ML061000625

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E-mail from D. Croulet of Entergy to Various, Regarding Project Plan for Wells
ML061000625
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/05/2005
From: Croulet D
Entergy Nuclear Operations
To: Noggle J
Division of Reactor Safety I
References
FOIA/PA-2006-0081
Download: ML061000625 (45)


Text

Jame- ~Nooole - FW: Project Plan for Wells

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From: "Croulet, Donald" <dcroule~entergy.co, To: "Conroy, Pat" <PConroy@entergy.cop>, Jones, T. R." <tjones2@entergy.com>, TCox, Mark R" <mcox90Oentergy.com>, "'jdn~nrc.gov"' <jdn@nrc.gov>

Date: 12/5/05 9:01AM

Subject:

FW: Project Plan for Wells You may have received some of this information from me already with the exception of the Engineering Request (which is the attached pdf document below).

From: Lavera, Ron Sent: Thursday, December 01, 2005 3:56 PM To: 'Ibrice~gw.dec.state.ny.us'; Croulet, Donald

Subject:

Project Plan for Wells Mr. Rice I understand that you were looking for some information on the Project Plan for the wells.

Please see the attached.

<<DRN-05-05409.tif>> <<16453.pdf>> <<DRN-05-05385.tif>> <<DRN-05-05395.tif>>

Fon LaVera RLaVera~entergy.com <mailto:RLaVera~entergy.com>

914-736-8433 914-736-8419 FAX Indian Point 3 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 3 P.O. Box 308 Buchanan, NY 10511-0308 ii i' 3$ JI,

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ATTACHMIENT 9.2 ER COVER SHEET (TN PICAL)

F Sheet 1 of 1 ER (Request)# I IP2-05-26056 IRevision No. 0

Title:

INSTALLATION OF NEW MONITORING WELLS FOR IP2-SFP Base ER No. IP2-05-26056 Linked i'R(s). NONE Prioril Pae1 of 1 ER Response No. ER-05-2-113

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1. . - I-riginator: R.F. Evers Date: 10-27-05 Ext: 6689 Dept.: Design Engineering - Civil / Structural ystem l[): N/A Date Required: November 15,2005 omponent ID: MW-31 Through MW-38 Outage [QYes: ZNo:

Problem j Proposed Solution/Justification:

SEE SECTION 1.2 l$SLS^CATI WNEtNEERlNGq ESPRONEW- ON _

Quality C~lassification: NON-CLASS "A" ER Response Type: El Reply O Administrative EO Engineering Evaluation 0 Commercial 0 Nuclear EO Inter-Discipline Problem Description/Proposed Solution/Problem Resolution (Attach additional sheets as required):

SEE SECTION 1.3

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0 Desicin Reviewer: P. C*VV,&,-t  ; '//611rl I Date:

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C9 Operations: J. Etzweiler 5 ( Date: ,./'t/?oeC7 0:3 Construction Services: , an Date: ,I_*X_

A 0 Planring: D.Norris Date: //2/ v$&_

14 0 Training: C.Hayes Date: t 0 Training (Simulator): R. Robenstein / Date:

0 Rad Support: R.LaVera Date:

Chemistry: J. Peters Date:

Environmental: D. Gray CZ Date://--

0 Configuration Management:E. tq o Date: /

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Responsible Engineer: R.F. Evers ' 7 , Date: -

Responsible Engineering Supervisor: R.S. Drake z Xgmf 76Date: tI/ loil EngineeringManager (if required) j- Date: l El E Engineering Director (if required) Date:

El GM Operations (if Required, for Nuclear Changes) Date:

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ER RESPONSE NO. ER-05-2-113 ENN-DC-l 15 Rev 5 ltJergy NUCLEAR CHANGE RESPONSE PAGE I OF 13 TABLE OF CONTENTS Section Description Paze

1.0 DESCRIPTION

. 2 1.1 Structures, Systems Or Components . 2 1.2 Re ison For Change . 2 1.3 Design Objective To Resolve Problem . 3 1.4 Components Listed . 3 2.0 DOCUMENTS . 4 2.1 List Of Affected Documents. 4 2.2 Re:'erence Documents. 4 3.0- EVALUATION / DESIGN

SUMMARY

.............................. a 6 3.1 Evaluation Resolution. 6 3.2 Design Basis Discussion ................  ; 7 3.3 Design Input Considerations. 8 3.4 Relationship With Other Modifications . 8 3.5 Operating Experience (OE) Review . 8 3.6 Design Margin Analysis. 8 4.0 IMPACT ON CURRENT OPERATIONAL BASIS. 8 5.0 ENGINEERING INSTRUCTIONS NECESSARY TO IMPLEMENT THE CHANGE 9 5.1 General Requirements ................ 9 5.2 Monitoring Wells No. MW-3 1 And No. MW-32. 10 5.3 Monitoring Wells No. MW-33 And No. MV-35. 10 5.4 Monitoring Wells No. MW-36 And No. MW-38. 10 5.5 Existing Monitoring Well No. U3-T.. . II 5.6 Temporary Installation Of Still Wells . II 5.7 Foreign Material Exclusion Control Requirements. Ii 6.0 ENGINEERING MATERIAL LIST AND VENDOR TECHNICAL INFORMATION 12 7.0 SPECIAL PROCESS REQUIREMENTS. 12 8.0 TE',T AND INSPECTION REQUIREMENTS. 12 9.0 ATrACHMENTS. 12 9.1 Dis ributed For Field Work/Installation. 12 9.2 Not Distributed For Field Work/Installation. 13

A ER RESPONSE NO. ER-05-2-113 ENN-DC-l 15 Rev 5

-:-Entegy NUCLEAR CHANGE RESPONSE PAGE2OF 13

1.0 DESCRIPTION

1.1 Structures. Systems or Components Description Monitoring Wells will be installed in the vicinity of the IP2-FSB, IP2 Transformer Yard Area, Condenser Tube Withdrawal Pit, IP2-TB Loading Bay and east side of the Discharge Canal, near the IP3 Security Command Post. The monitoring wells will provide Entergy the ability to monitor groundwater and evaluate the following:

1.1.1 The source area concentrations of contaminants and the hydrogeology of the bedrock aquifer in the vicinity of the IP2-FSB.

1.1.2 The width of the potential plume, which may emanate from the IP2-FSB and which may be detected in existing Monitoring Well No. MW-I 11.

1.1.3 If contaminants may have entered the backfill around the Discharge Canal-1.1.4 If contaminants may have migrated west of the Discharge Canal 1.1.5 If contaminants may have migrated along the backfill of the Discharge Canal towards the Hudson River.

1.2 Reason For Chance As part of the IPEC Dry Cask Storage Project, a new single failure proof Gantry Crane will be installed within the IP2 Fuel Storage Building (IP2-FSB) to transfer the Holtmc International HI-TRAC to/from the 1P2 Spent Fuel Pool (IP2-SFP). In order to facilitate installation of the North Pedestal Structure and the Steel Ballast Box Foundation, which will support the Gantry Crane, the existing IP2-FSB Truck Bay Floor, EL 80'-O" was removed from service. In addition, the sub-floor bedrock and soil, which is adjacent to the south wall of the IP2-SFP, was excavated to -EL 51 '-0". During recent excavation activities, two hairline shrinkage cracks in the south wall of the IP2-SFP were exposed, which exhibited signs of moisture. One crack, which is located at -EL 61'-O" near the northwest corner of the excavated Truck Bay Area, was observed to be actively discharging water at a rate of -1.5 Liters/Day. Radiochemistry testing indicated constituents found in the discharged water to be generally consistent with water typically associated with the IP2-SFP. This adverse condition is documented in Condition Repcort No. CR-IP2-2005-03557. Currently, there are no available methods to monitor groundwater in the vicinity of the IP2-FSB. As a result, IPEC cannot evaluate the source and extent of the potential leak from the IP2-SFP. In addition, IPEC cannot evaluate the hydrogeology in the vicinity of the IP2-FSB.

ER RESPONSE NO. ER-05-2-1 13 ENN-DC- I 15 Rev 5 Et l NUCLEAR CHANGE RESPONSE l PAGE 3 OF 13 1.3 Design Objective To Resolve Problem Eight (8) groundwater monitoring wells will be installed in the vicinity of the IP2-FSB, IP2 Transformer Yard Area, Condenser Tube Withdrawal Pit, IP2-TB Loading Bay and Discharge Canal, near the IP3 Security Command Post. The locations for the monitoring wells are as follows:

1.3.1 Monitoring Well No. MW-31 will be located near the entrance gate to the Alleyway between the IP2-FSB and the IP2-MOB.

1.3.2 Monitoring Well No. MW-32 will be located -10 FT within the entrance gate to the Truck Alleyway between the IP2-FSB and the IP2-PAB.

1.3.3 Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be located within the IP2 Transformer Yard Area along the west wall of the IP2-PAB. COne monitoring well will be located near the northwest end of the wall, the second monitoring well will be located near the middle of the wall and the third monitoring well will be located near the southwest end of the wall.

1.3.4 Monitoring Well No. MW-36 will be located on the east side of the Discharge Canal within the Condenser Tube Withdrawal Pit, near the southwest corner of the pit.

1.3.5 Monitoring Well No. MW-37 will be located on the west side of the Discharge Canal within the IP2-TB Loading Bay Area, EL 15'-0", between Column Lines 9-1 1 and Column Lines CC3-F.

