Indian Point Unit 1 and Unit 2 Spent Fuel Pool Leaks - Empty Unit 2 SFP.

by Bob Meyer

The NRC issued an Inspection Report dated May 2008 and noted (from previous reports also) that a small amount of contaminated water was leaking from the Unit 2 spent fuel pool and subsequent additional subsrface groundwater contamination emanating from the Unit 1 spent fuel pool system. At that time Entergy committed to remove and transfer all spent fuel from Unit 1 Spent Fuel Pool to Indian Point's Independent Spent Fuel Storage Installation, and drain the spent fule pool by Dec 31, 2008.

Entergy is seeking a license amendment request to authorize the transfer of spent fuel from the spent fuel pool at Indian Point Nuclear Generating Unit NO.3 (IP3) to the spent fuel pool at Indian Point Nuclear Generating Unit No.2 (IP2) using a newly designed transfer canister. From there, Entergy intends to transfer the spent fuel to the independent spent fuel storage installation which already exists at the site.

Based on other issues in the industry, the NRC issued Generic Safety Issue #202, Spent Fuel Pool Leakage Impacts that also discusses issues at Salem Unit 1 and Seabrook transfer canal.

Back in September, 2005, the NRC was informed by Entergy that cracks in a Unit 2 spent fuel pool wall had been discovered during excavation work, and that low levels of radioactive contamination were found in water leaking from the cracks having radionuclides similar to Unit 2 spent fuel pool water. Entergy initiated a prompt investigation to determine the extent of the condition and potential impact on health and safety. Initially, Entergy determined that on-site groundwater in the vicinity of the Unit 2 facility was contaminated with tritium as high as 200,000 picocuries per liter of water (about ten times the EPA drinking water standard). Subsequently, Entergy initiated actions to perform a comprehensive groundwater site characterization to investigate the extent of on-site groundwater contamination, identify the sources, and mitigate and remediate the condition. This effort required the establishment of several on-site groundwater monitoring wells to characterize groundwater behavior, flow, direction, and migration pathways.

March of 2006, independent on-site groundwater sample analysis effort first determined that strontium-90 was also a contaminant in the groundwater. This determination resulted in a significant expansion of the on-site groundwater characterization effort since the source of the strontium-90 contaminant was traced to leakage from the Unit 1 Spent Fuel Pool. A full site-wide hydrogeologic investigation was subsequently scoped to include Unit 1 and Unit 3.

January of 2008, Entergy described the sources of the groundwater contamination to be the Unit 1 and Unit 2 spent fuel pools. While both pools contributed to the tritium contamination of groundwater, leakage from the Unit 1 spent fuel pool was determined to be the source of other contaminants such as strontium-90, cesium-137, and nickel-63. Entergy identified its plan to remove all fuel from the Unit 1 spent fuel pool to an on-site storage location and drain the spent fuel pool system by the end of 2008, thereby essentially eliminating the source of the groundwater contamination from that facility. Some water is expected to remain in the bottom of the pool to reduce the potential for airborne contamination and provide shielding until the residual sludge is removed in early 2009. In the January 11, 2008 report, Entergy described its actions to repair or mitigate all identified potential leak locations in the Unit 2 spent fuel pool system that may have contributed to the on-site tritium-contaminated groundwater in the vicinity of that facility.

In 1992 it was identified that the conditions surrounding the leaking Unit 1 spent fuel pool are based on a leakage rate of 10 drops per second (about 25 gallons per day) . At that time, the licensee performed a hypothetical bounding dose impact that concluded that there was negligible dose impact to the public caused by this condition. This licensee assessment was inspected and evaluated, at that time, by NRC inspectors.

September 2005, a crack was discovered leaking on the outside of the Unit 2 spent fuel pool south wall (approximately 30 feet below the top) during excavation of the spent fuel building loading bay. The NRC initiated a special inspection on September 21, 2005, to investigate the implications of the observed Unit 2 spent fuel pool leakage. Based on analysis of the radionuclide concentrations in the Unit 2 spent fuel pool and maximum bounding pool makeup losses, a bounding dose calculation based on direct release to the Hudson River indicated a tiny fraction of 1 mrem (0.00002 mrem/yr) as the estimated dose to the maximally exposed hypothetical individual. This prompted the NRC Executive Director of Operations (EDO) to authorize Region I was to conduct additional oversight inspection of licensee performance and the circumstances surrounding this contamination issue to better understand the condition and examine possible generic implications, since similar conditions had been identified at other facilities. The EDO authorized increased inspections every year for additional oversight.

