ML20142A393

Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the 2019

ML20142A393
Person / Time
Site:	Davis Besse
Issue date:	05/05/2020
From:	Huey D Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20142A392	List: L-20-093, Offsite Dose Calculation Manual, Revision 37 ML20142A393 ML20142A394 ML20142A396 ML20142A397 ML20142A398 ML20142A399 ML20142A401
References
L-20-093
Download: ML20142A393 (175)

Text

a,. energy Energy Harbor Nuclear Corp.

~harbor Davis-Besse Nuclear Power Station 5501 N State Route 2 Oak Harbor, Ohio 43449 May 5, 2020 L-20-093 10 CFR 50.36a A TIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit 1 Docket Number 50-346, License Number NPF-3 Combined Annual Radiological Environmental Operating Report and Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2019 In accordance with 10 CFR 50.36a(a)(2), this letter transmits the c,ombined 2019 Annual Radiological Environmental Operating Report (AREOR) and Radiological Effluent Release Report (RERR) for the period January 2019 through December 2019. These annual reports are submitted for the Davis-Besse Nuclear Power Station (DBNPS). The ARE OR and the RERR must be submitted by May 15 of each year to satisfy the requirements of the DBNPS Technical Specifications 5.6.1 and 5.6.2.

The Attachment provides a listing of the specific requirements detailed in the DBNPS Offsite Dose Calculation Manual (ODCM) and the portion of the AREOR which was prepared to meet each requirement.

The following information is also provided only to the Document Control Desk. This information includes:

• 2019 RERR Meteorological Data (on Compact Disc)

• Environmental, Inc. Midwest Laboratory, Monthly Progress Report for January through December 2019 which contains the 2019 Radiological Environmental Monitoring Program Sample Analysis Results (on Compact Disc)

• Davis-Besse Offsite Dose Calculation Manual, Revision 36 and Revision 37 (on Compact Disc)

Davis-Besse Nuclear Power Station, Unit 1 L-20-093 Page 2 of 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Michael Brasile, Manager -

Site Chemistry, at (419) 249-2475.

Sincerely, Douglas B. Huey General Plant Manager, Nuclear Davis-Besse Nuclear Power Station jcs/kaf

Attachment:

Summary Location(s) of Off-Site Dose Calculation Manual Requirements Contents in the Annual Radiological Environmental Operating Report

Enclosure:

Annual Radiological Environmental Operating Report, including the Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2019 cc: Regional Administrator, NRC Region Ill DB-1 NRC Senior Resident Inspector DB-1 NRC/NRR Project Manager Branch Chief, Division of Reactor Projects, Branch 2 Utility Radiological Safety Board

L-20-093 Attachment Page 1 of 1 Summary Location(s) of Off-Site Dose Calculation Manual Requirements Contents in the Annual Radiological Environmental Operating Report Description of Requirement

• Summaries, interpretations, and analyses of trends of the radiological environmental surveillance activities, and an assessment of the observed impacts of the plant (pages 28 through 73 and Appendix C)

• Results of the Land Use Census (pages 103 through 108)

• Results of the analysis of radiological environmental samples and of environmental radiation measurements (Environmental, Inc. Midwest Laboratory, Monthly Progress Report for January through December 2019 (pages 26 through 73)

• Summary description of the radiological environmental monitoring program (also pages 26 through 73)

• At least two legible maps, covering sampling locations keyed to a table giving distances and directions from the centerline of one reactor (pages 40 through 70)

• The results of licensee participation in the Inter-Laboratory Comparison Program (Appendix A)

• Discussion of cases in which collection of specimens had irregularities due to malfunction of automatic sampling equipment and other legitimate reasons (page*

36)

L-20-093 Enclosure Annual Radiological Environmental Operating Report, including the Radiological Effluent Release Report for the Davis-Besse Nuclear Power Station - 2019

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ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT Davis-Besse Nuclear Power Station January 1, 2019 through December 31, 2019 Davis-Besse Nuclear Power Station May2020

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report TABLE OF CONTENTS Title List of Tables iv List of Figures Vl Executive Summary viii INTRODUCTION Fundamentals 1 Radiation and Radioactivity 2 Interaction with Matter 3 Quantities and Units of Measurement 5 Sources of Radiation 7 Health Effects of Radiation 9 Health Risks 10 Benefits of Nuclear Power 11 Nuclear Power Production 11 Station Systems 16 Reactor Safety and Summary 19 Radioactive Waste 19 Description of the Davis-Besse Site 22 References 24 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Introduction 26 Pre-Operational Surveillance Program 26 Operational Surveillance Program Objectives 27 Quality Assurance 27 Program Description 28 Sample Analysis 32 Sample History Comparison 34

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Title RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (continued) 2019 Program Anomalies 36 Atmospheric Monitoring 36 Terrestrial Monitoring 43 Aquatic Monitoring 50 Direct Radiation Monitoring 62 Conclusion 71 References 71 RADIOACTIVE EFFLUENT RELEASE REPORT Protection Standards 74 Sources of Radioactivity Released 74 Processing and Monitoring 75 Exposure Pathways 76 Dose Assessment 77 Results 78 Regulatory Limits 79 Effluent Concentration Limits 79 Average Energy 80 Measurements of Total Activity 80 Batch Releases 80 Abnormal Releases 81 Releases from the ISFSI 81 Percent ofOffsite Dose Calculation Manual (ODCM) Release Limits 81 Sources oflnput Data 81 Dose to Public Due to Activities Inside the Site Boundary 82 Non-Functional Radioactive Effluent Monitoring Equipment 83 Changes to The ODCM and Process Control Plan (PCP) 83 Borated Water Storage Tank Radionuclide Concentrations 84 Onsite Groundwater Monitoring 98 LAND USE CENSUS Program Design 103 Methodology 103 Results 104 ii

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Title NON-RADIOLOGICAL ENVIRONMENTAL PROGRAMS Meteorological Monitoring 109 On-Site Meteorological Monitoring 110 Land and Wetlands Management 123 Water Treatment Plant Operation 124 Chemical Waste Management 126 Other Environmental Regulating Acts 128 Other Environmental Programs 129 APPENDICES Appendix A: Interlaboratory Comparison Program Results 131 Appendix B: Data Reporting Conventions 150 Appendix C: REMP Sampling Summary 152 iii

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report List of Tables Table Page Title Number Number Risk Factors: Estimated Decrease in Average Life Expectancy 1 10 Sample Codes and Collection Frequencies 2 30 Sample Collection Summary 3 31 Radiochemical Analyses Performed on REMP Samples 4 33 Air Monitoring Locations 5 39 Milk Control Location 6 44 Groundwater Monitoring Locations 7 46 Broadleaf Vegetation Locations 8 47 Treated Surface Water Locations 9 52 Untreated Surface Water Locations 10 55 Shoreline Sediment Locations 11 56 Fish Locations 12 58 Thermoluminescent Dosimeter Locations 13 64 Gaseous Effluents - Summation of All Releases 14 84 Gaseous Effluents - Ground Level Releases - Batch Mode 15 85 Gaseous Effluents - Ground Level Releases - Continuous Mode 15 86 Ground Level Releases - LLDs for Continuous and Batch Mode 15 87 Gaseous Effluents - Mixed Mode Releases -Batch Mode 16 88 Gaseous Effluents - Mixed Mode Releases - Continuous Mode 16 89 LLDs for Gaseous Effluents - Mixed Mode Releases 16 90 Liquid Effluents - Summation of All Releases 17 91 Liquid Effluents - Nuclides Released in Batch Releases 18 92 iv

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table Page Title Number Number Liquid Effluents - Nuclides Released in Continuous Releases 18 94 Liquid Effluents - LLDs for Nuclides Released 18 95 Solid Waste and Irradiated Fuel Shipments 19 96 2019 Groundwater Tritium Results 20 99 Doses Due to Gaseous Releases for January through December 2019 21 101 Doses Due to Liquid Releases for January through December 2019 22 102 Annual Dose to the Most Exposed (from all pathways) Member 23 102 of the Public 2019 Closest Exposure Pathways Present in 2019 24 106 Pathway Locations and Corresponding Atmospheric Dispersion (X/Q) 25 108 and Deposition (D/Q) Parameters Summary of Meteorological Data Recovery for 2019 26 113 Summary of Meteorological Data Measured for 2019 27 114 Joint Frequency Distribution by Stability Class 28 119 V

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report List of Figures Figure Page Description Number Number-The Atom 1 1 Principal Decay Scheme of the Uranium Series 2 3 Range and Shielding 3 4 Sources of Radiation Exposure to the US Population 4 8 Fission Diagram 5 12 Fuel Rod, Fuel Assembly, Reactor Vessel 6 13 Station Systems 7 15 Initial HSM-80 Dry Fuel Storage Module Arrangement 8 21 Map of Area Surrounding Davis-Besse 9 22 2019 Airborne Gross Beta 10 38 Air Sample Site Map 11 40 Air Samples 25-mile Map - Community 12 41 Air Samples 25-mile Map - Control 13 42 Gross Beta Ground Water 1982-2019 14 45 Broadleaf Vegetation - Indicator Map 15 48 Terrestrial- Control Map 16 49 Gross Beta in Treated Surface Water 1972-2019 17 51 Gross Beta Concentration in Untreated Surface Water 1977-2019 18 54 Gross Beta in Fish 1972-2019 19 57 Aquatic Site Map 20 59 Aquatic 5-mile Map ~~ - ~ - ---~~-------2_.~1~ - 60--~---

Aquatic 25-mile Map 22 61 Gamma Dose for Environmental TLDs 1973 - 2019 23 63 TLD Site Map 24 68 TLD 5-mile Map 25 69 TLD 25-mile Map 26 70 Exposure Pathways 27 77 VI

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure Page Description Number Number Davis-Besse Onsite Groundwater Monitoring H-3 Trends 28 100 Land Use Census Map 29 105 Wind Rose Annual Average 100M 30 116 Wind Rose Annual Average 75M 31 117 Wind Rose Annual Average 1OM 32 118 vii

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Executive Summary The Annual Radiological Environmental Operating Report (AREOR) is a detailed report on the Environmental Monitoring Programs conducted at the Davis-Besse Nuclear Power Station (Da-vis-Besse) from January 1 through December 31, 2019. This report meets the requirements in NRC Regulatory Guide 4.8, Section 5.6 of Davis-Besse Technical Specifications, and Davis-Besse Offsite Dose Calculation Manual (ODCM) Section 7.1. Reports included are the Radio-logical Environmental Monitoring Program, Radiological Effluents Release Report, Land Use Census, Groundwater Monitoring, and the Non-Radiological Environmental Programs, which consist of Meteorological Monitoring, Land and Wetland Management, Water Treatment, Chem-ical Waste Management, and Waste Minimization and Recycling.

Radiological Environmental Monitoring Program The Radiological Environmental Monitoring Program (REMP) is established to monitor the ra-diological condition of the environment around Davis-Besse. The REMP is conducted in ac-cordance with NRC Regulatory Guide 4.8, Davis-Besse Technical Specifications, and the Davis-Besse ODCM, Section 6.0. This program includes the sampling and analysis of environmental samples and evaluation of the effects of releases of radioactivity on the environment.

Radiation levels and radioactivity have been monitored within a 25-mile radius around Davis-Besse since 1972. The REMP was established at Davis-Besse approximately five years before the Station became operational. This pre-operational sampling and analysis program provided data on radiation and radioactivity normally present in the area as natural background. Davis-Besse has continued to monitor the environment by sampling air, groundwater, milk, vegetables, drinking water, surface water, fish, shoreline sediment, and by direct measurement of radiation.

Samples are collected :from Indicator and Control locations. Indicator locations are within 5 miles of the site and are expected to show naturally occurring radioactivity plus any increases of radioactivity that might occur due to the operation of Davis-Besse. Control locations are farther away :from the Station and are expected to indicate the presence of only naturally occurring radi-oactivity. The results obtained from the samples collected :from Indicator locations are compared with the results :from those collected from Control locations and with the concentrations present in the environment before Davis-Besse became operational. This allows for the assessment of any impact the operation of Davis-Besse might have had on the surrounding environment.

Approximately 1,200 radiological environmental samples were collected and analyzed in 2019.

There were eleven missed air samples due to severe weather and sample pump performance is-sues. An air monitor refurbishment plan was implemented in 2019 to resolve those issues. There was also one anomaly during the year involving an Inner Ring TLD quarterly dose reading. In all incidents referenced above, other REMP samples were available, collected, and analyzed to ensure ODCM Table 6-1 requirements were met.

The results of the REMP indicate that Davis-Besse continues to be operated safely in accordance with applicable federal regulations. No significant increase above background radiation or radi-oactivity is attributed to the operation of Davis-Besse.

The sampling results are divided into four sections: atmospheric monitoring, terrestrial monitor-ing, aquatic monitoring and direct radiation monitoring.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Air samples are continuously collected at nine locations. Four samples are collected onsite. The other five are located between one and twenty-one miles away. Particulate filters and iodine car-tridges are collected weekly. The 2019 Indicator results were in close agreement with the sam-ples collected at Control locations.

Terrestrial monitoring includes analysis of milk (Control only), groundwater (Control only), and vegetables. Samples are collected onsite and up to twenty-five miles away, depending on the type of sample. Results of terrestrial sample analyses indicate concentrations of radioactivity similar to previous years and indicate no build-up of radioactivity due to the operation of Davis-Besse.

Aquatic monitoring includes the collection and analysis of drinking water (Treated Surface Wa-ter), Untreated Surface Water, fish and shoreline sediments collected onsite and in the vicinity of Lake Erie. In 2019, tritium was detected in six Untreated Water samples and one Treated Water sample slightly above the detection limit of 330 pCi/1 and is a small fraction of the 20,000 pCi/1 Environmental Protection Agency drinking water limit.

The 2019 results of analysis for fish, treated surface water and shoreline sediment indicate nor-mal background concentration of radionuclides and show no increase or build-up of radioactivity due to the operation of Davis-Besse.

Direct radiation averaged 15.1 mrem/91 days at Indicator locations and 15.5 mrem/91 days at Control locations, which is similar to results from previous years. Quarterly and annual gamma TLD dose rates for 2019 were evaluated using the methodologies presented in ANSI/HPS N13.37-2014 (R2019), "Environmental Dosimetry - Criteria for System De,sign and Implemen-tation," and U.S. NRC Regulatory Guide 4.13, Revision 2, "Environmental Dosimetry - Perfor-mance Specifications, Testing, and Data Analysis. The evaluation of Facility Related Dose at each TLD location determined that all quarterly and annual doses were considered "non-detectable". No increase above natural background radiation attributable to Davis-Besse was observed in 2019.

The operation of Davis-Besse in 2019 caused no significant increase in the concentrations of ra-dionuclides or adverse effects on the quality of the environment surrounding the plant. Radioac-tivity released in the Station's effluents was well below the applicable federal regulatory limits.

The estimated radiation dose to the general public due to the operation of Davis-Besse in 2019 was well below all applicable regulatory limits.

In order to estimate radiation dose to the public, the pathways through which public exposure can occur must be known. To identify these exposure pathways, an Annual Land Use Census is per-formed as part of the REMP. During the census, Station personnel travel every public road with-in a radius of five miles of Davis-Besse to locate radiological exposure pathways (e.g.,

residences, vegetable gardens, milk cows/goats, etc.). The most important pathway is the one that, for a specific radionuclide, provides the greatest dose to a sector of the population. This is called the critical pathway. The critical pathway for 2019 was a garden in the West sector 0.97 miles from Davis-Besse, which has not changed from 2018.

Radiological Effluent Release Report The Radiological Effluent Release Report (RERR) is a detailed listing of radioactivity released from the Davis-Besse Nuclear Power Station during the period January 1 through December 31, ix

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report 2019. The doses due to radioactivity released during this period were only a fraction of allowable per our operating license.

The Total Body doses to an individual and population in an unrestricted area due to direct radiation from Davis-Besse is not distinguishable from background. These doses represent an extremely small fraction of the limits set by the NRC or the limits set in the ODCM.

Unplanned Releases There were no unplanned releases of liquid or gaseous radioactivity from Davis-Besse during 2019.

Changes to the Offsite Dose Calculation Manual (ODCM) and the Process Con-trol Program (PCP)

There were two revisions to the ODCM in 2019. Changes included incorporating results of the 2019 Land Use Census and merging the REMP Enhancement program into the ODCM-required REMP program. The resulting consolidated program added multiple Indicator sample locations to ensure compliance with the minimum number of samples required in ODCM Table 6-1 in the event of a missed sample.

There were no revisions of the PCP during 2019.

Groundwater Protection Initiative (NEI 07-07)

Davis-Besse began sampling wells near the plant in 2007 as part of an industry-wide Groundwater Protection Initiative (GPI), which was established to ensure that there are no inadvertent releases of radioactivity from the plant which could affect offsite groundwater supplies. In addition to several existing pre-construction era wells, sixteen new GPI monitor-ing wells were installed in 2007 to accomplish the monitoring required. These wells are not used for drinking water purposes and are typically sampled in spring and fall of each year.

Groundwater wells were sampled twice in 2019 (spring and fall). Tritium was less than 2,000 pCi/L in all 40 samples collected, which is the threshold for making courtesy informa-tional notifications to local, county and state officials. Overall site groundwater flows in a west to east direction and discharges to the Intake Canal. Potential leaks or spills of licensed material originating from DBNPS would be captured by pumping water from the Intake Ca-nal back into the station as part of normal plant operations.

All assumptions regarding groundwater flow and modeling remain valid that the flow does not impact areas outside the Owner Controlled Area and essentially discharges into the In-take Canal.

Non-Radiological Environmental Programs Meteorological Monitoring The Meteorological Monitoring Program at Davis-Besse is part of a program for evaluating the radiological effects of the routine operation of Davis-Besse on the surrounding environment.

Meteorological monitoring began in October of 1968.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Meteorological data recorded at Davis-Besse include wind speed, wind direction, sigma theta (standard deviation of wind direction), ambient temperature, differential temperature, dew point and precipitation. Two instrument-equipped meteorological towers are used to collect data.

Data recovery for the five instruments that are operationally required by Davis-Besse Technical Requirements Manual was 98.9% in 2019.

Marsh Management FirstEnergy owns the Navarre Marsh. It is leased to the U.S. Fish and Wildlife Service, who manage it as part of the Ottawa National Wildlife Refuge.

Water and Wastewater Treatment Davis-Besse withdraws water from Lake Erie and processes it through a vendor-supplied water treatment process to produce the high-purity water used in the Station's cooling systems.

Since December 1, 1998, the Carroll Township Water Treatment Plant has provided for domestic water needs at Davis-Besse.

Sewage is treated at the Davis-Besse Wastewater Treatment Plant (WWTP) and its effluent is pumped to a settling basin. Following a retention period, this water is discharged with other Sta-tion liquid effluents back to Lake Erie. There was one exceedance of the National Pollutant Dis-charge Elimination System (NPDES) permit in 2019 at Outfall 001 which identified Total Residual Oxidant (TRO) concentration (0.057 mg/L) slightly above the NPDES limit of 0.050 mg/1.

Chemical Waste Management The Chemical Waste Management Program at Davis-Besse was developed to ensure that the offsite disposal of non-radioactive hazardous and nonhazardous chemical wastes is performed in accordance with all applicable state and federal regulations. Chemical waste disposal vendors contracted by Davis-Besse use advanced technology for offsite disposal, including recycling of chemical wastes, in order to protect human health and the environment. In 2019, the Davis-Besse Nuclear Power Station generated approximately 1,701 pounds of hazardous waste. Non-hazardous wastes generated include 3,017 gallons of used oil and 10,485 pounds of materials such as oil filters, resins, caulk, latex paints, and grout. As required by Superfund Amendment and Reauthorization Act (SARA), Davis-Besse reported hazardous products and chemicals to local fire departments and local and state planning commissions. As part of the program to re-move PCB fluid from Davis-Besse, all electrical transformers have been retro-filled and reclassi-fied as non-PCB transformers.

Waste Minimization and Recycling The Waste Minimization and Recycling Program at Davis-Besse began in 1991 with the collec-tion and recycling of paper. This program was expanded and reinforced during 1993 to include the recycling of aluminum cans and metal. The scrap metal collected onsite is sold to scrap compames.

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7 Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Appendices Appendix A includes results from the Inter-laboratory Comparison Program required by the Da-vis-Besse ODCM. Samples with known concentrations of radioisotopes are prepared by the En-vironmental Resources Associates (ERA), and then sent (with information on sample type and date of collection only) to the laboratory contracted by Davis-Besse to analyze its REMP sam-ples. The Environmental Resources Associates (ERA) compares results to known standards.

Appendix B contains data reporting conversions used in the REMP at Davis-Besse. The appen-dix provides an explanation of the format and computational methods used in reporting REMP data. Information on counting uncertainties and the calculations of averages and standard devia-tions are also provided.

Appendix C provides a REMP sampling summary from 2019. The appendix provides a listing of the following for each sample type:

• number and type of analysis performed

• lower limit of detection for each analysis (LLD)

• mean and range of results for Control and Indicator locations

• mean, range, and description of location with highest annual mean

• number of non-routine results For detailed studies, Appendix C provides more specific information than that listed in this re-port. The information presented in Appendices A through C was provided by Environmental, Inc. Midwest Laboratory in their Final Progress Report to Davis-Besse (February 12, 2020).

xii

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Introduction Nuclear power provides a clean and readily available source of energy. The operation of nuclear power stations has a very small impact on the environment. In fact, the Davis-Besse Nuclear Power Station is surrounded by hundreds of acres of marshland, which make up part of the Ottawa National Wildlife Refuge. In order to provide better understanding of this unique source of energy, back-ground information on basic radiation characteristics, risk assessment, reactor operation and effluent control is provided in this section.

Fundamentals The Atom All matter consists of atoms. Simply de-scribed, atoms are made up of positively and negatively charged particles, and particles which are neutral. These particles are called

@ Q ?ROTON protons, electrons, and neutrons, respec-tively (Figure I). The relatively large pro-X ==*

tons and neutrons are packed tightly to-gether in a cluster at the center of the atom called the nucleus. Orbiting around the nu-cleus are one or more smaller electrons. In ~-'<*D ,

an electrically neutral atom the negative charges of the electrons are balanced by the positive charges of the protons. Due to their

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"-----J ORBIT have a strong attraction for each other. This holds the atom together. Other attractive forces between the protons and neutrons Figure 1: An atom consists of two parts: a nucleus keep the densely packed protons from repel- containing positively charged protons and electrically neutral neutrons and one or more negatively charged ling each other, and prevent the nucleus electtons orbiting the nucleus. Protons and neutrons from breaking apart. are nearly identical in size and weight, while each is about 2000 times heavier than an electron.

1

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Radiation and Radioactivity Isotopes and Radionuclides A group of identical atoms containing the same number of protons make up an element. In fact, the number of protons an atom contains determines its chemical identity. For instance, all atoms with one proton are hydrogen atoms, and all atoms with eight protons are oxygen atoms. How-ever, the number of neutrons in the nucleus of an element may vary. Atoms with the same num-ber of protons but different numbers of neutrons are called isotopes. Different isotopes of the same element have the same chemical properties, and many are stable or nonradioactive. An un-stable or radioactive isotope of an element is called a radioisotope, a radioactive atom, or a radionuclide. Radionuclides usually contain an excess amount of energy in the nucleus. The excess energy is usually due to a surplus or deficit in the number of neutrons in the nucleus. Ra-dionuclides such as Uranium-238, Berylium-7 and Potassium-40 occur naturally. Others are man-made, such as Iodine-131, Cesium-137, and Cobalt-60.

Radiation Radiation is simply the conveyance of energy through space. For instance, heat emanating from a stove is a form of radiation, as are light rays, microwaves, and radio waves. Ionizing radiation is anoth~r type of radiation and has similar properties to those of the examples listed above. Ion-izing radiation consists of both electromagnetic radiation and particulate radiation. Electro-magnetic radiation is energy with no measurable mass that travels with a wave-like motion through space. Included in this category are gamma rays and X-rays. Particulate radiation con-sists of tiny, fast moving particles which, if unhindered, travel in a straight line through space.

The three types of particulate radiation of concern to us are alpha particles, which are made up of 2 protons and 2 neutrons; beta particles, which are essentially free electrons; and neutrons. The properties of these types of radiation will be described more fully in the Range and Shielding sec-tion.

Radioactive Decay Radioactive atoms, over time, will reach a stable, non-radioactive state through a process known as radioactive decay. Radioactive decay is the release of energy from an atom through the emission of ionizing radiation. Radioactive atoms may decay directly to a stable state or may go through a series of decay stages, called a radioactive decay series, and produce several daugh-ter products that eventually result in a stable atom. The loss of energy and/or matter through radioactive decay may transform the atom into a chemically different element. For example, when Uranium-238 decays, it emits an alpha particle and, as a result, the atom loses 2 protons and 2 neutrons. As discussed previously, the number of protons in the nucleus of an atom de-termines its chemical identity. Therefore, when the Uranium-238 atom loses the 2 protons and 2 neutrons, it is transformed into an atom of Thorium-234. Thorium-234 is one of the 14 succes-sive daughter products of Uranium-238. Radon is another daughter-product, and the series ends with stable Lead-206.

2

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report This example is part of a known radioactive decay series, called the Uranium series, which be-gins with Uranium-238 and ends with Lead-206 (Figure 2).

23BLJ 234LJ 4.5 x 109 Yr 2.5 X 105 Yr 234Pa

! 1.2 min  !

234Th 230Th 24d 8.0 x 104 Yr

! Beta Decay Alpha Decay 226Ra 1600 Yr 222Rn 3.82 d 21ap O 214p O 21op 0 3.05 min 1.6 X 10-4 S 138.4 d

! 214Bi 19.7 min  ! 210Bi 5.01 d 214pb 210pb 206pb 26.8 min 23 Yr stable Figure 2: Principal Decay Scheme of the Uranium Series.

Half-life Most radionuclides vary greatly in the frequency with which their atoms release radiation. Some radioactive materials, in which there are only infrequent emissions, tend to have a very long half-life. Those radioactive materials that are very active, emitting radiation more frequently tend to have comparably shorter half-lives. The length of time an atom remains radioactive is defined in terms of its half-life. Half-life is the amount of time required for a radioactive substance to lose half of its activity through the process of radioactive decay. Half-lives vary from millionths of a second to millions of years.

Interaction with Matter Ionization Through interactions with atoms, alpha, beta, and gamma radiation lose their energy. When these forms of radiation interact with any form of material, the energy they impart may cause 3

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report atoms in that material to become ions, or charged particles. Normally, an atom has the same number of protons as electrons. Thus, the positive and negative charges cancel, and the atom is electrically neutral. When one or more electrons are removed an ion is formed. Ionization is one of the processes that may result in damage to biological systems.

Range and Shielding Particulate and electromagnetic radiation each travel through matter differently because of their different properties. Alpha particles contain 2 protons and 2 neutrons, are relatively large, and carry an electrical charge of +2. Alpha particles are ejected from the nucleus of a radioactive atom at speeds ranging from 2,000 to 20,000 miles per second. However, due to its comparative-ly large size, an alpha particle usually does not travel very far before it loses most of its energy through collisions and interactions with other atoms. As a result, a sheet of paper or a few cen-timeters of air can easily stop alpha particles (Figure 3).

Beta particles are very small, and comparatively fast particles, traveling at speeds near the speed of light (186,000 miles per second). Beta particles have an electrical charge of either +1 or -1.

Because they are so small and have a low charge, they do not collide and interact as often as al-pha particles, so they can travel farther. Beta particles can usually travel through several meters of air, but may be stopped by a thin piece of metal or wood.

RADIOAC"TIVE MATERIAL PAPER ALUMINUM LE'AO CONCRETE.

Figure 3: As radiation travels, it collides and interacts with other atoms and loses energy. Alpha particles can be stopped by a sheet of paper, and beta particles by a thin sheet of aluminum. Gamma radiation is shielded by highly dense materials such as lead, while hydrogenous materials (those containing hydrogen atoms), such as water and concrete, are used to stop neutrons.

Gamma rays are pure energy and travel at the speed of light. They have no measurable charge or mass, and generally travel much farther than alpha or beta particles before being absorbed. After repeated interactions, the gamma ray finally loses all of its energy and vanishes. The range of a gamma ray in air varies, depending on the ray's energy and interactions. Very high-energy gamma radiation can travel a considerable distance, whereas low energy gamma radiation may travel only a few feet in air. Lead is used as shielding material for gamma radiation because of its density. Several inches of Lead or concrete may be needed to effectively shield gamma rays.

4

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Neutrons come from several sources, including the interactions of cosmic radiation with the earth's atmosphere and nuclear reactions within operating nuclear power reactors. However, neutrons are not of environmental concern since the neutron source at nuclear power stations is sealed within the containment building.

Because neutrons have no charge, they are able to pass very close to the nuclei of the material through which they are traveling. As a result, neutrons may be captured by one of these nuclei or they may be deflected. When deflected, the neutron loses some of its energy. After a series of these deflections, the neutron has lost most of its energy. At this point, the neutron moves about as slowly as the atoms of the material through which it is traveling, and is called a thermal neu-tron. In comparison, fast neutrons are much more energetic than thermal neutrons and have greater potential for causing damage to the material through which they travel. Fast neutrons can have from 200 thousand to 200 million times the energy of thermal neutrons.

Neutron shielding is designed to slow fast neutrons and absorb thermal neutrons. Neutron shielding materials commonly used to slow neutrons down are water or polyethylene. The shield is then completed with a material such as Cadmium, to absorb the now thermal neutrons. At Da-vis-Besse, concrete is used to form an effective neutron shield because it contains water mole-cules and can be easily molded around odd shapes.

Quantities and Units of Measurement There are several quantities and units of measurement used to describe radioactivity and its ef-fects. Three terms of particular usefulness are activity, absorbed dose, and dose equivalent.

Activity: Curie Activity is the number of atoms in a sample that disintegrate (decay) per unit of time. Each time an atom disintegrates, radiation is emitted. The curie (Ci) is the unit used to describe the activity of a material and indicates the rate at which the atoms of a radioactive substance are decaying.

One curie indicates the disintegration of 37 billion atoms per second.

A curie is a unit of activity, not a quantity of material. Thus, the amount of material required to produce one curie varies. For example, one gram (1128th of an ounce) of radium-226 is the equivalent of one curie of activity, but it would take 9,170,000 grams (about 10 tons) of thorium-232 to equal one curie.

Smaller units of the curie are often used, especially when discussing the low concentrations of radioactivity detected in environmental samples. For instance, the microcurie (uCi) is equal to one millionth of a curie, while the picocurie (pCi) represents one trillionth of a curie.

5

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Absorbed Dose: Rad Absorbed dose is a term used to describe the radiation energy absorbed by any material exposed to ionizing radiation, and can be used for both particulate and electromagnetic radiation. The Rad (radiation absorbed dose) is the unit used to measure the absorbed dose. It is defined as the energy of ionizing radiation deposited per gram of absorbing material (1 Rad = 100 erg/gm).

The rate of absorbed dose is usually given in Rad/hr.

If the biological effect of radiation is directly proportional to the energy deposited by radiation in an organism, the Rad would be a suitable measurement of the biological effect. However, bio-logical effects depend not only on the total energy deposited per gram of tissue, but on how this energy is distributed along its path. Experiments have shown that certain types of radiation are more damaging per unit path of travel than are others. Thus, another unit is needed to quantify the biological damage caused by ionizing radiation.

Dose Equivalent: Rem Biological damage due to alpha, beta, gamma and neutron radiation may result from the ioniza-tion caused by this radiation. Some types of radiation, especially alpha particles which cause dense local ionization, can result in up to 20 times the amount of biological damage for the same energy imparted as do gamma or X-rays. Therefore, a quality factor must be applied to account for the different ionizing capabilities of various types of ionizing radiation. When the quality factor is multiplied by the absorbed dose, the result is the dose equivalent, which is an estimate of the possible biological damage resulting from exposure to a particular type of ionizing radia-tion. The dose equivalent is measured in rem (radiation equivalent man).

An example of this conversion from absorbed dose to dose equivalent uses the quality factor for alpha radiation, which is equal to 20. Thus, 1 Rad of alpha radiation is approximately equal to 20 rem. Beta and gamma radiation each have a quality factor of 1, therefore one Rad of either beta or gamma radiation is approximately equal to one rem. Neutrons have a quality factor rang-ing from 2 to 10. One rem produces the same amount of biological damage, regardless of the source. In terms of radiation, the rem is a relatively large unit. Therefore, a smaller unit, the millirem, is often used. One millirem (mrem) is equal to 1/1,000 of a rem.

Deep Dose Equivalent (DDE)

Deep dose equivalent is the measurement of dose within the body, from sources of radiation that are external to the body. It is what is measured and recorded on thermo luminescent dosimeters (TLDs), film badges or other dosimeters. For example, at Davis-Besse or at any hospital that has x-ray equipment, you will see people wearing these devices. These instruments are worn to measure DDE.

Committed Effective Dose Equivalent (CEDE)

Committed effective dose equivalent is a measure of the dose received from any radioactive ma-terial taken into the body. It is calculated from the sum of the products of the committed dose equivalent to the organ or tissue multiplied by the organ or tissue-weighting factor. CEDE ac-counts for all the dose delivered during the entire time the radioactive material is in the body.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Total Effective Dose Equivalent (TEDE)

Total effective dose equivalent is the sum of the deep dose equivalent (for dose from sources ex-ternal to the body) and the committed effective dose equivalent (for internal dose). Since they are both doses to the body, they are not tracked separately. The NRC limits occupational dose to a radiation worker to five rem (5,000 mrem) TEDE per year.

Sources of Radiation Background Radiation Radiation did not begin with the nuclear power industry, and occurs naturally on earth. It is probably the most "natural" thing in nature. Mankind has always lived with radiation and proba-bly always will. In fact, during every second of life, over 7,000 atoms undergo radioactive decay "naturally" in the body of the average adult. In addition, radioactive decay occurs naturally in soil, water, air and space. All these common sources of radiation contribute to the natural back-ground radiation to which we are all exposed.

The earth is being showered by a steady stream of high-energy gamma rays and particulate radia-tion that come from space known as cosmic radiation. The atmosphere shields us from most of this radiation, but everyone still receives about 20 to 50 mrem each year from this source. The thinner air at higher altitudes provides less protection against cosmic radiation. People living at higher altitudes or flying in an airplane are exposed to even higher levels cosmic radiation. Ra-dionuclides commonly found in the atmosphere as a result of cosmic ray interactions include Be-ryllium-?, Carbon-14, tritium (H-3), and Sodium-22.

Another common naturally occurring radionuclide is Potassium-40. About one-third of the ex-ternal and internal dose from naturally occurring background radiation is attributed to this radio-active isotope of potassium.

The major source of background radiation is Radon, a colorless, odorless, radioactive gas that re-sults from the decay of Radium-226, a member of the Uranium-238 decay series. Since Uranium occurs naturally in all soils and rocks, everyone is continuously exposed to Radon and its daugh-ter products. Radon is not considered to pose a health hazard unless it is concentrated in a con-fined area, such as buildings, basements or underground mines. Radon-related health concerns stem from the exposure of the lungs to this radioactive gas. Radon emits alpha radiation when it decays, which can cause damage to internal tissues when inhaled. As a result, exposure to the lungs is a concern since the only recognized health effect associated with exposure to Radon is an increased risk of lung cancer. This effect has been seen when Radon is present at levels common in uranium mines. According to the Health Physics Society, University of Michigan, more than half of the radiation dose the average American receives is attributed to Radon.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Sources of Radiation Exposure to the US Population Consumer Products 3Y.

Other Nuclear Medicine

<1Y.

4Y.

Medical X-ra,s 11 Y.

Internal 11Y.

Radon 54Y.

Terrestrial 8Y.

Figure 4: The most significant annual dose received by an individual of the public is that received from naturally occurring radon. A very small annual dose to the public results from producing electricity by nuclear power (taken from the Health Physics Society, University of Michigan, 2013).

Further information on Radon, its measurement, and actions to reduce the Radon concentration in buildings can be obtained by contacting the state Radon program office at the following ad-dress:

Ohio Department of Health Bureau of Environmental Health and Radiation Protection Radon Education & Licensing Program 35 Chestnut Street Columbus, Ohio 43215 Telephone: (800) 523-4439 E-mail: indoor.radon@odh.ohio.gov The approximate average background radiation in the northern Ohio area is 620 mrem/year (Princeton University, 2013).

Man-made Radiation In addition to naturally occurring cosmic radiation and radiation from naturally occurring radio-activity, people are also exposed to man-made radiation. The largest sources of exposure include medical x-rays and radioactive pharmaceuticals. Small doses are also received from consumer products such as televisions, smoke detectors, and fertilizers. Fallout from nuclear weapons tests is another source of man-made exposure. Fallout radionuclides include Strontium-90, 8

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Cesium-13 7, and tritium. Less than one percent of the annual dose a member of the public re-ceives is a result of having electricity generated by nuclear power.

