ML12089A605
| ML12089A605 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/19/2009 |
| From: | Darrell Roberts Division of Reactor Safety I |
| To: | Joseph E Pollock Entergy Nuclear Operations, Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12089A599 | List: |
| References | |
| RAS 22132, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR IR-09-008 | |
| Download: ML12089A605 (17) | |
See also: IR 05000003/2009008
Text
ENT000343
Submitted: March 29, 2012
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
October 19, 2009
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 & 3 - NRC INSPECTION
REPORT NOS. 05000003/2009008 ; 05000247/2009008; AND
Dear Mr. Pollock:
On September 4, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Indian Point Nuclear Generating Units 1, 2, & 3. The enclosed report documents
the inspection results, which were discussed on August 19 and September 4, 2009, with Mr. Don
Mayer and other members of your staff.
The purpose of this inspection was to assess the establishment, implementation, and
maintenance of your Long-Term Groundwater Monitoring Program ; review the circumstances
surrounding a previously identified occurrence involving the detection of tritated water in a Unit 3
storm drain system; review the performance of the site's Radiation Monitoring System; and
inspect and assess your performance relative to radiological effluents monitoring and control.
The inspection involved an examination of activities conducted under Entergy's license as
related to safety and compliance with the Commission's rules and regulations and with the
conditions of your license. Within these areas, the inspection consisted of a selected
examination of procedures and representative records, observations of activities, interviews with
personnel, and independent assessment activities.
Based on the results of this inspection, no findings of significance were identified . Further, the
inspectors determined that Entergy's Long-Term Groundwater Monitoring Program for the .lndian
Point Energy Center was effectively implemented and maintained in a manner that provided
continued radiological monitoring of the groundwater conditions to confirm conformance with
NRC regulatory requirements relative to the maintenance of public health and safety, and
protection of the environment.
Since 2005, as approved by NRC's Executive Director of Operations, Region I conducted
frequent and focused reviews of your groundwater investigation activities and long-term
monitoring program that exceeded the scope of NRC's normal baseline inspection program. As
a result, we have developed confidence in your commitment and ability to continue effective
monitoring and assessment of the on-site conditions to assure the maintenance of
J. Pollock 2
public health and safety, protection of the environment, and conformance with NRC regulatory
requirements. Our inspectors confirmed that the objectives specified in our deviation
memorandum dated December 16,2008 (ML083590057) have been satisfied. However, we will
continue to monitor your performance in this area, and will re-assess the need for continued
heightened inspection oversight during our end-of-cycle review of your CY 2009 perfonmance.
In accordance with 10 CFR2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document Room
or from the Publicly Available Records (PARS) component of the NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
J);W~
Darrell J. Roberts, Director
Division of Reactor Safety
Docket Nos: 50-003, 50-247, 50-286
License Nos: DPR-5, DPR-26, DPR-64
Enclosure: Inspection Report Nos. 05000003/2009008, 05000247/2009008,
w/Attachment: Supplemental Information
cc w/encj: Distribution via ListServ
J. Pollock 2
public health and safety, protection of the environment, and conformance with NRC regulatory
requirements . Our inspectors confirmed that the objectives specified in our deviation
memorandum dated December 16, 2008 (ML083590057) have been satisfied. However, we will
continue to monitor your performance in this area, and will re-assess the need for continued
heightened inspection oversight during our end-of-cycle review of your CY 2009 performance.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in.the NRC Public Document Room
or from the Publicly Available Records (PARS) component of the NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at hllp:llwww.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
IRA by Peter R. Wilson forI
Darrell J. Roberts, Director
Division of Reactor Safety
Docket Nos: 50-003, 50-247, 50-286
License Nos: DPR-5, DPR-26, DPR-64
Enclosure: Inspection Report Nos. 05000003/2009008, 05000247/2009008,
w/Allachment: Supplemental Information
cc w/encl: Distribution via ListServ
Distribution w/encl: (via E-mail) S. McCarver, DRP
S. Collins, RA (R10RAMAIL RESOURCE) G. Malone, DRP, Senior Resident Inspector
M. Dapas, DRA (R10RAMAIL - Indian Point 2
RESOURCE) D. Hochmuth , DRP
D. Lew, DRP (R1 DRPMAIL RESOURCE) D. Bearde, DRP
J. Clifford, DRP (R1DRPMAIL Region I Docket Room (w/concurrences)
RESOURCE) ROPreport Resource
L. Trocine, Ri OEDO D. Roberts , DRS
RIDSNRRPMINDIANPOINTRESOURCE P. Wilson, DRS
B. Bickell, DRP
SUNSI Review Complete: JRW (Reviewer's Inrtials)
OOCUMENT NAME: G:IORSIPlant Support Branch 2INoggleIIP2009008Rev1 .doc
After declaring this document ~An Official Agency Record w it will be rel eased to the Public.