During the summer of 2006, Entergy collected and analyzed fish from the Hudson River, and strontium-90 was identified in one fish collected near the plant as well as in several fish caught in a control location 20 miles upstream of the plant at similar concentrations. In order to resolve whether the strontium-90 was plant-related or the result of existing background levels (Sr-90 exists in environment due to weapons-related fallout), an expanded fish sampling program was devised by the New York State DEC.

Indian Point Contaminated Groundwater Investigation Time Line

Unit 1 Spent Fuel Pool Timeline

Unit 1 ceased commercial operations on October 31, 1974

1. April 1990: A nuclear plant operator observed higher than usual frequency of fuel pool makeup than usual, initiated an investigation by Con Edison.

2. 1991: Con Edison began sampling the north curtain drain (NCD) and sphere foundation drain sump (SFDS) for tritium and established separate liquid discharge paths.

3. May 1992: Completed calculations of unaccounted water loss – 25 gpd leakage.

4. May 1994: A task force organization was created with a Unit 1 SFP Project Manager position reporting to the Plant General Manager. Individuals from Chemistry, Operations Maintenance, Health Physics and Engineering were represented.

5. May-June 1994: NRC inspection (Drs. Bores and Jang) to investigate Unit 1 SFP leakage (50-03/94-01) Boron concentration mass balance indicated 91 gpd leak rate to the SFDS and 1.5 gpd to the north curtain drain. Tritium concentration mass balance indicated 73 gpd to the SFDS and 1.2 gpd to the NCD. Hydrogeologist study indicated that the groundwater movement was about 10 ft/day and would flow towards the quarry, not the Hudson River. No violations were identified.

6. July 1994: Whitman hydrogeology report investigation of Unit 1 SFP leak migration concluded that “most” of the leakage would be captured by the Unit 1 building foundation drain system and the rest would migrate to the South in the shallow zone and could be detected in the creek bordering south of the plant and in the Trap Rock Quarry. These sample locations were added to the REMP program.

7. August 1994: NRC inspection (Bores/Jang) to review licensee’s leak investigation (50-03/94-02). Hydrogeologist completed study indicated that groundwater at the site flowed upward and either west or south into the Hudson River. No violations were identified.

8. December 1994: NRC inspection (Bores, Jang, Erikson, Noggle) inspect compliance with Bulletin 94-01 (fuel pool potential siphoning), leak investigation, and SAFSTOR approval (50-3/94-80). Confirmation of tritium in the sphere foundation drain sump that drains groundwater from the bottom of the Chemical Systems Building of Unit 1 in May 1994, provided evidence that the Unit 1 SFP system was leaking beyond the plant structure and resulted in initiating a corrective action SAO-132 report (94-06). 10CFR50.59 evaluations between March 9, 1992 and December 1994 were reviewed and found to be complete and met requirements. In October 1994, boron concentration was increased in the SFP and fluoresce in dye tracer was added to the water storage pool to detect these sources in the NCD and SFDS. As of mid-December, no increased boron or indications of tracer were detected in either of these Unit 1 drains. Tracer did indicate that the SFDS had been discharging through a Unit 3 storm drain to the discharge canal. Con Edison subsequently rerouted this discharge by hard pipe through the Unit 1 River water system into the discharge canal. NCD was diverted to the Unit 1 sphere sump where this discharge was pumped to the liquid radwaste processing system. The on-site stream was added to REMP monitoring for tritium on a quarterly basis. No violations were identified.

9. January 2, 1996: SECY-96-01, Decommissioning Plan for SAFSTOR and amendment of license for Unit 1 was approved.

10. June-August 1996: NRC inspection (Jang) to review followup actions: modification to north curtain drain for recapture, new RMS detector installed in SFDS (50-3/96-04).

