ML23060A073

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Annual Radiological Environmental Operating Report
ML23060A073
Person / Time
Site: La Crosse  File:Dairyland Power Cooperative icon.png
Issue date: 02/27/2023
From: Hazelhoff A
LaCrosseSolutions
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LC-2023-0004
Download: ML23060A073 (1)


Text

LACROSSE~ SOLUTIONS

10 CFR 50.36(a)(2)

February 27, 2023 LC-2023-0004

U.S. uclear Regulatory Commission ATTN: Do cument Control Desk Washington, DC 20555-0001

La Crosse Boiling Water Re actor Facility Operating License o. DPR-45 NRC Docket Nos. 50-409 and 72 - 046

Subject:

La Crosse Boiling Water Reactor (LACBWR) Annual Radiological Environmental Operating Report

In accordance with the Quality Assurance Program Description (QAPD), Appendix C, Section 2.5.1, " Annual Radiological Environmental Monitoring Report," and Section 2. 5.2, " Annual Radioactive Effluent Release Report, " this letter submits the 2022 reports for Facility Operating License No. DPR-45 and the Independent Spent Fuel Storage Installation. The reports are required to be submitted prior to March 1 per the QAPD reporting requirements. The 2022 Annual Radiological Environmental Operating Report, whic h includes the Radiological Environmental Monitoring Report and the Radioactive Effluent Release Report, is provided as Attachment I to this letter.

There are no new regulatory commitments in thi s submittal.

If you have any questions about this submittal, please contact me at (269) 370-7445.

Respectfully,

Amy Hazelhoff Vice President, Regulatory Affairs

Attachment:

2022 Annual Radiological Environmental Operating Report for the LaCrosse Boiling Water Reactor (LACBWR)

cc : Marlayna Doell, U.S. NRC Project Manager Regional Administrator, U.S. RC, Region III La Crosse Boiling Water Reactor Service List (without attachments)

S4601 State Highway 35, Genoa, WI 54632 J-E2-5 ;J ()1 5 5 :z6*

MS)

La Crosse Boilin g Water Reactor Service List cc:

Ken Robuck Mark Paulson, Manager President and CEO Radiation Protection Section Energy Solutions Bureau of Environmental and Occupational 299 South Main Street, Suite 1700 Health Division of Publi c Health Salt Lake City, UT 84111 Wisconsin Department of Health Services P.O. Box 2659 John Sauger Madison, WI 53701-2659 President and C O Reactor D&D Energy Solutions Brent Ridge 121 W. Trade Street, Suite 2700 President and CEO Charlotte, NC 28202 Dairyland Power Cooperative 3200 East A ve nue South Joseph Nowak La Crosse, WI 54602-081 7 General Manager LaCrosseSolutions Cheryl Olson, ISFSI Manager S4601 State Highway 35 La Crosse Boilin g Water Reactor Genoa, WI 54632-8846 Dairyland Power Cooperative S4601 State Highway 35 Amy Hazelhoff P.O. Box 817 VP Regulatory Affairs Genoa, WI 54632-8846 Energy Solutions 121 W. Trade Street, Suite 2700 John Henkelman Charlotte, NC 28202 Licensing Engineer La Crosse Boiling Water Reactor Russ Workman Dairyland Power Cooperative General Counsel S4601 State Highway 35 Energy Solutions P.O. Box 817 299 South Main Street, Suite 1700 Genoa, WI 54632-8846 Salt Lake City, UT 84 111

Jerome Pedretti, Clerk Town of Genoa E860 Mundsack Road Genoa, WI 54632

Jeffery Kitsembel Di vision of Energy Regulation Wisconsin Public Service Commission P.O. Bo x 7854 Madison, WI 53707-7854 Attachment 1

2022 Annual Radiological Environmental Operating Report for the Lacrosse Boiling Water Reactor (LACBWR)

24 Pages Fo ll ow LACROSSE~ SOLUTIONS

2022 ANNUAL RADIOLOGICAL ENVIRONMENTAL

OPERATING REPORT FOR THE LACROSSE BOILING

WATER REACTOR (LACBWR)

DATE: 02/17/2023

Digitally signed by Scott Zoller DN: C=US, OU=D&D Decommissioning,

Scott O=E nerg ysolutions, C N=Scott Zoller, APPROVED BY: E=sgzo ller@energysolutions.com Reas o n : I am approving this document Location:

