L-24-096, Submittal of Annual Radiological Environmental Operating Report

Submittal of Annual Radiological Environmental Operating Report

ML24121A138
Person / Time
Site:	Perry
Issue date:	04/22/2024
From:	Penfield R Energy Harbor Nuclear Corp, Vistra Operations Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-24-096
Download: ML24121A138 (1)

Text

Energy Harbor Nuclear Corp Perry Nuclear Power Plant 10 Center Road Perry, Ohio 44081 Rod L. P e nfield 440-280-5382 Site Vice P r esident, Perry Nuclear 724-462-0816 (cell)

April 22, 2024 L-24-096 10CFR50.36(a)

ATTN : Documen t Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 5000-440 Annual Radiological Environmental Operating Report

Enclosed is the Annual Radiological Environmental Operating Report for the Perry Nuclear Power Plant (PNPP) for the period of January 1, 2023 through December 31, 2023. This document partially satisfies the requirements of the PNPP Techn ical Specifications (TS), the PNPP Offsite Dose Calculation Manual (ODCM), and the Environmental Protection Plan contained in Append ix B of the PNPP Operating License.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Eli Crosby, Manager of Radiation Protection and Chemistry at (440) 280-5032.

Enclosures :

A PNPP 2023 Annual Radiological Env ironmental Operating Report

cc : NRC Project Manager NRC Resident Inspector NRC Region 111 Enclosure A

L-24-096

PNPP 2023 Annual Radiological Environmental Operating Report Annual Radiological Environmental Operating Report YEAR: 2023 Page 1 of 81

Company: Energy Harbor Plant: Perry Nuclear Power Plant

Annual Radiological Environmental Operating Report 2023

Document Number: L-24-096 Annual Radiological Environmental Operating Report YEAR: 2023 Page 2 of 81 L-24-096 Company: Energy Harbor Plant: Perry Nuclear Power Plant

TABLE OF CONTENTS Page 1.0 EXECUTIVE

SUMMARY

................................................................................................ 6 1.1 Radiological Environmental Monitoring Program................................................. 6 1.2 Pre-Occupational REMP..................................................................................... 6 1.3 Operational REMP.............................................................................................. 6

2.0 INTRODUCTION

............................................................................................................ 7 3.0 SAMPLE LOCATIONS................................................................................................... 8 4.0 MAPS OF COLLECTION SITES.................................................................................. 10 5.0 SAMPLING ANALYSIS................................................................................................ 12 5.1 Sampling Program............................................................................................ 13 5.2 Sampling Changes............................................................................................ 14 6.0 ATMOSPHERIC MONITORING................................................................................... 14 7.0 TERRESTRIAL MONITORING..................................................................................... 16 7.1 Milk............................................................................................................................... 16 7.2 Broadleaf Vegetation.................................................................................................... 16 8.0 AQUATIC MONITORING............................................................................................. 16 8.1 Water................................................................................................................ 17 8.2 Sediment.......................................................................................................... 17 8.3 Fish................................................................................................................... 18 9.0 DIRECT RADIATION MONITORING............................................................................ 18

10.0 CONCLUSION

............................................................................................................. 19 11.0 INTER-LABORATORY CROSS-CHECK COMPARISON PROGRAM.......................... 19 12.0 LAND USE CENSUS EXPOSURE PATHWAY............................................................. 19 12.1 Introduction....................................................................................................... 20 12.2 Discussion and Results..................................................................................... 20 13.0 ANNUAL ENVIRONMENTAL OPERATING REPORT.................................................. 22 14.0 ODCM NON-COMPLIANCES...................................................................................... 22 14.1 Non-Compliances............................................................................................. 22 14.2 Sampling Challenges........................................................................................ 23 15.0 CORRECTIONS TO PREVIOUS REPORTS.................................................... 23 16.0 BIBLIOGRAPHY........................................................................................................... 23 : Inter-Laboratory Cross Check Comparison Program Results............................ 25 : REMP Data Summary Reports.......................................................................... 43 : 2022 REMP Detailed Data Report..................................................................... 50

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TABLES Page Table 1: REMP Sampling Locations........................................................................................... 9 Table 2: REMP Sample Analyses.............................................................................................14 Table 3: Air Particulate and Radioiodine Comparison of Current Year and Historic Data..........15 Table 4: Nearest Residence - By Sector...................................................................................20 Table 5: Nearest Garden - By Sector........................................................................................21

FIGURES Page Figure 1: Potential exposure pathways to members of the public from plant operations [1]........ 8 Figure 2: REMP Sample Locations within Two Miles of the Plant Site.......................................10 Figure 3: REMP Sampling Locations between Two and Eight Miles from the Plant Site............11 Figure 4: REMP Sampling Locations Greater Than Eight Miles from the Plant Site..................12 Figure 5: Air Particulate and Radioiodine Comparison of Current Year and Historic Data.........15 Figure 6: Annual Average Gross Beta Activity in Water.............................................................17 Figure 7: Average Quarterly TLD Dose.....................................................................................18 Figure 8: Land Use Census Map...............................................................................................21

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LIST OF ACRONYMS AND DEFINITIONS

1. Airborne Activity Sampling: Continuous sampling of air through the collection of particulates and radionuclides on filter media. Periodic soil samples are collected for gamma isotopic analysis to provide information on deposition to the soil from airborne releases.

2. AIP: Air, Iodine and Particulate

3. ARERR: Annual Radioactive Effluent Release Report

4. AREOR: Annual Radioactive Environmental Operating Report

5. BLV: Broad Leaf Vegetation

6. BWR: Boiling Water Reactor

7. Composite Sample: A series of single collected portions (aliquots) analyzed as one sample. The aliquots making up the sample are collected at time intervals that are very short compared to the composite period.

