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| {{Adams
| | #REDIRECT [[Information Notice 2006-13, E-mail from M. Mclaughlin on NRC, Regarding NRC Information Notice 2006-13: Groundwater Contamination]] |
| | number = ML060540038
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| | issue date = 07/10/2006
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| | title = Ground-Water Contamination Due to Undetected Leakage of Radioactive Water
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| | author name = Miller C L, Nieh H K
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| | author affiliation = NRC/NMSS/IMNS, NRC/NRR/ADRA/DPR
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| | addressee name =
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| | addressee affiliation =
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| | docket = 05000213, 05000237, 05000247, 05000249, 05000286, 05000454, 05000455, 05000456, 05000457
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| | license number = DPR-019, DPR-025, DPR-026, DPR-061, NPF-037, NPF-072, NPF-077
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| | contact person = Markley A W, NRR/DPR/PGCB, 415-3165
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| | case reference number = FOIA/PA-2006-0314, FOIA/PA-2010-0209
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| | document report number = IN-06-013
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| | document type = NRC Information Notice
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| | page count = 10
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| }}
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| {{#Wiki_filter:UNITED STATES
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| | |
| ===NUCLEAR REGULATORY COMMISSION===
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| OFFICE OF NUCLEAR REACTOR REGULATION
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| WASHINGTON, D.C. 20555-0001 July 10, 2006NRC INFORMATION NOTICE 2006-13:GROUND-WATER CONTAMINATION DUE TO
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| ===UNDETECTED LEAKAGE OF RADIOACTIVE===
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| WATER
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| ==ADDRESSEES==
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| All holders of operating licenses for nuclear power and research and test reactors including
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| those who have permanently ceased operations
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| and have certified that fuel has been
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| permanently removed from the reactor and those authorized by Title 10 of the
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| Code of Federal
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| Regulations
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| (10 CFR) Part 72 licenses to store spent fuel in water-filled structures.
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| ==PURPOSE==
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| The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
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| addressees of the occurrence of radioactive contamination of ground water at multiple facilities
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| due to undetected leakage from facility structures, systems, or components that contain or
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| transport radioactive fluids. It is expected that recipients will review the information for
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| applicability to their facilities and consider actions, as appropriate, to avoid similar problems.
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| However, suggestions contained in this IN are not NRC requirements; therefore, no specific
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| action or written response is required.
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| ==DESCRIPTION OF CIRCUMSTANCES==
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| Radioactive contamination of ground water has occurred at multiple facilities due to undetected
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| leakage from facility structures, systems, or components that contain or transport radioactive
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| fluids. Specific instances that have occurred recently include the following:
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| ===Braidwood Nuclear Power Plant===
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| In March 2005, the licensee was notified by the Illinois Environmental Protection Agency (EPA)
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| of tritium detected in a nearby residential well. Following that notification, the licensee began
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| monitoring ground water between the community and the Braidwood plant. The licensee found
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| detectable levels of tritium in a drainage ditch near the Braidwood access road, but at that time, no other offsite contaminated ground water was found. Based on the tritium identified in the
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| drainage ditch, the licensee installed additional onsite monitoring wells to identify the source of
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| the tritium contamination.
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| In November 2005, the licensee identified peak contaminated ground water levels of
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| 58,000 picocuries per liter (pCi/L) in shallow, ground-water monitoring wells located at the edge
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| of the owner controlled area. The licensee notified the NRC and immediately suspended all
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| further liquid radioactive releases. The tritium was attributed to historical leakage from vacuum
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| breakers along the circulating water system blowdown line that is routinely used for radioactive
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| liquid releases.
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| ML060540038 Although the Braidwood piping was below ground, the vacuum breaker valve vaults
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| communicate with the surface. Consequently, the leaks were both above and below ground. The licensee subsequently determined that onsite radioactive leakage from the blowdown
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| system had occurred in 1996 (250,000 gallons), in 1998 (3,000,000 gallons), and in 2000
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| (3,000,000 gallons). Onsite tritium levels measured in a deep onsite ground-water monitoring
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| well measured as high as 282,000 pCi/L. Offsite tritium levels measured up to 1,600 pCi/L in a
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| residential well, below the Federal EPA drinking water standard of 20,000 pCi/L. The licensee
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| characterized the extent and magnitude of the tritium ground-water contamination as an area
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| that extended about 2,000 feet by 2,500 feet outside the site boundary. The licensee's
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| radiological assessment for the hypothetical, maximally exposed individual indicates that the
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| dose consequence would be about 0.16 millirem per year (i.e., about 5 percent of the "as low as
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| reasonably achievable" (ALARA) criteria for nuclear plant design objectives and limiting
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| conditions for operation).
