ML19135A665

2018 Annual Radiological Environmental Operating Report

ML19135A665
Person / Time
Site:	Browns Ferry
Issue date:	05/15/2019
From:	Hughes D Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19135A665 (58)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 May 15, 2019 10 CFR 50.4 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

2018 Annual Radiological Environmental Operating Report In accordance with the Browns Ferry Nuclear Plant Technical Specification 5.6.2 and Offsite Dose Calculation Manual Administrative Control Section 5.1, the Tennessee Valley Authority is submitting the 2018 Annual Radiological Environmental Operating Report for Browns Ferry Nuclear Plant, Units 1, 2, and 3. Enclosed is the subject report for the period of January 1, 2018, through December 31 , 2018.

There are no new regulatory commitments contained within this letter. If you have any questions, please contact J. L. Paul at (256) 729-2636.

Enclosure:

2018 Annual Radiological Environmental Operating Report cc (w/Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant

Enclosure Browns Ferry Nuclear Plant Units 1, 2, and 3 2018 Annual Radiological Environmental Operating Report See Enclosed

2018 Annual Radiological Environmental Operating Report Tennessee Valley Authority Browns Ferry Nuclear Plant May 2019 Prepared under contract by Chesapeake Nuclear Services, Inc. and GEL Laboratories, LLC

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• I Laboratories LLc a member of The GEL Group INC

TABLE OF CONTENTS Executive Summary ....................................................................................................................................... 1 Introduction .................................................................................................................................................. 2 Naturally Occurring and Background Radioactivity .................................................................................. 2 Electric Power Production......................................................................................................................... 3 Site and Plant Description ............................................................................................................................. 5 Radiological Environmental Monitoring Program ........................................................................................ 7 Direct Radiation Monitoring ....................................................................................................................... 10 Measurement Techniques ...................................................................................................................... 10 Results ..................................................................................................................................................... 10 Atmospheric Monitoring............................................................................................................................. 13 Sample Collection and Analysis .............................................................................................................. 13 Results ..................................................................................................................................................... 13 Terrestrial Monitoring................................................................................................................................. 15 Sample Collection and Analysis .............................................................................................................. 15 Results ..................................................................................................................................................... 15 Liquid Pathway Monitoring......................................................................................................................... 16 Sample Collection and Analysis .............................................................................................................. 16 Results ..................................................................................................................................................... 16 Assessment and Evaluation ........................................................................................................................ 18 Results ..................................................................................................................................................... 18 Conclusions ............................................................................................................................................. 18 References .................................................................................................................................................. 19 Appendix A Radiological Environmental Monitoring Program and Sampling Locations ....................... 20 Appendix B Program Modifications ....................................................................................................... 29 Appendix C Program Deviations............................................................................................................. 31 Appendix D Analytical Procedures ......................................................................................................... 33 Appendix E Lower Limits Of Detection .................................................................................................. 35 Appendix F Quality Assurance / Quality Control Program..................................................................... 39 Appendix G Land Use CENSUS ................................................................................................................ 42 Appendix H Data Tables and Figures ...................................................................................................... 45 Appendix I Errata to Previous Annual Environmental Operating Reports ............................................ 53

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EXECUTIVE

SUMMARY

This report describes the Radiological Environmental Monitoring Program (REMP) conducted by the Tennessee Valley Authority (TVA) near the Browns Ferry Nuclear Plant (BFN) during the 2018 monitoring period. The program is conducted in accordance with regulatory requirements to monitor the environment per 10 CFR 20, 10 CFR 50, applicable NUREGs (U.S. NRC, 1991) and TVA requirements (TVA, 2018). The REMP includes the collection and subsequent determination of radioactive material content in environmental samples. Various types of samples are collected within the vicinity of the plant, including air, water, food crops, soil, fish and shoreline sediment, and direct radiation levels are measured. The radiation levels of these samples are measured and compared with results at control stations located outside the plants vicinity and data collected at Browns Ferry Nuclear Plant prior to operations (preoperational data). This report contains an evaluation of the potential impact of BFN operations on the environment and the general public.

All environmental samples in support of the REMP were collected by TVA and contractor personnel. All environmental media were analyzed by GEL Laboratories, LLC except for environmental dosimeters which were analyzed by Landauer. The evaluation of all results and the generation of this report was performed by Chesapeake Nuclear Services, Inc. and GEL Laboratories.

Most of the radioactivity measured in environmental samples in the BFN program can be attributed to naturally occurring radioactive materials. There is no indication that BFN activities increased the background radiation levels normally observed in the areas surrounding the plant, as measured by environmental dosimeters. In 2018, trace quantities of cesium-137 (Cs-137) were measured in some soil samples. The concentrations were typical of the levels expected to be present in the environment from past nuclear weapons. The fallout from accidents at the Chernobyl plant in the Ukraine in 1986 and the Fukushima plant in Japan in 2011 may have also contributed to the low levels of Cs-137 measured in environmental samples. There was no identified increase in Cs-137 levels attributed by Browns Ferry.

Low levels of gross beta activity were detected in some drinking water samples, but this can be attributed to natural radioactivity. Tritium (H-3) was detected in some on-site well water samples in 2018. The measured tritium levels were very low and a small fraction of the EPA drinking water limit. Only naturally occurring radioactivity was identified in all fish and local crop samples, as well air particulate, surface water and shoreline sediment samples.

These levels of radioactive elements detected do not represent a significant contribution to the radiation exposure to members of the public.

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INTRODUCTION This report describes and summarizes the results of radioactivity measurements made in the vicinity of BFN and laboratory analyses of samples collected in the area. The measurements are made to comply with the requirements of 10 CFR 50, Appendix A, Criterion 64 and 10 CFR 50, Appendix I, Section IV.B.2, IV.B.3 and IV.C and to determine potential effects on public health and safety. This report satisfies the annual reporting requirements of BFN Technical Specification 5.6.2 and Offsite Dose Calculation Manual (ODCM) Administrative Control 5.1. In addition to reporting the data prescribed by specific requirements, other information is included to help correlate the significance of results measured by this monitoring program to the levels of environmental radiation resulting from naturally occurring radioactive materials Naturally Occurring and Background Radioactivity Most materials in our world today contain trace amounts of naturally occurring radioactivity. Potassium-40 (K-40), with a half-life of 1.3 billion years, is a common radioactive element found naturally in our environment. Approximately 0.01 percent of all potassium is radioactive potassium-40. Other examples of naturally occurring radioactivity are beryllium-7 (Be-7), bismuth-212 and 214 (Bi-212 and Bi-214), lead-210 and 214 (Pb-210 and Pb-214), thallium-208 (Tl-208), actinium-228 (Ac-228), uranium-235 and uranium-238 (U-235 and U-238), thorium-234 (Th-234), radium-226 (Ra-226), radon-220 and radon-222 (Rn-220 and Rn-222), carbon-14 (C-14), and hydrogen-3 (H-3, commonly called tritium). These naturally occurring radioactive elements are in the soil, our food, our drinking water, and our bodies. Radiation emitted from these materials make up part of low-level natural background radiation exposures.

Radiation emitted from cosmic rays is the remainder.

It is possible to get an idea of the relative hazard of different types of radiation sources by evaluating the amount of radiation the U.S. population receives from each general type of radiation source. The information in Table 1 is primarily adapted from the U.S. Nuclear Regulatory Commission (U.S. NRC, February 1996) and National Council On Radiation Protection (NCRP, March 2009).

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Table 1 - U.S. General Population Average Dose Equivalent Estimates Source millirem (mrem)i per Year per Person Natural Background Dose Equivalent Cosmic 33 Terrestrial 21 In the body 29 Radon 228 Total 311 Medical (effective dose equivalent) 300 Nuclear energy 0.28 Consumer Products 13 TOTAL 624.28 i

One-thousandth of a Roentgen Equivalent Man (rem). By comparison, the NRCs annual radiation dose limit for the public from any licensed activity, such as a nuclear plant, is 100 mrem As can be seen from the data presented above, natural background radiation dose equivalent to the U.S.

population exceeds that normally received from nuclear plants by several thousand times. This illustrates that routine nuclear plant operations result in population radiation doses that are insignificant compared to the dose from natural background radiation. It should be noted that the use of radiation and radioactive materials for medical uses has resulted in a similar effective dose equivalent to the U.S.

population as that caused by natural background cosmic and terrestrial radiation.

