ML101900414

Condition Report, CR-PNP-2009-00879

ML101900414
Person / Time
Site:	Pilgrim
Issue date:	03/12/2009
From:	Entergy Corp
To:	Office of Information Services
References
CR-PNP-2009-00879, FOIA/PA-2010-0209
Download: ML101900414 (36)

Text

Entergy CONDITION REPORT CR-PNP-2009-00879 Originator:

Scheffer,Jacob J Originator Group- Tech Chemistry Mgmt PNP Supervisor Namec McElhinneyThomas F Discovered Date: 03/12/2009 11:29 Originator Phone: 8323 Operability Required:

N Rcportabillty Required:

N Initiated Date: 03/12/2009 1 1:35 Condition

==

Description:==

In late 2008 an a3scssment of the nuclear flects compliance with the NEI Groundwater Protection Initiativo (GPI) was performed.

This assessment Identified gaps in each sites compliance with NEI guidance on the GPI. The gaps identified at Pilgrim are as follows: a) Pilgrim needs to perform additional risk assessments of SSCs which have the potential to leak radioactive liquids b) Pilgrim needs to prepare a Groundwater Monitoring Plan, a Buried Pipe Monitoring and Inspection Plan and a remedial Action Plan.c) Although four wells were installed in 2007, the linear orientation of the wells prevents the calculation of hydraulic gradients and reliable interpretation of groundwater flow directions.

d) The lack of deep monitoring walls prevents monitoring of potential contaminant migration within the deeper geological sand unit at the site, as well as prevents the calculation of vertical groundwater gradients and flow directions.

e) The lack of sentinel wells prevents a determination of the impact of the permeable backfill around buildings and SSCs.Immediate Action

Description:

Initiated URT form to request funding for the installation of additional wells.Suggested Action

Description:

Engineering should perform a risk assessment of Systems, Structures and Components which have tho potential to reloase radioactive liquids to the groundwater.

Prepare a formal Groundwater Monitoring Plan, a Buried Pipe Monitoring and Inspection Plan and a remedial Action plan.Install additional monitoring wells and sentinel wells, The contractor that performed the assessment has recommended that six additional wells be installed.

TRENDING (For Reference Purposes Only): Trym.Id T AD HE FACTOR REPORT WEIGHT INPO BINNING KEYWORDS rNPO BINNINO Trend Code CYMO P I CYI KW-ENVIRONMENTAL MONITORING C02 9t7ZZ-17L L40 1UaP!Sa6 WU56I-. Wd L~~EO'Ek-OLOZ Entergy ADMIN CR-PNP-2009-00879 Initiated Date: 3/12/2009 11:35 Owner Group :Tech Chemistry Mgmt PNP Current Contact: +Current Significance:

C Closed by: Summary

Description:

In late 2008 an assessment of the nuclear flect?s compliance with the NEI Groundwater Protection Initiative (OPI) was performed.

This assessment identified gaps in each site?s compliance with NEI guidance on the OPt. The gaps identified at Pilgrim are as fbllows: a) Pilgrim needs to perform additional risk assessments of SSCs which have the potential to leak radioactive liquids b) Pilgrim needs to prepare a Groundwater Monitoring Plan, a Buried Pipe Monitoring and Inspection Plan and a remedial Action Plan.c) Although four wells were Installed in 2007, the linear orientation of the wells prevents the calculation of hydraulic gradicnta and reliable interpretation of groundwater flow directions.

d) The lack of deep monitoring wells prevents monitoring of potential contaminant migration within the deeper geological sand unit at the site, as well as prevents the calculation of vertical groundwater gradients and flow directions.

o) The lack of sentinel wells prevents a determination of the impact of the permeable backfill around buildings and SSCs.Remarks

Description:

Closure

Description:

9V'Z 90 a:' AAC) ;U a Ps a 6 LL"6i!tV d -1 :71Ez; ý" -0*OK ?

Entergy A S S I G N M E N T S CR-PNP-2009-00879 Version: I Significance Coda: C Classiflcation Code: CORRECT/ADDRFlSS Owner Group: Tech Chemistry Mgmt PNP Performed By: BuckleyPatricia A Assignment

==

Description:==

Rcsponsible Manager -Scheffer 03118/2009 12:33 97ZZLVL'809 aD'JJrJ lUaP!Sa6 LLIJ61!1ý Wd LG:Zý Entergy T CORRECTIVE ACTION TCR-PNP-2009-00879 CA Number: I Grout)I Name I Assigned By: CR0 Mgmt PNP Assigned To: Tech Chemistry Mgmt PNP Subassigned To: I Schefferjacob

.Originated By: Buckley,Patricia A 3/18/2009 12:09:38 Performed By: Schoffer,Jacob " 3/30/2009 17:46:11 Subperformed By: Approved By: Closed By: Schefferjacob J 3/30/2009 17:46:11 Current Duo Data: 04/01/2009 Initial Due Date: 04/01/2009 CA Type: DISP -CA Plant Constraint:

NONE CA

Description:

NOTE: This CA cannot be extended without permission ftom the GMPO."CRG has assigned you as the Responsible Manager to ensure the described condition is corrected in accordance with EN-LI-102.

Valideto the problnm statcmcnt and determine corrective actions as needed to resolve the adverse condition(s).

If a CR/CA is closed to an existing CR, concurrence first needs to be obtained from the owner of the CR remaining open. A CA needs to be assigned to the owner of the CR remaining open stating that the CR has been closed to the CR remaining open and that the CR being closed must be addressed within the CR remaining open.Response: The problem statement has been validated.

