Text

2023 Annual Radiological Environmental Operating Report
	ML24121A277
Person / Time
Site:	Limerick
Issue date:	04/30/2024
From:	Gillin M; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	LG-24-052
	Download: ML24121A277 (1)
	v • d • e

Constellation.

LG-24-052 April 30, 2024 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

2023 Annual Radiological Environmental Operating Report TS 6.9.1.7 In accordance with the requirements of Section 6.9.1.7 of Limerick Generating Station (LGS)

Units 1 and 2 Technical Specifications (TS) and Section 6.1 of the LGS Units 1 and 2 Offsite Dose Calculation Manual (ODCM), this letter submits the 2023 Annual Radiological Environmental Operating Report. This report provides the 2023 results for the Radiological Environmental Monitoring Program (REMP), as called for in the ODCM.

In assessing the data collected for the REMP, it has been concluded that the operation of LGS Units 1 and 2 had no adverse impact on the environment. No plant-produced fission or activation products were found in any pathway modeled by the REMP. The results of the groundwater protection program are also included in this report.

There are no commitments contained in this letter.

If you have any questions or require additional information, please contact Laura Lynch at 610-718-2003.

Respectfully, Michael F. Gillin Site Vice President - Limerick Generating Station Constellation Energy Generation, LLC

Attachment:

2023 Annual Radiological Environmental Operating Report cc:

Administrator, Region I, USNRC LGS USNRC Senior Resident Inspector B. Edwards, Inspector Region I, USNRC LGS Senior Project Manager-NRR, USNRC (w/attachment)

(w/attachment)

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR THE LIMERICK GENERATING STATION UNITS 1 AND 2 January 1 - December 31, 2023 Prepared by S. Roberts M. Bilenky A. M. Barnett CONSTELLATION GENERATION CONSTELLATION NUCLEAR GENERATION APRIL 2024

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 i

TABLE OF CONTENTS LIST OF FIGURES...................................................................................................................... ii LIST OF TABLES....................................................................................................................... iii I.

SUMMARY

.................................................................................................................................4 II. LIMERICK GENERATING STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM..........................................................................................13 II.A. INTRODUCTION..........................................................................................................13 II.B. PROGRAM.....................................................................................................................14 II.B.1 Objectives.................................................................................................................14 II.B.2 Sample Collection....................................................................................................14 II.B.3 Data Interpretation..................................................................................................16 II.B.4 Program Exceptions................................................................................................17 II.B.5 Program Changes....................................................................................................18 II.B.6 Compliance with 40CFR190 Limits.......................................................................18 II.C. RESULTS AND DISCUSSIONS....................................................................................20 II.C.1 Aquatic Environment...............................................................................................20 II.C.2 Atmospheric Environment.....................................................................................21 II.C.3 Terrestrial Environment........................................................................................22 II.C.4 Direct Radiation.......................................................................................................23 II.D. CONCLUSION................................................................................................................24 II.E. ERRATA..........................................................................................................................26 V. REFERENCES........................................................................................................................31 APPENDIX A Sample Locations for the REMP.....................................................................33 APPENDIX B Analysis Results for the REMP........................................................................45 APPENDIX C Quality Assurance Program..............................................................................64 APPENDIX D Land Use Census...............................................................................................92 APPENDIX E Annual RGPP Report for Limerick Generating Station................................95

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 ii LIST OF FIGURES Figure Title Page A-1 Limerick Generating Station Sample Locations, Environmental Sampling Locations Within 1 mile of the Limerick Generating Station, 2023..................................................37 A-2 Limerick Generating Station Sample Locations, Environmental Sampling Locations Between 1 and 5 miles from the Limerick Generating Station, 2023................................38 A-3 Limerick Generating Station Sample Locations, Environmental Sampling Locations Greater than 5 miles from the Limerick Generating Station, 2023....................................39 A-4 Gross Beta in Public Water for the Last Ten Years 2014-2024........................................40 A-5 Gross Beta in Air for the Last Ten Years 2014-2024........................................................41 A-6 Annual Trending of Air Activity (Gross Beta)..................................................................42 A-7 2023 Monthly Gross Beta Concentrations in Drinking Water, (16C2) Split between CGS and TBE....................................................................................................................43 A-8 2023 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers 11S1 and 11S2 analyzed by CGS and TBE.................................................44 D-1 Land Use Census Map, Limerick Generating Station Land Use Census...94 E-1 Routine Well Water Sample Locations for the Radiological Groundwater Protection Program Limerick Generating Station, 2023.....109 E-2 Routine Precipitation Sample Locations for the Radiological Groundwater Protection Program Limerick Generating Station, 2023..................................................110

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 iii LIST OF TABLES Table Title Page 1

Synopsis of 2023 Limerick Generating Station Radiological Environmental Monitoring Program..............................................................................................................................29 2

Annual Summary of Radioactivity in the Environs of the Limerick Generating Station..30 A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station......35 A-2 Locations of Environmental Dosimetry for the Limerick Generating Station..................36 B-1 Concentration of Tritium, Gamma Emitters and Gross Beta in Surface and Drinking Water..................................................................................................................................47 B-2 Concentration of Gamma Emitters in the Flesh of Edible Fish.........................................49 B-3 Concentration of Gamma Emitters in Sediment................................................................50 B-4 Concentration of Iodine-131 in Filtered Air......................................................................51 B-5 Concentration of Beta Emitters in Air Particulates............................................................53 B-6 Concentration of Gamma Emitters in Air Particulates......................................................55 B-7 Concentration of Gamma Emitters in Vegetation Samples...............................................56 B-8 Concentration of Gamma Emitters (including I-131) in Milk...........................................57 B-9 Typical MDA Ranges for Gamma Spectrometry..............................................................59 B-10 Typical LLDs for Gamma Spectrometry...........................................................................60 B-11 Quarterly DLR Results for Limerick Generating Station, 2023........................................61 C-1 Results of Participation in Cross Check Programs............................................................70 C-2 Results of Quality Assurance Program..............................................................................76 C-2a Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Iodine-131 in Filtered Air......................................................................86 C-2b Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Beta Emitters in Air Particulates............................................................89 C-3 Limerick Generating Station ODCM Required LLDs.......................................................91 D-1 Land Use Census, Distance of the Nearest Residence, Garden, Dairy, Meat Animal within a Five Mile Radius of Limerick Generating Station 2023......................................92 E-1 Locations of Onsite Radiological Groundwater Protection Program, Limerick Generating Station, 2023.................................................................................................108 E-2 Concentration of Radiostrontium in Groundwater...........................................................111 E-3 Concentration of Tritium in Groundwater.......................................................................112 E-4 Concentration of Tritium in Surface Water, Precipitation, and Subsurface Drainage.....113

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 4

I.

SUMMARY

The following sections of the summary are meant to help define key concepts, provide clarity, and give context of the monitoring program and results to the readers of this report.

Annual Reports The Nuclear Regulatory Commission (NRC) is the federal agency who has the role to protect public health and safety related to nuclear energy. Nuclear Power Plants have made many commitments to the NRC to ensure the safety of the public. As part of these commitments, they provide two reports annually to specifically address how the stations operation impacts the environment of the local communities. The NRC then reviews these reports and makes them available to the public. The names of the reports are the Annual Radioactive Effluent Release Report (ARERR) and the Annual Radiological Environmental Operating Report (AREOR).

The ARERR reports the results of the analyses of samples taken from the effluent release paths at the station. An effluent is a liquid or gaseous waste, containing plant-related radioactive material emitted at the boundary of the facility.

The AREOR reports the results of the analyses of samples obtained in the environment surrounding the station. Environmental samples include air, water, vegetation, and other sample types that are identified as potential pathways radioactivity can reach humans.

Graphic 1. Examples of Gaseous and Liquid Effluent Pathways

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 5

Graphic 1 demonstrates some potential exposure pathways from Limerick Generating Station.

The ARERR and AREOR together ensure Nuclear Power Plants are operating in a manner that is within established regulatory commitments meant to adequately protect the public.

Understanding Radiation Generally, radiation is defined as emitted energy in the form of waves or particles. Radiation has enough energy to displace electrons from an atom and it is termed ionizing; otherwise it is non-ionizing. Non-ionizing radiation includes light, heat given off from a stove, radiowaves, and microwaves. Ionizing radiation occurs in atoms and particles too small for the eye to see. So, what are atoms, and how does radiation come from them?

Graphic 2. Types of Radiation, from NASA Hubblesite An atom is the smallest part of an element that maintains the characteristics of that element.

Atoms are made up of three parts: protons, neutrons, and electrons.

Graphic 3. Structure of an Atom The number of protons in an atom determines the element. For example, a hydrogen atom will always have one proton while an oxygen atom will always have eight protons. The protons are clustered with the neutrons, forming the nucleus at the center of the atom. Orbiting around the nucleus are the relatively small electrons.

The IEl&ctromagnetic Spectrum Wavelen(Ji.h I n me1e-rs Alb out th* s lz*, ef:

B uildin,g 1;1 G rain S Prolozoan s Baomria Mol ecul!e,s Atoms of sugiar Akim te n1,1clel

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 6

Isotopes are atoms that have the same number of protons but different numbers of neutrons.

Different isotopes of an element will all have the same chemical properties, and many isotopes are radioactive while other isotopes are not radioactive. A radioactive isotope can emit radiation because it contains excess energy in its nucleus. Radioactive atoms and isotopes are also referred to as radionuclides and radioisotopes.

There are two basic ways that radionuclides are produced at a nuclear power plant. The first is fission, which creates radionuclides that are called fission products. Fission occurs when a very large atom, such as uranium-235 (U-235) or plutonium-239 (Pu-239), absorbs a neutron into its nucleus making the atom unstable. The unstable atom can then split into smaller atoms. When fission occurs, there is a large amount of energy released in the form of heat. A nuclear power plant uses the heat generated to boil water that spins turbines to produce electricity.

The second way a radionuclide is produced at a nuclear power plant is through a process called activation, and the radionuclides produced in this method are termed activation products. Pure water that passes over the fissioning atoms is used to cool the reactor and produce steam to turn the turbines. Although this water is considered to be very pure, there are always some contaminants within the water from material used in the plants construction and operation.

These contaminants are exposed to the fission process and may become activation products. The atoms in the water itself can also become activated and create radionuclides.

Over time, radioactive atoms will reach a stable state and no longer be radioactive. To do this, they must release their excess energy. This release of excess energy is called radioactive decay.

The time it takes for a radionuclide to become stable is measured in units called half-lives. A half-life is the amount of time it takes for half of the original radioactivity to decay. Each radionuclide has a specific half-life. Some half-lives can be very long and measured in years, while others may be very short and measured in seconds.

Graphic 4. Radioactive Decay Half-Life In the ARERR and the AREOR, you will see both man-made and naturally occurring radionuclides listed, such as potassium-40 (K-40, natural) and cobalt-60 (Co-60, man-made).

We are mostly concerned about man-made radionuclides because they can be produced as by-products when generating electricity at a nuclear power plant. It is important to note that there are also other ways man-made radionuclides are produced, such as detonating nuclear Activity 600 lOO Half-life The amount of time it takes for half of the original radioactivity to decay

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 7

weapons. Weapons testing has deposited some of the same man-made radionuclides into the environment as those generated by nuclear power, and some are still present today because of long half-lives.

Measuring Radiation There are four different but interrelated units for measuring radiation: radioactivity, exposure, absorbed dose, and dose equivalent. Together, they are used to scientifically report the amount of radiation and its effects on humans.

Radioactivity refers to the amount of ionizing radiation released by a material. The units of measure for radioactivity used within the AREOR and ARERR are the Curie (Ci).

Small fractions of the Ci often have a prefix, such as the microCurie (µCi), which means 1/1,000,000 of a Curie.

Exposure describes the amount of radiation traveling through the air. The units of measure for exposure used within the AREOR and ARERR are the Roentgen (R).

Traditionally, direct radiation monitors placed around the site are measured in milliRoentgen (mR), 1/1,000 of one R.

Absorbed dose describes the amount of radiation absorbed by an object or person. The units of measure for absorbed dose used within the AREOR and ARERR are the rad.

Noble gas air doses reported by the site are measured in millirad (mrad), 1/1,000 of one rad.

Dose equivalent (or effective dose) combines the amount of radiation absorbed and the health effects of that type of radiation. The units used within the AREOR and ARERR are the Roentgen equivalent man (rem). Regulations require doses to the whole body, specific organ, and direct radiation to be reported in millirem (mrem), 1/1,000 of one rem.

Sources of Radiation People are exposed to radiation every day of their lives and have been since the dawn of mankind. Some of this radiation is naturally occurring while some is man-made. There are many factors that will determine the amount of radiation individuals will be exposed to, such as where they live, medical treatments, etc. The average person in the United States is exposed to approximately 620 mrem each year. 310 mrem comes from natural sources and 310 from man-made sources. Graphic 5 shows what the typical sources of radiation are for an individual over a calendar year:

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 8

Graphic 5. Sources of Radiation Exposure in the U.S., from NCRP Report No. 160 The radiation from a nuclear power plant is included in the chart as part of the Industrial and Occupational fraction, <0.1%. The largest natural source of radiation is from radon, because radon gas travels in the air we breathe. Perhaps you know someone who had a CT scan at a hospital to check his or her bones, brain, or heart. CT scans are included in the chart as Medical Procedures, which make up the next largest fraction. Graphic 6 on the following page shows some of the common doses humans receive from radiation every year.

Sources of Radiation Exposure in the U.S.

Terrestrial (Soil) - 3%

Internal - 5%

D Natural Sources - 50%

~310 millirem (0.31 rem)

Sourc,e: NCRP Report No, 160 f2009t Industrial and Occupational

<0.1%

Nuclear Medicine 12%

D Manmade Sources - 50%

~310 millirem (0.31 rem)

Full report is available on the NCRPwe-bsite-atwww.NCRPonline.org

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 9

Graphic 6.Relative Doses from Radiation Sources, from EPA Radiation Doses and Sources RELATIVE DOSES FROM RADIATION SOURCES All doses from the National Councll on Radiation Protection & Measurements, Report No. 160 (unless otherwise denoted)

Whole-yCT 1,000 mlllirem (single procedure)

H.. dCT 200 mllllrem (single procedure)

Mammogram

~

4 2 millfrem (sin11le procedure)

From ICRP 2007 Radiation In the body 29 mllllrem (annual)

Ch*tx-ray 10 millirem (single procedure) mrem Upper GutrolntMtlruil x-ray ax.am with ftuoro* copy 600 mllllrem (single procedure)

Radon In average U.S. home 228 mllllrem (annual)

Co*mlc radiation llvlng In Denver (high elevation) approximately 80 mllllrem (annual)

Co*mlc radiation lfvln11 at...

level ( low elevatlon) approximately 30 mllllrem (annual)

Te,,...trlal radioactivity 21 mllUrem (annual}

Uvlng ""r

nudear Power station

< 1 mllllrem (annual)

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 10 Radiation Risk Current science suggests there is some risk from any exposure to radiation. However, it is very hard to tell whether cancers or deaths can be attributed to very low doses of radiation or by something else. U.S. radiation protection standards are based on the premise that any radiation exposure carries some risk.

The following graph is an example of one study that tries to relate risk from many different factors. This graph represents risk as Days of Lost Life Expectancy. All the categories are averaged over the entire population except Male Smokers, Female Smokers, and individuals that are overweight. Those risks are only for people that fall into those categories. The category for Nuclear Power is a government estimate based on all radioactivity releases from nuclear power, including accidents and wastes.

Graphic 7. Days of Lost Life Expectancy, Adapted from the Journal of American Physicians and Surgeons Volume 8 Number 2 Summer 2003 Smoking - Men Heart Disease Smoking - Women Cancer EverylOlbsoverweight Stroke Motor Vehicle Accident Air Pollution I

Radon Chemical Residue in Foods Drowning Hurricanes and Tornadoes Lightning Nuclear Power 0

Hurricanes and Tornadoes Lightning Nuclear Power I 0

0.2 Days of Lost Life Expectancy 500 1000 1500 2000 2500 3000 Days of Lost Life Expectancy 0.4 0.6 0.8 1.2 1.4 1.6 1.8

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 11 In 2023, the Limerick Generating Station released to the environment through the radioactive effluent liquid and gaseous pathways approximately 41 curies of noble gas, fission, and activation products and approximately 34 curies of tritium.

The dose from both liquid and gaseous effluents was conservatively calculated for the Maximum Exposed Member of the Public. The results of those calculations and their comparison to the allowable limits were as follows:

The calculated doses from the radiological effluents released from Limerick were a very small percentage of the allowable limits.

This report on the Radiological Environmental Monitoring Program, conducted for the Limerick Generating Station (LGS) by Constellation, covers the period 1 January 2023 through 31 December 2023. During that period, 1512 analyses were performed on 1,253 samples.

Surface and drinking water samples were analyzed for concentrations of tritium (H-3) and low-level iodine-131 (I-131). Drinking water samples were also analyzed for concentrations of total gross beta. Total gross beta activities detected were consistent with those detected in previous years. No other fission or activation products were detected.

Fish (predator and bottom feeder) samples were analyzed for concentrations of gamma-emitting nuclides. Concentrations of naturally occurring potassium-40 (K-40) were consistent with those detected in previous years. No fission or activation products were detected in fish.

Sediment samples were analyzed for concentrations of gamma-emitting nuclides. No station-produced fission or activation products were found in sediment. For results, discussion, and dose to member of the public calculation see Section II.B.6.

Air particulate samples were analyzed for concentrations of gross beta and gamma-emitting nuclides. Gross beta and cosmogenic naturally occurring beryllium-7 (Be-7) were detected at levels consistent with those detected in previous years. No fission or activation products were detected. High-sensitivity I-131 analyses were performed on weekly air samples. All results were less than the minimum detectable concentration.

The air monitoring systems employed in the nuclear industry have proven to be capable of detecting very low levels of activity in the atmosphere, as activity from both the Chernobyl and Fukushima events was detected at many of the worlds nuclear power plants, including Limerick Generating Station.

Cow milk samples were analyzed for concentrations of I-131 and gamma-emitting nuclides.

Concentrations of naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were found.

Broadleaf vegetation samples were analyzed for gamma-emitting nuclides. Only naturally occurring activity was detected. K-40 was detected in all samples. Be-7 was found in 23 of 34 samples. Radium-226 (Ra-226) was found in 4 of 34 samples. Thorium-232 (Th-232) was found in 7 of 34 samples. No activity due to plant operations were detected.

Review of the gamma spectroscopy results from the surface water samples located at the Limerick intake (24S1) and downstream of the 10 CFR 20.2002 permitted storage area showed no evidence of offsite radionuclide transport from the 2002 permitted storage area.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 12 Environmental ambient gamma radiation measurements were performed quarterly using Optically Stimulated Luminescence dosimeters (OSLD). Levels detected were consistent with those observed in previous years and no facility-related dose was detected. A review of the dosimetry data for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) indicates no direct dose was received.

A Radiological Groundwater Protection Program (RGPP) was established in 2006 as part of a fleetwide assessment of potential groundwater intrusion from the operation of the Station.

Results and Discussion of groundwater samples are covered in Appendix E.

In assessing the data gathered for this report and comparing these results with preoperational data, it was concluded that the operation of LGS had no adverse radiological impact on the environment.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 13 II. LIMERICK GENERATING STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM II.A. INTRODUCTION The Limerick Generating Station (LGS), consisting of two 3,515 MW boiling water reactors owned and operated by Constellation Corporation, is located adjacent to the Schuylkill River in Montgomery County, Pennsylvania. Unit No. 1 went critical on 22 December 1984. Unit No. 2 went critical on 11 August 1989. The site is located in Piedmont countryside, transversed by numerous valleys containing small tributaries that feed into the Schuylkill River. On the eastern riverbank, elevation rises from approximately 110 to 300 feet mean sea level (MSL). On the western riverbank elevation rises to approximately 50 feet MSL to the western site boundary.

A Radiological Environmental Monitoring Program (REMP) for LGS was initiated in 1971.

Review of the 1971 through 1977 REMP data resulted in the modification of the program to comply with changes in the Environmental Report Operating License Stage (EROL) and the Branch Technical Position Paper (Rev. 1, 1979). The preoperational period for most media covers the periods 1 January 1982 through 21 December 1984 and was summarized in a separate report. This report covers those analyses performed by Constellation Generation Solutions (CGS), Landauer, and Teledyne Brown Engineering (TBE)/GEL Laboratories (GEL) on samples collected during the period 1 January 2023 through 31 December 2023.

On 6 July 1996, a 10 CFR 20.2002 permit was issued to Limerick for storage of slightly contaminated soils, sediments and sludges obtained from the holding pond, cooling tower, and spray pond systems. These materials will decay to background while in storage. Final disposition will be determined at Station decommissioning.

On 21 July 2008, an ISFSI pad was put into service. The ISFSI is dry cask storage, where spent nuclear fuel is stored.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 14 II.B. PROGRAM II.B.1 Objectives A. Objective of the REMP The objectives of the REMP are to:

1. Provide data on measurable levels of radiation and radioactive materials in the site environs.

2. Validate the radioactive effluent control program by evaluating the relationship between quantities of radioactive material released from the plant and resultant radiation doses to individuals from principal pathways of exposure.

