ML061320277

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E-mail from D. Croulet of Entergy to Various, Regarding Snap Shot Assessment - Gw
ML061320277
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/14/2006
From: Croulet D
Entergy Nuclear Operations
To: Noggle J
NRC/FSME
References
FOIA/PA-2006-0140
Download: ML061320277 (28)
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Text

X James No Jgle - FW: Snap Shot Assessment - GW IPage 1 l From:

"Croulet, Donald" <dcroule entergy.com>

To:

"Cox, Mark R" <mcox90@entergy.com>, "Conroy, Pat" <PConroyQentergy.com>,

"Bowman, Greg " <GBowm90@cc--exsO3.prod.entergy.com>, "'James Noggle"' <JDN@nrc.gov>,

"'Timothy Rice"' <tbrice gw.dec.state.ny.us>, "PRICE, ERNEST JR" <EPRICE2@entergy.com>, "Robert Oliveira (boliveira~amnucins.com)" <boliveira~amnucins.com>, "Janicki, John"

<JJanick@entergy.com>, "Quinn, Dennis" <dquin9l @entergy.com>, "Hinrichs, Gary"

<ghinric @entergy.com>

Date:

3/14/06 7:26AM

Subject:

FW: Snap Shot Assessment - GW Please find attached a snap shot self assessment from our tritium groundwater workshop held on February 14, 2006 at IPEC.

From: Lavera, Ron Sent: Monday, March 13, 2006 3:45 PM To: Axelson, William L; Croulet, Donald; Jones, T. R.

Subject:

RE: Snap Shot Assessment - GW Don Bill A. has asked that we forward a copy of the attached report to the attention of the State and the NRC.

<<GWWorkshop.2006_FinalO.pdf>>

Thanks Ron 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 From: Axelson, William L Sent: Monday, March 13, 2006 2:55 PM To: Lavera, Ron

Subject:

RE: Snap Shot Assessment - GW yes From: Lavera, Ron Sent: Monday, March 13, 2006 1:00 PM To: Axelson, William L

Subject:

RE: Snap Shot Assessment - GW No.

James Noggle - FW: Snap Shot Assessment - GW Piage 21 Do you want me to send them a copy via Licensing?

Ron 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 From: Axelson, William L Sent: Monday, March 13, 2006 11:07 AM To: Lavera, Ron

Subject:

RE: Snap Shot Assessment - GW Did you send this to nrc or dec?

From: Lavera, Ron Sent: Monday, March 13, 2006 11:02 AM To: Axelson, William L; Nutter, Victor (WPO)

Subject:

Snap Shot Assessment - GW Please see the attached Snap Shot Self Assessment report.

<<< File: GWWorkshop-2006-FinalO.pdf >>

Ron RLaVeraientergy.com <mailto:RLaVeraaentergy.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

Snap Shot Self Assessment -Ground Water Workshop 2006 P-P Entefgy IPEC SNAPSHOT SELF-ASSESSMENT REPORT DEPARTMENT: Radiation Protection TITLE: IP3LO-2006-0223 Snap Shot Self Assessment -Ground Water Workshop 2006 Approved By:

Submitted By:

W. Axelson R. LaVera RP-Support Supv.

/ Date Team Leader Page 1 of 26

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 2 of 26 ASSESSMENT SCOPE This assessment was performed to evaluate the current IPEC practices with Lessons Learned as presented at the Ground Water Contamination Workshop 2006 The scope of this assessment includes:

Summary of notes from relevant presentations made at the workshop meeting

  • Summary of Lessons Learned from breakout session This topic was selected because potential relevance to processes and practices at IPEC.

The following industry standards were used in developing the objectives and criteria

  • NA OBJECTIVES
  • Objective 1: Compare IPEC ground water sampling methods and experiences to those of experienced sites
  • Objective 2: Compare IPEC ground water source investigation processes to those of experienced sites

Snap Shot Self Assessment -' EPRI Ground Water Contamination Workshop 2005 Page 3 of 26 l1.

EVALUATION

SUMMARY

A number of sites that have experienced ground water contamination issues were invited to attend a one day Ground Water Workshop, to be conducted at IPEC on February 14th 2006. There were 19 attendees representing 9 different companies/sites. Attached is a detailed summary of the meeting agenda, recommended breakout discussion topics observation highlights.