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| The NRC inspection found that the licensee did not (1) adequately evaluate the radiological
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| hazards associated with the leakage; (2) calculate dose to member(s) of the public; (3) revise its
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| environmental monitoring program to adequatel
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| y measure the impact to the environment;
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| (4) report aspects of the leakage in its annual effluent report; and (5) record the residual
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| contamination in files for decommissioning purposes (NRC Inspection Reports Nos. 50-456;
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| 457/2006-02, Agency Wide Documents Access
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| and Management System (ADAMS) Accession
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| No. ML061360416, and 50-456; 457/2006-008, ADAMS Accession No. ML 061450522).
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| ===Byron Nuclear Power Plant===
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| Following the identification of tritium leakage at Braidwood, the licensee initiated a sampling and
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| analysis program along the Byron circulating wa
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| ter system blowdown line. Similar to the
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| Braidwood facility, the Byron blowdown line has
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| six vacuum breakers located in valve vaults
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| located on plant property. Standing water in the vaults was sampled and analyzed, with five of
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| the six vaults having detectable levels of tritium up to 80,000 pCi/L. The licensee suspended all
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| radioactive liquid effluent releases through the blowdown line.
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| Residential wells were sampled and found not to have any detectable contamination. Additional
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| monitoring wells were installed near the valve vaults and detectable levels of tritium have been
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| found near two of the valve vaults. By April 2006, the licensee had completed repairs to the
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| vacuum breakers and vaults, including sealing the vault floors. After repairs were completed, the licensee recommenced liquid effluent discharges through the circulating water system
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| blowdown line (NRC Preliminary Notifications Nos. PNO-III-06-004 and PNO-III-06-004B).
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| ===Dresden Nuclear Power Station===
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| In August 2004, the licensee identified contaminated ground water in onsite monitoring wells
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| resulting from a leaking underground pipe connected to the condensate storage tanks.
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| Subsequent, onsite sampling identified tritium levels consistent with those present in the
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| condensate storage tank of about 8,000,000 pCi/L. The licensee isolated the leaking pipe and
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| replaced the faulty section of piping.
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| Following the 2004 leak, the licensee sampled the private wells of nearby residents. One of the
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| residents' wells that had shown detectable tritium for a number of years had tritium levels of
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| approximately 1,000 pCi/L.
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| Additionally, three other residential wells were found to have measurable but lower levels of
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| tritium. The licensee continues to evaluate the tritium in those wells, one of which is the normal
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| sample point for its radiological environmental monitoring program. In February 2006, tritium levels of 600,000 pCi/L were detected in an onsite monitoring well near
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| a section of underground piping that had not been replaced in 2004. The leaking pipe was
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| isolated and onsite tritium levels in the two closest onsite wells subsequently stabilized at
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| 20,000 - 50,000 pCi/L (NRC Inspection Report Nos. 50-237; 239/2006-03, ADAMS Accession
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| No. ML061290091).
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| Haddam Neck Station (Connecticut Yankee Atomic Power Plant)
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| The Haddam Neck Station ceased operations about 10 years ago and is being decommissioned
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| under an approved NRC license termination plan (LTP). The licensee's monitoring programs
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| have not identified any offsite ground-water contamination associated with plant operations.
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| An onsite ground-water monitoring program has been established and is being implemented in
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| support of the decommissioning. The licensee initially identified tritium, cobalt-60, cesium-137
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| and strontium-90 in the onsite ground water and/or soil samples. The licensee has removed a
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| large amount of soil and some bedrock, and backfilled the excavated areas with clean soil.
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| While the licensee has substantially reduced residual contamination levels, recent ground-water
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| sampling results have identified residual tritium up to 19,500 pCi/L, cesium-137 up to 12 pCi/L
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| and strontium-90 up to 4.5 pCi/L. The licensee has completed dose assessments for the
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| existing onsite ground-water contamination in accordance with the LTP. The dose assessments
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| indicate a dose contribution of less than 1 millirem per year due to the ground-water
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| contamination.
