ML22136A261

Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021

ML22136A261
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Site:	Pilgrim
Issue date:	05/10/2022
From:	Hageman L Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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ML22136A259	List: ML22136A260 ML22136A261
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PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Annual Radiological Environmental Operating Report January 1 through December 31, 2021 Page 1

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2021 TABLE OF CONTENTS SECTION SECTION TITLE PAGE

-- EXECUTIVE

SUMMARY

6

1.0 INTRODUCTION

8 1.1 Radiation and Radioactivity 8 1.2 Sources of Radiation 9 1.3 Nuclear Reactor Operations 10 1.4 Radioactive Effluent Control 15 1.5 Radiological Impact on Humans 16 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 21 2.1 Pre-Operational Monitoring Results 21 2.2 Environmental Monitoring Locations 22 2.3 Interpretation of Radioactivity Analyses Results 24 2.4 Ambient Radiation Measurements 25 2.5 Air Particulate Filter Radioactivity Analyses 26 2.6 Milk Radioactivity Analyses 27 2.7 Vegetable/Vegetation Radioactivity Analyses 27 2.8 Surface Water Radioactivity Analyses 27 2.9 Sediment Radioactivity Analyses 28 2.10 Shellfish Radioactivity Analyses 28 2.11 Lobster Radioactivity Analyses 28 2.12 Fish Radioactivity Analyses 29 3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS 56

4.0 REFERENCES

58 APPENDIX A Special Studies 59 APPENDIX B Land Use Census 60 APPENDIX C Environmental Monitoring Program Discrepancies 61 APPENDIX D Environmental Dosimetry Company Annual Quality Assurance 63 Status Report APPENDIX E Teledyne Brown Engineering Environmental Services 2021 Quality Assurance Report Page 3

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2021 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 9 2.2-1 Routine Radiological Environmental Sampling Locations 30 2.4-1 Offsite Environmental TLD Results 31 2.4-2 Onsite Environmental TLD Results 33 2.4-3 Average TLD Exposures By Distance Zone During 2021 33 2.5-1 Air Particulate Filter Radioactivity Analyses 34 2.7-1 Vegetable/Vegetation Radioactivity Analyses 35 2.8-1 Surface Water Radioactivity Analyses 36 2.9-1 Sediment Radioactivity Analyses 37 2.10-1 Shellfish Radioactivity Analyses 38 2.11-1 Lobster Radioactivity Analyses 39 2.12-1 Fish Radioactivity Analyses 40 3.0-1 Radiation Doses From 2021 Pilgrim Station Operations 57 Page 4

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2021 LIST OF FIGURES FIGURE FIGURE TITLE PAGE 1.3-1 Radioactive Fission Product Formation 11 1.3-2 Radioactive Activation Product Formation 12 1.3-3 Barriers to Confine Radioactive Materials 13 1.5-1 Radiation Exposure Pathways 18 2.2-1 Environmental TLD Locations Within the PNPS Protected Area 41 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer 43 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers 45 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers 47 2.2-5 Marine/Aquatic Sampling Locations 49 2.2-6 Environmental Sampling and Measurement Control Locations 51 2.5-1 Airborne Gross Beta Radioactivity Levels: Near Station Monitors 53 2.5-2 Airborne Gross Beta Radioactivity Levels: Property Line Monitors 54 2.5-3 Airborne Gross Beta Radioactivity Levels: Offsite Monitors 55 Page 5

EXECUTIVE

SUMMARY

ENTERGY NUCLEAR PILGRIM NUCLEAR POWER STATION ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2021 INTRODUCTION This report summarizes the results of the Holtec (HDI) Nuclear Radiological Environmental Monitoring Program (REMP) conducted in the vicinity of Pilgrim Nuclear Power Station (PNPS) during the period from January 1 to December 31, 2021. This document has been prepared in accordance with the requirements of PNPS Facility Licensing Basis.

The REMP has been established to monitor the radiation and radioactivity released to the environment as a result of previous Pilgrim Station's operation. This program, initiated in August 1968, includes the collection, analysis, and evaluation of radiological data in order to assess the impact of Pilgrim Station on the environment and on the general public.

SAMPLING AND ANALYSIS The environmental sampling media collected in the vicinity of PNPS and at distant locations include air particulate filters, seawater, sediment, shellfish, American lobster, and fishes. Some sample media such as soil, forage, Irish moss, vegetation and cranberries were removed from the discussion of this report as they are no longer a pathway and therefore removed from the ODCM and sampling program. Soil sampling had been previously removed in 2003 in favor of extensive TLD monitoring.

During 2021, there were 409 samples collected from the atmospheric, aquatic, and terrestrial environments. In addition, 185 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs).

A small number of inadvertent issues were encountered during 2021 in the collection of environmental samples in accordance with the PNPS Offsite Dose Calculation Manual (ODCM). Equipment failures and power outages resulted in a small number of instances in which lower than normal volumes were collected at the airborne sampling stations. 335 of 342 air particulate were collected and analyzed as required. Charcoal cartridge collection was discontinued in the beginning of December 2019 when Iodines had decayed away following the permanent shutdown of PNPS on May 31, 2019. A full description of any discrepancies encountered with the environmental monitoring program is presented in Appendix D of this report.

Analyses on environmental samples were performed by Teledyne Brown Engineering Laboratory in Knoxville, TN. Samples were analyzed as required by the PNPS ODCM.

LAND USE CENSUS The annual land use census in the vicinity of Pilgrim Station is no longer conducted. All crop-based foods no longer exist within a 5 mile radius of the plant. Cranberries and Irish Moss crops were removed from the ODCM in revision 14. The collection of broad leaf vegetation was to account for deposition of iodine on a type of cattle feed in lieu of sampling for milk. There are no milk farms withing 5 miles. The need to account for changes in new or old gardens diminished once the plant shutdown and not only was no new iodine created, but that which had been created all decayed after 10 half lives for I-131 had passed (1 calendar quarter).

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Broadleaf vegetation may still be consumed by humans, and it will be projected and accounted for in dose modeling for all nuclides remaining that are released off site, but the only radionuclide detected in REMP samples while the plant was operating was Cs-137 from fall out (recently Chernobyl and Fukushima) which is deposited on and absorbed through the roots of plants and trees and has a 30-year half-life. The current dose model for gaseous release dose calculations utilizes a garden at the site boundary in the predominant downwind direction. As this is the most conservative scenario, no land use census will produce an alternate garden with higher off-site dose potential.

The wind rose maps for Pilgrim RBV mixed mode releases and ground releases show the predominant wind direction from the SSW in both frequency and wind speed. This means the predominant wind direction is from the land out to sea from the WNW to the SSW with SSW the most frequent compass point wind comes from toward the station. Essentially, gaseous effluents from the plant, however minor in quantity compared to when operating, are blown out to sea.

RADIOLOGICAL IMPACT TO THE ENVIRONMENT During 2021, samples collected as part of the REMP at Pilgrim Station continued to contain detectable amounts of naturally-occurring radioactive materials. No samples indicated any detectable radioactivity attributable to Pilgrim Station operations. Offsite ambient radiation measurements using environmental TLDs beyond the site boundary ranged between 46 and 86 milliRoentgens (1 mR=0.933 mrem) per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts.

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2021, radiation doses to the general public as a result of previous Pilgrim Station's operation continued to be well below the federal limits and much less than the collective dose due to other sources of man-made (e.g., X-rays, medical, fallout) and naturally-occurring (e.g., cosmic, radon) radiation.

The calculated total body dose to the maximally exposed member of the general public from radioactive effluents and ambient radiation resulting from PNPS operations for 2021 was approximately 0.30 mrem for the year. This conservative estimate is well below the EPA's annual dose limit to any member of the general public and is a fraction of a percent of the typical dose received from natural and man-made radiation.

CONCLUSIONS The 2021 Radiological Environmental Monitoring Program for Pilgrim Station resulted in the collection and analysis of hundreds of environmental samples and measurements. The data obtained were used to determine the impact of Pilgrim Station's operation on the environment and on the general public.

An evaluation of direct radiation measurements, environmental sample analyses, and dose calculations showed that all applicable federal criteria were met. Furthermore, radiation levels and resulting doses were a small fraction of those that are normally present due to natural and man-made background radiation.

Based on this information, there is no significant radiological impact on the environment or on the general public due to Pilgrim Station's decommissioning operations.

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1.0 INTRODUCTION

The Radiological Environmental Monitoring Program for 2021 performed by Comprehensive Decommissioning International (CDI), now Holtec Decommissioning International (HDI), owned by Holtec for Pilgrim Nuclear Power Station (PNPS) is discussed in this report. This report, which is required to be published annually by Pilgrim Station's Facility Licensing Basis, summarizes the results of measurements of radiation and radioactivity in the environment in the vicinity of the Pilgrim Station and at distant locations during the period January 1 to December 31, 2021.

The Radiological Environmental Monitoring Program consists of taking radiation measurements and collecting samples from the environment, analyzing them for radioactivity content, and interpreting the results. With emphasis on the critical radiation exposure pathways to humans, samples from the aquatic, atmospheric, and terrestrial environments are collected. These samples include, but are not limited to: air, seawater, sediment, shellfish, American lobster, and fish. Thermoluminescent dosimeters (TLDs) are placed in the environment to measure gamma radiation levels. The TLDs are processed and the environmental samples are analyzed to measure the very low levels of radiation and radioactivity present in the environment as a result of PNPS operation and other natural and man-made sources. These results are reviewed by PNPS's Chemistry staff and have been reported semiannually or annually to the Nuclear Regulatory Commission and others since 1972.

In order to more fully understand how a nuclear power plant impacts humans and the environment, background information on radiation and radioactivity, natural and man-made sources of radiation, radioactive effluent controls, and radiological impact on humans is provided. It is believed that this information will assist the reader in understanding the radiological impact on the environment and humans from the previous operation of Pilgrim Station.

1.1 Radiation and Radioactivity All matter is made of atoms. An atom is the smallest part into which matter can be broken down and still maintain all its chemical properties. Nuclear radiation is energy, in the form of waves or particles that is given off by unstable, radioactive atoms.

Radioactive material exists naturally and has always been a part of our environment. The earth's crust, for example, contains radioactive uranium, radium, thorium, and potassium. Some radioactivity is a result of nuclear weapons testing. Examples of radioactive fallout that is normally present in environmental samples are cesium-137 and strontium-90. Some examples of radioactive materials released from a nuclear power plants are cesium-137, iodine-131, strontium-90, and cobalt-60. Iodine is no longer an active Pilgrim station isotope as the station no longer produces iodine and that which was previously produced has decayed away.

Radiation is measured in units of millirem, much like temperature is measured in degrees. A millirem is a measure of the biological effect of the energy deposited in tissue. The natural and man-made radiation dose received in one year by the average American is approximately 620 mrem (References 2, 3, 4).

Radioactivity is measured in curies. A curie is that amount of radioactive material needed to produce 37,000,000,000 nuclear disintegrations per second. This is an extremely large amount of radioactivity in comparison to environmental radioactivity. That is why radioactivity in the environment is measured in picocuries. One picocurie is equal to one trillionth of a curie.

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1.2 Sources of Radiation As mentioned previously, naturally occurring radioactivity has always been a part of our environment.

Table 1.2-1 shows the sources and doses of radiation from natural and man-made sources.

Table 1.2-1 Radiation Sources and Corresponding Doses (1)

NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem/year)

(2) (3)

Internal, inhalation 230 Medical 300 External, space 30 Consumer(4) 12 (5)

Internal, ingestion 30 Industrial 0.6 External, terrestrial 20 Occupational 0.6 Weapons Fallout <1 Nuclear Power Plants <1 Approximate Total 310 Approximate Total 315 Combined Annual Average Dose: Approximately 625 millirem/year (1) Information from NCRP Reports 160 and 94 (2) Primarily from airborne radon and its radioactive progeny (3) Includes CT (150 millirem), nuclear medicine (74 mrem), interventional fluoroscopy (43 mrem) and conventional radiography and fluoroscopy (30 mrem)

(4) Primarily from cigarette smoking (4.6 mrem), commercial air travel (3.4 mrem), building materials (3.5 mrem), and mining and agriculture (0.8 mrem)

(5) Industrial, security, medical, educational, and research Cosmic radiation from the sun and outer space penetrates the earth's atmosphere and continuously bombards us with rays and charged particles. Some of this cosmic radiation interacts with gases and particles in the atmosphere, making them radioactive in turn. These radioactive byproducts from cosmic ray bombardment are referred to as cosmogenic radionuclides. Isotopes such as beryllium-7 and carbon-14 are formed in this way. Exposure to cosmic and cosmogenic sources of radioactivity results in approximately 30 mrem of radiation dose per year.

Additionally, natural radioactivity is in our body and in the food we eat (approximately 30 millirem/yr),

the ground we walk on (approximately 20 millirem/yr) and the air we breathe (approximately 230 millirem/yr). The majority of a person's annual dose results from exposure to radon and thoron in the air we breathe. These gases and their radioactive decay products arise from the decay of naturally occurring uranium, thorium and radium in the soil and building products such as brick, stone, and concrete. Radon and thoron levels vary greatly with location, primarily due to changes in the concentration of uranium and thorium in the soil. Residents at some locations in Colorado, New York, Pennsylvania, and New Jersey have a higher annual dose as a result of higher levels of radon/thoron gases in these areas. In total, these various sources of naturally-occurring radiation and radioactivity contribute to a total dose of approximately 310 mrem per year.

In addition to natural radiation, we are normally exposed to radiation from a number of man-made sources. The single largest doses from man-made sources result from therapeutic and diagnostic Page 9

applications of x-rays and radiopharmaceuticals. The annual dose to an individual in the U.S. from medical and dental exposure is approximately 300 mrem. Consumer activities, such as smoking, commercial air travel, and building materials contribute approximately 13 mrem/yr. Much smaller doses result from weapons fallout (less than 1 mrem/yr) and nuclear power plants. Typically, the average person in the United States receives approximately 314 mrem per year from man-made sources. The collective dose from naturally-occurring and man-made sources results in a total dose of approximately 620 mrem/yr to the average American.

1.3 Nuclear Reactor Operations Pilgrim Station was an operating boiling water reactor whose nuclear steam supply system was provided by General Electric Co. The nuclear station is located on a 1600-acre site approximately eight kilometers (five miles) east-southeast of the downtown area of Plymouth, Massachusetts. Commercial operation began in December 1972. Pilgrim Station was operational until May 31, 2019 before the decision to permanently shut down and decommission the station.

Nuclear-generated electricity was produced at Pilgrim Station by many of the same techniques used for conventional oil and coal-generated electricity. Both systems use heat to boil water to produce steam.

The steam turns a turbine, which turns a generator, producing electricity. In both cases, the steam passes through a condenser where it changes back into water and recirculates back through the system. The cooling water source for Pilgrim Station is the Cape Cod Bay.

The key difference between Pilgrim's nuclear power and conventional power is the source of heat used to boil the water. Conventional plants burn fossil fuels in a boiler, while nuclear plants make use of uranium in a nuclear reactor.

Inside the reactor, a nuclear reaction called fission takes place. Particles, called neutrons, strike the nucleus of a uranium-235 atom, causing it to split into fragments called radioactive fission products.

The splitting of the atoms releases both heat and more neutrons. The newly-released neutrons then collide with and split other uranium atoms, thus making more heat and releasing even more neutrons, and on and on until the uranium fuel is depleted or spent. This process is called a chain reaction.

The operation of a nuclear reactor results in the release of small amounts of radioactivity and low levels of radiation. The radioactivity originates from two major sources, radioactive fission products and radioactive activation products.

Radioactive fission products, as illustrated in Figure 1.3-1 (Reference 5), originate from the fissioning of the nuclear fuel. These fission products get into the reactor coolant from their release by minute amounts of uranium on the outside surfaces of the fuel cladding, by diffusion through the fuel pellets and cladding and, on occasion, through defects or failures in the fuel cladding. These fission products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive fission products on the pipes and equipment emit radiation. Examples of some fission products are krypton-85 (Kr-85), strontium-90 (Sr-90), xenon-133 (Xe-133), and cesium-137 (Cs-137).

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Nuclear Fission Fission is the splitting of the uranium-235 atom by a neutron to release heat and more neutrons, creating a chain reaction.

Radiation and fission products are by-products of the process.

Figure 1.3-1 Radioactive Fission Product Formation Page 11

Radioactive activation products (see Figure 1.3-2), on the other hand, originate from two sources. The first is by neutron bombardment of the hydrogen, oxygen and other gas (helium, argon, nitrogen) molecules in the reactor cooling water. The second is a result of the fact that the internals of any piping system or component are subject to minute yet constant corrosion from the reactor cooling water.

These minute metallic particles (for example: nickel, iron, cobalt, or magnesium) are transported through the reactor core into the fuel region, where neutrons may react with the nuclei of these particles, producing radioactive products. So, activation products are nothing more than ordinary naturally-occurring atoms that are made unstable or radioactive by neutron bombardment. These activation products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive activation products on the pipes and equipment emit radiation.

Examples of some activation products are manganese-54 (Mn-54), iron-59 (Fe-59), cobalt-60 (Co-60),

and zinc-65 (Zn-65).

n Co-59 Co-60 Stable Radioactive Neutron Cobalt Nucleus Cobalt Nucleus Figure 1.3-2 Radioactive Activation Product Formation At Pilgrim Nuclear Power Station there are five independent protective barriers that confine these radioactive materials. These five barriers, which are shown in Figure 1.3-3 (Reference 5), are:

fuel pellets; fuel cladding; reactor vessel and piping; primary containment (drywell and torus); and, secondary containment (reactor building).

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SIMPLIFIED DIAGRAM OF A BOILING WATER REACTOR Figure 1.3-3 Barriers To Confine Radioactive Materials Page 13

The ceramic uranium fuel pellets provide the first barrier. Most of the radioactive fission products are either physically trapped or chemically bound between the uranium atoms, where they will remain.

However, a few fission products that are volatile or gaseous may diffuse through the fuel pellets into small gaps between the pellets and the fuel cladding.

The second barrier, the fuel cladding, consists of zirconium alloy tubes that confine the fuel pellets. The small gaps between the fuel and the cladding contain the noble gases and volatile iodines that are types of radioactive fission products. This radioactivity can diffuse to a small extent through the fuel cladding into the reactor coolant or spent fuel pool water.

The third barrier consists of the reactor vessel, steel piping and equipment that confine the reactor water. The reactor vessel, which once held the reactor fuel, is a 65-foot high by 19-foot diameter tank with steel walls approximately nine inches thick. This provides containment for radioactivity in the water once used as primary coolant. However, during the course of decommissioning operations and maintenance, small amounts of radioactive fission and activation products can escape through valve leaks or upon breaching of the primary coolant system for maintenance.

The last barrier is the reactor building. This reactor building is equipped with a controlled filtered ventilation system that is used to keep the building as at a negative pressure.

These barriers confine most of the remaining radioactive fission and activation products. However, small amounts of radioactivity do escape via mechanical failures and maintenance on valves, piping, and equipment associated with the reactor/fuel pool systems. The small amounts of radioactive liquids and gases that do escape the various containment systems are further controlled by the liquid purification and ventilation filtration systems. Prior to a release to the environment, control systems collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable (ALARA). The control of radioactive effluents at Pilgrim Station will be discussed in more detail in the next section.

1.4 Radioactive Effluent Control The small amounts of radioactive liquids and gases that might escape the barriers are purified in the liquid and gaseous waste treatment systems, then monitored for radioactivity, and released only if the radioactivity levels are below the federal release limits as permitted.

Radioactivity released from the liquid effluent system to the environment is limited, controlled, and monitored by a variety of systems and procedures which include:

liquid radwaste treatment system; sampling and analysis of the liquid radwaste tanks; and, liquid waste effluent discharge header radioactivity monitor.

Water used previously for reactor or spent fuel cooling that might escape the primary cooling system and other radioactive water sources are collected in floor and equipment drains. These drains direct this radioactive liquid waste to large holdup tanks. The liquid waste collected in the tanks is purified again using the liquid radwaste treatment system, which consists of a filter and ion exchange resins.

( as it no longer serves its original purpose to aid in reactor level/ pressure control) to hold larger amounts of radwaste and process through means other than the established radwaste treatment system (ie. Demineralizers previously used with in the condensate system) for purification prior to release.

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Prior to release, the radioactivity in the liquid radwaste tank is sampled and analyzed to determine if the level of radioactivity is below the release limits and to quantify the total amount of radioactive liquid effluent that would be released. If the levels are below the federal release limits, the tank is drained to the liquid effluent discharge header.

This liquid waste effluent discharge header is provided with a shielded radioactivity monitor. This detector is connected to a radiation level meter and a strip chart recorder in the Control Room. The radiation alarm is set so that the detector will alarm before radioactivity levels exceed the release limits.

The liquid effluent discharge header has an isolation valve. If an alarm is received, the liquid effluent discharge valve will automatically close, thereby terminating the release to the Cape Cod Bay and preventing any liquid radioactivity from being released that may exceed the release limits. An audible alarm notifies the Control Room operator that this has occurred.

Some liquid waste sources which have a low potential for containing radioactivity, and/or may contain very low levels of contamination, may be discharged directly to the discharge canal without passing through the liquid radwaste discharge header. One such source of liquids is the neutralizing sump.

However, prior to discharging such liquid wastes, the tank is thoroughly mixed and a representative sample is collected for analysis of radioactivity content prior to being discharged.

Another means for adjusting liquid effluent concentrations to below federal limits is by mixing plant cooling water (salt service water) with the liquid effluents in the discharge canal. This larger volume of cooling water further dilutes the radioactivity levels far below the release limits.

The preceding discussion illustrates that many controls exist to reduce the radioactive liquid effluents released to the Cape Cod Bay to as far below the release limits as is reasonably achievable.

Radioactive releases from the radioactive gaseous effluent system to the environment are limited, controlled, and monitored by a variety of systems and procedures which include:

reactor building ventilation system; reactor building vent effluent radioactivity monitor; sampling and analysis of reactor building vent effluents The purpose of the reactor building ventilation system is to collect and exhaust reactor building air. Air collected from contaminated areas is filtered prior to combining it with air collected from other parts of the building. This combined air flow is then directed to the reactor building ventilation plenum that is located on the side of the reactor building. A sample stream of the plenum flows through a sampling rack equipp ed with a paticulate filt er. Air samples a re take n on a wee kly frequency fro m t he reactor building vent and are analyzed to quantify the total amount of tritium and radioactive particulate effluents released. This plenum, which vents to the atmosphere, was previously equipped with a gaseous radiation detector. The gaseous radiation monitor w as removed from th e O DCM in revision

15. All Noble gases have decayed away, save Kr-85 which is trapped inside gaps in the fuel bundles.

Kr-85 is a beta emitter with one gamma released for every 250 decays. The detector installed in the RBV plenum would not detect it, the point is moot, as of December 2021 all Spent fuel has been transferred to sealed dry storage casks on the Independent Spent Fuel Storage Installation (ISFSI) II pad.

Therefore, for both liquid and gaseous releases, radioactive effluent control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable (ALARA). The effluents are always monitored, sampled and analyzed prior to release to make sure that radioactivity levels are below release limits. If the release limits are being approached, isolation valves in some of the waste effluent lines will automatically shut to stop the Page 15

release, or Control Room operators will implement procedures to ensure that federal regulatory limits are always met.

1.5 Radiological Impact on Humans The final step in the effluent control process is the determination of the radiological dose impact to humans and comparison with the federal dose limits to the public. As mentioned previously, the purpose of continuous radiation monitoring and periodic sampling and analysis is to measure the quantities of radioactivity being released to determine compliance with the radioactivity release limits. This is the first stage for assessing releases to the environment.

Next, calculations of the dose impact to the general public from Pilgrim Station's radioactive effluents are performed. The purpose of these calculations is to periodically assess the doses to the general public resulting from radioactive effluents to ensure that these doses are being maintained as far below the federal dose limits as is reasonably achievable. This is the second stage for assessing releases to the environment.

The types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during each given year are reported to the Nuclear Regulatory Commission annually in the Annual Radiological Effluent Release Report (ARERR) These liquid and gaseous effluents were well below the federal release limits and were a small percentage of the PNPS ODCM effluent control limits.

These measurements of the physical and chemical nature of the effluents are used to determine how the radionuclides will interact with the environment and how they can result in radiation exposure to humans. The environmental interaction mechanisms depend upon factors such as the hydrological (water) and meteorological (atmospheric) characteristics in the area. Information on the water flow, wind speed, wind direction, and atmospheric mixing characteristics are used to estimate how radioactivity will distribute and disperse in the ocean and the atmosphere.

The most important type of information that is used to evaluate the radiological impact on humans is data on the use of the environment. Information on fish and shellfish consumption, boating usage, beach usage, locations of cows and goats, locations of residences, locations of gardens, drinking water supplies, and other usage information are utilized to estimate the amount of radiation and radioactivity received by the general public.

The radiation exposure pathway to humans is the path radioactivity takes from its release point at Pilgrim Station to its effect on man. The movement of radioactivity through the environment and its transport to humans is portrayed in Figure 1.5-1.