  • No Areas For Improvement were identified
  • Three Negative Observations were identified Oblective RP-1: Compare IPEC ground water sampling methods and experiences to those of experienced sites o Negative Observation #1: Experienced sites have established a protocol for evaluating suspect data prior to reporting to the stakeholders. IPEC has not established a good process for this evaluation o Negative Observation #2: Experienced sites have established better methods and practices than employed at IPEC to help prevent cross contamination of samples 0

Oblective RP-2: Compare IPEC ground water source investigation processes to those of experienced sites o

Negative Observation #3: Experienced sites have established better information about sources of underground contamination and potential flow paths for contaminated water under ground

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 4 of 26 IV.

CONCLUSIONS and RECOMMENDED ACTIONS Negative Observation #1: Experienced sites have established a protocol for evaluating suspect data prior to reporting to the stakeholders. IPEC has not established a good process for this evaluation Examples/Justification:

Participants made the following observations:

The sites established clear decision points agreed upon by stake holders:

o Minimum Detectable Activity detection limits (400-500 pCi/Li Tritium at some sites) o Near or off site ground water action points (All participants were able to establish a 1000 pCi/Li tritium value), which would establish "non-issue" thresholds (i.e. 20,000 pico Ci/Li EPA Drinking water limit) below which no action would be required.

o End points for remediation o The sites established a protocol for evaluating suspect data prior to reporting to the stakeholders. This protocol should be reviewed by and agreed upon by the stakeholders Consequences:

  • Use of inconsistent sample evaluation criteria can increase the cost of performing sample analysis associated with obtaining lower than needed detection limits. Inconsistent methods of reporting activity levels can reduce the trust and confidence of the stake holders.

Apparent Cause:

  • Insufficient sample evaluation processes are employed for evaluating samples taken at IPEC. Insufficient awareness of EPA guidance documents.

Corrective Actions:

  • CA To eliminate the inappropriate actions generated by reacting to inaccurate data, we need to establish a protocol for evaluating suspect data prior to reporting to the stakeholders. This protocol should be reviewed by and agreed upon by the stakeholders

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 5 of 26 CA Obtain and review EPA Documents and identify any required program changes:

a. CERCLA "Monitored Natural Attenuation"
b. Standard Procedure 901 for sampling.

Negative Observation #2: Experienced sites have established better methods and practices than employed at IPEC to help prevent cross contamination of samples Examples/Justification:

Participants made the following observations:

  • Use dedicated sample pumps in all wells that are routinely sampled. It costs about $1,000/well, but this is quickly saved by less time decontamination of pumps and tubing, and reducing the possibility of cross contamination Consequences:

Cross contamination of samples can lead to loss of confidence by stake holders, increased confusion and the resulting poor decision processes Apparent Cause:

  • Sharing sampling equipment between different sampling points Corrective Actions:
  • CA Use dedicated sample pumps in all wells that are routinely sampled. It costs about $1,000/well, but this is quickly saved by less time decontamination of pumps and tubing, and reducing the possibility of cross contamination.
  • CA-1 0 - Investigate the use of low flow pumps sampling pumps, methods, and required support equipment

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 6 of 26 Negative Observation #3: Experienced sites have established better information about sources of underground contamination and potential flow paths for contaminated water under ground Examples/Justification:

Participants made the following observations:

  • Some plants needed a PM program to ensure that pool leak detection drains are/stay clear. One site noted several hundred gallons of fluid were released following removal of blockage in installed leakage detection lines.
  • It is important to try and identify the source as soon as possible. Even if the plume is identified, it is import to continue to look to ensure all contributing factors have been identified. This may include going back even further in history to look at old leaks and spills. Several plants indicated that the contamination took a long time to dissipate (some still present at one site after 40 years), and this was also true of organic contaminants.

This is related to the "teabag effect", or the presence of contamination in the soil that washes out at a later time and acts as another source of tritium. Past spills should be reviewed all the way back to the startup of the first unit. Complete 50.75(g) records are critical to this effort

  • We need to look at non-obvious discharge paths for tritium. At one site, the water discharge for air handling units processing tritiated air, discharged to the sanitary sewer system.
  • Detailed depiction of underground pipes and structures are essential for predicting water flow paths by the site and for explaining plume movement to the stake holders. We need to have a complete knowledge of the hydrologic properties of the area under the plant and ALL underground structures (walls, pipes, cables).

