ML22111A068

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Annual Radiological Environmental Operating Report (AREOR)
ML22111A068
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 04/21/2022
From: Hardy J
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO2022-00014
Download: ML22111A068 (1)
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Text

S) entergy Entergy Operations, Inc.

P.O. Box756 Port Gibson , Mississippi 39150 Jeffery Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station Tel: 802-380-5124 GGNS TS 5.6.2*

GNRO2022-00014 April 21, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Grand Gulf Nuclear Station Annual Radiological Environmental Operating Report (AREOR)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 In accordance with Grand Gulf Nuclear Station Unit 1 Technical Specification 5.6.2, attached is the Annual Radiological Environmental Operating Report (AREOR) for the time-period of January 1, 2021 through December 31, 2021 .

There are no commitments contained in this submittal. If you have any questions or need additional information, please contact Jeff Hardy at 802-380-5124.

Sincerely,

~~

JH/ram

GNRO2022-00014 Page 2 of 2 cc: NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson , MS 39150 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

} entergy Page 1 of 59 Plant: Grand Gulf Nuclear Station YEAR: 2021 Document Number: GNRO 2022-00014 Annual Radiological Environmental Operating Report

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 2 of 59 Annual Radioloaical Environmental Operating Report TABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

.......................... ............ .. .. ........................ ... ......... ............................... 3

2.0 INTRODUCTION

........ ..................................................................... .. ... ........... ..................... ....... 5 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS .. ..... ... .... ..... ... 6 4.0 INTERPRETATION AND TRENDS OF RESULTS .... .......... .......... ........... ..... ............... ............. 17 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

.. ............. ........... 21 ATTACHMENTS - Sample Deviations ..................... .... .. ...... ......... .................. .... .... .... .... ....................... .... .28 - Monitoring Results Tables ..... .... .. .... ..... ... .. .. .... ............ ... ....... .. .... .... .... .... ........... .. .. .. .... 29 - lnterlaboratory Comparison Program Results .. ...... .. .... .. .. .. ........ .. ................................ .44

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 3 of 59 Annual Radiological Environmental Operating Report 1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report presents data obtained through analyses of environmental samples collected for Grand Gulf Nuclear Station (GGNS) Radiological Environmental Monitoring Program (REMP) for the period January 1 through December 31, 2021. This report fulfills the requirements of Grand Gulf Nuclear Station Technical Specification 5.6 .2.

All required lower limit of detection (LLD) capabilities were achieved in all sample analyses during 2021, as required by the GGNS Offsite Dose Calculation Manual (ODCM) Specifications Table 6.12.1-3. No measurable levels of radiation above baseline levels attributable to GGNS operation were detected in the vicinity of GGNS .

The 2021 Radiological Environmental Monitoring Program thus substantiated the adequacy of source control and effluent monitoring at GGNS with no observed impact of plant operations on the environment.

GGNS established the REMP in 1978 prior to the station's becoming operational (1985) to provide data on background radiation and radioactivity normally present in the area. GGNS has continued to monitor the environment by sampling air, water, sediment, fish and food products, as well as measuring direct radiation. GGNS also samples milk if milk-producing animals used for human consumption are present within five miles (8 km) of the plant.

The REMP includes sampling indicator and control locations within an approximate 20-mile radius of the plant. The REMP utilizes indicator locations near the site to show any increases or buildup of radioactivity that might occur due to station operation and control locations farther away from the site to indicate the presence of only naturally occurring radioactivity. GGNS personnel compare indicator results with control and preoperational results to assess any impact GGNS operation might have had on the surrounding environment.

In 2021, environmental samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. It was concluded that no significant relationship exists between GGNS operation and effect on the area around the plant. The review of 2021 data showed radioactivity levels in the environment were undetectable in many locations and near background levels in significant pathways.

1.2 Reporting Levels When averaged over any calendar quarter, no environmental samples equaled or exceeded reporting levels for radioactivity as outlined in ODCM Specifications Table 6.12.1-2; the analytical results did not trigger any Radiological Monitoring Program Special Reports.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 4 of 59 Annual Radiological Environmental Operating Report 1.3 Comparison to State and/or Federal Program GGNS personnel compared REMP data to state monitoring programs as results became available. Historically, the programs used for comparison have included the U.S. Nuclear Regulatory Commission (NRC) Thermoluminescent Dosimeter (TLD)

Direct Radiation Monitoring Network and the Mississippi State Department of Health (MSDH) , Division of Radiological Health monitoring program .

The NRC TLD Network Program was discontinued in 1998. Historically these results have compared to those from the GGNS REMP . GGNS TLD results continue to remain similar to the historical average and continue to verify that plant operation is not affecting the ambient radiation levels in the environment.

The MSDH and the GGNS REMP entail sim ilar radiological environmental monitoring program requirements. These programs include collecting air samples and splitting or sharing sample media such as water, sediment, and fish . Both programs have obtained similar results over previous years.

1.4 Sample Deviations During 2021, environmental sampling was performed for 5 media types addressed in the ODCM and for direct radiation. A total of 369 samples of the 377 scheduled were obtained. Of the scheduled samples, 98 percent were collected and analyzed in accordance with the requirements specified in the ODCM. Attachment 1 contains the listing of sample deviations and actions taken.

1.5 Program Modifications There were no program modifications during the reporting period .

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 5 of 59 Annual Radioloaical Environmental Operatina Report

2.0 INTRODUCTION

2.1 Radiological Environmental Monitoring Program GGNS established the REMP to ensure that plant operating controls properly function to minimize any associated radiation endangerment to human health or the environment. The REMP is designed for:

Analyzing applicable pathways for anticipated types and quantities of radionuclides released into the environment.

  • Considering the possibility of a buildup of long-lived radionuclides in the environment and identifying physical and biological accumulations that may contribute to human exposures .
  • Considering the potential radiation exposure to plant and animal life in the environment surrounding GGNS.
  • Correlating levels of radiation and radioactivity in the environment with radioactive releases from station operation.

2.2 Pathways Monitored The airborne, direct radiation, waterborne and ingestion pathways are monitored as required by GGNS ODCM Table 6.12.1-1. A description of the REMP utilized to monitor the exposure pathways is described in the attached Tables and Figures.

Section 4 .0 of this report provides a discussion of 2021 sampling results with Section 5.0 providing a summary of results for the monitored exposure pathways.

2.3 Land Use Census GGNS conducts a land use census biennially, as required by Section 6.12.2 of the ODCM. The purpose of this census is to identify changes in uses of land within five miles of GGNS that would require modifications to the REMP and the ODCM. The most important criteria during this census are to determine the location in each sector of the nearest occupied residence, unoccupied residence, garden, and milking animal.

Plant: Grand Gulf Nuclear Station I Year: 2021 T Page 6 of 59 Annual Radiological Environmental O_p_erating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway - Airborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency RADIOIODINE AND PARTICULATES AS-7 (Sector H, 0.5 miles) -

South-southeast of GGNS at 1 sample close to the SITE BOUNDARY the IBEW Union Hall having the highest calculated annual average ground level D/Q.

RADIOIODINE AND PARTICULATES AS-1 (Sector G, 5.5 miles)-

Southeast of GGNS at the

  • Radioiodine Canisters 131 analysis every 7 days 1 sample from the vicinity of a community having the highest calculated annual average Port Gibson City Barn
  • Air Particulate - Gross beta radioactivity analysis 7 days, or more frequently if following filter change ground level D/Q.

required by dust loading.

  • Air Particulate - Gamma Isotopic composite (by RADIOIODINE AND PARTICULATES AS-20 (Sector L, 0.9 miles) - location) every 92 days South-southeast of GGNS at 1 sample from the vicinity of a community the former Glodjo residence having the highest calculated annual average ground level D/Q.

RADIOIODINE AND PARTICULATES AS-3 (Sector B, 18 miles) -

North of the Vicksburg Airport 1 sample from a control location 15 - 30 km distance.

Plant: Grand Gulf Nuclear Station ] Year: 2021 ] Page 7 of 59 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS

  • M-16 (Sector A, Radius 0.9 Miles) - Meteorological Tower.

An inner ring of stations in the general areas 92 days Gamma dose; 92 days of the SITE BOUNDARY.

  • M-19 (Sector E, Radius 0.5 MIies) - Eastern SITE BOUNDARY Property line, North-northeast of HWSA
  • M-21 (Sector J, Radius 0.4 Miles) - Near Former Training Center Building on Bald Hill Road.
  • M-22 (Sector G, Radius 0.5 Miles) - Former RR Entrance Crossing On Bald Hill Road.
  • M-23 (Sector Q, Radius 0.5 Miles) - Gin Lake Road 50 Yards North of Heavy Haul Road on Power Pole.
  • M-25 (Sector N, Radius 1.6 Miles)- Radial Well Number 1.
  • M-28 (Sector L, Radius 0.9 Miles) - Bald Hill Road.
  • M-94 (Sector R, Radius 0.8 Miles)- Sector R Near Meteorological Tower.
  • M-95 (Sector F, Radius 0.5 mi)-

Spoils Area, fence of old storage area, near entrance gate

Plant: Grand Gulf Nuclear Station I Year: 2021 J Page 8 of 59 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS

  • M-96 (Sector B, Radius 0. 7 ml.) -

North Gate Fence An inner ring of stations in the general areas 92 days Gamma dose; 92 days of the SITE BOUNDARY.

  • M-97 (Sector D, Radius 0.8 ml.) -

Grand Gulf Road entrance gate to spoils area

  • M-98 (Sector H, Radius 0.5 mi.) -

Bald Hill Road, across from Union Hall, in curve

  • M-99 (Sector K, Radius 0.4 mi.) -

North Fence of old Ball Field near utility pole

  • M-100 (Sector C, Radius 0.6 mi.)