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EXAMPLES OF PILGRIM STATION'S RADIATION EXPOSURE PATHWAYS Figure 1.5-1 Radiation Exposure Pathways Page 17

There are three major ways in which liquid effluents affect humans:

external radiation from liquid effluents that deposit and accumulate on the shoreline; external radiation from immersion in ocean water containing radioactive liquids; and, internal radiation from consumption of fish and shellfish containing radioactivity absorbed from the liquid effluents.

There are six major ways in which gaseous effluents affect humans:

external radiation from an airborne plume of radioactivity; internal radiation from inhalation of airborne radioactivity; external radiation from deposition of radioactive effluents on soil; ambient (direct) radiation from contained sources at the power plant; internal radiation from consumption of vegetation containing radioactivity deposited on vegetation or absorbed from the soil due to ground deposition of radioactive effluents; and, internal radiation from consumption of milk and meat containing radioactivity deposited on forage that is eaten by cattle and other livestock.

In addition, ambient (direct) radiation emitted from contained sources of radioactivity at PNPS contributes to radiation exposure in the vicinity of the plant. Smaller amounts of ambient radiation result from low-level radioactive waste stored at the site prior to shipping and disposal.

To the extent possible, the radiological dose impact on humans is based on direct measurements of radiation and radioactivity in the environment. When PNPS-related activity is detected in samples that represent a plausible exposure pathway, the resulting dose from such exposure is assessed (see Appendix A). However, the operation of Pilgrim Nuclear Power Station resulted in releases of only small amounts of radioactivity, and, as a result of dilution in the atmosphere and ocean, even the most sensitive radioactivity measurement and analysis techniques cannot usually detect these tiny amounts of radioactivity above that which is naturally present in the environment. Therefore, radiation doses are calculated using radioactive effluent release data and computerized dose calculations that are based on very conservative NRC-recommended models that tend to result in over-estimates of resulting dose.

These computerized dose calculations are performed by or for station personnel. These computer codes use the guidelines and methodology set forth by the NRC in Regulatory Guide 1.109 (Reference 6). The dose calculations are documented and described in detail in the Pilgrim Nuclear Power Station's Offsite Dose Calculation Manual (Reference 7), which has been reviewed by the NRC.

Monthly dose calculations are performed by PNPS personnel. It should be emphasized that because of the very conservative assumptions made in the computer code calculations, the maximum hypothetical dose to an individual is considerably higher than the dose that would actually be received by a real individual.

After dose calculations are performed, the results are compared to the federal dose limits for the public.

The two federal agencies that are charged with the responsibility of protecting the public from radiation and radioactivity are the Nuclear Regulatory Commission (NRC) and the Environmental Protection Agency (EPA).

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The NRC, in 10CFR 20.1301 (Reference 8) limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of:

less than or equal to 100 mrem per year to the total body.

In addition to this dose limit, the NRC has established design objectives for nuclear plant licensees.

Conformance to these guidelines ensures that nuclear power reactor effluents are maintained as far below the legal limits as is reasonably achievable.

The NRC, in 10CFR 50 Appendix I (Reference 9) establishes design objectives for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to:

less than or equal to 3 mrem per year to the total body; and, less than or equal to 10 mrem per year to any organ.

The air dose due to release of noble gases in gaseous effluents is restricted to:

less than or equal to 10 mrad per year for gamma radiation; and, less than or equal to 20 mrad per year for beta radiation.

Note: There are no noble gas release at Pilgrim due to gases having decayed away The dose to a member of the general public from iodine-131, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to:

less than or equal to 15 mrem per year to any organ.

Note: There are no iodine release at Pilgrim due to no more produces and that which has been produced by the plant operation having decayed away The EPA, in 40CFR190.10 Subpart B (Reference 10), sets forth the environmental standards for the uranium fuel cycle. During normal operation, the annual dose to any member of the public from the entire uranium fuel cycle shall be limited to:

less than or equal to 25 mrem per year to the total body; less than or equal to 75 mrem per year to the thyroid; and, less than or equal to 25 mrem per year to any other organ.

The summary of the 2021 radiological impact for Pilgrim Station and comparison with the EPA dose limits and guidelines, as well as a comparison with natural/man-made radiation levels, is presented in Section 3 of this report.

The third stage of assessing releases to the environment is the Radiological Environmental Monitoring Program (REMP). The description and results of the REMP at Pilgrim Nuclear Power Station during 2021 is discussed in Section 2 of this report.

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2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.1 Pre-Operational Monitoring Results The Radiological Environmental Monitoring Program (REMP) at Pilgrim Nuclear Power Station was first initiated in August 1968, in the form of a pre-operational monitoring program prior to bringing the station on-line. Th -operational environmental monitoring program is to:

measure background levels and their variations in the environment in the area surrounding the evaluate procedures, equipment, and techniques for monitoring radiation and radioactivity in the environment.

The pre-operational program (Reference 12) continued for approximately three and a half years, from August 1968 to June 1972. Examples of background radiation and radioactivity levels measured during this time period are as follows:

Airborne Radioactivity Particulate Concentration (gross beta): 0.02 - 1.11 pCi/m3; Ambient Radiation (TLDs): 4.2 - 22 micro-R/hr (37 - 190 mR/yr);

Seawater Radioactivity Concentrations (gross beta): 12 - 31 pCi/liter; Fish Radioactivity Concentrations (gross beta): 2,200 - 11,300 pCi/kg; Milk Radioactive Cesium-137 Concentrations: 9.3 - 32 pCi/liter; Milk Radioactive Strontium-90 Concentrations: 4.7 - 17.6 pCi/liter; Cranberries Radioactive Cesium-137 Concentrations: 140 - 450 pCi/kg; Forage Radioactive Cesium-137 Concentrations: 150 - 290 pCi/kg.

This information from the pre-operational phase is used as a basis for evaluating changes in radiation and radioactivity levels in the vicinity of the plant following plant operation. In April 1972, just prior to initial reactor startup (June 12, 1972), Boston Edison Company implemented a comprehensive operational environmental monitoring program at Pilgrim Nuclear Power Station. This program (Reference 13) provides information on radioactivity and radiation levels in the environment for the purpose of:

demonstrating that doses to the general public and levels of radioactivity in the environment are within established limits and legal requirements; monitoring the transfer and long-term buildup of specific radionuclides in the environment to revise the monitoring program and environmental models in response to changing conditions; checking the condition of the station's operation, the adequacy of operation in relation to the adequacy of containment, and the effectiveness of effluent treatment so as to provide a mechanism of determining unusual or unforeseen conditions and, where appropriate, to trigger special environmental monitoring studies; assessing the dose equivalent to the general public and the behavior of radioactivity released during the unlikely event of an accidental release; and, Page 20

determining whether or not the radiological impact on the environment and humans is significant.

The Nuclear Regulatory Commission requires that Pilgrim Station provide monitoring of the plant environs for radioactivity that will be released as a result of normal operations and from postulated accidents. The NRC has established guidelines (Reference 14) that specify an acceptable monitoring program. The PNPS Radiological Environmental Monitoring Program was designed to meet and exceed these guidelines. Guidance contained in the NRC's Radiological Assessment Branch Technical Position on Environmental Monitoring (Reference 15) has been used to improve the program. In addition, the program has incorporated the provisions of an agreement made with the Massachusetts Wildlife Federation (Reference 16). The program was supplemented by including improved analysis of shellfish and sediment at substantially higher sensitivity levels to verify the adequacy of effluent controls at Pilgrim Station.

2.2 Environmental Monitoring Locations Sampling locations have been established by considering meteorology, population distribution, hydrology, and land use characteristics of the Plymouth area. The sampling locations are divided into two classes, indicator and control. Indicator locations are those that are expected to show effects from PNPS operations, if any exist. These locations were primarily selected on the basis of where the highest predicted environmental concentrations would occur. While the indicator locations are typically within a few kilometers of the plant, the control stations are generally located so as to be outside the influence of Pilgrim Station. They provide a basis on which to evaluate fluctuations at indicator locations relative to natural background radiation and natural radioactivity and fallout from prior nuclear weapons tests.

The environmental sampling media collected in the vicinity of Pilgrim Station during 2021 included air particulate filters, seawater, sediment, shellfish, American lobster, and fishes. The sampling medium, station description, station number, distance, and direction for indicator and control samples are listed in Table 2.2-1. These sampling locations are also displayed on the maps shown in Figures 2.2-1 through 2.2-6.

The radiation monitoring locations for the environmental TLDs are shown in Figures 2.2-1 through 2.2-

4. The frequency of collection and types of radioactivity analysis are described in Pilgrim Station's ODCM, Sections 3/4.5.

The land-based (terrestrial) samples, seawater, and monitoring devices are collected by station personnel. The aquatic samples are collected by Normandeau Associates, Inc. The radioactivity analysis of samples are performed by the Teledyne Brown Engineering Laboratory, and the environmental dosimeters are analyzed by Stanford Dosimetry.

The frequency, types, minimum number of samples, and maximum lower limits of detection (LLD) for the analytical measurements, are specified in the PNPS ODCM. During 2003, a revision was made to the PNPS ODCM to standardize it to the model program described in NUREG-1302 (Reference 14) and the Branch Technical Position of 1979 (Reference 15). In accordance with this standardization, a number of changes occurred regarding the types and frequencies of sample collections.

In regard to terrestrial REMP sampling, routine collection and analysis of soil samples was discontinued in lieu of the extensive network of environmental TLDs around PNPS, and the weekly collection of air samples at air sample locations. Such TLD monitoring and air sampling would provide an early indication of any potential deposition of radioactivity, and follow-up soil sampling could be performed on an as-needed basis. Also, with the loss of the indicator milk sample at the Plymouth County Farm and the lack of a sufficient substitute location that could provide suitable volumes for analysis, it was deemed unnecessary to continue to collect and analyze control samples of milk. NRC guidance (Reference 14) contains provisions for collection of vegetation in lieu of milk sampling. Such samples have historically been collected near Pilgrim Station as part of the routine REMP program. With the permanent shut Page 21

down of the plant and the decay of Iodine the need for vegetation samples is also no longer necessary.

Sample collection requirements have since been removed from the REMP program.

In the area of marine sampling, a number of the specialized sampling and analysis requirements implemented as part of the Agreement with the Massachusetts Wildlife Federation (Reference 16) for licensing of a second reactor at PNPS were dropped. When the ODCM was revised in 1999 in accordance with NRC Generic Letter 89-01, the sampling program description was relocated to the ODCM. Steps were taken in 2003 to standardize the PNPS ODCM to the NUREG-1302 model, the specialized marine sampling requirements were changed to those of the model program. These changes include the following:

A sample of the surface layer of sediment is collected, as opposed to specialized depth-incremental sampling to 30 cm and subdividing cores into 2 cm increments.

Standard LLD levels of approximately 150 to 180 pCi/kg were established for sediment, as opposed to the specialized LLDs of 50 pCi/kg.

Specialized analysis of sediment for plutonium isotopes was removed.

Sampling of Irish moss, shellfish, and fish was rescheduled to a semiannual period, as opposed to a specialized quarterly sampling interval.

Analysis of only the edible portions of shellfish (mussels and clams), as opposed to specialized additional analysis of the shell portions.

Standard LLD levels of 130 to 260 pCi/kg were established for edible portions of shellfish, as opposed to specialized LLDs of 5 pCi/kg.

Upon receipt of the analysis results from the analytical laboratories, the PNPS staff reviews the results.

If the radioactivity concentrations are above the reporting levels, the NRC must be notified within 30 days. For radioactivity that is detected that is attributable to Pilgrim Station's operation, calculations are performed to determine the cumulative dose contribution for the current year. Most importantly, if radioactivity levels in the environment become elevated as a result of the station's operations, an investigation is performed and corrective actions are recommended to reduce the amount of radioactivity to as far below the legal limits as is reasonably achievable.

The radiological environmental sampling locations are reviewed annually, and modified if necessary.

The accuracy of the data obtained through Program is ensured through a comprehensive Quality Assurance (QA) programs. PNPS's QA program has been established to ensure confidence in the measurements and results of the radiological monitoring program through:

Regular surveillances of the sampling and monitoring program; An annual audit of the analytical laboratory by the sponsor companies; Participation in cross-check programs; Use of blind duplicates for comparing separate analyses of the same sample; and, Spiked sample analyses by the analytical laboratory.

QA audits and inspections of the Radiological Environmental Monitoring Program are performed by the NRC, American Nuclear Insurers, and by the PNPS Quality Assurance Audits.

The Teledyne Brown Engineering Laboratory conducts extensive quality assurance and quality control programs. The 2021 results of these programs are summarized in Appendix E. These results indicate that the analyses and measurements performed during 2021 exhibited acceptable precision and accuracy.

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2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2021. Data for each environmental medium are included in a separate section. A table that summarizes unit of measurement for each medium is listed at the top of each table. The left hand column contains the radionuclides being reported, total number of analyses of that radionuclide, and the number of measurements that exceed ten times the yearly average for the control station(s). The latter are classified as "non-routine" measurements. The next column lists the Lower Limit of Detection (LLD) for those radionuclides that have detection capability requirements specified in the PNPS ODCM.

Those sampling stations within the range of influence of Pilgrim Station and which could conceivably be affected by its operations are called "indicator" stations. Distant stations, which are beyond plant influence, are called "control" stations. Ambient radiation monitoring stations are broken down into four separate zones to aid in data analysis based on distance.

For each sampling medium, each radionuclide is presented with a set of statistical parameters. This set of statistical parameters includes separate analyses for (1) the indicator stations, (2) the station having the highest annual mean concentration, and (3) the control stations. For each of these three groups of data, the following values are calculated:

The mean value of detectable concentrations, including only those values above LLD; The standard deviation of the detectable measurements; The lowest and highest concentrations; and, The number of measurements with results greater than the Minimum Detectable Activity (activity which is three times greater than the standard deviation), out of the total number of measurements.

Each single radioactivity measurement datum is based on a single measurement and is reported as a concentration plus or minus one standard deviation. The quoted uncertainty represents only the random uncertainty associated with the measurement of the radioactive decay process (counting statistics), and not the propagation of all possible uncertainties in the sampling and analysis process.

A sample or measurement is considered to contain detectable radioactivity if the measured value (e.g.,

concentration) exceeds three times its associated standard deviation. For example, a vegetation sample with a cesium-137 concentration of 85 21 pCi/kilogram would be considered "positive" (detectable Cs-137), whereas another sample with a concentration of 60 32 pCi/kilogram would be considered "negative", indicating no detectable cesium-137. The latter sample may actually contain cesium-137, but the levels counted during its analysis were not significantly different than the background levels.

The analytical laboratory that analyzes the various REMP samples employs a background subtraction correction for each analysis. A blank sample that is known not to contain any plant-related activity is analyzed for radioactivity, and the count rate for that analysis is used as the background correction.

That background correction is then subtracted from the results for the analyses in that given set of samples. For example, if the blank/background sample produces 50 counts, and a given sample being analyzes produces 47 counts, then the net count for that sample is reported as -3 counts. That negative value of -3 counts is used to calculate the concentration of radioactivity for that particular analysis. Such a sample result is technically more valid than reporting a q

)

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As an example of how to interpret data presented in the results tables, refer to the first entry on the table for air particulate filters (page 41). Gross beta (GR-B) analyses were performed on 569 routine samples. None of the samples exceeded ten times the average concentration at the control location.

The lower limit of detection (LLD) required by the ODCM is 0.01 pCi/m 3.

For samples collected from the seven indicator stations, 288 out of 288 samples indicated detectable gross beta activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 288 indicator station samples was 0.017 0.0054 (1.7E-2 5.4E-3) pCi/m3. Individual values ranged from 0.0072 to 0.049 (7.2E-3 4.9E-2) pCi/m3 The monitoring station which yielded the highest mean concentration was the sample location ER (East Rocky Hill Road), which yielded a mean concentration of 0.018 0.006 pCi/m3, based on 53 detectable indications out of 53 samples observations. Individual values ranged from 0.0075 to 0.045 pCi/m3.

At the control location, 53 out of 53 samples yielded detectable gross beta activity, for an average concentration of 0.017 0.0043 pCi/m3. Individual samples at the East Weymouth control location ranged from 0.0088 to 0.025 pCi/m3.

Analyses for cesium-137 (Cs-137) were performed 44 times (quarterly composites for 11 stations

• 4 quarters). No samples exceeded ten times the mean control station concentration. The required LLD value Cs-137 in the PNPS ODCM is 0.06 pCi/m3.

At the indicator stations, all 40 of the Cs-137 measurements were below the detection level. The same was true for the four measurements made on samples collected from the control location.

Analyses for Beryllium-7 (Be-7) are used to indicate representative sampling for air samplers in environmental applications.

2.4 Ambient Radiation Measurements The primary technique for measuring ambient radiation exposure in the vicinity of Pilgrim Station involves posting environmental thermoluminescent dosimeters (TLDs) at given monitoring locations and retrieving the TLDs after a specified time period. The TLDs are then taken to a laboratory and processed to determine the total amount of radiation exposure received over the period. Although TLDs can be used to monitor radiation exposure for short time periods, environmental TLDs are typically posted for periods of one to three months. Such TLD monitoring yields average exposure rate measurements over a relatively long time period. The PNPS environmental TLD monitoring program is based on a quarterly (three month) posting period, and a total of 44 locations are monitored using this technique.

The number of TLD were reduced in April 2020 after the permanent shut down of the Pilgrim station, then again in 2021 to collapse the outer ring to 3km from the plant. Only the 2 control locations Division of Marine Fisheries (DMF) and East Weymouth (EW) and the indicator station Manomet Elementary (ME) remain outside of the 3km distance. In addition, 4 of the 44 TLDs are currently located onsite, within the PNPS protected/restricted area, as well as 12 out of 44 are currently located outside the protected area but inside the site boundary and area used for business purposes only where the general public does not have access.

Thoug physically be accessed, jersey barriers, signage and security tours would drastically limit the stay of a person with out proper authorization to be within the areas.

Out of the 189 TLDs posted in the environment during 2021, 185 were retrieved and processed. The results for environmental TLDs located offsite, beyond the PNPS protected/restricted area fence, are presented in Table 2.4-1. Results from onsite TLDs posted within the restricted area are presented in Table 2.4-2. In addition to TLD results for individual locations, results from offsite TLDs were grouped according to geographic zone to determine average exposure rates as a function of distance. These Page 24

results are summarized in Table 2.4-3. All of the listed exposure values represent continuous occupancy (2190 hr/qtr or 8760 hr/yr).

Annual exposure rates measured at locations beyond the PNPS protected area boundary ranged from 48 to 329 mR/yr. The average exposure rate at control locations greater than 15 km from Pilgrim Station (i.e., Zone 4) was 72.8 +/- 4.0 mR/yr. When the 3-sigma confidence interval is calculated based on these control measurements, 99% of all measurements of background ambient exposure would be expected to be between 60 and 84 mR/yr. The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 48 to 86 mR/yr, which compares favorably with the preoperational results of 37 - 190 mR/yr.

Inspection of onsite TLD results listed in Table 2.4-2 indicates that all of those TLDs located within the PNPS protected/restricted area yield exposure measurements higher than the average natural background. Such results are expected due to the close proximity of these locations to the movement of station spent fuel into dry casks as well as radwaste material for storage or shipment.

A small number of offsite TLD locations in close proximity to the protected/restricted area indicated ambient radiation exposure above expected background levels. All of these locations are on Pilgrim Station controlled property, and experience exposure increases due to proximity to the onsite fuel storage pad (e.g., locations OA, TC, and P01) and/or transit and storage of radwaste onsite (e.g.,

locations BLE and BLW). Due to heightened security measures following September 11 2001, members for the general public do not have access to such locations within the owner-controlled area.

It should be noted that several of the TLDs used to calculate the Zone 1 averages presented in Table 2.4-3 are located on Pilgrim Station property. If the Zone 1 value is corrected for the near-site TLDs (those less than 0.6 km from the Reactor Building), the Zone 1 mean falls from a value of 90.5 +/- 70.6 mR/yr to 64.7 8.9 mR/yr. Additionally, exposure rates measured at areas beyond the site did not indicate any increase in ambient exposure from Pilgrim Station operation. For example, the annual exposure rate calculated from the TLD adjacent to the nearest offsite residence 0.80 kilometers (0.5 miles) southeast of the PNPS Reactor Building was 58.2 2.0 mR/yr, which compares not too far off with the average control location exposure of 67.6 +/- 3.7 mR/yr.

In conclusion, measurements of ambient radiation exposure around Pilgrim Station do not indicate any significant increase in exposure levels. Although some increases in ambient radiation exposure level were apparent on site property very close to Pilgrim Station, there were no measurable increases at areas beyond the site 2.5 Air Particulate Filter Radioactivity Analyses Airborne particulate radioactivity is sampled by drawing a stream of air through a glass fiber filter that has a very high efficiency for collecting airborne particulates. These samplers are operated continuously, and the resulting filters are collected weekly for analysis. Weekly filter samples are analyzed for gross beta radioactivity, and the filters are then composited on a quarterly basis for each location for gamma spectroscopy analysis. PNPS uses this technique to monitor locations in the Plymouth area, along with the control location in East Weymouth. At the start of 2021 seven locations were monitored. One location (Manomet Substation) was no longer needed due to the plant condition and was discontinued with the change to the ODCM in June 2021.

Out of 342 filters (6 locations

• 53 weeks and 1 location

• 24 weeks), 335 samples were collected and analyzed during 2021. There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes. Although these filters were analyzed, the LLDs were not met and these analyses were not included with the other results. East Breakwater had three instances in the first quarter 2021 where the Page 25

activities on site were not communicated and the power was interrupted. All of these discrepancies are noted in Appendix D.

The results of the analyses performed on these 335 filter samples are summarized in Table 2.5-1. Trend plots for the gross beta radioactivity levels at the near station, property line, and offsite airborne monitoring locations are shown in Figures 2.5-1, 2.5-2 and 2.5-3, respectively. Gross beta radioactivity was detected in 335 of the filter samples collected, including 53 of the 53 control location samples. This gross beta activity arises from naturally-occurring radionuclides such as radon decay daughter products. Naturally-occurring beryllium-7 was detected in 40 out of 40 of the quarterly composites analyzed with gamma spectroscopy. No airborne radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2021, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.6 Milk Radioactivity Analyses As included in a provision in standard ODCM guidance in NUREG-1302 (Reference 13), sampling and analysis of vegetation from the offsite locations calculated to have the highest D/Q deposition factor can be performed in lieu of milk sampling. Such vegetation sampling has been routinely performed at Pilgrim Station as part of the radiological environmental monitoring program, but due to plant condition the requirement for sampling no longer applies. Sample requirements and sample locations were removed in ODCM revision 15.

2.7 Vegetable/Vegetation Radioactivity Analyses Vegetation sampling as well as the Land Use census was discontinued, removed from the ODCM in revision 15 as described in the milk section above. Crop based foodstuffs no longer exist within a 5 mile radius on the plant (previously cranberries and Irish Moss) and were previously removed from the ODCM. The use of broadleaf vegetation was to account for the deposition of iodine on a type of cattle feed in lieu of sampling for milk. As there are no milk farms within the influence of the plant and the need to account for changes in new or old gardens has diminished with the shutdown and fuel removal at the plant, the requirement was removed.

Broadleaf vegetation may still be consumed by humans, and it will be projected and accounted for in the dose modelling for all nuclides remaining that are released off site, but the only radionuclide detected in REMP samples while the plant was operating was Cs-137 from fall out (recently Chernobyl and Fukashima) which is deposited on and absorbed thru the roots of plants and trees and has a 30-year half-life.

The current dose model for gaseous release dose calculations utilizes a garden at the site boundary in the predominant downwind direction. As this is the most conservative scenario, no land use census will produce an alternat garden with higher off-site dose potential.

2.8 Surface Water Radioactivity Analyses Samples of surface water are routinely collected from the discharge canal and from the control location at Powder Point Bridge in Duxbury. Grab samples are collected weekly from the Powder Point Bridge location. Samples of surface water are composited every four weeks and analyzed by gamma spectroscopy. These monthly composites are further composited on a quarterly basis and tritium analysis is performed on these quarterly samples.

A total of 32 samples of surface water were collected and analyzed as required during 2021. Bartlett Pond sample point was removed from the ODCM in the fourth Quarter 2019. Results of the analyses Page 26

of water samples are summarized in Table 2.12-1. Naturally-occurring potassium-40 was detected in all monthly composite samples, especially those composed primarily of seawater. No radioactivity attributable to Pilgrim Station was detected in any of the surface water samples collected during 2021.

In response to the Nuclear Energy Institute Groundwater Protection Initiative, Pilgrim Station installed a number of groundwater monitoring wells within the protected area in late 2007. Because all of these wells are onsite, they are not included in the offsite radiological monitoring program, and are not in the Annual Radioactive Effluent Release Report.

2.9 Sediment Radioactivity Analyses Samples of sediment are routinely collected from the outfall area of the discharge canal and from three other locations in the Plymouth area (Manomet Point, Plymouth Harbor and Plymouth Beach), and from control locations in Duxbury and Marshfield. Samples are collected twice per year by marine sampling vendor (Normandeau) and are analyzed by gamma spectroscopy.

