Text

2022 Radiological Environmental Operating Report
	ML23108A044
Person / Time
Site:	Palisades
Issue date:	04/18/2023
From:	Fleming J; Holtec Decommissioning International
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	HDI PNP 2023-008
	Download: ML23108A044 (1)
	v • d • e

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTEC Telephone (856) 797-0900 DECOMMISSION I NG Fax (856) 797-0909 INTERNATIONAL HDI PNP 2023-008 Technical Specification 5.6.2 April 18, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket Nos. 50-255 and 72-007 Renewed Facility Operating License No. DPR-20

Subject:

2022 Radiological Environmental Operating Report In accordance with the requirements of Palisades Nuclear Plant (PNP) Defueled Technical Specifications Section 5.6.2, Radiological Environmental Operating Report, Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades, LLC (Holtec Palisades) is submitting the 2022 Radiological Environmental Operating Report for PNP. The report was prepared in accordance with the requirements of 10 CFR 50, Appendix I, Section IV.B and 1V.C. The period covered by the enclosed report is January 1, 2022, through December 31, 2022 This letter contains no new and no revised regulatory commitments.

Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Engineer at (269) 764-2945.

Respectfully, Digitally signed by Jean A.

Fleming Jean A. Fleming Date: 2023.04.18 08:44:51

-04'00' Jean A. Fleming Vice President, of Licensing, Regulatory Affairs & PSA Holtec International

Enclosure:

Palisades Nuclear Plant Annual Radiological Environmental Operating Report cc: NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant

Enclosure to HDI PNP 2023-008 Palisades Nuclear Plant Annual Radiological Environmental Operating Report 49 Pages Follow

HOL TE C 1

~NTER . ATIO . AL Page 1 of 49 Plant: Palisades YEAR: 2022 Document Number: 2023-008 Annual Radiological Environmental Operating Report

Plant: Palisades I Year: 2022 I Page 2 of 49 Annual Radiological Environmental Operating Report TABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

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

2.0 INTRODUCTION

........................................................................................................................4 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS ......................5 4.0 INTERPRETATION AND TRENDS OF RESULTS ....................................................................13 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

..........................21 ATTACHMENTS - Sample Deviations ........................................................................................................27 - Monitoring Results Tables ............................................................................................29 - Interlaboratory Comparison Program Results ............................................................... 47

Plant: Palisades I Year: 2022 I Page 3 of 49 Annual Radiological Environmental Operating Report 1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report presents data obtained through analyses of environmental samples collected for Palisades Radiological Environmental Monitoring Program (REMP) for the period January 1 through December 31, 2022. This report fulfills the requirements of Palisades Technical Specification 5.6.2.

No measurable levels of radiation above baseline levels attributable to Palisades operation were detected in the vicinity of Palisades in 2022. The 2022 REMP thus substantiated the adequacy of source control and effluent monitoring at Palisades with no observed impact of plant operations on the environment.

Palisades established the REMP prior to the station becoming operational to provide data on background radiation and radioactivity normally present in the area.

Palisades has continued to monitor the environment by sampling air, water, sediment, broad leaf vegetation, fish, and food products, as well as measuring direct radiation.

Palisades also samples milk if milk-producing animals used for human consumption are present within five miles (8 km) of the plant. All analyses have required, nuclide specific, lower limit of detections (LLDs) which must be achieved. The requirements of the REMP are formally described in the offsite dose calculation manual (ODCM), a site specific regulatory document.

The REMP includes sampling indicator and control locations. The REMP utilizes indicator locations near the site to determine if any increases of radioactivity has occurred due to station operation and control locations farther away from the site to indicate the presence of only naturally occurring radioactivity. Palisades personnel compare indicator results with control and preoperational results to assess any impact Palisades operation might have had on the surrounding environment.

In 2022, REMP samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. All 2022 REMP results support the conclusion that the surrounding environment is not adversely affected by Palisades effluents. No activity in any REMP sample from 2022 was attributed to Palisades effluents.

1.2 Reporting Levels No samples equaled or exceeded reporting levels.

1.3 Sample Deviations During 2022, environmental sampling was performed for eight media types (airborne, surface water, drinking water, offsite groundwater, sediment, broad leaf vegetation, fish, and food products) and analyzed for direct radiation. All REMP samples were obtained as required by the ODCM in 2022 apart from seven instances of sample deviations which are further discussed in Attachment 1 Table 8.

Plant: Palisades I Year: 2022 I Page 4 of 49 Annual Radiological Environmental Operating Report 1.4 Program Modifications The REMP was modified slightly in 2022. All changes were made via the Offsite Dose Calculation Manual (ODCM) change process (Technical Specification 5.5.1 c.).

The changes included updating the LLD value for Zr-95 in water (to 30 pCi/L in accordance with regulatory guidance), and a change to some of the direct radiation measuring stations (discussed in more detail in section 4.2). As required by the ODCM change process, the revised ODCM is included in the 2022 Annual Radioactive Effluent Release Report (ARERR).

2.0 INTRODUCTION

2.1 Radiological Environmental Monitoring Program Palisades established the REMP, as defined in the ODCM, to fulfill 10 CFR Part 50 Appendix I Section IV.B.2. The REMP supplements the radiological effluent monitoring program by verifying that the concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

2.2 Pathways Monitored The airborne, direct radiation, waterborne and ingestion pathways are monitored as required by Palisades ODCM. These requirements are also listed in this report in Table 1 through Table 4.

Section 4.0 of this report provides a discussion of 2022 sampling results and Section 5.0 providing a summary of results for the monitored exposure pathways.

2.3 Land Use Census Palisades conducts a land use census annually to identify changes in uses of land within five miles of the site that would require modifications to the REMP and the ODCM. The purpose of this census is to identify critical receptor pathways for the purpose of effluent modeling and REMP sampling.

Plant: Palisades Year: 2022 Page 5 of 49 Annual Radiological Environmental Operating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway - Airborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency RADIOIODINE AND PARTICULATES x A8 (0.595 miles NE) - onsite Continuous sampler operation I-131 analysis weekly for each filter change.

near state park with sample collection every week, Six samples total. Four samples from within 6 or more frequently if required by Gross beta radioactivity analysis weekly for each km (3.7 miles) of the site boundary in different x A19 (0.423 miles SSE) - dust loading. filter change.

sectors. One sample from the vicinity of a onsite near Bluestar Hwy community having the highest calculated Gamma isotopic analysis quarterly for a composite of annual average ground level deposition factor. x A9 (1.525 miles SSW) - offsite all filters collected.

One control sample in the least prevalent wind near blue star highway IF filter gross beta is greater than 10 times the yearly direction (considering practical direction and x A4 (3.882 miles SE) - offsite in mean of the control sample THEN gamma isotopic is distance). Covert township performed on the filter.

x A5 (3.590 miles ESE) - offsite in Covert township x A10 (50.765 miles NE) -

offsite near Grand Rapids

Plant: Palisades Year: 2022 Page 6 of 49 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS x TLD-1 (0.213 miles E) - onsite Quarterly Gamma dose (units of milliRoentgen, abbreviated mR)

I 21 routine monitoring stations either with two inner ring TLD quarterly or more dosimeters or with one instrument for x TLD-8 (0.602 miles NE)- inner ring measuring and recording dose rate TLD continuously, placed as follows:

x TLD-13 (0.530 miles NNE) - inner One onsite TLD in the vicinity of the facility. ring TLD An inner ring of stations consisting of one in each overland meteorological sector in the x TLD-14 (0.551 miles NE)- inner general area of the site boundary and one ring TLD additional location near the State Park x TLD-15 (0.834 miles ENE)- inner camping area in the NE sector.

ring TLD An outer ring of stations one in each overland x TLD-16 (0.804 miles E)- inner ring meteorological sector within the 12 km range TLD from the site.

x TLD-17 (0.572 miles ESE) - inner One control TLD between 25 and 55 miles from the site. ring TLD x TLD-18 (0.469 miles SE) - inner ring TLD x TLD-19 (0.443 miles SSE)- inner ring TLD x TLD-20 (0.412 miles S)- inner ring TLD x TLD-21 (0.382 miles SSW) - inner ring TLD

Plant: Palisades Year: 2022 Page 7 of 49 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency x TLD-2 (5.560 miles S) - outer ring Quarterly Gamma dose (units of milliRoentgen, abbreviated mR)

TLD quarterly x TLD-3 (5.684 miles SSE) - outer ring TLD x TLD-4-21 (3.882 miles SE) - outer ring TLD x TLD-5-21 (3.590 miles ESE) -

outer ring TLD x TLD-6 (5.314 miles NE) - outer ring TLD x TLD-7 (4.115 miles NNE) - outer ring TLD x TLD-9-21 (1.525 miles SSW) -

outer ring TLD x TLD-23 (3.189 miles ENE) - outer ring TLD x TLD-24 (6.021 miles E) - outer ring TLD x TLD-11-21 (28.72 miles E) -

control TLD

Plant: Palisades Year: 2022 Page 8 of 49 Annual Radiological Environmental Operating Report Table 3, Exposure Pathway - Waterborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency Lake in - Lake Michigan intake water Daily samples are used to Gamma isotopic, gross beta (not ODCM required), and SURFACE WATER used in plant systems. Sample is make a monthly composite tritium analysis monthly Lake in (plant intake lake water) collected onsite. sample.