Electric Power Production Nuclear power plants are similar in many respects to conventional coal burning (or other fossil fuel) electrical generating plants. The basic process behind electrical power production in power plants is that fuel is used to heat water to produce steam which provides the force to turn turbines and generators. In a nuclear power plant, the fuel is uranium and heat is produced in the reactor through the fission of the uranium. Nuclear plants include many complex systems to control the nuclear fission process and to safeguard against the possibility of reactor malfunction. The nuclear reactions produce radionuclides commonly referred to as fission and activation products. Very small amounts of these fission and activation products are released into the plant systems. This radioactive material can be transported throughout plant systems and some of it may be released to the environment.

Paths through which radioactivity from a nuclear power plant is routinely released are monitored. Liquid and gaseous effluent monitors record the radiation levels for each release. These monitors also provide alarm mechanisms to prompt termination of any release above limits.

Releases are monitored at the onsite points of release. The radiological environmental monitoring program, which measures the environmental radiation in areas around the plant, provides a confirmation

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that releases are being properly controlled and monitored in the plant and that any resulting levels in the environment are within the established regulatory limits and a small fraction of the natural background radiation levels. In this way, the release of radioactive materials from the plant is tightly controlled, and verification is provided that the public is not exposed to significant levels of radiation or radioactive materials as the result of plant operations.

The BFN ODCM, which describes the program required by the plant Technical Specifications, prescribes limits for the release of radioactive effluents, as well as limits for doses to the general public from the release of these effluents.

The NRCs annual dose limit to a member of the public for all licensees is 100 mrem. The NRCs regulations for nuclear power plants require implementing a philosophy of as low as reasonably achievable, where the dose to a member of the public from radioactive materials released from nuclear power plants to unrestricted areas is further limited on a per unit operating basis to the following:

Liquid Effluents Total body 3 mrem/yr Any organ 10 mrem/yr Gaseous Effluents Noble gases:

Gamma radiation 10 millirad (mrad)/yr Beta radiation 20 mrad/yr Particulates:

Any organ 15 mrem/yr In addition to NRCs regulations, the EPA standard for the total dose to the public in the vicinity of a nuclear power plant, established in the Environmental Dose Standard of 40 CFR 190, are as follows:

Total Body 25 mrem/yr Thyroid 75 mrem/yr Any other organ 25 mrem/yr Table E-1 of this report presents and compares the nominal lower limits of detection (LLD) for the BFN monitoring program with the regulatory limits for maximum annual average concentration released to unrestricted areas. The table also presents the concentrations of radioactive materials in the environment which would require a special report to the NRC and the detection limits for measured radionuclides. It should be noted that the levels of radioactive materials measured in the environment are typically below or only slightly above the lower limit of detection.

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SITE AND PLANT DESCRIPTION BFN is located on the north shore of Wheeler Reservoir at Tennessee River Mile 294 in Limestone County in north Alabama (see Figure 1). Wheeler Reservoir averages 1 to 1-1/2 miles in width in the vicinity of the plant. The BFN site contains approximately 840 acres. The dominant character of land use is small, scattered villages and homes in an agricultural area. A number of relatively large farming operations occupy much of the land on the north side of the river immediately surrounding the plant. The principal crop grown in the area is cotton.

Approximately 1,397 people live within a 5-mile radius of the plant. The town of Athens has a population of about 29,500 and is approximately 10 miles northeast of BFN. Approximately 52,250 people live in the city of Decatur 10 miles southeast. The cities of Madison and Huntsville have a combined population of approximately 227,000 starting 20 miles east of the site.

Area recreation facilities are developed along the Tennessee River. The nearest facilities are public use areas located 2 to 3 miles from the site. The city of Decatur has a large municipal recreation area, Point Mallard Park, approximately 15 miles upstream of the site. The Tennessee River is also a popular sport fishing area.

BFN consists of three boiling water reactors. Unit 1 achieved criticality on August 17, 1973 and began commercial operation on August 1, 1974. Unit 2 began commercial operation on March 1, 1975.

However, a fire in the cable trays on March 22, 1975, forced the shutdown of both reactors. Units 1 and 2 resumed operation and Unit 3 began testing in August 1976. Unit 3 began commercial operation on March 1, 1977.

All three units were shut down from March 1985 to May 1991. Unit 2 was restarted May 24, 1991 and Unit 3 restarted on November 19, 1995. Recovery work for Unit 1 was completed and the unit was restarted on May 22, 2007.

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Figure 1 - TVA Region w V A.

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M S S. :lilJi -WATTS BAR NUCLEAR PLANT GEORGIA lli!I - SEOVOYAf! NUCLEAR PLANT llCH - BELLEFONTE NUCLEAR PLANT Jm - BROWNS FERRY NUCLEAR PLANT

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RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Most of the radiation and radioactivity generated in a nuclear reactor is contained within the reactor systems. Plant effluent radiation monitors are designed to monitor radionuclides released to the environment. Environmental monitoring is a final verification that the systems are performing as planned.

The monitoring program is designed to monitor the pathways between the plant and the people in the immediate vicinity of the plant. Sample types are chosen so that the potential for detection of radioactivity in the environment will be maximized. The Radiological Environmental Monitoring Program (REMP) and sampling locations for BFN are outlined in Appendix A.

There are two primary pathways by which radioactivity can move through the environment to humans:

air and water (reference Figure 2). The air pathway can be separated into two components: the direct (airborne) pathway and the indirect (ground or terrestrial) pathway. The direct airborne pathway consists of direct radiation and inhalation by humans. In the terrestrial pathway, radioactive materials may be deposited on the ground or on plants and subsequently ingested by animals and/or humans. Human exposure through the liquid pathway may result from drinking water, eating fish, or by direct exposure at the shoreline. The types of samples collected in this program are designed to monitor these pathways.

Many factors were considered in determining the locations for collecting environmental samples. The locations for the atmospheric monitoring stations were determined from a critical pathway analysis based on weather patterns, dose projections, population distribution, and land use. Terrestrial sampling stations were selected after reviewing such things as the locations of dairy animals and gardens in conjunction with the air pathway analysis. Liquid pathway stations were selected based on dose projections, water use information, and availability of media such as fish and sediment. Table A-2 lists the sampling stations and the types of samples collected. Modifications made to the BFN monitoring program in 2018 are reported in Appendix B. Deviations to the sampling program during 2018 are included in Appendix C.

To determine the amount of radioactivity in the environment prior to the operation of BFN, a preoperational REMP was initiated in 1968 and conducted until the plant began operation in 1973.

Sampling and analyses conducted during the preoperational phase has provided data that can be used to establish normal background levels for various radionuclides in the environment.

The preoperational monitoring program is a very important part of the overall program. During the 1950s, 1960s, and 1970s, atmospheric nuclear weapons testing released radioactive material to the environment causing increases in background radiation levels. Knowledge of preexisting radionuclide patterns in the environment permits a determination, through comparison and trending analyses, of the actual environmental impact of BFN operation.

The determination of environmental impact during the operating phase also considers the presence of control stations that have been established in the environment. Results of environmental samples taken at control stations (far from the plant) are compared with those from indicator stations (near the plant) to aid in the determination of the impacts from BFN operation.

In 2018 the sample analyses were performed by a contracted laboratory, GEL Laboratories, LLC, based in Charleston, SC. Analyses were conducted in accordance with written and approved procedures and are

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based on industry established standard analytical methods. A summary of the analysis techniques and methodology is presented in Appendix D.

The radiation detection devices and analysis methods used to determine the radionuclide content of samples collected in the environment are very sensitive and capable of detecting small amounts of radioactivity. The sensitivity of the measurement process is defined in terms of the lower limit of detection (LLD). A description of the nominal LLDs for the Radioanalytical Laboratory is presented in Appendix E.

The laboratory applies a comprehensive quality assurance/quality control program to monitor laboratory performance throughout the year. One of the key purposes of the QA/QC program is to provide early identification of any problems in the measurement process so they can be corrected in a timely manner.

This program includes instrument checks, to ensure that the radiation detection instruments are working properly, and the analysis of quality control samples. As part of an interlaboratory comparison program, the laboratory participates in a blind sample program administrated by Eckert & Ziegler Analytics. A complete description of the quality control program is presented in Appendix F. Appendix G contains the results of the annual land use census. Data tables summarizing the sample analysis results are presented in Appendix H. Finally, Appendix I contains any errata from previous AREORs.

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Figure 2 - Environmental Exposure Pathways ENVIRONMENTAL EXPOSURE PATHWAYS OF MAN DUE TD RELEASES OF RADIOACTIVE MATERIAL

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Liquid Releases Diluted By Lake MAN Animals (Milk.Meat) .____ _ _~

Consum~By Man ~Shoreline 0 Exposure Consumed '\"\

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c:::::J Drinking Water Vegetation Uptake From Soil

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DIRECT RADIATION MONITORING Direct radiation levels are measured at various monitoring points around the plant site. These measurements include contributions from cosmic radiation, radioactivity in the ground, fallout from atmospheric nuclear weapons tests conducted in the past, and any radioactivity that may be present from plant operations. Because of the relatively large variations in background radiation as compared to the small levels from the plant, contributions from the plant may be difficult to distinguish.

