Text

Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054
	ML23206A244
Person / Time
Site:	Columbia
Issue date:	07/25/2023
From:	Leidich A, Lepre M, Walsh T; Energy Northwest, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	; Office of Nuclear Reactor Regulation, NRC Region 4, Document Control Desk
Shared Package
ML23206A243	List: ML23206A244;
References
	EA-23-054, IR 2023092
	Download: ML23206A244 (1)
	v • d • e

Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW l Washington, DC 20036 l tel 202.663.8000 l fax 202.663.8007 Michael G. Lepre tel: +1.202.663.8193 michael.lepre@pillsburylaw.com www.pillsburylaw.com 4866-7463-6146.v1 July 25, 2023 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re:

Energy Northwest Columbia Generating Station Docket Number 50-397 Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 On behalf of Energy Northwest, I am submitting the enclosed Response to the Apparent Violation in NRC Inspection Report 05000397/2023092 (EA-23-054) dated June 1, 2023 (Inspection Report). The NRC previously agreed to extend the due date for this response to July 25.

The Inspection Report alleges that Energy Northwest violated NRC regulations (specifically 10 CFR § 20.1204(a)) and Energy Northwests internal procedures when it evaluated the radiation dose received by two pipefitters during an event at Energy Northwests Columbia Generating Station on May 28, 2021. Specifically, the Inspection Report alleges one apparent violation with a preliminary white finding:

Energy Northwests failure to take suitable and timely combination of measurements, including radioactive material in air in work areas, and urine and fecal samples to properly evaluate alpha emitters [specifically Pu-239/240] in the body contributing to the accrued internal dose, resulting in an inability of the licensee to properly assess the dose accrued by the pipefitters following the reactor water cleanup (RWCU) contamination event on May 28, 2021.

As this Response explains in detail, Energy Northwest has investigated the NRCs allegations and determined that, consistent with 10 CFR § 20.1204(a), NRC guidance, industry standards, and Energy Northwests own procedures, Energy Northwest did indeed take suitable and timely measurements of a combination of (1) radioactive material in air in work areas (through air samples); (2) quantities of radionuclides in the body (through whole body counts); and (3) quantities of radionuclides excreted from the body (through 24-hour urinalysis).

As also explained below, contrary to the Inspection Reports allegations, the data and evidence did not at the time of the event, nor in subsequent analyses, indicate the

July 25, 2023 Page 2 www.pillsburylaw.com 4866-7463-6146.v1 presence of Pu-239/240 in any of the samples. And, based on that data, Energy Northwest did not violate its procedures or NRC regulations.

Energy Northwest requests that Exhibits A and C be withheld from public disclosure because they contain personal privacy information regarding individual dose assessments.

If you have any questions or require additional information, please contact Mike Lepre at 202-663-8193.

Sincerely, Michael G. Lepre Timothy J.V. Walsh Anne Leidich Counsel for Energy Northwest

Enclosure:

Attachment I - Response to Apparent Violation (EA-23-054) cc:

Director, Division of Radiological Safety and Security, U.S. NRC, Region IV 1600 East Lamar Blvd.,

Arlington, Texas 76011-4511 Resident Inspector Columbia Generating Station

-h>2{/(U

www.pillsburylaw.com 4866-7463-6146.v1 Attachment I Response to Notice of Apparent Violation (EA-23-054)

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4866-7463-6146.v1 I.

The White Finding NRC Inspection Report 05000397/2023092 dated June 1, 2023 (the Inspection Report),

identified a preliminary white finding associated with Energy Northwests alleged failure to adequately determine the initial radiation dose two pipefitters received during an event that took place on May 28, 2021, at Energy Northwests Columbia Generating Station.

According to the NRC, Energy Northwest violated 10 CFR § 20.1204(a) because it allegedly failed to take suitable and timely measurements of concentrations of: (1) radioactive material in air in work areas; (2) quantities of radionuclides in the body; (3) quantities of radionuclides excreted from the body; or (4) combinations of these measurements, and therefore failed to properly assess the internal dose of two pipefitters.1 The Inspection Report adds:

[T]he licensee failed to use a combination of measurements, based on steps noted in their dose assessment procedures, PPM 11.2.4.5, PPM 11.2.4.6, and HPI-5.9 to adequately assess the internal dose. The licensee only took one 24-hour urine sample from each pipefitter, day 2 post the uptake event, and did not continue these in vitro assessments to establish elimination rates, nor did they take radioactive material in air in work area, evaluate the [whole-body count (WBC)] and survey assessments to determine that fecal sampling was needed to appropriately measure hard-to-detect radionuclides, including alpha emitters.2 The Inspection Report also states that at least one alpha emitter of [Plutonium-239/240 (Pu-239/240)], was not properly addressed or evaluated by the licensee.3 As support for this claim, the Inspection Report points to internal dose assessment data for the workers that allegedly show[s] the presence of an alpha emitter based on the following: the RWCU pipe smear had positive alpha counts for Pu-239/240, the air sampler within the RWCU heat exchanger room had indications of Pu-239/240 (no air sampling was completed in the breathing zone of the workers), and one of the pipefitters had a positive count for Pu-239/240 within their urine sample.4 Based on this, the Inspection Report claims that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters.5 1 Inspection Report at 6, 7.

2 Inspection Report at 6.

3 Inspection Report at 5.

4 Inspection Report at 5.

5 Inspection Report at 6. The Inspection Report further states, Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters. In support of this conclusion, the internal dose assessment performed by the licensees vendor stated, Additional 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion because the initial intake data performed by the vendor was not matching the licensees WBC data, as provided.

