ML081340425
| ML081340425 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/13/2008 |
| From: | Gamberoni M K Division of Reactor Safety I |
| To: | Joseph E Pollock Entergy Nuclear Operations |
| References | |
| EA-08-088, FOIA/PA-2010-0209, FOIA/PA-2016-0148 IR-07-010 | |
| Download: ML081340425 (56) | |
See also: IR 05000003/2007010
Text
May 13, 2008
Mr. Joseph Pollock
Site Vice President
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
450 Broadway, GSB
P.O. Box 249
Buchanan, NY 10511-0249
SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 1 & 2 - NRC INSPECTION REPORT NOS. 05000003/2007010 and 05000247/2007010
Dear Mr. Pollock:
On May 7, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Indian Point Nuclear Generating Units 1 & 2. The purpose of this inspection, initiated on
November 7, 2007, was to assess your site groundwater characterization conclusions and the
associated radiological significance relative to Entergy
=s discovery of a small amount of contaminated water leaking from the Unit 2 spent fuel pool, and the subsequent discovery of additional subsurface groundwater contamination emanating from the Unit 1 spent fuel pool
system. This inspection focused on assessing Entergy
=s groundwater investigation to evaluate the extent of contamination, and the effectiveness of actions, taken or planned, to effect appropriate mitigation and remediation of the condition.
The inspection involved an examination of activities conducted under Entergy's license as they
relate to safety and compliance with the Commission
=s rules and regulations, and with the conditions of the license. Within these areas, the inspection consisted of a selected examination of procedures and representative records, observations of activities, interviews with personnel,
and independent analytical and assessment activities. This inspection effort reviewed Entergy's
long-term monitoring plan intended for continuing verification and validation of the effectiveness
of the licensee's efforts to assess, mitigate and remediate on-site groundwater conditions
relative to public health and safety and protection of the environment. Details associated with
the long term monitoring program will continue to be the subject of ongoing NRC inspection. The NRC will also continue split sampling for analytical comparison of selected groundwater monitoring wells through 2008. During the course of this inspection, we coordinated activities
with representatives of the New York State Department of Environmental Conservation, who
observed our inspection and contributed valuable expertise and independent assessment
relative to its own focus on public health and safety, and environmental protection.
The enclosed inspection report documents the inspection findings, which were discussed on
May 7, 2008, with Mr. Don Mayer and other members of your staff
. The team found Entergy
=s response to identified conditions to be reasonable and technically sound. The existence of on-site groundwater contamination, as well as the circumstances surrounding the causes of
leakage and previous opportunities for identification and intervention, have been reviewed in
detail. Our inspection determined that public health and safety has not been, nor is likely to be,
J. Pollock 2 adversely affected, and the dose consequence to the public that can be attributed to current
on-site conditions associated with groundwater contamination is negligible. No significant
findings were identified. However, one minor violation with respect to quality control of
groundwater sampling is discussed in this report. This violation is not subject to enforcement
action in accordance with Section IV of the NRC Enforcement Policy. The NRC plans no further
action with regard to this matter; and no response to this letter is required.
Based on a telephone discussion between Messrs. John McCann, Director of Licensing, and
Samuel Collins, NRC Region I R
egional Administrato
r, on April 21, 2008, we understand that Entergy has committed to remove and transfer all spent fuel from the Unit 1 Spent Fuel Pool to
Indian Point's Independent Spent Fuel Storage Installation, and drain the spent fuel pool by
December 31, 2008, thereby essentially terminating the source of groundwater contamination
from that location. Notwithstanding, it is expected that some water will remain on the bottom of
the pool to reduce the potential for airbor
ne contamination, provide shielding, and facilitate the removal of the sediment in early 2009. We understand that Entergy will promptly inform the NRC of any condition that could potentially impact or delay this commitment. Additionally, we
understand that Entergy will inco
rporate the im
plementation requirements of its Long Term Monitoring Program (LTMP) as regulatory specifications in the Indian Point Energy Center's
(IPEC) Off-site Dose Calculation Manual, thereby a
ssuring that the LTMP will be regarded as an extension of the Radiological Effluents Technical Specifications and Radiological Environmental
Monitoring Program, which are subject to NRC inspection. During the Exit Meeting on May 7,
Entergy agreed to document these commitments to the NRC by May 20, 2008. Please inform us
if our understanding is not correct.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public ins
pection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC
=s document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Further, in light of ongoing public interest in these matters, the NRC has scheduled a public meeting in Cortland, New York on May 20,
2008, as announced by our Meeting Notice dated May 10, 2008, also available at the NRC web
site at http://www.nrc.gov/reactors.plant-specific-items/Indian-point-issues.html , to discuss NRC's assessment of Entergy's performance and actions to address the groundwater conditions
at Indian Point, and the associated impact on public health and safety of the environment.
Sincerely, /RA/
Marsha K. Gamberoni, Director
Division of Reactor Safety
Docket Nos: 50-003, 50-247
Enclosure: Inspection Report Nos. 05000003/2007010, 05000247/2007010 w/Attachment: Supplemental Information
J. Pollock 2 adversely affected, and the dose consequence to the public that can be attributed to current
on-site conditions associated with groundwater contamination is negligible. No significant
findings were identified. However, one minor violation with respect to quality control of
groundwater sampling is discussed in this report. This violation is not subject to enforcement
action in accordance with Section IV of the NRC Enforcement Policy. The NRC plans no further
action with regard to this matter; and no response to this letter is required.
Based on a telephone discussion between Messrs. John McCann, Director of Licensing, and
Samuel Collins, NRC Region I R
egional Administrato
r, on April 21, 2008, we understand that Entergy has committed to remove and transfer all spent fuel from the Unit 1 Spent Fuel Pool to
Indian Point's Independent Spent Fuel Storage Installation, and drain the spent fuel pool by
December 31, 2008, thereby essentially terminating the source of groundwater contamination
from that location. Notwithstanding, it is expected that some water will remain on the bottom of
the pool to reduce the potential for airbor
ne contamination, provide shielding, and facilitate the removal of the sediment in early 2009. We understand that Entergy will promptly inform the NRC of any condition that could potentially impact or delay this commitment. Additionally, we
understand that Entergy will inco
rporate the im
plementation requirements of its Long Term Monitoring Program (LTMP) as regulatory specifications in the Indian Point Energy Center's
(IPEC) Off-site Dose Calculation Manual, thereby a
ssuring that the LTMP will be regarded as an extension of the Radiological Effluents Technical Specifications and Radiological Environmental
Monitoring Program, which are subject to NRC inspection. During the Exit Meeting on May 7,
Entergy agreed to document these commitments to the NRC by May 20, 2008. Please inform us
if our understanding is not correct.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public ins
pection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC
=s document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Further, in light of ongoing public interest in these matters, the NRC has scheduled a public meeting in Cortland, New York on May 20,
2008, as announced by our Meeting Notice dated May 10, 2008, also available at the NRC web
site at http://www.nrc.gov/reactors.plant-specific-items/Indian-point-issues.html , to discuss NRC's assessment of Entergy's performance and actions to address the groundwater conditions
at Indian Point, and the associated impact on public health and safety of the environment.
Sincerely, /RA/ Marsha K. Gamberoni, Director
Division of Reactor Safety
SUNSI Review Complete: JDN (Reviewer
=s Initials) ADAMS ACCESSION NO. ML081340425 DOCUMENT NAME: G:\DRS\Plant Support Branch 2\Noggle\IP 22007010 Rev5Final.doc After declaring this document
AAn Official Agency Record
@ it will be released to the Public. To receive a copy of this document, indicate in the box:
" C" = Copy without attachment/enclosure " E" = Copy with attachment/enclosure " N" = No copy
OFFICE RI/DRS RI/DRS RI/DRP HQ/FSME via email
HQ/NRR NAME JNoggle/JDN*
JWhite//JW*
ECobey/ DJ for
TSmith//JW for*
SGarry/via telephone
DATE 04/25/08 05/12/08 05/06 /08
05/12/08 05/05/08 OFFICE HQ/NRR RI/ORA RI/DRS RI/DNMS HQ/RES/via email
NAME JBoska/via email
DHolody/RJS for*
MGamberoni/MKG
RLorson/RL*
TNicholson/JW for:*
DATE 04/29/08 05/02/08 05/13/08 05/12/08 05/1208 * See Previous Concurrence Page OFFICIAL RECORD COPY
J. Pollock 3
cc w/encl: Senior Vice President, Entergy Nuclear Operations
Vice President, Operations, Entergy Nuclear Operations
Vice President, Oversight, Entergy Nuclear Operations
Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations
Senior Vice President and CCO, Entergy Nuclear Operations
Assistant General Counsel, Entergy Nuclear Operations
Manager, Licensing, Entergy Nuclear Operations
P. Tonko, President and CEO, New York State Energy Research and Development Authority
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
A. Donahue, Mayor, Village of Buchanan
J. G. Testa, Mayor, City of Peekskill
R. Albanese, Four County Coordinator
S. Lousteau, Treasury Department, Entergy Services, Inc.
Chairman, Standing Committee on Energy, NYS Assembly
Chairman, Standing Committee on Environmental Conservation, NYS Assembly
Chairman, Committee on Corporations, Authorities, and Commissions
M. Slobodien, Director, Emergency Planning
P. Eddy, NYS Department of Public Service
Assemblywoman Sandra Galef, NYS Assembly
T. Seckerson, County Clerk, Westchester County Board of Legislators
A. Spano, Westchester County Executive
R. Bondi, Putnam County Executive
C. Vanderhoef, Rockland County Executive
E. A. Diana, Orange County Executive
T. Judson, Central NY Citizens Awareness Network
M. Elie, Citizens Awareness Network
D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists
Public Citizen's Critical Mass Energy Project
M. Mariotte, Nuclear Information & Resources Service
F. Zalcman, Pace Law School, Energy Project
L. Puglisi, Supervisor, Town of Cortlandt
Congressman John Hall
Congresswoman Nita Lowey
Senator Hillary Rodham Clinton
Senator Charles Schumer
G. Shapiro, Senator Clinton's Staff
J. Riccio, Greenpeace
P. Musegaas, Riverkeeper, Inc.
M. Kaplowitz, Chairman of County Environment & Health Committee
A. Reynolds, Environmental Advocates
D. Katz, Executive Director, Citizens Awareness Network
S. Tanzer, The Nuclear Control Institute
K. Coplan, Pace Environmental Litigation Clinic
M. Jacobs, IPSEC
W. Little, Associate Attorney, NYSDEC
M. J. Greene, Clearwater, Inc.
R. Christman, Manager Training and Development
J. Spath, New York State Energy Research, SLO Designee
A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
J. Pollock 4
Docket Nos: 50-003, 50-247
Enclosure: Inspection Report Nos. 05000003/2007010, 05000247/2007010
w/Attachment: Supplemental Information
Distribution w/encl
- S. Collins, RA
M. Dapas, DRA
S. Williams, RI OEDO (Acting)
R. Nelson, NRR
M. Kowal, NRR
T. Smith, FSME
J. Hughey, NRR
R. Lorson, NMSS
E. Cobey, DRP
D. Jackson, DRP
B. Welling, DRP
T. Wingfield, DRP
P. Cataldo, DRP, Senior Resident Inspector - Indian Point 3
M. Marshfield, DRP, Senior Resident Inspector - Indian Point 2 (Acting)
C. Hott, DRP, Senior Resident
Inspector - Indian Point 2 T. Koonce, Resident Inspector - Indian Point 3 (Acting)
Region I Docket Room (w/concurrences)
ROPreports@nrc.gov
D. Holody, ORA, RI
R. Summers, ORA, RI
K. Farrar, ORA, RI
A. DeFrancisco, ORA, RI
C. O'Daniell, ORA, RI
M. Gamberoni, DRS
D. Roberts, DRS
J. White, DRS
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.50-003, 50-247
Report Nos. 05000003/2007010 and 05000247/2007010
Licensee: Entergy Nuclear Northeast
Facility: Indian Poin
t Nuclear Gener
ating Stat
ion Units 1 & 2
Location: 295 Broadway Buchanan, NY 10511-0308
Dates: November 7, 2007 - May 7, 2008
Inspectors: J. Noggle, Sr. Health Physicist, CHP, team leader T. Nicholson, Sr. Technical Advisor for Radionuclide Transport
J. Williams, U.S. Geological Survey, Troy, New York
J. Kottan, State Agreements Officer
J. Commiskey, Health Physicist
Approved by: John R. White, Chief Plant Support Branch 2
Division of Reactor Safety
TABLE OF CONTENTS
Page SUMMARY OF FINDINGS------------------------------.iii
EXECUTIVE SUMMARY------------------------------...iv
4.0 OTHER ACTIVITIES (OA)---------------------------.1 4OA5 Other Activities----------------------------...1 .1 Overview of the Groundwater Contamination Investigation----------1 .2 Final Groundwater Contamination Characterization-------------.3 .3 Groundwater
Sampling------------------------.....4 .4 Dose Assessment---------------------------..7
.5A Unit 2
SFP Leak age--------------------
9 .5B Unit 1
SFP Leak age--------------------------.
11 .6 Hydrogeologic Investigations----------------------.13 .7 Prior Indications of On-site Groundwater Tritium Contamination-------.17 .8 Remediation and Long Term Monitori
ng Plans--------------..19 .9 Regulatory Requirements----------------------.......21 4OA6 Meetings, including Exit------------------------..24
Figure 1: Long Term Monitoring Plan
Figure 2: Unit 1 Building Foundation Drain System
Figure 3: Observed Bedding and Conjugate Fractures in Verplanck Quarry
Figure 4: Downhole Flow Meter and Geophysical Survey
Figure 5: Unit 2 Spent Fuel Pool Tritium Plume Cross Section
Attachment 1: Indian Point Contaminated Groundwater Investigation Time Line
Attachment 2: Site Groundwater Contaminant Concentrations
Attachment 3: Supplemental Information
ii
SUMMARY OF FINDINGS
IR 05000247/2007010 & IR 05000003/2007010; 11/08/2007 - 05/07/2008; Indian Point Nuclear
Generating Station Units 1 & 2; Other Activities - associated with ROP deviation memorandum.
