ML12335A616

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Official Exhibit - RIV000082-00-BD01 - Entergy Nuclear Management Manual, EN-MA-125, Rev 4, Attachment 9.1, Initial Investigation, Troubleshooting Plan for H-3 Investigation, Storm Drain System a, March/April 2009, IPEC00194517 Dec. 22, 201
ML12335A616
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/22/2011
From:
Entergy Corp
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21642, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12335A616 (17)
v • d • e


Text

{{#Wiki_filter:United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc. In the Matter of: (Indian Point Nuclear Generating Units 2 and 3) 

           "",~p..R REGUz.q"        ASLBP #: 07-858-03-LR-BD01 RIV000082 l~~

Docket #: 05000247 l 05000286 

 ..."                          0~

Exhibit #: RIV000082-00-BD01 Identified: 10/15/2012 Submitted: December 22, 2011 

 '"                            ~    Admitted: 10/15/2012                              Withdrawn:
     ~
      '<4; cS'      Rejected:                                            Stricken:
            " ~***.      '"            Other:

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT I 

                                           '11t::1t:5Y             MANUAL                      INFORMATIONAL USE               PAGE 1 OF 36 ATTACHMENT 9.1                                                                                  INITIAL INVESTIGATION Sheet 1 of 4 Troubleshooting Plan for H-3 investigation, Storm Drain System A,                           March/April 2009 Problem Descriptions on the WRIWO/CR or other actions:

CR-IP3-2009-01609 (3/25/9) identified unexpectedly high H-3 results in A system storm drains. Discussions with Operators, System Engineers or Maintenance Personnel: Communicated with Ops, Engineering, RP, WM, and Chem. An overflow of CVCS water was identified on Feb 4,2009, inside the CVCS tank area of the PAS. Communicated with site hydrologists. H-3 migration into storm drains from this event is possible, but unlikely due to elevation differences. Therefore investigation is ongoing, looking at buried pipes, unreported spills, groundwater contamination in the area, etc. A troubleshooting plan was suggested to ensure proper communication and provide the teamwork needed for this investigation. As Found Condition: Multiple samples were taken to confirm the H-3 contamination. Drain A-2 was the highest, at 90,000 pCilL (nominal is < 1000). This drain was stagnant, as is its normal condition. Drains downstream showed the expected dilution from what appears to be introduction at A 1 or A2 (see diagram). No immediate source or indication of surface water leaks/spills could be identified. The overflow of CVCS water in early Feb is being evaluated, but it was determined that the storm drain water is more than 15 feet higher than the suspected level of H-3 from this overflow, inside the PAS. Other sources of possible ingress are the U3 RWST, the U3 SFP, the U3 SFP truck bay (liquid waste processing), and the 95' hill (washing down past the RWST to the A system area roadway). This storm drain system empties into A-6 drain, which does NOT retain water long, passing it quickly to the E system, where it drains down the old U3 roadway to the old U3 command post area, and into the discharge canal. No activity (gamma or H-3) has been identified in the E system. This system involves significant dilution, so the absence of H-3 in E system was not surprising. The source of the Storm Drain Tritium contamination was not immediately known, but suspected as a function of washout. EQUIPMENT RESPONSE INFORMATION GATHERING Equipment 10 Expected Response Actual Response Storm 3-25-9 - 1000 pC ilL H-3 4330 pCilL H-3 Drain A-1 4-1-9 - 1000 pC ilL H-3 5890 pCilL H-3 Storm 3-25-9 - 1000 pC ilL H-3 21,600 pC ilL H-3 Drain A-2 4-1-9 - 1000 pC ilL H-3 94,200 pC ilL H-3 Storm 3-25-9 - 1000 pC ilL H-3 1900 pCilL H-3 Drain A-4 4-1-9 - 1000 pC ilL H-3 17,600 pC ilL H-3 Storm Drain A-6 3-30-9 (or 3-25?) - 1000 pC ilL H-3 2160 pCilL H-3 (No water available for sample on 4-1-9) IPEC00194517

