NL-10-0905, Enclosure 1 - Edwin I. Hatch, Units 1 and 2, Annual Radiological Environmental Operating Report for 2009

Enclosure 1 - Edwin I. Hatch, Units 1 and 2, Annual Radiological Environmental Operating Report for 2009

ML101390535
Person / Time
Site:	Hatch
Issue date:	05/14/2010
From:	Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
References
NL-10-0905
Download: ML101390535 (70)

Text

Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Annual Radiological Environmental Operating Reports for 2009 Enclosure 1 Hatch Annual Radiological Environmental Operating Report for 2009 EDWIN I. HATCH NUCLEAR PLANT ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2009 SOUTHERNA COMPANY Energy to Serve Your World" TABLE OF CONTENTS Title and/or Section Subsection Page List of Figures ii List of Tables iii List of Acronyms iv 1.0 Introduction 1-1 2.0 REMP Description 2-1 3.0 Results Summary 3-1 4.0 Discussion of Results 4-1 4.1 Land Use Census and River Survey 4-5 4.2 Airborne 4-7 4.3 Direct Radiation 4-12 4.4 Milk 4-18 4.5 Vegetation 4-22 4.6 River Water 4-25 4.7 Fish 4-28 4.8 Sediment 4-32 4.9 Groundwater 4-38 5.0 Interlaboratory Comparison Program 5-1 6.0 Conclusions 6-1 i LIST OF FIGURES Figure Number Title Page Figure 2-1 REMP Stations Near the Plant 2-8 Figure 2-2 REMP Stations Beyond Six Miles from the Plant 2-9 Figure 2-3 Groundwater Monitoring Locations 2-10 Figure 2-4 Deep Wells 2-11 Figure 4.2-1 Average Weekly Gross Beta Air Concentration 4-7 Figure 4.2-2 Average Annual Cs-137 Concentration in Air 4-9 Figure 4.3-1 Average Quarterly Exposure from Direct Radiation 4-13 Figure 4.3-2 Average Quarterly Exposure from Direct Radiation at Special Interest Areas 4-15 Figure 4.4-1 Average Annual Cs-137 Concentration in Milk 4-18 Figure 4.4-2 Average Annual 1-131 Concentration in Milk 4-20 Figure 4.5-1 Average Annual Cs-137 Concentration in Vegetation 4-23 Figure 4.6-1 Average Annual H-3 Concentration in River Water 4-26 Figure 4.7-1 Average Annual Cs-137 Concentration in Fish 4-28 Figure 4.7-2 Average Annual Cs-134 Concentration in Fish 4-30 Figure 4.8-1 Average Annual Co-60 Concentration in Sediment 4-32 Figure 4.8-2 Average Annual Cs-137 Concentration in Sediment 4-34 Figure 4.8-3 Average Annual Indicator Station Concentrations of Select Nuclides in Sediment 4-36 Figure 4.9-1 Plant Hatch Unconfined Perched Aquifer 4-41 November 2009 11 LIST OF TABLES Table Number Title Page Table 2-1 Summary Description of Radiological Environmental Monitoring Program 2-2 Table 2-2 Radiological Environmental Sampling Locations 2-5 Table 2-3 Groundwater Sampling Locations 2-7 Table 3-1 Radiological Environmental Monitoring Program Annual Summary 3-2 Table 4-1 Minimum Detectable Concentrations (MDC) 4-1 Table 4-2 Reporting Levels (RL) 4-2 Table 4-3 Deviations from Radiological Environmental Monitoring Program 4-4 Table 4.1-1 Land Use Census Results 4-5 Table 4.2-1 Average Weekly Gross Beta Air Concentration 4-8 Table 4.2-2 Average Annual Cs-137 Concentration in Air 4-10 Table 4.3-1 Average Quarterly Exposure from Direct Radiation 4-14 Table 4.3-2 Average Quarterly Exposure from Direct Radiation at Special Interest Areas 4-16 Table 4.4-1 Average Annual Cs-137 Concentration in Milk 4-19 Table 4.4-2 Average Annual 1-131 Concentration in Milk 4-21 Table 4.5-1 Average Annual Cs-137 Concentration in Vegetation 4-24 Table 4.6-1 Average Annual H-3 Concentration in River Water 4-27 Table 4.7-1 Average Annual Cs-137 Concentration in Fish 4-29 Table 4.7-2 Average Annual Cs- 134 Concentration in Fish 4-31 Table 4.8-1 Average Annual Co-60 Concentration in Sediment 4-33 Table 4.8-2 Average Annual Cs-137 Concentration in Sediment 4-35 Table 4.8-3 Sediment Nuclide Concentrations Other Than Co-60 &Cs-137 4-37 Table 5-1 Interlaboratory Comparison Results 5-3 iii LIST OF ACRONYMS Acronyms presented in alphabetical order.Acronym Definition ASTM American Society for Testing and Materials CL Confidence Level EL Georgia Power Company Environmental Laboratory EPA Environmental Protection Agency GPC Georgia Power Company HNP Edwin I. Hatch Nuclear Plant ICP Interlaboratory Comparison Program MDC Minimum Detectable Concentration MDD Minimum Detectable Difference NA Not Applicable NDM No Detectable Measurement(s)

NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual Po Preoperation REMP Radiological Environmental Monitoring Program RL Reporting Level TLD Thermoluminescent Dosimeter TS Technical Specification iv

1.0 INTRODUCTION

The Radiological Environmental Monitoring Program (REMP) is conducted in accordance with Chapter 4 of the Offsite Dose Calculation Manual (ODCM).REMP activities for 2009 are reported herein in accordance with Technical Specification (TS) 5.6.2 and ODCM 7.1.The objectives of the REMP are to: 1) Determine the levels of radiation and the concentrations of radioactivity in the environs and;2) Assess the radiological impact (if any) to the environment due to the operation of the Edwin I. Hatch Nuclear Plant (HNP).The assessments include comparisons between the results of analyses of samples obtained at locations where radiological levels are not expected to be affected by plant operation (control stations) and at locations where radiological levels are more likely to be affected by plant operation (indicator stations), as well as comparisons between preoperational and operational sample results.The pre-operational stage of the REMP began with the establishment and activation of the environmental monitoring stations in January of 1972. The operational stage of the REMP began on September 12, 1974 with Unit 1 initial criticality.

A description of the REMP is provided in Section 2 of this report. An annual summary of the results of the analyses of REMP samples is provided in Section 3.A discussion of the results, including assessments of any radiological impacts upon the environment, and the results of the land use census and the river survey, are provided in Section 4. The results of the Interlaboratory Comparison Program (ICP) are provided in Section 5. Conclusions are provided in Section 6.1-1 2.0 REMP DESCRIPTION A summary description of the REMP is provided in Table 2-1. This table summarizes the program as it meets the requirements outlined in ODCM Table 4-1. It details the sample types to be collected and the analyses to be performed in order to monitor the airborne, direct radiation, waterborne and ingestion pathways, and also delineates the collection and analysis frequencies.

The sampling locations (stations) specified by ODCM 4.2 are depicted on maps in Figures 2-1 and 2-2.These maps are keyed to Table 2-2 which delineates the direction and distance of each station from the main stack.REMP samples are collected by Georgia Power Company's (GPC) Environmental Laboratory (EL) personnel.

The same lab performs all the laboratory analyses at their headquarters in Smyrna, Georgia.2-1 TABLE 2-1 (SHEET 1 of 3)

SUMMARY

DESCRIPTION OF RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Approximate Sampling and Type of Analysis and Frequency and/or Sample Number of Sample Collection Frequency Locations 1. Airborne 6 Continuous operation Radioiodine canister:

1-131 analysis, weekly.Radioiodine and of the sampler with Particulates sample collection Particulate sampler: analyze for gross beta radioactivity not less weekly. than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following filter change, weekly; perform gamma isotopic analysis on affected sample when gross beta activity is 10 times the yearly mean of control samples; and composite (by location) for gamma isotopic analysis, quarterly.

2. Direct Radiation 37 Quarterly Gamma dose, quarterly.

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Milk (a) 1 Biweekly Gamma isotopic and 1-131 analysis, biweekly.Fish or Clams (b) 2 Semiannually -Gamma isotopic analysis on edible portions, semiannually.

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Grass or Leafy 3 Monthly during Gamma isotopic analysis, monthly. (c)Vegetation growing season.4. Waterborne

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Surface 2 Composite sample Gamma isotopic analysis, monthly. Composite (by location) for collected monthly. (d) tritium analysis, quarterly.

Sediment 2 Semiannually.

Gamma isotopic analysis, semiannually.

TABLE 2-1 (SHEET 2 of 3)

SUMMARY

DESCRIPTION OF RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Approximate Sampling and Type of Analysis and Frequency and/or Sample Number of Sample Collection Frequency Locations Drinking Water (e&f)One sample of river water near the intake and one sample of finished water from each of one to three of the nearest water supplies which could be affected by HNP discharges.

See Table 2-3, Figure 2-3, and Figure 2-4 River water collected near the intake will be a composite sample;the finished water will be a grab sample.These samples will be collected monthly unless the calculated dose due to consumption of the water is greater than 1 mrem/year; then the collection will be biweekly.

The collections may revert to monthly should the calculated doses become less than 1 mrem/year.

Quarterly sample;pump used to sample GW wells; grab sample from yard drains and ponds 1-131 analysis on each sample when biweekly collections are required.

Gross beta and gamma isotopic analysis on each sample; composite (by location) for tritium analysis, quarterly.

Tritium, gamma isotopic, and field parameters (pH, temperature, conductivity, dissolved oxygen, oxidation/reduction potential, and turbidity) of each sample quarterly; Hard to detect radionuclides as necessary based on results of tritium and gamma Groundwater I I TABLE 2-1 (SHEET 3 of 3)

SUMMARY

DESCRIPTION OF RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Notes: a. Up to three sampling locations within 5 miles and in different sectors will be used as available.

