ML13218A402
| ML13218A402 | |
| Person / Time | |
|---|---|
| Site: | Palisades  (DPR-020) |
| Issue date: | 08/06/2013 |
| From: | Billy Dickson Division of Reactor Safety III |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| Download: ML13218A402 (19) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 August 6, 2013 Mr. Anthony Vitale Vice-President, Operations Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
RESULTS OF INDEPENDENT SAMPLES COLLECTED BY THE NRC AT PALISADES NUCLEAR PLANT STORM DRAIN OUTFALL
Dear Mr. Vitale:
On May 4, 2013, your staff recognized that the Safety Injection Refueling Water Tank was leaking onto one of the facilitys roofs. Further investigation showed that some of the leakage onto a roof washed into the storm drain system, which terminated via a pipe outlet onto the beach along Lake Michigan and inside of Entergy property. This was not a normal discharge path. As part of its mission to protect the public, workers, and the environment, the U.S. Nuclear Regulatory Commission (NRC) conducts routine and special inspections.
Occasionally, during the NRC inspection process, circumstances warrant that independent measurements be made by the NRC, including the taking of samples and the analysis of various media to confirm the quality of a licensees analytical performance, or to independently determine the presence of radioactivity in the environment. The NRC decided to collect independent sand samples in the vicinity of the pipe outlet during the time you were collecting samples and at the same locations you obtained samples.
This letter provides the results of analysis of the four sand samples independently collected by the NRC on May 30, 2013. The NRC had instructed a private third party laboratory to analyze the samples for gamma emitting radionuclides and the beta emitting radionuclides of tritium (H-3), nickel (Ni-63) iron, (Fe-55), and strontium (Sr-89/Sr-90). Three of the samples were taken on the beach along the storm drain flow path on licensee property. One sample was taken several yards south of the others, away from the storm drain flow path (control sample). It should be noted that these samples were obtained after rain events. Therefore, the results can only quantify the amount of activity present in the sand at the time of sampling.
The analysis results do not represent the radiological content of the storm drain following the recent leak of the Safety Injection Refueling Water Tank on May 4, 2013. Your staff performed an assessment to address the contents of the storm drain.
A. Vitale The sample analysis results indicated the presence and quantities of some radionuclides associated with naturally occurring sources of radiation. In addition, a small amount of tritium was detected in the samples that were likely a result of the recent leak from the Safety Injection Refueling Water Tank on May 4, 2013. These results and amounts:
were expected given the dose calculation/evaluations performed by the Palisades staff and rainfall that occurred before the samples were collected; were below the EPAs safe drinking water standard; did not exceed any NRC limit or design objective; were too small to be expected to have any health impact to the individuals located at the pipe outlet and other members of the licensees workforce or the public.
A summary of NRCs evaluation of the laboratory analysis of the samples is included as. The independent laboratory results of the samples are included as Enclosure 2.
We are providing the laboratory analysis results and the NRCs evaluation of the results so that you may determine the corrective actions necessary.
When licensed radioactive material is inadvertently released into the environment, the NRCs regulations require that licensees do surveys of the affected area that are reasonable and necessary to assess the hazard. The presence of licensed radioactive material should be evaluated to determine whether additional corrective actions, including remediation should be performed by your staff. Please keep the NRC Resident Inspectors and the NRC Regional Health Physics inspector, assigned to your site, informed of the results of this evaluation. The NRC will assess the results of your evaluation of this information during a baseline inspection of this program later this year.
If you have any questions regarding this correspondence, please contact me at (630) 829-9827.
Sincerely,
/RA/
Billy C. Dickson, Chief Health Physics and Incident Response Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20
Enclosures:
- 1. NRC Analysis of Independent Laboratory Results
- 2. American Radiation Services, LLC. Laboratory Results cc w/encl: Distribution via ListServ'
NRC Analysis of Independent Laboratory Results 1
Radionuclides Not Attributed to Activities at Palisades All of the samples contained naturally occurring or background radioactive materials commonly found in soils worldwide. This was expected, and the radioactivity content totaled about 10,000 pico-Curie per kilogram (pCi/kg).
Some radionuclides that could be attributable to operation of Palisades were also preliminarily identified in the raw analysis results of some samples. However, the NRCs independent evaluation of the analysis results concluded that these radionuclides were either not present (Ni-63 and Fe-55) or were not attributable to this event or plant operations. A summary of the NRCs evaluation for each of these radionuclides is detailed below.
Ni-63 No positive values were identified by the NRC. Although the independent laboratorys analysis indicated the highest reported result was 300 pCi/kg, the NRC determined the result was not valid. This decision was based on several factors: (1) the QA/QC control sample results showed a significant positive bias that indicated the analysis was at the limit of the acceptance range, (2) the QA/QC blank result showed a significant positive bias that was similar in magnitude to the sample results, and (3) the knowledge of the source term indicated Ni-63 would not be expected to occur in the absence of other radionuclides. In summary, the analysis results did not have sufficient strength to conclude Ni-63 was present, and Ni-63 result was classified as a false-positive result.
Fe-55 No positive values were identified by the NRC. Although the independent laboratorys analysis indicated the activity for one sample was reported greater than the minimum detectable concentration, the analysis did not meet the quality control criteria. The third party laboratory prepared another sample from the same material provided by the NRC. The second analysis also did not meet quality control criteria. The cause of the laboratorys failure to meet quality control criteria is unknown, but might be attributed to the sample matrix (sand) which was much different than the normal liquid matrix processed by the facility.
