ML12335A591

Official Exhibit - RIV000071-00-BD01 - in the Matter of Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations Inc'S Joint Application for Cwa Section 401 Water Quality Certification, .

ML12335A591
Person / Time
Site:	Indian Point
Issue date:	12/22/2011
From:	Zoli E N Entergy Nuclear Indian Point 2, Entergy Nuclear Indian Point 3, Entergy Nuclear Operations, Goodwin Procter, LLP
To:	Atomic Safety and Licensing Board Panel, State of NY, Dept of Environmental Conservation
SECY RAS
References
RAS 21642, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12335A591 (3)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3)

ASLBP #:07-858-03-LR-BD01 Docket #:05000247 l 05000286 Exhibit #:

Identified:

Admitted: Withdrawn:

Rejected: Stricken: Other: RIV000071-00-BD01 10/15/2012 10/15/2012 RIV000071 Submitted: December 22, 2011 EXCERPT STATE OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION In the Matter of Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations Inc.'s Joint Application for CWA § 401 Water Quality Certification DEC App. Nos. 3-5522-00011100030 (IP2) 3-5522-00105/00031 (IP3) PRE FILED TESTIMONY OF MATTHEW J. BARVENIK IN SUPPORT OF ENTERGY NUCLEAR INDIAN POINT 2, LLC, ENTERGY NUCLEAR INDIAN POINT 3, LLC AND ENTERGY NUCLEAR OPERATIONS, INC. ISSUE FOR ADJUDICATION NO.3 -RADIOLOGICAL MATERIALS July 22, 2011 ENTERGY NUCLEAR INDIAN POINT 2, LLC, ENTERGY NUCLEAR INDIAN POINT 3, LLC, AND ENTERGY NUCLEAR OPERATIONS, INC. By its attorneys, John C. Englander Elise N. Zoli U. Gwyn Williams Robert Fitzgerald Goodwin Procter LLP 53 State Street Boston, Massachusetts 02109 Tel.: 617.570.1000 Fax: 617.523.1231 1 2 3 4 Q: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 PREFILED TESTIMONY OF MATTHEW J. BARVENIK IN SUPPORT OF ENTERGY NUCLEAR INDIAN POINT 2, LLC, ENTERGY NUCLEAR INDIAN POINT 3, LLC AND ENTERGY NUCLEAR OPERATIONS, INC. is regularly inspected to verify it is in good working condition.

Following the discovery of IP2 SFP releases, additional monitoring wells were put in place to monitor the groundwater beneath IP3 as a proactive and precautionary measure. Has the groundwater monitoring program allowed you to indentify and/or characterize any additional releases to groundwater?

Yes. As stated above, Entergy's broad array of monitoring installations, in addition to characterizing the extent and movement of existing radionuclides in groundwater, is also designed to assist Entergy in identifying possible future releases of radionuclides to the groundwater beneath the site, and to assist Entergy in identifying and remediating the source of such releases.

This is part of Entergy's Long Term Monitoring Program ("L TMP"), which is described more fully below. For example, since the L TMP began, we have identified and/or characterized additional releases to groundwater beneath the site:

• In the first quarter of2009, a leakage of water occurred in a distillation tank valve located within the IPI chemical systems building.

The result of this leakage was the identification of a brief increase in tritium levels in a monitoring location in the area of the chemical systems building.

Since the leakage was repaired, levels in that monitoring well have gone down to pre-leak levels. There is no indication that this i brief leakage caused any material increase in the amount of tritium reaching the river.

• In the fourth quarter of2009, a leakage of water occurred during a temporary operation to filter the water in the Refueling Water Storage Tank. This leakage resulted in a temporary increase in tritium levels in various monitoring wells. The leak was immediately fixed, and tritium levels have since gone down to pre-leak PREFILED TESTIMONY OF MATTHEW J. BARVENIK IN SUPPORT OF ENTERGY NUCLEAR INDIAN POINT 2, LLC, ENTERGY NUCLEAR INDIAN POINT 3, LLC AND ENTERGY NUCLEAR OPERA nONS, INC. 1 levels. Entergy has subsequently determined that the radionuclide dose consequence 2 as a result of this leak was immaterial.

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• Beginning in the third quarter of 20 1 0, we noticed increased tritium levels in a 4 monitoring location adjacent to the IP2 SFP, which generally coincided with an 5 increase in the rate of water flowing into the leak-collection box on the outside of the 6 IP2 SFP. As an initial finding of the on-going investigation, the increased flow 7 appears to be attributable to the periodic raising of the SFP water level, resulting in a 8 leak path from light boxes near the top of the SFP, allowing water to get behind the 9 stainless steel liner plates on the face of the SFP. This leak path has had a temporary 10 repair applied, through sealing of the light boxes. Those light boxes are planned to be 11 removed and permanently sealed in the near future. There is no indication that this 12 leakage has resulted in any material increase in the tritium plume but additional 13 evaluations continue, so as to fully understand this issue. 14 While the concentrations of tritium identified above have resulted in no material increase 15 in the offsite dose analyses regularly performed by Entergy, all such instances are* 16 enveloped by the reporting and analysis requirements of the NRC's effluent regulations.

17 As such, they are included in the annual environmental*

and effluent release reporting 18 documents provided to the NRC. 19 In my professional opinion, Entergy's ability to identify, characterize, and 20 respond appropriately to these sporadic releases, which occur at any large industrial 21 facility, demonstrates the efficacy of the LTMP. 22 VI. DETAILS OF GZA'S SITE HYDROGEOLOGY STUDY 23 Q: Please provide an overview of the purpose and objectives of Indian Point's