Text

Annual Radioactive Effluent Release Report
	ML20132A117
Person / Time
Site:	Clinton
Issue date:	12/31/2019
From:	Rathbun B; Exelon Generation Co
To:	; Office of Nuclear Reactor Regulation
References
	U-604546
	Download: ML20132A117 (108)
	v • d • e

January 01, 2019 - December 31, 2019 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT CLINTON POWER STATION-DOCKET NUMBER 50-461 Prepared by:

Briana Rathbun Clinton Power Station Page 1 of 108

TABLE OF CONTENTS SECTION#

TITLE PAGE 1

Executive Summary 5

2 Introduction 6

3 Supplemental Information 12 4

Radioactive Effluent Data 16 5

Solid Waste Disposal Information 27 6

Dose Measurements and Assessments 30 7

Meteorological Data and Dispersion Estimates 42 8

ODCM Operational Remedial Requirement Report 101 9

Changes to Radioactive Waste Treatment Systems 103 10 New Locations for Dose Calculation and/or Environmental Monitoring 104 11 Corrections to Data Reported in Previous Reports 107 12 Changes to the Offsite Dose Calculation Manual 108 Page 2 of 108

LIST OF TABLES TABLE#

TITLE PAGE Gaseous Effluents - Summation of All Releases 16 1

lA Air Doses Due to Gaseous Releases 17 1B Doses to a Member of the Public Due to Radioiodines, Tritium, 17 Carbon-14, and Particulates in Gaseous Releases 2

Gaseous Effluents - Nuclides Released 18 3

Radioactive Gaseous Waste LLD Values 19 4

Waterborne Effluents - Summation of All Releases 21 5

Waterborne Effluents - Nuclides Released 22 6

Radioactive Liquid Waste LLD Values 23 7

Solid Waste and Irradiated Fuel Shipments 28 8

Maximum Offsite Doses and Dose Commitments to Members of the Public 31 in Each Sector Calculated Doses to Members of the Public During Use of the Department 9

of Natural Resources Recreation Area in the East-Southeast Sector within 35 the CPS Site Boundary 10 Calculated Doses to Members of the Public During Use of the Road in the 36 Southeast Sector within the CPS Site Boundary 11 Calculated Doses for the Residents in the South-Southeast Sector within 37 the CPS Site Boundary 12 Calculated Doses for the Residents in the Southwest Sector within the CPS 38 Site Boundary 13 Calculated Doses to Members of the Public During Use of the Agricultural 39 Acreage in the South-Southwest Sector within the CPS Site Boundary 14 Calculated Doses for the Residents in the West-Southwest Sector within 40 the CPS Site Boundary 15 Calculated Doses to Members of the Public During Use of Clinton Lake in 41 the Northwest Sector within the CPS Site Boundary 16 Meteorological Data Availability 43 17 Classification of Atmospheric Stability 44 18 Joint Wind Frequency Distribution by Stability Class 45 Page 3 of 108

LIST OF FIGURES FIGURE#

TITLE PAGE 1

CPS Airborne Effluent Release Points 7

2 CPS Waterborne Effluents Release Pathway 8

3 Effluent Exposure Pathways 10 4

Areas Within the CPS Site Boundary Open to Members of the Public 34 Page 4 of 108

SECTION 1 EXECUTIVE

SUMMARY

The Annual Radioactive Effluent Release Report {ARERR) is a detailed description of gaseous and liquid radioactive effluents released from Clinton Power Sta.tion (CPS) and the resulting radiation doses for the period of January 01, 2019 through December 31, 2019. This report also includes a detailed meteorological section providing weather history of the surrounding area during this period. The information in the ARERR is used to calculate the offsite dose to our public.

The report also includes a summary of the amounts of radioactive material contained in solid waste that is packaged and shipped to a federally approved disposal/burialfacility offsite.

Additionally, this report notifies the U.S. Nuclear Regulatory Commission {NRC) staff of changes to CPS's Offsite Dose Calculation Manual (ODCM), as well as exceptions to the CPS effluent monitoring program and a summary of events that must be reported in accordance with ODCM Section 6.2.

The NRC requires that nuclear power facilities be designed, constructed and operated in such a manner as to maintain radioactive effluent releases to unrestricted areas As 10w As Reasonably Achievable {ALARA). To ensure compliance with this criterion, the NRC has established limitations governing the release of radioactivity in effluents.

During 2019, CPS operations were well within these federally required limits. The maximum annual radiation dose delivered to the inhabitants of the area surrounding CPS, due to radioactivity released from the station, was 3.89E-02 mRem (millirem). The radiation dose to the public in the vicinity of CPS was calculated by using the concentration of radioactive nuclides from each gaseous effluent release coupled with historical weather conditions. The dose from CPS gaseous radioactive effluents is only a small fraction of the limit {2.59E-01%) for the maximum exposed member of the public. There were no liquid effluent releases in 2019.

As such, there was no dose received by the public from the liquid radioactive effluent pathway.

Page 5 of 108

SECTION 2 INTRODUCTION CPS is located in Harp Township, DeWitt County approximately six miles east of the city of Clinton in east-central Illinois.

CPS is a ~1,140 megawatt gross electrical power output boiling water reactor. Initial fuel load commenced in September of 1986 with initial criticality of the reactor occurring on February 27, 1987. Commercial operation commenced in April 1987 and the reactor reached 100% power for the first time on September 15, 1987.

CPS releases airborne effluents via two gaseous effluent release points to the environment. They are the Common Station Heating, Ventilating, and Air Conditioning (HVAC)

Vent Stack and the Standby Gas Treatment System (SGTS) Vent as shown in Figure 1. Each gaseous effluent release point is continuously monitored consisting of a surveillance program of periodic sampling and analysis as specified in the ODCM.

CPS is licensed to release radioactive liquid effluents in a batch mode, however there were no radioactive liquid releases in 2019 at CPS. Each release would have been sampled and analyzed prior to release if this were to occur. Depending upon the amount of activity in a release, liquid effluents would vary from 10 to 300 gallons per minute (GPM). This volume is further combined with both Plant Service Water flow, which is a minimum of approximately 5,000 GPM, along with Plant Circulating Water flow, another Oto 567,000 GPM, in the seal well, just prior to entering the 3.4-mile discharge flume into Lake Clinton as depicted in Figure 2.

Processing and Monitoring CPS strictly controls effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria. Effluent controls include the operation of radiation monitoring systems within the plant as well as an offsite environmental analysis program. In-plant radiation monitoring systems are used to provide a continuous indication of radioactivity in effluent streams. Some are also used to collect particulate and radioiodine samples. Radioactive effluent related samples are analyzed in a controlled laboratory environment to identify the specific concentration of those radionuclides being released.

Sampling and analysis provides a more sensitive and precise method of determining effluent composition to complement the information provided by real-time radiation monitoring instruments.

Beyond the plant itself, a Radiological Environmental Monitoring Program (REMP) is maintained in accordance with Federal Regulations. The purpose of the REMP program is to assess the radiological impact on the environment due to the operation of CPS. Implicit in this charter is the license requirement to trend and assess radiation exposure rates and radioactivity concentrations that may contribute to dose to the public. The program consists of two phases; pre-operational and operational. During the pre-operational phase of the program, the baseline for the local radiation environment was established. The operational phase of the program includes the objective of making confirmatory measurements to verify that the in-plant controls for the release of radioactive material are functioning as designed.

Assessment of the operational impact of CPS on the environment is based on data collected since initial criticality of the reactor.

Page 6 of 108

FIGURE 1 CPS AIRBORNE EFFLUENT RELEASE POINTS I

I CONTAINMENT BUILDING FUa BUllDING ROOF EL 800'0" TURBINE BUILDING ROOF EL 875'0" RADWASTE AHO MACHINE SHOP BUILDING ROOF EL 781'0" COKTROL ROOM AIRHANDUNG UNITS I

L_ _____ =:y SGTS Fll1ER UNITS

(~ EL 719'0")

Release Point Height (feet)

Building Height (feet)

Release Point Geometry Release Point Area (ft2)

Release Point Diameter (feet)

Annual Average Flow Rate (ft3/sec)

Vertical Exit Velocity (feet/sec)

Effective 2(A/n) 112 diameter HVAC Exhaust Vent 200 190 Duct 120 12*

3,945 33 SGTS Exhaust Vent 200 190 Pipe 2

1 67 41 Page 7 of 108

FIGURE 2 CPS WATERBORNE EFFLUENTS RELEASE PATHWAY PLANT SERVICE WATER

.,. RW,s~ocf.

..t (AT LEAST $000 GPM)

(W'TO tS,')

t

.. '~l:lWCtO......,........_._ __ "T"J-_.

I LIQUID RADWASTE DISCHARGE LINE

( 10-00 OR 60-300 GPMl

@. RAOtATIO.NJ~ONITOR

.I..ARMlmlP SETPO!Nl' c.i.u::ut.mro BASED 00 ~.B)l'CH lSOTOPto IJUJYSIS #.NO Dtwrt0NR.OW M lSOl).TlON VALVE TERMIWJES R9.EA.SE ON HIGH RADWION.

H\\GH RB.EASE F1J1N ~

OR l!1H OIWTlOH FLOW M"E SEALWELL EJ COMPOSITE SAMPLER o:x.t.£Ci8 IJlPR0)3WJ'ElY 20 ml EVERY~ MINUTES FROM 11£ DISCHARGE FWME FORMONtHlY I.WJYSIS Pl. ANT ClRCULATING ~---.-..-----__......._-----'------:--__..._.

LAKE OlJNTON WATER (0-567,000 GPM)

DISCHARGE. FLUME 3.4 MILES Page 8 of 108

Exposure Pathways A radiological exposure pathway is the vehicle by which the public may become exposed to radioactivity released from nuclear facilities. The major pathways of concern are those that could cause the highest calculated radiation dose. These pathways are determined from the type and amount of radioactivity released, the environmental transport mechanism and how the plant environs are used (i.e., residence, gardens, etc.). The environmental transport mechanism includes the historical meteorological characteristics of the area that are defined by wind speed and wind direction. This information is used to evaluate how the radionuclides will be distributed within the surrounding area. The most important factor in evaluating the exposure pathway is the use of the environment by the public living around CPS. Factors such as location of homes in the area, use of cattle for milk and the growing of gardens for vegetable consumption are important considerations when evaluating exposure pathways. Figure 3 illustrates the effluent exposure pathways that were considered.

The radioactive gaseous effluent exposure pathways include direct radiation, deposition on plants and soil and inhalation by animals and humans. The radioactive liquid effluent exposure pathways include fish consumption and direct exposure from Clinton Lake.

Dose Assessment Whole body radiation involves the exposure of all organs in the human body to ionizing radiation. Most naturally occurring background radiation exposures consist of whole body exposure although specific organs can receive radiation exposure from distinct radionuclides.

These radionuclides enter the body through inhalation and ingestion and seek different organs depending on the nuclide. For example, radioactive iodine selectively concentrates in the thyroid, radioactive strontium in mineralized bone, and radioactive cesium collects in muscle and liver tissue.

The total dose to organs from a given radionuclide also depends on the amount of activity in the organ and the amount of time that the radionuclide remains in the body. Some radionuclides remain for very short periods of time due to their rapid radioactive decay and/or elimination rate from the body, while others may remain longer.

Radiation dose to the public in the area surrounding CPS is calculated for each release using historical weather conditions coupled with the concentrations of radioactive material present. The dose is calculated for all sixteen geographical sectors surrounding CPS and includes the location of the nearest residents, vegetable gardens producing broad leaf vegetables and dairy animals in all sectors. The calculated dose also uses the scientific concept of a "maximum exposed individual" and "standard man," and the maximum use factors for the environment, such as how much milk an average person consumes and how much air a person breathes in a year.

Section 6 contains more detailed information on dose to the public.

Page 9 of 108

ANIMALS (MILK, MEAT) t CONSUMED BY ANIMALS FIGURE 3 EFFLUENT EXPOSURE PATHWAYS CONSUMED BY PEOPLE

~

PEOPLE it fCONSUMEO BY PEOPLE J4 CONSUMED

'4 BY PEOPLE

/

\\

CLINTON POWER STATION RELEASES DILUTED BY LAKE FISH Page 10 of 108

Gaseous Effluents Gaseous effluent radioactivity released from CPS is classified into two (2) categories.

The first category is noble gases. The second category consists of 1131, 1133, H3, C14 and all radionuclides in particulate form with radioactive half-lives greater than eight (8) days. Noble gases - such as xenon and krypton - are biologically and chemically non-reactive. As such, these radionuclides - specifically Kr85m, Xe133 and Xe 135 - are the major contributors to external doses.

1131, 1133, H3, C14 and radionuclides in particulate form with radioactive half-lives greater than eight (8) days are the major contributors to internal doses.

Liquid Effluents Liquid effluents may originate from two (2) sources at CPS. The first is effluent from the Radioactive Waste Treatment System. This water is demineralized prior to release, and samples are taken after the tank has been allowed to adequately recirculate. The second is from heat exchanger leaks found in closed cooling water systems that service radioactively contaminated systems. This second source would be considered an abnormal release if to occur. As a matter of station management commitment, CPS strives to be a zero (0) radioactive liquid release plant. The last radioactive liquid release occurred in September of 1992.

Solid Waste Shipments To reduce the radiation exposure to personnel and maintain the federally required ALARA concept, the NRC and the Department of Transportation (DOT) have established limits on the types of radioactive waste and the amount of radioactivity that may be packaged and shipped offsite for burial or disposal. To ensure that CPS is complying with these regulations, the types of waste and the radioactivity present are reported to the NRC.

Page 11 of 108

I.

