ML12089A605

Entergy Prefiled Hearing Exhibit ENT000343 - Indian Point Nuclear Generating Units 1, 2 & 3 - NRC Inspection Reports Nos. 05000003/2009008; 05000247/2009008 and 05000286/2009008

ML12089A605
Person / Time
Site:	Indian Point
Issue date:	10/19/2009
From:	Darrell Roberts Division of Reactor Safety I
To:	Joseph E Pollock Entergy Nuclear Operations, Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML12089A599	List: ML12089A600 ML12089A601 ML12089A602 ML12089A604 ML12089A605 ML12089A608 ML12089A609
References
RAS 22132, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR IR-09-008
Download: ML12089A605 (17)

See also: IR 05000003/2009008

Text

ENT000343

Submitted: March 29, 2012

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

Mr. Joseph Pollock

Site Vice President

Entergy Nuclear Operations, Inc.

Indian Point Energy Center

450 Broadway, GSB

P.O. Box 249

Buchanan, NY 10511-0249

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

October 19, 2009

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNITS 1, 2 & 3 - NRC INSPECTION

REPORT NOS. 05000003/2009008; 05000247/2009008; AND

05000286/2009008

Dear Mr. Pollock:

On September 4, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at Indian Point Nuclear Generating Units 1, 2, & 3. The enclosed report documents

the inspection results, which were discussed on August 19 and September 4, 2009, with Mr. Don

Mayer and other members of your staff.

The purpose of this inspection was to assess the establishment, implementation, and

maintenance of your Long-Term Groundwater Monitoring Program; review the circumstances

surrounding a previously identified occurrence involving the detection of tritated water in a Unit 3

storm drain system; review the performance of the site's Radiation Monitoring System; and

inspect and assess your performance relative to radiological effluents monitoring and control.

The inspection involved an examination of activities conducted under Entergy's license as

related to safety and compliance with the Commission's rules and regulations and with the

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

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

personnel, and independent assessment activities.

Based on the results of this inspection, no findings of significance were identified. Further, the

inspectors determined that Entergy's Long-Term Groundwater Monitoring Program for the .lndian

Point Energy Center was effectively implemented and maintained in a manner that provided

continued radiological monitoring of the groundwater conditions to confirm conformance with

NRC regulatory requirements relative to the maintenance of public health and safety, and

protection of the environment.

Since 2005, as approved by NRC's Executive Director of Operations, Region I conducted

frequent and focused reviews of your groundwater investigation activities and long-term

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

a result, we have developed confidence in your commitment and ability to continue effective

monitoring and assessment of the on-site conditions to assure the maintenance of

J. Pollock

2

public health and safety, protection of the environment, and conformance with NRC regulatory

requirements. Our inspectors confirmed that the objectives specified in our deviation

memorandum dated December 16,2008 (ML083590057) have been satisfied. However, we will

continue to monitor your performance in this area, and will re-assess the need for continued

heightened inspection oversight during our end-of-cycle review of your CY 2009 perfonmance.

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

enclosure will be available electronically for public inspection in the NRC Public Document Room

or from the Publicly Available Records (PARS) component of the NRC's document system

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

rm/adams.html (the Public Electronic Reading Room).

J);W~

Darrell J. Roberts, Director

Division of Reactor Safety

Docket Nos: 50-003, 50-247, 50-286

License Nos: DPR-5, DPR-26, DPR-64

Enclosure:

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

05000286/2009008

w/Attachment: Supplemental Information

cc w/encj: Distribution via ListServ

J. Pollock

2

public health and safety, protection of the environment, and conformance with NRC regulatory

requirements. Our inspectors confirmed that the objectives specified in our deviation

memorandum dated December 16, 2008 (ML083590057) have been satisfied. However, we will

continue to monitor your performance in this area, and will re-assess the need for continued

heightened inspection oversight during our end-of-cycle review of your CY 2009 performance.

