Tritium: Fleet-Wide Assessment Program

Zigmund A. Karpa

Director Environmental and Regulatory Affairs

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Assessment Project

Obtained Executive SponsorshipDeveloped Issue Statement Identified Goals and Objectives Established Project Team and Assigned

ResponsibilitiesDeveloped a Detailed Scope of Work

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Primary Objectives of the Assessment

Identify and evaluate systems structures and components that contain or could potentially contain radioactively contaminated liquids;

Determine if the identified systems, structures and components have a potential pathway to the soils, groundwater or surface water;

Identify and evaluate the effectiveness of existing physical (i.e., secondary containment) and administrative controls (i.e. procedures) associated with each system, structure and component;

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Objectives (continued)

Enhance our understanding of geologic and hydrogeologic characteristics; and

Ensure proficient communication of non-permitted radiological releases with the surrounding communities and other stakeholders.

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Organization

Nuclear Executive Sponsor

Nuclear Corporate Project Team

• Chemistry

• Communications

• Engineering

• Environmental

• Licensing

• Project Management

• Public Affairs

• Radiation Protection

Stations Project Team

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Project Management Responsibilities

Manager and track schedules; Lead periodic management status updates; Manage and coordinate all budget estimates and

projections; Assemble periodic management reports ; Develop flee-wide performance indicators and project

tracking mechanisms; Identify and track actions; Coordinate Quality Assurance/Quality Control; and Contract or provide oversight.

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Environmental Affairs Responsibilities

Develop and Refine Templates;Manage base maps and final maps;Evaluate spills, accidental discharges and historic

releases;Document geologic and hydrogeologic conditions;Assess existing groundwater monitoring systems;Develop groundwater monitoring program; andAdminister environmental contracts.

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Station Responsibilities

Designate point-of-contact and project team; Identify and map potential sources;Document material conditions;Document known and alleged spills, accidental

discharges and historical release;Assemble environmental data; Document results of evaluation process;

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Station Responsibilities (continued)

Assist in risk evaluation process;Develop and implement corrective actions;Revise procedures to include management

program and system improvements; andMaintain files demonstrating the quality of the

evaluation process.

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Scope of Work

Phase I Project PlanningPhase II Data GatheringPhase III Work Plan DevelopmentPhase IV Risk EvaluationPhase V Implementation of Risk

Reduction

Strategies

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Phase I Project Planning

Develop detailed scheduleAssign project teams at corporate and each

stationCommunicate technical expectations and

deliverables to the stationsDevelop templates and technical data

management tools and protocolsDevelop project records retention programSchedule and conduct kick-off meetings

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Phase II – Data Gathering

Identify and map potential sources Document material condition Document and map historical releases, spills and

accidental discharges; and Develop environmental baseline.

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Primary Objectives of Data Gathering

To identify and map any system, structure or component that contained or potentially could contain radiological liquids and that had a viable pathway for a release to enter the environment;

To identify material condition of those systems, structures and components identified above;

To identify and map any historical release, spill or accidental discharge that had the potential to enter the environment; and

To document available regional and site specific geologic and hydrogeologic information.

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Potential Sources Identified

Aboveground storage tanks

Containers Discharge canals Discharge lines Fuel pools Other vessels Plant penetrations Pumps Relief valves

Sumps Supply lines Surface impoundments

(Pits, ponds, lagoons and lakes)

Trenches Underground storage

tanks Vacuum breakers Valves and valve pits

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Example: Logic Tree 

Does the sump, drywellor trench contain or have the

potential to contain radioactivelycontaminated liquids?

Yes

No additionalevaluationrequired

Complete Sump,Drywell and Trench

Source IdentificationWorksheet

No

Is the sump, drywell ortrench against a wall or

on a slab that is in contactwith the soil or gravel?

Yes

NO

No

Is the sump, drywell ortrench locatedin a building?