REGULATORY LIMITS SECTION 3 SUPPLEMENTAL INFORMATION The NRC requires nuclear power facilities to be designed, constructed and operated in such a way that the radioactivity in effluent releases to unrestricted areas is kept ALARA. To ensure these criteria are met, each license authorizing nuclear reactor operation includes the Offsite Dose Calculation Manual governing the release of radioactive effluents. The ODCM designates the limits for release of effluents, as well as the limits for doses to the general public from the release of radioactive liquids and gases. These limits are taken from Title 10 of the Code of Federal Regulations, Part 50, Appendix I (10CFR50 Appendix I), Title 10 of the Code of Federal Regulations, Part 20.1301 (10CFR20.1301) and Section 5.5.4 of Clinton Station's Technical Specifications. Maintaining effluent releases within these operating limitations demonstrates compliance with ALARA principles.

Specific limit information is given below.

A.

Gaseous Effluents

1.

The maximum permissible concentrations to limit doses for gaseous effluents shall not exceed the values provided within Section 5.5.4.g of Station's Technical Specifications. To ensure these concentrations are not exceeded, dose rates due to radioactive materials released in gaseous effluents from the site to areas at and beyond the site area boundary shall be limited to the following:

a.

Noble gases Less than or equal to 500 mRem/year to the total body.

Less than or equal to 3,000 mRem/year to the skin.

b.

1131, 1133, H3, C14, and all radionuclides in particulate form with radioactive half-lives greater than eight (8) days:

Less than or equal to 1,500 mRem/year to any organ.

2.

In accordance with 10CFR50 Appendix I, air dose due to noble gases released in gaseous effluents to areas at and beyond the site boundary shall be limited to the following:

a.

Less than or equal to 5 mRad for gamma radiation and less than or equal to 10 mRad for beta radiation during any calendar quarter.

b.

Less than or equal to 10 mRad for gamma radiation and less than or equal to 20 mRad for beta radiation during any calendar year.

3.

In accordance with 10CFR50 Appendix I, _dose to a member of the public (from 1131, 1133, H3, C14, and all radionuclides in particulate form with radioactive half-Page 12 of 108

lives greater than eight (8) days) in gaseous effluents released to areas at and beyond the site boundary shall be limited to the following values:

a.

Less than or equal to 7.5 mRem to any organ, during any calendar quarter.

b.

Less than or equal to 15 mRem to any organ, during any calendar year.

B. Liquid Effluents

1.

The concentration of radioactive material released in liquid effluents to unrestricted areas shall be limited to the values provided within Section 5.5.4.b of Station's Technical Specifications for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.0E-04 µCi/ml total activity.

2.

The dose or dose commitment to a member of the public from radioactive materials in liquid effluents released to unrestricted areas shall be limited to:

a.

Less than or equal to 1.5 mRem to the total body and less than or equal to 5 mRem to any organ during any calendar quarter.

b.

Less than or equal to 3 mRem to the total body and less than or equal to 10 mRem to any organ during any calendar year.

The above gaseous and liquid effluent limits are just a fraction of the dose limits established by the Environmental Protection Agency (EPA) found within Environmental Dose Standard Title 40, Code of Federal Regulations, Part 190 (40CFR190). The EPA has established dose limits for members of the public in the vicinity of a nuclear power plant. These dose limits are:

Less than or equal to 25 mRem per year to the total body.

Less than or equal to 75 mRem per year to the thyroid.

Less than or equal to 25 mRem per year to any other organ.

II.

AVERAGE ENERGY The CPS ODCM limits the dose equivalent rates due to the release of fission and activation gases to less than or equal to 500 mRem per year to the total body and less than or equal to 3,000 mRem per year to the skin. These limits are based on dose calculations using actual isotopic concentrations from our effluent release streams and not based upon the gross count rate from our monitoring systems. Therefore, the average beta and gamma energies for gaseous effluents as described in Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," are not applicable.

Ill.

MEASUREMENT AND APPROXIMATIONS OF TOTAL RADIOACTIVITY Page 13 of 108

A.

Fission and Activation Gases

1.

Gas samples are collected weekly and are counted on a high purity germanium detector (HPGe) for principal gamma emitters.

The HVAC and SGTS release points are continuously monitored and the average release flow rates for each release point are used to calculate the total activity released during a given time period.

2.

Tritium is also collected by passing a known volume of the sample stream through a gas washer containing a known quantity of demineralized water. The collected samples are distilled and analyzed by liquid scintillation. The tritium released was calculated for each release point from the measured tritium concentration, the volume of the sample, the tritium collection efficiency, and the respective stack exhaust flow rates.

3.

Carbon-14 release values were estimated using the methodology included in the EPRI Technical Report 1021106, using the 2019 Clinton Power Station specific parameters of normalized Carbon-14 production rate of 5.049 Ci/GWt-yr, a gaseous release fraction of 0.99, a Carbon-14 carbon dioxide fraction of 0.95, a reactor power rating of 3473 MWt, and equivalent full power operation of 320.2 days.

B.

Iodines Iodine is continuously collected on a silver zeolite cartridge filter via an isokinetic sampling assembly from each release point. Filters are normally exchanged once per week and then analyzed on an HPGe system. The flow rates for each release point are averaged over the duration of the sampling period and these results - along with specific isotopic concentrations -

are then used to determine the total activity released during the time period in question.

C.

Particulates Particulates are continuously collected on a filter paper via an isokinetic sampling assembly on each release point. Filters are normally exchanged once per week and then analyzed on an HPGe system. The flow rates for each release point are averaged over the duration of the sampling period and these results - along with specific isotopic concentrations -

are then used to determine the total activity released during the time period in question.

D.

Liquid Effluents Each tank of liquid radwaste is recirculated for at least two (2) tank volumes, sampled and analyzed for principal gamma emitters prior to release. Each sample tank is recirculated for a sufficient amount of time prior to sampling ensuring that a representative sample is obtained.

Samples are then analyzed on an HPGe system and liquid release permits are generated based upon the values obtained from the isotopic analysis and the most recent values for H3, gross alpha, Fess, Sr89 and Sr90. An aliquot based on release volume is saved and added to composite containers. The concentrations of composited isotopes and the volumes of the releases associated with these composites establish the proportional relationships that are then utilized for calculating the total activity released for these isotopes. However, there has not been a radioactive liquid release since September of 1992.

Page 14 of 108

IV.

DESCRIPTION OF ERROR ESTIMATES Estimates of measurement and analytical error for gaseous and liquid effluents are calculated as follows:

where:

Er= total percent error E1... EN = percent error due to calibration standards, laboratory analysis, instruments, sample flow, etc.

Page 15 of 108

SECTION 4 RADIOACTIVE EFFLUENT DATA TABLE 1 Gaseous Effluents - Summation Of All Releases Data Period: January 01, 2019 - December 31, 2019 Continuous Mixed Mode Units Quarter 1 Quarter 2 Quarter 3 A. Fission & Activation Gases

1.

Total Release Ci 5.83E+OO 7.46E+OO 1.63E+02

2.

Average release rate

µCi/sec for period 7.49E-01 9.49E-01 2.0SE+Ol

3.

Percent of ODCM Limit B. Iodines

1.

Total lodine-131 Ci 1.48E-05 1.80E-05 5.06E-05

2.

Average release rate

µCi/sec for period 1.90E-06 2.29E-06 6.36E-06

3.

Percent of ODCM Limit C. Particulates

1.

Particulates with Ci half-lives >8 days 2.70E-06 4.38E-06 1.SOE-04

2.

Average release rate

µCi/sec for period 3.47E-07 5.57E-07 1.88E-05

3.

Percent of ODCM Limit D. Tritium

1.

Total Release Ci 6.17E+OO 6.23E+OO 9.27E+OO

2.

Average release rate

µCi/sec for period 7.93E-01 7.92E-01 1.17E+OO

3.

Percent of ODCM Limit E. Gross Alpha

1.

Total Release Ci

<LLD

2.

Average release rate

µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO for period F. Carbon-14

1.

Total Release Ci 4.24E+OO 4.27E+OO 3.39E+OO

2.

Average release

µCi/se.c Rate for period 5.56E-01 5.57E-01 5.57E-01 Quarter 4 Est. Total Error,%

1.llE+Ol 3.00E+Ol 1.40E+OO 1.89E-06 3.lOE+Ol 2.37E-07 6.88E-05 2.40E+Ol 8.66E-06 8.32E+OO 2.lOE+Ol 1.0SE+OO

<LLD 0.00E+OO 3.49E+OO 5.56E-01 Applicable limits are expressed in terms of dose. See Tables lA and 18 of this report.

Page 16 of 108

TABLE 1A Air Doses Due to Gaseous Releases Doses per Quarter (mRad)

Type of ODCM 1st Quarter

% of Limit 2nd

% of Limit 3rd

% of Limit 4th Quarter

% of Limit Radiation Limit Quarter Quarter Gamma 5

2.70E-04 5.39E-03 3.48E-04 6.91E-03 7.23E-03 1.45E-01 5.14E-04 l.03E-02 mRad Beta 10 9.51E-05 9.51E-04 1.22E-04 1.22E-03 2.53E-03 02.53E-1.81E-04 1.81E-04 mRad 03 Doses per Year (mRad)

Type of Radiation ODCM Limit Year

% of Limit Gamma 10 mRad 8.36E-03 8.36E-02 Beta 20 mRad 2.92E-03 1.46E-02 TABLE 1B Doses to a Member of the Public Due to Radioiodines, Tritium, Carbon-14, and Particulates in Gaseous Releases Doses per Quarter (mRem)

Organ ODCM 1st

% of 2nd

% of 3rd

% of 4th

% of Limit Quarter Limit Quarter Limit Quarter Limit Quarter Limit Bone 7.5 mRem 1.08E-02 l.44E-01 l.09E-02 1.45E-01 8.62E-03 1.15E-01 8.62E-03 l.15E-01 Liver 7.5 mRem 1.02E-04 l.36E-03 l.03E-04 1.37E-03 1.57E-04 2.09E-03 l.39E-04 l.85E-03 TBody 7.5 mRem 2.25E-03 3.0lE-02 2.27E-03 3.02E-02 1.90E-03 2.53E-02 3.71E-03 4.95E-02 Thyroid 7.5 mRem 1.53E-04 2.04E-03 l.66E-04 2.21E-03 3.25E-04 4.33E-03 l.43E-04 l.91E-03 Kidney 7.5 mRem 1.02E-04 1.36E-03 l.03E-04 1.37E-03 1.55E-04 2.07E-03 1.38E-04 1.84E-03 Lung 7.5 mRem 1.02E-04 1.36E-03 l.03E-04 1.37E-03 1.54E-04 2.05E-03 1.37E-04 1.83E-03 GILLI 7.5 mRem 1.02E-04 l.36E-03 l.03E-04 1.37E-03 1.64E-04 2.19E-03 1.43E-04 1.91E-03 Doses per Year (mRem)

Type of Organ ODCM Limit Dose

% of Limit Bone 15 mRem 3.89E-02 2.59E-01 Liver 15 mRem 5.00E-04 3.33E-03 TBody 15 mRem 1.0lE-02 6.75E-02 Thyroid 15 mRem 7.88E-04 5.25E-03 Kidney 15 mRem 4.97E-04 3.32E-03 Lung 15 mRem 4:95E-04 3.30 E-03 GILLI 15 mRem 5.12E-04 3.41 E-03 Page 17 of 108

Mixed Mode Release Elevated Release Ground-Level Release

?!it }issig:o :G:~~~~e,~ *',..

XeBs Krssm Xe133 Krss Ar41 Total for Period B. Iodines 1131 1133 Total for Period C. Particulates Co6o y91m [2]

Nbgs ce141 crs1 Mns4 Na24 c21 Cd109 Cs138 c21 Coss zn6s Total for Period D. Gross Alpha Gross Alpha E. Tritium Total for Period F. Carbon-14 Total for Period TABLE 2 Gaseous Effluents - Nuclides Released Clinton Power Station VEAR: 2019 X

I Continuous Mode Batch Mode Units Quarter 1[11 Quarter 2[ 11 Quarter 3[11 X

Quarter 4[11

.. }.. \\* ; /;,.*.~ -_ :._z(

,; :r..

__,;_.'.:tff.:: "':.;(c*'_... _.*_.::f' *.. ::,,:

... ~

o.0 Ci

<LLD

<LLD 1.28E+OO

<LLD Ci

<LLD

<LLD 5.26E+OO

<LLD Ci

<LLD

<LLD 6.71E+OO

<LLD Ci

<LLD

<LLD 8.77E+OO

<LLD Ci 5.83E+OO 7.46E+OO 1.41E+02 1.llE+Ol Ci 5.83E+OO 7.46E+OO 1.63E+02 1.llE+Ol Ci 1.48E-05 1.80E-05 6.40E-05

<LLD Ci 3.59E-05 6.21E-05 5.06E-05 1.88E-06 Ci 5.07E-05 8.0lE-05 1.lSE-04 l.88E-06 Ci 7.44E-08

<LLD 6.58E-06 3.56E-06 Ci 4.38E-04

<LLD

<LLD Ci

<LLD 2.84E-08

<LLD

<LLD Ci 2.62E-06 1.0lE-07

<LLD

<LLD Ci

<LLD 2.70E-07

<LLD 1.08E-05 Ci

<LLD 3.98E-06 l.14E-04 4.90E-05 Ci 3.33E-05 3.lOE-05

<LLD

<LLD Ci

<LLD

<LLD 1.0SE-05

<LLD Ci

<LLD

<LLD 3.13E-01

<LLD Ci

<LLD

<LLD l.53E-06 1.47E-06 Ci

<LLD

<LLD 3.27E-06 3.97E-06 Ci 4.74E-04 3.54E-05 3.13E-01 6.88E-05 Ci

<LLD

<LLD Ci 6.17E+OO 6.23E+OO 9.27E+OO 8.32E+OO Ci 4.24E+OO 4.27E+OO 3.39E+OO 3.49E+OO 111 The lower the value of the actual sample activity - with respect to background activity -

the greater the counting error. Proportionally, large errors are reported for the various components of CPS gaseous effluents because of their consistent low sample activity.