Measurement Techniques The Landauer InLight environmental dosimeter is used in the radiological environmental monitoring program for the measurement of direct radiation. This dosimeter contains four elements consisting of aluminum oxide detectors with open windows as well as plastic and copper filters. The dosimeter is processed using optically stimulated luminescence (OSL) technology to determine the amount of radiation exposure.

The dosimeters are placed approximately one meter above the ground, with two at each monitoring location. Sixteen monitoring points are located around the plant near the site boundary, one location in each of the 16 compass sectors. One monitoring point is also located in each of the 16 compass sectors at approximately four to five miles from the plant.

Dosimeters are also placed at additional monitoring locations out to approximately 32 miles from the site.

The dosimeters are exchanged every three months. The dosimeters are sent to Landauer for processing and results reporting. The values are corrected for transit and shielded background exposure. An average of the two dosimeter results is calculated for each monitoring point. The system meets or exceeds the performance specifications outlined in American National Standards Institute (ANSI) N545-1975 and ANSI N13.37-2014 for environmental applications of dosimeters.

Results All results for environmental dosimeter measurements are normalized to a standard quarter (91 days).

The monitoring locations are grouped according to the distance from the plant. The first group consists of all monitoring points within 2 miles of the plant. The second group is made up of all locations greater than 2 miles from the plant. Past data have shown that the average results from the locations more than 2 miles from the plant are essentially the same. Therefore, for purposes of this report, monitoring points 2 miles or less from the plant are identified as onsite stations and locations greater than 2 miles are considered offsite.

The quarterly and annual gamma radiation levels determined from the dosimeters deployed around BFN in 2018 are summarized in Table 2. For comparison purposes, the average direct radiation measurements made in the preoperational phase of the monitoring program are also shown.

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Table 2 - Average External Gamma Radiation Levels at Various Distances from Browns Ferry Nuclear Plant for Each Quarter - 2018 Average External Gamma Radiation Levels Q1 Q2 Q3 Q4 Annual Preoperational (mrem/qtr) (mrem/qtr) (mrem/qtr) (mrem/qtr) (mrem/yr) (mR/yr)

Average 0-2 18.0 19.0 19.8 19.9 76.6 71 miles (onsite)a Average >2 miles 15.2 16.4 16.3 16.9 64.8 59 (offsite)a NOTES

a. Average of the individual measurements in the set The data in Table 2 indicate that the average quarterly direct radiation levels at the BFN onsite stations are approximately 3.0 mrem/quarter higher than levels at the offsite stations. This equates to 11.9 mrem/year detected at the onsite locations, which is not statistically different than that measured during the preoperational program. Even considering this 11.9 mrem/yr increase for onsite locations attributable to plant operations, it falls below the 25 mrem total body limit for 40 CFR 190. The difference in onsite and offsite averages is consistent with levels measured for the preoperational and construction phases of TVA nuclear power plant sites where the average levels onsite were slightly higher than levels offsite.

Figure 3 compares plots of the data from the onsite stations with those from the offsite stations over the period from 1977 through 2018. Landauer InLight Optically Stimulated Luminescence (OSL) dosimeters have been deployed since 2007, replacing the Panasonic UD-814 dosimeters used during the previous years. Beginning with 2018, the methodology for evaluating and reporting the environmental direct radiation exposure was modified, to reflect recommendations contained in ANSI N13.37-2014. A study was performed to determine the dose received by dosimeters that are used as unexposed controls to account for the transit dose to all dosimeters and the shielded storage dose to the unexposed control dosimeters. This in turn was used to correctly account for the extraneous dose that should be removed from the gross measurements as measured by the field dosimeters.

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Figure 3 - Average Direct Radiation Direct Radiation Levels Browns Ferry Nuclear Plant Four Quarter Moving Average a::

E 10 ~ - - - - ~ - - - - ~ ~ - ~ - - - - ~ - - - - ~ ~ - ~ - - - - ~ -

1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 Calendar Year

-+- On-Site

-o- Off-Site Table H-1 contains the results of the individual monitoring stations. The results reported in 2018 are consistent with historical and preoperational results, indicating that there is no measurable increase in direct radiation levels in the offsite environment attributable to the operation of BFN. There is no indication that BFN activities increased the background radiation levels normally observed in the areas surrounding the plant.

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ATMOSPHERIC MONITORING The atmospheric monitoring network is divided into three groups identified as local, perimeter, and remote. In the current program, five local air monitoring stations are located on or adjacent to the plant site in the general direction of greatest wind frequency. Three of these stations (LM-1, LM-2, and LM-3) are located on the plant side of the Tennessee River and two stations (LM-6 and LM-7) are located immediately across the river from the plant site. One additional station (station LM-4) is located at the point of maximum predicted offsite concentration of radionuclides based on meteorological data. Three indicator air monitoring stations (PM-1, PM-2 and PM-3) are in communities out to 13 miles from the plant, and two control stations (RM-1 and RM-6) are located out to 32 miles. The monitoring program and the locations of monitoring stations are identified in the tables and figures of Appendix A.

Results from the analysis of samples in the atmospheric pathway are presented in Table H-2 through Table H-4. Radioactivity levels identified in this reporting period are consistent with background radioactivity levels.

Sample Collection and Analysis Air particulates are collected by continuously sampling air at a flow rate of approximately 2 cubic feet per minute (cfm) through a 2-inch glass fiber filter. The sampling system consists of a pump, a magnehelic gauge for measuring the pressure drop across the system, and a dry gas meter. This allows an accurate determination of the volume of air passing through the filter. The sampling system is housed in a metal building. The filter is contained in a sampling head mounted on the outside of the monitoring building.

The filter is replaced weekly. Each filter is analyzed for gross beta activity about 3 days after collection to allow time for the radon daughters to decay. Every 4 weeks, composites of the filters from each location are analyzed by gamma spectroscopy.

Gaseous radioiodine is collected using a commercially available cartridge containing Triethylenediamine (TEDA)-impregnated charcoal. This system is designed to collect iodine in both the elemental form and as organic compounds. The cartridge is in the same sampling head as the air particulate filter and is downstream of the particulate filter. The cartridge is changed at the same time as the particulate filter and samples the same volume of air. Each cartridge is analyzed for iodine-131 (I-131) by gamma spectroscopy analysis.

Results The results from the analysis of air particulate samples are summarized in Table H-2. Gross beta activity in 2018 was consistent with levels reported in previous years. The annual average gross beta concentrations was 0.034 pCi/m3 in both indicator and control locations. The annual averages of the gross beta activity in air particulate filters for the years 1968-2018 are presented in Figure H-1. Increased levels due to fallout from atmospheric nuclear weapons testing are evident, especially in 1969, 1970, 1971, 1977, 1978, and 1981. Evidence of a small increase resulting from the Chernobyl accident can also be seen in 1986. These patterns are consistent with data from monitoring programs conducted by TVA at other nuclear power plant sites during construction and preoperational stages.

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Only naturally occurring radionuclides were identified by the monthly gamma spectral analysis of the air particulate samples. There was no I-131 detected in any charcoal cartridge samples during 2018. The results for the analysis of charcoal cartridges are reported in Table H-3.

Figure H Average Beta Radioactivity in Air Filters Annual Average Beta Activity in Air FIiters Brown s Ferry 0.2500

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~c 0.1500

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<( 0.0500 0.0000 1965 1975 1985 1995 2005 2015

- - Indicator - - Control - - Preoperational Avg

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TERRESTRIAL MONITORING Terrestrial monitoring is accomplished by collecting samples of environmental media that may transport radioactive material from the atmosphere to humans. Samples of soil and food crops are collected and analyzed to determine the potential impacts from exposure to this pathway. The results from the analysis of these samples are shown in Table H-5 and Table H-6.

A land use census is conducted annually to locate milk producing animals and gardens within a 5-mile radius of the plant. No milk-producing animals were identified within 5 miles of the plant. The results of the 2018 land use census are presented in Appendix G.

Sample Collection and Analysis Soil samples are collected annually from the area surrounding each air monitoring station. The samples are collected with either a cookie cutter or an auger type sampler. After drying and grinding, the sample is analyzed by gamma spectroscopy. When the gamma analysis is complete, the sample is analyzed for Sr-89 and Sr- 90.

