ML051370558

Annual Radiological Environmental Operating Report for January 1 Through December 31, 2004

ML051370558
Person / Time
Site:	Pilgrim
Issue date:	05/10/2005
From:	Ford B Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.05.037
Download: ML051370558 (108)

Text

Entergy Nuclear Operations, Inc.

I Entergy Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 May 10, 2005 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Annual Radiological Environmental Operating Report for January 1 through December 31, 2004 LETTER NUMBER: 2.05.037

Dear Sir or Madam:

In accordance with Pilgrim Technical Specification 5.6.2, Entergy Nuclear Operations, Inc. submits the attached Annual Radiological Environmental Monitoring Program Report for January 1 through December 31, 2004.

Should you have questions or require additional information, I can be contacted at (508) 830-8403.

This letter contains no commitments.

Sincerely, Bryan Ford 11-WGL/dm

Attachment:

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report, January 1 through December 31, 2004 cc: U.S. Nuclear Regulatory Commission Mr. John P. Boska, Project Manager Region I Office of Nuclear Reactor Regulation 475 Allendale Road Mail Stop: 0-8B-1 King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Senior Resident Inspector Rockville, MD 20852 205037

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Radiological Environmental Monitoring Program Report January 1 through December 31, 2004 Entergy

'Entergy PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REPORT JANUARY 01 THROUGH DECEMBER 31, 2004 K.J. Sejkora I /

Prepared by: -

K.J. Sejkora /

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D.C.i P Pr Radiation Protection Page 1

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2004 TABLE OF CONTENTS SECTION SECTION TITLE PAGE EXECUTIVE

SUMMARY

5

1.0 INTRODUCTION

7 1.1 Radiation and Radioactivity 7 1.2 Sources of Radiation 8 1.3 Nuclear Reactor Operations 9 1.4 Radioactive Effluent Control 15 1.5 Radiological Impact on Humans 17 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 21 2.1 Pre-Operational Monitoring Results 21 2.2 Environmental Monitoring Locations 22 2.3 Interpretation of Radioactivity Analyses Results 24 2.4 Ambient Radiation Measurements 25 2.5 Air Particulate Filter Radioactivity Analyses 26 2.6 Charcoal Cartridge Radioactivity Analyses 26 2.7 Milk Radioactivity Analyses 27 2.8 Forage Radioactivity Analyses 27 2.9 VegetableNegetation Radioactivity Analyses 27 2.10 Cranberry Radioactivity Analyses 28 2.11 Soil Radioactivity Analyses 28 2.12 Surface Water Radioactivity Analyses 28 2.13 Sediment Radioactivity Analyses 28 2.14 Irish Moss Radioactivity Analyses 29 2.15 Shellfish Radioactivity Analyses 29 2.16 Lobster Radioactivity Analyses 29 2.17 Fish Radioactivity Analyses 30 3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS 64

4.0 REFERENCES

66 APPENDIX A Special Studies 67 APPENDIX B Effluent Release Information 68 APPENDIX C Land Use Census 78 APPENDIX D Environmental Monitoring Program Discrepancies 79 APPENDIX E J.A. Fitzpatrick Interlaboratory Comparison Program 82 Page 2

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2004 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 8 1.3-1 PNPS Operating Capacity Factor During 2004 9 2.2-1 Routine Radiological Environmental Sampling Locations 31 2.4-1 Offsite Environmental TLD Results 33 2.4-2 Onsite Environmental TLD Results 35 2.4-3 Average TLD Exposures By Distance Zone During 2004 36 2.5-1 Air Particulate Filter Radioactivity Analyses 37 2.6-1 Charcoal Cartridge Radioactivity Analyses 38 2.7-1 Milk Radioactivity Analyses 39 2.8-1 Forage Radioactivity Analyses 40 2.9-1 VegetableNegetation Radioactivity Analyses 41 2.10-1 Cranberry Radioactivity Analyses 42 2.12-1 Surface Water Radioactivity Analyses 43 2.13-1 Sediment Radioactivity Analyses 44 2.14-1 Irish Moss Radioactivity Analyses 45 2.15-1 Shellfish Radioactivity Analyses 46 2.16-1 Lobster Radioactivity Analyses 47 2.17-1 Fish Radioactivity Analyses 48 3.0-1 Radiation Doses From 2004 Pilgrim Station Operations 65 B.1 Supplemental Information 69 B.2-A Gaseous Effluents Summation of All Releases 70 B.2-B Gaseous Effluents - Elevated Releases 71 B.2-C Gaseous Effluents - Ground Level Releases 73 B.3-A Liquid Effluents Summation of All Releases 75 B.3-B Liquid Effluents: January-June 2004 76 E.3-1 Ratio of Agreement 84 E.4-1 Interlaboratory Intercomparison Program 88 Page 3

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2004 LIST OF FIGURES FIGURE FIGURE TITLE PAGE 1.3-1 Radioactive Fission Product Formation 1 1.3-2 Radioactive Activation Product Formation 12 1.3-3 Barriers to Confine Radioactive Materials 13 1.5-1 Radiation Exposure Pathways 18 2.2-1 Environmental TLD Locations Within the PNPS Protected Area 49 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer 51 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers 53 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers 55 2.2-5 Terrestrial and Aquatic Sampling Locations 57 2.2-6 Environmental Sampling and Measurement Control Locations 59 2.5-1 Airborne Gross Beta Radioactivity Levels: Near Station 61 2.5-2 Airborne Gross Beta Radioactivity Levels: Property Line 62 2.5-3 Airborne Gross Beta Radioactivity Levels: Offsite 63 Page 4

EXECUTIVE

SUMMARY

ENTERGY NUCLEAR PILGRIM NUCLEAR POWER STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REPORT JANUARY 01 THROUGH DECEMBER 31, 2004 INTRODUCTION This report summarizes the results of the Entergy Nuclear Radiological Environmental Monitoring Program (REMP) conducted in the vicinity of Pilgrim Nuclear Power Station (PNPS) during the period from January 1 to December 31, 2004. This document has been prepared in accordance with the requirements of PNPS Technical Specifications section 5.6.2.

The REMP has been established to monitor the radiation and radioactivity released to the environment as a result of Pilgrim Station's operation. This program, initiated in August 1968, includes the collection, analysis, and evaluation of radiological data in order to assess the impact of Pilgrim Station on the environment and on the general public.

SAMPLING AND ANALYSIS The environmental sampling media collected in the vicinity of PNPS and at distant locations included air particulate filters, charcoal cartridges, seawater, shellfish, Irish moss, American lobster, fishes, sediment, milk, cranberries, vegetation, and animal forage.

During 2004, there were 1,254 samples collected from the atmospheric, aquatic and terrestrial environments. In addition, 429 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs).

A small number of inadvertent issues were encountered during 2004 in the collection of environmental samples in accordance with the PNPS Offsite Dose Calculation Manual (ODCM). Eleven out of 440 TLDs were unaccounted for during the quarterly retrieval process. However, the 429 TLDs that were collected provided the information necessary to assess ambient radiation levels in the vicinity of Pilgrim Station.

Equipment failures and power outages resulted in a small number of instances in which lower than normal volumes were collected at the airborne sampling stations. In some cases, outages were of sufficient duration to yield no sample, and 571 of 572 air particulate and charcoal cartridges were collected and analyzed as required. A full description of any discrepancies encountered with the environmental monitoring program is presented in Appendix D of this report.

There were 1,298 analyses performed on the environmental media samples. Analyses were performed by the J.A. Fitzpatrick Environmental Laboratory in Fulton, New York. Samples were analyzed as required by the PNPS ODCM.

LAND USE CENSUS The annual land use census in the vicinity of Pilgrim Station was conducted as required by the PNPS ODCM between July 15 and October 28, 2004. A total of 31 vegetable gardens having an area of more than 500 square feet were identified within five kilometers (three miles) of PNPS. No new milk or meat animals were located during the census. Of the 31 garden locations identified, samples were collected at or near four of the gardens as part of the environmental monitoring program.

RADIOLOGICAL IMPACT TO THE ENVIRONMENT During 2004, samples (except charcoal cartridges) collected as part of the REMP at Pilgrim Station continued to contain detectable amounts of naturally-occurring and man-made radioactive materials. No samples indicated any detectable radioactivity attributable to Pilgrim Station Operations. Offsite ambient radiation measurements using environmental TLDs beyond the site boundary ranged between 61 and 93 Page 5

milliRoentgens per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts as determined by the Environmental Protection Agency (EPA).

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2004, radiation doses to the general public as a result of Pilgrim Station's operation continued to be well below the federal limits and much less than the dose due to other sources of man-made (e.g., X-rays, medical, fallout) and naturally-occurring (e.g., cosmic, radon) radiation.

The calculated total body dose to the maximally exposed member of the general public from radioactive effluents and ambient radiation resulting from PNPS operations for 2004 was about 2.3 mrem for the year.

This conservative estimate is well below the EPA's annual dose limit to any member of the general public and is a fraction of a percent of the typical dose received from natural and man-made radiation.

CONCLUSIONS The 2004 Radiological Environmental Monitoring Program for Pilgrim Station resulted in the collection and analysis of hundreds of environmental samples and measurements. The data obtained were used to determine the impact of Pilgrim Station's operation on the environment and on the general public.

An evaluation of direct radiation measurements, environmental sample analyses, and dose calculations showed that all applicable federal criteria were met. Furthermore, radiation levels and resulting doses were a small fraction of those that are normally present due to natural and man-made background radiation.

Based on this information, there is no significant radiological impact on the environment or on the general public due to Pilgrim Station's operation.

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1.0 INTRODUCTION

The Radiological Environmental Monitoring Program for 2004 performed by Entergy Nuclear Company for Pilgrim Nuclear Power Station (PNPS) is discussed in this report. Since the operation of a nuclear power plant results in the release of small amounts of radioactivity and low levels of radiation, the Nuclear Regulatory Commission (NRC) requires a program to be established to monitor radiation and radioactivity in the environment (Reference 1). This report, which is required to be published annually by Pilgrim Station's Technical Specifications section 5.6.2, summarizes the results of measurements of radiation and radioactivity in the environment in the vicinity of the Pilgrim Station and at distant locations during the period January 1 to December 31, 2004.

The Radiological Environmental Monitoring Program consists of taking radiation measurements and collecting samples from the environment, analyzing them for radioactivity content, and interpreting the results. With emphasis on the critical radiation exposure pathways to humans, samples from the aquatic, atmospheric, and terrestrial environments are collected. These samples include, but are not limited to: air, soil, seawater, shellfish, lobster, fishes, milk, cranberries, vegetables, and forage. Thermoluminescent dosimeters (TLDs) are placed in the environment to measure gamma radiation levels. The TLDs are processed and the environmental samples are analyzed to measure the very low levels of radiation and radioactivity present in the environment as a result of PNPS operation and other natural and man-made sources. These results are reviewed by PNPS's radiological staff and have been reported semiannually or annually to the Nuclear Regulatory Commission and others since 1972.

In order to more fully understand how a nuclear power plant impacts humans and the environment, background information on radiation and radioactivity, natural and man-made sources of radiation, reactor operations, radioactive effluent controls, and radiological impact on humans is provided. It is believed that this information will assist the reader in understanding the radiological impact on the environment and humans from the operation of Pilgrim Station.

1.1 Radiation and Radioactivity All matter is made of atoms. An atom is the smallest part into which matter can be broken down and still maintain all its chemical properties. Nuclear radiation is energy, in the form of waves or particles that is given off by unstable, radioactive atoms.

Radioactive material exists naturally and has always been a part of our environment. The earth's crust, for example, contains radioactive uranium, radium, thorium, and potassium. Some radioactivity is a result of nuclear weapons testing. Examples of radioactive fallout that is normally present in environmental samples are cesium-137 and strontium-90. Some examples of radioactive materials released from a nuclear power plant are cesium-1 37, iodine-1 31, strontium-90, and cobalt-60.

Radiation is measured in units of millirem, much like temperature is measured in degrees. A millirem is a measure of the biological effect of the energy deposited in tissue. The natural and man-made radiation dose received in one year by the average American is 300 to 400 mrem (References 2, 3, 4).

Radioactivity is measured in curies. A curie is that amount of radioactive material needed to produce 37,000,000,000 nuclear disintegrations per second. This is an extremely large amount of radioactivity in comparison to environmental radioactivity. That is why radioactivity in the environment is measured in picocuries. One picocurie is equal to one trillionth of a curie.

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1.2 Sources of Radiation As mentioned previously, naturally occurring radioactivity has always been a part of our environment.

Table 1.2-1 shows the sources and doses of radiation from natural and man-made sources.

Table 1.2-1 Radiation Sources and Corresponding Doses NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem/year)

Cosmic/cosmogenic 30 Medical/Dental X-Rays 39 Internal 40 Nuclear Medicine 14 Terrestrial 30 Consumer Products 10 Radon/Thoron 200 Weapons Fallout 1 Nuclear Power Plants 1 Approximate Total J 300 Approximate Total 60 Cosmic radiation from the sun and outer space penetrates the earth's atmosphere and continuously bombards us with rays and charged particles. Some of this cosmic radiation interacts with gases and particles in the atmosphere, making them radioactive in turn. These radioactive byproducts from cosmic ray bombardment are referred to as cosmogenic radionuclides. Isotopes such as beryllium-7 and carbon-14 are formed in this way. Exposure to cosmic and cosmogenic sources of radioactivity results in about 30 mrem of radiation dose per year.

Additionally, natural radioactivity is in our body and in the food we eat (about 40 millirem/yr), the ground we walk on (about 30 millirem/yr) and the air we breathe (about 200 millirem/yr). The majority of a person's annual dose results from exposure to radon and thoron in the air we breathe. These gases and their radioactive decay products arise from the decay of naturally occurring uranium, thorium and radium in the soil and building products such as brick, stone, and concrete. Radon and thoron levels vary greatly with location, primarily due to changes in the concentration of uranium and thorium in the soil. Residents at some locations in Colorado, New York, Pennsylvania, and New Jersey have a higher annual dose as a result of higher levels of radon/thoron gases in these areas. In total, these various sources of naturally-occurring radiation and radioactivity contribute to a total dose of about 300 mrem per year.

In addition to natural radiation, we are normally exposed to radiation from a number of man-made sources.

The single largest doses from man-made sources result from therapeutic and diagnostic applications of x-rays and radiopharmaceuticals. The annual dose to an individual in the U.S. from medical and dental exposure is about 50 mrem. Consumer products, such as televisions and smoke detectors, contribute about 10 mrem/yr. Much smaller doses result from weapons fallout (less than 1 mrem/yr) and nuclear power plants (less than 1 mrem/yr). Typically, the average person in the United States receives about 60 mrem per year from man-made sources.

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1.3 Nuclear Reactor Ooerations Pilgrim Station generates about 700 megawatts of electricity at full power, which is enough electricity to supply the entire city of Boston, Massachusetts. Pilgrim Station is a boiling water reactor whose nuclear steam supply system was provided by General Electric Co. The nuclear station is located on a 1600-acre site about eight kilometers (five miles) east-southeast of Plymouth Center. Commercial operation began in December 1972.

Pilgrim Station was operational during most of 2004. The resulting monthly capacity factors are presented in Table 1.3-1.

TABLE 1.3-1 PNPS OPERATING CAPACITY FACTOR DURING 2004 (Based on rated reactor thermal power)

Month Percent Capacity January 100.0%

February 99.9%

March 89.3%

April 100.0%

May 100.0%

June 99.3%

July 99.2%

August 99.9%

September 98.2%

October 99.9%

November 98.8%

December 99.9%

Annual Average 98.7%

Nuclear-generated electricity is produced at Pilgrim Station by many of the same techniques used for conventional oil and coal-generated electricity. Both systems use heat to boil water to produce steam.

The steam turns a turbine, which turns a generator, producing electricity. In both cases, the steam passes through a condenser where it changes back into water and recirculates back through the system. The cooling water source for Pilgrim Station is the Cape Cod Bay.

The key difference between Pilgrim's nuclear power and conventional power is the source of heat used to boil the water. Conventional plants burn fossil fuels in a boiler, while nuclear plants make use of uranium in a nuclear reactor.

Inside the reactor, a nuclear reaction called fission takes place. Particles, called neutrons, strike the nucleus of a uranium-235 atom, causing it to split into fragments called radioactive fission products. The splitting of the atoms releases both heat and more neutrons. The newly-released neutrons then collide with and split other uranium atoms, thus making more heat and releasing even more neutrons, and on and on until the uranium fuel is depleted or spent. This process is called a chain reaction.

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The operation of a nuclear reactor results in the release of small amounts of radioactivity and low levels of radiation. The radioactivity originates from two major sources, radioactive fission products and radioactive activation products.

Radioactive fission products, as illustrated in Figure 1.3-1 (Reference 5), originate from the fissioning of the nuclear fuel. These fission products get into the reactor coolant from their release by minute amounts of uranium on the outside surfaces of the fuel cladding, by diffusion through the fuel pellets and cladding and, on occasion, through defects or failures in the fuel cladding. These fission products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive fission products on the pipes and equipment emit radiation. Examples of some fission products are krypton-85 (Kr-85), strontium-90 (Sr-90), iodine-131 (1-131), xenon-133 (Xe-133), and cesium-137 (Cs-137).

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Nuclear Fission Fission is the splitting of the uranium-235 atom by a neutron to release heat and more neutrons, creating a chain reaction.

Radiation and fission products are by-products of the process.

R-adiation Uranium Neutrons SRadiation Ik Neutron 0-o Neutrons Uranium Uranium Fission Products Figure 1.3-1 Radioactive Fission Product Formation Page 11

Radioactive activation products (see Figure 1.3-2), on the other hand, originate from two sources. The first is by neutron bombardment of the hydrogen, oxygen and other gas (helium, argon, nitrogen) molecules in the reactor cooling water. The second is a result of the fact that the internals of any piping system or component are subject to minute yet constant corrosion from the reactor cooling water. These minute metallic particles (for example: nickel, iron, cobalt, or magnesium) are transported through the reactor core into the fuel region, where neutrons may react with the nuclei of these particles, producing radioactive products. So, activation products are nothing more than ordinary naturally-occurring atoms that are made unstable or radioactive by neutron bombardment. These activation products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive activation products on the pipes and equipment emit radiation. Examples of some activation products are manganese-54 (Mn-54), iron-59 (Fe-59), cobalt-60 (Co-60), and zinc-65 (Zn-65).

- In)( -.. mu ( Co-60 Stable Radioactive Neutron Cobalt Nucleus Cobalt Nucleus Figure 1.3-2 Radioactive Activation Product Formation At Pilgrim Nuclear Power Station there are five independent protective barriers that confine these radioactive materials. These five barriers, which are shown in Figure 1.3-3 (Reference 5), are:

• fuel pellets;

• fuel cladding;

• reactor vessel and piping;

• primary containment (drywell and torus); and,

• secondary containment (reactor building).

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4. PRIMARY CONTAINMENT

3. REACTOR VESSEL

1. FUEL PELLETS

2. FUEL CLADDING 5. SE( :ONDARY CONTAINMENT

/ A V--

REACTOR BUIDING DRYWELL Figure 1.3-3 Barriers To Confine Radioactive Materials Page 13

The ceramic uranium fuel pellets provide the first barrier. Most of the radioactive fission products are either physically trapped or chemically bound between the uranium atoms, where they will remain.

However, a few fission products that are volatile or gaseous may diffuse through the fuel pellets into small gaps between the pellets and the fuel cladding.

The second barrier, the fuel cladding, consists of zirconium alloy tubes that confine the fuel pellets. The small gaps between the fuel and the cladding contain the noble gases and volatile iodines that are types of radioactive fission products. This radioactivity can diffuse to a small extent through the fuel cladding into the reactor coolant water.

The third barrier consists of the reactor pressure vessel, steel piping and equipment that confine the reactor cooling water. The reactor pressure vessel, which holds the reactor fuel, is a 65-foot high by 19-foot diameter tank with steel walls about nine inches thick. This provides containment for radioactivity in the primary coolant and the reactor core. However, during the course of operations and maintenance, small amounts of radioactive fission and activation products can escape through valve leaks or upon breaching of the primary coolant system for maintenance.

The fourth barrier is the primary containment. This consists of the drywell and the torus. The drywell is a steel lined enclosure that is shaped like an inverted light bulb. An approximately five foot thick concrete wall encloses the drywell's steel pressure vessel. The torus is a donut-shaped pressure suppression chamber. The steel walls of the torus are nine feet in diameter with the donut itself having an outside diameter of about 130 feet. Small amounts of radioactivity may be released from primary containment during maintenance.

The fifth barrier is the secondary containment or reactor building. The reactor building is the concrete building that surrounds the primary containment. This barrier is an additional safety feature to contain radioactivity that may escape from the primary containment. This reactor building is equipped with a filtered ventilation system that is used when needed to reduce the radioactivity that escapes from the primary containment.

The five barriers confine most of the radioactive fission and activation products. However, small amounts of radioactivity do escape via mechanical failures and maintenance on valves, piping, and equipment associated with the reactor cooling water system. The small amounts of radioactive liquids and gases that do escape the various containment systems are further controlled by the liquid purification and ventilation filtration systems. Also, prior to a release to the environment, control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable. The control of radioactive effluents at Pilgrim Station will be discussed in more detail in the next section.

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1.4 Radioactive Effluent Control The small amounts of radioactive liquids and gases that might escape the five barriers are purified in the liquid and gaseous waste treatment systems, then monitored for radioactivity, and released only if the radioactivity levels are below the federal release limits.

Radioactivity released from the liquid effluent system to the environment is limited, controlled, and monitored by a variety of systems and procedures which include:

• reactor water cleanup system;

• liquid radwaste treatment system;

• sampling and analysis of the liquid radwaste tanks; and,

• liquid waste effluent discharge header radioactivity monitor.

The purpose of the reactor water cleanup system is to continuously purify the reactor cooling water by removing radioactive atoms and non-radioactive impurities that may become activated by neutron bombardment. A portion of the reactor coolant water is diverted from the primary coolant system and is directed through ion exchange resins where radioactive elements, dissolved and suspended in the water, are removed through chemical processes. The net effect is a substantial reduction of the radioactive material that is present in the primary coolant water and consequently the amount of radioactive material that might escape from the system.

Reactor cooling water that might escape the primary cooling system and other radioactive water sources are collected in floor and equipment drains. These drains direct this radioactive liquid waste to large holdup tanks. The liquid waste collected in the tanks is purified again using the liquid radwaste treatment system, which consists of a filter and ion exchange resins.

Processing of liquid radioactive waste results in large reductions of radioactive liquids discharged into Cape Cod Bay. Of all wastes processed through liquid radwaste treatment, 90 to 95 percent of all wastes are purified and the processed liquid is re-used in plant systems.

Prior to release, the radioactivity in the liquid radwaste tank is sampled and analyzed to determine if the level of radioactivity is below the release limits and to quantify the total amount of radioactive liquid effluent that would be released. If the levels are below the federal release limits, the tank is drained to the liquid effluent discharge header.

This liquid waste effluent discharge header is provided with a shielded radioactivity monitor. This detector is connected to a radiation level meter and a strip chart recorder in the Control Room. The radiation alarm is set so that the detector will alarm before radioactivity levels exceed the release limits. The liquid effluent discharge header has an isolation valve. If an alarm is received, the liquid effluent discharge valve will automatically close, thereby terminating the release to the Cape Cod Bay and preventing any liquid radioactivity from being released that may exceed the release limits. An audible alarm notifies the Control Room operator that this has occurred.

