ML12157A247

Attachment 23 to GNRO-2012/00039, Er Reference - Entergy 2011 a (EN-CY-111) Radiological Ground Water Monitoring Program

ML12157A247
Person / Time
Site:	Grand Gulf
Issue date:	05/23/2012
From:	Entergy Operations
To:	Office of Nuclear Reactor Regulation
References
GNRO-2012/00039 EN-CY-111, Rev 1
Download: ML12157A247 (28)

Text

Attachment 23 to GNRO-2012/00039 Attachment 23 to GNRO-2012/00039 ER Reference - Entergy 2011 a (EN-CY-1 11)

"Radiological Ground Water Monitoring Program"

NUCLEAR NON-QUALITY RELATED EN-CY-111 REV. 1 MANAGEMENT MANUAL REFERENCE USE PAGE 1 OF 27 I Radiological Ground Water Monitoring Program

[Procedure Contains NMM REFLIB Forms: YES LI NO Z Effective Procedure Owner: Daniel Wilson Governance Owner: Patrick Donahue Date

Title:

Mgr., Chemistry

Title:

Mgr., Fleet Environ.

02/16/11 Site: IPEC Site: Echelon Exception Site Site Procedure Champion Title Date*

ANO Teresa Kring Chemistry Manager BRP Todd Shewmaker Chemistry Manger GGNS Richard Scarbrough Chemistry Manger IPEC Daniel Wilson Chemistry Manager JAF Laurie Rayle Chemistry Manager PLP Jarrod Miller Chemistry Manager PNPS Tom McElhinney Chemistry Manager RBS Robert Heath Chemistry Manager VY Jeff Hardy Chemistry Manager W3 John Hornsby Chemistry Manager NP N/A N/A HQN N/A N/A Site and NMM Procedures Canceled or Superseded By This Revision Process Applicability Exclusion) All Sites: Li Specific Sites: ANO LI BRP [I GGNS El IPECE] JAF El PLP El PNPS Z RBS LI VY El W3 EL

Chan-ce Statement This procedure has been revised to:

1. Reformat procedure to EN style/format.

2. Section 2.0 revised to add ANI Nuclear Liability Insurance Guideline 07-01 as a reference, and to separate regulatory references from company references.

3. Section 3.0 revised to add definition of Credible Mechanism, LLD, MDC.

4. Section 4.0 revised to include responsibilities for Senior Management, revise responsibilities for Chemistry Managers, added responsibilities for Site Engineering Director and NSA Director.

5. Section 5.3 added to identify and mitigate SSCs and Work Practices.

6. Section 5.4 added to document atmospheric deposition of plant effluents.

7. Section 5.8 added to address collection and analysis of soil samples collected in support of the RGWMP.

8. Section 5.10 added to clarify voluntary communications.

9. Section 5.11 added to identify periodicity and content of stakeholder briefings and updates.

10. Section 5.12 added to specifically identify associated ground water monitoring program reporting requirements.

11. Section 5.13 added to identify and document any remediation or mitigation performed.

12. Section 5.14 added to identify required program reviews.

13. Section 5.15 revised to better define due dates of self-assessments.

14. Section 5.16 added to distinguish NEI conducted assessments from site self-assessments.

15. Added Attachment 9.1 to identify work practices that can adversely affect ground water and soil.

16. Added Attachment 9.2 as a template to document analysis of plant effluent deposition.

17. Revised Attachment 9.3 to incorporate gross alpha MDC and to revise the beta-emitter MDCs

18. Added Attachment 9.4 to identify soil sample analytical MDCs.

19. Added Attachment 9.7 to assist user in identifying spill/leak reporting criteria.

• Requires justification for the exception

NUCLEAR NON-QUALiu RELATED EN-CY-111 REV. 1 MkEnterg MANAGEMENT MANUAL REFERENCE USE PAGE 3 OF 27 Radiological Ground Water Monitoring Program TABLE OF CONTENTS 1.0 PURPOSE ........................................................................................................................................ 4