Corrective Action #2 to this CR has been issued to complete the updated hydrogeological study and determine the recommended final locations for the additional wells recommended to comply with NEI Guidance.LO-HQNLO-2008-00048 CA#47 due 5/12/09 addresses the issue of obtaining finding for Installation of additional wells.LO-HQNLO-2008-00048 CA#55 due 5/26/09 requires that an asset management plan be developed with installation dates for the wells.LOCHQNLO-2008-00048 CA#9 due 6/23/09 requires the development of a site-specific basis document.This CR should not be closed until the LOs are closed.Subresponse Closure Comments: 917ZZ~l17O9

@D1.4.40 *4UaPISG8 uwip,jt! Wd L;£ZL Entergy CORRECTIVE ACTION I CR-PNP-2009-00879 1 CA Number: 2 Group I Assigned By: Tech Chemistry Mgmt PNP Assigned To: Tech Chemistry Mgmt PNP SubassIgned To: Name Scheffor,Jacob J Schefferjacob J I Originated By: Schefferjacob J 3/30/2009 17:31:54 Performed By: Schefferjacob J 9/8/2009 12:53:08 Subperformned By: Approved By: Closed By: Scheffer,Jacob 1 9/8/2009 12:53:08 Current Due Date: 09/10/2009 Initial Due Date: 09/10/2009 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Obtain funding approval and initiate hydrogeological assessment to determine final locations for recommended groundwater monitoring wells to comply with NEI guidance.Response: Funding was approved and the updated hydrogeological study has been Initiated under contract #10247648.

Corrective Action #3 under this CR with a due date of November 30, 2009 has been generated to track completion of the hydrogeological asscssmcnt.

Subresponse:

Closure Comments: 97ZZ-17-1809 a:)"14c) juap!Sa8 Lufj6pý Wd ýgýzl E0-4Eý,I-CLC)z Entergy T CA DUE DATE EXTENSION CR-PNP-2009-00879 Corrective Action: CR-PNP-2009-00879 CA-00002 Version: 1 Approved:

]Requested Duedate: 11/15/2009 Previoum Duedate: 08/31/2009 Requested By: Scheffer,Jacob 3 08/20/2009 Approved By: McElhinncyThomas F 08/20/2009 Request

Description:

It is acceptable to extend the duedate since it will not impact unit operations and it will not delay the installation of the wells since that Is not scheduled to occur until next year (2010).It Is necessary to extend the date since due to resource issues the contract for the project was not issued until August 17th., and the project will not be able to get started until the first week in September.

Since the project will take approximately two months to complete the duo date must be extended, Approved

Description:

a:L11O ~h4OC Juap!Sad unIJ6lW VWd ig:ZL EOAkOO Entergy CORRECTIVE ACTION CR-PNP-2009-00879 CA Number: 3 Group Name I Assigned By: Assigned To: Subassigned To: Originated By: Performed By: Subporformed By: Approved By: Closed By: Tech Chemistry Mgmt PNP Tech Chemistry Mgmt PNP SchefferJacob J Schefforjacob J Scheffer,Jacob J Schefferjacob J Schcfferjacob J 9/8/2009 12:48:44 12/29/2009 14:35:21 12/29/2009 14:35:2F Current Due Date: 12/30/2009 Initial Due Date: 12/30/2009 CA Type: ACTION Plant Constraint:

NONE CA

Description:

Complete updated hydrogeological assessment to determine final locations for additional recommended NEI GPI monitoring wells.Response: Updatcd hydrogcological report has been completed and is attached.This CA can be closed, Subresponse

Closure Comments: Attachments:

Response Description Updated Hydrogeologlcal Report DVZZUW.-18O9 jWC UGPiSa6 LUJ1 t'd E O-Avk-CLCY Attachment Header Document Name:ýntlfed Document Location Iýevponga D~orlpflon Attach Title: ppdated Hydrogeoioglcal Report." 97ZZ _IV-1 Rog GD, 4ýc) juap!saýý WIJ611ý Wd ý, s:?I I E 0 -ý -: ý,,

GZA GeoEnvironmental, Inc.December 29, 2009 File No. 09.0025576.20 Engineers and Scientists 4 Free Street Portland, Maine 04101 207-379-9190 207-879-0099 far wwwV.gza.cam Mr. Jacob Scheffer Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Re: Summary Report of Findings Additional SSC and Work Place Practices Review In Support of Groundwater Protection Initiative at Pilgrim Nuclear Power Station Plymouth, Massachusetts

Dear Jay:

GZA GeoEnvironmental, Inc. (OZA) is pleased to submit to Entergy Nuclear Operations, Inc.(Entorgy), the attached report of our supplemental risk assessment' activities at the Pilgrim Nuclear Power Station (PNPS) in Plymouth, Massachusetts, Please note that a work plan for installation of proposed groundwater monitoring wells at the plant is provided as Appendix B.We hope this report is consistent with your needs and expectations.

However, please do not hesitate to call if you have any questions.

We thank you for this opportunity to provide additional services to Entergy and PNPS.Very truly yours, GZA GEOENVIRONMENTAL, INC.John R. Paquin, P.G.Senior Project Manager Michael M. Shaw, LSP Principal Matthew J. Barvonik, LSP Senior Principal

-Consultant/Reviewer JRP/MMSdvIIBfitmn I The term Risk Assessment is used in this report in a manner, consistent with that described In Objective 1.2 of the NEI 07-07 Industry Ground Water Protection initiative

-Final Guidance Document.Copyright

© 2009 OZA GeoEnvironmrental, Inc.An Equal Employer MiPIVI/D7Zi10 C)j9E o;~KC uapiSa~ U~lI~t 5 d vd /g ZLz-E.-L~

TABLE OF CONTENTS cz 1.0 2.0 3.0 4.0 5.0 6.0 7.0 EXECUTIUVE

SUMMARY

INTRODUCTION BACKGROUND OBJECTIVES ADDITIONAL RISK ASSESSMENT ACIVITIES REVIEW OF HISTORICAL TRANSFORMER RELEASE REPORT WORK PLAN FOR INSTALLATION OF ADDITIONAL MONITORING WELLS 2 3 4 4 TABLE Table 1 -Additional Risk Assessment Activities FIGURE Figure I -Site Plan Showing Proposed Groundwater Monitoring Well Locations APPENDICIES Appendix A Appendix B 09.0025576.20 Report and Project Limitations Work Plan Page i December 29, 2009 9 7Z Z -' 17ý1 3 09 G D1.4.4 C) 1 UGP!S G 6 W! J6 PCý W d 0ý 0Z

1.0 EXECUTIUVE

SUiMARY GZ%1 This report presents a summary of the findings of additional risk assessment' and data review in support of the ongoing Groundwater Protection Initiative (GPi) activities at the Pilgrim Nuclear Power Station (PNPS) located in Plymouth, Massachusetts.