Twelve of twelve required samples of sediment were collected during 2021 plus two extra samples collected from Duxbury Bay. Gamma analyses were performed on these samples. Results of the gamma analyses of sediment samples are summarized in Table 2.13-1. Naturally-occurring potassium-40 and actinium/thorium-228 were detected in all of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2021, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.10 Shellfish Radioactivity Analyses Samples of blue mussels and soft-shell clams are collected from the discharge canal outfall and one other location in the Plymouth area (Plymouth Harbor), and from control locations in Duxbury and Marshfield. All samples are collected on a semiannual basis, and edible portions processed in the laboratory for gamma spectroscopy analysis.

Ten of the ten required samples of shellfish meat scheduled for collection during 2021 were obtained and analyzed. Results of the gamma analyses of these samples are summarized in Table 2.15-1.

Naturally-occurring potassium-40 was detected in ten of the ten the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2021, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.11 Lobster Radioactivity Analyses Samples of lobsters are routinely collected from the outfall area of the discharge canal and from control locations in Cape Cod Bay. Samples are collected monthly from the discharge canal outfall from June through September and once annually from the control locations. All lobster samples are normally analyzed by gamma spectroscopy.

Five samples of lobsters were collected as required during 2021. Results of the gamma analyses of these samples are summarized in Table 2.16-1. Naturally-occurring potassium-40 was detected in five of the five of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2021, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.12 Fish Radioactivity Analyses Samples of fish are routinely collected from the area at the outfall of the discharge canal and from the control locations in Cape Cod Bay and Buzzard's Bay. Fish species are grouped into four major categories according to their biological requirements and mode of life. These major categories and the representative species are as follows:

Group I Bottom-Oriented: Winter Flounder, Yellowtail Flounder Group II - Near-Bottom Distribution: Tautog, Cunner, Pollock, Atlantic Cod, Hake Group III - Anadromous: Alewife, Smelt, Striped Bass Group IV - Coastal Migratory: Bluefish, Herring, Menhaden, Mackerel Group I fishes are sampled on a semiannual basis from the outfall area of the discharge canal, and on an annual basis from a control location. Group II, III, and IV fishes are sampled annually from the discharge canal outfall and control location. All samples of fish are analyzed by gamma spectroscopy.

Eight samples of fish were collected during 2021. The seasonal sample of Group III fish (alewife, smelt, striped bass) from the Discharge Outfall becomes increasingly more difficult. Many fish species gravitated to the warmer waters. With the shutdown of the station the discharge flow and heat was reduced. These discrepancies are discussed in Appendix D. Results of the gamma analyses of fish samples collected are summarized in Table 2.17-1. The only radionuclide detected in any of the fish samples was naturally-occurring potassium-40. No radioactivity attributable to Pilgrim Station was detected in any of the fish samples collected during 2021, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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Table 2.2-1 Routine Radiological Environmental Sampling Locations Pilgrim Nuclear Power Station, Plymouth, MA Description Code Distance Direction Air Particulate Filters East Rocky Hill Road ER 0.9 km SE Property Line PL 0.5 km NNW Pedestrian Bridge PB 0.2 km N East Breakwater EB 0.5 km ESE Cleft Rock CR 1.3 km SSW East Weymouth (Control) EW 40 km NW Surface Water Discharge Canal DIS 0.2 km N Powder Point (Control) PP 13 km NNW Sediment Discharge Canal Outfall DIS 0.8 km NE Plymouth Harbor Ply-H 4.1 km W Duxbury Bay (Control) Dux-Bay 14 km NNW Plymouth Beach PLB 4.0 km WNW Manomet Point MP 3.3 km ESE Green Harbor (Control) GH 16 km NNW Shellfish Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor Ply-H 4.1 km W Duxbury Bay (Control) Dux-Bay 13 km NNW Manomet Point MP 4.0 km ESE Green Harbor (Control) GH 16 km NNW Lobster Discharge Canal Outfall DIS 0.5 km N Plymouth Harbor Ply-H 6.4 km WNW Duxbury Bay (Control) Dux-Bay 11 km NNW Fishes Discharge Canal Outfall DIS 0.5 km N Vineyard Sound (Control) MV 64 km SSW (Control) BB 40 km SSW Cape Cod Bay (Control) CC-Bay 24 km ESE Page 29

Table 2.4-1 Offsite Environmental TLD Results TLD Station TLD Location* Quarterly Exposure - mR/quarter (Value Std.Dev.)

2021 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/year Zone 1 TLDs: 0-3 km 0-3 km 21.0 +/- 14.4 21.9 +/- 13.6 21.8 +/- 13.1 25.8 +/- 26.6 90.5 +/- 70.6 BLW BOAT LAUNCH WEST 0.11 km E 54.1 +/- 3.3 59.2 +/- 2.8 51.5 +/- 1.9 45.8 +/- 1.9 210.6 +/- 22.8 OA OVERLOOK AREA 0.15 km W 37.6 +/- 2.4 38.6 +/- 1.9 39.7 +/- 2.4 32.9 +/- 1.3 148.7 +/- 12.7 TC HEALTH CLUB 0.15 km WSW 17.5 +/- 1.1 17.8 +/- 1.0 18.5 +/- 0.6 18.1 +/- 1.1 71.9 +/- 2.5 BLE BOAT LAUNCH EAST 0.16 km ESE 89.7 +/- 3.3 77.7 +/- 5.1 79.4 +/- 4.8 82.1 +/- 4.9 328.9 +/- 22.9 ISF-3 ISFSI-3 0.21 km W 23.3 +/- 1.2 24.4 +/- 1.1 34.2 +/- 1.0 152.7 +/- 4.8 234.6 +/- 251.7 P01 SHOREFRONT SECURITY 0.22 km NNW 20.2 +/- 1.3 21.1 +/- 0.9 19.6 +/- 0.7 17.9 +/- 0.9 78.7 +/- 5.9 WS MEDICAL BUILDING 0.23 km SSE 12.1 +/- 0.5 Removed Removed Removed 12.1 +/- 0.5 ISF-2 ISFSI-2 0.28 km W 18.2 +/- 0.8 19.8 +/- 0.6 21.9 +/- 0.7 32.5 +/- 1.4 92.3 +/- 25.8 ISF-1 ISFSI-1 0.35 km SW 18.6 +/- 1.0 20.6 +/- 0.7 20.5 +/- 0.8 19.8 +/- 1.1 79.5 +/- 4.0 PA SHOREFRONT PARKING 0.35 km NNW 18.5 +/- 0.6 18.2 +/- 0.8 18.8 +/- 0.5 18.2 +/- 1.0 73.6 +/- 1.9 A STATION A 0.37 km WSW 15.6 +/- 0.7 15.8 +/- 0.7 15.3 +/- 0.5 16.4 +/- 1.0 63.1 +/- 2.4 EB EAST BREAKWATER 0.44 km ESE 21.8 +/- 1.1 22.6 +/- 0.8 23.0 +/- 0.9 24.4 +/- 1.4 91.7 +/- 5.0 B STATION B 0.44 km S 21.4 +/- 0.9 22.0 +/- 1.1 22.0 +/- 0.7 21.7 +/- 1.5 87.1 +/- 2.4 PMT PNPS MET TOWER 0.44 km WNW 17.6 +/- 0.6 M+/-M 16.4 +/- 0.7 19.2 +/- 1.6 70.9 +/- 6.2 L STATION L 0.50 km ESE 26.0 +/- 1.6 29.3 +/- 1.7 30.2 +/- 1.6 29.8 +/- 1.6 115.4 +/- 8.3 G STATION G 0.53 km W 14.5 +/- 0.7 14.9 +/- 0.7 15.2 +/- 0.4 15.7 +/- 1.0 60.3 +/- 2.4 PL PROPERTY LINE 0.54 km NW 16.4 +/- 0.8 17.1 +/- 0.7 17.5 +/- 0.6 18.9 +/- 1.0 69.9 +/- 4.6 HB HALL'S BOG 0.63 km SE 18.8 +/- 0.7 19.2 +/- 0.6 19.4 +/- 1.7 18.9 +/- 1.1 76.3 +/- 2.5 GH GREENWOOD HOUSE 0.65 km ESE 16.5 +/- 0.8 16.9 +/- 0.5 17.0 +/- 0.6 16.7 +/- 1.0 67.1 +/- 1.7 WR W ROCKY HILL ROAD 0.83 km WNW 20.2 +/- 1.3 21.0 +/- 0.7 21.6 +/- 0.5 22.8 +/- 1.2 85.6 +/- 4.9 ER E ROCKY HILL ROAD 0.89 km SE 14.3 +/- 0.5 14.3 +/- 0.6 15.1 +/- 0.5 14.5 +/- 1.0 58.2 +/- 2.0 CR CLEFT ROCK 1.27 km SSW 19.3 +/- 0.8 18.3 +/- 0.6 18.5 +/- 0.6 18.4 +/- 1.0 74.4 +/- 2.4 BD BAYSHORE/GATE RD 1.34 km WNW 16.9 +/- 0.5 17.4 +/- 0.9 17.5 +/- 0.6 17.4 +/- 0.9 69.2 +/- 1.9 EM EMERSON ROAD 1.53 km SSE 16.0 +/- 0.6 16.3 +/- 0.6 16.4 +/- 0.5 15.4 +/- 1.0 64.0 +/- 2.3 EP EMERSON/PRISCILLA 1.55 km SE 15.2 +/- 0.5 15.6 +/- 0.6 15.9 +/- 0.5 15.8 +/- 0.9 62.5 +/- 1.7 BS BAYSHORE 1.76 km W 17.1 +/- 1.0 17.9 +/- 0.7 17.5 +/- 0.7 M+/-M 69.9 +/- 2.5 JG JOHN GAULEY 1.99 km W 16.4 +/- 0.9 16.1 +/- 0.6 16.1 +/- 0.7 18.1 +/- 1.4 66.6 +/- 4.2 J STATION J 2.04 km SSE 14.4 +/- 0.5 M+/-M 14.7 +/- 0.7 14.2 +/- 1.0 57.8 +/- 2.0 RC PLYMOUTH YMCA 2.09 km WSW 14.9 +/- 0.7 15.0 +/- 0.9 14.9 +/- 0.5 14.5 +/- 0.9 59.2 +/- 1.8 TT TAYLOR/THOMAS 2.26 km SE 15.1 +/- 0.7 16.3 +/- 0.6 15.9 +/- 0.7 16.0 +/- 1.3 63.2 +/- 2.6 YV YANKEE VILLAGE 2.28 km WSW 16.2 +/- 0.5 16.5 +/- 0.6 16.5 +/- 0.4 15.8 +/- 0.9 65.0 +/- 1.8 GN GOODWIN PROPERTY 2.38 km SW 11.8 +/- 0.4 12.1 +/- 0.4 12.2 +/- 0.6 11.9 +/- 0.9 48.0 +/- 1.5 RW RIGHT OF WAY 2.83 km S 14.0 +/- 1.2 13.3 +/- 0.7 13.5 +/- 0.5 13.1 +/- 0.8 54.0 +/- 2.3 TP TAYLOR/PEARL 2.98 km SE 14.9 +/- 0.5 14.9 +/- 0.6 14.8 +/- 0.6 14.7 +/- 0.9 59.3 +/- 1.4

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

• • • TLDs missing will be noted with M.

Page 30

Table 2.4-1 (continued)

Offsite Environmental TLD Results TLD Station TLD Location* Quarterly Exposure - mR/quarter (Value Std.Dev.)

2021 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/year Zone 2 TLDs: 3-8 km 3-8 km 14.8 +/- 2.2 15.4 +/- 2.3 17.2 +/- 0.5 16.6 +/- 0.8 61.6 +/- 8.5 ME MANOMET ELEM 3.29 km SE 16.5 +/- 0.7 17.5 +/- 0.5 17.1 +/- 0.8 16.3 +/- 0.9 67.3 +/- 2.7 MS MANOMET SUBSTATION 3.60 km SSE 16.6 +/- 0.5 17.0 +/- 0.8 17.2 +/- 0.8 16.9 +/- 1.0 67.6 +/- 1.9 PT PINES ESTATE 4.44 km SSW 13.2 +/- 0.7 13.7 +/- 0.5 Removed Removed 53.8 +/- 2.1 RM RUSSELL MILLS RD 4.85 km WSW 13.8 +/- 0.4 14.2 +/- 0.6 Removed Removed 56.0 +/- 1.8 MB MANOMET BEACH 5.43 km SSE 14.0 +/- 0.5 14.7 +/- 0.6 Removed Removed 57.3 +/- 2.5 BR BEAVERDAM ROAD 5.52 km S 14.9 +/- 0.8 14.9 +/- 0.5 Removed Removed 59.6 +/- 1.8 LD LONG POND/DREW RD 6.97 km WSW 11.9 +/- 0.5 12.3 +/- 0.7 Removed Removed 48.5 +/- 2.1 HR HYANNIS ROAD 7.33 km SSE 13.9 +/- 0.8 14.6 +/- 0.6 Removed Removed 57.0 +/- 0.0 MH MEMORIAL HALL 7.58 km WNW 19.5 +/- 0.9 20.4 +/- 0.7 Removed Removed 79.7 +/- 3.3 CP COLLEGE POND 7.59 km SW 13.6 +/- 0.8 14.8 +/- 0.7 Removed Removed 56.8 +/- 4.1 Zone 3 TLDs: 8-15 km 8-15 km 14.6 +/- 2.1 15.3 +/- 1.9 N/A N/A 59.8 +/- 7.6 DW DEEP WATER POND 8.59 km W 16.2 +/- 0.6 17.3 +/- 0.6 Removed Removed 67.1 +/- 3.6 LP LONG POND ROAD 8.88 km SSW 12.4 +/- 0.7 13.4 +/- 0.5 Removed Removed 51.6 +/- 3.3 NP NORTH PLYMOUTH 9.38 km WNW 16.6 +/- 0.5 16.5 +/- 0.8 Removed Removed 66.1 +/- 1.9 SH SACRED HEART 12.92 km W 13.3 +/- 0.5 14.0 +/- 0.6 Removed Removed 54.6 +/- 2.3 Zone 4 TLDs: >15 km >15 km 17.8 +/- 1.1 17.5 +/- 0.6 18.2 +/- 1.4 18.6 +/- 1.5 72.4 +/- 4.0 DMF DIV MARINE FISH 20.97 km SSE 18.5 +/- 0.7 M+/-M 19.1 +/- 0.6 19.5 +/- 1.0 76.2 +/- 2.7 EW E WEYMOUTH SUBST 39.69 km NW 17.1 +/- 0.7 17.5 +/- 0.6 17.3 +/- 0.7 17.6 +/- 1.1 69.5 +/- 1.8

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

• • • TLDs missing will be noted with M.

Page 31

Table 2.4-2 Onsite Environmental TLD Results TLD Station TLD Location* Quarterly Exposure - mR/quarter (Value Std.Dev.)

2021 ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Annual**

Exposure mR/year Onsite TLDs 2429.9 +/-

P17 FENCE-EXEC.BUILDING 107 m W 798.8 +/- 27.2 772.2 +/- 21.7 712.2 +/- 19.3 146.8 +/- 7.7 1237.6 P11 FENCE-TCF GATE 183 m ESE 131.5 +/- 4.7 115.0 +/- 5.7 102.2 +/- 3.0 110.0 +/- 4.9 458.6 +/- 50.5 P27 FENCE-TCF/BOAT RAMP 185 m ESE 68.4 +/- 4.0 66.4 +/- 6.6 66.0 +/- 3.5 66.1 +/- 5.8 266.9 +/- 11.2 P10 FENCE-TCF/INTAKE BAY 223 m E 81.5 +/- 6.3 79.2 +/- 3.8 80.7 +/- 7.6 87.8 +/- 9.3 329.2 +/- 20.7

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

• • • TLDs missing are noted with M.

-P17 shows higher than typical readings due to the movement of dry cask storage canisters and radwaste storage near TLD location, though decreasing in 4th quarter due to casks moving from ISFSI I pad to ISFSI II pad location.

Table 2.4-3 Average TLD Exposures By Distance Zone During 2021 Average Exposure Standard Deviation: mR/period Exposure Zone 1* Zone 2 Zone 3 Zone 4 Period 0-3 km 3-8 km 8-15 km >15 km Jan-Mar 21.0 +/- 14.4 14.8 +/- 2.2 14.6 +/- 2.1 17.8 +/- 1.1 Apr-Jun 21.9 +/- 13.6 15.4 +/- 2.3 15.3 +/- 1.9 17.5 (1)

Jul-Sep 21.8 +/- 13.1 17.2 +/- 0.5 Removed 18.2 +/- 1.4 Oct-Dec 25.8 +/- 26.6 16.6 +/- 0.8 Removed 18.6 +/- 1.5 Jan-Dec 90.5 +/- 70.6 61.6 +/- 8.5 59.8 +/- 7.6 72.4 +/- 4.0

• Zone 1 extends from the PNPS restricted/protected area boundary outward to 3 kilometers (2 miles) and includes several TLDs located within the site boundary.

• • When corrected for TLDs located within the site boundary, the Zone 1 annual average is calculated to be 64.7 +/- 8.9 mR/yr.

(1) No Standard deviation due to single data point.

Page 32

Table 2.5-1 Air Particulate Filter Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: Air Particulates (AP) UNITS: pCi/cubic meter Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Gross Beta 341 0.01 1.7E-2 +/- 5.4E-3 ER: 1.8E-2 +/- 6.3E-3 1.7E-2 +/- 4.3E-3 0 7.2E 4.9E-2 7.5E 4.9E-2 8.8E 2.5E-2 288 / 288 53 / 53 53 / 53 Be-7 44 6.1E-2 +/- 6.3E-2 1.3E-1 +/- 2.2E-2 1.1E-1 +/- 2.3E-2 0 -5.2E 1.6E-1 1.1E 1.5E-1 9.6E 1.5E-1 40 / 40 4/4 4/4 Cs-134 44 0.05 -3.3E-4 +/- 3.9E-3 1.8E-4 +/- 9.5E-4 -1.9E-4 +/- 8.6E-4 0 -1.4E 1.7E-2 -1.2E 7.3E-4 -1.0E 6.0E-4 0 / 40 0/4 0/4 Cs-137 44 0.06 2.1E-5 +/- 4.7E-4 EB: 3.8E-4 +/- 5.5E-4 -7.0E-5 +/- 2.2E-4 0 -1.3E 9.0E-4 -1.1E 9.0E-4 -1.9E 1.7E-4 0 / 40 0/4 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 33

Table 2.7-1 Vegetable/Vegetation Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

As stated in summary sections earlier in this report, vegetation sampling has been discontinued.

Page 34

Table 2.8-1 Surface Water Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: Surface Water (WS) UNITS: pCi/L Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD H-3 12 3000 -4.2E+1 +/- 9.4E+1 PwPt: 5.6E+1 +/- 2.2E+2 5.6E+1 +/- 1.6E+2 0 -1.8E+2 - 2.2E+1 -1.1E+2 - 2.7E+2 -1.1E+2 - 2.7E+2 0/8 0/4 0/4 K-40 24 2.8E+2 +/- 3.3E+1 PwPt: 3.0E+2 +/- 5.3E+1 3.0E+2 +/- 5.3E+1 0 2.4E+2 - 3.4E+2 2.1E+2 - 3.7E+2 2.1E+2 - 3.7E+2 12 / 12 12 / 12 12 / 12 Mn-54 24 15 -2.8E-1 +/- 1.5E+0 Dis: -2.8E-1 +/- 1.5E+0 -2.8E-1 +/- 1.2E+0 0 -2.3E+0 - 2.9E+0 -2.3E+0 - 2.9E+0 -2.5E+0 - 1.5E+0 0 / 12 0 / 12 0 / 12 Fe-59 24 30 -2.2E+0 +/- 4.1E+0 PwPt: 1.6E+0 +/- 3.6E+0 1.6E+0 +/- 3.6E+0 0 -1.0E+1 - 3.0E+0 -4.0E+0 - 8.5E+0 -4.0E+0 - 8.5E+0 0 / 12 0 / 12 0 / 12 Co-58 24 15 -5.8E-1 +/- 1.8E+0 PwPt: -5.1E-1 +/- 1.8E+0 -5.1E-1 +/- 1.8E+0 0 -4.5E+0 - 2.5E+0 -3.6E+0 - 2.3E+0 -3.6E+0 - 2.3E+0 0 / 12 0 / 12 0 / 12 Co-60 24 15 1.6E-1 +/- 2.0E+0 PwPt: 5.8E-1 +/- 1.7E+0 5.8E-1 +/- 1.7E+0 0 -3.5E+0 - 3.8E+0 -1.8E+0 - 3.2E+0 -1.8E+0 - 3.2E+0 0 / 12 0 / 12 0 / 12 Zn-65 24 30 -3.8E+0 +/- 4.3E+0 PwPt: -1.6E+0 +/- 3.9E+0 -1.6E+0 +/- 3.9E+0 0 -1.1E+1 - 1.4E+0 -8.3E+0 - 3.7E+0 -8.3E+0 - 3.7E+0 0 / 12 0 / 12 0 / 12 Zr-95 24 30 -1.8E-1 +/- 3.6E+0 PwPt: 2.8E-1 +/- 2.9E+0 2.8E-1 +/- 2.9E+0 0 -6.6E+0 - 7.5E+0 -3.4E+0 - 6.3E+0 -3.4E+0 - 6.3E+0 0 / 12 0 / 12 0 / 12 Nb-95 24 15 -6.8E-1 +/- 1.6E+0 PwPt: 4.8E-1 +/- 2.7E+0 4.8E-1 +/- 2.7E+0 0 -3.1E+0 - 2.7E+0 -3.6E+0 - 6.3E+0 -3.6E+0 - 6.3E+0 0 / 12 0 / 12 0 / 12 Cs-134 24 15 3.1E-1 +/- 1.7E+0 Dis: 3.1E-1 +/- 1.7E+0 -1.9E-1 +/- 2.0E+0 0 -2.2E+0 - 2.7E+0 -2.2E+0 - 2.7E+0 -3.8E+0 - 2.8E+0 0 / 12 0 / 12 0 / 12 Cs-137 24 18 -2.6E-1 +/- 2.5E+0 PwPt: 4.3E-1 +/- 1.6E+0 4.3E-1 +/- 1.6E+0 0 -6.1E+0 - 3.2E+0 -1.4E+0 - 4.1E+0 -1.4E+0 - 4.1E+0 0 / 12 0 / 12 0/ 12 Ba-140 24 60 -2.6E+0 +/- 1.0E+1 PwPt:3.4E+0 +/- 1.3E+1 3.4E+0 +/- 1.3E+1 0 -2.3E+1 - 1.6E+1 -2.6E+1 - 1.9E+1 -2.6E+1 - 1.9E+1 0 / 12 0 / 12 0 / 12 La-140 24 15 1.8E+0 +/- 5.5E+0 Dis:1.8E+0 +/- 5.5E+0 -9.8E-1 +/- 4.5E+0 0 -9.6E+0 - 1.2E+1 -9.6E+0 - 1.2E+1 -9.8E+0 - 7.0E+0 0 / 12 0 / 12 0 / 12

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 35

Table 2.9-1 Sediment Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: Sediment (SE) UNITS: pCi/kg dry Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 14 9.2E+3 +/- 1.3E+3 DuxBay: 1.5E+4 +/- 5.3E+2 1.3E+4 +/- 2.5E+3 0 7.1E+3 - 1.2E+4 1.4E+4 - 1.5E+4 1.0E+4 - 1.5E+4 8/8 2/2 4/4 Cs-134 14 150 1.5E+1 +/- 2.2E+1 GrnHrb: 4.0E+1 +/- 3.8E+1 3.1E+1 +/- 2.5E+1 0 -4.9E+0 - 5.1E+1 1.4E+1 - 6.6E+1 1.4E+1 - 6.6E+1 0/ 8 0/2 0/4 Cs-137 14 180 -4.6E+0 +/- 1.7E+1 GrnHrb: 1.8E+1 +/- 1.1E+1 1.0E+1 +/- 1.4E+1 0 -3.0E+1 - 2.9E+1 1.3E+1 - 2.3E+1 -7.1E+0 - 2.3E+1 0/8 0/2 0/4 AcTh-228 14 2.5E+2 +/- 5.6E+1 DuxBay: 5.3E+2 +/- 6.7E+1 4.3E+2 +/- 1.3E+2 0 2.0E+2 - 3.6E+2 4.9E+2 - 5.8E+2 3.1E+2 - 5.8E+2 7/7 2/2 4/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 36