To receive a copy of this document, Indicate in the box: "e" = COpy without attachment/enclosure "E" = COpy with attachment/enclosure "N" = No CQP"y
OFFICE RIIDRS I RES I RIIDRS I RIIDRP I RIIDRS I
NAME JNoggle/JDN TNicholsonltjn JWhite/jrw' ehg BWeliinglBW DRoberts/prw for
(telecon) for'
DATE 10/06/09 10/14/09 10/19/09 10/16/09 10/16/09
- see pnor concurrence OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.50-003 , 50-247, 50-286
License Nos. DPR-3, DPR-26, DPR-64
Report Nos. 05000003/2009008, 05000247/2009008, and 05000286/2009008
Licensee: Entergy Nuclear Northeast
Facility: Indian Point Nuclear Generating Station Units 1, 2, & 3
Location: 295 Broadway
Buchanan, NY 10511-0308
Dates: . Augusr18, 2009 - September 4, 2009
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
Approved by: John R. White, Chief
Plant Support Branch 2
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000003/2009008, IR 05000247/2009008, IR 05000286/2009008; 08/18/2009 - 9/04/2009;
Indian Point Nuclear Generating Station Units 1, 2 & 3; Other Activities - associated with ROP
deviation memorandum, one PI&R sample, and radioactive effluents baseline inspection.
No findings of significance were identified. The report covers the period from August 18 through
September 4, 2009, and discusses inspection activities conducted by a region-based inspector,
and an inspection team comprised of representatives of Region I, NRC's Office of Research,
and the U. S. Geological Survey. The inspection provided bases for the NRC to determine that
Entergy had completed actions necessary to satisfy the objectives delineated in our deviation
memorandum, "Request for Renewal of Deviation to the Action Matrix to Provide Heightened
NRC Oversight of the Onsite Groundwater Monitoring at the Indian Point Energy Center,"
(ML083590057), dated December 16,2008. The NRC's program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor
Oversight Process," Revision 4, dated December 2006.
ii
Enclosure
Report Details
2. RADIATION SAFETY
Cornerstone: Public Radiation Safety (PS)
2PS1 Gaseous and Liguid Effluents (71122.01 - 3 samples)
a. Inspection Scope
1) The inspector reviewed the following documents to evaluate the effectiveness of the
licensee's radioactive gaseous and liquid effluent control programs relative to the
applicable regulatory requirements specified in the Technical Specifications and the
Offsite Dose Calculation Manual (TS/ODCM).
- The 2007 and 2008 Radiological Annual Effluent Release Reports were
reviewed including independently assessing selected public dose calculations.
There were no anomalous results reported in these two reports . The report
included discussion of current groundwater conditions and the result of required
monitoring activities; and instances involving out-of-service radiation monitors or
effluent release flow rate monitors were listed in the reports and these were
evaluated during this inspection.
- The current ODCM was reviewed, including technical justifications for any
changes made since the previous revision.
- Applicable sections of the Updated Final Safety Analysis Report (UFSAR) were
reviewed to verify the adequacy of system descriptions for gaseous radioactive
waste and station ventilation systems.
- The latest quality assurance audits of radioactive effluents and chemistry were
reviewed, including Entergy's program for identifying, controlling and assessing
potential contaminated spills and leakage.
- There were no measurable effluent releases to the environment based on off-site
dose calculations, and there were no reported off-site environmental sample
measurements identifying plant-related radioactive materials during the 2007 and
2008 report period.
2) The inspector observed the following plant equipment and work activities to evaluate the
effectiveness of the licensee's radioactive gaseous and liquid effluent control programs.
- Walkdowns were performed of accessible gaseous and liquid release system
components to review any recent changes or modifications; and to confirm the
alignment, operation and material condition of the radioactive liquid and
gaseous effluent radiation monitoring systems (RMS) at Units 1, 2 and 3.
- Observations were conducted of radioactive effluent related sampling and
associated laboratory measurement techniques.
- Procedural controls and selected radioactive gaseous and liquid effluent release
permits were reviewed to verify that radiation monitor alarm setpoint values and
releases were in agreement with Technical Specification and ODCM
requirements.
