POLICY ISSUE 

(Information) 

February 9, 2011 SECY-11-0019

FOR: The Commissioners 

FROM: R. W. Borchardt 

Executive Director for Operations 

SUBJECT: SENIOR MANAGEMENT REVIEW OF OVERALL REGULATORY APPROACH 

TO GROUNDWATER PROTECTION 

PURPOSE: 

This paper provides the outcome of the U.S. Nuclear Regulatory Commission (NRC) senior 

management review of two of the four themes described in the “Groundwater Task Force 

Report,” issued June 2010 (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML101680435). Specifically, this paper describes the regulatory 

approach for addressing groundwater protection and addresses the themes of reassessing the 

regulatory framework and maintaining barriers as designed to confine licensed material. A 

separate memorandum to the Chairman describes the staff’s initiatives to create a more reliable 

and consistent NRC response and to strengthen trust. 

BACKGROUND: 

On March 5, 2010, the Executive Director for Operations (EDO) established the Groundwater 

Contamination Task Force (GTF) to evaluate the completeness of NRC actions to address 

recent incidents of radioactive contamination of groundwater and soils at civilian nuclear power 

plants. As described in the charter (ADAMS Accession No. ML100640188), the purpose of the 

GTF was to determine whether the actions the NRC has taken, or plans to take, in response to 

recent incidents and to the recommendations made in the “Liquid Radioactive Release Lessons 

Learned Task Force (LLTF) Final Report,” issued September 2006 (ADAMS Accession 

No. ML062650312) should be augmented. 

CONTACTS: A. Louise Lund, NRR/DLR 

 301-415-3248 

 Margie A. Kotzalas, OEDO/TBPM 

 301-415-1727
The Commissioners - 2 - 

In 2006, the LLTF reviewed the industry experience with unplanned and unmonitored releases 

of radioactive liquids into the environment, any associated public health impacts, NRC 

regulatory framework, NRC inspection and enforcement programs, industry reporting 

requirements, international perspectives, and communications with public stakeholders. The 

LLTF made 26 recommendations in a final report dated September 1, 2006, (ADAMS Accession 

No. ML062650312). 

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

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

contains four major themes that provide focus for its conclusions: 

Theme 1—Reassess the 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 

The recommendations from the GTF report that contain potential policy issues or discuss 

associated activities that could impact the regulatory framework include 1) incorporating the 

voluntary industry initiative on groundwater protection into the regulatory framework, 2) revising 

the current radiological effluent performance indicator in the Reactor Oversight Process (ROP), 

3) considering immediate remediation of leaks/spills at NRC-licensed facilities, and 4) 

participating in consensus standards development. 

The EDO directed a Senior Management Review Group (SMRG) to consider the findings of the 

GTF and to determine how to address the conclusions and recommendations in the final report. 

The SMRG was chaired by the Deputy Executive Director for Reactor and Preparedness 

Programs, and composed of office directors from the major NRC program offices, the General 

Counsel, and the Regional Administrator from Region III. 

DISCUSSION: 

The SMRG identified: 1) near-term staff actions, and 2) potential policy issues for consideration. 

This paper provides the outcome of the SMRG assessment of the first two themes of the GTF 

report. The second two themes are addressed in a memorandum to the Chairman titled 

“Initiatives for Improved Communication of Groundwater Incidents,” (ADAMS Accession 

No. ML110050252). 

The SMRG held a public meeting on October 4, 2010, to seek feedback on the 

recommendations of the GTF report from a diverse group of external stakeholders. 

Perspectives from the public are discussed in Enclosure 1. The SMRG’s consideration of 

groundwater protection within the current regulatory framework is summarized in Enclosure 2. 

In its review of the first two themes, the SMRG concurred with the GTF’s conclusion that the 

NRC is accomplishing its stated mission of protecting public health, safety, and protection of the 

environment through its response to groundwater leaks/spills, consistent with its regulatory 

framework. The NRC regulatory framework is undergirded by bedrock requirements that 

licensees must meet for control of effluents and release of radioactive material such as dose 

limits found in Title 10 of the Code of Federal Regulations (10 CFR) 20.1301 and design 

objectives found in 10 CFR 50, Appendix I, and the SMRG has concluded that, based upon staff 
The Commissioners - 3 - 

evaluations, these requirements are being met. The SMRG also acknowledged that there are 

ongoing activities by the staff and industry to address groundwater protection. Significant 

progress has been made and many near-term activities are close to completion. This paper 

summarizes these efforts, and the staff’s ongoing evaluation of progress on industry activities. 

The overall strategy is to evaluate results of the current and near-term industry activities before 

determining the need for the regulatory changes recommended in the GTF report. 

1) Incorporating the Voluntary Industry Initiative on Groundwater Protection into the 

Regulatory Framework

In response to leakage and groundwater contamination incidents, the nuclear industry 

developed three initiatives to address stakeholder concerns. The first initiative is Nuclear 

Energy Institute (NEI) 07-07, “Industry Ground Water Protection Initiative (GPI),” issued 

August 2007 (ADAMS Accession No. ML062260198). The second industry initiative is the 

Buried Piping Integrity Initiative, dated November 20, 2009 (ADAMS Accession 

No. ML093350032). The third industry initiative is the Underground Piping and Tanks Integrity 

Initiative, dated September 27, 2010 (ADAMS Accession No. ML103410507). This third 

initiative supersedes the second initiative and broadens its applicability to all underground piping 

and tanks. These initiatives are discussed further in Enclosure 3. 

The NRC’s Buried Piping Action Plan (ADAMS Accession No. ML102590171) contains activities 

to evaluate the long-term effectiveness of the Underground Piping and Tanks Integrity Initiative 

such as 1) trending the incidence of degradation of buried piping, 2) determining how effective 

the program is in decreasing the occurrence of groundwater incidents, and 3) evaluating the 

need for changes to the ROP. Methods of evaluating the initiative include onsite inspections 

discussed in Enclosure 4, review of licensees’ root cause analyses, tracking the frequency of 

leakage, and evaluating industry performance metrics related to leakage and potential 

groundwater contamination. The nuclear industry has developed a common database to track 

instances of degradation or leakage from buried and underground structures, systems, and 

components (SSC). This database is useful in tracking improvements in the management of 

buried and underground SSC leak tight integrity. In addition, the NRC staff tracks radionuclide 

concentrations released from the plants, and publishes them on the NRC public web page. 

