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{{Adams
#REDIRECT [[IR 05000003/2009008]]
| number = ML12089A605
| issue date = 10/19/2009
| title = Entergy Prefiled Hearing Exhibit ENT000343 - Indian Point Nuclear Generating Units 1, 2 & 3 - NRC Inspection Reports Nos. 05000003/2009008; 05000247/2009008 and 05000286/2009008
| author name = Roberts D J
| author affiliation = NRC/RGN-I/DRS
| addressee name = Pollock J
| addressee affiliation = Entergy Nuclear Operations, Inc, NRC/ASLBP
| docket = 05000247, 05000286
| license number = DPR-026, DPR-064
| contact person = SECY RAS
| case reference number = RAS 22132, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR
| document report number = IR-09-008
| package number = ML12089A599
| document type = Legal-Pre-Filed Exhibits
| page count = 17
}}
See also: [[followed by::IR 05000003/2009008]]
 
=Text=
{{#Wiki_filter:ENT000343
Submitted:  March 29, 2012
UNITED STATES NUCLEAR REGULATORY
COMMISSION
REGION I Mr. Joseph Pollock Site Vice President
Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249
4 7 5 ALLENDALE
ROAD KING OF PR USSIA, PA 19406-1415
October 19, 2009 SUBJECT: INDIAN POINT NUCLEAR GENERATING
UNITS 1 ,2 & 3 -NRC INSPECTION
REPORT NOS. 05000003/2009008
; 05000247/2009008
; AND 05000286/2009008
Dear Mr. Pollock: On September
4, 2009, the U.S. Nuclear Regulatory
Commission (NRC) completed
an inspection
at Indian Point Nuclear Generating
Units 1, 2, & 3. The enclosed report documents
the inspection
results, which were discussed
on August 19 and September
4 , 2009 , with Mr. Don Mayer and other members of your staff. The purpose of this inspection
was to assess the establishment, implementation, and maintenance
of your Long-Term
G r oundwater
Monitoring
Program; review the circumstances
surrounding
a prev i ously identified
occurrence
involving
the detection
of tritated water in a Unit 3 storm drain system; review the performance
of the site's Radiation
Monitoring
System; and inspect and assess your performance
r elative to radiological
effluents
monitoring
and control. The inspection
involved an examination
of activ i ties conducted
under Entergy's license as related to safety and compliance
with the Commission's
rules and regulations
and with the conditions
of your license. Within these areas, the inspection
consisted
of a selected examination
of procedures
and representative
records, observations
of activities , interviews
with personnel, and independent
assessment
activities.
Based on the results of this inspection , no findings of significance
were identified. Further, the inspectors
determined
that Entergy's Long-Term
Groundwater
Monitoring
Program for the.lndian Point Energy Center was effectively
implemented
and maintained
in a manner that provided continued
radiological
monitoring
of the groundwater
conditions
to confirm conformance
with NRC regulatory
requirements
relative to the maintenance
of public health and safety, and protection
of the environment.
Since 2005 , as approved by NRC's E x ecutive Director of Operations , Region I c onducted frequent and focused reviews of your groundwater
investigation
activities
and long-term
monitoring
program that exceeded the scope of NRC's normal baseline inspection
program. As a result, we have developed
confidence
i n your commitment
and ability to continue effective
monitoring
and assessment
of the on-s i te cond i tions to assure the maintenance
of 
J. Pollock 2 public health and safety, protection
of the environment, and conformance
with NRC regulatory
requirements.
Our inspectors
confirmed
that the objectives
specified
in our deviation
memorandum
dated December 16,2008 (ML083590057)
have been satisfied.
However, we will continue to monitor your performance
in this area , and will re-assess
the need for continued
heightened
inspection
oversight
during our end-of-cycle
review of your CY 2009 perfonmance.
In accordance
with 10 CFR2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure
will be available
electronically
for public inspection
in the NRC Public Document Room or from the Publicly Available
Records (PARS) component
of the NRC's document system (ADAMS). ADAMS is accessible
from the NRC Web site at
rm/adams.html (the Public Electronic
Reading Room).
Darrell J. Roberts, Director Division of Reactor Safety Docket Nos: 50-003, 50-247, 50-286 License Nos: DPR-5, DPR-26, DPR-64 Enclosure:
Inspection
Report Nos. 05000003/2009008, 05000247/2009008, 05000286/2009008
w/Attachment:
Supplemental
Information
cc w/encj: Distribution
via ListServ 
J. Pollock 2 public health and safety , protection
of the environment, and conformance
with NRC regulatory
requirements. Our inspectors
confirmed
that the objectives
specified
in our deviation
memorandum
dated December 16, 2008 (ML083590057)
have been satisfied.
However, we will continue to monitor your performance
in this area, and will re-assess
the need for continued
heightened
inspection
oversight
during our end-of-cycle
review of your CY 2009 performance.
