Liquid Release Task Force Recommendations Implementation Status 

as of July 10, 2009 

LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

(1) Completed The staff should review and develop a position 

to address using lake water that contains licensed radioactive material for other site purposes, such as for use in the fire protection system. 

NRC has established a position on using lake radioactive materials for other site purposes. “Contamination of Nonradioactive System and Unmonitored, Uncontrolled Release of Radioa

provides guidance on use of contaminated sysevaluations. In addition, NRC has issued RegSummary (RIS) RIS-08-33 that describes the the re-use of previously discharged radioactive 

(2) Completed The NRC should develop guidance to the 

industry for detecting, evaluating, and monitoring releases from operating facilities via unmonitored pathways. 

Updated regulatory guidance has been provide(RG) 1.21, “Measuring, Evaluating, and ReporMaterial in Liquid and Gaseous Effluents and SRegulatory Guide 4.1, “Environmental MonitorPlants.” In addition, technical guidance has bemonitoring and evaluating leaks and spills in N“Integrated Ground-Water Monitoring Strategy Facilities and Sites: Logic, Strategic Approach NUREG/CR-6805, “A Comprehensive Strategy Modeling and Uncertainty Analysis for Nuclear 

(3) Completed The NRC should revise the radiological 

effluent and environmental monitoring program requirements and guidance to be consistent with current industry standards and commercially available radiation detection technology. 

Updated regulatory guidance has been provide4.1 on the radiological effluent and environmeprograms. 

(4) Completed Guidance for the REMP should be revised to 

limit the amount of flexibility in its conduct. Guidance is needed on when the program, based on data or environmental conditions, should be expanded. 

Updated regulatory guidance has been providelimits the amount of flexibility in the conduct of monitoring program, and on expanding the prooperational occurrences or ground water mon

(5) Completed Develop guidance to define the magnitude of 

the spills and leaks that need to be 

Updated regulatory guidance has been provideinclude a definition of significant contamination 
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

documented by the licensee under 10 CFR 50.75(g). Also, clearly define “significant contamination.” Summaries of spills and leaks documented under 10 CFR 50.75(g) should be included in the annual radioactive effluent release report. 

documented in the nuclear decommissioning r50.75(g). The updated regulatory guide also preporting summaries of leaks and spills in the effluent release reports (available on the NRC 

(6) Completed The staff should provide guidance to the 

industry which expands the use of historical information and data in their 50.75(g) files to the operational phase of the plant. The data provides good information on current and future potential radiological hazards that are important during routine operation, and can aid in planning survey and monitoring programs. 

Updated regulatory guidance has been provideuse of historical information and 10 CFR 50.75environmental program review. 

(7) Completed The NRC should evaluate the need to enact 

regulations and/or provide guidance to address remediation. 

Updated regulatory guidance has been provideevaluating and implementing remediation of on

(8) Completed The NRC should require adequate assurance 

that leaks and spills will be detected before radionuclides migrate offsite via an unmonitored pathway. 

Staff have revised and issued Regulatory GuidEvaluating and Reporting Radioactive MateriaGaseous Effluents and Solid Waste." This RG guidance for monitoring abnormal discharges migrate offsite via an unmonitored pathway. Tupdated guidance on reporting abnormal releaenvirons from systems, structures, and compoguidance on reporting abnormal discharges to Additionally, all licensees must comply with the to monitor and report effluents that are dischaabnormal discharges that may migrate offsite. For new reactor license applicants, NRC is revusing the guidance of NEI 08-08, "Generic FSAGuidance for Life Cycle Minimization of Conta3.2.2 of this guidance requires that "The applicon-site ground water monitoring program to en
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

of inadvertent radiological releases to ground wNRC has proposed rulemaking for existing rea"Decommissioning Planning" (ML090490280) ground water monitoring and detection of leakmigration offsite. The Commission is currently relative merits of the safety benefit and the costhis proposed rule. 

(9) Completed To support one possible option for 

recommendation (6), regulatory guidance should be developed to define acceptable methods to survey and monitor onsite groundwater and sub-surface soil for radionuclides. 