The GTF report recommends that the staff consider incorporating the voluntary industry initiative 

on groundwater protection into the regulatory framework. Many stakeholders expressed 

concern that the NRC is relying on an industry initiative, rather than regulatory requirements, to 

prevent unintended releases of radioactive material and recommended that the initiative be 

incorporated into the regulatory framework. The SMRG found that, based on information gained 

from NRC inspections, independent peer assessments, and industry assessments, licensee 

actions taken in response to leaks and spills have been consistent with NRC’s regulatory 

requirements and no new regulatory requirements need to be considered with respect to 

groundwater protection at this time. The SMRG found that the three industry initiatives can, if 

properly implemented, enhance the prevention, response and remediation of potential threats to 

groundwater. The SMRG also found that in view of the progress being made by industry in 

protecting groundwater, rulemaking or some other form of regulatory requirement to codify the 

voluntary initiatives would not result, at this time, in a substantial increase in the overall 

protection of the public health and safety. Hence the SMRG did not support the GTF 

recommendation. 
The Commissioners - 4 - 

Consistent with one of the recommendations of the GTF report, the staff plans to develop a 

generic communication regarding leaks and spills onsite, to remind licensees to maintain their 

operations and designs consistent with their licenses. The intent of the generic communication 

will be to convey the staff’s observation that the industry programs are providing more active 

management of situations that can lead to unplanned releases and that the staff plans to 

continue to assess the effectiveness of the programs through the Reactor Oversight Program. 

2) Revising the Current Radiological Effluent Performance Indicator in the Reactor 

Oversight Program

In March 2000, the radiological effluent performance indicator was developed in accordance 

with NEI 99-02, Revision 0, “Regulatory Assessment Performance Indicator Guidelines,” 

(ADAMS Accession No. ML110180011) as a leading indicator for any challenge to the public 

dose limit of 10 CFR Part 20. The performance indicator was set to a small fraction of the 

regulatory limit and licensees’ performance regarding effluent releases never approached this 

small fraction of the regulatory limit. Based on this performance indicator, the staff has 

concluded that licensees’ radiological effluent control programs have been satisfactory. At the 

same time, however, the frequency of radioactive leaks and spills (unintentional releases) was 

increasing. The GTF report concluded that the current radiological effluent performance 

indicator did not provide meaningful data on groundwater contamination and recommended that 

the performance indicator be revised to be more predictive of degrading performance in this 

area. Based on this recommendation, the staff will evaluate whether a change should be made 

to develop a more leading indicator of degraded performance in groundwater protection for the 

current Public Radiation Safety Cornerstone. This recommendation will be evaluated in the 

annual ROP self-assessment and will be discussed in the Commission paper associated with 

that review. The SMRG supports this course of action. 

3) Considering Immediate Remediation of Spills at NRC-licensed Facilities 

The GTF report discussed a paper that was before the Commission, SECY-09-0042, “Final 

Rule: Decommissioning Planning.” Subsequently, the Commission approved the rule, with 

some changes, for publication in the Federal Register (ADAMS Accession No. ML103350034). 

Under the Decommissioning Planning Rule, licensees that identify subsurface contamination 

and those (except those under 10 CFR Part 40) that detect significant subsurface contamination 

have the option to conduct immediate remediation. The rule requires that surveys be performed 

if there is reason to believe that significant subsurface contamination is present. Significant 

contamination is that which would require remediation at the time of license termination to meet 

unrestricted release limits. If they do not remediate immediately, then materials licensees are 

required to plan for and provide funds in the form of financial assurance to conduct remediation 

at a later time, including at the time of decommissioning. No similar requirement is specified for 

power reactor licensees because the Commission’s regulations already require power reactor 

licensees to show how they can provide reasonable assurance that funds will be available for 

decommissioning. 

The new Decommissioning Planning Rule (SECY-09-0042) requires all licensees to ensure that 

records from surveys describing the location and amount of subsurface residual radioactivity 

identified at the site are kept with records important for decommissioning. For power reactors, 

the recordkeeping requirements are specified by 10 CFR 50.75(g). Per 10 CFR 50.75(f)(3), at 

or about 5 years prior to shutdown, power reactor licensees are required to submit a 
The Commissioners - 5 - 

site-specific, preliminary decommissioning cost estimate, which includes an assessment of the 

major factors that could affect the cost of decommissioning. The assessment will include 

information on subsurface residual radioactivity kept in the records required by 50.75(g), and 

therefore, the costs of remediating subsurface contamination will be included in the site-specific 

cost estimate. The final rule does not mandate prompt remediation for any licensees. 

Under a staff requirements memorandum dated December 10, 2007, for SECY-07-0177, 

"Proposed Rule: Decommissioning Planning," the Commission, among other things, directed 

the staff to make further improvements to the decommissioning planning process by addressing 

immediate remediation of residual radioactivity during the operational phase with the objective 

of avoiding complex decommissioning challenges that can lead to legacy sites. The staff 

started information gathering and analysis in support of the technical basis in fiscal year (FY) 

2010. The staff is currently performing a feasibility evaluation and will formulate a 

recommendation in FY 2011. 

4) Participating in Consensus Standards Development

Staff continues to participate in consensus standards (i.e., code) activities related to the 

potential for addressing nonsafety-related piping in code cases, as discussed in Enclosure 2. 

Many examples of degradation in buried piping have been discovered in nonsafety-related, 

nonclass piping, which are not subject to the jurisdiction of The American Society of Mechanical 

Engineers Boiler and Pressure Vessel Code (ASME Code). The ASME Code does not currently 

address nonsafety-related piping nor does it address leaks that are not structurally significant. 

Recognizing that leaks in piping, if undetected for extended periods, could represent precursors 

to loss of structural integrity, the staff discussed this issue with the appropriate ASME Code 

committee. The staff has initiated, and plans to continue, efforts to work with consensus 

standards organizations to have certain provisions related to inspections of nonsafety-related 

piping incorporated into ASME code cases. The staff is also working with a task group within 

NACE International (formerly National Association of Corrosion Engineers) to evaluate the need 

for corrosion protection standards specific to the configuration of piping at nuclear power plants. 

CONCLUSION: 

As discussed above, the SMRG concluded that the staff’s planned approach for addressing the 

issues raised in the first two themes of the GTF report are reasonable next steps. The staff 

plans to engage the industry to identify and to close gaps in implementation of the industry 

initiatives, and to evaluate the progress of these actions to reduce groundwater contamination. 

The staff has mechanisms in place to revisit its position based on the success of the initiatives 

in decreasing the trend of groundwater incidents. 