Health Effects of Radiation The effects of ionizing radiation on human health have been under study for more than one hun-

. dred years. Scientists have obtained valuable knowledge through the study of laboratory animals that were exposed to radiation under extremely controlled conditions. However, it has been dif-ficult to relate the biological effects of irradiated laboratory animals to the potential health effects on humans.

The effects of radiation on humans can be divided into two categories, somatic and genetic. So-matic effects are those which develop in the directly exposed individual, including an unborn child. Genetic effects are those which are observed in the offspring of the exposed individual.

Somatic effects can be divided further into acute and chronic effects. Acute effects develop shortly after exposure to large amount of radiation. Much study has been done with human pop-ulations that were exposed to ionizing radiation under various circumstances. These groups in-clude the survivors of the atomic bomb, persons undergoing medical radiation treatment, and early radiologists, who accumulated large doses of radiation, unaware of the potential hazards.

Chronic effects are a result of exposure to radiation over an extended period of time. Examples of such groups are clock dial painters, who ingested large amounts of Radium by "tipping" the paint brushes with their lips, and Uranium miners, who inhaled large amounts of radioactive dust while mining pitchblende (Uranium ore). The studies performed on these groups have increased our knowledge of the health effects from comparatively very large doses of radiation received over long periods of time.

Continuous exposure to low levels of radiation may produce somatic changes over an extended period of time. For example, someone may develop cancer from man-made radiation, back-ground radiation,* or some other source not related to radiation. Because all illnesses caused by low level radiation can also be caused by other factors, it is virtually impossible to determine in-dividual health effects of low level radiation. Even though no effects have been observed at dos-es less than 50 rem, we assume the health effects resulting from low doses of radiation occur proportionally to those observed following large doses of radiation. Most radiation scientists agree that this assumption over-estimates the risks associated with a low-level radiation expo-sure. The effects predicted in this manner have never been actually observed in any individuals exposed to low level radiation. Therefore, the most likely somatic effect of low level radiation is believed to be a small increased risk of cancer. Genetic effects could occur as a result of ioniz.:.

ing radiation interacting with the genes in the human cells. Radiation (as well as common chem-icals) can cause physical changes or mutations in the genes. Chromosome fibers can break and rearrange, causing interference with the normal cell division of the chromosome by affecting their number and structure. A cell is able to rejoin the ends of a broken chromosome, but ifthere are two breaks close enough together in space and time, the broken ends from one break could join incorrectly with those from another. This could cause translocations, inversions, rings, and other types of structural rearrangements. When this happens, new mutated genes are created.

Radiation is not the only mechanism by which such changes can occur. Spontaneous mutations and chemically induced mutations also have been observed. These mutated genes may be passed 9

7 Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report from parent to offspring. Viable mutat.ions due to low level, low dose radiation have not been observed in humans.

Health Risks While people may accept the risks inherent in their personal activities, such as smoking and driv-ing to work each day, they are less inclined to accept the risk inherent in producing electricity.

As with any industrial environment, it is not possible to guarantee a risk-free environment. Thus, attention should be focused on taking steps to safeguard the public, on developing a realistic as-sessment of the risks, and on placing these risks in perspective. The perceptions of risk associat-ed with exposure to radiation may have the greatest misunderstanding. Because people do not understand ionizing radiation and its associated risks, many fear it. This fear is compounded by the fact that we cannot hear, smell, taste or feel ionizing radiation.

We do not fear other potentially hazardous things for which we have the same lack of sensory perception, such as radio waves, carbon monoxide, and small concentrations of numerous can-cer-causing substances. These risks are larger and measurable compared to those presumed to be associated with exposure to low level, low dose radiation. Most of these risks are with us throughout our lives, and can be added up over a lifetime to obtain a total effect. Table 1 shows a number of different factors that decrease the average life expectancy of individuals in the Unit-ed States.

Table 1: Risk Factors: Estimated Decrease in Average Life Expectancy Overweight by 30%: 3.6 years Cigarette smoking: 1 pack/day 7.0 years 2 packs/day 10.0 years Heart Disease: 5.8 years Cancer: 2.7 years City living (non-rural): 5.0 years All operating commercial nuclear power plants totaled: less than 12 minutes

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Benefits of Nuclear Power Nuclear power plays an important part in meeting today's electricity needs, and will continue to serve as an important source of electric energy well into the future. Today approximately twenty percent of the electricity produced in the United States is from nuclear powered electrical gener-ating stations.

Nuclear power offers several advantages over alternative sources of electric energy:

• Nuclear power has an excellent safety record dating back to 1958, when the first commercial nuclear power station began operating,

• Uranium, the fuel for nuclear power stations, is a relatively inexpensive fuel that is readily available in the United States,

• Nuclear power is the cleanest energy source for power stations that use steam to produce electricity. There are no greenhouse gases or acid gases produced when using nuclear fuel.

The following sections provide information on the fundamentals of how Davis-Besse uses nucle-ar fuel and the fission process to produce electricity.

Nuclear Power Production Electricity is produced in a nuclear power station in the same way as in a fossil-fueled station with the exception of the source of heat. Heat changes water to steam that turns a turbine. In a fossil-fueled station, the fuel is burned in a furnace, which is also a boiler. Inside the boiler, wa-ter is turned into steam. In a nuclear station, a reactor that contains a core of nuclear fuel, pri-marily uranium, replaces the furnace. Heat is produced when the atoms of Uranium are split inside the reactor. The process of splitting atoms is called fission.

What is Fission?

A special force called the binding force holds the protons and neutrons together in the nucleus of the atom. The strength of this binding force varies from atom to atom. If the bond is weak enough, the nucleus can be split when bombarded by a free neutron (Figure 5). This causes the entire atom to split, producing smaller atoms, more free neutrons, and heat. In a nuclear reactor, a chain reaction of fission events provides the heat necessary to boil the water to produce steam.

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7 Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure 5: When a heavy atom, such as uranium-235 is split or fissioned, heat, free neutrons, and fission fragments result. The free neutrons can then strike neighboring atoms causing them to fission also. In the proper environment, this process can continue indefinitely in a chain reaction.

Nuclear Fuel The fissioning of one Uranium atom releases approximately 50 million times more energy than the combustion of a single Carbon atom common to all fossil fuels. Since a single small reactor fuel pellet contains trillions of atoms, each pellet can release an extremely large amount of ener-gy. The amount of electricity that can be generated from three small fuel pellets would require about 3.5 tons of coal or 12 barrels of oil to generate.

Nuclear fission occurs spontaneously in nature, but these natural occurrences cannot sustain themselves because the freed neutrons either are absorbed by non-fissionable atoms or quickly decay. In contrast, a nuclear reactor minimizes neutron losses, thus sustaining the fission pro-cess by several means:

• using fuel that is free of impurities that might absorb the free neutrons,

• enriching the concentration of the rarer fissionable isotope of Uranium (U-235) relative to the concentration of U-238, a more common isotope that does not fis-sion easily,

• slowing down neutrons by providing a "moderator" such as water to increase the probability of fission.

Natural Uranium contains less than one percent U-235 compared to the more abundant U-238 when it's mined. Before it can be economically used in a reactor, it is enriched to three to five percent U-235, in contrast to nuclear material used in nuclear weapons which is enriched to over 97 percent. Because of the low levels of U-235 in nuclear fuel, a nuclear power station cannot explode like a bomb.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report After the Uranium ore is separated from the earth and rock, it is concentrated in a milling pro-cess. After milling the ore to a granular form and dissolving out the Uranium with acid, the Ura-nium is converted to Uranium hexafluoride (UF6). UF6 is a chemical form of Uranium that exists as a gas at temperatures slightly above room temperature. The UF 6 is then highly purified and shipped to an enrichment facility where gaseous diffusion converters increase the concen-tration of U-235. The enriched gaseous UF6 is then converted into powdered Uranium dioxide (U02), a highly stable ceramic material. The UO2 powder is put under high pressure to form fuel pellets, each about 5/8 inch long and 3/8 inch in diameter. Approximately five pounds of these pellets are placed into a 12-foot long metal tube made of Zirconium alloy. The tubes con-stitute the fuel cladding. The fuel cladding is highly resistant to heat, radiation, and corrosion.

When the tubes are filled with fuel pellets, they are called fuel rods.

The Reactor Core Two hundred eight fuel rods comprise a single fuel assembly. The Reactor core at Davis-Besse contains 177 of these fuel assemblies, each approximately 14 feet tall and 2,000 pounds in weight. In addition to the fuel rods, the fuel assembly also contains 16 vacant holes for the inser-tion of control rods, and one vacant hole for an incore-monitoring probe. This probe monitors temperature and neutron levels in the fuel assembly. The Davis-Besse reactor vessel, which con-tains ~11 the fuel assemblies, weighs 838,000 pounds, has a diameter of 14 feet, is 39 feet high, and has steel walls that are 8 1/2 inches thick.

REAClOR VESSEL Figure 6: The reactor core at Davis-Besse contains 177 fuel assemblies. Each assembly contains 208 fuel rods.

Each fuel rod is filled with approximately five pounds of fuel pellets. Each pellet is approximately 3/8 inch diame-ter and 5/8 inch long.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Fission Control Raising or lowering control rod assemblies into the reactor core controls the fission rate. Each assembly consists of "fingers" containing Silver, Indium, and Cadmium metals that absorb free neutrons, thus disrupting the fission chain reaction. When control rod .assemblies are slowly withdrawn from the core, the fission process begins and heat is produced. If the control rod as-semblies are inserted rapidly into the reactor core, as occurs during a plant "trip", the chain reac-tion ceases. A slower acting (but more evenly distributed) method of fission control is achieved by the addition of a neutron poison to the reactor coolant water. At Davis-Besse, high-purity boric acid is concentrated or diluted in the coolant to achieve the desired level of fission. Boron-10 readily absorbs free neutrons, forming Boron-I 1, removing the absorbed neutrons from the chain reaction.

Reactor Types Virtually all of the commercial reactors in this country are either boiling water reactors (BWRs) or pressurized water reactors (PWRs). Both types are also called light water reac-tors (LWRs) because their coolant, or medium to transfer heat, is ordinary water, which contains the light isotope of Hydrogen. Some reactors use the heavy isotope of Hydrogen (deuterium) in the reactor coolant. Such reactors are called heavy water reactors (HWRs).

In BWRs, water passes through the core and boils into steam. The steam passes through separa-tors, which remove water droplets. *The steam then travels to dryers before entering the turbine.

After passing though the turbine the steam is condensed back into water and returns to the core to repeat the cycle.

In PWRs, the reactor water or coolant is pressurized to prevent it from boiling. The reactor wa-ter is then pumped to a steam generator (heat exchanger) where its heat is transferred to a sec-ondary water supply. The secondary water inside the steam generator boils into steam, which is

.then used to turn the turbine. This steam is then condensed back into water and returned to the steam generator. Davis-Besse uses a PWR design.

The following paragraphs describe the various systems illustrated in Figure 7. Major systems in .

the Davis-Besse Station are assigned a different color in the figure.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Station Systems Containment Building and Fission Product Release Barriers The Containment building houses the reactor vessel, the Pressurizer, two steam generators, the Reactor Coolant Pumps and Reactor Coolant System piping. The building is constructed of an inner 1-1/2 inch thick steel liner or Containment vessel, and the Shield Building with steel-reinforced concrete walls 2 feet thick. The shield building protects the containment vessel from.

a variety of environmental factors and provides an area for a negative pressure boundary around the steel Containment vessel. In the event that the integrity of the Containment vessel is compromised (e.g., a crack develops), this negative pressure boundary ensures that any airborne radioactive contamination present in the containment vessel is prevented from. leaking out into the environment. This is accomplished by maintaining the pressure inside the Shield Building lower than that outdoors, thus forcing clean outside air to leak in. This minimizes potentially contaminated air between the Containment vessel and the Shield Building from. leaking out. The Containment vessel is the third in a series of barriers that prevent the release of fission products in the unlikely event of an accident. The first barrier to the release of fission products is the fuel cladding itself. The second barrier is the walls of the primary system., i.e. the reactor vessel, steam generator and associated piping.

The Steam Generators The steam generators perform the same function as a boiler at a fossil-fueled power station.

The steam generator uses the heat of the primary coolant inside the steam. generator tubes to boil the secondary side feedwater (secondary coolant). Fission heat from. the reactor core is trans-ferred to the steam. generator in order to provide the steam necessary to drive the turbine. How-ever, heat must also be removed from the core even after reactor shutdown in order to prevent damage to the fuel cladding. Therefore, pumps maintain a continuous flow of coolant through the reactor and steam generator. Primary loop water (green in Figure 7) exits the reactor at ap-proximately 606°F, passes through the steam. generator, transferring some of its heat energy to the Secondary loop water (blue in Figure 7) without actually coming in contact with it. Primary coolant water exits the steam. generator at approximately 558°F to be circulated back into the re-actor where it is again heated to 606°F as it passes up through the fuel assemblies. Under ordi-nary conditions, water inside the primary system. would boil long before it reached such temperatures. However, it is kept under a pressure of approximately 2,200 pounds-per-square-inch (psi) at all times. This prevents the water from boiling and is the reason the reactor at Da-vis-Besse is called a Pressurized Water Reactor. Secondary loop water enters the base of the steam. generator at approximately 450°F and under 1,100 psi pressure. At this pressure, the wa-ter can easily boil into steam. as it passes over the tubes containing the primary coolant water.

Both the primary and the secondary coolant water are considered closed loop systems. This means that they are designed not to come in physical contact with one another. Rather, the cool-ing water in each loop transfers heat energy by convection. Convection is a method of heat transfer that can occur between two fluid media. It is the same process by which radiators are used to heat horn.es. The water circulating inside the radiator is separated from. the air (a "fluid" medium) by the metal piping.

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7 Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report The Turbine Generator The turbine, main generator, and the condenser are all housed in what is commonly referred to as the Turbine Building. The purpose of the turbine is to convert the thermal energy of the steam produced in the steam generator (referred to as main steam, red in Figure 7) to rotational energy of the turbine generator shaft. The turbine at Davis-Besse is actually composed of one six-stage high-pressure turbine and two seven-stage low-pressure turbines aligned on a common shaft. A turbine stage refers to a set of blades. Steam enters at the center of each turbine and moves outward along the shaft in opposite directions through each successive stage of blading.

As the steam passes over the turbine blades, it loses pressure. Thus, the blades must be propor-tionally larger in successive stages to extract enough energy from the steam to rotate the shaft at the correct speed.

The purpose of the main generator is to convert the rotational energy of the shaft to electrical energy for commercial usage and support of station systems. The main generator is composed of two parts, a stationary stator that contains coils of copper conductors, and a rotor that sup-plies a rotating magnetic field within the coils of the stator. Electrical current is generated in the stator portion of the main generator. From this point, the electric current passes through a series 9f transformers for transmission and use throughout northern Ohio.

The Condenser After the spent steam in the secondary loop (blue in Figure 7) passes through the High and Low Pressure Turbines, it is collected in the condenser, which is several stories tall and contains more than 70,000 small tubes. Circulating Water (yellow in Figure 7) goes to the Cooling Tower after passing through the tubes inside the Condenser. As the steam from the Low Pres-sure Turbines passes over these tubes, it is cooled and condensed. The condensed water is then purified and reheated before being circulated back into the steam generator again in a closed loop system. Circulating water forms the third (or tertiary) and final loop of cooling water used at the Davis-Besse Station.

Similar to the primary to secondary interface, the secondary-to-tertiary interface is based on a closed-loop design. The Circulating Water, which is pumped through the tubes in the Water Box, is able to cool the water in the Condenser by the processes of conduction and convection.

Even in the event of a primary-to-secondary leak, the water vapor exiting the Davis-Besse Cool-ing Tower would remain non-radioactive. Closed loops are an integral part of the design of any nuclear facility. This feature greatly reduces the chance of environmental impact from Station operation.

The Cooling Tower The Cooling Tower at Davis-Besse is easily the most noticeable feature of the plant. The tower stands 493 feet high and the diameter of the base is 411 feet. Two nine-foot diameter pipes circu-late 480,000 gallons of water per minute to the tower. Its purpose is to recycle water from the Condenser by cooling and returning it.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report After passing through the Condenser, the Circulating Water has warmed to approximately 100°F.

In order to cool the water back down to 70°F, the Circulating Water enters the Cooling Tower forty feet above the ground. It is then sprayed evenly over a series of baffles called fill sheets, which are suspended vertically in the base of the tower. A natural draft of air is swept upward through these baffles and cools the water by evaporation. The evaporated water exits the top of the Cooling Tower as water vapor.

As much as 10,000 gallons of water per minute are lost to the atmosphere through evaporation via the Cooling Tower. Even so, approximately 98 percent of the water drawn from Lake Erie for station operation can be recycled through the Cooling Tower for reuse. A small portion of the Circulating Water is discharged back to Lake Erie at essentially th~' same temperature it was withdrawn earlier. The slightly warmer water has no measureable adverse environmental impact on the area of lake surrounding the discharge point.

Miscellaneous Station Safety Systems The orange system in Figure 7 is part of the Emergency Core Cooling System (ECCS) housed in the Auxiliary Building of the station. The ECCS consists of three overlapping means of keeping the reactor core covered with water, in the unlikely event of a Loss-of-Coolant Accident (LOCA), thereby protecting the fuel cladding barrier against high-temperature failure. Depend-ing on the severity of the loss of pressure inside the Primary System, the ECCS will automatical-ly channel borated water into the Reactor by using High Pressure Injection Pumps, a Core Flood Tank, or Low Pressure Injection Pumps. Borated water can also be sprayed from the ceiling of the Containment Vessel to cool and condense any steam that escapes the Primary Sys-tem.

The violet system illustrated in Figure 7 is responsible for maintaining the Primary Coolant water in a liquid state. It accomplishes this by adjusting the pressure inside the Primary System. Heat-ers inside the Pressurizer tum water into steam. This steam takes up more space inside the Pressurizer, thereby increasing the overall pressure inside the Primary System. The Pressurizer is equipped with spray heads that shower cool water over the steam in the unit. In this case, the steam condenses and the overall pressure inside the Primary System drops. The Quench Tank is where excess steam is directed and condensed for storage.

The scarlet system in Figure 7 is part of the Auxiliary Feedwater System, a key safety system in event the main feedwater supply (blue in Figure 7) to the Steam Generator is lost. Following a reactor shutdown, the Auxiliary Feedwater System can supply water to the Steam Generators from the Condensate Storage Tanks. The Auxiliary Feedwater System is housed in the Tur-

.bine Building along with the Turbine, Main Generator, and the Condenser.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Reactor Safety and Summary Nuclear power plants are inherently safe, not only by the laws of physics, but by design. Nuclear power plants cannot explode like a bomb, because the concentration of fissionable material is far less than is necessary for such a nuclear explosion. Also, many safety features are equipped with several backup systems to ensure that any possible accident would be prevented from causing a serious health or safety threat to the public, or serious impact on the local environment. Davis-Besse, like all U.S. nuclear units, has many overlapping, or redundant safety features. If one sys-tem should fail, there are still back-up systems to assure the safe operation of the Station. During normal operation, the Reactor Control System regulates the power output by adjusting the posi-tion of the control rods. The Reactor can be automatically shut down by a separate Reactor Pro-tection -System, which causes all the control rod assemblies to be quickly and completely inserted into the Reactor core, stopping the chain reaction. To guard against the possibility of a Loss of Coolant Accident, the Emergency Core Cooling System is designed to pump reserve wa-ter into the reactor automatically if the reactor coolant pressure drops below a predetermined lev-el.

The Davis-Besse Nuclear Power Station was designed, constructed, and is operated to produce a reliable, safe, and environmentally sound source of electricity.

Radioactive Waste Many of the activities we depend on in our everyday lives produce radioactive waste by-products. Nuclear energy, industrial processes, and medical treatments are some of these activi-ties. These by-products are managed and disposed of under strict requirements set by the federal government. With the exception of used nuclear fuel assemblies, these by-products produced at commercial power plants are referred to as low level radioactive waste.

Low Level Radioactive Waste Low level radioactive waste consists of ordinary trash and other items that have become contam-inated with radioactive materials and can include plastic gloves and other protective clothing, machine parts and tools, medical and laboratory equipment, filters, resins, and general scrap.

The radioactive material in low level radioactive waste emits the same types of radiation as natu-rally-occurring radioactive materials. Most low level activity in radioactive waste decay to background levels within months or years. Nearly all activity diminishes to stable materials in less than 300 years.

Davis-Besse currently transports low-level radioactive waste to Tennessee for processing, after which it is shipped to Utah or Texas for disposal. Davis-Besse has the capacity to store low-level waste produced on site for several years in the Low Level Radioactive Waste Storage Facil-ity, should this facility close.

Davis-Besse added the Old Steam Generator Storage Facility (OSGSF) in 2011 to house the Re-actor Vessel Closure Head, Service Support Structure and Control Rod Drive mechanisms re-moved during the 17M outage. Two Steam Generators and two Reactor Coolant System Hot Leg piping sections were replaced during 18th Refueling Outage (18RFO) in 2014, and are also stored there. The reinforced concrete building is comprised of three sections, the largest of 19

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report which contains the old steam generators and hot legs. The old reactor vessel head is kept in an-other bay. The sections of the building are completely enclosed with concrete for shielding. The dose rates outside the walls of this section are at background levels. The third section is the ves-tibule, which provides access to the other two sections. Both the steam generator and reactor vessel head sections have floor drains that lead to a sump that can be monitored and sampled from the vestibule. Surveys are routinely performed by Radiation Protection personnel to moni-tor the dose rates and tritium.

High Level Nuclear Waste Like any industrial or scientific process, nuclear energy does produce waste. The most radioac-tive is defined as "high-level" waste (because it has high levels of radioactivity). Ninety-nine percent of high-level waste from nuclear plants is used nuclear fuel. The fuel undergoes certain changes during fission. Most of the fragments of fission, pieces that are left over after the atom is split, are radioactiv~. After a period of time, the fission fragments trapped in the fuel assem-blies reduce the efficiency of the chain reaction. The oldest fuel assemblies are removed from the reactor and replaced with fresh fuel at 24-month intervals.

High-level nuclear waste volumes are small. Davis-Besse produces about 30 tons of used fuel every 24 months. All the used fuel produced by all America's nuclear energy plants since the first plant started operating over 30 years ago would cover an area the size of a football field about five yards deep. All of America's nuclear plants combined produce less than 3,000 tons of used fuel each year. By contrast, the U.S. produces about 300,000,000 tons of chemical waste annually. Also, nuclear waste slowly loses its radioactivity, but some chemical waste remains hazardous indefinitely.

Davis-Besse presently stores much of its used fuel in steel-lined water-filled concrete vaults in-side the plant. The Department of Energy (DOE) is charged with constructing a permanent high-level waste repository for all of the nation's nuclear plants. By law, the Department of Energy was required to accept fuel from utilities by the end of 1998. Until the permanent DOE site is developed, nuclear plants will be responsible for the continued safe storage of high-level waste.

At Davis-Besse, the fuel pool reached its capacity in 1996. At the end of 1996, Davis-Besse be-gan the process of moving the older fuel assemblies that no longer require water cooling to air-cooled concrete shielded canisters. These will remain on site and inside the Protected Area until the Department of Energy facilities are ready to receive them. Dry fuel storage is already used in many countries, including Canada, and in the U.S. at multiple nuclear plants. Figure 8 illustrates the initial Dry Fuel Storage module arrangement (AREVA-TN HSM-80) at Davis-Besse. In 2001, work was performed to increase the storage capacity of the Spent Fuel Pool. The pool re-mains the same size, however, removing old storage racks and replacing them with new ones changed the configuration of storage.

After the Davis-Besse operating license was extended, additional storage capacity for used fuel became necessary. Dry fuel storage operations were resumed in 2017 using a similar, but more advanced module arrangement (AREVA-TN HSM-H) storage system. Four horizontal storage modules were added to the Independent Spent Fuel Storage Installation Pad in July of 201 7. An additional twelve modules (AREVA-TN EOS-HSM) were installed on the pad in the fall of 2019 in which eight were loaded with dry shielded cannisters.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure 8: Initial HSM-80 Dry Fuel Storage Module Arrangement 21

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Description of the Davis-Besse Site The Davis-Besse site is located in Carroll Township of Ottawa County, Ohio. It is on the south-western shore of Lake Erie, just north of the Toussaint River. The site lies north and east of Ohio State Route 2, approximately 10 miles northwest of Port Clinton, 7 miles north of Oak Harbor, and 25 miles east of Toledo, Ohio (Figure 9).

This section of Ohio is flat and marshy, with maximum elevations of only a few feet above the level of Lake Erie. The area originally consisted of swamp forest and marshland, rich in wildlife but unsuitable for settlement and farming. During the nineteenth century, the land was cleared and drained, and has been farmed successfully since. Today, the terrain consists of farmland with marshes extending in some places for up to two miles inland from the Sandusky Lake Shore Ridge.

Lake Erle ft

'I M~Lll ~

Figure 9: Davis-Besse is near Oak Harbor, Port Clinton, and the Ottawa National Wildlife Refuge.

The Davis-Besse site is mainly comprised of freshwater marsh land, with a small portion consist-ing of farmland. The marshes are part of a valuable ecological resource, providing a breeding ground for a variety of wildlife and a refuge for migratory birds. The site includes a tract known as Navarre Marsh, which was acquired from the U.S. Bureau of Sport Fisheries and Wildlife, Department of the Interior. In 1971, Toledo Edison purchased the 188-acre Toussaint River Marsh. The Toussaint River Marsh is contiguous with the 610-acre Navarre Marsh section of the Ottawa National Wildlife Refuge. The Navarre Marsh and Toussaint River Marsh are leased to the U.S. Fish and Wildlife Service, who manage it as part of the Ottawa National Wildlife Ref-uge.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report The immediate area near Davis-Besse is sparsely populated. The most recent Census was com-pleted in the year 2016 and listed the population of Ottawa County at 40,636. The incorporated communities nearest to Davis-Besse are:

• Port Clinton - 10 miles southeast, population 5,945

• Oak Harbor - 7 miles south, population 2,741

• Rocky Ridge - 7 miles west southwest, population 520

• Toledo (nearest major city) - 25 miles west, population 278,508 There are some residences along the lakeshore used mainly as summer homes. However, the major resort area of the county is farther east, around Port Clinton, Lakeside, and the Bass Is-lands.

The majority of non-marsh areas around the Davis-Besse site are used for farming. The major crops include soybeans, com, wheat, oats, hay, fruits and vegetables. Meat and dairy animals are not major sources of income in the area. The main industries within five miles of the site are lo-cated in Erie Industrial Park, about four miles southeast of the station.

Most of the remaining marshes in the area have been maintained by private hunting clubs, the U.S. Fish and Wildlife Service, and the Ohio Department of Natural Resources, Division of Wildlife. The State of Ohio Department of Natural Resources operates many wildlife and recrea-tional areas within 10 miles of the Station. These include Magee Marsh, Turtle Creek and Crane Creek Wildlife Research Station. Magee Marsh and Turtle Creek lie between three and six miles WNW of the Station. Magee Marsh is a wildlife preserve that allows public fishing, nature study, and a controlled hunting season. Turtle Creek is a wooded area at the southern end of Magee Marsh, which offers boating and fishing. Crane Creek is adjacent to Magee Marsh, and is a popular bird watching and hunting area. The Ottawa National Wildlife Refuge, which is oper-ated by the U.S. Fish and Wildlife Service, lies four to nine miles WNW of the Site, immediately west of Magee Marsh.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report References

1. "Basic Radiation Protection Criteria/' Report No. 39, National Council on Radiation Protec-tion and Measurement, Washington, D.C. (January 1971).

2. "Cesium-137 from the Environment to Man: Metabolism and Dose," Report No. 52, National Council on Radiation Protection and Measurements, Washington, D.C. (January 1977).

3. Deutch, R., "Nuclear Power, A Rational Approach," Fourth edition, GP Courseware, Inc.,

Columbia, MD. (1987).

4. Eisenbud, M., "Environmental Radioactivity," Academic Press, Inc., Orlando, FL. (1987).

5. "Environmental Radiation Measurements," Report No. 50, National Council on Radiation Protection and Measurements, Washington, D.C. (December 1976).

6. "Exposure of the Population in the United States and Canada from Natural Background Ra-diation," Report No. 94, National Council on Radiation Protection and Measurements, Wash-ington, D.C. (December 1987).

7. "Health Effects of Exposure to Low Levels of Ionizing Radiation: BEIR V," Committee on the Biological Effects oflonizing Radiations, Board on Radiation Effects Research Commis-sion on Life Sciences, National Research Council, National Academy Press, Washington, D.C. (1990).

8. Hendee, William R., and Doege, Theodore C., "Origin and Health Risks oflndoor Radon,"

Seminars in Nuclear Medicine, Vol. XVIII, No. 1, American Medical Association, Chicago, IL. (January 1987).

9. Hurley, P., "Living with Nuclear Radiation," University of Michigan Press, Ann Arbor, MI.

(1982).

10. "Indoor Air Quality Environmental Information Handbook: Radon," prepared for the United States Department of Energy, Assistant Secretary for Environment, Safety and Health, by Mueller Associated, Inc., Baltimore, MD. (January 1986).

11. Introduction to Davis-Besse Nuclear Power Station Plant Technology, July 1992, Rev. 4, Pg.2-9.

12. "Ionizing Radiation Exposure of the Population of the United States," Report No. 93, Na-tional Council on Radiation Protection and Measurements, Washington, D.C. (September 1987).

13. "Natural Background Radiation in the United State~," Report No. 45, National Council on Radiation Protection and Measurements, Washington, D.C. (November 1975).

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

14. "Nuclear Energy Emerges from 1980s Poised for New Growth," U.S. Council for Energy Awareness, Washington, D.C. (1989). *

15. "Nuclear Power: Answers to Your Questions," Edison Electric Institute, Washington, D.C.

(1987).

16. "Public Radiation Exposure from Nuclear Power Generation in the United States," Report No. 92, National Council on Radiation Protection and Measurement, Washington, D.C. (De-cember 1987).

17. "Radiation Protection Standards," Department of Environmental Sciences and Physiology and the Office of Continuing Education, Harvard School Of Public Health, Boston, MA. (Ju-ly 1989).

18. Radiological Environmental Monitoring Report for Three Mile Island Station," GPU Nuclear Corporation, Middletown, PA. (1985).

19. "Sources, Effects and Risk oflonizing Radiation," United Nations Scientific Committee on the Effects of Atomic Radiation, 1988 Report to the General Assembly, United Nations, New York (1988).

20. "Standards for Protection Against Radiation," Title 10, Part 20, Code of Federal Regulation, Washington, D.C. (1988}.

21. "Domestic Licensing of Production and Utilization Facilities," Title 10, Part 50, Code of Federal Regulations, Washington, D.C. (1988).

22. "Environmental Radiation Protection Stand~rd for Nuclear Power Operations," Title 40, Part 190, Code of Federal Regulations, Washington, D.C. (1988).

23. "Tritium in the Environment," Report No. 62, National Council on Radiation Protection and Measurement, Washington, D.C. (March 1979).

24. Site Environmental Report, Fernald Environmental Management Project, United States De-partment of Energy (June 1993).

25. "Exposure from the Uranium Series with Emphasis on Radon and its Daughters" Report No.

77, National Council on Radiation Protection and Measurements, Washington, D.C. (1984).

26. "Evaluation of Occupational and Environmental Exposures to Radon and Radon daughter in the United States," Report No. 78, National Council on Radiation Protection and Measure-ments, Washington, D.C: (1984).

27. Nuclear Energy Institute (NEI) website, www.nei.org.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Radiological Environmental Monitoring Program Introduction The Radiological Environmental Monitoring Program (REMP) was established at Davis-Besse for several reasons: to provide a supplementary check on the adequacy of containment and effluent controls, to assess the radiological impact of the Station's operation on the surrounding area, and to determine compliance with applicable radiation protection guides and standards. The REMP was established in 1972, five years before the Station became operational. This pre-operational surveillance program was established to describe and quantify the radioactivity, and its variability, in the area prior to the operation of Davis-Besse. After Davis-Besse became operational in 1977, the operational surveillance program continued to measure radiation and radioactivity in the surrounding areas.

A variety of environmental samples are collected as part of the REMP at Davis-Besse. The se-lection of sample types is based on the established critical pathways for the transfer of radionu-clides through the environment to humans. The selection of sampling locations is based on sample availability, local meteorological and hydrological characteristics, local population char-acteristics, and land usage in the area of interest. The selection of sampling frequencies for the -

various environmental media is based on the radionuclides of interest, their respective half-lives, and their effect in both biological and physical environments.

A description of the REMP at Davis-Besse is provided in the following section. In addition, a brief history of analytical results for each sample type collected since 1972, and a more detailed summary of the analyses performed during this reporting period is also provided.

Pre-operational Surveillance Program The federal government requires nuclear facilities to conduct radiological environmental moni-toring prior to constructing the facility. This pre-operational surveillance program is for the col-lection of data needed to identify critical pathways, including selection of radioisotope and sample media combinations for the surveillance conducted after facility operations begin. Ra-dio-chemical analyses performed on samples should include nuclides that are expected to be re-leased during normal facility operations, as well as typical fallout radionuclides and natural background radioactivity. All environmental media with a potential to be affected by facility operation, as well as those media directly in the critical pathways, should be sampled during the pre-operational phase of the environmental surveillance program.

The pre-operational surveillance design, including nuclide/media combinations, sampling fre-quencies and locations, collection techniques and radiochemical analyses performed, should be carefully considered and incorporated in the design of the operational surveillance program. In 26

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report this manner, data can be compared in a variety of ways (for example: from year to year, location to location, etc.) in order to detect any radiological impact the facility has on the surrounding en-vironment. Data collection during the pre-operational phase should be planned to provide a comprehensive database for evaluating any future changes in the environment surrounding the plant.

Davis-Besse began its pre-operational environmental surveillance program five years before the Station began producing power for commercial use in 1977. Data accumulated during that time provides an extensive database from which Station personnel are able to identify trends in the radiological characteristics of the local environment. The environmental surveillance program at Davis-Besse will continue after the Station has reached the end of its economic viability and de-commissioning has begun.

Operational Surveillance Program Objectives The operational phase of the environmental surveillance program at Davis-Besse was designed with the following objectives in mind:

• to fulfill the obligations of the radiological surveillance sections of the Sta-tion's Technical Specifications and Offsite Dose Calculation Manual

• to determine whether any significant increase in the concentration of radio-nuclides in critical pathways occurs

• to identify and evaluate the buildup, if any, of radionuclides in the local envi-ronment, or any changes in normal background radiation levels

• to verify the adequacy of Station controls for the release of radioactive mate-rials Quality Assurance An important part of the environmental monitoring program at Davis-Besse is the Quality Assurance (QA) Program, which is conducted in accordance with the guidelines specified in NRC Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs". The QA Program is designed to identify possible deficiencies in the REMP so that corrective actions can be initiated promptly. Davis-Besse's Quality Assurance program also provides confidence in the results of the REMP through:

• performing regular audits (investigations) of the REMP, including a careful examination of sample collection techniques and record keeping

• ** performing audits of contractor laboratories which analyze the environmental samples

• requiring analytical contractor laboratories to participate in the United States Environmental Protection Agency Cross Check Program

• requiring analytical contractor laboratories to split samples for separate analy-sis followed by a comparison of results 27

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

• splitting samples prior to analysis by independent laboratories, and then com-paring the results for agreement

• requiring analytical contractor laboratories to perform in-house spiked sample analyses Quality Assessment audits and inspections of the Davis-Besse REMP are performed by the FirstEnergy Nuclear Operating Company QA Department and the NRC. In addition, the Ohio Department of Health (ODH) also performs independent environmental monitoring in the vicini-ty of Davis-Besse. The types of samples collected, and list of sampling locations used by the ODH were incorporated in Davis-Besse's REMP, and the analytical results from their program can be compared to Davis-Besse's. This practice of comparing results from identical samples, which are collected and analyzed by different parties, provides a valuable tool to verify the quali-ty of the laboratories' analytical procedures and data generated.

In 1987, environmental sampling personnel at Davis-Besse incorporated their own QA program into the REMP. Duplicate samples, called quality control samples, were collected at several lo-cations. These duplicate samples were assigned different identification numbers than the num-bers assigned to the routine samples. This ensured that the analytical laboratory would not know the samples were identical. The laboratory results from analysis of the quality control samples and the routine samples could then be compared for agreement. Quality control sampling has been integrated into the program and has become an important part of the REMP since 1987.

Quality control sampling locations are changed frequently in order to duplicate as many sam-pling locations as possible, and to ensure the contractor laboratory has no way of correctly pair-ing a quality control sample with its routine sample counterpart.