The importance of the need for this data can not be overstated as tritium from sources of leakage will follow the low resistance flow paths provided by the gaps and fill materials adjacent to or surrounding underground Systems, Structures and Components (SSC's). You need to get whom ever you need as soon as possible to get this profile as in-depth as possible

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 7 of 26 Consequences:

Inadequate understanding of ground water flow patterns will impede the ability of the site to identify and repair existing leaks. Inadequate understanding of ground water flow patterns will prevent accurate determination of the impact to the site and surrounding environment.

  • Poor maintenance of leakage detection and other flow paths for contaminated water can result in inaccurate determination of leakage status and progression.
  • Poor understanding of past events may result in the misunderstanding of the integrity of SSC's up gradient from areas of positive sample results, when confounding contamination events are not considered.

Apparent Cause:

  • Documentation about underground systems structures

& components, is not reflected in a single, readily usable document.

  • Maintenance of installed leakage detection systems is not formalized.
  • 50.75(g) files associated with past contamination events have varing levels of detail and information available.

Corrective Actions:

  • CA Establish a sampling program to ensure that pool leak detection drains are sampled on a periodic basis.
  • CA Establish a PM program to ensure that pool leak detection drains are/stay clear. We need to do that at IP-3 and for the Leak Collection Container system at IP-2
  • CA We need to have a complete knowledge of ALL underground structures (walls, pipes, cables). The importance of the need for this data can not be overstated as tritium from sources of leakage will follow the low resistance flow paths provided by the gaps and fill materials adjacent to or surrounding underground Systems, Structures and Components (SSC's)
  • CA Past spills (including completed 50.75(g) files) should be reviewed all the way back to the startup of the first unit. Complete 50.75(g) records are critical to this effort.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 8 of 26

  • CA Perform an evaluation of our storm drain systems for integrity of the system and the soil around the pipes and any breaks in the lines.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 9 of 26 V.

REFERENCES Reg Guide 1.109 Calculation of Annual Doses to Man from Routing Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I EPRI TR-1 011730 Ground Water Guidance for Nuclear Power Plants Final Report September2005 Branch Technical Position Paper (DRAFT) on Site Characterization for Decommissioning 1994 NRC Information Notice 2004-05 Spent Fuel Pool Leakage to Onsite Ground Water

  • Branch Technical Position Paper on When to Remediate Inadvertent Contamination of the Terrestrial Environment 1994
  • NUREG-1575 Rev. 1 Multi Agency Radiation and Site Investigation Manual (MARSSIM) 57 FR 13389. April 16,1992. Ection Plan to Ensure Timely Cleanup of Site Decommissioning Management Plan Sites," Federal Register a

Environmental Protection Agency (EPA). 1993e. Subsurface Characterization and Monitoring Techniques: A Desk Reference Guide, Volume 1. EPA/625/R-93/003A, U.S. Environmental Protection Agency, Cincinnati, Ohio. (PB94-136272) 10 CFR 20. 1995. U.S. Nuclear Regulatory Commission. Standards for Protection Against Radiation.

10 CFR 50.75(g)

"Environmental Radiation Protection Standards for Nuclear Power NRC Regulatory Issue Summary 2002-02 Lessons Learned Related to Recently Submitted Decommissioning Plans and License Termination Plans VI.

TEAM MEMBERS Team Leader:

R. LaVera Team Members:

R. Sachatello W. Axelson D. Quinn

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 10 of 26 TRITIUM GROUNDWATER WORKSHOP INDIAN POINT STATION BUCHANAN, NY FEBRUARY 14, 2006

Snap Shot Self Assessment.- EPRI Ground Water Contamination Workshop 2005 Page 11 of 26 SEMINAR OBJECTIVE:

This 1 day workshop is designed to interactively share and update information on tritium groundwater investigations at various power facilities and national laboratories.

