Text

EM Environmental Manual
	ML061290240
Person / Time
Site:	Point Beach
Issue date:	09/28/2005
From:	; Nuclear Management Co
To:	; Office of Nuclear Reactor Regulation
References
	FOIA/PA-2010-0209
	Download: ML061290240 (36)
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EM ENVIRONMENTAL MANUAL DOCUMENT TYPE: Controlled Reference REVISION: 18.

EFFECTIVE DATE: September 28, 2005 APPROVAL AUTHORITY: Plant Manager PROCEDURE OWNER (title): Group Head OWNER GROUP: Chemistry

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE 1.0 RADIOLOGICAL ENVIRONMENTAL MONiTORING PROGRAM ADMINISTRATION .9 1.1 Definition and Basis .9 1.1.1 Definition .9 1.1.2 Basis .9 1.2 Responsibilities for Program Implementation .. 12 1.2.1 Chemistry Functions .......................... 12

a. Program scope.................................................................................... 12

b. Record keeping................................................................................... 13

c. Data monitoring.................................................................................. 14

d. Data summary .................. 15

e. Contractor communications ................... 15

f. Reportable items................................................................................. 16 1.2.2 Non-Chemistry Functions .......................... 20

a. Manual control and distribution .......................... 20

b. Program coordination......................................................................... 21 1.3 Quality Assurance/Quality Control ........................ 23 1.4 Program Revisions ........................ 25 Page 2 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING ........................................ 25 2.1 Program Overview ........................................ 25 2.1 Pu p s .................................................................................................... .. 25 2.1.1 Purpose ............. 25 2.1.2 Samples ......................... 26 2.1.3 Monitoring sensitivity ......................... 26 2.2 Program Parameters ......................... 28 2.2.1 Contamination avoidance .28 2.2.2 Sample size .30 2.2.3 Lower limit of detection .31 2.2.4 Notification levels .34 2.2.5 Sampling locations .. 37 2.2.6 Sampling media and frequency .38 2.2.7 Sample labeling .40 2.2.8 Sample shipping .41 2.2.9 Sample analyses and frequency .43 2.2.10 Analytical laboratory .43 2.3 Assistance to the State of Wisconsin .44 2.4 Specification of Sampling Procedures .46 2.4.1 Vegetation.......................... 46 2.4.2 Thermoluminescent dosimeters (TLDs) .47 2.4.3 Lake water . 49 2.4.4 Well water .50 2.4.5 Air ............................................................ 0................

2.4.6 Milk .61 2.4.7 Algae .64 2.4.8 F......

ish. 66 2.4.9. Soil .67 2.4.10 Shoreline Sediment . 70 2.5 Milk Survey ............................................................................................................ 71 Page 3 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE TABLE 2-1 RECOMMIENDED MINIMUM SAMPLE SiES .72 TABLE 2-2 SAMPLE TYPES AND ASSOCIATED LOWER LEVEL OF DETECTION (LLD) AND NOTIFICATION LEVEL VALUES .73 TABLE 2-3 RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ..................... 78 TABLE 2-4 PBNP RADIOLOGICAL ENVIRONMENTAL SAMPLE COLLECTION AND ANALYSIS FREQUENCY .82 TABLE 2-5 SAMPLES COLLECTED FOR STATE OF WISCONSIN ...................................... 85 FIGURE 2-la RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ..................... 86 FIGURE 2-lb RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ..................... 88 FIGURE 2-1c RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ..................... 91 IPage 4 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 1.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ADMINISTRATION 1.1 Definition and Basis

-1.1.1 Definition Radiological environmental monitoring is the measurement of radioactivity in samples collected from the atmospheric, aquatic and terrestrial environment around the Point Beach Nuclear Plant (PBNP). Monitoring radioactivity in effluent streams at or prior to the point of discharge to the environment is not part of the Radiological Environmental Monitoring Program (REMP).

1.1.2 Basis The REMP is designed to fulfill the requirements of 10 CFR 20.1302, PBNP GDC 17, GDC 64 of Appendix A to 10 CFR 50, and Sections IV.B.2 and IV.B.3 of Appendix I to 10 CFR 50.

No significant radionuclide concentrations of plant origin are expected in the plant environs because radioactivity in plant effluent is continuously monitored to ensure that releases are well below levels which are considered safe upper limits. The REIVIP is conducted to demonstrate compliance with applicable standards, to assess the radiological environmental impact of PBNP operations, and to monitor the efficacy of inplant effluent controls. The REMP, as outlined in Tables 2-2 through 2-4 is designed to provide sufficient sample types and locations to detect and to evaluate changes in environmental radioactivity.

Radioactivity is released in liquid and gaseous effluents. Air samplers and thermoluminescent dosimeters'placed at various locations provide means of detecting changes in environmental radioactivity as a result of plant releases to the atmosphere. 'Because the land area around PBNP is used primarily for farming and dairy operations, sampling of vegetation is conducted to detect changes in radiological conditions at the base of the food chain. Sampling of area-produced milk is conducted because dairy farming is a major industry in the area.

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ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL Water, periphyton, and fish are analyzed to monitor radionuclide levels in Lake Michigan in the vicinity of PBNP. Periphyton, attached algae, along with lake water samples, provide a means of detecting changes which may have a potential impact on the radionuclide concentrations in Lake Michigan fish. Because of the migratory behavior of fish, fish sampling is of minimal value for determining radiological impact specifically related to the operation of the Point Beach Nuclear Plant. However, fish sampling is carried out as a conservative measure with emphasis on species which are of intermediate trophic level and which exhibit minimal migration in order to monitor the status of radioactivity in fish.

Vegetation, algae, and fish sampling frequencies are qualified on an "as available" basis recognizing that certain biological samples may occasionally be unavailable due to environmental conditions.