B. Implementation of the Objectives The implementation of the objectives is accomplished by:

1. Identifying significant exposure pathways

2. Establishing baseline radiological data of media within those pathways

3. Continuously monitoring those media before and during station operation to assess station radiological effects (if any) on man and the environment.

II.B.2 Sample Collection and Analysis Samples for the LGS REMP were collected for Constellation Nuclear by contractors to, or personnel of, CGS according to applicable procedures (Ref 6,12,13). Control locations are sample locations that are not expected to be impacted by plant operations and are used to determine a baseline in the environment for each type of sample. This section describes the general collection methods used to obtain environmental samples for the LGS REMP in 2023.

The locations of the individual sampling stations are listed in Table A-1 and A-2 and shown in Figures A-1, A-2, and A-3.

Analyses are performed in accordance with applicable procedures (Ref 7,10,11,13) and results are provided in Appendix B for primary REMP Analysis. Analysis results for quality assurance are provided in Appendix C. Analysis results for LGS RGPP are provided in Appendix E.

All Samples were collected and analyzed as required except as noted in section II.B.4 Program exceptions.

II.B.2.a Aquatic Environment The aquatic environment was evaluated by performing radiological analyses on samples of surface water, drinking water, fish, and sediment. Two-gallon water samples were collected monthly from composite samplers located at two surface water locations (13B1 and 24S1) and four drinking water locations (15F4, 15F7, 16C2, and 28F3). Control locations were 24S1 and 28F3. All samples were collected in new unused plastic bottles, which were rinsed at least twice

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 15 with source water prior to collection. Fish samples comprising of the flesh of two groups, bottom feeder (Carp / Northern Hogsucker / Northern Sucker / White Sucker) and predator (American Eel / Black Crappie / Bluegill / Brown Trout / Channel Catfish / Flathead Catfish / Green Sunfish / Smallmouth Bass / Yellow Perch), were collected semiannually at two locations, 16C5 and 29C1 (control). Sediment samples composed of recently deposited substrate were collected at three locations semiannually, 16B2, 16C4, and 33A2 (control).

II.B.2.b Atmospheric Environment The atmospheric environment was evaluated by performing radiological analyses on samples of air particulate and airborne iodine. Airborne iodine and particulate samples were collected and analyzed weekly at seven locations (6C1, 10S3, 11S1, 13S4, 14S1, 15D1, and 22G1). The control location was 22G1. Airborne iodine and particulate samples were obtained at each location, using a vacuum pump with charcoal and glass fiber filters attached. The pumps were run continuously and sampled air at the rate of approximately one cubic foot per minute. The filters were replaced weekly and sent to the laboratory for analysis.

II.B.2.c Terrestrial Environment Milk samples were collected biweekly at four locations (18E1, 19B1, 23F1, and 22B1) from January through August. Location 23F1 was the control location, and in August milk samples were no longer available due to the farmer selling his herd. In September, sample collection began at the new milk control location, 8G1. All samples were collected in new unused two-gallon plastic bottles from the bulk tank at each location, preserved with sodium bisulfite, and shipped promptly to the laboratory. Broadleaf vegetation was collected monthly during the growing season, at three locations (11S3, 13S3, and 31G1). The control location was 31G1.

Eight different kinds of vegetation samples were collected and placed in new unused plastic bags and sent to the laboratory for analysis.

II.B.2.d Ambient Gamma Radiation Direct Radiation measurements were made using Optically Stimulated Luminescence dosimeters. The OSLD locations were placed on and around the LGS site as follows:

A site boundary ring consisting of 16 locations (36S2, 3S1, 5S1, 7S1, 10S3, 11S1, 13S2, 14S1, 18S2, 21S2, 23S2, 25S2, 26S3, 29S1, 31S1, and 34S2) near and within the site perimeter representing fence post doses (i.e., at locations where the doses will be potentially greater than maximum annual off-site doses) from LGS releases.

An intermediate distance ring consisting of 16 locations (36D1, 2E1, 4E1, 7E1, 10E1, 10F3, 13E1, 16F1, 19D1, 20F1, 24D1, 25D1, 28D2, 29E1, 31D2, and 34E1) extending to approximately 5 miles from the site designed to measure possible exposures to close-in population. The balance of eight locations (5H1, 6C1, 9C1, 13C1, 15D1, 17B1, 20D1, and 31D1) represent control and special interest areas such as population centers, schools, etc. The control location was 5H1.

The specific dosimetry locations were determined by the following criteria:

1. The presence of relatively dense population,

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 16

2. Site meteorological data accounted for distance and elevation for each of the sixteen-22 1/2-degree sectors around the site, where estimated annual dose from LGS, if any, would be most significant,

3. On hills free from local obstructions and within sight of the vents (where practical);

4. And near the closest dwelling to the vents in the prevailing downwind direction.

Two dosimeters were placed at each location in a mesh basket tube located approximately three feet above ground level. The dosimeters were exchanged quarterly and sent to Landauer for analysis.

II.B.2.e 10 CFR 20.2002 Permit Storage Area In 1996, the Limerick Generating Station received NRC approval to store slightly contaminated soils, sludges, and sediments on site per the requirements of 10 CFR 20.2002. These materials will be stored until the end of the site's renewed operating license. At that time, the material will be evaluated along with the site for decommissioning. The area is approximately 1.5 acres in size and was evaluated to hold a maximum of 1.12E+06 cubic feet with no more than 7E+04 cubic feet added to the area in any single year. After each material placement on the storage area, the area is graded and seeded to prevent erosion. Since all groundwater movement is to the river, the use of the REMP surface water sampling program is used as a check on potential groundwater movement from the pad. In 2023, 0 cubic feet of cooling water sludge was placed on the permitted storage area.

II.B.2.f Independent Spent Fuel Storage Installation (ISFSI)

The results from the dosimeter location 36S2 were used to determine the direct radiation exposure to the nearest residence from the ISFSI pad.

II.B.3 Data Interpretation The radiological and direct radiation data collected prior to LGS becoming operational was used as a baseline with which these operational data were compared. For this report, LGS was considered operational at initial criticality. In addition, data was compared to previous years' operational data for consistency and trending. Several factors were important in the interpretation of the data:

1. Lower Limit of Detection and Minimum Detectable Concentration The lower limit of detection (LLD) is defined as the smallest concentration of radioactive material in a sample that would yield a net count (above background) that would be detected with only a 5% probability of falsely concluding that a blank observation represents a "real" signal. The LLD is intended as a before the fact estimate of a system (including instrumentation, procedure, and sample type) and not as an after-the-fact criteria for the presence of activity. All analyses are designed to achieve the required LGS detection limits for environmental sample analysis.

2. Reporting of Results

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 17 Gamma spectroscopy analyzes samples for the full range of nuclides. All nuclides that identified positive results for non-natural gamma emitters are reported. Each type of sample also looks for specific nuclides that must meet LLD requirements as described above. The required nuclides and their LLDs for each type of sample are provided in Table C-3.

Means and standard deviations of positive results were calculated. The standard deviations represent the variability of measured results for different samples rather than single analysis uncertainty.

3. Minimum Detectable Activity Many results in environmental monitoring occur at or below the minimum detectable activity (MDA). In this report, all results at or below the relevant MDA are reported as being

"<MDA indicating less than the MDA value of all non-natural gamma emitters. The CGS laboratory lists in Table B-9 for reference, the Typical MDA values historically observed in laboratory samples for each media type.

II.B.4 Program Exceptions For 2023 the LGS REMP had a sample recovery rate of greater than 99%. Program exceptions are listed below:

1. On 4/3/23, during routine weekly REMP water collection it was discovered that there was a leak observed on one of the pipes connected to the water sampler 16C2, which caused the water compositor to stop collecting as power and flow were disrupted.

Approximately one gallon was collected from the sampler and a grab sample was collected to ensure approximately two gallons total of sample was collected.

2. On 9/5/23, REMP milk samples were unavailable at the 23F1 Guest Farm location due to the farmer selling his herd. No samples were available at this location and were not available going forward.

3. On 9/11/23, REMP 13S3 garden did not produce enough quantity to meet programmatic REMP garden sample collection requirements. One sample was collected, and two samples were not able to be collected due to extreme heat and insect damage.

4. On 9/18/23, REMP air sample pumps were found to be not functioning as expected for air sampler location 11S1/11S2. No power was found at entire site and PECO was contacted to restore power.

5. On 10/06/23, TBE notified CGS that the cooler received from CGS with September REMP 16C2 QA water sample had been damaged during shipment. This resulted in the water samples being lost in transit. CGS was able to replace the sample utilizing archived samples, thus there was no impact to regulatory REMP program requirements.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 18

6. In 2023, LGS switched the REMP dosimetry and vendors from Mirion's TLD's to Landauer's OSLD's. The 2023 dosimetry data for the second through fourth quarter had numerous locations with net positive facility dose. The investigation into these positive facility doses concluded that the spreadsheet used to calculate annual facility dose was using the wrong control dosimeters to subtract out the extraneous dose.

When the spreadsheet was updated to use the correct control dosimeters per the vendor CGS procedure, there was no positive facility dose for 2023.

Each program exception was reviewed to understand the causes of the program exception.

Occasional equipment breakdowns were unavoidable. The overall sample recovery rate indicates that the appropriate procedures and equipment are in place to assure reliable program implementation.

II.B.5 Program Changes A new milk farm was added to the REMP sampling program. The old milk farm control was 23F1 located 26,505 feet SW of site and the new milk farm control is 8G1 located 54,504 feet ENE of site. The first missed sample from the old milk farm 23F1 was on 09/05/23. Sampling of the new milk farm started on 10/03/23.

New dosimetry was added to the REMP dosimetry program to replace older technology. LGS REMP program replaced Mirions Thermoluminescent dosimeters (TLD) with Landauers Optically Stimulated Luminescent dosimeters (OSLD) in January of 2023. Positive annual facility dose was seen for 2023. Upon further investigation it was identified that the wrong control dosimeters were being used in the calculations in the spreadsheet when LGS switched to Landauer. This was fixed and there is no positive annual facility dose for 2023.

II.B.6 Compliance with 40 CFR 190 Limits

1. Dose to Members of the Public at or Beyond Site Boundary Per the ODCM Control 6.2, the Annual Radioactive Effluent Release Report shall include an assessment of the radiation doses to the hypothetically highest exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources. The ODCM does not require population doses to be calculated. For purposes of this calculation the following assumptions were made:

Long term annual average meteorology X/Q and D/Q and actual gaseous effluent releases were used.

Gamma air dose, Beta air dose, Total Body, and Skin doses were attributed to noble gas releases.

Critical organ and age group dose were attributed to iodine, particulate, Carbon-14, and tritium releases.

100 percent occupancy factor was assumed.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 19

Dosimetry measurements obtained from the REMP for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) was used to determine direct radiation exposure.

The highest dose from the critical organ and critical age group for each release pathway were summed and added to the net dosimetry measurement from the nearest residence to the ISFSI for 40 CFR 190 compliance.

The maximum calculated dose to a real individual would not exceed 0.27 mrem (total body),

1.22 mrem (organ), or 0.27 mrem (thyroid).

All doses calculated were below all ODCM and 40 CFR Part 190 limits to a real individual.

Table 1, Total Annual Offsite-Dose Comparison to 40 CFR 190 Limits for LGS1 Whole Body Thyroid Max Other Organ Limit 25 mrem 75 mrem 25 mrem Gaseous2 - Noble Gas 1.08E-03 1.08E-03 1.81E-03 Gaseous - Particulates & Iodine 1.13E-04 1.79E-04 1.14E-04 Carbon-14 2.39E-01 2.39E-01 1.19E+00 Liquid 8.06E-03 4.91E-03 1.04E-02 Direct Shine 0

0 0

Total Site Dose 2.48E-01 2.45E-01 1.20E+00

% Contribution of Carbon-14 to Gaseous Dose 96 97 99 Nearby Facility 2.17E-02 2.17E-02 2.17E-02 Total w/Other Nearby Facility3 2.70E-01 2.66E-01 1.22E+00

% of Limit 1.08 0.36 4.90 1 Table 1 is a summation of Units to show compliance with 40 CFR Part 190 Limits.

2 Gaseous dose values in Table 1 include organ dose from Noble Gas, Iodine, Tritium, and particulates.

3 Other fuel cycle sources within 5 miles of the site are considered in this analysis.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 20 II.C. RESULTS AND DISCUSSIONS All the environmental samples collected during the year were analyzed using Constellation Generation Services laboratory procedures CY-ES-205 and CY-ES-206, except tritium, which was analyzed by GEL Laboratories (GL-RAD-A-002 REV# 24), in accordance with analytical method EPA 906.0 Modified, and Dosimetry analysis by Landauer. The analytical results for this reporting period are presented in Appendix B and are also summarized in Table 2. For discussion, the analytical results are divided into four categories. The categories are Aquatic Environment, Atmospheric Environment, Terrestrial Environment, and Direct Radiation. These categories are further divided into subcategories according to sample type (e.g. Surface Water/Drinking Water and Aquatic Organisms for Aquatic Environment).

II.C.1 Aquatic Environment The aquatic environment was evaluated by performing radiological analyses on samples of surface water, drinking water, fish, and sediment. Two-gallon water samples were collected monthly from composite samplers located at two surface water locations (13B1 and 24S1) and four drinking water locations (15F4, 15F7, 16C2, and 28F3). Control locations were 24S1 and 28F3. All samples were collected in new unused plastic bottles, which were rinsed at least twice with source water prior to collection. Fish samples comprising of the flesh of two groups, bottom feeder (Northern Hogsucker / Quillback / White Sucker/Carp/ Yellow Bullhead) and predator (Channel Catfish/ Flathead Catfish / Red-Breast Sunfish/ Bluegill and Pumpkinseed Sunfish /

Largemouth Bass / Smallmouth Bass / American Eel), were collected semiannually at two locations: 16C5 and 29C1 (control). Sediment samples composed of recently deposited substrate were collected at three locations semiannually: 16B2, 16C4, and 33A2 (control).

II.C.1.a Surface and Drinking Water Surface and drinking water samples were analyzed for concentrations of tritium (H-3), low level iodine-131 (I-131), and gamma-emitting nuclides. Drinking water samples were also analyzed for concentrations of total gross beta. Total gross beta activities detected were consistent with those detected in previous years. No other fission or activation products were detected.

Gamma and gross beta analysis were performed on all water samples on a monthly basis Composites are made from the weekly samples. Results for all water gamma and gross beta analyses are listed in Table B-1.

Tritium analysis was performed on all water samples on a quarterly basis. Composites are made from the weekly samples. Tritium data is given in Table B-1.

Review of the gamma spectroscopy results from the surface water samples located at the Limerick intake (24S1) and downstream of the 10 CFR 20.2002 permitted storage area showed no evidence of offsite radionuclide transport from the 2002 permitted storage area.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 21 A Radiological Groundwater Protection Program (RGPP) was established in 2006 as part of a fleetwide assessment of potential groundwater intrusion from the operation of the Station.

Results and Discussion of groundwater samples are covered in Appendix E.

II.C.1.b Aquatic Organisms Fish (predator and bottom feeder) samples were analyzed for concentrations of gamma-emitting nuclides. Concentrations of naturally occurring potassium-40 (K-40) were consistent with those detected in previous years. No fission or activation products were detected in fish.

II.C.1.c Shoreline Sediment Sediment samples were analyzed for concentrations of gamma-emitting nuclides. No station-produced fission or activation products were found in sediment. For results, discussion, and dose to member of the public calculation, see Section II.B.6.

II.C.2 Atmospheric Environment The atmospheric environment was evaluated by performing radiological analyses on samples of air particulate and airborne iodine. Airborne iodine and particulate samples were collected and analyzed weekly at seven locations (6C1, 10S3, 11S1, 13S4, 14S1, 15D1, and 22G1). The control location was 22G1. Airborne iodine and particulate samples were obtained at each location, using a vacuum pump with charcoal and glass fiber filters attached. The pumps were run continuously and sampled air at the rate of approximately one cubic foot per minute. The filters were replaced weekly and sent to the laboratory for analysis.

II.C.2.a Air Particulate Filters Air particulate samples were analyzed for concentrations of gross beta and gamma-emitting nuclides. Gross beta and cosmogenic, naturally occurring beryllium-7 (Be-7) were detected at levels consistent with those detected in previous years. No fission or activation products were detected.

Based on weekly comparisons, there was no statistical difference between the Control and Indicator radioactive particulate concentrations. The averages for the control samples were 0.022 pCi/m3, and the averages for the indicators were 0.021 pCi/m3 for the period of January to December 2023. Maximum weekly concentrations for each station were less than 0.045 pCi/m3.

The particulate filters from each sampling location were saved, and a 13-week composite was made. A gamma isotopic analysis was performed for each sampling location and corrected for decay. The results of these analyses are listed in Table B-6.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 22 II.C.2.b Air Iodine High-sensitivity I-131 analyses were performed on weekly air samples. All results were less than the minimum detectable concentration.

The air monitoring systems employed in the nuclear industry have proven to be capable of detecting very low levels of activity in the atmosphere, as activity from both the Chernobyl and Fukushima events was detected at many of the worlds nuclear power plants, including Limerick Generating Station.

Radioiodine cartridges are placed at seven locations. These cartridges are changed and analyzed each week. No positive analytical results were found on any sample. A list of values for these cartridges is given in Table B-4.

II.C.3 Terrestrial Environment II.C.3.a Vegetation Broadleaf vegetation was collected monthly, during the growing season, at three locations (11S3, 13S3, and 31G1). The control location was 31G1. Ten different kinds of vegetation samples were collected and placed in new unused plastic bags and sent to the laboratory for analysis.

Broadleaf vegetation samples were analyzed for gamma-emitting nuclides. Only naturally occurring activity was detected. K-40 was detected in all samples. Be-7 was found in 25 of 36 samples. Radium-226 (Ra-226) was found in 6 of 36 samples. Thorium-232 (Th-232) was found in 15 of 36 samples. No activity due to plant operations were detected. Data for Non-Natural Gamma Emitters is given in Table B-7.

II.C.3.b Milk Milk samples were collected biweekly at four locations (18E1, 19B1, 23F1, and 22B1) from January through August. Location 23F1 was the control location and in August milk samples were no longer available due to the farmer selling their herd. In September, sample collection began at the new milk control location, 8G1. All samples were collected in new, unused two-gallon plastic bottles from the bulk tank at each location, preserved with sodium bisulfite, and shipped promptly to the laboratory.

In ODCM revision 35, location 25C1 will be removed as a sample location and replaced with location 22B1, and location 23F1 will be removed as a control location and replaced with location 8G1. The associated map will also be updated to include this new location. The map shown in Figure A-3 is the new map that was generated and will be included in ODCM revision

35.

Cow milk samples were analyzed for concentrations of I-131 and gamma-emitting nuclides.

Concentrations of naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were found. Gamma isotopic data is given in Table B-8.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 23 II.C.4 Direct Radiation Environmental ambient gamma radiation measurements were performed quarterly using optically stimulated luminescent dosimeters (OSLDs). Levels detected were consistent with those observed in previous years, and no facility-related dose was detected. A review of the dosimetry data for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) indicates no direct dose was received.

Ambient Gamma Radiation Direct Radiation measurements were made using optically stimulated luminescent dosimeters (OSLD). The OSLD locations were placed on and around the LGS site as follows:

A site boundary ring consisting of 16 locations (36S2, 3S1, 5S1, 7S1, 10S3, 11S1, 13S2, 14S1, 18S2, 21S2, 23S2, 25S2, 26S3, 29S1, 31S1, and 34S2) near and within the site perimeter representing fence post doses (i.e., at locations where the doses will be potentially greater than maximum annual off-site doses) from LGS releases.

An intermediate distance ring consisting of 16 locations (36D1, 2E1, 4E1, 7E1, 10E1, 10F3, 13E1, 16F1, 19D1, 20F1, 24D1, 25D1, 28D2, 29E1, 31D2, and 34E1) extending to approximately 5 miles from the site designed to measure possible exposures to close-in population.

The balance of eight locations (5H1, 6C1, 9C1, 13C1, 15D1, 17B1, 20D1, and 31D1) representing control and special interest areas such as population centers, schools, etc. The control location was 5H1.

The specific dosimetry locations were determined by the following criteria:

1. The presence of relatively dense population.

2. Site meteorological data where estimated annual dose from LGS, if any, would be most significant. This data takes into account distance and elevation for each of the sixteen-22 1/2-degree sectors around the site.

3. On hills free from local obstructions and within sight of the vents (where practical)

4. Near the closest dwelling to the vents in the prevailing downwind direction.

Two dosimeters were placed at each location in a mesh basket tube located approximately three feet above ground level. The dosimeters were exchanged quarterly and sent to Landauer for analysis.

10 CFR 20.2002 Permit Storage Area In 1996, the Limerick Generating Station received NRC approval to store slightly contaminated soils, sludges, and sediments on site per the requirements of 10 CFR 20.2002. These materials will be stored until end of the site's renewed operating license. At that time the material will be evaluated along with the site for decommissioning. The area is approximately 1.5 acres in size

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 24 and was evaluated to hold a maximum of 1.12E+06 cubic feet with no more than 7E+04 cubic feet added to the area in any single year. After each material placement on the storage area, the area is graded and seeded to prevent erosion. Since all groundwater movement is to the river, the use of the REMP surface water sampling program is used as a check on potential groundwater movement from the pad. In 2023, 0 cubic feet of cooling water sludge was placed on the permitted storage area.

