ML061000470

E-mail from D. Croulet of Entergy to J. Noggle of USNRC, Regarding ACE MW-111

ML061000470
Person / Time
Site:	Indian Point
Issue date:	11/22/2005
From:	Croulet D Entergy Nuclear Operations
To:	Noggle J Division of Reactor Safety I
References
FOIA/PA-2006-0081
Download: ML061000470 (9)

Text

JamessIcl FW-: ACE MW-1 1 1.doc

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Subject:

"Cret, Donald" <dcroule@entergy.com>

"'jdn nrc.gov"' <jdn~nrc.gov>

11/22/05 2:53PM FW: ACE MW-1.doc

Jim, FYI as requested.

From: Axelson, William L Sent: Tuesday, November 22, 2005 2:50 PM To: Leach, Don; Sachatello, Ronald; Hinrichs, Gary; Bode, Paul M.; Croulet, Donald; Skonieczny, John

Subject:

ACE MW-11.doc

<<ACE MW-i1ll.doc>>

Here is Ihe final ace in put into PCRS with agreed upon Cas and dates CC:

"Conroy, Pat" <PConroy@entergy.com>, "Comiotes, Jimr"

<JComiot@entergy.com>.,

"Leach, Don" <DLeach~entergy.com>, "Mayer, Don" <DMayerl @entergy.com>, "Cox, Mark R"

<mc:ox9 )entergy.com>,

"Jones, T. R." <tjones2@entergy.com>

LOWER-TIER APPARENT CAUSE Sheet 1 of 8 REV 0 Condition Report Number:

Assigned Department:

CR-IP2-2C'05-03986 and IP2-2005-04151 Radiation Protection Radiation Protection PROBLEM STATEMENT: (The WHAT)

Onsite monitoring wells indicated elevated to trace levels of tritium radioactivity. MW-i 11 (IP2 transformer yard well) showed tritium concentrations of 211,000 pCi/I and IP3 wells(near the Unit 3 turbine bldg. and discharge canal) showed tritium concentrations ranging from 417 to 960 pCiI, and two core bore wells beneath the Unit 3 turbine bldg showed tritium concentrations rangin~g from 703 to 1,590 pCi/I. No other plant related radioisotopes were identified in all samples.

A four hour notification report was made to the NRC pursuant to 10CFR50.72, and several other governmental agencies and other stake-holders were also notified.

EXPLANATION OF PROBLEM: (The HOW)

On September 29,2005(date of sample), tritium radioactivity from an onsite monitoring well was found lo have 211,000 pCi/I tritium, which is above the ODCM reporting limit of 30,000 pC/I.,

This wellrvia'sp're'vibo'u'sly established in early 2000 for the monitoring of contaminates-'su.h'cas'oil and PC'Bs, in preparation for the sale of IP2 to Entergy. The well (MW-111), is located inside the site protective area in the Unit 2 transformer yard, an area near both the Unit 1 and 2 fac:ilities.

