ML102350525

GPI Data Review, Grand Gulf Nuclear Station

ML102350525
Person / Time
Site:	Grand Gulf
Issue date:	04/30/2009
From:	GZA GeoEnvironmental
To:	Entergy Operations, Office of Information Services
References
09.0025576.00, FOIA/PA-2010-0275
Download: ML102350525 (40)

Text

GPI DATA REVIEW GRAND GULF NUCLEAR STATION PORT GIBSON, MISSISSIPPI PREPARED FOR:

Entergy Operations, Inc.

White Plains, NY PREPARED BY:

GZA GeoEnvironmental, Inc.

Portland, Maine April 2009 File No. 09.0025576.00 b9 Copyright © 2009 GZA GeoEnvironmental, Inc.

4l.. .

2.0 BACKGROUND

SITE GEOLOGY AND HYDROLOGY 2.1 SITE DESCRIPTION 2.2 SITE CONCEPTUAL MODEL 2.2.1 Site Geology 2.2.2 Hydrogeology 0w 3.0 RECENT GPI FIELD ACTIVITIES PERFORMED AT THE GGNS PLANT 3.1 GROUNDWATER MONITORING WELL INSTALLATION 3.2 GROUNDWATER SAMPLING AND ANALYSIS 3.3 GROUNDWATER ELEVATION MONITORING 4.0 FINDINGS OF RECENT GPI FIELD ACTIVITIES 4.1 GEOLOGY 4.2 HYDROGEOLOGY AND SHALLOW GROUNDWATER FLOW DIRECTIONS 4.3 SAMPLING AND ANALYSES 4.4 COMPARISON TO THE SCM 5.0 EVALUATION OF THE PLANT'S GPI PROGRAM RELATIVE TO NEI GUIDANCE 5.1 OVERVIEW ASSESSMENT 5.1.1 Key Findings: Objective I - Groundwater Protection Program 5.1.2 Key Findings: Objective 2 - Communication 5.1.3 Key Findings: Objective 3 - Program Oversight 6.0 OPTIONS TO ENHANCE CURRENT GPI PROGRAM TABLES TABLE 1 NEI Self Assessment Checklist FIGURES FIGURE 1 Site Locus FIGURE 2 Site Plan 09.0025576.09 Page i 4/15/09

.t, APPENDICES APPENDIX A Limitations APPENDIX B Analytical Results APPENDIX C Ground Water Contour Plans APPENDIX D List Of Documents Reviewed and Personnel Contacted 09.0025576.09 Page ii 4/15/09

1.0 INTRODUCTION

This report was prepared by GZA GeoEnvir'onmental, Inc. (GZA) on behalf of Entergy Operations, Inc (Entergy) and presents a summary of GZA's review of recent hydrogeologic investigation activities performed at Entergy's Grand Gulf Nuclear Station located in Port Gibson, Mississippi (hereafter referred to as the "Site" or the "GGNS Plant") and provides an opinion of the status of the Site's Groundwater Protection Initiative (GPI) program relative to the GPI guidance document 07-07 prepared by the Nuclear Energy Institute (NEI). This report is intended to fulfill the requirements of Objective 3.1a of the 07-'07 NEI guidance document, and is subject to the Limitations outlined in Appendix A.

GZA assessed the plant's progress relative to the NEI 07-07 guidance objectives" based on our understanding of the plant and associated Site Conceptual Mo0lel (SCM), using our technical expertise and experience developed through performance of groundwater investigations and remediation at thousands of sites contaminated-with industrial chemicals and/or radionuclides. Our opinions and judgments are based on well established, industry hydrogeologic and environmental engineering principals. Founded in 1964< GZA is a leading environmental and geotechnical engineering firm with over 500 highly skilled professionals including, geologists, hydrogeologists, and hydrologists, as well as geotechnical, instrumentation and environmental engineers, who underpin our technical qualifications to perform projects of this type. Our recent experience includes performance of "limited-scope", as well as sophisticated groundwater protection investigations, including a well documented Observational Method 2 /SCM approach to the investigation of the Indian Point Energy Center in Buchanan, New York. This work has been reviewed and validated by both the U.S. Nuclear Regulatory Com'mission and the U.S. Geological Survey.

During the fall of 2006 and winter of 2007, GZA was retained by Entergy, through Enercon Services, Inc. to perform an initial (Phase I) hydrogeologic assessment of GGNS in support of Entergy's corporate GPI program. This work was performed in general accordance with the then evolving NEI GPI guidelines and focused on assessing potential radionuclide pathways from impacted or potentially impacted, plant systems to, and then with, the groundwater. The findings of GZA's initial GPI study are presented in a report dated January 30, 2007 (Phase I Report)3.

Since completion of the Phase I study, NEI adopted the final 07-07 GPI guidance document and Entergy installed a series of groundwater monitoring wells downgradient of the Site and commenced groundwater monitoring activities.

NEI, August 2007, Industry Ground Water protection Initiative - Final Guidance Document, NEI document No. 07-07 [Final].

2 a Use of the ObservationalMethod in the Investigation and Monitoringof a Spent Fuel Pool Rilease, Barvenik, et. al.,

NEI Groundwater Workshop, Oct. 2007.

b. Use of the ObservationalMethod in the Remedial Investigation and Cleanup of ContaminatedLand, Dean, A.R. and M.J. Barvenik, The Seventh Geotechnique Symposium - Geotechnical Aspects of Contaminated Land, sponsored by the Institution of Civil Engineers, London, Volume XLII, Number 1, March 1992.

3 GZA and Enercon, January 30, 2007, Site Hydrogeologic Assessment in Support of Enterg, GPI. Grand Gulf Nuclear Power Station, Port Gibson, Mississippi.

09.0025576.09 Page I 4/15/09

This report provides a brief summary of GZA's Site Conceptual Model (SCM) of the geology and hydrogeology of the site, a review of recent GPI field activities conducted by others at the GGNS Plant, an assessment regarding the consistency of the recent findings with respect to the existing SCM, and our assessment of the Site's progress towards implementation of the GPI program relative to the NEI 07-07 guidance document.

2.0 BACKGROUND

SITE GEOLOGY AND HYDROLOGY 2.1 SITE DESCRIPTION Grand Gulf Nuclear Station consists of approximately 2,1.00 acres and is located in Claiborne County in southwestern Mississippi as shown, on Figure 1. The plant is located on the east side of the Mississippi River about 25 miles south of Vicksburg and 37 miles north-northeast of Natchez.

The Site consists primarily of woodlands, former farms and two oxbow lakes, Hamilton Lake and Gin Lake, which formed within a former channel of the Mississippi River. The Site is divided roughly in half between the eastern upland area that is in the elevation range of about 100 to 210 feet above mean sea level (msl) and the lowland western area that is in the elevation range of 55 to 80 feet above msl. Surface drainage over a majority of the developed upland portion of the Site occurs within two watersheds which discharge to Hamilton Lake. Most of the undeveloped western lowland area of the Site drains to Hamilton and Gin Lakes with only a very limited drainage area to the Mississippi River along its bank. The GGNS facilities, including the power generating facilities and administrative offices, are located in the eastern upland portion of the site.

2.2 SITE CONCEPTUAL MODEL This section provides a brief summary of GZA's understanding of Site geology and hydrogeology as discussed in the Phase I report and is presented herein as a Site Conceptual Model (SCM).

Combined with the results of recent data collection activities (described below in Section 4.0), this understanding forms the. basis of our assessment of the technical aspects of the GPI program for the GGNS Plant.

2.2.1. Site Geology The region lies within the Coastal Plain physiographic province which extends from New Jersey to Texas and encompasses all of Louisiana and nearly all of Mississippi. The wide Coastal Plain consists primarily of Late Cretaceous to Holocene deposits that were deposited mostly in a marine environment, were later uplifted and now tilt seaward, or to the south in Louisiana and Mississippi. The Site lies within the north-south trending Mississippi Alluvial Plain Section of the Coastal Plain Province that parallels the. Mississippi River extending from north of Mississippi to the Gulf of Mexico and consists of a %lowflood plain and delta system formed by the Mississippi River.

