ML23136A779

Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022

ML23136A779
Person / Time
Site:	Pilgrim
Issue date:	05/15/2023
From:	Fleming J Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
References
HDI-Pil-23-006
Download: ML23136A779 (1)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50 Appendix I May 15, 2023 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility Operating License No. DPR-35 Docket No. 50-293 and 72-1044

Subject:

Annual Radiological Environmental Operating Report, January 1 through December 31, 2022.

In accordance with the requirements of Pilgrim Station Defueled Safety Analysis Report, Appendix B-5.6.2, and 10 CFR 50 Appendix I, Holtec Decommissioning International LLC (HDI),

on behalf of Pilgrim Nuclear Power Station, herby submits the Annual Radiological Environmental Operating Report for calendar year 2022.

This letter contains no new regulatory commitments.

Should you have any questions or require further information, please contact Mark Lawson, Radiation Protection and Chemistry Manager, at (508) 830-7109 or me at (856) 797-0900, ext.

3578.

Sincerely, Digitally signed by Jean A.

Jean A. Fleming Fleming Date: 2023.05.15 11:53:23 -04'00' Jean A. Fleming Vice President, Licensing, Regulatory Affairs, & PSA Holtec International

Enclosure:

Annual Radiological Environmental Operating Report, January 1st through December 31st, 2022 cc:

USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Region I, Lead Inspector - Pilgrim Nuclear Power Station Director, Massachusetts Emergency Management Agency Deputy Regional Director Bureau of Air & Waste, Massachusetts DEP Environmental Analyst Surface Water Discharge Permitting Program , Massachusetts DEP Director, Massachusetts Department of Public Health Radiation Control Program HDI-Pil-23-006

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Annual Radiological Environmental Operating Report January 1 through December 31, 2022 HOLTEC DECOMMISSIONING INTERNATIONAL Page 1

HOLTEC DECOMMISSIONING INTERNATIONAL PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2022 Reviewed by: ~ '5. <;. Z3 M. Lawson l Date Chemistry/ Radiation Protection Manager Page2

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2022 TABLE OF CONTENTS SECTION SECTION TITLE PAGE

-- EXECUTIVE

SUMMARY

6

1.0 INTRODUCTION

8 1.1 Radiation and Radioactivity 8 1.2 Sources of Radiation 9 1.3 Nuclear Reactor Operations 10 1.4 Radioactive Effluent Control 14 1.5 Radiological Impact on Humans 16 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 20 2.1 Pre-Operational Monitoring Results 20 2.2 Environmental Monitoring Locations 21 2.3 Interpretation of Radioactivity Analyses Results 23 2.4 Ambient Radiation Measurements 24 2.5 Air Particulate Filter Radioactivity Analyses 25 2.6 Milk Radioactivity Analyses 26 2.7 Vegetable/Vegetation Radioactivity Analyses 26 2.8 Surface Water Radioactivity Analyses 26 2.9 Sediment Radioactivity Analyses 27 2.10 Shellfish Radioactivity Analyses 27 2.11 Lobster Radioactivity Analyses 27 2.12 Fish Radioactivity Analyses 28 3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS 55

4.0 REFERENCES

57 APPENDIX A Special Studies 58 APPENDIX B Land Use Census 59 APPENDIX C Environmental Monitoring Program Discrepancies 60 APPENDIX D Environmental Dosimetry Company Annual Quality Assurance 62 Status Report APPENDIX E Teledyne Brown Engineering Environmental Services 2022 Quality Assurance Report Page 3

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2022 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 9 2.2-1 Routine Radiological Environmental Sampling Locations 29 2.4-1 Offsite Environmental TLD Results 30 2.4-2 Onsite Environmental TLD Results 31 2.4-3 Average TLD Exposures By Distance Zone During 2022 32 2.5-1 Air Particulate Filter Radioactivity Analyses 33 2.7-1 Vegetable/Vegetation Radioactivity Analyses 34 2.8-1 Surface Water Radioactivity Analyses 35 2.9-1 Sediment Radioactivity Analyses 36 2.10-1 Shellfish Radioactivity Analyses 37 2.11-1 Lobster Radioactivity Analyses 38 2.12-1 Fish Radioactivity Analyses 39 3.0-1 Radiation Doses From 2022 Pilgrim Station Operations 56 Page 4

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2022 LIST OF FIGURES FIGURE FIGURE TITLE PAGE 1.3-1 Radioactive Fission Product Formation 11 1.3-2 Radioactive Activation Product Formation 12 1.3-3 Barriers to Confine Radioactive Materials 13 1.5-1 Radiation Exposure Pathways 17 2.2-1 Environmental TLD Locations Within the PNPS Protected Area 40 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer 42 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers 44 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers 46 2.2-5 Marine/Aquatic Sampling Locations 48 2.2-6 Environmental Sampling and Measurement Control Locations 50 2.5-1 Airborne Gross Beta Radioactivity Levels: Near Station Monitors 52 2.5-2 Airborne Gross Beta Radioactivity Levels: Property Line Monitors 53 2.5-3 Airborne Gross Beta Radioactivity Levels: Offsite Monitors 54 Page 5

EXECUTIVE

SUMMARY

HOLTEC DECOMISSIONING INTERNATIONAL PILGRIM NUCLEAR POWER STATION ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2022 INTRODUCTION This report summarizes the results of the Holtec Decommissioning International (HDI) Nuclear Radiological Environmental Monitoring Program (REMP) conducted in the vicinity of Pilgrim Nuclear Power Station (PNPS) during the period from January 1 to December 31, 2022. This document has been prepared in accordance with the requirements of PNPS Facility Licensing Basis.

The REMP has been established to monitor the radiation and radioactivity released to the environment as a result of previous Pilgrim Station's operation. This program, initiated in August 1968, includes the collection, analysis, and evaluation of radiological data in order to assess the impact of Pilgrim Station on the environment and on the general public. The results from the REMP are used also to validate dose modeling and concentration prediction results in the effluent dose model.

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

During 2022, there were 389 samples collected from the atmospheric, aquatic, and terrestrial environments. In addition, 155 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs).

312 of 312 air particulate were collected and analyzed as required without any equipment failures or power outages as is usually the case in an area in the Northeast US, but a mild winter and close monitoring of equipment has helped to prevent sample losses. Charcoal cartridge collection was discontinued in the beginning of December 2019 when Iodines had decayed away following the permanent shutdown of PNPS on May 31, 2019. A full description of any discrepancies encountered with the environmental monitoring program is presented in Appendix D of this report.

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

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

Broadleaf vegetation may still be consumed by humans, and it will be projected and accounted for in dose modeling for all nuclides remaining that are released off site, but the only radionuclide detected in Page 6

REMP samples while the plant was operating was Cs-137 from fall out (recently - Chernobyl and Fukushima) which is deposited on and absorbed through the roots of plants and trees and has a 30-year half-life. The current dose model for gaseous release dose calculations utilizes a garden at the site boundary in the predominant downwind direction. As this is the most conservative scenario, no land use census will produce an alternate garden with higher off-site dose potential.

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

RADIOLOGICAL IMPACT TO THE ENVIRONMENT During 2022, samples collected as part of the REMP at Pilgrim Station continued to contain detectable amounts of naturally-occurring radioactive materials. No samples indicated any detectable radioactivity attributable to Pilgrim Station operations. Offsite ambient radiation measurements using environmental TLDs beyond the site boundary ranged between 49 and 88 milliRoentgens (1 mR=0.933 mrem) per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts.

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2022, radiation doses to the general public as a result of previous Pilgrim Station's operation continued to be well below the federal limits and much less than the collective dose due to other sources of man-made (e.g., X-rays, medical, fallout) and naturally-occurring (e.g., cosmic, radon) radiation.

The calculated total body dose to the maximally exposed member of the general public from radioactive effluents and ambient radiation resulting from PNPS operations for 2022 was approximately 0.16 mrem for the year. This conservative estimate is well below the EPA's annual dose limit to any member of the general public and is a fraction of a percent of the typical dose received from natural and man-made radiation.

CONCLUSIONS The 2022 Radiological Environmental Monitoring Program for Pilgrim Station resulted in the collection and analysis of hundreds of environmental samples and measurements. The data obtained were used to determine the impact of Pilgrim Station's operation on the environment and on the general public.

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

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

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1.0 INTRODUCTION

The Radiological Environmental Monitoring Program for 2022 performed by Comprehensive Decommissioning International (CDI), now Holtec Decommissioning International (HDI), owned by Holtec for Pilgrim Nuclear Power Station (PNPS) is discussed in this report. This report, which is required to be published annually by Pilgrim Station's Facility Licensing Basis, summarizes the results of measurements of radiation and radioactivity in the environment in the vicinity of the Pilgrim Station and at distant locations during the period January 1 to December 31, 2022.

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

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

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

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

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

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

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

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

Table 1.2-1 (1)

Radiation Sources and Corresponding Doses NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem/year)

(2) (3)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Figure 1.3-1 Radioactive Fission Product Formation Page 11

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

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

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

and zinc-65 (Zn-65).

n Co-59 Co-60 Stable Radioactive Neutron Cobalt Nucleus Cobalt Nucleus Figure 1.3-2 Radioactive Activation Product Formation At Pilgrim Nuclear Power Station there were five independent protective barriers that confined radioactive materials during operation. These five barriers, which are shown in Figure 1.3-3 (Reference 5). Following the permanent shutdown and decommissioning of the plant in May of 2019 the only source of released radioactivity is that of the decay of radioactive activation products. Barriers like fuel pellets and cladding are no longer applicable. Building structures still play a part in shielding as discussed below.

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

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

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

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

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

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

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

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

More recently the option has been added to the ODCM (rev. 15) to be able to utilize the torus as a tank (as it no longer serves its original purpose to aid in reactor level/ pressure control) to hold water and process through means other than the established radwaste treatment system (e.g. Demineralizers previously used with in the condensate system) for purification prior to release.

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

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

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

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

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

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

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

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

reactor building ventilation system; sampling and analysis of reactor building vent effluents The purpose of the reactor building ventilation system is to collect and exhaust reactor building air. Air collected from contaminated areas is filtered prior to combining it with air collected from other parts of the building. This combined airflow is then directed to the reactor building ventilation plenum that is located on the side of the reactor building. A sample stream of the plenum flows through a sampling rack equipped with a particulate filter. Air samples are taken on a weekly frequency from the reactor building vent and are analyzed to quantify the total amount of tritium and radioactive particulate effluents released. This plenum, which vents to the atmosphere, was previously equipped with a gaseous radiation detector. The gaseous radiation monitor was removed from the ODCM in revision 15. All Noble gases have decayed away, save Kr-85 which is sealed in dry storage casks on the Independent Spent Fuel Storage Installation (ISFSI) II pad.

Therefore, for both liquid and gaseous releases, radioactive treatment systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable (ALARA). The effluents are always monitored, sampled, and analyzed prior to release to make sure that radioactivity levels are below the release limits. If the release limits are being approached, isolation valves in the liquid radwaste discharge line flow path will automatically shut to stop the release, or responsible personnel will implement procedures to ensure that federal regulatory limits are always met.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Note: There is no longer a fuel cycle, as normal operations ceased on May 31, 2019.

The summary of the 2022 radiological impact for Pilgrim Station and comparison with the EPA dose limits and guidelines, as well as a comparison with natural/man-made radiation levels, is presented in Section 3 of this report.

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

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2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.1 Pre-Operational Monitoring Results The Radiological Environmental Monitoring Program (REMP) at Pilgrim Nuclear Power Station was first initiated in August 1968, in the form of a pre-operational monitoring program prior to bringing the station on-line. The NRCs intent (Reference 11) with performing a pre-operational environmental monitoring program is to:

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

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

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

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

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

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

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

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

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

The environmental sampling media collected in the vicinity of Pilgrim Station during 2022 included air particulate filters, seawater, sediment, shellfish, American lobster, and fishes. The sampling medium, station description, station number, distance, and direction for indicator and control samples are listed in Table 2.2-1. These sampling locations are also displayed on the maps shown in Figures 2.2-1 through 2.2-6.

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

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

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

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

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

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

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

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

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

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

Specialized analysis of sediment for plutonium isotopes was removed.

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

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

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

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

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

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

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

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

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

The Teledyne Brown Engineering Laboratory conducts extensive quality assurance and quality control programs. The 2022 results of these programs are summarized in Appendix E. These results indicate that the analyses and measurements performed during 2022 exhibited acceptable precision and accuracy.

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2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2022. Data for each environmental medium are included in a separate section. A table that summarizes the years data for each type of medium follows a discussion of the sampling program and results. The unit of measurement for each medium is listed at the top of each table. The left hand column contains the radionuclides being reported, total number of analyses of that radionuclide, and the number of measurements that exceed ten times the yearly average for the control station(s). The latter are classified as "non-routine" measurements. The next column lists the Lower Limit of Detection (LLD) for those radionuclides that have detection capability requirements specified in the PNPS ODCM.

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

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

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

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

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

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

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

That background correction is then subtracted from the results for the analyses in that given set of samples. For example, if the blank/background sample produces 50 counts, and a given sample being analyzes produces 47 counts, then the net count for that sample is reported as -3 counts. That negative value of -3 counts is used to calculate the concentration of radioactivity for that particular analysis. Such a sample result is technically more valid than reporting a qualitative value such as <LLD (Lower limit of Detection) or NDA (No Detectable Activity).

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As an example of how to interpret data presented in the results tables, refer to the first entry on the table for air particulate filters (page 33). Gross beta (GR-B) analyses were performed on 312 routine samples. None of the samples exceeded ten times the average concentration at the control location.

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

For samples collected from the six indicator stations, 260 out of 260 samples indicated detectable gross beta activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 260 indicator station samples was 0.017 +/- 0.0048 (1.7E-2 +/- 4.8E-3) pCi/m3. Individual values ranged from 0.0692 to 0.033 (6.9E 3.3E-2) pCi/m3 The monitoring station which yielded the highest mean concentration was the sample location PL (Property Line), which yielded a mean concentration of 0.018 +/- 0.0055 pCi/m3, based on 52 detectable indications out of 52 samples observations. Individual values ranged from 0.0076 to 0.033 pCi/m 3.

At the control location, 52 out of 52 samples yielded detectable gross beta activity, for an average concentration of 0.018 +/- 0.0051 pCi/m3. Individual samples at the East Weymouth control location ranged from 0.0070 to 0.031 pCi/m3.

Analyses for cesium-137 (Cs-137) were performed 24 times (quarterly composites for 6 stations

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

At the indicator stations, all 20 of the Cs-137 measurements were below the detection level. The same was true for the four measurements made on samples collected from the control location.

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

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

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

Though the business area only or exclusion zone could physically be accessed, jersey barriers, signage and security tours would drastically limit the stay of a person with out proper authorization to be within the areas.

Out of the 176 TLDs posted in the environment during 2022, 155 were retrieved and processed for calculation of dose. The results for environmental TLDs located offsite, beyond the PNPS protected/restricted area fence, are presented in Table 2.4-1. Results from onsite TLDs posted within the restricted area are presented in Table 2.4-2. In addition to TLD results for individual locations, results from offsite TLDs were grouped according to geographic zone to determine average exposure Page 24

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

Annual exposure rates measured at locations beyond the PNPS protected area boundary ranged from 48 to 329 mR/yr. The average exposure rate at control locations greater than 15 km from Pilgrim Station (i.e., Zone 4) was 72.8 +/- 4.0 mR/yr. When the 3-sigma confidence interval is calculated based on these control measurements, 99% of all measurements of background ambient exposure would be expected to be between 60 and 84 mR/yr. The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 49 to 88 mR/yr, which compares favorably with the preoperational results of 37 - 190 mR/yr.

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

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

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

It should be noted that several of the TLDs used to calculate the Zone 1 averages presented in Table 2.4-3 are located on Pilgrim Station property. If the Zone 1 value is corrected for the near-site TLDs (those less than 0.6 km from the Reactor Building), the Zone 1 mean falls from a value of 97.5 +/- 92.2 mR/yr to 65.4 9.6 mR/yr. Additionally, exposure rates measured at areas beyond the sites control did not indicate any increase in ambient exposure from Pilgrim Station operation. For example, the annual exposure rate calculated from the TLD adjacent to the nearest offsite residence 0.80 kilometers (0.5 miles) southeast of the PNPS Reactor Building was 59.8 2.4 mR/yr, which is actually lower than the average control location exposure of 79.8 +/- 9.3 mR/yr.

In conclusion, measurements of ambient radiation exposure around Pilgrim Station do not indicate any significant increase in exposure levels. Although some increases and decreases in ambient radiation exposure level were apparent on site property very close to Pilgrim Station especially in areas where decommissioning components move between storage locations, there were no measurable increases at areas beyond the sites control.

2.5 Air Particulate Filter Radioactivity Analyses Airborne particulate radioactivity is sampled by drawing a stream of air through a glass fiber filter that has a very high efficiency for collecting airborne particulates. These samplers are operated continuously, and the resulting filters are collected weekly for analysis. Weekly filter samples are analyzed for gross beta radioactivity, and the filters are then composited on a quarterly basis for each location for gamma spectroscopy analysis. PNPS uses this technique to monitor locations in the Plymouth area, along with the control location in East Weymouth. At the start and end of 2022 six locations were monitored in total.

Out of 312 filters (6 locations

• 52 weeks), 312 samples were collected and analyzed during 2022.

There were no instances where power was lost or pumps failed during the course of the sampling period at any of the air sampling stations, which would result in lower than normal sample volumes. Any sample discrepancies are noted in Appendix D.

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The results of the analyses performed on these 312 filter samples are summarized in Table 2.5-1. Trend plots for the gross beta radioactivity levels at the near station, property line, and offsite airborne monitoring locations are shown in Figures 2.5-1, 2.5-2 and 2.5-3, respectively. Gross beta radioactivity was detected in 312 of the filter samples collected, including 53 of the 53 control location samples. This gross beta activity arises from naturally-occurring radionuclides such as radon decay daughter products. Naturally-occurring beryllium-7 was detected in 40 out of 40 of the quarterly composites analyzed with gamma spectroscopy. No airborne radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2022, and results of any detectable naturally-occurring radioactivity were similar to those observed in the properational monitoring program.

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

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

Broadleaf vegetation may still be consumed by humans, and it will be projected and accounted for in the dose modelling for all nuclides remaining that are released off site, but the only radionuclide detected in REMP samples while the plant was operating was Cs-137 from fall out (recently -

Chernobyl and Fukashima) which is deposited on and absorbed thru the roots of plants and trees and has a 30-year half-life.

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

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

A total of 32 samples of surface water were collected and analyzed as required during 2022. Bartlett Pond sample point was removed from the ODCM in the fourth Quarter 2019. Results of the analyses of water samples are summarized in Table 2.12-1. Naturally-occurring potassium-40 was detected in all monthly composite samples, especially those composed primarily of seawater. No radioactivity attributable to Pilgrim Station was detected in any of the surface water samples collected during 2022.

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

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

Eleven of twelve planned program samples of sediment were collected during 2022. The vendor was unable to obtain a sample at one location due to environmental conditions and access restrictions.

Gamma analyses were performed on these samples. Results of the gamma analyses of sediment samples are summarized in Table 2.13-1. Naturally-occurring potassium-40 was detected in all of the samples and actinium/thorium-228 were detected in 9 out of 11 samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2022, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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

Eight of the ten required samples of shellfish meat scheduled for collection during 2022 were obtained and analyzed. The vendor was unable to obtain a sample at one location due to environmental conditions and access restrictions. Results of the gamma analyses of these samples are summarized in Table 2.15-1. Naturally-occurring potassium-40 was detected in seven of the eight the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2022, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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

Five samples of lobsters were collected as required during 2022. Results of the gamma analyses of these samples are summarized in Table 2.16-1. Naturally-occurring potassium-40 was detected in five of the five of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2022, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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

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

Five samples of fish were collected during 2022. The seasonal sample of Group III fish (alewife, smelt, striped bass) from the Discharge Outfall becomes increasingly more difficult. Many fish species gravitated to the warmer waters. With the shutdown of the station the discharge flow and heat was reduced. These discrepancies are discussed in Appendix D. Results of the gamma analyses of fish samples collected are summarized in Table 2.17-1. The only radionuclide detected in any of the fish samples was naturally-occurring potassium-40. No radioactivity attributable to Pilgrim Station was detected in any of the fish samples collected during 2022, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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

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

2022 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/year Zone 1 TLDs: 0-3 km 0-3 km 26.0 +/- 28.5 24.1 +/- 21.4 24.3 +/- 22.2 23.3 +/- 20.7 97.5 +/- 92.2 BLW BOAT LAUNCH WEST 0.11 km E 47.3 +/- 2.8 31.5 +/- 2.8 30.0 +/- 1.1 29.7 +/- 1.4 138.5 +/- 34.2 OA OVERLOOK AREA 0.15 km W 26.7 +/- 1.6 130.4 +/- 12.4 135.6 +/- 10.6 127.4 +/- 6.8 420.1 +/- 210.1 TC HEALTH CLUB 0.15 km WSW 17.6 +/- 0.8 57.5 +/- 2.2 58.2 +/- 2.8 55.0 +/- 2.9 188.3 +/- 78.9 BLE BOAT LAUNCH EAST 0.16 km ESE 79.0 +/- 4.0 25.9 +/- 0.9 22.1 +/- 0.7 21.7 +/- 0.8 148.6 +/- 111.9 ISF-3 ISFSI-3 0.21 km W 160.1 +/- 4.9 Removed Removed Removed 160.1 +/- 4.9 P01 SHOREFRONT SECURITY 0.22 km NNW 17.2 +/- 0.6 29.2 +/- 1.5 30.6 +/- 2.2 30.4 +/- 2.5 107.4 +/- 26.0 ISF-2 ISFSI-2 0.28 km W 34.0 +/- 1.4 44.0 +/- 1.6 41.1 +/- 3.1 38.4 +/- 1.8 157.6 +/- 17.5 ISF-1 ISFSI-1 0.35 km SW 19.4 +/- 0.6 20.6 +/- 1.0 21.1 +/- 0.9 20.2 +/- 0.7 81.2 +/- 3.3 PA SHOREFRONT PARKING 0.35 km NNW 16.8 +/- 0.8 19.7 +/- 1.2 20.8 +/- 0.7 19.4 +/- 0.8 76.6 +/- 7.0 A STATION A 0.37 km WSW M+/-M 19.2 +/- 1.0 19.2 +/- 0.8 18.4 +/- 0.7 75.8 +/- 2.7 EB EAST BREAKWATER 0.44 km ESE 22.2 +/- 0.9 20.4 +/- 0.9 19.4 +/- 0.8 18.6 +/- 0.7 80.5 +/- 6.4 B STATION B 0.44 km S 21.4 +/- 0.8 21.3 +/- 0.9 21.2 +/- 1.0 20.4 +/- 0.8 84.3 +/- 2.6 PMT PNPS MET TOWER 0.44 km WNW 17.3 +/- 0.8 19.7 +/- 1.0 19.5 +/- 0.6 18.6 +/- 0.7 75.1 +/- 4.8 L STATION L 0.50 km ESE 27.6 +/- 1.4 17.0 +/- 0.6 16.2 +/- 0.6 16.4 +/- 0.7 77.3 +/- 22.3 G STATION G 0.53 km W M+/-M 15.1 +/- 0.7 16.2 +/- 0.6 15.3 +/- 0.6 62.1 +/- 2.9 PL PROPERTY LINE 0.54 km NW 18.0 +/- 0.9 19.0 +/- 0.8 20.0 +/- 0.8 18.9 +/- 0.8 75.9 +/- 3.6 HB HALL'S BOG 0.63 km SE 18.0 +/- 0.6 20.1 +/- 1.0 20.1 +/- 0.6 19.0 +/- 0.6 77.2 +/- 4.2 GH GREENWOOD HOUSE 0.65 km ESE 16.4 +/- 0.6 16.4 +/- 0.9 16.8 +/- 0.7 16.7 +/- 1.0 66.3 +/- 1.8 WR W ROCKY HILL ROAD 0.83 km WNW 21.8 +/- 1.1 21.6 +/- 1.1 22.5 +/- 1.0 22.1 +/- 1.1 88.0 +/- 2.6 ER E ROCKY HILL ROAD 0.89 km SE 14.3 +/- 0.6 15.2 +/- 0.6 14.8 +/- 0.5 15.5 +/- 0.8 59.8 +/- 2.4 CR CLEFT ROCK 1.27 km SSW 17.8 +/- 0.6 19.3 +/- 0.7 20.0 +/- 0.8 18.3 +/- 0.7 75.4 +/- 4.2 BD BAYSHORE/GATE RD 1.34 km WNW 18.3 +/- 0.6 18.5 +/- 0.6 18.5 +/- 0.9 17.6 +/- 0.7 72.9 +/- 2.2 EM EMERSON ROAD 1.53 km SSE 15.6 +/- 0.7 15.7 +/- 0.6 15.8 +/- 0.6 16.1 +/- 0.6 63.2 +/- 1.6 EP EMERSON/PRISCILLA 1.55 km SE 15.4 +/- 0.6 15.4 +/- 0.8 15.6 +/- 0.6 15.9 +/- 0.8 62.3 +/- 1.7 BS BAYSHORE 1.76 km W 18.0 +/- 1.0 18.0 +/- 0.6 18.7 +/- 0.7 17.9 +/- 0.8 72.6 +/- 2.1 JG JOHN GAULEY 1.99 km W 15.6 +/- 0.7 16.6 +/- 1.0 17.0 +/- 0.9 16.4 +/- 0.6 65.6 +/- 2.9 J STATION J 2.04 km SSE 13.8 +/- 0.6 14.8 +/- 0.6 15.6 +/- 0.5 15.0 +/- 0.8 59.1 +/- 3.4 RC PLYMOUTH YMCA 2.09 km WSW 14.3 +/- 0.5 15.1 +/- 0.5 15.7 +/- 0.7 15.3 +/- 0.7 60.4 +/- 2.7 TT TAYLOR/THOMAS 2.26 km SE M+/-M 15.7 +/- 1.0 15.0 +/- 0.7 15.3 +/- 0.6 61.4 +/- 2.3 YV YANKEE VILLAGE 2.28 km WSW 15.3 +/- 0.6 16.5 +/- 0.9 17.2 +/- 0.7 16.1 +/- 0.7 65.1 +/- 3.4 GN GOODWIN PROPERTY 2.38 km SW 11.9 +/- 0.6 12.4 +/- 0.6 13.0 +/- 0.8 12.1 +/- 0.5 49.4 +/- 2.3 RW RIGHT OF WAY 2.83 km S 13.1 +/- 0.6 13.4 +/- 0.5 13.5 +/- 0.5 12.7 +/- 0.6 52.7 +/- 1.8 TP TAYLOR/PEARL 2.98 km SE 14.6 +/- 0.5 14.5 +/- 0.5 15.1 +/- 0.6 14.9 +/- 0.8 59.1 +/- 1.6

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

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

• • • TLDs missing will be noted with M.

