ML090540158

Self Assessment List

ML090540158
Person / Time
Site:	Indian Point
Issue date:	07/31/2008
From:	Nuclear Energy Institute
To:	NRC Region 1
References
Download: ML090540158 (9)

Text

,MrA PT NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Reviewers:

P. Hollenbeck d.

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Date of Review: July 2008 r

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I Guideline Section Section Met Yes-No ObjectivelAcceptance Criteria Comments As Required 1.1 Ensure that the site characterization of geology and hydrology provides an understanding of predominant ground water gradients based upon current site conditions.

Perform hydrogeologic and geologic studies to determine predominant ground water flow characteristics and gradients.

1.1.a Y1I~s An extensive site groundwater investigation was performed from September 2005 through September 2007 and documented in Reference 1. Comprehensive geophysical testing of the site has determined the predominant groundwater characteristics such as water table elevations, gradients, flow rates and flow direction.

As appropriate, review existing hydrogeologic and geologic studies, As documented in Reference 1, GZA identified, historical environmental studies, and permitor license related retrieved and evaluated historic geological, 1.1.b reports.

Y s hydrogeological and geotechnical reports, as well as site construction plans and drawings and performed.

interviews with key site personnel to assist in studying the site.

Identify potential pathways for ground water migration from on-site As documented in Reference 1, groundwater flows 1.1.c locations to off-site locations through ground water.

Ys from the north, east and south towards the plant and

_____then ultimately discharges to the Hudson River.

Establish the frequency for periodic reviews of site hydrogeologic Reference 2 requires a review of the site hydrology 1.1.d studies.

Yes every 5 years. This may be achievable at IPEC via the quarterly report process presently in place and review by a hydrologist.

As appropriate, update the Final Safety Analysis Report with Based on Reference 1, minor changes to applicable changes to the hydrology and/or geology.

sections of the Unit 2 UFSAR have been submitted to 1.1.e Y s Licensing for approval. These changes are expected to be approved by September 2008. No updates to the Unit 3 UFSAR are currently underway.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Reviewers:

P. Hollenbeck*

Date of Review: July 2008 Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No Comments As Required 1.2 Identify site risk based on plant design and work practices Identify each SSC and work practice that involves or could As part of the extensive groundwater site reasonably be expected to involve licensed material and for which characterization activities and documented in there is a credible mechanism for the licensed material to reach Reference 1, all SSCs were reviewed to identify SSCs ground water.

that contain significant levels of radioactivity. Wells were installed downstream of these SSCs to assist in identifying leaks that could reach groundwater. Work 1.2.a Yes practices that involve or could involve mechanisms that could result in licensed material reaching groundwater are identified in job specific procedures, the ALARA and/or RWP programs before work can begin. Controls are established in job specific procedures and both the ALARA and RWP programs to help mitigate or eliminate spills and leaks.

Identify existing leak detection methods for each SSC and work Unit 3 SFP has a tell-tale system to assist in the practice that involves or could involve licensed material and for identification of leaks. As documented in Reference 1, which there isa credible potential for inadvertent releases to although Unit 3 currently has no leaks, sentinel wells ground water.

have been placed in strategic locations to identify any new leaks that may occur from Unit 3: The Unit 1 and Unit 2 SFPs do not have the tell-tale system; therefore, as part of the groundwater investigation, sentinel wells 1.2.b Yes have been installed to provide leak detection capability.

Additional programs such as the long term groundwater program, Reference 2, the Aging Management Program as defined in Reference 7, the NRC 80-10 program as implemented through Reference 8, sampling of the Storm Drain System and visual observations will be used to identify any new leaks in all three units.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST.

Plant or Utility Being Reviewed: Indian Point EnergyCenter (IPEC)

Rg~vip~wupr~q P Hnlli~n hP~k Date of Review: July 2008 Guideline Section Met Section Objective/Acceptance Criteria Yes-No Comments As Required Identify potential enhancements to leak detection systems or The Groundwater Monitoring Program, Reference 2, programs.

calls for an annual review. This review will evaluate the trends in the sample results and determine if enhancements to the program should be made. The NRC 80-10 and the Storm Drain Sampling programs are currently being reviewed to determine if enhancements can be made for the purpose of leak detection.