Program Description The Radiological Environmental Monitoring Program (REMP) at Davis-Besse is conducted in accordance with Title 10, Code of Federal Regulations, Part 50; NRC Regulatory Guide 4.8; the Davis-Besse Nuclear Power Station Operating License, Sections 5.6.1 and 5.6.2 of Davis-Besse Technical Specifications, the Davis-Besse Offsite Dose Calculation Manual (ODCM) and Sta-tion Operating Procedures. Samples are collected weekly, monthly, quarterly, semiannually, or annually, depending upon the sample type and nature of the radionuclides of interest. Environ-mental samples collected by Davis-Besse personnel are divided into four general types:

• ,atmospheric -- including samples of airborne particulate and airborne radio iodine

• .terrestrial -- including samples of milk, groundwater, broad leaf vegetation

• aquatic -- including samples of treated and untreated surface water, fish, and shoreline sediments

• direct radiation -- measured by thermoluminescent dosimeters All environmental samples are labeled using a sampling code. Table 2 provides the sample codes and collection frequency for each sample type.

REMP samples are collected onsite and offsite up to 25 miles away from the Station. Sampling locations may be divided into two general categories: Indicator and Control. Indicator locations 28

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report are those which would be most likely to display the effects caused by the operation of Davis-Besse and are located within five miles of the station. Control locations are those which should be unaffected by Station operations and are more than five miles from the Station. Data from Indicator locations are compared with data from the Control locations. This comparison allows REMP personnel to take into account naturally-occurring background radiation or fallout from weapons testing in evaluating any radiological impact Davis-Besse has on the surrounding envi-ronment. Data from Indicator and Control locations are also compared with pre-operational data to determine whether significant variations or trends exist.

Since 1987 the REMP has been' reviewed and modified to develop a comprehensive sampling program adjusted to the current needs of the utility. Modifications have included additions of sampling locations above the minimum amount required in the ODCM and increasing the num-ber of analyses performed on each sample. In addition to adding new locations, duplicate or Quality Control (QC) sample collection is performed to verify the accuracy of the lab analyzing the environmental samples. The ODCM was revised in February 2019 (Revision 36) to incorpo-rate the Radiological Environmental Monitoring Program (REMP) Enhancement Program into the ODCM-required REMP Program. This effort improved compliance with the ODCM re-quirements and added several Indicator sampling locations. In addition, this transition eliminat-ed unnecessary sampling stations that did not provide beneficial results.

Approximately 1,200 samples were collected and over 1,500 analyses were performed during 2019. In addition, 10% of the sampling locations were quality control sampling locations. Table 3 shows the number of the sampling location and number collected for each type.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 2: Sample Codes and Collection Frequencies Sample Collection Sample Type Code Frequency .

Airborne Particulate AP Weekly Airborne Iodine AI Weekly Thermoluminescent TLD Quarterly Dosimeter Milk MIL Monthly (semi-monthly during grazing season - when applicable)

Groundwater WW Quarterly-Control Only (when available)

Broadleaf Vegetation BLV Monthly (when available)

Surface Water-Treated SWT Weekly Surface Water - swu Weekly Untreated Fish FIS Annually Shoreline Sediment SED Semiannually 30

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 3: Sample Collection Summary Sample Collection Number of Number of Number of Type Type 8 / Locations Samples Samples (Remarks) Frequencyb Collected Missed Atmospheric Airborne Particulates C/W 9 508 ll(c)

Airborne Radioiodine C/W 9 508 l l(c)

Terrestrial Milk (Jan.-Apr.) G/M (d) 1 4 0 Groundwater G/Q(e) 1 3(e) 0 Broadleaf Vegetation G/M 5 22 0 Aquatic Treated Comp/WM 2 104 0 Surface Water G/WM(f) 1 52 0 Untreated G/WM(f) 3 156 0 Surface Water Comp/WM 3 156 0 Fish (2 species) GIA 2 4 0 Shoreline Sediments G/SA 2 4 0 Direct Radiation Thermo luminescent C/Q(f) 64 256 0 Dosimeters (TLD)

(a) Type of Collection: C = Continuous; G = Grab; Comp= Composite (b) Frequency of Collection: WM= Weekly composite Monthly; W = Weekly, M = Monthly; Q = Quarterly when available; SA = Semiannually; A = Annually (c) Eleven samples were "missed" during 2019 due to loss of power from weather-related conditions or from pump failures. A trend Condition Report was generated in February 2019 to document the multiple equip-ment failures in 2018 and early 2019. As a result, all fifteen sample pumps were refurbished between March and October 2019 to improve reliability and performance. In each case that an air sample was missed, the re-quired number of samples specified in Offsite Dose Calculation Manual Table 6-1 was satisfied by other in-service and operating REMP Air Samplers.

(d) There are no milking animals within the vicinity(:::; 8 km) of the Davis-Besse Nuclear Power Station. Con-trol samples were collected from January through April and analyzed for baseline purposes in the event that an animal is introduced within 8 km from the station in the future.

(e) There are no ground water wells within the vicinity of the Davis-Besse Nuclear Power Station that are tapped for drinking or irrigation purposes. The community is served by the Carrol Township Water Plant. One Con-trol location was sampled for three of the four quarters for baseline purposes in the event that a new well is drilled and utilized in which the hydraulic gradient or recharge properties are suitable for contamination.

Since the Control Ground Water Well is not required by ODCM Table 6-1, the sample not collected in the second quarter (due to lack of access) is not considered as a missed sample.

(f) Includes quality control location. SWU and SWT QC included in weekly grab sample/composited monthly.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Sample Analysis When environmental samples are analyzed, several types of measurements may be performed to provide information about the radionuclides present. The major analyses that are performed on environmental samples collected for the Davis-Besse REMP include:

Gross beta analysis measures the total amount of beta emitting radioactive material present in a sample. Beta radiation may be released by many different radionuclides. Since beta decay gives a continuous energy spectrum rather than the discrete lines or "peaks" associated with gamma radiation, identification of specific beta emitting nuclides is much more difficult. Therefore, gross beta analysis only indicates whether the sample contains normal or abnormal concentra-tions of beta emitting radionuclides; it does not identify specific radionuclides. Gross beta anal-ysis merely acts as a tool to identify samples that may require further analysis.

Gamma spectral analysis provides more specific information than gross beta analysis. Gamma spectral analysis identifies each gamma emitting radionuclide present in the sample, and the amount of each nuclide present. Each radionuclide has a very specific "fingerprint" that allows for swift and accurate identification. For example, gamma spectral analysis can be used to iden-tify the presence and amount of Iodine-131 in a sample. Iodine-131 is a man-made radioactive isotope of Iodine that may be present in the environment as a result of fallout from nuclear weapons testing, routine medical uses in diagnostic tests, and routine releases from nuclear pow-er stations.

Tritium analysis indicates whether a sample contains the radionuclide tritium (H-3) and the amount present. As discussed in the Introduction section, tritium is an isotope of Hydrogen that emits low energy beta particles.

Strontium analysis identifies the presence and amount of Strontium-89 and Strontium-90 in a sample. These man-made radionuclides are found in the environment as a result of fallout from nuclear weapons testing. Strontium is usually incorporated into the pool of the biosphere. In other words, it accumulates in living organisms, where it is stored in the bone tissue. The princi-pal Strontium exposure pathway is via milk produced by cattle grazed on pastures exposed to deposition from airborne releases.

Gamma Doses measured by thermoluminescent dosimeters while in the field are determined by a special laboratory procedure. Table 4 provides a list of the analyses performed on environmen-tal samples collected for the Davis-Besse REMP.

Often samples will contain little radioactivity, and may be below the lower limit of detection for the particular type of analysis used. The lower limit of detection (LLD) is the smallest amount of sample activity that can be detected with a reasonable degree of confidence at a predetermined level. When a measurement of radioactivity is reported as less than LLD (<LLD), it means that the radioactivity is so low that it cannot be accurately measured with any degree of confidence by a particular method for an individual analysis.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 4: Radiochemical Analyses Performed on REMP Samples Sample Type Analyses Performed Atmospheric Monitoring Airborne Particulate Gross Beta Gamma Spectroscopy Strontium-89 Strontium-90 Airborne Radioiodine Iodine-131 Terrestrial Monitoring Milk (when available) Gamma Spectroscopy Iodine-131 Strontium-89 Strontium-90 Stable Calcium Stable Potassium Groundwater (when available) Gross Beta Gamma Spectroscopy Tritium Strontium-89 Strontium-90 Broadleaf Vegetation Gamma Spectroscopy Iodine-131 Strontium-89 Strontium-90 33

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 4: Radiochemical Analyses Performed on REMP Samples (continued)

Sample Type Analyses Performed Aquatic monitoring Untreated Surface Water Gross Beta Gamma Spectroscopy

• Tritium Strontium-89 Strontium-90 Treated Surface Water Gross Beta Gamma Spectroscopy Tritium Strontium-89 Strontium-90 Iodine-131 Fish Gross Beta Gamma Spectroscopy Shoreline Sediment Gamma Spectroscopy Direct Radiation Monitoring Thermoluminescent Dosimeters Gamma Dose Sample History Comparison The measurement of radioactive materia,ls present in the environment will depend on factors such as weather or variations in sample collection techniques or sample analysis. This is one reason why the results of sample analyses are compared with results from other locations and from earlier years. Generally, the results of sample analyses are compared with pre-operational and operational data. Additionally, the results of Indicator and Control locations are also com-pared. This allows REMP personnel to track and trend the radionuclides present in the environ-ment, to assess whether a buildup of radionuclides is occurring and to determine the effects, if any, the operation of Davis-Besse is having on the environment If any unusual activity is de-tected, it is investigated to determine whether it is attributable to the operation of Davis-Besse, or to some other source such as nuclear weapons testing.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Atmospheric Monitoring

• Airborne Particulates: No radioactive particulates have been detected as a result of Davis-Besse's operation. Only natural and fallout radioactivity from nuclear weapons testing and the 1986 nuclear accident at Chernobyl have been detected.

• Airborne Radioiodine: Radioactive Iodine-131 fallout was detected in 1976, 1977, and 1978 from nuclear weapons testing, and in 1986 (0.12 to 1.2 picocuries per cubic meter) from the nuclear accident at Chernobyl. Iodine-131 was detected at all ten air sample locations over a four-week period between March 22 and April 12, 2011 following the Fukushima Daiichi Nuclear Station disaster in Japan.

Terrestrial Monitoring:

• Groundwater: Tritium was not detected above the lower limit of detection dur-ing 2019 in any REMP groundwater Control samples.

• Milk: Iodine-131 from nuclear weapons testing fallout was detected in 1976 and 1977 at concentrations of 1.36 and 23.9 picocuries/liter respectively. In 1986, concentrations of 8.5 picocuries/liter were detected from the nuclear accident at Chernobyl. Iodine was not detected in REMP milk samples following the Fuku-shima Daiichi Nuclear Station disaster in 2011. Iodine-131 was not detected in any REMP Milk Control samples in 2019.

• Broadleaf Vegetation: Only naturally-occurring radioactive material and materi-al from nuclear weapons testing have been detected.

Aquatic Monitoring

• Surface Water (Treated and Untreated): Historically, tritium has been detected sporadically at low levels in treated and untreated surface water at both Control and Indicator locations. Very low concentrations of tritium were detected in six Untreated surface water sample during 2019. The sample results were all slightly above the 330 pCi/L detection level and were just a small fraction of the 20,000 pCi/L Environmental Protection Agency drinking water limit. Enhancement sam-pling at site discharge paths (upstream of the untreated surface water locations) during the same periods indicated no detectable tritium. Similarly, one Treated surface water sample during 2019 indicated a tritium concentration of 336 pCi/L.

All other treated and untreated surface water samples in 2019 were less than the 330 pCi/L low level of detection value.

• Fish: Only natural background radioactive material was detected.

• Shoreline Sediments: Only natural background radiation, material from nuclear testing and the 1986 nuclear accident at Chernobyl have been detected.

Direct Radiation Monitoring

• Thermoluminescent Dosimeters (TLDs): The quarterly and annual gamma TLD dose rates for the current reporting period were evaluated using the methodologies presented in ANSI/BPS N13.37-2014 (R2019), "Environmental Dosimetry - Criteria for System De-sign and Implementation," and U.S. Nuclear Regulatory Commission Regulatory Guide 4.13, Revision 2, "Environmental Dosimetry - Performance Specifications, Testing, and Data Analysis. Evaluation of quarterly TLDs resulted in determination of the Facility 35

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Related Dose (FRD - actual amount of dose detected in a monitoring period above back-ground attributed to the facility) for each measuring location. Davis-Besse sampling lo-cations includes two inner ring TLDs in each meteorological sector in the general area of the Unrestricted Area Boundary, as well as two TLDs in each outer ring sector (excluding those sectors that extend into Lake Erie) located 6 to 8 km from the station. Multiple TLDs are also placed in special interest areas (Sand Beach and Long Beach local com-munities, Oak Harbor, and Port Clinton). The evaluation of FRD at each TLD location determined that all quarterly and annual doses were considered."non-detectable". No in-crease above natural background radiation attributable to Davis-Besse was observed in 2019. .

2019 Program Anomalies There was one REMP sample anomaly noted in 2019. One Inner Ring TLD in the SSE Sector during the first quarter 2019 indicated a dose of 41. 7 mrem compared to the expectedI 10 to 11

• mrem recorded at the same location in the four quarters in 2018 and in the second through fourth quarters in 2019. The 41. 7 mrem reading was verified to be anomalous when compared to the other Inner Ring TLD also located in the SSE Sector which indicated the expected 10.6 mrem in the first quarter 2019. All four TLDs in adjacent Inner Ring sectors, as well as the two TLDs in the Outer Ring of the SSE Sector, indicated normal readings.

There were also several missed air samples (see Table 3) during 2019 due to weather-related events or to performance issues with the sample pumps. New REMP air sample pumps were placed into service in 2018. Multiple equipment problems were identified with the new pumps and resulted in several instances in 2018 and early 2019 in which an adequate volume of air sample was not collected. Corrective Actions were initiated in February 2019 to refurbish all 15 REMP Air Monitor Pumps. While the pumps were being rotated out of service for refurbish-ment, loss of power events and equipment failures of the un-refurbished units continued. Despite the multiple failure events, the minimum number of air samples required by the ODCM were al-ways collected for analysis. Additional air sampling locations are normally in service each week by the Davis-Besse program.

Abnormal Releases There were no abnormal liquid or gaseous releases occurring during 2019.

Atmospheric Monitoring Air Samples Environmental air sampling is conducted to d~tect any increase in the concentration of airborne radionuclides that may be inhaled by humans or serve as an external radiation source. Inhaled radionuclides may be absorbed from the lungs, gastrointestinal tract, or from the skin. Air sam-ples collected by the Davis-Besse REMP include airborne particulate and airborne radioiodine.

Samples are collected weekly with low .volume vacuum pumps, which draw a continuous sample through a glass fiber filter and charcoal cartridge at a rate of approximately one cubic foot per minute. Airborne particulate samples are collected on 47 mm diameter filters. Charcoal car-tridges are installed downstream of the particulate filters to sample for the airborne radioiodine.

36

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report The airborne samples are sent to an offsite contract laboratory for analysis. At the laboratory, the airborne particulate filters are stored for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before they are analyzed to allow for the decay of naturally occurring short-lived radionuclides. However, due to the short half-life of iodine 131 (approximately eight days), the airborne radio iodine cartridges are analyzed upon receipt by the contract laboratory.

Airborne Particulate Davis-Besse has nine continuous air samplers that monitor for air particulate and iodine. There are six Indicator locations including four around the site boundary (T-1 , T-2, T-3, and T-4), and one by the adjacent community of Sand Beach (T-7). There are locations in two nearest commu-nities of Oak Harbor (T-9) and Port Clinton (T-11). Control stations are set up in Toledo (T-12) and at Crane Creek (T-27). Gross beta analysis is performed on each of the weekly samples.

Each quarter, the filters from each location are combined (composite) and analyzed for gamma-emitting radionuclides, Strontium-89 and Strontium-90. Beta-emitting radionuclides were de-tected at an average concentration of 0.021 pCi/m3 at Unrestricted Area Boundary locations, 0.025 pCi/ m3 at Community locations, and 0.024 pCi/m3 at Control locations. Beryllium-7 was detected by the gamma spectroscopic analysis of the quarterly composites. Beryllium-7 is a nat-urally occurring radionuclide produced in the upper atmosphere by cosmic radiation. Potassium-40 was the only other gamma-emitting radionuclide that was detected (in three samples) at levels slightly above its LLDs and is also naturally occurring. Strontium-89 and Strontium-90 were not detected above their LLDs. These results show no adverse change in radioactivity in air samples attributable to the operation of the Davis-Besse Nuclear Power Station in 2019.

37

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report 2011AlrborneGro* Beta 0.045 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ,

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Month Figure 10: Concentrations of beta-emitting radionuclides in airborne particulate samples were nearly identical and trended together at Indicator, Control, and Community locations during 2019.

Airborne Iodine-131 Airborne Iodine-131 samples are collected at the same nine locations as the airborne particulate samples. Charcoal cartridges are placed downstream of the particulate filters. These cartridges are collected weekly, sealed in separate collection bags and sent to the laboratory for gamma analysis.

38

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 5: Air Monitoring Locations Sample Location Type of Number Location Location Description T-1 I Site boundary, 0.6 miles ENE of Station T-2 I Site boundary, 0.9 miles E of Station T-3 I Site boundary, 1.4 miles ESE of Station T-4 I Site boundary, 0.8 miles S of Station T-7 CM Sand Beach, main entrance, 0.9 miles NW of Station T-9 CM Oak Harbor Substation, 6.8 miles SW of Station T-11 CM Ottawa County Regional Water Intake Facility, 9.5 miles SE of Station T-12 CN Toledo Water Treatment Plant, 20.7 miles WNW of Station T-27 CN Magee Marsh Wildlife Area, 5 .3 miles WNW of Station I= Indicator CN = Control CM = Community 39

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Terrestrial Monitoring The collection and analysis of groundwater, milk, and broad leaf vegetation provides data to as-sess the buildup of radionuclides that may be ingested by humans. The data provides infor-mation on the deposition of radionuclides from the atmosphere.

Many radionuclides are present in the environment due to sources such as cosmic radiation and fallout from nuclear weapons testing. Some of the radionuclides present are:

• Tritium, present as a result of the interaction of cosmic radiation with the upper atmosphere and as a result of routine release from nuclear facilities

• Beryllium-7, present as a result of the interaction of cosmic radiation with the upper atmosphere

• Cesium-137, a manmade radionuclide which has been deposited in the environment, (for example, in surface soils) as a result of fallout from nu-clear weapons testing and routine releases from nuclear facilities

• Potassium-40, a naturally occurring radionuclide normally found throughout the environment (including in the human body)

• Fallout radionuclides from nuclear weapons testing, including Strontium-89, Strontium-90, Cesium-137, Cerium-141, Cerium-144, and Ruthenium-106. These radionuclides may also be released in minute amounts from nuclear facilities.

The radionuclides listed above are expected to be present in many of the environmental samples collected in the vicinity of the Davis-Besse Station. The contribution of radionuclides from the operation of Davis-Besse is assessed by comparing sample results with pre-operational data, op-erational data from previous years, Control location data, and the types and amounts of radioac-tivity normally released from the Station in liquid and gaseous effluents.

Milk Samples Milk sampling is a valuable tool in environmental surveillance because it provides a direct basis for assessing the buildup of radionuclides in the environment that may be ingested by humans.

Milk from animals is collected and analyzed if available because it is one of the few foods com-monly consumed soon after production. The milk pathway involves the deposition of radionu-clides from atmospheric releases onto forage consumed by cows. The radionuclides present in the forage-eating cow are incorporated into the milk, which is then consumed by humans.

When available, milk samples are collected at Indicator and Control locations once a month from November through April, and twice a month between May and October. When grazing animals are present, sampling is increased in the summer when the herds are normally outside on pasture and not consuming stored feed. In December of 1993, Indicator location T-8 was eliminated from the sampling program, and no other Indicator milk site has existed since that time. The Control location is sampled periodically to document additional baseline data. In the event dairy animals return to the area within five miles of the station, monthly sampling will resume to in-clude them as an Indicator site.

43

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Four 2019 milk Control samples were analyzed for Strontium-89, Strontium-90, Iodine-131, oth-er gamma-emitting radionuclides, stable Calcium and Potassium. Strontium-89 and Strontium-90 were not detected above their LLDs of 0. 7 pCi/1.

Iodine-131 was not detected in any of the milk sample above the LLD of 0.5 pCi/1. The concen-trations of Barium-140 and Cesium-137 were below their respective LLDs in all samples collect-ed.

Since the chemistries of Calcium and Strontium are similar, as are Potassium and Cesium, organ-isms tend to deposit Cesium radioisotopes in muscle tissue and Strontium radioisotopes in bones.

In order to detect the potential environmental accumulation of these radionuclides, the ratios of the Strontium radioactivity (pCi/1) to the concentration of Calcium (g/1), and the Cesium radioac-tivity (pCi/1) compared to the concentration of Potassium (g/1) were monitored in milk. These ratios are compared to standard values to determine if buildup is occurring. No statistically sig-nificant variations in the ratios were observed.

Table 6: Milk Control Location Sample Location Type of Number Location Location Description T-24 C Toft Dairy, Sandusky, 21.0 miles SE of Station C = Control Groundwater Samples Soil acts as a filter and an ion exchange medium for most radionuclides. However, tritium and other radionuclides such as Ruthenium- I 06 have a potential to seep through the soil and could reach groundwater. Davis-Besse does not discharge its liquid effluents directly to the ground.

The Offsite Dose Calculation Manual requires that groundwater samples shall be collected when the wells are tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination. There currently are not any wells near the station that are used for drinking or irrigation purposes or that are located in areas where the hy-draulic gradient or recharge properties are suitable for contamination. Groundwater wells locat-ed within the Unrestricted Area Boundary are monitored in accordance with the NEI 07-07 program (reference Table 20).

REMP personnel periodically sample the groundwater well that is closest to the station ( 5.3 miles) at Control sample location T-27, Magee Marsh Wildlife Area, to collect data for compari-son to the NEI 07-07 well data. The Control groundwater samples are analyzed for beta-emitting radionuclides, tritium, Strontium-89, Strontium-90 and gamma-emitting radionuclides.

During the fall of 1998, the Carroll Township Water Plant began operation and offered residents a reliable, inexpensive source of high-quality drinking water. This facility has replaced drinking 44

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report water wells near Davis-Besse, as verified by the Ottawa County Health Department, and the In-dicator groundwater sampling was discontinued for a year. Two beach wells were subsequently identified within five miles of the Station, however, none of them are operational today. Three Control samples were collected in 2019. The gross beta averaged 3.3 pCi/1. Due to the hydraulic gradient of the Davis-Besse site, groundwater flows back towards the Intake Structure. In addi-tion, the site NEI 07-07 groundwater well tritium results are a fraction of regulatory limits.

Therefore, REMP Groundwater samples and local community were not affected by the operation of the Davis-Besse Nuclear Power Station.

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45

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 7: Groundwater Monitoring Locations Sample Location Type of Number Location Location Description T-27A C Magee Marsh Wildlife Area. Not used for irriga-tion or consumption.

T-225 I Previous location at Long Beach and Park, 1.5 mi NW of Station. Non-functional in 2019 and no plans by owner to complete repairs. Does not meet the criteria of ODCM Indicator Sample.

T-226 I Previous location at Allen residence, 1.6 miles NW of Station - Discontinued location in 2017 due to no flow. No plans by owner to restore well. Does not meet the criteria of ODCM Indicator Sample.

C = Control I = Indicator Broadleaf Vegetation Samples Broadleaf vegetation also represents a direct pathway to humans. Broadleaf vegetation may be-come contaminated by deposition of airborne radioactivity (nuclear weapons fallout or airborne releases from nuclear facilities), or from irrigation water drawn from lake water which receives liquid effluents (hospitals, nuclear facilities, etc.). Radionuclides from the soil may be absorbed by the roots of the plants and become incorporated into the edible portions. During the growing season, edible broadleaf vegetation samples, such as kale and cabbage, are collected from gar-dens and farms in the vicinity of the Station and also from Control locations.

In 2019, broadleaf vegetation samples (cabbage and kale) were collected at three Indicator loca-tions (T-17, T-19, T-227) and two Control locations (T-30, T-37). Broadleafvegetation was col-lected once per month during the growing season. All samples were analyzed for gamma-emitting radionuclides, Strontium-89, Strontium-90, and Iodine-131.

Iodine-131 was not detected above the LLD of 0.042 pCi/g (wet) in any broadleaf samples. The only gamma-emitting radionuclide detected in the broadleaf vegetation samples was Potassium-40, which is naturally occurring. Results of broadleaf vegetation samples were similar to results observed in previous years. Strontium-89 and Strontium-90 were not detected in any sample above their respective LLDs (0.039 and 0.026 pCi/1 wet) in broadleaf vegetation samples at Con-trol and Indicator locations.

Operation of Davis-Besse had no observable adverse radiological effect on the surrounding envi-ronment in 2019.

46

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 8: BroadleafVegetation Locations Sample Location Type of Number Location Location Description T-17 I D. Thompson, 1.8 miles SSE of Station T-19 I L. Bowyer Jr., 1.0 mile W of Station T-30 C Bench Farms, 12.8 miles WNW of Station T-37 C Bench Farm, 13.0 miles SW of Station T-227 I B. Edge, 1.8 miles SSE of station I= Indicator, C = Control 47

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Aquatic Monitoring Radionuclides may be present in Lake Erie from many sources including atmospheric deposition, run-off/soil erosion, and releases of radioactive material in liquid effluents from hospitals or nu-clear facilities. These sources provide two forms of potential exposure to radiation, external and internal. External exposure can occur from the surface of the water, shoreline sediments and from immersion (swimming) in the water. Internal exposure can occur from ingestion of radio-nuclides, either directly from drinking water, or as a result of the transfer of radionuclides through the aquatic food chain with eventual consumption of aquatic organisms, such as fish. To monitor these pathways, Davis-Besse collects samples of treated surface water (drinking water),

untreated surface water (lake or river water), fish, and shoreline sediments.

Treated Surface Water Treated surface water is water from Lake Erie, which has been processed for human consump-tion. Radiochemical analysis of this processed water provides a direct basis for assessing the dose to humans from ingestion of drinking water.

Samples of treated surface water were collected from one Indicator (T-22B) and one Control lo-cations (T-11). These locations include the water treatment facilities for Carroll Township and Port Clinton. Samples were collected weekly and composited monthly. The monthly compo-sites were analyzed for beta-emitting radionuclides. The samples were also composited in a quarterly sample and analyzed for Strontium-89, Strontium-90, gamma-emitting radionuclides, and tritium. One Quality Control sample was collected each month from one of the two routine sites on an alternating location basis.

50

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report The annual average of beta-emitting radionuclides for Indicator and Control locations was 1.36 and 1.40 pCi/1, respectively. These results are similar to previous years. Tritium was detected (336 pCi/1) slightly above the LLD of330 pCi/1 during 2019 in one sample. Strontium-89 was not detected above the LLD of0.8 pCi/1. Strontium-90 activity was not detected above its LLD of 0.5 pCi/1. These results are similar to those of previous years and indicate no adverse impact on the environment resulting from the operation of Davis-Besse during 2019.

Each month, weekly quality control samples were collected at different locations. The results of the analyses from the quality control samples were within statistical agreement with the routine samples.

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51

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 9: Treated Surface Water Locations Sample Location Type of Number Location Location Description T-11 C Ottawa County Regional Water Intake Facility, 9.5 miles SE of Station T-22B I Carroll Township Water Treatment Plant, sampled at Davis-Besse REMP lab T-143 QC Quality Control Site I = Indicator C = Control QC= Quality Control 52

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Untreated Surface Water Sampling and analysis of untreated surface water provides a method of assessing the dose to hu-mans from external exposure from the lake surface as well as from immersion in the water. It also provides information on the radionuclides present, which may affect drinking water, fish, and irrigated crops.

Routine Program The routine program is the basic sampling program that is performed year-round. Untreated wa-ter samples are collected from water intakes used by nearby water treatment plants. Routine samples are collected at Port Clinton and Carroll Township. An additional Indicator sample is located at the mouth of the Toussaint River just prior to entering Lake Erie. These samples are collected weekly and composited monthly. The monthly composite is analyzed for beta-emitting radionuclides, tritium, and gamma-emitting radionuclides. The samples are also composited quarterly and analyzed for Strontium-89 and Strontium-90. One QC sample was collected each month from one of the three routine sites on an alternating location basis.

53

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Sample Results For the routine untreated surface water samples that are composited weekly, the beta emitting radionuclides had an average concentration of 1.87 pCi/L at Indicator locations during 2019.

Control locations averaged 1.34 pCi/L during this period.

A trace level of tritium was detected in six Indicator samples of Untreated Surface Water at loca-tions T-3 and T-22 in 2019. In each case, the tritium concentration was slightly above the limit of detection of 330 pCi/L and significantly below regulatory limits.

Each month, weekly composited quality control samples of untreated water were analyzed from different locations. The results of the analyses from the quality control samples were consistent with the routine samples and averaged 1.39 pCi/L for beta emitting radionuclides.

Oro11 Beta Concentration In Untreated Surface Water 1977-2019 12.0 . . . . - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

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ct Figure 18: The average concentration of beta-emitting radionuclides in Untreated Surface Water. The peaks seen in 2015 and 2016 were attributed to elevated potassium from fertilizer runoff into the Portage River.

54

Davis-Besse Nuclear Power Station 20 I 9 Annual Radiological Environmental Operating Report Table 10: Untreated Surface Water Locations Sample Location Type of Number Location Location Description T-3 I Site boundary, 1.4 miles ESE of Station T-11 C Ottawa County Regional Water Treatment Plant, 9.5 miles SE of Station T-22A I Carroll Township Water Plant, State Route 2, 2.1 miles NW of Station T-145 QC Roving Quality control Site I= Indicator, C = Control 55

i I Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Shoreline Sediment The sampling of shoreline sediments can provide an indication of the accumulation of insoluble radionuclides which could lead to internal exposure to humans through the ingestion of fish, through re-suspension into drinking water supplies, or as an external radiation source from shore-line exposure to fishermen and swimmers.

Samples of deposited sediments in water along the shore were collected at Indicator site T-3 and Control location T-11. Samples were analyzed for gamma-emitting radionuclides. Naturally occurring Potassium-40 was detected at both Control and Indicator locations. No other gamma-emitting isotopes were detected. These results are similar to previous years.

Table 11: Shoreline Sediment Locations Sample Location Type of Number Location Location Description T-3 I Site boundary, 1.4 miles ESE of Station T-11 C Ottawa County Regional Water Intake Facility, 9.5 miles SE of Station I= Indicator C = Control 56

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Fish Fish are analyzed primarily to quantify the dietary radionuclide intake by humans, and secondari-ly to serve as indicators of radioactivity in the aquatic ecosystem. The principal nuclide that may be detected in fish is naturally occurring Potassium-40.

Davis-Besse collected two species of fish from sampling locations near the Station's liquid dis-charge point and more than ten miles away from the Station where fish populations would not be expected to be impacted by the Station operation. Walleye are collected because of being a pop-ular recreational fish and white perch and white bass are collected because their importance as a commercial fish.

The average concentrations of beta-emitting radionuclides in ODCM-required fish were similar for Indicator and Control locations (3.42 pCi/g and 4.09 pCi/g wet weight, respectively). No gamma emitters were detected above their respective LLDs.

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57

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 12: Fish Locations Sample Location Type of Number Location Location Description T-33 I Lake Erie, within 5 miles radius of Station T-35 C Lake Erie, greater than 10 mile radius of Station I = Indicator C= Control 58

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Direct Radiation Monitoring Thermoluminescent Dosimeters Radionuclides present in the air and deposited on the ground may directly irradiate individuals.

Direct radiation levels at and around Davis-Besse are constantly monitored by thermo-luminescent dosimeters (TLDs). TLDs are small devices which store radiation dose information.

The TLDs used at Davis-Besse contain a Sulfate:Dysprosium (CaSO4:Dy) card with four main readout areas. Multiple readout areas are used to ensure the precision of the measurements.

Thermoluminescence is a process in which ionizing radiation interacts with phosphor, which is the sensitive material in the TLD. Energy is trapped in the TLD material and can be stored for several months or years. This provides an excellent method to measure the dose received over long periods of time. The energy that was stored in the TLD as a result of interaction with radia-tion is released and measured by a controlled heating process in a calibrated reading system. As the TLD is heated, the phosphor releases the stored energy in the form of light. The amount of light detected is directly proportional to the amount of radiation to which the TLD was exposed.

The reading process re-zeroes the TLD and prepares it for reuse.

TLD Collection Davis-Besse has 64 TLD locations (48 Indicator, 10 Control, and 6 Quality Control). TLDs are collected and replaced on a quarterly basis. All ODCM TLDs placed in the field were retrieved and evaluated during the current reporting period.

In 2019, the average dose equivalent for quarterly TLDs at Indicator locations was 15.1 mrem/91 days, and for Control locations was 15.5 mrem/91 days. Evaluation of quarterly TLDs resulted in determination of the Facility Related Dose (FRD - actual amount of dose de-tected in a monitoring period above background attributed to the facility) for each measuring lo-cation. Davis-Besse Indicator sampling locations includes two inner ring TLDs in each meteorological sector in the general area of the Unrestricted Area Boundary, as well as two TLDs in each outer ring sector (excluding those sectors that extend into Lake Erie) located 6 to 8 km from the station. Control TLDs are also placed in special interest areas (Sand Beach and Long Beach local communities, Oak Harbor, and Port Clinton). The evaluation of FRD at each TLD location determined that all quarterly and annual doses in 2019 were considered as "non-detectable". No increase above natural background radiation attributable to the operation of Da-vis-Besse was observed in 2019.

Quality Control TLDs Duplicate TLDs have been placed at five sites. These TLDs are placed in the field at the same time and location as some of the routine TLDs, but are assigned quality control site numbers.

This allows for multiple measurements at the location without the laboratory being aware that they are the same. A comparison of the quality control and routine results provides a method to check the accuracy of the measurements. The dose equivalent of Indicator quality control TLDs averaged 12.l mrem/91 days while the quality control TLDs at Control locations yielded an av-erage dose equivalent of 12.4 mrem/91 days.

62

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Direct Radiation Monitoring Gamma Dose for Environmental TLD* 1973-2019 24 I -+- Indicator - Controll 22 20 18 g,.

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Figure 23: The similarity between Indicator and Control results demonstrates that the operation of Davis-Besse has not caused any abnormal gamma dose. Facility Related Dose for all Indicator and Control TLDs was non-detectable.

63

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 13: Thermoluminescent Dosimeter Locations Sample Location Type of Number Location Location Description T-1 I Site boundary, 0.6 miles ENE of Station T-2 I Site boundary, 0.9 miles E of Station T-3 I Site boundary, 1.4 miles ESE of Station T-4 I Site boundary, 0.8 miles S of Station T-5 I Site boundary, 0.5 miles W of Station T-6 I Site boundary, 0.5 miles NNE of Station T-7 C Sand Beach entrance, 0.9 miles NW of Station T-9 C Oak Harbor Substation, 6.8 miles SW of Station T-10 I Site boundary, 0.5 miles SSW of Station near Warehouse T-11 C Ottawa County Regional Water Treatment Plant, 9.5 miles SE of Station T-12 C Toledo Water Treatment Plant, 20.7 miles WNW of Station T-24 C Sandusky, 21.0 miles SE of Station T-27 C Magee Marsh, 5.3 miles WNW of Station T-38 I Site boundary, 0.6 miles ENE of Station T-40 I Site boundary, 1.1 miles SE of Station T-41 I Site boundary, 0.8 miles SSE of Station T-42 I Site boundary, 0.6 miles SW of Station T-43 I Site boundary, 0.5 miles SW of Station T-44 I Site boundary, 0.5 miles WSW of Station T-45 I Site boundary, 0.5 miles WNW of Station 64

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 13: Thermo luminescent Dosimeter Locations (continued)

Sample Location Type of Number Location Location Description T-46 I Site boundary, 0.5 miles NW of Station T-47 I Site boundary, 0.5 miles N of Station T-48 I Site boundary, 0.5 miles NE of Station T-49 I Site boundary, 0.5 miles NE of Station T-51 I Utility Pole, 4.2 miles SSE of Station T-52 I Utility Pole, 4.2 miles S of Station T-54 I Utility Pole, 4.2 miles SW of Station T-55 I Utility Pole, 4.0 miles W of Station T-60 I Site boundary, 0.7 miles S of Station T-62 I Site boundary, 1.0 mile SE of Station T-67 I Site boundary, 0.4 miles NNW of Station T-68 I Site boundary, 0.5 miles WNW of Station T-69 I Site boundary, 0.4 miles W of Station T-71 I Site boundary, 0.5 mile NNW of Station T-73 I Site boundary, 0.5 mile WSW of Station T-74 I Site boundary, 0.5 mile SSW of Station T-80 QC Quality Control Site T-83 QC Quality Control Site T-84 QC Quality Control Site T-87 QC Quality Control in lead pig DBAB Annex 65

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 13: Thermo luminescent Dosimeter Locations (continued)

Sample Location Type of Number Location Location Description T-100 C Ottawa County Highway Garage, Oak Harbor, 6.0 miles S of Station T-113 QC Quality Control Site T-124 C Lake Street, Ottawa Co. Agricultural Complex 6.0 miles SSW of Station T-125 I Behlman and Bier Roads, 4.4 miles SSW of Station T-126 I Utility pole, 4.4 miles S of Station T-127 I Camp Perry Western and Rymers Road, 4.0 miles SSE of Station T-128 I Erie Industrial Park, Port Clinton Road, 4.0 miles SE of Station T-142 I Site Boundary, 0.8 miles SSE of Station T-150 C Humphrey and Hollywood Roads, 2.1 miles NW of Station T-154 I Utility Pole, 4.0 miles SW of Station T-155 C Fourth and Madison Streets, Port Clinton, 9.5 miles SE of Station T-200 QC Quality Control Site T-201 C Sand Beach, 1.1 miles NNW of Station T-203 I Sand Beach/Site Boundary, 0. 7 miles N of Station T-206 I Site Boundary, 0.6 miles NW of Station 66

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 13: Thermo luminescent Dosimeter Locations (continued)

Sample Location Type of Number Location Location Description T-208 I Site Boundary, 0.5 miles NNE of Station T-211 I Site boundary, 0.8 miles E of Station T-212 I Site boundary, 1.2 miles ESE of Station T-217 I Utility Pole, 4.2 miles SSW of Station T-218 I Toussaint East Rd., 4.0 miles WSW of Station T-219 I Toussaint Portage Rd., 4.8 miles WSW of Station T-220 I Duff-Washa Rd., 4.6 miles W of Station T-221 I Magee Marsh, 5.0 miles WNW of Station T-222 I Turtle Creek Access, 3.8 miles WNW of Station T-224 I Erie Industrial Park, 4.4 miles SE of Station I = Indicator C = Control QC = Quality Control 67

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Conclusion The Radiological Environmental Monitoring Program at Davis-Besse is conducted to determine the radiological impact, if any, of the Station's operation on the environment. Radionuclide con-centrations measured at Indicator locations were compared with concentrations measured at Con-trol locations in previous operational studies and in the pre-operational surveillance program.