Updated regulatory guidance has been provideaddition, technical guidance has been provideevaluating leaks and spills in NUREG/CR-694Water Monitoring Strategy for NRC-Licensed FLogic, Strategic Approach and Discussion,” an“A Comprehensive Strategy of Hydrogeologic Uncertainty Analysis for Nuclear Facilities and 

(10) Completed The NRC should revise radioactive effluent 

release program guidance to upgrade the capability and scope of the in-plant radiation monitoring system, to include additional monitoring locations and the capability to detect lower risk radionuclides (i.e., low energy gamma, weak beta emitters, and alpha particles). 

RG 1.21 was revised and includes provisions fcapability for various release points (including radionuclides (including low energy gamma, walpha radioactivity). Pre-release sampling and for batch releases. For continuous releases, gfor continuous monitoring, periodic sampling asampling with both on-site and off-sample anadetection methods and capabilities for low enebeta emitters, and alpha particles. 

(11) Completed Determine whether there is a need for 

improved design, materials, and/or quality assurance requirements for SSCs that contain radioactive liquids for new reactors. 

A staff review has concluded that the current rCFR 20.1406 adequately address this recommreactors. Draft guide DG-4012 “Minimization oradioactive Waste Generation – Life Cycle Plaissued to provide guidance on how to meet thi

(12) Completed The staff should consider whether further 

action is warranted to enhance the performance of SFP telltale drains at nuclear power plants. 

The staff reviewed the operating experience, rand guidance related to SFP liner leakage collBased on the operating experience, the staff cexisting regulatory requirements are adequate

(13) Completed The staff should verify that there has been an 

evaluation of the effects of long term SFP 

NRC staff have verified that plant licensees whSFP leakage have assessed and evaluated th
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

leakage (boric acid) on safety significant structures (concrete, rebar), or the staff should perform such an evaluation. 

impact, both short term and long term, on strureinforced concrete SFP structure and determlicensing basis remains satisfied and will contisatisfied. 

(14) Completed The staff should assess whether the 

maintenance rule adequately covers SSCs that contain radioactive liquids. 

The scope of 10 CFR 50.65, the Maintenance in paragraph 50.65(b)(1), includes all safety-related SSCs relied upon to during and following design-basis events to ensure the integrity of tpressure boundary, the capability to shut down the reactor and maintacondition, or the capability to prevent or mitigate the consequences of acresult in potential offsite exposure comparable to the guidelines in 10 CCFR 50.67(b)(2), or 10 CFR 100.11 as applicable. Paragraph 50.65(b)(2) includes in the scope osafety-related SSCs (i) that are relied upon to mitigate accidents or transieplant emergency operating procedures; or (ii) whose failure could prevent from fulfilling their safety-related functions; or (iii) whose failure cscram or actuation of a safety-related system. Therefore, the MR doeSSCs with functions involving containing or preuncontrolled release of radioactive liquids undconditions be included within the scope of licerule programs; nor was it intended to do so. 

(15) Completed The staff should verify that the license renewal 

process reviews degradation of systems containing radioactive material such as those discussed in this report. 

These systems are not within the scope of the renewal regulations. The license renewal revievaluation on SSCs most important to safety. systems discussed in the LLTF report do not m
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

criteria that are contained in 10 CFR 54.4. Imprequirement on license renewal applicants to imanagement of radioactive waste systems woto 10 CFR Part 54 and would have a major imrenewal program that is not warranted based o

(16) Completed The NRC staff should open a dialogue with 

the States regarding the application of the NPDES system to discharges of radioactive materials to promote a common understanding of how the associated legal requirements in this area are addressed. 

Several state-issued NPDES permits were revthe permits did not regulate the discharge of raThe staff has recommended consideration of a States to promote a common understanding oprotection regulations, aquifer classification syimplementation procedures related to nuclear operations. 

(17) Completed Inspection guidance should be developed to 

review onsite contamination events including events involving contamination of ground water. 

The staff issued inspection guidance in the forInstruction TI 2515/173 to verify compliance wvoluntary initiative on ground water contaminacompletion of this Temporary Instruction, the Non-going review of ground water contaminatioinspection program. 

(18) Completed The inspection program should be revised to 

provide guidance to evaluate effluent pathways such that new pathways are identified and placed in the ODCM as applicable. In addition, guidance should be included as to when a new release path becomes “permanent” for purposes of inclusion in the ODCM and routine annual reporting. 