Daily South Haven drinking Gamma isotopic, gross beta, and tritium analysis monthly water samples are used to DRINKING WATER City of South Haven drinking water make a monthly composite intake structure (5.6 miles NNE of South Haven drinking water sample.

Palisades)

Palisades Park (Pal Park) community drinking 1 grab sample of Palisades Gamma isotopic, gross beta (not ODCM required), and Pal Park community drinking water water is sampled when in operation (summer Park (Pal Park) community tritium analysis monthly when operational (0.7 miles SSW of Palisades) months) drinking water is sampled Domestic water is sampled onsite from monthly when in operation Domestic water (not ODCM required) is any potable water source, typically an (summer months). Gamma isotopic, gross beta, and tritium analysis monthly sampled onsite. eye wash station.

Daily samples are used to make a monthly composite.

Surface Water and Drinking Water Control Daily samples are used to Gamma isotopic, gross beta, and tritium analysis monthly Ludington Control - Lake Michigan make a monthly composite Lake water from Ludington Pump-house is intake water from Ludington Pump- sample.

analyzed as a control sample for drinking and house (201 km North of Palisades).

surface water.

OFFSITE GROUNDWATER 1 grab sample is sampled Gamma isotopic, gross beta, and tritium analysis monthly monthly when in operation Palisades Park (Pal Park) commercial water 0.7 miles S of Palisades (summer months) is sampled when in operation (summer months). This sample is not ODCM required.

SEDIMENT FROM SHORELINE 1 sample between the north site Semiannually Gamma isotopic analysis semiannually.

boundary and Van Buren State Park North sediment sample beach, approximately 1/2 mile north of the plant discharge.

South sediment sample (not ODCM required) 1 sample from beach near south Semiannually Gamma isotopic analysis semiannually.

boundary of site property

Plant: Palisades Year: 2022 Page 9 of 49 Annual Radiological Environmental Operating Report Table 4, Exposure Pathway - Ingestion Sample Point Description Distance Sampling and Collection Requirement Type and Frequency Of Analyses and Direction Frequency MILK For 2022 goat milk samples were not Monthly Gamma isotopic and I-131 monthly I

Samples from milking animals in 3 locations available to be sampled from the indicator locations. Therefore no control samples between 5-8km distance were obtained, and broad leaf vegetation 1 sample from milking animals at a control was sampled as described below.

location.

Broad leaf Vegetation 0.7 miles SE from Palisades. Monthly during growing Gamma isotopic and I-131 monthly during growing season season Samples of three different kinds of broad leaf vegetation grown nearest each of two different offsite locations of highest predicted 0.4 miles SSE from Palisades.

annual average ground level deposition and one sample of each of the similar broad leaf vegetation grown 15-30 km distance in the 13.6 miles NNE from Palisades.

least prevalent wind direction IF milk sample is not performed.

FISH The indicator sample is obtained from Lake Semiannually Gamma isotopic analysis semiannually I

Sample 2 species of commercially and/or Michigan onsite within a few hundred feet of the main liquid discharge point.

recreationally important species in the vicinity of the plant discharge area. The control sample is obtained from Lake Michigan near Ludington MI (201 km North 1 sample of the same species in areas not of Palisades).

influenced by plant discharge.

FOOD PRODUCTS (blueberries) 3.7 to 4.7 miles SE or ESE Annually at time of harvest Gamma isotopic and I-131 annually from Palisades 1 sample of each of two principal fruit crops (blueberries and apples). (apples) 3.5 to 3.7 miles E or SE from Palisades

Plant: Palisades I Year: 2022 I Page 10 of 49 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway GASEOUS EFFLUENT NUCLEAR POWE R PLANT LIOUIO I

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Plant: Palisades Year: 2022 Page 11 of 49 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field

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---=I Year: 2022 Annual Radiological Environmental Operating Report Page 12 of 49 Figure 3, Sample Collection Sites - Far Field N

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Plant: Palisades I Year: 2022 I Page 13 of 49 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample There were 312 air samples collected and analyzed for gross beta and I-131 during 2022. Air iodine and particulate samples are collected weekly from six air-sampling locations. Air is metered into the sampling unit through a 47-mm air filter (for particulate) and an air iodine cartridge. The filters are in series with one another and housed within the same filter holder. An "as found" and "as left" leak test is performed at each station during each sample collection.

Weekly samples were sent to Teledyne Brown Engineering Environmental Services for analysis.

Analysis of the airborne particulate sample data, between the five near-site indicator locations and the control location, validates that the surrounding environment is not adversely affected by Palisades' effluents. The average concentration of gross beta activity among all indicator locations was 2.69E-02 pCi/m3 and was 2.54E-02 pCi/m3 for the control location. All I-131 activity results, for both indicator and control locations, were below the minimum detectable activity (MDA). Gamma isotopic analysis is performed quarterly on a quarterly composite of the filter papers. All radionuclides detected (Be-7) were naturally occurring radionuclides which are not attributed to plant effluents.

Palisades pre-operational environmental study showed naturally occurring gross beta radiation between 0.03 and 3.0 pCi/m3 with a similar trend between stations onsite, in the surrounding community, and control stations. The activity results from 2022 indicate there is no measurable change between pre-operational airborne gross beta activity and present day airborne gross beta activity.

There was five REMP deviations in 2022 involving air sampling. Two of the deviations involved a tripped GFCI outlet, two of the deviations involved a seized pump, and one deviation involved a loss of power supply. Sufficient volume was obtained from all REMP air samples to perform analysis and all results were incorporated in the statistics in this report. These instances are discussed in more detail in Attachment 1 Table 8.

In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. The air sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades' effluents. No REMP air samples from 2022 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I Year: 2022 I Page 14 of 49 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results Palisades reports measured dose as net exposure (subtracting transit reading) normalized to 92 days. TLDs are oriented in an inner ring, outer ring, and control locations. The inner ring consists of 11 TLDs, the outer ring consists of 9 TLDs, and there is 1 control location. This orientation allows for monitoring all 9 overland compass sectors surrounding Palisades. To assess the effect of direct and shine radiation from Palisades to the environment the inner ring, outer ring, and control TLDs are compared to one another. Additionally, each individual TLD location is compared to a baseline of data which was created from a comprehensive review of data from 2011 through 2016. The high and low values for the baseline are based upon two standard deviations for each data point from 2011 through 2016. If a value is measured outside the baseline additional follow-up investigation is performed to evaluate the cause.

During 2021, four additional locations were added (identified as 4-21, 5-21, 9-21, and 11-21) to establish a new baseline at these locations. Starting in the first quarter of 2022, locations 4, 5, 9, 10, 11, and 12 were discontinued and locations 4-21, 5-21, 9-21, and 11-21 were implemented into the program. Essentially this resulted in a relocation of three of the outer ring TLDs, a relocation of one of the control TLDs, and a discontinuation of two control TLDs. All changes made were in accordance with the ODCM and the ODCM change process (technical specification 5.5.1 c.).

There was two REMP deviations in 2022 involving TLDs. In October, TLD number 23 was found on the ground by a member of the public and was re-installed within a few days. During collections of the 4th quarter TLDs, TLD number 24 was found on the ground about 10 feet from its designated location. The 4th quarter results for TLD 23 and 24 are recorded in Attachment 2 Table 13, but are not included in the calculations in Table 5 or Table 7 due to the deviations. These instances are also discussed in Attachment 1 Table 8.

During 2022, three of the 82 valid results trended at a value above the baseline.

These TLDs were numbers 1, 7, and 9-21 from the 4th quarter 2022. An evaluation was performed which included other TLD programs (ISFSI monitoring), REMP TLD data, other REMP data, and effluents data. The conclusion is that activity from REMP TLDs is from naturally occurring background radiation and not from Palisades' direct or shine radiation.

Table 5 shows the consistent trend of average inner ring, outer ring, and control TLDs.

TLD measurements taken as part of Palisades pre-operational environmental study used different instrumentation which had difficulty in achieving desired sensitivity and accuracy. A more sensitive type of TLD was implemented in 1971 and the present day TLD device used is the industry standard. TLD data has trended consistently throughout the several most recent independent spent fuel storage installation (ISFSI) loading campaigns which indicates these loading campaigns have had no measurable effect on the environment.

Plant: Palisades I Year: 2022 I Page 15 of 49 Annual Radiological Environmental Operating Report Table 5, Direct Radiation Annual Summary Inner Ring Control Location Year Outer Ring (mR/Qtr)

(mR/Qtr) (mR/Qtr) 2014 9.1 10.9 10.7 2015 9.5 11.2 10.9 2016 9.6 11.3 11.2 2017 9.3 11.2 10.9 2018 9.3 11.1 11.0 2019 9.4 11.2 11.0 2020 9.3 11.2 11.1 2021 9.3 11.3 11.1 2022 9.7 11.4 12.0 4.3 Waterborne Sample Results During 2022 Palisades implemented the REMP in accordance with the ODCM for collection of surface, drinking, and groundwater. For all surface, drinking, and groundwater indicator samples, the same control sample is used as a baseline for comparison. That control sample is referred to as the "Ludington Control" and is collected 201 km north of Palisades. The Ludington Control sample is analyzed monthly and is a composite of daily samples. The Ludington Control sample is analyzed for gamma radionuclide, tritium, and gross beta activity. In 2022 the only radionuclide activity detected in Ludington Control water was naturally occurring isotopes (K-40 and Th-228). Of the twelve Ludington Control samples collected in 2022, five contained detectable gross beta with an average value of 3.03 pCi/L. The gross beta activity is a result of naturally occurring radionuclide and is not attributed to Palisades effluents.