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT r------------------r--------------~----------~ MANUAL INFORMATIONAL USE PAGE 2 OF 36 ATTACHMENT 9.1 INITIAL INVESTIGATION Sheet 2 of 4 PROBLEM STATEMENT: Tritium at these levels is not expected in these drains, which collect mostly runoff surface water between the 95' hill and the PABIFSB wall. While this H-3 introduction may have been from a one-time event, it may also be from underground piping or an unknown source. OBSERVATIONS:

1. Overflow of eves water on Feb 4 would have had to rise more than 15 feet to reach drain A-2. There is currently no credible method for this transition.
2. No standing water or evidence of leakage from RAMS, Annex, or FSB.
3. No evidence of RWST or other leakage, on the surface, from the 95' hill.
4. RWST was placed on recirc 2/9/09. The tank was purposefully overflowed thus filing the overflow line as part of this evolution.
5. A pipe integrity test was conducted in late March, on the RHR pump line to RWST.

This test's acceptance criteria is 7 gallons per hour.

6. See attached specific chemistry sampling timeline.

IPEC00194518

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 3 OF 36 Initial Chemistry Sampling Timeline, Feb -April 2009 04 Feb 09 03:55 32 Mon Tank pumped back to WHUT, 1700 gal overflowed to floor and sump. Mn-54: 1.92E-6 Co-60: 5.25E-5 H-3: 0.674 uCilml 11 Feb 09 20:40 Quarterly test of Storm Drain A-4 indicated slightly elevated H-3 19 Feb 09 10:35 Requested verification sample of A-4 H-3 indicated < mda <<6.39E-7 uCilml) 25 Mar 09 14:30 Sampled all site Storm Drains for Annual Inspection. No gamma. 28 Mar 09 12:00 Tritium samples prepared for weekly run on Liq Scin. 30 Mar 09 18:00 Spvr and Staff aware of first reported elevated H-3 in A-1, A-2, A-4, (and A-6?). 31 Mar 09 08:00 Investigating false positive, chemiluminescence, pH, & lab issues, etc. 31 Mar 09 14:00 samples collected for shipment offsite, for H-3 confirmation, and other beta. 01 Apr 09 08:30 multiple re-samples, prepared and counted immediately, verified 1st results. 02 Apr 09 09:00 more re-samples, taken after some precipitation. Prepared and counted ASAP. Last set of samples slightly higher in H-3. Data considered valid. 03 Apr 09 10:00 CR 1609 entered 1530 hr 03 Apr 09 21 :00 D Mayer briefing/telecon NRC Regional personnel (CR-IP3-09-1609) 04 Apr 09 01 :30 Email Message Mayer to McCafrey, action items for weekend investigative activities CONCLUSIONS: The most likely cause of the elevated H-3 in the effected storm drains was determined to be an accumulation of liquid H-3 condensation from the various airborne vents (washout), and the relative dry period before water was accumulated in effected drains (week of March 18-25, 2009.) In an effort to ensure all possibilities were evaluated, the investigation also covered many other potential sources, including leaks or spills. In addition to storm water, several groundwater samples were collected at various depths throughout the area, and sent off for analyses. It conjunction with the bulk of our surveys in the area, it is expected that this information will help us verify the nature of the H-3 washout effect. Groundwater results are due back in late July, 2009. The predominance of OE covering the washout phenomenon, the absence of any other indication of an introduction of H-3 to the drains, and the speed at which it dilutes to less than detectable levels - led us to believe that we simply identified a process that has been ongoing, but has no effluent contribution above what is already being conservatively quantified. Washout is not subtracted from airborne dose calculations and any liquid contribution is again included and reported in the annual assessment. Slightly elevated storm drain H-3 at key periods of dry weather and subsequent heavy rains, appears more connected with the ability to effectively monitor for pipe/tank integrity issues per NEI07-07. As such, some corrective actions will follow to ensure appropriate response when this phenomenon is experienced. IPEC00194519