Table 2.10-1 Shellfish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: Shellfish (SF) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 10 1.5E+3 +/- 3.8E+2 GrnHrb: 1.8E+3 +/- 2.2E+2 1.6E+3 +/- 3.9E+2 0 1.0E+3 - 1.9E+3 1.7E+3 - 1.8E+3 1.1E+3 - 1.8E+3 6/6 2/2 4/4 Mn-54 10 130 -4.3E+0 +/- 1.3E+1 Duxbay: 3.3E+0 +/- 8.9E+0 -8.7E+0 +/- 1.6E+1 0 -1.9E+1 - 1.2E+1 9.1E 5.7E+0 -2.8E+1 - 5.7E+0 0/6 0/2 0/4 Fe-59 10 260 -2.0E+1 +/- 2.6E+1 Duxbay: 1.4E+1 +/- 5.1E+1 1.2E+1 +/- 3.2E+1 0 -5.0E+1 - 1.1E+1 -2.0E+1 - 4.8E+1 -2.0E+1 - 4.8E+1 0/6 0/2 0/4 Co-58 10 130 1.5E+1 +/- 1.7E+1 PlyHrb: 2.0E+1 +/- 2.0E+1 -7.4E+0 +/- 1.9E+1 0 1.9E+0 - 4.4E+1 1.9E+0 - 4.4E+1 -2.3E+1 - 1.6E+1 0/6 0/4 0/4 Co-60 10 130 7.9E-1 +/- 1.1E+1 Dis: 7.1E+0 +/- 1.8E+1 -4.6E+0 +/- 2.0E+1 0 -6.9E+0 - 1.9E+1 -4.7E+0 - 1.9E+1 -2.9E+1 - 1.7E+1 0/6 0/2 0/4 Zn-65 10 260 -4.3E+1 +/- 3.2E+1 GrnHrb: -4.8E+0 +/- 5.8E+1 -1.1E+1 +/- 3.7E+1 0 -7.4E+1 - 4.2E+0 -4.2E+1 - 3.2E+1 -4.2E+1 - 3.2E+1 0/6 0/2 0/4 Cs-134 10 130 1.5E+1 +/- 2.2E+1 PlyHrb: 2.3E+1 +/- 2.3E+1 -1.4E+1 +/- 2.1E+1 0 -8.4E+0 - 4.0E+1 -8.4E+0 - 4.0E+1 -4.3E+1 - 1.8E+0 0/6 0/ 4 0/4 Cs-137 10 150 -1.0E+1 +/- 2.2E+1 PlyHrb: -8.8E+0 +/- 1.8E+1 -2.2E+1 +/- 1.5E+1 0 -3.9E+1 - 1.3E+1 -2.9E+1 - 1.3E+1 -3.7E+1 - -5.0E+0 0/6 0/4 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 37

Table 2.11-1 Lobster Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: American Lobster (HA) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 5 2.5E+3 +/- 6.2E+2 Dis: 2.5E+3 +/- 6.2E+2 1.8E+3 +/- 3.4E+2 0 1.7E+3 - 3.1E+3 1.7E+3 - 3.1E+3 1.8E+3 - 1.8E+3 4/4 4/4 1/1 Mn-54 5 130 1.3E+1 +/- 2.5E+1 Dis: 1.3E+1 +/- 2.5E+1 8.1E+0 +/- 1.2E+1 0 -8.6E+0 - 4.1E+1 -8.6E+0 - 4.1E+1 8.1E+0 - 8.1E+0 0/4 0/1 0/1 Fe-59 5 260 5.3E+1 +/- 8.7E+1 Dis: 5.3E+1 +/- 8.7E+1 2.8E+1 +/- 2.6E+1 0 -3.2E+1 - 1.7E+2 -3.2E+1 - 1.7E+2 2.8E+1 - 2.8E+1 0/4 0/1 0/1 Co-58 5 130 3.3E+0 +/- 4.4E+1 CcBay: 2.6E+1 +/- 1.1E+1 2.6E+1 +/- 1.1E+1 0 -3.2E+1 - 6.3E+1 2.6E+1 - 2.6E+1 2.6E+1 - 2.6E+1 0/4 0/4 0/1 Co-60 5 130 3.0E+0 +/- 3.0E+1 Dis: 3.0E+0 +/- 3.0E+1 -6.7E+0 +/- 1.4E+1 0 -2.8E+1 - 3.2E+1 -2.8E+1 - 3.2E+1 -6.7E+0 - -6.7E+0 0/4 0/4 0/1 Zn-65 5 260 -7.1E+1 +/- 2.7E+1 Dis: -7.1E+1 +/- 2.7E+1 -1.1E+2 +/- 3.0E+1 0 -9.1E+1 - -4.1E+1 -9.1E+1 - -4.1E+1 -1.1E+2 - -1.1E+2 0/4 0/4 0/1 Cs-134 5 130 1.5E+1 +/- 1.4E+1 Dis: 1.5E+1 +/- 1.4E+1 -1.1E+1 +/- 1.4E+1 0 1.1E+0 - 2.8E+1 1.1E+0 - 2.8E+1 -1.1E+1 - -1.1E+1 0/4 0/1 0/1 Cs-137 5 150 -5.8E-1 +/- 1.1E+1 Dis: -5.8E-1 +/- 1.1E+1 -7.8E+0 +/- 1.2E+1 0 -9.7E+0 - 9.7E+0 -9.7E+0 - 9.7E+0 -7.8E+0 - -7.8E+0 0/4 0/4 0/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 38

Table 2.12-1 Fish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2021)

MEDIUM: Fish (FH) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 8 3.3E+3 +/- 1.0E+3 BuzBay: 3.5E+3 +/- 1.7E+3 3.5E+3 +/- 1.7E+3 0 1.7E+3 - 4.1E+3 2.2E+3 - 5.4E+3 2.2E+3 - 5.4E+3 5/5 3/3 3/3 Mn-54 8 130 -2.2E+0 +/- 3.9E+1 BuzBay: -2.8E-1 +/- 2.1E+1 -2.8E-1 +/- 2.1E+1 0 -6.4E+1 - 3.4E+1 -2.2E+1 - 1.3E+1 -2.2E+1 - 1.3E+1 0/5 0/3 0/3 Fe-59 8 260 4.4E+0 +/- 2.7E+1 Dis: 4.4E+0 +/- 2.7E+1 -4.0E+1 +/- 3.7E+1 0 -1.8E+1 - 3.5E+1 -1.8E+1 - 3.5E+1 -7.7E+1 - -9.1E+0 0/5 0/5 0/3 Co-58 8 130 -3.6E+0 +/- 3.6E+1 Dis: -3.6E+0 +/- 3.6E+1 -3.7E+0 +/- 1.4E+1 0 -4.0E+1 - 5.4E+1 -4.0E+1 - 5.4E+1 -1.8E+1 - 4.2E+0 0/5 0/ 5 0/3 Co-60 8 130 -7.9E+0 +/- 2.9E+1 Dis: -7.9E+0 +/- 2.9E+1 -2.4E+1 +/- 1.1E+1 0 -3.2E+1 - 4.0E+1 -3.2E+1 - 4.0E+1 -3.3E+1 - -1.9E+1 0/5 0/5 0/3 Zn-65 8 260 -4.9E+1 +/- 8.3E+1 Dis: -4.9E+1 +/- 8.3E+1 -9.4E+1 +/- 9.1E+1 0 -1.5E+2 - 5.4E+1 -1.5E+2 - 5.4E+1 -1.6E+2 - 7.0E+0 0/5 0/5 0/3 Cs-134 8 130 5.2E+0 +/- 2.1E+1 BuxBay: 1.4E+1 +/- 1.5E+1 1.4E+1 +/- 1.5E+1 0 -1.3E+1 - 2.8E+1 -6.9E 2.2E+1 -6.9E 2.2E+1 0/5 0/3 0/3 Cs-137 8 150 1.9E+1 +/- 2.6E+1 Dis: 1.9E+1 +/- 2.6E+1 1.3E+1 +/- 1.6E+1 0 -9.8E+0 - 4.8E+1 -9.8E+0 - 4.8E+1 -9.9E 2.7E+1 0/5 0/5 0/3

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

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Figure 2.2-1 Environmental TLD Locations Within the PNPS Protected Area TLD Station Location*

Description Code Distance/Direction TLDs Within Protected Area FENCE-EXEC.BUILDING P17 107 m W FENCE-TCF GATE P11 183 m ESE FENCE-TCF/BOAT RAMP P27 185 m ESE FENCE-TCF/INTAKE BAY P10 223 m E

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

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Figure 2.2-1 (continued)

Environmental TLD Locations Within the PNPS Protected Area Page 41

Figure 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer TLD Station Location* Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km BOAT LAUNCH WEST BLW 0.11 km E PEDESTRIAN BRIDGE PB 0.21 km N OVERLOOK AREA OA 0.15 km W EAST BREAKWATER EB 0.44 km ESE HEALTH CLUB TC 0.15 km WSW PROPERTY LINE PL 0.54 km NNW BOAT LAUNCH EAST BLE 0.16 km ESE E ROCKY HILL ROAD ER 0.89 km SE ISFSI DOSE #3 ISF-3 0.21 km W SHOREFRONT SECURITY P01 0.22 km NNW ISFSI DOSE #2 ISF-2 0.29 km W ISFSI DOSE #1 ISF-1 0.35 km SW SHOREFRONT PARKING PA 0.35 km NNW ISFSI DOSE #4 ISF-4 0.35 km WSW ISFSI DOSE #5 ISF-5 0.37 km WSW STATION A A 0.37 km WSW ISFSI DOSE #6 ISF-6 0.41 km WSW STATION B B 0.44 km S EAST BREAKWATER EB 0.44 km ESE PNPS MET TOWER PMT 0.44 km WNW ISFSI DOSE #7 ISF-7 0.45 km W STATION L L 0.50 km ESE STATION G G 0.53 km W PROPERTY LINE PL 0.54 km NNW HALL'S BOG HB 0.63 km SE GREENWOOD HOUSE GH 0.65 km ESE W ROCKY HILL ROAD WR 0.83 km WNW E ROCKY HILL ROAD ER 0.89 km SE Page 42

Figure 2.2-2 (continued)

TLD and Air Sampling Locations: Within 1 Kilometer Page 43

Figure 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers TLD Station Location* Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km CLEFT ROCK CR 1.27 km SSW CLEFT ROCK CR 1.27 km SSW BAYSHORE/GATE RD BD 1.34 km WNW EMERSON ROAD EM 1.53 km SSE EMERSON/PRISCILLA EP 1.55 km SE BAYSHORE BS 1.76 km W JOHN GAULEY JG 1.99 km W STATION J J 2.04 km SSE PLYMOUTH YMCA RC 2.09 km WSW TAYLOR/THOMAS TT 2.26 km SE YANKEE VILLAGE YV 2.28 km WSW GOODWIN PROPERTY GN 2.38 km SW RIGHT OF WAY RW 2.83 km S TAYLOR/PEARL TP 2.98 km SE Zone 2 TLDs: 3-8 km MANOMET ELEM ME 3.29 km SE

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

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Figure 2.2-3 (continued)

TLD and Air Sampling Locations: 1 to 5 Kilometers Page 45

Figure 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers TLD Station Location* Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 4 TLDs: >15 km EAST WEYMOUTH SUBST EW 39.69 km NW DIV MARINE FISH DMF 20.97 km SSE EAST WEYMOUTH SUBST EW 39.69 km NW

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

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Figure 2.2-4 (continued)

TLD and Air Sampling Locations: 5 to 25 Kilometers Page 47

Figure 2.2-5 Marine/ Aquatic Sampling Locations Description Code Distance/Direction*

SURFACE WATER Discharge Canal DIS 0.2 km N Powder Point Control PP 13 km NNW SEDIMENT Discharge Canal Outfall DIS 0.8 km NE Manomet Point MP 3.3 km ESE Plymouth Beach PLB 4.0 km WNW Plymouth Harbor PLY-H 4.1 km W Green Harbor Control GH 16 km NNW MUSSELS Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor PLY-H 4.1 km W Green Harbor Control GH 16 km NNW SOFT-SHELLED CLAMS Plymouth Harbor PLY-H 4.1 km W Duxbury Bay Control DUX-BAY 13 km NNW LOBSTER Discharge Canal Outfall DIS 0.5 km N Duxbury Bay Control DUX-BAY 11 km NNW FISHES Discharge Canal Outfall DIS 0.5 km N Cape Cod Bay Control CC-BAY 24 km ESE Buzzards Bay Control BB 40 km SSW Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

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Figure 2.2-5 (continued)

Marine/Aquatic Sampling Locations Page 49

Figure 2.2-6 Environmental Sampling And Measurement Control Locations Description Code Distance/Direction* Description Code Distance/Direction*

TLD (Controls) SURFACE WATER Div. Marine Fisheries DMF 21 km SSE Powder Point Control PP 13 km NNW East Weymouth Substation EW 40 km NW SEDIMENT AIR SAMPLING (Control) Green Harbor Control GH 16 km NNW East Weymouth Substation EW 40 km NW MUSSELS Green Harbor Control GH 16 km NNW SOFT-SHELLED CLAMS Duxbury Bay Control DUX-BAY 13 km NNW LOBSTER Duxbury Bay Control DUX-BAY 11 km NNW FISHES Cape Cod Bay Control CC-BAY 24 km ESE Buzzards Bay Control BB 40 km SSW Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

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Figure 2.2-6 (continued)

Environmental Sampling And Measurement Control Locations Page 51

Figure 2.5-1 Airborne Gross-Beta Radioactivity Levels: Near Station Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Dec Jan Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2021 AP-07 Pedestrian Bridge AP-09 East Breakwater AP-21 East Weymouth Control Page 52

Figure 2.5-2 Airborne Gross-Beta Radioactivity Levels: Property Line Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Dec Jan Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2021 AP-01 E. Rocky Hill Road AP-06 Property Line AP-21 East Weymouth Control Page 53

Figure 2.5-3 Airborne Gross-Beta Radioactivity Levels: Offsite Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Dec Jan Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2021 AP-10 Cleft Rock AP-17 Manomet Substation AP-21 East Weymouth Control

• Manomet substation collection was discontinued after the ODCM revision 15 collapsed the outer sampling ring to 3km.

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3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS The radiological impact to humans from the Pilgrim Station's radioactive liquid and gaseous releases has been estimated using two methods:

calculations based on measurements of plant effluents; and calculations based on measurements of environmental samples.

The first method utilizes data from the radioactive effluents (measured at the point of release) together with conservative models that calculate the dispersion and transport of radioactivity through the environment to humans (Reference 7). The second method is based on actual measurements of radioactivity in the environmental samples and on dose conversion factors recommended by the Nuclear Regulatory Commission. The measured types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during 2021 were reported to the Nuclear Regulatory Commission The measured levels of radioactivity in the special studies environmental samples that required dose calculations are listed in Appendix A.

The maximum individual dose from liquid effluents is calculated using the following radiation exposure pathways:

shoreline external radiation during fishing and recreation at the Pilgrim Station Shorefront; Note:

there is no actual access to the shorefront allowed to a MEMBER of the PUBLIC. Recreational areas were closed to unauthorized personnel after 9/11.

external radiation from the ocean during boating and swimming; and ingestion of fish and shellfish.

For gaseous effluents, the maximum individual dose was calculated using the following radiation exposure pathways:

external radiation from cloud shine and submersion in gaseous effluents; inhalation of airborne radioactivity; external radiation from soil deposition; consumption of vegetables; and consumption of milk and meat. Note: There are no milk/ meat animals in the vicinity Pilgrim Station The results from the dose calculations based on PNPS operations are presented in Table 3.0-1. The dose assessment data presented were taken from the "Radioactive Effluent Release Report" for the period of January 1 through December 31, 2021 (Reference 17).

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Table 3.0-1 Radiation Doses from 2021 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway - mrem/yr Gaseous Liquid Ambient Receptor Effluents* Effluents Radiation** Total Total Body 0.00023 N/A 0.30 0.30 Thyroid 0.00015 N/A 0.30 0.30 Max. Organ 0.00024 N/A 0.30 0.30

• Gaseous effluent exposure pathway includes combined dose from particulates and tritium, calculated at the nearest residence or receptor location yielding the highest projected dose from all exposure pathways.

• • Ambient radiation dose for the hypothetical maximum-exposed individual at a location beyond the PNPS owner-controlled area yielding highest ambient radiation exposure value as measured with TLDs.

Two federal agencies establish dose limits to protect the public from radiation and radioactivity. The Nuclear Regulatory Commission (NRC) specifies a whole body dose limit of 100 mrem/yr to be received by the maximum exposed member of the general public. This limit is set forth in Section 1301, Part 20, Title 10, of the U.S. Code of Federal Regulations (10CFR20). By comparison, the Environmental Protection Agency (EPA) limits the annual whole body dose to 25 mrem/yr, which is specified in Section 10, Part 190, Title 40, of the Code of Federal Regulations (40CFR190).

Another useful "gauge" of radiation exposure is provided by the amount of dose a typical individual receives each year from natural and man-made sources of radiation. Such radiation doses are summarized in Table 1.2-1. The typical American receives approximately 620 mrem/yr from such sources.

As can be seen from the doses resulting from Pilgrim Station decommissioning operations during 2021, all values are well within the federal limits specified by the NRC and EPA. In addition, the calculated doses from PNPS operation represent only a fraction of a percent of doses from natural and man-made radiation.

In conclusion, the radiological impact of Pilgrim Station decommissioning operations, whether based on actual environmental measurements or calculations made from effluent releases, would yield doses well within any federal dose limits set by the NRC or EPA. Such doses represent only a small percentage of the typical annual dose received from natural and man-made sources of radiation.

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4.0 REFERENCES

1) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix A Criteria 64.

2) Donald T. Oakley, "Natural Radiation Exposure in the United States." U. S. Environmental Protection Agency, ORP/SID 72-1, June 1972.

3) National Council on Radiation Protection and Measurements, Report No. 93, "Ionizing Radiation Exposures of the Population of the United States," September 1987.

4) United States Nuclear Regulatory Commission, Regulatory Guide 8.29, "Instructions Concerning Risks from Occupational Radiation Exposure," Revision 0, July 1981.

5) Boston Edison Company, "Pilgrim Station" Public Information Brochure 100M, WNTHP, September 1989.

6) United States Nuclear Regulatory Commission, Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977.

7) Pilgrim Nuclear Power Station Offsite Dose Calculation Manual, Revision 15, June 2021.

8) United States of America, Code of Federal Regulations, Title 10, Part 20.1301.

9) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix I.

10) United States of America, Code of Federal Regulations, Title 40, Part 190.

11) United States Nuclear Regulatory Commission, Regulatory Guide 4.1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants," Revision 1, April 1975.

12) ICN/Tracerlab, "Pilgrim Nuclear Power Station Pre-operational Environmental Radiation Survey Program, Quarterly Reports," August 1968 to June 1972.

13) International Commission of Radiological Protection, Publication No. 43, "Principles of Monitoring for the Radiation Protection of the Population," May 1984.

14) United States Nuclear Regulatory Commission, NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," April 1991.

15) United States Nuclear Regulatory Commission, Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program," Revision 1, November 1979.

16) Settlement Agreement Between Massachusetts Wildlife Federation and Boston Edison Company Relating to Offsite Radiological Monitoring - June 9, 1977.

17) Annual 2021.

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APPENDIX A SPECIAL STUDIES There were no environmental samples collected during 2021 that contained plant-related radioactivity.

Therefore, no special studies were required to estimate dose from plant-related radioactivity.

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APPENDIX B LAND USE CENSUS RESULTS The annual land use census requirement for gardens and milk and meat animals, as well as the broadleaf vegetation collection in the vicinity of Pilgrim Station was discontinued in 2021 with Revision 15 of the ODCM. As stated earlier in this report the broadleaf vegetation collection was in lieu of milk sampling as a type of cattle feed to account for iodine deposition. At the plant is permanently in a shutdown and decommissioned status no new iodine is produced and that which was produced has decayed away.

No new milk or meat animals were identified during the last land use census. In addition, the Town of Plymouth Animal Inspector stated that their office is not aware of any animals at locations other than the Plimoth Plantation. Although milk sampling is not performed at Plimoth Plantation, effluent dose calculations are performed for this location assuming the presence of a milk ingestion pathway, as part of the Annual Radioactive Effluent Release Report (Reference 17).

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APPENDIX C ENVIRONMENTAL MONITORING PROGRAM DISCREPANCIES There were a number of instances during 2021 in which inadvertent issues were encountered in the collection of environmental samples. All of these issues were minor in nature and did not have an adverse effect on the results or integrity of the monitoring program. The PNPS TLD placement still far exceeds that prescribed by NUREG-1302. Details of these various problems are given below.

Within the air sampling program, there were a few instances in which continuous sampling was interrupted at the six airborne sampling locations during 2021. Most of these interruptions were due to short-term power losses due to weather related events . Such events did not have any significant impact on the scope and purpose of the sampling program, and lower limits of detection (LLDs) were met for both airborne particulates on 335 filters collected. In the fourth quarter of 2019, following the permanent shutdown of the station, the use of charcoal cartridges at air sample locations was discontinued as iodine had decayed away.

Out of 342 filters 335 samples were collected and analyzed during 2021. In accordance with ODCM Table 3.5-1, offsite REMP air particulate filters are to be collected at a weekly interval. Weekly is defined as once every seven days with a one-day grace period before and after the scheduled date. occasionally samples are collected with a longer than seven day interval due to access (especially in the winter) or someother issue. It must be emphasized that the station continued to sample during the duration and no monitoring time was lost.

The configuration of air samplers that had been in use at Pilgrim Station since the early 1980s, was replaced between June and August of 2012. Both the pumps and dry gas meters were replaced, and operating experience since changing over to the new configuration has been favorable. Although the occurrence of pump failures and gas meter problems have been largely eliminated, the new configuration is still subject to trips of the ground fault interrupt circuit (GFCI). Such problems can be encountered at air samplers located at the East Breakwater and Pedestrian Bridge. Both of these locations are immediately adjacent to the shoreline and are subject to significant wind-blown salt water, and are prone to tripping of the GFCI. In 2021 the air sample station at the Pedestrian Bridge was modified to increase the capabilities of collecting a representative sample after observations during an NRC inspection of the REMP program. The following table contains a listing of problems encountered with air sampling stations during 2021, many of which resulted in loss of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the sampling period. All problems were rectified by a ground fault reset or minor maintenance.

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Location Sampling Sampling Problem Description/Resolution Period Hours Lost EB 1/12-1/19/21 75 Ground Fault Circuit Interrupt (GFCI) tripped LLDs not Met due to low volume (IR-2600)

PL 2/16-3/2/21 No hours lost 2 week sample. No access to sample location (IR-2783 EB 3/16-3/23/21 162 Loss of power to sample station (cord was removed) (IR-2877)

CR 7/6-7/13/21 91 Ground Fault Circuit Interrupt (GFCI) tripped sample volume insufficient to meet LLDs PC No hours lost 2 week sample. No access to sample location PL 10/26-11/3/21 130 Due to storm, three stations lost power. (IR 3942)

PB 31.8 ER 149 Despite the lower-than-normal sampling volumes in the various instances involving power interruptions and equipment failures, required LLDs were met on 335 of the 342 particulate filters during 2021. When viewed collectively during the entire year of 2021, the following sampling recoveries were achieved in the airborne sampling program. Note the Manomet station has 46% recovery is due to the removal of sample location from the ODCM mid year and some are over 100% as the calculation is based off 52 weeks and 2021 included 53 weeks of samples.

Location Recovery Location Recovery ER 100.1% CR 100.8%

PL 100.3% MS 46.1%

PB 101.5% EW 101.8%

EB 99.8%

Group III fishes, consisting of alewife, smelt, or striped bass are normally collected once each year in the summer from the vicinity of the Discharge Canal Outfall. Since the shut down of Pilgrim station the warm water plume of the discharge, which drew in fish species like the Striped Bass, has dissipated and is no longer present. Fish species once in such abundance to bring in harbor seals and sharks behind them are no longer found in the plant area. Repeated and concerted efforts were made to collect these species, but failed to produce all required samples. Group I (autumn) and Group III (autumn) fish could not be collected.

In summary, the various problems encountered in collecting and analyzing environmental samples during 2021 were relatively minor when viewed in the context of the entire monitoring program. These discrepancies were promptly corrected when issue was identified, where possible. None of the discrepancies resulted in an adverse impact on the overall monitoring program.

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APPENDIX D Environmental Dosimetry Company Annual 2021 Quality Assurance Status Report 62

TABLE OF CONTENTS Page 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 III. 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 VIII. REFERENCES ............................................................................................................... 4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS LIST OF TABLES Page

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 5-10% 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:

Hi Hi 100 Hi where:

Hi = 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:

Hi Hi 1 100 n

Hi where:

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

Hi = 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:

Hi H 100 H

where:

Hi = the reported exposure for the ith dosimeter (i.e., the reported exposure) 1 H = the mean reported exposure; i.e., H Hi n

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.

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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%.

III. 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=6) 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.

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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.

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TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 2021(1), (2)

Number  % Passed Precision Dosimeter Type  % Passed Bias Criteria Tested Criteria Panasonic Environmental 72 100 100 (1)

This table summarizes results of tests conducted by EDC.

(2)

Environmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES (N=6)

JANUARY - DECEMBER 2021(1), (2)

Standard Tolerance Process Date Exposure Level Mean Bias %

Deviation % Limit +/-15%

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)

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

(2)

Environmental dosimeter results are free in air.

TABLE 3

SUMMARY

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

Mean Standard Issuance Period Client Deviation % Pass / Fail Bias %

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

Performance criteria are +/- 15%.

