A Regulatory Analysis and Perspective Regarding Leaks from Buried and Underground Piping at Nuclear Power Plants

Operating experience at nuclear power plants indicates that there have been several leaks of buried or underground piping.  Some of these leaks have resulted in the introduction of tritiated water into the groundwater beneath the plant.  None of these leaks has adversely affected the ability of a power plant to safely shut down or to remain in a shut down condition.  None of these leaks has resulted in the exposure to workers or the public to radiation in excess of regulatory limits.  While leaks to date have not resulted in significant risk to the public, stakeholder interest in this subject is significant.  This paper considers the potential for leaks from buried pipe to be more significant than have previously occurred.  This paper also considers the technical evidence and regulatory framework which is being used by the Nuclear Regulatory Commission in the review of this operating experience.  This paper will not attempt to provide a final NRC regulatory position concerning leaks from buried piping.