HBL-11-009, Submittal of Revised Annual Radiological Environmental Monitoring Report for 2010

Submittal of Revised Annual Radiological Environmental Monitoring Report for 2010

ML11144A180
Person / Time
Site:	Humboldt Bay
Issue date:	05/18/2011
From:	Roller P Pacific Gas & Electric Co
To:	Document Control Desk, NRC/FSME
References
HBL-11-009
Download: ML11144A180 (39)

Text

Pacific Gas and Electric Company 1000 King Salmon Avenue Humboldt Bay PowerPlant Eureka, CA 95503 PaulJ. Roller (707) 444-0819 Directorand PlantManager Humboldt Bay Nuclear May 18, 2011 PG&E Letter HBL-1 1-009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-133 License No. DPR-7 Humboldt Bay Power Plant Unit 3 Revised Annual Radiological Environmental Monitoring Report for 2010

Dear Commissioners and Staff:

On April 29, 2011, Pacific Gas and Electric Company (PG&E) submitted letter HBL-1 1-005 containing the Humboldt Bay Power Plant Unit 3, "Annual Radiological Environmental Monitoring Report" for 2010 as required by Section 4.1 of the SAFSTOR/Decommissioning Offsite Dose Calculation Manual (ODCM). The HBL-1 1-005 cover letter incorrectly referred to 10 CFR 20, 10 CFR 50 and 10 CFR 72.44.

In addition, Table C-2, Note 2 on page 18 of the enclosure to HBL-1 1-005 was inaccurate. Note 2 stated that four thermoluminescent dosimeters (TLDs) were added around the Independent Spent Fuel Storage Installation (ISFSI) in the second quarter of 2010. In reality, the four TLDs replaced existing TLDs that had been installed around the ISFSI since 2009.

As a result of the issues stated above, PG&E is submitting the enclosed revised Humboldt Bay Power Plant Unit 3, "Annual Radiological Environmental Monitoring Report" for 2010. Footnote 2 on Table C-2 has been clarified and is indicated with a revision bar in the margin. The enclosed report replaces the previously submitted report in its entirety.

There are no regulatory commitments made in this letter.

Document Control Desk PG&E Letter HBL-1 1-009 May 18, 2011 Page 2 If you wish to discuss the information in the enclosed report, please contact John Newey at (707) 441-2641, or David Sokolsky at (707) 444-0801.

Sincerely, Paul J. Roller Directorand Plant ManagerHumboldt Bay Nuclear cc/enc: Elmo E. Collins, Jr., NRC Region IV John B. Hickman, NRC Project Manager HBPP Humboldt Distribution Enclosure

Enclosure PG&E Letter HBL-1 1-009 HUMBOLDT BAY POWER PLANT UNIT 3 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT (REVISED)

JANUARY 1 THROUGH DECEMBER 31, 2010

TABLE OF CONTENTS A. RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM............................ 1

1. Program Description ............................................................................................ 1

2. Monitoring Requirem ents ................................................................................ 2

a. Offsite Environmental Monitoring - Direct Radiation ................................ 2

b. O nsite Environm ental Monitoring ............................................................. 2

c. Other Monitoring ......................................................................................... 3

3. Interlaboratory Com parison Program .............................................................. 3

4. NEI G roundwater Protection Initiative ................................................... 4 B. TRENDS, BASELINE COMPARISONS AND INTERPRETATIONS .................... 4

1. General Com m ents ......................................................................................... 4

2. Direct Radiation Pathway ................................................................................ 5

3. Airborne Pathway .......................................................................................... 6

4. W aterborne Pathway ...................................................................................... 6

a. Surface W ater ........................................................................................... 6

b. G roundwater ............................................................................................. 6

5. Ingestion Pathway .......................................................................................... 7

6. Terrestrial Pathway ......................................................................................... 7 C. MO NITO RING RESULTS .................................................................................... 7

1. Annual Sum m ary ............................................................................................. 7

2. Direct Radiation Pathway ................................................................................ 8

3. Airborne Pathway .......................................................................................... 8

4. W aterborne Pathway ...................................................................................... 8

a. Surface W ater ........................................................................................... 8

-i-

TABLE OF CONTENTS (Continued)

b. G ro undw ate r ............................................................................................. ..9

5. Ingestion Pathway ....................................................................................... 10

6. Terrestrial Pathway ......................................................................................... 10

7. NEI Groundwater Protection Initiative Voluntary Reporting Results ............ 10

8. Errata For Previous Report ........................................................................... 11

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LIST OF TABLES Table Page A-I HBPP Radiological Environmental Monitoring Program ................................... 12 A-2 Distances And Directions to HBPP Offsite TLD Locations ................ 13 A-3 GEL Participation - Interlaboratory Cross-Check Program Data ..................... 14 C-1 Radiological Environmental Monitoring Program Annual Report Summary ....... 16 C-2 Onsite Environmental TLD Stations ................................................................ 18 C-3 Offsite Environmental TLD Stations ................................................................ 19 C-4 Discharge Canal Sample Results ..................................................................... 20 C-5 Groundwater Monitoring Well Results .............................................................. 22 C-6 Caisson Sump Monitoring Results .......................... 24....................

24 C-7 French Drain Monitoring Results ......................................................... 25 C-8 Additional Monitoring Results ............................................................. 26 LIST OF FIGURES Figure Page A-1 HBPP Onsite TLD Locations .......................................................................... 28 A-2 HBPP Onsite Monitoring Well Locations ............................ 29 A-3 HBPP Offsite TLD Locations ........................................................................... 30 B-1 Offsite Environmental Radiation Level Trends ................................................ 32 B-2 Onsite Environmental Radiation Level Trends ................................................ 33

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PACIFIC GAS AND ELECTRIC COMPANY ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT FOR HUMBOLDT BAY POWER PLANT UNIT 3, COVERING THE PERIOD JANUARY 1 THROUGH DECEMBER 31, 2010 This annual report is required by 10 CFR Part 20, 10 CFR Part 50, and 10 CFR Part 72.44(d), and by Section 4.1 of the SAFSTOR Offsite Dose Calculation Manual (ODCM). This report provides information about the Radiological Environmental Monitoring Program (REMP) for the period of January 1 through December 31, 2010, in a manner consistent with the objectives outlined in the ODCM, and in 10CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The report has three sections. Section A provides a summary description of the REMP, including maps of sampling locations. Section A also provides the results of licensee laboratory participation in the Interlaboratory Comparison Program.

Section B provides summaries, interpretations, and analyses of trends of the results of the REMP for the reporting period. The material provided is consistent with the objectives outlined in the ODCM, and in 10CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C. Section B also includes a comparison with the baseline environmental conditions at the beginning of SAFSTOR.

Section C provides the results of analyses of radiological environmental samples and of environmental radiation measurements taken during the period pursuant to the quality related locations specified in the table and figures in the ODCM, presented as both summarized and tabulated results of these analyses and measurements. The summarized results are formatted for applicable reporting requirements of the NRC Radiological Assessment Branch's Branch Technical Position.

A. RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

1. Program Description The NRC Radiological Assessment Branch issued a Branch Technical Position (BTP) on environmental monitoring in March 1978. Revision 1 of the BTP was issued as Generic Letter 79-65, "Radiological Environmental Monitoring Program Requirements - Enclosing Branch Technical Position," Revision 1, dated November 27, 1979, and sets forth an example of an acceptable minimum radiological monitoring program. The specified environmental monitoring program provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of individuals resulting from plant effluents.

As discussed below, many of the exposure pathway sample requirements specified in the BTP are not required for the HBPP REMP because of the baseline conditions established in the SAFSTOR Decommissioning Plan (now identified as the Defueled Safety Analysis Report (DSAR)) and the Environmental Report.

In addition, the nuclides specified for analysis by the BTP have been revised to reflect the available source term at a nuclear power plant that has been shut down since July 2, 1976.

