ML102630196
| ML102630196 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/20/2010 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Cuthbert L Alliance For A Clean Environment |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| Download: ML102630196 (4) | |
Text
September 20, 2010 Dr. Lewis Cuthbert The Alliance for a Clean Environment P.O. Box 3063 Stowe, PA 19464
Dear Dr. Cuthbert:
Thank you for your letter on June 23,2010 entitled "Potential for an Unfolding Radioactive Groundwater Disaster from Leaking Nuclear Plants and NRC's Capitulation to the Nuclear Industry."
In your letter you requested a range of information regarding the amount and condition of underground piping at the Limerick Generating Station. You also inquired about whether leakage had occurred from this piping, as well as NRC inspections in this matter.
Much of the information you requested is publically available on the NRC website. For example, every year each licensee is required to submit the following two reports:
Annual Radiological Effluent Release Report: The "Effluent Report" lists the quantities of radionuclides released from the site in liquid and gaseous effluents for the calendar year.
Supplemental Sections F, "Abnormal Releases," and G, "Spill," of these reports would detail any spills or leaks from radioactive water systems to the environment. For example in the 2009 report pa~le 4, there is a discussion of a leak from the external walls of the condenser bay dripping onto the ground discovered on February 13, 2009. (Note: while this event did not involve an underground pipe, it did result in some localized soil contamination). The 2009 Report is attached as Enclosure 1.
Annual Radiological Environmental Operating Report: The "Environmental Report" lists the measurements of radioactive materials found in the environment surrounding the power plant.
This report details the site's environmental monitoring program, including the sampling methods for surface water, ground water, fish, sediment, milk vegetation, and airborne sampling. The report provides the sample data and locations for the samples, the results of the samples, and comparison of the results to the regulatory limits. The report also lists all of the radionuclides which are sampled for as part of the environmental monitoring program. For example, results of the February 13, 2009, spill are discussed on page 2 of the 2009 report. The report discussed the groundwater sampling results for the wells in the vicinity of the spill area. The 2009 report is attached as Enclosure 2.
L. Cuthbert 2
In addition, in 2006 a Groundwater Questionnaire was sent to each site. The "Groundwater Questionnaire" describes the state of the groundwater protection program, as of the time the questionnaire was submitted (July 2006). This questionnaire provides historical data about spills and remediation efforts (see page 4 & 5). This questionnaire is attached as Enclosure 3.
The annual reports from 2005-2009 and Limerick's response to the questionnaire is publically available at the following link:
http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports!lim1-2.html.
The NRC reviews the reports annually and conducts program inspections of the Radiological Environmental Monitoring Program in accordance with NRC Baseline Inspection Procedure 71124.07. This procedure is attached as Enclosure 4. This procedure is performed at each site biennially and the results are documented as a feeder to the applicable resident inspector quarterly integrated inspection report. For these inspections, Limerick has been found to be in compliance with the NRC's requirements. Plant-related radioactivity has not been detected at any offsite groundwater monitoring location.
With respect to underground piping, the NRC and the nuclear industry recognize that monitoring the health of underground piping systems is an issue that must be addressed. The nuclear industry has conducted a number of studies and launched several initiatives to standardize and improve the industry's performance in monitoring the condition of the piping, monitoring for indications of leaks, and reporting the results to the public, regulatory bodies, and their industry peers. All plants, including Limerick, have committed to this initiative. A description of the industry initiative is attached as Enclosure 5.
The NRC 43stablished task forces in 2006 and 2010 to review the applicable regulations and inspection procedures, and review industry proposed initiatives related to the design, inspection, and maintenance of safety-related and non safety-related buried piping. I have enclosed a copy of SECY-09-0174: "Staff Progress in Evaluation of Buried Piping at Nuclear Reactor Facilities."
This report is attached as Enclosure 6. Pages 10 and 11 of Enclosure 6 describe the current baseline inspection activities which are used to inspect buried piping. In addition, Temporary Instruction 2515/173, "Review of the Implementation of the Industry Groundwater Protection Voluntary Initiative," provided in Enclosure 7, is being conducted at all facilities and another Temporary Instruction is being developed to inspect the industry buried piping initiative.
Additional information related to groundwater monitoring and buried piping issues, can be found on the NRC's website at the following link:
http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html NRC Inspection Procedures are publically available at the following link:
http://www.nrc.qov/reading-rm/doc-collections/insp-manuaII. Additionally, copies of NRC inspection reports documenting these inspection activities are publically available at the following link: http://www.nrc.gov/NRRlOVERSIGHT/ASSESS/listofrptsbody.html.
The NRC also inspects the licensee's aging management programs as part of any license renewal review. As part of these aging management programs, an assessment of the health of buried piping and the establishment of a monitoring program is required. These inspections will be performed at limerick as part of the license renewal progress.
L. Cuthbert 3
I trust that the enclosed documents will resolve the questions you have in this matter as well as reassure you that the NRC and the licensee are monitoring the condition of underground piping and promptly addressing problems upon identification.
Respectfully, IRA!
Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects
Enclosures:
- Limerick Generating Station 2009 Annual Radioactive Effluent Release Report, ML101250324 : Limerick Generating Station 2009 Annual Environmental Operating Report, ML101250333 : Limerick Generating Station Response to the Groundwater Questionnaire, ML062280610 : NRC Inspection Procedure 71124.07, ML092190669 : NEI Industry Initiative on Buried Piping Integrity, ML093350034 and ML093350035 : SECY-09-0174 "Staff Progress in Evaluation of Buried Piping at Nuclear Reactor Facilities," ML093160004 : NRC Temporary Instruction 2515/173, IVIL082770349
L. Cuthbert 3
I trust that the enclosed documents will resolve the questions you have in this matter as well as reassure you that the NRC and the licensee are monitoring the condition of underground piping and promptly addressing problems upon identification.
Respectfully, IRA!
Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects
Enclosures:
- Limerick Generating Station 2009 Annual Radioactive Effluent Release Report, ML101250324 : Limerick Generating Station 2009 Annual Environmental Operating Report, ML101250333 : Limerick Generating Station Response to the Groundwater Questionnaire, ML062280610 : NRC Inspection Procedure 71124.07, ML092190669 : NEI Industry Initiative on Buried Piping Integrity, ML093350034 and M L093350035 : SECY-09-0174 "Staff Progress in Evaluation of Buried Piping at Nuclear Reactor Facilities," ML093160004 : NRC Temporary Instruction 2515/173, ML082770349 Distribution wlo !nclosures:
D. Lew, DRP
,J. Clifford, DRP A. Rosebrook, DRP R. Barkley, ORA J. White, DRS T. Moslak, DRS P. Krohn, DRP G. DiPaolo, DRP N. Sielier, DRP N. Esch, DRP OA D. Screnci, PAO N. Sheehan, PAO N. McNamara, SLO D. Tifft, SLO J. Bream, DRP SUNSI Review Complete: AAR (Reviewer's Initials)
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