8. Control: A sampling station in a location not likely to be affected by plant effluents due to its distance and/or direction from Perry Nuclear Power Plant.

9. Curie (Ci): A measure of radioactivity; equal to 3.7E+10 disintegrations per second or 2.22E+12 disintegrations per minute.

10. Direct Radiation Monitoring: The measurement of radiation dose at various distances from the plant is assessed using Thermoluminescent dosimeters.

11. DW: Drinking Water

12. Grab Sample: A single discrete sample drawn at one point in time.

13. Indicator: A sampling location that is likely to be affected by plant effluents due to its proximity and/or direction from the plant.

14. Ingestion Pathway: The ingestion pathway includes milk, fish, drinking water and garden produce. Also sampled (under special circumstances) are other media such as vegetation and animal products such as eggs and meat when additional information about particular radionuclides is needed.

15. Lower Limit of Detection (LLD): The smallest concentration of radioactive material in a sample that will yield a net count (above system background) that will be detected with 95% probability with a 5% probability of a false conclusion that a blank observation represents "real" signal.

16. MDA: Minimum Detectable Activity

17. Mean: The average, i.e., the sum of results divided by the number of results.

18. NA: Not Applicable

19. NIST: National Institute of Standards and Technology.

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20. NRC: Nuclear Regulatory Commission

21. ODCM: Offsite Dose Calculation Manual

22. pCi: is equal to one trillionth of a curie or 2.22 disintegrations per second.

23. pCi/L: picocuries / Liter

24. PNPP: Perry Nuclear Power Plant

25. PWR: Pressurized Water Reactor

26. REMP: Radiological Environmental Monitoring Program

27. SW: Surface Water

28. TLD: Thermoluminescent Dosimeter

29. TS: Technical Specification

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1.0 EXECUTIVE

SUMMARY

The Annual Radiological Environmental Operating Report (AREOR) details the results of Radiological Environmental Monitoring Program (REMP) conducted at the Perry Nuclear Power Plant (PNPP) from January 01 through December 31, 2023. This report meets all requirements in PNPP Offsite Dose Calculation Manual (ODCM). Report topics include radiological environmental monitoring and the land use census. The results of the environmental and effluent programs indicate that the operations of the PNPP did not result in any adverse environmental impact.

1.1 Radiological Environmental Monitoring Program The Radiological Environmental Monitoring Program (REMP) was established in 1981 to monitor the radiological conditions in the environment around PNPP. The operational REMP was initiated in 1986 and has continued through this reporting period. The REMP is conducted in accordance with the PNPP ODCM. This program includes collection and analysis of environmental samples and evaluation of results at indicator as well as control locations. Indicator samples are collected at locations determined to be most influenced by operation of the PNPP. Control samples are collected at locations beyond the measurable influence of the PNPP for data comparison.

1.2 Pre-Occupational REMP The REMP was established at PNPP six years before the plant became operational.

Between 1981 and 1986 environmental monitoring involved collection and analysis of environmental samples. This pre-operational program was designed to provide data on background radiation levels and radioactivity normally present in the area in order to establish a baseline for data comparison prior to operation of the plant. PNPP has continued to monitor the environment during plant operation by collecting and analyzing samples of air, milk, fish, vegetation, water, and sediment, as well as by measuring radiation directly.

The contribution of radionuclides to the environment resulting from PNPP operation is assessed by comparing results from the environmental monitoring program with pre-operational data, operational data from previous years, and control location data. The results for each sample type are compared to historical data to determine whether trends or changes in concentrations are observable.

1.3 Operational REMP Results of air samples collected to monitor the radioactivity in the atmosphere indicated normal background radionuclide concentrations. Terrestrial monitoring vegetation analysis due to the unavailability of milk samples, the results of which indicated concentrations of radioactivity similar to those found in previous years. Analyses of vegetation samples detected only natural radioactivity similar to that observed in previous years and indicated no radioactivity attributable to operation of the PNPP.

Aquatic monitoring included the collection and analyses of water, fish, and shoreline sediments. The analytical results of these samples showed normal background radionuclide concentrations.

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Direct radiation measurements showed no significant changes from previous years. The indicator locations averaged 14.4 mrem/quarter and control locations averaged 14.2 mrem/quarter. Radiation dose near PNPP was similar to the radiation dose measured at locations greater than ten miles away from PNPP.

Results from indicator samples collected during this reporting period were compared to control sample results and pre-operational data. Based on the results, it can be concluded that the operation of the PNPP resulted in no significant increase in the radionuclide concentrations observed in the surrounding environment. The results of the REMP indicate adequate control of radioactivity released from PNPP. These results also demonstrate that PNPP complies with federal regulations.

2.0 INTRODUCTION

The REMP was established at PNPP for several reasons. First, it verifies the adequacy of plant design and operation to control radioactive materials and limit effluent releases.

Second, it assesses the radiological impact, if any, that the plant has had on the surrounding environment. Third, it ensures compliance with regulatory guidelines. The REMP is conducted in accordance with Appendix B of the PNPP Operating License, Technical Specifications, the ODCM, Nuclear Regulatory Commission (NRC) Regulatory Guide 4.1, NUREG 1302 [3], and the 1979 NRC Branch Technical Position [9].

A variety of samples are collected as part of the PNPP REMP. The selection of sample types, locations, and collection frequency are based on many variables. Potential pathways for the transfer of radionuclides through the environment to humans, sample availability, local meteorology, population characteristics, land use, and NRC requirements are all factors and diagramed in Figure 1.