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 4 OF 36 ATTACHMENT 9.1 INITIAL INVESTIGATION Sheet 3 of 4 ACTIONS/RESUL TS:

1. ACTION:

Engineering evaluation is needed on lines 155, 181,252, and 161, to and from the RWST in addition to the aux steam and condensate return lines used for tank heating. The RWST lines are suction to SI/RHR, suction to VC spray, RWST overflow, and the 3" recirculation return line (also part of the purification loop). Are lines all Stainless steel? What is exact elevation? Do any of these lines have tell tale drains from an outer containment pipe? Do they come in contact with the actual storm drain pipe? Applicable drawings: Line No. Dwg No. Type of Drawing 1 Line 155 9321-F-26313, 26323 and 26553 Piping Arrangement Layout 2 Line 181 9321-F-26313, 26323 and 26553 Piping Arrangement Layout

3. Line 252 9321-F-26313, 26323 and 26553 Piping Arrangement Layout
4. Line 161 9321-F-26313, 26323 and 26553 Piping Arrangement Layout EXPECTED RESULTS:

Lines are not degraded or leaking. ACTUAL RESULTS: 16"- Line 155 Suction to SIIRHR 304 SS, 0.375" wall 12" - Line 181 Suction to VC spray 304 SS, 0.375" wall 6" - Line 252 RWST overflow 304 SS, sch 40S (0.280" wall} 3" - Line 161 3" return line and part of purification loop 304 SS, sch 40S (0.0.216" wall} Four lines are Stainless Steel, Pipe Class 151 R. Design Conditions: Pressure: 150 psig 210 psig 240 psig Max. Temp: 500 of 300 of 200 of These 4 lines are approx. 6 feet below grade for their entire length They run in parallel in a southerly direction approx. 6 feet below grade @ EI. 48 ft. Line 252 continues in southerly direction to the Waste Holdup Tank Pit. The other 3 lines turn west at the northwest corner of the Waste Holdup Tank Pit, continuing to the Fuel Storage Building at EI. 45 ft. There is other underground piping that runs in parallel with the RWST lines identified above that are associated with RWST tank heating: 6" Line 561 Steam line Class P-2: A-53 CS, 0.280" wall 2" Line 278 Condensate Return Class 151 R: 304 SS, 0.154" wall These 2 lines are routed side by side, encased in a 16" pipe conduit (dwg 9321-F-26323, Detail B). IPEC00194520

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 5 OF 36

2. ACTION:

Determine the depth of the "A" storm lines. Compare RWST pipe runs to these lines. What is depth of bottom seam in WHUT room, where overflow may have been most involved? EXPECTED RESULTS: Lines do not touch or involve galvanic corrosion. Downward pitch in A system from A-1/A-2. Review may Identify any channels or unique water transporting methods (old pipes?) that may move water into the A system drains, other than from surface runoff. ACTUAL RESULTS: Drawing 9321-F-26323, Section A-A shows a 12" storm sewer (A2 to A4) invert @ EI. 49.82 ft. at the point that it crosses over the 3 lines. Section X-X on the drawing shows that 16" Line 155 has 4 in. thick mineral wool and 2" foam-glass covers over the 16" Line 155. This line shown being above the RWST lines, but it would be immediately above the 16" covered line. The floor of the WHUT Pit structure is @ EI. 33 ft. (Ref 9321-F-26563, Section C-C)