Identify potential enhancements to prevent spills or leaks from The Unit 1 SFP is currently flooded to transfer all the reaching ground water.

fuel to dry cask storage. Upon completion of the fuel transfer, the pool will be drained in preparation for 1.2.d Yes cleaning. These activities will terminate the leak from the Unit 1 SFP. These activities are expected to be completed by the end of 2008 or early in 2009. All known leaks from the Unit 2 SFP have been terminated.

1.2.e Identify the mechanism or site process for tracking corrective Yes Entergy procedure, EN-LI-102, "Corrective Action actions.

Process" is used to track corrective actions.

Establish long term programs to perform preventative maintenance As part of the license renewal application, or surveillance activities to minimize the potential for inadvertent commitments have been made to perform preventative releases of licensed materials due to equipment failure.

measures and surveillance activities for many SSCs.

1.2.f Yes See Appendix B of Reference 7 for details of the Aging Management Program. In addition, the Radiological Ground Water Monitoring Program, Reference 2, will be used to assist in detecting inadvertent releases of licensed material.

Establish the frequency for periodic reviews of SSCs and work As part of the license renewal application, 1.2.g practices.

Yes commitments have been made to perform periodic reviews for many SSCs. See Appendix B of Reference 7 for details of the Aging Management Program.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE

.SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy.Center (IPEC)

Reviewers:

P. Hollenbeck Date of Review: July 2008 Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No CommentsAs Required 1.3 Establish an on-site ground water monitoring program to ensure timely detection of inadvertent radiological releases to ground water.

Using the hydrology and geology studies developed under As documented in Reference 1, over forty wells have Objective 1.1, consider placement of ground water monitoring wells been installed on site, primarily in the Industrial and down-gradient from the plant but within the boundary defined by Radiologically Controlled Areas.

the site license..

Consider, as appropriate, placing sentinel wells closer to SSCs that As documented in Reference 1, sentinel wells have have the highest potential for inadvertent releases that could reach been placed near high radioactivity SSCs such as the 1.3.b ground water or SSCs where leak detection capability is limited.

Yes U2 SFP and the Ul SFP. Although the U3 SFP currently has no leaks, sentinel wells have been strategically placed for additional leak detection capability.

Establish sampling and analysis protocols, including analytical Sampling frequencies, analyte suites and analysis 1.3.c sensitivity requirements, for ground water and soil.

Yes sensitivities for groundwater are established in 13cYs Reference 2. Reference 3 provides the sample size and analysis sensitivities for gamma emitters in soil.

Establish a formal, written program for long term ground water Reference 2 is the formal, written program for long term 1.3.d monitoring.

Yes groundwater monitoring. It has been in effect since January 2008.

Periodically review existing station or contract lab(s) analytical Entergy procedure EN-QV-121, "Supplier Qualification I capabilities.

Maintenance of Qualifications" requires contract laboratories to be evaluated every 3 years. This 1.3.e Yes evaluation can be accomplished by a company sponsored audit or by reviewing the data available from the Nuclear Procurement Issues Committee (NUPIC).

Establish a long term program for preventative maintenance of Reference 2 requires the periodic inspection of wells to 13.f ground water wells.

determine that the wells are suitable for sampling and analysis. The status of degraded wells will be changed from "Active" to "Inactive".

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Reviewers:

P. HoUenbeck Date of Review: July 2008 Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No Comments As Required Establish the frequency for periodic review of the ground water Reference 2 requires periodic self assessments of the 1.3.g monitoring program.

Yes groundwater monitoring program at frequencies consistent with NEI-07-07 (Final).