Some liquid waste sources which have a low potential for containing radioactivity, and/or may contain very low levels of contamination, may be discharged directly to the discharge canal without passing through the liquid radwaste discharge header. One such source of liquids is the neutralizing sump. However, prior to discharging such liquid wastes, the tank is thoroughly mixed and a representative sample is collected for analysis of radioactivity content prior to being discharged.

Another means for adjusting liquid effluent concentrations to below federal limits is by mixing plant cooling water from the condenser with the liquid effluents in the discharge canal. This larger volume of cooling water further dilutes the radioactivity levels far below the release limits.

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The preceding discussion illustrates that many controls exist to reduce the radioactive liquid effluents released to the Cape Cod Bay to as far below the release limits as is reasonably achievable.

Radioactive releases from the radioactive gaseous effluent system to the environment are limited, controlled, and monitored by a variety of systems and procedures which include:

• reactor building ventilation system;

• reactor building vent effluent radioactivity monitor;

• sampling and analysis of reactor building vent effluents;

• standby gas treatment system;

• main stack effluent radioactivity monitor and sampling;

• sampling and analysis of main stack effluents;

• augmented off-gas system;

• steam jet air ejector (SJAE) monitor; and,

• off-gas radiation monitor.

The purpose of the reactor building ventilation system is to collect and exhaust reactor building air. Air collected from contaminated areas is filtered prior to combining it with air collected from other parts of the building. This combined airflow is then directed to the reactor building ventilation plenum that is located on the side of the reactor building. This plenum, which vents to the atmosphere, is equipped with a radiation detector. The radiation level meter and strip chart recorder for the reactor building vent effluent radioactivity monitor is located in the Control Room. To supplement the information continuously provided by the detector, air samples are taken periodically from the reactor building vent and are analyzed to quantify the total amount of tritium and radioactive gaseous and particulate effluents released.

If air containing elevated amounts of noble gases is routed past the reactor building vent's effluent radioactivity monitor, an alarm will alert the Control Room operators that release limits are being approached. The Control Room operators, according to procedure, will isolate the reactor building ventilation system and initiate the standby gas treatment system to remove airborne particulates and gaseous halogen radioactivity from the reactor building exhaust. This filtration assembly consists of high-efficiency particulate air filters and charcoal adsorber beds. The purified air is then directed to the main stack. The main stack has dilution flow that further reduces concentration levels of gaseous releases to the environment to as far below the release limits as is reasonably achievable.

The approximately 335 foot tall main stack has a special probe inside it that withdraws a portion of the air and passes it through a radioactivity monitoring system. This main stack effluent radioactivity monitoring system continuously samples radioactive particulates, iodines, and noble gases. Grab samples for a tritium analysis are also collected at this location. The system also contains radioactivity detectors that monitor the levels of radioactive noble gases in the stack flow and display the result on radiation level meters and strip chart recorders located in the Control Room. To supplement the information continuously provided by the detectors, the particulate, iodine, tritium, and gas samples are analyzed periodically to quantify the total amount of radioactive gaseous effluent being released.

The purpose of the augmented off-gas system is to reduce the radioactivity from the gases that are removed from the condenser. This purification system consists of two 30-minute holdup lines to reduce the radioactive gases with short half-lives, several charcoal adsorbers to remove radioactive iodines and further retard the short half-life gases, and offgas filters to remove radioactive particulates. The recombiner collects free hydrogen and oxygen gas and recombines them into water. This helps reduce the gaseous releases of short-lived isotopes of oxygen that have been made radioactive by neutron activation.

The radioactive off-gas from the condenser is then directed into a ventilation pipe to which the off-gas radiation monitors are attached. The radiation level meters and strip chart recorders for this detector are also located in the Control Room. If a radiation alarm setpoint is exceeded, an audible alarm will sound to Page 16

alert the Control Room operators. In addition, the off-gas bypass and charcoal adsorber inlet valve will automatically re-direct the off-gas into the charcoal adsorbers if they are temporarily being bypassed. If the radioactivity levels are not returned to below the alarm setpoint within 13 minutes, the off-gas releases will be automatically isolated, thereby preventing any gaseous radioactivity from being released that may exceed the release limits.

Therefore, for both liquid and gaseous releases, radioactive effluent control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable. The effluents are always monitored, sampled and analyzed prior to release to make sure that radioactivity levels are below the release limits. If the release limits are being approached, isolation valves in some of the waste effluent lines will automatically shut to stop the release, or Control Room operators will implement procedures to ensure that federal regulatory limits are always met.

1.5 Radiological Impact on Humans The final step in the effluent control process is the determination of the radiological dose impact to humans and comparison with the federal dose limits to the public. As mentioned previously, the purpose of continuous radiation monitoring and periodic sampling and analysis is to measure the quantities of radioactivity being released to determine compliance with the radioactivity release limits. This is the first stage for assessing releases to the environment.

Next, calculations of the dose impact to the general public from Pilgrim Station's radioactive effluents are performed. The purpose of these calculations is to periodically assess the doses to the general public resulting from radioactive effluents to ensure that these doses are being maintained as far below the federal dose limits as is reasonably achievable. This is the second stage for assessing releases to the environment.

The types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during each given year are reported to the Nuclear Regulatory Commission annually. The 2004 Radioactive Effluents are provided in Appendix B and will be discussed in more detail in Section 3 of this report. These liquid and gaseous effluents were well below the federal release limits and were a small percentage of the PNPS ODCM effluent control limits.

These measurements of the physical and chemical nature of the effluents are used to determine how the radionuclides will interact with the environment and how they can result in radiation exposure to humans.

The environmental interaction mechanisms depend upon factors such as the hydrological (water) and meteorological (atmospheric) characteristics in the area. Information on the water flow, wind speed, wind direction, and atmospheric mixing characteristics are used to estimate how radioactivity will distribute and disperse in the ocean and the atmosphere.

The most important type of information that is used to evaluate the radiological impact on humans is data on the use of the environment. Information on fish and shellfish consumption, boating usage, beach usage, locations of cows and goats, locations of residences, locations of gardens, drinking water supplies, and other usage information are utilized to estimate the amount of radiation and radioactivity received by the general public.

The radiation exposure pathway to humans is the path radioactivity takes from its release point at Pilgrim Station to its effect on man. The movement of radioactivity through the environment and its transport to humans is portrayed in Figure 1.5-1.

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EXAMPLES OF PILGRIM STATION'S RADIATION EXPOSURE PATHWAYS LIQUID EFFLUENTS

4. DIRECT RADIATION a (SOIL DEPOSITION)

(AIR SUBMERSION) 5/l

1. SHORELINE DIRECT RADIX (FISHING, PICNICJNG) 5. CONSUMPTION (VEGETATION) A DEPOSITION

2. DIRECT RADIATION (IMMERSION IN OCEAN, -I BOATING, SWIMMING) dl K"

6. CONSUMPTION DEPOSITION (MILK AND MEAT)

3. CONSUMPTION (FISH, SHELLFISH)

A..:

Figure 1.5-1 Radiation Exposure Pathways Page 18

There are three major ways in which liquid effluents affect humans:

• external radiation from liquid effluents that deposit and accumulate on the shoreline;

• external radiation from immersion in ocean water containing radioactive liquids; and,

• internal radiation from consumption of fish and shellfish containing radioactivity absorbed from the liquid effluents.

There are six major ways in which gaseous effluents affect humans:

• external radiation from an airborne plume of radioactivity;

• internal radiation from inhalation of airborne radioactivity;

• external radiation from deposition of radioactive effluents on soil;

• ambient (direct) radiation from contained sources at the power plant;

• internal radiation from consumption of vegetation containing radioactivity absorbed from the soil due to ground deposition of radioactive effluents; and,

• internal radiation from consumption of milk and meat containing radioactivity deposited on forage that is eaten by cattle and other livestock.

In addition, ambient (direct) radiation emitted from contained sources of radioactivity at PNPS contributes to radiation exposure in the vicinity of the plant. Radioactive nitrogen-16 contained in the steam flowing through the turbine accounts for the majority of this "sky shine" radiation exposure immediately adjacent to the plant. Smaller amounts of ambient radiation result from low-level radioactive waste stored at the site prior to shipping and disposal.

To the extent possible, the radiological dose impact on humans is based on direct measurements of radiation and radioactivity in the environment. When PNPS-related activity is detected in samples that represent a plausible exposure pathway, the resulting dose from such exposure is assessed (see Appendix A). However, the operation of Pilgrim Nuclear Power Station results in releases of only small amounts of radioactivity, and, as a result of dilution in the atmosphere and ocean, even the most sensitive radioactivity measurement and analysis techniques cannot usually detect these tiny amounts of radioactivity above that which is naturally present in the environment. Therefore, radiation doses are calculated using radioactive effluent release data and computerized dose calculations that are based on very conservative NRC-recommended models that tend to result in over-estimates of resulting dose.

These computerized dose calculations are performed by or for Entergy Nuclear personnel. These computer codes use the guidelines and methodology set forth by the NRC in Regulatory Guide 1.109 (Reference 6). The dose calculations are documented and described in detail in the Pilgrim Nuclear Power Station's Offsite Dose Calculation Manual (Reference 7), which has been reviewed by the NRC.

Monthly dose calculations are performed by PNPS personnel. It should be emphasized that because of the very conservative assumptions made in the computer code calculations, the maximum hypothetical dose to an individual is considerably higher than the dose that would actually be received by a real individual.

After dose calculations are performed, the results are compared to the federal dose limits for the public.

The two federal agencies that are charged with the responsibility of protecting the public from radiation and radioactivity are the Nuclear Regulatory Commission (NRC) and The Environmental Protection Agency (EPA).

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The NRC, in 10CFR 20.1301 (Reference 8) limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of:

• less than or equal to 100 mrem per year to the total body.

In addition to this dose limit, the NRC has established design objectives for nuclear plant licensees.

Conformance to these guidelines ensures that nuclear power reactor effluents are maintained as far below the legal limits as is reasonably achievable.

The NRC, in 10CFR 50 Appendix I (Reference 9) establishes design objectives for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to:

• less than or equal to 3 mrem per year to the total body; and,

• less than or equal to 10 mrem per year to any organ.

The air dose due to release of noble gases in gaseous effluents is restricted to:

• less than or equal to 10 mrad per year for gamma radiation; and,

• less than or equal to 20 mrad per year for beta radiation.

The dose to a member of the general public from iodine-131, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to:

• less than or equal to 15 mrem per year to any organ.

The EPA, in 40CFR190.10 Subpart B (Reference 10), sets forth the environmental standards for the uranium fuel cycle. During normal operation, the annual dose to any member of the public from the entire uranium fuel cycle shall be limited to:

• less than or equal to 25 mrem per year to the total body;

• less than or equal to 75 mrem per year to the thyroid; and,

• less than or equal to 25 mrem per year to any other organ.

The summary of the 2004 radiological impact for Pilgrim Station and comparison with the EPA dose limits and guidelines, as well as a comparison with natural/man-made radiation levels, is presented in Section 3 of this report.

The third stage of assessing releases to the environment is the Radiological Environmental Monitoring Program (REMP). The description and results of the REMP at Pilgrim Nuclear Power Station during 2004 is discussed in Section 2 of this report.

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2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.1 Pre-Onerational Monitoring Results The Radiological Environmental Monitoring Program (REMP) at Pilgrim Nuclear Power Station was first initiated in August 1968, in the form of a pre-operational monitoring program prior to bringing the station on-line. The NRC's intent (Reference 11) with performing a pre-operational environmental monitoring program is to:

• measure background levels and their variations in the environment in the area surrounding the licensee's station; and,

• evaluate procedures, equipment, and techniques for monitoring radiation and radioactivity in the environment.

The pre-operational program (Reference 12) continued for approximately three and a half years, from August 1968 to June 1972. Examples of background radiation and radioactivity levels measured during this time period are as follows:

• Airborne Radioactivity Particulate Concentration (gross beta): 0.02 - 1.11 pCVm 3;

• Ambient Radiation (TLDs): 4.2 - 22 micro-R/hr (37 - 190 mR/yr);

• Seawater Radioactivity Concentrations (gross beta): 12 - 31 pCiAiter;

• Fish Radioactivity Concentrations (gross beta): 2,200 - 11,300 pCi/kg;

• Milk Radioactive Cesium-137 Concentrations: 9.3 - 32 pCi/liter;

• Milk Radioactive Strontium-90 Concentrations: 4.7 - 17.6 pCiAiter;

• Cranberries Radioactive Cesium-137 Concentrations: 140 - 450 pCVkg;

• Forage Radioactive Cesium-1 37 Concentrations: 150 - 290 pCi/kg.

This information from the pre-operational phase is used as a basis for evaluating changes in radiation and radioactivity levels in the vicinity of the plant following plant operation. In April 1972, just prior to initial reactor startup (June 12, 1972), Boston Edison Company implemented a comprehensive operational environmental monitoring program at Pilgrim Nuclear Power Station. This program (Reference 13) provides information on radioactivity and radiation levels in the environment for the purpose of:

• demonstrating that doses to the general public and levels of radioactivity in the environment are within established limits and legal requirements;

• monitoring the transfer and long-term buildup of specific radionuclides in the environment to revise the monitoring program and environmental models in response to changing conditions;

• checking the condition of the station's operation, the adequacy of operation in relation to the adequacy of containment, and the effectiveness of effluent treatment so as to provide a mechanism of determining unusual or unforeseen conditions and, where appropriate, to trigger special environmental monitoring studies;

• assessing the dose equivalent to the general public and the behavior of radioactivity released during the unlikely event of an accidental release; and,

• determining whether or not the radiological impact on the environment and humans is significant.

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The Nuclear Regulatory Commission requires that Pilgrim Station provide monitoring of the plant environs for radioactivity that will be released as a result of normal operations, including anticipated operational occurrences, and from postulated accidents. The NRC has established guidelines (Reference 14) that specify an acceptable monitoring program. The PNPS Radiological Environmental Monitoring Program was designed to meet and exceed these guidelines. Guidance contained in the NRC's Radiological Assessment Branch Technical Position on Environmental Monitoring (Reference 15) has been used to improve the program. In addition, the program has incorporated the provisions of an agreement made with the Massachusetts Wildlife Federation (Reference 16). The program was supplemented by including improved analysis of shellfish and sediment at substantially higher sensitivity levels to verify the adequacy of effluent controls at Pilgrim Station.

2.2 Environmental Monitoring Locations Sampling locations have been established by considering meteorology, population distribution, hydrology, and land use characteristics of the Plymouth area. The sampling locations are divided into two classes, indicator and control. Indicator locations are those that are expected to show effects from PNPS operations, if any exist. These locations were primarily selected on the basis of where the highest predicted environmental concentrations would occur. While the indicator locations are typically within a few kilometers of the plant, the control stations are generally located so as to be outside the influence of Pilgrim Station. They provide a basis on which to evaluate fluctuations at indicator locations relative to natural background radiation and natural radioactivity and fallout from prior nuclear weapons tests.

The environmental sampling media collected in the vicinity of Pilgrim Station during 2004 included air particulate filters, charcoal cartridges, seawater, shellfish, Irish moss, American lobster, fishes, sediment, milk, cranberries, vegetation, and forage. The sampling medium, station description, station number, distance, and direction for indicator and control samples are listed in Table 2.2-1. These sampling locations are also displayed on the maps shown in Figures 2.2-1 through 2.2-6.

The radiation monitoring locations for the environmental TLDs are shown in Figures 2.2-1 through 2.2-4.

The frequency of collection and types of radioactivity analysis are described in Pilgrim Station's ODCM, Sections 3/4.5.

The land-based (terrestrial) samples and monitoring devices are collected by Entergy personnel. The aquatic samples are collected by Marine Research, Inc. The radioactivity analysis of samples and the processing of the environmental TLDs are performed by Entergy's J.A. Fitzpatrick Environmental Laboratory.

The frequency, types, minimum number of samples, and maximum lower limits of detection (LLD) for the analytical measurements, are specified in the PNPS ODCM. During 2004, a revision was made to the PNPS ODCM to standardize it to the model program described in NUREG-1302 (Reference 14) and the Branch Technical Position of 1979 (Reference 15). In accordance with this standardization, a number of changes occurred regarding the types and frequencies of sample collections.

In regard to terrestrial REMP sampling, routine collection and analysis of soil samples was discontinued in lieu of the extensive network of environmental TLDs around PNPS, and the weekly collection of air samples at 11 locations. Such TLD monitoring and air sampling would provide an early indication of any potential deposition of radioactivity, and follow-up soil sampling could be performed on an as-needed basis. Also, with the loss of the indicator milk sample at the Plymouth County Farm, it was deemed unnecessary to continue to collect and analyze control samples of milk. Consequently, routine milk sampling was also dropped from the terrestrial sampling program.

In the area of marine sampling, a number of the specialized sampling and analysis requirements implemented as part of the Agreement with the Massachusetts Wildlife Federation (Reference 16) for licensing of a second reactor at PNPS were dropped. This agreement, made in 1977, was predicated on the construction of a second nuclear unit, and was set to expire in 1987. However, since the specialized requirements were incorporated into the PNPS Technical Specifications at the time, the requirements were continued. When the ODCM was revised in 1999 in accordance with NRC Generic Letter 89-01, the Page 22

sampling program description was relocated to the ODCM. When steps were taken in 2004 to standardize the PNPS ODCM to the NUREG-1302 model, the specialized marine sampling requirements were changed to those of the model program. These changes include the following:

• A sample of the surface layer of sediment is collected, as opposed to specialized depth-incremental sampling to 30 cm and subdividing cores into 2 cm increments.

• Standard LLD levels of about 150 to 180 pCi/kg were established for sediment, as opposed to the specialized LLDs of 50 pCi/kg.

• Specialized analysis of sediment for plutonium isotopes was removed.

• Sampling of Irish moss, shellfish, and fish was rescheduled to a semiannual period, as opposed to a specialized quarterly sampling interval.

• Analysis of only the edible portions of shellfish (mussels and clams), as opposed to specialized additional analysis of the shell portions.

• Standard LLD levels of 130 to 260 pCi/kg were established for edible portions of shellfish, as opposed to specialized LLDs of 5 pCi/kg.

Upon receipt of the analysis results from the analytical laboratories, the PNPS staff reviews the results. If the radioactivity concentrations are above the reporting levels, the NRC must be notified within 30 days.

For radioactivity that is detected that is attributable to Pilgrim Station's operation, calculations are performed to determine the cumulative dose contribution for the current year. Depending upon the circumstances, a special study may also be completed (see Appendix A for 2004 special studies). Most importantly, if radioactivity levels in the environment become elevated as a result of the station's operation, an investigation is performed and corrective actions are recommended to reduce the amount of radioactivity to as far below the legal limits as is reasonably achievable.

The radiological environmental sampling locations are reviewed annually, and modified if necessary. A garden and milk animal census is performed every year to identify changes in the use of the environment in the vicinity of the station to permit modification of the monitoring and sampling locations. The results of the 2004 Garden and Milk Animal Census are reported in Appendix C.

The accuracy of the data obtained through Pilgrim Station's Radiological Environmental Monitoring Program is ensured through a comprehensive Quality Assurance (QA) programs. PNPS's QA program has been established to ensure confidence in the measurements and results of the radiological monitoring program through:

• Regular surveillances of the sampling and monitoring program;

• An annual audit of the analytical laboratory by the sponsor companies;

• Participation in cross-check programs;

• Use of blind duplicates for comparing separate analyses of the same sample; and,

• Spiked sample analyses by the analytical laboratory.

QA audits and inspections of the Radiological Environmental Monitoring Program are performed by the NRC, American Nuclear Insurers, and by the PNPS Quality Assurance Department.

The J.A. Fitzpatrick Environmental Laboratory conduct extensive quality assurance and quality control programs. The 2004 results of these programs are summarized in Appendices E and F. These results indicate that the analyses and measurements performed during 2004 exhibited acceptable precision and accuracy.

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2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2004.

Data for each environmental medium are included in a separate section. A table that summarizes the year's data for each type of medium follows a discussion of the sampling program and results. The unit of measurement for each medium is listed at the top of each table. The left hand column contains the radionuclides being reported, total number of analyses of that radionuclide, and the number of measurements that exceed ten times the yearly average for the control station(s). The latter are classified as "non-routinem measurements. The next column lists the Lower Limit of Detection (LLD) for those radionuclides that have detection capability requirements specified in the PNPS ODCM.

Those sampling stations within the range of influence of Pilgrim Station and which could conceivably be affected by its operation are called "indicator' stations. Distant stations, which are beyond plant influence, are called "control' stations. Ambient radiation monitoring stations are broken down into four separate zones to aid in data analysis.

For each sampling medium, each radionuclide is presented with a set of statistical parameters. This set of statistical parameters includes separate analyses for (1) the indicator stations, (2) the station having the highest annual mean concentration, and (3) the control stations. For each of these three groups of data, the following values are calculated:

• The mean value of detectable concentrations, including only those values above LLD;

• The standard deviation of the detectable measurements;

• The lowest and highest concentrations; and,

• The number of positive measurements (activity which is three times greater than the standard deviation), out of the total number of measurements.

Each single radioactivity measurement datum is based on a single measurement and is reported as a concentration plus or minus one standard deviation. The quoted uncertainty represents only the random uncertainty associated with the measurement of the radioactive decay process (counting statistics), and not the propagation of all possible uncertainties in the sampling and analysis process. A sample or measurement is considered to contain detectable radioactivity if the measured value (e.g., concentration) exceeds three times its associated standard deviation. For example, a milk sample with a strontium-90 concentration of 3.5 +/- 0.8 pCiliter would be considered Npositive' (detectable Sr-90), whereas another sample with a concentration of 2.1 +/- 0.9 pCi/liter would be considered "negative', indicating no detectable strontium-90. The latter sample may actually contain strontium-90, but the levels counted during its analysis were not significantly different than background levels.

As an example of how to interpret data presented in the results tables, refer to the first entry on the table for air particulate filters (page 37). Gross beta (GR-B) analyses were performed on 571 routine samples.

None of the samples exceeded ten times the average concentration at the control location. The lower limit of detection (LLD) required by the ODCM is 0.01 pCiM3.

For samples collected from the ten indicator stations, 519 out of 519 samples indicated detectable activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 519 indicator station samples was 0.013 +/- 0.005 (1.3E-2 +/- 4.9 E-3) pCiM3. Individual values ranged from 0.0014 to 0.034 (1.4E 3.4E-2) pCvm3.

The monitoring station which yielded the highest mean concentration was station EW (East Weymouth),

which yielded a mean concentration of 0.015 +/- 0.005 pCiM 3 , based on 52 observations. Individual values ranged from 0.0043 to 0.024 pCi/M 3. Fifty-two of the fifty-two samples showed detectable activity at the three-sigma level.

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At the control location, 52 out of 52 samples yielded detectable gross beta activity, for an average concentration of 0.015 +/- 0.005 pCi/m 3. Individual samples at the control location ranged from 0.0043 to 0.024 pCi/mr3.

Referring to the last entry in the table, analyses for cesium-137 (Cs-137) were performed 44 times (quarterly composites for 11 stations

• 4 quarters). No samples exceeded ten times the mean control station concentration. The required LLD value Cs-137 in the PNPS ODCM is 0.06 pCi/m 3.

