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Entergy Prefiled Hearing Exhibit ENT000343 - Indian Point Nuclear Generating Units 1, 2 & 3 - NRC Inspection Reports Nos. 05000003/2009008; 05000247/2009008 and 05000286/2009008
	ML12089A605
Person / Time
Site:	Indian Point
Issue date:	10/19/2009
From:	Darrell Roberts; Division of Reactor Safety I
To:	Joseph E Pollock; Entergy Nuclear Operations, Atomic Safety and Licensing Board Panel
	SECY RAS
Shared Package
ML12089A599	List: ML12089A600; ML12089A601; ML12089A602; ML12089A604; ML12089A605; ML12089A608; ML12089A609;
References
	RAS 22132, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR IR-09-008
	Download: ML12089A605 (17)
	v • d • e

ENT000343

Submitted: March 29, 2012

UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION I Mr. Joseph Pollock Site Vice President

Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

4 7 5 ALLENDALE

ROAD KING OF PR USSIA, PA 19406-1415

October 19, 2009 SUBJECT: INDIAN POINT NUCLEAR GENERATING

UNITS 1 ,2 & 3 -NRC INSPECTION

REPORT NOS. 05000003/2009008

05000247/2009008

AND 05000286/2009008

Dear Mr. Pollock: On September

4, 2009, the U.S. Nuclear Regulatory

Commission (NRC) completed

an inspection

at Indian Point Nuclear Generating

Units 1, 2, & 3. The enclosed report documents

the inspection

results, which were discussed

on August 19 and September

4 , 2009 , with Mr. Don Mayer and other members of your staff. The purpose of this inspection

was to assess the establishment, implementation, and maintenance

of your Long-Term

G r oundwater

Monitoring

Program; review the circumstances

surrounding

a prev i ously identified

occurrence

involving

the detection

of tritated water in a Unit 3 storm drain system; review the performance

of the site's Radiation

Monitoring

System; and inspect and assess your performance

r elative to radiological

effluents

monitoring

and control. The inspection

involved an examination

of activ i ties conducted

under Entergy's license as related to safety and compliance

with the Commission's

rules and regulations

and with the conditions

of your license. Within these areas, the inspection

consisted

of a selected examination

of procedures

and representative

records, observations

of activities , interviews

with personnel, and independent

assessment

activities.

Based on the results of this inspection , no findings of significance

were identified. Further, the inspectors

determined

that Entergy's Long-Term

Groundwater

Monitoring

Program for the.lndian Point Energy Center was effectively

implemented

and maintained

in a manner that provided continued

radiological

monitoring

of the groundwater

conditions

to confirm conformance

with NRC regulatory

requirements

relative to the maintenance

of public health and safety, and protection

of the environment.

Since 2005 , as approved by NRC's E x ecutive Director of Operations , Region I c onducted frequent and focused reviews of your groundwater

investigation

activities

and long-term

monitoring

program that exceeded the scope of NRC's normal baseline inspection

program. As a result, we have developed

confidence

i n your commitment

and ability to continue effective

monitoring

and assessment

of the on-s i te cond i tions to assure the maintenance

of

J. Pollock 2 public health and safety, protection

of the environment, and conformance

with NRC regulatory

requirements.

Our inspectors

confirmed

that the objectives

specified

in our deviation

memorandum

dated December 16,2008 (ML083590057)

have been satisfied.

However, we will continue to monitor your performance

in this area , and will re-assess

the need for continued

heightened

inspection

oversight

during our end-of-cycle

review of your CY 2009 perfonmance.

In accordance

with 10 CFR2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure

will be available

electronically

for public inspection

in the NRC Public Document Room or from the Publicly Available

Records (PARS) component

of the NRC's document system (ADAMS). ADAMS is accessible

from the NRC Web site at

rm/adams.html (the Public Electronic

Reading Room).

Darrell J. Roberts, Director Division of Reactor Safety Docket Nos: 50-003, 50-247, 50-286 License Nos: DPR-5, DPR-26, DPR-64 Enclosure:

Inspection

Report Nos. 05000003/2009008, 05000247/2009008, 05000286/2009008

w/Attachment:

Supplemental

Information

cc w/encj: Distribution

via ListServ

J. Pollock 2 public health and safety , protection

of the environment, and conformance

with NRC regulatory

requirements. Our inspectors

confirmed

that the objectives

specified

in our deviation

memorandum

dated December 16, 2008 (ML083590057)

have been satisfied.

However, we will continue to monitor your performance

in this area, and will re-assess

the need for continued

heightened

inspection

oversight

during our end-of-cycle

review of your CY 2009 performance.