These comparisons indicate normal concentrations of radioactivity in all environmental samples collected in 2019. Davis-Besse's operation in 2019 indicated no adverse radiological impact on the residents and environment surrounding the station. The results of the sample analyses per-formed during the period of January through December 2019 are summarized in Appendix C of this report.

References

1. "Cesium.-137 from the Environment to Man: Metabolism and Dose," Report No. 52, National Council on Radiation Protection and Measurement, Washington, D.C. (January 1977).

2. "Environmental Radiation Measurements," Report No. 50, National Council on Radiation Protection and Measurement, Washington, D.C. (December 1976).

3. "Exposure of the Population in the United States and Canada from Natural Background Ra-diation," Report No. 94, National Council on Radiation Protection and Measurement, Wash-ington, D.C. (December 1987).

4. "A Guide for Environmental Radiological Surveillance at U.S. Department of Energy Instal-lations," DOE/EP-0023, Department of Energy, Washington, D.C. (July 1981).

5. "Ionizing Radiation Exposure of the Population of the United States," Report No. 93, Na-tional Council on Radiation Protection and Measurement, Washington, D.C. (September 1987).

6. "Natural Background Radiation in the United States," Report No. 45, National Council on Radiation Protection and Measurement, Washington, D.C. (November 1975).

7. "Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion 'As Low As Reasonably Achievable' for Radioactive Material in Light Water Cooled Nuclear Power Reactor Effluents," Code of Federal Regulations, Title 10 Energy, Part 50 "Domestic Licensfog of Production and Utilization Facilities," Appendix I (1988).

8. "Performance, Testing and Procedural Specifications for Thermolum.inescent Dosimetry,"

American National Standards Institute, Inc., ANSI-N45-1975, New York, New York (1975).

9. "Public Radiation Exposure from Nuclear Power Generation in the United States," Report No. 92, National Council on Radiation Protection and Measurement, Washington, D.C. (De-cember 1987).

71

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

10. "Radiological Assessment: Predicting the Transport, Bioaccumulation and Uptake by Man of Radionuclides Released to the Environment," Report No. 76, National Council on Radiation Protection and Measurement, Washington, D.C. (March 1984).

11. Regulatory Guide 4.1, "Programs for Monitoring Radioactivity in the Environs ofNuclear Power Plants," US NRC (April 1975). *

12. Regulatory Guide 4.13, Revision 2, "Environmental Dosimetry-Performance Specifica-tions, Testing, and Data Analysis," US NRC (June 2019).

13. Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," US NRC (February 1979).

14. NUREG-0475, "Radiological Environmental Monitoring by NRC Licensees for Routine Op-erations of Nuclear Facilities," US NRC (September 1978).

15. "Standards for Protection Against Radiation," Code of Federal Regulations, Title 10, Energy, Part 20 (1993).

16. Teledyne Isotopes Midwest Laboratory, "Operational Radiological Monitoring for the Davis-Besse Nuclear Power Station Unit No.1, Oak Harbor, OH," Annual Report, Parts I and II (1977 through 1990).

17. Teledyne Isotopes Midwest Laboratory, "Final Monthly Progress Report to Toledo Edison Company," (1991-1999).

18. Environmental, Inc. Midwest Laboratory, "Final Report to FirstEnergy Corporation," (2000-2019)

19. Teledyne Isotopes Midwest Laboratory, "Pre-operational Environmental Radiological Moni-toring for the Davis-Besse Power Station Unit No. 1," Oak Harbor, OH (1972-1977).

20. Toledo Edison Company, "Davis-Besse: Nuclear Energy for Northern Ohio."

21. Toledo Edison Company, Davis-Besse Nuclear Power Station, Unit No. 1, Radiological Ef-fluent Technical Specifications", Volume 1, Appendix A to License No. NPF-3. (Note - re-located to Offsite Dose Calculation Manual (ODCM) and Process Control Program (PCP),

Amendment 170, dated 3/9/92).

22. Toledo Edison Company, "Final Environmental Statement-Related to the Construction of Davis-Besse Nuclear Power Station," Docket #50-346 (1987).

23. Toledo Edison Company, "Performance Specifications for Radiological Environmental Mon-itoring Program," S-72N.

24. Davis-Besse Nuclear Power Station, "Radiological Environmental Monitoring Program,"

DB-CN-00015.

72

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

25. Davis-Besse Nuclear Power Station, "Radiological Environmental Monitoring Quarterly, Semiannual, and Annual Sampling", DB-CN-03004.

26. Davis-Besse Nuclear Power Station, "Radiological Monitoring Weekly, Semimonthly, and Monthly Sampling," DB-CN-03005. .

27. ANSI/RPS NB.37-2014 (R2019), "Environmental Dosimetry-Criteria for System Design and Implementation," American National Standard (May 2019).

28. Toledo Edison Company, "Updated Safety Analysis for the Offsite Radiological Monitoring Program," USAR 11.6, Revision 14, (1992).

29. Davis-Besse Nuclear Power Station, "Annual Radiological Environmental Operating Report Preparation and Submittal," DB-CN-00014.

30. Davis-Besse Nuclear Power Station, "Preparation of Radioactive Effluent Release Report,"

DB-CN-00012.

31. Davis-Besse Nuclear Power Station, "Offsite Dose Calculation Manual."

32. "Tritium in the Environment," Report No. 62, National Council on Radiation Protection and Measurements, Washington, D.C. (March 1979).

33. NEI 07-07, "Industry Ground Water Protection Initiative -Final Guidance Document,"

Revision 1 (March 2019).

34. "Groundwater Monitoring Well Installation & Monitoring Report Davis-Besse Nuclear Pow-er Station Oak Harbor, Ohio," Environmental Resources Management, March 18, 2008.

73

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Radioactive Effluent Release Report January 1 through December 31, 2019 Protection Standards Soon after the discovery ofx-rays in 1895 by Wilhelm Roentgen, the potential hazards of ionizing radiation were recognized, and efforts were made to establish radiation protection standards. The primary source of recommendations for radiation protection standards within the United States is the National Council on Radiation Protection and Measurement (NCRP). Many of these recom-mendations have been given legislative authority by being published in the Code of Federal Reg-ulations by the Nuclear Regulatory Commission.

The main objective in the control of radiation is to ensure that any dose is kept not only within regulatory limits, but kept as low as reasonably achievable (ALARA). The ALARA principle applies to reducing radiation dose both to the individual working at Davis-Besse and to the general public. "Reasonably achievable" means that exposure reduction is based on sound economic de-cisions and operating practices. By practicing ALARA, Davis-Besse minimizes health risk and environmental detriment and ensures that doses are maintained well below regulatory limits.

Sources of Radioactivity Released During the normal operation of a nuclear power station, most of the fission products are retained within the fuel and fuel cladding. However, small amounts of radioactive fission products and trace amounts of the component and structure surfaces, which have been activated, are present in the primary coolant water. The three types of radioactive material released are noble gases, Iodine and particulates, and tritium.

The noble gas fission products in the primary coolant are given off as a gas when the coolant is depressurized. These gases are then collected by a system designed for gas collection and stored for radioactive decay prior to release.

Small releases of radioactivity in liquids may occur from valves, piping or equipment associated with the primary coolant system. These liquids are collected through a series of floor and equip-ment drains and sumps. All liquids of this nature are monitored and processed, if necessary, prior to release.

Noble Gas Some of the fission products released in airborne effluents are radioactive isotopes of noble gases, such as Xenon (Xe) and Krypton (Kr). Noble gases are biologically and chemically inert. They do not concentrate in humans or other organisms. They contribute to human radiation dose by being an external source ofradiation exposure to the body. Xe-133 and Xe-135, with half-lives of approximately five days and nine hours, respectively, are the major radioactive noble gases re-leased. They are readily dispersed in the atmosphere.

74

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Iodine and Particulates Annual releases of radioisotopes of Iodine, and those particulates with half-lives greater than 8 days, in gaseous and liquid effluents are small. Factors such as their high chemical reactivity and solubility in water, combined with the high efficiency of gaseous and liquid processing sys-tems, minimize their discharge. The predominant radioiodine released is Iodine-131 with a half-life of approximately eight days. The main contribution of radioactive Iodine to human dose is to the thyroid gland, where the body concentrates Iodine.

The principal radioactive particulates released are fission products (e.g., Cesium-134 and Cesium-137) and activation products (e.g., Cobalt-58 and Cobalt-60). Radioactive Cesium and Cobalt contribute to internal radiation exposure of tissues such as muscle, liver, and the intestines. These particulates are also a source of external radiation exposure if deposited on the ground.

Tritium Tritium, a radioactive isotope of Hydrogen, is the predominant radionuclide in liquid effluents. It is also present in gaseous effluents. Tritium is produced in the reactor coolant as a result of neutron interaction with deuterium (also a Hydrogen isotope) present in the water and with the Boron in the primary coolant. When tritium, in the form of water or water vapor, is ingested or inhaled it is dispersed throughout the body until eliminated.

Carbon-14 Carbon-14 (C-14) is a naturally occurring isotope of carbon produced in the atmosphere by cosmic rays. Its concentration in the environment was significantly increased by nuclear weapons testing in the 1950s and 1960s. It is also produced in nuclear power production in much lesser amounts.

C-14 is a pure beta emitter and generates no dose from direct radiation. Its predominant exposure pathway is through ingestion of produce which has incorporated C-14 into plant matter via the chemical form of CO2 during photosynthesis.

Processing and Monitoring Effluents are strictly controlled to ensure radioactivity released to the environment is minimal and does not exceed regulatory limits. Effluent control includes the operation of monitoring systems, in-plant and environmental sampling and analysis programs, quality assurance programs for efflu-ent and environmental programs, and procedures covering all aspects of effluent and environmen-tal monitoring.

The radioactive waste treatment systems at Davis-Besse are designed to collect and process the liquid and gaseous wastes that contain radioactivity. For example, the Waste Gas Decay Tanks allow radioactivity in gases to decay prior to release via the Station Vent.

Radioactivity monitoring systems are used to ensure that all releases are below regulatory limits.

These instruments provide a continuous indication of the radioactivity present. Each instrument is equipped with alarms and indicators in the control room. The alarm setpoints are low enough 75

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report to ensure the limits will not be exceeded. If a monitor alarms, a release from a tank is automatically stopped.

All wastes are sampled prior to release and analyzed to identify the specific concentrations of radionuclides. Sampling and analysis provides a more sensitive and precise method of determining effluent composition than can be accomplished with monitoring instruments.

A meteorological tower is located in the southwest sector of the Station which is linked to com-puters that record its data. Coupled with the effluent release data, the meteorological data are used to calculate the dose to the public. Beyond the plant, devices maintained in conjunction with the Radiological Environmental Monitoring Program continuously sample the air in the sur-rounding environment. Frequent samples of other environmental media, such as water and vege-tation, are taken to determine if buildup of deposited radioactive material has occurred in the area.

Exposure Pathways Radiological exposure pathways defme the methods by which people may become exposed to radioactive material. The major pathways of concern are those which could cause the highest calculated radiation dose. These projected pathways are determined from the type and amount of radioactive material released, the environmental transport mechanism, and the use of the environ-ment. The environmental transport mechanism includes consideration of physical factors, such as the hydrological (water) and meteorological (weather) characteristics of the area. An annual aver-age of the water flow, wind speed, and wind direction are used to evaluate how the radionuclides will be distributed in an area for gaseous or liquid releases. An important factor in evaluating the exposure pathways is the use of the environment. Many factors are considered such as dietary intake of residents, recreational use of the area, and the locations of homes and farms in the area.

The external and internal exposure pathways considered are shown in Figure 27. The release of radioactive gaseous effluents involves pathways such as external whole body exposure, deposition of radioactive material on plants, deposition on soil, inhalation by animals destined for human consumption, and inhalation by humans. The release of radioactive material in liquid effluents involves pathways such as drinking water, fish, and direct exposure from the lake at the shoreline while swimming.

76

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report 0c:::::)

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Consumed By Animals II Figure 27: The exposure pathways shown here are monitored through the Radiological Environmental Monitoring Program (REMP) and are considered when calculating doses to the public.

Although radionuclides can reach humans by many different pathways, some result in more dose than others. The critical pathway is the exposure route that will provide, for a specific radionu-clide, the greatest dose to a population, or to a specific group of the population called the critical group. The critical group may vary depending on the radionuclides involved, the age and diet of the group, or other cultural factors. The dose may be delivered to the whole body or to a specific organ. The organ receiving the greatest fraction of the dose is called the critical organ.

Dose Assessment Dose is the energy deposited by radiation in an exposed individual. Whole body exposure to ra-diation involves the exposure of all organs. Most background exposures are of this form. Both radioactive and non-radioactive elements can enter the body through inhalation or ingestion.

When they do, they are usually not evenly distributed. For example, Iodine concentrates in the thyroid gland, Cesium collects in muscle and liver tissue, and Strontium collects in the bone.

The total dose to organs from a given radionuclide depends on the amount of radioactive material present in the organ and the length of time that the radionuclide remains there. Some radionuclides remain for short times due to their rapid radioactive decay and/or elimination rate from the body.

Other radionuclides may remain in the body for longer periods of time.

77

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report The dose to the general public in the area surrounding Davis-Besse is calculated for each liquid or gaseous release. The dose due to radioactive material released in gaseous effluents is calculated using factors such as the amount of radioactive material released, the concentration beyond the site boundary, the average weather conditions at the time of the release, the locations of exposure path-ways (cow milk, goat milk, vegetable gardens and residences), and usage factors (inhalation, food consumption). The dose due to radioactive material released in liquid effluents is calculated by using factors such as the total volume of the liquid released, the total volume of dilution water (near field dilution), and usage factors, such as water and fish consumption, and shoreline and swimming factors. These calculations produce a conservative estimation of the dose.

Results The Radioactive Effluent Release Report is a detailed listing of radioactivity released from the Davis-Besse Nuclear Power Station during the period from January 1 through December 31, 2019.

• Summation of the quantities of radioactive material relea,sed in gaseous and liquid efflu-ents (Tables 14-18)

• Summation of the quantities of radioactive material contained in solid waste packaged and shipped for offsite disposal at federally approved sites (Table 19)

During this reporting period, the maximum individual offsite dose due to radioactivity released in effluents was:

Liquid Effluents:

• 4.73E-03 mrem, maximum individual whole body dose

• 5.16E-03 mrem, maximum individual significant organ dose (Liver)

Gaseous Effluents:

Noble Gas:

• 0.00E+00 mrem, whole body

• 0.00E+00 mrad, skin Iodine - 131, Tritium, and Particulates with Half-Lives greater than 8 Days:

• 2.0lE-02 mrem, whole body dose

• 2.0lE-02 mrem, significant organ dose (Liver)

Carbon-14:

• l.3 lE-01 mrem, whole body

• 6.45E-0 1 mrem, significant organ dose (Bone)

These doses are a small fraction of the limits set by the NRC in the Davis-Besse ODCM. Addi-tional normal release pathways from the secondary system exist. For gaseous effluents, these pathways include the Auxiliary Feed Pump Turbines exhaust, the main steam safety valve system and the atmospheric vent valve system, steam packing exhaust and main feed water. For liquid effluents, the additional pathways include the Turbine Building drains via the settling basins. Re-leases via these pathways are included in the normal release tables in this report.

78

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Regulatory Limits Gaseous Effluents In accordance with Offsite Dose Calculation Manual, dose rates due to radioactivity released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to the fo~~: '

Noble gases:

• Released at a rate equal to or less than 500 mrem TEDE per year.

• Released at a rate such that the total dose to the skin will be less than or equal to 3000 mrem per year.

Iodine-131, tritium, and all radionuclides in particulate form with half-lives greater than 8 days:

• Released at a rate such that the total dose to any organ will be less than or equal to 1500 mrem per year.

In accordance with 10CFR50, Appendix I, Sec. IIB. 1, air dose due to radioactivity released in gaseous effluents to areas at and beyond the site boundary shall be limited to the following:

• Less than or equal to 10 mrad ,total for gamma radiation and less than or equal to 20 mrad total for beta radiation in any calendar year.

In accordance with 10CFR50, Appendix I, Sec. IIC, dose to a member of the public from Iodine-131, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released to areas at and beyond the site boundary shall be limited to the following:

• Less than or equal to 15 total mrem to any organ in any calendar year.

Carbon-14 Carbon-14 (C-14) is calculated based on plant power production. The C-14 doses are based on a calculated value of 3.18 Ci of C-14 in the form of CO2 released from Davis-Besse through the Station Vent during 2019.

Liquid Effluents In accordance with 10CFR50, Appendix I, Sec IIA, the dose or dose commitment to a member of the public from radioactivity in liquid effluents released to unrestricted areas shall be limited to accumulated doses of:

• Less than or equal to 3 mrem to the total body and less than or equal to 10 mrem to any organ in any calendar year.

Effluent Concentration Limits The Effluent Concentration Limits (ECs) for gaseous and liquid effluents at and beyond the site boundary are listed in 10CFR20, Appendix B, Table 2, Columns 1 and 2, with the most restrictive EC being used in all cases. For dissolved and entrained gases in liquids, the EC of2.0E-04 uCi/ml is applied. This EC is based on the Xe-135 DAC of lE-05 uCi/ml of air (submersion dose) con-79

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report verted to an equivalent concentration in water as discussed in the International Commission on Radiological Protection (ICRP), Publication 2.

Average Energy The Davis-Besse ODCM limits the dose equivalent rates due to the release of fission and activation products to less than or equal to 500 mrem per year to the total body and less than or equal to 3000 mrem per year to the skin. Therefore, the average beta and gamma energies (E) for gaseous efflu-ents 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.

Measurements of Total Activity Fission and Activation Gases:

These gases, excluding tritium, are collected in Marinelli beakers specially modified for gas sam-pling, in steel flasks, or in glass vials, and are counted on a Germanium detector for principal gamma emitters. Radionuclides detected are quantified via gamma spectroscopy.

Tritium gas is collected using a bubbler apparatus and counted by liquid scintillation.

Iodine Iodine is collected on a charcoal cartridge filter and counted on a germanium detector. Specific quantification of each iodine radionuclide is performed using gamma spectroscopy.

Particulates Particulates are collected on filter paper and counted on a Germanium detector. Specific quantifi-cation of each radionuclide present on the filter paper is performed by using gamma spectroscopy.

Liquid Effluents Liquid effluents are collected in a Marinelli beaker and counted on a germanium detector. Quan-tification of each gamma-emitting radionuclide present in liquid samples is via gamma spectros-copy. Tritium in the liquid effluent is quantified by counting an aliquot of a composite sample in a liquid scintillation counting system.

Batch Releases Liquid from 1/1/19 through 12/31/19

1. Number of batch releases: 74

2. Total time period for the batch releases: 353.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

3. Maximum time period for a batch release: 570 minutes

4. Minimum time period for a batch release: 75 minutes

5. Average time period for a batch release: 268.9 minutes 80

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Gaseous from 1/1/19 through 12/31/19

1. Number of batch releases: 2

2. Total time period for the batch releases: 103.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />

3. Maximum time period for a batch release: 5988 minutes

4. Minimum time period for a batch release: 210 minutes

5. Average time period for a batch release: 3099 minutes Abnormal Releases There were no abnormal gaseous releases of radioactivity from the station during 2019.

There were no abnormal liquid releases of radioactivity from the station during 2019.

Releases from the ISFSI As discussed earlier in the report, Davis-Besse added eight dry shielded cannisters to the storage pad located inside the Protected Area in 2019. There were no identified effluents from this facil-ity in 2019 and no increase in the dose to the public was observed or calculated from the ISFSI.

Percent of ODCM Release Limits The following table presents the ODCM annual dose limits and the associated offsite dose to the public, in percent of limits, for January 1, 2019 through December 31, 2019.

PERCENT OF SPECIFICATION ANNUAL DOSE LIMIT LIMIT Report Period: January 1, 2019 - December 31, 2019 (gaseous)

Noble gases ( gamma) 0.00E+00 mrad 10 mrad 0.00E+00 Noble gases (beta) 0.00E+00 mrad 20 mrad 0.00E+00 I-131, tritium and particulates 2.0lE-02 mrem 15 mrem 1.34E-01 C-14 6.45E-01 mrem 20mrem 3.22E+00 Report Period: January 1, 2019 - December 31, 2019 (liquid)

Total Body 4.73E-03 mrem 3mrem 1.58E-01 Organ (Liver) 5.16E-03 mrem l0mrem 5.16E-02 Sources of Input Data

• Water Usage: Survey of Water Treatment Plants (DSR-95-00347)

• 0-50 mile, milk, vegetable production, and population data was taken from 1982 Annual Environmental Operating Report entitled, "Evaluation of Compliance with Appendix I to 10CFR50: Updated Population, Agricultural, Meat - Animal, and Milk Production Data Tables for 1982". This evaluation was based on the 1980 Census, the Agricultural Ministry of Ontario 1980 report entitled "Agricultural Statistics and Livestock Marketing Account",

the Agricultural Ministry of Ontario report entitled "Agricultural Statistics for Ontario, Publication 21, 1980," the Michigan Department of Agriculture report entitled "Michigan Agricultural Statistics, 1981 ", and the Ohio Crop Reporting Service report entitled "Ohio Agricultural Statistics, 1981 ".

81

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

• Gaseous and liquid source terms: Tables 14 through 18 of this report.

• Location of the nearest individuals and pathways by sector within 5 miles, see Land Use Census Section of the report.

• Population of the 50-mile Radius of Davis-Besse (DSR-95-00398 and DBNPS Population Update Analysis-2015, KLD Engineering, P.C.).

Dose to Public Due to Activities Inside the Site Boundary In accordance with ODCM Section 7.2, the Radioactive Effluent Release Report includes an as-sessment of radiation doses from radioactivity released in liquid and gaseous effluents to members of the public from activities inside the site boundary.

The Pavilion and Training Center pond have, on occasion, been made accessible to employees and their families. The Pavilion may be accessible to the public for certain social activities. The Train-ing Center pond allows employees and their families to periodically fish on site under a "catch-and-release" program; therefore the fish pathway is not considered applicable. Considering the frequency and duration of the visits, the resultant dose would be a small fraction of the calculated maximum site boundary dose. For purposes of assessing the dose to members of the public in accordance with ODCM Section 7.2, the following exposure assumptions are used:

• Exposure time for maximally-exposed visitors is 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> (1 hr/day, 5 day/ week, 50 wk/yr)

• Annual average meteorological dispersion (conservative, default use of maximum site boundary dispersion).

• For direct "shine" from the Independent Spent Fuel Storage Installation (ISFSI), default use of the maximum dose rate for a completed (full) ISFSI, at a distance of 950 feet.

ODCM equations may be used for calculating the dose to a member of the public for activities inside the site boundary. This dose would be at least a factor of 35 times less than the maximum site boundary air dose, as calculated in the ODCM. Nowhere onsite are areas accessible to the public where exposure to liquid effluents could occur. There-fore, the modeling of the ODCM conservatively estimates the maximum potential dose to members of the public.

• The Old Steam Generator Storage Facility (OSGSF) provides long-term storage for two Once Through Steam Generators, two Reactor Coolant System Hot Leg Piping sections, one Reactor Vessel Closure Head (with Control Rod Drive Mechanisms and Service Support Structure). The OSGSF is designed so that dose rates at the exterior of the facility are within station designated dose rate limits which are more restrictive than the dose rate limits of 10CFR20.

82

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Non-Functional Radioactive Effluent Monitoring Equipment ODCM Table 2-1 Radioactive Liquid Effluent Monitoring Instrumentation Instrument Required Available Duration Comments Channels Channels Non-Functional None There were no instances in 2019 in which less than the required number of radioactive liquid effluent monitoring instrumentation channels were Functional for 30 days.

ODCM Table 3-1 Radioactive Gaseous Effluent Monitoring Instrumentation Instrument Required Available Duration Comments Channels Channels Non-Functional RE5052C, Con- 1 0 33 days With less than the number of required chan-tainment Purge nels Functional, effluent releases via this Monitoring Sys- pathway may continue provided grab sam-tern Noble Gas pies are taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and Activity Moni- analyzed in accordance with applicable pro-tor cedures.

There were no gaseous effluent releases via this pathway while RE5052C was non-func-tional.

This is not a typical release pathway during power operations and a preventive mainte-nance order was completed to restore the in-strument to Functional status.

Changes to the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP)

The ODCM was revised in February 2019 (Revision 36) to incorporate the Radiological Envi-ronmental Monitoring Program (REMP) Enhancement Program into the ODCM-required REMP Program. This effort improved compliance with the ODCM requirements and added several In-dicator sampling locations. In addition, this transition eliminated unnecessary sampling stations that did not provide beneficial results. Several REMP location maps were upgraded through the use of improved technology.

Revision 37 of the ODCM was issued in October 2019 to incorporate results from the 2018 Land Use Census. A new garden was located in the Southwest sector 4.74 miles from the station. In addition, abandoned REMP Groundwater Well locations were removed from the program. Nu-merous footnotes were added to ODCM Table 6-1, Radiological Environmental Monitoring Pro-gram, as a result of the 2019 NRC REMP Inspection to clarify implementation of the REMP.

There were no changes to the Process Control Program during 2019.

83

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Borated Water Storage Tank Radionuclide Concentrations During 2019, the Borated Water Storage Tank's sum of limiting fractions of radionuclides con-centration, a unitless number, did not exceed the ODCM Section 2.2.4 limit of 1.

Table 14 Gaseous Effluents - Summation of All Releases Est.

1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total%

Nuclide Unit 2019 2019 2019 2019 Error Fission and Activation Gases Total Release Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.5E+0l Average Release Rate for Period uCilsec NIA NIA NIA NIA Percent of applicable limits NIA Iodines Total Iodines (I-131) Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.5E+0I Average Release Rate for Period uCi/sec NIA NIA NIA NIA Percent of applicable limits NIA Particulates Particulates with half-lives greater Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.5E+0l than 8 days Average Release Rate for Period uCilsec NIA NIA NIA NIA Percent of applicable limits NIA Gross Alpha Activity Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.5E+0I Tritium Total Release Ci 8.14E+00 8.40E+00 7.39E+00 8.34E+00 2.5E+0l Average Release Rate for Period uCi/sec 2.32E-0I l.02E+00 3.25E-0I 9.88E-01 Percent of applicable limits NIA Carbon-14 Total Release Ci l.02E+00 l.06E+00 I.0lE+00 l.06E+00 Note: The average release rate is taken over the entire quarter, not over the time the time period of the releases.

84

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 15 Gaseous Effluents - Ground Level Releases - Batch Mode 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<1> 2019<1> 2019<1> 2019< 1>

Fission Gases Kr-85 Ci <LLD <LLD <LLD <LLD Kr-85m Ci <LLD <LLD <LLD <LLD Kr-87 Ci <LLD <LLD <LLD <LLD Kr-88 Ci <LLD <LLD <LLD <LLD Xe-133 Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Xe-135m Ci <LLD <LLD <LLD <LLD Xe-138 Ci <LLD <LLD <LLD <LLD Total for Period: NIA NIA NIA NIA Iodines 1-131 Ci <LLD <LLD <LLD <LLD 1-133 Ci <LLD <LLD <LLD <LLD 1-135 Ci <LLD <LLD <LLD <LLD Total for Period: NIA NIA NIA NIA Particulates and Tritium H-3 Ci 4.75E-04 l.91E-04 l.52E-02 l.28E-04 Sr-89 Ci <LLD <LLD <LLD <LLD Sr-90 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD <LLD <LLD <LLD Cs-137 Ci <LLD <LLD <LLD <LLD Ba-La-140 Ci <LLD <LLD <LLD <LLD Total for Period: 4.75E-04 l.91E-04 l.52E-02 1.28E-04

( 1) LLDs for Ground Level Gaseous Releases - Batch Mode are listed on page 87.

85

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 15 (Continued)

Gaseous Effluents - Ground Level Releases Continuous Mode 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<2> 2019<2> 2019<2> 2019<2>

Fission Gases Kr-85 Ci <LLD <LLD <LLD <LLD Kr-85m Ci <LLD <LLD <LLD <LLD Kr-87 Ci <LLD <LLD <LLD <LLD Kr-88 Ci <LLD <LLD <LLD <LLD Xe-133 Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Xe-135m Ci <LLD <LLD <LLD <LLD Xe-138 Ci <LLD <LLD <LLD <LLD Total for Period: NIA NIA NIA NIA Iodines 1-131 Ci <LLD <LLD <LLD <LLD 1-133 Ci <LLD <LLD <LLD <LLD 1-135 Ci <LLD <LLD <LLD <LLD Total for Period: NIA NIA NIA NIA Particulates and Tritium H-3 Ci l.97E-03 l.56E-03 l.41E-03 8.16E-04 Sr-89 Ci <LLD <LLD <LLD <LLD Sr-90 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD <LLD <LLD <LLD Cs-137 Ci <LLD <LLD <LLD <LLD Ba-La-140 Ci <LLD <LLD <LLD <LLD Total for Period: l.97E-03 l.56E-03 l.41E-03 8.16E-04 (2) LLDs for Ground Level Gaseous Releases - Continuous Mode are listed on page 87.

86

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 15 (Continued)

Gaseous Effluents - Ground Level Releases LLDs for Continuoush and Batcha Mode Ar-41 <9.13E-09 µCi/ml Kr-85 <1.76E-06 µCi/ml Kr-85m <8.00E-09 µCi/ml Kr-87 <2.68E-08 µCi/ml Kr-88 <2.SIE-08 µCi/ml Xe-133 <l.SlE-08 µCi/ml Xe-133m <l.85E-06 µCi/ml Xe-135 <6.81E-09 µCi/ml Xe-135m <1.83E-07 µCi/ml Xe-138 <5.99E-07 µCi/ml I-131 <9.32E-15 µCi/ml I-133 <1.04E-14 µCi/ml I-135 <5.39E-14 µCi/ml Cs-134 <9.67E-15 µCi/ml Cs-137 <l.27E-14 µCi/ml Ba-140 <2.79E-14 µCi/ml La-140 <1.62E-14 µCi/ml Sr-89 <3.40E-15 µCi/ml Sr-90 <l.30E-15 µCi/ml Mn-54 <l.46E-14 µCi/ml Fe-59 <2.27E-14 µCi/ml Co-58 <8.74E-15 µCi/ml Co-60 <l.77E-14 µCi/ml Zn-65 <3.62E-14 µCi/ml Mo-99 <7.39E-14 µCi/ml Ce-141 <l.26E-14 µCi/ml a Auxiliary Feed Pump Turbine Exhaust., Main Steam Safety Valves, and Auxiliary Boiler Outage Release are listed as batch release.

b Atmospheric Vent Valv~ weepage and Steam Packing Exhauster are continuous releases.

87

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 16 Gaseous Effluents - Mixed Mode Releases Batch Mode 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019< 1> 2019<1> 2019<1> 2019<1>

Fission Gases Ar-41 Ci <LLD <LLD <LLD <LLD Kr-85 Ci <LLD <LLD <LLD <LLD Kr-85m Ci <LLD <LLD <LLD <LLD Kr-87 Ci <LLD <LLD <LLD <LLD Kr-88 Ci <LLD <LLD <LLD <LLD Xe-131m Ci <LLD <LLD <LLD <LLD Xe-133 Ci <LLD <LLD <LLD <LLD Xe-133m Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Xe-135m Ci <LLD <LLD <LLD <LLD Xe-138 Ci <LLD <LLD <LLD <LLD Total for Period: 0.00E+00 0.00E+00 0.00E+00 0.00+00

• Iodines 1-131 Ci <LLD <LLD <LLD <LLD 1-133 Ci <LLD <LLD <LLD <LLD 1-135 Ci <LLD <LLD <LLD <LLD Total for Period: Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00

• Particulates & Tritium H-3 Ci <LLD l.3 lE-04 <LLD 6.15E-04 Sr-89 Ci <LLD <LLD <LLD <LLD Sr-90 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD <LLD <LLD <LLD Cs-137 Ci <LLD <LLD <LLD <LLD Ba-La-140 Ci <LLD <LLD <LLD <LLD Total for Period: Ci 0.00E+00 l.31E-04 0.00E+00 6.15E-04 (1) LLDs for Mixed Mode Gaseous Releases -

Batch Mode are listed on page 90.

• Release of iodines and particulates are quantified in Mixed Mode Releases, Continuous Mode (Unit Station Vent) 88

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 16 (Continued)

Gaseous Effluents - Mixed Mode Releases - Continuous Mode 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<2> 2019<2> 2019<2> 2019<2>

Fission Gases Kr-85 Ci <LLD <LLD <LLD <LLD Kr-85m Ci <LLD <LLD <LLD <LLD Kr-87 Ci <LLD <LLD <LLD <LLD Kr-88 Ci <LLD <LLD <LLD <LLD Xe-133 Ci <LLD <LLD <LLD <LLD Xe-133m Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Xe-135m Ci <LLD <LLD <LLD <LLD Xe-138 Ci <LLD <LLD <LLD <LLD Total for Period: 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Iodines 1-131 Ci <LLD <LLD <LLD <LLD 1-132 Ci <LLD <LLD <LLD <LLD 1-133 Ci <LLD <LLD <LLD <LLD 1-135 Ci <LLD <LLD <LLD <LLD Total for Period: 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Particulates, Tritium Na-24 Ci <LLD <LLD <LLD <LLD Co-57 Ci <LLD <LLD <LLD <LLD Co-58 Ci <LLD <LLD <LLD <LLD Sr-89 Ci <LLD <LLD <LLD <LLD Sr-90 Ci <LLD <LLD <LLD <LLD Sb-124 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD <LLD <LLD <LLD Cs-137 Ci <LLD <LLD <LLD <LLD Ba-La-140 Ci <LLD <LLD <LLD <LLD H-3 Ci 8.14E+00 8.40E+00 7.39E+00 8.34E+00 Total for Period Ci 8.14E+00 8.40E+00 7.39E+00 8.34E+00 Carbon-14 Ci l.02E+0l l.06E+00 l.0lE+00 l.06E+00 (2) LLDs for Mixed Mode Gaseous Releases -

Continuous Mode are listed on page 90.

