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* V \J V V \J \i 62! -1 6 1 3 "---7n2JO(, 7/23/06 7/2 4 106 7flSI06 7n 6lO6 7 fl7/06 7!l8J()(, WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR MW-48-38 (JULY 06) At high tide, the level of water in both of these wells is very close to the river level , while at low tide , it is s lightly above the river level and approximately 2 feet below the level of the Discharge Canal. The vertical gradient at this location is upward , with a stronger gradient at low tide. These data are consistent with anticipated trend s , indicating groundwater discharge to the river occurs predominantly at low tide. Note that the river w a ter temperatures shown on graph s in this report are not representative of the temperature of the water in the river adjacent to monitoring well s MW-48. Thi s i s due to the location of river transduce r HR-I. and tidal induced flows in the river. However, the elevated (above ambient) temperature of the groundwater at the s e location s (65 to 69° F) indicates it has been wanned by the Site's cooling water di s charge. 69 The temperature of water in monitoring well MW-48-23 varies with so me tide cycles, with the coolest temperature being near hjgh tide in the winter, and the warmest temperature being near high tide i n the summer. This pattern of temperature change is consistent with this monitoring well receiving river water at times of high tide. The temperature of water in monitoring we ll MW-48-38 does not appear to vary with tidal cycles. We interpret these data to mean that physical water quality in monitoring well MW-48-38 is not typically influenced by large exchanges of river water 44. The elevated groundwater temperature at this location , and the piezometric data, suggest, however, that flows created by purging of the well prior to sampli ng , at times of high tide, could induce river water flow to this location.  
* V \J V V \J \i 62! -1 6 1 3 "---7n2JO(, 7/23/06 7/2 4 106 7flSI06 7n 6lO6 7 fl7/06 7!l8J()(, WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR MW-48-38 (JULY 06) At high tide, the level of water in both of these wells is very close to the river level , while at low tide , it is s lightly above the river level and approximately 2 feet below the level of the Discharge Canal. The vertical gradient at this location is upward , with a stronger gradient at low tide. These data are consistent with anticipated trend s , indicating groundwater discharge to the river occurs predominantly at low tide. Note that the river w a ter temperatures shown on graph s in this report are not representative of the temperature of the water in the river adjacent to monitoring well s MW-48. Thi s i s due to the location of river transduce r HR-I. and tidal induced flows in the river. However, the elevated (above ambient) temperature of the groundwater at the s e location s (65 to 69° F) indicates it has been wanned by the Site's cooling water di s charge. 69 The temperature of water in monitoring well MW-48-23 varies with so me tide cycles, with the coolest temperature being near hjgh tide in the winter, and the warmest temperature being near high tide i n the summer. This pattern of temperature change is consistent with this monitoring well receiving river water at times of high tide. The temperature of water in monitoring we ll MW-48-38 does not appear to vary with tidal cycles. We interpret these data to mean that physical water quality in monitoring well MW-48-38 is not typically influenced by large exchanges of river water 44. The elevated groundwater temperature at this location , and the piezometric data, suggest, however, that flows created by purging of the well prior to sampli ng , at times of high tide, could induce river water flow to this location.
 
6.6.3 Aqueous Geochemistry Routine groundwater monitoring indicated th e presence of Tritium in a limited number of sam ples collected from monitoring well s MW-38 and MW-4 8. MW-38 was originally installed under the first phase of inve s tigation to bound the southern extent of T ritium contamination at the Site along the cooling water Discharge Canal. However, subse quent sampling events indicated the presence of Tritium in groundwater at thi s loca tion. The presence of Tritium in this well did not fit our CSM or what we knew of groundwater flow at the Site. A second well , MW-48, was insta ll ed at the so uthern Site boundary along the Hudson River to e s tabli sh if any Tritium would potentially migrate off-Site.
====6.6.3 Aqueous====
Tritium was detected intermittently in groundwater samples collected at this loca t ion as well. As neither of these locations was hydraulica ll y downgradient of identified rele ase areas, another mechani sm other than grou ndw ater migration from the release area was postu l ated. This mechanism involved releases from the legacy pip i ng that conveyed contaminated water from the IPI-SFDS to the "E"-ser ie s stormwater piping that runs beneath the access road on the South side of the Protected Area and discharges storm water to the cooling water Discharge Canal. While evaluating this hypothesis, we found evidence, as discussed in Section 6.62, that at certain tidal cycles, water from the Discharge Canal and the Hudson River may back flow into these groundwater monitoring wells. To help identify the source of Tritium in these two wells, we developed a focused water quality program specific to the se wells. Generally, the water quality program involved analyzing selec t aqueous geochemica l parameters in groundwater and surface water samples. Evaluation of these data can allow conclusions to be drawn regarding the sou r ce of the samp led water. Both data sets (elevation and water chemistry) indicate that water co ll ected from these wells may contain river or cooling water from the Discharge Canal. Based on these findings , we recommend that groundwater samp l e l aboratory re s ult s from th ese well loc ations not be used to evalua te the extent of groundwater contami n ation or contaminant
Geochemistry Routine groundwater monitoring indicated th e presence of Tritium in a limited number of sam ples collected from monitoring well s MW-38 and MW-4 8. MW-38 was originally installed under the first phase of inve s tigation to bound the southern extent of T ritium contamination at the Site along the cooling water Discharge Canal. However, subse quent sampling events indicated the presence of Tritium in groundwater at thi s loca tion. The presence of Tritium in this well did not fit our CSM or what we knew of groundwater flow at the Site. A second well , MW-48, was insta ll ed at the so uthern Site boundary along the Hudson River to e s tabli sh if any Tritium would potentially migrate off-Site.
Tritium was detected intermittently in groundwater samples collected at this loca t ion as well. As neither of these locations was hydraulica ll y downgradient of identified rele ase areas, another mechani sm other than grou ndw ater migration from the release area was postu l ated. This mechanism involved releases from the legacy pip i ng that conveyed contaminated water from the IPI-SFDS to the "E"-ser ie s stormwater piping that runs beneath the access road on the South side of the Protected Area and discharges storm water to the cooling water Discharge Canal. While evaluating this hypothesis, we found evidence, as discussed in Section 6.62, that at certain tidal cycles, water from the Discharge Canal and the Hudson River may back flow into these groundwater monitoring wells. To help identify the source of Tritium in these two wells, we developed a focused water quality program specific to the se wells. Generally, the water quality program involved analyzing selec t aqueous geochemica l parameters in groundwater and surface water samples. Evaluation of these data can allow conclusions to be drawn regarding the sou r ce of the samp led water. Both data sets (elevation and water chemistry) indicate that water co ll ected from these wells may contain river or cooling water from the Discharge Canal. Based on these findings , we recommend that groundwater samp l e l aboratory re s ult s from th ese well loc ations not be used to evalua te the extent of groundwater contami n ation or contaminant  
: 4. Rellltively large exchanges of water are required to overcome the thennal mass of the subsurface deposits surrounding the well bore. Therefore, while smaller exchangcs of g r oundwa t er/river water may go undetected via temperature change. they may st ill be large enough to adversely impact radiological water quality. particularly in consideration of the data from the proximate well sc r eens. Also see discussion in Section 6.6.3. 70 flux to the Hudson River and that these wells not be incorporated into the Long Term Monitoring P l an as Boundary W e ll s. 6.6.3.1 Sampling Gro undwater samp l es were collected from monitoring well s MW-38 , MW-48-23, and MW-48-38 and from the Discharge Cana l and Hud son River on January 19 , 2007. These samp le s were analyzed for bicarbonate alkalinity (as CaCO,), magnesium , sod ium , calcium, s u l fate, and chloride.
: 4. Rellltively large exchanges of water are required to overcome the thennal mass of the subsurface deposits surrounding the well bore. Therefore, while smaller exchangcs of g r oundwa t er/river water may go undetected via temperature change. they may st ill be large enough to adversely impact radiological water quality. particularly in consideration of the data from the proximate well sc r eens. Also see discussion in Section 6.6.3. 70 flux to the Hudson River and that these wells not be incorporated into the Long Term Monitoring P l an as Boundary W e ll s. 6.6.3.1 Sampling Gro undwater samp l es were collected from monitoring well s MW-38 , MW-48-23, and MW-48-38 and from the Discharge Cana l and Hud son River on January 19 , 2007. These samp le s were analyzed for bicarbonate alkalinity (as CaCO,), magnesium , sod ium , calcium, s u l fate, and chloride.
The data was graphed on Stiff diagrams and is shown on Figure 6.16. 6.6.3.2 Water Quality Evaluation GZA used the six water quality indicator s (bicarbonate alkalinity  
The data was graphed on Stiff diagrams and is shown on Figure 6.16. 6.6.3.2 Water Quality Evaluation GZA used the six water quality indicator s (bicarbonate alkalinity
[as CaC03], magnesium, sodium, calcium, s ulfate , and chloride) to assess whether or not Discharge Cana l and/or river water was present or mixed with groundwater at the two l oca tion s of intere st (note tha t th e MW-48 monitoring well location contains a shallow and a deep well). A summary of our findings f o llow s.
[as CaC03], magnesium, sodium, calcium, s ulfate , and chloride) to assess whether or not Discharge Cana l and/or river water was present or mixed with groundwater at the two l oca tion s of intere st (note tha t th e MW-48 monitoring well location contains a shallow and a deep well). A summary of our findings f o llow s.
* The river and canal samples are chemically s imilar and are dominated by sodium and chloride.
* The river and canal samples are chemically s imilar and are dominated by sodium and chloride.
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at low tide, there is slightly less sodium and chloride than at mid or high tide. We believe this likely indicates that at low tide , this location sees relatively more groundwater.
at low tide, there is slightly less sodium and chloride than at mid or high tide. We believe this likely indicates that at low tide , this location sees relatively more groundwater.
These data indicate that water samples collected from MW-38 and MW-48-23 are largely representative of the proximate surface water bodie s at the Site. Recognizing the source of water in these we ll s, the other chemistry data (e.g., Tritium and Strontium) are suspect and should not be used for evaluation of groundwater contaminant migration or flux. Based on the available data , MW-48-38 may provide samples more representative of Site groundwater than MW-38 and MW-48-23. However , further analysis would be necessary to allow this well to be recommended as a so uthern boundary monitoring location, particularly in light of the above analysis pursuant to the proximate well s creens and the potential for false positives.
These data indicate that water samples collected from MW-38 and MW-48-23 are largely representative of the proximate surface water bodie s at the Site. Recognizing the source of water in these we ll s, the other chemistry data (e.g., Tritium and Strontium) are suspect and should not be used for evaluation of groundwater contaminant migration or flux. Based on the available data , MW-48-38 may provide samples more representative of Site groundwater than MW-38 and MW-48-23. However , further analysis would be necessary to allow this well to be recommended as a so uthern boundary monitoring location, particularly in light of the above analysis pursuant to the proximate well s creens and the potential for false positives.
Given the demonstrated groundwater flow directions in this area 41 , it is GZA's opinion that an additional southern boundary monitorin g location (in addition to MW-Sl and MW-40) is not required proximate to MW-48-38.  
Given the demonstrated groundwater flow directions in this area 41 , it is GZA's opinion that an additional southern boundary monitorin g location (in addition to MW-Sl and MW-40) is not required proximate to MW-48-38.
 
6.7 GROUNDWATER FLOW PATTERNS A major purpose of this groundwater investigation was to identify the fate and level of groundwater contaminant migration.
===6.7 GROUNDWATER===
 
FLOW PATTERNS A major purpose of this groundwater investigation was to identify the fate and level of groundwater contaminant migration.
The contaminants of potential concern are so luble in groundwater, and at somewhat varying rates, move with it. This section provides a descripti o n of identified groundwater flow panems in and downgradient of identified contaminant release areas. The piezometric data, shown in Table 6.1 , which form the basi s of this evaluation are independent of chemical data collected at the same monitoring location s. Consequently.
The contaminants of potential concern are so luble in groundwater, and at somewhat varying rates, move with it. This section provides a descripti o n of identified groundwater flow panems in and downgradient of identified contaminant release areas. The piezometric data, shown in Table 6.1 , which form the basi s of this evaluation are independent of chemical data collected at the same monitoring location s. Consequently.
our evaluation of piezometric data provides an assessment of where contaminants are expected to migrate in various time frames. Refer to Section 9.0 for information on the observed distribution of contaminants and a discussion on disc re pancies between anticipated and observed conditions.
our evaluation of piezometric data provides an assessment of where contaminants are expected to migrate in various time frames. Refer to Section 9.0 for information on the observed distribution of contaminants and a discussion on disc re pancies between anticipated and observed conditions.
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W = width of the s tr eamt ube dh dh Q=K*A*-=T*W*
W = width of the s tr eamt ube dh dh Q=K*A*-=T*W*
-dl dl To estimate transmissivities, the aquifer was divided int o two layers or zo n es: th e upper forty feet; and bet ween depths of 4 0 feet and 185 feet, the identifi ed bottom of the sig nificant groundwater fl ow field. In each of the zo ne s, transm i ssiv iti es were calculated u s ing the geometric mean of hydraulic conductivity testing. The facility was further divided into 6 fl ow zo ne s representing a re as beneath pertinent Site features; and data East (upgradient) of the Discharge Canal was reviewed independently of that West (d owngrad i ent) of the Discharge Cana l. This process , s h own o n the fo ll owi n g four t a bl es, provides an estimate of th e grou ndw at er flux p assi n g beneath s tructure s of intere st that discharge to the cooling water Discharge Cana l and the Hudson River. In re v i ew in g th ese ca l cu lati o n s, note th e resulting total groundwater flow East of t h e canal i s approximately 18 gpm , which indicate s that the long term areal recharge to the aquife r is 10 inches per year, o r 28% of the I O-year average precipitation recorded at the IP EC. 76 Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) (I(Jlm) Northern Clean Area 0.36 209 0.600 0.23 Unit 2 Nonh 1.59 294 0.014 0.03 Unit 1/2 31.97 215 0.007 0.26 Unit 3 North 29.87 324 0.054 2.74 Unit 3 South 16.02 3 3 8 O.oJ8 1.07 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 8.45 SHALLOW ZONE BEFORE CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) DJ), Northern C l ean Area 0.36 209 0.600 0.23 Un il 2 North 1.59 2 2 1 0.038 0.07 Un it 1 12 31.97 146 0.022 0.52 Unit 3 North 29.87 3 16 0.013 0.61 Unit 3 South 16.02 248 0.011 0.24 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 5.79 SHALLOW ZONE AFTER CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydra ulic Volumetric (friday) G r adient Flow Rate (ftlft) (""m) Northern C lean Area 10.77 209 0.068 0.80 Unit 2 North 1 0.77 294 0.030 0.49 U nit 1 12 62.15 21 5 0.023 1.61 U nit 3 North 37.65 324 0.022 1.41 U nit 3 South 22.02 338 0.040 1.55 Southern Clean Zone 19.66 879 0.043 3.83 Total+ 9.69 DEEP ZONE BEFORE CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) 77 Unit Transmissivity W i dth (ft) Hydraulic Volumetric (ft'/day) Gradient Flow Rate (flirt) (20m) N orthern Cl e an A r e a 10.77 209 0.068 0.80 Unit 2 North 10.77 294 0.023 0.29 Unit 112 62.15 215 0.018 0.83 Unit 3 North 37.65 324 0.QI8 1.09 Unit 3 South 22.02 338 0.016 0.45 Southern Clean Zo ne 19.66 879 0.04 3 3.8 3 7.25 DEEP ZONE AFfER CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) GZA's groundwater flux calculations are used by Entergy to calculate radiolog i ca l dose impact. Entergy currently estimates this dose based upon the precipitation mass balance approach alone. Refinements to this dose mode l are feasible utilizing the hydrogeo l ogic data presented above. These refinements will improve the overall data fit of the flow model in concert with the long term monitoring p r ogram being implemented by Entergy. The resultant dose assessments are expected to remain close to , or be somewhat lower than , what has already been estimated.
-dl dl To estimate transmissivities, the aquifer was divided int o two layers or zo n es: th e upper forty feet; and bet ween depths of 4 0 feet and 185 feet, the identifi ed bottom of the sig nificant groundwater fl ow field. In each of the zo ne s, transm i ssiv iti es were calculated u s ing the geometric mean of hydraulic conductivity testing. The facility was further divided into 6 fl ow zo ne s representing a re as beneath pertinent Site features; and data East (upgradient) of the Discharge Canal was reviewed independently of that West (d owngrad i ent) of the Discharge Cana l. This process , s h own o n the fo ll owi n g four t a bl es, provides an estimate of th e grou ndw at er flux p assi n g beneath s tructure s of intere st that discharge to the cooling water Discharge Cana l and the Hudson River. In re v i ew in g th ese ca l cu lati o n s, note th e resulting total groundwater flow East of t h e canal i s approximately 18 gpm , which indicate s that the long term areal recharge to the aquife r is 10 inches per year, o r 28% of the I O-year average precipitation recorded at the IP EC. 76 Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) (I(Jlm) Northern Clean Area 0.36 209 0.600 0.23 Unit 2 Nonh 1.59 294 0.014 0.03 Unit 1/2 31.97 215 0.007 0.26 Unit 3 North 29.87 324 0.054 2.74 Unit 3 South 16.02 3 3 8 O.oJ8 1.07 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 8.45 SHALLOW ZONE BEFORE CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) DJ), Northern C l ean Area 0.36 209 0.600 0.23 Un il 2 North 1.59 2 2 1 0.038 0.07 Un it 1 12 31.97 146 0.022 0.52 Unit 3 North 29.87 3 16 0.013 0.61 Unit 3 South 16.02 248 0.011 0.24 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 5.79 SHALLOW ZONE AFTER CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydra ulic Volumetric (friday) G r adient Flow Rate (ftlft) (""m) Northern C lean Area 10.77 209 0.068 0.80 Unit 2 North 1 0.77 294 0.030 0.49 U nit 1 12 62.15 21 5 0.023 1.61 U nit 3 North 37.65 324 0.022 1.41 U nit 3 South 22.02 338 0.040 1.55 Southern Clean Zone 19.66 879 0.043 3.83 Total+ 9.69 DEEP ZONE BEFORE CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) 77 Unit Transmissivity W i dth (ft) Hydraulic Volumetric (ft'/day) Gradient Flow Rate (flirt) (20m) N orthern Cl e an A r e a 10.77 209 0.068 0.80 Unit 2 North 10.77 294 0.023 0.29 Unit 112 62.15 215 0.018 0.83 Unit 3 North 37.65 324 0.QI8 1.09 Unit 3 South 22.02 338 0.016 0.45 Southern Clean Zo ne 19.66 879 0.04 3 3.8 3 7.25 DEEP ZONE AFfER CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) GZA's groundwater flux calculations are used by Entergy to calculate radiolog i ca l dose impact. Entergy currently estimates this dose based upon the precipitation mass balance approach alone. Refinements to this dose mode l are feasible utilizing the hydrogeo l ogic data presented above. These refinements will improve the overall data fit of the flow model in concert with the long term monitoring p r ogram being implemented by Entergy. The resultant dose assessments are expected to remain close to , or be somewhat lower than , what has already been estimated.
It is recommended that Entergy evaluate the refinements to the existing model for inclusion in the next annual effluent assessment report. 78
It is recommended that Entergy evaluate the refinements to the existing model for inclusion in the next annual effluent assessment report. 78 7.0 GROUNDWATER TRACER TEST RESULTS A tracer test was conducted to help assess g roundwater migration pathways from IP2-SFP. As discussed in the followin g sec tions , the te st also helped to confirm migration pathways from Uni t I. The test was designed to s imulate a leak from IP 2-SFP. in that the tracer (Fluorescein) was released directly to the bedrock at the base of the structure, immediately below the sh rink age cracks associated with the 2005 release. The bedrock surface at this location is approximately elevation 51 feet, and thus approximately 40 feet above the water table (as measured in the immediately adjacent MW-30 -see Figure 7.1). This approach was taken (recognizing it would complicate tracer fl ow paths relative to injection directly into the groundwater) to provid e better understanding of the role of unsaturated bedrock in storing and transporting Tritium, A major difference in the test , as compared to possible releases at IP2-SFP , i s the rate of the injection.
 
===7.0 GROUNDWATER===
 
TRACER TEST RESULTS A tracer test was conducted to help assess g roundwater migration pathways from IP2-SFP. As discussed in the followin g sec tions , the te st also helped to confirm migration pathways from Uni t I. The test was designed to s imulate a leak from IP 2-SFP. in that the tracer (Fluorescein) was released directly to the bedrock at the base of the structure, immediately below the sh rink age cracks associated with the 2005 release. The bedrock surface at this location is approximately elevation 51 feet, and thus approximately 40 feet above the water table (as measured in the immediately adjacent MW-30 -see Figure 7.1). This approach was taken (recognizing it would complicate tracer fl ow paths relative to injection directly into the groundwater) to provid e better understanding of the role of unsaturated bedrock in storing and transporting Tritium, A major difference in the test , as compared to possible releases at IP2-SFP , i s the rate of the injection.
The 2005 Tritium release was measured at a peak rate of approximately 2 liters per day (0.005 gpm), as opposed to the tracer injection that occurred relatively instantaneously (as compared to the Tritium release) at a rate of app roxim ate l y 3.5 gpm over approximately an hour. This higher injection rate was used to insure that a suffic ient mass of Fluorescein was released at a known time. As anticipated, a nd discussed in s ub sequent sect ions, this practice appears to have enhanced the lateral spreading of the tracer in the unsaturated zone. 7.1 TRACER INJECTION Preparation for the injection began on January 29, 2007 with the injection of potable water to test the ability of the injection point 49 , TI-U2-1 , to accept water and to pre-wet fractures. The first potable water inj ec ti on was cond uct ed on January 29, 2007. Five hundred gallo n s of water (m easured using an inline totaling water meter) was introduced as fast as the water source wou ld pennit (approximately 8.5 gpm). The water level in the well did not ris e significantly.
The 2005 Tritium release was measured at a peak rate of approximately 2 liters per day (0.005 gpm), as opposed to the tracer injection that occurred relatively instantaneously (as compared to the Tritium release) at a rate of app roxim ate l y 3.5 gpm over approximately an hour. This higher injection rate was used to insure that a suffic ient mass of Fluorescein was released at a known time. As anticipated, a nd discussed in s ub sequent sect ions, this practice appears to have enhanced the lateral spreading of the tracer in the unsaturated zone. 7.1 TRACER INJECTION Preparation for the injection began on January 29, 2007 with the injection of potable water to test the ability of the injection point 49 , TI-U2-1 , to accept water and to pre-wet fractures. The first potable water inj ec ti on was cond uct ed on January 29, 2007. Five hundred gallo n s of water (m easured using an inline totaling water meter) was introduced as fast as the water source wou ld pennit (approximately 8.5 gpm). The water level in the well did not ris e significantly.
The second potable water injection was conducted on January 30, 2007. A total of 1 , 012 gallons of t ap water was introduced at a mean rate of approx imatel y 8.3 gpm. The piezometric data collected during that period from wells MW-30 , MW*31 , MW*33 , MW-34 and MW-35 were re viewed for evidence of groundwater mounding. (Note: transducers were not in s talled in RW-I and MW-32 on that date,) Mounding, on the order of 0.5 to 1 foot , was recorded at MW-31. No re spo n se was noted at the other four nearby monitored locations.
The second potable water injection was conducted on January 30, 2007. A total of 1 , 012 gallons of t ap water was introduced at a mean rate of approx imatel y 8.3 gpm. The piezometric data collected during that period from wells MW-30 , MW*31 , MW*33 , MW-34 and MW-35 were re viewed for evidence of groundwater mounding. (Note: transducers were not in s talled in RW-I and MW-32 on that date,) Mounding, on the order of 0.5 to 1 foot , was recorded at MW-31. No re spo n se was noted at the other four nearby monitored locations.
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* 1 I * * --* t I; ..... *
* 1 I * * --* t I; ..... *
* 1/28107 1129/07 1/30 1 07 1/31107 PIEZOMETRIC GROUNDWATER RESPONSE TO WATER INJECTION We have insufficient infonnation to render an op ini on on the s hape or height of the tracer injection-induced groundwater mound. We note, however , because of the lower rate of the tracer injection, the sho rt duration of the inj ection (see below), and the groundwater flow velocities, as derived from the tracer test, aZA believes mounding had relatively little effect (compared to unsaturated flow) on th e lateral spreading of the tracer. That is , the life of the mound was not of sufficient duration to cause long tenn, widespread lateral migration in the groundwater.
* 1/28107 1129/07 1/30 1 07 1/31107 PIEZOMETRIC GROUNDWATER RESPONSE TO WATER INJECTION We have insufficient infonnation to render an op ini on on the s hape or height of the tracer injection-induced groundwater mound. We note, however , because of the lower rate of the tracer injection, the sho rt duration of the inj ection (see below), and the groundwater flow velocities, as derived from the tracer test, aZA believes mounding had relatively little effect (compared to unsaturated flow) on th e lateral spreading of the tracer. That is , the life of the mound was not of sufficient duration to cause long tenn, widespread lateral migration in the groundwater.
The tracer injection was performed on February 8 , 2007. It consisted of the rele ase of 7.5 pounds of Fl uorescein with 210 gallons of water. More spec ifically, prior to Fluoresce in injection, 30 gallons of potable water was released to the well , this was followed by 10 gallons of a Fluore sce in-water mixture , fo llowed by 170 gallons of potable water (to flu sh th e Fluorescein out of the well). This procedure resulted in a minimum initial ave rage tracer concentration of 4 , 300 , 000 ppb. 80
The tracer injection was performed on February 8 , 2007. It consisted of the rele ase of 7.5 pounds of Fl uorescein with 210 gallons of water. More spec ifically, prior to Fluoresce in injection, 30 gallons of potable water was released to the well , this was followed by 10 gallons of a Fluore sce in-water mixture , fo llowed by 170 gallons of potable water (to flu sh th e Fluorescein out of the well). This procedure resulted in a minimum initial ave rage tracer concentration of 4 , 300 , 000 ppb. 80 7.2 TRACER CONCENTRATION MEASUREMENTS The concentrations of Fluorescein in groundwater were routinely measured between February 8. 2007 and Au g u s t 21. 2007'° at 63 locations.
 
===7.2 TRACER===
CONCENTRATION MEASUREMENTS The concentrations of Fluorescein in groundwater were routinely measured between February 8. 2007 and Au g u s t 21. 2007'° at 63 locations.
Thi s re s ulted in the collection analysis of 4,488 samples , including background samples , charcoal samplers and water samples. T hese data are tabulated and presented on timewconcentration graphs in Appendix N. Measurements of Fluore s cein concentrations were made by two methods. The first is through aqueous sample analy s is (1 , 969 individual samples).
Thi s re s ulted in the collection analysis of 4,488 samples , including background samples , charcoal samplers and water samples. T hese data are tabulated and presented on timewconcentration graphs in Appendix N. Measurements of Fluore s cein concentrations were made by two methods. The first is through aqueous sample analy s is (1 , 969 individual samples).
These water sample analyses provide direct concentration measurements, at the time of sampling , with a detec t ion limi t ofless than 1 ppb. A second method entailed desorbtion of Fluorescein from packets of activated carbon (carbon s ampler s) s u s pended in the groundwater flow pa t h a t multi-level sampling locations.
These water sample analyses provide direct concentration measurements, at the time of sampling , with a detec t ion limi t ofless than 1 ppb. A second method entailed desorbtion of Fluorescein from packets of activated carbon (carbon s ampler s) s u s pended in the groundwater flow pa t h a t multi-level sampling locations.
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* The shape of the plume is more r epresentative of an ongo in g rele ase than of a month-old instantaneous release in a st rong groundwater flow field. This supports other data which indicate water is stored in the unsaturated bedrock (and potentially within the upper water bearing zone) and is released to the groundwate r flow field over time.
* The shape of the plume is more r epresentative of an ongo in g rele ase than of a month-old instantaneous release in a st rong groundwater flow field. This supports other data which indicate water is stored in the unsaturated bedrock (and potentially within the upper water bearing zone) and is released to the groundwate r flow field over time.
* The center of the F luore scien mass in groundwater, in the release area, shifted to the North. (See data for wells MW-30 and MW-3Z on Figures 7.2 and 7.3). GZA interprets these data to mean: There is more storage in the unsaturated zone in proximity to IP2-FSB , than to the South or West; and The relatively high injection rate re s ulted in more lateral spreading of the tracer than would have re su l ted from a slow, long duration release. Vertical Distribution The table prov ided below prese n ts data on the vertical distribution of F l uorescein along the center lin e of the tracer plume (see Figure 7.2 for well locations).
* The center of the F luore scien mass in groundwater, in the release area, shifted to the North. (See data for wells MW-30 and MW-3Z on Figures 7.2 and 7.3). GZA interprets these data to mean: There is more storage in the unsaturated zone in proximity to IP2-FSB , than to the South or West; and The relatively high injection rate re s ulted in more lateral spreading of the tracer than would have re su l ted from a slow, long duration release. Vertical Distribution The table prov ided below prese n ts data on the vertical distribution of F l uorescein along the center lin e of the tracer plume (see Figure 7.2 for well locations).
It presents the maximum observed concentration at each depth and the approximate concentration S) proximate to June 14, 2007. J) Data estimated for the June 14th date are b ase d on time eonccntmtion gra ph s (s ee Appendix N). 83 FLUORESCEIN CONCENTRA nONS MW-JI MW-3 2 MW-JO Dc I b Co n e. ""h Cone. Dc t h CODe. " 16001 62 49 ,000/2 74 '690 0.' 2600 '7 1 2,700 I " 24.300 1 88 167 f 11 0 2"" ,"" " 1 8 1 013 14 0 ]5.)00/6 ", 4160116 197 621/56 1600 I 0.5 -Max. cone , I COIle. pr O;t(i mat c t o 61 14/07 in IlgiL Depth -Iklow Ground S urface (Feet) ND -Not Detected MW-JJ MW-III Dc t h Co n e. Dc th Cone. 1 " *** 1 " 2.' 1 1 2.' MW-J7 Dc th Cone. " 4 7/1 0 32 L3 1 N D The available d a t a indicate the bu lk of the Fluorescein was migrating at fairly shallow depths , although not always at the water table. As anticipated (consistent with the Co nceptu al Site Model), i t also suggests the pathway becomes somewhat deeper downgradient of the injection point, likely being below the well screens at MW -33 and MW-lil. The comparatively low concentrations at MW-lll , as compared to Tritium concent r ations , likely highlights the importance of unsaturated zone migration in groundwater contaminant distributions.  
It presents the maximum observed concentration at each depth and the approximate concentration S) proximate to June 14, 2007. J) Data estimated for the June 14th date are b ase d on time eonccntmtion gra ph s (s ee Appendix N). 83 FLUORESCEIN CONCENTRA nONS MW-JI MW-3 2 MW-JO Dc I b Co n e. ""h Cone. Dc t h CODe. " 16001 62 49 ,000/2 74 '690 0.' 2600 '7 1 2,700 I " 24.300 1 88 167 f 11 0 2"" ,"" " 1 8 1 013 14 0 ]5.)00/6 ", 4160116 197 621/56 1600 I 0.5 -Max. cone , I COIle. pr O;t(i mat c t o 61 14/07 in IlgiL Depth -Iklow Ground S urface (Feet) ND -Not Detected MW-JJ MW-III Dc t h Co n e. Dc th Cone. 1 " *** 1 " 2.' 1 1 2.' MW-J7 Dc th Cone. " 4 7/1 0 32 L3 1 N D The available d a t a indicate the bu lk of the Fluorescein was migrating at fairly shallow depths , although not always at the water table. As anticipated (consistent with the Co nceptu al Site Model), i t also suggests the pathway becomes somewhat deeper downgradient of the injection point, likely being below the well screens at MW -33 and MW-lil. The comparatively low concentrations at MW-lll , as compared to Tritium concent r ations , likely highlights the importance of unsaturated zone migration in groundwater contaminant distributions.
 