Paragraphs 16 and 17 of the attached Affidavit of Mr. Eric Darois (the Darois Affidavit), Executive Director of

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4866-7463-6146.v1 II.

Energy Northwests Response A.

Factual Background As the Inspection Report explains, on May 28, 2021, while performing weld preparations on the RWCU heat exchanger system piping at Columbia Generating Station, an airborne radioactivity event occurred that caused 22 positive intakes of radioactive materials, including significant uptakes of radioactive material by two pipefitters. After this event, Energy Northwest followed its applicable procedures and conservatively assessed dose to the two pipefitters following an evaluation of numerous whole body counts (WBCs), job coverage contamination surveys, smear samples from the RWCU pipe, a sample from the filter of the air sampler in use during the event, and a 24-hour urinalysis from each of these two pipefitters, in compliance with the requirements of 10 CFR § 20.1204.

Specifically, Energy Northwest first used a whole-body count to assess the initial scope of the anticipated dose. Shortly after the event, Radiation Support then ordered a 24-hour urinalysis for the two pipefitters to identify hard-to-detect isotopes and sent out work area samples for analysis.

As described in more detail below, existing test data and activity ratios in the work area indicated minimal alpha activity. As a result, Radiation Support was primarily concerned with identifying hard-to-detect beta-gamma emitters through urinalysis. Energy Northwest continued WBCs for the two pipefitters to determine elimination rates. In fact, one pipefitter underwent 16 total WBCs from May 28 (shortly before midnight) to June 7, 2021, while the other pipefitter underwent 25 total WBCs from May 29 (shortly after midnight) to June 9, 2021.6 After the whole-body counting was complete and a few weeks had passed, Energy Northwest received additional work area activity data, including an analysis of an area air sample and a RWCU pipe smear. This information was utilized by a third-party contractor to determine dose for the two pipefitters.7 Energy Northwest then used a separate third-party contractor to check and confirm the first contractors dose analysis.8 B.

Discussion

1.

Energy Northwest complied with applicable NRC regulations.

10 CFR §§ 20.1502 and 20.1204 contain the NRCs sole formal regulatory requirements related to the collection of measurements to determine internal radiation exposure. 10 CFR § 20.1502 states in relevant part that [e]ach licensee shall monitor (see § 20.1204) the occupational intake of radioactive material by and assess the committed effective dose equivalent to[a]dults likely Radiation Safety and Control Services (RSCS) (the vendor referenced in this quotation), describes how the Inspection Report has misinterpreted and taken this quotation out of context.

6 Exhibit A [Whole-body count datasheets].

7 Exhibit C [Compendium Laboratories Report] at PDF p. 195, 251.

8 Darois Affidavit at ¶ 9. RSCS also independently evaluated dose for these intakes. See Exhibit C [Compendium Laboratories Report] at PDF p. 75.

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4866-7463-6146.v1 to receive, in 1 year, an intake in excess of 10 percent of the applicable annual limit on intakes (ALI(s)), or 500 mrem committed effective dose equivalent.

Under 10 CFR § 20.1204(a), the licensee is required to take suitable and timely measurements of (1) Concentrations of radioactive materials in air in work areas; or (2) Quantities of radionuclides in the body; or (3) Quantities of radionuclides excreted from the body; or (4)

Combinations of these measurements. The Inspection Report claims that Energy Northwest violated 10 CFR § 20.1204(a) (and therefore 10 CFR § 20.1502), because it did not take [a]

suitable and timely combination of measurements.9 That claim is incorrect.

As an initial matter, 10 CFR § 20.1204(a) does not require licensees to take a suitable and timely combination of measurements. The four subsections of the regulation are connected by the word or (not and), meaning that performing any one of the measurements listed in

§ 20.1204(a)(1)-(4) in a suitable and timely manner satisfies the regulations plain language. A reading of § 20.1204(a) that give[s] effect, if possible, to every clause and word as required by U.S. Supreme Court precedent would clearly and unambiguously indicate that only one of the measurements in § 20.1204(a) must be performed.10 Energy Northwest cannot be found to have violated that regulation by failing to take a combination of measurements because under the regulations plain language doing so was one of four options and not explicitly required.

Moreover, the Inspection Reports broad claims that the licensee failed to take suitable and timely measurements of concentrations of radioactive materials in air in work areas, urine and fecal samples, as well as properly evaluate alpha emitters in the body contributing to the accrued internal dose11 are factually misleading. While it was not obligated to do so under 10 CFR

§ 20.1204(a), Energy Northwest actually took a combination of all these measurements, doing more than what the regulation required, by taking (1) work area air samples12 (in addition to pipe smears);13 (2) numerous whole-body counts;14 and (3) 24-hour urine samples from each pipefitter (note that 10 CFR § 20.1204(a)(3) does not specify whether excretions must be urine or fecal samples).

Accordingly, Energy Northwest clearly complied with 10 CFR § 20.1204(a). On that basis alone the NRC should withdraw the Apparent Violation as a matter of law.

9 Inspection Report at 7.

10 Duncan v. Walker, 533 U.S. 167, 174 (2001). See also Kisor v. Wilkie, 139 S. Ct. 2400, 2409 (2019) (explaining that courts are to interpret regulations using the traditional rules of construction).

11 Inspection Report at 11.

12 See, e.g., Exhibit B [Air Sample 1097086 Spreadsheet]; Exhibit C [Compendium Laboratories Report] at PDF p.

323.