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

enclosure will be available electronically for public inspection in. the NRC Public Document Room

or from the Publicly Available Records (PARS) component of the NRC's document system

(ADAMS). ADAMS is accessible from the NRC Web site at hllp:llwww.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

IRA by Peter R. Wilson forI

Darrell J. Roberts, Director

Division of Reactor Safety

Docket Nos: 50-003, 50-247, 50-286

License Nos: DPR-5, DPR-26, DPR-64

Enclosure:

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

05000286/2009008

w/Allachment: Supplemental Information

cc w/encl: Distribution via ListServ

Distribution w/encl: (via E-mail)

S. Collins, RA (R10RAMAIL RESOURCE)

M. Dapas, DRA (R10RAMAIL

RESOURCE)

D. Lew, DRP (R1 DRPMAIL RESOURCE)

J. Clifford, DRP (R1DRPMAIL

RESOURCE)

L. Trocine, Ri OEDO

RIDSNRRPMINDIANPOINTRESOURCE

B. Welling, DRP

B. Bickell, DRP

S. McCarver, DRP

G. Malone, DRP, Senior Resident Inspector

- Indian Point 2

D. Hochmuth, DRP

D. Bearde, DRP

Region I Docket Room (w/concurrences)

ROPreport Resource

D. Roberts, DRS

P. Wilson, DRS

J. White, DRS

SUNSI Review Complete:

JRW

(Reviewer's Inrtials)

OOCUMENT NAME: G:IORSIPlant Support Branch 2INoggleIIP2009008Rev1 .doc

After declaring this document ~An Official Agency Record w it will be released to the Public.

To receive a copy of this document, Indicate in the box: "e" = COpy without attachment/enclosure "E" = COpy with attachment/enclosure "N" = No CQP"y

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DATE

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10/14/09

10/19/09

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OFFICIAL RECORD COPY

Docket Nos.

License Nos.

Report Nos.

Licensee:

Facility:

Location:

Dates: .

Inspectors:

Approved by:

U.S. NUCLEAR REGULATORY COMMISSION

REGION I 50-003, 50-247, 50-286

DPR-3, DPR-26, DPR-64

05000003/2009008, 05000247/2009008, and 05000286/2009008

Entergy Nuclear Northeast

Indian Point Nuclear Generating Station Units 1, 2, & 3

295 Broadway

Buchanan, NY 10511-0308

Augusr18, 2009 - September 4, 2009

J. Noggle, Sr. Health Physicist, CHP, team leader

T. Nicholson, Sr. Technical Advisor for Radionuclide Transport

J. Williams, U.S. Geological Survey, Troy, New York

John R. White, Chief

Plant Support Branch 2

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000003/2009008, IR 05000247/2009008, IR 05000286/2009008; 08/18/2009 - 9/04/2009;

Indian Point Nuclear Generating Station Units 1, 2 & 3; Other Activities - associated with ROP

deviation memorandum, one PI&R sample, and radioactive effluents baseline inspection.

No findings of significance were identified. The report covers the period from August 18 through

September 4, 2009, and discusses inspection activities conducted by a region-based inspector,

and an inspection team comprised of representatives of Region I, NRC's Office of Research,

and the U. S. Geological Survey. The inspection provided bases for the NRC to determine that

Entergy had completed actions necessary to satisfy the objectives delineated in our deviation

memorandum, "Request for Renewal of Deviation to the Action Matrix to Provide Heightened

NRC Oversight of the Onsite Groundwater Monitoring at the Indian Point Energy Center,"

(ML083590057), dated December 16,2008. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor

Oversight Process," Revision 4, dated December 2006.

ii

Enclosure

Report Details

2.

RADIATION SAFETY

Cornerstone: Public Radiation Safety (PS)

2PS1 Gaseous and Liguid Effluents (71122.01 - 3 samples)

a.

Inspection Scope

1) The inspector reviewed the following documents to evaluate the effectiveness of the

licensee's radioactive gaseous and liquid effluent control programs relative to the

applicable regulatory requirements specified in the Technical Specifications and the

Offsite Dose Calculation Manual (TS/ODCM).

The 2007 and 2008 Radiological Annual Effluent Release Reports were

reviewed including independently assessing selected public dose calculations.

There were no anomalous results reported in these two reports. The report

included discussion of current groundwater conditions and the result of required

monitoring activities; and instances involving out-of-service radiation monitors or

effluent release flow rate monitors were listed in the reports and these were

evaluated during this inspection.

The current ODCM was reviewed, including technical justifications for any

changes made since the previous revision.

Applicable sections of the Updated Final Safety Analysis Report (UFSAR) were

reviewed to verify the adequacy of system descriptions for gaseous radioactive

waste and station ventilation systems.

The latest quality assurance audits of radioactive effluents and chemistry were

reviewed, including Entergy's program for identifying, controlling and assessing

potential contaminated spills and leakage.

There were no measurable effluent releases to the environment based on off-site

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

measurements identifying plant-related radioactive materials during the 2007 and

2008 report period.

2) The inspector observed the following plant equipment and work activities to evaluate the

effectiveness of the licensee's radioactive gaseous and liquid effluent control programs.

