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NEI Teleconference On Inadvertent Radiological Releases in Groundwater

On May 8, 2006, NEI Chief Health Physicist Ralph Andersen conducted a teleconference with journalists on the tritium issue a number of nuclear plants around the country are dealing with currently. A transcript of that call follows:
Transcript of Remarks by Ralph Andersen, NEI’s Chief Health Physicist

Teleconference with Journalists Concerning Voluntary Industry Initiative on Inadvertent Radiological Releases in Groundwater

May 8, 2006
3 p.m. U.S. EDT

ANDERSEN: Good afternoon. NEI’s initiative process involves taking a binding commitment to some course of action. It requires that a super-majority approve it but again, once passed, it obligates everyone to carry out some specified set of actions. And it obviously is very useful for dealing with various regulatory issues where it’s of value that we all undertake to resolve an issue in a standard manner.

This particular initiative was passed by a 100 percent majority. That is, every company voted on and approved the initiative. Therefore the things that I’m about to describe to you are binding on all of our companies. The initiative itself is referred to as our Groundwater Protection Initiative. It is in response to the recent events that involved elevated levels of tritium and other radionuclides in groundwater at some of the nuclear power plants. And it includes several actions.

The objectives of the initiative are: 1) to improve the management of situations involving inadvertent radiological releases into the groundwater, and 2) to enhance trust and confidence on the part of local communities, states, the Nuclear Regulatory Commission and the public in our commitment and practices in maintaining a high standard of public radiation safety and protection of the environment. Most specifically it involves: 1) actions to communicate pro-actively on issues associated with inadvertent releases in the groundwater, and 2) actions intended to assure timely detection and effective response to those situations so that we prevent migration of materials off-site and are able to quantify impacts for decommissioning planning.

The commitments that are specific in the initiative are: 1) by July 31st that every site will have in place a site-specific action plan with a set of actions that will assure timely detection and effective response to situations involving inadvertent releases in the groundwater; and 2) to expand the scope of our existing requirements for notification and reporting such that we will document all of our on-site and off-site groundwater sample results on an annual basis so that additionally and on an annual basis we would document any significant on-site leaks or spills of groundwater.

Thirdly, that we would provide a 30-day report to the Nuclear Regulatory Commission on a voluntary basis of any water sample results that exceed the criteria that we currently have in our license that are only applicable to off-site monitoring. So what we would do is expand that program to include on-site monitoring results as well. That’s a publicly available report. Finally, that we would notify our state and local officials – and it would need to be determined exactly who that is at each site – whenever we have a situation involving either a report of elevated samples of radioactivity in groundwater, either on-site or off-site, or of any significant spills or leaks of material into groundwater.

In short, that’s the initiative. These are all actions that go beyond what we’re required to do in regulation. Again, by undertaking these in the form of an initiative, they essentially would be binding and would continue to be a part of our common practice in the future. With that I think I’d like to just step back and invite you to ask any questions.

QUESTION: On the fourth criterion on notifying state and local officials, is there any time frame specified in the initiative for how soon these officials need to be notified?

ANDERSEN: There isn’t at this point, but we are developing detailed guidance for how we will implement these, and in that detailed guidance we will specify that time frame. Nominally it’s intended that it would be in the space of a couple of working days – sufficient time to allow people to verify the results of the sample and so forth. But this would really be a heads-up communication in advance of the formal, documented reporting that we would do in follow-up. But we’re looking at something on order of a couple of working days, but we will specify that in the detailed guidance that will follow.

QUESTION: And what’s the time frame for the release of the guidance?

ANDERSEN: They’re going to have an industry workshop to support implementation of the initiative on June 8th, so that’s where we would publish that guidance and discuss it and at that time we would certainly be disclosing that publicly so you’d understand what to expect.

QUESTION: Can you tell me how many members you have and how many plants this policy might affect?

ANDERSEN: The policy affects 103 operating nuclear power plants, soon to be 104. I don’t have at my fingertips the exact number of sites, but it’s in the low 60s – 64 sites. And with mergers and acquisitions, how many companies do we have today? I don’t have a solid number for you there, and that’s really a function of companies over the past years having merged. But I think it is on the order of about mid-20s. [READER: The 103 reactors operating at 64 sites in 31 states are operated by 27 companies.]