In accordance

with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure

will be available

electronically

for public inspection

in. the NRC Public Document Room or from the Publicly Available

Records (PARS) component

of the NRC's document system (ADAMS). ADAMS is access i ble from the NRC Web site at hllp: llwww.nrc.

rm/adams.html (the Public Electronic

Reading Room). Sincerely, IRA by Peter R. Wilson forI Darrell J. Roberts, Director Divis i on of Reactor Safety Docket Nos: 50-003 , 50-247 , 50-286 License Nos: DPR-5, DPR-26, DPR-64 Enclosure:

Inspection

Report Nos. 05000003/2009008, 05000247/2009008, 05000286/2009008 w/Allachment:

Supplemental

Information

cc w/encl: Distribution

via ListServ Distribution

w/encl: (via E-mail) S. Collins, RA (R10RAMAIL

RESOURCE)

M. Dapas, DRA (R10RAMAIL

RESOURCE)

D. Lew, DRP (R1 DRPMAIL RESOURCE)

J. Clifford, DRP (R1DRPMAIL

RESOURCE)

L. Trocine , Ri OEDO RIDSNRRPMINDIANPOINTRESOURCE

B. Welling, DRP B. Bickell, DRP S. McCarver , DRP G. Malone , DRP , Senior Resident Inspector

-Indian Point 2 D. Hochmuth , DRP D. Bearde, DRP Region I Docket Room (w/concurrences)

ROPreport

Resource D. Roberts , DRS P. Wilson, DRS J. White, DRS SUNSI Review Complete:

JRW (Reviewer's

Inrtials) OOCUMENT NA M E: G:I ORS I P la nt S upport B ranch 2 INoggl e II P 2009008 Re v1.do c After declaring

thi s document Offi c ial Agency Rec o rd w it will be rel ea s e d to the Pub lic. To receive a copy of this document, Indicate in the box: "e" = C Opy without attachm en t/enclosure "E" = COpy with atta c hment/enclosur

e "N" = No CQP"y OFFICE RIIDRS I RES I RIIDRS I RIIDRP I RIIDRS I NAME JNoggle/JDN TNicholsonltjn

JWhite/jrw'

ehg BWeliinglBW

DRoberts/prw

for (telecon)

for' DATE 10/06/09 10/14/09 10/19/09 10/16/09 10/16/09

see pnor concurrence

OFFICIAL RECORD COPY

Docket Nos. License Nos. Report Nos. Licensee: Facility:

Location:

Dates: . Inspectors:

Approved by: U.S. NUCLEAR REGULATORY

COMMISSION

REGION I 50-003 , 50-247 , 50-286 DPR-3, DPR-26, DPR-64 05000003/2009008, 05000247/2009008, and 05000286/2009008

Entergy Nuclear Northeast

Indian Point Nuclear Generating

Station Units 1, 2, & 3 295 Broadway Buchanan, NY 10511-0308

Augusr18 , 2009 -September

4, 2009 J. Noggle, Sr. Health Physicist, CHP, team leader T. Nicholson, Sr. Technical

Advisor for Radionuclide

Transport

J. Williams , U.S. Geological

Survey , Troy , New York John R. White, Chief Plant Support Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS IR 05000003/2009008, IR 05000247/2009008, IR 05000286/2009008;

08/18/2009

-9/04/2009;

Indian Point Nuclear Generating

Station Units 1, 2 & 3; Other Activities

-associated

with ROP deviation

memorandum, one PI&R sample, and radioactive

effluents

baseline inspection.

No findings of significance

were identified.

The report covers the period from August 18 through September

4, 2009, and discusses

inspection

activities

conducted

by a region-based

inspector, and an inspection

team comprised

of representatives

of Region I, NRC's Office of Research, and the U. S. Geological

Survey. The inspection

provided bases for the NRC to determine

that Entergy had completed

actions necessary

to satisfy the objectives

delineated

in our deviation

memorandum, "Request for Renewal of Deviation

to the Action Matrix

to Provide Heightened

NRC Oversight

of the Onsite Groundwater

Monitoring

at the Indian Point Energy Center," (ML083590057), dated December 16,2008. The NRC's program for overseeing

the safe operation

of commercial

nuclear power reactors is described

in NUREG-1649, "Reactor Oversight

Process," Revision 4, dated December 2006. ii Enclosure

Report Details 2. RADIATION

SAFETY Cornerstone:

Public Radiation

Safety (PS) 2PS1 Gaseous and Liguid Effluents

(71122.01 -3 samples) a. Inspection

Scope 1) The inspector

reviewed the following

documents

to evaluate the effectiveness

of the licensee's

radioactive

gaseous and liquid effluent control programs relative to the applicable

regulatory

requirements

specified

in the Technical

Specifications

and the Offsite Dose Calculation

Manual (TS/ODCM). * The 2007 and 2008 Radiological

Annual Effluent Release Reports were reviewed including

independently

assessing

selected public dose calculations.