7.4 TEMPORAL DISTRIB UTION OF FLUORESCEIN IN GROUNDWATER Groundwater samples were co ll ected a t regular int e rval s between February 8 and August 21, 2007 54. These data are shown on graphs prov i ded in Appendix N with selec ted infonnation s hown below. Interpretation of these graphs is complicated , beyond the n onnal difficu l ties associated w i th interpreting tracer test data in fractured rock. This i s because the tracer was not injected directly to the water tab l e , as would be more typical. Rather , the tracer was re l eased at the top of the bedrock , in the unsaturated zone , so as to better mimic the behavior of the Tritium re l ease from the cracks in the fuel pool wall; as was the primary object i ve of the tr acer test. Therefore , the tracer then entered the gro undwater regime at numerous l ocations due to unsatura t ed zone spread in g from the release point. In add ition , these numerous release points remained act i ve over a n extended period of time (months) due to storage in the unsaturated zone; see the previous subsection and Section 8.1.2 for further discus s ion. With the se li mitations noted , the follow i ng observation s/interpretation s are provided:
===7.4 TEMPORAL===
DISTRIB UTION OF FLUORESCEIN IN GROUNDWATER Groundwater samples were co ll ected a t regular int e rval s between February 8 and August 21, 2007 54. These data are shown on graphs prov i ded in Appendix N with selec ted infonnation s hown below. Interpretation of these graphs is complicated , beyond the n onnal difficu l ties associated w i th interpreting tracer test data in fractured rock. This i s because the tracer was not injected directly to the water tab l e , as would be more typical. Rather , the tracer was re l eased at the top of the bedrock , in the unsaturated zone , so as to better mimic the behavior of the Tritium re l ease from the cracks in the fuel pool wall; as was the primary object i ve of the tr acer test. Therefore , the tracer then entered the gro undwater regime at numerous l ocations due to unsatura t ed zone spread in g from the release point. In add ition , these numerous release points remained act i ve over a n extended period of time (months) due to storage in the unsaturated zone; see the previous subsection and Section 8.1.2 for further discus s ion. With the se li mitations noted , the follow i ng observation s/interpretation s are provided:
* At so me loca ti o n s, th e release to the water tab l e was rap i d. For example , at monitoring we ll located approximate l y 60 feet to the So u th of the i nj ect i o n point, the tracer arrival time SS was approximately o n e day. Conversely , at MW-30-74. located adjace n t to the injection we ll , the arrival t i me was app r ox i mately 25 da ys. See the following figures. 5 4 I n addition to the routin e sampling, s pec i fic w ells w ere sampled for a longer pe r iod of time as part of s lt ort term variabilit y te s ting (s ee Sect i on 9.0). 55 Arr i v al time s are genemlly established as the center of mas s (oft en the p ea k) of the concentration  
* At so me loca ti o n s, th e release to the water tab l e was rap i d. For example , at monitoring we ll located approximate l y 60 feet to the So u th of the i nj ect i o n point, the tracer arrival time SS was approximately o n e day. Conversely , at MW-30-74. located adjace n t to the injection we ll , the arrival t i me was app r ox i mately 25 da ys. See the following figures. 5 4 I n addition to the routin e sampling, s pec i fic w ells w ere sampled for a longer pe r iod of time as part of s lt ort term variabilit y te s ting (s ee Sect i on 9.0). 55 Arr i v al time s are genemlly established as the center of mas s (oft en the p ea k) of the concentration  
'I s. time g raph. 8 4 5 )0000 . . '" 20000 " * . , ii :s-o , >-N 1/28/07 , . I Jf29!07 J 4r.!8107 MW*32*62 , S128107 D a t e 6/2 1 107 7mm .,"'" Rai n""" .. I MW-32-62 FLOURESCEIN AND P RECIPITATION VS TIM E e ; e * 'i , *
'I s. time g raph. 8 4 5 )0000 . . '" 20000 " * . , ii :s-o , >-N 1/28/07 , . I Jf29!07 J 4r.!8107 MW*32*62 , S128107 D a t e 6/2 1 107 7mm .,"'" Rai n""" .. I MW-32-62 FLOURESCEIN AND P RECIPITATION VS TIM E e ; e * 'i , *
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* Because th e l ocations and times of releases from the unsaturated zone to the wate r table a r e not known , it is difficu l t , at best, to estimate tracer transport velocities.
* Because th e l ocations and times of releases from the unsaturated zone to the wate r table a r e not known , it is difficu l t , at best, to estimate tracer transport velocities.
However , as shown below, the ave ra ge value appears to be on the order of 4 to 9 feet/day.
However , as shown below, the ave ra ge value appears to be on the order of 4 to 9 feet/day.
Welll..ocation Time of Time Distance (Feet) Velocity (FtiDay) Arrival Date (Days) MW-33 3-5-07 25 1 10 4.4 MW-III 3-14.{)7 34 145 4.3 MW-37-22" 4-1 0.{)7 6 1 300 4.9 MW-55 3-28-07 48 240 5 to 9 FLOURESCEIN ARRIVAL TIMES AND TRANSPORT VELOCITIES 56 The sou rce o f the Fluorescei n observed in MW 37-22 i s uncertain.  
Welll..ocation Time of Time Distance (Feet) Velocity (FtiDay) Arrival Date (Days) MW-33 3-5-07 25 1 10 4.4 MW-III 3-14.{)7 34 145 4.3 MW-37-22" 4-1 0.{)7 6 1 300 4.9 MW-55 3-28-07 48 240 5 to 9 FLOURESCEIN ARRIVAL TIMES AND TRANSPORT VELOCITIES 56 The sou rce o f the Fluorescei n observed in MW 37-22 i s uncertain.
[t may be e n tire l y from m ig rat ion i n the bedrock s l ight[y to th e Nonh of that location. or may be due , in part or in whol e, t o transpon via s torm drain s and in the backfill around the Discharge Canal walls. See Section 4 . .5. 57 Th e calculatcd veloc i ty depends on which flow path is selecte d. Us in g a flow path fr om MW-32 (day of rele ase) t o MW-55. the calculated v elocit y is approximately 5 fe et/day. Us in g a flow path between MW-S3 and MW-55 (t h e Strontium flow path) th e ea[cu[ated velocity is 9 fcct/day.
[t may be e n tire l y from m ig rat ion i n the bedrock s l ight[y to th e Nonh of that location. or may be due , in part or in whol e, t o transpon via s torm drain s and in the backfill around the Discharge Canal walls. See Section 4 . .5. 57 Th e calculatcd veloc i ty depends on which flow path is selecte d. Us in g a flow path fr om MW-32 (day of rele ase) t o MW-55. the calculated v elocit y is approximately 5 fe et/day. Us in g a flow path between MW-S3 and MW-55 (t h e Strontium flow path) th e ea[cu[ated velocity is 9 fcct/day.
86 Also note, the carbon sampler data supports these estimates to the extent that no evidence of significant Fluorescein migration between aqueous sampling events was found. The observed tracer migration rates are approximately liS to 1110 the calculated groundwater velocity of SS ftlday , see Section 6.7.2. GZA attributes the difference between the "observed" and the "computed" transport velocities primarily to the effective porosity of the bedrock. That is, we believe the actual effective porosity is considerably larger (more on the order of 0.003) than that computed from our analyses of the Pumping Test (see Section 6.5.1); the aquifer response testing (see Section 6.6.1); or the hydraulic aperture of the bedrock (see Section 6.5.2). This slower transport velocity helps to explain the observed long term temporal variations in both tracer and Tritium groundwater concentrations, and supports the use of a porous media flow model. As a practical matter, this slower transport velocity encourages the use of conventional groundwater monitoring frequencies (quarterly or longer); and reduces concerns over the possibility of high concentrations of contaminants migrating by a monitoring location between sampling events. 7.5 FLUORESCEIN IN DRAINS, SUMPS AND THE DISCHARGE CANAL Fluorescein was also detected within storm drain catch basins, foundation drain sumps, and the Discharge Canal. Fluorescein was detected in manholes MH-4, MH-S and MH-6. In reviewing these data, note:
86 Also note, the carbon sampler data supports these estimates to the extent that no evidence of significant Fluorescein migration between aqueous sampling events was found. The observed tracer migration rates are approximately liS to 1110 the calculated groundwater velocity of SS ftlday , see Section 6.7.2. GZA attributes the difference between the "observed" and the "computed" transport velocities primarily to the effective porosity of the bedrock. That is, we believe the actual effective porosity is considerably larger (more on the order of 0.003) than that computed from our analyses of the Pumping Test (see Section 6.5.1); the aquifer response testing (see Section 6.6.1); or the hydraulic aperture of the bedrock (see Section 6.5.2). This slower transport velocity helps to explain the observed long term temporal variations in both tracer and Tritium groundwater concentrations, and supports the use of a porous media flow model. As a practical matter, this slower transport velocity encourages the use of conventional groundwater monitoring frequencies (quarterly or longer); and reduces concerns over the possibility of high concentrations of contaminants migrating by a monitoring location between sampling events. 7.5 FLUORESCEIN IN DRAINS, SUMPS AND THE DISCHARGE CANAL Fluorescein was also detected within storm drain catch basins, foundation drain sumps, and the Discharge Canal. Fluorescein was detected in manholes MH-4, MH-S and MH-6. In reviewing these data, note:
Line 168: Line 154:
* In our opin i on, the trace r test, in conjunction with the Tritium release, indicates that the existing network of monitoring wells can be used to monitor groundwater at IP EC. " It i s noted that Fluorescein is the primary colorant in automobile coolant anli*freezc.
* In our opin i on, the trace r test, in conjunction with the Tritium release, indicates that the existing network of monitoring wells can be used to monitor groundwater at IP EC. " It i s noted that Fluorescein is the primary colorant in automobile coolant anli*freezc.
Therefore, leak s from cars to parking lot/road s urfac es can impact surface water bodies via stonn drain sys t ems and/or direct runoff. Fluores<:cin was d e tect ed in the Discharge Canal prior to initiation of the traccr injt'Ction.
Therefore, leak s from cars to parking lot/road s urfac es can impact surface water bodies via stonn drain sys t ems and/or direct runoff. Fluores<:cin was d e tect ed in the Discharge Canal prior to initiation of the traccr injt'Ction.
further indicating it s prcsence as background. 88
further indicating it s prcsence as background. 88 8.0 CONTAMINANT SOURCES AND RELEASE MECHANISMS GZA conducted a review of availab l e co n s truct ion drawings , aerial photographs, prior reports , and documented releases , and interviewed Entergy pe r sonne l to assess potential contaminant sources. T he primary S9 radiological sources identified were the Uni t 2 Spent Fue l Poo l (IP2-SFP) located i n the Un it 2 Fuel Storage Bui ldin g (IP2-FSB) and the Unit I Fuel Pool Comp lex (IP I-S FPs)'" in the U nit I Fuel Handling Bu ilding (IPI-FHB. These two di s tinct so urces are responsible fo r the Uni t 2 plume a n d the Unit 1 p l ume, respectively. No release was iden tified in th e Unit 3 area. The absence of U ni t 3 sou rc es is attribu t ed to the design upgrades incorporated in the more recently constructed IP3*SFP. These upg rades include a stainless s teel liner (consistent with Unit 2 but not incl uded in th e Un i t 1 design) and an add iti ona l , seco nd ary l eak. detection drain system not included in the Unit 2 design. The id e ntifi ed spe cific so urc e mechanism s associa ted with the IP 2-SFP and the I P I-SFPs are di sc u ssed in the fo ll ow i ng sec ti o n s. We have segregated thi s sou rce discussion b ase d on primary co n tami n an t type; those cl assi fied as pr im arily Tritium sources, as associated with the U nit 2 pl u m e, and those classified as primarily Strontium sources, as associated with the Unit 1 plume. While the groundwate r plumes emanating from their respec ti ve source areas can clearly be characterized using eac h plume's primary constituent, radionuclides other than Tritium and Strontium a l so exist to a limit ed exten t and are fu ll y a ddr essed within the context of th e U nit 2 and U nit I plume disc u ssions 61* D iscussio n of the two primary sou r ce types will be parsed fu rth er as f o llo ws:
 
===8.0 CONTAMINANT===
 
SOURCES AND RELEASE MECHANISMS GZA conducted a review of availab l e co n s truct ion drawings , aerial photographs, prior reports , and documented releases , and interviewed Entergy pe r sonne l to assess potential contaminant sources. T he primary S9 radiological sources identified were the Uni t 2 Spent Fue l Poo l (IP2-SFP) located i n the Un it 2 Fuel Storage Bui ldin g (IP2-FSB) and the Unit I Fuel Pool Comp lex (IP I-S FPs)'" in the U nit I Fuel Handling Bu ilding (IPI-FHB. These two di s tinct so urces are responsible fo r the Uni t 2 plume a n d the Unit 1 p l ume, respectively. No release was iden tified in th e Unit 3 area. The absence of U ni t 3 sou rc es is attribu t ed to the design upgrades incorporated in the more recently constructed IP3*SFP. These upg rades include a stainless s teel liner (consistent with Unit 2 but not incl uded in th e Un i t 1 design) and an add iti ona l , seco nd ary l eak. detection drain system not included in the Unit 2 design. The id e ntifi ed spe cific so urc e mechanism s associa ted with the IP 2-SFP and the I P I-SFPs are di sc u ssed in the fo ll ow i ng sec ti o n s. We have segregated thi s sou rce discussion b ase d on primary co n tami n an t type; those cl assi fied as pr im arily Tritium sources, as associated with the U nit 2 pl u m e, and those classified as primarily Strontium sources, as associated with the Unit 1 plume. While the groundwate r plumes emanating from their respec ti ve source areas can clearly be characterized using eac h plume's primary constituent, radionuclides other than Tritium and Strontium a l so exist to a limit ed exten t and are fu ll y a ddr essed within the context of th e U nit 2 and U nit I plume disc u ssions 61* D iscussio n of the two primary sou r ce types will be parsed fu rth er as f o llo ws:
* Th e Uni t 2 (Tritiwn) plume so urce analyses will be split i nto: 1) "d irect sources" defined as releases to the exterior of Systems Structures and Components (SSCs); and 2) " indirect sto r ag e sources" rel ated to natur a l hydrogeologic mechanism s i n t he unsaturated zo n e (such as adsorp tion and dead-end f r actures) and poten ti al anthropogenic contaminant retention mechanisms (such as certain subsurface foundation construc t ion detail s);
* Th e Uni t 2 (Tritiwn) plume so urce analyses will be split i nto: 1) "d irect sources" defined as releases to the exterior of Systems Structures and Components (SSCs); and 2) " indirect sto r ag e sources" rel ated to natur a l hydrogeologic mechanism s i n t he unsaturated zo n e (such as adsorp tion and dead-end f r actures) and poten ti al anthropogenic contaminant retention mechanisms (such as certain subsurface foundation construc t ion detail s);
* The Uni t I (Stron t ium) plume so urce analyses will be split i nto the mechani s m s specific to the i ndi v idual plum e fl ow paths identified.
* The Uni t I (Stron t ium) plume so urce analyses will be split i nto the mechani s m s specific to the i ndi v idual plum e fl ow paths identified.
S9 1 n addi t ion to sources that d i rectl y impac t g rou ndwa t er, atmospheric deposition from pennined air discharges was a lso ident i fied as a potentia l source of diffuse. low l eve l Tritium impact to t h e groundwa t e r. 60 Al l of the pools in the IPI-SFPs c ontai ne d radio n uclides in t h e past. How ever. onl y the West pool currently co n tains any remaining fuel rod s and a ll of t he other IPI poo l s have been dra ined of wate r. It i s also noted that the U ni t I West pool has been u nd ergo ing increased proce ssi ng to sign ificantly reduce the amount of radioactive material in the pools. Once fuel is TertlQved , th e IPI-SF P s w i l l no longe r constitu t e an active source of g roun dwater c ontamination.
S9 1 n addi t ion to sources that d i rectl y impac t g rou ndwa t er, atmospheric deposition from pennined air discharges was a lso ident i fied as a potentia l source of diffuse. low l eve l Tritium impact to t h e groundwa t e r. 60 Al l of the pools in the IPI-SFPs c ontai ne d radio n uclides in t h e past. How ever. onl y the West pool currently co n tains any remaining fuel rod s and a ll of t he other IPI poo l s have been dra ined of wate r. It i s also noted that the U ni t I West pool has been u nd ergo ing increased proce ssi ng to sign ificantly reduce the amount of radioactive material in the pools. Once fuel is TertlQved , th e IPI-SF P s w i l l no longe r constitu t e an active source of g roun dwater c ontamination.
61 C ontam inants associated wi t h the U nit 2 leak were found to be essentia ll y comprised of Tritium. lhe Un it I plume i s comprised primari l y of Stronti u m, but also i n cl ude s Tri t ium and sporadic observation ofCesium-137 , Nickel-63 and Coba lt-60 at low levels in some well s downgradicnt of the IPI-SFP (see Figure 8.3). Ente r gy account s fo r all radionuclide s that can be expected to r each th e river in th ei r r equi r ed regulatory r epo nin g of es timated do se impact. 89 8.1 UNIT 2 SOURCE AREA The majority of the Tritium detected in the groundwater at the Site was traced to lP2-SFP. This pool contains water with maximum Tritium concentrations of up to 40,000,000 pCiIL'2 The highest Tritium levels measured in groundwater (up to 601 , 000 pCi1L 63) were detected early in the investigation at MW-30. This location is immediately adjace nt to IP2*SFP and directly below the 2005 s hrink age cracks. As s h own on Figure S.l, the Tritium contamination  
61 C ontam inants associated wi t h the U nit 2 leak were found to be essentia ll y comprised of Tritium. lhe Un it I plume i s comprised primari l y of Stronti u m, but also i n cl ude s Tri t ium and sporadic observation ofCesium-137 , Nickel-63 and Coba lt-60 at low levels in some well s downgradicnt of the IPI-SFP (see Figure 8.3). Ente r gy account s fo r all radionuclide s that can be expected to r each th e river in th ei r r equi r ed regulatory r epo nin g of es timated do se impact. 89 8.1 UNIT 2 SOURCE AREA The majority of the Tritium detected in the groundwater at the Site was traced to lP2-SFP. This pool contains water with maximum Tritium concentrations of up to 40,000,000 pCiIL'2 The highest Tritium levels measured in groundwater (up to 601 , 000 pCi1L 63) were detected early in the investigation at MW-30. This location is immediately adjace nt to IP2*SFP and directly below the 2005 s hrink age cracks. As s h own on Figure S.l, the Tritium contamination
(" the plume 64 ,,) then tracks with downgradient groundwater flow 6S through the Unit 2 T ran sfonne r Yard, und e r the Discharge Canal and discharges t o the river 66 between the Unit 2 and Un it 1 intake struct ures. During review of the following sections, it is important to recognize that only s mall quantities of pool leakage (on the order of liters/day) will result in the Tritium groundwater plume observed on the Site. 62 In contrast.
(" the plume 64 ,,) then tracks with downgradient groundwater flow 6S through the Unit 2 T ran sfonne r Yard, und e r the Discharge Canal and discharges t o the river 66 between the Unit 2 and Un it 1 intake struct ures. During review of the following sections, it is important to recognize that only s mall quantities of pool leakage (on the order of liters/day) will result in the Tritium groundwater plume observed on the Site. 62 In contrast.
thc levels of Tritium in the Unit I West pool arc only on the order of 250.000 pC il L. Strontium concentration s in IP2*SFP are on the order of 500 pCilL. 6) The 60 1.000 pCi/L Tritium concentration was measured during packer testing of the open borehole prior to multi*levcl completion. This value is therefore actually a lower bound estimate for depth.specifie Tritium concentration s lit that time. If the multi*level samp lin g instrumentation could have been completed prior to obtaining these da ta (not po ss ible because the packer testing was required to design the multi* level installation), samples would have yielded equal or higher co n ce ntrations.
thc levels of Tritium in the Unit I West pool arc only on the order of 250.000 pC il L. Strontium concentration s in IP2*SFP are on the order of 500 pCilL. 6) The 60 1.000 pCi/L Tritium concentration was measured during packer testing of the open borehole prior to multi*levcl completion. This value is therefore actually a lower bound estimate for depth.specifie Tritium concentration s lit that time. If the multi*level samp lin g instrumentation could have been completed prior to obtaining these da ta (not po ss ible because the packer testing was required to design the multi* level installation), samples would have yielded equal or higher co n ce ntrations.
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Therefore, legacy groundwater contamination does not have to be located immediately downgradient of the storm drain system (as exemplified by the Strontium found in MW-39 and tracer in MW-42). While three isopleths are shown on Figure 8.2, we believe it is possible that other areas in the general vicinity of this piping may exhibit similar groundwater concentrations.
Therefore, legacy groundwater contamination does not have to be located immediately downgradient of the storm drain system (as exemplified by the Strontium found in MW-39 and tracer in MW-42). While three isopleths are shown on Figure 8.2, we believe it is possible that other areas in the general vicinity of this piping may exhibit similar groundwater concentrations.
We have a l so concluded that the lower concentrations of Strontium detected in monitoring wells further downgradient , in the Unit 3 area, are also due to these historic, legacy storm drain releases.
We have a l so concluded that the lower concentrations of Strontium detected in monitoring wells further downgradient , in the Unit 3 area, are also due to these historic, legacy storm drain releases.
113
113 9.0 GROUNDWATER CONTAMINATION FATE AND TRANSPORT Strontium (the U nit I plume) and Tritium (the Unit 2 plume) are the radionuclides we used to map the groundwater contamination.
 
===9.0 GROUNDWATER===
 
CONTAMINATION FATE AND TRANSPORT Strontium (the U nit I plume) and Tritium (the Unit 2 plume) are the radionuclides we used to map the groundwater contamination.
The investigation focused on these two contaminants because they describe the relevant plume migration pathways, and the other Site groundwater contaminants are encompassed within these plumes. While radionuclide contaminants have been detected at various locations on the Site, both the on-Site and off-Site analytical testing, as well as the groundwater elevation data, demonstrate that groundwater contaminants are not flowing off-Site and do not flow to the North, East or South. Groundwater flow and thus contaminant transport is West to the Hudson River via: 1) groundwater discharge directly to the river; 2) groundwater discharge to the cooling water canal, and 3) groundwater infiltration into stonn dra i ns, and then to the canaL The primary source of groundwater Tr itium contamination i s the IP2-SFP. The resulting Unit 2 plume extends to the West , towards the river , as described in subsequent sections.
The investigation focused on these two contaminants because they describe the relevant plume migration pathways, and the other Site groundwater contaminants are encompassed within these plumes. While radionuclide contaminants have been detected at various locations on the Site, both the on-Site and off-Site analytical testing, as well as the groundwater elevation data, demonstrate that groundwater contaminants are not flowing off-Site and do not flow to the North, East or South. Groundwater flow and thus contaminant transport is West to the Hudson River via: 1) groundwater discharge directly to the river; 2) groundwater discharge to the cooling water canal, and 3) groundwater infiltration into stonn dra i ns, and then to the canaL The primary source of groundwater Tr itium contamination i s the IP2-SFP. The resulting Unit 2 plume extends to the West , towards the river , as described in subsequent sections.
T he source of the Strontium contamination is the IP I-SFPs. Previous conceptual models, based on infonnation presented in prior reports, indicated that releases from the IPl-SFPs were likely captured through collection of groundwater from the Uni t 1 foundation drain systems. However, based upon groundwater samp li ng and tracer tes t data, we now know that the Unit 1 foundation drain system , particularly the NCO, i s not hydraulically containing all groundwater contamination i n this area (see Section 8.0). GZA's understanding of the Tritium sou rc e and Strontium source are discussed in more detail in Section 8.0. The p l umes described on the figures in the following subsections are based on: 1) the isopleths bounding the maximum concentrations , as representative of "worst case conditions" I IS (Figures 8.1 and 8.2); and 2) the most recent laboratory data collected through August 2007, as representative of current conditions (Figures 9.1, 9.2, 9.3 and 9.4). While the figures showing upper bound isopleth concentrations do not show actual conditions, we believe these graphics are useful in developing an understanding of groundwater and radionuclide migration pathways.
T he source of the Strontium contamination is the IP I-SFPs. Previous conceptual models, based on infonnation presented in prior reports, indicated that releases from the IPl-SFPs were likely captured through collection of groundwater from the Uni t 1 foundation drain systems. However, based upon groundwater samp li ng and tracer tes t data, we now know that the Unit 1 foundation drain system , particularly the NCO, i s not hydraulically containing all groundwater contamination i n this area (see Section 8.0). GZA's understanding of the Tritium sou rc e and Strontium source are discussed in more detail in Section 8.0. The p l umes described on the figures in the following subsections are based on: 1) the isopleths bounding the maximum concentrations , as representative of "worst case conditions" I IS (Figures 8.1 and 8.2); and 2) the most recent laboratory data collected through August 2007, as representative of current conditions (Figures 9.1, 9.2, 9.3 and 9.4). While the figures showing upper bound isopleth concentrations do not show actual conditions, we believe these graphics are useful in developing an understanding of groundwater and radionuclide migration pathways.
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Also note that flow in the liS It is noted that these li g ures (F igures 8.1 and 8.2) do not show actual plumes: the isoplcths present contoured upper bound concentrat i ons for samples taken at any time and any depth at a particular location. rather than a 3-dimensional snaps hot of concentrations at a single time. As such. these "plumes" are an overstatement of the contaminant levels existing at any time. It should also be noted that the lightest co lor ed contour inh:rval begin s at one-quarter the USEPA drinking water standard. While drinking water standa rds do not apply to the Site (there are no drinking water well s on or proximate to the Site). they do provide a recognize d. and highly conservative benchmark for comparison purposes).
Also note that flow in the liS It is noted that these li g ures (F igures 8.1 and 8.2) do not show actual plumes: the isoplcths present contoured upper bound concentrat i ons for samples taken at any time and any depth at a particular location. rather than a 3-dimensional snaps hot of concentrations at a single time. As such. these "plumes" are an overstatement of the contaminant levels existing at any time. It should also be noted that the lightest co lor ed contour inh:rval begin s at one-quarter the USEPA drinking water standard. While drinking water standa rds do not apply to the Site (there are no drinking water well s on or proximate to the Site). they do provide a recognize d. and highly conservative benchmark for comparison purposes).
Lower. but positive, detections outside thc colored conto u rs arc sho wn as colored data blocks. See figure for additional notes, 114 unsaturated zone plays an important role in both the timing of releases to the water table and in the spread ing of contaminants.
Lower. but positive, detections outside thc colored conto u rs arc sho wn as colored data blocks. See figure for additional notes, 114 unsaturated zone plays an important role in both the timing of releases to the water table and in the spread ing of contaminants.
Based upon the results of aZA's geostructural analysis, the extent of contaminated groundwater , the 72 hour Pumping Test , the tracer test and tidal response tests, we believe that the bedrock underneath the Site i s sufficiently fractured and interconnected to allow the Site to be viewed as a non-homogenous and anisotropic porous media. Based on this finding, and because advection is the controlling transport mechanism, groundwater flow, and consequently contaminant migration in the saturated zone, is nearly perpendicular to groundwater contours on the scale of the Site. 9.1 AREAL EXTENT OF GROUNDWATER CONT AMINA nON Based on measured tracer velocities (4 to 9 feet per day; see Section 7.4), the limited di s tance s between release areas and the river (typically less than 400 feet), the age of the plumes (years), and recent interdictions, we believe contaminant plumes have reached their maximum size and are currently decreasing in size_ Co nsequently , our reporting in this section focuses on observed, "current" conditions (the summer of 2007). That is, we saw no need to mathematically predict future conditions.  
Based upon the results of aZA's geostructural analysis, the extent of contaminated groundwater , the 72 hour Pumping Test , the tracer test and tidal response tests, we believe that the bedrock underneath the Site i s sufficiently fractured and interconnected to allow the Site to be viewed as a non-homogenous and anisotropic porous media. Based on this finding, and because advection is the controlling transport mechanism, groundwater flow, and consequently contaminant migration in the saturated zone, is nearly perpendicular to groundwater contours on the scale of the Site. 9.1 AREAL EXTENT OF GROUNDWATER CONT AMINA nON Based on measured tracer velocities (4 to 9 feet per day; see Section 7.4), the limited di s tance s between release areas and the river (typically less than 400 feet), the age of the plumes (years), and recent interdictions, we believe contaminant plumes have reached their maximum size and are currently decreasing in size_ Co nsequently , our reporting in this section focuses on observed, "current" conditions (the summer of 2007). That is, we saw no need to mathematically predict future conditions.
 
