radiological Protection of Tritium – Part of the Tritium Studies Project,” Catalogue number: 

INFO-0799, Ottawa, Canada, April 2010.
E-20

CNSC 2010c. “Evaluation of Facilities Handling Tritium,” Canadian Nuclear Safety Commission, 

Catalogue No. INFO-0796, Ottawa, Canada, February 2010. Accessed at 

http://www.nuclearsafety.gc.ca/eng/readingroom/healthstudies/tritium/Evaluation_of_facilities_h

andling_tritium_info-0796_e.pdf

FANC 2009. Federal Agency for Nuclear Control, “Radiological Monitoring in Belgium, 

Surveillance of the Territory and Natural Radiation Service,” Summary Report 2008. Brussels, 

Belgium. November 2009.

IN 2009-27. NRC Information Notice 2009-27, “Revised International Nuclear and Radiological 

Event Scale User‟s Manual,” November 13, 2009 (ADAMS Accession No. ML092510055).

IAEA 2008. “The International Nuclear and Radiological Event Scale User‟s Manual.” Vienna, 

Austria. 2008 Edition. Accessed April 27, 2010, at http://wwwpub.iaea.org/MTCD/publications/PubDetails.asp?pubId=8120. 

NIA 1965. Nuclear Installations Act of 1965, as amended. Accessed at 

http://www.hse.gov.uk/nuclear/notesforapplicants.pdf (page 5);

RIS 2002-01. Regulatory Information Summary 2002-01, “Changes to NRC Participation in the 

International Nuclear Event Scale,” January 14, 2002 (ADAMS Accession No. ML013200502).

SECY-01-0071. Commission Notation Vote Paper, “Expanded NRC Participation in the Use of 

the International Nuclear Event Scale,” August 25, 2001. Accessed at 

http://www.nrc.gov/reading-rm/doc-collections/commission/cvr/2001/2001-0071vtr.html.

SECY-06-0212. Staff Requirements – Preparation of Annual Reports on Radioactive Materials 

released in Gaseous and Liquid Effluents and in Solid Wastes Shipped for Disposal by 

Commercial Nuclear Power Plants. November 5, 2006. Accessed at 

http://www.nrc.gov/reading-rm/doc-collections/commission/srm/2006/2006-0212srm.html
Appendix F

Acronyms
(Intentionally left blank)
F-1

Appendix F

Acronyms

AADQ Annual Authorised Discharge Quantity

ADAMS Agency-Wide Documents Access and Management System

AFW Auxiliary Feedwater

AIT Augmented Inspection Team

ALARA As Low As Reasonably Achievable

ALARP As Low As Reasonably Practicable

AMPs Aging Management Programs

ANS American National Standard

AOG Advanced Off Gas System

ASME American Society of Mechanical Engineers

ASN Autorité de Sûreté Nucléaire (French Regulator)

BNRA Bulgarian Nuclear Regulatory Agency

BPII Buried Piping Industry Initiative

CAP Corrective Action Program

CNSC Canadian Nuclear Safety Commission

COVRA Centrale Organisatie Voor Radioactief Afval (Dutch Reprocessing Facilty)

CSN Consejo de Seguridad Nuclear (Spanish Nuclear Regulator)

CST Condensate Storage Tank

DCF Dose Conversion Factors

EA Environment Agency (United Kingdom)

EC European Commission

FANC Federal Agency for Nuclear Control (Belgium)

GALL Generic Aging Lessons Learned

GPI Groundwater Protection Initiative

GTF Groundwater Task Force

HP Health Physics

IAEA International Atomic Energy Agency

IIT Incident Investigation Team

IMC Inspection Manual Chapter

INES International Nuclear and Radiological Event Scale

IP Indian Point

IRSN l‟Institut de Radioprotection et de Sûreté Nucléaire (France)

ISR In-Situ Recovery

KVD Kernfysische Dienst, Ministerie van Volkshuisvesting, Ruimtelijke Ordening 

en Milieubeheer, (Department of Nuclear Safety, Security, Safeguards and 

Radiation Protection, Netherlands)
F-2

LRRLLTF Liquid Radioactive Release Lessons Learned Task Force

LTMP Long Term Monitoring Program

LTP License Termination Plan

MD Management Directive

NEI Nuclear Energy Institute

NII Nuclear Installations Inspectorate

NNR National Nuclear Regulator (South Africa)

NPP Nuclear Power Plant

NRC Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulation

OCA Office of Congressional Affairs

OEDO Office of the Executive Director of Operations

OPA Office of Public Affairs

OPG Ontario Power Generation 

PI Performance Indicator

PNS Pickering Nuclear Station (Canada)

REMPS Radiological Environmental Monitoring Programs

REVIRA Environmental Radiation Monitoring Network

RG Regulatory Guide

ROP Reactor Oversight Process

SAP Safety Assessment Principles

SAR Safety Analysis Report

SCL&GMP Sellafield Contaminated Land and Groundwater Management Project

SDP Significance Determination Process

SDSP Storm Drain Stabilization Pond

SFP Spent Fuel Pool

SIT Special Inspection Term

SRP Standard Review Plan

SSCs Systems, Structures and Components

STEU SOCATRI Uranium Effluent Treatment plant (France)

TS Technical Specifications

TSN Act French Transparency and Nuclear Security Act

VY Vermont Yankee