There were no anomalous

results reported in these two reports. The report included discussion

of current groundwater

conditions

and the result of required monitoring

activities;

and instances

involving

out-of-service

radiation

monitors or effluent release flow

rate monitors were listed in the reports and these were evaluated

during this inspection.

The current ODCM was reviewed, including

technical

justifications

for any changes made since the previous revision.

Applicable

sections of the Updated Final Safety Analysis Report (UFSAR) were reviewed to verify the adequacy of system descriptions

for gaseous radioactive

waste and station ventilation

systems. * The latest quality assurance

audits of radioactive

effluents

and chemistry

were reviewed, including

Entergy's

program for identifying , controlling

and assessing

potential

contam i nated spills and leakage. * There were no measurable

effluent releases to the environment

based on off-site dose calculations , and there were no reported off-site environmental

sample measurements

i dentifying

plant-related

radioactive

materials

during the 2007 and 2008 report period. 2) The inspector

observed the following plant

equipment

and work activit i es to evaluate the effectiveness

of the licensee's

radioactive

gaseous and liquid effluent control programs.

Walkdowns

were performed

of accessible

gaseous and liquid release system components

to review any recent changes or modifications

and to confirm the alignment, operation

and material condition

of the radioactive

liquid and gaseous effluent radiation

monitoring

systems (RMS) at Units 1, 2 and 3. * Observations

were conducted

of radioactive

effluent related sampling and associated

laboratory

measurement

techniques.

Procedural

controls and selected radioactive

gaseous and liquid effluent release permits were reviewed to verify that radiation

monitor alarm setpoint values and releases were in agreement

with Technical

Specification

and ODCM requirements.

Enclosure

2 * Chemistry

logs, relative to out-of-service

radiation

monitoring

conditions, were reviewed to confirm the performance

of compensatory

sampling activities.

Surveillance

tests of gaseous filtration

discharge

systems were reviewed to confirm operability

and ventilation

flow rates with respect to the assumed flow rates used in gaseous effluent release calculations.

Entergy's

surveillance

program of non-radioactive

system interfaces

with radioactive

process systems was reviewed to confirm effective

monitoring

and control of potential

effluent discharge

paths to the environment.

Radiation

monitoring

system and chemistry

laboratory

counting instrument

calibration

and quality control records were reviewed with respect to ODCM surveillance

requirements

to confirm the licensee's

ability identify and report detectable

radionuclides

in radioactive

measurement

results. 3) Radioactive

effluent control related corrective

action program activities

for 2007 through August 2009 were reviewed , including

the results of audits and the resolution

of issues identified

through the condition

report system. A comprehensive

review was conducted

of conditions

and occurrences

involving

out-of-service

radiation

monitoring

system components.

Section 40A2 pertains.

b. Findings and Observations

No findings of significance

were identified.

The following

table summarizes

the dose consequence

of radiological

effluent release in the period between 2007 and 2008. Table of Effluent Release calculated

dose and public dose limits for 2007 and 2008 Dose in Air Dose %of Air Dose %of liquid '10 of Liquid %of mrem/yr Whole limit Max Organ Limit Dose limit Dose limit Body WB MaxO 2007 Units 1&2 2.43E-3 0.016 2.43E-3 0.016 5.3 5E-4 0.018 1.3E-3 0.013 2008 Units 1&2 2.07E-3 0.014 2.67E-3 0.018 6.11E-4 0.020 1.47E-3 0.Q15 2007 Unit 3 3.BBE-3 0.026 3.BBE-3 0.026 3.2E-4 0.007 2.14E-4 0.002 2008 Unit 3 1.99E-3 0.013 1.99E-3 0.013 1.56E-4 0.005 2.B3E-4 0.003 2007 Groundwater

2.66E-4 0.009 9.94E-4 0.01 2008 Groundwater

2.86E-4 0.009 9.35E-4 0.009 4. OTHER ACTIVITIES (OA) 40A2 Identification

and Resolution

of Problems Cornerstone:

Public Radiation

Safety .1 Radioactive

Gaseous and Liquid Effluent Treatment

and Monitoring

Systems a. Inspection

Scope (71122.01)