BACKGROUND:

Recent experiences at decommissioning nuclear facilities, national laboratories, and active power facilities has shown that tritium groundwater contamination is present in various concentrations to both onsite and offsite locations. Utilities are using various monitoring programs, remediation procedures, and community stakeholder involvement to inform and protect the public from this groundwater contaminant. In these programs, utility tritium groundwater investigations can typically expend 1-5 years for tritium investigation programs, and upwards of several million dollars for monitoring well installations, and corrective actions.

This seminar will bring together representatives from various utilities and national laboratories to interactively discuss their experiences, successes, and "what they would do different" approaches to this subject.

TOPIC SUGGESTIONS FOR EACH PRESENTER Welcoming and Opening Remarks:

Don Mayer-Indian Point Manager of Special Projects Sharina Experiences (Do's and Don'ts):

Each presenter is encouraged to provide a 30 minute discussion on their facilities tritium monitoring program with emphasis on major lessons learned with particular emphasis on regulator interfaces and involvement, stakeholder community involvement, and setting priorities to fully characterize the ground water magnitude, plume characteristics, and its regulatory impact.

Sample Selection Criteria:

Discuss what locations were selected for monitoring well sampling. Explain use of Storm Drain data collection if used, and value or complication it added.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 12 of 26 Schedules and Costs:

Discuss the cost and schedule impacts for monitoring well installations, lab analysis, remediation options (hydraulic remediation or other methods),and other cost or scheduler drivers.

Remediation Options and Experience:

Discuss what remediation processes were involved and how, and at what level, and at what cost, it was conducted. Discuss the progress, engineering considerations, successes and limitations. Discuss what the end point of activity was used to terminate the remediation Lona Term Monitoring:

Discuss long term monitoring programs, processes, sample frequencies, analysis programs, and how it was decided upon. Discuss who does long term sampling (in house or vendor personnel) and long term program expenditures.

Regulatory Commitments:

Discuss what commitments the site has made with regulators for monitoring and cleanup. Discuss how the program is integrated with the ODCM and REMP programs Three Most Important Lessons Learned:

Discuss the most important lessons learned from your utilities involvement Round Table Breakout and Panel Discussion

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 13 of 26 Discussion Topics for Panel INDUSTRIAL SAFETY IMPACTS DURING TRITIUM INVESTIGATIONS:

  • Has any personnel injuries happened during the tritium investigation
  • Have you had any near misses such as hitting a buried pipe, energized electric cable, etc ?
  • Any other area of interest from an industrial safety perspective, please discuss LEAK DISCOVERY AND REPAIR SUCCESS:

Did you definitively discover the single (or multiple) sources of the tritium leakage?

  • Where was the cause of the leak (s) ?
  • What led you to the discovery (monitoring wells, 50.75g knowledge, visual inspections)
  • How long had the leak occurred before you discovered it (years ?)
  • Were you able to fix the leak permanently ? How ?
  • How expensive was the repair ?

Do you have high confidence all the big contributors were discovered

  • Did you put robots in your SFP's, RWST, down pipes ?

Did you put a robot under your SFP racks ?

  • Was the robotic inspections definitive, or if not useful ?
  • Was your fuel pool steel liner in good conditions and how do you prove that it is ?

What percentage of your SFP was visually observed (include walls, floor, etc)

What was your under fuel rack clearance height ( ie 3"-4") ?

  • What vendor firm did your fuel pool inspection ?
  • Did you do underwater repair on your SFP liner ? If so how ?

Did you dig out large amounts of soil or rock to find the leak ?

  • If it came from your SFP, did your tell tail drain system find it ?
  • How did you prove other contributors were not broken ( RWST, etc
  • What leak rate do you state you can detect with installed leak detection systems (other than wells Do you have unlined sumps (i.e. concrete sumps ) that contain high tritium concentrations ?

Did you do dye test and were they definitive (useful)

Has your ongoing ISI programs changed to reflect tritium leakage issues ?

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 14 of 26 REMEDIATION ISSUES:

  • Did you remediate groundwater tritium ?
  • If so how ? (i.e. hydraulic pumping, etc)
  • If you hydraulically remediated, explain what you did ?
  • Where do you pump it to ?
  • What in-line samplers if any do you have ?
  • Are you still doing it ?
  • What was the trigger level or regulatory pressure that made you remediate ?
  • How did you measure the success (or progress) of remediation ?