2.0 REFERENCES

................................................................................................................................. 4 3.0 DEFINITIONS ................................................................................................................................... 5 4.0 RESPONSIBILITIES ........................................................................................................................ 6 5.0 DETAILS .......................................................................................................................................... 8 5.1 PRECAUTIONS AND LIMITATIONS ........................................................................ 8 5.2 OVERALL OBJECTIVES AND REQUIREMENTS ....................................................... 8 5.3 SSC AND WORK PRACTICE IDENTIFICATION &MITIGATION ..................................... 9 5.4 ATMOSPHERIC DEPOSITION COLLECTION &ANALYSIS ......................................... 10 5.5 GROUND WATER W ELL MANAGEMENT ................................................................. 10 5.6 SAMPLE SCHEDULE AND PLANNING ........................................................................ 11 5.7 GROUND WATER SAMPLE COLLECTION AND ANALYSIS IN SUPPORT OF THE RGWMP. 12 5.9 DATA REVIEW AND MANAGEMENT ...................................................................... 12 5.10 VOLUNTARY COMMUNICATIONS ................................................................... 13 5.11 STAKEHOLDER BRIEFINGS & UPDATES ............................................................ 14 5.12 REPORTING ................................................................................................ 14 5.13 GROUND WATER REMEDIATION PROCESS & DECISION MAKING PROCESS .......... 15 5.14 REVIEWS .................................................................................................... 16 5.15 SELF-ASSESSMENTS ................................................................................... 18 5.16 PEER REVIEW ASSESSMENT ........................................................................ 18 6.0 INTERFACES ................................................................................................................................. 18 7.0 RECORDS ...................................................................................................................................... 18 8.0 SITE SPECIFIC COMMITMENTS ............................................................................................. 19 9.0 ATTACHMENTS ............................................................................................................................ 19 9.1 WORK PRACTICES THAT COULD RESULT IN CONTAMINATION OF GROUND WATER OR SOIL ............. 20 9.2 ATMOSPHERIC DEPOSITION ANALYSIS ............................................................................. 219 9.3 RGW MP GROUND WATER SAMPLE RADIONUCLIDE ANALYSIS MDCs (EXAMPLE) ........................ 22 9.4 RGW MP SOIL SAMPLE RADIONUCLIDE ANALYSIS MDCs (EXAMPLE) ...................................... 23 9.5 MONITORING WELL INVESTIGATION LEVELS (EXAMPLE) ........................................................ 24 9.6 QUARTERLY INTEGRATED REVIEW CHECKLIST ................................................................... 25 9.7 SPILL/LEAK AND GROUND WATER SAMPLE RESULT REPORTING CRITERIA ................................. 26 9.8 POTENTIAL MITIGATING ACTIONS .................................................................................. 27

1.0 PURPOSE

[1] To establish the elements of a fleet radiological ground water monitoring program (RGWMP) for the timely detection of inadvertent radiological releases to ground water and the monitoring of any known radiological ground water plumes.

2.0 REFERENCES

[1] Regulatory References (a) 1 0CFR §50.75(g), Reporting and Recordkeeping for Decommissioning Planning.

(b) NEI Industry Ground Water Protection Initiative - Final Guidance Document, August 2007.

(c) Draft Regulatory Guide DG-4013, (Proposed Revision 2 of Regulatory Guide 4.1 dated April 1975), Radiological Environmental Monitoring for Nuclear Power Plants.

(d) NRC Temporary Instruction 2515/173, Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative.

(e) IE Bulletin 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment.

(f) EPRI Groundwater Protection Guidelines for Nuclear Power Plants Final Report, November 2007.

(g) ANI Nuclear Liability Insurance Guideline 07-01, Potential for Unmonitored and Unplanned Off-Site Releases of Radioactive Materials.

(h) INPO Topical Report TR10-71, Review of Sources of Unexpected Tritium Releases to the Environment, August 2010.

(i) EPRI 1019226 Review of Methods and Tools for Estimating Atmospheric Deposition of Tritium at Nuclear Power Plants

[2] Company References (a) EN-CY-108, Monitoring of Nonradioactive Systems (b) EN-RP-1 13, Response to Contaminated Spills/Leaks (c) EN-DC-343, Buried Piping and Tanks Inspection and Monitoring Program.

Section 2.0[21 Continued (d) EN-CY-1 09, Sampling and Analysis of Ground Water Monitoring Wells.

(e) Offsite Dose Calculation Manual (ODCM).

(f) EN-CY-1 02, Laboratory Analytical Quality Control.

(g) EN-MA-125, Troubleshooting Control of Maintenance Activities.

3.0 DEFINITIONS

[1] Credible Mechanism- A "credible mechanism" for licensed material to reach groundwater is considered one wherein the failure of a single barrier between an SSC and the environment, or the failure of a work practice control, could result in the inadvertent or unintentional contamination of ground water or soil.

(a) For SSCs, meaning the failure of a single barrier or subcomponent boundary resulting in radioactive liquid release to the groundwater or soil.

(b) For work practices, meaning the release of radioactive liquid to the groundwater or soil resulting from inadvertent or unplanned events during plant or personnel operational activities.

[2] Indicator radionuclides- Specific radionuclides that are selected for monitoring, based upon their abundance in a source-term, migration characteristics in ground water, or their potential for adverse impact, which can be used to indicate the general nature and extent of ground water contamination or detect leaks from a structure or component containing radioactive fluids. Indicator radionuclides are site specific.

[3] Investigation Level - the concentration of a specified radionuclide as detected in a specific ground water monitoring well that will initiate an evaluation or other actions.

Investigation levels are site specific.

[4] Lower Limit of Detection (LLD) - As defined in NUREG 1301/1302, the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

[5] Minimum Detectable Concentration (MDC) - An a posteriori estimate of the minimum net activity level that can be measured reliably by a particular system or technique under a given set of conditions. It is the net concentration that has a 95% chance of being detected. It is an estimate of the detection capability of a measuring protocol and is calculated after measurements are taken. MDC is the detection limit expressed as an activity concentration. If the activity concentration in a sample is equal to the MDC, then there is a 95% chance that radioactive material in the sample will be detected.

Section 3.0 Continued

[6] Perimeter Well - A ground water monitoring well located at the site perimeter in order to detect the presence of a contaminant at or near the site boundary.

[7] Positive Detection - A radionuclide is positively detected when the analytical result for a given radionuclide is determined to be greater than or equal to the associated MDC.