4.3.1 Surface Water The indicator surface water samples collected and analyzed for the REMP include "Lake In" water. This sample is Lake Michigan water after it has traveled through the Palisades intake structure and traveling screens. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclide and tritium onsite. This sample is also analyzed by Teledyne Brown Engineering Environmental Services for gamma, tritium, and gross beta activity. All radionuclide detected (K-40 and Th-228) were naturally occurring and are not attributed to Palisades effluents. Three out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2.66 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Plant: Palisades I Year: 2022 I Page 16 of 49 Annual Radiological Environmental Operating Report Palisades pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results for surface water showed consistently measurable results for gross beta activity between 11 - 18

(+/- 5) pCi/L.

The surface water sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP surface water samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

4.3.2 Drinking Water The indicator drinking water samples collected and analyzed for the REMP include "Domestic Water", "South Haven Drinking Water", and "Palisades Park Community Water". All samples are analyzed for gamma, tritium, and gross beta by Teledyne Brown Engineering Environmental Services.

Domestic Water is collected onsite from a potable water system. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclide and tritium onsite. All radionuclide detected (Ra-226 and Th-228) were naturally occurring and are not attributed to Palisades effluents. Three out of the twelve monthly samples contained measurable gross beta activity with the average detectable gross beta activity at 3.15 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide. Domestic water is not required by the ODCM for the REMP. This sample is collected as part of the NRC bulletin 80-10 commitments and is included in this report because the data strengthens the REMP.

South Haven Drinking Water is collected from the City of South Haven Water Treatment facility located in South Haven, MI. All radionuclide detected (Th-228) were naturally occurring and are not attributed to Palisades effluents. Three out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2.68 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades Park Community Water is collected once per month as a grab sample from a community just south of Palisades while the facility is operational (summer months).

This sample is analyzed for gamma, tritium, and gross beta activity. No radionuclide were detected from gamma spectroscopy or tritium analysis. Zero out of the six monthly samples contained measurable gross beta activity. Gross beta activity is not required by the ODCM for this sample but is performed for trending purposes and to strengthen the REMP.

Palisades pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results relied upon as a baseline for drinking water analysis are the same results as with surface water, that being consistent gross beta activity between 11 - 18 (+/- 5) pCi/L.

The drinking water sample results collected, in accordance with the REMP, support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not affected by Palisades effluents. No REMP drinking water samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

Plant: Palisades I Year: 2022 I Page 17 of 49 Annual Radiological Environmental Operating Report 4.3.3 Groundwater Palisades implements an extensive groundwater monitoring program in accordance with NEI-0707, "Industry Ground Water Protection Initiative - Final Guidance Document". This program is designed to identify onsite leaks to groundwater to allow for prompt repair or isolation of the leak. The results of the onsite groundwater program are described in the Annual Radioactive Effluent Release Report (ARERR).

Palisades samples one offsite groundwater location. This sample is not required by Palisades ODCM but is procedurally implemented to strengthen the program overall.

The REMP groundwater sample is the "Palisades Park Commercial Well Water" sample. This sample is collected once per month as a grab sample from a community just south of Palisades while the facility is operational (summer months).

This sample is analyzed for gamma, tritium, and gross beta activity by Teledyne Brown Engineering Environmental Services. In 2022, the only radionuclides detected (Th-228) were naturally occurring isotopes which are not attributed to Palisades effluents. No tritium was detected. Five out of the Six monthly samples contained measurable gross beta with the average detectable gross beta activity at 3.79 pCi/L.

The gross beta activity is attributed to naturally occurring radionuclide.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results were that five well water samples from Palisades contained gross beta activity above 5 pCi/L with the highest value being 16 pCi/L. Two samples from Covert Park well water contained gross beta activity at 6 and 7 pCi/L.

The groundwater sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades' effluents. No REMP groundwater samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

Plant: Palisades I Year: 2022 I Page 18 of 49 Annual Radiological Environmental Operating Report 4.4 Sediment Sample Results Sediment samples are collected two times per year north and south of the plant from the beach on Lake Michigan. One sample is collected at the southern edge of the property and a second sample is collected approximately 0.5 miles north of the plant.

The sample south of the plant is not required by the ODCM but is collected and analyzed to strengthen the REMP. Both the north and south sediment samples are analyzed for gamma radionuclide. In 2022, the only radionuclides detected (K-40, Th-228) were naturally occurring isotopes which are not attributed to Palisades effluents. In accordance with the ODCM, no control sample is collected for this sample type.

Soil samples were not specifically part of the Palisades pre-operational environmental study however a study of Cs-137 found in soil (due to global events such as historical atomic testing and fallout) was performed by Palisades in 2011.

Analysis was performed of soil in the surrounding area (Southwest Michigan) which showed Cs-137 concentrations between 1.41E-08 uCi/g and 5.68E-07 uCi/g with an average of 2.68E-07 uCi/g. Considering similar studies performed by other utilities, a conservative (low) background of 1.8E-07 uCi/g Cs-137 in soil is assumed to be due to global fallout.

The sediment sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP sediment samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

4.5 Ingestion Sample Results 4.5.1 Milk Sample Results Indicator milk samples were not available to be collected during 2022. In accordance with Palisades ODCM, broadleaf sampling is performed when milk sampling is not performed.

Plant: Palisades I Year: 2022 I Page 19 of 49 Annual Radiological Environmental Operating Report 4.5.2 Broad leaf Sample Results In accordance with Palisades ODCM three different kinds of broad leaf vegetation is sampled from two onsite (indicator) locations and one offsite (control) location due to the fact that milk sampling is not performed. Broad leaf samples are collected once per month during the growing season and analyzed for gamma radionuclides including iodine-131. Naturally occurring radionuclide detected in broad leaf vegetation (Be-7 and K-40) are not attributed to Palisades effluents. Cs-137 detected in broad leaf vegetation was attributed to historical global atomic testing and biological uptake. Cs-137 was detected at location BV1 (0.4 miles SSE) for four out of the five monthly samples with an average activity of 73.5 pCi/kg. Cs-137 was detected in none of the samples from location BV2 or BVC. It is not abnormal to detect Cs-137 in broad leaf samples. Palisades procedurally implements a conservative administrative action value to perform additional reviews if the activity of broad leaf samples exceeds 146 pCi/kg Cs-137. This administrative action value was developed in 2013 based upon Cs-137 trends in broadleaf samples. The absence of other more prominent radionuclides measured in the plant effluent and coolant systems further support that the Cs-137 detected in broadleaf is not a result of Palisades activity.

The pre-operational environmental study consisted in part of Cs-137 and Sr-90 analysis for crops and milk. These (and broadleaf) sample results are a result of historical global atomic testing and biological uptake. The pre-operational study identified Cs-137 in milk samples ranging from 2 to 70 pCi/L and Sr-90 ranging from 5 to 15 pCi/L. For crop samples, gross gamma activity was generally between 0.11 and 0.22 pCi/g and gross beta activity was generally between 0.72 to 3.31 pCi/g.

The broad leaf sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP broadleaf samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

4.5.3 Fish Sample Results Indicator and Control fish samples are collected and analyzed twice per year. The filet of the fish is analyzed for gamma radionuclide. The indicator fish are collected near Palisades lake-out discharge point. At least 2 species of commercial or recreational importance are collected and analyzed. At least one sample of the same species is collected as a control sample. The control fish are collected 201 km north of Palisades near Ludington, MI. In 2022, the only radionuclides detected among all fish samples were naturally occurring radionuclides (K-40 and Th-228) which were not attributed to Palisades effluents.

Palisades pre-operational environmental study established a baseline for radiological material in fish. The study established that gross beta activity is generally between 2 and 4 pCi/g and gross gamma activity is generally between 0.04 and 0.4 pCi/g in fish.

Cs-137 and Sr-90 were measured in the pre-operational study and were expected to be measured due to known worldwide contamination from historical global atomic testing. Cs-137 detected was generally between 0.10 and 0.25 pCi/g and Sr-90 detected was generally between 0.01 to 0.04 pCi/g in the pre-operational environmental study.

Plant: Palisades I Year: 2022 I Page 20 of 49 Annual Radiological Environmental Operating Report The fish sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP fish water samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

4.5.4 Food Product Sample Results Two principal fruit crops are collected once per year and analyzed for gamma radionuclides including Iodine-131 in accordance with the REMP. The two crops sampled in 2022 were blueberries and apples. The results of all sample analysis show that only naturally occurring radionuclides (K-40) were present. In accordance with the ODCM, no control sample is collected for this sample type.

Palisades pre-operational environmental study performed radiological analysis on a variety of crop samples. Gross gamma activity was generally between 0.11 and 0.22 pCi/g and gross beta activity was generally between 0.72 to 3.31 pCi/g.

The fruit sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2022. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP fruit samples from 2022 contained measurable radiological materials attributed to Palisades effluents.

4.6 Land Use Census Results The latest land use census (performed in 2022) did not identify any new locations that prompt a change to the REMP or to the atmospheric dispersion or deposition factors used for offsite dose modeling. The sectors in Table 6 include all overland compass sectors.