To ensure that the REMP data is significant and valuable, detailed sampling methods and procedures are followed to ensure that samples are collected in the same manner and from the same locations each time. All samples are packaged on site and then shipped to an independent vendor laboratory for analysis. The vendor laboratory analyzes the samples and reports results to the PNPP Chemistry Unit staff, the Lake County General Health District, and the State of Ohio Department of Health. Additionally, the Lake County General Health District obtains monthly split samples of milk (when available), water, and vegetation to perform an independent verification of PNPPs REMP.

The Radiological Environmental Monitoring Program (REMP) provides data on measurable levels of radiation and radioactive materials in the environment. This program also evaluates the relationship between quantities of radioactive materials released from the plant and resultant doses to individuals from principal pathways of exposure. In this capacity, REMP provides a check on the effluent release program and dispersion modeling to ensure that concentrations in the environment radioactive effluents conform to the As Low as Is Reasonably Achievable (ALARA) design objectives of 10 CFR 50, Appendix I. REMP is designed to conform to the NRC Regulatory Guide 4.1, NUREG 1302 [3], and the 1979 NRC Branch Technical Position [9].

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Figure 1: Potential exposure pathways to members of the public from plant operations [1].

Quality assurance aspects of the sampling program and TLD data collection are conducted in accordance with Regulatory Guide 4.15 [7] and Regulatory Guide 4.13 [11]. REMP also adheres to the requirements of the State of Ohio, PNPP Technical Specifications, and the Offsite Dose Calculation Manual (ODCM). These documents dictate the environmental sampling, sample analysis protocols, data reporting, and quality assurance requirements for the environmental monitoring program.

The Annual Radioactive Environmental Operating Report provides summaries of the environmental data from exposure pathways, interpretations of the data, and analyses of trends of the results. Routinely monitored pathways include ingestion, inhalation, and direct radiation. Routes of exposure are based on site specific information such as meteorology, receptor locations, and water usage around the plant.

3.0 SAMPLE LOCATIONS REMP samples are collected at numerous locations, both on site and up to 16.2 miles away from the plant. Sampling locations are divided into two general categories:

indicator and control. Indicator locations are relatively close to the plant and monitor for any environmental impact due to plant operations. Control locations are those that are unaffected by plant operation; they are a greater distance from the plant and in the least prevalent wind directions.

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Data obtained from the indicator locations are compared with data from the control locations. This comparison allows naturally occurring background radiation to be considered when evaluating any radiological impact PNPP may have had on the environment. Table 1, Figure 2, Figure 3, and Figure 4 identify the PNPP REMP sampling locations. Many REMP samples are collected in addition to those required by the PNPP ODCM. The ODCM requirements for each sample type are discussed in more detail later in the report.

Table 1: REMP Sampling Locations Location # Description Miles Direction Media (1) 1 Chapel Road 3.4 ENE TLD, AIP 2 Kanda Garden 1.9 ENE Broadleaf Vegetation 3 Meteorological Tower 1.0 SE TLD, AIP 4 Site Boundary 0.7 S TLD, AIP 5 Quincy Substation 0.6 SW TLD, AIP 6 Concord Service Center 11.0 SSW TLD, AIP 7 Site Boundary 0.6 NE TLD, AIP 8 Site Boundary 0.8 E TLD 9 Site Boundary 0.7 ESE TLD 10 Site Boundary 0.8 SSE TLD 11 Parmly Rd. at Center Rd. 0.6 SSW TLD 12 Site Boundary 0.6 WSW TLD 13 Madison-on-the-Lake 4.7 ENE TLD 14 Hubbard Rd. 4.9 E TLD 15 Eagle St. Substation 5.1 ESE TLD 16 Eubank Garden 0.9 S Broadleaf Vegetation 20 Rainbow Farms 1.9 E Broadleaf Vegetation 21 Hardy Rd. - Painesville Township Park 5.1 WSW TLD 23 High St. Substation 7.9 WSW TLD 24 St. Clair Ave. at Mentor Substation 15.1 SW TLD 25 Offshore - PNPP discharge 0.6 NNW Fish 29 River Rd.at Turney Rd. 4.3 SSE TLD 30 Lane Rd. 4.8 SSW TLD 31 Wood Rd. at River Rd. 4.8 SE TLD 32 Offshore - Mentor-on-the-Lake 15.8 WSW Fish 33 River Rd. at Blair Rd. 4.5 S TLD 34 PNPP Intake 0.2 NW Surface Water 35 Site Boundary 0.6 E TLD, AIP 36 Lake County Water Plant 3.9 WSW TLD, Drinking Water 37 Gerlica Farm 1.5 ENE Broadleaf Vegetation 39 Painesville Purification Plant 8.3 W Drinking Water 53 3715 Parmly Rd. 0.5 WSW TLD 54 Hale Rd. School 4.6 SW TLD 55 Center Rd. behind soccer field 2.5 S TLD 56 Madison High School 4.0 ESE TLD 57 Perry High School 1.7 S TLD 58 Antioch Rd. 0.8 ENE TLD 59 Lake Shoreline at Green Rd. 4.0 ENE Surface Water 60 Lake Shoreline at Perry Park 1.0 WSW Surface Water 64 Northwest Drain Mouth 0.4 WNW Sediment 66 Lake Shore, Metropolitan Park 1.4 NE Sediment 70 H&H Farm Stand 16.2 SSW Broadleaf Vegetation

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4.0 MAPS OF COLLECTION SITES

Figure 2: REMP Sample Locations within Two Miles of the Plant Site.

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Figure 3: REMP Sampling Locations between Two and Eight Miles from the Plant Site

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Figure 4: REMP Sampling Locations Greater Than Eight Miles from the Plant Site.