- Grand Gulf Road

Plant: Grand Gulf Nuclear Station j Year: 2021 j Page 9 of 59 Annual Radiological Environmental Operating R~port Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS

  • M-36 (Sector P, Radius 5.0 MIies) - Curve on HW 608, Point An outer ring of stations approximately 3 to 5 92 days Gamma dose: 92 days Nearest GGNS at Power Pole.

miles from the site.

  • M-40 (Sector M, Radius 2.3 Miles) - Headly Drive, Near River Port Entrance.
  • M-48 (Sector K, Radius 4.8 Miles) - 0.4 Miles South on Mont Gomer Road on West Side.
  • M-49 (Sector H, Radius 4.5 MIies) - Fork in Bessie Weathers Road/Shaifer Road.
  • M-50 (Sector B, Radius 5.3 Miles) - Panola Hunting Club Entrance.
  • M-55 (Sector D, Radius 5.0 Miles) - Near lngelside Karnac Ferry Road/Ashland Road Intersection.
  • M-57 (Sector F, Radius 4.5 Miles) - Hwy 61, Behind the Welcome to Port Gibson Sign at Glensdale Subdivision.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 10 of 59 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS

  • M-01 (Sector E, Radius 3.5 MIies) -Across the road from Additional stations in special interest areas 92 days Gamma dose; 92 days Lake Claiborne Entry Gate.

such as population centers, nearby (Special) residences, schools, and in 1 or 2 areas to serve as control locations.

  • M-07 (Sector G, Radius 5.5 Miles)-AS-1 PG, Port Gibson City Barn. (Special)
  • M-09 (Sector D, Radius 3.5 Miles)-Warner Tully Y-Camp.

(Special)

  • M-10 (Sector A, Radius 1.5 MIies) - Grand Gulf Military Park.

(Special)

  • M-14 (Sector B, Radius 18.0 Mlles)-AS-3-61VA, Hwy 61 ,

North of Vicksburg Airport.

(Control)

  • M-33 (Sector P, Radius 12.5 MIies) - Newellton, Louisiana Water Tower. (Control)
  • M-38 (Sector M, Radius 9.5 MIies) - Lake Bruin State Park, Entrance Road. (Special)
  • M-39 (Sector M, Radius 13.0 Miles) - St. Joseph, Louisiana, Auxiliary Water Tank. (Special)

Plant: Grand Gulf Nuclear Station j Year: 2021 j Page 11 of 59 Annual Radiological Envil'_onmental Qperating R_eport Table 3, Exposure Pathway - Waterborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency

  • MRUP (Sector R, Radius 1.8 Miles) - At least 4500 ft upstream 92 days Gamma isotopic and tritium analysis; 92 days of the GGNS discharge point into SURFACE WATER the Mississippi River to allow adequate mixing of the Mississippi 1 sample upstream and 1 sample and Big Black Rivers.

downstream.

  • MRDOWN (Sector N, Radius 1.6 Miles) - At least 5000 ft downstream of the GGNS discharge point in the Mississippi River near Radial Well No. 1.
  • MRDOWN (Sector P, Radius 1.3 Miles) - Downstream of the 1 sample downstream during a Liquid GGNS discharge point in the 366 days Gamma isotopic and tritium analysis; 366 days Radwaste Discharge.

Mississippi River near Radial Well No. 5.

1 sample from Outfall 007

  • OUTFALL 007 (Sector N, Radius 31 days Tritium; 31 days 0.2 MIies) - Storm Drain System
  • PGWELL (Sector G, Radius 5.0 MIies) - Port Gibson Wells -

366 days Gamma isotopic and tritium analysis; 366 days Taken from distribution system or GROUNDWATER one of the five wells.

Samples from 2 sources

  • CONSTWELL (Sector Q, Radius 0.4 Miles) - GGNS Construction Water Well - Taken from distribution system or the well.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 12 of 59 Annual Radiological Environmental Qperating Report Table 3, Exposure Pathway - Waterborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency SEDIMENT FROM SHORELINE

  • SEDHAM (Sector N, Radius 1.6 MIies) - Downstream of the 1 sample from downstream area and 1 366 days Gamma isotopic; 366 days GGNS discharge point in the sample from upstream area Mississippi River near Hamilton Lake outlet
  • SEDCONT (Minimum of 100 yds)

- Upstream of the GGNS discharge point in the Mississippi River.

Plant: Grand Gulf Nuclear Station l Year: 2021 I Page 13 of 59 Annual Radiological Environmental Operating Report Table 4, Exposure Pathway - Ingestion Sample Point Description Distance Sampling and Collection Requirement Type and Frequency Of Analyses and Direction Frequency MILK

  • If commercially available, 1 sample from
  • Currently, no available milking animals 92 days when required Gamma isotopic and 1-131 ; 92 days milking animals within 8 km distant within 8 km of GGNS.
  • 1 sample from milking animals at a
  • ALCONT (Sector K, Radius 10.5 control location >8 km distant when an MIies) - Located South-southwest of indicator location exists. GGNS at Alcorn State University.

(Control)

FISH AND INVERTEBRATES

  • FISHDOWN - Downstream of the GGNS discharge point into the
  • 1 sample in vicinity of GGNS discharge 366 days Gamma isotopic on edible portions; 366 days Mississippi River point.
  • 1 sample uninfluenced by GGNS
  • FISHUP - Upstream of the GGNS discharge point into the Mississippi discharge.

River uninfluenced by plant operations.

FOOD PRODUCTS

  • VEG-J (Sector J, Radius 0.4 Miles) -

South of GGNS near former Training

  • 1 sample of broadleaf vegetation grown in 92 days when available Gamma isotopic and 1-131 ; 92 days Center on Bald Hill Road.

one of two different offsite locations with highest anticipated annual average

  • VEG-CONT (Sector K, Radius 10.5 ground level D/Q if milk sampling is not Mlles)-Alcorn State University south-performed. southwest of GGNS when available, otherwise a location 15-30 km distant.
  • 1 sample of similar vegetation grown 15- (Control) 30 km distant if milk sampling is not performed.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 14 of 59 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway NUCLEAR POWER PLANT

)

LIQUID EFFLUENT

/.

0.rtel ld~ 1ion

..--::L I * ,.

TRANSPORT Exposure pathways to man

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 15 of 59 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field Ii:

~ ti ul 1 (]iii 'i~fr 11 * *.. I; w

i~!nU:11, ~ ~ ..

iii \. DO<] 8 00* $

I  !

  • I

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 16 of 59 Annual Radiological Environmental Operating Report Figure 3, Sample Collection Sites - Far Field I

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11 la)'

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Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 17 of 59 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample Results GGNS did not detect any plant related gamma emitting radionuclides in the quarterly air particulate composites. The REMP had previously detected airborne radioactivity attributable to other sources in this pathway. These sources include the Chinese nuclear test in 1980 and the accident at the Chernobyl Nuclear Power Plant in 1986.

The GGNS REMP detected radioactivity released from the Fukushima Dai-ichi Nuclear Power Plant following the March 11, 2011, Tohoku earthquake.

In 2021 there were no samples above the LLD for 1-131. Indicator gross beta air particulate results for 2021 were comparable to results obtained from 2011-2020 of the operational REMP. Also, the 2021 gross beta annual average was less than the average for preoperational levels. Results are reported as annual average picocuries per cubic meter (pCi/m 3).

Monitoring Period Result 2011 - 2020 (Minimum Value) 0.008 2021 Average Value 0.020 2011 - 2020 (Maximum Value) 0.041 Preoperational 0.032 In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. Table 3.1, which include gross beta concentrations and provide a comparison of the indicator and control means and ranges emphasizes the consistent trends seen in this pathway to support the presence of naturally occurring activity. Therefore, it can be concluded that the airborne pathway continues to be unaffected by Grand Gulf Nuclear Station operations.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 18 of 59 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results Grand Gulf Nuclear Station reports measured dose as net exposure (field reading less transit reading) normalized to 92 days and relies on comparison of the indicator locations to the control as a measure of plant impact. Grand Gulf Nuclear Station's comparison of the inner ring and special interest area TLD results to the control, as seen in Table 7, identified no noticeable trend that would indicate that the ambient radiation levels are being affected by plant operations. In addition, the inner ring value of 9.9 millirem/quarter (mR/Qtr) shown in Table 7 for 2021 is within the historical bounds of 2011 - 2020 annual average results, which have ranged from 9.3 to 10.0 mrem. Overall, Grand Gulf Nuclear Station concluded that the ambient radiation levels are not being affected by plant operations.

Table 5, Direct Radiation Annual Summary Control Location Year Inner Ring (mR/Qtr) Outer Ring (mR/Qtr)

(mR/Qtr) 2011 10.0 10.2 11.4 2012 9.5 9.7 11 .0 2013 9.8 9.7 10.8 2014 ' 10.0 9.9 11 .0 2015 9.6 9.5 10.8 2016 9.3 9.3 10.7 2017 9.9 9.9 11 .3 2018 9.7 9.8 10.6 2019 10.0 9.7 10.7 2020 9.6 9.4 10.7 2021 9.9 10.2 11 .7 4.3 Waterborne Sample Results Analytical results for 2021 surface water and drinking water samples were similar to those reported in previous years. Gamma radionuclides analytical results for 2021 surface water samples were similar to those reported in previous years. Tritium in Grand Gulf Nuclear Station surface water indicator samples continues to be detected, but is attributed to washout and entrainment of normal, previously monitored gaseous effluents. These results are further explained below.

4.3.1 Surface Water Samples were collected from two indicator locations (Outfall 007, MRDOWN) and one control location (MRUP) and analyzed for gamma emitting radionuclides and tritium . Plant related gamma emitting radionuclides and tritium remained undetectable in the upstream and downstream Mississippi River locations, which is consistent with previous operational years.