Table 6, Land Use Census - Nearest Residence Within Five Miles Garden Dairy Cow Goat Sector Direction Residence (miles) Beef Cattle (miles)

(miles) (miles) (miles) 2 NNE 1.67 2.52 >5 >5 >5 3 NE 1.14 2.76 >5 >5 >5 4 ENE 1.19 2.11 2.29 >5 >5 5 E 1.62 2.46 3.51 >5 3.46 6 ESE 1.35 1.66 2.04 >5 2.04 7 SE 0.87 2.20 3.88 >5 3.88 8 SSE 0.80 0.70 >5 >5 >5 9 S 0.51 3.51 >5 >5 >5 10 SSW 0.48 >5 >5 >5 >5

Plant: Palisades I Year: 2022 I Page 21 of 49 Annual Radiological Environmental Operating Report 4.7 Interlaboratory Comparison Results Attachment 3 contains result summary for Interlaboratory Comparison program for Teledyne Brown Engineering Environmental Services.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1. Table 7, Radiological Environmental Monitoring Program Summary, summarizes data for the 2022 REMP program.

Plant: Palisades Year: 2022 Page 22 of 49 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Number of Indicator Locations Location [Note 3] Control Sample Type Type / Number Mean (F)[Note 2] Reportable LLD [Note 1] Mean (F)[Note 2] [Highest Locations Mean (Units) of Analyses [Range] Occurrences

[Range] Annual Mean] (F)[Note 2] [Range] [Note 4]

Air (pCi/m3) GB / 312 0.01 2.69E-02 (260/260) Station A4 2.95E-02 2.54E-02 (52/52) 0

[5.84E 6.60E-02] (3.882 miles (52/52) [9.82E SE) [6.18E 5.53E-02]

6.60E-02]

I-131 / 312 0.07 <MDA (0/260) N/A N/A <MDA (0/52) 0 Cs-134 / 24 0.05 <MDA (0/20) N/A N/A <MDA (0/4) 0 Cs-137 / 24 0.06 <MDA (0/20) N/A N/A <MDA (0/4) 0 Sensitivity of 3 9.70 (44/44) Station 1 11.09 (4/4) 11.98 (4/4)

Inner Ring Gamma / 48 mR [8.10 - 12.01] (onsite 0.213 [10.68 - 12.01] [11.57 - 12.75] 0 TLDs (mR/Qtr) miles E)

Sensitivity of 3 11.36 (34/34) Station 2 14.43 (4/4) 11.98 (4/4) 0 Outter Ring Gamma / 38 mR [9.31 - 15.02] (5.560 miles S) [13.66 - 15.02] [11.57 - 12.75]

TLDs (mR/Qtr)

Plant: Palisades Year: 2022 Page 23 of 49 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Number of Indicator Locations Location [Note 3] Control Sample Type Type / Number Mean (F)[Note 2] Reportable LLD [Note 1] Mean (F)[Note 2] [Highest Locations Mean (Units) of Analyses [Range] Occurrences

[Range] Annual Mean] (F)[Note 2] [Range] [Note 4]

Gross Beta / 24 4.0 2.66 (3 / 12) Lake In (Plant 2.66 (3 / 12) 3.03 (5 / 12) 0

[2.35 -2.92] lake intake) [2.35 -2.92] [2.62 - 3.59]

H-3 / 24 2000 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Mn-54 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Fe-59 / 24 30 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Co-58 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Surface Water Co-60 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 (pCi/L) Zn-65 / 24 30 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Zr-95 / 24 30 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Nb-95 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Cs-134 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Cs-137 / 24 18 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 Ba-140 / 24 60 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0 La-140 / 24 15 <MDA (0 / 12) N/A N/A <MDA (0 / 12) 0

Plant: Palisades Year: 2022 Page 24 of 49 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Number of Indicator Locations Location [Note 3] Control Sample Type Type / Number Mean (F)[Note 2] Reportable LLD [Note 1] Mean (F)[Note 2] [Highest Locations Mean (Units) of Analyses [Range] Occurrences

[Range] Annual Mean] (F)[Note 2] [Range] [Note 4]

Gross Beta / 42 4 2.92 (6 / 30)

Domestic 3.15 (3 / 12) 3.03 (5 / 12) 0

[2.27 - 3.62]

Water (On-site) [2.43 - 3.62] [2.62 - 3.59]

N/A N/A <MDA (0 / 12) 0 H-3 / 42 2000 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Mn-54 / 42 15 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Fe-59 / 42 30 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Co-58 / 42 15 <MDA (0 / 30)

Drinking Water N/A N/A <MDA (0 / 12) 0 (pCi/L) Co-60 / 42 15 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Zn-65 / 42 30 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Zr-95 / 42 30 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Nb-95 / 42 15 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Cs-134 / 42 15 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Cs-137 / 42 18 <MDA (0 / 30)

N/A N/A <MDA (0 / 12) 0 Ba-140 / 42 60 <MDA (0 / 30) N/A <MDA (0 / 12)

N/A 0 La-140 / 42 15 <MDA (0 / 30)

Mn-54 / 9 130 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Fe-59 / 9 260 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Co-58 / 9 130 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Fish (pCi/kg) Co-60 / 9 130 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Zn-65 / 9 260 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Cs-134 / 9 130 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0 Cs-137 / 9 150 <MDA (0 / 6) N/A N/A <MDA (0 / 3) 0

Plant: Palisades Year: 2022 Page 25 of 49 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Number of Indicator Locations Location [Note 3] Control Sample Type Type / Number Mean (F)[Note 2] Reportable LLD [Note 1] Mean (F)[Note 2] [Highest Locations Mean (Units) of Analyses [Range] Occurrences

[Range] Annual Mean] (F)[Note 2] [Range] [Note 4]

I-131 / 2 60 <MDA (0 / 2) N/A N/A Control sample not 0 Food Products (pCi/kg) Cs-134 / 2 60 <MDA (0 / 2) N/A N/A required 0 Cs-137 / 2 80 <MDA (0 / 2) N/A N/A 0 I-131 / 15 60 <MDA (0 / 10) N/A N/A <MDA (0 / 5) 0 Broad leaf Cs-134 / 15 60 <MDA (0 / 10) N/A N/A <MDA (0 / 5) 0 Vegetation (pCi/kg) Cs-137 / 15 80 73.5 (4 / 10) BV1 (onsite 0.4 73.5 (4 / 5) <MDA (0 / 5) 0

[37.4 - 95.5] miles SSE) [37.4 - 95.5] [N/A]

Sediment Cs-134 / 4 150 <MDA (0 / 4) N/A N/A Control sample not 0 (pCi/kg) Cs-137 / 4 180 <MDA (0 / 4) N/A N/A required 0

Plant: Palisades Year: 2022 Page 26 of 49 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Number of Indicator Locations Location [Note 3] Control Sample Type Type / Number Mean (F)[Note 2] Reportable LLD [Note 1] Mean (F)[Note 2] [Highest Locations Mean (Units) of Analyses [Range] Occurrences

[Range] Annual Mean] (F)[Note 2] [Range] [Note 4]

Gross Beta / 18 4 3.79 (5 / 6) Pal Park 3.79 (5 / 6) 3.03 (5 / 12) 0 Commercial [2.62 - 3.59]

[2.62 - 5.03] [2.62 - 5.03]

Well (0.7 miles S)

H-3 / 18 2000 <MDA (0 / 6) N/A N/A N/A 0 Mn-54 / 18 15 <MDA (0 / 6) N/A N/A N/A 0 Fe-59 / 18 30 <MDA (0 / 6) N/A N/A N/A 0 Offsite Groundwater Co-58 / 18 15 <MDA (0 / 6) N/A N/A N/A 0 (Pal Park Co-60 / 18 15 <MDA (0 / 6) N/A N/A N/A 0 Commercial Zn-65 / 18 30 <MDA (0 / 6) N/A N/A 0 Well) (pCi/L) N/A Zr-95 / 18 30 <MDA (0 / 6) N/A N/A N/A 0 Nb-95 / 18 15 <MDA (0 / 6) N/A N/A N/A 0 Cs-134 / 18 15 <MDA (0 / 6) N/A N/A N/A 0 Cs-137 / 18 18 <MDA (0 / 6) N/A N/A N/A 0 Ba-140 / 18 60 <MDA (0 / 6) N/A N/A N/A 0 La-140 / 18 15 <MDA (0 / 6) N/A N/A N/A 0

[Note 1] - LLD = Required lower limit of detection

[Note 2] - Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

[Note 3] - Locations are specified (1) by name and (2) compass sector relative to reactor site.

[Note 4] - A reportable occurrence is a situation in which an NRC report was submitted in accordance with the requirements in Palisades ODCM.

Plant: Palisades Year: 2022 Page 27 of 49 Annual Radiological Environmental Operating Report Attachment 1 Page 1 of 2 Sample Deviations Table 8, Sample Deviations Table Sample Comment Sample Media Date Problem Evaluation / Actions No. Location Affected During normal weekly sample collection (on 05/30/22) the pump at air sample station A4 was found tripped off. The GFCI outlet was reset and the pump resumed sampling Air as normal. The volume of air sampled indicates that the pump was running for about 1 A4 05/30/22 GFCI trip Sample two thirds of the previous week. The sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report.

During normal weekly sample collection (on 06/13/22) the pump at air sample station A8 was found tripped off. The GFCI outlet was reset and the pump resumed sampling Air as normal. The volume of air sampled indicates that the pump was running for about 2 A8 06/13/22 GFCI trip Sample two thirds of the previous week. The sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report.

