Transforming Indian Point Units into Indian Point Energy Center: A Regulatory Journey

1. Target: One ODCM From Indian Point Units 1, 2, and 3 into Indian Point Energy Center with combined regulations, commitments, methods, and controls.

2. IPEC, from the NW

3. A Brief History of Indian Point Effluents, part I • Oct 8, 1954 - Con Ed purchases 260-acre former Indian Point amusement park in Buchanan, NY (no Env Impact Study!) • Sep 16, 1962 - The reactor that would become known as Indian Point 1 begins generating power. • Dec 10, 1962 - Con Ed applies for permit to build reactor in Ravenswood, Queens –denied • June, 1963 – One SG is damaged upon installation at unit 1, lowering its capacity. (Superheater planned for additional use). • Nov 23, 1965 - Con Ed's directors approve plans to build a second nuclear reactor at Indian Point. • Apr 12, 1967 - Con Ed applies for permission to build a 3rd nuc plant at Indian Point -granted.

4. A Brief History of Indian Point Effluents, part II • Aug, 1969 – Federal rules passed regarding the need to file an Environmental Impact Statement for new licensees. • Jun 30, 1970 – IP#1 S/D due to defects in stainless steel reactor coolant piping and cost to repair. • Jun 26, 1973 – IP#2 commences low power testing but finds buckling and bulging of VC dome liner. • Oct 12, 1974 – Unit 2 goes to 100% power, but has financial difficulty due to the oil embargo and a VC liner problem. Con Ed sells Unit 3 (under construction) to the State of NY (PASNY) and made final in late 70s. • 1975/1976 - Environmental Impact (NUREG 75/002&003) filed for unit 3, which became the source of the ETSR (R=“Requirements”) • 1977 – NUREG 0472 implemented for RETS at units 2 and 3, different Revs/Drafts, making ETSR the RETS (RETS accepted) RETS = App B of Tech Spec, painfully amended frequently.

5. A Brief History of Indian Point Effluents, part III • Nov, 1974 - IP#1 is permanently S/D, lacking any emergency cooling system. • Aug. 30, 1976 - Indian Point 3 goes into operation. • Feb. 27, 1980 - Con Edison retires Indian Point 1 permanently, but not fully decommissioned. • 1982-84 – Tech Spec amendments to create ODCM. Curies released now converted to dose on site Tech Spec RETS were “prior approval”, ODCM “calculational methodologies” was 50.59 • (’89) NRC Generic Letter 89-01allowed RETS RECS to make ALL effluent controls and calcs 50.59 space. • 1994 – Unit 2 chooses NOT to implement the GL. Goes to ANNUAL effluent reports (vice 6 mo). Decision not to update based on key individual’s fear of effluents losing its “Tech Spec” relevance.

6. A Brief History of Indian Point Effluents, part IV • Apr, 2000 - unit 3 fully implements GL and new Part 20. Formed ODCM part 1 (RECS) and part 2 (Calc Methods) • Nov, 2000 – ENTERGY purchases unit 3 • Mar, 2001 – IP3 implements Improved Tech Specs • Sep, 2001 – ENTERGY purchases units 1 & 2 site consolidation begins

7. A Brief History of Indian Point Effluents, part V • Dec, 2001- First 50.59 “improvement” in unit 3 RECS with a full 50.59 for ODCM. Discovered that ODCM updates not covered as well as other 50.59 processes in Entergy Northeast. • May to Dec 2003 – “ITS” project at unit 2, which included GL 89-01. However, a conscious decision was made to KEEP the old 10CFR20 at unit 2 (creating headaches for me now….)

8. Regulatory Documents • Both sites were licensed to NUREG 0472. • IP3 adopted some improvements from NUREG 1301 after implementing the Generic Letter 89-01. • Unit 2 maintained RECS in Tech Specs, per 0472. • Westinghouse’s NUREG 1431 now in place, and ODCMs are being evaluated for format as well as bases improvement (still mostly NUREG 1301.)

9. Components of an Effluents Program • ODCM required sampling schedule (Chem) • Conversion of curies to dose (Chem) • Radiation Monitoring (Sys Eng, I&C, Chem) • Other Effluent Instrumentation flow meters, totalizers, etc (Sys Eng, Prog & Comp) • Compactions for equipment OOS (all) • Processing Liquid Effluent (WM, Ops, Chem) • Optimizing Effluents separating high/low conductivity waste(all)

10. Effluent Regulations in 1980 Tech Specs from NUREG 0472 Included: U3: RETS controls (App B) U2: Sections 3.9 & 4.10 Both: REMP controls & program definitions FSAR /--- prior approval ---------------\ /------------50.59--------------\ Plant Procedures Effluent curie data was sent to the NRC for annual conversion to dose with codes owned and run by the NRC Admin Procedures Ops Procedures Chem Procedures REMP Procedures

