Text

Submittal of 10 CFR 20.2002 Request for Alternate Waste Disposal at Us Ecology
	ML16029A071
Person / Time
Site:	Vermont Yankee
Issue date:	01/14/2016
From:	Wamser C; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BVY 16-001
	Download: ML16029A071 (75)
	v • d • e

Entergy Nuclear Operations, Inc.

Vermont Yankee SEn tergy 320 Governor Hunt Rd.

Vernon, VT 05354 802-257-7711 Christopher J. Wamser Site Vice President BVY 16-001 10 CFR 20.2002 January 14, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

10 CFR 20.2002 Request for Alternate Waste Disposal at US Ecology Idaho Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO) requests NRC approval of alternate waste disposal at the US Ecology, Inc (USEI) Resource Conservation and Recovery Act (RCRA), Subtitle C hazardous waste disposal facility located near Grand View, Idaho. The waste will consist of approximately 200,000 gallons of low-activity radioactive waste containing byproduct material from activities associated with preparing for long term dormancy as part of the decommissioning process at Vermont Yankee Nuclear Power Station (VY). This request is made under the alternate disposal provision contained in 10 CFR 20.2002.

ENO is collaborating with USEI on this request. Since the USEI facility is not an NRC-licensed disposal facility, USEI will submit under separate letter a request for an exemption pursuant to 10 CFR 30.11 to allow for the disposal of the byproduct material at the USEI facility.

Enclosure 1 to this letter provides a conservative radiological assessment of the planned disposal and a description of the waste material. The description includes the physical and chemical properties important to risk evaluation, along with the proposed manner and conditions of waste disposal.

ENO's request is similar to a request by Pacific Gas and Electric Company (PG&E) for Humboldt Bay Power Plant Unit 3 in a letter dated May 2, 2012 (ADAMS Accession No. ML12135A295), as supplemented by email dated July 16, 2012 (ADAMS Accession No. ML12241A273). The NRC approved that request in a letter dated December 19, 2012 (ADAMS Accession No. MLI12244A084). The difference is that this request involves only contaminated liquids.

ENO requests review and approval of this request by April 15, 2016.

This letter contains no new regulatory commitments.

Kk~

1/Lb1~~'

BVY 16-001 / Page 2 of 2 If you have any questions on this transmittal, please contact Mr. Coley Chappell at 802-451-3374.

Sincerely, CJW/plc

Enclosures:

1. Evaluation in Support of 10 CFR 20.2002 Request for Alternate Waste Disposal

2. Copy of Letter from L. Camper to J. Weismann approving use of USEI SSDA for 10OCFR 20.2002 Alternate Disposal Authorization Requests, August 24, 2015 (ML15125A364)

3. USEI Part B Permit EPA ID. No.: IDD0731 14654, Revision Date: March 12, 2015, Part C.3 WASTE ACCEPTANCE CRITERIA

4. USEI SSDA Data Input Screen with VY Project-Specific Information

5. VYWaste Sample 10 CFR 61 Analysis Results cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Senior Project Manager Mail Stop T-8F5 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-260 1 Mr. Trey Martin, Deputy Secretary Vermont Agency of Natural Resources I National Life Drive - Davis 2 Montpelier, VT 05620-3901

BVY 16-001 / Enclosure 1 /Page 1 of 8 VERMONT YANKEE NUCLEAR POWER STATION EVALUATION IN SUPPORT OF 10 CFR 20.2002 REQUEST FOR ALTERNATE WASTE DISPOSAL DOCKET NO. 50-271 1, INTRODUCTION Entergy Nuclear Operations, Inc. (ENO) requests NRC authorization for alternate disposal of certain low-activity waste containing byproduct material from Vermont Yankee Nuclear Power Station (VY) at the US Ecology, Inc (USEI) Resource Conservation and Recovery Act (RORA),

Subtitle C hazardous waste disposal facility located near Grand View, Idaho. ENO is collaborating with USEI on this request. USEI will submit a request for exemption to 10 CFR 30.11 to allow for disposal of byproduct material at the USEI facility under a separate letter. The authority of 10 CFR 20.2002 and the exemptions requested from 10 CER 30.11 licensing requirements for byproduct material would allow ENO to transfer these wastes to the USEI facility for disposal.

The dose evaluation for this request for alternate disposal was performed using US Ecology's NRC-Approved Site Specific Dose Assessment Methodology (SSDA) for USEI. The SSDA provides a consolidated dose assessment framework for all occupational, transportation, and post-closure dose receptors required in 10 CFR 20.2002(d) - "Analyses and procedures to ensure that doses are maintainedALARPA and within the dose limits in this part." The information provided in this document as well as the Safety Evaluation Report and Environmental Assessment produced by the NRC serve to satisfy the requirements in

§20.2002(a), (b), and (c). The NRC approved the SSDA for use on August 24, 2015 (ADAMS Accession No. ML15125A364, provided as Enclosure 2).

Characteristics and operating parameters of the USE! disposal site are summarized in Section 2 of this Enclosure. Environmental conditions at the USEI site are well-documented in previous submittals to the NRC, including the Hematite Decommissioning Project (Docket #07000036) and the Humboldt Bay Nuclear Power Plant Decommissioning Project (Docket #50-133).

A description of the material to be disposed is included in Section 3. The material description includes physical and chemical properties of the material important to risk evaluation and the proposed conditions of waste disposal. Results of the SSDA dose evaluation are summarized in Section 4 for all occupational and transportation workers as well as postulated members of the public based on USEI's ResRad model (Ver. 6.5) and Inadvertent Intruder Scenarios described in NUREG-0782, "Draft Environmental Impact Statement on 10 CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste," and NUREG/CR-4370, "Update of Part 61 Impacts Analysis Methodology - Methodology Report." Enclosure 3 contains the Waste Acceptance Criteria (WAC) set forth in USEI's permit issued by the Idaho Department of Environmental Quality. The SSDA Data Input Screen with all of the project inputs for the VY Wastewater project is provided in Enclosure 4. The conclusion confirms doses to workers and members of the public will be well below NRC limits.

USE! has previously received approval to receive wastewater containing fission and activation products from the Humboldt Bay Nuclear Power Plan Unit 3 decommissioning project. A 10 CFR 30.11 exemption from licensing requirements was granted to USE! by the NRC on December 19, 2012 (ADAMS Accession No. ML12299A056).

2. DISPOSAL SITE CHARACTERISTICS The USEI site is located in the Owyhee Desert of southwestern Idaho. It is at the end of Lemley Road, approximately 17 kilometers (10.5 miles) northwest of Grand View, (Owyhee County)

Idaho. Grand View has a population of approximately 340. Owyhee County is a ranching and

BVY 16-001 I Enclosure 11/Page 2 of 8 agricultural area of approximately 19,900 square kilometers (7,678 square miles). The county is sparsely populated, with an average population of 0.5 people per square kilometer (1.4 people per square mile per Reference 1).

This region has an arid climate with an average annual precipitation rate of 7.4 inches. The USEI site is located on a 1.6 kilometer (1 mile) wide plateau. Maximum surface relief on the facility is 27 meters (90 feet) and the mean surface elevation is 790 meters (2,600 feet) above sea level. The nearest residence is 1.6 kilometers (1 mile) southwest of the site. There are no other land uses in the immediate vicinity of the site.

The operational performance characteristics of the USEI site have been reviewed by the NRC and determined to be protective within the NRC's "less than a few millirem (mrem) per yea?'

policy for Alternate Disposal Requests first stated in NRC Regulatory Issue Summary (RIS) 2004-08, "Results of the License Termination Rule Analysis," and reaffirmed in SECY-07-0060, "Basis for Justification and Approval Process for 10 CFR 20.2002 Authorizations and Options for Change." The NRC has granted USEI several 10 CFR 30.11 byproduct material exemptions for purposes of disposal of various licensee waste streams. Two key documents are referenced from previous NRC submittals:

Hazardous Waste Facility Siting License Application for Cell 16 (American Geotechnics, dated June 30, 2006); This document describes USEI's environmental setting and was accepted by the Idaho Department of Environmental Quality (IDEQ) as part of the 2005 siting process, which resulted in IDEQ approval (December 6, 2006) of USEI's request to expand its landfill operations. (ADAMS Accession No. ML100320540 - Attachment 7)

Summary of Hydrogeologic Conditions and Groundwater Flow Model for US Ecology Idaho Facility, Grand View, Idaho (Eagle Resources, dated January 13, 2010. This document provides a detailed description of USEI's site geology and hydrogeology.

(ADAMS Accession No. ML101170554 - Exhibit B)

3. DESCRIPTION OF THE WASTE The subject waste consists of approximately 200,000 gallons (~26,700 ft3) of water associated with decommissioning of VY and preparing the facility for long-term dormancy. Since the cessation of plant operations, plant process water has been drained from systems creating a surplus of water needed for make-up to the spent fuel pool. The water to be disposed of is currently stored in the former VY suppression chamber (Torus). The Torus has a capacity of 1.1 million gallons and currently is filled to approximately 96% of capacity. The water in the Torus is continuously circulated and filtered/demineralized to minimize suspended solids. For disposal, the water will be pumped from the Torus through the former High Pressure Coolant Injection suction strainers, which are located inside the Torus at an elevation that minimizes entrainment of sediment.

The wastewater being considered under this request will include fission and activation products resulting from VY operations. The waste concentrations are expected to be low. Water is assumed to have a density of 1.0 g/cc. Radiological characterization of the waste stream was performed through routine sampling and analysis of project waste materials as part of VY's 10 CFR 61 characterization program. The sample was drawn from the same location that will be used to pump the water for disposal.

A summary of the radionuclides and their concentrations are listed in Table 1 below. Full results of the Part 61 analytical results of the waste sample are provided in Enclosure 5.

BVY 16-001 / Enclosure 1 /Page 3 of 8 Table 1. Radionuclides Potentially Present in VY Waste Water Concentration Nuclide (pCi/ml)

Co-60 0.78 Cs-i137 0.33 H-3 1,870 Mn-54 0.04 Zn-65 0.24 The wastewater will be solidified with clay at USEI and disposed as a soil-like waste"upon receipt, The liquid solidification process at USEI is routinely used for applicable shipments. All wastes are conservatively assumed to be transported in a single year. To account for the solidification process at USEI, a total waste volume of 80,000 ft3 was entered into the SSDA workbook to account for the 'bulking' that will occur from the clay used to solidify the water. For conservatism, the wastewater concentrations were kept at the original characterized concentrations provided by VY and not diluted by the clay.

All shipments will have radioactivity concentrations well within the levels allowed in the site WAC set forth in USEI's permit issued by the Idaho Department of Environmental Quality (provided in Enclosure 3). The actual concentrations in the water shipments at the time of disposal will be reduced through the solidification process. These concentrations are also below levels requiring the waste to be classified as "radioactive material" for shipment purposes under U.S. Department of Transportation (DOT) regulations.

4. RADIOLOGICAL ASSESSMENT As described~in the following exposure scenarios, the dose equivalent for the Maximally Exposed Individual (MEl) has been demonstrated to not exceed "a few mrem per year." The standard of a "few mrem per year'to a member of the public is set forth in NRC RIS 2004-08, "Results of the License Termination Rule Analysis."* The transportation workers and USEI workers are treated as members of the public because the USEI site, while permitted by the State of Idaho under RCRA to accept certain radioactive materials, is not licensed by the NRC.

External exposure assessments in the SSDA were performed using MicroShield Code, Version 7.02. Evaluations of potential external and internal dose hazards are discussed in the sections that follow while all inputs to the SSDA workbook are provided in Enclosure 4. A summary of total estimated doses for all transporters, as well as USEI workers performing surveying, handling, treatment and disposal tasks on the VY waste is provided in Table 2.

4.1. Transport Dose to the Public All materials will be transported by truck to the USEI facility in Grand View, ID.Wastewater will be transported in tanker trailers with an approximate capacity of 5,000 gallons. All conveyances will be verified to comply with DOT external loose surface contamination limits prior to shipment.

Therefore, transport will not pose the potential for internal dose to the drivers or other members of the public.

The distance from VY to the USEI disposal facility is approximately 2,520 miles. Assuming an average speed of 55 miles per hour, the trip is estimated to take 46.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . A minimum of eight trucks will be used to transport the entire volume of anticipated wastewater over the course of the project to achieve maximum logistical efficiency. Using a minimum of eight trucks, it will take 40 tanker shipments of water to complete the project. Each tanker truck driver is expected to make a minimum of 5 round trips between VY and Grand View, ID over the course of the project. For dose modelling purposes, the tanker driver sits approximately 3.3 meters from the surface of the vessel with approximately 0.51 inches of steel shielding between him and the

BVY 16-001 / Enclosure 1 I Page 4 of 8 contaminated water. The tanker shielding includes the tank construction itself as well as outer steel liners.

Because of the very low average concentrations of radionuclides, external doses to the truck drivers are also very low. As a result, the dose to other members of the general public can reasonably be concluded to be much less. External dose to a tanker truck driver is estimated to be 0.21 mrem/yr.

BVY 16-001 / Enclosure 1 I Page 5 of 8 Table 2 - Results of SSDA Dose Evaluation for VY Wastewater Project UJSEN SieSeii Dose Assessment Workbook Rev. 2 Date: 12/9/2015 Summry.lofProject Ater-nate Disposal Dase Iresults Customer:

Project: Vuinog*Yudcee Tongs Wet.'