On 06/14/22 air sample station location A9 was validated to be without power after reports of power outages in the area due to a storm the previous day. Power was Air 3 A9 06/14/22 Power loss restored and sampling resumed on 06/16/22. The sample volume was sufficient to Sample analyze the filter media and incorporate the results into the statistics in this report.

During normal weekly sample collection (on 10/10/22) the pump at air sample station A10 was found seized. The pump was replaced the same day. The volume of air Air Pump found 4 A10 10/10/22 sampled indicates that the pump was running for about half the previous week. The Sample seized sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report.

2023-008 Rev. 2022 Page 28 of 49 Annual Radiological Environmental Operating Report Attachment 1 Page 2 of 2 Sample Deviations Table 8, Sample Deviations Table Sample Comment Sample Media Date Problem Evaluation / Actions No. Location Affected During normal weekly sample collection (on 10/24/22) the pump at air sample station A8 was found seized. The pump was replaced the same day. The volume of air Air Pump found 5 A8 10/24/22 sampled indicates that the pump was running for about half the previous week. The Sample seized sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report.

TLD number 23 was found on the ground by a member of the public over the 10/22/22 TLD found - 10/23/22 weekend, underneath the siren pole where it is typically mounted. The TLD 10/22/22 on ground by was brought to Palisades support building Monday 10/24 and re-deployed on Tuesday 6 TLD 23 through member of 10/25 with a new holder. The old holder had potentially failed during a windstorm about 10/25/22 the public 1 week prior to being found. The results from this TLD are listed in Table 13 but are not included in the statistics in Table 7 due to this deviation.

TLD found TLD number 24 was found on the ground about 10 feet from its designated location on ground during the collection of 4th quarter TLDs. A new TLD was installed at the normal 7 TLD 24 01/10/23 during location for 1st quarter 2023 monitoring. The results from this TLD are listed in Table 13 routine but are not included in the statistics in Table 7 due to this deviation.

change-out

Plant: Palisades I Year: 2022 I Page 29 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 1 of 18 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Station Station Station Station A5 Station A8 Station A9 Start Date End Date A4[Note 1] A19 A10[Note 2]

(Indicator) (Indicator) (Indicator)

(Indicator) (Indicator) (Control)

REQUIRED LLD 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 01/04/22 01/11/22 2.94E-02 3.08E-02 2.86E-02 3.29E-02 2.80E-02 2.86E-02 01/11/22 01/17/22 4.38E-02 4.11E-02 3.73E-02 3.36E-02 4.16E-02 3.42E-02 01/17/22 01/24/22 2.46E-02 2.32E-02 2.23E-02 2.17E-02 2.48E-02 2.64E-02 01/24/22 01/31/22 3.13E-02 2.83E-02 2.65E-02 3.18E-02 2.66E-02 2.12E-02 01/31/22 02/07/22 3.23E-02 2.83E-02 2.90E-02 3.06E-02 2.86E-02 2.94E-02 02/07/22 02/14/22 3.60E-02 3.57E-02 2.62E-02 3.16E-02 2.86E-02 2.27E-02 02/14/22 02/21/22 3.07E-02 3.13E-02 3.55E-02 2.51E-02 2.79E-02 2.99E-02 02/21/22 03/01/22 3.03E-02 2.75E-02 2.32E-02 3.23E-02 2.10E-02 2.57E-02 03/01/22 03/07/22 2.48E-02 3.02E-02 2.28E-02 2.48E-02 2.70E-02 2.93E-02 03/07/22 03/14/22 2.67E-02 3.00E-02 2.58E-02 2.68E-02 2.67E-02 2.48E-02 03/14/22 03/21/22 2.97E-02 2.83E-02 3.21E-02 2.79E-02 2.66E-02 2.68E-02 03/21/22 03/28/22 2.10E-02 2.16E-02 1.84E-02 1.94E-02 1.78E-02 1.39E-02 03/28/22 04/05/22 2.15E-02 1.90E-02 1.80E-02 1.81E-02 2.09E-02 1.70E-02 04/05/22 04/11/22 1.98E-02 2.51E-02 1.48E-02 1.95E-02 2.10E-02 1.63E-02 04/11/22 04/18/22 1.75E-02 2.13E-02 1.96E-02 1.74E-02 1.45E-02 1.73E-02 04/18/22 04/25/22 2.40E-02 2.49E-02 1.91E-02 2.11E-02 2.00E-02 2.00E-02 04/25/22 05/02/22 2.99E-02 2.04E-02 1.91E-02 1.94E-02 1.73E-02 1.70E-02 05/02/22 05/09/22 2.09E-02 2.18E-02 2.03E-02 2.01E-02 1.78E-02 1.70E-02 05/09/22 05/16/22 2.83E-02 2.38E-02 2.80E-02 2.42E-02 2.77E-02 2.44E-02 05/16/22 05/23/22 2.66E-02 2.48E-02 2.12E-02 2.23E-02 1.91E-02 1.87E-02 05/23/22 05/30/22 2.75E-02 [Note3] 1.91E-02 1.37E-02 1.62E-02 1.70E-02 1.88E-02 05/30/22 06/06/22 2.23E-02 2.81E-02 2.18E-02 2.79E-02 2.54E-02 2.54E-02 2.57E-02 06/06/22 06/13/22 2.43E-02 1.88E-02 [Note3] 2.21E-02 2.40E-02 1.72E-02 2.59E-02 06/13/22 06/20/22 2.55E-02 2.49E-02 2.43E-02 [Note3] 2.00E-02 1.91E-02 06/20/22 06/27/22 2.17E-02 2.70E-02 1.97E-02 2.07E-02 2.15E-02 1.76E-02 06/27/22 07/05/22 2.65E-02 2.08E-02 2.05E-02 1.46E-02 1.68E-02 2.72E-02

Plant: Palisades I Year: 2022 I Page 30 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 2 of 18 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Station Station Station Station A5 Station A8 Station A9 Start Date End Date A4[Note 1] A19 A10[Note 2]

(Indicator) (Indicator) (Indicator)

(Indicator) (Indicator) (Control) 07/05/22 07/11/22 3.01E-02 2.25E-02 2.15E-02 2.69E-02 2.46E-02 2.14E-02 07/11/22 07/19/22 2.59E-02 2.48E-02 2.35E-02 2.72E-02 2.60E-02 2.22E-02 07/19/22 07/25/22 3.64E-02 2.69E-02 2.81E-02 2.15E-02 2.81E-02 1.86E-02 07/25/22 08/01/22 2.08E-02 2.15E-02 1.23E-02 1.49E-02 1.79E-02 2.47E-02 08/01/22 08/09/22 2.41E-02 2.23E-02 2.33E-02 2.32E-02 2.15E-02 2.44E-02 08/09/22 08/15/22 2.85E-02 3.34E-02 2.45E-02 2.70E-02 2.19E-02 1.86E-02 08/15/22 08/22/22 3.29E-02 2.65E-02 2.80E-02 2.64E-02 2.82E-02 2.74E-02 08/22/22 08/29/22 3.38E-02 3.08E-02 2.72E-02 3.32E-02 2.97E-02 9.82E-03 08/29/22 09/05/22 6.18E-03 5.84E-03 8.96E-03 8.77E-03 6.11E-03 2.13E-02 09/05/22 09/13/22 2.54E-02 2.70E-02 2.10E-02 2.43E-02 2.32E-02 3.04E-02 09/13/22 09/19/22 3.69E-02 3.14E-02 3.48E-02 3.11E-02 3.27E-02 3.56E-02 09/19/22 09/26/22 2.54E-02 2.74E-02 2.71E-02 2.10E-02 2.38E-02 2.79E-02 09/26/22 10/03/22 1.81E-02 1.37E-02 1.79E-02 1.72E-02 1.44E-02 1.49E-02 3.33E-02 10/03/22 10/11/22 3.04E-02 2.96E-02 2.74E-02 2.31E-02 2.60E-02 [Note3]

10/11/22 10/17/22 3.04E-02 2.67E-02 2.55E-02 3.37E-02 2.63E-02 2.75E-02 3.68E-02 10/17/22 10/24/22 3.79E-02 3.58E-02 [Note3] 2.52E-02 3.18E-02 2.74E-02 10/24/22 11/01/22 3.33E-02 3.15E-02 2.85E-02 2.62E-02 2.44E-02 2.68E-02 11/01/22 11/07/22 5.24E-02 4.96E-02 4.70E-02 4.43E-02 4.94E-02 5.53E-02 11/07/22 11/14/22 2.98E-02 2.69E-02 2.59E-02 2.43E-02 2.12E-02 1.62E-02 11/14/22 11/21/22 1.81E-02 1.79E-02 1.72E-02 1.95E-02 1.45E-02 2.00E-02 11/21/22 11/28/22 4.68E-02 4.88E-02 5.00E-02 5.25E-02 4.64E-02 4.85E-02 11/28/22 12/05/22 3.20E-02 3.62E-02 2.99E-02 3.22E-02 3.33E-02 3.28E-02 12/05/22 12/12/22 5.00E-02 4.35E-02 4.52E-02 4.40E-02 4.05E-02 4.76E-02 12/12/22 12/19/22 2.97E-02 2.59E-02 2.51E-02 2.80E-02 2.62E-02 2.67E-02 12/19/22 12/27/22 3.41E-02 2.75E-02 2.95E-02 3.25E-02 2.90E-02 2.78E-02 12/27/22 01/03/23 6.60E-02 4.89E-02 4.53E-02 4.53E-02 4.81E-02 4.71E-02

Plant: Palisades I Year: 2022 I Page 31 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 3 of 18 Monitoring Results Tables

[Note 1] - Station with highest annual mean.