Enclosure
2
- Chemistry logs, relative to out-of-service radiation monitoring conditions, were
reviewed to confirm the performance of compensatory sampling activities.
- Surveillance tests of gaseous filtration discharge systems were reviewed to
confirm operability and ventilation flow rates with respect to the assumed flow
rates used in gaseous effluent release calculations.
- Entergy's surveillance program of non-radioactive system interfaces with
radioactive process systems was reviewed to confirm effective monitoring and
control of potential effluent discharge paths to the environment.
- Radiation monitoring system and chemistry laboratory counting instrument
calibration and quality control records were reviewed with respect to ODCM
surveillance requirements to confirm the licensee's ability identify and report
detectable radionuclides in radioactive measurement results.
3) Radioactive effluent control related corrective action program activities for 2007 through
August 2009 were reviewed, including the results of audits and the resolution of issues
identified through the condition report system. A comprehensive review was conducted
of conditions and occurrences involving out-of-service radiation monitoring system
components. Section 40A2 pertains.
b. Findings and Observations
No findings of significance were identified. The following table summarizes the dose
consequence of radiological effluent release in the period between 2007 and 2008.
Table of Effluent Release calculated dose and public dose limits for 2007 and 2008
Dose in Air Dose %of Air Dose %of liquid '10 of Liquid %of
mrem/yr Whole limit Max Organ Limit Dose limit Dose limit
Body WB MaxO
2007 Units 1&2 2.43E-3 0.016 2.43E-3 0.016 5.35E-4 0.018 1.3E-3 0.013
2008 Units 1&2 2.07E-3 0.014 2.67E-3 0.018 6.11E-4 0.020 1.47E-3 0.Q15
2007 Unit 3 3.BBE-3 0.026 3.BBE-3 0.026 3.2E-4 0.007 2.14E-4 0.002
2008 Unit 3 1.99E-3 0.013 1.99E-3 0.013 1.56E-4 0.005 2.B3E-4 0.003
2007 Groundwater 2.66E-4 0.009 9.94E-4 0.01
2008 Groundwater 2.86E-4 0.009 9.35E-4 0.009
4. OTHER ACTIVITIES (OA)
40A2 Identification and Resolution of Problems
Cornerstone: Public Radiation Safety
.1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope (71122.01)
The inspector reviewed approximately one hundred corrective action condition reports,
initiated between january 2007 and August 2009, that were associated with the gaseous,
liquid, and groundwater radioactive effluents program. The review was performed to
Enclosure
3
verify that problems identified by these condition reports were properly characterized in
the licensee's event reporting system, causes were identified, and actions implemented
commensurate the safety significance of the matters.
b. Findings and Observations
No findings of significance were identified .
.2 Radioactive Effluent Radiation Monitor System (RMS) Maintenance (71152 - 1 sample)
a. Inspection Scope
The inspectors conducted a review corrective action program condition reports
associated with out-of-service radiation monitoring system equipment that was identified
in the period between January 2007 and August 2009. Licensee personnel having
cognizance of Radiation Monitoring System (RMS) performance and activities were
interviewed, including the RMS system engineer and senior chemistry staff. "Radiation
Monitoring System, Second Quarter 2009, Condition Report Trend Review for Radiation .
Monitoring System Improvement: dated September 2, 2009, was also reviewed.
b. Findings and Observations
No findings of Significance were identified.
A large number of condition reports associated with the radiation monitoring system were
initiated during the past two years . Most of the condition reports were associated with
interruption of service of the RMS display consoles in both the Unit 2 and Unit 3 control
rooms. While these temporary display outages affected operators' ability to poll
individual detector readout displays, they did not interfere with control room annunciator
actuation or actual detector operability.
The cause of the Unit 3 display console issues was determined to be related to
excessive temperature in the RMS electronics cabinets that affected certain control room
RMS display console components. Short-term corrective actions included installing
permanent air conditioning to effect improved cooling of the RMS electronics cabinets.
The cause of Unit 2 RMS display console service interruptions continues to be under
review. Notwithstanding, Entergy is evaluating replacing the RMS display console
equipment in both control rooms to support station-wide computer network access
improvements.
Less frequently occurring RMS equipment issues remain to be resolved, including
occurrences involving the R-56 detectors, which monitor the discharge of waste sewage
from Units 2 and 3. The location of these detectors was determined to be susceptible to
failure due to flooding , power spiking, and power outages. In such conditions, waste
sewage is diverted to an on-site holding tank in order to conduct sampling prior to off-site
release . Accordingly, there is no safety significance to these RMS system failures. The
inspector confirmed that the licensee has implemented appropriate remedial actions for
these occurrences, and has initiated actions to improve the operating environment and
detector function to reduce the out-of-service time.