The well was last sampled for radioactivity (tritium and gamma spectra analysis) in March 2000, and the results showed no detectable plant related radioisotopes. In addition, three other onsite monitoring wells were sampled (MW-1 07,108 and 111) to investigate past leakage associated with the Unit 1 spent fuel pools. These samples also showed no detectable plant related radioisotopes. None of these wells were subsequently sampled for radioactivity until OctDber 2005 as part of the investigation into the apparent Unit 2 spent fuel pool liner leak. These wells were sampled periodically for oil and PCBs only. In mid October 2005; five additional wells were sampled in the general vicinity of the Unit 3 turbine bldg. and discharge canal. Trace concentralions of tritium were identified as discussed above. On November 3, 2005, a 30-day report was filed with the NRC describing these issues and future corrective actions. For perspective, the EPA drinking water regulations (40CFR141) limits tritium to 20,000 pCVI. All of the onsite wells are for monitoring only and not sources for drinking water for onsite workers or the public Since discovery of elevated tritium activity in these wells, a weekly sampling program wats established. Tritium concentrations in MW-i 11 have essentially remained constant except for a one week period of heavy rains in mid October. During that period, tritium concentrations significantly dropped to 6,820 pCi/I. However, one week later, its concentration returned to 284,000 pCi/I, and has generally remained constant between 250,000 to 300,000 pCi/I as of November 10, 2005. Tritium concentrations in the other Unit 3 wells also varied somewhat since discovery. U3-1, U3-2, and U3-4 wells now are less than detectable and have been for the last four weeks. U3-3 well is still exhibiting very low levels of tritium at 471 pCi/l, and the two core bore well samples beneath the Unit 3 turbine bldg. are showing low levels of tritium at 563(T-1) and 1635(T-2) pCi/I respectively. T-1 samples were less than detectable for the last four weeks and now(1 1/10/05) is detectable, where as T-2 has consistently showed tritium concentrations ranging from 1420 to 1600 pCVI. T-2 is at the north end of the five foot elevation and T-1 is at

LOWER-TIER APPARENT CAUSE Sheet 2 of 8 the south end five foot elevation. Of interest, is T-2 tritium concentrations did not vary significantly after the site heavy rains from mid-October 2005.

IPEC has an offsite radiological environmental monitoring program (REMP) which routinely samples offsite drinking water sources and other special water sources for radioactivity.

Quarterly drinking water samples are taken the Campfield reservoir in Peekskill, NY and the Croton reservoir. Further, samples are taken from an abandoned well (5th street well) in Verplanck. which is no longer used as a drinking water source. Monthly special water samples are also taken from two near site outfalls (Algonquin and Gypsum streams), both of which discharge directly to the Hudson River just of the plant's owner control area. Also, samples are taken at an abandoned flooded rock quarry located in Verplanck. These special sample locations were chosen specifically to monitor any potential offsite tritium releases from the known Unit 1 SFP leakage. Historical sampling results for all of these locations have shown no detectable plant related radioactivity for the past ten years or since new monitoring locations were added to the REMP program. The Algonquin outfall was first sampled in 1996 and the 5th street well in August 2002. There are no other known well water drinking water sources near the site.

,: I;1 Special independent samples of MW-i 11 were analyzed by Teledyne and confirmed the accuracy of IPEC's laboratory and Fitzpatrick's laboratory for tritium and gamma spectra analysis. Further this well was sampled for Sr-90 and Ni-63, two additional hard-to-detect isotopes of interest as it relates to plant operations, and no detectable activity was identified.

The NY Department of Conservation split samples with IPEC at all wells where tritium was detected and their results were in very good agreement with IPEC's results.

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,,.I, A, To date, IF'EC has contracted with a hydrologist firm and other knowledgeable consultants to determine the source(s) of groundwater contamination, the general groundwater flow direction and flow rates, and to determine what additional monitoring is necessary. Currently, an onsite well monitoring modification project has been approved for the installation of nine new wells.

These wells are currently being installed.

An evaluation of the potential radiation doses to offsite receptors from the ground water contamination was done assuming the water went directly to the Hudson River and was not diluted via the discharge canal. Only near site dilution was considered. The exposure pathways considered are the ingestion of contaminated drinking water and of fresh-water fish. The calculations showed potential doses to any organs of an offsite receptor were less than 1.0 E-04 mrem/quarter, significantly lower than the ODCM quarterly limits of 1.5 mrem to the whole body and 5.0 mrem to any organ.