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| The NRC license termination requirement is that the all-pathways, total effective dose
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| equivalent to the average member of the critical group does not exceed the 10 CFR 20.1402
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| unrestricted release requirement of 25 millirem
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| per year and the residual radioactivity has been
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| reduced to ALARA. This includes the soil
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| exposure pathway, existing groundwater dose
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| contributions and future groundwater dose contributions. Additionally, the licensee must comply
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| with requirements by the State of Connecticut's Department of Environmental Protection to
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| meet the Federal EPA Maximum Contaminant Levels. The most recent NRC onsite inspection
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| is documented in NRC Inspection Report No. 50-213/2005-03, ADAMS Accession No.
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| ML060390475.
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| Indian Point Nuclear Generating Station Units 1, 2, and 3 In September 2005, the licensee identified leakage of contaminated water from cracks in the
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| Unit 2 spent fuel pool (SFP), and subsequently discovered tritium contaminated ground water, about 200,000 pCi/L, in a monitoring well located in the Unit 2 transformer yard. Upon
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| discovery of this condition, the licensee initiated extensive efforts to characterize the nature and
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| source of the ground-water contamination. Efforts included the installation of a series of
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| instrumented monitoring wells, comprehensive
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| hydrological and geophysical assessment of the
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| site, engineering efforts to determine the source of contamination, and enhancements to onsite
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| and offsite radiological environmental monitoring.
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| Extensive efforts were also made by the
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| licensee and NRC to keep members of the public and interested local, state, and federal
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| stakeholders informed of progress and developments in the site characterization, and plans to
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| effect resolution of the ground-water contamination.
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| Onsite ground-water tritium concentrations have been measured as high as about
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| 600,000 pCi/L in the immediate vicinity of the Unit 2 SFP. Strontium-90 contamination has also
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| been identified in ground water in the vicinity of the Unit 1 decommissioned facility which has
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| been in SAFSTOR since 1974. The current hydrological assessment indicates that ground water is likely migrating into the Hudson River. A conservative radiological assessment for the
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| maximally exposed individual indicates that the dose consequence would be about 0.01 millirem
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| per year (i.e., about 0.1 percent of ALARA criteria for nuclear plant design objectives and
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| limiting conditions for operation).
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| NRC Inspection Report 50-247/2005-11, dated March 16, 2006 (ADAMS Accession No.
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| ML060750842), documented the results of an NRC special inspection that was conducted to
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| review and assess the events and circumstances in this case. While the inspection reached
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| important safety conclusions, significant licensee performance deficiencies were not identified.
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| However, NRC inspection activities are continuing to review the licensee efforts and progress to
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| support a final regulatory conclusion.
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| ==BACKGROUND==
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| NRC requirements related to the radioactive liquid effluents include:
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| 10 CFR 20.1301(a)(1) - requires that each licensee conduct operations so that the total effective
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| dose equivalent to individual members of the public from the licensed operation does not
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| exceed 100 millirem (1 mSv) in a year.
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| 10 CFR 20.1302 - requires licensees to perform appropriate surveys in unrestricted areas and
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| controlled areas to demonstrate compliance with dose limits for individual members of the
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| public.10 CFR 20.1501 - requires, in part, that licensees conduct surveys that are reasonable under
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| the circumstances to evaluate the concentrations or quantities of radioactive material and the
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| potential radiological hazards.
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| 10 CFR Part 50, Appendix I, Section II.A - establishes the design objectives and limiting
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| conditions for operation to meet ALARA criteria such that the calculated annual total quantity of
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| all radioactive material above background released to unrestricted areas will not result in an
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| estimated annual dose or dose commitment from li
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| quid effluents in excess of 3 millirems to the
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| total body or 10 millirems to any organ.
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| 10 CFR Part 50, Appendix A, Criterion 64 - requires, in part, that a means be provided for
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| monitoring effluent discharge paths, and the plant environs for radioactivity that may be
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| released from normal operations. To meet this
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| regulation, licensees implement a Radiological
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| Environmental Monitoring Program (REMP) wh
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| ich provides for ground-water monitoring.