Zoller

  • IDate: 2023-02-23 07 :50 :11 Foxit Pha ntom PDF Version : 9.4.1

Page 1 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

FOR THE LA CROSSE BOILING WATER REACTOR (LACBWR)

(February 09, 2022 to January 01, 2023)

LACROSSESOLUTTONS S4601 STATE HIGHWAY 35 GENOA; WI 54632

Page 2 of 24 TABLE OF CONTENTS

SECTION A: RADIOACTIVE EFFLUENT REPORT

Section Title

Introduction................................................................................. 6 1.0 Regulatory Limits........................................................................ 8 2.0 Effluent Release Concentration Limit.......................................... 10 3.0 Average Energy.......................................................................... 10 4.0 Analytical Methods...................................................................... 10 5.0 Releases...................................................................... 1 *************** 11 6.0 Abnormal Releases.................................................................... 11 7.0 Estimated Total Analytical Error................................................. 11 8.0 Offsite Dose Calculation Summary and Conclusions.................. 12 9.0 Offsite Dose Calculation Manual (ODCM) Review...................... 13 10.0 Process Control Program (PCP) Review.................................... 13 11.0 Errata Data................................................................................. 13

Page 3 of 24 SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

Section Title Page

Introduction.................................................................... :............ 16 1.0 Sample Collection....................................................................... 17 2.0 Results of the 2022 Radio-Environmental Monitoring Survey..... 17 3.0 Conclusions................................................................................ 18 4.0 lnterlaboratory Comparison Program Results............................. 19

SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT Figure No. Title Page

1 LACBWR Property Map.............................................................. 20

2 ISFSI Environmental TLD Locations.......................................... 21

SECTION B: RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

Table No. Title Page

1 ISFSI Environmental TLD Locations......................................... 22 2 Sample Frequency and Analysis of Radio Environmental Samples 23 3 Quarterly Environmental TLD Results for ISFSI Area 24

Page 4 of 24 Radioactive Effluent Report

SECTION A

RADIOACTIVE EFFLUENT

REPORT

Page 5 of 24 Radioactive Effluent Report

INTRODUCTION

The La Crosse Boiling Water Reactor (LACBWR), also known as Genoa Station No. 2, was located on the east bank of the Mississippi River near Genoa, Vernon County, Wisconsin. The plant was designed and constructed by the Allis-Chalmers Manufacturing Company. It was completed in 1967 and had a generation capacity of 50 MW (165 MW (th))- The reactor is owned by Dairyland Power Cooperative (DPC).

The reactor went critical in July 1967 and first contributed electricity to the DPC system in April 1968. After completing full power tests in August 1969, the plant operated between 60% and 100% full power, with the exception of plant shutdowns for maintenance and repair until 1987.

In April of 1987 plant operation was ceased. The reactor was defueled and placed in a SAFSTOR mode. In August of 1987 a possession-only license was received. In 2007 the reactor vessel was removed from the site and buried at the Barnwell waste repository. In 2012 all spent fuel was placed in dry storage and placed at the LACBWR Independent Spent Fuel Storage Installation (ISFSI).

In June of 2016 DPC, working with the selected decommissioning contractor LaCrosseSolutions LLC, transferred their NRC License to LaCrosseSolutions LLC for the purposes of decommissioning the site to unconditional release criteria, per the I

license termination plan. At the conclusion of CY 2~18 all facilities inside the radiological restricted area were demolished and the contents placed into radioactive waste shipping containers. The focus in CY 2019 was to finish minor decommissioning work in the radiologically restricted area as needed, complete the final status surveys for the LACBWR site, and demobilize equipment and personnel. As of October 2019, all LACBWR site field decommissioning work was completed including final status surveys (FSS) and Oak Ridge Associated Universities (ORAU) independent verification of final status surveys at NRC direction.

Page 6 of 24 Radioactive Effluent Report

In accordance with LC-RP-PG-004, "Radiological Environmental Monitoring Program and Preparation of the Annual Radiological Environmental Operating Report," this document provides the Annual Radiological Environmental Operating Report (AREOR) for the Period February 09, 2022 through January 01, 2023. All LACBWR site required effluent and environmental monitoring, other than for the LACBWR ISFSI, has been terminated as of October 2019. The termination of environmental monitoring followed completion of both the final status surveys field work and independent verification survey field work by ORAU of the radiologically restricted area.