Walkdowns were performed of accessible gaseous and liquid release system

components to review any recent changes or modifications; and to confirm the

alignment, operation and material condition of the radioactive liquid and

gaseous effluent radiation monitoring systems (RMS) at Units 1, 2 and 3.

Observations were conducted of radioactive effluent related sampling and

associated laboratory measurement techniques.

Procedural controls and selected radioactive gaseous and liquid effluent release

permits were reviewed to verify that radiation monitor alarm setpoint values and

releases were in agreement with Technical Specification and ODCM

requirements.

Enclosure

2

Chemistry logs, relative to out-of-service radiation monitoring conditions, were

reviewed to confirm the performance of compensatory sampling activities.

Surveillance tests of gaseous filtration discharge systems were reviewed to

confirm operability and ventilation flow rates with respect to the assumed flow

rates used in gaseous effluent release calculations.

Entergy's surveillance program of non-radioactive system interfaces with

radioactive process systems was reviewed to confirm effective monitoring and

control of potential effluent discharge paths to the environment.

Radiation monitoring system and chemistry laboratory counting instrument

calibration and quality control records were reviewed with respect to ODCM

surveillance requirements to confirm the licensee's ability identify and report

detectable radionuclides in radioactive measurement results.

3) Radioactive effluent control related corrective action program activities for 2007 through

August 2009 were reviewed, including the results of audits and the resolution of issues

identified through the condition report system. A comprehensive review was conducted

of conditions and occurrences involving out-of-service radiation monitoring system

components. Section 40A2 pertains.

b.

Findings and Observations

No findings of significance were identified. The following table summarizes the dose

consequence of radiological effluent release in the period between 2007 and 2008.

Table of Effluent Release calculated dose and public dose limits for 2007 and 2008

Dose in

Air Dose

%of

Air Dose

%of

liquid

'10 of

Liquid

%of

mrem/yr

Whole

limit

Max Organ

Limit

Dose

limit

Dose

limit

Body

WB

MaxO

2007

Units 1&2

2.43E-3

0.016

2.43E-3

0.016

5.35E-4

0.018

1.3E-3

0.013

2008

Units 1&2

2.07E-3

0.014

2.67E-3

0.018

6.11E-4

0.020

1.47E-3

0.Q15

2007

Unit 3

3.BBE-3

0.026

3.BBE-3

0.026

3.2E-4

0.007

2.14E-4

0.002

2008

Unit 3

1.99E-3

0.013

1.99E-3

0.013

1.56E-4

0.005

2.B3E-4

0.003

2007

Groundwater

2.66E-4

0.009

9.94E-4

0.01

2008

Groundwater

2.86E-4

0.009

9.35E-4

0.009

4.

OTHER ACTIVITIES (OA)

40A2 Identification and Resolution of Problems

Cornerstone: Public Radiation Safety

.1

Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

a.

Inspection Scope (71122.01)

The inspector reviewed approximately one hundred corrective action condition reports,

initiated between january 2007 and August 2009, that were associated with the gaseous,

liquid, and groundwater radioactive effluents program. The review was performed to

Enclosure

3

verify that problems identified by these condition reports were properly characterized in

the licensee's event reporting system, causes were identified, and actions implemented

commensurate the safety significance of the matters.

b.

Findings and Observations

No findings of significance were identified .

. 2

Radioactive Effluent Radiation Monitor System (RMS) Maintenance (71152 - 1 sample)

a.

Inspection Scope

The inspectors conducted a review corrective action program condition reports

associated with out-of-service radiation monitoring system equipment that was identified

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

cognizance of Radiation Monitoring System (RMS) performance and activities were

interviewed, including the RMS system engineer and senior chemistry staff. "Radiation

Monitoring System, Second Quarter 2009, Condition Report Trend Review for Radiation .

Monitoring System Improvement: dated September 2, 2009, was also reviewed.

b.

Findings and Observations

No findings of Significance were identified.

A large number of condition reports associated with the radiation monitoring system were

initiated during the past two years. Most of the condition reports were associated with

interruption of service of the RMS display consoles in both the Unit 2 and Unit 3 control

rooms. While these temporary display outages affected operators' ability to poll

individual detector readout displays, they did not interfere with control room annunciator

actuation or actual detector operability.

The cause of the Unit 3 display console issues was determined to be related to

excessive temperature in the RMS electronics cabinets that affected certain control room

RMS display console components. Short-term corrective actions included installing

permanent air conditioning to effect improved cooling of the RMS electronics cabinets.