1.3.6 Monitoring Well No. MW-38 will be located on the east side of the Discharge Canal, near the IP3 Security Command Post. This monitoring well will be located outside the Protected Area Fence, near the point in the Discharge Canal, where it transitions from a rip-rap embankment to a sheet-pile structure.

1.3.7 Two Temporary Still Wells will be located near the Discharge Canal. One well will be located on the west side of the Discharge Canal within the Hudson River and the second well will be located within the Discharge Canal at the south end of the Discharge Canal.

1.4 Components Listed 1.4.1 Components Added Monitoring Wells No. MW-3 1Through No. MW-38.

1.4.2 Components Deleted NONE

a ER RESPONSE NO. ER-05 113 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE 4 OF 13 2.0 DOCUMENTS 2.1 List Of Affected Documents 2.1.1 Document Revision Notices (DRNs)/Preliminary Design Documents (PDDs)

Specific Document Information Document Required For Doc. No. Rev Title Inst. RTS Post RTS DRN-05-05385 0 IP2 Ground Water Sampling LI (400936) Monitoring Well Details DRN-05-05395 0 IP2 Ground Water Sampling 123 z (400937) Site Monitoring Well Locations DRN-05-05409 0 IP2 Ground Water Sampling E0 O

(400938) Temp Monitoring Well Details 2.1.2 Documents Affected By This ER Without Attached DRNs/PDDS 2.1.2.1 MAXIMO Database - Need to update the information for Monitoring Wells No. MW-31 through No. MW-38. The database needs to be revised Post-RTS 2.1.2.2 Future sampling procedures for Monitoring Wells No. MW-31 through No. MW-38 will need to be developed by the responsible IPEC Department.

2.1.3 Documents Voided By This ER NONE 2.1.4 Design Change Documents Affected By This ER NOT APPLICABLE 2.2 Reference Documents Where no specific date or revision is identified within this ER or otherwise noted on the Entergy Drawings, the latest revision, edition or addendum in effect at the time of construction shall apply. The following industry standards will be invoked, as required:

2.2.1 American National Standards Institute (ANSI) Documents 2.2.1.1 ANSI N45.2.2, "Packaging, Shipping, Receiving, Storage & Handling"

M ER RESPONSE NO. ER-05 113 ENN-DC- 115 Rev5

' Enter NUCLEAR CHANGE RESPONSE PAGE 5 OF 13 _

2.2.2 American Society of Testing Materials (ASTM) Documents 2.2.2.1 ASTM A53, "Standard Specification For Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded And Seamless" 2.2.2.2 ASTM A106, "Standard Specification For Seamless Carbon Steel Pipe For High-Temperature Service" 2.2.2.3 ASTM A312, "Standard Specification For Seamless, Welded, And Heavily Cold Worked Austenitic Stainless Steel Pipes" 2.2.2.4 ASTM D1784, "Standard Specification For Rigid Poly(Vinyl Chloride)

(PVC) Compounds And Chlorinated Poly(Vinyl Chloride) (CPVC)

Compounds" 2.2.3 Code OfFederal Regulations (CFR) Documents 2.2.3.1 CFR Title 29, Part 1910 (29CFR1910), "Occupational Safety And Health Standards" 2.2.3.2 CFR Title 29, Part 1926 (29CFR19 10), "Safety And Health Regulations For Construction" 2.2.4 Entergy Nuclear (Entergy) Documents 2.2.4.1 Entergy Condition Report No. CR-IP2-2005-03557 2.2.4.2 Entergy ERCN No. 1P2-05-25674 2.2.5 GZA GeoEnvironmental, Inc (GZA) Documents 2.2.5.1 GZA Letter Dated October 28,2005, "Project Plan/Work Plan, Monitoring Well Installation, Indian Point Unit 2 Spent Fuel Storage Pool' 2.2.6 New York State Department Of Environmental Conservation (NYS-DEC)

Documents 2.2.6.1 NYS-DEC, "Sampling Guidelines And Protocols" 2.2.7 United States Department Of The Interior (US-DOI) Documents 2.2.7.1 US-DOI, "Groundwater Manual" (1981 Edition).

2.2.8 United States Environmental Protection Agency (US-EPA) Documents 2.2.8.1 US-EPA, "Groundwater Sampling Procedure Fow Low Stress Purging ard Sampling"

ER RESPONSE NO. ER-05-2-113 ENN-DC-1 15 Rev 7]

ZEntergy NUCLEAR CHANGE RESPONSE PAGE6OF 13 3.0 EVALUTION / DESIGN

SUMMARY

3.1 Evaluation Resolution Eight (8) groundwater monitoring wells will be installed in the vicinity of the IP2-F',B, 1P2 Transformer Yard Area, Condenser Tube Withdrawal Pit, 1P2-TB Loading Bay and Discharge Canal, near the IP3 Security Command Post. The wells will provide IPEC the ability to monitor groundwater and determine the extent of any groundwater contamination. Locations for the monitoring wells are as follows:

3.1.1 Monitoring Wells No. MW-31 And No. MW-32 Monitoring Well No. MW-31 will be located near the entrance gate to the alleyway between the IP2-FSB and the IP2-MOB. In addition, Monitoring Well

. ;,No. MW-32 will be located -10 FT within the entrance gate to the Tnrck Alleyway between the IP2-FSB and the IP2-PAB. These wells will be advanced from EL 79'-6" to EL -10'-O". These multi-level monitoring wells will be used to evaluate the source area concentrations of contaminants and the hydrogeology of the bedrock aquifer.

3.1.2 Monitoring Wells No. MW-33 Through No. MW-35 Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be located within the IP2 Transformer Yard Area along the west wall of the IP2-PAB. One well will be located near the northwest end of the wall, the second well will be located near the middle of the wall and the third well will be located near the southwest end of the wall. These wells will be advanced from EL 18'-6" to EL -10'-O". These monitoring wells will be used to evaluate the width of the potential plume, which may emanate from the IP2-FSB. The plume may be detected in existing Monitoring Well No. MW-I 1, which is located in the IP2 Transformer Yard Area.

3.1.3 Monitoring Wells No. MW-36 Monitoring Well No. MW-36 will be located on the east side of the Discharge Canal within the IP2 Condenser Tube Withdrawal Pit, near the southwest corner of the pit. This well will be advanced from EL 12'-9" to EL -15'-O". This monitoring well will be used to evaluate if contaminants may have entered the backfill around the Discharge Canal.

3.1.4 Monitoring Wells No. MW-37 Monitoring Well No. MW-37 will be located on the west side of the Discharge Canal within the IP2-TB Loading Bay Area, EL 15'-0", between Column Lines 9-11 and Column Lines CC3-F. This well will be advanced from EL 15'-0" to EL -15'-0". This monitoring well will be used to evaluate if contaminants may have migrated west of the Discharge Canal.

I ER RESPONSE NO. ER-05 113 ENN-DC- 115 Rev 5

^Entergy NUCLEAR CHANGE RESPONSE PAGE 7 OF 13 3.1.5 Monitoring Wells No. MW-38 Monitoring Well No. MW-38 will be located on the east side of the Discharge Canal, near the IP3 Security Command Post. This well will be located outside the Protected Area Fence, near the point in the Discharge Canal, where it transitions from a rip-rap embankment to a sheet-pile structure. This well will be advanced from EL 15'-0" to EL -15'-0". This monitoring well will be used. to evaluate if contaminants may have migrated along the backfill of the Discharge Canal towards the Hudson River.

3.1.6 Temporary Still Wells A Temporary Still Well will be located on the west side of the Discharge Canal within the Hudson River. In addition, another Temporary Still Well will be located within the Discharge Canal at the south end of the Discharge Canal.

These wells will be located-ouitsid e he.Protected Area Fence. The Temporary Still Wells will be used to validate the hydrogeology at the IPEC Site.

3.2 Design Basis Discussion 3.2.1 Monitoring Wells No. MW-31 and No. MW-32 will be open rock wall type wells. These monitoring wells will be advanced -90 FT, i.e., from EL 79'-6" to EL -10'-0". The upper -5 FT of these wells will consist of a 4"0 carbon steel casing, which will be protected by a manhole and steel sleeve. Following completion of each monitoring well, the wells will be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

3.2.2 Monitoring Wells No. MW-33 though No. MW-38 will be screen type wells.

Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be will be advanced -29 FT, i.e., from EL 18'-6" to EL -I0'-0". Monitoring Well No.

MW-36 will be will be advanced -28 FT, i.e., from EL 12'-9" to EL-15'-".

Monitoring Wells No. MW-37 and No. MW-38 will be advanced from EL 15'-.0" to EL -15'-0". Each well will be constructed with a 4"0, 0.05" slotted PV1C screen, which will penetrate -5 FT into the water table. A 4"0 PVC riser p pe will extend from the screened section to grade elevation. The annular space around the screened section will be backfilled with Filler Gravel material to

-2 FT above the screened section. A 2 FT long Bentonite Plug will be installed above the Filler Gravel material. The annular space around the 4"0 PVC riser pipe will be grouted from the Bentonite Plug to grade elevation. Following completion of each monitoring well, the well will be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment H.

ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE 8 OF 13 3.2.3 A Temporary Still Well will be located on the west side of the Discharge Carial within the Hudson River. In addition, another Temporary Still Well will be located within the Discharge Canal at the south end of the Discharge Canll.