Samples representative of food crops raised in the area near the plant are obtained from individual gardens in sectors with the highest predicted D/Qs, where available. Types of foods may vary from year to year as a result of changes in the local vegetable gardens. Samples of apples, cabbage, corn, green beans, potatoes, and tomatoes were collected from local gardens in 2018. Samples of these same food crops were purchased from area produce markets or private gardens to serve as control samples. The edible portion of each sample is analyzed by gamma spectroscopy.

Results The only fission or activation product identified, above nominal LLD, in soil samples was Cs-137. The average concentration measured in samples from indicator locations was 172 pCi/kg. The average concentration for control locations was 109 pCi/kg. These concentrations are consistent with levels previously reported from fallout. All other radionuclides reported were naturally occurring isotopes.

The results of the analysis of soil samples are reported in Table H-5. A plot of the annual average Cs-137 concentrations in soil is presented in Figure H-2. The concentration of Cs-137 in soil is steadily decreasing due to the cessation of weapons testing in the atmosphere, the 30-year half-life of Cs-137 and transport through the environment.

Analyses of food samples indicated no contribution from plant activities. The results are reported in Table H-6.

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LIQUID PATHWAY MONITORING Potential exposures from the liquid pathway can occur from drinking water, ingestion of fish, and from direct radiation exposure to radioactive materials deposited in the river shoreline sediment. The liquid pathway monitoring program conducted during 2018 included the collection of samples of surface (river/reservoir) water, groundwater, drinking water supplies, fish, and shoreline sediment. Samples from the reservoir are collected both upstream and downstream from the plant. Results from the analysis of aquatic samples are presented in Table H-7 through Table H-11.

Sample Collection and Analysis Samples of surface water are collected from the Tennessee River using automatic sampling systems from one downstream station and one upstream station. The upstream sample is collected from the raw water intake at the Decatur, Alabama water plant (TRM 306.0) and is utilized as a control sampling location for both surface and drinking water. A timer turns on the system at least once every two hours. The line is flushed, and a sample collected into a collection container. A one-gallon sample is removed from the container every 4 weeks and the remaining water in the jug is discarded. The 4-week composite sample is analyzed for gamma isotopic and gross beta activity. A quarterly composite sample is analyzed for tritium.

Samples are also collected by an automatic sampling system at the first downstream drinking water intake, West Morgan - East Lawrence Water Authority. This sample of raw untreated water is collected at the intake from the water plant. These samples are collected in the same manner as the surface water samples. These monthly samples are analyzed for gamma isotopic and gross beta activity. A quarterly composite is analyzed for tritium.

At other selected locations, grab samples are collected from drinking water systems which use the Tennessee River as their source. These samples are analyzed every 4 weeks for gamma isotopic and gross beta activity. A quarterly composite sample from each station is analyzed for tritium.

A groundwater well onsite is equipped with an automatic water sampler. Water is also collected from a private well in an area unaffected by BFN. Samples from the wells are collected every 4 weeks and analyzed by gamma spectroscopy. A quarterly composite sample is analyzed for tritium.

Samples of commercial and game fish species are collected semiannually from each of the two reservoirs:

the reservoir on which the plant is located (Wheeler Reservoir) and the upstream reservoir (Guntersville Reservoir). The samples are collected using a combination of netting techniques and electrofishing. To sample edible portions of the fish, the fish are filleted. After drying and grinding, the samples are analyzed by gamma spectroscopy.

Shoreline sediment is collected from two downstream recreational use areas and one upstream location.

The samples were collected at the normal water level shoreline and analyzed by gamma spectroscopy.

Results Only naturally occurring isotopes were identified by gamma spectral analysis of surface water. Although tritium is occasionally detected in surface water samples, it was not detected in any control or indicator

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surface water samples in 2018. A summary table of the results for this reporting period is shown in Table H-7.

No fission or activation products were detected by the gamma or tritium analysis of public drinking water.

Gross beta activity averaged 3.40 pCi/liter at the downstream stations and 4.04 pCi/liter at upstream stations. These results are consistent with previous monitoring results. Like surface water, tritium is occasionally identified in drinking water samples, but was not detected in any control or indicator drinking water samples in 2018. The results are shown in Table H-8.

No fission or activation products were detected in groundwater samples from BFN REMP monitoring locations by gamma analysis. Tritium was detected in samples collected from the indicator location at a maximum concentration of 1050 pCi/liter. These tritium concentrations represent only a small fraction of the Environmental Protection Agency (EPA) drinking water limit of 20,000 pCi/liter. Results from the analysis of groundwater samples are presented in Table H-9.

In 2018, game fish (large mouth bass) and commercial fish (channel catfish) were sampled and analyzed from both control and indicator locations. No fission or activation products were identified in any of the samples. The results are summarized in Table H-10.

Only naturally occurring radionuclides were identified above the nominal LLD in shoreline sediment samples from the indicator locations. In some years, Cs-137 has been identified in shoreline sediment samples, but that did not occur in 2018. The results of the analysis of shoreline sediment are provided in Table H-11.

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ASSESSMENT AND EVALUATION Potential doses to the public are estimated from measured effluents using computer models. These models were developed by TVA and are based on methodology provided by the NRC in Regulatory Guide 1.109 for determining the potential dose to individuals and populations living near a nuclear power plant.

The results of the effluent dose calculations are reported in the Annual Radioactive Effluent Release Report. The calculated doses are a representation of the dose to a maximum exposed individual. Some of the factors used in these calculations (such as ingestion rates) are maximum expected values which will tend to overestimate the dose to this hypothetical person. The calculated maximum dose due to plant effluents are small fractions of the applicable regulatory limits. The expected dose to actual individuals is significantly lower.

Based on the very low concentrations of radionuclides present in plant effluent, the calculated doses as a result of plant operations are small fractions of regulatory limits and the natural background radiation dose. The results for the radiological environmental monitoring conducted for BFN 2018 operations confirm this expectation.

Results As stated earlier in the report, the estimated increase in radiation dose equivalent to the public resulting from the operation of BFN is negligible when compared to the dose from natural background radiation.

The results from each environmental sample are compared with the concentrations from the corresponding control stations and appropriate preoperational and background data to determine influences from the plant. During this reporting period, Cs-137 was identified above the nominal LLD in soil samples. The Cs-137 detected in these samples was consistent with levels generally found in the environment as the result of past nuclear weapons testing. The low levels of tritium measured in some on-site well water samples represent concentrations that are significantly lower than the EPA drinking water limit.

Conclusions The 2018 radiological environmental monitoring program results demonstrate that exposure to members of the general public, which may have been attributable to BFN, is a small fraction of regulatory limits and essentially indistinguishable from the natural background radiation. The radioactivity reported herein is primarily the result of fallout or natural background. Any activity which may be present in the environment as a result of plant operations does not represent a significant contribution to the exposure of members of the public.

[18]

REFERENCES GEL. (2018). 2018 Annual Quality Assurance Report for the Radiological Environmental Monitoring Program (REMP). Charleston, SC.

NCRP. (March 2009). Report No. 160, Ionizing Radiation Exposure of the Population of the United States.

NCRP, Washington, D.C.

TVA. (2018). Browns Ferry Offsite Dose Calculation Manual, 0-ODCM-001, Revision 24.

U.S. NRC. (1991). NUREG-1302 Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors, Generic Letter 89-01, Supplement No. 1. Washington, D.C.:

USNRC. Retrieved from http://www.nrc.gov/docs/ML0910/ML091050059.pdf U.S. NRC. (February 1996). Instruction Concerning Risks from Occupational Exposure. USNRC, Washington, D.C.

[19]

APPENDIX A RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM AND SAMPLING LOCATIONS

[20]

APPENDIX A Table A Browns Ferry Radiological Environmental Monitoring Program Exposure Pathway and/or Sample Number of Samples and Locationsa Sampling and Collection Type and Frequency of Frequency Analysis

1. AIRBORNE

a. Particulates 6 samples from locations (in different sectors) Continuous sampler operation Analyze for gross beta at or near the site boundary (LM-1, LM-2, LM-3, with sample collection weekly radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LM-4, LM-6 and LM-7) (more frequently if required by following filter change.

dust loading) Perform gamma isotopic 3 samples from communities approximately 10 analysis on each sample if miles from plant (PM-1, PM-2 and PM-3) gross beta > 10 times yearly mean of control sample.

2 samples from control locations > 10 miles Composite at least once per from the plant (RM-1 and RM-6) 31 days (by location) for gamma spectroscopy.

b. Radioiodine Samples from same locations as air particulates Continuous sample operation I-131 by gamma scan on each with filter collection at least sample.

once per 7 days.

c. Soil Samples from same location as air particulates Once every year Gamma scan, Sr-89, Sr-90 once per year

2. DIRECT

a. Dosimeters 2 or more dosimeters placed at or near the site At least once per 92 days Gamma dose once per 92 days boundary in each of the 16 sectors.