Enclosure
4
Entergy has identified the Unit 2 RMS as an upgrade project in its Top Ten Action Plan
for 2009. System engineering activities have been initiated for this improvement activity.
The inspector determined that the majority of identified problems with the Unit 2 and Unit
3 radiation monitoring systems were not associated with radiation detector operability or
effluent release control functions. For those instances that resulted in out-of-service
conditions, the licensee implemented appropriate compensatory measures as required
by regulatory requirements. The inspector confirmed that Entergy is engaged in RMS
. improvement activities, and has initiated appropriate corrective actions.
40A5 Other Activities
.1 Assessment of Licensee Performance Relative to Meeting the Objectives of the
December 16.2008 Memorandum Reguesting Deviation from the Action Matrix
Background:
On September 1, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent
fuel pool wall had been discovered during excavation work inside the spent fuel pool
building. Low levels of radioactive contamination were found in the vicinity. Entergy's
initial investigation of the issue revealed that groundwater in the vicinity was
contaminated with tritium. On September 20, 2005, Region I initiated a special inspection
of this matter to examine the licensee's performance and determine if the contaminated
groundwater affected, or could affect, public health and safety. Subsequently, Entergy
initiated actions to perform a comprehensive groundwater site characterization, identify
the sources, and effect mitigation and remediation of the condition.
The NRC special inspection report, issued in March 2006, assessed Entergy's
performance, achievements, and plans for more extensive site characterization, and
reported that the groundwater contamination did not, nor was likely to, adversely affect
public health and safety. In the report, and subsequent public meetings, NRC indicated
that a final conclusion would be reached after Entergy completed its groundwater
characterization initiative.
The NRC Region I continued inspection and monitoring of Entergy's activities in
accordance with successive approved deviation to the normal Reactor Oversight
Process for calendar years 2006 (ML053010404), 2007 (ML063480016), 2008
(ML073480290) and 2009 (ML083590057). During this period, the NRC staff closely
monitored Entergy's groundwater characterization efforts, performed independent
inspections and testing, and independently evaluated radiological and hydrological
conditions affecting groundwater onsite. Additionally, the NRC independently verified
groundwater releases by conducting split monitoring well sampling with Entergy and the
State of New York.
On January 11, 2008, Entergy submitted the results of its comprehensive hydrogeologic
site characterization investigation (ML080320600), and included its plan for remediation
and long-term monitoring of the on-site groundwater conditions. In its report, Entergy
described the source of groundwater contamination to be from the Unit 1 and Unit 2
spent fuel pools. The NRC documented its review of Entergy's report in inspection report
05000247 & 05000003/2007010 on May 13, 2008 (ML081340425). In a subsequent
inspection 05000247/2008004 (ML08311 0566) dated November 6,2008, the NRC
Enclosure
5
confirmed that Entergy's conceptual site model of the site, which included both the
vadose zone and saturated zone processes and conditions, effectively characterized the
onsite groundwater plume behavior and radionuclide transport. Evaluation of
radionuclide concentrations and pathway analyses indicated that the groundwater
contamination did not adversely affect public health and safety. Detailed discussions
and analyses indicated that the licensee's plans for long-term monitoring of the site,
relative to monitoring natural attenuation of residual groundwater contamination, were
reasonable.
On November 3, 2008, Entergy completed Unit 1 spent fuel pool system drainage and
sludge removal activities, essentially terminating the source from that facility. Given the
change in conditions, Entergy initiated actions to establish a new groundwater
contaminant baseline in support of its long-term monitoring program.
a. Inspection Scope
The most recently approved Memorandum of Deviation, i.e., "Request for Renewal of
Deviation to the Action Matrix to Provide Heightened NRC Oversight of the Onsite
Groundwater Monitoring at the Indian Point Energy Center," dated December 16, 2008
(ML083590057), identified the following objectives to be addressed in order to support
resumption of normal inspection activities in accordance with the Reactor Oversight
Process:
- Entergy has completed sufficient data collection and assessment to establish a
new groundwater contaminant baseline, now that the Unit 1 source term has
been terminated.
- Entergy has determined whether active leakage has been terminated or
continues to persist in regard to the Unit 2 spent fuel pool; and has implemented
appropriate monitoring and control measures, as necessary.