LZ+/-H Number of Project Years:

Max Dose Anowed (mrem/yr):

a) USEI Worker Total Project Dose_____ ________________

Miunnu External Total External Total Internal Total Project Number of Waste Contact Expsue Rate Internal Dose Distance Total No. of Dose per Dose per Dose per 1%of Mare FucinWorkers Tmnne (l) (mRt/br) Rate jmren,/hr) (im) Repetitions worker inrem)iWorker(intr) worker Inve) Ann,,, Doe Front-End Dray Truck Drivers 4 0.00 8.94E-04 0.008+00 00 0 0.OOE+00 O.00E40 0.008400 0.0O%

Long-aul DOs ect Truck Drivers: 8 46.36 8.94E.04 O.00E+00 0.6 40 2.07E.01 O.OOE+0O0 2.071E.01 4.14%

Gondola Radiler Suive~yors 4 0.33 8.34E.04 0.008400 1.0 0 O.008+00 O,008400 0.008+00) 0.00%

Truck Surveyors 8 0.08 6.98E.04 0.00E+00 1.0 40 2.798-04 0.008400 2.798-04 0.01%

Intenoe Container Suvyr 8 0.08 6.98E.04 0.008400 1.0 0 0.00E+00 0O00840 0.008+00 0.00%

RTF Excvator Operator 2 0.75 4.838-04 8.42E-08 2.0 0 0.008+00) .0008400 0.008+00) 0.00%

Gondola Rala Cleaout 4 0.16 2.348-04 8.42E-08 0.3 0 0.008400 0.00840 0()

.008+00 0.00%

Rail Transfer Equipnent Oiperator 4 0.25 &.008-05 0.008-+00 4.9 0 0.008-+00 0.008400) 0.008400 0.00%

Back-End Dray Truck 1Drivers 10 0.75 O.008400 0.00840O0 0.6 0 0.008+00 0.008400 0.008+00 0.00%

Treatment Workers 6 0.75 2.818-04 8.42E-08 2.0 50 1.76E.03 5,,26E.,07 1.761E-03 0.04%

Landfill Cell Operators 4 0.25 3.00E.04 &.428-08 1.0 50 9.368-04 2.638E-07 9.37E.04 0.02%

b) 1)58 Worker Total Dose per Project Year (if applicable)_________________

Minmu External Annual Exera Annual Internal Total Annuaml Number of Waste Contact Exposure Rate Interna Dose Distncrwe Total No. of Dose per Dose per Dose per % of Max FucinWorkers T-me (hv) InsR/br) Rate (mrein/hr) Ira) Repetitions Worker (inter) Worerl (inter) Worke linre) Annual Dose Front-End Dray Truck Drivers 4 0.00 8.948-04 0.00E400 0.0 0 0.008E+00 0J)(.0080 0.008+00 0.00%

Lon-Hu Direct Truck Drivers 8 46.36 8&948.04 0.008400 0.6 40 2.07E.01 0.00E400 2.071[-01 4.14%

Gondlola Rala Surveyors 4 0.33 8.348-04 0.008400 1.0 0 0.008+00 0.0084E00 0.008+00 0.00%5 Truck Surveyors 8 0.08 6.988-04 0.008400 1.0 40 2.798.04 0.008-400 2.798-04 0.01%

Intermodal Container Swv*eyors 8 0.08 6.988-04 0.00E400 1.0 0 0.008400 0.00E+00 0.008+00 0.00%

RTF Excavator Operetor 2l 0.75 4.838-04 8.428-08 2.0 0 0.0018+00 0.008400 0.00+00 0.00%

Godl akr Cleanou 4 0.16 ?_348-04 8.42E-08 0.3 0 0.008E+00 0.0008400 0.008400 0.00%

Rail Transfer Eqimn Operator .2 8 .008-05 4900080 O.040

.008400 0.008400 0.00%

Sack-End Dray Tnuck Driver 10 0.75 0.OOEe00 0.008400 0.6 0 0.008+00 0.008400 0.008+00 0.00%

Treatment Workers 6 0.75 2.818-04 8.428-08 2.0 50 1,76E-03 5.26E-07 1.768-03 0,.04%

Landfil Cell Operators 4 0.25 3.00E.04 8.42E.08 1.0 50 9.368.04 2.63E-O7 9.37E-04 0.02%

) USEI RESRAD Postasure Screening Dose 2.028-02 mrem/yr

1. Total No. of Reeiin (Tanker Trips) : 200,000 gal / 5,000 gal per tanker = 40 d) navetent Intuder DOses 2. Dose to Treatment Plan and Landfill Workers represents labor associted with post-solidfcto soils to landf ill.

(d) 1. Construction Scen-ario 2.18E-02 mrensyr 3. Transportato plan calls tor 8 tanker trucks assge to pret wit each truck making: 5trips.

(d) 2. Wall Drier Scenario 1.198-02 m~trns/Yr 4. The Treatment pathway is turted assdue to the need to solidify the water prior to disosl.

(d) 3. Driller Occupancy Scenaro 1.42E-03 mrem/yr

BVY 16-001 / Enclosure 1 /Page 6 of 8 4.2. USEI Worker Dose Assessment Upon receipt at the facility, the material will be surveyed and screened prior to transporting the waste to the indoor stabilization facility on the USEI site. Five minutes is required to perform a survey of each tanker truck. Based on current practice, a surveyor is assumed to stand at a distance of one meter from the truck or trailer during the survey, with four surveyors sharing the task. External dose (i.e., total dose) to each surveyor is estimated to be 2.8E-04 mrem. There will be no additional dose to the VY truck drivers from other trucks in the vicinity during the surveying, because the external dose rate from o~ther trucks is negligible.

For the purposes of this assessment, it is conservatively assumed that all waste water from VY will require treatment (via solidification) for incoming water shipments. All water shipments will require solidification with clay soils within the USEI indoor stabilization building before burial in the landfill. After surveying, the waste is delivered to the stabilization building by the transport truck driver. The waste to be treated will be placed into a steel-lined concrete tank where it will be mixed with dry clay. The building is equipped with a negative pressure air handling system so that all air leaving the building is exhausted through High Efficiency Particulate Air (HEPA) filters. The stabilization process requires approximately 45 minutes, during which time the excavator operator, who is in an enclosed cab and wearing a respirator, is approximately 2.8 meters from the waste. Six operators share the stabilization task. External dose to each stabilization operator is estimated to be 1.76E-03 torero.

Personnel who work in the stabilization building may also be exposed to airborne activity from "dusting." Significantly, all USEI employees who work with any hazardous materials are required to participate in an Occupational Safety and Health Administration (OSHA) compliant respiratory protection program. Although this proven form of protection is required, conservatively no credit is taken in the internal dose assessment. Stabilization building workers are also the maximally exposed individuals for inhalation dose, primarily because of the assumed exposure time (45 minutes) and the indoor environment. Internal dose to each stabilization operator is estimated to be 5.3E-07 mrem.

After stabilization, the excavator operator removes the treated waste from the stabilization tank and places it into an on-site haul truck for transport to the disposal cell for burial. After delivery to the disposal cell, a bulldozer operator wearing a respirator within an enclosed cab, spreads and compacts the waste. A minimal external dose is calculated for the two bulldozer operators who share the task of spreading and compacting the stabilized waste material once it has been deposited within the disposal cell.

The average time to spread and compact 50 tons of material (which is the capacity of 2.5 Intermodal Containers) is 15 minutes. This shorter exposure time results in less potential internal dose from airborne radionuclides than was calculated for an excavator operator.

Personnel working in the disposal cells are also required to wear air purifying respirators at all times. Again, no credit is taken for this proven form of protection and. internal dose is estimated to be the bounding dose calculated for a stabilization operator. The estimated total dose to each disposal cell operator is 9.4E-04 mrem.

4.3. Post Closure Dose to the General Public USEI's RCRA permit requires that it demonstrate that no person will receive an annual dose exceeding 15 mrem for 1,000 years after closure of the facility. This standard is more restrictive than the annual 25 mrem total effective dose equivalent (TEDE) stated in 10 CFR 20.1402 for NRC license termination, as well as the limits for near surface disposal of low-level radioactive waste set forth in 10 CFR 61. RESRAD code Version 6.5 was used for modeling the Grand View site for potential long-term post-closure doses. A number of default parameters in the Grand View model have been replaced with site specific parameters consistent with the facility's

BVY 16-001 / Enclosure 1 /Page 7 of 8 2005 permit modification and a report prepared by its consultant (previously submitted to the NRC as part of an RAI response for the exemption request for the Westinghouse Hematite project, Docket #070-00036).

The SSDA contains a screening RESRAD model to assess the impact of the solidified VY waste on the USEI site. The model is consistent with USEI's post-closure dose model included in the Part B RCRA permit, which assumes that all of the VY waste is distributed evenly within the contaminated zone (area = 88,221 in2 , depth = 33.6 in). 'Screening' in the SSDA means that ALL nuclides are evaluated at their peak dose-to-source ratio regardless of when it occurs. The radionuclide concentrations in Table 1 are automatically adjusted in the SSDA Workbook to reflect aggregation into the entire landfill volume, resulting in a dilution factor of 6.5E-03. All other RESRAD code parameters remain the same. The results of the screening model show a maximum annual dose of 2.02E-02 mnrem. Due to the very low dose projection from the screening model, a separate project-specific dose model was not necessary.

Three post-closure inadvertent intruder scenarios were also conducted using the framework from NUREG-0782, "Draft Environmental Impact Statement on 10 CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste," and NUREG/CR-4370, Volume 1, "Update of Part 61 Impacts Analysis Methodology" built into the SSDA. These scenarios include:

Intruder Construction Scenario - An inadvertent intruder may excavate or construct a building on a disposal site following a breakdown in institutional controls. Under these circumstances, dust will be generated from the application of mechanical forces to the surface materials (soil, rock) through tools and implements (wheels, blades) that pulverize and abrade these materials. The dust particles generated may be then entrained by localized turbulent air currents and can thus become available for inhalation by the intruder. The intruder may also be exposed to direct gamma radiation resulting from airborne particulates and by working directly in the waste-soil mixture. The Construction Worker scenario uses the Air Uptake and Direct Gamma Exposure pathways to estimate a total dose to the intruder.

Intruder Well Drillinq Scenario - An intruder accesses the site and develops a well. The intruder is exposed to contaminated drill cuttings spread over the ground surface and contaminated airborne dust. The scenario presented in NUREG/CR- 4370 was modified to exclude consideration of exposure to cuttings in a mud pit due to the standard practices in the area around the waste site. The assumption that drill cuttings are spread over the ground will result in higher dose estimates than if the cuttings were assumed to be in a mud pit because of the decrease in the shielding factor. The driller is assumed to work on site for a period of 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months and it is assumed that the contaminated layer is drilled through in 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . As such, the driller is assumed to be exposed to the undiluted cuttings for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and to diluted material for the balance of the exposure duration. The dilution is calculated based on the ratio of the depth of the waste layer to the total well depth. No dilution in the USEI landfill is assumed. The Well Driller scenario includes contributions from Internal and External dose to the intruder.

Intruder Driller Occupancy Scenario - An inadvertent intruder occupies the site upon which a well had been drilled through waste materials. The Driller Occupancy Scenario uses the same concentrations in the exhumed well cuttings (Cw') as the Well Driller scenario. The Driller Occupancy scenario uses the Air Uptake and Direct Gamma Exposure pathways to estimate a total dose to the intruder.

BVY 16-001 I Enclosure 1 / Page 8 of 8 No credit was taken for dilution of the radionuclide concentrations in any of the intruder calculations. The estimated inadvertent intruder doses are therefore 2.2E-02 mrem for the Construction Scenario, 1.2E-02 mrem for the Well Driller Scenario, and 1.4E-03 mrem for the Driller Occupancy Scenario. All of these values meet the "less than a few mrem per year"for approval of an alternate disposal authorization at an operating site and is well within the 10 CFR 20.1301 dose limit of 100 mrem/yr for individual members of the public from licensed operation.

5. CONCLUSION VY developed this request and related evaluation in consultation with USEI, including health physics personnel responsible for the Grand View disposal facility's waste acceptance and radiological performance assessment programs. This assessment team performed a radiological dose assessment of the material to be shipped and determined that the potential dose to the workers involved in the transportation and placement of the material and to members of the general public after site closure is less than one mrem per year TEDE. This dose is a small fraction of the NRC decommissioning limits for exposure to any member of the public of 25 mrem/yr TEDE, and is well within the "few mrem per yea?' criterion that the NRC has established in RIS 2004-08.

6. REFERENCES

1. American Geotechnics, "Hazardous Waste Facility Siting License Application Cell 16," Project No. 06B-C1 202, June 30, 2006 (MLI100320540 - Attachment 7)

2. Eagle Resources, Inc. "Summary of Hydrogeologic Conditions and Groundwater Flow Model for US Ecology Idaho Facility, Grand View, Idaho." January 13, 2010 (MLI101170554 - Exhibit B)

3. US Ecology Idaho, Inc. USEI Site B Permit No. IDD073114654 (2004)

4. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2004-08, "Results of the License Termination Rule Analysis." Office of Material Safety and Safeguards, May 28, 2004

5. U.S. Nuclear Regulatory Commission, "Basis and Justification for Approval process for 10CFR20.2002 Authorizations and Options for Change." SECY 0060. Division of Waste Management and Environmental Protection, March 27, 2007

Enclosure 2 Copy of Letter from L. Camper to J. Weismann approving use of USEI SSDA for 10OCFR 20.2002 Alternate Disposal Authorization Requests, August 24, 2015 (ML15125A364)

(3 Pages)

August 24, 2015 Mr. Joseph J. Weismann, CHP Vice President of Radiological Programs and Field Services US Ecology, Inc.

Lakepointe Centre I 300 East Mallard Dr., Suite 300 Boise, ID 83706

SUBJECT:

US ECOLOGY, INC. - TECHNICAL EVALUATION REPORT OF US ECOLOGY IDAHO'S PROPOSED METHODOLOGY SUPPORTING ALTERNATE WASTE DISPOSAL PROCEDURES IN ACCORDANCE WITH 10 CFR 20.2002 By letter dated June 14, 2013, US Ecology, Inc. (USEI) requested an exemption to receive and dispose of low-activity radioactive waste from Studsvik's Processing Facility in Memphis, TN at USEI, a Resource Conservation and Recovery Act Subtitle-C hazardous and low-activity waste facility near Grand View, ID. USEI also requested that the U.S. Nuclear Regulatory Commission (NRC) review a newly developed Site-Specific Dose Assessment Methodology (SSDA). In a letter dated March 10, 2014, USEI withdrew the request to dispose of low-activity waste from Studsvik Processing Facility; however, USEI requested that the NRC continue to review the SSDA. USEI stated that this process provides a streamlined methodology for preparing and reviewing future 10 CER 20.2002 alternate disposal requests (ADR) from USEI.