In accordance
with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure
will be available
electronically
for public inspection
in. the NRC Public Document Room or from the Publicly Available
Records (PARS) component
of the NRC's document system (ADAMS). ADAMS is access i ble from the NRC Web site at hllp: llwww.nrc.
rm/adams.html (the Public Electronic
Reading Room). Sincerely, IRA by Peter R. Wilson forI Darrell J. Roberts, Director Divis i on of Reactor Safety Docket Nos: 50-003 , 50-247 , 50-286 License Nos: DPR-5, DPR-26, DPR-64 Enclosure:
Inspection
Report Nos. 05000003/2009008, 05000247/2009008, 05000286/2009008 w/Allachment:
Supplemental
Information
cc w/encl: Distribution
via ListServ Distribution
w/encl: (via E-mail) S. Collins, RA (R10RAMAIL
RESOURCE)
M. Dapas, DRA (R10RAMAIL
RESOURCE)
D. Lew, DRP (R1 DRPMAIL RESOURCE)
J. Clifford, DRP (R1DRPMAIL
RESOURCE)
L. Trocine , Ri OEDO RIDSNRRPMINDIANPOINTRESOURCE
B. Welling, DRP B. Bickell, DRP S. McCarver , DRP G. Malone , DRP , Senior Resident Inspector
-Indian Point 2 D. Hochmuth , DRP D. Bearde, DRP Region I Docket Room (w/concurrences)
ROPreport
Resource D. Roberts , DRS P. Wilson, DRS J. White, DRS SUNSI Review Complete:
JRW (Reviewer's
Inrtials) OOCUMENT NA M E: G:I ORS I P la nt S upport B ranch 2 INoggl e II P 2009008 Re v1.do c After declaring
thi s document Offi c ial Agency Rec o rd w it will be rel ea s e d to the Pub lic. To receive a copy of this document, Indicate in the box: "e" = C Opy without attachm en t/enclosure "E" = COpy with atta c hment/enclosur
e "N" = No CQP"y OFFICE RIIDRS I RES I RIIDRS I RIIDRP I RIIDRS I NAME JNoggle/JDN TNicholsonltjn
JWhite/jrw'
ehg BWeliinglBW
DRoberts/prw
for (telecon)
for' DATE 10/06/09 10/14/09 10/19/09 10/16/09 10/16/09
* see pnor concurrence
OFFICIAL RECORD COPY 
Docket Nos. License Nos. Report Nos. Licensee: Facility:
Location:
Dates: . Inspectors:
Approved by: U.S. NUCLEAR REGULATORY
COMMISSION
REGION I 50-003 , 50-247 , 50-286 DPR-3, DPR-26, DPR-64 05000003/2009008, 05000247/2009008, and 05000286/2009008
Entergy Nuclear Northeast
Indian Point Nuclear Generating
Station Units 1, 2, & 3 295 Broadway Buchanan, NY 10511-0308
Augusr18 , 2009 -September
4, 2009 J. Noggle, Sr. Health Physicist, CHP, team leader T. Nicholson, Sr. Technical
Advisor for Radionuclide
Transport
J. Williams , U.S. Geological
Survey , Troy , New York John R. White, Chief Plant Support Branch 2 Division of Reactor Safety Enclosure 
SUMMARY OF FINDINGS IR 05000003/2009008, IR 05000247/2009008, IR 05000286/2009008;
08/18/2009
-9/04/2009;
Indian Point Nuclear Generating
Station Units 1, 2 & 3; Other Activities
-associated
with ROP deviation
memorandum, one PI&R sample, and radioactive
effluents
baseline inspection.
No findings of significance
were identified.
The report covers the period from August 18 through September
4, 2009, and discusses
inspection
activities
conducted
by a region-based
inspector, and an inspection
team comprised
of representatives
of Region I, NRC's Office of Research, and the U. S. Geological
Survey. The inspection
provided bases for the NRC to determine
that Entergy had completed
actions necessary
to satisfy the objectives
delineated
in our deviation
memorandum, "Request for Renewal of Deviation
to the Action Matrix
to Provide Heightened
NRC Oversight
of the Onsite Groundwater
Monitoring
at the Indian Point Energy Center," (ML083590057), dated December 16,2008. The NRC's program for overseeing
the safe operation
of commercial
nuclear power reactors is described
in NUREG-1649, "Reactor Oversight
Process," Revision 4, dated December 2006. ii Enclosure 
Report Details 2. RADIATION
SAFETY Cornerstone:
Public Radiation
Safety (PS) 2PS1 Gaseous and Liguid Effluents
(71122.01 -3 samples) a. Inspection
Scope 1) The inspector
reviewed the following
documents
to evaluate the effectiveness
of the licensee's
radioactive
gaseous and liquid effluent control programs relative to the applicable
regulatory
requirements
specified
in the Technical
Specifications
and the Offsite Dose Calculation
Manual (TS/ODCM). * The 2007 and 2008 Radiological
Annual Effluent Release Reports were reviewed including
independently
assessing
selected public dose calculations.
There were no anomalous
results reported in these two reports. The report included discussion
of current groundwater
conditions
and the result of required monitoring
activities;
and instances
involving
out-of-service
radiation
monitors or effluent release flow
rate monitors were listed in the reports and these were evaluated
during this inspection.