1.2 Responsibilities for Program Implementation 1.2.1 Chemistry Functions Chemistry together with Regulatory Affairs (RA) provides the Plant Manager with the technical, regulatory, licensing, and administrative support necessary for the implementation of the program. The Chemistry administrative functions relating to the REMP fall into the six broad areas outlined below.

a. Program scope The scope of the REMP is determined by the cognizant Chemist based on sound radiological principles for the fulfillment of PBNP Technical Specifications (IS) and the applicable Federal Regulations. Based on the scope, the Environmental Manual (EM) is written to accomplish the collection and analyses of the necessary environmental samples. The EM is revised as necessary to conform to changes in procedures and scope.

Chemistry monitors the REMP effectiveness and compliance with TS and with the procedures and directives in the EM. In order to verify compliance with TS, Nuclear Oversight arranges for program audits and NMC Supplier Assessments of the contracted radioanalytical laboratory.

b. Record keeping The monthly radioanalytical results from the contracted laboratory are reviewed by Chemistry and one copy of the monthly radioanalytical results from the contracted laboratory is kept for the lifetime of the plant.

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c. Data monitoring Ii Chemistry reviews and interprets all program analytical results on a monthly basis as they are reported. Trends, if any, are noted. Any resulting corrections, modifications and additions to the data are made by Chemistry. Inconsistencies are investigated by Chemistry with the cooperation of Radiation Protection (RP) and contractor personnel, as I required. Unusual results as evidenced by radioactivity levels exceeding administrative notification levels are also investigated. Results of the investigation will be conveyed to the Plant Manager. Chemistry will promptly inform the Plant Manager of any sample exceeding Nuclear Regulatory Commission (NRC) regulatory notification levels and will initiate an investigation. A formal report shall be provided to the Plant Manager upon completion of the investigation.

d. Data summary I REMP results shall be summarized annually for inclusion in the PBNP Annual Monitoring Report. This summary advises the Plant Manager of the radiological status of the environment in the vicinity of PBNP. The summary shall include the numbers and types of samples as well as the averages, statistical confidence limits and the ranges of analytical results.

I Methods used in summarizing data are at the discretion of Chemistry.

e. Contractor communications Communication with the contractor regarding data, analytical procedures, lower limits of detection, notification levels and contractual matters are normally conducted by Chemistry. Communication regarding sample I shipment may be done by either RP or Chemistry as appropriate.

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f. Reportable items l1. Chemistry shall generate all technically-specified reports related to the operation of the REMP. The material included shall be sufficient to fulfill the objectives outlined in Sections IV.B.2 and IV.B.3 of Appendix I to 10 CFR 50. The following items and occurrences, are required to be reported in the PBNP Annual Monitoring Report:

(a) Summary and discussion of monitoring results including number and type of samples and measurements, and all detected radionuclides, except for naturally occurring radionuclides; (b) Unavailable, missing, and lost samples and plans to prevent recurrence and comments on any significant portion of the REMP not conducted as indicated in Tables 2-3 through 2-4.

(c) New or relocated sampling locations and reason for change; (d) L.LDs that are higher than specified in Table 2-2 and factors contributing to inability to achieve specified LLDs; (e) Notification that the analytical laboratory does not participate in an interlaboratory comparison program and corrective action taken to preclude a recurrence; and (f) Results of the annual milk sampling program land use census "milk survey" to visually verify that the location of grazing animals in the vicinity of the PBNP site boundary so as to ensure that the milk sampling program remains as conservative as practicable.

2. The following items are required to be reported to the NRC within 30 days of occurrence pursuant to the criteria of Section 2.2.4:

(a) Confirmed environmental radionuclide concentrations, attributable to PBNP effluents, in excess of notification levels; (b) Confirmed results of weighted sum calculations involving radionuclide concentrations, attributable to PBNP effluents, in environmental samples in excess of the specified notification level; and Page 8 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL (c) The report shall, to the extent possible, identify the cause(s) for exceeding the limit(s) and define the corrective actions taken to reduce radioactivity in effluents so that the potential dose to a member of the public will not exceed the annual limits.

3. The annual results from the contracted REMP analytical laboratory as well as the laboratories analytical QA/QC results, in-house blanks, interlaboratory comparisons, etc., shall be transmitted to the NRC, Region HI, with, or as a'separate concurrent submittal, the Annual Monitoring Report.

4. The Annual Monitoring Report for the previous 12 month period, or fraction thereof, ending December 31, shall be submitted to the NRC by April 30 of the following year.

1.2.2 Non-Chemistry Functions The primary responsibility for the implementation of the PBNP REMP and for any actions to be taken at PBNP, based on the results of the program, resides with the Plant Manager.

a. Manual control and distribution The distribution of the PBNP Environmental Manual is the responsibility of Document Control.

b. Program coordination The daily operation of the program is conducted by PBNP Radiation Protection personnel, and other qualified personnel as required, under the supervision of an RP staff member who consults, as needed, with Chemistry. The daily administrative functions of the RP Management Employee address those functions required for the effective operation of the PBNP Radiological Environmental Monitoring Program. These administrative functions include the following:

1. Ensuring that samples are obtained in accordance with the type and frequency in Table 2-4 following procedures outlined in this manual;

2. Ensuring adequate sampling supplies and calibrated, operable equipment are available at all times;

3. Ensuring that air sampling pumps are maintained, repaired and calibrated as required and that an adequate number of backup pumps are readily available at all times; Page 9 of 36 INFORMATION USE

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ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL

4. Reporting lost or unavailable samples as well as other potential deviations from the sampling regime in Table 2-4 via the Corrective Action Program and notifying the cognizant Chemist.

5. Assisting the State of Wisconsin in obtaining samples at co-located and other sampling sites based upon a yearly, renewable agreement; and

6. Assisting Chemistry, as necessary, with investigations into elevated radioactivity levels in environmental samples.

1.3 Ouality Assurance/Quality Control Quality assurance considerations are an integral part of PBNP's Radiological Environmental Monitoring Program. The program involves the interaction of Chemistry, site quality assurance and the contracted analytical vendor. The contracted vendor shall participate in an interlaboratory comparison program. The laboratory is audited periodically, either by NMC or by an independent third party.