This Technical Evaluation Report (TER) documents the NRC staff's technical review of the proposed methodology. Similar to a review of a 10 CFR 20.2002 exemption request, the NRC staff performed a technical review of the methodology and associated documents and evaluated the technical basis and assumptions incorporated into the calculations used by USEI. The NRC staff also used the methodology to evaluate a previously evaluated exemption request and compared the conclusions. Based on this review, the NRC staff considers the use of USEI's SSDA to be an appropriate method for evaluating future proposed disposals. The SSDA methodology can be used to satisfy the criteria in § 20.2002 (d); however, individual 20.2002 requests by US El, or other licensees wishing to ship to USEI, must address the criteria in

§ 20.2002 (a), (b), or (c) separately.

In response to your initial request, the SSDA, the technical basis document, and the NRC's detailed TER are considered proprietary and will not be available for public review. However, a second, publicly-available TER was also developed to demonstrate how this process will satisfy the NRC's mission of protecting public health, safety, and the environment. The NRC would note that specific parameter values, in the necessary form, that have not always been included with historical submittals may need to be included in future submittals in order for the SSDA methodology to be used.

J. Weismann-2 In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure, "a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http:llwww. nrc.pqovlreadincq-rrn/adams. html.

Copies of both TEns are enclosed. Please contact Mr. Maurice Heath if you have any questions concerning the above. He can be reached at (301) 415-3137 or via email at Maurice. Heath~?nrc..Qov.

Sincerely,

/RA/

Larry W. Camper, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

Enclosures:

Technical Evaluation Report (Proprietary Version)

Technical Evaluation Report (Public Version)

J. Weismann-2 In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure, "a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http:llwww. nrc.govlreadinaq-rmladams.html.

Copies of both TERs are enclosed. Please contact Mr. Maurice Heath ifyou have any questions concerning the above. He can be reached at (301) 415-3137 or via email at Maurice.Heathtnrc..qov.

Sincerely,

/RA/

Larry W. Camper, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

Enclosures:

Technical Evaluation Report (Proprietary Version)

Technical Evaluation Report (Public Version)

DISTRIBUTION:

LCamper/NMSS ML1 5'125A364 OFFICE NMSS NMSS NMSS NMSS OGC NMSS NAME M. Heath A. Walker-Smith C. MoKenney G. Suber L. London L. Camper S ~ (via email)

DATE 5/20/15 5/12/15 J5/29/15 5/22/15 7/21/15 8/24/15 OFFICIAL RECORD COPY

Enclosure 3 USEI Part B Permit EPA ID. No.: IDD073114654 Revision Date: March 12, 2015 Part C.3 WASTE ACCEPTANCE CRITERIA (6 Pages)

USEI Part B Permit EPA ID. No.: IDD0731 14654 Revision Date: March 12, 2015 C.3 WASTE ACCEPTANCE CRITERIA C.3.1 Pre-acceptance Review The pre-acceptance protocol has been designed to ensure that only hazardous and radioactive material that can be properly and safely stored, treated and/or disposed of by USEI are approved for receipt at the facility. A two-step approach is taken by USEI. The first step is the chemical and/or radiological and physical characterization of the candidate waste stream by the generator.

The second step is the pre-acceptance evaluation performed by USEI to determine the acceptability of the waste for receipt at the facility. Figure 0-2 presents a logic diagram of the pre-acceptance protocol that is utilized at the facility.

C.3.,2 Radioactive Material Waste Acceptance Criteria The following waste acceptance criteria are established for accepting radiological contaminated waste material that is not regulated under the Atomic Energy Act of 1954 ("AEA"), as amended.

This may be accomplished by the following regulatory mechanisms: use of ageneral or specific exemption from regulation by the Nuclear Regulatory Commission (NRC) or an Agreement State; a Release from Radiological Control declaration by the Department of Energy (DOE); or a determination that 91(b) radioactive material is no longer regulated by the Department of Defense (DoD). Material may also be accepted ifit is not regulated or licensed by the NRC or Agreement State or has been authorized for disposal by the IDEQ and is within the numeric waste acceptance criteria. Waste acceptance criteria are consistent with these restrictions.

The following five tables establish types and concentrations of radioactive materials that may be accepted. These tables are based on categories and types of radioactive material not regulated by the NRC, an Agreement State, the DOE, or the DoD for alternate disposal. The criteria are consistent with these restrictions and detailed analyses set forth in Waste Acceptance Criteria and Justification for FUSRAP Material, prepared by Radiation Safety Associates, Inc. (RSA) as subsequently refined, expanded and updated in Waste Acceptance Criteriaand Justification for Radioactive Material, prepared by USEI.

Material may be accepted ifthe material has been specifically exempted from regulation by rule, order, license, license condition, letter of interpretation, or specific authorization under the following conditions: Thirty (30) days prior to intended shipment of such materials to the facility, USEI shall notify IDEQ of its intent to accept such material and submit information describing the material's physical, radiological, and/or chemical properties, impact on the facility radioactive materials performance assessment, and the basis for determining that the material does not require disposal at a facility licensed under the AEA. The IDEQ will have 30 days from receipt of this notification to reject USEI's determination or require further information and review. No response by IDEQ within thirty (30) days following receipt of such notice shall constitute concurrence. IDEQ concurrence is not required for generally exempted material as set forth in Table C.4a.

Based on categories of waste described in the waste acceptance criteria, the concentration of the various radionuclides in the conveyance (e.g., rail car gondola, other container etc.) shall not exceed the concentration limits established in the WAC without the specific written approval of the IDEQ unless generally exempted as set forth in Table C.4a. Radiological surveys will be 4

Chapter C

USEI Part B Permit EPA ID. No.: IDD073114654 Revision Date: March 12, 2015 performed as outlined in ERMP-01 to verify compliance with the WAC. If individual "pockets" of activity are detected indicating the limits may be exceeded, the RSO or RPS shall investigate the discrepancy and estimate the extent or volume of the material with the potentially elevated radiation levels. The RPS or RSO shall then make a determination on the compliance of the entire conveyance load with the appropriate WAC limits. If the conveyance is determined not to meet the limits, USEI will notify IDEQ's RCRA Program Manager within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a concentration based exceedance of the facility WAC to evaluate and discuss management options. The findings and resolution actions shall then be documented and submitted to the IDEQ.

The radioactive material waste acceptance criteria, when used in conjunction with an effective radiation monitoring and protection program as defined in the USEI Radioactive MaterialHealth and Safety Plan and Exempt Radioactive Materials Procedures provides adequate protection of human health and the environment. Included within this manual are requirements for USEI to submit a written summary report of all radioactive material waste receipts showing volumes and radionuclide concentrations and total activities disposed at the USEI site on a quarterly basis.

The 4rn quarter report of each year will also include an updated analysis of the cumulative impact on the facility performance assessment based upon the previous year's waste receipt.

These criteria and procedures are designed to assure that the highest potential dose to a worker handling radioactive material at USEI shall not exceed 400 mrem/year TEDE dose, and that no member of the public is calculated to receive a potential post closure dose exceeding 15 mrem/year TEDE dose, from the USEI program. TEDE is defined as the "Total Effective Dose Equivalent", which equals the sum of external and internal exposures. The public dose limit during operation activities is limited to 100 mrem/yr TEDE dose. An annual summary report of environmental monitoring results will be submitted to IDEQ by June 1 St for the preceding year.

Materials that have a radioactive component that meets the criteria described in Tables 0.1 through C.4c and are RCRA regulated material will be managed as described within this WAP for the RCRA regulated constituents.

Chapter C

USEI Part B Permit EPA ID. No.: IDD073114654 Revision Date: March 12, 2015 Table C.1: Unimportant Quantities of Source Material Uniformly Dispersed" in Soil or Other Media**

STStatus.of, Equilibriuim%*- il!:*7i*;i7:MaximumCo~ncenitrationo*f :;:7 .sum of ConcenrattiOns ,.,7.!

a Natural uranium in equilibrium with <500 ppm / 167 pCi/g (238U activity) <*3000 pCi/g

__progeny Refined natural uranium <500 ppm / 167 pCi/g ( 23 8U activity) _<2000 pCi/g]

Depleted Uranium <500 ppm /169 pCi/g <_2000 pCi/g b Natural thorium <500 ppm / 55 pCilg (2 32Th -<2000pCi/g

______________________________activity)________________

23

°Th (with no progeny) 0.1 ppm / **2000 pCi/g Any mixture of Thorium and Sum of ratios _<1... <2000 pCi/g

-Uranium ______________ ____________

235

Refined Uranium includes238U, U, 234U; 234 Th, 234 mpa, 231 Th Table C.2: Naturally Occurring Radioactive Material Other Than Uranium and Thorium Uniformly Dispersed 0 in Soil or Other Media**

SttsfEqiibimM a xi mum*- ii:- .!** ir":: +i'i Sum o0f Conce'ntrationls of Par~ent -

a 226Ra or 22 8 Ra with progeny in bulk form 1 500 pCi/g *<4500 pCi/g b 226 Ra or 228 Ra with progeny in reinforced 1500 pCi/g 13,500 pCi/g IP-1 containers 1________________

21 C °pb with progeny( Bi &21°po) 1500 pCi/g 4500 pCi/g 4

°K 818 pCi/g N/A 1

Any other NORM 226 3000 pCi/g Any material containing Fa greater than 222 poi/g shall be disposed at least 6 meters from the external point on the completed cell.

Table C.3: Particle Accelerator Produced Radioactive Material 7Accepotabl!e Materia! *i*Activit or;Con:centra~tion. *,ii"!; : :;, ;- ;-,:ii*>*

Any particle All materials shall be packaged in accordance with USDOT packaging requirements.

accelerator produced Any packages containing iodine or volatile radionuclides will have lids or covers radionuclide. sealed to the container with gaskets. Contamination levels on the surface of the packages shall not exceed those allowed at point of receipt by USDOT rules.

Gamma or x-ray radiation levels may not exceed 10 millirem per hour anywhere on the surface of the package. All packages received shall be directly disposed in the

________________active cell. All containers shall be certified to be 90% full.

Average over conveyance or container. The use of the phrase "over the conveyance or container" is meant to reflect the variability on the generator side. The concentration limit is the primary acceptance criteria.

- Unless otherwise authorized by IDEQ, other Media does not include radioactively contaminated liquid (except for incidental liquids in materials). See radioactive contaminated liquid definition (definition section of Part B permit).

- Conc. of U in sample Conc. of Th in Sample Allowable conc. of U + Allowable conc. of Th *-1 6

Chapter C

USEI Part B Permit EPA ID. No.: IDD073114654 Revision Date: March 12, 2015 Table C.4a: NRC Exempted Products, Devices or Items

,Exemnption.

I0CFR-, :Product, !:.- Device i or Item *:*.'

i .!? .: ~* :!! '"i",'Isotope, ConcentrationActivity or **-U-. .

30.15 As listed in the regulation Various isotopes and activities as set forth in 30.15 30.14, Other materials, products or devices specifically exempted Radionuclides in 30.18 from regulation by rule, order, license, license condition, concentrations consistent with

_______concurrence, or letter of interpretation the exemption 85 147 30.19 Self-luminous products containing tritium, Kr, 3H or pm Activity by Manufacturing

___________license 30.20 Gas and aerosol detectors for protection of life and property Isotope and activity by from lire Manufacturing license 30.21 Capsules containing 14 C urea for in viva diagnosis of 14 C, one p*Ci per capsule humans _____________

31.12 General License for certain items and self-luminous products As set forth in 31.12 and see containing Radium 226 #4 under Additional

__________Information below 40.13(a) Unimportant quantity of source material: see Table C.1 *0.05% by weight source material 40.1(b). Unrefined and unprocessed ore containing source material As set forth in rule 40.1 3(c)(1) Source material in incandescent gas mantles, vacuum tubes, Thorium and uranium, various welding rods, electric lamps for illumination amounts or concentrations, see rules 40.1 3(c)(2) (i)Source material in glazed ceramic tableware *<20% by weight (ii)Piezoelectric ceramic *_2% by weight (iii) Glassware not including glass brick, pane glass, ceramic _<10% by weight tile, or other glass or ceramic used in construction 40.13(c)(3) Photographic film, negatives or prints UraniUm or Thorium 40.1 3(c)(4) Finished product or part fabricated of or containing tungsten _<4%by weight thorium or magnesium-thorium alloys. Cannot treat or process content.

__________chemically, metallurgqically, or physically. _____________

40.13(c)(5) Uranium contained in counterweights installed in aircraft, Per stated conditions in rule.

rockets, projectiles and missiles or stored or handled in connection with installation or removal of such counterweights. ______________

40.13(c)(6) Uranium used as shielding in shipping containers if Depleted Uranium conspicuously and legibly impressed with legend "CAUTION RADIOACTIVE SHIELDING - URANIUM" and uranium

___________incased in at least 1/8 inch thick steel or fire resistant metal. ______________

40.13(c)(7) Thorium contained in finished optical lenses *<30% by weight thorium, per

__________conditions in rule.

40.13(c)(8) Thorium contained in any finished aircraft engine part _<4%by weight thorium, per containing nickel-thoria alloy, conditions in rule.

7 Chapter C

USEI Part B Permit EPA ID. No.: IDD073114654 Revision Date: March 12, 2015 Table C.4b: Materials Specifically Exempted by the NRC or NRC Agreement State Exemption Materials: i Isotope, Activity or

_____,_____...___ Concentration*,- -,:

10 CFR Byproduct material including production particle Byproduct material at 30.1 1"* accelerator material exempted from NRC or concentrations consistent Agreement State regulation by rule, order, license, with the exemption license condition or letter of interpretation may be accepted as determined by specific NRC or

____________Agreement State exemption.***

10 CFR Source material exempted from NRC or Agreement Source material at 40.14** State regulation by rule, order, license, license concentrations consistent condition or letter of interpretation may be with the exemption.

accepted as determined by specific NRC or

____________Agreement State exemption.***

10 CFR 70.17 Special Nuclear Material (SNM) exempted from SNM at concentrations NRC regulation by rule, order, license, license consistent with the condition or letter of interpretation may be exemption.

accepted as determined by specific NRC or

___________Agreement State exemption.*** ____________

Sum of all isotopes up to a maximum concentration of 3,000 pCi/gm.

