Partnering with Onsite Departments to Implement the New Environmental Regulations

1. Partnering with Onsite Departments to Implement the New Environmental Regulations Steve Sandike, Entergy NNE, Indian Point Energy Center

2. Involve Multiple Departments • Help ensure compliance with the objectives of the various regulatory environmental guidance. • Target watchstanders, technicians, managers, Operations, Maintenance - and yes, contractors too. • Institutionalize processes and the overlaps between them.

3. Additional Purpose Environmental Regulation for which specific OVERLAP and interconnection should be identified: • NEI 07-07, Env Protection Initiative (groundwater) • ANI 07-01, Litigation-related environmental issues • NRC inspection module and Temp Inst (TI) • EPRI guidelines (1015118) • Well known processes like RETS, REMP, site programs like IE Bulletin 80-10, 10CFR50.75g

4. Problem Statement • Chem/RP responding to an “emergent” issue every time it comes up will ensure only one thing: Continued (independent) Events and Resulting Chem/RP Response ! • Goal is to implement some “prevention” and ensure cognizance PRIOR to events, (simultaneously using talents of ALL departments).

5. Understand the Scope • Incorporate NEI/ANI new material into initial and continuing training programs, (especially NPOs) and visit the classroom as Subject Matter Expert (SME). • Training is great… might even work, but it won’t ensure “institutionalized” capture. • Need to make a list of site programs and procedures or manuals covering them. • Properly imbed requirements into these programs and test, reinforce, or otherwise elevate cognizance with mass communication tools like a daily bulletin.

6. General Employee or Initial Training • Tough to add site-specific issues to GET these days, as this product is “fleet” oriented. • Fortunately, this is a FLEET initiative ! • Find a way to get a few sentences into initial training. (Groundwater awareness, secondary fluid, H-3, spills, etc. There are usually “fleet” procedures for these things, so it shouldn’t be superfluous to mention them.)

7. Groundwater Site Management Manual • Like most programs, better if there is one site contact (at least easier to inspect) • Establish elements of the radiological groundwater monitoring program • Define overlapping programs, eg: RETS, REMP, 80-10 (surface water), & 75g • Establish actual LLDs or Lc values used • Define scope of the RGWMP and the cross-over point to other programs

9. PWR secondary fluid • Historically considered free of activity or political concern when no Pri to Sec Leak • Steam trap drains and airborne vents are releases, especially if plant steam is used for heating. • SG atmospheric vents are intermittent pathways • SG blowdown and flash tank vents are generally already in the ODCM • OK, no gamma, but there is certainly H-3 • Site programs should be “ready” to adequately respond to the concept of actual gamma contamination from a Pri to Sec leak, unless you want to learn under fire !

10. Is it all an “effluent” release • Original Tech Specs/ODCM may be unclear, or refer to “turbine hall drains”. Is this all condensate? • Is general secondary system loss better captured under the IE Bulletin 80-10 program? • Evaluate and specify in the ODCM whether secondary system losses are being treated as an “effluent” pathway, or with a more global 80-10 evaluation. • Whether it’s 80-10 or effluent, secondary system losses must STILL be accounted for and analyzed for offsite dose potential (10CFR20).

11. Batch Release Points Vents Cont. Release Main Monitor Point Condenser Tanks Liquid Cont. Waste R15 Release Point R18 Condenser Air-eject See Recirc Figure 2-1 River (on high alarm) R14 R11 R12 PV Vapor Containment R27 Primary Auxiliary Building Fill R20 O RCV-014 Waste Gas Cont. Tanks Release Point Fuel Storage Building R59 Cont. Release Radioactive Point Machine Shop Turbine R46 Cont. Release Administration Points Building #32 Aux Feed Pump Excess Steam Vent Main Steam Atmospherics and Safeties S/G B/D Flash Tank R19 Vent STEAM Steam #32 Aux GEN Generator Feed Pump Blowdown Flash Tank to to BDR River

12. Heating Steam • Some plants have decided to “suspend” operation of Aux Boilers, in favor of using plant steam, reduced to ~150 psi, for plant service needs, like heating. • Most designs include auto-termination of this steam supply on a rad monitor alarm (having nothing to do with H-3 !). • Original 50.59 may have NOT included enough thinking regarding trace levels of H-3 ! • Clearly not a large effluent impact, but may present trouble with demonstrated compliance with Part 20. • IPEC captured this issue with 80-10 bounding calc.