The results of previous borings drilled at the site indicate that the subsurface consist of the following (listed from youngest to oldest):

• 0 to 145 feet of Holocene Alluvium consisting of clay, silt, sand, and gravel;

• 0 to 82 feet of Pleistocene Loess consisting of silt; 09.0025576.09 Page 2 4/15/09

IP ,

• 0 to 151 feet of Pleistocene Terrace Deposits consisting of clay, silt, and gravel;

• Miocene Catahoula Formation consisting of up to 320 feet of hard to very hard partially indurated silty, fine, sandy clay to clayey silt and sand; and

• Oligocene Vicksburg Group consisting of hard clays and interbedded limestone and fine sand. -. .

Due to the lack of intermediate-age Pliocene deposits, an unconformity exists between the older Catahoula clay and the overlying younger terrace deposits and alluvium. The top of the Catahoula clay is elevated in the area of the power block with elevations generally above 80 ft msl and as high as about 100 ft msl. The top of Catahoula clay elevations generally decrease in all directions from the power block area with topographic lows of less than 70 feet below msl to the west beneath Hamilton and Gin Lakes; less than 20 feet below msl along the north property line; about 10 ft msl to the northeast, and 30 ft msl to south. The area of elevated Catahoula clay appears to exist as a ridge beneath the power block oriented generally northwest-southeast.

The Catahoula clay is the load bearing unit for the major plant structures at the Site. The foundations for the major plant structures including the Auxiliary Building and Control Building were excavated into the Catahoula clay. Sumps beneath the containment building were excavated to depths of about 69 ft msl compared to the existing grade around the power block of about 132 ft msl and pre-construction surface grades as high as 200 ft msl.

The Terrace deposits generally blanket the upland portion of the Site with pre-construction thicknesses of at least 25 feet. The areas of thinnest Terrace deposits were in the power block area where the Catahoula is most elevated. The Loess deposits overlie the Terrace deposits and generally blanket the upland portion of the Site with pre-construction thicknesses of at least 50 feet.

The Alluvium deposits are generally only present in the low lying portion of the Site from the ground surface to depths generally greater the 50 feet and maximum thicknesses of about 180 feet near the banks of the Mississippi River.

2.2.2 Hydrogeology The findings of the Phase I report indicated that several important major regional aquifers exist at or near the Site corresponding to the geologic units described above. These include the:

• Pleistocene to Holocene Mississippi River Alluvial Aquifer system;

" Oligocene to Holocene Coastal Lowlands Aquifer system; and

• Upper Cretaceous through Eocene Mississippi Embayment Aquifer system.

The southern extent of the Mississippi River Alluvial Aquifer system is not present at the site but exists approximately 10 miles north of the Site. The northern extent of the Coastal Lowlands Aquifer system exists approximately 10 miles north of the Site and extends to beyond the Gulf of Mexico to the south. The Site is present near the center of Mississippi Embayment Aquifer system which extends from the southern tip of Illinois to beyond the southern extent of Mississippi into the Gulf of Mexico. The top of this third aquifer is estimated to be approximately 600 feet below msl in the area of the Site.

The Coastal Lowlands Aquifer system is the first and primary aquifer encountered at the Site. The Coastal Lowlands Aquifer system consists of a "gulf-ward thickening, heterogeneous unconsolidated to poorly consolidated wedge of discontinuous beds of sand, silt and clay that range from Oligocene to Holocene." Where sufficiently thick and permeable, the Coastal Lowlands 09.0025576.09 Page 3 4/15/09

I i, Aquifer system yields large quantities of groundwater for high capacity well systems for industrial, municipal, commercial, and irrigation uses. While the Coastal Lowlands Aquifer system consists of five permeable units and two confining units and is greater than 10,000 feet thick south of the Site, it is only present at the Site in the form of the relatively thin alluvial deposits in the lowland western portion of the Site and the terrace deposits and loess in the eastern upland areas of the Site.

Given the presence of alluvial sands in close proximity to the Mississippi River, cooling and On drinking water for the GGNS Site is obtained from wells constructed in the Coastal Lowlands Aquifer system. Additional cooling water is obtained from wells constructed in Holocene Mississippi alluvial deposits and water for other uses at the Site including for consumption is

-obtained from the Pleistocene Terrace deposits -in-the eastern -upland-portion of-the-Site. - - -

Within the shallow soils at the site, there are three distinct water levels: a "perched"4 water table in the Terrace deposits in the vicinity of the power block, a regional water table in the Mississippi River alluvium and potentiometric head in the confined aquifer within the Catahoula Formation.

These are further described below:

Perched Water Table: Perched groundwater is present in the power block area where the top of the Catahoula clay is above 70 ft msl (less than 60 ft bgs in the power block). Water levels measured in the perched groundwater system prior to construction during the period of 1972 to 1976 were generally in the range of 95 to 110 ft msl (20 to 35 ft bgs in the power block), with the highest water level.measured in the perched groundwater system of 130 ft msl.

Regional Water Table: The regional groundwater table corresponds to the water level within the alluvial deposits and terrace deposits outside the clay ridge and are reported to be in the 60- to 85-foot msl elevation range (approximately 50 ft bgs in the power block area). Groundwater flow in this deposit is in a generally westward direction toward the Mississippi River. In the southern portion of the site, groundwater flow patterns in the Mississippi River alluvium are strongly influenced by the pumping from four radial wells that supply water for the GGNS cooling water system.

Potentiometric Head: The potentiometric head in the Catahoula Formation was reported to be in the range of 55- to 80-foot msl. Groundwater flow in the Catahoula Formation is expected to be generally towards the west with discharge to the Mississippi River.

3.0 RECENT GPI FIELD ACTIVITIES PERFORMED AT THE GGNS PLANT This section summarizes information provided by Entergy pertaining to recent field investigation activities performed by others at the GGNS site in support of the pending Combined Operating License Application (COLA) for the proposed GGNS Unit 3 Plant, and incorporated as part of the overall GPI activities for the existing GGNS site.

4 Note that the term "perched" is used in this document to be consistent with the historical terminology used for the elevated groundwater in the power block portion of the Site. In reality, perched water classically refers to water elevated above the regional water table with an unsaturated zone beneath. GZA believes that the elevated water identified in the power block area may actually reflect mounding of groundwater due to the extensive ridge of low permeability clay and that an unsaturated zone may not exit below the elevated water in the power block.

09.0025576.09 Page 4 4/15/09

3.1 GROUNDWATER MONITORING WELL INSTALLATION Monitoring wells were recently installed at the plant to support the GGNS Unit 3 COLA. A total of 44 groundwater monitoring wells were installed at locations west of the existing GGNS Plant within the terrace deposits or Mississippi River Alluvium. Four (4) of these wells located closest to the GGTNS--lant.(.desigZnateu-wel~s4-4Wlf 9OB, MWlO26B, MW1O27B3, and MWll134B) were then selected for groundwater monitoring for the presence of radionuclides in support of the GPI activities for the GGNS Plant. Well locations are shown the groundwater contour plans provided in Appendix C. Boring logs for these wells were not provided to GZA for review.

3.2 GROUNDWATER SAMPLING AND ANALYSIS GZA was provided with groundwater monitoring data (analytical testing and groundwater elevation measurements) for each of the new wells. Groundwater monitoring rounds were performed on July 31, 2007, October 31, 2007, February 1, 2008, and April 14, 2008. Each of the samples was tested for tritium and gamma activity5 by Entergy's Chemistry Laboratory. Analytical results are provided in Appendix B.

3.3 GROUNDWATER ELEVATION MONITORING The draft COLA for GGNS Unit 3 includes groundwater contour plans prepared based on groundwater level measurements in the new wells on December 2006 and May 2007, corresponding to the periods of highest and lowest groundwater elevations, respectively. Copies of these plans are provided in Appendix C. Groundwater measurements are provided in table 2.4.12-202 of the draft COLA. Depth to groundwater measurements recorded in the wells used for GPI groundwater monitoring ranged from approximately 45 to 60 feet below the ground surface.