(2)

Blind spikeirradiations using Cs-137 5of 6

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

APPENDIX E Teledyne Brown Engineering Environmental Services Annual 2021 Quality Assurance Report 76

TELEDYNE BROWN ENGINEERING A Teledyne Technologies Company TELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES Knoxville Laboratory 4th Quarter 2021 QUALITY ASSURANCE REPORT January - December 2021 Teledyne Brown Engineering 2508 Quality Lane Knoxville, TN 37931-3133 Downloaded or Printed copies are UNCONTROLLED copies

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Downloaded or Printed copies are UNCONTROLLED copies TABLE OF CONTENTS I. INTRODUCTION ......................................................................................................... 1 A. Operational Quality Control Scope......................................................................... 1

1. Interlaboratory.................................................................................................. 1

2. Intralaboratory.................................................................................................. 1

3. Quality Assurance Program ............................................................................. 2 B. Performance Characteristics .................................................................................. 2

1. Interlaboratory Accuracy .................................................................................. 2

2. Intralaboratory Accuracy Acceptance Criteria ................................................. 5

3. Investigations and Nonconformance Reports .................................................. 6 II. ANALYTICAL SERVICES QUALITY CONTROL SYNOPSIS ..................................... 7 A. Interlaboratory Cross-Check Program ................................................................... 7 B. Intralaboratory Cross-Check Program ................................................................... 7

1. Blanks .............................................................................................................. 8

2. Spikes .............................................................................................................. 8

3. Duplicates ........................................................................................................ 8 C. Non-Conformance Reports (NCRs) ....................................................................... 8 D. Instrumentation ...................................................................................................... 8 ATTACHMENTS (where applicable)

A. Interlaboratory Quality Control Program Results Summary A.1 Analytics Environmental Radioactivity Cross Check Program A.2 DOE's Mixed Analyte Performance Evaluation Program (MAPEP)

A.3 ERA Environmental Radioactivity Cross Check Program A.4 Formal Interlaboratory Quality Control Program Results A.5 Client-Supplied Cross Check Program Results B. Intralaboratory Quality Control Program Results B.1 TBE-ES QC Program In-House Water Blanks, Spikes and Matrix Spikes B.2 TBE-ES QC Program In-House Duplicates C. Non-Conformance Reports (NCR's)

D. Audit Reports D.1 Internal Audits D.2 External Audits Downloaded or Printed copies are UNCONTROLLED copies

I. INTRODUCTION This report covers the Quality Assurance (QA) Program for the Analytical Services function of the Teledyne Brown Engineering Environmental Services (TBE-ES) laboratory for January through December 2021.

A. Operational Quality Control Scope The TBE-ES Laboratory Quality Control (QC) Program is designed to monitor the quality of analytical processing associated with environmental, effluent (USNRC Regulatory Guide 4.15), bioassay, industrial process, and waste characterization (10CFR Part 61) samples.

Quality Control of radioanalyses involves an internal process control program and participation in external independent third party programs administered by Analytics, Environmental Resource Associates (ERA) and the Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP). The MAPEP is designed to evaluate specific analytical capabilities that are of importance for DOE analytical services. These types of performance evaluation samples may contain both radiological and non-radiological mixed analytes and are reflective of real-world samples seen from DOE monitoring sites. Although TBE-ES is not currently under contract to analyze samples for DOE sites, the laboratory chooses to participate in PE program because it offers a variety of matrices and nuclides that are analyzed on a routine basis (water, soil, air filters, etc.).

1. Interlaboratory Results for third-party process checks prepared by Analytics, ERA and MAPEP are not reported during the first quarter of the year.

Inter-laboratory cross-check samples are received and reported as follows:

Analytics cross-check samples are analyzed by TBE two times per year, typically in April and September.

MAPEP provides samples semi-annually in March and September with required reporting dates in May and November, respectively, following sample receipt.

ERA cross-check samples are analyzed by TBE semi-annually in April and October with required reporting dates in May and November, respectively, following sample receipt.

2. Intralaboratory The internal QC program is designed to include QC functions such as instrumentation checks (to insure proper instrument response) and blank samples (to which no analyte radioactivity has been added) for contamination checks and instrumentation backgrounds. Process controls (or process checks) are actual samples analyzed in duplicate (duplicates) in order to evaluate the precision of laboratory measurements. Accuracy of analyses is measured by analyzing blank samples which have been spiked 1

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with a known quantity of a radioisotope (spikes) that are of interest to laboratory clients. Some client samples are also spiked with a known activity of target analyte (matrix spikes) and aid in evaluating analytical method performance.

QC samples are intended to evaluate the entire radiochemical and radiometric process. Process control and qualification analyses samples seek to mimic the media type of those samples submitted for analysis by laboratory clients. The magnitude of the process control program combines both internal and external sources targeted at 10% of the routine sample analysis load. A summary of blanks, spikes and duplicates is found in Attachments B.1 and B.2.

3. Quality Assurance Program To provide direction and consistency in administering the quality assurance program, TBE-ES has developed and follows a Quality Manual and a set of Standard Operating Procedures (SOP). The plan describes the scheduled frequency and scope of Quality Assurance and Quality Control (QA/QC) considered necessary for an adequate QA/QC program conducted throughout the year.

Internal audits are performed on an annual schedule, usually during the 4th quarter. External audits are performed by prospective and/or existing clients in accordance with contractual specifications. State audits are conducted to maintain client-specific certification requirements and for accreditation by the National Environmental Laboratory Accreditation Program (NELAP). The Nuclear Procurement Issues Corporation (NUPIC) evaluates suppliers of laboratory services to nuclear utilities. TBE-ES is audited every 33-36 months by NUPIC as a function of the utilities Radiological Environmental Monitoring Program (REMP).

One audit was performed during the second quarter of 2021 by the Utah Department of Health (NELAP). Results are included in Attachment D.2.

B. Performance Characteristics

1. Interlaboratory Accuracy TBE-ES has adopted a QC acceptance protocol based upon two external performance models. For the interlaboratory programs that have established performance criteria (e.g., established warning and failure limits), the laboratory uses those established criteria to evaluate QC sample results. For interlaboratory QC programs which report no pre-set acceptance (pass/fail) criteria (e.g. Analytics Cross Check Program), results are evaluated in accordance with TBE-ES internal acceptance criteria.

a) Analytics Evaluation Criteria Analytics evaluation report provides a ratio of TBEs result and the Analytics known value. Since flag values are not assigned, TBE-ES 2

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evaluates the reported ratios based on internal QC requirements, which are based on the DOE MAPEP criteria.

b) MAPEP Evaluation Criteria MAPEP evaluation criteria found in the Handbook for the Department of Energys Mixed Analyte Performance Evaluation Program (MAPEP),

MAPEP-HB-1 Rev. 2 (June 13, 2018), pp. 9-11 & 30-32 and online at https://www.id.energy.gov/resl/mapep/MAPEP-HB-1%20Rev%202.pdf contains the following information:

MAPEPs evaluation report provides a calculated relative bias for the labs reported results, the acceptance range, and associated flag values. The relative bias places the laboratory result in one of three categories:

Acceptable (flag = A) Bias <= 20%

Acceptable with Warning (flag = W) 20% < Bias <=30%

Not Acceptable (flag = N) Bias > 30%

Radiological results must be reported with an associated uncertainty at one standard deviation. The uncertainty associated with a result is not currently used as part of the acceptance criteria, but an uncertainty evaluation is used to flag potential areas of concern. MAPEP assigns A (Acceptable), W (Acceptable with Warning) and N (Not Acceptable) uncertainty flags based upon the relative precision (RP) ratio:

RP = (Reported Uncertainty / Reported Result) x 100 Uncertainty flags are currently for information only, but reported total uncertainties are used to evaluate performance in false positive/ negative tests and sensitivity evaluations.

The MAPEP program uses false-positive testing in each session to identify laboratory results that indicate the presence of a particular radionuclide when, in fact, the actual activity of the radionuclide is far below the detection limit of the measurement. Not Acceptable (N) performance, and hence a false positive result, is indicated when the range encompassing the result, plus or minus the total uncertainty at three standard deviations, does not include zero (i.e. 2.5 +/-

0.2; range of 1.9 -3.1). Statistically, the probability that a result can exceed the absolute value of its total uncertainty at three standard deviations by chance alone is less than 1%. MAPEP uses a three standard deviation criterion for the false positive test to ensure confidence about issuing a false-positive performance evaluation. A result that is greater than three times the total uncertainty of the measurement represents a statistically- positive detection with over 99% confidence.

Sensitivity evaluations are routinely performed to complement the false-positive tests. In a sensitivity evaluation, the radionuclide is present at or near the detection limit, and the difference between the reported result and the MAPEP reference value is compared to the propagated combined total uncertainties.

The results are evaluated at three standard deviations. If the observed difference is greater than three times the combined total uncertainty, the sensitivity evaluation in Not Acceptable. The probability that such a difference 3

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can occur by chance alone is less than 1%. If the participant did not report a statistically-positive result, a Not Detected is noted in the text field of the MAPEP performance report. A non-detect is potentially a false-negative result, dependent upon the laboratorys detection limit for the radionuclide.

False-negative tests are also performed in combination with the sensitivity evaluations. In this scenario, the sensitivity of the reported measurement indicates that the known specific activity of the targeted radionuclide in the performance evaluation sample should have been detected, but was not, and a Not Acceptable performance evaluation is issued. The uncertainty of the MAPEP reference value and of the reported result at three standard deviations is used for the false-negative test.

The false-positive/negative and sensitivity evaluation tests are conducted in a manner that assists the participants with their measurement uncertainty estimates and helps ensure they are not under estimating or over inflating their total uncertainties. If the total uncertainty is over-inflated in order to pass a false-positive test, it will result in a Not Detected if the test is actually a sensitivity evaluation. The opposite is true for a false-positive test. False-negatives and failed sensitivity evaluations can also result from under-estimating the total uncertainty. An accurate estimate of measurement uncertainty is required for consistent performance at the acceptable level.

c) ERA Evaluation Criteria The ERA evaluation report provides an acceptance range for control and warning limits with associated flag values. Acceptance limits for drinking/potable water are established per The NELAC Institutes (TNI) guidance. The TNI Standard uses Fields of Proficiency Testing (FoPT)

Tables to calculate upper and lower acceptance limits set at the Mean +/-

2 standard deviations (SD). ERAs acceptance limits for other matrices differ based on historical data from past studies.

d) NRC Verification Test Comparison Criteria Some laboratory clients submit double-blind 10 CFR Part 50 performance evaluation samples. The lab processes these samples as routine client samples and sends the reports to the client, who then reports the result(s) to the samples originator. This may be via an outside vendor (i.e. Analytics) or prepared by the client. After the results are received by the client, NRC Resolution Criteria is used to determine acceptance of results using a calculated resolution number (known value / 1-sigma uncertainty) and a calculated ratio (lab result of unknown/known value). Clients may or may not share the result with the laboratory and are therefore usually not included with this report.

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2. Intralaboratory Accuracy Acceptance Criteria a) Process Controls The measure of accuracy for a group of test measurements to a given spike level is found by calculating the recovery of the spike activity found versus the added spike activity. The percent recovery is calculated as follows:

% Recovery = (Am / As) 100 Where: Am = the activity measured As = the spiked activity Internal Process Control sample results use acceptance criteria of 70%-

130% for spike recovery. Warning limits are set from 70%-79% and 121%-130%. Results evaluated as Warning are assessed for trends of low or high bias and are used to detect potential problems. The laboratorys internal acceptance criteria are based on MAPEPs defined performance levels of bias greater than 30%.

Matrix spikes (MS) may be used to document the bias of a method in a sample matrix. MS acceptance criteria is 60% - 140% recovery.

b) Other Measures Backgrounds, which represent the ambient signal response recorded by measuring instruments, are independent of radioactivity contributed by the radionuclides being measured in the sample. If possible, equivalent media for preparing laboratory processing blanks will be used.

Acceptable method blank sample results have no three-sigma statistically-positive activity for the target parameters. If all sample results associated with the blank are greater than the MDC, then the blank MDC shall be less than the activity of the least active sample in the work order or it will be flagged with a qualifier in the client report with a case narrative.

Replicate/duplicate (DUP) and matrix spike duplicate (MSD) samples are produced by taking two aliquots from a single sample and assigning each aliquot a different Lab Sample Number. In cases of duplicate analyses where there are no known values, the analyses will be evaluated for precision only. All duplicates are carried through the complete sample preparation and analytical procedure. Precision is evaluated by calculating the Relative Percent Difference (RPD) between the two samples. Relative Percent Difference is calculated as the absolute difference between two values normalized to the average value, expressed as a percentage:

% RPD = (abs[orig - dup] / [orig + dup]/2) x 100 5

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Matrix spike duplicates are split samples spiked with identical concentrations of a target analyte and are used to evaluate precision and bias. The matrix spike duplicate recovery is expressed as a percentage:

% MSD = (abs[orig activity* - dup activity]/spike activity) x 100

• If the original activity is not detected then the activity is considered zero (0)

For purposes of analytical reporting, each result specifies the radionuclide concentration and the a posteriori Minimum Detectable Concentration (MDC). TBE-ES calculates the a posteriori MDC using the samples actual measurement parameters (i.e., sample volume, chemical recovery, instrument background, etc.) to demonstrate that the Nuclear Regulatory Commissions (NRC) a priori MDC has been met for each radionuclide/sample. By TBE-ES policy, the a posteriori MDC must be less than the required NRC a priori MDC.

3. Investigations and Nonconformance Reports QC investigations are initiated when QC results fall outside of the QC criteria. Other investigations may arise from unanticipated situations which are not clearly defined in the procedures or bounded by pre-established performance criteria but have the potential of becoming QA-related issues.

The QA investigation is the mechanism to quickly ascertain if there is due cause to issue a formal Non-Conformance Report (NCR).

An NCR is issued to formally document a QC investigation into the root cause of failure, the corrective action taken, and the action taken to prevent recurrence where applicable. Investigations may include review of procedures, interviews of personnel, review of laboratory and instrument logbooks, observation of analyst techniques and any other items identified as necessary to resolve the issue. For intercomparison performance evaluation samples, it is TBEs policy to issue an NCR for all unacceptable results.

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II. ANALYTICAL SERVICES QUALITY CONTROL SYNOPSIS A. Interlaboratory Cross-Check Program During this reporting period, 27 nuclides associated with six media types (Air Filter, Charcoal [Air Iodine], Milk, Soil, Vegetation and Water) were analyzed.

Samples were obtained from Analytics, the Department of Energys (DOE) Mixed Analyte Performance Evaluation Program (MAPEP) and Environmental Resource Associates (ERA). Media types representative of client analyses performed during this reporting period were selected. The results are presented in Attachment A.

1. Analytics Environmental Cross Check Program Twelve nuclides were evaluated in air particulate, charcoal filter, milk and soil matrices during this reporting period. All analyses were within acceptable criteria.

2. DOEs MAPEP Quality Assessment Program Fourteen nuclides in water, air particulate (AP), soil, urine and vegetation samples were evaluated in January - December 2021. All of the environmental analyses performed were evaluated as within the acceptable/acceptable with warning criteria except for one AP Gross Alpha and two soil Ni-63. TBE also analyzed water and soil for Tc-99 for informational purposes (not on required list for REMP) and one soil sample was evaluated as unacceptable.

NCR 21-02, NCR 21-03 and NCR 21-13 were initiated to address the failures and Corrective Actions issued. All raw and associated QC data were reviewed and found to be within acceptable limits. (See Attachment C for NCR detail).

3. ERA Environmental Cross Check Program (RAD/MRAD)

Eighteen nuclides were evaluated in water, soil, and air particulate samples during January - December 2021. All analyses performed were within acceptable criteria except for one water Fe-55, one Gross Beta and one H-3.

NCR 21-01, NCR 21-10, NCR 21-11 and NCR 21-14 were initiated to address failures and Corrective Action was issued. All raw and associated QC data were reviewed and found to be within acceptable limits. (See Attachment C for NCR detail).

B. Intralaboratory Cross-Check Program During this reporting period, 21 nuclides (and numerous gamma nuclides) in various matrices, including air particulate, charcoal, vegetation, fish, milk, soil/sediment and water were analyzed by means of the laboratorys internal process control program. A compilation of intralaboratory comparison data for this reporting period is summarized in Attachment B. (Note: Only gamma nuclides that are typically seen in samples are included in the attachment - a complete list is available upon request).

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The TBE-ES laboratory's internal process control program evaluated 7,805 analyses during this period.

1. Blanks During this reporting period, all 1474/1475 blanks analyzed were less than the MDC. One workgroup blank for Ni-63 was above the MDC. The workrgoup included a blank, spike and two client samples whose activity was greater than 5x the blank. The blank activity was reported with a case narrative.

2. Spikes During this reporting period, 1435/1436 workgroup and matrix spikes analyzed were within the acceptance criteria. Samples in the single WG with a failing spike recovery were not reported but were completely re-prepped.

The new workgroup QC was within acceptable range.

3. Duplicates All of the 4894 duplicate sets analyzed were within acceptance criteria.

C. Non-Conformance Reports (NCRs)

A total of fourteen NCRs were initiated for this monitoring period and corrective action assigned.

D. Instrumentation TBE-ES uses the statistical principle method of evaluation for instrument quality control check data based on the mean, 2-sigma and 3-sigma set point model or uses pre-set tolerance limits. Each detector is checked prior to use for that day and the resulting data points are automatically compared to statistical baselines to determine the instrument's acceptability for counting. Control charts showing this data are available during audits or upon request. TBE-ES instrumentation includes:

1. Gamma Spectroscopy Gamma detectors are routinely monitored for energy, full width at half maximum, efficiency, and background. TBE-ES gamma detectors operated without incident during this reporting period. Occasional second runs (as allowed by our QA program) were necessary to verify acceptable operation.

Some amplifier fine gain adjustments and liquid nitrogen addition to the dewars were also necessary when data trends indicate an energy drift on the detector.

2. Liquid Scintillation Counters (LSC):

LSC instruments, used in tritium, carbon-14, nickel-63 and other low-energy beta-emitters, are monitored for background and efficiency. The reliability of 8

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these instruments is exceptional with zero instances of background or efficiency values outside of control limits.

3. Alpha/Beta Gas Flow Proportional (GFP) Counters:

GFP detectors used for gross alpha/beta, strontium-89/90, iodine-131 (low level) and other nuclides are monitored for background and efficiency.

These detectors operated without incident during this reporting period.

Occasionally, second runs (primarily for alpha due to the sensitivity of source placement) were necessary to verify acceptable operation or because of low P-10 pressure. After gas change-out and purging, control check values return to control norms.

4. Alpha Spectroscopy:

Alpha detectors are routinely monitored for energy, full width at half maximum, efficiency, and background. TBE-ES alpha detectors operated without incident during this reporting period. Occasional second runs (as allowed by our QA program) were necessary to verify acceptable operation.

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ATTACHMENT A Interlaboratory Quality Control Program Results Downloaded or Printed copies are UNCONTROLLED copies

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A.1 Analytics Cross Check Program Results Downloaded or Printed copies are UNCONTROLLED copies

A.1 Analytics Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services TBE Identification Known Ratio of TBE to (b)

Month/Year Matrix Nuclide Units Reported Evaluation Number Value (a) Analytics Result Value March 2021 E13466 Milk Sr-89 pCi/L 84.6 87.1 0.97 A Sr-90 pCi/L 11.5 12.6 0.91 A E13467 Milk Ce-141 pCi/L 111 125 0.89 A Co-58 pCi/L 123 128 0.96 A Co-60 pCi/L 140 154 0.91 A Cr-51 pCi/L 252 242 1.04 A Cs-134 pCi/L 130 151 0.86 A Cs-137 pCi/L 110 110 1.00 A Fe-59 pCi/L 105 109 0.96 A I-131 pCi/L 77.6 86.9 0.89 A Mn-54 pCi/L 111 112 0.99 A Zn-65 pCi/L 200 211 0.95 A E13468 Charcoal I-131 pCi 83.5 88.5 0.94 A E13469 AP Ce-141 pCi 103.0 103 1.00 A Co-58 pCi 93.3 105 0.89 A Co-60 pCi 136 126 1.08 A Cr-51 pCi 213 198 1.07 A Cs-134 pCi 123.0 124 0.99 A Cs-137 pCi 86.3 90.1 0.96 A Fe-59 pCi 81.3 89.6 0.91 A Mn-54 pCi 93.5 92.0 1.02 A Zn-65 pCi 166 173 0.96 A E13470 Soil Ce-141 pCi/g 0.232 0.262 0.89 A Co-58 pCi/g 0.251 0.268 0.94 A Co-60 pCi/g 0.306 0.322 0.95 A Cr-51 pCi/g 0.517 0.506 1.02 A Cs-134 pCi/g 0.263 0.317 0.83 A Cs-137 pCi/g 0.278 0.301 0.92 A Fe-59 pCi/g 0.228 0.229 1.00 A Mn-54 pCi/g 0.221 0.235 0.94 A Zn-65 pCi/g 0.448 0.441 1.02 A E13471 AP Sr-89 pCi 92.2 95.5 0.97 A Sr-90 pCi 11.7 13.9 0.84 A (a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (Page 1 of 2)

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A.1 Analytics Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services TBE Identification Known Ratio of TBE to (b)

Month/Year Matrix Nuclide Units Reported Evaluation Number Value (a) Analytics Result Value September 2021 E13472 Milk Sr-89 pCi/L 66.4 85.4 0.78 W Sr-90 pCi/L 11.9 14.0 0.85 A E13473 Milk Ce-141 pCi/L 118 114 1.03 A Co-58 pCi/L 116 118 0.98 A Co-60 pCi/L 142 145 0.98 A Cr-51 pCi/L 244 236 1.03 A Cs-134 pCi/L 81 93.1 0.87 A Cs-137 pCi/L 105 112 0.94 A Fe-59 pCi/L 105 102 1.03 A I-131 pCi/L 65.1 85.6 0.76 W Mn-54 pCi/L 128 128 1.00 A Zn-65 pCi/L 158 153 1.03 A E13474 Charcoal I-131 pCi 85.2 90.9 0.94 A E13475 AP Ce-141 pCi 126 135 0.94 A Co-58 pCi 148 139 1.07 A Co-60 pCi 183 171 1.07 A Cr-51 pCi 322 278 1.16 A Cs-134 pCi 118 110 1.08 A Cs-137 pCi 147 132 1.12 A Fe-59 pCi 131 120 1.09 A Mn-54 pCi 161 151 1.06 A Zn-65 pCi 202 180 1.12 A E13476 Soil Ce-141 pCi/g 0.215 0.219 0.98 A Co-58 pCi/g 0.208 0.226 0.92 A Co-60 pCi/g 0.277 0.277 1.00 A Cr-51 pCi/g 0.388 0.452 0.86 A Cs-134 pCi/g 0.157 0.178 0.88 A Cs-137 pCi/g 0.270 0.284 0.95 A Fe-59 pCi/g 0.218 0.195 1.12 A Mn-54 pCi/g 0.239 0.246 0.97 A Zn-65 pCi/g 0.312 0.293 1.06 A E13477 AP Sr-89 pCi 85.6 68.3 1.25 W Sr-90 pCi 12.6 11.2 1.13 A (a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (Page 2 of 2)

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A.2 MAPEP Quality Assessment Program Results Downloaded or Printed copies are UNCONTROLLED copies

A.2 DOE's Mixed Analyte Performance Evaluation Program (MAPEP)

Teledyne Brown Engineering Environmental Services TBE Identification Known Acceptance Month/Year Matrix Nuclide Units Reported Evaluation (b)

Number Value (a) Range Value February 2021 21-GrF44 AP Gross Alpha Bq/sample 0.371 1.77 0.53 - 3.01 N(3)

Gross Beta Bq/sample 0.731 0.65 0.325 - 0.974 A 21-MaS44 Soil Ni-63 Bq/kg 310 689.0 482 - 896 N(4)

Tc-99 Bq/kg 457 638 447 - 829 W 21-MaSU44 Urine Cs-134 Bq/L 2.34 2.73 1.91 - 3.55 A Cs-137 Bq/L 2.54 2.71 1.90 - 3.52 A Co-57 Bq/L 0.4100 (1) A Co-60 Bq/L 2.24 2.44 1.71 - 3.17 A Mn-54 Bq/L 2.03 2.03 1.42 - 2.64 A K-40 Bq/L 52.8 54.0 38 - 70 A U-234 Bq/L 0.108 0.0877 0.0614 - 0.114 W U-238 Bq/L 0.101 0.091 0.064 - 0.118 A Zn-65 Bq/L 1.06 1.34 (2) A 21-MaW44 Water Ni-63 Bq/L 6.7 8.2 5.7 - 10.7 A Tc-99 Bq/L 3.850 4.01 2.81 - 5.21 A 21-RdV44 Vegetation Cs-134 Bq/sample 3.13 3.60 2.5 - 4.7 A Cs-137 Bq/sample 4.64 4.69 3.28 - 6.10 A Co-57 Bq/sample 5.25 5.05 3.54 - 6.57 A Co-60 Bq/sample 2.86 2.99 2.09 - 3.89 A Mn-54 Bq/sample 5.02 5.25 3.68 - 6.83 A Sr-90 Bq/sample 0.631 0.673 0.471 - 0.875 A Zn-65 Bq/sample -0.233 (1) A August 2021 21-GrF45 AP Gross Alpha Bq/sample 0.368 0.960 0.288 - 1.632 A Gross Beta Bq/sample 0.595 0.553 0.277 - 0.830 A 21-MaS45 Soil Ni-63 Bq/kg 546 1280 896 - 1664 N(5)