[zJ Half-life is less than 8 days, therefore not included in Table 1 Summation.

Page 18 of 108

TABLE 3 Radioactive Gaseous Waste LLD Values TYPE OF ACTIVITY ANALYSIS Lower Limit of Detectiona

(µCi/cc)

Principal Gamma Emitters,

1.ooE-04

[Noble Gases] b,c H3C

1.ooE-06 1131 d

1.ooE-12 1133 d

s;l.OOE-10 Principal Gamma Emitters,

s;l.OOE-11

[Particulates] b,e Srs9, Srgo g

s;l.QOE~11 Gross Alphaf

s;l.OOE-11 Table 3 Notations:

a The Lower Limit of Detection (LLD) as defined for purposes of these specifications, as an "a priori" determination of the smallest concentration of radioactive material in a sample that will yield a net count - above system background - that will be detected with a 95% probability and with a low (5%) probability of incorrectly concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

Where:

LLD =

4.66. Sb E

V

2.22 x 106

Y. e-M.t LLD is the "a priori" lower limit of detection as defined above, as µCi per unit mass or volume, Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate, in counts per minute (cpm),

Page 19 of 108

Table 3 Notations (continued):

Eis the counting efficiency, in counts per disintegration, Vis the sample size in units of mass or volume, 2.22E+06 is the number of disintegrations per minute (dpm) per microcurie, Y is the fractional radiochemical yield, when applicable,

'A is the radioactive decay constant for the particular radionuclide (sec-1) and

~t for plant effluents is the elapsed time between the midpoint of sample collection and the time of counting (sec).

Typical values of E, V, Y, and ~t should be used in the calculation.

The LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

b The principal gamma emitters for which the LLD specification applies include the following radionuclides: Kr87, Kr88, Xe133, Xe133m, Xe135, and Xe138 in noble gas releases and Mn 54, Fe 59, Co58, Co 60, Zn 65, Mo99, 1131, Cs134, Cs137, Ce 141, and Ce 144 in iodine and particulate releases.

This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable - together with those of the above nuclides - shall also be analyzed and reported in the Radioactive Effluent Release Report.

c Weekly grab sample and analysis d Continuous charcoal sample analyzed weekly e Continuous particulate sample analyzed weekly fComposite particulate sample analyzed monthly g Composite particulate sample analyzed quarterly Page 20 of 108

TABLE 4 Waterborne Effluents - Summation Of All Releases Data Period: January 01, 2019 - December 31, 2019 There were zero (O) liquid radwaste releases from CPS in 2019.

Units Quarter Quarter Quarter 1

2 3

A. Fission & Activation Products[ 11

1.

Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO Average diluted

2.

concentration

µCi/ml 0.00E+OO O.OOE+OO O.OOE+OO during period

3.

Percent of ODCM N/A N/A N/A Limit B. Tritium[1l

1.

Total Release Ci 0.00E+OO O.OOE+OO O.OOE+OO Average diluted

2.

concentration

µCi/ml O.OOE+OO O.OOE+OO 0.00.E+OO during period

3.

Percent of ODCM N/A N/A N/A Limit C. Dissolved and Entrained Gases[ 1l

1.

Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO Average diluted

2.

concentration

µCi/ml 0.00E+OO O.OOE+OO O.OOE+OO during period

3.

Percent of ODCM N/A N/A N/A Limit D. Gross Alpha Radioactivity[1l Gross alpha radioactivity Ci O.OOE+OO O.OOE+OO O.OOE+OO E. Volume of Waste Released (prior to Dilution)

Volume of Waste Released (prior to Liters O.OOE+OO O.OOE+OO O.OOE+OO Dilution)

F. Volume of dilution water used during period Volume of dilution water Liters O.OOE+OO O.OOE+OO O.OOE+OO used during period Est.

Quarter Total 4

Error,%

O.OOE+OO N/A O.OOE+OO N/A O.OOE+OO N/A O.OOE+OO N/A 0.00E+OO N/A O.OOE+OO N/A O.OOE+OO N/A O.OOE+OO N/A O.OOE+OO N/A

[ll A value corresponding to ten times the values found in 10CFR20 Appendix B, Table 2, Column 2 is used for all Effluent Concentration Limit (ECL} calculations. For dissolved and entrained noble gases, the concentration is limited to 2.00E-04 µCi/ml total activity.

Page 21 of 108

TABLE 5 Waterborne Effluents - Nuclides Released Clinton Power Station YEAR: 2019 There were zero (0) liquid radwaste releases from CPS in 2019.

I Continuous Mode Batch Mode Units Quarter 1 Quarter 2 Quarter 3 Quarter 4

'*p/4:r* *t**T<. \\ *.

C-:)

'.. *;\\. ;*. C*: *c. '/*:,' r.:*

... !.:..-.ri.1.1,tm,. /If.... :.,

,... _....... le.,.-.~..,

. c':'.F"'. *:>

,,,:, * :~.. :~;;i:r ' :.,*J~~:-- *,.,~\\:(. X. * ** ',. ::S.f-

,, *, '/

Total for Period Ci O.OOE+Oci O.OOE+OO 0.00E+OO O.OOE+OO B. Fission and Activation Products Mns4 Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Coss Ci O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO Fess Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Fesg Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Coss Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Co6o Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO zn6s Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Srsg Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Srgo Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Nbgs Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO Zrgs Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO Mogg Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 1131 Ci 0.00E+OO O.OOE+OO 0.00E+OO O.OOE+OO Cs134 Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO Csl37 Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO Ba140 Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO La140

.Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ce141 Ci 0.00E+OO O.OOE+OO 0.00E+OO O.OOE+OO ce144 Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Total for Period Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO C. Dissolved and Entrained Noble Gases Krssm Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Krs1 Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO Kras Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO xe133 Ci O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO Xe13s Ci O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO Xe138 Ci 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO Total for Period Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 22 of 108

TABLE 6 Radioactive Liquid Waste LLD Values TYPE OF ACTIVITY ANALYSIS Lower Limit of Detection (LLD) *

(µCi/ml)

Principal Gamma Emitters b

s;S.OOE-07 1131

1.00E-06 Dissolved and Entrained Gases

1.ooE-OS

{Gamma Emitters) c H3

1.ooE-OS Gross Alpha

1.ooE-01 srs9, Sr9o

s;S.OOE-08 Fess

s;l.OOE-06 Table 6 Notations:

a The Lower Limit of Detection (LLD) as defined for purposes of these specifications, as an "a priori" determination of the smallest concentration of radioactive material in a sample that will yield a net count - above system background - that will be detected with a 95% probability and with only a 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

Where:

LLD =

4.66. sb E

V

2.22 x 106

Y

e-AAt LLD is the "a priori" lower limit of detection as defined above, as µCi per unit mass or volume, Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate, in counts per minute (cpm),

Eis the counting efficiency, as counts per disintegration, Vis the sample size in units of mass or volume, 2.22E+06 is the number of disintegrations per minute (dpm) per microcurie, Page 23 of 108

Table 6 Notations (continued):

Y is the fractional radiochemical yield, when applicable,

'A is the radioactive decay constant for the particular radionuclide (sec-1) and Llt for plant effluents is the elapsed time between the midpoint of sample collection and the time of counting (sec).

Typical values of E, V, Y, and 'At should be used in the calculation.

The LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact, MDA) limit for a particular measurement.

b The principal gamma emitters for which the LLD requirement applies include the following radionuclides: Mn 54, Fe 59, Co 58, Co 60, Zn 65, Mo99, Cs134, Cs137, and Ce 141* Ce144 shall also be measured, but with an LLD of 5.0E-06. This list does not mean that only these nuclides are detected and reported. Other gamma peaks that are measurable -

together with those of the above nuclides - shall also be analyzed and reported in the Radioactive Effluent Release Report.

c Dissolved and entrained gases are: Xe 133, Xe 135, Xe138, Kr85 m, Kr87 and Kr88

Page 24 of 108

BATCH RELEASES There were zero (O) liquid radwaste releases from CPS in 2019.

A.

Batch Liquid Releases: 2019

1.

Number of batch releases:

0

2.

Total time period for batch releases:

N/A

3.

Maximum time period for batch release:

N/A

4.

Average time period for batch release:

N/A

5.

Minimum time period for batch release:

N/A

6.

Average stream flow during periods of release:

N/A

7.

Total waste volume:

N/A

8.

Total dilution volume:

N/A B.

Batch Gaseous Releases: 2019

1.

Number of batch releases:

0

2.

Total time period for batch releases:

N/A

3.

Maximum time period for batch release:

N/A

4.

Average time period for batch release N/A

5.

Minimum time period for batch release:

N/A Page 25 of 108

ABNORMAL RELEASES Information concerning abnormal radioactive liquid and gaseous releases is presented below for the year 2019. There were no abnormal or unplanned liquid or gaseous releases from CPS in 2019.

Liquid Releases:

Number of Abnormal Liquid Releases: Zero (0)

Activity Released [Ci]

Nuclides N/A Total Gaseous Releases:

Number of Abnormal Gaseous Releases: Zero (0)

Activity Released [Ci]

Nuclides N/A Total Activity [Ci]

0.0 0.0 Activity [Ci]

0.0 0.0 Page 26 of 108

SECTION 5 SOLID WASTE DISPOSAL INFORMATION During this reporting period -January 01, 2019 through December 31, 2019 - there were twenty-one (21) radioactive waste shipments and zero (0) irradiated fuel shipments from CPS.

In addition, the CPS ODCM requires reporting of the following information for solid waste shipped offsite during the above reporting period:

1. Container volume:

Class A Waste: 1.90E+04 ft3 / Class B Waste: 0.0 ft 3 / Class C Waste: 4.31E+OO ft3 This total includes Dry Active Waste (DAW), resins, filter sludges, evaporator bottoms, control rod blades, and other low level waste such as mixed waste.

2. Total curie quantity: Class A Waste was 7.20E+01 curies and Class B Waste was O.OOE+OO curies and Class C Waste was 3.81E+03 curies in 2019 (determined by dose-to-curie and sample concentration methodology estimates).

3. Principal radionuclides: See Table 7-A.2 for listing of measured radionuclides.

4. Source of waste and processing employed: Non-compacted dry active waste, resins, filter sludges and evaporator bottoms dewatered.

5. Type of container: General Design and Type B Containers.

6. Solidification agent or absorbent: None.

Page 27 of 108

TABLE 7 Solid Waste and Irradiated Fuel Shipments A.1 Estimate of Solid Waste Shipped Offsite for Burial or Disposal: [NOT irradiated fuel]

a.

b.

C.

d.

A.1 Type of Waste Spent resins, filter sludges, evaporator bottoms, etc.

Dry compactable waste, contaminated equipment, etc.

Irradiated components, control rods, etc. (not fuel)

Other Wastes-Mixed Units ft3 January - December 2019 2.30E+03 Est. Total Error, 2.50E+01 2.50E+01 2.50E+01 2.50E+01

Total curie quantity and principal radionuclides were determined by measurements.

A.2 Estimate of Major Nuclide Composition (by type of waste):

1. Spent resins, filters, evaporator bottoms, etc.

Waste Class Nuclide Name

% Percent Abundance Curies A

Mns4 39.06 2.65E+01 Fess 30.20 2.05E+01 Fes9 1.19 8.06E-01 Co6o 20.96 1.42E+01 Ni63 1.05 7.09E-01 zn6S 4.85 3.29E+OO

2.

Dry compactable waste, contaminated equipment, etc.

Waste Class Nuclide Name

% Percent Abundance Curies A

crsl 1.89 7,96E-02 Mns4 28.30 1.19E+OO Fess 46.06 1.94E+OO Fes9 1.08 7.57E-02 Co6o 18.40 7.73E-01 Zn6s 1.33 5.59E-02 C

Mns4 58.98 1.20E-02 Fess 16.54 3.36E-03 Co6o 21.24 4.31E-03 Sn6s 1.20 2.43E-04 Page 28 of 108

TABLE 7 (continued)

Solid Waste and Irradiated Fuel Shipments

3.

Irradiated Components Waste Class Nuclide Name

% Percent Abundance Curi es C

Fess 24.82 9.47E +02 Co6o 71.32 2.72E +03 Ni63 2.38 9.08E +01 Sb12s 1.24 4.72E +01

4.

Mixed Waste Waste Class Nuclide Name

% Percent Abundance Curi es C

Pu239 100 1.61E -06 A.3 Solid Waste Disposition:

January - December 2019 Number of Shipments Mode of Transportation Destination 9

Hittman Transport Energy Solutions-Clive, UT D Facility isposal 11 Hittman Transport Energy Solutions-Bear Cree k, TN 1

Hittman Transport Waste Control Specialist - And rews, TX B. Irradiated Fuel Shipments Disposition:

January - December 2019 Number of Shipments Mode of Transportation Destination 0

N/A N/A Pag e 29 of 108

SECTION 6 DOSE MEASUREMENTS AND ASSESSMENTS This section of the Annual Effluent Release Report provides the dose received by receptors around CPS from gaseous and liquid effluents. The dose to the receptor that would have received the highest dose in each sector (defined as the Critical Receptor for that sector) is listed within this report. This section also provides the dose to individuals who were inside the Site Boundary. This section also summarizes CPS's compliance with the requirements found within 40CFR190.