4.0 FINDINGS OF RECENT GPI FIELD ACTIVITIES The following subsections provide a summary of GZA's review of the recent work performed by others at the GGNS site relative to geology, hydrogeology, and groundwater monitoring results.

4.1 GEOLOGY Although GZA was -not provided-with copies-of boring logs for the new COLA wells, the information presented within the draft COLA suggests the subsurface materials encountered in the new borings were generally consistent with the materials previously described for the site (Section 2.2.2).

4.2 HYDROGEOLOGY AND SHALLOW GROUNDWATER FLOW DIRECTIONS The information presented in the draft COLA indicates that small isolated areas of perched groundwater exist in the loess. The soils of the Terrace Deposits (a.k.a. the Upland Complex) are the principal shallow groundwater bearing unit at the site, consistent with the pre-existing information.

54 58 59 5 These parameters include, Mn, CO, Fe, 5°Co, 65 Zn, 95 Nb, 95 Zr, 1311, 134 Cs, 137Cs, 149 Ba, and 140La.

09.0025576.09 Page 5 4/15/09

As stated in Section 3.3, groundwater contour plans provided in the draft GGNS Unit 3 COLA were based on groundwater level measurements in the Upland Complex wells recorded in December 2006 and May 2007. Copies of these plans are provided in Appendix C. For each plan, the groundwater elevation contours depict a groundwater gradient to the west/northwest towards the Mississippi River, consistent with the SCM. The available information also indicates that although an aquitard exists. between the' Upland Complex and the underlying Catahoula Formation, a downwards vertical hydraulic gradient from the Upland Complex to the Catahoula formation exists.

Although the-groundwater-contours-from-the-GGNS-Unit 3-COLA-providea-solid-understanding-of groundwater gradients west of the existing GGNS plant, they do not show actual gradients and flow directions within the existing plant. In addition, because 1) the closest of these wells to the existing GGNS plant are located approximately 650 feet west of the GGNS plant, 2) that they are spaced 600 to 800 feet apart, and 3) that only one well (MW-1027B) is hydraulically downgradient of the. plant, this monitoring well network does not provide. adequate groundwater quality monitoring for the existing plant.

4.3 SAMPLING AND ANALYSES Radionuclides were not detected in any of the groundwater samples collected from the new monitoring wells sampled as part of the GPI program (Section 3.2). However, it is noted that none of these wells is likely installed immediately downgradient of the potentially contaminated SSCs within the power block.

4.4 COMPARISON TO THE SCM

-As discussed above, the recently collected GPI field data are generally consistent with the Site's SCM. Thus, no changes to the SCM or the Plant's Final Safety Analysis Report (FSAR) are suggested at this time. A brief summary of key findings of the new GPI data relative to the pre-existing SCM is presented below:

• The subsurface aquifer materials described in the draft COLA are generally consistent with the SCM which includes a layer of loess overlying alluvial materials of, the Upland Complex.

• The groundwater elevation data and interpreted groundwater contour plan provided are generally consistent with-the anticipated westerly flow towards the Mississippi River-and Gin and Hamilton lakes. Tritium and gamma activity were not detected in any of the samples collected from the new wells. However, as noted above, these wells are not likely located immediately downgradient of potentially contaminated SSCs.

• The available analytical data do not indicate that radionuclides are migrating off-site into the Mississippi River.

5.0 EVALUATION OF THE PLANT'S GPI PROGRAM RELATIVE TO NEI GUIDANCE Consistent with NEI 07-07, Objective 3.1a, GZA has assisted Entergy in performing a self-assessment of the GGNS Plant's GPI program. In performing this assessment, GZA completed the checklist provided in Appendix B of NEI 07-07 and included in this report as Table 1. An overview of the results and key findings of this review is presented below.

09.0025576.09 Page 6 4/15/09

Our assessment of the Plant's progress relative to the NEI 07-07 criteria was based on information provided by Entergy, including:

• various documents associated with recent field activities, including the draft COLA for GGNS Unit 3.

• corporate and Plant procedures, and program documents; and

• verbal communications with plant personnel.

A listing of the documents reviewed and personnel contacted is presented in Appendix D.

It should be noted that the NEI guidance document is a little over 12. months old. As such, facilities across the country are currently working to put in place GPI programs consistent with this guidance. As with any endeavor involving an understanding of subsurface conditions, this is best accomplished in an iterative fashion. As such, and given the newness of this program, some degree of follow-on work is to be expected as programs are initiated and then refined.

5.1 OVERVIEW ASSESSMENT Entergy and the GGNS Plant personnel have made a significant commitment to the GPI Initiative.

This effort commenced in 2006, before final NEI guidance was released in August 2007 has included, among other things:

" the preparation of a corporate GPI program;

• the preparation of an initial hydrogeology assessment of the Plant (January 2007 Phase I Report);

" the installation of supplemental Site monitoring wells (Section 3.1);

" implementation of groundwater monitoring (Section 3.2); and

• initial stakeholder communications about the GPI program.

This has resulted in real progress at the Site and substantial achievement of the NEI objectives. A brief summary of the key findings for each of the NEI objectives follows. Additional discussion is provided as comments within Table 1.

5.1.1 Key Findings: Obiective I - Groundwater Protection Program Based on our review of the information provided, GZA is of the opinion that Entergy and the GGNS plant have made real progress towards meeting the general criteria of-Objective I of the 07-07 guidance document. This opinion is offered in consideration that the information presented in the Phase I report, combined with the data from the recent GPI field activities, forms the basis of the SCM as presented herein. However, it is noted that, as with all hydrogeologic site characterizations conducted following an observational approach, the activities performed to date should be considered part of an iterative process as data gaps are identified and addressed and the SCM is refined. For the GGNS site, the available data indicate that the following enhancements to the existing GPI program are recommended to meet the 07-07 guidance document:

Performance of a groundwater monitoring well inventory to assess the status of existing wells at the existing GGNS site. If the results of this inventory indicate that existing wells are serviceable and appropriately positioned, select additional wells should be used to assess groundwater gradients, flow pathways, and groundwater quality at the existing 09.0025576.09 Page 7 4/15/09

GGNS plant. If the premexisting well§ are not serviceable, installation of additional monitoring wells to better define the on-site horizontal and vertical hydraulic gradients within the power block area would be required.

• Preparation and implementation of a site-specific groundwater monitoring plan, including groundwater monitoring locations, sampling frequency, data quality objectives, and procedures for periodic review and revision of the plan;

• Preparation and implementation of a buried pipe and tank monitoring and inspection plan;

. Expansion of.the plant's-risk assessment- of engineering -systems-to include-work- practices-and existing leak detection systems and programs; and Preparation of a remedial action plan to address potential spills and releases of licensed material at the site.

5.1.2 Key Findings: Objective 2- Communication ExternaLcommunications is managed. in accordance with Entergy's written procedures. These procedures are generally consistent with the criteria for Objective 2. Thus, only minor enhancements are suggested including but not limited to the addition of procedures for the notification of NEI officials.

5.1.3 Key Findings: Objective 3 - Program Oversight Through completion of this review, the plant is complying with the NEI Objective for Program Oversight. Further reviews in the future should be performed in accordance with NEI guidance.

6.0 OPTIONS TO ENHANCE CURRENT GPI PROGRAM Options to enhance the current GPI program at the plant are included in Table 1.

09.0025576.09 Page 8 4/15/09

TABLES TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potentiall Areas for Improvement Section Criteria Yes-No 1.1 Ensure that the site characterization of geology and hydrology provides an understanding of predominant ground water gradients based upon current site conditions.