- Alternate disposals authorized by Agreement States also require an NRC exemption for the purposes of disposal inthe State of Idaho.

- Similarmaterial not regulated or licensed by the NRC may also be accepted. Sum of all isotopes up to a maximum concentration of 3,000 pCilgm. IDEQ shall be notified prior to the receipt of Special Nuclear Material not regulated or licensed by the NRC.

Table C.4c Material Released by Other Government Agencies Exemption- Materials .*Isotope, Activity or

__________Concentration*

US DOE Radioactive materials that have been released or Radioactive materials at cleared from radiological control concentrations consistent with the Release **

US DoD Radioactive materials determined to not be Radioactive materials at regulated under the AEA under authority granted to concentrations consistent the DoD in Section 91(b) of the AEA of 1954, as with the Authorization**

___________amended_____________

Sum or all isotopes up to a maximum of 3,000 pCi/gm.

- May include byproduct materials, source materials and special nuclear material as defined inthe AEA of 1954 as amended. NORM and Partical Accelerator Produced Radioactive Material may also be accepted under Tables C.2 and C.3, as part of of these Releases and Authorizations.

Additional Information for USEI's Waste Analysis Plan

1. US Ecology Idaho, Inc. (USEI) may receive contaminated materials or other materials as described in Tables C.1 - C.4b above. USEI may not accept for disposal any material that by its possession would require USEI to have a radioactive material license from the Nuclear Regulatory Commission (NRC).

2. Unless approved in advance by USEI and IDEQ, average activity concentrations may not exceed those concentrations enumerated in Tables C.1 and C.2. Additionally, for Tables C.1 and C.2, individual pockets of material may exceed the WAC for the radionuclides present as long as the average concentration of all radionuclides within the package or conveyance remains at or below the WAC and the highest dose rate measured on the outside of the unshielded package or conveyance does not exceed those action levels Chapter C

USEI Part B Permit EPA ID, No,: IDD073114654 Revision Date: February 26, 2013 enumerated in ERMP-01.

3. Other items, devices or materials listed in Table C.4a, which are exempted in accordance with 10 CFR Parts 30, 40 or equivalent Agreement State regulations or 10 CFR Part 70 may be accepted at or below the activities (per device or item) or concentrations specified in those exemptions.

4. 10OCFR20.2008 authorizes disposal of certain byproduct material as defined in Section 11 .e(3) and 11 .e(4) of the Atomic Energy Act, as amended, at disposal facilities authorized to dispose of such material in accordance with any Federal or State solid or hazardous waste law, as authorized under the Energy Policy Act of 2005.

5. The generator of particle accelerator produced waste must specify that the waste meets applicable acceptance criteria.

6. In accordance with permit requirements, notification of any exceedance of the WAG will be provided to the RC3RA Program Manager within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , in accordance with the permit.

C3hapter C3

Enclosure 4 USEI SSDA Data Input Screen with VY Project-Specific Information (2 Pages)

Attachment 2 Rev. 2Date: 12/*9/2015 USESie-SpecficEDoerAssset okbo DataontnankeeWorksheete Cutm er: bate Worloheet User Insructo and Notes:

Project: Vermont YankeeTorusWater

1. Enter data into Yellow shaded cells (1Njj. All other cells in the workbook are automated and/or protected.

2. Answer all questions in Sectlon I - Waste Stream lnformation first.

Enter values in yellow cells or select answer from drop-down lists 80,000 provided. Notes are also provided in key celLs to asslst the user.

3. Enter concentrations (hn pCVg) for all nuclides in your characterized yu*j ; L* ;-

Volume of waste [cubic meters (in')]: 2.26 waste stream into Section II - Waste Profile Nudlde Eealuatlon.

bris, or a Mix of both? Soil 4. The Manimum Acceptable Concentration for each nuclide is ora combination of both? Truck determined by either the USEI waste Acceptance Criteria (WAC) or a dose-based limit, whichever it lower. The dose-based limit ls tied to the Total Volume of Waste encored by the user. L~ogicin the SSPA workbook will automatrcally choose the mast appropriate value for each nuclide.

5. USEi it limited tona total of 3,000 pCi/g of source material summed over all parent & progeny nuclides (Tb + U).

6. USEI ls limited to a total of 3.000 p~l/g of SNM summed over all Waste Density (Ib/ftn): 62.5 fissile nuclides and their isotopic mixture nuclides, i.e., U-234, U-235, Waste Density (e/cmn): 1.00 and U-238l for enriched uranium.

7. Cross-checks against all USti WAC limits tin automatically calculated in the indicators below.

Maelmwm Acceptable cocetratlon Coa~on Rat*oto USED Max Cal/s) fpO/g~

Nuclide Ac-227 3000 Ag-108m 3000 Ag-i~m 30 Am-241 3000 Am-243 3000 Au-195 3000 Ba-133 30 C-14 3000' Ca-41 50 Cd-109 Ce.13935000 30 Ce-141 3000 I Cf-252 3!000 '

CI-36 30O00 Cm-242 30",0 Cm-243 3000 Cm-24 300 Cm-244 Cm-246 3110 NOTE:

Cm-247 3000 *Thesecross-checks only apply to rrdividual shipmentsfor co-57 3000 IJSEIWAC compliance purposes. They are not intended for annualized saf'ety assessment calculations chat ore dose-Co-60 0.78300000 hosed.

Cr-51 00 Cs-134 3000 Cs-U3S 30(10 Cs-137 0.33 3000 0.0100 Eu-152 31, Eu-154 300 eU-155 310 Fe-55S 3000 Gd-152 3000 Ii H1-3 1870 ,

1-129 3111 1-131 301 lr-192 3110 K-40 3000 Mn-54 0,04 300 0.0 Na-22 3000 l Nb-93m 3000, Page 10of2

Attachment 2 Nb-94 Nb-95 3000 m

Pu-238 3000 pu-239*

PU-240 Pu-241 Pu-242 Ra-226 I *t* -- I Ra-203 Ru-103 3000 S-3S 3000 Sb-122 300 Sb-124 300 5b-125 300 Sc-46 3 000 Sm-14T " 3= !

5m-iS51 5n-113 30 Sr-89 30 Sr-90 3000 Te-I23 3000 Th-228* 300 _____ .... _____

Th-230s00 ____________

Th-232* 3000 Th-204 5 UI-2334 300 ,_________

__ -2____________ 00 U-2356 ________ 3000 I u-235' ________I 30 U-238s ________7 30 Nta Uranium ________ 167 NaturadUraniums _________ 17 ____________

Depleted Uranium ________ 19 __________

Zn-6S 0.24 3000 0.000 Zr-95 _________ 30 ____________

Totol Concentration (pCi/g) 1871.4 Total Sit Metl (pCi/g) 0 Total SNM (p~i/g) 0 TotalActivity (pCi) 424840 Page 2 of 2

Enclosure 5 VY Waste Sample 10 CFR 61 Analysis Results (50 Pages)

I!Laboratories LLC

$[*,l;c Pc-71Cho*r'e:e'n, LC'I SC:294$?

a member of The GEL Group INC P \43_~5-'Sl 7I F 4 ,79.1478 gel~corn December 02, 2015 Mr. Mark Vandale Entergy Nuclear Operations, Inc., VY 530 Governor Hunt Road PO Box 250 Vernon, Vermont 05354 Re: Vermont Yankee Part 61 Work Order: 385542

Dear Mr. Vandale:

GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the sample(s) we received on November 13, 2015. This original data report has been prepared and reviewed in accordance with GEL's standard operating procedures.

Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs on time every time. We trust that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate to call me at (843) 556-8171, ext. 4504.

Sincerely, Erin Trent Project Manager Purchase Order: 10287833 Enclosures

Table of Contents Case Narrative .............................................................. 1 Chain of Custody ........................................................... 3 Laboratory Certifications................................................... 6 Radiological Analysis ...................................................... 8 Sample Data Summary .............................................. 32 Quality Control Data................................................ 36

Case Narrative Page 1 of 48

Case Narrative for Vermont Yankee, Entergy Nuclear Operations Inc.

SDG: 385542 December 02, 2015 Laboratory Identification:

GEL Laboratories LLC 2040 Savage Road Charleston, South Carolina 29407 (843) 556-8171 Summary Sample Receipt The sample arrived at GEL Laboratories LLC, Charleston, South Carolina on November 13, 2015 for analysis. The sample was delivered with proper chain of custody documentation and signatures. All sample containers arrived without any visible signs of tampering or breakage. There are no additional comments concerning sample receipt.

Sample Identification The laboratory received the following sample:

Laboratory ID Client ID 385542001 Torus Water Sample Case Narrative Sample analyses were conducted using methodology as outlined in GEL Laboratories, LLC (GEL)

Standard Operating Procedures. Any technical or administrative problems during analysis, data review, and reduction are contained in the analytical case narratives in the enclosed data package.

Data Package The enclosed data package contains the following sections: General Narrative, Chain of Custody and Supporting Documentation, and data from the following fractions: Radiochemistry.

Eri Trent Project Manager Page 2 of 48

Page 3 of 48 tO Project I 1i~ GEoof GEL Laboratories, LLC

2040 Savage Road 0 GEL Quote #: **See www.gel.com for GEL's Sample Acceptance SOP** Charleston, SC 29407 I-s- COC? Number 0 GEL Work Order Nuber g*** Phone: (843) 556-8171 P0 Number: 10287833 ~Fax: ': (843) 766-1178 Client Name: Mark T. Vandale Phone #:802-258-5579 Sample Analysis Requested (s (Fill in the number of containers for each test)

Project/Site Name: Entergy Nuclear Vermont Yankee Fax #: 802-258-5489 .= .a .'.reevaie'ye 6

_________ _______<--_Preser__ative__Type_ (6.

Address: 320 Governor Hunt Road, Vernon, VT 05354 * *Comments Collected by: Duane Holmquist Send Results Mark T. Vandale -*

c Note: extra sample is

DsteCollketed *Time g .required for sample Sampele ( tedy QC Field Sample * * -= o specific QC t 4

Farcomposites - indicate start andstop dafe.-'titne (mm-dd-yy) (hhmm) Fitrd arx

Tutus Water Sample 11I/10/2015 1t46 G na W Y na I X Approx. 275 nil

[AT Requested: Normal: XX Rush: Specify: (Subjectto Surcharg Fax Results: Yes / No__ Circle Deliverable: C ofA / QC Summary, / Level l / Level 2 / Level 3 1 Level 4 Remarks: Per our conversations the sample was antalyzedfor gamma using I liter in a marinelli beaker. Gamma spec included with email. Samole Co~llection Time Zone EE-astern Pacific Central Other_____

Chain of Custody Signatures Sample Shipping and Delivery Details R~linqaishedfBy (Signed) Date Time IReceived by (signed) Dale TimeGEP:

I" T. Vandale Jl'lark [/'. /,.f( ' (l6* 1 A....e/-/t.-@ Method of Shipment: PedEx Date Shipped:

2 2k' Airbill 15:8013 9497 0310 3

I.) Chain or'Custody Number = Client Determined 13 Airbill 4:

2.) QC Codes: N = Normal Sample, TB = Trip Blank. ltD =Field Duplicate. EBi= Equipment Blank, MS - Matrix Spike Sample, MSD = Matrix Spike Duplicate Sample. G Grab, C Composite For Lab Receiving Use Ontly 3.) Field Filtered: For liquid matrices, indicate with a - Y - for yea th~esample was field filtered or- N - for sample was not foIelfiltered.

-5.) Macix Codes: DW=Drinking Watcr. GW=Groeodwater. SW=Surfacc Water, WWVWaste Water, W=Watec, ML=Misc Liquid. SO=Soil. SD=Scdiment, SL=Sludse, SS=Solid Waste. O--Oil, F-Filter. P-Wipe. OUtrine. F=Feeal. N=Nash CsooySele ITacp:

cN YETetnp:

Cooler 5.) Sample Analysis Requested: Analytical method requested (i.e. 826011.6 Ol/l747A) and number ofecontainers provided for each (i.e. 826eB) -3. 60115174Pt0A- tI).

6.) Preservative Type: HA =Hydrochloric Acid. NI Nitric Acid. SH = Sodium Hydroxide, SA =Sulfuric Acid. AA Ascorbic Acid, HlX =Henane, ST Sodiunm Thiosulfate, If no preservative is added =leave field blank C WH/ITE = LABORATORY YELLOW =FILE PINK =CLIENT

SLaboratories LLC SAMPLE RECEIPT & REVIEW FORM R eeied By: .. tcZ _, _ Date Receivd: I l Suspcte EfaardFnfersntion SuspctedHazad Iformtion*

~* ;

5 fl'Nat Counts > 100rpm on*

investigation.'

~pies ant-s marked 'radioactive', contact the Radiation Safety CGroup for further COCiSampies marked as radioactive? _ _ Maximum Net Counts Observed* (Observed Counts - Area Background Counts): Eli*'.

Classified Radioactive li or il[ by' RSO? .,"if yes. Were swipes takens of sample containers < action levels? "

COCISamples marked containing PCBs? ______________,__________________________

Package.; COC andlor Samples marked as ... ,.be *'*I.:'.., .. . '.'" .:-::*:

Shipped as a DOT Hazardous? 4 Hazard Class Shipped: UN#: /0i" Samples identified as Foreign Soii? ________________________________________________

Sample Receipt Criteria * * -[ Commnents/Qualifiers (Required for Non-Conformingl tiens)

S"ppn cnanrreiedjtctndCircle Ap'plieabie: Sealsbroken Damaged container Leaking conaraner Other (describe) 1sealed?

2 Samples requiring cold5 preservation a1tmeaue r eoddi esu within (0, <:,6 do'g. C)? _,_,_-__a______tat_.... __d__in __lsiu ___________________ ---

2a Daily check performed and passed on IR T~emisermnre Device Serial

I plmbeS ,.

temperature gun? eods eprtr eieSra 3Chain of custody documents included with shipment? _____________________________________

Circle Applicable: Seats broken Damaged container Leakingecontainer Other (describe) 4 Sample containers intact and sealed?