Page 30

Table 2.4-1 (continued)

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

2022 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/year Zone 2 TLDs: 3-8 km 3-8 km 16.4 +/- 0.4 17.4 +/- 0.7 16.9 +/- 1.2 17.0 +/- 0.8 67.6 +/- 2.8 ME MANOMET ELEM 3.29 km SE 16.4 +/- 0.4 17.0 +/- 0.7 16.1 +/- 0.9 M+/-M 66.0 +/- 2.5 MS MANOMET SUBSTATION 3.60 km SSE 16.3 +/- 0.6 17.7 +/- 0.8 17.7 +/- 0.6 17.0 +/- 0.8 68.7 +/- 2.9 Removed Removed Removed Removed Removed Zone 3 TLDs: 8-15 km 8-15 km Zone 4 TLDs: >15 km >15 km 17.1 +/- 1.0 19.7 +/- 1.9 20.0 +/- 1.4 20.5 +/- 1.2 77.4 +/- 7.0 DMF DIV MARINE FISH 20.97 km SSE 17.7 +/- 0.5 18.4 +/- 0.7 19.1 +/- 0.7 19.8 +/- 0.8 75.0 +/- 3.8 EW E WEYMOUTH SUBST 39.69 km NW 16.5 +/- 0.8 21.1 +/- 0.8 20.9 +/- 0.8 21.3 +/- 0.9 79.8 +/- 9.3

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

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

• • • TLDs missing will be noted with M.

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

2022 ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Annual**

Exposure mR/year Onsite TLDs P17 FENCE-EXEC.BUILDING 107 m W 38.6 +/- 2.5 288.6 +/- 18.9 196.4 +/- 11.1 189.4 +/- 6.2 713.0 +/- 414.6 P11 FENCE-TCF GATE 183 m ESE 101.8 +/- 7.7 36.4 +/- 1.2 30.7 +/- 1.0 37.6 +/- 1.3 206.5 +/- 134.6 P27 FENCE-TCF/BOAT RAMP 185 m ESE 57.0 +/- 3.5 25.4 +/- 1.2 22.0 +/- 0.7 21.6 +/- 0.7 126.0 +/- 68.4 P10 FENCE-TCF/INTAKE BAY 223 m E 91.8 +/- 3.2 29.8 +/- 1.4 21.6 +/- 0.8 21.4 +/- 0.9 164.7 +/- 136.1

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

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

• • • TLDs missing are noted with M.

-Components are quite frequently moved around site to different storage areas depending on station need. Due to this the quarters can fluctuate up and down accordingly.

Page 31

Table 2.4-3 Average TLD Exposures By Distance Zone During 2022 Average Exposure Standard Deviation: mR/period Exposure Zone 1* Zone 2 Zone 3 Zone 4 Period 0-3 km 3-8 km 8-15 km >15 km Jan-Mar 26.0 +/- 28.5 16.4 +/- 0.4 Removed 17.1 +/- 1.0 Apr-Jun 24.1 +/- 21.4 17.4 +/- 0.7 Removed 19.7 +/- 1.9 Jul-Sep 24.3 +/- 22.2 16.9 +/- 1.2 Removed 20.0 +/- 1.4 Oct-Dec 23.3 +/- 20.7 17.0 +/- (1) Removed 20.5 +/- 1.2 Jan-Dec 97.5 +/- 92.2 67.6 +/- 2.8 Removed 77.4 +/- 7.0

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

• • When corrected for TLDs located within the site boundary, the Zone 1 annual average is calculated to be 65.4 +/- 9.6 mR/yr.

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

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Table 2.5-1 Air Particulate Filter Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Gross Beta 312 0.01 1.7E-2 +/- 4.8E-3 EW: 1.8E-2 +/- 5.1E-3 1.8E-2 +/- 5.1E-3 0 6.9E 3.3E-2 7.0E 3.1E-2 7.0E 3.1E-2 260 / 260 52 / 52 52 / 52 Be-7 24 1.1E-1 +/- 2.3E-2 EW: 1.2E-1 +/- 1.4E-2 1.2E-1 +/- 1.4E-2 0 6.2E 1.4E-1 1.0E 1.3E-1 1.0E 1.3E-1 20 / 20 4/4 4/4 Cs-134 24 0.05 4.3E-5 +/- 5.4E-4 PL: 3.1E-4 +/- 3.5E-4 -4.8E-4 +/- 6.5E-4 0 -1.1E 9.2E-4 -2.5E 6.4E-4 -1.1E 2.3E-4 0 / 20 0/4 0/4 Cs-137 24 0.06 6.7E-5 +/- 5.0E-4 EB: 3.4E-4 +/- 3.4E-4 1.2E-4 +/- 3.2E-4 0 -1.1E 1.0E-3 7.1E 7.4E-4 -6.1E 4.7E-4 0 / 20 0/4 0/4

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

Page 33

Table 2.7-1 Vegetable/Vegetation Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

Page 34

Table 2.8-1 Surface Water Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD H-3 12 3000 -6.8E+1 +/- 1.2E+2 PwPt: -3.7E+1+/- 8.6E+1 -3.7E+1 +/- 8.6E+1 0 -2.1E+2 - 3.8E+1 -1.5E+2 - 5.1E+1 -1.5E+2 - 5.1E+1 0/8 0/4 0/4 K-40 24 2.8E+2 +/- 5.2E+1 PwPt: 2.9E+2 +/- 5.3E+1 2.9E+2 +/- 5.3E+1 0 2.2E+2 - 3.6E+2 2.0E+2 - 3.5E+2 2.0E+2 - 3.5E+2 12 / 12 12 / 12 12 / 12 Mn-54 24 15 -1.0E+0 +/- 2.3E+0 PwPt:7.0E-1 +/- 2.3E+0 7.0E-1 +/- 2.3E+0 0 -5.1E+0 - 3.6E+0 -3.8E+0 - 3.7E+0 -3.8E+0 - 3.7E+0 0 / 12 0 / 12 0 / 12 Fe-59 24 30 9.8E-1 +/- 3.9E+0 PwPt: 1.4E+0 +/- 5.9E+0 1.4E+0 +/- 5.9E+0 0 -8.0E+0 - 6.9E+0 -8.3E+0 - 1.4E+1 -8.3E+0 - 1.4E+1 0 / 12 0 / 12 0 / 12 Co-58 24 15 -2.2E-1 +/- 1.3E+0 Dis: -2.2E-1 +/- 1.3E+0 -2.3E-1 +/- 1.6E+0 0 -2.3E+0 - 1.6E+0 -2.3E+0 - 1.6E+0 -3.2E+0 - 1.8E+0 0 / 12 0 / 12 0 / 12 Co-60 24 15 1.6E+0 +/- 1.1E+0 Dis: 1.6E+0 +/- 1.1E+0 -2.2E-2 +/- 2.6E+0 0 -4.6E 3.6E+0 -4.6E 3.6E+0 -5.2E+0 - 3.4E+0 0 / 12 0 / 12 0 / 12 Zn-65 24 30 -3.2E+0 +/- 4.3E+0 PwPt: -3.1E+0 +/- 4.4E+0 -3.1E+0 +/- 4.4E+0 0 -1.1E+1 - 4.7E+0 -1.2E+1 - 4.7E+0 -1.2E+1 - 4.7E+0 0 / 12 0 / 12 0 / 12 Zr-95 24 30 9.2E-1 +/- 5.3E+0 Dis: 9.2E-1 +/- 5.3E+0 8.7E-1 +/- 3.9E+0 0 -9.8E+0 - 8.7E+0 -9.8E+0 - 8.7E+0 -5.3E+0 - 5.9E+0 0 / 12 0 / 12 0 / 12 Nb-95 24 15 8.4E-1 +/- 1.7E+0 Dis: 8.4E-1 +/- 1.7E+0 -4.3E-1 +/- 2.3E+0 0 -1.8E+0 - 3.7E+0 -1.8E+0 - 3.7E+0 -4.3E+0 - 2.8E+0 0 / 12 0 / 12 0 / 12 Cs-134 24 15 -2.3E-1 +/- 2.3E+0 PwPt: 8.8E-1 +/- 2.4E+0 8.8E-1 +/- 2.4E+0 0 -3.3E+0 - 3.5E+0 -2.9E+0 - 4.6E+0 -2.9E+0 - 4.6E+0 0 / 12 0 / 12 0 / 12 Cs-137 24 18 4.6E-1 +/- 2.0E+0 Dis: 4.6E-1 +/- 2.0E+0 -8.7E-1 +/- 2.6E+0 0 -2.0E+0 - 3.8E+0 -2.0E+0 - 3.8E+0 -4.7E+0 - 4.2E+0 0 / 12 0 / 12 0/ 12 Ba-140 24 60 -3.9E+0 +/- 2.6E+1 PwPt: 2.3E+0 +/- 2.1E+1 2.3E+0 +/- 2.1E+1 0 -4.9E+1 - 4.0E+1 -3.3E+1 - 4.1E+1 -3.3E+1 - 4.1E+1 0 / 12 0 / 12 0 / 12 La-140 24 15 1.4E+0 +/- 6.8E+0 PwPt: 2.0E+0 +/- 7.0E+0 2.0E+0 +/- 7.0E+0 0 -1.5E+1 - 8.9E+0 -5.1E+0 - 1.8E+1 -5.1E+0 - 1.8E+1 0 / 12 0 / 12 0 / 12

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

Page 35

Table 2.9-1 Sediment Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 11 9.6E+3 +/- 1.9E+3 DuxBay:1.7E+4 +/- 5.4E+3 1.4E+4 +/- 4.8E+3 0 8.0E+3 - 1.3E+4 1.4E+4 - 2.1E+4 1.1E+4 - 2.1E+4 7/7 2/2 4/4 Cs-134 11 150 2.6E+1 +/- 1.3E+1 PlyHrb: 3.9E+1 +/- 1.7E+1 1.6E+1 +/- 1.9E+1 0 1.1E+1 - 4.7E+1 3.0E+1 - 4.7E+1 -5.7E+0 - 3.1E+1 0/ 8 0/2 0/4 Cs-137 11 180 1.1E+0 +/- 2.7E+1 DuxBay: 2.6E+1 +/- 1.9E+1 4.0E+0 +/- 2.8E+1 0 -4.9E+1 - 3.3E+1 1.5E+1 - 3.7E+1 -2.1E+1 - 3.7E+1 0/8 0/2 0/4 AcTh-228 11 2.7E+2 +/- 1.1E+2 DuxBay: 7.9E+2 +/- 1.1E+2 6.0E+2 +/- 2.3E+2 0 1.7E+2 - 4.3E+2 7.3E+2 - 8.6E+2 3.9E+2 - 8.6E+2 5/ 5 2/2 4/4

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

Page 36

Table 2.10-1 Shellfish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 8 1.5E+3 +/- 1.6E+2 PlyHrb: 1.5E+3 +/- 1.8E+2 1.4E+3 +/- 2.6E+2 0 1.4E+3 - 1.6E+3 1.4E+3 - 1.6E+3 1.0E+3 - 1.6E+3 4/ 4 3/ 3 4/4 Mn-54 8 130 2.7E+0 +/- 1.3E+1 PlyHrb: 7.2E+0 +/- 1.1E+1 -6.1E+0 +/- 8.6E+0 0 -1.1E+1 - 1.3E+1 -2.8E+0 - 1.3E+1 -1.5E+1 - -1.0E+0 0/4 0/3 0/4 Fe-59 8 260 -1.1E+1 +/- 2.7E+1 GrnHrb: 8.5E+0 +/- 6.1E+1 5.2E+0 +/- 3.7E+1 0 -4.0E+1 - 2.0E+1 -3.3E+1 - 5.0E+1 -3.3E+1 - 5.0E+1 0/4 0/2 0/4 Co-58 8 130 -8.9E+0 +/- 2.3E+1 GrnHrb: 8.8E+0 +/- 1.2E+1 1.6E+0 +/- 1.7E+1 0 -3.3E+1 - 2.0E+1 3.2E+0 - 1.4E+1 -2.1E+1 - 1.4E+1 0/4 0/4 0/4 Co-60 8 130 -6.9E-2 +/- 7.7E+0 Dis: 2.1E+0 +/- 1.2E+1 -1.3E+1 +/- 9.0E+0 0 -5.3E+0 - 6.5E+0 2.1E+0 - 2.1E+0 -1.8E+1 - -5.6E+0 0/4 0/1 0/4 Zn-65 8 260 -7.0E+1 +/- 6.9E+1 Dis: 6.0E+0 +/- 2.4E+1 -7.7E+1 +/- 5.3E+1 0 -1.2E+2 - 6.0E+0 6.0E+0 - 6.0E+0 -1.3E+2 - -1.0E+1 0/4 0/1 0/4 Cs-134 8 130 -1.2E+1 +/- 2.5E+1 GrnHrb: 4.4E+0 +/- 9.4E+0 1.5E-1 +/- 2.2E+1 0 -4.1E+1 - 1.8E+1 4.3E+0 - 4.5E+0 -2.9E+1 - 2.1E+1 0/4 0/ 2 0/4 Cs-137 8 150 -1.1E+1 +/- 2.1E+1 GrnHrb: 9.5E+0 +/- 1.5E+1 2.4E+0 +/- 2.9E+1 0 -2.6E+1 - 1.8E+1 1.5E+0 - 1.7E+1 -3.7E+1 - 2.7E+1 0/4 0/4 0/4

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

Page 37

Table 2.11-1 Lobster Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 5 2.7E+3 +/- 3.7E+2 Dis: 2.7E+3 +/- 3.7E+2 2.5E+3 +/- 3.0E+2 0 2.2E+3 - 3.1E+3 2.2E+3 - 3.1E+3 2.5E+3 - 2.5E+3 4/4 4/4 1/1 Mn-54 5 130 3.1E+0 +/- 5.4E+0 CcBay: 1.6E+1 +/- 1.1E+1 1.6E+1 +/- 1.1E+1 0 3.7E 7.5E+0 1.6E+1 - 1.6E+1 1.6E+1 - 1.6E+1 0/4 0/1 0/1 Fe-59 5 260 1.1E+1 +/- 2.6E+1 CcBay: 1.9E+1 +/- 2.4E+1 1.9E+1 +/- 2.4E+1 0 -1.0E+1 - 4.6E+1 1.9E+1 - 1.9E+1 1.9E+1 - 1.9E+1 0/4 0/1 0/1 Co-58 5 130 7.1E+0 +/- 1.4E+1 CcBay: 3.2E+1 +/- 1.3E+1 3.2E+1 +/- 1.3E+1 0 -1.1E+1 - 2.1E+1 3.2E+1 - 3.2E+1 3.2E+1 - 3.2E+1 0/4 0/1 0/1 Co-60 5 130 4.8E+0 +/- 6.2E+0 Dis: 4.8E+0 +/- 6.2E+0 -3.6E+1 +/- 1.3E+1 0 2.0E 1.1E+1 2.0E 1.1E+1 -3.6E+1 - -3.6E+1 0/4 0/4 0/1 Zn-65 5 260 -4.2E+1 +/- 1.9E+1 Dis: -4.2E+1 +/- 1.9E+1 -6.3E+1 +/- 3.1E+1 0 -6.5E+1 - -2.9E+1 -6.5E+1 - -2.9E+1 -6.3E+1 - -6.3E+1 0/4 0/4 0/1 Cs-134 5 130 -3.3E-1 +/- 4.9E+0 Dis: -3.3E-1 +/- 4.9E+0 -3.8E+0 +/- 1.5E+1 0 -2.9E+0 - 1.7E+0 -2.9E+0 - 1.7E+0 -3.8E+0 - -3.8E+0 0/4 0/4 0/1 Cs-137 5 150 -4.6E+0 +/- 1.0E+1 CcBay: 2.8E+1 +/- 1.1E+1 2.8E+1 +/- 1.1E+1 0 -1.7E+1 - 4.0E+0 2.8E+1 - 2.8E+1 2.8E+1 - 2.8E+1 0/4 0/1 0/1

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

Page 38

Table 2.12-1 Fish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2022)

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 5 3.3E+3 +/- 4.7E+2 BuzBay: 3.7E+3 +/- 1.6E+3 3.7E+3 +/- 1.6E+3 0 3.0E+3 - 3.6E+3 2.0E+3 - 4.7E+3 2.0E+3 - 4.7E+3 2/2 3/3 3/3 Mn-54 5 130 -8.0E+0 +/- 8.5E+0 BuzBay: 1.1E+1 +/- 1.6E+1 1.1E+1 +/- 1.6E+1 0 -8.6E+0 - -7.4E+0 -1.9E+0 - 2.4E+1 -1.9E+0 - 2.4E+1 0/2 0/3 0/3 Fe-59 5 260 4.4E+1 +/- 1.9E+1 Dis: 4.4E+1 +/- 1.9E+1 2.6E+1 +/- 7.4E+1 0 4.2E+1 - 4.7E+1 4.2E+1 - 4.7E+1 -4.9E+1 - 9.4E+1 0/2 0/2 0/3 Co-58 5 130 -6.6E+0 +/- 1.2E+1 BuzBay: 3.6E+0 +/- 1.8E+1 3.6E+0 +/- 1.8E+1 0 -1.3E+1 - -2.5E-1 -1.4E+1 - 1.6E+1 -1.4E+1 - 1.6E+1 0/2 0/ 3 0/3 Co-60 5 130 -8.9E+0 +/- 2.3E+1 BuzBay: 7.1E+0 +/- 1.4E+1 7.1E+0 +/- 1.4E+1 0 -2.4E+1 - 6.4E+0 -4.3E+0 - 1.9E+1 -4.3E+0 - 1.9E+1 0/2 0/3 0/3 Zn-65 5 260 -6.2E+1 +/- 4.5E+1 BuzBay: -4.5E+1 +/- 6.0E+1 -4.5E+1 +/- 6.0E+1 0 -9.0E+1 - -3.3E+1 -8.8E+1 - 1.9E+1 -8.8E+1 - 1.9E+1 0/2 0/3 0/3 Cs-134 5 130 -6.9E+0 +/- 1.8E+1 BuzBay: -1.2E+0 +/- 2.6E+1 -1.2E+0 +/- 2.6E+1 0 -1.8E+1 - 3.7E+0 -2.9E+1 - 1.8E+1 -2.9E+1 - 1.8E+1 0/2 0/3 0/3 Cs-137 5 150 -4.1E+0 +/- 1.7E+1 BuzBay: 1.8E+1 +/- 2.3E+1 1.8E+1 +/- 2.3E+1 0 -1.4E+1 - 6.1E+0 4.9E+0 - 4.2E+1 4.9E+0 - 4.2E+1 0/2 0/3 0/3

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

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

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

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

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Figure 2.2-1 (continued)

Environmental TLD Locations Within the PNPS Protected Area Page 41

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

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

Figure 2.2-2 (continued)

TLD and Air Sampling Locations: Within 1 Kilometer Page 43

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

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

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

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Figure 2.2-3 (continued)

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

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

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

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

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Figure 2.2-4 (continued)

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

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

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

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

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Figure 2.2-5 (continued)

Marine/Aquatic Sampling Locations Page 49

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

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

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

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Figure 2.2-6 (continued)

Environmental Sampling And Measurement Control Locations Page 51

Figure 2.5-1 Airborne Gross-Beta Radioactivity Levels: Near Station Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2022 AP-07 Pedestrian Bridge AP-09 East Breakwater AP-21 East Weymouth Control Page 52

Figure 2.5-2 Airborne Gross-Beta Radioactivity Levels: Property Line Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2022 AP-01 E. Rocky Hill Road AP-06 Property Line AP-21 East Weymouth Control Page 53

Figure 2.5-3 Airborne Gross-Beta Radioactivity Levels: Offsite Monitors 4.E-02 3.E-02 picoCuries/cubic meter 2.E-02 1.E-02 0.E+00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2022 AP-10 Cleft Rock AP-21 East Weymouth Control

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

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3.0

SUMMARY

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

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

The first method utilizes data from the radioactive effluents (measured at the point of release) together with conservative models that calculate the dispersion and transport of radioactivity through the environment to humans (Reference 7). The second method is based on actual measurements of radioactivity in the environmental samples and on dose conversion factors recommended by the Nuclear Regulatory Commission. The measured types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during 2022 were reported to the Nuclear Regulatory Commission within the stations Annual Radiological Effluent Release Report (ARERR). The measured levels of radioactivity in the special studies environmental samples that required dose calculations are listed in Appendix A.