3. ACTION:

Evaluate the pipe integrity test, to determine if frequency or specific acceptance criteria can help us pin down a potential source of leakage. EXPECTED RESULTS: Leakage test does not indicate leakage to the environment. ACTUAL RESULTS: 3PT-R178, "Alternate SI Low Head to High Head Recirc Piping Leak Test," was performed SAT on 3/22/09. The test is performed every refuel outage. The test verifies the integrity of the alternate path from the RHR pump discharge to the suction of 32 SI Pump via the RWST discharge piping and SI-898. The buried portion of 16 inch Line 155 is in the test boundary. In addition to testing SI-846 and SI-MOV-882, the test verifies the seat leakage of SI-846 is less than7 gph OR that the combined RWST leakage through SI-846, SI-842 and SI-843 is less than 9 gph. The 3/22/09 SI-846 leakage rate was 6.02 gph. Test also measures 3PT-C01 leakage (Primary Coolant Sources Outside Containment - Total Leakage Rate Monitoring Tabulation) Summary of last performances of 3-PT-R178: SI-847 Leakage (A/C) 3-PT-C01 Leakage 3/22/09 6.02 gph (::; 7.0 gph) 0.1657234 gph (::; 1.9 gph) 3/15/07 4.21 gph (::; 7.0 gph) 0.1657234 gph (::; 1.9 gph) 3/24/05 2.06 gph (::; 7.0 gph) IPEC00194521

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 6 OF 36

4. ACTION:

Evaluate the RWST overflow line, filled before every outage, and the water ported over to the CVCS sump. With ground water contour mapping, consult with hydrologist with regard to scenarios involving a leak from this line. Include in investigation potential for splashing of RWST water during overflow conditions where overflow line discharge coming out of tank is funneled to underground piping. EXPECTED RESULTS: No indication of leakage from recirc or overflow lines. ACTUAL RESULTS: Overflow line is not under pressure, and is filled approximately a month before each outage. Leaks from this line can be detected from local groundwater sampling. Hydrological studies are not yet complete, but so far, there is no evidence of an underground leak in the area. Sample results are pending, see Action #11.

5. ACTION:

Interview Ops regarding all work/testing/lineup modifications in Feb/Mar that may have involved water running down the hill into A system storm drains. Perform a walkdown of the outside area for evidence of surface runoff or leaks EXPECTED RESULTS: No credible source of groundwater contamination. ACTUAL RESULTS: On 4/2,approx 20:00, various Ops personnel and station oversight individuals identified that contamination was not likely from these events. On 4/3, a walkdown was completed with no evidence of undue runoff, standing water, or leakage from plant systems. In addition, the secondary side of the BUSFCS was tested to confirm H-3 activity levels; levels were normal.

6. ACTION:

Obtain Monitoring Well samples in the effected area, including transducer readings for any changing conditions over last several months. EXPECTED RESULTS: H-3 activity at various depths consistent with historical levels. If not, then evaluate the possible communication between storm drains and ground water. ACTUAL RESULTS: Monitoring Well samples were taken at MW 38, 39, 41, 43, 44, 45, U3-T1, and U3-T2. Results are expected before July 2009, and will be documented under Action Item #11. IPEC00194522

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 7 OF 36

7. ACTION:

Continue sampling storm drains for gamma and H-3. Consider pumping out existing water in A-2 and looking at how rapidly it returns, in conjunction with precipitation. Compare daily rainfall versus H-3 activity in key drains. Compare ongoing H-3 activity with rainfall, dilution, or potential recharge. Send storm water out for offsite analyses to verify H-3, and also for other beta-emitters. EXPECTED RESULTS: H-3 activity should subside and approach baseline if this was a one-time event. May reside longer if there is an ongoing leak. Evidence of gamma may help pinpoint source. ACTUAL RESULTS: No gamma has been detected, in the water in any drain. Typical spring rainfall has occurred since Mar 30, usually some every day. WinCDMS shows trends for H-3 analyses results and notes precip. This chart summarizes H-3 data in A-series drains, in uCilml ( MDA for this analysis is approx 7E-7 uCilml): Date A-1 A-2 A-2A A-3 A-4 A-6 E-1 1/19/2006 <mda <mda na na 1.19E-06 6.86E-07 na 10/19/2006 6.71 E-07 8.15E-07 na <mda 1.49E-06 7.00E-07 na 3/10/2007 Dry dry na na <mda na na 7/9/2007 na na na na <mda na na 8/20/2007 na na na na <mda na na 11/16/2007 na na na na <mda na na 2/1512008 na na na na 2.46E-06 na na 2/27/2008 na na na na <mda na na 4/712008 7.03E-07 7.03E-07 na 3.86E-06 7.81 E-07 na <mda 5/12/2008 na na na na 1.06E-06 na na 8/12/2008 na na na na <mda na na 11/10/2008 na na na na <mda na na 2/11/2009 na na na na 1.74E-06 na na 2/19/2009 na na na na <mda na na 3/25/2009 4.33E-06 2.16E-05 na <mda 1.90E-06 Dry <mda 3/30/2009 5.36E-06 9.08E-05 na na na 1.16E-05 na 4/112009 5.89E-06 9.42E-05 na na 1.76E-05 3.71 E-06 na 4/2/2009 8.03E-06 1.89E-05 ~(for confirmation)~ 7.96E-06 ~ Analyzed at GEL 4/4/2009 8.96E-07 1.97E-06 7.09E-07 na 1.14E-06 1.14E-06 4/12/2009 6.24E-07 7.94E-07 na na 6.73E-07 6.24E-07 na IPEC00194523