SSamples requiring chemical preservation

Sample IDes,cont'ainers affected and observ'ed pit:

Sat proper p1-? -r Psprocreaion added, I, lt5 6Do Low Level Perchiorate sanmples have Sample Il's andlcontaincrs affected:

6 hseadspace as required? __________________________________________

7 VOA vials contain acid preservation? (t nnwslc o 8 VOA vials free of headspace (defined'as Sample ID's aed containers affected:

S6nsm' bubble)? S" 9 r Enoreconaines peset?.If yes, imnmediately deliver to.Voiatiles laboratory) tD's and tests affected:

10 Samples reeeived within holding time? I Sample ID's on COC match ID's on Sample ID's and containers affersed':

11 b*ottles?

12 Date & time on COC match dale & time Sapl D's fetd Number of containers received match Sample lD¶saffected:

13 number indicated on COC?

14Ar sanmpie constainers identifiable as 14GEL provided? ___________________________________

COC grmfo is properly signed in 15erlinquishsed/received sections? ______________________________________

~Cirele Applieshle FedE's Ground UPS Field Services Courier Other 16 Carrier and tracking number.

Comments (Use'Continuation Form if needed): "

PM(rPA eie:Iiil ate IPg 4-f L G-o-S-O e Page 5 of 48

Laboratory Certifications Page 6 of 48

List of current GEL Certifications as of 02 December 2015 State Certification Alaska UST-110 Arkansas 88-0651 CLIA 42D0904046 California 2940 Interim Colorado SC00012 Connecticut PH-0 169 Delaware SC00012201 3-1 0 DoD ELAP/I1SO17025 A2LA 2567.01 Florida NELAP E87 156 Foreign Soils Permit P330-15-00283, P330-15-00253 Georgia SC00012 Georgia SDWA 967 Hawaii SC000122013-10 Idaho Chemistry SC00012 Idaho Radiochemistry SC00012 Illinois NELAP 200029 Indiana C-SC-01 Kansas NELAP E-10332 Kentucky SDWA 90129 Kentucky Wastewater 90129 Louisiana NELAP 03046 (A133 904)

Louisiana SDWA LA150001 Maryland 270 Massachusetts M-SC012 Michigan 9976 Mississippi SC000122013-10 Nebraska NE-OS-26-1 3 Nevada SC000122016-5 New Hampshire NELAP 2054 New Jersey NELAP SC002 New Mexico SC00012 New York NELAP 11501 North Carolina 233 North Carolina SDWA 45709 North Dakota R-158 Oklahoma 9904 Pennsylvania NELAP 68-00485 S.Carolina Radchem 10120002 South Carolina Chemistry 10120001 Tennessee TN 02934 Texas NELAP T104704235-15-10 Utah NELAP SC000122015-19 Vermont VT87 156 Virginia NELAP 460202 Washington C780 West Virginia 997404 Page 7 of 48

Radiological Analysis Page 8 of 48

Radiochemistry Technical Case Narrative Vermont Yankee, Entergy Nuclear Operations Inc. (NTRG)

SDG #f: 385542 Method/Analysis Information Product: Alphaspec Pu242, Liquid Analytical Method: DOE EML HASL-3 00, Pu-i11-RC Modified Analytical Batch Number: 1526134 Sample ID Client I'D 385542001 Torus Water Sample 1203440593 Method Blank (MVB) 1203440595 Laboratory Control Sample (LCS) 1203440594 385542001(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-01 1REV# 25.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality_ Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Page 9 of 48

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Manual Integration No manual integrations were performed on data in this batch.

Sample-Specific MDA/MiDC The MDAIMDC reported on the certificate of analysis is a sample-specific MDA/MvDC.

Additional Comments Samples 1203440594 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Oualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Alphaspec Am-241, Cm-242, 243/244 Liquid Analytical Method: DOE EML HASL-300, Am-05-RC Modified Analytical Batch Number: 1526135 Sample ID Client ID 385542001 Torus Water Sample 1203440597 Method Blank (MB) 1203440599 Laboratory Control Sample (LCS) 1203440598 385542001l(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with Page 10 of 48

GL-RAD-A-01 1 REV# 25.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality Control (QC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Manual Integration No manual integrations were performed on data in this batch.

Sample-Specific MDA/MDC The MDAJMDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Samples 1203440598 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis. ,

Oualifier Information Manual qualifiers were not required.

Page 11 of 48

Method/Analysis Information Product: Aiphaspec Np, Liquid.

Analytical Method: ASTM C 1476-00 Modified Analytical Batch Number: 1526136 Sample LID Client ID 38554200 1 Torus Water Sample 1203440600 Method Blank (MB) 1203440602 Laboratory Control Sample (LCS) 1203440601 385542001(Torus Water Sample) Sample Duplicate (DUJP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-032 REV# 20.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Quality Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis Page 12 of 48

None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Manual Integration No manual integrations were performed on data in this batch.

Sample-Specific MDA/MDC The IvDAJMiDC reported on the certificate of analysis is a sample-specific MD)AiMDC.

Additional Comments Samples 1203440601 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

_Qualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Gammaspec, Gamma, Liquid Analytical Method: EPA 901.1 Analytical Batch Number: 1523381 Sample ID Client ID 385542001 Torus Water Sample 1203433635 Method Blank (MB).

1203433637 Laboratory Control Sample (LCS) 1203433636 385542001(Torus Water Sample) Sample Duplicate (DUJP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-013 REV# 25.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Page 13 of 48

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Onality Control (OC0 Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts Samples 1203433636 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were counted for a longer time period to achieve lower detection limits.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MvDA/MvDC.

Additional Comments Gamma spec is typically the first analysis performed on 10 CFR part 61 samples. Due to some following tests requiring that their samples have no preservation, the samples 1203433636 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were analyzed without preservation.

Qualifier Information Qualifier Reason Analyte Sample Client Sample UIData rejected due to high counting Cbl-8 35401 Torus Water UJuncertainty.bat58 35520 Sample Page 14 of 48

Method/Analvsis Information Product: Gamma 1129, Liquid Analytical Method: DOE EML HASL-300,I-01 Modified Analytical Batch Number: 1524875 Sample ID Client ID 385542001 Torus Water Sample 1203437407 Method Blank (MB) 1203437410 Laboratory Control Sample (LCS) 1203437408 385542001(Torus Water Sample) Sample Duplicate (DUP) 1203437409 385542001(Torus Water Sample) Matrix Spike (MVS)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-006 REV# 21.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Page 15 of 48

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MD)A/MvDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Additional comments were not required for this sample set.

Qualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Gamma Ni59, Liquid Analytical Method: DOE RESL Ni-i Analytical Batch Number: 1526787 Sample ID Client ID 385542001 Torus Water Sample 1203442168 Method Blank (MB) 1203442170 Laboratory Control Sample (LCS) 1203442169 38554200 1(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-022 REV# 17.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Page 16 of 48

Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality_ Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Chemical Recoveries All chemical recoveries meet the required acceptance limits for this sample set.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDAIMDC.

Additional Comments Samples 1203442169 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Oualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Liquid Scint Pu241, Liquid Page 17 of 48

Analytical Method: AnalticaEML Metod:DOE HASL-300, Pu-I11-RC Modified Analytical Batch Number: 1526137 Sample ID Client ID 385542001 Torus Water Sample 1203440603 Method Blank (MB) 1203440605 Laboratory Control Sample (LCS) 1203440604 385542001(Torus Water Sample) Sample Duplicate (DUJP)

Sample 385542 001 in this SDG was analyzed on an "as received' basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-035 REV# 16.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Quality Control (0C0 Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts Sample 1203440605 (LCS) was recounted due to high recovery. The recount is reported.

Page 18 of 48

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Manual Integration No manual integrations were performed on data in this batch.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Samples 1203440604 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Qualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: LSC, Rapid Sr-89/90, Liquid Analytical Method: GL-RAD-A-05 1 Analytical Batch Number: 1525458 Sample iD Client ID 38554200 1 Torus Water Sample 1203438834 Method Blank (MB) 1203438836 Laboratory Control Sample (LCS) 1203438835 385542001(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-05 1 REV# 6.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Page 19 of 48

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Quality. Control (0C) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples meet the required acceptance limits with the following exceptions: The blank, 1203438834 (MB), did not meet the Strontium-90 detection limit due to keeping the blank volume consistent with the other sample aliquots. All other samples met the detection limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MDA/MvDC reported on the certificate of analysis is a sample-specific MDAfMI)C.

Additional Comments Samples 1203438835 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Qualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Liquid Scint Fe55, Liquid Analytical Method: DOE RESL Fe-i, Modified Analytical Batch Number: 1525543 Page 20 of 48

Sample ID Client ID 38554200 1 Torus Water Sample 1203439050 Method Blank (MB) 1203439052 Laboratory Control Sample (LCS) 1203439051 385542001(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an 'as received' basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-040 REV# 12.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Page 21 of 48

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Samples 1203439051 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Qualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Liquid Scint Ni63, Liquid Analytical Method: DOE RESL Ni-i, Modified Analytical Batch Number: 1525545 Sample ID Client ID 385542001 Torus Water Sample 1203439053 Method Blank (MB) 1203439055 Laboratory Control Sample (LCS) 1203439054 385542001(Torus Water Sample) Sample Duplicate (DUJP)

Sample 385542 001 in this SDG was analyzed on an 'as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-022 REV# 17.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Quality Control (OC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Page 22 of 48

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (§DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MIDA/MDC.

Additional Comments Samples 1203439054 (Torus Water SampleDUP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Oualifier Information Manual qualifiers were not required.

Method/Analysis Information Product: Liquid Scint Tc99, Liquid Analytical Method: DOE EML HASL-300, Tc-02-RC Modified Analytical Batch Number: 1525546 Sample ID Client ID 38554200 1 Torus Water Sample 1203439056 Method Blank (MB) 1203439058 "Laboratory Control Sample (LCS) 1203439057 38554200 1(Torus Water Sample) Sample Duplicate (DUP)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Page 23 of 48

Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-059 REV# 3.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality_ Control (QC) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of 'the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. A data exception report (DER) was not generated for this SDG.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Samples 1203439057 (Torus Water SampleDUiP) and 385542001 (Torus Water Sample) were received unpreserved. The entire container was preserved prior to analysis.

Qualifier Information Manual qualifiers were not required.

Page 24 of 48

Method/Analysis Information Product: LSC, Tritium Dist, Liquid Analytical Method: EPA 906.0 Modified Analytical Batch Number: 1525547 Sample ID Client ID 385542001 Torus Water Sample 1203439059 Method Blank (MB) 1203439062 Laboratoiy Control Sample (LCS) 1203439060 385542001(Torus Water Sample) Sample Duplicate (DUP?)

1203439061 385542001(Torus Water Sample) Matrix Spike (MS)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-002 REV# 21.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Oualityv Control (0C) Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples meet the required acceptance limits with the following exceptions: The blank result 1203439059 (MB) is greater than the MDC but less than the required detection limit.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis Page 25 of 48

None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. The following DER was generated for this SDG: DER 1473853 was generated due to Sample improperly preserved. 1. Samples 385542001, 1203439060, and 1203439061 were received unpreserved; however, the sample container was preserved with nitric acid prior to analysis, which mnay cause the samples' results to be biased low. 1. Reporting results.

Sample-Specific MDA/MDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Additional comments were not required for this sample set.

Qualifier Information Qualifier Reason Analyte Sample Client Sample Result may be biased low due to the sample container being J preserved with nitric prior to Tritium 385542001 Torus Water Sample analysis.

1203439060 TouWae Sample(385542001DUP) 1203439061 TouWae Sample(385542001MS)

Method/Analysis Information Product: Liquid Scint C14, Liquid Analytical Method: EPA EERF C-01 Modified Analytical Batch Number: 1525548 Sample ID Client ID 385542001 Torus Water Sample 1203439063 Method Blank (MB) 1203439066 Laboratory Control Sample (LCS) 1203439064 38554200 1(Torus Water Sample) Sample Duplicate (D:UP)

Page 26 of 48

1203439065 385542001(Torus Water Sample) Matrix Spike (MS)

Sample 385542 001 in this SDG was analyzed on an "as received" basis.

SOP Reference Procedure for preparation, analysis and reporting of analytical data are controlled by GEL Laboratories LLC as Standard Operating Procedure (SOP). The data discussed in this narrative has been analyzed in accordance with GL-RAD-A-003 REV# 15.

Calibration Information:

Calibration Information All initial and continuing calibration requirements have been met.

Standards Information Standard solutions for these analysis are NIST traceable or verified with a NIST traceable standard and used before the expiration dates.

Sample Geometry All counting sources were prepared in the same geometry as the calibration standards.

Ouality Control (00)Information:

Blank Information The blank volume is representative of the sample volume in this batch.

QC Information All of the QC samples met the required acceptance limits.

Designated QC The following sample was used for QC: 385542001 (Torus Water Sample).

Technical Information:

Holding Time All sample procedures for this sample set were performed within the required holding time.

Sample Re-prep/Re-analysis None of the samples in this sample set required reprep or reanalysis.

Recounts None of the samples in this sample set were recounted.

Miscellaneous Information:

Data Exception (DER) Documentation Data exception reports are generated to document any procedural anomalies that may deviate from referenced SOP or contractual documents. The following DER was generated for this SDG: DER 1473847 was generated due to Sample improperly preserved. 1. Samples 385542001, 1203439064, and 1203439065 were received unpreserved; however, the sample container was preserved with nitric acid prior to analysis, which may cause the samples' results to be biased low. 1. Reporting results.

Sample-Specific MDA/MIDC The MDA/MDC reported on the certificate of analysis is a sample-specific MDA/MDC.

Additional Comments Page 27 of 48

Additional comments were not required for this sample set.

Oualifier Information Qualifier Reason Analyte Sample Client Sample Result may be biased low due to the sample container being J preserved with nitric prior to Carbon-14 385542001 Torus Water Sample analysis.

120349064 Torus Water Sample(385542001DUP) 1203439065 TouWae Sample(385542001MS)

Certification Statement Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless otherwise noted in the analytical case narrative.

Page 28 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com VERM001 Vermiont Yankee, Entergy Nuclear Operations Inc.

Client SDG: 385542 GEL Work Order: 385542 Sample(s) Contained within this report:

Lab Sample ID Client Sample ID Sample Description Collected 385542001 N/A 11/10/2015 11:46 Torus Water Sample Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the Certificate of Analysis.