COMMITMENTS: 

Staff plans to evaluate the long-term effectiveness of the industry initiatives through onsite 

inspections, review of licensees’ root cause analyses, tracking the frequency of leakage, and 

evaluating industry performance metrics related to leakage and potential groundwater 

contamination. 
The Commissioners - 6 - 

The staff has initiated, and plans to continue, efforts to work with consensus standards 

organizations to have certain provisions related to inspecting and maintaining buried piping 

incorporated into ASME code cases and NACE standards. 

The staff will evaluate whether a change should be made to develop a more leading indicator of 

degraded performance in SSCs designed to prevent unplanned releases of radioactive material 

for the current Public Radiation Safety Cornerstone in the annual ROP self-assessment and will 

be discussed in the Commission paper associated with that review. 

The staff is currently performing a feasibility evaluation to address remediation of residual 

radioactivity during the operational phase with the objective of avoiding complex 

decommissioning challenges that can lead to legacy sites and will formulate a recommendation 

in FY 2011. 

RESOURCES: 

The resources required to implement these activities are fully funded in the FY 2011 budget. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objections. The 

Office of the Chief Financial Officer has reviewed this paper for resource implications and has 

no objections. 

 /RA/ 

R. W. Borchardt 

Executive Director 

 for Operations 

Enclosures: 

1. Stakeholder Perspectives on 

 Groundwater Releases 

2. Regulatory Framework 

3. Industry Initiatives 

4. NRC’s Inspection Program 
The Commissioners - 6 -

The staff has initiated, and plans to continue, efforts to work with consensus standards 

organizations to have certain provisions related to inspecting and maintaining buried piping 

incorporated into ASME code cases and NACE standards. 

The staff will evaluate whether a change should be made to develop a more leading indicator of 

degraded performance in SSCs designed to prevent unplanned releases of radioactive material 

for the current Public Radiation Safety Cornerstone in the annual ROP self-assessment and will 

be discussed in the Commission paper associated with that review. 

The staff is currently performing a feasibility evaluation to address remediation of residual 

radioactivity during the operational phase with the objective of avoiding complex 

decommissioning challenges that can lead to legacy sites and will formulate a recommendation 

in FY 2011. 

RESOURCES: 

The resources required to implement these activities are fully funded in the FY 2011 budget. 

COORDINATION: 

The Office of the General Counsel has reviewed this paper and has no legal objections. The 

Office of the Chief Financial Officer has reviewed this paper for resource implications and has 

no objections. 

 /RA/ 

R. W. Borchardt 

Executive Director 

 for Operations 

Enclosures: 

1. Stakeholder Perspectives on 

 Groundwater Releases 

2. Regulatory Framework 

3. Industry Initiatives 

4. NRC’s Inspection Program 

ADAMS Accession Number: ML110050525 *Concurrence via Email 

OFFICE NRR/DLR TECH EDITOR NRR NRO FSME 

NAME ALund KAzariah-Kribbs* ELeeds MJohnson* CMiller 

DATE 01/14/2011 01/07/2011 01/31/2011 01/31/2011 02/02/2011 

OFFICE NMSS RGNIII RES OCFO OGC 

NAME CHaney* MSatorius* BSheron* 

(JUhle for) 

JDyer* 

(GPeterson for) 

SBurns* 

(LLondon for) 

DATE 01/28/2011 01/27/2011 01/26/2011 02/04/2011 01/31/2011 

OFFICE EDO 

NAME RBorchardt 

DATE 02/09/2011 

OFFICIAL RECORD COPY
ENCLOSURE 1 

Stakeholder Perspectives on Groundwater Releases

As the Groundwater Task Force (GTF) Report stated, detection of tritium in groundwater 

monitoring wells has caused licensees to take actions to address the source of the tritium and 

communicate the impact to their stakeholders. Implementation of the industry voluntary 

groundwater initiative has resulted in increased reporting by licensees of the discovery of 

leaks/spills that have the potential to affect groundwater, and has led to increased stakeholder 

interest. The report concluded that the U.S. Nuclear Regulatory Commission (NRC) response 

to leaks and spills has varied widely and has been case specific. Some stakeholders believe 

these incidents have raised questions regarding NRC actions to date, as well as licensee 

actions, and whether these actions should be augmented. The review by the Senior 

Management Revision Group (SMRG) afforded the agency an opportunity to reflect on past and 

current agency activities to evaluate whether additional efforts should be initiated. 

After reviewing the GTF report recommendations, the SMRG held a public meeting on 

October 4, 2010, to seek feedback on the recommendations from a diverse group of external 

stakeholders. A wide range of stakeholders attended, including representatives from other 

Federal agencies (U.S. Environmental Protection Agency (EPA), U.S. Department of Energy 

(DOE), U.S. Geological Survey), the State regulatory agencies, the Canadian Nuclear Safety 

Commission, the Conference of Radiation Control Program Directors, the Health Physics 

Society, the Prairie Island Indian Community, the Nuclear Energy Institute, the National Mining 

Association, licensees, and public advocacy groups. The purpose of the meeting was to ensure 

that senior management had identified and considered the right issues on which to focus 

attention as it addressed the GTF report recommendations and conclusions. The meeting was 

transcribed, and written comments pertaining to the policy issues discussed at the meeting were 

accepted until November 1, 2010. The SMRG received comments from 25 different entities in 

total, captured in the meeting transcript or in written comments. 

Reviewing this input, the SMRG realized that there are a wide range of views held by 

stakeholders. Some stakeholders expressed their views that no new regulations are needed, 

just consistent application and enforcement of current regulations. The SMRG also noted 

differences in perspective on NRC’s role in groundwater protection and how it is viewed by 

some key stakeholders (States, Tribes, etc.). Some stakeholders treat groundwater and surface 

water as “potential” drinking water (in addition to the drinking water sources regulated by the 

EPA Safe Drinking Water Act) and compare testing results to the same standard as the EPA 

drinking water standard. State guidelines and targets may be more stringent than either the 

EPA or NRC regulations, and States may view that they are “filling the gap,” when they perceive 

that NRC efforts do not go far enough. In comparison, the NRC’s regulatory framework includes 

actions licensees must take if environmental samples exceed NRC reporting levels. The NRC 

design objective for light water power reactors is 3 millirems (mrem) whole body dose for liquid 

effluent through all pathways of exposure (Title 10 of the Code of Federal Regulations Part 50 