The report covers an inspection of a September 1, 2005, licensee-identified Unit 2 spent fuel
pool leak investigation final report and long term monitoring plan; and review of historical
leakage involving the Unit 1 spent fuel pool by three regional inspectors, one headquarters
hydrology specialist, and a U.S. Geological Survey hydrology specialist. The NRC
=s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, AReactor Oversight Process," Revision 4, dated December 2006.
A. NRC - Identified and Self-Revealing Findings
No findings of significance were identified.
B. Licensee - Identified Violations
None
iii
EXECUTIVE SUMMARY
Background:
On September 1, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent fuel pool wall had been discovered during excavation work, and that low levels of radioactive
contamination were found in water leaking from the cracks having radionuclides similar to Unit 2
spent fuel pool water. Entergy initiated a prompt investigation to determine the extent of the
condition and potential impact on health and safety. Initially, Entergy determined that on-site
groundwater in the vicinity of the Unit 2 facility was contaminated with
tritium as high as 200,000 picocuries per liter of water (about ten times the EPA drinking water standard). Subsequently,
Entergy initiated actions to perform a comprehensive groundwater site characterization to
investigate the extent of on-site groundwater contamination, identify the sources, and mitigate
and remediate the condition. This effort required the establishment of several on-site
groundwater monitoring wells to characterize groundwater behavior, flow, direction, and
migration pathways.
On September 20, 2005, Region I initiated a special inspection of this matter to examine the
licensee's performance and determine if the contaminated groundwater effected, or could effect,
public health and safety. On October 31, 2005, NRC's Executive Director of Operations (EDO)
authorized continuing NRC inspection to assess licensee performance of on-site groundwater
investigation activities, and independently evaluate and analyze data and samples to assure the
effectiveness and adequacy of the licensee's efforts. Throughout this effort, the NRC
coordinated its inspection activities with the New York State Department of Environmental
Conservation (DEC), which initiated its own independent assessment of the groundwater
conditions, including observation of NRC's inspection activities.
The NRC issued a special inspection report on March 16, 2006 (ADAMS Accession No.
ML060750842). The report assessed Entergy's performance, achievements, and plans relative
to radiological and hydrological site characterization; and reported that the on-site groundwater
contamination did not, nor was likely to, adversely affect public health and safety. In the report
and in subsequent public meetings, NRC indicated that it would continue to inspect licensee
performance in this area, including independent evaluation and analysis of data, to assure that
Entergy continued to conform to regulatory requirements, and that public health and safety was
maintained.
On March 21, 2006, NRC's independent on-site groundwater sample analysis effort first
determined that strontium-90 was also a contaminant in the groundwater, a fact that was
subsequently confirmed by Entergy and the DEC. This determination resulted in a significant
expansion of the on-site groundwater characterization effort since the source of the strontium-90
contaminant was traced to leakage from the Unit 1 Spent Fuel Pool. A full site-wide
hydrogeologic investigation was subsequently scoped to include Unit 1 and Unit 3. The NRC
inspection charter objectives were similarly revised to provide the necessary oversight. Off-site
groundwater samples have also been obtained since the fall of 2005, and have never detected
any off-site groundwater contamination.
iv
Enclosure
Since that time, the NRC has continued to inspect and monitor Entergy's activities beyond the
limits of normal baseline inspection, as authorized by NRC's Executive Director of Operations
(EDO). During this period, NRC inspectors closely monitored Entergy's groundwater
characterization efforts, and performed independent inspection of radiological and hydrological
conditions affecting on-site groundwater. Additionally, from early 2006 through January 2008,
the NRC kept interested Federal, State, and Local government stakeholders informed of current
conditions through routine bi-weekly teleconferences.
Status of Current Activities, Plans, and Inspection Results:
On January 11, 2008, Entergy submitted the results of its comprehensive ground water
investigation, and included its plan for remediation and long-term monitoring of the on-site
groundwater conditions. In its report, Entergy described the sources of the groundwater
contamination to be the Unit 1 and Unit 2 spent fuel pools. While both pools contributed to the
tritium contamination of groundwater, leakage from the Unit 1 spent fuel pool was determined to
be the source of other contaminants such as strontium-90, cesium-137, and nickel-63. Entergy
identified its plan to remove all fuel from the Unit 1 spent fuel pool to an on-site storage location
and drain the spent fuel pool system by the end of 2008, thereby essentially eliminating the
source of the groundwat
er contamination from that facility. Some water is expected
to remain in the bottom of the pool to reduce the potential for airborne contamination and provide shielding
until the residual sludge is removed in early 2009. In the January 11, 2008 report, Entergy
described its actions to repair or mitigate all identified potential leak locations in the Unit 2 spent
fuel pool system that may have contributed to the on-site tritium-contaminated groundwater in
the vicinity of that facility.
Notwithstanding, residual radioactivity is expected to continue to impact on-site groundwater for
the duration of licensed activities. On-site groundwater is
expected to continue to be monitored and reported as an abnormal liquid release in accordance with NRC regulatory requirements.
No off-site groundwater has been impacted, since the on-site groundwater flow is to the
discharge canal and the Hudson River. Accordingly, the licensee has established a long-term
monitoring strategy for the purpose of evaluating the effect and progress of the natural
attenuation of residual contamination, informing and confirming groundwater behavior as
currently indicated by the existing site conceptual model, and determining changes in conditions
that may be indicative of new or additional leakage.
Entergy's performance and effectiveness relative to successfully draining water from the Unit 1
spent fuel pool system by the end of 2008, and the quality and effectiveness of its long-term
monitoring program, will be the immediate focus of NRC's continuing inspection of Entergy's performance and conformance with regulatory requirements relative to the existing groundwater
conditions. Additionally, NRC will continue to inspect the efficacy of the licensee's long-term monitoring program as part of the Reactor Oversight Process pertaining to radiological
environmental and effluents inspection activities.
Notwithstanding, radiological significance from the groundwater conditions at Indian Point is
currently, and is expected to remain negligible with respect to impact on public health and safety
and the environment. NRC has confirmed with the New York State Department of Health, that
drinking water is not derived from groundwater or the Hudson River in the areas surrounding or
v
Enclosure
influenced by effluent release from Indian Point. Accordingly, the only human exposure pathway
of merit is from the possible consumption of aquatic foods from the Hudson River, such as fish
and invertebrates. Dose assessment of the potential for exposure from this pathway, continues
to indicate that the hypothetical maximally exposed individual would be subject to no more than
a very small fraction of the NRC regulatory limit for liquid radiological effluent release.
Status of Current Inspection Results:
1. Upon the initial identification of conditions that provided evidence of an abnormal radiological effluent release affecting ground water, the licensee implemented actions
that conformed to the radiological survey requirements of 10 CFR 20.1501 to ensure
compliance with dose limits for individual members of the public as specified in 10 CFR
20.1302, including: (1) promptly investigating and evaluating the radiological conditions
and potential hazards affecting groundwater conditions, on- and off-site; (2) annually
reporting the condition, and determining that the calculated hypothetical dose to the
maximally exposed member of the public was well below established NRC regulatory
requirements for liquid radiological release; (3) confirming, through off-site
environmental sampling and analyses, that plant-related radioactivity was not
distinguishable from background; (4) initiating appropriate actions to mitigate and
remediate the conditions to assure that NRC regulatory dose limits to members of the
public and the environment were not exceeded; and (5) developing the bases for a long-
term monitoring program to ensure continuing assessment of groundwater effluent
release and reporting of the residual radioactivity affecting the groundwater. Additional
refinement of the long term monitoring program is expected to occur as data is collected
and evaluated to verify and validate the effectiveness of expected natural attenuation of
the existing groundwater plumes, and to ensure the timely detection of new or additional
leakage affecting ground water.
2. The determination of contaminated on-site groundwater conditions at Indian Point was the result of the licensee's investigation of potential leakage from the Unit 2 Spent Fuel
Pool initiated in September 2005, and subsequent development and application of a
series of ground water monitoring wells to determine the extent of that condition. No
evidence was found that indicated that the events at Indian Point, that resulted in the on-
site groundwater contamination (identified to the NRC on September 1, 2005), were the
result of the licensee's failure to meet a regulatory requirement or standard, where the
cause of the condition was reasonably within the licensee's ability to fores
ee and correct, and should have been prevented. This determination is based on: interviews with
licensee personnel; comprehensive review of pertinent documentation, including
previous condition reports, survey records, radiological liquid effluent and environmental
monitoring reports, records of
historical spills and leaks documented in accordance with 10 CFR 50.75, "Reporting and Recordkeeping for Decommissioning Planning"; and
extensive on-site NRC inspection to confirm licensee conformance with required
regulatory requirements.
3. The current contaminated groundwater conditions at Indian Point Energy Center are the result of leakage associated with the Unit 1 and Unit 2 spent fuel pool (SFP) systems.
No other systems, structures, or components were identified as contributors to the
continuing on-site contamination of ground water.
vi
Enclosure
4. Entergy's hydrogeologic site characterization studies provided sufficiently detailed field observations, monitoring, and test data which supported the development and
confirmation of a reasonable conceptual site model of groundwater flow and transport
behavior. An independent analysis of groundwater transport through fractured bedrock
utilizing geophysical well logging data was conducted by the U.S. Geological Survey (USGS). The USGS assessment corroborated the groundwater transport characteristics
that were determined by Entergy's contractor.
5. Entergy's hydrogeologic site characterization and developed conceptual site model provide a reasonable basis to support the determination that the liquid effluent releases
from the affected spent fuel pool systems migrate in the subsurface to the west, and
partially discharge to the site's discharge canal, with the remainder moving to the Hudson
River. Current data and information indicates that contaminated groundwater from the
site does not migrate off-site except to the Hudson River. This conceptual site model of
groundwater behavior and flow characteristics is supported by the results of independent
groundwater sampling and analyses conducted by NRC, which have not detected any
radioactivity distinguishable from background in the established on-site boundary
monitoring well locations, or in various off-site environmental monitoring locations.
6. Currently, there is no drinking water exposure pathway to humans that is affected by the contaminated groundwater conditions at Indian Point Energy Center. Potable water
sources in the area of concern are not presently derived from groundwater sources or the
Hudson River, a fact confirmed by the New York State Department of Health. The
principal exposure pathway to humans is from the assumed consumption of aquatic
foods (i.e., fish or invertebrates) taken from the Hudson River in the vicinity of Indian
Point that has the potential to be affected by radiological effluent releases.
Notwithstanding, no radioactivity distinguishable from background was detected during
the most recent sampling and analysis of fish and crabs taken from the affected portion
of the Hudson River and designated control locations.
7. The annual calculated exposure to the maximum exposed hypothetical individual, based on application of Regulatory Guide 1.109, "Calculation of Annual Doses to Man from
Routine Release of Reactor Effluents for the Purpose of Evaluation Compliance with 10
CFR Part 50, Appendix I," relative to the liquid effluent aquatic food exposure pathway is
currently, and expected to remain, less than 0.1 % of the NRC's "As Low As is
Reasonably Achievable (ALARA)" guidelines of Appendix I of Part 50 (3 mrem/yr total
body and 10 mrem/yr maximum organ), which is considered to be negligible with respect
to public health and safety, and the environment.
8. All identified liner flaws in the Unit 2 spent fuel pool, and the initially identified crack affecting the Unit 2 spent fuel pool system have been repaired or mitigated. However,
not all Unit 2 fuel pool surfaces are accessible for examination. No measurable leakage
is discernable from evaporative losses based on Unit 2 fuel pool water makeup inventory
data. Unit 1 spent fuel pool water is being processed continuously to reduce the
radioactive concentration at the source prior to leakage into the groundwater, and actions
have been initiated to effect the complete removal of spent fuel and essentially all the
water from the Unit 1 Spent Fuel Pool system by the end of 2008, thereby terminating the
source of 99.9% of the dose significant strontium-90 and nickel-63 contaminants (the
remaining 0.1% is represented by the Unit 2 and Unit 1 hydrogen-3 (tritium)
contaminants). Entergy's selected remediation approach for the contaminated
groundwater conditions appears reasonable and commensurate with the present
radiological risk.
vii
Enclosure
9. The historical duration of leakage from the Unit 1 and Unit 2 spent fuel pool systems that resulted in groundwater contamination is indeterminate. The evidence indicates that the
volume of leakage was small compared to the available water inventory, and was much
less than the normally expected evaporative losses from spent fuel pools. This
conclusion is based on NRC staff review and assessment of spent fuel pool makeup
inventory records and applicable leakage collection data, the results of the continuously
implemented Radiological Environmental Monitoring Program affecting the Indian Point
site, and evaluation of the developed hydrogeologic groundwater transport model.
Accordingly, there is no evidence of any significant leak or loss of radioactive water
inventory from the site that was discernable in the off-site environment.
10. No releases were observed or detected from Unit 3.
11. The conditions surrounding the leaking Unit 1 spent fuel pool are based on a leakage rate of 10 drops per second (about 25 gallons per day) that was identified in 1992. At
that time, the licensee performed a hypothetical bounding dose impact that concluded
that there was negligible dose impact to the public caused by this condition. This
licensee assessment was inspected and evaluated, at that time, by NRC inspectors.