Storm waters contribute to Outfall 007 and can include tritium as a result of washout and

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 19 of 59 Annual Radioloaical Environmental Operating Report entrainment of normal, previously monitored gaseous effluents. As a result, tritium is occasionally observed. Tritium was measured at during February (926 pCi/L), May (2080 pCi/L), September (1010 pCi/L), October (6300 pCi/L), November (2230 pCi/L), and December (3510 pCi/L) at the Outfall 007 location. Tritium was also measured in the duplicate samples collected during February (1390 pCi/L), May (2380 pCi/L), September (1160 pCi/L),

October (6530 pCi/L), November (2460 pCi/L), and December (3860 pCi/L). Tritium was not observed in the remaining Outfall 007 samples collected during 2021. Results are reported as annual average pCi/1.

Monitoring Period Result 2011 - 2020 (Minimum Value) 905 2021 Average Value 2820 2011 - 2020 (Maximum Value) 3283 Preoperational 2739 In addition to the tritium samples required by the REMP, five special surface water samples for gamma emitting radionuclides were collected at the Outfall 007 location.

Plant related gamma emitting radionuclides remained undetectable in these samples.

Grand Gulf Nuclear Station personnel have noted no definable increasing trends associated with the tritium levels at the discharge location (Outfall 007). Levels detected during 2021 and previous operational years have been well below regulatory reporting limits. Therefore , the operation of Grand Gulf Nuclear Station had no definable impact on this waterborne pathway during 2021 and levels of radionuclides remain similar to those obtained in previous operational years.

4.3.2 Drinking Water Drinking water samples were collected from two locations, CONSTWELL (indicator) and PGWELL (control). Drinking water samples were analyzed for 1-131, gamma radionuclides and tritium. During 2021, gamma radionuclides, 1-131, and tritium concentrations were below the LLD limits at the indicator and control locations, which is consistent with previous operational years. Results are reported as annual average pCi/L.

Radionuclide 2021 2011 - 2020 Preoperational Gross Beta < LLD < LLD <LLD lodine-131 < LLD < LLD < LLD Gamma < LLD < LLD < LLD Tritium < LLD < LLD <LLD Grand Gulf Nuclear Station personnel have noted no definable trends associated with drinking water results at the indicator location. Therefore, the operation of Grand Gulf Nuclear Station had no definable impact on this waterborne pathway during 2021 and levels of radionuclides remain similar to those obtained in previous operational years.

Results from 2021 are summarized in Table 7.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 20 of 59 Annual Radiological Environmental Operating Report 4.3.3 Groundwater Groundwater monitoring data collected during administration of the Groundwater Protection Initiative (GPI) site program are included in the Annual Radioactive Effluent Release Report.

4.4 Soil Sample Results Sediment samples were collected from two locations in 2021 and analyzed for gamma radionuclides. Listed below is a comparison of 2021 indicator results to the 2011 - 2020 operational years. Grand Gulf Nuclear Station operations had no significant impact on the environment or public by this waterborne pathway. Results are reported as pCi/kg.

Monitoring Period Result 2011 - 2020 (Minimum Value) <LLD 2021 Value < LLD 2011 - 2020 (Maximum Value) 40.3 Preoperational 295.0 4.5 Ingestion Sample Results 4.5.1 Milk Sample Results Milk samples were not collected during 2021 due to the unavailability of indicator locations within five miles of Grand Gulf Nuclear Station.

4.5.2 Fish Sample Results Fish samples were collected from two locations and analyzed for gamma radionuclides. In 2021, gamma radionuclides were below detectable limits which are consistent with preoperational and operational years. Therefore, based on these measurements, Grand Gulf Nuclear Station operations had no significant radiological impact upon the environment or public by this ingestion pathway.

4.5.3 Food Product Sample Results The REMP has detected radionuclides prior to 1990 that are attributable to other sources. These include the radioactive plume release due to reactor core degradation at Chernobyl Nuclear Power Plant in 1986 and atmospheric weapons testing.

In 2021 , food product samples were collected from two locations and analyzed for plant related lodine-131 and gamma radionuclides. The 2021 levels remained undetectable, as has been the case in previous years. Therefore, based on these measurements, Grand Gulf Nuclear Station operations had no significant radiological impact upon the environment or public by this ingestion pathway.

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 21 of 59 Annual Radiological Environmental Operating Report 4.6 Land Use Census Results The latest land use census, performed in 2020, did not identify any new locations that yielded a calculated dose or dose commitment greater than those currently calculated.

The land use census identified no milk-producing animals within a five-mile radius of the plant site. In accordance with ODCM Section 6.12.1, Grand Gulf Nuclear Station personnel sampled broadleaf vegetation.

Table 6, Land Use Census - 2020 Nearest Residence Within Five Miles Sector Direction Nearest Residence (miles) Nearest Garden (miles)

A N 1.02 1.02 B NNE 1.51 1.52 C NE 0.70 4.14 D ENE 2.60 4.50 E E 0.83 0.91 F ESE 2.25 4.51 G SE 3.72 4.20 H SSE 1.10 4.31 J s 3.14 3.16 K SSW 2.20 2.18 L SW 0.89 0.89 M WSW none within 5 miles none within 5 miles N w none within 5 miles none within 5 miles p WNW none within 5 miles none within 5 miles Q NW none within 5 miles none within 5 miles R NNW 1.44 none within 5 miles The next land use census is scheduled to be conducted in 2022.

4.7 lnterlaboratory Comparison Results Teledyne Brown Engineering and Stanford Dosimetry analyzed interlaboratory comparison samples to fulfill the requirements of ODCM Specification 6.12.1. The results are shown in Attachment 3.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1. Table 7, Radiological Environmental Monitoring Program Summary, summarizes data for the 2021 REMP program.

Plant: Grand Gulf Nuclear Station I Year: 2021 J Page 22 of 59 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type/ Number Indicator Locations Mean Number of Sample Type LLD Mean (F)INote 31 Locations of Analyses (Note 21 Mean (F)INote 31 Non-Routine (Units) (Note 1) Mean (F)INote 31 Results [Note 61

[Range] Location [Note 41 [Range]

[Range]

GB/ 207 0.01 0.0199 (156 / 156) AS-1 PG 0.0203 (52 / 52) 0.0205 (52 / 52) 0 Air [0.0090 - 0.0388) (Sector G, 5.5 mi) [0.0107 - 0.0388) [0.0099 - 0.0356)

Particulates GS/ 16 (pCi/m 3) Cs-134 0.05 <LLD NIA NIA <LLD 0 CS-137 0.06 <LLD NIA NIA <LLD 0 Airborne 1-1311207 0.07 < LLD NIA NIA < LLD 0 Iodine (pCi/ m 3)

Inner Ring [Note6]

Gamma/ 54 9.86 (541 54) M-99 12.5 (4 / 4) NIA 0 TLDs (mR/Qtr)

[6.2 -13.8) (Sector J, 0.4 mi.) [12.0-13.8)

Outer Ring Gamma/ 26 [Note BJ 10.19 (26 / 26) M-55 11.7(4/4) 0 NIA TLDs (mR/Qtr) [5.1 -13.2) (Sector D, 5.0 mi.) [11.0-13.2)

Special Interest TLDs Gamma/ 27 [Note BJ 10.2 (27 / 27) M-01 12.0 (4 / 4) NIA 0 (mR/Qtr) [7.4 - 12.9) (Sector E, 3.5 mi.) [11.0 - 12.9)

Control TLD NIA 11.7(4/4) 0 Gamma/ 4 [Note6] NIA NIA (mR/Qtr) [10.2-13.1)

Plant: Grand Gulf Nuclear Station j Year: 2021 j Page 23 of 59 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type / Number Indicator Locations Mean Number of Sample Type LLD (Nata2) Mean (F)[Nata 3) Locations of Analyses Mean (F)INate 3) Non-Routine (Units) [Nota 1) Mean (F)INata 31 Results [Nata 61

[Range] Location !Nata 41 [Range]

[Range]

H-3 / 39 3000 2820 (12 / 32) Outfall 007 2820 (12 / 23) < LLD 0

[926-6530] (Sector N, 0.2 mi.) [926-6530]

GS/ 16 Mn-54 15 < LLD N/A N/A < LLD 0 Fe-59 30 < LLD N/A N/A < LLD 0 Co-58 15 < LLD N/A N/A < LLD 0 Co-60 15 < LLD N/A N/A < LLD 0 Surface Water Zn-65 30 < LLD N/A N/A < LLD 0 (pCi/1)

Zr-95 30 < LLD N/A N/A < LLD 0 Nb-95 15 < LLD N/A N/A < LLD 0 1-131 15 < LLD N/A N/A < LLD 0 Cs-134 15 < LLD N/A N/A < LLD 0 Cs-137 18 < LLD N/A N/A < LLD 0 Ba-140 60 < LLD N/A NIA < LLD 0 La-140 15 < LLD N/A N/A < LLD 0

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 24 of 59 Annual Radiological Envir~onmentaJQperating Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type/ Number Indicator Locations Mean Number of Sample Type LLD [Note 2) Mean (F)[Nota 31 Locations of Analyses Mean (F)INote 3J Non-Routine (Units) [Note 1] Mean (F)[Note 31 Results [Note 61

[Range] Location [Note 41 [Range]

[Range]

1-131 / 6 1 < LLD N/A N/A < LLD 0 H-3 / 6 2000 < LLD N/A N/A < LLD 0 GS/ 6 Mn-54 15 < LLD N/A N/A < LLD 0 Fe-59 30 < LLD N/A N/A < LLD 0 Drinking Water Co-58 15 < LLD N/A N/A < LLD 0 (pCi/1) Co-60 15 < LLD N/A N/A < LLD 0 Zn-65 30 < LLD N/A N/A < LLD 0 Zr-95 30 <LLD N/A NIA < LLD 0 Nb-95 15 < LLD N/A N/A < LLD 0 Cs-134 15 < LLD N/A N/A < LLD 0 Cs-137 18 < LLD N/A N/A < LLD 0 Ba-140 60 < LLD N/A N/A < LLD 0 La-140 15 < LLD N/A N/A < LLD 0 GS/4 Sediment Cs-134 150 < LLD N/A N/A N/A 0 (pCi/kg) Cs-137 180 < LLD N/A N/A N/A 0