The REMP consists of the collection and analysis of both onsite and offsite environmental samples. HBPP personnel perform sample collection and General Engineering Laboratories (GEL) personnel perform sample analysis.

The Diablo Canyon Power Plant (DCPP) dosimetry group performs analysis of thermoluminescent dosimeters (TLDs) used for monitoring direct radiation. A summary of the REMP is provided as Table A-i, "HBPP Radiological Environmental Monitoring Program."

Prior to 2006, HBPP utilized an "in-house" environmental lab for sample analysis. That environmental lab was Technical and Ecological Services (TES) located in San Ramon, California. At the beginning of 2006, HBPP REMP changed its environmental lab to GEL located in Charleston, South Carolina.

Sample collection for the REMP is performed at the sampling stations defined by Table A-2, Distances and Directions to HBPP Offsite TLD Locations; Figure A-I, HBPP Onsite TLD Locations; Figure A-2, HBPP Onsite Monitoring Well Locations; and the discharge canal shown in Figure A-2, HBPP Onsite Monitoring Well Locations.

2. Monitoring Requirements

a. Offsite Environmental Monitoring - Direct Radiation The SAFSTOR ODCM requires four offsite environmental monitoring stations equipped with TLDs to monitor gamma exposure. The TLDs are to be exchanged quarterly. The stations selected to satisfy this requirement are Stations 1, 2, 14 and 25 as described in Table A-2. These stations are considered to be the four control locations for the direct radiation dose pathway.

b. Onsite Environmental Monitoring (1) Direct Radiation The SAFSTOR ODCM requires sixteen onsite environmental monitoring stations, equipped with TLDs to monitor gamma exposure.

The TLDs are to be exchanged quarterly. The stations selected to satisfy this requirement are Stations T1 through T16, shown on Figure A-I. Four additional TLDs were added around the ISFSI in the second quarter. These are Stations T18 through T21.

Each quarter the exposures from 20 stations are determined, which results in the 80 analyses for a full year. Each TLD station has three TLDs, each containing a number of phosphors (normally three).

The phosphor exposures for each TLD are averaged and then the three TLDs per station are averaged to provide the quarterly exposure for the station.

(2) Surface Water The SAFSTOR ODCM requires that the discharge canal effluent be monitored by gamma isotopic analysis and by tritium analysis.

Composite samples are normally collected weekly from a continuous sampler, with dip (grab) samples collected if the sampler is inoperable.

(3) Groundwater The SAFSTOR ODCM requires that five groundwater wells be monitored by gamma isotopic analysis and by tritium analysis.

Samples are to be collected quarterly. The monitoring wells selected to satisfy this requirement are identified as MW-1, MW-2, MW-4, MW-6, and MW-1 1, shown on Figure A-2.

c. Other Monitoring Airborne, ingestion and terrestrial pathway monitoring is not required by the ODCM. The Environmental Report, submitted to the NRC as Attachment 6 to the SAFSTOR license amendment request, established baseline conditions for these pathways. In accordance with the NRC-approved SAFSTOR Decommissioning Plan, (now identified as the DSAR), these baseline conditions will only need to be reestablished prior to final decommissioning if a significant release occurs during SAFSTOR. The Environmental Report also contains a description of the demography and human activities within the environs surrounding the site.

As a matter of plant policy, groundwater leakage into the reactor caisson is routinely sampled, approximately monthly, and analyzed for tritium and gamma emitters, in order to develop a historical record of this parameter for the remainder of SAFSTOR. The results are included in this report, but are not considered part of the SAFSTOR REMP.

3. Interlaboratory Comparison Program PG&E's contract laboratory, GEL, has analyzed evaluation samples provided by a commercial supplier to satisfy the requirement to participate in an Interlaboratory Cross-Check Program. This participation includes sufficient determinations (sample medium and radionuclide combination) to ensure independent checks on the precision and accuracy of the measurements of radioactive materials in the REMP samples. Table A-3 presents the participation in this Interlaboratory Cross-Check Program for samples analyzed in the report period that represent analyses performed for HBPP. The agreement criteria are consistent with the guidance for "Confirmatory Measurements" in NRC Inspection Procedure 83502.3, "Radiological Environment Monitoring Program and Radioactive Material Control Program."

GEL analyzed 3 samples for 30 parameters that are representative of analyses performed for HBPP during 2010. All results met the acceptance criteria. No adverse trends in quality were noted in the crosscheck program results.

GEL also participated in various proficiency testing programs for federal and state agencies, including the DOE Mixed Analyte Performance Evaluation Program (MAPEP). The data on appropriate media samples is also included.

One "Disagreement" was noted.

4. NEI Groundwater Protection Initiative Groundwater monitoring data is collected in accordance with the Nuclear Energy Institute (NEI) Groundwater Protection Initiative. The results show that there are detectable concentrations of radionuclides in the groundwater within the HBPP restricted area. These are believed to be the results of historical spills at the site.

The impact of these detectable concentrations is negligible, as the groundwater is saline and is not used now or likely to be used in the future for either direct consumption or for agricultural purposes.

To further characterize any groundwater issues, twelve additional wells are monitored as well as the five that are required to be monitored by the SAFSTOR REMP. The results of the analyses for the five required are in Table C-5. Additional wells are included in Table C-8, Additional Groundwater Monitoring Results.

B. TRENDS, BASELINE COMPARISONS AND INTERPRETATIONS Section B provides interpretations of results, and analyses of trends of the results. The material provided is consistent with the objectives outlined in the ODCM, and in 10CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

Section B also includes a comparison with the baseline environmental conditions at the beginning of SAFSTOR.

1. General Comments The Environmental Report, submitted to the NRC as Attachment 6 to the SAFSTOR license amendment request, established baseline conditions for soil, biota and sediments. In accordance with the NRC approved SAFSTOR Decommissioning Plan (now identified as the DSAR), these baseline conditions will only need to be reestablished prior to final decommissioning if a significant release occurs during SAFSTOR. The results to date indicate no significant change from the baseline environmental conditions established in the Environmental Report.

The results, interpretations, and analysis of trends of the results, indicate that SAFSTOR activities have had no measurable radiological effect on the environment. Facility surveys for radiation and radioactive surface contamination are performed on both a scheduled basis and on an as-required basis. These surveys indicate that the radioactivity control barriers established for SAFSTOR continue to be effective.

As discussed below, the ODCM calculation model conservatively assumes that exposure pathways begin at the unrestricted area boundary. Since there have not been any changes in the location of the boundary, no survey for changes to the use of unrestricted areas was necessary.

2. Direct Radiation Pathway A plot of the radiation level trends for the four control locations is shown in Figure B-1, Offsite Environmental Radiation Level Trends. A plot of the radiation level trends for onsite stations is shown in Figure B-2, Onsite Environmental Radiation Level Trends. This plot includes the average dose for two groups of onsite stations, selected by their potential to be affected by radioactive waste handling activities.

The plots show that the offsite annual doses continue to be within the ranges that have been observed over the last ten years.

Figure B-2 also shows that dose measurement variations can be attributed to in-plant sources and low-level waste packaging and shipping activities.

However, allowing for the background change in the general environs, all measurements were comparable to the ranges observed at these locations since entering SAFSTOR, with the onsite station dose levels approximately within the range of dose levels shown by the offsite stations.

The ODCM calculation model for the direct radiation exposure pathway assumes an occupancy factor for the portion of the unrestricted area boundary that is closest to the radioactive waste handling area of the plant, which is the location of the highest potential exposure. The occupancy factor is 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> per year, based on regulatory guidance for shoreline recreation, even though the actual shoreline is farther from the boundary.

Since there have been no significant changes of the locations of the radioactive waste handling activities, boundary, or shoreline, no further survey for changes to the use of unrestricted areas is necessary.

The Independent Spent Fuel Storage Facility (ISFSI) was constructed in 2008 and spent fuel transfer from the spent fuel pool was completed in December 2008. As a result of this the dose rates at the fence line increased slightly. The ISFSI Final Safety Analysis Report (FSAR) assumes an occupancy factor of 2,080 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per year at the fence line.