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

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

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

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

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

external radiation from cloud shine and submersion in gaseous effluents; inhalation of airborne radioactivity; external radiation from soil deposition; consumption of vegetables; and consumption of milk and meat. Note: There are no milk/ meat animals in the vicinity Pilgrim Station The results from the dose calculations based on PNPS operations are presented in Table 3.0-1. The dose assessment data presented were taken from the "Radioactive Effluent Release Report" for the period of January 1 through December 31, 2022 (Reference 17).

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Table 3.0-1 Radiation Doses from 2022 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway - mrem/yr Gaseous Liquid Ambient Receptor Effluents* Effluents Radiation** Total Total Body 0.000068 N/A 0.16 0.16 Max. Organ 0.000070 N/A 0.16 0.16

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

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

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

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

As can be seen from the doses resulting from Pilgrim Station decommissioning operations during 2022, all values are well within the federal limits specified by the NRC and EPA. In addition, the calculated doses from PNPS operation represent only a fraction of a percent of doses from natural and man-made radiation.

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

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4.0 REFERENCES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

17) Pilgrim Nuclear Power Station, Annual Radioactive Effluent Release Report, May 2022.

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APPENDIX A SPECIAL STUDIES There were no environmental samples collected during 2022 that contained plant-related radioactivity.

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

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

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

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

Within the air sampling program, there were no instances in which continuous sampling was interrupted at airborne sampling locations during 2022. There was only one instance (01 Feb 2023) where the filter changeout had a two week run time instead of require one week due to area access issues. This event did not have any significant impact on the scope and purpose of the sampling program, and lower limits of detection (LLDs) were met for airborne particulates on all 311 filters collected. In the fourth quarter of 2019, following the permanent shutdown of the station, the use of charcoal cartridges at air sample locations was discontinued as iodine had decayed away.

Out of 312 filters 311 samples were collected and analyzed during 2022. In accordance with ODCM Table 3.5-1, offsite REMP air particulate filters are to be collected at a weekly interval. Weekly is defined as once every seven days with a one-day grace period before and after the scheduled date. occasionally samples are collected with a longer than seven day interval due to access (especially in the winter) or some other issue. It must be emphasized that the station continued to sample during the duration and no monitoring time was lost.

The configuration of air samplers that had been in use at Pilgrim Station since the early 1980s, was replaced between June and August of 2012. Both the pumps and dry gas meters were replaced, and operating experience since changing over to the new configuration has been favorable. Although the occurrence of pump failures and gas meter problems have been largely eliminated, the new configuration is still subject to trips of the ground fault interrupt circuit (GFCI). Such problems can be encountered at air samplers located at the East Breakwater and Pedestrian Bridge. Both of these locations are immediately adjacent to the shoreline and are subject to significant wind-blown salt water, and are prone to tripping of the GFCI. In 2021 the air sample station at the Pedestrian Bridge was modified to increase the capabilities of collecting a representative sample after observations during an NRC inspection of the REMP program. The following table contains a listing the discrepancies encountered with air sampling stations during 2022.

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Location Sampling Sampling Problem Description/Resolution Period Hours Lost EW 2/1-2/8/22 0 Two week collection due to access issues caused by snow Group III fishes, consisting of alewife, smelt, or striped bass are normally collected once each year in the summer from the vicinity of the Discharge Canal Outfall. Since the shut down of Pilgrim station the warm water plume of the discharge, which drew in fish species like the Striped Bass, has dissipated and is no longer present. Fish species once in such abundance to bring in harbor seals and sharks behind them are no longer found in the plant area. Repeated and concerted efforts were made to collect these species, but failed to produce all required samples. Group I (autumn) and Group III (autumn) fish could not be collected.

Issues were encountered when attempting to sample sediment and shellfish due to environmental conditions due negative tides, several unsuccessful attempts were made resulting in fewer program samples.

In summary, the various problems encountered in collecting and analyzing environmental samples during 2022 were relatively minor when viewed in the context of the entire monitoring program. These discrepancies were promptly corrected when issue was identified, where possible. None of the discrepancies resulted in an adverse impact on the overall monitoring program.

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APPENDIX E Teledyne Brown Engineering Environmental Services Annual 2022 Quality Assurance Report

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

SUMMARY

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

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2022 ................. 3 A. General Discussion ............................................................................................. 3 B. Result Trending .................................................................................................. 4 IV. STATUS OF EDC CONDITION REPORTS (CR) ........................................................... 4 V. STATUS OF AUDITS/ASSESSMENTS .......................................................................... 4 A. Internal................................................................................................................ 4 B. External .............................................................................................................. 4 VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2022 ... 4 VII. CONCLUSION AND RECOMMENDATIONS ................................................................. 4 VIII. REFERENCES ............................................................................................................... 4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS LIST OF TABLES Page

1. Percentage of Individual Analyses Which Passed EDC Internal Criteria, January - December 2022 5

2. Mean Dosimeter Analyses (n=6), January - December 2022 5

3. Summary of Independent QC Results for 2022 5

-ii-

EXECUTIVE

SUMMARY

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

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

One internal assessment was performed in 2022.There were no findings.

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

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

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

Results of these tests are described in this report.

Excluded from this report are instrumentation checks. Although instrumentation checks represent an important aspect of the quality assurance program, they are not included as process checks in this report. Instrumentation checks represent between 5-10% of the TLDs processed.

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

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

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

Hi Hi 100 Hi where:

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

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

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

Hi Hi 1 100 n

Hi where:

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

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

Hi H 100 H

where:

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

n = the number of dosimeters in the test group

3. EDC Internal Tolerance Limits All evaluation criteria are taken from the EDC Quality System Manual, (Reference 2). These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs-137) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +/-

12.8% for precision.

2of 6

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

1. No investigation is necessary when an individual QC result falls outside the QC performance criteria for accuracy.

2. Investigations are initiated when the mean of a QC processing batch is outside the performance criterion for bias.

C. Reporting of Environmental Dosimetry Results to EDC Customers

1. All results are to be reported in a timely fashion.

4. If the QA Officer determines that an investigation is required for a process, the results shall be issued as normal. If the QC results prompting the investigation have a mean bias from the known of greater than +/-20%, the results shall be issued with a note indicating that they may be updated in the future, pending resolution of a QA issue.

5. Environmental dosimetry results do not require updating if the investigation has shown that the mean bias between the original results and the corrected results, based on applicable correction factors from the investigation, does not exceed +/-20%.

III. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2022 A. General Discussion Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4.

Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period100% (72/72) of the individual dosimeters, evaluated against these criteria, met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision. A graphical interpretation is provided in Figures 1 and 2.

Table 2 provides the bias and standard deviation results for each group (N=6) of dosimeters evaluated against the internal tolerance criteria. Overall,100% (12/12) of the dosimeter sets, evaluated against the internal tolerance performance criteria, met these criteria. A graphical interpretation is provided in Figure 3.

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

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

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

IV. STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period.

V. STATUS OF AUDITS/ASSESSMENTS

1. Internal EDC Internal Quality Assurance Assessment was conducted during the fourth quarter 2022. There were no findings identified.

2. External None.

VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2022 Two procedures were reissued with no changes as part of the 5 year review cycle.

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

VIII. REFERENCES

1. EDC Quality Control and Audit Assessment Schedule, 2022.

2. EDC Manual 1, Quality System Manual, Rev. 4, September 28, 2020.

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TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 2022(1), (2)

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

This table summarizes results of tests conducted by EDC.

(2)

Environmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES (N=6)

JANUARY - DECEMBER 2022(1), (2)

Standard Tolerance Process Date Exposure Level Mean Bias %

Deviation % Limit +/-15%

4/25/2022 43 1.2 1.8 Pass 4/27/2022 62 6.2 1.0 Pass 5/05/2022 99 2.3 0.7 Pass 7/26/2022 34 -2.6 1.2 Pass 7/27/2022 81 0.6 1.7 Pass 8/07/2022 107 -3.5 0.7 Pass 10/27/2022 52 1.8 0.9 Pass 11/02/2022 76 2.0 0.9 Pass 11/07/2022 27 7.0 0.7 Pass 01/24/2023 38 1.5 1.7 Pass 01/26/2023 115 -0.3 2.0 Pass 02/14/2023 49 2.3 4.0 Pass (1)

This table summarizes results of tests conducted by EDC for TLDs issued in 2022.

(2)

Environmental dosimeter results are free in air.

TABLE 3

SUMMARY

OF INDEPENDENT DOSIMETER TESTING JANUARY - DECEMBER 2022(1), (2)

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

st 1 Qtr. 2022 Millstone -0.6 0.6 Pass 2nd Qtr.2022 Millstone -3.9 1.0 Pass 3rd Qtr. 2022 Millstone 0.1 0.5 Pass 4th Qtr.2022 Millstone -2.6 1.2 Pass 4th Qtr.2022 PSEG(PNNL) 48mR 1.1 1.5 Pass 4th Qtr.2022 PSEG(PNNL) 95mR 0.7 0.3 Pass 4th Qtr.2022 PSEG(PNNL) 143mR 2.3 0.8 Pass 4th Qtr.2022 PSEG(PNNL) 190mR 1.4 0.8 Pass 4th Qtr.2022 SONGS -5.6 1.1 Pass (1)

Performance criteria are +/- 15%.

(2)

Blind spike irradiations using Cs-137 5of 6

APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2022 6of 6

APPENDIX D Environmental Dosimetry Company Annual 2022 Quality Assurance Status Report

TELEDYNE BROWN ENGINEERING A Teledyne Technologies Company TELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES Knoxville Laboratory 4th Quarter 2022 QUALITY ASSURANCE REPORT January - December 2022 Teledyne Brown Engineering 2508 Quality Lane Knoxville, TN 37931-3133 Downloaded or Printed copies are UNCONTROLLED copies

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4th Quarter 2022 Quality Assurance Report Review and Signatures Quality Assurance Manager: YJ otfau,/43 Contractual Review / ShJron L. Northcutt Date Laboratory Operations Manager:

Technical Review Downloaded or Printed copies are UNCONTROLLED copies

TABLE OF CONTENTS I. INTRODUCTION ......................................................................................................... 1 A. Operational Quality Control Scope......................................................................... 1

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

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

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

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

2. Intralaboratory Accuracy Acceptance Criteria ................................................. 4

3. Investigations and Nonconformance Reports .................................................. 6 II. ANALYTICAL SERVICES QUALITY CONTROL SYNOPSIS ..................................... 7 A. Interlaboratory Cross-Check Program ................................................................... 7 B. Intralaboratory Cross-Check Program ................................................................... 8

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

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

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

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

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

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

I. INTRODUCTION This report covers the Quality Assurance (QA) Program for the Analytical Services function of the Teledyne Brown Engineering Environmental Services (TBE-ES) laboratory for January through December 2022.

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

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

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

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

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

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

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

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

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

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

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

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

Audits have been performed by NUPIC, Perry Johnson Laboratory Accreditation (PJLA) for ISO 17025 accreditation and BWXT. Audit results are included in Attachment D.2.

B. Performance Characteristics

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

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

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

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

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

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

Acceptable (flag = A) Bias <= 20%

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

Not Acceptable (flag = N) Bias > 30%

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

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

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

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

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

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

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

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

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

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

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

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

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

2. Intralaboratory Accuracy Acceptance Criteria a) Process Controls The measure of accuracy for a group of test measurements to a given spike level is found by calculating the recovery of the spike activity found 4

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versus the added spike activity. The percent recovery is calculated as follows:

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

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

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

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

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

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

% RPD = (abs[orig - dup] / [orig + dup]/2) x 100 Matrix spike duplicates are split samples spiked with identical concentrations of a target analyte and are used to evaluate precision and bias. The matrix spike duplicate recovery is expressed as a percentage:

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

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

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

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

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

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

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

1. Analytics Environmental Cross Check Program Twelve nuclides were evaluated in air particulate, charcoal filter, milk and soil matrices during this reporting period. All analyses were within acceptable criteria except for one AP Ce-141 and one AP Co-60 (first failure for each).

NCRs 22-04 and 22-21 were initiated and closed. All raw and associated QC data was reviewed and found to be within acceptable limits. (See Attachment C for NCR detail)

2. DOEs MAPEP Quality Assessment Program Fourteen nuclides in water, air particulate (AP), soil, urine and vegetation samples were evaluated in January - December 2022. All of the environmental analyses performed were evaluated as within the acceptable/acceptable with warning criteria except for the urine U-234 & U-238 and water Tc-99 (first failure for each). NCRs 22-05 and 22-22 were initiated and closed. (See Attachment C for NCR detail)

NOTE: The soil Tc-99 result for 1st quarter was not within the acceptable range and is not on the ICP list. The 3rd quarter sample result was acceptable.

(TBE is running this for our information only at this point.)

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

Eighteen nuclides were evaluated in water, soil, and air particulate samples during 2022. All analyses performed were within acceptable criteria except for the MRAD 3rd quarter AP Pu-238 and RAD 4th quarter water U Natural. NCRs 22-19 and 22-20 were initiated and closed. All raw and associated QC data was reviewed and found to be within acceptable limits. (See Attachment C for NCR detail)

NOTE: The soil U-238 result for 3rd quarter was not within the acceptable range and is not on the ICP list. (TBE is running this for our information only at this point.)

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

The TBE-ES laboratory's internal process control program evaluated 7,251 analyses during this period.

1. Blanks During this reporting period, 1,597/1,5999 blanks analyzed were less than the MDC. One workgroup blank for Sr-90 and one for S-35 was above the MDC. The workgroups included samples whose activity was greater than 5x the blank. Positive blank activities were reported with a case narrative.

2. Spikes During this reporting period, all 1,564 workgroup and matrix spikes analyzed were within the acceptance criteria.

3. Duplicates All of the 4,088 duplicate sets analyzed were within acceptance criteria.

C. Non-Conformance Reports (NCRs)

Twenty-two NCRs were initiated, and corrective action completed in 2022. Copies are included in Attachment C.

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

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

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

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2. Liquid Scintillation Counters (LSC):

LSC instruments, used in tritium, carbon-14, nickel-63 and other low-energy beta-emitters, are monitored for background and efficiency. The reliability of these instruments is exceptional with zero instances of background or efficiency values outside of control limits.

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

GFP detectors used for gross alpha/beta, strontium-89/90, iodine-131 (low level) and other nuclides are monitored for background and efficiency. These detectors operated without incident during this reporting period. Occasionally, second runs (primarily for alpha due to the sensitivity of source placement) were necessary to verify acceptable operation or because of low P-10 pressure. After gas change-out and purging, control check values return to control norms.

4. Alpha Spectroscopy:

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

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

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

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

Month/Year Matrix Nuclide Units Reported Evaluation Number Value (a) Analytics Result Value March 2022 E13706 Milk Sr-89 pCi/L 80.3 96.8 0.83 A Sr-90 pCi/L 12.7 12.6 1.01 A E13707 Milk Ce-141 pCi/L 62.3 65 0.96 A Co-58 pCi/L 158 164 0.96 A Co-60 pCi/L 286 302 0.95 A Cr-51 pCi/L 314 339 0.93 A Cs-134 pCi/L 155 182 0.85 A Cs-137 pCi/L 210 223 0.94 A Fe-59 pCi/L 211 185 1.14 A I-131 pCi/L 88.0 96.7 0.91 A Mn-54 pCi/L 169 164 1.03 A Zn-65 pCi/L 238 246 0.97 A E13708 Charcoal I-131 pCi 79.9 87.1 0.92 A E13709 AP Ce-141 pCi 60.9 42.0 1.45 N(1)

Co-58 pCi 118 107 1.11 A Co-60 pCi 218 196 1.11 A Cr-51 pCi 251 221 1.14 A Cs-134 pCi 129 118 1.09 A Cs-137 pCi 156 145.0 1.07 A Fe-59 pCi 124 120.0 1.03 A Mn-54 pCi 120 107 1.12 A Zn-65 pCi 162 160 1.01 A E13710 Soil Ce-141 pCi/g 0.123 0.103 1.19 A Co-58 pCi/g 0.254 0.263 0.97 A Co-60 pCi/g 0.493 0.483 1.02 A Cr-51 pCi/g 0.603 0.543 1.11 A Cs-134 pCi/g 0.268 0.292 0.92 A Cs-137 pCi/g 0.399 0.431 0.93 A Fe-59 pCi/g 0.320 0.296 1.08 A Mn-54 pCi/g 0.263 0.263 1.00 A Zn-65 pCi/g 0.407 0.395 1.03 A E13711 AP Sr-89 pCi 83.2 97.4 0.85 A Sr-90 pCi 12.7 12.7 1.00 A (a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits:

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

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

Month/Year Matrix Nuclide Units Reported Evaluation Number Value (a) Analytics Result Value September 2022 E13712 Milk Sr-89 pCi/L 71.1 89.1 0.80 A Sr-90 pCi/L 12.0 13.6 0.88 A E13713 Milk Ce-141 pCi/L 148 161 0.92 A Co-58 pCi/L 178 189 0.94 A Co-60 pCi/L 229 260 0.88 A Cr-51 pCi/L 486 456 1.07 A Cs-134 pCi/L 220 252 0.87 A Cs-137 pCi/L 203 222 0.92 A Fe-59 pCi/L 174 173 1.01 A I-131 pCi/L 75.9 94.2 0.81 A Mn-54 pCi/L 269 282 0.95 A Zn-65 pCi/L 364 373 0.97 A E13714 Charcoal I-131 pCi 81.4 83.6 0.97 A E13715 AP Ce-141 pCi 102 91 1.12 A Co-58 pCi 118 107 1.11 A Co-60 pCi 207 147 1.41 N(2)

Cr-51 pCi 310 257 1.21 W Cs-134 pCi 148 142 1.04 A Cs-137 pCi 137 125 1.10 A Fe-59 pCi 115 98 1.18 A Mn-54 pCi 168 159 1.05 A Zn-65 pCi 240 211 1.14 A E13716 Soil Ce-141 pCi/g 0.288 0.284 1.01 A Co-58 pCi/g 0.320 0.334 0.96 A Co-60 pCi/g 0.445 0.459 0.97 A Cr-51 pCi/g 0.883 0.805 1.10 A Cs-134 pCi/g 0.410 0.446 0.92 A Cs-137 pCi/g 0.447 0.465 0.96 A Fe-59 pCi/g 0.314 0.305 1.03 A Mn-54 pCi/g 0.489 0.499 0.98 A Zn-65 pCi/g 0.666 0.660 1.01 A E13717 AP Sr-89 pCi 87.5 98.3 0.89 A Sr-90 pCi 12.6 15.0 0.84 A (a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits:

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

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

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

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

Number Value (a) Range Value February 2022 22-GrF46 AP Gross Alpha Bq/sample 0.402 1.20 0.36 - 2.04 A Gross Beta Bq/sample 0.669 0.68 0.341 - 1.022 A 22-MaS46 Soil Ni-63 Bq/kg 645 780 546 - 1014 A Tc-99 Bq/kg 526 778 545 - 1011 N(3) 22-MaSU46 Urine Cs-134 Bq/L 1.67 1.77 1.24 - 2.30 A Cs-137 Bq/L 1.50 1.56 1.09 - 2.03 A Co-57 Bq/L 4.93 5.39 3.77 - 7.01 A Co-60 Bq/L 2.13 2.06 1.44 - 2.68 A Mn-54 Bq/L 4.83 5.08 3.56 - 6.60 A U-234 Bq/L 0.142 0.0074 0.0052 - 0.0096 N(4)

U-238 Bq/L 0.0254 0.0103 0.0072 - 0.0134 N(4)

Zn-65 Bq/L 4.71 4.48 3.14 - 5.82 A 22-MaW46 Water Ni-63 Bq/L 28.6 34.0 23.8 - 44.2 A Tc-99 Bq/L 8.59 7.90 5.5 - 10.3 A 22-RdV46 Vegetation Cs-134 Bq/sample 6.61 7.61 5.33 - 9.89 A Cs-137 Bq/sample 1.50 1.52 1.06 - 1.98 A Co-57 Bq/sample 5.11 5.09 3.56 - 6.62 A Co-60 Bq/sample 0.0162 (1) A Mn-54 Bq/sample 2.42 2.59 1.81 - 3.37 A Sr-90 Bq/sample 0.684 0.789 0.552 - 1.026 A Zn-65 Bq/sample 1.44 1.47 1.03 - 1.91 A August 2022 22-MaS47 Soil Ni-63 Bq/kg 14.6 (1) A Tc-99 Bq/kg 994 1000 700 - 1300 A 22-MaW47 Water Ni-63 Bq/L 24.4 32.9 23.0 - 42.8 A Tc-99 Bq/L 1.9 (1) N(5) 25-RdV47 Vegetation Cs-134 Bq/sample 0.032 (1) A Cs-137 Bq/sample 0.891 1.08 0.758 - 1.408 A Co-57 Bq/sample 0.006 (1) A Co-60 Bq/sample 4.04 4.62 3.23 - 6.01 A Mn-54 Bq/sample 2.01 2.43 1.70 - 3.16 A Sr-90 Bq/sample 1.25 1.60 1.12 - 2.08 W Zn-65 Bq/sample 6.16 7.49 5.24 - 9.74 A (a) The MAPEP known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) DOE/MAPEP evaluation:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (1) False positive test (2) Sensitivity evaluation (3) Tc-99 soil cross-checks done for TBE information only - not required (4) See NCR 22-05 Downloaded or Printed copies are UNCONTROLLED copies (Page 1 of 1)

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

A.3 ERA Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services Identification TBE Reported Known Acceptance Month/Year Matrix Nuclide Units (a) Evaluation (b)

Number Value Value Limits March 2022 MRAD-36 Water Am-241 pCi/L 68.3 74.6 51.2 - 95.4 A Fe-55 pCi/L 797 1140 670 - 1660 A Pu-238 pCi/L 146 147 88.4 - 190 A Pu-239 pCi/L 69.9 71.9 44.5 - 88.6 A Soil Sr-90 pCi/kg 8050 6720 2090 - 10500 A AP Fe-55 pCi/filter 148 127 46.4 - 203 A Pu-238 pCi/filter 29.9 29.6 22.3 - 36.4 A Pu-239 pCi/filter 51.6 49.7 37.2 - 60.0 A U-234 pCi/filter 59.9 67.3 49.9 - 78.9 A U-238 pCi/filter 59.0 66.7 50.4 - 79.6 A GR-A pCi/filter 95.6 94.2 49.2 - 155 A GR-B pCi/filter 71.2 66.8 40.5 - 101 A April 2022 RAD-129 Water Ba-133 pCi/L 61.7 62.9 52.3 - 69.2 A Cs-134 pCi/L 80.9 81.6 68.8 - 89.8 A Cs-137 pCi/L 37.4 36.6 32.1 - 43.3 A Co-60 pCi/L 103 97.4 87.7 - 109 A Zn-65 pCi/L 318 302 272 - 353 A GR-A pCi/L 26.9 20.8 10.4 - 28.3 A GR-B pCi/L 49.7 51.0 34.7 - 58.1 A U-Nat pCi/L 56.3 68.9 56.3 - 75.8 A H-3 pCi/L 17,000 18,100 15,800 - 19,000 A Sr-89 pCi/L 65.3 67.9 55.3 - 76.1 A Sr-90 pCi/L 42.1 42.7 31.5 - 49.0 A I-131 pCi/L 25.7 26.2 21.8 - 30.9 A September 2022 MRAD-37 Water Am-241 pCi/L 111 96.2 66.0 - 123 A Fe-55 pCi/L 850 926 544 - 1350 A Pu-238 pCi/L 62.1 52.6 31.6 - 68.2 A Pu-239 pCi/L 139.5 117 72.5 - 144 A Soil Sr-90 pCi/kg 3350 6270 1950 - 9770 A U-234 pCi/kg 1684 3350 1570 - 4390 A (2)

U-238 pCi/kg 1658 3320 1820 - 4460 N AP Fe-55 pCi/filter 71.9 122 44.5 - 195 A Pu-238 pCi/filter 38.8 29.9 22.6 - 36.7 N(1)

Pu-239 pCi/filter 14.5 13.0 9.73 - 15.7 A U-234 pCi/filter 78.0 71.5 53.0 - 83.8 A U-238 pCi/filter 79.7 70.9 53.5 - 84.6 A GR-A pCi/filter 62.8 55.5 29.0 - 91.4 A GR-B pCi/filter 70.9 64.8 39.3 - 97.9 A October 2022 RAD-131 Water Ba-133 pCi/L 76.2 79.4 66.6 - 87.3 A Cs-134 pCi/L 28.0 30.5 23.9 - 33.6 A Cs-137 pCi/L 202 212 191 - 235 A Co-60 pCi/L 52.4 51.4 46.3 - 59.1 A Zn-65 pCi/L 216 216 194 - 253 A GR-A pCi/L 19.7 16.9 8.28 - 23.7 A GR-B pCi/L 49.8 53.0 36.1 - 60.0 A (3)

U-Nat pCi/L 10.54 8.53 6.60 - 9.88 N H-3 pCi/L 13,900 15,100 13,200 - 16,600 A Sr-89 pCi/L 59.7 64.5 52.3 - 72.5 A Sr-90 pCi/L 32.9 37.3 27.4 - 43.0 A I-131 pCi/L 26.9 24.4 20.2 - 28.9 A (a) The ERA known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation.

