ML081340425

IR 05000247-07-010 & 05000003-07-010 on 11/07/2007 - 05/07/2008 for Indian Point, Units 1 & 2

ML081340425
Person / Time
Site:	Indian Point
Issue date:	05/13/2008
From:	Gamberoni M Division of Reactor Safety I
To:	Joseph E Pollock Entergy Nuclear Operations
References
EA-08-088, FOIA/PA-2010-0209, FOIA/PA-2016-0148 IR-07-010
Download: ML081340425 (56)

See also: IR 05000003/2007010

Text

May 13, 2008

EA-08-088

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

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 1 & 2 - NRC INSPECTION

REPORT NOS. 05000003/2007010 and 05000247/2007010

Dear Mr. Pollock:

On May 7, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

Indian Point Nuclear Generating Units 1 & 2. The purpose of this inspection, initiated on

November 7, 2007, was to assess your site groundwater characterization conclusions and the

associated radiological significance relative to Entergy=s discovery of a small amount of

contaminated water leaking from the Unit 2 spent fuel pool, and the subsequent discovery of

additional subsurface groundwater contamination emanating from the Unit 1 spent fuel pool

system. This inspection focused on assessing Entergy=s groundwater investigation to evaluate

the extent of contamination, and the effectiveness of actions, taken or planned, to effect

appropriate mitigation and remediation of the condition.

The inspection involved an examination of activities conducted under Entergys license as they

relate to safety and compliance with the Commission=s rules and regulations, and with the

conditions of the license. Within these areas, the inspection consisted of a selected examination

of procedures and representative records, observations of activities, interviews with personnel,

and independent analytical and assessment activities. This inspection effort reviewed Entergys

long-term monitoring plan intended for continuing verification and validation of the effectiveness

of the licensees efforts to assess, mitigate and remediate on-site groundwater conditions

relative to public health and safety and protection of the environment. Details associated with

the long term monitoring program will continue to be the subject of ongoing NRC inspection. The

NRC will also continue split sampling for analytical comparison of selected groundwater

monitoring wells through 2008. During the course of this inspection, we coordinated activities

with representatives of the New York State Department of Environmental Conservation, who

observed our inspection and contributed valuable expertise and independent assessment

relative to its own focus on public health and safety, and environmental protection.

The enclosed inspection report documents the inspection findings, which were discussed on

May 7, 2008, with Mr. Don Mayer and other members of your staff. The team found Entergy=s

response to identified conditions to be reasonable and technically sound. The existence of

on-site groundwater contamination, as well as the circumstances surrounding the causes of

leakage and previous opportunities for identification and intervention, have been reviewed in

detail. Our inspection determined that public health and safety has not been, nor is likely to be,

J. Pollock 2

adversely affected, and the dose consequence to the public that can be attributed to current

on-site conditions associated with groundwater contamination is negligible. No significant

findings were identified. However, one minor violation with respect to quality control of

groundwater sampling is discussed in this report. This violation is not subject to enforcement

action in accordance with Section IV of the NRC Enforcement Policy. The NRC plans no further

action with regard to this matter; and no response to this letter is required.

Based on a telephone discussion between Messrs. John McCann, Director of Licensing, and

Samuel Collins, NRC Region I Regional Administrator, on April 21, 2008, we understand that

Entergy has committed to remove and transfer all spent fuel from the Unit 1 Spent Fuel Pool to

Indian Points Independent Spent Fuel Storage Installation, and drain the spent fuel pool by

December 31, 2008, thereby essentially terminating the source of groundwater contamination

from that location. Notwithstanding, it is expected that some water will remain on the bottom of

the pool to reduce the potential for airborne contamination, provide shielding, and facilitate the

removal of the sediment in early 2009. We understand that Entergy will promptly inform the

NRC of any condition that could potentially impact or delay this commitment. Additionally, we

understand that Entergy will incorporate the implementation requirements of its Long Term

Monitoring Program (LTMP) as regulatory specifications in the Indian Point Energy Centers

(IPEC) Off-site Dose Calculation Manual, thereby assuring that the LTMP will be regarded as an

extension of the Radiological Effluents Technical Specifications and Radiological Environmental

Monitoring Program, which are subject to NRC inspection. During the Exit Meeting on May 7,

Entergy agreed to document these commitments to the NRC by May 20, 2008. Please inform us

if our understanding is not correct.

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 accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room). Further, in light of ongoing public interest

in these matters, the NRC has scheduled a public meeting in Cortland, New York on May 20,

2008, as announced by our Meeting Notice dated May 10, 2008, also available at the NRC web

site at http://www.nrc.gov/reactors.plant-specific-items/Indian-point-issues.html, to discuss

NRCs assessment of Entergys performance and actions to address the groundwater conditions

at Indian Point, and the associated impact on public health and safety of the environment.

Sincerely,

/RA/

Marsha K. Gamberoni, Director

Division of Reactor Safety

Docket Nos: 50-003, 50-247

License Nos: DPR-5, DPR-26

Enclosure: Inspection Report Nos. 05000003/2007010, 05000247/2007010

w/Attachment: Supplemental Information

J. Pollock 2

adversely affected, and the dose consequence to the public that can be attributed to current

on-site conditions associated with groundwater contamination is negligible. No significant

findings were identified. However, one minor violation with respect to quality control of

groundwater sampling is discussed in this report. This violation is not subject to enforcement

action in accordance with Section IV of the NRC Enforcement Policy. The NRC plans no further

action with regard to this matter; and no response to this letter is required.

Based on a telephone discussion between Messrs. John McCann, Director of Licensing, and

Samuel Collins, NRC Region I Regional Administrator, on April 21, 2008, we understand that

Entergy has committed to remove and transfer all spent fuel from the Unit 1 Spent Fuel Pool to

Indian Points Independent Spent Fuel Storage Installation, and drain the spent fuel pool by

December 31, 2008, thereby essentially terminating the source of groundwater contamination

from that location. Notwithstanding, it is expected that some water will remain on the bottom of

the pool to reduce the potential for airborne contamination, provide shielding, and facilitate the

removal of the sediment in early 2009. We understand that Entergy will promptly inform the

NRC of any condition that could potentially impact or delay this commitment. Additionally, we

understand that Entergy will incorporate the implementation requirements of its Long Term

Monitoring Program (LTMP) as regulatory specifications in the Indian Point Energy Centers

(IPEC) Off-site Dose Calculation Manual, thereby assuring that the LTMP will be regarded as an

extension of the Radiological Effluents Technical Specifications and Radiological Environmental

Monitoring Program, which are subject to NRC inspection. During the Exit Meeting on May 7,

Entergy agreed to document these commitments to the NRC by May 20, 2008. Please inform us

if our understanding is not correct.

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 accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room). Further, in light of ongoing public interest

in these matters, the NRC has scheduled a public meeting in Cortland, New York on May 20,

2008, as announced by our Meeting Notice dated May 10, 2008, also available at the NRC web

site at http://www.nrc.gov/reactors.plant-specific-items/Indian-point-issues.html, to discuss

NRCs assessment of Entergys performance and actions to address the groundwater conditions

at Indian Point, and the associated impact on public health and safety of the environment.

Sincerely,

/RA/

Marsha K. Gamberoni, Director

Division of Reactor Safety

SUNSI Review Complete: JDN (Reviewer=s Initials) ADAMS ACCESSION NO. ML081340425

DOCUMENT NAME: G:\DRS\Plant Support Branch 2\Noggle\IP 22007010 Rev5Final.doc

After declaring this document AAn Official Agency Record@ it will be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE RI/DRS RI/DRS RI/DRP HQ/FSME via email HQ/NRR

NAME JNoggle/JDN* JWhite//JW* ECobey/ DJ for TSmith//JW for* SGarry/via telephone

DATE 04/25/08 05/12/08 05/06 /08 05/12/08 05/05/08

OFFICE HQ/NRR RI/ORA RI/DRS RI/DNMS HQ/RES/via email

NAME JBoska/via email DHolody/RJS for* MGamberoni/MKG RLorson/RL* TNicholson/JW for:*

DATE 04/29/08 05/02/08 05/13/08 05/12/08 05/1208

• See Previous Concurrence Page OFFICIAL RECORD COPY

J. Pollock 3

cc w/encl:

Senior Vice President, Entergy Nuclear Operations

Vice President, Operations, Entergy Nuclear Operations

Vice President, Oversight, Entergy Nuclear Operations

Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations

Senior Vice President and CCO, Entergy Nuclear Operations

Assistant General Counsel, Entergy Nuclear Operations

Manager, Licensing, Entergy Nuclear Operations

P. Tonko, President and CEO, New York State Energy Research and Development Authority

C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

A. Donahue, Mayor, Village of Buchanan

J. G. Testa, Mayor, City of Peekskill

R. Albanese, Four County Coordinator

S. Lousteau, Treasury Department, Entergy Services, Inc.

Chairman, Standing Committee on Energy, NYS Assembly

Chairman, Standing Committee on Environmental Conservation, NYS Assembly

Chairman, Committee on Corporations, Authorities, and Commissions

M. Slobodien, Director, Emergency Planning

P. Eddy, NYS Department of Public Service

Assemblywoman Sandra Galef, NYS Assembly

T. Seckerson, County Clerk, Westchester County Board of Legislators

A. Spano, Westchester County Executive

R. Bondi, Putnam County Executive

C. Vanderhoef, Rockland County Executive

E. A. Diana, Orange County Executive

T. Judson, Central NY Citizens Awareness Network

M. Elie, Citizens Awareness Network

D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists

Public Citizen's Critical Mass Energy Project

M. Mariotte, Nuclear Information & Resources Service

F. Zalcman, Pace Law School, Energy Project

L. Puglisi, Supervisor, Town of Cortlandt

Congressman John Hall

Congresswoman Nita Lowey

Senator Hillary Rodham Clinton

Senator Charles Schumer

G. Shapiro, Senator Clinton's Staff

J. Riccio, Greenpeace

P. Musegaas, Riverkeeper, Inc.

M. Kaplowitz, Chairman of County Environment & Health Committee

A. Reynolds, Environmental Advocates

D. Katz, Executive Director, Citizens Awareness Network

S. Tanzer, The Nuclear Control Institute

K. Coplan, Pace Environmental Litigation Clinic

M. Jacobs, IPSEC

W. Little, Associate Attorney, NYSDEC

M. J. Greene, Clearwater, Inc.

R. Christman, Manager Training and Development

J. Spath, New York State Energy Research, SLO Designee

A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)

J. Pollock 4

Docket Nos: 50-003, 50-247

License Nos: DPR-5, DPR-26

Enclosure: Inspection Report Nos. 05000003/2007010, 05000247/2007010

w/Attachment: Supplemental Information

Distribution w/encl:

S. Collins, RA

M. Dapas, DRA

S. Williams, RI OEDO (Acting)

R. Nelson, NRR

M. Kowal, NRR

J. Boska, PM, NRR

T. Smith, FSME

J. Hughey, NRR

R. Lorson, NMSS

E. Cobey, DRP

D. Jackson, DRP

B. Welling, DRP

T. Wingfield, DRP

P. Cataldo, DRP, Senior Resident Inspector - Indian Point 3

M. Marshfield, DRP, Senior Resident Inspector - Indian Point 2 (Acting)

C. Hott, DRP, Senior Resident Inspector - Indian Point 2

T. Koonce, Resident Inspector - Indian Point 3 (Acting)

Region I Docket Room (w/concurrences)

ROPreports@nrc.gov

D. Holody, ORA, RI

R. Summers, ORA, RI

K. Farrar, ORA, RI

A. DeFrancisco, ORA, RI

C. ODaniell, ORA, RI

M. Gamberoni, DRS

D. Roberts, DRS

J. White, DRS

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket Nos.50-003, 50-247

License Nos. DPR-3, DPR-26

Report Nos. 05000003/2007010 and 05000247/2007010

Licensee: Entergy Nuclear Northeast

Facility: Indian Point Nuclear Generating Station Units 1 & 2

Location: 295 Broadway

Buchanan, NY 10511-0308

Dates: November 7, 2007 - May 7, 2008

Inspectors: 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

J. Kottan, State Agreements Officer

J. Commiskey, Health Physicist

Approved by: John R. White, Chief

Plant Support Branch 2

Division of Reactor Safety

TABLE OF CONTENTS

Page

SUMMARY OF FINDINGS.iii

EXECUTIVE SUMMARY...iv

4.0 OTHER ACTIVITIES (OA).1

4OA5 Other Activities...1

.1 Overview of the Groundwater Contamination Investigation1

.2 Final Groundwater Contamination Characterization.3

.3 Groundwater Sampling.....4

.4 Dose Assessment..7

.5A Unit 2 SFP Leakage9

.5B Unit 1 SFP Leakage.11

.6 Hydrogeologic Investigations.13

.7 Prior Indications of On-site Groundwater Tritium Contamination.17

.8 Remediation and Long Term Monitoring Plans..19

.9 Regulatory Requirements.......21

4OA6 Meetings, including Exit..24

Figure 1: Long Term Monitoring Plan

Figure 2: Unit 1 Building Foundation Drain System

Figure 3: Observed Bedding and Conjugate Fractures in Verplanck Quarry

Figure 4: Downhole Flow Meter and Geophysical Survey

Figure 5: Unit 2 Spent Fuel Pool Tritium Plume Cross Section

Attachment 1: Indian Point Contaminated Groundwater Investigation Time Line

Attachment 2: Site Groundwater Contaminant Concentrations

Attachment 3: Supplemental Information

ii

SUMMARY OF FINDINGS

IR 05000247/2007010 & IR 05000003/2007010; 11/08/2007 - 05/07/2008; Indian Point Nuclear

Generating Station Units 1 & 2; Other Activities - associated with ROP deviation memorandum.