Did remediation have negative side affects such as drawing contamination to different areas ?

  • Give any negatives (cost, equipment reliability) to remediation ?

SITE TOPOGRAPHY AND LOCATION:

  • Does your plant or site have off site drinking water wells close by ?
  • What is the approximate acreage of your facility ?
  • Are their any unique topographical issues that affects groundwater flow ?
  • How close are the closest personal residences located ?

STORM DRAINS, 80-10 PROGRAM ISSUES, 50.75 a PROGRAMS

  • Was your 80-10 program robust enough to prove leaks did not occur regularly ?
  • Did you extensively look at your storm drain systems ?
  • Did your storm drain manholes have tritium ? If so how long historically ?
  • Did your facility have good accurate engineering drawings of the storm drain system ?
  • Did any storm drains go to unmonitored release points ?
  • What was the highest tritium levels (pCi/L)found in a storm drain system ?
  • In the past if you had seen low level tritium in 80-10 monitoring would you have looked further ?
  • Is your 50.75g program robust, comprehensive, updated, and very useful for this type issue ?

Snap Shot Self Assessment - EPR.I Ground Water Contamination Workshop 2005 Page 15 of 26

  • What today would be "significant" in a monitoring well or storm drain

(.>1000 pCi/ L ?).

Did the other sites have "other programs" that should have detected tritium groundwater ?

WELL SAMPLING ISSUES

  • How often are you sampling wells (quarterly, monthly, weekly, etc)
  • Who (what onsite or vendor group) sample your wells ?
  • Who (name group) who counts your samples ( in house chem. Lab or vendor lab) ?
  • If you use a vendor to take your well samples, what are your yearly costs ?
  • How many wells does this cost include ( i.e. $ 180,000 yearly for 50 wells per quarter ?)
  • If you use on-site plant personnel for sampling, what is their training TRITIUM ANALYSIS ISSUES:
  • What level do you on-site count tritium to (< 1000, < 500, < 100 pCi/L, lower/higher ?)
  • What does your offsite vendor lab count tritium to ( < 60 pCi/L like NY State ?)
  • How large a volume sample do you take for outside vendor lab sample analysis ?

OTHER ISOTOPES:

  • If so what isotopes, concentrations, and where ?
  • If you detected Sr-90, how did that affect your sampling process and dose calculations OTHER TRACKING MATERIALS:
  • Did you detect PCBs ? If so how much and where ?

Did you see boron, if so how much, and where ?

Did you see solvents, or other items that could "fingerprint the source location"

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 16 of 26

  • Did you take pH or other measurement on wells (what are these other measurement ?)
  • Did you look for S/G additives Did you send samples out for Hydrazine, EDTA or other possible tracking agents ?
  • Does your plant venting system or S/G leakage normally add tritium to your facility environment and to what level ( ie. 1 E-06 uCi/cc or higher)

STRONTIUM-90 ISSUES:

  • Did your facility detect Sr-90 ?
  • If so where, and how much ?
  • One site said Sr-90 went in a different plume pathway than tritium /

Why ?

PLUME CHARACTERISTICS:

  • Did portions of your tritium go directly (unmonitored) to the river or settling ponds ?
  • What percentage was determined to go unmonitored offsite
  • How did you prove it didn't go to an unmonitored location ?
  • How did you calculate the offsite monitored and unmonitored tritium (leak rate, volume, concentration) ?

CROSS CONTAMINATION ISSUES:

Did tritium sampling cross contamination issues occur in your monitoring processes ?

  • What special precautions did you take on-site to preclude this ?
  • In the early phases, did you buy dedicated pumps, sampling eqpt for each well ?
  • Did you have many "false positives" from the State or NRC that had to be resolved ?
  • Did the State or NRC report levels of tritium or Sr-90 much different than your labs ?
  • Has the NRC asked you to investigate the possibility of clean system interfaces with contaminated systems ? If so do you have a robust program to do this and how ?

WELL LOCATIONS AND RATIONALES:

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 17 of 26

  • How many wells did you originally start with (Phase I) to define your tritium plume pathway ?
  • How many monitoring wells did you keep the permanent "steady state" monitoring well system ?
  • How deep were your average wells ?
  • Where the wells in bedrock or softer materials ?
  • Was your backfill regions sand, clay, shot rock ?
  • How many isolation zones (Packer zones) did each well have ?