The cause of Unit 2 RMS display console service interruptions continues to be under

review. Notwithstanding, Entergy is evaluating replacing the RMS display console

equipment in both control rooms to support station-wide computer network access

improvements.

Less frequently occurring RMS equipment issues remain to be resolved, including

occurrences involving the R-56 detectors, which monitor the discharge of waste sewage

from Units 2 and 3. The location of these detectors was determined to be susceptible to

failure due to flooding, power spiking, and power outages. In such conditions, waste

sewage is diverted to an on-site holding tank in order to conduct sampling prior to off-site

release. Accordingly, there is no safety significance to these RMS system failures. The

inspector confirmed that the licensee has implemented appropriate remedial actions for

these occurrences, and has initiated actions to improve the operating environment and

detector function to reduce the out-of-service time.

Enclosure

4

Entergy has identified the Unit 2 RMS as an upgrade project in its Top Ten Action Plan

for 2009. System engineering activities have been initiated for this improvement activity.

The inspector determined that the majority of identified problems with the Unit 2 and Unit

3 radiation monitoring systems were not associated with radiation detector operability or

effluent release control functions. For those instances that resulted in out-of-service

conditions, the licensee implemented appropriate compensatory measures as required

by regulatory requirements. The inspector confirmed that Entergy is engaged in RMS

. improvement activities, and has initiated appropriate corrective actions.

40A5 Other Activities

.1

Assessment of Licensee Performance Relative to Meeting the Objectives of the

December 16.2008 Memorandum Reguesting Deviation from the Action Matrix

Background:

On September 1, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent

fuel pool wall had been discovered during excavation work inside the spent fuel pool

building. Low levels of radioactive contamination were found in the vicinity. Entergy's

initial investigation of the issue revealed that groundwater in the vicinity was

contaminated with tritium. On September 20, 2005, Region I initiated a special inspection

of this matter to examine the licensee's performance and determine if the contaminated

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

initiated actions to perform a comprehensive groundwater site characterization, identify

the sources, and effect mitigation and remediation of the condition.

The NRC special inspection report, issued in March 2006, assessed Entergy's

performance, achievements, and plans for more extensive site characterization, and

reported that the groundwater contamination did not, nor was likely to, adversely affect

public health and safety. In the report, and subsequent public meetings, NRC indicated

that a final conclusion would be reached after Entergy completed its groundwater

characterization initiative.

The NRC Region I continued inspection and monitoring of Entergy's activities in

accordance with successive approved deviation to the normal Reactor Oversight

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

(ML073480290) and 2009 (ML083590057). During this period, the NRC staff closely

monitored Entergy's groundwater characterization efforts, performed independent

inspections and testing, and independently evaluated radiological and hydrological

conditions affecting groundwater onsite. Additionally, the NRC independently verified

groundwater releases by conducting split monitoring well sampling with Entergy and the

State of New York.

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

site characterization investigation (ML080320600), and included its plan for remediation

and long-term monitoring of the on-site groundwater conditions. In its report, Entergy

described the source of groundwater contamination to be from the Unit 1 and Unit 2

spent fuel pools. The NRC documented its review of Entergy's report in inspection report

05000247 & 05000003/2007010 on May 13, 2008 (ML081340425). In a subsequent

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

Enclosure

5

confirmed that Entergy's conceptual site model of the site, which included both the

vadose zone and saturated zone processes and conditions, effectively characterized the

onsite groundwater plume behavior and radionuclide transport. Evaluation of

radionuclide concentrations and pathway analyses indicated that the groundwater

contamination did not adversely affect public health and safety. Detailed discussions

and analyses indicated that the licensee's plans for long-term monitoring of the site,

relative to monitoring natural attenuation of residual groundwater contamination, were

reasonable.

On November 3, 2008, Entergy completed Unit 1 spent fuel pool system drainage and

sludge removal activities, essentially terminating the source from that facility. Given the

change in conditions, Entergy initiated actions to establish a new groundwater

contaminant baseline in support of its long-term monitoring program.

a.

Inspection Scope

The most recently approved Memorandum of Deviation, i.e., "Request for Renewal of

Deviation to the Action Matrix to Provide Heightened NRC Oversight of the Onsite

Groundwater Monitoring at the Indian Point Energy Center," dated December 16, 2008

(ML083590057), identified the following objectives to be addressed in order to support

resumption of normal inspection activities in accordance with the Reactor Oversight

Process:

Entergy has completed sufficient data collection and assessment to establish a

new groundwater contaminant baseline, now that the Unit 1 source term has

been terminated.