Independent Spent Fuel Storage Installation (ISFSI)

The results from the dosimeter location 36S2 were used to determine the direct radiation exposure to the nearest residence from the ISFSI pad.

II.D. CONCLUSION In assessing the data gathered for this report and comparing these results with preoperational data, it was concluded that the operation of LGS had no adverse radiological impact on the environment.

In 2023, the Limerick Generating Station released to the environment through the radioactive effluent liquid and gaseous pathways approximately 41 curies of noble gas, fission, and activation products and approximately 34 curies of tritium.

The dose from both liquid and gaseous effluents was conservatively calculated for the Maximum Exposed Member of the Public. The results of those calculations and their comparison to the allowable limits are located in Table 2, Limerick Generating Station Site Dose Summary.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 25 Table 2, Limerick Generating Station Site Dose Summary1 Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Liquid Effluents Limit 3 mrem 3 mrem 3 mrem 3 mrem 6 mrem Total Body Dose2 1.39E-04 5.37E-03 2.56E-03 1.62E-06 8.06E-03

% Of Limit 0.005 0.179 0.085

<0.001 0.134 Limit 10 mrem 10 mrem 10 mrem 10 mrem 20 mrem Maximum Organ Dose3 1.83E-04 6.75E-03 3.42E-03 1.62E-06 1.04E-02

% Of Limit 0.002 0.068 0.034

<0.001 0.052 Gaseous Effluents Limit 10 mrad 10 mrad 10 mrad 10 mrad 20 mrad Gamma Air Dose4 3.45E-04 6.35E-04 1.07E-04 5.54E-05 1.14E-03

% Of Limit 0.003 0.006 0.001 0.001 0.006 Limit 20 mrad 20 mrad 20 mrad 20 mrad 40 mrad Beta Air Dose5 2.04E-04 3.97E-04 6.39E-05 3.24E-05 6.97E-04

% Of Limit 0.001 0.002

<0.001

<0.001 0.002 Limit 5 mrem 5 mrem 5 mrem 5 mrem 10 mrem NG Total Body Dose6 3.28E-04 6.02E-04 1.02E-04 5.28E-05 1.08E-03

% Of Limit 0.007 0.012 0.002 0.001 0.011 Limit 15 mrem 15 mrem 15 mrem 15 mrem 30 mrem NG Skin Dose7 5.43E-04 1.01E-03 1.68E-04 8.76E-05 1.81E-03

% Of Limit 0.004 0.007 0.001 0.001 0.006 Limit 15 mrem 15 mrem 15 mrem 15 mrem 30 mrem Maximum Organ Dose8 1.04E-05 5.99E-05 4.05E-05 6.78E-05 1.79E-04

% Of Limit

<0.001

<0.001 0.001 1 Table 2 demonstrates compliance with 10 CFR Part 50, App. I Limits. Carbon-14 dose is not included in this table.

2 Adult, LGS Outfall 3 Teenager, LGS Outfall, Liver 4 Site Boundary, All Age Groups 5 Site Boundary, All Age Groups 6 Site Boundary, All Age Groups 7 Site Boundary, All Age Groups 8 Child, Vegetation, Thyroid

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 26 II.E. 2022 AREOR ERRATA 2022 Land Use Census

1. The 2022 Land Use Census had the incorrect closest farms in the Distance of the Nearest Residence, Garden, Dairy, Meat Animal within a Five Mile Radius of Limerick Generating Station (Distance in feet) 2022 AREOR Table D-1. This was discovered on 02/23/24. The closest ESE Meat Animal was 5,181 ft instead of 12,264. The closest NNW Garden was 6,976 ft instead of 6,473 ft (no longer existing) (IR 04761927).

Table D-1 Distance of the Nearest Residence, Garden, Dairy, Meat Animal within a Five Mile Radius of Limerick Generating Station (Distance in feet) 2022 Sector Residence Garden (1)

Dairy Animal Meat Animal N

3,109 3,333 24,775*

10,077 NNE 2,706 3,792 3,792 NE 3,469 13,917 3,469 ENE 3,231 8,241 4,070 E

2,864 4,117 3,890 ESE 3,434 3,434 12,264 5,181 SE 3,928 6,376 10,903 SSE 5,403 6,912

- 8,177 S

4,347 6,103 22,114*

9,933 SSW 5,063 5,732 10,390* 7,729 SW 3,251 6,319 20,011*

23,145 WSW 3,799 4,507 14,177*

4,084 W

3,627 8,886 14,123 WNW 3,685 12,022 NW 3,619 8,200 NNW 5,050 6,473 6,976 12,065

Denotes current REMP Dairy sample location

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 27 N

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January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 28

2. On April 4, 2023, it was identified that the 2022 AREOR had data missing from Table B-3, "Concentration of Gamma Emitters in Sediment". June 2022 sediment samples were reported to the customer as required during the 2022 sample period and met program monitoring requirements. The oversight in the 2022 AREOR occurred as a result of the lab transitioning to a new database at the same time as these samples were received in the old database. Since the program requirements were met and no non-natural radionuclides were detected, there are no program impacts as a result of this event.

Table B-3 Concentration of Gamma Emitters in Sediment (Results in units of pCi/kg (wet) +/- 2)

Sample Code Sample Date Gamma Emitters 16B2 6/3/2022 SSE Sector 11/14/2022 16C4 6/3/2022 SSE Sector 11/14/2022 33A21 6/3/2022 NNW Sector 11/14/2022 1 Control Location

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 29 Table 1 Synopsis of 2023 Limerick Generating Station Radiological Environmental Monitoring Program Sample Type Sampling Frequency1 Number of Locations Number Collected Analysis Analysis Frequency1 Number Analyzed Aquatic Environment Surface Water, Drinking Water MC 6

72 Gamma MC 72 Gross Beta MC 48 Tritium QC 24 Fish2 SA 2

8 Gamma SA 8

Shoreline Sediment SA 3

6 Gamma SA 6

Atmospheric Environment Air Iodine3 W

7 3637 I-131 W

3637 Air Particulates4 W

7 3637 Gross Beta W

3637 Gamma QC 28 Terrestrial Environment Milk5 M/BW 58 87 Gamma W

87 Vegetation6 M

3 349 Gamma M

349 Dosimetry Q

40 320 Direct Radiation Q

320 1 W=Weekly, BW=Biweekly (15 days), M=Monthly (31 days), Q=Quarterly (92 days), SA=Semiannual, A=Annual, C=Composite 2 Twice during fishing season including at least four species.

3 The collection device contains activated charcoal.

4 Beta counting is performed >= 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following filter change. Gamma spectroscopy performed on quarterly composite of weekly samples.

5 Bi-Weekly when cows are on pasture. Monthly when cows are not on pasture.

6 Monthly during growing season. Samples include broad leaf vegetation.

7 Sample sites 11S1 and 11S2 had power failure; samples were collected but were considered qualitative results only.

8 Currently, there are 4 milk sample locations after 23F1 samples were unavailable and 23F1 was replaced with 8G1.

9 Only one type of vegetation was available at 13S3 in September 2023 due to insect damage.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 30 Table 2 Annual Summary of Radioactivity in the Environs of the Limerick Generating Station Medium or Pathway Sampled (Unit of Measurement)

Type and Total Number of Analyses Performed Lower Limit of Detection (LLD)

Indicator Locations Mean (F)/Range1 Location with Highest Annual Mean Name/Distance &

Direction2 Highest Annual Mean (F) / Range1 Control Locations Mean (F)/Range Aquatic Environment Surface Water, Drinking Water (pCi/L)

Gross Beta (48) 4 3.0 (36/36)

(1.6-4.3)

AQUA Water 15F4 13.9 km 3.7 (12/12)

(3.0 - 4.3) 2.9 (12/12)

(1.9 - 3.9)

Atmospheric Environment Air Particulates (10-2 pCi/m3)

Gross Beta (363) 1.0 2.1 (311/311)

(0.61-3.95)

Longview Road 14S1 1.0 km SSE 2.22 (52/52)

(0.72-3.9) 2.23 (52/52)

(0.59-4.1)

Dosimetry (mrem/Qtr)

OSLD (320)

NA 17.7 (312/312)

(11.8-27.8) 500KV Substation 13S2 0.04 km SE 26.6 (8/8)

(25.3-27.8) 22.4 (8/8)

(21.2-24.4) 1 Mean and range based upon detectable measurements only. Fraction (F) of detectable measurements at specified location is indicated in parentheses.

2 From the center point of the containment building

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 31 V. REFERENCES (1)

Environmental Report Operating License Stage, Limerick Generating Station, Units 1 and 2, Volumes 1-5 Philadelphia Electric Company (2)

NUREG-1302 Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors (3)

Branch Technical Position Paper, Regulatory Guide 4.8, Revision 1, November 1979 (4)

Pre-operational Radiological Environmental Monitoring Program Report, Limerick Generating Station Units 1 and 2, 1 January 1982 through 21 December 1984, Teledyne Isotopes and Radiation Management Corporation (5)

CY-LG-170-301 Current Revision, Limerick Generating Station Units 1 and 2 Offsite Dose Calculation Manual (6)

Constellation Generation Solutions Analytical Sampling Procedures

a. CY-ES-214, Collection of RGPP Water Samples for Radiological Analysis

b. CY-ES-237, Air Iodine and Air Particulate Sample Collection for Radiological

c. CY-ES-239, CGS Collection Exchange of Field Dosimeters for Radiological Analysis

d. CY-ES-241, Vegetation Sample Collection for Radiological Analysis

e. CY-ES-242, Soil and Sediment Sample Collection for Radiological Analysis

f. CY-ES-247, Precipitation Sampling and Collection for Radiological Analysis (7)

Constellation Generation Solutions Analytical Procedures

a. CY-ES-204, Sample Preparation for Gamma Analysis

b. CY-ES-205, Operation of HPGE Detectors with the Genie PC Counting System

c. CY-ES-206, Operation of the Tennelec S5E Proportional Counter

d. CY-ES-246, Sample Preparation for Gross Beta Analysis (8)

Limerick Generating Station 2023 Land use Survey (9)

CY-AA-170-1000, Radiological Environmental Monitoring Program (REMP) and Meteorological Program Implementation.

(10)

Teledyne Browne Engineering, (TBE) 2018 Analysis Procedures Current Revisions

a. TBE-2001 Alpha Isotopic and Pu-241

b. TBE-2006 Iron-55 Activity in Various Matrices, if needed

c. TBE-2007 Gamma Emitting Radioisotope Analysis

d. TBE-2008 Gross Alpha and/or Gross Beta Activity in Various Matrices

d. TBE-2011 Tritium Analysis in Drinking Water by Liquid Scintillation

e. TBE-2012 Radioiodine in Various Matrices

f. TBE-2013 Radionickel Activity in Various Matrices g.TBE-2018 Radiostrontium Analysis by Chemical Separation

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 32 (11)

GEL Laboratory Procedures

a. GL-RAD-A-002 Tritium

b. GL-RAD-A-022 Ni-63

c. GL-RAD-A-004 Sr89/90, Liquid

d. GL-RAD-A-040 Fe-55 (12)

Normandeau Associates, Inc. (NAI) Sampling Procedures Current Revisions for Collection of Fish and Bottom Sediment for Radiological Analysis

a. ER6 COLLECTION OF FISH SAMPLES FOR RADIOLOGICAL ANALYSIS

b. ER7 COLLECTION OF SEDIMENT SAMPLES FOR RADIOLOGICAL ANALYSIS (13)

Landauer Incorporated, Proprietary procedures Current Revision (14)

Teledyne Browne Engineering Environmental Services, 4th Quarter 2023 Quality Assurance Report, January - December 2023 (15)

GEL 2023 Annual Environmental Quality Assurance Report for the Radiological Environmental Monitoring Program (REMP)

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 33 APPENDIX A Sample Locations for the REMP Appendix A contains information concerning the environmental samples that were collected during this operating period.

Sample locations and specific information about individual locations for the Limerick Generating Station are given in Table A-1 and A-2. Figure A-1 shows the Environmental Sampling Locations within 1 mile of the Limerick Generating Station. Figure A-2 shows the Environmental Sampling Locations Between 1 and 5 miles and Figure A-3 shows the locations Greater than 5 miles from Limerick Generating Station

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 34 TABLE OF CONTENTS - SAMPLING LOCATIONS Table Title Page A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station......35 A-2 Locations of Environmental Dosimetry for the Limerick Generating Station..................36 Figure Title Page A-1 Limerick Generating Station Sample Locations, Environmental Sampling Locations Within 1 mile of the Limerick Generating Station, 2023..................................................37 A-2 Limerick Generating Station Sample Locations, Environmental Sampling Locations Between 1 and 5 miles from the Limerick Generating Station, 2023................................38 A-3 Limerick Generating Station Sample Locations, Environmental Sampling Locations Greater than 5 miles from the Limerick Generating Station, 2023....................................39 A-4 Gross Beta in Public Water for the Last Ten Years 2014-2024........................................40 A-5 Gross Beta in Air for the Last Ten Years 2014-2024........................................................41 A-6 Annual Trending of Air Activity (Gross Beta)..................................................................42 A-7 2023 Monthly Gross Beta Concentrations in Drinking Water, (16C2) Split between CGS and TBE....................................................................................................................43 A-8 2023 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers 11S1 and 11S2 analyzed by CGS and TBE as 10-2pCi/m3.........................44

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 35 TABLE A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station Distance and Direction from Site Station Description (KM)

(Miles)

(Sector) 10S3 Keen Rd 0.8 0.5 E

11S1 Across street from Limerick Training Center 0.6 0.4 ESE 11S3 Across street from Limerick Training Center 0.6 0.3 ESE 13B1 PA American 2.8 1.7 SE 13S3 500 Kv Sub on Longview Rd 0.4 0.2 SE 13S4 Longview Rd 0.4 0.2 SE 14S1 Longview Rd 1.0 0.6 SSE 15D1 Spring City Substation 5.1 3.2 SE 15F4 AQUA Water Company 13.9 8.6 SE 15F7 Phoenixville Water Treatment Plant 10.2 6.3 SSE 16B2 Down River from Plant Discharge Area 2.2 1.3 SSE 16C2 PA American 4.3 2.7 SSE 16C4 Down River from Plant Discharge Area 3.5 2.2 SSE 16C5 LGS Discharge Area Downstream of Discharge 18E1 Miller Farm 6.8 4.2 S

19B1 Kolb Farm 3.1 2.0 SSW 22B1 Pigeon Creek Farm 6.1 3.8 SW 22G1 Manor Substation (Control) 28.5 17.7 SW 23F11 Guest Farm (Control) 8.1 5.0 SW 24S1 LGS Intake Building (Control) 0.3 0.2 SW 8G11 Knechel Farm (Control) 16.6 10.3 ENE 28F3 Pottstown Water (Control) 9.4 5.8 WNW 29C1 Area not influenced by Plant Discharge (Control)

Upstream of Intake 31G1 Jollyview Farm (Control) 21.9 13.6 NW 33A2 Upstream from Plant Discharge Area (Control) 1.4 0.8 NNW 6C1 Limerick Airport 3.4 2.1 Ne 11S2 Across street from Limerick Training Center (QC collocated with 11S1) 0.6 0.4 ESE 1 23F1 Discontinued during 2023 and replaced by 8G1

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 36 TABLE A-2 Locations of Environmental Dosimetry for the Limerick Generating Station Distance and Direction from Site Location Location Description (KM)

(Miles)

(Sector)

Inner Ring 36S2 Evergreen & Sanatoga Road 1.0 0.6 N

3S1 Sanatoga Road 0.7 0.4 NNE 5S1 Possum Hollow Road 0.7 0.4 NE 7S1 LGS Training Center 0.9 0.6 ENE 10S3 Keen Road 0.8 0.5 E

11S1 LGS Information Center 0.6 0.4 ESE 13S2 500 KV Substation 0.7 0.4 SE 14S1 Longview Road 1.0 0.6 SSE 18S2 Rail Line along Longview Road 21S2 Near Intake Building 23S2 Transmission Tower 25S2 Sector Site Boundary 26S3 Met. Tower #2 29S1 Sector Site Boundary 31S1 Sector Site Boundary 34S2 Met. Tower #1 0.4 0.3 0.9 0.7 0.6 0.9 0.4 0.9 0.3 0.2 0.5 0.5 0.4 0.5 0.3 0.6 S

SSW SW WSW W

WNW NW NNW Outer Ring

36D1 Siren Tower No. 147 5.6 3.5 N

2E1 Laughing Waters GSC 7.7 4.8 NNE

4E1 Neiffer Road 7.7 4.8 NE

7E1 Pheasant Road 6.9 4.3 ENE

10E1 Royersford Road 6.3 4.0 E

10F3 Trappe Substation 9.0 5.6 ESE

13E1 Vaughn Substation 6.9 4.3 SE

16F1 Pikeland Substation 8.1 5.0 SSE

19D1 Snowden Substation 5.6 3.5 S

20F1 Sheeder Substation 8.4 5.2 SSW

24D1 Porters Mill Substation 6.4 4.0 SW

25D1 Hoffecker & Keim Streets 6.4 4.0 WSW

28D2 W. Cedarville Road 6.2 4.0 W

29E1 Prince Street 8.0 5.0 WNW

31D2 Popular Substation 34E1 Varnell Road 6.2 7.4 4.0 4.6 NW NNW Control &

Special Interest 5H1 C Birch Substation (control) 6C1 Limerick Airport 9C1 Reed Road 13C1 King Road 15D1 Spring City Substation 17B1 Linfield Substation 20D1 Ellis Woods Road 31D1 Lincoln Substation 40.0 3.4 3.5 4.6 5.1 2.6 5.0 4.8 24.8 2.1 2.2 2.8 3.2 1.6 3.0 3.0 NE NE E

SE SE S

SSW WNW

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 37 Figure A-1 Limerick Generating Station Sample Locations Environmental Sampling Locations Within 1 mile of the Limerick Generating Station, 2023 RIDGF. 0 /KE N

E SE s

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 38 Figure A-2 Limerick Generating Station Sample Locations Environmental Sampling Locations Between 1 and 5 miles from the Limerick Generating Station, 2023

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 39 Figure A-3 Limerick Generating Station Sample Locations Environmental Sampling Locations Greater than 5 miles from the Limerick Generating Station, 2023

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 40 Figure A-4 Gross Beta in Public Water for the Last Ten Years 2014-2024 J

' *- 4 u

0.

07;14 01115 071S 01116 07/16 01 '17 07;17 01 118 07118 0l,19 07119 01/20 07/20 01/21 07'21 01'22 07122 01/23 07'23 0124

+ 15F4 (I) + 15F7 (I) 16C2 (I) 28f 3 (C) + Control monthly mean + Indicator monthly mean

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 41 Figure A-5 Gross Beta in Air for the Last Ten Years 2014-2024 75 m so E

' -u i.. 25 0

0714 0115 0715 01 '!6 07,16 OJI!?

07117 0118 07/18 01 IJ9 07 19 01,20 07 20 01 21 07/21 01 22 07 22 01,2l O?r23 01,24

+ 10S3(1) + 11S1 (I) 11S2(QC)(I) 13S4~) + 14S1 (I) + 1501 (I) 22G1 (C) + ~1 (ij + Controlmonlhfymean lrr:licatormonthfymean

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 42 Figure A-6 Annual Trending of Air Activity (Gross Beta) 0.00E+00 5.00E-03 1.00E-02 1.50E-02 2.00E-02 2.50E-02 3.00E-02 3.50E-02 4.00E-02 4.50E-02 1/9/2023 2/9/2023 3/9/2023 4/9/2023 5/9/2023 6/9/2023 7/9/2023 8/9/2023 9/9/2023 10/9/2023 11/9/2023 12/9/2023 2023 Weekly Gross Beta Concentrations in Air Particulate Samples Collected for the Limerick Radiological Environmental Monitoring Program as pCi/m3 6C1 10S3 11S1 14S1 15D1 22G1 13S4 T

T

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 43 Figure A-7 2023 Monthly Gross Beta Concentrations in Drinking Water, (16C2)

Split between CGS and TBE 3.16 2.51 2.21 3.18 2.34 2.80 1.80 1.60 2.25 2.66 2.93 2.31 3.26 3.44 3

3.95 2.92 3.23 0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 9.00 10.00 1/31/2023 2/28/2023 3/31/2023 4/30/2023 5/31/2023 6/30/2023 7/31/2023 8/31/2023 9/30/2023 10/31/2023 11/30/2023 12/31/2023 pCi/Liter Calendar CGS TBE

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 44 Figure A-8 2023 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers 11S1 and 11S2 analyzed by CGS and TBE as 10-2pCi/m3

~

7.50 6.50 5.50 E 4.50 u :,;

u.....