5.0 SAMPLING ANALYSIS When environmental samples are analyzed for radioactivity, several types of measurements are performed to provide information about the types of radiation and radionuclides present. The major analyses that are performed are discussed below.

Gross beta activity measures the total amount of beta-emitting radioactivity present in a sample and acts as a tool to identify samples that may require further analysis. Beta radiation may be released by many different radionuclides. Since beta-decay results in a continuous energy spectrum rather than the discrete energy levels, or "peaks",

associated with gamma radiation, identification of specific beta-emitting nuclides is more difficult. Therefore, gross beta activity only indicates whether the sample contains normal or abnormal amounts of beta emitting radioactivity; it does not specifically identify the radionuclides present.

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Gamma spectral analysis provides more specific information than does the analysis for gross beta activity. Gamma spectral analysis identifies each radionuclide and the amount of radioactivity present in the sample that is emitting gamma radiation. Each radionuclide has a very specific "fingerprint" that allows for accurate identification and quantification.

Iodine activity analysis measures the amount of radioactive iodine present in a sample.

Some media (e.g., air sample charcoal cartridges) are analyzed directly by gamma spectral analysis. With other media (e.g., milk when available), the radioiodines are extracted by chemical separation before being analyzed by gamma spectral analysis.

Tritium activity analysis measures the amount of the radionuclide tritium (H-3) present in a sample. Tritium is an isotope of hydrogen that emits low-energy beta particles. Tritium occurs naturally from interactions with atmospheric cosmic rays and is also man-made from the nuclear fission process.

Gamma doses received by Thermoluminescent Dosimeters (TLD) while in the field are determined by a special laboratory procedure. Thermoluminescence is a process by which ionizing radiation interacts with the sensitive phosphor material in the TLD. Energy is trapped in the TLD material and can be stored for months or years. This capability provides a method to measure the dose received over long periods of time. The amount of energy that was stored in the TLD as a result of interaction with radiation is released by a controlled heating process and measured in a calibrated reading system. As the TLD is heated, the phosphor releases the stored energy as light. The amount of light is directly proportional to the amount of radiation to which the TLD was exposed.

The required REMP detection limits for samples are determined by sample media and the radionuclide that is being analyzed. The NRC has established LLDs for REMP sample analysis. These LLDs are listed in the PNPP ODCM. The vendor laboratory for REMP sample analysis has complied with these LLDs.

Table 2 provides a list of the analyses performed on environmental samples collected for the PNPP REMP, with the exception of terrestrial monitoring of milk samples. No milk-producing animals are located within the required distance per the ODCM, reference Section 7.1 Milk.

5.1 Sampling Program The contribution of radionuclides to the environment resulting from PNPP operation is assessed by comparing results from the environmental monitoring program with pre-operational data (i.e., data from before 1986), operational data from previous years, and control location data. The results for each sample type are discussed below and compared to historical data to determine if there are any observable trends. All results are expressed as concentrations. Refer to Appendix B, 2023 REMP Data Summary Reports for a detailed listing of these results. The NRC requires special reporting whenever sample analysis results exceed set limits. No values exceeded those limits.

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Table 2: REMP Sample Analyses

Type Sample Frequency Analysis

Airborne Weekly Gross Beta Activity Atmospheric Particulates Quarterly Gamma Spectral Analysis Monitoring Airborne Weekly Iodine-131 Radioiodine Monthly Gamma Spectral Analysis &

Milk Semi-Monthly when Iodine-131 Terrestrial animals are on pasture Monitoring Gamma Spectral Analysis &

Broadleaf Monthly during growing Vegetation season Iodine-131

Monthly Gross Beta Activity Drinking Water & Gamma Spectral Analysis

Quarterly Tritium Activity

Surface Water Monthly Gamma Spectral Analysis Aquatic Monitoring Quarterly Tritium Activity Annually if seasonal.

Fish Semi-Annually if not Gamma Spectral Analysis seasonal.

Sediment Semi-annually Gamma Spectral Analysis

Direct Radiation TLD Quarterly & Gamma Dose Monitoring Annually

5.2 Sampling Changes There were no changes to the REMP program during this reporting period.

6.0 ATMOSPHERIC MONITORING Air sampling is conducted to detect any increase in the concentration of airborne radionuclides. The PNPP REMP maintains an additional two air sampling locations above the five locations (four indicators and one control) required by the ODCM. Six of these locations are within four miles of the plant site; the seventh is used as a control location and is eleven miles from PNPP.

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Air sampling pumps draw continuous samples at a rate of approximately two cubic feet per minute. The air is drawn through glass fiber filters to collect particulate material and a charcoal cartridge to adsorb iodine. The samples are collected on a weekly basis, 52 weeks a year, from each of the seven air sampling stations. Due to how the 2023 calendar year fell, 53 weeks of data were collected and included in this report.

Air samples are analyzed weekly for gross beta activity and radioiodine activity. The air samples are also analyzed by gamma spectral analysis quarterly. A total of 370 air particulate and 370 air radioiodine samples were collected and analyzed.

Gross beta activity was detected in 370 of the 370 air samples. The average gross beta activity for all indicator locations was 0.025 pCi/m3 and the controls was 0.026 pCi/m3.

Historically, the concentration of gross beta in air has been essentially identical at indicator and control locations. Figure 5 reflects the average gross beta activity for 2023 and previous years.

With the exception of naturally occurring beryllium-7, no radionuclides above the LLD values were identified in the quarterly gamma spectral analysis. All radioiodine samples were less than the lower limit of detection for iodine-131.

Figure 5: Air Particulate Gross Beta Comparison of Current Year and Historic Data

Air particulate and gross beta results from this monitoring period, 2023, were similar compared to preoperational data as shown in Figure 5 and Table 3 There were no significant changes in baseline.