In addition, one or more control locations beyond 10 miles will be used.b. Commercially or recreationally important fish may be sampled. Clams may be sampled if difficulties are encountered in obtaining sufficient fish samples.c. If gamma isotopic analysis is not sensitive enough to meet the Minimum Detectable Concentration (MDC), a separate analysis for 1- 131 may be performed.

d. The composite samples shall be composed of a series of aliquots collected at intervals not exceeding a few hours.e. If it is found that river water downstream of the plant is used for drinking, drinking water samples will be collected and analyzed as specified herein.f. A survey shall be conducted annually at least 50 river miles downstream of the plant to identify those who use water from the Altamaha River for drinking, N,)

TABLE 2-2 (SHEET 1 of 2)RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Station Station Descriptive Location Direction Distance (a) Sample Type Number Type (a) (miles)064 Other Roadside Park WNW 0.8 Direct Rad 101 Indicator Inner Ring N 1.9 Direct Rad 102 Indicator Inner Ring NNE 2.5 Direct Rad 103 Indicator Inner Ring NE 1.8 Airborne Rad Direct Rad 104 Indicator Inner Ring ENE 1.6 Direct Rad 105 Indicator Inner Ring E 3.7 Direct Rad 106 Indicator Inner Ring ESE 1.1 Direct Rad Vegetation 107 Indicator Inner Ring SE 1.2 Airborne Rad Direct Rad 108 Indicator Inner Ring SSE 1.6 Direct Rad 109 Indicator Inner Ring S 0.9 Direct Rad 110 Indicator Inner Ring SSW 1.0 Direct Rad 111 Indicator Inner Ring SW 0.9 Direct Rad 112 Indicator Inner Ring WSW 1.0 Airborne Rad Direct Rad Vegetation 113 Indicator Inner Ring W 1.1 Direct Rad 114 Indicator Inner Ring WNW 1.2 Direct Rad 115 Indicator Inner Ring NW 1.1 Direct Rad 116 Indicator Inner Ring NNW 1.6 Airborne Rad Direct Rad 170 Control Upstream WNW (c) River (b)172 Indicator Downstream E (c) River (b)201 Other Outer Ring N 5.0 Direct Rad 202 Other Outer Ring NNE 4.9 Direct Rad 203 Other Outer Ring NE 5.0 Direct Rad 204 Other Outer Ring ENE 5.0 Direct Rad 205 Other Outer Ring E 7.2 Direct Rad 206 Other Outer Ring ESE 4.8 Direct Rad 207 Other Outer Ring SE 4.3 Direct Rad 208 Other Outer Ring SSE 4.8 Direct Rad 209 Other Outer Ring S 4.4 Direct Rad 210 Other Outer Ring SSW 4.3 Direct Rad 211 Other Outer Ring SW 4.7 Direct Rad 212 Other Outer Ring WSW 4.4 Direct Rad 213 Other Outer Ring W 4.3 Direct Rad 214 Other Outer Ring WNW 5.4 Direct Rad 215 Other Outer Ring NW 4.4 Direct Rad 216 Other Outer Ring NNW 4.8 Direct Rad 301 Other Toombs Central School N 8.0 Direct Rad 304 Control State Prison ENE 11.2 Airborne Rad Direct Rad 304 Control State Prison ENE 10.3 Milk 309 Control Baxley S 10.0 Airborne Rad Substation Direct Rad 416 Control Emergency News NNW 21.0 Direct Rad Center Vegetation 2-5 TABLE 2-2 (SHEET 2 of 2)RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Notes: a. Direction and distance are determined from the main stack.b. River (fish or clams, shoreline sediment, and surface water)c. Station 170 is located approximately 0.6 river miles upstream of the intake structure for river water, 1.1 river miles for sediment and clams, and 1.5 river miles for fish.Station 172 is located approximately 3.0 river miles downstream of the discharge structure for river water, sediment and clams, and 1.7 river miles for fish.The locations from which river water and sediment may be taken can be sharply defined.However, the sampling locations for clams often have to be extended over a wide area to obtain a sufficient quantity.

High water adds to the difficulty in obtaining clam samples and may also make an otherwise suitable location for sediment sampling unavailable.

A stretch of the river of a few miles or so is generally needed to obtain adequate fish samples. The mile locations given above represent approximations of the locations where samples are collected.

2-6 Table 2-3 Groundwater Monitoring Locations WELL [ DEPTH (ft) [ MONITORING PURPOSE R1 82.9 Confined Aquifer Upgradient R2 82.7 Confined Aquifer Near Diesel Generator Bldg.R3 89.2 Confined Aquifer Near CST-1 R4 41 Dilution Line Near River Water Discharge Structure R5 33.6 Between Subsurface Drain Lines Downgradient R6 38.2 Between Subsurface Drain Lines Downgradient NW2A 27 Water Table Near CST-2 Inside of Subsurface Drain NW2B 27 Water Table Outside of Subsurface Drain NW3A 26.5 Water Table Inside of Subsurface Drain NW3B 25.3 Water Table Outside of Subsurface Drain NW4A 27 Water Table Upgradient Inside of Subsurface Drain NW5A 26.7 WateriTable Upgradient Inside of Subsurface Drain NW5B 26.3 Water Table Upgradient Outside of Subsurface Drain NW6 27 Water Table Near Diesel Generator Bldg.NW8 23 Water Table Near Diesel Generator Bldg.NW9 26.1 Water Table Downgradient Inside of Subsurface Drain NW10 26.2 Water Table Near CST-2 T2 21.9 Water Table Near Recombiner Bldg.T3 18 Water Table Near Turbine Bldg.T7 21.4 Water Table Near Diesel Generator Bldg.T10 18.8 Water Table Near CST-1 T12 23.2 Water Table Near CST-1 T15 27.4 Water Table Near CST-1 P15A 74.5 Confined Aquifer Near Turbine Bldg.P15B 18 Water Table Near Turbine Bldg.P17A 77 Confined Aquifer Near Diesel Generator Bldg.P1 7B 14.8 Water Table Near Diesel Generator Bldg.Deep Well 1 680 Backup Supply for Potable Water (infrequently used)Deep Well 2 711 Plant Potable Water Supply Deep Well 3 710 Potable Water Supply -Rec. Center, Firing Range, and Garage 2-7 Radiological Environmental Sampling Locations REMP Stations Near Indicator Control Additional TLD A A A the Plant Other 0 0 0 TLD & Other Figure 2-1 2-8 Whe' q !g05 Radiological Environmental Sampling Locations REMP Stations Beyond Indicator Control Additional TLD A A A Five Miles from the Plant Other 0 0 0 TLD & Other Figure 2-2 I *R4 Figure 2-3 Groundwater Monitoring Locations 2-10 Figure 2-4 Deep Wells:0>"1-I>AREA WATER 0 DEEP WELL 3 2-11 3.0 RESULTS

SUMMARY

In accordance with ODCM 7.1.2.1, the summarized and tabulated results for all of the regular samples collected for the year at the designated indicator and control stations are presented in Table 3-1. The format of Table 3-1 is similar to Table 3 of the Nuclear Regulatory Commission (NRC) Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program", Revision 1, November 1979. Since no naturally occurring radionuclides were found in the plant's effluent releases, only man-made radionuclides are reported as permitted by ODCM 7.1.2.1. Results for samples collected at locations other than control or indicator stations are discussed in Section 4 under the particular sample type.3-1 TABLE 3-1 (SHEET 1 of 4)RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL

SUMMARY

Edwin I. Hatch Nuclear Plant, Docket Nos. 50-321 and 50-366 Appling County, Georgia Medium or Type and Total Minimum Indicator Location with the Highest Other Control Pathway Number of Detectable Locations Annual Mean Stations(g)

Locations Sampled Analyses Concentration Mean (b), Mean (b), Mean (b), (Unit of Performed (MDC) (a) Range Name Distance Mean (b), Range Range Measurement) (Fraction)

& Direction Range (Fraction) (Fraction)(Fraction)

Airborne Gross Beta 10 21.2 No. 304 21.9 NA 21.4 Particulates 299 7.6-39.7 State Prison 7.4-35.9 5.0-35.9 (fCi/m3) (195/195) 11.2 miles, (52/52) (104/104)ENE Gamma Isotopic 24 Cs- 134 50 NDM (c) NDM NDM Cs-137 60 NDM NDM NDM Airborne 1-131 70 NDM NDM NA NDM Radioiodine 299 (fCi/m3)Direct Radiation Gamma Dose NA (d) 12.4 No. 214 15.7 12.2 12.2 (mR/91 days) 146 10.4-17.0 Outer Ring 14.7-16.2 9.4-16.2 10.4-13.7 (62/62) 5.4 miles, (4/4) (72/72) (12/12)WNW Milk Gamma Isotopic NA (pCi/1) 26 Cs-134 15 NA NDM NDM Cs-137 18 NA NDM NDM Ba-140 60 NA NDM NDM La- 140 15 NA NDM NDM I-.131 1 NA NDM NDM 26 TABLE 3-1 (SHEET 2 of 4)RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL

SUMMARY

Edwin I. Hatch Nuclear Plant, Docket Nos. 50-321 and 50-366 Appling County, Georgia Medium or Type and Minimum Indicator Location with the Highest Control Pathway Total Number Detectable Locations Annual Mean Locations Sampled of Analyses Concentration Mean (b), Mean (b), (Unit of Performed (MDC) (a) Range Name Distance Mean (b), Range Measurement) (Fraction)

& Direction Range (Fraction) (Fraction)

Vegetation Gamma (pCi/kg-wet)

Isotopic 36 1-131 60 NDM NDM NDM Cs-134 60 NDM NDM NDM Cs-137 80 46.8 Station 106 47.8 NDM 21.3-68.0 Inner Ring 30.2-68.0 (12/24) 1.1 miles; ESE (5/12)River Water Gamma (pCi/1) Isotopic 24 Mn-54 15 NDM NDM NDM Fe-59 30 NDM NDM NDM Co-58 15 NDM NDM NDM Co-60 15 NDM NDM NDM Zn-65 30 NDM NDM NDM Zr-95 30 NDM NDM NDM Nb-95 15 NDM NDM NDM 1-131 15 (e) NDM NDM NDM Cs- 134 15 NDM NDM NDM Cs-137 18 NDM NDM NDM Ba- 140 60 NDM NDM NDM La-140 15 NDM NDM NDM Titium 3000 (f) 242 No. 170 343 343 8 (1/4) 0.6 miles (1/4) (1/4)Upstream TABLE 3-1 (SHEET 3 of 4)RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL

SUMMARY

Edwin I. Hatch Nuclear Plant, Docket Nos. 50-321 and 50-366 Appling County, Georgia Medium or Type and Minimum Indicator Location with the Highest Control Pathway Total Number Detectable Locations Annual Mean Locations Sampled of Analyses Concentration Mean (b), Mean (b), (Unit of Performed (MDC) (a) Range Name Distance Mean (b), Range Measurement) (Fraction)

& Direction Range (Fraction) (Fraction)

Fish Gamma (pCilkg-wet)

Isotopic 6 Mn-54 130 NDM NDM NDM Fe-59 260 NDM NDM NDM Co-58 130 NDM NDM NDM Co-60 130 NDM NDM NDM Zn-65 260 NDM NDM NDM Cs- 134 130 NDM NDM NDM Cs-137 150 12.4 No. 172 12.4 8.4 (1/1) 3.0 miles (1/1) (1/1)Downstream Sediment Gamma (pCi/kg-dry)

Isotopic 4 Cs- 134 150 NDM NDM NDM Cs-137 180 74.9 No. 172 74.9 60.5 35.3-114.5 3.0 miles 35.3-114.5 28.6-92.5 1(2/2) Downstream (2/2) (2/2)

TABLE 3-1 (SHEET 4 of 4)RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANNUAL

SUMMARY

Edwin I. Hatch Nuclear Plant, Docket Nos. 50-321 and 50-366 Appling County, Georgia NOTATIONS a. The MDC is defined in ODCM 10.1. Except as noted otherwise, the values listed in this column are the detection capabilities required by ODCM Table 4-3. The values listed in this column are a priori (before the fact) MDCs. In practice, the a posteriori (after the fact) MDCs are generally lower than the values listed. Any a posteriori MDC greater than the value listed in this column is discussed in Section 4.b. Mean and range are based upon detectable measurements only. The fraction of all measurements at specified locations that are detectable is placed in parenthesis.

c. No Detectable Measurement(s).

d. Not Applicable.

e. If a drinking water pathway were to exist, a MDC of 1 pCi/i would have been used (see Table 4-1 of this report).f. If a drinking water pathway were to exist, a MDC of 2000 pCi/1 would have been used (see Table 4-1 of this report).g. "Other" stations, identified in the "station type" column of Table 2-2, include community and special stations.