The report covers an inspection of a September 1, 2005, licensee-identified Unit 2 spent fuel

pool leak investigation final report and long term monitoring plan; and review of historical

leakage involving the Unit 1 spent fuel pool by three regional inspectors, one headquarters

hydrology specialist, and a U.S. Geological Survey hydrology specialist. The NRC=s program for

overseeing the safe operation of commercial nuclear power reactors is described in NUREG-

1649, AReactor Oversight Process, Revision 4, dated December 2006.

A. NRC - Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee - Identified Violations

None

iii

EXECUTIVE SUMMARY

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, and that low levels of radioactive

contamination were found in water leaking from the cracks having radionuclides similar to Unit 2

spent fuel pool water. Entergy initiated a prompt investigation to determine the extent of the

condition and potential impact on health and safety. Initially, Entergy determined that on-site

groundwater in the vicinity of the Unit 2 facility was contaminated with tritium as high as 200,000

picocuries per liter of water (about ten times the EPA drinking water standard). Subsequently,

Entergy initiated actions to perform a comprehensive groundwater site characterization to

investigate the extent of on-site groundwater contamination, identify the sources, and mitigate

and remediate the condition. This effort required the establishment of several on-site

groundwater monitoring wells to characterize groundwater behavior, flow, direction, and

migration pathways.

On September 20, 2005, Region I initiated a special inspection of this matter to examine the

licensees performance and determine if the contaminated groundwater effected, or could effect,

public health and safety. On October 31, 2005, NRCs Executive Director of Operations (EDO)

authorized continuing NRC inspection to assess licensee performance of on-site groundwater

investigation activities, and independently evaluate and analyze data and samples to assure the

effectiveness and adequacy of the licensees efforts. Throughout this effort, the NRC

coordinated its inspection activities with the New York State Department of Environmental

Conservation (DEC), which initiated its own independent assessment of the groundwater

conditions, including observation of NRCs inspection activities.

The NRC issued a special inspection report on March 16, 2006 (ADAMS Accession No.

ML060750842). The report assessed Entergys performance, achievements, and plans relative

to radiological and hydrological site characterization; and reported that the on-site groundwater

contamination did not, nor was likely to, adversely affect public health and safety. In the report

and in subsequent public meetings, NRC indicated that it would continue to inspect licensee

performance in this area, including independent evaluation and analysis of data, to assure that

Entergy continued to conform to regulatory requirements, and that public health and safety was

maintained.

On March 21, 2006, NRCs independent on-site groundwater sample analysis effort first

determined that strontium-90 was also a contaminant in the groundwater, a fact that was

subsequently confirmed by Entergy and the DEC. This determination resulted in a significant

expansion of the on-site groundwater characterization effort since the source of the strontium-90

contaminant was traced to leakage from the Unit 1 Spent Fuel Pool. A full site-wide

hydrogeologic investigation was subsequently scoped to include Unit 1 and Unit 3. The NRC

inspection charter objectives were similarly revised to provide the necessary oversight. Off-site

groundwater samples have also been obtained since the fall of 2005, and have never detected

any off-site groundwater contamination.

iv

Since that time, the NRC has continued to inspect and monitor Entergys activities beyond the

limits of normal baseline inspection, as authorized by NRCs Executive Director of Operations

(EDO). During this period, NRC inspectors closely monitored Entergys groundwater

characterization efforts, and performed independent inspection of radiological and hydrological

conditions affecting on-site groundwater. Additionally, from early 2006 through January 2008,

the NRC kept interested Federal, State, and Local government stakeholders informed of current

conditions through routine bi-weekly teleconferences.

Status of Current Activities, Plans, and Inspection Results:

On January 11, 2008, Entergy submitted the results of its comprehensive ground water

investigation, and included its plan for remediation and long-term monitoring of the on-site

groundwater conditions. In its report, Entergy described the sources of the groundwater

contamination to be the Unit 1 and Unit 2 spent fuel pools. While both pools contributed to the

tritium contamination of groundwater, leakage from the Unit 1 spent fuel pool was determined to

be the source of other contaminants such as strontium-90, cesium-137, and nickel-63. Entergy

identified its plan to remove all fuel from the Unit 1 spent fuel pool to an on-site storage location

and drain the spent fuel pool system by the end of 2008, thereby essentially eliminating the

source of the groundwater contamination from that facility. Some water is expected to remain in

the bottom of the pool to reduce the potential for airborne contamination and provide shielding

until the residual sludge is removed in early 2009. In the January 11, 2008 report, Entergy

described its actions to repair or mitigate all identified potential leak locations in the Unit 2 spent

fuel pool system that may have contributed to the on-site tritium-contaminated groundwater in

the vicinity of that facility.

Notwithstanding, residual radioactivity is expected to continue to impact on-site groundwater for

the duration of licensed activities. On-site groundwater is expected to continue to be monitored

and reported as an abnormal liquid release in accordance with NRC regulatory requirements.

No off-site groundwater has been impacted, since the on-site groundwater flow is to the

discharge canal and the Hudson River. Accordingly, the licensee has established a long-term

monitoring strategy for the purpose of evaluating the effect and progress of the natural

attenuation of residual contamination, informing and confirming groundwater behavior as

currently indicated by the existing site conceptual model, and determining changes in conditions

that may be indicative of new or additional leakage.

Entergys performance and effectiveness relative to successfully draining water from the Unit 1

spent fuel pool system by the end of 2008, and the quality and effectiveness of its long-term

monitoring program, will be the immediate focus of NRCs continuing inspection of Entergys

performance and conformance with regulatory requirements relative to the existing groundwater

conditions. Additionally, NRC will continue to inspect the efficacy of the licensees long-term

monitoring program as part of the Reactor Oversight Process pertaining to radiological

environmental and effluents inspection activities.

Notwithstanding, radiological significance from the groundwater conditions at Indian Point is

currently, and is expected to remain negligible with respect to impact on public health and safety

and the environment. NRC has confirmed with the New York State Department of Health, that

drinking water is not derived from groundwater or the Hudson River in the areas surrounding or

v

Enclosure

influenced by effluent release from Indian Point. Accordingly, the only human exposure pathway

of merit is from the possible consumption of aquatic foods from the Hudson River, such as fish

and invertebrates. Dose assessment of the potential for exposure from this pathway, continues

to indicate that the hypothetical maximally exposed individual would be subject to no more than

a very small fraction of the NRC regulatory limit for liquid radiological effluent release.

Status of Current Inspection Results:

1. Upon the initial identification of conditions that provided evidence of an abnormal

radiological effluent release affecting ground water, the licensee implemented actions

that conformed to the radiological survey requirements of 10 CFR 20.1501 to ensure

compliance with dose limits for individual members of the public as specified in 10 CFR

20.1302, including: (1) promptly investigating and evaluating the radiological conditions

and potential hazards affecting groundwater conditions, on- and off-site; (2) annually

reporting the condition, and determining that the calculated hypothetical dose to the

maximally exposed member of the public was well below established NRC regulatory

requirements for liquid radiological release; (3) confirming, through off-site

environmental sampling and analyses, that plant-related radioactivity was not

distinguishable from background; (4) initiating appropriate actions to mitigate and

remediate the conditions to assure that NRC regulatory dose limits to members of the

public and the environment were not exceeded; and (5) developing the bases for a long-

term monitoring program to ensure continuing assessment of groundwater effluent

release and reporting of the residual radioactivity affecting the groundwater. Additional

refinement of the long term monitoring program is expected to occur as data is collected

and evaluated to verify and validate the effectiveness of expected natural attenuation of

the existing groundwater plumes, and to ensure the timely detection of new or additional

leakage affecting ground water.

2. The determination of contaminated on-site groundwater conditions at Indian Point was

the result of the licensees investigation of potential leakage from the Unit 2 Spent Fuel

Pool initiated in September 2005, and subsequent development and application of a

series of ground water monitoring wells to determine the extent of that condition. No

evidence was found that indicated that the events at Indian Point, that resulted in the on-

site groundwater contamination (identified to the NRC on September 1, 2005), were the

result of the licensees failure to meet a regulatory requirement or standard, where the

cause of the condition was reasonably within the licensees ability to foresee and correct,

and should have been prevented. This determination is based on: interviews with

licensee personnel; comprehensive review of pertinent documentation, including

previous condition reports, survey records, radiological liquid effluent and environmental

monitoring reports, records of historical spills and leaks documented in accordance with

10 CFR 50.75, Reporting and Recordkeeping for Decommissioning Planning; and

extensive on-site NRC inspection to confirm licensee conformance with required

regulatory requirements.

3. The current contaminated groundwater conditions at Indian Point Energy Center are the

result of leakage associated with the Unit 1 and Unit 2 spent fuel pool (SFP) systems.

No other systems, structures, or components were identified as contributors to the

continuing on-site contamination of ground water.

vi

Enclosure

4. Entergys hydrogeologic site characterization studies provided sufficiently detailed field

observations, monitoring, and test data which supported the development and

confirmation of a reasonable conceptual site model of groundwater flow and transport

behavior. An independent analysis of groundwater transport through fractured bedrock

utilizing geophysical well logging data was conducted by the U.S. Geological Survey

(USGS). The USGS assessment corroborated the groundwater transport characteristics

that were determined by Entergys contractor.

5. Entergys hydrogeologic site characterization and developed conceptual site model

provide a reasonable basis to support the determination that the liquid effluent releases

from the affected spent fuel pool systems migrate in the subsurface to the west, and

partially discharge to the sites discharge canal, with the remainder moving to the Hudson

River. Current data and information indicates that contaminated groundwater from the

site does not migrate off-site except to the Hudson River. This conceptual site model of

groundwater behavior and flow characteristics is supported by the results of independent

groundwater sampling and analyses conducted by NRC, which have not detected any

radioactivity distinguishable from background in the established on-site boundary

monitoring well locations, or in various off-site environmental monitoring locations.

6. Currently, there is no drinking water exposure pathway to humans that is affected by the

contaminated groundwater conditions at Indian Point Energy Center. Potable water

sources in the area of concern are not presently derived from groundwater sources or the

Hudson River, a fact confirmed by the New York State Department of Health. The

principal exposure pathway to humans is from the assumed consumption of aquatic

foods (i.e., fish or invertebrates) taken from the Hudson River in the vicinity of Indian

Point that has the potential to be affected by radiological effluent releases.

Notwithstanding, no radioactivity distinguishable from background was detected during

the most recent sampling and analysis of fish and crabs taken from the affected portion

of the Hudson River and designated control locations.

7. The annual calculated exposure to the maximum exposed hypothetical individual, based

on application of Regulatory Guide 1.109, Calculation of Annual Doses to Man from

Routine Release of Reactor Effluents for the Purpose of Evaluation Compliance with 10

CFR Part 50, Appendix I, relative to the liquid effluent aquatic food exposure pathway is

currently, and expected to remain, less than 0.1 % of the NRCs As Low As is

Reasonably Achievable (ALARA) guidelines of Appendix I of Part 50 (3 mrem/yr total

body and 10 mrem/yr maximum organ), which is considered to be negligible with respect

to public health and safety, and the environment.

8. All identified liner flaws in the Unit 2 spent fuel pool, and the initially identified crack

affecting the Unit 2 spent fuel pool system have been repaired or mitigated. However,

not all Unit 2 fuel pool surfaces are accessible for examination. No measurable leakage

is discernable from evaporative losses based on Unit 2 fuel pool water makeup inventory

data. Unit 1 spent fuel pool water is being processed continuously to reduce the

radioactive concentration at the source prior to leakage into the groundwater, and actions

have been initiated to effect the complete removal of spent fuel and essentially all the

water from the Unit 1 Spent Fuel Pool system by the end of 2008, thereby terminating the

source of 99.9% of the dose significant strontium-90 and nickel-63 contaminants (the

remaining 0.1% is represented by the Unit 2 and Unit 1 hydrogen-3 (tritium)

contaminants). Entergys selected remediation approach for the contaminated

groundwater conditions appears reasonable and commensurate with the present

radiological risk.

vii

Enclosure

9. The historical duration of leakage from the Unit 1 and Unit 2 spent fuel pool systems that

resulted in groundwater contamination is indeterminate. The evidence indicates that the

volume of leakage was small compared to the available water inventory, and was much

less than the normally expected evaporative losses from spent fuel pools. This

conclusion is based on NRC staff review and assessment of spent fuel pool makeup

inventory records and applicable leakage collection data, the results of the continuously

implemented Radiological Environmental Monitoring Program affecting the Indian Point

site, and evaluation of the developed hydrogeologic groundwater transport model.

Accordingly, there is no evidence of any significant leak or loss of radioactive water

inventory from the site that was discernable in the off-site environment.

10. No releases were observed or detected from Unit 3.

11. The conditions surrounding the leaking Unit 1 spent fuel pool are based on a leakage

rate of 10 drops per second (about 25 gallons per day) that was identified in 1992. At

that time, the licensee performed a hypothetical bounding dose impact that concluded

that there was negligible dose impact to the public caused by this condition. This

licensee assessment was inspected and evaluated, at that time, by NRC inspectors.

This early bounding hypothetical calculation agrees with the dose impact now confirmed

by the recently completed hydrogeologic site investigation, and NRCs independent

assessment. Based on extensive review of the circumstances and inspection records

from that period, it appears that the licensee was in conformance with the standards,

policy, and regulatory requirements that prevailed at that time.

viii

Enclosure

REPORT DETAILS

4.0 OTHER ACTIVITIES (OA)

4OA5 Other Activities

.1 Overview of the Groundwater Contamination Investigation

In September 2005, a crack was discovered leaking on the outside of the Unit 2 spent fuel

pool south wall (approximately 30 feet below the top) during excavation of the spent fuel

building loading bay. The NRC initiated a special inspection on September 21, 2005, to

investigate the implications of the observed Unit 2 spent fuel pool leakage. Based on

analysis of the radionuclide concentrations in the Unit 2 spent fuel pool and maximum

bounding pool makeup losses, a bounding dose calculation based on direct release to the

Hudson River indicated a tiny fraction of 1 mrem (0.00002 mrem/yr) as the estimated dose

to the maximally exposed hypothetical individual. Though the radiological significance of

the circumstance was negligible, the condition was unexpected. Accordingly, NRC Region

I was authorized by the Executive Director of Operations (EDO) to conduct additional

oversight inspection of licensee performance and the circumstances surrounding this

contamination issue to better understand the condition and examine possible generic

implications, since similar conditions had been identified at other facilities.