[Note 2] - The sample date range is accurate to plus or minus 2 days for station A10

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table Table 10, Air Radioiodine Data Table Summary Analysis: I-131 Units: pCi/m3 Station Station Station A4 Station A5 Station A8 Station A9 Start Date End Date A19 A10[Note 1]

(Indicator) (Indicator) (Indicator) (Indicator)

(Indicator) (Control)

REQUIRED LLD 7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 01/04/22 01/11/22 <MDA <MDA <MDA <MDA <MDA <MDA 01/11/22 01/17/22 <MDA <MDA <MDA <MDA <MDA <MDA 01/17/22 01/24/22 <MDA <MDA <MDA <MDA <MDA <MDA 01/24/22 01/31/22 <MDA <MDA <MDA <MDA <MDA <MDA 01/31/22 02/07/22 <MDA <MDA <MDA <MDA <MDA <MDA 02/07/22 02/14/22 <MDA <MDA <MDA <MDA <MDA <MDA 02/14/22 02/21/22 <MDA <MDA <MDA <MDA <MDA <MDA 02/21/22 03/01/22 <MDA <MDA <MDA <MDA <MDA <MDA 03/01/22 03/07/22 <MDA <MDA <MDA <MDA <MDA <MDA 03/07/22 03/14/22 <MDA <MDA <MDA <MDA <MDA <MDA 03/14/22 03/21/22 <MDA <MDA <MDA <MDA <MDA <MDA 03/21/22 03/28/22 <MDA <MDA <MDA <MDA <MDA <MDA 03/28/22 04/05/22 <MDA <MDA <MDA <MDA <MDA <MDA 04/05/22 04/11/22 <MDA <MDA <MDA <MDA <MDA <MDA 04/11/22 04/18/22 <MDA <MDA <MDA <MDA <MDA <MDA 04/18/22 04/25/22 <MDA <MDA <MDA <MDA <MDA <MDA 04/25/22 05/02/22 <MDA <MDA <MDA <MDA <MDA <MDA 05/02/22 05/09/22 <MDA <MDA <MDA <MDA <MDA <MDA 05/09/22 05/16/22 <MDA <MDA <MDA <MDA <MDA <MDA 05/16/22 05/23/22 <MDA <MDA <MDA <MDA <MDA <MDA 05/23/22 05/30/22 <MDA [Note 2] <MDA <MDA <MDA <MDA <MDA 05/30/22 06/06/22 <MDA <MDA <MDA <MDA <MDA <MDA 06/06/22 06/13/22 <MDA <MDA <MDA [Note 2] <MDA <MDA <MDA 06/13/22 06/20/22 <MDA <MDA <MDA <MDA [Note 2] <MDA <MDA

Plant: Palisades I Year: 2022 I Page 32 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 4 of 18 Monitoring Results Tables Table 10, Air Radioiodine Data Table Summary Analysis: I-131 Units: pCi/m3 Station Station Station A4 Station A5 Station A8 Station A9 Start Date End Date A19 A10[Note 1]

(Indicator) (Indicator) (Indicator) (Indicator)

(Indicator) (Control) 06/20/22 06/27/22 <MDA <MDA <MDA <MDA <MDA <MDA 06/27/22 07/05/22 <MDA <MDA <MDA <MDA <MDA <MDA 07/05/22 07/11/22 <MDA <MDA <MDA <MDA <MDA <MDA 07/11/22 07/19/22 <MDA <MDA <MDA <MDA <MDA <MDA 07/19/22 07/25/22 <MDA <MDA <MDA <MDA <MDA <MDA 07/25/22 08/01/22 <MDA <MDA <MDA <MDA <MDA <MDA 08/01/22 08/09/22 <MDA <MDA <MDA <MDA <MDA <MDA 08/09/22 08/15/22 <MDA <MDA <MDA <MDA <MDA <MDA 08/15/22 08/22/22 <MDA <MDA <MDA <MDA <MDA <MDA 08/22/22 08/29/22 <MDA <MDA <MDA <MDA <MDA <MDA 08/29/22 09/05/22 <MDA <MDA <MDA <MDA <MDA <MDA 09/05/22 09/13/22 <MDA <MDA <MDA <MDA <MDA <MDA 09/13/22 09/19/22 <MDA <MDA <MDA <MDA <MDA <MDA 09/19/22 09/26/22 <MDA <MDA <MDA <MDA <MDA <MDA 09/26/22 10/03/22 <MDA <MDA <MDA <MDA <MDA <MDA 10/03/22 10/11/22 <MDA <MDA <MDA <MDA <MDA <MDA [Note 2]

10/11/22 10/17/22 <MDA <MDA <MDA <MDA <MDA <MDA 10/17/22 10/24/22 <MDA <MDA <MDA [Note 2] <MDA <MDA <MDA 10/24/22 11/01/22 <MDA <MDA <MDA <MDA <MDA <MDA 11/01/22 11/07/22 <MDA <MDA <MDA <MDA <MDA <MDA 11/07/22 11/14/22 <MDA <MDA <MDA <MDA <MDA <MDA 11/14/22 11/21/22 <MDA <MDA <MDA <MDA <MDA <MDA 11/21/22 11/28/22 <MDA <MDA <MDA <MDA <MDA <MDA 11/28/22 12/05/22 <MDA <MDA <MDA <MDA <MDA <MDA 12/05/22 12/12/22 <MDA <MDA <MDA <MDA <MDA <MDA 12/12/22 12/19/22 <MDA <MDA <MDA <MDA <MDA <MDA 12/19/22 12/27/22 <MDA <MDA <MDA <MDA <MDA <MDA

Plant: Palisades I Year: 2022 I Page 33 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 5 of 18 Monitoring Results Tables Table 10, Air Radioiodine Data Table Summary Analysis: I-131 Units: pCi/m3 Station Station Station A4 Station A5 Station A8 Station A9 Start Date End Date A19 A10[Note 1]

(Indicator) (Indicator) (Indicator) (Indicator)

(Indicator) (Control) 12/27/22 01/03/23 <MDA <MDA <MDA <MDA <MDA <MDA

[Note 1] - The sample date range is accurate to plus or minus 2 days for station A10

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Table 11, Air Sample Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/m3 Location Start Date End Date Cs-134 Cs-137 Be-7[Note 1]

REQUIRED LLD 0.05 0.06 NA Station A4 01/04/22 03/28/22 <MDA <MDA 1.37E-01 Station A4 03/28/22 06/27/22 <MDA <MDA 1.60E-01 Station A4 06/27/22 10/03/22 <MDA <MDA 1.16E-01 Station A4 10/03/22 01/03/23 <MDA <MDA 1.28E-01 Station A5 01/04/22 03/28/22 <MDA <MDA 1.19E-01 Station A5 03/28/22 06/27/22 <MDA <MDA 1.40E-01 Station A5 06/27/22 10/03/22 <MDA <MDA 1.01E-01 Station A5 10/03/22 01/03/23 <MDA <MDA 1.30E-01 Station A8 01/04/22 03/28/22 <MDA <MDA 1.31E-01 Station A8 03/28/22 06/27/22 <MDA <MDA 1.33E-01 Station A8 06/27/22 10/03/22 <MDA <MDA 1.28E-01 Station A8 10/03/22 01/03/23 <MDA <MDA 9.89E-02 Station A9 01/04/22 03/28/22 <MDA <MDA 1.20E-01 Station A9 03/28/22 06/27/22 <MDA <MDA 1.06E-01 Station A9 06/27/22 10/03/22 <MDA <MDA 8.02E-02 Station A9 10/03/22 01/03/23 <MDA <MDA 9.95E-02 Station A19 01/04/22 03/28/22 <MDA <MDA 7.55E-02 Station A19 03/28/22 06/27/22 <MDA <MDA 1.18E-01 Station A19 06/27/22 10/03/22 <MDA <MDA 1.07E-01 Station A19 10/03/22 01/03/23 <MDA <MDA 1.03E-01 Station A10 01/03/22 03/28/22 <MDA <MDA 1.29E-01 Station A10 03/28/22 06/28/22 <MDA <MDA 1.58E-01 Station A10 06/28/22 10/04/22 <MDA <MDA 1.15E-01 Station A10 10/04/22 01/03/23 <MDA <MDA 6.45E-02

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I Year: 2022 I Page 34 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 6 of 18 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mR Annual Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Mean 1[Note 1] 10.80 10.85 10.68 12.01 11.09 8 9.82 10.26 9.94 11.16 10.30 13 9.85 9.70 9.22 10.23 9.75 14 8.57 8.59 8.10 9.11 8.59 15 8.97 9.56 8.96 9.86 9.34 16 9.09 9.32 8.96 10.18 9.39 17 9.17 8.91 8.60 10.00 9.17 18 9.54 9.76 9.64 10.90 9.96 19 9.49 9.77 9.27 10.29 9.71 20 9.36 9.47 9.13 10.62 9.65 21 9.54 9.72 9.14 10.54 9.74

[Note 1] - Station with highest annual mean.