89

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 16 (Continued)

LLDs for Gaseous Effluents - Mixed Mode Releases Continuous Mode8 Batch Mode8 Kr-85 <l.76E-06 µCi/ml Ar-41 <2.17E-06 µCi/ml Kr-85m <8.00E-09 µCi/ml Kr-85m <l.l0E-06 µCi/ml Kr-87 <2.68E-08 µCi/ml Kr-87 <3.0lE-06 µCi/ml Kr-88 <2.51E-08 µCi/ml Kr-88 <3.24E-06 µCi/ml Xe-133 <l.51E-08 µCi/ml Xe-133 <1.44E-06 uCi/:inl Xe-133m <1.85E-06 µCi/ml Xe-133m <7.28E-05 µCi/ml Xe-135 <6.81E-09 µCi/ml Xe-135 <7.33E-07 µCi/ml Xe-135m <l.83E-07 µCi/ml Xe-135m <1.ISE-05 µCi/ml Xe-138 <5.99E-07 µCi/ml Xe-138 <3.79E-05 µCi/ml I-131 <9.32E-15 µCi/ml I-131 <1.05E-06 µCi/ml I-133 <l.04E-14 µCi/ml I-133 <l.07E-06 µCi/ml I-135 <5.39E-14 µCi/ml I-135 <5.34E-06 µCi/ml Cs-134 <9.67E-15 µCi/ml Sr-89 <3.40E-15 µCi/ml Cs-137 <l.27E-14 µCi/ml Sr-90 <l.30E-15 µCi/ml Ba-140 <2.79E-14 µCi/ml Cs-134 <8.88E-07 µCi/ml La-140 <l.62E-14 µCi/ml Cs-137 <l.19E-06 µCi/ml Sr-89 <3.40E-15 µCi/ml Ba-140 <4.24E-06 µCi/ml Sr-90 <l.30E-15 uCi/ml La-140 <l.57E-06 uCi/ml Mn-54 <l.46E-14 µCi/ml Kr-85 <3.0lE-04 uCi/ml Fe-59 <2.27E-14 µCi/ml Xe-131m <7.43E-05 uCi/ml Co-58 <8.74E-15 µCi/ml Co-60 <l.77E-14 µCi/ml Zn-65 <3.62E-14 µCi/ml Mo-99 <7.39E-14 µCi/ml Ce-141 <l.26E-14 µCi/ml-a These radionuclides were not identified in every quarter in concentrations above the lower limit of detection (LLD).

90

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 17 Liquid Effluents - Summation of All Releases Type Unit 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Est. Total 2019 2019 2019 2019 %Error Fission and Activation Products Total Release (without Tritium, Ci 6.72E-05 3.00E-03 4.75E-04 8.86E-07 2.0E+0l Gases, Alpha)

Average Diluted Concentration µCi/ml 6.36E-12 2.46E-10 3.34E-11 6.91E-14 During Perioda Percent of 10CFR20 Limit  % 7.35E-06 l.52E-04 9.69E-06 2.41E-08 Tritium Total Release Ci 2.45E+02 l.12E+02 3.33E+02 3.09E+02 2.0E+Ol Average Diluted Concentration µCi/ml 2.32E-05 9.16E-06 2.34E-05 2.41E-05 During Perioda Percent of 10CFR20 Limit  % 1.62E-01 6.40E-02 l.63E-01 l.68E-01 Dissolved and Entrained Gases Total Release Ci 2.09E-06 0.00E+00 5.49E-05 4.99E-05 2.0E+0l Average Diluted Concentration µCi/ml 1.98E-13 0.00E+00 3.86E-12 3.89E-12 During Perioda Percent of 10CFR20 Limit  % 6.90E-09 0.00E+00 1.35E-07 1.36E-07 Gross Al;uha Total Release Ci 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.0E+Ol Volume of Waste Released (prior to dilution)

Batch liter 3.96E+05 3.24E+05 5.38E+05 7.59E+05 2.0E+0l Continuous liter 1.26E+08 9.92E+07 8.12E+07 l.54E+08 2.0E+Ol Volume of Dilution Water Batch liter 4.74E+08 1.70E+08 6.94E+08 6.52E+08 2.0E+0l Continuous liter 9.96E+09 l.19E+10 l.34E+10 1.20E+10 2.0E+0l Total Volume of Water Released liter 1.06E+10 1.22E+10 l.42E+10 1.28E+10

• Tritium and alpha may be found in both continuous and batch releases. Average diluted concentrations are based on total volume of water released during the quarter. Fission and Activation products and Dissolved and Entrained Gases are nor-ma11y only detected in batch releases.

91

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 18 Liquid Effluents - Nuclides Released in Batch Releases 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<1> 2019<1) 2019<1) 2019<1>

Fission and Activation Products Cr-51 Ci <LLD <LLD <LLD <LLD Mn-54 Ci <LLD 6.42E-07 <LLD <LLD Fe-55b Ci <LLD 3.89E-04 <LLD <LLD Co-57 Ci <LLD 2.07E-05 2.68E-06 <LLD Co-58 Ci 2.44E-07 1.12E-03 l.24E-04 8.86E-07 Fe-59 Ci <LLD <LLD <LLD <LLD Co-60 Ci <LLD 2.00E-04 3.l0E-05 <LLD Ni-63 Ci <LLD 1.13E-03 3.18E-04 <LLD Zn-65 Ci <LLD <LLD <LLD <LLD Sr-89b Ci <LLD <LLD <LLD <LLD Sr-90b Ci <LLD <LLD <LLD <LLD Sr-92 Ci <LLD <LLD <LLD <LLD Nb-95 Ci <LLD <LLD <L.LD <LLD Zr-95 Ci <LLD <LLD <LLD <LLD Nb-97 Ci <LLD <LLD <LLD <LLD Zr-97 Ci <LLD <LLD <LLD <LLD Mo-99 Ci <LLD <LLD <LLD <LLD Tc-99m Ci <LLD <LLD <LLD <LLD Ru-103 Ci <LLD <LLD <LLD <LLD Ru-106 Ci <LLD <LLD <LLD <LLD Ag-llOm Ci <LLD <LLD <LLD <LLD Sb-122 Ci 6.00E-07 <LLD <LLD <LLD Te-123M Ci <LLD <LLD <LLD <LLD Sb-124 Ci 6.45E-05 l.0SE-05 <LLD <LLD Sb-125 Ci <LLD <LLD <LLD <LLD I-131 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD 7.84E-07 <LLD <LLD Cs-137 Ci 1.83E-06 l.24E-04 <LLD <LLD Ba-140 Ci <LLD <LLD <LLD <LLD La-140 Ci <LLD <LLD <LLD <LLD Ce-141 Ci <LLD <LLD <LLD <LLD Total for Period Ci 6.72E-05 3.00E-03 4.75E-04 8.86E-07 (1) LLDs for Liquid Releases - Batch Mode are listed on page 95.

92

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 18 (continued)

Liquid Effluents - Nuclides Released In Batch Releases 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<1> 2019<1> 2019<1> 2019< 1>

H-3 Ci 2.45E+02 1.12E+02 3.33E+02 3.09E+02 Dissolved and Entrained Gases Kr-85 Ci <LLD <LLD <LLD <LLD Xe-131m Ci <LLD <LLD <LLD <LLD Xe-133 Ci 2.09E-06 <LLD 5.49E-05 4.99E-05 Xe-133m Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Total for Period: Ci 2.09E-06 0.00E+00 5.49E-05 4.99E-05

( 1) LLDs for Liquid Releases - Batch Mode are listed on page 95.

93

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 18 (continued)

Liquid Effluents - Nuclidesa Released In Continuous Releases 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Nuclide Unit 2019<2> 2019<2> 2019<2> 2019<2>

Fission and Activation Products Cr-51 Ci <LLD <LLD <LLD <LLD Mn-54 Ci <LLD <LLD <LLD <LLD Fe-59 Ci <LLD <LLD <LLD <LLD Co-58 Ci <LLD <LLD <LLD <LLD Co-60 Ci <LLD <LLD <LLD <LLD Zn-65 Ci <LLD <LLD <LLD <LLD Sr-89b Ci <LLD <LLD <LLD <LLD Sr-90b Ci <LLD <LLD <LLD <LLD Zr-95 Ci <LLD <LLD <LLD <LLD Mo-99 Ci <LLD <LLD <LLD <LLD Tc-99m Ci <LLD <LLD <LLD <LLD I-131 Ci <LLD <LLD <LLD <LLD Cs-134 Ci <LLD <LLD <LLD <LLD Cs-137 Ci <LLD <LLD <LLD <LLD Ba/La-140 Ci <LLD <LLD <LLD <LLD Ce-141 Ci <LLD <LLD <LLD <LLD Total for Period: Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+oO Tritium Ci O.OOE-00 O.OOE+OO O.OOE+oO O.OOE+OO Dissolved and Entrained Gases Xe-133 Ci <LLD <LLD <LLD <LLD Xe-135 Ci <LLD <LLD <LLD <LLD Total for Period: Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO (2) LLDs for Liquid Releases - Continuous Mode are listed on page 95.

94

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 18 (continued)

Liquid Effluents - LLDs for Nuclides Releaseda Cr-51 <l.15E-07 µCi/ml Ar-41 <2.25E-08 µCi/ml Mn-54 <l.84E-08 µCi/ml I-131 <l.35E-08 µCi/ml Fe-55b <6.80E-07 µCi/ml Xe-13lm <6.63E-06 µCi/ml Co-57 <1.07E-08 µCi/ml Xe-133 <2.64E-08 µCi/ml Co-58 <1.35E-08 µCi/ml Xe-133m <6.46E-06 µCi/ml Fe-59 <4.93E-07 µCi/ml Cs-134 <l.S0E-08 µCi/ml Co-60 <l.73E-08 µCi/ml Xe-135 <1.08E-08 µCi/ml Zn-65 <3.26E-08 µCi/ml Cs-137 <l.99E-08 µCi/ml Kr-85 <3.15E-06 µCi/ml Ba-140 <4.80E-08 µCi/ml Sr-89b <7.30E-08 µCi/ml La-140 <2.18E-08 µCi/ml Sr-90b <1.60E-08 µCi/ml Ce-141 <1.82E-08 µCi/ml Sr-92 <l.73E-08 µCi/ml Ce-144 <7.92E-08 µCi/ml Zr-95 <1.87E-08 µCi/ml Nb-97 <2.39E-08 µCi/ml Zr-97 <2.44E-08 µCi/ml Sb-122 <1.56E-08 µCi/ml Tc-99m <1.12E-08 µCi/ml Te-123m <6.21E-09 µCi/ml Mo-99 <8.31E-08 µCi/ml Ni-63 <7.70E-08 µCi/ml Ru-103 <l.25E-08 µCi/ml Ru-106 <l.34E-07 µCi/ml Ag-llOm <l.69E-08 µCi/ml Sb-124 <l.64E-08 µCi/ml Sb-125 <4.84E-08 µCi/ml a These radionuclides were not identified every quarter in concentrations above the lower limit of detection (LLD). LLDs are applicable to both batch and continuous modes due to identical sample and analysis methods.

b Quarterly composite sample 95

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 19 Solid Waste and Irradiated Fuel Shipments A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel) 12-month Est. Total

1. Tvoe of Waste Unit Period Error,%

a. Spent resins, filter sludges, m3 1.88 E+0l 2.5E+0l evaporator bottoms, etc. Ci 9.53 E+00 2.5E+0l

b. Dry compressible waste, m3 1.05 E+02 2.5E+0l contaminated equip., etc. Ci 9.55 E-02 2.5E+0l C. Irradiated components, m3 control rods, etc. Ci NIA NIA

d. Filters m3 1.62 E-01 2.5E+0l Ci 2.13 E-02 2.5E+0l

e. Others: Spent Resin Storage m3 Tank Liquor Ci NIA NIA

2. Estimate of major nuclide composition (by type of waste)

~ Percent(%) Est. Error~ %

a. Spent Resins c 8 t37 3.35 E+0l 2.50E+0l H3 2.27 E+0l 2.50E+0l Ni63 2.25 E+0l 2.50E+0l Fess 8.37 E+00 2.50E+0l Co6o 7.79 E+00 2.50E+0l Cs134 1.58 E+00 2.50E+0l c14 1.33 E+00 2.50E+0l Coss 9.94 E-01 2.50E+0l Mns4 2.85 E-01 2.50E+Ol Sr90 2.02 E-01 2.50E+0l Nis9 1.96 E-01 2.50E+0l Cos1 1.19 E-01 2.50E+0l

b. Dry compressible waste, contaminated Ni63 7.16 E+0l 2.50E+0l equipment, etc. H3 1.49 E+0l 2.50E+0l Co6o 4.69 E+00 2.50E+0l Coss 2.99 E+00 2.50E+0l c8t37 2.44E+00 2.50E+0l c14 2.31 E+00 2.50E+0l cet44 1.01 E+00 2.50E+0l 96

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report C. None

~ Percent(%} Est Error,%

d. Filters Ni63 5.05 E+0l 2.50E+0l Cs137 2.52 E+0l 2.50E+0l Co6o 1.66 E+0l 2.50E+0l Fess 6.96 E+00 2.50E+0l Sb12s 5.05 E-01 2.50E+0l c14 1.27 E-01 2.50E+0l Sr90 1.09 E-01 .2.50E+0l

e. None Shipments Number of Shipments: 2 Mode of Transportation: Truck Destination: Energy Solutions, Oak Ridge, TN for processing and disposal at Energy Solutions, Clive, UT Type of Container (Container Volume): Metal boxes (assorted sizes, 0.2 - 36.2 m 3)

Volume shipped for processing 58.6 m 3 Number of Shipments: 1 Mode of Transportation: . Truck Destination: Unitech, Oak Ridge, TN for processing and disposal at Energy Solutions, Clive, UT Type of Container (Container Volume): Metal boxes 36.2 m3 Volume shipped for processing 51 m3 Number of Shipments: 1 Mode of Transportation: Truck Destination: TOXCO, Oak Ridge, TN for processing and disposal at Energy Solutions, Clive, UT Type of Container (Container Volume): Metal liners 5.38 m3 Volume shipped for processing 11.8 m3 97

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Number of Shipments: 1 Mode of Transportation: Truck Destination: ResinSqlutions, Oak Ridge, TN for processing and disposal at WCS, Andrews, TX Type of Container (Container Volume): Poly IDC 3.40 m 3 Volume shipped for processing 2.41 m3 B. IRRADIATED FUEL SHIPMENTS There were no shipments of irradiated fuel.

Onsite Groundwater Monitoring Davis-Besse began sampling wells near the plant in 2007 as part of an industry-wide Groundwater Protection Initiative (GPI), which was established to ensure there are no inadvertent releases of radioactivity from the plant which could affect offsite groundwater supplies. In addition to several existing pre-construction era wells, sixteen new GPI monitoring wells were installed in 2007 to accomplish the monitoring required. These wells are not used for drinking water purposes and are typically sampled in the spring and fall of each year. There is a total of forty-nine groundwater wells on site that can be sampled to monitor groundwater flow and tritium concentration.

Davis-Besse's Groundwater Protection Program includes baseline annual spring and fall sampling of the sixteen monitoring wells installed in 2007. Additional wells can be sampled as needed if increased monitoring is warranted. An increasing trend of tritium in groundwater wells was identified in February 2015. The investigation determined that the most probable cause was due to construction activities surrounding removal of the Primary Water Storage Tank. Additional wells were added to the spring and fall sampling campaigns and the sampling frequency was increased to quarterly for selected wells to closely monitor and trend tritium values in vulnerable areas of the site. A decreasing trend in tritium concentration has been observed since 2016. In the third quarter of 2017, Davis-Besse returned to semi-annual sampling (spring and fall) after all wells were less than 2,000 pCi/L for three consecutive quarters.

2018 groundwater wells continued to be less than 2,000 pCi/L and all were less than 1000 pCi/L in 2019.

2019 groundwater well sample results are presented in Table 20 and a historical trend is shown in Figure 28.

In April 2017, Environmental Resources Management completed a model update of the site hydrology.

The scope of the study was to determine the impact that construction of the Emergency Feedwater Facility (EFWF) had on groundwater flow at DBNPS and to evaluate if the Intake Canal is still the discharge location for site groundwater. The study concluded that the presence of the new EFWF does not appear to significantly impact groundwater flow for the site. Overall site-wide groundwater flow remains in a west to east direction, with groundwater flowing around the EFWF foundation. While wells MW-22S/D were removed during the EFWF project, potential leaks or spills west of the Power Block would still be detected by other existing wells. Groundwater flow is discharging to the Intake Canal.

Therefore, potential leaks or spills of licensed material originating from Davis-Besse would be captured by pumping water from the Intake Canal as part of normal plant operations.

98

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 20 2019 Groundwater Tritium Results Year 2019 Mav November Well No. [H-3], pCi/1 [H-3], pCi/1 MW-100A 157 173 MW-100B < 153 179 MW-100C 185 226 MW-101A < 153 < 151 MW-101B < 153 < 151 MW-102A 451 < 151 MW-102B 441 609 MW-103A 320 259 MW-103B 445 612 MW-104A < 153 < 151 MW-104B 235 341 MW-104C < 153 < 151 MW-105A 468 438 MW-14S 345 502 MW-18S 872 825 MW-20S < 153 246 MW-21S 216 251 MW-30S 193 447 MW-34S 324 444 MW-37S 256 237 99

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

- Avg of All GVVM Indicator Wells H-3 (pCi/L)

Davis Besse Onsite Groundwater Monitoring Program H-3 Trends _.,._ Control Location

<200 pCi/L = Typical LLD - Typical LLD H-3 (<200 pCi/L) 348 pCi/L = Pre-Operational Mean 2,000 pCUL = NRC Required LLD Pre- Operational Mean H-3 (348 pCi/L) 2,000 pCi/L = FENOC/NEI Communication Level - NRC Required LLD H-3 (2,000 pCi/L) 20,000 pCi/L = EPA Drinking Water Reporting Level - EPA Drinking Water Reporting Level H-3 (20,000 pCi/L)

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Jr- * * =i 100 +--.---.--,---,---,---,--,---,---,---,--,---,---,---,----,,---,---,---,--,---,---,---,--,---,---,---,,-....--1 Figure 28 - Onsite Groundwater Monitoring Summary of Onsite Spills and Notifications There were no identified onsite spills during 2019.

There were no groundwater well sample results during 2019 that required notifications to the State, County and local officials.

Summary of Items Added to Decommissioning Files per 10 CFR 50.75(g)

There were no elevated groundwater tritium values during 2019 and no updates to the Decommissioning Files per 10 CFR 50.75(g).

100

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 21 Doses Due to Gaseous Releases for January through December 2019 Maximum Individual Dose Due to 1-131, H-3 and Particulates with Half-Lives Greater than 8 days.

Whole Body Dose 2.0lE-02 mrem Significant Organ Dose (Liver) 2.0lE-02 mrem Maximum Individual Dose Due to Noble Gas Whole Body Dose 0.00E+00 mrem Skin Dose 0.00E+00 mrad Maximum Individual Dose Due to C-14 Whole Body Dose 1.3 lE-01 mrem Significant Organ Dose (Bone) 6.45E-0 1 mrem Population Dose Due to 1-131, H-3 and Particulates with Half-Lives Greater than 8 days.

Total Integrated Population Dose 5.87E-02 person-rem Average Dose to Individual in Population 2.69E-05 mrem Population Dose Due to Noble Gas Total Integrated Population Dose 0.00E+00 person-rem Average Dose to Individual in Population 0.00E+00 mrem Population Dose Due to C-14 Total Integrated Population Dose 1.75E-01 person-rem Average Dose to Individual in Population 8.0lE-05 mrem 101

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 22 Doses Due to Liquid Releases for January through December 2019 Maximum Individual Whole Body Dose 4. 73E-03 mrem Maximum Individual Significant Organ Dose 5. l 6E-03 mrem (Liver)

Population Dose Total Integrated Population Dose 7.74E-01 person-rem Average Dose to Individual 3.54E-04 mrem Table 23 Annual Dose to The Most Exposed (from all pathways) Member of the Public 2019 ANNUAL DOSE 40CFR190 LIMIT PERCENT OF (mrem) (mrem) LIMIT Whole Body Dose*

Noble Gas 0.00E+00 Iodine, Tritium, Particulates 2.0lE-02 C-14 l.31E-01 Liquid 4.73E-03 Total Whole Body Dose l.56E-01 25 6.24E-01 Thyroid Dose Iodine, Tritium, Particulates l.39E-02 75 l.85E-02 Skin Dose Noble Gas 0.00E+00 25 0.00E+00 Significant Organ Dose (Liver) l.51E-02 25 6.04E-02 Significant Organ Dose (C-14) 6.45E-01 25 2.58E+00 (Bone)

Meteorological Data Meteorological data, stored on a compact disk for January 1 through December 31, 2019, has been submitted with this document to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555.

• Direct radiation from the facility is not distinguishable from natural background and is, therefore, not included in this compilation.

102

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Land Use Census Program Design Each year a Land Use Census is conducted by Davis-Besse in order to update information neces-sary to estimate radiation dose to the general public and to determine if any modifications are necessary to the Radiological Environmental Monitoring Program (REMP). The Land Use Census is required by Title 10 of the Code of Federal Regulations, Part 50, Appendix I and Davis-Besse Nuclear Power Station Offsite Dose Calculation Manual, Section 5, Assessment of Land Use Cen-sus Data. The Land Use Census identifies gaseous pathways by which radioactive material may reach the general population around Davis-Besse. The information gathered during the Land Use Census for dose assessment and input into the REMP ensure these programs are as current as possible. The pathways of concern are listed below:

• Inhalation Pathway - Internal exposure as a result of breathing radionuclides carried in the air.

• Ground Exposure Pathway - External exposure from radionuclides deposited on the ground

• Plume Exposure Pathway - External exposure directly from a plume or cloud of radioactive material.

• Vegetation Pathway - Internal exposure as a result of eating vegetables, fruit, etc.

which have a build-up of deposited radioactive material or which have absorbed ra-dionuclides through the soil.

• Milk Pathway - Internal exposure as a result of drinking milk, which may contain radioactive material as a result of a cow or goat grazing on a pasture contaminated by radionuclides.

Methodology The Land Use Census consists of recording and mapping the locations of the closest residences, dairy cattle and goats, and broad leaf vegetable gardens (greater than 500 square feet) in each meteorological sector within a five-mile radius of Davis-Besse.

The surveillance portion of the 2019 Land Use Census was performed during the months of June through August. In order to gather as much information as possible, the locations of residences, dairy cows, dairy goats, and vegetable gardens were recorded. The residences, vegetable gardens, and milk animals are used in the dose assessment program. The gardens should be at least 500 square feet in size, with at least 20% of the vegetables being broadleafplants (such as cabbage and kale).

Each residence is tabulated as being an inhalation pathway, as well as ground and plume exposure pathways. Each garden is tabulated as a vegetation pathway.

103

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report All of the locations identified are plotted on a map (based on the U.S. Geological Survey 7.5 mi-nute series of the relevant quadrangles) which has been divided into 16 equal sectors corresponding to the 16 cardinal compass points (Figure 29). If available, the closest residence, milk animal, and vegetable garden in each sector are determined by measuring the distance from each to the Station Vent at Davis-Besse.

Results One new pathway was identified in the 2019 census:

SW sector: A new garden was located 4.74 miles from the plant.

One garden from 2018 was no longer active in 2019:

SW sector: A garden 3.5 miles from the plant was not planted in 2019.

The critical receptor is a garden in the W sector at 0.97 miles from Davis-Besse, which is unchanged from 2018.

The detailed list in Table 24 was used to update the database of the effluent dispersion model used in dose calculations. Table 24 is divided by sectors and lists the distance (in miles) of the closest pathway in each.

Table 25 provides information on pathways, critical age group, atmospheric dispersion (x/Q) and deposition (D/Q) parameters for each sector. This information is used to update the Offsite Dose Calculation Manual (ODCM). The ODCM describes the methodology and parameters used in calculating offsite doses from radioactivity released in liquid and gaseous effluents and in calcu-lating liquid and gaseous effluent monitoring instrumentation alarm/trip setpoints. The x/Q and D/Q values are revised each year, as required, based on the Annual Land Use Census results.

104

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 24 Closest Exposure Pathways Present in 2019 Distance from Station (miles) Closest Pathways N 0.55 Inhalation Ground Exposure Plume Exposure NNE 0.55 Inhalation Ground Exposure Plume Exposure NE 0.56 Inhalation Ground Exposure Plume Exposure ENE,E, ESE NIA Located over Lake Erie SE 4.94 Inhalation Ground Exposure Plume Exposure SSE 1.82 Vegetation SSE 0.93 Inhalation Ground Exposure Plume Exposure s 3.10 Vegetation s 0.68 Inhalation Ground Exposure Plume Exposure SSW 0.70 Vegetation SSW 0.61 Inhalation Ground Exposure Plume Exposure

• SW 4.74 Vegetation SW 0.67 Inhalation Ground Exposure Plume Exposure

• changed from 2018 106

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 24 (Continued)

Closest Exposure Pathways Present in 2019 Distance from Station (miles) Closest Pathways WSW 0.96 Inhalation Ground Exposure Plume Exposure WSW 4.0 Vegetation w 0.61 Inhalation Ground Exposure Plume Exposure w 0.97 Vegetation WNW 0.94 Inhalation Ground Exposure Plume Exposure NW 0.93 Inhalation Ground Exposure Plume Exposure NNW 0.80 Inhalation Ground Exposure Plume Exposure 107

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 25 Pathway Locations and Corresponding Atmospheric Dispersion (X/Q) and Deposition (D/Q)

Parameters SECTOR MILES CRITICAL AGE X/Q D/Q PATHWAY GROUP (SEC/M3) (M-2)

N 0.55 Inhalation Child l.56E-06 l.34E-08 NNE 0.55 Inhalation Child 2.09E-06 2.34E-08 NE 0.56 Inhalation Child 1.43E-06 2.32E-08

• ENE

• E

• ESE SE 4.94 Inhalation Child 9.69E-09 l.53E-10 SSE 1.82 Vegetation Child 4.58E-08 8.31E-10 s 3.10 Vegetation Child l.76E-08 2.66E-10 SSW 0.70 Vegetation Child 2.23E-07 4.33E-09

• • SW 4.74 Vegetation Child 1.49E-08 2.llE-10 WSW 4.00 Vegetation Child 2.66E-08 3.68E-10 w 0.97 Vegetation Child 3.28E-07 4.56E-09 WNW 0.94 Inhalation Child 2.84E-07 2.94E-09 NW 0.93 Inhalation Child 2.90E-07 2.55E-09 NNW 0.80 Inhalation Child 4.83E-07 3.78E-09

• Since these sectors are located over marsh areas and Lake Erie, no ingestion pathways are present.

• • Changed location from 2018 Land Use Census.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Non-Radiological Environmental Programs Meteorological Monitoring 1 The Meteorological Monitoring Program at Davis-Besse is required by the Nuclear Regulatory Commission (NRC) as part of the program for evaluating the effects ofroutine operation of nuclear power stations on the surrounding environment. Both NRC regulations and the Davis-Besse Tech-nical Requirements Manual provide guidelines for the Meteorological Monitoring Program. These guidelines ensure that Davis-Besse has the proper equipment, in good working order, to support the many programs utilizing meteorological data.

Meteorological observations at Davis-Besse began in October 1968. The Meteorological Moni-toring Program at Davis-Besse has an extensive record of data with which to perform climate studies which are used to determine whether Davis-Besse has had any impact upon the local cli-mate. After extensive statistical comparative research the meteorological personnel have found no impact upon local climate or short-term weather patterns.

The Meteorological Monitoring Program also provides data that can be used by many other groups and programs such as the Radiological Environmental Monitoring Program, the Emergency Pre-paredness Program, Site Chemistry, Plant Operations, Nuclear Security, Materials Management and Industrial Safety, as well as other plant personnel and members of the surrounding community.

The' Radiological Environmental Monitoring Program uses meteorological data to aid in evaluat-ing the radiological impact, if any, ofradioactivity released in Station effluents. The meteorolog-ical data is used to evaluate radiological environmental monitoring sites to assure the program is as .current as possible. The Emergency Preparedness Program uses meteorological data to calcu-late emergency dose scenarios for emergency drills and exercises and uses weather data to plan evacuations or station isolation during adverse weather. The Chemistry Unit uses meteorological data for chemical spill response activities, marsh management studies, and wastewater discharge flow calculations. Plant Operations uses meteorological data for cooling tower efficiency calcu-lations, Forebay water level availability and plant work which needs certain environmental condi-tions to be met before work begins. Plant Security utilizes weather data in their routine planning and activities. Materials Management plans certain Plant shipments around adverse weather con-ditions to avoid high winds and precipitation, which would cause delays in material deliveries and safety concerns. Industrial Safety uses weather and climate data to advise personnel of unsafe working conditions due to environmental conditions, providing a safer place to work. Regulatory Affairs uses climate data for their investigation into adverse weather accidents in relation to the Plant and personnel.

1. Detailed meteorological information is available upon request.

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Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report On-Site Meteorological Monitoring

System Description

At Davis-Besse there are two meteorological systems, a primary and a backup. Both are housed in separate environmentally controlled buildings with independent power supplies. Both primary and backup systems have been analyzed to be statistically identical, so that if a redundant system in one unit fails, the other system can take its place. The instrumentation of each system follows:

PRIMARY . BACKUP 100 Meter Wind Speed 100 Meter Wind Speed 75 Meter Wind Speed 75 Meter Wind Speed 10 Meter Wind Speed 10 Meter Wind Speed 100 Meter Wind Direction 100 Meter Wind Direction 75 Meter Wind Direction 75 Meter Wind Direction 10 Meter Wind Direction 10 Meter Wind Direction 100 Meter Delta Temperature 100 Meter Delta Temperature 75 Meter Delta Temperature 75 Meter Delta Temperature 10 Meter Ambient Temperature 10 Meter Ambient Temperature 10 Meter Dew Point 10 Meter Solar Incidence Precipitation Meteorological Instrumentation The meteorological system consists of one monitoring site located at an elevation of 577 feet above mean sea level (IGLD 1955)*. It contains a 100 meter (m) free-standing tower located approxi-mately 3,000 feet SSW of the Cooling Tower and a 10m auxiliary tower located 100 feet west of the 100 m tower. Both are used to gather the meteorological data. The 1OOm tower has primary and backup instruments for wind speed and wind direction at 100m and 75m. The 100m tower also measures differential temperature (delta Ts): 100-lOm and 75-lOm. The 10m tower has in-struments for wind speed and wind direction. Precipitation is measured by a tipping bucket rain gauge located near the base of the 1Om tower.

According to the Davis-Besse Nuclear Power Station Technical Requirements Manual, a minimum of five instruments are required to be operable at the two lower levels (75m and 10m) to measure temperature, wind speed, and wind direction. During 2019, average annual data recoveries for all required instruments were greater than 98.9 percent. Minor losses of data occurred during routine instrument maintenance, calibration, and data validation.

Personnel at Davis-Besse inspect the meteorological site and instrumentation regularly. Data is reviewed daily to ensure that all communication pathways, data availability and data reliability are working as required. Tower instrumentation maintenance and semiannual calibrations are per-formed by in-house facilities and by an outside consulting firm. These instruments are wind tunnel tested to assure compliance with applicable regulations and plant specifications.

• International Great Lakes Data - 1955 110

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Meteorological Data Handling and Reduction Each meteorological system, primary and backup, have two Campbell Scientific Data-loggers (model 21XL) assigned to them. The primary system has a first data logger to communicate 900 second averages to the control room via a Digital Alpha computer system. This is a dedicated line.

If a failure occurs at any point between the primary meteorological system and the control room the control room can utilize the second data logger in the primary shelter. Each data logger has its own dedicated communication link with battery backup. The backup meteorological system is designed the same as the primary; so to lose all meteorological data the primary and backup me-teorological systems would have to lose all four data loggers. However, this would be difficult since each is powered by a different power supply and equipped with lightning and surge protec-tion, plus four independent communication lines and data logger battery backup.

The data from the primary and backup meteorological systems are stored in a 30-day circular stor-age module with permanent storage held by the Digital Alpha computer. Data goes back to 1988 in this format and to 1968 in both digital and hardcopy formats. All data points are scrutinized every 900 seconds by meteorological statistics programs running continuously. These are then reviewed by meteorological personnel daily for validity based on actual weather conditions. A monthly review is performed using 21 NRC computer codes, which statistically analyze all data points for their availability and validity. If questionable data on the primary system cannot be corroborated by the backup system, the data in question is eliminated and not incorporated into the final database. All validated data is then documented and stored on hard copy and in digital format for a permanent record of meteorological conditions.

Meteorological Data Summaries This section contains Tables 26-28, which summarize meteorological data collected from the on-site monitoring program in 2019.

Wind Speed and Wind Direction Wind sector graphics represent the frequency of wind direction by sector and the wind speed in mph by sector. This data is used by the NRC to better understand local wind patterns as they relate to defined past climatological wind patterns reported in Davis-Besse's Updated Safety Analysis Report. The maximum sustained wind speeds recorded during 2019 occurred on December 30th, when the 100-meter level was measured at 53.36 mph, and on February 24th, when the 75-meter level was measured at 49.98 mph. The maximum wind speed in 2019 at the IO-meter level oc-curred on February 24th;when it reached 36.65 mph.

Figures 30-32 provide an annual sector graphic of average wind speed and percent frequency by direction measured at the three monitoring levels. Each wind sector graphic has two radial bars.

The darker bar represents the percent of time the wind blew from that direction. The hatched bar represents the average wind speed from that direction. Wind direction sectors are classified using Pasquill Stabilities. Percent calms (less than or equal to 1.0 mph) are shown in the middle of the wind sector graphic.

111

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Ambient and Differential Temperatures Monthly average, minimum and maximum ambient temperatures for 2019 are provided in Table

27. The parameters were measured at the 10m level; with differential temperatures taken from 100m and 75m levels. The yearly average ambient temperature was 51.06°F. The maximum temperature was 92.47°F on July 20th with a minimum temperature of -8.44°F on January 30th.

Yearly average differential temperatures were -0.63°F (100-lOm), and -0.38°F (75-lOm). Maxi-mum differential temperatures for 100-10 meter and 75-lOm levels were 7.98°F on May 9 and 7.97°F on May 18th respectively. Minimum differential temperatures were -3.93°F (100-lOm) and -3.54°F (75-lOm) on December 1. Differential temperatures are a measurement of atmos-pheric stability and used to calculate radioactive plume dispersions based on Gaussian Plume Mod-els of continuous effluent releases.

Dew Point Temperatures and Relative Humidity Monthly average and extreme dew point temperatures for 2019 are not available due to a sensor failure. These data are measured at the 1Om level.

Precipitation Monthly totals and extremes of precipitation at Davis-Besse for 2019 are provided in Table 27.

Total precipitation for the year was 38.30 inches. The maximum daily precipitation total was 1.25 inches on July 4th. There were many days in which no precipitation was recorded. It is likely that precipitation totals recorded in colder months are somewhat less than actual due to snow/sleet blowing across the collection unit rather than accumulating in the gauge.

Lake Breeze and Lake Level Monitoring The "Lake Breeze" condition is monitored at Davis-Besse because of its potential to cause major atmospheric/ dispersion problems during the unlikely event of an unplanned radioactive release.

A lake breeze event can occur during the daytime, usually during the summer, under the conditions in which the land surface heats up faster than the water and reaches warmer temperatures than the temperature of the water. The warmer air above the land rises faster because it is less dense than the cooler air over the lake. This leads to rising air currents over the land with denser cold air descending over the lake. This starts a wind circulation which draws air from the water to the land during the daytime, creating a "Lake Breeze" effect. This event could be problematic if a release were to occur, because diffusion would be slow, thus creating an adverse atmosphere to the area surrounding the site.

Lake and Forebay levels are monitored at Davis-Besse to observe, evaluate, predict and dissemi-nate high or low lake level information. This data is critical to the operation of the plant due to the large amounts of water needed to cool plant components. If water levels get too low, the plant operators can take measures to ensure safe shutdown of the plant. Since Lake Erie is the shallowest of the Great Lakes, it is not uncommon for five feet of lake level fluctuation to occur within an eight to ten hour period (plus or minus). High water levels also affect the plant due to emergency transportation and evacuation routes. A Lake Breeze condition was not identified near Davis-Besse during 2019.

112

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 26 Summary of Meteorological Data Recovery for 2019 Davis-Besse Nuclear Power Station January 1, 2019 through December 31, 2019*

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2019 100m Wind Speed 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.60 98.95 100M Wind Direction 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.60 98.95 75M Wind Speed 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.73 99.96 75M Wind Direction 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.60 98.95 1OM Wind Speed 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.73 98.96 1OM Wind Direction 100 100 99.60 99.86 99.86 100 100 100 100 100 88.06 99.73 98.94 1OM Ambient Air Temp 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.87 98.97 1OM Dew Point Temp 0 0 0 0 0 0 0 0 0 0 0 0 0 Delta T (l00M-lOM) 100 100 99.73 100 100 100 100 100 100 100 88.47 99.60 99.00 Delta T (75M-10M) 100 100 99.73 100 100 100 100 100 100 100 88.47 99.87 99.02 Joint l00M Winds and Delta T (1 00M-1 OM) 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.60 98.95 Joint 75M Winds and Delta T (1 00M-1 OM) 100 100 99.60 99.86 100 100 100 100 100 100 88.19 99.60 98.95 Joint lOM Winds and Delta T (75M-10M) 100 100 99.60 99.86 99.86 100 100 100 100 100 88.06 99.73 98.94

• all data for individual months expressed as percent of time instrument was operable during the month, divided by the maximum number of hours in that month that the instru-ment could be operable. Values for annual data recoveries equals the percent of time instrument was operable during the year, divided by the number of hours in the year that the instrument was operable.