~ 3.50 2.50 1.50 0.50 1/9/2023 2/9/2023 3/9/2023 4/9/202.3 5/9/2023 6/9/2023 7/9/2023 8/9/2023 9/9/2023 10/9/2023 11/9/2023 12/9/2023 Calendar 11s1 -

11s20

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 45 APPENDIX B Analysis Results for the REMP Appendix B is a presentation of the analytical results for the Limerick Generating Station radiological environmental monitoring programs.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 46 TABLE OF CONTENTS - ANALYTICAL RESULTS Table Title Page B-1 Concentration of Tritium, Gamma Emitters and Gross Beta in Surface and Drinking Water..................................................................................................................................47 B-2 Concentration of Gamma Emitters in the Flesh of Edible Fish.........................................49 B-3 Concentration of Gamma Emitters in Sediment................................................................50 B-4 Concentration of Iodine-131 in Filtered Air......................................................................51 B-5 Concentration of Beta Emitters in Air Particulates Onsite Samples..................................53 B-6 Concentration of Gamma Emitters in Air Particulates......................................................55 B-7 Concentration of Gamma Emitters in Vegetation Samples...............................................56 B-8 Concentration of Gamma Emitters (including I-131) in Milk...........................................57 B-9 Typical MDA Ranges for Gamma Spectrometry...............................................................59 B-10 Typical LLDs for Gamma Spectrometry............................................................................60 B-11 Quarterly DLR Results for Limerick Generating Station 2023..........................................61

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 47 Table B-1 Concentration of Gamma Emitters, Tritium, and Gross Beta in Surface and Drinking Water (Results in units of pCi/L +/- 2)

Sample Code Sample Date Gamma Emitters Tritium (2)

Gross Beta (3) 13B1 Vincent Dam 1/31/2023 ND ND 2/27/2023 ND ND 4/3/2023

<191 ND 5/1/2023 ND ND 5/30/2023 ND ND 7/3/2023

<119 ND 7/31/2023 ND ND 8/28/2023 ND ND 10/2/2023

<109 ND 10/30/2023 ND ND 11/27/2023 ND ND 1/2/2024

<153 ND 16C2 PA American 1/31/2023 ND 3.16+/-0.82 2/27/2023 ND 2.51+/-0.82 4/3/2023

<188 2.21+/-0.80 5/1/2023 ND 3.18+/-0.84 5/30/2023 ND 2.34+/-0.72 7/3/2023

<118 2.80+/-0.82 7/31/2023 ND 1.80+/-0.74 8/28/2023 ND 1.60+/-0.77 10/2/2023

<108 2.24+/-0.79 10/30/2023 ND 2.66+/-0.82 11/27/2023 ND 2.93+/-0.84 1/2/2024

<154 2.31+/-0.80 24S11 LGS Intake 1/31/2023 ND ND 2/27/2023 ND ND 4/3/2023

<189 ND 5/1/2023 ND ND 5/30/2023 ND ND 7/3/2023

<118 ND 7/31/2023 ND ND 8/28/2023 ND ND 10/2/2023

<114 ND 10/30/2023 ND ND 11/27/2023 ND ND 1/2/2024

<153 ND

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 48 Table B-1 Concentration of Gamma Emitters, Tritium, and Gross Beta in Surface and Drinking Water (Results in units of pCi/L +/- 2)

Sample Code Sample Date Gamma Emitters Tritium (2)

Gross Beta (3) 15F4 AQUA Water 1/31/2023 ND 3.17+/-0.81 2/27/2023 ND 3.67+/-0.88 4/3/2023

<190 3.25+/-0.86 5/1/2023 ND 3.25+/-0.84 5/30/2023 ND 4.15+/-0.84 7/3/2023

<163 4.14+/-0.90 7/31/2023 ND 3.41+/-0.85 8/28/2023 ND 4.33+/-0.94 10/2/2023

<115 3.92+/-0.89 10/30/2023 ND 3.64+/-0.88 11/27/2023 ND 3.95+/-0.91 1/2/2024

<155 3.01+/-0.84 15F7 Phoenixville 1/31/2023 ND 1.98+/-0.73 2/27/2023 ND 2.76+/-0.83 4/3/2023

<189 2.46+/-0.81 5/1/2023 ND 2.96+/-0.82 5/30/2023 ND 3.48+/-0.79 7/3/2023

<157 2.97+/-0.83 7/31/2023 ND 3.14+/-0.83 8/28/2023 ND 3.15+/-0.87 10/2/2023

<115 3.53+/-0.86 10/30/2023 ND 3.08+/-0.84 11/27/2023 ND 3.92+/-0.91 1/2/2024

<155 2.63+/-0.81 28F31 Pottstown Water 1/31/2023 ND 2.98+/-0.80 2/27/2023 ND 2.26+/-0.80 4/3/2023

<155 1.85+/-0.76 5/1/2023 ND 3.27+/-0.84 5/30/2023 ND 3.23+/-0.77 7/3/2023

<115 3.25+/-0.85 7/31/2023 ND 2.30+/-0.77 8/28/2023 ND 2.89+/-0.86 10/2/2023

<109 2.59+/-0.81 10/30/2023 ND 3.65+/-0.88 11/27/2023 ND 3.89+/-0.91 1/2/2024

<155 3.01+/-0.84 1 Control Location 2 Tritium Result for the quarterly composite 3 ND, No Data, analysis not required

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 49 Table B-2 Concentration of Gamma Emitters in the Flesh of Edible Fish (Results in units of pCi/kg (wet) +/- 2)

Sample Code Sample Date Sample Type Gamma Emitters 16C5 5/17/2023 Predator Fish SE Sector 5/17/2023 Bottom Feeder 10/18/2023 Predator Fish 10/18/2023 Bottom Feeder 29C11 5/16/2023 Predator Fish WNW Sector 5/16/2023 Bottom Feeder 10/11/2023 Predator Fish 10/11/2023 Bottom Feeder 1 Control Location

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 50 Table B-3 Concentration of Gamma Emitters in Sediment (Results in units of pCi/kg (dry) +/- 2)

Sample Code Sample Date Gamma Emitters 16B2 5/19/2023 SSE Sector 11/8/2023 16C4 5/19/2023 SSE Sector 11/8/2023 33A21 5/19/2023 NNW Sector 11/8/2023 1 Control Location

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 51 Table B-4 Concentration of Iodine-131 in Filtered Air (Results in units of 10-3 pCi/m3 +/- 2)

Start Coll date End Coll date 6C1 10S3 11S1 14S1 15D1 22G11 13S4 1/3/2023 1/9/2023 1/9/2023 1/17/2023 1/17/2023 1/23/2023 1/23/2023 1/31/2023 1/31/2023 2/7/2023 2/7/2023 2/13/2023 2/13/2023 2/20/2023 2/20/2023 2/27/2023 2/27/2023 3/6/2023 3/6/2023 3/13/2023 3/13/2023 3/20/2023 3/20/2023 3/27/2023 3/27/2023 4/3/2023 4/3/2023 4/10/2023 4/10/2023 4/17/2023 4/17/2023 4/24/2023 4/24/2023 5/1/2023 5/1/2023 5/8/2023 5/8/2023 5/15/2023 5/15/2023 5/22/2023 5/22/2023 5/30/2023 5/30/2023 6/5/2023 2

6/5/2023 6/12/2023 6/12/2023 6/19/2023 6/19/2023 6/26/2023 6/26/2023 7/3/2023

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 52 Table B-4 Concentration of Iodine-131 in Filtered Air (Results in units of 10-3 pCi/m3 +/- 2)

Start Coll date End Coll date 6C1 10S3 11S1 14S1 15D1 22G11 13S4 7/3/2023 7/10/2023 7/10/2023 7/17/2023 7/17/2023 7/24/2023 7/24/2023 7/31/2023 7/31/2023 8/7/2023 8/7/2023 8/14/2023 8/14/2023 8/21/2023 8/21/2023 8/28/2023 8/28/2023 9/5/2023 9/5/2023 9/11/2023 9/11/2023 9/18/2023 2

9/18/2023 9/25/2023 9/25/2023 10/2/2023 10/2/2023 10/9/2023 10/9/2023 10/16/2023 10/16/2023 10/23/2023 10/23/2023 10/30/2023 10/30/2023 11/6/2023 11/6/2023 11/13/2023 11/13/2023 11/20/2023 11/20/2023 11/27/2023 11/27/2023 12/4/2023 12/4/2023 12/11/2023 12/11/2023 12/19/2023 12/19/2023 12/27/2023 12/27/2023 1/2/2024 1 Control Location 2 Air sample was unavailable due to power failure at 11S1.

<MDA (I-131)

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 53 Table B-5 Concentration of Beta Emitters in Air Particulates (Results in units of 10-2 pCi/m3 +/- 2)

Date 6Cl 10S3 11S1 14S1 15D1 22Gl (Control)!

13S4 1/912023 2.00E-02

~

2.29E-03 1.97E-02

~

2.28E-03 l.90E-02

~

2.26E-03 I.SSE-02 2.23E-03 UOE-02 2.0SE-03 2.06E-02 =

2.25E-03 l.90E-02

= 2.31E-03 1/1712023 2.46E-02

~

l.99E-03 2.52E-02

~

2.0IE-03 2.08E-02

~

l.88E-03 2.04E-02 l.86E-03 l.60E-02 U IE-03 2.45E-02 l.99E-03 l.97E-02

=

l.84E-03 1/2312023 l.46E-02

~

2.!0E-03 l.18E-02

~

l.99E-03 I.IOE-02

~

2.07E-03 l.27E-02 2.03E-03 l.30E-02 2.04E-03 l.29E-02 2.04E-03 9.71E-03

=

l.90E-03 1/3112023 2.37E-02

~

l.98E-03 2.27E-02

~

l.95E-03 l.88E-02

~

l.83E-03 2.35E-02 l.98E-03 2.33E-02 l.97E-03 2.40E-02 l.99E-03 2.IOE-02

=

l.90E-03 2/712023 2.68E-02

~

2.27E-03 2.37E-02

~

2.17E-03 2.15E-02

~

2.IOE-03 2.59E-02 2.24E-03 2.43E-02 2.19E-03 2.60E-02 2.23E-03 2.29E-02

= 2.15E-03 2/1312023 3.59E-02

~

2.76E-03 3.22E-02

~

2.73E-03 2.84E-02

~

2.61E-03 3.23E-02 2.73E-03 3.09E-02 2.69E-03 3.12E-02 =

2.71E-03 3.24E-02

= 2.73E-03 2/2012023 2.13E-02

~

2.04E-03 2.08E-02

~

2.04E-03 l.88E-02

~

l.94E-03 2.14E-02 2.04E-03 2.09E-02 2.02E-03 2.15E-02 =

2.05E-03 2.07E-02

= 2.0IE-03 2/2712023 2.45E-02

~

2.09E-03 2.46E-02

~

2.22E-03 2.08E-02

~

2.IOE-03 2.5!E-02 2.24E-03 2.26E-02 2.16E-03 2.47E-02 =

2.21E-03 2.27E-02

= 2.16E-03 3/612023 1.48E-02

~

1.87E-03 l.55E-02

~

l.90E-03 l.29E-02

~

l.80E-03 l.42E-02 1.85E-03 l.36E-02 l.&4E-03 l.26E-02 =

1.85E-03 l.39E-02

= l.84E-03 3/1312023 L19E-02

~

1.77E-03 l.54E-02

~

l.91E-03 U ?E-02

~

l.85E-03 1.48E l.89E-03 USE l.76E-03 U7E l.91E-03 L39E l.85E-03 3/2012023 2.00E-02

~

2.03E-03 2.17E-02

~

2.09E-03 1.67E-02

~

l.93E-03 2.21E-02 2.IIE-03 2.06E-02 2.07E-03 2.22E-02 =

2.0SE-03 l.99E-02

= 2.04E-03 3/2712023 2.l7E-02

~

2.05E-03 2.30E-02

~

2.09E-03 2.09E-02

~

2.00E-03 2.59E-02 2.17E-03 2.52E-02 2.15E-03 2.69E-02 =

2.l lE-03 2.42E-02

= 2.12E-03 41312023 2.40E-02

~

2.!4E-03 2.57E-02

~

2.19E-03 2.26E-02

~

2.IOE-03 2.74E-02 2.25E-03 2.37E-02 2.13E-03 2.76E-02 2.25E-03 2.41E-02

= 2.15E-03 411012023 2.20E-02

~

2.!7E-03 2.62E-02

~

2.30E-03 2.29E-02

~

2.19E-03 2.73E-02 2.33E-03 2.63E-02 2.31E-03 2.65E-02 2.33E-03 2.37E-02

= 2.22E-03 411712023 2.53E-02

~

2.!7E-03 2.62E-02

~

2.20E-03 2.32E-02

~

2.IOE-03 2.92E-02 2.28E-03 2.87E-02 2.29E-03 2.54E-02 2.ISE-03 2.50E-02

= 2.16E-03 412412023 l.72E-02

~

l.93E-03 l.82E-02

~

1.97E-03 l.76E-02

~

l.95E-03 l.96E-02 2.0lE-03 l.75E-02 l.95E-03 2.03E-02 2.0SE-03 l.84E-02

=

l.97E-03 5/112023 9.67E-03

~

l.66E-03 l.21E-02

~

1.76E-03 9.80E-03

~

1.67E-03 l.34E-02 l.82E-03 l.26E-02 l.78E-03 l.llE-02 =

l.73E-03 l.15E-02

= l.74E-03 5/812023 6.78E-03

~

I.SlE-03 7.27E-03

~

l.54E-03 7.68E-03

~

l.55E-03 7.04E-03 l.53E-03 7.15E-03 l.53E-03 5.85E-03 =

l.48E-03 6.09E-03

= 1.48E-03 5/1512023 2.21E-02

~

2.20E-03 2.30E-02

~

2.23E-03 2.62E-02

~

2.33E-03 2.35E-02 2.24E-03 2.lSE-02 2.17E-03 2.55E-02 =

2.25E-03 2.28E-02

= 2.22E-03 5/2212023 1.48E-02

~

l.86E-03 1.70E-02

~

l.96E-03 l.52E-02

~

l.88E-03 1.86E-02 2.00E-03 1.74E-02 l.96E-03 1.86E-02 =

l.99E-03 l.87E-02

= 2.00E-03 5/3012023 l.64E-02

~

1.75E-03 l.63E-02

~

1.75E-03 1.49E-02

~

1.70E-03 l.65E-02 l.76E-03 l.54E-02 l.74E-03 1.83E-02 =

1.82E-03 1.76E-02

= 1.79E-03 6/512023 l.58E-02

~

2.07E-03 l.52E-02

~

2.05E-03 l.59E-02

~

2.08E-03 UIE-02 2.04E-03 l.65E-02 2.lOE-03 l.66E-02 =

2.16E-03 l.50E-02

= 2.04E-03 6/1212023 2.0lE-02

~

2.07E-03 2.05E-02

~

2.08E-03 l.95E-02

~

2.05E-03 2.lSE-02 2.12E-03 2.09E-02 2.0SE-03 2.25E-02 =

2.lOE-03 2.00E-02

= 2.07E-03 6/1912023 l.66E-02

~

l.93E-03 l.62E-02

~

l.91E-03 1.41E-02

~

l.84E-03 l.60E-02 l.91E-03 l.64E-02 l.94E-03 l.96E-02 =

I.SSE-03 l.64E-02

= l.93E-03 6/2612023 9.77E-03

~

1.74E-03 l.05E-02

~

1.77E-03 8.42E-03

~

l.68E-03 9.42E-03 l.72E-03 9.45E-03 l.72E-03 S.91E-03 2.00E-03 l.06E-02

=

l.77E-03 7/312023 2.13E-02

~

2.09E-03 2.03E-02

~

2.05E-03 2.07E-02

~

2.07E-03 2.4SE-02 2.lOE-03 l.95E-02 2.03E-03 2.34E-02 2.16E-03 2.31E-02

= 2.15E-03 7/1012023 l.97E-02

~

2.06E-03 2.15E-02

~

2.IIE-03 2.03E-02

~

2.08E-03 2.53E-02 2.24E-03 2.31E-02 2.17E-03 2.70E-02 2.29E-03 2.35E-02

= 2.lSE-03

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 54 Table B-5 Concentration of Beta Emitters in Air Particulates (Results in units of 10-2 pCi/m3 +/- 2)

Date 6Cl I0S3 llSI 14Sl

! SDI 22G I (Control)1 13S4 7/1712023 2.66E-02

+/-

2.23E-03 2.S5E-02

+/-

2.29E-03 2.49E-02

+/-

2.ISE-03 2.84E-02 = 2.2SE-03 2.89E-02 = 2.JOE-03 3.19E-02 = 2.35E-03 2.7SE-02

+/-

2.27E-03 712412023 2.38E-02

+/-

2.24E-03 2.42E-02

+/-

2.25E-03 2.ISE-02

+/-

2.ISE-03 2.61E-02 = 2.JIE-03 2.62E-02 = 2.JOE-03 2.53E-02 = 2.27E-03 2.64E-02

+/-

2.32E-03 7/3112023 2.14E-02

+/-

2.IOE-03 2.25E-02

+/-

2.13E-03 2.02E-02

+/-

2.05E-03 2.60E-02 = 2.24E-03 2.56E-02 = 2.24E-03 2.67E-02 = 2.32E-03 2.53E-02

+/-

2.22E-03 8/712023 l.71E-02

+/-

l.94E-03 l.76E-02

+/-

l.96E-03 l.77E-02

+/-

l.96E-03 l.92E-02 = 2.02E-03 l.94E-02 = 2.02E-03 l.96E-02 = 2.00E-03 l.95E-02

+/-

2.03E-03 8/1412023 2.IIE-02

+/-

2.0SE-03 2.12E-02

+/-

2.0SE-03 2.0IE-02

+/-

2.04E-03 2.51E-02 = 2.21E-03 2.40E-02 = 2.17E-03 2.36E-02 = 2.19E-03 2.4SE-02

+/-

2.20E-03 8/2112023 l.71E-02

+/-

2.0IE-03 l.95E-02

+/-

2.IOE-03 l.73E-02

+/-

l.98E-03 l.96E-02 = 2.05E-03 l.99E-02 = 2.05E-03 2.0SE-02 = 2.04E-03 2.19E-02

+/-

2.ISE-03 8/2812023 2.06E-02

+/-

2.09E-03 2.20E-02

+/-

2.14E-03 2.06E-02

+/-

2.09E-03 2.41E-02 = 2.21E-03 2.43E-02 = 2.21E-03 2.JIE-02 = 2.17E-03 2.16E-02

+/-

2.12E-03 9/512023 2.IOE-02

+/-

l.90E-03 2.27E-02

+/-

l.95E-03 2.20E-02

+/-

l.92E-03 2.50E-02 = 2.0IE-03 2.29E-02 = l.97E-03 2.41E-02 = 2.04E-03 2.2SE-02

+/-

l.95E-03 9/1112023 3.20E-02

+/-

2.74E-03 3.95E-02

+/-

2.96E-03 3.IOE-02

+/-

2.72E-03 3.93E-02 = 2.95E-03 3.91E-02 = 2.95E-03 4.IIE-02 = 2.99E-03 3.57E-02

+/-

2.85E-03 9/1&12023 l.78E-02

+/-

l.97E-03 2.13E-02

+/-

2.09E-03 2

2.12E-02 = 2.IIE-03 2.24E-02 = 2.12E-03 2.19E-02 = 2.12E-03 2.0IE-02

+/-

2.0SE-03 912512023 l.25E-02

+/-

1.S4E-03 l.49E-02

+/-

l.93E-03 l.31E-02

+/-

l.S9E-03 l.67E-02 =

l.99E-03 l.60E-02 = l.99E-03 l.76E-02 = 2.02E-03 l.52E-02

+/-

l.93E-03 101212023 l.lSE-02

+/-

1.S4E-03 l.25E-02

+/-

l.S6E-03 l.07E-02

+/-

l.SOE-03 l.40E-02 =

l.92E-03 l.21E-02 = l.85E-03 l.41E-02 =

l.92E-03 l.lSE-02

+/-

l.84E-03 101912023 2.27E-02

+/-

2.20E-03 2.79E-02

+/-

2.36E-03 2.66E-02

+/-

2.32E-03 2.9SE-02 = 2.41E-03 2.83E-02 = 2.36E-03 3.05E-02 = 2.42E-03 2.76E-02

+/-

2.35E-03 10/16/2023 l.70E-02

+/-

2.03E-03 l.S7E-02

+/-

2.07E-03 1.57E-02

+/-

l.96E-03 l.95E-02 = 2.09E-03 l.92E-02 = 2.09E-03 2.00E-02 = 2.l.3E-03 l.SJE-02

+/-

2.05E-03 10123/2023 9.53E-03

+/-

l.77E-03 l.09E-02

+/-

1.S4E-03 S.64E-03

+/-

l.76E-03 l.OSE-02 =

l.84E-03 9.45E-03 = l.7SE-03 l.14E-02 =

l.SIE-03 l.12E-02

+/-

l.86E-03 10130/2023 l.99E-02

+/-

2.IIE-03 2.52E-02

+/-

2.28E-03 2.12E-02

+/-

2.15E-03 2.55E-02 = 2.29E-03 2.JIE-02 = 2.21E-03 2.43E-02 = 2.25E-03 2.39E-02

+/-

2.24E-03 11/612023 2.24E-02

+/-

2.IIE-03 2.53E-02

+/-

2.20E-03 2.41E-02

+/-

2.16E-03 2.93E-02 =

2.33E-03 2.61E-02 = 2.24E-03 2.9SE-02 = 2.39E-03 2.76E-02

+/-

2.27E-03 11/1312023 2.29E-02

+/-

2.ISE-03 2.40E-02

+/-

2.21E-03 2.28E-02

+/-

2.17E-03 2.76E-02 =

2.32E-03 2.5SE-02 = 2.25E-03 2.59E-02 = 2.2,6E-03 2.51E-02

+/-

2.24E-03 11/20(2023 2.59E-02

+/-

2.32E-03 3.00E-02

+/-

2.44E-03 2.70E-02

+/-

2.35E-03 3.21E-02 =

2.50E-03 2.91E-02 = 2.41E-03 2.89E-02 = 2.35E-03 3.21E-02

+/-

2.50E-03 1112712023 l.52E-02

+/-

l.93E-03 l.63E-02

+/-

l.97E-03 l.38E-02

+/-

l.SSE-03 l.SOE-02 = 2.03E-03 l.64E-02 = l.97E-03 l.76E-02 = 2.0.3E-03 l.61E-02

+/-

l.96E-03 121412023 2.98E-02

+/-

2.39E-03 3.19E-02

+/-

2.45E-03 2.S2E-02

+/-

2.34E-03 3.26E-02 = 2.47E-03 2.89E-02 = 2.JSE-03 3.62E-02 = 2.62E-03 3.14E-02

+/-

2.43E-03 1211112023 2.16E-02

+/-

2.0SE-03 2.38E-02

+/-

2.16E-03 2.12E-02

+/-

2.07E-03 2.69E-02 = 2.25E-03 3.05E-02 = 2.37E-03 2.56E-02 = 2.21E-03 2.44E-02

+/-

2.ISE-03 1211912023 l.97E-02

+/-

l.SSE-03 2.04E-02

+/-

l.S5E-03 2.04E-02

+/-

1.S4E-03 2.66E-02 = 2.04E-03 2.83E-02 = 2.IOE-03 2.41E-02 =

l.97E-03 2.29E-02

+/-

l.92E-03 12127/2023 l.58E-02

+/-

l.SIE-03 l.S7E-02

+/-

l.SSE-03 l.74E-02

+/-

1.S4E-03 2.13E-02 =

l.97E-03 2.26E-02 = 2.00E-03 2.00E-02 = l.87E-03 l.96E-02

+/-

l.92E-03 1/212024 l.31E-02

+/-

2.0?E-03 1.37E-02

+/-

2.03E,.03 l.39E.02

+/-

2.04E,.03 l.63E-02

+/-

2.14E-03 l.90E-02

+/-

2.26E-03 l.SOE-02

+/-

2.32E-03 l.l2E-02

+/-

2.09E-03

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 55 Table B-6 Concentration of Gamma Emitters in Air Particulates (Results in units of 10-3 pCi/m3 +/- 2)