Tc-99 Bq/kg 453 777 544 - 1010 N(6) 21-MaSU45 Urine Cs-134 Bq/L 3.10 3.62 2.53 - 4.71 A Cs-137 Bq/L 0.083 (1) A Co-57 Bq/L 0.844 0.87 0.606 - 1.125 A Co-60 Bq/L 0.0535 (1) A Mn-54 Bq/L 0.459 0.417 (2) A K-40 Bq/L 48.8 54.0 38 - 70 A U-234 Bq/L 0.133 0.116 0.081 - 0.151 A U-238 Bq/L 0.137 0.121 0.085 - 0.157 A Zn-65 Bq/L 0.339 0.420 (2) A 21-MaW45 Water Ni-63 Bq/L 33.5 39.5 27.7 - 51.4 A Tc-99 Bq/L 3.5 3.7 2.60 - 4.82 A 21-RdV45 Vegetation Cs-134 Bq/sample 3.42 4.34 3.04 - 5.64 W Cs-137 Bq/sample 2.14 2.21 1.55 - 2.87 A Co-57 Bq/sample 4.08 4.66 3.26 - 6.06 A Co-60 Bq/sample 2.81 3.51 2.46 - 4.56 A Mn-54 Bq/sample 0.035 (1) A Sr-90 Bq/sample 1.15 1.320 0.92 - 1.72 A Zn-65 Bq/sample 2.05 2.43 1.70 - 3.16 A (a) The MAPEP known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) DOE/MAPEP evaluation:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (1) False positive test (2) Sensitivity evaluation (3) See NCR 21-02 (4) See NCR 21-03 (5) See NCR 21-13 (6) Tc-99 cross-checks done for TBE information only - not Downloaded or required Printed copies are UNCONTROLLED copies (Page 1 of 1)

A.3 ERA Cross Check Program Results Downloaded or Printed copies are UNCONTROLLED copies

A.3 ERA Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services TBE Identification Known Acceptance (b)

Month/Year Matrix Nuclide Units Reported Evaluation Number Value (a) Limits Value March 2021 MRAD-34 Water Am-241 pCi/L 175 157 108 - 201 A Fe-55 pCi/L 579 275 162 - 400 N(1)

Pu-238 pCi/L 181 171 103 - 222 A Pu-239 pCi/L 153 142 87.9 - 175 A Soil Sr-90 pCi/kg 6570 9190 2860 - 14,300 A AP Fe-55 pCi/filter 107 121 44.2 - 193 A U-234 pCi/filter 25.99 25.5 18.9 - 29.9 A U-238 pCi/filter 24.7 25.3 19.1 - 30.2 A April 2021 RAD-125 Water Ba-133 pCi/L 92.3 90.5 76.2 - 99.6 A Cs-134 pCi/L 62.9 70.5 57.5 - 77.6 A Cs-137 pCi/L 161 168 151 - 187 A Co-60 pCi/L 22.5 20.9 17.7 - 25.8 A Zn-65 pCi/L 183 177.0 159 - 208 A GR-A pCi/L 30.8 30.2 15.4 - 39.4 A GR-B pCi/L 60.1 67.5 46.8 - 74.2 A U-Nat pCi/L 36.45 36.9 30.0 - 40.8 A H-3 pCi/L 13,400 14,600 12,800 - 16,100 A Sr-89 pCi/L 64.5 63.5 51.4 - 71.5 A Sr-90 pCi/L 22.8 23.0 16.5 - 27.0 A I-131 pCi/L 28.2 26.7 22.2 - 31.4 A September 2021 MRAD-35 Water Am-241 pCi/L 68 63.7 43.7 - 81.5 A Fe-55 pCi/L 179 246 145 - 358 A Pu-238 pCi/L 102 114 68.5 - 148 A Pu-239 pCi/L 32 34.3 21.2 - 42.3 A Soil Sr-90 pCi/kg 6160 6090 1,900 - 9,490 A AP Fe-55 pCi/filter 493 548 200 - 874 A Pu-238 pCi/filter 28 28.5 21.5 - 35.0 A Pu-239 pCi/filter 21 21.6 16.1 - 26.1 A U-234 pCi/filter 7.95 7.76 5.75 - 9.09 A U-238 pCi/filter 8.0 7.69 5.81 - 9.17 A October 2021 RAD-127 Water Ba-133 pCi/L 82.8 87.5 73.6 - 96.2 A Cs-134 pCi/L 64.0 70.1 57.1 - 77.1 A Cs-137 pCi/L 145 156 140 - 174 A Co-60 pCi/L 83.2 85.9 77.3 - 96.8 A Zn-65 pCi/L 133 145 130 - 171 A GR-A pCi/L 76.0 66.7 35.0 - 82.5 A GR-B pCi/L 63.0 55.7 38.1 - 62.6 N(2)

U-Nat pCi/L 52.88 55.5 45.3 - 61.1 A H-3 pCi/L 13,800 17,200 15,000 - 18,900 N(3)

Sr-89 pCi/L 54.9 61.0 49.1 - 68.9 A Sr-90 pCi/L 24.8 29.3 21.3 - 34.0 A I-131 pCi/L 27.4 26.4 21.9 - 31.1 A December 2021 QR 120121Y Water GR-B pCi/L 47.6 39.8 26.4 - 47.3 N(4)

H-3 pCi/L 17,500 17,800 15,600 - 19,600 A (a) The ERA known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation.

(b) ERA evaluation:

A = Acceptable - Reported value falls within the Acceptance Limits N = Not Acceptable - Reported value falls outside of the Acceptance Limits (1) See NCR 21-01 (2) See NCR 21-10 (3) See NCR 21-11 (4) See NCR 21-14 Downloaded or Printed copies are UNCONTROLLED copies (Page 1 of 1)

A.4 Formal Interlaboratory Quality Control Program Results Downloaded or Printed copies are UNCONTROLLED copies

Eckert & Ziegler ACC REDITE D Analytics 1380 Seaboard Industrial Blvd.

Atlanta, Georgia 30318 U.S.A.

Tel 404-352-8677 Fax 404-352-2837 RESULTS OF ENVIRONMENTAL CROSS CHECK PROGRAM TELEDYNE BROWN ENGINEERING 1st QUARTER 2021 (Ref. Date 11 Mar 2021, Rev. 0)

Downloaded or Printed copies are UNCONTROLLED copies 17 May 2021 Levan Tkavadze , Nuclear Metrologist 1st QUARTER 2021 (Ref. Date 11 Mar 2021, Rev. 0)

E13467 Milk Ce-141 1.11E+02 1.25E+02 0.89 Co-58 1.23E+02 1.28E+02 0.96 Co-60 1.40E+02 1.54E+02 0.91 Cr-51 2.52E+02 2.42E+02 1.04 Cs-134 1.30E+02 1.51E+02 0.86 Cs-137 1.10E+02 1.10E+02 1.00 Fe-59 1.05E+02 1.09E+02 0.96 1-131 7.76E+01 8.69E+01 0.89 K-40 1.34E+03 Not Measured Mn-54 1.11E+02 1.12E+02 0.99 Zn-65 2.00E+02 2.11E+02 0.95 Downloaded or Printed copies are UNCONTROLLED copies E13471 Filter Sr-89 9.22E+01 9.55E+01 0.97 Sr-90 1.17E+01 1.39E+01 0.84

E13469 Filter Ce-141 1.03E+02 1.03E+02 1.00 Co-58 9.33E+01 1.05E+02 0.89 Co-60 1.36E+02 1.26E+02 1.08 Cr-51 2.13E+02 1.98E+02 1.07 Cs-134 1.23E+02 1.24E+02 0.99 Cs-137 8.63E+01 9.01E+01 0.96 Fe-59 8.13E+01 8.96E+01 0.91 Mn-54 9.35E+01 9.20E+01 1.02 Zn-65 1.66E+02 1.73E+02 0.96 E13470 Soil Ce-141 2.32E-01 2.62E-01 0.89 Co-58 2.51E-01 2.68E-01 0.94 Co-60 3.06E-01 3.22E-01 0.95 Cr-51 5.17E-01 5.06E-01 1.02 Downloaded or Printed copies are UNCONTROLLED copies Cs-134 2.63E-01 3.17E-01 0.83 Cs-137 2.78E-01 3.01E-01 0.92 Fe-59 2.28E-01 2.29E-01 1.00 K-40 9.86E-01 Not Measured Mn-54 2.21E-01 2.35E-01 0.94 Zn-65 4.48E-01 4.41E-01 1.02 1st QUARTER 2021 (Ref. Date 11 Mar 2021, Rev. 0)

Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies

~(TELE01) Teledyne Brown Engineering - Environmental Services~

Department of Energy RESL - 1955 Fremont Ave, MS4149 - Idaho Falls, ID 83415 Laboratory Results For MAPEP Series 44 (TELE01) Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-6819 MAPEP-21-GrF44: Gross alpha/beta air filter Radiological Units: (Bq/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Gross alpha .371 1.77 N -79.0 0.53 - 3.01 .0468 A Gross beta .731 0.649 A 12.6 0.325 - 0.974 .0536 A Radiological Reference Date: February 1, 2021 MAPEP-21-MaS44: Radiological and inorganic combined soil standard Inorganic Units: (mg/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 78 55 - 101 Arsenic NR 45.8 32.1 - 59.5 Barium NR 223 156 - 290 Beryllium NR 60.6 42.4 - 78.8 Cadmium NR 7.05 4.94 - 9.17 Chromium NR 49.9 34.9 - 64.9 Cobalt NR 194 136 - 252 Copper NR 34.0 23.8 - 44.2 Lead NR 28.8 20.2 - 37.4 Nickel NR 148 104 - 192 Selenium NR 16.9 11.8 - 22.0 Silver NR 42.5 29.8 - 55.3 Technetium-99 NR 0.00101 0.00071 - 0.00131 Thallium NR 11.0 7.7 - 14.3 Uranium-235 NR 0.0469 0.0328 - 0.0610 Uranium-238 NR 16.7 11.7 - 21.7 Uranium-Total NR 16.7 11.7 - 21.7 Vanadium NR 279 195 - 363 Zinc NR 370 259 - 481 Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 88 62 - 114 Cesium-134 NR False Positive Test Cesium-137 NR 1550 1085 - 2015 Cobalt-57 NR 920 644 - 1196 Issued 6/14/2021 Printed 6/14/2021 Downloaded or Printed copies are UNCONTROLLED copies

Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Cobalt-60 NR 1370 959 - 1781 Iron-55 NR 910 637 - 1183 Manganese-54 NR False Positive Test Nickel-63 310 689 N -55.0 482 - 896 32.1 A Plutonium-238 NR 49.1 34.4 - 63.8 Plutonium-239/240 NR False Positive Test Potassium-40 NR 618 433 - 803 Strontium-90 NR 272 190 - 354 Technetium-99 457 638 W -28.4 447 - 829 43.2 A Uranium-234 NR 59 41 - 77 Uranium-238 NR 208 146 - 270 Zinc-65 NR 604 423 - 785 Radiological Reference Date: February 1, 2021 MAPEP-21-MaSU44: Radiological urine standard Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.0748 0.0524 - 0.0972 Cesium-134 2.34 2.73 A -14.3 1.91 - 3.55 .123 A Cesium-137 2.54 2.71 A -6.3 1.90 - 3.52 .171 A Cobalt-57 .041 A False Positive Test .0472 Cobalt-60 2.24 2.44 A -8.2 1.71 - 3.17 .124 A Curium-244 NR False Positive Test Hydrogen-3 NR False Positive Test Iron-55 NR False Positive Test Manganese-54 2.03 2.03 A 0.0 1.42 - 2.64 .177 A Nickel-63 NR False Positive Test Plutonium-238 NR 0.0468 0.0328 - 0.0608 Plutonium-239/240 NR 0.0772 0.0540 - 0.1004 Potassium-40 52.8 54 A -2.2 38 - 70 2.37 A Radium-226 NR False Positive Test Strontium-90 NR 0.48 0.34 - 0.62 Technetium-99 NR False Positive Test Uranium-234 .108 0.0877 W 23.1 0.0614 - 0.1140 .0319 W Uranium-238 .101 0.091 A 11.0 0.064 - 0.118 .0304 N Zinc-65 1.06 1.34 A Sensitivity Evaluation .309 Radiological Reference Date: February 1, 2021 MAPEP-21-MaW44: Radiological and inorganic combined water standard Inorganic Units: (mg/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 8.63 6.04 - 11.22 Arsenic NR 2.06 1.44 - 2.68 Barium NR 7.58 5.31 - 9.85 Issued 6/14/2021 Printed 6/14/2021 Downloaded or Printed copies are UNCONTROLLED copies

Inorganic Units: (mg/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Beryllium NR 3.15 2.21 - 4.10 Cadmium NR 0.748 0.524 - 0.972 Chromium NR 4.01 2.81 - 5.21 Cobalt NR 10.3 7.2 - 13.4 Copper NR 5.53 3.87 - 7.19 Lead NR 2.52 1.76 - 3.28 Mercury NR 0.106 0.074 - 0.138 Nickel NR 5.05 3.54 - 6.57 Selenium NR 0.676 0.473 - 0.879 Technetium-99 NR 6.35E-6 4.45E 8.26E-6 Thallium NR 2.46 1.72 - 3.20 Uranium-235 NR 0.000499 3.49E 6.49E-4 Uranium-238 NR 0.069 0.048 - 0.090 Uranium-Total NR 0.070 0.049 - 0.091 Vanadium NR 17.4 12.2 - 22.6 Zinc NR 15.5 10.9 - 20.2 Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR False Positive Test Cesium-134 NR 11.5 8.1 - 15.0 Cesium-137 NR 7.9 5.5 - 10.3 Cobalt-57 NR 11.4 8.0 - 14.8 Cobalt-60 NR False Positive Test Hydrogen-3 NR False Positive Test Iron-55 NR 26.9 18.8 - 35.0 Manganese-54 NR 15.5 10.9 - 20.2 Nickel-63 6.7 8.2 A -18.3 5.7 - 10.7 .765 A Plutonium-238 NR 0.577 0.404 - 0.750 Plutonium-239/240 NR 0.649 0.454 - 0.844 Potassium-40 NR False Positive Test Radium-226 NR 0.632 0.442 - 0.822 Strontium-90 NR 4.47 3.13 - 5.81 Technetium-99 3.85 4.01 A -4.0 2.81 - 5.21 1.32 N Uranium-234 NR 0.85 0.60 - 1.11 Uranium-238 NR 0.86 0.60 - 1.12 Zinc-65 NR 10.5 7.4 - 13.7 Radiological Reference Date: February 1, 2021 MAPEP-21-RdV44: Radiological vegetation Inorganic Units: (ug/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Uranium-235 NR 0.0825 0.0578 - 0.1073 Uranium-238 NR 11.5 8.1 - 15.0 Issued 6/14/2021 Printed 6/14/2021 Downloaded or Printed copies are UNCONTROLLED copies

Inorganic Units: (ug/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Uranium-Total NR 11.6 8.1 - 15.1 Radiological Units: (Bq/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.0586 0.0410 - 0.0762 Cesium-134 3.13 3.6 A -13.1 2.5 - 4.7 .166 A Cesium-137 4.64 4.69 A -1.1 3.28 - 6.10 .245 A Cobalt-57 5.25 5.05 A 4.0 3.54 - 6.57 .171 A Cobalt-60 2.86 2.99 A -4.3 2.09 - 3.89 .178 A Manganese-54 5.02 5.25 A -4.4 3.68 - 6.83 .275 A Plutonium-238 NR 0.0446 0.0312 - 0.0580 Plutonium-239/240 NR 0.0921 0.0645 - 0.1197 Strontium-90 .631 0.673 A -6.2 0.471 - 0.875 .0232 A Uranium-234 NR 0.138 0.097 - 0.179 Uranium-238 NR 0.143 0.100 - 0.186 Zinc-65 -.233 A False Positive Test .229 Radiological Reference Date: February 1, 2021 Issued 6/14/2021 Printed 6/14/2021 Downloaded or Printed copies are UNCONTROLLED copies

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A.5 Client Cross Check Samples Downloaded or Printed copies are UNCONTROLLED copies

Downloaded or Printed copies are UNCONTROLLED copies 9.64E-04 9.47E-04 1.02 lcoNFIDENTIALI 2.15E-03 2.00E-03 1.08 FIDENTIAL lcoNFIDENTIALI A37534 Simulated Gas Ce-141 3.00E-02 3.02E-02 0.99 Co-58 2.29E-02 2.38E-02 0.96 Co-60 2.35E-02 2.38E-02 0.99 2 Cr-51 9.60E-02 9.63E-02 1.00 20 Cs-134 2.13E-02 2.38E-02 0.90 20 Cs-137 2.01E-02 2.06E-02 0.98 20 Fe-59 2.83E-02 2.74E-02 1.03 20 Mn-54 2.80E-02 2.86E-02 0.98 20 Zn-65 3.37E-02 3.48E-02 0.97 20 5.94E-05 Downloaded or Printed copies are UNCONTROLLED copies 2nd QUARTER 2021 (Ref. Date 14 May 2021, Rev. 3) 2 of 3

Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Eckert & Ziegler ACC REDITED PROFICIENCY TESTING Analytics PROVIDER 1380 Seaboard Industrial Blvd.

Atlanta, Georgia 30318 U.S.A.

Tel 404-352-8677 Fax 404-352-2837 RESULTS OF RADIOCHEMISTRY CROSS CHECK PROGRAM CONFIDENTIAL CLIENT 3rd QUARTER 2021 (Ref. Date 13 Aug 2021, Rev. 2)

Downloaded or Printed copies are UNCONTROLLED copies L. 02 Nov 2021 Levan Tkavadze , Nuclear Metrologist 3rd QUARTER 2021 (Ref. Date 13 Aug 2021, Rev. 2)

XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXX Downloaded or Printed copies are UNCONTROLLED copies 3rd QUARTER 2021 (Ref. Date 13 Aug 2021, Rev. 2)

Downloaded or Printed copies are UNCONTROLLED copies A38181 Solid Ce-141 2.69E-02 2.70E-02 1.00 20 AGREEMENT Co-58 1.72E-02 1.72E-02 1.00 20 AGREEMENT Co-60 2.58E-02 2.60E-02 0.99 20 AGREEMENT Cr-51 6.77E-02 6.64E-02 1.02 20 AGREEMENT Cs-134 1.82E-02 1.97E-02 0.92 20 AGREEMENT Cs-137 1.36E-02 1.35E-02 1.00 20 AGREEMENT Fe-59 2.05E-02 1.98E-02 1.04 20 AGREEMENT Mn-54 1.93E-02 1.86E-02 1.04 20 AGREEMENT Zn-65 3.32E-02 3.21E-02 1.04 20 AGREEMENT A38182 Simulated Gas Ce-141 2.17E-02 2.25E-02 0.96 20 AGREEMENT Co-58 1.33E-02 1.43E-02 0.93 20 AGREEMENT Co-60 2.11E-02 2.17E-02 0.97 20 AGREEMENT Cr-51 5.40E-02 5.54E-02 0.97 20 AGREEMENT Downloaded or Printed copies are UNCONTROLLED copies Cs-134 1.50E-02 1.64E-02 0.91 20 AGREEMENT Cs-137 1.0SE-02 1.13E-02 0.96 20 AGREEMENT Fe-59 1.66E-02 1.65E-02 1.01 20 AGREEMENT Mn-54 1.48E-02 1.55E-02 0.96 20 AGREEMENT Zn-65 2.50E-02 2.68E-02 0.93 20 AGREEMENT 4th QUARTER 2021 (Ref. Date 05 Nov 2021, Rev. 0) 3 of 3

Intentionally Left Blank Downloaded or Printed copies are UNCONTROLLED copies

ATTACHMENT B Intralaboratory Quality Control Program Results Downloaded or Printed copies are UNCONTROLLED copies

ATTACHMENT B.1 TBE - ES QC Program In-House Water Blanks and Spikes Spike  % of Samples

1. of Samples Nuclide Blank Results Recovery % Within 20% of Analyzed (Range*) Known Value Am-241 38 All < MDC 73.8 - 108 97 C-14 64 All < MDC 71.4 - 128 76.6 Ce-144 (RAD) 21 All < MDC NA Cs-137 (RAD) 16 All < MDC 87.3 - 109 56 Fe-55 107 All < MDC 70.4 - 125 79.4 Gross Alpha 136 All < MDC 70.1 - 106 75.0 Gross Beta 105 All < MDC 72.4 - 125 83.8 H-3 343 All < MDC 71.3 - 127 94.5 I-129/131 109 All < MDC 70.4 - 128 86.2 Ni-63(1) 120 All < MDC (2) 70.4 - 115 88.3 P-32 13 All < MDC NA Pb-210 3 All < MDC 89.7 - 121 67 Pu-239/240 39 All < MDC 75.5 - 108 95 S-35 (RAD) 8 All < MDC NA Sr-89 125 All < MDC 72.0 - 125 94 Sr-90 139 All < MDC 71.6 - 130 86.3 Tc-99 28 All < MDC 771.4 - 95.1 60.7 Th-230 13 All < MDC 84.5 - 99.3 100 U-238 48 All < MDC 86.3 - 112 100 (1)

One spike failure: Not reported/not included with data/workgroup completely re-prepped (2)

One blank failure: Sample result > 5x blank activity (reported with case narrative)

• Internal Process Control results use TBE-ES acceptance criteria of 70 -130% recovery Matrix Spikes Nuclide Count Date Sample Result Spiked Result Spike Value  %

Fe-55 02/02/21 < 120 501 488 103 Fe-55 05/03/21 < 47.9 417 424 98.3 Fe-55 08/04/21 < 75.9 1170 1610 72.7 Fe-55 11/03/21 <131 1611 1500 107 Gr-A CP 01/26/21 2.29 43.6 52.3 79.0 Gr-A CP 04/27/21 1.96 46.2 52.3 84.6 Gr-A CP 07/27/21 2.73 45.0 52.3 80.8 Gr-A CP 10/22/21 2.39 46.8 52.2 85.0 Gr-B 01/27/21 17.8 89.2 95.1 75.1 Gr-B 04/21/21 5.5 47.8 56.6 74.7 Gr-B 07/27/21 12.2 53.3 56.2 73.1 Gr-B 10/20/21 9.7 46.5 55.9 65.9 H-3 (Dist) 01/23/21 < 264 4830 4150 116 H-3 (Dist) 04/21/21 < 266 4950 4070 122 H-3 (Dist) 07/29/21 < 286 5120 4000 128 H-3 (Dist) 10/21/21 < 275 4140 3940 105 Ni-63 02/05/21 < 4.32 699 873 80.1 Ni-63 05/04/21 < 4.02 811 871 93.1 Ni-63 08/05/21 < 4.98 768 869 88.4 Ni-63 11/02/21 < 4.47 691 868 79.6 Pb-210 06/19/21 0.775 22.0 21.9 96.9 Pb-210 11/16/21 0.412 26.5 23.7 110 Pb-210 11/23/21 0.427 16.9 14.0 118 Sr-89 02/16/21 < 8.2 105 119 88.2 Sr-89 08/04/21 < 7.8 1200 1540 77.9 Sr-89 11/02/21 < 6.9 149 198 75.3 Sr-90 02/16/21 < 1.0 45.7 54.1 84.5 Sr-90 04/28/21 < 0.86 59.5 55.0 108 Sr-90 08/04/21 < 0.92 143.0 110 130 Sr-90 11/02/21 < 0.93 43.3 54.5 79.5 Downloaded or Printed copies are UNCONTROLLED copies

• • Internal Process Control results use TBE-ES acceptance criteria of 60 -140% recovery

ATTACHMENT B.2 TBE - ES QC Program In-House Duplicates*

1. of Dups # Samples RPD Upper Matrix Nuclide Analyzed Evaluated for RPD** RPD Range Limit Air Particulates Be-7 (Gamma) 48 6 1.3 - 12.9 30 Gross Alpha 64 19 0.5 - 29.6 30 Gross Beta 516 242 0.0 - 29.8 30 Sr-89 72 5 2.2 - 19.9 30 Sr-90 75 0 30 Th-228 15 0 30 U-234 1 1 7.1 30 U-238 1 1 4.8 30 Charcoal I-131 (Gamma) 427 2 5.3 - 6.1 50 Feed/Food/Grass/Veg Be-7 (Gamma) 34 3 5.7 - 35.4 50 K-40 (Gamma) 35 34 0.3 - 41.9 50 Fish/Shellfish (1) Be-7 (Gamma) 7 0 50 K-40 (Gamma) 7 3 1.1 - 22.6 50 Milk K-40 (Gamma) 155 155 0.0 - 25.3 30 Sediment/Soil/Solid C-14 (RAD) 18 4 16.8 - 34.3 50 H-3 (RAD) (2) 7 0 50 K-40 15 9 0.5 - 40.8 50 Pb-210 3 1 10.6 50 Water/Liquid Am-241 6 2 12.4 - 23.0 30 Fe-55 10 0 30 Gross Alpha 25 2 7.2 - 12.5 30 Gross Beta 35 5 3.5 - 8.5 30 H-3 268 36 0.3 - 28.0 30 K-40 (Gamma) 69 3 3.8 - 14.0 30 Ni-63 10 2 14.4 - 27.3 30 Sr-89 17 2 3.5 - 9.7 30 Sr-90 17 3 7.9 - 18.2 30 LO/LR C-14 (RAD) 14 0 30 H-3 40 15 0.0 - 25.4 30 LCSD's Am-241 (AS) 32 32 0.1 - 22.7 30 C-14 (RAD) 27 27 0.0 - 29.1 30 Cs-137 (RAD) 9 9 1.1 - 16.4 30 Fe-55 83 24 0.3 - 23.8 30 Gross Alpha 37 37 0.0 - 25.1 30 Gross Beta 38 38 0.0 - 25.4 30 H-3 28 28 0.2 - 15.9 30 I-129 62 40 0.6 - 26.3 30 Ni-63 95 95 0.0 - 25.7 30 Pu-239/240 (AS) 33 33 0.2 - 29.8 30 Sr-89 28 25 0.1 - 28.7 30 Sr-90 44 44 0.0 - 29.7 30 Tc-99 24 24 0.7 - 14.4 30 Th-230 (AS) 13 13 0.5 - 18.1 30 U-238 (AS) 26 26 1.5 - 25.8 30 MSD's Pb-210 3 3 5.4 - 8.6 30