4.0 DISCUSSION OF RESULTS Included in this section are evaluations of the laboratory results for the various sample types. Comparisons were made between the difference in mean values for pairs of station groups (e.g., indicator and control stations) and the calculated Minimum Detectable Difference (MDD) between these pairs at the 99%Confidence Level (CL). The MDD was determined using the standard Student's t-test. A difference in the mean values which was less than the MDD was considered to be statistically indiscernible.

The 2009 results were compared with past results, including those obtained during pre-operation.

As appropriate, results were compared with their Minimum Detectable Concentrations (MDC) and Reporting Levels (RL) which are listed in Tables 4-1 and 4-2 of this report, respectively.

The required MDCs were achieved during laboratory sample analyses.

Any anomalous results are explained within this report.Results of interest are graphed to show historical trends. The data points are tabulated and included in this report. The points plotted and provided in the tables represent mean values of only detectable results. Periods for which no detectable measurements (NDM) were observed or periods for which values were not applicable (e.g., milk indicator, etc.) are plotted as O's and listed in the tables as NDM.Table 4-1 Minimum Detectable Concentrations (MDC)Analysis Water Airborne Fish Milk Grass or Sediment (pCi/l) Particulate (pCi/kg- (pCi/I) Leafy (pCi/kg-or Gases wet) Vegetation dry)(fCi/m3) (pCi/kg-wet)

Gross Beta 4 10 H-3 2000 (a)Mn-54 15 130 Fe-59 30 260 Co-58 15 130 Co-60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 1-131 1 (b) 70 1 60 Cs-134 15 50 130 15 60 150 Cs-137 18 60 150 18 80 180 Ba-140 60 60 La-140 15 15 (a) If no drinking water pathway exists, a value of 3000 pCi/l may be used.(b) If no drinking water pathway exists, a value of 15 pCi/l may be used.4-1 Table 4-2 Reporting Levels (RL)Analysis Water Airborne Fish Milk (pCi/l) Grass or Leafy (pCi/l) Particulate (pCi/kg-wet)

Vegetation or Gases (pCi/kg-wet)(fCi/m3)H-3 20,000 (a)Mn-54 1000 30,000 Fe-59 400 10,000 Co-58 1000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-95 400 Nb-95

• 700 1-131 2 (b) 900 3 100 Cs- 134 30 10,000 1000 60 1000 Cs-137 50 20,000 2000 70 2000 Ba-140 200 300 La-140 100 400 (a) This is the 40 CFR 141 value for drinking water samples. If no drinking water pathway exists, a value of 30,000 may be used.(b) If no drinking water pathway exists, a value of 20 pCi/I may be used.4-2 Atmospheric nuclear weapons tests from the mid 1940s through 1980 distributed man-made nuclides around the world. The most recent atmospheric tests in the 1970s and in 1980 had a significant impact upon the radiological concentrations found in the environment prior to and during preoperation, and the earlier years of operation.

Some long lived radionuclides, such as Cs-137, continue to be detectable.

Significant upward trends also followed the Chernobyl incident which began on April 26, 1986.In accordance with ODCM 4.1.1.2.1, deviations from the required sampling schedule are permitted, if samples are unobtainable due to hazardous conditions, unavailability, inclement weather, equipment malfunction or other just reasons.Deviations from conducting the REMP as described in Table 2-1 are summarized in Table 4-3 along with their causes and resolutions.

All results were tested for conformance to Chauvenet's criterion (G. D. Chase and J. L. Rabinowitz, Principles of Radioisotope Methodology, Burgess Publishing Company, 1962, pages 87-90) to identify values which differed from the mean of a set by a statistically significant amount. Identified outliers were investigated to determine the reason(s) for the difference.

If equipment malfunction or other valid physical reasons were identified as causing the variation, the anomalous result was excluded from the data set as non-representative.

No data were excluded exclusively for failing Chauvenet's criterion.

Data exclusions are discussed in this section under the appropriate sample type.4-3 TABLE 4-3 DEVIATIONS FROM RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM COLLECTION AFFECTED DEVIATION CAUSE RESOLUTION PERIOD SAMPLES 02/02/09-02/09/09 AF Stations Heavy particulate Controlled bum in area Filters changed at CR2010105981 107 -1.2 miles SE loading on filter beginning of week 112 -1.0 miles WSW 304- 11.2 miles ENE 309 -10.0 miles S 1 t Quarter TLD- Direct radiation data Moisture or rainwater Replaced TLDs at CR2010105988 Station 301B rendered suspect due to beginning of quarter 8 miles N presence of water in bag 04/20/09-04/27/09 AF/AC Non-representative Sampling period was short by 15.6 Station operated CR2010105984 Station 103 direct radiation data hours due to blown fuse satisfactorily after fuse 1.8 miles NE replaced 06/29/09-09/28/09 AF/AC Non-representative Major failure of underground power Station operated CR2010105986 Station 107 sample of airborne line resulted in station being out of satisfactorily after EXCLUDED 1.2 miles SE particulates service for 13 weeks underground line repaired Second Semi-Annual Fish No fish data for second High river water level and flooding Continue to monitor Collection Period semi-annual period during the entire fall; unable to perform conditions on river CR2009112046 electrofishing 3 d Quarter TLD Non-representative TLDs found on ground at collection Replaced TLDs at CR2010105988 Station 114 direct radiation data time beginning of quarter 1.2 miles WNW 4th Quarter TLD Stations Non-representative TLDs were missing at mid-quarter; Replaced TLDs at CR2010105988 102 -2.5 miles NNE direct radiation data replaced with blanks but data was not beginning of quarter EXCLUDED 104 -1.6 miles ENE representative of collection period 4th Quarter TLD Stations Direct radiation data Mechanical reader problem Used data from companion CR2010105988 215B -4.4 miles NW loss; only companion badges 216A -4.8 miles NNW badge results used Dec Monthly Comp. RW Station 172 Non-representative rivet Grab sample taken of river water; ISCO ISCO sampler replaced CR2010105987 Downstream 3 miles E sample sampler destroyed by flooding when flood waters receded 4.1 Land Use Census and River Survey In accordance with ODCM 4.1.2, a land use census was conducted on November 9, 2009, to determine the locations of the nearest permanent residence and milk animal in each of the 16 compass sectors within a distance of 5 miles, and the locations of all milk animals within a distance of 3 miles. A milk animal is defined as a cow or goat producing milk for human consumption.

The locations of beef cattle and of gardens greater than 500 square feet producing broad leaf vegetation were also included in the census. The census results are tabulated in the Table 4.1-1.Table 4.1-1 LAND USE CENSUS RESULTS Distance in Miles to Nearest Location in Each Sector SECTOR RESIDENCE MILK ANIMAL BEEF CATTLE [ GARDEN N 2.1 None None 3.8 NNE 2.9 None None None NE 3.3 None 3.5 None ENE 4.2 None 4.1 None E 3.0 None None None ESE 3.8 None None None SE 1.8 None 2.3 4.4 SSE 2.0 None 3.6 2.2 S 1.1 None 2.3 2.3 SSW 1.5 None 2.0 None SW 1.1 None 2.3 1.6 WSW 1.0 None 4.8 3.2 W 1.1 None 2.8 None WNW 1.1 None None None NW 3.6 None 4.6 None NNW 1.9 None 2.8 2.8 4-5 ODCM 4.1.2.2.1 requires a new controlling receptor to be identified if the land use census identifies a location that yields a calculated receptor dose greater than the one in current use. No change in the controlling receptor was required as a result of the 2009 land use census. The current controlling receptor as described in ODCM Table 3-7 is a child in the WSW Sector at 1.2 miles ODCM 4.1.2.2.2 requires that whenever the land use census identifies a location which would yield a calculated dose (via the same ingestion pathway) 20% greater than that of a current indicator station, the new location must become a REMP station (if samples are available).

The 2009 land use census did not identify a garden which yielded a calculated dose 20% greater than that for any of the current indicator stations for vegetation.

The results of the census were corroborated by inquiries to the county extension agents in the 5 counties in the vicinity of the plant.As required by Note f of Table 2.1, the annual survey of the Altamaha River for 50 miles downstream of the plant was conducted on September 28, 2009 to identify any withdrawal of river water for drinking purposes.

No sources of withdrawal for drinking water or agricultural purposes were identified.

Information obtained from the Georgia Department of Natural Resources on October 2, 2009 indicated that no surface water withdrawal permits for agricultural or drinking purposes had been issued for this stretch of the Altamaha River between the 2008 survey and the 2009 survey. Should it be determined that river water downstream of the plant is being used for drinking, the sampling and analysis requirements for drinking water found in Table 2-1 would be implemented.

4-6 4.2 Airborne As indicated in Table 2-2 and Figures 2-1 and 2-2, airborne particulates and airborne radioiodine are collected at 4 indicator stations (Nos. 103, 107, 112 and 116) which encircle the plant near the site periphery and at 2 control stations (Nos.304 and 309) which are located approximately 10 miles from the main stack. At each location, air is continuously drawn through a glass fiber filter and a charcoal canister placed in series to collect airborne particulates and radioiodine.

