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 technical evidence and regulatory
framework which is being used by the Nuclear Regulatory Commission in its review of this
operating experience. This paper will not attempt to provide a final NRC regulatory position
concerning leaks from buried piping.