Based on the 2080 hour0.0241 days <br />0.578 hours <br />0.00344 weeks <br />7.9144e-4 months <br /> occupancy factor the dose at the fence line would have been less than 0.1 mrem per year.

3. Airborne Pathway Airborne pathway monitoring is not required by the ODCM. The Environmental Report, submitted to the NRC as Attachment 6 to the SAFSTOR license amendment request, established baseline conditions for the airborne pathway. In accordance with the NRC-approved SAFSTOR Decommissioning Plan, (now identified as the DSAR), these baseline conditions will only need to be reestablished prior to final decommissioning if a significant release occurs during SAFSTOR. The ODCM calculation model for the airborne pathway assumes that the airborne exposure pathway (inhalation exposure) is at the unrestricted area boundary, which is the location of the highest potential exposure.

4. Waterborne Pathway

a. Surface Water None of the REMP samples indicated detectable levels of Tritium or gamma radioactivity. These sample results were typical of those observed since entering SAFSTOR.

The ODCM calculation model for the surface water waterborne pathway assumes that the waterborne exposure pathway (vertebrate and invertebrate food consumption) begins at the unrestricted area boundary, which is the location of the highest potential exposure.

The ODCM calculation model is based on the average concentration of the radioactivity released and diluted by the tidal flow of water in the outfall canal. For the purposes of comparing the sampling results with effluents, consider a conservatively estimated liquid waste batch of 7,000 gallons containing Tritium at 30,000 pico-Curies/liter, Cs-1 37 at 1,000 pico-Curies/liter, and Co-60 at 100 pico-Curies/liter. For a single batch release during a week-long canal composite sample, the tidal flow volume is approximately 7E6 gallons, so the diluted activity for Tritium, Cs-137 and Co-60 would be 30, 1.0, and 0.1 pico-Curies/liter, respectively. These concentrations are unlikely to be detected.

b. Groundwater None of the samples of the 5 SAFSTOR REMP required monitoring wells indicated detectable levels of tritium. For gamma radioactivity, these sample results were typical of those observed since entering SAFSTOR. Results for other parameters and samples were comparable to the ranges observed since entering SAFSTOR.

This report also contains information on gamma emitting radionuclides and tritium concentrations in the caisson sump and gamma emitting radionuclide concentrations for the Spent Fuel Pool (SFP) French drain. There is detectable radioactivity, due to plant operations, at these sample points. Both of these locations are believed to be contaminated as a result of groundwater intrusion into historically contaminated areas of concrete and fill material.

The ODCM does not provide a model for the groundwater waterborne pathway, as the groundwater is saline and is not used for either direct consumption or for agricultural purposes.

5. Ingestion Pathway Ingestion pathway monitoring is not required by the ODCM. The Environmental Report, submitted to the NRC as Attachment 6 to the SAFSTOR license amendment request, established baseline conditions for the ingestion pathway. In accordance with the NRC-approved SAFSTOR Decommissioning Plan, (now identified as the DSAR), these baseline conditions will only need to be reestablished prior to final decommissioning if a significant release occurs during SAFSTOR.

The ODCM calculation model for the airborne pathway assumes that the ingestion pathways (milk, meat and vegetable consumption) begin at the unrestricted area boundary, which is the location of the highest potential exposure, whether any dairy, farm, etc. is actually present.

6. Terrestrial Pathway Terrestrial pathway monitoring is not required by the ODCM. The Environmental Report, submitted to the NRC as Attachment 6 to the SAFSTOR license amendment request, established baseline conditions for the terrestrial pathway. In accordance with the NRC-approved SAFSTOR Decommissioning Plan, (now identified as the DSAR), these baseline conditions will only need to be reestablished prior to final decommissioning if a significant release occurs during SAFSTOR.

The ODCM calculation model for the terrestrial pathway conservatively assumes that the terrestrial exposure (direct radiation from airborne radioactivity deposition) is at the unrestricted area boundary, which is the location of the highest potential exposure.

C. MONITORING RESULTS

1. Annual Summary Results of the REMP sampling and analysis are summarized in Table C-1 in the format of the BTP Table 3. None of the REMP samples results exceeded the reporting levels for radioactivity concentration in environmental samples specified in HBPP ODCM Table 2-8.

All of the minimum detectable activities (MDAs) for analyses required by the SAFSTOR REMP were less than or equal to the lower limit of detection (LLD) criteria for radioactivity in environmental samples specified in Table C-1 of this report. Because alpha and beta radioactivity analyses of the saline ground water are less effective than Tritium and Gamma radioactivity analyses for monitoring potential spent fuel pool leakage, the ODCM does not currently require alpha and beta radioactivity analyses to be part of the SAFSTOR REMP.

2. Direct Radiation Pathway Monitoring of the direct radiation pathway is performed at 20 onsite locations near the facility fence line, and at 4 offsite (control) locations in the vicinity of the facility. Monitoring is performed with TLDs with multiple crystal elements. Three TLDs are installed at each station, and the set is exchanged quarterly. The reported result and its standard error are calculated from the measurements of multiple elements in the TLD triplet.

Results of the onsite and offsite monitoring are provided in Tables C-2 and C-3, respectively.

3. Airborne Pathway Airborne pathway monitoring is not required by the ODCM.

4. Waterborne Pathway

a. Surface Water Surface water sampling of the waterborne pathway is performed by sampling the discharge canal effluent. Sampling is normally performed by collecting a weekly sample from a discharge canal continuous composite sampler. If the composite sampler is found to be inoperable, dip samples from the discharge canal are taken. All samples during the reporting period were obtained from the continuous composite sampler.

Detailed results of the discharge canal monitoring are provided in Table C-4. None of the REMP samples indicated detectable levels of Tritium or gamma radioactivity at or above the MDA. The MDA for these analyses was at or below the LLD stated in Table C-1 of this report.

These sample results were typical of those observed since entering SAFSTOR. Since no activity was detected, a comparison with the baseline levels was not performed.

b. Groundwater Groundwater sampling of the waterborne pathway is performed by sampling five monitoring wells located to monitor for leakage from the spent fuel pool. Sampling of these monitoring wells is performed quarterly. Detailed results of groundwater monitoring are provided in Table C-5.

The tritium concentration for all of the wells listed in Tables C-5 and C-8 during 2010 was less than the MDA of approximately 300 pCi/liter.

The addition of the several more groundwater monitoring wells in the last-couple of years will help to further characterize groundwater issues.

All of the monitoring wells are inside the owner controlled area boundary and the groundwater is saline and is not used for direct consumption or for agricultural purposes. Therefore, there is no groundwater waterborne pathway for a member of the public. None of the other ODCM required REMP samples indicated detectable levels of tritium or gamma radioactivity.

Because alpha and beta radioactivity analyses of the saline ground water are less effective than tritium and gamma radioactivity analyses for monitoring potential spent fuel pool leakage, the ODCM does not currently require alpha and beta radioactivity analyses to be part of the SAFSTOR REMP. Nevertheless, alpha and beta radioactivity analyses are performed as a matter of plant policy, in order to maintain a historical record of this parameter for the remainder of SAFSTOR.

These results are included in Table C-5, but are not considered part of the SAFSTOR REMP.

All required sampling and analysis for the five monitoring wells of the waterborne pathway required during this reporting period was performed successfully.

Groundwater leakage into the reactor caisson is also routinely sampled, approximately monthly, and analyzed for gamma emitters and Tritium as a matter of plant policy, in order to develop a historical record of this parameter for the remainder of SAFSTOR. These results are included in Table C-6, but are not considered part of the SAFSTOR REMP.

The French Drain beneath the Spent Fuel Pool is also routinely sampled, approximately monthly, and analyzed for gamma emitters as a matter of plant policy, in order to develop a historical record of this parameter for the remainder of SAFSTOR. These results are included in Table C-7, but are not considered part of the SAFSTOR REMP.