Quality control for the PBNP portion of the Radiological Environmental Monitoring Program is achieved by following the procedures contained in this manual. Health Physics Technologists (HPTs) collect, package and ship environmental samples under the supervision of Radiation Protection supervisors. They are advised by Radiation Protection Management who has immediate responsibility for the overall technical operation of the environmental sampling functions. The HPTs receive classroom training as well as on-the-job training in carrying out these procedures.

An audit of the PBNP Radiological Environmental Monitoring Program and its results shall be completed periodically as a means of monitoring program effectiveness and assuring compliance with program directives. The audit shall be performed in accordance with Section 1.4 of the ODCM.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 1.4 Program Revisions This manual describes the current scope of the PBNP Radiological Environmental Monitoring Program. Program items or procedures periodically may be updated or changed, consistent with good radiologically monitoring practices, either to reflect new conditions or to improve program effectiveness. Technical and program features described in this manual may be changed with the approval of the PORC and Plant Manager pursuant to the requirements stated in the ODCM.

2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING 2.1 Pro-gram Overview 2.1.1 Purpose No significant or unexpected radionuclide concentrations of plant origin are expected because each normal effluent pathway at PBNP is monitored at or before the release point. However, the REMP is conducted to verify that plant operations produce no significant radiological impact on the environment and to demonstrate compliance with applicable standards.

2.1.2 Samples Samples for the REMP are obtained from the aquatic, terrestrial and atmospheric environment. The sample types represent key indicators or critical pathways identified by applying sound radiological principles to the PBNP environment.

2.1.3 Monitoring sensitivity The effectiveness of the REMP in fulfilling its purpose depends upon the ability to accurately determine the nature and origins of fluctuations in low levels of environmental radioactivity. This requires a high degree of sensitivity so that it is possible to correctly discriminate between fluctuations in background radiation levels and levels of radioactivity that may be attributable to the operation of PBNP. Therefore, personnel actively participating in the monitoring program should make every effort to minimize the possibility of contaminating environmental samples and to obtain samples of the appropriate size.

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2.2 Program Parameters 2.2.1 Contamination avoidance Contamination prevents the accurate quantification of environmental radioactivity and the correct differentiation between fluctuating background radioactivity and levels of radioactivity attributable to the operation of PBNP.

Therefore, it is necessary that all personnel associated with collecting and handling radiological environmental samples take the appropriate precautions to minimize the possibility of contaminating the samples. Some of the precautions that should be taken and which will help to minimize contamination are listed below:

a. Equipment which has been on the controlled side, even if released clean, should not normally be used in conjunction with radiological environmental monitoring. An exception to this is the HPTI equipment used to calibrate the air flow calibrator.

b. Store sampling equipment in radiologically clean areas only;

c. Store radiological environmental samples only in radiologically clean areas when samples cannot be shipped to the contractor on the same day they are collected;

d. Treat each sample as a possible source of contamination for other samples so as to minimize the possibility of cross-contamination;

e. Radiological environmental monitoring equipment should be repaired in clean-side shops;

f. Contamination avoidance for environmental TLDs is covered in Section 2.4.2; and

g. Avoid entering contaminated areas prior to collecting environmental samples.

2.2.2 Sample size Sample size affects the sensitivity achievable in quantifying low levels of environmental radioactivity. Therefore, sampling personnel must attempt to attain the quantities of sample specified in Table 2-1. When a range is given, every effort should be made to obtain a quantity at the upper part of the range.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.2.3 Lower limit of detection The sensitivity required for a specific analysis of an environmental sample is defined in terms of the lower limit of detection (LLD). The LLD is the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with a 95% probability and have only a 5% probability of falsely concluding that a blank observation represents a real signal. Mathematically, the LUD is defined by the formula

=.

LLDn 4.66 sb E x V x 2.22 x Y x EXP(-XAT)

Where LLD = the a priori lower limit of detection in picocuries per unit volume or mass, as applicable; Sb = the standard deviation of the background counting rate or the counting rate of a blank sample, as appropriate, in counts per minutes; E = counting efficiency in counts per disintegration; V = sample size in units of volume or mass, as applicable; 2.22 = number of disintegrations per minute per picocurie; Y = the fractional chemical yield as applicable; X = the radioactive decay constant for the particular radionuclide; and AT = the elapsed time between sample collection, or the end of the collection period, and the time of counting.

Typical values of E, V, Y, and AT are used to calculate the LU). As defined, the LLD is an a priori limit representing the capability of a measuring system and not an a posteriori limit for a particular measurement.

The required analysis for each environmental sample and the highest acceptable LU) associated with each analysis are listed in Table 2-2.

Whenever LID)values lower than those specified in Table 2-2 are reasonably achievable, the analytical contractor for the radiological environmental samples will do so. When the LLDs listed in Table 2-2 are not achieved, a description of the factors contributing to the higher LILD shall be reported in the next PBNP Annual Monitoring Report.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.2.4 Notification levels The Notification Level (NL) is that measured quantity of radioactivity in an environmental sample which, when exceeded, requires a notification of such an occurrence be made to the appropriate party. Regulatory and administrative notification levels are listed in Table 2-2.

a. Regulatory notification levels The regulatory notification levels listed in Table 2-2 represent the concentration levels at which NRC notification is required. If a measured level of radioactivity in any radiological environmental monitoring program sample exceeds the regulatory notification level listed in Table 2-2, resampling and/or reanalysis for confirmation shall be completed within 30 days of the determination of the anomalous result. If the confirmed measured level of radioactivity remains above the notification level, a written report shall be submitted to the NRC. If more than one of the radionuclides listed in Table 2-2 are detected in any environmental medium, a weighted sum calculation shall be performed if the measured concentration of a detected radionuclide is greater than 25%

of the notification levels. For those radionuclides with LLDs in excess of 25% of the notification level, a weighted sum calculation needs to be performed only if the reported value exceeds the LTLD. Radionuclide concentration levels, called Weighted Sum Action Levels, which trigger a weighted sum calculation are listed in Table 2-2.