QUESTION: Can you give us a pretty clear and simplistic definition of the difference between what you all are going to be doing as an industry versus what you are required to do, if you could enumerate that?

ANDERSEN: Currently under NRC regulations we are required to report releases that exceed regulatory limits. We are required to report annually in a written report – what we call abnormal releases, which are releases off-site of material where the release itself in some way wasn’t planned and monitored properly – so we’re required to report that. Additionally we’re required to report elevated sample results above specified criteria for off-site samples. That’s what we currently have on the books as being required to be reported.

What this would add to that is that we would also be reporting all of the results of our on-site monitoring. We would also be reporting spills and leaks or other kinds of inadvertent releases that occur on-site but didn’t get off-site, which today are not required to be reported. Additionally we would be making that early notification to state and local officials, which currently is not part of our required monitoring framework.

Now obviously many sites do such informal communication, but this would basically lock us in to also make sure that the local communities and the states are apprised of those well in advance of their showing up in formal reports.

QUESTION: In the case of Braidwood, I just read a recent NRC report that said that in 1998, a three-million-gallon spill of tritiated water, that these people at the plant weren’t even aware that this water contained tritium at the time. Will there be some sort of effort to make sure that all the plant operators are aware of what releases could contain radioactive material, and will there be any type of standard year-round monitoring of, for example, wells, warning systems on breaker valves and things of that nature that will ensure that these things are actually recognized when they happen?

ANDERSEN: Yes. Certainly I can’t speak to the specifics of the situation at Braidwood, but generically within this initiative, the meat and potatoes side of the initiative – you know we talked previously about the reporting and the notification – are actually the action plans that people need to put into place. That goes to the types of things you’re talking about.

Specifically it involves every site doing a detailed assessment and in many cases a reassessment of the potential sources and pathways for inadvertent liquid and gaseous releases. It requires that each plant do a detailed review of site history to make sure that we’ve dealt with any inadvertent releases we’ve had in the past properly – that we’ve documented those properly, analyzed them properly and so forth. That we look at the current site geo-hydrology, make sure that we’ve got a very up-to-date assessment using the most modern methods because, obviously – having licensed the plant in some cases 10, 20, 30 years ago – there may have been advancements in the technology that would be worthwhile to incorporate now. Additionally to look at our current on-site, particularly, our on-site groundwater monitoring again to make sure that it reflects best practices and the most up-to-date understanding of the hydrology.

Part and parcel of that, actually the name of the workshop, is “Industry Lessons Learned Workshop.” The big emphasis overlying all this is to learn from our experience including the Braidwood experience. In fact, Braidwood and some of the other plants that currently show up on the NRC website as having tritium in their groundwater will be the very first part of the program to share with us very candidly what they’ve learned from their experiences so that we can make sure that we don’t repeat things.

So the answer is solidly yes and, again, that’s really the meaty part of this initiative. That’s the one that will carry on for a long time to come.

QUESTION: Is there any remediation or call for remediation or any guideline at all regarding remediation and what you all are doing now?

ANDERSEN: One of the things that we’re going to take on coming out of the Lessons Learned Workshop is to look at whether we can standardize industry criteria for monitoring, response and remediation. The remediation decision is one that rests under normal circumstances upon whether it makes sense to pursue a clean-up and to what extent to pursue it – during operation of the plant or whether it’s something to defer until decommissioning of the plant.

But I would say that we’re continuing to evolve our own awareness and our own understanding of the timing and the involvement in our local communities and so forth in that kind of decision-making. That’s going to have to be part of a process that we work out.

But the starting point I guess I would like to add, and it goes to an inference in your question, in no cases do we believe that there’s a whole lot of situations out there that people aren’t aware of. For many, many plants this will be a forward-looking initiative. They’ll bring an entirely different perspective to this type of situation should it occur at their plant in the future. You’re seeing a change in culture here as well as a change in practice.