[8] Sentinel Well - A groundwater monitoring well located in proximity and downgradient of an SSC such that any leak or spill from the associated SSC will be quickly detected.

[9] Stake Holder - A non-regulatory individual or group with an official capacity or responsibility for the welfare of the community and a desire to be involved in environmental issues.

[10] SSCs - systems, structures, or components that contain or could contain licensed material and for which there is a credible mechanism for the licensed material to reach ground water. SSCs are site specific.

4.0 RESPONSIBILITIES

[1] Enteray Nuclear Chemistry Peer Group is responsible for maintaining, reviewing, and interpreting this procedure.

[2] Station Senior Management are responsible for:

(a) Establish and maintain expectations for open and honest communications consistent with Entergy standards.

(b) Ensure confirmed positive water sample test results are investigated in a timely manner.

(c) Initiate investigative, mitigation and remediation actions as necessary for plume discovery, mitigation, or remediation.

[3] Site Chemistry Managers or Designee are responsible for:

(a) Administering this procedure at the site level.

(b) Reviewing analytical data associated with sampling of groundwater.

(c) Notifying site management personnel and regulatory agencies, as required.

(d) Making notifications as may be required through EN-CY-1 08, Monitoring of Nonradioactive Systems.

(e) Ensures an Independent Assessment of the Groundwater Protection Program is conducted per EN-LI-1 04 every five years.

NUCLEAR NON-QUALTYRELATED EN-CY-1Il REV. 1 Entergy MANAGEMENT MANUAL REFERENCE USE PAGE 7 OF 27 Radiological Ground Water Monitoring Program Section 4.0 Continued

[4] Site Radiation Protection Managers or Designee are responsible for:

(a) Ensuring that any radioactive spills or leaks are documented and communicated as per EN-RP-1 13, Response to Contaminated Spills/Leaks.

(b) Ensuring that records of leaks, spills, and remediation efforts are retained and are retrievable to meet the requirements of 10CFR §50.75(g), Reporting and Recordkeeping for Decommissioning Planning.

[5] Site Engineering Director or Designee is responsible for:

(a) Evaluating all systems, structures, and components (SSCs) that contain or could contain radioactive liquids, including both above and below grade SSCs; and provides a credible mechanism for releasing radioactive liquid to soil or groundwater.

(b) Ensuring that a risk assessment profile of SSCs and work practices is developed per this procedure.

(c) Periodic review identifying site specific SSCs and leak detection methods per this procedure.

(d) Notifying Chemistry of any deficiencies in buried or partially buried piping and tanks that, if degraded, could provide a path for radioactive contamination of groundwater.

[61 Site NSA Director or Designee is responsible for:

(a) Ensure periodic meeting are held with state and local officials pertaining to communicating Groundwater Protection Program results and events.

(b) Consider using informal communications to state and local officials when spills or leaks or confirmed positive well test results are discovered.

[7] Site Maintenance Manager or Designee are responsible for:

(a) Monitoring Well Maintenance, including:

(1) Maintaining the exterior of the well and well vault (if equipped),

(2) Maintain the well visible and protected, (3) Maintain access to the well (shoveling or mowing a path to the well).

NUCLEAR NON-QUALTY RELATED EN-CY-1 11 REV. 1 gyopn MANAGEMENT MANUAL REFERENCE USE PAGE 8 OF 27 Radiological Ground Water Monitoring Program 5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS

[1] The ground water monitoring program is separate and distinct from the radiological environmental monitoring program (REMP).

[2] Each facility shall complete a site characterization of the geology and hydrology that provides an understanding of predominant ground water gradients based upon current site conditions, and if necessary update the Final Safety Analysis Report (FSAR).

[3] Each facility shall complete a risk assessment identifying SSCs and work practices that involve or could reasonably be expected to involve licensed material and for which there is a credible mechanism for licensed material to reach ground water.

[4] For those sites whose radiological ground water monitoring program wells are included in the Radiological Environmental Monitoring Program (REMP), revise the site's ODCM/ODAM. For any site that does not sample RGWMP monitoring wells as part of their REMP program then no change to their ODCM/ODAM is necessary.

[5] Initial Stakeholder briefings have been conducted.

[6] This procedure provides the fleet standard on the implementation of a ground water monitoring programs at Entergy nuclear facilities. Each site will need to carefully assess and utilize site specific characteristics to implement an effective local program.

5.2 OVERALL OBJECTIVES AND REQUIREMENTS

[1] Procedures, staffing and equipment shall be maintained to monitor, investigate and characterize contamination of ground water with licensed radioactive material at Entergy facilities.

[2] Monitoring activities shall be performed to accomplish the following objectives:

(a) Monitor the status of any known radiological ground water plumes.

(b) Detect and quantify previously unidentified sources of ground water contamination such as a spill or leak from a radioactively contaminated system, structure or component.

(c) Provide data to calculate potential doses to a member of the public.

(d) Monitor and evaluate the long term effectiveness of remediation or intervention actions.