The inspector

reviewed approximately

one hundred corrective

action condition

reports, initiated

between january 2007 and August 2009, that were associated

with the gaseous, liquid, and groundwater

radioactive

effluents

program. The review was performed

to Enclosure

3 verify that problems identified

by these condition

reports were properly characterized

in the licensee's

event reporting

system, causes were identified, and actions implemented

commensurate

the safety significance

of the matters. b. Findings and Observations

No findings of significance

were identified . . 2 Radioactive

Effluent Radiation

Monitor System (RMS) Maintenance

(71152 -1 sample) a. Inspection

Scope The inspectors

conducted

a review corrective

action program condition

reports associated

with out-of-service

radiation

monitoring

system equipment

that was identified

in the period between January 2007 and August 2009. Licensee personnel

having cognizance

of Radiation

Monitoring

System (RMS) performance

and activities

were interviewed, including

the RMS system engineer and senior chemistry

staff. "Radiation

Monitoring

System, Second Quarter 2009, Condition

Report Trend Review for Radiation. Monitoring

System Improvement

dated September

2, 2009, was also reviewed.

b. Findings and Observations

No findings of Significance

were identified.

A large number of condition

reports associated

with the radiation

monitoring

system were initiated

during the past two years. Most of the condition

reports were associated

with interruption

of service of the RMS display consoles in both the Unit 2 and Unit 3 control rooms. While these temporary

display outages affected operators'

ability to poll individual

detector readout displays , they did not interfere

with control room annunciator

actuation

or actual detector operability. The cause of the Unit 3 display console issues was determined

to be related to excessive

temperature

in the RMS electronics cabinets

that affected certain control

room RMS display console components.

Short-term

corrective

actions included installing

permanent

air conditioning

to effect improved cooling of the RMS electronics

cabinets.

The cause of Unit 2 RMS display console service interruptions

continues

to be under review. Notwithstanding, Entergy is evaluating

replacing

the RMS display console equipment

in both control rooms to support station-wide

computer network access improvements.

Less frequently

occurring

RMS equipment

issues remain to be resolved, including

occurrences

involving

the R-56 detectors, which monitor the discharge

of waste sewage from Units 2 and 3. The location of these detectors

was determined

to be susceptible

to failure due to flooding , power spiking, and power outages. In such conditions, waste sewage is diverted to an on-site holding tank in order to conduct sampling prior to off-site release. Accordingly, there is no safety significance

to these RMS system failures.

The inspector

confirmed

that the licensee has implemented

appropriate

remedial actions for these occurrences, and has initiated

actions to improve the operating

environment

and detector function to reduce the out-of-service

time. Enclosure

4 Entergy has identified

the Unit 2 RMS as an upgrade project in its Top Ten Action Plan for 2009. System engineering

activities

have been initiated

for this improvement

activity.

The inspector

determined

that the majority of identified

problems with the Unit 2 and Unit 3 radiation

monitoring

systems were not associated

with radiation

detector operability

or effluent release control functions.

For those instances

that resulted in out-of-service

conditions, the licensee implemented

appropriate

compensatory

measures as required by regulatory

requirements.

The inspector

confirmed

that Entergy is engaged in RMS . improvement

activities, and has initiated

appropriate

corrective

actions. 40A5 Other Activities

.1 Assessment

of Licensee Performance

Relative to Meeting the Objectives

of the December 16.2008 Memorandum

Reguesting

Deviation

from the Action Matrix Background:

On September

1, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent fuel pool wall had been discovered

during excavation

work inside the spent fuel pool building.

Low levels of radioactive

contamination

were found in the vicinity.

Entergy's

initial investigation

of the issue revealed that groundwater

in the vicinity was contaminated

with tritium. On September

20, 2005, Region I initiated

a special inspection

of this matter to examine the licensee's

performance

and determine

if the contaminated

groundwater

affected, or could affect, public health and safety. Subsequently, Entergy initiated

actions to perform a comprehensive

groundwater

site characterization, identify the sources, and effect mitigation

and remediation

of the condition.

The NRC special inspection

report, issued in March 2006, assessed Entergy's

performance, achievements, and plans for more extensive

site characterization, and reported that the groundwater

contamination

did not, nor was likely to, adversely

affect public health and safety. In the report, and subsequent

public meetings, NRC indicated

that a final conclusion

would be reached after Entergy completed

its groundwater

characterization

initiative.

The NRC Region I continued

inspection

and monitoring

of Entergy's

activities

in accordance

with successive

approved deviation

to the normal Reactor Oversight

Process for calendar years 2006 (ML053010404), 2007 (ML063480016), 2008 (ML073480290)

and 2009 (ML083590057).