Plant: Grand Gulf Nuclear Station I Y~ear: 2021 ~~ Page 25 of 59 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type/ Number Indicator Locations Mean Number of Sample Type LLD [Note 2) Mean (F)[Nota 31 Locations of Analyses Mean (F)lNote 3J Non-Routine (Units} [Note 1) Mean (F)[Note 31 Results [Note 61

[Range] Location [Note 41 [Range]

[Range]

GS/4 Mn-54 130 < LLD N/A N/A < LLD 0 Fe-59 260 < LLD N/A N/A < LLD 0 Fish (pCi/kg} Co-58 130 < LLD N/A N/A < LLD 0 Co-60 130 <LLD N/A N/A < LLD 0 Zn-65 260 < LLD N/A N/A < LLD 0 Cs-134 130 < LLD N/A N/A < LLD 0 Cs-137 150 < LLD N/A N/A < LLD 0 1-131 / 12 60 < LLD N/A N/A N/A 0 Food Products GS/ 12 (pCi/kg}

Cs-134 60 < LLD N/A N/A N/A 0 Cs-137 80 <LLD N/A NIA N/A 0

Plant: Grand Gulf Nuclear Station j Year: 2021 I Page 26 of 59 Annual Radiological Envj_l'_onmenta_l _Operatir_1g Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type/ Number Indicator Locations Mean Number of Sample Type LLD [NotazJ Mean (F)INota 31 Locations of Analyses Mean (F)INota 3J Non-Routine (Units) (Nota 1) Mean (F)INota 3J Results (Nata 61

[Range] Location INota 41 [Range]

[Range]

GS I 7 Mn-54 15 < LLD N/A N/A < LLD 0 Fe-59 30 < LLD N/A N/A <LLD 0 Co-58 15 < LLD N/A N/A < LLD 0 Co-60 15 < LLD N/A N/A < LLD 0 Surface Water Zn-65 30 < LLD N/A N/A < LLD 0 (Special) Zr-95 30 <LLD N/A N/A < LLD 0 (pCi/1) Nb-95 15 < LLD N/A N/A < LLD 0 Cs-134 15 < LLD N/A N/A < LLD 0 Cs-137 18 < LLD N/A N/A < LLD 0 Ba-140 60 < LLD N/A N/A < LLD 0 La-140 15 < LLD N/A N/A < LLD 0

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 27 of 59 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Location with the Highest Annual Control Type/ Number Indicator Locations Mean Number of Sample Type LLD (Nota2J Mean (F)(Nota 31 Locations of Analyses Mean (F)lNote 31 Non-Routine (Units) (Nota 1) Mean (F)lNota 31 Results (Nota 61

[Range] Location (Note 41 [Range]

[Range]

GS/ 1 Mn-54 130 < LLD NIA NIA < LLD 0 Fe-59 260 < LLD NIA NIA < LLD 0 Meat Co-58 130 <LLD NIA NIA < LLD 0 (Special)

(pCilkg) Co-60 130 < LLD NIA NIA < LLD 0 Zn-65 260 < LLD NIA NIA < LLD 0 Cs-134 130 < LLD NIA NIA < LLD 0 Cs-137 150 < LLD NIA NIA < LLD 0 LEGEND:

[Note 1] - GB= Gross beta; 1-131 = lodine-131; H-3 = Tritium; GS= Gamma scan.

[Note 2] - LLD = Required lower limit of detection based on ODCM Table 6.12.1-3.

[Note 3] - Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

[Note 4] -Where applicable, locations are specified (1) by name, (2) distance from reactor site, and (3) meteorological sector.

[Note 5] - Non-routine results are those which exceed ten times the control station value. If no control station value is available, the result is considered non-routine if it exceeds ten times the preoperational value for the location.

[Note 6]- LLD is not defined in ODCM Table 6.12.1-3.

Plant: Grand Gulf Nuclear Station l Year: 2021 ] Page 28 of 59 Annual Radiological Environmental Operating Report Attachment 1 Page 1 of 1 Sample Deviations Table 8, Sample Deviations Table Sample Comment Sample Media Date Problem Evaluation / Actions No. Location Affected Air sample locations AS-1 , AS-3, AS-7, and AS-20 had reduced runtimes due to weather related power outages (ice storm). Due to low sample volume, the AS-1, AS-3, Air Sampler required LLDs for AS-20 gross beta and 1-131 were not met. The AS-20 data 1 Air 02/23/21 AS-7, AS-20 Power Outage was excluded from data summary calculations, and the analytical results are included in data tables for information only. CR-GGN-2021-01470 documents the condition.

During collection of 1st quarter 2021 TLDs, monitoring location M-25 was Inaccessible 2 TLD M-25 04/05/21 inaccessible due to high Mississippi River water level. CR-GGN-2021-02653 TLD documents the condition.

During collection of 1st quarter 2021 TLDs, monitoring location M-40 was lost 3 TLD M-40 04/02/21 LostTLD due to road construction activities. A new TLD was installed at the location.

CR-GGN-2021-02616 documents the condition.

During collection of 2nd quarter 2021 TLDs, monitoring location M-25 was Inaccessible 4 TLD M-25 07/06/21 inaccessible due to high Mississippi River water level. CR-GGN-2021-05178 TLD documents the condition.

During collection of 2nd quarter 2021 TLDs, monitoring location M-33 was 5 TLD M-33 07/06/21 LostTLD lost due to building construction activities. A new TLD was installed at the location. CR-GGN-2021-05174 documents the condition.

During collection of 3rd quarter 2021 TLDs, monitoring location M-40 was 6 TLD M-40 10/04/21 LostTLD lost. The cause for the missing TLD was not determined. A new TLD was installed at the location. CR-GGN-2021-07512 documents the condition .

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 29 of 59 Annual Radiological Environmental Operating Report Page 1 of 15 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta Units: pCi/m 3 I

Station Station Station Station Start Date End Date AS-7 AS-20 AS-3 [Note 1)

AS-1 (Indicator)

(Indicator) (Indicator) (Control)

REQUIRED LLD + 0.01 0.01 0.01 0.01 12/29/20 01/05/21 0.01580 0.01520 0.01100 0.01420 01/05/21 01/12/21 0.02040 0.01870 0.01720 0.02080 01/12/21 01/19/21 0.02420 0.02040 0.02360 0.02120 01/19/21 01/26/21 0.01720 0.01840 0.01860 0.02220 01/26/21 02/02/21 0.02240 0.01790 0.02340 0.02370 02/02/21 02/09/21 0.01450 0.01960 0.01910 0.01740 02/09/21 02/17/21 0.02080 0.02160 0.01870 0.02590 02/17/21 02/23/21 0.03500 0.02230 0.22800(Note 2] 0.02310 02/23/21 03/02/21 0.01850 0.01670 0.01700 0.02060 03/02/21 03/09/21 0.01520 0.01200 0.01570 0.01580 03/09/21 03/16/21 0.01500 0.01410 0.01540 0.01400 03/16/21 03/23/21 0.01760 0.01460 0.01700 0.01370 03/23/21 03/30/21 0.01620 0.01580 0.01550 0.01440 03/30/21 04/06/21 0.02180 0.02030 0.02750 0.02240 04/06/21 04/13/21 0.01930 0.01840 0.01810 0.02050 04/13/21 04/20/21 0.01240 0.01570 0.01870 0.01750 04/20/21 04/27/21 0.01910 0.02120 0.01950 0.01800 04/27/21 05/04/21 0.01950 0.01970 0.02170 0.01670 05/04/21 05/11/21 0.01600 0.01790 0.01690 0.01800 05/11/21 05/18/21 0.01910 0.01740 0.01800 0.01450 05/18/21 05/25/21 0.01750 0.01850 0.01640 0.01380 05/25/21 06/01/21 0.01370 0.01260 0.01130 0.01380 06/01/21 06/08/21 0.01290 0.01390 0.01400 0.01510 06/08/21 06/15/21 0.01430 0.01460 0.01490 0.01530 06/15/21 06/22/21 0.01810 0.01920 0.01670 0.01910 06/22/21 06/29/21 0.01140 0.01190 0.01440 0.00993 06/29/21 07/06/21 0.01500 0.01330 0.01600 0.01350

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 30 of 59 Annual Radiological Environmental Operating Report Page 2 of 15 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta Units: pCi/m 3 I

Station Station Station Station Start Date End Date AS-7 AS-20 AS-3 (Note 1)

AS-1 (Indicator)

(Indicator) (Indicator) (Control)

REQUIRED LLD .+ 0.01 0.01 0.01 0.01 07/06/21 07/13/21 0.01200 0.00899 0.01110 0.01270 07/13/21 07/20/21 0.01380 0.01280 0.01490 0.01740 07/20/21 07/27/21 0.01920 0.01960 0.01870 0.02130 07/27/21 08/03/21 0.02520 0.02870 0.02580 0.02500 08/03/21 08/10/21 0.02930 0.02560 0.02770 0.02960 08/10/21 08/17/21 0.01070 0.01070 0.01100 0.01290 08/17/21 08/24/21 0.01490 0.01390 0.01690 0.01300 08/24/21 08/31/21 0.01460 0.01990 0.01540 0.01700 08/31/21 09/07/21 0.02030 0.01740 0.01880 0.02160 09/07/21 09/14/21 0.02400 0.02030 0.02420 0.02600 09/14/21 09/21/21 0.01070 0.00898 0.00997 0.01090 09/21/21 09/28/21 0.03000 0.02940 0.02630 0.02990 09/28/21 10/05/21 0.01410 0.01590 0.01390 0.01570 10/05/21 10/12/21 0.02630 0.02470 0.03010 0.03560 10/12/21 10/19/21 0.01840 0.01720 0.02320 0.01780 10/19/21 10/26/21 0.03360 0.03240 0.03130 0.03450 10/26/21 11/02/21 0.02060 0.01940 0.01810 0.02230 11/02/21 11/09/21 0.03350 0.03280 0.03220 0.02970 11/09/21 11/16/21 0.02780 0.02700 0.02580 0.02830 11/16/21 11/23/21 0.03110 0.02760 0.02720 0.03250 11/23/21 11/30/21 0.02980 0.02950 0.02580 0.02920 11/30/21 12/07/21 0.03880 0.03000 0.02940 0.03350 12/07/21 12/14/21 0.02560 0.02400 0.02780 0.02840 12/14/21 12/21/21 0.01850 0.02130 0.02080 0.01620 12/21/21 12/28/21 0.03130 0.02970 0.03190 0.02880