Entergy has determined whether active leakage has been terminated or

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

appropriate monitoring and control measures, as necessary.

Entergy has established and implemented effluent control and environmental

monitoring procedures that provide reasonable assurance that the existing

groundwater conditions will continue to be effectively monitored and assessed,

that the procedures will detect new or changed conditions in a timely manner, and

that the procedures are sufficient to monitor natural attenuation of the Unit 1 and

Unit 2 groundwater contamination plumes.

The NRC team reviewed the licensee's performance and achievements relative to the

completion of these objectives.

b.

Findings and Observations

No findings of significance were identified.

The inspectors determined that Entergy completed the actions necessary to satisfy the

objectives delineated in the approved Memorandum of Deviation, dated December 16,

2008, (ML083590057). Notwithstanding, NRC will continue to monitor performance in

this area, and re-assess the need for continued heightened inspection oversight as part

of the CY 2009 end-of-cycle performance review of IPEC.

Enclosure

6

The following pertains:

Objective 1: Completion of sufficient data collection and assessment to establish

a new groundwater contaminant baseline, now that the Unit 1 source term has

been terminated.

As a result of the defueling, drainage, and de-sludging of the Unit 1 spent fuel pool

system in the Fall of 2008, the groundwater contamination source term from the Unit 1

facility was terminated. The inspectors confirmed that Entergy's subsequent data

collection and assessment activities, associated with the continual monitoring of the

residual groundwater contamination, would be sufficient and effective to establish a new

baseline relative to monitoring the residual groundwater condition and subsequent

assessment of dose consequence.

As expected, the first and second-quarter ground-water sample results in 2009, collected

from Monitoring Wells in the immediate vicinity of the Unit 1 spent fuel pool, indicated an

increase in Sr-90 groundwater concentrations. As determined from review of the

licensee's data and analysis, this increased concentration was the expected result of the

volume of water that was necessary to fill the spent fuel pool system to effect defueling.

Accordingly, Entergy's baseline data was predicated on the existing groundwater

conditions determined from its continuing analysis of collected monitoring data. Given

that the original source of the contamination associated with leakage from the Unit 1.

spent fuel pool system has been terminated, the residual groundwater contamination

involving Sr-90 is expected to naturally attenuate over time. The inspectors confirmed

that the current groundwater contaminant concentrations have not, nor are expected to,

affect public health and safety; and the public radiological dose consequence is

expected to continue to be a fraction of the NRC annual regulatory limit affecting liquid

effluents. The inspectors confirmed that continual monitoring of the migration and

attenuation of the Unit 1 associated groundwater contamination condition is being

performed in accordance with Entergy's Long-Term Ground-Water Monitoring Program

(LTGWMP).

The inspectors confirmed that Entergy has established, implemented and maintains a

long-term ground-water monitoring program that has sufficient in scope and

implementation requirements to effectively monitor and assess this condition.

Accordingly, the intent of this objective was considered satisfied.

Objective 2: Determination whether active leakage has been terminated or

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

monitoring and control measures have been implemented, as necessary.

Entergy has been actively engaged in analyzing Monitoring Well data associated with the

H-3 (tritium) groundwater contamination condition that resulted from previously identified

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

decreaSing trend in tritium concentration in the groundwater as a result of previous

efforts to examine the condition of the spent fuel pool and transfer canal liner, and effect

repair, as necessary. Notwithstanding, as previously reported, Entergy's examination of

the spent fuel pool liner was necessarily limited to only the accessible surfaces. That is,

only about 40 % of the total liner surfaces were accessible for examination; the

remaining surfaces were necessarily inaccessible due to the proximity of stored spent

fuel that prevented examination.

Enclosure

7

The inspectors reviewed the licensee's analysis derived from groundwater monitoring

data, and confirmed that there was no apparent indication of any significant large flux on-

going active leakage. The inspectors also reviewed the licensee's monitoring well

detection sensitivity data, which supports that active leakage, if occurring, would likely

not exceed 30 gallons per day (0.02 gpm). This sensitivity analysis was based on

comparison of the tritium concentration that is available in the spent fuel pool and the

actual tritium concentration derived from samples collected from relevant monitoring

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

licensee analysis and data from a long-term tracer test that indicated the potential for

slow, episodic tritium migration in the fractures of the vadose zone that affect the mobility

of contaminated groundwater from the immediate vicinity of the Unit 2 spent fuel pool to

the water table. The licensee's analysis is supported by the fact that fluorescine dye,

which was injected as part of the groundwater characterization study over two years ago,

is still detectable in certain nearby monitoring wells.