QUESTION: In terms of site-specific follow-up plans that you have just spoken about, is there a time frame within the initiative by which these plans need to be developed and put in place?

ANDERSEN: As far as the detailed guidance that’s necessary to implement the initiatives, obviously that needs to be in place by July 31st because that’s the date we’ve committed to have our action plans in place and to have our reporting protocol in place. As far as follow-on action from a site-specific basis, that’s really an artifact of the site-specific circumstances and the action plan.

What I would expect is that as a result of doing these assessments that I referred to, that each plant then will have its own follow-on schedule for implementing changes in their programs and their practices. For instance, that could take the form of doing additional on-site monitoring. However, there might be a plant right up the road that has a very robust on-site monitoring program, but it could change the way that they respond to an inadvertent release should they have one or to identifying groundwater contamination.

It’s really going to vary from plant to plant because current practices differ from plant to plant. What one would expect is that following July 31st, that each plant will have its own action plan which inevitably is going to have actions that extend over some period of time, and those are going to be appropriate to the plant specific circumstances.

QUESTION: But each NEI member company is going to have these actions plans at least in place by July 31st?

ANDERSEN: That’s correct.

QUESTION: You mentioned a culture change. Is there some recognition now that tritium is more of a concern than perhaps it was perceived to be a few years back?

ANDERSEN: I’m going to offer my own perspective as a health physicist, and I don’t think it’s just restricted to tritium. Given that nuclear power plant operators and especially the health physicist or radiation safety professionals working at the nuclear power plants have a very informed perspective about radiation, we tend to prioritize things on the basis of their significance to health and safety, and tritium is included in that. Up to now I would say that when we’ve looked at circumstances, even including the situation at Braidwood, we tend to scale that against existing radiation that naturally occurs in the environment. We tend to scale it to the safety limits that have been established by the federal government. We tend to scale it to standards of excellence that we use for our practices to maintain levels of radioactivity well below those standards. Our response in the past has been we almost know too much about the subject. And I don’t think we ignore it; it’s just that we give it a priority, and we take actions based on dealing with first things first.

I think what’s changing now is an appreciation that over these many years that we’ve operated is that our public interest and our public involvement in industries in and around communities has really increased. People want to know more to start with. They feel they have a right to know more, and they want to know more. Additionally, they want their questions answered. Their concerns about tritium aren’t satisfied perhaps with statements about, ‘Well, this doesn’t pose a significant health and safety issue.’ They really want to look for, ‘Yes, but what are you doing about it?’ and ‘What does this mean? What’s the perspective on it?’

That’s what I mean by our culture change. We are coming to recognize that our public has changed over the last 20 years than the public that was there when we licensed the plants and had very intense public involvement at that time.

QUESTION: Since these things, a lot of them are voluntary; you’ve got voluntary state and local official communications; you’ve got voluntary 30-day reports to NRC, is this really going to go to the length you want it to go in terms of resolving the problems? I mean, this doesn’t seem to sort of go as far as the legislation that’s been proposed.

ANDERSEN: Right. I’m glad you asked it that way because it actually reminds me that even in house here people keep asking me to be very clear on what we mean by voluntary. It’s voluntary on the part of the industry in that no one forced us to make the commitment to do these things. But having made that commitment and having undertaken this formally as an initiative through our binding process is essentially [conceptually] a contractual obligation between our members. It’s not voluntary for us now, so it’s voluntary only in the sense that it’s not required by federal regulation or legislation. But this is not the first initiative we’ve ever undertaken. Once they’re in place, they’re in place and with regards to our regulator, the Congress and anybody else we deal with, there’s no question that that’s an expectation that we are obligated to fulfill into the future.

QUESTION: Will plants then be willing to make these plans so-called regulatory commitments to the NRC since they already obligated themselves to follow them?

ANDERSEN: Well, they are a commitment in that sense.

QUESTION: It’s a term of art within the NRC whereby a company communicates what they call a regulatory commitment in writing to NRC and they’re therefore obligated to a specific process to follow it, and the NRC can oversee that.