9.2 DEPTH OF GROUNDWATER CONT AMINA nON Because of the location of Indian Point on the edge of the Hudson River, the width of the river, and the nature of contaminants of potential concern, groundwater flow patterns (and, consequently , contaminant pathways) are relatively shallow. Furthennore, as discussed in Section 6.0, the upper portion of the aquifer (typically, the upper 40 feet of the bedrock) has a higher average hydraulic conductivity than the deeper portions of the bedrock. Consequently, the center of mass of the contaminated groundwater is s hallow. Figures 9.1 and 9.2 are cross sections which s how the approximate vertical distribution of Tritium and Strontium, near the center lines of the Unit 1 and Unit 2 plumes , in the summer of 2007 ("current conditions
===9.2 DEPTH===
OF GROUNDWATER CONT AMINA nON Because of the location of Indian Point on the edge of the Hudson River, the width of the river, and the nature of contaminants of potential concern, groundwater flow patterns (and, consequently , contaminant pathways) are relatively shallow. Furthennore, as discussed in Section 6.0, the upper portion of the aquifer (typically, the upper 40 feet of the bedrock) has a higher average hydraulic conductivity than the deeper portions of the bedrock. Consequently, the center of mass of the contaminated groundwater is s hallow. Figures 9.1 and 9.2 are cross sections which s how the approximate vertical distribution of Tritium and Strontium, near the center lines of the Unit 1 and Unit 2 plumes , in the summer of 2007 ("current conditions
"). In reviewing these figures, note that Strontium was not found below a depth of 105 feet in MW-67. We attribute the low concentrations of Trit ium below a depth of 200 feet at this location, at least in part, to the downward migration of Tritium during our inve s tigations.
"). In reviewing these figures, note that Strontium was not found below a depth of 105 feet in MW-67. We attribute the low concentrations of Trit ium below a depth of 200 feet at this location, at least in part, to the downward migration of Tritium during our inve s tigations.
For example, by nece ssi ty , well RW-J was an open wellbore for a period of time ll6 which allowed vertical groundwater migration , a lo ng an art ificial preferred pathway, deeper than would occur along ambient flow paths. 9.3 UNIT 2 TRITIUM PLUME BERA VIOR As sho wn on Figures 8.1 and 9.3, the Unit 2 plume exhibits T ritium concentration s originating at the fP2-SFP. The higher concentration isopleths are shown around the entire 116 RW-l is located immediately below the 2005 shrinkage crack leak (high Tritium concentrations in shallow groundwater).
For example, by nece ssi ty , well RW-J was an open wellbore for a period of time ll6 which allowed vertical groundwater migration , a lo ng an art ificial preferred pathway, deeper than would occur along ambient flow paths. 9.3 UNIT 2 TRITIUM PLUME BERA VIOR As sho wn on Figures 8.1 and 9.3, the Unit 2 plume exhibits T ritium concentration s originating at the fP2-SFP. The higher concentration isopleths are shown around the entire 116 RW-l is located immediately below the 2005 shrinkage crack leak (high Tritium concentrations in shallow groundwater).
This well had remained as an open w el1bo re for periods o f time in preparation for and during: I) the drilling of the wellbore;  
This well had remained as an open w el1bo re for periods o f time in preparation for and during: I) the drilling of the wellbore;
: 2) the packer testing: 3) the geophysical logg ing: and , 4) the Pumpi ng Test. During th ese ti mes. vertically downward grad ien ts likel y mov cd some Tritium to level s deeper than it would otherwise exist. When possible, this wellborc h as been sea l ed ove r its entire Icngth using a Flute Liner Systcm. 115 pool area so as to incl u de the location of the shrinkage crack leak in the South pool wall, the loca tion of the 1992 leak on the East wall, and the location of the weld imperfection in the North wall of the [P2 Transfer Canal. We believe the core of the plume, as shown, is relatively narrow where Tritium flows downgradient (westerly) to and MW-III in the Transformer yard 1l7. This delineation is based on: 1) the degree of connection ll8 observed from MW-30 to MW-33 (as compared with that from MW-30 to MW-31 andlor as being indicative of a zone of higher hydraulic conductivity limiting lateral dispersion; and 2) the localized increased thickness of the saturated soil in the vicinity of MW -III (see Figure 1.3) which likely behaves as a local groundwater sink/source for wes t erly bedrock groundwater flow, prior to entering the associated backfill of the Discharge Canal. " I I ", * -. . . -.-.-_ .. -; * !. Hudson .-.-' I I ' , [l.
: 2) the packer testing: 3) the geophysical logg ing: and , 4) the Pumpi ng Test. During th ese ti mes. vertically downward grad ien ts likel y mov cd some Tritium to level s deeper than it would otherwise exist. When possible, this wellborc h as been sea l ed ove r its entire Icngth using a Flute Liner Systcm. 115 pool area so as to incl u de the location of the shrinkage crack leak in the South pool wall, the loca tion of the 1992 leak on the East wall, and the location of the weld imperfection in the North wall of the [P2 Transfer Canal. We believe the core of the plume, as shown, is relatively narrow where Tritium flows downgradient (westerly) to and MW-III in the Transformer yard 1l7. This delineation is based on: 1) the degree of connection ll8 observed from MW-30 to MW-33 (as compared with that from MW-30 to MW-31 andlor as being indicative of a zone of higher hydraulic conductivity limiting lateral dispersion; and 2) the localized increased thickness of the saturated soil in the vicinity of MW -III (see Figure 1.3) which likely behaves as a local groundwater sink/source for wes t erly bedrock groundwater flow, prior to entering the associated backfill of the Discharge Canal. " I I ", * -. . . -.-.-_ .. -; * !. Hudson .-.-' I I ' , [l.
* R i ver " -'. .  
* R i ver " -'. .  
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Once on the western side of the Discharge C anal, as evidenced by groundwater elevations and Tritium concentr a tions in MW-37 , -49 , and 117   
Once on the western side of the Discharge C anal, as evidenced by groundwater elevations and Tritium concentr a tions in MW-37 , -49 , and 117   
-67, groundwater flow and Tritium migration is to the Hudson River, via both bedrock and unconsolidated material along the riverfront.
-67, groundwater flow and Tritium migration is to the Hudson River, via both bedrock and unconsolidated material along the riverfront.
The spe cific flow path for the Tritium detected in MW-37-22 (located in the fill on the West side of the canal) is not certain. It is however associated with either: 1) upward groundwater flow into the backfill from the bedrock beneath the canal, as supported by the upward vertical hydraulic gradients;  
The spe cific flow path for the Tritium detected in MW-37-22 (located in the fill on the West side of the canal) is not certain. It is however associated with either: 1) upward groundwater flow into the backfill from the bedrock beneath the canal, as supported by the upward vertical hydraulic gradients;
: 2) groundwater flow into the blast rock fill on the West side of the canal, with northerly flow in the fill to, and around the North end of the canal and then southerly along the East side of the canal to MW-37; and/or 3) exfiltration from the stormwater piping between MH-4 and MH-4A into the fill on the western side of the canal, with a similar flow path as described in 2). See Section 7.5 for additional information.
: 2) groundwater flow into the blast rock fill on the West side of the canal, with northerly flow in the fill to, and around the North end of the canal and then southerly along the East side of the canal to MW-37; and/or 3) exfiltration from the stormwater piping between MH-4 and MH-4A into the fill on the western side of the canal, with a similar flow path as described in 2). See Section 7.5 for additional information.
Regardless of the upstream flow path to MW-37-22, the groundwater flow direction from this location is westerly toward the Hudson River. Also note that the exact pathway to this location does not change the results of the groundwater flux calculations to be used in radiologic dose impact assessments.
Regardless of the upstream flow path to MW-37-22, the groundwater flow direction from this location is westerly toward the Hudson River. Also note that the exact pathway to this location does not change the results of the groundwater flux calculations to be used in radiologic dose impact assessments.
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,-, II: .-. -.-' r UNIT 2) -. -. .-.' * .-. -. -----.. ' .-* ... _ .. -. -I " '. -..... . . .. : ..... -E' ! \ \ ...... * "'" _. *** '; : .. .. * !. -.... I. * .', . .... . -, .
,-, II: .-. -.-' r UNIT 2) -. -. .-.' * .-. -. -----.. ' .-* ... _ .. -. -I " '. -..... . . .. : ..... -E' ! \ \ ...... * "'" _. *** '; : .. .. * !. -.... I. * .', . .... . -, .
* 1.-.. r...., -----. I * ...... * * -* -* H udson c'-' r--''''"e;'' I." 1.1 -r .. " .... R iv er ... ,. ...... CURRENT UNIT I PLUME ,. -L I However , because of the timing of the interdictions and, we believe, the slower groundwater transport rates for Strontium, overa ll the Unit 1 plume has not decayed to the extent the Unit 2 plume has decayed (see Section 9.4.1). In fact, due to what we attribute to short tcnn Strontium fluctuations , at six of the well locations within the Unit I plume, the highest Strontium groundwater concentrations were observed during the last project sampling event (see the following table for additiona l detail). In reviewing both figures , note th at they show what we believe are conservative estimates of the lateral distribution of the higher (25 pCi/L) Strontium g roundwat er concentrations.
* 1.-.. r...., -----. I * ...... * * -* -* H udson c'-' r--''''"e;'' I." 1.1 -r .. " .... R iv er ... ,. ...... CURRENT UNIT I PLUME ,. -L I However , because of the timing of the interdictions and, we believe, the slower groundwater transport rates for Strontium, overa ll the Unit 1 plume has not decayed to the extent the Unit 2 plume has decayed (see Section 9.4.1). In fact, due to what we attribute to short tcnn Strontium fluctuations , at six of the well locations within the Unit I plume, the highest Strontium groundwater concentrations were observed during the last project sampling event (see the following table for additiona l detail). In reviewing both figures , note th at they show what we believe are conservative estimates of the lateral distribution of the higher (25 pCi/L) Strontium g roundwat er concentrations.
125 ANALYSIS OF STRONTIUM CONCENTRATIONS OVER TIME Max. Monitoring Currene) Elapsed Time Current Observed (I) Well Strontium between Max. Cone. As Strontium Concentration and Current P erce n t of Concent ratio n (pCi/L) Concentrations Maximum _(PCuL) (day,) 110 MW-42 20.1 490 18 ,0) 37 MW*53* 37 0 100 3.6 MW-47* 3.6 0 100 2.7 MW-56 2.4 332 89 26.8 UI-CSS* 26.8 0 100 21.9 MW-54 19.2 88 88 40.4 MW-55 34.0 263 84 45.5 MW-57 3 7.9 44 83 5.0 MW-36 2.3 483 46 29.8 MW-3 7 23.3 40 78 31 MW-50* 31 0 100 25.6 MW49* 25.6 0 100 19.1 MW-67"" 19.1 0 100** -6.2 MW-66"" 6.2 0 100 it Cu rr ent concentration is the maximum concentration of sam ple s analyzed at thi s monitoring well . .. Only one sample analyzed.  
125 ANALYSIS OF STRONTIUM CONCENTRATIONS OVER TIME Max. Monitoring Currene) Elapsed Time Current Observed (I) Well Strontium between Max. Cone. As Strontium Concentration and Current P erce n t of Concent ratio n (pCi/L) Concentrations Maximum _(PCuL) (day,) 110 MW-42 20.1 490 18 ,0) 37 MW*53* 37 0 100 3.6 MW-47* 3.6 0 100 2.7 MW-56 2.4 332 89 26.8 UI-CSS* 26.8 0 100 21.9 MW-54 19.2 88 88 40.4 MW-55 34.0 263 84 45.5 MW-57 3 7.9 44 83 5.0 MW-36 2.3 483 46 29.8 MW-3 7 23.3 40 78 31 MW-50* 31 0 100 25.6 MW49* 25.6 0 100 19.1 MW-67"" 19.1 0 100** -6.2 MW-66"" 6.2 0 100 it Cu rr ent concentration is the maximum concentration of sam ple s analyzed at thi s monitoring well . .. Only one sample analyzed.
(1) Any depth , any event , at the indicated location.  
(1) Any depth , any event , at the indicated location.
(2) Any depth , on the date of the la st project sampli n g event , at the indicated location (3) It should be noted thai the latest data just recently received (well after the report data-cut-otf
(2) Any depth , on the date of the la st project sampli n g event , at the indicated location (3) It should be noted thai the latest data just recently received (well after the report data-cut-otf
-date of August 31, 2007) for MW-42 s hows a n increase to 46 pC il L. 126 10.0 FINDINGS AND CONCLUSIONS At no time have analyses of existing Site conditions yie ld ed any indication of potential adverse environmental o r health risk , as assessed by Entergy as well as the principal regulatory authorities.
-date of August 31, 2007) for MW-42 s hows a n increase to 46 pC il L. 126 10.0 FINDINGS AND CONCLUSIONS At no time have analyses of existing Site conditions yie ld ed any indication of potential adverse environmental o r health risk , as assessed by Entergy as well as the principal regulatory authorities.
In fact, rad i o logical assessme nt s have consisten t ly s hown that the releases to the environment are a s mall perce nt age of regulatory limits , and no threat to public health or safety. In this regard, it is also important to note that the groundwater i s not used as a sourc e of drinking water on or near the Site. Consisten t with the purpose of the inve st i gat i ons , we have deve l oped s ix major supporting conclusions which are described in the fo ll owi n g su b sect i ons. Based on our findings and conclusions, we are recommending completion of source interdiction measures with Monitored Natural Attenuat i on as the preferred remedial measure. Refer to Section 11.0 for more information, includin g our reasons for making this recommendation. 10.1 NATURE AND EXTENT OF CONTAMINANT MIGRATION The primary groundwater radiological contaminants of int e re st are Tritium and Strontium.
In fact, rad i o logical assessme nt s have consisten t ly s hown that the releases to the environment are a s mall perce nt age of regulatory limits , and no threat to public health or safety. In this regard, it is also important to note that the groundwater i s not used as a sourc e of drinking water on or near the Site. Consisten t with the purpose of the inve st i gat i ons , we have deve l oped s ix major supporting conclusions which are described in the fo ll owi n g su b sect i ons. Based on our findings and conclusions, we are recommending completion of source interdiction measures with Monitored Natural Attenuat i on as the preferred remedial measure. Refer to Section 11.0 for more information, includin g our reasons for making this recommendation. 10.1 NATURE AND EXTENT OF CONTAMINANT MIGRATION The primary groundwater radiological contaminants of int e re st are Tritium and Strontium.
Other contaminants (Ces ium-137, N i ckel-63 and CobaIt-60) have been detected, but are limited to areas that h ave groundwater pathways dominated by T riti um and/or Strontium , and are accounted for i n Entergy's dose calcu l at i o n s. Groundwater co ntamin at i on i s limited to Indian Po i n t's p r operty and i s not m i grating off-p r operty to the North, East or South. The contamination migrates with the Site groundwater from a r eas of hi gher he ads to areas of l ower heads along paths of l east resist ance, and ultimately discharges to the Hudson River to the West. This is supported by the bedrock geo l ogy, multi-l evel groundwater elevation data and the radiological resu l ts from analytical test i ng. The nearest d r inking water reservo ir s are located at distances and elevations which preclude impact s from contaminated groundwater from the Site and there i s no nearby use of groundwater.  
Other contaminants (Ces ium-137, N i ckel-63 and CobaIt-60) have been detected, but are limited to areas that h ave groundwater pathways dominated by T riti um and/or Strontium , and are accounted for i n Entergy's dose calcu l at i o n s. Groundwater co ntamin at i on i s limited to Indian Po i n t's p r operty and i s not m i grating off-p r operty to the North, East or South. The contamination migrates with the Site groundwater from a r eas of hi gher he ads to areas of l ower heads along paths of l east resist ance, and ultimately discharges to the Hudson River to the West. This is supported by the bedrock geo l ogy, multi-l evel groundwater elevation data and the radiological resu l ts from analytical test i ng. The nearest d r inking water reservo ir s are located at distances and elevations which preclude impact s from contaminated groundwater from the Site and there i s no nearby use of groundwater.
: a. The Site is located over a portion of the aquifer basin where Site-wide ambient groundwater flow patterns , both sha llow and deep , have been defined. These flows are towards the Site from higher elevations to the North , East and South. Groundwater flow on Site enters the Hudson River through: footing drains (which di sc harge to the Discharge Canal); the D i scharge Cana l; the storm dra i n system; or direct d i sc h arge. The results of over two years of in vest igations demonstrate that the off-Site groundwater migration to the South , as originally hypothe s ized by others prior to these in vestigations, i s not occurring.  
: a. The Site is located over a portion of the aquifer basin where Site-wide ambient groundwater flow patterns , both sha llow and deep , have been defined. These flows are towards the Site from higher elevations to the North , East and South. Groundwater flow on Site enters the Hudson River through: footing drains (which di sc harge to the Discharge Canal); the D i scharge Cana l; the storm dra i n system; or direct d i sc h arge. The results of over two years of in vest igations demonstrate that the off-Site groundwater migration to the South , as originally hypothe s ized by others prior to these in vestigations, i s not occurring.
: b. Surface water samples collected from the Algonquin Cree k , the Trap Rock Quarry and from the drink i ng water r eservoirs do not ex hi bit impact s from the Site. c. The Hudson River is the regional groundwater sin k for the area. We found no Site data , pub li s hed information , or other reasons suggest i ng that g roundwater would migrate beneath the river. To the contrary, based on the a r ea's hydrogeologic setting and all available information , we are confident that groundwater beneath the Site discharges to the river. 127
: b. Surface water samples collected from the Algonquin Cree k , the Trap Rock Quarry and from the drink i ng water r eservoirs do not ex hi bit impact s from the Site. c. The Hudson River is the regional groundwater sin k for the area. We found no Site data , pub li s hed information , or other reasons suggest i ng that g roundwater would migrate beneath the river. To the contrary, based on the a r ea's hydrogeologic setting and all available information , we are confident that groundwater beneath the Site discharges to the river. 127
: d. Because of the hydraulic properties of the bedrock , the bedrock aquifer on-Site wi ll not support large yields, o r accept input of lar ge volumes of wa t er. e. There are no identified off-Site uses of groundwater (extrac tion or injection) proximate to the Site that influence groundwater flow patterns on the Site. Furthennore, we have no reason to believe that potable or irrigation wells will be insta ll ed on or near the Site in the reasonably foreseeable future, in part because municipal water is available in the area. f. Groundwater flow at the Site occurs in two distinct h ydraulic regimes that are vertical l y connected, bedrock and overburden soils. Mo s t of the groundwater flow and contaminants are found in the bedrock fractures.
: d. Because of the hydraulic properties of the bedrock , the bedrock aquifer on-Site wi ll not support large yields, o r accept input of lar ge volumes of wa t er. e. There are no identified off-Site uses of groundwater (extrac tion or injection) proximate to the Site that influence groundwater flow patterns on the Site. Furthennore, we have no reason to believe that potable or irrigation wells will be insta ll ed on or near the Site in the reasonably foreseeable future, in part because municipal water is available in the area. f. Groundwater flow at the Site occurs in two distinct h ydraulic regimes that are vertical l y connected, bedrock and overburden soils. Mo s t of the groundwater flow and contaminants are found in the bedrock fractures.
No evidence of large scale solut i o n features exist i n the rock cores obtained from any of the bedrock borings advanced at the Site; i.e., no open voids such as runnels, caverns, caves, etc., sometimes referred to as "unde rground rivers," were found. Our on-Site investigatory findings are consistent with that expected for the Inwood Marble. Therefore, this work eliminates from concern solution feature flow associated with karst systems. The second regime is groundwater flow in the unconsolidated soil deposits.
No evidence of large scale solut i o n features exist i n the rock cores obtained from any of the bedrock borings advanced at the Site; i.e., no open voids such as runnels, caverns, caves, etc., sometimes referred to as "unde rground rivers," were found. Our on-Site investigatory findings are consistent with that expected for the Inwood Marble. Therefore, this work eliminates from concern solution feature flow associated with karst systems. The second regime is groundwater flow in the unconsolidated soil deposits.
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129 10.3 GROUNDWATER CONTAMINANT TRANSPORT Based on our assessment of the bedrock's hydraulic properties, the area's hydrogeologic setting, the properties of the contaminants, the age of the releases , interdictions made to eliminate or reduce release rates, and the distances between the source areas and the Hudson River, we believe the groundwater contaminant plumes have expanded to their maximum extent and are now decreasing in size. In this regard , the Unit 2 Tritium plume is decreasing faster than the Unit I Strontium plume, as anticipated.
129 10.3 GROUNDWATER CONTAMINANT TRANSPORT Based on our assessment of the bedrock's hydraulic properties, the area's hydrogeologic setting, the properties of the contaminants, the age of the releases , interdictions made to eliminate or reduce release rates, and the distances between the source areas and the Hudson River, we believe the groundwater contaminant plumes have expanded to their maximum extent and are now decreasing in size. In this regard , the Unit 2 Tritium plume is decreasing faster than the Unit I Strontium plume, as anticipated.
These conclusions are based on the data available which, given the aggressiveness with which Entergy implemented the investigations, is compressed in duration lJO , Therefore, ultimate confirmation of these conclusions will require monitoring over a number of years to allow ranges in seasonal variation to be adequately reflected in the monitoring data. During long tenn monitoring, GZA further anticipates that contaminant concentrations in individual monitoring wells will fluctuate over time (increasing at times as well as decreasing, as potentially related to precipitation events), and that a future short tenn increase in concentrations does not, in and of itself, indicate a new leak. In addition, it is also expected that some areas within the plumes will exhibit faster decay rates than others. Both behaviors are commonly observed throughout the industry with groundwater contamination sampling and analyses, and therefore, conclusions pursuant to plume behavior must be evaluated in the context of all of the Site-wide monitoring data. Overall, however, aZA believes that the continuing monitoring will demonstrate decreasing long tenn trends in groundwater contaminant concentrations over time given the source interdictions completed by Entergy. It is also further emphasized that even the upper bound Tritium and Strontium groundwater concentration isopleths presented on Figures S.l and S.2 result in releases to the river which are only a small percentage of the regulato!), limits, which are of no threat to public health. a. The major groundwater transport mechanism is advection.
These conclusions are based on the data available which, given the aggressiveness with which Entergy implemented the investigations, is compressed in duration lJO , Therefore, ultimate confirmation of these conclusions will require monitoring over a number of years to allow ranges in seasonal variation to be adequately reflected in the monitoring data. During long tenn monitoring, GZA further anticipates that contaminant concentrations in individual monitoring wells will fluctuate over time (increasing at times as well as decreasing, as potentially related to precipitation events), and that a future short tenn increase in concentrations does not, in and of itself, indicate a new leak. In addition, it is also expected that some areas within the plumes will exhibit faster decay rates than others. Both behaviors are commonly observed throughout the industry with groundwater contamination sampling and analyses, and therefore, conclusions pursuant to plume behavior must be evaluated in the context of all of the Site-wide monitoring data. Overall, however, aZA believes that the continuing monitoring will demonstrate decreasing long tenn trends in groundwater contaminant concentrations over time given the source interdictions completed by Entergy. It is also further emphasized that even the upper bound Tritium and Strontium groundwater concentration isopleths presented on Figures S.l and S.2 result in releases to the river which are only a small percentage of the regulato!), limits, which are of no threat to public health. a. The major groundwater transport mechanism is advection.
Sorption retards the migration of radiological contaminants other than Tritium relative to groundwater advection rates, while Tritium, within hydraulically interconnected fractures, can migrate at rates that approach the groundwater seepage velocity.  
Sorption retards the migration of radiological contaminants other than Tritium relative to groundwater advection rates, while Tritium, within hydraulically interconnected fractures, can migrate at rates that approach the groundwater seepage velocity.
: b. The Unit 2 contaminant plume is characterized by Tritium in the groundwater.
: b. The Unit 2 contaminant plume is characterized by Tritium in the groundwater.
Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased (see Table 5.1 and Figures S.l and 9.3). However, the center of mass of the Unit 2 plume is not rapidly migrating downgradient , and remains in proximity to the LP2-SFP. While a small active leak can not be ruled out completely, this behavior is also consistent with the identified role of unsaturated zone (above the water table) storage of historic releases, with precipitation
Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased (see Table 5.1 and Figures S.l and 9.3). However, the center of mass of the Unit 2 plume is not rapidly migrating downgradient , and remains in proximity to the LP2-SFP. While a small active leak can not be ruled out completely, this behavior is also consistent with the identified role of unsaturated zone (above the water table) storage of historic releases, with precipitation
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Further planned interdictions include removal of the fuel rods and draining of the pool water , which will pennanently eliminate the West Fuel Pool as well as the entire IPI-SFP complex as a source of contamination to the groundwater.
Further planned interdictions include removal of the fuel rods and draining of the pool water , which will pennanently eliminate the West Fuel Pool as well as the entire IPI-SFP complex as a source of contamination to the groundwater.
With elimination of this source, natural attenuation will reduce Strontium concentrations in the Unit I plume over time. GROUNDWATER MASS FLUX CALCULATIONS During the project (over the past two years), as testing progressed and more information became available, we refined methods to calculate the groundwater flux and associated radiological activity to the Hudson River. As described below , we have developed a procedure which is scientifically sound, relatively straight-forward, and appropriately conservative.
With elimination of this source, natural attenuation will reduce Strontium concentrations in the Unit I plume over time. GROUNDWATER MASS FLUX CALCULATIONS During the project (over the past two years), as testing progressed and more information became available, we refined methods to calculate the groundwater flux and associated radiological activity to the Hudson River. As described below , we have developed a procedure which is scientifically sound, relatively straight-forward, and appropriately conservative.
Groundwater flow rates are provided to Entergy, who computes the radiological dose impact. a. Migration of radionuclides to the river is computed based on groundwater flow r ates, in combination with contaminant concentrations within the flow regime. This information is then used in surface water models to compute radiological contaminant concentrations in the river and thus potential dose to receptors.  
Groundwater flow rates are provided to Entergy, who computes the radiological dose impact. a. Migration of radionuclides to the river is computed based on groundwater flow r ates, in combination with contaminant concentrations within the flow regime. This information is then used in surface water models to compute radiological contaminant concentrations in the river and thus potential dose to receptors.
: b. To assess the va lid ity of the precipitation mass balance method used to date for computing groundwater flux across the Site, aZA also performed groundwater flux computations using an independent method based on Darcy's La w. Thus , the re su lts from two widely accepted groundwater flow calculation methods were compared against each other. The first, the precipitation mass balance method, is a "to p-down" procedure based on precipitation-driven water balance analyses.
: b. To assess the va lid ity of the precipitation mass balance method used to date for computing groundwater flux across the Site, aZA also performed groundwater flux computations using an independent method based on Darcy's La w. Thus , the re su lts from two widely accepted groundwater flow calculation methods were compared against each other. The first, the precipitation mass balance method, is a "to p-down" procedure based on precipitation-driven water balance analyses.
The second, based on Darcy's Law, is a "bottom-up" method using hydr a ulic conductivity and flow gradient measurements.
The second, based on Darcy's Law, is a "bottom-up" method using hydr a ulic conductivity and flow gradient measurements.
These two methods resulted in estimated groundwater flow value s which were in agreement , providing a high degree of confidence in the values obtained relative to their impact on subsequent dose computations and risk analyses.  
These two methods resulted in estimated groundwater flow value s which were in agreement , providing a high degree of confidence in the values obtained relative to their impact on subsequent dose computations and risk analyses.
: c. The original groundwater flux computations were developed for two separate areas of the Site. T he northernmost area included both the U nit 2 and U nit 1 plumes. T he southernmost area encompassed Unit 3. This bifurcation of the Site was established given: 1) the co-location of the Unit 2 plume and the U nit 1 plume near the western boundary of the Site just upgradient of the river; 2) the much lower contaminant concentrations in the Unit 3 area; and 3) the amount of data available at that time. Current data, derived from a greater number of groundwater elevation and sampling points than reflected in ear li er data, show the Site can be divided into six separate areas. The computations were further s eparated into shallow and deep flow regimes given: 1) the generally higher hydraulic conductivity in the shallow 131 portion of the bedrock, and 2) the generally more elevated contaminant concentrations in the shallow flow regime. d. The groundwater contaminant concentrations used for the radiological dose computations were obtained primarily from the analysis of samples taken from the recently completed multi-level wells specifically installed for this These wells are located downgradient of the Unit 2 and Unit 1 infrastructure l 3 and are positioned within the plumes and just upgradient of where the groundwater discharges to the river and Discharge Canal. The multi-level nature of these wells allows the groundwater to be sampled over at least five separate elevations in the bedrock, in addition to the overburden layer above. Sampling zones specifically targeted the most pervious depths within the bedrock boreholes.
: c. The original groundwater flux computations were developed for two separate areas of the Site. T he northernmost area included both the U nit 2 and U nit 1 plumes. T he southernmost area encompassed Unit 3. This bifurcation of the Site was established given: 1) the co-location of the Unit 2 plume and the U nit 1 plume near the western boundary of the Site just upgradient of the river; 2) the much lower contaminant concentrations in the Unit 3 area; and 3) the amount of data available at that time. Current data, derived from a greater number of groundwater elevation and sampling points than reflected in ear li er data, show the Site can be divided into six separate areas. The computations were further s eparated into shallow and deep flow regimes given: 1) the generally higher hydraulic conductivity in the shallow 131 portion of the bedrock, and 2) the generally more elevated contaminant concentrations in the shallow flow regime. d. The groundwater contaminant concentrations used for the radiological dose computations were obtained primarily from the analysis of samples taken from the recently completed multi-level wells specifically installed for this These wells are located downgradient of the Unit 2 and Unit 1 infrastructure l 3 and are positioned within the plumes and just upgradient of where the groundwater discharges to the river and Discharge Canal. The multi-level nature of these wells allows the groundwater to be sampled over at least five separate elevations in the bedrock, in addition to the overburden layer above. Sampling zones specifically targeted the most pervious depths within the bedrock boreholes.
As such, the groundwater samples encompass the full depth of the contaminant plume, from the upper soil zones to depths where the contaminant concentrations have fallen off to insignificant levels. The high number of samples over the depth of the plume provides a higher degree of confidence that the significant flow zones are accounted for. The high number of vertical sampling zones also provides a higher level of redundancy relative to the longevity and efficacy of the monitoring network over time. 10.5 GROUNDWATER MONITORING The current groundwater well and footing drain monitoring network is consistent with the objectives of the NEI Groundwater Protection lnitiative 1 32. Wells have been installed and are currently being monitored to both detect and characterize current and potential future groundwater contaminant migration to the river, as well as, in concert with specific footing dra in monitoring, provide earlier detection of potential future leaks associated with the exi s ting infrastructure.  
As such, the groundwater samples encompass the full depth of the contaminant plume, from the upper soil zones to depths where the contaminant concentrations have fallen off to insignificant levels. The high number of samples over the depth of the plume provides a higher degree of confidence that the significant flow zones are accounted for. The high number of vertical sampling zones also provides a higher level of redundancy relative to the longevity and efficacy of the monitoring network over time. 10.5 GROUNDWATER MONITORING The current groundwater well and footing drain monitoring network is consistent with the objectives of the NEI Groundwater Protection lnitiative 1 32. Wells have been installed and are currently being monitored to both detect and characterize current and potential future groundwater contaminant migration to the river, as well as, in concert with specific footing dra in monitoring, provide earlier detection of potential future leaks associated with the exi s ting infrastructure.
: a. The network of 59 monitoring well locations and over 140 sampling intervalsllocations , has allowed us to identify groundwater flow patterns. A subset of this network will provide an adequate long tenn monitoring system. b. Existing and potential sources have been identified, and monitoring is in place to both evaluate current conditions and identify future releases , should they occur. c. The nature and extent of contamination is known and reporting requirements are in place. 10.6 COMPLETENESS Inv est igations at the Site have been broad, comprehensive, and rigorous.
: a. The network of 59 monitoring well locations and over 140 sampling intervalsllocations , has allowed us to identify groundwater flow patterns. A subset of this network will provide an adequate long tenn monitoring system. b. Existing and potential sources have been identified, and monitoring is in place to both evaluate current conditions and identify future releases , should they occur. c. The nature and extent of contamination is known and reporting requirements are in place. 10.6 COMPLETENESS Inv est igations at the Site have been broad, comprehensive, and rigorous.
Major components of the field studies include: detailed acquisition of geologic infonnation; automated long duration collection of piezometric data; vigorous source area 131 The multi-level sampling nctwo r k is concentrated in the U nit 2 and Unit I areas given that this is where contaminant concentrations are by far the highest. The individual monitoring wells located downgradient of Unit 3 are judged suffi c ient for computations in this area given the low contami nant concentra ti o n s measured, even in the typica l ly more contaminated sh allow flow regimc. 1)2 NEI developed a set of procedures/goals for nuclear plants to assess the potentia!
Major components of the field studies include: detailed acquisition of geologic infonnation; automated long duration collection of piezometric data; vigorous source area 131 The multi-level sampling nctwo r k is concentrated in the U nit 2 and Unit I areas given that this is where contaminant concentrations are by far the highest. The individual monitoring wells located downgradient of Unit 3 are judged suffi c ient for computations in this area given the low contami nant concentra ti o n s measured, even in the typica l ly more contaminated sh allow flow regimc. 1)2 NEI developed a set of procedures/goals for nuclear plants to assess the potentia!
for releases of radionuclides to pote n tia!1y migrate off-Site.
for releases of radionuclides to pote n tia!1y migrate off-Site.
132 identification; comprehensive aquifer property testin g, including perfonnance of a full scale Pumping Test; and larg e-scale confirmatory contaminant transport testing, in the fonn of an extensive tracer test. The re su l ts of this systematic testing program are in agreement with conditions anticipated by our Conceptual Site Model. Based on our review of findings, we have concluded that the field studies conducted at the Site have addressed the study objectives.  
132 identification; comprehensive aquifer property testin g, including perfonnance of a full scale Pumping Test; and larg e-scale confirmatory contaminant transport testing, in the fonn of an extensive tracer test. The re su l ts of this systematic testing program are in agreement with conditions anticipated by our Conceptual Site Model. Based on our review of findings, we have concluded that the field studies conducted at the Site have addressed the study objectives.
: a. There is no need to monitor groundwater at off-Site loc ations. The density and spacing of on-Site monitoring wells i s adequate to: I) demonstrate that contaminated groundwater is migrating to the Hudson River to the West, and not migrating off of the property to the North, East or South; 2) monitor the anticipated attenuation of contaminant concentrations;  
: a. There is no need to monitor groundwater at off-Site loc ations. The density and spacing of on-Site monitoring wells i s adequate to: I) demonstrate that contaminated groundwater is migrating to the Hudson River to the West, and not migrating off of the property to the North, East or South; 2) monitor the anticipated attenuation of contaminant concentrations;
: 3) identify future releases, should they occur; and 4) provide the data required to compute radiological dose impact. b. Hydraulic conductivity is the most important aquifer property.
: 3) identify future releases, should they occur; and 4) provide the data required to compute radiological dose impact. b. Hydraulic conductivity is the most important aquifer property.
We have completed more than 245 hydraulic conductivity tests, including a full-scale Pumping Test. Therefore, we believe no future aquifer testing is required.
We have completed more than 245 hydraulic conductivity tests, including a full-scale Pumping Test. Therefore, we believe no future aquifer testing is required.
In addition , the contaminant plumes have reached their maximum spatial extent. Therefore, there is no need for contaminant transport modeling.  
In addition , the contaminant plumes have reached their maximum spatial extent. Therefore, there is no need for contaminant transport modeling.
: c. The sources of releases to the groundwater have been identified.
: c. The sources of releases to the groundwater have been identified.
In addit i on to monitoring, actions have been taken to reduce or eliminate these re l eases. Therefore, we believe no future source characterization is required.  
In addit i on to monitoring, actions have been taken to reduce or eliminate these re l eases. Therefore, we believe no future source characterization is required.
: d. All information indicates Monitored Natural Attenuation is the appropriate remedial response and is GZA's recommended approach (see Section 11.0). The existing monitoring network wi ll serve this remedial approach.
: d. All information indicates Monitored Natural Attenuation is the appropriate remedial response and is GZA's recommended approach (see Section 11.0). The existing monitoring network wi ll serve this remedial approach.
Therefore, no design phase studies are required.
Therefore, no design phase studies are required.
133 11.0 RECOMMENDATIONS Based upon the comprehensive groundwater investigation and other work perfonned by En te rgy, GZA recommends the following:  
133 11.0 RECOMMENDATIONS Based upon the comprehensive groundwater investigation and other work perfonned by En te rgy, GZA recommends the following:
: 1. Repair the identified Unit 2 Transfer Canal liner weld imperfection (completed mid December 2007); 2. Continue source tenn reduction in the Unit 1 pool via the installed demineralization system; 3. Remove the remaining Unit 1 fuel and drain the pools; and 4. Implement long term monitoring consistent with monitored natural attenuation, property boundary monitoring, future potential leak identific a tion, and support of ongoing dose assessment.
: 1. Repair the identified Unit 2 Transfer Canal liner weld imperfection (completed mid December 2007); 2. Continue source tenn reduction in the Unit 1 pool via the installed demineralization system; 3. Remove the remaining Unit 1 fuel and drain the pools; and 4. Implement long term monitoring consistent with monitored natural attenuation, property boundary monitoring, future potential leak identific a tion, and support of ongoing dose assessment.
It is GZA's opinion that our investigations have characterized the hydrogeology and radiochemistry of the groundwater regime at the Site. Therefore, we are not recommending further s ubsurface investigations (see Section 10.0). Based upon the findings and conclusions from these investigations, as well as other salient Site operational infonnation. we recommend the completion of source interdiction measures with Monitored Natural Attenuation (MNA) as the remediation teclmology at the Site. In no small part. this recommendation is made because of the low potential for ri s k associated with g r oundwater plume discharge to the Hudson River. Monitored Natural Attenuation is defined by the United States Envirorunental Protection Agency as the reliance on natural attenuation processes (with in the con t ext of a carefully contro lled and monito red clean up approach) to achieve Site-specific remedial objectives within a time frame that is reasonable compared to other methods. The "na tural attenuation p r ocesses" that are at work in the remed i ation approach at this Site include a variety of physical, chemical and radiological processes that act without human intervention to reduce the activity, toxicity, mobility, volume, or concentration of contaminants in soil and groundwater.
It is GZA's opinion that our investigations have characterized the hydrogeology and radiochemistry of the groundwater regime at the Site. Therefore, we are not recommending further s ubsurface investigations (see Section 10.0). Based upon the findings and conclusions from these investigations, as well as other salient Site operational infonnation. we recommend the completion of source interdiction measures with Monitored Natural Attenuation (MNA) as the remediation teclmology at the Site. In no small part. this recommendation is made because of the low potential for ri s k associated with g r oundwater plume discharge to the Hudson River. Monitored Natural Attenuation is defined by the United States Envirorunental Protection Agency as the reliance on natural attenuation processes (with in the con t ext of a carefully contro lled and monito red clean up approach) to achieve Site-specific remedial objectives within a time frame that is reasonable compared to other methods. The "na tural attenuation p r ocesses" that are at work in the remed i ation approach at this Site include a variety of physical, chemical and radiological processes that act without human intervention to reduce the activity, toxicity, mobility, volume, or concentration of contaminants in soil and groundwater.
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MNA i s typically used in conjunction with active remediation measures (e.g .* source control), or as a follow-up to active remediation measures that have already been i mplemented.
MNA i s typically used in conjunction with active remediation measures (e.g .* source control), or as a follow-up to active remediation measures that have already been i mplemented.
At IP EC. active remedial measures alr e ady implemented include e l iminat i on (e.g., repair of the Unit 21990 liner leak and repair of Transfer Canal weld imperfection in mid-December 2007) and/or control (e.g., installation of a collection box to capture moisture from the IP2 shrinkage cracks) of active leaks , and reduction of the source term in t he Unit 1 fuel storage pool through demineralization.
At IP EC. active remedial measures alr e ady implemented include e l iminat i on (e.g., repair of the Unit 21990 liner leak and repair of Transfer Canal weld imperfection in mid-December 2007) and/or control (e.g., installation of a collection box to capture moisture from the IP2 shrinkage cracks) of active leaks , and reduction of the source term in t he Unit 1 fuel storage pool through demineralization.
with subsequent planned removal of the source term (fuel rods) followed by complete draining of the lPl-SFPs. Remediation  
with subsequent planned removal of the source term (fuel rods) followed by complete draining of the lPl-SFPs. Remediation
: 1. Our recommendation of MNA principles includes so urc e term contaminant reduc tion as an integral part of this remediation strategy.
: 1. Our recommendation of MNA principles includes so urc e term contaminant reduc tion as an integral part of this remediation strategy.
Data demonstrating plume concentration reduction s over time, as considered along with other salient \34 Site infonnation, are consistent with a conclusion that the i nterdiction efforts to date (both current and in the past) have resulted in: 1) termination of the identifi ed Tritium leaks in the IP2-SFP; 2) id ent i fica tion of an imperfection in a Unit 2 Transfer Canal we ld which has been repaired;  
Data demonstrating plume concentration reduction s over time, as considered along with other salient \34 Site infonnation, are consistent with a conclusion that the i nterdiction efforts to date (both current and in the past) have resulted in: 1) termination of the identifi ed Tritium leaks in the IP2-SFP; 2) id ent i fica tion of an imperfection in a Unit 2 Transfer Canal we ld which has been repaired;
: 3) reduction in IPI-SFP contaminant concentrations; and 4) elimination of Sphere Foundation Drain Sump discharges to the s torm drain piping East of Un it 3. As suc h , these interdictions have re s ulted in the elimination and/or control of identified sources of contamination to the groundwater. as required:  
: 3) reduction in IPI-SFP contaminant concentrations; and 4) elimination of Sphere Foundation Drain Sump discharges to the s torm drain piping East of Un it 3. As suc h , these interdictions have re s ulted in the elimination and/or control of identified sources of contamination to the groundwater. as required:
: a. Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased.
: a. Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased.
These data are consistent with a conclusion that the leaks responsible for the currently monitored Tritium plume are related primarily to the previously repaired 1992 legacy liner leak and the imperfection in the Transfer Cana l weld. With the implemented physical containment of the associated 2005 "concrete wall crack leaks" and the repair of the Transfer Canal liner, the source of contamination to the groundwater has been reduced and controlled.  
These data are consistent with a conclusion that the leaks responsible for the currently monitored Tritium plume are related primarily to the previously repaired 1992 legacy liner leak and the imperfection in the Transfer Cana l weld. With the implemented physical containment of the associated 2005 "concrete wall crack leaks" and the repair of the Transfer Canal liner, the source of contamination to the groundwater has been reduced and controlled.
: b. Over the last two years , the highest radionuclide concentrations in the Unit I plume have decreased.
: b. Over the last two years , the highest radionuclide concentrations in the Unit I plume have decreased.
These decreases are consi sten t with a reduction in the concentrations in the Unit I West Fuel Pool via pool water recirculation through demineralization beds. While the physicalleak(s) in this fuel pool s till exist, the source term to the groundwater has been reduced due to treabnent of the source water. FUrther planned interdiction s include removal of the fuel rods and draining of the pool water , which will pennanently eliminat e th e West Fuel Pool as a source of contamination to the groundwater.  
These decreases are consi sten t with a reduction in the concentrations in the Unit I West Fuel Pool via pool water recirculation through demineralization beds. While the physicalleak(s) in this fuel pool s till exist, the source term to the groundwater has been reduced due to treabnent of the source water. FUrther planned interdiction s include removal of the fuel rods and draining of the pool water , which will pennanently eliminat e th e West Fuel Pool as a source of contamination to the groundwater.
: c. The U nit 1 plume in the Unit 3 area has been attribu ted to a historic legacy discharge from the Sphere Foundation Drain Sump (SFDS) through the s tonn drain system which traverses a lon g the southeastern portion of the Site. Leaks from this storm drain system have, in tum, resulted in past contamination of the groundwater along the s torm drains, with subsequent groundwater migration westward, through Unit 3 toward the river. The SFDS no longer discharges to the stonn drain and the Strontium concentrations in the Unit 3 groundwater have decreased to low levels , consistent with natural attenuation processes.  
: c. The U nit 1 plume in the Unit 3 area has been attribu ted to a historic legacy discharge from the Sphere Foundation Drain Sump (SFDS) through the s tonn drain system which traverses a lon g the southeastern portion of the Site. Leaks from this storm drain system have, in tum, resulted in past contamination of the groundwater along the s torm drains, with subsequent groundwater migration westward, through Unit 3 toward the river. The SFDS no longer discharges to the stonn drain and the Strontium concentrations in the Unit 3 groundwater have decreased to low levels , consistent with natural attenuation processes.
: 2. GZA selected Monitored Natural Attenuation as the remediation strategy because: a. Interdiction measures undertaken and planned to date have, or are expected to, eliminat e/co ntrol active sources of groundwater contamination.  
: 2. GZA selected Monitored Natural Attenuation as the remediation strategy because: a. Interdiction measures undertaken and planned to date have, or are expected to, eliminat e/co ntrol active sources of groundwater contamination.
: b. Groundwater flow at the Site precludes off*Site migration of contaminated groundwater to the No rth , South or East. c. Consistent with the Conceptual Site Model , no contaminants have been detected above regional background in any of the off-Site monitoring locations or drinking water supply systems in the region. d. The only on-Site exposure route for the documented contamination is through direct exposure.
: b. Groundwater flow at the Site precludes off*Site migration of contaminated groundwater to the No rth , South or East. c. Consistent with the Conceptual Site Model , no contaminants have been detected above regional background in any of the off-Site monitoring locations or drinking water supply systems in the region. d. The only on-Site exposure route for the documented contamination is through direct exposure.
Because the majority of the Site is capped by 135 impermeable surfaces, there is no uncontrolled direct contact with contaminants.  
Because the majority of the Site is capped by 135 impermeable surfaces, there is no uncontrolled direct contact with contaminants.
: e. Our studies indicate that under existing conditions, the spatial extent of the groundwater plume will decrease with time. f. Groundwater is not used as a source of drinking water on the Site or in the immediate vicinity of the Site, and there is no reason to believe that this practice will change in the foreseeable future. g. Groundwater associated with the Unit 1 foundation drainage systems is captured and treated to reduce contaminants prior to discharge to the Discharge Canal , consistent with ALARA principles.  
: e. Our studies indicate that under existing conditions, the spatial extent of the groundwater plume will decrease with time. f. Groundwater is not used as a source of drinking water on the Site or in the immediate vicinity of the Site, and there is no reason to believe that this practice will change in the foreseeable future. g. Groundwater associated with the Unit 1 foundation drainage systems is captured and treated to reduce contaminants prior to discharge to the Discharge Canal , consistent with ALARA principles.
: h. At the locations where contaminated groundwater discharges to the Hudson River, the concentrations have been, and will continue to be, reduced by sorption, hydrodynamic dispersion and radiological decay. No detections of contaminants associated with plant operations have been found in the Hudson River or biota samp l ed as part of the required routine environmental sampling.
: h. At the locations where contaminated groundwater discharges to the Hudson River, the concentrations have been, and will continue to be, reduced by sorption, hydrodynamic dispersion and radiological decay. No detections of contaminants associated with plant operations have been found in the Hudson River or biota samp l ed as part of the required routine environmental sampling.
I. More aggressive teclmologies would alter groundwater flow patterns and, therefore, in our opinion , offer no clear advantages.
I. More aggressive teclmologies would alter groundwater flow patterns and, therefore, in our opinion , offer no clear advantages.
Long Term Monitoring  
Long Term Monitoring
: 1. The second primary requirement for implementation of is a demonstration that contaminant migration is consistent with the Co nceptual Site Model. In particular, rigorous monitoring is required to demonstrate reductions in source area contamination, reductions in plume contaminant concentrations, and reduction in contaminant discharge to the river over time. The initial implementation stages of this monitoring process were begun nearly two years ago as part of the investigations summarized herein. As outlined above , reductions in maximum groundwater plume contaminant concentrations have already been documented.
: 1. The second primary requirement for implementation of is a demonstration that contaminant migration is consistent with the Co nceptual Site Model. In particular, rigorous monitoring is required to demonstrate reductions in source area contamination, reductions in plume contaminant concentrations, and reduction in contaminant discharge to the river over time. The initial implementation stages of this monitoring process were begun nearly two years ago as part of the investigations summarized herein. As outlined above , reductions in maximum groundwater plume contaminant concentrations have already been documented.
T he elements for long term monitoring , consistent with the objectives of the N E l Groundwater Protection Initiative, are in place. We further note: a. Groundwa ter wells have specifically been installed , and are currently being monitored, to both detect and characterize current and potential future off-Site groundwater contaminant migration to the river. Additional wells have also been installed for monitoring of other Site property boundaries.  
T he elements for long term monitoring , consistent with the objectives of the N E l Groundwater Protection Initiative, are in place. We further note: a. Groundwa ter wells have specifically been installed , and are currently being monitored, to both detect and characterize current and potential future off-Site groundwater contaminant migration to the river. Additional wells have also been installed for monitoring of other Site property boundaries.
: b. Monitoring wells have also been installed just downgradient of identified critical Structures, Systems and Components (SSCs). These wells, in concert with specific footing drain monitoring , provide earlier detection of potential future leaks associated with the power generating units than would be possible with boundary well s alone. c. Monitoring wells have been strategically placed to monitor the behavior of the plumes identified on the Site. d. MW-3g and MW-4g should be excluded from the monitoring plan as samp l es from these wells are generally indicative of a mixed groundwater 136 and Discharge CanaVriver water condition and, therefore, are not completely groundwater specifi c l33. e. The long tenn monitoring plan should include action levels, which if exceeded, trigger further analysis and/or investigations, potentially leading to implementation of an interdiction plan, if required.  
: b. Monitoring wells have also been installed just downgradient of identified critical Structures, Systems and Components (SSCs). These wells, in concert with specific footing drain monitoring , provide earlier detection of potential future leaks associated with the power generating units than would be possible with boundary well s alone. c. Monitoring wells have been strategically placed to monitor the behavior of the plumes identified on the Site. d. MW-3g and MW-4g should be excluded from the monitoring plan as samp l es from these wells are generally indicative of a mixed groundwater 136 and Discharge CanaVriver water condition and, therefore, are not completely groundwater specifi c l33. e. The long tenn monitoring plan should include action levels, which if exceeded, trigger further analysis and/or investigations, potentially leading to implementation of an interdiction plan, if required.
: f. A number of individual vertical sampling zones were included in nearly all the monitoring well installations, particularly within the contaminant plumes and at the location of plume discharge to the river. These individual vertical monitoring zones provide a significant level of vertical resolution and also provide a substantial degree of redundancy relative to the longevity and efficacy of the monitoring network over time l34. g. While previous and current dose calculations are both reasonable and conservative, we recommend that, with the accumulation of additional Site-specific hydrogeologic infonnation, the calculations be modified to incorporate Site-specific transmissivities and groundwater gradients.
: f. A number of individual vertical sampling zones were included in nearly all the monitoring well installations, particularly within the contaminant plumes and at the location of plume discharge to the river. These individual vertical monitoring zones provide a significant level of vertical resolution and also provide a substantial degree of redundancy relative to the longevity and efficacy of the monitoring network over time l34. g. While previous and current dose calculations are both reasonable and conservative, we recommend that, with the accumulation of additional Site-specific hydrogeologic infonnation, the calculations be modified to incorporate Site-specific transmissivities and groundwater gradients.
Entergy has agreed that Site-specific model infonnation will be utilized in the next NRC required annual assessment of dose from this pathway_ Our specific recommendations (which will include additional trend information in early 2008) will be provided under separate cover for Entergy's incorporation to support the annual report. m See Section 6.6.3 for further discussion pursuant to this conclusion. 1 l4The level of redundancy designed into the long term monitoring network anticipates and allows for the loss of a number of monitoring zones without significant impact to the adequacy of the monitoring system. 137}}
Entergy has agreed that Site-specific model infonnation will be utilized in the next NRC required annual assessment of dose from this pathway_ Our specific recommendations (which will include additional trend information in early 2008) will be provided under separate cover for Entergy's incorporation to support the annual report. m See Section 6.6.3 for further discussion pursuant to this conclusion. 1 l4The level of redundancy designed into the long term monitoring network anticipates and allows for the loss of a number of monitoring zones without significant impact to the adequacy of the monitoring system. 137}}