Table 13, Thermoluminescent Dosimeters - Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 2[Note 1] 13.66 14.18 14.87 15.02 14.43 3 11.06 11.04 11.39 12.54 11.51 4-21 10.09 10.04 10.23 11.41 10.44 5-21 10.87 11.83 11.84 12.61 11.79 6 10.87 10.70 10.63 11.98 11.05 7 10.14 9.97 9.31 11.24 10.17

Plant: Palisades I Year: 2022 I Page 35 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 7 of 18 Monitoring Results Tables Table 13, Thermoluminescent Dosimeters - Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 9-21 9.81 9.58 9.68 11.30 10.09 23 10.99 11.39 11.04 12.17[Note 2] 11.14 24 11.23 11.90 11.66 13.29[Note 2] 11.60

[Note 1] - Station with highest annual mean.

[Note 2] - Values not included in the annual mean. Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table Table 14, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 11-21 11.57 12.00 11.58 12.75 11.98 Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Mn- Cs- Cs- Ba- La-Location End Date Co-58 Fe-59 Co-60 Zn-65 Zr-95 Nb-95 K-40 Th-228 Date 54 134 137 140 140 REQUIRED LLD 15 15 30 15 30 30 15 15 18 60 15 [Note 1] [Note 1]

Lake In 01/01/22 02/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 02/01/22 03/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 03/01/22 04/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4.41 Lake In 04/01/22 05/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 14.74 <MDA Lake In 05/01/22 06/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 06/01/22 07/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 32.20 <MDA Lake In 07/01/22 08/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 08/01/22 09/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

Plant: Palisades I Year: 2022 I Page 36 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 8 of 18 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Mn- Cs- Cs- Ba- La-Location End Date Co-58 Fe-59 Co-60 Zn-65 Zr-95 Nb-95 K-40 Th-228 Date 54 134 137 140 140 Lake In 09/01/22 10/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 10/01/22 11/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3.16 Lake In 11/01/22 12/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 12/01/22 01/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Ludington 01/01/22 02/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 02/01/22 03/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 03/01/22 04/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 04/01/22 05/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 05/01/22 06/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 06/01/22 07/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 07/01/22 08/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 08/01/22 09/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 09/01/22 10/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 25.24 <MDA Control Ludington 10/01/22 11/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 11/01/22 12/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3.97 Control Ludington 12/01/22 01/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I Year: 2022 I Page 37 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 9 of 18 Monitoring Results Tables Table 16, Surface Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta REQUIRED LLD 2000 4.00 Lake In 01/01/22 02/01/22 <MDA <MDA Lake In 02/01/22 03/01/22 <MDA <MDA Lake In 03/01/22 04/01/22 <MDA <MDA Lake In 04/01/22 05/01/22 <MDA <MDA Lake In 05/01/22 06/01/22 <MDA <MDA Lake In 06/01/22 07/01/22 <MDA 2.35 Lake In 07/01/22 08/01/22 <MDA <MDA Lake In 08/01/22 09/01/22 <MDA <MDA Lake In 09/01/22 10/01/22 <MDA <MDA Lake In 10/01/22 11/01/22 <MDA 2.92 Lake In 11/01/22 12/01/22 <MDA <MDA Lake In 12/01/22 01/01/23 <MDA 2.71 Ludington Control 01/01/22 02/01/22 <MDA 2.89 Ludington Control 02/01/22 03/01/22 <MDA <MDA Ludington Control 03/01/22 04/01/22 <MDA 2.77 Ludington Control 04/01/22 05/01/22 <MDA <MDA Ludington Control 05/01/22 06/01/22 <MDA 3.59 Ludington Control 06/01/22 07/01/22 <MDA <MDA Ludington Control 07/01/22 08/01/22 <MDA <MDA Ludington Control 08/01/22 09/01/22 <MDA <MDA

Plant: Palisades I Year: 2022 I Page 38 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 10 of 18 Monitoring Results Tables Table 16, Surface Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta Ludington Control 09/01/22 10/01/22 <MDA <MDA Ludington Control 10/01/22 11/01/22 <MDA 2.62 Ludington Control 11/01/22 12/01/22 <MDA <MDA Ludington Control 12/01/22 01/01/23 <MDA 3.29 Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15 [Note 1] [Note 1]

Domestic 01/01/22 02/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 02/01/22 03/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 03/01/22 04/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4.93 <MDA Water Domestic 04/01/22 05/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 05/01/22 06/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 06/01/22 07/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 07/01/22 08/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 08/01/22 09/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3.49 <MDA Water Domestic 09/01/22 10/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 72.21 Water

Plant: Palisades I Year: 2022 I Page 39 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 11 of 18 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15 [Note 1] [Note 1]

Domestic 10/01/22 11/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 11/01/22 12/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 12/01/22 01/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Pal Park 05/22/22 NA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park NA 06/13/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park NA 07/12/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park NA 08/15/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park NA 09/13/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park NA 10/03/21 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community South 01/01/22 02/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 02/01/22 03/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 03/01/22 04/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 8.32 <MDA Haven South 04/01/22 05/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 05/01/22 06/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 06/01/22 07/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven

Plant: Palisades I Year: 2022 I Page 40 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 12 of 18 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15 [Note 1] [Note 1]

South 07/01/22 08/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4.78 <MDA Haven South 08/01/22 09/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 09/01/22 10/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 10/01/22 11/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 11/01/22 12/01/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 5.12 <MDA Haven South 12/01/22 01/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 18, Drinking Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta REQUIRED LLD 2000 4.00 Domestic Water 01/01/22 02/01/22 <MDA <MDA Domestic Water 02/01/22 03/01/22 <MDA <MDA Domestic Water 03/01/22 04/01/22 <MDA 3.62 Domestic Water 04/01/22 05/01/22 <MDA <MDA Domestic Water 05/01/22 06/01/22 <MDA <MDA Domestic Water 06/01/22 07/01/22 <MDA <MDA Domestic Water 07/01/22 08/01/22 <MDA <MDA

Plant: Palisades I Year: 2022 I Page 41 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 13 of 18 Monitoring Results Tables Table 18, Drinking Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta Domestic Water 08/01/22 09/01/22 <MDA <MDA Domestic Water 09/01/22 10/01/22 <MDA 3.41 Domestic Water 10/01/22 11/01/22 <MDA <MDA Domestic Water 11/01/22 12/01/22 <MDA <MDA Domestic Water 12/01/22 01/01/23 <MDA 2.43 Pal Park Community 05/22/22 NA[Note 1] <MDA <MDA Pal Park Community 06/13/22 NA[Note 1] <MDA <MDA Pal Park Community 07/12/22 NA[Note 1] <MDA <MDA Pal Park Community 08/15/22 NA[Note 1] <MDA <MDA Pal Park Community 09/13/22 NA[Note 1] <MDA <MDA Pal Park Community 10/03/22 NA[Note 1] <MDA <MDA South Haven 01/01/22 02/01/22 <MDA <MDA South Haven 02/01/22 03/01/22 <MDA <MDA South Haven 03/01/22 04/01/22 <MDA 3.37 South Haven 04/01/22 05/01/22 <MDA <MDA South Haven 05/01/22 06/01/22 <MDA 2.41 South Haven 06/01/22 07/01/22 <MDA <MDA South Haven 07/01/22 08/01/22 <MDA <MDA South Haven 08/01/22 09/01/22 <MDA <MDA South Haven 09/01/22 10/01/22 <MDA <MDA South Haven 10/01/22 11/01/22 <MDA <MDA South Haven 11/01/22 12/01/22 <MDA <MDA

Plant: Palisades I Year: 2022 I Page 42 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 14 of 18 Monitoring Results Tables Table 18, Drinking Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta South Haven 12/01/22 01/01/23 <MDA 2.27

[Note 1] - This is a grab sample and therefore there is no end date.

Table 19, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 K-40 Th-228

[Note 1] [Note 1]

REQUIRED LLD 150 180 North Sediment 05/09/22 <MDA <MDA 4187 147 North Sediment 09/08/22 <MDA <MDA 3657 151 South Sediment 05/09/22 <MDA <MDA 2700 179 South Sediment 09/08/22 <MDA <MDA 4210 167

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location / Collection Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 Th-228 species Date

[Note 1] [Note 1]

REQUIRED LLD 130 130 260 130 260 130 150 Ludington /

05/14/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3219 <MDA Brown Trout Ludington /

Chinook 08/17/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2690 <MDA Salmon Ludington /

08/17/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3845 <MDA Lake Trout Palisades /

05/04/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2708 <MDA Brown Trout

Plant: Palisades I Year: 2022 I Page 43 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 15 of 18 Monitoring Results Tables Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location / Collection Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 Th-228 species Date Palisades /

Chinook 08/16/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3017 <MDA Salmon Palisades /

05/04/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2413 <MDA Drum Palisades /

05/04/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2547 80.61 Gizzard Shad Palisades /

08/16/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3110 <MDA Lake Trout Palisades /

Rainbow 08/16/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3066 <MDA Trout

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 21, Food Products Analysis: I-131, Gamma Isotopic Units: pCi/kg Sample / Location Collection Date I-131 Cs-134 Cs-137 K-40

[Note 1]

