ML090560470

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Long-Term Monitoring Plan Position Paper
ML090560470
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 08/31/2008
From:
Entergy Corp
To:
NRC Region 1
References
Download: ML090560470 (8)
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Text

Long Term Monitoring Plan Position Paper A. Purpose and Scope Define the basis for the IPEC Groundwater Long Term Monitoring Plan (LTMP),

and describe the current plans for changes and improvements in the LTMP.

The LTMP must meet the previously developed long term monitoring objectives, which are summarized as follows. A more detailed description of the objectives is shown in Attachment 1.

1. Monitor groundwater flow rate and radionuclide concentrations
2. Monitor groundwater in the vicinity of potential sources of leakage
3. Monitor groundwater to confirm no migration off of the property
4. Monitor existing groundwater plumes Because the objectives include monitoring in the vicinity of potential sources of leakage and existing groundwater plumes, it is not sufficient to merely review monitoring well data. There must be an integrated review including the following:
  • Monitoring well data
  • Understanding of the placement of the wells
  • Continuing review of operations associated with known sources (e.g.,

fuel pools)

  • - Knowledge of past spills and potential for below-surface sources of radioactivity (10 CFR 50.75g files)
  • Review of current plant operations and maintenance of systems to determine the potential for leakage.

This integrated LTMP review, when including the items listed above, can help to assure groundwater protection. Figure 1 shows the various aspects of an integrated LTMP review..

DeW -f

Long Term Monitoring Plan Position Paper Draft August 2008.,

Current Operations _ Hydrol(ogy Review and Systems Review andWi ell Placement Boundary

t Wells Continuing Review Groundwater Routine Well of Known Sources I I, ýProtection Sampling 7- Source Identification and Tracking Wells Past Spills and 10 CFR 50.75g Bulletin 80-10 Issues and Files Storm Drain Sampling Figure 1 - Integrated Long Term Monitoring Review Page 2

Long Term Monitoring Plan Position Paper Draft August 2008 B. Existing IPEC Long Term Monitoring Plan (LTMP)

Regulatory and industry guidance documents that relate to the LTMP are listed in Attachment 2. IPEC has developed and complies with procedure IP-SMM-CY-110, "Radiological Groundwater Monitoring Program", which includes the requirements for a long term monitoring program. This procedure lists the monitoring objectives, as follows

1. Monitor status of known groundwater plume
2. Detect & quantify unidentified sources of GW contamination, such as leaks from Systems, Structures and Components (SSCs)
3. Provide data to perform groundwater dose calculations
4. Monitor effectiveness of remediation or intervention actions IP-SMM-CY-1 10 further lists investigation/characterization objectives as:
1. Determine the source of groundwater contamination
2. Determine the extent of the radioactive groundwater plume
3. Evaluate corrective/investigative actions, using the corrective action system The data review and investigation requirements are listed as follows:

Data review:

  • Required analyses performed
  • Minimum Detectable Concentrations (MDCs) met
  • Quality Control (QC) samples satisfactory
  • Review unusual results (high or low)
  • Review unexpected results (e.g., new nuclides)
  • Compare results to investigation level in Attachment 8.5 of the procedure
i. For well LAF-002, any positive detection of H-3 or Sr-90 (Note that a positive detection is where the result is greaterthan or equal to 3 times the I sigma uncertainty) ii. MW-40, 51, 52, and 107: > 1000 pCi/L H-3 or > 2 pCi/L Sr-90, and any positive detection of other plant related nuclides iii. MW-60, 62, and 63: > 2000 pCi/L H-3 or > 2 pCi/L Sr-90, and any positive detection of other plant related nuclides iv. All remaining wells: Any positive detection of nuclides that exceed 2 times the average from previous year, and the positive detection must be > 1000 pCi/L H-3 or >2 pCi/L Sr-90.-

Actions/reviews after start of investigation (consider each item if appropriate)