Revision as of 03:04, 30 April 2019

Entergy Pre-Filed Hearing Exhibit ENT00331B, Hydrogeologic Site Investigation Report for the Indian Point Energy Center, Page 64 Through Page 137
ML12089A567
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 01/07/2008
From: Barvenik M J, Powers M, Winslow D M
GZA GeoEnvironmental
To: Evers R
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ENT00331B Submitted: March 29, 2012 I.E-t{)1 Anll)ytic:a) solution oftidlll response Amplitude:

  • P eak delay: * * * * *
  • x-..ws um cc fr o m the bol.mdary (ft) A"'!ida l amp li tude: (ft) * * * ... *
  • Average measured amplitude

--Theoretica s olution with TIS-SO , ooonJ/d I.-t idal cyc l e (day)

  • I.E-<>' ______ --_---_--o 10 0 2 00 JOO 4 00 SOO 600 Distance &om the riv er, x (ft) 70 0 so o TIDAL RESPONSE VS DISTANCE FROM THE HUDSON RIVER provides an analytical solution fo r the theoretical piezometric re s ponse of an aquifer adjacent to a tidal boundary (see above graph). The assumptions upon which this solution is based are quite restrictive. In addition to the nonnal difficulties (aquifer heterogeneities, anisotropic prorrties , etc.) which limit the practical use of the solution in estimating aqu i fer propert i e s , J it i s not clear if water l evel s at the Site are responding to changes in the river le vel , changes in the Discharge Canal l evels , or perhaps, a combination of both, Further complicating this is s ue, the concrete cana l walls, and at some locations (not all) the concrete canal bottom , should clearly affect propagation of tidal fluctuations in the canaL With these limitations noted, our review of data indicates that the hydraulic diffusivity4 0 (tran s missivity , T , divided by storativ i ty, S) of the rock, as estimated by the t idal responses , is on the order of 80 , 000 Fr I day. See the above graph and infonnat i on in Appendix K. As presented in Section 6.S, we believe the average transmissivity of the bedrock aquifer is typically in the range of 30 to 50 fi'/day. Using a transmissivity of 40 ti'/dayand a diffusivity of 80 , 000 tt'/day , it follows the storativity of the bedrock aquifer is on the order of 5xI0-4. This value is in good agreement with the values we computed from an evaluation of the Pumping Test data and from the cubic equation (see Section 6.S.1). JI C.W. Felter , Appli ed H y drol ogy, Second E dition. Merrill 1988. )9 Pat ri ck P o w e rs , Co n s tru c ti o n Dewat e rin g, S e c ond Editio n. 40 Fre e ze & C herry , G r ()Untm'aler Pr e nticc-ll all 1979. 64 Another effect of river tidal changes i s manifested in monitoring wells in close proximity to the river or Discharge Canal as follows. As the river approaches high tide , the groundwater gradients in proximity to the river become flatter, and at certain locations and tides, are reversed; iliat is, on a temporary basis, groundwater discharge to the river is generally slowed, and in at least some location s, groundwater flow nonnally to the river is reversed to then be from the river into the aquifer. 6.6.2 Groundwater Temperature The cooling water intake structure i s located North (upstream) of the cooling water discharge structure (see Figure 1.3). When the river is near high tide, the cooling water intake draws river water that contains discharge water 4! (i.e., river flow reverses and water begins to flow away from the ocean). At periods near low tide, the current in the river reduces or eliminates this circulation (within the river) of cooling water. A consequence of this tidal influence is that the temperature of water in the Discharge C anal, in addition to always being warmer than the river water, varies with tidal cycles. This i s illustrated on Figure 6.15 as well as the graph below, a double-axis graph to show the water level and temperature data collected in January 2007 from two still ing wells: Out-I , located at the southern end of the Discharge Canal, and HR-!, located in the cooling water intake structure of Unit }4 2. 7 Out-! and HR-J 6 5 '" 4 3 2 2 _3 L---1114/07 1/15 10 7 111 6107 11-Oue*! "!It e r level -HR*! .... ater level 1 1 17/07 1118/07 ... 65 0 i 60= E 55 Co 5
  • 50 ... 45 40 _Jl----L 35 1/19/07 WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR DISCHARGE CANAL AND HUDSON RIVER (JAN. 07) The direction of the flow in the river is tidally influenced. which at periods near high tide, is to the North, away from the ocean. Unit I i s inactive and this stilling well should provide a good measure of the riv e r e l evations with time. 65 Based on this information and water quality variations (see Section 6.6.3), we evaluated the potential for the Discharge Canal water to influence water quality at two locations originally proposed for southern property boundary monitoring 43 , MW-38 and MW-48 (located adjacent to the canal and river respectively; see Figure 1.3). 6.6.2.1 Monitoring Well MW-38 Groundwater response to tidal influence of the coo l ing water Discharge Canal (at thi s location) is strong and appears to vary between tidal cycles. We note , however , that we observed respon ses from approximate l y 60% to at least 86% with an average of approximately 70%. 7 6 , 4 3 1/14107 >C Out*1 water level Out*1 terrperaturt MW*38 water level MW*38 tefl1>eraturt 1 115/07 1/1 6107 11 17/07 , , 11\&107 r. f! ': , , , f: r.-" :oc-t *: * . . '. :oc: i : V , ' r 80 40 30 20 1/19/07 WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR DISCHARGE CANAL AND MW-38 (JAN. 07) Additionally, at high tide the canal level is above the water level in MW-38 and at low tide the water level in MW-38 is abov e the level of the canal (see above graph). These data demonstrate the potential for water in the canal to migrate to the proximity of MW*38 during periods of high tide. Groundwater temperature data collected from MW-38 indicate that canal water doe s in fact , at times , migrate to well MW-38. This i s shown on the above graph 'l The rc s ults of our ana l yses demonstrate that monitoring wclls MW*38 and MW-48 are impacted hy Discharge Cana l water at various time s. Therefore.

these w e ll s arc not s uitable for measuring southern boundary groundwater radiolo gica l conditions.

66 which shows water leve l s and temperatures collected i n January 2007. In reviewing this graph , note that the temperature of groundwate r in MW-38 is: I) wanned significantly above ambient ground wate r temperatu r es (averaging approximately 70° F as compared to an ambient temperature of approximate l y 55° F); 2) on average , during this period , wanner than the canal water; 3) at its lowest temperatu r e near high tide; and 4) increases in temperature while water leve l s in the well decline. These observations are consistent with groundwater discharge to the canal at low tide and canal water flow to the vicinity of well MW-3 8 during high tide. 7 80 x Ota;.l \\Iller lev e l _____ MW-38 \\a te r level 7. 6 -MW*38 t e mp e r a t l.r e 78 ;:: '" j 5 II tt 77 0 '" A' nn l\ 76 ,; -* 4 = " x .!! = --3 ... *1"\ ..

is. = .,. >. 74 on e -, 7J ;l ... 0

  • 72 71 70 7/211 06 7/2 3/06 7124106 712 51 06 7/26106 7/27/06 7128106 7129/06 WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR DISCHARGE CANAL AND MW-38 (JULY06) Data presented above , which is for MW-38 in the summer of 2006 , while not as dramatic , supports our conclusion that groundwater in MW-38 is mixed , at times, with canal water.

In reviewing this graph , note the canal water is significantly wanner than the groundwater, and that water temperature in the well water increases while the canal water level is above the l evel of water in the well. 6.6.2.2 Monitoring Well MW-48 Water leve l s respond to tidal changes in both well s (MW-48-23 and MW-48-38) at the MW-48 l ocation. The water levels and temperature variations in these two well s are pre s ented and described below. 67 7 6 5 " 4 j '" 3 *

  • oS 2 -o * ---M W 4&.23 water level -HR*) water l evel
  • MW-4&.23

-!"\ " ..........

-: I -

.... . 7. 69 :. 68 , 67 66 o 65 i o 64 * ; 6J :. E -1 6 2 3 1/1 41 07 1/1 5107 11 1&07 111 710 7 1/1 8107 6 1 60 1/1 9/07 " j '" * * -< = * -:!

  • WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR HUDSON RIVER AND MW-48-23 (JAN_ 07) 7 --M W-48-23 wate r \c\" el 6 5 4 3 2 1 -* 2 -3 7/22106 7/23/06 7/241fYJ 7 12 5/06 )( OUI-I water level 7/2 6/06 7 1 27/06 7/28106 90 65 60 7/29/06 WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR DISCHARGE CANAL AND MW-48-2 3 (JULY 06) 68

.. 7 6 l .. . j "' J *

  • oS 2 * ;:
  • I -MW-48-3 8 w S tl!T le v el -HR*] w'tlt c rl e v e l o M W 38 temperature
__ 2 -3 1/[4/0 7 1115/0 7 11161()7 1/17/07 1118 10 7 70 69 68 67 , 66' i 6l' i , 641 -+ 63
  • 62 6 1 6<l 1119 1(}7 WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR HUDSON RIVER AND MW-48-38 (JAN. 07) 7 I 66 --MW*48*3 8 water Icvel j .: i---------1 t 6l
  • MW-48-3 8temp e ralurc 64 J A A A ' "' *
  • oS * ;:
  • 2 ./\ .!i ,"'!i.1\ JiW'i!\ ii f\ .. f\ \.1\ \1\1 . '.'\i\lU\,*\i o
  • V , V V
  • V \J V V \J \i 62! -1 6 1 3 "---7n2JO(, 7/23/06 7/2 4 106 7flSI06 7n 6lO6 7 fl7/06 7!l8J()(, WATER LEVEL AND TEMPERATURE RELATIONSHIPS FOR MW-48-38 (JULY 06) At high tide, the level of water in both of these wells is very close to the river level , while at low tide , it is s lightly above the river level and approximately 2 feet below the level of the Discharge Canal. The vertical gradient at this location is upward , with a stronger gradient at low tide. These data are consistent with anticipated trend s , indicating groundwater discharge to the river occurs predominantly at low tide. Note that the river w a ter temperatures shown on graph s in this report are not representative of the temperature of the water in the river adjacent to monitoring well s MW-48. Thi s i s due to the location of river transduce r HR-I. and tidal induced flows in the river. However, the elevated (above ambient) temperature of the groundwater at the s e location s (65 to 69° F) indicates it has been wanned by the Site's cooling water di s charge. 69 The temperature of water in monitoring well MW-48-23 varies with so me tide cycles, with the coolest temperature being near hjgh tide in the winter, and the warmest temperature being near high tide i n the summer. This pattern of temperature change is consistent with this monitoring well receiving river water at times of high tide. The temperature of water in monitoring we ll MW-48-38 does not appear to vary with tidal cycles. We interpret these data to mean that physical water quality in monitoring well MW-48-38 is not typically influenced by large exchanges of river water 44. The elevated groundwater temperature at this location , and the piezometric data, suggest, however, that flows created by purging of the well prior to sampli ng , at times of high tide, could induce river water flow to this location.

6.6.3 Aqueous Geochemistry Routine groundwater monitoring indicated th e presence of Tritium in a limited number of sam ples collected from monitoring well s MW-38 and MW-4 8. MW-38 was originally installed under the first phase of inve s tigation to bound the southern extent of T ritium contamination at the Site along the cooling water Discharge Canal. However, subse quent sampling events indicated the presence of Tritium in groundwater at thi s loca tion. The presence of Tritium in this well did not fit our CSM or what we knew of groundwater flow at the Site. A second well , MW-48, was insta ll ed at the so uthern Site boundary along the Hudson River to e s tabli sh if any Tritium would potentially migrate off-Site.

Tritium was detected intermittently in groundwater samples collected at this loca t ion as well. As neither of these locations was hydraulica ll y downgradient of identified rele ase areas, another mechani sm other than grou ndw ater migration from the release area was postu l ated. This mechanism involved releases from the legacy pip i ng that conveyed contaminated water from the IPI-SFDS to the "E"-ser ie s stormwater piping that runs beneath the access road on the South side of the Protected Area and discharges storm water to the cooling water Discharge Canal. While evaluating this hypothesis, we found evidence, as discussed in Section 6.62, that at certain tidal cycles, water from the Discharge Canal and the Hudson River may back flow into these groundwater monitoring wells. To help identify the source of Tritium in these two wells, we developed a focused water quality program specific to the se wells. Generally, the water quality program involved analyzing selec t aqueous geochemica l parameters in groundwater and surface water samples. Evaluation of these data can allow conclusions to be drawn regarding the sou r ce of the samp led water. Both data sets (elevation and water chemistry) indicate that water co ll ected from these wells may contain river or cooling water from the Discharge Canal. Based on these findings , we recommend that groundwater samp l e l aboratory re s ult s from th ese well loc ations not be used to evalua te the extent of groundwater contami n ation or contaminant

4. Rellltively large exchanges of water are required to overcome the thennal mass of the subsurface deposits surrounding the well bore. Therefore, while smaller exchangcs of g r oundwa t er/river water may go undetected via temperature change. they may st ill be large enough to adversely impact radiological water quality. particularly in consideration of the data from the proximate well sc r eens. Also see discussion in Section 6.6.3. 70 flux to the Hudson River and that these wells not be incorporated into the Long Term Monitoring P l an as Boundary W e ll s. 6.6.3.1 Sampling Gro undwater samp l es were collected from monitoring well s MW-38 , MW-48-23, and MW-48-38 and from the Discharge Cana l and Hud son River on January 19 , 2007. These samp le s were analyzed for bicarbonate alkalinity (as CaCO,), magnesium , sod ium , calcium, s u l fate, and chloride.

The data was graphed on Stiff diagrams and is shown on Figure 6.16. 6.6.3.2 Water Quality Evaluation GZA used the six water quality indicator s (bicarbonate alkalinity

[as CaC03], magnesium, sodium, calcium, s ulfate , and chloride) to assess whether or not Discharge Cana l and/or river water was present or mixed with groundwater at the two l oca tion s of intere st (note tha t th e MW-48 monitoring well location contains a shallow and a deep well). A summary of our findings f o llow s.

  • The river and canal samples are chemically s imilar and are dominated by sodium and chloride.

The sodium and chloride contents are highest at the mid tide samp lin g event. These data indicate that at mid tide there was a greater vertical mixing of river water which caused the water to contain more sodium and chloride 45.

  • The MW-48-23 samples collected at low, mid and high tide are all geochemically s imil ar and are dominated by the sod ium and chloride ions. However, the electrolyte concentration of these two ions is approximately half of that measured in the river or canal samples. Additionally. at low tid e, there is slightly le ss sodium chloride and s lightl y more bicarbonate anion than at mid o r high tide. We believe this indicates that at low tide , this location receive s relatively more groundwater.
  • Samples collected from MW-48-38 at low , mid , and high tide were generally all dominated by calcium and magnesium cations and chloride and bicarbonate anions. These samp le s also contained s imilar sodium, chloride , calcium, bicarbonate , magnesium, and sulfate electrolyte concentrations.

However, at mid and high tide, there was so mewh at more ca lcium , magnesiwn , and bicarbonate measured in these samples. It is further noted that the cation/anion imbalance for the MW-48-38 samples (excep t MW-48-38-U) was greate r than 5%. T his i nd ica tes a lack of accuracy or the pre sence of unanalyzed ion s in the groundwater samp le s. While samples from MW-48-38 currently appear more representative of groundwater than those from wells MW-38 and MW-48-23, it is not certain that they are always fully representative of groundwater only46 . * , We believe the river and canal samples are s imilar (in pan) because th e river sample l ocation was silU atcd imm ediately down*ri ver of th e Discharge Canal outfall. In addition, the ri ver samp l ing locat i on v i sibly appears to remain w ithin the discharge water h ca t plume. Therefore , th e ri ver samp l es are likely Discharge Canal water or at least mixed with what is being discharged from the canal. 46 for example. 573 pCi/L of Tritium was detect e d in this interval on Septe m ber.5. 2006. Tritium had n ever previously been detected and has s ince not been detect e d in thi s interval.

It may be that sam ple was misidentified in the field and the sample was actual1y obtained from the upper interval of this well where Tritium is routinely detected. However. 71

  • The samples collected from MW-38 at low , mid and high tide are all geochemically similar and are dominated by the sodium and chloride ions. However , the electrolyte concentration of the s e two ions is less than half of that measured in the river or canal samples. Additionally.

at low tide, there is slightly less sodium and chloride than at mid or high tide. We believe this likely indicates that at low tide , this location sees relatively more groundwater.

These data indicate that water samples collected from MW-38 and MW-48-23 are largely representative of the proximate surface water bodie s at the Site. Recognizing the source of water in these we ll s, the other chemistry data (e.g., Tritium and Strontium) are suspect and should not be used for evaluation of groundwater contaminant migration or flux. Based on the available data , MW-48-38 may provide samples more representative of Site groundwater than MW-38 and MW-48-23. However , further analysis would be necessary to allow this well to be recommended as a so uthern boundary monitoring location, particularly in light of the above analysis pursuant to the proximate well s creens and the potential for false positives.

Given the demonstrated groundwater flow directions in this area 41 , it is GZA's opinion that an additional southern boundary monitorin g location (in addition to MW-Sl and MW-40) is not required proximate to MW-48-38.

6.7 GROUNDWATER FLOW PATTERNS A major purpose of this groundwater investigation was to identify the fate and level of groundwater contaminant migration.

The contaminants of potential concern are so luble in groundwater, and at somewhat varying rates, move with it. This section provides a descripti o n of identified groundwater flow panems in and downgradient of identified contaminant release areas. The piezometric data, shown in Table 6.1 , which form the basi s of this evaluation are independent of chemical data collected at the same monitoring location s. Consequently.

our evaluation of piezometric data provides an assessment of where contaminants are expected to migrate in various time frames. Refer to Section 9.0 for information on the observed distribution of contaminants and a discussion on disc re pancies between anticipated and observed conditions.

Testing has indicated that the bedrock i s sufficiently fractured to , on the scale of the Site , behave as a non-homogeneou s, anisotropic , vertically porou s media. This finding indicate s that groundwater flow is perpendicular to lines of equal heads. This assessment appears particularly valid in horizontal (East-West

& North-South) directions.

The nature of bedrock fracturing s uggests the hydraulic conductivity is higher in the horizontal than in the vertical direction.

Furthermore it appears the upper portions of the rock are more conductive than the deep rock except within the zone of higher hydraulic conductivity between Units I and 2. These findings suggest that the bulk of the it also is po ss ible that this sample is reflectiv e of river water induced i nto the w e ll through sampling and/or th e s pecific condition s existing at the time the samp l e was l aken. 47 While the representativeness of the chemistry data in theSe: wells (MW-38. MW*48*23 and MW-48.38) is not certain, the groundwater elevation data is reliable for es tabli s hing now direction. 72 groundwater moves at shallower depth , with small masses being reflected deeper into the rock mass than would be seen in anisotropic aquifer. 6.7.1 Groundwater Flow Direction G r oundwater elevations from pre ss ure transducers at a representative low tide have been used to construct a potentiometric surface map of the aqu if e r beneath the S i te (see Figure 6.17). We c h ose this data set after evaluating a number of piezometric data sets. More spec ificall y we have mapped s i x groundwater conditions:

  • Low tide during the drier portion of the year (2112107)
  • High tide during the wetter portion of the year (3/28/07)
  • Low tide during the wetter portion of the year (3/28/07)
  • High tide during the drier portion of the year (2/12/07)
  • Groundwater e lev ations at sample locations with the greatest Tri tium impact during wet season
  • Groundwa t er elevations at sample locations with the greatest Tritium impact during the dry season Based on this evaluation, it appears that there i s not a great deal of change in groundwater flow patterns over time (see Appendix S). However , as groundwater elevat i ons have a s maller tidal re sponse (amp li tude) than the fluctuations of the river , l ow tide is a time with a relatively high degree of groundwater flux from the Site. Funhermore, low tide during the drier portion of the year l ikely rep r esents a period of highest groundwater flux. Groundwater flow is in three dimensions.

A representative set of groundwater elevations was used to construct a cross-sectional groundwater contour map as shown on Figure 6.18. This figure is based on a 1:1 horizontal to vertical hydr aulic conductivity.

Because horizontal fractures transmit flow in only a horizontal direction, and vertical fractures transmit flow in both a horizontal and vertical d i rection, the aquifer is vertically anisotropic with a preference for horizontal flow. Conversely , if the vertical hydraulic conductivity decreases with depth, the groundwater flow s hould be driven deeper than s hown on the figure, but would still ultimately discharge to the Hudson River. Based on the observed vertical distribution of piezometric head s, the deepest flow paths of potential intere s t for this investigation originate near Un it 2. Based on the observed vertical distribution of contaminants (see Section 9.2), these flow path s are limited to depths of betwee n 200 and 300 feet below ground sur face. As di scussed p re viously. gro u ndwater flow patterns are also influ enced by anthropogenic so urces and s i nks. The gro undwater sources/s inks are shown on Figure 1.3 a nd are summarized below:

  • U nit 1 Chem i cal Sy s tems Building (IPI-CSB) Foundation Drain: This drain discharges into the Sphere Foundation Drain Sump (SF OS) and is designed to maintain groundwater elevations beneath IP-I-CSB subbasement to an elevation of approximately 1 2 feet NOVD 29. The reported groundwater extraction rate from this drain is approximately 10 ga ll ons per minute (gpm). 73
  • IP I-NeD: This drain is designed to maintain groundwater elevations beneath the Unit I contai n me n t build i ng (IP I-CB) and the Unit I Fuel Handling Bui l ding FHB) at an elevation ranging from 33 to 42 feet NGVD 29. The reported groundwater extraction rate from this drain is approximately 5 gpm.
  • Unit 2 Footing Drain: This drain is designed to maintain groundwater elevations beneath the Unit 2 Vapor Containment (lP2-VC) at an elevation ranging from approximately 13 to 42 feet NGVD 29. The long term flow rate from this drain is not known, but short term measurements made prior to and during the Pumping Test indicate it i s li kely on the order of5 gpm.
  • Unit 3 Footing Drain: IP3* VC is known to have a Curtain Drain. However, specifics of i ts construction were not available.

It is known that a pipe that connects to the Unit 3 Curtain Dra i n is currently under water in a manhole Northeast of Unit 3. Due to this condition, it is unknown how much or whether or not this drain is removing groundwater.

  • Unit I , 2, and 3 storm drains: The storm drains surrounding Units I, 2, and 3 were constructed of corrugated metal piping. These pipes and associated utility trenches have been shown to allow at least some infiltrationlexfiltration.

That is, depending on rainfall and location , these structures may e i ther receive groundwater or recharge the aquifer. 6.7.2 Groundwater Flow Rates In the interest of evaluating conditions when a relatively large amount of groundwater (and assoc i ated constituents) flux to the Hudson River occurs, our discussion of lateral groundwater flow direction focuses on the low tide potentiometric surface contours as shown on Figures 6.19 and 6.20. These groundwater contours show that groundwater genera ll y flows toward the Site from the North, East and South, with a generally westerly flow direction across the Site with a gradient ave raging about 0.06 feet per feet. 6.7.2.1 Seepage Velocities We used Darcy's Law to estimate the average groundwater seepage velocity across the Site: Where: dh dl n , dh I V=K*-*dl average linear groundwater velocity hydraulic conductivity (0.27 feet/day [see Section 6_5 0]) groundwater gradient (0.06) effective porosity (assumed to be 0.0003 based on spec i fic yield measured during Pumping Test) 74 Based on this equation and Site data, we computed the average groundwater seepage veloc i ty to be on the order of 55 ftlday. This is an upper end estimate in that it does not account for the effect of dead-end fractures and irregularities in fracture aperture s. That is , we believe the effective porosity is larger than that indicated by hydraulic testing. Also note that this is an average velocity with flow rate in individual fractures being controlled by the local gradient and hydraulic apertu re of the fracture.

Based on the tracer test (see Section 7.3.2), actual measured ave rage seepage rates were substantially less than 55 ftlday. 6.7.2.2 Groundwater Flux To estimate groundwater flows (i.e., groundwater mass flux) beneath the IPEC , a calibrated analytical groundwater flow model was constructed.

This model was based on two independent equations, both of which provide groundwater flow estimates.

The first of these equations is based on a mass balance. That is , on a long term average, the groundwater discharging from the aquifer is equal to the aquifer recharge.

The second equation is "Darcy's Law", which s tates the flow per unit width of aquifer is equal to the transmis s ivity of the aquifer multiplied by the hydraulic gradient.

As discussed in the following subsections using Site-specific data for the governing parameters, both of these independent methods provided s im ilar results. Because we were conservative (that is, we chose values for both equations that we believe may somewhat overestimate flows), we believe the model is appropriate for it s intended use for estimating the mass of groundwater discharging to the Hudson River as part of dose impact computations

48. Please note, this model is not, therefore , conservative for all purposes.

For examp le , we believe it would likely overestimate the yield of extraction wells shou ld they be developed at the facility.

While the calculated groundwater flu x from the Site directly to the river (approx imat ely 1 3 gpm) may intuitively seem smal l, it i s consistent with our Conceptua l Site Model and the identified hydrogeological setting. Mass Balance The mass balance approach r ecognizes that the on l y su bstantial so urce of recharge to aqu i fer is areal recharge derived from precipitation. Precipitation in the area reported l y varies from 49 inche s per year (3D-year average) to 36 inches per year (to-year average) at the IPEe Meteorological Station. Areal recharge is that portion of precipitation that reaches the water table (total precipitation minus run-off, evaporation and transpiration).

The average areal recharge is dependent on total precipitation, the nature and timing of individual stonn events, soil types, topography , plant cover, the percentage of impervious cover (roads, buildings, etc.) and precipitation recharge through exfi ltr ating 4 1 It i s n ote d that the do s e impact computa t ions reponed for 2006 were based on the mas s balance model only. The se analyses were completed prior to obtaining sufficient data to implement the Darcy's Law mode1. It is recommended that future dose impac t computations also be based on the mass balance model , but with upgrade s based on Darcy's Law analyses.

75 stormwater management systems. B ase d on our review of avai l able inform at ion , we bel ieve that the areal rechar ge at the IP EC is greater than 6 inche s per y ear and l ess than 1 2 inches per year. For the purpo ses o f thi s st udy , an average of 10 inches per ye ar was used (see Appendix S for information on how we arrived at this average).

To pographic divide s were used to defined the recharge area (se e Figure 3.1). Th i s provides a recharge a re a of approximately 4 , 000 , 000 square feet (92 acres) and a calculated recharge r a te of 38 gpm. From this va lu e, the 20 gpm extracted by pumpin g from foundation drains was su btracted (see Section 8.0). Thi s app ro ac h , therefore , indicates that the groundwater discharge to th e coo lin g wate r Di sch ar ge Cana l and the Hudson River is approx im a t e l y 18 gpm. Darcv's Law Da rcy's Law is presented below: Where: Q = volumetric flow (ft') T = transmiss ivity (tt'lday)

W = width of the s tr eamt ube dh dh Q=K*A*-=T*W*

-dl dl To estimate transmissivities, the aquifer was divided int o two layers or zo n es: th e upper forty feet; and bet ween depths of 4 0 feet and 185 feet, the identifi ed bottom of the sig nificant groundwater fl ow field. In each of the zo ne s, transm i ssiv iti es were calculated u s ing the geometric mean of hydraulic conductivity testing. The facility was further divided into 6 fl ow zo ne s representing a re as beneath pertinent Site features; and data East (upgradient) of the Discharge Canal was reviewed independently of that West (d owngrad i ent) of the Discharge Cana l. This process , s h own o n the fo ll owi n g four t a bl es, provides an estimate of th e grou ndw at er flux p assi n g beneath s tructure s of intere st that discharge to the cooling water Discharge Cana l and the Hudson River. In re v i ew in g th ese ca l cu lati o n s, note th e resulting total groundwater flow East of t h e canal i s approximately 18 gpm , which indicate s that the long term areal recharge to the aquife r is 10 inches per year, o r 28% of the I O-year average precipitation recorded at the IP EC. 76 Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) (I(Jlm) Northern Clean Area 0.36 209 0.600 0.23 Unit 2 Nonh 1.59 294 0.014 0.03 Unit 1/2 31.97 215 0.007 0.26 Unit 3 North 29.87 324 0.054 2.74 Unit 3 South 16.02 3 3 8 O.oJ8 1.07 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 8.45 SHALLOW ZONE BEFORE CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydraulic Volumetric (friday) Gradient Flow Rate (ftlft) DJ), Northern C l ean Area 0.36 209 0.600 0.23 Un il 2 North 1.59 2 2 1 0.038 0.07 Un it 1 12 31.97 146 0.022 0.52 Unit 3 North 29.87 3 16 0.013 0.61 Unit 3 South 16.02 248 0.011 0.24 Southern Clean Zone 24.34 879 0.037 4.12 Total+ 5.79 SHALLOW ZONE AFTER CANAL (OVERBURDEN AND TOP 40 FEET OF BEDROCK) Unit Transmissivity Width (ft) Hydra ulic Volumetric (friday) G r adient Flow Rate (ftlft) (""m) Northern C lean Area 10.77 209 0.068 0.80 Unit 2 North 1 0.77 294 0.030 0.49 U nit 1 12 62.15 21 5 0.023 1.61 U nit 3 North 37.65 324 0.022 1.41 U nit 3 South 22.02 338 0.040 1.55 Southern Clean Zone 19.66 879 0.043 3.83 Total+ 9.69 DEEP ZONE BEFORE CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) 77 Unit Transmissivity W i dth (ft) Hydraulic Volumetric (ft'/day) Gradient Flow Rate (flirt) (20m) N orthern Cl e an A r e a 10.77 209 0.068 0.80 Unit 2 North 10.77 294 0.023 0.29 Unit 112 62.15 215 0.018 0.83 Unit 3 North 37.65 324 0.QI8 1.09 Unit 3 South 22.02 338 0.016 0.45 Southern Clean Zo ne 19.66 879 0.04 3 3.8 3 7.25 DEEP ZONE AFfER CANAL (FROM 40 TO 18 5 FEET BELOW TOP OF BEDROCK) GZA's groundwater flux calculations are used by Entergy to calculate radiolog i ca l dose impact. Entergy currently estimates this dose based upon the precipitation mass balance approach alone. Refinements to this dose mode l are feasible utilizing the hydrogeo l ogic data presented above. These refinements will improve the overall data fit of the flow model in concert with the long term monitoring p r ogram being implemented by Entergy. The resultant dose assessments are expected to remain close to , or be somewhat lower than , what has already been estimated.