13 See, e.g., Exhibit D [Survey VSDS_Prod-M-20210529-13]; Exhibit E [Survey VSDS_Prod-M-20210513-33];

Exhibit C [Compendium Laboratories Report] at PDF p. 326.

14 Exhibit A [Whole-body count datasheets]. In total, one pipefitter underwent 16 total WBCs from May 28 (shortly before midnight) to June 7, 2021, while the other pipefitter underwent 25 total WBCs from May 29 (shortly after midnight) to June 9, 2021.

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2.

Energy Northwests actions were suitable and timely, consistent with NRC guidance and industry practice.

It is also clear that all of Energy Northwests measurements were suitable and timely because they were consistent with (1) Regulatory Guide 8.9, which the NRC staff published as non-mandatory general guidance for meeting the requirements set forth in 10 CFR §§ 20.1502 and 20.1204; and (2) industry practice.

For a radiation intake like this onegreater than 10% of ALI (annual limit on intake)Reg.

Guide 8.9 recommends multiple bioassay measurements and an evaluation of available workplace monitoring data.15 However, it does not mandate a particular type of bioassay measurement (in vivo or in vitro). Rather, Reg. Guide 8.9 says measurement types should be selected based on the physical and biological characteristics of the radioactive material.16 And that is precisely what Energy Northwest did.

For example, under Reg. Guide 8.9, in vivo lung or total body measurements shortly following exposure generally provide reliable estimates of intakes for most gamma emitting radionuclides, (like Co-60 and Co-58) while in vitro measurements should be used for radionuclides that emit little or no gamma radiation.17 To the extent that in vitro measurements are selected, Reg. Guide 8.9 does not state a preference for feces sample collection over urine samples or otherwise require a specific duration of sampling.18 Here, Energy Northwest used numerous whole-body counts (an in vivo measurement) along with a 24-hour urine sample (an in vitro measurement) of each pipefitter as its multiple bioassay measurements. With initial workplace monitoring data indicating a statistically insignificant quantity of alpha emitters,19 and subsequent workplace monitoring indicating a significant presence of Co-60 and Co-58 (both gamma emitters),20 the analysis appropriately focused on whole body counts (in vivo measurements) with a confirmatory 24-hour urinalysis (in vitro measurements) to identify hard-to-detect isotopes, including hard-to-detect beta/gamma emitters.

Having performed this analysis and identified the isotopes in the intake, Energy Northwests outside consultants at Hanford Mission Integration Solutions (HMIS) were then able to determine an appropriate retention and excretion curve in accordance with Reg. Guide 8.9, leading to a dose assessment.21 This dose assessment was later independently reviewed and 15 Reg. Guide 8.9 at 8.9-4.

16 Id.

17 Id.

18 See generally id.

19 See infra at Section B.3.a.

20 See, e.g., infra at Section B.3.b; Exhibit C [Compendium Laboratories Report] at PDF p. 256.

21 See Exhibit C [Compendium Laboratories Report] at PDF pp. 256-257. While the initial data was not a good fit for historical retention and excretion curves, a subsequent review of the published literature found a similar fit in a publication from 2007. Id. at 257.

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4866-7463-6146.v1 confirmed by RSCS.22 Thus, Energy Northwests analysis was performed in compliance with published NRC guidance.

Beyond Reg. Guide 8.9, the NRC has otherwise declined to define suitable and timely measurements under 10 CFR § 20.1204. Rather, according to the NRC, whether measurements are suitable and timely is a matter of professional judgement in a good radiation protection program.23 Energy Northwest exercised sound professional judgment consistent with industry standards. In the absence of more specific regulatory requirements, the Electric Power Research Institute (EPRI) has developed a voluntary set of Alpha Monitoring and Control Guidelines for Operating Nuclear Power Stations (the Guidelines) with more detail on how to comply with US regulations.24 These Guidelines were developed, by consensus, by a group of radiation safety professionals representing twenty six US and six international nuclear companies shar[ing] their collective experiences and expertise.25 The Guidelines establish the use of activity ratios and provide further detail on the need for monitoring to indicate the potential presence of alpha emitter exposure in individuals.26 These Guidelines are consistent with the requirements of Reg. Guide 8.9, although they provide more detailed guidance. Specifically, the Guidelines provide that whole-body counting (as noted previously, both pipefitters underwent numerous whole-body counts) may be used to investigate a low level intake from alpha emitting nuclides (for example, above the screening level of 10 mrem committed effective dose), using scaling factors determined from representative characterization samples from the work area at times soon after exposure, such as [a]ir samples or smears from the work area.27 That is, if the activity ratio is Level I, as it was here,28 the alpha dose can be inferred from the gamma dose using a scaling factor from air samples and smears from the work area. Under the 22 Darois Affidavit at ¶ 9.

23 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html.

24 EPRI Alpha Monitoring and Control Guidelines for Operating Nuclear Power Stations, Revision 2 (2013)

(ADAMS Accession No. ML14083A589) [hereinafter EPRI Alpha Monitoring Report]. EPRI is the Electric Power Research Institute, an independent non-profit energy research, development, and deployment organization, with three specialized labs.