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 1

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 31 of 59 Annual Radiological Environmental Operating Report Page 3 of 15 Monitoring Results Tables Table 10, Radioiodine Cartridge Data Table Summary Analysis: 1-131 Units: pCi/m 3 I

AS-1 AS-7 AS-20 AS-3 Start Date End Date (Indicator) (Indicator) (Indicator) (Control)

REQUIRED LLD + 0.07 0.07 0.07 0.07 12/29/20 01/05/21 <0.03013 <0.0303 <0.02909 <0.0298 01/05/21 01/12/21 <0.02497 <0.02548 <0.02548 <0.01659 01/12/21 01/19/21 <0.04214 <0.0427 <0.04236 <0.04205 01/19/21 01/26/21 <0.02385 <0.02393 <0 .02356 <0.02314 01/26/21 02/02/21 <0.03603 <0.03614 <0.0363 <0.03533 02/02/21 02/09/21 <0.04267 <0.04397 <0.04278 <0.04195 02/09/21 02/17/21 <0.03102 <0.03074 <0.03169 <0.03043 02/17/21 02/23/21 <0.04697 <0.05151 <0.5912[Note 1) <0.03936 02/23/21 03/02/21 <0.03366 <0.03342 <0.03403 <0.03255 03/02/21 03/09/21 <0.01734 <0.01765 <0.01754 <0.01697 03/09/21 03/16/21 <0.03579 <0.03491 <0.0359 <0.03431 03/16/21 03/23/21 <0.04056 <0.03999 <0.04098 <0.03952 03/23/21 03/30/21 <0.02661 <0.02551 <0.02676 <0.02616 03/30/21 04/06/21 <0.03081 <0.03025 <0.03077 <0.02926 04/06/21 04/13/21 <0.01585 <0.01585 <0.01603 <0.01512 04/13/21 04/20/21 <0.02191 <0.02163 <0.02209 <0.02104 04/20/21 04/27/21 <0.03618 <0.03685 <0.03782 <0.03433 04/27/21 05/04/21 <0.03003 <0.02984 <0.03025 <0.02886 05/04/21 05/11/21 <0.03864 <0.04593 <0 .04535 <0.03887 05/11/21 05/18/21 <0.02855 <0.02835 <0.02949 <0.02295 05/18/21 05/25/21 <0.03047 <0.02965 <0.03073 <0.02946 05/25/21 06/01/21 <0.02841 <0.02783 <0.02861 <0.02703 06/01/21 06/08/21 <0.04667 <0.04649 <0.04712 <0.04446 06/08/21 06/15/21 <0.03657 <0.03636 <0.03704 <0.03464 06/15/21 06/22/21 <0.01935 <0.01902 <0 .01959 <0.0184 06/22/21 06/29/21 <0.036 <0.03608 <0.0363 <0.03598 06/29/21 07/06/21 <0.03461 <0.03492 <0.03482 <0.03557

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 32 of 59 Annual Radiological Environmental Operating Report Page 4 of 15 Monitoring Results Tables Table 10, Radioiodine Cartridge Data Table Summary Analysis: 1-131 Units: pCi/m 3 I

AS-1 AS-7 AS-20 AS-3 Start Date End Date (Indicator) (Indicator) (Indicator) (Control)

REQUIRED LLD -+ 0.07 0.07 0.07 0.07 07/06/21 07/13/21 <0.0362 <0.03638 <0.03711 <0.03674 07/13/21 07/20/21 <0.03198 <0.0319 <0.03281 <0.03285 07/20/21 07/27/21 <0.0365 <0.03649 <0.03694 <0.03739 07/27/21 08/03/21 <0.03974 <0.04204 <0 .04247 <0.04108 08/03/21 08/10/21 <0 .03643 <0.03729 <0.03754 <0.03754 08/10/21 08/17/21 <0.02693 <0.0275 <0 .01421 <0.02802 08/17/21 08/24/21 <0.0203 <0.02076 <0.02118 <0.02098 08/24/21 08/31/21 <0.02636 <0.03662 <0.0336 <0.02791 08/31/21 09/07/21 <0.01963 <0.02017 <0.02035 <0.0195 09/07/21 09/14/21 <0.03342 <0.03266 <0 .03367 <0.03379 09/14/21 09/21/21 <0.052 <0.05059 <0.05248 <0.05269 09/21/21 09/28/21 <0.03201 <0.03162 <0.0329 <0.03276 09/28/21 10/05/21 <0.03764 <0.03742 <0.03904 <0.03873 10/05/21 10/12/21 <0.02707 <0.02686 <0.02806 <0.02806 10/12/21 10/19/21 <0.04026 <0.04024 <0.04188 <0.04145 10/19/21 10/26/21 <0.01589 <0.03117 <0 .03261 <0.03318 10/26/21 11/02/21 <0.04283 <0.04378 <0.04517 <0.04455 11/02/21 11/09/21 <0.02977 <0.03028 <0 .03139 <0.03123 11/09/21 11/16/21 <0.02321 <0.02345 <0 .02443 <0.0244 11/16/21 11/23/21 <0.04294 <0.04343 <0.04505 <0.04439 11/23/21 11/30/21 <0.02842 <0.02899 <0.0299 <0.02969 11/30/21 12/07/21 <0.02915 <0.02984 <0.03092 <0.03056 12/07/21 12/14/21 <0.02772 <0.02841 <0.02919 <0.02894 12/14/21 12/21/21 <0.02194 <0.02229 <0.02306 <0.02327 12/21/21 12/28/21 <0.02833 <0.02855 <0 .01403 <0.02891

[Note 1]- Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 1

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 33 of 59 Annual Radiological Environmental Operating Report Page 5 of 15 Monitoring Results Tables Table 11, Air Gamma Quarterly Composite Analysis: Gamma Isotopic Units: pCi/cu.m Location Date CS-134 CS-137 REQUIRED LLD + 0.05 0.06 AS-1 <0 .002278 <0 .001452 AS-3 <0.001326 <0.001052 02/12/21 AS-7 <0.001495 <0.00126 AS-20 <0.002218 <0 .001994 AS-1 <0.002422 <0 .001861 AS-3 <0.0021 <0.001923 05/14/21 AS-7 <0.001928 <0.001669 AS-20 <0.002531 <0.001925 AS-1 <0.002446 <0 .001978 AS-3 08/13/21 <0.003193 <0.002981 AS-7 <0.002989 <0.00209 AS-20 <0.002875 <0.001924 AS-1 <0.001645 <0.001512 AS-3 <0.002066 <0.001946 11/12/21 AS-7 <0.002402 <0.00254 AS-20 <0.001307 <0.001228

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 34 of 59 Annual Radiological Environmental Operating Report Page 6 of 15 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mrem I

Annual Station 1st Qtr 2021 2 nd Qtr 2021 3 rd Qtr 2021 4 th Qtr 2021 Mean 2021 M-16 10.2 11.0 10.3 12.0 10.9 M-19 8.7 9.5 9.2 11.1 9.6 M-21 11 .6 12.3 12.3 13.4 12.4 M-22 8.1 8.5 8.3 9.4 8.6 M-23 8.4 7.4 8.3 9.6 8.4 M-25 Lost[Nole 2] Lost[Nole 3] 8.4 9.3 8.8 M-28 10.1 10.8 10.9 12.1 11.0 M-94 9.8 10.1 9.9 11.6 10.4 M-95 6.4 6.2 7.4 7.4 6.9 M-96 8.0 8.0 8.1 9.1 8.3 M-97 7.5 7.7 7.4 8.1 7.6 M-98 11 .0 11.1 12.2 12.8 11.8 M-99[Note 1] 12.1 12.2 12.0 13.8 12.5 M-100 10.5 11.1 9.8 10.1 10.4

[Note 1]- Station with highest annual mean.

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 2

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 3

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 35 of 59 Annual Radiological Environmental Operating Report Page 7 of 15 Monitoring Results Tables Table 13, Thermoluminescent Dosimeters - Outer Ring Analysis: Gamma Dose Units: mrem I

Annual Mean Station 1st Qtr 2021 2nd Qtr 2021 3 rd Qtr 2021 4th Qtr 2021 2021 M-36 7.8 8.2 8.9 9.8 8.7 M-40 Lost[Note 2] 5.1 Lost(Note 3] 6.7 5.9 M-48 9.5 9.7 10.3 11 .6 10.3 M-49 10.5 10.5 11.4 12.1 11 .1 M-50 9.0 9.1 10.2 11 .6 9.9 M-55[Note 1] 11 .0 11 .1 11 .3 13.2 11 .6 M-57 10.4 11 .5 11 .9 12.7 11 .6

[Note 1]- Station with highest annual mean.