It is recommended that Entergy evaluate the refinements to the existing model for inclusion in the next annual effluent assessment report. 78 7.0 GROUNDWATER TRACER TEST RESULTS A tracer test was conducted to help assess g roundwater migration pathways from IP2-SFP. As discussed in the followin g sec tions , the te st also helped to confirm migration pathways from Uni t I. The test was designed to s imulate a leak from IP 2-SFP. in that the tracer (Fluorescein) was released directly to the bedrock at the base of the structure, immediately below the sh rink age cracks associated with the 2005 release. The bedrock surface at this location is approximately elevation 51 feet, and thus approximately 40 feet above the water table (as measured in the immediately adjacent MW-30 -see Figure 7.1). This approach was taken (recognizing it would complicate tracer fl ow paths relative to injection directly into the groundwater) to provid e better understanding of the role of unsaturated bedrock in storing and transporting Tritium, A major difference in the test , as compared to possible releases at IP2-SFP , i s the rate of the injection.

The 2005 Tritium release was measured at a peak rate of approximately 2 liters per day (0.005 gpm), as opposed to the tracer injection that occurred relatively instantaneously (as compared to the Tritium release) at a rate of app roxim ate l y 3.5 gpm over approximately an hour. This higher injection rate was used to insure that a suffic ient mass of Fluorescein was released at a known time. As anticipated, a nd discussed in s ub sequent sect ions, this practice appears to have enhanced the lateral spreading of the tracer in the unsaturated zone. 7.1 TRACER INJECTION Preparation for the injection began on January 29, 2007 with the injection of potable water to test the ability of the injection point 49 , TI-U2-1 , to accept water and to pre-wet fractures. The first potable water inj ec ti on was cond uct ed on January 29, 2007. Five hundred gallo n s of water (m easured using an inline totaling water meter) was introduced as fast as the water source wou ld pennit (approximately 8.5 gpm). The water level in the well did not ris e significantly.

The second potable water injection was conducted on January 30, 2007. A total of 1 , 012 gallons of t ap water was introduced at a mean rate of approx imatel y 8.3 gpm. The piezometric data collected during that period from wells MW-30 , MW*31 , MW*33 , MW-34 and MW-35 were re viewed for evidence of groundwater mounding. (Note: transducers were not in s talled in RW-I and MW-32 on that date,) Mounding, on the order of 0.5 to 1 foot , was recorded at MW-31. No re spo n se was noted at the other four nearby monitored locations.

Note that MW-31 is located upgradient of the in jection point from a saturated zone groundwater flow perspective , and unsaturated zone flow in this direction is The injection point as s hown on Figure 7.2 is constructed from two-inch ste el pipe thnt e nd s in a tee and perforated piping runn ing directly on the bed r ock s urface , well above the water table. 'Ibis perforated piping was covered with approximately 0.5 feet of e ru:>hed stone exten ding from the bedrock e x cavation face to the South face of the SF P , over a l e ngth of approximately 8 feet. 'I be crushed s t one was covered with filter fabric prior to placing the co n crete mud-m at for gantry crane foundation constructio n: th e mud*mat covers the en t ire bedrock excava ti on " floor" adjacent to the South s i de of the SFP. 79 consistent with the bedrock strike/dip directions.

Based on the shape of the time response curve at MW-31, GZA believes that: I. 2. 44 43 42 41 40 39 The center of the rele ase to the water table was at some distance from MW-31 (see time lag), and; Injected water was rele ased to the water t ab le over a l o nger duration than the tw o hour injection te st. 1bi s opinion is b ased on th e re l atively s low decay of the mound at MW-3 1. This response is shown on th e figure below: 1/29/07 injection 1/30 injection

  • I I , , *
  • 1 I -

'I

  • 1 I * * --* t I; ..... *
  • 1/28107 1129/07 1/30 1 07 1/31107 PIEZOMETRIC GROUNDWATER RESPONSE TO WATER INJECTION We have insufficient infonnation to render an op ini on on the s hape or height of the tracer injection-induced groundwater mound. We note, however , because of the lower rate of the tracer injection, the sho rt duration of the inj ection (see below), and the groundwater flow velocities, as derived from the tracer test, aZA believes mounding had relatively little effect (compared to unsaturated flow) on th e lateral spreading of the tracer. That is , the life of the mound was not of sufficient duration to cause long tenn, widespread lateral migration in the groundwater.

The tracer injection was performed on February 8 , 2007. It consisted of the rele ase of 7.5 pounds of Fl uorescein with 210 gallons of water. More spec ifically, prior to Fluoresce in injection, 30 gallons of potable water was released to the well , this was followed by 10 gallons of a Fluore sce in-water mixture , fo llowed by 170 gallons of potable water (to flu sh th e Fluorescein out of the well). This procedure resulted in a minimum initial ave rage tracer concentration of 4 , 300 , 000 ppb. 80 7.2 TRACER CONCENTRATION MEASUREMENTS The concentrations of Fluorescein in groundwater were routinely measured between February 8. 2007 and Au g u s t 21. 2007'° at 63 locations.

Thi s re s ulted in the collection analysis of 4,488 samples , including background samples , charcoal samplers and water samples. T hese data are tabulated and presented on timewconcentration graphs in Appendix N. Measurements of Fluore s cein concentrations were made by two methods. The first is through aqueous sample analy s is (1 , 969 individual samples).

These water sample analyses provide direct concentration measurements, at the time of sampling , with a detec t ion limi t ofless than 1 ppb. A second method entailed desorbtion of Fluorescein from packets of activated carbon (carbon s ampler s) s u s pended in the groundwater flow pa t h a t multi-level sampling locations.

This method provides a measure of the mass of Fluorescein moving through a monitoring well s creen over the period the activated carbon i s in the welL However , the actual concentration of Fluorescein in the groundwater is not detenninable from this test. Among other things, carbon sample analys es are useful in establishing that the F luorescein mas s being transported by groundwater did not pa s s sampling locations between discrete sampling events. This was important for this study because of the potential for high tran sp ort r a te s (see Section 6.0). 7.3 SPATIAL DISTRIBUTION AND EXTENT OF FLUORESCEIN IN GROUNDWATER The groundwater tracer test was developed primarily to identify groundwater migration pathw a y s. We have divided our discu s sion on ob s erved pathway s into three s ubsection s: unsaturated zone migration, the lateral distribution of Fluorescein, and the vertical dist r ibution of Fluore s cein. U nsaturated Zone Transport By design, F luorescein was released atop the bedrock, in the unsaturated zone. The bedrock s tructure (s trike and dip direction of bedrock fracture s) therefore played a dominant role in controlling tracer migration to the water table. This is witnessed by the sign i fic a nt F luorescein concentrations ob s erved in the upgradient monitorin g well MW-31 and MW-32 (see below) and at lower concentrations in the more distant and upgradient Unit I monitoring well MWA2. The observed un s aturated zone migration to the South and E ast i s consi s tent with the observed bedrock fracturing (see Section 6.0). This mechanism is also evidenced by data s howing the highest Fluorescein concentration (49 , 000 pico-curies per liter _ pCi lL)S I so In ad dit i on to th e r o uti ne samp lin g, s pe ci fi c w e ll s w e re s ampl(."(l f or a lon g er pe riod of time as part of s hort term variability t es t i n g (se c Stction 9.0). S! pCiIL is a standard u nit of radiation measurement.

81 being found in well MW-32 , located 60 feet to the South of the injection location, and not in MW-30 , located immediately be l ow the injection location.

In reviewing tracer test re su lts, it should be recognized that the F luorescein released at a single location on the bedrock was not released to the water table at a single location , rather , it reached the water table over an undefined area that likely extends to the East of MW-31, to the South to MW-42 , and likel y not far to the North of the injection weI!. As discussed in Section 7.S , this limits our ability to evaluate migration rates, but increases our abi li ty to understand likely Tritium migration pathways from lP2-SFP. The sp reading of Fluorescein in the unsa t urated zone was likel y more pronounced than the spread ing of Tritium because of the higher release rate. The tracer test , howeve r, supports data that shows the Uni t 2 plume to extend upgradient of the source area and laterally to Unit I to the South of lP2-SFB. Lateral Distribution Two conditions were se lected to s how the lateral distribution of Fluorescein in a manner illustrating cond i t i ons influencin g the migration of groundwater in the vicinity of lP2-SFB. These are: 1. The maximum observed concentrat i ons; and, 2. Condit i ons just prior to , and including, June 14, 2007. While the maximum observed concentrations do not illustrate an actual condition, the resulting figure is useful in highlighting migration pathways.

We chose June 14t h because it repre se nts conditions ap proximately 4 month s after the in jection. With estimated F luor esce in transport r ates on th e order of 4 to 9 fee t per day (see Section 7.4), conditions proximate to that date cle a rly illu strat e the effects of subsurface storage on both Fluorescein and Tritium s2. Lateral Distribution

-Maximum Observed Concentrations The distribution of the observed maximum concentrations of Florescein, at any depth, in g roundwater i s shown on Figure 7.2. This figure was developed based on both the observed concentrations and our understanding of groundwa ter flow directions (inferred from groundwater contours).

This figure does n o t show conditions at any s ingle time; rather it represents our interpretation of the highest tracer concentration, at any time during the test , at a location.

In reviewing that figure please note:

  • The maximum observed tracer concentration was 49,000 ppb; approximately I % of the calculated average injection concentration.

We interpret these data to mean th at there i s considerable s preading and mixing of the tracer in the unsaturated and s hallow saturated zones. 52 I , ater dales were not selected because of the associated r eduetion in the sampling frequency and/or number of samp lin g locations.

82

  • The 50 ppb contour represents approximate ly 11100,000 the concentration of the injected tracer. Because Tritium concentrations in IP2-SFP are approximately 20,000,000 pCiIL this contour (50 ppb Fluorescein) represents the detection limit of a release ofTririum from IPZ-SFP (at the injection well).
  • The general shape of the resulting plume is strik in g l y si milar to the observed Uni t 2 plume, see Figure 8.1. This supports our interpretation of contaminant migration from IPZ-SFP.
  • Because tracer was detected in MW-42 and MW-53 , the test can be used to help assess migration pathways from Unit I. The observed distribution of F luor escein in the vicinity of Unit 1 supports our interpretation of the migration of Strontium, with a we s tward migration towards the Hudson River in a fairly narrow zone (see Figure 7.2).
  • The low concentrations to the West (downgradient) of the cooling water Discharge Canal (as compared to East of the canal) indicate the canal received a significant mass of the tracer, as opposed to direct discharge to the river.
  • Concentrations found in Manhole Five (MH-5) indicate the IP-2 Curtain Drain received tracer (see Sect ion 7.S). Lateral Distribution

-June 14, 2007 aZA's interpretation of the distribution of F luor escein in groundwater pro xi mate to June 1 4,2007 i s s hown on Figure 7.3. Again , concentrations are the highe st measured at any depth. While not idea l for the observed concentrations, the contour interval was se lected to match the co ntour intervals shown on Figure 7.2. In reviewing that figure, please note:

  • The shape of the plume is more r epresentative of an ongo in g rele ase than of a month-old instantaneous release in a st rong groundwater flow field. This supports other data which indicate water is stored in the unsaturated bedrock (and potentially within the upper water bearing zone) and is released to the groundwate r flow field over time.
  • The center of the F luore scien mass in groundwater, in the release area, shifted to the North. (See data for wells MW-30 and MW-3Z on Figures 7.2 and 7.3). GZA interprets these data to mean: There is more storage in the unsaturated zone in proximity to IP2-FSB , than to the South or West; and The relatively high injection rate re s ulted in more lateral spreading of the tracer than would have re su l ted from a slow, long duration release. Vertical Distribution The table prov ided below prese n ts data on the vertical distribution of F l uorescein along the center lin e of the tracer plume (see Figure 7.2 for well locations).

It presents the maximum observed concentration at each depth and the approximate concentration S) proximate to June 14, 2007. J) Data estimated for the June 14th date are b ase d on time eonccntmtion gra ph s (s ee Appendix N). 83 FLUORESCEIN CONCENTRA nONS MW-JI MW-3 2 MW-JO Dc I b Co n e. ""h Cone. Dc t h CODe. " 16001 62 49 ,000/2 74 '690 0.' 2600 '7 1 2,700 I " 24.300 1 88 167 f 11 0 2"" ,"" " 1 8 1 013 14 0 ]5.)00/6 ", 4160116 197 621/56 1600 I 0.5 -Max. cone , I COIle. pr O;t(i mat c t o 61 14/07 in IlgiL Depth -Iklow Ground S urface (Feet) ND -Not Detected MW-JJ MW-III Dc t h Co n e. Dc th Cone. 1 " *** 1 " 2.' 1 1 2.' MW-J7 Dc th Cone. " 4 7/1 0 32 L3 1 N D The available d a t a indicate the bu lk of the Fluorescein was migrating at fairly shallow depths , although not always at the water table. As anticipated (consistent with the Co nceptu al Site Model), i t also suggests the pathway becomes somewhat deeper downgradient of the injection point, likely being below the well screens at MW -33 and MW-lil. The comparatively low concentrations at MW-lll , as compared to Tritium concent r ations , likely highlights the importance of unsaturated zone migration in groundwater contaminant distributions.

7.4 TEMPORAL DISTRIB UTION OF FLUORESCEIN IN GROUNDWATER Groundwater samples were co ll ected a t regular int e rval s between February 8 and August 21, 2007 54. These data are shown on graphs prov i ded in Appendix N with selec ted infonnation s hown below. Interpretation of these graphs is complicated , beyond the n onnal difficu l ties associated w i th interpreting tracer test data in fractured rock. This i s because the tracer was not injected directly to the water tab l e , as would be more typical. Rather , the tracer was re l eased at the top of the bedrock , in the unsaturated zone , so as to better mimic the behavior of the Tritium re l ease from the cracks in the fuel pool wall; as was the primary object i ve of the tr acer test. Therefore , the tracer then entered the gro undwater regime at numerous l ocations due to unsatura t ed zone spread in g from the release point. In add ition , these numerous release points remained act i ve over a n extended period of time (months) due to storage in the unsaturated zone; see the previous subsection and Section 8.1.2 for further discus s ion. With the se li mitations noted , the follow i ng observation s/interpretation s are provided:

  • At so me loca ti o n s, th e release to the water tab l e was rap i d. For example , at monitoring we ll located approximate l y 60 feet to the So u th of the i nj ect i o n point, the tracer arrival time SS was approximately o n e day. Conversely , at MW-30-74. located adjace n t to the injection we ll , the arrival t i me was app r ox i mately 25 da ys. See the following figures. 5 4 I n addition to the routin e sampling, s pec i fic w ells w ere sampled for a longer pe r iod of time as part of s lt ort term variabilit y te s ting (s ee Sect i on 9.0). 55 Arr i v al time s are genemlly established as the center of mas s (oft en the p ea k) of the concentration

'I s. time g raph. 8 4 5 )0000 . . '" 20000 " * . , ii :s-o , >-N 1/28/07 , . I Jf29!07 J 4r.!8107 MW*32*62 , S128107 D a t e 6/2 1 107 7mm .,"'" Rai n""" .. I MW-32-62 FLOURESCEIN AND P RECIPITATION VS TIM E e ; e * 'i , *

  • i ** " ] , 1t:!81(l7 m7/07 ]12'1107 4/Z1II01 MW-30-69 S128107 "'" 6/27107 7127/07 Sf.W07 -Ra;;:;;j MW-30-69 FLOURESCEIN AND PRECIPITATION VS T IME 85 , , 912510 7 . ., , i !
  • In mid-June 2007, there was sti ll an ongoing source of Fluorescein to the water table in the vicini t y ofIP2-FSP.

This is evidenced by the time-concentration grap h s for MW-30 -74 (see previous figure) and MW-30 -88 , presented below: ,., * ' .. '0 " . , '00 '" .-. \. * ... . .. .. r 5 I ., * ., * * .. , " , * "

  • 0 * " ox t ..
  • I * , ,,.,., 2127/07 '' MW-30-88 * .....
  • j . "'-. A Il.l I "' 71l7101 J ,
  • WW07 MW-3 0-88 FLOURESCEIN AND PRECIPITATION VS TIME
  • Because th e l ocations and times of releases from the unsaturated zone to the wate r table a r e not known , it is difficu l t , at best, to estimate tracer transport velocities.

However , as shown below, the ave ra ge value appears to be on the order of 4 to 9 feet/day.

Welll..ocation Time of Time Distance (Feet) Velocity (FtiDay) Arrival Date (Days) MW-33 3-5-07 25 1 10 4.4 MW-III 3-14.{)7 34 145 4.3 MW-37-22" 4-1 0.{)7 6 1 300 4.9 MW-55 3-28-07 48 240 5 to 9 FLOURESCEIN ARRIVAL TIMES AND TRANSPORT VELOCITIES 56 The sou rce o f the Fluorescei n observed in MW 37-22 i s uncertain.

[t may be e n tire l y from m ig rat ion i n the bedrock s l ight[y to th e Nonh of that location. or may be due , in part or in whol e, t o transpon via s torm drain s and in the backfill around the Discharge Canal walls. See Section 4 . .5. 57 Th e calculatcd veloc i ty depends on which flow path is selecte d. Us in g a flow path fr om MW-32 (day of rele ase) t o MW-55. the calculated v elocit y is approximately 5 fe et/day. Us in g a flow path between MW-S3 and MW-55 (t h e Strontium flow path) th e ea[cu[ated velocity is 9 fcct/day.

86 Also note, the carbon sampler data supports these estimates to the extent that no evidence of significant Fluorescein migration between aqueous sampling events was found. The observed tracer migration rates are approximately liS to 1110 the calculated groundwater velocity of SS ftlday , see Section 6.7.2. GZA attributes the difference between the "observed" and the "computed" transport velocities primarily to the effective porosity of the bedrock. That is, we believe the actual effective porosity is considerably larger (more on the order of 0.003) than that computed from our analyses of the Pumping Test (see Section 6.5.1); the aquifer response testing (see Section 6.6.1); or the hydraulic aperture of the bedrock (see Section 6.5.2). This slower transport velocity helps to explain the observed long term temporal variations in both tracer and Tritium groundwater concentrations, and supports the use of a porous media flow model. As a practical matter, this slower transport velocity encourages the use of conventional groundwater monitoring frequencies (quarterly or longer); and reduces concerns over the possibility of high concentrations of contaminants migrating by a monitoring location between sampling events. 7.5 FLUORESCEIN IN DRAINS, SUMPS AND THE DISCHARGE CANAL Fluorescein was also detected within storm drain catch basins, foundation drain sumps, and the Discharge Canal. Fluorescein was detected in manholes MH-4, MH-S and MH-6. In reviewing these data, note:

  • MH-S receives discharge from the IP2-VC Curtain Drain system. The presence of tracer in this manhole indicates that tracer entered the Curtain Drain system due to lateral spreading at the release point during injection.

Once in the Curtain Drain system, the tracer migrated to MH-S.

  • Water in MH-S flows towards the cooling water Discharge Canal passing tltrough MH-4, discharging at MH-4A.
  • T he concentrations detected in MH-4 are very similar to the Fluorescein concentrations detected in samples collected from MH-S, while Fluorescein was not detected in samples collected from the downstream manhole MH-4A. T his suggests that either dilution in MH-4A reduced Fluorescein to below method detection limits, and/or the tracer is lost via exfiltration from piping between MH-4 and MH-4A. This loss (if it occurs) in conjunction with flow in the canal backfill , could explain the Fluorescein observed in MW-37. Available data are not adequate to fully address this issue. In any event , the test further demonstrates the need to account for the Tritium being transported in the IP2-VC Curtain Drain (see Section 7.6).
  • In reviewing data, note that the tracer concentrations in MH-6 are lower than the concentrations observed in MH-S (peak in MH-6 of 14.4 ppb as opposed to a peak in MH-S of 43.1 ppb). We attribute the concentrations in MH-6 to groundwater infiltration in the area of the identified tracer plume. Also note the flow from MH-6 is to MH-S. Fluorescein was also detected in the IPI-NCD , the IPI-SFDS , and the Containment Spray Sump (CSS). We have attributed the presence of tracer at these locations to unsaturated zone migration to the vicinity and West of MW-42. The concentration and arrival times at 87 these three locations are not easily explained but , taken as a whole, are consistent with the observed migration of Trit ium. Fluorescein was detected at low concentrations , a t various times, in carbon samples co llected from the cooling water Discharge Cana L Because of the s ub stant i a l dilution in the canal, the extended release of tracer to the canal and the low concentrations of tracer found in the samples, we believe th ese data represent background conditions 58 , and cannot be used to evaluate the tracer test. 7.6 MAJOR FINDINGS As an overview, the tracer test, supports our CSM and the observed distribution of contamina ted groundwater.

GZA also concludes that:

  • Unsatura ted zone flow is important to the migration of contaminants r eleased above the water table in the vicinity of Uni t 2. Bedrock fractures induce this flow to the South and East of the release.
  • There is s ignificant storage of contaminated groundwater above the water table or in zones of low hydraulic conductivity (homogeneities) in the saturated zone. These features allow a long-lived release of contaminants to the Site groundwater flow field.
  • Observed tracer migration rates are l owe r than calculated theoretical migration rates. As a practical matter, this "migration" indicate s that the use of the est imated average hydraulic cond ucti v ity (0.27 ft/dayo r lxlO-4 cm/sec) will overestimate the volume of groundwater migrating through a g i ve n area. That is, we attribute th e lower transport ve l ocity to be due , in part, to a l ower average hydraulic conductivity.
  • In our opin i on, the trace r test, in conjunction with the Tritium release, indicates that the existing network of monitoring wells can be used to monitor groundwater at IP EC. " It i s noted that Fluorescein is the primary colorant in automobile coolant anli*freezc.

Therefore, leak s from cars to parking lot/road s urfac es can impact surface water bodies via stonn drain sys t ems and/or direct runoff. Fluores<:cin was d e tect ed in the Discharge Canal prior to initiation of the traccr injt'Ction.

further indicating it s prcsence as background. 88 8.0 CONTAMINANT SOURCES AND RELEASE MECHANISMS GZA conducted a review of availab l e co n s truct ion drawings , aerial photographs, prior reports , and documented releases , and interviewed Entergy pe r sonne l to assess potential contaminant sources. T he primary S9 radiological sources identified were the Uni t 2 Spent Fue l Poo l (IP2-SFP) located i n the Un it 2 Fuel Storage Bui ldin g (IP2-FSB) and the Unit I Fuel Pool Comp lex (IP I-S FPs)'" in the U nit I Fuel Handling Bu ilding (IPI-FHB. These two di s tinct so urces are responsible fo r the Uni t 2 plume a n d the Unit 1 p l ume, respectively. No release was iden tified in th e Unit 3 area. The absence of U ni t 3 sou rc es is attribu t ed to the design upgrades incorporated in the more recently constructed IP3*SFP. These upg rades include a stainless s teel liner (consistent with Unit 2 but not incl uded in th e Un i t 1 design) and an add iti ona l , seco nd ary l eak. detection drain system not included in the Unit 2 design. The id e ntifi ed spe cific so urc e mechanism s associa ted with the IP 2-SFP and the I P I-SFPs are di sc u ssed in the fo ll ow i ng sec ti o n s. We have segregated thi s sou rce discussion b ase d on primary co n tami n an t type; those cl assi fied as pr im arily Tritium sources, as associated with the U nit 2 pl u m e, and those classified as primarily Strontium sources, as associated with the Unit 1 plume. While the groundwate r plumes emanating from their respec ti ve source areas can clearly be characterized using eac h plume's primary constituent, radionuclides other than Tritium and Strontium a l so exist to a limit ed exten t and are fu ll y a ddr essed within the context of th e U nit 2 and U nit I plume disc u ssions 61* D iscussio n of the two primary sou r ce types will be parsed fu rth er as f o llo ws:

  • Th e Uni t 2 (Tritiwn) plume so urce analyses will be split i nto: 1) "d irect sources" defined as releases to the exterior of Systems Structures and Components (SSCs); and 2) " indirect sto r ag e sources" rel ated to natur a l hydrogeologic mechanism s i n t he unsaturated zo n e (such as adsorp tion and dead-end f r actures) and poten ti al anthropogenic contaminant retention mechanisms (such as certain subsurface foundation construc t ion detail s);
  • The Uni t I (Stron t ium) plume so urce analyses will be split i nto the mechani s m s specific to the i ndi v idual plum e fl ow paths identified.

S9 1 n addi t ion to sources that d i rectl y impac t g rou ndwa t er, atmospheric deposition from pennined air discharges was a lso ident i fied as a potentia l source of diffuse. low l eve l Tritium impact to t h e groundwa t e r. 60 Al l of the pools in the IPI-SFPs c ontai ne d radio n uclides in t h e past. How ever. onl y the West pool currently co n tains any remaining fuel rod s and a ll of t he other IPI poo l s have been dra ined of wate r. It i s also noted that the U ni t I West pool has been u nd ergo ing increased proce ssi ng to sign ificantly reduce the amount of radioactive material in the pools. Once fuel is TertlQved , th e IPI-SF P s w i l l no longe r constitu t e an active source of g roun dwater c ontamination.

61 C ontam inants associated wi t h the U nit 2 leak were found to be essentia ll y comprised of Tritium. lhe Un it I plume i s comprised primari l y of Stronti u m, but also i n cl ude s Tri t ium and sporadic observation ofCesium-137 , Nickel-63 and Coba lt-60 at low levels in some well s downgradicnt of the IPI-SFP (see Figure 8.3). Ente r gy account s fo r all radionuclide s that can be expected to r each th e river in th ei r r equi r ed regulatory r epo nin g of es timated do se impact. 89 8.1 UNIT 2 SOURCE AREA The majority of the Tritium detected in the groundwater at the Site was traced to lP2-SFP. This pool contains water with maximum Tritium concentrations of up to 40,000,000 pCiIL'2 The highest Tritium levels measured in groundwater (up to 601 , 000 pCi1L 63) were detected early in the investigation at MW-30. This location is immediately adjace nt to IP2*SFP and directly below the 2005 s hrink age cracks. As s h own on Figure S.l, the Tritium contamination

(" the plume 64 ,,) then tracks with downgradient groundwater flow 6S through the Unit 2 T ran sfonne r Yard, und e r the Discharge Canal and discharges t o the river 66 between the Unit 2 and Un it 1 intake struct ures. During review of the following sections, it is important to recognize that only s mall quantities of pool leakage (on the order of liters/day) will result in the Tritium groundwater plume observed on the Site. 62 In contrast.

thc levels of Tritium in the Unit I West pool arc only on the order of 250.000 pC il L. Strontium concentration s in IP2*SFP are on the order of 500 pCilL. 6) The 60 1.000 pCi/L Tritium concentration was measured during packer testing of the open borehole prior to multi*levcl completion. This value is therefore actually a lower bound estimate for depth.specifie Tritium concentration s lit that time. If the multi*level samp lin g instrumentation could have been completed prior to obtaining these da ta (not po ss ible because the packer testing was required to design the multi* level installation), samples would have yielded equal or higher co n ce ntrations.

This conclusion rencet s the limited s tandard l ength and temporary emplacement of the packe rs used during the packer testing, and thus the grea t cr potential for mixing and dilution betwecn zones. as compared to the nume r ou s packers pcnnanentl y installed in the multi* level completion

s. 6-1 It is that Figure 8.1 does nOI show an actual Tritium plume: the i so p1cth s presented contour hound co n centra t io n s for samp l es taken at any lime and any d e plh at a panieular location , rather than a 3-dimen s iona l snapshot of concentration s UI a s ingle lime. As s uch. thi s "plum e" i s an overstatement of the contaminant level s e.xi s l ing al any timc. [I sho uld also be noted thatlhe lightest colored contour interval begin s at one-quarter the USEPA drinking water standard. While drinking water standards do not apply to the Site (there arc no drinking water wells on or proximate to the S i te). they do provide a recogni7.cd.

and highly conservative.

benchmark for comparison purposes).

Lower. but positive detections outside the colored contours are show n as colored data blocks. See figure for additional notes. 6$ It is recognized that low concentrations of Tritium likely extend to the South. all the way t o Unit L This conclu s ion i s supported by: I) the low Tritium concentrations remaining in IPI*SFPs (250 , ooopCi/L): 2) the data from MW*42 and MW*53: and 3) the Tritium balance between that released by the [Pl*SFP s leak and that collected by tbe N C O. The transport mechani s m i s thro u gh unsalUrated z one flow which follows bedrock fracture s trike/dip direction s rather than groundwater flow direction (see sc h ematic of unsaturated zone flow mecbanism included below). The leve l s of Tritium dctected upgradi e nt of IP 2*SFP in monitoring well s MW*31 and MW-32 arc also duc to unsaturated z one tran s port from IP2*SFP a l ong the generally southerly and eas t erly dipping bedrock fractures (sec structural gCQ l ogy analy s i s in Seetion 6.0 and tracer test discussions in Seetion 7.0). 66 A s the Tritium moves under the Discharge Canal. a significant amount discharge s directly to the canal before tbe plume reaches the Ilu dson River. 90

  • , * . -' . -' .-.--. * -. * -. -. -.
  • Hudson --. [:J .* [ Rive r ' . . ... .' I * -. [ I .-' -I UNIT 2 BOUNDING ACTIVITY ISOPLETHS

!!a:_" __ "'_ -..,. ..................

...-..-_

... ---........ -__ 11.) __ ",.._) 5011.. BACKFILL B I!!.DROCK I P1-CB IP2-SFP UNSATURATED ZONE FLOW MECHANISM 91 The IP2-SFP contains both the fuel poo l itself as well as its integral Transfer Canal. IP2-SFP is founded directly on bedrock which was excavated to elevation 51.6 feet for construction of this structure.

As such, this pool's concrete bonom slab is located approximately 40 feet above the groundwater (as measured directly below the pool in MW_30 61). During construction , a grid of steel "T-beams" was embedded in the interior s urface of the 4-to 6-foot-thick concrete pool walls. These T-beam s provided linear weld points for the 6 by 20 foot stainless steel liner plates. Given this construction method, an inter st itial space exists between the back of the lh-inch-thick stainless steel pool liner and the concrete wa ll s. The space i s expected to be irregular 68 and its exact width is unknown , but nominal estimates of a 1/8 to lh inch are not unreasonable for assessing potential interstitial volume. Usi ng the se estimates , the volume of the s pa ce behind the liner could be on the order of 1500 gallons. In addition, the degree of interconnection between the spaces behind the individual liner plates i s also expected to be highly variable given the likely variability of weld penetrat i on into the <'<'T beams." Therefore, the travel path for pool water that may penetrate through a leak in the liner is likely to be highly circuitous. 8.1.1 Direct Tritium Sources Two confirmed leaks in the IP2-SFP liner h ave been documented, as well as the 2005 shrinkage crack leak through the IP2-SFP concrete wa 1l 69. The first liner leak dates back to the 1990 time frame, under prior ownership.

This legacy leak was discovered and repaired in 1992. With the more recent discovery of the concre te shrinkage cracks in September 2005, Entergy undertook an extensive investigation of the IP2-SFP liner integrity.

Within areas accessible to inve stigation, no additionalleaks were found in the liner of the pool itself. However, after draining of the IP2-SFP Transfer Canal in 2007 for further liner investigations specific to the Transfer Canal, a si ngle smal l weld imperfect i on was detected in one of these lin e r plate welds. Thi s was the only leak identified in the Transfer Canal whe re the ent i re su rface and a ll the welds could be and were inspected.

This second liner leak is expected to have released tritiated pool water into the interstitia l space behind this area of the liner plates whenever the Transfer Cana l was filled above the depth of the imperfection (the Transfer Canal is currently drained and this imperfection will be welded leak-tight prior to refillin g the Transfer C anal). All identified leak s h ave therefore been terminated. While additional active leak s can not be completely ruled out, i f they exist, the data 1 0 indicate they must be very sma ll and of little impact to the groundwater

11. 6' While s imilar and lower groundwater elevations persist downgradient to the We s t. the s h allow groundwater elevations are much higher (up to approximately etev. 45 fe et) within only 50 feet to thc Eust (MW-3 1) and Southeast (MW-32) of the pool. 611 The interstitial s pace width and uniformity will be related to the dcgree to which the concrete wall s urface falls wi th in a single plane. Because of the practicalities of forming and pouring concrete wall s. we believe the surface is unlik ely to be While the 2005 leak from the shrinkage cracks doe s not appear to be related to a spe cific l eak in the pool liner. it is considered a **direcl source'* because il still resulted in a release to Ihe exterio r of one of the p lan t*s SSCs. 10 T hese data include: monitored water levels in th e S FP. with variations accoun l ed for based on refilli n g and evapornlion vol u mes: the mass of Tr itiu m migrating wit h groundwater i s small: and the age of the water in th e interstitial space. 71 For examp l e. the 2005 s hrinkage cracks st ill inlermittt:nlly release sma ll amounlS of waler: on the order of 10 10 20 ml/day. This waler could represenl a tran sien t aclive l eak. or il may just be due 10 re s idual water trapped behind the liner plates abo ve the 2005 crack elevation still working its way slowly to the cracks. While this water is contained and prevt:nted from reaching the groundwater, other such small leak s may exist which do reach the !,,'Toundwater.