The filters and canisters are collected weekly and analyzed for gross beta and 1-131, respectively.

A gamma isotopic analysis is performed quarterly on a composite of the filters for each station.The 2009 annual average weekly fross beta concentration of 21.2 fCi/m 3 for the indicator stations was 0.2 fCi/m less than that for the control stations (21.4 fCi/m 3). This difference is not statistically discernible, since it is less than the calculated MDD of 1.7 fCi/m 3.Figure 4.2-1 and Table 4.2-1 provide the historical trending of the average weekly gross beta concentrations in air. In general, there is close agreement between the results for the indicator and control stations.

This close agreement supports the position that the plant is not contributing significantly to the gross beta concentration in air.Figure 4.2-1 Average Weekly Gross Beta Air Concentration 300 250 200 44-.2 150 0 0100 50 0 Year MDC Indicator

-Control 4-7 Table 4.2-1 Average Weekly Gross Beta Air Concentration Year Indicator Control (fCi/m3) (fCi/m3)Pre-op 140 140 1974 87 90 1975 85 90 1976 135 139 1977 239 247 1978 130 137 1979 38 39 1980 49 48 1981 191 203 1982 33 34 1983 31 30 1984 26 28 1985 22 21 1986 36 38 1987 23 22 1988 22.6 21.7 1989 18.4 17.8 1990 19.3 18.7 1991 18.1 18 1992 18.5 18.4 1993 20.4 20.7 1994 19.5 19.7 1995 21.7 21.7 1996 21.3 21.4 1997 20.3 20.7 1998 20.0 20.5 1999 21.3 21.3 2000 23.6 23.9 2001 21.5 21.0 2002 19.3 19.2 2003 18.8 18.2 2004 21.4 21.3 2005 19.7 19.4 2006 24.9 24.7 2007 24.4 24.3 2008 21.8 22.5 2009 21.2 21.4 4-8 During 2009, no man-made radionuclides were detected from the gamma isotopic analysis of the quarterly composites of the particulate air filters. During preoperation and during operation through 1986, a number of fission products and activation products were detected.These were generally attributed to the nuclear weapons tests and to the Chernobyl incident.On only one occasion since 1986, has a man-made radionuclide been detected in a quarterly composite.

A small amount of Cs-137 (1.7 fCi/m3) was identified in the first quarter of 1991 at Station 304. The MDC and RL for Cs-137 in air are 60 and 20,000 fCi/m3, respectively.

The historical trending of the average annual concentrations of detectable Cs-137 from quarterly air filter composites is provided in Figure 4.2-2 and Table 4.2-2.Figure 4.2-2 60 Average Annual Cs-137 Concentration in Air 50 o0 30 C 0 2 0 o .k ...JYe Year I- ndicator ----Control -MDCI 4-9 Table 4.2-2 Average Annual Cs-137 Concentration In Air Year Indicator Control (fCi/m3) (fCi/m3)Pre-op NDM 2.0 1974 1.5 2.0 1975 1.4 1.4 1976 0.6 0.7 1977 1.5 1.4 1978 2.3 2.6 1979 0.8 0.8 1980 0.4 0.6 1981 1.8 1.7 1982 0.5 0.6 1983 0.7 NDM 1984 NDM NDM 1985 0.7 NDM 1986 8.1 9.6 1987 NDM NDM 1988 NDM NDM 1989 NDM NDM 1990 NDM NDM 1991 NDM 1.7 1992 NDM NDM 1993 NDM NDM 1994 NDM NDM 1995 NDM NDM 1996 NDM NDM 1997 NDM NDM 1998 NDM NDM 1999 NDM NDM 2000 NDM NDM 2001 NDM NDM 2002 NDM NDM 2003 NDM NDM 2004 NDM NDM 2005 NDM NDM 2006 NDM NDM 2007 NDM NDM 2008 NDM NDM 2009 NDM ;NDM°: , 4-10 No airborne 1-131 was detected in the charcoal canisters in 2009. During 1976, 1977, and 1978, positive levels of 1-131 were found in nearly all of the samples collected for a period of a few weeks following atmospheric nuclear weapons tests.3 Some of the concentrations were on the order of 70 fCi/m .In 1986, the same phenomenon occurred following the Chernobyl incident.

The highest airborne 1-131 concentration found to date in an individual charcoal canister was 217 fCi/m3 in 1977. The MDC and RL for airborne 1-131 are 70 fCi/m3 and 900 fCi/m 3 , respectively.

Table 4-3 lists REMP deviations that occurred in 2009. Three deviations involved air sampling.

Heavy particulates were noted at four stations (107, 112, 304, and 309) after a controlled burn occurred in the area during the week 02/02-02/09.

The results for these stations were compared to the unaffected stations and all four passed Chauvenet's Criterion and were retained in the data summary. Station 103 lost 15.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of sampling time after a fuse was blown during the collection period from 04/20-04/27.

The results passed Chauvenet's Criterion and were retained in the data summary. Station 107 was out of service for 13 weeks (06/29-09/28) due to a failure of the underground power supply. After weeks of investigation and troubleshooting, the line was successfully repaired and the station put back in service.4-11 4.3 Direct Radiation Direct (external) radiation is measured with thermoluminescent dosimeters (TLDs). Two Panasonic UD-814 TLD badges are placed at each station. Each badge contains three phosphors composed of calcium sulfate crystals (with thulium impurity).

The gamma dose at each station is based upon the average readings of the phosphors from the two badges. The badges for each station are placed in thin plastic bags for protection from moisture while in the field. The badges are nominally exposed for periods of a quarter of a year (91 days). An inspection is performed near mid-quarter to assure that all badges are on-station and to replace any missing or damaged badges.Two TLD stations are established in each of the 16 compass sectors around the plant to form 2 concentric rings, as seen in Figures 2-1 and 2-2. The two ring configuration of stations was established in 1980, in accordance with NRC Branch Technical Position "An Acceptable Radiological Environmental Monitoring Program", Revision 1, 1979. With the exception of the East sector, the inner ring stations (Nos. 101 through 116) are located near the site boundary and the outer ring stations (Nos. 201 through 216) are located at distances of 4 to 5 miles from the plant. The stations in the East sector are a few miles farther out than the other stations in their respective rings due to large swamps making normal access extremely difficult.

The 16 stations forming the inner ring are designated as the indicator stations.

The 3 control stations (Nos. 304, 309 and 416) are located 10 miles or more from the plant. Stations 064 and 301 monitor special interest areas.Station 064 is located at the onsite roadside park, while Station 301 is located near the Toombs Central School. Station 210, in the outer ring, is located near the Altamaha School (the only other nearby school).As provided in Table 3-1, the average quarterly exposure measured at the indicator stations (inner ring) during 2009 was 12.4 mR. At the controlstations, the average quarterly exposure was 12.2 mR. This difference (0.2 mR) is not statistically discernible since it is less than the MDD of 1.0 mR.The quarterly exposures acquired at the outer ring stations during 2009 ranged from 9.4 to 16.2 mR, with an average of 12.23 mR. The average for the outer ring stations was 0.03 mR more than the average for the control stations.

Since the results for the outer ring stations and the control stations differ by less than the MDD of 1.17 mR, there is no discernible difference between outer ring and control station results for 2009.The historical trending of the average quarterly exposures for the indicator inner ring, outer ring, and the control stations are plotted in Figure 4.3-1 and listed in Table 4.3-1. The decrease between 1991 and 1992 values is attributed to a change in TLDs from Teledyne to Panasonic.

It should be noted however that the differences between indicator and control and outer ring values did not change.The close agreement between the station groups supports the position that the plant is not contributing significantly to direct radiation in the environment.

4-12 Figure 4.3-1 Average Quarterly Exposure from Direct Radiation 30 25£20-E 5 tO Year[ '- Indicator -UI- Control ---* Outer Ring 4-13 Table 4.3-1 Average Quarterly Exposure from Direct Radiation Year 7 Indicator (mR) Control (mR) Outer Ring (mR)Pre-op 22.3 23 NA 1974 23.2 25.6 NA 1975 10.0 10.5 NA 1976 8.18 6.9 NA 1977 7.31 6.52 NA 1978 6.67 6.01 NA 1979 5.16 6.77 NA 1980 4.44 5.04 4.42 1981 5.9 5.7 5.7 1982 12.3 12 11.3 1983 11.4 11.3 10.6 1984 13.3 12.9 11.9 1985 14.7 14.7 13.7 1986 15 14 14.5 1987 14.9 14.6 15.3 1988 15.0 14.7 15.2 1989 16.4 18.0 16.5 1990 14.9 13.9 14.7 1991 15.1 13.7 15.6 1992 11.9 10.9 12.3 1993 11.6 10.7 11.5 1994 11 10.7 11.2 1995 11.5 10.8 11.3 1996 11.6 11.3 11.6 1997 12.3 11.8 12.3 1998 12.1 12.3 12.3 1999 12.8 13.2 13.0 2000 13.6 13.3 13.3 2001 12.0 12.1 11.8 2002 11.7 11.7 11.5 2003 11.4 11.4 11.4 2004 12.2 12.4 12.2 2005 12.1 12.5 12.0 2006 12.4 11.9 11.8 2007 12.8 12.5 12.6 2008 13.0 12.3 12.4 2009 12.4 12.2 12.2 4-14 The historical trending of the average quarterly exposures at the special interest areas for the past 23 years is provided in Figure 4.3-2 and listed in Table 4.3-2. These exposures are within the range of those acquired at the other stations.

They too, show that the plant is not contributing significantly to direct radiation at the special interest areas.Figure 4.3-2 Average Quarterly Exposure from Direct Radiation at Special Interest Areas25-20O M 15 1t:q- A 01 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 Year 1-'--- Roadside Park (Sta 064) ---- Toombs Central School (Sta 301)4-15 Table 4.3-2 Average Quarterly Exposure from Direct at Special Interest Areas Radiation Period Station 064 Station 301 (mR) (mR)1986 14.6 15.1 1987 14.2 15.0 1988 14.9 15.3 1989 16.1 16.6 1990 15.1 14.4 1991 14.4 15.2 1992 11.1 11.5 1993 11.2 10.8 1994 10.4 10.7 1995 11.0 10.5 1996 11.7 11.0 1997 12.6 11.4 1998 12.4 11.8 1999 12.5 12.4 2000 13.3 12.6 2001 11.8 11.3 2002 11.4 11.4 2003 11.2 11.1 2004 11.9 12.3 2005 11.8 12.4 2006 11.9 11.6 2007 11.9 12.1 2008 12.3 12.2'"ý"2009 12.1 1n 2.1 In 2009, there were four deviations involving direct radiation measurements.