Table 3: Air Particulate Gross Beta Comparison of Current Year and Historic Data Pre-Operational (pCi/m3) 2023 Sample Result Average (pCi/m3) 0.023 0.025

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7.0 TERRESTRIAL MONITORING Collecting and analyzing samples of milk (when available) and broadleaf vegetation provides data to assess the build-up of radionuclides that may be ingested by humans.

The historical data from soil and vegetation samples provides information on atmospheric radionuclide deposition.

7.1 Milk Since the milk sampling locations do not meet the requirements of the ODCM (no milk-producing animals are located within the required distance), broadleaf vegetation sampling (discussed below) is performed by PNPP. Milk was collected from the available locations to augment vegetation sampling until Spring 2018.

7.2 Broadleaf Vegetation Because there is not a milking animal within 5 km of the plant, PNPP sampled broadleaf vegetation as required by the ODCM. These samples are collected monthly during the growing season from four gardens in the vicinity of PNPP and one control location 16.2 miles SSW from PNPP.

Sixty three (63) samples were collected and analyzed by gamma spectral analysis. Four vegetation types were grown and collected: collard greens, turnip greens, kale, and Swiss chard. Beryllium-7 and potassium-40, both naturally occurring radionuclides, were found in the samples. No other radionuclides were detected.

The decrease in the number samples from previous years is because three garden participants were unable to produce swiss chard for the 2023 growing season. This was corelated to excessive rain during the spring. A second planting was attempted in mid-July to attempt obtaining end of season vegetation; however, this planting was unsuccessful.

8.0 AQUATIC MONITORING Radionuclides may be present in Lake Erie from many sources other than the PNPP.

These sources include atmospheric deposition, run-off, soil erosion, and releases of radioactivity in liquid effluents from hospitals, universities, or other industrial facilities.

These sources provide two forms of potential radiation exposure: external and internal.

External exposure can occur from contact with water or shoreline sediments, while internal exposure can occur from either direct ingestion of radionuclides or the transfer of radionuclides through the aquatic food chain. Direct exposure can occur through ingestion by drinking the water, while the transfer via the aquatic food chain occurs from the eventual consumption of aquatic organisms, such as fish. PNPP samples water, shoreline sediments, and fish to monitor these pathways.

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8.1 Water Water is sampled from five locations along Lake Erie in the vicinity of the PNPP as required by the PNPP ODCM when available and as weather permits. Sixty (60) monthly composite samples were collected and analyzed for gross beta activity and gamma spectral analysis. Monthly composite samples are analyzed for gamma emitters.

Aliquots from the monthly composites are combined to form quarterly composites which is then analyzed for tritium.

Gross beta activity was detected in 44 of the 60 samples collected. The indicator annual average gross beta activity was 1.5 pCi/L and the control average gross beta activity was 1.1 pCi/L. Refer to Figure 6 for the annual average gross beta activity for both indicator and control locations. No gamma activity was detected in any of the 60 samples collected. The 20 quarterly composite samples had 6 samples where tritium activity was detected. Any positive result less than 500 pCi/L is considered as background activity and not due to plant operations. The highest tritium activity was 221.3 pCi/L.

4.5

4

3.5

3

2.5

2

1.5

1

0.5

0

Year IndicatorControl Figure 6: Annual Average Gross Beta Activity in Water

8.2 Sediment Sampling shoreline sediments provides an indication of the accumulation of particulate radionuclides which may lead to an external radiation source to fishermen and swimmers from shoreline exposure. Sediment was sampled from two locations.

A total of four sediment samples were collected and were analyzed by gamma spectroscopy. The only radionuclide detected was naturally occurring potassium-40.

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8.3 Fish Fish are analyzed primarily to quantify the radionuclide intake by humans and secondarily to serve as indicators of radioactivity in the aquatic ecosystem. Fish are collected from two locations annually during the fishing season as required by the ODCM. Important sport or commercial species are targeted, and only the fillets are sent to the laboratory for analysis.

Eighteen (18) fish samples were collected and analyzed: 9 indicator and 9 control samples. The species were smallmouth bass, walleye, white sucker, red horse sucker, gizzard shad, yellow perch, freshwater drum, golden red horse, channel catfish, and white perch. Only naturally occurring potassium-40 was detected in these samples.

9.0 DIRECT RADIATION MONITORING Environmental radiation is measured directly at 27 locations around the PNPP site and at two control locations using thermoluminescent dosimeters (TLDs). The locations are positioned in two rings around the plant as well as at the site boundary. The inner ring is within a one-mile radius of the plant site; the outer ring is four to five miles from the plant.

The control locations are over ten miles from the plant in the two least prevalent wind directions. Each location has three TLDs, two of which are changed quarterly, and one that is changed annually.

A total of 261 TLDs were collected and analyzed. This includes 232 collected on a quarterly basis and 29 collected annually. Annual TLDs are not required per the ODCM and are used for supplemental data only.

The annual average dose for all indicator locations was 59.2 mrem versus 57.3 mrem for the control locations. The average quarterly dose for the indicator locations was 14.4 mrem versus 14.2 mrem for the control locations. Refer to Figure 7 for the average quarterly TLD dose rates for both indicator and control locations.

18 16 14 12 10 8

6 4

2 0

Year Indicator Control Figure 7: Average Quarterly TLD Dose

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10.0 CONCLUSION

There are no discernable trends or increase in radiological parameters when comparing current monitoring results to pre-operational studies. Non-routine analyses were not required during this reporting period. While you can note a slight increase in data of control vs indicator locations, there is no significant impact on the surrounding environment due to the operation of the Perry Nuclear Power Plant.