The weighted sum is calculated as follows:

concentration (1) concentration (2) notification level (1) notification level (2)

If the calculated weighted sum is equal to or greater than 1, resampling and/or reanalysis for confirmation shall be completed within 30 days of the determination of the anomalous result. If the confirmed calculated weighted sum remains equal to or greater than 1, a written report shall be submitted to the NRC. This calculation requirement and report is not required if the measured level of radioactivity was not the result of plant effluents.

b. Administrative notification levels The administrative notification levels are the concentration levels at which the contracted analytical laboratory promptly notifies the cognizant Chemistry Specialist by phone, followed by a formal written communication. The administrative notification levels are set lower than the NRC regulatory notification levels and lower than, or equal to, the weighted sum action levels so that the nature and origin of the increased level of environmental radioactivity may be expeditiously ascertained and corrective actions taken if required.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.2.5 Sampling locations A list of sampling locations and the corresponding location codes appear in Table 2-3. The locations also are shown in Figures 2-la, 2-lb, and 2-ic. It is conceivable that samples may become unavailable from specified sample locations. If this were to occur, new locations for obtaining replacement samples shall be identified and added to the Radiological Environmental Monitoring Program. If milk or vegetation samples become unavailable from the specified sampling locations, new sampling locations will be identified within 30 days. The specific locations where samples were unavailable may be deleted from the monitoring program. A formal, written reason for the new site and its location shall be transmitted to Chemistry who will make the appropriate changes to the Environmental Manual. Any significant changes in existing sampling location and the criteria for the change shall be reported in the Annual Monitoring Report for the period in which the change occurred.

Additional sampling locations may be designated if deemed necessary by cognizant company personnel. Figures and tables in this manual shall be revised to reflect the changes.

2.2.6 Sampling media and frequency The sampling frequency for the environmental media required by the PBNP REMP is found in Table 2-4. In addition to samples required by the former Technical Specifications, the Radiological Environmental Monitoring Program also includes the sampling of soil and shoreline sediment. To ensure that all samples are obtained at the appropriate times, a checklist is used. The checklist provides a month-by-month indication of all samples, to be obtained at each sampling location (PBF-4121a through 41211). These checklists also identify the schedule for the annual milk survey and provides space for recording the date samples were shipped offsite for analysis. In addition, the checklist lists each sampling location to identify all samples, to be obtained and the collection date. Because the weekly air samples require additional information, a separate checklist is used for each individual air sampling location for calculations and other information as shown in PBF-4078.

It is recognized that on occasions samples will be lost or that samples cannot be collected at the specified frequency because of hazardous conditions, seasonable unavailability, automatic sampling equipment malfunctions and other legitimate reasons. Reasonable efforts will be made to recover lost or missed samples if warranted and appropriate. If samples are not obtained at the indicated frequency or location, the reasons or explanations for deviations from the sampling frequency specified in Table 2-4 shall be submitted to the PBNP Corrective Action Program.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.2.7 Sample labeling All samples must be properly labeled to ensure that the necessary information is conveyed to the analytical contractor and that the results are associated with the correct geographical location. Each label (PBF-4026) must contain the following:

a. Sample type;

b. Sample location from Table 2-3;

c. Date and time (as appropriate) collected;

d. Air samples must show the total volume in in 3 ; volumes for water and milk are in gallons; vegetation, sediment, soil, and algae are indicated as

<1000 grams; and fish 21000 grams;

e. Analyses for routine samples are indicated as "per contract." For special samples, the Radiation Protection manager or another Radiation Protection Management Employee will designate the analyses required; and

f. Name of person collecting the sample.

A permanent or indelible ink type felt-tip marker shall be used.

A separate sample label is needed for each sample type and location.

Labels are securely attached to each sample container. In addition to sample labels, other identifying markings may be placed on sample containers as appropriate.

2.2.8 Sample shipping All environmental samples are shipped to a contractor for analysis. The samples shall be packaged and shipped in such a way as to minimize the possibility of cross-contamination, loss, spoilage and leakage. Each sample shipment shall have a typed cover letter and, when appropriate, a contractor data collection sheet. Included in the letter shall be the same information required for the sample labels as well as the specific analyses required. The original cover letter and data collection sheet shall be sent to the contractor under separate cover; one copy of each is to be used as a packing list and a copy of each shall be kept in the appropriate PBNP file.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.2.9 Sample analyses and frequency The PBNP REMP samples shall be analyzed for designated parameters at the frequency listed in Table 24. Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to effluents from PBNP. Typically, this entails the scanning of the spectrum from 80 to 2048 keV and decay correcting identified radionuclides to the time of collection. The analysis specifically includes, but is not limited to, Mn-54, Fe-59, Zn-65, Co-58, Co-60, Zr-Nb-95, Ru-103, I-131, Cs-134, Cs-137, Ba-La-140, Ce-141, and Ce-144.

2.2.10 Analytical laboratory The analyses shall be performed by a laboratory that participates in an interlaboratory crosscheck program. If the laboratory is not participating in such a program, a report shall be made pursuant to 1.2.1.f.1.(e). The current laboratory is:

Environmental Incorporated Midwest Laboratory 700 Landwehr Road Northbrook, IL 60062-4517 (847) 564-0700 This laboratory performs the analyses in such a manner as to attain the desired LLDs. The contracted laboratory participates in an inter-laboratory comparison crosscheck program.

The contractor is responsible for providing prompt notification to the cognizant Chemist regarding any samples found to exceed the administrative notification levels as identified in Table 2-2.

2.3 Assistance to the State of Wisconsin As a courtesy and convenience, PBNP personnel obtain certain environmental samples for the Section of Radiation Protection, Department of Health and Family Services of the State of Wisconsin as listed in Table 2-5. A checklist is used. In addition, a State of Wisconsin air sampling data sheet is submitted with each sample obtained at Wisconsin air sampling locations serviced by PBNP personnel.

State of Wisconsin precipitation samples collected twice a month (or as available) require a state sample tag to be placed in a box with the quart cubitainer. State supplied labels for air particulate filters require start and stop time, date and beginning and ending volume. Fish sent to the state identify only the quarter and the year using a PBNP label (PBF4026). The monthly lake water sample may be picked up by state personnel and in which case these samples require only that the date and location be written on the box for the cubitainer. The well water samples, 2 times/year, may be picked similar to lake water samples.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL Samples obtained for the State of Wisconsin are either given directly to state personnel or shipped as required. The department address is:

State Lab of Hygiene Radiochemistry Unit 2601 Agriculture Dr.