2 or more dosimeters placed at stations located approximately 5 miles from the plant in each of the 16 sectors.

2 or more dosimeters in at least 8 additional locations of special interest, including at least 2 control stations.

[21]

APPENDIX A Table A Browns Ferry Radiological Environmental Monitoring Program (Continued)

Exposure Pathway and/or Sample Number of Samples and Locationsa Sampling and Collection Type and Frequency of Frequency Analysis

3. WATERBORNE

a. Surface Water 1 sample downstream from plant discharge Collected by automatic Gamma scan at least once per (TRM 293.5) sequential-type samplerb with 31 days. Composite for composite samples collected tritium at least once per 92 1 sample at a control location upstream from over a period of approximately days.

the plant discharge (TRM 306.0) 31 days.

b. Drinking Water 1 sample at the first potable surface water Collected by automatic Gross beta and gamma scan at supply downstream from the plant sequential-type samplerb with least once per 31 days.

(TRM 286.5) composite sample collected at Composite for tritium analysis least once per 31 days. at least once per 92 days.

1 sample at a control location (TRM 306) 3 additional samples of potable surface water Grab sample taken from the downstream from the plant (TRM 274.9, TRM water supply at a facility using 259.8 and TRM 259.6) water from the public supply being monitored. Sample collected at least once per 31 days.

c. Ground water 1 sample adjacent to the plant (Well #6R) Collected by automatic Composite for gamma scan sequential-type samplerb with and tritium at least once per composite samples collected 92 days.

over a period of approximately 31 days.

1 sample at a control location up gradient from Grab sample taken at least the plant (Farm B) once per 31 days.

[22]

APPENDIX A Table A Browns Ferry Radiological Environmental Monitoring Program (Continued)

Exposure Pathway and/or Sample Number of Samples and Locationsa Sampling and Collection Type and Frequency of Frequency Analysis

d. Shoreline Sediment 1 sample from each of at least two downstream At least once per 184 days Gamma scan of each sample locations with recreational use. (TRM 293 and TRM 279.5) 1 sample from a control location upstream from plant discharge (TRM 305)

4. INGESTION

a. Fish 2 samples representing commercial and game Semi-Annually (at least once Gamma spectroscopy on species in Guntersville Reservoir above the per 184 days) edible portions plant.

2 samples representing commercial and game species in Wheeler Reservoir near the plant.

b. Food Products Samples of food crops such as greens, corn, At least once per year at time Gamma spectroscopy on green beans, tomatoes and potatoes grown at of harvest. edible portions private gardens and/or farms in the immediate vicinity of the plant.

1 sample of each of the same foods grown at greater than 10 miles from the plant.

a Sample locations are shown on Figure A-1 through Figure A-3.

b Samples shall be collected by collecting an aliquot at intervals not exceeding 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

[23]

APPENDIX A Table A Browns Ferry REMP Sampling Locations Map Approximate Indicator (I)

Station Distance or Control Numbera Station Sector (miles) (C) Samples Collectedb 1 PM-1 NW 13.8 I AP,CF,S 2 PM-2 NE 10.9 I AP,CF,S 3 PM-3 SSE 7.5 I AP,CF,S 4 LM-7 W 2.1 I AP,CF,S 5 RM-1 W 31.0 C AP,CF,S 6 RM-6 E 23.4 C AP,CF,S 7 LM-1 NNW 1.0 I AP,CF,S 8 LM-2 NNE 0.9 I AP,CF,S 9 LM-3 ENE 0.9 I AP,CF,S 10 LM-4 NNW 1.7 I AP,CF,S 11 LM-6 SSW 3.0 I AP,CF,S 12 Farm B NNW 6.8 C W 24 TRMc 306.0 - 12.0d C PW, SW 25 TRM 259.6 - 34.4d I PW 26 TRM 274.9 - 19.1d I PW 28 TRM 293.5 - 0.5d I SW 70 TRM 259.8 - 34.2d I PW 71 TRM 286.5 - 7.5d I PW 72 TRM 305 - 11.0d C SS 73 TRM 293 - 1.0d I SS 74 TRM 279.5 - 14.5d I SS 76 Well 6R NW 0.12 I W Wheeler Reservoir

- - I F (TRM 275 - 349)

Guntersville Reservoir

- - C F (TRM 349 - 424) a See Figure A-1 through Figure A-3 b

Sample Codes:

AP = Air particulate filter PW = Public water SS = Shoreline sediment F = Fish V= Vegetation SW = Surface water M = Milk S= Soil W= Well water CF = Charcoal Filter c

TRM = Tennessee River Mile d

Distance from plant discharge at Tennessee River Mile (TRM) 294

[24]

APPENDIX A Table A Browns Ferry Environmental Dosimeter Locations Distance Onsite or Station Sector (miles) Offsitea 1 NW-3 NW 13.8 Off 2 NE-3 NE 10.9 Off 3 SSE-2 SSE 7.5 Off 5 W-3 W 31.0 Off 6 E-3 E 23.1 Off 7 N-1 NNW 1.0 On 8 NNE-1 NNE 0.9 On 9 ENE-1 ENE 0.9 On 10 NNW-2 NNW 1.7 On 38 N-2 N 5.0 Off 39 NNE-2 NNE 0.7 On 40 NNE-3 NNE 5.2 Off 41 NE-1 NE 0.8 On 42 NE-2 NE 5.0 Off 43 ENE-2 ENE 6.2 Off 44 E-1 E 0.8 On 45 E-2 E 5.2 Off 46 ESE-1 ESE 0.9 On 47 ESE-2 ESE 3.0 Off 48 SE-1 SE 0.5 On 49 SE-2 SE 5.4 Off 50 SSE-1 SSE 5.1 Off 51 S-1 S 3.1 Off 52 S-2 S 4.8 Off 53 SSW-1 SSW 3.0 Off 54 SSW-2 SSW 4.4 Off 55 SW-1 SW 1.9 On 56 SW-2 SW 4.7 Off 58 WSW-1 WSW 2.7 Off 59 WSW-2 WSW 5.1 Off 60 WSW-3 WSW 10.5 Off 61 W-1 W 1.9 On 62 W-2 W 4.7 Off 64 WNW-1 WNW 3.3 Off 65 WNW-2 WNW 4.4 Off 66 NW-1 NW 2.2 Off 67 NW-2 NW 5.3 Off 68 NNW-1 NNW 1.0 On 69 NNW-3 NNW 5.2 Off 75 N-1A N 1.0 On a

Dosimeters designated onsite are located 2 miles or less from the plant; offsite are located more than 2 miles from the plant. See Figure A-1 through Figure A-3.

[25]

APPENDIX A Figure A Radiological Environmental Monitoring Locations within 1 mile of Plant 5

78.75 w E 101.25 191.25 S 1s8.1 5 SSE Scale 0 Mile 1

[26]

APPENDIX A Figure A Radiological Environmental Monitoring Locations 1 - 5 miles from Plant w

,,us

'*---;;os

,,-"',,,--,o**=----,,

• wu.u

[27]

APPENDIX A Figure A Radiological Environmental Sampling Locations Greater than 5 miles from Plant

• --,--,-."';::<:"::;~.,-~,a--*,*,

[28]

APPENDIX B PROGRAM MODIFICATIONS

[29]

APPENDIX B Radiological Environmental Monitoring Program Modifications In 2018, there were no modifications to the Browns Ferry Nuclear Power Plant Radiological Environmental Monitoring Program sampling locations, analysis types, or frequency.

[30]

APPENDIX C PROGRAM DEVIATIONS

[31]

APPENDIX C Program Deviations Media Location Date CR Issue Direct Radiation WSW-3 1/8/2019 1483613 Environmental OSLDs found missing at location Q4 40A and B. Dosimeters were relocated to nearby utility pole for Q1 2019.

Air Filter LM-2 5/22/2018 1416823 Sampler found inoperable. Breaker reset fixed Charcoal Filter issue. Inadequate volume for air sample.

[32]

APPENDIX D ANALYTICAL PROCEDURES

[33]

APPENDIX D Analytical Procedures Analyses of environmental samples are performed by GEL Laboratories, LLC in Charleston, SC. Analysis of environmental dosimeters are performed by Landauer, Inc. in Glenwood, IL. Analysis procedures are based on accepted methods and summarized below.

The gross beta measurements are made with an automatic low background counting system. Normal counting times are 50 minutes. Water samples are prepared by evaporating 400 milliliter (mL) of samples to near dryness, transferring to a stainless steel planchet, and completing the evaporation process. Air particulate filters are counted directly in a shallow planchet.