92 The three identified direct sources are discussed individually In the following paragraphs and shown on the figure below. '" ........ -FSB Ioadinll bay Full Storage Bulldlrtg

..... -....... UNIT 2 FUEL POOL DIRECT SOURCE LOCATIONS 1P2-SFP 1990-1992 Legacy Liner Leak -This leak was first documented o n May 7 , 1992 when a small area of white radioactive precipitate was discovered above the ground s urface on the outside of the IP2-SFP East concrete wall. This boron deposit exhibited radiological characteristics consistent with a potential l eak from the pool. A camera survey was then conducted within the IP2-SFP to identify the location of the associated leak(s) in the liner. The survey initially revea l ed no damage to the liner. However, to further investigatory efforts, divers were utili zed to visually inspect accessible portions of the liner. The divers found i ndicat i ons that the li ner had been gouged when an internal rack had been removed on October 1, 1990. Two hundred and forty linear feet of the North and West IP2-SFP wall welds were then inspected and vacuum-tested to verify that the identified damage was i solated to this one case. No other leaks were identified, and on June 9, 1992, the leak was repaired.

Subsequent analyses conducted by the previous plant o wner indicate that approximately 50 gal l ons per day could have leaked through the liner. This leak rate and the lime sca le of the release event would be expected to fill all the accessible interstitia l space behind the l in er 72. Once the s pace behind the liner was filled to elevation 85 feet (the elevation of the 1990 cracks), water then began to l eak out of the cracks in the concrete wall, with a maximum total release volume of up to 50,000 gallons. Given the very slow release rate (0.035 gaUmin), the porous, hydrophilic nature of concrete, and the location of the leak at approximately five feet above the ground surface, a sig nificant portion of the released water likely evaporated prior to entering the soils. However, given that the soi l s n While the inters t it ia l space was filling up to elevation 85 fect.. any olher cracks or joint s in the concrete wall below t hi s elevation, s uch as those identified in 2005 , l ike l y released contaminated water to the environ men l As discussed below. it is hypothe s ized th a i with time , these su bsurface cracksljoinlS may have beco m e sealed due to precipitation of dissolved compounds , c ith er carried with the pool water or dcrived from the concrcte pool wall. Thi s would have been required to allow retention of pool water in the interstiti a l s pace bclow e l eva tion 85 feet aftcr the liner leak was repaired in 1992 , and thus subsequent l eakage of th e 2005 shrin ka ge cracks. 93 below the leak were found to be contaminated 73 , it i s clear that some port i on of this release entered the subsurface.

While Strontium and Cesium could have largely partitioned out of the pool water to the shallow soils, tritiated water would be expected to have continued to migrate downward to the groundwater.

IP2-SFP 2007 Transfer Canal Liner Weld Imperfection

-As part of the recently completed liner inspections initiated by Entergy in 2005 , the IP2-SFP Transfer Canal was drained in 2007 to facilitate further leak-detection efforts includin g vacuum box testing of the welds. These inspection s discovered a single small imperfection in one of the liner plate welds on the North wall of the Transfer Canal at a depth of ahout 25 feet, which is approximately 15 feet above the bottom of the pool. All of the welds and the entire liner surfac e area of the Transfer Canal have been inspected by one or more techniques and no other leaks were found. Engineering assessments indicate this wall imperfection is likely from the original construction activity since there is no evidence of an ongoing degradation mechanism.

Given that the Transfer Canal i s now drained. this we l d imperfection is no longe r an active leak s ite. However, the hi sto ric practice of maintainin g water in the Transfer Cana l likely resulted in a generally continuous release of pool water into the interstitial space behind the liner over time , and then potentially through the concrete pool walls and into the groundwater.

1P2-SFP 2005 Concrete Shrinkage Crack Leak -During construction excavation in September 2005 for the dry cask storage project , the South wall of the IP2-SFP was exposed and two horizontal "hairline" shrinkage cracks were discovered (see schematic below). These crack s exhibited signs of moisture , though fluid flow was not observed emanating from the cracks. To promote collection of adequate liquid volumes for sampling and analysis, the crack s were subsequently covered with a plastic membrane to retard moisture evaporat i on and enhance water vapo r condensation.

The trapped fluid was drained to a sample collection container.

This temporary collection effort not only provided leak rate measurement capability and s ufficient water for analysis.

it also prevented further release to the groundwater.

n Approximately 30 cubic yards of radio nuclide contaminated soi l s were excavated from the area in 199 2. 94 UNIT 2 SFP 2005 SHRINKAGE CRACKS IDENTIFIED IN SEPTEMBER 2005 Initially, the two cracks were found to be leaking at a combined average rate typically as high as 1.5 Vday (peak of about 2 I/day) from the time of crack discovery/initial containment through the fall of 2005. In early 2006, a pennanent stainless ste el leak containment and collection device was installed.

This containment was also piped to a permanent collection point such that any future le akage from the crack could be monitored and prevented from reaching the groundwater.

Subsequent monitoring through 2006 and into 2007 has indicated that the leakage rate had fallen off rapidly and become intermittent with an average flow rate of approximate l y 0.02 Jlday , when flowing (see figure below presenting shrinkage crack flow rate and Tritium concentration over time). This small amoun t of leakage is permanently being contained and it therefore is not impacting the groundwater. , e ; , ,§ ] ., " .; ,.'"' 2 , 000 Leak collection flow mte and Tritium concentration

"' I . '"' o [1[8107 2!I , ooo , OOO " 20,000,000

'i * . , 1 5, 000 , 000

  • 10,000 ,000 ::: '--§ *0 'I: ---. ,. 4128107 816107 UNIT 2 2005 SHRINKAGE CRACK LEAK RATE AND TRITIUM LEVELS Based upon two years of flow and radio l ogical and chemical sample data, it appears that excavation of the backfill from behind the pool wall caused the shrinkage cracks to 95 begin releasing water trapped in the interstitial space dating back to 1992. This release mechanism is hypothesized to have developed as follows:
  • During the original construct ion , the fuel pool walls developed shrinkage cracks in the concrete upon curing, as is not atypical for concrete.
  • When the pool walls were backfilled with soil, they flexed inward slightly in response to the soil pressures developed during backfill placement and . 74 compactIOn .
  • The pool was then filled with water which exerts an outward pressure against the walls. However, little outward flexure would be expected given the stiffness of the compacted soil backfill , which assists the concrete walls in resisting outward bending motion due to the water pressure.
  • The stainless steel pool liner was punctured in 1990 and began leaking. Over time, this leak filled the interstitial space between the liner and the concrete walls. tritiated pool water then lik ely first le aked out of the l ower-most cracks/joints, such as those responsible for the 2005 leak (e levation 62 to 64 feet), and successively leaked out of higher imperfections until it reached the cracks at elevation 85 feet. At this point, leakage was detected and the le ak was fixed in 1992.
  • At some point during the leakage, the subsurface cracks apparently became plugged with precipitate which stopped the leak age. This allowed pool water to remain trapped behind the liner at an elevation above the 2005 shrinkage cracks, potentially as high as elevation 85 feet. To the extent that the subsurface cracks/joints in the concrete did not all become completely leak-tight, the interstitial space behind the liner was lik ely recharged by leakage from the Transfer Canal weld imperfection (up until Transfer Canal drainage in July 2007) and/or other small leak sites in the liner.
  • With excavation of the soil backfill from behind the southern pool wall, the pressure exerted by the backfill material was sequentially removed from the top to the base of the concrete wall. The elimination of this inwardly focused backfill pressure allowed the outwardly directed water pressure in the pool to flex the wall outward. It is hypothesized that this motion, while li mited, was sufficient to initiate l eakage from the 2005 shrinkage cracks at a rate of approximately 1.5 Vday during the fa ll/winter of2005.
  • The released water is believed to be primarily residual water derived from the 1990-1992 liner leak. However, laboratory results for water samples initially collected from the crack in the September 2005 time frame yielded Cesium-137 to Cesium-1 34 ratios indicating that the age of the water was approximately 4 to 9 years old. This age does not directly correlate with the 1990-1992 release timeframe.

Conversely, the water clearly had exited the pool many years ago. A potential explanation for this intennediate age water is the mixing of water from a then-current small leak in the liner with 1992 age water.

  • Over t im e, the shrinkage crack leak reduced the elevation of the residual water trapped behind the liner to the elevation of the cracks. Beginning in 2006 and through 2007 , the leak rate was observed to have quickly become intennittent with typical leak rates, when leaking , of only approximately 0.02I1day.

These ,. While the 4-10 6-fool-thick concrete walls are st iff, so me ncxure is required for the walls to develop bending s tre sses. 96 subsequent water samples did not contain Cesium-134, indicating that this more recent crack water could, in fact, be old enough to be from the 1990-1992 leak 75.

  • As a corollary to the above conceptual model, the intennediate

-aged crack water may be partially comprised of leakage from the Transfer Cana l weld imperfection. This release pathway could potentially explain the measured intermittent and variable leakage collected in the permanent containment system after 2005. The variations in water elevation and temperature in the Transfer Ca nal are consistent with this hypothesis.

While the Transfer Canal leak water would be recent, it is likely that it would take a substantial amount of time to flow from the North wall of the Transfer Canal to the South wall of the IP2-S FP". This hypothesis is therefore consistent with the lack of s hort-lived isotopes (as associated with SFP water) currently being found in the water from the shrinkage crack. A more significant leak rate with shorter transit times (e.g., the magnitude of the 1990-92 leak) would be expected to, and did previously show, short-lived radionuclide signat ure s.

  • Although several additional theories have also been postulated and investigated, a definitive explanation of the apparent discrepancy in Ces ium age ratios could not be definitively determined.

Th i s discrepancy from the early sample data when the crack location was first investigated was an important factor in Entergy's decision to perfonn intensive pool and ongoing Transfer Canal liner inspections.

  • It can also be concluded from the above data and analysis that any ongoing active leak. in the pool liner , if one exists, must be quite small. Otherwise, the limited volume of the interstitial space between the liner and the concrete wall would transport a more s ubstantial leak to the shrinkage cracks in a short time and the water would thus show a young age 77. 8.1.2 Indirect Storage Sources of Tritium The extensive testing of the IP2-SFP liners to date by E ntergy provides evidence that all direct sources (i.e., releases from SSCs) of Tritium have been identified and are currently no longer contributing radionuclides to the groundwater
78. However, the Unit 2 plume, while decreased in concentration relative to the samples taken just after 7S Cesi um-137 was present at sufficient concentrations that if the water was "youn g", Ces ium-13 4 would have also been present al concentntt ion s above method dete(.1ion limi ts. [\ is further noted that the two isotopes of Cesium should partition to solids at the same ratios. Therefore , preferential removal of the Cesium*134 due to partitioning to the concrete is not an explanation for the lack of thi s isotope in the more recent crack water samples. 76 [t is noted that the scepagt::

path(s) from the liner leak on the North wall of the Transfer Canal to the shrinkage cracks on the southern pool wall is likely to be particularly circuitous.

The interstitial space between these two liners can only be con n ected (if they are connected at aU) at the gate from the Transfer Canal to the fuel pool and/or through imperfections in the concrete walVfloor waterstops or in the co ncret e itself (given the five-foot-thick c oncrete wall separating Ihe Transfer Canal from the SFP itself). 77 As a benchmark, pool water from a one-tenth of a gaUon p er minute leak would be expected to r each the sh rink age crack in less than two weeks given the estimated volume of the interstitial space. n Howe ver, some liIDAll. amount of leakag e cou ld still be on g oing from other potential imp erfections in th e lin er and/or concrete pool wall; large ongO in g leak s would result in conditions inconsistent with the measurements of both !cak rate and water age collected from the 2005 s hrink age crack. A large leak would also be inconsistent with the reductions observed i n the Tritium concentrations in th e groundwater.

97 identification of the 2005 shrinkage crack leak 79 , still exhibits elevated concentrations.

If all of the releases to the groundwater were tenninated, it would be expected that the Unit 2 plume would attenuate more qu i ckly than observed 8o. As such, a subsurface mechanism appears to exist in the unsaturated zone under the that can retain substantial volumes of poo l water for substantial amounts of time. The existence of such a "retention mechanism" is also supported by both the results of the tracer test and the recent evaluation of contaminant concentration variability trends over short timeframes and precipitation events. The tracer test results, discussed more fully in Section 7.0, indicate tha t:

  • Tracer injection directly to the top of bedrock below the above MW-30 did not result in arrivals a t in time frames expected for vertical transport through the fractured bedrock vadose (i.e., unsaturated) zone. In fact, the earliest arrivals and maximum tracer concentrations were detected in and MW-32 at distances of greater than 50 feet from the injection location;
  • Tracer concentrations in MW-30 took longer than expected to reach peak concentrations from the time of first arrival;
  • The tracer concentration vs. time curves exhibit a "long tail;" and
  • The tracer concentrations exhibit significant variation over short periods of time, which may be related to precipitation events moving tracer out of storage. It is, therefore , apparent that once tracer, and thus tritiated water, is released from directly below the [P2-SFP , it does not flow directly down to the groundwater but can be "trapped" (held in storage) for substantial periods oftime. The Tritium concentrations i n were measured on a weekly basis between August 8 and August 30, 2007 (see Section 9.3.1). These data show significant variability in concentrations over these short timeframes.

This variability appears to far exceed that which can be attributed to variation inherent in groundwater samp lin g or radionuc1ide analyses.

Aliquots submitted for tracer concentration testing also showed similar trends. It appears that these variations may be the result of the displacement of water, as evidenced by both tracer and Tritium, from this storage mechanism by infiltration such as associated with precipitation events. Based on the above summarized infonnation, two indirect storage mechanisms are postulated to explain the persistence of the Unit 2 plume. The first is the storage of tritiated water in dead-end fractures in the unsaturated zone. The second is the potential for tritiated water from the SFP to be trapped in the backfill above the The earliest samples taken from directly below the SFP in MW-30 (open bo r ehole and packer te s ting samples) yielded Trit ium concentrations over 600,000 pCilL. More currently, maximum concentrations detected have bee n below half of those initial concentrations.

8(1 Rapid attenuation of the Tritium plume would be expected based on 1) Tritium's lack of partitioning to solid materials in the subsurface:

and 2) the crystalline nature , low s tomtivity and high g roundwater gradients associated wi t h the bedrock on th e Site. S l Prior to constructing a stru(..1ural base slab (typically 2 to 5 fcet thick) for the fuel pool, a 6-10 8-inch-thick, lean concrete **mud-mat'* is typically constructed over blasted bedrock to evcn out the irregular rock surface and provide a 98 which was placed prior to construction of the SFP structural base slab. A combination of these two indirect s torage mechanism s, as discussed separately below, is a conceptual model that explains the observed Unit 2 plume behavior in the context of the termination of the identified direct release mechanisms

82. Dead-Ended Bedrock Fracture Storage -Naturally occurring bedrock fractures, as discussed in Section 6.0, are seldom long, continuous linear features.

Rather, they are more typically networks of interconnected, discontinuous fractures.

These networks often contain many dead-ended fractures.

While dead-ended fractures are not subject to advective groundwater flow, they still can contain high contaminant concentrations. Contam inants enter these fractures through osmotic pressures set up in the subsurface by concentration gradients (initially high concentrations at the fracture "mouth" and low concentrations within the fracture).

Over time, these concentration s equilibrate through liqu id-phase diffusion.

Therefore, under conditions of high Tritium groundwater concentration s, such as likely occurred during the two year timeframe of the 1990-1992 liner leak, the dead-ended fractures would be expected to end up containing high Tritium concentrations.

Once the liner leak was repaired , the input of Tritium to the groundwater would subside and the concentrations in the advective fractures would start to decrease.

However, the high Tritium concentrations within the dead-ended fractures would then start to diffuse back out of the dead-ended fractures into the groundwater flowing past them, thus maintaining higher than otherwise expected Tritium concentrations in the groundwater.

Our computation of the volume of the naturally occurring dead-ended fractures in the unsaturated zone below the IP2-SFP yields fracture volumes which are unlikely to s upport the observed Unit 2 plume for the required time frames (years). However, two additional considerations substantially increase the dead-ended fracture volume: I) the observed unsaturated flow to the East and Southeast (this migration pathway exposes many more fractures to the Tritium due to the bigger area involved); and 2) construction blasting (which creates more fractures in the bedrock remaining below the s tructure).

As demonstrated vividly during the tracer test, contaminants released to the bedrock at the bottom of the SF? travel at least 50 to 75 feet to the Eas t and Southeast as evidenced by the high tracer concentrations quickly detected in the upgradient monitoring wells hard. flat surface upon which to se t the r e i nforcing rod "chairs" (these chairs the l owest layer of rods to provide sufficient concrete corrosion prevention cover). 82 It is not ed that we or iginall y believed that the groundwater in the Unit 2 Transronner Yard was uncontaminated with Tritiu m prior to February of 2000. I r true, th is finding would be inconsistent with the storage mechanisms proposed.

Our original conclusion was based on the sampling results at that time from MW-llJ: this wel1 was s ampled as part of the due diligence for property transfer to Entergy and was found not to contain Tritium above detection limit s (900 pCi/l.). Hov.'e v er, interviews with facility personnel revealed that the sample was collected from the upper surrace of the water table with a bai l e r. Thcr c was no attempt t o purge the well to obtain samples representative of deeper aquifer water because the samples were taken primarily to look for !1oatin g oil in the well. Because th is sample was collected from th e upper groundwater surface (which will be most subject to infiltration b y rain water) without adequate well purging, it is likely that this samp l e resu lt was biased low. As discussed in Section 9.0. this w ell is subject to wide varia tion s in Tritium concentrations due to rainfal1 events. Therefore.

it is entirely plausible that no Tritium was detected above labo ratory method detection l imits even i f Tritium were present at much higher concentrations deeper in the aquifer. As s uch , this February 2000 groundwater samp l e result should not be used to assess Tritium groundwater co ndition s at that time. See support ing data in Section 9.3.1. 99 MW-31 and MW_32 83; the same behavior would be expected for Tritium. This wide areal distribution would substantially increase the volume of dead-ended fractures available for storage of contam i nants. In addition to naturally occurring fractures, the founding elevation of the SFP was achieved through construction blasting of the bedrock. While the bulk of the blasted rock was removed to allow construction , a zone of much more highly fractured bedrock typically remains after the founding elevation is reached. While these blast-induced fractures may be intercoIll1ected, they may not be fully connected to tectonic fractures that intersect the groundwater, and thus would be dead-ended. Therefore, contaminated water may be stored in these fractures and periodically escape in response to precipitation events. Blast-Rock Backfill Storage -Following blasting of the bedrock to accommodate the IP2-SFP foundat ion , standard construction practice would have been to pour a mud_mat 84. Based on construction photographs , it appears that the areal extent of the blasting was not much bigger than the dimensions of the structural slab for the SFP; this would be typical given standard contracting specifications and the cost of blasting.

Therefore, it would be expected that the mud-mat was poured directly against the face of the bedrock excavation, without the use of fonns. This hypothesis was continned visually during the 2005 excavation alongside the IP2-SFP for dry cask gantry crane foundation construction.

The concrete for a mud-mat is typically placed in a relatively fluid state to enhance se lf-leveling properties.

As this fluid concrete is placed, it is typically pushed up against the perimeter fonns, or in this case the bedrock face. This placement procedure would be expected to coat and seal off the fractures in the lower portion of the bedrock sidewalls.

While the height above the surface of the mud-mat to which this seal would be fonned is highly variable and occurrence-specific, it would not be unreasonable to find a 2-to 6-inch high "lip" of concrete against the bedrock. The net effect would have been to create storage volume above the mud-mat, between the sides of the subsequently constructed structural floor slab and the bedrock sidewa ll s directly at the base of the SFP. While this space was lik ely filled with blast-rock fill, the pore volume of this material available for pool water storage could easily be over 30 percent of the total volume. T hi s results in a substantial storage volume when compared to that required to "feed" and maintain the U nit 2 plume over time. During the 1990-1992 liner leak, a large volume of highly tritiated water appears to have been released from the pool, thereafter traveling down the exterior of the SFP concrete wall. This travel path would place the pool water directly into the hypothesized storage containment.

Once full, additional pool water would overtop the containment , migrate into fractures that were not sealed off by concrete, and then travel through the unsaturated zone. Once in the unsaturated bedrock, some tritiated water would quickly 3J Tmcer reached MW-3J and MW-32 in less than four hours (time of fir.>t sample), thus supporting the conclusion of unsaturated zone transport to these locutions.

84 A. 6-to 8-inc h, lean concrete *'mud-mat'*

is typically constructed over blasted bedrock to even out the irregular surface and provide a hard flat surface upon which to set the reinforcing rod *'chairs'* (these chairs elevate the lowe s t layer of rods to provide sufficie nt co ncrete cover for corrosion prev ent ion). 100 reach the groundwater and some would be retained in dead-ended fractures, as discussed above. Over time, rainfall event s would be expected to repeatedly displace pool water out of the containment and into the bedrock fractures.

Contaminated water would therefore continue to impact the groundwater even if all active leak s from the pool were tenninated.

We believe this process could continue over substantial periods oftime 85. 8.2 UNIT I SOURCE AREA The Un it 1 contamination , as shown on Figure 8.2 and the figure included below, is often referred to as the Strontium "plume"s6. Th i s is because the other radionuclides detected, including Tritium, Cesium-137, Nickel-63 and Co balt-60 , have a sma ller radiological impact when compared to Strontium-90 and the Strontium is found in the entirety of the plume's areal extent , while the other contaminants are found only spora dically and in smaller subsets of the plume's area. The Tritium data for the Unit 1 plume is included on Figure 8.1 and the Cesium-l 37, Nickel-63 and Cobalt-60 data are presented on Figure 8.3. --. -. . -* r.-* .' * " ':' -J" ... .... -tr" * * . . * * --. .. .. ! . ,.-,.., i l uNiT3) ! ,'.;------...... < .-.-! .', . _., .--.... ; .--.-..... ,-..... -.... ...... ,-. -. L ***n -. --: ....... [ -, ,w Hudson R i ver UNIT I BO UNDING ACTIVITY ISOPLETHS 15 See footnote No. 58 above rel ative to the reported T ritium results for MW-II I as sa mpl ed in Mayof2000.

1!6 It is noted that F igure 8.2 does D.Q1 show an actual Strontium plume: the isop!cth s presented contour upper bound concentration s for sam pl es taken at an y lime and any d e pth at a particular location, rather than a 3*dimen sional sna p s hot of concentrations at a single time. As such, this "plume" is an overstatement of the contaminant levels existing at any time. It should also be not ed that the lightest co l ored contour interval begins at one-quarter th e USEPA drinking water standard. While drinking water sta ndard s do not apply to the Site (there arc no drinking water wells on or proximate to t hc Site), they do provide a r ecognized, and highly conservative benchmark for comparison purposes).

Lower , but positive det<<tions outside the colored contours are show n as colored data blocks. Sec figure for add ition al notes. 101 The hi g he st le vels of Strontium (up to 110 pCi lL) were originally found adjace nt to the No rth side of IPl-SFP s in MW-4 i". H owe ver , s ince En tergy began processing the pool waler to rem ove the Strontium, the levels of Strontium (and other r adio nucli des) in thi s well have decreased.

From MW-42 , th e U ni t I " plume" tracks downgradi e n t with the g roundwat e r along the No rth side of the Un it I S uperhe at er and Turbine Buildings 88. As thi s plume a pproache s and move s under the Discharge Canal, i t comming les with the U ni t 2 plume , and discharges to the ri ve r 89 between the Uni t s I and 2 intake struc tur es, as does the U nit 2 plu me. As discussed in Section 6.0 , the plume track appears to fo ll ow a more fractured, higher conductivity preferential flow path in this area. The so urce of all the Strontium contamination detected in g roundwater beneath the Site has been established as the [PI-SFPs. The [P I-S FPs were identified by th e prior owner as le ak ing in the mid-1990's, and are estimated to currently be leaking at a rate of up to 70 gallons/day.

A sche matic of this pool complex is included below. ,-... / , ./. ....W .. lPOOI I!., U NIT I FUEL POOL COMPLEX The IPl-SFPs were constructed of r ei nf orced concrete w ith an internal l ow penneability coa t ing 90; s tainless steel liners were not included in the design of these early fuel pools. The pool wa ll thickne ss ran ges from 3 to 5.5 feet thi ck. The bottom o f the [PI-SFPs i s IT The highe s t conccnlrations ofthc other co ntam inants associat ed w ith th c U nit I plume. including Cesium-I 37. Nickel-63 and Cobalt-60 were also found i n well MW-42. Thi s location i s very close to th e IP1-SFP s and it is t herefore not unexpected to find t h ese hi ghe r concentrations of l ess mobile radionuc1ides near the source. " This genera l introductory discussion of th c Unit I plum e i s focused speci fi ca ll y on t hc "primary Unit I plum e." Further more detailed disc u ssio n of the other "secondary Unit I plume s:' whieh all originate fr om the IPI-SFPs. is c r ovidcd in s ubsequent su b sect ions. 9 As i s th e case wi t h the Tritium from the Unit 2 p lu me. some S tr o ntium discharges direct l y to the Discharge C anal before the p lume reaches the Hudson Ri ve r. 90 The origina l coati n g failed and was subseque ntl y r emoved. 102 founded directly on bedrock, generally at elevation 30 feet 91. As such, there is no significant unsaturated zone below the IPI-SFPs. While all of the pools have been drained except the West the other poo l s have a ll contained radionuclide at various times in the past. The West pool, which is approximately 15 feet by 40 feet in area, currently contains the last 160 Unit 1 fuel assemblies remaining from prior plant operations.

This plant was retired from service in 1974. The IPl-SFPs are contained within the IPI-FHB. The foundation system of the FHB and IP 1-CB complex contains three levels of subsurface footing drains (see figure included below). The design objective of these drains, with the potential exception of the Sphere Foundation Drain (SFD)92, appears to be permanent depression of groundwater elevations to below the bottom of the structures

93. North and South Curtain Drains -The uppermost IPI-FHB drain encircles the Unit 1 FHB and IP l-CB. This footing drain, typically referred to as the Curtain Drain, is divided into two sections, the North Curtain Drain (NCD) and the South Curtain Drain (SCD). Each of these drains starts at a common high point (elevation of 44 feet) located along the center of the eastern wall of the FHB. These drains then run to the North and South, respectively , and wrap around the Unit I FHB and CB. The NCD then discharges to the spray annulus in the IP l_C8 94 at an elevation of 33 feet. From the annulus, the water is pumped for treatment and then discharged.

The NCD flows at a yearly average of about 5 gpm carrying a Strontium concentration of 50 to 200 pCilL (concentrations measured prior to reductions in Unit 1 pool water radionuclides via accelerated demineralization). The SCD pipe remains as originally designed with discharge to the Discharge Canal; however, the SCD is typically dry95. Chemical Systems Building Drain -The lowest level of the IPI-CSB (contained within the FHB) is also encompassed by a footing drain. The eastern portion of this drain begins at a high point elevation of 22 feet at its northernmost extent, located proximate to the IP I-C8, and then slopes to elevation 11.5 feet at its low point on the southern side of the IPt-CSB. The western portion of this drain begins at a high point elevation of 12.5 feet at its northernmost extent, again located proximate to the IP 1-C8, and then slopes to elevation 11.5 feet at its low point on the southern side of the Both portions of the drain join at the southern side of the IPI-CSB where the common drain line runs below the floor slab and drains into the [PI-SFDS (bottom elevation of 6.5 feet). This drain typically flows 91 The bottom elevation of the individual pools range from a high elevation of36 feet for the Water Storage Pool to a low of 22 feet for the Tran s fer Pool. 92 The SFD is constructed at an elevation of 16.S feet. [t is above lhe bottom of the Sphere (elevation

-I I feet) and comp l etely encapsulated in either concrete or grout. 9;1 The elimination of hydro s tatic uplift pre ss ures allow s a "relieved d es ign" to be u s ed for the bottom concrete s lab s of the structures.

The alternative to a relieved slab design is a ""boat slab design:* In this casco the slab is heavily reinforced to re si st hydrostatic uplift pres s ure s. Boat s lab s are mor e expen s ive to con s truct than r e li e ved s lab s. and thu s arc typically only used when it is not feasible to relieve the hydrostatic uplift pressures.

94 This design modification within the IPI*CB , to allow storage of the footing drain water prior to treatment., was implemented by the fonner owner once the water was found to contain radionueHde

s. The initial Unit I d es ign connected the two 12-foot perforated footing drain lines into a common IS-inch tee and drain pipe at the entrance to the Nuelear Service Building. Thi s IS-inch footing drain pipe was collocated in the bedrock trench containing t he s pray annulus to CSS drain line. 95 The lack of waler in the SCD is consistent with the expected impact of the CSB drain givcn its proximity and lower elevation.

103 at a yearly average of 10 gpm canying a Strontium concentration of not detected (NO) to 30 pCiIL. DRAJN (SCD) sros .""",GE--'-CHE". SYS. CURTAIN DRAJN (NCO) NOT TO SCACE ./ * ./ BUILD ING (C SB) DRAIN UNIT 1 FOOTING DRAINS AND DISCHARGE SUMP Sphere Foundation Drain* The third foundation drain below the IPI*FHB and lPI*CB complex is the SFD. This drain is loc ated directly around the bottom portion of the Sphere and consists of: 1) nine perforated pipe risers spaced around the sphere and tied into a circumferential drain line at elevation 13.75 feet; 2) each vertical riser is surrounded by a graded crushed s tone filter; and 3) al l of which are within a clean washed sand which encompasses the Sphere from e l evation 25 to 16.5 feet (the " sand cus hion"). The sand cushion is " sandwiched" between the concrete foundat i on wall , the Sphere and the grout below the Sphere; it i s open at the top , proximate to the annulus. As such, it appears that this drain does not interface with the groundwater , except to the extent that some leakage may occur through imperfections in joint seals. This drain is also connected to the SFDS through a valve. During the development of the initia l Conceptual Site Model , it was understood that the IPI-SFPs were cu rr ently l eaking, but it was concluded that the footing drainage s ys tems would contain any releases from the IPI-S FPs. This was also the conclusion ofa previous analysi s performed for th e prior owner in 1994 96* This conclu s i on wa s based on:

  • The proximity of the drains to IPI*SFPs; in fact , the NCD runs alo n g the North and East walls, and in conjunction with the SCD, completely encompa sses the [PI*SFPs;
  • The generally downgradient location of the drains relative to the IPI-SFPs;
  • The elevation of the drains relative to the bottom of the IPl-SFPs; 96 Ass es sm e nt o f Groundwater Migration Pathway s fr o m U nit I Spent Fll e l P oo l s 01 Indian Point P o w e r Plant , Bu c hanon, NY; Th e Whitman C ompanie s, July 1994 104
  • * *
  • The elevation of the drains relative to the surrounding groundwater elevations 97; The continuous flow of the drains, even during dry periods; therefore, the groundwater surface does not drop below, and thus bypass, the drains; The reported predominant southerly strike and easterly dip of the bedrock fractures relative to the southerly location of the CSB footing drain; this expected anisotropy should extend the capture zone of this drain preferentially to the North towards the !PI-SFPs; and The existence ofIPl-SFPs pool water constituents in the drain discharge 98. In February 2006, Strontium was detected in the downgradient, westerly portion of the IP2-TY (downgradient of IP2-SFP). Given that Strontium could not reasonably be associated with a release from the Unit 2 SFP, the most plausible source remaining was the retired Unit 1 plant where: I) the SFPs hi storically contained Strontium at approximately 200,000 pCilL (prior to enhanced demineralization 99); and 2) legacy leakage was known to be occurring. Based on this finding, we concluded that either: I) an unidentified mechanism(s) must be transport i ng JPl-SFPs leakage beyond the capture zone of the footing drains tOO; or 2) other sources of Strontium existed on the Site. A number of plausible hypotheses potentially explaining each of these two scenarios were therefore developed, and then each was inve stigated further. During these investigations, additional detections of Strontiwn were also identified, including some relatively low concentrations in the area of Unit 3. However, with completion of the investigations and associated data analyses, it was concluded that all of the Strontium detections could be traced back to leakage from the IP J-SFPs. These Strontium detections can be grouped into five localized flow paths, each associated with a different lP I*SFPs release area. Co llectively , these flow paths define the overall Unit I " plume JOJ" as listed below:
  • The primary !P I flow path;
  • The eastern IPI-CB_flow path;
  • The southwestern IPI-CB.flow path;
  • The IP I-CSS trench flow path; and
  • The legacy IPI stonn drain flow path. Thi s line of evidence remained supportive of the initial conclusion until the installation of MW-53. which occurred during the third phase of borings (after the discovery of Strontium in the g roundwater).

91 Drain water is treated prior to discharge as permitted monitored e ffiu en t. 1>9 S t rontium levels in IPI-SFPs have been more recently reduced to approximately 3.000 pCi/L under accelerated liltering through demineralization beds. Tritium concentrations in IP I-SFP s are on the ordcr of250,ooo p C i/L. 100 Once Strontium-contaminated pool leakage enters the groundwater, it i s transported in the direction of groundwater flow: Stront ium. as well as the other potential radionuclides , do not migrate in directions opposing g roundwat er flow (with the exception of diffu s ive flow which is insignificant as eompared to adveetivc flow under these hydrological conditions).

Therefore leakage entering the groundwater within thc capture zone of the footing drains is captun:-d by those drains. 101 The grouping of Strontium detections inlO contiguous "plumes" may be an over-simplification, and the detections may. in reality be due to small, isolated individual groundwater entry points and flow paths from the IPI*SFPs. This is lik e ly to be particularly true pursuant to the [PI Lcgacy Piping "flow path:' 105

....... "'-00 __ .. _, . --... = EASTERN o I P1-C 8 FLOW P A T H -;.I:.... I J" .. .. , LEGACY IP1 sToRki!'DRAIN' FlowPATH' ...::" ... . , '. " _ .. .-, '4.

  • j SOUTH WESTERN :. \ W<l I T1] : IP1-CBF L OWPATH: t \ -'. 't o ....... ; . ;r .'" .-I I * * . ' I , 0 , .-n... . * * *
  • Hudson River r __ _..:" :" :"

INDIVIDUAL UNIT 1 STRONTIUM FLOW PATH LOCATIONS The discuss i ons below are focused on the discovery and characterization of these individual flow paths, and the final mechanisms that best explain their existence.