Due to the complicated nature of the groundwater characterization effort at Indian Point

(i.e., a relatively small site containing two operating units and one unit in SAFSTOR, built

on a complex fractured bedrock foundation that required sophisticated analysis and

modeling to fully understand groundwater behavior), the EDO renewed the increased

inspection authorization each year to permit active and frequent inspection oversight. As a

result, inspection of the Indian Point contaminated groundwater conditions evolved to

include not only radiological environmental and effluent expertise from Region I, but also

hydrological assessment expertise from NRCs Office of Research, and later, from the US

Geological Survey (USGS). The application of such resources permitted the NRC to

conduct several independent reviews and assessments of data, information, and analysis

on which the licensee based its conclusions and determinations.

In addition, the NRC and USGS specialists, worked closely with the New York State

Department of Environmental Conservations (NYS DEC) by sharing data and assessment

information, coordinating independent split sampling of various sample media, and

providing a combined oversight of licensee performance.

On November 7, 2005, the licensee began installing a series of monitoring wells on-site,

based on an initial understanding of on-site groundwater flow patterns and associated

contaminant transport. Thirty-six monitoring wells were installed over the next 2 years,

with the final well installed and operational by the end of August 2007. The groundwater

monitoring network ultimately developed by Entergy includes these plus a number of

previously existing monitoring locations. Various geophysical evaluations and analyses,

including groundwater table mapping, ground permeability measurements and

groundwater gradient calculations, were performed and two site-wide hydrology tests were

2

conducted to observe groundwater response in a network of monitoring wells. These tests

included a 3-day duration groundwater pump-down test from the Unit 2 spent fuel pool

(SFP) leak location, and injection of a tracer dye at the base of the Unit 2 SFP to trace its

path across the site.

This body of information was utilized by Entergy to determine the sources of the

groundwater contamination, evaluate the potential for leak mitigation through pumping,

and confirm the site groundwater transport model through a final tracer test. Throughout

the investigation frequent iterations were made to refine the extent of groundwater

contamination, the total amount of contaminant released to the environment, and the

resulting public dose assessment to ensure that public health and safety were maintained.

As additional wells were drilled and sampled, gradually the full extent of on-site ground

water contamination was revealed. A short synopsis providing the significant highlights of

the licensees investigation follows, with a more detailed timeline provided in Attachment 1,

Timeline Synopsis.

On February 27, 2006, hydrogen-3 (tritium) contamination was detected in a monitoring

well beyond the discharge canal, providing the first evidence of potentially contaminated

groundwater being directly released into the Hudson River. On February 28, 2006, the

licensee developed a new groundwater release bounding calculation methodology based

on an overall site rainfall recharge into several discrete site drainage areas to the Hudson

River. On March 21, 2006, radionuclides other than tritium (strontium-90 and nickel-63)

were first discovered in a monitoring well, which was later determined to be associated

with the Unit 1 spent fuel pool system.

On April 24, 2006, utilizing a rainfall recharge water mass balance approach to calculate

groundwater flow and more recent monitoring well data utilizing the maximum

concentrations of hydrogen-3 (tritium), strontium-90, and nickel-63, a new revised public

dose estimate (from the hypothetical consumption of fish) indicated a maximum

hypothetical public dose of 0.0025 mrem/yr to the total body and a maximum of 0.011

mrem/yr to the highest organ (adult bone). These values represent about 0.1% of the

regulatory specification for liquid effluent releases contained in the Offsite Dose

Calculation Manual. This specification is derived from 10CFR50, Appendix I, As Low As is

Reasonably Achievable (ALARA) design objectives for liquid effluent releases.

The basis for calculating public doses is site specific, and at Indian Point, is based on the

hypothetical, assumed consumption of fresh water fish and salt water invertebrates. Due

to a higher dose significance of strontium-90 detected in groundwater releases, Entergy

revised its Off-site Dose Calculation Manual (ODCM) to include the analysis of strontium-

90 in environmental media, such as fish and invertebrates collected from the Hudson

River. Consumption of fish was assumed notwithstanding the fact that the New York State

Department of Health publishes health advisories for sport and game fish and

recommends very limited or no consumption of fish be taken from the lower reaches of the

Hudson River due to mercury and Poly-Chlorinated Biphenyls (PCB) contaminants.

Enclosure

3

Subsequently, during the summer of 2006, Entergy collected and analyzed fish from the

Hudson River, and strontium-90 was identified in one fish collected near the plant as well

as in several fish caught in a control location 20 miles upstream of the plant at similar

concentrations. In order to resolve whether the strontium-90 was plant-related or the result

of existing background levels (Sr-90 exists in environment due to weapons-related fallout),

an expanded fish sampling program was devised by the New York State DEC. The

program included an additional 90 mile upstream sample location, the collection of specific

fish species identified by the States biologist as having limited migratory behavior, and a

three-way split of the edible fish portions of the prepared samples between NRC, Entergy,

and the NYS DEC. The effort was conducted in June 2007. In the expanded samples, all

three independent analytical laboratories reported results that indicated that no plant-

related radioactivity was detected or distinguishable from background. To date, no offsite

environmental samples (other than water samples from the discharge canal and the tidally

influenced intake structure) have indicated any detectable plant-related radionuclides,

The USGS performed an independent fracture flow analysis to determine on-site

groundwater flow utilizing different data and methods than Entergy to compare

groundwater flow results with the licensee. This provided a comparison of fracture flow

dominated groundwater flow with the licensees groundwater flow results based on an

assumption of general porous media flow through dense fracture sets in the ground. No

significant differences were observed from these comparisons, which essentially confirmed

that either model of groundwater transport flow provided valid results.

On January 11, 2008, Entergy submitted a hydrogeologic site investigation final report to

the NRC documenting closure of the groundwater investigation, adoption of selected

remediation actions, and a plan for the continued long-term monitoring of the existing

contaminant plumes (ADAMS Accession No. ML080320600). On January 25, 2008,

Entergy submitted a synopsis of the long term monitoring plan basis to describe a

groundwater monitoring network and a sampling schedule to continue monitoring the

existing plumes, detect any future Unit 2 spent fuel pool leaks, and detect any future leaks

from any other plant systems structures or components at the site (ADAMS Accession No.

ML080290204).

This inspection report provides NRC review of the above mentioned licensee activities.

Continued NRC inspection will continue through 2008 of the removal of spent fuel and

draining of the leaking Unit 1 spent fuel pool, split sampling to verify the basis of licensees

off-site dose assessment, and review of further development and refinements to the

licensees long term monitoring plan. Inspection findings will be documented in future

reports.

.2 Final Groundwater Contamination Characterization

By the end of 2007, based on over 900 monitoring well samples, the extent of the on-site

subsurface contamination had been mapped and the sources have been determined. Two

on-site plumes were discovered emanating from the Unit 2 and Unit 1 spent fuel pool

regions, respectively. Due to the influence of the Unit 1 building foundation drain system,

some of the Unit 2 plume was drawn into the Unit 1 area, with both plumes intermingling

Enclosure

4

and following a converging path westward towards the Hudson River. Both plumes were

relatively shallow (less than 200 feet below ground surface) following a common

groundwater trough between Units 1 and 2, and a groundwater transport velocity of

between 4 and 9 feet per day, covering a total distance of about 400 feet to the Hudson

River (see Figure 1). Approximately one-half of the combined plumes are being

intercepted by the plant discharge canal which allows for substantial dilution of this fraction

and is a monitored discharge path. The other portion of the combined plumes flows below

the discharge canal and discharges directly into the bottom of the Hudson River.

Due to limited groundwater sampling of the new river front monitoring wells across normal

seasonal groundwater flow variations, no trend in plume concentrations is yet discernable.

Current contaminant concentrations detected from monitoring wells closest to the Hudson

River indicate 9,000 pCi/L of hydrogen-3 (tritium) and 27 pCi/L of strontium-90. A map of

monitoring well locations and a table of radionuclide concentration values at each

monitoring well are provided in Attachment 2.

These concentrations are slightly below the minimum required effluent release detection

sensitivities for these radionuclides (i.e., 10,000 pCi/L for hydrogen-3 (tritium) and 50 pCi/L

for strontium-90), and well below the maximum allowable liquid effluent release ALARA

guidelines of ten times the effluent concentrations in 10 CFR 20, Appendix B, Table 2,

Column 2 (10,000,000 pCi/L for hydrogen-3 (tritium) and 5,000 pCi/L for strontium-90).

NRC required calculation of the maximum dose to a hypothetical person consuming fish

and invertebrates at the site boundary, indicates less than 0.1% of design objectives for

liquid effluents (3 mrem total body and 10 mrem maximum organ). Since the groundwater

contamination is considered an abnormal release, the condition is required to be

quantified, evaluated and reported in the annual radiological effluent release reports.

.3 Groundwater Sampling

a. Inspection Scope

During the licensees groundwater investigation, over 900 groundwater samples were

collected and analyzed from the established on-site monitoring well network by the end of

2007. 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 Entergys 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 southern boundary

wells and those bordering the Hudson River that were utilized in 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 government laboratory. The

NRC samples were sent to the NRC contract laboratory, the Oak Ridge Institute for

Science and Education (ORISE), Environmental Site Survey and Assessment Program

(ESSAP) radioanalytical laboratory.

Enclosure

5

By the end of 2007, over 250 split groundwater samples were obtained to provide an

independent check of Entergys analytical results and to independently verify if there was

any detectable migration of groundwater contaminants offsite. These split samples

represent over 1,000 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.

Various in-plant contamination sources (the Unit 1 and 2 spent fuel pools and others) were

also sampled and analyzed by the NRC for a complete range of radionuclides to evaluate

the known and potential leaking sources of radioactivity, and to ensure an adequate scope

of radionuclide analysis was conducted by the licensee in their groundwater sampling

campaign. In addition, the NRC analyzed miscellaneous environmental samples of

interest including offsite water supply sources, Hudson River aquatic vegetation, and fish

samples. The New York State DEC also provided confirmation of the licensees sample

analysis results through a parallel split sample program. This provided for a three-way

laboratory comparison of many of the offsite release and environment-critical sample

results. This three-way data comparison provided for timely identification of any discrepant

sample results potentially affecting offsite releases.

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 NRC and the State of

New York, (i.e., the Department of Environmental Conservation and the Department of

Health). Of the over 1000 results that were reviewed, there were some sample

disagreements based on the statistical comparison criteria specified in NRC Inspection

Procedure 84750, Radioactive Waste Treatment, and Effluent and Environmental

Monitoring. A discussion of the sample disagreements is provided below.

• Between March and September 18, 2006, Entergy reported some strontium-90

results associated with the Unit 1 plume that were low when compared to NRC

results. Entergys results indicated that the Unit 1 spent fuel pool cleanup system

had shown a reduction in the associated groundwater plume concentrations over

a relatively short period of time. There was no other consequence due to this

disparity. Entergy initiated an investigation into this issue with their offsite

contract laboratory. The investigation did not identify a definitive cause. As a

result, Entergy terminated its contract with the lab and procured the services of

another offsite laboratory. Entergys reanalysis of the samples confirmed that the

original results were low. The reanalysis results were subsequently in agreement

with the NRC laboratory results.

• Entergy reported no detectable nickel-63 contamination in four samples from

Monitoring Well-42 taken on November 16-17, 2006. Since Monitoring Well-42 is

closest to the Unit 1 SFP, and other radionuclides analyzed at the same location

remained at expected levels, this indication was not considered reasonable and

Enclosure

6

was also not in agreement with the New York State or NRC laboratory results.

This resulted in an investigation into this issue by the licensees new off-site

contract laboratory. Improper procedure protocol was identified and additional

controls were implemented to correct this issue. Reanalysis of the nickel-63

results were in agreement with the NRC laboratory results. No other significant

sample anomalies were identified by the NRC through the end of 2007.

The above NRC-identified discrepancies highlighted the need for quality control in the

licensees sample acquisition and laboratory processing and measurement processes.

Oversight of offsite laboratory analysis of samples was not originally specified by the

licensee for on-site groundwater sampling. NRC radiological environmental monitoring

program laboratory quality control requirements, specify radionuclide detection

sensitivities, and require blind blank samples and blind radionuclide-spiked samples to

be provided by the licensee as a check on the off-site laboratorys analytical

performance. These requirements apply to the offsite radiological environmental

monitoring program, but no requirements are specified for on-site groundwater sample

quality controls.

NRC radiological effluent sampling analyses also require laboratory quality controls as

specified above. On February 27, 2006, based on detecting hydrogen-3 (tritium) in a

monitoring well near the Hudson River, Entergy revised their bounding dose calculation

and began calculating actual effluent releases via the groundwater pathway. At this

point in the groundwater investigation, the quality assurance of groundwater sample

analyses used in effluent reporting became a requirement. However, the offsite

laboratory analyses of groundwater samples were not independently evaluated by

Entergy until more than one year later. Technical Specifications Section 5.4.1(a)

specifies written procedures shall be established, implemented, and maintained covering

Appendix A of Regulatory Guide 1.33, Revision 2, which specifies quality assurance

requirements for procedures associated with the control of radioactive effluents released

to the environment. The inadequate procedure (O-CY-1420, Rev. 1), constitutes a

violation of minor significance that is not subject to enforcement action in accordance

with Section IV of the NRC Enforcement Policy. There was no actual or potential

consequence of this procedure deficiency, because in function, the NRC and NYS DEC

split sampling program provided a very effective verification of Entergys laboratory

sample analysis program during the groundwater investigation by assuring the accuracy

of analytical results.