These wells will be located outside the Protected Area Fence. Each well will be advanced from the Discharge Canal walkway to the river bottom or the canal bottom. Each monitoring well will be constructed with a 2"0, 2 FT long, 0.02" slotted stainless steel screen, which will rest on the river bottom or the canal bottom. A 2"0 stainless steel riser pipe will extend from the screened section to an elevation above the Discharge Canal walkway handrail. The Temporary Still Wells will be used to validate the hydrogeology at the IPEC Site.

3.3 Design Input Considerations See EN-DC-141, Attachment 9.1 - 'Design Input Record" 3.4 Relationship Witliht her Modifications This modification does not interface with any other modifications; however, ERCN No. IP2-05-25674 installed Monitoring Well No. MW-30 within the IP2-FSB.

3.5 Operating Experience (OE) Review A search of the EPIX Database was performed using these keywords - "Wells", "Site Sampling Wells", "Site Well Drilling", "Site Drilling" and "Monitoring Wells". No INPO hits were detected. The only industry operating experience was addressed in NRC Information Notice No. 2004-05, "Spent Fuel Pool Leakage To Onsite Groundwater".

3.6 Design Margin Analysis The monitoring wells are passive components, which do not interface with any plant systems or change plant system configurations; therefore, this modification does not impact any existing SSC design margin analyses or introduce a new SSC design margin analysis.

4.0 IMPACT ON CURRENT OPERATIONAL BASIS This modification will have no impact on the current plant operational bases. The monitoring wells are passive components, which do not interface with any plant systems or change plant system configurations. Drilling of the boreholes for the monitoring wells has the potential to impact underground utilities and subsurface structures, which is addressed in Section 5.1.

1 ER RESPONSE NO. ER-05-2-1 13 ENN-DC-1 15 Rev 5

-~- Ente"NUCLEAR JJ1111 CHANGE 5 yPAGE RESPONSE 9 OF 13 5.0 ENGINEERING INSTRUCTIONS NECESSARY TO IMPLEMENT THE CHANGE 5.1 General Requirements 5.1.1 To the maximum extent practical, the workscope associated with this modification shall be performed in accordance with the skill of the craft.

5.1.2 All work shall be performed in accordance with the applicable OSH[A requirements addressed in 29CFR1910 and 29CFR1926. During implementation of the modifications, the Installer shall adhere to all safety precautions, as identified in applicable Entergy Procedures.

5.1.3 Prior to drilling the borings, review underground utility drawings and subsurface structure drawings to determine candidate boring locations.

5.1.4 Prior to drilling the borings, a surface geophysical survey method shall be used to pre-clear candidate boring locations to a depth of -5 FT below grade elevation.

The geophysical survey shall consist of electromagnetic metal detectors, utility locating instruments or ground penetrating radar. In addition, non-metallic utilities may be investigated by inserting a flexible steel antenna into the lines, if accessible, and using a utility locating instrument to detect a signal.

5.1.5 Prior to drilling the borings, map the rebar to identify potential interferences and if required, obtain Design Engineering permission to cut rebar. Provide a step in the job order for Design Engineering approval and sign-off.

5.1.6 Design Engineering shall approve the candidate boring locations for drilling.

Provide a step in the job order for Design Engineering approval and sign-off.

5.1.7 A high-vacuum excavation technique shall be used in combination with an air knife to excavate unconsolidated materials to a minimum of 5 FT below grade elevation or until bedrocktobstructions are encountered, which ever is less. Do not use equipment, which may possibly damage subsurface utilities.

5.1.8 All drill cuttings and drilling fluids will be containerized and staged on-site.

Characterization and disposal of the wastes shall be in accordance with applicable Entergy procedures.

5.1.9 After installation of Monitoring Wells No. MW-31 through No. MW-38, the Installer shall document the "As-Installed" location (longitude, latitude and elevation) for each monitoring well.

5.1.10 Monitoring Wells No. MW-31 through No. MW-38 shall be tagged per Entergy Plant Procedure No. OAP-044. Obtain stainless steel labels from Operation Support per Label Request Form, which should be submitted by the Responsible Engineer.

4% ER RESPONSE NO. ER-05-2-113 ENN-DC-115 Rev55

- =Entergy NUCLEAR CHANGE RESPONSE PAGE 10 OF 13 5.2 Monitoring Wells No. MW-31 And No. MW-32 5.2.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2-FSB Monitoring Wells No. MW-31 and No. MW-32. The general area locations for these wells are indicated on Entergy Drawing No. DRN-05-05395.

5.2.2 Install Monitoring Wells No. MW-31 and No. MW-32 in accordance with Entergy Drawing No. DRN-05-05385, Detail 1.

5.2.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

5.2.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-31 and No. MW-32.

5.2.5 After data acquisition, remove pressure transducers.

5.3 Monitoring Wells No. MW-33 Through No. MW-35 5.3.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2 Transformer Yard Area Monitoring Wells No. MW-33, No. MW-34 and No. MW-35. The general area locations for these wells are indicated on Entergy Drawing No. DRNV-05-05395.

5.3.2 Install Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 in accordance with Entergy Drawing No. DRN-05-05385, Detail 2.

5.3.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

5.3.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-33 through No. MW-35.

5.3.5 After data acquisition, remove pressure transducers.

5.4 Monitoring Well No. MW-36 Through No. MW-38 5.4.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2 Condenser Tube Withdrawal Pit Monitoring Well No. MW-36, IP2-TB Loading Bay Area Monitoring Well No. MW-37 and Discharge Canal Monitoring Well No. MW-38. The general area locations for these wells are indicated on Entergy Drawing No. DRN-05-05395.

5.4.2 Install Monitoring Wells No. MW-36, No. MW-37 and No. MW-38 in accordance with Entergy Drawing No. DRN-05-05385, Detail 3, Detail 4 and Detail 5.

Ad ER RESPONSE NO. ER-05-2-113 ENN-DC-l 15 RevS 0 :Entergy NUCLEAR CHANGE RESPONSE PAGE I1 OF 13 5.4.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", AttachmentI and Attachment II.

5.4.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-36 through No. MW-38.

5.4.5 After data acquisition, remove pressure transducers.

5.5 Existing Monitoring Well No. U3-TI 5.5.1 In order to install a Pressure Transducer within Monitoring Well No. U3-TI, which is located within the IP3-TB, EL 15'-O", raise the existing well stand pipe by

-1.5 FT to minimize potential seepage of groundwater, which may be under the floor slab..

5.5.2 The existing well stand pipe for Monitoring Well No. U3-TI shall be modified in accordance with Entergy Drawing No. DRN-05-05409.

5.5.3 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Well No. U3-TI.

5.5.4 After data acquisition, remove pressure transducers.

5.6 Temporary Installation Of Still Wells 5.6.1 Install one still well on the west side of the Discharge Canal within the Hudson River. In addition, install a second still well within the Discharge Canal at the south end of the Discharge Canal.

5.6.2 Temporary installation (Field-to-Suit) of the still wells shall be in accordance with Entergy Drawing No. DRN-05-05409.

5.6.3 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in the two Temporary Still Wells.

5.6.4 After data acquisition, remove still wells and pressure transducers.

5.7 Foreign Material Exclusion Control Requirements 5.7.1 When not working, the tops of the well borehole, carbon steel well casing and PVC well riser pipes shall be temporarily sealed in accordance with applicable Entergy Procedures to prevent the introduction of materials or debris into the well borehole or monitoring wells.

ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE 12 OF 13 6.1 ASME or ASTM materials are acceptable. Material and equipment shall be handled, shipped and stored in accordance with of ANSI N45.2.2, Level D.

6.2 For Monitoring Wells No. MW-31 and No. MW-32, the 4"0, Sch. 40, carbon steel cac.ing material shall be in accordance ASTM A53 or ASTM A106, Gr B.

6.3 For Monitoring Wells No. MW-33 through No. MW-38, the solid 4"0, Sch. 40, PVC riser pipe material shall be in accordance ASTM D1784.

6.4 For Monitoring Wells No. MW-33 through No. MW-38, the slotted (0.05" Wide Slots),

4"0, Sch. 40, PVC screen material shall be in accordance ASTM D1784.

6.5 For Monitoring Wells No. MW-33 through No. MW-38, the well cap shall be Morris Model No. 318104001.

- 6.6 For Monitoring Wells No. MW-31 through No. MW-38, the manhole cover and manhole cover/steel sleeve shall be shall be Morris Model No. 318101200.

6.7 For the Temporary Still Wells, the 2"0, Sch 40, stainless steel riser pipe material shall be in accordance ASTM A312.

6.8 For the Temporary Still Wells, the slotted (0.02" Wide Slots), 2"0, Sch. 40, stainless steel screen material shall be in accordance ASTM A312.

6.9 For existing 1P3 Monitoring Well No. U3-TI, the 1.25"0 PVC riser pipe extension a.nd coupling shall be in accordance ASTM D1784.