In addition, this report includes a work plan for installation of additional groundwater monitoring wells at the PNPS site. The proposed groundwater monitoring wells, combined with those already existing at the plant, are expected to satisfy PNPS's requirement for establishment of a groundwater monitoring network at the site and development of a groundwater monitoring plan. This design-phase work was performed to address data gaps identified during previous GPI related studies at the site, as follows: The results of the additional risk assessment are consistent with the previous studies. The only work place practices identified as having a potential to result in direct contaminant pathways to the ground were related to the Condensate Storage Tanks and the use of buried piping.A total of six additional groundwater monitoring wells are proposed for the PNPS site to fill idcntified data gaps. Those wells Include both perimeter wells and sentinel wells. The combined data from the existing and proposed new wells will be used to assess horizontal and vertical groundwater flow gradients as well as contaminant migration pathways in groundwater.

2.0 INTRODUCTION

OZA has prepared this summary report of our findings related to recent additional studies performed in support of the GPI at PNPS in Plymouth, Massachusetts.

This work was performed in accordance with our executed contract with Entergy dated August 6, 20092.Specifically, this report includes;A project background;

• Supplemental risk assessment activities, including an evaluation of certain work place practices associated with radionuclide contaminated materials; and A work plan for Installation of additional groundwater monitoring wells at the site.Please note that this report is subject to the limitations provided in Appendix A.

3.0 BACKGROUND

In 2007, GZA performed an initial (Phase 1) hydrogeologic assessment of the PNPS in support of Entergy's fleet-wide corporate OPI program. This initial work was performed in general accordance with the then evolving OPI guidelines being developed by the Nuclear Energy Institute (NEI) and focused on assessing potential radionuclide pathways in groundwater from impacted or potentially impacted, plant systems, structures, and components (SSCs). The The term Risk Assessment Is used In this report In a manner consistent with that described in Objective 1.2 of the ME! 07-07 Industry Ground Watcr Protcction initiativo

-Final Guidance Document.' Entergy Short Form Contract No. 10247648, Effective date August 6, 2009.09.0025576.20 Page I December 29, 2009 97Z _'L_1809 GD1W44 C G! b LU I J61!ý Ld 9:z: E-,'A 'Lk-0LO)Z findings of QZA's initial GPI study are presented in a report dated January 30, 2007 (Phase I Report)3.Subsequent to the completion of the Phase I study: NEI issued the final GPI guidance document number 07-07';1 PNPS/Entergy installed additional groundwater monitoring wolls at the site along the shore of Cape Cod Bay;PNPS/Entergy conducted groundwater monitoring of the new wells and several pre-existing wells;Entergy retained GZA to review the available GPI data for the PNPS site (as part of a fleet-wide OPI review) relative to compliance with tho final NEI 07-07 guidance document.

The findings of GZA's review are presented in a report dated April 2009 (Phase II report)':

and I OZA was retained by Entergy to update a pro-existing summary matrix of GPI data for Entergy's fleet of nuclear power plants, including PNPS. This matrix was updated to include summaries of OZA's Draft Phase II reports, as well as conceptual locations and rationale for potential additional monitoring wells required to fill identified data gaps. This matrix and the associated potential well location maps were transmitted to Entergy on December.3 1, 2008.The current study was performed to: 1) supplement the information presented in the 2007 Phase I report and the 2009 Phase II report; and 2) develop a plan for the installation of additional permanent groundwater monitoring wells at the PNPS site.4.0 OBJECTIVES The specific objectives of this projcct ware to: Assist PNPS with supplementing the existing engineering evaluation of SSCs at the site with regard to evaluating potential contaminant pathways to groundwater; I Assist PNPS with identification and assessment of workplace practices at the station relative to the potential for releases of radionuclides to groundwater; Reassess and refine the proposed locations for additional monitoring wells required to comply with the NEI 07-07 guidance document based on available data; and i Prepare a work plan for installation of the recommended monitoring wells.In addition, GZA reviewed a Massachusetts Contingency Plan (MCP) Class A2 Response Action Outcome Statement for an historical remedial action performed at the site in response to a release of transformer oil.'OZA and Enercon Services, Inc., January 30, 2007, Site Hldrogeologic A6e9,smCnt in SUPPort OP&. Pllarim Noalear Power Statlon. MasschsaItts.

4 NEI, August 2007, Indwiry Ground Water Proteatinn Intiay -Final Ouldwnze Do .mct.'GZA, April 2009, CPIT Data Rview. Plymouth Nuclem"Power Station, Pvymouth.

Masacihuscits.

6 Ram Environmental, Fobruary 18, 1998, Draft Immediate Response Action Completion Statement and Documentation Supporting A-2 Rcsponsa Action Outcome Statement, Transformer Oil Release, Boston Edison Power Plant, 600 Rocky Hill Rgad, Plymouth, Massachuset!;, RTN 4-12893.09.0025576.20 Page 2 December 29, 2009 D 1ZZ _ r_'39a: IJ : I~4 ~U aP!Sad u-L" 6 1! Wd Lglzý 0O- 4 -cAGoz

5.0 ADDITIONAL

RISK ASSESSMENT ACMTIES This section presents the results of additional risk assessment activities performed to supplement the tasks previously presented in the Phase I report. Specifically, this evaluation included: G ZXI Additional review of plans specific to buried portions of SSCs identified in the Phase I study as being potential sources or release points for radionuclides; and* An Initial assessment of operational work practices at the plant.Our evaluation was based on: Interviews with key PNPS plant personnel; A review of supplemental information provided by PNPS; and A plant reconnaissance performed on November 18, 2009.As a result of the additional review of buried SSCs, a number of additional plant utility and/or construction drawings were also reviewed.

Based on this work, no substantive changes to the initial impacted systems assessment, presented in the Phase I report, were deemed necessary.