SNUCLEAR NON-QUALITY RELATED EN-CY-1 11 REV. 1

=7_Enterp7y MANAGEMENT MANUAL REFERENCE USE PAGE 9 OF 27 Radiological Ground Water Monitoring Program Section 5.2 Continued

[3] Ground water contamination investigation and characterization activities are conducted to accomplish one or more of the following objectives:

(a) Determine the source(s) of ground water contamination (e.g., leaking radioactive components or systems, radioactive spills or legacy soil or bedrock contamination).

(b) Determine the locations, extent and concentrations of ground water contamination (e.g., define the plume).

(c) Evaluate necessary corrective/investigative actions, utilizing the Corrective Action Program.

5.3 SSC and WORK PRACTICE IDENTIFICATION & MITIGATION

[1] SSC Assessment:

(a) The Site Engineering Director or Designee shall ensure a comprehensive evaluation is completed for systems, structures, and components (SSCs) that meet both of the following criteria:

(1) Contain or could contain radioactive liquids, including both above and below grade SSCs; and (2) Provides a credible mechanism for releasing radioactive liquid to soil or groundwater.

(b) All SSCs shall be evaluated and documented.

(c) The assessment shall include existing leak detection methods for each credible SSC. Leak detection methods may include, but are not limited to:

(1) Operator rounds (2) Work package walkdowns (3) Engineering or management walkdowns or inspections (4) Leak detection systems or devices (5) Periodic or corrective integrity testing

[2] Work Practices Assessment:

(a) The assessment needs to consider work practices from multiple departments at the station.

_ EM GNUCLEAR NON-QUALiTY RELATED EN-CY-111 REV. 1 Ente MANAGEMENT MANUAL REFERENCE USE PAGE 10 OF 27 Radiological Ground Water Monitoring Program Section 5.3[2] Continued (b) Attachment 9.1, Work Practices That Could Result in Contamination of Ground Water or Soil, gives examples of work practices that should be considered in the assessment.

(c) The assessment should include both routine operational work practices and those associated with non-routine projects or outages.

5.4 ATMOSPHERIC DEPOSITION COLLECTION & ANALYSIS

[1] The Environmental Specialist shall assess the potential contribution of atmospheric deposition of tritium to groundwater by completing the following:

(a) Complete the assessment using Attachment 9.2, Atmospheric Deposition Analysis.

(b) Re-assess by completing Attachment 9.2 every 5 years.

5.5 GROUND WATER WELL MANAGEMENT

[1] Ground water wells should be capable of providing one or more of the following functions:

(a) Provide long term monitoring/sampling capabilities.

(b) Provide near term investigative/characterization sampling capabilities.

(c) Collect hydro-geological data (e.g., water table levels, flows, etc.)

(d) Support tests such as dye injection or draw down tests.

(e) Support remediation, containment or intervention activities.

[2] Well inspection and maintenance to ensure a well is suitable for qualitative sampling should be performed at least annually and should include (a) A visual inspection of surface facility, borehole, and any pulled components:

(1) The concrete pads should be inspected for cracks, separation from well, and heaving.

(2) The surface casing should be inspected for cracks or damage.

(3) Traffic cover (for flush-mounted wells) should be inspected for fit, cracks, and leaks.

Section 5.5[2](a) Continued (4) Locks, if equipped, should be serviceable and prevent unauthorized entry into the well.

(b) Sample pump performance and the hydraulic performance of a well should be observed in response to pumping at the time of sampling.

(c) Any discrepancies noted should be addressed and documented by the site condition reporting system.

(d) Annual evaluations of well instrumentation (such as transducers) used to provide hydrological data supporting the RGWMP.

(e) A listing of monitoring wells, with their purpose, status and routine analytes should be maintained.

5.6 SAMPLE SCHEDULE AND PLANNING

[1] Sampling and analysis of wells shall be performed to meet the objectives of the RGWMP.

[2] Routine sampling of wells shall be performed at frequencies that will support meeting the objectives of the RGWMP. Although samples should be scheduled at consistent intervals, site activities that could influence site hydrogeology or SSCs should also influence the frequency and location of collected samples. Some examples of activities that can influence ground water:

(a) Refueling Activities, (b) Spent Fuel Pool and Cavity flood up.

(c) Unexplained level change in an SSC.

(d) Construction activities affecting an SSC or that may influence groundwater flow or direction.

(e) A known or suspected spill requiring notification per EN-RP-1 13.

(f) Unexpected change in radionuclide concentration in an SSC such as Reactor Coolant System, Spent Fuel Pool or Refueling Water Storage Tank.

[3] A listing of the current RGWMP monitoring wells should be maintained that specifies well status and the current sampling schedule.

5.7 GROUND WATER SAMPLE COLLECTION AND ANALYSIS IN SUPPORT OF THE RGWMP

[1] Sample collection, handling and tracking for RGWMP well samples shall be performed in accordance with EN-CY-1 09, Sampling and Analysis of Ground Water Monitoring Wells.

[2] At a minimum, each ground water sample shall be analyzed for tritium and plant-related gamma emitters listed in Attachment 9.3, RGWMP Ground Water Sample Radionuclide Analysis MDCs (Example). If tritium or plant-related gamma activity is positively detected, then the sample should be analyzed for the presence of other radionuclides using the MDC values listed in this same table.

[3] The selection of the additional radionuclides for analysis shall be based on site-specific source terms and as necessary to support ground water investigation and characterization.