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| However, the REMP program is designed to validate the results of the licensee's normal
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| radioactive gaseous and liquid effluent release programs for dose assessment in the
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| Unrestricted Area. Consequently, the data from the REMP program may not provide a full
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| understanding of the extent, types, and movement of potentially undetected radioactive
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| contamination in onsite ground water within the Restricted Area. NRC Regulatory Issue
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| Summary 2002-02, "Lessons Learned Related to Recently Submitted Decommissioning Plans
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| and License Termination Plans," dated January 16, 2002, provides additional information in this
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| regard (ADAMS Accession No. ML013510432).
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| 10 CFR 50.75(g)(1) - requires, in part, that each licensee keep a record of spills or other
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| unusual occurrences involving the spread of contamination in and around the facility or site.
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| These records must include any known information on identification of involved nuclides, quantities, forms, and concentrations. Such documentation in a decommissioning record file is important to provide a database for site characterization during decommissioning, as well as, providing support for public and worker dose assessments. NUREG-1757, "Consolidated
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| [Office of Nuclear Material Safety and Safeguards] NMSS Decommissioning Guidance,"
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| provides guidance on decommissioning record keeping (ADAMS Accession No. ML032530410).
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| 10 CFR 50.72 - requires a four-hour report to NRC Operations Center when any event or
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| situation occurs, related to protection of the environment, for which a news release or
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| notification to other government agencies has been or will be made.
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| ===Related Generic Communications===
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| NRC Information Notice 2004-05, "Spent Fuel Pool Leakage to Onsite Ground Water," dated | |
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| March 3, 2004, (ADAMS Accession No. ML040580454) discussed SFP leakage at Salem
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| Station Unit 1 to the onsite ground water, including potential impact to the public and workers, and the structural integrity of the SFP. The NRC noted that leaks can develop in SFPs and go
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| undetected for long periods of time absent appropriate monitoring, resulting in the
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| contamination of onsite ground water and the potential for undetected, unevaluated releases of
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| radioactivity to an unrestricted area.
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| ==DISCUSSION==
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| NRC reviews to-date have identified the following important points associated with ground-water
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| contamination events: 1. Leakage from structures, systems, or co
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| mponents that contain and transport radioactive
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| fluids can contribute, over long periods of time, to extensive ground-water contamination.
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| This leakage may not be easily detectable due to small leakage rates or because the
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| area near the point of leakage is not subject to routine radiological monitoring. Leakage
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| from underground piping at Braidwood released substantial quantities of contaminated
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| water to onsite ground water. Representative sampling and analysis of onsite ground
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| water may be the only viable method to detect this leakage and the subsequent
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| migration of the contamination, particularly for subsurface leakage (e.g., buried pipe
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| leakage).2.Existing NRC regulations do not explicitly mandate routine onsite ground-water
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| monitoring in the Restricted Area during facility operations. If the contamination is
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| detected by environmental monitoring at or beyond the site boundary under the REMP,
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| extensive contamination may have already
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| occurred that could have been contained if
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| detected sooner. Further, although licensees may be sampling onsite drinking water as
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| part of its REMP, this water may originate from deeper hydro-geologic units not affected
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| by contamination of the shallow water table hydro-geologic unit.3.The identification of onsite contamination may serve as an early indicator of degradation
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| of onsite structures, systems, or components or the need for maintenance, particularly
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| degradation caused by boric acid. 4.The principal screening method of detecting leakage at reactor sites is sampling and
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| analyses for tritium contamination. Ho
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| wever, other analysis methods can detect radioactive gamma emitters, and consideration should be given to performing analyses
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| for typical hard-to-detect radionuclides. These nuclides can consist of both fission or
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| activation products that may include Nickel-63, Iron-55, Strontium-90, transuranics, and
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| others. While initial analyses may conclude the absence of gamma emitters and hard-
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| to-detect radionuclides, long-term migration may subsequently result in the transport of
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| contamination to downstream locations. Further, a working knowledge and
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| understanding of onsite hydrology would aid
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| development of monitoring strategies, sampling plans, and selection of individual sampling locations.
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| 5.Licensees typically establish onsite ground-water monitoring and sampling programs in
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| response to known, identified structure, system, or component leakage. Once the
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| source of the leakage is repaired, it is important to objectively evaluate whether it is
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| appropriate to terminate these supplemental onsite monitoring and sampling programs, as the onsite monitoring and sampling programs may be the only reliable method for
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| detecting repeat occurrences in a timely manner, particularly for subsurface leakage. In
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| the case of the Dresden facility, the onsite ground-water monitoring wells that had been
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| installed for previous leakage incidents were instrumental in identifying the 2006
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| leakage, which enabled a more timely identification and limited the extent of the
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| contamination.