This early bounding hypothetical calculation agrees with the dose impact now confirmed
by the recently completed hydrogeologic site investigation, and NRC's independent
assessment. Based on extensive review of the circumstances and inspection records
from that period, it appears that the licensee was in conformance with the standards,
policy, and regulatory requirements that prevailed at that time.
viii
REPORT DETAILS 4.0 OTHER ACTIVITIES (OA) 4OA5 Other Activities
.1 Overview of the Groundwater Contamination Investigation
In September 2005, a crack was discovered leaking on the outside of the Unit 2 spent fuel
pool south wall (approximately 30 feet below the top) during excavation of the spent fuel
building loading bay. The NRC initiated a special inspection on September 21, 2005, to
investigate the implications of the observed Unit 2 spent fuel pool leakage. Based on
analysis of the radionuclide concentrations in the Unit 2 spent fuel pool and maximum
bounding pool makeup losses, a bounding dose calculation based on direct release to the
Hudson River indicated a tiny fraction of 1 mrem (0.00002 mrem/yr) as the estimated dose
to the maximally exposed hypothetical individual. Though the radiological significance of
the circumstance was negligible, the condition was unexpected. Accordingly, NRC Region
I was authorized by the Executive Director of Operations (EDO) to conduct additional
oversight inspection of licensee performance and the circumstances surrounding this
contamination issue to better understand the condition and examine possible generic
implications, since similar conditions had been identified at other facilities.
Due to the complicated nature of the groundwater characterization effort at Indian Point
(i.e., a relatively small site containing two operating units and one unit in SAFSTOR, built
on a complex fractured bedrock foundation that required sophisticated analysis and
modeling to fully understand groundwater behavior), the EDO renewed the increased
inspection authorization each year to permit active and frequent inspection oversight. As a
result, inspection of the Indian Point contaminated groundwater conditions evolved to
include not only radiological environmental and effluent expertise from Region I, but also
hydrological assessment expertise from NRC's Office of Research, and later, from the US
Geological Survey (USGS). The application of such resources permitted the NRC to
conduct several independent reviews and assessments of data, information, and analysis
on which the licensee based its conclusions and determinations.
In addition, the NRC and USGS specialists, worked closely with the New York State
Department of Environmental Conservations (NYS DEC) by sharing data and assessment
information, coordinating independent split sampling of various sample media, and
providing a combined oversight of licensee performance.
On November 7, 2005, the lic
ensee began installing a series of monitoring wells on-site, based on an initial understanding of on-site groundwater flow patterns and associated
contaminant transport. Thirty-six monitoring wells were installed over the next 2 years,
with the final well installed and operational by the end of August 2007. The groundwater
monitoring network ultimately developed by Entergy includes these plus a number of
previously existing monitoring locations. Various geophysical evaluations and analyses,
including groundw
ater table mappi
ng, ground permeability measurements and groundwater gradient calculations, were performed and two site-wide hydrology tests were
Enclosure
2 conducted to observe groundwater response in a network of monitoring wells. These tests
included a 3-day duration groundwater pump-down test from the Unit 2 spent fuel pool
(SFP) leak location, and injection of a tracer dye at the base of the Unit 2 SFP to trace its
path across the site.
This body of information was utilized by Entergy to determine the sources of the groundwater contamination, evaluate the potential for leak mitigation through pumping,
and confirm the site groundwater transport model through a final tracer test. Throughout
the investigation frequent iterations were made to refine the extent of groundwater
contamination, the total amount of contaminant released to the environment, and the
resulting public dose assessment to ensure that public health and safety were maintained.
As additional wells were drill
ed and sampled, gradually the full extent of on-site ground water contamination was revealed. A short synopsis providing the significant highlights of
the licensee's investigation follows, with a more detailed timeline provided in Attachment 1,
"Timeline Synopsis".
On February 27, 2006, hydrogen-3 (tritium) contamination was detected in a monitoring
well beyond the discharge canal, providing the first evidence of potentially contaminated
groundwater being directly released into the Hudson River. On February 28, 2006, the
licensee developed a new groundwater release bounding calculation methodology based
on an overall site rainfall recharge into several discrete site drainage areas to the Hudson
River. On March 21, 2006, radionuclides other than tritium (strontium-90 and nickel-63)
were first discovered in a monitoring well, which was later determined to be associated
with the Unit 1 spent fuel pool system.
On April 24, 2006, utilizing a rainfall recharge water mass balance
approach to calculate groundwater flow and more recent monitoring well data utilizing the maximum concentrations of hydrogen-3 (tritium), strontium-90, and nickel-63, a new revised public
dose estimate (from the hypothetical consumption of fish) indicated a maximum
hypothetical public dose of 0.0025 mrem/yr to the total body and a maximum of 0.011
mrem/yr to the highest organ (adult bone). These values represent about 0.1% of the
regulatory specification for liquid effluent releases contained in the Offsite Dose
Calculation Manual. This specification is derived from 10CFR50, Appendix I, As Low As is
Reasonably Achievable (ALARA) design objectives for liquid effluent releases.
The basis for calculating public doses is site specific, and at Indian Point, is based on the
hypothetical, assumed consumption of fresh water fish and salt water invertebrates. Due
to a higher dose significance of strontium-90 detected in groundwater releases, Entergy
revised its Off-site Dose Calculation Manual (ODCM) to include the analysis of strontium-
90 in environmental media, such as fish and invertebrates collected from the Hudson
River. Consumption of fish was assumed notwithstanding the fact that the New York State
Department of Health publishes health advisories for sport and game fish and
recommends very limited or no consumption of fish be taken from the lower reaches of the
Hudson River due to mercury and Poly-Chlorinated Biphenyls (PCB) contaminants.
Enclosure
3 Subsequently, during the summer of 2006, Entergy collected and analyzed fish from the
Hudson River, and strontium-90 was identified in one fish collected near the plant as well
as in several fish caught in a control location 20 miles upstream of the plant at similar
concentrations. In order to resolve whether the strontium-90 was plant-related or the result
of existing background levels (Sr-90 exists in environment due to weapons-related fallout),
an expanded fish sampling program was devised by the New York State DEC. The
program included an additional 90 mile upstream sample location, the collection of specific
fish species identified by the State's biologist as having limited migratory behavior, and a
three-way split of the edible fish portions of the prepared samples between NRC, Entergy,
and the NYS DEC. The effort was conducted in June 2007. In the expanded samples, all
three independent analytical laboratories reported results that indicated that no plant-
related radioactivity was detected or distinguishable from background. To date, no offsite
environmental samples (other than water samples from the discharge canal and the tidally
influenced intake structure) have indicated any detectable plant-related radionuclides, The USGS performed an independent fracture flow analysis to determine on-site
groundwater flow utilizing different data and methods than Entergy to compare groundwater flow results with the licensee. This provided a comparison of fracture flow
dominated groundwater flow with the licensee's groundwater flow results based on an
assumption of general porous media flow through dense fracture sets in the ground. No
significant differences were observed from these comparisons, which essentially confirmed
that either model of groundwater transport flow provided valid results.
On January 11, 2008, Entergy submitted a hydrogeologic site investigation final report to
the NRC documenting closure of the groundwater investigation, adoption of selected
remediation actions, and a plan for the continued long-term monitoring of the existing
contaminant plumes (ADAMS Accession No. ML080320600). On January 25, 2008,
Entergy submitted a synopsis of the long term monitoring plan basis to describe a
groundwater monitoring network and a sampling schedule to continue monitoring the
existing plumes, detect any future Unit 2 spent fuel pool leaks, and detect any future leaks
from any other plant systems structures or components at the site (ADAMS Accession No.
This inspection report provides NRC review of the above mentioned licensee activities.
Continued NRC inspection will c
ontinue through 2008 of the removal of spent fuel and draining of the leaking Unit 1 spent fuel pool, split sampling to verify the basis of licensee's
off-site dose assessment, and review of further development and refinements to the
licensee's long term monitoring plan. Inspection findings will be documented in future reports. .2 Final Groundwater Contamination Characterization
By the end of 2007, based on over 900 monitoring well samples, the extent of the on-site
subsurface contamination had been mapped and the sources have been determined. Two
on-site plumes were discovered emanating from the Unit 2 and Unit 1 spent fuel pool
regions, respectively. Due to the influence of the Unit 1 building foundation drain system,
some of the Unit 2 plume was drawn into the Unit 1 area, with both plumes intermingling
Enclosure
4 and following a converging path westward towards the Hudson River. Both plumes were
relatively shallow (less than 200 feet below ground surface) following a common
groundwater trough between Units 1 and 2, and a groundwater transport velocity of
between 4 and 9 feet per day, covering a total distance of about 400 feet to the Hudson
River (see Figure 1). Approximately one-half of the combined plumes are being
intercepted by the plant discharge canal which allows for substantial dilution of this fraction
and is a monitored discharge path. The other portion of the combined plumes flows below
the discharge canal and discharges directly into the bottom of the Hudson River.
Due to limited groundwater sampling of the new river front monitoring wells across normal
seasonal groundwater flow variations, no trend in plume concentrations is yet discernable.
Current contaminant concentrations detected from monitoring wells closest to the Hudson
River indicate 9,000 pCi/L of hydrogen-3 (tritium) and 27 pCi/L of strontium-90. A map of
monitoring well locations and a table of radionuclide concentration values at each
monitoring well are provided in Attachment 2.
These concentrations are slightly below the minimum required effluent release detection
sensitivities for these radionuclides (i.e., 10,000 pCi/L for hydrogen-3 (tritium) and 50 pCi/L
for strontium-90), and well below the maximum allowable liquid effluent release ALARA
guidelines of ten times the effluent concentrations in 10 CFR 20, Appendix B, Table 2,
Column 2 (10,000,000 pCi/L for hydrogen-3 (tritium) and 5,000 pCi/L for strontium-90).
NRC required calculation of the maximum dose to a hypothetical person consuming fish
and invertebrates at the site boundary, indicates less than 0.1% of design objectives for
liquid effluents (3 mrem total body and 10 mrem maximum organ). Since the groundwater
contamination is considered an abnormal release, the condition is required to be
quantified, evaluated and reported in the annual radiological effluent release reports.
.3 Groundwater Sampling
a. Inspection Scope
During the licensee's groundwater investigation, over 900 groundwater samples were
collected and analyzed from the established on-site monitoring well network by the end of
2007. The analytical results provide the basis for assessing the extent of the groundwater
plume and for performing calculations of offsite doses to members of the public. In order
to assess 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 southern boundary
wells and those bordering the Hudson River that were utilized in effluent release and dose assessment calculations. Sample identity was assured by chain-of-custody procedures
that included sample collection observation by the NRC or a representative of the NYS
DEC. The NRC samples were analyzed by an independent government laboratory. The
NRC samples were sent to the NRC contract laboratory, the Oak Ridge Institute for
Science and Education (ORISE), Environmental Site Survey and Assessment Program
(ESSAP) radioanalytical laboratory.
Enclosure
5 By the end of 2007, over 250 split groundwater samples were obtained to provide an
independent check of Entergy's analytical results and to independently verify if there was
any detectable migration of groundwater contaminants offsite. These split samples
represent over 1,000 analyses, primarily for hydrogen-3 (tritium), strontium-90, nickel-63,
and gamma-emitting radionuclides that characterized the effluent releases. Analyses for
other radionuclides were performed, but none were detected.
Various in-plant contamination sources (the Unit 1 and 2 spent fuel pools and others) were
also sampled and analyzed by the NRC for a complete range of radionuclides to evaluate
the known and potential leaking sources of radioactivity, and to ensure an adequate scope
of radionuclide analysis was conducted by the licensee in their groundwater sampling
campaign. In addition, the NRC analyzed miscellaneous environmental samples of
interest including offsite water supply sources, Hudson River aquatic vegetation, and fish
samples. The New York State DEC also provided confirmation of the licensee's sample
analysis results through a parallel split sample program. This provided for a three-way
laboratory comparison of many of the offsite release and environment-critical sample
results. This three-way data comparison provided for timely identification of any discrepant
sample results potentially affecting offsite releases.
b. Findings and Assessment
No findings of significance were identified.
In general, Entergy
=s groundwater measurements of radioactivity were of good quality and of sufficient sensitivity to assess radiological impact. The quality of Entergy
=s measurements were confirmed by various split samples analyzed by NRC and the State of New York, (i.e., the Department of Environmental Conservation and the Department of
Health). Of the over 1000 results that were reviewed, there were some sample
disagreements based on the statistical comparison criteria specified in NRC Inspection
Procedure 84750, "Radioactive Waste Treatment, and Effluent and Environmental
Monitoring." A discussion of the sample disagreements is provided below.
- Between March and September 18, 2006, Entergy reported some strontium-90 results associated with the Unit 1 plume that were low when compared to NRC
results. Entergy's results indicated that the Unit 1 spent fuel pool cleanup system
had shown a reduction in the associated groundwater plume concentrations over
a relatively short period of time. There was no other consequence due to this
disparity. Entergy initiated an investigation into this issue with their offsite
contract laboratory. The investigation did not identify a definitive cause. As a
result, Entergy terminated its contract with the lab and procured the services of
another offsite laboratory. Entergy's reanalysis of the samples confirmed that the
original results were low. The reanalysis results were subsequently in agreement
with the NRC laboratory results.
- Entergy reported no detectable nickel-63 contamination in four samples from Monitoring Well-42 taken on November 16-17, 2006. Since Monitoring Well-42 is
closest to the Unit 1 SFP, and other radionuclides analyzed at the same location
remained at expected levels, this indication was not considered reasonable and
Enclosure
6 was also not in agreement with the New York State or NRC laboratory results.
This resulted in an investigation into this issue by the licensee's new off-site
contract laboratory. Improper procedure protocol was identified and additional
controls were implemented to correct this issue. Reanalysis of the nickel-63
results were in agreement with the NRC laboratory results. No other significant
sample anomalies were identified by the NRC through the end of 2007.
The above NRC-identified discrepancies highlighted the need for quality control in the
licensee's sample acquisition and laboratory processing and measurement processes.
Oversight of offsite laboratory analysis of samples was not originally specified by the
licensee for on-site groundwater sampling. NRC radiological environmental monitoring
program laboratory quality control requirements, specify radionuclide detection
sensitivities, and require blind blank samples and blind radionuclide-spiked samples to
be provided by the licensee as a check on the off-site laboratory's analytical
performance. These requirements apply to the offsite radiological environmental
monitoring program, but no requirements are specified for on-site groundwater sample
quality controls.