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 4

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 5 Table 14, Thermoluminescent Dosimeters - Special Interest Areas Analysis: Gamma Dose Units: mrem I

Annual Mean Station 1st Qtr 2021 2 nd Qtr 2021 3 rd Qtr 2021 4 th Qtr 2021 2021 M-01[Note1] 11 .0 11.8 12.2 12.9 12.0 M-07 9.8 11.2 10.5 12.0 10.9 M-09 9.9 10.2 10.2 11.4 10.4 M-10 8.5 9.1 9.3 10.0 9.2 M-33 7.4 Lost[Note 2] 10.6 12.5 10.2 M-38 9.0 9.0 10.0 11 .3 9.8 M-39 8.6 8.6 8.8 9.9 9.0

[Note 1]- Station with highest annual mean .

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Comment 6 Table 15, Thermoluminescent Dosimeters- Control Analysis: Gamma Dose Units: mrem I

Annual Mean Station 1st Qtr 2021 2nd Qtr 2021 3 rd Qtr 2021 4th Qtr 2021 2021 M-14 10.2 11 .6 11 .8 13.1 11.7

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 36 of 59 Annual Radiological Environmental Operating Report Attachment 2 Page 8 of 15 Monitoring Results Tables Table 16, Surface Water - Gamma Analysis: Gamma Isotopic Units: pCi/L Location Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 1-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD + 15 15 30 15 30 15 30 15 15 18 60 15 MRDOWN 02/03/21 <6.201 <6.632 <16.6 <8.541 <13.31 <7.019 <10.62 <13.52 <6.236 <7.916 <32.51 <9.547 (Indicator)

MRUP 02/03/21 <6.482 <6.426 <15.64 <5.432 <14.45 <5.764 <11.24 <10.8 <6.424 <6.57 <34.02 <10.49 (Control)

MRDOWNGG 02/03/21 <5.218 <4.648 <11.29 <5.684 <8.778 <6.114 <10.25 <5.066 <3.486 <5.967 <21.16 <7.571 (Indicator)

MRUPGG 02/03/21 <6.837 <7.163 <18.15 <7.568 <14.67 <6.171 <16.26 <12.97 <8.71 <8.027 <33.93 <13.4 (Control)

MRDOWN 05/06/21 <6.85 <4.679 <7.035 <6.344 <14.75 <5.909 <11.77 <9.349 <6.609 <5.879 <28.98 <6.834 (Indicator)

MRUP 05/06/21 <5.971 <6.029 <11.1 <5.331 <8.992 <6.62 <13.44 <10.87 <6.653 <6.028 <30.2 <9.968 (Control)

MRDOWN 08/05/21 <6.702 <5.864 <16.34 <6.761 <14.77 <6.765 <9.605 <9.598 <7.23 <6.831 <26.41 <10.64 (Indicator)

MRUP 08/05/21 <5.31 <4.57 <9.425 <3.78 <7.811 <5.264 <9.009 <7.18 <5.017 <5.236 <19.81 <6.566 (Control)

MRDOWNGG 08/05/21 <6.336 <3.929 <11.39 <5.367 <12.61 <6.212 <10.41 <10.93 <6.409 <5.386 <24.44 <9.467 (Indicator)

MRUPGG 08/05/21 <4.782 <4.873 <12.95 <5.66 <14.17 <5.686 <10.87 <8.573 <5.54 <4.87 <28.01 <11 .81 (Control)

Plant: Grand Gulf Nuclear Station J Year: 2021 l Page 37 of 59 Annual Radiological Environmental Operating Report Attachment 2 Page 9 of 15 Monitoring Results Tables Table 16, Surface Water - Gamma Analysis: Gamma Isotopic Units: pCi/L Location Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 1-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD + 15 15 30 15 30 15 30 15 15 18 60 15 MRDOWN 11/04/21 <7.981 <7.422 <13.36 <8.663 <13.68 <8.994 <15.44 <13.71 <7.654 <7.234 <44.92 <8.26 (Indicator)

MRUP 11/04/21 <4.718 <4.659 <8.575 <6.252 <10.52 <7.18 <9.698 <8.449 <5.909 <5.379 <28 <9.834 (Control)

MRDOWNGG 11/04/21 <4.786 <4.381 <9.244 <5.787 <8.606 <5.173 <9.034 <8.28 <4.559 <4.794 <25.36 <8.551 (Indicator)

MRUPGG 11/04/21 <4.763 <5.559 <11.75 <5.224 <10.82 <7.552 <8.232 <9.537 <4.481 <5.713 <27.9 <5.973 (Control)

MRDOWN*

11/05/21 <5.674 <5.355 <11.44 <4.803 <9.748 <7.021 <9.153 <14.09 <5.658 <7.214 <36.48 <10.4 (Indicator)

MRDOWNGG*

11/05/21 <6.314 <5.688 <11.8 <5.94 <12.94 <5.398 <10.46 <13.39 <5.434 <6.174 <37.33 <9.397 (Indicator)

GG - indicates duplicate sample

  • - indicates annual sample collected during liquid effluent discharge

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 38 of 59 Annual Radiological Environmental Operating Report Page 100 of 155 Monitoring Results Tables Table 17, Surface Water - Tritium Analysis: H-3 Units: pCi/L Location Date H-3 REQUIRED LLD + 3000 OUTFALL 007 01/19/21 <512 OUTFALL 007 GG 01/19/21 <502 MRDOWN 02/03/21 <505 MRUP 02/03/21 <504 MRDOWNGG 02/03/21 <501 MRUP GG 02/03/21 <496 OUTFALL 007 02/23/21 926 OUTFALL 007 GG 02/23/21 1390 OUTFALL 007 03/12/21 <479 OUTFALL 007 GG 03/12/21 <472 OUTFALL 007 04/20/21 <527 OUTFALL 007 GG 04/20/21 <555 MRDOWN 05/06/21 <522 MRUP 05/06/21 <551 OUTFALL 007 05/18/21 2080 OUTFALL 007 GG 05/18/21 2380 OUTFALL 007 06/15/21 <574 OUTFALL 007 GG 06/15/21 <573 OUTFALL 007 07/20/21 <525 MRDOWN 08/05/21 <531 MRUP 08/05/21 <525 MRDOWNGG 08/05/21 <535 MRUP GG 08/05/21 <528 OUTFALL 007 08/18/21 <523 OUTFALL 007 GG 08/18/21 <514

Plant: Grand Gulf Nuclear Station I Rev. 2021 I Page 39 of 59 Annual Radiological Environmental Operating Report Page 11 of 15 Monitoring Results Tables Table 17, Surface Water-Tritium Analysis: H-3 Units: pCi/L Location Date H-3 OUTFALL 007 09/14/21 1010 OUTFALL 007 GG 09/14/21 1160 OUTFALL 007 10/19/21 6300 OUTFALL 007 GG 10/19/21 6530 MRDOWN 11/04/21 <508 MRUP 11/04/21 <477 MRDOWNGG 11/04/21 <558 MRUP GG 11/04/21 <498 MRDOWN* 11/05/21 <501 MRDOWNGG* 11/05/21 <536 OUTFALL 007 11/16/21 2230 OUTFALL 007 GG 11/16/21 2460 OUTFALL 007 12/14/21 3510 OUTFALL 007 GG 12/14/21 3860 GG - indicates duplicate sample

  • - indicates Annual Sample collected during liquid discharge

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 40 of 59 Annual Radiological Environmental Operating Report Attachment 2 Page 122 of 15 Monitoring Results Tables Table 18, Drinking Water-Gamma, 1-131 Analysis: Gamma Isotopic, 1-131 Units: pCi/L Location Date 1-131 Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD + 1 15 15 30 15 30 15 30 15 18 60 15 CONSTWELL 3 11/10/21 <0.589 <6.701 <5.942 <11 .72 <7.329 <14.73 <6.888 <10.48 <6.098 <7.104 <24.74 <8.693 CONSTWELL 3 GG 11/10/21 <0.589 <6.411 <6.63 <9.803 <5.568 <12.14 <5.061 <11.1 <7.99 <6.766 <22.16 <9.491 CONSTWELL4 11/10/21 <0.757 <6.481 <5.714 <14.77 <4.974 <14.22 <6.539 <10.79 <6.475 <6.679 <21.58 <6.832 CONSTWELL 4 GG 11/10/21 <0.824 <5.15 <5.835 <11 .16 <8.789 <11.83 <6.149 <11.06 <7.52 <7.034 <23.01 <6.461 PGWELL 11/10/21 <0.656 <7.054 <9.511 <21.7 <8.799 <16.92 <8.871 <13.24 <9.107 <9.181 <26.98 <8.97 PGWELLGG 11/10/21 <0.909 <6.665 <5.543 <13.43 <5.349 <15.2 <7.414 <9.914 <6.34 <5.246 <20.25 <8.286 GG - indicates duplicate sample

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 41 of 59 Annual Radiological Environmental Operating Report Page 13 of 155 Monitoring Results Tables Table 19, Drinking Water - Tritium Analysis: H-3 Units: pCi/L Location Date H-3 REQUIRED LLD :t 2000 CONSlWELL 3 11/10/21 <495 CONSlWELL 3 GG 11/10/21 <516 CONSlWELL4 11/10/21 <487 CONSlWELL 4 GG 11/10/21 <482 PGWELL 11/10/21 <483 PGWELL GG 11/10/21 <486 GG - indicates duplicate sample Table 20, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Date Cs-134 Cs-137 REQUIRED LLD ~ 150 180 SEDHAM 09/07/21 <72.71 <62.09 SEDHAM GG 09/07/21 <64.31 <51 .98 SEDCONT 09/07/21 <65.2 <50.24 SEDCONTGG 09/07/21 <72.73 <65 .1 GG - indicates duplicate sample