- Entergy has established and implemented effluent control and environmental
monitoring procedures that provide reasonable assurance that the existing
groundwater conditions will continue to be effectively monitored and assessed,
that the procedures will detect new or changed conditions in a timely manner, and
that the procedures are sufficient to monitor natural attenuation of the Unit 1 and
Unit 2 groundwater contamination plumes.
The NRC team reviewed the licensee's performance and achievements relative to the
completion of these objectives.
b. Findings and Observations
No findings of significance were identified.
The inspectors determined that Entergy completed the actions necessary to satisfy the
objectives delineated in the approved Memorandum of Deviation, dated December 16,
2008, (ML083590057). Notwithstanding, NRC will continue to monitor performance in
this area, and re-assess the need for continued heightened inspection oversight as part
of the CY 2009 end-of-cycle performance review of IPEC.
Enclosure
6
The following pertains:
- Objective 1: Completion of sufficient data collection and assessment to establish
a new groundwater contaminant baseline, now that the Unit 1 source term has
been terminated.
As a result of the defueling, drainage, and de-sludging of the Unit 1 spent fuel pool
system in the Fall of 2008, the groundwater contamination source term from the Unit 1
facility was terminated. The inspectors confirmed that Entergy's subsequent data
collection and assessment activities, associated with the continual monitoring of the
residual groundwater contamination, would be sufficient and effective to establish a new
baseline relative to monitoring the residual groundwater condition and subsequent
assessment of dose consequence.
As expected, the first and second-quarter ground-water sample results in 2009, collected
from Monitoring Wells in the immediate vicinity of the Unit 1 spent fuel pool, indicated an
increase in Sr-90 groundwater concentrations . As determined from review of the
licensee's data and analysis, this increased concentration was the expected result of the
volume of water that was necessary to fill the spent fuel pool system to effect defueling.
Accordingly, Entergy's baseline data was predicated on the existing groundwater
conditions determined from its continuing analysis of collected monitoring data. Given
that the original source of the contamination associated with leakage from the Unit 1.
spent fuel pool system has been terminated , the residual groundwater contamination
involving Sr-90 is expected to naturally attenuate over time. The inspectors confirmed
that the current groundwater contaminant concentrations have not, nor are expected to,
affect public health and safety; and the public radiological dose consequence is
expected to continue to be a fraction of the NRC annual regulatory limit affecting liquid
effluents. The inspectors confirmed that continual monitoring of the migration and
attenuation of the Unit 1 associated groundwater contamination condition is being
performed in accordance with Entergy's Long-Term Ground-Water Monitoring Program
(LTGWMP).
The inspectors confirmed that Entergy has established , implemented and maintains a
long-term ground-water monitoring program that has sufficient in scope and
implementation requirements to effectively monitor and assess this condition .
Accordingly, the intent of this objective was considered satisfied.
- Objective 2: Determination whether active leakage has been terminated or
continues to persist in regard to the Unit 2 spent fuel pool, and that appropriate
monitoring and control measures have been implemented , as necessary.
Entergy has been actively engaged in analyzing Monitoring Well data associated with the
H-3 (tritium) groundwater contamination condition that resulted from previously identified
leakage from the Unit 2 spent fuel pool: Entergy's analysis indicated an overall .
decreaSing trend in tritium concentration in the groundwater as a result of previous
efforts to examine the condition of the spent fuel pool and transfer canal liner, and effect
repair, as necessary. Notwithstanding , as previously reported , Entergy's examination of
the spent fuel pool liner was necessarily limited to only the accessible surfaces. That is,
only about 40 % of the total liner surfaces were accessible for examination; the
remaining surfaces were necessarily inaccessible due to the proximity of stored spent
fuel that prevented examination.
Enclosure
7
The inspectors reviewed the licensee's analysis derived from groundwater monitoring
data, and confirmed that there was no apparent indication of any significant large flux on-
going active leakage. The inspectors also reviewed the licensee's monitoring well
detection sensitivity data, which supports that active leakage, if occurring, would likely
not exceed 30 gallons per day (0.02 gpm). This sensitivity analysis was based on
comparison of the tritium concentration that is available in the spent fuel pool and the
actual tritium concentration derived from samples collected from relevant monitoring
wells in the near vicinity of the spent fuel pool. Additionally, the inspectors reviewed
licensee analysis and data from a long-term tracer test that indicated the potential for
slow, episodic tritium migration in the fractures of the vadose zone that affect the mobility
of contaminated groundwater from the immediate vicinity of the Unit 2 spent fuel pool to
the water table. The licensee's analysis is supported by the fact that fluorescine dye,
which was injected as part of the groundwater characterization study over two years ago,
is still detectable in certain nearby monitoring wells.