Appendix I). The NRC’s approach is focused on minimizing public dose within established 

regulatory limits and, as such, is assumed to protect the environment. The Commission has 

recently addressed aspects of this issue in its response to a staff paper on international 

standards (SECY-08-0197). 
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Many comments received by the SMRG focused on the importance of maintaining the integrity 

of buried piping in order to minimize leakage. Another stakeholder concern mentioned 

frequently was the location of onsite wells relative to the underground components carrying 

radioactive material. Stakeholders suggested that, to the extent feasible, licensees should 

reduce both routine and unintended radiological releases from facilities that the NRC regulates 

and that there should be better oversight of nonsafety-related buried piping that contains 

radioactive material. They were particularly concerned about the adequacy of monitoring and 

characterizing unintended releases on site and the condition of the piping that is either buried (in 

contact with soil) or underground. Stakeholders asked that the NRC recognize that this will only 

become more of a problem as plants age, unless piping is maintained in a manner that 

minimizes the possibility of leakage. 
ENCLOSURE 2 

Regulatory Framework

An understanding of the routine discharge of radioactive materials, including tritium, from a 

nuclear power plant is necessary to gain a perspective on the unplanned releases from 

underground and buried components. Tritium is a naturally occurring radioactive form of 

hydrogen that is produced in the atmosphere when cosmic rays collide with air molecules. As a 

result, tritium is found in very small or trace amounts in groundwater throughout the world. It is 

also a byproduct of the production of electricity by nuclear power plants. A radiation dose from 

tritium is the same as from any other type of radiation, including natural background radiation 

and medical administrations. The tritium dose from nuclear power plants is much lower than the 

doses attributable to natural background radiation and medical administrations. Humans 

receive approximately 50% of their annual radiation dose from natural background radiation, 

48% from medical procedures (e.g., x-rays), and 2% from consumer products. Doses from 

tritium and nuclear power plant effluents are a negligible contribution to the background 

radiation to which people are normally exposed, and they account for less than 0.1% of the total 

background dose (National Commission on Radiation Protection and Measurement, Report No. 

160, “Ionizing Radiation Exposure of the Population of the United States: An Update,” 

September 2009). As an example, assume that a residential drinking water well sample 

contains tritium at the level of 1,600 picocuries per liter (pCi/L) (a comparable tritium level was 

identified in a drinking water well near the Braidwood Station nuclear facility). The radiation 

dose from drinking water at this level for a full year (using EPA assumptions that 20,000 pCi/L 

equates to 4 millirem (mrem) annually) is 0.3 mrem, which is: 

• at least three hundred times lower than the dose from a medical procedure involving a 

full-body computed tomography (CT) scan (e.g., 500 to 1,500 mrem from a CT scan) 

• one thousand times lower than the approximate 300 mrem dose from natural 

background radiation 

• fifty times lower than the dose from natural radioactivity (potassium) in your body (e.g., 

15 mrem from potassium) 

• twelve times lower than the dose from a round-trip cross-country airplane flight (e.g., 4 

mrem from Washington, DC to Los Angeles and back) 

Virtually all commercial nuclear power plants routinely release minor amounts of radioactive 

materials, including tritium, to the environment in liquids and gases. These releases are 

planned, monitored, and documented. NRC regulations in Title 10 of the Code of Federal 

Regulations (10 CFR) Part 20, “Standards for Protection Against Radiation,” and in 

10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities,” place limits and 

As Low As Is Reasonably Achievable (ALARA) numerical design objectives on these releases 

to ensure that the impact on public health is very low. On an annual basis, the NRC ALARA 

design objective specifies that the release of radioactive material in a liquid form from a nuclear 

power plant must not result in a radiation dose of greater than 3 mrem (0.03 mSv) to any 

individual in an unrestricted area (outside the plant perimeter). All licensees are required to 

report results to the NRC, and all reports have been well within this limit. 
- 2 - 

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 from nuclear power plants. However, 

many State authorities have adopted the EPA’s drinking water standards as legally enforceable 

groundwater protection standards, and those standards are often used in assessing laboratory 

test results of water from private wells. In 1976, EPA established a dose-based drinking water 

standard of 4 mrem per year. In so doing, EPA set a maximum contaminant level of 20,000 

pCi/L for tritium. This level is assumed to yield a dose of 4 mrem per year. If other similar 

radioactive materials are present in the drinking water, in addition to tritium, the sum of the 

annual dose from all radionuclides shall not exceed 4 mrem per year. Since EPA developed the 

1976 drinking water standard, scientists have improved the calculation methods to equate 

concentrations of tritium in drinking water (pCi/L) to radiation doses in people (mrem). In 1991, 

EPA calculated a tritium concentration to yield a 4 mrem per year dose as 60,900 pCi/L – a 

threefold increase from the maximum contaminant level of 20,000 pCi/L established in 1976. 

However, EPA kept the 1976 value of 20,000 pCi/L for tritium in its latest regulations. 

A comparison of international standards and guidelines for tritium in drinking water was recently 

published by the Canadian Nuclear Safety Commission in January 2008, titled “Standards and 

Guidelines for Tritium in Drinking Water.” The guidelines for radionuclides in drinking water 

adopted by the majority of the international community are based on international radiation 

protection methodologies and recommendations of the International Commission on 

Radiological Protection (ICRP) and the World Health Organization. The information was 

provided in SI (International System) units, with the United States limit of 20,000 pCi/L 

converted to 740 Becquerel per Liter (Bq/L) for easy comparison. The limits ranged from 100 

(most European Union countries use this as a screening value) to 76,103 Bq/L in Australia. 

Canada, our closest neighbor listed in the table, uses 7000 Bq/L as their limit, which is much 

higher than the US limit. The World Health Organization guidelines are 10,000 Bq/L, which is 

also much higher than the US limit. 

As with any industrial facility, a nuclear power plant may deviate from normal operation with a 

spill or leak of liquid material. However, the plant design and the NRC’s inspection program 

both provide reasonable assurance that safety limits will be met – even in situations where leaks 

occur. The NRC limits and ALARA dose controls apply to both normal effluent discharges and 

unplanned releases such as leaks or spills containing radioactive materials. Regardless of the 

source, each nuclear power plant is required to account for the radioactivity released to the 

environment, including planned and unplanned releases. Each licensee is responsible for 

accounting for the release, evaluating the release relative to NRC regulatory requirements, and 

reporting the quantity of radioactivity released and the highest radiation dose to any member of 

the public. 