(b) ERA evaluation:

A = Acceptable - Reported value falls within the Acceptance Limits N = Not Acceptable - Reported value falls outside of the Acceptance Limits (1) See NCR 22-19 (2) U soil cross-checks done for TBE information only - not required (3) See NCR 22-20 Downloaded or Printed copies are UNCONTROLLED copies (Page 1 of 1)

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

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

~(TELE01) Teledyne Brown Engineering - Environmental Services~

Department of Energy RESL - 1955 Fremont Ave, MS4149 - Idaho Falls, ID 83415 Laboratory Results For MAPEP Series 46 (TELE01) Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-6819 MAPEP-22-GrF46: Gross alpha/beta air filter Radiological Units: (Bq/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Gross alpha .402 1.20 A -66.5 0.36 - 2.04 .0497 A Gross beta .669 0.681 A -1.8 0.341 - 1.022 .0521 A Radiological Reference Date: February 1, 2022 MAPEP-22-MaS46: Radiological and inorganic combined soil standard Inorganic Units: (mg/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 0.16 Sensitivity Evaluation Arsenic NR 35.2 24.6 - 45.8 Barium NR 341 239 - 443 Beryllium NR 59.1 41.4 - 76.8 Cadmium NR 11.7 8.2 - 15.2 Chromium NR 110 77 - 143 Cobalt NR 245 172 - 319 Copper NR 195 137 - 254 Lead NR 72.8 51.0 - 94.6 Mercury NR 0.322 0.225 - 0.419 Nickel NR 347 243 - 451 Selenium NR 0.36 Sensitivity Evaluation Silver NR 10.6 7.4 - 13.8 Technetium-99 NR 0.00123 0.00086 - 0.00160 Thallium NR 75.0 52.5 - 97.5 Uranium-235 NR 0.0330 0.0231 - 0.0429 Uranium-238 NR 9.9 6.9 - 12.9 Uranium-Total NR 9.9 6.9 - 12.9 Vanadium NR 215 151 - 280 Zinc NR 288 202 - 374 Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 72.0 50.4 - 93.6 Cesium-134 NR 890 623 - 1157 Cesium-137 NR 365 256 - 475 Issued 6/13/2022 Printed 6/13/2022 Downloaded or Printed copies are UNCONTROLLED copies

Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Cobalt-57 NR 1400 980 - 1820 Cobalt-60 NR 443 310 - 576 Iron-55 NR 1100 770 - 1430 Manganese-54 NR 1140 798 - 1482 Nickel-63 645 780 A -17.3 546 - 1014 44.6 A Plutonium-238 NR 56.0 39.2 - 72.8 Plutonium-239/240 NR 41.0 28.7 - 53.3 Potassium-40 NR 596 417 - 775 Strontium-90 NR 677 474 - 880 Technetium-99 526 778 N -32.4 545 - 1011 49.2 A Thorium-228 NR 43 30 - 56 Thorium-230 NR 38 27 - 49 Thorium-232 NR 42 29 - 55 Uranium-234 NR 44.0 30.8 - 57.2 Uranium-238 NR 123 86 - 160 Zinc-65 NR False Positive Test Radiological Reference Date: February 1, 2022 MAPEP-22-MaSU46: Radiological urine standard Mass Units: (ng/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Uranium-235 NR 4.14 2.90 - 5.38 Uranium-238 NR 828 580 - 1076 Uranium-Total NR 832 582 - 1082 Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.0018 Sensitivity Evaluation Cesium-134 1.67 1.77 A -5.7 1.24 - 2.30 .172 A Cesium-137 1.5 1.56 A -3.8 1.09 - 2.03 .298 W Cobalt-57 4.93 5.39 A -8.5 3.77 - 7.01 .239 A Cobalt-60 2.13 2.06 A 3.4 1.44 - 2.68 .203 A Curium-244 NR False Positive Test Manganese-54 4.83 5.08 A -4.9 3.56 - 6.60 .288 A Nickel-63 NR 6.44 4.51 - 8.37 Plutonium-238 NR 0.0042 Sensitivity Evaluation Plutonium-239/240 NR 0.291 0.204 - 0.378 Strontium-90 NR 1.26 0.88 - 1.64 Technetium-99 NR False Positive Test Uranium-234 .142 0.0074 N 1818.9 0.0052 - 0.0096 .0177 A Uranium-238 .0254 0.0103 N 146.6 0.0072 - 0.0134 .00697 W Zinc-65 4.71 4.48 A 5.1 3.14 - 5.82 .56 A Radiological Reference Date: February 1, 2022 Issued 6/13/2022 Printed 6/13/2022 Downloaded or Printed copies are UNCONTROLLED copies

MAPEP-22-MaW46: Radiological and inorganic combined water standard Inorganic Units: (mg/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 10.22 7.15 - 13.29 Arsenic NR 3.37 2.36 - 4.38 Barium NR 0.041 Sensitivity Evaluation Beryllium NR 1.95 1.37 - 2.54 Cadmium NR False Positive Test Chromium NR 3.29 2.30 - 4.28 Cobalt NR 12.5 8.8 - 16.3 Copper NR 15.3 10.7 - 19.9 Lead NR 1.57 1.10 - 2.04 Mercury NR 0.152 0.106 - 0.198 Nickel NR 8.22 5.75 - 10.69 Selenium NR 0.81 0.57 - 1.05 Technetium-99 NR 1.26E-5 8.80E 1.64E-5 Thallium NR 1.04 0.73 - 1.35 Uranium-235 NR 9.1E-4 6.37E 1.18E-3 Uranium-238 NR 0.124 0.087 - 0.161 Uranium-Total NR 0.125 0.088 - 0.163 Vanadium NR 4.9 3.4 - 6.4 Zinc NR 10.2 7.1 - 13.3 Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.355 0.249 - 0.462 Cesium-134 NR False Positive Test Cesium-137 NR 7.64 5.35 - 9.93 Cobalt-57 NR 36.0 25.2 - 46.8 Cobalt-60 NR 9.3 6.5 - 12.1 Hydrogen-3 NR 300 210 - 390 Iron-55 NR 15.2 10.6 - 19.8 Manganese-54 NR 18.9 13.2 - 24.6 Nickel-63 28.6 34.0 A -15.9 23.8 - 44.2 .481 N Plutonium-238 NR 1.07 0.75 - 1.39 Plutonium-239/240 NR 1.19 0.83 - 1.55 Potassium-40 NR False Positive Test Radium-226 NR 0.8 0.6 - 1.0 Strontium-90 NR 12.9 9.0 - 16.8 Technetium-99 8.59 7.9 A 8.7 5.5 - 10.3 1.52 W Uranium-234 NR 1.5 1.1 - 2.0 Uranium-238 NR 1.54 1.08 - 2.00 Zinc-65 NR 26.2 18.3 - 34.1 Radiological Reference Date: February 1, 2022 MAPEP-22-RdV46: Radiological vegetation Issued 6/13/2022 Printed 6/13/2022 Downloaded or Printed copies are UNCONTROLLED copies

Inorganic Units: (ug/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Uranium-235 NR 0.0434 0.0304 - 0.0564 Uranium-238 NR 5.95 4.17 - 7.74 Uranium-Total NR 5.99 4.19 - 7.79 Radiological Units: (Bq/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.101 0.071 - 0.131 Cesium-134 6.61 7.61 A -13.1 5.33 - 9.89 .267 A Cesium-137 1.5 1.52 A -1.3 1.06 - 1.98 .148 A Cobalt-57 5.11 5.09 A 0.4 3.56 - 6.62 .188 A Cobalt-60 .0162 A False Positive Test .0775 Manganese-54 2.42 2.59 A -6.6 1.81 - 3.37 .235 A Plutonium-238 NR 0.027 0.019 - 0.035 Plutonium-239/240 NR 0.0594 0.0416 - 0.0772 Strontium-90 .684 0.789 A -13.3 0.552 - 1.026 .0229 A Uranium-234 NR 0.071 0.050 - 0.092 Uranium-238 NR 0.074 0.052 - 0.096 Zinc-65 1.44 1.47 A -2.0 1.03 - 1.91 .344 W Radiological Reference Date: February 1, 2022 Issued 6/13/2022 Printed 6/13/2022 Downloaded or Printed copies are UNCONTROLLED copies

~(TELE01) Teledyne Brown Engineering - Environmental Services~

Department of Energy RESL - 1955 Fremont Ave, MS4149 - Idaho Falls, ID 83415 Laboratory Results For MAPEP Series 47 (TELE01) Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-6819 MAPEP-22-MaS47: Radiological and inorganic combined soil standard Inorganic Units: (mg/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 7.8 5.5 - 10.1 Arsenic NR 13.9 9.7 - 18.1 Barium NR 280 196 - 364 Beryllium NR 8.78 6.15 - 11.41 Cadmium NR 10.0 7.0 - 13.0 Chromium NR 49.1 34.4 - 63.8 Cobalt NR 60.0 42.0 - 78.0 Copper NR 59.0 41.3 - 76.7 Lead NR 51.0 35.7 - 66.3 Mercury NR 0.235 0.165 - 0.306 Nickel NR 194 136 - 252 Selenium NR 11.1 7.8 - 14.4 Silver NR 52.9 37.0 - 68.8 Technetium-99 NR 0.00158 0.00111 - 0.00205 Thallium NR 64.4 45.1 - 83.7 Uranium-235 NR 0.0389 0.0272 - 0.0506 Uranium-238 NR 12.6 8.8 - 16.4 Uranium-Total NR 12.7 8.9 - 16.5 Vanadium NR 122 85 - 159 Zinc NR 127 89 - 165 Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 99.2 69.4 - 129.0 Cesium-134 NR 627 439 - 815 Cesium-137 NR False Positive Test Cobalt-57 NR 786 550 - 1022 Cobalt-60 NR False Positive Test Iron-55 NR 740 518 - 962 Manganese-54 NR 841 589 - 1093 Nickel-63 14.6 A False Positive Test 17.5 Plutonium-238 NR 0.56 Sensitivity Evaluation Plutonium-239/240 NR 113 79 - 147 Plutonium-241 NR 26.8 Sensitivity Evaluation Potassium-40 NR 537 376 - 698 Issued 12/15/2022 Printed 12/15/2022 Downloaded or Printed copies are UNCONTROLLED copies

Radiological Units: (Bq/kg)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Strontium-90 NR 852 596 - 1108 Technetium-99 994 1000 A -0.6 700 - 1300 85.4 A Thorium-228 NR 49 34 - 64 Thorium-230 NR 43 30 - 56 Thorium-232 NR 47 33 - 61 Uranium-234 NR 50.8 35.6 - 66.0 Uranium-238 NR 157 110 - 204 Zinc-65 NR 1140 798 - 1482 Radiological Reference Date: August 1, 2022 MAPEP-22-MaW47: Radiological and inorganic combined water standard Inorganic Units: (mg/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Antimony NR 4.77 3.34 - 6.20 Arsenic NR 1.53 1.07 - 1.99 Barium NR 2.34 1.64 - 3.04 Beryllium NR 3.27 2.29 - 4.25 Cadmium NR 0.634 0.444 - 0.824 Chromium NR 3.49 2.44 - 4.54 Cobalt NR 6.01 4.21 - 7.81 Copper NR 6.72 4.70 - 8.74 Lead NR 2.11 1.48 - 2.74 Mercury NR 0.124 0.087 - 0.161 Nickel NR 4.02 2.81 - 5.23 Selenium NR False Positive Test Technetium-99 NR False Positive Test Thallium NR 0.000017 Sensitivity Evaluation Uranium-235 NR 5.05E-4 3.54E 6.57E-4 Uranium-238 NR 0.068 0.048 - 0.088 Uranium-Total NR 0.068 0.048 - 0.088 Vanadium NR 3.37 2.36 - 4.38 Zinc NR 3.62 2.53 - 4.71 Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.327 0.229 - 0.425 Cesium-134 NR 17.1 12.0 - 22.2 Cesium-137 NR 16.8 11.8 - 21.8 Cobalt-57 NR 30.0 21.0 - 39.0 Cobalt-60 NR 17.0 11.9 - 22.1 Hydrogen-3 NR 395 277 - 514 Iron-55 NR 27.8 19.5 - 36.1 Manganese-54 NR False Positive Test Nickel-63 24.4 32.9 W -25.8 23.0 - 42.8 1.17 A Issued 12/15/2022 Printed 12/15/2022 Downloaded or Printed copies are UNCONTROLLED copies

Radiological Units: (Bq/L)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Plutonium-238 NR 0.985 0.690 - 1.281 Plutonium-239/240 NR 1.070 0.749 - 1.391 Potassium-40 NR False Positive Test Radium-226 NR 0.511 0.358 - 0.664 Strontium-90 NR 7.73 5.41 - 10.05 Technetium-99 1.86 N (1) False Positive Test .414 Uranium-234 NR 1.37 0.96 - 1.78 Uranium-238 NR 0.84 0.59 - 1.09 Zinc-65 NR 11.3 7.9 - 14.7 Radiological Reference Date: August 1, 2022 MAPEP-22-RdV47: Radiological vegetation Inorganic Units: (ug/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Uranium-235 NR 0.076 0.053 - 0.099 Uranium-238 NR 10.5 7.4 - 13.7 Uranium-Total NR 10.5 7.4 - 13.7 Radiological Units: (Bq/sample)

Ref Bias Acceptance Unc Unc Analyte Result Value Flag Notes (%) Range Value Flag Americium-241 NR 0.189 0.132 - 0.246 Cesium-134 .0321 A False Positive Test 0.1058 Cesium-137 0.891 1.083 A -17.7 0.758 - 1.408 0.169 W Cobalt-57 0.005817 A False Positive Test 0.0543 Cobalt-60 4.04 4.62 A -12.6 3.23 - 6.01 0.189 A Manganese-54 2.01 2.43 A -17.3 1.70 - 3.16 0.245 A Plutonium-238 NR 0.156 0.109 - 0.203 Plutonium-239/240 NR 0.162 0.113 - 0.211 Strontium-90 1.25 1.60 W -21.9 1.12 - 2.08 0.0413 A Uranium-234 NR 0.126 0.088 - 0.164 Uranium-238 NR 0.130 0.091 - 0.169 Zinc-65 6.16 7.49 A -17.8 5.24 - 9.74 0.549 A Radiological Reference Date: August 1, 2022 Notes:

(1) = False Positive Issued 12/15/2022 Printed 12/15/2022 Downloaded or Printed copies are UNCONTROLLED copies

Ver. 1 Page 8 of 11 MRAD-36 Final Evaluation Report Sharon Northcutt EPA ID: TN11387 QA Manager ERA Customer Number: T200801 Teledyne Brown Engineering Report Issued: 05/24/2022 2508 Quality Ln. Study Dates: 03/21/2022 - 05/20/2022 Knoxville, TN 37931 (865) 934-0374 TNI Study Reported Assigned Acceptance Performance Analysis Study Analyte Analyte Units Method Description Z Score Standard Analyst Name Value Value Limits Evaluation Date Mean Code Deviation MRAD Soil Radionuclides (cat# 802, lot# A036-608) 2700 Actinium-228 pCi/kg 1670 1100 - 2100 Not Reported 1550 186 2755 Americium-241 pCi/kg 1310 707 - 1850 Not Reported 1420 418 2772 Bismuth-212 pCi/kg 1840 527 - 2740 Not Reported 1700 356 2773 Bismuth-214 pCi/kg 790 379 - 1180 Not Reported 790 132 2800 Cesium-134 pCi/kg 6620 4530 - 7910 Not Reported 6030 907 2805 Cesium-137 pCi/kg 6760 5110 - 8550 Not Reported 6840 1020 2815 Cobalt-60 pCi/kg 2820 2220 - 3480 Not Reported 2830 418 2902 Lead-212 pCi/kg 1630 1140 - 2060 Not Reported 1620 195 2903 Lead-214 pCi/kg 838 352 - 1320 Not Reported 838 164 2905 Manganese-54 pCi/kg < 555 0.00 - 555 Not Reported 2930 Plutonium-238 pCi/kg 289 144 - 439 Not Reported 382 123 2932 Plutonium-239 pCi/kg 1180 643 - 1700 Not Reported 1250 377 2946 Potassium-40 pCi/kg 37900 26100 - 45300 Not Reported 40400 2780 Downloaded or Printed copies are UNCONTROLLED copies HASL 300 Sr-03 28th ED 3005 Strontium-90 pCi/kg 8050 6720 2090 - 10500 Acceptable 1997 5/3/2022 0.396 7510 1350 3028 Thorium-234 pCi/kg 3390 1280 - 5810 Not Reported 3840 692 3036 Uranium-234 pCi/kg 3410 1600 - 4470 Not Reported 3460 408 3038 Uranium-238 pCi/kg 3390 1860 - 4550 Not Reported 3540 274 3055 Uranium-Total pCi/kg 6960 3860 - 9000 Not Reported 6840 346 1184 Uranium (mass) g/kg 10100 4560 - 13600 Not Reported 10100 1520 3070 Zinc-65 pCi/kg 5070 4050 - 6920 Not Reported 5330 929 16341 Table Mountain Pkwy

• Golden, CO 80403

• 800.372.0122

• 303.431.8454

• fax 303.421.0159

• www.eraqc.com Study # : MRAD-36

Ver. 1 Page 9 of 11 MRAD-36 Final Evaluation Report Sharon Northcutt EPA ID: TN11387 QA Manager ERA Customer Number: T200801 Teledyne Brown Engineering Report Issued: 05/24/2022 2508 Quality Ln. Study Dates: 03/21/2022 - 05/20/2022 Knoxville, TN 37931 (865) 934-0374 TNI Study Reported Assigned Acceptance Performance Analysis Study Analyte Analyte Units Method Description Z Score Standard Analyst Name Value Value Limits Evaluation Date Mean Code Deviation MRAD Air Filter Radionuclides (cat# 800, lot# A036-606) 2755 Americium-241 pCi/Filter 21.0 15.0 - 28.0 Not Reported 21.2 0.926 2800 Cesium-134 pCi/Filter 549 356 - 673 Not Reported 486 31.0 2805 Cesium-137 pCi/Filter 1320 1080 - 1730 Not Reported 1390 97.9 2815 Cobalt-60 pCi/Filter 885 752 - 1120 Not Reported 922 66.4 2885 Iron-55 pCi/Filter 148 127 46.4 - 203 Acceptable TBE Proprietary 4/21/2022 0.688 126 31.6 2905 Manganese-54 pCi/Filter < 35.0 0.00 - 35.0 Not Reported 2930 Plutonium-238 pCi/Filter 29.9 29.6 22.3 - 36.4 Acceptable TBE Proprietary 4/14/2022 1.36 28.5 0.995 2932 Plutonium-239 pCi/Filter 51.6 49.7 37.2 - 60.0 Acceptable TBE Proprietary 4/14/2022 1.59 47.2 2.75 3005 Strontium-90 pCi/Filter 31.1 19.7 - 42.3 Not Reported 32.3 3.99 3036 Uranium-234 pCi/Filter 59.9 67.3 49.9 - 78.9 Acceptable TBE Proprietary 4/19/2022 -1.29 64.9 3.90 3038 Uranium-238 pCi/Filter 59.0 66.7 50.4 - 79.6 Acceptable TBE Proprietary 4/19/2022 -1.61 64.1 3.18 3055 Uranium-Total pCi/Filter 137 100 - 162 Not Reported 133 5.01 1184 Uranium (mass) g/Filter 200 160 - 234 Not Reported 193 7.68 Downloaded or Printed copies are UNCONTROLLED copies 3070 Zinc-65 pCi/Filter 671 550 - 1030 Not Reported 756 59.1 MRAD Air Filter Gross Alpha/Beta (cat# 801, lot# A036-607) 2830 Gross Alpha pCi/Filter 95.6 94.2 49.2 - 155 Acceptable EPA 900.0 1980 4/27/2022 0.678 87.2 12.4 2840 Gross Beta pCi/Filter 71.2 66.8 40.5 - 101 Acceptable EPA 900.0 1980 4/27/2022 0.225 68.9 10.4 16341 Table Mountain Pkwy

• Golden, CO 80403

• 800.372.0122

• 303.431.8454

• fax 303.421.0159

• www.eraqc.com Study # : MRAD-36

Ver. 1 Page 10 of 11 MRAD-36 Final Evaluation Report Sharon Northcutt EPA ID: TN11387 QA Manager ERA Customer Number: T200801 Teledyne Brown Engineering Report Issued: 05/24/2022 2508 Quality Ln. Study Dates: 03/21/2022 - 05/20/2022 Knoxville, TN 37931 (865) 934-0374 TNI Study Reported Assigned Acceptance Performance Analysis Study Analyte Analyte Units Method Description Z Score Standard Analyst Name Value Value Limits Evaluation Date Mean Code Deviation MRAD Water Radionuclides (cat# 804, lot# A036-617)

HASL 300 Am-03 28th ED 2755 Americium-241 pCi/L 68.3 74.6 51.2 - 95.4 Acceptable 1997 4/21/2022 -0.327 70.7 7.32 2800 Cesium-134 pCi/L 1720 1300 - 1890 Not Reported 1590 101 2805 Cesium-137 pCi/L 1120 959 - 1270 Not Reported 1120 35.4 2815 Cobalt-60 pCi/L 2710 2340 - 3110 Not Reported 2770 90.7 2885 Iron-55 pCi/L 797 1140 670 - 1660 Acceptable TBE Proprietary 4/21/2022 -0.334 938 422 2905 Manganese-54 pCi/L < 71.0 0.00 - 71.0 Not Reported HASL 300 Pu-10 28th ED 2930 Plutonium-238 pCi/L 146 147 88.4 - 190 Acceptable 1997 4/14/2022 1.12 130 14.6 HASL 300 Pu-10 28th ED 2932 Plutonium-239 pCi/L 69.9 71.9 44.5 - 88.6 Acceptable 1997 4/14/2022 0.994 63.7 6.23 3005 Strontium-90 pCi/L 628 452 - 776 Not Reported 624 34.0 3036 Uranium-234 pCi/L 44.1 33.6 - 50.4 Not Reported 41.9 2.79 3038 Uranium-238 pCi/L 43.7 33.9 - 51.4 Not Reported 41.9 1.83 3055 Uranium-Total pCi/L 89.8 70.0 - 102 Not Reported 85.0 3.52 1184 Uranium (mass) g/L 131 106 - 149 Not Reported 123 5.69 Downloaded or Printed copies are UNCONTROLLED copies 3070 Zinc-65 pCi/L 1220 1090 - 1540 Not Reported 1290 51.9 16341 Table Mountain Pkwy