PO Box 7996 Madison, Wisconsin 53707-7996 2.4 Specification of Sampling Procedures General radiological environmental sampling procedures follow the directives presented in Sections 2.1 and 2.2. Specific information for handling individual sample types follow.

2.4.1 Vegetation Vegetation samples consist of green, growing grasses and weeds and are obtained three times per year, as available, from specified locations. New growth, not dead vegetation, should be used because these samples are indicators of recent atmospheric deposition. Use a scissors or other sharp cutting tool to cut the grasses and weeds off as close to the ground as possible.

Do not include plant roots and take care not to contaminate the sample with soil. Total sample collected should exceed 500 grams and ideally should be 1000 grams. Place entire sample in an appropriate container, such as a plastic bag (tape the bag shut) and label the container as described in Section 2.2.7.

2.4.2 Thermoluminescent dosimeters (TLDs)

TLDs capable of multiple, independent measurements of the same exposure are posted at locations specified in Table 2-4 and are changed quarterly. The utmost care in handling is required to minimize unnecessary exposure during transit, storage and posting because the TLDs begin recording all radiation from the moment they are annealed (heated to rezero) at the contractor's laboratory. Packages of TLDs in transit should be marked "DO NOT X-RAY."

Transportation control (TLDs) shall accompany the new batch in transit from the contractor's laboratory to the plant. The control TLDs shall accompany the batch during brief storage and subsequent posting. The same control TLDs shall accompany the "old" or exposed batch on its way back to the contractor. Therefore, each control represents the sum of approximately half the in-transit exposure of the two batches. This control system is able to identify any unusual in-transit exposure.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL Environmental TLDs should never be brought into the plant RCA or any other area with elevated radiation, but may be stored for brief periods in a shielded enclosure in the RP Office Area or other low background area, such as the Energy Information Center or the Site Boundary Control Center. The contractor is to time shipments to coincide as closely as possible with the beginning of a calendar quarter. TLDs should be shipped back to the contractor immediately or within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of removal. The contractor is instructed to process the samples immediately upon receipt. The contractor shall report removal data and cumulative readings in mR for all locations and control, correct for in-transit exposure and express results in net mR/7 days.

Labels of the exposed set for shipment to contractor should show both posting and removal dates.

2.4.3 Lake water Lake water samples are obtained monthly at specified locations. The contractor is responsible for the compositing for quarterly analyses. Collect approximately 8000 ml of lake water in the required number of cubitainers, or other appropriate containers, at each location and label as directed in Section 2.2.7.

Also, lake water is collected for the State of Wisconsin pursuant to Table 2-5.

The sample is collected, labeled, and forwarded to the appropriate State agency.

2.4.4 Well water Well water samples are obtained quarterly from the single onsite well. Collect approximately 8000 ml of well water using the required number of cubitainers or other appropriate containers. Label as directed in Section 2.2.7.

2.4.5 Air

a. Sample collection Air filters are changed weekly at specified locations and placed in glassine envelopes for shipment to the vendor for analyses. Take precautions to avoid loss of collected material and to avoid contamination when handling filters. Washing hands before leaving the plant to change filters is a recommended practice.

Both particulate filters and charcoal cartridges are employed at each sampling location. Particulate filters are analyzed for gross beta activity after waiting for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to allow for the decay of short-lived radon and thoron daughter products. The contractor makes quarterly composites of the weekly particulate samples for gamma isotopic analyses.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL A regulated pump (Eberline Model RAS-I or equivalent) is used at each air sampling location. Because of the automatic flow regulation, rotameter readings at the beginning and ending of the sampling period should be nearly identical. Substantial differences in readings usually require some investigation to determine the cause. The rotameters attached to the pumps are calibrated in liters per minute. When new filters are installed, flow rate should be about 28-30 1pm. Flow rates less than 26 Ipm or greater than 32 1pm require that the pump regulator be readjusted. The correct flow rate is determined by multiplying the rotameter reading by the correction factor indicated on the calibration sticker affixed to the rotameter.

Some pumps are equipped with an elapsed time meter which reads in hours. Form PBF-4078 is used for recording pertinent air sampling data for each location. At a normal filter change, the following procedure will apply:

1. Record "date off" and "time off."

2. Record rotameter reading for end of period (R 2 ).

3. Turn off pump, if necessary, and record hour meter reading or actual time for end of period (t2 ).

4. Before removing the filter, label the sample envelope as directed in Section 2.2.7. Also enter any other pertinent information at this time. Always write data on the envelope before inserting the particulate filter in the envelope.

5. Remove particulate filter being careful to handle filter only by edges, place in the glassine envelope.

6. Remove charcoal cartridge, place in plastic bag, and label as directed in Section 2.2.7.

7. Install new charcoal cartridge and particulate filter being sure to check the charcoal cartridge for breaks and the particulate filter for holes in the filter surface. Discard unacceptable filter media.

8. Record "date on."

9. Record hour meter reading or time for beginning of period (t1).

10. Turn pump on (if necessary).

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL

11. Perform weekly gross leak test by blocking the air flow with a large rubber stopper. (For this test only, the rotameter ball may register zero or drop all the way to the bottom. The difference between zero and the bottom is not significant.)

12. Record rotameter reading for beginning of period (R1 ).

13. Record correction factor as indicated on calibration sticker affixed to rotameter (C).

14. Observe that the starting rotameter reading (R1 ) is close to the previous ending reading (R2). A substantial difference indicates need for further investigation because the regulator will generally maintain constant flow regardless of filter loading.

15. Calculate total volume for period and enter on data sheet (m3 ). (This step may be performed at a later time.)

16. Any unusual conditions or observations should be referenced under

(*) and recorded under "*NOTES" at the bottom of the data sheet.