Page 7 of 24 Radioactive Effluent Report

EFFLUENT AND WASTE DISPOSAL REPORT

(Supplemental Information)

FACILITY: La Crosse Boillnq Water Reactor LICENSEE: LaCrosseSo/utions

LICENSE NO. DPR-45

DOCKET NO. 50-409 & 72-046

1.0 REGULATORY LIMITS

1.1 Airborne Effluent Release Limits:

LACBWR airborne particulates, with hatf-lives greater than 8 days, released to areas

beyond the Effluent Release Boundary shall be limited to</= 7.5 mRem to any organ

per calendar quarter and </= to 15 mRem to any organ per calendar year( 10 CFR 50

Appendix I). The cumulative dose contributions from airborne particulate effluent

releases are determined in accordance with the LaCrosseSolutions, LLC Offsite Dose

Calculation Manual (ODCM) and consideration of 10 CFR 20 Appendix B Table 2

Column 1 concentration values. Additionally, gaseous effluents of beta radiation in the

form of tritium, beyond the Effluent Release Boundary, shall be limited to 10 mRad per

calendar quarter and 20 mRad per calendar year (10 CFR 50 Appendix I).

Also, in accordance with the provisions of 40 CFR 190, the restrictions for total dose to

any member of the public from all LACBWR related sources and dose* pathways are

evaluated quarterly and on an annual basis during active decommissioning. No

samples for airborne radioactivity were obtained in 2022 since active decommissioning

ceased in 2019.

1.2 Liquid Effluent Release Limits:

LACBWR's liquid effluent release limitations are those concentrations specified in 10

CFR 20 Appendix B, Table 2, Column 2. The values reported are either based on

dilution of the effluent with the Genoa Station No. 3 condenser cooling water flow or no

, Page 8 of 24 Radioactive Effluent Report

condenser cooling water flow prior to discharge to the Mississippi River. No credit is

taken for further dilution in the mixing zone of the Mississippi River.

Also, in accordance with 10 CFR 50, Appendix I, the dose commitment to a member of

the public from radioactive materials released in liquid effluents to areas beyond the

Effluent Release Boundary are limited to less than 1.5 mRem whole body and 5.0

mRem organ dose per calendar quarter, and less than 3.0 mRem whole body and 10

mRem organ dose per calendar year via the critical ingestion pathway. The cumulative

dose contributions from liquid effluent releases are determined in accordance with the

LaCrosseSo/utions, LLC Offsite Dose Calculation Manual.

In accordance with the provisions of 40 CFR 190, the restrictions for total dose to any member of the public from all LACBWR related sources and dose pathways are '

evaluated quarterly and on an annual basis during active decommissioning. There

were no liquid discharges from the LACBWR site in 2022, and no monitoring or

sampling was performed.

1.3 Solid Radioactive Waste

All solid radioactive wastes are handled in accordance with a Process Control Program

as defined by LaCrosseSo/utions, LLC procedures, in order to assure that all

applicable transportation and burial site disposal requirements are met. There were no

shipments of radioactive waste in 2022.

Page 9 of 24 Radioactive Effluent Report

2.0 EFFLUENT RELEASE CONCENTRATION LIMIT

The Liquid Effluent Release Concentration used to calculate permissible release rates are obtained from 10 CFR 20, Appendix B, Table 2, Column 2.

3.0 AVERAGE ENERGY The release rate limits for LACBWR are not based on average energy.

4.0 ANALYTICAL METHODS

4.1 Liquid Effluents

Liquid effluent measurements for gross radioactivity are performed by HPGe gamma

isotopic analysis of representative samples from each monitor tank or pump down

release prior to discharge. In addition, each batch monitor tank or pump down sample

is analyzed for tritium activity concentrations using site approved bench top analysis

equipment. A composite sample is created by collecting representative aliquots from

(

each tank batch or pump down release discharged during a calendar quarter. This

composite is analyzed for: lron-55, Strontium-90, Nickel-59, Nickel-63, Americium-

241, Plutonium-238, Plutonium 239/240, and Plutonium -241 by an off-site contractor

on a quarterly basis. 1

4.2 Airborne Particulates

Airbom_e particulate releases are determined by HPGe gamma isotopic analysis and

gross beta and gross alpha analyses of glass fiber filter paper taken from four low

volume air samplers placed either in prevailing downwind locations or in

representative sampling locations on HEPA exhaust systems. The filter paper is changed out weekly and analyzed approximately one week later.