11. February-March 1998: NRC inspection (Jang) to review followup actions: effluent controls and trending of SFP inventory (50-3/98-02).

12. May-June 1998: NRC inspection (Ragland) reviewed schedule for draining and cleanout of pools (50-03/98-04). Con Edison removed all irradiated hardware from both the East and West Unit 1 SFPs.

13. November-December 1998: NRC inspection (Ragland) verified that irradiated hardware had been removed from the East pool and shipped off-site during May-August 1998, with the East pool ready for desludging and draining. PCBs detected in water storage pool sludge. (50-03/98-17).

14. December 1998-February 1999: NRC SAFSTOR inspection (Dimitriadis) (50-03/98-19). Work in progress in draining and desludging various pools. While desludging the water storage

pool, PCBs were detected. Due to known leakage of this pool, the NCD was diverted into the Unit 1 sphere annulus for waste processing.

15. April-June 1999: NRC inspection (50-03/99-03) NRR reviewed a Unit 1 safety evaluation for modifications to the SFPs.

16. June-July 1999: NRC inspection (Ragland) reviewed monitoring of pool leakage, north curtain drain water was being treated by mechanical and charcoal filtration. Water storage pool cleanup in progress (50-03/99-06).

17. April 7, 2003: Unit 1 Remediation plan was approved to accomplish several objectives that included pursuing sealing the Unit 1 East SFP, transferring the spent fuel into that pool, and draining the leaking Unit 1 West SFP, thereby stopping the leak.

18. 2004: Insitu dry storage option was proposed by Unit 1 project team to stop the leak. Too many uncertainties surfaced regarding potential airborne radioactivity and future floodup effects on fuel integrity upon final spent fuel removal.

19. September 19-November 17, 2005: The Unit 1 West SFP was flooded up for spent fuel inspection for material condition evaluation. After drain down, Unit 1 SFP leak rate recalculated to be 70 gpd.

20. January 16, 2006: Unit 1 drain system collects seven times more tritium than can be attributed to the current 1 SFP leak rate.

21. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being released in the groundwater to the Hudson River. Initial bounding calculations were revised, indicating less than 0.1% of effluent release limits.

22. April 17, 2006: Due to the 3/21/06 discovery of strontium-90 in Monitoring Well-111, the licensee initiated demineralization of the Unit 1 SFP 40 hrs per week in order to reduce leaking source term. Final assessment of Unit 1 SFP leakage calculations indicated 70 gpd post-drain down since November 2005.

23. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90 and nickel-63: 2.5E-3 mrem total body and 1.1E-2 mrem maximum organ (adult bone). Strontium-90 analysis was added to REMP fish, Hudson River and sediment samples.

24. August 9, 2006: After completing a temporary system modification, Entergy began continuous cleanup of the Unit 1 West SFP.

25. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and hydrology results of a 3-day pump down test of Recovery Well-1.

26. April 2007: Revised calculation of tritium mass balance for Unit 1 SFP based on total radioactivity per year (based on 65 gpd leak rate) versus total radioactivity collected in the Unit 1 building drains for 2006. The Unit 1 SFP releases accounted for only 30% of the tritium collected in the Unit 1 drain system.

27. June 6-22, 2007: An expanded control zone fish split sampling exercise was conducted to include a second control location in the Catskills to help evaluate background levels of strontium-90 in fish.

Unit 2 Spent Fuel Pool Timeline

Operating license issued September 28, 1973

1. October 1, 1990: Unit 2 SFP stainless steel liner was perforated by a diver during re-rack cutting operation, but was not identified at that time.

2. May 7, 1992: Unit 2 SFP liner was discovered to be leaking (about 50 gpd), due to outside visible boric acid deposits on the wall of the fuel service building. Condition report determined cause and examined all other liner work areas for similar perforations. Entergy excavated 35 cubic yards of soil to a depth of 8 feet leaving no detectable contamination.

3. June 9, 1992: Under water epoxy temporary patch was installed, sealing the leak.

4. June 12, 1992: A steel box was welded over the liner perforation permanently sealing the leak completing corrective actions for this fuel pool leak event.