25 Id. at v.

26 See generally id.

27 Id. at 5-2 to 5-3.

28 Energy Northwests job coverage contamination surveys that existed at the time of the event generally indicated that the activity ratio of the area was consistent with a Level I Area, i.e., an area with a derived air concentration (DAC) fraction ratio (or ratio of alpha to beta-gamma activity) below 0.1. EPRI Alpha Monitoring Report, at 2-3, 2-6. More specifically, air samples taken on May 28 from 9:20 pm until 11:05 pm and analyzed a few hours later indicated a DAC fraction ratio of only 0.01. See Exhibit B [Air Sample 1097086 Spreadsheet]. According to industry standards, [i]n Level I Areas, the relative abundance of loose alpha contamination compared with

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4866-7463-6146.v1 Guidelines, whole-body counting can be used until alpha doses reach 100 mrem or the activity ratio is greater than Level I.29 If alpha exposures are expected to exceed 100 mrem then 24-hour sampling is required, and if alpha exposures are expected to exceed 500 mrem, then excreta sampling is required for five days.30 Energy Northwest followed these industry Guidelines. In (1) a Level I area, with (2) evidence of minimal alpha activity (see Section B.3.a below), and (3) anticipated alpha exposures expected to be below 100 mrem based on activity ratios, whole-body counting was sufficient to establish dose. Yet, Energy Northwest also performed 24-hour urinalyses on both pipefitters and confirmed (as also described in Section B.3.b below) that there was no statistically significant, conclusive indication of any alpha emitters in the urine.31 More significant samples were not recommended under the Guidelines unless alpha exposure was expected to reach 500 mrem,32 a level beyond even the approximately 100 mrem alleged (improperly as described in paragraph 17 of the Darois Affidavit) in the NRC Inspection Report.33 For these reasons, Energy Northwest complied with consensus industry standards and no additional sampling was necessary.34 Mr. Darois agrees, stating in paragraph 12 of his Affidavit: Based on my review of these measurements results, and my 46 years of experience in this industry, my professional opinion is that Energy Northwests measurements were suitable and timely measurements such that under standard industry practice, either at the time of the incident or at any point thereafter, Energy Northwest did not need to take additional in vitro measurements to determine internal exposure....

The NRC cannot credibly conclude that Energy Northwest failed to exercise professional judgment when it followed well established industry practice, NRC regulatory guidance, and the applicable regulations. Nor can the NRC use enforcement actions to impose new requirements on its licensees without adequate prior notice. As the Supreme Court has explained, regulated parties should know what is required of them so they may act accordingly precision and guidance are necessary so that those enforcing the law do not act in an arbitrary or discriminatory way. Federal Communications Commission v. Fox Television Stations, Inc.,

567 U.S. 239, 253 (2012).

beta-gamma contamination is minimal, and [i]nternal exposure from loose alpha emitters is not likely to exceed 10% of the total internal dose. Id. at 1-2.

29 Id. at 5-3.

30 Id. at 5-4.

31 Infra at B.3.b.

32 EPRI Alpha Monitoring Report at 5-4.

33 Inspection Report at 6. (Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters.)

34 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html.

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3.

The Inspection Report incorrectly asserts that Pu-239/240 is a significant contributor to dose.

While Energy Northwest complied with regulatory requirements, guidance, and industry standards, the Inspection Report nevertheless alleges that Energy Northwest should have taken additional excrement samples due to data for the workers show[ing] the presence of Pu-239/240.35 The Inspection Report misreads the relevant data. Energy Northwest did not need to take additional internal dose measurements because: (1) at the time of the event, when Radiation Support decided on the tests to measure internal dose, available data did not show the presence of Pu-239/240; and (2) even now, there is still no data showing that Pu-239/240 was detectable or present.

a.

Contrary to the Inspection Report, at the time of the event (when Radiation Support decided on the tests to measure internal dose), available data did not show the presence of Pu-239/240.

Energy Northwest reviewed numerous tests indicating that the RWCU system (on which the pipefitters were working), and the work area itself contained minimal (if any) alpha emitters. As such, Energy Northwest in its professional judgement had no reason to believe that Pu-239/240, or any other alpha emitter, would be a significant contributor to the pipefitters dose.

As an initial matter, Energy Northwest had an independent laboratory report from December 2020 showing that water in the RWCU system at issue here contained no alpha emitters.36 That report states that all analyzed alpha emitters, including Pu-239/240, were not detected above the

[Minimum Detection Limit (MDL)], [Minimum Detectable Activity (MDA)],37 [Minimum Detectable Concentration (MDC)] or [Limit of Detection (LOD)].38 Pu-239/240 specifically was noted in the RWCU system at 2.01E-5 uCi/g, below the Minimum Detection Amount for Pu-239/240 of 6.23E-5 uCi/g.39 In addition, Energy Northwests job coverage contamination surveys from the time of the event indicated that the activity ratio of the area was consistent with a Level I Area under the EPRI 35 Inspection Report at 5.

36 See Exhibit F [2020 RWCU Sample Results] at PDF p. 26.

37 A minimum detectable activity is used to determine the capabilities of the counting system used and to ensure that the action levels appropriate for the analysis are statistically distinguishable from background, typically at a 95% confidence level. EPRI Alpha Monitoring Report at D-7. This is related to the lower limit of detection which is generally the point at which a radioactive material will be detected with at least 95% probability and with no greater than a 5% probability of falsely concluding that a blank observation represents a real signal.

NUREG/CR-4007, Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements at 67 (1984) (ADAMS Accession No. ML16152A647).

