ML090540162
| ML090540162 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/31/2008 |
| From: | NRC Region 1 |
| To: | |
| References | |
| Download: ML090540162 (7) | |
Text
NRC Inspection and Assessment Team Principal Inspection Contributors:
NRC ASSESSMENT:
INDIAN POINT CONTAMINATED GROUNDWATER
- NRC Region I
- James Noggle, Senior Health Physicist
- James Kottan, Senior Health Physicist
- John White, Chief, Plant Support Branch 2
- NRC Office of Research
- Thomas Nicholson, Senior Technical Advisor-Radionuclide Transport
- US Geological Survey
- John Williams, Senior Hydrologist
(
)
i _.Coordinating Government Agencies Federal:
- US Geological Survey (USGS)
New York State:
- Department of Environmental Conservation (DEC)
- Department of Public Health (DPH) c*2 Purpose Evaluate Entergy's performance and provide status of inspection findings associated with the following:
- Cause of the groundwater contamination
- Extent and migration of the groundwater releases
- Radiological significance of these releases Ensure that public health and safety and protection of the environment were maintained C~J2 Purpose
- Ensure Entergy's groundwater transport model is correct and tested
- Research prior opportunities for leak discovery and evaluate Entergy's response
- Determine Entergy's conformance with regulatory requirements c*
Scope
- Assess Entergy's investigation of the Unit 2 spent fuel pool leak since August 2005
- Examine Entergy's investigation of previous Unit 1 and Unit 2 spent fuel pool leaks identified in 1992 1
Scope Scope
- Independent Assessment Effort:
- Collection and analysis of groundwater samples
- Verification of licensee's hydrological conclusions
- Verification of dose assessment to the public
- Verification of water inventory losses from Unit 1 and Unit 2 spent fuel pools
- Verification of no detectable environmental impact through the analysis of aquatic food samples from the Hudson River.
U
- Comprehensive assessment of groundwater transport pathways and contaminant plume behavior
- Historical conditions NRC Assessment
- Independent analysis confirms offsite migration is limited to the Hudson River
- The groundwater transport model was based on well-developed data, measurements, and field observations NRC Assessment During site visits and teleconferences, questions posed:
> to evaluate the Conceptual Site Model assumptions, and
> to pro-actively engage Licensee's contractor in developing corroborating field data
> to understand ground-water plume sources, extent, and behavior Y
.NRC Inspection Focus and Activities
- NRC Staff from Region I and Office of Nuclear Regulatory Research provided technical oversight of IPEC ground-water contamination studies U.S. Geological Survey scientist provided technical support to the technical oversight Initial ground-water contamination identified in leak from Unit 2 Spent Fuel Pool
- Site visits focused on technical questions concerning the contaminant sources, pathways, potential receptors, and monitoring to detect future leaks
- Field data from rock cores, monitoring wells, geophysical surveys, hydraulic tests and tracer tests independently reviewed NRC Assessment Questions What are the source(s) of the ground-water contamination?
Where do they intersect the accessible environment?
Are there fast and preferential pathways?
Do the contaminant plumes move under the Hudson River?
Are local drinking water sources affected?
Are the plumes captured by the Discharge Canal?
What are the hydraulic controls on the plume(s)' behavior as reflected in the Conceptual Site Model?
What remediation is appropriate?
How can future leaks be detected?
What surveillance is needed to confirm dose, assessments remain below regulatory limits?
2
C *
!"NRC Assessment Fundamental Understanding for the Conceptual Site Model
- Nature of the leaks and initial pathways through backfills and fractured rock at or above the local water table.
- Role of fractures and possibility of solutioning A connectivity
- Interaction of ground-water flow with the Hudson River
- Location and relationships to local drinking water sources
- Ground-water flow gradients, vertical and horizontal flow directions related to the sources, Discharge Canal, and River
- Benefits of a long-term ground-water monitoring program NRC Assessment Conclusions U
Unit 1 and 2 are the source(s) of the ground-water contamination Plumes move west, intersect the Hudson River but not under to Rockland County Bfackfills and connected fractures are the preferential pathways No local drnking water sources are affected Discharge Canal captures some but not all of the plume Ground-water gradient and flow direction controlled by local hydrology Monitored natural attenuation is the appropriate remediation approach Future leaks can be detected by monitoring wells near Units 1 and 2 Lon-term monitoring is needed to confirm dose assessments remain bel regulatory limits during plant operations NRC Assessment.