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 42 of 59 Annual Radiological Environmental Operating Report Attachment 2 Page 144 of 155 Monitoring Results Tables Table 21, Fish Analysis: Gamma Isotopic Units: pCi/kg Collection Location Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 Date REQUIRED LLD + 130 130 260 130 260 130 150 FISHDOWN 09/01 /21 <68.33 <60.12 <124.3 <65.91 <107.6 <45.78 <55.18 FISHDOWN GG 09/01/21 <56.8 <56.56 <113.9 <51.67 <81.87 <61.77 <61.47 FISHUP 09/01 /21 <46.14 <41.1 <124 <49.72 <100.7 <54.75 <46.29 FISHUP GG 09/01/21 <48.42 <66.81 <111.7 <62.27 <76.07 <48.4 <45.79 Table 22, Food Products Analysis: Gamma Isotopic, 1-131 Units: pCi/kg Location Collection Date 1-131 Cs-134 Cs-137 REQUIRED LLD + 60 60 80 VEG-CONT 02/24/21 <23.11 <27.31 <24.57 VEG-J 02/24/21 <28.87 <28.45 <27.19 VEG-CONT 05/19/21 <32.61 <36.51 <30.85 VEG-CONTGG 05/19/21 <36.55 <33.88 <32.78 VEG-J 05/19/21 <28.1 <28.86 <29.78 VEG-J GG 05/19/21 <23.79 <27.16 <26.95 VEG-CONT 08/12/21 <20.62 <21.37 <17.34 VEG-J 08/12/21 <30.16 <32.72 <33.34 VEG-CONT 11/17/21 <24.01 <18.4 <11 .09 VEG-CONTGG 11/17/21 <21.72 <15.77 <17.09 VEG-J 11/21/21 <12.83 <15.62 <13.43 VEG-J GG 11/21/21 <19.32 <19.43 <16 .75 GG - indicates duplicate sample

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 43 of 59 Annual Radiological Environmental Operating Report Attachment 2 Page 15 of 15 Monitoring Results Tables Table 23, Special Samples, Surface Water Analysis: Gamma Isotopic Units: pCi/L Location Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 1-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD + 15 15 30 15 30 15 30 15 15 18 60 15 OUTFALL007 03/12/21 <6.329 <6.532 <15.59 <5.738 <11.15 <7.518 <10.86 <12.7 <6.925 <6.113 <35.49 <14.07 OUTFALL 007 GG 03/12/21 <6.134 <6.008 <12.3 <6.492 <10.62 <6.813 <9.705 <13.36 <6.623 <6.735 <30.64 <9.914 OUTFALL 007 06/08/21 <6.186 <5.977 <12.83 <6.325 <11.45 <5.224 <11.6 <11.47 <6.618 <7.302 <31.91 <11.52 OUTFALL 007 09/29/21 <5.922 <6.955 <16.05 <5.948 <15.46 <8.641 <12.7 <13.84 <7.815 <9.872 <36.25 <13.59 OUTFALL 007 GG 09/29/21 <5.887 <8.354 <17.98 <8.933 <13.78 <7.078 <14.76 <10.67 <5.528 <7.64 <28.4 <11.33 OUTFALL 007 12/14/21 <5.195 <5.707 <11.04 <6.656 <16.26 <4.628 <11.31 <10.42 <6.429 <7.487 <29.63 <10.88 OUTFALL 007 GG 12/14/21 <5.317 <6.459 <11.75 <5.249 <11.86 <6.467 <9.237 <10.8 <5.582 <6.162 <24.65 <10.82 GG - indicates duplicate sample Table 24, Special Samples, Meat Analysis: Gamma Isotopic Units: pCi/kg Location I Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 REQUIRED LLD + 130 130 260 130 260 130 150 DEER j 12120I21 <96.5 <74.6 <162 <98.69 <200.5 <78.52 <95.03

Plant: Grand Gulf Nuclear Station I Year: 2021 I Page 44 of 59 Annual Radiological Environmental Operating Report ATTACHMENT 3 INTERLABORATORY COMPARISON RES ULTS Quality control data from the offsite environmental laboratories are summarized in the following pages.

Information from Teledyne Brown Engineering is presented first, followed by Environmental Dosimetry Company I Stanford Dosimetry.

TELEDYNE BROWN ENGINEERING 1.0 Summary The TBE Laboratory analyzed Performance Evaluation (PE) samples of air particulate (AP), air iodine, milk, soil , vegetation , and water matrices for various analytes. The PE samples supplied by Analytics Inc., Environmental Resource Associates (ERA) and Department of Energy (DOE)

Mixed Analyte Performance Evaluation Program (MAPEP), were evaluated against the following pre-set acceptance criteria :

A. Analytics Evaluation Criteria Analytics' evaluation report provides a ratio of TBE's result and Analytics' known value. Since flag values are not assigned by Analytics, TBE evaluates the reported ratios based on internal QC requirements based on the DOE MAPEP criteria.

B. ERA Evaluation Criteria ERA's evaluation report provides an acceptance range for control and warning limits with associated flag values. ERA's acceptance limits are established per the US EPA, National Environmental Laboratory Accreditation Conference (NELAC), state-specific Performance Testing (PT) program requirements or ERA's SOP for the Generation of Performance Acceptance Limits, as applicable. The acceptance limits are either determined by a regression equation specific to each analyte or a fixed percentage limit promulgated under the appropriate regulatory document.

C. DOE Evaluation Criteria MAPEP's evaluation report provides an acceptance range with associated flag values. MAPEP defines three levels of performance:

  • Acceptable (flag = "A") - result within +/- 20% of the reference value
  • Acceptable with Warning (flag = "W') - result falls in the +/- 20% to +/- 30% of the reference value
  • Not Acceptable (flag = "N") - bias is greater than 30% of the reference value Note: The Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP) samples are created to mimic conditions found at DOE sites which do not resemble typical environmental samples obtained at commercial nuclear power facilities.

For the TBE laboratory, 126 out of 133 analyses performed met the specified acceptance criteria. Seven analyses did not meet the specified acceptance criteria for the following reasons and were addressed through the TBE Corrective Action Program. A summary is found below:

Plant: Grand Gulf Nuclear Station I Year: 2020 I Page 48 of 48 Annual Radiological Environmental Operating Report Page 2 of 2

1. The MAPEP February 2020 AP U-233/234 and U-238 results were evaluated as Not Acceptable. The reported value for U-233/234 was 0.0416 +/- 0.0102 Sq/sample and the known result was 0.075 Sq/sample (acceptance range 0.053 - 0.098) . The reported value for U-238 was 0.0388 +/- 0.00991 Sq/sample and the known result was 0.078 Sq/sample (acceptance range 0.055 - 0.101). This sample was run as the workgroup duplicate and had RPD's of 10.4% (U-234) and 11.7% (U-238). After the known results were obtained, the sample was relogged. The filter was completely digested with tracer added originally; the R1 results were almost identical. It was concluded that the recorded tracer amount was actually double, causing the results to be skewed. Lab worksheets have been modified to verify actual tracer amount vs. LIMS data. TBE changed vendors for this cross-check to ERA MRAD during the 2 nd half of 2020. Results were acceptable at 97.8% for U-234 and 106% for U-238. (NCR 20-13)
2. The Analytics September 2020 milk Sr-89 result was evaluated as Not Acceptable. The reported value was 62.8 pCi/L and the known result was 95.4 (66%) . All QC data was reviewed and there were no anomalies. This was the first failure for milk Sr-89 since 2013 and there have only been 3 upper/lower boundary warnings since that time. It is believed that there may have been some Sr-89 loss during sample prep. The December 2020 result was at 92% of the known. (NCR 20-19)
3. The ERA October 2020 water 1-131 result was evaluated as Not Acceptable. The reported value was 22.9 pCi/L and the known result was 28.2 (acceptance range 23.5 - 33.1). The reported result was 81 % of the known, which passes TBE QC criteria. This was the first failure for water 1-131 . (NCR 20-17)
4. The ERA October 2020 water Gross Alpha and Gross Beta results were evaluated as Not Acceptable. The reported/acceptable values and ranges are as follows:

Reported Known Range Gross Alpha 40.0 26.2 13.3 - 34.7 Gross Beta 47.5 69.1 48 .0 - 76.0 All QC data was reviewed with no anomalies and a cause for failure could not be determined. This was the first failure for water Gross Beta. A Quick Response follow-up cross-check was analyzed as soon as possible with acceptable results at 96.8% for Gross Alpha and 102% for Gross Beta. (NCR 20-18)

5. The MAPEP August 2020 soil Ni-63 result was evaluated as Not Acceptable. The reported value was 438 +/- 21.1 Bq/kg and the known result was 980 Bq/kg (acceptance range 686 - 1274). It is believed that some Ni-63 loss occurred during the sample prep step. (NCR 20-20)

The Inter-Laboratory Comparison Program provides evidence of "in control" counting systems and methods, and that the laboratories are producing accurate and reliable data.