5. September 1, 2005: Initial discovery of the Unit 2 spent fuel pool leak. Contamination was first detected on a swipe sample of the exposed crack in the SFP south wall excavation area at approximately 65-foot elevation. The NRC resident inspector was informed.

6. September 12-15, 2005: NRC initial radiological scoping inspection and dose assessment, 0.00002 mrem/year based on 2 L/day leak rate.

7. September 20, 2005: NRC Special Inspection Charter was issued, followed by a press release announcing this action.

8. October 5, 2005: Tritium was discovered in the Unit 2 transformer yard Monitoring Well-111. This was the first location removed from the Unit 2 SFP indicating a groundwater contamination concern.

9. October 27, 2005: Unit 2 SFP liner inspection begins with underwater camera inspection to identify any leaks. Visual indications were followed by vacuum box testing.

10. October 31, 2005: NRC Executive Director for Operations issued Reactor Oversight Process deviation memorandum to provide additional NRC resources and continuing NRC inspection of the groundwater contamination investigation through 2006.

11. November 3, 2005: Licensee submitted a non-required 30-day report to the NRC, based on tritium results for Monitoring Well-111 (0.0002 uCi/ml) that were above the radiological environmental monitoring program (REMP) reporting criteria for non-drinking water samples (0.00003 uCi/ml). However, Monitoring Well-111 is an on-site well not representative of an offsite environmental sample therefore, no NRC report was required.

12. November 7, 2005: Drilling of the first new monitoring well was initiated (Monitoring Well-30).

13. January 13, 2006: A permanent leak collection box was installed encompassing the Unit 2 SFP crack.

14. January 31, 2006: A NRC Special Inspection team met on-site to review the Phase 1 monitoring well hydrology results.

15. February 8-10, 2006: A NRC Special Inspection team was on-site to evaluate the licensee’s compliance with IE Bulletin 80-10 (radiological monitoring of on-site non-contaminated systems),

10 CFR 50.75(g) (on-site spill documentation for future decommissioning), and chemistry counting quality control requirements. Hudson River waterfront well sample splits were taken for NRC, NYS and IPEC.

16. February 27, 2006: Monitoring Well-37 initial sample result = 30,000 pCi/L, provided the first indication of a tritium groundwater release directly to the Hudson River.

17. February 28, 2006: Licensee provided a revised dose calculation of 0.000015 mrem/yr to the maximally exposed member of the public based on a general site area hydrology water transport and multiple contamination area drainage model. The NRC conducted the SIT exit meeting.

18. March 16, 2006: NRC Special Inspection Report No. 05000247/2005001 was issued describing NRC


=s initial response and evaluation of the Indian Point groundwater contamination issue.

19. March 21, 2006: NRC sample results of Monitoring Well-37 strontium-90 analyses were received indicating 26 pCi/L. This was the first indication that strontium-90 was likely being released directly to the Hudson River. Initial bounding calculations were revised, indicating less than 0.1% of effluent release limits.

20. April 1, 2006: Due to the 2/21/06 discovery of strontium-90 in Monitoring Well-111, the licensee initiated continuous demineralization of the Unit 1 SFP in order to reduce the leaking source term.

21. April 10, 2006: Entergy groundwater monitoring and commitment letter sent to NRC Region I.

22. April 24, 2006: Updated dose assessment based on 2/28/2006 methodology using more recent monitoring well data and maximum concentrations of hydrogen-3 (tritium), strontium-90 and nickel-63: 0.0025 mrem total body and 0.011 mrem maximum organ (adult bone).

23. June 12-16, 2006: NRC groundwater contamination hydrology inspection team was on-site. U.S. Geological Survey participation was added to the NRC inspection effort.

24. November 7, 2006: NRC split sample results identify licensee strontium-90 results from 8/1 - 9/18/2006 were low and caused licensee resampling and licensee investigation.

25. October 30- November 1, 2006: Entergy conducted a 3-day groundwater draw-down pump test from Recovery Well - 1 (adjacent to Unit 2 SFP).

26. November 13-17, 2006: NRC on-site team inspection to review Unit 1 SFP leak history and hydrology results of a 3-day pump down test of RW-1.











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