11.0 INTER-LABORATORY CROSS-CHECK COMPARISON PROGRAM The purpose of the Inter-laboratory Cross-Check Comparison Program is to provide an independent check on the vendor laboratory's analytical procedures. Samples with a known concentration of specific radionuclides are provided to the vendor laboratory. The vendor laboratory measures and reports the concentration of specified radionuclides.

The known values are then compared to the vendor results. Results consistently outside established acceptance criteria indicate a need to check instruments or procedures.

Regulatory Guide 4.15 [7] specifically requires that contractor laboratories that performed environmental measurement participate in the EPAs Environmental Radioactivity Laboratory Inter Comparison Studies Program, or an equivalent program.

The EPAs program is no longer funded or offered. The reason that the EPA program was referenced in the regulatory guide is that the EPA standards were traceable to National Bureau of Standards (now known as National Institute of Standards and Technology). In response, the vendor lab incorporated a program offered by Environmental Resource Associates (ERA), which covered the same analyses in the same matrix at the same frequency as the EPA program. ERA has received NIST accreditation as an equivalent program. In addition to comparison cross checks performed with ERA, the vendor laboratory routinely monitors the quality of their analyses by analyzing "spiked" samples (samples with a specific quantity of radioactive material present in them) and participating in the Department of Energys Mixed Analyte Performance Evaluation Program (MAPEP).

See Attachment 1 for the vendor Inter-Laboratory Cross-Check Comparison Program Results.

12.0 LAND USE CENSUS EXPOSURE PATHWAY To estimate radiation dose attributable to operation of the PNPP, the potential pathways through which public exposure can occur must be known. To identify these pathways, an Annual Land Use Census is performed as part of the REMP. During the census, PNPP personnel travel public roads within a five-mile radius of the plant to locate key radiological exposure pathways. These key pathways include the nearest resident and nearest garden in each of the ten meteorological land sectors that surround the plant.

The information obtained from the census is entered into a computer program used to assess hypothetical dose to members of the public. The predominant land use within the census area continues to be rural and/or agricultural.

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12.1 Introduction Each year a Land Use Census is conducted to identify the locations of the nearest available milking animal, garden (of greater than 500 square feet), and residence in each of the meteorological sectors that is over land. Information gathered during the Land Use Census is used for off-site dose assessment and to update sampling locations for the REMP. The census is conducted by traveling all roads within a five-mile radius of the plant site and recording and mapping the locations of the nearest resident, available milk animal, and vegetable garden.

The Land Use Census was conducted in August 2023. The census identified the garden, and residence locations identified in Table 4 and Table 5 that are depicted in Figure 8.

Note that the W, WNW, NW, NNW, N, and NNE sectors extend over Lake Erie and are not included in the survey. No location with an available milking animal was identified.

12.2 Discussion and Results In general, the predominant land use within the census area continues to be rural/

agricultural. In recent years, however, it has been noted that tracts of land once used for farming are now being developed as mini-industrial parks and residential housing. This is reflected in the loss of available milking animals within a five-kilometer radius of PNPP to support the REMP.

There were no changes to the REMP sampling locations compared to the 2022 Land Use Census. Refer to Figure 2, Figure 3, and Figure 4, for the REMP sampling locations.

Table 4 identifies the nearest residences, by sector, to the PNPP. There were no changes from the 2022 Land Use Census. Refer to Figure 8 for map locator numbers.

Table 4: Nearest Residence - By Sector Sector Location Address Miles from PNPP Map Locator Number NE 2348 W. Hemlock 0.9 11 ENE 2452 Antioch 1.1 12 E 2634 Antioch 1.1 10 ESE 2836 Antioch 1.1 4 SE 4671 North Ridge 1.3 15 SSE 4225 Red Mill Valley 1.1 16 S 3121 Center Rd. 0.9 7 SSW 3850 Clark 0.9 8 SW 3021 Perry Park 1.3 13 WSW 3460 Parmly 1.0 14

Table 5 lists the nearest gardens by sector to the PNPP consisting of at least 500 square feet. Refer to Figure 8 for map locator numbers.

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Table 5: Nearest Garden - By Sector Sector Location Address Miles from PNPP Map Locator Number NE 4384 Lockwood 0.7 1 ENE 4602 Lockwood 1.1 2 E 2626 Antioch 1 3 ESE 2836 Antioch 1.1 4 SE 4495 North Ridge 1.3 5 SSE 3119 Parmly 0.9 6 S 3121 Center 0.9 7 SSW 3300 Ohio St. 2.3 17 SW 2997 Perry Park 1.2 9 WSW 3460 Parmly 1 14

Figure 8: Land Use Census Map

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13.0 ANNUAL ENVIRONMENTAL OPERATING REPORT The NRC issued Amendment No. 178 to Facility Operating License No. NPF-58 on October 19, 2017. This amendment revises the PNPP Environmental Protection Plan (Non-radiological) (EPP) to clarify and enhance wording to remove duplicative or outdated program information, and to relieve the burden of submitting unnecessary or duplicative information to the NRC.

As a result of the above Amendment issued in October 2017, redundant program information is no longer required to be compiled and included in this report. This includes the sections: Clam/Mussel Monitoring, Herbicide Applications, and Special Reports which included National Pollutant Discharge Elimination System Permit exceedances, and the EPP from previous years.

14.0 ODCM NON-COMPLIANCES Sampling and analysis are performed for media types addressed in the Offsite Dose Calculation Manual. ODCM non-compliances occur when a sample required by the ODCM is not obtained and/or analyzed.