The inspectors noted that there were occasional spikes and general variability in some

monitoring well tritium concentration values that were not characteristic of the expected

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

continued to occasionally collect a small quantity of water from the leak collection box

that was installed on the Unit 2 spent fuel pool wall crack that was identified in 2005.

Accordingly, while there was no indication of any significant large flux active leakage,

there was insufficient basis to conclude that there is absolutely no persistent low flux

leakage from the Unit 2 spent fuel pool, at this time.

Notwithstanding, the inspectors determined that the licensee's sensitivity analysis of

groundwater monitoring data, relative to its ability to detect active leakage in excess of

about 30 gallons per day, was reasonably derived. Additionally, the inspectors

confirmed that the current groundwater conditions, even if there was persistent low flux

leakage from the Unit 2 spent fuel pool, has not, nor would be expected to, affect public

health and safety; and the public radiological dose consequence would be expected to

continue to be a fraction of the NRC annual regulatory limit affecting liquid effluents. The

inspectors confirmed that continual monitoring of the migration and attenuation of the

Unit 2 associated groundwater contamination condition was being performed in

accordance with Entergy's Long-Term Ground-Water Monitoring Program; and that the

program implemented appropriate monitoring and control measures for this condition.

The inspectors confirmed that Entergy has established, implemented and maintained a

long-term ground-water monitoring program that has sufficient scope and

implementation requirements to effectively monitor and assess the present condition.

Further, the licensee is considering monitOring in the vadose zone, in the vicinity of the

Unit 2 facility, to assist in the detection of large flux releases. Accordingly, the intent of

this objective was considered satisfied.

Objective 3: Establishment and implementation of effluent control and

environmental monitoring procedures that provide reasonable assurance that the

existing groundwater conditions will continue to be effectively monitored and

assessed, that the procedures will detect new or changed conditions in a timely

manner, and that the procedures are sufficient to monitor natural attenuation of

the Unit 1 and Unit2 groundwater contamination plumes.

Enclosure

8

The NRC has conducted several inspections (August 2007, October 2008, and August

2009) of the licensee's Long-Term Ground-Water Monitoring Program. The inspectors

confirmed that Entergy has established, implemented and maintained a Long-Term

Ground-Water Monitoring Program that was sufficient in scope and implementation

requirements to effectively monitor and assess the existing contaminated groundwater

conditions affecting the Indian Point Energy Center.

During this inspection, the inspectors examined the refurbishment of the LaFarge No.2

Monitoring Well (one of the principal off-site monitoring wells) and confirmed its

acceptability as a valid off-site monitoring location. Additionally, the inspectors verified

that the administrative controls, established in the Long-Term Groundwater Monitoring

Program, were sufficient t9 provide assurance of review and appropriate communication

of activities and changes that affect ground-water monitoring conditions; and that the

program included sufficient sampling requirements for storm drains and the Unit 1

foundation drain systems.

During this inspection, the inspectors reviewed a March 25, 2009 instance involving the

licensee's detection of tritiated water in the catch basin of a storm drain in the vicinity of

Unit 3, and in an adjacent shallow monitoring well. The licensee conducted an extensive

investigation but was unable to find an explanation for this one-time occurrence. The

inspectors confirmed that the occurrence had no radiological consequence onsite or

offsite; and no leakage was identified from any Unit 3 component containing tritiated

water. However, the nature of the occurrence indicated uncertainty in the ability of the

existing Unit 3 monitoring wells to detect potential leakage from that facility. While there

was no current on-going leakage affecting the groundwater at Unit 3, Entergy initiated

action to re-evaluate the Unit 3 groundwater monitoring configuration (both vertically and

horizontally) to determine its effectiveness in meeting the objectives and

recommendations of the NEI "Industry Groundwater Protection Initiative- Final Guidance

Document, August 2007" (ML072600292 and ML07261 0036); and amend the Long-

Term Groundwater Monitoring Program, as necessary.

Notwithstanding, the inspectors confirmed that Entergy has established, implemented

and maintained a Long-Term Ground-Water Monitoring Program that has sufficient

scope and implementation requirements to effectively monitor and assess the existing *

groundwater conditions affecting Indian Point Energy Center. Accordingly, the intent of

this objective was considered satisfied .

. 2

Groundwater Sampling

a.