The specific analysis of I-131 in milk is performed by first isolating and purifying the iodine by radiochemical separation and then counting the final precipitate on a beta-gamma coincidence counting system. The normal count time is 480 minutes. Then the I-131 is counted in a gamma spectroscopy utilizing high resolution Hp-Ge detectors.

After a radiochemical separation, milk samples analyzed for Sr-89 and Sr-90 are counted on a low background beta counting system. The sample is counted a second time after a minimum ingrowth period of six days. From the two counts, the Sr-89 and Sr-90 concentrations can be determined.

Water samples are analyzed for tritium content by first distilling a portion of the sample and then counting by liquid scintillation. A commercially available scintillation cocktail is used.

Gamma analyses are performed in various counting geometries depending on the sample type and volume. All gamma counts are obtained with germanium type detectors interfaced with a high resolution gamma spectroscopy system.

The charcoal cartridges used to sample gaseous radioiodine are analyzed by gamma spectroscopy using a high resolution gamma spectroscopy system with germanium detectors.

The necessary efficiency values, weight-efficiency curves, and geometry tables are established and maintained on each detector and counting system. A series of daily and periodic quality control checks are performed to monitor counting instrumentation. System logbooks and control charts are used to document the results of the quality control checks.

The Landauer InLight Environmental Dosimetry System is used for measuring direct radiation in the REMP.

Landauer has performed type testing of this system in accordance with ANSI N13.37-2014 standards.

[34]

APPENDIX E LOWER LIMITS OF DETECTION

[35]

APPENDIX E Lower Limits of Detection Many factors influence the Lower Limit of Detection (LLD) for a specific analysis method, including sample size, count time, counting efficiency, chemical processes, radioactive decay factors, and interfering isotopes encountered in the sample. The most probable values for these factors have been evaluated for the various analyses performed in the environmental monitoring program. The nominal LLDs are calculated from these values, in accordance with the methodology prescribed in the ODCM. The current nominal LLD values achieved by the radioanalytical lab are listed in Table E-2 and Table E-3. For comparison, the maximum values for the lower limits of detection specified in the ODCM are given in Table E-4.

Table E Comparison of Program Lower Limits of Detection with the Regulatory Limits for Maximum Annual Average Effluent Concentration Released to Unrestricted Areas and Reporting Levels Concentrations in Water (pCi/Liter) Concentrations in Air (pCi/m3) 10 CFR 20 Nominal 10 CFR 20 Nominal Effluent Lower Effluent Lower Concentration Reporting Limit of Concentration Reporting Limit of Analysis Limita Levelb, c Detectiond Limita Levelb, c Detectiond H-3 1,000,000 20,000 270 100,000 -- --

Cr-51 500,000 -- 45 30,000 -- 0.02 Mn-54 30,000 1000 5 1,000 -- 0.005 Fe-59 10,000 400 10 500 -- 0.005 Co-58 20,000 1000 5 1,000 -- 0.005 Co-60 3,000 300 5 50 -- 0.005 Zn-65 5,000 300 10 400 -- 0.005 Sr-89 8,000 -- -- 1,000 -- --

Sr-90 500 -- -- 6 -- --

Nb-95 30,000 400 5 2,000 -- 0.0005 Zr-95 20,000 400 10 400 -- 0.005 Ru-103 30,000 -- 5 900 -- 0.005 Ru-106 3,000 -- 40 20 -- 0.02 I-131 1,000 2 0.4 200 0.9 0.005 Cs-134 900 30 5 200 10 0.005 Cs-137 1,000 50 5 200 20 0.005 Ce-144 3,000 -- 30 40 -- 0.01 Ba-140 8,000 200 25 2,000 -- 0.015 La-140 9,000 200 10 2,000 -- 0.01 a

Source: Table 2 of Appendix B to 10 CFR 20.1001-20.2401 b

For those reporting levels and lower limits of detection that are blank, no value is given in the reference c

Source: BFN Offsite Dose Calculation Manual, Table 2.3-3 d

Source: Table E-2 and Table E-3 of this report

[36]

APPENDIX E Table E Nominal LLD Values - Radiochemical Airborne Particulate or Wet Sediment Gases Water Milk Vegetation and Soil Analysis (pCi/m3) (pCi/L) (pCi/L) (pCi/kg, wet) (pCi/kg, dry)

Gross beta 0.002 1.9 -- -- --

H-3 3.0 270 -- -- --

I-131 -- 0.4 0.4 6.0 --

Sr-89 -- -- 3.5 -- 1.6 Sr-90 -- -- 2.0 -- 0.4 Table E Nominal LLD Values - Gamma Analysis Food Airborne Charcoal Water and Wet Sediment Fish Products Particulate Filter Milk Vegetation and Soil (pCi/kg, (pCi/kg, Analysis (pCi/m3) (pCi/m3) (pCi/L) (pCi/kg, wet) (pCi/kg, dry) wet) wet)

Ce-141 0.005 0.02 10 35 0.10 0.07 20 Ce-144 0.01 0.07 30 115 0.20 0.15 60 Cr-51 0.02 0.15 45 200 0.35 0.30 95 I-131 0.005 0.03 10 60 0.25 0.20 20 Ru-103 0.005 0.02 5 25 0.03 0.03 25 Ru-106 0.02 0.12 40 190 0.20 0.15 90 Cs-134 0.005 0.02 5 30 0.03 0.03 10 Cs-137 0.005 0.02 5 25 0.03 0.03 10 Zr-95 0.005 0.03 10 45 0.05 0.05 45 Nb-95 0.005 0.02 5 30 0.04 0.25 10 Co-58 0.005 0.02 5 20 0.03 0.03 10 Mn-54 0.005 0.02 5 20 0.03 0.03 10 Zn-65 0.005 0.03 10 45 0.05 0.05 45 Co-60 0.005 0.02 5 20 0.03 0.03 10 K-40 0.04 0.30 100 400 0.75 0.40 250 Ba-140 0.015 0.07 25 130 0.30 0.30 50 La-140 0.01 0.04 10 50 0.20 0.20 25 Fe-59 0.005 0.04 10 40 0.05 0.08 25 Be-7 0.02 0.15 45 200 0.25 0.25 90 Pb-212 0.005 0.03 15 40 0.10 0.04 40 Pb-214 0.005 0.07 20 80 0.15 0.10 80

[37]

APPENDIX E Table E Nominal LLD Values - Gamma Analysis (continued)

Food Airborne Charcoal Water and Wet Sediment Fish Products Particulate Filter Milk Vegetation and Soil (pCi/kg, (pCi/kg, Analysis (pCi/m3) (pCi/m3) (pCi/L) (pCi/kg, wet) (pCi/kg, dry) wet) wet)

Bi-214 0.005 0.05 20 55 0.15 0.10 40 Bi-212 0.02 0.20 50 250 0.45 0.25 130 Tl-208 0.002 0.02 10 30 0.06 0.03 30 Ra-224 -- -- -- -- 0.75 -- --

Ra-226 -- -- -- -- 0.15 -- --

Ac-228 0.01 0.07 20 70 0.25 0.10 50 Pa-234m -- -- 800 -- 4.0 -- --

Table E-4 -Maximum Values for Lower Limits of Detection (LLD)

Airborne Particulate or Fish Food Water Gases (pCi/kg, Milk Products Sediment Analysis (pCi/L) (pCi/m3) wet) (pCi/L) (pCi/kg, wet) (pCi/kg, dry)

Gross beta 4 0.01 -- -- -- --

H-3 2000a -- -- -- -- --

Mn-54 15 -- 130 -- -- --

Fe-59 30 -- 260 -- -- --

Co-58, 60 15 -- 130 -- -- --

Zn-65 30 -- 260 -- -- --

Zr-95 30 -- -- -- -- --

Nb-95 15 -- -- -- -- --

I-131 1b 0.07 -- 1 60 --

Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 -- -- 60 -- --

La-140 15 -- -- 15 -- --

Notes

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.

[38]

APPENDIX F QUALITY ASSURANCE / QUALITY CONTROL PROGRAM

[39]

APPENDIX F Quality Assurance / Quality Control Program A quality assurance program is employed by the offsite vendor laboratory to ensure that the environmental monitoring data are reliable. This program includes the use of written, approved procedures in performing the work, provisions for staff training and certification, internal self-assessments of program performance, audits by various external organizations, and a laboratory quality control program.