7.0 SPECIAL PROCESS REQUIREMENTS NOT APPLICABLE 8.0 TEST AND INSPECTION REQUIREMENTS See ENN-DC-1 17, Attachment 9.4 - "Post Modification Test Plan Form" 9.0 ATTACHMENTS 9.1 Distributed For Field Work/installation 9.1.1 ENN-DC- 117, Attachment 9.4 - "Post Modification Test Plan Form" 9.1.2 Entergy Drawing No. DRN-05-05385 9.1.3 Entergy Drawing No. DRN-05-05395 9.1.4 Entergy Drawing No. DRN-05-05409

ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE 13 OF 13 9.2 Not Distributed For Field Work/Installation 9.2.1 Entergy Procedure No. ENN-DC-141, Attachment 9.1 - "Design Input Record" 9.2.2 Entergy Procedure No. ENN-DC-141, Attachment 9.2 - "Design Input Record Continuation Sheet" 9.2.3 Entergy Procedure No. ENN-LI-100, Attachment 9.1 - "Process Applicabilily Determination" 9.2.4 Entergy Procedure No. ENN-LI-101, Attachment 9.1 - "50.59 Screen Control Form"

ATTACHM1ENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet I of I ER No. E.1-05-2-113 Rev 0

Title:

INSTALLATION OF NEW Page I of 5 MONITORING WELLS FOR IP2-SFP Test Requirement(s) Acceptance Criteria Item # s Construction Attachment I and Attachment 11 Attachment I and Attachment II 001 L Functional L ER Assumption Item # El Construction L Functional Q ER Assumption Item # L Construction O Functional Li ER Assumption Item # Li Construction EJ Functional L ER Assumption Item # LConstruction U Functional LER Assumption Item # L Construction Li Functional El ER Assumption Item # El Construction 71 Functional LiER Assumption Item # Li Construction 0 Functional I] ER Assumption

ATTACHME2NT 9.4 POST MODIFICATION TEST PLAN FoRM Sheet 2 of '

ATTACHMENT I MONITORING WELL DEVELOPMENT PLAN 1.0 Miltilevel Sampling Equipment The Installer shall use a Waterloo Systems Multilevel Sampling System supplied by Solist. This system uses modular components which form a sealed casing string of various casing lengths, packers, ports, a base plug and a surface manifold. This configuration allows accurate placement of ports at precise monitoring zones. Monitoring tubes attached to the stem of each port individually connect that monitoring zone to the surface. The standard system is built on 2"0 Schedule 80'PVC pipe to fit 3"- 4' ...

diameter boreholes adiiuses 3 FT long packers. Stainless steel components, custom packer materials and sizes, Teflon tubing are available.

Monitoring ports are constructed from 316 Stainless Steel. Ports are isolated by packers at each desired monitoring zone and are individually connected to the surface manifold with narrow diameter tubing.

This formation water enters the port, passes into the stem, up into the monitoring tube attached to the stem, to its static level. A sampling pump and pressure transducer will be dedicated to each monitoring zorne by attachment to the port stem.

The manifold completes the system at surface. It organizes, identifies, and coordinates the tubes and/or cables from each monitoring zone. The manifold allows connection to each transducer in turn, and a simple, one-step connection for operation of pumps. When dedicated pumps are selected, it allows individual zones to be purged separately, or purging of many zones simultaneously to reduce field tirres.

Peimanent packers ensure long term integrity of seals in cored bedrock holes and cased wells. They use a water activated expansion sleeve fitted over the perforated packer body. A layer of porous plastic distributes water evenly to the packer expansion material. A Rubber/Kevlar/Rubber sheath envelops the expansion material. The Kevlar layer provides strength to bridge across large fissures. The pliant gum rutber forms an effective seal against the borehole wall. Water is added to the inside of the sealed casing string after installation. The water passes through the packer body into the expansion sleeve, causing the material to expand. Thus an engineered seal is permanently formed against the borehole wall.

The Installer shall use Waterloo Systems Gas-Driven Double Valve Pumps supplied by Solist with sta nless steel and TeflonD valves. The pumps are connected directly to the stem of each port and dual line polyethylene or Teflon( tubing connects the pump to the wellhead manifold. The pumps will use manual pump control units. They have quick-connect couplings with only a single connection to the manifold required. Samples from all levels are easily and rapidly obtained. Purging from some or all levels simultaneously is accommodated by the multi-purge feature of the manifold.

ATTACHMENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet 3 of ';

2.0 Ro-k Face Logging The Installer shall provide an expert geologist or geologic engineer to log the rock face exposed in the IP2-FSB. The bedrock face will be mapped and logged for lithology, bedding planes, fractures, joints and faults. The three dimensional orientation of the surfaces will be recorded and evaluated. The information will be used to understand the fracture orientations and their control on the hydrologic processes at the site.

3.0 Geophysical Well Logging Prior to completing the wells as permanent monitoring wells, the ,Installer. shall conduct down-hole gecphysical well-logging of the three completed borings adjacent to TP2-FSB. The well-logging will consist of borehole temperature logging, fluid resistivity, 3-arn caliper logging, acoustical televiewer logging (ATV) and heat pulse flow meter logging. The ATV log will provide data on fracture depth and orientation. The caliper log will provide information on depths of bedrock fractures. The fluid temperature and fluid resistivity will provide information as to which fractures are productive.

4.0 Packer Testing Baled upon review of the geophysical well logging results, the Installer shall select discreet intervals to conduct packer testing to assess hydraulic conductivity within the bedrock. Packer tests will be performed using a double inflatable bladder and straddle packer assembly with a 10 FT long testing zone. Packer testing will begin at the highest testing zone and continue down the length of the uncased bedrock. Packer test intervals and test pressures will be determined in the field and recorded. The raw data will be reduced in the office and hydraulic conductivity values will be calculated using a computer program called Permcalc, developed by GZA based on the methods presented in the US-DOI, "Groundwater Manual"..

5.0 Hydraulic Conductivity Tests The Installer shall conduct hydraulic conductivity "pump/drawdown tests" at each of the existing groundwater monitoring wells, as well as, the (6) new screened monitoring wells. The test generally identifies the rates of rising water through the surrounding soils for which the test is being conducted.

Hydraulic conductivity and transmissivity are then calculated from those results. At each of the tested monitoring wells, the resting (static) water level will be measured along with the depth and diameter of the well casing. An electrical submersible pump will be utilized to drawdown water in the well. The puraping rate will be adjusted until a steady state is achieved. Discharged water will be pumped to 275-galion plastic holding tanks. Approximately 350 gallons of water will be generated for each monitoring well. Elapsed time and water levels will be manually recorded and recorded by a vibrating wire transducer and data logger system at 10-second intervals. The test will be repeated at each tested monitoring well. The resultant data will be evaluated to assess the hydraulic conductivity cf the formations.

ATrACHM ENT 9.4 POST MODIFICATION TEST PLAN FORA Sheet 4 of 5 6.0 Groundwater Santpling And Analysis Following installation of the new monitoring wells, the Installer will collect groundwater samples from each of the previously installed wells and the newly installed wells. Groundwater samples will be collected using USEPA low flow procedures. Groundwater samples will be collected from five feet below the water table or adjacent to high permeability flow zones as documented by geophysical logging. A decontaminated, stainless steel electrical submersible pump with controller and dedicated tubing will used to perform the groundwater sampling activities. The wells will be pumped for purging and sampling at a flow rate of between 250 to 500 mL per min (mlmin). Field parameters, including p14, specific conductivity, turbidity, dissolved oxygen, temperature, and ORP, were measured approximately every five (5) -minutes-during the purge process at each well using a multi-parameter waiter quality system. Purging will `eaisdwhen all or most field parameters have stabilized to within the range specified in the US-EPA "Groundwater Sampling Procedure For Low Stress Purging and Sampling".

Gioundwater samples will be given to IPEC personnel who will be responsible for chemical analysis.

7.0 In tallation And Monitoring Of Pressure Transducers In order to validate hydrogeology at the IPEC Site, the Installer will temporarily install In-situ Mini-Troll pressure transducers in existing on-site groundwater monitoring wells, as well as, the newly installed wells.

In addition, the Installer will install (2) still wells which will house pressure transducers. One still well will be installed on the west side of the Discharge Canal within the Hudson River. The second still well will be installed on the south end of the Drainage Canal within the Drainage Canal proper.

In order to install a transducer within well U3-T1, located on the bottom floor of the Unit 3 Turbine Building, the Installer will need to raise the existing stand pipe by 1.5 feet in order to minimize potential seepage of groundwater, which is under pressure beneath the slab. The additional 1.5 feet of one-inch diameter PVC riser pipe will be secured to the existing riser pipe using a PVC coupling and PVC glue.

The pressure transducers will be set one-foot off the bottoms of the wells with a maximum of 100 FT of water column above the transducer. The transducers will be set to record water levels in the wells on at specific intervals. The information will aid in assessing tidal influences on groundwater at the Site, as well as, assessing the flux of groundwater across the Site.

8.0 Elevation Survey The Installer will locate and survey Monitoring Wells No. MW-3 I through No. MW-38. ThA longitude and latitude of each well will be measured to the nearest second and the elevation of each well will be measured to one-hundredth of a foot. The elevation of each well will be referenced to on-site datum. In addition, several catch basins and drainage points will be surveyed to determine their exact locations and elevations.

ATTACHMENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet 5 of 5 ATTACHMENT 11 NYS-DEC. SAMPLING GUIDELINES AND PROTOCOLS Section 54;.4 - Monitoring And Well Development All permanently installed wells shall be adequately developed prior to initial sampling efforts. Adequate development should eliminate all fine material from the area of the well screen and allow for the collection of a sample which is free,?f,§uspended materials. Wells installed by "wet drilling" where drilling muds are used shall be.,,,,,,

developed s6ohiatiresiduafdrilling muds will not settle around the well screens or in the surrounding soil :and >,

contaminate future sanipling. Various methods may be used to develop wells. These methods consist of suction lift pumping (pitcher, centrifugal, roller, piston, peristaltic pumps) pressure injection pumping, submersible pumping, surge blocks, bailing, and air lift pumping.