113

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 27 Summary of Meteorological Data Measured for 2019 Davis-Besse Nuclear Power Station January 1, 2019 through December 31, 2019 JAN FEB MAR APR M.A.Y JUN JUL AUG SEP OCT NOV DEC 2019 lO0MWIND Max Speed (mph) 38.94 51.95 42.51 37.15 34.28 33.33 27.74 28.94 28.85 41.85 48.73 53.36 53.36 Date of Max Speed 01/29 02/24 03/10 04/14 05/08 06/13 07/19 08/30 09/22 10/27 11/27 12/30 12/30 Min Speed (mph) 2.35 1.56 2.07 1.16 1.50 1.50 1.32 2.30 1.56 2.00 0.90 2.35 0.90 Date of Min Speed 01/28 02/01 03/02 04/06 05/16 06/21 07/24 08/13 09/27 10/25 11/19 12/07 11/19 Ave Wind Speed 18.71 18.16 16.58 18.04 15.41 14.00 12.29 12.55 13.85 16.42 15.86 17.78 15.79 75MWIND Max Speed (mph) 36.03 49.98 40.64 35.49 33.12 32.68 25.36 26.31 27.64 39.39 47.71 49.53 49.98 Date of Max Speed 01/29 02/24 03/10 04/14 05/08 06/13 07/20 08/30 09/22 10/27 11/27 12/30 02/24 Min Speed (mph) 2.79 1.43 2.25 2.43 1.68 1.97 1.27 1.81 1.69 1.83 0.56 1.86 0.56 Date of Min Speed 01/28 02/01 03/02 04/06 05/16 06/07 07/24 08/20 09/04 10/20 11/19 12/07 11/19 Ave Wind Speed 17.47 16.82 15.27 16.59 14.03 12.88 11.37 11.55 12.63 15.00 14.65 15.97 14.50 lOMWIND Max Speed (mph) 30.65 36.65 30.12 26.31 21.66 21.17 17.49 16.72 17.70 27.52 35.52 32.72 36.65 Date of Max Speed 01/20 02/24 03/10 04/19 05/23 06/13 07/20 08/30 09/22 10/31 11/27 12/30 02/24 Min Speed (mph) 1.23 1.18 0.68 1.17 1.26 0.62 0.74 0.69 1.42 0.30 0.62 0.76 0.30 Date of Min Speed 01/04 02/01 03/27 04/06 05/30 06/07 07/24 08/03 09/16 10/20 11/18 12/14 10/20 Ave Wind Speed 11.66 10.59 9.81 10.85 8.74 7.57 7.05 6.95 6.84 8.43 8.99 9.30 8.89 114

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 27 (continued)

Summary ofMeteorological*Data Measured for 2019 Davis-Besse Nuclear Power Station January 1, 2019 through December 31, 2019 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2019 lOM AMBIENT TEMP Max(F) 54.01 58.71 65.37 73.35 85.18 87.60 92.47 86.47 89.10 86.45 55.27 60.50 92.47 Date of Max 01/07 02/07 03/14 04/18 05/25 06/29 07/20 08/20 09/13 10/01 11/27 12/26 07/20 Min (F) -8.44 4.11 7.73 24.52 45.17 51.47 60.22 58.39 53.21 34.94 8.84 - 11.58 -8.44 Date of Min 01/30 02/01 03/05 04/01 05/04 06/14 07/24 08/29 09/27 10/31 11/13 12/19 01/30 Ave Temp 25.32 29.12 34.35 48.39 58.92 67.93 76.27 72.13 69.40 55.75 36.36 35.47 51.06 lOM DEW POINT TEMP Mean(F) * * * * * * * * * * * *

• Max (F) * * * * * * * * * * * *

• Date of Max * * * * * * * * * * * *

• Min(F) * * * * * * * * * * * *

• Date of Min * * * * * * * * * * * *

• PRECIPITATION Total (inches) 1.33 2.63 3.81 5.23 6.20 4.14 3.52 3.42 2.36 3.73 0.43 1.50 38.30 Max in One Day 0.18 0.26 0.83 0.57 1.12 0.39 1.25 0.78 0.43 0.19 0.06 0.15 1.25 Date 01/14 02/24 03/12 04/05 05/14 06/13 07/04 08/20 09/12 10/26 11/23 12/29 07/04 115

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure 30 Wind Rose Annual Average 100M N

0 s Annual 8667 HRS Wind Direction Frequency (Percent) Mean Wind Speed (MPH)

DAVIS-BESSE ANNUAL 2019 100M LEVEL 116

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure 31 Wind Rose Annual Average 75M N

s Annual 8668 HRS Wind Direction F~uency (Percent) Mean Wind Speed (MPH)

DA VIS-BESSE ANNUAL 2019 75M I.EVEL 117

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Figure 32 Wind Rose Annual Average 1OM N

s Annual 8667 HRS Wind Direction F~uency (Percent) Mean Wind Speed (MPH)

DA VIS-BESSE ANNUAL 2019 IOM LEVEL 118

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 28 Joint Frequency Distribution by Stability Class DAVIS-BESSE NUCLEAR POWER STATION PROGRAM: JFD VERSION: F77-l.0 DAVIS-BESSE 75-10 DT, NO BACKUP SITE IDENTIFIER: 19 DATA PERIOD EXAMINED: 01/0l/19-12/31/19

• • • ANNUAL***

STABILITY CLASS A STABILITY BASED ON: DELTA T BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0 FEET WIND THRESHOLD AT: 1.00 MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 0 1.01 -3.SO 0 0 0 0 0 0 0 0 0 0 0 0 0 3 3.51 - 7.50 0 0 l 2 0 0 1 2 3 2 8 7 30 7.51 - 12.SO 0 0 3 s 1 0 l 0 0 3 14 9 4 14 32 l 87 12.51 - 18.50 0 0 l 0 2 0 0 0 0 21 6 17 21 5 3 77 18.51 -24.00 0 0 0 0 0 0 0 0 0 0 3 4 5 0 0 0 12

>24.00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 TOTAL l 2 4 5 4 3 2 4 40 22 28 43 44 5 209 STABILITY CLASS B STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: l.0OMPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 0 1.01 - 3.50 0 0 0 0 0 0 0 I 0 0 0 0 0 0 0 2 3.51 - 7.50 0 0 0 2 7 3 0 2 3 9 5 2 3 8 5 50 7.51 - 12.50 0 0 15 3 l 0 l 12 32 10 6 9 15 4 110 12.51 - 18.50 0 0 8 0 0 0 0 0 3 17 16 10 5 4 l 65 18.51 - 24.00 0 0 0 2 I 0 0 0 0 0 2 3 2 1 0 0 11

>24.00 0 0 0 0 0 0 0 0 0 0 2 0 0 0 0 3 TOTAL 0 0 2 27 11 4 2 3 18 62 35 21 18 27 10 241 119

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 28 (Continued)

Joint Frequency Distribution by Stability Class DAVIS-BESSE NUCLEAR POWER STATION PROGRAM: JFD VERSION: F77-l.0 DAVIS-BESSE 75-10 DT, NO BACKUP SITE IDENTIFIER: 19 DATA PERIOD EXAMINED: 01/01/19 - 12/31/19

• • • ANNUAL ***

STABILITY CLASS C STABILITY BASED ON: DELTA T BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0 FEET WIND THRESHOLD AT: 1.00 MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE S SSW SW WSW W WNW NW NNW TOTAL CALM 0 1.01 - 3.50 0 0 0 0 0 0 0 I 0 0 0 0 0 0 3 3.51 - 7.50 0 15 15 13 I 0 0 3 14 12 4 4 4 8 95 7.51 - 12.50 0 4 41 9 2 I 0 0 16 41 19 7 8 13 7 169 12.51 - 18.50 0 3 13 0 0 0 0 I 8 31 24 9 8 6 2 106 18.51 - 24.00 2 3 0 2 1 0 0 0 0 0 11 8 2 0 0 0 29

>24.00 0 0 0 0 0 0 0 0 0 0 2 0 0 0 0 0 2 TOTAL 5 3 8 71 25 15 2 27 99 64 22 20 24 17 404 STABILITY CLASS D STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: l.00MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 0 1.01 - 3.50 6 4 15 14 19 12 7 11 10 8 6 7 7 4 4 4 138 3.51 - 7.50 73 66 123 217 183 89 48 46 80 106 91 81 33 41 35 51 1363 7.51 - 12.50 67 114 229 249 121 56 25 12 54 149 164 144 69 56 77 84 1670 12.51 - 18.50 32 70 114 100 27 8 3 8 24 161 141 78 86 73 49 975 18.51 - 24.50 5 18 4 18 3 0 0 0 0 3 74 32 10 10 9 5 191

>24.00 7 II 0 1 0 0 0 5 57 14 4 0 0 3 104 TOTAL 190 283 485 599 353 166 83 70 157 291 553 419 201 197 198 196 4441 120

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 28 (Continued)

Joint Frequency Distribution by Stability Class DAVIS-BESSE NUCLEAR POWER STATION PROGRAM: JFD VERSION: F77-l.0 DAVIS-BESSE 75-10 OT, NO BACKUP SITE IDENTIFIER: 19 DATA PERIOD EXAMINED: 01/01/19- 12/31/19

• • • ANNUAL ***

STABILITY CLASS E STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: l.00MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 1.01-3.50 5 8 11 13 27 29 44 41 47 26 21 16 6 6 8 3 311 3.51 - 7.50 16 40 30 51 94 84 89 75 175 248 127 81 57 25 27 17 1236 7.51 - 12.50 11 9 15 21 41 8 20 20 92 177 134 75 51 21 29 24 748 12.51 - 18.50 5 6 2 0 3 0 4 10 18 10 42 21 12 9 15 8 165 18.51 - 24.00 0 0 0 0 1 0 3 12 7 1 0 29

>24.00 0 0 0 0 0 0 0 0 0 3 2 0 0 0 0 6 TOTAL 38 64 58 85 165 121 158 146 333 465 339 202 127 62 80 52 2496 STABILITY CLASS F STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: l.00MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 6 1.01 - 3.50 3 2 4 4 3 13 25 48 48 35 27 10 13 4 4 2 245 3.51 - 7.50 0 0 0 6 13 22 27 20 84 148 40 21 21 6 1 2 411 7.51 - 12.50 0 0 I 4 5 2 4 1 2 6 2 0 0 0 29 12.51 - 18.50 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 2 18.51 - 24.00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

>24.00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 TOTAL 3 2 5 14 21 37 56 69 134 184 75 33 36 JO 5 4 694 121

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Table 28 (Continued)

Joint Frequency Distribution by Stability Class DAVIS-BESSE NUCLEAR POWER STATION PROGRAM: JFD VERSION: F77-1.0 DAVIS-BESSE 75-10 DT, NO BACKUP SITE IDENTIFIER: 17 DATA PERIOD EXAMINED: 01/01/19 - 12/31/19

• • • ANNUAL ***

STABILITY CLASS G STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: 1.00MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 4 1.01 - 3.50 0 0 9 7 14 17 17 8 5 3 1 0 85 3.51 - 7.50 0 0 0 3 11 13 4 3 30 13 1 3 0 2 0 1 84 7.51 - 12.50 0 0 0 4 2 2 0 0 0 0 0 0 0 0 0 0 8 12.51 - 18.50 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 18.51 - 24.00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

>24.00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 TOTAL 0 0 1 8 14 24 11 17 47 30 9 8 5 181 STABILITY CLASS ALL STABILITY BASED ON: DELTAT BETWEEN 250.0 AND 35.0 FEET WIND MEASURED AT: 35.0FEET WIND THRESHOLD AT: 1.00MPH JOINT FREQUENCY DISTRIBUTION OF WIND SPEED AND DIRECTION IN HOURS AT 35.00 FEET SPEED (MPH) N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW TOTAL CALM 11 1.01 - 3.50 14 15 31 32 50 64 83 116 123 86 62 39 28 17 18 9 787 3.51 - 7.50 91 107 154 294 324 226 170 145 371 522 284 206 119 89 82 85 3269 7.51 - 12.50 79 123 253 339 182 71 52 33 149 358 391 259 138 108 166 120 2821 12.51 - 18.50 38 76 121 121 32 8 7 11 28 45 273 208 127 129 103 63 1390 18.51 - 24.00 8 22 4 22 5 0 1 0 6 102 54 20 12 10 5 272

>24.00 7 11 0 0 0 0 5 2 65 17 4 0 0 3 116 TOTAL 237 354 563 809 593 370 313 305 677 1019 1177 783 436 355 379 285 8666 122

Davis-Besse Nuclear Power Station 2019 Annual Radiological Environmental Operating Report Land and Wetlands Management The Navarre Marsh, which is part of the Ottawa National Wildlife Refuge, makes up 733 acres of wetlands on the southwestern shore of Lake Erie and surrounds the Davis-Besse Nuclear Power Station. The marsh is owned by FirstEnergy and jointly managed by the U.S. Fish and Wildlife Service and FirstEnergy. Navarre Marsh is divided into three pools. The pools are separated from Lake Erie and each other by a series of dikes and revetments. Davis-Besse is responsible for the maintenance and repair of the dikes and controlling the water levels in each of the pools.

A revetment is a retaining structure designed to hold water back for the purposes of erosion control and beach formation. Revetments are built with a gradual slope, which causes waves to dissipate their energy when they strike their large surface area. Beach formation is encouraged through the passive deposition of sediment. A dike is a retaining structure designed to hold water for the purpose of flood control and to aid in the management of wetland habitat. When used as a marsh management tool, dikes help in controlling water levels in order to maintain desired vegetation and animal species. Manipulating water levels is one of the most important marsh management techniques used in the Navarre Marsh. Three major types of wetland communities exist in Navarre Marsh, the freshwater marsh, the swamp forest, and the wet meadow. Also, there exists a narrow dry beach ridge along the lakefront, with a sandbar extending out into Lake Erie. All these areas provide essential food, shelter and nesting habitat, as well as a resting area for migratory birds.

Davis-Besse personnel combine their efforts with a number of conservation agencies and organi-zations. The Ottawa National Wildlife Refuge, the Ohio Department of Natural Resources (ODNR), and the Black Swamp Bird Observatory work to preserve and enhance existing habitat.

Knowledge is gained through research and is used to help educate the public about the importance of preserving wetlands.

With its location along two major migratory flyways, the Navarre Marsh serves as a refuge for a variety of birds in the spring and fall, giving them an area to rest and restore energy reserves before continuing their migration. The Black Swamp Bird Observatory, a volunteer research group, cap-tures, bands, catalogues, and releases songbirds in the marsh during these periods.

Navarre Marsh is also home to wildlife that is typical of much of the marshland in this area, in-cluding deer, fox, coyote, beavers, muskrats, mink, rabbits, groundhogs, hawks, owls, ducks, geese, herons, snakes and turtles. American Bald Eagles chose the Navarre Marsh as a nesting site in late 1994, and fledged a healthy eaglet in July 1995. A second pair built a nest in 1999-2000. Numerous eagles have fledged from these two nests since 1994.

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Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Water Treatment Plant Operation Description The Davis-Besse Nuclear Power Station draws water from Lake Erie for its water treatment plant.

The lake water is treated with sodium hypochlorite and/or sodium bromide, coagulant aid, filtra-tion, electrolysis and demineralization to produce high-purity water used in many of the Station's cooling systems.

Water from the Carroll Township Water Treatment Plant is used in Davis-Besse's Fire Protection System and as a backup supply to the demineralized water production system.

Water Treatment System Raw water from Lake Erie enters an intake structure, then passes through traveling screens which remove debris greater than one-half inch in size. The water is then pumped to chlorine detention tanks. Next, the water is sent to the pre-treatment system, which is comprised of coagulation and filtration to remove sediment, organic debris, and certain dissolved compounds from the raw water.

The next step of the process is reverse osmosis, where pressure is used to remove certain impurities by passing the water through a selectively-permeable membrane. The water is then stripped of dissolved gases, softened, electrolytically deionized and finally, is routed through a polishing de-mineralization process before being sent to storage.

Domestic Water When Davis-Besse began operation over 3 5 years ago, all site domestic water was produced in the Water Treatment Facility. Operation of the domestic water treatment and distribution system, including the collection and analysis of daily samples, was reportable to the Ohio Environmental Protection Agency.

Since December of 1998, the Carroll Township Water Treatment Plant has supplied domestic wa-ter to Davis-Besse. Carroll Township Water and Wastewater District follow all applicable regu-latory requirements for the sampling and analysis of Station drinking water. ,

Zebra Mussel Control With the exception of its domestic water, the Plant withdraws all of its water through an intake system from Lake Erie. Zebra mussels have, in the past, had the potential to severely impact the availability of water for Plant processes. Dreissena polymorpha, commonly known as the zebra mussel, is a native European bivalve that was introduced into the Great Lakes in 1986 and was discovered in Lake Erie in 1989. Zebra mussels are prolific breeders that rapidly colonize an area by forming byssal threads, which enable them to attach to solid surfaces and to each other. Because of their ability to attach in this manner, they may form layers several inches deep. This has posed problems to facilities in the past for water intakes on Lake Erie because mussels attach to the intake structures and restrict water flow. Zebra mussels have not caused any significant problems at Davis-Besse due to effective biocide control. At present, the mussel populations are declining.

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Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Algae Control Lake Erie continues to exhibit changes, and strand-forming blue-green algae has become more prolific during the last few years. Blue-green algae has the potential to cause problems with Cir-culating Water screen plugging and system fouling. Increased addition of oxidants has kept the algae in check thus far, but changes in lake conditions requires constant vigilance to prevent oper-ational challenges.

Wastewater Treatment Plant (WWTP) Operation The WWTP operation is supervised by an Ohio licensed Wastewater Operator. Wastewater gen-erated by site personnel is treated in an onsite extended aeration package treatment facility de-signed to accommodate up to 38,000 gallons per day. In the treatment process, wastewater from the various collection points around the site enters the facility through a grinder, from where it is distributed to the surge tanks of one or both of the treatment plants.

The wastewater is then pumped into aeration tanks, where it is digested by microorganisms. Ox-ygen is necessary for good sewage treatment, and is provided to the microbes by blowers and diffusers. The mixture of organics, microorganisms, and decomposed wastes is called activated sludge. The treated wastewater settles in a clarifier, and the clear liquid leaves the clarifier under a weir and exits the plant through an effluent trough. The activated sludge contains the organisms necessary for continued treatment, and is pumped back to the aeration tank to digest incoming wastewater. The effluent leaving the plant is drained to the wastewater basin (NPDES Outfall 601) where further treatment takes place.

National Pollutant Discharge Elimination System (NPDES) Reporting The Ohio Environmental Protection Agency (OEPA) has established limits on the amount of pol-lutants that Davis-Besse may discharge to the environment. These limits are regulated through the Station's National Pollutant Discharge Elimination System (NPDES) permit. Permit number 2IB00011 *KD has an effective date of May 1, 2018 and is valid for 5 years from the effective date. Parameters such as chlorine, suspended solids and pH are monitored under the NPDES per-mit. Davis-Besse personnel prepare the NPDES Reports and submit them to the OEPA each month.

Davis-Besse has eight sampling points described in the NPDES permit. Seven of these locations are discharge points/outfalls or Internal Monitoring Stations, and one is a temperature monitoring location. Descriptions of these sampling points follow:

Outfall 001 Collection Box: a point representative of discharge to Lake Erie Source of Wastes: Low volume wastes (Outfalls 601 and 602), Circulating Water system blow-down and Service Water Outfall 002 Area Runoff: Discharge to Toussaint River Source of Wastes: Storm water runoff, Circulating Water pump house sumps 125

Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Outfall 003 Screenwash Catch Basin: Outfall to Navarre Marsh Source of Wastes: Backwash water and debris from water intake screens Outfall 004/005 Cooling Tower Basin Ponds: Outfall to State Route 2 Ditch Source of Wastes: Circulating Water System drain (only during system outages)

Sludge Monitoring 588 Sludge Monitoring Source of Wastes: Wastewater Plant sludge shipped for offsite processing Internal Monitoring Station 601 Wastewater Plant Tertiary Treatment Basin: Discharge from Wastewater Treatment Plant Sources of Wastes: Wastewater Treatment Plant Internal Monitoring Station 602 Low volume wastes: Discharge from settling basins Sources of wastes: Water treatment residues, Condensate Polishing Holdup Tank decants and Condensate Pit sumps Intake Monitoring 801 Intake temperature: Intake water prior to cooling operation 2019 NPDES Summary During 2019, Davis-Besse Nuclear Power Station had one exceedance of the NPDES permit.

The exceedance came from Outfall 001 which identified Total residual oxidants (TRO) con-centration of 0.057 mg/1- which exceeded the NPDES limit of 0.050 mg/1. The chlorination system was immediately secured to prevent further oxidants from reaching the Outfall 001. A problem-solving team performed a failure mode analysis to identify the cause of the exceed-ance. From the failure mode analysis, the problem-solving team created a Corrective action plant to avoid future exceedances.

Chemical Waste Management The Chemical Waste Management Program for hazardous and nonhazardous chemical wastes gen-erated at the Davis-Besse Nuclear Power Station was developed to ensure wastes are managed and disposed of in accordance with all applicable state and federal regulations.

126

Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Resource Conservation and Recovery Act The Resource Conservation and Recovery Act (RCRA) is the statute which regulates solid haz-ardous waste. Solid waste is defined as a solid, liquid, semi-solid, or contained gaseous material.

The major goals of RCRA are to establish a hazardous waste regulatory program to protect human health and the environment and to encourage the establishment of solid waste management, re-source recovery, and resource conservation systems. The intent of the hazardous waste manage-ment program is to control hazardous wastes from the time they are generated until they are properly disposed of, commonly referred to as "cradle to grave" management. Anyone who gen-erates, transports, stores, treats, or disposes of hazardous waste are subject to regulation under RCRA.

Under RCRA, there are essentially three categories of waste generators:

• Large quantity Generators - A facility which generates 1,000 kilograms/month (2,200 lbs./month) or more. '

• Small quantity Generators - A facility which generates less than 1,000 kilograms/

month (2,200 lbs./month).

• Conditionally Exempt Small Quantity Genera{ors - A facility which generates 100 kilo-grams/month (220 lbs./month).

In 2019, the Davis-Besse Nuclear Power Station generated approximately 1,701 pounds of haz-ardous waste. The site's total hazardous waste quantity for 2019 was 1,701 pounds.

Non-hazardous waste generated in 2019 included 3,017 gallons of used oil and 10,485 pounds of other nonhazardous wastes such as oil filters, resins and caulks. The total amount of non-hazard-ous waste from DBNPS in 2019 was-approximately 10,485 pounds.

RCRA mandates other requirements such as the use of proper storage and shipping containers, labels, manifests, reports, personnel training, a spill control plan and an accident contingency plan. These are part of the Chemical Management Program at Davis-Besse. The following are completed as part of the hazardous waste management program and RCRA regulations:

• Weekly Inspections of the Chemical Waste Accumulation Areas are designated throughout the site to ensure proper handling and disposal of chemical waste. These, along with the Chemical Waste Storage Area, are routinely patrolled by security personnel and inspected weekly by Environmental and Chemistry personnel. All areas used for storage or accumu-lation of hazardous waste are posted with warning signs and drums are color-coded for easy identification of waste categories.

• Waste Inventory Forms are placed on waste accumulation drums or provided in the accu-mulation area for employees to record the waste type and amount when chemicals are added to the drum. This ensures that incompatible wastes are not mixed and also identifies the drum contents for proper disposal.

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Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Other Environmental Regulating Acts Comprehensive Environmental Response, Compensation and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Su-perfund) established a federal authority and source of funding for responding to spills and other releases of hazardous materials, pollutants and* contaminants into the environment. Superfund establishes "reportable quantities" for several hundred hazardous materials and regulates the cleanup of abandoned hazardous waste disposal sites.

Superfund Amendment and Reauthorization Act (SARA)

Superfund was amended in October 1986 to establish new reporting programs dealing with emer-gency preparedness and community right-to-know laws. As part of this program, CERCLA is enhanced by ensuring that the potential for release of hazardous substances is minimized, and that adequate and timely responses are made to protect surrounding populations.

Davis-Besse conducts site-wide inspections to identify and record all hazardous products and chemicals onsite as required by SARA. Determinations are made as to which products and chem-icals are present in reportable quantities.

Annual SARA reports are submitted to local fire departments and state and local planning com-missions by March 1 for the preceding calendar year.

Toxic Substances Control Act (TSCA)

The Toxic Substance Control Act (TSCA) was enacted to provide the USEPA with the authority to require testing of new chemical substances for potential health effects before they are introduced into the environment, and to regulate them where necessary. This law would have little impact on utilities except for the fact that one family of chemicals, polychlorinated biphenyls (PCBs), has been singled out by TSCA. This has resulted in an extensive PCB management system, very similar to the hazardous waste management system established under RCRA.

In 1992, Davis-Besse completed an aggressive program that eliminated PCB transformers onsite.

PCB transformers were either changed out with non-PCB fluid transformers or retrofilled with non-PCB liquid.

Retro-filling PCB transformers involves flushing the PCB fluid out of a transformer, refilling it with PCB-leaching solvents and allowing the solvent to circulate in the transformer during operation. The entire retro-fill process takes several years and will extract almost all of the PCB.

In all, Davis-Besse performed retro-fill activities on eleven PCB transformers between 1987 and 1992. The only remaining PCB containing equipment onsite are a limited number of capacitors.

These capacitors are being replaced and disposed of during scheduled maintenance activities.

128

Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Clean Air Act The Clean Air Act identifies substances that are considered air pollutants. Davis-Besse holds an OEPA permit to operate an Air Contaminant Source for the station Auxiliary Boiler. This boiler is used to heat the station and provide steam to plant systems when the reactor is not operating.

The Ohio EPA has granted an exemption from permitting the seven Davis-Besse diesel engines, including the Station Blackout Diesel Generator, the 2 Emergency Diesel Generators, the Emer-gency Response Facility Diesel Generator; the Miscellaneous Diesel, the Fire Pump Diesel, and the Diesel Driven Emergency Feedwater Pump. These sources are operated infrequently to verify their reliability, and would only be used in the event of an emergency. A report detailing the operation of these air emission sources is submitted biennially.

In response to "Clean Air Act Title V" legislation, an independent study identifying and quantify-ing all of the air pollution sources onsite was performed. Of particular significance is asbestos removal from renovation and demolition projects for which USEPA has outlined specific regula-tions concerning handling, removal, environmental protection, and disposal. Also, the Occupa-tional Safety and Health Protection Administration (OSHA) strictly regulates asbestos with a con-cern for worker protection. Removal teams must meet medical surveillance, respirator fit tests, and training requirements prior to removing asbestos-containing material. Asbestos is not consid-ered a hazardous waste by RCRA, but the EPA does require special handling and disposal of this waste under the Clean Air Act.

Transportation Safety Act The transportation of hazardous chemicals, including chemical waste, is regulated by the Trans-portation Safety Act of 1976. These regulations ate enforced by the United States Department of Transportation (DOT) and cover all aspects of transporting hazardous materials, including pack-ing, handling, labeling, marking, and placarding. Before any wastes are transported off site, Davis-Besse must ensure that the wastes are identified, labeled and marked according to DOT regula-tions, including verification that the vehicle has appropriate placards and it is in good operating condition.

Other Environmental Programs Underground Storage Tanks According to RCRA, facilities with Underground Storage Tanks (USTs) are required to notify the State. This regulation was implemented in order to provide protection from tank contents leaking and causing damage to the environment. Additional standards require leak detection systems and performance standards for new tanks. At Davis-Besse, two 40,000 gallon and one 8,000 gallon diesel fuel storage tanks are registered USTs.

129

Davis-Besse Nuclear Power Station 2018 Annual Radiological Environmental Operating Report Spill Kits Spill control equipment is maintained throughout the Station at chemical storage areas and haz-ardous chemical and oil use areas. Equipment in the kits may include chemical-resistant coveralls, gloves, boots, decontamination agents, absorbent cloth, goggles and warning signs.

Waste Minimization and Recycling Municipal Solid Waste (MSW) is normal trash produced by individuals at home and by industries.

In some communities, MSW is burned in specially designed incinerators to produce power or is separated into waste types (such as aluminum, glass, and paper) and recycled. The vast majority of MSW is sent to landfills for disposal. As the population increases and older landfills reach their capacity, MSW disposal becomes an important economic, health, and resource issue.

The State of Ohio has addressed the issue with the State Solid Waste Management Plan, otherwise known as Ohio House Bill 592. The intent of the bill is to extend the life of existing landfills by reducing the amount of MSW produced, by reusing certain waste material, and by recycling other wastes. This is frequently referred to as "Reduce, Reuse, and Recycle."

Davis-Besse has implemented and participated in company wide programs that emphasize the re-duction, reuse, recycle approach to MSW management. An active Investment Recovery Program has greatly contributed to the reduction of both hazardous and municipal waste generated by eval-uating options for uses of surplus materials prior to the materials entering Davis-Besse's waste streams. Such programs include aluminum cans, used tires, and metals recycling or recovery.

Aluminum soft drink cans are collected for the Boy Scouts of America to recycle. Additionally, lead-acid batteries are recycled and tires are returned to the seller for proper disposal.

Although scrap metal is not usually considered part of the MSW stream, Davis-Besse collects and recycles scrap metals, which are sold at market price to a scrap dealer for resource recovery.

130

llt'-- ATI Environmental,

~li: r\l Midwest Laboratory Inc.

700 Landwehr Read* Northbrook, IL 60062-2310 phone (847) 584-0700

• tax (847) 584-4517 APPENDIX A INTERLABORATORY AND INTRALABORATORY COMPARISON PROGRAM RESULTS NOTE: Appendix A is updated four times a year. The complete appendix is included in March, June, September and December monthly progress reports only.

January, 2019 through December, 2019 131

Appendix A lnterlaboratory/ lntralaboratory Comparison Program Results Environmental, Inc., Midwest Laboratory has participated in interlaboratory comparison (crosscheck) programs since the formulation of it's quality control program in December 1971. These programs are operated by agencies which supply environmental type samples containing concentrations of radionuclides known to the issuing agency but not to participant laboratories. The purpose of such a program is to provide an independent check on a laboratory's analytical procedures and to alert it of any possible problems.

Participant laboratories measure the concentration of specified radionuclides and report them to the issuing agency. Several months later, the agency reports the known values to the participant laboratories and specifies control limits. Results consistently higher or lower than the known values or outside the control limits indicate a need to check the instruments or procedures used.

Results in Table A-1 were obtained through participation in the RAD PT Study Proficiency Testing Program administered by Environmental Resource Associates, serving as a replacement for studies conducted previously by the U.S. EPA Environmental Monitoring Systems Laboratory, Las Vegas, Nevada.

Results in Table A-2 were obtained through participation in the New York Department of Health Environmental Laboratory Approval Program (ELAP) PT Table A-3 lists results for thermoluminescent dosimeters (TLDs), via irradiation and evaluation by the University of Wisconsin-Madison Radiation Calibration Laboratory at the University of Wisconsin Medical Radiation Research Center.

Table A-4 lists results of the analyses on in-house "spiked" samples for the past twelve months. All samples are prepared using NIST traceable sources. Data for previous years available upon request.

Table A-5 lists results of the analyses on in-house "blank" samples for the past twelve months. Data for previous years available upon request.

Table A-6 lists analytical results from the in-house "duplicate" program for the past twelve months. Acceptance is based on the each result being with 25% of the mean of the two results or the two sigma uncertanties of each result overlap.

The results in Table A-7 were obtained through participation in the Mixed Analyte Performance Evaluation Program.

Results in Table A-8 were obtained through participation in the MRAD PT Study Proficiency Testing Program administered by Environmental Resource Associates, serving as a replacement for studies conducted previously by the Environmental Measurement Laboratory Quality Assessment Program (EML).

Attachment A lists the laboratory acceptance criteria for various analyses.

Out-of-limit results are explained directly below the result.

132

7 Attachment A ACCEPTANCE CRITERIA FOR "SPIKED" SAMPLES Analysis Ratio of lab result to known value.

Gamma Emitters 0.8to1.2 Strontium-89, 0.8to1.2 Strontium-90 Potassium-40 0.8 to 1.2 Gross alpha 0.5 to 1.5 Gross beta 0.8 to 1.2 Tritium 0.8 to 1.2 Radium-226, 0.7 to 1.3 Radium-228 Plutonium 0.8 to 1.2 lodine-129, 0.8 to 1.2 lodine-131 Nickel-63, 0.7 to 1.3 Technetium-99, Uranium-238 lron-55 0.8 to 1.2 Other Analyses 0.8 to 1.2 133

TABLE A-1. lnterlaboratory Comparison Crosscheck program, Environmental Resource Associates (ERA)8.

RAD study Concentration (pCi/L)

Lab Code Date Analysis Laboratory ERA Control Result Result Limits Acceptance ERW-71 1/7/2019 Ba-133 97.9 +/-4.5 99.5 84.1 -109 Pass ERW-71 117/2019 Cs-134 45.4 +/- 3.1 49.1 39.5 - 54.0 Pass ERW-71 1/7/2019 Cs-137 129 +/-6 125 112 -140 Pass ERW-71 1/7/2019 Co-60 98.1 +/- 4.1 96.4 86.8 - 108 Pass ERW-71 1/7/2019 Zn-65 80.4 +/- 7.8 77.4 69.5 +/- 93.2 Pass ERW-73 1/7/2019 Gr. Alpha 22.2 +/- 1.6 21.8 10.9 -29.5 Pass ERW-73 1/7/2019 Gr. Beta 46.4 +/- 1.4 55.7 38.1 -62.6 Pass ERW-75 117/2019 Ra-226 7.19 +/- 0.30 7.37 5.55 +/-8.72 Pass ERW-75 117/2019 Ra-228 4.02 +/-0.70 4.28 2.48 -5.89 Pass ERW-75 117/2019 Uranium 50.2 +/- 2.9 68.2 55.7 - 75.0 Failb ERW-77 1/7/2019 H-3 2,129 +/- 158 2,110 1,740 - 2,340 Pass ERW-397 2/11/2019 1-131 27.2 +/- 1.0 25.9 25.1 -30.6 Pass ERW-1141 4/8/2019 Ra-226 7.58 +/- 0.53 7.15 5.39 -8.48 Pass ERW-1141 4/8/2019 Ra-228 2.64 +/- 0.79 2.94 1.54 -4.35 Pass ERW-1141 4/8/2019 Uranium 67.0 +/- 0.9 55.9 45.6 - 61.5 Failc ERW-2471 7/8/2019 Ba-133 66.5 +/-4.0 66.9 55.8 - 73.6 Pass ERW-2471 7/8/2019 Cs-134 29.6 +/- 2.6 32.0 25.1 - 35.2 Pass ERW-2471 7/8/2019 Cs-137 21.3 +/- 3.6 21.4 17.6 - 26.7 Pass ERW-2471 7/8/2019 Co-60 99.9 +/- 4.4 95.1 85.6 -107.0 Pass ERW-2471 7/8/2019 Zn-65 43.7 +/-6.2 41.2 35.3 - 51.4 Pass ERW-2473 7/8/2019 Gr. Alpha 41.7 +/- 2.1 70.6 37.1 - 87.1 Pass ERW-2473 7/8/2019 Gr. Beta 57.0 +/- 1.6 63.9 44.2 - 70.5 Pass ERW-2477 7/8/2019 Ra-226 16.2 +/- 0.5 18.5 13.8-21.1 Pass ERW-2477 7/8/2019 Ra-228 6.2 +/-0.8 8.2 5.2 -10.3 Pass ERW-2477 7/8/2019 Uranium 63.8 +/-3.6 68.3 55.8 - 75.1 Pass ERW-2479 7/8/2019 H-3 8,630 +/-200 16,700 14,600 - 18,400 Faild ERW-2475 7/8/2019 1-131 33.6+/-1.3 29.6 24.6 - 34.6 Pass

• Results obtained by Environmental, Inc., Midwest Laboratory as a participant In the crosscheck program for proficiency testing In drinking water conducted by Environmental Resource Associates (ERA).

b In order to get to the root cause of the above "Fail" resolution the U-232 tracer was standardized using a known concentration of NIST U-238 solution. A duplicate analysis was performed and the results obtained were well within the acceptance range (Known value for Total Uranium=68.2 pCI/L, acceptance range of (55.7-75 pCi/L). The results obtained were 63.3 pCi/L and 66.0 pCi/L respectively.

e The standardized U-232 value utilized on ERA sample ERW-1141 above was found to be estimated high due to interferences in the U-238 solution causing ERW-1141 to fail the study. After performing U-isotopic chemistry on the NIST-Uranium solution to remove interferences a more accurate U-232 tracer concentration was obtained.

