Tritium: Fleet-Wide Assessment Program

1. Tritium: Fleet-Wide Assessment Program Zigmund A. Karpa Director Environmental and Regulatory Affairs

2. Assessment Project • Obtained Executive Sponsorship • Developed Issue Statement • Identified Goals and Objectives • Established Project Team and Assigned Responsibilities • Developed a Detailed Scope of Work

3. 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;

4. 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.

5. Organization • Nuclear Executive Sponsor • Nuclear Corporate Project Team • Chemistry • Communications • Engineering • Environmental • Licensing • Project Management • Public Affairs • Radiation Protection • Stations Project Team

6. 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.

7. 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; and • Administer environmental contracts.

8. 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;

9. Station Responsibilities (continued) • Assist in risk evaluation process; • Develop and implement corrective actions; • Revise procedures to include management program and system improvements; and • Maintain files demonstrating the quality of the evaluation process.

10. Scope of Work • Phase I Project Planning • Phase II Data Gathering • Phase III Work Plan Development • Phase IV Risk Evaluation • Phase V Implementation of Risk Reduction Strategies

11. Phase I Project Planning • Develop detailed schedule • Assign project teams at corporate and each station • Communicate technical expectations and deliverables to the stations • Develop templates and technical data management tools and protocols • Develop project records retention program • Schedule and conduct kick-off meetings

12. 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.

13. 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.

14. 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 Potential Sources Identified

15. Example: Logic Tree

16. Example: Template

17. Example: Template (continued)

18. Example: Template (continued)

19. 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.

20. 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

21. 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

22. 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. Release Data Collected

23. 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.

24. 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.

25. 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;

26. 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.

27. 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.

28. QUESTIONS?