ATTACHMEINT 9.2 ER COVER SHEET (TYPICAL)

Sheet 1 cf 1 FER (Request)# lIP2-05-26056 l Revision No. 0 l Priority: Page 1 of 1

Title:

INSTALLATION OF NEW MONITORING WELLS FOR IP2-SFP Base ER No. IP2-05-26056 Linked E.R(s). NONE ER Response No. ER-05-2-113 I< 3sUa-tllapuFRE Mnzr5 czEpwAR-7 MF~P_... :E Originator: R.F. Evers Date: 10-27-05 Ext: 6689 Dept.: Design Engineering - Civil / Structural System It): N/A Date Required: November 15,2005 Component ID: MW-31 Through MW-38 Outage Q;Yes: ONo:

Problem I Proposed Solution/Justification:

SEE SECTION 1.2; .

$SlIF-S~fi.G111E1lESON Quality Classification: NON-CLASS WA" ER Response Type: El Reply El Administrative El Engineering Evaluation El Commercial 0 Nuclear El Inter-Discipline Problem Description/Proposed Solution/Problem Resolution (Attach additional sheets as required):

SEE SECTION 1.3

__ _ EV .1t 0 Design Reviewer: P N 7to, 2 p ) IDate: '//6r/07 0El Operations: J. Etzweiler _,_ ,, Date: ,./-;/2oo >

0n Consiruction Services: .z anleXyr, , Date:

1 0 Planning: D. Norris Date:t///2a5-0Train!ing: C.Hayes Date: je;L, X_ : 0 Trainiig(Simulator): R.Robenstein/_ Date:/_

A Rad S;upport: R. LaVera Date:

0 Chemistry: J. Peters Date: ,,A/M Environmental: D.Gray Date://

, - 5-_

0 Configuration Management:E. It0o Date: ///4$/d/

9 ResponsibleEngineer: R.F. Evers Date: / '

0 Respcnsible Engineering Supervisor: R. S. Drake a k e Date: f_

Engineering Manager (if required) Date:

E Engineering Director (if required) Date:

l G Operations (if Required, for Nuclear Changes)

GM Date:

L\ GSRtNeqaired) o, Date:

-s kx'z,61 4'*

?1-B-8.zg 0

A" ER RESPONSE NO. ER-05-2-113 ENN-DC-I 15 RevS 2 -. ll PAGE!I OF 13 TABLE OF CONTENTS Section Des;crintion Page

1.0 DESCRIPTION

. 2 1.1 Stnictures, Systems Or Components. 2 1.2 Reison For Change. 2 1.3 Design Objective To Resolve Problem. 3 1.4 Components Listed 3 3....................

2.0 DOCUMENTS .............................................................. 4 2.1 List Of Affected Documents. .................... 4 2.2 Reference Documents .............................................................. 4 3.0 EVALUATION / DESIGNS IA'RY'; ............................................................. 6 3.1 Evaluation Resolution ......................... ..................................... 6 3.2 Design Basis Discussion ................................. ............................. 7 3.3 Design Input Considerations ...................................................... ........ 8 3.4 Relationship With Other Modifications ............................................................ 8 3.5 Operating Experience (OE) Review .............................................................. 8 3.6 Desiign Margin Analysis. 8 4.0 IMPACT ON CURRENT OPERATIONAL BASIS. 8 5.0 ENGINEERING INSTRUCTIONS NECESSARY TO IMPLEMENT THE CHANGE 9 5.1 General Requirements ......................... ..................................... 9 5.2 Monitoring Wells No. MW-3 1 And No. MW-32 .10 5.3 Monitoring XVells No. MW-33 And No. MW-35 ........................................................... 10 5.4 Monitoring Wells No. MW-36 And No. MW-38 .................................................... 10 5.5 Existing Monitoring Well No. U3-TI ............................................................... 1 5.6 Temporary Installation Of Still Wells .................................. ............................ Il 5.7 Foreign Material Exclusion Control Requirements ................................................ II.......

1 6.0 ENGINEERING MATERIAL LIST AND VENDOR TECHNICAL INFORMATION 12 7.0 SPECIAL PROCESS REQUIREMENTS ......................................................... 12 8.0 TEST AND INSPECTION REQUIREMENTS .12 9.0 ATrACHMENTS .............................................................. 12 9.1 Distributed For Field Work/lnstallation ............................................................ 12 9.2 Not Distributed For Field Work/Installation ....................................................... 13

ER RESPONSE NO. ER-05-2-113 ENN-DC-1 15 Rev 5

-Ent&y NUCLEAR CHANGE RESPONSE PAGE2OF 13

1.0 DESCRIPTION

1.1 Structures. Systems or Components Description Monitoring Wells will be installed in the vicinity of the IP2-FSB, IP2 Transformer Yard Area, Condenser Tube Withdrawal Pit, 1P2-TB Loading Bay and east side of the Discharge Canal, near the IP3 Security Command Post. The monitoring wells will provide Entergy the ability to monitor groundwater and evaluate the following:

1.1.1 The source area concentrations of contaminants and the hydrogeology of the bedrock aquifer in the vicinity of the IP2-FSB.

1.1.2 The width of the potential plume, which may emanate from the IP2-FSB and which may be detected in existing Monitoring Well No. MW-I 11.

' " y;i 1.1.3 If contaminants may have entered the backfill around the DischargdCanal'.-

1.1.4 If contaminants may have migrated west of the Discharge Canal 1.1.5 If contaminants may have migrated along the backfill of the Discharge Canal towards the Hudson River.

1.2 Reason For Chanee As part of the IPEC Dry Cask Storage Project, a new single failure proof Gantry Crane will be installed within the IP2 Fuel Storage Building (IP2-FSB) to transfer the Holtec International HI-TRAC to/from the IP2 Spent Fuel Pool (IP2-SFP). In order to facilitate installation of the North Pedestal Structure and the Steel Ballast Box Foundation, which will support the Gantry Crane, the existing IP2-FSB Truck Bay Floor, EL 80'-O" was removed from service. In addition, the sub-floor bedrock and soil, which is adjacent to the south wall of the 1P2-SFP, was excavated to -EL 51 '-0". During recent excavation activities, two hairline shrinkage cracks in the south wall of the IP2-SFP were exposed, which exhibited signs of moisture. One crack, which is located at -EL 61'-O" near the northwest corner of the excavated Truck Bay Area, was observed to be actively discharging water at a rate of -1.5 Liters/Day. Radiochemistry testing indicated constituents found in the discharged water to be generally consistent with water typically associated with the IP2-SFP. This adverse condition is documented in Condition Report No. CR-1P2-2005-03557. Currently, there are no available methods to monitor groundwater in the vicinity of the IP2-FSB. As a result, IPEC cannot evaluate the source and extent of the potential leak from the IP2-SFP. In addition, IPEC cannot evaluate the hydrogeology in the vicinity of the IP2-FSB.

ER RESPONSE NO. ER-05-2-1 13 j ENN-DC-l 15 Rev 5 Entergy l NUCLEAR CHANGE RESPONSE PAGE 3 OF 13 1.3 Design Objective To Resolve Problem Eight (8) groundwater monitoring wells will be installed in the vicinity of the IP2-FSB, IP2 Transformer Yard Area, Condenser Tube Withdrawal Pit, IP2-TB Loading Bay and Discharge Canal, near the IP3 Security Command Post. The locations for the monitoring wells are as follows:

1.3.1 Monitoring Well No. MW-31 will be located near the entrance gate to the Alleyway between the 1P2-FSB and the IP2-MOB.

1.3.2 Monitoring Well No. MW-32 will be located -10 FI' within the entrance gate to the Truck Alleyway between the IP2-FSB and the IP2-PAB.

1.3.3 Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be located within the IP2 Transformer Yard Area along the west wall of the IP2-PAB. One monitoring well will be located near the northwest end of the wall, the second monitoring well will be located near the middle of the wall and the third monitoring well will be located near the southwest end of the wall.

1.3.4 Monitoring Well No. MW-36 will be located on the east side of the Discharge Canal within the Condenser Tube Withdrawal Pit, near the southwest corner of the pit.

1.3.5 Monitoring Well No. MW-37 will be located on the west side of the Discharge Canal within the 1P2-TB Loading Bay Area, EL 15'-On, between Column Lines 9-11 and Column Lines CC3-F.

1.3.6 Monitoring Well No. MW-38 will be located on the east side of the Discharge Canal, near the IP3 Security Command Post. This monitoring well will be located outside the Protected Area Fence, near the point in the Discharge Canal, where it transitions from a rip-rap embankment to a sheet-pile structure.

1.3.7 Two Temporary Still Wells will be located near the Discharge Canal. One well will be located on the west side of the Discharge Canal within the Hudson River and the second well will be located within the Discharge Canal at the south end of the Discharge Canal.