* The current ODCM was reviewed, including
technical
justifications
for any changes made since the previous revision.
* Applicable
sections of the Updated Final Safety Analysis Report (UFSAR) were reviewed to verify the adequacy of system descriptions
for gaseous radioactive
waste and station ventilation
systems. * The latest quality assurance
audits of radioactive
effluents
and chemistry
were reviewed, including
Entergy's
program for identifying , controlling
and assessing
potential
contam i nated spills and leakage. * There were no measurable
effluent releases to the environment
based on off-site dose calculations , and there were no reported off-site environmental
sample measurements
i dentifying
plant-related
radioactive
materials
during the 2007 and 2008 report period. 2) The inspector
observed the following plant
equipment
and work activit i es to evaluate the effectiveness
of the licensee's
radioactive
gaseous and liquid effluent control programs.
* Walkdowns
were performed
of accessible
gaseous and liquid release system components
to review any recent changes or modifications
; and to confirm the alignment, operation
and material condition
of the radioactive
liquid and gaseous effluent radiation
monitoring
systems (RMS) at Units 1, 2 and 3. * Observations
were conducted
of radioactive
effluent related sampling and associated
laboratory
measurement
techniques.
* Procedural
controls and selected radioactive
gaseous and liquid effluent release permits were reviewed to verify that radiation
monitor alarm setpoint values and releases were in agreement
with Technical
Specification
and ODCM requirements.
Enclosure 
2 * Chemistry
logs, relative to out-of-service
radiation
monitoring
conditions, were reviewed to confirm the performance
of compensatory
sampling activities.
* Surveillance
tests of gaseous filtration
discharge
systems were reviewed to confirm operability
and ventilation
flow rates with respect to the assumed flow rates used in gaseous effluent release calculations.
* Entergy's
surveillance
program of non-radioactive
system interfaces
with radioactive
process systems was reviewed to confirm effective
monitoring
and control of potential
effluent discharge
paths to the environment.
* Radiation
monitoring
system and chemistry
laboratory
counting instrument
calibration
and quality control records were reviewed with respect to ODCM surveillance
requirements
to confirm the licensee's
ability identify and report detectable
radionuclides
in radioactive
measurement
results. 3) Radioactive
effluent control related corrective
action program activities
for 2007 through August 2009 were reviewed , including
the results of audits and the resolution
of issues identified
through the condition
report system. A comprehensive
review was conducted
of conditions
and occurrences
involving
out-of-service
radiation
monitoring
system components.
Section 40A2 pertains.
b. Findings and Observations
No findings of significance
were identified.
The following
table summarizes
the dose consequence
of radiological
effluent release in the period between 2007 and 2008. Table of Effluent Release calculated
dose and public dose limits for 2007 and 2008 Dose in Air Dose %of Air Dose %of liquid '10 of Liquid %of mrem/yr Whole limit Max Organ Limit Dose limit Dose limit Body WB MaxO 2007 Units 1&2 2.43E-3 0.016 2.43E-3 0.016 5.3 5E-4 0.018 1.3E-3 0.013 2008 Units 1&2 2.07E-3 0.014 2.67E-3 0.018 6.11E-4 0.020 1.47E-3 0.Q15 2007 Unit 3 3.BBE-3 0.026 3.BBE-3 0.026 3.2E-4 0.007 2.14E-4 0.002 2008 Unit 3 1.99E-3 0.013 1.99E-3 0.013 1.56E-4 0.005 2.B3E-4 0.003 2007 Groundwater
2.66E-4 0.009 9.94E-4 0.01 2008 Groundwater
2.86E-4 0.009 9.35E-4 0.009 4. OTHER ACTIVITIES (OA) 40A2 Identification
and Resolution
of Problems Cornerstone:
Public Radiation
Safety .1 Radioactive
Gaseous and Liquid Effluent Treatment
and Monitoring
Systems a. Inspection
Scope (71122.01)
The inspector
reviewed approximately
one hundred corrective
action condition
reports, initiated
between january 2007 and August 2009, that were associated
with the gaseous, liquid, and groundwater
radioactive
effluents
program. The review was performed
to Enclosure 
3 verify that problems identified
by these condition
reports were properly characterized
in the licensee's
event reporting
system, causes were identified, and actions implemented
commensurate
the safety significance
of the matters. b. Findings and Observations
No findings of significance
were identified . . 2 Radioactive
Effluent Radiation
Monitor System (RMS) Maintenance
(71152 -1 sample) a. Inspection
Scope The inspectors
conducted
a review corrective
action program condition
reports associated
with out-of-service
radiation
monitoring
system equipment
that was identified
in the period between January 2007 and August 2009. Licensee personnel
having cognizance
of Radiation
Monitoring
System (RMS) performance
and activities
were interviewed, including
the RMS system engineer and senior chemistry
staff. "Radiation
Monitoring
System, Second Quarter 2009, Condition
Report Trend Review for Radiation. Monitoring
System Improvement
: dated September
2, 2009, was also reviewed.
b. Findings and Observations
No findings of Significance
were identified.