To address this concern, in May 2007, Entergy initiated an on-site groundwater sampling

quality control program incorporating a blind blank sample and blind radionuclide-spiked

sample program to verify its own offsite laboratory analytical results. In addition,

Entergys corrective action program is still addressing the quality control program

requirements relative to groundwater sample analysis, with corrective action

responsibilities transferred to the corporate group for resolution (CR-HQN-2007-00894).

NRC split sample analysis comparison of the licensees groundwater sample results are

expected to continue until such time as Entergy has addressed all of the concerns

associated with laboratory quality assurance issue.

Enclosure

7

Due to the presence of strontium-90 in groundwater monitoring wells close to the Hudson

River, Entergy modified their environmental monitoring analysis of fish samples to

include strontium-90 analysis and in September 2006, strontium-90 was detected in one

of six fish caught near the plant. Three out of six samples caught 20 miles upstream at

the control location also contained similar detectable levels of strontium-90. Entergy

concluded that no strontium-90 was detected above background based on similar results

obtained from the control location. Strontium-90 is not uniquely generated by nuclear

power plants, but was also generated from above ground nuclear testing in the early

1950s and 1960s and now exists ubiquitously in the environment. From a review of

applicable scientific literature, comparable levels of strontium-90 that were detected in

the September 2006 fish samples were also indicated in background fish testing results

in other parts of New York State.

To further clarify the origin of the strontium-90 and confirm the efficacy of utilizing

Entergys control location in monitoring background strontium-90 concentrations in fish,

an expanded fish sampling program was conducted in June 2007 led by NYS DEC, in

consultation with its fish biologists, to ensure that the control location is sufficiently

removed from Indian Point to preclude fish migration and to accurately represent

background levels of strontium-90. This expanded fish sampling program collected fish

samples from three Hudson River locations: an area influenced by liquid releases from

Indian Point, a control location 20 miles upstream, and a special control location 90 miles

upstream in the Catskills. Three-way split fish samples were supplied to Entergy, NYS

DEC and NRC for inter-laboratory comparison of these results. Neither strontium-90 nor

any plant-related radionuclides were detected in any edible fish samples by any of the

three participating laboratories at any of the three Hudson River locations. This is

considered significant, since public doses from liquid discharges from Indian Point are

calculated based on assumed fish and invertebrate consumption. This confirms the

results expected from the groundwater effluent and normal plant liquid effluent release

calculations, indicating small fractions of one millirem per year to the maximally exposed

hypothetical member of the public that consumes fish and invertebrates.

.4 Dose Assessment

a. Inspection Scope

Groundwater effluent discharges and associated hypothetical dose calculations to the

public involve a two-step process. First, a groundwater transport model is developed to

estimate the amount of radioactive material being discharged and its dilution into the

environment. The hydrogeologic site investigation of Indian Point has provided the

results for determining this aspect of the dose calculation.

Second, based on methods defined in the Indian Point Energy Center Offsite Dose

Calculation Manual (ODCM), calculations are performed to determine the maximally

exposed individual (infant, child, teen or adult) and maximum organ (bone, kidney,

gastro-intestinal tract, liver, thyroid, lung and total body). NRC has confirmed with the

NYS Department of Health that groundwater and Hudson River water is not used for

drinking or irrigation purposes in the area surrounding Indian Point Energy Center.

Therefore, at Indian Point Energy Center, the liquid effluent dose pathway is through the

Enclosure

8

ingestion of fish and invertebrates (crab). Both the groundwater effluent discharge and

the pathway-to-man methodologies and calculation methods were reviewed throughout

the licensees investigation in order to ensure that the significance of the liquid effluent

releases were bounded and the associated dose impact was evaluated to provide an

accurate dose assessment of public health and safety.

b. Findings and Assessment

No findings of significance were identified.

The licensee performed an initial conservative bounding dose calculation, dated

October 21, 2005, that assumed a worst case condition, i.e., Unit 2 spent fuel pool water

being discharged directly into the Hudson River with minimal Hudson River dilution flow

(approximately 100,000 gallons per minute). This dose assessment assumed a

conservative Unit 2 SFP leak rate of 2.6 gallons per day1 incorporating all the

radionuclides detected. The resultant calculated dose was about 0.0001 millirem/year,

well below the ALARA design objectives for liquid effluent releases (3 millirem/year per

reactor) and a very small percentage of the public dose limits (100 millirem per year).

The inspectors concluded that the licensee=s preliminary offsite dose calculation utilized

conservative assumptions regarding the Unit 2 SFP leak rate and groundwater dilution,

appropriately applied the methodology of the licensee=s Offsite Dose Calculation Manual,

provided a timely dose evaluation response to the identified condition.

As more data became available, the licensee performed a revision to the conservative

bounding calculation, dated December 13, 2005, using Hudson River dilution based on a

six hour half-tidal surge. This resulted in a dilution volume of 1.45E10 gallons. This

revised bounding dose calculation was based on the actual radioactivity concentration of

the Unit-2 SFP and the resultant annual dose to the hypothetical maximally exposed

member of the public was calculated to be about 0.0001millirem/year. This revision was

based on conservative and reasonable assumptions and agreed with the result from the

original bounding calculation.

As on-site groundwater monitoring wells were installed, groundwater sample results were

collected, water table contours were identified, and groundwater transport parameters

were determined. Entergy developed a site area drainage model based on annual

rainfall groundwater recharge water balance and applied maximum monitoring well

groundwater concentrations, which was used in a February 28, 2006 effluent release and

off-site dose calculation with a result of 0.000015 mrem/yr to the maximally exposed

hypothetical member of the public. This was no longer a bounding calculation, but

represented an actual groundwater effluent release determination based on groundwater

measurements and groundwater drainage calculations. Radiological and hydrogeologic

inspection of this method determined that the basis was reasonable and the calculations

were accurate.

1

The basis for the assumed value of 2.6 gallons per day is discussed in Section 5 of this

report.

Enclosure

9

Later in the investigation on March 21, 2006, NRC sample results of Monitoring Well-37

(a river front monitoring well) indicated strontium-90 concentration of 26 pCi/L. This was

the first indication that strontium-90 was likely being released directly to the Hudson River

through the groundwater. Licensee results confirmed both strontium-90 and nickel-63, in

addition to hydrogen-3 (tritium), were likely migrating to the Hudson River. The dose

significance for these additional radionuclides is over one hundred times that of

hydrogen-3 (tritium). On April 24, 2006, Entergy updated their dose assessment in

recognition of this new monitoring well data, and applied the maximum concentrations of

hydrogen-3 (tritium), strontium-90 and nickel-63. The resulting groundwater effluent

discharge and off-site dose assessment indicated a maximum hypothetical public dose of

0.0025 mrem total body and 0.011 mrem maximum organ dose (adult bone) per year.

The increase from the previous dose estimates is a direct result of the strontium-90 and

nickel-63 radionuclides.

As additional groundwater sample data became available, the licensees dose

assessment model was further refined to rank the monitoring well sample data in each

site drainage area from low to high, and apply a 75th percentile of radionuclide

concentration to the dose assessment calculations. This approach was determined to be

more realistic and yet still conservative. Utilizing this methodology, abnormal

groundwater effluent releases were calculated and the following doses for groundwater

releases in 2005 and 2006 were officially reported to the NRC in the annual radiological

effluent release reports as follows:

2005: 0.00212 mrem total body and 0.0097 mrem maximum organ (adult bone)

2006: 0.00178 mrem total body and 0.0072 mrem maximum organ (adult bone)

Based on discussions with the NRC and USGS hydrologists, Entergy agreed to further

evaluate the groundwater flow rate model to utilize groundwater flux calculations based

on Darcys Law, a hydrogeological algorithm that considers actual groundwater gradient

and soil permeability rather than inferring groundwater flow based on a rainfall infiltration

model. Accordingly, Entergy initiated actions to develop a refined method to calculate

local drainage area groundwater flux calculations based on Darcys Law while retaining

an overall rainfall infiltration as input to the local drainage calculations. Entergy intends

to use this approach to calculate and report the 2007 groundwater effluent discharges

and dose assessments.

.5A Unit 2 SFP Leakage

a. Inspection Scope

The Unit 2 SFP does not have a leak detection system, therefore, the licensee used

alternative means of assessing the amount of leakage from the spent fuel pool.

Detectable fuel pool inventory loss could not be determined based on fuel pool water

makeup records, given the variability in water evaporation loss due to atmospheric

temperature, pressure, and humidity variations. A more sensitive indicator of spent fuel

Enclosure

10

pool water loss utilized the trending of spent fuel pool boric acid concentration over time,

since boric acid is not affected by evaporative losses and any reduction in boric acid

concentration would likely be due to leakage.

The NRC followed Entergys progress in examination of the Unit 2 SFP liner and transfer

canal for leaks and subsequent repair of a through-wall leak in the transfer canal.

As was reported in the March 16, 2006 special inspection report, NRC investigation into

the capture efficiency of the Unit 1 building foundation drain system indicated

approximately seven times more hydrogen-3 (tritium) radioactivity was captured by the

drain system than was accounted for by Unit 1 SFP leak calculations. Evidence from the

hydrogeologic site investigation confirms the source of this additional tritium radioactivity

is from the Unit 2 SFP. Based on this understanding, additional NRC analysis used

historical Unit 1 building foundation drain system hydrogen-3 (tritium) sample results to

attempt to assess the age and variation of the Unit 2 SFP leak since 1999.

b. Findings and Assessment

No findings of significance were identified.

A review of daily boron concentration measurements in the Unit 2 spent fuel pool since

the last refueling outage indicated a decrease of 7 parts per million (ppm) (normally

2,300 ppm) over a one year time period. This measurement provided a bounding water

loss value of 2.6 gallons per day (gpd), with a large uncertainty of +/- 7.2 gpd. This

uncertainty indicates that no definitive loss of spent fuel pool inventory could actually be

determined with any certainty.

The licensee has pursued consistent efforts to inspect the Unit 2 spent fuel pool stainless

steel liner for evidence of leaks. Approximately 40% of the liner was inspected by

underwater video camera. No leakage was determined on the surfaces examined. The

remainder of the pool liner surfaces is inaccessible to optical examination due to

limitations imposed by the proximity of the fuel racks and other obstructions. Beginning

in July 2007, Entergy lowered the water level in the Unit 2 fuel transfer canal, which is

immediately adjacent to the spent fuel pool, in order to examine those surfaces for

possible leaks. One pinhole leak was discovered and was subsequently repaired on

December 15, 2007. An expert review of the material condition of the leak

determined that it was due to an original welding construction flaw, and that there were

no indications of any active corrosion on the transfer canal surfaces.

Notwithstanding that all identified potential leak locations have been repaired, most of the

spent fuel pool surfaces remain unexamined, with the potential for unidentified leaks

remaining. Since the Unit 2 spent fuel pool was constructed without a leak collection

system, groundwater monitoring remains the only means for assessing leakage from the

Unit 2 spent fuel pool.

Enclosure

11

.5B Unit 1 SFP Leakage

a. Inspection Scope

A review of available licensee records was conducted to search for any possible

indications of the beginning or duration of the Unit 1 SFP leak. Records were also

reviewed to evaluate the licensees response to the initial discovery of Unit 1 SFP

leakage, and the adequacy of corrective actions to repair or mitigate the effects of the

identified leakage based on regulatory requirements and information known at the time.

b. Findings and Assessment

No findings of significance were identified.

A search for historical Unit 1 control room logs and for Unit 1 spent fuel pool inventory

makeup records was initiated, but no pre-1994 records were found. Without those

records, which are no longer required to be maintained, no data was available to indicate

past water inventory makeup trends. The water makeup records and control room log

entries represented the only potential data records to evaluate the onset of Unit 1 SFP

leakage, which remains indeterminate.

The initial licensees corrective action program identification and investigation of the

leaking Unit 1 SFP (SAO-132 Report 94-06), identified a net fuel pool leak rate

(subtracting evaporative losses) of 25 gallons per day, or 10 drops per second, attributed

to age-related degradation of the fuel pool epoxy coating, which resulted in pool water

penetrating through the fuel pool concrete walls and floors. The corrective actions

associated with Report 94-06, included a large scope of investigative activities aimed at

identifying potential leakage paths within the Unit 1 plant structures, including

groundwater collected in the external Unit 1 building foundation drain system (Figure 2).

Bounding dose calculations performed by the licensee in 1994, which assumed four

times the identified leak rate released to the Hudson River, indicated that the resulting

dose from such a liquid release would be <0.1% of the liquid effluent regulatory

specification and ALARA guidelines.

The NRC conducted three separate team inspections in 1994 (specified in Attachment 1)

to assess the licensees identification and resolution of the leaking Unit 1 spent fuel pool

condition and based on a comprehensive review concluded that the licensees

investigation was responsive to this concern and the potential impact on the public health

and environment. Further, that the licensees investigation incorporated all reasonable

probable pathways of release and had demonstrated no off-site dose impacts would be

attributable to pool leakage based on enhanced environmental surveillance.

Entergys investigative activities did not result in correcting the degraded condition of the

Unit 1 spent fuel pools or otherwise eliminate the identified leakage. Unit 1 licensing and

procedural requirements were reviewed and no corrective action program violations were

identified. NRC requires safety-related functions of plant components to be repaired or

corrected in accordance with 10 CFR 50, Appendix B, Criterion XVI. However, the leak

rate from the pool did not affect the safety-related function of the Unit 1 spent fuel pool

Enclosure

12

(associated with spent fuel cooling), and the off-site dose consequence of the leakage

was evaluated and determined to have no significant dose impact. Therefore, there was

no condition adverse to quality and no violation of NRC requirements identified.