1. L.a Perform hydrogeologi& and An initaat ae r-yarogeologlc Assessment o0 me kJUikN riant v reriormance ot a monrtorlug wenl inventory to assess me geologic studies to determine completed January 2007 (Phase I Report). Forty four (44) status of any existing wells. If the results of this inventory predominant ground water flow groundwater monitoring wells were subsequently installed at indicate that existingiwells are serviceable and appropriately characteristics and gradients. locations west of the plant in support of the COLA for GGNS positioned, additional wells should be used to assess Unit 3. The data from these wells, along with information groundwater gradienis, flow pathways, and groundwater provided in previous studies, form an initial basis for assessing quality at the plant. If the pre-existing wells are not regional groundwater flow directions. Based onl these data, the serviceable, additional monitoring wells in and around the dominant shallow groundwater flow directions is towards the power block area areirecommended to assess site west/northwest in the vicinity of the proposed GGNS Unit 3. groundwater gradients and flow directions at the plant.

Additional explorations are required to confirm groundwater gradients and groundwater flow directions in the area of the existing GGNS plant.

1.l.b As appropriate, review existing Yes Substantially completed January 2007 and presented in the None hydrogeologic and geologic January 2007 Phase I Report and draft GGNS Unit 3 COLA studies, historical report.

environmental studies, and permit or license related reports _

l.l.c Identify potential pathways for Yes* Initial identification of pathways completed January 2007 and Review and update SCM and associated pathways following ground water migration from presented in the January 2007 Phase I Report. any additional site characterization conducted under 1.1 .a on-site locations to off-site above.

locations through ground water.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page I of 14 GZA GeoErivironmental, Inc. (GZA)

TABLE I NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria - Yes-No l.I.d Establish the frequency for Yes* A review of existing hydrogeologic studies has been completed as Prepare plant-specific plan to periodically review available periodic reviews of site part of the GPI development process, which is ongoing. Going hydrogeologic studies.

hydrogeologic studies.* forward, hydrogeologic information should be reviewed periodically and following any significant plant or off-site modifications.

l.l.e As appropriate, update the Final Yes* The preliminary hydrogeologic testing results for the GGNS Plant Conduct additional characterizatikn as identified under I.l.a Safety Analysis Report with are generally consistent with the existing FSAR. above and then update FSAR if and as appropriate.

changes to the hydrology and/or geology.

1.2 Identify site risk based on plant design and , "' *-.. M '

work practices* ~ K .

1.2.a Identify each SSC and work Yes* An Operational Engineering Review of SSCs was performed as Conduct a formal review of work practices consistent with practice that involves or could part of the January 2007 Phase I report. This review included NEI guidance.

reasonably be expected to identification of potentially contaminated systems, release areas, involve licensed material and and potential unmonitored contaminant transport pathways.

for which there is a credible mechanism for the licensed material to reach ground water.*

1.2.b Identify existing leak detection No Information pertaining to leak detection systems from the 0 Expand SSC and Work Practice assessment (1.2.a) to methods for each SSC and potentially contaminated SSCs identified in the Phase I report has include an assessment of current leak detection work practice that involves or not been provided to GZA. systems.

could involve licensed material and for which there is a Plant personnel indicate that monitoring of 'non-contaminated"

• Fully implement Entergy procedure number EN-DC-credible potential for systems is performed to detect cross contamination. 343, Buried Piping and Tanks Inspection Program inadvertent releases to ground water.* Plant personnel indicate that GGNS has begun to implement EN-DC-343 Buried Piping and Tanks Inspection Program Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 2 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required PotentiaI Areas for Improvement Section Criteria Yes-No 1 1.2.c Identify potential enhancements No Information pertaining to potential enhancements to leak detection ° Assess potential enhancements to leak detection to leak detection systems or systems f'om the potentially contaminated SSCs identified in the systems i programs.* Phase I report has not been provided to GZA. 0 Fully implement Entergy procedure number EN-DC-While the new wells to the west provide some enhanced leak 343, Buried Piping and Tanks Inspection Program defection capability, they are not close to the power block and are not well-positioned in general to serve as a pro-active leak detection mechanism within the intent of this criteria.

Plant personnel indicate that GGNS has begun to implement EN-DC-343 Buried Piping and Tanks Inspection Program 1.2.d Identify potential enhancements No The information provided by the GGNS plant did not indentify 0 Complete an assessment of procedures and equipment to prevent spills or leaks from potential enhancements or an assessment of potential to prevent releases from reaching groundwater.

reaching ground water.* enhancements to prevent spills or leaks from reaching the groundwater.

• Fully implement Entergy procedure number EN-DC, 343, Buried Piping and Tanks Inspection Program Plant personnel indicate that GGNS has begun to implement EN-DC-343 Buried Piping and Tanks Inspection Program _,

1.2.e Identify the mechanism or site Yes Corrective Actions are identified and tracked in accordance with None process for tracking corrective Entergy's corporate corrective action program (Procedure EN-LI-actions. 102). Under this program, when a problem is identified, a condition report (CR) is initiated, corrective actions will be assigned, and the CR is dispositioned based on its severity. _

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 3 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No 1.2.f Establish long term programs to Yes* Monitoring for cross contamination of clean systems is routinely Prepare site-specific plan in accordance with Entergy perform preventative performed at the plant. procedure EN-DC-343 maintenance or surveillance activities to minimize the Entergy procedure EN-DC-343 provides requirements for each potential for inadvertent plant to develop a site-specific Buried Piping and Tanks releases of licensed materials Inspection and Monitoring program. However, a site-specific due to equipment failure. program for the GGNS Plant has not yet been prepared and/or provided to GZA.

1.2.g Establish the frequency for No The frequency of periodic reviews of SSCs and work practices at Prepare plant-specific plan to peliodically review SSCs and periodic reviews of SSCs and the GGNS Plant has not been established, work practices.

work practices. ' -- * , * .. .. ¢'" ' "t".*' * ** .. i *,

1.3 Establish an on-site ground water ,

monitoring program to ensure timely detection of inadvertent radiological releases , .

to ground water.

1.3.a Using the hydrology and Yes* Forty Four (44) wells were installed west of the GGNS plant in Installation of additional shallow groundwater monitoring geology studies developed support of the GGNS Unit 3 COLA. However, these wells are not wells at hydraulically downgradient locations to the under Objective 1.1, consider " close to the power block, are widely spaced, and are not well I west/northwest.

placement of ground water positioned in general to serve as downgradient boundary monitoring wells downgradient monitoring points within the intent of this criteria. Additional from the plant but within the wells are now needed downgradient of the power block to the fill boundary defined by the site data gaps in the recently installed COLA well network.

license.

1.3.b Consider, as appropriate, No There are currently no sentinel wells at the GGNS plant. Evaluate installation of sentinel wells near potentially placing sentinel wells closer to contaminated SSCs, taking into account other leak detection SSCs that have the highest and surveillance activities potential for inadvertent releases that could reach ground water or SSCs where leak detection capability is limited.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 4 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No 1.3.c Establish sampling and analysis Yes* While ongoing groundwater monitoring activities have been Prepare site-specific groundwater monitoring plan.

protocols, including analytical initiated at GGNS, a comprehensive written plan including these sensitivity requirements, for details has not yet been prepared.

ground water and soil.*

1.3.d Establish a formal, written Yes* Groundwater monitoring at the GGNS plant is performed in Prepare site-specific~groundwater monitoring plan program for long-term ground accordance with Entergy Procedure EN-CY-109 water monitoring.*

1.3.e Periodically review existing Yes* While ongoing groundwater monitoring activities have been Prepare site-specificsgroundwater monitoring plan station or contract lab(s) initiated at GGNS, a comprehensive written plan including these analytical capabilities.* details has not yet been prepared 1.3.f Establish a long-term program Yes* While ongoing groundwater monitoring activities have been Prepare site-specificigroundwater monitoring plan for preventative maintenance of initiated at GGNS, a comprehensive written plan including these ground water wells, details has not yet been prepared 1.3.g Establish the frequency for Yes* While ongoing groundwater monitoring activities have been Prepare site-specificIgroundwater monitoring plan periodic review of the ground initia~ted at GGNS, a comprehensive written plan including these water monitoring program. I details has not yet been prepared 1.4 Establish a remediation protocol to prevent migration of licensed material off-site

• and to minimize decommissioning impacts J 1.4.a Establish written procedures Yes* Leaks, spills, or other releases at the GGNS are managed pursuant Prepare a site specific Remediation Plan consistent with EN-outlining the decision making to Entergy's procedure EN-RP-1 13, Response to Contaminated R.P-I 13.

process for remediation of leaks Spills/Leaks and spills or other instances of inadvertent releases. This process is site specific and shall consider migration pathways 1.4.b Evaluate the potential for Yes* Licensed materials have not been detected in groundwater The potential for detectible levels of licensed material detectible levels of licensed samples from the site wells, resulting from planned releases (e.g., afibome wash-out.of material resulting from planned Tritium) should be consideredin future groundwater releases of liquids and/or monitoring reports airborne materials.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 5 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No 1.4.c Evaluate and document, as No Based on the available information, an evaluation of the impact of Perform an evaluation of decommissioning impacts.

appropriate, decommissioning site conditions on plant decommissioning has not been performed impacts resulting from remediation activities or the absence thereof.