The following actions are necessary in order to determine final cause(s) of the tritium groundwater contamination to onsite monitoring wells;

• Conplete the K-T root cause analysis already underway to determine final causes of tritium contamination to onsite monitoring wells-EngineeringlWPO Conplete installation of the onsite monitoring well modification project, Phase one-Facilities

• Co nplete hydrologist study of site ground water physical parameters such as water flow

LOWER-TIER APPARENT CAUSE Sheet 3 of 8 rate, direction and discharge points to offsite environment-Eng Determine if additional onsite monitoring wells are necessary(Phase 2) in order to determine more accurate ground water flow/direction and sources of ground water contamination, plume definition, and potential site remediation-Eng Determine if tritium ground water contamination warrants remediation--RP Develop and implement ground water tracer program for various onsite systems or facilities of interest to determine sources of ground water contamination-Eng Develop a long term onsite well monitoring program including sample frequency, training, procedures methodology, equipment needs, and sampling types-RP.

• Update site licensing documents(FSAR, drawings, etc.) to capture onsite monitoring well modification--Eng

• Identify all onsite underground piping or equipment/tanks, which contain radioactive liquids which may be a contributor to tritium ground water contamination-Eng.

Update 30-day report to NRC-Licensing Update ODCM and RG 1.21 report to reflect needed changes/outcomes from the well monitoring program results, tracer study results and hydrologist report as it relates to offsite dose calculations-from HTO releases not previous accounted for--Chem.

Identify existing site unlined sumps and radioactive storage tanks( i.e., RWST, Waste Distillate tanks, etc.) which may contribute to ground water contamination for inspection, repair(if necessary) and ongoing PM--Eng.

Update 1 OCFR50.75(g) file based on outcome of this investigation--RP

• Operations to benchmark other PWRs/BWRs SFP inventory practices as it relates to pool inventory, boron mass balance and leak/level monitoring capabilities--Ops.

• Add new monitoring well, MW-138(P-9) to the offsite REMP program and revise sampling procedure as necessary. Well shall be sampled to the same criteria as the other eight onsite wells-RP/NEM.

• Obtain technical assistance from EPRI organization as it relates to their experience in onsite well monitoring programs and procedures-RP

• RP, Chemistry, Operations and Engineering to discuss this CR during its continual training programs Develop OE package for dissemination to INPO--A&A.

APPARENT/CONTRIBUTING CAUSE(S): (The WHY)

ACI The apparent cause(s) of this event is currently undetermined. A special investigation team has been established to investigate these issues and a K-T root cause investigation is currently underway. The team has met several times and continues to meet as new information becomes available. A separate corrective action is issued to WPO engineering to complete the K-T analysis and issue additional corrective actions, if necessary, not discussed in this report.

Contributing causes were as follows:

CC-1)--lneffective utilization of existing onsite monitoring wells for radioactive contamination of ground water

LOWER-TIER APPARENT CAUSE Sheet 4 of 8 EXTENT OF CONDITION:

The EOC is limited to onsite ground water contamination only as no offsite contamination of any plant related isotopes was identified. The site never had any onsite well monitoring program for testing for radioactivity.

COMPLETED CORRECTIVE ACTION(S): (see Procedure step 5.4[2](e))

ISSUE / PROBLEM SOLUTION / RESOLUTION / ACTION / COMPLETED

[note any Work Orders, MODs, other]

CAl.determine offsite dose impact Completed-offsite dose assessment made and to public from HTO contamination radiological impact was determined to be significantly lower than the ODCM quarterly limits.

CA2.determine initial EOC of HTO Establish weekly monitoring program for all wells were HTO ground water contamination.

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as identified PROPOSED/ASSIGNED CORRECTIVE ACTIONS ITEM #

ISSUE/CAUSE SOLUTION I TYPE CA Assigned Due Date FICRS RESOLUTION Department CA#

[note any Work Orders, MODs, other]

CAl

.determine apparent Complete the initial Perform Eng 12/15/05 cause(s)

K-T root cause analysis already underway to determine final causes of tritium contamination to onsite monitoring wells-EngineeringlWPO CA2 Need additional Complete Perform Faclities 2/28/06 onsite monitoring installation of the wells to characterize onsite monitoring plume, water flow and well modification direction project, Phase one-Construction Need additional site Complete CA3 hydrology information hydrologist study of Perform Eng 3/31/06