Yes

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Example: Template

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Example: Template (continued)

Facility Name:

System Number:

B. SUMP- Construction Information Write the Tank Number(s) and place an in the appropriate box for each tank component.

Sump # Sump # Sump # Sump # Sump # Sump Construction & Corrosion Protection

A. Concrete Sump

B. Welded Stainless steel lined concrete sump

C. Welded steel lined concrete sump

D Fiberglass sump

E. Molded Plastic lined concrete sump

F. Unknown

G. Other: Sump # Sump # Sump # Sump # Sump # Sump Base Material (what is under

Sump)

A. Concrete Slab or Pan

B. Ground (soil, rock, sand, etc.)

C. Impermeable Liner (describe)

D. Unknown

C. SUMP – Containment Sump # Sump # Sump # Sump # Sump #

Secondary Containment

A. No

B. Yes (If yes please describe below)

D. SUMP – Other Information

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Example: Template (continued)

Facility Name:

System Number:

E. TRENCH - Construction Information Trench # Trench # Trench # Trench # Trench # Trench Construction & Corrosion Protection

A. Concrete

B. Lined Concrete

C. Other:

Trench # Trench # Trench # Trench # Trench # Trench Base Material (what is under Trench)

A. Concrete Slab or Pan

B. Ground (soil, rock, sand, etc.)

C. Impermeable Liner (describe)

D. Unknown

F. TRENCH – Other Information

Name of the Individual Completing Form:

Telephone Number:

Date Completed:

Note: The location of each sump, drywell and trench must be depicted on a map.

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Document Material Condition

Description – Age, dimensions, location, design capacity, etc.

Fluid concentrations – Estimate of the maximum concentrations of radioactive material in each system or component (i.e. historic or existing);

Controls and Inspections – Equipment and system components inspection frequencies and types etc.

Maintenance Records – Records of any repairs or replacements related to equipment that is known or suspected of having leaked radioactively contaminated water.

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Quality Control

A cross functional team with representatives from Chemistry, Engineering, and Radiation Protection was assembled.

The team was responsible for:• Comparing templates from the stations to identify

potential gaps;• Holding meetings with the stations to challenge the

data included in each source identification worksheet• Documenting the rational for including or removing

systems, structures or components form the source identification worksheets

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Document Historical Releases, Spills and Accidental Discharges

Identify and list historical releases as recorded in accordance with 10 CFR 50.75.g.

Review available records and interview knowledgeable personnel to identify accidental discharges, spill areas, and disposal areas.

Document all alleged events and disposal areas that have potentially impacted the environment and record the information in a corporate-supplied template.

Map all identified historical releases, spills and accidental discharges

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Release Data Collected

Date of event; Source of release; Location of release; Area Impacted; Media impacted (i.e., soil,

groundwater or surface water);

Material released including concentrations, if known;

Amount of material released;

Remediation efforts implemented; and

Post remediation analysis, if any.

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Develop Environmental Baseline

Regional and site specific-geology;

Regional and site specific-hydrogeology;

On-site groundwater monitoring wells;

On-site groundwater dewatering systems and recovery wells;

Existing and historic monitoring programs;

Soil logs, locations and data;

Groundwater elevations, contour maps and analytical data;

Sediment sample locations and data; and

REMP and RETS data and reports.

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Quality Control

A team of environmental professionals from Exelon, the Stations and a Consultant was assembled to evaluate the releases.

The team was responsible for:• Evaluating each release to determine if groundwater

was potentially impacted or could be impacted in the future;

• If a potential impact existed, identify the spill area was for further evaluation; and

• Documenting the rational for including or excluding the area for further evaluation.

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Hydrogeologic Work Plans

Site Specific investigation work plans were developed to:

Characterize the hydrogeologic conditions at the property including subsurface soil types, the presence or absence of confining layers, and the direction and rate of groundwater flow;

Characterize the groundwater/surface water interaction at the Station, including a determination of the surface water flow regime;

Evaluate groundwater quality at the Station including the vertical and horizontal extent of any tritium in the groundwater;

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Hydrogeologic Work Plans (continued)

Define the probable sources and estimate quantity of any tritium released at the station;

Evaluate potential human, ecological or environmental receptors of tritium released to groundwater, if any;

Evaluate whether interim response activities were warranted to address the groundwater; and

Provide a technical basis to evaluate possible remedial alternatives for tritium impacts identified at the station.

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Hydrogeologic Reports

Hydrogeologic Work Plans were implemented; Hydrogeologic Reports were generated and provided to

the NRC and State agencies as appropriate; Meetings were held with the NRC and various state

agencies to review the results of the Reports; The Reports were posted on Exelon’s external web page; A long term monitoring program was developed and

institutionalized through procedures; and The results of subsequent sampling episodes are included

as part of each Station’s REMP.

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QUESTIONS?