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 8 OF 36 Water was pumped out of A-1 and A-2 on 4/5/9 to a drum. Water did NOT fill back up. and there was no evidence of new ingress. This information points to a discreet event (one-time H-3 introduction to A-2 drain, in mid March, 2009). Storm Drain water was sent offsite to GEL on April 2. GEL's results confirm our analyses results for H-3, and did NOT identify other gamma or beta emitting isotopes. Summarizing GEL's results, in pCilL: / --------------------- M DA -------------------\ Date ID H-3 Cs-137 Sr-90 Ni-63 4/2/2009 Storm Drain A-1 8030 +/- 665 1.10 +/- 1.92 0.272 +/- 0.434 -7.56 +/- 11.1 4/2/2009 Storm Drain A-2 18900 +/- 964 0.425 +/- 1.59 0.579 +/- 0.384 -6.38 +/- 11.1 4/2/2009 Storm Drain A-4 7960 +/- 662 -0.477 +/- 1.87 0.224 +/- 0.528 -9.58 +/- 11.1 Groundwater samples were also collected and sent to GEL. These results are expected in July or August, 2009, and will be captured in a separate CA, per Action #11. MET data over the interval shows a long dry period, followed by significant precipitation at the end of March. The lack of precipitation is a known contributor to what appears to be a concentrating mechanism with regard to surface concentrations from washout and runoff. o o o 3/31/2009 o Graphical representations of H-3 in A series storm drains are shown on the following pages. Drain A-4 indicates that there may have been a historical presence of washout in this system, perhaps connected to atmospheric conditions in the FSB. While we may consider altering sample collection periodicity to better observe this phenomenon in the future, the collective data continues to indicate that (probably due to dilution down E series), there is no EFFLUENT concern as all samples into the canal are <mda. IPEC00194524

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 9 OF 36 U3 Storm Drain A series, 2006-2009 1.00E-04 t - - - - - - - - - - - - - I 

                                             --A-4
                                             -     A-6

_ E-1 1.00E-05 t - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - f . . - - - - - j 1.00E-06 t--------',.......,.......:-::-:=====~_--------------I_l_-_=":.--------___J'+- 1.00E-07 +-------II~-------.;;::._---...::I ...---."..__ -~~-_ ...___ -....;III_--."..--....'"""IIIt----j 1.00E-08 + - - - - - - - - r - - - - - - - r - - - - - - - - - - - , - - - - - - - - - , - - - - - - - . , - - - - - - - - - r - - - - - - - - j 9/5/2005 3/24/2006 10/10/2006 412812007 11/14/2007 611/2008 12118/2008 716/2009 U3 Storm Drain A series, 2009 _A-1 100E-04 + - - - - I - A - 2 r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -_ _ ------! _ _ A-4 

                    -     A-6
                    -lIf- E-1 100E-05 + - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - . , " ' - - - -----JI\-I4-!I - - - - - - - j 100E-06 t==::::::::=====-__        ---=====::::::::~~~~I~nv~e~st~ig~at~io~n~L!eV~e~I--~