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| 6.SFP leak detection may require special te
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| chniques since SFPs have an evaporation rate
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| up to several hundred gallons per day. This evaporation rate may mask small leaks in
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| the SFP liner and make small leakage rates difficult to detect by evaluation of make-up
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| rates within a water balance calculation. Consequently, licensees who are not closely
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| evaluating the potential for leakage, including through-wall and/or floor leakage, may not
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| detect such leakage. Further, the leakage may be from SFP fuel transfer tubes and may
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| only occur during refueling outages. Because there is considerable water transfer
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| activity during refueling outages, small leakage rates may not be readily apparent during
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| make-up or transfer operations. Other considerations include:*Licensee experience with onsite and offsite ground-water contamination as a
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| result of SFP leakage varies significantly. Some licensees have identified large
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| areas of onsite ground-water contamination due to SFP leakage. It is important
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| to be aware that small, long-term, undetected leaks from SFPs can result in
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| extensive areas of contamination. *Due to the difficulty in detecting single small leaks or small leaks from different
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| locations, particularly those that occur over long time periods, corrective actions
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| may involve management of leakage (e.g., collection and treatment) rather than
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| leak repair.*Some licensees have not evaluated the capability of their SFP leak detection
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| systems to detect small leaks. Leakage trending and tracking programs can
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| supplement leakage detection systems and provide an indication of changes in
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| apparent leakage rates. Any unexplained change in leakage rates, including a
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| reduction in leakage rates, should prompt further evaluation.*Clogging of SFP telltale drain systems could result in undetected SFP leakage.
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| Maintenance and cleaning programs for SFP telltale drain systems ensure viable
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| drain paths remain open. Alternate methods to look for leakage are available for
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| facilities without SFP telltale drain systems. .Leakage from facility structures to the environment can itself become a source of
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| contaminated in-leakage (back into the facility) at another location. Because stations
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| have facilities and rooms below grade level, it is not uncommon for ground water to leak
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| into the facilities. It is important to evaluate unexpected in-leakage to determine if it is
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| contaminated ground water using radio-analytical and chemical analysis (e.g., boron).8.Radioactive contamination of subsurface rock, soil, or ground-water contamination can
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| impact decommissioning decisions. Remediation at the time of discovery in some
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| instances could prevent significant migration to large subsurface areas that could
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| complicate and increase the cost of decommissioning. Hydrogeology studies and the
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| addition of onsite monitoring wells should be considered to identify ground-water flow
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| patterns, support knowledge of the location and extent of contamination, to quantify
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| contaminant migration, and to support decision-making for potential remediation
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| measures. These studies can also support an estimation of future decommissioning
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| costs. 9. NRC's inspection program identified that there is an apparent wide variation in licensee
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| knowledge in the requirement to document the ground-water contamination issues
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| consistent with all parts of 10 CFR 50.75(g)(1) for the decommissioning record file.
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| Such documentation is important to provide a database for site characterization during
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| decommissioning, as well as, providing support for public and worker dose
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| assessments.
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| CONCLUSION
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| Although NRC regulations require licensees to make surveys, as necessary, to evaluate the
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| potential hazard of radioactive material released in order to assess doses to members of the
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| public and workers, the above examples indicate that undetected leakage to ground water from
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| facility structures, systems, or components can occur; resulting in unmonitored and unassessed
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| exposure pathways to members of the public.
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| ===GENERIC IMPLICATIONS===
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| This information notice provides a timely means of communicating to licensee senior
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| management information regarding ground-water c
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| ontamination. To address this important
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| issue, NRC is actively pursuing rulemaking to revise 10 CFR 20.1406, "minimization of
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| contamination," and its supporting guidance, as well as changes to NRC inspection and
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| enforcement guidance. These ongoing NRC efforts are part of the NRC's Integrated
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| Decommissioning Improvements Plan (ADAMS
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| Accession No. ML050890059) to resolve issues
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| described in SECY-03-0069, "Results of the License Termination Rule Analysis" and its staff
| |
| | |
| requirements (ADAMS Accession Nos. ML030840302 and ML033210595). A publically
| |
| | |
| available NRC memorandum dated September 23, 2005, provides the results of an initial NRC
| |
| | |
| study of ground-water contamination at decommissioning sites (ADAMS Accession No.