Licensees are required to verify that radioactive effluents, either from leak/spills or from normal 

operations, are within NRC regulatory limits and design objectives. The NRC limits doses 

received by the public from licensee operations, including releases of radioactive effluents 

through requirements found in 10 CFR 20.1301, "Dose Limits for Individual Members of the 

Public," and the design objectives are contained in 10 CFR 50 Appendix I, "Numerical Guides 

for Design Objectives and Limiting Conditions for Operation to Meet the Criterion ‘As Low As Is 

Reasonably Achievable’ for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor 

Effluents." These limits and design objectives are incorporated into the licensee’s technical 

specifications and Offsite Dose Calculation Manual (ODCM). 
- 3 - 

As part of their site programs, licensees monitor groundwater by using wells to detect whether 

leakage of radioactive materials is occurring. Once radionuclides are discovered in 

groundwater onsite, licensees are required (by their licensing basis such as Technical 

Specifications and ODCM) to monitor groundwater and drinking water if local supplies are likely 

to be affected. The intent of this routine monitoring is to assure that leaks will be detected in a 

timely manner, before established limits could be challenged. 

The regulations identify how quickly reports on various unplanned and planned releases should 

be submitted to the NRC. The regulations in 10 CFR 50.72 include criteria for four-hour reports. 

These reports are required for any event or situation related to the health and safety of the 

public or onsite personnel, or protection of the environment, for which a news release is planned 

or notification to other government agencies has been or will be made. Such an event may 

include an inadvertent release of radioactively contaminated materials. The licensee’s licensing 

basis also includes provisions for 30-day reports if any radionuclide (or combination of 

radionuclides) exceeds the reporting levels outlined in the licensee’s ODCM. There are also 

reporting requirements in 10 CFR 50.73 for Licensee Event Reports tied to radioactive releases 

substantively above those specified in 10 CFR 20 Appendix B. The licensee’s programs must 

be sufficiently robust to support the regulatory requirements for monitoring and reporting. 

In accordance with 10 CFR 50.36a, nuclear power plant operators are required to submit an 

annual Radioactive Effluent Release Report to the NRC detailing the amount of radioactive 

material released to the environment during the past year. This report estimates the public 

health impact of the releases. In accordance with 10 CFR 50 Appendix I, Section IV.B, NRC 

regulations also require nuclear power plant operators to monitor the environment in the vicinity 

of the nuclear power plant to assess the cumulative impact of the radioactive material that has 

been released. On an annual basis, the results of the environmental monitoring program are 

submitted to the NRC in the Annual Radiological Environmental Operating Report. These 

reports are available to the public via the NRC Web site 

(http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html). 

Changing the NRC regulations to explicitly consider protection of the environment was 

addressed in the staff’s evaluation of the 2007 recommendations of the International 

Commission on Radiological Protection, contained in ICRP Publication 103. The ICRP 

definition of environment considers a small set of reference animals and plants that are typical 

of the major environments. Recommendations from this publication were discussed with the 

Advisory Committee on Nuclear Waste and Materials (ACNW&M) during its 

February 12–14, 2008, meeting and summarized in an ACNW&M report, “Review of ICRP 

Publication 103,” dated March 27, 2008 (ADAMS Accession No. ML080790301). The staff 

presented options to the Commission in 2008 regarding the recommendations contained in 

ICRP Publication 103, SECY-08-0197, “Options to Revise Radiation Protection Regulations and 

Guidance with Respect to the 2007 Recommendations of the International Commission on 

Radiological Protection,” dated December 18, 2008. The associated staff requirements 

memorandum, dated April 2, 2009, agreed with the NRC staff that “there is no evidence that the 

current set of radiation protection controls is not protective of the environment, and that the NRC 

should not develop separate radiation protection regulations for plant and animal species.” The 

staff’s approach has followed the Commission direction. The SMRG finds that licensee actions 

taken in response to leaks and spills are protective of the environment and no new policy 

actions need to be considered with respect to protection for plant and animal species of the 

environment. 
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In 2009, in response to an increasing trend of reported occurrences of leaks in buried piping, the 

Chairman requested a staff evaluation of the adequacy of 1) NRC requirements for design, 

inspection, and maintenance of safety-related buried piping, 2) ASME Code requirements for 

design, inspection, and maintenance of safety-related piping, and 3) voluntary initiatives for the 

design, inspection, and maintenance of safety-related and nonsafety-related buried piping. The 

Chairman also requested a discussion of staff plans for recommending revisions to regulations, 

requirements, practices, or oversight related to buried piping. SECY-09-0174, “Staff Progress in 

Evaluation of Buried Piping at Nuclear Reactor Facilities,” dated December 2, 2009, responded 

to the Chairman’s request and discusses the NRC’s current regulatory framework for 

maintaining the integrity of buried piping used at nuclear plants. The paper concluded that the 

goals of current regulations are to ensure that the piping is able to perform its intended safety 

function by supplying sufficient fluid flow and to maintain inadvertent releases below the 

licensee’s technical specifications or other applicable NRC limits. The staff determined that 

current regulations are adequate for these purposes but are not intended to ensure pipes are 

leak tight. 

The paper discussed the regulatory framework regarding underground systems, structures and 

components (SSCs) as well as groundwater protection to protect the health and safety of the 

public. Applicable regulations establish criteria or limits that, if met, ensure the health and 

safety of the public are maintained. Both buried piping (in contact with soil) and underground 

piping (e.g., contained in vaults) can be either safety-related or nonsafety-related piping. The 

criteria and limits for safety-related piping require the piping to be able to perform its safety 

function and require that any radioactive material that may be released not pose any credible 

threat of harm to public health and safety. Safety related is defined by 10 CFR 50.2 and means 

those items relied upon to remain functional during and following design basis events to assure: 

(1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the 

reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate 

the consequences of accidents which could result in potential offsite exposures comparable to 

the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 10 CFR 100.11, as 

applicable. Safety related piping systems generally fall into one of the ASME Code 

classifications (i.e., Class 1, 2 or 3). Safety-related buried piping falls under ASME Code Class 

3, which means it generally contains relatively low pressure and low temperature water. 

For all nuclear power plants, the regulations in 10 CFR Part 50, Appendix A, “General Design 

Criteria,” or similar requirements imposed during plant licensing for pre-10 CFR Part 50, 

Appendix A facilities, provide requirements for SSCs important to safety. These regulations 

specify piping, including buried piping, be designed in a robust manner that ensures piping 

structural integrity, capability to withstand the effects of natural phenomenon such as 

earthquakes, configuration to permit inspection to assure integrity and capability of the system, 

and capability to permit appropriate periodic pressure and functional testing. The criteria 

presented in 10 CFR 50, Appendix A, are design and operational objectives that provide a 

foundation for safety at nuclear power plants. 