100E-07+---------------------------------~__----~~~------------------------------~--*_*__*------~I 100E-08 +----r---t----t---i-----j---t---t----t---+----r---t----t---i-----j---t---t----t---+---___1__' Jan07 Jan12 Jan17 Jan22 Jan27 Feb01 Feb06 Feb11 Feb16 Feb21 Feb26 Mar03 Mar08 Mar13 Mar18 Mar23 Mar28 Apr02 Apr07 Apr12 In all cases, H-3 in the "E" series was less than minimum detectable levels. IPEC00194525

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 10 OF 36 Two views of the FSB roof drain pipe, inside the FSB, 53' near manhole A-2 Manhole A-2 from outside, looking at Annex and FSB on right. This is a roof drain from the annex bldg, going into the culvert, and eventually A-2. IPEC00194526

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 11 OF 36

8. ACTION:

Determine if there is a need for 80-10 eval update for potential site effluent. EXPECTED RESULTS: Insufficient H-3 reaches downstream drains to impact site effluents or demand updated 80-10 eval. ACTUAL RESULTS: No H-3 has been detected reaching system "E" downstream of system "A". Existing 80-10 guidance for storm drains continuously evaluates potential effluent impact. To date there is no measurable effluent. Samples are periodically scheduled in Chemistry procedures and task matrices per the ongoing 80-10 and Effluent programs. Modified sample periodicity, specifically for periods of high suspected washout or runoff may be a future corrective action, as a product of this investigation, but this action would be for NEI and ANI concerns (pipe/tank integrity) and not necessarily for effluent or 80-10 purposes.

9. ACTION:

Observe the area near the U3 FSB truck bay LWP sump area for standing water. Document any gamma constituents in the water if found, or gamma in the actual drains (A-1 and A-2). EXPECTED RESULTS: No standing water in the truck bay, no contamination outside the doorway. ACTUAL RESULTS: No water was evident inside or outside the doorway. After some rain, there were some pockets of standing water just south of the A-1 and A-2, however, all water samples were <MDA for gamma emitting isotopes. (No storm drain on site indicated positive gamma emitting isotopes in the water).

10. ACTION:

Obtain a matrix of dirt sample information on 95' hill, around the RWST, to determine if a RWST leak or runoff issue could have contributed to H-3 activity in Storm Drain A series. EXPECTED RESULTS: Some activity is expected in the dirt around the RWST (per 10CFR50.75g). However, Co-58 is not expected. Continued and elevated presence of Co-58 may indicate a spill or leak. See map and dwgs. ACTUAL RESULTS: Most dirt samples were <MDA for gamma, or had some trace Cs-137 consistent with our 75g program. One area (sample 6) showed trace Co-58. This area required more detailed investigation. Additional samples of the very specific area were taken, and samples of soil were collected at 6" and 1 foot below the surface. The Co-58 was very small, and mostly on the surface. None was detected at a depth of 12". This contamination was traced back to work performed on the valve directly above the area, a week before. The Co-58 is indicative of approximately 82 mls of water and could not possibly suggest the volume necessary to contribute to the H-3 in the A system storm drains. Therefore, a leak from the RWST atop the hill, down into the drains is NOT considered a likely source of the H-3 found in the storm drains in late March. See the data and maps on the following pages: IPEC00194527

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT r-----------------~r_------------~------------, MANUAL INFORMATIONAL USE PAGE 12 OF 36 RWST Soil Samples Collected On 04/06/09 Two additional samples were taken around point RWST-6, called 6A and 68. Later, 4 more samples were taken, 6C and 6D at 6" into the soil, and 6E and 6F at 12" depth. IPEC00194528