Entergy implemented timely actions to investigate source, and determine dose impact Entergy conformed to regulatory survey requirements
- Groundwater contamination resulted only from leakage attributed to Unit 1 and Unit 2
- Entergy's site characterization was based on state-of-the-practice monitoring wells, tests, and analysis methods S-NRC Assessment
- Exposure pathway to man is aquatic food from Hudson River (fish, invertebrates)
- Calculated exposure to maximum exposed individual is 0.002 mrem/yr total body and 0.01 mrem/yr maximum organ Calculated exposures are less than 0.1%
of NRC regulatory limit Radiation Dose Perspective
- Background (est.)
360 mrem/year (NCRP 94)
- Public Dose Limits 100 mrem/year (10CFR20.1301) 25 mrem/year (40CFR190)
- Liquid Effluent Limit 3 mrermlyear, total body 10 mrem/year, organ (10CFR50, App. I)
- Estimated Dose Rate 0.002 inrem/year, total body 0.01 mrem/year, bone EPA drinking water limits (40 CFR 141.16)
Tritium (H-3) 20,000 pCi/L Strontium (Sr-90) 8 pCi/L (EPA maxim= contamtiant level based on 4 mrems pmr year)
NRC Assessment-Regulatory Requirements Entergy is monitoring and reporting the groundwater effluent release condition in accordance with NRC regulations Relative to Unit 1, there was no condition in which the licensee failed to meet a regulatory requirement or standard that was reasonably within its ability to detect or correct 3
NRC Assessment Removal of Unit 1 fuel and drainage of the pools will eliminate the source of Sr-90, Ni-63, Cs-137 Entergy has initiated a long-term monitoring process to:
- Report groundwater liquid releases
- Measure the effectiveness of remediation and natural attenuation
- Detect new or changing groundwater contamination conditions
'7 NRC Lessons-Learned NRC Lessons Learned Task Force Identified:
- Lack of regulatory guidance for detecting, evaluating, and monitoring releases via unmonitored pathways
- Lack of regulatory requirement / guidance for remediation of groundwater conditions
- Lack of requirement to assure leaks and spills will be detected before migration off-site Actions have been initiated to address these and other identified issues.
)
i Planned and Continuing NRC Inspection and Assessment
- Assessment of Long-Term Groundwater Monitoring Plan
- Inspection oversight of Unit 1 fuel removal and pool draining activities Baseline inspection now includes aspects of groundwater protection and assessment Inspection initiative to confirm licensee implementation of Industry Groundwater Protection Initiative NRC Homepage
- www.nrc.gov Additional Information
- Indian Point 2 Current Performance Summary
- www.nrc.gov/NRRIOVERSIGHTIASSESSIIP2/ip2_chart.html
- Indian Point 3 Current Performance Summary
- www.nrc.gov/NRR/OVERSIGHT/ASSESS/IP2/ip3_chart.html
- Indian Point "Specific Plant of Interest" Page
- www.nrc.gov/reactors/plant-specific-itemsfindian-point-issues.html
- Indian Point License Renewal Review Status
- www.nrc.aov/reactors/operatinqllicensinp/renewal/aapplicationsAn diSn-point.html
- USGS Open-File Report on Flow-Log Analysis
- http://Hubs.usss.gov/of/2008/1123/
4
I I
NYS Department of Environmental Conservation Community Fact Sheet Prepared for the 5/09/08 NRC Government-to-Government Meeting on the Indian Point Energy Center For more, information about the DEC or
- DOHI activities relativet*
the
- .,,.roundat~er investigations at Indian Pitplease contact:
Buhaan NY,
_Tim TRice,'FProject Lead.
En adiation Specialist F~iv.of Solid &l Hazardous Materials 6'ý25.1Broadway
,.,Abany, NY 12233-7255 V(518ý)402-8579 tbrice@gw.dec state.ny. us
!,Mr Larry Rosenmann 4'n'g6in~erih6Geologist
,NYSIDECK Div of Solid & Hazardous Materialsy'
'625 Br adway Abany, NY 12233-7258
- ý"Iarosenmn~gw.dec.st'ate.ny.us WMr. Robert Snyder
, Radiological Health Specialist
ýNYýSDOH, Bureau of Env.- Radiation Protection iý-547,River'Streek
- Troy N_12180 (800) 45ik I
.8ext.