Air samples are collected for the State of Wisconsin at two locations, one of which is co-located with a PBNP air sampling site. They are handled in a manner similar to PBNP samples except that no charcoal cartridges are involved. However, state samplers are equipped with volume integrating meters. Therefore, clock time must be recorded in addition to the ending and beginning volumes.

Label and forward samples to the State.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL

b. Air sampling system description The air monitoring equipment for the PBNP air sampling program consists of a Regulated Rate Control System. The Regulated Rate Control System is used at PBNP because of its simplicity and reliability. It is designed to minimize both calibration difficulties and the potential for leaks. The regulated rate control system includes a pump, a flow regulator, the appropriate filter holders and a minimum of tubing. Also, it may include an elapsed time meter. In this system, the total volume sampled can be calculated simply and accurately from the elapsed time and the flow rate which is kept constant by the regulator regardless of filter loading.

The air samplers are Eberline Model RAS-1 (or equivalent) and have built-in rotameters which read in liters per minute. The systems also include an Eberline WPH-1 (or equivalent) weatherproof housing and an iodine cartridge holder and mounting kit and may include an electric hour meter. Glass fiber, 47 mm diameter, particulate filters capable of collecting 95% of 1 micron diameter particles and iodine impregnated charcoal cartridges (Scott or equivalent) constitute the filter media.

c. Calibration Calibrate the pump rotameter at initial installation and at yearly intervals thereafter by connecting a laboratory-quality reference flow meter with NIST traceable calibration to the filter face with the particulate filter and charcoal cartridge in position. Upon completion, a calibration sticker indicating the correction factor is affixed to, or near, the built-in rotameter.

The results are recorded on Form PBF-4020.

d. Inspection and maintenance Weekly gross leak checks shall be accomplished as indicated in the appropriate PBNP procedure.

Page 22 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL For normal operation, the regulators should be adjusted to maintain a true flow rate of 28-30 liters per minute. Adjustments are made by turning the screw marked FLOW ADJUST located on the side of the regulator body:

counterclockwise increases flow, clockwise decreases flow. Flow rates should be observed at all filter changes. Flow rates less than 26 1pm or more than 32 lpm require readjustment of the regulator. Particular attention should be paid to flow rate readings with the "old," loaded filter and with new, unused filters in position. Because of the regulator, the difference in flow should be barely perceptible, perhaps no more than one lpm. Significant differences in flow rates require further investigation to determine the cause.

Preventive maintenance shall be performed as indicated in the appropriate PBNP procedure on all environmental air samplers and the results recorded on Form PBF-4020.

e. Pump repair and replacement The pumps can operate for long periods of time with minimal or no maintenance. The vane assembly of the pump is most susceptible to failure, indicated by excessive noise or inability to maintain sufficient flow across loaded filters. At least one standby pump should be available for temporary service during the repair period. In the event of motor failures due to causes other than defective connections, complete replacement of the unit may be necessary. All pump repairs should be done in a clean-side shop with clean tools.

2.4.6 Milk Because of iodine decay and protein binding of iodine in aging milk samples, speed is imperative in processing and samples must be kept cool to avoid degradation and spoilage of the samples. Milk samples are obtained monthly in conjunction with the State of Wisconsin Milk Sampling Program from three individual dairy farmers located north, south, and west of the site. Milk sampling data can also be obtained from the Kewaunee Nuclear Power Plant, whose radiological environmental monitoring program includes samples taken from a dairy in Green Bay, WI. This location could act as a control location.

Because two of the three sites are co-located, the PBNP pickup is coordinated to coincide with the State arranged schedule. The pickup usually will be the first Wednesday of the month.

The following sequence should be followed:

a. After verifying the State milk pickup date with the Manitowoc Public Health Department (Mr. Mark Chatenka, phone number 683-4454), notify Mr. Leon Strutz (755-2060) of the pickup date. This must be done because the Strutz farm (PBNP sampling location E-21) is not a State of Wisconsin sampling site.

Page 23 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL

b. Because the milk must be kept cool, but not frozen, fill enough cubitainers, or other appropriate containers, with water and freeze to be able to put one in each shipping container. Fill the containers with water and freeze the day preceding the pickup.

c. The milk from the Strutz farm (E-21) must be picked up before 0900 because that is the time the Strutz milk is shipped. A late arrival may mean a missed sample. Milk from sites E-1 1 and E-40 may be picked up any time after the Strutz pickup.

d. Identify yourself and the nature of your business at each milk pickup site.

Collect two one-gallon samples from each site, using a funnel if necessary.

If shipment cannot occur on the collection day, store the milk in a clean-side refrigerator overnight. DO NOT FREEZE.

e. Complete a PBNP sample tag according to Section 2.2.7 for each gallon sample and place in the box with the sample. Do not seal the box. Place the samples in insulated containers and turn them over to Ready Stores personnel for shipment. Make sure that the cover letter and, as appropriate, the contractor data collection sheets are sent according to Section 2.2.8 of this manual.

2.4.7 Algae Filamentous algae are collected from pilings or rocks three times per year, as available, from two locations. The long, grassy, dark green algae can normally be cut with scissors. The shorter, light green algae normally must be scraped from rocks or pilings. When scraping algae, be careful not to include pieces of rock in the sample. The sample can be lightly rinsed in the same medium in which it is growing. This rinse will help rid the sample of pieces of rock and gravel that may have been inadvertently collected with the sample. Because rocks and sediment contain naturally occurring radioactive materials, their inclusion may give false sample results. Collect between 100 and 1000 gm of algae. A sample greater than 500 gm is preferred. Place the algae in a wide-mouth poly bottle or other appropriate container and label the container as director in Section 2.2.7. The algae must be kept cool to prevent spoilage.

, Page 24 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL 2.4.8 Fish Fish are obtained three times per year (March, August and December) as available either from the traveling screens as washed into the fish basket or by other methods as required. For any given sampling period, three fish, or a sufficient number to yield at least 1000 gin of fillets, should be provided.