Sampling and analysis challenges may be experienced due to a multitude of reasons including environmental factors, loss of TLDs, contamination of samples, etc. To aid classification of sampling and analysis challenges experienced in 2023, the following three terms are used to describe the issues: Sample Anomalies (SA), Sample Deviation (SD), and Unavailable Samples (US).

Media that experienced downtime (i.e., air samplers or water samplers) during a surveillance period are classified a Sample Deviation.

Sample Anomalies are defined as errors that were introduced to a sample once it arrived in the laboratory or errors that prevent the sample from being analyzed as it normally would or may alter the outcome of the analysis (i.e., cross contamination, human error).

Sample Unavailability is defined as sample collection evolution with no available sample (i.e., food crop, TLD).

14.1 Non-Compliances There was one ODCM non-compliance for 2023. During the week of 3/2/2023 no iodine and particulate sample was obtained at the P-1 location (Chapel Road). This occurred due to an accident on 2/21/2023 when a vehicle collided with air sample station #1. The offsite air sample station was damaged when the vehicle struck it and a nearby power pole. This traffic accident was caused by non-site personnel.

Due to the nature of the accident the power had been cut off to the air sample station for an extended period of time. Air sampler station #1 was reassembled and restored with a complete pump rebuild, keypad, and turbine replacement. Temporary power was routed to the sample station from a nearby business the following week until the completion of restoration of power to a new power pole. This full evolution took around seven weeks:

First Energy installed a new power pole and meter, the Lake County Building

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Department inspected the electricians work and provided approval of compliance, then power was reconnected to the sample station and restoration of service was achieved.

This was captured in the stations Corrective Action Program.

14.2 Sampling Challenges There was sample unavailability at 3 garden locations for vegetation, specifically swiss chard, for the duration of the growing season. This was attributed to the excessive rains during the spring and a failed second planting of swiss chard in July at these locations.

Sample Deviation did occur due to the previous listed ODCM non-compliance. In the following 6 weeks after 2/21/23 accident that removed power to air sample station #1 (Chapel Road) reduced air sample run times occurred due to business temporary power availability not being continuous. This is noted in sample volume collected for this station.

This was captured in the stations Corrective Action Program.

15.0 CORRECTIONS TO PREVIOUS REPORTS There were no corrections identified for previous reports.

16.0 BIBLIOGRAPHY

1. Japan Atomic Energy Agency. [Online] November 06, 2021.

https://www.jaea.go.jp/english/04/ntokai/houkan/houkan_02.html.

2. Measurements of Radionuclides in the Environment Sampling and Analysis of Plutonium in Soil. s.l. : Nuclear Regulatory Commission, 1974. ADAMS Accession No. ML003739541.

3. NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors,. s.l. : Nuclear Regulatory Commission, April 1991. ADAMS Accession No. ML091050059.

4. NUREG-1301, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors,. s.l. : Nuclear Regulatory Commission, April 1991. ADAMS Accession No. ML091050061.

5. NRC Resource Page. [Online] [Cited: November 10, 2021.]

http://www.nrc.gov/about-nrc/radiation.html.

6. NUREG-0133, Preparation of Effluent Technical Specifications for Nuclear Power Plants. s.l. : Nuclear Regulatory Commission, 1987. ML091050057.

7. Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination) -- Effluent Streams and the Environment. s.l. : Nuclear Regulatory Commission, July, 2007.

ML071790506.

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8. ANSI 13.37, Environmental Dosimetry-Criteria for System Design and Implementation. s.l. : Health Physics Society (HPS), May, 2019.

9. Branch Technical Position, Revision 1. s.l. : NRC000096, Submitted March 30, 2012, November 1979.

10. Regulatory Guide 4.1, "Radiological Environmental Monitoring for Nuclear Power Plants", Revision 2. s.l. : Nuclear Regulatory Commission, 2009. ADAMS Accession No. ML091310141.

11. Regulatory Guide 4.13, Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications, Revision 2. s.l. :

Nuclear Regulatory Commission, June, 2019. ML19044A595.

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Attachment 1: Inter-Laboratory Cross Check Comparison Program Results

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Attachment 2: REMP Data Summary Reports

Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

0.054 0.056 3 0.058 0.061 Air Be-7 pCi/m3 28 N/A 28/28 24/24 1.0 4/4 4/4 0

0.038 - 0.068 0.038 - 0.068 SE 0.043 - 0.065 0.049 - 0.068

< LLD < LLD < LLD Air Co-58 pCi/m3 28 N/A 0/28 0/24 0/4 0

< LLD < LLD < LLD Air Co-60 pCi/m3 28 N/A 0/28 0/24 0/4 0

< LLD < LLD < LLD Air Cs-134 pCi/m3 28 0.005 0/28 0/24 0/4 0

< LLD < LLD < LLD Air Cs-137 pCi/m3 28 0.045 0/28 0/24 0/4 0

0.025 0.025 7 0.026 0.026 Air Gross Beta 3 0.0075 370/370 317/317 0.6 53/53 53/53 0 pCi/m 370 0.007 - 0.050 0.007 - 0.050 NE 0.009 - 0.048 0.011 - 0.049

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

< LLD < LLD <LLD Air I-131 pCi/m3 370 0.050 0/370 0/317 0/53 0

Broadleaf 544.6 544.9 2 719.1 543.7 Be-7 Vegetation 63 N/A 39/63 34/49 1.9 9/12 10/13 0 pCi/kg wet 158 - 1249 158 - 1249 ENE 292 - 1249 314 - 838

Broadleaf 4746.6 4693.9 16 4855.0 4931.2 K-40 Vegetation 63 N/A 63/63 49/49 0.9 12/12 14/14 0 pCi/kg wet 2768 - 8101 2768 - 7528 S 4044 - 6275 3333 - 8101