Page 10 of 24 Radioactive Effluent Report

5.0 RELEASES 5.1 Airborne To demonstrate compliance with the limits in Section 1.1 dose contributions have been calculated using a bounding assessment as described in Regulatory Guide 1.21. This analysis is summarized in the current Offsite Dose Calculation Manual. Routine low volume air sampling is in place at four locations outside the RCA in the predominant typical downwind locations, to be used to demonstrate compliance with dose limits in Section 1.1 during remediation activities. Any HEPA system exhausting to the outside environment has representative air sampling performed of the exhaust air following passing thru the HEPA system also for the purposes of demonstrating compliance with Section 1.1 during remediation activities. No monitoring for airborne activity was performed in 2022 since all LACBWR site required effluent and environmental monitoring, other than for the LACBWR ISFSI, has been terminated as of October 2019.

5.2 Liquid All liquid effluent releases at LACBWR are batch releases or pump down releases as described in the ODCM. No liquid effluent was released in-2022.

6.0 ABNORMAL RELEASES There were no abnormal releases of radioactivity in plant effluents which exceeded release limits.

7.0 ESTIMATED TOTAL ANALYTICAL ERROR

There is no estimated error in this report.

Page 11 of 24 Radioactive Effluent Report

8.0 OFFSITE DOSE CALCULATIONS

SUMMARY

AND CONCLUSIONS:

8.1 Particulate/Gaseous Effluent Releases

The maximum quarterly offsite dose to any organ from the release of all radionuclides

in particulate form with half-lives greater than 8 days was 0 mRem. The cumulative

2022 annual maximum organ dose from these radionuclides was also 0 mRem. The

maximum quarterly offsite dose from gaseous beta emitters in the form of tritium is

0 mRad/quarter and overall for the year released a total of 0 mRad.

8.2 Liquid Effluent Releases

The maximum quarterly organ dose from liquid releases was 0 mRem. The

cumulative 2022 annual organ dose was 0 mRem. The maximum quarterly total body

dose for liquid releases was 0 mRem, and the cumulative 2022 annual total body dose

' I was 0 mRem.

8.3 Conclusion

All calculated offsite doses were below all ODCM limits for airborne and liquids releases for CY 2022. _,..

Page 12 of 24 Radioactive Effluent Report

9.0 OFFSITE DOSE CALCULATION MANUAL (ODCM) REVIEW

No revisions were made to the ODCM in 2022.

I

10.0 PROCESS CONTROL PROGRAM (PCP) REVIEW

The LaCrosseSolutions, LLC PCP was not revised in 2022.

11.0 ERRATA DATA

A typographical error was noted in the 2021 LACBWR ARE OR, Table 3, "Quarterly

Environmental TLD Results for ISFSI Area." For the fourth quarter of 2021, Station

Location No. 5 was recorded as 37 mrem for the period when the completed TLD form

and raw data provide a dose of 47 mrem. The increase of Station Location No. 5 from

37 to 47 mRem does not result in a change in the maximum Whole Body Dose for

2021.

The following is a corrected Table 3 from the ?021 LACBWR AREOR:

Page 13 of 24 Radioactive Effluent Report

TABLE 3 QUARTERLY ENVIRONMENTAL TLD RESULTS FOR ISFSI AREA JANUARY 2021-FEBRUARY 09,2022

STATION NO. 1st QUARTER 2nd QUARTER 3rd QUARTER 4' Quarter mRem mRem mRem mRem 1 </=BKG 3.0 2.0 5.0

2 24.0 20.0 20.0 37.0

3 73.0 77.0 70.0 67.0

4 16.0 15.0 13.0 6.0

5 21.0 25.0 26.0 47.0

6 (*) </=BKG 0.01 0.01 0.04

7(*) 0.01 0.02 0.01 0.06

8 (*) 0.02 0.03 0.02 0.05

9 (*) </=BKG 0.02 0.02 </=BKG

10 (*) 0.02 0.05 0.04 0.07

ALL BACKGROUND CORRECTED AND THOSE ON OWNER CONTROLLED AREA FENCE LINE IDENTIFIED WITH(*) HAD OCCUPANCY FACTOR CORRECTION APPLIED IF> BACKGROUND TLD RES UL TS