38 Exhibit F [2020 RWCU Sample Results] at PDF p. 26.

39 Id.

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4866-7463-6146.v1 Alpha Monitoring Guidelines described previously.40 According to EPRI, [i]n Level I Areas, the relative abundance of loose alpha contamination compared with beta-gamma contamination is minimal, and [i]nternal exposure from loose alpha emitters is not likely to exceed 10% of the total internal dose.41 Air samples taken on May 28 contemporaneous with the event (from 9:20 pm until 11:05 pm) and analyzed a few hours later indicated a ratio of alpha to beta-gamma activity (DAC fraction ratio) of only 0.01, within the bounds of a Level 1 area.42 The minimal (if any) presence of alpha emitters demonstrated by the DAC ratio was further confirmed by smear data taken from the RWCU heat exchanger room and analyzed on the morning of May 29. That data indicated alpha activity from the smear below the decision level43 of the measurement device,44 consistent with prior smear data taken from RWCU piping on May 13 that also indicated alpha activity below the decision level of the measurement device.45 In short, available data at the time showed minimal alpha activity in the area, and there was no indication of any specific alpha emitters of concern, including Pu-239/240. As a result, at the time of the event there was no indication that either pipefitter had an intake of hard-to-detect radionuclides or specific alpha emitters sufficient to require in vitro bioassay sampling in addition to the 24-hour urinalyses that Energy Northwest conducted. As paragraph 17 of the Darois Affidavit states, there is no evidence that alpha emitters were present for the subject intake and this data represents a beta to alpha ratio of greater than 200,000:1. From this, it is apparent that fecal sampling and analysis would not have been needed to assess the dose.

b.

Contrary to the Inspection Report, there is still no reason to believe that Pu-239/240 was detectable or present.

Even without any indication of significant alpha activity, Energy Northwest continued to evaluate the event and obtained additional data including 24-hour urine samples from the pipefitters (requested by Radiation Support), along with smear samples and the filter from the air sampler in use during the event. Based on the Inspection Report, we have inferred that the NRC may be relying on some of this data to claim that Pu-239/240 was present and to also claim that further tests should have been conducted. But the NRC has misinterpreted the data, which actually shows that there is no reason to believe Pu-239/240 was present during the event.

Shortly after the event, Energy Northwest obtained 24-hour urine samples that were evaluated by HMIS labs and GEL Laboratories, LLC (GEL Labs).46 One pipefitters (Person 1) 24-hour 40 See supra, note 27.

41 EPRI Alpha Monitoring Report at 1-2.

42 See Exhibit B [Air Sample 1097086 Spreadsheet].

43 A decision level is generally the amount of a count as final instrument measurement of a quantity of analyte at or above which a decision is made that the analyte is definitely present. See DOE, Decision Level (Lc), available at https://www.directives.doe.gov/terms_definitions/decision-level-lc 44 See Exhibit D [Survey VSDS_Prod-M-20210529-13.]

45 See Exhibit E [Survey VSDS_Prod-M-20210513-33.]

46 As noted previously, HMIS also performed dose assessment, which was independently reviewed by RSCS.

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4866-7463-6146.v1 urine sample indicated the presence of only Co-60 and Co-58. No other isotopes were detected at levels above the decision level, including all alpha emitters and Plutonium isotopes.47 Specifically, as set forth on page 263 of Exhibit C (upon which we believe the Inspection Reports conclusions may rely, in part), Pu-239/240 was noted in the urine sample at 3.96E-3 pCi/s. But this value was below the Decision Level for Pu-239/240 of 4.61E-3 pCi/s. The lab decision level was set at twice the total propagated uncertainty48 (2-sigma), which is a statistical determination of detection with a 95% confidence interval.49 This data can only be read as showing, contrary to the Inspection Reports claim, that Pu-239/240 was not validly detected with statistical confidence in the pipefitters (Person 1) 24-hour urine sample. The Darois Affidavit at paragraph 13 agrees that the only reasonable way to interpret that data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

The other pipefitters (Person 2) 24-hour urine sample also indicated the presence of Co-60 and Co-58, in addition to Tc-99. No other isotopes were detected at levels above the Decision Level, including all alpha emitters and Plutonium isotopes.50 In fact, Pu-239/240 was noted in this pipefitters urine sample at negative 3.55E-4 pCi/s. This absence of any validly detectable alpha emitters in the urine samples only further demonstrates the absence of any significant alpha intake, and that Energy Northwests dose assessment met NRC regulations, NRC guidance, and industry standards as explained above in Section II.B.1-2.

Additional data obtained weeks after the event further confirmed the lack of any alpha emitters.

Energy Northwest obtained additional information from both an air sample of the room and an additional pipe smear taken at the time of the incident.

Regarding the air sample, PDF page 323 of Exhibit C (upon which we believe the Inspection Reports conclusions may rely, in part) indicates the presence of various isotopes including gamma emitters Co-60 and Co-58. But no alpha emitters were detected at levels above the Minimum Detectable Activity, including Plutonium isotopes.51 In fact, Pu-239/240 was noted at negative 1.27E-6 uCi/filter in the air sample, and the U in the Qualifier column (as defined in the footnotes) means that Pu239/240 was not detected above the MDL, MDA, MDC or LOD.52 Accordingly, this data also can only be read as showing that Pu-239/240 was not validly detected with statistical confidence in the air sample taken at the time of the incident. As the Darois Affidavit at paragraph 13 again confirms, the only reasonable way to interpret that 47 Exhibit C [Compendium Laboratories Report] at PDF page 263.

48 Total Propagated Uncertainty (or TPU) includes uncertainties not only in sample peak determination but also uncertainties in the isotopic abundance, relative absorption factor (where appropriate), decay factor, aliquoting, weighing, blank correction, peak overlap (where appropriate), impurities etc. Exhibit C [Compendium Laboratories Report] at PDF page 255.