The 2019 maximum expected annual dose from Carbon-14 released from CPS has been calculated using the methodology included in the EPRI Technical Report 1021106 using the maximum gross thermal capacity maintained for 320.2 days of equivalent full power operation.

The assumptions used in determining dose values are as follows:

All receptors within a five (5) mile radius are included in the Annual Land Use Census. This Annual Census determines what dose pathways are present as well as the distance of each receptor from the site.

The annual average meteorological data for 2019 was used in conjunction with the Annual Land Use Census to determine the dose to each receptor within five (5) miles.

The doses for each receptor from each sector were determined using methodologies given in the ODCM.

The activity used in these assessments is the total activity released by CPS for the year 2019 not including radionuclides with half-lives less than eight (8) days and when dose pathway factors were available.

The occupancy factor was taken into consideration by calculating the dose to individuals using areas inside the Site Boundary in non-residential areas.

The occupancy factor is determined by dividing the number of hour(s) of occupancy per year (taken from the ODCM) and dividing that value by the total number of hour(s) per year.

Dose to individuals using areas inside the Site Boundary (that are not residents) was calculated using the Ground Plane and Inhalation pathways.

Page 30 of 108

TABLE 8 Maximum Offsite Doses and Dose Commitments To Members of the Public in Each Sector Data Period: January 01, 2019 - December 31, 2019 This table illustrates the dose that a member from the public would most likely be exposed to from radioactive effluents in each sector from CPS. These values represent the maximum dose likely to expose a member of the public in each sector.

AIRBORNE EFFLUENT DOSE WATERBORNE RECEPTOR INFORMATION EFFLUENT DOSE Iodines and Particulates Noble Gases

(mRem) 111 (mRem)

(mRad)

Distance Pathways Organ Skin Total Gamma Beta Organ Total Sector (km)

Organ Age Body Body N

1.50 GP, l,M,V B

A 2.39E-02 2.37E-OS S.18E-03 S.76E-03 2.76E-03 O.OOE+OO O.OOE+OO NNE 1.50 GP, I B

A 1.30E-03 3.54E-OS 4.39E-04 7.63E-03 3.66E-03 NE 2.07 GP, I, V B

A 4.89E-03 1.SlE-05 1.23E-03 3.90E-03 1.87E-03 ENE 2.86 GP, I, V B

A 3.72E,03 8.68E-06 9.31E-04 2.97E-03 1.42E-03 E

1.67 GP, I, V B

A S.12E-03 2.3SE-OS 1.29E-03 4.0BE-03 1.9SE-03 ESE 5.14 GP, I, V B

A 3.82E-03 6.SlE-06 9.53E-04 3.0SE-03 1.46E-03 SE 4.44 GP, I B

A 4.66E-04 6.90E-06 1.SSE-04 2.77E-03 1.33E-03 SSE 2.90 GP, I B

A 4.16E-04 8.BOE-06 1.39E-04 2.46E-03 1.18E-03 s

4.78 GP, I, M B

A S.68E-03 4.06E-06 1.19E-03 1.86E-03 8.90E-04 SSW 4.68 GP, I B

A 3.59E-04 4.04E-06 1.18E-04 2.14E-03 1.03E-03 SW 1.17 GP, I B

A 8.BSE-04 2.37E-OS 2.99E-04 S.21E-03 2.SOE-03 WSW 3.62 GP, I, M,V B

A 8.17E-03 4.59E-OS 1.BOE-03 1.96E-03 9.41E-04 w

1.95 GP, I B

T 1.48E-03 1.lOE-05 2.79E-04 3.0lE-03 1.44E-03 WNW 2.63 GP, I B

A 4.SSE-04 6.23E-OS 1.94E-04 2.62E-03 1.26E-03 NW 2.65 GP, I, V B

A 3.21E-03 S.89E-06 8.03E-04 2.57E-03 1.23E-03 NNW 2.05 GP, I, M,V B

A 1.44E-02 1.0SE-05 3.11E-03 3.46E-03 1.66E-03 Key for Table 8 Pathways Organ Age GP = Ground Plane B = Bone A= Adult I = Inhalation T = Teen M = Meat I= Infant V = Vegetation C = Child C1lThere were zero (O) liquid radwaste releases from CPS in 2019. All doses were within all regulatory limits, including limits from 40CFR190.

Page 31 of 108

COMPLIANCE WITH 40CFR190 REQUIREMENTS Dosimeter of Legal Records (DLRs) are stationed around CPS to measure the ambient gamma radiation field. Monitoring stations are placed near the site boundary, which includes the Independent Spent Fuel Storage Installation (ISFSI) pad, and approximately five (5) miles from the reactor, in locations representing the sixteen (16) compass sectors. Other locations are chosen to measure the radiation field at places of special interest such as nearby residences, meeting places and population centers. Control sites are located further than ten (10) miles from the site, in areas that should not be affected by plant operations. The results from the field dosimeters are reported in the Annual Radiological Environmental Operating Report (AREOR) and indicated no excess dose to offsite areas. The organ and whole body doses reported in the above tables are determined using 10CFR50 Appendix I methodology, which encompasses the limits of 40CFR190. The requirement requires the preparation and submittal of a Special Report whenever the calculated doses from plant generated radioactive effluents and direct radiation exceed 25 mRem to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mRem. During 2019, Clinton Power Station operated at 4.05E-02% of the 40CFR190 total body limit, 1.56E-01% of the 40CFR190 organ limit and 1.05E-3% 40CFR190 thyroid limit.

INDENDENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

No radioactive effluents were released from the Clinton Station ISFSI and no additional casks were placed on the pad for the period January 1, 2019 through December 31, 2019. Over the long term, as more storage modules containing dry shielded canisters of spent fuel are placed on the ISFSI pad, it is expected that ISFSI operations will become the prominent contributor to dose limits in this section. ISFSI dose contribution is in the form of direct radiation as no liquid or gas releases are expected to occur from the ISFSI canisters. The CPS 10CFR72.212 Report prepared in accordance with 10CFR72 requirements assumes a certain array of storage modules exists on the pad. The dose contribution from this array of casks combination with historical uranium fuel cycle operations prior to ISFSI operations was analyzed to be within 40CFR190 and 10CFR72.104 limits and is documented in Holtec Report No. Hl-2135750, Site Boundary Dose Rate Calculations for HI-STORM FW System for Clinton Power Station.

DOSE TO MEMBERS OF THE PUBLIC WITHIN THE SITE BOUNDARY CPS Offsite Dose Calculation Manual section 6.2 requires that the Radioactive Effluent Release Report include an assessment of the radiation doses from radioactive liquids and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY.

Within the CPS site boundary there are seven areas that are open to members of the public as identified by CPS ODCM Table 5-3 (see Figure 4):

The Department of Natural Resources Recreation Area at 1.287 kilometers (0.8 miles) in the ESE sector A road at 0.495 kilometers (0.3 miles) in the SE sector A residence at 2.736 kilometers (1.7 miles) in the SSE sector A residence at 1.219 kilometers (0.8 miles) in the SW sector Agricultural acreage at 1.372 kilometers (0.9 miles) in the SSW sector A residence at 2.414 kilometers (1.5 miles) in the WSW sector Page 32 of 108

A portion of Clinton Lake at 0.335 kilometers (0.2 miles) in the NW sector At all of the above locations, the plume, inhalation and ground-plane exposure pathways are used for dose calculations. The 2019 Annual Land Use Census identified no other exposure pathways. All dose calculations were performed using the methodology contained in the CPS ODCM, with the exception of dose due to C-14, which was calculated using methodology included in the EPRI Technical Report 1021106.

Page 33 of 108

FIGURE 4 AREAS WITHIN THE CPS SITE BOUNDARY OPEN TO MEMBERS OF THE PUBLIC TO CHAMPAIGN NOTES:

--1-.

2.

3.

4.

5.

6.

7.

Raad 0.3 miles in SE Sector Agricultural acreage 0.9 miles in SSW Sector Clinton Lake 0.2 miles in the NW Sector Department of Natural Resources Recreation Area 0.8 miles in ESE Sector Residence 0.8 miles in SW Sector Residence 1.5 miles in WSW Sector Residence 1.7 miles in SSE Sector Page 34 of 108

TABLE 9 Calculated Doses to Members of the Public During Use of the Department of Natural Resources Recreation Area in the East-Southeast Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION Total Body Dose Rate (Noble Gases)

Skin Dose Rate (Noble Gases)

Gamma Air Dose Beta Air Dose Total Body Dose[1l Skin Dose DOSE UNITS 1.03E-03 mRem/year 2.83E-03 mRem/year 1.84E-03 8.84E-04 1.60E-04 1.14E-05 mRad mRad mRem mRem

[ll Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 3.16E-04 4.48E-04 6.lSE-04 NA121 mRem mRem mRem mRem

[zJ Dose(s) are calculated only for the age groups likely to be in the field.

Page 35 of 108 i

TABLE 10 Calculated Doses to Members of the Public During Use of the Road in the Southeast Sector within the CPS Site Boundary Data Period: January 01, 2019 -December 31, 2019 DESCRIPTION DOSE UNITS Total Body Dose Rate {Noble Gases) 3.82E-04 mRem/year Skin Dose Rate {Noble Gases) 5.61E-04 mRem/year

,c',:

.,* *:.' h:

Gamma Air Dose 4.74E-04 mRad Beta Air Dose 2.27E-04 mRad Total Body Dose[ll 4.13E-05 mRem Skin Dose 3.18E-06 mRem

[ll Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 8.12E-05 1.lSE-04 1.58E-04 1.17E-04 mRem mRem mRem mRem Page 36 of 108

TABLE 11 Calculated Doses for the Residents in the South-Southeast Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION Total Body Dose Rate (Noble Gases)

Skin Dose Rate (Noble Gases)

Gamma Air Dose Beta Air Dose Total Body Dose[1l Skin Dose DOSE 2.21E-03 3.24E-03

{? C:.*'s*

01'*, ~*

2.53E-03 1.21E-03 2.lSE-04 9.56E-06 UNITS mRem/year mRem/year mRad mRad mRem mRem

[ll Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 4.28E-04 6.09E-04 8.38E-03 6.20E-04 mRem mRem mRem mRem Page 3 7 of 108

TABLE 12 Calculated Doses for the Residents in the Southwest Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION DOSE UNITS Total Body Dose Rate (Noble Gases) 4.39E-03 mRem/year Skin Dose Rate (Noble Gases) 6.44E-03 mRem/year Gamma Air Dose 5.02E-03 mRad Beta Air Dose 2.41E-03 mRad Total Body Dosel1J 4.29E-04 mRem Skin Dose 2.27E-05 mRem

[ll Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 8.53E-04 1.21E-03 1.67E-03 1.23E-03 mRem mRem mRem mRem Page 38 of 108

TABLE 13 Calculated Doses to Members of the Public During Use of the Agricultural Acreage in the South-Southwest Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION DOSE UNITS Total Body Dose Rate (Noble Gases) 3.52E-04 mRem/year Skin Dose Rate (Noble Gases) 5.17E-04 mRem/year Gamma Air Dose 4.03E-04 mRad Beta Air Dose 1.93E-04 mRad Total Body Dose[11 2.88E-05 mRem Skin Dose 2.llE-06 mRem ri1 Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 6.86E-05 9.74E-05 NA[2l NA[2l mRem mRem mRem mRem (21 Dose(s) are calculated only for the age groups likely to be in the field Page 39 of 108

TABLE 14 Calculated Doses for the Residents in the West-Southwest Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION Total Body Dose Rate (Noble Gases)

Skin Dose Rate (Noble Gases)

Q...

.., *t;;,,.,,,,.

..: ,r,,'

Gamma Air Dose Beta Air Dose Total Body Dose[1l Skin Dose DOSE 2.0SE-03 3.0lE-03 UNITS mRem/year mRem/year

, g,:*:.AY \\',

'-Jl;,5f';v;\\.. ~

\\ ',,.~<l".\\r:)(Z:,3'.' *), **'"'r,.-,[<,;'<, :::J 2.35E-03 1.13E-03 1.98E-04 7.61E-06 mRad mRad mRem mRem

[ll Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone 3.96E-04 5.64E-04 7.76E-04 5.74E-04 mRem mRem mRem mRem Page 40 of 108

TABLE 15 Calculated Doses to Members of the Public During Use of Clinton Lake in the Northwest Sector within the CPS Site Boundary Data Period: January 01, 2019 - December 31, 2019 DESCRIPTION Total Body Dose Rate (Noble Gases)

Skin Dose Rate (Noble Gases)

Gamma Air Dose Beta Air Dose Total Body Doser11 Skin Dose

...... q.*,,

DOSE 3.07E-03 4.SlE-03

~. t,* ~ '*,'i-2J***'.,,

3.SOE-03 1.68E-03 2.96E-04 1.26E-OS UNITS mRem/year mRem/year

'<i"-tt.,_.,,*,

. "**'t'*.

mRad mRad mRem mRem

"]

ri1 Dose includes the dose values resulting from the release of iodines, particulates (with half lives >8 days), tritium, and C-14 in gaseous effluents.

Highest Organ Dose by Age Group:

Adult Bone Teen Bone Child Bone Infant Bone S.90E-04 8.41E-04 1.16E-03 N/Ar21 mRem mRem mRem mRem r21 Dose(s) are calculated only for the age groups likely to be in the field Page 41 of 108

SECTION 7 METEOROLOGICAL DATA AND DISPERSION ESTIMATES On 13 April 1972, the meteorological monitoring program commenced at the Clinton Power Station site. The meteorological system consists of a tower 199 feet high with two (2) levels of instrumentation at the 10-meter and 60-meter elevations. A combined cup and vane sensor measures wind direction and wind speed(s) at the 10-meter and 60-meter levels. An aspirated dual temperature sensor senses the temperatures at these levels. One-half of the dual sensors at each elevation are used for ambient temperature while the other half are used to provide a differential temperature between the 10-meter and 60-meter levels.