At the indicator stations, all 40 of the Cs-137 measurements were below the detection level. The same was true for the four measurements made on samples collected from the control location.

2.4 Ambient Radiation Measurements The primary technique for measuring ambient radiation exposure in the vicinity of Pilgrim Station involves posting environmental thermoluminescent dosimeters (TLDs) at given monitoring locations and retrieving the TLDs after a specified time period. The TLDs are then taken to a laboratory and processed to determine the total amount of radiation exposure received over the period. Although TLDs can be used to monitor radiation exposure for short time periods, environmental TLDs are typically posted for periods of one to three months. Such TLD monitoring yields average exposure rate measurements over a relatively long time period. The PNPS environmental TLD monitoring program is based on a quarterly (three month) posting period, and a total of 110 locations are monitored using this technique. In addition, 27 of the 110 TLDs are located onsite, within the PNPS protected/restricted area, where the general public does not have access.

Out of the 440 TLDs (110 locations

• 4 quarters) posted during 2004, 429 were retrieved and processed.

Those TLDs missing from their monitoring locations were lost to storm damage, vandalism, and/or replacement of the utility poles to which they were attached, and their absence is discussed in Appendix D.

The results for environmental TLDs located offsite, beyond the PNPS protected/restricted area fence, are presented in Table 2.4-1. Results from onsite TLDs posted within the restricted area are presented in Table 2.4-2. In addition to TLD results for individual locations, results from offsite TLDs were grouped according to geographic zone to determine average exposure rates as a function of distance. These results are summarized in Table 2.4-3. All of the listed exposure values represent continuous occupancy (2190 hr/qtr or 8760 hr/yr).

Annual exposure rates measured at offsite locations ranged from 60 to 568 mR/yr. The average exposure rate at control locations greater than 15 km from Pilgrim Station (i.e., Zone 4) was 73.1 +/- 13.7 mR/yr.

When the 3-sigma confidence interval is calculated based on these control measurements, 99% of all measurements of background ambient exposure would be expected to be between 32 and 114 mR/yr.

The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 61 to 93 mR/yr, which compares favorably with the preoperational results of 37 - 190 mR/yr.

Inspection of onsite TLD results listed in Table 2.4-2 indicates that all of those TLDs located within the PNPS protected/restricted area yield exposure measurements higher than the expected background.

Such results are expected due to the close proximity of these locations to radiation sources onsite. The radionuclide nitrogen-16 (N-16) contained in steam flowing through the turbine accounts for most of the exposure onsite. Although this radioactivity is contained within the turbine and is not released to the atmosphere, the "sky shine" which occurs from the turbine increases the ambient radiation levels in areas near the turbine building.

A small number of offsite TLD locations in close proximity to the protected/restricted area indicated ambient radiation exposure above expected background levels. All of these locations are on Pilgrim Station controlled property, and experience exposure increases due to turbine sky shine (e.g., locations OA, TC, P01, and WS) and/or transit and storage of radwaste onsite (e.g., location BLW). A hypothetical maximum exposed member of the public accessing these near-site areas on Pilgrim Station controlled property for limited periods of time would receive a maximum dose of about 2.3 mrem/yr above their average ambient background dose of 73 mrem/yr.

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One TLD, located in the basement of the Plymouth Memorial Hall, indicated an annual exposure of 92 mR in 2004. The higher exposure within the building at this location is due to the close proximity of stone building material, which contains higher levels of naturally-occurring radioactivity, as well as from the buildup of radon in this area of the building.

It should be noted that several of the TLDs used to calculate the Zone 1 averages presented in Table 2.4-3 are located on Pilgrim Station property. If the Zone 1 value is corrected for the near-site TLDs (those less than 0.6 km from the Reactor Building), the Zone 1 mean falls from a value of 110.5 t 89.2 mR/yr to 76.1 +/- 12.8 mR/yr. Additionally, exposure rates measured at areas beyond Entergy's control did not indicate any increase in ambient exposure from Pilgrim Station operation. For example, the annual exposure rate calculated from the two TLDs nearest the nearest offsite residence 0.80 kilometers (0.5 miles) southeast of the PNPS Reactor Building was 77.4 +/- 15.5 mRlyr, which compares quite well with the average control location exposure of 73.1 +/- 13.7 mR/yr.

In conclusion, measurements of ambient radiation exposure around Pilgrim Station do not indicate any significant increase in exposure levels. Although some increases in ambient radiation exposure level were apparent on Entergy property very close to Pilgrim Station, there were no measurable increases at areas beyond Entergy's control.

2.5 Air Particulate Filter Radioactivity Analyses Airborne particulate radioactivity is sampled by drawing a stream of air through a glass fiber filter that has a very high efficiency for collecting airborne particulates. These samplers are operated continuously, and the resulting filters are collected weekly for analysis. Weekly filter samples are analyzed for gross beta radioactivity, and the filters are then composited on a quarterly basis for each location for gamma spectroscopy analysis. PNPS uses this technique to monitor 10 locations in the Plymouth area, along with the control location in East Weymouth.

Out of 572 filters (11 locations

• 52 weeks), 571 samples were collected and analyzed during 2004. There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes. In one of the cases, sampling locations were inaccessible due to snow, and the filters were left on until the collection during the following week. Thus, sampling capability continued, but only one filter was recovered for a two-week period in this case. All of these discrepancies are noted in Appendix D. These occurrences did not adversely affect the monitoring results.

The results of the analyses performed on these 571 filter samples are summarized in Table 2.5-1. Trend plots for the gross beta radioactivity levels at the near station, property line, and offsite airborne monitoring locations are shown in Figures 2.5-1, 2.5-2 and 2.5-3, respectively. Gross beta radioactivity was detected in 571 of the filter samples collected, including 52 of the 52 control location samples. This gross beta activity arises from naturally-occurring radionuclides such as radon decay daughter products. Naturally-occurring beryllium-7 was detected in 44 out of 44 of the quarterly composites analyzed with gamma spectroscopy. Naturally-occurring potassium-40 (K-40) was detected in 16 of 40 indicator samples, and in one of four control samples. No airborne radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.6 Charcoal Cartridge Radioactivity Analyses Airborne radioactive iodine is sampled by drawing a stream of air through a charcoal cartridge after it has passed through the high efficiency glass fiber filter. As is the case with the air particulate filters, these samplers are operated continuously, and the resulting cartridges are collected weekly for analysis. Weekly cartridge samples are analyzed for radioactive iodine. The same eleven locations monitored for airborne particulate radioactivity are also sampled for airborne radioiodine.

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Out of 572 cartridges (11 locations

• 52 weeks), 571 samples were collected and analyzed during 2004.

There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes. In one of the cases, sampling locations were inaccessible due to snow, and the filters were left on until the collection during the following week. Thus, sampling capability continued, but only one filter was recovered for a two-week period in this case. All of these discrepancies are noted in Appendix D. Despite such events during 2004, required LLDs were met on 570 of the 571 filters collected during 2004.

The results of the analyses performed on these 571 charcoal cartridges are summarized in Table 2.6-1.

No airborne radioactive iodine was detected in any of the charcoal cartridges collected.

2.7 Milk Radioactivity Analyses In July 2002, the Plymouth County Farm ceased operation of its dairy facility. This was historically the only dairy facility near Pilgrim Station, and had been sampled continuously since Pilgrim Station began operation in 1972. Although attempts were made to obtain samples from an alternate indicator location, a suitable substitute could not be found. Thus, milk collection at an indicator location was discontinued in July 2002, but control samples of milk continued to be collected and analyzed in the event an indicator location could be secured. In conjunction with the standardization of the ODCM during 2003, the decision was made to remove milk sampling from the PNPS Radiological Environmental Monitoring Program since no milk ingestion pathway existed in the vicinity of Pilgrim Station.

2.8 Forage Radioactivity Analyses Samples of animal forage (hay) are collected from the Plymouth County Farm and from the control location in Whitman. Samples are collected annually and analyzed by gamma spectroscopy.

All samples of forage were collected and analyzed as required during 2004. Results of the gamma analyses of forage samples are summarized in Table 2.8-1. Naturally-occurring beryllium-7, potassium-40, and actinium/thorium-228 were detected in forage samples collected during 2004. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.9 VecetableNegetation Radioactivity Analyses Samples of vegetables had historically been collected from the Plymouth County Farm and from the control location in Bridgewater. However, some problems were encountered in collection of crop samples during 2004. Crops were not grown at the Plymouth County Farm (CF) during 2004. Due to a loss of state funding at the Bridgewater Correctional Facility, garden samples were not available from this source.

An alternate sampling location (Hanson Farm) was identified in the general vicinity in Bridgewater, and was used as a source of control vegetable samples. In addition, samples of vegetables or leafy vegetation were collected at or near a number of gardens identified during the Annual Land Use Census. Results of this census are discussed in Appendix C. Samples of vegetables are collected annually and analyzed by gamma spectroscopy.

Thirteen samples of vegetables/vegetation were collected and analyzed as required during 2004. Results of the gamma analyses of these samples are summarized in Table 2.9-1. Naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228 were identified in most of the samples collected.

Cesium-137 was also detected in four out of 11 samples of naturally-growing vegetation collected, with concentrations ranging from 37 to 105 pCVkg. These Cs-137 results are in the range expected for weapons-testing fallout (75 to 145 pCVkg), and are not indicative of any releases associated with Pilgrim Station. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during Page 27

2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.10 Cranberry Radioactivity Analyses Samples of cranberries are routinely collected from two bogs in the Plymouth area and from the control location in Kingston. Samples of cranberries are collected annually and analyzed by gamma spectroscopy. In 2002, the bog at Manomet Point ceased harvesting operations, and a sample was collected from an alternate location along Beaver Dam Road. This discrepancy is noted in Appendix D.

Three samples of cranberries were collected and analyzed during 2004. Results of the gamma analyses of cranberry samples are summarized in Table 2.10-1. Cranberry samples collected during 2004 yielded detectable levels of naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228.

No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.11 Soil Radioactivity Analvses In the past, a survey of radioactivity in soil had been conducted once every three years at the 10 air sampling stations in the Plymouth area and the control location in East Weymouth. However, in conjunction with standardization of the ODCM during 2004, the soil survey effort was abandoned in favor of the extensive TLD monitoring effort at Pilgrim Station. Prior to ending the soil survey effort, there had been no apparent trends in radioactivity measurements at these locations.

2.12 Surface Water Radioactivity Analyses Samples of surface water are routinely collected from the discharge canal, Bartlett Pond in Manomet and from the control location at Powder Point Bridge in Duxbury. Grab samples are collected weekly from the Bartlett Pond and Powder Point Bridge locations. Samples of surface water are composited every four weeks and analyzed by gamma spectroscopy and low-level iodine analysis. These monthly composites are further composited on a quarterly basis and tritium analysis is performed on this quarterly sample.

A total of 36 samples (3 locations

• 12 sampling periods) of surface water were collected and analyzed as required during 2004. Results of the analyses of water samples are summarized in Table 2.12-1.

Naturally-occurring potassium-40, radium-226, and actinium/thorium-228 were detected in several of the samples, especially those composed primarily of seawater. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.13 Sediment Radioactivity Analyses Samples of sediment are routinely collected from the outfall area of the discharge canal and from three other locations in the Plymouth area (Manomet Point, Plymouth Harbor and Plymouth Beach), and from control locations in Duxbury and Marshfield. Samples are collected twice per year and are analyzed by gamma spectroscopy. Sediment cores are subdivided into depth increments for analysis of radionuclide distribution by depth. During the first half of the year, samples were divided into 2 cm increments, whereas samples for the second half of the year are divided into 5 cm increments. In addition to the gamma analyses, plutonium analyses are performed on the surface layer samples collected during the first half of the year from the discharge canal outfall, Plymouth Harbor, Manomet Point and Duxbury. Plutonium analyses are also performed on a mid-depth section from the discharge canal sample and Duxbury sample.

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Seventy-two samples of sediment were collected during 2004. Gamma analyses were performed on these samples. Results of the gamma analyses of sediment samples are summarized in Table 2.13-1. Results of the plutonium analyses are presented in Table 2.13-2. Naturally-occurring potassium-40 and actiniumlthorium-228 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.14 Irish Moss Radioactivity Analyses Samples of Irish moss are collected from the discharge canal outfall and two other locations in the Plymouth area (Manomet Point, Ellisville), and from a control location in Marshfield (Green Harbor). All samples are collected on a semiannual basis, and processed in the laboratory for gamma spectroscopy analysis.

Nine samples of Irish moss scheduled for collection during 2004 were obtained and analyzed. Results of the gamma analyses of these samples are summarized in Table 2.14-1. Naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

A sample of Irish moss collected from the control station at Brant Rock on 07-Apr-2004 indicated a very low level of iodine-131 at a concentration of about 28 pCi/kg. This control location is located 18 km (11 mi) distant, beyond the influence of Pilgrim Station. None of the indicator locations sampled during the same period indicated any detectable iodine-131. No discharges of liquid wastes containing radioactivity occurred from Pilgrim Station during 2004. Since this sample is split with the Massachusetts Department of Public Health Radiation Control Program, their office was contacted. Their analyses did not detect any iodine-131 in the split sample. A backup sample collected on 10-May failed to indicate any iodine. Iodine-131 is a radionuclide commonly used in medical diagnostics and treatment, and often appears in municipal sewage discharges. It has an 8-day half life, and decays relatively quickly. It is surmised that iodine-131 was released in municipal sewage in the vicinity of Brant Rock and was responsible for the low level detected in the 07-Apr sample. By the time the backup sample was collected a month later, the levels had decayed below detection levels.

2.15 Shellfish Radioactivity Analyses Samples of blue mussels, soft-shell clams and quahogs are collected from the discharge canal outfall and two other locations in the Plymouth area (Manomet Point, Plymouth Harbor), and from control locations in Duxbury and Marshfield. All samples are collected on a semiannual basis, and edible portions processed in the laboratory for gamma spectroscopy analysis.

All 12 samples of shellfish meat scheduled for collection during 2004 were obtained and analyzed. Results of the gamma analyses of these samples are summarized in Table 2.15-1. Naturally-occurring potassium-40, radium-226, and actinium/thorium-228 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.16 Lobster Radioactivity Analyses Samples of lobsters are routinely collected from the outfall area of the discharge canal and from the control location in Duxbury. Samples are collected monthly from the discharge canal outfall from June through September and annually from the control location. Due to inclement weather in July, the collection of the July lobster sample was delayed into the latter part of August, and the remainder of the year's Page 29

lobster collection efforts was shifted by one month. This discrepancy is noted in Appendix D. All lobster samples are analyzed by gamma spectroscopy.

All five samples of lobsters were collected and analyzed as required during 2004. Results of the gamma analyses of lobster samples are summarized in Table 2.16-1. The only radionuclides detected in any of the samples were naturally-occurring potassium-40, radium-226, and actinium/thorium-228. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.17 Fish Radioactivity Analyses Samples of fish are routinely collected from the area at the outfall of the discharge canal and from the control locations in Cape Cod Bay and Buzzard's Bay. Fish species are grouped into four major categories according to their biological requirements and mode of life. These major categories and the representative species are as follows:

• Group I - Bottom Oriented: Winter Flounder, Yellowtail Flounder

• Group II - Near-Bottom Distribution: Tautog, Cunner, Pollock, Atlantic Cod, Hake

• Group Ill - Anadromous: Alewife, Smelt, Striped Bass

• Group IV - Coastal Migratory: Bluefish, Herring, Menhaden, Mackerel Group I and 11fishes are sampled on a semiannual basis from the outfall area of the discharge canal, and on an annual basis from a control location. Group IlIl and IV fishes are sampled annually from the discharge canal outfall and control location. All samples of fish are analyzed by gamma spectroscopy.

Due to declining fish stock and the migration of fish to deeper water during colder seasons, samples of Groups I and 11fishes could not be collected during the latter half of the year. Although repeated and concerted efforts were made to collect the fish in the vicinity of the Discharge Canal Outfall, no samples could be obtained. Additional details regarding these discrepancies can be found in Appendix D.

Eight samples of fish were collected during 2004. Results of the gamma analyses of fish samples collected are summarized in Table 2.17-1. The only radionuclides detected in any of the samples were naturally-occurring potassium-40, radium-226, and actinium/thorium-228. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2004, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

Page 30

Table 2.2-1 Routine Radiological Environmental SamDling Locations Pilgrim Nuclear Power Station. Plymouth. MA Description No Code Distance Direction Air Particulate Filters. Charcoal Cartridges Medical Building 00 WS 0.2 km SSE East Rocky Hill Road 01 ER 0.9 km SE West Rocky Hill Road 03 WR 0.8 km WNW Property Line 06 PL 0.5 km NNW Pedestrian Bridge 07 PB 0.2 km N Overlook Area 08 OA 0.1 km W East Breakwater 09 EB 0.5 km ESE Cleft Rock 10 CR 1.3 km SSW Plymouth Center 15 PC 6.7 km W Manomet Substation 17 MS 3.6 km SSE East Weymouth Control 21 EW 40 km NW Milk Plymouth County Farm 11 CF 5.6 km W Whitman Farm Control 21 WF 34 km WNW Forage Plymouth County Farm 11 CF 5.6 km W Whitman Farm Control 12 WF 34 km WNW Whipple Farm 43 WH 2.9 km SW Vegetation Plymouth County Farm 11 CF 5.6 km W Bridgewater Farm Control 27 BF 31 km W Cranberries Manomet Point Bog 13 MR 3.9 km SE Bartlett Road Bog 14 BR 4.3 km SSE Pine Street Bog Control 23 PS 26 km WNW Page 31

Table 2.2-1 (continued)

Routine Radiological Environmental Sampling Locations Pilgrim Nuclear Power Station. Plymouth. MA Description No Code Distance Direction Surface Water Discharge Canal 11 DIS 0.2 km N Bartlett Pond 17 BP 2.7 km SE Powder Point Control 23 PP 13 km NNW Sediment Discharge Canal Outfall 11 DIS 0.8 km NE Plymouth Harbor 12 Ply-H 4.1 km W Duxbury Bay Control 13 Dux-Bay 14 km NNW Plymouth Beach 14 PLB 4.0 km WNW Manomet Point 15 MP 3.3 km ESE Green Harbor Control 24 GH 16 km NNW Irish Moss Discharge Canal Outfall 11 DIS 0.7 km NNE Manomet Point 15 MP 4.0 km ESE Ellisville 22 EL 12 km SSE Brant Rock Control 34 BR 18 km NNW Shellfish Discharge Canal Outfall 11 DIS 0.7 km NNE Plymouth Harbor 12 Ply-H 4.1 km W Duxbury Bay Control 13 Dux-Bay 13 km NNW Manomet Point 15 MP 4.0 km ESE Green Harbor Control 24 GH 16 km NNW Lobster Discharge Canal Outfall 11 DIS 0.5 km N Plymouth Harbor 15 Ply-H 6.4 km WNW Duxbury Bay Control 13 Dux-Bay 11 km NNW Fishes Discharge Canal Outfall 11 DIS 0.5 km N Priest Cove Control 29 PC 48 km SW Jones River Control 30 JR 13 km WNW Vineyard Sound Control 92 MV 64 km SSW Buzzard's Bay Control 90 BB 40 km SSW Cape Cod Bay Control 98 CC-Bay 24 km ESE Page 32

Table 2.4-1 Offsite Environmental TLD Results TLD Station TLD Location ' Quarterly Exposure - mR/quarter (Value +/- Std.Dev.)

TT 2004 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure Zone 1 TLDs: 0-3 km 0-3 km 26.3 +/- 22.7 23.0 +/- 21.0 31.2*21.9 29.9+/- 23.3 110.5 t 89.2 BLW BOAT LAUNCH WEST 0.11 km E 65.4

• 4.6 59.0 +/- 4.3 74.8 +/- 5.8 70.0 +/- 4.3 269.2

• 28.6 OA OVERLOOK AREA 0.15 km W 157.9 +/-4.6 140.8 +/- 9.7 119.5 +/-5.2 150.0 +/- 4.6 568.2 + 67.4 TC HEALTH CLUB 0.15 km WSW 48.7 +/- 1.5 55.4 : 1.5 58.4 +/-4.6 45.9 t 1.8 208.4 +/- 23.7 BLE BOAT LAUNCH EAST 0.16 km ESE 46.2 +/- 4.6 39.2

• 2.4 112.5 +/- 0.9 96.7

• 8.2 294.7

• 146.0 PB PEDESTRIAN BRIDGE 0.21 km N 38.0 +/- 3.0 31.6+/- 2.1 49.6* 1.5 40.5 +/-1.2 159.7 +/- 30.0 P01 SHOREFRONT SECURITY 0.22 km NNW 36.8 +/- 2.7 31.3 +/- 0.3 45.0

• 0.9 38.9

• 0.9 152.1

• 22.8 WS MEDICAL BUILDING 0.23 km SSE 41.7 +/- 3.3 32.5

• 1.2 42.0

• 1.2 42.0 t 2.4 158.2+/- 19.2 CT PARKING LOT 0.31 km SE 29.2* 1.2 22.5+/- 0.9 31.3* 1.5 29.8* 3.0 112.8+/- 16.1 PA SHOREFRONT PARKING 0.35 km NNW 22.5 +/-1.5 20.7+/- 1.2 26.5 +/- 2.1 24.3 +/- 1.2 94.0+/- 10.4 A STATION A 0.37 km WSW 25.2* 1.2 18.6 +/- 0.9 29.8 +/- 0.3 Missing 98.1 +/- 22.7 F STATION F 0.43 km NW 19.8 +/-1.5 19.5 +/-0.9 30.4+/- 1.2 24.9 +/-0.9 94.6 +/-20.8 EB EAST BREAKWATER 0.44 km ESE 21.6+/- 2.1 16.1 +/- 0.9 23.7 +/-1.5 24.0 +/- 0.6 85.5