A large number of condition
reports associated
with the radiation
monitoring
system were initiated
during the past two years. Most of the condition
reports were associated
with interruption
of service of the RMS display consoles in both the Unit 2 and Unit 3 control rooms. While these temporary
display outages affected operators'
ability to poll individual
detector readout displays , they did not interfere
with control room annunciator
actuation
or actual detector operability. The cause of the Unit 3 display console issues was determined
to be related to excessive
temperature
in the RMS electronics cabinets
that affected certain control
room RMS display console components.
Short-term
corrective
actions included installing
permanent
air conditioning
to effect improved cooling of the RMS electronics
cabinets.
The cause of Unit 2 RMS display console service interruptions
continues
to be under review. Notwithstanding, Entergy is evaluating
replacing
the RMS display console equipment
in both control rooms to support station-wide
computer network access improvements.
Less frequently
occurring
RMS equipment
issues remain to be resolved, including
occurrences
involving
the R-56 detectors, which monitor the discharge
of waste sewage from Units 2 and 3. The location of these detectors
was determined
to be susceptible
to failure due to flooding , power spiking, and power outages. In such conditions, waste sewage is diverted to an on-site holding tank in order to conduct sampling prior to off-site release. Accordingly, there is no safety significance
to these RMS system failures.
The inspector
confirmed
that the licensee has implemented
appropriate
remedial actions for these occurrences, and has initiated
actions to improve the operating
environment
and detector function to reduce the out-of-service
time. Enclosure 
4 Entergy has identified
the Unit 2 RMS as an upgrade project in its Top Ten Action Plan for 2009. System engineering
activities
have been initiated
for this improvement
activity.
The inspector
determined
that the majority of identified
problems with the Unit 2 and Unit 3 radiation
monitoring
systems were not associated
with radiation
detector operability
or effluent release control functions.
For those instances
that resulted in out-of-service
conditions, the licensee implemented
appropriate
compensatory
measures as required by regulatory
requirements.
The inspector
confirmed
that Entergy is engaged in RMS . improvement
activities, and has initiated
appropriate
corrective
actions. 40A5 Other Activities
.1 Assessment
of Licensee Performance
Relative to Meeting the Objectives
of the December 16.2008 Memorandum
Reguesting
Deviation
from the Action Matrix Background:
On September
1, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent fuel pool wall had been discovered
during excavation
work inside the spent fuel pool building.
Low levels of radioactive
contamination
were found in the vicinity.
Entergy's
initial investigation
of the issue revealed that groundwater
in the vicinity was contaminated
with tritium. On September
20, 2005, Region I initiated
a special inspection
of this matter to examine the licensee's
performance
and determine
if the contaminated
groundwater
affected, or could affect, public health and safety. Subsequently, Entergy initiated
actions to perform a comprehensive
groundwater
site characterization, identify the sources, and effect mitigation
and remediation
of the condition.
The NRC special inspection
report, issued in March 2006, assessed Entergy's
performance, achievements, and plans for more extensive
site characterization, and reported that the groundwater
contamination
did not, nor was likely to, adversely
affect public health and safety. In the report, and subsequent
public meetings, NRC indicated
that a final conclusion
would be reached after Entergy completed
its groundwater
characterization
initiative.
The NRC Region I continued
inspection
and monitoring
of Entergy's
activities
in accordance
with successive
approved deviation
to the normal Reactor Oversight
Process for calendar years 2006 (ML053010404), 2007 (ML063480016), 2008 (ML073480290)
and 2009 (ML083590057).
During this period, the NRC staff closely monitored
Entergy's
groundwater
characterization
efforts, performed
independent
inspections
and testing, and independently
evaluated
radiological
and hydrological
conditions
affecting
groundwater
onsite. Additionally, the NRC independently
verified groundwater
releases by conducting
split monitoring
well sampling with Entergy and the State of New York. On January 11, 2008, Entergy submitted
the results of its comprehensive
hydrogeologic
site characterization
investigation (ML080320600), and included its plan for remediation
and long-term
monitoring
of the on-site groundwater
conditions.
In its report, Entergy described
the source of groundwater
contamination
to be from the Unit 1 and Unit 2 spent fuel pools. The NRC documented
its review of Entergy's
report in inspection
report 05000247 & 05000003/2007010
on May 13, 2008 (ML081340425).
In a subsequent
inspection
05000247/2008004 (ML08311 0566) dated November 6,2008, the NRC Enclosure 
5 confirmed
that Entergy's
conceptual
site model of the site, which included both the vadose zone and saturated
zone processes
and conditions, effectively
characterized
the onsite groundwater
plume behavior and radionuclide
transport. Evaluation
of radionuclide
concentrations
and pathway analyses indicated
that the groundwater
contamination
did not adversely
affect public health and safety. Detailed discussions
and analyses indicated
that the licensee's
plans for long-term
monitoring
of the site, relative to monitoring
natural attenuation
of residual groundwater
contamination, were reasonable.