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• fax 303.421.0159

• www.eraqc.com Study # : MRAD-36

Ver. 1 Page 8 of 9 RAD-129 Final Evaluation Report Sharon Northcutt EPA ID: TN11387 QA Manager ERA Customer Number: T200801 Teledyne Brown Engineering Report Issued: 05/23/2022 2508 Quality Ln. Study Dates: 04/04/2022 - 05/19/2022 Knoxville, TN 37931 (865) 934-0374 TNI Study Reported Assigned Acceptance Performance Analysis Study Analyte Analyte Units Method Description Z Score Standard Analyst Name Value Value Limits Evaluation Date Mean Code Deviation RAD Gamma EmitterS' (cat# 808, lot# R129-758) 2765 Barium-133 pCi/L 61.7 62.9 52.3 - 69.2 Acceptable EPA 901.1 1980 4/11/2022 0.152 61.1 3.66 2800 Cesium-134 pCi/L 80.9 81.6 66.8 - 89.8 Acceptable EPA 901.1 1980 4/11/2022 -0.191 82.0 5.69 2805 Cesium-137 pCi/L 37.4 36.6 32.1 - 43.3 Acceptable EPA 901.1 1980 4/11/2022 -0.272 38.0 2.35 2815 Cobalt-60 pCi/L 103 97.4 87.7 - 109 Acceptable EPA 901.1 1980 4/11/2022 0.739 100 3.47 3070 Zinc-65 pCi/L 318 302 272 - 353 Acceptable EPA 901.1 1980 4/11/2022 0.435 313 11.7 RAD GroSS' Alpha/Beta (cat# 809, lot# R129-759) 2830 Gross Alpha pCi/L 26.9 20.8 10.4 - 28.3 Acceptable EPA 900.0 (GPC) 1 2018 4/14/2022 3.69 17.6 2.53 2840 Gross Beta pCi/L 49.7 51.0 34.7 - 58.1 Acceptable EPA 900.0 (GPC) 1 2018 4/20/2022 1.00 45.0 4.67 RAD NaturalS' (cat# 811, lot# R129-751) 2965 Radium-226 pCi/L 9.46 7.09 - 11.1 Not Reported 9.55 1.13 2970 Radium-228 pCi/L 3.18 1.71 - 4.63 Not Reported 3.17 0.678 3055 Uranium (Nat) pCi/L 56.3 68.9 56.3 - 75.8 Acceptable EPA 908.0 1980 4/27/2022 -5.11 66.0 1.89 1184 Uranium (mass) g/L 101 82.5 - 111 Not Reported 96.4 4.24 Downloaded or Printed copies are UNCONTROLLED copies RAD TritiuM' (cat# 812, lot# R129-752) 3030 Tritium pCi/L 17000 18100 15800 - 19900 Acceptable EPA 906.0 1980 4/8/2022 -0.713 17700 988 RAD Strontium-89/90 (cat# 807, lot# R129-757) 2995 Strontium-89 pCi/L 65.3 67.9 55.3 - 76.1 Acceptable EPA 905.0 1980 5/3/2022 -0.792 71.3 7.53 3005 Strontium-90 pCi/L 42.1 42.7 31.5 - 49.0 Acceptable EPA 905.0 1980 5/4/2022 0.187 41.3 4.41 RAD Iodine-131 (cat# 810, lot# R129-750)

SM 7500-I C (GPC)-2000 2875 Iodine-131 pCi/L 25.7 26.2 21.8 - 30.9 Acceptable 2000 4/14/2022 -0.638 26.7 1.63 All analytes are included in ERAs A2LA accreditation. Lab Code: 1539-01 16341 Table Mountain Pkwy

• Golden, CO 80403

• 800.372.0122

• 303.431.8454

• fax 303.421.0159

• www.eraqc.com Study # : RAD-129

Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Intentionally Left Blank Downloaded or Printed copies are UNCONTROLLED copies

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

B.1 Blanks, Spikes and Matrix Spikes Downloaded or Printed copies are UNCONTROLLED copies

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

1. of Samples Nuclide Blank Results Recovery % Within 20% of Analyzed (Range*) Known Value Am-241 35 All < MDC 78.9 - 102 91.4 C-14 96 All < MDC 71.5 - 121 70.5 Ce-144 (RAD) 32 All < MDC NA Cs-137 18 All < MDC 72.9 - 109 94.4 Co-60 (Direct) 3 All < MDC 96.8 - 99.4 100 Fe-55 116 All < MDC 72.6 - 125 87.1 Gross Alpha 145 All < MDC 70.5 - 114 62.8 Gross Beta 107 All < MDC 74.0 - 129 87.9 H-3 342 All < MDC 70.1 - 129 88.6 I-129/131 99 All < MDC 74.2 - 124 89.0 Ni-63 115 All < MDC 72.5 - 124 93.9 P-32 19 All < MDC NA Pu-239/240 36 All < MDC 79.5 - 122 94.4 S-35 (RAD) 6 All < MDC(1) NA Sr-89 139 All < MDC 80.5 - 130 87.8 Sr-90 175 All < MDC(1) 80.2 - 129 89.7 Tc-99 49 All < MDC 74.7 - 105 91.8 Th-230 19 All < MDC 78.5 - 115 89 U-238 45 All < MDC 83.3 - 119 100 1

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

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

Nuclide Count Date (pCi/L) (pCi/L) (pCi/L) Recovery**

Fe-55 02/10/22 <186 1252 1470 85.3 Fe-55 05/18/22 <115 1183 1320 89.4 Fe-55 08/25/22 <94.0 1068 1240 86.1 Fe-55 12/29/22 <76.60 1200 1160 103.2 Gr-A 02/02/22 4.23 50.8 52.2 89.2 Gr-A 05/05/22 1.65 46.7 52.2 86.3 Gr-A 08/15/22 2.71 41.6 52.2 74.5 Gr-A 12/27/22 2.22 40.1 42.8 88.6 Gr-B 01/31/22 22.5 58.4 55.8 64.4 Gr-B 05/04/22 8.45 58.4 55.2 90.4 Gr-B 08/11/22 9.70 49.0 54.9 71.6 Gr-B 12/20/23 11.60 71.1 54.6 109.0 H-3 01/26/22 <293 4000 3920 102 H-3 05/09/22 <273 5600 7670 73.0 H-3 08/16/22 <282 4150 3780 109.8 H-3 12/20/23 <285 5130 3730 137.7 Ni-63 02/09/22 <4.50 1020 1300 78.4 Ni-63 05/20/22 5.75 877 865 100.8 Ni-63 08/24/22 <4.17 800 863 92.7 Ni-63 12/30/23 <4.87 899 862 104.3 Sr-89 03/10/22 < 8.25 1180 1220 96.6 Sr-89 05/17/22 <7.3 179 163 109.8 Sr-89 09/08/22 <6.56 63.1 45.5 138.7 Sr-89 12/28/23 <7.52 230 327 70.4 Sr-90 03/10/22 <0.85 51.3 54.3 94.5 Sr-90 05/17/22 <0.997 68.6 53.8 127.5 Sr-90 09/08/23 <0.724 70.3 53.5 131.4 Sr-90 12/28/23 <0.807 52.8 53.1 99.4 Downloaded

• • Internal Process or Printed Control results copiesacceptance use TBE-ES are UNCONTROLLED copiesrecovery criteria of 60 -140%

B.2 Duplicates Downloaded or Printed copies are UNCONTROLLED copies

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

1. of Dups # Samples RPD Upper Matrix Nuclide Analyzed Evaluated for RPD** RPD Range Limit Air Particulates Be-7 (Gamma) 45 9 2.3 - 17.9 30 Gross Alpha 66 13 0.0 - 25.5 30 Gross Beta 505 289 0.0 - 29.5 30 Sr-89 74 2 11.8 - 17.0 30 Sr-90 76 1 16.3 30 Animals Be-7 (Gamma) 2 0 50 K-40 (Gamma) 2 2 0.2 - 0.4 50 Charcoal I-131 (Gamma) 393 2 1.8 - 1.9 50 Feed/Food/Grass/Veg Be-7 (Gamma) 52 12 0.7 - 23.9 50 K-40 (Gamma) 57 56 0.2 - 21.4 50 Fish/Shellfish Be-7 (Gamma) 4 0 50 K-40 (Gamma) 4 2 0.7 - 12.9 50 Milk K-40 (Gamma) 116 116 0.1 - 27.9 30 Sediment/Soil/Solid C-14 (RAD) 4 0 50 H-3 3 0 50 K-40 (Gamma) 13 5 3.9 - 15.8 50 Water/Liquid Fe-55 6 1 4.4 30 Gross Alpha 31 1 16.7 30 Gross Beta 37 4 0.0 - 21.7 30 H-3 249 37 0.0 - 27.1 30 K-40 (Gamma) 33 3 0.1 - 27.6 30 Ni-63 5 1 2.5 30 Sr-89 18 2 2.9 - 4.5 30 Sr-90 22 2 1.4 - 4.8 30 LO/LR C-14 (RAD) 9 0 30 H-3 34 7 0.6 - 10.0 30 LCSD's Am-241 (AS) 31 31 0.2 - 21.7 30 C-14 (RAD) 66 66 0.0 - 19.5 30 Co-60 (Direct) 3 3 3.5 - 4.5 30 Cs-137 18 18 0.0 - 25.8 30 Fe-55 100 98 0.2 - 29.7 30 Gross Alpha 42 42 0.0 - 27.2 30 Gross Beta 44 44 0.0 - 23.9 30 H-3 54 54 0.0 - 26.5 30 I-129 66 66 0.4 - 27.1 30 Ni-63 101 101 0.0 - 21.0 30 Pu-239/240 (AS) 32 32 0.7 - 23.1 30 Sr-89 38 38 0.7 - 27.9 30 Sr-90 46 46 0.7 - 22.5 30 Tc-99 41 41 0.3 - 24.5 30 Th-230 (AS) 18 18 0.5 - 27.7 30 U-238 (AS) 39 39 0.3 - 22.4 30 MSD's Th-230 (AS) 2 2 2.49 - 3.3 50 U-234 (AS) 2 2 16.7 - 17.6 50 U-235 (AS) 2 2 28.9 - 41.2 50 U-238 (AS) 2 2 5.7 - 10.2 50

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

• • Precision is not evaluated if results are < 5x MDC or if both results are non-detect Downloaded or Printed copies are UNCONTROLLED copies

Intentionally Left Blank Downloaded or Printed copies are UNCONTROLLED copies

ATTACHMENT C Non-Conformance Reports Downloaded or Printed copies are UNCONTROLLED copies

C.1 Downloaded or Printed copies are UNCONTROLLED copies

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C.2 4 TELEDYNE Ill" BROWN ENGINEERING NONCONFORMANCE REPORT (NCR) FORM

1. NCR No.: ---""'-=-----

22-02

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

3. Laboratory Area: Count Toom 4. Client/Project Affected: N/A

5. Requirement

Reference:

QA Manual; TBE-4019 6. Affected Data: NIA

7. NCR

Description:

Audit Deficiency - Gamma calibration standard dilution calculation spreadsheet not appropriately validated

8. Client Notification: YES [R] NO 9. Associated CC#: N/A

10. Prepared By: Sharon Northcutt I 11. Date: 02/10/22 PART 2. TO BE COMPLETED BY NCR INVESTIGATOR

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

13. Planned Completion Date(s) for Actions(s): 03/10/22

14. Prepared By: 15. Date: fJol./;n/4 ;>.._

16. Approved By: 17: Date: 1/0 2 z._

PART 3. TO BE COMPLETED BY QUALITY ASSURANCE MANAGER

18. Revi -,.Verification of Corrective Action (where applicable) l2'.'.J Accepted D Rejected 81-ollow-up Needed -

&le.-

19. Prepared By: 20. Date:

PART 4. TO BE COMPLETED BY RESPONSIBLE MANAGER

21. Client Follow-Up Notification: YES @No 22. Date:

Description:

23. Prepared By: 24. Date:

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

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C.10 TELEDYNE BROWN ENGINEERING NONCONFORMANCE REPORT (NCR) FORM NCR No.: -------

22-10 Responsible Manager: _S......,._ha'"""""r__ n__No o__ _ .....rt......h__c__u.....

tt________

PART 1. TO BE COMPLETED BY ORIGINATOR OF NCR Initiated due to: D Customer Complaint [xJ Audit/Mgmt Rept O XCHK Failure D Staff Observation Process Area: Quality Assurance Client/Project Affected: N/A Requirement

Reference:

QSM 5.4 v1 M2 4.2.8.5 & 4.2.2 Affected Data: N/A NCR

Description:

Audit Finding NCR 3 - Technical SOPs not reviewed annually and updated where necessary - see supplement page Client Notification Needed: DYES 0 NO Associated CAR or CC #: {ill Prepared By: Sharon Northcutt I Date: 09/23/22 PART 2. TO BE COMPLETED BY ROOT CAUSE INVESTIGATOR Root Cause:

Corrective Action Plan:

Prepared By: Date:

Approved By: Date:

PART 3. TO BE COMPLETED BY QUALITY ASSURANCE MANAGER Review and Verification of Corrective Action I !:(] Accepted D Rejected D Follow-up Needed (describe) D Completed Prepared By: Date:

PART 4. TO BE COMPLETED BY RESPONSIBLE MANAGER Client Follow-Up Notification: YES I /l NO 1

22. Date:

Description:

23. Prepared By: 24. Date:

Nonconformance Report (NCR)Downloaded Form or Printed copies are UNCONTROLLED copies KQA-9 Rev 6 12/229/21

C.10 Downloaded or Printed copies are UNCONTROLLED copies

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C.10 Page i of iv Number: Active Procedures TOC Revision:

Procedure Issue Date: 03/02/2004 Revision Date: 11/01/2022 Responsible Individual: Quality Assurance Manager Next Review Date: N/A

Subject:

Table of Contents, Record of Revisions & Review Schedule Table of Contents and Record of Revisions Number Title Revision Date Review Date Next Review Introduction 07/01/22 06/22/22 As Needed Quality Assurance Procedures TBE-1001 Validation and Verification of Computer 6 05/27/21 05/27/21 05/27/24 Programs for Radiochemistry Data Reduction TBE-1003 Control and Retention of Quality Assurance 5 12/01/20 12/18/19 12/18/22 Records TBE-1005 Data Integrity 9 05/03/21 05/03/21 05/03/24 TBE-1007 Training, Qualification and Certification of 9 07/26/22 06/23/22 06/23/25 Personnel TBE-1008 Documents and Document Control 10 10/20/21 10/20/21 10/20/24 TBE-1009 Calibration Systems 7 10/15/21 10/13/21 10/13/24 TBE-1013 Audits and Management Review 8 10/15/22 10/12/22 10/12/25 TBE-1014 RFP, Contract Review and Project Setup 5 10/15/22 10/15/22 10/15/25 TBE-1015 Procurement Controls 10 08/01/22 07/29/22 07/29/25 TBE-1016 Documentation of Customer Complaints 4 08/02/21 07/09/21 07/09/24 TBE-1018 Corrective/Preventative Action and Original 12/29/21 NEW 12/29/24 Nonconformity Control Analytical Procedures TBE-2001 Alpha Isotopic and Pu-241 16 06/05/21 06/05/21 06/05/23 TBE-2002 Carbon-14 Activity in Various Matrices 6 08/05/20 08/05/20 05/05/23 TBE-2003 Carbon-14 and Tritium in Soils, Solids, and 6 05/28/21 05/12/21 05/12/23 Biological Samples: Harvey Oxidizer Method TBE-2004 Cerium-141 and Cerium-144 by Radiochemical 7 06/08/21 06/08/21 06/08/23 Separation TBE-2005 Cesium by Radiochemical Separation 7 08/02/21 07/26/21 07/26/23 TBE-2006 Iron-55 Activity in Various Matrices 9 05/13/22 02/01/22 02/01/23 TBE-2007 Gamma Emitting Radioisotope Analysis 11 04/25/22 04/25/22 04/25/23 Downloaded or Printed copies are UNCONTROLLED copies

C.10 Page ii of iv Number: Active Procedures TOC Revision:

Procedure Issue Date: 03/02/2004 Revision Date: 11/01/2022 Responsible Individual: Quality Assurance Manager Next Review Date: N/A

Subject:

Table of Contents, Record of Revisions & Review Schedule Number Title Revision Date Review Date Next Review Analytical Procedures (continued)

TBE-2008 Gross Alpha and/or Gross Beta Activity in 12 05/15/22 05/03/22 05/03/23 Various Matrices TBE-2010 Beta Activity by Liquid Scintillation (Direct Prep) 6 07/15/20 07/15/20 07/15/23 TBE-2011 Tritium Analysis in Drinking Water by Liquid 12 06/10/21 06/10/21 06/10/23 Scintillation TBE-2012 Radioiodine in Various Matrices 12 03/01/22 03/01/22 03/01/23 TBE-2013 Radionickel Activity in Various Matrices 10 09/15/22 09/15/22 09/15/23 TBE-2014 Phosphorus-32 Activity in Various Matrices 9 08/30/22 08/19/22 08/19/23 TBE-2015 Lead-210 Activity in Various Matrices 7 05/03/21 05/03/21 05/03/23 TBE-2018 Radiostrontium Analysis by Chemical 14 05/05/22 05/05/22 05/05/23 Separation TBE-2019 Radiostrontium Analysis by Ion Exchange 8 02/15/21 05/22/20 05/22/23 TBE-2020 Sulfur-35 Analysis 6 03/27/22 03/21/22 03/21/23 TBE-2021 Technetium-99 Analysis by Eichrom Resin 10 12/27/21 12/21/21 12/27/22 Separation TBE-2023 Compositing of Samples 6 11/02/21 11/02/22 11/02/23 TBE-2024 Dry Ashing of Environmental Samples 6 11/01/22 11/01/22 11/01/23 TBE-2025 Preparation and Standardization of Carrier 7 12/28/19 12/28/19 12/28/22 Solutions TBE-2027 Labware Washing and Storage 6 11/22/21 11/01/22 11/01/23 TBE-2028 Moisture Content of Various Matrices 4 12/31/19 12/16/19 12/16/22 TBE-2032 10CFR61 Sample Preparation 6 11/24/21 10/26/22 10/26/23 TBE-2033 Sample Digestion by Fusion 9 07/15/21 06/17/21 06/17/23 TBE-2034 Homogenization of Solid Sample (Sample Prep) 7 12/30/21 11/05/22 11/05/22 TBE-2037 Radiochemical Determination of Gross Alpha 5 01/03/20 12/18/19 12/18/22 Activity in Drinking Water by Coprecipitation Downloaded or Printed copies are UNCONTROLLED copies

C.10 Page iii of iv Number: Active Procedures TOC Revision:

Procedure Issue Date: 03/02/2004 Revision Date: 11/01/2022 Responsible Individual: Quality Assurance Manager Next Review Date: N/A

Subject:

Table of Contents, Record of Revisions & Review Schedule Number Title Revision Date Review Date Next Review Instrument Procedures TBE-3001 Calibration and Control of Gamma-Ray 8 08/20/21 07/08/21 07/08/23 Spectrometers TBE-3002 Calibration of Alpha Spectrometers 6 08/17/21 08/16/21 08/16/23 TBE-3003 Calibration and Control of Alpha and Beta 7 10/15/22 10/15/22 10/15/23 Counters TBE-3004 Calibration and Control of Liquid Scintillation 7 10/01/21 08/18/21 08/18/23 Counters TBE-3006 Balance Calibration and Check 5 12/13/21 12/13/21 12/13/22 TBE-3009 Calibration, Use, and Maintenance of 5 02/01/22 02/01/22 02/01/23 Mechanical Pipettes and Pipettors Technical Procedures TBE-4002 Quality Control Checking of Analytical Data 6 12/20/19 12/17/19 12/17/22 TBE-4003 Sample Receipt and Control 15 11/01/22 11/01/22 11/01/23 TBE-4004 Preparation of a Data Package 8 12/28/19 12/28/19 12/28//22 TBE-4005 Quality Control Samples - Blanks, Spikes and 7 08/31/21 05/28/21 05/28/24 Duplicates TBE-4006 Inter-Laboratory Performance Evaluation 12 01/12/22 01/12/22 01/12/25 Programs TBE-4007 Method Basis, Validation and Demonstration of 7 12/10/21 12/10/21 12/10/24 Capability TBE-4009 Detection Levels 3 01/09/20 01/09/20 01/09/23 TBE-4010 State and Government Agency Certifications 4 12/04/19 12/18/19 12/18/22 TBE-4011 Quality Calculations and Charting (Accuracy, 3 12/04/19 12/04/19 12/14/22 Precision, Recovery, Efficiency, Control Charts and Data Quality Objectives)

TBE-4014 Laboratory Facilities 6 12/20/19 12/20/19 12/20/22 TBE-4015 Documentation of Analytical Laboratory 5 10/08/21 10/01/21 10/01/24 Logbooks TBE-4016 Uncertainty of Measurements 3 05/05/21 12/11/19 12/11/22 TBE-4019 Radioactive Reference Standard Solutions and 7 06/08/21 06/03/21 06/03/24 Records Downloaded or Printed copies are UNCONTROLLED copies

C.10 Page iv of iv Number: Active Procedures TOC Revision:

Procedure Issue Date: 03/02/2004 Revision Date: 11/01/2022 Responsible Individual: Quality Assurance Manager Next Review Date: N/A

Subject:

Table of Contents, Record of Revisions & Review Schedule Number Title Revision Date Review Date Next Review Facility Procedures TBE-5001 Laboratory Hood Operations 7 05/02/22 05/02/22 05/02/25 TBE-5002 Operation and Maintenance of Deionized Water 10 10/15/22 10/12/22 10/12/25 System TBE-5003 Waste Management 8 03/25/22 01/31/22 03/25/25 LIMS Procedures TBE-6001 LIMS Raw Data Processing, Reporting, Backup 9 05/13/22 05/05/22 05/05/25 TBE-6002 Software Development and/or Pilots of COTS 2 11/15/20 11/15/20 11/15/23 Packages TBE-6003 Software Change and Version Control 4 10/17/12 12/13/21 12/13/24 TBE-6005 Disaster Recovery Plan 4 10/26/2 10/26/22 10/26/25 TBE-6006 LIMS Hardware 7 10/26/25 10/26/22 10/26/25 TBE-6010 Laboratory Information Management System Original 08/24/21 NEW 08/24/24 (LIMS)

Radiation Protection Program Procedures TBE-7001 Receiving Packaged Radioactive Materials 14 11/01/22 11/01/22 11/01/23 TBE-7002 Laboratory Contamination Control 7 11/01/22 11/01/22 11/01/25 TBE-7003 Facility and Personnel Exposure Monitoring 6 11/01/22 11/01/22 11/01/25 TBE-7005 Facility Surveys 12 10/15/22 10/15/22 10/15/25 TBE-7007 Radiation Protection Program Assessment & 7 11/15/22 11/10/22 11/10/25 Records TBE-7009 Radioactive Waste Management and 8 11/01/22 10/26/22 10/26/25 Minimization Environmental Regulatory Procedures TBE-8004 Environmental Management System 2 05/18/22 05/15/22 05/15/25 TBE-8005 Management of Change 2 05/18/22 05/18/22 05/18/25 TBE-8015 Precious Metals 1 10/1818 12/08/21 12/08/24 Downloaded or Printed copies are UNCONTROLLED copies

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

INTERNAL AUDIT REPORT Audit Plan Audit Date:

Auditor: Charles Hurst (Lead), Joy White Audit No.: 2022-029 14-16 November 2022 Auditee(s): Sharon Northcutt, TBE Knox Lab Methods: Review of objective evidence, Scope: documentation, and through interview of personnel TBE Knoxville Lab Operations Tools: AS9100D Aerospace Standard (or other Criteria: standard as noted in Scope & Criteria), K-QAM-1 Rev TBE Knoxville Quality Manual 35, Process Specifications, Internal Audit Checklists, associated forms, and other tools as needed Date Time Area / Department / Process / Function Key Contact 14-16 Nov Various TBE Knoxville Lab Quality program and lab operations Keith Jeter, Sharon Northcutt, Casey

Dearcop,

Tyler Cavin, Donna Webb, Hillary Wellnitz Process Effectiveness Assessment Report (PEAR)

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

Personnel training, Contracts management, method verification, handling of tests, results reporting, nonconformances, corrective actions.