This data report has been prepared and reviewed in accordance with GEL Laboratories LLC standard operating procedures. Please direct any questions to your Project Manager, Erin Trent.

Reviewed by Name: Theresa Austin Date: 07 DEC 2015

Title:

Group Leader Page 29 of 48

GEL Laboratories LLC DER Report No.: 1473847 Form GEL-DER Revision No.: 2 DATA EXCEPTION REPORT Mo.Day Yr. Division: Quality Criteria: Type:

07-DEC-i5 Radiochemistry Specifications Process Instrument Type: Test!/ Method: Matrix Type: Client Code:

LSC EPA EERF 0-01 Modified Liquid VERM Batch ID: Sampie Numbers:

1525548 See below Potentially affected work order(s)(SDG): 385542 Application issues:

Sample improperly preserved Specification and Requirements IDER Disposition:

Exception

Description:

1. Samples 385542001, 1203439064, and 1203439065 were received 1. Reporting results.

unpreserved; however, the sample container was preserved with nitric acid prior to analysis, which may cause the samples' results to be biased low.

Originator's Name: Data ValdatorlGroup Leader:

Lyndsey Pace 07-DEC-i5 Lesley Anderson 07-DEC-I5 Page 30 0f48

GEL Laboratories LLC DER Report No.: 1473853 Form GEL-DER Revision No.: 1 DATA EXCEPTION REPORT Mo.Day Yr. Division: Quality Criteria: Type:

07-DEC-i15 Radiochemistry Specifications Process Instrument Type: Test!/ Method: Matrix Type: Client Code:

LSC EPA 906.0 Modified Liquid VERM Batch ID: Sampie Numbers:

1525547 See below Potentaialy affected work order(s)(SDG): 385542 Appiication Issues:

Sampie improperly preserved Specification and Requirements DER Disposition:

Exception

Description:

-F

1. Samples 385542001, 1203439060, and 1203439061 were received 1. Reporting results.

unpreserved; however, the sample container was preserved with nitric acid prior to analysis, which may cause the samples' results to be biased low.

Originator's Name: Data ValidatorlGroup Leader:

Lyndsey Pace 07-DEC-i5 Lesley Anderson 07-DEC-I5 Page 31 of 48

Sample Data Summary Page 32 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.corn 10 CFR Part 50/6 1 Certificate of Analysis GEL Sample ID: 385542001 Client: Vermont Yankee, Entergy Nuclear Operati.

Client Sample I-D: Torus Water Sample Collect Date: November 10, 2015 Matrix: Water Receive Date: November 13, 2015 Geometry Received: Report Date: December 07, 2015 Analyte Run Date Qualifier Activity 2 Sigma 1 Uncertainty MDA- RL Units H-3 12/04/15 3,J 1.87E-03 2.7 1E-04 2.33E-04 4.00E-02 uCi/mL C-14 12/05/15 UJ -2.12E-06 1.85E-05 3.25E-05 8.00E-03 uCi/mL Fe-55 12/02/15 U 2.49E-06 5.54E-05 8.46E-05 7.00E-01 uCi/mL Ni-63 12/01/15 U 6.46E-06 2.85E-05 4.94E-05 3.50E-03 uCi/mL Sr-89 12/01/15 3,U 6.18E-05 4.54E-05 7.25E-05 7.00E-01 uCi/mL Sr-90 12/01/15 U -4.53E-06 2.17E-05 3.79E-05 4.00E-05 uCi/mL Tc-99 11/29/15 U -2.82E-05 2.71lE-05 4.94E-05 3.00E-03 uCi/mE Pu-241 12/01/15 U 2.25E-06 4.81IE-06 8.33E-06 3.50E-03 uCi/mL Alpha Spec Np-237 11/28/15 U I1.45E-08 2.86E-08 4.83E-08 1.00E-04 uCi/mL Pu-238 11/28/15 U 3.85E-09 2.14E-08 4.10OE-08 1.00E-04 uCi/mE Pu-239/240 11/28/15 U 2.96E-10 2.20E-08 4.88E-08 1.00E-04 uCi/mL Pu-242 11/28/15 U -5.33E-09 1.61IE-08 4.52E-08 1.00E-04 uCi/mnL Am-241 11/28/15 U 3.15E-09 1 .75E-08 3.35E-08 1.00E-04 uCi/mL Cm-242 11/28/15 U 6.45E-09 1.8 1E-08 1.94E-08 2.O0E-02 uCi/mL Cm-243/244 11/28/15 U -2.87E-09 1.27E-08 3.31IE-08 1.00E-04 uCi/mL Gamma Spec Be-7 11/17/15 U 5.30E-08 1.15E-07 2.03E-07 uCi/mL Na-22 11/17/15 3,U I1.48E-08 1.19E-08 2.05E-08 uCi/mL K-40 11/17/15 U 2.1 1E-08 1.89E-07 2.07E-07 uCi/mL Cr-5 1 11/17/15 U 6.01E-08 1.1 6E-07 2.08E-07 uCi/mL Mn-54 11/17/15 3 4.27E-08 2.26E-08 2.88E-08 uCi/mL Fe-59 11/17/15 U 1.74E-08 5.14E-08 6.50E-08 uCi/mL Co-56 11/17/15 U 1 .38E-08 1.62E-08 3.00E-08 uCi/mE Co-57 11/17/15 U 1.22E-09 9.36E-09 1.43E-08 uCi/mL Co-58 11/17/15 UI 0.00E+00 2.67E-08 2.53E-08 uCi/mL Co-60 11/17/15 3 7.76E-07 5.59E-08 2.30E-08 7.00E-01 uCi/mL Ni-59 11/30/15 U -3.65E-05 5.81IE-05 9.51lE-05 2.20E-01 uCi/mi Zn-65 11/17/15 3 2.35E-07 5.15E-08 6.82E-08 uCi/mL Y-88 11/17/15 U -4. 19E-09 1.07E-08 1.97E-08 uCi/mL Zr-95 11/17/15 U 2.30OE-08 2.65E-08 4.49E-08 uCi/mL Nb-94 11/17/15 U -2.09E-09 I1.38E-08 2.34E-08 2.00E-04 uCi/mL Nb-95 11/17/15 U 5.93E-I0 1.41E-08 2.52E-08 uCi/mL Ru- 106 11/17/15 U -1.72E-08 1.27E-07 2.25E-07 uCi/mLt Ag-Illin 11/17/15 U 7.53E-09 1.56E-08 2.52E-08 uCi/mLt Sn-il13 11/17/15 U -5.62E-09 1.60E-08 2.72E-08 uCi/miL Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

J Value is estimated U Analyte was analyzed for, but not detected above the MDL, MDA, or LOD.

UL Gamma Spectroscopy--Uncertain identification Page 33 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gelkcom 10 CFR Part 50/61 Certificate of Analysis GEL Sample ID: 385542001 Client: Vermont Yankee, Entergy Nuclear Operati, Client Sample I-D: Torus Water Sample Collect Date: November 10, 2015 Matrix: Water Receive Date: November 13, 2015 Geometry Received: Report Date: December 07, 2015 Analyte Run Date Qualifier Activity 2 2 Sigma1 Uncertainty MDA RL Units Sb- 124 11/17/15 U -7.35E-09 2.57E-08 4.78E-08 uCi/mL Sb-125 11/17/15 U 1.45E-08 3.74E-08 6.58E-08 uCi/mE 1-129 11/25/15 U -1.84E-08 1.27E-07 2.46E-07 8.00E-05 uCi/mE Cs-134 11/17/15 U -5.30E-09 1.64E-08 2.83E-08 uCi/mL Cs-136 11/17/15 U 1.44E-08 2.90E-08 5.35E-08 uCi/mL Cs-137 11/17/15 3 3.27E-07 3.45E-08 2.54E-08 1.00E-03 uCi/mL Ba- 133 11/17/15 U -1.94E-08 1.99E-08 3.02E-08 uCi/mL Ba-140 11/17/15 U 1.95E-08 6.53E-08 1.20E-07 uCi/mnL Ce-139 11/17/15 U -4.68E-09 9.73E-09 1.71IE-08 uCi/mL Ce-141 11/17/15 U -6.62E-09 2.05E-08 3.12E-08 uCi/mL Ce-144 11/17/15 3,U 9.07E-08 8.08E-08 1.02E-07 uCi/mL Nd-147 11/17/15 3,U 1.49E-07 1.25E-07 2.42E-07 uCi/mL Pm-144 11/17/15 U 9.75E-09 1.39E-08 2.57E-08 uCi/mnL Pm-146 11/17/15 U -6.55E-10 1.70E-08 2.9 1E-08 uCi/mL Eu-1 52 11/17/15 U 3.61E-08 4.45E-08 6.50E-08 uCi/mL Eu- 154 11/17/ 15 3,U 4.21IE-08 3.3 9E-08 6.6 1E-08 uCi/mL Eu-155 11/17/15 3,U 3.78E-08 3.2 1E-08 5.81IE-08 uCi/mL Ir-192 11/17/15 U -5.45E-10 1.29E-08 2.24E-08 uCi/mE Hg-203 11/17/15 U 4.87E-09 1.28E-08 2.29E-08 uCi/mE T1-208 11/17/15 U 2.43E-09 2.92E-08 2.23E-08 uCi/inL Pb-210 11/17/15 U 1.69E-07 8.54E-07 8.63E-07 uCi/mL Pb-2 12 11/17/15 U -2.09E-08 2.43E-08 3.88E-08 uCi/mL Pb-214 11/17/15 U -3.36E-09 3.41lE-08 5.44E-08 uCi/mnL Bi-2 12 11/17/15 U -1.83E-08 1.97E-07 3.47E-07 uCi/mL Bi-214 11/17/15 U 4.05E-09 4.31LE-08 4.91IE-08 uCi/mL Ra-228 11/17/15 U -2.06E-08 7.42E-08 1.24E-07 uCi/mL Ac-228 11/17/15 U -2.06E-08 7.42E-08 1.24E-07 uCi/mL Th-230 11/17/15 U -1.32E-06 2.58E-06 4.13E-06 uCi/mE Th-234 11/17/15 U -3.63E-07 3.51IE-07 5.96E-07 uCi/mL U-235 11/17/15 U -9.03E-08 7.99E-08 1.17E-07 uCi/mL U-238 11/17/15 U -3.63E-07 3.51IE-07 5.96E-07 uCi/mL Np-239 11/17/15 U 1.06E-09 8.64E-08 I1.47E-07 uCi/mL Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

J Value is estimated U Analyte was analyzed for, but not detected above the MDL, MDA, or LOD.

UI Gamma Spectroscopy--Uncertain identification Page 34 of 48

GEL LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Isotope Abundance Report GEL Sample ID: 385542001 Client: Vermont Yankee, Entergy Nuclear Operations Inc.

Client SampleI [D: TorulS Water Sample Collect Date: November 10, 2015 Matrix: Water Receive Date: November 13, 2015 Ana!yte ....... Activity Units % Abundance H-3 1.87E-03 uCi/mL 099.93 Alpha Spec Gamma Spec Cs-137 3.27E-07 uCi/nmL 000.02 Co-60 7.76E-07 uCi/mL 000.04 Zn-65 2.35E-07 uCi/miL 000.01 Total Activity: 1.87E-03 Total % Abundance: 100.00 Page 35 of 48

Quality Control Data Page 36 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.com Oc Summary Report Date: December 7. 2015 Entergy Nuclear Operations, Inc., VY Page 1 of 12 530 Governor Hunt Road P0 Box 250 Vernon, Vermont

Contact:

Mr. Mark Vandale Workorder: 385542 Parmname NOM Samnle Oual OC Units RPD% REC% Ranne Anlst Date Time Rad Alpha Spec Batch 1526134 QC1203440594 385542001 DUP Plutonium-238 U 3.85E-09 3.72E-08 uCi/mE 9.74 (0%- 100%) MXS2 11/28/15 11:30 Uncertainty +/'-2. 14E-08 +/-3.38E-08 Plutonium-239/240 U 2.96E-10 U -6.20E-09 uCi/mL N/A N/A Uncertainty +//-2.20E-08 +/-1.44E-08 Plutonium-242 U -5.33E-09 U -7.74E-09 uCi/mL N/A N/A Uncertainty +//-1.61E-08 +/-1 .47E-08 QC1203440595 LCS Plutonium-238 U -1.57E-08 uCi/mL 11/28/15 11:30 Uncertainty +/-2.98E-08 Plutonium-239/240 1.98E-06 2.43E-06 u~i/rmL 123 (75%-125%)

Uncertainty +/-3.5 1E-07 Plutonium-242 U -2.62E-09 uCi/mL Uncertainty +/-3.93E-08 QC1203440593 MB Plutonium-238 U 4.95E-09 uCi/mE 11/28/15 11:30 Uncertainty +/-1 .86E-08 Plutonium-239/240 U 8.33E-09 uCi/mL Uncertainty +/-2.29E-08 Plutonium-242 U -6.24E-09 uCi/inL Uncertainty +/-1 .45E-08 Batch 1526135 QC1203440598 385542001 DUP Americium-241 U 3.15E-09 U -1.76E-09 uCi/mnL N/A N/A MXS2 11/28/15 11:30 Uncertainty +/'-1 .75E-08 +/-1 .52E-08 Curium-242 U 6.45E-09 U 7.82E-09 uCi/mL N/A N/A Uncertainty +//-1.81E-08 +/-2.20E-08 Curium-243/244 U -2.87E-09 U -1.74E-09 uCi/miL N/A N/A Uncertainty +//1.27E-08 +/-1 .50E-08 QC1203440599 LCS Americium-241 1.97E-06 1.88E-06 uCi/miL 11/28/15 11:30 95.4 (75%-125%)

Uncertainty +/-2. 13E-07 Curium-242 U 6.19E-09 uCi/miL Uncertainty +/- 1.74E-08 Curium-243/244 2.69E-06 2.44E-06 uCi/mE 90.7 (75%-125%)