On November 3, 2008, Entergy completed
Unit 1 spent fuel pool system drainage and sludge removal activities, essentially
terminating
the source from that facility. Given the change in conditions, Entergy initiated
actions to establish
a new groundwater
contaminant
baseline in support of its long-term
monitoring
program. a. Inspection
Scope The most recently approved Memorandum
of Deviation, i.e., " Request for Renewal of Deviation
to the Action Matrix to Provide Heightened
NRC Oversight
of the Onsite Groundwater
Monitoring
at the Indian Point Energy Center," dated December 16, 2008 (ML083590057), identified
the following
objectives
to be addressed
in order to support resumption
of normal inspection
activities
in accordance
with the Reactor Oversight
Process: * Entergy has completed
sufficient
data collection
and assessment
to establish
a new groundwater
contaminant
baseline, now that the Unit 1 source term has been terminated.
* Entergy has determined
whether active leakage has been terminated
or continues
to persist in regard to the Unit 2 spent fuel pool; and has implemented
appropriate
monitoring
and control measures, as necessary.
* Entergy has established
and implemented
effluent control and environmental
monitoring
procedures
that provide reasonable
assurance
that the existing groundwater
conditions
will continue to be effectively
monitored
and assessed, that the procedures
will detect new or changed conditions
in a timely manner, and that the procedures
are sufficient
to monitor natural attenuation
of the Unit 1 and Unit 2 groundwater
contamination
plumes. The NRC team reviewed the licensee's
performance
and achievements
relative to the completion
of these objectives.
b. Findings and Observations
No findings of significance
were identified.
The inspectors
determined
that Entergy completed
the actions necessary
to satisfy the objectives
delineated
in the approved Memorandum
of Deviation, dated December 16, 2008, (ML083590057).
Notwithstanding, NRC will continue to monitor performance
in this area, and re-assess
the need for continued
heightened
inspection
oversight
as part of the CY 2009 end-of-cycle
performance
review of IPEC. Enclosure 
6 The following
pertains:
* Objective
1: Completion
of sufficient
data collection
and assessment
to establish
a new groundwater
contaminant
baseline, now that the Unit 1 source term has been terminated.
As a result of the defueling, drainage, and de-sludging
of the Unit 1 spent fuel pool system in the Fall of 2008, the groundwater
contamination
source term from the Unit 1 facility was terminated.
The inspectors
confirmed
that Entergy's subsequent
data collection
and assessment
activities , associated
with the continual
monitoring
of the residual groundwater
contamination, would be sufficient
and effective
to establish
a new baseline relative to monitoring
the residual groundwater
condition
and subsequent
assessment
of dose consequence. As expected, the first and second-quarter
ground-water
sample results in 2009, collected
from Monitoring
Wells in the immediate
vicinity o f the Unit 1 spent fuel pool, indicated
an increase in Sr-90 groundwater
concentrations. As determined
from review of the licensee's
data and analysis, this increased
concentration
was the expected result of the volume of water that was necessary
to fill the spent fuel pool system to effect defueling.
Accordingly, Entergy's baseline data was predicated
on the existing groundwater
conditions
determined
from its continuing
analysis of collected
monitoring
data. Given that the original source of the contamination
associated
with leakage from the Unit 1. spent fuel pool system has been terminated , the residual groundwater
contamination
involving
Sr-90 is expected to naturally
attenuate
over time. The inspectors
confirmed
that the current groundwater
contaminant
concentrations
have not, nor are expected to, affect public health and safety; and the public radiological
dose consequence
is expected to continue to be a fraction of the NRC annual regulatory
limit affecting
liquid effluents.
The inspectors
confirmed
that cont i nual monitoring
of the migration
and attenuation
of the Unit 1 associated
groundwater
contamination
condition
is being performed
in accordance
with Entergy's
Long-Term Ground-Water
Monitoring
Program (LTGWMP).
The inspectors
confirmed
that Entergy has established , implemented
and maintains
a long-term
ground-water
monitoring
program that has sufficient
in scope and implementation
requirements
to effectively
monitor and assess this condition. Accordingly, the intent of this objective
was considered
satisfied. * Objective
2: Determination
whether active leakage has been terminated
or continues
to persist in regard to the Unit 2 spent fuel pool , and that appropriate
monitoring
and control measures have been implemented , as necessary.
Entergy has been actively engaged in analyzing
Monitoring
Well data associated
with the H-3 (tritium)
groundwater
contamination
condition
that resulted from previously
identified
leakage from the Unit 2 spent fuel pool: Entergy's analysis indicated
an overall . decreaSing
trend in tritium concentration
in the groundwater
as a result of previous efforts to e x amine the condition
of the spent fuel pool and transfer canal liner , and effect repair , as necessary.
Notwithstanding , as previously
reported , Entergy's
e x amination
of the spent fuel pool liner was necessarily
limited to only the accessible
surfaces.
That is, only about 40 % of the total liner surfaces were accessible
for examination;
the remaining
surfaces were necessarily
inaccessible
due to the pro x imity of stored spent fuel that prevented
examination.