Start Date Stop Date 6C1 10S3 11S1 14S1 15D1 22G11 13S4 1/3/2023 4/3/2023 4/3/2023 7/3/2023 7/3/2023 10/2/2023 10/2/2023 1/2/2024 1 Control Location

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 56 Table B-7 Concentration of Gamma Emitters in Vegetation Samples (Results in units of pCi/kg (wet) +/- 2)

Sample Code Sample Date Sample Type Gamma Emitters 11S3 LGS 6/13/2023 Mustard Greens Information Ctr 6/13/2023 Cabbage 6/13/2023 Brussels Sprouts 7/18/2023 Collards 7/18/2023 Cabbage 7/18/2023 Broccoli 8/15/2023 Swiss Chard 8/15/2023 Collards 8/15/2023 Cucumber 9/11/2023 Swiss Chard 9/11/2023 Collards 9/11/2023 Cucumber 13S3 LGS 6/13/2023 Mustard Greens 500 KV Yard 6/13/2023 Cabbage 6/13/2023 Brussels Sprouts 7/18/2023 Collards 7/18/2023 Cabbage 7/18/2023 Broccoli 8/15/2023 Cucumber 8/15/2023 Swiss Chard 8/15/2023 Collards 9/11/2023 Swiss Chard 9/11/2023 ND2 9/11/2023 ND2 31G11 Jollyview Farm 6/13/2023 Cabbage 6/13/2023 Broccoli 6/13/2023 Cauliflower 7/18/2023 Squash Leaves 7/18/2023 Cucumber 7/18/2023 Butternut Squash 8/15/2023 Squash Leaves 8/15/2023 Cucumber 8/15/2023 Butternut Squash 9/11/2023 Pumpkin 9/11/2023 Squash Leaves 9/11/2023 Cucumber 1 Control Location 2 ND, No Data; 13S3 only had 1 vegetation sample available due to insect damage

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 57 Table B-8 Concentration of Gamma Emitters (including I-131) in Milk (Results in units of pCi/Liter +/- 2 Sample Code Sample Date Gamma Emitters 18E1 Miller Farm 1/10/2023 2/14/2023 3/7/2023 4/4/2023 4/17/2023 5/2/2023 5/16/2023 5/30/2023 6/13/2023 6/27/2023 7/11/2023 7/25/2023 8/7/2023 8/22/2023 9/5/2023 9/19/2023 10/3/2023 10/16/2023 10/31/2023 11/14/2023 11/28/2023 12/12/2023 19B1 Kolb Farm 1/10/2023 2/14/2023 3/7/2023 4/4/2023 4/17/2023 5/2/2023 5/16/2023 5/30/2023 6/13/2023 6/27/2023 7/11/2023 7/25/2023 8/7/2023 8/22/2023 9/5/2023 9/19/2023 10/3/2023 10/16/2023 10/31/2023 11/14/2023 11/28/2023 12/12/2023 23F11 Guest Farm 1/10/2023 2/14/2023 3/7/2023

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 58 Table B-8 Concentration of Gamma Emitters (including I-131) in Milk (Results in units of pCi/Liter +/- 2 Sample Code Sample Date Gamma Emitters 23F1 Guest Farm (cont.)

4/4/2023 4/17/2023 5/2/2023 5/16/2023 5/30/2023 6/13/2023 6/27/2023 7/11/2023 7/25/2023 8/7/2023 8/22/2023 9/5/2023 2

22B1 Pigeon Creek Farm 1/10/2023 2/14/2023 3/7/2023 4/4/2023 4/17/2023 5/2/2023 5/16/2023 5/30/2023 6/13/2023 6/27/2023 7/11/2023 7/25/2023 8/7/2023 8/22/2023 9/5/2023 9/19/2023 10/3/2023 10/16/2023 10/31/2023 11/14/2023 11/28/2023 12/12/2023 8G11 9/19/2023 10/3/2023 10/16/2023 10/31/2023 11/14/2023 11/28/2023 12/12/2023 1 Control Locations 2 Samples No Longer Available

All Non-Natural Gamma Emitters <MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 59 Table B-9 Typical MDA Ranges for Gamma Spectrometry Selected Nuclides Air Particulates (10-3 pCi/m3)

Surface

Water, Drinking Water (pCi/L)

Fish (pCi/kg) Wet Ground water (pCi/L)

Milk (pCi/L)

Oysters (pCi/kg)

Shoreline Sediment (pCi/kg) Dry Soil (pCi/kg)

Dry Vegetation (pCi/kg) Wet K-40 5.65 - 24.6 16 - 182 2,747 - 4,505 21.5 -66.4 1,286 - 1,529 1,269 - 2,069 781 - 13,761 789 - 10,713 1980-5174 Mn-54 0.32 - 1.16 2.7 - 5.6 9.8 - 19.6 2.86 - 5.14 3.6 - 6.6 10.8 - 16.4 41.4 - 67.1 37.4 - 91.9 11.8-26.3 Fe-59 1.01 - 8.52 5.6 - 13.2 31.6 - 93.2 6.04 - 11.7 9.2 - 15.9 29.3 - 56.7 142 - 251 96.4 - 389 28.2-61.3 Co-58 0.38 - 2.07 2.7 - 5.6 10.9 - 28.3 2.86 - 5.27 3.7 - 6.3 10.5 - 19.3 53.7 - 82.9 44.6 - 133 11.6-26.3 Co-60 0.28 - 1.09 2.8 - 5.5 10.9 - 24.3 3.01 - 5.38 4.1 - 7.2 11.7 - 17.0 38.6 - 57.9 32.8 - 85.8 13.5-32.2 Zn-65 0.81 - 3.10 5.5 - 11.4 23.3 - 57.2 6.41 - 14.4 9.4 - 16.1 22.0 - 43.3 112 - 198 96.4 - 275 29.3-60.1 Ag-110m 0.33 - 1.06 2.42 - 4.96 8.2 - 18.1 2.79 - 5.06 3.26-5.64 8.7 - 16.0 36.6 - 175 40.7 - 99.4 11-23.6 Zr-95 0.72 - 3.88 4.7 - 10.2 20.0 - 47.1 5.62 - 8.75 5.8 - 11.5 19.0 - 34.0 93.5 - 151 84.6 - 261 21.5-44.2 Nb-95 0.56 - 4.91 2.9 - 6.0 13.7 - 42.7 3.3 - 5.88 3.9 - 6.5 13.9 - 24.3 82.1 - 157 61.5 - 227 13-26.9 Ru-106 3.00 - 12.1 23.8 - 48.1 77.1 - 197 25.6 - 45.3 29.3 - 51.8 88.0 - 141 327.0 - 570 314.0 - 840 105-227 I-1311 2.73 - 914 0.52 - 11.7 21.4 - 2,340 4.87 - 9.04 0.5 - 7.03 22.4 - 107 470 - 2,040 139 - 8,060 15.1-35.7 Cs-134 0.47 - 0.88 3.2 - 5.7 7.8 - 16.0 2.92 - 5.48 4.09 - 4.82 9.7 - 16.5 43.3 - 82.4 33.4 - 109 11.4-23.8 Cs-137 0.46 - 0.88 3.7 - 5.9 3.8 - 17.5 2.97 - 5.43 4.08 - 5.29 10.0 - 16.7 38.4 - 65.4 39.1 - 135 13.1-30.8 La-140 2.01 - 116 5.05 - 11.5 15.9 - 444 4.87 - 10.3 4.89 - 6.28 24.1 - 80.4 368 - 773 136 - 1,820 12.6-39 Ba-140 2.01 - 116 5.05 - 11.5 15.9 - 444 5.86 - 26.0 4.89 - 6.28 24.1 - 80.4 368 - 773 136 - 1,820 17.5-105 Ce-144 1.12 - 3.27 16.8 - 36.7 38.1 - 70.9 17.8 - 32.0 20.5 - 31.0 42.6 - 72.6 208 - 279 191 - 414 71.5-132 Cr-51 4.90 - 45.0 23.2 - 50.6 93.0 - 395 26.7 - 42.1 30.4 - 46.8 97.0 - 199 711 - 1,110 489 - 1,810 104-196 Na-22 0.34 - 1.33 2.7 - 6.0 12.1 - 28.0 2.78 - 5.94 4.9 - 8.5 13.4 - 19.5 46.4 - 77.4 36.4 - 92.4 4.4-56.6 1 This MDA range for I-131 on a charcoal cartridge is typically 5.22 x 10-3 to 1.37 x 10-2 pCi/m3

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 60 Table B-10 Typical LLDs for Gamma Spectrometry Selected Nuclides Air Particulates 10-3 pCi/m3 Surface Water, Drinking Water pCi/L Fish pCi/kg (wet)

Ground water pCi/L Oysters pCi/kg (wet)

Milk pCi/L Soil pCi/kg (dry)

Vegetation pCi/kg (wet)

Na-22 5

5.3 12 5.3 12 9.1 78 27 Cr-51 74 37 76 37 76 62 452 185 Mn-54 4.6 4.7 13 4.7 13 7.4 63 20 Co-58 6.7 4.3 12 4.3 12 8.2 78 31 Fe-59 20 11 27 11 27 18 123 73 Co-60 3.5 4.8 12 4.8 12 7.5 59 37 Zn-65 8.9 11 27 11 27 17 162 57 Nb-95 9.8 4.5 13 4.5 13 9.5 73 24 Zr-95 11 7.9 18 7.9 18 14 117 40 Ru-106 43 38 111 38 111 62 624 178 Ag-110m 4.2 4.3 11 4.3 11 6

65 24 Te-129m 101 56 118 56 118 90 833 370 I-131*

90 0.8 11 6.4 11 0.8 58 42 Cs-134 4.7 4.7 11 4.7 11 6.7 66 17 Cs-137 4.2 5.1 11 5.1 11 6.9 78 26 Ba-140 47 23 39 23 39 46 103 143 La-140 47 9.2 15 9.2 15 13 103 43 Ce-144 15 23 45 23 45 37 288 114

The LLD for I-131 measured on a Charcoal cartridge is 3.7 x10-2 pCi/m3

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 61 Table B-11 Quarterly DLR Results for Limerick Generating Station 2023 (Results in Units of mrem/91 days +/- 2)

Location Quarter 1 Quarter 2 Quarter 3 Quarter 4 Normalized Annual Dose, MA (mrem/yr)

BA BA + MDDA Annual Facility Dose, FA (mrem) 10E1 18.6 21.5 20.7 18.7 79.5 71.0 82.7 ND 10F3 17.2 17.3 19.0 16.4 69.8 69.7 81.4 ND 10S3 17.2 19.4 19.3 16.8 72.7 70.9 82.6 ND 11S1 20.6 20.9 22.9 20.1 84.4 83.1 94.8 ND 13C11 12.0 13.3 12.7 13.1 51.0 49.8 61.5 ND 13E1 18.8 21.3 20.4 19.9 80.4 70.1 81.8 ND 13S2 25.3 27.8 26.1 27.2 106.4 112.1 123.8 ND 14S1 15.4 15.8 15.6 17.1 64.0 63.2 74.9 ND 15D11 18.1 18.4 21.1 17.8 75.5 72.5 84.2 ND 16F11 19.4 17.2 19.1 18.6 74.2 73.4 85.1 ND 17B1 16.7 17.4 15.6 18.3 67.9 66.8 78.5 ND 18S2 16.9 15.5 19.9 17.7 70.0 78.4 90.1 ND 19D1 17.6 17.7 18.0 16.7 69.9 66.3 78.0 ND

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 62 Table B-11 Quarterly DLR Results for Limerick Generating Station 2023 (Results in Units of mrem/91 days +/- 2)

Location Quarter 1 Quarter 2 Quarter 3 Quarter 4 Normalized Annual Dose, MA (mrem/yr)

BA BA + MDDA Annual Facility Dose, FA (mrem) 20D11 17.0 16.7 15.8 17.4 66.9 63.0 74.7 ND 20F1 16.4 16.5 16.1 16.7 65.7 67.5 79.2 ND 21S2 19.3 18.6 19.4 17.1 74.4 64.1 75.8 ND 23S2 17.5 15.3 15.9 15.8 64.6 63.9 75.6 ND 24D1 14.7 15.9 16.3 16.1 63.0 59.7 71.4 ND 25D1 13.3 13.1 14.4 14.7 55.5 56.5 68.2 ND 25S2 15.2 14.2 15.9 14.7 60.1 58.1 69.8 ND 26S3 15.7 16.1 17.4 14.8 64.1 60.4 72.1 ND 28D2 15.8 14.3 17.2 16.2 63.6 63.5 75.2 ND 29E1 16.3 15.8 15.7 15.6 63.5 62.3 74.0 ND 29S1 14.1 17.7 16.0 14.8 62.7 61.4 73.1 ND 2E1 18.6 18.5 18.4 18.2 73.8 71.9 83.6 ND 31D11 19.9 22.2 23.4 20.9 86.3 83.0 94.7 ND 31D2 18.9 20.4 18.9 19.5 77.7 71.2 82.9 ND 31S1 19.5 19.1 19.3 20.3 78.2 71.6 83.3 ND

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 63 Table B-11 Quarterly DLR Results for Limerick Generating Station 2023 (Results in Units of mrem/91 days +/- 2)

Location Quarter 1 Quarter 2 Quarter 3 Quarter 4 Normalized Annual Dose, MA (mrem/yr)

BA BA + MDDA Annual Facility Dose, FA (mrem) 34E1 16.2 18.6 16.5 16.0 67.3 67.0 78.7 ND 34S2 16.7 17.0 18.0 17.4 69.1 71.6 83.3 ND 36D1 14.9 15.7 14.4 14.8 59.8 62.1 73.8 ND 36S2 18.6 19.5 20.8 19.7 78.6 73.4 85.1 ND 3S1 18.5 17.0 15.9 17.8 69.2 70.1 81.8 ND 4E1 13.3 11.8 12.7 12.2 50.0 51.4 63.1 ND 5H11 22.2 21.8 24.4 21.1 89.5 86.3 98.0 ND 5S1 19.0 19.9 19.8 20.8 79.4 80.0 91.7 ND 6C11 17.8 16.7 18.6 17.8 71.0 69.5 81.2 ND 7E1 17.3 19.3 21.5 20.1 78.1 74.6 86.3 ND 7S1 18.2 18.3 19.3 18.4 74.3 73.1 84.8 ND 9C11 17.0 17.8 19.6 18.5 72.8 68.1 79.8 ND 1 Control & Special Interest Locations

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 64 APPENDIX C Quality Assurance Program Appendix C is a summary of Constellation Generation Solutions (CGS) laboratorys quality assurance program. It consists of Table C-1, Results of Participation in Cross Check Programs, which is a compilation of the results of the CGS laboratorys participation in an interlaboratory comparison program with Environmental Resource Associates (ERA), located in Arvada, Colorado, and Eckert and Ziegler Analytics, Inc.

(EZA), located in Atlanta, Georgia.

It also includes Table C-2, Results of Quality Assurance Program, which is a compilation of the results of the Constellation Generation Solutions (CGS) laboratorys participation in a split sample program with Teledyne Brown Engineering, located in Knoxville, Tennessee, and Table C-3, Limerick Generating Station ODCM Required LLDs, which is a list of the Site Specific LLDs required by the LGS ODCM.

The CGS laboratory's results, contained in Table C-1, Results of Participation in Cross Check Programs, are in full agreement when they were evaluated using the NRC Resolution Test Criteria [1] except, as noted in the Pass/Fail column and described below. The CGS laboratory's results are provided with their analytical uncertainties of 2 sigma. When evaluating with the NRC Resolution Test, a one sigma uncertainty is used to determine Pass or Fail and noted accordingly.

All results reported passed their respective vendor acceptance ranges and NRC Resolution Test Criteria [1], with one exception for the Water Study ERA RAD 133, reference date 4/10/2023. The CGS lab reported a result of 26.6 pCi/L for Ba-133 which passed the NRC Resolution Test Criteria but failed the Vendor Acceptance Range of 17.1-25.8 pCi/L. This high result is for a low concentration of an isotope with low statistics that historically is observed at the lower end of acceptable data ranges. In this case however, the result was an outlier and should have been flagged out of trend and not have passed internal QA review. This event has been entered into the Corrective Action Program for tracking and to prevent future occurrence.

The vendor laboratories used by CGS for subcontracting and interlaboratory comparison samples, GEL Laboratories and Teledyne Brown Engineering, also participate in the ERA and EZA interlaboratory comparison program. A presentation of their full data report is provided in their Annual Environmental Quality Assurance Program Reports, (Ref 14,15). In summary, GEL and TBE reported results met vendor and laboratory acceptance ranges, with the following exceptions discussed here:

For the TBE laboratory, 110 out of 115 analyses performed met the specified acceptance criteria. Five analyses did not meet the specified acceptance criteria and were addressed through the TBE Corrective Action Program. A summary is found below:

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 65

1. TBE result for ERA RAD April 2023 water Ba-133 result was evaluated as Not Acceptable. The reported value was 26.0 pCi/L and the known was 22.3 pCi/L (acceptance range 17.1 - 25.8 pCi/L) or 117% of the known (acceptable for TBE QC). The sample was used as the workgroup duplicate with a result of 25.4 pCi/L (114%). The sample had also been counted on a different detector with a result of 21.9 pCi/L (98%). This was TBEs first failure for Ba-133. (NCR 23-10).

2. The ERA RAD October 2023 water Gross Alpha result was evaluated as Not Acceptable. The reported result was 53.2 pCi/L, and the known result was 70.6 pCi/L (acceptable range of 54.0 - 87.2 pCi/L). The reported result was the workgroup duplicate and was within 75% of the known value (within TBE QC range). The original result was 63.3 pCi/L (90% of the known). Because the LCS result was biased slightly high, the decision was made to report the lower value. (NCR 23-20).

3. The ERA RAD October 2023 water I-131 result was evaluated as Not Acceptable. The reported value was 23.5 pCi/L, and the known result was 29.7 pCi/L (acceptable range of 25.8 - 33.6 pCi/L). The reported result was 79% of the known, which is within the acceptable TBE QC range. The workgroup was reviewed with no anomalies found. The LCS/LCSD results were 109% and 86.1%. The sample was not processed in a timely manner as per the ERA instructions, which stated to analyze shortly after receipt due to the short half-life. Going forward, the QA &/or Lab Mgr. will ensure that this analysis is started sooner. (NCR 23-21).