• 14.9 B STATION B 0.44 km S 24.6 +/-1.8 21.6 +/-0.3 32.9 +/-0.6 27.4 +/-0.3 106.5+/- 19.2 PMT PNPS MET TOWER 0.44 km WNW 18.9 +/-0.6 18.9 +/-0.3 27.4 +/- 0.9 25.9 +/- 2.7 90.9 +/-18.3 H STATION H 0.47 km SW Missing 23.4* 1.2 33.2+/- 0.6 27.1 +/-1.5 111.5 +/-19.9 I STATION I 0.48 km WNW 21.0+/- 0.6 16.7 +/-0.6 21.6 +/-0.9 24.3+/- 1.5 83.6 +/-12.7 L STATION L 0.50 km ESE 24.6 +/- 2.1 19.2 +/- 0.9 31.9 f 4.0 27.7 +/- 0.6 103.4 +/- 22.0 G STATION G 0.53 km W 16.7 +/-1.2 15.8 +/-0.9 20.7 +/- 0.3 18.6 +/-1.2 71.8 +/-8.8 D STATION D 0.54 km NNW 21.3 +/- 1.5 18.6 +/-0.6 27.7 +/- 0.9 22.8 +/- 1.5 90.3 +/- 15.5 PL PROPERTY LINE 0.54 km NW 21.6 +/-0.0 17.9+/- 1.2 25.2 +/- 2.4 26.2 +/-1.5 90.9 +/-15.3 C STATION C 0.57 km ESE 16.7+/- 0.9 15.2 +/-0.6 21.9 +/-0.6 21.0 +/-1.2 74.8 +/-13.1 HB HALLS BOG 0.63 km SE 19.8+/- 0.6 19.5 +/-1.2 24.3 +/-1.8 21.9 +/-0.3 85.5 +/-9.3 GH GREENWOOD HOUSE 0.65 km ESE 20.7 +/- 0.6 19.2 +/-0.6 21.9 +/-1.2 26.8 +/- 1.5 88.5* 13.3 WR W ROCKY HILL ROAD 0.83 km WNW 22.8 +/- 2.1 19.8 +/- 1.2 25.9 +/- 0.9 24.0 +/- 0.3 92.5 +/- 10.6 ER E ROCKY HILL ROAD 0.89 km SE 18.3+/-11.2 11.0* 1.2 20.4 +/- 0.3 19.8 +/- 1.2 69.4 +/- 17.5 MT MICROWAVE TOWER 1.03 km SSW 19.2+/- 0.9 15.2 +/-0.3 21.9+/- 2.1 22.8+/- 1.5 79.1 +/-13.9 CR CLEFT ROCK 1.27 km SSW 17.3 +/-0.9 14.6 +/-2.1 Missing 20.1 +/- 2.1 69.4 +/-11.7 BD BAYSHORE/GATE RD 1.34 km WNW 19.5 +/- 0.9 17.3 +/-0.3 22.8 +/-1.8 20.4 +/- 0.3 80.0 +/- 9.3 MR MANOMET ROAD 1.38 km S 18.3 +/-1.5 16.1

• 1.5 22.5+/- 1.8 20.1 +/-1.2 77.0+/- 11.3 DR DIRT ROAD 1.48 km SW 17.0 +/-0.9 14.9+/- 0.6 17.9 +/-1.2 17.9 +/-1.5 67.8+/- 6.2 EM EMERSON ROAD 1.53 km SSE 20.7 +/- 0.9 14.3 +/- 0.9 22.2 +/- 0.6 21.3 +/-0.3 78.5 +/- 14.5 EP EMERSON/PRISCILLA 1.55 km SE 18.6 +/- 0.3 Missing 21.3 +/-1.2 23.4 +/- 1.8 84.4

• 1.2 AR EDISON ACCESS ROAD 1.59 km SSE 16.7 +/- 0.9 14.3 +/- 0.9 18.3 +/- 0.9 20.1 +/- 0.6 69.4 +/- 9.9 BS BAYSHORE 1.76 km W 19.2+/- 0.3 15.5* 1.5 23.4+/- 1.8 22.5+/-1.5 80.6+/- 14.7 E STATION E 1.86 km S 18.6+/- 0.9 16.7+/- 0.6 21.9+/- 0.6 21.3+/-11.2 78.5+/-9.8 JG JOHN GAULEY 1.99 km W 19.2 +/- 0.3 16.7 +/-0.3 22.2

• 2.4 22.8 +/- 0.6 80.9 +/-11.6 J STATION J 2.04 km SSE 16.7 +/-0.6 14.0+/- 1.5 19.5+/- 1.2 23.1 +/-0.3 73.3+/- 15.7 WH WHITEHORSE ROAD 2.09 km SSE 18.6 +/-0.3 15.5 +/- 0.6 18.9 +/-0.6 19.8+/-11.2 72.7 +/- 7.5 RC PLYMOUTH YMCA 2.09 km WSW 16.7 +/-1.2 13.1 +/- 1.2 20.4 +/- 0.6 21.9 +/-1.5 72.1 +/-16.0 K STATION K 2.17 km S 17.3 +/-0.3 Missing 20.7 +/-2.4 21.3 +/-3.0 79.1 +/- 10.0 TT TAYLOR/THOMAS 2.26 km SE 18.9 +/- 0.9 15.5 +/- 0.9 20.1 +/-1.5 18.9 +/- 0.9 73.3 +/- 8.1 YV YANKEE VILLAGE 2.28 km WSW 17.0 +/- 0.3 15.8 +/- 0.3 22.5 +/-1.2 21.9 +/-0.3 77.3 +/- 13.6 GN GOODWIN PROPERTY 2.38 km SW 14.3

• 0.9 12.5 +/- 0.6 21.0 +/-2.4 17.6 +/- 0.6 65.4+/-15.3 RW RIGHT OF WAY 2.83 km S 15.2 +/- 0.9 10.3

• 0.3 16.4 +/- 1.8 20.7 +/- 2.4 62.7 +/- 17.3 TP TAYLOR/PEARL 2.98 km SE 18.3 +/- 0.6 14.3+/- 1.2 18.6 +/- 0.9 18.9 +/- 3.0 70.0 +/- 9.2

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value Is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 33

Table 2.4-1 (continued)

Offsite Environmental TLD Results TLD Station TLD Location* Quarteri Exposure - mRlquarter (Value i Std.Dev.)

2004 Annual-ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure Zone 2 TLDs: 3-8 km 3-8 km 17.0 +/-2.0 13.9 +/-2.4 18.8 +/-2.4 20.8 +/-2.3 70.8 +/-13.6 VR VALLEY ROAD 3.26 km SSW 16.1 +/-0.6 11.3 +/- 0.9 16.4 +/-1.5 18.6 +/-1.5 62.4 +/-12.6 ME MANOMET ELEM 3.29 km SE 19.2 +/- 0.6 15.2 t 1.2 21.9 +/- 0.9 20.4 +/- 1.2 76.7 +/- 11.6 WC WARREN/CLIFFORD 3.31 km W 16.7 +/- 0.6 13.1 +/-1.5 19.8 +/-1.2 20.1 +/- 0.3 69.7 +/-13.2 BB RT.3A/BARTLETT RD 3.33 km SSE 17.0+/- 0.9 14.6 +/- 0.3 17.6 +/-1.2 19.2 +/-1.5 68.4 +/-7.9 MP MANOMET POINT 3.57 km SE 18.3 +/- 0.3 13.7+/-t 0.9 16.4+/- 1.2 22.2 +/-1.5 70.6 +/-14.5 MS MANOMET SUBSTATION 3.60 km SSE 18.3 +/- 0.3 19.8 +/- 0.6 24.3 +/- 3.3 25.2

• 0.9 87.6 +/-14.1 BW BEACHWOOD ROAD 3.93 km SE 16.4 +/- 0.6 14.6 +/- 0.9 16.7 +/-2.4 22.2 +/-1.5 70.0+/- 13.5 PT PINES ESTATE 4.44 km SSW 14.3 +/-0.3 11.6 +/-0.9 17.3+/-t 0.6 20.1 +/-1.8 63.3 +/-14.9 EA EARL ROAD 4.60 km SSE 14.3 +/- 0.6 13.1 +/-0.9 19.8 +/-0.6 22.8 +/-0.3 70.0 18.4 SP S PLYMOUTH SUBST 4.62 km W 16.1 +/-0.3 14.3 +/-0.6 19.8 +/- 1.5 21.6 +/- 1.8 71.8*13.6 RP ROUTE 3 OVERPASS 4.81 km SW 16.1 +/-0.9 11.6 +/-0.6 21.0+/-2.1 20.4 +/-1.5 69.0 +/-17.7 RM RUSSELL MILLS RD 4.85 km WSW 16.4+/-1.2 11.6 +/- 0.6 Missing 19.8 +/-1.8 63.7 +/-16.8 HD HILLDALE ROAD 5.18 km W 16.7 +/- 0.3 Missing 19.2 +/- 0.6 22.5 +/- 1.2 77.9 +/- 11.8 MB MANOMET BEACH 5.43 km SSE 18.9 +/-0.9 14.0+/- 0.0 16.4+/- 0.3 21.6 +/-0.6 70.9 +/-13.1 BR BEAVER DAM ROAD 5.52 km S 16.7+/-0.9 13.4+/-1.5 17.9+/-0.3 20.1 +/- 0.9 68.1 +/- 11.4 PC PLYMOUTH CENTER 6.69 km W 14.3 +/- 0.6 Missing 15.5 +/-0.6 18.3 +/-0.9 64.1 +/-8.3 LD LONG POND/DREW RD 6.97 km WSW 17.3+/-1.2 14.3+/-0.3 19.2 +/- 1.8 18.6 +/- 1.2 69.4 +/-9.0 HR HYANNIS ROAD 7.33 km SSE 17.9 +/-0.6 12.5 +/-0.6 18.3 +/-2.1 21.6 +/-1.2 70.3 +/-15.3 SN SAQUISH NECK 7.58 km NNW 15.5 +/-0.9 11.0 +/-0.9 17.6 +/-0.6 16.4+/-0.6 60.5 +/-11.8 MH MEMORIAL HALL 7.58 km WNW 23.1 +/-0.9 19.5 +/-0.6 22.8 +/-0.6 26.2 +/-1.2 91.6+/- 11.1 CP COLLEGE POND 7.59 km SW 17.9+/-1.2 14.6 +/-0.9 Missing 19.2+/-1.5 68.9 +/-9.9 Zone 3 TLDs: 8-15 km 8-15 km 17.9 +/-1.8 13.3 +/-1.9 18.3 +/-2.0 20.3 +/-1.8 70.3 +/-12.4 DW DEEP WATER POND 8.59 km W 20.1 +/-0.3 15.8 +/-0.9 21.6 +/-0.6 21.3 +/-1.1 78.8 +/-10.8 LP LONG POND ROAD 8.88 km SSW 16.4 +/-0.9 12.5 +/-0.6 17.3 +/-1.5 20.1

• 0.6 66.3 +/-12.7 NP NORTH PLYMOUTH 9.38 km WNW 20.7 +/- 0.9 17.0 +/- 0.6 20.4 +/- 0.0 23.7 +/-1.2 81.8 +/-11.1 SS STANDISH SHORES 10.39 km NW 17.0 +/- 1.2 12.5 +/- 1.2 18.3 +/-0.9 18.3 +/-0.9 66.0 +/- 11.2 EL ELLISVILLE ROAD 11.52 km SSE 19.2 +/- 0.9 12.2 +/- 1.5 18.6 +/- 0.6 20.7 +/-0.0 70.6 +/- 15.1 UC UP COLLEGE POND RD 11.78 km SW 17.3 +/-0.3 11.6 +/-0.6 15.5 +/-1.5 21.6 +/-0.9 66.0 +/-16.8 SH SACRED HEART 12.92 km W 16.7 +/-0.3 13.4 +/-1.2 15.2 +/-1.2 18.9 +/-1.5 64.2 +/-9.6 KC KING CAESAR ROAD 13.11 km NNW 17.3 +/-0.0 12.5 +/-0.6 18.9 +/-1.2 19.8 +/-0.9 68.4+/-13.1 BE BOURNE ROAD 13.37 km S 15.2 +/- 0.9 Missing 17.6 +/- 0.0 17.9 +/- 0.6 67.7 +/- 6.2 SA SHERMAN AIRPORT 13.43 km WSW 19.5 +/- 0.9 12.5 +/- 0.3 19.5 +/- 0.9 21.0 +/- 0.3 72.4 +/- 15.3 Zone 4 TLDs: >15 km >15 km 17.7 +/-2.7 14.9+/-2.4 20.2 +/-3.1 20.6 +/-2.6 73.1 +/-13.7 CS CEDARVILLE SUBST 15.93 km S 20.4 +/- 0.6 16.1 +/- 0.3 Missing 20.1 +/-1.2 75.4 +/- 9.7 KS KINGSTON SUBST 16.15 km WNW 15.8 +/-0.3 13.1 +/-0.6 17.6 +/-0.6 20.7 +/-2.1 67.2 +/-13.0 LR LANDING ROAD 16.46 kmNNW 15.8 +/-1.2 16.4+/-0.6 18.9 +/-1.2 19.5+/-0.6 70.6 +/-7.4 CW CHURCHIWEST 16.56 km NW 14.6 +/-1.5 11.0 +/-0.9 16.7+/-0.6 17.3 +/-0.0 59.6 +/-11.7 MM MAINIMEADOW 17.02 km WSW 16.1 +/-0.3 14.0 +/-1.5 24.9+/-0.9 18.6+/- 0.3 73.6 +/-19.1 DMF DIV MARINE FISH 20.97 km SSE 21.3 +/-1.8 16.1 +/- 1.8 21.0 +/-1.8 23.1 +/-0.9 81.5 +/- 12.4 EW EWEYMOUTH SUBST 39.69 km NW 19.8*0.3 17.6+/-1.2 22.2 +/- 1.8 24.6 +/- 1.8 84.3 +/- 12.4

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 34

Table 2.4-2 Onsite Environmental TLD Results TLD Station TLD Location' Quarterly Exposure - mR/quarter (Value +/- Std.Dev.)

2004 Annual..

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure Onsite TLDs P21 O&M/RXB. BREEZEWAY 50 m SE 26.2 +/- 1.2 26.5 +/- 0.6 31.3 +/- 2.4 36.2 +/- 2.1 120.1 +/- 19.3 P24 EXEC.BUILDING 57 m W 80.0 +/- 5.5 92.2 +/- 6.4 86.7 +/-1.5 91.3 +/- 5.5 350.1 +/- 24.5 P04 FENCE-R SCREENHOUSE 66 m N 88.8 +/- 9.4 77.6 +/- 2.4 86.7 +/- 6.1 87.3 +/- 6.7 340.4 +/- 24.3 P20 O&M - 2ND W WALL 67 m SE 74.8 +/- 5.5 73.6 +/- 0.6 74.8 +/-1.2 85.2 +/- 3.7 308.4 +/- 22.6 P25 EXEC.BUILDING LAWN 76 m WNW 126.5 +/- 1.8 112.8 +/- 9.1 126.5 +/- 12.8 143.3 +/- 11.0 509.2 +/- 53.4 P05 FENCE-WATER TANK 81 m NNE 37.7 +/- 3.0 37.4 +/-1.5 36.5 +/-1.2 42.6

• 1.5 154.2 +/-11.6 P06 FENCE-OIL STORAGE 85 m NE 65.7 +/- 5.5 52.0 +/-1.8 61.4 +/-4.3 55.7

• 3.3 234.8 +/- 25.5 P19 O&M - 2ND SW CORNER 86 m S 97.3 +/- 6.4 108.3 +/-4.3 124.4 +/-9.1 39.5 +/- 1.5 369.6 +/- 148.3 P18 O&M - 1ST SW CORNER 90 m S 71.5 +/-11.6 70.0 +/-5.5 70.6 +/- 1.8 77.3 +/- 8.8 289.3 +/-20.6 P08 COMPRESSED GAS STOR 92 m E 62.4 +/- 4.3 62.4 +/- 5.5 60.2 +/- 3.3 77.3 +/- 6.7 262.2 +/- 33.1 P03 FENCE-L SCREENHOUSE 100 m NW 94.6 +/- 8.5 82.7 +/- 2.1 87.0 +/- 4.0 95.8 +/- 7.6 360.1 +/- 27.8 P17 FENCE-EXEC.BUILDING 107m W 175.5+/- 13.1 175.2 +/-7.0 186.8 +/-9.4 198.6 +/-8.5 736.1 +/-48.6 P07 FENCE-INTAKE BAY 121 m ENE 45.9+/-4.0 50.2 +/-5.2 46.5+/-4.6 50.2 +/-4.0 192.8 +/- 12.8 P230&M-2NDSWALL 121 mSSE 51.7+/-2.7 47.1 +/-3.0 56.9+/-3.0 58.1 +/-1.8 213.8+/-20.9 P26 FENCE-WAREHOUSE 134 m ESE 58.7 +/- 5.5 60.2 +/- 6.1 61.7 +/- 2.7 66.6 +/- 4.3 247.3 +/-16.7 P02 FENCE-SHOREFRONT 135 m NW 65.7 +/- 4.6 62.7 +/- 3.3 71.5 +/- 4.6 66.6 +/- 4.9 266.5 +/-17.0 P09 FENCE-W BOAT RAMP 136 m E 51.1 +/-2.7 45.0+/-4.0 47.1 +/-3.7 54.4+/-6.4 197.7 +/-18.9 P22 O&M - 2ND N WALL 137 m SE 44.1 +/- 6.1 38.9 +/- 1.8 Missing 104.3 +/- 9.4 249.8 +/- 146.2 P16 FENCE-W SWITCHYARD 172 m SW 143.3 6.7 139.9 +/-4.9 155.4 +/- 14.0 154.2 +/-8.8 592.8 +/-36.2 P11 FENCE-TCF GATE 183 m ESE 78.8 +/- 5.8 67.8 +/- 4.6 77.0+/- 5.8 66.9 +/- 4.6 290.5 +/- 26.6 P27 FENCE-TCF/BOAT RAMP 185 m ESE 83.0 +/-1.2 73.9 +/- 5.5 46.5 +/-1.8 51.7 +/-4.0 255.2 +/- 70.3 P12 FENCE-ACCESS GATE 202 m SE 43.5 +/-3.3 42.6 +/- 4.6 39.8 +/-1.8 45.0 +/-3.7 170.9 +/-11.1 P15 FENCE-E SWITCHYARD 220 m S 55.7 +/- 0.9 56.9 +/-4.9 64.8 +/-2.4 62.4

• 4.0 239.7 +/-18.7 P1O FENCE-TCF/INTAKE BAY 223 m E 49.3 +/- 2.4 39.2 +/-1.5 49.0 +/- 0.3 50.5+/- 1.8 188.0 +/-21.1 P13 FENCE-MEDICAL BLDG. 224 m SSE 41.1 +/-4.0 35.9 +/-0.9 43.5 +/-1.5 45.0 +/-0.6 165.5 +/- 16.6 P14 FENCE-BUTLER BLDG 228 m S 37.1 +/- 2.4 33.5 +/-2.1 42.9 +/- 2.4 47.8 +/- 4.0 161.2 +/-25.8 P28 FENCE-TCF/PRKNG LOT 259 m ESE 110.7 +/-13.4 91.6 +/- 7.0 Missing 46.5 +/- 2.1 331.7 +/-133.3

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 35

Table 2.4-3 Average TLD Exposures By Distance Zone During 2004 Average Exposure +/- Standard Deviation: m _Rperiod_l Exposure Zone 1* Zone 2 Zone 3 Zone 4 Period 0-3 km 1 3-8 km 8-15 km >15 km Jan-Mar 26.3 +/- 22.7 17.0 +/- 2.0 17.9 +/- 1.8 17.7 +/- 2.7 Apr-Jun 23.0 +/- 21.0 13.9 +/- 2.4 13.3 +/- 1.9 14.9 +/- 2.4 Jul-Sep 31.2 +/- 21.9 18.8 +/- 2.4 18.3 +/- 2.0 20.2 +/- 3.1 Oct-Dec 29.9 +/- 23.3 20.8 +/- 2.3 20.3 +/- 1.8 20.6 +/- 2.6 Jan-Dec f 110.5 +/- 89.2** 70.8 +/- 13.6 70.3 +/-12.4 73.1 +/- 13.7

• Zone 1 extends from the PNPS restricted/protected area boundary outward to 3 kilometers (2 miles),

and includes several TLDs located within the site boundary.

• • When corrected for TLDs located within the site boundary, the Zone 1 annual average is calculated to be 76.1 +/- 12.8 mR/yr.

Page 36

Table 2.5-1 Air Particulate Filter Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Air Particulates (AP) UNITS: oCl/cubic meter Indicator Stations Station with Highest Mean Control Stations Mean t Std.Dev. Station: Mean

• Std.Dev. Mean

• Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine' LLD Fraction>LLD Fraction>LLD Fraction>LLD Gross Beta 571 0.01 1.3E-2

• 4.9E-3 EW: 1.5E-2

• 4.7E-3 1.5E-2

• 4.7E-3 0 1.4E 3.4E-2 4.3E 2.4E-2 4.3E 2.4E-2 519/519 52/52 52/52 Be-7 44 6.6E-2

• 2.1 E-2 WR: 8.6E-2 +/- 9.6E-3 7.4E-2 +/- 8.9E-3 0 2.6E 1.1E-1 7.7E 9.5E-2 9.OE 8.4E-2 40/40 4/4 4/4 K-40 44 3.6E-2 +/-1 .3E-2 EB: 5.2E-2

• 8.OE-3 3.8E-2 t 6.OE-3 0 1.7E 5.9E-2 5.2E 5.2E-2 6.OE 3.8E-2 116/40 1/4 1/4 Cs-134 44 0.05 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/4 0/4 Cs-137 44 0.06 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/4 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 37

Table 2.6-1 Charcoal Cartridge Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Charcoal Cartridge (CFA UNITS: oCVcubic meter Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean

• Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine' LLD Fraction>LLD Fraction>LLD Fraction>LLD 1-131 571 0.07 <LLD <LLD <LLD 0 <LLD <LLD <LLD I I _ 0/519 0/52 0/52

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 38

Table 2.7-1 Milk Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

No milk sampling was performed during 2004, as no indicator locations were available for sampling within 5 miles of Pilgrim Station.

Page 39

Table 2.8-1 Forage Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Forace (TC) UNITS: oCLka wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean

• Std.Dev. Mean t Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine' LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 2 1.6E+3

• 1.1IE+2 WF: 6.8E+3+/- 4.2E+2 6.8E+3 +/-4.2E+2 0 1.6E+3 -1 .6E+3 6.8E+3 - 6.8E+3 6.8E+3 - 6.8E+3 I_1_/I 1 /I 1/1 K-40 2 6.2E+3 +/- 2.8E+2 WF: 1.3E+4 +/- 7.7E+2 1.3E+4 t 7.7E+2 0 6.2E+3 - 6.2E+3 1.3E+4- 1.3E+4 1.3E+4 -1.3E+4 1/1 1 /1 1/1 1-131 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD O_1 1 O /i1 O11 Cs-134 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 0/1 Cs-137 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD O_1 Oi11 0/1 Ra-226 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 O/1 AcTh-228 2 <LLD WF: 1.9E+2 +/-1.OE+2 1.9E+2 +/- 1.OE+2 0 <LLD 11.9E+2 - 1.9E+2 1.9E+2 - 1.9E+2 0/1 1/1 1/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 40

Table 2.9-1 VegetableNegetation Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

IlA=1Il IRiA.

IVIImIJIUPIVI. VOU"iLUI,

/1rMooio i I4 .U'.I~ -fi ~ l.

Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean

• Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine^ LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 13 2.OE+3 +/- 1.1E+3 MwvTwr: 3.7E+3 +/- 1.5E+2 1.5E+3

• 1.1E+2 0 <LLD - 3.7E+3 3.7E+3 - 3.7E+3 <LLD -1 .5E+3 9/11 1/1 1/2 K-40 13 5.7E+3 : 3.4E+3 CF: 9.3E+3t 7.4E+3 3.7E+3 +/-1 .9E1+3 0 1.6E+3 - 1.5E+4 4.OE+3 -1 .5E+4 2.4E+3 - 5.OE+3 11/11 2/2 2/2 1-131 13 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/11 0/2 0/2 Cs-134 13 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/11 0/2 0/2 Cs-137 13 80 6.7E+1

• 3.3E+1 MwvTwr: 1.1E.I+2* 1.2E+1 <LLD 0 <LLD - 1.1E+2 1.1E+2- 1.1E+2 <LLD 4/11 1/1 0/2 Ra-226 13 6.OE+2 +/- 4.2E+2 MwvTwr: 1.6E+3 +/- 2.8E+2 3.5E+2 +/-1 .4E+2 0 <LLD - 1.6E+3 1.6E+3 -1.6E+3 <LLD - 3.5E+2 9/11 1 /1 1/2 AcTh-228 13 1.3E-+2

• 8.2E+1 Gmwd: 2.9E+2 +/- 5.4E+1 <LLD 0 <LLD - 2.9E+2 2.9E+2 - 2.9E+2 <LLD 7/11 1/1 0/2

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels In ODCM Table 3.5-4.