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 13 OF 36 Summary of the RWST soil samples: RWST-1 1.90E-6 Cs-137 only RWST-2 2.62E-6 Cs-137 only RWST-3 1.33E-S Cs-137 only RWST-4 2.77E-6 Cs-137 only RWST-S < mda Cs-137 MDA is approx SE-6 uCi/gm RWST-6 1.99E-S Co-58, verified. More sa collected. Indication of RWST fluid. 8e-7, Cr-S1, Co-60, as well as Cs-137, RWST-6A 3.73E-6 in very small amounts. (This sample was in large bottle). RWST-68 7.7SE-6 Same host of RWST nuclides as 6A. RWST-6C S.4SE-7 Cs-137 only, 6" below grade. RWST-6D S.10E-7 25% Cs-137, 75% Co-58, nothing else, 6" below grade. RWST-6E S.90E-8 Cs-137 only, high error, 12" below grade. RWST-6F 1.68E-7 Cs-137 only, 12" below grade. RWST-7 < mda RWST-8 < mda RWST-9 2.76E-6 Cs-137 only RWST-10 4.S8E-6 RWST-11 < mda RWST-12 < mda RWST-13 < mda Water in the RWST during the time of this sampling was 2.S9E-3 uCilml (Fission & Activation Products - Co-58, Co-60, Cr-S1 , Nb-9S, Cs-137, etc) and approximately 0.0853 uCilml of Tritium. Local, near-surface activity of E-S uCilgm in only one spot, represents only a few drops of this water. A large spill from the RWST adding the H-3 we saw in the "A" series drains is not credible: A 12"x"12"x6" cube, with average concentration of 7 .8E-6 uCilgm (taken from all samples in the 3 area), times the density of dirt (120Ibs/ft ), is about .212 uCi. At an RWST concentration of 2.S9E-3 uCilml, we need only 82 mls to cause this kind of contamination. At 8.S3E-2 uCilml, 82 mls of RWST water would be approximately 7 uCi of H-3. With a total of approximately 100 stagnant gallons of water at an average SE-S uCilml of H-3 in the "A" series drains, we would need approximately 37 gallons of RWST water, or about 1700 times more volume than what the dirt samples would suggest. IPEC00194529

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT r------------------r--------------~----------~ MANUAL INFORMATIONAL USE PAGE 14 OF 36

11. ACTION:

Document the offsite analytical results of Groundwater and Storm water near the effected A series drains, from April 4, 2009 time frame. Evaluate these results to determine if there is evidence of an unexplained underground contribution of H-3 or other contam inant. EXPECTED RESULTS: If data suggests an underground tank or pipe integrity concern, contact Engineering and initiate a new CR. If data is consistent with existing levels of GW activity, then document this event to surface contamination potentially connected with refueling outages and implement corrective actions. ACTUAL RESULTS: in pC ilL SarnplePoiht 1-1-3 Sf-gO 0s-137 Notes MW-38 MW-39 MW-41 MW-43 MW-44 MW-45 MW-46 U3-T1 U3-T2 SD A-1 SD A-2 SD A-4 INITIAL DATA COLLECTED BY: NAME TELEPHONE Steve Sandike 914-736-8455 Pat Donahue 914-736-8405 Dara Gray 914-736-8414 Bob Lee 914-734-6612 Pat Conroy 914-734-6668 IPEC00194530

NUCLEAR QUALITY RELATED EN-MA-125 REV. 4 MANAGEMENT MANUAL INFORMATIONAL USE PAGE 15 OF 36 ATTACHMENT 9.2 TROUBLESHOOTING CONTROL FORM INSTRUCTIONS Sheet 1 of 2 I. Determine Troubleshooting Risk Level Attribute Description

1. Initiating Enter number of document Document Number:

describing problem (such as CR or WR/WO). CR-IP3-2009-01609

2. Affected List components that will be No adverse consequences to any Components: affected during troubleshooting components are anticipated as a result of activities, NA if listed in the the planned troubleshooting. Components WRIWO. under review include RWST piping, BUSFCS, monitor tanks, U3 SFP, storm drains, monitoring wells, bldg structures and pipe penetrations.
3. Problem Fully describe the problem using
  • Unexpected levels of H-3 in Storm Drain

Description:

any additional information obtained System A. from preliminary investigation. (KT or Problem Analysis may be used).