Page 14 of 24 Radioactive Effluent Report

SECTION B

ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

Page 15 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

INTRODUCTION:

The Radiological Environmental Monitoring (REM) Program is conducted to comply with the

requirements of the ODCM and in accordance with 10 CFR 50 Part 50.36a and 10 CFR

72. 104. The REM Program provides measurements of radiation and of r':'dioactive materials

in those exposure pathways and for those radionuclides which could potentially lead to

radiation doses to Members of the Public resulting from plant effluents. Environmental

samples were taken within the surrounding areas of the plant and in selected background

locations.

The monitoring program at the LACBWR facility includes monitoring of liquid and airborne

particulate releases from the plant, as well as collecting environmental samples of surface air,

river water, river sediment, and c}mbient radiation.

The REM program therefore supplements the Radioactive Effluent analyses by verifying that

the measurable concentrations of radioactive materials and levels of radiation are not higher

than expected on the basis of the effluent measurements and modeling of the environmental

exposure pathways using the methodology of the Offsite Dose Calculation Manual (ODCM).

  • An lnterlaboratory Comparison Program is provided to ensure that independent checks on

the precision and accuracy of the measurements of radioactive material in environmental I

samples are performed.

All LACBWR site required environmental monitoring, other than for the LACBWR ISFSI, has

been terminated as of October 2019. The termination of environmental monitoring followed

completion of both the final status surveys field work and indifpendent verification survey field

work by ORAU of the radiologically restricted area.

Page 16 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

1.0 SAMPLE COLLECTION

Environmental samples are collected from the area surrounding LACBWR at the frequencies outlined in the ODCM and the Environmental Monitoring Program. A

series of figures and tables are included in this report to explain the LACBWR

environmental program in 2022.

FIGURE 1 This map includes the plant exclusion boundary, roads, other

generation plants, and the relationship of the plant to the nearest

local community.

FIGURE 2 This map shows the location of ISFSI environmental TLDs.

TABLE 1 This table logs the environmental TLD locations at ~e ISFSI.

TABLE 2 This table shows the sampling frequency of the various

environmental samples and the analyses performed on these

samples

TABLE 3 Quarterly Environmental TLD results for ISFSI Area

2.0 RESULTS OF THE 2022 ENVIRONMENTAL MONITORING SURVEYS

During 2022, activity levels in the local environment were trending normal.

Page 17 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

2.1 PENETRATING RADIATION

The environmental penetrating radiation dose is measured by environmental TLDs.

2.1.1 ISFSI - These environmental TLDs are exchanged hn a quarterly basis.

Table 3 summarizes the results for 2022. Please note that due to supplier issues, the environmental TLDs were not exchanged in the fourth quarter of 2021 until February 09, 2022. As such, the dose associated with the first quarter of 2022 is the period between February 09, 2022 and April 01, 2023.

2.2 AIR PARTICULATE

Air samples were collected continuously from various sites around LACBWR during

decommissioning. Low volume particulate air samplers were used to collect air

samples. The air filter consists of a glass fiber filter with an associated pore size of

approximately 0.45 µm. The particulate filters were analyzed bi-weekly for gross beta

activity with an internal proportional counter, as well as analyzed by gamma

spectroscopy for individual isotopic concentration. No air sampling was conducted in

2022.

2.3 RIVER WATER

River water is collected semi-annually. River water samples before the intake

structure, at plant outfall, and below the plant outfall are collected and are gamma

analyzed for isotopic concentration and tritium analysis. No samples of river water

were collected in 2022.

2.4 SEDIMENT SAMPLES

Sediment samples were collected semi-annually before the intake structure, at plant

outfall, and below the plant outfall. These samples were analyzed via gamma

~pectroscopy. No sediment samples were collected in 2022.

3.0 CONCLUSION

S Page 18 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL: MONITORING REPORT

All environmental samples collected and analyzed during 2022 exhibited no significant contribution from LACBWR or ISFSI operations. Also, in accordance with 40 CFR 190

requirements, all pathway doses to the environment for LACBWR Site for calendar

year 2022 were evaluated and the summary for CY 2022 is:

Whole Body Dose: 0.10 mRem which is 0.4% of the annual limit.