Applicable AS9100 clause(s): N/A. This annual internal audit is conducted for the purpose of assessing TBE Knoxville Labs quality system as documented in the Quality Assurance Manual for Teledyne Brown Engineering Environmental Services, Document K-QAM-1, Rev 35, effective August 15, 2022, and associated implementing Procedures. A specific checklist was developed and used for this audit. The completed checklist is attached to this form.

Organizations method for determining process effectiveness:

- Audit results

- NCRs generated

- Other external audits

- Customer Complaints F-926, Rev. C, 9/8/21 Page 1 of 2 Downloaded or Printed copies are UNCONTROLLED copies Teledyne Confidential; Commercially Sensitive Business Data

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

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

Statement of Effectiveness Level:

The process is:

1. Not implemented; planned results are not achieved.

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

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

4. Implemented; planned results are achieved.

Auditor Name(s): Charles Hurst (Lead), Joy White Auditee Representative Acknowledgement Name: Sharon Northcutt Audit Summary The results of this audit are documented in the attached checklist.

There were zero (0) findings noted during the course of this audit with three (3) Opportunities for Improvement recommended Based on the results of this audit, TBE Knoxville Lab QA program and operations are determined to be effectively implemented.

Note: The 2023 internal audit of the Knoxville Lab will be shifted to earlier in the calendar year to correspond to the ISO 17025 external audit. The internal will be conducted 1-2 months prior to the external and will be based on the ISO 17025 checklist.

Previous Years Finding REF Requirements Observation, Comments, Objective Evidence ACC REJ NONE Current Year Audit Findings and Opportunities for Improvement (OFIs)

REF Requirements Observation, Comments, Objective Evidence ACC REJ Three (3) OFIs as noted in the attached checklist X Checklist - See Attached Checklist REF Requirements Observation, Comments, Objective Evidence ACC REJ F-926, Rev. C, 9/8/21 Page 2 of 2 Downloaded or Printed copies are UNCONTROLLED copies Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes Section 6.2 Personnel 6.2.1 The QA Manager maintains the training matrix for the SAT 2022 Training matrix was reviewed and found to provide extensive lab and ensures that procedure update or annual quality coverage of procedures/methods.

and/or safety-related training is complete The following records were reviewed and found to be current to the training matrix:

- Kenny Cooper

- Tyler Cavin

- Donna Webb

- Casey Dearcop 6.2.2 Job descriptions that include duties and responsibilities SAT Reviewed job descriptions for the following positions: 1) PM, 2) Lab for all staff are available for review. Technician, 3) Sample Receiving/Login Technician All included the following elements:

- Position Summary and Responsibilities

- Minimum Education/Experience Requirements

- Job Advancement Opportunity 6.2.4 Analysts must be recertified if: a) not enough QC data SAT Training record reviews indicated process for managing this requirement has been generated to support annual requirement or b) is in place and appears affective. Procedure revision training was there are significant changes to a procedure indicated by training records reviews as noted elsewhere in this checklist.

In the case of insufficient QC data to support annual requirements, this is Downloaded or Printed copies are UNCONTROLLED copies managed by the QA Manager through standard reporting generated b y LIMS that identifies the qualities of materials works by analysts. Any that fall short of the annual requirements are identified and reported to the lab manager so workload can be adjusted, when possible, to allow sufficient data to justify annual recertification per the QAM.

6.2.5 Staff Responsibilities & Authorities SAT The TBE Knox lab org chart is maintained on the TBE website and was NOTE: Some positions may be filled as a dual role with another accessed to evaluate this section. The list was easily accessible and position contains extensive information for each employee to include position, contact information, and years of service.

ATTACHMENT 1 1 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes 6.2.5.1 Lab Operations Manager SAT Position has been filled by the incumbent for several years. As

a. directing all aspects of normal business operations, demonstrated throughout the audit, the person is very knowledgeable in including strategic planning, staff management and the requirements for running this lab and satisfies all the requirements as meeting TBE profitability objectives; detailed in this section of the manual

b. supervising the establishment of client programs and ensuring review of proposals, contracts, and purchase orders to determine adequate personnel, equipment, training and procedure needs to meet referenced requirements;

c. monitoring the validity of analyses performed and data generated in the laboratory to assure reliable data, as well as reviewing results for accuracy and signing final client reports (Reports may be signed by the QA Manager or other qualified designee if needed);

d. ensuring that clients are contacted regarding non-standard or out-of-spec results (client contact may be performed by a qualified designee);

e. defining qualifications, experience and skills necessary for each staff position and verifying that lab technicians demonstrate initial and continuing proficiency in their assigned procedures; Downloaded or Printed copies are UNCONTROLLED copies ATTACHMENT 1 2 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes 6.2.5.3 Quality Assurance Manager SAT The QAM exercises a wide breadth of control and engagement with all aspects of lab operations. She conducts extensive internal audits of the

g. conducting or arranging for periodic internal audits multitude of procedures, generates managements review documentation, and management reviews, as well as coordinating coordinates numerous external audits, and maintains document control external audits; of training records, forms and procedures.

Two surveillances have been conducted in 2022:

• 3/17/22 TBE-2020 Rev 5

• 8/19/22 TBE-2014 Rev 8 Multiple internal audits were conducted in 2022. The following were reviewed and found to be complete:

• TBE-1001 Rev 6

• TBE-1013 Rev 7

• TBE-1018 Rev O 6.2.5.4 Project Managers (PMs) SAT Engagements with PMs in other sections of this checklist demonstrated a

b. entering and maintaining client information for high level of professionalism and quality among their team. They were contacts, reporting, billing, and technical specifications knowledgeable, helpful, and diligent in their job performance and in into the LIMS meeting the requirements of the QAM.

h. documenting and investigating client complaints The following customer complaints were reviewed and found to be in compliance with this manual:

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j. maintaining a storage system for lab reports and other

• CC-22-01, Client = WCS documents required to be kept for a specified time

• CC-22-03, Client = Entergy RBS period

• CC-22-07, Client = Exelon Limerick ATTACHMENT 1 3 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes 6.2.5.5 Sample Custodian SAT The sample custodian receives in all samples, reviews all paperwork and verifies that the samples received match the associated paperwork. Any

b. thoroughly reviewing paperwork and containers discrepancies are documented on a copy of the chain of custody as well received with shipped packages and noting as the variance report and the PM is also notified. Reviewed L98349 inconsistencies or damage and informing the Project (LIMS ID for samples), some of the glass sample bottles arrived broken Manager Immediately and this was documented on the variance report and a copy of the chain of custody. The PM was notified immediately.

A very recent higher, and auditing engagement with this position demonstrated a job level of job knowledge and performance. Training record reviews documented a high level of initial training and indoctrination for the position.

6.2.5.6 Laboratory Technicians SAT Laboratory technicians are identified on the org chart and were directly

d. identifying potential sources of error and correcting engaged during the audit demonstrated knowledge and capability for the problems that could affect data quality position. Corrective Action documentation reviewed indicated awareness of opportunities/requirements to identify improvements/concerns in correcting errors.

During interview with Lab Technician, it was noted the lab technicians feel that they can bring forth any ideas or improvements when needed.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes 6.2.5.9 Health & Safety Officer SAT Reviewed reports with facility Health & Safety Officer. Items reviewed/notes:

c. performing safety checks and audits - AFTAC Program Weekly Safety Walk-through indicated regular weekly inspections are being conducted as required

- AFTAC Monthly Environmental Safety Report also indicated regular assessment and documentation as required

- AFTAC Fire Extinguisher Monthly reports reviewed were found to be current and well documented

- TBE Huntsville conducts annual, informal Health and Safety visits

- Teledyne Corporate conducts formal inspections every 2-3 years.

Last conducted was 2021.

6.2.5.10 Radiation Safety Officer (RSO) SAT The RSO RPP Annual Assessment was just completed by TBE Huntsville Environmental, Health & Safety representatives on 10 November 2022.

b. coordinating scheduled radiological surveys and No findings were issued, and one observation was noted.

administer personal dosimetry and sealed radioactive source leak test programs In reviewing the audit checklist, it appears the TBE Knox lab was in good compliance with all aspects of the RSO program.

Section 7.0 Process Requirements 7.1 Review of Requests, Tenders and Contracts 7.1.1 Review of Requests, Tenders and Contracts SAT Reviewed Quote (Q713) for soil samples, it was assigned to Karli (PM) and the scope was asking for nuclide testing with given tolerance ranges on Initial requests for quote or for additional analytical work the soil samples. The PM has an excel sheet which list the labs testing Downloaded or Printed copies are UNCONTROLLED copies are assigned a project manager who verifies that the capabilities and all required nuclides were listed on the sheet when scope of work is clearly defined and reviews the request verified.

against current laboratory procedures and capabilities.

7.1.2 The response to request will include lab procedure SAT The response to request typically does not include the lab procedure or and/or analytical method with appropriate accreditation method in any of the quote process unless required by the customer. The information (where needed). final report lists SOPs (test methods) next to the nuclide that was tested.

Reviewed Project ID VE705-3EFINALSUR-22, final report, listed SOP TBE-2000 next to the respective nuclide.

ATTACHMENT 1 5 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes Section 7.0 Process Requirements 7.4 Handling of Test Items 7.4.2 Sample Acceptance SAT When sample boxes/containers are received, the appropriate bar Upon receipt, a log is kept documenting each code is scanned in the Knox Lab database as well as the bar code shipping container received for the type of box received. Verified that the 32 boxes received from Riverrun were received in appropriately.

7.4.3 Identification SAT Once the samples have been matched against the chain of custody Once approved, each sample is given a LIMS- paperwork and have been verified to be in acceptable condition the generated unique laboratory ID (L#). Information samples are logged into the LIMS database. The LIMS database associated with each sample is carried through the assigns a UID to each sample. Observed L98515 being created as entire analytical process included: sample ID, L98515-1, L98515-2, L98515-3. The sample label is printed and collection date and/or time, receipt date/time, attached to each sample with the following information: LIMS IUD, requested analysis, results of sample inspection. All date, and numbers of containers.

sample containers are given a durable label using Note: The sample label currently does not have the project ID listed indelible ink that indicates the project ID, L#, the as described per the QMS but the folder that contains all the number of containers and the storage locations(s). paperwork/data for the samples has its own label which does have the project ID. This was addressed during the audit.

7.4.4 Sample Storage SAT Samples are stored away from standards, reagents, and food. The Samples are stored away from standards, reagents, sample are stored in the stockroom, freezers, refrigerators, or bins.

Downloaded or Printed copies are UNCONTROLLED copies and food for human consumption.

Section 7.0 Process Requirements 7.5 Technical Records 7.5.1 The laboratory maintains a documentation system for SAT The QA Manager maintains all the quality documents and keeps the quality records of the analytical process. originals in fireproof cabinets. The LIMS database maintains all records of the testing data and is maintained by the LIMS administrator.

ATTACHMENT 1 6 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Item Line of Inquiry Status Summary of Observations/Objective Evidence, Reviewed/Audit Notes 7.5.2 Amendments to original records are signified by a single SAT Everyone receives training on the QMS manual which describes this stroke through the incorrect information with a brief correction process. This is also noted in SOP methods such as TBE-2011, explanation (unless obvious). The person making the page 11, section 10.3 Corrections.

change initials and dates the change.

7.5.3 Quality records retention is based upon several factors, SAT The LIMS database will store all data points indefinitely.

including client contract or Unless each contract specifies record retention, the labs standard regulatory requirement. Physical records are retained timeframe is 2/3 years and then the documents are sent offsite to storage.

onsite for 2-3 years and then logged and shipped to the TBE Huntsville storage facility. All records are kept at a minimum of 7 years, unless classified as permanent (kept for the life of the project or facility). Electronic records are kept indefinitely. (TBE-1003 Control and Retention of Quality Assurance Records, TBE-1008 Documents and Document Control, TBE-6001 LIMS Raw Data Processing, Reporting and Backup)

Section 7.0 Process Requirements 7.6 Evaluation of Measurement Uncertainty 7.6.3 TBE includes a 1- or 2-sigma combined standard SAT TBE lab includes a 1- or 2-sigma combined standard uncertainty value with uncertainty (CSU) [aka Total Propagated Uncertainty all analytical results. If the client requests the final report to not include the Downloaded or Printed copies are UNCONTROLLED copies (TPU)] value with all analytical results, depending on SCU then it is not in the final report but is present in the LIMS report.

client request.

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 7.0 Process Requirements 7.7 Ensuring the Validity of Results 7.7.3 Analytical Batches SAT All samples are assigned a workgroup using the LIMS database. Once The Labs analytical system is shown to be in control assigned a workgroup, the samples have a workgroup ID.

using batch and sample-specific QC. All samples must be placed in a workgroup batch and processed a. Preparation batches, observed WG40667, Tritium 2011 (H-3) in LIMS being selected for analysis. The workgroup contained 20 samples plus one with appropriate QC. Batch size is dependent upon blank, one spike and one duplicate preparation for a total of 23. The LIMS the method, but generally consists of one (1) to software generated the list of required reagents for the analysis, NaOH twenty (20) samples plus QC. All batch samples are pellets and KMnO4. All workgroup samples are prepared together using the processed together in the same manner same method(s), reagents, and diluent(s). Once prepared the samples are (preparation, analysis, data reduction and given to the lab technicians in the count room for sample analysis. The reporting). Batch samples are not required to be maximum time between the start of processing of the first and last sample analyzed concurrently on the same detection is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

system. The lab does not systematically or Lab technician calibrated balance #13, C033887187 before use (last cal.

preferentially use specific detectors, equipment, or 3/25/22 next due 3/31/23 follows TBE-3006) and the data is stored in glassware for analyzing QC samples. Two types of LIMS. Tolerance was 1% and LIMS will flag an alert if outside the tolerance.

batches in the radiochemical lab are: Used weight set #2, S/N 15721 (last cal. 3/28/20 and cal due. 3/20/25)

Lab technician verified pipette ENV #6 before use (last cal. 10/3/22 and

a. Preparation Batch - samples require physical cal. due 1/1/23) and the data is stored in LIMS. Pipettes are calibrated or chemical processing that affect the outcome of once every quarter by QA Manager.

the analysis. Samples are prepared with the same process, personnel and lot(s) of reagents, with a b. RMB samples received in for non-destructive gamma spectrometry are maximum time between the start of processing of placed on their respective instruments and then the testing begins. The Downloaded or Printed copies are UNCONTROLLED copies the first and last sample to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. samples requiring gamma are tested as soon as possible upon receipt due

b. Radiation Measurements Batch (RMB) - to the short half-life of Iodine. Samples are processed within 14 days of samples require no physical or chemical processing receipt.

that could affect the outcome of the test. Examples are: non-destructive gamma spectrometry, air filters for alpha/beta counting, or swipes on gas proportional detectors. Samples may be processed within fourteen (14) calendar days (start of the first sample to the last sample).

ATTACHMENT 1 8 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 7.7.4 QC Samples SAT Reviewed data from LIMS indicating that 10% of samples tested/processed Process control checks demonstrate consistent lab are QC proficiency samples. OE: P-32, 21% were QC proficiency samples.

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

7.7.5 Interlaboratory and Client Proficiency Testing SAT TBE performs proficiency testing regularly by either purchasing samples or To further ensure the validity of results, TBE regularly testing samples received from clients. TBE does is unaware of the level of participates in various proficiency testing (PT) studies spike added to the samples. The samples are received in and processed the during the year. These external performance checks same as the non-proficiency samples. If the results obtained by TBE are not (aka cross-checks) are samples with an unknown amount comparable to the expected results, then a RCCA and NCR are initiated. If of analyte added. Internal PT samples are obtained from the client does not give TBE the expected results, the results obtained are and reported to accredited proficiency testing providers. still given to the client no additional work is required. There have not been Some clients also routinely send their own cross-check any recent NCRs for this issue.

samples.

Reviewed RAD 129 report for samples which were purchased for All PT samples are received, analyzed, and processed in proficiency testing through ERA. The study dates were 4/04/22-5/19/22 the same manner as routine samples. Internal PT results and the report was issued on 5/23/22. All results reported were are reported directly to the PT provider and the results acceptable. This type of testing is performed every 6 months.

sent back to the lab and its accrediting body (where applicable). Clients report their cross-checks to the PT provider directly and final evaluations are not always shared with the lab. Although all radionuclide or matrix combinations are not available for proficiency testing.

TBE makes every effort to analyze PT samples that are Downloaded or Printed copies are UNCONTROLLED copies representative of routine client samples. Cross-check results that are not within the providers acceptance criteria are documented with a root cause investigation, corrective action (where merited) and a non-conformance report (NCR). (TBE-4006 Interlaboratory Performance Evaluation Programs)

ATTACHMENT 1 9 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 7.0 Process Requirements 7.8 Reporting of Results 7.8.2 Required Items SAT Reviewed sample report for SORA-2-02-007-F-S Sample results are compiled into a report and contain a) Report of Analysis for C of C the following items: b) TBE

a. title (Report of Analysis or ROA) 2508 Quality Lane

b. name and address of the laboratory (where analyses Knoxville, TN 37931 are performed) c) L98014

c. unique identification that correlates individual pages d) Gerald Wood, Vernon VT to the entirety of the report e) Collection date time varies but all were listed, SORA-2-02-007-F-S

d. contact name/address of the client f) 10/10/22, variance report was accepted with no discrepancies

e. sample description information (ID, collection g) Yes, each SOP was listed next to the test performed date/time) and lab ID information h) Yes, all information was listed

f. sample receipt date, condition and any sample i) N/A acceptance criteria variance j) Report authorized by Keith

g. TBE Procedure (SOP) ID k) Yes

h. test result (activity) directly as obtained with l) Yes appropriate number of significant figures, measurement No subcontracted analyses for this report uncertainty estimation, detection limit (MDC),

measurement units, reference date, count date/time, and flagged values (results outside of technical specifications)

i. notation for method changes (if applicable)

j. name, title and signature of the person(s) authorizing Downloaded or Printed copies are UNCONTROLLED copies the report

k. statement that results relate only to the items tested

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

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

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 7.0 Process Requirements 7.9 Client Complaints 7.9.2 Complaint Resolution Process SAT a) Reviewed Customer Complaint CC 22-09.

a. Staff receives and documents complaint on TBE KQA-22 Documented on form KQA-22, Rev. 3, 5/15/20 Complaint Detail Form. Samples L96852

b. Complaint is investigated promptly and if warranted a Non-Conformance Report that includes a root cause b) The complaint was investigated, and a CAR was initiated, CAR 22-13.

evaluation and corrective action is initiated. (Section 7.10) The technician selected the wrong geometry when setting up the

c. A decision is made regarding the complaint resolution instrument parameters. The data was able to be re-processed.

such that all parties involved are in agreement and are satisfied with the outcome (client notification and c) Once the investigation was completed the report was revised and re-approval). distributed to the client. At this time the client had not responded back

d. Suitable response is taken by the lab to prevent yet with the new report results, so it is assumed to be in agreement recurrence (where applicable). with the client.

d) Because this was the first time this issue had happened the corrective action was to verbally discuss with the technicians to be more diligent when setting up these parameters.

Section 7.0 Process Requirements 7.10 Nonconforming Work, Corrective and Preventative Actions 7.10. When a nonconformity is discovered, the following steps SAT a.) Reviewed NCR 22-07, (form KQA-9 Rev. 6), it was added to the Downloaded or Printed copies are UNCONTROLLED copies 3 are taken: NCR log which is maintained by the QA Manager, and it had a

a. Nonconformance is initiated by the responsible staff and summary which included a requested completion date of documented on form KQA-9 Nonconformance Report (NCR) immediately. Samples were contaminated by a cleaning agent Form. The nonconformance is given a unique identifier, before they were logged in and placed in their storage location.

added to the NCR log, and a brief summary including b.) The NCR 22-07 was relinquished to the appropriate manager requested completion date recorded on the form. who conducted a root cause.

b. The NCR is relinquished to the appropriate manager for c.) CAR 22-16 was initiated after the root cause analysis was evaluation of significance, including work stoppage where completed (form KQA-40 Rev. 0). The client was notified by the appropriate. The manager conducts a root cause PM who wrote a Case Narrative which is generated out of LIMS.

investigation to determine the source of the departure d.) The QA Manager closed the CAR and stated that it would be re-evaluated in 6 months from 9/29/22. The training record was ATTACHMENT 1 11 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 from the standard. The manager will also update the attached (KQA-8 Rev. 3) which included anyone who has parties involved as to the progress towards resolution. permission to log in samples.

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

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

Note: More complex issues may require more time.

Section 7.0 Process Requirements 7.11 Control of Data and Information Management 7.11.2 Any changes to the LIMS software configuration or SAT Any changes to the LIMS software that will affect the results has to be modifications to commercial software approved by the Operations Manager. Any changes to LIMS that do not are authorized, documented and validated before use. affect the results are permitted acceptable and the LIMS administrator can proceed with the requested change.

Reviewed a request from a PM to enhance LIMS so that the SAMPLE volume would show when added later. The LIMS administrator verified that it would work and then dated the day that he completed the Downloaded or Printed copies are UNCONTROLLED copies request. Any major changes to LIMS software require validation which is performed by the LIMS administrator using tables and conversions.

7.11.3 TBE-ES LIMS is only accessible by trained staff with assigned SAT Each staff member is assigned a role in LIMS which is based upon their security levels based upon job function. Changes to LIMS job function and which permissions they need daily. When a new person programming are documented and can only be accessed by is hired, they are added to LIMS and then assigned a role such as lab the LIMS Manager. technician or PM. All changes to LIMS programming are documented and retained by the LIMS administrator.

7.11.6 Only the most current document revisions are available on SAT All revisions on the shared network drive are the most current. Verified the shared network drive. This includes TBE procedures as TBE-2003 Rev. 6 (5/28/21) matched online and in the original book in well as the Safety and QA Manuals. All staff have access at the QA Managers office. All staff have computer access with access to all times to these documents. the shared network.