4. Special Plant or Describe plant or equipment
  • Identified during 3R15, but may not be Equipment required for troubleshooting. related to outage activities.

Conditions

5. Potential From the Initial Investigation list the
  • CVCS overflow event (Feb 4)

Cause(s): potential cause(s).

  • Pipe, tank or SFP integrity issues in area
  • Undocumented spill or direct disposition of tritiated water to storm drain.
6. Boundaries Identify the electrical, mechanical,
  • Between RWST hill, Monitor Tank pad, or system boundaries such as EHC RAMS, PAB, FSB, in blacktop area Control Cabinets and include any around storm drains A-1 thru A-6.

equipment interface risks.

7. Expected Plant Identify any expected alarms,
  • No expected response from plant, unless Equipment instrument indications, automatic special tests are suggested (to observe Response: actions, etc. RWST overflow line, for example).
8. Worst Potential Describe the plant response if the
  • Ongoing H-3 leak from plant system to Consequence of affected components or systems environment.

Activity: were to be either inadvertently actuated or incapacitated in the

  • Rad effluent issue.

course of troubleshooting.

  • Loss of public trust/confidence from pipe, tank, or SFP integrity issues.

IPEC00194531

e~Entergy NUCLEAR MANAGEMENT QUALITY RELATED EN-MA-125 I REV. 4 MANUAL INFORMATIONAL USE PAGE 9 OF 36 ATTACHMENT 9.3 TROUBLESHOOTING CONTROL FORM PART I - DETERMINE TROUBLESHOOTING RISK LEVEL

1. Initiating Document No. CR-IP3-2009-01609
2. Affected Components: Storm Drain System A, Unit 3
3. Problem

Description:

Unexpected high H-3 in storm drains.

4. Special Plant/Equipment Conditions: _ _-=M=a:..Ly-=b=e:.....:,r..=e=la;.:.:te:.;:d::..t::.;::o;....:3::..:.R..:..1:...;::5:...-
5. Potential Cause(s): Possible pipe/tank integrity problem. spill, or GW issue.
6. Boundaries:_----::.R...:.:o=-=a=d::..,:.w=-=a;:..ty....;.a=r...:;.o=u:..:.nd=-=Sc.::..:to=...;.r-'-"m.:..=D.:..:ra=in:...:...:...A.:....;s::...:e::.,:.r.:.;:ie;.,:s...::d::..:,.r=.ai:..:.,:n=s_ _
7. Expected Plant Equipment Response: _ _"""n/;.,:a'---_ _ _ _ _ __
8. Worst Potential Consequence of Activity: indication of pipe/tank integrity challenge with RWST or SFP
9. Risk Level: '3 lit-at. . '

Approval: 1- tf~P1 Date Troubleshooting Risk Level is defined / as not requiring a Detailed Troubleshooting Ian: NR Cj

~:c :e:~f:2::::':IU~~M ~~~~h~
    ~ - r \:~                                                      \ Wo..~k Group                                               ~ame                                             \:                  Anerna~e
                      ~'\Ml~t5 ~.uJ\J~                                                                                                               Q                kb ~                                     .r   ,

Work Group Name Alternate Work Group me Alternate IPEC00194532

e Entergy -::::=- NUCLEAR MANAGEMENT QUALITY RELATED EN-MA-125 I REV. 4 MANUAL INFORMATIONAL USE PAGE 16 OF 36 ATTACHMENT 9.3 TROUBLESHOOTING CONTROL FORM PART 11- DETAILED TROUBLESHOOTING PLAN NRC) Name (Print) Date Work Group Date

13. Approval:_-:---::--:_.....f'!'-I-{A ______

Craft Superintendent Date (required for Level 1 and 2 activities only) Approval: _ ___ ~_=.V_A-OPS MGR or designee Date (required for Level 1 and 2 activities only) APproval:-=-:-:-:---:-/"L~~:.......l::~~+-___--:-____ ~1.J.~01 

                                                                .!..'l:L/W_.

Shift Manager / C~ Date IPEC00194533}}

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