• NOTE: Duplicates for Gamma analyses on this form are only for nuclides reported for QC data packages (All Gamma nuclides are duplicated at the time of analysis)

• • Precision is not evaluated if results are < 5x MDC or if both results are non-detect (1) 2nd Qtr QA report contained erroroneous numbers of samples - should have been 1 instead of 5 (each)

(2) 3rd Qtr QA report correct values: 6 samples, 0 evaluated (13.2 RPD was for with K-40, not H-3)

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ATTACHMENT C Non-Conformance Reports (NCRs)

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C.1 Downloaded or Printed copies are UNCONTROLLED copies

C.1 Downloaded or Printed copies are UNCONTROLLED copies

C.2 TELEDYNE BROWN ENGINEERING NONCONFORMANCE REPORT (NCR) FORM

1. NCR No.: __2_1_-0_2...______

2. Responsible Manager: Sharon Northcutt PART 1. TO BE COMPLETED BY ORIGINATOR OF NCR

3. Laboratory Area: Environmental Lab 4. Client/Project Affected: TBE MAPEP

5. Requirement

Reference:

TBE-4006 6. Affected Data: L# L91129

7. NCR

Description:

Unacceptable AP Gross Alpha result

8. Client Notification: YES w NO 9. Associated CC #: NA

10. Prepared By: Sharon Northcutt i 11. Date: 06/09/21 PART 2. TO BE COMPLETED BY NCR INVESTIGATOR

12. Root Cause, Corrective/Preventative Action: See Attached Supplemental Sheet

13. Planned Completion Date(s) for Actions(s): 0709/21

14. Prepared By: 15. Date:

16. Approved By: 17: Date:

PART 3. TO BE COMPLETED BY QUALITY ASSURANCE MANAGER

18. Revi w a d Verification of Corrective Action (where applicable) l ]

\/ Accepted D Rejected D Follow-up Needed

19. Prepared By: 20. Date:

PART 4. TO BE COMPLETED BY RESPONSIBLE MANAGER J

21. Client Follow-Up Notification: D YES I x: No

22. Date:

Description:

23. Prepared By: 24. Date:

Nonconformance Report (NCR) Form KQA-9 Rev 5 05/15/20 Downloaded or Printed copies are UNCONTROLLED copies

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ATTACHMENT D Audit Reports Downloaded or Printed copies are UNCONTROLLED copies

E.1 INTERNAL AUDITS Downloaded or Printed copies are UNCONTROLLED copies

INTERNAL AUDIT REPORT Audit Plan Audit Date:

Auditor: Charles Hurst, Lead Auditor Audit No.: 2021-038 6-9 December 2021 Auditee(s): Sharon Northcutt, TBE Knox Lab Methods: Review of objective evidence, Scope: documentation, and through interview of personnel TBE Knoxville Lab Operations Tools: AS9100D Aerospace Standard (or other Criteria: standard as noted in Scope & Criteria), K-QAM-1 Rev TBE Knoxville Quality Manual 34, Process Specifications, Internal Audit Checklists, associated forms, and other tools as needed Date Time Area / Department / Process / Function Key Contact 6 Dec-9 Dec 0830-1630 TBE Knoxville Lab operations Sharon Northcutt Process Effectiveness Assessment Report (PEAR)

Process Name: TBE Knoxville Quality System and Operations Process details, including associated process interfaces:

Applicable AS9100 clause(s): N/A. This annual internal audit was conducted for the purpose of assessing TBE Knoxville Labs quality system as documented in the Quality Assurance Manual for Teledyne Brown Engineering Environmental Services, Document K-QAM-1, Rev 34, effective April 15, 2021, and associated implementing Procedures. A specific checklist was developed and used for this audit. The completed checklist is attached to this form.

Organizations method for determining process effectiveness:

- Customer satisfaction

- Audit results

- NCRs generated F-926, Rev. C, 9/8/21 Page 1 of 3 Downloaded or Printed copies are UNCONTROLLED copies Teledyne Confidential; Commercially Sensitive Business Data

INTERNAL AUDIT REPORT Auditor observations and comments supporting process effectiveness determination:

The quality program of TBE Lab Knoxville was well documented, organized and implemented. All required information was readily available, and all involved in the audit were very helpful and knowledgeable.

Statement of Effectiveness Level:

The process is:

1. Not implemented; planned results are not achieved.

2. Implemented; planned results are not achieved, and appropriate actions not taken.

3. Implemented; planned results are not achieved, but appropriate actions being taken.

4. Implemented; planned results are achieved.

Auditor Name(s): Charles Hurst Auditee Representative Acknowledgement Name: Sharon Northcutt Audit Summary The audit results documented in the checklist consists of two observations. There were no findings identified during the course of this audit.

Based on the results of this audit, I believe the labs QA program remains effectively implemented.

Previous Years Finding REF Requirements Observation, Comments, Objective Evidence ACC REJ TBE-1010 Not all non-retest customer complaints were being X processed through the NCR procedures as required by TBE-1010. - Finding was addressed and closed during the 2020 audit.

Current Year Audit Findings and Opportunities for Improvement (OFIs)

REF Requirements Observation, Comments, Objective Evidence ACC REJ K-QAM-1 6.2.5.3g Periodic annual reviews Observation (1): The 2020 annual review was not X completed until July 2021. While the report was well done and extensively detailed, the significant F-926, Rev. C, 9/8/21 Page 2 of 3 Downloaded or Printed copies are UNCONTROLLED copies Teledyne Confidential; Commercially Sensitive Business Data

INTERNAL AUDIT REPORT lag between the end of the calendar year and generation of the actual report lessons the assessment/evaluation potential of the report. It is recommended the report be completed as close to the end of the calendar year as possible to assure the data and analysis is relevant at the time of review.

K-QAM-1 8.6.3 Audits are performed to Observation (2): When improvements are X identify trends and offer identified in a surveillance, they are noted there suggestions for improvement. but not collected in manner to readily show how many and what types of improvements were achieved over a given time. Recommend that as improvements are identified, an NCR be opened and identified as an Improvement Action to take credit for the improvement and to track overall improvement progress. The NCR log could be retitled, accordingly, as the NCR/Improvement Action log.

Checklist - See Attached Checklist REF Requirements Observation, Comments, Objective Evidence ACC REJ F-926, Rev. C, 9/8/21 Page 3 of 3 Downloaded or Printed copies are UNCONTROLLED copies Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 6.2 Personnel 6.2.1 The QA Manager maintains the training matrix for the lab SAT Reviewed training matrix. Pulled three records to compare to and ensures that procedure update or annual quality requirements of the matrix:

and/or safety-related training is complete

• Megan Demarse

• Kenny Cooper

• Kimberly Thurman No anomalies noted. All records were clear, legible, and well maintained.

6.2.2 Job descriptions that include duties and responsibilities SAT Job descriptions are specifically maintained, beyond the standard HR for all staff are available for review. position descriptions, to clearly lay out the duties and responsibilities assigned. The following were reviewed:

• Megan Demarse (Lab Tech)

• Kenny Cooper (Receiving)

• Kimberly Thurman (PM) 6.2.4 Analysts must be recertified if: a) not enough QC data has SAT Generated QC data is tracked by the QA Manager as the employee Downloaded or Printed copies are UNCONTROLLED copies been generated to support annual requirement or b) and method level to identify progress toward meeting annual there are significant changes to a procedure requirements and to highlight when recertification might be required.

6.2.5.3 Quality Assurance Manager SAT The 2021 Internal Audit Schedule was reviewed. The following audits were reviewed:

g. conducting or arranging for periodic internal audits and

• 4015 completed 1/1 management reviews, as well as coordinating external

• 1013 completed 10/8 audits;

• 2012 completed 6/18 ATTACHMENT 1``` 1 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 The Quality Manager is consistently producing both Quarterly and Annual Quality Assurance Management Reviews. The following were reviewed:

• Q3 2021 Quarterly Quality Assurance Management Review

• 2020 Quality Assurance Management Review Observation(1): The Annual review was not completed until July 2021. Given this review covers CY20, it was seem the usefulness of such a review is somewhat degraded if not completed until 7 months into the new year.

While the report contains an excellent rundown of very detailed information, it would be more effective as a management tool if the review was conducted closer to the end of the calendar year in the event actionable decisions needed to be made to address identified process or other shortfalls from the previous year.

Recommendation is to conduct this annual as soon after the conclusion of the previous year as possible. The QA Manager is of the same mind in this regard and had already noted her intention to improve in this area.

6.2.5.4 Project Managers (PMs) SAT Interview confirmed PMs serve as the primary interface with he

b. entering and maintaining client information for client. Client complaints come to the lab through the PM.

contacts, reporting, billing, and technical specifications Downloaded or Printed copies are UNCONTROLLED copies into the LIMS Customer complaint documentation was reviewed for the following:

• CC-21-03

h. documenting and investigating client complaints

• CC-21-11

j. maintaining a storage system for lab reports and other PM provides document retention for lab reports. The following documents required to be kept for a specified time period reports were reviewed as OE:

• L93331

• L93380

• L93340 All we found to be complete, fully documented and well organized.

ATTACHMENT 1``` 2 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

6.2.5.5 Sample Custodian SAT Interviewed Sample Custodian and observed him full processing a sample shipment. He was well versed on the requirements of the

b. thoroughly reviewing paperwork and containers position and followed procedural requirements as documented in received with shipped packages and noting the quality system.

inconsistencies or damage and informing the Project Manager Immediately 6.2.5.6 Laboratory Technicians SAT Observed two separate Lab Techs in preparing samples for TBE-2007

d. identifying potential sources of error and correcting (WG38153) and TBE-2011 (WG38151). Both were well versed on the problems that could affect data quality requirements of each method and followed the written procedures as required.

6.2.5.9 Health & Safety Officer SAT Reviewed Healthy and Safety inspection reports covering the previous four-month period. Checks appeared to be comprehensive

c. performing safety checks and audits and thorough.

6.2.5.10 Radiation Safety Officer (RSO) SAT The Lab Manager serves in the role of RSO. Regular radiological surveys are being conducted as required. The following were

b. coordinating scheduled radiological surveys and reviewed:

Downloaded or Printed copies are UNCONTROLLED copies administer personal dosimetry and sealed radioactive

• Weekly report ending 11/29 source leak test programs

• Monthly report for November 2021

• Quarterly report for Q4 dated 10/31/21 ATTACHMENT 1``` 3 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.1 Review of Requests, Tenders and Contracts 7.1.1 Review of Requests, Tenders and Contracts SAT Through interview it was confirmed the PMs are the conduit for responding to requests for quote, tenders and contracts.

Initial requests for quote or for additional analytical work are assigned a project manager who verifies that the Q677 was reviewed which showed evidence of Dunn and Bradstreet scope of work is clearly defined and reviews the request review, forbidden course review and final response to the prospective against current laboratory procedures and capabilities. clients. Files are maintained locally in could condition and readily available.

7.1.2 The response to request will include lab procedure and/or SAT Required elements of the response with found in the files examined.

analytical method with appropriate accreditation information (where needed).

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.2 Selection, Verification and Validation of Methods 7.2.1.3 The laboratory verifies proper performance of any new N/A No new methods have been implemented in many years so there was methods prior to processing samples to ensure that nothing recent to review. The lab does have a procedure, TBE-4007 required performance criteria can be achieved. Rev 6, covering this process, however.

Verification records are maintained by the QA Manager.

Method revisions to national standards require TBE-4007 Rev 6 was last revised in 2017 and should be reviewed in verification to the extent necessary. accordance with every three-year requirement to assurance the document remains current.

7.2.2.1 Controls have been established to assure computer N/A V & V was done years ago during the initial deployment of LIMS.

software validity and track verification of validity. All computer programs used in laboratory operations have documented verification and validation prior to first use and after program modification.

7.2.2.3 Method validation includes demonstration of detection N/A No V &V performed in recent years.

Downloaded or Printed copies are UNCONTROLLED copies capability, precision, bias, and measurement uncertainty for each matrix. It also may include comparing results achieved against other validated methods.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.4 Handling of Test Items 7.4.2 Sample Acceptance SAT As observed in witnessing Sample Receiving process, the log is Upon receipt, a log is kept documenting each maintained electronically in LIMS.

shipping container received 7.4.3 Identification SAT Identification created in LIMS during the receiving process was Once approved, each sample is given a LIMS- noted as being carried through all processes at TBE Knox, generated unique laboratory ID (L#). Information including work group creation to final ROA.

associated with each sample is carried through the entire analytical process included: sample ID, collection date and/or time, receipt date/time, requested analysis, results of sample inspection. All sample containers are given a durable label using indelible ink that indicates the project ID, L#, the number of containers and the storage locations(s).

Downloaded or Printed copies are UNCONTROLLED copies 7.4.4 Sample Storage SAT Dedicated storage space was inspected. Storage appeared to Samples are stored away from standards, reagents, be safe, well organized and conveniently located. Storage and food for human consumption. includes dry and cold storage. All is well labeled and properly segregated as required.

ATTACHMENT 1``` 6 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.5 Technical Records 7.5.1 The laboratory maintains a documentation system for SAT The entire process is well documented, both in hard copy and quality records of the analytical process. electronically through LIMS. Receipt records, processing records, data output, QA documentation of machine performance and final output records are all well maintained and efficiently organized.

7.5.2 Amendments to original records are signified by a single SAT Very few amendments to records were noted during this audit.

stroke through the incorrect information with a brief The few records that did show evidence of physical amendment, explanation (unless obvious). The person making the were done so according to local instruction for single line through, change initials and dates the change. initials and dates.

7.5.3 Physical records are retained onsite for 2-3 years and then SAT Records retained locally as required. Beyond 3 years, records are logged and shipped to the TBE Huntsville storage facility. inducted into long term storage through the TBE Huntsville (TBE-1003, TBE-1008, TBE6004) records storage program.

Section 7.0 Process Requirements 7.6 Evaluation of Measurement Uncertainty Downloaded or Printed copies are UNCONTROLLED copies 7.6.3 TBE includes a 1- or 2-sigma combined standard SAT Observed on reports are required by the respective client.

uncertainty (CSU) [aka Total Propagated Uncertainty (TPU)]

value with all analytical results, depending on client request.

ATTACHMENT 1``` 7 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.7 Ensuring the Validity of Results 7.7.3 Analytical Batches SAT Reviewed the following workgroups:

The Labs analytical system is shown to be in control using batch and sample-specific QC. All samples must

• WG38137 (TBE-2011) be placed in a workgroup batch and processed with

• WG38151 (TBE-2011) appropriate QC. Batch size is dependent upon the

• WG38153 (TBE-2007) method, but generally consists of one (1) to twenty All batches were processed IAW written procedures as noted. Lab (20) samples plus QC. All batch samples are Technicians appear knowledgeable and well trained for their processed together in the same manner assigned roles.

(preparation, analysis, data reduction and reporting).

Batch samples are not required to be analyzed concurrently on the same detection system. The lab does not systematically or preferentially use specific detectors, equipment, or glassware for analyzing QC samples. Two types of batches in the radiochemical lab are:

a. Preparation Batch - samples require physical Downloaded or Printed copies are UNCONTROLLED copies or chemical processing that affect the outcome of the analysis. Samples are prepared with the same process, personnel and lot(s) of reagents, with a maximum time between the start of processing of the first and last sample to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. Radiation Measurements Batch (RMB) -

samples require no physical or chemical processing that could affect the outcome of the test. Examples are: non-destructive gamma spectrometry, air filters ATTACHMENT 1``` 8 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 for alpha/beta counting, or swipes on gas proportional detectors. Samples may be processed within fourteen (14) calendar days (start of the first sample to the last sample).

7.7.4 QC Samples SAT Extensive control checks are tracked and available throughout the Process control checks demonstrate consistent lab quality. process. The following checks were specifically reviewed:

These checks that include QC and proficiency samples, constitute 10% of the annual processing workload for lab

• Gamma analytes and methods.

• Alpha

• X and Y 7.7.5 Interlaboratory and Client Proficiency Testing SAT The Cross Check program is extensively detailed in Appendix A.1 of the To further ensure the validity of results, TBE regularly Q3 Quarterly Assurance Report. Conforming and non-conforming status participates in various proficiency testing (PT) studies is presented in detail with links to NCRs where applicable.

during the year. These external performance checks (aka cross-checks) are samples with an unknown amount of analyte added. Internal PT samples are obtained from and reported to accredited proficiency testing providers. Some clients also routinely send their own cross-check samples.

All PT samples are received, analyzed, and processed in the same manner as routine samples. Internal PT results are reported directly to the PT provider and the results sent back to the lab and its accrediting body (where applicable).

Downloaded or Printed copies are UNCONTROLLED copies Clients report their cross-checks to the PT provider directly and final evaluations are not always shared with the lab.

Although all radionuclide or matrix combinations are not available for proficiency testing. TBE makes every effort to analyze PT samples that are representative of routine client samples. Cross-check results that are not within the providers acceptance criteria are documented with a root cause investigation, corrective action (where merited) and a non-conformance report (NCR). (TBE-4006 Interlaboratory Performance Evaluation Programs)

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.8 Reporting of Results 7.8.2 Required Items SAT The following were reviewed as objective evidence for this requirement:

Sample results are compiled into a report and contain the

• L93340 following items: o Palisades Nuclear Plant

a. title (Report of Analysis or ROA) o TBE-2008

b. name and address of the laboratory (where analyses are o TBE-2010 performed)

• L93331

c. unique identification that correlates individual pages to o Mayo Clinic the entirety of the report o TBE-2007

d. contact name/address of the client

• L93380

e. sample description information (ID, collection o PSEG Nuclear LLC date/time) and lab ID information o TBE-2007

f. sample receipt date, condition and any sample o TBE-2011 acceptance criteria variance

g. TBE Procedure (SOP) ID All elements of this requirement were noted in each of the three above

h. test result (activity) directly as obtained with ROAs).

appropriate number of significant figures, measurement uncertainty estimation, detection limit (MDC),

measurement units, reference date, count date/time, and Downloaded or Printed copies are UNCONTROLLED copies flagged values (results outside of technical specifications)

i. notation for method changes (if applicable)

j. name, title and signature of the person(s) authorizing the report

k. statement that results relate only to the items tested

l. statement that the report shall not be reproduced, except in full without approval of the laboratory

m. clear identification of any subcontracted analyses and results ATTACHMENT 1``` 10 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.9 Client Complaints 7.9.2 Complaint Resolution Process SAT Customer complaints are documented via KQA-22 as required here. A

a. Staff receives and documents complaint on TBE KQA-22 Customer Complaint Log is maintained by PM and QA Manager which Complaint Detail Form. includes relevant information and current status.

b. Complaint is investigated promptly and if warranted a Non-Conformance Report that includes a root cause Extensive details are included in the Quarterly Quality Assurance evaluation and corrective action is initiated. (Section 7.10) Reviews.

c. A decision is made regarding the complaint resolution such that all parties involved are in agreement and are satisfied with the outcome (client notification and approval).

d. Suitable response is taken by the lab to prevent recurrence (where applicable).

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.10 Nonconforming Work, Corrective and Preventative Actions 7.10.3 When a nonconformity is discovered, the following steps SAT Nonconformities are handled in accordance with TBE procedures.

are taken:

a. Nonconformance is initiated by the responsible staff The following NCRs were reviewed:

and documented on form KQA-9 Nonconformance Report

• 21-03 (NCR) Form. The nonconformance is given a unique

• 21-04 identifier, added to the NCR log, and a brief summary

• 21-07 including requested completion date recorded on the

• 21-11 form.

b. The NCR is relinquished to the appropriate manager for All reviewed NCRs included evidence of processing as required.

evaluation of significance, including work stoppage where appropriate. The manager conducts a root cause investigation to determine the source of the departure from the standard. The manager will also update the parties involved as to the progress towards resolution.

c. After the root cause analysis is completed, a corrective action plan is developed with the Operations Manager (or other involved staff). The Operations Manager or designee Downloaded or Printed copies are UNCONTROLLED copies determines the acceptability of nonconforming work and where necessary, the client may be notified, and the work recalled.

d. The Operations Manager or designee authorizes the resumption of work (where necessary). The QA Manager tracks the progress of the NCR through closure and evaluates the effectiveness. (Section 8.7). The target date from NCR initiation to corrective action plan is 30 days.

Note: More complex issues may require more time.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 7.0 Process Requirements 7.11 Control of Data and Information Management 7.11.2 Any changes to the LIMS software configuration or SAT The only LIMS software configuration that occurs locally is through modifications to commercial software revision of the user interface of existing forms, creation of addition are authorized, documented and validated before use. data extraction reports, and other minor user interface modifications that do not adjust the underlying code of LIMS or alter the calculation methodology employed by LIMS. Extensive documentation is maintained regarding requests to modify forms and any actions taken that modify LIMS forms as a result.

7.11.3 TBE-ES LIMS is only accessible by trained staff with assigned SAT Access to LIMS is controlled by a single local IT member (with backups security levels based upon job function. Changes to LIMS provided through IT Shared Services in Huntsville). Local IT grants programming are documented and can only be accessed by remote access that allows employees to get to the LIMS application the LIMS Manager. then he also assigned specific LIMS access that correspond to job responsibilities as assigned.

7.11.6 Only the most current document revisions are available on SAT Current revisions of manuals and procedures are maintained on a the shared network drive. This includes TBE procedures as network drive that is controlled by local IT. It provides lab-wide well as the Safety and QA Manuals. All staff have access at access to the most recent procedures and other documents.

all times to these documents. Superseded documents are maintained independently by the QA Downloaded or Printed copies are UNCONTROLLED copies Manager for historical purposes, both electronically and in hardcopy.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 8.0 Quality Management System (Option A) 8.2 Management System Documentation 8.2.3 The QMS allows only qualified personnel to SAT Reviews/Updates to procedures are fully controlled by the QA review/update/perform specific procedures. It Manager. Assignment to perform specific procedures is encourages integrity, impartiality and consistency in daily monitored by the QA Manager through the Training matrix, job lab operations at all levels. description and documentation of completed training.

Section 8.0 Quality Management System (Option A) 8.3 Control of Management System Documents 8.3.1 TBE-ES maintains control of documents that relate to the SAT Current revisions of manuals and procedures are maintained on a QMS, including training, procedures, audits, corrective network drive that is controlled by local IT. It provides lab-wide actions, management reviews, forms, and the QA Manual. access to the most recent procedures and other documents.

(TBE-1008 Documents and Document Control) Superseded documents are maintained independently by the QA Manager for historical purposes, both electronically and in hardcopy.

8.3.2 Controlled documents are periodically reviewed and SAT Reviewed 24 procedures. 3 of those 24 had surpassed the 3-year Downloaded or Printed copies are UNCONTROLLED copies updated as necessary. Only authorized personnel can review requirement (when considered month to month); 3006, approve and issue controlled documents. All staff whose 1012, 4007. 3006 and 1012 we due in 2021 and are being tracked work is affected by changes are notified and trained to the for completion by the end of CY21 to meet the intent of the revision. requirement. 4007 was due for review in 2020. QA Manager has this for review at this time.

8.3.4 Original signed QMS documents are stored in the QA SAT QA Manager maintains in fireproof cabinets in the QA Managers Managers office and/or stored electronically on TBEs office. Only documents were verified to only by the most current shared computer network drive. Only current pdf copies of revisions.

QMS documents are available for access and distribution and include the disclaimer DOWNLOADED or PRINTED copies are UNCONTROLLED.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 8.0 Quality Management System (Option A) 8.4 Control of Records 8.4.1 Quality and technical records are maintained in SAT As noted throughout this audit, all documents reviewed were accordance with TBE Procedures TBE-1003 Control and found to be maintained in accordance with this requirement.

Retention of Quality Assurance Records and TBE-1008 Documents and Document Control.

Section 8.0 Quality Management System (Option A) 8.6 Improvement 8.6.2 Actions are taken in response to trends signifying SAT Regular audits and surveillances are assessed during quarterly deterioration in lab performance reviews for trends and effectiveness of previous corrective indicators such as quality data, repeated audit findings or actions.

turnaround times.

8.6.3 Audits are performed to identify trends and offer SAT Extensive audits are scheduled and completed. Many showed suggestions for improvement. evidence of improvements identified during the audit or surveillance.

Observation (2): When improvements are identified in a Downloaded or Printed copies are UNCONTROLLED copies surveillance, those are noted there but not collected in manner to readily show how many and what types of improvements were achieved over a given time. Would recommend that as improvements are identified, an NCR be opened with it identified as an Improvement Action to take credit for the improvement.