4. The MAPEP February 2023 vegetation Sr-90 result was evaluated as Not Acceptable. The reported value was 0.05 Bq/kg (not detected), and the known result was a false positive. This was a statistical failure because TBEs reported result with 3 times the uncertainty resulted in a slightly positive net result (0.03194 Bq/kg). The reported result was significantly below TBEs average detection limit for vegetation samples. (NCR 23-09).

5. The Analytics September 2023 milk Sr-90 result was evaluated as Not Acceptable. The reported result was 7.28 pCi/L, and the known result was 12.8 (57% of known). This sample was used as the workgroup duplicate and the carrier yields for both samples were 107% and 75%. The LCS recovery for the workgroup was at 106%. The ERA drinking water Sr-90 cross check that was analyzed around the same time was acceptable at 108%. There was no explanation for the failure. This is the first low biased failure for Sr-90 milk. The last failure (high) was in 2016. (NCR 23-24).

For the GEL Laboratory, nine analyses from four performance evaluation studies did not meet the specified acceptance criteria and were addressed through the GELs internal nonconformance system. A summary is found below:

1. RAD-132 Water failed three parameters. All data and laboratory processes were evaluated, and no errors were found. The investigation determined that the laboratory met

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 66 all quality control criteria specified in the methods and failures were tracked through GEL's internal nonconformance system.

Zinc-65 was reported at 126 pCi/L with a Reference Value of 105 pCi/L and acceptance range of (94.5 - 125 pCi/L). The unacceptable error is due to an unknown error.

Tritium was reported at 18,000 pCi/L with a Reference Value of 21,600 pCi/L and acceptance range of (18,900-23,800 pCi/L). The laboratory has concluded that this low bias was an isolated occurrence and that the overall process is within control.

Iodine-131 was reported at 16.8 pCi/L with a Reference Value of 27 pCi/L and acceptance range of (22.4 - 31.8 pCi/L). Having found no errors, the laboratory continues to investigate all steps of the analytical process including the standardization of the carrier reagent as a possible contributor to the low bias.

2. E13890 Milk failed Strontium-90. All data and laboratory processes were evaluated, and no errors were found. The investigation determined that the laboratory met all quality control criteria specified in the method, and failures were tracked through GEL's internal nonconformance system. Strontium-90 was reported at 6.21 pCi/L with a Reference Value of 12.7 pCi/L and acceptance range of (7.62 - 15.88 pCi/L). The laboratory reviewed the data for this analysis, and no errors were found. It was noted that both the Strontium and Yttrium carriers recovered greater than is typically seen for this method, which could cause a potential low bias in the results. Due to the Sr-89 result being within acceptance limits, it is also suspected that an undetermined error occurred during the second separation resulting in a low Y-90 recovery.

3. RAD-134 Water failed three parameters. The investigation determined that the laboratory met all quality control criteria specified in the method. Additionally, all internal procedures and policies were performed as required. These failures were tracked through GELs internal non-conformance system.

Barium-133 was reported at 75.7 pCi/L with a Reference Value of 66 pCi/L and acceptance range of (55.4 - 73.2 pCi/L). The data was reviewed, and no errors were found. The result recovered at 114% of the reference value, which is within the laboratory's acceptance criteria for LCS recovery. The batch Duplicate result was within the acceptance range of the study and met batch replication criteria with the sample result. Historical performance evaluation results do not indicate a high bias for this parameter. Additionally, a contributing factor is how long the samples were counted. The laboratorys SOP indicates drinking water samples are typically counted for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 67 results in an uncertainty associated with the result that approaches the acceptable range.

Strontium 89 was reported at 61.8 pCi/L and 59.6 pCi/L with a Reference Value of 51.2 pCi/L and acceptance range of (40.4 - 58.7 pCi/L). Strontium 90 was reported at 58.2 pCi/L with a Reference Value of 45.0 pCi/L and acceptance range of (33.2 - 51.6pCi/L). The data for the drinking water PT analysis has been reviewed, and no anomalies were noted. The Strontium-89 result recovered at 118% (905.0 Mod) and 116% (905.0), which is within the laboratorys acceptance criteria for LCS recovery. The sample was analyzed in duplicate for each method, and the duplicate results were within the acceptance range of the study. While the Stontium-90 LCS for the batch met recovery requirements, the recovery was higher than is typically recovered for these methods. The two gravimetrical yields that are determined in the drinking water method were reviewed. It was noted that the yields were closer to the lower end of the acceptance range. It is possible that the yield recoveries contributed to bias in the results. For the failed Strontium-90, it was also noted that the first prep of the sample needed to be reanalyzed due to low yields. A smaller sample volume was used in the reanalysis, and this may have contributed to variation in the results and greater uncertainty in the measurement.

Iodine-131 was reported at 29.1 pCi/L with a Reference Value of 24.4 pCi/L and acceptance range of (20.2 - 28.9 pCi/L). The data for the drinking water PT analysis has been reviewed, and no anomalies were noted. The laboratory has reviewed the data for this analysis, and no errors were found. The result recovered at 119% of the reference value, which is within the laboratorys acceptance criteria for LCS recovery. The Duplicate in the analysis batch was within the acceptance range of the study and met replication criteria with the sample result. Review of historical results for I-131 performance evaluation samples by this method does not indicate a high bias.

4. MRAD-39 Soil failed two parameters. The investigation determined that the laboratory met all quality control criteria specified in the method. Additionally, all internal procedures and policies were performed as required. These failures were tracked through GELs internal nonconformance system.

Cesium-137 was reported at 1290 pCi/Kg with a Reference Value of 1780 pCi/Kg and acceptance range of (1350 - 2250 pCi/Kg).

Cobalt-60 was reported at 5760 pCi/Kg with a Reference Value of 7960 pCi/Kg and acceptance range of (6270 - 9830 pCi/Kg).

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 68 The Interlaboratory results contained in Table C-2, Results of Quality Assurance Program, are intercomparison results for routine samples split for analyses between CGS and its subcontractor, GEL, as the primary REMP Laboratory and TBE as the QA laboratory. Analysis evaluated were Tritium, Strontium 90, beta, and non-natural gamma emitters. The CGS laboratorys results are provided with their analytical uncertainties of 2 sigma. When evaluating with the NRC Resolution Test, a one sigma uncertainty is used to determine Pass or Fail and noted accordingly.

In the event there are no non-natural isotopes detected, the samples are reported <MDA and designated as Pass.

The results contained in Table C-2, Results of Quality Assurance Program, generally agree with their respective CGS laboratory original and Teledyne Brown Engineerings split laboratory sample according to NRC Resolution Test Criteria1. The results for separate air samplers, collocated at 11S1 and 11S2Q, analyzed by CGS and TBE respectively are provided in Table C-2a, Results of Quality Assurance Program Co-Located Air Samplers, for air iodine and Table C-2b, Results of Quality Assurance Program Co-Located Air Samplers, for the beta particulate.

The results are generally in trend and a plot of the data between the two locations is found in the main body of the report, Figure A-8. Instances where the split data does not meet NRC Resolutions test Criteria are for Gross Beta analysis. This is because the CGS laboratory counts samples an order of magnitude below required MDAs, thus achieving very low uncertainties.

This results in a tight acceptance range when comparing to TBEs results that are counted to meet required MDAs resulting in greater uncertainty in the data.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 69 TABLE OF CONTENTS -Appendix C ANALYTICAL RESULTS Table Title Page C-1 Results of Participation in Cross Check Programs............................................................70 C-2 Results of Quality Assurance Program..............................................................................76 C-2a Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Iodine-131 in Filtered Air......................................................................86 C-2b Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Beta Emitters in Air Particulates............................................................89 C-3 Limerick Generating Station ODCM Required LLDs.......................................................91

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 70 Sample Date Vendor Study ID Sample Type Units Equip ID Isotope Observed Reported Laboratory's Results Cross Check Lab Results NRC Resolution Test Pass / Fail 1 3/16/2023 ANA E13841 Cartridge Gamma pCi D2 I-131 84.0

+/-

9.3 90.1 Pass 3/16/2023 ANA E13841 Cartridge Gamma pCi D3 I-131 88.6

+/-

10.4 90.1 Pass 3/16/2023 ANA E13841 Cartridge Gamma pCi D4 I-131 86.6

+/-

10.0 90.1 Pass 3/16/2023 ANA E13841 Cartridge Gamma pCi D5 I-131 83.2

+/-

10.6 90.1 Pass 3/16/2023 ANA E13840 Water Beta pCi/L S5E Cs137 228

+/-

4.4 229 Pass 3/16/2023 ANA E13839 Milk Gamma pCi/L D4 I-131 69.1

+/-

19.0 82.0 Pass Cs-134 177

+/-

9.9 200 Pass Cs-137 133

+/-

12.9 140 Pass Ce-141 150

+/-

14.6 139 Pass Cr-51 307

+/-

82.4 302 Pass Mn-54 172

+/-

15.1 180 Pass Co-58 125

+/-

13.7 131 Pass Fe-59 118

+/-

17.7 122 Pass Co-60 267

+/-

14.6 279 Pass Zn-65 284

+/-

33.5 306 Pass Table C-1 Results of Participation in Cross Check Programs

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 71 3/16/2023 ANA E13839 Milk Gamma pCi/L D5 I-131 71.7

+/-

21.6 82.0 Pass Cs-134 179

+/-

9.1 200 Pass Cs-137 138

+/-

14.2 140 Pass Ce-141 143

+/-

16.9 139 Pass Cr-51 272

+/-

91.2 302 Pass Mn-54 184

+/-

15.9 180 Pass Co-58 126

+/-

14.5 131 Pass Fe-59 116

+/-

19.1 122 Pass Co-60 258

+/-

14.1 279 Pass 3/16/2023 ANA E13839 Milk Gamma pCi/L D5 Zn-65 276

+/-

33.2 306 Pass 4/10/2023 ERA Rad-133 Water Gamma pCi/L D3 Ba-133 26.3

+/-

2.9 22.3 Fail Cs-134 75.6

+/-

3.0 77.6 Pass Cs-137 61.0

+/-

4.6 61.0 Pass Co-60 31.8

+/-

2.7 30.3 Pass Zn-65 230

+/-

14.1 242 Pass 4/10/2023 ERA Rad-133 Water Beta pCi/L S5E Cs-137 50.7

+/-

2.2 60.7 Pass 4/10/2023 ERA Rad-133 Water Gamma pCi/L D5 I-131 28.1

+/-

4.5 28.7 Pass 6/15/2023 ANA E13771 Soil Gamma pCi/g D4 Cs-134 0.285

+/-

0.02 0.292 Pass Cs-137 0.423

+/-

0.05 0.441 Pass 6/15/2023 ANA E13842 Water Beta pCi/L S5E Cs-137 205

+/-

4.2 205 Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 72 6/15/2023 ANA E13843 Water Gamma pCi/L D4 Ce-141 91.0

+/-

12.4 82.5 Pass Co-58 102

+/-

11.9 94.7 Pass Co-60 237

+/-

12.0 252 Pass Cr-51 175

+/-

81.2 201 Pass Cs-134 121

+/-

7.7 126 Pass Cs-137 162

+/-

12.8 158 Pass Fe-59 127

+/-

17.4 118 Pass Mn-54 113

+/-

11.8 112 Pass Zn-65 152

+/-

24.2 170 Pass 6/15/2023 ANA E13843 Water Gamma pCi/L D3 Ce-141 93.8

+/-

16.4 82.5 Pass Co-58 92.9

+/-

14.4 94.7 Pass Co-60 267

+/-

15.1 252 Pass Cr-51 237

+/-

86.7 201 Pass Cs-134 118

+/-

9.4 126 Pass Cs-137 160

+/-

16.1 158 Pass Fe-59 138

+/-

20.4 118 Pass Mn-54 119

+/-

14.8 112 Pass Zn-65 161

+/-

29.1 170 Pass 6/15/2023 ANA E13844 Filter Gamma pCi D4 Ce-141 77.0

+/-

3.3 76.7 Pass Co-58 84.8

+/-

5.0 88.1 Pass Co-60 227

+/-

2.9 235 Pass Cr-51 184

+/-

24.8 187 Pass Cs-134 97.3

+/-

2.8 117 Pass Cs-137 139

+/-

5.5 147 Pass Fe-59 129

+/-

7.6 110 Pass Mn-54 111

+/-

5.3 104 Pass Zn-65 171

+/-

11.3 159 Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 73 6/15/2023 ANA E13844 Filter Gamma pCi D5 Ce-141 80.3

+/-

5.8 76.7 Pass Co-58 83.9

+/-

7.1 88.1 Pass Co-60 237

+/-

8.4 235 Pass Cr-51 180

+/-

36.9 187 Pass Cs-134 101

+/-

3.9 117 Pass Cs-137 147

+/-

7.7 147 Pass Fe-59 131

+/-

10.9 110 Pass Mn-54 113

+/-

7.1 104 Pass Zn-65 167

+/-

15.3 159 Pass 6/15/2023 ANA E13845 Filter Beta pCi S5E Cs-137 201

+/-

2.9 185 Pass 9/14/2023 ANA E13846 Filter Beta pCi S5E Cs-137 260

+/-

3.4 237 Pass 9/14/2023 ANA E13772 Soil Gamma pCi/g D2 Cs-134 0.221

+/-

0.03 0.202 Pass Cs-137 0.326

+/-

0.05 0.315 Pass 9/14/2023 ANA E13772 Soil Gamma pCi/g D3 Cs-134 0.213

+/-

0.02 0.202 Pass Cs-137 0.268

+/-

0.04 0.315 Pass 9/18/2023 ERA MRAD-39 Filter Gamma pCi D5 Cs-134 1188

+/-

17.0 1350 Pass Cs-137 1010

+/-

26.1 932 Pass Co-60 113

+/-

5.7 96 Pass Zn-65 175

+/-

16.6 161 Pass 10/6/2023 ERA RAD-135 Water Gamma pCi/L D2 Cs-134 43.3

+/-

4.2 41.2 Pass Cs-137 215

+/-

12.6 199 Pass Co-60 48.1

+/-

5.3 47.8 Pass Zn-65 62.1

+/-

13.6 57.0 Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 74 10/6/2023 ERA RAD-135 Water Gamma pCi/L D2 I-131 28.9

+/-

6.1 29.7 Pass 10/6/2023 ERA RAD-135 Water Gamma pCi/L D3 I-131 28.3

+/-

5.0 29.7 Pass 11/30/2023 ANA E13847 Filter Gamma pCi D4 Cs-134 161

+/-

5.3 189 Pass Cs-137 156

+/-

8.5 160 Pass Ce-141 119

+/-

6.6 117 Pass Cr-51 176

+/-

34.7 201 Pass Mn-54 138

+/-

8.5 130 Pass Fe-59 163

+/-

11.2 142 Pass Co-60 123

+/-

6.6 123 Pass Zn-65 163

+/-

16.2 168 Pass 11/30/2023 ANA E13847 Filter Gamma pCi D5 Cs-134 163

+/-

5.0 189 Pass Cs-137 163

+/-

8.2 160 Pass Ce-141 119

+/-

6.1 117 Pass Cr-51 179

+/-

32.4 201 Pass Mn-54 134

+/-

7.8 130 Pass Fe-59 169

+/-

10.2 142 Pass Co-60 122

+/-

5.9 123 Pass Zn-65 174

+/-

15.0 168 Pass 11/30/2023 ANA E13848 Water Beta pCi/L S5e Cs-137 229

+/-

4.5 189 Pass 11/30/2023 ANA E13849 Cartridge Gamma pCi D3 I-131 72.9

+/-

5.5 79.9 Pass 11/30/2023 ANA E13849 Cartridge Gamma pCi D4 I-131 72.1

+/-

8.7 79.9 Pass 11/30/2023 ANA E13849 Cartridge Gamma pCi D5 I-131 73.3

+/-

7.7 79.9 Pass 11/30/2023 ANA E13850 Milk Gamma pCi/L D4 I-131 38.4

+/-

15.5 40.0 Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 75 Cs-134 129

+/-

6.1 143 Pass Cs-137 123

+/-

9.9 121 Pass Ce-141 88.5

+/-

10.4 88.7 Pass Cr-51 155

+/-

63.9 152 Pass Mn-54 99.8

+/-

9.5 98.3 Pass Fe-59 107

+/-

13.7 108 Pass Co-60 94.3

+/-

6.8 92.9 Pass Zn-65 121

+/-

17.1 127 Pass 11/30/2023 ANA E13850 Milk Gamma pCi/L D5 I-131 32.2

+/-

12.5 40.0 Pass Cs-134 138

+/-

8.1 143 Pass Cs-137 116

+/-

12.6 121 Pass Ce-141 79.1

+/-

14.0 88.7 Pass Cr-51 146

+/-

78.3 152 Pass Mn-54 103

+/-

11.7 98.3 Pass Fe-59 119

+/-

17.4 108 Pass Co-60 95.5

+/-

8.9 92.9 Pass Zn-65 113

+/-

23.2 127 Pass 1 See discussion at the beginning of the Appendix.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 76 Table C-2 Results of Quality Assurance Program Sample Type and Location Sample Date Type of Analysis Result Units Original Analysis Split Analysis Pass/Fail (Split)

Water -

Q9-1 2/2/2023 Gross Beta pCi/L 1.4 +/- 0.7

<1.96 Pass Water -

Q9-1 2/2/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 2/2/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 2/2/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/2/2023 Gross Beta pCi/L 1.7 +/- 0.7

<2.09 Pass Water -

Q9-1 3/2/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/2/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/2/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/30/2023 Gross Beta pCi/L 1.2 +/- 0.7

<2.03 Pass Water -

Q9-1 3/30/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/30/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 3/30/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 4/26/2023 Gross Beta pCi/L 1.1 +/- 0.6

<1.89 Pass Water -

Q9-1 4/26/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 4/26/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 4/26/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 6/1/2023 Gross Beta pCi/L 2.8 +/- 0.7 2.3 +/- 1.4 Pass Water -

Q9-1 6/1/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 6/1/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 6/1/2023 Tritium pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 77 Water -

Q9-1 6/29/2023 Gross Beta pCi/L 1.6 +/- 0.8

<2.39 Pass Water -

Q9-1 6/29/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 6/29/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 6/29/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 7/27/2023 Gross Beta pCi/L 2.0 +/- 0.7 2.9 +/- 1.6 Pass Water -

Q9-1 7/27/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 7/27/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 7/27/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 8/31/2023 Gross Beta pCi/L 2.0 +/- 0.7 2.8 +/-1.5 Pass Water -

Q9-1 8/31/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 8/31/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 8/31/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 10/3/2023 Gross Beta pCi/L 2.1 +/- 0.8

<2.13 Pass Water -

Q9-1 10/3/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 10/3/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 10/3/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 11/2/2023 Gross Beta pCi/L 2.1 +/- 0.7 3.1 +/- 1.3 Pass Water -

Q9-1 11/2/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 11/2/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 11/2/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/9/2023 Gross Beta pCi/L 1.4 +/- 0.7

<2.05 Pass Water -

Q9-1 12/9/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/9/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/9/2023 Tritium pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/28/2023 Gross Beta pCi/L 1.6 +/- 0.8 2.2 +/- 1.5 Pass Water -

Q9-1 12/28/2023 LLI pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/28/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

Q9-1 12/28/2023 Tritium pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 78 Milk-G2-1 1/11/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 1/11/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 2/15/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 2/15/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 3/8/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 3/8/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 3/22/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 3/22/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 4/6/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 4/6/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 4/20/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 4/20/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 5/3/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 5/3/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 5/17/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 5/17/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 5/31/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 5/31/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 6/14/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 6/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 6/28/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 6/28/2023 LLI pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 79 Milk-G2-1 7/12/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 7/12/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 7/26/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 7/26/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 8/9/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 8/9/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 8/23/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 8/23/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 9/6/2023 Gamma pCi/L

<MDA

<MDA Milk-G2-1 9/6/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 9/20/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 9/20/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 10/4/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 10/4/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 10/18/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 10/18/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 11/1/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 11/1/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 11/15/2023 Gamma pCi/L

<MDA

<MDA Milk-G2-1 11/15/2023 LLI pCi/L

<MDA

<MDA Pass Pass Milk-G2-1 11/29/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-G2-1 11/29/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 12/14/2023 Gamma pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 80 Milk-G2-1 12/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-G2-1 3/22/2023 Strontium 89 pCi/L

<MDA

<MDA Pass Milk-G2-1 3/22/2023 Strontium 90 pCi/L

<MDA

<MDA Pass Milk-G2-1 6/28/2023 Strontium 89 pCi/L

<MDA

<MDA Pass Milk-G2-1 6/28/2023 Strontium 90 pCi/L

<MDA

<MDA Pass Milk-G2-1 9/21/2023 Strontium 89 pCi/L

<MDA

<MDA Pass Milk-G2-1 9/21/2023 Strontium 90 pCi/L

<MDA

<MDA Pass Filter E1-2 3/30/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter E1-2 6/29/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter E1-2 9/28/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter E1-2 12/28/2023 Gamma pCi/m3

<MDA

<MDA Pass Vegetation H1-2 6/14/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 7/12/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 8/16/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 9/20/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 6/14/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 7/12/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 8/16/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation H1-2 9/20/2023 Gamma pCi/Kg