During this period, the NRC staff closely monitored

Entergy's

groundwater

characterization

efforts, performed

independent

inspections

and testing, and independently

evaluated

radiological

and hydrological

conditions

affecting

groundwater

onsite. Additionally, the NRC independently

verified groundwater

releases by conducting

split monitoring

well sampling with Entergy and the State of New York. On January 11, 2008, Entergy submitted

the results of its comprehensive

hydrogeologic

site characterization

investigation (ML080320600), and included its plan for remediation

and long-term

monitoring

of the on-site groundwater

conditions.

In its report, Entergy described

the source of groundwater

contamination

to be from the Unit 1 and Unit 2 spent fuel pools. The NRC documented

its review of Entergy's

report in inspection

report 05000247 & 05000003/2007010

on May 13, 2008 (ML081340425).

In a subsequent

inspection

05000247/2008004 (ML08311 0566) dated November 6,2008, the NRC Enclosure

5 confirmed

that Entergy's

conceptual

site model of the site, which included both the vadose zone and saturated

zone processes

and conditions, effectively

characterized

the onsite groundwater

plume behavior and radionuclide

transport. Evaluation

of radionuclide

concentrations

and pathway analyses indicated

that the groundwater

contamination

did not adversely

affect public health and safety. Detailed discussions

and analyses indicated

that the licensee's

plans for long-term

monitoring

of the site, relative to monitoring

natural attenuation

of residual groundwater

contamination, were reasonable.

On November 3, 2008, Entergy completed

Unit 1 spent fuel pool system drainage and sludge removal activities, essentially

terminating

the source from that facility. Given the change in conditions, Entergy initiated

actions to establish

a new groundwater

contaminant

baseline in support of its long-term

monitoring

program. a. Inspection

Scope The most recently approved Memorandum

of Deviation, i.e., " Request for Renewal of Deviation

to the Action Matrix to Provide Heightened

NRC Oversight

of the Onsite Groundwater

Monitoring

at the Indian Point Energy Center," dated December 16, 2008 (ML083590057), identified

the following

objectives

to be addressed

in order to support resumption

of normal inspection

activities

in accordance

with the Reactor Oversight

Process: * Entergy has completed

sufficient

data collection

and assessment

to establish

a new groundwater

contaminant

baseline, now that the Unit 1 source term has been terminated.

Entergy has determined

whether active leakage has been terminated

or continues

to persist in regard to the Unit 2 spent fuel pool; and has implemented

appropriate

monitoring

and control measures, as necessary.

Entergy has established

and implemented

effluent control and environmental

monitoring

procedures

that provide reasonable

assurance

that the existing groundwater

conditions

will continue to be effectively

monitored

and assessed, that the procedures

will detect new or changed conditions

in a timely manner, and that the procedures

are sufficient

to monitor natural attenuation

of the Unit 1 and Unit 2 groundwater

contamination

plumes. The NRC team reviewed the licensee's

performance

and achievements

relative to the completion

of these objectives.

b. Findings and Observations

No findings of significance

were identified.

The inspectors

determined

that Entergy completed

the actions necessary

to satisfy the objectives

delineated

in the approved Memorandum

of Deviation, dated December 16, 2008, (ML083590057).

Notwithstanding, NRC will continue to monitor performance

in this area, and re-assess

the need for continued

heightened

inspection

oversight

as part of the CY 2009 end-of-cycle

performance

review of IPEC. Enclosure

6 The following

pertains:

Objective

1: Completion

of sufficient

data collection

and assessment

to establish

a new groundwater

contaminant

baseline, now that the Unit 1 source term has been terminated.

As a result of the defueling, drainage, and de-sludging

of the Unit 1 spent fuel pool system in the Fall of 2008, the groundwater

contamination

source term from the Unit 1 facility was terminated.

The inspectors

confirmed

that Entergy's subsequent

data collection

and assessment

activities , associated

with the continual

monitoring

of the residual groundwater

contamination, would be sufficient

and effective

to establish

a new baseline relative to monitoring

the residual groundwater

condition

and subsequent

assessment

of dose consequence. As expected, the first and second-quarter

ground-water

sample results in 2009, collected

from Monitoring

Wells in the immediate

vicinity o f the Unit 1 spent fuel pool, indicated

an increase in Sr-90 groundwater

concentrations. As determined

from review of the licensee's

data and analysis, this increased

concentration

was the expected result of the volume of water that was necessary

to fill the spent fuel pool system to effect defueling.