1.4 Components Listed 1.4.1 Components Added Monitoring Wells No. MW-3 1Through No. MW-38.

1.4.2 Components Deleted NONE

ER RESPONSE NO. ER-05 113 ENN-DC- 115 Rev 5 z Efntergy NUCLEAR CHANGE RESPONSE PAGE4OF 13 2.0 DOCUMENTS 2.1 List Of Affected Documents 2.1.1 Document Revision Notices (DRNs)/Preliminary Design Documents (PDDs)

Specific Document Information Document Required For Doc. No. Rev Title Inst. RTS Post RTS DRN-05-05385 0 1P2 Ground Water Sampling _ _

(400936) Monitoring Well Details DRN-05-05395 0 IP2 Ground Water Sampling 0 O 0 (400937) . '. Monitoring Well Locations MSjt DRN-05-05409 0 IP2 Ground water Sampling 0 El 0 (400938) Temp Monitoring Well Details 2.1.2 Documents Affected By This ER Without Attached DRNs/PDDS 2.1.2.1 MAXIMO Database - Need to update the information for Monitorinlg Wells No. MW-31 through No. MW-38. The database needs to *be revised Post-RTS 2.1.2.2 Future sampling procedures for Monitoring Wells No. MW-31 through No. MW-38 will need to be developed by the responsible IPEC Department.

2.1.3 Documents Voided By This ER NONE 2.1.4 Design Change Documents Affected By This ER NOT APPLICABLE 2.2 Reference Documents Where no specific date or revision is identified within this ER or otherwise noted on the Entergy Drawings, the latest revision, edition or addendum in effect at the time of construction shall apply. The following industry standards will be invoked, as required:

2.2.1 American National Standards Institute (ANSI) Documents 2.2.1.1 ANSI N45.2.2, "Packaging, Shipping, Receiving, Storage & Handling"

ER RESPONSE NO. ER-05 113 ENN-DC-115 Rev 5 Entery NUCLEAR CHANGE RESPONSE PAGE 5 OF 13 2.2.2 American Society of Testing Materials (ASTM) Documents 2.2.2.1 ASTM A53, "Standard Specification For Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded And Seamless" 2.2.2.2 ASTM A106, "Standard Specification For Seamless Carbon Steel Pipe For High-Temperature Service" 2.2.2.3 ASTM A312, "Standard Specification For Seamless, Welded, And Heavily Cold Worked Austenitic Stainless Steel Pipes" 2.2.2.4 ASTM D1784, "Standard Specification For Rigid Poly(Vinyl Chlorice)

(PVC) Compounds And Chlorinated Poly(Vinyl Chloride) (CPVC)

Compounds" 2.2.3^-GCode Of Federal Regulations (CFR) Documents 2.2.3.1 CFR Title 29, Part 1910 (29CFR1910), "Occupational Safety And Health Standards" 2.2.3.2 CFR Title 29, Part 1926 (29CFR1910), "Safety And Health Regulations For Construction" 2.2.4 Entergy Nuclear (Entergy) Documents 2.2.4.1 Entergy Condition Report No. CR-IP2-2005-03557 2.2.4.2 Entergy ERCN No. 1P2-05-25674 2.2.5 GZA GeoEnvironmental, Inc (GZA) Documents 2.2.5.1 GZA Letter Dated October 28, 2005, "Project Plan/Work Plan, Monitoring Well Installation, Indian Point Unit 2 Spent Fuel Storage Pool" 2.2.6 New York State Department Of Environmental Conservation (NYS-DEC)

Documents 2.2.6.1 NYS-DEC, "Sampling Guidelines And Protocols" 2.2.7 United States Department Of The Interior (US-DOI) Documents 2.2.7.1 US-DOI, "Groundwater Manual" (1981 Edition).

2.2.8 United States Environmental Protection Agency (US-EPA) Documents 2.2.8.1 US-EPA, "Groundwater Sampling Procedure Fow Low Stress Purging and Sampling"

ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE6OF13 3.0 EVALUTION / DESIGN

SUMMARY

3.1 Evaluation Resolution Eight (8) groundwater monitoring wells will be installed in the vicinity of the IP2-F'SB, 1P2 Transformer Yard Area, Condenser Tube Withdrawal Pit, IP2-TB Loading Bay and Discharge Canal, near the IP3 Security Command Post. The wells will provide IPEC the ability to monitor groundwater and determine the extent of any groundwater contamination. Locations for the monitoring wells are as follows:

3.1.1 Monitoring Wells No. MW-3 1 And No. MW-32 Monitoring Well No. MW-31 will be located near the entrance gate to the alleyway between the IP2-FSB and the IP2-MOB. In addition, Monitoring Well No. MW-32 will be located -10 FT within the entrance, gate to the Truck Alleyway between the IP2-FSB and the 1P2-PAB. -These'.we1ls will be advanced from EL 79'-6" to EL -10'-0". These multi-level monitoring wells will be used. to evaluate the source area concentrations of contaminants and the hydrogeology of the bedrock aquifer.

3.1.2 Monitoring Wells No. MW-33 Through No. MW-35 Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be located within the IP2 Transformer Yard Area along the west wall of the IP2-PAB. One well will be located near the northwest end of the wall, the second well will be located near the middle of the wall and the third well will be located near the southwest end of the wall. These wells will be advanced from EL 18'-6" to EL -l0'-O". These monitoring wells will be used to evaluate the width of the potential plume, which may emanate from the EP2-FSB. The plume may be detected in existing Monitoring Well No. MW-I 1, which is located in the IP2 Transformer Yard Area.

3.1.3 Monitoring Wells No. MW-36 Monitoring Well No. MW-36 will be located on the east side of the Dischaige Canal within the IP2 Condenser Tube Withdrawal Pit, near the southwest conier of the pit. This well will be advanced from EL 12'-9" to EL -15'-0". This monitoring well will be used to evaluate if contaminants may have entered the backfill around the Discharge Canal.

3.1.4 Monitoring Wells No. MW-37 Monitoring Well No. MW-37 will be located on the west side of the Discharge Canal within the IP2-TB Loading Bay Area, EL 15'-0", between Column Lines 9-11 and Column Lines CC3-F. This well will be advanced from EL 15'-0" to EL -15'-0". This monitoring well will be used to evaluate if contaminants may have migrated west of the Discharge Canal.

Af ER RESPONSE NO. ER-05-2-1 13 ENN-DC- 115 Rev 5 Entergy NUCLEAR CHANGE RESPONSE PAGE 7 OF 13 3.1.5 Monitoring Wells No. MW-38 Monitoring Well No. MW-38 will be located on the east side of the Discharge Canal, near the IP3 Security Command Post. This well will be located outside the Protected Area Fence, near the point in the Discharge Canal, where it transitions from a rip-rap embankment to a sheet-pile structure. This well will be advanced from EL 15'-0' to El. -15'-0". This monitoring well will be used to evaluate if contaminants may have migrated along the backfill of the Discharge Canal towards the Hudson River.

3.1.6 Temporary Still Wells A Temporary Still Well will be located on the west side of the Discharge Canal within the Hudson River. In addition, another Temporary Still W'ell will be located within the.Discharge Canal at the south end of the Discharge Canal.

These wells'will be ilocated outside the Protected Area Fence. The Temporary Still Wells will be used to validate the hydrogeology at the IPEC Site.

3.2 Design Basis Discussion 3.2.1 Monitoring Wells No. MW-31 and No. MW-32 will be open rock wall type wells. These monitoring wells will be advanced -90 FT, i.e., from EL 79'-6" to EL -10'-0". The upper -5 FT of these wells will consist of a 4"0 carbon steel casing, which will be protected by a manhole and steel sleeve. Following completion of each monitoring well, the wells will be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

3.2.2 Monitoring Wells No. MW-33 though No. MW-38 will be screen type wells.

Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 will be will be advanced -29 FT, i.e., from EL 18'-6" to EL -10'-0". Monitoring Well No.

MW-36 will be will be advanced -28 FT, i.e., from EL 12'-9" to EL-15'-0".

Monitoring Wells No. MW-37 and No. MW-38 will be advanced from EL 15'.-."

to EL -15'-0". Each well will be constructed with a 4"0, 0.05" slotted PVC screen, which will penetrate -5 FT into the water table. A 4"0 PVC riser pipe will extend from the screened section to grade elevation. The annular space around the screened section will be backfilled with Filler Gravel material to

-2 FT above the screened section. A 2 FT long Bentonite Plug will be installed above the Filler Gravel material. The annular space around the 4"0 PVC riser pipe will be grouted from the Bentonite Plug to grade elevation. Following completion of each monitoring well, the well will be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

- ER RESPONSE NO. ER-05-2-113 ENN-DC-l 15 Rev 5

- Entergy NUCLEAR CHANGE RESPONSE PAGE 8 OF 13 3.2.3 A Temporary Still Well will be located on the west side of the Discharge Canal within the Hudson River. In addition, another Temporary Still Well will be located within the Discharge Canal at the south end of the Discharge Canal.

These wells will be located outside the Protected Area Fence. Each well will be advanced from the Discharge Canal walkway to the river bottom or the canal bottom. Each monitoring well will be constructed with a 2"0, 2 FT long, 0.0Ž"

slotted stainless steel screen, which will rest on the river bottom or the canal bottom. A 2"0 stainless steel riser pipe will extend from the screened section to an elevation above the Discharge Canal walkway handrail. The Temporary Still Wells will be used to validate the hydrogeology at the IPEC Site.

3.3 Design Input Considerations See EN-DC-141, Attachment 9.1 - "Design Input Record"

Relationship With Other Modifications This modification does not interface wvith any other modifications; however, ERCN No. IP2-05-25674 installed Monitoring Well No. MW-30 within the IP2-FSB.