  • Review trends over a longer period of time
  • Review condition report for spills or incidents
  • Review recent rainfall data
  • Contact Lab to check QC, volume, MDCs met, etc.
  • Resample Page 3

-Long Term Monitoring Plan Position Paper Draft August 2008

  • Consider an increase in sample frequency
  • Initiate a condition report and involve other departments as needed.
  • Consider remediation of groundwater or source (soil)

C. Review of the IPEC LTMP IPEC's requirements in procedure IP-SMM-CY-1 10 are adequate to effectively monitor the groundwater, in accordance with the four basic objectives previously stated:

1. Monitor groundwater flow rate and radionuclide concentrations
2. Monitor groundwater in the vicinity of potential sources of leakage
3. Monitor groundwater to confirm no migration off of the property
4. Monitor existing groundwater plumes One of the important aspects of the review of groundwater program is the consideration of historical activities and events, as they relate to the LTMP.

Entergy has a network of programs that interrelate, each having a separate function, yet still supporting the LTMP. Attachment 2 describes historical events and requirements, related documents, and their applicability to ongoing groundwater monitoring.

D. Program Improvements While the current methods of groundwater monitoring and review are adequate, additional efforts are needed in order to ensure a consistent review which will rely less on individual expertise and more on institutional programs. These recommendations will also include involvement of the appropriate departments and/or program owners for programs supporting the groundwater monitoring.

Planned Improvement No. 1:

Change trigger level to an improved statistically based value once sufficient analysis data is obtained for the wells.

Note that the current method of using 2 times the averagefor that site is conservativeand may result in a high number of triggers of the investigation process. This is considered to acceptable in the short term and after 1full year (6 to 8sets of66uarterlydat???Per GZ4??) of data is available at these locations; the trigger level value will be re-evaluated:.

Planned Improvement No. 2:

Formalize the groundwater data review so that a quarterly review is undertaken and documented, and that review evaluates the well sample results and other data using a repeatable methodology (e.g., checklist format). It is anticipated that site personnel would provide data from existing program documentation to support this quarterly review.

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- Long Term Monitoring Plan Position Paper Draft August 2008

  • Groundwater sample results
  • Storm drain sample results
  • Potential new leaks and spills (via the Condition Reporting System)
  • Parameters that would cause changes to known leaks (such as water level changes in fuel storage pools)

Review of 10 CFR 50.75(g) files as necessary to review anomalous results Planned Improvement No. 3:

After at least one year of data (6 to.8 sets of quarterlydata???Per GZA??) has been collected on the wells listed as active in procedure IP-SMM-CY-1 10, the frequency and number of wells being sampled and evaluated will be re-evaluated.

Consider more specific guidance to increase frequency based on operations near known sources with higher potential for leakage. For example, consider increased frequency near fuel storage pools when moving fuel and utilizing the fuel transfer canal.

This re-evaluation will involve expertisefrom both the plant (radiologicaland operational)andfrom the hydrogeologicalconsultants. The goal of this re-evaluation is to ensure that IPECis obtaining information at sufficient frequency to detect potential leaks and to monitor known plumes, yet does not obtain unnecessarydata.

E.

Conclusion:

The LTMP as it now exists at IPEC (IP-SMM-CY- 110), is an effective document to monitor the existing GW plumes, detect new sources of radiologically contaminated water to the GW environment, and it provides sufficient information to allow the performance of dose calculations. The LTMP is supported by other programs such as the Bulletin 80-10 Program, 10 CFR 50.75(g), the Plant Condition Reporting System, and others. Three improvements are planned to help institutionalize the program reviews.