Accordingly, Entergy's baseline data was predicated

on the existing groundwater

conditions

determined

from its continuing

analysis of collected

monitoring

data. Given that the original source of the contamination

associated

with leakage from the Unit 1. spent fuel pool system has been terminated , the residual groundwater

contamination

involving

Sr-90 is expected to naturally

attenuate

over time. The inspectors

confirmed

that the current groundwater

contaminant

concentrations

have not, nor are expected to, affect public health and safety; and the public radiological

dose consequence

is expected to continue to be a fraction of the NRC annual regulatory

limit affecting

liquid effluents.

The inspectors

confirmed

that cont i nual monitoring

of the migration

and attenuation

of the Unit 1 associated

groundwater

contamination

condition

is being performed

in accordance

with Entergy's

Long-Term Ground-Water

Monitoring

Program (LTGWMP).

The inspectors

confirmed

that Entergy has established , implemented

and maintains

a long-term

ground-water

monitoring

program that has sufficient

in scope and implementation

requirements

to effectively

monitor and assess this condition. Accordingly, the intent of this objective

was considered

satisfied. * Objective

2: Determination

whether active leakage has been terminated

or continues

to persist in regard to the Unit 2 spent fuel pool , and that appropriate

monitoring

and control measures have been implemented , as necessary.

Entergy has been actively engaged in analyzing

Monitoring

Well data associated

with the H-3 (tritium)

groundwater

contamination

condition

that resulted from previously

identified

leakage from the Unit 2 spent fuel pool: Entergy's analysis indicated

an overall . decreaSing

trend in tritium concentration

in the groundwater

as a result of previous efforts to e x amine the condition

of the spent fuel pool and transfer canal liner , and effect repair , as necessary.

Notwithstanding , as previously

reported , Entergy's

e x amination

of the spent fuel pool liner was necessarily

limited to only the accessible

surfaces.

That is, only about 40 % of the total liner surfaces were accessible

for examination;

the remaining

surfaces were necessarily

inaccessible

due to the pro x imity of stored spent fuel that prevented

examination.

Enclosure

7 The inspectors

reviewed the licensee's

analysis derived from groundwater

monitoring

data, and confirmed

that there was no apparent indication

of any significant

large flux going active leakage. The inspectors

also reviewed the licensee's monitoring

well detect i on sensitivity

data , which supports that active leakage , if occurring , would likely not exceed 30 gallons per day (0.02 gpm). This sensitivity

analysis was based on comparison

of the tritium concentration

that is available

in the spent fuel pool and the actual tritium concentration

derived from samples collected

from relevant monitoring

wells in the near vicinity of the spent fuel pool. Additionally, the inspectors

reviewed licensee analysis and data from a long-term

tracer test that indicated

the potential

for slow, episodic trit i um migration

in the fractures

of the vadose zone that affect the mobility of contamina t ed groundwater

from the immediate

vicinity of the Unit 2 spent fuel pool to the water table. The licensee's analysis is supported

by the fact that fluorescine

dye, which was injected as part of the groundwater

characterization

study over two years ago, is still detectable

in certain nearby monitor i ng wells. The inspectors noted that

there were occasional

spikes and general variability

in some monitor i ng well tritium concentration

values that were not characteristic

of the e x pected attenuation

that would normally be expected at this time. Additionally , the licensee continued

to occasionally

collect a small quantity of water from the leak collection

box that was installed

on the Unit 2 spent fuel pool wall crack that was identified

in 2005. Accordingly, while there was no indication

of any significant

large flux active leakage, there was insufficient

basis to conclude that there is absolutely

no persistent

low flux leakage from the Unit 2 spent fuel pool, at this time. Notwithstanding , the inspectors

determined

that the licensee's sensitivity

analysis of groundwater

monitoring

data, relative to its ability to detect active leakage in e x cess of about 30 gallons per day , was reasonably

derived. Additionally , the inspectors

confirmed

that the current groundwater

conditions, even if there was persistent

low flux leakage from the Unit 2 spent fuel pool, has not, nor would be e x pected to, affect public health and safety; and the public radiological

dose consequence

would be expected to continue to be a fraction of the NRC annual regulatory

limit affecting

liquid effluents.

The inspectors

confirmed

that continual

monitoring

of the mig r ation and attenuation

of the Un it 2 associated

groundwater

contamination

condition

was being performed

in accordance

with Entergy's Long-Term

Ground-Water Monitoring

Program; and that the program implemented

appropriate

monitoring

and control measures for this condition.

The inspectors

confirmed

that Entergy has established, implemented

and maintained

a long-term

ground-water

monitoring

program that has sufficient

scope and implementation

requirements

to effectively

monitor and assess the present condition. Further, the licensee is considering

monitOring

in the vadose zone , in the vicinity of the Unit 2 facility , to assist in the detection

of large flu x releases. Accord i ngly , the intent of this objective

was considered

satisfied.