Place fish in plastic bags and tape and/or tie tightly closed. Fish are stored briefly in a radiologically clean freezer. It may be desirable in warm weather to coordinate milk and fish sampling, thereby allowing simultaneous shipment in insulated containers. Pack fish samples with ice if needed. Label bags as directed in Section 2.2.7, being sure to indicate fish species when possible.

Following packaging of fish, remove and discard any fish left in the freezer.

This avoids sending fish that are not representative of the sampling period.

Fish are obtained four times per year (March, June, September and December) for the State of Wisconsin. Fish sampling for the State is performed in the same manner as that for the plant. Approximately four fish should be sent to the state at each sampling period.

2.4.9 Soil Soil integrates atmospheric deposition and acts as a reservoir for long-lived radionuclides. Although soil sampling is a poor technique for assessing small incremental releases and for monitoring routine releases, it does provide a means of monitoring long-term trends in atmospheric deposition in the vicinity of PBNP. Therefore, soil samples are obtained two times per year from specified locations.

Clear the vegetation from a 6" x 6" area, being careful to leave the top layer of soil relatively intact. Remove root bound soil by shaking the soil onto the cleared area or into the sample container before discarding the roots. When necessary, it is preferable to leave some roots in the soil rather than to lose the top layer of soil.

Remove the soil to a depth of three inches. If necessary, expand the area, instead of digging deeper, to obtain the required amount of sample. If an area larger than 6" x 6" is used, notify Chemistry of the area used. The minimum acceptable quantity is 500 grams. Place the entire soil sample in a wide-mouth poly bottle or another appropriate container. If a plastic bag is used, seal the bag with tape. Label the sample as directed in Section 2.2.7.

Page 25 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL This procedure assumes that the samples are obtained from undisturbed land; land that has not been plowed within approximately the last 25 years. If the land has been plowed, the soil should be sampled to the plow depth which typically is eight inches. Place the soil in a clean bucket or appropriate size plastic bag, homogenize the soil and place 1000 grams of the well mixed soil sample in a plastic bag, or other appropriate container, and label as described above.

2.4.10 Shoreline Sediment Shoreline sediment consisting of sand and smaller grain size material is sampled two times per year from specified locations. The 1000 gram sample is collected, from beach areas near the water ridge. At each location collect representative samples of sediment types roughly in proportion to their occurrence. For example, at E-06 avoid collecting a sample which consists exclusively of the dark-brown to black sediments which occur in layers up to several inches thick. Package the sample in a wide-mouth poly bottle or other appropriate container and label as described in Section 2.2.7.

2.5 Milk Survey The milk sampling program is reviewed annually, including a visual verification of animal grazing in the vicinity of the site boundary, to ensure that sampling locations remain as conservative as practicable. The verification is conducted each summer by cognizant PBNP personnel. Because it is already assumed that milk animals may graze up to the site boundary, it is only necessary to verify that these animals have not moved onto the site. No animal census is required. Upon completion of the visual check, RP personnel will notify Chemistry in writing. To ensure performance of the annual verification, "milk review" is identified on the sampling checklist (i.e., the PBF-4121a-l series).

Page 26 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005

- ENVIRONMENTAL MANUAL TABLE 2-1 RECOMMENDED MINIMUM SAMPLE SIEZES Sample Type Size Vegetation 100-1000 gin Lake Water 8 liters (2 gal)

Air Filters 250 I3 Well Water 8 liters (2 gal)

Milk 8 liters (2 gal)

Algae 100-1000 gm Fish (edible portions) 1000 gm Soil 500-1000 gm Shoreline Sediment 500-1000 gm PageI'27 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 MN VKUNAIAN I AL MYAN UAL TABLE 2-2 SAMPLE TYPES AND ASSOCIATED LOWER LEVEL OF DETECTION (LLD) AND NOTIFICATION LEVEL VALUES NOTIFICATION LEVELS WEIGHTED l SAMPLE REPORTING NRC PBNP@) SUM TYPE UNIT PARAMETER LLD(a) (Regulatory) (Admin.) ACTION LEVEL Vegetation pCi/g wet Gross Beta 0.25 60 Cs-137 0.08 2 0.40 0.50 Cs-134 0.06 1 0.20 0.25 1-131 0.06 0.1 0.06 0.06 Other(c) 0.25 2.0 Shoreline pCi/g dry Gross Beta 2.0 100 Sediment and Cs-137 0.15 20 Soil Other(c) 0.15 20 Algae pCi/g wet Gross Beta 0.25 12 Cs-137 0.25 10 1 2.5 Cs-134 0.25 10 1 2.5 Co-58 0.25 10 1 2.5 Co-60 0.25 10 1 2.5 Other(c) 0.25 1 Fish pCi/g wet Gross Beta 0.5 125 Cs-137 0.15 2 0.40 0.50 Cs-134 0.13 1 0.20 0.25 Co-58 0.13 30 3 7.5 Co-60 0.13 10 1 2.5 Mn-54 0.13 30 3 7.5 Fe-59 0.26 10 1 2.5 Zn-65 0.26 20 2 5.0 Other(c) 0.5 6 TLDs mR/7 days Gamma Exposure lmRfrLD SmRf7 days Lakewater(e) pCi/LT.S.(d) Gross Beta 4 100 and Well Water Cs-134 15 30 15 15 Cs-137 18 50 18 18 Fe-59 30 400 40 100 Zn-65 30 300 30 75 Zr-Nb-95 15 400 40 100 Ba-La-140 15 200 20 50 Co-58 15 1,000 100 250 Co-60 15 300 30 75

, Page 28 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL Table 2-2 Lakewater pCi/L-T.S.(d) Mn-54 15 , 1,000 100 250 and Well Water I-131 2 2 (Continued) Other 30 100 H-3 3,000 30,000 3,000 7,500 Sr-89 10 50 Sr-90 2 20 Milk pCi/L Sr-89 5 100 Sr-90 1 100 I-131 0.5 3 0.5 0.75 Cs-134 15 60 15 15 Cs-137 18 70 18 18 Ba-La-140 15 300 30 75 Other(c) 15 30 Air Filter pCi/m 3 Gross Beta 0.01 1.0 1-131 0.07 0.9 0.09 0.2 Cs-137 0.06 20 2.0 5.0 Cs-134 0.05 10 1.0 2.5 Other(c) 0.1 1.0 (a) The LLDs in this column are the maximum acceptable values.