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-Long Term Monitoring Plan Position Paper Draft August 2008 Attachment 1: List of Ion! term monitoring obectives:

1. Monitor groundwater flow rate and radionuclide concentrations to both detect and characterize current and potential future off Site groundwater contaminant migration to the Hudson River, both via direct groundwater discharge to the river and through infiltration into the Discharge Canal, from abnormal radionuclide releases of liquid effluents, so as to allow computation of potential radiation dose to the public from these releases;
2. Monitor groundwater proximate to Systems, Structures and Components (SSCs) which exhibit a credible probability of resulting in a visually undetected release of radionuclides to the subsurface carrying an activity level of significance;
3. Monitor groundwater along the property boundary to confirm that contaminated groundwater is not migrating off of the property to locations other than the river; and
4. Monitor the groundwater plumes identified on-Site to demonstrate overall reductions in total activity over time as is consistent with the requirements of Monitored Natural Attenuation (MNA), the selected remediation for the WPEC Site.

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Long Term Monitoring Plan Position Paper Draft August 2008 - Relationship between Historical Events and Requirements and Applicability to Ongoing Groundwater Monitoring Historical Events and Requirements Related Documents Applicability to ongoing GW monitoring 10 CFR 50.75(g) - requires documentation of spills and leaks Used as required to evaluate anomalous GW for future use in decommissioning. 50.75(g) file onsite, EN-RP-1 13 sample results.

IE Bulletin80-10; IPEC 80-10 Program, Rev.

0, 1-31-2006; EN-CY- 108, Rev. 1, Ongoing storm drain sampling program; Monitoring of Non-Radioactive Systems results stored in Win-CSMS database. Review (Entergy corporate procedure); EN-RP-1 13, of storm drain sample results is performed as IE Bulletin 80 requires plant "Response to Contaminated Spills/Leaks"; results are available. In addition, storm drain, systems be reviewed for the Bulletin 80-1.0, IPEC Focused Self- sample results summary is reviewed as part of potential to cross-contamination Assessment; O-CY-15 10, Rev. 5, IPEC Storm the quarterly GW monitoring integrated normally clean systems. Drain Sampling. review.

GW database used to determine the range of expected values, to compare to other data Groundwater sample results The groundwater sampling database is points in time and location, and to produce database maintained in an electronic format. investigation flags for anomalous results.

Used as required to evaluate anomalous GW In addition to 50.75(g) file, other records sample results. In addition, the condition include the condition reporting system, reporting system is reviewed for evidence of operator logs, reports, maintenance records, leaks or spills as part of the quarterly GW Operational History etc. monitoring integrated review.

The effect of known leakage on GW sample results is evaluated when reviewing anomalous GW sample results, In addition, as part. of the quarterly GW monitoring integrated review, any changes to the known sources are reviewed. This would include parameters such as water level changes, Known issues, such as Unit 1 fuel Existing reports and evaluations, condition demineralization changes, component/fuel pool leakage. reports, corrective action system. movement, etc.

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Long Term Monitoring Plan Position Paper Draft August 2008 : Documents Reviewed Regulatory and industry guidance documents were reviewed, along with IPEC and Entergy procedures, program documents, and reports to ensure that the LTMP is in alignment with existing guidance.

NEI-07-07, "NEI Industry Ground Water Protection Initiative - Final Guidance Document", August 2007.

  • ANI Guidance 07-01, "Potential for Unmonitored and Unplanned Off-site releases of radioactive material", March 2007.

0 NRC IE Bulletin 80-10, "Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release to Environment", May 1980.

0 NRC Information Notice 2006-3, "Ground Water Contamination due to Undetected Leakage of Radioactive Water".

  • IPEC Procedure, O-CY-15 10, Rev. 3, ,IPEC Storm Drain Sampling", November 2007.
  • IPEC Procedure, IP-SMM-CY-1 10, "Radiological Groundwater Monitoring Program, Rev. 0" a IPEC 80-10 Program, Rev. 0, 1-31-2006 0 IPEC Focused Self-Assessment, 2007, IE Bulletin 80-10.
  • Entergy Procedure, EN-RP-1 13, "Response to Contaminated Spills/Leaks, Rev. 2".
  • Quarterly Long-Term Monitoring Report No. 1, 2007, Quarters 2, 3, and 4, GZA.
  • Quarterly Long-Term Monitoring Report No. 2, 2008, Quarter 1, GZA.

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