PURGING WELLS

  • How did you handle and process large volumes of purge water with tritium ?
  • What was your activity trigger level to collect purge water in barrels or collection tanks ?
  • If you had a well with < 5000 pCi/L would you allow to purge it to the ground or storm drain ?
  • If not < 5000 pCi/L, at what level if any would you let tritium purge water to the ground ?
  • How many purge volumes do you use ( i.e. 3-5) other ?
  • Does "hard" water affect your purge water processing system ?
  • On a deep well (One site had -600' deep wells), what is your purge times for sampling ?
  • If you use offsite vendors to take the samples have you been satisfied ?

TRITIUM INVESTIGATION MANPOWER RESOURCES:

  • At the height of the tritium investigation process how many site or vendor personnel were involved ?
  • How many people are now involved ?
  • Give examples of approximate numbers for rad waste personnel, RP personnel, chemists, well samplers, management personnel ?
  • What was a typical (or highest) yearly budget for the tritium investigation ?

STAKEHOLDER INVOLVEMENT:

  • How often do you go to the State or NRC offices and meet with them on this issue ?

Do you provide weekly, monthly, quarterly, yearly formal reports?

  • How many public forum meetings have you had in your community ?

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 18 of 26

  • What was the level of public interest, involvement, or information petitioning ?
  • Where the public meetings well attended ?
  • What was the best way you had to explain this problem and investigation to the public ?
  • Did you have good plant aerial maps, video, show and tell displays etc ?

HYDROLOGIST ISSUES

  • Who did you use as your hydrology experts ?

Do you have a full time hydrology presence now ?

  • Was your hydrology team process accepted by your stakeholders and regulators ?
  • How were the number of wells determined ?
  • Did your management challenge or support the cost of the tritium project, give examples of pushback or endorsement ?

FINES/FSAR CHANGES/LICENSE AMMENDMENTS

  • Have you received any regulatory fines or citations ? If so explain
  • Have you had to modify your license to include continued on site monitoring ?
  • What is included in any license amendments ?
  • Have you had to buy any land or make restitution to outside groups ?

IF YOU HAD IT ALL OVER TO DO AGAIN:

  • What Top 3 "Lessons Learned" would you give to another utility on this issue ?
  • What would you do different if the tritium was initially discovered today onsite ?
  • What would you do first ?
  • How would you structure your project team to do the initial and continuing investigation
  • Would you stick with onsite resources and treat it as a "level of effort project" ?
  • What organizations on or offsite proved invaluable ?
  • What groups were not effective ?
  • Did INPO get involved with your discovery and follow up investigations ?
  • Did ANI, EPRI, or other groups have heavy involvement, or results ?

Did other utilities offer help or OE or did you "do it on your own ?

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 19 of 26 Did any workshops help with this issue ?

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 20 of 26 Meeting Summary

1. Communications
a. Stakeholders
i. Most important to keep the stake holders involved and informed.

ii. Need to do this early, and often.

iii. Make sure that you have the agreement of the stake holder's prior to implementing changes.

iv. Need to have Subject Matter Experts [SME] (Recommend PhD or professionally certified level) for Geology, Radiation Protection & Communications (such as Peter Sandman, a (SME) on communications). These people should be available at stake holder and public meetings

v. We need to establish clear decision points agreed upon by stake holders:
1. Minimum Detectable Activity detection limits (400-500 pCi/Li Tritium at some sites)
2. Near or off site ground water action points (All participants were able to establish a 1000 pCi/Li tritium value), which would establish "non-issue" thresholds (i.e. 20,000 pico Ci/Li EPA Drinking water limit) below which no action would be required.
3. End points for remediation vi.