NRC radiological effluent sampling analyses also require laboratory quality controls as
specified above. On February 27, 2006, based on detecting hydrogen-3 (tritium) in a
monitoring well near the Hudson River, Entergy revised their bounding dose calculation
and began calculating actual effluent releases via the groundwater pathway. At this
point in the groundwater investigation, the quality assurance of groundwater sample
analyses used in effluent reporting became a requirement. However, the offsite
laboratory analyses of groundwater samples were not independently evaluated by
Entergy until more than one year later. Technical Specifications Section 5.4.1(a)
specifies written procedures shall be established, implemented, and maintained covering
Appendix A of Regulatory Guide 1.33, Revision 2, which specifies quality assurance
requirements for procedures associated with the control of radioactive effluents released
to the environment. The inadequate procedure (O-CY-1420, Rev. 1), constitutes a
violation of minor significance that is not subject to enforcement action in accordance
with Section IV of the NRC Enforcement Policy. There was no actual or potential
consequence of this procedure deficiency, because in function, the NRC and NYS DEC
split sampling program provided a very effective verification of Entergy's laboratory
sample analysis program during the groundwater investigation by assuring the accuracy
of analytical results.
To address this concern, in May 2007, Entergy initiated an on-site groundwater sampling
quality control program incorporating a blind blank sample and blind radionuclide-spiked
sample program to verify its own offsite laboratory analytical results. In addition,
Entergy's corrective action
program is still addressing the quality
control program requirements relative to groundwater sample analysis, with corrective action
responsibilities transfe
rred to the corporate group for resoluti
on (CR-HQN-
2007-00894). NRC split sample analysis comparison of the licensee's groundwater sample results are
expected to continue until such time as Entergy has addressed all of the concerns
associated with laboratory quality assurance issue.
Enclosure
7 Due to the presence of strontium-90 in groundwater monitoring wells close to the Hudson
River, Entergy modified their environmental monitoring analysis of fish samples to
include strontium-90 analysis and in September 2006, strontium-90 was detected in one
of six fish caught near the plant. Three out of six samples caught 20 miles upstream at
the control location also contained similar detectable levels of strontium-90. Entergy
concluded that no strontium-90 was detected above background based on similar results
obtained from the control location. Strontium-90 is not uniquely generated by nuclear
power plants, but was also generated from above ground nuclear testing in the early
1950's and 1960's and now exists ubiquitously in the environment. From a review of
applicable scientific literature, comparable levels of strontium-90 that were detected in
the September 2006 fish samples were also indicated in background fish testing results
in other parts of New York State.
To further clarify the origin of the strontium-90 and confirm the efficacy of utilizing Entergy's control location in monitoring background strontium-90 concentrations in fish,
an expanded fish sampling program was conducted in June 2007 led by NYS DEC, in
consultation with its fish biologists, to ensure that the control location is sufficiently
removed from Indian Point to preclude fish migration and to accurately represent
background levels of strontium-90. This expanded fish sampling program collected fish
samples from three Hudson River locations: an area influenced by liquid releases from
Indian Point, a control location 20 miles upstream, and a special control location 90 miles
upstream in the Catskills. Three-way split fish samples were supplied to Entergy, NYS DEC and NRC for inter-laboratory comparison of these results. Neither strontium-90 nor
any plant-related radionuclides were detected in any edible fish samples by any of the
three participating laboratories at any of the three Hudson River locations. This is
considered significant, since public doses from liquid discharges from Indian Point are
calculated based on assumed fish and invertebrate consumption. This confirms the
results expected from the groundwater effluent and normal plant liquid effluent release
calculations, indicating small fractions of one millirem per year to the maximally exposed hypothetical member of the public that consumes fish and invertebrates.
.4 Dose Assessment
a. Inspection Scope
Groundwater effluent discharges and associated hypothetical dose calculations to the
public involve a two-step process. First, a groundwater transport model is developed to
estimate the amount of radioactive material being discharged and its dilution into the
environment. The hydrogeologic site investigation of Indian Point has provided the
results for determining this aspect of the dose calculation.
Second, based on methods defined in the Indian Point Energy Center Offsite Dose
Calculation Manual (ODCM), calculations are performed to determine the maximally
exposed individual (infant, child, teen or adult) and maximum organ (bone, kidney,
gastro-intestinal tract, liver, thyroid, lung and total body). NRC has confirmed with the
NYS Department of Health that groundwater and Hudson River water is not used for
drinking or irrigation purposes in the area surrounding Indian Point Energy Center.
Therefore, at Indian Point Energy Center, the liquid effluent dose pathway is through the
Enclosure
8 ingestion of fish and invertebrates (crab). Both the groundwater effluent discharge and
the pathway-to-man methodologies and calculation methods were reviewed throughout
the licensee's investigation in order to ensure that the significance of the liquid effluent
releases were bounded and the associated dose impact was evaluated to provide an
accurate dose assessment of public health and safety.
b. Findings and Assessment
No findings of significance were identified.
The licensee performed an initial conservative bounding dose calculation, dated
October 21, 2005, that assumed a worst case condition, i.e., Unit 2 spent fuel pool water
being discharged directly into the Hudson River with minimal Hudson River dilution flow
(approximately 100,000 gallons per minute). This dose assessment assumed a
conservative Unit 2 SFP leak rate of 2.6 gallons per day
1 incorporating all the
radionuclides detected. The resultant calculated dose was about 0.0001 millirem/year, well below the ALARA design objectives for liquid effluent releases (3 millirem/year per reactor) and a very small percentage of the
public dose limits (100 millirem per year).
The inspectors concluded that the licensee
=s preliminary offsite dose calculation utilized conservative assumptions regarding the Unit 2 SFP leak rate and groundwater dilution, appropriately applied the methodology of the licensee
=s Offsite Dose Calculation Manual, provided a timely dose evaluation response to the identified condition.
As more data became available, the licensee performed a revision to the conservative
bounding calculation, dated December 13, 2005, using Hudson River dilution based on a
six hour half-tidal surge. This resulted in a dilution volume of 1.45E10 gallons. This
revised bounding dose calculation was based on the actual radioactivity concentration of
the Unit-2 SFP and the resultant annual dose to the hypothetical maximally exposed
member of the public was calculated to be about 0.0001millirem/year. This revision was based on conservative and reasonable assumptions and agreed with the result from the
original bounding calculation.
As on-site groundwater monitoring wells were installed, groundwater sample results were
collected, water table contours were identified, and groundwater transport parameters
were determined. Entergy developed a site area drainage model based on annual
rainfall groundwater recharge water balance and applied maximum monitoring well
groundwater concentrations, which was used in a February 28, 2006 effluent release and
off-site dose calculation with a result of 0.000015 mrem/yr to the maximally exposed
hypothetical member of the public. This was no longer a bounding calculation, but
represented an actual groundwater effluent release determination based on groundwater
measurements and groundwater drainage calculations. Radiological and hydrogeologic
inspection of this method determined that the basis was reasonable and the calculations
were accurate.
1The basis for the assumed value of 2.6 gallons per day is discussed in Section 5 of this report.
Enclosure
9 Later in the investigation on March 21, 2006, NRC sample results of Monitoring Well-37
(a river front monitoring well) indicated strontium-90 concentration of 26 pCi/L. This was
the first indication that strontium-90 was likely being released directly to the Hudson River
through the groundwater. Licensee results confirmed both strontium-90 and nickel-63, in
addition to hydrogen-3 (tritium), were likely migrating to the Hudson River. The dose
significance for these additional radionuclides is over one hundred times that of
hydrogen-3 (tritium). On April 24, 2006, Entergy updated their dose assessment in
recognition of this new monitoring well data, and applied the maximum concentrations of
hydrogen-3 (tritium), strontium-90 and nickel-63. The resulting groundwater effluent
discharge and off-site dose assessment indicated a maximum hypothetical public dose of
0.0025 mrem total body and 0.011 mrem maximum organ dose (adult bone) per year.
The increase from the previous dose estimates is a direct result of the strontium-90 and
nickel-63 radionuclides.
As additional groundwater sample data became available, the licensee's dose
assessment model was further refined to rank the monitoring well sample data in each
site drainage area from low to high, and apply a 75
th percentile of radionuclide concentration to the dose assessment calculations. This approach was determined to be
more realistic and yet still conservative. Utilizing this methodology, abnormal groundwater effluent releases were calculated and the following doses for groundwater
releases in 2005 and 2006 were officially reported to the NRC in the annual radiological
effluent release reports as follows:
2005: 0.00212 mrem total body and 0.0097 mrem maximum organ (adult bone)
2006: 0.00178 mrem total body and 0.0072 mrem maximum organ (adult bone)
Based on discussions with the NRC and USGS hydrologists, Entergy agreed to further
evaluate the groundwater flow rate model to utilize groundwater flux ca
lculations based on Darcy's Law, a hydrogeological algorithm that considers actual groundwater gradient
and soil permeability rather than inferring groundwater flow based on a rainfall infiltration model. Accordingly, Entergy initiated actions to develop a refined method to calculate
local drainage area groundwater flux calculations based on Darcy's Law while retaining
an overall rainfall infiltration as input to the local drainage calculations. Entergy intends
to use this approach to calculate and report the 2007 groundwater effluent discharges
and dose assessments.
.5A Unit 2 SFP Leakage
a. Inspection Scope
The Unit 2 SFP does not have a leak detection system, therefore, the licensee used
alternative means of assessing the amount of leakage from the spent fuel pool.
Detectable fuel pool inventory loss could not be determined based on fuel pool water
makeup records, given the variability in water evaporat
ion loss due to atmospheric temperature, pressure, and humidity variations. A more sensitive indicator of spent fuel
Enclosure
10 pool water loss utilized the trending of spent fuel
pool boric acid concentration over time, since boric acid is not affected by evaporative losses and any reduction in boric acid
concentration would likely be due to leakage.
The NRC followed Entergy's progress in examination of the Unit 2 SFP liner and transfer
canal for leaks and subsequent repair of a through-wall leak in the transfer canal.
As was reported in the March 16, 2006 special inspection report, NRC investigation into
the capture efficiency of the Unit 1 building foundation drain system indicated
approximately seven times more hydrogen-3 (tritium) radioactivity was captured by the
drain system than was accounted for by Unit 1 SFP leak calculations. Evidence from the
hydrogeologic site investigation confirms the source of this additional tritium radioactivity
is from the Unit 2 SFP. Based on this understanding, additional NRC analysis used
historical Unit 1 building foundation drain system hydrogen-3 (tritium) sample results to
attempt to assess the age and variation of the Unit 2 SFP leak since 1999.
b. Findings and Assessment
No findings of significance were identified.
A review of daily boron concentration measurements in the Unit 2 spent fuel pool since
the last refueling out
age indicated a decrease of 7 parts per million (ppm) (normally 2,300 ppm) over a one year time period. This measurement provided a bounding water
loss value of 2.6 gallons per day (gpd), with a large uncertainty of +/- 7.2 gpd. This
uncertainty indicates that no definitive loss of spent fuel pool inventory could actually be
determined with any certainty.
The licensee has pursued consistent efforts to inspect the Unit 2 spent fuel pool stainless
steel liner for evidence of leaks. Approximately 40% of the liner was inspected by
underwater video camera. No leakage was determined on the surfaces examined. The
remainder of the pool liner surfaces is inaccessible to optical examination due to
limitations imposed by the proximity of the fuel racks and other obstructions. Beginning
in July 2007, Entergy lowered the water level in the Unit 2 fuel transfer canal, which is
immediately adjacent to the spent fuel pool, in order to examine those surfaces for
possible leaks. One pinhole leak was discovered and was subsequently repaired on
December 15, 2007. An expert review of the material condition of the leak
determined that it was due to an original welding construction flaw, and that there were
no indications of any active corrosion on the transfer canal surfaces.
Notwithstanding that all identified potential leak locations have been repaired, most of the
spent fuel pool surfaces remain unexamined, with the potential for unidentified leaks
remaining. Since the Unit 2 spent fuel pool was constructed without a leak collection
system, groundwater monitoring remains the only means for assessing leakage from the
Unit 2 spent fuel pool.
Enclosure
11 .5B Unit 1 SFP Leakage
a. Inspection Scope
A review of available licensee records was conducted to search for any possible
indications of the beginning or duration of the Unit 1 SFP leak. Records were also
reviewed to evaluate the licensee's response to the initial discovery of Unit 1 SFP
leakage, and the adequacy of corrective actions to repair or mitigate the effects of the
identified leakage based on regulatory requirements and information known at the time.
b. Findings and Assessment
No findings of significance were identified.
A search for historical Unit 1 control room logs and for Unit 1 spent fuel pool inventory
makeup records was initiated, but no pre-1994 records were found. Without those
records, which are no longer required to be maintained, no data was available to indicate
past water inventory makeup trends. The water makeup records and control room log
entries represented the only potential data records to evaluate the onset of Unit 1 SFP
leakage, which remains indeterminate.
The initial licensee's corrective action program identification and investigation of the
leaking Unit 1 SFP (SAO-132 Report 94-06), identified a net fuel pool leak rate
(subtracting evaporative losses) of 25 gallons per day, or 10 drops per second, attributed
to age-related degradation of the fuel pool epoxy coating, which resulted in pool water
penetrating through the fuel pool concrete walls and floors. The corrective actions
associated with Report 94-06, included a large scope of investigative activities aimed at
identifying potential leakage paths within the Unit 1 plant structures, including
groundwater collected in the external Unit 1 building foundation drain system (Figure 2).
Bounding dose calculations performed by the licensee in 1994, which assumed four
times the identified leak rate released to the Hudson River, indicated that the resulting
dose from such a liquid release would be <0.1% of the liquid effluent regulatory
specification and ALARA guidelines.
The NRC conducted three separate team inspections in 1994 (specified in Attachment 1)
to assess the licensee's identification and resolution of the leaking Unit 1 spent fuel pool
condition and based on a comprehensive review concluded that the licensee's
investigation was responsive to this concern and the potential impact on the public health
and environment. Further, that the licensee's investigation incorporated all reasonable
probable pathways of release and had demonstrated no off-site dose impacts would be
attributable to pool leakage based on enhanced environmental surveillance.