In the first quarter, the TLDs at Station 110 were destroyed in a fire. In the first quarter, TLD 301B had water in the holding bag. In third quarter, the TLDs at Station 114 were found on the ground at collection time. The results passed Chauvenet's Criterion for the affected stations in first and third quarters and were retained in the data set. In fourth quarter, the TLDs at Station 102 and 104 were missing at midquarter and blanks were put in place. The results were determined not to be representative and were excluded from the data summary. Also in fourth quarter, TLD results for 215B and 216A were lost due to a mechanical reader problem. The companion badge results were used in the data summary.4-16 The standard deviation for the quarterly result for each badge was subjected to a self-imposed limit of 1.4. This limit is based upon the standard deviations obtained with the Panasonic UD-814 badges during 1992 and is calculated using a method developed by the American Society of Testing and Materials (ASTM Special Technical Publication 15D, ASTM Manual on Presentation of Data and Control Chart Analysis, Fourth Revision, Philadelphia, PA, October 1976).The limit serves as a flag to initiate an investigation.

To be conservative, readings with a standard deviation greater than 1.4 are excluded from the data set since the high standard deviation is interpreted as an indication of unacceptable variation in TLD response.

In 2009, the following TLD results were excluded from the data set because their standard deviations were greater than 1.4: First Quarter None Second Quarter None Third Quarter None Fourth Quarter None If one badge at a station exhibited a standard deviation greater than 1.4, then the reading of the companion badge at each location would be used to determine the quarterly exposure.

The badges exceeding the self-imposed limit would be visually inspected under a microscope and the glow curve and test results for the anneal data and the element correction factors would be reviewed.4-17 4.4 Milk Milk samples are obtained biweekly from Station 304 (the state prison dairy)which is a control station located more than 10 miles from the plant. Gamma isotopic and 1-131 analyses are performed on each sample as specified in Tables 2-1 and 2-2. Since 1989, efforts to locate a reliable milk sample source within 5 miles of the plant have been unsuccessful.

During 2009, no man-made radionuclides were detected from the gamma isotopic analysis of the milk samples. Cesium-137 was found in most of the samples each year from 1978 (when this analysis became a requirement) through 1989. No other man-made radionuclides have been detected by this analysis.The MDC and RL for Cs-137 in milk are 18 and 70 pCi/l, respectively.

The historical trending of the average annual detectable Cs-137 concentration in milk is provided in Figure 4.4-1 and Table 4.4-1.Figure 4.4-1 Annual Cs-137 Concentration in Milk 25 20"" 15 0.10 0 0 qo Year$ -Indicator -U--Control MDCI 4-18 Table 4.4-1 Average Annual Cs-137 Concentration in Milk Year Indicator Control (pCE ) [ Pre-op 19.9 19.4 1974 NDM ,NDM 1975 NDM NDM 1976 NDM NDM 1977 NDM NDM 1978 12.1 18.3 1979 16.1 13 1980 14.7 15.4 1981 12.57 10.2 1982 11.8 11 1983 12 7.2 1984 9.6 10.2 1985 9.14" 5.35 1986 9.8 10 1987 NDM NDM 1988 10.9 NDM 1989 8.6 7.9 1990 NDM NDM 1991 NDM NDM 1992 NDM NDM 1993 NDM NDM 1994 NDM NDM 1995 NDM NDM 1996 NDM NDM 1997 NDM NDM 1998 NDM NDM 1999 NDM NDM 2000 NDM NDM 2001 NDM NDM 2002 NDM NDM 2003 NDM NDM 2004 NDM NDM 2005 NDM NDM 2006 NDM NDM 2007 NDM NDM 2008 NDM NDM 2009 ___________

N~D4-19 During 2009, 1-131 was not detected in any of the milk samples. During preoperation, all readings were less than 2 pCi/I which was the allowed MDC at that time. Figure 4.4-2 and Table 4.4-2 provide the historical trending of the average annual detectable concentration of 1-131 in milk. In 1988, a single reading of 0.32 pCi/l, which was believed to have resulted from a procedural deficiency, was reported.

The MDC and RL for 1-131 in milk are 1 and 3 pCi/l, respectively.

All the detectable results for Cs-137 and 1-131 are attributed to fallout from the nuclear weapons tests and the Chernobyl incident.Figure 4.4-2 Average Annual 1-131 Concentration in Milk S S10 C 0 C 6 0 0 I- I-l Year---indicator -UN-Control -MDC ýR:L: 4-20 Table 4.4-2 Average Annual 1-131 Concentration in Milk Year Indicator Control (pCi/l) [ (pC~il)Pre-op NDM NDM 1974 0.98 2.6 1975 0.3 NDM 1976 12.23 9.1 1977 14.61 4.08 1978 2.72 4.18 1979 NDM NDM 1980 1.26 0.69 1981 NDM NDM 1982 NDM NDM 1983 NDM NDM 1984 NDM NDM 1985 NDM NDM 1986 8.9 7.6 1987 NDM NDM 1988 NDM 0.32 1989 NDM NDM 1990 NDM NDM 1991 NDM NDM 1992 NDM NDM 1993 NDM NDM 1994 NDM NDM 1995 NDM NDM 1996 NDM NDM 1997 NDM NDM 1998 NDM NDM 1999 NDM NDM 2000 NDM NDM 2001 NDM NDM 2002 NDM NDM 2003 NDM NDM 2004 NDM NDM 2005 NDM NDM 2006 NDM NDM 2007 NDM NDM 2008 NDM NDM 2009 NDM NDM 4-21

4.5 Vegetation

In accordance with Tables 2-1 and 2-2, grass samples are collected monthly from two indicator stations near the site boundary (Nos. 106 and 112) and at one control station located about 21 miles from the plant (No. 416). Gamma isotopic analyses are performed on each sample. Gamma isotopic analysis on vegetation samples began in 1978 when the analysis became a TS requirement.

The results presented in Table 3-1 show that Cs-137 was the only man-made radionuclide detected in vegetation samples during 2009. Cs-137 was detected in 12 samples of the 24 samples collected at the indicator stations at an average value of 46.8 pCi/kg-wet.

No-samples collected at the control station had detectable Cs-137. The Cs-137 seen at the indicator stations could potentially be attributed to plant effluents.

Since 1986, Cs-137 has been the only man-made radionuclide found in vegetation samples. The MDC and RL for Cs-137 in vegetation samples are 80 pCi/kg-wet and 2000 pCi/kg-wet, respectively.

The occasional presence of Cs-137 in vegetation samples is attributed primarily to fallout from nuclear weapons tests and the Chernobyl incident.Figure 4.5-1 and Table 4.5-1 provide the historical trending of the average annual detectable Cs-137 concentration found in vegetation.

Since 1978, the Cs-137 concentration has been on a decline, and since about 1989, generally occurring below the required MDC.4-22 Figure 4.5-1 Average Annual Cs-137 Concentration in Vegetation 1200 1000 4-800 600 0 400 200 0 I =11111111111111 Alb (ýYear s---Indicator -U--Control -MDC 4-23 Table 4.5-1 Average Annual Cs-137 Concentration in Vegetation Year Indicator Control (pCi/kg-wet) (pCi/kg-wet)

Pre-op 55 30 1974 NDM NDM 1975 NDM NDM 1976 NDM NDM 1977 NDM NDM 1978 112 1089 1979 59 695 1980 208 916 1981 182 152 1982 65 99 1983 95 211 1984 149 388 1985 60.9 113.3 1986 80 215 1987 60 428 1988 40.1 228.8 1989 37 NDM 1990 66.7 34.5 1991 34.1 36.1 1992 35.2 41.3 1993 24.7 45.8 1994 32.2 46.6 1995 49.8 47.6 1996 47.2 41.1 1997 48.4 54.9 1998 81.4 44.1 1999 26.9 NDM 2000 NDM NDM 2001 NDM NDM 2002 33.7 41.1 2003 61.0 62.8 2004 41.6 43.5 2005 47.7 39.8 2006 66.8 29.6 2007 55.7 31.1 2008 41.8 38.1_____...._2009__

46.8 __________DM_

4-24 4.6 River Water Surface water, from the Altamaha River is obtained at an upstream location (Station 170) and at a downstream location (Station 172) using automatic samplers.

Small quantities are drawn at intervals not exceeding a few hours. The samples drawn are collected monthly and quarterly composites are produced from the monthly collections.

As specified in Table 2-1, a gamma isotopic analysis is conducted on each monthly sample. No man-made gamma emitters were detected during 2009. The only man-made gamma emitters previously detected are presented in the table below.Year Quarter Station Radionuclide Level I I I I (pCi/I)1975 4th 172 Ce-141 78.2 1986 2nd 170 La- 140 18.0 1986 2nd 172 Cs-137 12.0 1988 2nd 170 Cs-137 6.8 A tritium analysis is performed on the quarterly composite.

Prior to 1986, positive results were usually found in each quarterly composite at levels generally ranging from 200 and 350 pCi/1 which is approximately background environmental levels.Subsequently, the number of positive results have diminished.

In 2009, tritium was detected in one of the four quarterly samples at the upstream (control) location and in one of the four quarterly samples at the downstream (indicator) location.

The single positive value at the indicator station was 242 pCi/l. The single positive value at the control station was 343 pCi/l. The low levels detected at both the indicator and control stations are essentially environmental background levels (typically 350 pCi/L +/- 250 pCi/L). The MDC and RL for tritium in river water are 3000 and 30,000 pCi/l, respectively.

Figure 4.6-1 and Table 4.6-1 provide the historical trending of the annual average detectable tritium concentration in river water.The annual 50 mile downstream survey of the Altamaha River to determine if river water is being withdrawn for drinking purposes is discussed in Section 4.1.4-25 Figure 4.6-1 Average Annual H-3 Concentration in River Water 3500 3000" 2500 C., 2000 0 4-0)1000 500 0 q0&I MJim Alb -<% Aq 19, 0 Year I-*Indicator -UJ-Control -MDCI 4-26 Table 4.6-1 Average Annual H-3 Concentration in River Water Year Indicator Control (pCi/i) (pCi/1)Pre-op 210 191 1974 230 205 1975 205 238 1976 165 153 1977 189 170 1978 224 193 1979 210 180 1980 358 218 1981 220 135 1982 165 220 1983 265 328 1984 437 327 1985 288 220 1986 242 206 1987 241 204 1988 220 NDM 1989 NDM NDM 1990 139 NDM 1991 NDM NDM 1992 NDM NDM 1993 NDM NDM 1994 NDM NDM 1995 200 NDM 1996 144 147 1997 NDM NDM 1998 NDM NDM 1999 NDM NDM 2000 209 NDM 2001 NDM NDM 2002 NDM NDM 2003 NDM 261 2004 206 302 2005 245 NDM 2006 299 NDM 2007 235 338 2008 329 298 2009 242 343 4-27 4.7 Fish Gamma isotopic analyses were performed on the edible portion of the fish samples collected at the river stations on June 8, 2009 (no fish were collected during the second semi-annual period due to high river water level). The control station (No.170) is located upstream of the plant while the indicator station (No. 172) is located downstream.