Regardless of which model(s) used, make sure that the stake holders agree with your approach before you start the modeling process.

vii. The regulatory structure at various sites is different. We need to know who really has the responsibility to make demands of the station. This includes a combination of NRC, EPA, State and local environmental protection departments.

viii. All utilities at this point have better graphics than we do for public meetings ix. These are 3-10 year projects at all of the facilities

x. No utility was faster or more aggressive than we have been moving, to this date. We are just beginning the process.
b. Site Personnel i The employees are going to be your first line of defense out in the public when friends and neighbors ask questions.

ii. We need to have short briefing/information sheet for all of the plant personnel so that they can address questions from the public.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 21 of 26

2. Sampling
a. To eliminate the inappropriate actions generated by reacting to inaccurate data, we need to establish a protocol for evaluating suspect data prior to reporting to the stakeholders. This protocol should be reviewed by and agreed upon by the stakeholders
b. A high priority should be set to get monitoring capability at the site boundary in all directions and offsite to ensure the plume is contained and has not left site.
c. Some plants needed a PM program to ensure that pool leak detection drains are/stay clear. We need to do that at IP-3 and now for the Leak Collection Container system at IP-2.
d. Other contaminants may be present. Test groundwater samples for other contaminants, such as solvents (VOCs), PCB's from building paints or oil etc.
e. Use dedicated sample pumps in all wells that are routinely sampled.

It costs about $1,000/well, but this is quickly saved by less time decontamination of pumps and tubing, and reducing the possibility of cross contamination.

f. Water samples taken, labeled, split, stored until all split sample results available and resolved. In some cases, samples had to be store for a good year to avoid issues.
3. Source Identification/Control
a. We need to look at non-obvious discharge paths for tritium. At one site, the water discharge for air handling units processing tritiated air, discharged to the sanitary sewer system.
b. Building seams appear to be likely sources for introduction of activity.
c. It is important to try and identify the source as soon as possible.

Even if the plume is identified, it is import to continue to look to ensure all contributing factors have been identified. This may include going back even further in history to look at old leaks and spills.

d. None of the attendees said that there was dose to the public near the limits
e. Dose reports should be verified or independently performed by an SME.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 22 of 26

4. Hydrology - Ground Water
a. Because tritium has the same density as water, they encountered conditions where tritium collected in stratified layers of ground water that would move vertically under the influence of precipitation etc.

This would give the false impression of a tritium concentration flux.

One site had to sample every 2 feet to determine gradient. Another member indicated that they had experienced very narrow strips of activity due to coarse (every 5 feet) checking of geological conditions.

b. Detailed depiction of underground pipes and structures are essential for predicting water flow paths by the site and for explaining plume movement to the stake holders.
c. Flow modeling using MODFLOW and MT3D were very useful in determining plume direction and extend as well as tritium concentration. Note: Due to fractured nature of our water table, these may not be the appropriate models. Regardless of which model(s) used, make sure that the stake holders agree with your approach before you start the modeling process.
d. We need to have a complete knowledge of the hydrologic properties of the area under the plant and ALL underground structures (walls, pipes, cables). The importance of the need for this data can not be overstated as tritium from sources of leakage will follow the low resistance flow paths provided by the gaps and fill materials adjacent to or surrounding underground Systems, Structures and Components (SSC's). You need to get whom ever you need as soon as possible to get this profile as in-depth as possible.
e. Several plants indicated that the contamination took a long time to dissipate (some still present at one site after 40 years), and this was also true of organic contaminants. This is related to the "teabag effect", or the presence of contamination in the soil that washes out at a later time and acts as another source of tritium. Past spills should be reviewed all the way back to the startup of the first unit.

Complete 50.75(g) records are critical to this effort.

f. None of the attendees had conducted tracer studies. We may be putting more "positive expectations to stakeholders" on what this test can actually deliver. The other sites were able to "stop" the identified leaks by such measures as large area sealant coats, removal of blockages or by draining the SSC that was the ultimate source of the activity. Due to the plant and fuel configurations, IPEC may not be able to accomplish this task.
g. Thin Monitoring Wells (1") will NOT be able to be used to help remediate leaks and often cannot support all of the required sampling and monitoring equipment. The cost associated with drilling a new well is prohibitive. It is cheaper in long run to drill 4" (or larger) Wells

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 23 of 26

h. One site's underground sanitary/sewers (not sure if they mean storm drains) had 20% loss to the Sewage Treatment Plant. We need to perform an evaluation of our storm drain systems for integrity of the system and the soil around the pipes and any breaks in the lines.