Inspection Scope

During the licensee's groundwater investigation, over 1200 groundwater samples were

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

second quarter of 2009. The analytical results provide the basis for assessing the extent

of the groundwater plume and for performing calculations of offsite doses to members of

the public. In order to assess Entergy's performance in this area, the NRC implemented

an independent split sample collection program with the licensee beginning in

September 2005. The monitoring wells selected for independent verification included

the southem boundary wells and those wells bordering the Hudson River that were used

Enclosure

9

in support of effluent release and dose assessment calculations. Sample identity was

assured by chain-of-custody procedures that included sample collection observation by

the NRC or a representative of the NYS DEC. The NRC samples were analyzed by an

independent govemment laboratory to ensure validation of the licensee's groundwater

contamination results and off-site environmental sample radioactive measurements.

By the second quarter of 2009, over 300 split groundwater samples were obtained to

provide an independent check of Entergy's analytical results and to independently verify

if there was any detectable migration of groundwater contaminants offsite. These split

samples represent over 1,200 analyses, primarily for hydrogen-3 (tritium), strontium-90,

nickel-63, and gamma-emitting radionuclides that characterized the effluent releases.

Analyses for other radionuclides were performed, but none were detected.

b.

Findings and Assessment

No findings of significance were identified.

In general, Entergy's groundwater measurements of radioactivity were of good quality

and of sufficient sensitivity to assess radiological impact. The quality of Entergy's

measurements were confirmed by various split samples analyzed by the NRC. Of the

over 1200 results that were reviewed, there were only a few sample disagreements

based on the statistical comparison criteria specified in NRC Inspection Procedure

84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring." As

a result of these few discrepancies, Entergy took corrective action to establish,

implement, and maintain procedures to effect improved quality control and assurance of

sample analysis performed by its own laboratory and contract analytical laboratories.

During the past 3)1" years, the on-site groundwater transport pathway has been

effectively characterized by the licensee, and a significant quantity of on-site groundwater

monitoring data has been collected and analyzed by Entergy. A representative numbers

of split samples have confirmed the overall efficacy of the licensee's analytical capability.

As the site characterization was tested through pumping and tracer testing, the

contaminant plume uncertainty has been significantly reduced. Given this

accomplishment, and the NRC determination that Entergy has demonstrated an effective

groundwater sample quality control program, the NRC will discontinue any further split

sampling activities.

40A6 Meetings, including Exit

.1

Exit Meeting Summary

The inspectors presented the inspection results to Mr. D. Mayer and other licensee and

New York State representatives on August 19, 2009 and September 4, 2009. The

licensee acknowledged the findings presented. Based upon discussions with the

licensee, none of the information presented at the exit meeting and included in this report

was considered proprietary.

Enclosure

Licensee Personnel

J. Pollock

M. BaNenik

P. Conroy

D. Croulet

P. Donahue

C. English

G. Hinrichs

D. Loope

T. Jones

R. LaVera

D. Mayer

J. Michetti

J. Peters

D. Rusczyk

S. Sandike

J. Simpson

R. Walpole

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Site Vice President

Principal Engineer, GZA Geo EnVironmental, Inc.

Director, Nuclear Safety Assurance

Licensing Engineer

Chemistry Specialist

Unit 1 Project Engineer

Project Engineer

Radiation Protection Superintendent

Licensing Engineer

Radiological Engineer

Director, Special Projects

RMS System Engineer

Plant Chemist

Environmental Assessment, GZA

Chemistry ODCM Specialist

Environmental Assessment, GZA

Manager, Licensing

New York State Inspection ObseNers

L. Rosenmann

Engineering Geologist, New York State, Department of Environmental

ConseNations

INSPECTION PROCEDURES USED

71122.01

Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

LIST OF DOCUMENTS REVIEWED

Annual Radiological Effluent Release Reports - 2007 and 2008

Off-Site Dose Calculation Manual, Revision 2

O-CY-2730, Rev. 1, Airbome Radioactive Effluents

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

IP-SMM-CY-001, Rev. 7, Radioactive Effluents Control Program

IP-SMM-CY-110, Rev. 3, Radiological Groundwater Monitoring Program

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

3-CY-2325, Rev. 8, Radioactive Sampling Schedule

2-S0P-5.2.4, Rev. 33, Calculation and Recording of Radioactive Gaseous Releases

2-S0P-5.1.5, Rev. 34, Calculation and Recording of Radioactive Liquid Releases

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

Attachment

A-2

3-S0P-WDS-013, Rev. 25, Gaseous Waste Releases

EN-RP-113, Response to Contaminated Spills/Leaks

EN-CY-109, Sampling and Analysis of Groundwater Monitoring Wells

EN-CY-108, Monitoring of Non-Radioactive Systems

"Industry Groundwater Protection Initiative

- Final Guidance Document, August 2007" (ML072600292 and ML072610036)