Page 41

Table 2.10-1 Cranberry Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Cranberries (CB) UNITS: oCi/ko wet Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean

• Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 3 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/2 0/1 0/1 K-40 3 1.1 E+3* 1.1 E+2 BvR: 1.2E+3

• 1.OE+2 1.2E+3

• 1.OE+2 0 1.0E+3- 1.2E+3 1.2E+3 - 1.2E+3 1.2E+3 - 1.2E+3 2/2 1 /1 1 /1 1-131 3 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/2 0/1 0/1 Cs-134 3 60 <LLD <LLD <LD 0 <LLD <LD <LLD OI 2 0 /1 0/1 Cs-137 3 80 <LD <LLD <LLD 0 <LLD <LLD <LLD OI 2 0 /1 0/1 Ra-226 3 1.9E+2 +/- 8.7E+1 BvR: 3.9E+2 +/- 8.7E+1 3.9E+2 +/- 9.6E+1 0 <LLD - 1.9E+2 3.9E+2 - 3.9 E+2 3.9E+2 - 3.9 E+2 12 1/1 1 /1 AcTh-228 3 5.3E+1 +/-2.2E+1 BR: 5.3E+1 +/-2.2E+1 <LLD 0 <LD - 5.3E+1 5.3E+1 - 5.3E+1 <LLD 1 /2 I/1 0/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 42

Table 2.12-1 Surface Water Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Surface Water (WS) UNITS: OCi/ko Indicator Stations Station with Highest Mean Control Stations Mean t Std.Dev. Station: Mean t Std.Dev. Mean t Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine^ LLD Fraction>LLD Fraction>LLD Fraction>LLD H-3 12 3000 cLLD cLLD <LLD 0 cLLD <LLD <LLD 0/8 0/4 014 Be-7 36 <LLD <LLD <LLD 0 <LLD <LLD <LLD O t 24 0 /12 0 /12 K-40 36 3.5E+2 +/- 1.9E+2 DIS: 5.2E+2 t 7.8E+1 5.1 E+2 t 1.OE+2 0 8.5E+1 - 6.7E+2 4.4E+2 - 6.7E+2 3.5E+2 - 6.5E+2 24/24 12/12 12/12 Mn-54 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0 /24 0/12 0/12 Fe-59 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD O /24 0 /12 0 /12 Co-58 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD O/24 0 /12 0/12 Co-60 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD O /24 0 /12 0 /12 Zn-65 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/24 0/12 0/12 Zr-95 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Nb-95 36 15 <LLD <LLD <LLD O <LLD <LLD <LLD 0/24 0/12 0/12 1-131 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD O /24 0 /12 0/12 Cs-134 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Cs-137 36 18 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Ba-140 36 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/24 0/12 0/12 La-140 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD O /24 0 /12 0/12 Ra-226 36 9.1E+1 *3.1E+1 PP: 9.1E+1 *2.6E+1 9.IE+1 +/-2.6E+1 0 <LLD- 1.4E+2 <LLD- 1.2E+2 5.1E+1 - 1.2E+2 23/24 10/12 10/12 AcTh-228 36 1.OE+1 +/- 2.1 E+O PP: 1.2E+1 t 2.2E+0 1.2E+1 +/- 2.2E+O 0 <LLD - 1.3E+1 <LLD - 1.4E+1 1.OE+1 - 1.4E+1 12/24 6/12 3/12 Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 43

Table 2.13-1 Sediment Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDiiIUM- Sediment MM~

Ws---v-v-. vswlllullw v_.

UNITA-vlul *v.

nria uvvrvw n dri wtl Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean

• Std.Dev. Mean

• Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 12 7.3E+2

• 1.7E+2 PLY-H: 7.3E+2 t 1.7E+2 cLLD 0 <LLD - 7.3E+2 <LLD - 7.3E+2 <LLD 1/8 1/2 0/4 K-40 12 -

1.lE+4 3.3E+3 PLY-H: 11.4E+4 +/- 2.4E+3 1.1 E+4

• 1.5E+3 0 6.7E+3 - 1.6E+4 1.2E+4- 1.6E+4 8.8E+3 - 1.2E+4 8/8 2/2 4/4 Cs-134 12 50 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Cs-137 12 50 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Ra-226 12 9.3E+2

• 3.9E+2 PLY-H: 1.1 E+3 t 3.8E+2 9.5E+2 t 4.1 E+2 0 <LLD - 1.4E+3 <LLD -1.1E+3 6.1 E+2 -1.5E+3 5/8 1/2 4/4 AcTh-228 12 3.7E+2 +/- 2.OE+2 PLY-H: 6.3E+2

• 8.5E+1 4.9E+2 +/- 9.5E+1 0 1.OE+2 - 6.8E+2 5.9E+2 - 6.8E+2 3.9E+2 - 5.8E+2 8/8 2/2 4/4 I Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 44

Table 2.14-1 Irish Moss Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MFDIUM- Irish Mntq 1AL'I UNITS: 0,01Vkn wet Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean

• Std.Dev. Mean t Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine^ LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 9 1.6E+2 : 6.7E+1 DIS: 1.8E+2 +/- 1.OE+2 <LLD 0 8.OE+1 - 2.5E+2 1.1 E+2 - 2.5E+2 <LLD 6/6 2/2 0/3 K-40 9 6.9E+3

• 1.1E+3 BR: 9.5E+3 t 1.2E+3 9.5E+3

• 1.2E+3 0 5.7E+3 - 8.7E+3 8.6E+3 - 1.1 E+4 8.6E+3 - 1.1 E+4

_ 6/6 3/3 3/3 Mn-54 9 130 <LD <LLD cLLD 0 <LLD <LLD <LLD 0/6 0/4 0/3 Fe-59 9 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/6 0/4 0/3 Co-58 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/3 Co-60 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/6 0/4 0/3 Zn-65 9 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/3 1-131 9 <LLD BR: 2.8E+1 t 1.2E+1 2.8E+1 +/- 1.2E+1 0 <LLD <LLD - 2.8E+1 <LLD - 2.8E+1 0/6 1/3 1 /3 Cs-134 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/6 0/4 0/3 Cs-137 9 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/3 Ra-226 9 2.6E+2 1t.2E+2 MP: 3.3E+2 +/- 2.2E+2 1.9E+2 +/- 5.4E+1 0 1.5E+2 - 4.7E+2 1.BE+2 - 4.7E+2 1 .8E+2 - 2.3E+2 6/6 2/2 3/3 AcTh-228 9 5.2E+1 t 1.4E+1 EL: 6.3E+1 +/- 1.7E+1 3.5E+1 +/-1.4E+1 0 <LLD - 6.3E+1 <LLD - 6.3E+1 <LLD - 3.5E+1 3/6 1/2 1/2

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels In ODCM Table 3.5-4.

Page 45

Table 2.15-1 Shellfish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004) urAMM1111 IvMIIUIVI.

ek-AIMie one1VIII01I 10M

-OrF IUW111 I~le I -0. / -n uI.AIPU weL Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean t Std.Dev.

No. Analyses Required Range Range Range Radbonuclide Non-routine' LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 12 <LLD <LLD <LLD 0 <LLD <LLD <LD

_0/8 0/2 0/4 K-40 12 2.7E+3 +/- 5.4E+2 DUX: 3.OE+3 +/- 4.5E+2 2.8E+3 t 6.OE+2 0 2.2E+3 - 3.6E+3 2.7E+3 - 3.3E+3 2.OE+3 - 3.3E+3 8/8 2/2 4/4 Mn-54 12 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/8 0/2 0/4 Fe-59 12 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/8 0/2 0(4 Co-58 12 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 012 0/4 Co-60 12 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Zn-65 12 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Cs-134 12 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/2 0/4 Cs-137 12 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Ra-226 12 4.4E+2 +/- 1.4E+2 6.5E+2 +/- 1.2E+2 5.8E+2 +/- 1.8E+2 0 <LLD - 6.5E+2 <LLD - 6.5E+2 4.3E+2 - 7.6E+2 618 1/2 4/4 AcTh-228 12 <LLD GH: 8.5E+1 +/-4.8E+1 7.7E+1 +/-3.1E+1 0 <LLD <LLD - 8.5E+1 <LLD - 8.5E+1 0/8 1/2 2/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 46

Table 2.16-1 Lobster Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: American Lobster (HAI UNITS: oCVko wet Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 5 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/4 0/4 0/1 K-40 5 3.7E+3 +/- 8.5E+2 DIS: 3.7E+3 +/- 8.5E+2 3.3E1+3 +/- 3.1 E+2 0 3.OE+3 - 4.9E+3 3.OE+3 - 4.9E+3 3.3E+3 - 3.3E+3 4/4 4/4 1 /1 Mn-54 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Fe-59 5 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Co-58 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Co-60 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Zn-65 5 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Cs-134 5 130 <LLD <LLD <LLD 0 <LLW <LLD <LLD 0/4 0/4 0/1 Cs-137 5 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Ra-226 5 5.2E+2 t 2.3E+2 DIS: 5.2E+2

• 2.3E+2 9.6E+2 +/- 2.3E+2 0 <LLD - 7.5E+2 <LLD - 7.5E+2 9.6E+2 - 9.6E+2 3/4 3/4 1/1 cTh-228 5 6.2E+1

• 3.3E+1 DIS: 6.2E+1

• 3.3E+1 <LLD 0 <LLD - 6.2E+1 <LLD - 6.2E+1 <LLD 1/4 1/4 0/1

' Non-Routine refers to those radionuclides that exceeded the Reporting Levels In ODCM Table 3.5-4.

Page 47

Table 2.17-1 Fish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2004)

MEDIUM: Fish (FH) UNITS: oCil/ka wet Indicator Stations Station with Highest Mean Control Stations Mean

• Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 K-40 8 6.OE+3 +/- 9.4E+2 CC-Bay: 6.2E+3 +/- 7.7E+2 6.2E+3

• 7.7E+2 0 5.4E+3 - 7.3E+3 5.4E+3 - 6.9E+3 5.4E+3 - 6.9E+3 4/4 4/4 4/4 Mn-54 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD

_0/4 0/4 0/4 Fe-59 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Co-56 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Co-60 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Zn-65 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Cs-134 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Cs-137 8 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/4 Ra-226 8 3.2E+2

• 1.5E+2 CC-Bay 8.6E+2 +/-3.1 E+2 8.6E+2+/- 3.1 E+2 0 <LLD - 3.2E+2 6.OE+2 - 1.1 E+3 6.OE+2 - 1.1 E+3 1/3 3/4 3/4 AcTh-228 8 <LLD CC-Bay: 1.6E+2 +/- 4.6E+1 1.6E+2 +/- 4.6E+1 0 <LLD <LLD- 1.6E+2 <LLD- 1.6E+2 0/4 1/4 1/4

' Non-Routine refers to those radionuclides that exceeded the Reporting Levels In ODCM Table 3.5-4.

Page 48

Figure 2.2-1 Environmental TLD Locations Within the PNPS Protected Area TLD Station _ Location' Description Code lDistance/Direction TLDs Within Protected Area O&M/RXB. BREEZEWAY P21 50 m SE EXEC.BUILDING P24 57 m W FENCE-R SCREENHOUSE P04 66 m N O&M - 2ND W WALL P20 67 m SE EXEC.BUILDING LAWN P25 76 m WNW FENCE-WATER TANK P05 81 m NNE FENCE-OIL STORAGE P06 85 m NE O&M - 2ND SW CORNER P19 86 m S O&M - 1ST SW CORNER P18 90 m S COMPRESSED GAS STOR P08 92 m E FENCE-L SCREENHOUSE P03 100 m NW FENCE-EXEC.BUILDING P17 107 m W O&M - 2ND S WALL P23 121 m ENE FENCE-INTAKE BAY P07 121 m SSE FENCE-WAREHOUSE P26 134 m ESE FENCE-SHOREFRONT P02 135 m NW FENCE-W BOAT RAMP P09 136 m E O&M - 2ND N WALL P22 137 m SE FENCE-W SWITCHYARD P16 172 m SW FENCE-TCF GATE P11 183 m ESE FENCE-TCFtBOAT RAMP P27 185 m ESE FENCE-ACCESS GATE P12 202 m SE FENCE-E SWITCHYARD P15 220 m S FENCE-TCFAINTAKE BAY P10 223 m E FENCE-MEDICAL BLDG. P13 224 m SSE FENCE-BUTLER BLDG P14 228 m S FENCE-TCF/PRKNG LOT P28 259 m ESE

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 49

Figure 2.2-1 (continued)

Environmental TLD Locations Within the PNPS Protected Area Page 50

Figure 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer TLD Station Location* Air Sampling Station Location Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km BOAT LAUNCH WEST BLW 0.11 km E OVERLOOK AREA OA 0.15 km W OVERLOOK AREA OA 0.15 km W PEDESTRIAN BRIDGE PB 0.21 km N HEALTH CLUB TC 0.15 km WSW MEDICAL BUILDING WS 0.23 km SSE BOAT LAUNCH EAST BLE 0.16 km ESE EAST BREAKWATER EB 0.44 km ESE PEDESTRIAN BRIDGE PB 0.21 km N PROPERTY LINE PL 0.54 km NNW SHOREFRONT SECURITY P01 0.22 km NNW W ROCKY HILL ROAD WR 0.83 km WNW MEDICAL BUILDING WS 0.23 km SSE E ROCKY HILL ROAD ER 0.89 km SE PARKING LOT CT 0.31 km SE SHOREFRONT PARKING PA 0.35 km NNW STATION A A 0.37 km WSW STATION F F 0.43 km NW STATION B B 0.44 km S EAST BREAKWATER EB 0.44 km ESE PNPS MET TOWER PMT 0.44 km WNW STATION H H 0.47 km SW STATION I i 0.48 km WNW STATION L L 0.50 km ESE STATION G G 0.53 km W STATION D D 0.54 km NW PROPERTY LINE PL 0.54 km NNW STATION C C 0.57 km ESE HALL'S BOG HB 0.63 km SE GREENWOOD HOUSE GH 0.65 km ESE W ROCKY HILL ROAD WR 0.83 km WNW E ROCKY HILL ROAD ER 0.89 km SE Page 51

Figure 2.2-2 (continued)

TLD and Air Sampling Locations: Within 1 Kilometer

.,w .

I' 04k PNPS -'

QA +Ia Page 52

Figure 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers TLD Station Location* Air SamplingStation l Location' Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km MICROWAVE TOWER MT 1.03 km SSW CLEFT ROCK CR 1.27 km SSW CLEFT ROCK CR 1.27 km SSW MANOMET SUBSTATION MS 3.60 km SSE BAYSHOREJGATE RD BD 1.34 km WNW MANOMETROAD MR 1.38 km S DIRT ROAD DR 1.48 km SW EMERSON ROAD EM 1.53 km SSE EMERSON/PRISCILLA EP 1.55 km SE EDISON ACCESS ROAD AR 1.59 km SSE BAYSHORE BS 1.76 km W STATION E E 1.86 km S JOHN GAULEY JG 1.99 km W STATION J J 2.04 km SSE WHITEHORSE ROAD WH 2.09 km SSE PLYMOUTH YMCA RC 2.09 km WSW STATION K . K 2.17 km S TAYLOR/THOMAS TT 2.26 km SE YANKEE VILLAGE YV 2.28 km WSW GOODWIN PROPERTY GN 2.38 kmo SW RIGHT OF WAY RW 2.83 Ion S TAYLOR/PEARL TP 2.98 km SE Zone 2 TLDs: 3-8 km VALLEY ROAD VR 3.26 km SSW MANOMET ELEM ME 3.29 km SE WARREN/CLIFFORD WC 3.31 km W RT.3A/BARTLETT RD BB 3.33 km SSE MANOMET POINT MP 3.57 km SE MANOMET SUBSTATION MS 3.60 km SSE BEACHWOOD ROAD BW 3.93 km SE PINES ESTATE PT 4.44 km SSW EARL ROAD EA 4.60 km SSE S PLYMOUTH SUBST SP 4.62 km W ROUTE 3 OVERPASS RP 4.81 km SW RUSSELL MILLS RD RM 4.85 km WSW l

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 53

Figure 2.2-3 (continued)

TLD and Air Sampling Locations: 1 to 5 Kilometers Page 54

Figure 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers TLD Station Location Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 2 TLDs: 3-8 km HILLDALE ROAD HD 5.18 km W PLYMOUTH CENTER PC 6.69 km W MANOMET BEACH MB 5.43 km SSE BEAVER DAM ROAD BR 5.52 km S PLYMOUTH CENTER PC 6.69 km W LONG POND/DREW RD LD 6.97 km WSW HYANNIS ROAD HR 7.33 km SSE MEMORIAL HALL MH 7.58 km WNW SAQUISH NECK SN 7.58 km NNW COLLEGE POND CP 7.59 km SW Zone 3 TLDs: 8-15 km DEEP WATER POND DW 8.59 km W LONG POND ROAD LP 8.88 km SSW NORTH PLYMOUTH NP 9.38 km WNW STANDISH SHORES SS 10.39 km NW ELLISVILLE ROAD EL 11.52 km SSE UP COLLEGE POND RD UC 11.78 km SW SACRED HEART SH 12.92 km W KING CAESAR ROAD KC 13.11 km NNW BOURNE ROAD BE 13.37 km S SHERMAN AIRPORT SA 13.43 km WSW Zone4TLDs: >15 km CEDARVILLE SUBST CS 15.93 km S KINGSTON SUBST KS 16.15 km WNW LANDING ROAD LR 16.46 km NNW CHURCH/WEST CW 16.56 km NW MAIN/MEADOW MM 17.02 km WSW DIV MARINE FISH DMF 20.97 km SSE

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 55

Figure 2.2-4 (continued)

TLD and Air Sampling Locations: 5 to 25 Kilometers KI AR

.-' t .

> - - i, Page 56

Figure 2.2-5 Terrestrial and Aquatic Sampling Locations Description Code Distance/Direction* jDescription Code Distance/Direction SURFACE WATER Plymouth County Farm CF 5.6 km W Discharge Canal DIS 0.2 km N Whitman Farm Control WF 34 km WNW Bartlett Pond BP 2.7 km SE Powder Point Control PP 13 km NNW FORAGE Whipple Farm WH 2.9 km SW SEDIMENT Plymouth County Farm CF 5.6 km W Discharge Canal Outfall DIS 0.8 km NE Whitman Farm Control WF 34 km WNW Plymouth Beach PLB 4.0 km W Manomet Point MP 3.3 km ESE VEGETABLESNEGETATION Plymouth Harbor PLY-H 4.1 km W Site Boundary C BC 0.5 km SW Duxbury Bay Control DUX-BAY 14 km NNW Site Boundary B BB 0.5 km ESE Green Harbor Control GH 16 km NNW Rocky Hill Road RH 0.9 km SE Site Boundary D Bd 1.1 km SSW IRISH MOSS Site Boundary A BA 1.5 km SSW Discharge Canal Outfall DIS 0.7 km NNE Clay Hill Road CH 1.6 km W Manomet Point MP 4.0 km ESE Brook Road BK 2.9 km SSE Ellisville EL 12 km SSE Beaver Dam Road BD 3.4 km S Brant Rock Control BK 18 km NNW Plymouth County Farm CF 5.6 km W Div. Marine Fisheries DMF 21 km SSE SHELLFISH Bridgewater Control BF 31 km W Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor PLY-H 4.1 km W CRANBERRIES Manomet Point MP 4.0 km ESE Manomet Point Bog MR 3.9 km SE Duxbury Bay Control DUX-BAY 13 km NNW Bartlett Road Bog BT 4.3 km SSE Powder Point Control PP 13 km NNW Pine Street Bog Control PS 26 km WNW Green Harbor Control GH 16 km NNW LOBSTER Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km W Plymouth Harbor PLY-H 6.4 km WNW Duxbury Bay Control DUX-BAY 11 km NNW FISHES Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km W Jones River Control JR 13 km WNW Cape Cod Bay Control CC-BAY 24 km ESE N River-Hanover Control NR 24 km NNW Cataumet Control CA 32 km SSW Provincetown Control PT 32 km NE Buzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 57

Figure 2.2-5 (continued)

Terrestrik il and Aquatic Sampling Locations NORTH-NORTHWEST SYM\OL KEY v lMARSHEL-i In SHELLFISH (M BLUE MUSSEL)

(S SOFT-SHELL)

(H HARD-SHELL) o NI Q IRISH MOSS ci LOBSTER DUXBUR>>k < (DI FISHES Is NORTHWS

/ SURFACEWATER

/!^ > .0SEDIMENT 34KnM@bTERS PRWEST-NORTH WEST N, X CRANBERRY

-XJOI.lMTERS WIST-NORTHWEST

-E 0 2 31DOLOMFTERS WEST 31 lOMETERs NORTHEhST 30 KEDMETERS WEST 4 tM a Xrms ILLOMMErERS ooSOUTHWEST 64ILON5M ESUTH-EDUTHWEST SOUTH-SUTHWEST 22EII.OMEES SOTH-SDUTMWEST SOUTHSOUTHEAST p f t a KIOMETERS SOUTH-SOUTHZEAST Page 58

Figure 2.2-6 Environmental Sampling And Measurement Control Locations Description Code Distance/Direction* Description Code Distance/Direction^

IL SURFACE WATER Cedarville Substation CS 16 km S Powder Point Control PP 13 km NNW Kingston Substation KS 16 km WNW Landing Road LR 16 km NNW SEDIMENT Church & West Street CW 17 km NW Duxbury Bay Control DUX-BAY 14 km NNW Main & Meadow Street MM 17 km WSW Green Harbor Control GH 16 km NNW Div. Marine Fisheries DMF 21 km SSE East Weymouth EW 40 km NW IRISH MOSS Substation Brant Rock Control BK 18 km NNW AIR SAMPLER East Weymouth EW 40 km NW SHELLFISH Substation Duxbury Bay Control DUX-BAY 13 km NNW Mm Powder Point Control PP 13 km NNW Whitman Farm Control WF 34 km WNW Green Harbor Control GH 16 km NNW FORAGE LOBSTER Whitman Farm Control WF 34 km WNW Duxbury Bay Control DUX-BAY 11 km NNW VEGETABLESIVEGETATION FISHES Div. Marine Fish. Control DMF 21 km SSE Jones River Control JR 13 km WNW Bridgewater Farm Control BF 31 km W Cape Cod Bay Control CC-BAY 24 km ESE N River-Hanover Control NR 24 km NNW CRANBERRIES Cataumet Control CA 32 km SSW Pine Street Bog Control PS 26 km WNW Provincetown Control PT 32 km NE Buzzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 59

Figure 2.2-6 (continued)

Environmental Sampling And Measurement Control Locations SYMBOL KEY SEELLFISH (M BLUE MUSSEL)

(S SOFT-SHELL CLAM (H HARD-SHL CLAM 0 lRIsE}MOSS Z LOBSTER MASACHUSET BAY CZ( FISHE K7 SURFACE WATER

_ SEDR4ENT C3 CRANERRY V EGTATiONxORAGE O ThD C AR SAMPLE ER 0 MIIES 10 SCALE (9c CAPE OOD BAY BEAY Page 60

Airborne Gross-Beta Radioactivity Levels Near-Station Monitors 5.OE-02 4.OE-02 HE;3.OE-02 E

.2

.0 0

p9 2.OE-02 1.OE-02 O.OE+00 .