13. Summarizing ODCM requirements (the ones we all know inside out) • Ensure significant pathways are identified (SG Blowdown Flash Tank vent, other vents, SG atmospherics or safeties) • Recognize there are hundreds of tiny pathways for steam releases (traps, gland seal, leaks, heating steam, etc) • Most of these are better “evaluated” with 80-10 • They will contribute to surface water H-3, along with washout • Define your own boundary between 80-10 & effluents

14. OK, the program is complete, but • Thinking that secondary fluid is “FREE” of radioactivity is a misunderstanding that may take some work to correct. • Yes, usually OUR work. • So let’s be pre-emptive, especially with Ops and Public Relations.

15. Examples of Department Interface • Operations or Maintenance is required to drain a portion of a secondary system. • Imbed in their procedures a required interface with Chem or RP to determine disposition of water. • Electrical vaults, or any hole in the ground requiring pump-out of water prior to inspection or repair. • Standing water in these holes should be consistent with area groundwater contamination levels.

16. Ensure these lessons are not lost • Don’t rely on training, skill of the craft, good graces, etc, for departments to call you and resolve questions. • Work with departments to INCLUDE in their work orders or procedures, a STEP that directs them to contact you. • This also helps general communication on the entire NEI 07-07 objective.

17. IPEC Experience 1 • Investigating an increase in surface water tritium in a few storm drains has increased awareness of NEI 07-07 across the site. • Initiated discussions of measuring washout. • Opens a new investigation of underground pipes. • While it might be difficult, must avoid accusatory tone when interviewing watchstanders. • Widespread communication of purpose and highly visible program can help smooth out investigations.

18. IPEC Experience 2 • Investigating an increase in Groundwater H-3: • Without confidence in the buy-in from other departments, we would need to compile a list of the many condition reports mentioning “leak”, searching for a possible connection. • Hardly an effective way to manage a program. • Nowadays, ALL organizations on site should recognize the value of preventing groundwater contamination, and NOT imagine that it’s something for Chem/RP to mitigate !

19. IPEC Experience 3 While outdoor “spills” or “leaks” are managed with a fleet procedure implementing NEI 07-07, and relatively inclusive, INDOOR spills in areas with concrete, unlined sumps, can still pass the H-3 to the environment, perhaps without the knowledge of the groundwater specialist or Sr. Management! We suggested an update to the fleet procedure accordingly.

20. IPEC Experience 4 • A unit trip involved a partial loss of vacuum and subsequent decision to use the SG atmospherics to help control cooldown rate. • These steam releases are supposedly routine, but actually quite rare these days. • They are highly visible (and audible)! • Public Relations submitted a press release announcing the plant shutdown, and “no release”. • NRC questioned this press release, due to our new cognizance of H-3 as a contaminant, even in SGs where there is no declared Pri to Sec leak.

21. How do we fix this? • Certainly, we can’t imagine the industry will suddenly REFRAIN from using atmospheric dump valves when needed. • There’s more ways of getting H-3 into the ground than just outdoor spills… • Knowing the extent of your H-3 “washout” helps to balance efforts during investigation of potential underground pipe leaks. • Even if you are NOT trying to subtract out the “washout” tritium from your surface waterborne H-3

22. Use of SG atmospherics • Develop talking points or phrases for PR • If “No Release” is unacceptable, then try to describe ‘normal’ operation, or “releases consistent with plant design”, or “well below regs”, etc. • Differentiate Pri to Sec Leak from H-3 “migration” • Ensure programs/procedures include an evaluation. • Can be quantified with aux feed flow, valve position indication, SG pressure/level, various other parameters. • Probably a ground level release • Release = ~0.05 curies, ~1E-5 mrem. This small fraction of PWR routine H-3 releases should be documented.

25. Improving NEI implementing procedures • Requested an update to the fleet procedure for implementing NEI guidelines with regard to spills/leaks to include INDOOR spills where an unlined concrete sump may be involved. • Updated procedure definition of reportability for NEI 07-07. • Collecting some precipitation for H-3 measurement (qualitative only).

26. The Chemistry Department, in conjunction with industry OE, is collecting precipitation (rainwater) over the next several months. Our objective is to periodically collect and analyze the water for natural amount of contaminants, like tritium. The collection devices are simple, covered orange buckets, staged in ten different locations on site. The buckets include and internal water collection bottle, and a funnel atop the bucket. Please do not tamper with them. If you suspect a problem or have questions, please call or email Steve Sandike @ 8455, Brent Magurno @ 8444, or the Watch Chemist @ 5150 or 8460.

27. It’s on Ongoing Effort, Not a One-Time Fix