The quality control program employed by the radioanalytical laboratory is designed to ensure that the sampling and analysis process is working as intended. The program includes equipment checks and the analysis of quality control samples, along with routine field samples. Instrument quality control checks include background count rate and counts reproducibility. In addition to these two general checks, other quality control checks are performed on the variety of detectors used in the laboratory. The exact nature of these checks depends on the type of device and the method it uses to detect radiation or store the information obtained.

Quality control samples of a variety of types are used by the laboratory to verify the performance of different portions of the analytical process. These quality control samples include blanks, field duplicates, process duplicates, matrix spikes, laboratory control samples, and independent cross-checks.

Blanks are samples which contain no measurable radioactivity or no activity of the type being measured.

Such samples are analyzed to determine whether there is any contamination or cross-contamination of equipment, reagents, processed samples, or interferences from isotopes other than the ones being measured.

Matrix spikes are field samples that have been spiked with known low levels of specific target isotopes.

Recovery of the known amount allow the analyst to determine if any interferences are exhibited from the field samples matrix.

Laboratory control samples are another type of quality control sample. A known amount of radioactivity is added to a sample medium and processed along with the other QC and field samples in the analytical batch. Laboratory control samples provide the assurance that all aspects of the process have been successfully completed within the criteria established by Standard Operating Procedure.

Another category of quality control samples are cross-checks. The laboratory procures single-blind performance evaluation samples from Eckert & Ziegler Analytics to verify the analysis of sample matrices processed at the laboratory. Samples are received on a quarterly basis. The laboratorys Third-Party Cross-Check Program provides environmental matrices encountered in a typical nuclear utility REMP.

Once performance evaluation samples have been prepared in accordance with the instructions from the performance evaluator provider, samples are managed and analyzed in the same manner as environmental samples. These samples have a known amount of radioactivity added and are presented to the lab staff labeled as cross-check samples. The laboratory does not know the true value of the activity added to the sample. Such samples test the best -performance of the laboratory by determining if the laboratory can find the right answer. These samples provide information about the accuracy of the measurement process. Further information is available about the variability of the process if multiple analyses are requested on the same sample. Like matrix spikes or laboratory control samples, these

[40]

APPENDIX F samples can also be spiked with low levels of activity to test detection limits. The analysis results for internal cross-check samples met program performance goals for 2018.

The quality control data are routinely collected, examined and reported to laboratory supervisory personnel. They are checked for trends, problem areas, or other indications that a portion of the analytical process needs correction or improvement. The result is a measurement process that provides reliable and verifiable data and is sensitive enough to measure the presence of radioactivity far below the levels which could be harmful to humans.

Per the GEL 2018 Annual Environmental Quality Assurance (QA) Report (GEL, 2018), forty-five (45) radioisotopes associated with seven (7) matrix types (air filter, cartridge, water, milk, soil, liquid and vegetation) were analyzed under GELs Performance Evaluation program in participation with ERA, MAPEP, and Eckert & Ziegler Analytics. Matrix types were representative of client analyses performed during 2018. Of the four hundred fifty-two (452) total results, 98.4% (445 of 452) were found to be acceptable within the PT providers three sigma or other statistical criteria. For the Eckert & Ziegler Analytics Environmental Cross Check Program, GEL was provided ninety-two (92) individual environmental analyses. The accuracy of each result reported to Eckert & Ziegler Analytics, Inc. is measured by the ratio of GELs result to the known value. All results fell within GELs acceptance criteria (100% within acceptance).

The radioanalytical lab performance in 2018 meets the criteria described in Reg. Guide 4.15 and ANSI/HPS N13.37-2014.

[41]

APPENDIX G LAND USE CENSUS

[42]

APPENDIX G Land Use Census A land use census was conducted in accordance with the provisions of ODCM Control 1.3.2 to identify the location of the nearest milk animal, the nearest residence, and the nearest garden of greater than 500 square feet (50 m2) producing fresh leafy vegetables in each of 16 meteorological sectors within a distance of 5 miles (8 km) from the plant. The land use census also identifies all gardens of greater than 500 square feet producing fresh leafy vegetables within a distance of 3 miles (5 km) from the plant.

The land use census was conducted during the growing season in June 2018 using appropriate techniques such as door-to-door survey, mail survey, telephone survey, aerial survey, or information from local agricultural authorities or other reliable sources. Sectors and distances were determined using a global positioning system (GPS).

The location of the nearest resident was changed or updated in four different meteorological sectors. The changes were minor and summarized below:

Table G 2018 Updated Nearest Residence 2017 Nearest 2018 Nearest Resident Distance Resident Distance Sector (meters) (meters)

ENE 2460 2560 SSW 4610 4160 SW 4650 4940 WSW 4200 4040 The location of the nearest garden greater than 500 ft2 was changed or updated in six sectors. The changes are minor and summarized below:

Table G 2018 Updated Nearest Garden 2017 Nearest 2018 Nearest Garden Garden Sector (meters) (meters)

NE 3790 4290 ENE 5180 4700 ESE 1830 2070 W 3070 8020 NNW 2290 4350 SW 4650 4940

[43]

APPENDIX G In 2018 no milk locations were identified within an 8-km (5 miles) radius of the plant site. Browns Ferry gaseous effluents are characterized as an elevated release. As a result, BFN is required to identify all qualifying gardens out to 3 miles, in accordance with regulatory requirements and the Browns Ferry ODCM (TVA, 2018). The 2018 land use census identified a total of four additional gardens within 3 miles that are not the nearest gardens to the site, in their sector. Of these four, one was new in 2018.

Results of the 2018 Land Use Census indicated only minor changes and that no changes are needed to the BFN REMP.

Table G Browns Ferry Land Use Census Results Nearest Nearest Nearest Milk Additional Meteorological Resident Garden Production Gardens Sector (meters) (meters) (meters) (meters)

N 2440 2540 - -

NNE 2620 5980 - -

NE 2020 4290 - -

ENE 2560 4700 - -

E 1410 1530 - 4240 4500 ESE 1750 2070 -

2780 SE - - - -

SSE - - - -

S 4540 4540 - -

SSW 4160 4880 - -

SW 4940 4940 - -

WSW 4040 4330 - 4620 W 2660 8020 - -

WNW 5280 - - -

NW 3150 - - -

NNW 1650 4350 - -

[44]

APPENDIX H DATA TABLES AND FIGURES

[45]

APPENDIX H Table H Individual Dosimeter Stations at Browns Ferry Nuclear Plant Map Q1 Q2 Q3 Q4 Annual Loc. Station Dir. Distance 2018 2018 2018 2018 Exposure No. Number (degrees) (miles) (mrem/qtr) (mrem/yr) 1 NW-3 310 13.8 14.0 15.6 14.3 15.2 59.1 2 NE-3 56 10.9 14.0 13.1 15.3 17.7 60.1 3 SSE-2 165 7.5 15.0 15.6 18.3 15.2 64.1 5 W-3 275 31.0 15.5 14.1 16.3 14.7 60.6 6 E-3 90 23.1 16.1 15.6 18.3 17.7 67.6 7 N-1 348 1.0 19.6 20.6 25.7 21.8 87.6 8 NNE-1 12 0.9 17.1 20.1 17.8 19.2 74.2 9 ENE-1 61 0.9 17.1 21.1 20.2 18.2 76.6 10 NNW-2 331 1.7 17.6 19.1 18.3 18.2 73.1 38 N-2 1 5.0 13.5 16.1 14.8 15.7 60.1 39 NNE-2 31 0.7 19.6 19.6 17.8 23.3 80.2 40 NNE-3 19 5.2 12.0 17.1 13.3 15.2 57.6 41 NE-1 51 0.8 19.6 18.6 21.2 22.3 81.7 42 NE-2 49 5.0 17.6 18.6 19.7 20.7 76.7 43 ENE-2 62 6.2 15.5 17.6 17.8 18.7 69.6 44 E-1 85 0.8 20.1 19.1 23.7 19.2 82.1 45 E-2 91 5.2 15.5 19.1 19.2 18.7 72.6 46 ESE-1 110 0.9 14.5 16.1 17.3 22.3 70.2 47 ESE-2 112 3.0 15.0 14.6 16.3 17.7 63.6 48 SE-1 130 0.5 20.6 18.6 22.2 20.2 81.7 49 SE-2 135 5.4 16.1 16.6 19.2 17.2 69.1 50 SSE-1 163 5.1 16.1 16.1 14.8 16.7 63.7 51 S-1 185 3.1 16.3 16.1 15.8 15.7 63.9 52 S-2 182 4.8 14.0 15.6 11.3 15.7 56.7 53 SSW-1 203 3.0 14.2 15.6 14.3 17.2 61.3 54 SSW-2 199 4.4 16.3 18.1 17.8 17.2 69.4 55 SW-1 228 1.9 17.3 16.1 18.7 15.7 67.9 56 SW-2 219 4.7 16.3 17.1 14.8 19.7 67.9 58 WSW-1 244 2.7 12.7 13.1 13.3 13.7 52.8 59 WSW-2 251 5.1 15.8 17.6 16.8 18.7 68.9 60 WSW-3 257 10.5 15.3 16.1 17.8 N/A 49.1 61 W-1 275 1.9 15.8 15.1 19.2 17.2 67.3 62 W-2 268 4.7 14.7 16.6 15.8 15.2 62.3 64 WNW-1 291 3.3 16.3 16.1 15.8 16.7 64.9 65 WNW-2 293 4.4 15.8 16.6 19.2 18.7 70.3 66 NW-1 326 2.2 13.0 16.1 15.8 16.2 61.1 67 NW-2 321 5.3 16.6 19.6 15.8 17.2 69.2 68 NNW-1 331 1.0 16.1 20.6 14.3 16.7 67.7 69 NNW-3 339 5.2 16.6 17.6 17.8 17.2 69.1 75 N-1A 355 1.0 19.1 21.6 20.7 24.8 86.2