As shown in Table 3-1, Cs-137 was the only man-made radionuclide detected in fish during 2009. The concentration of 12.4 pCi/kg-wet at the indicator station was 4 pCi/kg-wet more than the concentration found at the control station (8.4 pCi/kg-wet).

Cs-137 in fish samples is attributed primarily to weapons testing and the Chernobyl incident.

However, the Cs-137 seen in the fish samples at the indicator station could be attributed to plant effluents.

The MDC and RL for Cs-137 in fish are 150 and 2000 pCi/kg-wet, respectively.

The historical trending of the average annual detectable Cs-137 concentration in fish is provided in Figure 4.7-1 and Table 4.7-1. Figure 4.7-1 indicates, in general, a decline in the Cs-137 levels after 1983. (Note: From 1979 through 1982, clams were collected rather than fish.)Figure 4.7-1 Average Annual Cs-137 Concentration in Fish 160-140-4 )120- -------------------100 80 40-0 Year-4 Indicator Control -MDC 4-28 Table 4.7-1 Average Annual Cs-137 Concentration in Fish Year Indicator Control (pCi/kg-wet) (pCi/kg-wet)

Pre-op 90 115 1974 134 61 1975 80.6 89.4 1976 73 88 1977 76 91 1978 88 47 1979 NDM NDM 1980 NDM NDM 1981 NDM NDM 1982 NDM NDM 1983 138.6 67.5 1984 84 53 1985 117 63.3 1986 79 44 1987 62 52 1988 77.8 33.3 1989 34.3 28.9 1990 26.7 24.2 1991 32.9 26.9 1992 41.6 28.8 1993 38.0 25.9 1994 23.8 20.7 1995 25.0 27.9 1996 20.4 18.0 1997 29.4 15.1 1998 26.1 17.7 1999 22.3 13.5 2000 17.9 25.3 2001 20.8 10.2 2002 18.2 13.0 2003 13.1 7.1 2004 11.6 18.8 2005 13.0 13.3 2006 10.4 13.5 2007 6.8 9.8 2008 19.9 8.4 2009 12.4 18.4 4-29 In the past, the only other man-made radionuclides detected in fish samples were Co-60 and Cs-134. During preoperation, Co-60 was detected in one fish sample at a very low concentration.

During the period of 1983 through 1988, Cs-134 was found in about half of the samples at concentrations of the same order of magnitude as those found for Cs-137.The Co-60 and Cs-134 levels found in these samples are attributed to the nuclear weapons tests and the Chernobyl incident.

Figure 4.7-2 and Table 4.7-2 show the historical trending of the annual average detectable concentration of Cs- 134 in fish.Figure 4.7-2 Average Annual Cs-134 Concentration in Fish 160 ----140 --120-0)60-4 0-----20-I , 01 Year-4-Indicator Q- Control -MDC 4-30 Table 4.7-2 Average Annual Cs-134 Concentration in Fish Year Indicator Control (pCi/kg-wet) (pCi/kg-wet)

Pre-op NDM NDM 1974 NDM NDM 1975 NDM NDM 1976 NDM NDM 1977 NDM NDM 1978 NDM NDM 1979 NDM NDM 1980 NDM NDM 1981 NDM NDM 1982 NDM NDM 1983 101.8 NDM 1984 35.8 26.3 1985 46.7 21.1 1986 29 NDM 1987 69 15 1988 21.7 6.9 1989 NDM NDM 1990 NDM NDM 1991 NDM NDM 1992 NDM NDM 1993 NDM NDM 1994 NDM NDM 1995 NDM NDM 1996 NDM NDM 1997 NDM NDM 1998 NDM NDM 1999 NDM NDM 2000 NDM NDM 2001 NDM NDM 2002 NDM NDM 2003 NDM NDM 2004 NDM NDM 2005 NDM NDM 2006 NDM NDM 2007 NDM NDM 2008 NDM NDM 2009 NDM NDM 4-31 4.8 Sediment Sediment was collected along the shoreline of the Altamaha River on May 4 and November 2, 2009, at the upstream control station (No. 170) and the downstream indicator station (No. 172). A gamma isotopic analysis was performed on each sample.Co-60 was not found in sediment samples in 2009. With the exception of a few years, Co-60 has been found at either the indicator or the control station every year since 1986. There is no RL or MDC assigned to Co-60 in sediment in ODCM Tables 4-2 and 4-3 (Tables 4-2 and 4-1 of this report). The MDC assigned by the EL for Co-60 in sediment is 70 pCi/kg-dry.

The historical trending of the average annual detectable Co-60 concentration in sediment is provided in Figure 4.8-1 and Table 4.8-1.Figure 4.8-1 250200 15O 0-100 0 U s Average Annual Co-60 Concentration in Sediment I / I Ai I..........H- .. ....01!11 0 qo Alb Kx A% ltý 0 Year--Indicator -U- Control MC 4-32 Table 4.8-1 Average Annual Co-60 Concentration in Sediment Year Indicator Control (pCi/kg-dry) (pCi/kg-dry)

Pre-op NDM NDM 1974 NDM NDM 1975 NDM NDM 1976 NDM NDM 1977 NDM NDM 1978 NDM NDM 1979 NDM NDM 1980 NDM NDM 1981 NDM NDM 1982 NDM NDM 1983 NDM NDM 1984 NDM NDM 1985 NDM NDM 1986 108 33 1987 NDM NDM 1988 67.8 NDM 1989 NDM 31 1990 33 19 1991 123.6 NDM 1992 81.4 NDM 1993 70.7 NDM 1994 218 NDM 1995 NDM NDM 1996 118.5 NDM 1997 NDM NDM 1998 79.4 NDM 1999 107.7 NDM 2000 70.0 NDM 2001 58.1 NDM 2002 NDM NDM 2003 NDM 31.5 2004 NDM NDM 2005 NDM NDM 2006 NDM NDM 2007 NDM NDM 2008 NDM NDM 2009 NDM NDM 4-33 Co-60 was not detected in sediment samples near the plant until 1986, the year of the Chernobyl incident.

However, because Co-60 was detected in indicator station samples more often than in control station samples during the years 1986 through 2002, some contribution from plant effluents cannot be ruled out. Co-60 has not been detected in either control or indicator station samples since 2004.In 2009, Cs-137 was detected in both indicator and control station sediment samples. It has been found in over 95% of all of the sediment samples collected back through preoperation, and is generally attributed to the atmospheric nuclear weapons tests or to the Chernobyl incident.

As shown in Table 3-1, the average at the indicator station was 74.9 pCi/kg-dry and the average at the control station was 60.5 pCi/kg-dry.

The difference between the indicator and control stations (14.4 pCi/kg-dry) is not statistically discernible since it is less than the MDD of 354 pCi/kg-dry.

The MDC for Cs-137 in sediment is 180 pCi/kg-dry.

The historical trending of the average annual detectable Cs-137 concentration in sediment is provided in Figure 4.8-2 and Table 4.8-2.Figure 4.8-2 C", CL 0 o.C 1000 900 800 700 600 500 400 300 200 Average Annual Cs-137 Concentration in Sediment I/ v 11ýK.LI 100 0 to: Alb -1( A% qtq0 Year--$ Indicator -U11---Control -MDCI 4-34 Table 4.8-2 Average Annual Cs-137 Concentration in Sediment Year Indicator Control (pCi/kg-dry) (pCi/kg-dry)

Pre-op 170 270 1974 218 57 1975 330 615 1976 211 300 1977 364 200 1978 330 260 1979 NDM 310 1980 240 NDM 1981 590 110 1982 141 285 1983 384 365 1984 500 260 1985 76.5 269 1986 238 190 1987 59 39 1988 903 114 1989 56 62 1990 130.5 66 1991 43.1 54.5 1992 151 198.5 1993 113 115 1994 127 104 1995 52.3 80.6 1996 106 110 1997 186 137 1998 148.5 101.4 1999 92 111.8 2000 68.1 114.5 2001 68.7 69.6 2002 68.1 62.8 2003 57.3 106 2004 59.5 57.1 2005 57.2 30.3 2006 85.2 79.2 2007 82.1 71.6 2008 112.7 61.9 2009 74.9 :,060.5 4-35 Other man-made nuclides, besides Co-60 and Cs-137, were occasionally found in past years. Their presence was generally attributed to the nuclear weapons tests or to the Chemobyl incident, although plant releases were not ruled out. Mn-54, Co-58, and Zn-65, which have relatively short half-lives, are most likely a result of plant releases and have been plotted in Figure 4.8-3 along with their MDCs. All the man-made nuclides detected in sediment except for Co-60 and Cs-137 have been listed in Table 4.8-3. The Cs-134 MDC (150 pCilkg-dry) is defined in ODCM Table 4-3 (Table 4-1 of this report). The MDCs for Mn-54 (42 pCi/kg-dry) and Zn-65 (129 pCi/kg-dry) were determined by the EL since no values are provided in ODCM Table 4-3.Figure 4.8-3 600 500 400 C.C 300.2~5 200 U.) 100 Average Annual Indicator Station Concentrations of Select Nuclides in Sediment/ l lI I \ /_I fit If 1 1 i[A 1 X 11 0 q 0'0 '< ý' 9 0 IbA # clý4b Year-4-Mrv-54 -I- Z n-65 ~C s-1 34-Mn-MDC -Zn-MDC -Cs-MDC 4-36 Table 4.8-3 Sediment Nuclide Concentrations Other Than Co-60 & Cs-137 Nuclide YEAR Indicator Control (pCi/kg-dry) (pCi/kg-dry)

Ce-141 1976 340 254 1977 141 Ce-144 Preop 720 1974 363 1975 342 389 1978 700 1981 1290 Co-58 1994 22.2 Cs-134 Preop 40 1981 280 1984 130 40 1986 132 1988 505 1990 31 Mn-54 1975 36.1 1986 28 26 1991 57.2 1996 77.7 Ru-103 1974 81 1976 158 1977 195 1981 220 Zn-65 1986 175 1988 136 1991 250.5 1992 83 1993 39.9 1994 332 Zr-95 Preop 180 1974 138 1976 427 170 1977 349 294 1978 220 230 1981 860 280 4-37

4.9 Groundwater

As nuclear plants began to undergo decommissioning in' the late 1990's to early 2000s, instances of subsurface and/or groundwater contamination were identified.