49 Id. at PDF p. 255.

50 See id. at PDF p. 207.

51 See id. at PDF p. 323.

52 Id.

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I www.pillsburylaw.com 10 4866-7463-6146.v1 data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

The Inspection Report also appears to allege that Pu-239/240 was identified on the May 17 pipe smear.53 That is also incorrect. Pu-239/240 was not identified in this smear sample. In fact, Pu-239/240 was again noted at negative 7.23E-07 uCi/filter in the smear, and the U in the Qualifier column (as defined in the footnotes) means that Pu239/240 was not detected above the MDL, MDA, MDC or LOD.54 In short, contrary to the Inspection Reports claim, there is no statistically significant indication of the presence of Plutonium-239/240 in any of the measurements from the event, including the pipe smear, the air sample from the room, and the urinalysis data, nor is Energy Northwest aware of any available measured data associated with the event suggesting that alpha activity was a significant contributor to the dose (unless the NRC has additional information on which it is relying but has not specifically cited in the Inspection Report, to which Energy Northwest would be pleased to respond).

Accordingly, the Inspection Reports central claim that more testing was necessary because data showed the presence of alpha emitters is based on a misreading or misinterpretation of the relevant data.

4.

Energy Northwest complied with its own procedures.

The Inspection Report also claims that, due to the alleged presence of alpha emitters, Energy Northwest failed to comply with its own dose assessment procedures. For many of the reasons set forth above, this claim is incorrect.

Energy Northwests procedures cited by the NRCPPM 11.2.4.6, PPM 11.2.4.5, and HPI-5.9 govern the need for in vitro samples to determine internal exposures as needed to comply with 10 CFR § 20.1204. These procedures allow Radiological Support and Radiation Protection to exercise significant discretion in determining the necessary tests based on the specific facts of each potential exposure. Given that alpha emitters were not detectable or present in a statistically significant quantity, Radiation Support exercised its discretion, in accordance with its procedures, and determined to pursue 24-hour urinalysis, numerous whole-body counts, the smear, and air sample data to calculate dose.

Energy Northwest procedure PPM 11.2.4.6 provides that Radiation Protection supervision or Radiological Support determine when in vitro bioassay sampling is necessary to assess an 53 Inspection Report at 4-5.

54 See Exhibit C [Compendium Laboratories Report] at PDF p. 326. There was a relatively small amount of Pu-238 identified in this pipe smear taken 11 days prior to the event. Id. Those results, however, were not available to Energy Northwest until 3 weeks after the event, and such a small amount of Pu-238 would have resulted in only approximately 6 mrem of dose. See Darois Affidavit at ¶ 18. In addition, the presence of Pu-238 was not reliably detected in any of the other measurements from the site, including either urinalysis sample.

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I www.pillsburylaw.com 11 4866-7463-6146.v1 individuals intake of radioactive material.55 The procedure states that [i]n vitro bioassay sampling is not normally conducted at Energy Northwest, and is initiated only when whole body count results, air sample results, or personnel contamination events indicate the possibility that an individual has had an intake of hard-to-detect radionuclides (e.g., C-14, Fe-55, Sr-90, H-3, Am-241, Pu-239).56 Section 3.1 of PPM 11.2.4.6 identifies several events that may trigger the determination to conduct in vitro bioassay sampling.57 It is important to note that this language is permissive; the occurrence of any one of the events does not explicitly require in vitro bioassay sampling.

For one example, PPM 11.2.4.6 Section 3.1 states that in vitro bioassay sampling may be triggered if intake of alpha contamination (other than naturally occurring) has occurred or is suspected and the magnitude of the intake is unknown.58 As detailed throughout this Response, work area data indicated that the individuals were not likely to have an intake of hard-to-detect radionuclides or alpha emitters.

Section 3.1 also states that the determination to conduct in vitro bioassay sampling may be triggered based on a positive whole body count which indicates an intake greater than or equal to Action Level 1 (0.001 ALI or 5 mrem Committed Effective Dose Equivalent (CEDE)), as described in PPM 11.2.4.5.59 That was the case here.

But importantly, PPM 11.2.4.6 does not dictate the type or frequency of in vitro bioassay sample.

Rather, PPM 11.2.4.6 explicitly states that [t]he type and frequency of in vitro sampling is determined on a case-by-case basis, and should be based on the physical, chemical, and biological characteristics of the radionuclides.60 In addition, PPM 11.2.4.6 Section 5.1 directs that the procedures Attachment 8.1 be consulted for guidelines for type of sample needed for various radionuclides.61 Attachment 8.1, in turn, provides recommended sample types (urine or urine and feces) for various the radionuclides H-3 (Tritium), C-14, Fe-55, Sr-90, I-131, U-234/235/238, Pu-239/240, and Am-241.62 In this case, as described above data showed that the most prevalent isotopes in the work area were Co-60 and Co-58. Neither of these isotopes are identified on Attachment 8.1. Thus, the 55 PPM 11.2.4.6 at 3.1.

56 PPM 11.2.4.6 at 2.0.

57 PPM 11.2.4.6 at 3.1.

58 Id. at 3.1.2. This is consistent with procedure PPM 11.2.4.5, which provides in relevant part IF an intake of alpha emitting radionuclides is suspected, THEN EVALUATE the need to perform excreta sampling per PPM 11.2.4.6. PPM 11.2.4.5 at 5.4.1(d).