Uncertainty +/-2.39E-07 QC1203440597 MB Americium-241 U -6.80E-09 uCi/miL 11/28/15 11:30 Uncertainty +/-2.30E-08 Curium-242 U -5.33E-09 uCi/mL Uncertainty +/-1.61E-08 Page 37 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.com Workorder: 385542 Qc Summary Pg f1 Parmname NOM Sample Qual QC Units RPD% REC% Range Anist Date Time Rad Alpha Spec Batch 1526135 Curium-243/244 U 3.79E-09 uCi/mL

+/-2.11IE-08 Uncertainty Batch 1526136-QC1203440601 385542001 DUP Neptunium-237 U 1.45E-08 U 1.40E-08 uCi/mL N/A N/AMXS2 11/28/15 11:30 Uncertainty +/-2.86E-08 +/-3.1 1E-08 QC1203440602 LCS Neptunium-237 4.47E-06 4.55E-06 uCi/mL 102 (75%-125%) 11/28/15 11:30 Uncertainty +/-3.58E-07 QC1203440600 MB Neptunium-237 U 2.54E-08 uCi/mL 11/28/15 11:30 Uncertainty +/-4. 12E-08 Batch 1526137-QC1203440604 385542001 DUP Plutonium-24 1 U 2.25E-06 U 1.07E-06 uCi/mL N/A N/A MXS2 12/01/15 05:18 Uncertainty +/-4.81E-06 +/-4.79E-06 QC1203440605 LCS Plutonium-241 7.93E-05 9.81lE-05 uCi/mL 12/01/15 09:35 124 (75%-125%)

Uncertainty +/-9. 15E-06 QC1203440603 MB Plutonium-241 U 1.97E-06 uCi/muL 12/01/15 05:02 Uncertainty +/-4.60E-06 Rad Gamma Spec Batch 1523381 QC1203433636 385542001 DUP Act inium-228 U -2.06E-08 U 9.45E-08 uCi/mLt N/A N/A MJH1 11/16/15 08:04 Uncertainty +/-7.42E-08 +/-1.04E-07 Antimony-124 U -7.35E-09 U 1.67E-08 uCi/muL N/A N/A Uncertainty +/-2.57E-08 +/-2.33E-08 Antimony- 125 U I1.45E-08 U 3.74E-08 uCi/mL N/A N/A Uncertainty +/-3.74E-08 +/-3.94E-08 Barium-I133 U -1.94E-08 U -9.74E-09 uCi/mL N/A N/A Uncertainty +/-1.99E-08 +/- 1.86E-08 Barium-140 U 1.95E-08 U 3.92E-08 uCi/muL N/A N/A Uncertainty +/-6.53E-08 +/-7.90E-08 Beryllium-7 U 5.30E-08 U 4.98E-09 uCi/mL N/A N/A Uncertainty +/-1.15E-07 +/-1 .22E-07 Bismuth-212 U -1.83E-08 U 1.15E-07 uCi/mL N/A N/A Uncertainty +/-1 .97E-07 +/-2.40E-07 Bismuth-214 U 4.05E-09 U -3.46E-08 uCi/mL N/A N/A Uncertainty +/-4.3IE-08 +/-3.96E-08 Cerium-139 U -4.68E-09 U -6.64E-09 uCi/mL N/A N/A Uncertainty +/-9.73E-09 +/-1.23E-08 Cerium- 141 U -6.62E-09 U 1.81E-08 uCi/mL N/A N/A Uncertainty +/-2.05E-08 +/-2.26E-08 Page 38 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.corni Qc Summary Workorder: 385542 Page 3 of 12 Workorder: 385542 Page 3 of 12 Parm nnme NOM 5Samnle 01,al OC U~nits RPD%/ REC% Range Anlst Date Time Rad Gamma Spec Batch 1523381 Cerium- 144 U 9.07E-08 -3.07E-09 uCi/mL N/A N/A Uncertainty +/-8.08E-08 +/-7.47E-08 Cesium-134 U -5.30E-09 -1 .26E-09 uCi/mnL N/A N/A MliH1 11/16/15 08:04 Uncertainty +/-1 .64E-08 +/-1 .95E-08 Cesium-136 U 1.44E-08 -2.56E-08 uCi/mE N/A N/A Uncertainty +/-2.90E-08 +/-3.05E-08 Cesium-I137 3.27E-07 2.77E-07 uCi/mE 9.25 (0%-20%)

Uncertainty +/-3.45E-08 +/-4.64E-08 Chromium-5 1 U 6.01E-08 -11.34E-08 uCi/mL N/A N/A Uncertainty +/-1.16E-07 +/-1.32E-07 Cobalt-56 U 1.38E-08 2.32E-09 uCi/mL N/A N/A Uncertainty +/-1 .62E-08 +/-2.00E-08 Cobalt-57 U 1.22E-09 2.82E-10 uCi/mL N/A N/A Uncertainty +/-9.36E-09 +/-9.80E-09 Cobalt-58 UI 0.00 2. 14E-08 uCi/mE N/A N/A Uncertainty +/-2.67E-08 +/-2. 10E-08 Cobalt-60 7.76E-07 8.21E-07 uCi/mL 8.11 (0%-20%)

Uncertainty +/-5.59E-08 +/-6.1 1E-08 Europium- 152 U 3.61E-08 2.72E-08 uCi/mL N/A N/A Uncertainty +/-4.45E-08 +/-4.24E-08 Europium- 154 U 4.21E-08 9.42E-10 uCi/mL N/A N/A Uncertainty +/-3.39E-08 +/-3.99E-08 Europium- 155 U 3.78E-08 -3.64E-09 uCi/mL N/A N/A Uncertainty +/-3.21E-08 +/-3.69E-08 Iridium- 192 U -5.45E-10 -9.59E-09 uCi/mL N/A N/A Uncertainty +/-1.29E-08 +/-1.47E-08 Iron-59 U 1.74E-08 2.89E-08 uCi/mL N/A N/A Uncertainty +/-5. 14E-08 +/-3.55E-08 Lead-210 U 1.69E-07 3.25E-07 uCi/mL N/A N/A Uncertainty +/-8.54E-07 +/-7.46E-07 Lead-212 U -2.09E-08 -4.31lE-I0 uCi/mL N/A N/A Uncertainty +/-2.43E-08 +/-2.72E-08 Lead-214 U -3.36E-09 -5.04E-10 uCi/mL N/A N/A Uncertainty +/-3.41E-08 +/-3.57E-08 Manganese-54 4.27E-08 4.91LE-08 uCi/mL 17.3 (0% - 100%)

Uncertainty +/-2.26E-08 +/-2.43E-08 Mercury-203 U 4.87E-09 -1 .09E-09 uCi/mL N/A N/A Uncertainty +/-1.28E-08 +/-1.46E-08 Neodymium- 147 U 1.49E-07 -1 .25E-07 uCi/mL N/A N/A Uncertainty +/-1 .25E-07 +/-1.38E-07 Neptunium-239 U 1.06E-09 -5.80E-08 uCi/mL N/A N/A Uncertainty +/-8.64E-08 +/-1 .04E-07 Niobium-94 U -2.09E-09 -9.04E-09 uCi/mL N/A N/A Uncertainty +/-1 .38E-08 +/-1.71E-08 Page 39 of 48

GEL LABORATORIES LLC - www.gel.com 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 QC Summary Workorder: 385542 Page 4 of 12 Workorder: 385542 Page 4of 12 Pormnnmi NOM Ramnle 011al AC Units RPD% REC0 / Range Anlst Date Time Rad Gamma Spec Batch 1523381 Niobium-95 U 5.93E-10 U 5.35E-09 uCi/mL N/A N/A Uncertainty +/-1 .41E-08 +/-1 .77E-08 Potassium-40 U 2.11E-08 U -1.20E-07 uCi/mL N/A N/A MJH1 11/16/15 08:04 Uncertainty +/-1.89E-07 +/-1.57E3-07 Promethium- 144 U 9.75E-09 U 2.20E-08 uCi/mL N/A N/A Uncertainty +/-1 .39E-08 +1-1.63E3-08 Promethium- 146 U -6.55E-10 U 4.63E-09 uCi/mL N/A N/A Uncertainty +/-1.70E-08 +/-2.41E3-08 Radium-228 U -2.06E-08 U 9.45E-08 uCi/mL N/A N/A Uncertainty +/-7.42E-08 +/-I .04E-07 Ruthenium-106 U -1.72E-08 U 5.52E-08 uCi/mL N/A N/A Uncertainty +/-1 .27E-07 +/-1 .41E-07 Silver-I110i U 7.53E-09 U 1.37E3-08 uCi/mL N/A N/A Uncertainty +/-1.56E3-08 +-1--i.80E-08 Sodium-22 U 1.48E-08 U 1.20E-10 uCi/mL N/A N/A Uncertainty +/-1. 19E-08 +/-1.40E3-08 Thallium-208 U 2.43E-09 U 1.61E-09 uCi/mL N/A N/A Uncertainty +/-2.92E-08 +1-1.90E3-08 Thorium-230 U -1.32E-06 U 8.65E-07 uCi/mL N/A N/A Uncertainty +/-2.58E-06 +/-3.42E3-06 Thorium-234 U -3.63E-07 U 2.09E3-07 uCi/mE N/A N/A Uncertainty +/-3.51lE-07 +/-4.76E3-07 Tin-I113 U -5.62E-09 U 7.00E-09 uCi/mL N/A N/A Uncertainty +-1--I.60E3-08 +/-2.33E3-08 Uranium-235 U -9.03E3-08 U 7.65E3-08 uCi/mL N/A N/A Uncertainty +/-7.99E3-08 +/-1.04E3-07 Uraniurn-238 U -3.63E3-07 U 2.09E-07 uCi/mL N/A N/A Uncertainty +/-3.51E-07 +/-4.76E-07 Yttrium-88 U -4.19E-09 U 3.29E3-09 uCi/mL N/A N/A Uncertainty +/-1 .07E3-08 +/-1.05E3-08 Zinc-65 2.35E3-07 1.68E-07 uCi/mL 4.37 (0% - 100%)

Uncertainty +/-5. 15E-08 +/-7.82E3-08 Zirconium-95 U 2.30E3-08 U -6.68E-10 uCi/mL N/A N/A Uncertainty +/-2.65E-08 +/-2.98E3-08 QC1203433637 LCS Americium-241 0.000288 0.000295 uCi/mE 11/16/15 06:54 102 (75%-125%)

Uncertainty +/-5.50E3-06 Actinium-228 U -3.95E-07 uCi/mL Uncertainty +/-1.99E3-06 Antimony- 124 U -1.71E3-07 uCi/mL Uncertainty +/-3.28E3-07 Antimony- 125 U 1.71E3-06 uCi/mL Uncertainty +/-1 .4913-06 Barium-I133 U -2.5613-07 uCi/mL Uncertainty Page 40 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Page 5 of 12 Workorder: 38*.8542 Parmname NOM Samnle Oual OC Units RPD% REC% Range Artist Date Time Rad Gamma Spec Batch 1523:381

+/-5.20E-07 Barium-140 U -8.38E-07 uCi/mL MJH1 11/16/15 06:54

+/-1 .43E-06 Uncertainty Beryllium-7 U -11.54E-07 uCi/mL Uncertainty +/-3.61E-06 Bismuth-212 U -9.65E-07 uCi/miL Uncertainty +/-4.68E-06 Bismuth-214 U 7.72E-08 uCi/mL Uncertainty +/-7.44E-07 Cerium-139 U 1.50E-08 uCi/mL Uncertainty +/-2.67E-07 Cerium- 14 1 U 1.96E-07 uCi/mL Uncertainty +/-4.94E-07 Cerium- 144 U 8.70E-07 uCi/mL Uncertainty +/-1.91E-06 Cesium-I134 U i1.22E-07 uCi/mL Uncertainty +/-4.47E-07 Cesium-136 U 4.76E-07 uCi/mL Uncertainty +/-7.01E-07 Cesium-i137 9.91E-05 0.000104 uCi/mL 105 (75%-125%)

Uncertainty +/-2.09E-06 Chromium-51 U 1.98E-06 uCi/mL Uncertainty +/-3.51E-06 Cobalt-56 U 6.80E-08 uCi/mL Uncertainty +/-4.53E-07 Cobalt-57 U 3.39E-07 uCi/mL Uncertainty +/-2.47E-07 Cobalt-58 U 1.81IE-07 uCi/mnL Uncertainty +/-4.1 9E-07 Cobalt-60 7.80E-05 8.02E-05 uCi/mL 103 (75%-125%)

Uncertainty +/-2. 15E-06 Europium- 152 U 2.08E-07 uCi/mL Uncertainty +/-1.18E-06 Europium-i154 U -5.43E-07 uCi/nmL Uncertainty +/-6.34E-07 Europium- 155 U -2.52E-07 uCi/miL Uncertainty +/-9.64E-07 Iridium- 192 U -5.90E-09 uCi/mL Uncertainty +/-4.09E-07 Iron-59 U 5.36E-07 uCi/miL Uncertainty +/--9.41E-07 Lead-210 0.00346 uCi/mL Uncertainty +/-8. 16E-05 Page 41 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com Qc Summary Workorder: 385542 Page 6 of 12 Parmname NOM Samnle fluai OC Units RPD%/ REC%/ Range Anlst Date Time Rad Gamma Spec Batch 1523381 Lead-212 U 3.48E-07 uCi/mL