11. Unit 3: GL in 2000, ITS in 2001Unit 2: Entire move Jul-Dec 2003 Tech Specs FSAR ODCM /--- prior approval ----\ /-----------------50.59-------------------\ RETS: Non-radiological stays, radiological elements move. TRM ODCM Part I ODCM Part II ITS Plant Procedures

12. Why is Effluents assigned to Chemistry? • Unit 2 • Chemistry initially had program. • Key elements (and individuals) left to “Rad Support” • Separation of tasks led to holes developing, RG 1.21 errors. • Key individuals retired or re-assigned, program suffered. • Chemtechs now UNFAMILIAR with effluents and must be re-trained. Jobs re-assigned. • Unit 3 • Chemistry owned program from initial licensing. Directly involved in all aspects, including RMS BKGD evals/cals. Chemists are generally more aware of source term and risks.

13. 2003 IPEC Integration • IPEC effluents among the country’s highest (IP1, 2, & 3): • Although Chemistry owns effluents, support is required from all departments on site to reach goals of lowering totals of curies and mrem. • Release streams are now treated as an IPEC concern, not unit specific, and funding is allocated accordingly. • Plan to clean sumps, lines, tanks, more aggressively • Unit 1 Special Projects Group - cleaning SFP, etc • Unit 2 project: dry cask storage or shutdown in 2006.

14. RECS Format: 1301 or 1431? • Unit 1/2 ODCM written by vendors who also placed the RECS in 1431 format. • Unit 3 RECS is still in NUREG 1301 format and will most likely be converted to 1431 format. • REMP procedures updated to exactly match the ODCM(s), especially sample locations and names. • Site procedures will remain mostly the same, referencing unit specific ODCMs till at least Jan 2005, when ONE ODCM for IPEC is planned.

15. IPEC Effluent Challenges (unit 1/2 ) • Regardless of ODCM conversion of Ci to dose, effluents at units 1& 2 has historically been near 4th quartile (curies) due mostly to age. • Curtain Drain around unit 1 VC receiving storm drains • High conductivity, low radioactivity, but treated as waste • Some initial contamination of this stream with PCBs • Mixed waste generated, with Sr-90, Cs-137, PCBs • Created a continuous-intermittent pathway, initially handled as batch, but now cleaned up continuously. • INPO’s curie rankings are now based on the whole SITE, divided by the number of operating reactors. IPEC’s Ci’s are divided by 2, not 3, despite the large contribution from IP1. • High source term due to plant age and early bad fuel.

16. IPEC Effluent Challenges (unit 3) • Effluents at unit 3 had been near top quartile • While unit 3 performance stayed about the same, the industry improved dramatically, especially in liquid waste cleanup efforts. IP3 fell to 2nd or 3rd quartile. • NRC identified an un-monitored Noble Gas pathway (1986): • An outdoor liquid waste monitor tank vented to atmosphere – no quantification of gases from tank. • LER and bad publicity • Over-reliance on existing procedures, not enough review of bases. Led to much more aggressive 50.59 review. • History of poor modification process with regard to effluent regulations

17. Lessons Learned from self assessment on Liquid Effluents, Aug, 2003 (1 of 2) • Mixing high and low conductivity liquid waste lowers • efficiency of cleanup • Less than adequate connection between radiochemistry • and effluents • The station needs a liquid waste optimization plan • Unit 2 lacked a modern 10CFR50 tracking system for • error-free annual reports • Inter-department communication breakdowns in review • of annual report

18. Lessons Learned from self assessment on Liquid Effluents, Aug, 2003 (2 of 2) • Few people on site knew Chemistry owned effluents, even after integration. • Good effort underway in mitigating the NCD release pathway; need to celebrate this success. • Training is needed for Chemistry, Operations, Waste Management • Planned initiative to cleanup sumps and waste lines should reduce source term. • Liquid and Airborne H-3 will become the significant release isotope.

19. Integration Issues Complete • ITS and Gen Letter 89-01 complete • Finite Cloud Assumptions employed • REMP location descriptions identical • Liquid Effluent pathways identical FWF/SWI • Liquid doses calculated w SITE dilution (10CFR50) • Sampling periodicity requirements identical • Unit 1 Curtain Drain project complete and operational • 10CFR50 tracking mechanism in place • Vent H-3 quantification from SiO2, “monthly”

20. Integration issues in progress • Establish MET update periodicity for X/Q • Update the annual average MET data for IPEC • Ownership of MET and associated QA • Unit 2 must upgrade liq eff to new Part 20 • Standardize 10CFR20 controlling procs for both liquid and airborne limit sharing • VCPR quantification methods dissimilar: (flow rate * time vs Press Diff and volume)

21. Once the science is complete: • RECS for the station ODCM: • NUREG 1431 Format? • So far, reception has been lukewarm at best • How to capture sufficient info on the unit 1 “legacy” issues • Losing expertise to VSP, etc. – Program must be bundled for turnover.