As a response to the NEI groundwater initiative, additional analyses were performed on some groundwater samples. The results of these analyses are provided in Table C-8.

5. Ingestion Pathway Ingestion pathway monitoring is not required by the ODCM.

6. Terrestrial Pathway Terrestrial pathway monitoring is not required by the ODCM.

7. NEI Groundwater Protection Initiative Voluntary Reporting Results The NEI Groundwater Protection Initiative contains the following requirements:

OBJECTIVE 2.2 VOLUNTARY COMMUNICATION Make informal notification as soon as practicableto appropriate State/Local officials, with follow up notification to the NRC, as appropriate, regardingsignificantonsite leaks/spills into groundwaterand onsite or offsite water sample results exceeding the criteria in the REMP as described in the ODCM/ODAM.

HBPP Response to 2.2:

There were no reports or notifications required to be generated in 2010 for groundwater results exceeding reporting/notification levels or significant onsite leaks/spills.

OBJECTIVE 2.3 THIRTY-DAY REPORTS Submit a 30-day report to the NRC for any water sample result for onsite groundwaterthat is or may be used as a source of drinking water that exceeds the criteria in the licensee's existing REMP for 30-day reporting of offsite water sample results. Copies of 30-day reports for both onsite and offsite watersamples will also be provided to the appropriateState agency, and:

HBPP Response to 2.3:

There were no reports or notifications required to be generated in 2010 for groundwater results exceeding reporting/notification levels or significant onsite leaks/spills.

OBJECTIVE 2.4 ANNUAL REPORTING Document all on-site ground water sample results and a description of any significanton-site leaks/spills into groundwaterfor each calendaryear in the AREOR for REMP or the ARERR for the RETS as contained in the appropriatereportingprocedure, beginning with Calendaryear 2006..

HBPP Response to 2.4:

Onsite groundwater monitoring points are described and reported in this report as follows:

MW-01 (Monitoring Well 01), MW-02 (Monitoring Well 02), MW-04 (Monitoring Well 04), MW-06 (Monitoring Well 06), MW-1 1 (Monitoring Well 11), the Caisson Sump and the French Drain. A summary of the sample results are provided in Section C.

There were no significant onsite leaks/spills into groundwater in 2010.

Note: the term "significant" is defined by the NEI Initiative as greater than 100 gallons.

8. Errata for Previous Report There are no errata for previous reports.

TABLE A-1 HBPP RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Samples Sampling and Collection Type of Analysis And/Or Sample And Locations Frequency DIRECT RADIATION 20 onsite stations with TLDs TLDs exchanged quarterly Gamma exposure 4 offsite stations with TLDs TLDs exchanged quarterly Gamma exposure WATERBORNE Surface Water Discharge canal effluent Continuous sampler operation Gamma isotopic(a) and with sample collection weekly. Tritium analysis of Dip samples ifsampler weekly sample inoperable Groundwater 5 groundwater monitoring Quarterly Tritium and gamma wells isotopic(a) analysis (a)Gamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents from the facility.

TABLE A-2 DISTANCES AND DIRECTIONS TO HBPP OFFSITE TLD LOCATIONS Radial Radial Direction Distance By From Plant Station Name Sector Degrees (Miles)

King Salmon Picnic Area W 270 0.3 City of Fortuna Water Pollution SSE 158 9.4 Control Plant, 180 Dinsmore Drive, Fortuna South Bay School Parking Lot S 180 0.4 Irving Drive, Humboldt Hill SSE 175 1.3 TABLE A-3 GEL PARTICIPATION - INTERLABORATORY CROSS-CHECK PROGRAM DATA Table Notation: (a) All of the values shown are relative. Therefore, the units for total activity or concentration levels are not shown.

Sample/Analysis Radionuclide Quarter 2010 GEL Ref Value Evaluation Water/Gamma Ce-141 2nd 2.04E+02 2.04E+02 Agreement Co-58 2nd 2.19E+02 2.13E+02 Agreement Co-60 2nd 2.67E+02 2.58E+02 Agreement Cr-51 2nd 5.78E+02 5.54E+02 Agreement Cs-1 34 2nd 2.56E+02 2.55E+02 Agreement Cs-137 2nd 1.81E+02 1.81E+02 Agreement Fe-59 2nd 1.94E+02 1.79E+02 Agreement 1-131 2nd 1.OOE+02 9.61E+01 Agreement Mn-54 2nd 11.90E+02 1.79E+02 Agreement Zn-65 2nd 3.72E+02 3.48E+02 Agreement Water/Gamma Ce-141 2nd 2.78E+02 2.63E+02 Agreement Co-58 2nd 1.51 E+02 1.44E+02 Agreement Co-60 2nd 1.94E+02 1.85E+02 Agreement Cr-51 2nd 3.86E+02 3.64E+02 Agreement Cs-134 2nd 1.85E+02 1.79E+02 Agreement Cs-137 2nd 1.71E+02 1.59E+02 Agreement Fe-59 2nd 1.60E+02 1.38E+02 Agreement 1-131 2nd 8.12E+01 7.22E+01 Agreement Mn-54 2nd 2.30E+02 2.09E+02 Agreement Zn-65 2nd 2.97E+02 2.56E+02 Agreement Water/Gamma Ce-141 4th 1.74E+02 1.65E+02 Agreement Co-58 4th 9.63E+01 9.35E+01 Agreement Co-60 4th 2.34E+02 2.17E+02 Agreement Cr-51 4th 3.12E+02 2.97E+02 Agreement Cs-134 4th 1.22E+02 1.18E+02 Agreement Cs-137 4th 1.24E+02 1.20E+02 Agreement Fe-59 4th 1.48E+02 1.41 E+02 Agreement 1-131 4th 7.24E+01 6.44E+01 Agreement Mn-54 4th 1.70E+02 1.52E+02 Agreement Zn-65 4th 2.97E+02 2.59E+02 Agreement TABLE A-3 (Continued)

GEL PARTICIPATION - INTERLABORATORY CROSS-CHECK PROGRAM DATA Sample/Analysis Radionuclide Quarter 2010 GEL MAPEP Evaluation WaterNarious Am-241 3rd 1.0323 1.30 Agreement Cs-137 3rd 63.1 60.6 Agreement Mn-54 3rd 28.83 26.9 Agreement Co-57 3rd 29.2 28.3 Agreement Ni-63 3rd 57.7 59.9 Agreement Pu-238 3rd 1.213 1.93 Disagreement Pu-239/240 3rd 0.026 0.009 Agreement U-234/233 3rd 1.163 1.22 Agreement U-238 3rd 1.223 1.25 Agreement Zn-65 3rd 45.9 40.7 Agreement Water/Gross Alpha 3rd 0.559 0.676 Agreement Water/Gross Beta 3rd 13.110 3.09 Agreement TABLE C-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL REPORT

SUMMARY

Name of Facility Humboldt Bay Power Plant Unit 3 Docket No. 50-133; License No. DPR-7 Location of Facility Humboldt County, California Reporting Period January 1 - December 31, 2010 (County, State)

Type and All Indicator Location with Highest Annual Mean Control Total Lower Locations Locations Number of Medium or Number of Limit of Mean, Name, Mean, Mean, Nonroutine Pathway Sampled Analyses Detectiona (Fraction) Distance and (Fraction) (Fraction) Reported

[Unit of Measurement] Performed (LLD) & [Rankle b Direction & [Range] b ( rRanoe] b Measurements AIRBORNE Radioiodine and Not N/A N/A N/A N/A Not Required N/A Particulates Required DIRECT RADIATION

[mR/quarter] Direct 3 12.9 +/- 0.1 Station T19, 14.5 +/- 0.3 12.3 +/- 0.1 0 radiation (76/76) Figure B-1 (3/3) (16/16)

(76) [11.0- 15.0] [14.4- 14.6] [11.0- 14.4]