Meteorological monitoring instruments have been placed on the Clinton Power Station backup meteorological tower at the 10-meter level to serve as a backup to the primary meteorological tower.

Clinton Power Station meteorological data is transmitted to the Main Control Room (MCR) via a dedicated communication link. Once the signals are received at the MCR, they are then converted to a 4 to 20 milliamp signal and fed individually to a microprocessor and chart recorders. The microprocessor is part of the Clinton Power Station Radiation Monitoring System (RMS). Meteorological data is available via the microprocessors in the Main Control Room and the Technical Support Center (TSC).

Dispersion modeling for effluents for normal operation of Clinton Power Station is a straight-line, sector-averaged Gaussian plume model designed to estimate average relative concentration at various receptor points. The model was developed in accordance with routine release analysis procedures specified in Regulatory Guide 1.111. For joint frequency input data, periods of calm are distributed in accordance with a directional distribution. For hourly input data, periods of calm are the previous hour's wind direction. Periods of calm are assigned a wind speed value of half the specified instrument threshold value. Reference Table 18 for more detailed information on meteorology and dispersion data.

Page 42 of 108

TABLE 16 Meteorlogical Data Availability Data Period: January 01, 2019 - December 31, 2019 PERCENT OF VALID PARAMETER HOURS PARAMETER Quarter 1 Quarter 2 Quarter 3 Quarter 4

1. Wind Speed

a. 10-Meter sensor 99.9%

100.0%

99.8%

100.0%

b. 60 Meter sensor 98.4%

100.0%

99.8%

100.0%

2. Wind Direction

a. 10-Meter sensor 99.9%

100.0%

99.8%

100.0%

b. 60 Meter sensor 99.9%

100.0%

99.8%

100.0% *

3. Temperature

a. 10-Meter sensor 99.9%

98.0%

99.8%

100.0%

b. 60 Meter sensor 99.9%

100.0%

99.8%

100.0%

c. Temperature Difference (10m-60m) 99.9%

100.0%

99.8%

100.0%

4. Percent of hours for which valid 10-meter Wind Speed, Wind Direction, and Delta Temperature were available 99.9%

100.0%

99.8%

100.0%

5. Percent of hours for which valid 60-meter Wind Speed, Wind Direction, and Delta Temperature were available 99.4%

100.0%

99.8%

100.0%

Clinton Power Station was able to achieve 99.8% Meteorological Recoverable Data during 2019 exceeding the minimum criteria of 90% as delineated within Regulatory Guide 1.23.

Page 43 of 108

TABLE 17 Classification of Atmospheric Stability Stability Classification Pasquill Category Defining Conditions Extremely unstable A

<Ll T ~ -1. 9 Moderately unstable B

-1.9 <LlT~ -1.7 Slightly unstable C

-1.7 <LlT~ -1.5 Neutral D

-1.5 <LlT~ -0.5 Slightly stable E

-0.5 <Ll T ~ 1.5 Moderately stable F

1.5 <LlT~ 4.0 Extremely stable G

4.0 <Ll T.:s_ ------

LlT = temperature difference in degrees Celsius per 100 meters Page 44 of 108

TABLE 18 Joint Wind Frequency Distribution by Stability Class Reporting Period: January 01, 2019 - December 31, 2019 The following table contains the joint wind frequency tables for CPS. The tables are segregated by sensor elevation and calendar quarter. All tabled values are in hours.

Clinton Power Station Period of Record: January - March 2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

5 1

0 0

6 NNE 0

0 1

4 0

0 5

NE 0

0 0

ENE 0

2 5

0 0

0 7

E 0

1 4

0 0

0 5

ESE 0

0 0

SE 0

8 1

0 0

0 9

SSE 0

0 0

s 0

0 1

0 0

0 1

SSW 0

0 0

SW 0

0 0

WSW 0

0 0

w 0

0 0

WNW 0

0 2

3 0

0 5

NW 0

0 2

0 0

0 2

NNW 0

0 4

1 0

0 5

Variable 0

0 0

Total 0

11 25 9

0 0

45 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 45 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Moderately Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 1

2 1

0 0

4 NNE 0

0 0

2 0

0 2

NE 0

0 0

ENE 0

2 4

0 0

0 6

E 0

1 5

0 0

0 6

ESE 0

2 2

0 0

0 4

SE 0

0 0

SSE 0

0 1

0 0

0 1

s 0

0 4

0 0

0 4

SSW 0

0 3

0 0

0 3

SW 0

0 3

0 0

0 3

WSW 0

0 1

1 0

0 2

w 0

0 1

6 0

3 10 WNW 0

2 4

3 0

0 9

NW 0

0 4

4 0

0 8

NNW 0

1 3

0 0

0 4

Variable 0

0 0

Total 0

9 37 17 0

3 66 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 46 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

5 0

0 0

5 NNE 0

1 1

0 0

0 2

NE 0

1 3

0 0

0 4

ENE 0

3 2

0 0

0 5

E 0

2 3

0 0

0 5

ESE 0

6 3

0 0

0 9

SE 0

3 1

0 0

0 4

SSE 0

2 2

0 0

0 4

s 0

0 2

0 0

0 2

SSW 0

0 3

0 0

0 3

SW 0

0 2

0 0

0 2

WSW 0

1 3

3 0

0 7

w 0

0 2

13 1

1 17 WNW 0

1 5

18 3

1 28 NW 0

5 9

2 0

0 16 NNW 0

2 4

2 0

0 8

Variable 0

0 0

Total 0

27 50 38 4

2 121 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 47 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

5 23 20 11 4

0 63 NNE 5

21 19 10 7

0 62 NE 4

18 25 19 0

0 66 ENE 2

22 39 0

0 0

63 E

0 46 55 1

0 0

102 ESE 2

69 18 1

0 0

90 SE 2

32 30 1

0 0

65 SSE 3

11 27 10 0

0 51 s

1 3

12 11 1

0 28 SSW 1

4 23 9

2 0

39 SW 0

2 14 4

0 1

21 WSW 1

10 33 9

9 5

67 w

1 8

26 27 31 10 103 WNW 0

19 46 70 39 0

174 NW 4

22 44 14 10 0

94 NNW 2

33 56 10 0

0 101 Variable 0

0 0

Total 33 343 487 207 103 16 1189 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 48 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

2 7

5 0

0 0

14 NNE 4

16 5

1 0

0 26 NE 11 26 5

2 0

0 44 ENE 6

8 8

2 0

0 24 E

9 19 6

1 0

0 35 ESE 7

22 3

1 0

0 33 SE 3

14 9

2 0

0 28 SSE 1

24 30 4

0 0

59 s

1 14 39 11 0

0 65 SSW 1

16 17 4

0 0

38 SW 3

19 13 4

1 0

40 WSW 1

11 24 5

0 0

41 w

2 10 18 11 3

1 45 WNW 4

14 33 4

0 1

56 NW 2

11 7

2 0

0 22 NNW 5

7 3

0 0

0 15 Variable 0

0 0

Total 62 238 225 54 4

2 585 Hours of calm in this stability class:

1 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 49 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 3

0 0

4 NNE 7

1 0

0 0

0 8

NE 3

3 0

0 0

0 6

ENE 4

0 0

0 4

E 3

3 0

0 0

0 6

ESE 6

2 0

0 0

0 8

SE 8

0 0

0 8

SSE 1

5 0

0 0

0 6

s 1

11 11 0

0 0

23 SSW 2

5 0

0 0

0 7

SW 0

4 0

0 0

0 4

WSW 1

6 2

0 0

0 9

w 1

3 1

0 0

0 5

WNW 1

4 3

0 0

0 8

NW 2

3 0

0 0

0 5

NNW 1

0 0

0 1

Variable 0

0 0

Total 42 53 17 0

0 0

112 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 50 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

0 NNE 1

1 0

0 0

0 2

NE 0

3 0

0 0

0 3

ENE 1

2 0

0 0

0 3

E 1

0 0

0 1

ESE 1

0 0

0 1

SE 0

2 0

0 0

0 2

SSE 1

6 0

0 0

0 7

s 0

1 1

0 0

0 2

SSW 0

0 0

SW 1

0 0

0 1

WSW 0

0 0

w 0

0 0

WNW 2

2 0

0 0

0 4

NW 4

3 0

0 0

0 7

NNW 2

3 0

0 0

0 5

Variable 0

0 0

Total 14 23 1

0 0

0 38 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 51 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

0 6

0 0

6 NNE 0

0 0

1 4

0 5

NE 0

0 0

ENE 0

0 2

4 1

0 7

E 0

0 2

3 0

0 5

ESE 0

0 1

0 0

0 1

SE 0

0 8

0 0

0 8

SSE 0

0 0

s 0

0 1

0 0

0 1

SSW 0

0 0

SW 0

0 0

WSW 0

0 0

w 0

0 0

WNW 0

0 0

2 3

0 5

NW 0

0 1

2 0

0 3

NNW 0

0 1

3 0

0 4

Variable 0

0 0

Total 0

0 16 21 8

0 45 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 52 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Moderately Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

1 1

1 0

3 NNE 0

0 0

1 1

0 2

NE 0

0 0

ENE 0

0 1

2 1

0 4

E 0

0 6

3 0

0 9

ESE 0

0 3

0 0

0 3

SE 0

0 0

1 0

0 1

SSE 0

0 0

s 0

0 2

3 0

0 5

SSW 0

0 2

0 0

0 2

SW 0

0 0

3 0

0 3

WSW 0

0 0

2 0

0 2

w 0

0 0

2 5

3 10 WNW 0

1 1

3 2

1 8

NW 0

1 4

2 4

0 11 NNW 0

0 2

1 0

0 3

Variable 0

0 0

Total 0

2 22 24 14 4

66 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 53 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

0 4

0 0

4 NNE 0

0 1

0 0

0 1

NE 0

1 2

2 0

0 5

ENE 0

0 3

1 1

0 5

E 0

1 4

2 0

0 7

ESE 0

1 4

4 0

0 9

SE 0

2 2

0 0

0 4

SSE 0

1 1

1 0

0 3

s 0

0 0

2 0

0 2

SSW 0

0 3

0 0

0 3

SW 0

0 0

2 0

0 2

WSW 0

0 1

4 1

0 6

w 0

0 1

4 8

5 18 WNW 0

0 6

4 11 6

27 NW 0

2 6

5 2

0 15 NNW 0

1 4

4 0

0 9

Variable 0

0 0

Total 0

9 38 39 23 11 120 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

1 Hours of missing stability measurements in all stability classes:

3 Page 54 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

2 11 24 23 5

0 65 NNE 5

6 19 8

7 1

46 NE 0

9 14 16 16 4

59 ENE 0

5 14 20 15 0

54 E

1 3

33 57 14 1

109 ESE 0

10 47 39 6

0 102 SE 1

16 30 25 4

0 76 SSE 1

5 13 11 11 1

42 s

0 2

4 10 12 4

32 SSW 0

0 12 17 0

4 33 SW 0

0 5

15 2

2 24 WSW 1

1 14 27 9

17 69 w

0 1

21 15 22 46 105 WNW 0

4 21 39 38 57 159 NW 3

13 23 40 10 8

97 NNW 0

15 32 32 2

0 81 Variable 0

0 0

Total 14 101 326 394 173 145 1153 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

36 Hours of missing stability measurements in all stability classes:

3 Page 55 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 4

6 7

0 0

18 NNE 2

3 11 8

2 0

26 NE 1

2 12 20 0

0 35 ENE 0

5 4

7 5

0 21 E

0 4

18 8

3 1

34

\\

ESE 1

4 19 5

5 1

35 SE 0

10 14 7

7 0

38 SSE 0

5 13 28 17 4

67 s

0 3

7 19 26 4

59 SSW 0

2 6

23 4

0 35 SW 1

4 14 10 8

2 39 WSW 0

2 11 24 6

1 44 w

0 3

10 12 9

10 44 WNW 0

3 8

31 8

1 51 NW 3

3 15 6

1 0

28 NNW 3

2 5

2 0

0 12 Variable 0

0 0

Total 12 59 173 217 101 24 586 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 56 of 108

Clinton Power Station Period of Record: January -

March 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 1

0 0

3 NNE 0

2 2

2 0

0 6

NE 1

1 1

1 0

0 4

ENE 0

2 1

0 1

0 4

E 0

4 2

0 0

0 6

ESE 1

5 3

1 0

0 10 SE 0

5 6

0 0

0 11 SSE 0

0 3

4 1

0 8

s 0

0 1

6 8

0 15 SSW 0

1 2

4 2

0 9

SW 0

0 3

6 0

0 9

WSW 0

0 1

6 0

0 7

w 0

1 1

5 0

0 7

WNW 0

0 1

3 1

0 5

NW 0

1 2

2 0

0 5

NNW 0

0 2

1 0

0 3

Variable 0

0 0

Total 2

22 33 42 13 0

112 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 57 of 108

Clinton Power Station Period of Record: January - March 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