The key findings of the additional risk assessment activities are summarized in Table 1. The work practices considered during this assessment are generally consistent with those identified in the BPIU Groundwater Protection Guideline' and the US NRC Regulatory Guide 4.21.Consistent with the Initial impacted systems assessment presented in the Phase I report, the operational items identified during the current review were evaluated as to whether the practice presents either a direct or potential direct pathway or secondary pathway to ground. The definition of a direct pathway to ground, as used in Table 1, relates to whether the practice in and of itself has the potential to introduce radiological constituents into the subsurface by means of direct contact with the ground. Secondary pathways refer to other practices with the ability to introduce constituents to ground via an alternative pathway (e.g. if a potential pathway exists only in the event of a failure of one or more c6ntrol systems).As shown in Table 1, the only practices identified as having a potential direct pathway to ground were related to the: Use of condensate Storage Tanks; and I Use of burled piping.Bach of the SSCs associated with these practices were previously identified in the Phase I report as having a potential direct pathway to the ground.In general, only secondary pathways were found for the remaining practices; thus requiring a failure of multiple control systems to complete a pathway to the ground.7 Eletrio Power Research Institute (EPRI), November 2007, Grnundwnter Proetlorn Guidelines rhr Nuiclar Power Plantk.S U.S. Nuclear Regulatory Commission, June 2008, Minimizatlon of Cenraminatfon and Radlo Active Waste Generation, Life Cycle Planning, Regulatory Guide 4.21.09.0025576.20 Page 3 December 29, 2009 917ZZ -117-1 809 @:)1,' 40 1 U a P!S@8 LU'J6 P d Wd -' 92L H- A ýW-CLOZ

6.0 REVIEW

OF HISTORICAL TRANSFORMER RELEASE REPORT During this project, OZA was provided with a copy of a draft report of remedial actions performed by RAM Environmental (RAM) in response to a release of transformer oil adjacent to the Turbine Building at the site'. Our review of this report was limited to the data related to the subsurface hydrogeologic conditions at the site.On March 7, 1997, approximately 15,465 gallons of transformer oil was released from the main transformer at the site, of which approximately 130 gallons of oil were estimated to have been released to the soil surrounding the transformer.

Immediate Response Action (IRA) activities included: I Oil recovery;U Oil-contaminated soil removal and disposal;I Installation of 4 microwells (designated MW-i through MW-4);I Laboratory testing of oil, soil, and groundwater samples; and I Preparation of groundwater contour plans in the vicinity of the release.The locations of each of the microwells installed by RAM are shown on Figure 1. The microwells are constructed of five to tcn-foot sections of % inch PVC well screen attached to 3/4" solid, Sch. 40 well casings advanced to depths between 22 and 23 feet below ground surface.Subsurface.

soil samples, collected from the top 10 feet of each boring, indicates that the soil is engineered fill consisting of fine to medium sand with gravel and cobbles. RAM reported the soil was highly compacted and likely to exhibit low permeability.

Groundwater was encountered at approximately 15-18 feet below the ground surface.Groundwater contour plans were generated using groundwater elevation data measured in April 1997, September 1997, and December 1997. Each of these contour plans indicates a shallow groundwater flow gradient towards the southeast, rather than easterly towards Cape Cod Bay as would be expected based on regional topography and drainage conditions.

RAM concluded that because the foundation for the turbine building extends below the groundwater table, groundwater levels and flow direction were likely impacted by effects of groundwater mounding.Those data suggest that the backfill surrounding the PNPS power block may not be a preferential groundwater flow pathway. The findings of the RAM report are generally consistent with GZA's existing Conceptual Site Model (CSM) for the PNPS site.7.0 WORK PLAN FOR INSTALLATION OF ADDITIONAL MONITORING WELLS A work plan for installation of additional groundwater monitoring wells, including the rationale for each well, is provided in Appendix B.RAM Environmental, op. cit.09.0025576.20 Page 4 December 29. 2009 91z~t_809 aDIB1 Juap~Saý2 uL;J6!- Wd 'g:ZL L4-LC TABLE G:114Q1 ,liap!sa6 wujijb, Wd L;:ZL EOA--"o TABLE I ADDITIONAL RISK ASSEMENT ACTIVITIES Pilgrim Nuclear Power Station Plymouth, Massachusetts Potential Potential Work Practice Applicable PNPS Procdure(s)

CommentsDirect Secondary Pathway Pathway to to Ground Ground Filling. draining, and venting

• System Fill, Vent, and Drain hIsimetions w Procedieapplies to all plant operations involving water N/A N/A water filled proceas systms (Procedure 2-1.11.1, Rev. 21) transfers.

• A procedure-gencraeld penmit must be obtained from the plant's chemistry dpwtmenl prior to all discharges to the environment._-

Liquid Radioactive Dimsharges M Radwaste Collection System (Procedure

• f All liquids in the plant, except sanitary wses, oily No Yes No. 2.5.2.71, Rev. 31) wastes, and seawater wastes, are processed through the 0 Processing Liquid Rzdicmtive plantes radwastc facility.Discharges (Procedure 2.5-2.17)

• The plant uses a Neutralizing Sump as part of its operations.

This samp is located within the Aux Bay area 2nd has a total capacity of 16,700 gallons. Wat=FRom this surp is discharged th-ough the plant's storm drain system. The water level within this sump must be maintained within certain criteria to prevent overflow.* System includes underground cornpoDonts (potential

__________________

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sicandaiy pathway)_____

____CI Ln a)09.0025576.20, Page I of 3 GZA GcoEnvironrncntal, Inc.

TABLE I ADDITIONAL RISK ASSESSMENT ACTIVITIES Pilgrim Nuclear Power Station Plymouth, Massachusetts

('I U aj Cr P!Poleotial Potential Direct Secondary Work Practice Applicable PNPS Procedure(s)