WATERBORNE Surface Water Gamma Co-60: 15 <MDA N/A N/A Not Required 0 (Discharge canal isotopic Cs-137:18 (0/52) effluent) (52) [N/A]

[pCi/I]

Tritium (52) ODCM: 3000 <MDA N/A N/A Not Required 0 Plant Policy: (0/52) 400 [N/A]

TAB. C-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL REPORT

SUMMARY

Type All Indicator Location with Highest Annual Control Medium or and Total Lower Locations Mean Locations Number of Pathway Sampled Number of Limit of Mean, Name, Mean, Mean, Nonroutine

[Unit of Analyses Detection" (Fraction) Distance and (Fraction) (Fraction) Reported Measurement] Performed (LLD) & [Rankle b Direction & [Range] b & [Range] b Measurements WATERBORNE Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137 Co-60 Cs-137 (continued)

Groundwater Gamma Co-60: 15 <MDA <MDA N/A N/A <MDA <MDA N/A N/A 0 (Monitoring wells) isotopic Cs-1 37:18 (0/20) (0/20) (0/4) (0/4)

[pCi/I] (20) [N/A] [N/A] [N/A] [N/A]

Tritium ODCM:2000 <MDA N/A <MDA N/A 0 (20) Plant Policy: (0/20) (0/4) 400 [N/A] [N/A]

Dbrinklin-g Wvat-er o-t- Re-q-u-i-red-

--N-- -N/A-- - - - -N/-A - - - - - - --N-/A - - - - - --N-/A - - - - - --N-o-t- Re-q-u-i-re d- - --N-/A - - - - -

Not Required N/A N/A N/A N/A Not Required N/A Algae Not Required N/A N/A N/A N/A Not Required N/A INGESTION Milk Not Required N/A N/A N/A N/A Not Required N/A Fish and Not Required N/A N/A N/A N/A Not Required N/A invertebrates TERRESTRIAL Soil Not Required N/A N/A N/A N/A Not Required N/A a The LLD is defined as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95 percent probability with only 5 percent probability of falsely concluding that a blank observation represents a "real" signal.

LLD is defined as the a priori (before the fact) lower limit of detection (as pCi per unit mass or volume) representing the capability of a measurement system and not as the a posteriori (after the fact) limit for a particular measurement. (Current literature defines the LLD as the detection capability for the instrumentation only, and the MDA, minimum detectable concentration, as the detection capability for a given instrument, procedure and type of sample.) The actual MDA for these analyses was at or below the LLD.

b The mean and the range are based on detectable measurements only. The fraction of detectable measurements at specified locations is indicated in parentheses; e.g., (10/12) means that 10 out of 12 samples contained detectable activity. The range of detected results is indicated in brackets; e.g., [23-34].

Not Required: Not required by the HBPP Unit 3 Technical Specifications or the SAFSTOR Offsite Dose Calculation Manual. Baseline environmental conditions for this parameter were established in the Environmental Report as referenced by the SAFSTOR Decommissioning Plan (now identified as the Defueled Safety Analysis Report).

N/A - Not applicable TABLE C-2 ONSITE ENVIRONMENTAL TLD STATIONS Station TLD Exposure Measurements (mR)

Number First Quarter Second Quarter Third Quarter Fourth Quarter T1 14.1 +/- 0.8 14.3 +/- 0.5 14.5 +/- 0.6 13.8 +/- 0.5 T2 12.8 +/- 0.4 12.1 +/- 0.4 13.6 +/- 0.4 13.0 +/- 0.6 T3 12.5 +/- 0.8 12.4 +/- 0.6 12.9 +/- 0.5 13.1 +/- 0.7 T4 13.4 +/- 0.5 12.6 +/- 0.6 13.1 +/- 0.3 13.4 +/- 0.2 T5 12.4 +/- 0.4 12.3 +/- 0.5 12.4 +/- 0.7 13.1 +/- 0.8 T6 11.3+/-0.5 11.5+/-0.5 11.2+/-0.4 12.2 +/- 0.7 T7 12.9 +/- 0.6 12.1 +/- 0.5 12.3 +/- 0.6 13.4 +/- 0.4 T8 11.0 +/- 0.5 11.5 +/- 0.5 11.4 +/- 0.4 11.9 +/- 0.4 T9 12.1 +/- 0.6 12.1 +/- 0.4 12.8 +/- 0.8 13.4 +/- 0.5 T10 12.1 +/-0.9 11.7+/-0.4 12.0 +/- 0.4 11.6 +/- 0.5 T1l 12.8+/-0.5 12.1 +/-0.6 12.7+/-0.6 12.7 +/- 0.5 T12 12.4 +/- 0.6 12.6 +/- 0.3 13.0 +/- 0.7 13.1 +/- 0.7 T13 12.6 +/- 0.3 13.0 +/- 0.8 13.5 +/- 0.4 13.0 +/- 0.6 T14 12.7 +/- 0.5 12.8 +/- 0.4 13.6 +/- 0.6 13.7 +/- 0.6 T15 13.1 +/- 0.6 14.5 +/- 0.9 13.1 +/- 0.7 13.6+/- 0.4 T16 12.8 +/- 0.8 14.6 +/- 0.6 12.6 +/- 0.6 13.5 +/- 0.6 T18 Note 2 13.5 +/- 0.7 13.5 +/- 0.7 14.6 +/- 0.6 T19 Note 2 14.6 +/- 0.6 14.4 +/- 0.6 14.6 +/- 0.5 T20 Note 2 15.0 +/- 0.2 13.7 +/- 0.6 13.9 +/- 0.2 T21 Note 2 13.3 +/- 0.4 13.6 +/- 0.3 13.6 +/- 0.6 Calculated Parameters (mR)

Parameter First Quarter Second Quarter Third Quarter Fourth Quarter

[Average 12.6 +/- 0.2 12.9 +/- 0.1 13.0 +/- 0.1 13.3 +/- 0.1 Maximum 14.1 +/- 0.8 15.0 +/- 0.2 14.5 +/- 0.6 14.6 +/- 0.6 Notes:

1. These exposures are reported for a standardized period of 90 days.

2. TLD stations T18, T19, T20 and T21 are on the fence surrounding the Independent Spent Fuel Storage Installation (ISFSI). In 2009 and the first quarter of 2010, monitoring of this fence was done using Panasonic 802 TLDs. The 802 TLDs use a background subtract algorithm, with the resulting doses for all measurements of zero. In the second quarter of 2010, Panasonic 814 TLDs replaced the 802 TLDs.

The 814 algorithm reports environmental doses.

TABLE C-3 OFFSITE ENVIRONMENTAL TLD STATIONS Station TLD Exposure Measurements (mR)

Number First Quarter Second Quarter Third Quarter Fourth Quarter 1 12.4 +/- 0.4 12.6 +/- 0.5 12.3 +/- 0.6 12.4 +/- 0.4 2 14.0 +/- 0.9 13.6 +/- 0.7 13.7 +/- 0.4 14.4 +/- 0.6 14 11.1 +/-0.4 11.1 +/-0.4 11.0+/-0.5 11.3+/-0.6 25 12.4 +/- 0.8 11.1 +/- 0.2 j 11.3 +/- 0.8 11.4 +/- 0.6 Calculated Parameters (mR)

Parameter First Quarter Second Quarter Third Quarter Fourth Quarter Average 12.5 +/- 0.3 12.1 +/- 0.2 12.1 +/- 0.3 12.4 +/- 0.3 Maximum 1 14.0 +/- 0.9 13.6 +/- 0.7 13.7 +/- 0.4 14.4 +/- 0.6 Note:

1. These exposures are reported for a standardized period of 90 days.

TABLE C-4 DISCHARGE CANAL SAMPLE RESULTS Gamma Activity (pCi/I) Tritium Activity Sample Date Cs-1 37 Co-60 (pCi/I) 1/6/2010 <MDA <MDA <MDA 1/13/2010 <MDA <MDA <MDA 1/20/2010 <MDA <MDA <MDA 1/27/2010 <MDA <MDA <MDA 2/3/2010 <MDA <MDA <MDA 2/10/2010 <MDA <MDA <MDA 2/17/2010 <MDA <MDA <MDA 2/24/2010 <MDA <MDA <MDA 3/3/2010 <MDA <MDA <MDA 3/10/2010 <MDA <MDA <MDA 3/17/2010 <MDA <MDA <MDA 3/24/2010 <MDA <MDA <MDA 3/31/2010 <MDA <MDA <MDA 4/7/2010 <MDA <MDA <MDA 4/14/2010 <MDA <MDA <MDA 4/21/2010 <MDA <MDA <MDA 4/28/2010 <MDA <MDA <MDA 5/5/2010 <MDA <MDA <MDA 5/12/2010 <MDA <MDA <MDA 5/19/2010 <MDA <MDA <MDA 5/26/2010 <MDA <MDA <MDA 6/2/2010 <MDA <MDA <MDA 6/9/2010 <MDA <MDA <MDA 6/16/2010 <MDA <MDA <MDA 6/23/2010 <MDA <MDA <MDA 6/30/2010 <MDA <MDA <MDA 7/7/2010 <MDA <MDA <MDA 7/14/2010 <MDA <MDA <MDA 7/21/2010 <MDA <MDA <MDA 7/28/2010 <MDA <MDA <MDA 8/4/2010 <MDA <MDA <MDA 8/11/2010 <MDA <MDA <MDA 8/18/2010 <MDA <MDA <MDA 8/25/2010 <MDA <MDA <MDA 9/1/2010 <MDA <MDA <MDA 9/8/2010 <MDA <MDA <MDA 9/15/2010 <MDA <MDA <MDA 9/22/2010 <MDA <MDA <MDA 9/29/2010 <MDA <MDA <MDA TABLE C-4 (CONTINUED)

DISCHARGE CANAL SAMPLE RESULTS Gamma Activity (pCi/I) Tritium Activity Sample Date Cs-1 37 Co-60 (pCi/I) 10/6/2010 <MDA <MDA <MDA 10/13/2010 <MDA <MDA <MDA 10/20/2010 <MDA <MDA <MDA 10/27/2010 <MDA <MDA <MDA 1'1/3/2010 <MDA <MDA <MDA 11/10/2010 <MDA <MDA <MDA 11/17/2010 <MDA <MDA <MDA 11/24/2010 <MDA <MDA <MDA 12/1/2010 <MDA <MDA <MDA 12/8/2010 <MDA <MDA <MDA 12/15/2010 <MDA <MDA <MDA 12/22/2010 <MDA <MDA <MDA 12/29/2010 <MDA <MDA <MDA Calculated Gamma Activity (pCi/I) Tritium Activity Parameters Cs-1 37 Co-60 (pCi/I)

Average Note 4 Note 4 Note 4 Maximum Note 4 Note 4 Note 4 Notes:

I. Gamma measurements are performed on the original sample, with results corrected to the time of sampling. Naturally occurring isotopes are not reported. The maximum lower limits of detection (LLDs) for Co-60 and Cs-1 37 are 15 and 18 pCi/I, respectively. The MDA for these analyses was at or below the LLD and are reported as "<MDA".

2. For purposes of this report, LLD is defined as the a priori (before the fact) lower limit of detection, which represents the capability of the measurement system. MDA is defined as the a posteriori (after the fact) limit of detection capability considering a given instrument, procedure and type of sample.

3. Tritium analysis is performed on a measured aliquot of distilled sample. The reported values are net measurements above instrument background. The normal MDA for the analyses for tritium was less than 400 pCi/I. Results that are at or below the normal MDA are reported as "<MDA".

4. Results identified as "<MDA" are not included in the calculation of average and maximum values.

TABLE C-5 GROUNDWATER MONITORING WELL RESULTS Monitor Alpha Beta Gamma Tritium Well Sample Activity Activity Activity Activity Number Date (pCi/I) (pCi/I) (pCi/I) (pCi/I)

Cs-137 Co-60 MW-11 2/18/10 <4.23 (MDA) <5.56 (MDA) <5.01 (MDA) <4.26 (MDA) <211 (MDA)

MW-1 2/18/10 <4.77 (MDA) <5.52 (MDA) <5.57 (MDA) <5.03 (MDA) <211 (MDA)

MW-4 2/18/10 8.35 +/- 3.75 13.2 +/- 3.20 <3.53 (MDA) <4.17 (MDA) <211 (MDA)

MW-6 2/18/10 <3.19 (MDA) <2.85 (MDA) <6.84 (MDA) <6.19 (MDA) <242 (MDA)

MW-2 2/18/10 <3.34 (MDA) 7.64 +/- 2.31 <5.07 (MDA) <4.52 (MDA) <212 (MDA)

MW-11 5/19/10 <8.67 (MDA) <11.9 (MDA) <4.64 (MDA) <5.60 (MDA) <127 (MDA)

MW-1 5/18/09 <8.27 (MDA) <10.9 (MDA) <5.88 (MDA) <4.09 (MDA) <335 (MDA)

MW-4 5/18/10 9.19 +/- 3.13 12.6 +/- 3.40 <5.23 (MDA) <3.64 (MDA) <125 MDA)

MW-6 5/18/10 <1.49 (MDA) <3.17 (MDA) <3.96 (MDA) <4.28 (MDA) <338 (MDA)

MW-2 5/18/10 <1.28 (MDA) 3.85 +/- 1.68 <5.04 (MDA) <5.14 (MDA) <129 (MDA)

MW-11 8/25/10 <6.67(MDA) <6.76 (MDA) <4.36 (MDA) <4.63 (MDA) <317 (MDA)

MW-1 8/25/10 <5.67 (MDA) <6.84 (MDA) <3.47 (MDA) <4.36 (MDA) <319 (MDA)

MW-4 8/25/10 <3.12 (MDA) 6.41 +/- 2.53 <3.97 (MDA) <4.26 (MDA) <318 (MDA)

MW-6 8/25/10 <1.95 (MDA) <3.65 (MDA) <7.74 (MDA) <5.29 (MDA) <318 (MDA)

MW-2 8/25/10 <2.96 (MDA) <2.57 (MDA) <3.73 (MDA) <4.78 (MDA) <363 (MDA)

MW-11 11/17/10 <4.04(MDA) <6.37 (MDA) <2.19 (MDA) <2.11 (MDA) <272 (MDA)

MW-1 11/17/09 <4.10 (MDA) <4.95 (MDA) <2.26 (MDA) <2.08 (MDA) <273 (MDA)

MW-4 11/17/10 <3.22 (MDA) 3.92 +/- 2.19 <2.14 (MDA) <2.28 (MDA) <272 (MDA)

MW-6 11/17/10 <2.97 (MDA) <3.68 (MDA) <2.35 (MDA) <2.39 (MDA) <272 (MDA)

MW-2 111/17/10 <2.95 (MDA) <2.39 (MDA) <2.52 (MDA) <2.30 (MDA) <271 (MDA)

TABLE C-5 (CONTINUED)

GROUNDWATER MONITORING WELL RESULTS Calculated Alpha Beta Gamma Tritium Parameters Activity Activity Activity Activity (By Monitor Well (pCi/I) (pCil() (PC!) (pCi/I)

Number) Cs-1 37 Co-60 Average: MW-1 Note 4 Note 4 Note 4 Note 4 Note 4 Average: MW-2 Note 4 5.75 +/- 1.43 Note 4 Note 4 Note 4 Average: MW-4 8.77 +/- 2.44 9.03 +/- 1.44 Note 4 Note 4 Note 4 Average: MW-6 Note 4 Note 4 Note 4 Note 4 Note 4 Average: MW-1 I Note 4 Note 4 Note 4 Note 4 Note 4 Maximum: MW-1 Note 4 Note 4 Note 4 Note 4 Note 4 Maximum: MW-2 Note 4 7.64 1 2.31 Note 4 Note 4 Note 4 Maximum: MW-4 9.19 +/- 3.13 13.2 +/- 3.20 Note4 Note 4 Note4 Maximum: MW-6 Note 4 Note 4 Note 4 Note 4 Note 4 Maximum: MW-1 1 Note 4 Note 4 Note 4 Note 4 Note 4 Notes:

1. Reported values are net measurements (above instrument background). The normal minimum detectable activities (MDAs) for the analyses for gross alpha, gross beta and tritium are approximately 4, 4 and 400 pCi/I, respectively. Results that are at or below the normal MDA are reported as "<MDA".