Enclosure 
7 The inspectors
reviewed the licensee's
analysis derived from groundwater
monitoring
data, and confirmed
that there was no apparent indication
of any significant
large flux going active leakage. The inspectors
also reviewed the licensee's monitoring
well detect i on sensitivity
data , which supports that active leakage , if occurring , would likely not exceed 30 gallons per day (0.02 gpm). This sensitivity
analysis was based on comparison
of the tritium concentration
that is available
in the spent fuel pool and the actual tritium concentration
derived from samples collected
from relevant monitoring
wells in the near vicinity of the spent fuel pool. Additionally, the inspectors
reviewed licensee analysis and data from a long-term
tracer test that indicated
the potential
for slow, episodic trit i um migration
in the fractures
of the vadose zone that affect the mobility of contamina t ed groundwater
from the immediate
vicinity of the Unit 2 spent fuel pool to the water table. The licensee's analysis is supported
by the fact that fluorescine
dye, which was injected as part of the groundwater
characterization
study over two years ago, is still detectable
in certain nearby monitor i ng wells. The inspectors noted that
there were occasional
spikes and general variability
in some monitor i ng well tritium concentration
values that were not characteristic
of the e x pected attenuation
that would normally be expected at this time. Additionally , the licensee continued
to occasionally
collect a small quantity of water from the leak collection
box that was installed
on the Unit 2 spent fuel pool wall crack that was identified
in 2005. Accordingly, while there was no indication
of any significant
large flux active leakage, there was insufficient
basis to conclude that there is absolutely
no persistent
low flux leakage from the Unit 2 spent fuel pool, at this time. Notwithstanding , the inspectors
determined
that the licensee's sensitivity
analysis of groundwater
monitoring
data, relative to its ability to detect active leakage in e x cess of about 30 gallons per day , was reasonably
derived. Additionally , the inspectors
confirmed
that the current groundwater
conditions, even if there was persistent
low flux leakage from the Unit 2 spent fuel pool, has not, nor would be e x pected to, affect public health and safety; and the public radiological
dose consequence
would be expected to continue to be a fraction of the NRC annual regulatory
limit affecting
liquid effluents.
The inspectors
confirmed
that continual
monitoring
of the mig r ation and attenuation
of the Un it 2 associated
groundwater
contamination
condition
was being performed
in accordance
with Entergy's Long-Term
Ground-Water Monitoring
Program; and that the program implemented
appropriate
monitoring
and control measures for this condition.
The inspectors
confirmed
that Entergy has established, implemented
and maintained
a long-term
ground-water
monitoring
program that has sufficient
scope and implementation
requirements
to effectively
monitor and assess the present condition. Further, the licensee is considering
monitOring
in the vadose zone , in the vicinity of the Unit 2 facility , to assist in the detection
of large flu x releases. Accord i ngly , the intent of this objective
was considered
satisfied.
* Objective
3: Establishment
and implementation
of effluent control and environmental
monitoring
procedures
that provide reasonable
assurance
that the e x isting groundwater
conditions
will continue to be effectively
monitored
and assessed, that t he procedures
will detect new or changed conditions
in a timely manner, and that the procedures
are sufficient
to monitor natural attenuation
of the Unit 1 and Unit2 groundwater
contamination
plumes. Enclosure 
8 The NRC has conducted several
inspections (August 2007, October 2008, and August 2009) of the licensee's
Long-Term
Ground-Water
Monitoring
Program. The inspectors
confirmed
that Entergy has established, implemented
and maintained
a Long-Term
Ground-Water
Monitoring
Program that was sufficient
in scope and implementation
requirements
to effectively
monitor and assess the existing contaminated
groundwater
conditions
affecting
the Indian Point Energy Center. During this inspection, the inspectors
examined the refurbishment
of the LaFarge No.2 Monitoring
Well (one of the principal off-site monitoring
wells) and confirmed
its acceptability
as a valid off-site monitoring
location.
Additionally , the inspectors
verified that the administrative
controls, established
in the Long-Term
Groundwater
Monitoring
Program, were sufficient
t9 provide assurance
of review and appropriate
communication
of activities
and changes that affect ground-water
monitoring
conditions;
and that the program included sufficient
sampling requirements
for storm drains and the Unit 1 foundation
drain systems. During this inspection, the inspectors
reviewed a March 25, 2009 instance involving
the licensee's
detection
of tritiated
water in the catch basin of a storm drain in the vicinity of Unit 3 , and in an adjacent shallow monitoring
well. The licensee conducted
an extensive
investigation
but was unable to find an explanation
for this one-time occurrence.
The inspectors
confirmed
that the occurrence
had no radiological
consequence
onsite or offsite; and no leakage was identified
from any Unit 3 component
containing
tritiated
water. However, the nature of the occurrence
indicated
uncertainty
in the ability of the existing Unit 3 monitoring
wells to detect potential
leakage from that facility.
While there was no current on-going leakage affecting
the groundwater
at Unit 3 , Entergy initiated
action to re-evaluate
the Unit 3 groundwater
monitoring
configuration (both vertically
and horizontally)
to determine
its effectiveness
in meeting the objectives
and recommendations
of the NEI "Industry
Groundwater
Protection
Initiative-
Final Guidance Document, August 2007" (ML072600292
and ML07261 0036); and amend the Term Groundwater
Monitoring
Program , as necessary.