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2004

-_- AP-00 Warehouse -a- AP-07 Pedestrian Bridge

- - AP-08 Overlook Area )( AP-09 East Breakwater a AP-21 East Weymouth Control Figure 2.5-1 Airborne Gross-Beta Radioactivity Levels: Near Station Monitors Page 61

Airborne Gross-Beta Radioactivity Levels Property Line Monitors 5.OE-02 4.OE-02 S

% 3.OE-02 E

.2

.0 U

U? 2.OE-02 1.OE-02 O.OE+00 I I I I I a I Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Month - 2004 s AP-01 E. Rocky Hill Road I-a- AP-03 W. Rocky Hill Road

- - AP-06 Property Line it AP-21 East Weymouth Control Figure 2.5-2 Airborne Gross-Beta Radioactivity Levels: Property Line Monitors Page 62

Airborne Gross-Beta Radioactivity Levels Offsite Monitors 5.OE-02 4.OE-02 E 3.OE-02 E

.2

.0 0

p 2.OE-02 1.OE-02 O.OE+00 I I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2004

+ AP-10 Cleft Rock -u-AP-15 Plymouth Center

- - AP-1 7 Manomet Substation - AP-21 East Weymouth Control Figure 2.5-3 Airborne Gross-Beta Radioactivity Levels: Offsite Monitors Page 63

3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS The radiological impact to humans from the Pilgrim Station's radioactive liquid and gaseous releases has been estimated using two methods:

• calculations based on measurements of plant effluents; and

• calculations based on measurements of environmental samples.

The first method utilizes data from the radioactive effluents (measured at the point of release) together with conservative models that calculate the dispersion and transport of radioactivity through the environment to humans (Reference 7). The second method is based on actual measurements of radioactivity in the environmental samples and on dose conversion factors recommended by the Nuclear Regulatory Commission. The measured types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during 2004 were reported to the Nuclear Regulatory Commission, copies of which are provided in Appendix B. The measured levels of radioactivity in the environmental samples that required dose calculations are listed in Appendix A.

The maximum individual dose from liquid effluents was calculated using the following radiation exposure pathways:

• shoreline external radiation during fishing and recreation at the Pilgrim Station Shorefront;

• external radiation from the ocean during boating and swimming; and

• ingestion of fish and shellfish.

For gaseous effluents, the maximum individual dose was calculated using the following radiation exposure pathways:

• external radiation from cloud shine and submersion in gaseous effluents;

• inhalation of airborne radioactivity;

• external radiation from soil deposition;

• consumption of vegetables; and

• consumption of milk and meat.

The results from the dose calculations based on PNPS operations are presented in Table 3.0-1. The dose assessment data presented were taken from the "Radioactive Effluent and Waste Disposal Report" for the period of January 1 through December 31, 2004.

Page 64

Table 3.0-1 Radiation Doses from 2004 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway- mrem/yr Gaseous Liquid Ambient _

Receptor Effluents* Effluents Radiation** Total Total Body 0.10 Zero 2.3 2.4 Thyroid 0.11 Zero 2.3 2.4 Max. Organ 0.11 Zero 2.3 2.4

• Gaseous effluent exposure pathway includes combined dose from particulates, iodines and tritium in addition to noble gases, calculated at the nearest residence.

• • Ambient radiation dose for the hypothetical maximum-exposed individual at a location on PNPS property yielding highest ambient radiation exposure value as measured with TLDs.

Two federal agencies establish dose limits to protect the public from radiation and radioactivity. The Nuclear Regulatory Commission (NRC) specifies a whole body dose limit of 100 mrem/yr to be received by the maximum exposed member of the general public. This limit is set forth in Section 1301, Part 20, Title 10, of the U.S. Code of Federal Regulations (10CFR20). By comparison, the Environmental Protection Agency (EPA) limits the annual whole body dose to 25 mrem/yr, which is specified in Section 10, Part 190, Title 40, of the Code of Federal Regulations (40CFR1 90).

Another useful "gauge of radiation exposure is provided by the amount of dose a typical individual receives each year from natural and man-made (e.g., diagnostic X-rays) sources of radiation. The typical American receives 300 to 400 mrem/yr from such sources.

As can be seen from the doses resulting from Pilgrim Station Operations during 2004, all values are well within the federal limits specified by the NRC and EPA. In addition, the calculated doses from PNPS operation represent only a fraction of a percent of doses from natural and man-made radiation.

In conclusion, the radiological impact of Pilgrim Station operations, whether based on actual environmental measurements or calculations made from effluent releases, would yield doses well within any federal dose limits set by the NRC or EPA. Such doses represent only a small percentage of the typical annual dose received from natural and man-made sources of radiation.

Page 65

4.0 REFERENCES

1) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix A Criteria 64.

2) Donald T. Oakley, "Natural Radiation Exposure in the United States. U. S. Environmental Protection Agency, ORP/SID 72-1, June 1972.

3) National Council on Radiation Protection and Measurements, Report No. 93, "Ionizing Radiation Exposures of the Population of the United States," September 1987.

4) United States Nuclear Regulatory Commission, Regulatory Guide 8.29, Instructions Concerning Risks from Occupational Radiation Exposure,' Revision 0, July 1981.

5) Boston Edison Company, 'Pilgrim Station' Public Information Brochure 100M, WNTHP, September 1989.

6) United States Nuclear Regulatory Commission, Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix l," Revision 1, October 1977.

7) Pilgrim Nuclear Power Station Offsite Dose Calculation Manual, Revision 8, August 1998.

8) United States of America, Code of Federal Regulations, Title 10, Part 20.1301.

9) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix I.

10) United States of America, Code of Federal Regulations, Title 40, Part 190.

11) United States Nuclear Regulatory Commission, Regulatory Guide 4.1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants," Revision 1, April 1975.

12) ICN/Tracerlab, "Pilgrim Nuclear Power Station Pre-operational Environmental Radiation Survey Program, Quarterly Reports,' August 1968 to June 1972.

13) International Commission of Radiological Protection, Publication No. 43, "Principles of Monitoring for the Radiation Protection of the Population," May 1984.

14) United States Nuclear Regulatory Commission, NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," April 1991.

15) United States Nuclear Regulatory Commission, Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program," Revision 1, November 1979.

16) Settlement Agreement Between Massachusetts Wildlife Federation and Boston Edison Company Relating to Offsite Radiological Monitoring - June 9, 1977.

Page 66

APPENDIX A SPECIAL STUDIES None of the samples collected as part of the radiological environmental monitoring program during 2004 indicated any detectable radioactivity attributable to Pilgrim Station operations. Therefore, no special dose analyses were performed.

Page 67

APPENDIX B Effluent Release Information TABLE TITLE PAGE B.1 Supplemental Information 72 B.2-A Gaseous Effluents Summation of All Releases 73 B.2-B Gaseous Effluents - Elevated Releases 74 B.2-C Gaseous Effluents - Ground Level Releases 76 B.3-A Liquid Effluents Summation of All Releases 78 B.3-B Liquid Effluents 79 Page 68

Table B.1 Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Supplemental Information January-December 2004 FACILITY: PILGRIM NUCLEAR POWER STATION LICENSE: DPR-35

1. REGULATORY LIMITS

a. Fission and activation gases: 500 mrem/yr total body and 3000 mrem/yr for skin at site boundary b,c. Iodines, particulates with half-life: 1500 mrem/yr to any organ at site boundary

>8 days, tritium

d. Liquid effluents: 0.06 mrem/month for whole body and 0.2 mrem/month for any organ (without radwaste treatment)

2. EFFLUENT CONCENTRATION LIMITS

a. Fission and activation gases: 10CFR20 Appendix B Table II

b. lodines: 10CFR20 Appendix B Table II

c. Particulates with half-life > 8 days: 10CFR20 Appendix B Table II

d. Liquid effluents: 2E-04 gCi/mL for entrained noble gases; 10CFR20 Appendix B Table II values for all other radionuclides

3. AVERAGE ENERGY Not Applicable

4. MEASUREMENTS AND APPROXIMATIONS OF TOTAL RADIOACTIVITY

a. Fission and activation gases: High purity germanium gamma spectroscopy for all

b. lodines: gamma emitters; radiochemistry analysis for H-3,

c. Particulates: Fe-55 (liquid effluents), Sr-89, and Sr-90

d. Liquid effluents:

5. BATCH RELEASES Jan-Mar _ Apr-Jun Jul-Sep Oct-Dec Jan-Dec 2004 2004 2004 2004 2004

a. Liquid Effluents _

1. Total number of releases: 0 0 0 0 0

2. Total time period (minutes): 0 0 0 0 0

3. Maximum time period (minutes): 0 0 0 0 0

4. Average time period (minutes): 0 0 0 0 0

5. Minimum time period (minutes): 0 0 0 0 0

6. Average stream flow (Liters/min):

during periods of release of 0 0 0 0 0 effluents into a flowing stream

b. Gaseous Effluents None None None None None

6. ABNORMAL RELEASES

a. Liquid Effluents l None l None l None l None l None

b. Gaseous Effluents None None None None None Page 69

Table B.2-A Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Gaseous Effluents - Summation of All Releases January-December 2004 1 1 1 1Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2004 l 2004 l 2004 2004 l 2004 Error A. FISSION AND ACTIVATION GASES Total Release: Ci 2.94E+01 8.01 E+00 8.34E+00 8.91 E+00 5.47E+01 Average Release Rate: gCi/sec 3.74E+00 1.02E+00 1.05E+00 1.12E+00 1.73E+00 +/-22%

Percent of Effluent Control Limit i+

B. IODINE-131 Total oodine-131 Release: Ci 2.58E-04 3.09E-04 3.17E-04 2.82E-04 1.17E-03 Average Release Rate: CVsec 3.29E-05 3.93E-05 3.99E-05 3.55E-05 3.69E-05 +/-20%

Percent of Effluent Control Limit C. PARTICULATES Total Release: Ci 1.91 E-04 1.10E-04 1.20E-04 8.05E-05 5.02E-04 Average Release Rate: VCi/sec 2.42E-05 1.40E-05 1.51 E-05 1.01 E-05 1.59E-05 +/-21%

Percent of Effluent Control Limit * * * *

• Gross Alpha Radioactivity: Ci NDA NDA NDA NDA NDA D. TRITIUM Total Release: Ci 8.41 E+01 5.72E+01 6.30E+01 7.69E+01 2.81 E+02 Average Release Rate: u.CVsec 1.07E+01 l 7.28E+00 7.93E+00 9.67E+00 8.89E+00 +20%

+/-

Percent of Effluent Control Limit *

• r * *

• _

Notes for Table B.2-A:

• Percent of Effluent Control Limit values based on dose assessments are provided in Section 7 of this report.

1. NDA stands for No Detectable Activity.

2. LLD for airborne gross alpha activity listed as NDA is 1E-1 1 ,Ci/cc.

Page 70

Table B.2-B Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Gaseous Effluents - Elevated Release January-December 2004 CONTINUOUS MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released Jan-Mar 2004 Apr-Jun 2004 Jul-Sep 2004 Oct-Dec 2004 Jan-Dec 2004

1. FISSION AND ACTIVATION GASES: Ci Ar-41 1.07E-01 NDA NDA NDA 1.07E-01 Kr-85 NDA NDA NDA NDA NDA Kr-85m 2.35E+00 2.09E+00 2.03E+00 2.08E+00 8.55E+00 Kr-87 1.62E+00 NDA NDA NDA 1.62EE+00 Kr-88 1.58E+00 NDA NDA NDA 1.58E+00 Xe-131m NDA NDA NDA NDA NDA Xe-133 3.06E+00 2.73E+00 3.09E+00 3.30E+00 1.22E+01 Xe-133m NDA NDA NDA NDA NDA Xe-1 35 3.39E+00 3.07E-02 1.44E-01 2.40E-01 3.80E+00 Xe-1 35m 3.07E+00 NDA NDA NDA 3.07E+00 Xe-137 NDA NDA NDA NDA NDA Xe-138 7.13E+00 NDA NDA NDA 7.13E+00 Total for Period 2.23E+01 4.84E+00 5.27E+00 5.62E+00 3.80E+01

2. IODINES: Ci 1-131 1.53E-04 1.39E-04 1.09E-04 8.31 E-05 4.84E-04 1-133 9.81 E-04 1.03E-03 7.20E-04 6.18E-04 3.35E-03 Total for Period 1.13E-03 1.17E-03 8.29E-04 7.01 E-04 3.83E-03

3. PARTICULATES: CI Mn-54 NDA NDA NDA NDA NDA Co-60 NDA NDA NDA NDA NDA Zn-65 NDA NDA NDA NDA NDA Sr-89 1.12E-04 0.OOE+00 0.OOE+00 0.OOE+00 1.1 2E-04 Sr-90 NDA NDA NDA NDA NDA Cs-137 NDA NDA NDA NDA NDA Ba/La-140 NDA NDA NDA NDA NDA Total for Period 1.12E-04 0.OOE+00 0.OOE+00 0.OOE+00 1.12E-04

4. TRITIUM: Cl H-3 2.91 E+00 1.90E+00 2.52E+00 2.38E+00 9.71 E+00 Notes for Table B.2-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 giCi/cc lodines: 1E-12 LCi/cc Particulates: 1E-1 1 glCi/cc Page 71

Table B.2-B (continued)

Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Gaseous Effluents - Elevated Release January-December 2004 BATCH MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released l Jan-Mar 2004 Apr-Jun 2004 Jul-Sep 2004 Oct-Dec 2004 Jan-Dec 2004

1. FISSION AND ACTIVATION GASES: Cl Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A N/A N/A N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A N/A Kr-88 N/A N/A N/A N/A N/A Xe-131m NIA N/A N/A N/A N/A Xe-133 N/A N/A N/A N/A N/A Xe-133m N/A N/A N/A N/A N/A Xe-1 35 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A N/A N/A Xe-1i37 N/A N/A N/A N/A N/A Xe-1i38 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

3. PARTICULATES: Cl Mn-54 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A N/A Notes for Table B.2-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 gCi/cc lodines: 1E-12 CCVcc Particulates: 1E-1 1 gCicc Page 72

Table B.2-C Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Gaseous Effluents - Ground-Level Release January-December 2004 CONTINUOUS MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released Jan-Mar 2004 Apr-Jun 2004 Jul-Sep 2004 Oct-Dec 2004 Jan-Dec 2004

1. FISSION AND ACTIVATION GASES: Ci Ar-41 NDA NDA NDA NDA NDA Kr-85 NDA NDA NDA NDA NDA Kr-85m NDA 5.71 E-01 NDA NDA 5.71 E-01 Kr-87 NDA NDA NDA NDA NDA Kr-88 NDA NDA NDA NDA NDA Xe-131m NDA NDA NDA NDA NDA Xe-133 NDA NDA NDA NDA NDA Xe-133m NDA NDA NDA NDA NDA Xe-135 4.30E+00 2.60E+00 3.08E+00 3.29E+00 1.33E+01 Xe-135m 2.81 E+00 NDA NDA NDA 2.81 E+00 Xe-137 NDA NDA NDA NDA NDA Xe-138 NDA NDA NDA NDA NDA Total for period 7.11 E+00 3.17E+00 3.08E+00 3.29E+00 1.67E+01

2. IODINES: CI 1-131 1.05E-04 1.70E-04 l 2.09E-04 l 1.99E-04 l 6.83E-04 1-133 8.44E-04 8.77E-04 1.11 E-03 1.16E-03 3.99E-03 Total for period 9.49E-04 1.05E-03 1.32E-03 1.36E-03 4.67E-03

3. PARTICULATES: Cl Mn-54 NDA NDA NDA NDA NDA Co-60 NDA NDA NDA NDA NDA Zn-65 NDA NDA NDA NDA NDA Sr-89 7.86E-05 1.1OE-04 1.20E-04 8.05E-05 3.90E-04 Sr-90 NDA NDA NDA NDA NDA Cs-137 NDA NDA NDA NDA NDA Ba/La-140 NDA NDA NDA NDA NDA Total 7.86E-05 1.1 OE-04 1.20E-04 8.05E-05 3.90E-04

4. TRITIUM: Ci H-3 8.12E+01 5.53E+01 6.05E+01 7.45E+01 2.72E+02 Notes for Table B.2-C:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 gCicc lodines: 1E-1 2 gCicc Particulates: 1E-11 IpCicc Page 73

Table B.2-C (continued)

Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Gaseous Effluents - Ground-Level Release January-December 2004 BATCH MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released I Jan-Mar 2004 Apr-Jun 2004 Jul-Sep 2004 Oct-Dec 2004 Jan-Dec 2004

1. FISSION AND ACTIVATION GASES: Cl Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A N/A N/A N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A N/A Kr-88 N/A N/A N/A N/A N/A Xe-131m N/A N/A N/A N/A N/A Xe-1i33 N/A N/A N/A N/A N/A Xe-133m N/A N/A N/A N/A N/A Xe-135 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A N/A N/A Xe-i137 N/A N/A N/A N/A N/A Xe-i138 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

3. PARTICULATES: Cl Mn-54 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A N/A Notes for Table B.2-C:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 iCVcc lodines: 1E-12 pCicc Particulates: 1E-11IgCVcc Page 74

Table B.3-A Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Liquid Effluents - Summation of All Releases January-December 2004 1 1 1 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec l Jan-Dec Total 2004 2004 2004 1 2004 1 2004 I Error A. FISSION AND ACTIVATION PRODUCTS Total Release (not including H-3, N/A N/A N/A N/A N/A noble gas, or alpha): Ci Average Diluted Concentration N/A N/A N/A N/A NIA NIA During Period: jiCimL Percent of Effluent Concentration N/A N/A N/A N/A N/A Lim it*_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B. TRITIUM Total Release: Ci N/A N/A N/A N/A N/A During Period: gCimL I NA Percent of Effluent Concentration N/A N/A N/A N/A N/A Lim it* __ _ _ _ _ __ _ _ _ _ __ _ _ _ _ I C. DISSOLVED AND ENTRAINED GASES Total Release: Ci N/A N/A N/A N/A N/A Average Diluted Concentration N/A N/A N/A N/A N/A During Period: VCVmL NIA Percent of Effluent Concentration N/A N/A N/A N/A N/A Lim ftI_________

D. GROSS ALPHA RADIOACTIVITY Total Release: Ci I N/A N/A N/A N/A N/A N/A E. VOLUME OF WASTE RELEASED PRIOR TO DILUTION Waste Volume: Liters I N/A I N/A I N/A N/A N/A N/A F. VOLUME OF DILUTION WATER USED DURING PERIOD Dilution Volume: Liters I N/A I N/A I N/A N/A N/A N/A Notes for Table B.3-A:

• Additional percent of Effluent Control Limit values based on dose assessments are provided in Section 7 of this report.

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLD for dissolved and entrained gases listed as NDA is 1E-05 tLCVmL.

4. LLD for liquid gross alpha activity listed as NDA is 1E-07 jCi/mL.

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Table B.3-B Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Liquid Effluents January-December 2004 CONTINUOUS MODE RELEASES Nuclide Released Jan-Mar 2004 l Apr-Jun 2004 Jul-Sep2004 Oct-Dec 2004 Jan-Dec2004

1. FISSION AND ACTIVATION PRODUCTS: Cl Cr-51 N/A N/A N/A N/A NIA Mn-54 N/A N/A N/A N/A N/A Fe-55 N/A N/A N/A N/A N/A Fe-59 N/A N/A NIA N/A N/A Co-58 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Zn-69m N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Zr/Nb-95 N/A N/A N/A N/A N/A Mo/Tc-99 N/A N/A N/A N/A NIA Ag-110m N/A N/A N/A N/A N/A Sb-124 N/A N/A N/A N/A N/A 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Cs-134 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-1 40 N/A N/A N/A N/A N/A Ce-141 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. DISSOLVED AND ENTRAINED GASES: Cl Xe-133 N/A N/A N/A N/A N/A Xe-1 35 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A Notes for Table B.3-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for liquid radionuclides listed as NDA are as follows:

Strontium: 5E-08 gtCVmL lodines: 1E-06 gCVmL Noble Gases: 1E-05 gCVmL All Others: 5E-07 VCVmL Page 76

Table B.3-B (continued)

Pilgrim Nuclear Power Station Effluent and Waste Disposal Report Liquid Effluents January-December 2004 BATCH MODE RELEASES Nuclide Released Jan-Mar 2004 Apr-Jun 2004 Jul-Sep 2004 Oct-Dec 2004 Jan-Dec 2004

1. FISSION AND ACTIVATION PRODUCTS: CI Cr-541 N/A N/A N/A N/A N/A Mn-54 N/A N/A N/A N/A N/A Fe-55 N/A N/A N/A N/A N/A Fe-59 N/A N/A N/A N/A N/A Co-58 NIA N/A N/A N/A N/A 0n-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Zn-69m N/A N/A N/A N/A N/A Sr-89 N/A N/A NIA N/A N/A Sr-90 N/A N/A N/A N/A N/A Zr/Nb-95 N/A N/A N/A N/A NIA Mo/Tc-99 N/A N/A N/A N/A N/A Ag-1240 N/A N/A N/A N/A N/A Sb-1124 N/A N/A N/A N/A N/A 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Cs-1 34 N/A N/A N/A N/A N/A Cs-1 37 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Ce-141 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. DISSOLVED AND ENTRAINED GASES: Cl Xe-1i33 N/A N/A N/A N/A N/A Xe-1135 N/A N/A N/A N/A N/A Total for period N/A I N/A N/A N/A N/A Notes for Table 8.3-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for liquid radionuclides listed as NDA are as follows:

Strontium: 5E-08 tLCVmL lodines: lE-06 gCVmL Noble Gases: 1E-05 gCi/mL All Others: 5E-07 t+/-CVmL Page 77

APPENDIX C LAND USE CENSUS RESULTS The annual land use census for gardens and milk and meat animals in the vicinity of Pilgrim Station was performed between July 15 and October 28, 2004. The census was conducted by driving along each improved road/street in the Plymouth area within 5 kilometers (3 miles) of Pilgrim Station to survey for visible gardens with an area of greater than 500 square feet. In compass sectors where no gardens were identified within 5 km (SSW, WNW, NW, and NNW sectors), the survey was extended to 8 km (5 mi). A total of 31 gardens were identified in the vicinity of Pilgrim Station. In addition, the Town of Plymouth Animal Inspector was contacted for information regarding milk and meat animals.

Atmospheric deposition (D/Q) values at the locations of the identified gardens were compared to those for the existing sampling program locations. These comparisons enabled PNPS personnel to ascertain the best locations for monitoring for releases of airborne radionuclides. Gardens yielding higher D/Q values than those currently in the sampling program were also sampled as part of the radiological environmental monitoring program.