2. Gamma activity measurements are performed on the original sample, with results corrected to the time of sampling. Naturally occurring isotopes are not reported. The maximum lower limits of detection (LLDs) for Co-60 and Cs-137 are 15 and 18 pCi/I, respectively. The actual MDAs for these analyses were at or below the LLD.

3. For purposes of this report, LLD is defined as the a priori (before the fact) lower limit of detection, which represents the capability of the measurement system. MDA is defined as the a posteriori (after the fact) limit of detection capability considering a given instrument, procedure and type of sample.

4. Results identified as "<" are not included in the calculation of average and maximum values.

TABLE C-6 CAISSON SUMP MONITORING RESULTS Cs-1 37 Activity Co-60 Activity Tritium Sample (pCi/L) (pCilL) Activity Date (pCi/I) 01/14/10 60.1 <MDA 440 +/- 227 02/17/10 91.9 <MDA 768 +/- 236 03/17/10 31.4 <MDA 462 +/- 197 04/16/10 118 <MDA 559 +/- 151 05/13/10 79.5 <MDA 548 +/- 201 06/10/10 9.17 <MDA 601 +/- 225 07/12/10 111 <MDA 670 +/- 280 08/11/10 172 <MDA 1140 +/- 262 09/08/10 147 <MDA 770 +/- 197 10/15/10 11.3 <MDA 762 +/- 205 11/15/10 19.3 <MDA 961 +/- 217 12/15/10 13.2 <MDA 538 +/- 307 Notes:

1. Gamma measurements are performed on the original sample, with results corrected to the time of sampling. Naturally occurring isotopes are not reported. The maximum lower limits of detection (LLDs) for Co-60 and Cs-137 are 15 and 18 pCi/I, respectively. The MDA for these analyses was at or below the LLD and are reported as "<MDA".

2. For purposes of this report, LLD is defined as the a priori (before the fact) lower limit of detection, which represents the capability of the measurement system. MDA is defined as the a posteriori (after the fact) limit of detection capability considering a given instrument, procedure and type of sample.

3. Tritium analysis is performed on a measured aliquot of distilled sample. The reported values are net measurements above instrument background. The normal MDA for the analyses for tritium was 400 pCi/I. Results that are at or below the normal MDA are reported as "<MDA".

TABLE C-7 FRENCH DRAIN MONITORING RESULTS Cs-137 Activity Co-60 Activity Sample (pCi/L) (pCi/L)

Date 111412010 324 <MDA 2/1712010 282 <MDA 3/1712010 259 <MDA 4116/2010 322 <MDA 5/1312010 397 <MDA 6/10/2010 369 <MDA 7/12/2010 396 <MDA 8/11/2010 363 <MDA 910812010 311 <MDA 10/15/2010 320 <MDA 11/2010 Note 3 Note 3 12/15/2010 236 <MDA Notes:

1. Gamma measurements are performed on the original sample, with results corrected to the time of sampling. Naturally occurring isotopes are not reported. The maximum lower limits of detection (LLDs) for Co-60 and Cs-1 37 are 15 and 18 pCi/I, respectively. The MDA for these analyses was at or below the LLD and reported as

"<MDA".

2. For purposes of this report, LLD is defined as the a priori (before the fact) lower limit of detection, which represents the capability of the measurement system. MDA is defined as the a posteriori (after the fact) limit of detection capability considering a given instrument, procedure and type of sample.

3. Unable to obtain a sample in November.

TABLE C-8 ADDITIONAL GROUNDWATER MONITORING RESULTS Monitor Alpha Beta Gamma Tritium Well Sample Activity Activity Activity Activity Number Date (pCiIl) I(pCi/I) (pCill) (pCi/I)

Cs-1 37 Co-60 SG-MW-03 Note 4 Note 4 Note 4 Note 4 Note 4 Note 4 1C-MW-07 2/18/10 <2.70 (MDA) <3.61 (MDA) <4.32 (MDA) <4.65 (MDA) <242 (MDA) 1C-MW-08 2/18/10 <2.97 (MDA) 2.82 +/- 1.88 <5.01 (MDA) <5.41 (MDA) <213 (MDA) 1E-MW-12 2/18/10 <7.93 (MDA) <10.3 (MDA) <5.28 (MDA) <3.87 (MDA) <242 (MDA) 1E-MW-13 2/18/10 <2.88 (MDA) <2.99 (MDA) <4.54 (MDA) <5.12 (MDA) <212 (MDA)

RCW-SFP-1 2/18/10 <3.16 (MDA) <3.64 (MDA) <4.48 (MDA) <3.63 (MDA) <242 (MDA)

RCW-SFP-2 2/18/10 4.77 +/- 2.79 <3.45 (MDA) <4.85 (MDA) <4.68 (MDA) <242 (MDA)

RCW-CS-1 2/18/10 29.7 +/- 17.6 <23.4 (MDA) <7.61 (MDA) <5.43 (MDA) <211 (MDA)

RCW-CS-2 2/18/10 <11.30 (MDA) <12.3 (MDA) <6.38 (MDA) <6.99 (MDA) <211 (MDA)

RCW-CS-3 2/18/10 <2.16 (MDA) <3.83 (MDA) <6.73 (MDA) <6.36 (MDA) <242 (MDA)

RCW-CS-4 2/18/10 <3.07 (MDA) <2.88 (MDA) <3.64 (MDA) <4.82 (MDA) <241 (MDA)

RCW-CS-5 2/18/10 <3.07 (MDA) <2.81 (MDA) <4.99 (MDA) <5.37 (MDA) <242 (MDA)

SG-MW-03 Note 4 Note 4 Note 4 Note 4 Note 4 Note 4 IC-MW-07 5/19/10 <1.72 (MDA) 2.97 +/- 1.08 <4.62 (MDA) <5.25 (MDA) <336 (MDA) 1C-MW-08 5/18/10 <3.20 (MDA) 2.87 +/- 1.79 <4.22 (MDA) <4.24 (MDA) <337 (MDA) 1E-MW-12 5/19/10 <23.3 (MDA) <21.4 (MDA) <6.47 (MDA) <4.91 (MDA) <337 (MDA)

IE-MW-13 5/19/10 <3.89 (MDA) 2.98 +/- 1.90 <4.83 (MDA) <5.22 (MDA) <330 (MDA)

RCW-SFP-1 5/18/10 <1.99 (MDA) <3.13 (MDA) <4.15 (MDA) <5.16 (MDA) <333 (MDA)

RCW-SFP-2 5/19/10 <3.12 (MDA) <4.84 (MDA) <5.61 (MDA) <4.94 (MDA) <282 (MDA)

RCW-CS-1 5/19/10 <48.0 (MDA) <50.8 (MDA) <4.85 (MDA) <5.60 (MDA) <332 (MDA)

RCW-CS-2 5/18/10 27.4 +/- 16.4 31.4 +/- 19.5 <7.87 (MDA) <4.50 (MDA) <127 (MDA)

RCW-CS-3 5/18/10 <2.03 (MDA) <2.99 (MDA) <5.69 (MDA) <5.52 (MDA) <326 (MDA)

RCW-CS-4 5/19/10 <6.12 (MDA) 5.19 +/- 3.11 <5.29 (MDA) <5.11 (MDA) <337 (MDA)