[4] The omission of additional radionuclides from analysis shall be based on site-specific source terms and the historical lack of their occurrence in the presence of low level concentrations of tritium.

[5] The required MDCs for each ground water sample analyte can be found in Attachment 9.3.

5.8 SOIL SAMPLE COLLECTION & ANALYSIS IN SUPPORT OF THE RGWMP

[1] Soil samples taken in support of the RGWMP shall be collected at locations, frequencies and volume as dictated by the Chemistry Specialist based on the objective of the soil sampling.

[2] The required MDCs for each soil sample analyte can be found in Attachment 9.4, RGWMP Soil Sample Radionuclide Analysis MDCs (Example).

5.9 DATA REVIEW AND MANAGEMENT

[1] Sample data review and data management for RGWMP well samples shall be performed in accordance with EN-CY-1 09.

[2] Sample results shall be compared to their associated investigation levels contained in Attachment 9.5.

(a) IF a sample result exceeds its associated investigation level, THEN a condition report shall be generated to document this condition and any investigatory and corrective actions taken.

Section 5.9 Continued

[3] Once per quarter perform a review of other site programs that can provide additional information on systems that can affect ground water. This review should include the following:

(a) Ground water sample results, (b) Storm Drain sample results, (c) IE Bulletin 80-10 reports, (d) Operational history (e) Spill Reports (f) System Chemistry & Activity (e.g. SFP, RWST and RCS)

(g) Notifications, Evaluations and Communication (h) Work Practices.

[4] Document this completed review in Attachment 9.6, RGWMP Quarterly Integrated Review Checklist and maintain this document as a record.

5.10 VOLUNTARY COMMUNICATIONS NOTE Attachment 9.7, Spill/Leak and Ground Water Sample Result Reporting Criteria, contains a decision making flow chart to assist in determining voluntary reportability.

[1] Voluntary notification of spills and leaks from radioactive or potentially radioactive systems is performed in accordance with Procedure EN-RP-1 13, Response to Contaminated Spills/Leaks.

[2] Verify that the documentation and communication protocols outlined in EN-RP-1 13 are implemented IF:

(a) A confirmed water sample result from an offsite groundwater or surface water location exceeds the REMP reporting criterion for water as outlined in the ODCM.

NUCLEAR NON-QUALiTY RELATED EN-CY-1 11 REV. I 7=-Ente, gy MANAGEMENT MANUAL REFERENCE USE PAGE 14 OF 27 Radiological Ground Water Monitoring Program Section 5.10[2] Continued (b) A confirmed water sample result from an onsite groundwater monitoring well that is or could be used in the future as a source of drinking water that exceeds the REMP reporting criterion for water as outlined in the ODCM.

[3] Documentation of leaks, spills and remediation efforts shall be made in the condition reporting system.

[4] Documentation of leaks, spills and remediation efforts shall be made as required by 10 CFR 50.75(g).

[5] Document voluntary communications.

[6] Evaluate the need for remediation. A list of potential mitigating actions is contained in Attachment 9.8, Potential Mitigating Actions.

5.11 STAKEHOLDER BRIEFINGS & UPDATES

[1] Briefings about the site RGWMP shall be conducted at minimum annually with the State/Local officials.

[2] Sites should coordinate these communications with other licensees in their state.

[3] The briefing should discuss:

(a) The background or industry events that led to the ground water monitoring program.

(b) Any additional information that the State/Local officials need to better understand the issue or place it in perspective for their constituents.

(c) "How" the State/Local officials will use or distribute the information.

5.12 REPORTING

[1] Submit a written 30-day report to the NRC for any confirmed onsite groundwater water sample result that is or may be used as a source of drinking water that exceeds the REMP reporting criterion for water as outlined in the ODCM.

[2] Submit a written 30-day report to the NRC for any confirmed offsite groundwater water sample result that exceeds the REMP reporting criterion for water as outlined in the ODCM.

[3] Submit copies of written 30-day reports for both onsite and offsite water sample results that exceeds the REMP reporting criterion for water as outlined in the ODCM to the appropriate state and local officials.

Section 5.12 Continued

[4] The 30-day special report should include:

(a) A statement that the report is being submitted in support of the Ground Water Protection Initiative, (b) A list of the contaminant(s) and the verified concentration(s),

(c) Description of the action(s) taken, (d) An estimate of the potential or bounding annual dose to a member of the public, and (e) Corrective action(s), if necessary, that will be taken to reduce the projected annual dose to a member of the public to less than the limits in 10 CFR 50 Appendix I.

5.13 GROUND WATER REMEDIATION PROCESS & DECISION MAKING PROCESS

[1] Once ground water contamination has been detected sites shall evaluate the need for performing:

(a) An estimate of the potential or bounding annual dose to a member of the public, (b) Corrective action(s) to maintain ALARA standards with regard to site radioactive effluents.

(c) Update to the site Offsite Dose Calculation Manual (ODCM).

(d) Update to the site Final Safety Analysis Report (FSAR)

[2] Each facility shall establish protocols to prevent the migration of licensed material offsite. This shall include:

(a) Establishing documentation outlining the decision making process for remediation of leaks and spills or other instances of inadvertent releases. This process is site specific and shall consider migration pathways.