REQUIRED LLD 60 60 80 Blueberries / Covert

<MDA <MDA <MDA 1398 MI 07/05/22 Apples / Covert MI 10/04/22 <MDA <MDA <MDA 1465

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I Year: 2022 I Page 44 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 16 of 18 Monitoring Results Tables Table 22, Offsite Groundwater - Gamma isotopic Analysis: Gamma Isotopic Units: pCi/L Collection Location Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 Date REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15 [Note 1]

Pal Park Commercial 05/22/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 10.59 Well Pal Park Commercial 06/13/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 07/12/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 08/15/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 09/13/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 10/03/22 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I Year: 2022 I Page 45 of 49 Annual Radiological Environmental Operating Report Page 17 of 18 Monitoring Results Tables Table 23, Offsite Groundwater - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Collection Date Tritium Gross Beta REQUIRED LLD 2000 4.00 Pal Park Commercial 05/22/22 <MDA 5.03 Well Pal Park Commercial 06/13/22 <MDA <MDA Well Pal Park Commercial 07/12/22 <MDA 2.73 Well Pal Park Commercial 08/15/22 <MDA 4.68 Well Pal Park Commercial 09/13/22 <MDA 3.90 Well Pal Park Commercial 10/03/22 <MDA 2.62 Well Table 24, Broad Leaf Vegetation Analysis: I-131, Gamma Isotopic Units: pCi/kg Location Collection Date I-131 Cs-134 Cs-137 K-40 Be-7

[Note 1] [Note 1]

REQUIRED LLD 60 60 80 Location BV1, 0.4 miles SSE 05/22/22 <MDA <MDA 37.4 2644 765 Location BV1, 0.4 miles SSE 06/11/22 <MDA <MDA 72.0 2571 1684 Location BV1, 0.4 miles SSE 07/13/22 <MDA <MDA 95.5 2104 1915 Location BV1, 0.4 miles SSE 08/17/22 <MDA <MDA <MDA 2428 2366 Location BV1, 0.4 miles SSE 09/15/22 <MDA <MDA 89.2 2248 3558 Location BV2, 0.7 miles SSE 05/22/22 <MDA <MDA <MDA 4011 1230

Plant: Palisades I Year: 2022 I Page 46 of 49 Annual Radiological Environmental Operating Report Attachment 2 Page 18 of 18 Monitoring Results Tables Table 24, Broad Leaf Vegetation Analysis: I-131, Gamma Isotopic Units: pCi/kg Location Collection Date I-131 Cs-134 Cs-137 K-40 Be-7 Location BV2, 0.7 miles SSE 06/11/22 <MDA <MDA <MDA 4708 2876 Location BV2, 0.7 miles SSE 07/13/22 <MDA <MDA <MDA 4621 1406 Location BV2, 0.7 miles SSE 08/17/22 <MDA <MDA <MDA 3216 2280 Location BV2, 0.7 miles SSE 09/15/22 <MDA <MDA <MDA 3780 2252 Location BVC, 13.6 miles SSE 05/22/22 <MDA <MDA <MDA 4018 1003 Location BVC, 13.6 miles SSE 06/11/22 <MDA <MDA <MDA 4770 1801 Location BVC, 13.6 miles SSE 07/13/22 <MDA <MDA <MDA 3984 1748 Location BVC, 13.6 miles SSE 08/17/22 <MDA <MDA <MDA 3374 3088 Location BVC, 13.6 miles SSE 09/15/22 <MDA <MDA <MDA 3254 1757

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I Year: 2022 I Page 47 of 49 Annual Radiological Environmental Operating Report Attachment 3 Page 1 of 3 Interlaboratory Comparison Program Results 1.0 Summary Summary of Results - Inter-laboratory Comparison Program (ICP)

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

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

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

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

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

- Acceptable (flag = A) - result within +/- 20% of the reference value

- Acceptable with Warning (flag = W) - result falls in the +/- 20% to +/- 30% of the reference value

- Not Acceptable (flag = N) - bias is greater than 30% of the reference value Note: The Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP) samples are created to mimic conditions found at DOE sites which do not resemble typical environmental samples obtained at commercial nuclear power facilities.

For the TBE laboratory, 142 out of 150 analyses performed met the specified acceptance criteria. Eight analyses did not meet the specified acceptance criteria and were addressed through the TBE Corrective Action Program.

TBE implements a non-conformance report (NCR) program to formally document QC investigations which include the root cause of the failure, the corrective action taken, and actions taken to prevent reoccurrence.

Plant: Palisades I Year: 2022 I Page 48 of 49 Annual Radiological Environmental Operating Report Page 2 of 3 Interlaboratory Comparison Program Results NOTE: Two analyses (soil for Tc-99 and U-238) that did not meet acceptance criteria was performed for TBE information and is not on the list of required ICP analyses. A summary is found below:

1 The Analytics March 2022 AP Ce-141 result was evaluated as Not Acceptable.

The reported value for Ce-141 was 60.9 pCi and the known result was 42.0 pCi/L (1.45 ratio of reported result vs. known; TBEs internal acceptance range is 0.70 -

1.30). This sample was used as the workgroup duplicate with a result of 45.7 (109% of known) and was also counted on a different detector with a result of 50.9 (121% of known). This was TBEs first failure for AP Ce-141. (NCR 22-04) 2 The MAPEP February 2022 Urine U-234 & U-238 results were evaluated as Not Acceptable. TBEs reported values of 0.142 and 0.0254 were above the known upper ranges of 0.0096 and 0.0134 respectively for U-234 and U-238. These spiked values were below TBEs typical MDC for urine client samples. The samples were re-prepped using a larger sample aliquot and counted for 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months as opposed to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The recount results were 0.00732 for U-234 and 0.0119 for U-238 (both within acceptable range). MAPEP urine samples will be flagged to use a larger sample aliquot and counting time than typical client samples.

MAPEP did not include any urine cross-check samples in August. (NCR 22-05) 3 The ERA MRAD September 2022 AP Pu-238 was evaluated as Not Acceptable.

The reported value was 38.8 pCi and the known result was 29.9 (acceptance range 22.6 - 36.7). The AP filter was cut in half prior to digestion (shared with Fe-55) but should have been complete digested together and aliquotted afterwards like typical client samples. This is the first failure for AP Pu-238.

(NCR 22-19) 4 The ERA October 2022 water Uranium result was evaluated as Not Acceptable.

The reported value was 10.54 pCi/L and the known was 8.53 (acceptance range 6.60 - 9.88) or 124% of the known (acceptable for TBE QC). The 2-sigma error was 3.2, placing the reported result well within the acceptable range. This sample was used as the workgroup duplicate with a result of 8.2 +/- 2.9 pCi/L (also within the acceptable range). All other QA was reviewed with no anomalies. (NCR 22-20) 5 The Analytics AP Co-60 result was evaluated as Not Acceptable. The reported value was 207 pCi and the known was 147 (141% of the known). TBEs internal QC acceptance is 70 - 130%. All QA was reviewed with no anomalies. This sample was used as the workgroup duplicate and counted on a different detector with a result of 167 pCi (114% of the known). This is the first failure for AP Co-60

- average result ratio compared to the known is 109%. (NCR 22-21)

Plant: Palisades I Year: 2022 I Page 49 of 49 Annual Radiological Environmental Operating Report Page 3 of 3 Interlaboratory Comparison Program Results 6 The MAPEP August 2022 water Tc-99 result was evaluated as Not Acceptable.

The reported value was 1.86 +/- 0.414 Bq/L for this false positive test. The evaluation of the submitted result to the 3 times the uncertainty indicated a slight positive. This sample was used as the workgroup duplicate with a result of 0.88

+/- 0.374 Bq/L. All QC was reviewed, and no anomalies found. This is the first unacceptable since the resumption of reporting water Tc-99 for the 3rd quarter of 2020. TBE to known ratios have ranged from 94-109% during this time. (NCR 22-22)

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

Thermoluminescent dosimeters (TLDs) are analyzed by an offsite vendor, Environmental Dosimetry Company (EDC). The TLDs used are Panasonic 814 Environmental dosimeters.

EDC implements an internal quality assurance program and audits the program annually. There were no findings from the 2022 audit. Some of EDCs vendors also perform independent testing on the TLDs accuracy and precision. During 2022, 100% (72/72) of the individual dosimeters met the criterion for accuracy and precision. Also, 100% (12/12) of the dosimeter sets met the criterion for mean bias and precision and 100% (9/9) of independent blind testing passed the performance criteria for mean bias. Acceptance criteria for mean bias is +/-15% and for precision is +/-12.8% in accordance with EDC Quality System Manual..

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Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance... Administration Meeting Questions Answers Results Approval, Approval Other: ML24152A134, ML24152A195, ML24152A199, ML24155A003, ML24155A010, ML24155A026, ML24163A055, ML24163A082, ML24163A083, ML24163A109, ML24163A147, ML24163A192, ML24163A239, ML24183A127, ML24183A128, ML24183A129, ML24183A130, ML24183A131, ML24183A132, ML24183A133, ML24183A134, ML24183A135, ML24183A136, ML24183A137, ML24183A138, ML24183A139, ML24183A140, ML24183A141, ML24183A142, ML24183A143, ML24183A144, ML24183A145, ML24183A146, ML24183A147, ML24183A148, ML24183A149, ML24183A150, ML24183A151, ML24183A153, ML24183A154, ML24183A155, ML24183A156, ML24183A157, ML24183A158, ML24183A159, ML24183A160, ML24183A161, ML24219A420
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PNP 2023-008, 2022 Radiological Environmental Operating Report

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