<MDA

<MDA Pass Vegetation B10-2 8/16/2023 Gamma pCi/Kg

<MDA

<MDA Pass Fish INDP 10/4/2023 Gamma pCi/Kg

<MDA

<MDA Pass Fish INDP 10/4/2023 Strontium 90 pCi/Kg

<MDA

<MDA Pass Water -

16C2 1/31/2023 Gross Beta pCi/L 3.16 +/- 0.82

<2.58 Pass Water -

16C2 1/31/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 1/31/2023 Gamma pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 81 Water -

16C2 2/27/2023 Gross Beta pCi/L 2.51 +/- 0.82 3.26 +/- 1.65 Pass Water -

16C2 2/27/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 2/27/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 4/3/2023 Gross Beta pCi/L 2.21 +/- 0.80 3.44 +/- 1.66 Pass Water -

16C2 4/3/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 4/3/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 4/3/2023 Tritium Qtr 1 pCi/L

<MDA

<MDA Pass Water -

16C2 5/1/2023 Gross Beta pCi/L 3.18 +/- 0.84

<2.39 Pass Water -

16C2 5/1/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 5/1/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 5/30/2023 Gross Beta pCi/L 2.34 +/- 0.72 3.00 +/- 1.58 Pass Water -

16C2 5/30/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 5/30/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 7/3/2023 Gross Beta pCi/L 2.80 +/- 0.82 3.95 +/- 1.95 Pass Water -

16C2 7/3/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 7/3/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 7/3/2023 Tritium Qtr 2 pCi/L

<MDA

<MDA Pass Water -

16C2 7/31/2023 Gross Beta pCi/L 1.80 +/- 0.74

<2.51 Pass Water -

16C2 7/31/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 7/31/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 8/28/2023 Gross Beta pCi/L 1.60 +/- 0.77 2.92 +/- 1.90 Pass Water -

16C2 8/28/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 8/28/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 10/2/2023 Gross Beta pCi/L 2.24 +/- 0.79

<2.97 Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 82 Water -

16C2 10/2/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 10/2/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 10/2/2023 Tritium Qtr 3 pCi/L

<MDA

<MDA Pass Water -

16C2 10/30/2023 Gross Beta pCi/L 2.66 +/- 0.82 3.23 +/- 1.73 Pass Water -

16C2 10/30/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 10/30/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 11/27/2023 Gross Beta pCi/L 2.93 +/- 0.84

<2.50 Pass Water -

16C2 11/27/2023 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 11/27/2023 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 1/2/2024 Gross Beta pCi/L 2.31 +/- 0.80

<2.66 Pass Water -

16C2 1/2/2024 LLI pCi/L

<MDA

<MDA Pass Water -

16C2 1/2/2024 Gamma pCi/L

<MDA

<MDA Pass Water -

16C2 1/2/2024 Tritium Qtr 4 pCi/L

<MDA

<MDA Pass Milk-19B1 1/10/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 1/10/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 1/10/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 1/10/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 2/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 2/14/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 2/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 2/14/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 3/7/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 3/7/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 3/7/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 3/7/2023 Gamma pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 83 Milk-19B1 4/4/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 4/4/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 4/4/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 4/4/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 4/17/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 4/17/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 4/17/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 4/17/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 5/2/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 5/2/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 5/2/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 5/2/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 5/16/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 5/16/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 5/16/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 5/16/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 5/30/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 5/30/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 5/30/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 5/30/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 6/13/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 6/13/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 6/13/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 6/13/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 6/27/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 6/27/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 6/27/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 6/27/2023 Gamma pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 84 Milk-19B1 7/11/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 7/11/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 7/11/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 7/11/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 7/25/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 7/25/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 7/25/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 7/25/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 8/7/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 8/7/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 8/7/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 8/7/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 8/22/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 8/22/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 8/22/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 9/5/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 9/5/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 9/5/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 9/5/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 9/19/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 9/19/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 9/19/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 9/19/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 10/3/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 10/3/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 10/3/2023 LLI pCi/L

<MDA

<MDA Pass

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 85 Milk-22B1 10/3/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 10/16/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 10/16/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 10/16/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 10/16/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 10/31/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 10/31/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 10/31/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 10/31/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 11/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 11/14/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 11/14/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 11/14/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 11/28/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 11/28/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 11/28/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 11/28/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-19B1 12/12/2023 LLI pCi/L

<MDA

<MDA Pass Milk-19B1 12/12/2023 Gamma pCi/L

<MDA

<MDA Pass Milk-22B1 12/12/2023 LLI pCi/L

<MDA

<MDA Pass Milk-22B1 12/12/2023 Gamma pCi/L

<MDA

<MDA Pass Filter 11S1 / 11S2 4/03/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter 11S1 / 11S2 7/03/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter 11S1 / 11S2 10/02/2023 Gamma pCi/m3

<MDA

<MDA Pass Filter 11S1 / 11S2 1/02/2024 Gamma pCi/m3

<MDA

<MDA Pass 1 See discussion at the beginning of the Appendix.

- The nature of these samples precluded splitting them with an independent laboratory.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 86 Table C-2a Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Iodine-131 in Filtered Air (Results in units of 10-3 pCi/m3 +/- 2)

Start Date Stop Date Isotope Observed 11S1 Analysis 11S2 Analysis 1/3/2023 1/9/2023 I-131

<MDA

<MDA 1/9/2023 1/17/2023 I-131

<MDA

<MDA 1/17/2023 1/23/2023 I-131

<MDA

<MDA 1/23/2023 1/31/2023 I-131

<MDA

<MDA 1/31/2023 2/7/2023 I-131

<MDA

<MDA 2/7/2023 2/13/2023 I-131

<MDA

<MDA 2/13/2023 2/20/2023 I-131

<MDA

<MDA 2/20/2023 2/27/2023 I-131

<MDA

<MDA 2/27/2023 3/6/2023 I-131

<MDA

<MDA 3/6/2023 3/13/2023 I-131

<MDA

<MDA 3/13/2023 3/20/2023 I-131

<MDA

<MDA 3/20/2023 3/27/2023 I-131

<MDA

<MDA 3/27/2023 4/3/2023 I-131

<MDA

<MDA 4/3/2023 4/10/2023 I-131

<MDA

<MDA 4/10/2023 4/17/2023 I-131

<MDA

<MDA 4/17/2023 4/24/2023 I-131

<MDA

<MDA 4/24/2023 5/1/2023 I-131

<MDA

<MDA 5/1/2023 5/8/2023 I-131

<MDA

<MDA 5/8/2023 5/15/2023 I-131

<MDA

<MDA 5/15/2023 5/22/2023 I-131

<MDA

<MDA 5/22/2023 5/30/2023 I-131

<MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 87 Table C-2a Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Iodine-131 in Filtered Air (Results in units of 10-3 pCi/m3 +/- 2)

Start Date Stop Date Isotope Observed 11S1 Analysis 11S2 Analysis 5/30/2023 6/5/2023 I-131

<MDA

<MDA 6/5/2023 6/12/2023 I-131

<MDA

<MDA 6/12/2023 6/19/2023 I-131

<MDA

<MDA 6/19/2023 6/26/2023 I-131

<MDA

<MDA 6/26/2023 7/3/2023 I-131

<MDA

<MDA 7/3/2023 7/10/2023 I-131

<MDA

<MDA 7/10/2023 7/17/2023 I-131

<MDA

<MDA 7/17/2023 7/24/2023 I-131

<MDA

<MDA 7/24/2023 7/31/2023 I-131

<MDA

<MDA 7/31/2023 8/7/2023 I-131

<MDA

<MDA 8/7/2023 8/14/2023 I-131

<MDA

<MDA 8/14/2023 8/21/2023 I-131

<MDA

<MDA 8/21/2023 8/28/2023 I-131

<MDA

<MDA 8/28/2023 9/5/2023 I-131

<MDA

<MDA 9/5/2023 9/11/2023 I-131

<MDA

<MDA 9/11/2023 9/18/2023 I-131 9/18/2023 9/25/2023 I-131

<MDA

<MDA 9/25/2023 10/2/2023 I-131

<MDA

<MDA 10/2/2023 10/9/2023 I-131

<MDA

<MDA 10/9/2023 10/16/2023 I-131

<MDA

<MDA 10/16/2023 10/23/2023 I-131

<MDA

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 88 Table C-2a Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Iodine-131 in Filtered Air (Results in units of 10-3 pCi/m3 +/- 2)

Start Date Stop Date Isotope Observed 11S1 Analysis 11S2 Analysis 10/23/2023 10/30/2023 I-131

<MDA

<MDA 10/30/2023 11/6/2023 I-131

<MDA

<MDA 11/6/2023 11/13/2023 I-131

<MDA

<MDA 11/13/2023 11/20/2023 I-131

<MDA

<MDA 11/20/2023 11/27/2023 I-131

<MDA

<MDA 11/27/2023 12/4/2023 I-131

<MDA

<MDA 12/4/2023 12/11/2023 I-131

<MDA

<MDA 12/11/2023 12/19/2023 I-131

<MDA

<MDA 12/19/2023 12/27/2023 I-131

<MDA

<MDA 12/27/2023 1/2/2024 I-131

<MDA

Power Outage Lost sample

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 89 Start Date Stop Date 11S1 11S2 1/9/2023 1/17/2023 2.08

+/-

0.19 1.79

+/-

0.35 1/17/2023 1/23/2023 1.10

+/-

0.21 0.86

+/-

0.40 1/23/2023 1/31/2023 1.88

+/-

0.18 1.51

+/-

0.33 1/31/2023 2/7/2023 2.15

+/-

0.21 1.60

+/-

0.39 2/7/2023 2/13/2023 2.84

+/-

0.26 1.79

+/-

0.47 2/13/2023 2/20/2023 1.87

+/-

0.19 1.85

+/-

0.41 2/20/2023 2/27/2023 2.08

+/-

0.21 1.87

+/-

0.40 2/27/2023 3/6/2023 1.29

+/-

0.18 0.74

+/-

0.33 3/6/2023 3/13/2023 1.37

+/-

0.18 1.17

+/-

0.36 3/13/2023 3/20/2023 1.67

+/-

0.19 1.26

+/-

0.37 3/20/2023 3/27/2023 2.09

+/-

0.20 1.73

+/-

0.40 3/27/2023 4/3/2023 2.26

+/-

0.21 1.92

+/-

0.41 4/3/2023 4/10/2023 2.29

+/-

0.22 1.66

+/-

0.41 4/10/2023 4/17/2023 2.32

+/-

0.21 2.00

+/-

0.42 4/17/2023 4/24/2023 1.76

+/-

0.20 1.55

+/-

0.37 4/24/2023 5/1/2023 0.98

+/-

0.17 0.91

+/-

0.33 5/1/2023 5/8/2023 0.77

+/-

0.16 0.25

+/-

0.29 5/8/2023 5/15/2023 2.62

+/-

0.23 1.52

+/-

0.41 5/15/2023 5/22/2023 1.52

+/-

0.19 1.07

+/-

0.41 5/22/2023 5/30/2023 1.49

+/-

0.17 1.11

+/-

0.33 5/30/2023 6/5/2023 1.59

+/-

0.21 1.04

+/-

0.42 6/5/2023 6/12/2023 1.95

+/-

0.21 1.88

+/-

0.42 6/12/2023 6/19/2023 1.41

+/-

0.18 1.33

+/-

0.38 6/19/2023 6/26/2023 0.84

+/-

0.17 0.69

+/-

0.36 6/26/2023 7/3/2023 2.07

+/-

0.21 1.63

+/-

0.41 7/3/2023 7/10/2023 2.03

+/-

0.21 1.53

+/-

0.40 7/10/2023 7/17/2023 2.49

+/-

0.22 2.68

+/-

0.46 7/17/2023 7/24/2023 2.17

+/-

0.22 1.82

+/-

0.41 Table C-2b Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Beta Emitters in Air Particulates (Results in units of 10-2 pCi/m3 +/- 2)

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 90 Results of Quality Assurance Program Co-Located Air Samplers 11S1 and 11S2 Concentration of Beta Emitters in Air Particulates (Results in units of 10-2 pCi/m3 +/- 2)

Start Date Stop Date 11S1 11S2 7/24/2023 7/31/2023 2.02

+/-

0.21 1.93

+/-

0.43 7/31/2023 8/7/2023 1.77

+/-

0.20 1.20

+/-

0.38 8/7/2023 8/14/2023 2.01

+/-

0.20 1.73

+/-

0.41 8/14/2023 8/21/2023 1.73

+/-

0.20 1.64

+/-

0.42 8/21/2023 8/28/2023 2.06

+/-

0.21 2.17

+/-

0.41 8/28/2023 9/5/2023 2.20

+/-

0.19 1.50

+/-

0.33 9/5/2023 9/11/2023 3.10

+/-

0.27 2.67

+/-

0.50 9/11/2023 9/18/2023 9/18/2023 9/25/2023 1.31

+/-

0.19 1.33

+/-

0.37 9/25/2023 10/2/2023 1.07

+/-

0.18 1.24

+/-

0.39 10/2/2023 10/9/2023 2.66

+/-

0.23 1.93

+/-

0.43 10/9/2023 10/16/2023 1.57

+/-

0.20 1.17

+/-

0.39 10/16/2023 10/23/2023 0.86

+/-

0.18 0.49

+/-

0.35 10/23/2023 10/30/2023 2.12

+/-

0.22 1.96

+/-

0.43 10/30/2023 11/6/2023 2.40

+/-

0.22 1.40

+/-

0.40 11/6/2023 11/13/2023 2.28

+/-

0.22 1.68

+/-

0.41 11/13/2023 11/20/2023 2.70

+/-

0.24 1.85

+/-

0.44 11/20/2023 11/27/2023 1.38

+/-

0.19 0.96

+/-

0.35 11/27/2023 12/4/2023 2.82

+/-

0.23 1.79

+/-

0.39 12/4/2023 12/11/2023 2.12

+/-

0.21 1.58

+/-

0.37 12/11/2023 12/19/2023 2.04

+/-

0.18 1.55

+/-

0.37 12/19/2023 12/27/2023 1.74

+/-

0.18 1.26

+/-

0.34 12/27/2023 1/2/2024 1.39

+/-

0.20 1.25

+/-

0.40 1 See Appendix C Summary

Power Outage Lost sample Table C-2b

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 91 TABLE C-3 Limerick Generating Station ODCM Required LLDs Selected Water Fish/Shellfish Milk Sediment Vegetation Particulates1 Nuclides pCi/L pCi/kg pCi/L pCi/kg pCi/kg pCi/m3 (Wet)

(Dry)

(Wet)

Gross Beta 4

H-3 2000 Mn-54 15 130 Co-58 15 130 Fe-59 30 260 Co-60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 I-131 153 1

60 0.072 Cs-134 15 130 15 150 60 0.05 Cs-137 18 150 18 180 80 0.06 Ba-140 60 60 La-140 15 15 1Gross Beta activity LLD = 0.01 pCi/m3 2 Air samples for I-131 are collected separately on a charcoal radioiodine cannister.

3Water samples with a drinking water pathway require low level Iodine 1.0 pCi/L LLD.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 92 APPENDIX D Land Use Census Appendix D contains the results of a Land Use Census conducted in the fall of 2023 around Limerick Generating Station (LGS), performed by Constellation Generation Solutions to comply with Bases 3.3.2 of the Limericks Offsite Dose Calculation Manual. The purpose of the land use survey is to look for all potential pathways of radiation to a person. This is accomplished by documenting the nearest resident, milk-producing animal, and garden of greater than 500 ft2 in each of the sixteen 22 1/2 degree sectors out to five miles around the site. The distance and direction of all locations from the LGS reactor buildings were positioned using Global Positioning System (GPS) technology.

There were gardens identified in all sixteen sectors in this report. Fifteen (15) new gardens were located this year in N, ENE, ESE, S, SSW, SW, WSW, WNW, NW, and NNW meteorological sectors, within three (3) miles of the Limerick release vents. Gardens planted in sectors ESE and SE that are maintained for the REMP program are not included in this survey because of their location on LGS property. New gardens observed in the ENE, WSW, and NNW sectors were identified as the closest in the sector. The nearest gardens in all other sectors reported in the 2023 report are the same as last years report.

Dairy sites were identified in four (4) of sixteen (16) meteorological sectors. The dairy sites were identified in the ENE, S, SSW, and SW sectors. The collectors were able to locate a dairy animal for sampling in the ENE sector between 8 - 15 kilometers from the Limerick release vents as a control sample. The new location in the ENE sector was identified as the closest dairy animals in that sector.

Animals used for meat consumption were identified in fifteen (15) of the sixteen (16) meteorological sectors. There were no meat animals identified in the NW sector. Seven (7) new sites were identified this year in ESE, S, SSW, SW, WSW, W, and WNW sectors, within three (3) miles of the Limerick release vents. The new locations in the SSW, SW, and WNW were identified as the closest meat animals in that sector. The nearest meat animal in all other sectors reported in the 2023 report are the same as last years report.

There was no observed water usage for agricultural irrigation of root vegetables drawn directly from the Schuylkill River downriver from Limerick Generation Station. This was confirmed with a phone interview with Mr. David Kovach of the Delaware River Basin Commission on 11/21/23.

Further investigation utilizing the Pennsylvania Department of Environmental Protections website corroborated this information as no permits have been issued for a direct draw from the Schuylkill River for commercial agricultural irrigation of root vegetables.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 93 Table D-1 Land Use Census Distance of the Nearest Residence, Garden, Dairy, Meat Animal within a Five Mile Radius of Limerick Generating Station 2023 (Distance in feet)

Sector Residence Garden (1)

Dairy Animal Meat Animal N

3,109 3,333 10,077 NNE 2,706 3,792 3,792 NE 3,469 13,917 3,469 ENE 3,231 7,451 54,504*

4,070 E

2,864 4,117 3,890 ESE 3,434 3,434 5,181 SE 3,928 6,376 10,903 SSE 5,403 6,912 8,177 S

4,347 6,103 22,114*

9,933 SSW 5,063 5,732 10,390*

7,620 SW 3,251 6,319 20,011*

7,682 WSW 3,799 4,459 4,084 W

3,627 8,886 14,123 WNW 3,685 12,022 3,900 NW 3,619 8,200 NNW 5,050 7,446 12,065 (1) Larger than 500 square feet (as can best be determined from a distance)

Denotes current REMP Dairy sample location Red Denotes the site/site information has been updated from the previous years Land Use Census

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 94 Figure D-1 Land Use Census Map Limerick Generating Station Land Use Census

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Limerick Generating Station Land Use 2023

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NORMANDEAU ASSOCIATES Date

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January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 95 APPENDIX E Annual Radiological Groundwater Protection Program Report For Limerick Generating Station This report on the Radiological Groundwater Protection Program (RGPP) conducted for the Limerick Generating Station (LGS) by Constellation Nuclear covers the period 01 January 2023 through 31 December 2023. During that period:

62 analyses were performed on 44 samples from 13 groundwater locations and 20 analyses were performed on 12 precipitation water locations collected from the environment, both on and off station property in 2023.

Groundwater samples were analyzed for tritium. Low levels of tritium were detected at 5 of the 13 groundwater monitoring locations. All other results were less than the required Constellation-specified LLD of 200 pCi/L.

Groundwater samples were analyzed for strontium-89 (Sr-89) and strontium-90 (Sr-90).

All Sr-89 and Sr-90 results were less than the Minimum Detectable Concentration (MDC).

Hard-To-Detect (HTD) analyses are routinely performed on a once per five-year frequency for all groundwater monitoring locations. HTD analyses were performed in 2021 for 7 samples. All HTD results were less than the MDC. HTD analyses will be performed again in 2026.

Precipitation water samples were analyzed for tritium. Tritium was detected at 1 of 12 precipitation locations sampled.

In assessing all the data gathered for this report, it was concluded that the operation of Limerick Generating Station had no adverse radiological impact on the environment offsite of LGS. Additionally, there does not appear to be an active source of tritium to groundwater at the Station.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 96 II.

Introduction The Limerick Generating Station (LGS), consisting of two 3515 MW boiling water reactors owned and operated by Constellation Corporation, is located adjacent to the Schuylkill River in Montgomery County, Pennsylvania. Unit No. 1 went critical on 22 December 1984. Unit No. 2 went critical on 11 August 1989.

The site is located in Piedmont countryside, transversed by numerous valleys containing small tributaries that feed into the Schuylkill River. On the eastern riverbank, elevation rises from approximately 110 to 300 feet mean sea level (MSL).

On the western riverbank, elevation rises to approximately 50 feet MSL.

This report covers those analyses performed by Teledyne Brown Engineering (TBE) on samples collected in 2023 and analysis for replicate samples performed by GEL Laboratories In 2006, a comprehensive program to evaluate the impact of station operations on groundwater and surface water in the vicinity of Limerick Generating Station was instituted. This evaluation involved numerous station personnel and contractor support personnel.

A. Objective of the RGPP The long-term objectives of the RGPP are as follows:

1.

Identify suitable locations to monitor and evaluate potential impacts from station operations before significant radiological impact to the environment and potential drinking water sources.

2. Understand the local hydrogeologic regime in the vicinity of the station and maintain up-to-date knowledge of flow patterns on the surface and shallow subsurface.