59 Id. at 3.1.1.

60 Id. at 2.0.

61 Id. at 5.1.1.

62 Id. at Attachment 8.1.

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I www.pillsburylaw.com 12 4866-7463-6146.v1 procedure did not suggest (let alone require) that Energy Northwest undertake either urine sampling or urine and feces sampling.

Furthermore, both Co-60 and Co-58 are gamma emitters, while no data indicated the presence of alpha emitters in statistically significant quantities. Accordingly, there was no clear need for in vitro sampling to assess [the] individuals intake of radioactive material from alpha emitters under Section 3.1.

Energy Northwests actions were also consistent with PPM 11.2.4.5. Section 5.4.3(d) of PPM 11.2.4.5 states in part, [f]or an intake equivalent to or greater than 3000 nanoCuries of Co-60 (an approximate CEDE of 1 rem), EVALUATE the contribution to the CEDE from alpha emitters.63 While there was sufficient intake of Co-60 to require a separate evaluation of alpha emitters in accordance with Section 5.4.3(d) of PPM 11.2.4.5, the 24-hour urinalysis Energy Northwest conducted was sufficient under its procedures to demonstrate that further evaluation was not required.

Nor was there any clear need to continue excreta collection until the elimination rates are well-established,64as the Inspection Report allegesgiven that elimination rates were needed for radioisotopes better identified through whole-body counting and a published elimination rate was later found to fit these circumstances.65 As such, 24-hour urinalysis, in combination with the other data available, met the requirements of PPM 11.2.4.5 and 11.2.4.6, subject to the discretion of Radiological Support and Radiation Protection.

Beyond these two procedures, HPI-5.9 requires that Energy Northwest use information from either in vitro bioassay measurements in addition to lapel or breathing zone air samples, scaling factors from air sampling in the work area, scaling factors from known contamination levels in the work area, or other plant scaling factors in the event of potential alpha intake.66 Since as described above the data showed that Energy Northwest had no reason to believe that alpha intake potentially occurred, this step was not required. However, Energy Northwest still obtained plant radiological data from other samples described above, including the air sample from the work area and pipe smears.

In sum, Energy Northwest reasonably interpreted and complied with its own procedures, which left significant discretion with Radiological Support and Radiation Protection. The NRC Staff has not provided evidence demonstrating that Energy Northwest deviated from its procedures or any reasonable interpretation of them. There was no violation of the procedures, particularly in a field where the NRC admittedly relies heavily on professional judgement.67 63 PPM 11.2.4.5 at 5.4.3(d).

64 Inspection Report at 5.

65 See Exhibit C [Compendium Laboratories Report] at PDF p. 257.

66 HPI-5.9 at § 4.5.

67 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I www.pillsburylaw.com 13 4866-7463-6146.v1 III.

Conclusion In summary, Energy Northwests actions to measure and to assess dose complied with applicable requirements and guidance. The worker internal dose was assessed in accordance with 10 CFR

§ 20.1204 and Energy Northwests procedures, as well as regulatory guidance and industry standards. Accordingly, Energy Northwest did not violate 10 CFR § 20.1204 and respectfully requests that the NRC withdraw the Apparent Violation.

AFFIDAVIT STATE OF NEW HAMPSHIRE

)

) ss COUNTY OF ROCKINGHAM

)

I, Eric L. Darois, hereby affirm and state as follows:

1. I am currently the Executive Director of Radiation Safety & Control Services, Inc.

(RSCS). I have served in that position for 34 years.

2. In that role, I have been a consultant for radiation protection project services for approximately 50 operating and decommissioning nuclear power plants and many more other users of radioactive material, including environmental laboratories, fuel fabrication facilities, Naturally Occurring Radioactive Material sites, medical and laboratory facilities, and other industrial sites. These services include providing calculations and measurements and serving in an advisory role for program operations, data management, Multi-Agency Radiation Survey and Site Investigation Manual implementation, internal dosimetry, and external dosimetry.

3. Over the course of my career I have performed many dose assessments and dose reconstructions, including dose reconstructions under the Energy Employees Occupational Illness Compensation Program Act of 2000. During my employment, I was responsible for technical support groups at Seabrook Station and Connecticut Yankee and responsible for internal and external dosimetry assessments and instrumentation operations and use. I have delivered dozens of presentations and training classes through my career (including statistical analysis and dose analysis) and was recipient of the Jason Jang Award in 2017 from the Organization for Economic Cooperation and Developments Nuclear Energy Agency North American Technical Centre and the Nuclear Energy Institutes Radiological Effluents and Environmental Workshop Steering Committee.

4. I have an M.S. degree in Radiological Sciences and Protection and a B.S. degree in Radiological Health Physics from the University of Massachusetts - Lowell, and am a practicing American Board of Health Physics-certified Health Physics professional.

5. I also served as an expert panel member for the Nuclear Regulatory Commissions Advisory Committee on Nuclear Waste (now merged into the Advisory Committee on Reactor Safeguards). I am currently a member of the Nuclear Energy Institutes Radiological Protection, Environmental and Radiological Waste Decommissioning Issues Task Force.

6. For four years, I was the principal investigator for four nuclear industry Electric Power Research Institute guidance documents relating to alpha contamination control programs and groundwater monitoring at nuclear power plants.

2

7. I have assisted two Canadian nuclear power facilities in dose reconstruction activities for large cohorts of workers to potential transuranic intakes. I also participated in the Energy Employees Occupational Illness Compensation Program Act of 2000 for the National Institute for Occupational Safety and Health Dose Reconstruction Project for the Department of Energy by performing dose reconstruction calculations for current and former workers of DOE and atomic weapons employees.