Comments Pat Sacnday Pathway Pathway to to Ground Ground Coodensate Liquid storage and Cotndensat Storage and Transfer System CST system i dch.ks two 275,000 galon storage tanks Yes No transfer t/from the Condensate (Procedure No. 2.2.35, Rev. 43) and associated tnmsfer pumps and piping, Storage Tank (CST) Condxens=

and Feedwaler System These tanks rceive water from the Deminralized (Procedure No. 2.2.96, rev. 89) Water Trap sfcr System as weal as trauted water firom the Conadesate DemineralzaerOperztions Radwaste building.(Procedure 2.5.2.127, Rev 68) U Liquid transfbas to the CSTs are performed by manually operating control valves. The tanks are equipped with high level control alarms.SEac tnk is equipped with overflow piping that diverts overflow to the radwaste building through the reactor BuiLding Equipmim Drain sump.* The CSTs are not equipped with a leak detection system or scondary containment (potential direct pathway).transferring of spent resin and

• Dewatering the Spent Resin Storage Tank

• The SRST is incapable of being dewatered through its No Yes.spent resin dewatcring water (SRST) From die PRdwvaste Truck Lock installed drainage line., Th tank must be dewatered by (Procedure No. 2.5.1.6, Rev. 10) manual pmping firestanding water from the tank to the* Transferning of resin and Dewatering Radwaste Di" drain system.Liners Using Studsvik Processing Facility U iýquid and Resin transfer is conducted using aThor Thor Dewateong System (Procedure No. Fillport systemn which interfaces with Studsvik 2.5.10, Rev 18) containers.

STransfer activities are monitored with a cootrol panel which inchlues CCTV monitor, lev-l alarm, and valv controls.1 Potential secondamy pathway !Thgh paved surfaces 09.0025576.20 Page2 of 3 09.02557.20 age2ofj ZA GeoEnvironniental, Ioc.

TABLE I ADDMONAL RISK ASSESSMENT ACIWITIES Pilgrim Nuclear Power Station Plymouth, Ma.sachusefts Potental Potential Work Practice Applicable PNPS Procedure(s)

Commen Direc Seondary Pathway Pathway to to Ground Ground Exterior Strage of N/A

• Exterior storage of conLaminated equipment or maerials N/A N/A Coanmminatad Equipmeat or with exposure to the weimiber is not allowed al the site.Materials Buried Piping an Tanks [] Bied Piping and Tanks Inspetion and PNPS has initiated a buried piping and tank inspection Yes Inspection Monitoring Program Monitoring program (EN-DC-343) program. A field-level underground component* Ent~rgy Nuclarp aniios Buid assssrt is planned for 2010.__pin raf3 acion Plan Note: I. The definition of a potential diret oathway to ground as used in Table I relates to wbether the practice in and of itself has the potential to introduce radiological constituents directly to the grouxl.2. Potential secodarv pathways refer to otbe- practices with the ability to introduce constituents to ground via an alternative parhway (e.g. if a potential pathway exists only in the event of a failure of one or mam control systems).3. MA indicates practice is not applicable to the PNPS Plant (-'J C, uL)aj 09.002557620 Page 3 of 3 09.02557.20 age3ofJGZA GeoEnvixonmentaL, Inc.

FIGURE L17/OE D*VZ -Iý89a: 44c) I u aP~s a LLiU~ I 4 Wd I £zO-AEW,-OLOZ i--CA -CoD -" mAY M I fl~MT3 z -~--~LO r.J.D C" C>I)( 13 0'0 Lii CJ Co iS---fly.-,'7-=3, Wmfl28 * ---r3, *r Mi-'I = -1.J G7w\APPENDIX A REPORT AND PROJECT LIMITATIONS GD'AIIQ IU@Pisa6 u~li.t!t Wd L9S~z Eo~-AECLCI APPENDIX A REPORT AND PROJECT LIMITATIONS GrZy 1. This focused report was prepared for use by the Client at the subject Facility, for the limited technical and legal purposes stated in the report. We take no responsibility for other uses of this report, or for use by other parties.2. By agreement with the Client, we reviewed and relied on information provided by the Client and Facility to develop our opinions.

We also relied upon public sources of information to help develop our understanding of the Facility's hydrogeologic setting.Local subsurface conditions or soil heterogeneities may exist and may subsequently be shown to have an unanticipated effect on groundwater flow patterns.

These were initial reviews; we did not attempt to verify or validate information, oral or written.3. Unidentified and/or unanticipated conditions may exist. Should such conditions become obvious, it may be necessary for us to reevaluate the opinions expressed in this report.4. Our findings and conclusions are provided as professional opinions, and not as statements of fact.5. Our services were provided with the degree of skill and care ordinarily used by qualified professionals perfoirning the same or similar services, at the same time, under similar circumstances, in the same or similar locations.

No other warranty expressed or implied is made.09.0025576.20 A-1 December 29, 2009 , r/EE 9~~~Og )V44C) IU@P!S@6 U Wdi1I VJS:Z EO-AýW-CLOZ GAZX APPENDIX B WORK PLAN D17ZZ -117,LSDS a D' I u a P!s ad LL I J61!d Wd L;:Zý ED crz)x\Z -WORK PLAN FOR INSTALLATION OF ADDITIONAL GROUNDWATER MONITORING WELLS This work plan presents the general approach and technical requirements for installation of additional groundwater monitoring wells at the Pilgrim Nuclear Power Station (PNPS). These wells are needed to fill data gaps identified during PNPS's on-going Groundwiter Protection Initiative, and are intended to be permanent groundwater quality monitoring wells which will be Incorporated within PNPS's long-term groundwater monitoring plan.This work plan includes: I Proposed monitoring weU locations and rationale; I Drilling and monitoring well installation procedures; I Monitoring well development procedures; and I Project reporting.

PROPOSED MONITORING WELL LOCATIONS AND PLACEMENT RATIONALE A summary of monitoring wells to be installed under this work plan and the associated placement rationale are provided below. Proposed well locations are shown on Figure 1.Monitoring Proposed Rationale Well Typo Well Location Perimeter MW-2021 Proposed deeper monitoring wall to be installed near existing shallow Wells well MW-202. This well will allow groundwater quality monitoring of the deeper sand deposit and will provide groundwater elevation data for calculation of groundwater gradlents and flow directions.