ANDERSEN: Right. I don’t want to speculate on that because this is a process question that, as a health physicist, I’m not a licensing person. What I would say is this: typically those commitments those voluntary commitments become then licensing commitments, are typically in response to a particular regulatory requirement, so whether this plays out exactly that way I’m not sure. I guess the best I can say is check back in about 45 days, and I can tell you how we’ve locked this in.

But I’ll say this, tomorrow we’re going to meet with the NRC in a public meeting and commit our industry to doing this. Whether it’s writ on a piece of paper that the lawyers can work with or not, I believe that our industry and anybody else who attends that meeting is going to understand that we either do it or we’re going to have a serious problem. The reason is because NRC certainly will be taking into consideration our initiative when they review whether they need to do other things in terms of regulations or requirements. Whether it turns into the exact form you described or not, I don’t know. But for practical purposes it is that after nine o’clock tomorrow morning.

QUESTION: You said that you all have a variety of these initiatives that are basically no longer voluntary for your members. Could you give us a couple examples?

ANDERSEN: One initiative involved what we call the personnel access data system, which was actually our very first initiative that involved a system of record-keeping between the plants that facilitated a much better process for doing background checks and reliability checks for people to gain access to working in the plants. That initiative was undertaken many, many years ago and actually in the post 9-11 environment we actually upgraded that initiative considerably, such that today it really serves as the backbone to our ability to have workers move from plant to plant and be sure that we’re completely in a position to verify and validate their reliability and trustworthiness for working in the plants. That was actually a formal industry initiative using this process.

Another initiative that we have has to do with materials that we use in our system. This has to do with – well, we have certain stainless steel type materials matched up in the plants where we found over time that we needed to upgrade our inspection processes to identify situations where you have some degradation over time associated with those materials. Again, we came up with a common standard approach to it that went beyond the regulations, and then we committed to that inspection process and then NRC took that into account when they re-evaluated their regulations for overseeing that activity.

QUESTION: Is any of this in order to basically set your agenda for what you want in the tritium collection as opposed to being told what to do by the NRC?

ANDERSEN: Oh yes, definitely. On any given day I will tell you this – that the people who probably are the best experts on what needs to be done to resolve an issue are the people who are doing the hands-on work at the plants. Right behind that are your regulators who are observing them doing it.

I would say it this way: we would always prefer to propose our own solutions to the problem with a better understanding of how we can integrate those into our plant operations, than to let the regulator take their best shot at what will satisfy the requirement but may not efficiently work in with everything that we do. I’ll tell you this, when we see a problem we’d rather jump out of the box and try to solve it working with the regulator and let them oversee our solution and basically build it into their regulatory process than the other way around.

QUESTION: So no question it’s at July 31st? Basically you wanted it done before they…?

ANDERSEN: Oh yes, without any question. We owe them that if you think about it. I’d rather not let them come out of the box first and then second-guess it and say, ‘Well, here’s what you really should have thought of doing.’ I’d rather it say, ‘This is our best shot; take a look at it, evaluate it critically. If you see something else you still need to do by all means but factor in what we’re doing.’

QUESTION: Does NEI have a position right now on the federal legislation?

ANDERSEN: The issue that we have with the legislation, and we’ve communicated that to the staff of the various sponsors of the legislation, is that as written, it would be difficult to implement. There’s some terminology in the legislation that is not abundantly clear on what’s intended or what’s not. I will say this – that part of the criteria in the legislation actually are already in NRC requirements and that’s, as I mentioned previously, to report situations where you actually exceeded a regulatory limit. The other part that dealt with unplanned releases would need a lot of work to translate into a law of the land and then ultimately into regulations. What I would say is what we’re proposing to do actually goes beyond what is contemplated in the legislation.

QUESTION: Just to clarify, is this the Illinois assembly legislation or the federal legislation?

ANDERSEN: Actually, I’m glad you asked that because I’m not personally familiar with what was in the Illinois assembly legislation. I was referring to the bills that had been placed in the (U.S.) House and the Senate.

This transcript was posted here on July 20, 2006 in response to a Union of Concerned Scientists statement that was issued on July 19, 2006.


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