[46]

APPENDIX H Table H Weekly Airborne Particulate Gross Beta All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD)a Direction Measurements Range Range Air Filter 0.034 (477/477) 0.035 (53/53) 0.034 (106/106)

Inhalation Gross Beta 583 0.01 LM-2, 0.9 Mi. NNE 0 (0.014 - 0.120) (0.016 - 0.120) (0.015 - 0.082)

(pCi/m3)

NOTES

a. LLD is the a priori limit as prescribed by the ODCM.

Figure H Average Beta Radioactivity in Air Filters Annual Average Beta Activity in Air FIiters Browns Ferry 0.2500 r::-, 0.2000

§ g 0.1500 0

~

~

ca. 0.1000 Q)

Q.0

~

Q)

<I: 0.0500 0.0000 1965 1975 1985 1995 2005 2015

-+- Indicator -+- Control - - Preoperational Avg

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APPENDIX H Table H Weekly Airborne Iodine-131 Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) a Direction Measurements Range Range Activated Charcoal Inhalation I-131 583 0.07 < LLDa (0/477) < LLD < LLD < LLD (0/106) 0 (pCi/m3)

NOTES

a. The term < LLD as used means that results had no identified activity above the minimum detectable.

Table H Quarterly Composite Airborne Particulate Gamma Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Air Filter Gamma Inhalation 143 Various b < LLD (0/117) < LLD < LLD < LLD (0/26) 0 Isotopica (pCi/m3)

NOTES

a. Natural occurring radionuclides were observed in quarterly composite air samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

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APPENDIX H Table H Annual Soil Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Gamma 11 Various b < LLD (0/9) < LLD < LLD < LLD (0/2) 0 Isotopic a Soil Direct Radiation 172 (6/9) 215 (1/1) 109 (2/2)

Cs-137 11 180 LM-6, 3 Mi.SSW 0 (pCi/kg) 113 - 215 215 - 215 104 - 114 Sr-89 11 1.6 < LLD (0/9) < LLD < LLD < LLD (0/2) 0 Sr-90 11 0.4 < LLD (0/9) < LLD < LLD < LLD (0/2) 0 NOTES

a. Natural occurring radionuclides were observed in soil samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

Figure H Average Cs-137 Radioactivity in Soil Average Cs-137 Radioactivity in Soil Browns Ferry 3.0 2.5 b.ii 2.0 u

a.

'i- 1.5

~

u

<i:: 1.0 0.5 0.0 1965 1975 1985 1995 2005 2015

_._ Indicator _._ Control - - Preoperational Average

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APPENDIX H Table H Annual Local Crop Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Apples Ingestion Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 (pCi/kg) Isotopic a Cabbage Ingestion Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 (pCi/kg) Isotopic a Corn Ingestion Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 (pCi/kg) Isotopic a Potatoes Ingestion Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 (pCi/kg) Isotopic a Green Beans Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 Ingestion (pCi/kg) Isotopic a Tomatoes Ingestion Gamma 2 Various b < LLD (0/1) < LLD < LLD < LLD (0/1) 0 (pCi/kg) Isotopic a NOTES

a. Natural occurring radionuclides were observed in local crop samples in 2018

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

Table H Monthly Surface Water Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Gamma Surface Water Direct 26 Various c < LLD (0/13) < LLD < LLD < LLD (0/13) 0 Isotopic a Exposure (pCi/L)

Tritium b 8 2000 < LLD (0/4) < LLD < LLD < LLD (0/4) 0 NOTES

a. Natural occurring radionuclides were observed in surface water samples in 2018.

b. Tritium analysis of surface water is required quarterly per the BFN ODCM.

c. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

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APPENDIX H Table H Monthly Public Drinking Water Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range 3.40 (2/52) 4.04 (1/13)

Gross Beta 65 4.0 TRM 286.5 < LLD (0/13) 0 Drinking Water 2.75 - 4.04 4.04 - 4.04 Ingestion Gamma 65 Various b < LLD (0/52) < LLD < LLD < LLD (0/13) 0 (pCi/L) Isotopic a Tritium c 20 2000 < LLD (0/16) < LLD < LLD < LLD (0/4) 0 NOTES

a. Natural occurring radionuclides were observed in drinking water samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

c. Tritium analysis of drinking water is required quarterly per the BFN ODCM.

Table H Quarterly Well (Ground) Water Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Gamma 26 Various b < LLD (0/13) < LLD < LLD < LLD (0/13) 0 Ground Water Isotopic a Ingestion (pCi/L) 913 (2/4) 913 (2/4)

Tritium 8 2000 Well #6R, 0.12 Mi., NW < LLD (0/4) 0 776 - 1050 776 - 1050 NOTES

a. Natural occurring radionuclides were observed in ground water samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

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APPENDIX H Table H Semi-Annual Fish Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Game Fish - Large Mouth Bass Gamma 4 Various b < LLD (0/2) < LLD < LLD < LLD (0/2) 0 Ingestion Isotopic a (pCi/kg)

Commercial Fish -

Channel Catfish Gamma 6 Various b < LLD (0/4) < LLD < LLD < LLD (0/2) 0 Ingestion Isotopic a (pCi/kg)

NOTES

a. Natural occurring radionuclides were observed in fish samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

Table H Semi-Annual Shoreline Sediment Radioactivity All Indicator Location with Highest Annual Mean All Control Sample Lower Limit Non-routine Type and Number of Locations Locations Pathway of Detection Name, Distance and Reported Analysis Performed Mean (Count) Mean (Range) Mean (Count)

(Measurement Unit) (LLD) Direction Measurements Range Range Shoreline Sediment Gamma Direct Radiation 6 Various b < LLD (0/4) < LLD < LLD < LLD (0/2) 0 Isotopic a (pCi/kg)

NOTES

a. Natural occurring radionuclides were observed in shoreline sediment samples in 2018.

b. See Table E-1 through Table E-4 for the required and nominal LLDs for individual radionuclides via gamma isotopic analysis.

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APPENDIX I ERRATA TO PREVIOUS ANNUAL ENVIRONMENTAL OPERATING REPORTS

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APPENDIX I Errata to Previous AREORs

1. In the 2017 Browns Ferry AREOR, the acronym CF was not defined as Charcoal Filter in the table describing the Browns Ferry REMP Sampling locations. This has been added to the 2018 AREOR, see Table A-2. (CR 1425931)

2. The 2017 Browns Ferry AREOR did not fully describe the results of the interlaboratory cross check program. For 2017, the radioanalytical lab participated in a number of independent cross check programs, including the National Institute of Standards and Technology (NIST) and Analytics cross-check programs (CR 1493388). The information on the 2017 interlaboratory cross check program is below.

Per the 2017 Annual Environmental Quality Assurance (QA) Report, GEL was provided ninety-two (92) individual environmental analyses. The accuracy of each result reported to Eckert & Ziegler Analytics, Inc. is measured by the ratio of GELs result to the known value. All results fell within GELs acceptance criteria (100%).

In the 1st quarter of 2017, the gross alpha analysis for water samples did not meet the applicable performance evaluation. This condition was identified and documented by GEL, via CARR170227-1085. The sample was re-analyzed with an acceptable result. In the 3rd quarter of 2017, the I-131 analysis for water was not acceptable. GEL CARR170828-1125 documented the issue, and the lab determined that the observed positive bias was an isolated occurrence and the laboratorys overall process is in control.

The radioanalytical lab performance in 2017 meets the criteria described in Reg. Guide 4.15 and ANSI/HPS N13.37-2014.

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