3 1

0 0

4 NNE 0

1 7

0 0

0 8

NE 0

1 0

2 0

0 3

ENE 0

0 0

2 0

0 2

E 0

0 1

0 0

0 1

ESE 1

1 0

0 3

SE 0

1 1

0 0

0 2

SSE 0

1 0

1 1

0 3

s 0

0 0

4 2

0 6

SSW 0

1 1

0 0

0 2

SW 0

0 0

WSW 0

0 0

w 0

0 0

WNW 0

0 0

1 0

0 1

NW 1

0 0

2 0

0 3

NNW 0

0 0

Variable 0

0 0

Total 2

6 13 14 3

0 38 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

3 Page 58 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class -

Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

3 5

0 0

8 NNE 0

0 0

NE 0

0 4

0 0

0 4

ENE 0

0 0

E 0

0 4

2 0

0 6

ESE 0

0 0

SE 0

0 0

SSE 0

0 0

s 0

0 1

1 0

0 2

SSW 0

0 0

1 0

0 1

SW 0

0 0

1 1

0 2

WSW 0

0 0

0 1

w 0

0 0

WNW 0

0 0

NW 0

0 2

1 3

0 6

NNW 0

0 4

4 1

0 9

Variable 0

0 0

Total 0

0 18 15 6

0 39 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 59 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Moderately Unstable -

60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

4 2

0 0

6 NNE 0

0 0

NE 0

0 6

0 0

0 6

ENE 0

0 3

0 0

0 3

E 0

0 0

ESE 0

0 0

SE 0

0 0

SSE 0

1 1

0 0

0 2

s 0

1 7

2 0

0 10 SSW 0

0 1

4 0

0 5

SW 0

0 0

2 4

0 6

WSW 0

0 3

0 0

0 3

w 0

0 1

0 0

0 1

WNW 0

0 2

0 0

0 2

NW 0

2 7

6 0

0 15 NNW 0

2 3

3 0

0 8

Variable 0

0 0

Total 0

6 38 19 4

0 67 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 60 of 108

Clinton Power Station Period of Record: April - June 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 2

0 0

2 NNE 0

1 1

0 4

NE 0

1 7

2 0

0 10 ENE 0

1 3

0 0

0 4

E 0

0 2

1 0

0 3

ESE 0

2 4

0 0

0 6

SE 0

0 1

0 0

0 1

SSE 0

6 1

0 0

0 7

s 0

1 8

4 0

0 13 SSW 0

6 7

13 0

0 26 SW 0

5 6

6 1

0 18 WSW 0

0 12 4

3 0

19 w

0 1

4 1

0 0

6 WNW 0

0 4

1 0

0 5

NW 0

1 8

2 0

0 11 NNW 0

0 4

3 0

0 7

Variable 0

0 0

Total 0

27 72 38 5

0 142 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 61 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

3 25 25 12 3

0 68 NNE 4

24 16 7

10 0

61 NE 2

45 42 10 0

0 99 ENE 1

18 34 3

1 0

57 E

2 15 22 15 0

0 54 ESE 9

11 16 6

0 0

42 SE 1

22 17 0

0 0

40 SSE 3

19 20 3

0 0

45 s

2 29 42 17 1

0 91 SSW 2

24 45 43 3

0 117 SW 2

22 31 14 0

0 69 WSW 5

19 21 7

1 0

53 w

2 14 12 9

1 0

38 WNW 2

22 33 4

0 0

61 NW 9

22 38 14 0

0 83 NNW 4

12 11 12 0

0 39 Variable 0

0 0

Total 53 343 425 176 20 0

1017 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 62 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

4 9

3 9

0 0

25 NNE 3

19 8

4 0

0 34 NE 9

17 18 2

0 0

46 ENE 5

17 12 0

0 0

34 E

4 28 10 0

0 0

42 ESE 8

26 4

0 0

0 38 SE 10 29 3

0 0

0 42 SSE 1

26 27 0

0 0

54 s

5 37 31 7

0 0

80 SSW 2

38 44 9

0 0

93 SW 3

30 24 3

1 0

61 WSW 6

22 15 2

0 0

45 w

2 20 5

5 0

0 32 WNW 6

20 15 0

0 0

41 NW 4

13 8

1 0

0 26 NNW 5

6 6

0 0

0 17 Variable 0

0 0

Total 77 357 233 42 1

0 710 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 63 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 1

0 0

2 NNE 6

0 0

0 6

NE 6

4 1

0 0

0 11 ENE 3

2 0

0 0

0 5

E 4

1 0

0 0

0 5

ESE 1

0 0

0 1

SE 3

3 0

0 0

0 6

SSE 5

5 0

0 0

0 10 s

1 12 0

0 0

0 13 SSW 2

9 0

0 0

0 11 SW 6

9 0

0 0

0 15 WSW 1

9 0

0 0

0 10 w

9 6

0 0

15 WNW 7

9 0

0 0

0 16 NW 4

5 1

0 0

0 10 NNW 2

1 0

0 0

0 3

Variable 0

0 0

Total 61 76 2

0 0

0 139 Hours of calm in this stability class:

1 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 64 of 108

Clinton Power Station Period of Record: April - June 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

2 0

0 0

2 NNE 4

0 0

0 4

NE 5

5 0

0 0

0 10 ENE 2

0 0

0 2

E 0

0 0

ESE 2

0 0

0 2

SE 1

1 0

0 0

0 2

SSE 2

1 0

0 0

0 3

s 3

1 0

0 0

0 4

SSW 2

2 0

0 0

0 4

SW 5

3 0

0 0

0 8

WSW 7

0 0

0 7

w 7

0 0

0 7

WNW 5

2 0

0 0

0 7

NW 1

1 0

0 0

0 2

NNW 4

0 0

0 4

Variable 0

0 0

Total 52 16 0

0 0

0 68 Hours of calm in this stability class:

1 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 65 of 108

Clinton Power Station Period of Record: April - June 2019 Stability Class -

Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 1

5 0

8 NNE 0

0 0

NE 0

0 0

4 0

0 4

ENE 0

0 0

E 0

0 1

2 3

0 6

ESE 0

0 0

SE 0

0 0

SSE 0

0 0

s 0

0 1

2 0

0 3

SSW 0

0 0

SW 0

0 0

0 1

2 3

WSW 0

0 0

w 0

0 0

WNW 0

0 0

1 1

NW 0

0 0

2 1

2 5

NNW 0

0 3

1 3

2 9

Variable 0

0 0

Total 0

0 7

12 13 7

39 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 66 of 108

l Clinton Power Station Period of Record: April -

June 2019 Stability Class - Moderately Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 2

2 0

6 NNE 0

0 0

NE 0

0 2

3 0

0 5

ENE 0

0 1

2 1

0 4

E 0

0 0

ESE 0

0 0

SE 0

0 0

SSE 0

0 3

0 0

0 3

s 0

1 1

8 3

0 13 SSW 0

0 0

1 0

0 1

SW 0

0 0

0 2

4 6

WSW 0

0 0

3 0

0 3

w 0

0 0

1 0

0 1

WNW 0

0 2

1 0

0 3

NW 0

0 4

4 3

2 13 NNW 0

0 6

0 3

0 9

Variable 0

0 0

Total 0

1 21 25 14 6

67 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 67 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 0

0 0

2 NNE 0

0 2

1 0

1 4

NE 0

0 3

7 0

0 10 ENE 0

0 1

0 2

0 3

E 0

0 0

1 2

0 3

ESE 0

0 2

6 0

0 8

SE 0

1 1

0 0

0 2

SSE 0

4 1

1 1

0 7

s 0

0 5

5 4

0 14 SSW 0

1 9

12 6

0 28 SW 0

1 3

6 3

2 15 WSW 0

0 5

10 1

2 18 w

0 0

3 3

0 0

6 WNW 0

0 3

0 1

0 4

NW 0

0 4

5 1

1 11 NNW 0

0 3

2 1

1 7

Variable 0

0 0

Total 0

7 47 59 22 7

142 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 68 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 13 21 20 7

6 68 NNE 2

13 9

4 3

13 44 NE 4

18 31 23 17 3

96 ENE 0

10 21 21 18 4

74 E

1 6

4 13 22 11 57 ESE 1

7 9

13 7

7 44 SE 0

10 18 16 1

0 45 SSE 2

18 6

19 6

4 55 s

0 9

21 35 23 10 98 SSW 0

10 22 34 30 5

101 SW 4

10 24 21 7

2 68 WSW 0

11 15 16 8

2 52 w

3 6

12 6

7 2

36 WNW 0

13 17 29 4

0 63 NW 4

11 20 28 11 0

74 NNW 4

10 7

7 13 1

42 Variable 0

0 0

Total 26 175 257 305 184 70 1017 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 69 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 6

9 4

7 2

28 NNE 1

0 8

6 3

1 19 NE 0

6 17 10 2

0 35 ENE 0

2 12 32 3

0 49 E

1 5

11 22 3

0 42 ESE 0

5 28 11 1

0 45 SE 0

13 24 2

0 0

39 SSE 0

5 17 30 16 0

68 s

1 4

33 28 12 9

87 SSW 0

3 27 38 12 1

81 SW 0

4 17 26 6

1 54 WSW 0

0 11 23 8

0 42 w

3 3

19 8

7 0

40 WNW 1

4 17 15 0

0 37 NW 1

4 12 12 1

0 30 NNW 0

4 4

5 1

0 14 Variable 0

0 0

Total 8

68 266 272 82 14 710 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 70 of 108

Clinton Power Station Period of Record: April - June 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 3

3 0

0 0

6 NNE 0

1 1

0 0

0 2

NE 0

0 2

0 0

0 2

ENE 0

1 9

1 0

0 11 E

1 2

4 0

0 0

7 ESE 0

1 4

0 0

0 5

SE 0

6 2

0 0

0 8

SSE 0

1 0

3 0

0 4

s 0

1 6

5 0

0 12 SSW 0

0 8

7 0

0 15 SW 0

0 7

2 0

0 9

WSW 0

0 6

8 1

0 15 w

0 4

7 1

0 0

12 WNW 0

0 13 2

0 0

15 NW 0

3 5

5 0

0 13 NNW 0

2 2

0 0

0 4

Variable 0

0 0

Total 1

25 79 34 1

0 140 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 71 of 108

Clinton Power Station Period of Record: April -

June 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 0

0 0

1 NNE 0

3 0

0 0

0 3

NE 0

1 2

0 0

0 3

ENE 0

2 3

1 0

0 6

E 0

0 5

0 0

0 5

ESE 1

1 0

0 0

0 2

SE 0

1 0

0 0

0 1

SSE 1

1 1

0 0

0 3

s 1

1 0

0 3

SSW 0

2 3

4 0

0 9

SW 0

2 4

3 0

0 9

WSW 0

1 4

0 0

0 5

w 0

3 3

0 0

0 6

WNW 1

3 1

2 0

0 7

NW 0

1 2

1 0

0 4

NNW 1

0 1

0 0

0 2

Variable 0

0 0

Total 6

22 29 12 0

0 69 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

0 Page 72 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 4

0 0

4 NNE 0

1 4

1 0

0 6

NE 0

5 1

0 0

0 6

II ENE 0

3 1

0 0

0 4

E 0

0 1

0 0

0 1

ESE 0

1 0

0 0

0 1

SE 0

4 0

0 0

0 4

SSE 0

0 0

s 0

0 0

SSW 0

0 10 0

0 0

10 SW 0

0 10 0

0 0

10 WSW 0

0 0

w 0

2 3

0 0

0 5

WNW 0

1 7

1 0

0 9

NW 0

3 6

0 0

0 9

NNW 0

6 12 0

0 0

18 Variable 0

0 0

Total 0

30 55 2

0 0

87 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 73 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Moderately Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 11 4

0 0

0 15 NNE 0

6 1

0 0

0 7

NE 0

7 0

0 0

0 7

ENE 0

5 3

0 0

0 8

E 0

2 2

0 0

0 4

ESE 0

4 1

0 0

0 5

SE 0

4 1

0 0

0 5

SSE 0

3 1

0 0

0 4

s 0

1 3

2 0

0 6

SSW 0

3 14 2

0 0

19 SW 0

0 7

0 0

0 7

WSW 0

0 1

2 0

0 3

w 0

3 11 2

0 0

16 WNW 0

2 7

1 0

0 10 NW 0

9 7

0 0

0 16 NNW 0

7 4

0 0

0 11 Variable 0

0 0

Total 0

67 67 9

0 0

143 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 74 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 4

2 0

0 0

6 NNE 0

4 2

1 0

0 7

NE 0

5 1

0 0

0 6

ENE 0

3 1

0 0

0 4

E 0

9 1

0 0

0 10 ESE 0

7 3

0 0

0 10 SE 0

8 1

0 0

0 9

SSE 1

7 1

0 0

0 9

s 0

10 2

0 0

0 12 SSW 0

5 10 1

0 0

16 SW 0

5 15 0

0 0

20 WSW 0

4 3

1 0

0 8

w 0

6 6

1 0

0 13 WNW 0

7 7

0 0

0 14 NW 0

14 6

0 0

0 20 NNW 0

6 5

0 0

0 11 Variable 0

0 0

Total 1

104 66 4

0 0

175 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 75 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

3 11 6

0 0

0 20 NNE 3

25 8

1 0

0 37 NE 2

21 8

0 0

0 31 ENE 3

8 6

0 0

0 17 E

0 17 1

0 0

0 18 ESE 2

14 0

0 0

0 16 SE 4

15 0

0 0

0 19 SSE 6

40 11 1

0 0

58 s

2 42 18 5

0 0

67 SSW 3

31 57 16 0

0 107 SW 2

26 35 3

0 0

66 WSW 3

16 10 1

0 0

30 w

1 17 6

0 0

0 24 WNW 3

28 11 0

0 0

42 NW 5

28 4

0 0

0 37 NNW 1

16 3

0 0

0 20 Variable 0

0 0

Total 43 355 184 27 0

0 609 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 76 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