The inspectors noted that there were occasional spikes and general variability in some
monitoring well tritium concentration values that were not characteristic of the expected
attenuation that would normally be expected at this time . Additionally, the licensee
continued to occasionally collect a small quantity of water from the leak collection box
that was installed on the Unit 2 spent fuel pool wall crack that was identified in 2005.
Accordingly, while there was no indication of any significant large flux active leakage,
there was insufficient basis to conclude that there is absolutely no persistent low flux
leakage from the Unit 2 spent fuel pool, at this time.
Notwithstanding, the inspectors determined that the licensee's sensitivity analysis of
groundwater monitoring data, relative to its ability to detect active leakage in excess of
about 30 gallons per day, was reasonably derived. Additionally, the inspectors
confirmed that the current groundwater conditions, even if there was persistent low flux
leakage from the Unit 2 spent fuel pool, has not, nor would be expected to, affect public
health and safety; and the public radiological dose consequence would be expected to
continue to be a fraction of the NRC annual regulatory limit affecting liquid effluents. The
inspectors confirmed that continual monitoring of the migration and attenuation of the
Unit 2 associated groundwater contamination condition was being performed in
accordance with Entergy's Long-Term Ground-Water Monitoring Program; and that the
program implemented appropriate monitoring and control measures for this condition.
The inspectors confirmed that Entergy has established, implemented and maintained a
long-term ground-water monitoring program that has sufficient scope and
implementation requirements to effectively monitor and assess the present condition .
Further, the licensee is considering monitOring in the vadose zone , in the vicinity of the
Unit 2 facility, to assist in the detection of large flux releases . Accordingly, the intent of
this objective was considered satisfied.
- Objective 3: Establishment and implementation of effluent control and
environmental monitoring procedures that provide reasonable assurance that the
existing groundwater conditions will continue to be effectively monitored and
assessed, that the procedures will detect new or changed conditions in a timely
manner, and that the procedures are sufficient to monitor natural attenuation of
the Unit 1 and Unit2 groundwater contamination plumes.
Enclosure
8
The NRC has conducted several inspections (August 2007, October 2008, and August
2009) of the licensee's Long-Term Ground-Water Monitoring Program. The inspectors
confirmed that Entergy has established, implemented and maintained a Long-Term
Ground-Water Monitoring Program that was sufficient in scope and implementation
requirements to effectively monitor and assess the existing contaminated groundwater
conditions affecting the Indian Point Energy Center.
During this inspection, the inspectors examined the refurbishment of the LaFarge No.2
Monitoring Well (one of the principal off-site monitoring wells) and confirmed its
acceptability as a valid off-site monitoring location. Additionally, the inspectors verified
that the administrative controls, established in the Long-Term Groundwater Monitoring
Program, were sufficient t9 provide assurance of review and appropriate communication
of activities and changes that affect ground-water monitoring conditions; and that the
program included sufficient sampling requirements for storm drains and the Unit 1
foundation drain systems.
During this inspection, the inspectors reviewed a March 25, 2009 instance involving the
licensee's detection of tritiated water in the catch basin of a storm drain in the vicinity of
Unit 3, and in an adjacent shallow monitoring well. The licensee conducted an extensive
investigation but was unable to find an explanation for this one-time occurrence. The
inspectors confirmed that the occurrence had no radiological consequence onsite or
offsite; and no leakage was identified from any Unit 3 component containing tritiated
water. However, the nature of the occurrence indicated uncertainty in the ability of the
existing Unit 3 monitoring wells to detect potential leakage from that facility. While there
was no current on-going leakage affecting the groundwater at Unit 3, Entergy initiated
action to re-evaluate the Unit 3 groundwater monitoring configuration (both vertically and
horizontally) to determine its effectiveness in meeting the objectives and
recommendations of the NEI "Industry Groundwater Protection Initiative- Final Guidance
Document, August 2007" (ML072600292 and ML07261 0036); and amend the Long-
Term Groundwater Monitoring Program, as necessary.
Notwithstanding, the inspectors confirmed that Entergy has established, implemented
and maintained a Long-Term Ground-Water Monitoring Program that has sufficient
scope and implementation requirements to effectively monitor and assess the existing *
groundwater conditions affecting Indian Point Energy Center. Accordingly, the intent of
this objective was considered satisfied .