1.4 Establish a remediation protocol to prevent migration of licensed material off-site and to minimize decommissioning impacts Establish written procedures outlining the decision making process For leaks determined through the groundwater for remediation-of leaks and spills or other instances of inadvertent monitoring program,*Reference 2, provides guidance releases. This~process is site specific and shall consider migration on the decision making process if Investigation Levels 1.4.a pathways Yes are reached. For leaks and spills that occur as a result of plant activities, Reference 9 provides guidance on actions and communications. IPEC management will determine whether additional actions such as remediation will be taken.

Evaluate the potential for detectible levels of licensed material The Radiological Environmental Monitoring Program resulting from planned releases of liquids and/or airborne (REMP) is used to evaluate the impact of IPEC materials.

operations on the surrounding environment. Results to date show that IPEC has had no adverse radiological impact. If an environmental sample result has unusual or unexpected levels of radioactivity, Reference 6 will be used to provide guidance on evaluating, notifying and reporting.

Evaluate and document, as appropriate, decommissioning impacts As documented in Reference 1, after removing the fuel resulting from remediation activities or the absence thereof.

and water from the Unit 1 SFP, no additional actions will be taken. All known leaks from Unit 2 SFP have been stopped. Monitored natural attenuation will be 1.4.c Yes used to observe the predicted downward trends in groundwater concentrations. The latest decommissioning cost estimate has included the additional work scope caused by the pool leaks.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Date of Review: July 2008 Reviewer's:

P. Hollenbeck Guideline Section Met Section Objective/Acceptance Criteria Yes-No Comments As Required For licensees that are in States where multiple nuclear power Entergy procedure EN-RP-1 13, "Response to plants are located and multiple owner companies, it is highly Contaminated Spills/Leaks", Reference 4, contains recommended that the licensees coordinate their efforts and guidance on communication with State/Local officials.

communicate with each other. The initial briefing for the State/local Another procedure IP-SMM-LI-108, "Event Notification officials and the contents of a voluntary communication should be and Reporting", Reference 5; will also be implemented 2.1.c consistent.

Yes should notifications be required by EN-RP-1 13. These procedures will be used by all Entergy plants in New York. Due to the unique nature of the IPEC groundwater situation and the high level of interest in IPEC, it is difficult to reach agreement between different companies on when to communicate with State and Local officials."

2.2 Make informal communication as soon as practicable to appropriate State/Local officials, with follow-up notifications to the NRC, as appropriate, regarding significant "on-site leaks/spills into ground water and on-site or off-site water sample results exceeding the criteria in the REMP as described-in the OCDM/ODAM.

Communication with the designated State/Local officials shall be Reference 4 contains guidance on'communication with made before the end of the next business day if an inadvertent leak State/Local officials if the conditions specified in (i), (ii) or spill to the environment has or can potentially get into or (iii) have been met. Another procedure, Reference groundwater and exceeds any of the following criteria: i) If a spill or 5, will also be implemented should notifications be 2.2.a leak exceeding 100 gallons from a source containing licensed Yes required by EN-RP-113.

material; ii) If the volume of a spill or leak can not be quantified, but is likely to exceed 100 gallons, from a source containing licensed material, or iii) Any leak of spill, regardless of volume or activity, deemed by the licensee to warrant voluntary communication.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE

, SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Reviewers:

P. Hollenbeck Date of Review: July 2008 Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No Comments As Required Communication with the designated State/Local officials shall be Reference 6 contains guidance on communication with made before the end of the next business day for a water sample State/Local officials if the condition specified in (i) has result (i) of off-site ground water or surface water that exceeds any been met. Based upon the groundwater investigation, 2.2.b of the REMP reporting criteria for water as described in the Yes Reference 1, no on-site surface water is hydrologically ODCM/ODAM, or (ii) of on-site surface water, that is hydrologically connected to groundwater and no groundwater is or connected to ground water, or ground water that is or could be could be used as a source of drinking water.

used as a source of drinking water, exceed any of the REMP Therefore, no communication will be made under reporting criteria for water as described in the ODCM/ODAM.

condition (ii).