1.5 Ensure that records of leaks, spills,  ! .

remediation efforts are retained and **<

• fI f -

retrievable to meet the requirements of 10 '

CFR 50.75(g).

1.5.a Establish a record keeping Yes The plant maintains a record keeping system pursuant to 10 CFR None program to meet the 50.75(g). These files were reviewed as part of the 2007 Phase 1.

requirements of 10 CFR study.

50.7 5(g)"

2.1 Each licensee should conduct initial and ,, -. ,

periodic briefings of their site specific GPI z program with the designated State/Local officials 2.1 a The licensee should discuss i) Yes Information from the GGNS plant indicates that initial briefings None The background or industry with municipal officials has been performed.

events that led to the GPI ii) If there is additional information that the State/Local officials need to .better understand the issue or place it in perspective for their constituents iii)

"How" the State/Local officials will use or distribute the inibnnation Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 6 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No _

2.l.b Licensees should consider No The information from the GGNS plant do not indicate that Provide communication updates with municipal officials including additional additional updates have been made to municipal officials information or updates on ground water protection in periodic discussions with State/Local officials _

2.l.c For licensees that are in States Yes GGNS is the only nuclear power plan in Mississippi. None where multiple nuclear power plants are located and multiple owner companies, it is highly recommended that the licensees coordinate their efforts and communicate with each other.

The initial briefing for the State/local officials and the contents of a voluntary communication should be I consistent.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 7 of 14 GZA GeoErivironrmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guidelineseto_t Objective/Acceptancerira Section

_esNMet Comments As Required Potential Areas for ImprovementI 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 OCDMJODAM.*

2.2.a Communication with the Yes Entergy's procedure EN-RP- 113, Response to Contaminated None designated State/Local officials Spills/Leaks, requires notification of Federal, State and Local shall be made before the end of agencies within one business day of the release to the the next business day if an environmental of contaminated material of more than 100 gallons, inadvertent leak or spill to the or of unknown volume, or other leaks deemed by the plant to environment has or can warrant voluntary communication. To our knowledge, no potentially get into groundwater conditions triggering this notification have been recorded.

and exceeds any of the following criteria: i) If a spill or leak exceeding 100 gallons from a source containing licensed 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.

• Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 8 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No 2.2.b Communication with the Yes Entergy's procedure EN-RP-1 13, Response to Contaminated None designated State/Local officials Spills/Leaks, requires notification of Federal, State and Local shall be made before the end of agencies within one business day of the confirmed detection of the next business day for a activity in either an off-site or on-site groundwater or surface water sample result (i) of off- water sample which exceeds the REMP reporting criteria. To our site ground water or surface knowledge, no conditions triggering this notification have been water that exceeds any of the recorded.

REMP reporting criteria for water as described in the ODCM/ODAM, or (ii) of on-site surface water, that is hydrologically comnected to ground water, or ground water that is or could be used as a source of drinking water, exceed any of the REMP reporting criteria for water as described in the ODCM/ODAM _ _ _

2.2.c When communicating to the Yes Entergy's procedure EN-RP-I 13, Response to Contaminated None State/Local officials, be clear Spills/Leaks provides guidance for communications with Federal, and precise in quantifying the State and Local officials. To our knowledge, no conditions actual release information as it triggering this notification have been recorded.

applies to the appropriate regulatory criteria.

• 2.2.d Voluntary communication to Yes As stated above, Entergy's procedure EN-RP- 113, Response to None State and/or Local officials may Contaminated Spills/Leaks, includes notification of Federal NRC also require NRC notification regulators. To our knowledge, no conditions triggering this under 10 CFR 50.72(b) (2) (xi). notification have been recorded.

Licensees should perform these notifications consistent with their existing program, Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 9 of 14 GZA GeoEnvironlnental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section __Criteria __Yes-No 2.2.e Contact NEI by email to Unknown Information from the GGNS does not confirm if this Confirm that procedures to communicate with NEI per

/GW_-Notice@nei.org as part of communication has been made. Objective 2.2.e are in place.

/a voluntary communication

/event 2.3 Submit a written 30-day report to the NRC for any water sample result for on-site ground water that is or may be used as a source of drinking water that exceeds any of the criteria in the licensee's existing REMP/ODCM for 30-day reporting of off-site water sample results. Copies of the written 30-day reports for both on-site and off-site water samples shall also be provided to the appropriate State/Local officials.

2.3.a All ground water samples taken Yes* We understand that the groundwater samples were analyzed and Verify that all groundwater analysis are compared to the for the Industry Initiative shall compared to the plants REMP. plant's REMP.

be analyzed and compared to the standards and limits contained in the station's REMP as described in the ODCM/ODAM*

2.3.b The 30-day special report Yes No 30-day reports have been submitted to the NRC for the plant., None should include the items listed*

2.3.c All written 30-day NRC reports Yes No 30-day reports have been submitted to the NRC for the plant. None generated under item 2.3.a are to be concurrently forwarded to the designated State/Local officials Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 10 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No 2.4 Document all on-site ground water sample results and a description of any significant on-site leaks/spills into ground water for each ,

calendar year in the Annual Radiological ,..; r .

Environmental Operating Report (AREOR)

• r , : t' "

for REMP or the Annual Radioactive Effluent * ".,

Release Report (ARERR) for the RETS as , , ,..

contained in the appropriate Site reporting , ,, 0 procedure, beginning with the report for... .

calendar year 2006.

2.4.a Complete appropriate changes Yes* I No changes to the ODCM/ODAM have been made given that a Complete written gr6undwater monitoring plan and make to the ODCM/ODAM or to the groundwater monitoring plan for the site is not yet available. appropriate changes to ODCM/ODAM appropriate procedures to support the 2007 report. For new plants, appropriate procedures that require inclusion of significant on-site leaks/spills into ground water and all on-site ground water results shall be developed and implemented prior to initial

-_receipt of nuclear fuel*

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page I11 of 14 GZA GeoEnvironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria' Yes-No 2.4.b Report on-site ground water Yes Information provided by the GGNS Plant indicate that the None sample results as follows i) available groundwater monitoring data were appropriately Ground water sample results reported in the 2007 ARERR. However, a copy of this report was that are taken in support of the not provided for review.

GPI but not part of REMP in the ARERR ii) For long-term sample points that are included in the REMP as described in the ODCM/ODAM, the results are reported in the AREOR; those long-tenr sample points that are not included in REMP, the results are reported in the ARERR

• Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 12 of 14 GZA GeoEnvironrnental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas for Improvement Section Criteria Yes-No l 2.4.c In addition to 2.1.b, voluntary Yes* Based on information provided by the GGNS Plant, this Verify that the infor/nation will be provided in the 2009 communications shall be information will be provided in future reports as appropriate, report included as follows: the following are to be included in either the ARERR and/or the AREOR i) A description of all spills or leaks that were communicated per Objective 2.2 acceptance criterion a shall be included in the ARERR ii)

All on-site or off-site ground water sample results that exceeded the REMP reporting thresholds as described in the ODCM/ODAM that were communicated per Objective 2.2 acceptance criterion b shall be included in either the ARERR and/or the AREOR 3.1 Perforn a self-assessment of the GPI ' - " w program (references this check sheet) .  :.