MW-208S/I Proposed multi-level well couplet to be screened in the shallow soil (Two wells) and deeper sand deposit. This well couplet will be used to document background groundwater quality and will provide groundwater eleva~tion data for calculation of groundwater gradients and flow directions.

Sentinel MW-205 Assess groundwater quality in the vicinity of the CSTs and associated Wells buried piping. The data from this well will also be used to assess groundwater gradients and flow directions within the permeable backfill in the power block area.MW-206 Assess groundwater quality In the vicinity of the buried components of the radwaste system. Also used to assess Rroundwater gradients and flow directions within the power block area (when used in conjunction with other proposed sentinel wells): MW-207 Assess groundwater quality in the yard piping backfill and allow calculation of groundwater gradients and flow directions within the power block area (when used in conjunction with other proposed sentinel wells).09.0025576.20 B-1 December 29, 2009 9 17 Z Z L V -1 8 OG G :1114 4 0 1 U a P!s a 6 LL'J6 P d Wd Zlý E 0-WORK PLAN TASK I -PRELIJMTARY TASKS Preliminary tasks to be performed prior to initiation of any subsurface activities shall include: Preparation of a proposed project schedule for review and approval by PNPS personnel; Preparation of a project-specific Health and Safety Plan (HASP) in accordance with applicable regulations and guidelines for review and approval by PNPS personnel; and Clearance of subsurface and above ground utilities by PNPS personnel (Note: if conflicts are identified, alternate well locations will need to be selected by authorized personnel).

TASK 2 -DRILLING AND MONITORING WELL INSTALLATION Vacuum ExcavalJon To limit the potential for damage to unknown subsurface utilities, the top 10 feet (or deeper if structures in the area are known or suspected to be below 10 feet) of the boring for each monitoring well shall be advanced using vacuum excavation (VacEx)methods. Down-hole equipment shall be decontaminated or disposed between boring locations.

Drillinf and Wel Istallation Drilling shall be performed using either drive and wash casing or hollow stem auger drilling methods. If heaving sand conditions are encountered during auger drilling, the drilling method may be switched to drive and wash drilling methods, or approved alternate method. Where drilling fluid is needed, only clean potable water shall be used. Drilling water can be re-circulated at individual well locations unless significant environmental impacts are detected or suspected.

For multi-level well locations, the deepest of the installations will be drilled first, with soil sampling.

Soil samples shall be collected at 5-foot intervals and strata changes using a split spoon sampler or similar soil sampling device. The sampler shall be decontaminated between samples. The shallower installations can be drilled without soil sampling.

The screened interval of the deep overburden wells are intended to be installed within the lower sand layer encountered below approximately 35 feet at the site. The screened intervals of the shallow overburden wells shall be installed to intersect the water table. Monitoring wells shall not be screened across multiple hydrogeologic units.Each well shall be constructed of a 10 foot length of 2-inch diameter 0.010 slot schedule 40 NSF-certified PVC well screen attached with flush threaded joints to schedule 40 NSF-certified PVC riser pipe, The screened interval shall be bacldilled with clean silica filter sand of an appropriate grain size for the formation encountered to an elevation of approximately 2 feet above the top of the well screen. A minimum 2-foot thick bentonite pellet or chip seal shall be installed above the filter sandpack.

The remaining borehole shall be backfilled with a bentonite or bentonite/cement grout installed from the top of the bentonite pellet/chip seal using a tremnie pipe.Each well will be equipped with a vented plug and a protective road box or standpipe.

The protective road boxes will be installed in a concrete pad at the ground surface. The concrete pads shall have dimensions of approximately 2 feet x 2 feet x 1-foot thick, and shall be sloped away 09.0025576.20 B-2 December 29, 2009 Drzz _17ý809 aDI4:II'D luap!sad -51!(ý Wd _Igýzl EO-A=W-CLOZ 1 7 / 9 E from the protective road boxes, Where constructed in paved surfaces, the edges of the paved surface shall be saw cut prior to the construction of the concrete pad.AInvestigation derived wastes (IDWs), including but not limited to drilling cuttings and drilling fluids, shall be containerized in drums to be provided and managed by Entergy. These drums shall be filled and left at the well head for subsequent management and disposal by Entergy.Drilling activities shall be monitored in the field by a field geologist or engineer experienced with drilling and monitoring well installations.

The field geologist or engineer shall prepare drilling and well installation logs, describe and containerize soil samples, describe fill materials encountered, and dovelop the final design for constructing the groundwater monitoring wells.Wells will be installed in accordance with ASTM standards D2488-93 and D5092-04e1, and the requirements and protocols for groundwater monitoring wells specified by the USEPA [RCRA Groundwater Monitoring Technical Enforcement Guidance Document (TEOD) dated 19863, and other applicable regulatory requirements.

TASK 3 -WELL DEVELOPMENT Each of the new groundwater monitoring wells shall be developed using surge block, pumping, and/or bailing methods. Well development shall be performed until water pumped from each well Is, to the extent practicable, visibly free of sediment.

Equipment used to develop walls shall be decontaminated at the well head and decontamination rinse water containerized with well purge water. Along with the other IDWs, this material shall be containerized for future management by PNPS.TASK 4 -REPORTING A well completion report shall be prepared following the completion of this work. This report shall include: I A description of field procedures and methods;U A description of subsurface conditions encountered at each well location;3 An updated site plan showing final monitoring well locations and elevations; U Soil boring and monitoring well constrnction logs; and U Well development results.ACTIVITLES TO BE PERFORM7ED/PROVIDED BY ENTERGY/PNPS Tasks to be performed or provided by Entergy/PNPS shall include: Final underground utility clearance; Groundwater sampling and laboratory analysis;Surveying of the now wells for location and reference elevation relative to the existing plant datum;I Groundwater level measurements and preparation of a revised groundwater level contour plan and flow direction map; and Management and disposal of IDWs.09.0025576.20 B-3 December 29, 2009 DVZZL t7,1 809 @:Ili JiZ) 1UaP!SG8 LI-11-15Ud Wd LG:ZL N-A ýý,'-CLOZ Entergy I CA DUE DATE EXTENSION TCR-PN.-2009-00879 Corrective Action: CR-PNP-2009-00879 CA-00003 Version: 1 Approved:

717 Requested Duedate: 12/30/2009 Previous Duedato: 11/30/2009 Requested By: Scheffbr,Jacob 1 11/19/2009 Approved By: SchefferJacob 3 11123/2009 Request

Description:

It is acceotable to extend the due date because the delay of one month will not impact our ability to site the new wells in 2010.It is necessary to cxtend tho due date because the contractor was delayed In starting the study due to illness and prior commiments at VY.Approved

Description:

Discussed extension request with Chemistry Manager and received his approval.9L~9 TU uaP!Sad LLU 6 1!( VWd 4kCO Entergy CORRECTIVE ACTION TCR-PNP-2009-00879 CA Number: 4 Group ..Name Assigned By: CA&A Staff PNP Assigned To: Tech Chemistry Mgmt PNP McElhinney,Thomas F Subassigned To : Originated By: McWilliams,Dorena C 9/23/2009 10:19:19 Performed By: McEIhinneyThomas F 9/30/2009 13:32:10 Subporfornied By: Approved Byi Closed By: McEIhinney,Thomas F 9/30/2009 13:32:10 Current Due Date: 10/07/2009 Initial Due Date: 10/07/2009 CA Type: PERIODIC REVrEW Plant Constraint:

NONE CA Deserfption:

Safety Equipment Related review.In accordance with EN-LT-102, CR Interim and Periodic Review: Each open CR assoclatcd with Satbry Related equipment will be reviewed approximately six months from Initial assignment.

At least once per year, following the initial review, each open CR associated with Safety Related equipment will be reviewed.Since the review specifies Safety Related equipment only, if you determine this CRis not Safety Related equipment document this statement in the closure of this CA, no further action required.If this CR is determined to be Safety Related use the attached form to review.NOTE: Director and/or GMPO review and signature are required on the form.The fbrm Is used as the means to document the following:

1. Verification that the action plan documented in PCRS will correct the condition.

2. Document expected CR Closurc date based on remaining needed actions.3. Verification, for equipment related CRa, that the documented operability/fimnetionality position remains valid for tha current condition of the equipment and is expected to remain valid for the duration of the action plan. Initiate a new CR if the current operability/f.nctionality position Is questionablo.

4. Verification that administrative performance within the corrective action process has been acceptable to date.(Appropriate approval levels and justifications for DDEs are documented; LTCAs are appropriately flagged, etc), 5. Verification that the risk of not correcting the condition is acceptable for the duration of the action plan.6. Approval of these reviews and approval for the CR to remain open beyond six months has been obtained and documented from a director level or above.NOTE: Questions on Safety Related equipment determinations can be discussed at CRG as a 'Bring Back' issue.Response: This Is not safety related, this CA can be closed.Subresponse:

Closure Comments: 9vEzz-Lr2)O9 63,4O0 juapls;6 WIJU 5 W Wd Lgz ZO-AtW.OLCOZ Entergy T CORRECTIVE ACTION ICR-PNP-2009-00879 Attachments:

CA Description form GD14,10 juap!saýj LLJJ61!ý Wd -IGlzt E,-)-AEk.-OLCýz Attachment Header 00CUMet~t Name: PnftEod Document Location FCA Description1 Attach Tilue: 97Z Z-1 7-1 SOS a:" 11 11 C) juap!saý w1j6pd w d EO-Az- k,-OL Oz ATTACHMENT

9.8 SHEET

1 OF 1 CR INTE=RIM AND PE!RIODIC REVIEW FORM CR Interim and Periodic Review CR Number: Category Level E] A F1 B D C CR Owner Group: CR

Description:

CR Review: (All No responses require explanation be Included.)

1. Will the existing corrective actions documented In the condition report, when completed, correct the condition report Issue? Yes ED / No -2. What is the expected CR Closure date based on remaining needed actions? DATE: 3. Is the previously documented operabilIty/functionallty position still valid for the current condition and expected to remain valid until CR closure? Yes E] / No I/N/A I If the answer is NO, then initiate a new CR to document the concern; CR #4. Are all Li-1 02 requirements for corrective action administration and control being met, i.e.justifications for Due Date Extensions valid, Long Term Corrective Actions Identified, CARB approved CAPRs Identified, and appropriate approvals obtained for all?Yes IE-/ No --6. What risk to plant operation is Imposed by the condition identified and how Is risk reduced to an acceptable level for the duration of the action plan?Review / Approval Required: Director/GM Title: Date: (Print name & Position title)NOTE: The expectation Is to capture the discussion points of this form in a CA. The form itself need not be used, but all points applicable must be addressed.

EN-LI-102 REV 13 917zz-)17ý809 GD144c) IUGPýSa6 LU!J61!,Z Wd -'; ZL Entergy CORRECTIVE ACTION CR-PNP-2009-00879 CA Number: 5 Groun I Assigned By: CA&A Mgmt PNP Assigned To: Tech Chemistry Mgmt PNP Subassigned To: Name KeyesJames D McElhinney,Thomas F Originated By: MeWilliams,Dorena C 12/30/2009 09:52:2;Performed By: McElhinney,Thomas F 1/13/2010 15:40:25 Subperformed By: Approved By: Closed By: McElhxinneyThomas F 1/13/2010 15:40:25 Current Due Date: 01/14/2010 InitialDue Date: 01/14/2010 CA Type: CR CLOSURE REVIEW Plant Constraint:

NONE CA

Description:

1. This CA Is assigned to you as ownar of the condition report to conduct a review of the actions taken and render a determination of whether the CR Is adequate for closure. Use the guidance in the attached checklist to ensure expectations of a quality review are performed.

2. You are validating that your review of the closed corrective action(s) resolves the specific condition identified by the CR and that all corrective action items are completed.

Refer to the guidance in Section 5.9.1 of LI-102 for additional details.3. Verify appropriate trend codes have been added. In addition, for any equipment related CR, ensure system numbers, component codes and descriptions have been entered in accordance with EN-LI- 121.4. Should the closure not be satisfactory, issue a new action item(s) to correct the condition(s) that has not been adequately addressed.