Entergy's investigative activities did not result in correcting the degraded condition of the
Unit 1 spent fuel pools or otherwise eliminate the identified leakage. Unit 1 licensing and
procedural requirements were reviewed and no corrective action program violations were
identified. NRC requires safety-related functions of plant components to be repaired or
corrected in accordance with 10 CFR 50, Appendix B, Criterion XVI. However, the leak
rate from the pool did not affect the safety-related function of the Unit 1 spent fuel pool
Enclosure
12 (associated with spent fuel cooling), and the off-site dose consequence of the leakage
was evaluated and determined to have no significant dose impact. Therefore, there was
no condition adverse to quality and no violation of NRC requirements identified.
This 1992 investigation was the earliest documentation confirming leakage of the Unit 1
SFP. Since 1992, the leakage rate remained constant until the Fall of 2005, when the
Unit 1 West SFP was flooded up to allow fuel inspection as part of the future dry cask
storage relocation of the spent fuel. After lowering the water level back down and
draining the surrounding pools in November 2005, the Unit 1 West SFP leak rate
increased to 70 gallons per day due to a higher water pressure forcing more water to
drain through the preexisting cracks to the surrounding now drained Unit 1 spent fuel
pools. Based on the tritium concentration measured in the Unit 1 West SFP and the
current leakage rate, a comparison of tritium leaking from the Unit 1 West SFP and the
total tritium collected by the Unit 1 building foundation drain systems could be compared.
Latest calculations indicates that there is approximately three times more tritium collected
than can be accounted for from Unit 1 West SFP leakage.
2 Based on the hydrogeologic site investigation, it is now known that the source of the
additional tritium activity is due to migration of tritium contaminated water from the Unit 2
SFP, in the unsaturated zone southward towards Unit 1 and being drawn into the
groundwater cone of depression created by the Unit 1 building foundation drain system.
Recognizing that the Unit 1 West SFP leak condition was stable at about 25 gpd prior to
the Fall of 2005 with a stable radioactive source term, historical review of licensee data
was used to evaluate the change in the Unit 2 SFP leakage over time since
approximately 75% of the tritium collected in the Unit 1 foundation drainage system was
due to the Unit 2 SFP leak.
This evaluation was considered necessary to help investigate the results of a sample
taken in the Spring of 2000 from Monitoring Well-111 when Entergy was exploring the
possibility of purchasing Unit 2. No tritium was detected in the sample. The monitoring
well is located in the current Unit 2 SFP tritium plume. The sensitivity of the sample
method should have detected any tritium above 270 pCi/L. This fact would indicate that
the Unit 2 SFP tritium plume did not exist in the Spring of 2000, and that the SFP leak
may have begun more recently. Entergy's site characterization report indicates the
sample was not a reliable groundwater sample as it was taken from the surface of the
well without any purging and was, therefore, not considered representative of the
groundwater at this location. In order to determine the efficacy of the Spring 2000
Monitoring Well-111 sample and the possibility of a more rec
ent SFP leak, the Unit 1 building foundation drain collection data was accessed to provide an indication of excess
tritium infiltration (attributable to Unit 2 SFP leakage) around the time of the Spring 2000
Monitoring Well-111 sample compared to the present time.
If there was no tritium plume emanating from the Unit 2 SFP at that time, then there
should be a significant reduction (approximately 75%) in the tritium input to the Unit 1
building foundation drain system. Otherwise, Entergy's site characterization model,
2 The March 16, 2006 Special Inspection Report indicated a higher unaccounted for tritium balance due to a calibration issue with a flow rate monitor, a condition that has been corrected.
Enclosure
13 which suggests a long-term tritium leak, would be reasonable. The following table
summarizes data extracted by the NRC from licensee data. The two Unit 1 building
foundation groundwater drain systems consist of the north curtain drain (NCD) and the
sphere foundation drain (SFD). The combination of both of these two french drain type
systems represents the total tritium collected annually based on weekly sample
collections.
Unit 1 Drain Tritium Collection
Year SFD uCi SFD flowrate gpm NCD uCi NCD flowrate
gpm Total uCi Total flowrate
gpm Corrected 3 uCi 1999 8.82E4 18 6.0E5 3 6.9E5 21 4.6E4 2005 2.67E4 24 5.8E4 3.6 8.5E4 28 5.6E4 2006 5.2E4 17 4.7E4 4 9.9E4 22 6.6E4 2007 2.6E4 11 2.7E4 2.8 5.3E4 14 5.3E4
As can be seen, in the final corrected column in the table above, there has been a
consistent amount of tritium collection in the Unit 1 drain system that predates the "due
diligence" sampling of Monitoring Well-111 in the Spring of 2000. This would indicate
that the Unit 2 SFP tritium plume was being captured by the Unit 1 drain system in 1999
as currently characterized, and that the Spring 2000 Monitoring Well-111 sample may not
be a valid sample. This confirms the designation as an invalid sample as stated in
Entergy's hydrogeological final report.
Considering factors including the radiological and non-radiological contamination
condition at Unit 1, Entergy determined that any immediate remediation (such as
groundwater pump down) of the existing contaminated groundwater in the vicinity of the
Unit 2 spent fuel pool would be inappropriate at this time. Such remedial action could
adversely affect the current groundwater contamination condition, in particular, it would
create a situation in which contaminated water that is currently collected, monitored and
discharged from the Unit 1 drain systems in accordance with NRC regulatory
requirements, to spread elsewhere unnecessarily. Accordingly, the NRC agrees that, in
the absence of any over-riding public health and safety c
oncern, pum
p and treat remediation of the Unit 2 SFP could adversely affect the spread of the Unit 1
groundwater contamination plume and is not advisable.
.6 Hydrogeologic Investigations
a. Inspection Scope
NRC Region I Inspectors, and scientists from the U.S. Geological Survey (USGS) and
NRC's Office of Research made numerous visits to the IPEC site to observe site
features, test hole
drilling and sampling, rock cores recovered from the test wells, groundwater quality sampling, tracer and pump test procedures, and other site
3 In 2006, the SFD flowrate monitor was found to be significantly overestimating the flow rate by 50%; therefore assuming relatively constant annual groundwater flow, the total tritium results for
the prior years was reduced by 50% to provide a normalized comparison.
Enclosure
14 characterization and monitoring activities. During these site visits, the inspection team
interviewed Entergy staff and contractors, i.e., GZA GeoEnvironmental, Inc. (GZA)
geotechnical engineers, geologists, and hydrogeologists, and examined their methods,
analytical results and bases for conclusions regarding groundwater contamination
transport at Indian Point Energy Center.
b. Findings and Assessment
No findings of significance were identified.
The purpose of the hydrogeological investigation was to identify the on-site, and potential
off-site, pathways for the abnormal releases, and to define the conceptual site hydrologic
model controlling the subsurface transport of t
he released radionuclides.
Initially there were significant uncertainties in defining the tritium pathway (the first
detected abnormal release radionuclide). In discussions with GZA, it was apparent that
the tritium source(s) and pathway(s) were not fully defined. Questions were raised as to
the groundwater flow direction, which the IPEC FSAR Section 2.5 references indicated
was to the south. Based upon water-level data taken by GZA from a series of installed
test wells, the groundwater gradient was initially determined to be west to the Hudson
River in the vicinity of the Screen Wall Structure building (near Monitoring Well-67).
Upon close examination of the water-level data for the full complement of test wells, the
groundwater flow direction was confirmed to be the west and, therefore, the tritium plume
was determined to follow the gradient to the Hudson River. Tritium moves at the same
rate as the groundwater since it is part of the molecular water composition. Analysis of
monitored water levels, temperature and water quality demonstrated tidal effects from the
river affecting groundwater flow conditions along the river bank and upgradient to the
Discharge Canal.
The question of preferential flow pathways was raised due to the nature of the bedrock
underlying the IPEC site, the Inwood Marble, being a metamorphosed carbonate with
numerous fractures. These fractures, which can be observed on-site and in the
Verplanck Quarry as shown in Figure 3, were inspected for the possibility of solutioning
and connectivity. The rock cores collected during the drilling of the test wells were examined for fractures, solutioning and fracture filling. In order to confirm the Entergy/GZA determinations a range of possible conceptual site models were examined
to determine the influence of fracturing, solutioning and fracture filling on contaminant transport. In order to fully investigate and independently analyze alternative conceptual
site models involving preferential groundwater flow pathways, NRC developed an
Interagency Agreement with the USGS - New York Water Science Center located in
Troy, New York.
The USGS conducted a detailed flow-log analysis for hydraulic characterization of
selected test wells. This analysis examined fracture geometries and hydraulic properties
in the bedrock using flow logs, as well as downhole caliper, optical- and acoustic-
televiewer, and fluid resistivity and temperature logs, collected in the test wells by
Geophysical Applications, Inc. under the direction of GZA. The USGS analysis
determined the distribution and character of fracture-flow zones. Hydraulically active
Enclosure
15 fractures were identified in these zones. Transmissivity and hydraulic heads in these
flow zones were estimated using the flow-log analysis method. As reported in USGS
Open File Report 2008-1123 "Flow-Log Analysis of Hydraulic Characterization of
Selected Test Wells at the Indian Point Energy Center (IPEC), Buchanan, New York"
(ADAMS Accession No. ML081120119), the flow-log analysis was corroborated with
pump test and tracer test results from GZA's site characterization and analyses.
Figure 4 shows the presence of intersecting (conjugate) fracture sets which provide
higher permeability zones
and create directional flow properties (anisotropy). These analyses were confirmed by pump test results, and later, tracer test results and
observations showing distinct fracture zones and variable permeability in the Inwood Marble between the Unit 1 and 2 SFPs extending west to the Discharge Canal. No
solution features affecting radionuclide transport were observed or detected by the field
testing and USGS independent analysis. However, fracture connectivity was observed
and is a contributor to preferential flow and transport, particularly in partially-saturated
bedrock (i.e., above the water table) as demonstrated by the GZA tracer test results.
Certain site areas subject to extensive rock backfills, such as the excavated-blast
depressions in the transformer yard and along the river, which are porous-flow
dominated rather than fracture-flow dominated as indicated in the bedrock.
Early in the investigations, the Discharge Canal was thought to capture the tritium plume.
NRC staff questioned this assumption and encouraged its testing. GZA installed
Monitoring Well-37 west of the Canal and down gradient of the plume to test the
assumption. Sampling in Monitoring Well-37 confirmed that the tritium plume did
continue west under the canal toward the Hudson River; however, a significant amount
(perhaps up to 50%) of tritium was captured by the canal. Sampling in Monitoring Well-
37 also identified strontium-90 which extended the scope of the investigation.
As the conceptual site model (CSM) was developed using observed tritium and
strontium-90 monitored data from the numerous monitoring wells, the role of backfill
material around buildings and in excavated depressions (e.g., transformer yard and
along the river) was investigated by GZA. The role of storm drains, sump pumps and
curtain drains on the local hydrology was also investigated and analyzed. The
conceptual site model, as reported in the licensee's Hydrogeological Site Investigation
Final Report (GZA report), recognized the affect of these features relative to the
observed tracer test results and contaminant plume behavior. The conceptual site model
incorporated both natural features (e.g., water-levels and flow directions) and human-
made features (e.g. building foundations, backfills, curtain dr
ains, storm runoff drains and manholes). The conceptual site model considered percolation to the unsaturated zone,
where the Unit 2 tritium source emanates, and flows to the water table. The strontium
source was determined to enter the water-table via the north curtain drain surrounding
the Unit 1 SFP, and also from the spray foundation sump. Both the tritium and strontium
plumes migrate through the connected fractured zones to the Hudson River. Cross-
sectional diagrams from the GZA report, shown in Figure 5, depict the flow and transport
pathways to the river, including the location of monitoring wells down gradient of the
radionuclide sources. Tracer test and radionuclide sampling data from these monitoring
wells support the conceptual site model assumptions.
Enclosure
16 A pump test using Recovery Well-1, with observations in the surrounding monitoring
wells, was performed to test the feasibility of a pump, m
onitor and dischar
ge remediation approach for the tritium plume, and to create a depressed water table (drawdown cone)
beneath Unit 2 SFP to capture and provide early detection of abnormal releases. The
operation of the Recovery Well-1 caused cesium-137, which had not been previously
detected in monitoring wells, to migrate to Monitoring Well-31 and Monitoring Well-32
(west of the Unit 1 and 2 SFP's). This test confirmed the presence of cesium-137 in the
fractured rock, and the connectivity of the fractures in the aforementioned fracture zones
between the Unit 2 and 1 SFP's. The migration of cesium-137 from Unit 1 to Unit 2
during the test confirmed that the pump test should be conducted at very low pumping
rates in the event that other radionuclides were present in the fractured rock and could
become mobilized. The fracture filling in
the bedrock appears to
adsorb the cesium during ambient groundwater flow conditions.
Using insights from this pump test, GZA planned and conducted a tracer test adjacent to
Unit 2 SFP at the base of the construction pit where the original abnormal releases of
radionuclides were observed. A fluorescein dye tracer was introduced in a shallow
borehole above the water table. At the suggestion of NRC staff, the tracer sampling
continued for a significantly longer period of time than would be normal to fully detect and
analyze the transport pathways. The tracer results confirmed the aforementioned
conceptual site model pathways, and identified the role of the fractures in creating
preferential transport in the unsaturated zone, and the role of human-made features
relative to the observed tritium concentrations in the monitoring wells and Manhole 5
adjacent to Unit 2 SFP. The tracer sampling identified the contaminant pathway
direction, transport rate and attenuation for both the tritium and strontium plumes. Since
strontium-90 is adsorbed by the fracture filling materials (e.g., clays), the tracer moved at a faster rate than the strontium plume. The residual cesium-137 appears to be relatively
immobile due to adsorption and the relatively slow groundwater velocity in the fracture
zones until increased by local flow perturbations such as groundwater pumping.