3.1.a An independent, Yes Performed by GZA None knowledgeable individual(s) shall perform the initial self assessment within one year of implementation.? _

3.1 .b Perform periodic self-assessments of the GPI program at least once every five years after initial self-assessment.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

09.0025576.00 Page 13 of 14 GZA GeoEnfivironmental, Inc. (GZA)

TABLE 1 NEI SELF ASSESSMENT CHECKLIST Grand Gulf Nuclear Station Port Gibson, Mississippi Guideline Objective/Acceptance Section Met Comments As Required Potential Areas fotl Improvement Section Criteria Yes-No 3.1.c The self-assessment, at a minimum, shall evaluate implementation of all objectives identified in this document.

3.1.d The self-assessment shall be documented consistent with applicable procedures. * ** ' * * * , I* * ** I '** *.  :.

3.2 Conduct a review of the GPI program, including at a minimum the licensee's self-assessments, under the auspices of NEI.

3.2.a An independent, knowledgeable individual(s) shall perform the initial review within one year of the initial self-assessment perforned per objective 3.1.a above 3.2.b Periodic review of the GPI program should be performed every five years, subsequent to the license's periodic self-assessment performed per Objective 3. .b above.

Notes:

• indicates progress has been made towards meeting the stated NEI criteria. However, additional progress is required to fully meet the criteria.

,'V.

09.0025576.00 Page 14 of 14 GZA GeoEnvironmental, Inc. (GZA)

I FIGURES

N GROUNDWATER PROTECTION INITIATIVE ENTERGY NUCLEAR GENERATION COMPANY GRAND GULF NUCLEAR STATION GRAND GULF, MISSISSIPPI

ki POTNTAl RAITD W inNTLSA U AREAS O

[SYSTEMI' FRIA TAl 1 m- I LIGUIDRZADIACTIVE WASTE[1GI7,PASI O DISCHARGE BASIN[1i31 Q CONDENATE STORAGE ANDDRANSFEW PIGSI REFUELING W/ATEASTORAGE [Pil CO) DILUTERMIXTUREDISCHARGE PIPING [1*111 ROTORCOOLAT MONITOR AT PUMPP WATER~~~DWTEN CICLTIGHUSlL, ~) 8

.*'/,-me W-,3 2 62 LEGEllrt*/h32SW8 ND:n te t 5t MR*NATOR War ILL Iis FACILITES KEY:

12n C-dlngN Wi 32* Unity I-d 4 Unit Wt0.T  % PPr B o ulldb Au~gioE cl141y g 35 31 RokgTw nling o,.nohi nr..

V__________________________________ S Uitij 2 Eonioln-t.n 36 Old'GCIl l.oto Ofto. R1,iiig Uito T3n i DO I uitt 011400 8a Uni A ý.I il I.t din4,; 3A C-gA Th,.

t) oi.. G-nnto1-- 0 .W0.oio dN14H W_ II o ..... 41, P-1.nl; D, 1" . lod1in ,0011 OW -4 210;,o -Ca ,on1 ats R1M,lO Rt., ,42 Pint.,, tI . Tra .,

Qt2 Stoog. Tank-C*O*t-1 ngT g 001.f1n9 WoW-9 4 Mot. _0,1.

4, Paint otag. oin 44 Enonn O

.gItt1d.,

Spo_ t

I4 Stong. Thi Dmn Win 5 MltltfS 15 Wter Tratmnt 46 Re .tor.IH d StagA BuildO g AA Nlter Treatent A, 47 at. OilStorate Sh1 d C

:2ol~~~ ~~~~~~~g 17 Iltl, Tr-tmnt Building AýiwastehuS-gtfc~.

IS A. tIft. Pimp 1-&1. 7-1tae~cet 11" k

'4 KerryAW Stn 4 OutageMtloi *ngmTl V

ttag. 04d.

g I ... h52 GontroCt"tt _rass Alle C523 - OldGEWbUquId 2 n-.1.l hwl.,.It-ra, Wud"I"

- 54 SO Ill Tnt G Si. - -%..AShý F4/Ii1y O52eRadOff-Go.

.. G4l W-ugn

~F..lt 5O1-gS/.noto. 5 5

S.'nitnyflC log.H.-

26 OldIGE ioding CC". 51 fat- =

0 n T04 Tur1. M iddo ng 59 Go. C/ l.ng TS nu-a lUnt O....... . . ..... . tt.nSI.. .

DG .

34 SSWB..d~ :10 *o ty olig to. - &00.4, lf 5631S IN8.1 2 -11oionCoWllg To .b~,

St tion 52 RIPtN BY dSIOS GROUNDWATER PROTECTION INITIATIVE

" ENTERGY NUCLEAR GENERATION COMPANY GRAND GULP NUCLEAR STATION GRANDGULF,MISSISSIPPI NOTES' SITE FEATURES AND 1BASED ON EATERGYPLAN4TTLEOSItE PLAN.DRAWIAG MS0237.DGN. EXPLORATON LOCTINo to AN

2. WELLLOCATIONS BASEDON ENTERGYT PLANTITLED DEWATERIAG AND O WELL SER SIATION .00 t 1 t OltItO AT 01 YTI1100 T000,T1I ItO -

PLAN

. DRAMAS OTHERMONITURIAG MATERfTAO.DGN. WELLSEXISTON THEAIMS SITEMESTo0 , Ei000it tR b0 a 00*100 NL

• £OWNt 0IO0000 tooonoEoointD, D~ O *.oUE , -P*

209" 0.oor 557-8M 000 0 On 4010 FIGUR OF THECPORTIONOFTHESITESAHANON THIOFIGURE.  %=n =

3. T100000iNTRUS/ON POTENTIAL AREASSHOWNHEIREON AREBASEDGA THE "  ! ttnio*Ano*:t,F?*[, 00 00 0 0

• .US ouT,t ,

1 0 0 0

- 00o0 P SF00GURE00 OPERATIONALENGINEERINGREVIEWPERFORMED BY ENERCON; OBSERVATIONS MADEBy W 00T00

... 0Sor 001 1.000100. 00.-E ENERCON MNDGZA DURING A SITE WALKON NOVEMBER 30. 2006: ANDREVIEWOF Tono o o.' I;0 , t.00 000 0. ,0002 INFORATIO ASo SUMARZE IN0 THIS0i REPRT _g00 = ... in AMto 40400 O.On

APPENDIX A LIMITATIONS

APPENDIX A PROJECT LIMITATIONS

1. This focused report was prepared for use by the Client at the subject Facility, for the limited technical and legal purposes stated in the report. We take no responsibility for other uses of this report, or for use by other parties.

2.- By agreement with the Client, we reviewed-and-relied on-information-provided-by-the Client and Facility to develop our opinions. We also relied upon public sources of information to help develop our understanding of the Facility's hydrogeologic setting.

Local subsurface conditions or soil heterogeneities may exist and may subsequently be shown to have an unanticipated effect on groundwater flow patterns. These were initial reviews; we did not attempt to verify or validate information, oral or written.

3. Unidentified and/or unanticipated conditions-may exist. Should such conditions become obvious, it may be necessary for us to reevaluate the opinions expressed in this report.

4. Our findings and conclusions are provided as professional opinions, and not as statements of fact.

5. Our services were provided with the degree of skill and care ordinarily used by qualified professionals performing the same or similar services, at the same time, under similar circumstances, in the same or similar locations. No other warranty expressed or implied is made.