Other initially plausible mechanisms were also investigated as part of the Observational Method approach employed l02 , but they did not remain plausible in light of the subsequently developed data and analyses, and are therefore not discussed herein. In addition , portions of the discussions below also relate to the concurrent investigation of other potential source areas across the Site. During review of the following sections, it is important to recognize that only small quant i t i es of leakage are required to result in the groundwater plumes observed on the Site. Primary IPt Flow Path -Monitoring well MW-42 was initially installed to investigate the premise that contaminants may be leaking into the subsurface from the IP2-Reactor Water Storage Tank (RWST). However, the sample analysis made it clear that I PI-SFPs water was present in the groundwater at MW-42; the radiological profile was consistent with 102 As indicated above , multiple initially plausible hypotheses potentially explaining the genesis of these flow paths were developed and inve s tigated. The s e inve s tigation s proc e eded in a s tep-wise , iterative manner con sis tent with t he Observational Method , whereby variou s aspects of the Conceptual Site Model (C SM) were modified to develop an overall CSM that better fit all of the data. Not all mechani s m s investigated remained plausible in light of a l l the data and ana l y ses developed part of thi s hypothe s i s-te s ting. 106 Unit 1 fuel pool water (low Tritium, high Strontium and Cesium). While IPI-SFPs leakage was known to be ongoing, this conclusion was not consistent with the CSM at the time which was predicated, in part , on containment of IPl-SFPs leakage by the footing drains (North and South curtain Drains, and the Chern. Sys. Building Drain). An additional monitoring well, MW -53, was subsequently installed downgradient of MW-42 (on the Northwest side of the IPI-CB). Groundwater in this well was also apparently impacted by IPt-SFP water, thus resulting in the initial s tep s in the identification of the Unit t primary Strontium flow path. The groundwater elevations measured in MW-53 proved even more enlightening than the radiological profile. In the case of a continuously flowing footing drain such as the NCO , groundwater would generally be expected to be flowing into the drain over the entire length of the drain; the corollary to this conclusion i s that the groundwater e l evation would be above the drain invert along its entire extent. Otherwise, water flowing into the drain along its eastern, upgradient extent would exfiltra te the drain along its western, downgradient extent and thus, water would no longer discharge out of the end of the drain into the [P l-CB Spray Annulus; it would therefore not typically be continuously flowing. However, the groundwater elevation in MW-53 was measured at approximately elevation 9 to 10 feet, substantially lower than the water table elevation in MW-42 (35 feet) and the elevation of the NCD invert (33 feet). Therefore, it was found that on ly a portion of the groundwater which infiltr ated the drain to the East was observed as continuous flow at the Spray Annulus collection point. The remainder of the water was exfi lt rat in g along the drain further to the West l03 , where groundwater elevations were below the drain invert and thus outside the capture zone of the drain. Therefore, leakage from the IPI-SFPs was initially being captured by the NCD , but then during transport to the Annulus for collection and treatment, a portion of this leakage was discharging to the groundwater outside th e capture zone of the drain. This leakage then migrates downgradient to the West with the grou ndwater and establishes the Unit I primary Strontium flow path. Eastern IPI-CB Flow Path -A S trontium plume is shown on Figure 8.2 as existing be l ow the entire IPl-SFPs. With the exception of MW-42, there are no monitoring wells in this area to verify that this plume actually exists. However, it is known that the IPl-SFPs have and continue to leak, and the NCD and CSB footing drains have been shown to contain radionuclides consistent with that expected from IPl-SF Ps' leakage. The locations of the specific release points are not known, but could be anywhere a l ong the walls and bottom of the IP I-SFPs. Once leakage from any of the above postulated points enters the groundwater, i t will migrate either to the NCO or the CSB drain, depending on where the specific release point is lo cated relative to these drains. Leakage located along the northeastern portions of the IPl-SFPs is likely to migrate to the NCD (elevation 33 feet), whereas leakage located more to the South and West is more likely to migrate to the lower CSB drain (elevation 22 to 1 0J [t is hypothesiud that, in the past, the drain lik e ly did not flow continuously.

However. over lime, the exfiltration rate has been reduced through siltation such that the drain can no longer release water ovcr its western extent as fast as it intiltmtes into the drain further to the East. 107 11.5 feet). These scenarios, when considered for multiple potential release points, should result in Strontium flow paths that are all contained within the plume boundaries shown on the figure. Southwestern IP]-CB Flow Path -As part of the investigations to identifY other potential releases to the groundwater across the Site, low levels of Strontium (less than 3 pCilL) were detected in mon i toring wells MW-47 and MW-5 6. Groundwater contamination in this area was inconsistent with the known sources and the groundwater flow paths induced by the IPI-CSB footing drains. A s ummary of the investigations and analyses undertaken to identifY the release mechanism responsible for this Strontium flow path follows. Construction drawings indicate that the 1PI-CB and the 1PI-FHB were constructed with an inter-building seis mic gap and s tainless steel plate between the two s tructures.

This construction detail creates a preferential flow path for any pool leakage through the western walls of the IPI-SFPs, as well as leakage from other loc atio n s which migrates to the western side of the IPI_SFPS 104. While thi s "plate/gap" separates the structures all the way do wn through the struc tural foundation slabs, it likely would not h ave p e netrated the mud_mat I05. In addition, it would not be uncommon for the surface of the mud-mat to not be c o mpletely cleaned prior to pouring of the structural slab. Even small amounts of soil, mud , dust, etc. between the mud-mat and the structural slab above would res u lt in a preferential flow path a l ong the top of the mud-mat. Therefore, it is expected that pool leakage in thi s zone (between the s tructural slab and the mud-mat) could flow laterally and would still be isolated from the fractured bedrock below. It would then, in turn, also be isolated from the influence of the footing drains (both the NCD and the lPl-C SB drain). To the extent that the above hypotheses are correct, this leakage could then build up and flow along the plate and above the top of the mud-mat. With sufficient input of leakage from the pool, the elevation of this flowing water could also rise above the top of the lPI-CB footing.

With the above hypothesized conditions, pool leakage may migrate along the plate all the way around the IPt-CB to the South and West until it reaches the end of the plate (at the intersection of the perimeter of the IPI-CB with the 1PI-FHB). At that location, the water would follow the of the mud-mat (and/or top offooting) along the IPI-CB bottom slab further to the West 1 7. This leakage flow path is highlighted on Figure 8.2. The leakage water would not be constrained 10 flow into the SCD given that this footing drain is dry. Once past the end of the plate, the pool leakage could enter the bedrock at multiple points, wherever it encounters bedrock fractures.

T hereafter , the leakage would enter the groundwater and thus be constrained to migrate in the direction of groundwater flow. 1()4 This hypothesis is funher supported by the presence of weeps of contaminated water (SFP leakage) in the e3stcrn wall of the IP I-CB at th e footing wall joint. lOS While not sho wn on th e constructions drawin gs reviewed "as required", construct i on photos show that a mud-mat was p l aced prior to rebar cage construction (a lso sec discussion of rationale under Tritium source areas above). Given the consistent bottom e l evatio n s of both the VC and the SFPs s tru ctural co ncr ete s lab s. a s in g l e mud-mat was likely constructed.

106 Leakage now above the top of the footing (elevation 33 feet) to the East and Southeast of the VC would not be captured by the SCD given that this dmin is dry. 107 Sce discussion of likely mud-m atlbed rock excavation wall configuration and the impact of precipitation events in the section above under Trit ium so urce areas. 108 As shown on the figure , pool leakage entering the groundwater along the South side of the IPI-CB wou ld be expected to mound the groundwater somewhat.

This is particularly true in this case given the leakage entry point within the "fla t zone" encompassing the groundwater divide between flow to the river to the West and flow to the East to the CSB footing drain lO8* The portion of the pool leakage which flows West would fonn the southwestern IPI-CB Strontium flow path and thus explain the low leve l s of Strontium found in MW-47 and MW-5 6. From this point, the "plume" continues to flow West and joins the primary Strontium flow path. IPI-CSS Trench Flow Path -During the course of the investi gat ion for potential sources, MW-S7 exhibited significant Strontium concentrations.

Strontium was also detected in the upgradient IPI-CSS, located in the Unit 1 Superheater Building.

This s ump was investigated to evaluate the extent to which it may be associated with the contamination identified to the West, near the Discharge Canal. A retired subsurface pipe, designed to drain water from the Unit 1 Spray Annulus to the CSS, was detennined to be the input source path for water observed within the sump. During Un it 1 construction, this pipe was installed within a 3-f oot-wide trench cut up to 20 feet int o bedrock, which slopes downward from the Spray Annulus to the CSS 109. Construction drawings further indicate that this trench was backfilled with soil. This pipe had been temporarily plugged in the mid-1 990's when contaminated water from the NCD was routed to the Spray Annulus. However, the temporary inflatable plug was later found to be leaking and the pipe was then permanently sea l ed with grout. As part of our investigations, a monitoring well (UI-CSS) was installed horizontally through the East wall of the CSS at an approximated elevation of 4 feet. This horizontal well is connected to a vertical riser which extends to above the top of the ess. Water level s in this well typically range from elevation 12 to 18 feet and re spond rapidly to precipitation events. Based upon avai l able data , we believe the IPl-eSS is not a source of contamination to the groundwater.

Inspections of the sump indicate the likely entry point for water periodically found in the sump is the pipe from the IPI Spray Annulus, the joint between the concrete sump wall and the sump ceiling (the floor of the Superheater Building), and/or the joint in the su mp wall where the pipe penetrate s from the rock trench into the sump. These conclusions are based on:

  • The groundwater elevations measured in UI-CSS are above the bottom of the ess which i s generally nearly empty (bottom elevation of 1.0 feet);
  • The results of the tracer test confirmed that contaminated groundwater can enter the CSS when it is empty; and
  • Visual inspections of the interior of the sump and associated piping. 10& While a groundwater divide must exist between the eSB footing drdin and riv e r to t h e WeSt, the exaet l ocation of the divide is unknown. 1 1)9 The tre nch bottom starts at elevat ion 22.75 feet at the Spray Annulus and slopes gradua lly to elevatio n 2 1.75 feet at a point 9 feet from the e55. From this point, the trench s l o p es steeply to elevation 1 3 feett at the CS5. 109 This sump is no longer in service as the system it supported is retired. While the ess itself does not appear to be a release point, we believe the associated bedrock trench between the Spray Annulus and the C SS is a sourc e of contamination to the groundwater.

As in d icated above, the Spray Annulus is used to store releases collected from the IPl-SFPs by the NeD, which contains contaminants.

The Annulus water has been historically documented as leaking into the pipe and surveys indicate that the pipe itself likely leaks into the trench. While the leak into the pipe from the Spray Annulus was sealed, other leakage inputs to the trench also likely exist. One s uch likel y leakage path is for water to flow directly from the NeD through the drain backfill and abandoned piping I 1 0 to the pipe trench. This flow path is supported by the trends in VI-e SS water elevation var i ation as compared to the NCD discharge rate (see figure included below). .S . ; , , '=' ';; = = * " , " "' \5 -_NCO flow TlIIe 1 " " '' 4113i06 612106 7f22i06 9!10A>6 10130106 1 2119106 2/1107 3f29/o7 5/111107 7n/07 8126/07 1 01)5107 UNIT I NCD FLOW, UI-CSS GROUNDWATER ELEVATION AND PRECIPITATION RELATIONSHIPS 18 " " c p 'i :; " , 8 These hypothesized leakage paths are highlighted on Figure 8.2. Once leakage enters the trench, it should flow along the sloped bottom until it finds bedrock fractures through which to exfiltrate.

This leakage will then flow through the unsaturated zone along the strike/d i p of the fractures until it encounters the saturated zone, and thereafter will follow groundwater flow. Because of these hypothes i zed, but probable condi t ions, we concluded that leakage has exited the trench and impacted groundwater.

Impacts directly to the groundwater below the pipe trench are characterized by Strontium concentrations in monitoring well V I-eSS. In addition , source inputs to the groundwater from the trench are also envisioned to h ave occurred farther to the South, where the groundwater flow would then carry contamination to MW-57 , thus explaining the Strontium concentrations found in that welll)l. Whi l e sou t herly flow in this area is i nconsistent with groundwater flow direction , source inputs can migrate from the bedrock trench to the South in the unsaturated zone near th e 11 0 A s not e d above. the N C D discharge w as rerouted into the S pray Annulu s when the NCD was found to contain conlaminants by the previous owner. Prior 10 lhis modification , the footing drain was roUled to a 15-inch drain line collocaloo in lhc CSS pipe trench. T he abandoned pipin g and permeable backfill s till exisl and likel y act as an anthropogenic preferential flow palh. 1 11 Monitor ing wells Ul*CSS and MW-57 do not appear to be in the groundwat er flow path of the primary Unit I **plume.'" 110 CSS, where the unsaturated zone is relatively deepl1 2. This hypothesized unsaturated zone flow path is s hown on Figure 8.2, as well as the schema tic included below . lfIII:_oI

___ ** -_ ..... -.. _ .... --_ .. _--

_",Io"--, __ --.......... . " , I P1 -CB IPI*CSS TRENCH UNSATURATED ZONE FLOW MECHANISM In add i t i on, the construction details of the Superheater Eas t wall may a l so channel satu r ated flow to the South. depending on variation in groundwater elevations.

These le ss direct l eakage inputs th en establish the s outhern portion of the source area fo r the CSS trench flow path such that the groundwater flow carries the " plume" through monitoring well MW-57, thu s explaining the Strontium found in samples collected from this wen ll3. Le gacy IPt Storm Drain Flow Path -As summarized above. the CSB footing drain collects groundwater from the vicinity of the IP1-SF Ps; this water ha s been documented to contain radionuclides.

The contaminated water i s then conveyed to the SFDS, located at the southern end of the CSB. In addition , historical events , including CSB sump tank overflows in Unit 1, have impacted the SFDS. Prior to construction of Unit 3, water collected in the SFDS was pumped up to elevation 65 feet and di sc harged to the storm water system on the South side of the Unit 1 CSB. The discharge was conveyed by these drains to the South lOwards catch basin UI-CB-9 (c urrentl y under the access ramp to Unit 3), and then West (U I CB*IO) under what i s n ow the £P3-VC toward the Di scharge Canal. This pathway was re-routed during construction of Un it 3 i n the early 197 0s t o fl ow South from catch basin U I*CB*9, then further South towards catch basin U3*CB*A4 and s ub seque ntly to the Di s charge Canal throu g h the 112 The hypothesized SQ uth e rl y now of a portion of the tren ch l ea ka ge to th e So ut h through th e un sat urated zo ne is co n s i s tent with: I) the s trike/dip direction of major joint se t s found on Site: and 2) the groundwatcr flow path from the re s ultin g unsaturated zone input to thc well s which identified this S trontium flow path. II) Th is w e ll appears to be located outside. and upgradient of , th e prim ary Unit I Strontium flow path to the North. I I I E-Series storm drains. (See figure included below and Figure 8.2 where these pathways are also highlighted.)

-" ',-,-,-!. ----, -, 1 1 1 I'L -. J " -, i1 _ ....... --: .. --. -' [I Legend Pre Unil35'""" era", P_., ............. ) (_...., 700) S_ DnWI P_IY -...... ,_cn;np_1Y

-_z-,L-+ Hud son . ' w-I I 1 1 ". ,-o 10: ",:: River DIFFERING SPHERE FOUNDATION DRAIN SUMP DISCHARGE PATHWAYS OVERTIME A recent in spection of the storm drain system, including smoke tests and water flushing, has revealed that a number of pipes along these sections have been compromised and are leakin g. Strontium found in groundwater on the South side of the Un it 1 FSB, and upgradient ofVnit 3, is coincident with the locations of these stormwa ter pipes. Therefore, we concluded that some of the contaminated water discharged into these pipes ex filtrated, and then migrated downward through the unsaturated zone and contaminated the groundwater, thus resulting in the " legac y" s torm drain flow path l14 shown on Figure 8.2. In 1994, this discharge route was changed again, when contamination was detected in the emuent from the Unit 1 S FDS. The pipe leading from the SFDS toward s Unit 3 was capped, and discharges were thereafter routed directly to the Discharge Canal through a series of interior pipes as well as a radiation monitor. As such, the storm drain lines to the 114 Three discrete isopleths h ave been drawn around MW*39. MW-41 and MW-43 given the measured concentrations grea t er than 2 pCi/L. However. it is expected thaI s imilar c oncemration s exist at other locations along the legac y piping alignment in addition to those s how n on the figure. During the historic active discharge 10 th e stonn drain s. it i s expected that the individual leak areas ..... ould have resulted in comming lin g of th e groundwater contamination into a single **plume" area. This **p lume'* would have then migrated downgradicnt across the Unit 3 area. With the cessatio n of discharge to the s tonn drains. the **plume** atte nu ated over time. leaving down gradient remnants which are still d etectable as low level Stron tium co ntaminati on in Unit 3 monitoring wells suc h as MW-44. 45 & 46 , U3*TI & 2. and U3*2. 112 South of Unit 1 no longer carry this contaminated water and they are therefore no longer an active source of contamination to the groundwater.

However, from a contaminant plume perspective, these historic releases still represent an ongoing legacy source of Strontium in the groundwater to the South side of Unit 1. This is because Strontium partitions from the water phase and adsorbs to solid materials, including subsurface soil and bedrock. The Strontium previously adsorbed to these subsurface materials then partitions back to, and continues to contaminate, the groundwater over time, even after the stonn dra in releases have been tenninated.

As shown on Figure 8.2 , low level residual evidence of this legacy pathway was identified in monitoring wells installed to South of Unit 1 during the course of the investigations proximate to potential sources assoc iat ed with Unit 3. Strontium, Cesium and Tritium were detected in these wells at levels below the EPA drinking water standard.

Three monitoring wells to the South of Unit 1 show "Legacy Stonn Drain flow pat h s" drawn around them. These wells have yielded samples at one time/depth with Strontium concentrations greater than 2 pCilL, or one-quarter of the Strontium-90 drinking water sta ndard. While the actual extent of these Strontium concentrations is not known given that each has been drawn around a single point, they appear to be limited in extent (based on the data from the surrounding monitoring wells). It is also important to recognize that the specific locations of the historic releases from the stonn drain lines are not known. In addition, once water has exfiltrated from the drain line, it moves generally downward in the unsaturated zone as controlled by the strike/dip direction of the specific bedrock fractures encountered.

Therefore, legacy groundwater contamination does not have to be located immediately downgradient of the storm drain system (as exemplified by the Strontium found in MW-39 and tracer in MW-42). While three isopleths are shown on Figure 8.2, we believe it is possible that other areas in the general vicinity of this piping may exhibit similar groundwater concentrations.

We have a l so concluded that the lower concentrations of Strontium detected in monitoring wells further downgradient , in the Unit 3 area, are also due to these historic, legacy storm drain releases.

113 9.0 GROUNDWATER CONTAMINATION FATE AND TRANSPORT Strontium (the U nit I plume) and Tritium (the Unit 2 plume) are the radionuclides we used to map the groundwater contamination.

The investigation focused on these two contaminants because they describe the relevant plume migration pathways, and the other Site groundwater contaminants are encompassed within these plumes. While radionuclide contaminants have been detected at various locations on the Site, both the on-Site and off-Site analytical testing, as well as the groundwater elevation data, demonstrate that groundwater contaminants are not flowing off-Site and do not flow to the North, East or South. Groundwater flow and thus contaminant transport is West to the Hudson River via: 1) groundwater discharge directly to the river; 2) groundwater discharge to the cooling water canal, and 3) groundwater infiltration into stonn dra i ns, and then to the canaL The primary source of groundwater Tr itium contamination i s the IP2-SFP. The resulting Unit 2 plume extends to the West , towards the river , as described in subsequent sections.

T he source of the Strontium contamination is the IP I-SFPs. Previous conceptual models, based on infonnation presented in prior reports, indicated that releases from the IPl-SFPs were likely captured through collection of groundwater from the Uni t 1 foundation drain systems. However, based upon groundwater samp li ng and tracer tes t data, we now know that the Unit 1 foundation drain system , particularly the NCO, i s not hydraulically containing all groundwater contamination i n this area (see Section 8.0). GZA's understanding of the Tritium sou rc e and Strontium source are discussed in more detail in Section 8.0. The p l umes described on the figures in the following subsections are based on: 1) the isopleths bounding the maximum concentrations , as representative of "worst case conditions" I IS (Figures 8.1 and 8.2); and 2) the most recent laboratory data collected through August 2007, as representative of current conditions (Figures 9.1, 9.2, 9.3 and 9.4). While the figures showing upper bound isopleth concentrations do not show actual conditions, we believe these graphics are useful in developing an understanding of groundwater and radionuclide migration pathways.

In reviewing this section please note the plumes show our current understanding of how an th ropogenic features influence groundwater flow patterns, in particular the various footing drains and backfill types used during construction.

Also note that flow in the liS It is noted that these li g ures (F igures 8.1 and 8.2) do not show actual plumes: the isoplcths present contoured upper bound concentrat i ons for samples taken at any time and any depth at a particular location. rather than a 3-dimensional snaps hot of concentrations at a single time. As such. these "plumes" are an overstatement of the contaminant levels existing at any time. It should also be noted that the lightest co lor ed contour inh:rval begin s at one-quarter the USEPA drinking water standard. While drinking water standa rds do not apply to the Site (there are no drinking water well s on or proximate to the Site). they do provide a recognize d. and highly conservative benchmark for comparison purposes).

Lower. but positive, detections outside thc colored conto u rs arc sho wn as colored data blocks. See figure for additional notes, 114 unsaturated zone plays an important role in both the timing of releases to the water table and in the spread ing of contaminants.

Based upon the results of aZA's geostructural analysis, the extent of contaminated groundwater , the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Pumping Test , the tracer test and tidal response tests, we believe that the bedrock underneath the Site i s sufficiently fractured and interconnected to allow the Site to be viewed as a non-homogenous and anisotropic porous media. Based on this finding, and because advection is the controlling transport mechanism, groundwater flow, and consequently contaminant migration in the saturated zone, is nearly perpendicular to groundwater contours on the scale of the Site. 9.1 AREAL EXTENT OF GROUNDWATER CONT AMINA nON Based on measured tracer velocities (4 to 9 feet per day; see Section 7.4), the limited di s tance s between release areas and the river (typically less than 400 feet), the age of the plumes (years), and recent interdictions, we believe contaminant plumes have reached their maximum size and are currently decreasing in size_ Co nsequently , our reporting in this section focuses on observed, "current" conditions (the summer of 2007). That is, we saw no need to mathematically predict future conditions.

9.2 DEPTH OF GROUNDWATER CONT AMINA nON Because of the location of Indian Point on the edge of the Hudson River, the width of the river, and the nature of contaminants of potential concern, groundwater flow patterns (and, consequently , contaminant pathways) are relatively shallow. Furthennore, as discussed in Section 6.0, the upper portion of the aquifer (typically, the upper 40 feet of the bedrock) has a higher average hydraulic conductivity than the deeper portions of the bedrock. Consequently, the center of mass of the contaminated groundwater is s hallow. Figures 9.1 and 9.2 are cross sections which s how the approximate vertical distribution of Tritium and Strontium, near the center lines of the Unit 1 and Unit 2 plumes , in the summer of 2007 ("current conditions

"). In reviewing these figures, note that Strontium was not found below a depth of 105 feet in MW-67. We attribute the low concentrations of Trit ium below a depth of 200 feet at this location, at least in part, to the downward migration of Tritium during our inve s tigations.

For example, by nece ssi ty , well RW-J was an open wellbore for a period of time ll6 which allowed vertical groundwater migration , a lo ng an art ificial preferred pathway, deeper than would occur along ambient flow paths. 9.3 UNIT 2 TRITIUM PLUME BERA VIOR As sho wn on Figures 8.1 and 9.3, the Unit 2 plume exhibits T ritium concentration s originating at the fP2-SFP. The higher concentration isopleths are shown around the entire 116 RW-l is located immediately below the 2005 shrinkage crack leak (high Tritium concentrations in shallow groundwater).

This well had remained as an open w el1bo re for periods o f time in preparation for and during: I) the drilling of the wellbore;

2) the packer testing: 3) the geophysical logg ing: and , 4) the Pumpi ng Test. During th ese ti mes. vertically downward grad ien ts likel y mov cd some Tritium to level s deeper than it would otherwise exist. When possible, this wellborc h as been sea l ed ove r its entire Icngth using a Flute Liner Systcm. 115 pool area so as to incl u de the location of the shrinkage crack leak in the South pool wall, the loca tion of the 1992 leak on the East wall, and the location of the weld imperfection in the North wall of the [P2 Transfer Canal. We believe the core of the plume, as shown, is relatively narrow where Tritium flows downgradient (westerly) to and MW-III in the Transformer yard 1l7. This delineation is based on: 1) the degree of connection ll8 observed from MW-30 to MW-33 (as compared with that from MW-30 to MW-31 andlor as being indicative of a zone of higher hydraulic conductivity limiting lateral dispersion; and 2) the localized increased thickness of the saturated soil in the vicinity of MW -III (see Figure 1.3) which likely behaves as a local groundwater sink/source for wes t erly bedrock groundwater flow, prior to entering the associated backfill of the Discharge Canal. " I I ", * -. . . -.-.-_ .. -; * !. Hudson .-.-' I I ' , [l.
  • R i ver " -'. .

.', . .' -, -:.; BOUNDING UNIT 2 ACTIVITY ISOPLETHS

.-T ritium has been detected in and both of which are upgradient of the [P2-SFP. As evidenced by the tracer test (see Section 7.0) and hydraulic heads, this 111 The: bedrock in this area was excavated via blasting to allow foundation construction.

As such. Ihc uppcr portions of the bedrock are lik e ly highly fractured in this area. In addit ion , the pr e.construc tion bedrock contours (see Figure 1.3) indicate that the particularly deep depression in thc bedrock in the Transfonncr yard in the vicinity ofMW*1 1 1 (filled with soil down to elevation 0 feet) was likely excavated to serve as II dewatering sump. The associated deeper blas t ing. induced frdcturing and the saturated soil backfill are also likely to further increase the transmissivity in th is area. ". The degree of connection is inferred based on both the similar stat i c water l eve l s in MW*30 and *33 (separated by over 100 fcct), as contrasted to the much higher water levels in MW*J I and *J2located about 65 feet from MW*30. and the rapid change in water elevat ion in MW*30 in response to water level perturbations in MW*33 (e.g., during drillingl!mmpling), with little or no response in MW*31 and *32. 116 occurrence involves gravity flow a l ong bedrock fractures in the unsaturate d portion of the bedrock beneath the IP2-SFP. This unsaturated flow direction i s con s istent with the dominant foliations (which strike to the Northeast and dip to the Northwest).

T hi s beh a vior is s hown on the figure by dashed arrow s and the isometric ins e rt (see Section 8.1). This mechanism also accounts for some of the T ritium found near Unit 1 and is als o s upported by the results of the tracer te s t (see Section 7.3). H owever , once the contaminated water enters the local groundwater flow field , it migrate s via advection in a direction generally perpendicular to the groundwater contours (i.e., with the groundwater flow). In the IP2-TY , the plume i s drawn a s more di s persive in re s pon s e t o the concentration s measured in MW-34 and -35 as well as the high degree of connect i on observed between MW-33, -34 and -35 along an orientation transverse to the general groundwater flow direction.

See the figure below for a schematic of the three dimensional fracture orie n tations in this area that account for the observed lateral di s persion. In thi s general area , the Unit 2 plume is bounded to the South by MW-54 and to the North by MW-52. 33 34 3 Tranaml ** lv. I"r.ctu .... In MW*34 and MW*35 at App r oxIm a t e ly EI,v , tlon 3 3 -DIMENSIONAL BEDROCK FRACTURE ORIENTATIONS At the we s tern boundary of IP2-TY , Tritium flow s into the hi g hly conductive soil backfill found along the eastern wall of the Discharge Canal (see Figure 1.3). This conclusion is s upported by both the groundwater elevations and Tritium concentrations in MW-36. The groundwater elevations with depth in MW-36 indic a te that once in the Discharge Canal backfill , the groundwater flows downward below the canal wall and , subsequently , into both the Discharge Canal (lower water elevation in the canal) as well as under the canal through the bedrock fractures (see Section 6.7.2.2 for an estimate of the relative flows to these two discharge l ocations).

Once on the western side of the Discharge C anal, as evidenced by groundwater elevations and Tritium concentr a tions in MW-37 , -49 , and 117

-67, groundwater flow and Tritium migration is to the Hudson River, via both bedrock and unconsolidated material along the riverfront.

The spe cific flow path for the Tritium detected in MW-37-22 (located in the fill on the West side of the canal) is not certain. It is however associated with either: 1) upward groundwater flow into the backfill from the bedrock beneath the canal, as supported by the upward vertical hydraulic gradients;

2) groundwater flow into the blast rock fill on the West side of the canal, with northerly flow in the fill to, and around the North end of the canal and then southerly along the East side of the canal to MW-37; and/or 3) exfiltration from the stormwater piping between MH-4 and MH-4A into the fill on the western side of the canal, with a similar flow path as described in 2). See Section 7.5 for additional information.

Regardless of the upstream flow path to MW-37-22, the groundwater flow direction from this location is westerly toward the Hudson River. Also note that the exact pathway to this location does not change the results of the groundwater flux calculations to be used in radiologic dose impact assessments.

Both Figures 8.1 and 9.3 show a southern component of flow as the Tritium migrates West towards the river. This pathway corresponds with the location of several East-West trending fractures zones and a fault zone. It is likely that this area is characterized by a zone of higher transmissivity that induces the contaminated groundwater to migrate as shown on these figures. We also note that it appears groundwater flow from higher elevations to the North also impedes a more northerly contaminant migration pattern. 9.3.1 Short Term Tritium Fluctuations During our investigation, we observed short term fluctuating Tritium concentrations that we cannot reasonably attribute to a continuous release ll9 (see Table 5.1). These fluctuations make drawing an accurate representation of a plume, on any single date, difficult because any single sample may not be representative of the overall water quality in proximity to the sampling location.

In the case of T ritium associated with the IP2-FSB , we believe the fluctuations are associated with temporal variations in the release of contaminated groundwater from the unsaturated zone to the water table. T hat is, we believe the unsaturated zo ne acts as an intermittent , ongoing source to the groundwater flow regime (see Section 8.0). The following graph shows the results of T ritium vs. time in samples collected from MW-30 , located adjacent to the lP2-SFP. 119 In addition, our r eview of sampling procedures and labora tory methods did not expla in the variations observed in samples collected from monitoring well MW-30. lIS C4) 700.000 . -i\1W.JOTrW_m

_ .... e.Ioo .........

600."" *

  • Iow*tbw/pa<:ket

.........

I * """"*tbw/pa<:",,'

deep I

  • *
  • w"""loodeep
  • p<e<:opUl1Clll
  • . S 400.000 , * * * , ** 300,000 0 *C
  • i " 200,000 , 8 , ..............

,'--./// --.. 100,000 * , * * '-11)'1 S05 2Jllo06 4Il)}06 .,"" 8111Kl6 11)'10.06 ' "'" mm -'' TRITIUM CONCENTRATIONS AND PRECIPITATION VS TIME FOR MW-30 Similar temporal vanatlOns in Tritium concentrations are observed in data generated by testing of samples downgradient of IP2-SFP at MW-33-34-35 and -Ill; see the following figure: 350,000 .,. MW-3J, -34, -35 ,-1 1 1 Triliarn * +

  • ___ MW.33 _MW.3.( -o-MW.)s 100." I * * , :; 150.000 I +
  • 100.000 so,." J o I " 91510S l OO3IOS I2II4IOS 212106 lI24106 5113106 7f21(X:, 8121105 1 0l'1Ml6 TRITIUM CONCENTRATIONS VS TIME FOR MW -33, -34, -35 AND -Ill MW-lll i s a sha1low overburden well completed to a depth of 19 feet below ground s urface (bgs). Thi s well is located in a soil-filled bowl-shaped depression within the Transfonner yard (see Figure 1.3), Consequently, the concentrations of Trit ium in samples collected from MW-lil are more sensi tive t o precipitation (and th e likel y assoc iated exfiltration from the proximate storm drain) than samp le s collec t ed from other wells in this area (see above). In particular, note the substantial decrease in T ritium concentration as shown on the following graph , in sample s collected after significant precipitation events in October 2005 and May 2006. 119 350.000 MW_.n,.J4,.J5,_111
  • M W-13 300,000 ** Tritium o MW-1 4 0 Il MW-JS *
  • 2SO.ooo '. .MW_l 11 t* S F O ol << 'i. 200,000 .. .. 0
  • E o *
  • 1 50.000 ** * :E 0 * ... ,
  • 100.000 , ' "" 0 lO , ooo ' ' , B " 0 0 0 4 6 10 12 Prctipillllion IOIIlI tOr 7 dllYs prior 10 sampling, in. TRITIUM CONCENTRATIONS VS PRECIPTIATION 9.3.2 Long Term Variations in Tritium Concentrations Recognizing the limitations posed by short tenn fluctuations , we constructed Figure 9.3 , which s hows t he l a teral extent of Tritium contamination i n th e late s ummer of 2 007 ("current conditions

"), ,-' " , ...... ,. ..... . ... , \ , ' * .,Y ! '-"1'1 i r "., '-' ' \

  • If.':" "-',! i'-"1'J ........ -. * .-..' .'. , !. * . --..* 41.' ** ,;;., " .--.--".'. -, --'*-1 1 -" ." * .'. ... ' .........
  • n ::'J ,,--* .-"---;-* [ I I .. , o r-o Hudson R i ver CURRENT UNIT 2 PLUME 120 .--.

Our review of this figure , in conjunction with Figure 8.1 12 0 and Table 5.1, reveal s the following:

  • Despite interdictions , the lateral extent of the two plumes (i.e., the Tritium plume vs. the bounding isopleths) is similar. This indicates storage in the unsaturated zone remains important, and that previous releases did not generate significant groundwater mounding.
  • The highest concentrations remain in the area of lP2-SFP. This i s consistent with the observed re l at i vely higb (4 to 9 feet pe r day) groundwater transport velocities and an ongoing but smaller release from the un saturated zone.
  • Interdictions made at the lP2-SFP appear to have resulted in measurable reductions in Tritium groundwater concentrations over the entire Unit 2 plume lengthl2t.

The larger reductions in Tritium concentrations are most evident in the source area, closer to the IP2-SFP (see table below). ANALYSIS OF TRITIUM CONCENTRATIONS OVER TIME Max. Observe "J Monitoring Tritium Well Concentrations (pCVL) 601000 MW-30 302000 MW-III 107000* RW-( 40600 MW-31 44400 MW-32 264 000 MW-33 276000 MW-34 119000 MW-35 55200 MW-36 44800 MW-37 3980 MW-42 13 200 MW-53 13 100 MW-55 10800 MW-50 9 100 MW*66** 4860 MW-67**

  • Sample obtained during Pumping Tesl. ** Only one samp le analyzed.

Current '£, Tritium Concentrations (pCVL) 92000 98800 30600 37700 14,200 23000 22200 5950 12500 6680 1600 8050 9910 4500 9100 4 , 860 (1) Any depth, any date at the indicated location.

Elapsed Time between Max. and Current Concentrations (davs) 657 629 3 39 406 390 476 510 494 400 490 346 263 427 0 0 (2) Maximum concentration , at any depth , report ed during the last proj ect sampling event at the indicated location s. Current Cone. As Percent of Maximum 15 33 48 93 32 9 8 5 23 72 40 61 76 42 100 100 120 When comparing the U nil 2 (Trit i um) plume s hown on Figure 9.3 with the bounding i sopleths presented on Figure 8.1 , the anal yses/method s used to develop the bounding isopleth s need to be full y con s id e red -please refe r to Sulion 8.0. m As based on monitoring

..... ell data over the plume length do",m to and acro ss the Di sc harge Canal to MW-37, as well as the apparent migration velocity of Tritium in the groundwater observed on-Site. Data from monitoring

..... ell s downgradiem of MW-37 have not been sampled over a suffiCie ntly long period of time to confirm this conclu s i on. Further analy s i s of th e plume behavior will be conducted as the Long Term Monitoring Plan data is developed over time. 121 9.4 UNIT I STRONTIUM PLUME BEHAVIOR Figures 8.2 and 9.4 illustrate the migration paths for Strontium.

These flow paths represent Strontium originating from an ongoing legacy leak(s) in the IPI-FHB (see Section 8.0). This leak explains the Strontium levels detected in MW-42. This well i s loc ated in close proximity to the NCO!2l, with the upper screen spann ing the elevation of the drain (e levation 33 feet) and the lower screen located approximately 35 feet below the drain elevation.