The Uranium result In the subsequent ERA PT study was acceptable. See ERW-2477 Uranium result above.

d EIML's routine H-3 analysis does include a blank sample. The ERA provided blank was paired with a H-3 standard vial and EIML's blank was also paired with a standard vial. Inadvertently the efficiency was overestimated by a factor of 2.

This understated the calculated results by half. The result of reanalysis (17,400 pCi/L) is within the control limits for the study.

134

TABLE A-2. lnterlaboratory Comparison Crosscheck program, New York Department of Health (ELAP) 8

• Concentration (pCi/L)

Lab Code Date Analysis Labora~ory Assigned Acceptance Result Value Limits Acceptance Shipment 427R NYW-3472 9/17/2019 H-3 5250 +/- 229 4991 4280 - 5490 Pass NYW-3476 9/17/2019 Gross Alpha 18.0+/-1.2 20.1 9.99 - 27.5 Pass NYW-3476 9/17/2019 Gross Beta *22.7+/-1.0 27.2 17.1 - 35.1 Pass NYW-3478 9/17/2019 1-131 18.7+/-1.8 15.6 12.8 -19.3 Pass NYW-3480 9/17/2019 Ra-226 5.02 +/- 0.37 4.41 3.37 - 5.43 Pass NYW-3480 9/17/2019 Ra-228 16.0+/-1.9 18.3 12.3 - 21.9 Pass NYW-3480 9/17/2019 Uranium 13.7 +/- 0.9 13.9 11.0 -15.7 Pass NYW-3482 9/17/2019 Co-60 63.9 +/-4.0 63.0 56.7 - 71.8 Pass NYW-3482 9/17/2019 Zn-65 108 +/-9 113 97.2 - 129 Pass NYW-3482 9/17/2019 Ba-133 53.3 +/-4.3 61.9 51.4 - 68.2 Pass NYW-3482 9/17/2019 Cs-134 47.2 +/- 3.4 55.8 45.1 -61.4 Pass NYW-3482 9/17/2019 Cs-137 52.0 +/-4.6 53.8 48.4 - 62.0 Pass

• Results obtained by Environmental, Inc., Midwest Laboratory as a participant in the crosscheck program for proficiency testing in drinking water conducted by the New York Department of Health Laboratory Approval Program(NY ELAP).

135

8 TABLE A-3. Thermoluminescent Dosimetry, (TLD, CaSO 4 : Dy Cards).

mrem Lab Code Irradiation Delivered Reportedb Performancec Date Description Dose Dose Quotient {P)

Environmental. Inc. Group 1 2019-1 11/11/2019 Spike 1 126.0 128.3 0.02 2019-1 11/11/2019 Spike 2 126.0 122.2 -0.03 2019-1 11/11/2019 Spike 3 126.0 122.5 -0.03 2019-1 11/11/2019 Spike 4 126.0 119.3 -0.05 2019-1 11/11/2019 Spike 5 126.0 116.9 -0.07 2019-1 11/11/2019 Spike 6 126.0 109.5 -0.13 2019-1 11/11/2019 Spike 7 126.0 114.6 -0.09 2019-1 11/11/2019 Spike 8 126.0 121.8 -0.03 2019-1 11/11/2019 Spike 9 126.0 120.2 -0.05 2019-1 11/11/2019 Spike 10 126.0 126.4 0.00 2019-1 11/11/2019 Spike 11 126.0 125.0 -0.01 2019-1 11/11/2019 Spike 12 126.0 109.0 -0.13 2019-1 11/11/2019 Spike 13 126.0 123.4 -0.02 2019-1 11/11/2019 Spike 14 126.0 118.2 -0.06 2019-1 11/11/2019 Spike 15 126.0 134.3 0.07 2019-1 11/11/2019 Spike 16 126.0 120.1 -0.05 2019-1 11/11/2019 Spike 17 126.0 131.3 0.04 2019-1 11/11/2019 Spike 18 126.0 120.4 -0.04 2019-1 11/11/2019 Spike 19 126.0 121.1 -0.04 2019-1 11/11/2019 Spike 20 126.0 122.8 -0.03 Mean (Spike 1-20) 121.4 -0.04 Passd Standard Deviation (Spike 1-20) 6.2 0.05 Passd a TLD's were irradiated by the University of Wisconsin-Madison Radiation Calibration Laboratory following ANSI N13.37 protocol from a known air kerma rate. TLD's were read and the results were submitted by Environmental Inc. to the University of Wisconsin-Madison Radiation Calibration Laboratory for comparison to the delivered dose.

b Reported dose was converted from exposure (R) to Air Kerma (cGy) using a conversion of 0.876. Conversion from air kerma to ambient dose equivalent for Cs-137 at the reference dose point H*(1 0)Ka = 1.20 . mrem/cGy = 1000.

c Performance Quotient (P) is calculated as ((reported dose - conventially true value) + conventially true value) where the conventially true value is the delivered dose.

d Acceptance is achieved when neither the absolute value of the mean of the P values, nor the standard deviation of the P values exceed 0.15.

136

8 TABLE A-3. Thermoluminescent Dosimetry, (TLD, CaSO 4 : Dy Cards).

mrem Lab Code Irradiation Delivered Reportedb Performancec Date Description Dose Dose Quotient (P)

Environmental, Inc. Group 2 2019-2 11/11/2019 Spike 21 79.0 78.8 0.00 2019-2 11/11/2019 Spike 22 79.0 71.8 -0.09 2019-2 11/11/2019 Spike 23 79.0 75.8 -0.04 2019-2 11/11/2019 Spike 24 79.0 71.3 -0.10 2019-2 11/11/2019 Spike 25 79.0 74.5 -0.06 2019-2 11/11/2019 Spike 26 79.0 71.6 -0.09 2019-2 11/11/2019 Spike 27 79.0 73.3 -0.07 2019-2 11/11/2019 Spike 28 79.0 74.0 -0.06 2019-2 11/11/2019 Spike 29 79.0 73.8 -0.07 2019-2 11/11/2019 Spike 30 79.0 76.0 -0.04 2019-2 11/11/2019 Spike 31 79.0 76.7 -0.03 2019-2 11/11/2019 Spike 32 79.0 77.8 -0.02 2019-2 11/11/2019 Spike 33 79.0 75.2 -0.05 2019-2 11/11/2019 Spike 34 79.0 69.1 -0.13 2019-2 11/11/2019 Spike 35 79.0 68.7 -0.13 2019-2 11/11/2019 Spike 36 79.0 68.2 -0.14 2019-2 11/11/2019 Spike 37 79.0 67.9 -0.14 2019-2 11/11/2019 Spike 38 79.0 68.9 -0.13 2019-2 11/11/2019 Spike 39 79.0 78.1 -0.01 2019-2 11/11/2019 Spike 40 79.0 68.6 -0.13 Mean (Spike 21-40) 73.0 -0.08 Passd Standard Deviation (Spike 21-40) 3.6 0.05 Passd a TLD's were irradiated by the University of Wisconsin-Madison Radiation Calibration Laboratory following ANSI N13.37 protocol from a known air kerma rate. TLD's were read and the results were submitted by Environmental Inc. to the University of Wisconsin-Madison Radiation Calibration Laboratory for comparison to the delivered dose.

b Reported dose was converted from exposure (R) to Air Kerma (cGy) using a conversion of 0.876. Conversion from air kerma to ambient dose equivalent for Cs-137 at the reference dose point H*(1 0)Ka =1.20 . mrem/cGy =1000.

c Performance Quotient (P) is calculated as ((reported dose - conventially true value) + conventially true value) where the conventially true value is the delivered dose.

d Acceptance is achieved when neither the absolute value of the mean of the P values, nor the standard deviation of the P values exceed 0.15.

137

TABLE A-4. In-House "Spiked" Samples Concentration" Lab Codeb Date Analysis Laboratory results Known Control Ratio 2s, n=1° Activi!}'. Limitsd Acceetance Lab/Known SPW-61 1/5/2019 Ra-226 13.4 +/- 0.4 12.3 9.8 - 14.8 Pass 1.09 SPW-118 1/14/2019 H-3 15,463 +/- 369 16,507 13,206 - 19,808 Pass 0.94 SPW-178 1/16/2019 Ra-228 17.7+/-2.1 15.1 12.10 -18.14 Pass 1.17 SPW-199 1/18/2019 Sr-90 17.6 +/- 1.2 17.9 14.3 - 21.5 Pass 0.98 SPW-250 1/24/2019 Ni-63 356.3 +/- 44.5 465 326 -605 Pass 0.77 SPW-256 1/15/2019 Ra-226 12.0 +/- 0.4 12.3 9.8 - 14.8 Pass 0.98 SPW-271 3/18/2019 H-3 22,035 +/- 450 21,700 17,360 - 26,040 Pass 1.02 SPW-281 1/25/2019 Ra-226 11.6 +/- 0.4 12.3 9.8 - 14.8 Pass 0.94 W-012119 4/29/2016 Cs-134 37.3 +/- 10.6 36.2 29.0 -43.4 Pass 1.03 W-012119 4/29/2016 Cs-137 82.7 +/- 8.0 71.9 57.5 -86.3 Pass 1.15 '

W-012319 4/29/2016 Cs-134 33.4 +/- 10.1 36.2 25.3 -47.1 Pass 0.92 W-012319 4/29/2016 Cs-137 79.1 +/- 9.6 71.9 57.5 - 86.3 Pass 1.10 ,

W-012519 4/29/2016 Cs-134 35.0 +/- 7.7 36.2 29.0 -43.4 Pass 0.97 W-012519 4/29/2016 Cs-137 79.2 +/- 7.9 71.9 57.5 - 86.3 Pass 1.10 W-012919 4/29/2016 Cs-134 32.3 +/- 8.3 36.2 29.0 -43.4 Pass 0.89 W-012919 4/29/2016 Cs-137 82.3 +/- 8.3 71.9 57.5 - 86.3 Pass 1.14 SPW-370 3/19/2019 H-3 21,689 +/- 444 21,700 17,360 - 26,040 Pass 1.00 SPW-400 1/31/2019 Ra-226 11.6 +/- 0.4 12.3 8.6 -16.0 Pass 0.95 SPW-461 2/12/2019 Ra-226 11.1 +/- 0.4 12.3 8.6 - 16.0 Pass 0.90 W-020619 4/26/2016 Cs-134 35.0 +/- 14.9 36.2 29.0 -43.4 Pass 0.97 W-020619 4/29/2016 Cs-137 72.8 +/- 8.9 71.9 57.5 - 86.3 Pass 1.01 W-020819 4/26/2016 Cs-134 36.7 +/- 8.6 36.2 29.0 -43.4 Pass 1.01 W-020819 4/29/2016 Cs-137 76.7 +/- 8.7 71.9 57.5 -86.3 Pass 1.07 SPW-568 2/21/2019 Ra-226 10.3 +/- 0.3 12.3 8.6 -16.0 Pass 0.84 W-021319 4/29/2016 Cs-134 37.7 +/- 11.5 36.2 29.0 -43.4 Pass 1.04 W-021319 4/26/2016 Cs-137 75.8 +/- 9.6 71.9 57.5 -86.3 Pass 1.05 SPW-469 3/19/2019 H-3 21,696 +/- 447 21,700 17,360 - 26,040 Pass 1.00 SPW-600 3/6/2019 H-3 20,710 +/- 425 21,700 17,360 -26,040 Pass 0.95 SPW-837 3/21/2019 Ra-228 11.7 +/- 1.5 15.1 10.58 - 19.66 Pass 0.78 SPW-709 3/19/2019 H-3 20,369 +/- 421 21,700 17,360 - 26,040 Pass 0.94 SPW-818 3/19/2019 H-3 20,457 +/- 424 21,700 17,360 - 26,040 Pass 0.94 SPW-845 3/22/2019 U-234 15.1 +/- 0.5 13.6 9.5 -17.7 Pass 1.11 SPW-845 3/22/2019 U-238 15.3 +/- 0.5 13.1 9.2 -17.0 Pass 1.17 SPW-934 3/19/2019 H-3 20,487 +/- 421 21,700 17,360 - 26,040 Pass 0.94 SPW-1061 3/1/2019 Ra-226 10.6 +/- 0.3 12.3 8.6 - 16.0 Pass 0.86 SPW-1091 4/10/2019 H-3 20,323 +/- 421 21,700 17,360 - 26,040 Pass 0.94 SPW-1093 4/8/2019 Ra-228 14.9 +/- 1.9 15.1 10.6 -19.6 Pass 0.98 SPW-1267 4/16/2019 H-3 20,302 +/- 421 21,700 17,360 - 26,040 Pass 0.94 SPW-1339 4/18/2019 H-3 19,924 +/- 417 21,700 17,360 - 26,040 Pass 0.92 SPW-1403° 4/25/2019 Gr. Alpha 56.7 +/- 2.6 72.4 36.2 -108.6 Pass 0.78 SPW-1403° 4/25/2019 Gr. Beta 43.2 +/- 1.4 54.8 43.8 - 65.8 Fail 0.79 SPW-1427 4/26/2019 H-3 20,119 +/-418 21,700 15,190 - 28,210 Pass 0.93 SPW-1537 5/6/2019 Sr-90 19.9+/-1.2 17.9 14.3 - 21.5 Pass 1.11 W-050719 4/29/2016 Cs-134 38.5 +/- 9.0 36.2 29.0 -43.4 Pass 1.06 W-050719 4/26/2016 Cs-137 85.2 +/- 8.5 71.9 57.5 - 86.3 Pass 1.18 SPW-1582 5/9/2019 H-3 20,492 +/- 423 21,700 15,190 - 28,210 Pass 0.94 138

TABLE A-4. In-House "Spiked" Samples Concentration" Lab Codeb Date Analysis Laboratory results Known Control Ratio 2s, n=1° Activit:z: Limitsd Acee eta nee Lab/Known W-050919 4/29/2016 Cs-134 37.4 +/- 8.9 36.2 29.0 - 43.4 Pass 1.03 W-050919 4/26/2016 Cs-137 81.5 +/- 7.8 71.9 57.5 - 86.3 Pass 1.13 SPW-1596 5/8/2019 Ra-228 14.1 +/- 1.7 15.1 10.6 -19.6 Pass 0.94 W-051419 4/29/2016 Cs-134 36.2 +/- 11.7 36.2 29.0 - 43.4 Pass 1.00 W-051419 4/26/2016 Cs-137 75.8 +/- 10.0 71.9 57.5 - 86.3 Pass 1.05 SPW-1676 5/17/2019 H-3 20,233 +/- 420 21,700 15,190 - 28,210 Pass 0.93 SPW-1799 5/20/2019 H-3 20,428 +/- 422 21,700 15,190 -28,210 Pass 0.94 SPW-1858 5/28/2019 H-3 20,367 +/- 522 21,700 15,190 - 28,210 Pass 0.94 SPW-1890 5/30/2019 H-3 20,206 +/- 419 21,700 15,190 -28,210 Pass 0.93.

SPW-2014 5/31/2019 Ra-226 - 11.9 +/- 0.3 12.3 8.6 - 16.0 Pass 0.97 SPW-2030 6/12/2019 Ni-63 377 +/- 45 464.8 325 -604 Pass 0.81 SPW-2093 6/18/2019 H-3 20,158 +/-418 21,700 17,360 -.26,040 Pass 0.93

• W-062419 4/29/2016 Cs-134 33.0 +/- 12.4 36.2 29.0 -43.4 Pass 0.91 W-062419 4/26/2016 Cs-137 66.0 +/- 10.4 71.9 57.5 -86.3 Pass 0.92 SPW-2338 6/26/2019 H-3 20,032 +/- 417 21,700 17,360 - 26,040 Pass 0.92 SPW-2552 7/1/2019 Gr. Alpha 20.4 +/- 1.5 21.8 10.9 - 32.7 Pass 0.94 SPW-2552 7/1/2019 Gr. Beta 46.1 +/- 1.3 55.7 44.6 -66.8 Pass 0.83 W-072619 4/29/2016 Cs-134 36.3 +/- 9.2 36.2 29.0 - 43.4 Pass 1.00 W-072619 4/26/2016 Cs-137 79.7 +/- 7.6 71.9 57.5 - 86.3 Pass 1.11 SPW-3188 7/30/2019 Ra-226 11.9 +/- 0.3 12.3 8.6 -16.0 Pass 0.97 SPW-2947 8/9/2019 H-3 20,128 +/- 425 21,700 17,360 - 26,040 Pass 0.93 SPW-3003 8/14/2019 H-3 20,588 +/- 435 21,700 17,360 - 26,040 Pass 0.95 W-081519 4/26/2019 Cs-134 36.2 +/- 9.2 36.2 29.0 -43.4 Pass 1.00 W-081519 4/26/2019 Cs-137 78.1 +/- 8.4 71.9 57.5 -86.3 Pass 1.09 W-082119 4/26/2019 Cs-134 32.8 +/- 9.1 36.2 29.0 -43.4 Pass 0.91 W-082119 4/26/2019 Cs-137 79.1 +/-7.9 71.9 57.5 -86.3 Pass 1.10 SPW-3151 8/26/2019 H-3 20,329 +/- 428 21,700 17,360 - 26,040 Pass 0.94 W-082619 4/26/2019 Cs-134 33.3 +/- 17.8 36.2 29.0 -43.4 Pass 0.92

• W-082619 4/26/2019 Cs-137 82.6 +/- 13.2 71.9 57.5 - 86.3 Pass 1.15 W-082719 4/26/2019 Cs-134 33.9 +/- 7.0 36.2 29.0 - 43.4 Pass 0.94.

W-082719 4/26/2019 Cs-137 81.4 +/- 6.0 71.9 57.5 - 86.3 Pass 1.13 SPW-3359 8/30/2019 Gr. Alpha 54.2 +/- 0.3 72.4 36.2 - 108.6 Pass 0.75 SPW-3359 8/30/2019 Gr. Beta 59.7 +/- 0.2 54.8 43.8 -65.8 Pass 1.09 SPW-3323 9/6/2019 Ra-228 12.7+/-1.8 15.1 10.6 -19.6 Pass 0.84 W-091019 4/26/2019 Cs-134 31.0 +/- 11.3 36.2 29.0 - 43.4 Pass 0.86.

W-091019 4/26/2019 Cs-137 80.5 +/- 10.0 71.9 57.5 -86.3 Pass 1.12 SPW-3349 9/10/2019 H-3 19,851 +/- 422 21,700 17,360 - 26,040 Pass 0.91 SPW-3410 9/13/2019 H-3 20,267 +/- 431 21,700 17,360 -26,040 Pass 0.93 W-091719 4/26/2019 Cs-134 39.3 +/- 12.6 36.2 29.0 -43.4 Pass 1.09 W-091719 4/26/2019 Cs-137 81.1+/-9.9 71.9 57.5 - 86.3 Pass 1.13 .

SPW-3450 9/17/2019 H-3 20,036 +/- 427 21,700 17,360 - 26,040 Pass 0.92 W-091919 9/19/2019 Cs-134 40.0 +/- 10.7 36.2 29.0 -43.4 Pass 1.10 W-091919 9/19/2019 Cs-137 71.0 +/- 8.7 71.9 57.5 -86.3 Pass 0.99 SPW-3569 8/28/2019 Ra-226 11.9 +/- 0.3 12.3 8.6 - 16.0 Pass 0.97.

SPW-3571 9/27/2019 H-3 21,026 +/-440 21,700 17,360 - 26,040 Pass 0.97 139

TABLE A-4. In-House "Spiked" Samples Concentration" Lab Codeb Date Analysis Laboratory results Known Control Ratio 2s, n=1° Activitl Limitsd Acceptance Lab/Known SPW-3615 10/1/2019 Ra-228 18.9 +/- 2.5 14.9 10.4 - 19.3 Pass 1.27 SPW-3706 10/8/2019 H-3 20,082 +/- 427 21,700 17,360 - 26,040 Pass 0.93 SPW-4093 10/14/2019 Gr. Alpha 20.8 +/- 0.1 19.7 9.9 -29.6 Pass 1.06 SPW-4093 10/14/2019 Gr. Beta 63.2 +/- 0.1 61.1 48.9 - 73.3 Pass 1.03 SPW-4095 10/24/2019 H-3 20,684 +/- 432 21,700 17,360 - 26,040 Pass 0.95 SPW-4144 9/26/2019 Ra-226 12.8 +/- 0.3 12.3 8.6 - 16.0 Pass 1.04 W-091719 3/19/2018 H-3 22,291 +/- 470 21,700 17,360 - 26,040 Pass 1.03 SPW-4239 10/30/2019 Ra-228 12.4 +/- 1.8 14.9 10.4 -19.3 Pass 0.84 SPW-4254 11/8/2019 H-3 20,187 +/- 427 21,700 17,360 - 26,040 Pass 0.93 SPW-4368 11/14/2019 H-3 20,386 +/- 429 21,700 17,360 - 26,040 Pass 0.94 SPW-4370 10/30/2019 Ra-226 12.8 +/- 0.4 12.3 8.6 - 16.0 Pass 1.04 SPW-4472 11/21/2019 H-3 20,479 +/- 432.0 21,700 17,360 - 26,040 Pass 0.94 SPW-4474 11/22/2019 Sr-90 18.9 +/- 1.2 17.9 14.3 - 21.5 Pass 1.06 SPW-4602 12/5/2019 H-3 20,187 +/- 429 21,700 17,360 - 26,040 Pass 0.93 W-121119 3/19/2018 H-3 22,734 +/- 477 21,700 17,360 - 26,040 Pass 1.05 SPW-4663 12/11/2019 Ra-228 11.2 +/- 1.6 14.9 10.4 -19.3 Pass 0.75 SPW-4688 12/13/2019 H-3 20,506 +/-431 21,700 17,360 - 26,040 Pass 0.94 SPW-4734 11/15/2019 Ra-226 12.6 +/- 0.3 12.3 8.6 - 16.0 Pass 1.02 SPW-4743 12/5/2019 Ra-226 10.0 +/- 0.3 12.3 8.6 - 16.0 Pass 0.81 SPW-4745 12/19/2019 H-3 20,067 +/- 427 21,700 17,360 - 26,040 Pass 0.92 SPW-4889 12/19/2019 Ra-226 9.3 +/- 0.3 12.3 8.6 - 16.0 Pass 0.76 SPW-4636 12/27/2019 Tc-99 94.3 +/- 8.2 90.3 72.2 -108.4 Pass 1.04 SPW-4899 1/3/2020 H-3 20,386 +/- 432 21,700 17,360 - 26,040 Pass 0.94

• Liquid sample results are reported in pCi/Liter, air filters ( pCi/m3), charcoal (pCi/charcoal canister), and solid samples (pCi/kg).

b Laboratory codes : W & SPW (Water), Ml (milk), AP (air filter), SO (soil), VE (vegetation), CH (charcoal canister), F (fish), U (urine).

0 Results are based on single determinations.

d Control limits are listed in Attachment A of this report.

• The LCS sample was prepared from an Environmental Resource Associates (ERA) sample of known activity. While the analysis did satisfy the acceptance criteria of the ERA study from which it was sourced, it did not satisfy EIML's internal LCS acceptance criteria. An investigation is in process to determine the reason for the low bias and to evaluate the acceptance criteria.

NOTE: For fish, gelatin is used for the spike matrix. For vegetation, cabbage is used for the spike matrix.

140

TABLE A-5. In-House "Blank" Samples Concentration 8 0

Lab Code Sample Date Analysisc Laborat0!:£ results (4.66cr! Acceptance Type LLD Activitya Criteria (4.66 cr)

SPW-5449 Water 1/7/2019 Gr. Alpha 0.76 -0.30 +/-0.52 2 SPW-5449 Water 1/7/2019 Gr. Beta 0.42 0.19+/-0.31 4 SPW-34 Water 1/7/2019 1-131 0.36 0.13 +/-0.18 1 SPW-60 Water 11/5/2018 Ra-226 0.03 0.15 +/-0.03 2 SPW-119 Water 1/14/2019 H-3 148 42 +/-80 200 SPW-177 Water 1/16/2019 Ra-228 0.93 -0.10 +/- 0.42 2 SPW-198 Water 1/18/2019 Sr-89 0.67 0.25 +/-0.50 5 SPW-198 Water 1/18/2019 Sr-90 0.67 -0.16 +/- 0.29 1 SPW-249 Water 1/24/2019 Ni-63 67 31 +/-41 200 SPW-255 Water 1/15/2019 Ra-226 0.04 0.16 +/- 0.03 2 SPW-280 Water 1/25/2019 Ra-226 0.06 -0.09 +/- 0.14 2 SPW-399 Water 1/31/2019 Ra-226 0.03 0.15 +/- 0.03 2 SPW-460 Water 2/12/2019 Ra-226 0.03 0.15 +/-0.02 2 SPW-567 Water 2/21/2019 Ra-226 0.03 0.13 +/-0.02 2 SPW-844 Water 3/22/2019 U-234 0.19 0.04 +/-0.14 1 SPW-844 Water 3/22/2019 U-238 0.19 0.00 +/- 0.11 1 SPW-836 Water 3/21/2019 Ra-228 0.74 0.53 +/- 0.41 2 SPW-1060 Water 3/31/2019 Ra-226 0.04 -0.02 +/- 0.03 2 SPW-1090 Water 4/10/2019 H-3 155 -14 +/- 72 200 SPW-1092 Water 4/8/2019 Ra-228 0.82 0.75 +/-0.46 2 SPW-1266 Water 4/16/2019 H-3 152 67 +/-74 200 SPW-1338 Water 4/18/2019 H-3 152 66 +/-79 200 SPW-1386 Water 4/8/2019 Ra-226 0.03 0.09 +/-0.03 2 SPW-1426 Water 4/26/2019 H-3 156 34 +/-75 200 SPW-1536 Water 5/6/2019 Sr-89 0.66 -0.07 +/- 0.45 5 SPW-1536 Water 5/6/2019 Sr-90 0.59 -o*.10 +/- 0.26 1 SPW-1581 Water 5/9/2019 H-3 147 73 +/-77 200 SPW-1644 Water 4/22/2019 Ra-226 0.02 0.15 +/-0.02 2 SPW-1675 Water 5/17/2019 H-3 154 -30 +/- 71 200 SPW-1798 Water 5/20/2019 H-3 149 24 +/-73 200 SPW-1857 Water 5/28/2019 H-3 150 54 +/-74 200 SPW-1889 Water 5/30/2019 H-3 152 45 +/-73 200 SPW-2013 Water 5/31/2019 Ra-226 0.01 0.13 +/- 0.02 2 SPW-2029 Water 6/12/2019 Ni-63 66 10 +/-40 200 SPW-2092 Water 6/18/2019 H-3 154 -42 +/- 70 200 SPW-2237 Water 6/26/2019 H-3 150 -9 +/-69 200 SPW-2107 Water 6/18/2019 1-131 0.16 0.04 +/-0.09 1 SPW-2152 Water 6/19/2019 1-131 0.16 0.04 +/-0.09 1 141

TABLE A-5. In-House "Blank" Samples Concentration" Lab Codeb Sample Date Analysisc Laborato!l'. results (4.66cr) Acceptance Type LLD Activity° Criteria (4.66 cr)

SPW-3187 Water 7/30/2019 Ra-226 0.02 0.17 +/-0.02 2 SPW-2924 Water 8/6/2019 Sr-89 0.71 -0.06 +/- 0.57 5 SPW-2924 Water 8/6/2019 Sr-90 0.59 0.08 +/-0.28 1 SPW-2946 Water 8/9/2019 H-3 152 33 +/-72 200 SPW-3002 Water 8/14/2019 H-3 152 -22 +/- 74 200 SPW-3150 Water 8/26/2019 H-3 151 115+/-77 200 SPW-3358 Water 8/30/2019 Gr. Alpha 0.44 -0.08 +/- 0.30 2 SPW-3358 Water 8/30/2019 Gr. Beta 0.72 -0.31 +/- 0.49 4 SPW-3568 Water 8/28/2019 Ra-226 0.03 0.16 +/-0.03 2 SPW-3322 Water 9/6/2019 Ra-228 0.82 0.46 +/- 0.43 2 SPW-3348 Water 9/10/2019 H-3 150 107 +/- 76 200 SPW-3409 Water 9/13/2019 H-3 154 133 +/- 79 200 SPW-3449 Water 9/17/2019 H-3 147 102 +/- 79 200 SPW-3570 Water 9/27/2019 H-3 151 70 +/-77 200 SPW-3614 Water 10/1/2019 Ra-228 1.29 1.03 +/- 0.73 2 SPW-3705 Water 10/8/2019 H-3 147 107 +/- 77 200 SPW-4238 Water 10/30/2019 Ra-228 0.99 0.58 +/- 0.52 2 SPW-4253 Water 11/8/2019 H-3 151 80 +/-76 200 SPW-4367 Water 11/14/2019 H-3 154 42 +/-74 200 SPW-4369 Water 10/30/2016 Ra-226 0.03 0.14 +/-0.03 2 SPW-4471 Water 11/21/2019 H-3 155 81 +/- 77 200 SPW-4474 Water 11/21/2019 C-14 12 0 +/-7 200 SPW-4476 Water 11/22/2019 Sr-89 0.62 0.23 +/-0.45 5 SPW-4476 Water 11/22/2019 Sr-90 0.57 -0.16 +/- 0.24 SPW-4601 Water 12/5/2019 H-3 155 28 +/-74 200 SPW-4635 Water 12/9/2019 Tc-99 12 -6 +/-7 20 SPW-4662 Water 12/17/2019 Ra-228 0.77 0.55 +/- 0.42 2 SPW-4687 Water 12/13/2019 H-3 150 143 +/- 78 200 SPW-4733 Water 11/15/2019 Ra-226 0.03 0.13 +/-0.03 2 SPW-4742 Water 12/5/2019 Ra-226 0.04 0.10 +/- 0.10 2 SPW-4744 Water 12/19/2019 H-3 151 119 +/-81 200 SPW-4888 Water 12/19/2019 Ra-226 0.03 0.15 +/-0.02 2 SPW-4898 Water 1/3/2020 H-3 159 19 +/-78 200

• Liquid sample results are reported in pCi/Liter, air filters ( pCi/m3), charcoal (pCi/charcoal canister), and solid samples (pCi/g).

b Laboratory codes : W & SPW (Water), Ml (milk), AP (air filter), SO (soil), VE (vegetation), CH (charcoal canister), F (fish), U (urine).

0 l-131(G); iodine-131 as analyzed by gamma spectroscopy.

d Activity reported is a net activity result.

142

TABLE A-6. In-House "Duplicate" Samples Concentration" Averaged Lab Codeb Date Analysis First Result Second Result Result Acceptance AP-5499,5500 1/2/2019 Fe-55 941 +/- 220 1027 +/- 226 984 +/- 158 Pass AP-5499,5500 1/2/2019 Sr-89 20.2 +/- 7.3 14.9 +/- 5.7 17.5 +/-4:7 Pass AP-5499,5500 1/2/2019 Ni-63 12.1 +/- 8.5 15.6 +/- 8.5 13.8 +/-6.0 Pass CF-20,21 1/2/2019 Gr. Beta 10.0 +/-0.2 10.7 +/- 0.2 10.3 +/- 0.2 Pass CF-20,21 1/2/2019 Sr-90 0.005 +/- 0.002 0.005 +/- 0.002 0.005 +/- 0.001 Pass CF-20,21 1/2/2019 Be-7 0.27 +/-0.09 0.29 +/- 0.08 0.28 +/- 0.06 Pass CF-20,21 1/2/2019 K-40 6.69 +/- 0.34 6.83 +/- 0.34 6.76 +/- 0.24 Pass SG-211,212 1/21/2019 Ra-226 7.94 +/- 1.15 8.50 +/- 1.11 9.79 +/- 0.19 Pass SG-211,212 1/21/2019 Ac-228 4.46 +/- 0.37 4.63 +/- 0.43 4.55 +/-0.28 Pass WW-324,325 2/4/2019 Gr. Alpha 0.68 +/- 0.44 0.49 +/- 0.46 0.59 +/-0.32 Pass WW-324,325 2/4/2019 Gr. Beta 1.80 +/- 0.55 2.95 +/- 0.63 2.37 +/- 0.42 Pass W-345,346 2/4/2019 H-3 245 +/- 84 277 +/- 85 261 +/- 60 Pass WW-797,798 3/5/2019 H-3 165 +/- 80 222 +/- 83 193 +/- 58 Pass WW-648,649 3/8/2019 H-3 587 +/- 101 630 +/- 102 608 +/- 72 Pass SW-713,714 3/14/2019 H-3 326 +/- 90 254 +/- 86 290 +/-62 Pass AP-1241, 1242 4/2/2019 Be-7 0.097 +/- 0.018 0.108 +/- 0.020 0.103 +/- 0.013 Pass AP-1285,1286 4/3/2019 Be-7 0.080 +/- 0.014 0.078 +/- 0.012 0.079 +/- 0.009 Pass AP-1306,1307 4/3/2019 Be-7 0.085 +/- 0.009 0.096 +/- 0.011 0.090 +/- 0.007 Pass AP-1327, 1328 4/3/2019 Be-7 0.078 +/- 0.010 0.079 +/- 0.011 0.078 +/- 0.007 Pass AP-1327,1328 4/3/2019 K-40 0.012 +/- 0.007 0.021 +/- 0.010 0.017 +/- 0.006 Pass AP-2119,2120 4/3/2019 Be-7 0.276 +/- 0.098 0.265 +/- 0.116 0.270 +/- 0.076 Pass AP-2225,2226 4/3/2019 Be-7 0.231 +/- 0.128 0.208 +/- 0.123 0.220 +/- 0.089 Pass CF-820,821 4/3/2019 K-40 6.39 +/-0.30 6.63 +/- 0.37 6.51 +/-0.24 Pass WW-648,649 4/5/2019 H-3 587 +/- 101 630 +/- 102 608 +/-72 Pass WW-1043,1044 4/5/2019 H-3 666 +/- 121 662 +/- 121 664 +/-86 Pass SW-1087,1088 4/8/2019 H-3 9,997 +/- 300 10,330 +/- 305 10,164 +/- 214 Pass WW-1198, 1199 4/9/2019 H-3 562 +/-99 640 +/- 102 601 +/- 71 Pass LW-1503,1504 4/25/2019 Gr. Beta 1.09 +/- 0.55 1.46 +/- 0.57 1.27 +/- 0.39 Pass WW-1789,1790 517/2019 H-3 366 +/- 90 400 +/- 92 383 +/-64 .Pass SG-2269,2270 517/2019 Pb-214 39.1 +/- 0.5 40.3 +/- 0.5 39.7 +/- 0.4 Pass SG-2269,2270 5/7/2019 Ac-228 53.2+/-1.0 57.1 +/- 1.0 55.2 +/- 0.7 Pass DW-10049,10050 5/7/2019 Ra-226 1.31+/-0.13 1.66 +/- 0.15 1.49 +/- 0.10 Pass DW-10049,10050 517/2019 Ra-228 1.24 +/- 0.52 1.33 +/- 0.53 1.29 +/- 0.37 Pass WW-1690A,B 5/8/2019 H-3 325 +/- 89 303 +/- 93 314 +/-64 Pass S-1812,1813 5/16/2019 K-40 22.0 +/-0.9 23.3 +/- 1.0 22.6 +/-0.7 Pass S-1812,1813 5/16/2019 Cs-137 0.05 +/- 0.03 0.07 +/- 0.04 0.06 +/-0.02 Pass DW-10053, 10054 5/22/2019 Gr. Alpha 0.93 +/- 0.63 1.14 +/- 0.72 1.04 +/- 0.48 Pass DW-10053,10054 5/22/2019 Gr. Beta 1.43 +/- 0.62 1.13 +/- 0.59 1.28 +/- 0.43 Pass W-2053,2054 5/29/2019 H-3 1572 +/- 135 1470 +/- 131 1521 +/- 94 Pass 143