09.0025576.00 4/15/09

APPENDIX B ANALYTICAL RESULTS

Q, VpSI1EID. ILABI D dSM EYEI,.SAMPLE lD<YPIý:,ý,SM LED IENDODATE. [EOI M SI IS31>FE,5>~4I0-O 5'Z-5ISIN-5.S1R91ISI~I11I9 S1411C-3 7 MW-1134B Pre-iGGNS 20070820 GMW Sample 7/31/2007, 8:06< 12.34 < 8.47< 1885< 9.75 < 17.00< i 10.68,< ;17.43;< 11.88< 14,62i< 10.35i GN 20081MWWi13GW 7/31/2007ý. 9:32< 10.X34< 727< 229_9;<`- 8---.75< 29.94. < I 14J6;<- 123 9.36< 1281< 06 iGGNS 20070822,GMW sampie 7/31/2007 951< 8.70< 8.381< 16.91 < 8.26 < 19.51 < 904'< 1231< 1332< 799:< 7451 GGNS 20070823 GMW MW-1027B GW i 7/31/2007i 1115< 835< 897< 16.17< 897 25.16.. < 118.61< .. 787< 14.84< 28 7.27 IMW-10278 Post-iGGNS 200705241GMW iSample 1 7131/2007 11:38< 8.99< 1 1034< 1851 < 8*10 < 16.03.< 12.38'< 16.99< 10.09'< 10,08;< 8.96, GONiýS 200C70825 GMW WW-1026b0GW ....... 7/31/2007 13:03 7.40;< 4.35 < 11.28 < 3.67 16.63< 9.38< 14:6*< I 13< 790. 8 37'

' - MW-1O20B Post-1GGNS 20070826 GMW 'sample 7/31/2007 13:28 < 9.57 < 8.35< 21.88 < 7.52< 18.95 < 10.60.< 13.88,< 9.22'< 8,04'< 8.42 GS 20070827, GM iMW-102-68G, W.......... .....7'/3'1/20 14410< 12 48<.901 < 6i 11421< 11.29< 21.18<'. 13.17< 2014< . 1198< 12.93:< 14.34.

MW-10268 Post- ~ . I GGNS 20070828 GMW sample 7/31/2007, 15:00< 10.74!< 9.29 < 11,41 < 8.30 < 21,93::< 10:29:< :14.04< 12.93< 12,12:< 8.22 GGNS 20071175 0MW Sample 10/31/2007 9:00< 7.871< 7.99 < 16.03 < 6.30< 14.31;< 889< 18.10U< 13.04" 782< 6.69 GGNS I 20071176GMW MW-1134BGW 10/31/2007' 930< 629< 772< 14.62 < 5.76 < 11.50i< 8.151< 13< I 17 840<4831<

V............oii-...........W-14Pot IGGNS 120071177:GMW jSample 10/31/2007 9-45< i 7.311< 7.401< 13.271< 8.18.< 10,29< 8.67!< 12.68;< 13.14:< 7.25ý<_ 8.26i SMW-1027B GW 10/3 6961<_ 71 2 1< I 18.20i< 833 13.15< 88 7.89 < 70 h I MW-1027B Post-I GGINS I 200711790GMW !Sample 10/31/2007 1106& < 1010< 1066 < 22.23i< 5.02:< 23.59 < i 8831< 17.50< 14.44:< 13.721< 6.25.

iGGNS 20071180,1MW 8 W 10/31/2007j_.1215< 929< 725

'W-1020 1283<, 6 52< 1.55< 9,70< 15.38 < 1386<, 7.90< 1.0

!MW-1020B Post-.

rGGNS 20071181 GMW ýSample 10/31/2007i 12,20 < 7.20< 7.41 < 13r23< 09,< 14.01< . 6.55i< 11.65< 10.59< 7.83< 7.90:

GONS5 20071182GqMW _MW-1026BGW

, .10131/2007. 13:30<

.. 7,47 < 6.48 < 12.32< 6.36< 14.53:< 872 < 1193<1 10,99< .3 6.67:

126 P.os..t-.... . ...

1G 2001113 M. ISample 10/31/2007. 13:40< 8.51< 9.30o< 19.03<- 5.90 25.90< 10.23< I 14.15:< 12.42< 8.91.< 9.821

• SITE~I D! L*B'2" SAMLE.k'0I'FE *SAMPL*E lD*Y i'- IENDOATE *AEND TIMES*1 M'$IN-4 iC0:60* 2 '0058 S3 EE59]'-'$4 5 I ZN:65',-'jSj 5 S R9 .S -I11 94C~-4, SN 11~S13~

GGNS 20080251!GMW - MW-1134b Pre 2/1/2008' 8:30'< 10.74t< f 7688 < 17.254< 605 < 23.90:< 6.94:< i 16.56;< 12.84<! 7.98< 8.46'

ýGGNS 20080252GMW IMW-1 134b GW 2J1120081 9151< 70< 1 9< 110 6 iGGNS 1-20068-052-53d0MW 1MW-i1134b Post 2//08 :30. < 8:88i< 7.861<ý 21 95< 8.24 10,14i< 8.59 < 12.64;< 143 .<, 9.60:

GGNS f20080254 GMW MW-1027B GW 2/1/2008 1035< 5.32< 565< 1360< 5.97< 13 57i< 8 49< 12.58 < 11.33 < 6.83< 6.04 GGN'S'20080255GMW iMW-1027B post 2/111208 11:00.< 86004< 13.04< 9 <18 18.28<

........... .. ..8.99<,

.... 9 -; 11:98< .......... 13.58i<

. .. . . ............. 2...... .. .... . . 7.76

( < . ...... ..8.. 5 GONS 20080256!GMW MW-i027BG 2i208 10:35t,2 5.58< 1330<ý 5,78< 13< 7.39 < 1.57< 06< 6.43. 5.90' iGGNS ,20080257 GMW 1 W-028 os 2/1/20M8 12:15.< 742-6 -- 132< 18.07:< 9.05 < 17.09.< 1297< 7 1006 8.37,~k 1-5N§ 20080258 GM4W MW-1026B GW- 2/1/2008, 13:15< 972 5.54<, 19.61 < 9ý41f 1535< 1210<. -_i.&'- 1335

!0111ýIl9.23 <_: _9.05ý iGGNS 20080259 GMW MW.2Bps //08 13< 991 56 < 17 15 10.89 < 1905< 1013< 1383< 1415< 967< 11.25

!GGNS 20080476 ~

FGiGlM ;i/

(g-'iM*068............ .....MW-I1134B *V ..........

M* ,1'°:7 i* PRE  !....... *4/14/2008ý

• i*/$ 8* ....................

84< ................

1.0

.. 7

...........929< -............

IT~,i+ ",788" ............-..2<

6

.... 27< 10.94 < 14-59<! 11.42 < 10.85<, 11.09

~GS 20080477 GMW MW-1 134B GW 4/1420 2< 52< 98 16 6 22.88.<

....... 2-*8i**12.81<,

£ i......... *7i - ..........

,1)i* ! * *.............Y; 14.76ý<

• * ...... 7.85 13.27:<

5<* '.....i8 4; 10.43.

20080478 GMW 2GNS .MW-1134B POST 4/14/2008' 9:30 < 10.71 < 1058< 1415< 1012 1983 < 9.97< 16.45<, 122 11:78 < 9.93S G NS 20080479 GM MW-i1027 GW 41208 13< 725<94 191< 973 17.58< 9.13< 14.58< 8.42< 8.94< 9.80 JGb §-8--ýi8ý60GM .------ W-1027 POST 4.1..4.200.566<

.8..4.... 6 " 1

.80 <......

< 7.53 < 15.51< . 7.76< 14.11< 10.581< 70.4 i 20080481 GMW-102

-GGNS MW GW 4/14/20081 11:35 < 10.461< W 8 28< 10.15 23.63;< 1__10.26< 15.63< , 16< 11.87<, 10.10' GGNS 20080482 GMW iMW-i 020 POST 4/14/20081 11:45.< 1024< 9 40i< 1705< 9.05: 18.54!< i 650< 17,16< 10 8.87< 11.12'

GGNS 20080483 GMW---- W-1026 GW 41/08 24< 97 87< 22.511< 10.711 26.92< 9.80< 11.82 < 12.20ý< 1106 < 11.43

04N4 GMW MW-1026 POST .. 4/14200 125 8.97..916<.1840<.711 21.241< 1 9.78< 17.12 < 10.75< 7,96< 9.481

IDI SMPL

[SITID. " LASAPLED TYEJ II EN DAE~.SillBA-40. S11 . L'~i4:~.l14l,. H-3'1KErrrlI 1,4SITE; JUCT"' LAB ID,ýI:SAMPLE:TYPEJ SAMPLE 1D END ýDATEýý'; IS1,,1I:!,BXT40 ý`]'Sl 2 1:;Dl LAý14W] S141 H-3 1 Error'15" SMW-1134B Pre-

!GGNS 120070820 GMW Sample i...........i*3,*2*

7/31120071< **..........*,*:37:57*!;*

• .. ....13.50< *"*..... *.