Unit 2 Liquid Release Permit No. 090016

Unit 2 Gaseous Release Permit No. 090126

Unit 3 Liquid Release Permit No. 090081

Unit 3 Gaseous Release Permit No. 090067

Condition Reports:

CR-IP3-2007 -0803

CR-IP2-2009-2089

CR-IP3-2009-3356

CR-IP2-2009-2528

CR-IP2-2009-3307

CR-IP3-2007-3954

CR-IP2-200S-0270

CR-IP2-200S-0375

CR-IP3-200S-071S

CR-IP2-200S-0377

CR-IP2-2009-2266

CR-IP2-200S-1236

CR-IP3-2007 -3860

CR-IP3-200S-1112

CR* IP3*200S*2915

CR*IP3*200S*1042

CR*IP2*200S*2767

CR*IP2*200S*4136

CR*IP3*200S*2184

CR*IP2*200S*3662

CR*IP3*200S*2125

CR*IP2c200S*4130

CR*IP2*200S*4529

CR*IP2-200S-4191

CR-IP2-200S-456S

CR-IP3-2007-0151

CR-IP3-2007 -2S99

CR-IP3-2007 -2134

CR-IP3-2007 -3129

CR-IP2-2008-4981

CR-IP2-2008-5552

CR-IP2-2009-0609

CR-IP2-2009-0565

CR-IP2-2009-223S

CR-IP2-2009-1334

CR-IP2-2009-2352

CR-IP3-2009-3201

CR-IP3-2009-3254

CR-IP2-2009-3306

CR-IP3-2007-3925

CR-IP2-2007-5226

CR-IP2-200S-0549

CR-IP2-200S-0960

CR-IP2-200S-0144

CR-IP3-200S-0569

CR-IP3-200S-0852

CR-IP3-2008-0942

CR-IP2-2008-2468

CR-IP3-2008-1215

CR-IP2-2008-2581

CR-IP3-2008-1218

CR-IP3-2008-200 1

CR-IP2-2008-3342

CR-IP3-200S-1S99

CR-IP2-200S-4193

CR-IP2-200S-4254

CR-IP2-200S-4337

CR-IP3-200S-2279

CR-IP3-2008-0624

CR-IP3-2007-3367

CR-IP3-2007-3061

CR-IP3-2007 -3075

CR-IP2-2008-4S48

CR-IP2-200S-5055

CR-IP3-2009-003S

CR-IP2-2009-1125

CR-IP2-2009-079S

CR-IP2-2009-1295

CR-IP2-2009-2090

CR-IP2-2009-2603

CR-IP3-2009-320S

CR-IP3-2007 -3953

CR-IP3-2007 -41S3

CR-IP2-2007-5217

CR-IP2-2008-1149

CR-IP2-2008-0404

CR-IP2-2008-0492

CR-IP3-2008-0S46

CR-IP2-2008-0179

CR-IP2-2008-3154

CR-IP3-2008-0194

CR-IP2-2008-3526

CR-IP2-2008-2691

CR-IP3-2009-00S0

CR-IP2-2008-2955

CR-IP2-2008-3492

CR-IP3-2008-1979

CR-IP2-2008-4108

CR-IP2-2008-4202

CR-IP3-2008-2296

CR-IP3-2008-2294

CR-IP3-2007-0005

CR-I P3-2007 -27 48

CR-IP3-2007-2S70

CR-IP2-2008-1132

CR-IP3-200S-2S62

CR-IP2-2009-0477

CR-IP2-2009-01S4

CR-IP3-2009-0494

CR-IP3-2009-0591

Attachment

A-3

NRC Groundwater Sample Result Documentation ICY 2009. 1st Quarter)

ML090400502. ML090920949. ML090920932

FSAR

GPM

LTGWMP

NYS DEC

ODCM

pCi/L

PI&R

Rap

LIST OF ACRONYMS USED

Final Safety Analysis Report

gallons per minute

Long Term Ground-Water Monitoring Program

State of New York Department of Environmental Conservation

Offsite Dose Calculation Manual

pico-Curies per Liter

Problem Identification and Resolution

Reactor Oversight Process

Attachment