3. Perform routine water sampling and radiological analysis of water from selected locations.

4. Report new leaks, spills, or other detections with potential radiological significance to stakeholders in a timely manner.

5. Regularly assess analytical results to identify adverse trends.

6. Take necessary corrective actions to protect groundwater resources.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 97 B. Implementation of the Objectives The objectives identified have been implemented at Limerick Generating Station as discussed below:

1. Locations have been identified as described in the 2006 Phase 1 study. The Phase 1 study results and conclusions were made available to state and federal regulators in station specific reports.

2. The Limerick Generating Station reports describe the local hydrogeologic regime. Periodically, the flow patterns on the surface and shallow subsurface are updated based on ongoing measurements.

3. Limerick Generating Station will continue to perform routine sampling and radiological analysis of water from selected locations.

4. Limerick Generating Station has procedures to identify and report new leaks, spills, or other detections with potential radiological significance in a timely manner.

5. Limerick Generating Station staff and consulting hydrogeologist assess analytical results on an ongoing basis to identify adverse trends.

C. Program Description Samples for the ongoing ground water monitoring program were collected by Constellation Generation Solutions (CGS). This section describes the general collection methods used to obtain environmental samples for the LGS RGPP in 2023. Sample locations can be found in Table E-1, Locations of Onsite Radiological Groundwater Protection Program, Limerick Generating Station, 2023, Appendix E.

1. Sample Collection Groundwater Samples of groundwater were collected, managed, transported, and analyzed in accordance with approved procedures following EPA methods.

Sample locations, sample collection frequencies, and analytical frequencies were controlled in accordance with approved station procedures.

Contractor and/or station personnel were trained in the collection, preservation management, and shipment of samples, as well as in documentation of sampling events. Analytical laboratories were subject to internal quality assurance programs and industry cross-check programs, as well as nuclear industry audits. Station personnel reviewed and evaluated all analytical data deliverables as data were received. Both station

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 98 personnel and an independent hydrogeologist reviewed analytical data results for adverse trends or changes to hydrogeological conditions.

Precipitation A five-gallon precipitation collection bucket fitted with a funnel was installed at four locations around the Limerick Generating Station. Three collection buckets were located on site in the highest prevalent wind sectors, and one was located on site in the least prevalent wind sector.

D. Characteristics of Tritium (H-3)

Tritium (chemical symbol H-3) is a radioactive isotope of hydrogen. The most common form of tritium is tritium oxide, which is also called "tritiated water."

The chemical properties of tritium are essentially those of ordinary hydrogen.

Tritiated water behaves the same as ordinary water in both the environment and the body. Tritium can be taken into the body by drinking water, breathing air, eating food, or absorption through skin. Once tritium enters the body, it disperses quickly and is uniformly distributed throughout the body. Tritium is excreted primarily through urine with a clearance rate characterized by an effective biological half-life of about 14 days. Within one month or so after ingestion, essentially all tritium is cleared. Organically bound tritium (tritium that is incorporated in organic compounds) can remain in the body for a longer period.

Tritium is produced naturally in the upper atmosphere when cosmic rays strike air molecules. Tritium is also produced during nuclear weapons explosions, as a by-product in reactors producing electricity, and in special production reactors, where the isotopes lithium-7 and/or boron-10 are activated to produce tritium.

Like normal water, tritiated water is colorless and odorless. Tritiated water behaves chemically and physically like non-tritiated water in the subsurface; therefore, tritiated water will travel at the same velocity as the average groundwater velocity.

Tritium has a half-life of approximately 12.3 years. It decays spontaneously to helium-3 (He-3). This radioactive decay releases a beta particle (low-energy electron). The radioactive decay of tritium is the source of the health risk from exposure to tritium. Tritium is one of the least dangerous radionuclides because it emits very weak radiation and leaves the body relatively quickly. Since tritium is almost always found as water, it goes directly into soft tissues and organs. The associated dose to these tissues is generally uniform and is dependent on the water content of the specific tissue.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 99 III.

Program Description A. Sample Analysis This section lists the analyses performed by TBE and GEL Laboratories, LLC (GEL) on environmental samples for the LGS RGPP in 2023. The analytical procedures used by the laboratories are listed in the AREOR References.

In order to achieve the stated objectives, the current program includes the following analyses:

1. Concentrations of tritium in groundwater and precipitation water

2. Concentrations of gross alpha (dissolved and suspended) in groundwater

3. Concentrations of gamma-emitters (Be-7, K-40, Mn-54, Co-58, Fe-59, Co-60, Zn-65, Nb-95, Zr-95, I-131, Cs-134, Cs-137, Ba-140, and La-140) in groundwater

4. Concentrations of strontium (Sr-89 and Sr-90) in groundwater B. Data Interpretation The radiological data collected prior to Limerick Generating Station becoming operational were used as a baseline with which these operational data were compared. For the purpose of this report, Limerick Generating Station was considered operational at initial criticality. Several factors were important in the interpretation of the data:

1. Lower Limit of Detection and Minimum Detectable Concentration The lower limit of detection (LLD) is defined as the smallest concentration of radioactive material in a sample that would yield a net count (above background) that would be detected with only a 5% probability of falsely concluding that a blank observation represents a "real" signal. The LLD is intended as a before the fact estimate of a system (including instrumentation, procedure, and sample type) and not as an after the fact criterion for the presence of activity. All analyses were designed to achieve the required LGS detection capabilities for environmental sample analysis.

The minimum detectable concentration (MDC) is defined above with the exception that the measurement is an after the fact estimate of the presence of activity.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 100

2. Laboratory Measurements Uncertainty The estimated uncertainty in measurement of tritium in environmental samples is frequently on the order of 50% of the measurement value.

Statistically, the exact value of a measurement is expressed as a range with a stated level of confidence. The convention is to report results with a 95%

level of confidence. The uncertainty comes from calibration standards, sample volume or weight measurements, sampling uncertainty, and other factors. Constellation reports the uncertainty of a measurement created by statistical process (counting error) as well as all sources of error (Total Propagated Uncertainty or TPU). Each result has two values calculated.

Constellation reports the TPU by following the result with plus or minus (+/-)

the estimated sample standard deviation, as TPU, that is obtained by propagating all sources of analytical uncertainty in measurements.

Analytical uncertainties are reported at the 95% confidence level in this report for reporting consistency with the AREOR.

C. Background Analysis A pre-operational radiological environmental monitoring program (pre-operational REMP) was conducted to establish background radioactivity levels prior to operation of the Station. The environmental media sampled and analyzed during the pre-operational REMP were atmospheric radiation, fall-out, domestic water, surface water, aquatic life, and foodstuffs. The results of the monitoring were detailed in the report entitled Pre-operational Radiological Environmental Monitoring Program Report, Limerick Generating Station Units 1 and 2, 1 January 1982 through 21 December 1984, Teledyne Isotopes and Radiation Management Corporation.

The pre-operational REMP contained analytical results from samples collected from both surface water and groundwater.

Monthly surface water sampling began in 1982, and the samples were analyzed for tritium as well as other radioactive analytes. During the preoperational program tritium was detected at a maximum concentration of 420 pCi/L, indicating that these preoperational results were from nuclear weapons testing, and the tritium is radioactively decaying as predicted. Gamma isotopic results from the preoperational program were all less than or at the minimum detectable concentration (MDC) level.

1. Background Concentrations of Tritium The purpose of the following discussion is to summarize background measurements of tritium in various media performed by others. Additional detail may be found by consulting references.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 101

a. Tritium Production Tritium is created in the environment from naturally occurring processes, both cosmic and subterranean, as well as from anthropogenic (i.e., man-made) sources. In the upper atmosphere, Cosmogenic tritium is produced from the bombardment of stable nuclides and combines with oxygen to form tritiated water, which will then enter the hydrologic cycle.

Below ground, lithogenic tritium is produced by the bombardment of natural lithium present in crystalline rocks by neutrons produced by the radioactive decay of naturally abundant uranium and thorium. Lithogenic production of tritium is usually negligible compared to other sources due to the limited abundance of lithium in rock. The lithogenic tritium is introduced directly to groundwater.

A major anthropogenic source of tritium and Sr-90 comes from the former atmospheric testing of thermonuclear weapons. Levels of tritium in precipitation increased significantly during the 1950s and early 1960s, and later with additional testing, resulting in the release of significant amounts of tritium to the atmosphere. The Canadian heavy water nuclear power reactors, other commercial power reactors, nuclear research, and weapons production continue to influence tritium concentrations in the environment.

b. Precipitation Data Precipitation samples are routinely collected at stations around the world for the analysis of tritium and other radionuclides. Two publicly available databases that provide tritium concentrations in precipitation are Global Network of Isotopes in Precipitation (GNIP) and USEPAs RadNet database. GNIP provides tritium precipitation concentration data for samples collected worldwide since 1960. RadNet provides tritium precipitation concentration data for samples collected at stations throughout the U.S. Based on GNIP data for sample stations located in the U.S. Midwest, tritium concentrations peaked around 1963. This peak, which approached 10,000 pCi/L for some stations, coincided with the atmospheric testing of thermonuclear weapons. Tritium concentrations in surface water showed a sharp decline up until 1975 followed by a gradual decline since that time. Tritium concentrations have typically been below 100 pCi/L since approximately 1980. Tritium concentrations in wells may still be above the 200 pCi/L detection limit from the external causes described above.

Water from previous years was naturally captured in groundwater. As a result, some well water sources today are affected by the surface water from the 1960s that contained elevated tritium activity.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 102

c. Surface Water Data Tritium concentrations are routinely measured in the Schuylkill and Delaware Rivers. Pennsylvania surface water data are typically less than 100 pCi/L.

The USEPA RadNet surface water data typically has a reported Combined Standard Uncertainty of 35 to 50 pCi/L. According to USEPA, this corresponds to a +/-70 to 100 pCi/L 95% confidence bound on each given measurement. Therefore, the typical background data provided may be subject to measurement uncertainty of approximately +/- 70 to 100 pCi/L.

The radioanalytical laboratory is counting tritium results to a Constellation specified LLD of 200 pCi/L. Typically, the lowest positive measurement will be reported within a range of 40 - 240 pCi/L or 140 +/- 100 pCi/L. Clearly, these sample results cannot be distinguished as different from background at this concentration. The surface water data ends in 1999 as the USEPA RadNet surface water program was terminated in March 1999.

The Constellation fleet-wide and Limerick RGPP was modified at the beginning of 2020. Changes to the RGPP included sample locations, frequency, and the removal of surface water sampling.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 103 IV.

Results and Discussion A. Groundwater Results Samples were collected from onsite wells throughout the year in accordance with the station Radiological Groundwater Protection Program. Analytical results and anomalies are discussed below:

Tritium Samples from 13 locations were analyzed for tritium activity (Appendix E, Table E-6). Tritium values ranged from non-detectable to 3,270 pCi/L. There is no drinking water pathway available from these groundwater sample locations (Appendix E, Table E-3).

Strontium Samples were analyzed for Sr-89 and Sr-90. All results were below the required LLDs (Appendix E, Table E-2).

Gross Alpha (dissolved and suspended)

Analyses for gross alpha was not performed in 2023. Gross alpha will be performed in 2024.

Gamma-Emitters Gamma-radionuclide analysis was not performed in 2023. The next time gamma-radionuclide analysis will be performed is 2024.

Hard-To-Detect HTD analyses were performed in 2021 on 7 groundwater locations. There were no detects and all results were below the required LLDs. The next sampling event is scheduled to take place in 2026.

B. Precipitation Sample Results Tritium Tritium activity was detected in 1 of 12 precipitation water locations analyzed.

The concentrations ranged from 382 pCi/L. These concentrations are consistent with historical values observed (Appendix E, Table E-4).

C. Drinking Water Well Survey In April 2019, GHD (formerly Conestoga Rover Associates) conducted a comprehensive database search (PaGWIS) for private and public wells within one mile of the Station.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 104 The detailed results of the 2019 well search are presented in Appendix C of the 2019 Hydrogeologic Investigation Report for Limerick Generating Station. In general, the well depths range from 45 to 585 feet below ground surface (bgs) and yield between 2 and 65 gpm. All wells are completed in the Brunswick Formation. In the GHD report, Figure 2.3 presents the approximate locations of the water wells that surround the Station.

A review of the PaGWIS database table reveals the following type and associated number of off-Station wells within the one-mile radius of the Station:

x Domestic = 41 wells (68%)

x Industrial = 5 wells (8%)

x Observation = 9 wells (15%)

x Abandoned = 5 wells (8%)

x Total = 60 wells One well was identified at the active quarry, which is approximately 2,000 feet to the northwest of the Station. The PaGWIS database search identifies the quarry well as constructed to a depth of 100 feet bgs, and reportedly yields at least 50,400 gpd (35 gpm).

A well inventory included in the Stations USFAR cites the total depth of the quarry supply well as 130 feet bgs, with a yield of 100 gpm and typical operation of 50 gpm for ten hours a day.

The Station has one potable supply well and one fire water well. The potable supply well is constructed as an open-rock borehole. Groundwater was measured at a depth 102 feet bgs during a well pump replacement in 2014. The pump was placed at a depth of approximately 294 feet bgs. The total well depth and the depth of the steel casing are approximately 310 feet bgs. The well is located approximately 175 feet east of the Reactor Building. The potable supply well is sampled as part of the RGPP and designated as DW-LR-1. In 2023, DW-LR-1 pumped 5,539,400 gallons.

The fire water well is constructed as an open-rock borehole. Groundwater was encountered at 121 feet bgs during a well pump replacement in 2004. The well pump was placed at a depth of approximately 399 feet bgs. The total well depth and the depth of the steel casing are unknown. The well is located approximately 500 feet east of the cooling towers. The well is used in an emergency fire situation and for system testing and flushing. In 2023, 813,117 gallons were pumped from the well.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 105 D. Summary of Results - Inter-Laboratory Comparison Program Inter-Laboratory Comparison Program results for TBE are presented in the Annual Radiological Environmental Operating Report. In addition, the results for interlaboratory comparison RGPP samples are included in the data tables in Appendix E.

E. Leaks, Spills, and Releases There were no spills to ground containing radioactive material in 2023.

F. Trends Low level tritium detections in monitoring well MW-LR-9 are being trended.

G. Investigations Intermittent, low-level tritium detections in monitoring well MW-LR-9 are currently being investigated.

H. Actions Taken

1. Compensatory Actions There have been no station events requiring compensatory actions at the Limerick Generating Station.

2. Installation of Monitoring Wells No new monitoring wells.

3. Actions to Recover/Reverse Plumes No actions were required to recover or reverse groundwater plumes.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 106 V.

References

1. GHD, Inc. Hydrogeologic Investigation Report, Limerick Generating Station, 3146 Sanatoga Road, Pottstown, Pennsylvania, Ref. No. 11189800(1), December 2019

2. Pre-operational Radiological Environmental Monitoring Program Report, Limerick Generating Station Units 1 and 2, 1 January 1982 through 21 December 1984, Teledyne Isotopes and Radiation Management Corporation

3. 2023 Annual RGPP Monitoring Report Summary of Results and Conclusions, Limerick Generating Station, AMO Environmental Decisions, Pottstown, Pennsylvania, January 26, 2024.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 107 TABLE OF CONTENTS - ANALYTICAL RESULTS Table Title Page E-1 Locations of Onsite Radiological Groundwater Protection Program, Limerick Generating Station, 2023........................................................................................ 108 E-2 Concentration of Radiostrontium in Groundwater................................................................. 111 E-3 Concentration of Tritium in Groundwater...112 E-4 Concentration of Tritium in Surface Water, Precipitation, and Subsurface Drainage............ 113 Figure Title Page E-1 Routine Well Water Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2023..................................................... 109 E-2 Routine Precipitation Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2023..................................................... 110

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 108 TABLE E-1 Locations of Onsite Radiological Groundwater Protection Program Limerick Generating Station, 2023 RGPP Description MW-LR-1 Monitoring Well MW-LR-2 Monitoring Well MW-LR-3 Monitoring Well MW-LR-4 Monitoring Well MW-LR-5 Monitoring Well MW-LR-6 Monitoring Well MW-LR-7 Monitoring Well MW-LR-8 Monitoring Well MW-LR-9 Monitoring Well MW-LR-10 Monitoring Well P3 Monitoring Well P11 Monitoring Well P14 Monitoring Well P17 Monitoring Well DW-LR-1 Monitoring Well 36S3 Precipitation Water E-5 Precipitation Water ESE-6 Precipitation Water RS-1 Precipitation Water RS-2 Precipitation Water RS-3 Precipitation Water RS-4 Precipitation Water RS-5 Precipitation Water RS-6 Precipitation Water RS-7 Precipitation Water RS-8 Precipitation Water SE-7 Precipitation Water

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 109 Figure E-1 Routine Well Water Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2023 MW-LR-9 MW-LR-5 0

400 MW-LR-1

800 Feet

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 110 Figure E-2 Routine Precipitation Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2023

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Figure 3 2021 Precipit:ttion Recapture Sample Locations Exelon Corpot'ation Limerick Generati"9 Station

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 111 Table E-2 Concentration of Radiostrontium in Groundwater (Results in units of pCi/L +/- 2)

Station Sample Date SR-89 (pCi/L)

SR-90 (pCi/L)

MW-LR-4 04/11/2023

<7.31

<0.828 MW-LR-4(Dup) 04/11/2023

<8.24

<0.852 MW-LR-4(QA) 04/11/2023

<1.58

<0.997 P14 04/12/2023

<6.57

<0.91 MW-LR-10 04/12/2023

<6.5

<0.837 MW-LR-9 04/12/2023

<6.92

<0.942 MW-LR-8 04/12/2023

<6.27

<0.849 MW-LR-8(Dup) 04/12/2023

<7.54

<0.745 MW-LR-8(QA) 04/12/2023

<1.12

<0.492 P11 04/12/2023

<7.52

<0.874 MW-LR-1 04/11/2023

<7.95

<0.814 (Dup) -Sample analyzed in duplicate by TBE.

(QA) -Additional sample collected and analyzed for Quality Assurance by GEL Laboratory

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 112 Table E-3 Concentration of Tritium in Groundwater (Results in units of pCi/L +/- 2)

LOCATION 1/24/2023 2/27/2023 3/24/2023 4/11/2023 4/12/2023 5/26/2023 6/27/2023 7/31/2023 8/1/2023 8/25/2023 9/27/2023 10/23/2023 10/24/2023 DW-LR-1

<176 ND ND

<195 ND ND ND ND

<183 ND ND ND

<195 MW-LR-1 ND ND ND

<193 ND ND ND ND ND ND ND ND ND MW-LR-2 ND ND ND

<186 ND ND ND ND ND ND ND ND ND MW-LR-3 ND ND ND 234+/-130 ND ND ND ND ND ND ND ND ND MW-LR-4

<176 ND ND

<192 ND ND ND ND

<184 ND ND ND

<185 MW-LR-4 (Dup)

ND ND ND

<195 ND ND ND ND ND ND ND ND ND MW-LR-4 (QA)

ND ND ND

<136 ND ND ND ND ND ND ND ND ND MW-LR-5 ND ND ND

<195 ND ND ND ND ND ND ND ND ND MW-LR-7 ND ND ND

<196 ND ND ND ND ND ND ND ND ND MW-LR-8 399+/-124 ND ND ND 437+/-135 ND ND ND 455+/-133 ND ND ND 553+/-141 MW-LR-8 (Dup)

ND ND ND ND 416+/-135 ND ND ND ND ND ND ND ND MW-LR-8 (QA)

ND ND ND ND 316+/-124 ND ND ND ND ND ND ND ND MW-LR-9 2290+/-294 1540+/-225 2010+/-267 ND 1850+/-258 1510+/-229 2120+/-283 2470+/-312 ND 2300+/-303 2310+/-300 ND 3270+/-396 MW-LR-9(Dup) 2480+/-313 ND ND ND ND ND ND 3040+/-376 ND ND ND ND ND MW-LR-9 (QA) 2320+/-226 ND ND ND ND ND ND 1920+/-210 ND ND ND 2610+/-246 ND MW-LR-10

<177 ND ND ND

<191 ND ND ND

<184 ND ND ND

<187 LR-P11

<179 ND ND ND

<194 ND ND ND

<196 ND ND ND

<189 LR-P14 180+/-116 ND ND ND

<191 ND ND ND

<184 ND ND ND

<188 LR-P17 ND ND ND 204+/-128 ND ND ND ND ND ND ND ND ND ND - No Data, Sample obtained as required.

(Dup) -Sample analyzed in duplicate by TBE.

(QA) -Additional sample collected and analyzed for Quality Assurance by GEL Laboratory.

January 1 - December 31, 2023 Docket Nos. 50-352, 50-353 113 ND - No Data, Sample obtained as required.

Table E-4 Concentration of Tritium in Surface Water, Precipitation, and Subsurface Drainage (Results in units of pCi/L +/- 2)

LOCATION 5/19/2023 11/20/2023 RS-1

<191

<180 RS-2

<184

<180 RS-3

<190

<188 RS-4

<187

<180 RS-5

<186

<193 RS-6

<187

<175 RS-7

<189

<200 RS-8 382+/-129

<191 SE-7

<185 ND ESE-6

<184 ND E-5

<187 ND

LG-24-052, 2023 Annual Radiological Environmental Operating Report

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SUMMARY

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