3.5 Operating Experience (OE) Review A search of the EPIX Database was performed using these keywords - "Wells", "Site Sampling Wells", "Site Well Drilling", "Site Drilling" and "Monitoring Wells". No INPO hits were detected. The only industry operating experience was addressed in NR.C Information Notice No. 2004-05, "Spent Fuel Pool Leakage To Onsite Groundwater".

3.6 Design Margin Analysis The monitoring wells are passive components, which do not interface with any plant systems or change plant system configurations; therefore, this modification does not impact any existing SSC design margin analyses or introduce a new SSC design margin analysis.

4.0 IMPACT ON CURRENT OPERATIONAL BASIS This modification will have no impact on the current plant operational bases. The monitoring wells are passive components, which do not interface with any plant systems or change plant system configurations. Drilling of the boreholes for the monitoring wells has the potential to impact underground utilities and subsurface structures, which is addressed in Section 5.1.

f ER RESPONSE NO. ER-05-2-113 ENN-DC-115 Rev S

-Entergy NUCLEAR CHANGE RESPONSE PAGE 9 OF 13 5.0 ENGINEERING INSTRUCTIONS NECESSARY TO IMPLEMENT THE CHANGE 5.1 General Requirements 5.1.1 To the maximum extent practical, the workscope associated with this modification shall be performed in accordance with the skill of the craft.

5.1.2 All work shall be performed in accordance with the applicable OSHA requirements addressed in 29CFR1910 and 29CFR1926. During implementation of the modifications, the Installer shall adhere to all safety precautions, as identified in applicable Entergy Procedures.

5.1.3 Prior to drilling the borings, review underground utility drawings and subsurface structure drawings to determine candidate boring locations.

5.1.4 Prior to drilling the borings, a surface geophysical survey method shall be used to pre-clear candidate boring locations to a depth of -5 FT below grade elevation.

The geophysical survey shall consist of electromagnetic metal detectors, utility locating instruments or ground penetrating radar. In addition, non-metallic utilities may be investigated by inserting a flexible steel antenna into the lines, if accessible, and using a utility locating instrument to detect a signal.

5.1.5 Prior to drilling the borings, map the rebar to identify potential interferences and if required, obtain Design Engineering permission to cut rebar. Provide a step in the job order for Design Engineering approval and sign-off.

5.1.6 Design Engineering shall approve the candidate boring locations for drilling.

Provide a step in the job order for Design Engineering approval and sign-off.

5.1.7 A high-vacuum excavation technique shall be used in combination with an air knife to excavate unconsolidated materials to a minimum of 5 FT below grade elevation or until bedrocktobstructions are encountered, which ever is less. Do not use equipment, which may possibly damage subsurface utilities.

5.1.8 All drill cuttings and drilling fluids will be containerized and staged on-site.

Characterization and disposal of the wastes shall be in accordance with applicable Entergy procedures.

5.1.9 After installation of Monitoring Wells No. MW-31 through No. MW-38, the Installer shall document the 'As-Installed" location (longitude, latitude and elevation) for each monitoring well.

5.1.10 Monitoring Wells No. MW-31 through No. MW-38 shall be tagged per Entergy Plant Procedure No. OAP-044. Obtain stainless steel labels from Operation Support per Label Request Form, which should be submitted by the Responsible Engineer.

ER RESPONSE NO. ER-05-2-1 13 ENN-DC- 115 Rev 5 41tEntergy NUCLEAR CHANGE RESPONSE PAGE 10 OF 13 5.2 Monitoring Wells No. MW-31 And No. MW-32 5.2.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2-FSB Monitoring Wells No. MW-31 and No. MW-32. The general area locations for these wells are indicated on Entergy Drawing No. DRN-05-05395.

5.2.2 Install Monitoring Wells No. MW-31 and No. MW-32 in accordance with Entergy Drawing No. DRN-05-05385, Detail 1.

5.2.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

5.2.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-3 1 and No. MW-32.

5.2.5 After data acquisition, remove pressure transducers.

5.3 Monitoring Wells No. MW-33 Through No. MW-35 5.3.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2 Transformer Yard Area Monitoring Wells No. MW-33, No. MW-34 and No. MW-35. The general arta locations for these wells are indicated on Entergy Drawing No. DRN-OS-05395.

5.3.2 Install Monitoring Wells No. MW-33, No. MW-34 and No. MW-35 in accordance with Entergy Drawing No. DRN-05-05385, Detail 2.

5.3.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

5.3.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-33 through No. MW-35.

5.3.5 After data acquisition, remove pressure transducers.

5.4 Monitoring Well No. MW-36 Through No. MW-38 5.4.1 After completion of Step 5.1.2 and Step 5.1.3, locate IP2 Condenser Tube Withdrawal Pit Monitoring Well No. MW-36, IP2-TB Loading Bay Area Monitoring Well No. MW-37 and Discharge Canal Monitoring Well No. MW-38. The general area locations for these wells are indicated on Entergy Drawing No. DRN-05-05395.

5.4.2 Install Monitoring Wells No. MW-36, No. MW-37 and No. MW-38 in accordance with Entergy Drawing No. DRN-05-05385, Detail 3, Detail 4 and Detail 5.

ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5

-'Erntergy NUCLEAR CHANGE RESPONSE PAGE I I OF 13 5.4.3 Following completion of each monitoring well, the well shall be developed in accordance with the "Post Modification Test Plan Form", Attachment I and Attachment II.

5.4.4 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Wells No. MW-36 through No. MW-38.

5.4.5 After data acquisition, remove pressure transducers.

5.5 Existing Monitoring Well No. U3-TI 5.5.1 In order to install a Pressure Transducer within Monitoring Well No. U3-Tl, which is located within the IP3-TB, EL 15'-C", raise the existing well stand pipe by

-1.5 FT to minimize potential seepage of groundwater, which may be under the

..,... floor slab.

5.5.2 The existing well stand pipe for Monitoring Well No. U3-TI shall be modified in accordance with Entergy Drawing No. DRN-05-05409.

5.5.3 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in Monitoring Well No. U3-TI.

5.5.4 After data acquisition, remove pressure transducers.

5.6 Temporary Installation Of Still Wells 5.6.1 Install one still well on the west side of the Discharge Canal within the Hudson River. In addition, install a second still well within the Discharge Canal at the south end of the Discharge Canal.

5.6.2 Temporary installation (Field-to-Suit) of the still wells shall be in accordance with Entergy Drawing No. DRN-05-05409.

5.6.3 Install (Field-to-Suit) In-Situ Mini-Troll Pressure Transducers in the two Temporary Still Wells.

5.6.4 After data acquisition, remove still wells and pressure transducers.

5.7 Foreign Material Exclusion Control Requirements 5.7.1 When not working, the tops of the well borehole, carbon steel well casing and PVC well riser pipes shall be temporarily sealed in accordance with applicable Entergy Procedures to prevent the introduction of materials or debris into the well borehole or monitoring wells.

_ ER RESPONSE NO. ER-05-2-113 ENN-DC- 115 Rev 5 Enltegy NUCLEAR CHANGE RESPONSE PAGE 12 OF 13 6.1 ASME or ASTM materials are acceptable. Material and equipment shall be handled, shipped and stored in accordance with of ANSI N45.2.2, Level D.

6.2 For Monitoring Wells No. MW-31 and No. MW-32, the 4"0, Sch. 40, carbon steel casing material shall be in accordance ASTM A53 or ASTM A106, Gr B.

6.3 For Monitoring Wells No. MW-33 through No. MW-38, the solid 4"0, Sch. 40, PVC riser pipe material shall be in accordance ASTM D1784.

6.4 For Monitoring Wells No. MW-33 through No. MW-38, the slotted (0.05" Wide Slcts),

4"0, Sch. 40, PVC screen material shall be in accordance ASTM D1784.

6.5 For Monitoring Wells No. MW-33 through No. MW-38, the well cap shall be Morris Model No. 318104001.

6.6 For Monitoring Wells No. MW-31 through No. MW-38, the manhole cover and manhole cover/steel sleeve shall be shall be Morris Model No. 318101200.

6.7 For the Temporary Still Wells, the 2"0, Sch 40, stainless steel riser pipe material shall be in accordance ASTM A312.

6.8 For the Temporary Still Wells, the slotted (0.02" Wide Slots), 2"0, Sch. 40, stainless steel screen material shall be in accordance ASTM A312.

6.9 For existing IP3 Monitoring Well No. U3-TI, the 1.25"0 PVC riser pipe extension and coupling shall be in accordance ASTM D1784.