Response: This CA can be closed, Subresponse

Closure Comments: Attachments:

CA Description form CA6 issued to track Installing new wells.97FZýr_1809 juap!sad LUIJ61!,4 Wd Lg:zt zo-AEý"-CLC)z Attachment Header Document Nama, Document Location SA DOwptlion Attach Tltlo: F7on qv Z ,7180 61 44C) I ~U aP!s~ a WLU'1W Wd ZO4E,-LO ATTACHMENT

9.3 CHECKLIST

FOR LEVEL C CR CLO8URE Page 1 of 2 0 1. Read and understand the CR description, immediate actions, and suggested actions.2. Ensure that the REPORTABILITY TAB and OPERABILITY TAB have been completed if required.

If flagged for Operability and / or ReportablIlty review on the front screen, then review the Information documented in the REPORTABILITY TAB and OPERABILITY TAB.I If the last Operability's code Is "Operable-Comp Meas" contact the Control Room STA/SM and Operations DPIC to resolve the issue. If needed, initiate an action with a due date no greater than 14 days to Operations to revise the Operability.

If the last Reportability was indeterminate, then initiate an action to Licenelng to clarify the status of determining this CR's reportabillty requirements with a 14 day due date.El 3. Review the ASSIGNMENT TAB, noting the screening level, type of evaluation directed, and any screening notes, such as other related CR9 to be addressed.

4. Verify no documents Identified as Proprietary or Safeguards on the document are contained In the CR.5. If flagged as ODMI or SDNC, verify that all ODMI or SDNC actions have been completed and the ODMI or SDNC has been closed based on CRG approval.E 8. Ensure the following trend codes have been entered into PCRS: " One Report Weight; at least one INPO Bin Code; at least one HEP Factor* At least one Problem Code, along with an associated Work Group Code-One or more Keywords" If the CR was an error of some type, the HU Classification (human error, NCE, or event) with an associated Work Group Code" If an HPER was completed, the HU Attributes with associated Work Group Codes" If and EFE was performed, equipment failure mode andlor INPO ERPOC codes.Refer to Attachment 9.5 for detailed trending guidance.ED 7. Ensure CR closure has been performed by the responsible manager or designee.

The Manager Closure Review can sometimes correct deficiencies found in corrective actions.8. Have the proper additional reviews, as referenced in the REFERENC2,TAB or ADMIN TAB, been performed?

If additional reviews are required Initiate the actions to the groups and assign a due date requested by the group El Operating Experience (OE) Review Required El QAAFI El [ Safety Committee Review required Licensing review required for a Non-cited Violation, Notice of Violation, Non-compliance, NRC l t]finding, NRC minor violation, NRC Violation' [ Other reviews EN-LI-1 02-02 Rev 0 DVZZ_17ý809 a)44C) 1UGP!Sa) LU4!J1!,c Wd i-w GO:k-L ATTACHMENT

9.3 CHECKLIST

FOR LEVEL C CR CLOSURE Page2of2$A 9. Very the corrective actions corrected the condition Identified In the Condition Descrlption.

SAT 10. Verify that each corrective action Identified In the evaluation was completed as Intended.SAT Recommendations and Enhancements may be tracked by other processes.

Corrective actions are completed in full and the Intent of the action Is met. Adequate logic and.. documentation Is provided to Justify closuro. If action Ia not completed as steted, detailed SAT documentation shall be provided to explain why and to provide alternate or equivalent actions and CA number for tracking.

The Responsible Manager agreement must be documented.

Verify the action item was !12 closed to a "promise" of a future action Item.SAT E 1 Verify CAs that are to "evaluate", "Initiate", or "determine" have follow-up corrective actions issued to SAT resolve the intended subject or clearly state why no further action Is needed.E When a CA Is closed to another CR/CA, ensure the CA Is properly referenced In the other CR/CA SAT (traceability).

Verify the other CR/CA fully addressed the corrective action.11. Recommendations and enhancements can be closed to other processes.

If a corrective action was SAT Issued that later was determinod to be an enhancement ensure the reason the action Is considered a recommendation or enhancement and what group made that determination should be documented.

Actions addressing the original condition are not enhancements.

13 12. Verity the corrective action Is not closed to another process other than WO approved by the CRG.SAT-l 13. Corrective Actions may be closed to an approved WO only with CRG aooroval.SAT -Verify evidence or CRG approval The following types of CAs shall agj be closed to Work Orders or other processes:

a Substantially Degraded or Non-Conforming Conditions (SDNCs)" 14. Attach orverify that any additional documentation Is attached to the CR as a .PDF file or .DOC file. If documentation cannot be attached (such as a Post Trip Evaluation with lots of charts, computer printouts, etc.), check the "Additional Paper" box at the bottom of the CR ADMIN TAB and Include with the hard copy printout that vwll have to be manually transmitted to Records Management.

LI 15. If this quality closure review identifies an unsatisfactory closure of a checklist Item annotated "8AT", Issue a CA using the "UNSAT RESPONSE CA&A" action type, with specific recommendations or Identified discrepancies that need further review.0] 16. When all items In the checklist are satisfactorily completed, the CR is ready to close.EN-LI-1 02-02 Rev 0'/97 Entergy CORRECTIVE ACTION CR-PNP-2009-00879 CA Number: 6 Group I Name I Assigned By: Tech Chemistry Mgmt PNP Assigned To: Tech Chemistry Mgmt PNP Subassigned To: iMc~lhinnoy,Thomas F Schofferjacob J Originated By: McE[hinneyThomas F Performed By: Subpcrformed By: Approved By: Closed Hy!1/13/2010 15:39:27 Current Due Date: 06/29/2010 Initial Due Date: 06/30/2010 CA Type: ACTION Plant Constraintz NONE CA

Description:

Complete installation of 6 new groundwater monitoring wells.Response: Subresponse:

Closure Comments:;:ý,,,jrj juap!S;6 Lu'J6j!1-Wd ý19:ZL E0-4ýW-CLOZ I V)I.7