ATTACHMENT 1 12 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 8.0 Quality Management System (Option A) 8.2 Management System Documentation 8.2.3 The QMS allows only qualified personnel to SAT All documents reviewed where signed/authorized by qualified review/update/perform specific procedures. It personnel. Training records were sampled to document completeness encourages integrity, impartiality and consistency in daily lab of training to include:

operations at all levels. - Kenny Cooper

- Casey Deacop

- Tyler Cavin

- Donna Webb Section 8.0 Quality Management System (Option A) 8.3 Control of Management System Documents 8.3.1 TBE-ES maintains control of documents that relate to the SAT Current document revisions were observed throughout. Only current QMS, including training, procedures, audits, corrective document revisions are maintained on the QAM controlled SharePoint actions, management reviews, forms, and the QA Manual. site, while original, hardcopy documentation is maintained in file (TBE-1008 Documents and Document Control) cabinets in the QAMs office.

All appear to be maintained IAW the requirements of this manual and TBE-1008 8.3.2 Controlled documents are periodically reviewed and updated SAT All controlled documents reviewed showed review within the 3 years as necessary. Only authorized personnel can approve and currently required by procedure. Based on the pursuit of ISO 17025 Downloaded or Printed copies are UNCONTROLLED copies issue controlled documents. All staff whose work is affected certification, that requirement will revert to an ANNUAL review of all by changes are notified and trained to the revision. technical procedures and documents IAW the requirements of IS 17025. That certification is currently pending based on a recently completed external audit and will likely be implemented in 2023.

8.3.4 Original signed QMS documents are stored in the QA SAT Access to documents is maintained as stated here. Documents Managers office and/or stored electronically on TBEs shared reviewed in the QAM storage area/online included:

computer network drive. Only current pdf copies of QMS - Training records documents are available for access and distribution and - Position descriptions include the disclaimer - Procedure revisions DOWNLOADED or PRINTED copies are UNCONTROLLED. - Audit & surveillance schedules and results ATTACHMENT 1 13 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 8.0 Quality Management System (Option A) 8.4 Control of Records 8.4.1 Quality and technical records are maintained in accordance SAT See sections 8.3.1 - 8.3.4 of this checklist with TBE Procedures TBE-1003 Control and Retention of Quality Assurance Records and TBE-1008 Documents and Document Control.

Section 8.0 Quality Management System (Option A) 8.6 Improvement 8.6.2 Actions are taken in response to trends signifying SAT Trending, or other, issues are raised throughout the year and deterioration in lab performance addressed via Corrective Actions. All employees, not just the Quality indicators such as quality data, repeated audit findings or Manager, are encouraged to identify areas of concern and document turnaround times. them via the Corrective Action program where they are reviewed and work for potential process improvements.

8.6.3 Audits are performed to identify trends and offer suggestions SAT An extensive list of procedure and process audits were observed to for improvement. be conducted annually. These are all tracked via spreadsheet and a reviewed indicated all audits planned through October 22 had been conducted. Audit reports existed for each of the completed audits.

8.6.3.4 Lab quality performance is reviewed and summarized in a SAT The Q2 2022 QA Report, the most recent completed, was signed quarterly QA Report. 11/4/22. Review of this report demonstrated a good, overall Audits and nonconformance/corrective actions are also assessment of the state of the labs quality performance.

included in the report. This report is distributed to TBE management and is also available for clients. A summary of The most recent Annual Management report was reviewed and found this report is included with the Annual Management Report. to be mostly conforming to the requirements of this manual. The Downloaded or Printed copies are UNCONTROLLED copies report was issued on 15 April 2022 for CY22. This represents a significant improvement in timeliness from previous years when the annual reports were not completed until halfway into the proceeding year.

Opportunity for improvement (#1): Since the generation of the CY21 Management report, the Quality Manual has been revised to now include requirements for reporting and assessing Risks and Opportunities periodically. A good way to begin meeting this would be to address these areas in the upcoming CY 22 Management report.

ATTACHMENT 1 14 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 Section 8.0 Quality Management System (Option A) 8.7 Corrective Actions 8.7.1 Corrective action is taken as the result of a departure SAT Numerous Corrective Actions were reviewed. These included:

from specifications imposed by client

• CC-02 contract, regulatory requirement or TBE stated policy or

• CD-05 procedure. It is a measure taken to

• CC-06 discover the source of a deviation and to avoid similar

• CC-15 issues going forward. Corrective

• CC-15 action is taken promptly and to a degree appropriate to All were found to be fairly well documented and demonstrated a highly the magnitude and risk of the issue.

engaged team effort to identify and mitigate potential quality issues:

Conditions adverse to quality are documented and Opportunity for improvement (#2): The corrective action program tracked with proposed and actual could be improved by focusing additional effort in the following areas:

completion dates. (TBE-1018 Corrective/Preventative 1. Do not close out Corrective Actions until sufficient time has Action and Nonconformity Control) passed to accurately assess the effectivity of any corrective actions made as a result of the Root Cause Corrective Action (RCCA). A few reports (22-06, 22-13, 22-16, 22-19 among others) were observed to have been initiated an closed in a very short period of time that likely did not allow sufficient time to properly evaluate actions taken.

2. Include more detailed information in section 3 of the CA report to more thoroughly detail actions taken as a result of the RCCA.

Downloaded or Printed copies are UNCONTROLLED copies The same applies for the closure section of the RCCA to provide supporting information for the effectiveness determination 8.7.2 Nonconformities are documented on a Non-Conformance SAT Nonconformances are documented and hardcopies retained in the Report (NCR) Form. After investigation and analysis is Quality Managers office. The following NCRs were reviewed and found complete, appropriate corrective action is taken and to be in conformance with this manual:

consequences are determined (where applicable). A

• CC-01 target completion date is set for 30 days from initiation to

• CC-02 corrective action plan. This date may be adjusted as

• CC-06 deemed necessary due to the complexity of the ATTACHMENT 1 15 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 nonconforming issue. Where analytical results are involved, data is monitored carefully until the issue is fully resolved. Notification is made to appropriate parties (where applicable). All NCRs are included with the quarterly/annual QA Report.

8.7.3 Corrective action effectiveness is evaluated periodically to SAT Corrective Action effectiveness is evaluated on the CA forms during the verify that measures put into place have been successful process of closure and summaries are included in the annual report.

and/or to ensure that any nonconforming issue has not been repeated. A summary evaluation of corrective As noted in the summary for 8.7.1 above, additional information could be included in the CA closure box to better substantiate the action of effectiveness is included in the annual determination of effectiveness.

management report.

8.7.4 Risks and opportunities based on corrective actions taken SAT As noted in 8.6.3.4 above -

are evaluated periodically by management. Changes to the management system may be made to limit Opportunity for improvement (#1): Since the generation of the CY21 vulnerability or exposure to potential risk or to promote Management report, the Quality Manual has been revised to now include requirements for reporting and assessing Risks and more efficient lab operation.

Opportunities periodically. A good way to begin meeting this would be to address these areas in the upcoming CY 22 Management report.

Section 8.0 Quality Management System (Option A) 8.8 Internal Audits Downloaded or Printed copies are UNCONTROLLED copies 8.8.1 In order to detect actual or potential nonconformities SAT The Quality Manager develops and maintains a tracking spreadsheet before data quality could be affected, internal audits are with all CY internal audits listed. A review of the CY 22 audit scheduled planned and conducted. These audits verify conformance demonstrated these audits are being conducted per the schedule and of lab operations and the management system to complete documentation is being maintained.

regulatory and accreditation requirements, and to the labs own policies and procedures. (TBE-1013 Audits and Management Review)

ATTACHMENT 1 16 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 8.8.2 An internal audit plan is generated annually and includes SAT A review of the CY22 internal audit scheduled demonstrated all checks the procedures and surveillances that are planned during scheduled through Oct 22 have been completed and documentation of the year. The goal is to review each area of the lab in such is on-hand. 13 checks remain for CY22 and there is no reason to some fashion. The plan is maintained by the QA suspect those will not be completed as scheduled.

Manager, but audits may be performed by other staff.

Internal audit reports for the following were reviewed:

Auditors are trained in performing audits, have some

• TBE-1015, completed 7/29/22 technical background in the subject matter, and are

• TBE-2023, completed 11/2/22 independent of the activity to be audited (not directly

• TBE-2027, completed 11/1/22 involved or have supervisory responsibility).

• TBE-3003, completed 10/13/22

• TBE-4019, completed 1/14 and 6/30

• TBE-1018, completed 11/11/22 8.8.4 An analytical procedure surveillance is scheduled to SAT Method surveillance status is being actively tracked by the Quality observe analysts as they perform a method to verify that Manager. For CY 22, two surveillances were completed:

it is being done as written and to note any changes that may need to be made to the written procedure. The

• TBE-2020 Rev 5 on 3/17/22 results of the QC workgroup are included to show that

• TBE-2014 Rev 8 on 8/19/22 the results are within control limits. All audit results are Opportunity for improvement (#3): With only 2 surveillances evaluated by the Operations Manager and any necessary completed in CY22, a greater focus on this requirement should be changes are made where needed. made. The Quality Manager has had many competing priorities in CY22 with several major external audits being conduct. This resulted in a lesser than normal completion rate for surveillances. Expanding the number of persons qualified to perform such surveillances would be one Downloaded or Printed copies are UNCONTROLLED copies possible way to level out this workload, expand the reach of the surveillance program and enhance professional development of the rest of the staff.

8.8.6 Audit findings of nonconformances are documented and SAT Multiple external audit nonconformances were identified, documented timely corrective action is taken, tracked to closure, and and worked to resolution.

evaluated for effectiveness. An audit response including corrective action is sent to the auditor, (and to the A large number of internal audits were conducted that yielded no findings but several observations. The Quality Manager and Director of Quality Management Systems for the annual Operations Manager are encouraged to assess the rigor of the internal Quality System audit). Any findings that could cast doubt on the validity of results are disclosed in writing to the ATTACHMENT 1 17 Teledyne Confidential; Commercially Sensitive Business Data

TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 affected client(s) within 7 days. The QA Manager (or audits being conducted to ensure sufficient evaluation of their systems designee) verifies that the client was contacted properly. to more completely identify potential nonconformances.

Section 8.0 Quality Management System (Option A) 8.9 Management Reviews 8.9.1 In conjunction with the Internal Audits (Section 8.9 SAT The Management Review for CY21 was reviewed. The report was above), the laboratory conducts an annual management signed out on 4/22/12 which represents a significant improvement in review to ensure continuing suitability, adequacy, and timeliness of report completion which, in the past, could lag by 6 effectiveness of stated policies and objectives in this months from the end of the year. Timeliness is very important to accurately and effectively assess prior year performance to implement Quality Manual. (TBE-1013 Audits and Management in required improvements.

Review)

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TELEDYNE BROWN ENGINEERING KNOXVILLE LABORATORY QUALITY ASSURANCE DEPARTMENT INTERNAL AUDIT CHECKLIST 2022 8.9.2 The review includes: SAT All the elements noted in this section were found to be included in the

• a summary of any changes to the QA program from the CY21 Management Report with two exceptions:

previous year - results of risk identification

• adequacy of staff and equipment resources - radiological health/safety, waste and management functions

• a list of staff specialty training certificates with expiration dates Both of these elements are being included in the CY22 report based

• highlights from the 4th Qtr (annual) QA Report (QC sample and proficiency results upon CY22 audit results and other observations.

• and audits)

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

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

• commentary on effectiveness of corrective actions

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

• comparisons of sample volume and turnaround times to previous years

• client feedback not included with the QA Report

• observations by staff for improvements

• results of risk identification

• any changes/updates to methodology

• radiological health/safety, waste and management functions

• a statement of management system effectiveness and fulfillment of objectives 8.9.3 Upon completion of the draft review, the information is SAT The CY21 Management Report was signed out and transmitted via email submitted to and signed by the Operations Manager and to the Sr VP of Energy and the Director of Quality.

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

ATTACHMENT 1 19 Teledyne Confidential; Commercially Sensitive Business Data

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

EA 22-01 NUPIC AUDIT February 7 - 10, 2022 Downloaded or Printed copies are UNCONTROLLED copies

March 8, 2022 Ms. Sharon L. Northcutt QA Manager Teledyne Brown Engineering - Environmental Services (TBE-ES) 2508 Quality Lane Knoxville, TN 37931-3133

Subject:

Entergy Audit Report Number WT-WTHQN-2021-00564/

NUPIC Audit Report Number 25265 CEXO2022-00020

Dear Ms. Northcutt:

Enclosed is the audit report for Entergy Audit WT-WTHQN-2021-00564 conducted at the TBE-ES facility located in Knoxville, TN from February 7-10, 2022. The audit was performed to assess the implementation and effectiveness of the companys quality assurance program for providing radiochemical analysis of environmental samples, providing radiochemical analysis of radioactive waste samples, providing bioassays, and providing laboratory services.

The audit team concluded TBE-ES is effectively implementing its quality assurance program consistent with the applicable requirements of U.S. Nuclear Regulatory Guide 4.15. TBE-ES will be maintained on the Entergy Qualified Suppliers List (QSL).

While there were no program findings identified during the audit there were, however, two program deficiencies identified during the audit. These deficiencies were entered into your internal corrective action program. No written response is required to be sent to Entergy for the deficiencies. The actions you take for these deficiencies will be evaluated during the next NUPIC audit. Since there are no follow up actions required, this audit is closed based upon issuance of this report.

Downloaded or Printed copies are UNCONTROLLED copies

Subject:

Entergy Audit Report Number WT-WTHQN-2021-00564/NUPIC Audit Report Number 25265 Date: March 8, 2022 CEXO2022-00020 Page 2 of 2 We would like to thank you as well as the entire TBE-ES staff for your cooperation and the courtesies extended to the team during the audit. Should you have any questions or require additional information, please contact Joseph Walker at 601-368-5542 or via email at jwalk15@entergy.com Sincerely, Alisha Johnson-Thomas Supervisor, Supplier QA AJT/JCW/jcw Attachments: 1. Audit Report WT-WTHQN-2021-00564

2. Audit Checklist (Not to addressee)

3. PBSA Worksheet (Not to addressee)

4. Technical Specialist Resume/ Audit Team Orientation (Not to addressee)

Cc: Corporate File [ 75 ], w/a Downloaded or Printed copies are UNCONTROLLED copies

Attachment 1 Audit Report WT-WTHQN-2021-00564 Downloaded or Printed copies are UNCONTROLLED copies

Audit Number: WT-WTHQN-2021-00564 Date(s) of Audit: February 07-10, 2022 Organization/Address: Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-3133 Organization

Contact:

Sharon L. Northcutt, Quality Assurance Manager Phone Number: (865) 934-0374 Supplier Product/Service:

Radiochemical analysis of environmental samples, providing radiochemical analysis of radioactive waste samples, providing bioassays, and providing laboratory services.

Audit Scope:

To evaluate the adequacy and implementation of the TBE-ES quality program for the product/service scope identified above. A performance-based auditing approach was used to evaluate the effectiveness and implementation of the TBE-ES quality assurance program as it relates to the referenced documents listed. The audit was performed using the part 1 of the NUPIC radiological audit checklist, revision 1.

Reference Documents:

QA Manual K-QAM-1, Rev. 34, Dated: 04/15/2021 Revision 1 to part 1 of the NUPIC radiological audit checklist QA Program Requirements:

The TBE-ES QA Manual references both revision 1 and revision 2 to Regulatory Guide 4.15 due to variations in client contract language, as some utilities use revision 1 while others use revision 2 of Regulatory Guide 4.15. Typically, Regulatory Guide 4.15 Rev 2 (2007) provides additional details and descriptions with more current references to regulatory documents than revision 1 (1979). Specifically, Regulatory Guide 4.15 revision 2 changed the following elements:

Section 8 from Review and Analysis of Data to V/V (data and software)

Section 9 Audits was split into Assessments & Audits and Preventative & Corrective Actions (added Section 10)

In summary, the two revisions to regulatory guide 4.15 do not have conflicting guidance but provide greater detail with the actual references being provided in the different sections clarifying justifications for the requirements.

Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs, Effluent Streams, and the Environment, Revisions 1, & 2 Compliance with 10CFR Part 21: ( ) YES ( X ) NO Executive Summary and Program Effectiveness:

The results of the audit showed that for the orders reviewed TBE-ES is effectively implementing their quality assurance program in accordance with Regulatory Guide 4.15 to the extent that it is applied except for the 2 deficiencies noted in the report. In addition, the audit team concluded that the identified deficiencies have no adverse impact to the quality of the products and services previously or currently Page 1 of 12 Downloaded or Printed copies are UNCONTROLLED copies

being provided by TBE-ES. Based on this conclusion, TBE-ES will be re-qualified on the Entergy qualified suppliers list (QSL) to provide radiochemical analysis of environmental samples, radiochemical analysis of radioactive waste samples, bioassay analysis results, and laboratory services.

Audit Summary:

This re-qualification audit was performed and reported in accordance with applicable Entergy procedures utilizing revision 1 to part 1 of the NUPIC radiological audit checklist. During the audit, the team evaluated to the extent possible the implementation and adequacy of the TBE-ES QA program relative to Regulatory Guide 4.15. The audit scope included the following as defined in the Part 1 of the NUPIC radiological audit checklist:

Contract/Purchase Order Review Organizational Structure and Personnel Responsibilities Qualification of Personnel Operating Procedures and Instructions Records Quality Control in the Radioanalytical Laboratory Data and Computer Software Verification and Validation Assessments and Audits Preventive and Corrective Actions TBE-ESs quality program implementation was verified through review of records, review of procedures, observations of laboratory testing/analysis activities, and interviews with personnel.

In addition to providing radiochemical analysis of environmental samples, bioassay analysis results, and laboratory services, TBE-ES also performs radiochemical analyses for utility plant site radioactive waste samples which fall under 10CFR61. For the radiochemical analyses performed for the utility plant site radioactive waste samples there are isotopes included that are in addition to the isotopes analyzed in the environmental samples. For waste samples, additional isotopes such as Sr, Sr, Ni , Fe, I, C, Tc, Pu, Pu, Am, Cm, Cm, and Cm (i.e., isotopes of Strontium-89, Strontium-90, Nickel-63 Iron-55, Iodine-129, Carbon-14, Technetium-99, Plutonium-238, Plutonium-239, Americium-241, Curium-243, Curium-244, and Curium-242) are analyzed with the testing results being provided solely by TBE-ES as testing/analysis of these isotopes are not typically performed by the utilities. Since the utilities do not perform testing/analyses for these additional isotopes, the utilities do not perform a comparison of their testing/analysis results to the TBE-ES test results for waste samples for the purpose of assuring that the correct samples were submitted by the utility to TBE-ES. The utilities classify and characterize radioactive wastes using the test results provided by TBE-ES prior to contacting suppliers of waste disposal services for arrangement of shipments to the disposal sites. However, when classifying and characterizing radioactive wastes, some utilities may rely solely on TBE-ES test results, or some combination of their own analysis results and use TBE-ES test results only for those isotopes they are unable to test for or analyze at the utility plant site. Entergy uses TBE-ES results for characterization as well as classification of radioactive wastes. In addition, Entergy compares their own site testing/analysis results for environmental/bioassay samples to the TBE-ES test results for these environmental/bioassay samples to ensure that the correct environmental/bioassay test samples were shipped to TBE-ES.

The radioactive waste samples are handled in a separate part of the TBE-ES Knoxville, TN facility due to the potential for contamination and because the radioactivity levels of the waste samples are typically higher. There were no testing activities in process within the waste sample analysis area of the facility that could be observed during the audit. However, the audit team performed a walk-through of the laboratory area where the 10CFR Part 61 testing/analysis of waste samples is performed that allowed the audit team to verify laboratory conditions and laboratory equipment is suitably controlled. Also, the audit team verified that assigned personnel performing testing/analyses in the waste sampling laboratory were adequately qualified. In addition, the audit team observed the sample storage areas where the audit Page 2 of 12 Downloaded or Printed copies are UNCONTROLLED copies

team visually verified that waste samples are uniquely identified and stored in appropriately labeled locations allowing for easy retrieval.

The waste sample laboratory and the environmental sample laboratory are very similar with testing methods being similar or in some cases nearly identical. Based on these similarities and in the interest of efficiency, all the audit information was documented in part 1 the NUPIC radiological audit checklist with the applicable sections in part 4 of the radiological audit checklist not being used.

Audit Team:

Joseph C. Walker Audit Team Leader Entergy (ENT)

James L. Jones Auditor Entergy (ENT)

Brenda Mills Auditor (in-training) Entergy (ENT)

Alejandro Ramírez Auditor Comision Federal de Electricidad (CFE)

Evan Humes Auditor PSEG Nuclear LLC (PSE)

John S. Larson Auditor Nebraska Public Power District (NPPD)

Steve Lusk Auditor Tennessee Valley Authority (TVA)

James Reese Technical Specialist Entergy (ENT)

Personnel Contacted During the Audit:

Name Title A* B* C*

Arterburn, Karli Project Manager Cooper, Kenneth Sample Receipt Custodian Culston, Kristen Laboratory Technician Jeter, Keith Laboratory Operations Manager McKanney, Kelly Laboratory Technician Newton, John Quality Management Systems Director Northcutt, Sharon Quality Manager Thurman, Kim Project Manager Webb, Donna Laboratory Technician Wright, Jim Information Technology

• A = Pre audit conference

• B = During audit

• C = Post audit conference Audit Finding(s) Summary:

No audit findings were issued during this audit.

Audit Deficiency Summary:

There were two deficiencies issued during the audit. The details of these deficiencies can be found in the checklist.

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Technical Specialists Evaluation Summary:

TBE-ES provides analytical services for nuclear utility customers. Primary services offered by TBE-ES include the analysis for radiological effluents, environmental samples, 10CFR61 radioactive waste stream samples, and personnel bioassay samples. Areas reviewed included:

1. Sample Receipt Process Control

2. Laboratory Controls

3. Quality Control

4. Participation in a Laboratory Inter-Comparison Program The assessment of processes consisted of direct observations of work activities, interviews of applicable personnel, the review of records, and the review of procedures.

The audit produced satisfactory results with one deficiency being noted for gamma spectroscopy calibrations. The current process does not require appropriate validation and verification of Excel spreadsheets used to over check hand calculated gamma radioactivity levels for diluted secondary calibration standards made using the primary NIST-traceable mixed gamma standard. While no errors in spreadsheet calculations were identified during the audit, not applying independent validation and verification (V&V) process controls, which are required for other software and hand calculations related to sampling analysis reporting allows an opportunity for spreadsheet programming logic errors to reduce the precision in the calibration of gamma detectors, thereby leading to inaccuracies for data produced during analysis of the samples. Post calibration checks would potentially not detect these errors because it is traditional industry practice for gamma radioactivity analyses to process the same diluted calibration standards and compare results to NIST certified values for each nuclide in the mixed gamma standard.

As a result, inaccuracies for calibration of the gamma detectors would not necessarily reveal itself through analysis of the same standard. Depending on the magnitude of the error, daily quality control (QC) checks may possibly not detect the inaccuracies in the test data during calibration activities. Application of the independent V&V process for this spreadsheet would ensure precision of calibration for the detectors (See NCR 22-02 for additional details). Because this was an isolated event, and because no errors were identified this issue was a programmatic deficiency as there was no impact to quality.