This well exhibits upward vertical gradients from the bedrock into the overburden and the NCO. Therefore, a release through a crack in the Water Storage Pool wall (a l so fonns the wall of the FHB), for example, would fl ow down through the backfill and into the drain where it would enter groundwater near monitoring well MW-42. However, as described in Section 8.0 , the NCD is not 100% effective in hydraulically containing leak s from the IP I-SFPs. Contaminated pool water collected along the eastern portion of the NCD is rele ase d from the NCD via exfiltration as the groundwater elevations drop below elevation 33 feet towards the West; this is one source mechanism responsible forthe Uni t I Plume. -), -.. ..... ".--. ... -.. . . --. ... . --. ---r * -. .:.--_.-. * ** h_ . ..;. .. --:.-; -. -, .-. r '\ _ .. ". ." *

  • r... " , , I I _.-. -_ ... ,., I::. _ I I.....J. "'. 'I I II * -' . Hudson River -. ......... .. . . . J BOUNDING UNIT I ACTIVITY ISOPLETHS 1:2 [t is noted that MW-42 is screened in the bedrock s l ight[y North of the drain. As such. it i s located h y draulicall y upg,radient o f the drain. The drain should therefore fonn a s i nk between the pote n tial leaks and the well. thu s cap t uring con t aminants from the F HIl f u rt her S outh. with the well only encountering groundwate r flowin g from the No rth to thc South towards the drain (i.e., the well shoul d not sample groundwater in communication with IPI-FHB leaks). H owever. during min events, it appears that t he groundwater elevations at the drain can i n c rease to a point w h ere th e groundwat e r flow direction is temporarily reversed (flow s from the NCD northward past MW --42) due to th e high inflow s associated with s tonn drain leak s (stonn drain s being repaired.

and/or taken o ut o f se rvice). This flow reversal can depos i t Strontium on fracture surfaces aroun d MW-42 , which lat er e nter s the well during purging. 122 The easternmost portion of the overall Unit I plume is s hown to ex ist below the entire fPI-SFP s. aZA termed this the eastern Unit 1 CB Flow Path. Strontium-contaminated groundwater in this area will migrate either to the NCD or the CSB drain, depending on where the specific release point is located relative to these drains. As discussed in Section 8.0, the overall Unit I plume also extends to the West towards MW-47 and MW-56. GZA tenned this the southwestern U nit I CB Flow Path. Once the contaminated water enters the groundwater on the South side of U nit I , it flows either East to the CSB footing drain or to the Northwest towards Hudson River , depending on the hydraulic gradient at the l ocation where the release reache s the water table. In addition, we believe the bedrock trench that contained the Unit I Annulus-to-CSS drain creates a preferential pathway (through the backfill within the bedrock trench), further aiding the transport of Strontium-contaminated groundwater to the West. aZA tenned thi s the Unit 1 CSS Trench Flow Path. Once leakage enters the trench, it should flow along the sloped bottom until it finds bedrock fractures through which it will exfiltrate.

T hi s leakage will then flo w through the unsaturated zone aJong the strike/dip of the fracture s until it encounters the saturated zone, and thereafter will follow groundwater flow. This pattern i s illu stra ted on Figure 9.4 by dashed arrows to the West of U nit 1. It results in a sp re ad ing of Strontium-contaminated groundwater, which then flow s with groundwater to the Hudson River. Figures 8.2 and 9.4 also s how the Strontium contamination related to releases from legacy piping. These historic releases from the drain pipes are currently manifested as spo radic , low level detections of Strontium in groundwater wells (MW-39 , -41 and -43) along the legacy piping. Note, as shown, thi s spa tial distribution of contamination is not a re sult of groundwater contaminant transport to the South; rather it i s a result of multiple r elease points along the piping. In summary, thi s contamination repre sents residual contamination which has attenuated and decayed over time , and will not result in further sign ificant mig ra tion. Once outside the drain capture zo ne , the Strontium migrates West towards the lower groundwater elevations measured in the LP2-TV and along the walls of the Discharge Cana l along the so uthern end of the lP2-TB (MW-36 , -55 , -37 , -49 , -50 and -67) (see Figures 8.2 and 9.4). A more southerly track is not anticipated because: 1) the higher groundwater elevations measured in MW-58 and -59 just to the South of the lPI TGB; and 2) the likely existence of low conductivity concrete backfill along the inside of the IPI-TB walls, it s s ubbasement, discharge piping and eastern Discharge Canal wall (as contrasted with the much higher conductivity blast-rock backfill likely used in the lP2-TY and along the outside of the IPI-TGB walls as well as adjacent to the upgradient IPI structures).

In addition , as discussed in Section 6.0 and shown on Figure 6.2, there are North-South trending faults in the vicinity of MW-49, MW-61, and MW-66 , which are characterized by 123 clay-rich fault gouge 123. In aZA's OpInion (see Section 6.4.5), these zones of low hydraulic conductivity limit the southerly extent of contaminated groundwater.

In addition, this area is characterized by the two discrete plumes (Tritium and Strontium) comm i ngling and following the same flow path West towards the Hudson River. We attribute this flow pattern to a zone of higher transmissivity located between Units I and 2. Also note this area of higher flow is accounted for in our groundwater flux calculations. The Unit 1 plume in the Transfonner yard area is shown as widening due to Strontium concentrations detected in MW-lll and MW-36. This widening may reflect the increased thickness of the saturated zone soil deposits around MW-lll, or the presence of high conductivity backfill around the Discharge Canal. This conclusion is supported by the hydraulic heads that indicate groundwater flow to the North along the canal as discussed above pursuant to the Unit 2 plume and the tracer test. West of the Discharge Canal, the Strontium pathways correspond to those described for the Unit 2 plume in Section 9.3. 9.4.1 Short Term Strontium Concentrations As observed with Tritium, it appears that Strontium groundwater concentrations fluctuate, over short durations, more than can be reasonably explained l24 (see Table 5.1)by a continuous release at generally constant concentration.

We attribute these fluctuations to variations in flows in the [PI-NCO, which are directly influenced by precipitation events (see Section 8.2). That is, we postulate that as flows in the drain vary, so do the concentrations and/or volumes of Strontium contaminated water being released.

9.4.2 Long Term Variations in Strontium Groundwater Variations We used the results of the last sampling event to construct the current Unit 1 plume (see Figure 9.4 and Table 5.1). In reviewing that figure (see below). note the overall configuration is similar to that of the bounded Unit I plume (see Figure 8.2 1 25). The major difference between these plumes is the decrease in concentrations shown in the immediate vicinity of the IPI-SFp l26. We attribute this decrease in Strontium concentrations to the increased rate of demineralization of the IPI-SFPs water (overall source of the plume). I:) 'Illis conclusion has been verified in the areas where the gouge was confirmed with split spoon sampling. See individual boring log s in Appendix B for funher. more detailed.

infonnation.

1 24 Fo r example, our revi e w of sampling procedure s and laboratory methods did not explain the variations observ e d in samples collected from monitoring well MW-42. IlS Who;:n comparing the Unit I (Strontium) plume s hown on Figure 9.4 with the bounding i so pleth s pre s ented on Figure 8.2, the analyses/methods used to develop the bounding isopleths need to be fully considered

-please refer to Section 8.0. 126 It should be noted that the latest data just recently received (well after the repon data-cut-otf-date of August 31 , 2007) for MW-42 shows an increase to 46 pei/L. This increase, however, s till remains within levels consistent with an overall reduction in concentrations in this area. as attributed to accelerated demineralization of the IP I-SFPs. 124

,-, II: .-. -.-' r UNIT 2) -. -. .-.' * .-. -. -----.. ' .-* ... _ .. -. -I " '. -..... . . .. : ..... -E' ! \ \ ...... * "'" _. *** '; : .. .. * !. -.... I. * .', . .... . -, .

  • 1.-.. r...., -----. I * ...... * * -* -* H udson c'-' r--''"e; I." 1.1 -r .. " .... R iv er ... ,. ...... CURRENT UNIT I PLUME ,. -L I However , because of the timing of the interdictions and, we believe, the slower groundwater transport rates for Strontium, overa ll the Unit 1 plume has not decayed to the extent the Unit 2 plume has decayed (see Section 9.4.1). In fact, due to what we attribute to short tcnn Strontium fluctuations , at six of the well locations within the Unit I plume, the highest Strontium groundwater concentrations were observed during the last project sampling event (see the following table for additiona l detail). In reviewing both figures , note th at they show what we believe are conservative estimates of the lateral distribution of the higher (25 pCi/L) Strontium g roundwat er concentrations.

125 ANALYSIS OF STRONTIUM CONCENTRATIONS OVER TIME Max. Monitoring Currene) Elapsed Time Current Observed (I) Well Strontium between Max. Cone. As Strontium Concentration and Current P erce n t of Concent ratio n (pCi/L) Concentrations Maximum _(PCuL) (day,) 110 MW-42 20.1 490 18 ,0) 37 MW*53* 37 0 100 3.6 MW-47* 3.6 0 100 2.7 MW-56 2.4 332 89 26.8 UI-CSS* 26.8 0 100 21.9 MW-54 19.2 88 88 40.4 MW-55 34.0 263 84 45.5 MW-57 3 7.9 44 83 5.0 MW-36 2.3 483 46 29.8 MW-3 7 23.3 40 78 31 MW-50* 31 0 100 25.6 MW49* 25.6 0 100 19.1 MW-67"" 19.1 0 100** -6.2 MW-66"" 6.2 0 100 it Cu rr ent concentration is the maximum concentration of sam ple s analyzed at thi s monitoring well . .. Only one sample analyzed.

(1) Any depth , any event , at the indicated location.

(2) Any depth , on the date of the la st project sampli n g event , at the indicated location (3) It should be noted thai the latest data just recently received (well after the report data-cut-otf

-date of August 31, 2007) for MW-42 s hows a n increase to 46 pC il L. 126 10.0 FINDINGS AND CONCLUSIONS At no time have analyses of existing Site conditions yie ld ed any indication of potential adverse environmental o r health risk , as assessed by Entergy as well as the principal regulatory authorities.

In fact, rad i o logical assessme nt s have consisten t ly s hown that the releases to the environment are a s mall perce nt age of regulatory limits , and no threat to public health or safety. In this regard, it is also important to note that the groundwater i s not used as a sourc e of drinking water on or near the Site. Consisten t with the purpose of the inve st i gat i ons , we have deve l oped s ix major supporting conclusions which are described in the fo ll owi n g su b sect i ons. Based on our findings and conclusions, we are recommending completion of source interdiction measures with Monitored Natural Attenuat i on as the preferred remedial measure. Refer to Section 11.0 for more information, includin g our reasons for making this recommendation. 10.1 NATURE AND EXTENT OF CONTAMINANT MIGRATION The primary groundwater radiological contaminants of int e re st are Tritium and Strontium.

Other contaminants (Ces ium-137, N i ckel-63 and CobaIt-60) have been detected, but are limited to areas that h ave groundwater pathways dominated by T riti um and/or Strontium , and are accounted for i n Entergy's dose calcu l at i o n s. Groundwater co ntamin at i on i s limited to Indian Po i n t's p r operty and i s not m i grating off-p r operty to the North, East or South. The contamination migrates with the Site groundwater from a r eas of hi gher he ads to areas of l ower heads along paths of l east resist ance, and ultimately discharges to the Hudson River to the West. This is supported by the bedrock geo l ogy, multi-l evel groundwater elevation data and the radiological resu l ts from analytical test i ng. The nearest d r inking water reservo ir s are located at distances and elevations which preclude impact s from contaminated groundwater from the Site and there i s no nearby use of groundwater.

a. The Site is located over a portion of the aquifer basin where Site-wide ambient groundwater flow patterns , both sha llow and deep , have been defined. These flows are towards the Site from higher elevations to the North , East and South. Groundwater flow on Site enters the Hudson River through: footing drains (which di sc harge to the Discharge Canal); the D i scharge Cana l; the storm dra i n system; or direct d i sc h arge. The results of over two years of in vest igations demonstrate that the off-Site groundwater migration to the South , as originally hypothe s ized by others prior to these in vestigations, i s not occurring.
b. Surface water samples collected from the Algonquin Cree k , the Trap Rock Quarry and from the drink i ng water r eservoirs do not ex hi bit impact s from the Site. c. The Hudson River is the regional groundwater sin k for the area. We found no Site data , pub li s hed information , or other reasons suggest i ng that g roundwater would migrate beneath the river. To the contrary, based on the a r ea's hydrogeologic setting and all available information , we are confident that groundwater beneath the Site discharges to the river. 127
d. Because of the hydraulic properties of the bedrock , the bedrock aquifer on-Site wi ll not support large yields, o r accept input of lar ge volumes of wa t er. e. There are no identified off-Site uses of groundwater (extrac tion or injection) proximate to the Site that influence groundwater flow patterns on the Site. Furthennore, we have no reason to believe that potable or irrigation wells will be insta ll ed on or near the Site in the reasonably foreseeable future, in part because municipal water is available in the area. f. Groundwater flow at the Site occurs in two distinct h ydraulic regimes that are vertical l y connected, bedrock and overburden soils. Mo s t of the groundwater flow and contaminants are found in the bedrock fractures.

No evidence of large scale solut i o n features exist i n the rock cores obtained from any of the bedrock borings advanced at the Site; i.e., no open voids such as runnels, caverns, caves, etc., sometimes referred to as "unde rground rivers," were found. Our on-Site investigatory findings are consistent with that expected for the Inwood Marble. Therefore, this work eliminates from concern solution feature flow associated with karst systems. The second regime is groundwater flow in the unconsolidated soil deposits.

This includes groundwater found in native glacial and alluvial deposits , as well as groundwater flow in anthropogenic s tructure s such as blast rock fill and utility trenches.

These flow paths, whi l e potential l y complicating migration p atterns, all tetminate at the Hudson River. g. While groundwater movement in the bedrock is controlled by fracture pattern s, the high degree of fracturing allows groundwater flow to be effectively represented and modeled on a Si te-wide scale using the w ell developed techniques derived for porous media t27. 10.2 SOURCES OF CONTAMlNATION The investigations identified two sources of radiological contamination.

The IPI-SF Ps and the IP2-SFP rr ransfer Canal. The IPI-SFPs are the primary source of Strontium groundwater contamination , while the IP2-SFP is the primary source of Tritium groundwater contamination.

No ev i dence of releases from Unit 3 have been identified during this investigation.

During the course ofGZA's and Entergy's investigations , we have identified the sources of l eakage associated with the IP2-SFP and Transfer Canal. T he s e sources have been eliminated and/or controlled by E n tergy. Specifically , Entergy has: 1) confinned that the damage to th e liner associated with the 1 992 release was repaired by the prior owner and is no l onger leaking; 2) installed a containment system (collection box) at the site of the leakage discovered in 2005, which precludes further release to the groundwater; and 3) id entified a weld imperfection in the Transfer Canal liner that, once identified , was prevented from leaking further by draining the Transfer Canal. This weld imperfection was then subseque ntl y repaired by Entergy (comp leted in mid December 07). Therefore , all identified leak s have been addressed.

Water li kely remains between the IP2-SFP stainless 127 While fracture-specific numerical models cx i Sl. the y an: less well developed and less flexible than porous media-based models. The u se of a porous media representation requires some level of approximation, particular l y on small sca l es of ten s of feet. How eve r , th e fracture flow models also require su bstantial approximations based on fracture sta t istics and are thu s, more prob lematic at thi s Site than a porous model. 128 steel liner and the concrete walls, and thus additional active leaks can not be completely ruled out. However, if they exist at all, the data l28 indicate they must be very sma ll and of little impact to the groundwater.

Our investigations also identified the source of all the Strontium contamination detected in groundwater beneath the Site as coming from the Unit I Fuel Pool Complex (IPI-SFPs). The IPl-SFPs were identified by the prior owner as leaking in the mid-1990's.

All of the pools have been drained by Entergy except the West Pool, which currently contains the last 160 Unit I fuel assemblies remaining from prior plant operations.

This plant was retire d from service in 1974. Fo llowing detection of radionuclides associated with IP1-SF Ps in the groundwater, Entergy, as part of their already planned fuel rod removal and complete pool drainage program, accelerated efforts to further reduce activity in the IP I-SFPs through demineralization

.. T he on-Site tracer test demonstrated that aqueous releases in the vicinity of [P2-SFP are stored above the water table in either: 1) unsaturated zone dead-e nd fractures; and/or 2) anthropogenic foundation details such as blast-rock backfill over a mud-mat (see Section 8.1.2). This impacted unsaturated zone water is then periodically released to the groundwater over time as driven, for example, by infiltration of precipitation.

Consequently , subse quent releases to the groundwa t er can continue for significant durations after the initial leak ha s been terminated.

In addition, the tracer studies further demonstrate that the migration rates fo r the Tritium plume in the groundwa t er can be slowed down as compared to the groundwater itself. This reduction in Tritium plume migration velocity occurs when impacted groundwater encounters, and becomes "entrapped" by dead-end fractures, both naturally occurring fractures and those created by excavation blasting during Site construction J29. The radionuclides identified in the Unit 3 area are related to historic legacy l eakage from IPt , and reflect what remains of the plume that has been naturally attenuating since approximately 1 99 4. The pathway to the Unit 3 area was via the IP I-S FDS and then to the storm drain system which transverses along the southeastern portion of the Site; not via groundwater flow to the South (see Section 8.2). Exfiltration from this stonn drain system had , in turn, resulted in contamination of the groundwater along the stonn drain pip ing. The Sphere Fou ndation Drain Sump no longer discharges to the stonn drain system and this l egacy release pathway had therefore been tenninated because the associated piping was capped in 1994. 128 These data include: monitored water levels in the SFP , with variations accounted for based on refilling and evaporation volumes: the m ass of Tritium migrating with groundwater i s sm all; and the age of th e water in the interstitial space. 12 9 Once contaminants enter dead-end fractures , the y no l onge r migrate w i th the gro undwater flow. However. this "entrapped contamina tion" does re-cntcr thc flow regime o v er time due to turbulent flow mixing at the fracture:

opening as well as diffusion.

129 10.3 GROUNDWATER CONTAMINANT TRANSPORT Based on our assessment of the bedrock's hydraulic properties, the area's hydrogeologic setting, the properties of the contaminants, the age of the releases , interdictions made to eliminate or reduce release rates, and the distances between the source areas and the Hudson River, we believe the groundwater contaminant plumes have expanded to their maximum extent and are now decreasing in size. In this regard , the Unit 2 Tritium plume is decreasing faster than the Unit I Strontium plume, as anticipated.

These conclusions are based on the data available which, given the aggressiveness with which Entergy implemented the investigations, is compressed in duration lJO , Therefore, ultimate confirmation of these conclusions will require monitoring over a number of years to allow ranges in seasonal variation to be adequately reflected in the monitoring data. During long tenn monitoring, GZA further anticipates that contaminant concentrations in individual monitoring wells will fluctuate over time (increasing at times as well as decreasing, as potentially related to precipitation events), and that a future short tenn increase in concentrations does not, in and of itself, indicate a new leak. In addition, it is also expected that some areas within the plumes will exhibit faster decay rates than others. Both behaviors are commonly observed throughout the industry with groundwater contamination sampling and analyses, and therefore, conclusions pursuant to plume behavior must be evaluated in the context of all of the Site-wide monitoring data. Overall, however, aZA believes that the continuing monitoring will demonstrate decreasing long tenn trends in groundwater contaminant concentrations over time given the source interdictions completed by Entergy. It is also further emphasized that even the upper bound Tritium and Strontium groundwater concentration isopleths presented on Figures S.l and S.2 result in releases to the river which are only a small percentage of the regulato!), limits, which are of no threat to public health. a. The major groundwater transport mechanism is advection.

Sorption retards the migration of radiological contaminants other than Tritium relative to groundwater advection rates, while Tritium, within hydraulically interconnected fractures, can migrate at rates that approach the groundwater seepage velocity.

b. The Unit 2 contaminant plume is characterized by Tritium in the groundwater.

Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased (see Table 5.1 and Figures S.l and 9.3). However, the center of mass of the Unit 2 plume is not rapidly migrating downgradient , and remains in proximity to the LP2-SFP. While a small active leak can not be ruled out completely, this behavior is also consistent with the identified role of unsaturated zone (above the water table) storage of historic releases, with precipitation

-induced infusion of this entrapped water into the groundwater regime over time. c. The Unit I contaminant plume is primarily characterized by Strontium concentrations in the groundwater , though near the physical pool area other isotopes are present as expected due to proximity.

Over the last two years , the highest Strontium concentrations in the Unit I plume have decreased (Table 5.1). These decreases in concentration are consistent with a reduction in Strontium IlQ It is noted that a number of key monitoring installations have only recently be en complet e d. and monitorin g rounds s pann i ng multiple s eason s ar e not y e t a vailable.

130 10.4 concentrations in the Unit I West Fue l Pool via pool water recirculation through demineralization beds. While the physical leak(s) in this fuel pool still exist, the source tenn to the groundwater has been reduced through reduction in the contaminant concentrations in the leak water. It is noted , however, the U nit I Strontium decreases are more modest and are generally more limited to the immediate source area than that observed for Tritium at Unit 2. The slower rate of plume decay is not unanticipated give the adsorption properties of Strontium.

Further planned interdictions include removal of the fuel rods and draining of the pool water , which will pennanently eliminate the West Fuel Pool as well as the entire IPI-SFP complex as a source of contamination to the groundwater.

With elimination of this source, natural attenuation will reduce Strontium concentrations in the Unit I plume over time. GROUNDWATER MASS FLUX CALCULATIONS During the project (over the past two years), as testing progressed and more information became available, we refined methods to calculate the groundwater flux and associated radiological activity to the Hudson River. As described below , we have developed a procedure which is scientifically sound, relatively straight-forward, and appropriately conservative.

Groundwater flow rates are provided to Entergy, who computes the radiological dose impact. a. Migration of radionuclides to the river is computed based on groundwater flow r ates, in combination with contaminant concentrations within the flow regime. This information is then used in surface water models to compute radiological contaminant concentrations in the river and thus potential dose to receptors.

b. To assess the va lid ity of the precipitation mass balance method used to date for computing groundwater flux across the Site, aZA also performed groundwater flux computations using an independent method based on Darcy's La w. Thus , the re su lts from two widely accepted groundwater flow calculation methods were compared against each other. The first, the precipitation mass balance method, is a "to p-down" procedure based on precipitation-driven water balance analyses.

The second, based on Darcy's Law, is a "bottom-up" method using hydr a ulic conductivity and flow gradient measurements.

These two methods resulted in estimated groundwater flow value s which were in agreement , providing a high degree of confidence in the values obtained relative to their impact on subsequent dose computations and risk analyses.

c. The original groundwater flux computations were developed for two separate areas of the Site. T he northernmost area included both the U nit 2 and U nit 1 plumes. T he southernmost area encompassed Unit 3. This bifurcation of the Site was established given: 1) the co-location of the Unit 2 plume and the U nit 1 plume near the western boundary of the Site just upgradient of the river; 2) the much lower contaminant concentrations in the Unit 3 area; and 3) the amount of data available at that time. Current data, derived from a greater number of groundwater elevation and sampling points than reflected in ear li er data, show the Site can be divided into six separate areas. The computations were further s eparated into shallow and deep flow regimes given: 1) the generally higher hydraulic conductivity in the shallow 131 portion of the bedrock, and 2) the generally more elevated contaminant concentrations in the shallow flow regime. d. The groundwater contaminant concentrations used for the radiological dose computations were obtained primarily from the analysis of samples taken from the recently completed multi-level wells specifically installed for this These wells are located downgradient of the Unit 2 and Unit 1 infrastructure l 3 and are positioned within the plumes and just upgradient of where the groundwater discharges to the river and Discharge Canal. The multi-level nature of these wells allows the groundwater to be sampled over at least five separate elevations in the bedrock, in addition to the overburden layer above. Sampling zones specifically targeted the most pervious depths within the bedrock boreholes.

As such, the groundwater samples encompass the full depth of the contaminant plume, from the upper soil zones to depths where the contaminant concentrations have fallen off to insignificant levels. The high number of samples over the depth of the plume provides a higher degree of confidence that the significant flow zones are accounted for. The high number of vertical sampling zones also provides a higher level of redundancy relative to the longevity and efficacy of the monitoring network over time. 10.5 GROUNDWATER MONITORING The current groundwater well and footing drain monitoring network is consistent with the objectives of the NEI Groundwater Protection lnitiative 1 32. Wells have been installed and are currently being monitored to both detect and characterize current and potential future groundwater contaminant migration to the river, as well as, in concert with specific footing dra in monitoring, provide earlier detection of potential future leaks associated with the exi s ting infrastructure.

a. The network of 59 monitoring well locations and over 140 sampling intervalsllocations , has allowed us to identify groundwater flow patterns. A subset of this network will provide an adequate long tenn monitoring system. b. Existing and potential sources have been identified, and monitoring is in place to both evaluate current conditions and identify future releases , should they occur. c. The nature and extent of contamination is known and reporting requirements are in place. 10.6 COMPLETENESS Inv est igations at the Site have been broad, comprehensive, and rigorous.

Major components of the field studies include: detailed acquisition of geologic infonnation; automated long duration collection of piezometric data; vigorous source area 131 The multi-level sampling nctwo r k is concentrated in the U nit 2 and Unit I areas given that this is where contaminant concentrations are by far the highest. The individual monitoring wells located downgradient of Unit 3 are judged suffi c ient for computations in this area given the low contami nant concentra ti o n s measured, even in the typica l ly more contaminated sh allow flow regimc. 1)2 NEI developed a set of procedures/goals for nuclear plants to assess the potentia!

for releases of radionuclides to pote n tia!1y migrate off-Site.

132 identification; comprehensive aquifer property testin g, including perfonnance of a full scale Pumping Test; and larg e-scale confirmatory contaminant transport testing, in the fonn of an extensive tracer test. The re su l ts of this systematic testing program are in agreement with conditions anticipated by our Conceptual Site Model. Based on our review of findings, we have concluded that the field studies conducted at the Site have addressed the study objectives.

a. There is no need to monitor groundwater at off-Site loc ations. The density and spacing of on-Site monitoring wells i s adequate to: I) demonstrate that contaminated groundwater is migrating to the Hudson River to the West, and not migrating off of the property to the North, East or South; 2) monitor the anticipated attenuation of contaminant concentrations;
3) identify future releases, should they occur; and 4) provide the data required to compute radiological dose impact. b. Hydraulic conductivity is the most important aquifer property.

We have completed more than 245 hydraulic conductivity tests, including a full-scale Pumping Test. Therefore, we believe no future aquifer testing is required.

In addition , the contaminant plumes have reached their maximum spatial extent. Therefore, there is no need for contaminant transport modeling.

c. The sources of releases to the groundwater have been identified.

In addit i on to monitoring, actions have been taken to reduce or eliminate these re l eases. Therefore, we believe no future source characterization is required.

d. All information indicates Monitored Natural Attenuation is the appropriate remedial response and is GZA's recommended approach (see Section 11.0). The existing monitoring network wi ll serve this remedial approach.

Therefore, no design phase studies are required.

133 11.0 RECOMMENDATIONS Based upon the comprehensive groundwater investigation and other work perfonned by En te rgy, GZA recommends the following:

1. Repair the identified Unit 2 Transfer Canal liner weld imperfection (completed mid December 2007); 2. Continue source tenn reduction in the Unit 1 pool via the installed demineralization system; 3. Remove the remaining Unit 1 fuel and drain the pools; and 4. Implement long term monitoring consistent with monitored natural attenuation, property boundary monitoring, future potential leak identific a tion, and support of ongoing dose assessment.

It is GZA's opinion that our investigations have characterized the hydrogeology and radiochemistry of the groundwater regime at the Site. Therefore, we are not recommending further s ubsurface investigations (see Section 10.0). Based upon the findings and conclusions from these investigations, as well as other salient Site operational infonnation. we recommend the completion of source interdiction measures with Monitored Natural Attenuation (MNA) as the remediation teclmology at the Site. In no small part. this recommendation is made because of the low potential for ri s k associated with g r oundwater plume discharge to the Hudson River. Monitored Natural Attenuation is defined by the United States Envirorunental Protection Agency as the reliance on natural attenuation processes (with in the con t ext of a carefully contro lled and monito red clean up approach) to achieve Site-specific remedial objectives within a time frame that is reasonable compared to other methods. The "na tural attenuation p r ocesses" that are at work in the remed i ation approach at this Site include a variety of physical, chemical and radiological processes that act without human intervention to reduce the activity, toxicity, mobility, volume, or concentration of contaminants in soil and groundwater.

These primarily include radiological decay , dispersion , and sorption.

MNA i s typically used in conjunction with active remediation measures (e.g .* source control), or as a follow-up to active remediation measures that have already been i mplemented.

At IP EC. active remedial measures alr e ady implemented include e l iminat i on (e.g., repair of the Unit 21990 liner leak and repair of Transfer Canal weld imperfection in mid-December 2007) and/or control (e.g., installation of a collection box to capture moisture from the IP2 shrinkage cracks) of active leaks , and reduction of the source term in t he Unit 1 fuel storage pool through demineralization.

with subsequent planned removal of the source term (fuel rods) followed by complete draining of the lPl-SFPs. Remediation

1. Our recommendation of MNA principles includes so urc e term contaminant reduc tion as an integral part of this remediation strategy.

Data demonstrating plume concentration reduction s over time, as considered along with other salient \34 Site infonnation, are consistent with a conclusion that the i nterdiction efforts to date (both current and in the past) have resulted in: 1) termination of the identifi ed Tritium leaks in the IP2-SFP; 2) id ent i fica tion of an imperfection in a Unit 2 Transfer Canal we ld which has been repaired;

3) reduction in IPI-SFP contaminant concentrations; and 4) elimination of Sphere Foundation Drain Sump discharges to the s torm drain piping East of Un it 3. As suc h , these interdictions have re s ulted in the elimination and/or control of identified sources of contamination to the groundwater. as required:
a. Over the last two years, the highest Tritium concentrations in the Unit 2 plume have decreased.

These data are consistent with a conclusion that the leaks responsible for the currently monitored Tritium plume are related primarily to the previously repaired 1992 legacy liner leak and the imperfection in the Transfer Cana l weld. With the implemented physical containment of the associated 2005 "concrete wall crack leaks" and the repair of the Transfer Canal liner, the source of contamination to the groundwater has been reduced and controlled.

b. Over the last two years , the highest radionuclide concentrations in the Unit I plume have decreased.

These decreases are consi sten t with a reduction in the concentrations in the Unit I West Fuel Pool via pool water recirculation through demineralization beds. While the physicalleak(s) in this fuel pool s till exist, the source term to the groundwater has been reduced due to treabnent of the source water. FUrther planned interdiction s include removal of the fuel rods and draining of the pool water , which will pennanently eliminat e th e West Fuel Pool as a source of contamination to the groundwater.

c. The U nit 1 plume in the Unit 3 area has been attribu ted to a historic legacy discharge from the Sphere Foundation Drain Sump (SFDS) through the s tonn drain system which traverses a lon g the southeastern portion of the Site. Leaks from this storm drain system have, in tum, resulted in past contamination of the groundwater along the s torm drains, with subsequent groundwater migration westward, through Unit 3 toward the river. The SFDS no longer discharges to the stonn drain and the Strontium concentrations in the Unit 3 groundwater have decreased to low levels , consistent with natural attenuation processes.
2. GZA selected Monitored Natural Attenuation as the remediation strategy because: a. Interdiction measures undertaken and planned to date have, or are expected to, eliminat e/co ntrol active sources of groundwater contamination.
b. Groundwater flow at the Site precludes off*Site migration of contaminated groundwater to the No rth , South or East. c. Consistent with the Conceptual Site Model , no contaminants have been detected above regional background in any of the off-Site monitoring locations or drinking water supply systems in the region. d. The only on-Site exposure route for the documented contamination is through direct exposure.

Because the majority of the Site is capped by 135 impermeable surfaces, there is no uncontrolled direct contact with contaminants.

e. Our studies indicate that under existing conditions, the spatial extent of the groundwater plume will decrease with time. f. Groundwater is not used as a source of drinking water on the Site or in the immediate vicinity of the Site, and there is no reason to believe that this practice will change in the foreseeable future. g. Groundwater associated with the Unit 1 foundation drainage systems is captured and treated to reduce contaminants prior to discharge to the Discharge Canal , consistent with ALARA principles.
h. At the locations where contaminated groundwater discharges to the Hudson River, the concentrations have been, and will continue to be, reduced by sorption, hydrodynamic dispersion and radiological decay. No detections of contaminants associated with plant operations have been found in the Hudson River or biota samp l ed as part of the required routine environmental sampling.

I. More aggressive teclmologies would alter groundwater flow patterns and, therefore, in our opinion , offer no clear advantages.

Long Term Monitoring

1. The second primary requirement for implementation of is a demonstration that contaminant migration is consistent with the Co nceptual Site Model. In particular, rigorous monitoring is required to demonstrate reductions in source area contamination, reductions in plume contaminant concentrations, and reduction in contaminant discharge to the river over time. The initial implementation stages of this monitoring process were begun nearly two years ago as part of the investigations summarized herein. As outlined above , reductions in maximum groundwater plume contaminant concentrations have already been documented.

T he elements for long term monitoring , consistent with the objectives of the N E l Groundwater Protection Initiative, are in place. We further note: a. Groundwa ter wells have specifically been installed , and are currently being monitored, to both detect and characterize current and potential future off-Site groundwater contaminant migration to the river. Additional wells have also been installed for monitoring of other Site property boundaries.

b. Monitoring wells have also been installed just downgradient of identified critical Structures, Systems and Components (SSCs). These wells, in concert with specific footing drain monitoring , provide earlier detection of potential future leaks associated with the power generating units than would be possible with boundary well s alone. c. Monitoring wells have been strategically placed to monitor the behavior of the plumes identified on the Site. d. MW-3g and MW-4g should be excluded from the monitoring plan as samp l es from these wells are generally indicative of a mixed groundwater 136 and Discharge CanaVriver water condition and, therefore, are not completely groundwater specifi c l33. e. The long tenn monitoring plan should include action levels, which if exceeded, trigger further analysis and/or investigations, potentially leading to implementation of an interdiction plan, if required.
f. A number of individual vertical sampling zones were included in nearly all the monitoring well installations, particularly within the contaminant plumes and at the location of plume discharge to the river. These individual vertical monitoring zones provide a significant level of vertical resolution and also provide a substantial degree of redundancy relative to the longevity and efficacy of the monitoring network over time l34. g. While previous and current dose calculations are both reasonable and conservative, we recommend that, with the accumulation of additional Site-specific hydrogeologic infonnation, the calculations be modified to incorporate Site-specific transmissivities and groundwater gradients.

Entergy has agreed that Site-specific model infonnation will be utilized in the next NRC required annual assessment of dose from this pathway_ Our specific recommendations (which will include additional trend information in early 2008) will be provided under separate cover for Entergy's incorporation to support the annual report. m See Section 6.6.3 for further discussion pursuant to this conclusion. 1 l4The level of redundancy designed into the long term monitoring network anticipates and allows for the loss of a number of monitoring zones without significant impact to the adequacy of the monitoring system. 137

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