In addition, the regulations in 10 CFR 50.55a, “Codes and Standards,” require the application of 

various codes and standards such as the ASME Code. 10 CFR 50.55a provides requirements 

for examining and testing buried, safety-related piping through the endorsement of sections of 

the ASME Code. The ASME Code does not currently address nonsafety-related piping nor 

does it address all leaks that are not structurally significant. However, the integrity of 

underground SSCs remains important to the nuclear power plant operators, as they must 
- 5 - 

monitor the releases (effluents) from their plants, regardless of whether the releases are 

planned or unplanned. As required by 10 CFR 50.75(g), records of spills/leaks and the 

locations of structures in underground locations that may be subject to contamination must be 

kept to facilitate safe and effective decommissioning of the facility. 

NRC regulations incorporate by reference the technical requirements, safety requirements, 

guidelines, and recommended practices of the ASME Code for assessing structural adequacy of 

piping considered important to safety. The NRC staff has determined that current ASME Code 

requirements are adequate for ensuring that structural integrity is maintained for buried, 

safety-related piping such that the piping is capable of performing its safety function. The 

ASME Code does not currently address nonsafety-related piping nor does it address all leaks 

that do not challenge the structural integrity of the pipe. Historically, the focus of the NRC’s 

regulatory requirements has been to ensure that radioactive releases—including unintended 

leaks and spills—stay below NRC dose limits and design objectives, within the effluent limits 

that are approved for the plant. Because some of the leakage that has been observed has been 

associated with nonsafety-related piping, and NRC regulations are not prescriptive for 

addressing the maintenance of nonsafety-related piping and tanks containing radioactive 

material, the GTF report recommended additional staff efforts in this area. The staff had earlier 

noted in SECY-09-0174 that discussions with ASME Code committee members resulted in the 

observation that changes to the ASME Code to require pipes be leak tight, or to extend Code 

provisions to nonsafety-related piping, would be a significant effort that would not necessarily 

have any beneficial effect on structural integrity, which is the current focus of the Code 

provisions. However, in light of NRC involvement in this issue and stakeholder attention, and 

recognizing the benefits to the utilities of proactive maintenance, the pertinent ASME Code 

committees have decided to develop a Code Case for inspection and maintenance of 

safety-related buried piping and are considering the development of provisions for 

nonsafety-related piping as well. Development of such inspection and maintenance guidance 

via the consensus standard process is responsive to the recommendations in the GTF report 

and may be included in a future update to the regulatory framework. The staff would review any 

additional Code provisions for endorsement through the normal 10 CFR 50.55a, “Codes and 

Standards,” rulemaking, which incorporates Code provisions by reference into the regulations. 

Over the past decade, instances of buried piping leaks have occurred in safety-related and 

nonsafety-related piping at nuclear power plants. Some of these leaks have caused inadvertent 

releases of low-level radioactive material. This has resulted in groundwater contamination at 

several plants. The staff evaluated these events individually and contemporaneously. The pipe 

degradation leading to these leaks did not affect the operability of safety systems, and the type 

and amount of radioactive material or chemicals released to the environment was a small 

fraction of the regulatory limits. Consequently, these pipe leaks have been of low significance 

with respect to public health and safety and the environment. 

The staff evaluated whether the occurrences of release of radioactive material into the ground 

as a result of degradation of buried piping indicated a need to establish limits at a location other 

than the site boundary (within the site boundary). As part of the operational experience review 

associated with the development of SECY-09-0174, the staff determined that none of the events 

associated with degradation of buried piping resulted in releases that exceeded a small fraction 

of existing limits for members of the public at the site boundary. Since the staff’s review of the 

known pipe leaks indicated the dose impact was a small fraction of existing limits at the site 

boundary, the staff concluded that it is not currently necessary to establish any new 
- 6 - 

requirements that would be applicable inside the site boundary to address buried piping 

degradation. 

Looking to the future, new reactors are required to meet the requirements discussed above. In 

addition, 10 CFR 20.1406, Minimization of Contamination, requires license applications 

submitted after August 1997 to demonstrate how the facility's design and procedures for 

operation will reduce contamination of both the facility and environment as well as reduce the 

generation of radioactive waste. Proper implementation of this regulation for new reactors 

should substantially reduce or eliminate the occurrence of residual contamination for the next 

generation of nuclear facilities, and could include adoption of predictive maintenance practices 

to ensure leakage and contamination is maintained as low as reasonably achievable. 

Recognizing that many facilities and installations other than facilities regulated by the NRC 

employ buried piping, the staff has also evaluated regulations and codes and standards 

applicable to other industries, as discussed in SECY-09-0174. Buried piping and tanks that 

contain or transport potentially hazardous or environmentally sensitive material are regulated 

under U.S. Department of Transportation (49 CFR) and EPA (40 CFR) regulations. Generally, 

these regulations implement installation, corrosion protection, maintenance and condition 

monitoring standards developed by NACE International (formerly National Association of 

Corrosion Engineers). Degradation of buried piping is caused by corrosion. The 

implementation of these standards has been highly effective in preventing leaks in buried piping 

and buried tanks. These corrosion protection standards are required to be applied to many 

thousands of miles of buried petroleum product transportation piping and many thousands of 

buried tanks in the United States but are not required to be implemented at nuclear power 

plants. The staff reviewed these standards and concluded that implementation of these 

standards at nuclear power facilities could be an effective means of reducing the potential for 

degradation and consequential leakage from buried piping. 

Current NACE standards are optimized for long straight runs of piping typical of transmission 

pipelines, and therefore cannot be considered optimized for use by nuclear power plant 

operators. In recognition of the significant interest of nuclear power plant operators in the issue 

of buried piping, NACE has formed a nuclear buried piping task group. The purpose of this task 

group is to evaluate the need for specific corrosion protection standards that could be 

implemented at nuclear power facilities. The staff is participating in this task group and believes 

that implementation of NACE standards in nuclear power plants could complement the ASME 

Code Section III and XI provisions and be an effective means of reducing the potential for 

degradation and consequential leakage from buried piping through proactive strategies such as 

cathodic protection. Reducing the potential for leaks by strengthening piping standards is 

responsive to the policy issue raised in the GTF report regarding the need to ensure that the 

regulatory framework is sufficient to address inadvertent leaks and spills. The nuclear power 

industry has developed a document through the Electric Power Research Institute, 

“Recommendations for an Effective Program to Control the Degradation of Buried Pipe,” 

released publicly on October 7, 2009 (and update December 2010), for use by nuclear plants 

and is implemented programmatically through the industry initiatives discussed in Enclosure 3. 