(b) Estimating the leak/spill location and size or extent and movement of the contaminant plume.

(c) Evaluating the dose to members of the public from the leak or spill using realistic exposure scenarios.

(d) Evaluating the potential for detectable levels of licensed material resulting from planned releases of liquids and/or airborne materials.

NUCLEAR NON-QUALITY RELATED EN-CY-1 11 REV. 1 7f-Enterg MANAGEMENT MANUAL REFERENCE USE PAGE 16 OF 27 Radiological Ground Water Monitoring Program Section 5.13[2] Continued (e) Evaluating and documenting, as appropriate, decommissioning impacts resulting from remediation activities or the absence thereof.

(f) Documenting any remediation efforts to meet the requirements of 10 CFR 50.75(g).

(g) Creating and documenting an action plan in accordance with EN-MA-125 or equivalent describing existing conditions and proposed corrective actions.

5.14 REVIEWS

[1] Annual Ground Water Sample Data Review:

(a) Sample data shall be compiled, organized and reviewed annually as a minimum to:

(1) Analyze for increasing or decreasing trends at individual sample points, wells or groups of wells.

(2) Review the radionuclides detected to determine whether changes should be made to the analysis suites or sampling frequencies for each sampling location.

(3) Evaluate the locations of radionuclides in ground water to determine if changes should be made to the sampling locations.

(4) Review current investigation levels (Attachment 9.5, Monitoring Well Investigation Levels) and determine if changes should be made.

(5) Determine if any change to the ODCM is required.

(6) Determine if a corrective actions/remediation is required.

[2] Annual Radiological Environmental Operating Report: (AREOR)

(a) The Radiological Environmental Monitoring Program (REMP) contact shall:

(1) Review the annual RGWMP report, and (2) Ensure the sample results obtained from REMP wells listed in the Offsite Dose Calculation Manual (ODCM) are reported and summarized in the Annual Radiological Environmental Operating Report (AREOR).

Section 5.14 Continued

[3] Annual Radiological Effluent Release Report (ARERR)

(a) The Radiological Effluent Controls contact shall review the annual RGWMP report and ensure the Annual Radiological Effluent Release Report (ARERR) includes:

(b) A listing of non-REMP wells and a summary of pertinent sample results from the RGWMP are reported in the ARERR.

(c) An estimate of the doses to a member of the public associated with off-site releases of licensed radioactive material via ground water is included in the ARERR.

[4] SSC and Work Practice Review (a) Every five years, perform a periodic review of the site SSCs and work practices that involves or could involve licensed material and for which there is a credible mechanism for inadvertent releases to ground water.

(b) Only those SSCs that have a credible mechanism for releasing radioactive liquid to soil or groundwater need be considered in this evaluation. Identify the SSCs of concern and evaluate their applicable components, their locations, their age, and their current physical condition.

(c) Work practices shall be evaluated to assess their potential for contributing to groundwater contamination. Only those work practices that have a credible mechanism for causing or allowing the release of radioactive liquid to soil or groundwater need be considered in this evaluation.

[5] Perform a review of the site hydrogeologic studies every 5 years.

(a) As a minimum, reviews should be performed whenever any of the following occurs:

(1) Substantial on-site construction, (2) Substantial disturbance of site property, (3) Substantial changes in on-site or nearby off-site use of water, or (4) Substantial changes in on-site or nearby off-site pumping rates of ground water

NUCLEAR NON-WUALITY KELATED EN'hY'I11 VI=V.

1 Entery MANAGEMENT MANUAL REFERENCE USE PAGE 18 OF 27 Radiological Ground Water Monitoring Program 5.15 SELF-ASSESSMENTS

[1] Perform periodic self-assessment of the radiological ground water monitoring program at least once every 5 years.

[2] The self-assessment, at a minimum, shall include evaluating implementation of all of the objectives identified in this document.

[3] The self-assessment shall be documented consistent with applicable station procedures and programs.

[4] Notify NEI of the completion of the periodic site self-assessment conducted as per 5.15[1].

5.16 PEER REVIEW ASSESSMENT

[1] A periodic review of the GPI program should be performed every 5 years, subsequent to the license's periodic self-assessment performed per step 5.15[1].

6.0 INTERFACES

[1] EN-CY-108, Monitoring of Nonradioactive Systems.

[2] Reporting requirements per EN-RP-1 13, Response to Contaminated Spills/Leaks.

[3] EN-CY-109, Sampling and Analysis of Ground Water Monitoring Wells.

[4] 10CFR §50.75(g), Reporting and Recordkeeping for Decommissioning Planning.

[5] EN-DC-343, Buried Piping and Tanks Inspection and Monitoring Program.

7.0 RECORDS

[1] Records generated by this procedure shall be retained in accordance with the Records Retention Schedule. They include:

(a) Radiological Ground Water Monitoring Program Report.

(b) Records of well inspections and maintenance.

(c) Lists of wells types and sampling frequencies.

(d) Self assessments.

(e) Quarterly Integrated Review Checklist.

8.0 SITE SPECIFIC COMMITMENTS NONE 9.0 ATTACHMENTS 9.1 Work Practices That Could Result in Contamination of Ground Water or Soil.