Objective

3: Establishment

and implementation

of effluent control and environmental

monitoring

procedures

that provide reasonable

assurance

that the e x isting groundwater

conditions

will continue to be effectively

monitored

and assessed, that t he procedures

will detect new or changed conditions

in a timely manner, and that the procedures

are sufficient

to monitor natural attenuation

of the Unit 1 and Unit2 groundwater

contamination

plumes. Enclosure

8 The NRC has conducted several

inspections (August 2007, October 2008, and August 2009) of the licensee's

Long-Term

Ground-Water

Monitoring

Program. The inspectors

confirmed

that Entergy has established, implemented

and maintained

a Long-Term

Ground-Water

Monitoring

Program that was sufficient

in scope and implementation

requirements

to effectively

monitor and assess the existing contaminated

groundwater

conditions

affecting

the Indian Point Energy Center. During this inspection, the inspectors

examined the refurbishment

of the LaFarge No.2 Monitoring

Well (one of the principal off-site monitoring

wells) and confirmed

its acceptability

as a valid off-site monitoring

location.

Additionally , the inspectors

verified that the administrative

controls, established

in the Long-Term

Groundwater

Monitoring

Program, were sufficient

t9 provide assurance

of review and appropriate

communication

of activities

and changes that affect ground-water

monitoring

conditions;

and that the program included sufficient

sampling requirements

for storm drains and the Unit 1 foundation

drain systems. During this inspection, the inspectors

reviewed a March 25, 2009 instance involving

the licensee's

detection

of tritiated

water in the catch basin of a storm drain in the vicinity of Unit 3 , and in an adjacent shallow monitoring

well. The licensee conducted

an extensive

investigation

but was unable to find an explanation

for this one-time occurrence.

The inspectors

confirmed

that the occurrence

had no radiological

consequence

onsite or offsite; and no leakage was identified

from any Unit 3 component

containing

tritiated

water. However, the nature of the occurrence

indicated

uncertainty

in the ability of the existing Unit 3 monitoring

wells to detect potential

leakage from that facility.

While there was no current on-going leakage affecting

the groundwater

at Unit 3 , Entergy initiated

action to re-evaluate

the Unit 3 groundwater

monitoring

configuration (both vertically

and horizontally)

to determine

its effectiveness

in meeting the objectives

and recommendations

of the NEI "Industry

Groundwater

Protection

Initiative-

Final Guidance Document, August 2007" (ML072600292

and ML07261 0036); and amend the Term Groundwater

Monitoring

Program , as necessary.

Notwithstanding, the inspectors

confirmed

that Entergy has established, implemented

and maintained

a Long-Term

Ground-Water

Monitoring

Program that has sufficient

scope and implementation

requirements

to effectively

monitor and assess the existing* groundwater

conditions

affecting

Indian Point Energy Center. Accordingly, the intent of this objective

was considered

satisfied . . 2 Groundwater

Sampling a. Inspection

Scope During the licensee's

groundwater

investigation, over 1200 groundwater

samples were collected

and analyzed from the established

on-site monitoring

well network by the second quarter of 2009. The analytical

results provide the basis for assessing

the extent of the groundwater

plume and for performing

calculations

of offsite doses to members of the public. In order to assess Entergy's

performance

in this area, the NRC implemented

an independent

split sample collection

program with the licensee beginning

in September

2005. The monitoring

wells selected for independent

verification

included the southem boundary wells and those wells bordering

the Hudson River that were used Enclosure

9 in support of effluent release and dose assessment

calculations.

Sample identity was assured by chain-of-custody

procedures

that included sample collection

observation

by the NRC or a representative

of the NYS DEC. The NRC samples were analyzed by an independent

govemment

laboratory

to ensure validation

of the licensee's

groundwater

contamination

results and off-site environmental

sample radioactive

measurements.

By the second quarter of 2009, over 300 split groundwater

samples were obtained to provide an independent

check of Entergy's

analytical

results and to independently

verify if there was any detectable

migration

of groundwater

contaminants

offsite. These split samples represent

over 1,200 analyses, primarily

for hydrogen-3 (tritium), strontium-90, nickel-63, and gamma-emitting

radionuclides

that characterized

the effluent releases. Analyses for other radionuclides

were performed, but none were detected.

b. Findings and Assessment

No findings of significance

were identified. In general, Entergy's

groundwater

measurements

of radioactivity

were of good quality and of sufficient

sensitivity

to assess radiological

impact. The quality of Entergy's

measurements

were confirmed

by various split samples analyzed by the NRC. Of the over 1200 results that were reviewed, there were only a few sample disagreements

based on the statistical

comparison

criteria specified

in NRC Inspection

Procedure

84750, "Radioactive

Waste Treatment, and Effluent and Environmental

Monitoring." As a result of these few discrepancies, Entergy took corrective

action to establish, implement, and maintain procedures

to effect improved quality control and assurance

of sample analysis performed

by its own laboratory

and contract analytical

laboratories.