Based on assessment of the gardens identified during the 2004 land use census, samples of garden-grown vegetables or naturally-growing vegetation (e.g. grass, leaves from bushes or trees, etc.) were collected at or near the closest gardens in each of the following landward compass sectors. These locations, and their distance and direction relative to the PNPS Reactor Building, are as follows:

Rocky Hill Road 0.9 km SE (garden not grown in 2004; however, historic location)

Brook Road 2.9 km SSE Beaver Dam Road 3.4 km S Bay Colony Drive 3.1 km WSW Clay Hill Road 1.6 km W In addition to these special sampling locations identified and sampled in conjunction with the 2004 land use census, samples were also collected at or near the Plymouth County Farm (5.6 km W), and from a control location in Bridgewater (31 km W).

Samples of naturally-growing vegetation were also collected in the vicinity of the site boundary locations yielding the highest deposition (D/Q) factors for each of the two release points. These locations, and their distance and direction relative to the PNPS Reactor Building, are as follows:

Highest Main Stack D/Q: 1.5 km SSW Highest Reactor Building Vent D/Q: 0.5 km ESE 2" highest D/Q, both release points: 1.1 km S No new milk or meat animals were identified during the land use census. In addition, the Town of Plymouth Animal Inspector stated that their office is not aware of any animals at locations other than the Plimoth Plantation and the Plymouth County Farm. Samples of milk and forage have historically been collected from the Plymouth County Farm, and forage samples were part of the 2004 sampling program.

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APPENDIX D ENVIRONMENTAL MONITORING PROGRAM DISCREPANCIES There were a number of instances during 2004 in which inadvertent issues were encountered in the collection of environmental samples. All of these issues were minor in nature and did not have an adverse effect on the results or integrity of the monitoring program. Details of these various problems are given below.

During 2004, eleven thermoluminescent dosimeters (TLDs) were not recovered from their assigned locations during the quarterly retrieval process. During the first quarter retrieval, the TLD at Station H could not be located, and was presumed lost to storm damage. A search of the area in the immediate vicinity of the TLD posting location failed to find the TLD. During the second quarter retrieval, the TLDs located at Emerson and Priscilla (EP), Station K, and Bourne Road (BE) were presumably lost to storm damage or vandalism; the TLD at Hilidale Road (HD) was lost when the utility pole to which it was attached was replaced; and the TLD at Plymouth Center (PC) was lost during construction activities at the Town Hall. Vandalism or storm damage was assumed to be the cause of losses of the TLDs at Cleft Rock (CR),

Russell Mills Road (RM), College Pond (CP), and Cedarville Substation (CS) during the third quarter.

Vandalism or storm damage was also assumed to be the cause of losses of the TLD at Station A during the fourth quarter. Despite these losses, the 429 TLDs that were collected (98%) allowed for adequate assessment of the ambient radiation levels in the vicinity of Pilgrim Station.

Within the air sampling program, there were a few instances in which continuous sampling was interrupted at the eleven airborne sampling locations during 2004. Most of these interruptions were due to short-term power losses and were sporadic and of limited duration (less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> out of the weekly sampling period). Such events did not have any significant impact on the scope and purpose of the sampling program, and all lower limits of detection (LLDs) were met for both particulates and iodine-131 on the filters.

During the week of 13-20 Jan, the fuse blew at the Manomet Substation air sampler shortly after the weekly filter exchange. When the filter was collected on 20-Jan, the total sample volume was estimated to be less than 10 cubic meters, and the decision was made to not perform analyses on the filters due to the small sample volume. The fuse was replaced and the sampler restarted.

During the week of 18-25 May, the dry gas meter at the control location in Weymouth was found to have stopped advancing, indicating an abnormally low volume. The sampler was replaced, and the total volume for the week was estimated based on the pump run time multiplied by the average flow rates measured at the beginning and end of the sampling period.

During the week of 15-22 Nov, blown fuses were found at the Pedestrian Bridge (run time = 120.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) and at the Cleft Rock (run time = 3.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) air samplers. The fuses were replaced and the samplers restarted. The filters were collected and analyzed. The required LLDs were achieved on the sample collected from the Pedestrian Bridge sampler, but the very low sample volume at the Cleft Rock location prevented the analytical laboratory from reaching the required LLDs on the particulate and iodine filters.

Unexpectedly low sample volumes were observed for samples collected at the Cleft Rock location beginning with the samples collected on 10-Nov and continuing through the end of the year. Despite the low sample volumes, the amount of dust loading on the particulate filters seemed normal, and the total gross beta activity was comparable to that from other sampling locations. When the normal gross beta activity collected on the filter was divided by the unusually low volume, the gross beta concentrations appeared to be elevated when compared to other locations for the same period. This led REMP personnel to question the results obtained from the dry gas meter. The problem was traced to a crack in the plastic tubing connecting the discharge of the sample pump to the dry gas meter. Air was escaping through the crack in the tubing. Thus, the dry gas meter was only registering a portion of the air pulled through the filters. The tubing was replaced, and the volumes for the affected period were estimated from the

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measured pump run times multiplied by the flow rate indicated by an in-line rotameter. When corrected for these volumes, weekly gross beta concentrations for the period were comparable to those collected from other stations for the period.

During the last week of 2004, a large snow storm prevented safe access to two of the sampling locations.

The particulate filters and charcoal cartridges were not collected from the Overlook Area (OA) and Property Line (PL) sampling stations during the normal weekly exchange. These filters were left on for an additional week, and collected during the next collection cycle, on 04-Jan-2005. The filters were analyzed, and all LLDs were met as required. Since the sampling period for the latter week of December (21 through 28-Dec) was contiguous and represented by the filters collected on 04-Jan-2005, the results obtained from the 04-Jan filters were also attributed to the 21-28 December period.

Despite the lower-than-normal sampling volumes in the various instances involving power interruptions and equipment failures, required LLDs were met on 570 of the 571 particulate filters, and 570 of the 571 of the iodine cartridges collected during 2004. None of the sample analyses associated with limited pump run times indicated any questionable or anomalous results. When viewed collectively during the entire year of 2004, the following sampling recoveries were achieved in the airborne sampling program:

Location Recovery Location Recovery Location Recovery Ws 100.0% PB 99.2% PC 100.0%

ER 99.5% OA 98.0% MS 98.0%

WR 99.9% EB 100.0% EW 99.9%

PL 98.0% CR 98.1%

An alternate location had to be found for sampling control vegetable samples in the Bridgewater area. In past years, samples had been collected at the Bridgewater County Farm, associated with the Bridgewater Correctional Facility. Due to loss of state funding for garden projects during 2004, no garden was grown.

An alternate location was found at the Hanson Farm in Bridgewater, located in the same compass sector, and at approximately the same distance as the Bridgewater County Farm. As expected for control samples, vegetables collected at this location only contained naturally-occurring radioactivity (K-40).

Some problems were encountered in collection of crop samples during 2004. Crops which had normally been sampled in the past (lettuce, tomatoes, potatoes, and onions) were not grown at the Plymouth County Farm (CF) during 2004. Pumpkins and squash were substituted for the edible 'hard' vegetables, whereas samples of naturally-growing leafy vegetation (grass, leaves from trees and bushes, etc.) were substituted for the lettuce. No radionuclides attributed to PNPS operations were detected in any of the samples.

Naturally-growing leafy vegetation (grass, leaves from trees and bushes, etc.) was collected near some gardens identified during the annual land use census. Due to the unavailability of crops grown in several of these gardens, these substitute samples were collected as near as practicable to the gardens of interest. No radionuclides attributed to PNPS operations were detected in any of the samples. Additional details regarding the land use census can be found in Appendix C of this report.

The cranberry bog at Manomet Point (MP) was not in production during 2004, so a sample could not be obtained from this location. Samples were collected as required from the other indicator bog located along Bartlett Road (BT), and an additional sample was collected from a bog located along Beaver Dam Road.

Again, the extensive sampling of leafy vegetation would provide a better indication of deposition radionuclides, so the loss of the Manomet Point sample does not adversely affect overall monitoring efforts. A similar situation occurred in the case of the control location for cranberries. In the past, the control sample of cranberries had been collected from the Pine Street Bog in Halifax. Since this bog was not in production during 2004, a substitute sample was collected from a bog in Kingston, beyond the influence of Pilgrim Station.

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Several problems were encountered with the continuous composite collection of water samples at the PNPS discharge canal during 2004. Although Pilgrim Station did not discharge any liquid wastes containing radioactivity during calendar year 2004, sampling capability was maintained during the year.

During the period of 20-27 Jan 2005, the lift pump providing water to the composite sampling station blew a fuse during the week and resulted in a less than minimum volume sample during the week. A grab sample was collected to substitute for the continuous composite sample. Similar problems with the lift pump also occurred during the week of 13-20 Jul when the pump failed from normal use, and during the week of 19-26 Oct when a switch controlling the pump failed. In both of these cases, a grab sample was substituted for the weekly composite sample.

There were four instances when problems were experienced with the composite sampler itself. On 22-Mar, the composite sampler was found in a halted state, and it was not clear whether the sampler was not returned to service from the previous week, or if a power interruption had resulted in the sampler entering a halted state. During the week of 06-13 Apr, the programming mode controlling the sampling interval was found to be corrupted, and the sampler had to be reprogrammed. A similar event occurred during the week of 30-Jun through 06-Jul, and the sampler was again reprogrammed. During the week of 13-20 Apr, the peristaltic tubing which draws the sample suction failed, and the sampler did not collect sufficient volume. In each of these four cases, grab samples were substituted for the weekly composite samples.

Due to inclement weather and unavailability of contractor personnel during July, the collection of a lobster sample from the discharge canal outfall was not completed by the end of the month. Although sampling is normally performed on a monthly basis from June through September, the ODCM requirement does not specify a rigid one-month sampling interval. A sample was procured on 30-Aug. The remainder of the lobster collections for the year were shifted by one month, and the remaining samples were collected in September and October, fulfilling the ODCM requirement to sample lobster four times from May through October.

As part of the standardization of the ODCM that occurred in 2003, sampling of Group I (bottom-distribution) and Group II (near-bottom distribution) fishes was changed from a quarterly interval to a semiannual interval, to be performed during the sampling windows of April-May, and again in October-November. A sample of Group II fishes was not collected within the first targeted period, due to seasonal unavailability. Such fish species move to deeper water during colder months, and were not available.

Repeated efforts were made during the period from April through May, and a sample was finally collected in late June. Samples of Group I and Group II fishes were also not available for sampling in the vicinity of the discharge outfall during the latter sampling period of 2004. Repeated and concerted efforts were made during the months of October through December, but failed to produce fish samples during the period.

In summary, the various problems encountered in collecting and analyzing environmental samples during 2004 were relatively minor when viewed in the context of the entire monitoring program. None of the discrepancies resulted in an adverse impact on the overall monitoring program.

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APPENDIX E J.A. FITZPATRICK INTERLABORATORY COMPARISON PROGRAM E.1 Program Description An important factor in assuring the quality of radiological environmental monitoring results is the analytical laboratory's participation in an Interlaboratory Comparison Program. The Interlaboratory Comparison Program shall include sample media for which samples are routinely collected and for which Comparison samples are commercially available. Participation in an Interlaboratory Comparison Program ensures that independent checks on the precision and accuracy of the measurement of radioactive material in the environmental samples are performed as part of the Quality Assurance Program for environmental monitoring. To fulfill the requirement for an Interlaboratory Comparison Program, the JAF Environmental Laboratory has engaged the services of two independent laboratories to provide quality assurance comparison samples. The two laboratories are Analytics, Incorporated in Atlanta, Georgia and the U.S.

Department of Energy's Environmental Measurements Laboratory (EML) in New York City.

Analytics supplies sample media as blind sample spikes, which contain certified levels of radioactivity unknown to the analysis laboratory. These samples are prepared and analyzed using standard laboratory procedures. The results are submitted to Analytics, which issues a statistical summary report. The JAFNPP Environmental Laboratory uses predetermined acceptance criteria methodology for evaluating the laboratory's performance for Analytic's sample results.

In addition to the Analytics Program, the JAF Environmental Laboratory participated in the Environmental Measurements Laboratory (EML) Quality Assessment Program (QAP). EML supplies sample media as blind sample spikes to approximately 127 laboratories worldwide. These samples, containing a spiked amount of low level activity, are analyzed using standard laboratory procedures. The results are submitted to the Environmental Measurements Laboratory for statistical evaluation. Reports are provided to each participating laboratory, which provide an evaluation of the laboratory's performance.

In 2004, the program provided by Environmental Measurements Laboratory was scaled back as a result of the laboratory being reorganized under the Federal Department of Homeland Security as part of the Science and Technology directorate. Under the reorganization, the laboratory no longer provided spiked cross check samples to commercial laboratories. The JAF Environmental lab was eligible to participate in the first of two annual quality assessment programs (QAP-0403) in 2004 before the program was restructured.

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E.2 Program Schedule SAMPLE LABORATORY SAMPLE PROVIDER YEARLY EML MEDIA ANALYSIS ANALYTICS TOTAL Water Gross Beta 0 1 1 Water Tritium 1 1 2 Water 1-131 2 0 2 Water Mixed Gamma 2 1 3 Air Gross Beta 2 1 3 Air 1-131 2 0 2 Air Mixed Gamma 2 1 3 Milk 1-131 2 0 2 Milk Mixed Gamma 2 0 2 Soil Mixed Gamma 1 0 1 Vegetation Mixed Gamma 1 0 1 TOTAL SAMPLE INVENTORY 17 17 5 E.3 Accentance Criteria Each sample result is evaluated to determine the accuracy and precision of the laboratory's analysis result.

The evaluation method for the QA sample results is dependent on the supplier of the sample. The sample evaluation methods are discussed below.

E.3.1 Analytics Sample Results Samples provided by Analytics are evaluated using what is specified as the NRC method. This method is based on the calculation of the ratio of results reported by the participating laboratory (QC result) to the Vendor Laboratory Known value (reference result).

An Environmental Laboratory analytical result is evaluated using the following calculation:

The value for the error resolution is calculated.

The error resolution = Reference Result Reference Results Error Using the appropriate row under the Error Resolution column in Table E.3-1 below, a corresponding Ratio of Agreement interval is given.

The value for the ratio is then calculated.

Ratio = QC Result of Agreement Reference Result If the value falls within the agreement interval, the result is acceptable.

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TABLE E.3-1 ERROR RESOLUTION RATIO OF AGREEMENT

<3 0.4-2.5 3.1 to7.5 0.5-2.0 7.6 to 15.5 0.6-1.66 15.6 to 50.5 0.75-1.33 50.6 to 200 0.8-1.25

>200 0.85-1.18 Again, this acceptance test is generally referred to as the "NRC" method. The acceptance criteria is contained in Procedure DVP-04.01 and was taken from the Criteria of Comparing Analytical Results (USNRC) and Bevington, P.R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York, (1969). The NRC method generally results in an acceptance range of approximately t 25% of the Known value when applied to sample results from the Analytics Inc. Interlaboratory Comparison Program.

This method is used as the procedurally required assessment method and requires the generation of a nonconformity report when results are unacceptable.

E.3.2 Environmental Measurements Laboratory (EML)

The laboratory's analytical performance is evaluated by EML based on the historical analytical capabilities for individual analyte/matrix pairs. The statistical criteria for Acceptable Performance, NAN, has been chosen by EML to be between the 15th and 85th percentile of the cumulative normalized distribution, which can be viewed as the middle 70% of all historic measurements. The Acceptable With Warning criteria, NW", is between the 5th and 15th percentile and between the 85th and 95th percentile. In other words, the middle 70% of all reported values are acceptable, while the other 5th-15th (10%) and 85th-95th percentiles (10%)

are in the warning area. The Not Acceptable criteria, "N", is established at less than the 5th percentile and greater than the 95th percentile, that is, the outer 10% of the historical data. Using five years of historical analytical data, the EML, determined performance results using the percentile criteria summarized below:

Result Cumulative Normalized Distribution Acceptable ("A") 15%- 85%

Acceptable with Warning ('W") 5% - 15% or 85% - 95%

Not Acceptable ("N") <5% or >95%

E.4 Program Results Summary The Interlaboratory Comparison Program numerical results are provided on Table E.4-1.

E.4.1 Analytics QA Samples Results Seventeen QA blind spike samples were analyzed as part of Analytics 2004 Interlaboratory Comparison Program. The following sample media were evaluated as part of the comparison program.

• AirCharcoalCartridge: 1-131

• Air Particulate Filter: Mixed Gamma Emitters, Gross Beta

• Water: 1-131, Mixed Gamma Emitters, Tritium

• Soil: Mixed Gamma Emitters

• Milk: 1-131, Mixed Gamma Emitters

• Vegetation: Mixed Gamma Emitters Page 84

The JAF Environmental Laboratory performed 81 individual analyses on the seventeen QA samples. Of the 81 analyses performed, 80 were in agreement using the NRC acceptance criteria for a 98.8% agreement ratio.

Sample non-conformities are discussed in Section E.4.1.1.

E.4.1.1 Analytics SamDle Nonconformities A. Analytics Sample E-4166-05, Zn-65 in Soil -- Nonconformity No. 2004-01 A spiked mixed gamma in soil sample supplied by Analytics, Inc., was analyzed in accordance with standard laboratory procedures. The sample contained a total of nine radionuclides for analysis. Nine of the nine radionuclides present were quantified. Eight of the nine radionuclides were quantified within the acceptable range. The mean result for Zn-65 was determined to be outside the QA Acceptance Criteria resulting in a sample nonconformity. The soil sample was analyzed five times using four different detectors with the mean Zn-65 result reported as 334 pCi/kg. The known result for the sample was 262 pCi/kg as determined by the supplier. One of the five reported results was 292 pCi/kg and resulted in an agreement when compared to the known of 262 pCVkg with a ratio of 1.11. The remaining 4 individual results were outside the acceptance criteria and had ratios to the known value that ranged from 1.29 to 1.34. All of the analysis had relatively high associated counting errors, which ranged from 8.2% to 13.1%.

An evaluation of the Zn-65 result was performed. The spectrum and peak search results were examined with no anomalies identified. Zn-65 decays by electron capture with a 244 day half-life and a gamma ray energy of 1115 keV with a yield of 50.75%. No significant secondary gamma energies are produced in the Zn-65 decay scheme. The average net count rates of the five analyses were low and ranged from a high of 1.50 counts per minute to a low of 0.93 counts per minute. The low activity in the sample resulted in high associated counting errors as noted above.

In soil samples, Ra-226 is a naturally occurring radionuclide, which produces a secondary peak at 1120 KeV.

The presence of Ra-226 (1120 KeV) and Zn-65 (1115 KeV) in the sample resulted in a doublet peak formation in this region of the spectrum. In most cases, the computer algorithm can differentiate the two adjacent peaks and correct for interferences from overlapping (doublet) peaks. In these sample spectrums, there was a low number of total counts in the 1110, to 1130 KeV area of the spectrum. The low count rate and subsequent poor peak shape made it difficult for the algorithm to select an exact background for determining the total counts in the peak. In addition low count rate made it difficult to define the two peaks contained in the doublet. To determine if this was a programmatic or systematic error inherent to the software/analysis system, an extent of condition was performed using another spiked sample result for any similar nonconformities. In 2004 eleven spiked samples were analyzed which contained certified concentrations of Zn-65 and other radionuclides. This sample set included four additional samples. The results are presented in the following table:

Page 85

2004 Zn-65 Rest SamDle ID Medium JAF Reference Ratio E-4053-05 Water pCi/liter 146+/- 6 143 +/- 5 1.03 E-4319-05 Water pCi/liter 123* 3 125 +/- 4 0.98 E-4054-05 Filter pCi/filter 98+/-5 95+/-3 1.03 E-4320-05 Filter pCi/filter 81 +/-2 84+/-3 0.96 E-4321 -05 Milk pCiliter 155*7 167+/-6 0.93 E-4165-05 Milk pCi/liter 99+/-3 99+/-3 0.84 E-4168-05 Vegetation pCikg 149+/-8 232+/-8 1.12 E-4154-09** Soil pCi/kg 289 +/-20 262 +/- 5 1.10 E-4051-09* Soil pCikg 289+/-17 252 +/-6 1.15 E-4253-09* Soil pCVkg 239 +/-12 248+/-6 0.96 E-4373-09* Soil pCVkg 336 +/- 22 329+/-6 1.02 Mean Ratio = 1.01

• Provided by Lab client-NOT reported in Annual Report

• • Duplicate sample of E-4165-05 provided by Lab client-NOT reported in Annual Report A duplicate sample of this sample (E-4166-05) was submitted to the laboratory as a blind spike (E-4154-09).

This sample was made from the exact supplier stock as the non-conformity sample. The Zn-65 result for this duplicate sample was in full agreement with the known value on all five of the analysis performed. The mean Zn-65 result for the duplicate sample was 289

• 13 pCi/Kg for a ratio to the known value of 1.10 (See results in the table above). The mean ratio for all eleven Zn-65 results was 1.01. The mean ratio for the four soil sample Zn-65 results was 1.06. The mean ratio value for the eleven samples noted above and each individual ratio values for each of Zn-65 results are excellent indicators that the routine measurement of Zn-65 in environmental media is accurate. These results demonstrate that there is no systematic error or bias for the analysis of Zn-65 in soil or other environmental sample media. No corrective action was implemented as a result of this non-conformity.

E.4.2 Environmental Measurements Laboratory (EML)

In 2004, JAF Environmental Laboratory participated in both the EML Quality Assessment Programs, QAP-0403. Sample sets consisted of the following sample media:

• Water: Gross Beta, Mixed Gamma Emitters

• Water: Trtium

• Air Particulate Filter: Mixed Gamma Emitters/Gross Beta A total of 5 samples containing 8 individual radionuclides were evaluated for the samples included in QAP-0403. Using the EML acceptance criteria, 8 of 8 radionuclides analyses (100%) were evaluated to be acceptable. Results for the EML cross Check Program are contained in the table below and results for all participants can be viewed on-line at www.eml.doe.aov. A summary of the JAF Environmental Laboratory results is as follows:

Matrix Total Analyses Acceptable Not Acceptable Air 4 4 0 Water 4 4 0 Total 8 8 0 Percentage 100% 0.0%

Page 86

There were no sample nonconformities with samples analyzed for the Environmental Measurements Laboratory program.