.2 Groundwater Sampling
a. Inspection Scope
During the licensee's groundwater investigation, over 1200 groundwater samples were
collected and analyzed from the established on-site monitoring well network by the
second quarter of 2009. The analytical results provide the basis for assessing the extent
of the groundwater plume and for performing calculations of offsite doses to members of
the public. In order to assess Entergy's performance in this area, the NRC implemented
an independent split sample collection program with the licensee beginning in
September 2005. The monitoring wells selected for independent verification included
the southem boundary wells and those wells bordering the Hudson River that were used
Enclosure
9
in support of effluent release and dose assessment calculations. Sample identity was
assured by chain-of-custody procedures that included sample collection observation by
the NRC or a representative of the NYS DEC. The NRC samples were analyzed by an
independent govemment laboratory to ensure validation of the licensee's groundwater
contamination results and off-site environmental sample radioactive measurements.
By the second quarter of 2009, over 300 split groundwater samples were obtained to
provide an independent check of Entergy's analytical results and to independently verify
if there was any detectable migration of groundwater contaminants offsite. These split
samples represent over 1,200 analyses, primarily for hydrogen-3 (tritium), strontium-90,
nickel-63, and gamma-emitting radionuclides that characterized the effluent releases.
Analyses for other radionuclides were performed, but none were detected.
b. Findings and Assessment
No findings of significance were identified.
In general, Entergy's groundwater measurements of radioactivity were of good quality
and of sufficient sensitivity to assess radiological impact. The quality of Entergy's
measurements were confirmed by various split samples analyzed by the NRC. Of the
over 1200 results that were reviewed, there were only a few sample disagreements
based on the statistical comparison criteria specified in NRC Inspection Procedure
84750, "Radioactive Waste Treatment, and Effluent and Environmental Monitoring." As
a result of these few discrepancies, Entergy took corrective action to establish,
implement, and maintain procedures to effect improved quality control and assurance of
sample analysis performed by its own laboratory and contract analytical laboratories.
During the past 3)1" years, the on-site groundwater transport pathway has been
effectively characterized by the licensee, and a significant quantity of on-site groundwater
monitoring data has been collected and analyzed by Entergy. A representative numbers
of split samples have confirmed the overall efficacy of the licensee's analytical capability.
As the site characterization was tested through pumping and tracer testing, the
contaminant plume uncertainty has been significantly reduced . Given this
accomplishment, and the NRC determination that Entergy has demonstrated an effective
groundwater sample quality control program, the NRC will discontinue any further split
sampling activities.
40A6 Meetings, including Exit
.1 Exit Meeting Summary
The inspectors presented the inspection results to Mr. D. Mayer and other licensee and
New York State representatives on August 19, 2009 and September 4, 2009. The
licensee acknowledged the findings presented. Based upon discussions with the
licensee, none of the information presented at the exit meeting and included in this report
was considered proprietary.
Enclosure
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Pollock Site Vice President
M. BaNenik Principal Engineer, GZA Geo EnVironmental, Inc.
P. Conroy Director, Nuclear Safety Assurance
D. Croulet Licensing Engineer
P. Donahue Chemistry Specialist