Broadleaf < LLD <LLD < LLD Co-58 Vegetation 63 N/A 0/63 0/49 0/14 0 pCi/kg wet

< LLD <LLD < LLD Broadleaf Co-60 Vegetation N/A 0/63 0/49 0/14 0 pCi/kg wet 63

Broadleaf < LLD <LLD < LLD Vegetation I-131 45 0/49 0/14 63 0/63 0 pCi/kg wet Broadleaf < LLD <LLD < LLD Vegetation Cs-134 45 0/63 0/49 0/14 pCi/kg wet 63 0

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

Broadleaf < LLD <LLD < LLD Cs-137 Vegetation 63 60 0/63 0/49 0/14 0 pCi/kg wet

1660.5 1565.4 25 1565.4 1755.6 Fish K-40 pCi/kg wet 18 N/A 18/18 9/9 0.6 9/9 9/9 0

605 - 3797 851 - 2184 NNW 851 - 2184 605 - 3797

< LLD < LLD < LLD Fish Mn-54 pCi/kg wet 18 94 0/18 0/9 0/9 0

< LLD < LLD < LLD Fish Fe-59 pCi/kg wet 18 195 0/18 0/9 0/9 0

< LLD < LLD < LLD Fish Co-58 pCi/kg wet 18 97 0/18 0/9 0/9 0

< LLD < LLD < LLD

Fish Co-60 97 0/18 0/9 0/9 0 pCi/kg wet 18

< LLD < LLD < LLD Fish Zn-65 pCi/kg wet 18 195 0/18 0/9 0/9 0

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

< LLD < LLD < LLD Fish Cs-134 pCi/kg wet 18 97 0/18 0/9 0/9 0

< LLD < LLD < LLD Fish Cs-137 pCi/kg wet 18 112 0/18 0/9 0/9 0

7589.0 7589.0 66 7607.5 N/A Sediment K-40 pCi/kg wet 4 N/A 4/4 4/4 1.4 2/2 N/A 0

6850 - 8291 6850 - 8291 NE 6983 - 8232 N/A

< LLD < LLD N/A Sediment Co-58 pCi/kg wet 4 50 0/4 0/4 N/A 0

N/A

< LLD < LLD N/A Sediment Co-60 pCi/kg wet 4 40 0/4 0/4 N/A 0

N/A

< LLD < LLD N/A Sediment Cs-134 pCi/kg wet 4 112 0/4 0/4 N/A 0

N/A

< LLD < LLD N/A Sediment Cs-137 pCi/kg wet 4 135 0/4 0/4 N/A 0

N/A

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

14.8 14.8 36 18.7 14.2 TLD (E) Direct mR/91 days 116 1.0 116/116 108/108 3.9 4/4 8/8 0

8.1 - 20.0 9.8 - 20.0 WSW 16.6 - 18.5 12.4 - 16.3

14.4 14.4 33 18.5 14.2 TLD (Q) Direct mR/91 days 116 1.0 116/116 108/108 4.5 4/4 8/8 0

10.3 - 20.6 10.3 - 20.6 S 16.7 - 20.3 12.4 - 16.8

TLD 59.0 59.2 29 75.6 57.3 mR/365 Direct 1.0 29/29 27/27 4.3 1/1 2/2 days 29 0 48.2 - 75.6 48.2 - 75.6 SSE 75.6 - 75.6 53.8 - 60.7

1.4 1.5 34 1.6 1.1 Water Gross Beta pCi/L 60 3 44/60 37/48 0.2 10/12 7/12 0

0.9 - 3.3 0.9 - 3.3 NW 1.0 - 3.3 1.0 - 1.4

195.9 195.9 59 221.3 <LLD Water H-3 pCi/L 20 1500 6/20 6/16 4.0 1/4 0/4 0

166.0 - 221.3 166.0 - 221.3 ENE 221.3 - 221.3

< LLD < LLD < LLD Water Mn-54 pCi/L 60 11 0/60 0/48 0/12 0

< LLD < LLD < LLD Water Fe-59 pCi/L 60 22 0/60 0/48 0/12 0

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

< LLD < LLD < LLD Water Co-58 pCi/L 60 11 0/60 0/48 0/12 0

< LLD < LLD < LLD Water Co-60 pCi/L 60 11 0/60 0/48 0/12 0

< LLD < LLD < LLD Zn-65 Water 60 22 0/60 0/48 0/12 0 pCi/L

< LLD < LLD < LLD Water Zr-95 pCi/L 60 22 0/60 0/48 0/12 0

< LLD < LLD < LLD Water Nb-95 0/60 pCi/L 60 11 0/48 0/12 0

< LLD < LLD < LLD Water Cs-134 pCi/L 60 11 0/60 0/48 0/12 0

< LLD < LLD < LLD Water Cs-137 pCi/L 60 13 0/60 0/48 0/12 0

1 Mean and range are based on detectable measurements only.

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Type, Total Location with Highest Annual Pathway Number of Lower Limit All Locations Mean1 Indicator Mean1 Mean Control Mean1 Number of Sampled Analyses of Detection Detected/Collected Detected/Collected Location # Mean1 Detected/Collected Non-routine (Units) Performed (LLD) Range1 Range1 Distance Detected/Collected Range Reported Direction Range Measurements

< LLD < LLD < LLD Water Ba-140 pCi/L 60 45 0/60 0/48 0/12 0

< LLD < LLD < LLD Water La-140 pCi/L 60 11 0/60 0/48 0/12 0

1 Mean and range are based on detectable measurements only.

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Attachment 3: 2022 REMP Detailed Data Report

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