(b) The values in this column are not technical specifications.

(c) Other refers to non-specified identifiable gamma emitters.

(d) T.S. = total solids.

(e) No drinking water Page 29 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE 2-3 RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Location Code Location Description E-01 Primary Meteorological Tower, South of the plant E-02 Site Boundary Control Center - East Side of Building E-03 Tapawingo Road, about 0.4 Miles West of Lakeshore Road E-04 North Boundary E-05 Two Creeks Park E-06 Point Beach State Park - Water and shoreline sediment samples at the Coast Guard Station; soil and vegetation from the Point Beach State Park campground area N of the Coast Guard Station and on the W side of County Road 0; TLD located South of lighthouse on telephone pole.

E-07 WPSC Substation on County Rt. V, about 0.5 Miles West of Hwy. 42 E-08 G. J. Francar Property, at the Southeast Corner of the Intersection of Cty. B and Zander Road E-09 Nature Conservancy E-10 PBNP Site Well E-11 Dairy Farm (W. Funk), about 3.75 Miles West of Site E-12 On fence at U-2 discharge flume E-13 Pumphouse E-14 South Boundary, about 0.2 miles East of Site Boundary Control Center E-15 Southwest Corner of Site E-16 WSW, Hwy. 42, Residence, about 0.25 miles North of Nuclear Road E-17 North of Mishicot, Cty. B and Assman Road, Northeast Corner of Intersection E-18 Northwest of Two Creeks at Zander and Tannery Roads E-20 Reference Location, 17 miles Southwest, at Silver Lake College E-21 Local Dairy Farm just South of Site (L. Strutz) on Lakeshore and Irish Roads E-22 West Side of Hwy. 42, about 0.25 miles North of Johanek Road E-23 Greenfield Lane, about 4.5 Miles South of Site, 0.5 Miles East of Hwy. 42 E-24 North Side of County Rt. V, near intersection of Saxonburg Road E-25 South Side of County Rt. BB, about 0.5 miles West of Norman Road E-26 804 Tapawingo Road, about 0.4 miles East of Cty. B. North Side of Road E-27 Intersection of Saxonburg and Nuclear Roads, Southwest Corne, about 4 Miles WSW E-28 TLD on westernmost pole between the 2nd and 3rd parking lots, E-29 On fence near propane tank NE of Warehouse #8 E-30 NE corner at Intersection of Tapawingo and Lakeshore Roads.

E-31 On utility pole North side of Tapawingo Road closest to the gate at the West property line

- Page 30 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM' ENVIRONMENTALMANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL Table 2-3 E-32 On a tree located at the junction of property lines, as indicated by trees and shrubs, about 500 feet east of the west gate in line with first designated treeline on Tapawingo Road and about 1200 feet south of Tapawingo Road. The location is almost under the power lines between the blue and gray transmission towers.

E-33 Lake Michigan shoreline accessed from SE corner of KNPP parking lot. Sample south of creek.

E-38 On tree W of former Retention Pond site E-39 On tree E of former Retention Pond site E-40 Local Dairy Farm, about 1.8 miles north of intersection of Highway 42 and Nuclear Road (Manitowoc County), on West side of Highway 42.

E-TC Transportation Control; Reserved for TLDs Page 31 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE 2-4 PBNP RADIOLOGICAL ENVIRONMENTAL SAMPLE COLLECTION AND ANALYSIS FREQUENCY Sample Type Sample Codes Analyses Frequency Environmental Radiation E-01, -02, -03, -04, -05, TLD Quarterly Exposure -06, -07, -08, -09, -12,

-14, -15, -16, -17, -18,

-20, -22, -23, -24, -25,

-26, -27, -28, -29, -30,

-31, -32,

-38, -39, -TC Vegetation E-01, -02, -03, -04, -06, Gross Beta 3x/yr as available

-08, -09, -20, Gamma Isotopic Analysis Algae E-05, -12 Gross Beta 3x/yr as available Gamma Isotopic Analysis Fish E-13 Gross Beta 3x/yr as available Gamma Isotopic Analysis (Analysis of edible portions only)

Well Water E-10 Gross Beta, H-3 Quarterly Sr-89, 90, I-131 Gamma Isotopic Analysis (on total solids)

Lake Water E-01, -05, -06, Gross Beta Monthly

-33 H-3, Sr-89, 90 Quarterly composite of monthly collections I-131 Monthly Gamma Isotopic Analysis Monthly (on total solids)

I Milk E- Il, -21, -40 Sr-89, 90 Monthly 1-131 Gamma Isotopic Analysis Air Filters E-01, -02, -03, -04, Gross Beta Weekly (particulate)

-08, -20 I-131 Weekly (charcoal)

Gamma Isotopic Analysis Quarterly (on composite particulate filters)

Soil E-01, -02, -03, -04, Gross Beta 2x/yr

-06, -08, -09, -20, Gamma Isotopic Analysis Shoreline Sediment E-01, -05, -06, -12, Gross Beta 2x/yr

-33 Gamma Isotopic Analysis Page 32 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL TABLE 2-5 SAMPLES COLLECTED FOR STATE OF WISCONSIN Sample Type Location Frequency

1. Lake Water E-01 Monthly

2. Air Filters E-07 Weekly E-08

3. Fish E-13 Quarterly, As Available

4. Precipitation E-04 Twice a month, E-08 As Available

5. Milk E-11 Monthly I E-40

6. Well Water E-10 2 times/year

'- I I IPage 33 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM .

ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL FIGURE 2-la RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS IPage 34 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 ENVIRONMENTAL MANUAL FIGURE 2-lb RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Page 35 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 18 September 28, 2005 I

T ENVIRONMENTAL MANUAL Li -

I FIGURE 2-ic RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS PB01658Gdgn 8/3OrM &11:44AM Page 36 of 36 INFORMATION USE

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