4.0 INTERLABORATORY COMPARISON PROGRAM RESULTS

No interlaboratory comparison samples were analyzed in 2022, as the onsite

laboratory was demobilized from the site in October of 2019.

Page 19 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

FIGURE 1 - LACBWR PROPERTY MAP

I I

I

11.L a:oct<' I' T a DAIii tro.1/

I I

I

,.,Je., ' i LOT\\-

!IJ lit. 29 28 32 33 -. -

LOcATION-MAP '-'-'. EXC.VSION-l0UmW

1000 1100 ft radiw l C SQO /4 11:0MI I SCA!.£ OF FEET

  • 1::10,-N.. ~3:w.

OF THE 5th.. P.M.

SEC. 7

l:*13-N., R.-7-W.

OF THE 41 th P.lc\\.

n>WN OF GEN~

VERNON COUNTY1 WISCONSIN

LOT l LOT 4 " WELL

[1 ISLANt> IH JS UMOEII tlC

.IURII DICTION DI' UPPl fl MISSISSIPPI RIVOi Wll.0 ll*ti'U IN81CA1U... Lll AIOYt tit[ urc AtCD FISH 11["'11[.

MOU1tt OF 1Ht OK~ IIIYEII.

Page 20 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

FIGURE 2 - ISFSI ENVIRONMENTAL TLD LOCATIONS

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aAa..,,. IOO,,al...0- I'

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Page 21 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

TABLE 1

ISFSI ENVIRONMENTAL TLD LOCATIONS LOCATION* LOCATION..

NO.,_

1 ISFSI ADMINISTRATIVE BUILDING WEST

2 ISFSI PROTECTED AREA NORTH EAST SIDE

3 ISFSI PROTECTED AREA NORTH WEST SIDE

4 ISFSI PROTECTED AREA SOUTH WEST SIDE

5 ISFSI PROTECTED AREA SOUTH EAST SIDE I

6 ISFSI OWNER CONTROLLED FENCE NORTH

7 ISFSI OWNER CONTROLLED FENCE WEST

8 ISFSI OWNER CONTROLLED FENCE EAST

9 ISFSI OWNER CONTROLLED FENCE NORTH EAST BY HEAVY HAUL PATH 10 ISFSI OWNER CONTROLLED FENCE WEST BY BOAT LANDING

Page 22 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

TABLE 2

SAMPLE FREQUENCY AND ANALYSIS OF RADIOLOGICAL ENVIRONMENTAL SAMPLES

SAMPLE FREQUENCY ANALYSIS PERFORMED

Environmental TLDs Quarterl'y Dose in mRem

Particulate Air - Glass Bi-Weekly Gross Beta and Gamma Fiber Filters Spectroscopy

River Sediment Semi-annually Gamma Spectroscopy

River Water Semi-annually Gamma Spectroscopy and Tritium (Liquid Scintillation Analyzer)

NOTE:

All LACBWR site required effluent and environmental monitoring, other than for the

LACBWR ISFSI, has been terminated as of October 2019. The termination of

environmental monitoring followed completion of both the final status surveys field work

and independent verification survey field work by ORAU of the radiologically restricted

area.

Page 23 of 24 ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

TABLE 3 QUARTERLY ENVIRONMENTAL TLD RESULTS FOR ISFSI AREA February 09, 2022 - January 01,2023

STATION NO. 1st QUARTER 2nd QUARTER 3rd QUARTER 4TH Quarter mRem mRem mRem mRem 1 </=BKG </=BKG 1.0 2.0

2 13.0 20.0 22.0 20.0

3 41.0 64.0 75.0 61.0

4 9.0 15.0 15.0 15.0

5 17.0 23.0 25.0 24.0

6 (*) </=BKG 0.02 0.05 0.02

7(*) </=BKG 0.02 0.01 0.02

8 (*) 0.01 0.01 0.02 0.03

9 (*) 0.01 0.02 0.02 0.02

10 (*) 0.02 0.02 0.03 0.03

ALL BACKGROUND CORRECTED AND THOSE ON OWNER CONTROLLED AREA FENCE LINE IDENTIFIED WITH(*) HAD OCCUPANCY FACTOR CORRECTION APPLIED IF> BACKGROUND TLD RESULTS

Page 24 of 24