This document contains elements of the NACE standards, which have formed the basis for the 

industry initiatives addressing buried piping. The Institute for Nuclear Power Operations uses 

the NACE guidance to evaluate plants’ buried piping programs during its evaluations. 
- 7 - 

The staff has also recognized the value of these corrosion protection strategies in their license 

renewal guidance. In response to operating experience, the NRC staff initiated a recent update 

to the Buried and Underground Piping and Tanks Aging Management Program in the NRC 

guidance document for license renewal, NUREG-1801, Revision 2, “Generic Aging Lessons 

Learned (GALL) Report,” issued December 2010 (ADAMS Accession No. ML103490041). The 

Buried and Underground Piping and Tanks Aging Management Program has been modified to 

inspect a wider variety of buried components subject to an aging management program and to 

credit the consistent use of cathodic protection for a buried component in determining the 

inspection frequency for the component. 

The staff has also participated in developing an industry-consensus standard on evaluation of 

subsurface radionuclide transport at commercial nuclear power plants. This standard was 

completed and approved by the American Nuclear Society (ANS) and the American National 

Standard Institute (ANSI) as ANS/ANSI-2.17-2010 in December 2010. Its scope is to establish 

“the requirements for evaluating the occurrence and movement of radionuclides in the 

subsurface resulting from unplanned radionuclide releases at commercial nuclear power plants. 

This standard applies to unplanned radionuclide releases that affect groundwater, water 

supplies derived from groundwater, and surface waters affected by subsurface transport, 

including exposure pathways across the groundwater-surface water transition zone.” 

Other concurrent staff activities include amending environmental protection regulations, 

10 CFR Part 51, for license renewal by updating the Commission’s 1996 findings on the 

environmental impacts related to the renewal of nuclear power plant operating licenses. The 

most recent Commission direction on this update can be found in a 2009 Staff Requirements 

Memorandum, SRM-SECY-09-0034 (May 4, 2009). 

The NRC proposed (74 Federal Register 38117; July 31, 2009), and the public has commented 

on, a rule that adds a new plant specific issue, “Radionuclides Released to Groundwater,” to 

evaluate the potential impact of discharges of radionuclides, such as tritium, from plant systems 

into groundwater. This issue is relevant to license renewal because all commercial nuclear 

power plants routinely release radioactive gaseous and liquid materials into the environment, 

and the continuing trend of inadvertent releases from plant systems and piping being discovered 

at nuclear power plants. These reviews will be plant specific as no generic evaluation would 

apply to all plants because each site has its own unique groundwater protection program. If 

approved, the rule will require license renewal applicants to assess the impact of radionuclides 

in groundwater resources that could also have an impact on human health and the environment 

during the license renewal term. 

Based on its review of the current regulatory framework and the industry initiatives that are 

intended to help industry meet the regulatory requirements in a uniform manner, the SMRG 

found that licensee actions taken in response to leaks and spills have been consistent with 

NRC’s regulatory requirements and no new regulatory requirements need to be considered with 

respect to protection of the environment. The SMRG found that the three industry initiatives 

can, if properly implemented, enhance the prevention, response and remediation of potential 

threats to groundwater. The SMRG also found that in view of the progress being made by 

industry in protecting groundwater, rulemaking or some other form of regulatory requirement to 

codify the voluntary initiatives would not result, at this time, in a substantial increase in the 

overall protection of the public health and safety. 
ENCLOSURE 3 

Industry Initiatives

The nuclear power industry, through the Nuclear Energy Institute (NEI), has developed industry 

initiatives focused on managing the various aspects of groundwater protection: Groundwater 

Protection Initiative, Buried Piping Integrity Initiative, and Underground Piping and Tanks 

Integrity Initiative. NEI 07-07, “Industry Groundwater Protection Initiative,” was issued in 

August 2007 (ADAMS Accession No. ML072600295). The goal of the Groundwater Protection 

Initiative (GPI), which all plants have committed to follow, is to identify licensee actions to 

improve the response to inadvertent releases that may result in low but detectable levels of 

plant-related radioactive materials in subsurface soils and water. These actions include the 

development of written groundwater protection programs, improved stakeholder 

communications, and program oversight. One objective of the GPI is to detect leaks well before 

they can challenge regulatory limits for unintended release of radioactive material to the public 

and the environment. The GPI addresses detection and remediation of leaks but is not 

necessarily focused on preventing leaks, which became the intent of a later initiative regarding 

buried piping. The GPI elements describe conducting hydrogeologic studies, performing site risk 

assessments, establishing on-site groundwater monitoring, and establishing a remediation 

protocol. Recordkeeping, communications, self assessments, and peer assessment are also 

included. Based on these program elements, licensees can select locations for site monitoring 

wells near potential sources of contamination, in order to identify leaks early. 

Industry self-assessment and peer assessment of the implementation of the GPI are key 

aspects of the program. For example, to ensure that the individual sites are implementing the 

initiative, the GPI requires licensees to do both of the following: 

(1) independent peer assessments of the site’s written groundwater protection program, and 

(2) independent NEI assessments of the site’s written groundwater protection program. 

The independent industry peer assessments evaluate aspects of the site program, such as 

having independent hydrogeologists review the location of monitoring wells relative to SSCs that 

contain or could contain licensed material and for which there is a credible mechanism for the 

licensed material to reach groundwater. The hydrogeologist assesses whether the wells are 

situated in appropriate locations. For the independent NEI assessment, a team was sent to 

each site after 1 year, with plans to reevaluate at least once every 5 years (baseline 

assessments were completed by the first quarter of calendar year 2010), to ensure that the 

program elements are in place and that elements that are not consistent with the guidance are 

tracked in the licensee’s corrective action program and addressed in a timely manner. 

 

On January 14, 2011, the NRC received a summary report of the results of the NEI-sponsored 

peer reviews of industry implementation of the 43 acceptance criteria contained in the GPI. The 

report summarizes the results of the first full round of peer reviews conducted in 2009-2010 by 

five teams of industry subject matter experts. The report concluded that industry’s 

implementation of the GPI has been successful in improving ground water protection. The 

review confirmed that each nuclear power plant site has at least one method for early detection 

of unintended releases to the environment and each site has improved procedures for 

communicating effectively to stakeholders in the event of an unintended release. The industry 
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peer reviews were designed to be challenging evaluations that identified opportunities for 

improvement. The report concluded that the assessments also identified opportunities to further 

improve these efforts using shared operating experience and best practices. Identified gaps 

were most commonly due to incomplete documentation, most frequently in the following four 

areas: 

• Documentation of evaluations of work practices to determine the potential for unintended 

releases; 

• Improvements to the systems, structures, and components (SSC) evaluations from use 

of detailed information and engineering involvement, particularly on preventative 

maintenance programs and inspections or other means of determining the condition of 

some systems, structures and components); 

• Establishment of a site-specific decision-making protocol for remediation efforts; and 

• Evaluation of the potential contribution of monitored and controlled radioactive effluents 

to detectable concentrations of plant-related licensed material in ground water (as a 

result of planned and permitted releases). 