In addition, several operating facilities also identified groundwater contamination resulting from spills and leaks or equipment failure. In one instance, low levels of licensed material were detected in a private well located on property adjacent to a nuclear power plant.In 2006, NEI (Nuclear Energy Institute) formed a task force to address monitoring onsite groundwater for radionuclides at nuclear facilities.

A Groundwater Protection Initiative was developed which was adopted by all U.S. commercial operating nuclear plants.The NRC also formed a task force to study the groundwater issues and released Information Notice 2006-13 "Ground-water Contamination due to Undetected Leakage of Radioactive Water" which summarized its review of radioactive contamination of ground water at multiple facilities as a result of undetected leakage from structures, systems, or components that contain or transport radioactive fluids. Licensees were instructed to review the information for applicability and to consider appropriate actions to avoid similar problems.The NEI task force felt it was prudent for the industry to update site hydrology information and to develop radiological groundwater monitoring plans at each site.These groundwater protection plans would ensure that underground leaks and spills would be addressed promptly.

Additionally, the task force recommended developing a communications protocol to report radioactive leaks or spills that entered groundwater (or might eventually enter groundwater) to the NRC and State and Local government officials as needed.Southern Nuclear developed a company-wide communications protocol which is contained in the Nuclear Management Procedure, Actions for Potential Groundwater Contamination Events, to ensure radioactive leaks and spills would be addressed and communicated appropriately.

The guidance in this procedure is used to informally update both the NRC and the State of Georgia regarding the changes in Hatch's groundwater tritium concentrations.

Plant Hatch has monitored onsite groundwater since preoperation.

Initially piezometers, which were installed prior to plant construction, were used to monitor groundwater.

In the late 1970s to the early 1980s timeframe, a hydrological engineering consultant was hired to evaluate several areas where leaks had occurred and tritium had been detected in onsite wells. The consultant recommended drilling additional monitoring wells to study the groundwater movement, to determine the source of the leaks, and to track the tritium concentrations in groundwater.

In the late 1970s through the mid 1980s, Hatch reported groundwater results to the NRC. The reporting frequency was decreased for several reasons -the areas where the groundwater showed tritium were all onsite and the movement of groundwater was extremely slow and in a direction (towards the river) that was not expected to impact the public. Although the reports are no longer made on a routine basis, Plant Hatch has continued to monitor onsite groundwater wells for tritium on a scheduled frequency.

4-38 In 2006 as the nuclear industry was moving towards establishing groundwater monitoring programs, Plant Hatch hired a hydrological engineering consultant to re-evaluate the groundwater study which had been done previously.

The key purpose of the new study was to evaluate the adequacy of the current monitoring program and to diagram the existing groundwater tritium plume to ensure that the plume had not migrated offsite. The consultant concluded that tritium was not leaving the site through the groundwater.

The consultant recommended installing additional monitoring wells to better characterize the groundwater plume in areas of the site where there were no existing wells.During the course of Plant Hatch's groundwater evaluation in 2006, some leaks were discovered which explained why the levels of tritium around CST-1 (Unit 1 Condensate Storage Tank) were not decreasing.

Underground piping which carried radioactive liquids was evaluated over the plant site and replaced in some areas around CST-1. Both CST tank/pump moats (Unit 1 and Unit 2) were coated and sealed to ensure that moats would not leak in the event of transfer pump or tank leaks.In 2006, Plant Hatch's groundwater monitoring program included over 50 location points which were sampled on weekly, monthly, quarterly, or annual frequencies (see maps at the end of this section).

Included in these sample points were the onsite drinking water wells. They did not contain detectable amounts of radioactivity.

Surface drains or outfalls were also included as sample points.Tritium was detected in two of the outfalls which discharged to the river. These outfalls were initially added to the Hatch ODCM as radiological effluent release points. Permitted release point Y22N008A (by design) discharges groundwater from the site subsurface drainage system which includes the tritiated groundwater around the CST-1. The other release point, Y22N003A, discharges runoff from the roof drains. The source of tritium in this outfall has been determined to be from rain washout of the gaseous plant effluents and is no longer a permitted release point. Plant Hatch sampled rainfall during two rain events in 2006 and found tritium levels as high as 4.58E5 pCi/1 on the reactor building roof. Two other outfalls, Y22N024A and Y22N025A, which discharge into the onsite swamp show sporadic levels of tritium. The source of tritium in these outfalls is also believed to be from rain washout.In 2007, Hatch continued to aggressively monitor the groundwater tritium plume especially in two areas of higher activity around CST-1 and CST-2. The amount of seasonal rainfall during 2007 seems to have had some correlation with the tritium concentrations in the T- 12 well near CST- 1. During early spring and late fall rainy seasons, the concentrations of tritium were at their highest levels, whereas, during the summer and early fall drought season the tritium concentrations decreased significantly.

This is indicative of water table level fluctuations.

However, this same seasonal affect was not observed in the newer NW1O monitoring well installed in 2006 near CST-2. The tritium concentration in NW1O increased from February 2007 through September 2007 by a factor of 2.5. Events which could have contributed to the increase were a CST-2 transfer pump leak (in November 2006) which led to an accumulation of a couple feet of CST-2 water in the pump moat. Although the moat had been sealed earlier in 2006, there was a possibility that some of the contaminated water seeped through the concrete moat and gradually seeped through the ground to NW1O. In addition, there was a deep hole dug (in January 2007) near the CST-2 (and NW1O) to replace some CST-2 piping. The hole may have altered groundwater flow toward NW1O from the CST-1 groundwater plume and resulted in higher concentrations of tritium being drawn to NW1O.4-39 In 2008, Hatch made further enhancements to the groundwater tritium monitoring program. Three additional shallow wells and three additional deep wells were installed

("R" series wells). One of the deep wells was a replacement well for the deep well N7A. The integrity of N7A was questioned due to the high level of tritium (-211,000 pCi/1) seen in this well which should have been protected from contamination by a confining layer. The well was retired and a new well (R-3) was placed in the same vicinity.

The newer well showed much smaller amounts of tritium activity (average of 2180 pCi/l for the last three quarters of 2008).In addition, several other groups within Southern Company are now utilized to conduct an improved sampling program and to provide additional expertise in characterizing groundwater quality and flow. The sampling frequency for radiological groundwater monitoring was officially changed to quarterly starting in second quarter of 2008 with SCS Civil Field Services performing the sampling and Georgia Power Environmental Laboratory continuing to analyze the samples.Over the past couple of years, SNC Corporate Engineering and Hatch Site Engineering have developed the Buried Piping and Tanks Inspection Program.This program should help to prevent releases-of radioactive material to groundwater.

Underground piping and components are risked ranked using detailed procedures and EPRI's software, BPWorks, to ensure vulnerable areas are identified and repaired or replaced before problems occur.The latest groundwater tritium plume map (generated from the 2009 SCS sampling data) is shown on the following page. It is a representation of the current groundwater conditions at Plant Hatch. The wells of interest around the CSTs had the following average tritium concentrations from the. 4 quarters of sampling in 2009: T-12, near CST-1, averaged approximately 295,000 pCi/1 of tritium (down from an average of 650,000 pCi/1 for the 3 quarters sampled by SCS in 2008) and NW1O, near CST-2, averaged 75,400 pCi/1 of tritium (down from an average of 116,000 pCi/i for the 3 quarters sampled by SCS in 2008).In May of 2009, there was an increase in tritium concentration in well T-3 (located near the U-1 Turbine Building) from approximately 2600 pCi/1 to approximately 37,000 pCi/1. Neighboring well N9B (not part of the formal GW sampling program) also showed an approximate 1oX increase -going from 1300 pCi/1 to over 10K pCi/l. Investigation found no process leaks and the non-rad constituents continued to match groundwater.

The increase was attributed to migration of the plume. Increased rainfall and the fact that the wells are located near the subsurface drain could likely have facilitated the pathway of the plume towards the T3 well.A courtesy notification was made to the State of Georgia Dept. of Natural Resources and a 1OCFR50.72 formal report was made to the NRC -although only courtesy notifications were required per procedure.

The tritium concentration in T3 continues to decrease and was down to approximately 7000 pCi/1 in November.N9B has not been routinely sampled since the major decline in tritium has been observed in T3 but will be sampled again in 2010 to confirm that tritium levels have declined'.

No tritium activity above backgrourdd was seen in the Deep Wells 2 and 3 which are .used for drinking water at the plant. The plant staff continues to sample and monitor strategically located wells on a more frequent basis than quarterly to ensure that radiological leaks have not occurred.

In addition, outfalls, pull boxes, manholes, and the sewage treatment plant effluent are sampled by the plant staff on a periodic basis.4-40 CONCENTRATION DATA PCiIL M1> 1.00E + 06 5.00E + 05 -1.OOE + 06 1.OOE + 05 -5.OOE + 05 5.00E + 04 -1.00E + 05 2.OOE + 04 -5.OOE + 04 1.OOE + 04 -2.OOE + 04 1.OOE + 03 -1.OOE + 04 3.OOE + 02 -1.OOE + 03 LEGEND: NW90 Unconfined Perched Aquifer Tritium Source Detection Monitoring Well-Approximately Located French Drain & Flow< MDA Less Than Minimum Detectable Activity NS Not Sampled 200 I 0 100 200 I I I 400 ,1O Southern Company Generation Engineering and Construction Services FOR Southern Nuclear Company Southern coay Senrcee krc Copygt c 2010. Southern Company Wc. An MRghts RAwved This document contoirs proprietky, confdutial, and/or trod. secrt informaton of the subsidieries of The Southern Company or of th*d poattes. It is itended for use only by empoye of, or authorized contractors of, the susidlorie of the Southern Company. Unauthorized poesemon, use, distribution, copying, dWssmation, or disclosure of any portion hereof is prohibited.