TABLE A-6. In-House "Duplicate" Samples Concentration 8 Averaged Lab Codeb Date Anal~sis First Result Second Result Result rAcceptance G-1989,1990 6/3/2019 Be-7 0.80 +/- 0.18 0.72 +/- 0.15 0.76 +/- 0.12 Pass G-1989, 1990 6/3/2019 K-40 6.15 +/- 0.51 5.98 +/- 0.46 6.07 +/- 0.34 Pass G-1989, 1990 6/3/2019 Gr. Beta 7.24 +/- 0.19 7.00 +/- 0.19 7.12 +/- 0.13 Pass WW-2204,2205 6/6/2019 H-3 3861 +/- 194 3722 +/- 191 3792 +/- 136 Pass S-2031,2032 6/10/2019 Pb-214 5.16 +/-0.19 4.75 +/- 0.22 4.96 +/- 0.15 Pass S-2031,2032 6/10/2019 Ac-228 3.81 +/- 0.31 3.63 +/- 0.33 3.72 +/- 0.23 Pass S-2010,2011 6/10/2019 Pb-214 1.48 +/- 0.10 1.05 +/- 0.11 1.27 +/- 0.07 Pass F-2140,2141 6/12/2019 K-40 1.01 +/- 0.28 1.39 +/- 0.32 1.20 +/- 0.21 Pass S-2162,2163 6/12/2019 Pb-214 0.65 +/- 0.06 0.54 +/- 0.05 0.60 +/- 0.04 Pass S-2162,2163 6/12/2019 Ac-228 0.46 +/- 0.10 0.44 +/- 0.08 0.45 +/- 0.07 Pass S-2162,2163 6/12/2019 K-40 4.22 +/- 0.49 3.81 +/- 0.41 4.02 +/- 0.32 Pass S-2162,2163 6/12/2019 Tl-208 0.09 +/- 0.02 0.10+/-0.02 0.09 +/- 0.01 Pass S-2162,2163 6/12/2019 Pb-212 0.34 +/- 0.03 0.26 +/-0.03 0.30 +/-0.02 Pass SWT-2355,2356 6/25/2019 Gr. Beta 1.12 +/- 0.57 1.24 +/- 0.56 1.18 +/-0.40 Pass AP-2689,2690 6/28/2019 Be-7 0.089 +/- 0.020 0.075 +/- 0.018 0.082 +/- 0.013 Pass AP-2710,2711 7/1/2019 Be-7 0.091 +/- 0.010 0.097 +/- 0.010 0.094 +/- 0.007 Pass AP-2731,2732 7/2/2019 Be-7 0.073 +/- 0.013 0.072 +/- 0.011 0.072 +/- 0.009 Pass DW-10062, 10063 7/5/2019 Ra-226 4.10 +/- 0.30 4.03 +/-0.30 4.07 +/- 0.21 Pass DW-10062,10063 7/5/2019 Ra-228 1.95 +/- 0.60 2.31 +/- 0.62 2.13 +/- 0.43 Pass AP-70818,70819 7/8/2019 Gr. Beta 0.021 +/- 0.004 0.023 +/- 0.004 0.022 +/- 0.003 Pass XW-2459,2460 7/10/2019 H-3 304 +/- 92 234 +/- 89 269 +/-64 Pass VE-2516,2517 7/10/2019 Be-7 0.63 +/- 0.16 0.52 +/- 0.19 0.58 +/- 0.12 Pass VE-2516,2517 7/10/2019 K-40 6.50 +/- 0.47 6.81 +/- 0.54 6.66 +/-0.36 Pass AP-71518A,B 7/15/2019 Gr. Beta 0.022 +/- 0.004 0.025 +/- 0.004 0.023 +/- 0.003 Pass VE-2668,2669 7/16/2019 K-40 3.84 +/- 0.27 3.74 +/-0.26 3.79 +/-0.19 Pass DW-10076, 10077 7/16/2019 Gr.Alpha 3.01 +/- 0.92 4.13 +/- 0.91 3.57 +/- 0.65 Pass DW-10073,10074 7/16/2019 Ra-226 1.57 +/- 0.18 1.51 +/- 0.21 1.54 +/- 0.14 Pass DW-10073,10074 7/16/2019 Ra-228 1.29 +/- 0.56 1.48 +/- 0.57 1.385 +/- 0.40 Pass AP-72218A,B 7/22/2019 Gr. Beta 0.013 +/- 0.004 0.016 +/- 0.004 0.015 +/- 0.003 Pass G-2752,2753 7/23/2019 K-40 4.53 +/- 0.42 4.47 +/- 0.46 4.50 +/- 0.31 Pass G-2752,2753 7/23/2019 Be-7 1.98 +/- 0.29 1.96 +/- 0.29 1.97 +/- 0.20 Pass AP-2800,2801 7/25/2019 Be-7 0.208 +/- 0.090 0.321 +/- 0.147 0.264 +/- 0.086 Pass AP-72918A,B 7/29/2019 Gr. Beta 0.026 +/- 0.005 0.025 +/- 0.005 0.025 +/- 0.003 Pass VE-2840,2841 7/31/2019 K-40 3.94 +/- 0.38 3.99 +/- 0.47 3.96 +/- 0.30 Pass AP-2903,2904 8/1/2019 Be-7 0.198 +/- 0.102 0.228 +/-0.102 0.213 +/- 0.072 Pass P-2882,2983 8/1/2019 H-3 265 +/-85 327 +/-88 296 +/- 61 Pass SG-2926,2927 8/5/2019 Pb-214 9.07 +/- 0.39 8.82 +/- 0.39 8.95 +/- 0.28 Pass SG-2926,2927 8/5/2019 Ac-228 9.00 +/- 0.76 8.58 +/-0.72 8.79 +/-0.52 Pass AV-2993,2994 8/9/2019 Gr. Beta 1.22 +/- 0.19 1.28 +/- 0.21 1.25 +/-0.14 Pass AV-2993,2994 8/9/2019 K-40 3.12 +/- 0.36 3.14 +/- 0.35 3.13 +/- 0.25 Pass 144

TABLE A-6. In-House "Duplicate" Samples Concentration" Averaged Lab Codeb Date Analysis First Result Second Result Result Acceptance DW-10088, 10089 8/9/2019 Ra-228 0.60 +/- 0.50 1.20 +/- 0.50 0.90 +/- 0.35 Pass DW-10088, 10089 8/9/2019 Ra-226 1.40 +/- 0.20 0.94 +/- 0.20 1.17 +/-0.14 Pass VE-3016,3017 8/12/2019 Be-7 0.39 +/- 0.12 0.47 0.28 0.43 0.15 Pass VE-3016,3017 8/12/2019 K-40 6.13 +/- 0.41 6.24 0.64 6.18 0.38 Pass G-3600,3601 8/12/2019 Be-7 4.42 +/- 0.33 4.35 0.27 4.39 0.21 Pass WW-3100,3101 8/14/2019 H-3 480 +/- 96 401 +/- 92 441 +/- 66 Pass Ml-3211,3212 8/27/2019 K-40 1862 +/- 131 1923 +/- 136 1893 +/- 94 Pass Ml-3211,3212 8/27/2019 Sr-90 0.90 +/- 0.33 0.56 +/- 0.29 0.73 +/- 0.22 Pass LW-3512,3513 8/30/2019 Gr. Beta 0.79 +/- 0.50 1.39 +/- 0.58 1.09 +/- 0.38 Pass DW-10100, 10101 9/5/2019 Ra-226 0:50 +/- 0.11 0.57 0.12 0.54 +/- 0.08 Pass DW-10100, 10101 9/5/2019 Ra-228 3.38 +/- 0.82 2.54 1.03 2.96 +/- 0.66 Pass DW-10111,10112 9/23/2019 Gr. Alpha 1.72 +/- 0.73 1.41 0.68 1.57 +/- 0.50 Pass DW-10115,10116 9/25/2019 Ra-228 3.65 +/-0.80 2.76 0.68 3.21 +/- 0.52 Pass DW-10115,10116 9/25/2019 Ra-226 2.99 +/-0.23 2.74 0.25 2.87 +/-0.17 Pass WW-3793,3794 10/8/2019 Gr. Beta 3.75 +/- 1.18 4.34 1.20 4.05 +/- 0.84 Pass BS-3879,3880 10/9/2019 Pb-214 0.60 +/- 0.03 0.65 +/- 0.05 0.63 +/-Q.03 Pass BS-3879,3880 10/9/2019 Ra-226 1.27 +/-0.14 1.15 +/-0.14 1.21 +/-0.10 Pass BS-3879,3880 10/9/2019 K-40 11.05 +/- 0.29 10.69 +/- 0.30 10.87 +/- 0.21 Pass BS-3879,3880 10/9/2019 Pb-212 0.58 +/-0.02 0.55 +/- 0.02 0.56 +/- 0.01 Pass BS-3879,3880 10/9/2019 Tl-208 0.21 +/- 0.02 0.21 +/- 0.01 0.21 +/- 0.01 Pass BS-3879,3880 10/9/2019 Bi-212 0.75 +/- 0.17 0.62 +/-0.17 0.68 +/- 0.12 Pass BS-3879,3880 10/9/2019 Bi-214 0.57 +/- 0.02 0.52 +/- 0.06 0.54 +/- 0.03 Pass BS-4161,4162 10/29/2019 K-40 15.3 +/- 0.6 15.3+/-0.7 15.3 +/- 0.5 Pass BS-4161,4162 10/29/2019 Ra-226 2.16+/-0.35 2.27 +/-0.78 2.22 +/- 0.43 Pass DW-10126,10127 10/22/2019 Ra-228 0.85 +/- 0.58 1.19 +/-0.62 1.02 +/- 0.42 Pass DW-10129,10130 10/22/2019 Gr. Alpha 1.44 +/- 0.96 3.06 +/- 0.95 2.25 +/-0.68 Pass SG-4071 10/22/2019 Ac-228 2.10 +/- 0.16 2.16 +/- 0.20 2.13 +/-0.13 Pass SPSG-4071,4072 10/22/2019 Pb-214 1.61 +/- 0.10 1.29 +/- 0.08 1.45 +/- 0.06 Pass SS-3900,3901 10/15/2019 Bi-212 0.29 +/- 0.14 0.19 +/- 0.12 0.24 +/- 0.09 Pass WW-4291,4292 11/5/2019 H-3 481 +/- 97 528 +/-97 505 +/-68 Pass DW-10139, 10140 11/6/2019 Ra-228 2.61 +/- 0.62 2.26 +/- 0.63 2.44 +/- 0.44 Pass DW-10139, 10140 11/6/2019 Ra-226 1.49 +/- 0.17 1.32 +/- 0.19 1.41 +/- 0.13 Pass WW-4270,4271 11/6/2019 H-3 112 +/- 78 165 +/- 81 139 +/- 56 Pass S-4312,4313 11/7/2019 K-40 20.2 +/-0.8 23.0 +/-0.9 21.6 +/-0.6 Pass AP-4379,4380 11/12/2019 Be-7 0.133 +/- 0.075 0.134 +/- 0.073 0.134 +/- 0.052 Pass S-4422,4223 11/13/2019 Pb-214 1.22 +/- 0.09 1.28 +/-0.10 1.25 +/- 0.07 Pass S-4422,4423 11/13/2019 Ac-228 1.14 +/- 0.15 1.21 +/- 0.17 1.18 +/- 0.11 Pass WW-4556,4557 11/13/2019 H-3 438 +/-96 482 +/- 98 460 +/-69 Pass SO-5024,5025 11/14/2019 K-40 6.60 +/- 0.54 6.26 +/-0.58 6.43 +/-0.40 Pass Ml-4443,4444 11/18/2019 K-40 1304 +/- 114 1340 +/- 109 1322 +/- 79 Pass 145

TABLE A-6. In-House "Duplicate" Samples Concentration a Averaged Lab Codeb Date Analz'.sis First Result Second Result Result Acceetance SW-4492,4493 11/19/2019 H-3 188 +/- 87 264 +/-97 226 +/-65 Pass WW-4577,4578 11/21/2019 H-3 212 +/- 83 232 +/-84 222 +/-59 Pass AP-4514,4515 11/21/2019 Be-7 0.130 +/- 0.055 0.193 +/-0.112 0.162 +/-0.062 Pass SWT-4598,4599 11/26/2019 Gr. Beta 1.43 +/- 0.57 1.14 +/-0.54 1.28 +/- 0.39 Pass AP-120218A,B 12/2/2019 Gr. Beta 0.009 +/- 0.004 0.013 +/- 0.004 0.011 +/- 0.003 Pass S-4644,4645 12/4/2019 Pb-214 1.01 +/-0.09 0.91 +/- 0.09 0.96 +/-0.06 Pass S-4644,4645 12/4/2019 Ac-228 0.85 +/-0.15 0.96 +/- 0.16 0.91 +/- 0.11 Pass AP-121618A,B 12/16/2019 Gr. Beta 0.028 +/- 0.005 0.030 +/- 0.005 0.029 +/- 0.003 Pass.

S-4735,4736 12/16/2019 Pb-214 9.33 +/-0.38 9.45 +/- 0.27 9.39 +/-0.23 Pass S-4735,4736 12/16/2019 Ac-228 13.4 +/- 0.7 14.9 +/- 0.7 14.1 +/- 0.5 Pass AP-122318A,B 12/23/2019 Gr. Beta 0.034 +/- 0.005 0.035 +/- 0.005 0.035 +/- 0.003 Pass AP-123018A,B 12/30/2019 Gr. Beta 0.037 +/- 0.005 0.037 +/- 0.005 0.037 +/-0.004 Pass Note: Duplicate analyses are performed on every twentieth sample received in-house. Results are not listed for those analyses with activities that measure below the LLD.

a Results are reported in units of pCi/L, except for air filters (pCi/Filter or pCi/m3), food products, vegetation, soil and sediment (pCi/g).

b CH (Charcoal Canister), OW (Drinking Water), E (Egg), F (Fish), G (Grass), LW (Lake Water), P (Precipitation),

PM (Powdered Milk), S, (Solid), SG (Sludge), SO (Soil), SS (Shoreline Sediment), SW (Surface Water),

SWT (Surface Water Treated), SWU (Surface Water Untreated), VE (Vegetation), W Water (Water), WW (Well Water).

146

TABLE A-6. Department of Energy's Mixed Analyte Performance Evaluation Program (MAPEP).

Concentration" Reference Known Control 0

Lab Code b Date Analysis Laboratory result Activity Limits Acceptance MAVE-607 2/1/2019 Cs-134 2.33 +/- 0.10 2.44 1.71 -3.17 Pass MAVE-607 2/1/2019 Cs-137 2.62 +/- 0.13 2.30 1.61 - 2.99 Pass MAVE-607 2/1/2019 Co-57 2.39 +/- 0.11 2.07 1.45 - 2.69 Pass MAVE-607 2/1/2019 Co-60 0.046 +/- 0.04 0 NA 0 Pass MAVE-607 2/1/2019 Mn-54 0.031 +/- 0.04 0 NA 0 Pass MAVE-607 2/1/2019 Sr-90 0.013 +/- 0.022 0 NA 0 Pass MAAP-3299 8/1/2019 Gross Alpha 0.13 +/- 0.03 0.528 0.158 - 0.898 Fail 9 MAAP-3299 8/1/2019 Gross Beta 1.06 +/- 0.07 0.937 0.469 - 1.406 Pass MAW-3252 8/1/2019 Gross Alpha 0.93 +/- 0.06 1.06 0.32 -1.80 Pass MAW-3252 8/1/2019 Gross Beta 3.03 +/- 0.07 3.32 1.66 -4.98 Pass MASO-3297 8/19/2019 Cs-134 881.98 +/- 9.03 1020 714 - 1326 Pass MASO-3297 8/19/2019 Cs-137 871.50 +/- 10.83 789 552 - 1026 Pass MASO-3297 8/19/2019 Co-57 -1.72 +/- 3.01 0 NA 0 Pass MASO-3297 8/19/2019 Co-60 783.69 +/- 8.21 760 532 - 988 Pass MASO-3297 8/19/2019 Mn-54 834.48 +/- 11.29 745 522 - 969 Pass 0

MASO-3297 8/19/2019 Zn-65 -3.01 +/- 5.27 0 NA Pass MASO-3297 8/19/2019 K-40 662.91 +/- 42.65 555 389 - 722 Pass MAW-3240 8/1/2019 Cs-134 -0.08 +/- 0.06 0 NA 0 Pass MAW-3240 8/1/2019 Cs-137 18.48 +/- 0.90 18.4 12.9 - 23.9 Pass MAW-3240 8/1/2019 Co-57 14.68 +/- 0.52 15.6 10.9 -20.3 Pass MAW-3240 8/1/2019 Co-60 8.67 +/- 0.39 8.8 6.2 - 11.4 Pass MAW-3240 8/1/2019 Mn-54 20.72 +/- 0.93 20.6 14.4 - 26.8 Pass MAW-3240 8/1/2019 Zn-65 20.52 +/- 1.05 20.3 14.200 - 26.400 Pass 0

MAW-3240 8/1/2019 K-40 5.11 +/- 0.68 0 NA Fail MAW-3240 8/1/2019 H-3 179.52 +/- 3.32 175 123 -228 Pass MAW-3240 8/1/2019 U-234 1.11 +/- 0.04 1.07 0.75 -1.39 Pass MAW-3240 8/1/2019 U-238 1.08 +/- 0.04 1.05 0.74 -1.37 Pass 0

MAVE-3295 8/1/2019 Cs-134 0.02 +/- 0.02 0 NA Pass MAVE-3295 8/1/2019 Cs-137 3.38 +/- 0.32 3.28 2.30 -4.26 Pass MAVE-3295 8/1/2019 Co-57 4.99 +/- 0.51 4.57 3.20 - 5.94 Pass MAVE-3295 8/1/2019 Co-60 5.29 +/- 0.39 5.30 3.71 -6.89 Pass MAVE-3295 8/1/2019 Mn-54 4.73 +/- 0.45 4.49 3,14 - 5.84 Pass MAVE-3295 8/1/2019 Zn-65 3.10+/-0.31 2.85 2.00 - 3.71 Pass

• Results are reported in units of Bq/kg (soil), Bq/L (water) or Bq/total sample (filters, vegetation).

b Laboratory codes as follows: MAW (water), MAAP (air filter), MASO (soil) and MAVE (vegetation).

0 MAPEP results are presented as the known values and expected laboratory precision (1 sigma, 1 determination) and control limits as defined by the MAPEP. A known value of "zero" indicates an analysis was included in the testing series as a "false positive". MAPEP does not provide control limits.

d Provided in the series for "sensitivity evaluation". MAPEP does not provide control limits.

• Past results have been acceptable so will watch to see if a trend develops.

1 An erroneous volume conversion caused some incorrect values to be submitted. If the conversion had been performed properly the results in Bq/sample would have been (Sr-90: 0.671 +/- 0.066) and (U-234: 0.153 +/- 0.036) and (U-238: 0.144 +/- 0.035).

This result had been included in the Uranium investigation. See footnote "C" on Table A-1.

9 The lab will adopt a MAPEP specific gross alpha/beta filter calibration as discussed in the MAPEP test instructions.

Utilizing a MAPEP specific calibration, the result in Bq/sample ( 0.39 +/- 0.09 Bq/total) which passes the MAPEP acceptance criteria.

147

TABLEA-7. Deeartment of Energts Mixed Analyte Performance Evaluation Program (MAPEP).

Concentration 8 Reference Known Control Lab Code b Date Analysis Laboratory result Activity Limits c Acceetance MAAP-609 2/1/2019 Gross Alpha 0.16 +/- 0.03 0.528 0.158 - 0.898 Pass MAAP-609 2/1/2019 Gross Beta 1.09 +/- 0.07 0.948 0.474 - 1.422 Pass MAW-550 2/1/2019 Gross Alpha 0.73 +/- 0.06 0.84 0.25 -1.43 Pass MAW-550 2/1/2019 Gross Beta 2.26 +/- 0.06 2.33 1.17 - 3.50 Pass MASO-605 2/1/2019 Am-241 38.89 +/- 5.92 49.9 34.9 +/-64.9 Pass MASO-605 2/1/2019 Cs-134 0.45 +/-2.52 0.0 NAC Pass MASO-605 2/1/2019 Cs-137 1273.1 +/- 13.0 1164 815 -1513 Pass MASO-605 2/1/2019 Co-57 0.46 +/- 1.1 0.0 NA C Pass MASO-605 2/1/2019 Co-60 857.96 +/- 8.52 855.0 599 - 1112 Pass MASO-605 2/1/2019 Mn-54 1,138.0 +/- 13.5 1027 719 -1335 Pass MASO-605 2/1/2019 Zn-65 730.92 +/- 16.48 668 468 - 868 Pass MASO-605 2/1/2019 K-40 676 +/- 47 585 410-761 Pass MASO-605 2/1/2019 Sr-90 0.0007 +/- 0.0007 0.000 NA C Pass MASO-605 2/1/2019 Pu-238 78.15 +/- 6.11 71.0 49.7 - 92.3 Pass MASO-605 2/1/2019 Pu-239/240 65.00 +/- 5.4 59.8 41.9 -77.7 Pass MASO-605 2/1/2019 U-234 65 +/- 13 56 39 -73 Pass MASO-605 2/1/2019 U-238 237 +/-23 205 144 - 267 Pass MAW-613 2/1/2019 Am-241 0.46 +/- 0.03 0.582 0.407 - 0.757 Pass MAW-613 2/1/2019 Cs-134 5.49 +/- 0.18 5.99 4.19 - 7.79 Pass MAW-613 2/1/2019 Cs-137 0.089 +/- 0.080 0 NAC Pass MAW-613 2/1/2019 Co-57 10.87 +/- 0.24 10.00 7.0 -13.0 Pass MAW-613 2/1/2019 Co-60 6.78 +/-0.19 6.7 4.7 - 8.7 Pass MAW-613 2/1/2019 Mn-54 8.98 +/-0.17 8.4 5.9 - 10.9 Pass MAW-613 2/1/2019 Zn-65 0.096 +/-0.141 0 NAC Pass MAW-613 2/1/2019 Fe-55 0.004 +/- 4.00 0 NAC Pass MAW-613 2/1/2019 Ni-63 5.54 +/- 1.52 5.8 4.1 - 7.5 Pass MAW-613 2/1/2019 Sr-90 6.02 +/- 0.53 6.35 4.45 - 8.26 Pass MAW-613 2/1/2019 Pu-238 0.315 +/- 0.088 0.451 0.316 - 0.586 Faile MAW-613 2/1/2019 Pu-239/240 0.07 +/- 0.07 0.005 NA d Pass MAW-613 2/1/2019 U-234 0.96 +/- 0.07 0.800 0.56 +/- 1.04 Pass MAW-613 2/1/2019 U-238 0.94 +/- 0.07 0.810 0.57 +/- 1.05 Pass MAAP-611 2/1/2019 Cs-134 0.185 +/- 0.025 0.216 0.151 - 0.281 Pass MAAP-611 2/1/2019 Cs-137 0.288 +/- 0.045 0.290 0.203 - 0.377 Pass MAAP-611 2/1/2019 Co-57 0.369 +/- 0.033 0.411 0.288 - 0.534 Pass MAAP-611 2/1/2019 Co-60 0.333 +/- 0.045 0.340 0.238 - 0.442 Pass MAAP-611 2/1/2019 Mn-54 0.546 +/- 0.058 0.547 0.383-0.711 Pass MAAP-611 2/1/2019 Zn-65 0.025 +/- 0.0348 0 NAC Pass MAAP-611 2/1/2019 Sr-90 1.34 +/- 0.13 0.662 0.463 - 0.861 Fauf 1

MAAP-611 2/1/2019 U-234 4.14 +/-0.97 0.106 0.074-0.138 Fail MAAP-611 2/1/2019 U-238 3.89 +/- 0.94 0.110 0.077 - 0.143 Fail1 MAW-601 2/1/2019 1-129 0.56 +/- 0.08 0.616 0.431 - 0.801 Pass 148

TABLE A-8. lnterlaboratory Comparison Crosscheck Program, Environmental Resource Associates (ERA)8.

MRAD-30 Stud:z'.

Concentration a Lab Code b Date Analysis Laboratory ERA Control 0

Result Value Limits d Acceptance ERAP-846 3/18/2019 Am-241 19.1 18.7 13.3 - 24.9 Pass ERAP-846 3/18/2019 Cs-134 612 721 468 - 884 Pass ERAP-846 3/18/2019 Cs-137 679 634 521 - 832 Pass ERAP-846 3/18/2019 Co-60 93.7 93.8 79.7-119 Pass ERAP-846 3/18/2019 Fe-55 612 718 262 - 1150 Pass ERAP-846 3/18/2019 Mn-54 < 0.5 < 50.0 0.00 - 50.0 Pass ERAP-846 3/18/2019 Zn-65 1500 1380 1130 -2110 Pass ERAP-846 3/18/2019 Pu-238 34.0 33.8 25.5 - 41.5 Pass ERAP-846 - 3/18/2019 Pu-239 64.9 67.0 50.1 - 80.8 Pass ERAP-846 3/18/2019 Sr-90 199 181 114 - 246 Pass ERAP-846 3/18/2019 U-234° 29.0 18.2 13.5 -21.3 Fail ERAP-846 3/18/2019 U-238° 28.6 18.1 13.7 -21.6 Fail ERAP-848 3/18/2019 Gross Alpha 48.4 50.3 26.3 - 82.9 Pass ERAP-848 3/18/2019 Gross Beta 95.5 78.6 47.7 -119 Pass a Results obtained by Environmental, Inc., Midwest Laboratory (EIML) as a participant in the crosscheck program for proficiency testing administered by Environmental Resource Associates, serving as a replacement for studies conducted previously by the Environmental Measurements Laboratory Quality Assessment Program (EML).

b Laboratory code ERAP (air filter). Results are reported in units of (pCi/Filter).

0 The ERA Assigned values for the air filter standards are equal to 100% of the parameter present in the standard as determined by the gravimetric and/or volumetric measurements made during standard preparation as applicable.

d The acceptance limits are established per the guidelines contained in the Department of Energy (DOE) report EML-564, Analysis of Environmental Measurements Laboratory (EML) Quality Assessment Program (QAP)

Data Determination of Operational Criteria and Control Limits for Performance Evaluation Purposes or ERA's SOP for the generation of Performance Acceptance Limits.

° Failure traced to an over-estimated U-232 tracer value. Tracer has been re-standardized. (See footnote "c" on Table A-1).

149

APPENDIXB DATA REPORTING CONVENTIONS 150

Data Reporting Conventions 1.0. All activities, except gross alpha and gross beta, are decay corrected to collection time or the end of the collection period.

2.0. Single Measurements Each single measurement is reported as follows: x+/-s where: x = value of the measurement; s = 2cr counting uncertainty (corresponding to the 95% confidence level).

In cases where the activity is less than the lower limit of detection L, it is reported as: < L, where L = the lower limit of detection based on 4.66cr uncertainty for a background sample.

3.0. Duplicate analyses If duplicate analyses are reported, the convention is as follows. :

3.1 Individual results: For two analysis results; x 1 +/- s1 and x2 +/- s2 Reported result: x +/- s; where x = (1/2) (x1 + x2) and s = (1/2) sf + Si 3.2. Individual results: < L1 , < 1/2 Reported result: < L, where L = lower of L1 and 1/2 3.3. Individual results: x +/- s, < L Reported result: x +/- s if x ~ L; < L otherwise.

4.0. Computation of Averages and Standard Deviations 4.1 Averages and standard deviations listed in the tables are computed from all of the individual measurements over the period averaged; for example, an_ annual standard deviation would not be the average of quarterly standard deviations. The average x and standard deviation "s" of a set of n numbers x1 , x2 ..

. xn are defined as follows:

X 1

=;, L X s-

-~~ -\/~

4.2 Values below the highest lower limit of detection are not included in the average.

4.3 If all values in the averaging group are less than the highest LLD, the highest LLD is reported.

4.4 If all but one of the values are less than the highest LLD, the single value x and associated two sigma error is reported.

4.5 In rounding off, the following rules are followed:

4.5.1. If the number following those to be retained is less than 5, the number is dropped, and the retained numbers are kept unchanged. As an example, 11.443 is rounded off to 11.44.

4.5.2. If the number following those to be retained is equal to or greater than 5, the number is dropped and the last retained number is raised by 1. As an example, 11.445 is rounded off to 11.45.

151

APPENDIX C REMP SAMPLING

SUMMARY

152

TABLE C: Davis-Besse Nuclear Power Station REMP Sampling Summary January - December 2019 Location with Highest r

Annual Mean Control Number Type and Indicator Locations Non-Sample Type Number of Locations Mean Mean (F}c Mean (F)0 Routine (Units) Analyses* LLDb (F)<Range 0 Locationd Range< Range 0 Results*

0.022 0.024 T-7, Sand Beach 0.027 (51/52)

Airborne GB 457 0.003 (257/260) (200/208) 0 0.9mi.NW (0.005-0.055)

Particulates (0.005-0.055) (0.009-0.049)

(pCi/m3)

Sr-89 36 0.0014 < LLD - - < LLD 0 Sr-90 36 0.0013 < LLD - - < LLD 0 GS 36 0.087 0.077 (20/20) T-7, Sand Beach 0.100 (4/4)

Ele-7 0.0150 (16/16) 0 (0.046-0.126) 0.9 mi. NW (0.087-0.126)

(0.065-0.110)

T-11, Port 0.030 K-40 0.0300 0.026 (20/20) Clinton 9.5 mi. 0.030 (1/1) 0 (16/16)

SE Nb-95 0.0040 < LLD - - < LLD 0 Zr-95 0.0035 < LLD - - < LLD 0 Ru-103 0.0021 < LLD - < LLD 0 Ru-106 0.0141 < LLD - - < LLD 0 Cs-134 0.0018 < LLD - < LLD 0 Cs-137 0.0018 < LLD - - < LLD 0 Ce-141 0.0035 < LLD - - < LLD 0 Ce-144 0.0078 < LLD - < LLD 0 Airborne Iodine 1-131 457 0.07 < LLD - <LLD 0 (pCi/m 3 )

TLD 15.1 T-7, Residence 20.13 (4/4) 15.5 (40/40)

(Quarterly) Gamma 232 1.0 (191/192} 0 0.9mi.NW (16.5-23.4) (11.8-20.8)

(mR/91days) (7.2-23.4)

TLD (Quarterly)

Gamma 4 1.0 < LLD - - < LLD 0 (mR/91days)

(Shield) 153

TABLE C: Davis-Besse Nuclear Power Station REMP Sampling Summary January- December 2019 Location with Highest Annual Mean Indicator Control Number Locations Locations Non-Sample Type and Number Mean (F)< Mean (F)< Mean (F)c Routine Type (Units) of Analyses* LLDb Range< Locationd Range< Range< Results*

Milk (pCi/L) 1-131 4 0.5 none - - < LLD 0 Sr-89 4 0.7 none - - < LLD 0 Sr-90 4 0.7 none - - < LLD 0 GS 4 T-24, Sandusky 1324.3 (4/4) 1324 (4/4)

K-40 100 none. 0 21.0 mi. SE (1290-1363) (1290-1363)

Cs-134 4.6 none - - < LLD 0 Cs-137 2.9 none - - < LLD 0 Ba-La- 3.0 none - - < LLD 0 140 T-24, Sandusky 1.01 (4/4) 1.01 (4/4)

(g/L) Ca 4 0.50 none 0 21.0 mi. SE (0.92-1.08) (0.92-1.08)

T-24, Sandusky 1.62 (4/4) 1.62 (4/4)

(g/L) K (stable) 4 none 0 21.0 mi. SE {1.57-1.66) (1.57-1.66)

(pCi/g) Sr-90/Ca 4 0.65 none - - < LLD 0 (pCi/g) Cs-137/K 4 1.78 none - - < LLD 0 Ground T-27, Park 3.3 (2/3) 3.3 (2/3)

Water GB (TR) 3 3.8 none 0 5.3mi. NW (2.8-3.8) (2.8-3.8)

(pCi/L)

H-3 3 330 none - - < LLD 0 Sr-89 4 1.6 none - - < LLD 0 Sr-90 4 0.9 none - - < LLD 0 GS 3 Mn-54 15 none - - < LLD 0 Fe-59 30 none - - < LLD 0 Co-58 15 none - - < LLD 0 Co-60 15 none - - < LLD 0 Zn-65 30 none - - <!-LD 0 Zr-95 15 none - - < LLD 0 Cs-134 10 none - - < LLD 0 Cs-137 10 none - - < LLD 0 Ba-La- 15 none - - < LLD 0 140 154

TABLE C: Davis-Besse Nuclear Power Station REMP Sampling Summary January- December 2019 Location with Highest Annual Mean Indicator Control Number Locations Locations Non-Sample Type Type and Number Mean (F) 0 Mean (F) 0 Mean (F) 0 Routine (Units) of Analyses* LLDb Range0 Locationd Rangec Range 0 Results*

Broad Leaf Sr-.89 19 0.025 < LLD - - < LLD 0 Vegetation (pCi/gwet) Sr-90 19 0.014 < LLD - < LLD 0 GS 22 2.88 (16/16) T-19, Residence 3.26 (9/9) 3.43 (6/6)

K-40 0.50 0 (1.87-5.00) 0.97mi. W (2.07-5.00) (1.67-4.64)

Nb-95 0.002 < LLD - < LLD 0 Zr-95 0.029 < LLD - < LLD 0 1-131 0.042 < LLD - < LLD 0 Cs-134 0.021 < LLD - < LLD 0 Cs-137 0.018 < LLD - - < LLD 0 Ce-141 0.044 < LLD - < LLD 0 Ce-144 0.122 < LLD - < LLD 0 Treated 1.36 (10/12) T-11, Port Clinton 1.40 (8/12) 1.40 {8/12)

Surface GB(TR) 24 0.9 0 (0.9-2.3) 9.14 mi. SE (1.0-1.9) (1,0-1.9)

Water (pCi/L)

T-22, Carroll Twp H-3 8 330 336 (1/4) Water Plant 336 (1/4} < LLD 0 2.lmi.W Sr-89 8 0.8 <LLD - - < LLD 0 Sr-90 8 0.5 <LLD - <LLD 0 GS 8 Mn-54 15 < LLD - - < LLD 0 Fe-59 30 < LLD - - < LLD 0 Co-58 15 < LLD - < LLD 0 Co-60 15 < LLD - - < LLD 0 Zn-65 30 < LLD - - < LLD 0 zr-Nb-95 15 < LLD - - < LLD 0 Cs-134 10 < LLD - - < LLD 0 Cs-137 10 <LLD - < LLD 0 Ba-La- 15 < LLD - < LLD 0 140 155

TABLE C: Davis-Besse Nuclear Power Station REMP Sampling Summary January- December 2019 Location with Highest Annual Mean Indicator Control Number Locations Locations Non-Sample Type Type and Number Mean (F)< Mean (F)c Mean (F)c Routine (Units) of Analyses* LLDb Range< Locationd Range< Range< Results*

Untreated T-3, Site 1.87 (24/24) 2.17 (12/12) 1.34 (11/12)

Surface GB (TR) 36 1.8 Boundary 0 (1.0-2.9) (1.1-2.9) (0.9-1.8)

Water (pCi/L) 1.4 mi. ESE T-22, Carroll Twp 480 (5/24) 513 (2/12)

H-3 36 330 Water Plant 367 (1/12) 0 (430-546) (480-546) 2.lmi.W Sr-89 12 0.8 < LLD - - < LLD 0 Sr-90 12 0.6 < LLD - - < LLD (j GS 12 Mn-54 15 < LLD - - < LLD 0 Fe-59 30 < LLD - - < LLD 0 Co-58 15 < LLD - - < LLD 0 Co-60 15 < LLD - - < LLD 0 Zn-65 30 < LLD - - < LLD 0 Zr-Nb-95 15 < LLD - - < LLD 0 Cs-134 10 < LLD - - < LLD 0 Cs-137 10 < LLD - - < LLD 0 Ba-La- 15 < LLD - - < LLD 0 140 Fish (pCi/G wet) 3.45 (2/2) T-33, Lake Erie 4.09 (2/2) 4.09 (2/2)

GB 4 0.10 0 (3.33-3.52) 1.52 mi. NE (3.80-4.38) (3.80-4.38)

GS 4 3.44 (2/2) T-33, Lake Erie 3.90 (2/2) 3.90 (2/2)

K-40 0.10 0 (3.33-3.52) 1.52 mi. NE (3. 78-4.02) (3.78-4.02)

Mn-54 0.040 < LLD - - < LLD 0 Fe-59 0.254 < LLD - - < LLD 0 Co-58 0.069 < LLD - - < LLD 0 Co-60 0.027 < LLD - - < LLD 0 Zn-65 0.073 < LLD - - < LLD 0 Cs-134 0.036 < LLD - - < LLD 0 Cs-137 0.032 < LLD - - < LLD 0 156

TABLE C: Davis-Besse Nuclear Power Station REMP Sampling Summary January- December 2019 Location with Highest Annual Mean Indicator Control Number Type and Locations Locations Non-Sample Type Number of Mean (F) 0 Mean (F) 0 Mean (F) 0 Routine (Units) Analyses* LLDb Range 0 Locationd Rangec Rangec Results*

Shoreline Sediments (pCi/g dry) GB 4 10.75 (2/2) T-11, Port Clinton 11.93 (2/2) 11.93 (2/2)

K-40 0.10 0 (9.44-12.06) 9.5 mi. SE (11.67-12.19) (11.67-12.19)

Mn-54 0.017 < LLD - - < LLD 0 Co-58 0.023 < LLD - - < LLD 0 Co-60 0.018 < LLD - - < LLD 0 Cs-134 0.012 < LLD - - < LLD 0 Cs-137 0.013 < LLD - - < LLD 0

• GB= Gross Beta, GS= Gamma Scan LLD= nominal lower limit of detection based on a 4.66 sigma counting error for background sample.

c Mean and range are based on detectable only (i.e.,> LLD) Fraction of detectable measurements at specified locations is indicated in parentheses (F).

Locations are specified by station code and distance (miles) and direction relative to reactor site.

Non-routine results are those which exceed ten times the control station value.

157