Notwithstanding, the inspectors
confirmed
that Entergy has established, implemented
and maintained
a Long-Term
Ground-Water
Monitoring
Program that has sufficient
scope and implementation
requirements
to effectively
monitor and assess the existing* groundwater
conditions
affecting
Indian Point Energy Center. Accordingly, the intent of this objective
was considered
satisfied . . 2 Groundwater
Sampling a. Inspection
Scope During the licensee's
groundwater
investigation, over 1200 groundwater
samples were collected
and analyzed from the established
on-site monitoring
well network by the second quarter of 2009. The analytical
results provide the basis for assessing
the extent of the groundwater
plume and for performing
calculations
of offsite doses to members of the public. In order to assess Entergy's
performance
in this area, the NRC implemented
an independent
split sample collection
program with the licensee beginning
in September
2005. The monitoring
wells selected for independent
verification
included the southem boundary wells and those wells bordering
the Hudson River that were used Enclosure 
9 in support of effluent release and dose assessment
calculations.
Sample identity was assured by chain-of-custody
procedures
that included sample collection
observation
by the NRC or a representative
of the NYS DEC. The NRC samples were analyzed by an independent
govemment
laboratory
to ensure validation
of the licensee's
groundwater
contamination
results and off-site environmental
sample radioactive
measurements.
By the second quarter of 2009, over 300 split groundwater
samples were obtained to provide an independent
check of Entergy's
analytical
results and to independently
verify if there was any detectable
migration
of groundwater
contaminants
offsite. These split samples represent
over 1,200 analyses, primarily
for hydrogen-3 (tritium), strontium-90, nickel-63, and gamma-emitting
radionuclides
that characterized
the effluent releases. Analyses for other radionuclides
were performed, but none were detected.
b. Findings and Assessment
No findings of significance
were identified. In general, Entergy's
groundwater
measurements
of radioactivity
were of good quality and of sufficient
sensitivity
to assess radiological
impact. The quality of Entergy's
measurements
were confirmed
by various split samples analyzed by the NRC. Of the over 1200 results that were reviewed, there were only a few sample disagreements
based on the statistical
comparison
criteria specified
in NRC Inspection
Procedure
84750, "Radioactive
Waste Treatment, and Effluent and Environmental
Monitoring." As a result of these few discrepancies, Entergy took corrective
action to establish, implement, and maintain procedures
to effect improved quality control and assurance
of sample analysis performed
by its own laboratory
and contract analytical
laboratories.
During the past 3)1" years, the on-site groundwater
transport
pathway has been effectively
characterized
by the licensee, and a significant
quantity of on-site groundwater
monitoring
data has been collected
and analyzed by Entergy. A representative
numbers of split samples have confirmed
the overall efficacy of the licensee's
analytical
capability.
As the site characterization
was tested through pumping and tracer testing, the contaminant
plume uncertainty
has been significantly
reduced. Given this accomplishment, and the NRC determination
that Entergy has demonstrated
an effective
groundwater
sample quality control program, the NRC will discontinue
any further split sampling activities.
40A6 Meetings, including
Exit .1 Exit Meeting Summary The inspectors
presented
the inspection
results to Mr. D. Mayer and other licensee and New York State representatives
on August 19, 2009 and September
4, 2009. The licensee acknowledged
the findings presented.
Based upon discussions
with the licensee, none of the information
presented
at the exit meeting and included in this report was considered
proprietary.
Enclosure 
Licensee Personnel
J. Pollock M. BaNenik P. Conroy D. Croulet P. Donahue C. English G. Hinrichs D. Loope T. Jones R. LaVera D. Mayer J. Michetti J. Peters D. Rusczyk S. Sandike J. Simpson R. Walpole A-1 ATTACHMENT