The staff has revised Inspection Procedure 71recommendation. The staff issued additional the form of a Temporary Instruction TI 2515/17with the NEI 07-07 voluntary initiative on grounevents. Following completion of this Temporawill incorporate on-going review of ground watevents back into its routine inspection program

(19) Completed Limited, defined documentation of significant 

radioactive releases to the environment should be allowed in inspection reports for those cases where such events would not normally be documented under the present guidance. 

The staff has revised Inspection Manual Chaplimited, defined documentation of the review ounplanned radioactive discharges (e.g., leaks in the inspection reports. 

(20) Completed The staff should revise the Public Radiation The proposed revision to the Public Radiation 
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

SDP to better address the range of events that can occur, including unplanned, unmonitored releases or spills. 

approved by the Commission (SECY-07-0112revised the Public Radiation Safety SDP to inc

(21) Completed 10 CFR 20.1406 requires in part that 

applicants for licenses shall describe in their application how facility design and procedures for operation will minimize contamination of the environment. The NRC should develop regulatory guidance to describe acceptable options to meet this requirement. 

The staff has issued a new Regulatory Guide 4guidance on meeting the requirements in 10 Creactor license applicants, NRC is reviewing aguidance of NEI 08-08, "Generic FSAR TemplCycle Minimization of Contamination." 

(22) Completed NRC should evaluate whether the present 

decommissioning funding requirements adequately address the potential need to remediate soil and groundwater contamination, particularly if the licensee has no monitoring program during plant operations to identify such contamination. 

In SECY-06-0065, dated May 17, 2006, the Costaff to review the agency’s decommissioning As directed by the Commission for year 2011, formula used in calculating decommissioning fand adjust it, if necessary. To help establish a this opportunity to assess the impact of the remunmonitored, contaminated soil and groundwadecommissioning costs of Connecticut Yankee (CY), Maine Yankee Atomic Power Company Nuclear Power Station (Rowe). The staff has econcluded that present decommissioning fundadequate with respect to the potential need to groundwater contamination. The staff based itworst case decommissioning scenario for whicexperience. For that case, the licensee had suthe cost of $850 million to decommission Connincluding the additional costs resulting from unMoreover, Connecticut Yankee was decommisstringent State release criterion, which likely inbeyond what it would have been under NRC c

(23) In-progress The NRC should consider the development of 

guidance on the evaluation of radionuclide transport in groundwater. American National Standard (ANSI/ANS) 2.17 addresses this issue and is being extensively updated. 

The staff participated in the ANS 2.17 writing ccompleted a draft revision to this ANSI/ANS instaff hasl included this ANSI standard as a refto Regulatory Guide 1.21. 
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LLTF Recommendation 

Status Task Force Recommendation Summary of Actions 

(24) Completed The NRC’s guidelines for “immediate 

notification” public communications should continue to be based on public health and safety considerations. To support the NRC’s openness goals, the NRC staff should consider whether to notify the public of radioactive releases to the environment that are not significant from a radiation dose perspective, but that could be of general public interest nonetheless. 

10 CFR 50.72 requires licensees to report any news release is planned, and additional guidanthis requirement relative to leaks and spills of contained in RG 1.21 (Revision 2). AdditionallInstitute (NEI) issued NEI 07-07, “Industry GroInitiative – Final Guidance Document,” August industry initiative that puts in place a process tnotifications to local and state and federal ageimplements inspections under Temporary Instmonitor the implementation and effectiveness initiative. 

(25) Completed NRC staff should review NUREG/BR-0308, 

“Effective Risk Communication,” and other training tools to ensure an event’s risk is provided with appropriate context. 

The staff has reviewed the guidance and trainstakeholder communication on events and conguidance already exists. Regulatory Guide 1.2and includes guidance on using NUREG/BR-0communication when notifying local authorities 

(26) Completed Nuclear power plant licensees should consider 

entering into agreements with local and state agencies to voluntarily report preliminary information on significant radioactive liquid releases that do not otherwise trigger reporting requirements. The present industry ground water protection initiative may address this. 

The Nuclear Energy Institute (NEI) issued NEI Ground Water Protection Initiative – Final GuidAugust 2007. This initiative establishes a comwhereby licensees establish a working relationinformation directly to local and state agencies