ENVIRONMENTAL DOSIMETRY COMPANY ANNUAL QUALITY ASSURANCE STATUS REPORT January - December 2021 Prepared By: Date:

Approved By: Date: ,3/16/2--2 Environmental Dosimetry Company 10 Ashton Lane Sterling, MA 01564

TABLE OF CONTENTS LIST OF TABLES .. ........ .... ... ... .. .. .............. ... ............. ..... ........ ............ .. ... ....... ..... ........ .............. . iii EXECUTIVE

SUMMARY

.... ....... .... .... .. ... .... ...... .... .... ..... ...... .. ..... .... .. .. .............................. .... .... .. iv I. INTRODUCTION ........ .. ........... .... .. ........ .. .. ... .. ...... ................ .... .... ...... ...... ..... .... ............. 1 A. QC Program ..................... ... .. ................ ........................... ...... ..... .... .................... 1 B. QA Program ........................................................................... ... .......................... 1 II. PERFORMANCE EVALUATION CRITERIA ....... .. .. .......... .. .... ... .. ...... ............................. 1 A Acceptance Criteria for Internal Evaluations ............. .. ..... ... ... ... .... .. ...... ...... .. .. ..... 1 B. QC Investigation Criteria and Result Reporting .... ... .... ....................................... . 3 C. Reporting of Environmental Dosimetry Results to EDC Customers ..................... 3 Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2021 ................. 3 A. General Discussion ................ ... .... ... ... .... .. ............. .............. ... ....... ..................... 3 B. Result Trending ............. .......... .. .. .. ..... .... ............... .. ..... .. ............. ... ........ .......... .. 4 IV. STATUS OF EDC CONDITION REPORTS (CR) .......... ... ...... .. .......... ... ..... ... .......... ....... 4 V. STATUS OF AUDITS/ASSESSMENTS .......... ... .... ................... .. .... ........ ...... ... ...... .... .... . 4 A. Internal. .. ..... .. ... ..................... .......... ......... .. ..................... ....... .. .. ... ...................... 4 B. External .. ....................................... .. ....................................... .. .. .. ...................... 4 VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2021 ... 4 VII. CONCLUSION AND RECOMMENDATIONS .. .... .. .... ..... .. .. .. .... ... ....................... ........ .... 4 VI 11. REFERENCES .... ... ..... ..... ....... ... .. .. .... .............. .. ... .... .... .. ... ..... ... ....... ... .... ...... .... .. ... .. ... .. 4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS LIST OF TABLES

1. Percentage of Individual Analyses Which Passed EDC Internal Criteria, January - December 2021 5
2. Mean Dosimeter Analyses (n=6), January - December 2021 5
3. Summary of Independent QC Results for 2021 5

-ii-

EXECUTIVE

SUMMARY

Routine quality control (QC) testing was performed for dosimeters issued by the Environmental Dosimetry Company (EDC).

During this annual period100% (72/72) of the individual dosimeters, evaluated against the EDC internal performance acceptance criteria (high-energy photons only), met the criterion for accuracy and 100% (72/72) met the criterion for precision (Table 1). In addition , 100% (12/12) of the dosimeter sets evaluated against the internal tolerance limits met EDC acceptance criteria (Table 2) and 100% (6/6) of independent testing passed the performance criteria (Table 3). Trending graphs, which evaluate performance statistic for high-energy photon irradiations and co-located stations are given in Appendix A.

One internal assessment was performed in 2021.There were no findings .

I. INTRODUCTION The TLD systems at the Environmental Dosimetry Company (EDC) are calibrated and operated to ensure consistent and accurate evaluation of TLDs. The quality of the dosimetric results reported to EDC clients is ensured by in-house performance testing and independent performance testing by EDC clients, and both internal and client directed program assessments.

The purpose of the dosimetry quality assurance program is to provide performance documentation of the routine processing of EDC dosimeters. Performance testing provides a statistical measure of the bias and precision of dosimetry processing against a reliable standard, which in turn points out any trends or performance changes. Two programs are used:

A. QC Program Dosimetry quality control tests are performed on EDC Panasonic 814 Environmental dosimeters. These tests include: (1) the in-house testing program coordinated by the EDC QA Officer and (2) independent test perform by EDC clients. In-house test are performed using six pairs of 814 dosimeters, a pair is reported as an individual result and six pairs are reported as the mean result. Results of these tests are described in this report.

Excluded from this report are instrumentation checks. Although instrumentation checks represent an important aspect of the quality assurance program, they are not included as process checks in this report. Instrumentation checks represent between 5-1 0% of the TLDs processed.

B. QA Program An internal assessment of dosimetry activities is conducted annually by the Quality Assurance Officer (Reference 1). The purpose of the assessment is to review procedures, results, materials or components to identify opportunities to improve or enhance processes and/or services.

II. PERFORMANCE EVALUATION CRITERIA A. Acceptance Criteria for Internal Evaluations

1. Bias For each dosimeter tested, the measure of bias is the percent deviation of the reported result relative to the delivered exposure. The percent deviation relative to the delivered exposure is calculated as follows:

where:

H; = the corresponding reported exposure for the ith dosimeter (i.e., the reported exposure)

Hi = the exposure delivered to the ith irradiated dosimeter (i.e., the delivered exposure) 1of 6

2. Mean Bias For each group of test dosimeters, the mean bias is the average percent deviation of the reported result relative to the delivered exposure. The mean percent deviation relative to the delivered exposure is calculated as follows:

where:

H:= the corresponding reported exposure for the ith dosimeter (i.e., the reported exposure)

H, = the exposure delivered to the ith irradiated test dosimeter (i.e., the delivered exposure) n = the number of dosimeters in the test group Precision For a group of test dosimeters irradiated to a given exposure, the measure of precision is the percent deviation of individual results relative to the mean reported exposure. At least two values are required for the determination of precision. The measure of precision for the ith dosimeter is:

where:

H; = the reported exposure for the ith dosimeter (i.e. , the reported exposure)

R= the mean reported exposure; i.e., R=LH;(~)

n = the number of dosimeters in the test group

3. EDC Internal Tolerance Limits All evaluation criteria are taken from the "EDC Quality System Manual,"

(Reference 2). These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs-137) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +/-

12.8% for precision.

2of 6

B. QC Investigation Criteria and Result Reporting EDC Quality System Manual (Reference 2) specifies when an investigation is required due to a QC analysis that has failed the EDC bias criteria. The criteria are as follows:

1. No investigation is necessary when an individual QC result falls outside the QC performance criteria for accuracy.
2. Investigations are initiated when the mean of a QC processing batch is outside the performance criterion for bias.

C. Reporting of Environmental Dosimetry Results to EDC Customers

1. All results are to be reported in a timely fashion.
4. If the QA Officer determines that an investigation is required for a process, the results shall be issued as normal. If the QC results prompting the investigation have a mean bias from the known of greater than +/-20%, the results shall be issued with a note indicating that they may be updated in the future, pending resolution of a QA issue.
5. Environmental dosimetry results do not require updating if the investigation has shown that the mean bias between the original results and the corrected results, based on applicable correction factors from the investigation, does not exceed +/-20%.

Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2021 A. General Discussion Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4.

Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period100% (72/72) of the individual dosimeters, evaluated against these criteria ,

met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision . A graphical interpretation is provided in Figures 1 and 2.

Table 2 provides the bias and standard deviation results for each group (N=S) of dosimeters evaluated against the internal tolerance criteria . Overall, 100% (12/12) of the dosimeter sets, evaluated against the internal tolerance performance criteria, met these criteria. A graphical interpretation is provided in Figure 3.

Table 3 presents the independent blind spike results for dosimeters processed during this annual period. All results passed the performance acceptance criterion. Figure 4 is a graphical interpretation of Seabrook Station blind co-located station results.

3of 6

B. Result Trending One of the main benefits of performing quality control tests on a routine basis is to identify trends or performance changes. The results of the Panasonic environmental dosimeter performance tests are presented in Appendix A. The results are evaluated against each of the performance criteria listed in Section II ,

namely: individual dosimeter accuracy, individual dosimeter precision, and mean bias.

All of the results presented in Appendix A are plotted sequentially by processing date.

IV. STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period.

V. STATUS OF AUDITS/ASSESSMENTS

1. Internal EDC Internal Quality Assurance Assessment was conducted during the fourth quarter 2021 . There were no findings identified.
2. External None.

VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2021 Several procedures were reissued with no changes as part of the 5 year review cycle.

VII. CONCLUSION AND RECOMMENDATIONS The quality control evaluations continue to indicate the dosimetry processing programs at the EDC satisfy the criteria specified in the Quality System Manual. The EDC demonstrated the ability to meet all applicable acceptance criteria.

VIII. REFERENCES

1. EDC Quality Control and Audit Assessment Schedule, 2021 .
2. EDC Manual 1, Quality System Manual, Rev. 4, September 28, 2020.

4of 6

TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 2021 !1l, !2l Number  % Passed Precision Dosimeter Type  % Passed Bias er1teria Testeg Criteria Panasonic Environmental 72 100 100 1

( lThis table summarizes results of tests conducted by EDC.

2

( lEnvironmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES tN=6)

JANUARY - DECEMBER 2021 ( l, (2l Standard Tolerance Rr:ocess Date Exposure Level Mean Bias%

-~ -- Deviation% Limit +/-16%

5/04/2021 33 0.6 0.9 Pass 5/06/2021 120 -0.2 1.4 Pass 5/26/2021 53 -3.8 1.6 Pass 7/27/2021 67 2.8 1.4 Pass 8/04/2021 91 -1.8 2.3 Pass 9/14/2021 47 -0.2 2.3 Pass 11/01/2021 28 3.7 0.6 Pass 11/03/2021 74 1.9 1.9 Pass 11/09/2021 103 1.1 1.1 Pass 01/26/2022 37 2.6 1.9 Pass 01/30/2022 85 -4.2 1.1 Pass 02/06/2022 58 2.9 1.2 Pass 1

< lThis table summarizes results of tests conducted by EDC for TLDs issued in 2021 .

2

( lEnvironmental dosimeter results are free in air.

TABLE 3

SUMMARY

OF INDEPENDENT DOSIMETER TESTING JANUARY - DECEMBER 2021 !1l, (2l

- Standard Mean Issuance Period Client Deviation% Pass/ Fall

-- Blas%

- .. _, II 1st Qtr. 2021 SONGS -3.8 1.4 Pass 1st Qtr. 2021 SONGS -4.7 1.1 Pass 2 nd Qtr.2021 Seabrook 3.1 1.0 Pass 3ra Qtr. 2021 Millstone -4.7 1.4 Pass 4 th Qtr.2021 PSEG(PNNL) 50mR 1.3 0.8 Pass 4m Qtr.2021 PSEG(PNNL) 100mR 1.8 0.8 Pass 4 th Qtr.2021 PSEG(PNNL) 150mR -0.6 0.5 Pass 4 th Qtr.2021 PSEG(PNNL) 200mR -2.6 2.0 Pass 4m Qtr.2021 Seabrook 2.6 1.4 Pass 1

( lperformance criteria are +/- 15%.

2

( JBlind spikeirradiations using Cs-137 5of 6

APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2021 6of 6

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