RCW-CS-5 5/19/10 <1.73 (MDA) <3.12 (MDA) <4.15 (MDA) <5.77 (MDA) <333 (MDA)

SG-MW-03 Note 4 Note 4 Note 4 Note 4 Note 4 Note 4 1C-MW-07 8/25/10 <2.92 (MDA) 7.32 +/- 2.17 <6.22 (MDA) <6.21 (MDA) <317 (MDA) 1C-MW-08 8/25/10 <4.65 (MDA) 8.65 +/- 3.22 <6.08 (MDA) <5.23 (MDA) <314 (MDA) 1E-MW-12 8/25/10 103 +/- 27.5 86.0 +/- 21.2 <3.99 (MDA) <3.79 (MDA) <312 (MDA) 1E-MW-13 8/25/10 <2.83 (MDA) <2.28 (MDA) <4.62 (MDA) <5.36 (MDA) <318 (MDA)

RCW-SFP-1 8/25/10 <2.91 (MDA) <3.63 (MDA) <3.79 (MDA) <5.06 (MDA) <321 (MDA)

RCW-SFP-2 8/25/10 <5.26 (MDA) <6.97 (MDA) <4.29 (MDA) <3.08 (MDA) <319 (MDA)

RCW-CS-1 8/25/10 <84.7 (MDA) <122 (MDA) <5.27 (MDA <3.66 (MDA) <315 (MDA)

RCW-CS-2 8/25/10 <21.1 (MDA) <18.7 (MDA) <5.00 (MDA) <4.96 (MDA) <320 (MDA)

RCW-CS-3 8/25/10 <3.20 (MDA) <2.92 (MDA) <3.83 (MDA) <3.93 (MDA) <316 (MDA)

RCW-CS-4 8/25/10 <4.50 (MDA) 10.8 +/- 2.46 <4.44 (MDA) <5.50 (MDA) <316 (MDA)

RCW-CS-5 8/25/10 <2.79 (MDA) <2.54 (MDA) <4.35 (MDA) <5.04 (MDA) <319 (MDA) 5G-MW-03 Note 4 Note 4 Note 4 Note 4 Note 4 Note 4 1C-MW-07 11/17/10 <2.88 (MDA) 3.28 +/- 2.13 <4.83 (MDA) <4.62 (MDA) <245 (MDA) 1C-MW-08 11/17/10 8.71 +/- 3.22 11.5 +/- 2.32 <6.74 (MDA) <7.18 (MDA) <271 (MDA)

_1E-MW-1 2 11/17/10 <1 1.5 (MDA) <10.9 (MDA) <5.43 (MDA) <4.27 (MDA) <270(MDA)

TABLE C-8 (CONTINUED)

ADDITIONAL GROUNDWATER MONITORING RESULTS Monitor Alpha Beta Gamma Tritium Well Sample Activity Activity Activity Activity Number Date. (pCi/I) (pCill) (pCi/I) (pCi/I)

Cs-137 Co-60 1E-MW-13 11/17/10 <3.02 (MDA) <5.31 (MDA) <7.60 (MDA) <5.33 (MDA) <271 (MDA)

RCW-SFP-1 11/17/10 <1.46 (MDA) <3.66 (MDA) <4.55 (MDA) <3.62 (MDA) <265 (MDA)

RCW-SFP-2 11/17/10 <4.86 (MDA) 6.33 +/- 3.62 <5.03 (MDA) <3.92 (MDA) <272 (MDA)

RCW-CS-1 11/17/10 <30.2 (MDA) <32.5 (MDA) <1.98 (MDA) <2.37 (MDA) <272 (MDA)

RCW-CS-2 11/17/10 <14.9 (MDA) <29.2 (MDA) <2.80 (MDA) <2.82 (MDA) <269 (MDA)

RCW-CS-3 11/17/10 <2.45 (MDA) 5.13 +/- 2.57 <1.89 (MDA) <1.79 (MDA) <273 (MDA)

RCW-CS-4 11/17/10 <3.13 (MDA) <3.06 (MDA) <4.85 (MDA) <5.86 (MDA) <272 (MDA)

RCW-CS-5 11/17/10 <2.52 (MDA) <3.48 (MDA) <4.63 (MDA) <5.30 (MDA) <273 (MDA)

Notes:

1. Reported values are net measurements (above instrument background). The normal minimum detectable activities (MDAs) for the analyses for gross alpha, gross beta and tritium are approximately 4, 4 and 400 pCi/I, respectively. Results that are at or below the normal MDA are reported as "<MDA".

2. Gamma activity measurements are performed on the original sample, with results corrected to the time of sampling. Naturally occurring isotopes are not reported. The maximum lower limits of detection (LLDs) for Co-60 and Cs-1 37 are 15 and 18 pCi/I, respectively. The actual MDAs for these analyses were at or below the LLD.

3. For purposes of this report, LLD is defined as the a priori (before the fact) lower limit of detection, which represents the capability of the measurement system. MDA is defined as the a posteriori (after the fact) limit of detection capability considering a given instrument, procedure and type of sample.

4. The technicians were unable to obtain a water sample from the well suitable for radiological analyses. At the time of sampling, the well did not provide a sample size large enough for analyses or the degree of sample turbidity was unacceptable.

- 27 -

FIGURE A-1 LOCATIONS HBPP ONSITE TLD lip

ýMff-/

KELL BLDG~ ~ E OPAN SMPL

~ ~~R UNTI Z)

Erc CANIOW 0 F.I GE ..-

00) 4 I UNITR OFFICEYAT UN z HO OFIC ANNEX WAREHOUSE~W9e121Q.-LlS iur w%

FIGURE A-3 HBPP OFFSITE TLD LOCATIONS SoI (5

• I-,'.t .*,,

d Sp,, 9 ',a..+I M

• ": ~ ~~Tradler *. *:

~*** ~Radio 8... AN.

we~r W Park / o ,

King silmon 'Azj Trader YA -p

'(21 A+.l

)1:: ýa. ,

('I I '

. ~~ ~ ......+

.. y ...... ...

~

.... .ay. tan *]- /....a,.,

0 Lighto

1. .... .. -,b *'y .', ==.. %

t 16 A,1 t ,

.-xi = I"=

LEridND

%. . .,-\

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.=

. .,i o.,, ". --...b.::t:*.'-',. i "\

.":i:"... ,, . . *  :"0

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/1/2r P41 0

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LiiloialSato

• ! (= k if  ;'

.. j * ._*_*_* ).! Air Particulate Station

• ~~~~ ".Fi.:". .0*,~ , ~~~ *,** Biological Station

- 30 -

FIGURE A-3 (CONTINUED)

HBPP OFFSITE TLD LOCATIONS Fortuna Figure B-1 Offsite Environmental Radiation Level Trends 70 60-504 E

0,40 E -King Salmon Picnic Area (Station 1) 300 0 - Fortuna (Station 2) 0 204

- - - South Bay School (Station 14) 10

-Humboldt Hill (Station 25) 0 I i i i i i i I I..

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Year The baseline values for each location were obtained by averaging the readings at each location from 1977 through 1983. These values, however, were obtained using ion chambers instead of TLDs. The average values from 1977 through 1983 were Station 1 - 83.0 mrem, Station 2 - 79.8 mrem, Station 14 -

80.2 mrem, and Station 25 - 73.7 mrem

- 32 -

Figure B-2 Onsite Environmental Radiation Level Trends 70 60

- 0 - - - 0 50 - 00 - - - 0 0~~

40 E

a)30 -I-0 20

- - - Stations Near Radwaste Activities (T5 through T8) 10

- Other Onsite Stations 0 ' i '*i I i I i 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Year The baseline values for the two areas were obtained by averaging the readings for each area from 1977 through 1983. These values, however, were obtained using ion chambers instead of TLDs. The average value from 1977 through 1983 for the stations near the Radwaste Activities was 78.6 mrem and the average for Other Onsite stations was 79.4 mrem.