This 1992 investigation was the earliest documentation confirming leakage of the Unit 1

SFP. Since 1992, the leakage rate remained constant until the Fall of 2005, when the

Unit 1 West SFP was flooded up to allow fuel inspection as part of the future dry cask

storage relocation of the spent fuel. After lowering the water level back down and

draining the surrounding pools in November 2005, the Unit 1 West SFP leak rate

increased to 70 gallons per day due to a higher water pressure forcing more water to

drain through the preexisting cracks to the surrounding now drained Unit 1 spent fuel

pools. Based on the tritium concentration measured in the Unit 1 West SFP and the

current leakage rate, a comparison of tritium leaking from the Unit 1 West SFP and the

total tritium collected by the Unit 1 building foundation drain systems could be compared.

Latest calculations indicates that there is approximately three times more tritium collected

than can be accounted for from Unit 1 West SFP leakage.2

Based on the hydrogeologic site investigation, it is now known that the source of the

additional tritium activity is due to migration of tritium contaminated water from the Unit 2

SFP, in the unsaturated zone southward towards Unit 1 and being drawn into the

groundwater cone of depression created by the Unit 1 building foundation drain system.

Recognizing that the Unit 1 West SFP leak condition was stable at about 25 gpd prior to

the Fall of 2005 with a stable radioactive source term, historical review of licensee data

was used to evaluate the change in the Unit 2 SFP leakage over time since

approximately 75% of the tritium collected in the Unit 1 foundation drainage system was

due to the Unit 2 SFP leak.

This evaluation was considered necessary to help investigate the results of a sample

taken in the Spring of 2000 from Monitoring Well-111 when Entergy was exploring the

possibility of purchasing Unit 2. No tritium was detected in the sample. The monitoring

well is located in the current Unit 2 SFP tritium plume. The sensitivity of the sample

method should have detected any tritium above 270 pCi/L. This fact would indicate that

the Unit 2 SFP tritium plume did not exist in the Spring of 2000, and that the SFP leak

may have begun more recently. Entergys site characterization report indicates the

sample was not a reliable groundwater sample as it was taken from the surface of the

well without any purging and was, therefore, not considered representative of the

groundwater at this location. In order to determine the efficacy of the Spring 2000

Monitoring Well-111 sample and the possibility of a more recent SFP leak, the Unit 1

building foundation drain collection data was accessed to provide an indication of excess

tritium infiltration (attributable to Unit 2 SFP leakage) around the time of the Spring 2000

Monitoring Well-111 sample compared to the present time.

If there was no tritium plume emanating from the Unit 2 SFP at that time, then there

should be a significant reduction (approximately 75%) in the tritium input to the Unit 1

building foundation drain system. Otherwise, Entergys site characterization model,

2

The March 16, 2006 Special Inspection Report indicated a higher unaccounted for tritium

balance due to a calibration issue with a flow rate monitor, a condition that has been corrected.

Enclosure

13

which suggests a long-term tritium leak, would be reasonable. The following table

summarizes data extracted by the NRC from licensee data. The two Unit 1 building

foundation groundwater drain systems consist of the north curtain drain (NCD) and the

sphere foundation drain (SFD). The combination of both of these two french drain type

systems represents the total tritium collected annually based on weekly sample

collections.

Unit 1 Drain Tritium Collection

Year SFD SFD flowrate NCD NCD flowrate Total Total flowrate Corrected3

uCi gpm uCi gpm uCi gpm uCi

1999 8.82E4 18 6.0E5 3 6.9E5 21 4.6E4

2005 2.67E4 24 5.8E4 3.6 8.5E4 28 5.6E4

2006 5.2E4 17 4.7E4 4 9.9E4 22 6.6E4

2007 2.6E4 11 2.7E4 2.8 5.3E4 14 5.3E4

As can be seen, in the final corrected column in the table above, there has been a

consistent amount of tritium collection in the Unit 1 drain system that predates the due

diligence sampling of Monitoring Well-111 in the Spring of 2000. This would indicate

that the Unit 2 SFP tritium plume was being captured by the Unit 1 drain system in 1999

as currently characterized, and that the Spring 2000 Monitoring Well-111 sample may not

be a valid sample. This confirms the designation as an invalid sample as stated in

Entergys hydrogeological final report.

Considering factors including the radiological and non-radiological contamination

condition at Unit 1, Entergy determined that any immediate remediation (such as

groundwater pump down) of the existing contaminated groundwater in the vicinity of the

Unit 2 spent fuel pool would be inappropriate at this time. Such remedial action could

adversely affect the current groundwater contamination condition, in particular, it would

create a situation in which contaminated water that is currently collected, monitored and

discharged from the Unit 1 drain systems in accordance with NRC regulatory

requirements, to spread elsewhere unnecessarily. Accordingly, the NRC agrees that, in

the absence of any over-riding public health and safety concern, pump and treat

remediation of the Unit 2 SFP could adversely affect the spread of the Unit 1

groundwater contamination plume and is not advisable.

.6 Hydrogeologic Investigations

a. Inspection Scope

NRC Region I Inspectors, and scientists from the U.S. Geological Survey (USGS) and

NRCs Office of Research made numerous visits to the IPEC site to observe site

features, test hole drilling and sampling, rock cores recovered from the test wells,

groundwater quality sampling, tracer and pump test procedures, and other site

3

In 2006, the SFD flowrate monitor was found to be significantly overestimating the flow rate by

50%; therefore assuming relatively constant annual groundwater flow, the total tritium results for

the prior years was reduced by 50% to provide a normalized comparison.

Enclosure

14

characterization and monitoring activities. During these site visits, the inspection team

interviewed Entergy staff and contractors, i.e., GZA GeoEnvironmental, Inc. (GZA)

geotechnical engineers, geologists, and hydrogeologists, and examined their methods,

analytical results and bases for conclusions regarding groundwater contamination

transport at Indian Point Energy Center.

b. Findings and Assessment

No findings of significance were identified.

The purpose of the hydrogeological investigation was to identify the on-site, and potential

off-site, pathways for the abnormal releases, and to define the conceptual site hydrologic

model controlling the subsurface transport of the released radionuclides.

Initially there were significant uncertainties in defining the tritium pathway (the first

detected abnormal release radionuclide). In discussions with GZA, it was apparent that

the tritium source(s) and pathway(s) were not fully defined. Questions were raised as to

the groundwater flow direction, which the IPEC FSAR Section 2.5 references indicated

was to the south. Based upon water-level data taken by GZA from a series of installed

test wells, the groundwater gradient was initially determined to be west to the Hudson

River in the vicinity of the Screen Wall Structure building (near Monitoring Well-67).

Upon close examination of the water-level data for the full complement of test wells, the

groundwater flow direction was confirmed to be the west and, therefore, the tritium plume

was determined to follow the gradient to the Hudson River. Tritium moves at the same

rate as the groundwater since it is part of the molecular water composition. Analysis of

monitored water levels, temperature and water quality demonstrated tidal effects from the

river affecting groundwater flow conditions along the river bank and upgradient to the

Discharge Canal.

The question of preferential flow pathways was raised due to the nature of the bedrock

underlying the IPEC site, the Inwood Marble, being a metamorphosed carbonate with

numerous fractures. These fractures, which can be observed on-site and in the

Verplanck Quarry as shown in Figure 3, were inspected for the possibility of solutioning

and connectivity. The rock cores collected during the drilling of the test wells were

examined for fractures, solutioning and fracture filling. In order to confirm the

Entergy/GZA determinations a range of possible conceptual site models were examined

to determine the influence of fracturing, solutioning and fracture filling on contaminant

transport. In order to fully investigate and independently analyze alternative conceptual

site models involving preferential groundwater flow pathways, NRC developed an

Interagency Agreement with the USGS - New York Water Science Center located in

Troy, New York.

The USGS conducted a detailed flow-log analysis for hydraulic characterization of

selected test wells. This analysis examined fracture geometries and hydraulic properties

in the bedrock using flow logs, as well as downhole caliper, optical- and acoustic-

televiewer, and fluid resistivity and temperature logs, collected in the test wells by

Geophysical Applications, Inc. under the direction of GZA. The USGS analysis

determined the distribution and character of fracture-flow zones. Hydraulically active

Enclosure

15

fractures were identified in these zones. Transmissivity and hydraulic heads in these

flow zones were estimated using the flow-log analysis method. As reported in USGS

Open File Report 2008-1123 "Flow-Log Analysis of Hydraulic Characterization of

Selected Test Wells at the Indian Point Energy Center (IPEC), Buchanan, New York"

(ADAMS Accession No. ML081120119), the flow-log analysis was corroborated with

pump test and tracer test results from GZAs site characterization and analyses.

Figure 4 shows the presence of intersecting (conjugate) fracture sets which provide

higher permeability zones and create directional flow properties (anisotropy). These

analyses were confirmed by pump test results, and later, tracer test results and

observations showing distinct fracture zones and variable permeability in the Inwood

Marble between the Unit 1 and 2 SFPs extending west to the Discharge Canal. No

solution features affecting radionuclide transport were observed or detected by the field

testing and USGS independent analysis. However, fracture connectivity was observed

and is a contributor to preferential flow and transport, particularly in partially-saturated

bedrock (i.e., above the water table) as demonstrated by the GZA tracer test results.

Certain site areas subject to extensive rock backfills, such as the excavated-blast

depressions in the transformer yard and along the river, which are porous-flow

dominated rather than fracture-flow dominated as indicated in the bedrock.

Early in the investigations, the Discharge Canal was thought to capture the tritium plume.

NRC staff questioned this assumption and encouraged its testing. GZA installed

Monitoring Well-37 west of the Canal and down gradient of the plume to test the

assumption. Sampling in Monitoring Well-37 confirmed that the tritium plume did

continue west under the canal toward the Hudson River; however, a significant amount

(perhaps up to 50%) of tritium was captured by the canal. Sampling in Monitoring Well-

37 also identified strontium-90 which extended the scope of the investigation.

As the conceptual site model (CSM) was developed using observed tritium and

strontium-90 monitored data from the numerous monitoring wells, the role of backfill

material around buildings and in excavated depressions (e.g., transformer yard and

along the river) was investigated by GZA. The role of storm drains, sump pumps and

curtain drains on the local hydrology was also investigated and analyzed. The

conceptual site model, as reported in the licensees Hydrogeological Site Investigation

Final Report (GZA report), recognized the affect of these features relative to the

observed tracer test results and contaminant plume behavior. The conceptual site model

incorporated both natural features (e.g., water-levels and flow directions) and human-

made features (e.g. building foundations, backfills, curtain drains, storm runoff drains and

manholes). The conceptual site model considered percolation to the unsaturated zone,

where the Unit 2 tritium source emanates, and flows to the water table. The strontium

source was determined to enter the water-table via the north curtain drain surrounding

the Unit 1 SFP, and also from the spray foundation sump. Both the tritium and strontium

plumes migrate through the connected fractured zones to the Hudson River. Cross-

sectional diagrams from the GZA report, shown in Figure 5, depict the flow and transport

pathways to the river, including the location of monitoring wells down gradient of the

radionuclide sources. Tracer test and radionuclide sampling data from these monitoring

wells support the conceptual site model assumptions.

Enclosure

16

A pump test using Recovery Well-1, with observations in the surrounding monitoring

wells, was performed to test the feasibility of a pump, monitor and discharge remediation

approach for the tritium plume, and to create a depressed water table (drawdown cone)

beneath Unit 2 SFP to capture and provide early detection of abnormal releases. The

operation of the Recovery Well-1 caused cesium-137, which had not been previously

detected in monitoring wells, to migrate to Monitoring Well-31 and Monitoring Well-32

(west of the Unit 1 and 2 SFPs). This test confirmed the presence of cesium-137 in the

fractured rock, and the connectivity of the fractures in the aforementioned fracture zones

between the Unit 2 and 1 SFPs. The migration of cesium-137 from Unit 1 to Unit 2

during the test confirmed that the pump test should be conducted at very low pumping

rates in the event that other radionuclides were present in the fractured rock and could

become mobilized. The fracture filling in the bedrock appears to adsorb the cesium

during ambient groundwater flow conditions.

Using insights from this pump test, GZA planned and conducted a tracer test adjacent to

Unit 2 SFP at the base of the construction pit where the original abnormal releases of

radionuclides were observed. A fluorescein dye tracer was introduced in a shallow

borehole above the water table. At the suggestion of NRC staff, the tracer sampling

continued for a significantly longer period of time than would be normal to fully detect and

analyze the transport pathways. The tracer results confirmed the aforementioned

conceptual site model pathways, and identified the role of the fractures in creating

preferential transport in the unsaturated zone, and the role of human-made features

relative to the observed tritium concentrations in the monitoring wells and Manhole 5

adjacent to Unit 2 SFP. The tracer sampling identified the contaminant pathway

direction, transport rate and attenuation for both the tritium and strontium plumes. Since

strontium-90 is adsorbed by the fracture filling materials (e.g., clays), the tracer moved at

a faster rate than the strontium plume. The residual cesium-137 appears to be relatively

immobile due to adsorption and the relatively slow groundwater velocity in the fracture

zones until increased by local flow perturbations such as groundwater pumping.

The extensive IPEC site characterization data as reported in the GZA report includes:

water levels; tidal effects; upward and downward flow components determined by flow

meters and by using the Waterloo packers (i.e. inflatable bladders to vertically isolate

fracture zones in a well); tritium and strontium concentrations; and pump and tracer test

results. This database provides valuable site-specific information to confirm the

conceptual site model (CSM) and dose calculations. This information also provides a

valuable two-year baseline for future long-term monitoring and re-evaluation of the

conceptual site model since seasonal groundwater flow dynamics, episodic recharge and

potential future releases may alter the assumptions in the CSM. This information is also

critical in determining the adequacy of the Entergys chosen remediation approach of

monitored natural attenuation for the tritium and strontium-90 plumes.