PLANT HATCH UNCONFINED PERCHED AQUIFER NOVEMBER 2009 FIGURE 4.9-1 PROJ ID.DRAWING NUMBER ISHEET I oN-rD IREv 1 ~FINAL~ 0 4-41 5.0 INTERLABORATORY COMPARISON PROGRAM In accordance with ODCM 4.1.3, the EL participates in an ICP that satisfies the requirements of Regulatory Guide 4.15, Revision 1, "Quality Assurance for Radiological Monitoring Programs (Normal Operations)

-Effluent Streams and the Environment", February 1979. The guide indicates the ICP is to be conducted with the Environmental Protection Agency (EPA) Environmental Radioactivity Laboratory Intercomparison Studies (Cross-check)

Program or an equivalent program, and the ICP should include all of the determinations (sample medium/radionuclide combinations) that are offered by the EPA and included in the REMP.The ICP is conducted by Analytics, Inc. of Atlanta, Georgia. Analytics has a documented Quality Assurance (QA) program and the capability to prepare Quality Control (QC) materials traceable to the National Institute of Standards and Technology.

The ICP is a third party blind testing program which provides a means to ensure independent checks are performed on the accuracy and precision of the measurements of radioactive materials in environmental sample matrices.Analytics supplies the crosscheck samples to the EL which performs the laboratory analyses in a normal manner. Each of the specified analyses is performed three times. The results are then sent to Analytics who performs an evaluation which may be helpful to the EL in the identification of instrument or procedural problems.The samples offered by Analytics and included in the EL analyses are gross beta and gamma isotopic analyses of an air filter; gamma isotopic analyses of milk samples; and gross beta, tritium and gamma isotopic analyses of water samples.The accuracy of each result is measured by the normalized deviation, which is the ratio of the reported average less the known value to the total error. The total error is the square root of the sum of the squares of the uncertainties of the known value and of the reported average. The uncertainty of the known value includes all analytical uncertainties as reported by Analytics.

The uncertainty of the reported average is the propagated error of the values in the reported average by the EL.The precision of each result is measured by the coefficient of variation, which is defined as the standard deviation of the reported result divided by the reported average. An investigation is undertaken whenever the absolute value of the normalized deviation is greater than three or whenever the coefficient of variation is greater than 15% for all radionuclides other than Cr-51 and Fe-59. For Cr-51 and Fe-59, an investigation is undertaken when the coefficient of variation exceeds the values shown as follows: Nuclide Concentration

• Total Sample Activity Percent Coefficient (pCi) of Variation Cr-51 <300 NA 25 Cr-51 NA >1000 25 Cr-51 >300 <1000 15 Fe-59 <80 NA 25 Fe-59 >80 NA 15* For air filters, concentration units are pCi/filter.

For all other media, concentration units are pCi/liter (pCi/1).5-1 As required by ODCM 4.1.3.3 and 7.1.2.3, a summary of the results of the EL's participation in the ICP is provided in Table 5-1 for: the gross beta and gamma isotopic analyses of an air filter; gamma isotopic analyses of milk samples; and gross beta, tritium and gamma isotopic analyses of water samples. Delineated in this table for each of the media/analysis combinations, are: the specific radionuclides; Analytics' preparation dates; the known values with their uncertainties supplied by Analytics; the reported averages with their standard deviations; and the resultant normalized deviations and coefficients of variation expressed as a percentage.

The EL analyzed 9 samples for 35 parameters in 2009. These analyses included tritium, gross beta and gamma emitting radio-nuclides in different matrices.

The attached results indicate all analyses are acceptable for precision and one analysis outside the acceptance limits for accuracy.

The activity recovery of Fe-59 in air filter was above the upper acceptance limit for accuracy.The analysis of Fe-59 is performed by gamma spectroscopy, with the value determined by a weighted average of the three germanium detectors.

In a 2005 investigation a positive bias was determined to exist in the analysis based on summing of nuclides in the calibration standard.

The detectors are calibrated on a three year geometry rotation.

The air filter geometry calibration is scheduled and will be completed in 2010. The 2009 sample will be reanalyzed with the new calibration to verify calibration accuracy.5-2 TABLE 5-1 (SHEET 1 of 3)INTERLABORATORY COMPARISON PROGRAM RESULTS GROSS BETA ANALYSIS OF AN AIR FILTER (pCi/filter)

Analysis or DtReoed K wnStandard Uncertainty Percent Coef Normalized Radionuclide Prepared Average Value Deviation EL Analytics (3S) of Variation Deviation Gross Beta 09/17/09 85.00 85.80] 1.68[ 0.481 5.21 ] -0.19 GAMMA ISOTOPIC ANALYSIS OF AN AIR FILTER (pCi/filter)

Analysis or Date Reported Known Standard Uncertainty Percent Coef Normalized Radionuclide Prepared Average Value Deviation EL Analytics (3S) of Variation I Deviation Ce-141 09/17/09 204.10 193.00 8.07 1.08 5.02 1.08 Co-58 09/17/09 75.60 69.90 3.81 0.39 7.23 1.05 Co-60 09/17/09 117.10 113.00 2.15 0.63 3.78 0.92 Cr-51 09/17/09 194.50 155.00 2.1 0.86 13.61 1.49 Cs-134 09/17/09 83.90 86.50 1.48 0.48 3.99 -0.77 Cs-137 09/17/09 142.40 130.00 4.01 0.72 4.46 1.95 Fe-59 09/17/09 131.30 103.00 6.51 0.58 6.86 3.14 Mn-54 09/17/09 160.10 145.00 0.86 0.81 3.44 2.74 Zn-65 09/17/09 176.20 143.00 7.22 0.80 6.35 2.97 GAMMA ISOTOPIC ANALYSIS OF A MILK SAMPLE (pCi/liter)

Analysis or Date Reported Known Standard Uncertainty Percent Coef Normalized Radionuclid Prepared Average Value Deviation EL Analytics (3S) of Variation Deviation Ce- 141 06/18/09 286.50 284.00 22.86 1.58 8.94 0.10 Co-58 06/18/09 97.40 91.90 3.44 0.51 8.17 0.69 Co-60 06/18/09 326.50 312.00 9.4 1.74 4.73 0.94 Cr-51 06/18/09 415.30 400.00 48.83 .2.23 15.87 0.23 Cs-134 06/18/09 178.10 166.00 6.63 0.92 5.65 1.20 Cs-137 06/18/09 205.20 192.00 15.72 1.07 9.03 0.71 TABLE 5-1 (SHEET 1 of 3)INTERLABORATORY COMPARISON PROGRAM RESULTS GAMMA ISOTOPIC ANALYSIS OF A MILK SAMPLE (pCi/liter)

Analysis or Date Reported Known Standard Uncertainty Percent Coef Normalized Radionuclide Prepared Average Value [Deviation EL Analytics (3S) of Variation Deviation Fe-59 06/18/09 144.10 122.00 3.6 0.68 7.69 1.99 1-131 06/18/09 116.00 102.00 7.01 0.57 9.34 1.29 Mn-54 06/18/09 138.80 137.00 17.49 0.76 13.97 0.09 Zn-65 06/18/09 194.90 175.00 3.54 0.98 8.45 1.21 GROSS BETA ANALYSIS OF WATER SAMPLE (pCi/liter)

GAMMA ISOTOPIC ANALYSIS OF WATER SAMPLES (pCi/liter)

Analysis or Date Reported Known Standard Uncertainty Percent Coef Normalized Radionuclide Prepared Average Value [Deviation EL Analytics (3S) of Variation Deviation Ce-141 03/19/09 119.10 120.00 9 0.67 9.54 -0.08 Co-58 03/19/09 145.30 151.00 9.04 0.84 8.18 -0.48 Co-60 03/19/09 193.70 180.00 4.54 1.00 4.44 1.60 Cr-51 03/19/09 406.90 387.00 12.63 2.15 9.69 0.50 Cs-134 03/19/09 122.20 119.00 6.96 0.66 7.42 0.35 TABLE 5-1 (SHEET 3 of 3)INTERLABORATORY COMPARISON PROGRAM RESULTS GAMMA ISOTOPIC ANALYSIS OF WATER SAMPLES (pCi/liter)

Analysis or Date Reported Known J Standard Uncertainty Percent Coef Normalized Radionuclide I Prepared Average Value Deviation EL Analytics (3S) of Variation Deviation Cs-137 03/19/09 152.00 141.00 9.57 0.79 8.05 0.90 Fe-59 03/19/09 142.00 127.00 2.78 0.70 6.68 1.58 1-131 03/19/09 76.10 69.00 3.21 0.38 7.95 1.18 Mn-54 03/19/09 179.10 162.00 3.05 0.90 4.90 1.95 Zn-65 03/19/09 210.40 197.00 4.72 1.10 6.91 0.92 TRITIUM ANALYSIS OF WATER SAMPLES (pCi/liter) 1-131 ANALYSIS OF AN AIR CARTRIDGE (pCi/cartridge)

Analysis or Date Reported Known Standard Uncertainty Percent Coef Normalized Radionuclide Prepared Average I Value I Deviation EL Analytics (3S) of Variation I Deviation 1-131 06/18/09 96.405 99.10 10.4 0.55] 11.94 7 -0.24

6.0 CONCLUSION

S This report confirms the licensee's conformance with the requirements of Chapter 4 of the ODCM. It provides a summary and discussion of the results of the laboratory analyses for each type of sample.In 2009, there were two instances where the indicator station results were statistically discernible from the control station results. This is discussed below.No discernible radiological impact upon the environment or the public as a consequence of plant discharges to the atmosphere and to the river was established for any other REMP samples.Cesium-137 was identified in 12 of 24 samples vegetation samples at the indicator stations and in none of the samples at the control station. The average of the positive samples at the indicator stations was 46.8 pCi/kg-wet.

The potential dose to a member of the public due (an adult) who would receive the highest dose due to regular consumption of vegetation containing the above level of Cs-137 would be 0.98 mrem in a year. This dose is less than 7% of the regulatory limit of 15 mrem per year to any organ due to gaseous effluents.

Cesium-137 was identified in the spring collection at both the indicator station and at the control station. The sample at the indicator station was 12.4 pCi/kg-wet and the sample at the control station was 8.4 pCi/kg-wet.

The potential dose to a member of the public who would receive the highest dose (an adult) due to regular consumption of fish containing Cs-137 would be 6.OOE-3 mrem in a year. This dose is approximately 0.2% of the regulatory limit of 3 mrem per year due to liquid effluents.

Low levels of Cs-137 in the environment are attributed primarily to fallout from nuclear weapons testing and from the Chernobyl incident.

However, the levels of Cs-137 seen at the indicator stations for vegetation, and for fish could potentially be attributed to plant effluents.

The radiological levels reported in 2009 were low and are generally trending downward.

The REMP trends over the course of time from preoperation to the present are decreasing or have remained fairly constant.

This supports the conclusion that there is no adverse radiological impact on the environment or to the public as a result of the operation of Hatch Nuclear Plant.6-1