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. Michetti RMS System Engineer
J. Peters Plant Chemist
D. Rusczyk Environmental Assessment, GZA
S. Sandike Chemistry ODCM Specialist
J. Simpson Environmental Assessment, GZA
R. Walpole Manager, Licensing
New York State Inspection ObseNers
L. Rosenmann Engineering Geologist, New York State, Department of Environmental
ConseNations
INSPECTION PROCEDURES USED
71122.01 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
LIST OF DOCUMENTS REVIEWED
Annual Radiological Effluent Release Reports - 2007 and 2008
Off-Site Dose Calculation Manual, Revision 2
O-CY-2730, Rev. 1, Airbome Radioactive Effluents
O-CY-2740, Rev. 1, Liquid Radioactive Effluents
IP-SMM-CY-001, Rev. 7, Radioactive Effluents Control Program
IP-SMM-CY-110, Rev. 3, Radiological Groundwater Monitoring Program
2-CY-2625, Rev. 14, General Plant Systems Specifications and Frequencies
3-CY-2325, Rev. 8, Radioactive Sampling Schedule
2-S0P-5.2.4, Rev. 33, Calculation and Recording of Radioactive Gaseous Releases
2-S0P-5.1.5, Rev. 34, Calculation and Recording of Radioactive Liquid Releases
3-S0P-WDS-014, Rev. 25, Liquid Waste Releases
Attachment
A-2
3-S0P-WDS-013, Rev. 25, Gaseous Waste Releases
EN-RP-113, Response to Contaminated Spills/Leaks
EN-CY-109, Sampling and Analysis of Groundwater Monitoring Wells
EN-CY-108, Monitoring of Non-Radioactive Systems
"Industry Groundwater Protection Initiative
- Final Guidance Document, August 2007" (ML072600292 and ML072610036)
Unit 2 Liquid Release Permit No. 090016
Unit 2 Gaseous Release Permit No. 090126
Unit 3 Liquid Release Permit No. 090081
Unit 3 Gaseous Release Permit No. 090067
Condition Reports:
CR-IP3-2007 -0803 CR-IP2-2009-1334 CR-IP2-2009-1295
CR-IP2-2009-2089 CR-IP2-2009-2352 CR-IP2-2009-2090
CR-IP3-2009-3356 CR-IP3-2009-3201 CR-IP2-2009-2603
CR-IP2-2009-2528 CR-IP3-2009-3254 CR-IP3-2009-320S
CR-IP2-2009-3307 CR-IP2-2009-3306 CR-IP3-2007 -3953
CR-IP3-2007-3954 CR-IP3-2007-3925 CR-IP3-2007 -41S3
CR-IP2-200S-0270 CR-IP2-2007-5226 CR-IP2-2007-5217
CR-IP2-200S-0375 CR-IP2-200S-0549 CR-IP2-2008-1149
CR-IP3-200S-071S CR-IP2-200S-0960 CR-IP2-2008-0404
CR-IP2-200S-0377 CR-IP2-200S-0144 CR-IP2-2008-0492
CR-IP2-2009-2266 CR-IP3-200S-0569 CR-IP3-2008-0S46
CR-IP2-200S-1236 CR-IP3-200S-0852 CR-IP2-2008-0179
CR-IP3-2007 -3860 CR-IP3-2008-0942 CR-IP2-2008-3154
CR-IP3-200S-1112 CR-IP2-2008-2468 CR-IP3-2008-0194
CR* IP3*200S*2915 CR-IP3-2008-1215 CR-IP2-2008-3526
CR*IP3*200S*1042 CR-IP2-2008-2581 CR-IP2-2008-2691
CR* IP2*200S*2767 CR-IP3-2008-1218 CR-IP3-2009-00S0
CR*IP2*200S* 4136 CR-IP3-2008-200 1 CR-IP2-2008-2955
CR* IP3*200S*2184 CR-IP2-2008-3342 CR-IP2-2008-3492
CR*IP2*200S*3662 CR-IP3-200S-1S99 CR-IP3-2008-1979
CR*IP3* 200S*2125 CR-IP2-200S-4193 CR-IP2-2008-4108
CR*IP2 c200S*4130 CR-IP2-200S-4254 CR-IP2-2008-4202
CR*IP2*200S*4529 CR-IP2-200S-4337 CR-IP3-2008-2296
CR*IP2-200S-4191 CR-IP3-200S-2279 CR-IP3-2008-2294
CR-IP2-200S-456S CR-IP3-2008-0624 CR-IP3-2007-0005
CR-IP3-2007-0151 CR-IP3-2007-3367 CR-I P3-2007-27 48
CR-IP3-2007 -2S99 CR-IP3-2007-3061 CR-IP3-2007-2S70
CR-IP3-2007 -2134 CR-IP3-2007 -3075 CR-IP2-2008-1132
CR-IP3-2007-3129 CR-IP2-2008-4S48 CR-IP3-200S-2S62
CR-IP2-2008-4981 CR-IP2-200S-5055 CR-IP2-2009-0477
CR-IP2-2008-5552 CR-IP3-2009-003S CR-IP2-2009-01S4
CR-IP2-2009-0609 CR-IP2-2009-1125 CR-IP3-2009-0494
CR-IP2-2009-0565 CR-IP2-2009-079S CR-IP3-2009-0591
CR-IP2-2009-223S
Attachment
A-3
NRC Groundwater Sample Result Documentation ICY 2009. 1st Quarter)
ML090400502. ML090920949. ML090920932
LIST OF ACRONYMS USED
FSAR Final Safety Analysis Report
GPM gallons per minute
LTGWMP Long Term Ground-Water Monitoring Program
NYS DEC State of New York Department of Environmental Conservation
ODCM Offsite Dose Calculation Manual
pCi/L pico-Curies per Liter
PI&R Problem Identification and Resolution
Rap Reactor Oversight Process
Attachment