The extensive IPEC site characterization data as reported in the GZA report includes:
water levels; tidal effects; upward and downward flow components determined by flow
meters and by using the Waterloo packers (i.e. inflatable bladders to vertically isolate
fracture zones in a well); tritium and strontium concentrations; and pump and tracer test
results. This database provides valuable site-specific information to confirm the
conceptual site model (CSM) and dose calculations. This information also provides a
valuable two-year baseline for future long-term monitoring and re-evaluation of the
conceptual site model since seasonal groundwater flow dynamics, episodic recharge and
potential future releases may alter the assumptions in the CSM. This information is also
critical in determining the adequacy of the Entergy's chosen remediation approach of
monitored natural attenuation for the tritium and strontium-90 plumes.
Monitored natural attenuation refers to the natural groundwater removal of residual
contaminants after the source of contamination has been secured, and the radioactive
decay acts to diminish the remaining residual radioactivity. Monitored natural attenuation
requires the elimination of the contaminant sources, detailed monitoring of the plumes'
behavior through a confirmatory groundwater monitoring program and confirmation of the
conceptual site model, over time.
Enclosure
17 The licensee indicated t
hat its long-term groundwater monitoring program w
ill incorporate
monitored nat
ural attenuation and have a detection capability for potential future
abnormal releases. Future NRC inspection will review the program details to focus on achieving the goals of monitored natural attenuation and detecting future leaks. Specific
areas of review include determining which monitoring wells and what monitoring
frequencies are needed to demonstrate monitored natural attenuation, early radionuclide
leak detection and if the assumptions in the conceptual site model are valid. The long-
term groundwater monitoring program will be reviewed in a future NRC inspection to ensure there is sufficient detection sensitivity and monitoring frequency to detect
changes in Unit 2 SFP leakage and the capability to detect leaks from other plant components in the presence of existing groundwater contamination. .7 Prior Indications of On-site Groundwater Tritium Contamination
a. Inspection Scope
The inspectors reviewed NRC required documentation affecting the identification of
potential and actual leaks of radioactivity outside of plant systems. The records were
reviewed to identify any historical survey data that the licensee possessed that would
indicate prior knowledge of any groundwater contamination issue that was not evaluated
as required. Title 10 CFR 50.75(g) requires records to be retained of past on-site
contamination spills. These records for the Indian Point site were reviewed for relevance
to the current site condition.
NRC IE Bulletin No. 80-10, AContamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment
@, requires licensees to review their facility design
and operations to identify nonradioactive systems, that could become radioactive through interfaces with radioactive systems, to
include leaks and valve misalignments. The Bulletin required routine sampling and
analysis for the identified nonradioactive plant systems be established in order to identify
any contaminating events that could lead to unmonitored, uncontrolled releases to the
environment. In response to the Bulletin, the licensee developed lists of affected plant
systems and sampling periods. The inspectors also reviewed the licensee's program for
the sampling of on-site storm drain systems for radioactive liquids and sediments. Also,
the inspectors reviewed the results of the "due d
iligence" sampling that was conducted in early 2000 to identify outside plant areas with residual contamination. These results
were also screened for potential evidence of the preexisting groundwater contamination
condition.
b. Findings and Assessment
No findings of significance were identified.
The 10 CFR 50.75(g) decommissioning file included records of the prior Unit 2 SFP leak
from October 1, 1990 - June 9, 1992 as documented in corrective action report
(SAO-132, 92-08). These records indicate an effective cause determination and repair
of the condition. In addition all affected soil was excavated to a depth of eight feet and
the affected 35 cubic yards of soil was shipped off-site as radioactive waste, with no
Enclosure
18 residual soil contamination remaining. No evidence of groundwater contamination was
determined.
The Unit 1 SFP leak assessment corrective action report (SAO 132 94-06) and
hydrology report (Whitman 1994) were included in the decommissioning file, identifying
that most of the 25 gpd leak identified in 1992 would be intercepted by the Unit 1 building
foundation drain system. Any portion not intercepted by the drain system would likely
follow a shallow ground water flow pathway into a small stream discharging into the
Hudson River some 1700 feet southwest of Unit 1. Based on this information, the
licensee added environmental sampling stations to include the small stream south of
Indian Point as well as the Trap Rock Quarry (0.7 miles south of the plant) and an
unused groundwater well located off of Fifth Street in the town of Verplanck (1.3 miles
south of Indian Point). Environmental records of those sampling activities did not identify
any radioactivity in these samples that was plant-related.
Decommissioning file records of the Unit 2 SFP leak that was discovered in September
2005, includes records indicating a 2.6 gpd bounding leak rate was determined in a
November 21, 2005, boron-loss mass balance calculation. The current hydrogeologic
site investigation report completes the groundwater contamination records in the
10 CFR 50.75(g) decommissioning file.
Other miscellaneous documents were reviewed including some legacy records of low
level Cs-137 contamination found in, and associated with, Unit 1 storm drain lines (1-50
picocuries per gram) that predated commercial operation of Units 2 and 3. One area, 10
feet X 70 feet X 3 feet deep, identified in July 1990 on the north side of the Unit 3 fuel
storage building, was originally excavated storm drain material with residual levels of Cs-
137 (30 pCi/g) from Unit 1 operations; it was later paved over. This action included a
dose evaluation which indicated the area would result in much less than 1mrem/yr, which
would not require immediate cleanup in accordance with NRC site cleanup screening
level of 5 mrem/yr (NUREG/CR-5849).
Review of the "due diligenc
e" site assessment conducted by Canberra Services on February 14 - 22, 2000, identified various areas inside the restricted area with detectable
radioactivity. Several monitoring wells were installed and sampled. None of the
groundwater samples indicated any detectable plant-related radioactivity.
The IE Bulletin 80-10 program specific to on-site storm drain monitoring was fairly
extensive and provided detailed records since 1981. Review of the site wide storm drain
system data did not indicate a history of the current extent of elevated tritium
contamination. No historical marker was indicated in the storm drain sample data as to
when the tritium leaks may have been initiated.
Entergy's IE Bulletin 80-10 program ("IPEC Storm Drain Sampling Procedure", O-CY-
151-, Rev. 3) has been recently revised, consolidating two previously separate Unit-
specific programs with an updated map of the Unit 1, 2 and 3 storm drain systems, and
incorporating a consolidated sampling schedule, with appropriate frequencies, that
includes monthly sampling for sensitive storm drain outfalls. The improved program now
includes specific sample detection criteria requiring management involvement.
Enclosure
19 .8 Remediation and Long Term Monitoring Plans
a. Inspection Scope
In addition to providing the hydrogeologic site investigation final report to the NRC on
January 14, 2008, a subsequent Memorandum dated January 25, 2008 (ADAMS
Accession No. ML, 080290204) provided a synopsis of the Long Term Monitoring Plan
Bases. These documents were reviewed along with a number of Entergy and GZA
implementing procedures that provide a framework for addressing the current and future
groundwater contamination issue. Several meetings were also held between the NRC,
USGS and NYS DEC in January and February 2008 to discuss the adequacy of
Entergy's plans and procedures.
b. Findings and Assessment
No findings of significance were identified.
Based on the installation of on-site monitoring wells, 36 out of 39 monitoring wells were
selected by Entergy for continued sampling at established frequencies. In addition, three
storm drain manholes were included in the sampling plan to monitor drainage from the
Unit 2 containment footer drain and the Unit 3 foundation and containment footer drains.
This initial sampling program consists of 378 annual samples to provide trending
information on the current contaminant plumes and provide for early detection of leakage
from other potential on-site sources to comply with the requirements of NEI 07-07,
"Industry Ground Water Protection Initiative", for early detection and reporting of on-site
spills or inadvert
ent contamination of groundwater.
In addition, the on-site storm drain system for Units 1, 2 and 3 was visually inspected
using remote camera technology and large volumes of material (over 100 tons) were
removed to complete the inspection and make requisite repairs. During NRC inspection
of prior sampling evidence of groundwater contamination, in the March 16, 2006, special
inspection report, the storm drain sampling program was assessed as a segregated
program (between the operating Units) without proper program administration or data
trending review. Since those observations, Entergy has renovated the storm drain
systems, validated their connections and flow directions, and consolidated the program
into one site-wide program with individual sample detection criteria that initiates
management review. The current storm drain sampling program requires over 140
samples per year to detect potentially leaking plant systems as part of the IE Bulletin
80-10 requirement.
Currently, there is no periodic trending review of storm drain sampling data or use of this
program with the groundwater monitoring program. Since one of the main functions of
storm drains is to remove surface runoff water, many of the storm drains included in the
sampling program may not provide any indication of below ground leaking plant systems
or components. Since the site groundwater investigation has established the water table
and groundwater gradients, the licensee has initiated actions to evaluate the storm drain
systems for additional input to the long-term monitoring program.
Enclosure
20 The long term monitoring plan implementing procedures incorporate periodic sampling
from a groundwater monitoring network composed of 36 monitoring wells and numerous
other sampling locations. The current groundwater plumes are mapped spatially among
this network of monitoring wells to allow future monitoring of the plume's footprint. At the
conclusion of this inspection, the licensee was still in the process of defining and establishing the parameters of its long-term monitoring program.
Early in the Unit 2 spent fuel pool leak investigation, Entergy reviewed detailed fuel pool
boron sampling data in an effort to determine net leakage losses from the fuel pool, since
boron loss would not be affected by pool evaporative losses and any reduction in boron
concentration would be due to pool leakage. Transfers of spent fuel and reactor water
during refueling outages set a new boron solution level and trends of boron concentration
losses after each refueling outage. This trending of boron data provided an initial Unit 2
SFP loss rate of approximately 2.6 gallons per day (approximately 1 drop per second)
calculated by Entergy in September 2005. Although there are some complicating factors
(e.g., variance in boron data measurement and any unidentified fuel pool cooling system
leaks), this approach does provide an early indication of net change in spent fuel pool
leakage.
Entergy plans on removing the spent fuel and draining the Unit 1 spent fuel pools by the
end of 2008. Some water may remain in the bottom of the
pool to reduce the possibility of airborne contamination and provide shielding of remaining sludge. Sludge removal is
expected to be completed in early 2009. After completion of these activities, the source
of the Unit 1 plume will be eliminated allowing residual radioactivity removal through continued purging from the Unit 1 building foundation drain system and through natural
attenuation processes. Relative to Unit 2, the licensee has taken action to repair all
identified liner leak imperfections, and has identified a program for monitored natural
attenuation on the presumption that leakage has been terminated, based on its current
assessment of groundwater tritium concentrations. However, neither the licensee
nor the NRC is conclusive at this time, since only 40% of the liner surface was accessible
for inspection; and it is too early to detect any significant decline in tritium concentrations
(with respect to the natural variability in groundwater flow). Notwithstanding, it is expected that the lic
ensee's implementation of its long-term monitoring program will establish sufficient data to permit a conclusive determination in the near term.
The current dose significance of the Unit 2 SFP tritium leak rate is 1000 times lower than
the current Unit 1 plume (approximately 0.000002 mrem/yr versus 0.002 mrem/year), and
therefore, additional actions beyond long-term groundwater
monitoring of both groundwater plumes by Entergy are not warranted and the current approach is
acceptable to the NRC.
Further definition of the long term monitoring plan and licensee commitment to this
groundwater surveillance program will be purs
ued through continuing inspection activities in 2008. These future inspection activities will verify completion of Entergy's planned
remediation activities, and to review plume attenuation results to confirm Entergy's site
groundwater characterization conclusions.
Enclosure
21 .9 Regulatory Requirements
a. Inspection Scope
The following regulations were reviewed to identify any areas of noncompliance.
The NRC regulates the radioactive effluent releases from nuclear power plants through
guidelines based on instantaneous maximum concentration values specific for each
radionuclide as well as regulatory limits on potential doses to the public. The release
limits are based on 100 mrem total effective dose equivalent per year. In addition,
licensee's are required to meet the ALARA design objective guidelines of 3 mrem to the
total body per reactor and 10 mrem to the maximum organ dose receptor per reactor
(10CFR50, Appendix I). There are also total site annual exposure limits to actual
members of the public from all pathways of 25 mrem to the whole body, 75 mrem to the
thyroid and 25 mrem to any other organ (40CFR190.10(a)).
Effluent releases are reported by each nuclear power plant licensee to the NRC on an
annual basis with calculated maximum doses to the public and comparison to the above
indicated NRC limits. In addition, to provide a verification of these calculated releases, a
radiological environmental monitoring program is conducted by the licensee providing off-
site environmental sample measurement results for biologically sensitive pathways of
exposure to man especially in locations directly downstream or downwind of the nuclear
power plant. Spills or leaks on the site property
are requir
ed to be recorded to support future decommissioning activities (10CFR50.75(g)).
Unless drinking water is provided from on-site groundwater wells, the environmental
monitoring program does not require on-site groundwater monitoring. This area of the
regulations is currently under review. The industry has adopted a Groundwater
Protection Initiative (Nuclear Energy Institute; NEI 07-07, August 2007) to initiate on-site
groundwater monitoring at all nuclear power plants, and the NRC is proposing additional
rulemaking and guidance (10 CFR 20.1406 and Regulatory Guide 4.21) to address the
potential for leaks into the groundwater and the need to monitor this potential effluent
pathway.
b. Findings and Assessment
No findings of significance were identified.
Instantaneous release rates are limited by procedures that establish gaseous and liquid
release radiation monitor system setpoints and automatic discharge valve closures.
Based on review of monitoring well sample results from October 2005 through
December 2007, groundwater effluent instantaneous release concentrations were
always a small fraction of the regulatory limits.