Monitored natural attenuation refers to the natural groundwater removal of residual

contaminants after the source of contamination has been secured, and the radioactive

decay acts to diminish the remaining residual radioactivity. Monitored natural attenuation

requires the elimination of the contaminant sources, detailed monitoring of the plumes

behavior through a confirmatory groundwater monitoring program and confirmation of the

conceptual site model, over time.

Enclosure

17

The licensee indicated that its long-term groundwater monitoring program will incorporate

monitored natural attenuation and have a detection capability for potential future

abnormal releases. Future NRC inspection will review the program details to focus on

achieving the goals of monitored natural attenuation and detecting future leaks. Specific

areas of review include determining which monitoring wells and what monitoring

frequencies are needed to demonstrate monitored natural attenuation, early radionuclide

leak detection and if the assumptions in the conceptual site model are valid. The long-

term groundwater monitoring program will be reviewed in a future NRC inspection to

ensure there is sufficient detection sensitivity and monitoring frequency to detect

changes in Unit 2 SFP leakage and the capability to detect leaks from other plant

components in the presence of existing groundwater contamination.

.7 Prior Indications of On-site Groundwater Tritium Contamination

a. Inspection Scope

The inspectors reviewed NRC required documentation affecting the identification of

potential and actual leaks of radioactivity outside of plant systems. The records were

reviewed to identify any historical survey data that the licensee possessed that would

indicate prior knowledge of any groundwater contamination issue that was not evaluated

as required. Title 10 CFR 50.75(g) requires records to be retained of past on-site

contamination spills. These records for the Indian Point site were reviewed for relevance

to the current site condition.

NRC IE Bulletin No. 80-10, AContamination of Nonradioactive System and Resulting

Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment@,

requires licensees to review their facility design and operations to identify nonradioactive

systems, that could become radioactive through interfaces with radioactive systems, to

include leaks and valve misalignments. The Bulletin required routine sampling and

analysis for the identified nonradioactive plant systems be established in order to identify

any contaminating events that could lead to unmonitored, uncontrolled releases to the

environment. In response to the Bulletin, the licensee developed lists of affected plant

systems and sampling periods. The inspectors also reviewed the licensees program for

the sampling of on-site storm drain systems for radioactive liquids and sediments. Also,

the inspectors reviewed the results of the due diligence sampling that was conducted in

early 2000 to identify outside plant areas with residual contamination. These results

were also screened for potential evidence of the preexisting groundwater contamination

condition.

b. Findings and Assessment

No findings of significance were identified.

The 10 CFR 50.75(g) decommissioning file included records of the prior Unit 2 SFP leak

from October 1, 1990 - June 9, 1992 as documented in corrective action report

(SAO-132, 92-08). These records indicate an effective cause determination and repair

of the condition. In addition all affected soil was excavated to a depth of eight feet and

the affected 35 cubic yards of soil was shipped off-site as radioactive waste, with no

Enclosure

18

residual soil contamination remaining. No evidence of groundwater contamination was

determined.

The Unit 1 SFP leak assessment corrective action report (SAO 132 94-06) and

hydrology report (Whitman 1994) were included in the decommissioning file, identifying

that most of the 25 gpd leak identified in 1992 would be intercepted by the Unit 1 building

foundation drain system. Any portion not intercepted by the drain system would likely

follow a shallow ground water flow pathway into a small stream discharging into the

Hudson River some 1700 feet southwest of Unit 1. Based on this information, the

licensee added environmental sampling stations to include the small stream south of

Indian Point as well as the Trap Rock Quarry (0.7 miles south of the plant) and an

unused groundwater well located off of Fifth Street in the town of Verplanck (1.3 miles

south of Indian Point). Environmental records of those sampling activities did not identify

any radioactivity in these samples that was plant-related.

Decommissioning file records of the Unit 2 SFP leak that was discovered in September

2005, includes records indicating a 2.6 gpd bounding leak rate was determined in a

November 21, 2005, boron-loss mass balance calculation. The current hydrogeologic

site investigation report completes the groundwater contamination records in the

10 CFR 50.75(g) decommissioning file.

Other miscellaneous documents were reviewed including some legacy records of low

level Cs-137 contamination found in, and associated with, Unit 1 storm drain lines (1-50

picocuries per gram) that predated commercial operation of Units 2 and 3. One area, 10

feet X 70 feet X 3 feet deep, identified in July 1990 on the north side of the Unit 3 fuel

storage building, was originally excavated storm drain material with residual levels of Cs-

137 (30 pCi/g) from Unit 1 operations; it was later paved over. This action included a

dose evaluation which indicated the area would result in much less than 1mrem/yr, which

would not require immediate cleanup in accordance with NRC site cleanup screening

level of 5 mrem/yr (NUREG/CR-5849).

Review of the due diligence site assessment conducted by Canberra Services on

February 14 - 22, 2000, identified various areas inside the restricted area with detectable

radioactivity. Several monitoring wells were installed and sampled. None of the

groundwater samples indicated any detectable plant-related radioactivity.

The IE Bulletin 80-10 program specific to on-site storm drain monitoring was fairly

extensive and provided detailed records since 1981. Review of the site wide storm drain

system data did not indicate a history of the current extent of elevated tritium

contamination. No historical marker was indicated in the storm drain sample data as to

when the tritium leaks may have been initiated.

Entergys IE Bulletin 80-10 program (IPEC Storm Drain Sampling Procedure, O-CY-

151-, Rev. 3) has been recently revised, consolidating two previously separate Unit-

specific programs with an updated map of the Unit 1, 2 and 3 storm drain systems, and

incorporating a consolidated sampling schedule, with appropriate frequencies, that

includes monthly sampling for sensitive storm drain outfalls. The improved program now

includes specific sample detection criteria requiring management involvement.

Enclosure

19

.8 Remediation and Long Term Monitoring Plans

a. Inspection Scope

In addition to providing the hydrogeologic site investigation final report to the NRC on

January 14, 2008, a subsequent Memorandum dated January 25, 2008 (ADAMS

Accession No. ML, 080290204) provided a synopsis of the Long Term Monitoring Plan

Bases. These documents were reviewed along with a number of Entergy and GZA

implementing procedures that provide a framework for addressing the current and future

groundwater contamination issue. Several meetings were also held between the NRC,

USGS and NYS DEC in January and February 2008 to discuss the adequacy of

Entergys plans and procedures.

b. Findings and Assessment

No findings of significance were identified.

Based on the installation of on-site monitoring wells, 36 out of 39 monitoring wells were

selected by Entergy for continued sampling at established frequencies. In addition, three

storm drain manholes were included in the sampling plan to monitor drainage from the

Unit 2 containment footer drain and the Unit 3 foundation and containment footer drains.

This initial sampling program consists of 378 annual samples to provide trending

information on the current contaminant plumes and provide for early detection of leakage

from other potential on-site sources to comply with the requirements of NEI 07-07,

Industry Ground Water Protection Initiative, for early detection and reporting of on-site

spills or inadvertent contamination of groundwater.

In addition, the on-site storm drain system for Units 1, 2 and 3 was visually inspected

using remote camera technology and large volumes of material (over 100 tons) were

removed to complete the inspection and make requisite repairs. During NRC inspection

of prior sampling evidence of groundwater contamination, in the March 16, 2006, special

inspection report, the storm drain sampling program was assessed as a segregated

program (between the operating Units) without proper program administration or data

trending review. Since those observations, Entergy has renovated the storm drain

systems, validated their connections and flow directions, and consolidated the program

into one site-wide program with individual sample detection criteria that initiates

management review. The current storm drain sampling program requires over 140

samples per year to detect potentially leaking plant systems as part of the IE Bulletin

80-10 requirement.

Currently, there is no periodic trending review of storm drain sampling data or use of this

program with the groundwater monitoring program. Since one of the main functions of

storm drains is to remove surface runoff water, many of the storm drains included in the

sampling program may not provide any indication of below ground leaking plant systems

or components. Since the site groundwater investigation has established the water table

and groundwater gradients, the licensee has initiated actions to evaluate the storm drain

systems for additional input to the long-term monitoring program.

Enclosure

20

The long term monitoring plan implementing procedures incorporate periodic sampling

from a groundwater monitoring network composed of 36 monitoring wells and numerous

other sampling locations. The current groundwater plumes are mapped spatially among

this network of monitoring wells to allow future monitoring of the plumes footprint. At the

conclusion of this inspection, the licensee was still in the process of defining and

establishing the parameters of its long-term monitoring program.

Early in the Unit 2 spent fuel pool leak investigation, Entergy reviewed detailed fuel pool

boron sampling data in an effort to determine net leakage losses from the fuel pool, since

boron loss would not be affected by pool evaporative losses and any reduction in boron

concentration would be due to pool leakage. Transfers of spent fuel and reactor water

during refueling outages set a new boron solution level and trends of boron concentration

losses after each refueling outage. This trending of boron data provided an initial Unit 2

SFP loss rate of approximately 2.6 gallons per day (approximately 1 drop per second)

calculated by Entergy in September 2005. Although there are some complicating factors

(e.g., variance in boron data measurement and any unidentified fuel pool cooling system

leaks), this approach does provide an early indication of net change in spent fuel pool

leakage.

Entergy plans on removing the spent fuel and draining the Unit 1 spent fuel pools by the

end of 2008. Some water may remain in the bottom of the pool to reduce the possibility

of airborne contamination and provide shielding of remaining sludge. Sludge removal is

expected to be completed in early 2009. After completion of these activities, the source

of the Unit 1 plume will be eliminated allowing residual radioactivity removal through

continued purging from the Unit 1 building foundation drain system and through natural

attenuation processes. Relative to Unit 2, the licensee has taken action to repair all

identified liner leak imperfections, and has identified a program for monitored natural

attenuation on the presumption that leakage has been terminated, based on its current

assessment of groundwater tritium concentrations. However, neither the licensee

nor the NRC is conclusive at this time, since only 40% of the liner surface was accessible

for inspection; and it is too early to detect any significant decline in tritium concentrations

(with respect to the natural variability in groundwater flow). Notwithstanding, it is

expected that the licensees implementation of its long-term monitoring program will

establish sufficient data to permit a conclusive determination in the near term.

The current dose significance of the Unit 2 SFP tritium leak rate is 1000 times lower than

the current Unit 1 plume (approximately 0.000002 mrem/yr versus 0.002 mrem/year), and

therefore, additional actions beyond long-term groundwater monitoring of both

groundwater plumes by Entergy are not warranted and the current approach is

acceptable to the NRC.

Further definition of the long term monitoring plan and licensee commitment to this

groundwater surveillance program will be pursued through continuing inspection activities

in 2008. These future inspection activities will verify completion of Entergys planned

remediation activities, and to review plume attenuation results to confirm Entergys site

groundwater characterization conclusions.

Enclosure

21

.9 Regulatory Requirements

a. Inspection Scope

The following regulations were reviewed to identify any areas of noncompliance.

The NRC regulates the radioactive effluent releases from nuclear power plants through

guidelines based on instantaneous maximum concentration values specific for each

radionuclide as well as regulatory limits on potential doses to the public. The release

limits are based on 100 mrem total effective dose equivalent per year. In addition,

licensees are required to meet the ALARA design objective guidelines of 3 mrem to the

total body per reactor and 10 mrem to the maximum organ dose receptor per reactor

(10CFR50, Appendix I). There are also total site annual exposure limits to actual

members of the public from all pathways of 25 mrem to the whole body, 75 mrem to the

thyroid and 25 mrem to any other organ (40CFR190.10(a)).

Effluent releases are reported by each nuclear power plant licensee to the NRC on an

annual basis with calculated maximum doses to the public and comparison to the above

indicated NRC limits. In addition, to provide a verification of these calculated releases, a

radiological environmental monitoring program is conducted by the licensee providing off-

site environmental sample measurement results for biologically sensitive pathways of

exposure to man especially in locations directly downstream or downwind of the nuclear

power plant. Spills or leaks on the site property are required to be recorded to support

future decommissioning activities (10CFR50.75(g)).

Unless drinking water is provided from on-site groundwater wells, the environmental

monitoring program does not require on-site groundwater monitoring. This area of the

regulations is currently under review. The industry has adopted a Groundwater

Protection Initiative (Nuclear Energy Institute; NEI 07-07, August 2007) to initiate on-site

groundwater monitoring at all nuclear power plants, and the NRC is proposing additional

rulemaking and guidance (10 CFR 20.1406 and Regulatory Guide 4.21) to address the

potential for leaks into the groundwater and the need to monitor this potential effluent

pathway.

b. Findings and Assessment

No findings of significance were identified.

Instantaneous release rates are limited by procedures that establish gaseous and liquid

release radiation monitor system setpoints and automatic discharge valve closures.

Based on review of monitoring well sample results from October 2005 through

December 2007, groundwater effluent instantaneous release concentrations were

always a small fraction of the regulatory limits.

The annual and quarterly liquid effluent public doses were calculated annually for 2005

and quarterly and annually for 2006 based on a rain precipitation water infiltration

drainage model developed by Entergys hydrogeologists to derive groundwater flux

Enclosure

22

values to drive the contamination concentrations obtained from monitoring well sample

results. In 2005, when few samples were available, the maximum monitoring well

sample results were used in the calculations. For the quarterly 2006 groundwater

effluent calculations, when multiple sample results were available, the monitoring well

sample results were ranked (low to high) and the 75th percentile values were used to

derive a best estimate of the groundwater releases to the Hudson River. A half-tidal

surge of the Hudson River was used as a final dilution of these releases and dose

calculations were performed based on the Indian Point Energy Center Off-site Dose

Calculation Manual (ODCM) methodology. The ODCM incorporates exposure pathway

dose calculations based on Regulatory Guide 1.109. Doses were calculated based on

Hudson River specific bioaccumulation of contaminants in fish flesh and based on infant,

child, teen and adult fish consumption rates. Various organs concentrate various

radionuclides at differing rates, so doses are calculated for bone, liver, total body, thyroid,

kidney, lungs, and gastrointestinal tract, based on applicable dose factors for each

critical organ. The maximum age group and organ is reported.