SUPPLEMENTAL
INFORMATION
KEY POINTS OF CONTACT Site Vice President
Principal
Engineer, GZA Geo EnVironmental, Inc. Director, Nuclear Safety Assurance
Licensing
Engineer Chemistry
Specialist
Unit 1 Project Engineer Project Engineer Radiation
Protection
Superintendent
Licensing
Engineer Radiological
Engineer Director, Special Projects RMS System Engineer Plant Chemist Environmental
Assessment, GZA Chemistry
ODCM Specialist
Environmental
Assessment, GZA Manager, Licensing
New York State Inspection
ObseNers L. Rosenmann
Engineering
Geologist, New York State, Department
of Environmental
ConseNations
INSPECTION
PROCEDURES
USED 71122.01 Radioactive
Gaseous and Liquid Effluent Treatment
and Monitoring
Systems LIST OF DOCUMENTS
REVIEWED Annual Radiological
Effluent Release Reports -2007 and 2008 Off-Site Dose Calculation
Manual, Revision 2 O-CY-2730, Rev. 1, Airbome Radioactive
Effluents
O-CY-2740, Rev. 1, Liquid Radioactive
Effluents
IP-SMM-CY-001, Rev. 7, Radioactive
Effluents
Control Program IP-SMM-CY-110, Rev. 3, Radiological
Groundwater
Monitoring
Program 2-CY-2625, Rev. 14, General Plant Systems Specifications
and Frequencies
3-CY-2325, Rev. 8, Radioactive
Sampling Schedule 2-S0P-5.2.4, Rev. 33, Calculation
and Recording
of Radioactive
Gaseous Releases 2-S0P-5.1.5, Rev. 34, Calculation
and Recording
of Radioactive
Liquid Releases 3-S0P-WDS-014, Rev. 25, Liquid Waste Releases Attachment 
A-2 3-S0P-WDS-013 , Rev. 25 , Gaseous Waste Releases EN-RP-113 , Response to Contaminated
Spills/Leaks
EN-CY-109, Sampling and Analysis of Groundwater
Monitoring
Wells EN-CY-108, Monitoring
of Non-Radioactive
Systems " Industry Groundwater
Protection
Initiative
-Final Guidance Document , August 2007" (ML072600292
and ML072610036)
Unit 2 Liquid Release Permit No. 090016 Unit 2 Gaseous Release Permit No. 090126 Unit 3 Liquid Release Permit No. 090081 Unit 3 Gaseous Release Permit No. 090067 Condition
Reports: CR-IP3-2007 -0803 CR-IP2-2009
-2089 CR-IP3-2009-3356
CR-IP2-2009-2528
CR-IP2-2009-3307
CR-IP3-2007-3954
CR-IP2-200S-0270
CR-IP2-200S-0375
CR-IP3-200S-071S
CR-IP2-200S-0377
CR-IP2-2009-2266
CR-IP2-200S-1236
CR-IP3-2007 -3860 CR-IP3-200S-1112
CR*IP3*200S*2915
CR*IP3*200S*1042
CR*IP2*200S*2767
CR*IP2*200S*4136 CR*IP3*200S*2184
CR*IP2*200S*3662
CR*IP3*200S*2125
CR*IP2 c 200S*4130
CR*IP2*200S*4529
 
CR*IP2-200S-4191
CR-IP2-200S-456S
CR-IP3-2007-0151
CR-IP3-2007
-2S99 CR-IP3-2007
-2134 CR-IP3-2007
-3129 CR-IP2-2008-4981
 
CR-IP2-2008-5552
CR-IP2-2009-0609
CR-IP2-2009-0565
CR-IP2-2009-223S
CR-IP2-2009-1334
CR-IP2-2009-2352
CR-IP3-2009-3201
CR-IP3-2009-3254
CR-IP2-2009-3306
CR-IP3-2007-3925
CR-IP2-2007-5226
CR-IP2-200S-0549
CR-IP2-200S-0960
CR-IP2-200S-0144
CR-IP3-200S-0569
CR-IP3-200S-0852
CR-IP3-2008-0942
CR-IP2-2008-2468
CR-IP3-2008-1215
CR-IP2-2008-2581
CR-IP3-2008-1218
CR-IP3-2008-200
1 CR-IP2-2008-3342
CR-IP3-200S-1S99
CR-IP2-200S-4193
CR-IP2-200S-4254
CR-IP2-200S-4337
CR-IP3-200S-2279
CR-IP3-2008-0624
CR-IP3-2007-3367
CR-IP3-2007-3061
CR-IP3-2007
-3075 CR-IP2-2008-4S48
CR-IP2-200S-5055
CR-IP3-2009-003S
CR-IP2-2009-1125
CR-IP2-2009-079S
CR-IP2-2009-1295
CR-IP2-2009-2090
 
CR-IP2-2009-2603
CR-IP3-2009-320S
CR-IP3-2007
-3953 CR-IP3-2007
-41S3 CR-IP2-2007-5217
CR-IP2-2008-1149
CR-IP2-2008-0404
CR-IP2-2008-0492
CR-IP3-2008-0S46
CR-IP2-2008-0179
CR-IP2-2008-3154
CR-IP3-2008-0194
CR-IP2-2008-3526 CR-IP2-2008-2691
CR-IP3-2009-00S0
CR-IP2-2008-2955
CR-IP2-2008-3492
CR-IP3-2008-1979
CR-IP2-2008-4108
CR-IP2-2008-4202
CR-IP3-2008-2296
CR-IP3-2008-2294
 
CR-IP3-2007
-0005 CR-I P3-2007 -27 48 CR-IP3-2007-2S70
CR-IP2-2008-1132
CR-IP3-200S-2S62
CR-IP2-2009-0477
 
CR-IP2-2009
-01S4 CR-IP3-2009-0494
 
CR-IP3-2009-0591
Attachment 
A-3 NRC Groundwater
Sample Result Documentation
ICY 2009. 1 s t Quarter) ML090400502.
ML090920949.
ML090920932
FSAR GPM LTGWMP NYS DEC ODCM pCi/L PI&R Rap LIST OF ACRONYMS USED Final Safety Analysis Report gallons per minute Long Term Ground-Water
Monitoring
Program State of New York Department
of Environmental
Conservation Offsite Dose
Calculation
Manual pico-Curies
per Liter Problem Identification
and Resolution
Reactor Oversight
Process Attachment
}}

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