The annual and quarterly liquid effluent public doses were calculated annually for 2005
and quarterly and annually for 2006 based on a rain precipitation water infiltration
drainage model developed by Entergy's hydrogeologists to derive groundwater flux
Enclosure
22 values to drive the contamination concentrations obtained from monitoring well sample
results. In 2005, when few samples were available, the maximum monitoring well
sample results were used in the calculations. For the quarterly 2006 groundwater
effluent calculations, when multiple sample results were available, the monitoring well
sample results were ranked (low to high) and the 75
th percentile values were used to derive a best estimate of the groundwater releases to the Hudson River. A half-tidal
surge of the Hudson River was used as a final dilution of these releases and dose
calculations were performed based on the Indian Point Energy Center Off-site Dose
Calculation Manual (ODCM) methodology. The ODCM incorporates exposure pathway
dose calculations based on Regulatory Guide 1.109. Doses were calculated based on
Hudson River specific bioaccumulation of contaminants in fish flesh and based on infant,
child, teen and adult fish consumption rates. Various organs concentrate various
radionuclides at differing rates, so doses are calculated for bone, liver, total body, thyroid,
kidney, lungs, and gastrointestinal tract, based on applicable dose factors for each
critical organ. The maximum age group and organ is reported.
Enclosure
23 For 2005 and 2006, the following doses were reported for both normal and groundwater
liquid effluents.
2005 Liquid Effluents Units 1 & 2 (mrem) Unit 3 (mrem) Limit (mrem) Max % of Limit Routine max
quarter 2.93E-4 TB
4 4.68E-4 O
5 3.29E-4
3.85E-4
O 1.5 5 0.02 0.009 Routine
annual 8.11E-4 TB 1.31E-3 O 4.45E-4 TB
5.4E-4
O 3 10 Groundwater
annual 2.12E-3 TB 9.72E-3 O
3 10 0.098 TB 6 0.11 O 6
0.07 0.1 2006 Liquid Effluents
Routine max quarter 7.04E-4 TB 1.03E-3 O 6.8E-5 TB
7.6E-5 O 1.5 5 0.05 0.02 Routine
annual 8.8E-4 TB 1.26E-3 O 1.27E-4 TB
1.6E-4
O 3 10 Groundwater
annual 1.78E-3 TB 7.21E-3 O
3 10 0.09 TB 6 0.085 O 6
0.06 0.07
These maximum hypothetical doses represent approximately 0.1% of the ALARA design
objectives for liquid effluents (3 mrem and 10 mrem per year per reactor) for Units 1 and
2, combined with the groundwater releases attributed to Units 1 and 2.
In conclusion, based on a review of applicable NRC radiation protection regulations, all
effluent and environmental survey and reporting requirements have been met, indicating
that the existing groundwater contamination conditions represent a small fraction of
regulatory limits and no violation of these requirements have been identified.
4 TB - Total Body exposure
5 O - Maximum Organ exposure
6 Represents total dose from Units 1&2 and groundwater
Enclosure
24 4OA6 Meetings, including Exit
.1 Exit Meeting Summary
The inspectors presented the Inspection results to Mr. D. Mayer and other licensee and
New York State representatives on May 7, 2008. The licensee acknowledged the
findings presented. Based upon discussions with the licensee, none of the information
presented at the exit meeting and included in this report was considered proprietary.
Enclosure Figure 1 Long Term Monitoring Plan
Enclosure
Figure 2 Unit 1 Building Foundation Drain System
Enclosure
Figure 3 Observed bedding and conjugate fractures in Verplanck Quarry (from USGS)
Enclosure
Figure 4 Downhole Flow Meter and Geophysical Survey Example from Monitoring Well Monitoring Well-58
Enclosure
Figure 5 Unit 2 Spent Fuel Pool Tritium Plume Cross Section
Attachment
ATTACHMENT 1
Indian Point Contaminated Groundwater Investigation Time Line
Date Event
Unit 1 Spent Fuel Pool Timeline
Unit 1 ceased commercial operations on October 31, 1974
1. April 1990: A nuclear plant operator observed higher than usual frequency of fuel pool
makeup than usual, initiated an investigation by Con Edison.
2. 1991: Con Edison began sampling the north curtain drain (NCD) and sphere foundation
drain sump (SFDS) for tritium and established separate liquid discharge paths.
3. May 1992: Completed calculations of unaccounted water loss - 25 gpd leakage.
4. May 1994: A task force organization was created with a Unit 1 SFP Project Manager position
reporting to the Plant General Manager. Individuals from Chemistry, Operations Maintenance,
Health Physics and Engineering were represented.
5. May-June 1994: NRC inspection (Drs. Bores and Jang) to investigate Unit 1 SFP leakage
(50-03/94-01) Boron concentration mass balance indicated 91 gpd leak rate to the SFDS and
1.5 gpd to the north curtain drain. Tritium concentration mass balance indicated 73 gpd to the
SFDS and 1.2 gpd to the NCD. Hydrogeologist study indicated that the groundwater movement
was about 10 ft/day and would flow towards the quarry, not the Hudson River. No violations were
identified.
6. July 1994: Whitman hydrogeology report investigation of Unit 1 SFP leak migration
concluded that "most" of the leakage would be captured by the Unit 1 building foundation drain
system and the rest would migrate to the South in the shallow zone and could be detected in the
creek bordering south of the plant and in the Trap Rock Quarry. These sample locations were
added to the REMP program.
7. August 1994: NRC inspection (Bores/Jang) to review licensee's leak investigation (50-03/94-
02). Hydrogeologist completed study indicated that groundwater at the site flowed upward and
either west or south into the Hudson River. No violations were identified.
8. December 1994: NRC inspection (Bores, Jang, Erikson, Noggle) inspect compliance with
Bulletin 94-01 (fuel pool potential siphoning), leak investigation, and SAFSTOR approval (50-
3/94-80). Confirmation of tritium in the sphere foundation drain sump that drains groundwater
from the bottom of the Chemical Systems Building of Unit 1 in May 1994, provided evidence that
the Unit 1 SFP system was leaking beyond the plant structure and resulted in initiating a
corrective action SAO-132 report (94-06). 10CFR50.59 evaluations between March 9, 1992 and
December 1994 were reviewed and found to be complete and met requirements. In October
1994, boron concentration was increased in the SFP and fluoresce in dye tracer was added to
Attachment
the water storage pool to detect these sources in the NCD and SFDS. As of mid-December, no
increased boron or indications of tracer were detected in either of these Unit 1 drains. Tracer
did indicate that the SFDS had been discharging through a Unit 3 storm drain to the discharge
canal. Con Edison subsequently rerouted this discharge by hard pipe through the Unit 1 River
water system into the discharge canal. NCD was diverted to the Unit 1 sphere sump where this
discharge was pumped to the liquid radwaste processing system. The on-site stream was
added to REMP monitoring for tritium on a quarterly basis. No violations were identified.
9. January 2, 1996: SECY-96-01, Decommissioning Plan for SAFSTOR and amendment of
license for Unit 1 was approved.
10. June-August 1996: NRC inspection (Jang) to review followup actions: modification to north
curtain drain for recapture, new RMS detector installed in SFDS (50-3/96-04).
11. February-March 1998: NRC inspection (Jang) to review followup actions: effluent controls
and trending of SFP inventory (50-3/98-02).
12. May-June 1998: NRC inspection (Ragland) reviewed schedule for draining and cleanout of
pools (50-03/98-04). Con Edison removed all irradiated hardware from both the East and West
Unit 1 SFPs.
13. November-December 1998: NRC inspection (Ragland) verified that irradiated hardware had
been removed from the East pool and shipped off-site during May-August 1998, with the East
pool ready for desludging and draining. PCBs detected in water storage pool sludge. (50-03/98-
17).
14. December 1998-February 1999: NRC SAFSTOR inspection (Dimitriadis) (50-03/98-19).
Work in progress in draining and desludging various pools. While desludging the water storage
pool, PCBs were detected. Due to known leakage of this pool, the NCD was diverted into the
Unit 1 sphere annulus for waste processing.
15. April-June 1999: NRC inspection (50-03/99-03) NRR reviewed a Unit 1 safety evaluation for
modifications to the SFPs.
16. June-July 1999: NRC inspection (Ragland) reviewed monitoring of pool leakage, north
curtain drain water was being treated by mechanical and charcoal filtration. Water storage pool
cleanup in progress (50-03/99-06).
17. April 7, 2003: Unit 1 Remediation plan was approved to accomplish several objectives that
included pursuing sealing the Unit 1 East SFP, transferring the spent fuel into that pool, and
draining the leaking Unit 1 West SFP, thereby stopping the leak.
18. 2004: Insitu dry storage option was proposed by Unit 1 project team to stop the leak. Too
many uncertainties surfaced regarding potential airborne radioactivity and future floodup effects
on fuel integrity upon final spent fuel removal.
Attachment 19. September 19-November 17, 2005: The Unit 1 West SFP was flooded up for spent fuel inspection for material condition evaluation. After drain down, Unit 1 SFP leak rate recalculated
to be 70 gpd.
20. January 16, 2006: Unit 1 drain system collects seven times more tritium than can be
attributed to the current 1 SFP leak rate.
21. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were
received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being
released in the groundwater to the Hudson River. Initial bounding calculations were revised,
indicating less than 0.1% of effluent release limits.
22. April 17, 2006: Due to the 3/21/06 discovery of strontium-90 in Monitoring Well-111, the
licensee initiated demineralization of the Unit 1 SFP 40 hrs per week in order to reduce leaking
source term. Final assessment of Unit 1 SFP leakage calculations indicated 70 gpd post-drain
down since November 2005.
23. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more
recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90
and nickel-63: 2.5E-3 mrem total body and 1.1E-2 mrem maximum organ (adult bone).
Strontium-90 analysis was added to REMP fish, Hudson River and sediment samples.
24. August 9, 2006: After completing a temporary system modification, Entergy began
continuous cleanup of the Unit 1 West SFP.
25. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and
hydrology results of a 3-day pump down test of Recovery Well-1.
26. April 2007: Revised calculation of tritium mass balance for Unit 1 SFP based on total
radioactivity per year (based on 65 gpd leak rate) versus total radioactivity collected in the Unit 1
building drains for 2006. The Unit 1 SFP releases accounted for only 30% of the tritium
collected in the Unit 1 drain system.
27. June 6-22, 2007: An expanded control zone fish split sampling exercise was conducted to
include a second control locati
on in the Catskills to help evaluate background levels of strontium-90 in fish.
Unit 2 Spent Fuel Pool Timeline
Operating license issued September 28, 1973
1. October 1, 1990: Unit 2 SFP stainless steel liner was perforated by a diver during re-rack
cutting operation, but was not identified at that time.
Attachment 2. May 7, 1992: Unit 2 SFP liner was discovered to be leaking (about 50 gpd), due to outside visible boric acid deposits on the wall of the fuel service building. Condition report determined
cause and examined all other liner work areas for similar perforations. Entergy excavated 35
cubic yards of soil to a depth of 8 feet leaving no detectable contamination.
3. June 9, 1992: Under water epoxy temporary patch was installed, sealing the leak.
4. June 12, 1992: A steel box was welded over the liner perforation permanently sealing the
leak completing corrective actions for this fuel pool leak event.
5. September 1, 2005: Initial discovery of the Unit 2 spent fuel pool leak. Contamination was
first detected on a swipe sample of the exposed crack in the SFP south wall excavation area at
approximately 65-foot elevation. The NRC resident inspector was informed.
6. September 12-15, 2005: NRC initial radiological scoping inspection and dose assessment,
0.00002 mrem/year based on 2 L/day leak rate.
7. September 20, 2005: NRC Special Inspection Charter was issued, followed by a press
release announcing this action.
8. October 5, 2005: Tritium was discovered in the Unit 2 transformer yard Monitoring Well-111.
This was the first location removed from the Unit 2 SFP indicating a groundwater contamination
concern.
9. October 27, 2005: Unit 2 SFP liner inspection begins with underwater camera inspection to
identify any leaks. Visual indications were followed by vacuum box testing.
10. October 31, 2005: NRC Executive Director for Operations issued Reactor Oversight
Process deviation memorandum to provide additional NRC resources and continuing NRC
inspection of the groundwater contamination investigation through 2006.
11. November 3, 2005: Licensee submitted a non-required 30-day report to the NRC, based on
tritium results for Monitoring Well-111 (0.0002 uCi/ml) that were above the radiological
environmental monitoring program (REMP) reporting criteria for non-drinking water samples
(0.00003 uCi/ml). However, Monitoring Well-111 is an on-site well not representative of an off-
site environmental sample therefore, no NRC report was required.
12. November 7, 2005: Drilling of the first new monitoring well was initiated (Monitoring Well-30).
13. January 13, 2006: A permanent leak collection box was installed encompassing the Unit 2
SFP crack.
14. January 31, 2006: A NRC Special Inspection team met on-site to review the Phase 1
monitoring well hydrology results.
Attachment 15. February 8-10, 2006: A NRC Special Inspection team was on-site to evaluate the licensee's compliance with IE Bulletin 80-10 (radiological monitoring of on-site non-contaminated systems),
10 CFR 50.75(g) (on-site spill documentation for futu
re decommissioning), and chemistry counting quality control requirements. Hudson River waterfront well sample splits were taken for
16. February 27, 2006: Monitoring Well-37 initial sample result = 30,000 pCi/L, provided the
first indication of a tritium groundwater release directly to the Hudson River.
17. February 28, 2006: Licensee provided a revised dose calculation of 0.000015 mrem/yr to
the maximally exposed member of the public based on a general site area hydrology water
transport and multiple contamination area drainage model. The NRC conducted the SIT exit
meeting.
18. March 16, 2006: NRC Special Inspection Report No. 05000247/2005001 was issued
describing NRC
=s initial response and evaluation of the Indian Point groundwater contamination issue.
19. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were
received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being
released directly to the Hudson River. Initial bounding calculations were revised, indicating less
than 0.1% of effluent release limits.
20. April 1, 2006: Due to the 2/21/06 discovery of strontium-90 in Monitoring Well-111, the
licensee initiated continuous demineralization of the Unit 1 SFP in order to reduce the leaking
source term.