Page 87

TABLE E.4-1 INTERLABORATORY INTERCOMPARISON PROGRAM Gross Beta Analysis of Air Particulate Filters -- (DCifilter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 6/17/2004 E4164-05 AIR 159.8 t 3.1 pCi/fifter GROSS 158.5 +/- 3.1 BETA 155.7 +/- 3.1 Mean = 158.0 +/- 1.8 166.0 +/- 5.5 0.95 A 12/9/2004 E-4376-05 AIR 223.2 +/- 2.1 pClfilter GROSS 219.7 +/- 2.1 BETA 222.4 +/- 2.1 Mean = 221.8

• 1.2 225.0 +/- 7.5 0.99 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 88

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Tritium Analysis of Water -- (PCiAiter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 3/25/2004 E-4052-05 WATER 4681

• 171 pC/liter 4699

• 171 H-3 4716 +/- 171 Mean = 4699

• 99 4700 +/- 300 1.00 A (1) Results reported as activity +/-1 sigma. Sample analyzed by JAF Environmental Laboratory (2) Results reported as activity *2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 89

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Iodine Analysis of Water. Air and Milk JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 3/25/2004 E-4053-05 WATER 92.9

• 1.9 pCiAiter 13* 94.1

• 1.7 90.7

• 1.8 Mean = 92.6 +/- 1.0 90.2 +/- 3.0 1.03 A 6/17/2004 E-4167-05 AIR 83.8

• 5.6 pCVcc113 78.3 +/- 5.8 80.4 +/- 4.9 Mean = 80.8 +/- 3.1 83.1 +/- 2.8 0.97 A 6/17/2004 E-4165-05 MILK 53.0

• 1.7 pCiAiter 1-131-* 55.4 2.2 56.0

• 2.0 Mean= 55.1 0.8 58.2 +/- 1.9 0.95 A 9/16/2004 E-4322-05 Al R 72.4 +/- 5.2 pCicc 1-131 75.0 +/- 4.8 73.5 +/- 4.9 Mean = 73.6 +/- 2.9 76.7 +/- 2.6 0.96 A 9/16/2004 E-4319-05 WATER 69.7 +/- 1.1 pCiAiter I131* 7.2 +/- 1.2 71.7 +/- 1.0 Mean = 69.5

• 0.6 70.8 +/- 2.4 0.98 A 9/16/2004 E-4321-05 MILK 74.1 +/- 1.2 p-13te r 72.7 +/- 1.1 75.1

• 1.3

_ __ __ __ __ __ __ _ _ _ _ _ _ _ _ _ Ma 7 .0

• 0.7 83.5 +/- 2.8 0.89 A (1) Results reported as activity 11sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(*) Result determined by Resin Extraction/Gamma Spectral Analysis.

(A) Evaluation Results, Acceptable.

Page 90

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Water -- (pCi/liter)

JAF ENV REFERENCE I DATE ID NO. MEDIUM I ANALYSIS I JAF RESULT (1) LAB* (2) _RATIO (3)

. _ 1 _ I 3/25/2004 I E-4053-05 WATER 81.5 +/- 10.4 pCiAiter 86.2

• 1.1 Ce-141 89.0

• 9.4 80.4 +/- 7.8 Mean = 84.3

• 4.0 85.0

• 2.8 0.99 A 362.0 t 48.1 325.0

• 6.6 Cr-51 431.0 +/- 47.7 305.0 +/- 35.8 Mean = 355.8

• 19.2 326.0

• 10.9 1.09 A 83.3 +/- 1.4 Cs-1 34 85.9

• 7.0 84.5 +/- 5.7 Mean = 84.6

• 3.1 89.7

• 3.0 0.94 A 174.0

• 9.3 Cs-137 178.0

• 1.1 174.0 +/- 9.0 Mean = 175.3

• 4.3 185.0 +/- 6.2 0.95 A 116.0 +/- 7.9 116.0 +/- 1.0 Mn-54 116.0

• 7.8 115.0 +/- 5.9 Mean = 115.8

• 3.1 114.0 +/- 3.8 1.02 A 66.3 +/- 8.8 59.5 t 1.i Fe-59 64.4 t 8.1 70.9 +/- 5.7 Mean= 65.3 +/- 3.3 56.7 +/- 1.9 1.15 A 161.0 +/- 15.2 149.0 +/- 1.7 Zn-65 124.0 +/- 14.5 151.0

• 10.8 Mean= 146.3

• 5.9 143.0 +/- 4.8 1.03 A 143.0 +/- 6.8 153.0 +/- 0.8 Co-60 145.0 +/- 6.6 153.0 +/- 5.0 Mean = 148.5 +/- 2.7 153.0 +/- 5.1 0.97 A 114.0 t 8.3 116.0 +/- 1.0 Co-58 118.0 +/- 7.8 112.0 +/- 5.9

______ A A 1. 1 Mean = 115.0 +/- 3.2 A 112.0 +/- 3.7 I 1.03 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 91

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Water -- (Ci/liter)

JAF ENV EEEC DATE ID NO. I MEDIUM ANALYSIS I JAF RESULT (1) LAB- (2) RATIO (3) 9/16/2004 1 E-4319-05 WATER 251.0

• 9.1 pCi/liter 257.0

• 8.6 Ce-141 255.0

• 7.8 Mean = 254.3 + 4.9 250.0

• 8.3 1.02 A 163.0

• 30.9 Cr-51 209.0 +/- 31.8 173.0 +/- 30.4 Mean = 181.7 +/- 17.9 223.0 +/- 7.5 0.81 A 91.6

• 5.8 Cs-134 90.0 +/- 9.2 97.9 +/- 5.4 Mean = 93.2 +/- 4.1 96.4 +/- 3.2 0.97 A 217.0 +/- 7.2 Cs-137 206.0 +/- 6.8 206.0 +/- 6.6 Mean = 209.7 +/- 4.0 215.0

• 7.2 0.98 A 182.0 +/- 6.9 Mn-54 169.0 +/- 6.4 175.0 +/- 6.3 Mean = 175.3 +/- 3.8 181.0 +/- 6.1 0.97 A 83.6

• 6.6 Fe-59 99.6 +/- 6.4 96.7

• 6.1 Mean = 93.3 +/- 3.7 91.6

• 3.1 1.02 A 178.0 +/- 11.4 Zn-65 156.0 +/- 10.2 161.0 +/- 10.1 Mean = 165.0 +/- 6.1 178.0

• 5.9 0.93 A 117.0 +/- 4.4 Co-60 132.0 +/- 4.5 119.0 +/- 4.1 Mean = 122.7 +/- 2.5 125.0 +/- 4.2 0.98 A 100.0 +/- 5.6 89.4 +/- 5.2 Co-58 90.2 +/- 5.0 Mean = 93.2 +/- 3.1 94.6 t 3.2 0.99 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 92

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis of Air Particulate Filters -- (DCi/filter)

JAF ENV] REFERENCE DATE ID NO. I MEDIUM I ANALYSIS I JAF RESULT (1) I LAB* (2) RATIO (3) 3/25/2004 I E-4054-05 FILTER 51.1 +/- 2.9 pCi/filter 52.8 +/- 3.6 Ce-141 57.2 t 2.9 Mean = 53.7 +/- 1.8 56.6 +/- 1.9 0.95 A 192.0 +/- 21.1 Cr-51 214.0 +/- 25.4 194.0 +/- 19.7 Mean = 200.0 +/- 12.8 217.0 +/- 7.2 0.92 A 55.0 +/- 4.1 Cs-1 34 52.4 +/- 5.0 50.3 +/- 4.0 Mean = 52.6 +/- 2.5 59.7 +/- 2.0 0.88 A 116.0 +/- 5.0 Cs-137 131.0 +/- 6.4 116.0 +/- 4.9 Mean= 121.0 +/- 3.1 123.0

• 4.1 0.98 A 79.2 +/- 4.6 Mn-54 77.4 +/- 5.5 76.0

• 4.3 Mean = 77.5

• 2.8 75.8

• 2.5 1.02 A 33.7 +/- 4.7 Fe-59 37.1

• 5.7 40.2 +/- 4.7 Mean = 37.0 +/- 2.9 37.8

• 1.3 0.98 A 87.7 +/- 8.6 Zn-65 109.0 +/- 11.1 97.7 +/- 8.3 Mean = 98.1 +/- 5.4 95.1 +/- 3.2 1.03 A 105.0 +/- 4.3 Co-60 95.7 +/- 5.0 91.3

• 4.0 Mean = 97.3

• 2.6 102.0

• 3.4 0.96 A 78.3 +/- 4.6 71.6 +/- 5.5 Co-58 71.9 +/- 4.4

& .. a.

Mean = 73.9 +/- 2.8 I 74.6

• 2.5 a. 0.99 A I

(1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 93

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis of Air Particulate Filters -- (oCitfilter)

JAF ENV REFERENCE I DATE ID NO.

JMEDIUM ANALYSIS JAF RESULT (1) - LAB* (2) RATIO (3) 9/16/2004 1 E-4320-05 FILTER 183.0

• 5.0 pCi/filter 195.0 +/- 5.7 Ce-141 173.0 +/- 5.1 Mean = 183.7

• 3.0 168.0

• 5.6 1.09 A 132.0

• 20.9 Cr-51 128.0

• 21.5 142.0

• 21.7 Mean = 134.0 +/- 12.3 150.0

• 5.0 0.89 A 60.4

• 8.4 Cs-1 34 74.8 +/- 5.3 76.0

• 4.8 Mean = 70.4 +/- 3.7 64.9

• 2.2 1.08 A 148.0

• 5.7 Cs-137 155.0

• 6.2 149.0

• 5.3 Mean = 150.7

• 3.3 145.0 +/- 4.8 1.04 A 154.0

• 6.0 Mn-54 143.0

• 6.0 135.0

• 5.3 Mean = 144.0

• 3.3 122.0 +/- 4.1 1.18 A 78.7 +/- 6.1 Fe-59 78.7 +/- 6.3 73.3

• 5.4 Mean = 76.9

• 3.4 61.6 +/- 2.1 1.25 A 144.0

• 10.4 Zn-65 145.0 +/- 10.8 135.0

• 9.1 Mean = 141.3 +/- 5.8 120.0 +/- 4.0 1.18 A 87.0 +/- 3.8 Co-60 73.7 +/- 3.9 82.3

• 3.5

,Mean = 81.0o 2.1 84.3 +/- 2.8 0.96 A 77.0 +/- 4.8 69.2 +/- 4.9 Co-58 64.2 +/- 4.2 Mean = 70.1 +/- 2.7 63.7 +/- 2.1 1.10 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 94

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Milk -- (nCi/liter)

JAF ENV t REFERENCE DATE I ID NO. MEDIUM ANALYSIS I JAF RESULT (1) LAB* (2) RATIO (3) 9/16/2004 1 E-4321-05 MILK 226.0 +/- 8.5 pCifliter 220.0 +/- 9.1 Ce-141 230.0

• 8.6 Mean = 225.3 +/- 5.0 235.0

• 7.8 0.96 A 256.0

• 35.5 Cr-51 212.0 +/- 32.7 145.0 +/- 37.0 Mean = 204.3 +/- 20.3 210.0 +/- 7.0 0.97 A 84.0 +/- 9.5 Cs-134 81.4 +/- 9.6 75.7 +/- 11.2 Mean = 80.4 +/- 5.9 90.6 +/- 3.0 0.89 A 193.0 +/- 6.6 Cs-1 37 188.0 +/- 6.8 179.0 +/- 7.9 Mean = 186.7 +/- 4.1 202.0 +/- 6.7 0.92 A 180.0 +/- 6.5 Mn-54 185.0 +/- 6.9 169.0 +/- 7.9 Mean = 178.0 +/- 4.1 171.0 +/- 5.7 1.04 A 90.6 +/- 6.4 Fe-59 92.6 +/- 7.2 97.5 +/- 8.6 Mean = 93.6 +/- 4.3 86.1 +/- 2.9 1.09 A 173.0 +/- 11.4 Zn-65 150.0 +/- 11.4 143.0

• 13.3 Mean = 155.3

• 7.0 167.0 +/- 5.6 0.93 A 108.0 +/- 4.2 Co-60 116.0

• 4.5 122.0 +/- 5.5

,Mean = 115.3 +/- 2.8 118.0 +/- 3.9 0.98 A 83.7 +/- 5.2 88.4

• 5.7 Co-58 81.5 +/- 6.3 Mean = 84.5 +/- 3.3 89.0

• 3.0 0.95 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(*) Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

Page 95

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Milk -- (nCi/liter)

IJAF ENVJ REFERENCE I DATE IDNO. MEDIUM ANALYSIS I JAF RESULT (1) LAB* (2) RATO(3) 6/17/2004 I E-4165-05 MILK 161.

• 6.1 pC/liter 157.

• 11.1 153.

• 7.6 Ce-141 155.

• 10.9 141. +/- 6.4 166.

• 8.2 Mean = 165.A + 35 157.0

• 5.2 0.99 A 274. +/- 30.6 143. +/- 47.8 239. +/- 31.3 Cr-51 228. +/- 44.0 225. + 28.6 195.

• 37.9 Mean = 217. +/- 15.3 228.0 +/- 7.6 0.95 A 96.6 i 4.6 96.6 +/- 7.6 92.5 +/- 4.2 Cs-134 97.9 +/- 7.2 104.

• 4.6 93.6 +/- 5.8 Mean = 96.9 i 2.4 101.0 +/- 3.4 0.96 A 147.

• 5.5 134. +/- 8.8 147. +/- 5.5 Cs-137 141. +/- 8.3 151. + 5.4 139. +/- 6.4 Mean= 143. + 2.R 156.0 +/- 5.2 0.92 A 68.9 +/- 4.2 64.4 +/- 7.4 65.9 + 4.6 Mn-54 62.4 +/- 6.3 71.7 +/- 4.2 76.9 +/- 5.2 Mean = 68.4 + 2.2 70.5 +/- 2.4 0.97 A 37.5 +/- 5.1 45.3 +/- 9.1 53.6 +/- 6.3 Fe-59 50.3 +/- 7.9 60.3 +/- 5.4 51.8 i 5.8 Mean= 49.8 +/- 2.8 44.5 +/- 1.5 1.12 A 113. +/- 8.9 76.5

• 14.0 95.4 +/- 9.4 Zn-65 88.2 +/- 13.5 90.6 8.5 3

99.2 +/- 10.3 Mean = 93.8 4.5 99.3 +/- 3.3 0.94 A 172.

• 4.7 172. +/- 7.7 180. +/- 4.9 Co-60 160. +/- 7.1 175. + 4.7 175.

• 5.3

_______________ .I1Mean = 172. +/- 2.4 172.0 +/- 5.7 1.00 A Page 96

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Milk -- (pCiAiter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 6/17/2004 E-4165-05 MILK 45.2 +/- 3.8 pCi/liter 38.4

• 6.3 40.7 +/- 3.7 Co-58 45.3 +/- 5.9 40.9 +/- 3.7 49.8 +/- 4.6

_Mean= 43.4 + 1.9 46.2 +/- 1.5 0.94 A (1) Results reported as activity +/-1 sigma. (-) Sample provided by Analytics, Inc.

(2) Results reported as activity +/-2 sigma. (A) Evaluation Results, Acceptable.

(3) Ratio = Reported/Analytics (See Section F.3).

Page 97

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Soil -- (pCi/aram)

JAF ENV I I REFERENCE LAB*

DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) (2) RATIO (3) 6/17/2004 E-4166- I SOIL 0.378

• 0.034 05 pCVgram 0.493 +/- 0.025 0.503 +/- 0.043 Ce-141 0.467

• 0.022 0.414 +/- 0.032 Mean = 0.451

• 0.015 0.413

• 0.014 1.09 A 0.502 +/- 0.162 0.617 +/- 0.110 Cr-51 0.825 +/- 0.110 0.932 +/- 0.183 Mean = 0.719 +/- 0.054 0.601 +/- 0.020 1.20 A 0.302 +/- 0.028 0.244 +/- 0.032 Cs-134 0.370 +/- 0.033 0.286 +/- 0.016 0.279 +/- 0.262 Mean= 0.296 +/- 0.012 0.267 +/- 0.009 1.11 A 0.568 +/- 0.034 0.525 +/- 0.022 0.480 +/- 0.041 Cs-i37 0.534 +/- 0.020 0.518 +/- 0.032 Mean= 0.525 +/- 0.012 0.516 +/- 0.017 1.02 A 0.227 +/- 0.025 0.215 +/- 0.016 Mn-54 0.178 +/- 0.032 0.203 +/- 0.015 0.183 +/- 0.024 Mean= 0.201 +/- 0.011 0.186 +/- 0.006 1.08 A 0.149 +/- 0.049 0.129 +/- 0.031 Fe-59 0.120 +/- 0.026 0.101 +/- 0.037 Mean= 0.126 +/- 0.013 0.117 +/- 0.004 1.08 A 0.342 +/- 0.044 0.292 +/- 0.029 0.338 +/- 0.062 Zn-65 0.348 +/- 0.029 1.27 D 0.352 +/- 0.046 NC #2004-Mean= 0.334 +/- 0.019 0.262 +/- 0.009 01 0.539 +/- 0.026 0.461 +/- 0.017 0.466 +/- 0.031 Co-60 0.476 +/- 0.016 0.500 +/- 0.025 Mean = 0.488 +/- 0.011 0.453 +/- 0.015 11.08 A Page 98

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Soil -- (yCi/pram)

JAF ENV REFERENCE LAB*

DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) (2) RATIO (3) 6/17/2004 E-4166- SOIL 0.127

• 0.022 05 pClgram 0.140

• 0.016 Co580.112 +/-0.028 0o-58 0.112 0.014 0.079 +/- 0.022 Mean= 0.114 +/- 0.009 0.122 +/- 0.004 0.93 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity *2 sigma.

(3) Ratio = Reported/Analytics (See Section F.3).

(') Sample provided by Analytics, Inc.

(A) Evaluation Results, Acceptable.

(D) Evaluation Results, Not Acceptable (NC) Non Conformity number Page 99

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Vegetation -- (oCi/qram)

JAF ENV REFERENCE I RATIO DATE ID NO. MEDIUM ANALYSIS I JAF RESULT (1) LAB* (2) (3) 6/17/2004 I E-4168-05 VEGETATION 0.371 +/- 0.010 pCi/gram 0.370 +/- 0.022 Ce-141 0.346 +/- 0.025 0.330 +/- 0.020 Mean = 0.354

• 0.010 0.365 +/- 0.012 I 0.97 A 0.478 +/- 0.054 0.511 +/- 0.011 Cr-51 0.670 +/- 0.013 0.617 +/- 0.010 Mean = 0.569 +/- 0.051 0.351 +/- 0.018 1.07 A 0.234 +/- 0.007 0.256 +/- 0.020 Cs-1 34 0.278 +/- 0.025 0.238

• 0.019 Mean = 0.252 +/- 0.010 0.235 +/- 0.008 1.07 A 0.353 +/- 0.008 0.381 +/- 0.022 Cs-137 0.340 +/- 0.025 0.388 +/- 0.021 Mean = 0.366 +/- 0.010 0.363 +/- 0.012 1.01 A 0.179 +/- 0.006 0.200 +/- 0.018 Mn-54 0.154 +/- 0.023 0.170 +/- 0.017 Mean= 0.176 +/- 0.009 0.164 +/- 0.005 1.07 A 0.085 +/- 0.010 0.108 +/- 0.025 Fe-59 0.140 +/- 0.028 0.107 +/- 0.022 Mean= 0.110 +/- 0.011 0.104 +/- 0.003 1.06 A 0.251 +/- 0.014 0.300 +/- 0.039 Zn-65 0.240 +/- 0.047 0.249

• 0.031 Mean= 0.260 +/- 0.017 0.232 +/- 0.008 1.12 A 0.405 +/- 0.007 0.390 +/- 0.019 Co-60 0.409 +/- 0.025 0.412 +/- 0.019 Mean = 0.404 +/- 0.010 0.4 +/- 0.013 1.01 A 0.106 +/- 0.006 0.114 +/- 0.016 Co-58 0.121 +/- 0.022 0.101 +/- 0.016 Mean = 0.111 +/- 0.008 0.108 +/- 0.004 11.03 A (1) Results reported as activity +/-1 sigma. (*) Sample provided by Analytics, Inc.

(2) Results reported as activity +/-2 sigma. (A) Evaluation Results, Acceptable.

(3) Ratio = Reported/Analytics (See Section F.3).

Page 100

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Water -- (BaAiter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB' (2) RATIO (3) 311/2004 QAP-0403 WATER 52.5

• 2.9 Bq/Iiter 47.4 +/- 2.7 Cs- 137 50.0

• 2.8 52.2 +/- 3.4 50.7 +/-2.6 Mean t50.5 1.3 52.0 +/- 2.7 0.972 A 156.1 +/-3.7 161.3 +/-3.9 C-0159.5 +/-3.8 Co-60159.5 +/-4.7 159.5 +/-3.7

____ _____Mean = 159.2 +/-1.8 163.2 +/-5.9 0.975 A (1) Results reported as activilty +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = ReportedfEML(See Section F.3).

(-) Sample provided by Environmental Measurements Lab., Dept. of Energy.

(A) Evaluation Results, Acceptable.

Page 101

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gamma Analysis Air Particulate Filters -- (Ba/filter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB' (2) RATIO (3) 311/2004 QAP-0403 FILTER 35.0

• 0.5 Bq/filter 36

• 0.4 Co-60 3. .

35.6

• 0.4 Mean = 35.6 +/- 0.3 35.4 +/- 0.85 1.006 A 19.4 +/- 0.4 Cs-1 34 20.8 +/- 0.4 20.2 +/-0.4 Mean = 20.1 +/- 0.2 18.2 +/- 0.40 1.104 W 27.9 +/-0.5 Cs11728.0 +/-0.5 Ci3727.8 +/-0.4

_ _ _Mean = 27.9 0.3 26.4 +/- 0.86 1.057 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity *2 sigma.

(3) Ratio = Reported/EML (See Section F.3).

(*) Sample provided by Environmental Measurements Lab., Dept. of Energy.

(A) Evaluation Results, Acceptable.

(W) Acceptable with Warning.

Page 102

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gross Beta Analysis of Water -- (Ba/Iiter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB' (2) RATIO (3) 3/1/2004 QAP-0403 WATER GROSS 1109 +/- 30 Bq/liter BETA 1115 +/- 30 1090 +/- 30 Mean= 1105 +/- 17 1170

• 117 0.944 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = Reported/EML (See Section F.3).

(*) Sample provided by Environmental Measurements Lab., Dept. of Energy.

(A) Evaluation Results, Acceptable.

Page 103

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Tritium Analasis of Water -- (Ba/liter)

JAF ENV REFERENCE DATE ID NO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 3/11/2004 QAP-0403 WATER H-3 233.4

• 7.8 Bqlliter 2249

• 7.8 238.3 8.0 232.0 +/-7.9 235.3 +/- 8.0 Mean = 232.8 +/- 3.5 186.6 +/- 3.3 1.25 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = ReportedfEML (See Section F.3).

(-) Sample provided by Environmental Measurements Lab., Dept. of Energy.

(A) Evaluation Results, Acceptable.

Page 104

TABLE E.4-1 (Continued)

INTERLABORATORY INTERCOMPARISON PROGRAM Gross Beta Analysis of Air -- (Ba/filter)

JAF ENV REFERENCE DATE IDNO. MEDIUM ANALYSIS JAF RESULT (1) LAB* (2) RATIO (3) 3/11/2004 OAP-0403 AIR GROSS 2.8 +/- 0.08 Bq/filter BETA 2.6 +/- 0.08 2.7 +/- 0.08 2.6 +/- 0.08 2.6 +/- 0.08 2.7 +/- 0.08 Mean = 2.7 +/- 0.05 2.85 +/- 0.28 0.94 A (1) Results reported as activity +/-1 sigma.

(2) Results reported as activity +/-2 sigma.

(3) Ratio = ReportedfEML (See Section F.3).

(*) Sample provided by Environmental Measurements Lab., Dept. of Energy.

(A) Evaluation Results, Acceptable.

Page 105

F.5 References F.5.1 Semi-Annual Report of the Department of Energy, Office of Environmental Management, Quality Assessment Program, EML 621, June 2004.

F.5.2 Radioactivity and Radiochemistry, The Counting Room: Soecial Edition, 1994 Caretaker Publications, Atlanta, Georgia.

F.5.3 Data Reduction and Error Analysis for the Phvsical Sciences, Bevington P.R., McGraw Hill, New York (1969).3 Page 106