9.2 Atmospheric Deposition Analysis.

9.3 RGWMP Ground Water Sample Radionuclide Analysis MDCs (Example) 9.4 RGWMP Soil Sample Radionuclide Analysis MDCs (Example) 9.5 Monitoring Well Investigation Levels (Example) 9.6 Quarterly Integrated Review Checklist.

9.7 Spill/Leak And Ground Water Sample Result Reporting Criteria 9.8 Potential Mitigating Actions.

9.1 WORK PRACTICES THAT COULD RESULT IN CONTAMINATION OF GROUND WATER OR SOIL The following are examples of work practices that have the potential to impact soil or ground water and should be considered in site work practice assessments:

" The method by which liquids containing radioactivity are sampled or drained, and the precautions taken for eliminating spills to the ground.

" The procedure for monitoring the filling of tanks, particularly with regard to the potential for the tank capacity to be exceeded.

" The method of controlling hydrolaser wands and hoses in refueling cavities and spent fuel pools, i.e., in light of the potential for siphoning liquid out of the structure if left unattended and with no check valve in place.

" Work practices related to the packaging of radioactive waste for shipment and storage, and the potential exposure of radioactive material or contaminated surfaces to weathering and subsequent release to soil or groundwater.

" Movement of spent fuel storage casks containing liquids or creating ground water movement due to weight distribution as the cask travels to the ISFSI pad.

" Temporary Radiation Control Areas (RCAs) or work areas that are used for the storage or staging of contaminated equipment, or for work on such equipment, such as temporary RCAs established for packaging or dismantling large components, such as turbine rotors, should be assessed as a potential source of inadvertent contamination, unless appropriate contamination control measures have been implemented.

" Operational activities having a credible potential to contaminate ground water such as:

o Sampling or draining radioactive liquids.

o Filling, draining, or transferring liquids in to or from tanks and sumps.

o Storage of radioactive material exposed to weather.

o Transfer of spent ion exchange resin.

o Use of hydrolaser for cleaning radiologically contaminated systems.

o Use of secondary cooling water re-circulated within a closed-loop system that may become contaminated by primary systems.

o Use of auxiliary steam for building heat supply or to provide freeze protection for tanks containing radioactive liquid.

9.2 ATMOSPHERIC DEPOSITION OF TRITIUM TO GROUNDWATER ASSESSMENT FORM Performer Potential Contribution to Groundwater Date: Low High Observational Lines of Evidence Tritium detected in rain water samples [ ]No [ ] Yes Tritium detected in stormwater runoff [ ] No [ ] Yes Anomalous tritium detections in groundwater:

Detections upgradient of SSCs [] No [ ] Yes Detections cross gradient of SSCs [ ] No [ ] Yes Atmospheric Sources / Variables Stacks / Vents []No []Yes On-site containment ponds: [ No [ Yes Tritium concentration in surface water [ <2,000 pCi/L [ >2,000 pCi/L Amount of vegetation in pond [ I Low [ ] High Gaseous releases during rain events [ ] No [ ] Yes Prevailing winds from plant over [ ] River/Lake Land/Pond Hydrogeologic / Infiltration Variables Pervious nature of ground surface [ ] Impervious [ ] Pervious Slope of ground surface [ ] Steep [] Flat Amount of vegetation on ground surface [ ] High []Low Soil type Unconsolidated [] Clay [] Sand/Gravel Bedrock Fractured [ Unfractured [ I Fractured Groundwater conditions Water table fluctuates with rainfall events [] No [ ] Yes Comments:

S-Enler NUCLEAR NON-QUALTY RELATED EN-CY-111 REV. 1 Entgy MANAGEMENT MANUAL REFERENCE USE PAGE 22 OF 27 Radiological Ground Water Monitoring Program 9.3 RGWMP GROUND WATER SAMPLE RADIONUCLIDE ANALYSIS MDCs (EXAMPLE)

Radionuclide MDC Radionuclide MDC Gamma 54Emitters: a Beta Emitters: c Mn 15 _ H_2000 d b9Fe 30 5bFe 110 buCo 15 b;3Ni 530

• °Co 15 uSr 23 65Zn 30 __Sr 3.6 9

5Zr 30 9bNb 15 Alpha Emitters:

1 i1 1 1 Gross Alphae 15 13 4 Cs 15 137Cs 18 140Ba 60 14°La 15 At a minimum, each ground water sample shall be analyzed for tritium and plant-related gamma emitters listed above. If tritium or plant-related gamma activity is positively detected, then the sample should be analyzed for the presence of other radionuclides using the MDC values listed in this table. Selection of the additional radionuclides for analysis shall be based on site-specific source terms.

a The gamma emitters and corresponding LLD values listed are derived from standard ODCM guidance for environmental water samples as found in Table 4.12-1 in NUREG-1301/1302.

b The MDC value of 1.0 pCi/L for 1-131 is applicable only to groundwater used as a source of drinking water. If no drinking water pathway exists, a value of 15 pCi/L can be used.