The importance of the need for this data can not be overstated as tritium from sources of leakage will follow the low resistance flow paths provided by the gaps and fill materials adjacent to or surrounding underground pipes and drainage components.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 24 of 26

5. Sampling
a. Should consider use of low flow sampling techniques to prevent unintentional movement of the tritium plume.
b. We may want to consider the use of low flow pumps for remediation to prevent moving other contaminants.
c. We need to review EPA Standard Procedure 901 for sampling.
d. Strontium concentration LLD was at the 1 pCi/Li in water level and the 0.02 pCi/gm level in soil.
e. One site found 45-60 mR/hr (hard gamma) on certain buried weathered bedrock which indicated the presence of (Cesium) transport to the location after burial. One site noted strontium migration to an extent greater than that of Cesium, but less that that of tritium. Strontium-90 was fairly wide spread at low concentration.
f. One site recommended the use of site specific Kd's (dispersion coefficients).
g. We should have an activity number for identified wells that would initiate an action level of recount for the lab.
h. Some of the stations had protocols for sample results and verification. We are getting the procedures from one of the attendees.
6. Remediation
a. Leaks were generally not found and repaired. Some plants expended 2 years of effort to find precise source of leak, and still didn't find the leak. One site could not find a leak even after the pool was drained and inspected. When repairs were successful, they were generally a global solution such as draining, drying and then coating an entire tank or pool, rather than fixing one or two individual leaks. The patch repairs of the SFP did NOT work. Some plants had problems with adherence of the small patches due to poor surface preparation. Stainless Steel is a relatively smooth surface that does not provide a lot of 'teeth"
b. One site experienced de-lamination of an appreciable section of the wall coating application of Instacote.
c. One site used the concept of doing a "Pilot Test" to allow implementation of remediation while the plan went through formal state approval.
d. Ensure that your remediation plan indicates that it is a "reactive plan" so that changes that need to be implemented as a result of changes in plume extent or direction, that do not need to be pre-approved by the state.
e. One site set up a trailer/tank arrangement to do spot remediation.
f. The remediation process can take some time to gain state approval.

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 25 of 26

g. We need to check EPA CERCLA "Monitored Natural Attenuation" guidance documents
h. ALL sites recommended not starting remediation until the site hydrology was well understood
i. The time from discovery of leak to actual hydraulic remediation varied from a low of 3 months at one site, to never done at another site. One site did not start remediation for 1 year, and another waited 2 years from discovery of leak to start of remediation.
j. One plant was able to install remediation wells inside plant buildings.

This simplified supply of utilities, facilitated maintenance and in many cases was more appropriate than external wells.

k. About 20-40 % of wells may have to be relocated based on many concerns and obstacles

Snap Shot Self Assessment - EPRI Ground Water Contamination Workshop 2005 Page 26 of 26 Recommended Corrective Actions:

1. Burns - To eliminate the inappropriate actions generated by reacting to inaccurate data, we need to establish a protocol for evaluating suspect data prior to reporting to the stakeholders. This protocol should be reviewed by and agreed upon by the stakeholders
2. Wilson - Establish a PM program to ensure that pool leak detection drains are/stay clear. We need to do that at IP-3 and for the Leak Collection Container system at IP-2.
3. Burns - Use dedicated sample pumps in all wells that are routinely sampled.

It costs about $1,000/well, but this is quickly saved by less time decontamination of pumps and tubing, and reducing the possibility of cross contamination.

4. Hinrichs -We need to have a complete knowledge of ALL underground structures (walls, pipes, cables). The importance of the need for this data can not be overstated as tritium from sources of leakage will follow the low resistance flow paths provided by the gaps and fill materials adjacent to or surrounding underground Systems, Structures and Components (SSC's).
5. Meighan - Past spills (including completed 50.75(g) files) should be reviewed all the way back to the startup of the first unit. Complete 50.75(g) records are critical to this effort.
6. Drake - Perform an evaluation of our storm drain systems for integrity of the system and the soil around the pipes and any breaks in the lines.
7. Burns - Investigate the use of low flow pumps sampling pumps, methods, and required support equipment
8. LaVera - Obtain and review EPA Documents:
a. CERCLA "Monitored Natural Attenuation"
b. Standard Procedure 901 for sampling.
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