Enclosure

23

For 2005 and 2006, the following doses were reported for both normal and groundwater

liquid effluents.

2005 Liquid Units 1 & 2 Unit 3 Limit Max % of

Effluents (mrem) (mrem) (mrem) Limit

Routine max 2.93E-4 TB4 3.29E-4 1.5 0.02

quarter 4.68E-4 O5 TB 5 0.009

3.85E-4

O

Routine 8.11E-4 TB 4.45E-4 3 0.098 TB6

annual 1.31E-3 O TB 10 0.11 O6

5.4E-4

O

Groundwater 2.12E-3 TB 3 0.07

annual 9.72E-3 O 10 0.1

2006 Liquid

Effluents

Routine max 7.04E-4 TB 6.8E-5 1.5 0.05

quarter 1.03E-3 O TB 5 0.02

7.6E-5 O

Routine 8.8E-4 TB 1.27E-4 3 0.09 TB6

annual 1.26E-3 O TB 10 0.085 O6

1.6E-4

O

Groundwater 1.78E-3 TB 3 0.06

annual 7.21E-3 O 10 0.07

These maximum hypothetical doses represent approximately 0.1% of the ALARA design

objectives for liquid effluents (3 mrem and 10 mrem per year per reactor) for Units 1 and

2, combined with the groundwater releases attributed to Units 1 and 2.

In conclusion, based on a review of applicable NRC radiation protection regulations, all

effluent and environmental survey and reporting requirements have been met, indicating

that the existing groundwater contamination conditions represent a small fraction of

regulatory limits and no violation of these requirements have been identified.

4

TB - Total Body exposure

5

O - Maximum Organ exposure

6

Represents total dose from Units 1&2 and groundwater

Enclosure

24

4OA6 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 May 7, 2008. 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

Figure 1

Long Term Monitoring Plan

Enclosure

Figure 2

Unit 1 Building Foundation Drain System

Enclosure

Figure 3

Observed bedding and conjugate fractures in Verplanck Quarry (from USGS)

Enclosure

Figure 4

Downhole Flow Meter and Geophysical Survey

Example from Monitoring Well Monitoring Well-58

Enclosure

Figure 5

Unit 2 Spent Fuel Pool Tritium Plume Cross Section

Enclosure

ATTACHMENT 1

Indian Point Contaminated Groundwater Investigation Time Line

Date Event

Unit 1 Spent Fuel Pool Timeline

Unit 1 ceased commercial operations on October 31, 1974

1. April 1990: A nuclear plant operator observed higher than usual frequency of fuel pool

makeup than usual, initiated an investigation by Con Edison.

2. 1991: Con Edison began sampling the north curtain drain (NCD) and sphere foundation

drain sump (SFDS) for tritium and established separate liquid discharge paths.

3. May 1992: Completed calculations of unaccounted water loss - 25 gpd leakage.

4. May 1994: A task force organization was created with a Unit 1 SFP Project Manager position

reporting to the Plant General Manager. Individuals from Chemistry, Operations Maintenance,

Health Physics and Engineering were represented.

5. May-June 1994: NRC inspection (Drs. Bores and Jang) to investigate Unit 1 SFP leakage

(50-03/94-01) Boron concentration mass balance indicated 91 gpd leak rate to the SFDS and

1.5 gpd to the north curtain drain. Tritium concentration mass balance indicated 73 gpd to the

SFDS and 1.2 gpd to the NCD. Hydrogeologist study indicated that the groundwater movement

was about 10 ft/day and would flow towards the quarry, not the Hudson River. No violations were

identified.

6. July 1994: Whitman hydrogeology report investigation of Unit 1 SFP leak migration

concluded that most of the leakage would be captured by the Unit 1 building foundation drain

system and the rest would migrate to the South in the shallow zone and could be detected in the

creek bordering south of the plant and in the Trap Rock Quarry. These sample locations were

added to the REMP program.

7. August 1994: NRC inspection (Bores/Jang) to review licensees leak investigation (50-03/94-

02). Hydrogeologist completed study indicated that groundwater at the site flowed upward and

either west or south into the Hudson River. No violations were identified.

8. December 1994: NRC inspection (Bores, Jang, Erikson, Noggle) inspect compliance with

Bulletin 94-01 (fuel pool potential siphoning), leak investigation, and SAFSTOR approval (50-

3/94-80). Confirmation of tritium in the sphere foundation drain sump that drains groundwater

from the bottom of the Chemical Systems Building of Unit 1 in May 1994, provided evidence that

the Unit 1 SFP system was leaking beyond the plant structure and resulted in initiating a

corrective action SAO-132 report (94-06). 10CFR50.59 evaluations between March 9, 1992 and

December 1994 were reviewed and found to be complete and met requirements. In October

1994, boron concentration was increased in the SFP and fluoresce in dye tracer was added to

Attachment

the water storage pool to detect these sources in the NCD and SFDS. As of mid-December, no

increased boron or indications of tracer were detected in either of these Unit 1 drains. Tracer

did indicate that the SFDS had been discharging through a Unit 3 storm drain to the discharge

canal. Con Edison subsequently rerouted this discharge by hard pipe through the Unit 1 River

water system into the discharge canal. NCD was diverted to the Unit 1 sphere sump where this

discharge was pumped to the liquid radwaste processing system. The on-site stream was

added to REMP monitoring for tritium on a quarterly basis. No violations were identified.

9. January 2, 1996: SECY-96-01, Decommissioning Plan for SAFSTOR and amendment of

license for Unit 1 was approved.

10. June-August 1996: NRC inspection (Jang) to review followup actions: modification to north

curtain drain for recapture, new RMS detector installed in SFDS (50-3/96-04).

11. February-March 1998: NRC inspection (Jang) to review followup actions: effluent controls

and trending of SFP inventory (50-3/98-02).

12. May-June 1998: NRC inspection (Ragland) reviewed schedule for draining and cleanout of

pools (50-03/98-04). Con Edison removed all irradiated hardware from both the East and West

Unit 1 SFPs.

13. November-December 1998: NRC inspection (Ragland) verified that irradiated hardware had

been removed from the East pool and shipped off-site during May-August 1998, with the East

pool ready for desludging and draining. PCBs detected in water storage pool sludge. (50-03/98-

17).

14. December 1998-February 1999: NRC SAFSTOR inspection (Dimitriadis) (50-03/98-19).

Work in progress in draining and desludging various pools. While desludging the water storage

pool, PCBs were detected. Due to known leakage of this pool, the NCD was diverted into the

Unit 1 sphere annulus for waste processing.

15. April-June 1999: NRC inspection (50-03/99-03) NRR reviewed a Unit 1 safety evaluation for

modifications to the SFPs.

16. June-July 1999: NRC inspection (Ragland) reviewed monitoring of pool leakage, north

curtain drain water was being treated by mechanical and charcoal filtration. Water storage pool

cleanup in progress (50-03/99-06).

17. April 7, 2003: Unit 1 Remediation plan was approved to accomplish several objectives that

included pursuing sealing the Unit 1 East SFP, transferring the spent fuel into that pool, and

draining the leaking Unit 1 West SFP, thereby stopping the leak.

18. 2004: Insitu dry storage option was proposed by Unit 1 project team to stop the leak. Too

many uncertainties surfaced regarding potential airborne radioactivity and future floodup effects

on fuel integrity upon final spent fuel removal.

Attachment

19. September 19-November 17, 2005: The Unit 1 West SFP was flooded up for spent fuel

inspection for material condition evaluation. After drain down, Unit 1 SFP leak rate recalculated

to be 70 gpd.

20. January 16, 2006: Unit 1 drain system collects seven times more tritium than can be

attributed to the current 1 SFP leak rate.

21. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were

received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being

released in the groundwater to the Hudson River. Initial bounding calculations were revised,

indicating less than 0.1% of effluent release limits.

22. April 17, 2006: Due to the 3/21/06 discovery of strontium-90 in Monitoring Well-111, the

licensee initiated demineralization of the Unit 1 SFP 40 hrs per week in order to reduce leaking

source term. Final assessment of Unit 1 SFP leakage calculations indicated 70 gpd post-drain

down since November 2005.

23. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more

recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90

and nickel-63: 2.5E-3 mrem total body and 1.1E-2 mrem maximum organ (adult bone).

Strontium-90 analysis was added to REMP fish, Hudson River and sediment samples.

24. August 9, 2006: After completing a temporary system modification, Entergy began

continuous cleanup of the Unit 1 West SFP.

25. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and

hydrology results of a 3-day pump down test of Recovery Well-1.

26. April 2007: Revised calculation of tritium mass balance for Unit 1 SFP based on total

radioactivity per year (based on 65 gpd leak rate) versus total radioactivity collected in the Unit 1

building drains for 2006. The Unit 1 SFP releases accounted for only 30% of the tritium

collected in the Unit 1 drain system.

27. June 6-22, 2007: An expanded control zone fish split sampling exercise was conducted to

include a second control location in the Catskills to help evaluate background levels of

strontium-90 in fish.

Unit 2 Spent Fuel Pool Timeline

Operating license issued September 28, 1973

1. October 1, 1990: Unit 2 SFP stainless steel liner was perforated by a diver during re-rack

cutting operation, but was not identified at that time.

Attachment

2. May 7, 1992: Unit 2 SFP liner was discovered to be leaking (about 50 gpd), due to outside

visible boric acid deposits on the wall of the fuel service building. Condition report determined

cause and examined all other liner work areas for similar perforations. Entergy excavated 35

cubic yards of soil to a depth of 8 feet leaving no detectable contamination.

3. June 9, 1992: Under water epoxy temporary patch was installed, sealing the leak.

4. June 12, 1992: A steel box was welded over the liner perforation permanently sealing the

leak completing corrective actions for this fuel pool leak event.

5. September 1, 2005: Initial discovery of the Unit 2 spent fuel pool leak. Contamination was

first detected on a swipe sample of the exposed crack in the SFP south wall excavation area at

approximately 65-foot elevation. The NRC resident inspector was informed.

6. September 12-15, 2005: NRC initial radiological scoping inspection and dose assessment,

0.00002 mrem/year based on 2 L/day leak rate.

7. September 20, 2005: NRC Special Inspection Charter was issued, followed by a press

release announcing this action.

8. October 5, 2005: Tritium was discovered in the Unit 2 transformer yard Monitoring Well-111.

This was the first location removed from the Unit 2 SFP indicating a groundwater contamination

concern.

9. October 27, 2005: Unit 2 SFP liner inspection begins with underwater camera inspection to

identify any leaks. Visual indications were followed by vacuum box testing.

10. October 31, 2005: NRC Executive Director for Operations issued Reactor Oversight

Process deviation memorandum to provide additional NRC resources and continuing NRC

inspection of the groundwater contamination investigation through 2006.

11. November 3, 2005: Licensee submitted a non-required 30-day report to the NRC, based on

tritium results for Monitoring Well-111 (0.0002 uCi/ml) that were above the radiological

environmental monitoring program (REMP) reporting criteria for non-drinking water samples

(0.00003 uCi/ml). However, Monitoring Well-111 is an on-site well not representative of an off-

site environmental sample therefore, no NRC report was required.

12. November 7, 2005: Drilling of the first new monitoring well was initiated (Monitoring

Well-30).

13. January 13, 2006: A permanent leak collection box was installed encompassing the Unit 2

SFP crack.

14. January 31, 2006: A NRC Special Inspection team met on-site to review the Phase 1

monitoring well hydrology results.

Attachment

15. February 8-10, 2006: A NRC Special Inspection team was on-site to evaluate the licensees

compliance with IE Bulletin 80-10 (radiological monitoring of on-site non-contaminated systems),

10 CFR 50.75(g) (on-site spill documentation for future decommissioning), and chemistry

counting quality control requirements. Hudson River waterfront well sample splits were taken for

NRC, NYS and IPEC.

16. February 27, 2006: Monitoring Well-37 initial sample result = 30,000 pCi/L, provided the

first indication of a tritium groundwater release directly to the Hudson River.

17. February 28, 2006: Licensee provided a revised dose calculation of 0.000015 mrem/yr to

the maximally exposed member of the public based on a general site area hydrology water

transport and multiple contamination area drainage model. The NRC conducted the SIT exit

meeting.

18. March 16, 2006: NRC Special Inspection Report No. 05000247/2005001 was issued

describing NRC=s initial response and evaluation of the Indian Point groundwater contamination

issue.

19. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were

received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being

released directly to the Hudson River. Initial bounding calculations were revised, indicating less

than 0.1% of effluent release limits.

20. April 1, 2006: Due to the 2/21/06 discovery of strontium-90 in Monitoring Well-111, the

licensee initiated continuous demineralization of the Unit 1 SFP in order to reduce the leaking

source term.

21. April 10, 2006: Entergy groundwater monitoring and commitment letter sent to NRC

Region I.

22. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more

recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90

and nickel-63: 0.0025 mrem total body and 0.011 mrem maximum organ (adult bone).

23. June 12-16, 2006: NRC groundwater contamination hydrology inspection team was on-site.

U.S. Geological Survey participation was added to the NRC inspection effort.

24. November 7, 2006: NRC split sample results identify licensee strontium-90 results from

8/1 - 9/18/2006 were low and caused licensee resampling and licensee investigation.

25. October 30- November 1, 2006: Entergy conducted a 3-day groundwater draw-down pump

test from Recovery Well - 1 (adjacent to Unit 2 SFP).

26. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and

hydrology results of a 3-day pump down test of RW-1.

Attachment

27. February 8, 2007: Fluorescein dye tracer test injected near the base of Unit 2 SFP. Test

samples were collected through August 2007.

28. March 21, 2007: NRC inspection team reviewed preliminary tracer test results.

29. May 9-10, 2007: NRC conducted an on-site inspection team review of tracer test results

and the evaluation of groundwater transport.

30. June 6-22, 2007: An expanded control zone fish split sampling exercise was conducted to

include a second control location in the Catskills to help evaluate background levels of

strontium-90 in fish.

31. June 2007: The Unit 2 SFP transfer canal was drained below the pinhole leak, which

arrested this leak pathway.

32. July-August 2007: An independent fracture flow analysis using down hole geophysical and

flow logs was conducted by the USGS to compare groundwater flow results based on fracture

flow with the licensee=s groundwater flow rate calculations derived from packer testing data (slug

tests) and based on a general porous media groundwater flow model.

33. August 31, 2007: The last monitoring well was installed and became operational

(Monitoring Well-67).

34. November 7-9, 2007: NRC inspection team was on-site to compare and review the final site

conceptual groundwater model based on all previously derived site data and USGS analyses.

35. December 15, 2007: The pinhole leak in the Unit 2 SFP transfer canal was repaired.

36. January 14, 2008: NRC received Entergys final site hydrogeological investigation report.

37. January 29, 2008: NRC received Entergys Synopsis of Long Term Monitoring Plan Bases.

38. February 4, 2008: NRC inspection team conducted a critique of the Long Term Monitoring

Plan and associated implementing procedures.

39. February 21, 2008: NRC held a meeting with Entergy and GZA to discuss further

development and refinement of the Long Term Monitoring Plan.

40. May 7, 2008: NRC conducted an exit meeting of inspection report 50-003/2007010 & 50-

247/2007010.

Attachment

ATTACHMENT 2

Site Groundwater Contaminant Concentrations

Attachment

Indian Point Monitoring Well Groundwater Contamination

Results as of 12/31/2007 in units of pCi/L

H-3 Sr-90 Ni-63 Cs-137

Southern Boundary Wells

MW-40 ND ND ND ND

MW-51 ND ND ND ND

Northern Boundary Wells

MW-52 ND ND ND ND

MW60 ND ND ND ND

Eastern Boundary Well

MW-65 ND ND ND ND

Riverfront Wells

MW-60 ND ND ND ND

MW-66 9000 11 ND ND

MW-67 5000 27 ND ND

MW-62 780 2 ND ND

MW-63 ND ND ND ND

Unit 2 SFP Wells

MW-30 130000 ND ND 3000*

MW-31 36000 ND ND 200*

MW-32 14000 ND ND ND

MW-33 23000 ND ND ND

MW-34 22000 ND ND ND

MW-35 6000 ND ND ND

MW-111 100000 1 ND ND

MW-36 12000 2.5 ND ND

MW-37 6000 28 56 ND

MW-55 10000 32 ND ND

MW-50 4000 47 ND ND

MW-49 7000 26 ND ND

Unit 1 SFP Wells

MW-42 2500 47 200 37000

MW-53 7400 28 ND ND

MW-55 10000 32 ND ND

MW-50 4000 47 ND ND

MW-49 7000 26 ND ND

MW-47 3500 4 ND ND

MW-56 1500 2 ND ND

Attachment

MW-57 4000 38 ND ND

MW-54 2000 20 ND ND

MW-58 900 ND ND ND

MW-59 800

Unit 3 Wells

MW-39 ND 5 ND ND

MW-41 ND 6 ND ND

MW-45 2200 ND ND ND

MW-44 ND ND ND ND

MW-43 ND ND ND ND

MW-46 1700 ND ND ND

U3-T1 530 ND ND ND

U3-T2 1200 ND ND ND

Off-site Locations

LaFarge No. 1 ND ND ND ND

LaFarge No. 2 ND ND ND ND

LaFarge No. 3 ND ND ND ND

Trap Rock Quarry ND ND ND ND

5th Street Well ND ND ND ND

Camp Field Reservoir ND ND ND ND

New Croton Reservoir ND ND ND ND

ND indicates nothing detectable

above background

• Single positive result was obtained immediately after a 3-day pump down test indicating

hydraulic connectivity between Monitoring Well-42 and Monitoring Well-30 and 31.

These radionuclide concentrations reflect end of 2007 results. Due to annual cyclic groundwater

flow variability, no definite trend of the radionuclide concentrations could be conclusively

determined at the present time. Additional sample data over time will clarify whether the Unit 1

and Unit 2 groundwater plumes are shrinking in size or concentration.

Attachment

ATTACHMENT 3

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Barvenik Principal Engineer, GZA Geo Environmental, Inc.

J. Comiotes Director, Nuclear Safety Assurance

P. Conroy Manager, Licensing

D. Croulet Licensing Engineer

P. Donahue Chemistry Specialist

J. Pollock Site Vice President

C. English Unit 1 Project Engineer

G. Hinrichs Project Engineer

D. Loope Radiation Protection Superintendent

T. Jones Licensing Engineer

R. LaVera Radiological Engineer

D. Mayer Director, Special Projects

J. Peters Plant Chemist

S. Sandike Chemistry ODCM Specialist

New York State Inspection Observers

T. Rice Environmental Radiation Specialist, New York State, Department of

Environmental Conservations (NYS DEC)

L. Rosenmann Engineering Geologist, NYS DEC

A. Czuhanich Engineering Geologist, NYS DEC

LIST OF INSPECTIONS PERFORMED

7112203 Radiological Environmental Monitoring Program and Radioactive Material

Control

LIST OF DOCUMENTS REVIEWED

Entergy Letter, NL-08-009 to USNRC, Results of Ground Water Contamination Investigation,

January 11, 2008

GZA Final Report Hydrogeologic Site Investigation Indian Point Energy Center, January 7, 2008

GZA Memorandum to Entergy, Synopsis of Long Term Monitoring Plan Bases, January 25,

2008

Consolidated Edison Calculation No. CGX-00006-00, ASeismic Qualification Structural

Evaluation of the Unit 2 Fuel Pool Wall Considering Deteriorated Condition of Concrete Due to

Pool Leak@

Attachment

United Engineers and Constructors Technical Report No. 8281,@Evaluation of Spent Fuel Pool

Walls - Indian Point 2 Nuclear Power Plant@

ABS Consulting Report 1487203-R-001, AStudy of Potential Concrete Reinforcement Corrosion

on the Structural integrity of the Spent Fuel Pit@, September 2005

Chazen, ANorthern Westchester County groundwater conditions summary, data gaps and

program recommendations,@ Contract C-PL-02-71, Dutchess County Office, the Chazen

Companies, Poughkeepsie, NY, April 2003

Clark, J.F., P. Schosser, M. Stute, and H.J. Simpson, ASF6 - 3He tracer release experiment: A

new method of determining longitudinal dispersion coefficients in large rivers,@ Environmental

Science and Technology, vol 30, pp 1527-1532, 1996

Annual Radiological Environmental Operating Reports, 2005 and 2006

Radioactive Effluent Release Reports, 2005 and 2006

Pre-Operational Environmental Survey of Radioactivity in the vicinity of Indian Point Power Plant,

1958 and 1959

SECY-96-001, Order to Authorize Decommissioning and Amendment to License No. DPR-5 for

Indian Point Unit No. 1, January 2, 1996

Indian Point Nuclear Generating Unit No. 1, License Amendment No. 42 and Technical

Specifications

de Vries, P, and L.A. Weiss, ASalt-front movement in the Hudson River Estuary, New York -

simulations by one-dimensional flow and solute-transport models,@ U.S. Geological Survey,

Water Resources Investigations Report 99-4024, 2001

Freeze and Cherry, Groundwater, 1979

GWPO, AGroundwater Program Office annual report for fiscal year 1994, ORNL/GWPO-013

NCRP, AScreening Models for Releases of Radionuclides to Atmosphere, Surface Water and

Ground,@ National Council on Radiation Protection and Measurements, Report No. 123, 1996

Whitman, AAssessment of groundwater migration pathways from Unit 1 spent fuel pools at

Indian Point Nuclear Power Plant,@ the Whitman Companies Inc, Project 940510, July 1994

ABS Consulting Report 1394669-R-004, Rev. C, AAssessment of Leakage from Unit 1 West

Fuel Pool during Fuel Cleaning Activities@

ABS Consulting Report 1186959-R-007, April 2004,Indian Point Unit 1 East Spent Fuel Pool

and Rack Fitness for Service Inspection Report

ENN-DC-114, Rev. 2, AUnit 1 Remediation - Phase 1 Project Plan

USGS Open File Report 01-385, ACharacterization of Fractures and Flow Zones in a

Contaminated Shale of the Watervliet Arsenal, Albany County, NY@

Attachment

Procedures

EN-LI-102, ACorrective Action Process@, Rev. 3

EN-LI-118, ARoot Cause Analysis Process@, Rev. 3

EN-LI-119, AApparent Cause Evaluation (ACE) Process@, Rev. 3

HP-SQ-3.013, Rev. 12, ARoutine Surveys Outside the Normal RCA@

2-CY-2625, Rev. 9, AGeneral Plant Systems Specifications and Frequencies@

3-CY-2325, Rev. 6, ARadioactive Sampling Schedule@

IPEC IE Bulletin 30-10 Program

O-CY-1510, Rev. 3, IPEC Storm Drain Sampling

O-CY-2740, Rev. 0, Liquid Radiological Effluents

O-CY-1420, Rev. 1, Radiological Quality Assurance Program

O-RP-NEM-101, Rev. 0, Nuclear Environmental Monitoring Sampling and Analysis Schedule

O-RP-NEM-100, Rev. 0, Notification, Investigation and Reporting of Abnormal Activity in

Environmental Samples

IP-SMM-CY-110, Rev. 0, Radiological Groundwater Monitoring Program

GZA-IP-101, Rev. 0, Radiological Groundwater Monitoring Program Quality Assurance and

Procedures IPEC

IPEC Off-site Dose Calculation Manual

Attachment

Condition Reports

IP2-2005-03885

IP2-2005-03557

IP2-2005-04151

IP2-2005-03986

IP2-2005-04152

IP2-2005-M-11

IP2-2005-04789

IP2-2005-04799

IP2-2005-04957

IP2-2005-04977

IP2-2005-05145

IP2-2005-05160

IP2-2005-05194

IP2-2006-00137

IP2-2006-00488

Drawings

9321-F-1196-7, Fuel Storage Building Concrete Details No. 1

9321-F-1197-8, Fuel Storage Building Concrete Details No. 2

9321-F-1198-8, Fuel Storage Building Concrete Details No. 3

9321-F-1199-7, Fuel Storage Building Concrete Details No. 4

9321-F-1200-5, Fuel Storage Building Concrete Details No. 5

9321-F-1388-15, Fuel Storage Building Floor Plans, Section & Roof

9321-F-1389-11, Fuel Storage Building - Building Elevations & Section

9321-F-1390-05, Fuel Storage Building - Building Details & Door Schedule

9321-F-2514-16, Fuel Storage General Arrangement Plans & Elevations (U2)

9321-F-2576-24, Fuel Storage Building Auxiliary Coolant System Plans

9321-F-2577-24, Fuel Storage Building Auxiliary Coolant System Sections

9321-F-2715-5, Containment Building Piping & Penetrations - Details of Fuel Transfer Tube

9321-F-2762-15, Fuel Storage Building Piping Supports

Miscellaneous

ENN-LI-101 Att. 9.1, 50.59 Screen Control Form Activity, ID No. DCP-03-2-128

IP2 FSAR, Section 1.2.1.2, AGeology and Hydrology@ Rev. 19

IPEC Preliminary Cause Analysis, FSB Concrete Wall/Tritium in the Groundwater, February 10,

2006

NRC Groundwater Sample Result Documentation

ML060720148 ML061880387 ML062720227 ML070110577

ML070110602 ML070110559 ML070110548 ML070110561

ML070940618 ML070940504 ML070940574 ML070940515

ML070940546 ML070940534 ML071900442 ML071900462

ML071900438 ML071900445 ML071900447 ML071900458

ML072840255 ML071900448 ML071900456 ML072840312

ML072840323 ML072840334 ML072840357 ML072840292

ML072840278 ML080080499 ML073180148 ML073180167

ML073620089

Attachment

LIST OF ACRONYMS

CFR Code of Federal Regulations

CR condition report

CSM conceptual site model

DEC State of New York Department of Environmental Conservation

EDO Executive Director for Operations

EPA Environmental Protection Agency

ESSAP Environmental Site Survey and Assessment Program

FSAR final safety analysis report

FSB Fuel Storage Building

GPD gallons per day

GPM gallons per minute

IN Information Notice

IP Inspection Procedure

IP2 Indian Point 2

IPEC Indian Point Energy Center

IR Inspection Report

ISFSI independent spent fuel storage installation

MDC minimum detectable concentration

MSL mean sea level

MW monitoring well

NCD north curtain drain

NYS DEC State of New York Department of Environmental Conservation

NYSEMO State of New York Emergency Management Organization

NYSPSC State of New York Public Services Commission

ORISE Oak Ridge Institute for Science and Education

PCB polychlorinated biphenyls

pCi/L pico-Curies per Liter

REMP Radiological Environmental Monitoring Program

SFD sphere foundation drain

SFP spent fuel pool

USGS United States Geological Survey

Note: Explanation of the terms groundwater, ground-water and ground water -- Hydrologists often

use the term Aground-water@ in adjective form and Aground water@ in noun form. This report has

not followed that convention, and instead typically uses Agroundwater@ universally. However, all

three forms of the word may be used herein.

Attachment