When communicating to the State/Local officials, be clear and Reference 4 has an attachment (9.1) which will be precise in quantifying the actual release information as it applies to completed prior to communicating information. The the appropriate regulatory criteria, attachment documents information about the source,'

2.2.c Yes location, actions taken, etc. When communication is made, space is available for recording agencies, names, dates and times. Attachment 9.1 will become part of the 10CFR50.75(g) file.

Voluntary communication to State and/or Local officials may also Entergy procedure, Reference 4, contains guidance on require NRC notification under 10 CFR 50.72(b)(2)(xi). Licensees communication with the NRC under 10CFR50.72 2.2.d should perform these notifications consistent with their existing Yes should voluntary communication be made to State program.

Ys and/or Local officials. This notification would be made under Reference 5, IP-SMM-LI-108, "Event Notification and Reporting".

2.2;e Contact NEI by email to GWNotice@nei.org as part of a voluntary No Reference 4 contains no guidance on communication communication event.

with NEI as part of a voluntary communication event.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST.

Date of Review: July 2008 Plant or Utility Being Reviewed: Indian Point EnergyCenter (IPEC)

Reviewers:

P. Hollenbeck Guideline Section Met Section Objective/Acceptance Criteria Yes-No Comments As Required 3.1 Perform a self-assessment of the GPI program (references this check sheet)

An independent, knowledgeable individual(s) shall perform the The initial self assessment was completed in August 3.1.a initial self assessment within one year of implementation.

Yes 2008. The program was initiated in January 2008.

3.1.b Perform periodic self-assessments of the GPI program at least No The first periodic self-assessment is not due until 2013.

once every five years after initial self-assessment.

3.1.c The self-assessment, at a minimum, shall evaluate implementation Yes All objectives in the Check List have been evaluated of all objectives identified in this document.

and documented.

The self-assessment shall be documented consistent with The self assessment will be documented consistent 3.1.d applicable procedures.

Yes with EN-LI-102, "Self Assessment and Benchmark Process" 3.2 Conduct a review of the GPI program, including at a minimum the licensee's self assessments, under the auspices of NEI.

An independent, knowledgeable individual(s) shall perform the The first independent review of the initial self-3.2.a initial review within one year of the initial self-assessment No assessment is due before August 2009.

performed per objective 3.1.a above Periodic review of the GPI program should be performed every five The first independent periodic review is not due until 3.2.b years, subsequent to the license's periodic self-assessment No completion of 3.1.b above.

performed per Objective 3.1.b above.

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NUCLEAR ENERGY INSTITUTE GROUNDWATER PROTECTION INITIATIVE SELF ASSESSMENT CHECKLIST Plant or Utility Being Reviewed: Indian Point Energy Center (IPEC)

Reviewers:

P Hnllenbeck Date of Review: July 2008 Guideline Section Met Section ObjectivelAcceptance Criteria Yes-No Comments As Required

References:

1.0 GZA Final Ground Water Report to IPEC, "Hydrogeologic Site Investigation Report", dated January 7, 2008.

2.0 IP-SMM-CY-1 10, "Radiological Ground Water Monitoring Program" 3.0 IP-SMM-RP-801, "Radiological Control of Volumetric Materials" 4.0 EN-RP-113, "Response to Contaminated Spills/Leaks" 5.0 IP-SMM-LI-108, "Event Notification and Reporting" 6.0 0-CY-1905, "Notification, Investigation & Reporting of Abnormal Activity in Environmental Samples" 7.0 Indian Point Energy Center License Renewal Application 8.0 EN-CY-108, "Monitoring of Non-Radioactive Systems" 9.0 IP-SMM-EV-101, "IPEC Spill / Release Response Plan" 10.0 EN-LI-102, "Corrective Action Process" 11.0 EN-LI-104, "Self Assessment and Benchmark Process" 12.0 EN-QV-121, "Supplier Qualification / Maintenance of Qualifications" 13.0 RE-ADM-1-22, "Site Soil Characterization" Page 12 of 12