Sr-90 The NRCs evaluation indicated no Sr-90 was attributable to this event or to plant operations.
The independent laboratory values reported (125 pCi/kg and 148 pCi/kg) were similar to the levels to be expected as background radiation. The amount of this specific radionuclide may be found in the environment as a result of historic above ground nuclear testing in the 1950s through 1970s. The Environmental Surveillance, Education, and Research Program at the Idaho National Laboratory Site, indicated that the average strontium-90 concentrations in surface soil are about 100 pCi/kg.
Cs-137 The NRCs evaluation did not indicate any Cs-137 that were concentrations in the samples attributable to this event or to plant operations. The values reported by the independent laboratory (7 to 13 pCi/kg) were similar to the levels to be expected as background radiation.
The amount of this specific radionuclide may be found in the environment as a result of historic
NRC Analysis of Independent Laboratory Results 2
above ground nuclear testing in the 1950s through 1970s. The Environmental Surveillance, Education, and Research Program at the Idaho National Laboratory Site, indicated that the concentration of cesium-137 in surface soil from fallout ranges from about 100 to 1000 pCi/kg, averaging less than 400 pCi/kg.
Radionuclide Attributed to Activities at Palisades or Likely a Result of the Recent Leak of the Safety Injection Refueling Water Tank on May 4, 2013 Tritium (H-3)
Three of the four samples were collected within the storm drain flow path. The samples were collected to survey for radioactive materials in effluents potentially released to unrestricted and controlled areas from the recent leak of the Safety Injection Refueling Water Tank. The fourth sample was taken several yards south of the storm drain (outside of the flow path).
The inspectors collected sand from the beach as a surrogate for a direct water sample from the storm drain pipe which was not possible due to heavy rains that occurred before sample collection. Of the three samples taken within the storm drain flow path, only the sample closest to the storm drain pipe outlet showed positive tritium result. The tritium concentration was measured 1160 pico-Curies (pCi) per kilogram (kg) of sand. Based on the measured tritium concentration of 1160 pCi H-3 per kg of sand, the NRC calculated the tritium concentration in the moisture (i.e., the liquid fraction of the sand) was about 4000 to 6000 pCi/liter of water.
These results and amounts:
were expected given the dose calculation/evaluations performed by the Palisades staff and rainfall that occurred before the samples were collected; were below the EPAs safe drinking water standard; did not exceed any NRC limit or design objective; were too small to be expected to have any health impact to the individuals located at the pipe outlet and other members of the licensees workforce or the public.
The remaining fourth sample, taken several yards south of the storm drain (outside of the flow path), showed detectable tritium at 358 pCi/kg, which was slightly above background but less than the Lower Limit of Detection required by the NRC for H-3 in water (2000 pCi/l).
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A. Vitale The sample analysis results indicated the presence and quantities of some radionuclides associated with naturally occurring sources of radiation. In addition, a small amount of tritium was detected in the samples, that was likely a result of the recent leak from the Safety Injection Refueling Water Tank on May 4, 2013. These results and amounts:
were expected given the dose calculation/evaluations performed by the Palisades staff and rainfall that occurred before the samples were collected; were low; compared to the EPAs safe drinking water standard; did not exceed any NRC limit or design objective; were too small to be expected to have any health impact to the individuals located at the pipe outlet and other members of the licensees workforce or the public.
A summary of NRCs evaluation of the laboratory analysis of the samples is included as Enclosure 1.
The independent laboratory results of the samples are included as Enclosure 2. We are providing the laboratory analysis results and the NRCs evaluation of the results so that you may determine the corrective actions necessary.
When licensed radioactive material is inadvertently released into the environment, the NRCs regulations require that licensees do surveys of the affected area that are reasonable and necessary to assess the hazard. The presence of licensed radioactive material should be evaluated to determine whether additional corrective actions, including remediation should be performed by your staff. Please keep the NRC Resident Inspectors and the NRC Regional Health Physics inspector, assigned to your site, informed of the results of this evaluation. The NRC will assess the results of your evaluation of this information during a baseline inspection of this program later this year.
If you have any questions regarding this correspondence, please contact me at (630) 829-9827.
Sincerely,
/RA/
Billy C. Dickson, Chief Health Physics and Incident Response Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20
Enclosures:
- 1. NRC Analysis of Independent Laboratory Results
- 2. American Radiation Services, LLC. Laboratory Results cc w/encl: Distribution via ListServ' DISTRIBUTION w/encl:
See next page DOCUMENT NAME: Ltr 080613 Palisades Results of Independent Samples.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII NAME JCassidy:cs JGiessner BDickson DATE 08/06/13 08/06/13 08/06/13 OFFICIAL RECORD COPY
Letter to Mr. Anthony Vitale from Mr. Billy C. Dickson dated August 6, 2013.
SUBJECT:
RESULTS OF INDEPENDENT SAMPLES COLLECTED BY THE NRC AT PALISADES NUCLEAR PLANT STORM DRAIN OUTFALL DISTRIBUTION w/encl:
Vivian Campbell RidsNrrPMPalisades Resource RidsNrrDorlLpl3-1 Resource RidsNrrDirsIrib Resource Cynthia Pederson Anne Boland Steven Orth Allan Barker Christine Lipa Carole Ariano Linda Linn DRPIII DRSIII Tammy Tomczak ROPassessment.Resource@nrc.gov