6 21 3

0 0

0 30 NNE 2

32 3

0 0

0 37 NE 4

43 1

0 0

0 48 ENE 1

17 1

0 0

0 19 E

10 32 1

0 0

0 43 ESE 14 24 0

0 0

0 38 SE 12 24 1

0 0

0 37 SSE 12 29 4

0 0

0 45 s

11 92 17 0

0 0

120 SSW 9

80 55 3

0 0

147 SW 11 31 6

1 0

0 49 WSW 11 17 4

0 0

0 32 w

12 23 6

0 0

0 41 WNW 17 28 0

1 0

0 46 NW 12 28 2

0 0

0 42 NNW 1

17 1

0 0

0 19 Variable 0

0 0

Total 145 538 105 5

0 0

793 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 77 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

2 4

1 0

0 0

7 NNE 7

22 0

0 0

0 29 NE 13 33 0

0 0

0 46 ENE 5

4 0

0 0

0 9

E 11 4

0 0

15 ESE 9

1 0

0 0

0 10 SE 5

1 0

0 0

0 6

SSE 3

6 0

0 0

0 9

s 4

17 0

0 0

0 21 SSW 7

18 0

0 0

0 25 SW 10 14 1

0 0

0 25 WSW 12 7

0 0

19 w

10 6

0 0

16 WNW 7

1 0

0 0

0 8

NW 14 11 0

0 0

0 25 NNW 5

2 0

0 0

0 7

Variable 0

0 0

Total 124 151 2

0 0

0 277 Hours of calm in this stability class:

3 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 78 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

4 0

0 0

4 NNE 12 1

0 0

13 NE 18 15 0

0 0

0 33 ENE 3

0 0

0 3

E 3

0 0

0 3

ESE 1

0 0

0 1

SE 3

0 0

0 3

SSE 5

1 0

0 0

0 6

s 2

0 0

0 2

SSW 2

2 0

0 0

0 4

SW 3

2 0

0 0

0 5

WSW 5

1 0

0 0

0 6

w 5

0 0

0 5

WNW 4

0 0

0 4

NW 14 1

0 0

15 NNW 6

0 0

0 6

Variable 0

0 0

Total 90 23 0

0 0

0 113 Hours of calm in this stability class:

4 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 79 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 1

3 1

0 0

5 NNE 0

0 1

3 0

0 4

NE 0

0 5

0 0

0 5

ENE 0

0 5

1 0

0 6

E 0

0 0

1 0

0 1

ESE 0

1 1

0 0

0 2

SE 0

3 0

0 0

0 3

SSE 0

0 0

s 0

0 0

1 0

0 1

SSW 0

0 5

7 0

0 12 SW 0

0 2

5 0

0 7

WSW 0

0 0

w 0

0 6

1 0

0 7

WNW 0

0 3

4 0

0 7

NW 0

0 6

3 0

0 9

NNW 0

1 12 5

0 0

18 Variable 0

0 0

Total 0

6 49 32 0

0 87 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 80 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Moderately Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 6

8 1

0 0

15 NNE 0

1 4

0 0

0 5

NE 0

3 4

0 0

0 7

ENE 0

1 3

3 0

0 7

E 0

2 1

1 0

0 4

ESE 0

3 2

2 0

0 7

SE 0

3 0

0 0

0 3

SSE 0

2 2

1 0

0 5

s 0

1 2

3 2

0 8

SSW 0

2 8

8 1

0 19 SW 0

0 0

5 0

0 5

WSW 0

0 1

1 1

0 3

w 0

0 12 2

0 0

14 WNW 0

2 4

3 2

0 11 NW 0

5 5

2 0

0 12 NNW 0

5 11 2

0 0

18 Variable 0

0 0

Total 0

36 67 34 6

0 143 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 81 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 2

4 1

0 0

7 NNE 0

2 4

2 0

0 8

NE 0

4 1

0 0

0 5

ENE 0

3 1

1 0

0 5

E 0

3 4

0 0

0 7

ESE 0

4 5

5 0

0 14 SE 0

6 0

0 0

0 6

SSE 1

5 5

2 0

0 13 s

0 9

1 1

0 0

11 SSW 0

0 9

5 0

0 14 SW 0

4 10 7

0 0

21 WSW 0

0 4

2 0

0 6

w 0

3 10 0

1 0

14 WNW 0

3 6

5 0

0 14 NW 0

9 8

1 0

0 18 NNW 0

6 4

2 0

0 12 Variable 0

0 0

Total 1

63 76 34 1

0 175 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 82 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

3 6

13 4

0 0

26 NNE 1

10 14 1

0 0

26 NE 0

5 16 3

0 0

24 ENE 0

5 6

10 1

0 22 E

0 1

8 8

0 0

17 ESE 1

5 10 3

0 0

19 SE 4

16 5

0 0

0 25 SSE 4

22 28 8

1 0

63 s

1 11 34 13 6

2 67 SSW 2

12 28 41 14 0

97 SW 1

11 29 24 2

0 67 WSW 2

9 16 5

0 0

32 w

2 7

11 4

0 0

24 WNW 1

11 17 8

0 0

37 NW 0

21 15 2

0 0

38 NNW 2

10 12 1

0 0

25 Variable 0

0 0

Total 24 162 262 135 24 2

609 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 83 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 6

19 10 0

0 36 NNE 0

6 22 5

0 0

33 NE 1

0 7

29 0

0 37 ENE 0

1 15 9

0 0

25 E

0 1

13 13 0

0 27 ESE 1

4 29 13 0

0 47 SE 3

13 21 1

0 0

38 SSE 0

19 29 14 0

0 62 s

1 9

50 49 2

1 112 SSW 2

6 56 70 4

0 138 SW 0

7 31 13 2

0 53 WSW 0

7 11 13 0

0 31 w

3 7

16 15 0

0 41 WNW 0

11 34 5

0 1

51 NW 3

7 26 4

0 0

40 NNW 2

7 6

7 0

0 22 Variable 0

0 0

Total 17 111 385 270 8

2 793 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 84 of 108

Clinton Power Station Period of Record: July - September 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 2

7 1

1 0

11 NNE 0

3 8

15 0

0 26 NE 1

1 4

19 0

0 25 ENE 0

2 6

17 0

0 25 E

0 4

6 5

0 0

15 ESE 1

3 7

1 0

0 12 SE 2

2 7

0 0

0 11 SSE 2

4 1

0 0

0 7

s 0

2 10 2

0 0

14 SSW 0

6 11 13 0

0 30 SW 0

4 16 8

1 0

29 WSW 2

3 12 6

0 0

23 w

2 5

5 2

0 0

14 WNW 0

7 7

1 0

0 15 NW 2

2 6

1 0

0 11 NNW 1

3 7

1 0

0 12 Variable 0

0 0

Total 13 53 120 92 2

0 280 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 85 of 108

Clinton Power Station Period of Record: July -

September 2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 2

2 0

0 0

5 NNE 1

2 1

0 0

0 4

NE 0

3 4

2 0

0 9

ENE 0

1 2

4 0

0 7

E 3

3 11 7

0 0

24 ESE 2

6 3

0 0

0 11 SE 2

1 2

0 0

0 5

SSE 1

2 0

0 0

0 3

s 1

5 3

0 0

0 9

SSW 1

4 1

0 0

0 6

SW 1

3 2

0 0

0 6

WSW 0

0 1

2 0

0 3

w 1

5 2

1 0

0 9

WNW 2

5 1

0 0

0 8

NW 0

0 0

NNW 1

1 6

0 0

0 8

Variable 0

0 0

Total 17 43 41 16 0

0 117 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

4 Page 86 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

1 1

0 0

2 NNE 0

0 0

NE 0

0 0

ENE 0

0 2

0 0

0 2

E 0

0 0

ESE 0

0 0

SE 0

0 0

SSE 0

0 1

0 0

0 1

s 0

0 0

SSW 0

0 0

SW 0

0 0

1 0

0 1

WSW 0

0 0

w 0

0 0

WNW 0

0 0

NW 0

0 2

0 0

0 2

NNW 0

1 2

0 0

0 3

Variable 0

0 0

Total 0

1 8

2 0

0 11 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 87 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Moderately Unstable -

60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 1

1 0

0 0

2 NNE 0

1 0

2 0

0 3

NE 0

0 2

0 0

0 2

ENE 0

0 0

E 0

0 0

ESE 0

3 1

0 0

0 4

SE 0

2 1

0 0

0 3

SSE 0

0 2

0 0

0 2

s 0

0 2

0 0

0 2

SSW 0

0 0

1 0

0 1

SW 0

0 1

3 0

0 4

WSW 0

0 2

2 2

0 6

w 0

0 0

3 0

0 3

WNW 0

0 3

1 0

0 4

NW 0

0 5

0 0

0 5

NNW 0

0 3

0 0

0 3

Variable 0

0 0

Total 0

7 23 12 2

0 44 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 88 of 108

Clinton Power Station Period of Record: October -

Decernber2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 1

1 1

0 0

3 NNE 0

2 5

1 0

0 8

NE 0

0 1

0 0

0 1

ENE 0

1 0

0 0

0 1

E 0

0 0

ESE 0

1 0

0 0

0 1

SE 0

4 2

0 0

0 6

SSE 0

2 5

0 0

0 7

s 0

1 10 5

0 0

16 SSW 0

0 8

8 0

0 16 SW 0

0 7

5 0

0 12 WSW 0

2 4

1 0

0 7

w 0

1 2

1 0

0 4

WNW 0

0 9

8 0

0 17 NW 0

6 5

4 0

0 15 NNW 0

6 1

0 0

0 7

Variable 0

0 0

Total 0

27 60 34 0

0 121 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 89 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

2 26 23 23 0

0 74 NNE 0

23 30 4

0 0

57 NE 0

14 18 2

0 0

34 ENE 0

8 5

0 0

0 13 E

0 20 4

0 0

0 24 ESE 0

19 4

0 0

0 23 SE 0

14 7

0 0

0 21 SSE 3

19 22 2

0 0

46 s

2 13 55 18 0

0 88 SSW 0

22 56 41 1

0 120 SW 0

10 15 12 0

0 37 WSW 1

12 18 28 11 3

73 w

0 9

25 23 7

6 70 WNW 1

24 50 42 8

0 125 NW 2

40 49 21 0

0 112 NNW 0

19 44 9

0 0

72 Variable 0

0 0

Total 11 292 425 225 27 9

989 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 90 of 108

Clinton Power Station Period of Record: October -

Decernber2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 18 10 1

0 0

30 NNE 0

9 5

1 3

0 18 NE 1

21 2

0 0

0 24 ENE 1

11 3

0 0

0 15 E

1 14 5

0 0

0 20 ESE 2

26 13 0

0 0

41 SE 6

47 18 1

0 0

72 SSE 4

53 24 6

0 0

87 s

3 35 56 9

0 0

103 SSW 1

25 62 13 0

0 101 SW 4

20 22 6

1 0

53 WSW 2

24 29 4

1 0

60 w

3 19 13 7

0 0

42 WNW 4

31 18 1

1 0

55 NW 2

19 5

1 0

0 27 NNW 0

7 9

0 0

0 16 Variable 0

0 0

Total 35 379 294 50 6

0 764 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 91 of 108

Clinton Power Station Period of Record: October - December2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 2

0 0

2 NNE 7

3 0

0 0

0 10 NE 4

3 0

0 0

0 7

ENE 0

5 0

0 0

0 5

E 3

2 0

0 0

0 5

ESE 3

3 0

0 0

0 6

SE 5

4 1

0 0

0 10 SSE 2

10 2

0 0

0 14 s

4 18 8

0 0

0 30 SSW 3

25 4

0 0

0 32 SW 4

8 0

0 0

0 12 WSW 6

6 0

0 0

0 12 w

1 3

0 0

4 WNW 3

7 0

0 0

0 10 NW 4

9 0

0 0

0 13 NNW 3

1 0

0 0

0 4

Variable 0

0 0

Total 52 109 15 0

0 0

176 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 92 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class -

Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 10 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

0 NNE 2

1 0

0 0

0 3

NE 5

9 0

0 0

0 14 ENE 1

0 0

0 1

E 9

2 0

0 0

0 11 ESE 4

0 0

0 4

SE 5

3 0

0 0

0 8

SSE 0

5 0

0 0

0 5

s 2

6 0

0 0

0 8

SSW 1

6 0

0 0

0 7

SW 1

4 0

0 0

0 5

WSW 4

0 3

0 0

0 7

w 3

1 3

10 1

0 18 WNW 2

1 0

0 0

0 3

NW 2

1 0

0 0

0 3

NNW 4

0 0

0 4

Variable 0

0 0

Total 45 39 6

10 1

0 101 Hours of calm in this stability class:

1 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 93 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Extremely Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

1 2

0 0

3 NNE 0

0 0

NE 0

0 0

ENE 0

0 2

0 0

0 2

E 0

0 0

ESE 0

0 0

SE 0

0 0

SSE 0

0 0

s 0

0 0

1 0

0 1

SSW 0

0 0

SW 0

0 0

0 1

WSW 0

0 0

w 0

0 0

WNW 0

0 0

NW 0

0 0

2 0

0 2

NNW 0

0 0

2 0

0 2

Variable 0

0 0

Total 0

0 3

7 1

0 11 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 94 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Moderately Unstable -

60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 0

0 0

2 NNE 0

0 0

1 1

0 2

NE 0

0 2

0 0

0 2

ENE 0

0 1

0 0

0 1

E 0

0 0

ESE 0

0 4

0 0

0 4

SE 0

0 2

0 0

0 2

SSE 0

0 2

1 0

0 3

s 0

0 0

2 0

0 2

SSW 0

0 0

0 1

SW 0

0 0

0 3

WSW 0

0 1

2 2

2 7

w 0

0 0

0 2

WNW 0

0 0

4 1

0 5

NW 0

0 1

4 0

0 5

NNW 0

0 1

2 0

0 3

Variable 0

0 0

Total 0

0 16 16 10 2

44 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 95 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Slightly Unstable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