7.0 SPECIAL PROCESS REQUIREMENTS NOT APPLICABLE 8.0 TEST AND INSPECTION REQUIREMENTS See ENN-DC-117, Attachment 9.4 - "Post Modification Test Plan Form" 9.0 ATTACHMENTS 9.1 Distributed For Field Work/Installation 9.1.1 ENN-DC- 117, Attachment 9.4 - "Post Modification Test Plan Form" 9.1.2 Entergy Drawing No. DRN-05-05385 9.1.3 Entergy Drawing No. DRN-05-05395 9.1.4 Entergy Drawing No. DRN-05-05409

ER RESPONSE NO. ER-05 113 ENN-DC- 115 Rev 5 7Entergy NUCLEAR CHANGE RESPONSE PAGE 13 OF 13 9.2 Not Distributed For Field Work/Installation 9.2.1 Entergy Procedure No. ENN-DC-141, Attachment 9.1 - "Design Input Record" 9.2.2 Entergy Procedure No. ENN-DC-141, Attachment 9.2 - "Design Input Record Continuation Sheet" 9.2.3 Entergy Procedure No. ENN-LI-100, Attachment 9.1 "Process Applicability Determination" 9.2.4 Entergy Procedure No. ENN-LI-101, Attachment 9.1 - "50.59 Screen Control Form"

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ATTACHMENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet I of I ER No. ER-05-2-113 Rev 0

Title:

INSTALLATION OF NEW Page 1 of 5 MONITORING WELLS FOR IP2-SFP Test Requirement(s) Acceptance Criteria Item # E Construction Attachment I and Attachment II Attachment I and Attachment II 001 El Functional El ER Assumption Item # El Construction El Functional D ER Assumption Item # D Construction Q Functional El ER Assumption Item # El Construction El Functional El ER Assumption Item # El Construction L] Functional El ER Assumption Item # a Construction El Functional El ER Assumption Item # El Construction L Functional Li ER Assumption Item # El Construction a Functional El ER Assumption

ATTACHM ENT 9.4 POST MODIFICATION TEST PLAN FORm Sheet 2 of :5 ATTACHMENT I MONITORING WELL DEVELOPMENT PLAN 1.0 Multilevel Sampling Equipment Tht Installer shall use a Waterloo Systems Multilevel Sampling System supplied by Solist. This system uses modular components which form a sealed casing string of various casing lengths, packers, ports, a base plug and a surface manifold. This configuration allows accurate placement of ports at precise monitoring zones. Monitoring tubes attached to the stem of each port individually connect that

-i monitoring zone to the surface. The standard system is built on 2"0 Schedule 80 PVC pipe to fit 3'- 4" 7 diameter boreholes and uses 3 FT long packers. Stainless steel components, custom packer materials and sizes, Teflon tubing are available.

Monitoring ports are constructed from 316 Stainless Steel. Ports are isolated by packers at each desired monitoring zone and are individually connected to the surface manifold with narrow diameter tubing.

Thus formation water enters the port, passes into the stem, up into the monitoring tube attached to the stem, to its static level. A sampling pump and pressure transducer will be dedicated to each monitoring zone by attachment to the port stem.

The manifold completes the system at surface. It organizes, identifies, and coordinates the tubes and/or cables from each monitoring zone. The manifold allows connection to each transducer in turn, and a simple, one-step connection for operation of pumps. When dedicated pumps are selected, it allows individual zones to be purged separately, or purging of many zones simultaneously to reduce field tirres.

Peimanent packers ensure long term integrity of seals in cored bedrock holes and cased wells. They use a vwater activated expansion sleeve fitted over the perforated packer body. A layer of porous plastic dis ributes water evenly to the packer expansion material. A Rubber/Kevlar/Rubber sheath envelops the expansion material. The Kevlar layer provides strength to bridge across large fissures. The pliant gum rubber forms an effective seal against the borehole wall. Water is added to the inside of the sealed casing string after installation. The water passes through the packer body into the expansion sleeve, causing the material to expand. Thus an engineered seal is permanently formed against the borehole wall.

The Installer shall use Waterloo Systems Gas-Driven Double Valve Pumps supplied by Solist with stainless steel and Teflon valves. The pumps are connected directly to the stem of each port and dual line polyethylene or Teflon tubing connects the pump to the wellhead manifold. The pumps will use manual pump control units. They have quick-connect couplings with only a single connection t: the manifold required. Samples from all levels are easily and rapidly obtained. Purging from some or all levels simultaneously is accommodated by the multi-purge feature of the manifold.

ATTACHMENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet 3 of 5 2.0 Rock Face Logging The Installer shall provide an expert geologist or geologic engineer to log the rock face exposed in the IP2-FSB. The bedrock face will be mapped and logged for lithology, bedding planes, fractures, joints and faults. The three dimensional orientation of the surfaces winl be recorded and evaluated. The information will be used to understand the fracture orientations and their control on the hydrologic processes at the site.

3.0 Geophysical Well Logging Prior to completing the wells.as nperpnanent monitoring wells, the Installer shall conduct down-hole geophysical well-logging of ite6thre&1 completed borings adjacent to MP2-FSB. The well-logging will consist of borehole temperature logging, fluid resistivity, 3-arm caliper logging, acoustical televiewer logging (ATV) and heat pulse flow meter Jogging. The ATV log will provide data on fracture depth and ori ntation. The caliper log will provide information on depths of bedrock fractures. The fluid temperature and fluid resistivity will provide information as to which fractures are productive.

4.0 Parker Testing Bas;ed upon review of the geophysical well logging results, the Installer shall select discreet intervals to conduct packer testing to assess hydraulic conductivity within the bedrock. Packer tests will be performed using a double inflatable bladder and straddle packer assembly with a 10 FT long testing zone. Packer testing will begin at the highest testing zone and continue down the length of the uncased bedrock. Packer test intervals and test pressures will be determined in the field and recorded. The raw data will be reduced in the office and hydraulic conductivity values will be calculated using a computer program called Permcalc, developed by GZA based on the methods presented in the US-DOI, "Groundwater Manual".

5.0 Hydraulic Conductivity Tests The Installer shall conduct hydraulic conductivity "pump/drawdown tests" at each of the existing groundwater monitoring wells, as well as, the (6) new screened monitoring wells. The test generally identifies the rates of rising water through the surrounding soils for which the test is being conducted.

Hydraulic conductivity and transmissivity are then calculated from those results. At each of the tested monitoring wells, the resting (static) water level will be measured along with the depth and diameter of the well casing. An electrical submersible pump will be utilized to drawdown water in the well. The pumping rate will be adjusted until a steady state is achieved. Discharged water will be pumped to 275-gallon plastic holding tanks. Approximately 350 gallons of water will be generated for each monitoring well. Elapsed time and water levels will be manually recorded and recorded by a vibrating wire transducer and data logger system at 10-second intervals. The test will be repeated at each tested monitoring well. The resultant data will be evaluated to assess the hydraulic conductivity of the forriations.

ATrACHM ENT 9.4 POST MODIFICATION TEST PLAN FORm Sheet 4 of 5 6.0 Groundwater Sarupling And Analysis Following installation of the new monitoring wells, the Installer will collect groundwater samples from each of the previously installed wells and the newly installed wells. Groundwater samples will be collected using USEPA low flow procedures. Groundwater samples will be collected from five feet below the water table or adjacent to high permeability flow zones as documented by geophysical logging. A decontaminated, stainless steel electrical submersible pump with controller and dedicated tubing will used to perform the groundwater sampling activities. The wells will be pumped for purging and sampling at a flow rate of between 250 to 500 mL per min (mUmin). Field parameters, including pE, specific conductivity, turbidity, dissolved oxygen, temperature, and ORP, were measured

%eaproximately every five (5) minutes during the purge process at each well using a multi.parameter i!;'wv.ter quality system. Purging will cease when all or most field parameters have stabilized touwithin the range specified in the US-EPA "Groundwater Sampling Procedure For Low Stress Purging and Sampling".

Groundwater samples will be given to IPEC personnel who will be responsible for chemical analysis.

7.0 Installation And Monitoring Of Pressure Transducers In order to validate hydrogeology at the IPEC Site, the Installer will temporarily install In-situ Mini-Troll pressure transducers in existing on-site groundwater monitoring wells, as well as, the newly installed wells.

In addition, the Installer will install (2) still wells which will house pressure transducers. One still well will be installed on the west side of the Discharge Canal within the Hudson River. The second still well will be installed on the south end of the DrainageCanal within the Drainage Canal proper.

In order to install a transducer within well U3-TI, located on the bottom floor of the Unit 3 Turbine Building, the Installer will need to raise the existing stand pipe by 1.5 feet in order to minimize potential seepage of groundwater, which is under pressure beneath the slab. The additional 1.5 feet of one-inch diameterPVC riser pipe will be secured to the existing riser pipe using a PVC coupling and PVC glue.

The pressure transducers will be set one-foot off the bottoms of the wells with a maximum of 100 FT of water column above the transducer. The transducers will be set to record water levels in the wells on at specific intervals. The information will aid in assessing tidal influences on groundwater at the Site, as well as, assessing the flux of groundwater across the Site.

8.0 Elvation Survey Th, Installer will locate and survey Monitoring Wells No. MW-3 I through No. MW-38. The longitude and latitude of each well will be measured to the nearest second and the elevation of each well will be measured to one-hundredth of a foot. The elevation of each well will be referenced to on-site datum. In addition, several catch basins and drainage points will be surveyed to determine their exact locations and elevations.

ATrACHMENT 9.4 POST MODIFICATION TEST PLAN FORM Sheet 5 of 5 ATTACHMENT 11 NYS-DEC SAMPLING GUIDELINES AND PROTOCOLS Section 55.4 - Monitoring And Well Development All permanently installed wells shall be adequately developed prior to initial sampling efforts. Adequate development should eliminate all fine material from the area of the well screen and allow for the collection of a sample which is free of suspended materials. Wells installed by "wet drilling' whre drilling muds are used shall be developed so that residual drilling muds will not settle around the4welI1r1ee~nisjr in the surrounding soil and contaminate future sampling. Various methods may be used to develop wells. These methods consist of suction lift pumping (?itcher, centrifugal, roller, piston, peristaltic pumps) pressure injection pumping, submersible pumping, surge blocks, bailing, and air lift pumping.

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