_site ground water

LOWER-TIER APPARENT CAUSE Sheet 5 of 8 physical parameters such as water flow rate, direction and discharge points to offsite environment-Eng Are the new Determine if additional nine wells additional onsite Perform Eng 6/25/06 CA4 sufficient to monitoring wells are characterize site necessary(Phase 2) ground water flow?

in order to determine more accurate ground water flow/direction and sources~pf..grgund water contami'rnation, plume definition, and potential site remediation-Eng CA5 HTO ground Determine if tritium Perform RP 4/15/2006 contamination ground water exceeds EPA contamination standards warrants remediation--RP CA6 Identify which HTO Develop and Perform Eng 3/31/2006 source is implement ground contaminating MW-water tracer 111 program for various onsite systems or facilities of interest to determine sources of ground water contamination-Eng CA7 Need site well Develop a long term Perform RP 2/28/2006 monitoring program to onsite well meet objectives monitoring program including sample frequency, training, procedures

_methodology,

LOWER-TIER APPARENT CAUSE Sheet 6 of 8 equipment needs, and sampling types-RP CA8 Well modification Update site licensing Perform Eng 4/15/2006 program needs to be documents(FSAR, reflected in licensing drawings, etc.) to bases capture onsite monitoring well modification--Eng CA9 Several underground Identify all onsite Perform Eng 3/31/2006 piping systems underground piping contain HTO and may or equipment/tanks, be a contributor which contain radioactive liquids which may be a contributor to tritiuM,¶.

ground watert,.:R-r-contamination-Eng CA10 NRC; 30-day report Update 30-day Perform Licensing 4/15/2006 needs updating report to NRC-Licensing CAl 1 ODCM may need Update ODCM and Perform Chem 4/15/2006 updating/modification RG 1.21 report to if HTO is identified as reflect needed new release point changes/outcomes from the well monitoring program results, tracer study results and hydrologist report as it relates to offsite dose calculations from HTO releases not previous accounted for--

Chem CA1 2 Several liquid waste Identify existing site Perform Eng 2/28/2006 sums are unlined unlined sumps and and holding tanks radioactive storage may also be tanks( i.e., RWST, degraded all of which Waste Distillate contain significant tanks, etc.) which levels of HTO may contribute to ground water

LOWER-TIER APPARENT CAUSE Sheet 7 of 8 contamination for inspection, repair(if necessary) and ongoing PM--Eng CA13 Wells identified with Update Perform RP 4/14/2006 HTO are not captured 1 OCFR50.75(g) file in 1 0CFR50.75(g) based on outcome of this investigation--

RP CA14 U2 SFP does not Operations to Perform Ops 4/15/2006 have a tell-tail drain to benchmark other quickly identify a leak PWRs/BWRs SFP and SFP water inventory practices inventory practices as it relates to pool need to be re-inventory, boron evaluated mass balance and leak/level monitoring' capabilities--Ops CA15 One of the new nine Add new monitoring Perform RP/NEM 3/31/2006 wells is located offsite well, MW-38(P-9) to and represents a the offsite REMP potential indicator for program and revise offsite radiological sampling procedure impact as necessary. Well shall be sampled to the same criteria as the other eight onsite wells-RP/NEM.

CA16 IPEG lacks Obtain technical Perform RP 3/31/2006 experience in onsite assistance from ground water EPRI organization monitoring for HTO as it relates to their experience in onsite well monitoring programs and procedures-RP CA17 Varies department RP, Chemistry, Perform RP Eng 4/15/2006 CA18 need to brief staff on Operations and Chem CA19 lessons learned from Engineering to Ops CA20 this CR discuss this CR during its continual

_training programs

LOWER-TIER APPARENT CAUSE Sheet E of 8 CA21 Share OE with Develop OE Perform CA&

3/31/2006 industry package for dissemination to INPO-CA&A.

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