527.552 . .... ........

GG~NS-1 200708k21 G'MW M -1468Gw 341< 11.97<ý 527.27:

iMW-l 134B post-IGGNS I 20070822 GMW _ sample 7131I2007i< 3788< 14.67 < 526.91 GGN" ......."26676620083GMW

........... ....... M.MW-1027"

...........M W-1027B GW Pos~t- 7/1207 475: < 8.33' < 552.29.

,GGNS 20070824 GMW Sample 7/31/2007.< 39.01< 1398< 551.15 GGNS 20070825 GMW :MW-1020B GW 7/3112007 < 31 .39-< 12.85 < 525.60, S iiMW-1020B Post-

,GGNS 20070826 GMW sample 7/31/2007 " 38.62< 1250 < 526.90

ýGGNS 120070827 GMW _ MW-1026B GW 7/31/2007< 41.71:< 1162<

bi 52896 1

MW-1026B Post-iGGNS 20070828 GMW iSample 7/31/2007:'< 40.24.8< . 13.76. 527.43 S.......... i.. ... . .........

i.. ...... ......... . l l 13 ,B os :

IMW-lIl34B Pre-10131120071 34.78. < . 13.31 528.23.

1GGNS GGNGG .. *20071175:GMW 66*l* ""

20071176 GMW*..... ..........

Sample m O 134BGW G.... .

.... 10/31/2007; 30.82 14.20< 553.18:-----

'MW-1 134B Post-GGNS .200711773GMW Sample 10131/2007< 36.72< 1302'< 549.48 0GGNS GMW 20071178 MV-102713b GW 10/31/2007< 30.16< 1216< 550.51.

MW-102713b Post-GGNS 20071179 GMW 'Sample 10/31/2007i< 52.00< 14.10 < 543.25 10/31/2007< . 3878< 1391 < 5462 .

'GGNS 20071180;GMW MW.-1w020B GW 10/31/20074< 31.23'< 127931< 550.51

.NS 200 18. 2 .......

GMW .W 6..........G...... 1031207< 311< 12.78'< 5-23'61

.....7 ........... MW-102"6B Pst-

'GGNS 200711 83 GMW . Sample 3/07< 33.57< 1251Iý< 519.42:

• 7,!!t

_fENDDATf7TESli FrA4140 I S121 ;4,l2'A-1l40' 2/112008;< 47.00 <

,ýýýS.141 12.57i<

~.H-3~ . [ErrorlS.

463.33, S...... 'GGN

.GG 0080251 GGM 208025 2.. . .. *MV-1 026B W- Post- ...

GqGNS '20080256 GMW . M-07 GWa 2/1/20081< 36.57.< 11 8 61 i................

i 1 i I* ......*48.59.<

2/112008!< .* * - ..... y** 7.27!< = :6  : t .............

470.84 2/1/2008<

I...............

5)i*6 * ; -"I.. I.-...... 3607T<

.. __-:6 ... .. i14.36i<,T 1 ,--.- - i 4486650 5 6 [.............

-* -8 2/1/2-0084< 41.01's< 14.881< 44569 GS 2_0,08,0,289 3GMW MW-1026b Post 2/1/2008t< 31,.1,3: 10.33< 463 GGNsGN ... 20080250476GMW 200-80257 GMW ............ " -113 PRE,

,MW M W-....... 'i2/1/2008 < 43.14i< 13:99"< ......4.5 45 6 .64 GGN3*s

.GGNS jGGNS .

2006802452GMW 20847 20080256 GMW MW-1134 ....... :MW-11"34 MW-10263 GWt...

GW 7 GPW pI 211/2008i< 47.98:< 3.69 < 431.97.

2//208< 51.11:< 61< 562.81ý GGNS 20807 GMW 'MW-1027 GW, 4/14/08< 35.29 < 13.32< 6195.3: ...........

RGGN ...2ý0080ý480 MW .. MW-1027I post 39.50< 14.53 < 608.77 411412008t<

'GGNS :200804581GMW" MW-i 2G'W 4/14&668< 32.89< " 13962< 61`811 4/14/2008< 2870< 26< " 617188 GG'(NS 20080482 GMW MW-1020 POST 4/14/200 8< 33 33< 1 1.94< 1 617.56

GGNS 20080483 GMW MW-1027 GVV 4/14/208< 2754 13062-<- 616.61,

.. 4/2008.< 34.87< 12.86,"< 618-51

...... 41 3/ 60S<

74< 61665 .

iGGNS .20080484 !GMW ;MW-1026 POS 4/14/200< 338< 0 6152

APPENDIX C GROUNDWATER LEVEL DATA

Grand Gulf Nuclear Station, Unit 3 COL Application Part 2, FSAR (N

(

a--.... ..

General Powerblock Area C.-V T-LEGENO 6 Well Location Well Designation It/I A

Groundwater feveation.Feet MSL

7: Existing Building Existing Road Groundwater Etevetron Contour (Dashed W=ere Approximate) contour interval- 1 foot Groundwater Graodent ..

0 425 850 S-et feet Figure 2.4-12-203. December 2006 Groundwater Gradient Map, Wells Screened in the Upland Complex Revision 0

Grand Gulf Nuclear Station, Unit 3 COL Application Part 2, FSAR 2

75..0 C -7 , i 0-. . ....

General Unit 3 Powerblock Area n`ý"

LEGEND Well Location

• o Well Designation e/ "o Groundwater Elenation, Feet MSL

.-:- Existing Building

- Existing Road Groundwater EOevation Contour contour interval - 1 foot (Dashed Where Approximate)

- Groundwater Gradient 0 425 850 Feet Figure 2.4.12-204. May 2007 Groundwater Gradient Map, Wells Screened in the Upland Complex GGNS ESP CC)L 2.4-9 Revision 0

APPENDIX D LIST OF DOCUMENTS REVIEWED AND PERSONNEL CONTACTED

APPENDIX D LIST OF DOCUMENTS REVIEWED AND PERSONNEL CONTACTED Grand Gulf Nuclear Station Port Gibson, Mississippi

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

• Entergy, EN-RP-1 13, Rev. 4, Response to Contaminated Spills / Leaks

• Entergy, EN-CY-108, Rev. 2, Monitoring of Nonradioactive Systems

" Entergy, EN-CY-109, Rev. 2, Sampling and Analysis of Groundwater Monitoring Wells

• Entergy, EN-RP- 106, Rev. 1, Radiological Survey Documentation

" Entergy, EN-LI-108, Rev. 2, Event Notification and Reporting

• Entergy, EN-LI-.102, Rev. 12, Corrective Action Process

• Entergy, EN-IS-1 12, Rev 5, Trenching, Excavating, and Ground Penetrating Activities

" Entergy EN-DC-343, Rev. 1, Buried Piping and Tanks Inspection and Monitoring Program

• Draft COL Application, Grand Gulf Nuclear Station, Unit 3, Part 2 FSAR, Section 2.4.12 Groundwater

• Microsoft Excel spreadsheet titled "Entergy South GMW Sampling Results.xls" provided by Entergy

• John M. Lassetter, Grand Gulf Nuclear Station

• GZA and Enercon, January 30, 2007, Site Hydrogeologic Assessment in Support of Entergy GPI, Grand Gulf Nuclear Power Station, Port Gibson, Mississippi.