Observations of personnel performance showed individuals were proficient in their assigned roles and they performed job assignments as required. The Laboratory Information Management System (LIMS) is used by TBE-ES to manage as well as store nearly all information related to receipt of customer samples, tracking of the analyses for these samples, calibration information for measuring and testing equipment (M&TE), and all other relevant information. The LIMS is a database management system that optimizes the TBE-ES business model which is to say that TBE-ES operates as a high-capacity production analytical lab. The LIMS ensures that traceability information is accurate and unique which allows ease of tracking for customer samples along with the associated analytical results. The LIMS also reduces the potential for human error during data entry when performing laboratory activities through use of laser scan man readable bar-coded labels facilitating the transfer of information into the LIMS and interchangeably between instruments integrated into the LIMS.

The results of the audit were satisfactory.

1. Sample Receipt Process Control This section reviewed the processes related to sample receipt and inspection, sample storage, preparation and processing for analysis, analysis of samples, and reporting of results to the customer.

References:

TBE-2007 Gamma Emitting Radioisotope Analysis, Revision 10, 12/28/2019 Page 4 of 12 Downloaded or Printed copies are UNCONTROLLED copies

TBE-2010 Beta Activity by Liquid Scintillation (Direct Prep), Revision 6, 07/15/2020 TBE-2012 Radioiodine in Various Matrices, Revision 11, 06/15/2021 TBE-4003 Sample Receipt and Control, Revision 14, 06/05/2021 TBE-4009 Detection Levels, Revision 3, 01/09/2020 TBE-6010 Laboratory Information Management Systems (LIMS), Original Version, 06/05/2019 TBE-7001 Receiving Packaged Radioactive Materials, Revision 12, 06/05/2019 Sample Receipt, Identification, Control, and Storage Receipt inspection for four milk samples from the Susquehanna Steam Electric Station (SSES) was observed. The customer requested analyses for gamma-emitting radionuclides ( ) and the iodine 131 isotope ( I). The customers chain of custody form was included with the shipment and was also electronically transmitted in a Microsoft WORD format to TBE-ES prior to sample arrival. The chain of custody WORD file is imported into the LIMS which minimizes the potential for human performance errors during data entry into the LIMS. The information for each sample was verified against the chain of custody form and a receipt checklist was completed to document that no discrepancies were noted. The LIMS generated a unique sample number along with computer-generated man readable bar-coded labels for each of the sample components. The individual labels containing the unique sample number was applied to each customer container. Samples were stored within the location identified by the location identifier which is also on the labels. The location identifier was also written on the outer refrigerator label for ease in locating samples for retrieval during analysis or disposal. The resulting receipt package was taken to the project manager for review and approval. Observations of the receiving inspection process was considered adequate and was effectively implemented.

The project manager for the environmental sample program performed a peer-check of the paperwork and documented approval electronically in the LIMS. This electronic approval is one of the numerous process overchecks ensuring the accuracy of sample information and that all specified analyses will be performed as required. These in-process inspections are a key part of TBE-ES quality controls. Approval by the project manager within the LIMS makes the data available to lab personnel when they query their work assignments for the day. The review/approval processes performed by project managers is adequate for assurance of accuracy in the LIMS information and was effectively implemented.

TBE-ES processes have minimal data entry relying primarily on file transfers for testing/analysis data as well as transfers of quality reviews by personnel. These largely automated processes for the LIMS minimize introduction of human performance errors in the system.

This process is unchanged from the previous audit. TBE-ES has established adequate measures for receipt of samples, identification of samples, control of samples, as well as storage of samples and is effectively implementing these measures.

Sample Preparation and Analysis The four milk samples received from Susquehanna were observed during preparation for and I analyses. The analysis was completed first because this is considered a non-destructive examination in that none of the sample is consumed in the performance of this analysis. Preparation for performance of the I analysis required consumption of a large portion of the sample, so this analysis is performed last.

Performance of the analyses in this order reduces the volume of sample required from the customer.

The milk samples had already been retrieved from the storage location identified in the LIMS prior to the observations of the analyses in the laboratory. The technician performing analysis queried the approved samples from the LIMS and printed sample labels for each of the 3.5-liter Marinelli beakers.

After beakers were labeled and the samples were transferred to the beakers, the beakers were weighed on a digital scale and the sample weights were electronically transferred into the LIMS. Sample analyses were then performed using the spectroscopy detector system housed in thick shielding.

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At completion of the analyses, the isotopic report was reviewed by the technician to verify sample identity, analysis parameters, and to ensure the required lower level of detection (LLD) values were met.

Analysis results were forwarded to the laboratory operations manager for review. Upon completion of the review by the laboratory operations manager, the analysis results were transferred into the LIMS.

Even though no unidentified energy peaks were listed on the analysis report, the technician and laboratory operations manager were questioned about how unidentified energy peaks would be handled.

This was a deficiency identified in the previous audit, although in the instances reported the unidentified energy peaks were secondary energy levels of radionuclides already identified as present in the samples (Previous NUPIC audit deficiency SR-2019-14-1 and TBE-ES NCR 19-09). In response to that audit, TBE-ES created and implemented a job aid where secondary gamma energies of radionuclides commonly identified in the samples are posted in the laboratory. These energy lines are not included in the spectroscopy libraries used by the software for radionuclide identification and quantification because their probability (yield) is too low for accurate quantification of activity level. However, these energy peaks may be detected and listed in the results as unidentified energy peaks. The job aid is used to determine if these energy peaks are secondary peaks of radionuclides already identified and quantified in the sample results. For unknown energy peaks not listed on the job aid, the laboratory operations manager would assist the technician in identifying the radionuclide(s) using the energy reference produced by TBE-ES, commonly known as the Kocher reference, calculating the resulting activity level, and updating the analysis report accordingly. This solution is satisfactory to ensure all radionuclides present in the sample are identified during analysis.

Following the analysis, the milk samples were prepared for I analyses. This is a more complex analysis that requires isolating I in the sample matrix using a combination of an anion resin, the addition of a stable iodine carrier, and the addition of binding agents as well as extraction chemicals to reduce the total iodine present to a palladium iodide ( Pd- I) precipitate, which is filtered, dried, and weighed to determine chemical yield that will be used in the analytical calculations. Sample preparation steps using 4 liters for each sample were observed, but time constraints did not allow observation of the entire analysis. The analyst was questioned about the purpose of various portions of the sample preparation and was knowledgeable of the process. This complex extraction process produces the most consistent results if the analyst performs the analysis activities on a regular basis. Through personnel workflows and qualifications, TBE-ES ensures that each analysis is performed by a primary technician with backup technicians available if needed. This practice ensures the technician remains familiar with the complex analysis techniques thereby providing for consistent and accurate analytical results.

Sample results were provided for review by the laboratory operations manager after the analysis was completed. The laboratory operations manager must review/approve of the data before it is transferred to the LIMS. This independent review of the data ensures the required I LLD values are met. Sample analysis reports generated in the LIMS are reviewed and approved by a project manager before results are provided to the customer.

Samples are returned to storage following analysis and held for a period after sample test results have been provided to the customer. If the customer questions analysis results, the sample can be pulled for reanalysis assuming that enough sample remains in unaltered form.

The area of sample preparation and analysis is unchanged from the previous audit, apart from the addition of the job aid for unknown gamma energy peaks. This area is adequately controlled and effectively implemented.

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2. Laboratory Controls This section reviewed the controls of radionuclides, cleanliness, handling, and NIST traceability.

References:

TBE-2007 Gamma Emitting Radioisotope Analysis, Revision 10, 12/28/2019 TBE-2012 Radioiodine in Various Matrices, Revision 11, 06/15/2021 TBE-4002 Quality Control Checking of Analytical Data, Revision 6, 12/20/2019 TBE-4019 Radioactive Reference Standard Solutions and Records, Revision 7, 06/08/2021 TBE-ES Radiation Protection Program Manual, Revision 6 Control of Radionuclides Radioactive source inventory and accountability is tracked in the LIMS. Tennessee Radioactive Materials License Number R-47173-G23 has an expiration date of 07/31/2028 and is unchanged since the previous audit. A random check of sources used in various areas of the laboratory indicated proper source identification and radiological markings. Most sources are maintained in common storage areas for adequate source control, but some sources such as tritium isotopes ( H ) and the carbon-14 isotopes

( C) are required to be dark adapted prior to analysis due to the adverse effect laboratory lighting can have on these sources, which requires that these isotopes be maintained within the analytical instruments. This is a common practice for these sensitive, low-level sources.

Established controls for radionuclides are considered adequate and are being effectively implemented.

Cleanliness and Handling Sample preparations for potentially radioactive samples was observed in multiple areas of the laboratory.

Personnel demonstrated good radiological control practices and wore proper personal protective equipment. All samples were clearly marked with radioactive stickers where applicable. Radioactive waste receptacles were properly marked, and waste levels were not excessive. Personnel contamination monitoring instruments were properly maintained and in good condition and were also observed to be source checked as required. All personnel wore dosimetry as required when working with radioactive samples and materials.

There were no 10 CFR Part 61 waste samples received or analyzed during the audit, but the laboratory operations manager explained the process and how it differs from the environmental samples typically analyzed by the laboratory. Separate labs are used for analysis of these typically high activity samples where higher levels of personnel protection and radiological controls are required. The remaining portions of the Part 61 waste samples are typically not returned to the customer. Storage areas for waste samples is in an isolated portion of the facility that provides required shielding for dose reduction to personnel.

The laboratory areas and associated analytical measuring and testing equipment (M&TE) used for environmental sample analyses was observed to be clean and well maintained. It could be seen from observations of personnel cleaning up their work areas at the conclusion of their assigned activities each day that these activities were being performed as required. Review of inspection documentation for laboratory fume hoods and safety showers located within this area of the laboratory showed that inspections were being performed as required. Laboratory fire extinguishers were properly charged and mounted appropriately for quick access. Laboratory counter space was observed to be clean with fresh counter paper applied. Anti-fatigue padded floor mats were used throughout the laboratory areas to aid technicians who often stand for long periods of time performing assigned analysis activities.

Controls for cleanliness and handling were considered adequate as well as effectively implemented.

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NIST Traceability The spectroscopy detector calibration records were reviewed, along with the respective radionuclide source certificates providing objective evidence that NIST-traceable radionuclide sources are used in the calibration of M&TE. Primary liquid radionuclide source standards are used to make secondary radionuclide source standards in various sample geometries. Spreadsheets are used for sample dilution calculations. Documentation of the radionuclide source standard serial number for primary radionuclide sources was included on the printed spreadsheet pages contained in calibration records for the various sample geometries reviewed. This provided traceability to the primary radionuclide source standards.

Several certificates for sealed radionuclide sources such as H and C were also provided for review showing there is clear traceability of instrument calibrations to the NIST traceable radionuclide source standards. The NIST traceable radionuclide source standard certificates are maintained along with instrument calibration records in fireproof cabinets. Certificates for the NIST traceable radionuclide source standards are also available from the various radionuclide source standard vendors upon request if the lab copy is damaged or lost. Controls which provide evidence of traceability for radionuclide source standards to NIST were considered adequate and noted to be effectively implemented.

3. Quality Controls This section reviewed the instrument reference standards, calibration records and QC samples and trends.

References:

TBE-1009 Calibration Systems, Revision 7, 10/15/2021 TBE-3001 Calibration and Control of Gamma-Ray Spectrometers, Revision 8, 6/20/2021 TBE-3006 Balance Calibration and Check, Revision 4, 11/02/2018 TBE-3009 Calibration, Use, and Maintenance of Pipettes and Pipettors, Revision 4, 02/01/2019 TBE-4002 Quality Control Checking of Analytical Data, Revision 6, 12/20/2019 TBE-4005 Quality Control Samples - Blanks, Spikes and Duplicates, Revision 7, 8/31/2021 TBE-4011 Quality Calculations and Charting, Revision 3, 12/04/2019 TBE-4019 Radioactive Reference Standard Solutions and Records, Revision 7, 06/08/2021 A review of calibration records for several spectroscopy detectors, liquid scintillation detectors, and gas flow proportional counters was conducted as no calibrations were performed by the technicians during the audit. Quality control charts are typically maintained internally by the instrument software. When an instrument fails the QC checks, the technician removes the instrument from service and places an Out of Service sign on the instrument to prevent further use of the instrument until the problem is identified and resolved.

Instrument calibrations are performed only when required and are driven by QC check results. Some instruments havent required recalibration in more than 10 years which is a testament to the stability of the instrumentation and laboratory environmental conditions.

Observations during the audit indicated that adequate and accurate calibrations were performed for spectroscopy equipment. Part of the calibration process is the use of Excel spreadsheets to verify hand calculations of the radioactivity levels for secondary working radionuclide source standards made from NIST traceable primary radionuclide source standards. The audit identified that while current processes require validation and verification (V&V) of Excel spreadsheets used to calculate activity levels for the diluted secondary radionuclide source standards or spike standards, it was noted that the laboratory operations manager had created the spreadsheet to verify hand-calculated values for calibration radionuclide source standard dilutions. While this spreadsheet was initially validated and verified by the laboratory operations manager prior to use, it was not independently verified and validated by the QA manager. This was discussed with the laboratory operations manager where nonconformance report Page 8 of 12 Downloaded or Printed copies are UNCONTROLLED copies

(NCR) number NCR 22-02 was initiated since the spreadsheet calculations were not verified in an appropriate and systematic manner. Per NCR 22-02, an additional Excel spreadsheet for radionuclide source standard dilutions will be employed to verify the original dilution calculation(s) as a secondary review. A copy of both sheets will be kept in the QA Managers office along with the standard calibration certificate and a backup of the spreadsheet stored on the TBE network. The QA manager is the only individual with access to the calculation verification spreadsheets, so no modifications can be made to the spreadsheets by anyone other than the QA manager.

During the audit, the spreadsheet used for calculating radioactivity levels of diluted secondary radionuclide source calibration standards was verified to have no errors and be producing accurate results. This spreadsheet was initially validated and verified by the laboratory operations manager prior to use. Creating the additional Excel spreadsheet for calculating the radioactivity levels for the purpose of appropriately verifying and validating calculations as a secondary review provides an additional barrier to ensure that no software errors are inadvertently overlooked that could potentially produce errors in the sample results. Because this was an isolated event, and because no errors were identified this issue was considered a deficiency with no impact to quality.

Except for the minor deficiency, quality controls are considered adequate and observed to be effectively implemented.

4. Participation in Lab Inter-Comparison Program The 2021 results for the Inter-Laboratory Performance Evaluation Program were reviewed for the three inter-laboratory programs in which TBE-ES participates covering multiple analytes in matrices approximating normal laboratory samples. The QA manager was interviewed to answer questions related to cross-check failures and discuss results of the cross-check program investigations.

References:

TBE-4005 Quality Control Samples - Blanks, Spikes and Duplicates, Revision 7, 08/31/2021 TBE-4006 Inter-Laboratory Performance Evaluation Programs, Revision 11, 11/07/2018 Interlaboratory Cross-Check Program:

TBE-ES participates in three inter-laboratory programs. Two programs are commercial - Environmental Resource Associates (ERA) and Eckert and Ziegler Analytics, and one program is government -

Department of Energy Mixed Analyte Performance Evaluation Program (MAPEP). In each program unknown samples with unknown activity levels are received by the cross-check laboratories for analytes of interest in matrices like those received from clients. The QA manager selects the analytes, matrices, and frequency of samples from those offered by each program. Samples are received, logged in, and analyzed per TBE-ES procedures. Analysis results are submitted to the test lab for evaluation, and the test lab provides a report flagging any results that exceed the respective programs specified warning and failure limits. Warnings or failures are investigated internally by TBE-ES and reports on failures are provided to the respective test labs. The samples provided by Analytics are assessed by criteria within the TBE-ES quality program.

Analytics Cross-Check Program Results:

Six samples were analyzed in March 2021. These were two milk samples, two activation product samples, one charcoal sample, and one soil sample. All sample results were evaluated as Acceptable.

Six samples were analyzed in September 2021. These were two milk samples, two activation product samples, one charcoal sample, and one soil sample. Out of 33 total analytes, three were evaluated as Acceptable with Warning.

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The controls for the analytics cross-check program were considered adequate and were observed to be effectively implemented.

ERA Cross-Check Program Results:

Nine samples were analyzed throughout 2021, including five water samples, two soil samples, and two activation product samples.

In March 2021, the Fe in water sample MRAD-34 was evaluated as Not Acceptable. The reported value was higher than acceptance limits (NCR 21-01). The investigation revealed an unexpected loss of sample during the plating process which caused an unusually low yield resulting in artificially high values for the sample test data. Re-analysis of a duplicate sample produced results that were evaluated as Acceptable. To prevent recurrence, lab technicians were instructed to conduct closer examinations of analysis plates for detection of possible sample loss and to automatically reprocess samples where a loss of sample is indicated or suspected.

In October 2021, the gross beta ( ) activity analysis for water sample RAD-127 was evaluated as Not Acceptable. The test data indicated a value that was slightly higher than the acceptance limits (NCR 21-10). The investigation failed to determine the cause of the deviation but did note the ERA acceptance limit was significantly tighter than the TBE-ES QC acceptance criteria for the instrument at the upper limit.

The reported result was well within the TBE-ES limit for QC results. H was also evaluated as Not Acceptable on this sample. The test data showed the value was lower than the acceptance limits (NCR 21-11). The investigation failed to determine the cause of the deviation but noted the ERA acceptance limit was significantly tighter than the TBE-ES limit for QC results on the instrument.

A Quick Response ERA sample was ordered following the gross beta and H failures. This sample was analyzed in December 2021 with the H result being evaluated as Acceptable. However, the gross was once again slightly above the acceptance limit. The investigation failed to determine the cause of the deviation. Again, the ERA acceptance limits were significantly tighter than the TBE-ES limits for QC results on the instrument. TBE-ES determined no corrective action was necessary since both H values were only slightly outside the acceptance range but well within the TBE-ES acceptable QC range for the instrument.

The controls for the ERA cross-check program were considered adequate and noted to be effectively implemented.

DOE MAPEP Cross-Check Program Results:

Five samples were analyzed in February 2021. These samples consisted of activation products, soil, urine, water, and vegetation samples. Gross alpha ( ) on activation product sample 21-GrF44 was evaluated as Not Acceptable. The reported value was lower than the acceptance range (NCR 21-02).

The investigation revealed a possible mispositioning of the filter in the sample container by the vendor.

The MAPEP instructions stated the spiked side of the filter is placed in the packet facing up toward the label. The filters are not marked, so the analyst must maintain correct orientation of the filter when transferring from the packet to the instrument for analysis. The technician utilized a practice of placing a small dot on the outer edge of the spiked side of the filter immediately upon opening the filter packet to ensure the correct filter orientation could be maintained without question. Since the filter itself will shield activity from the detector, correct orientation is critical for accurate results. The sample was reanalyzed with the same orientation as the initial count and again with the filter flipped. It was noted that the analysis with the filter flipped so the spiked side was facing away from the detector yielded results that were Acceptable.

TBE-ES requested the vendor mark the filter in a similar way to ensure the filter orientation is maintained correct for analysis. Until the vendor adopts this practice, TBE-ES lab technicians will mark the filter as described above to ensure the correct orientation is maintained. The investigation resulted in no further Page 10 of 12 Downloaded or Printed copies are UNCONTROLLED copies

corrective actions since it is suspected the vendor oriented the filter incorrectly in the packet. It should be noted that normal air filter samples give clear indication of the correct side to face the detector due to the large volume of air filtered that discolors the filter on the inlet side. The dot technique is not necessary for correct positioning of customer air samples.

On the same sample set, the nickel-63 isotope ( Ni) on soil sample 21-MaS44 was evaluated as Not Acceptable. The reported value was lower than the acceptance range (NCR 21-03). The investigation noted the MAPEP soil sample is spiked with radionuclides known to interfere with the Ni analysis.

These interferences were evaluated as not completely removed in the TBE-ES precipitation and separation process used in the analysis. The TBE-ES process is sufficient for customer soil samples because they do not contain the interfering radionuclides added to the cross-check sample. The procedure for soils analysis has been re-evaluated against national standards and rewritten to provide better removal of known interferences to ensure lower loss of Ni in the sample preparation process.

Five samples were analyzed in August 2021. Samples consisted of activation products, soil, urine, water, and vegetation samples. Ni and technetium-99 isotope ( Tc) on soil sample 21-MaS45 were evaluated as Not Acceptable. The Tc analysis was not required and was performed for TBE-ES information only.

The Ni result was lower than the acceptance range (NCR 21-13). The investigation again noted the presence of interfering radionuclides that are not typically present in customer soil samples. Further investigation into a revised sample preparation continues, and until a more definitive solution is found for analyzing the MAPEP soil cross-check samples, a matrix spike will be added to all Ni soil and sediment samples to ensure quality analysis results are achieved.

The controls for the DOE MAPEP cross-check program were considered adequate and noted to be effectively implemented.

Technical Specialist

Conclusion:

It was concluded that TBE-ES is employing processes that ensure control of sample receipt, laboratory processes, measuring and testing equipment calibration, and the laboratory inter-comparison program.

All performance-based audit attributes, for activities observed during this assessment, were determined to be implemented satisfactorily.

Conclusions The TBE-ES Quality Program is adequately documented. Except for the two deficiencies, TBE-ES is effectively implementing these established measures. TBE-ES will be maintained on the Entergy qualified suppliers list with no procurement requirements.

Previous Audit Findings/ Deficiencies:

(Ref. NUPIC Audit 24791 / EXL SR-2019-14)

No findings were identified during the last NUPIC audit. One deficiency was identified during the previous audit. Through observations it was verified that adequate corrective actions continue to be effectively implemented.

Review of Previously Identified Industry Issues and/or NRC Information:

Review of the INPO OE database and the NUPIC database was conducted which resulted in no industry related issues associated with TBE-ES.

TBE-ES Nuclear has not had any NRC Inspections since the previous audit.

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Unique Order Entry:

There are no unique order entry requirements. Contracts and/or purchase orders should be submitted to the Knoxville, TN office to the following address:

Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-3133 Approved Shipping Location:

TBE-ES provides testing services and does not ship manufactured items. TBE-ES typically disposes of samples and does not return anything to the utility. However, when samples are returned to the utility this happens when the sample is mixed waste, both radioactive and hazardous. Normally this only occurs 1-2 times per year. If shipping was required, the shipments would be from:

Teledyne Brown Engineering - Environmental Services 2508 Quality Lane Knoxville, TN 37931-3133 Report Approvals:

Joseph C. Walker Digitally signed by Joseph C. Walker DN: cn=Joseph C. Walker, c=US, o=Supplier QA, ou=NIOS, email=jwalk15@entergy.com Reason: I agree to the specified portions of this document Date: 2022.03.07 10:35:13 -06'00' Audit Team Leader Date James Digitally signed by James Reese SN: C=US O=Entergy CN=James Reese OU=GGNS Chemistry Reese E=JReese3@entergy.com Date: 2022.03.08 00:55:47 -06'00' Technical Specialist Date Guy Digitally signed by Guy Robinson DN: cn=Guy Robinson, c=US, ou=Entergy Supplier QA, Robinson email=hrobin1@entergy.com Date: 2022.03.07 11:42:15 -06'00' NUPIC Representative Date Supervisor, Supplier QA Date Confidentiality Statement This audit report, including any attachments, contains or may contain confidential and privileged information solely for the use of the individual and/or supplier to whom they are addressed. Suppliers receiving a copy of the joint utility audit report directly from the lead utility are to consider the documents confidential and proprietary and shall consider the document for information only and may not disclose in whole or in part, by any means, to any third party without the written consent of the lead utility. Also note that this joint utility audit does not constitute nor imply any industry-wide endorsement, certification, approval or disapproval of your Quality Assurance Program and the results shall not be used in any supplier advertising material.

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Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies Downloaded or Printed copies are UNCONTROLLED copies END OF DOCUMENT Downloaded or Printed copies are UNCONTROLLED copies