During the past 3)1" years, the on-site groundwater

transport

pathway has been effectively

characterized

by the licensee, and a significant

quantity of on-site groundwater

monitoring

data has been collected

and analyzed by Entergy. A representative

numbers of split samples have confirmed

the overall efficacy of the licensee's

analytical

capability.

As the site characterization

was tested through pumping and tracer testing, the contaminant

plume uncertainty

has been significantly

reduced. Given this accomplishment, and the NRC determination

that Entergy has demonstrated

an effective

groundwater

sample quality control program, the NRC will discontinue

any further split sampling activities.

40A6 Meetings, including

Exit .1 Exit Meeting Summary The inspectors

presented

the inspection

results to Mr. D. Mayer and other licensee and New York State representatives

on August 19, 2009 and September

4, 2009. The licensee acknowledged

the findings presented.

Based upon discussions

with the licensee, none of the information

presented

at the exit meeting and included in this report was considered

proprietary.

Enclosure

Licensee Personnel

J. Pollock M. BaNenik P. Conroy D. Croulet P. Donahue C. English G. Hinrichs D. Loope T. Jones R. LaVera D. Mayer J. Michetti J. Peters D. Rusczyk S. Sandike J. Simpson R. Walpole A-1 ATTACHMENT

SUPPLEMENTAL

INFORMATION

KEY POINTS OF CONTACT Site Vice President

Principal

Engineer, GZA Geo EnVironmental, Inc. Director, Nuclear Safety Assurance

Licensing

Engineer Chemistry

Specialist

Unit 1 Project Engineer Project Engineer Radiation

Protection

Superintendent

Licensing

Engineer Radiological

Engineer Director, Special Projects RMS System Engineer Plant Chemist Environmental

Assessment, GZA Chemistry

ODCM Specialist

Environmental

Assessment, GZA Manager, Licensing

New York State Inspection

ObseNers L. Rosenmann

Engineering

Geologist, New York State, Department

of Environmental

ConseNations

INSPECTION

PROCEDURES

USED 71122.01 Radioactive

Gaseous and Liquid Effluent Treatment

and Monitoring

Systems LIST OF DOCUMENTS

REVIEWED Annual Radiological

Effluent Release Reports -2007 and 2008 Off-Site Dose Calculation

Manual, Revision 2 O-CY-2730, Rev. 1, Airbome Radioactive

Effluents

O-CY-2740, Rev. 1, Liquid Radioactive

Effluents

IP-SMM-CY-001, Rev. 7, Radioactive

Effluents

Control Program IP-SMM-CY-110, Rev. 3, Radiological

Groundwater

Monitoring

Program 2-CY-2625, Rev. 14, General Plant Systems Specifications

and Frequencies

3-CY-2325, Rev. 8, Radioactive

Sampling Schedule 2-S0P-5.2.4, Rev. 33, Calculation

and Recording

of Radioactive

Gaseous Releases 2-S0P-5.1.5, Rev. 34, Calculation

and Recording

of Radioactive

Liquid Releases 3-S0P-WDS-014, Rev. 25, Liquid Waste Releases Attachment

A-2 3-S0P-WDS-013 , Rev. 25 , Gaseous Waste Releases EN-RP-113 , Response to Contaminated

Spills/Leaks

EN-CY-109, Sampling and Analysis of Groundwater

Monitoring

Wells EN-CY-108, Monitoring

of Non-Radioactive

Systems " Industry Groundwater

Protection

Initiative

-Final Guidance Document , August 2007" (ML072600292

and ML072610036)

Unit 2 Liquid Release Permit No. 090016 Unit 2 Gaseous Release Permit No. 090126 Unit 3 Liquid Release Permit No. 090081 Unit 3 Gaseous Release Permit No. 090067 Condition

Reports: CR-IP3-2007 -0803 CR-IP2-2009

-2089 CR-IP3-2009-3356

CR-IP2-2009-2528

CR-IP2-2009-3307

CR-IP3-2007-3954

CR-IP2-200S-0270

CR-IP2-200S-0375

CR-IP3-200S-071S

CR-IP2-200S-0377

CR-IP2-2009-2266

CR-IP2-200S-1236

CR-IP3-2007 -3860 CR-IP3-200S-1112