21. April 10, 2006: Entergy groundwater monitoring and commitment letter sent to NRC
Region I.
22. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more
recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90
and nickel-63: 0.0025 mrem total body and 0.011 mrem maximum organ (adult bone).
23. June 12-16, 2006: NRC groundwater contamination hydrology inspection team was on-site.
U.S. Geological Survey participation was added to the NRC inspection effort.
24. November 7, 2006: NRC split sample results identify licensee strontium-90 results from
8/1 - 9/18/2006 were low and caused licensee resampling and licensee investigation.
25. October 30- November 1, 2006: Entergy conducted a 3-day groundwater draw-down pump
test from Recovery Well - 1 (adjacent to Unit 2 SFP).
26. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and
hydrology results of a 3-day pump down test of RW-1.
Attachment 27. February 8, 2007: Fluorescein dye tracer test injected near the base of Unit 2 SFP. Test samples were collected through August 2007.
28. March 21, 2007: NRC inspection team reviewed preliminary tracer test results.
29. May 9-10, 2007: NRC conducted an on-site inspection team review of tracer test results
and the evaluation of groundwater transport.
30. June 6-22, 2007: An expanded control zone fish split sampling exercise was conducted to
include a second control locati
on in the Catskills to help evaluate background levels of strontium-90 in fish.
31. June 2007: The Unit 2 SFP transfer canal was drained below the pinhole leak, which
arrested this leak pathway.
32. July-August 2007: An independent fracture flow analysis using down hole geophysical and
flow logs was conducted by the USGS to compare groundwater flow results based on fracture
flow with the licensee
=s groundwater flow rate calculations derived from packer testing data (slug tests) and based on a general porous media groundwater flow model.
33. August 31, 2007: The last monitoring well was installed and became operational
(Monitoring Well-67).
34. November 7-9, 2007: NRC inspection team was on-site to compare and review the final site
conceptual groundwater model based on all previously derived site data and USGS analyses.
35. December 15, 2007: The pinhole leak in the Unit 2 SFP transfer canal was repaired.
36. January 14, 2008: NRC received Entergy's final site hydrogeological investigation report.
37. January 29, 2008: NRC received Entergy's Synopsis of Long Term Monitoring Plan Bases.
38. February 4, 2008: NRC inspection team conducted a critique of the Long Term Monitoring
Plan and associated implementing procedures.
39. February 21, 2008: NRC held a meeting with Entergy and GZA to discuss further
development and refinement of the Long Term Monitoring Plan.
40. May 7, 2008: NRC conducted an exit meeting of inspection report 50-003/2007010 & 50-
247/2007010.
Attachment
ATTACHMENT 2
Site Groundwater Contaminant Concentrations
AttachmentIndian Point Monitoring Well Groundwater Contamination Results as of 12/31/2007 in units of pCi/L
H-3 Sr-90 Ni-63 Cs-137 Southern Boundary Wells MW-40 ND ND ND ND MW-51 ND ND ND ND Northern Boundary Wells MW-52 ND ND ND ND MW60 ND ND ND ND Eastern Boundary Well MW-65 ND ND ND ND Riverfront Wells MW-60 ND ND ND ND MW-66 9000 11 ND ND MW-67 5000 27 ND ND MW-62 780 2 ND ND MW-63 ND ND ND ND Unit 2 SFP Wells MW-30 130000 ND ND 3000* MW-31 36000 ND ND 200* MW-32 14000 ND ND ND MW-33 23000 ND ND ND MW-34 22000 ND ND ND MW-35 6000 ND ND ND MW-111 100000 1 ND ND MW-36 12000 2.5 ND ND MW-37 6000 28 56 ND MW-55 10000 32 ND ND MW-50 4000 47 ND ND MW-49 7000 26 ND ND Unit 1 SFP Wells MW-42 2500 47 200 37000 MW-53 7400 28 ND ND MW-55 10000 32 ND ND MW-50 4000 47 ND ND MW-49 7000 26 ND ND MW-47 3500 4 ND ND MW-56 1500 2 ND ND
Attachment MW-57 4000 38 ND ND MW-54 2000 20 ND ND MW-58 900 ND ND ND MW-59 800 Unit 3 Wells MW-39 ND 5 ND ND MW-41 ND 6 ND ND MW-45 2200 ND ND ND MW-44 ND ND ND ND MW-43 ND ND ND ND MW-46 1700 ND ND ND U3-T1 530 ND ND ND U3-T2 1200 ND ND ND Off-site Locations LaFarge No. 1 ND ND ND ND LaFarge No. 2 ND ND ND ND LaFarge No. 3 ND ND ND ND Trap Rock Quarry ND ND ND ND 5th Street Well ND ND ND ND Camp Field Reservoir ND ND ND ND New Croton Reservoir ND ND ND ND ND indicates nothing detectable above background * Single positive result was obtained immediately after a 3-day pump down test indicating
hydraulic connectivity between Monitoring Well-42 and Monitoring Well-30 and 31.
These radionuclide concentrations reflect end of 2007 results. Due to annual cyclic groundwater
flow variability, no definite trend of the radi
onuclide concentrations could be conclusively
determined at t
he present time. Additional sample data over time will clarify whether
the Unit 1 and Unit 2 groundwater plumes are shrinking in size or concentration.
Attachment
ATTACHMENT 3
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Barvenik Principal Engineer, GZA Geo Environmental, Inc.
J. Comiotes Director, Nuclear Safety Assurance
P. Conroy Manager, Licensing
D. Croulet Licensing Engineer
P. Donahue Chemistry Specialist
J. Pollock Site Vice President
C. English Unit 1 Project Engineer
G. Hinrichs Project Engineer
D. Loope Radiation Protection Superintendent
T. Jones Licensing Engineer
R. LaVera Radiological Engineer
D. Mayer Director, Special Projects
J. Peters Plant Chemist
S. Sandike Chemistry ODCM Specialist
New York State Inspection Observers
T. Rice Environmental Radiation Specialist, New York State, Department of Environmental Conservations (NYS DEC) L. Rosenmann Engineering Geologist, NYS DEC
A. Czuhanich Engineering Geologist, NYS DEC
LIST OF INSPECTIONS PERFORMED
7112203 Radiological Environmental Monitoring Program and Radioactive Material Control
LIST OF DOCUMENTS REVIEWED
Entergy Letter, NL-08-009 to USNRC, "Results of Ground Water Contamination Investigation,"
January 11, 2008
GZA Final Report Hydrogeologic Site Investigation Indian Point Energy Center, January 7, 2008
GZA Memorandum to Entergy, "Synopsis of Long Term Monitoring Plan Bases," January 25,
2008
Consolidated Edison Calculation No. CGX-00006-00, ASeismic Qualification Structural Evaluation of the Unit 2 Fuel Pool Wall Considering Deteriorated Condition of Concrete Due to Pool Leak@
Attachment
United Engineers and Constructors Technical Report No. 8281,@Evaluation of Spent Fuel Pool Walls - Indian Point 2 Nuclear Power Plant
@ ABS Consulting Report 1487203-R-001, AStudy of Potential Concrete Reinforcement Corrosion on the Structural integrity of the Spent Fuel Pit
@, September 2005
Chazen, ANorthern Westchester County groundwater conditions summary, data gaps and program recommendations,@ Contract C-PL-02-71, Dutchess County Office, the Chazen Companies, Poughkeepsie, NY, April 2003
Clark, J.F., P. Schosser, M. Stute, and H.J. Simpson, A SF 6 - 3He tracer release experiment: A new method of determining longitudinal dispersion coefficients in large rivers,@ Environmental Science and Technology, vol 30, pp 1527-1532, 1996
Annual Radiological Environmental Operating Reports, 2005 and 2006
Radioactive Effluent Release Reports, 2005 and 2006
Pre-Operational Environmental Survey of Radioactivity in the vicinity of Indian Point Power Plant,
1958 and 1959
SECY-96-001, Order to Authorize Decommissioning and Amendment to License No. DPR-5 for
Indian Point Unit No. 1, January 2, 1996
Indian Point Nuclear Generating Unit No. 1, License Amendment No. 42 and Technical
Specifications
de Vries, P, and L.A. Weiss, ASalt-front movement in the Hudson River Estuary, New York - simulations by one-dimensional flow and solute-transport models,@ U.S. Geological Survey, Water Resources Investigations Report 99-4024, 2001
Freeze and Cherry, Groundwater, 1979
GWPO, AGroundwater Program Office annual report for fiscal year 1994, ORNL/GWPO-013
NCRP, AScreening Models for Releases of Radionuclides to Atmosphere, Surface Water and Ground,@ National Council on Radiation Protection and Measurements, Report No. 123, 1996
Whitman, AAssessment of groundwater migration pathways from Unit 1 spent fuel pools at Indian Point Nuclear Power Plant,@ the Whitman Companies Inc, Project 940510, July 1994
ABS Consulting Report 1394669-R-004, Rev. C, AAssessment of Leakage from Unit 1 West Fuel Pool during Fuel Cleaning Activities
@ ABS Consulting Report 1186959-R-007, April 2004,"Indian Point Unit 1 East Spent Fuel Pool
and Rack Fitness for Service Inspection Report"
ENN-DC-114, Rev. 2, AUnit 1 Remediation - Phase 1 Project Plan"
USGS Open File Report 01-385, ACharacterization of Fractures and Flow Zones in a Contaminated Shale of the Watervliet Arsenal, Albany County, NY
@
Attachment
Procedures
EN-LI-102, ACorrective Action Process
@, Rev. 3 EN-LI-118, ARoot Cause Analysis Process
@, Rev. 3 EN-LI-119, AApparent Cause Evaluation (ACE) Process
@, Rev. 3 HP-SQ-3.013, Rev. 12, ARoutine Surveys Outside the Normal RCA
@ 2-CY-2625, Rev. 9, AGeneral Plant Systems Specifications and Frequencies
@ 3-CY-2325, Rev. 6, ARadioactive Sampling Schedule
@ IPEC IE Bulletin 30-10 Program O-CY-1510, Rev. 3, "IPEC Storm Drain Sampling"
O-CY-2740, Rev. 0, "Liquid Radiological Effluents"
O-CY-1420, Rev. 1, "Radiological Quality Assurance Program"
O-RP-NEM-101, Rev. 0, "Nuclear Environmental Monitoring Sampling and Analysis Schedule"
O-RP-NEM-100, Rev. 0, "Notification, Investigation and Reporting of Abnormal Activity in
Environmental Samples"
IP-SMM-CY-110, Rev. 0, "Radiological Groundwater Monitoring Program"
GZA-IP-101, Rev. 0, "Radiological Groundwater Monitoring Program Quality Assurance and
Procedures IPEC"
IPEC Off-site Dose Calculation Manual
Attachment
Condition Reports
IP2-2005-M-11
Drawings 9321-F-1196-7, Fuel Storage Building Concrete Details No. 1
9321-F-1197-8, Fuel Storage Building Concrete Details No. 2
9321-F-1198-8, Fuel Storage Building Concrete Details No. 3
9321-F-1199-7, Fuel Storage Building Concrete Details No. 4
9321-F-1200-5, Fuel Storage Building Concrete Details No. 5
9321-F-1388-15, Fuel Storage Building Floor Plans, Section & Roof
9321-F-1389-11, Fuel Storage Building - Building Elevations & Section
9321-F-1390-05, Fuel Storage Building - Building Details & Door Schedule
9321-F-2514-16, Fuel Storage General Arrangement Plans & Elevations (U2)
9321-F-2576-24, Fuel Storage Building Auxiliary Coolant System Plans
9321-F-2577-24, Fuel Storage Building Auxiliary Coolant Syst
em Sections 9321-F-2715-5, Containment Building Piping & Penetrations - Details of Fuel Transfer Tube
9321-F-2762-15, Fuel Storage Building Piping Supports
Miscellaneous
ENN-LI-101 Att. 9.1, 50.59 Screen Control Form Activity, ID No. DCP-03-2-128 IP2 FSAR, Section 1.2.1.2, AGeology and Hydrology
@ Rev. 19 IPEC Preliminary Cause Analysis, FSB Concrete Wall/Tritium in the Groundwater, February 10, 2006
NRC Groundwater Sample Result Documentation
ML060720148 ML061880387 ML062720227 ML070110577
ML070110602 ML070110559 ML070110548 ML070110561
ML070940618 ML070940504 ML070940574 ML070940515
ML070940546 ML070940534 ML071900442 ML071900462
ML071900438 ML071900445 ML071900447 ML071900458
ML072840255 ML071900448 ML071900456 ML072840312
ML072840323 ML072840334 ML072840357 ML072840292
ML072840278 ML080080499 ML073180148 ML073180167
Attachment
LIST OF ACRONYMS
CFR Code of Federal Regulations
CR condition report
CSM conceptual site model
DEC State of New York Department of Environmental Conservation
EDO Executive Director for Operations
EPA Environmental Protection Agency
ESSAP Environmental Site Survey and Assessment Program
FSAR final safety analysis report
FSB Fuel Storage Building
GPD gallons per day
GPM gallons per minute
IN Information Notice
IP Inspection Procedure
IP2 Indian Point 2
IPEC Indian Point Energy Center
IR Inspection Report
ISFSI independent spent fuel storage installation
MDC minimum detectable concentration
MSL mean sea level
MW monitoring well
NCD north curtain drain
NYS DEC State of New York Department of Environmental Conservation
NYSEMO State of New York Emergency Management Organization
NYSPSC State of New York Public Services Commission
ORISE Oak Ridge Institute for Science and Education
PCB polychlorinated biphenyls
pCi/L pico-Curies per Liter
REMP Radiological Environmental Monitoring Program
SFD sphere foundation drain
SFP spent fuel pool
USGS United States Geological Survey
Note: Explanation of the terms groundwater, ground-water and ground water -- Hydrologists often
use the term
Aground-water
@ in adjective form and
Aground water
@ in noun form. This report has not followed that convention, and instead typically uses
Agroundwater
@ universally. However, all three forms of the word may be used herein.