The NCR log could be retitled, accordingly, as the NCR/Improvement Action log.

ATTACHMENT 1``` 15 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 8.6.3.4 Lab quality performance is reviewed and summarized in a SAT Reviewed the Q3 2021 QA report. This is an outstanding quarterly QA Report. document that provides excellent levels of detail to management Audits and nonconformance/corrective actions are also as a tool for monitoring/improving the performance of the included in the report. This report is distributed to TBE program.

management and is also available for clients. A summary of this report is included with the Annual Management Report.

Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 8.0 Quality Management System (Option A) 8.7 Corrective Actions 8.7.1 Corrective action is taken as the result of a departure SAT Nonconformities are handled in accordance with TBE procedures.

from specifications imposed by client contract, regulatory requirement or TBE stated policy or The following NCRs were reviewed:

procedure. They are measures taken to discover the

• 21-03 source of a deviation and to avoid similar issues going

• 21-04 forward. Corrective action is taken promptly and to a

• 21-07 Downloaded or Printed copies are UNCONTROLLED copies

• 21-11 degree appropriate to the magnitude and risk of the issue. Conditions adverse to quality are documented All reviewed NCRs included evidence of processing as required.

and tracked with proposed and actual completion dates. (TBE-1012 Corrective and Preventative Action)

ATTACHMENT 1``` 16 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 8.7.2 Nonconformities are documented on a Non- SAT See 8.7.1 above.

Conformance Report (NCR) Form. After investigation and analysis is complete, appropriate corrective action is taken and consequences are determined (where applicable). A target completion date is set for 30 days from initiation to corrective action plan. This date may be adjusted as deemed necessary due to the complexity of the nonconforming issue. Where analytical results are involved, data is monitored carefully until the issue is fully resolved. Notification is made to appropriate parties (where applicable). All NCRs are included with the quarterly/annual QA Report.

8.7.3 Corrective action effectiveness is evaluated SAT Extensive evaluation is included in the Annual QA Management periodically to verify that measures put into place have review.

been successful and/or to ensure that any nonconforming issue has not been repeated. A summary evaluation of corrective action of effectiveness is included in the annual management report.

8.7.4 Risks and opportunities based on corrective actions SAT Assessed during Annual QA Management.

taken are evaluated periodically by management.

Downloaded or Printed copies are UNCONTROLLED copies Changes to the management system may be made to limit vulnerability or exposure to potential risk or to promote more efficient lab operation.

ATTACHMENT 1``` 17 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 8.0 Quality Management System (Option A) 8.8 Internal Audits 8.8.1 In order to detect actual or potential nonconformities SAT The 2021 Internal Audit Schedule was reviewed. The following before data quality could be affected, internal audits audits were reviewed:

are planned and conducted. These audits verify

• 4015 completed 1/1 conformance of lab operations and the management

• 1013 completed 10/8 system to regulatory and accreditation requirements,

• 2012 completed 6/18 and to the labs own policies and procedures. (TBE-1013 Audits and Management Review) 8.8.2 An internal audit plan is generated annually and SAT The internal audit schedule for 2021 was reviewed and found to includes the procedures and surveillances that are include over 50 audits that covered the following areas:

planned during the year. The goal is to review each

• Client area of the lab in some fashion. The plan is maintained

• Equipment/Calibration by the QA Manager, but audits may be performed by

• LIMS other staff. Auditors are trained in performing audits,

• Non-Conformance/Client Complaint have some technical background in the subject matter,

• Organization/Management

• Lab Procedure/Forms and are independent of the activity to be audited (not

• QS Stds Downloaded or Printed copies are UNCONTROLLED copies directly involved or have supervisory responsibility).

• Rad/Safety/Facilities

• Training ATTACHMENT 1``` 18 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

8.8.4 An analytical procedure surveillance is scheduled to SAT A Method Procedures for Surveillance is maintained by the QA observe analysts as they perform a method to verify Manager and was found to include 10 surveillances in CY21. The that it is being done as written and to note any following were reviewed during this audit:

changes that may need to be made to the written

• TBE-2003, completed 5/12/21 procedure. The results of the QC workgroup are

• TBE-2005, completed 7/26/21 included to show that the results are within control

• TBE-2007, completed 11/24/21

• TBE-2018, completed 11/21 limits. All audit results are evaluated by the Operations Manager and any necessary changes are made where needed.

8.8.6 Audit findings of nonconformances are documented SAT For CY21, no findings were noted during scheduled audits.

and timely corrective action is taken, tracked to closure, and evaluated for effectiveness. An audit response including corrective action is sent to the auditor, (and to the Director of Quality Management Systems for the annual Quality System audit). Any findings that could cast doubt on the validity of results are disclosed in writing to the affected client(s) within 7 days. The QA Manager (or designee) verifies that the Downloaded or Printed copies are UNCONTROLLED copies client was contacted properly.

ATTACHMENT 1``` 19 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021 Item Line of Inquiry Status Summary of Observations/Objective Evidence Reviewed/Audit Notes. Listed procedures / documents should also indicate revision number and date of implementation.

Section 8.0 Quality Management System (Option A) 8.9 Management Reviews 8.9.1 In conjunction with the Internal Audits (Section 8.9 SAT The most recent Management Review was completed 7/1/2021 above), the laboratory conducts an annual for CY20. See Observation (1) earlier in this audit.

management review to ensure continuing suitability, adequacy, and effectiveness of stated policies and objectives in this Quality Manual. (TBE-1013 Audits and Management Review) 8.9.2 The review includes: SAT All elements listed in this requirement were found to be included

• a summary of any changes to the QA program from in the CY20 Annual review completed on 7/1/2021 the previous year

• adequacy of staff and equipment resources

• a list of staff specialty training certificates with expiration dates

• highlights from the 4th Qtr (annual) QA Report (QC sample and proficiency results and audits)

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• an analysis of QA results (indication of analytical bias)

• internal/external audit results and associated investigations and corrective actions

• commentary on effectiveness of corrective actions

• a listing of current accreditations and/or plans for any changes

• comparisons of sample volume and turnaround times to previous years

• client feedback not included with the QA Report ATTACHMENT 1``` 20 Teledyne Teledyne Confidential; Confidential; Commercially Commercially Sensitive Sensitive Business Data Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2021

• observations by staff for improvements

• results of risk identification

• any changes/updates to methodology

• a statement of management system effectiveness and fulfillment of objectives 8.9.3 Upon completion of the draft review, the information SAT The CY20 Annual Review included signatures by both the QA is submitted to and signed by the Operations Manager Manager and the Operations Manager. The final report was and then signed by the QA Manager. Action items are subsequently distributed as required.

assigned to designated responsible staff with an agreed-upon schedule for completion. The QA Manager ensures that actions are documented and completed. A copy of the signed report is sent electronically to the Sr VP of Energy & Environment and to the Director of Quality Management Systems (both TBE Huntsville management).

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E.2 EXTERNAL AUDITS Downloaded or Printed copies are UNCONTROLLED copies

Intentionally Left Blank Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Utah Department of Health NELAP Certification On-Site Audit Downloaded or Printed copies are UNCONTROLLED copies

Intentionally left blank Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Northcutt, Sharon From: Robert Aullman <raullman@utah.gov>

Sent: Monday, June 28, 2021 8:35 AM To: Northcutt, Sharon

Subject:

Onsite Report Attachments: AuditResultsFindings.pdf External Email I have attached a copy of your onsite report. Please respond so that I have documentation of the receipt of the report. Thank you for your time and cooperation with the assessment. Let me know if you have any questions or concerns.

Robert Kyan Aullman Environmental Lab Certification Officer Phone: 385-977-1255 Fax: 801-536-0149

• • • • • • • • • • • • • • • IMPORTANT MESSAGE***************

This message, including any attachments, may contain confidential information intended for a specific individual and purpose, and is protected by law. If you are not the intended recipient, delete this message, including from trash, and notify me by telephone or email.

If you are not the intended recipient, any distributions or copying of this message, or the taking of any action based on its content is strictly prohibited.

1 Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Utah Department of Health Richard G. Saunders Executive Director Division of Disease Control and Prevention State of Utah Janae Duncan Spencer J. Cox Division Director Governor Deidre Henderson Lieutenant Governor Keith O. Jeter 6/17/2021 Teledyne Brown Engineering Environmental Services 2508 Quality Lane Knoxville, TN 37931

Dear Keith 0. Jeter,

An on-site assessment of Teledyne Brown Engineering Environmental Services was performed beginning 06/10/2021. The purpose of the on-site assessment was to evaluate your facility and determine Teledyne Brown Engineering Environmental Services's compliance with Utah Rule R444-14 Rules for the Certification of Environmental Laboratories and the TNI standard. The on-site assessment was performed by staff of the Utah Environmental Laboratory Certification Program (ELCP) and included participation by Teledyne Brown Engineering Environmental Services's personnel listed at the end of this report.

Areas of Assessme nt TNI Environmental Standard 2016 V1M1 Proficiency Testing TNI Environmental Standard 2016 V1 M2 Quality Systems General Requirements TNI Environmental Standard 2016 V1 M6 Radiochemistry Testing I. Introductio n This assessment report reflects only the findings and decisions germane to the on-site evaluation and related application information, including personnel qualifications, laboratory procedures, detection limit studies, training records, quality assurance records, and quality assurance manual.

This assessment report does not attempt to comprehensively address all ongoing certification requirements prescribed in the Utah Rule (R444-14), promulgated methods, and applicable Code of Federal Regulations (40CFR 136, 141, and 261).

The on-site assessment portion for the evaluation of the laboratory included the following steps:

1. Opening conference.

2. Interviews with laboratory management, quality assurance personnel, and technical staff.

3. Review of sample collection, preservation, handling, and transport practices.

4. Review of procedures used for the analysis of environmental samples.

5. Inspection of laboratory facilities and equipment.

6. Review of data reporting, record keeping, instrument maintenance, and self-monitoring (QA records).

7. Discussion of assessment results with the laboratory director and/or personnel.

4431 South 2700 West* Taylorsville, UT 84129

• phone (801) 965-2400

• fax (801) 536-0149 UTAH DEPARTMENT OF https://uphl.utah.gov/

-~HEALTH Page 1 of 6 Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01

- If a CAR indicating unacceptable CAs for any General Laboratory Findings is received, Teledyne Brown Engineering Environmental Services will be notified. You may experience a delay and/or lapse in Teledyne Brown Engineering Environmental Services's certification status until acceptable CAs are received by the ELCP. Teledyne Brown Engineering Environmental Services's certification will expire on the date cited in Teledyne Brown Engineering Environmental Services's latest certificate letter (if applicable).

- If a CAR indicating unacceptable CAs for any Method Specific Findings is received, the ELCP will issue a certificate letter without approval for the affected parameter (method(s) and associated analyte or interdependent analyte group). The current certification cycle will be complete. The affected parameter (method and associated analyte or interdependent analyte group) may be requested again at any time in the future, by notifying the ELCP in writing. A parameter change fee may be assessed.

-Certificate extensions for previously certified laboratories will be issued only if a delay in the certification process is caused by the ELCP.

Ill. Assessment Findings, Requirements, and Recommendations Findings TNI 2016 V1 M2 4.7 Service to the Client (Quality Systems) 1 Citation V1M2 4.7.2/TNI 2016 V1M2 4.7 Service to the Client (Quality Systems)

The laboratory shall seek feedback, both positive and negative, from its customers. The feedback shall be used and analysed to improve the management system, testing and calibration activities and customer service.

NOTE: Examples of the types of feedback include customer satisfaction surveys and review of test or calibration reports with customers.

ELCP Finding The laboratory did not have a process to seek feedback from clients.

Recommendations ----*--

• ]

~~~~*~~~~~

TNI 2016 V1 MG 1.7 Technical Requirements (Radiochemical) 4431 South 2700 West* Taylorsville, UT 84129

• phone (801) 965-2400

• fax (801) 536-0149 UTAH DEPARTMENT OF hllps://uphl.utah.gov/

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EA 21-01 IV. Conclusion Based upon the findings of the on-site evaluation, I will recommend to the Certification Authority that Teledyne Brown Engineering Environmental Services be certified for analyses pertaining to environmental compliance monitoring applicable to the Clean Water Act and Safe Drinking Water Act --

provided that the items listed in section Ill of this report have been adequately addressed within the time frame specified in section 11 of this report.

If Teledyne Brown Engineering Environmental Services needs additional clarification, or believes that any of the findings and requirements have been improperly evaluated, please feel free to contact me for clarification or re-evaluation. I can be reached by phone at 385-977-1255.

Sincerely Robert Aullman Certification Officer (Lead Assessor)

Utah Environmental Laboratory Certification Program 4431 South 2700 West* Taylorsville, UT 84129

• phone (801) 965-2400

• fax (801) 536-0149 UTAH DEPARTMENT OF https://uphl.utah.gov/

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EA 21-01 July 19, 2021 Robert Aullman Certification Officer (Lead Assessor)

Utah Environmental Laboratory Certification Program Utah Department of Health 4431 South 2700 West Taylorsville, UT 84129

Dear Mr. Aullman,

Please find attached the corrective action plan (CAP) which was prepared in response to the National Environmental Laboratory Approval Program (NELAP) audit report, issued on June 17, 2021 and received via email on June 28, 2021. The onsite audit was conducted June 10, 2021.

This CAP is arranged by suggestions/deficiency in the order presented in the audit report and includes objective evidence for the action item identified.

Teledyne Brown Engineering would like to note the professional and technically competent manner in which this audit was conducted. We appreciate the identification of these opportunities for improvement, as well as your department's assistance in our NELAP certification process. Please do not hesitate to contact us with any questions regarding this transmittal or with any request for additional information.

Contacts:

Keith Jeter Laboratory Operations Manager (865) 934-0373 Sharon Northcutt Quality Assurance Manager (865) 934-0374 Sincerely, Sharon Northcutt Quality Assurance Manager Teledyne Brown Engineering Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Findings:

1. V1M2 4.7.2/TNI 2016 V1M2 4.7 Service to the Client (Quality Systems)

The laboratory did not have a process to seek feedback from clients.

Response: Please see NCR 21-04 Form attached.

Recommendations:

1. V1M6 1.7.2.1 a (Assignment of a Preparation Batch or RMB for samples & QC)

It is recommended that the laboratory batch nonprepared samples in radiation measurement batches (RMBs).

Response: Currently, the LIMS issues one type of workgroup batch for no more than 20 samples plus QC (blank, spike, dup, etc). Additional LIMS programming is being implemented to designate between Prep Batch (physical or chemical processing of samples) vs. RMB (non-destructive gamma spectrometry, alpha/beta counting of air filters, or swipes on gas proportional detectors).

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EA 21-01 NONCONFORMANCE REPORT (NCR) FORM

1. NCR No.: 21-04

2. Responsible Manager: Sharon Northcutt PART 1. TO BE COMPLETED BY ORIGINATOR OF NCR

3. Laboratory Area: Quality Assurance Manual 4. Client/Project Affected: NELAP (Utah)

5. Requirement

Reference:

TNI Std 2016 V1M2 4.7 6. Affected Data: N/A

7. NCR

Description:

Audit finding - the laboratory did not have a process to seek feedback from clients f

8. Client Notification: DYES [SJ '

NO 9. Associated CC#: N/A

10. Prepared By: Sharon Northcutt i 11. Date: 06/28/21 PART 2. TO BE COMPLETED BY NCR INVESTIGATOR

12. Root Cause, Corrective/Preventative Action: See Attached Supplemental Sheet

13. Planned Completion Date(s) for Actions(s): 07/28/21

14. Prepared By: Sharon Northcutt 15. Date: 06/28/21

16. Approved By: 17: Date:

PART 3. TO BE COMPLETED BY QUALITY ASSURANCE MANAGER

18. Review and Verification of Corrective Action (where applicable) 1x,/1 Accepted D Rejected Follow-up Needed

19. Prepared By: 20. Date:

PART 4. TO BE COMPLETED BY RESPONSIBLE MANAGER

21. Client Follow-Up Notification: YES l><I NO

22. Date:

Description:

23. Prepared By: 24. Date:

Nonconformance Report (NCR) Form KQA-9 Rev 5 05/15/20 Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Supplemental Sheet NCR No: 21-04 Description of Nonconformance:

Utah Department of Health NELAP audit finding that the laboratory did not have a process to seek feedback from clients.

Reference:

TNI 2016 Standard V1M2 4.7.2:

"The laboratory shall seek feedback, both positive and negative, from its customers. The feedback shall be used and analyzed to improve the management system, testing and calibration activities and customer service.

NOTE: Examples of the types of feedback include customer satisfaction surveys and review of test of calibration reports with customers."

Root Cause:

The prior NELAP audit conducted in 2018 by the State of New York was based on the 2003 NELAC/2009 TNI Standard, which did not directly address this issue. The TBE QA Manual was completely reformatted and updated with Rev. 34, issued March 1, 2021. This revision included the updated regulatory requirements of the 2016 TNI Standard and ISO17025:2017.

Section 8.6.4 states: "In order to understand customer needs and to ensure satisfaction, TBE-ES encourages both positive and negative feedback from clients. The first line of client communication is with the project management team who serve as the primary contact for login, sample results, reporting, turnaround time and complaints Any feedback given to the lab is used to improve the overall management system, analytical procedures and most importantly, customer satisfaction."

While we appreciate and welcome client feedback, there was no official mechanism in place to pro-actively gather this valuable information.

Corrective Action to Prevent Recurrence:

TBE Procedure TBE-1016 "Documentation of Customer Complaints" will be revised, expanded and renamed to include Client Feedback. A client survey will be made readily available in client correspondence and on the website. Once the survey is completed, the results will be sent to the QA Manager, who will evaluate and summarize the comments. The summary will be discussed with the Lab Manager & Project Manager(s) for any needed follow up actions. Results will be communicated to the staff and included in the Annual Management Report.

Date Assurande Manager or Designee Date Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Page 1 0 f 9 Number: TBE-1016 Revision: 4 Procedure Issue Date: 11/10/06 Revision Date: 08/02/2021 Responsible Individual: Quality Assurance Manaqer Next Review Date: 08/02/2024

Subject:

Documentation of Customer Complaints TELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES TBE-1016 Revision 4 Documentation of Client Complaints and Feedback Prepared by: Date:

Sharon Northcutt Quality Assurance Manager Reviewed by: Date:

Sharon Northcutt Quality Assurance Manager Approved by: Date:

Keith 0. Jeter Laboratory Operations Manager Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 p aqe 5 o f 9 Number: TBE-1016 Revision: 4 Procedure Issue Date: 11/10/06 Revision Date: 08/02/2021 Responsible Individual: Quality Assurance Manaqer Next Review Date: 08/02/2024

Subject:

Documentation of Customer Complaints 1.0 SCOPE AND APPLICABILITY 1.1 This procedure describes the process to document client complaints and feedback.

2.0

SUMMARY

OF METHOD 2.1 It is the responsibility of management to record all client complaints and to proactively seek out both positive and negative feedback regarding client satisfaction.

2.2 Complaints are recorded in the Complaint Log and documented on a customer complaint form in enough detail to enable reconstruction of the event. The documentation should include personnel receiving the complaint, date of complaint, steps taken to investigate and resolve the complaint.

If complaints result in data changes to a report, the non-conformance and corrective action systems are used to resolve the issue and record all actions taken.

2.3 Client feedback is gathered via survey link information included with staff-to-client correspondence (primarily email) and/or the TBE website. Survey results assess TBE customer service and are used to make improvements. The results and effectiveness of client feedback is evaluated by the QA Manager in the Annual Management Report.

3.0 DEFINITIONS 3.1 See QA Manual, Appendix B.

4.0 PERSONNEL 4.1 Personnelshall be trained, qualified and certified as per procedure TBE-1007, "Training, Qualification and Certification of Personnel".

4.2 The applicable managers, working with Quality Assurance, are responsible for documenting the customer complaint and supporting corrective and preventive actions where applicable. QA coordinate,s the analysis of the complaint and initiation of corrective action where merited.

4.3 The QA Manag~r is responsible for gathering survey results and relating them to management. A summary is included in the Annual Management Report. The Lab Manager is responsible for communicating results to staff as applicable.

5.0 PROCEDURE 5.1 Customer Complaints and Follow Up 5.1.1 Complaint Log Documentation Go to the G:\QACustomerComplaint Log and Attachments directory and open the Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Paqe 6 o 9 Number: TBE-1016 Revision: 4 Procedure Issue Date: 11/10/06 Revision Date: 08/02/2021 Responsible Individual: Quality Assurance Manaqer Next Review Date: 08/02/2024

Subject:

Documentation of Customer Complaints "Customer Complaint Log Running 2016 to current" (EXCEL) file. Assign the next complaint number (CC-YY--##-) and enter the date of complaint, staff filing the complaint, a brief description, the relevant L#/WG#, and the Client/Project ID.

5.1.2 Complaint Investigation and Follow Up 5.1.2.1 Complete Form KQA-22, "Customer Complaint Detail Form" to document the complaint (WORD document). A blank form can be found in the G:\QA\Customer Complaint Log and Attachments or G:\Forms directories. The customer complaint form includes a space for a related NCR - include this information if available at the time. The following information should be supplied:

a. The complaint number (YY--##-).

b. The date the complaint was received and the person handling it.

c. Client contact, company name, associated. L#/WG#, NCR# (if known) 5.1.2.2 Record the complaint in detail and note any requests made by the customer for resolution of the complaint (reanalysis, revised report, etc.).

5.1.2.3 Record in detail the steps that were taken to investigate and determine the cause of the discrepancy.

5.1.2.4 Document the results of the investigation and the resolution of the complaint.

5.1.2.5 Print a copy and save the completed & signed document in G:\QA\Customer Complaint log and Attachments. Print/scan pertinent documents and save along with the form. The attached documents must contain the complaint number.

5.1.2.6 If the validity of results is affected, contact the Quality Assurance Manager and initiate a non-conformance and corrective action per procedures TBE-1010, "Nonconformance Controls" and TBE-1012, "Corrective and Preventive Action".

Note the non-conformance number on the complaint form.

5.2 Client Feedback and Follow Up 5.2.1 Client feedback is requested via a survey that can be accessed through a link included on client correspondence (primarily email) and on the TBE website.

5.2.2 Survey results are sent directly to the QA Manager, who will document the feedback. A summary is generated for the Lab Manager and Project Manager(s) for discussion and any follow up needed. Any opportunities for improvement are documented on Form Downloaded or Printed copies are UNCONTROLLED copies

EA 21-01 Paqe 7 of 9 Number: TBE-1016 Revision: 4 Procedure Issue Date: 11/10/06 Revision Date: 08/02/2021 Responsible Individual: Quality Assurance Manaqer Next Review Date: 08/02/2024

Subject:

Documentation of Customer Complaints KQA-21 with a target completion date of 1 month. The QA Manager tracks the progress and retains all associated records.

5.2.3 The Lab Manager communicates survey results to staff as appropriate.

5.2.4 A summary and evaluation of effectiveness is included in the Annual Management Report 6.0 CRITERIA, CHECKLISTS AND STANDARDS 6.1 N/A 7.0 DATA RECORDS MANAGEMENT 7.1 See procedure TBE-1003, "Control and Retention of Quality Assurance Records".

8.0 QA/QC 8.1 QA/QC is as stated in the procedure.

9.0 REFERENCES

9.1 TBE-ES QA Manual, current revision.

9.2 TBE-1003 "Control and Retentio11 of QA Records", current revision.

9.3 TBE-1007 "Training, Qualification and Certification of Personnel", current revision.

9.4 TBE-1010 "Nonconformance Controls", current revision.

9.5 TBE-1012 "Corrective and Preventative Action", current revision.

9.6 The NELAC Institute "TNI Standard EL-V1 M2-2016-Rev2.1" Volume 1, Module 2: Quality Systems Requirements, 2016.

9.7 International Standard ISO/IEC 17025 "General Requirements for the Competence of Testing and Calibration laboratories", 3rd Edition, 2017.

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EA 21-01 p a~e 9 0 f9 Number: TBE-1016 Revision: 4 Procedure Issue Date: 11/10/06 Revision Date: 08/02/2021 Responsible Individual: Quality Assurance Manaqer Next Review Date: 08/02/2024

Subject:

Documentation of Customer Complaints ATTACHMENT B - KQA-21 PREVENTIVE ACTION FORM PANO.:

Initiator Name: I Date:

Identified Through (check one): D Daily Operations D Management Review D Customer Feedback D Audit D Other/ )

Description of Problem Area:

AF Description of Possible Solution (if available):

Assigned to:

T To be completed by Quality Assurance Manqer Solution approval signatures required from:

I Priority : 0 High O Medium D Low I Date:

Comments:

R To be completed bv Assianee (Attach additional information as necessarv)

Relevant background information collected? D Yes I Existing processes investigated and understood? D Yes D

Summary of Proposed Solution:

Documents Requiring Update:

Solution approval signatures To be completed bv Qualitv Assurance Manaaer Documentation Updated? D Yes Has the solution been effective? Yes No Date Closed :

I I Closing Comments: (If the solution has not been effective, reference the new preventative action form to readdress the problem area.)

KQA21 RevO 11/18/18 Downloaded or Printed copies are UNCONTROLLED copies

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