27550 BE RP@health.state. ny.uLs Frinformation about',State.
ýýJnvYlvemxeit in the NRC license.
2ýrenew~al process forlIndian Point, please contact:
JonLeary Matthews; Esq.
~Sleior Counsel for Special Projectst 6
,6fcGe o
- e G enral Council 625
ý'Broadway Alay'NY 12233-5500 (58)402-91 90
ýJlm atthe~gw. dec. state. ny. us
- 1
.1
.2
- 1
.1 Groundwater Investigation To protect the interests of the citizens and the environment of the State of New York, scientists from the NYS Department of Environmental Conservation (DEC) and the NYS Department of Health (DOH) oversaw Entergy's investigation into the source and fate of the radionuclide contamination in the groundwater on the Indian Point Energy Center site. The State's goals were to ensure that Entergy performed a comprehensive characterization of site groundwater contamination, took appropriate actions to identify and stop the sources of the leaks, carried out any necessary remedial actions, and developed a comprehensive monitoring program to detect any future leaks.
General In 2005, Entergy discovered water leaking from a crack in the exterior of the Unit 2 Spent Fuel Pool (SFP). The subsequent investigation identified tritium (radioactive hydrogen or H-
- 3) contamination in groundwater coming from the Unit 2 SFP and radioactive strontium-90 (Sr-
- 90) and other isotopes coming from the Unit 1 SFP.
NYS Involvement DEC and DOH provided State oversight for the hydrological investigation.
During this process, we:
" Collected split samples of groundwater from on-site and off-site monitoring wells.
" Reviewed and made recommendations on the work of Entergy's hydrology contractor.
" Performed an independent assessment of potential public health impacts.
" Recommended that Entergy expand its Hudson River ish sampling program in 2007 to address questions regarding potential impacts from Sr-90.
" Collected split samples of fish flesh from this enhanced effort, as well as unilaterally collecting bone samples for Sr-90 analysis. (See reverse side for details.)
- Participated in periodic stakeholder calls and meetings.
Key Findings e Groundwater from the site flows east to west -
directly toward and into the Hudson River - and does not flow to surrounding properties.
Contaminated groundwater is moving into the Hudson River, but the levels of radionuclides in the River are below State surface water standards for H-3 (20,000 pCi/1) and Sr-90 (8 pCi/1).
" Concentrations of Sr-90 have been detected on site at up to 14 times the drinking water standard.
" No drinking water sources are affectedbecause the Hudson River in this area is brackish and is not used as a drinking water source.
" Because the Hudson River is not used as a drinking water source in this area, the only pathway for a dose to the public from groundwater entering the River is through consumption of fish.
Outcome of the Investigation
- DEC and DOH have accepted Entergy's characterization of the extent and levels of contamination reported in its 1/7/08 "Hydrogeologic Site Investigation Report."
" The planned remedy for the Sr-90 contamination (removal of the spent fuel and water from the Unit 1 SFP) will remove the active source of contamination for that plume, but residual contamination will.
continue for many years.
- The H-3 contamination
ý rimarily came from the nit 2 SFP.
" While the known leaks have been stopped in the Unit 2 SFP, because of an inability to inspect the liner in the Umt 2 SFP while the unit is operating, the full extent of the leaks is not known.
" With the removal of the active contamination source, Entergy's planned use of monitored, natural attenuation is an acceptable approach to managing the remaining Sr-90 and H-3 plumes.
" Because H-3 becomes part of the water molecule, it cannot be removed from site groundwater by current treatment methods.
" Entergy's 2007 calculated doses to the public through fish consumption (0.00027 mrem whole body and 0.00099 mrem organ dose) are less than 1% of the NRC dose limits.
Fl5 L-ti,.
of InA-Nk PoE -gy C-, it,,
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No, Yo,S.
1
Cross-section of Tritium Plume shoMnq relationship to Source. Discharge Canal and River (GZA, 2008)
[to Source, ý pscharge 'Canal:andl Rivelý.(GZý,,'2008 2