The cover letter for the NEI report stated that upon completion of the full cycle of initial peer 

reviews, company chief nuclear officers followed up on the findings. They confirmed that all 

identified areas for improvement had been entered into the respective site corrective action 

programs and had either been addressed or were on an appropriate schedule for completion. 

Recognizing that leaks have occurred that have affected public confidence and requiring 

increased monitoring, a second industry initiative was created. This initiative is the “Buried 

Piping Integrity Initiative”, dated November 20, 2009 (ADAMS Accession No. ML093350032). 

The goal of this initiative is to provide proactive assessment and management of the condition 

of buried piping systems, sharing of industry experience, and technology development to 

improve the available techniques for inspecting and analyzing buried piping. 

The third initiative is the Underground Piping and Tanks Integrity Initiative, dated 

September 27, 2010 (ADAMS Accession No. ML103410507). Shortly after the Buried Piping 

Integrity Initiative was approved, Entergy identified a pipe located within an underground vault 

as the source of a tritium leak at Vermont Yankee. This event received much public attention in 

the Northeast and attracted significant stakeholder interest. This experience showed the 

industry that, if its Buried Piping Integrity Initiative was intended to enhance public confidence, 

limiting the scope of the initiative to piping that is in direct contact with the soil was not adequate 

when piping in vaults and other underground components could also leak into the groundwater. 

In response to this concern, the industry revised the Buried Piping Integrity Initiative to extend 

its scope to additional underground components. The added scope includes underground 

piping and tanks that are outside of a building and below grade (whether or not they are in direct 

contact with the soil) if they are safety related, or contain licensed radioactive material, or are 

known to be contaminated with licensed radioactive material. The revised initiative, the third 

consensus industry initiative, was issued with the new name, “Underground Piping and Tanks 

Integrity Initiative.” 
- 3 - 

The staff has initiated, and plans to continue, efforts to work with consensus standards 

organizations to have certain provisions related to inspection and maintenance of buried pipe 

incorporated into ASME Code cases and NACE standards. The industry initiative on 

Underground Piping and Tanks Integrity implements the philosophy of the NACE standards. 

Overall, these initiatives have the objective of reducing the number and severity of leaks 

experienced across the nuclear fleet. The GPI targets the detection of leaks when they are 

small, before they have a chance to grow and the Underground Piping and Tanks Integrity 

Initiative targets the prevention of leaks by improving maintenance and inspection (and possible 

replacement) of SSCs. Although the staff’s review of these initiatives and interaction with the 

industry continues, the SMRG finds that these initiatives provide industry the programmatic 

infrastructure to manage groundwater protection in order to enhance their compliance with the 

regulatory requirements and provide the information necessary for ensuring that these initiatives 

achieve the expected outcome—fewer and more limited unplanned releases. 
ENCLOSURE 4 

NRC’s Inspection Program

The NRC has revised its inspections of nuclear power plants to evaluate licensees’ programs to 

inspect, assess and repair equipment and structures that could potentially leak. The NRC has 

also placed additional emphasis on evaluating the licensees’ abilities to analyze additional 

discharge pathways, such as groundwater, as a result of a spill or leak. The agency’s resident 

inspectors, who work full-time at operating U.S. nuclear power plants, regularly monitor all these 

activities and any deficiencies discovered could trigger more intensive NRC oversight of a plant. 

Prior to 2008, the NRC’s baseline inspection procedures in its Reactor Oversight Program 

contained guidance for monitoring radioactive effluents, but the procedures lacked detailed 

guidance regarding inspection of licensees’ groundwater monitoring programs. As a result, the 

NRC developed NRC Temporary Instruction TI-2515/173 in 2008. 

Between August 2008 and August 2010, NRC inspectors used this Temporary Instruction to 

evaluate licensees’ groundwater monitoring programs. As all of the nuclear plants have 

indicated that they are committed to following the voluntary industry initiative on groundwater 

protection, the Temporary Instruction has been tailored to help the NRC understand how the 

program as implemented on each site ensures that the regulations are met. This Temporary 

Instruction contained detailed guidance that NRC Inspectors used to evaluate all aspects of the 

licensees’ groundwater monitoring programs. NRC inspectors used the Temporary Instruction 

at all U.S. reactor sites, and the conclusions from that effort indicated licensee’s performance 

had improved. Minor gaps still exist for some licensees in their full implementation of the 

voluntary initiative on groundwater protection, and will be the subject of review for later baseline 

inspections. 

In January 2010, the NRC baseline inspection procedures IP 071124.06 and IP 071124.07 were 

revised to include detailed guidance on inspecting licensees’ Groundwater Monitoring 

Programs. These inspection procedures contain guidance that NRC inspectors use for 

inspecting licensees’ programs for Radiological Environmental Monitoring and Radioactive 

Effluents, including guidance for inspecting licensees’ Groundwater Monitoring Programs. The 

NRC will rely on these inspection procedures to ensure licensees’ Groundwater Monitoring 

Programs contain the information necessary to comply with NRC regulations. Additionally, 

when gaps are identified in a licensee’s groundwater monitoring program, the gaps will be 

entered into the licensee’s corrective action program in order to track issues to resolution. 

As was done for the Groundwater Protection Initiative, the NRC is developing a Temporary 

Instruction for inspecting licensees’ programs for the Underground Piping and Tanks Integrity 

Initiative (formerly called the Buried Piping Integrity Initiative). This Temporary Instruction will 

be used to gauge the effectiveness of the licensees’ Underground Piping and Tank Integrity 

Initiative. 

The SMRG found that the NRC’s Temporary Instructions and Baseline Inspection Procedures 

provide a sufficient framework to inspect licensees’ compliance with NRC’s requirements for 

control of effluents and release of radioactive materials, and the programs that the licensees 

use to enhance compliance with the regulations, and the Groundwater Protection and 
- 2 - 

Underground Piping and Tank Integrity Programs. The NRC staff will continue to use this 

inspection approach, along with monitoring the licensees’ implementation of the NEI Initiatives, 

to monitor licensees’ performance with respect to groundwater protection.