2 1

0 0

3 NNE 0

0 4

1 1

0 6

NE 0

0 1

1 0

0 2

ENE 0

0 1

1 0

0 2

E 0

0 0

ESE 0

0 1

0 0

0 1

SE 0

1 4

0 0

0 5

SSE 0

1 7

0 0

0 8

s 0

0 6

3 5

0 14 SSW 0

1 6

2 7

1 17 SW 0

0 2

6 4

0 12 WSW 0

1 4

2 1

0 8

w 0

0 1

1 0

0 2

WNW 0

0 3

9 5

0 17 NW 0

2 9

2 3

0 16 NNW 0

2 5

1 0

0 8

Variable 0

0 0

Total 0

8 56 30 26 1

121 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 96 of 108

Clinton Power Station Period of Record: October -

Decernber2019 Stability Class - Neutral 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 9

20 12 18 4

63 NNE 0

14 22 11 8

0 55 NE 0

3 12 18 9

0 42 ENE 0

3 11 4

2 0

20 E

0 3

10 6

0 0

19 ESE 0

5 12 6

0 0

23 SE 0

10 11 6

0 0

27 SSE 1

5 14 11 6

2 39 s

1 6

26 37 16 1

87 SSW 1

6 22 51 30 7

117 SW 0

8 10 16 8

0 42 WSW 0

5 10 14 18 24 71 w

2 5

9 27 11 13 67 WNW 0

8 30 33 29 22 122 NW 0

17 38 34 21 0

110 NNW 0

10 26 38 11 0

85 Variable 0

0 0

Total 5

117 283 324 187 73 989 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 97 of 108

Clinton Power Station Period of Record: October -

Decernber2019 Stability Class - Slightly Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

0 0

14 11 0

0 25 NNE 0

1 8

10 0

4 23 NE 0

0 8

5 0

1 14 ENE 0

0 4

15 0

0 19 E

0 2

5 11 0

0 18 ESE 0

0 3

18 1

0 22 SE 0

4 40 26 3

0 73 SSE 0

6 33 35 8

4 86 s

0 2

13 57 15 6

93 SSW 1

0 18 77 18 2

116 SW 0

1 12 39 8

1 61 WSW 0

2 8

29 13 2

54 w

0 4

18 20 11 0

53 WNW 0

2 22 15 5

1 45 NW 2

3 27 11 2

0 45 NNW 0

1 8

8 0

0 17 Variable 0

0 0

Total 3

28 241 387 84 21 764 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 98 of 108

Clinton Power Station Period of Record: October -

December 2019 Stability Class - Moderately Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 1

1 0

0 0

3 NNE 0

3 2

1 0

0 6

NE 1

2 5

0 0

0 8

ENE 0

0 1

2 0

0 3

E 0

5 3

2 0

0 10 ESE 0

1 2

1 0

0 4

SE 0

1 8

0 0

0 9

SSE 0

3 4

4 0

0 11 s

1 0

3 12 8

0 24 SSW 0

1 5

26 1

0 33 SW 0

0 3

14 0

0 17 WSW 0

0 6

7 0

0 13 w

0 0

5 1

0 0

6 WNW 0

1 4

2 0

0 7

NW 1

0 7

5 0

0 13 NNW 1

2 4

2 0

0 9

Variable 0

0 0

Total 5

20 63 79 9

0 176 Hours of calm in this stability class:

0 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 99 of 108

Clinton Power Station Period of Record: October -

December2019 Stability Class - Extremely Stable 60m-10m Delta-T (F)

Winds Measured at 60 Meters Wind Speed (in mph)

Wind Direction 1-3 4-7 8-12 13-18 19-24

> 24 Total N

1 1

1 0

0 0

3 NNE 1

0 1

0 0

0 2

NE 0

1 1

1 0

0 3

ENE 1

1 1

2 1

0 6

E 0

0 3

2 0

0 5

ESE 0

3 2

1 0

0 6

SE 0

6 3

0 0

0 9

SSE 0

1 5

0 0

0 6

s 1

0 1

5 0

0 7

SSW 0

2 3

3 0

0 8

SW 1

1 0

11 0

0 13 WSW 1

0 0

6 0

0 7

w 0

1 0

6 7

2 16 WNW 0

1 1

0 0

1 3

NW 0

0 2

0 0

0 2

NNW 0

4 1

0 0

0 5

Variable 0

0 0

Total 6

22 25 37 8

3 101 Hours of calm in this stability class:

1 Hours of missing wind measurements in this stability class:

0 Hours of missing stability measurements in all stability classes:

1 Page 100 of 108

SECTION 8 ODCM OPERATIONAL REMEDIAL REQUIREMENT REPORT In accordance with CPS ODCM 3.1.1 Action G.1, 3.2.1 Action F.1, and 3.2.2 Action G.1; NON-FUNCTIONAL radioactive liquid and gaseous effluent monitoring instrumentation channels remaining in a NON-FUNCTIONAL condition for greater than the designated time shall be reported in the Annual Radioactive Effluent Release Report. During the course of 2019, there were zero (O) instances where a radioactive liquid or gaseous effluent monitoring instrumentation channel remained in a NON-FUNCTIONAL condition for greater than the designated clock requirement.

Throughout 2019, there was two (2) instances of missed ODCM required samples documented in Issue Reports 4220189 and 4222110 and two (2) instances of delayed ODCM required sampling recorded in Issue Reports 4280491 and 4282609. A summary of the sample deviations are captured below.

February 13, 2019 -- Issue Report# 4220189 MISSED ODCM NG & TRITIUM SAMPLE DUE TO EQUIPMENT MALFUNCTION During the 06:19 VG run on 2/13/2019, the system was shut down due to an equipment issue causing oscillations prior to the ODCM required NG and tritium grab sample to be obtained. A noble gas and tritium grab sample are to be obtained for each release in accordance with the Station ODCM's, CY-CL-170-301 Table 4.4.1-1 B. During this short run, the low-range and high-range Noble Gas activity monitors remained steady and did not alarm giving the station reasonable reassurance that noble gases were orders of magnitude below alarm values. RP set up a portable noble gas air monitoring station in secondary containment at 755' Fuel Building at 09:14, and analysis results showed no noble gases were present in the area at this time. Also, after the issues that were causing the oscillations were fixed, VG was ran again for PMT and a valid noble gas and tritium sample were obtained at 15:04 on 2/13/2019 with expected values.

February 20, 2019 -- Issue Report# 4222110 1RIX-PR036 COMP. GRAB SAMPLE ANALYSIS MISSED On 2/20/19 IMD performed a channel calibration on 1RIX-PR036 which puts chemistry in a 9 hour1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months compensatory grab sampling during the calibration. The first compensatory grab sample was due to be sampled and analyzed by 19:35. The compensatory sample was obtained at 17:39 and analysis results were reported to Operations at 18:17. At approximately 23:35, the on~shift duty chemistry technician was preparing the count room for the nightly checks where he discovered that a compensatory grab sample for 1RIX-PR036 was ran on Gamma Detector

'C' which was not calibrated to analyze 4L liquid Marinelli's. This resulted in a missed ODCM required sample because the sample was not obtained and analyzed within the ODCM requirements. Upon discovery, another sample was immediately obtained and analyzed while the original sample was reanalyzed on a calibrated detector. Both analyzes resulted in anticipated results.

September 17, 2019 - Issue Report 4280491 ODCM HVAC SAMPLE DELAYED An HVAC noble gas and tritium sample is required in Modes 4 and 5 upon initiation of flow without delay in a controlled manner for drywell purge and high volume containment Page 101 of 108

ventilation per the Station's ODCM. Operations started Containment/Drywell Purge Mode per CPS 3408.01, Section 8.1.1.5 on 09/17/2019 03:05, but communication issues concluded that no sample was required at that time. After further review of the ODCM, it was determined that an HVAC noble gas and tritium sample was actually required. Chemistry management immediately directed a technician to sample HVAC for noble gas and tritium. The sample was obtained approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months after containment/drywell purge was started, but sample results were as expected.

September 26, 2019 - Issue Report 4282609 ODCM HVAC TRITIUM NOT SAMPLED WITHOUT DELAY An HVAC noble gas and tritium sample is required in Modes 4 and 5 upon initiation of flow without delay in a controlled manner for drywell purge and high volume containment ventilation per the Station's ODCM. On 09/26/2019 at 03:48, Operations started Containment

/Drywell Purge Mode per CPS 3408.01, section 8.2.1.4 however, chemistry was not contacted to obtain the HVAC noble gas and tritium samples.

Before Operations shutdown Containment/Drywell Purge Mode, a HVAC noble gas sample happened to be obtained on 09/26/2019 at 04:11 and thus was without delay. However, the HVAC tritium sample was not obtained until approximately 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after the fact. The delayed tritium sample results were as anticipated.

Page 102 of 108

SECTION 9 CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS In accordance with Section 6.2 of the CPS ODCM, licensee-initiated changes to the liquid, gaseous or solid radioactive waste treatment systems shall be reported in the Annual Radioactive Effluent Release Report.

There were no permanent changes to the Radioactive Waste Treatment Systems during the course of the 2019 reporting period; therefore, there is no documentation required in the 2019 Annual Radioactive Effluent Release Report.

Page 103 of 108

SECTION 10 NEW LOCATIONS FOR DOSE CALCULATION AND/OR ENVIRONMENTAL MONITORING The following is a summary of the 2019 Annual Land Use Census. It shows changes in locations for dose calculations and/or environmental monitoring identified by the Annual Land Use Census. The distance of the receptor is being listed in the report in lieu of the name of the resident. This is being done to maintain and respect the privacy of the residents.

1.0 Nearest Residence The nearest residents identified in each of the sixteen (16) sectors are shown below.

SECTOR 2019 RESIDENT AGE GROUP 2018 RESIDENT AGE GROUP (km)

(km)

N 1.50 A

1.50 A

NNE 1.50 A

1.50 A

NE 2.07 A

2.07 A

ENE 2.86 A

2.86 A

E 1.67 A

1.67 A

ESE 5.14 A

5.14 A

SE 4.44 A*

4.44 C/T/A SSE 2.90 A

2.90 A

s 4.78 A

4.78 A

SSW 4.68 A*

4.68 C/A SW 1.17 A

1.17 A

WSW 3.62 A

3.62 A

w 1.95 T/A*

1.95 C/A WNW 2.63 A

2.63 A

NW 2.65 A

2.65 A

NNW 2.05 A

2.05 A

Indicates any changes from the previous year (l)nfant (C) hild (T)een (A)dult Page 104 of 108

2.0 Broadleaf Garden Census Fifty-seven (57) gardens within a five (5) kilometer radius were located in the sixteen (16) geographical sectors surrounding CPS. Thirteen (13) gardens contained broad leaf vegetation, which were specifically identified for this report. Although other crops were identified within these areas, they are not addressed as part of this report.

The nearest gardens greater than fifty (50) square-meters and producing broadleaf vegetation identified in each of the sixteen (16) geographical sectors are shown below.

SECTOR 2019 GARDENS AGE GROUPS 2018 GARDENS AGE GROUPS (km)

(km)

N 1.50 A

1.50 A

NNE

>8*

1.50 A

NE 3.46 A*

3.46 C/A ENE 4.29*

A 4.22 A

E 1.67 A

1.67 A

ESE 7.72*

A*

5.30 C/A SE

>8*

7.80 A

SSE

>8

>8 s

>8*

6.60 A

SSW

>8

>8 SW

>8

>8 WSW 4.32 C/T/A 4.32 C/T/A w

>8*

3.32 A

WNW

>8*

2.63 A

NW 4.70*

A*

>8 NNW 2.05 A

2.05 A

Indicates any changes from the previous year (l)nfant (C)hild (T)een (A)dult Page 105 of 108

3.0 Milking Animal Census Milking animals within the sixteen (16) geographical sectors were located within five (5) miles surrounding CPS. These milking animals were either used for the nursing of the animal's offspring or used for meat production for the resident's own personal use and sold commercially. There were no residents that milked their animals for human consumption.

Milking animals were specifically identified for this report. Although other livestock were identified within these areas, they are not addressed as part of this report.

The nearest milking animals identified in each of the sixteen (16) geographical sectors are shown below.

SECTOR 2019 MILKING AGE GROUPS 2018 MILKING ANIMALS AGE GROUPS ANIMALS (km)

(km)

N 1.50 A

1.50 A

NNE

>8

>8 NE

>8

>8 ENE

>8*

4.20 A

E

>8

>8 ESE

>8

>8 SE

>8*

7.10 T/A SSE

>8

>8 s

6.60 A

SSW

>8*

6.30 C/T/A SW

>8

>8 WSW 4.32 C/A/T*

4.32 A

w

>8

>8 WNW

>8

>8 NW

>8

>8 NNW 2.05 A

2.05 A

Indicates any changes from the previous year (l)nfant (C)hild (T)een (A)dult Page 106 of 108

SECTION 11 CORRECTIONS TO DATA REPORTED IN PREVIOUS REPORTS There were no administrative changes identified in 2019 against previously submitted Annual Radioactive Effluent Release Reports resulting in an errata data submittal to the Commission.

Page 107 of 108

SECTION 12 CHANGES TO THE OFFSITE DOSE CALCULATION MANUAL The Offsite Dose Calculation Manual was last revised in December of 2015. Revision 25 of the ODCM is not included with this submittal since no updates were made in 2019.

Page 108 of 108

U-604546, Annual Radioactive Effluent Release Report

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