+/-6.22E-07 Uncertainty Lead-2 14 U 2.46E-07 uGi/mL MJH1 11/16/15 06:54 Uncertainty +/-8.79E-07 Manganese-54 U -3.32E-07 uCi/mE Uncertainty +/-4.37E-07 Mercury-203 U -6.82E-08 uCi/mL Uncertainty +/-3.57E-07 Neodymium- 147 U 9.15E-07 uCi/mL Uncertainty +/-3.09E-06 Neptunium-239 U -2.67E-06 uCi/mL Uncertainty +/-2.53E-06 Niobium-94 U 6.99E-08 uCi/mL Uncertainty +/-3.35E-07 Niobium-95 U -5.90E-08 uCi/mL Uncertainty +/-3.80E-07 Potassium-40 U 6.51E-07 uCi/mL Uncertainty +/-1 .58E-06 Promethium- 144 U -1 .08E-07 uCi/mL Uncertainty +/-4.01E-07 Promethium- 146 U 1.62E-07 uCi/mL Uncertainty +/-6.07E-07 Radium-228 U -3.95E-07 uCi/mE Uncertainty +/-1.99E-06 Ruthenium- 106 U -2.01E-06 uCi/mL Uncertainty +/-3.45E-06 Silver-il10m 5.28E-06 uCi/mL Uncertainty +/-6.19E-07 Sodium-22 U -2.17E-07 uCi/mL Uncertainty +/-2.35E-07 Thallium-208 U -1.53E-07 uCi/mIL Uncertainty +/-3.71E-07 Thorium-230 U 2.86E-06 uCi/mL Uncertainty +/-9.46E-05 Thorium-234 U -2.86E-06 uCi/mL Uncertainty +/-1 .23E-05 Tin-Il13 U 1.98E-07 uCi/mL Uncertainty +/--5.35E-07 Uranium-235 U -4.67E-07 uCi/mL Uncertainty +/-1 .87E-06 Uranium-238 U -2.86E-06 uCi/mL Uncertainty +/-1.23E-05 Yttrium-88 U -7.52E-08 uCi/mL Uncertainty +/--1.63E-07 Page 42 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel~com Qc Summary Workorder: 385542 Page 7 of 12 Parmname NOM Sample Qual QC Units RPD% REC% Range Anist Date Time Rad Gamma Spec Batch 1523381 Zinc-65 1.15E-07 uCi/mL

+/-1.01E-06 Uncertainty Zirconium-95 -4.51lE-08 uCi/mL MJH1 11/16/15 06:54 Uncertainty +/-6.72E-07 QC1203433635 MB Actinium-228 -5.28E-08 uCi/mE 11/16/15 07:06 Uncertainty +/-1.18E-07 Antimony- 124 -1.16E-08 uCi/mL Uncertainty +/-7.13E-08 Antimony- 125 -6.24E-08 uCi/mL Uncertainty +/-7. 15E-08 Barium- 133 -1.68E-08 uCi/mL Uncertainty +/-3.07E-08 Barium-140 3.44E-09 uCi/mL Uncertainty +/-8.99E-08 Beryllium-7 6.71LE-08 uCi/mL Uncertainty +-1--I.97E-07 Bismuth-212 -1 .68E-07 uCi/mL Uncertainty +/-2.32E-07 Bismuth-214 -2.37E-08 uCi/mL Uncertainty +/-6.06E-08 Cerium- 13 9 -1.33E-09 uCi/mL Uncertainty +/-1.58E-08 Cerium-141 5.94E-09 uCi/mL Uncertainty +/-2.71E-08 Cerium-144 -3.97E-08 uCi/mL Uncertainty +/-1.14E-07 Cesium-i134 -4.42E-09 uCi/mL Uncertainty +/-3.07E-08 Cesium- 136 -1 .86E-08 uCi/mL Uncertainty +/-3.65E-08 Cesium- 137 4.04E-09 uCi/mL Uncertainty +/-2.81E-08 Chromium-5 1 9.82E-08 uCi/mL Uncertainty +/-1.78E-07 Cobalt-56 -3.35E-08 uCi/mL Uncertainty +/-3.11lE-08 Cobalt-57 -6.49E-09 uCi/mL Uncertainty +/-1.48E-08 Cobalt-58 -1 .03E-08 uCi/mL Uncertainty +/-2.08E-08 Cobalt-60 8.96E-09 uCi/mL Uncertainty +/-2.31lE-08 Europium-152 1.47E-08 uCi/mL Uncertainty Page 43 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www. gel corn QC Summary Workorder: 385542 Page 8 of 12 Parmname NOM Sample Qua QC Units RPD% REC% Range Anist Date Time Rad Gamma Spec Batch 1523381

+/-7.28E-08 Europium-154 U -4.21E-08 uCi/mL MJIH1 11/16/15 07:06*

+/-8.63E-08 Uncertainty Europium- 155 U 4.22E-09 uCi/mL Uncertainty +/-5.50E-08 Iridium-i192 U 8.27E-09 uCi/mL Uncertainty +/-2.1 8E-08 Iron-59 U -1.31E-08 uCi/mL Uncertainty +/-5.21E-08 Lead-210 U 6.81E-06 uCi/mL Uncertainty +/-8 .43E-06 Lead-212 U 3.95E-08 uCi/mi Uncertainty +/-4.59E-08 Lead-214 U -3.06E-08 uCi/mL Uncertainty +/-5.68E-08 Manganese-54 U -2.30E-08 uCi/mL Uncertainty +/-2.66E-08 Mercury-203 U 1.43E-08 uCi/mL Unetit +/-2.08E-08 Neodymium- 147 Uncertainty U -5.03E-08 uCi/mL

+/-1 .71E-07 Neptunium-239 Uncertainty U -8.21E-08 uCilimL

+/-1 .92E-07 Niobium-94 Uncertainty U -9.86E-09 uCi/mL

+/-2.49E-08 Niobium-95 Uncertainty U -1.58E-08 uCi/mL

+/-2.55E-08 Potassium-40 Uncertainty U -1.41E-07 uCi/mL

+/-3.25E-07 Promethium-144 Uncertainty U -7.78E-09 uCi/mL

+/-2.63E-08 Promethium-146 Uncertainty U -1.81E-09 uCi/mL

+/-2.69E-08 Radium-228 Uncertainty U -5.28E-08 uCi/mL

+/-1.18E-07 Ruthenium- 106 Uncertainty U 6.24E-08 uCi/mL

+/-2.41E-07 Silver-I110m Uncertainty U -5.46E-09 uCi/mi

+/-2.21E-08 Sodium-22 Uncertainty U -1.48E-08 uCi/mL

+/-3.02E-08 Thallium-208 Uncertainty U -1.09E-08 uCi/mL

+/-2.36E-08 Page 44 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com Oc Summary Workorder: 385542 Page 9 of 12 Parmname NOM Samnie Oual OC Units RPD% REC% Ranee Anlst Date Time Rad Gamma Spec Batch 1523381 Thorium-230 U -3.75E-06 uCi/mL Uncertainty +/-7.23E-06 Thorium-234 U -3.75E-07 uCi/mL MJH1 11/16/15 07:06 Uncertainty +/-1.1 5E-06 Tin-Il13 U 6.42E-09 uCi/mL Uncertainty +/-2.83E-08 Uranium-235 U -1. 12E-07 uCi/mL Uncertainty +/-1.27E-07 Uraniumi-238 U -3.75E-07 uCi/rnL Uncertainty +/-1.15E-06 Yttrium-88 U -6.01lE-10 uCi/mL Uncertainty +/-3.43E-08 Zine-65 U -1 .38E-08 uCi/mL Uncertainty +/-6.24E-08 Zirconium-95 U -4.42E-08 uCi/mL Uncertainty +/-4.27E-08 Batch 1524875-QC1203437408 385542001 DUP Iodine- 129 U -1.84E-08 U -7.15E-08 uCi/mnL N/A N/A MJHI 11/25/15 12:06 Uncertainty +/-1 .27E-07 +/-1 .39E-07 QC1203437410 LCS Iodine-129 8.32E-06 7.93E-06 uCi/mL 11/25/15 13:31 95.2 (75%-125%)

Uncertainty +/-6.76E-07 QC12O3437407 MB Iodine-129 U 4.56E-08 uCi/mL 11/25/15 11:36 Uncertainty +/-7.28E-08 QC12034374O9 385542001 MS Iodine-129 8.32E-06 U -1.84E-08 8.42E-06 uCi/mL 11/25/15 12:54 101 (75%-125%)

Uncertainty +/-1.27E-07 +/-1.13E-06 Batch 1526787 QC1203442169 385542001 DUP Nickel-59 U -3.65E-05 U -3.28E-06 uCi/mL N/A N/A TYJ1 12/01/15 05:58 Uncertainty +/-5.81E-05 +/-4.71E-05 QC1203442170 LCS Nickel-59 0.00209 0.002 19 12/01/15 06:40 uCi/mL 105 (75%-125%)

Uncertainty +/-/-0.000233 SQC1203442168 MB Nickel-59 U 2.68E-06 uCi/mL 11/30/15 18:11 Uncertainty +/-5.41E-05 Rad Liquid Scintillation Batch 1525458 QC1203438835 385542001 DUP Strontium-89 U 6.18E-05 U 9.74E-06 uCi/mL N/A N/AMYM1 12/01/15 13:13 Uncertainty +/-4.54E-05 +/-5.05E-05 Strontium-90 U -4.53E-06 U -4.84E-06 uCi/mL N/A N/A Uncertainty +/-2. 16E-05 +/-2.08E-05 Page 45 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.corn QC Summary Workorder: 385542 Page 10 of 12 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time Rad Liquid Scintillation Batch 1525458 QC1203438836 LCS Strontium-89 0.00796 0.0064 uCi/mL 80.5 (75%-125%) MYM1 12/01/15 13:31 Uncertainty +/-0.000 176 Strontium-90 0.00 108 0.00107 uCi/mL 98.5 (75%-125%)

Uncertainty +/-4.57E-05 QC1203438834 MB Strontium-89 U 4.72E-05 uCi/mL 12/01/15 12:55 Uncertainty +/-3.83E-05 Strontium-90 U -7.30E-06 uCi/mL Uncertainty +/-2.36E-05 Batch 1525543-QC1203439051 385542001 DUP Iron-55 U 2.49E-06 U 5.57E-05 uCi/mL N/A N/A TYJ1 12/02/15 00:51 Uncertainty +/-5.54E-05 +/-6.1 6E-05 QC1203439052 LCS Iron-55 0.00 148 0.00159 uCi/mL 107 (75%-125%) 12/02/15 01:07 Uncertainty +/-0.000126 QC1203439050 MB Iron-55 U 3.32E-05 uCi/mL 12/02/15 00:34 Uncertainty +/-5.55E-05 Batch 1525545 QC1203439054 385542001 DUP Nickel-63 U 6.46E-06 U 3.80E-06 uCi/mL N/A N/A AFA 12/01/15 11:55 Uncertainty +/-2.85E-05 +/-2.87E-05 QC1203439055 LCS Nickel-63 0.00 136 0.00135 uCi/mL 99.5 (75%-125%) 12/01/15 12:11 Uncertainty +/-6.90E-05 QC1203439053 MB Nickel-63 U 1.34E-05 uCi/mL 12/01/15 11:39 Uncertainty +/-2.85E-05 Batch 1525546 QC1203439057 385542001 DUP Technetium-99 U -2.82E-05 U -2.29E-05 uCi/mE N/A N/AMYM1 11/29/15 17:17 Uncertainty +/-2.71E-05 +/-2.89E-05 QC1203439058 LCS Technetium-99 0.000861 0.000729 uCi/mL 84.7 (75%-125%) 11/29/15 17:34 Uncertainty +/-5.49E-05 QC1203439056 MB Technetium-99 U 2.50E-06 uCi/mL 11/29/15 17:01 Uncertainty +/-3. 14E-05 Batch 1525547-QC1203439060 385542001 DUP Tritium J 0.00187 J 0.00 186 uCi/mL 0.735 (0%-20%) TXJ1 12/04/15 07:55 Uncertainty +/-0.00027 1 +/-0.000272 QC1203439062 LCS Tritium 0.00 12 0.00116 uCi/mL 96.3 (75%-125%) 12/04/15 08:28 Uncertainty +/-0.000227 Page 46 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 -www.gel.com QC Summary Workorder: 385542 Page 11 of 12 Parmname NOM Sample Qual QC Units RPD% REC% Range Anist Date Time Rad Liquid Scintillation Batch 1525547 QC1203439059 MB Tritium 0.000248 uCi/mL TXJ1 12/04/15 07:39 Uncertainty +/-0.000151 QC1203439061 385542001 MS Tritium 0.00121 J 0.00187 J 0.00313 uCi/mL 104 (75%-125%) 12/04/15 08:12 Uncertainty +/-0.00027 1 +/-0.00033 5 Batch 1525548 QC1203439064 385542001 DUP Carbon-14 UJ -2.12E-06 UJ -1.84E-05 uCi/mLh N/A N/A TXJ1 12/05/15 06:29 Uncertainty +/-l1.85E-05 +/-1.76E-05 Qc1203439066 LCS Carbon-14 0.000757 0.000744 uCi/mL 98.2 (75%-I125%) 12/05/15 07:01 Uncertainty +/-3.99E-05 QC1203439063 MB Carbon-14 U -8.21E-06 uCi/mL. 12/05/15 06:12 Uncertainty +/-1.82E-05 QC1203439065 385542001 MS Carbon-14 0.000757 UJ -2.12E-06 J 0.000748 uCi/mL 98.8 (75%-125%) 12/05/15 06:45 Uncertainty +/-1.85E-05 +/-4.00E-05 Notes:

Counting Uncertainty is calculated at the 95% confidence level (1.96-sigma).

The Qualifiers in this report are defined as follows:

- Analyte is a Tracer compound

< Result is less than value reported

> Result is greater than value reported BD Results are either below the MDC or tracer recovery is low FA Failed analysis.

H Analytical holding time was exceeded J Value is estimated K Analyte present. Reported value may be biased high. Actual value is expected to be lower.

L Analyte present. Reported value may be biased low. Actual value is expected to be higher.

M M if above MDC and less than LLD M REMP Result > MDC/CL and < RDL N/A RPD or %Recovery limits do not apply.

Nl1 See case narrative ND Analyte concentration is not detected above the detection limit NJ Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Q One or more quality control criteria have not been met. Refer to the applicable narrative or DER.

R Sample results are rejected U Analyte was analyzed for, but not detected above the MDL, MDA, or LOD.

Page 47 of 48

GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 385542Pae2of2 Parmname NOM Sample Qual OC Units RPD% REC% Range Antist Date Time-UI Gamma Spectroscopy--Uncertain identification UJ Gamma Spectroscopy--Uncertain identification UL Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.

X Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Y Other specific qualifiers were required to properly define the results. Consult case narrative.

A RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry.

h Preparation or preservation holding time was exceeded N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike cone, by a factor of 4 or more or %RPD not applicable.

A The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/-the RI is used to evaluate the DUJP result.

Indicates that a Quality Control parameter was not within specifications.

For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.

Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the QC Summary.

Page 48 of 48