| |
| | |
| ML052630421).
| |
| | |
| ==CONTACT==
| |
| This information notice requires no specific action or written response. If there are any questions about this notice, contact one of the persons listed below or the appropriate project
| |
| | |
| manager in the Office of Nuclear Reactor Regulation (NRR) or Office of Nuclear Material Safety
| |
| | |
| and Safeguards./RA//RA/Charles L. Miller, DirectorHo K. Nieh, Acting DirectorDivision of Industrial and Medical Nuclear SafetyDivision of Policy and Rulemaking
| |
| | |
| Office of Nuclear Material SafetyOffice of Nuclear Reactor Regulation
| |
| | |
| and Safeguards
| |
| | |
| Technical Contacts: Timothy Frye, NRRMarvin Mendonca, NRR301-415-9676301-415-2191
| |
| | |
| E-mail: tjf@nrc.gov
| |
| | |
| E-mail: mmm@nrc.gov
| |
| | |
| John White , RIJames Shepherd, NMSS610-337-5114301-415-6712
| |
| | |
| E-mail: jrw1@nrc.gov
| |
| | |
| E-mail: jcs2@nrc.gov
| |
| | |
| Steve Orth, RIIIThomas Nicholson, RES630-829-9827301-415-6268
| |
| | |
| E-mail: sko@nrc.gov
| |
| | |
| E-mail: tjn@nrc.gov
| |
| | |
| ===Ronald Nimitz, RI===
| |
| 610-337-5267
| |
| | |
| E-mail: rln@nrc.gov
| |
| | |
| ML030840302 and ML033210595). A publically
| |
| | |
| available NRC memorandum dated September 23, 2005, provides the results of an initial NRC
| |
| | |
| study of ground-water contamination at decommissioning sites (ADAMS Accession No.
| |
| | |
| ML052630421).
| |
| | |
| ==CONTACT==
| |
| This information notice requires no specific action or written response. If there are any
| |
| | |
| questions about this notice, contact one of the persons listed below or the appropriate project
| |
| | |
| manager in the Office of Nuclear Reactor Regulation (NRR) or Office of Nuclear Material Safety
| |
| | |
| and Safeguards.RA//RA/Charles L. Miller, DirectorHo K. Nieh, Acting DirectorDivision of Industrial and Medical Nuclear SafetyDivision of Policy and Rulemaking
| |
| | |
| Office of Nuclear Material SafetyOffice of Nuclear Reactor Regulation
| |
| | |
| and Safeguards
| |
| | |
| Technical Contacts: Timothy Frye, NRRMarvin Mendonca, NRRJohn White , RI301-415-9676301-415-2191610-337-5114
| |
| | |
| E-mail: tjf@nrc.gov
| |
| | |
| E-mail: mmm@nrc.gov
| |
| | |
| E-mail: jrw1@nrc.govJames Shepherd, NMSSSteve Orth, RIIIThomas Nicholson, RES301-415-6712630-829-9827301-415-6268
| |
| | |
| E-mail: jcs2@nrc.gov E-mail: sko@nrc.gov
| |
| | |
| E-mail: tjn@nrc.gov
| |
| | |
| ===Ronald Nimitz, RI===
| |
| 610-337-5267
| |
| | |
| E-mail: rln@nrc.gov
| |
| | |
| ===DISTRIBUTION===
| |
| : IN FileADAMS ACCESSION NUMBER: ML060540038OFFICEIHPB:DIRSTech EdBC:IHPB:DIRSD:DIRSNAMESGarryHChangTFryeMCase
| |
| | |
| DATE06/14/200603/01/200606/14/200606/15/2006OFFICEBC:PRTA:DPRRDS:DWM:NMSSDRS:RIDRS:RIIINAMEBThomasCCraigJWhiteSOrth
| |
| | |
| DATE06/19/200606/21/200606/16/200606/16/2006OFFICELA:PGCB:DPRFCSS:UPSDPR:PGCBBC:PGCB:DPRNAMECHawesSCohenDBeaulieuCJackson
| |
| | |
| DATE06/26/200606/16/200606/28/200607/05/2006OFFICED:DIMNSDFERR:RESD:DPR (A)NAMECMillerNChokshiHNieh
| |
| | |
| DATE06/20/200606/19/200607/10/2006}}
| |
| | |
| {{Information notice-Nav}}
| |