C The beta emitters listed are based on common beta-emitting radionuclides observed through industry experience. The MDC values listed are based on a dose consequence of 1.0 mrem/yr effective dose equivalent (EDE) total body dose, assuming age-specific drinking water ingestion rates from Regulatory Guide 1.109 Table E-5 in conjunction with ICRP-72 age-specific EDE dose conversion factors. The application of EDE dose is consistent with the NRC bases of using only stochastic dose to derive Effluent Concentration Limits as documented in the front-note to Table 2 in 10CFR20 Appendix B.

d The MDC value of 2,000 or 3,000 pCi/L for tritium is derived from standard ODCM guidance for environmental water samples as found in Table 4.12-1 in NUREG-1 301/1302.

e The MDC value of 15 pCi/L for gross alpha is derived from EPA Drinking Water Maximum Contaminant Level and laboratory analytical capabilities.

in NUCLEAR NON-QUALITY RELATED EN-CY-111 REV. 1

=:-Entery MANAGEMENT MANUAL REFERENCE USE PAGE 23 OF 27 Radiological Ground Water Monitoring Program 9.4 RGWMP SOIL RADIONUCLIDE ANALYSIS MDCs (EXAMPLE)

Radionuclide MDC Radionuclide MDC (p~I/Kg) (pCi/Kg)

Gamma Emitters: a Beta Emitters: b 54 55 Mn 150 Fe 1,000,000 59 63 Fe 300 Ni 210,000 58 90 Co 150 Sr 170 60 Co 150 65 Zn 300 95 Zr 300 95 Nb 150 Alpha Emitters: b 1311 150 238pu 250 134Cs 150 239pu 230 137Cs 180 241Pu 7,200 140Ba 600 24_Am_ 210 14°L-a 150 233 Cm 320 a The gamma emitters MDC values listed are derived from the Cs-1 34/137 10:1 ratio established in the environmental LLDs in NUREG-1 301 and NUREG-1 302, Table 4.12-1, Detection Capabilities for Environmental Sample Analysis.

b The beta and alpha-emitter MDC values are derived from the NRC Screening Values from NUREG-1757, "NRC Consolidated Decommissioning Guidance", Volumes 2, September 2006, Table H-2.

9.5 MONITORING WELL INVESTIGATION LEVELS (EXAMPLE)

Well ID H-3 W (pCi/L) Sr-90 Other Plant-related (pCiIL) Radionuclides Off-Site Well Any Any detection f detection f Any detection Perimeter Well / Sentinel Well 2000 g h Any detection f Sentinel Well 40009 4h Any detection f located in known plume All remaining wells Note' Note' Note' A radionuclide is positively detected when the analytical result for a given radionuclide is determined to be greater than or equal to the associated MDC.

The values of 2000 and 4000 pCi/L for H-3 have been chosen such that they are low enough to assure timely detection of any new release or change to an existing release and be outside the normal expected range of sample results at these locations.

h The value of 4 pCi/L for Sr-90 have been chosen such that they are low enough to assure timely detection of any new release or change to an existing release and be outside the normal expected range of sample results at these locations.

Any positively detected radionuclide that has a result greater than 2 times the average from the previous year. The investigation level is not reached until an H-3 result is greater than 2000 pCi/L or a Sr-90 result is greater than 4 pCi/L.

This list is presented for illustrative purposes only. Actual data will vary and is site specific.

9.6 QUARTERLY INTEGRATED REVIEW CHECKLIST Program Item Review/Comments Monitoring Well MW Sample Results Sample Data MW Result Trends Storm Drain Storm Drain Activities Sample Data Storm Drain Trends IE Bulletin New 80-10 File Reports No. 80-10 Facility Refueling Activities Opeatiit s Spent Fuel Moves Operations ConstructionActivities Spill Reports Spills & Leaks Condition CRO75g Reports I OCFR50. 75(g)

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9.8 POTENTIAL MITIGATING ACTIONS The following mitigating actions are listed to assist in the user in their consideration of future actions for a site with known groundwater contamination. Approval of local, state, and federal agencies is generally required prior to performing remediation.

o Repair the source of the leak/spill.

o Remediate the root cause of leakage through a major replacement or design change.

o Address the unanalyzed pathway.

o Remove contaminated soil within the source area.

o Initiate a program of Monitored Natural Attenuation.

This relies on naturally-occurringprocesses such as dilution, dispersion, adsorption,and radioactive decay to reduce the concentration of radioactive contaminants over time. A groundwatermonitoring program is essential to provide data to demonstrate the effectiveness of this approach. Use of this technique may be appropriateif a contaminantplume is generally in equilibrium, the risk to receptorsis low, and contaminantconcentrationsare low enough so that applicableregulatory criteriacan be achieved within a reasonable timeframe.

o Pump and treat (or release) near the source area.

This approachshould be used with caution because of the potentialfor re-distributing contamination. Groundwaterflow should be well understood before employing this technique.

o Pump groundwater to intercept the plume before it advances to the site boundary.

This approachshould be used with caution because of the potentialfor re-distributingcontamination. Groundwaterflow should be well understood before employing this technique.

o Install grout curtains or sheet piling to create low-permeability boundaries which divert groundwater flow.

This technique usually also requirespumping and treating of the intercepted plume.

o Initiate a program of phytoremediation.

This technique uses vegetation to transpiregroundwaterand dissolved contaminantsfrom the shallow subsurface. This technique results in a portion of the contaminant being released to the atmosphere and a portion accumulating in the plant tissue.