8. A copy of my curriculum vitae is attached to this Affidavit as Exhibit 1.

9. In support of this matter, in 2021 RSCS was contracted by Energy Northwest to perform two tasks: 1) An independent dose calculation from the intakes (completed in July 2021);

and 2) A review of the sites calculation of estimated air concentration for the workers intake (completed in October 2021). Our staff performed the first task and I reviewed and approved that document (TSD 21-052). That document contained in Exhibit C, PDF page 75, of Energy Northwests Response. Our staff performed, peer reviewed, and approved another document (TSD 21-083) in support of the second task. That document is attached to this Affidavit as Exhibit 2.

10. Also in support of this Affidavit, I reviewed the NRCs preliminary white finding in NRC Inspection Report EA-23-054 dated June 1, 2023. As part of that review, I performed a follow up second review of the initial calculation and of RSCSs previous internal review of this calculation, including the laboratory results of the air sample and smear analysis. I also have read the Response to which this Affidavit is attached.

11. In this proceeding, Energy Northwest utilized whole-body counting, a 24-hour urine sample for each pipefitter, area air sampling, and swab sampling for the purposes of assessing dose to the two pipefitters.

12. Based on my review of these measurements results, and my 46 years of experience in this industry, my professional opinion is that Energy Northwests measurements were suitable and timely measurements such that under standard industry practice, Energy Northwest, either at the time of the incident or at any point thereafter, did not need to take additional in vitro measurements to determine internal exposure, especially given that (based on my understanding from having read page 7 of the Responses description of an independent laboratory report from December 2020 showing that water in the RWCU system at issue here contained no alpha emitters) the site staff was aware of the isotopic characterization of the source-term responsible for the unplanned airborne event.

13. In addition, based on my review of those results, which I understand Energy Northwest provided to the NRC, I agree with Energy Northwests assertions in its Response at pages 8-10 that the only reasonable way to interpret that data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

14. According to the NRCs Inspection Report at page 6: Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal

3 dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters. In support of this conclusion, the internal dose assessment performed by the licensees vendor stated, Additional 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion because the initial intake data performed by the vendor was not matching the licensees WBC data, as provided.

15. RSCS is the vendor referenced in the last sentence of this quotation. For proper context, however, the following is a more complete excerpt from our document, TSD 21-052, page 7, The initial intake, using NUREG CR/4884 for Class Y Co-60 and the 24-hour urine sample, does not seem to match the IMBA initial intake using the WBC data. It is a factor of 20 lower for the initial intake. Based on the WBC data, this may indicate that a significant portion of the intake cleared via the ingestion path or clearance out of the lung is slower than the standard Cobalt kinetic modeling. A couple 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion.

16. We included the above statement in our assessment as merely an observation regarding the initial clearance of the material, not as a comment that Energy Northwest should have undertaken fecal sampling. This component of the intake would contribute a very small fraction of the assigned dose and would only have been used to reconcile the rapid clearance of the initial portion of the intake.

17. The NRC may have taken this statement from our report out of context. Based on my review of the smear and air sample data, there is no evidence that alpha emitters were present for the subject intake and this data represents a beta to alpha ratio of greater than 200,000:1. This ratio confirms that fecal sampling and analysis would not have been needed to assess the dose because there was no reason for Energy Northwest to believe at the time of the event or thereafter that a dose exceeding 100 mrem from alpha emitters occurred, and, in fact, a dose exceeding 100 mrem from alpha emitters did not occur.

18. Finally, although not referenced in the Inspection Report, I note that there was a relatively small amount of Pu-238 identified in the pipe smear taken 11 days prior to the event. Applying the ratio of the Co-60 to Pu-238 activity level in the air sample of 291,000 to 1 to the intake of 7.07E6 pCi of Co-60 equates to a scaled expected intake of Pu-238 of 24.3 pCi. The stochastic ALI for Pu-238 (Y form) is 2E-02 Ci or 20,000 pCi.

This equates to a CEDE of 24.3/20,000 x 5,000 mrem = 6 mrem. In summary, this small amount of Pu-238 would have resulted in only approximately 6 mrem of dose.

19. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

4 Eric L. Darois, M.S., CHP Executive Director Radiation Safety & Control Services, Inc.

Sworn to and subscribed before me:

This ____ day of ________________, 2023 Notary Public

Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP 1

CAREER PROFILE A broad-based ABHP-certified Health Physics professional with over 40 years of experience in various technical and managerial positions in nuclear power facilities, decommissioning sites, environmental laboratories, fuel fabrication facilities, NORM sites, medical and laboratory facilities and other industrial sites. Excellent experience in alpha contamination controls, internal and external dosimetry, groundwater contamination investigations, neutron measurements, instrumentation, decommissioning cost estimation, MARSSIM implementation and statistical analysis. Authored many professional papers and presentations and provided his experience as a consultant and technical expert to many clients dealing with radiation exposures, radiation detection and regulatory compliance, for both US and international clients. He was also the principal investigator for several nuclear industry -EPRI-guidance documents relating to alpha contamination control programs and groundwater monitoring programs. MS and BS in radiological sciences. Currently a member of NEIs RP, Environmental and Radwaste Decommissioning Issues Task Group.

PROFESSIONAL EXPERIENCE 4/89 - Present Radiation Safety & Control Services, Inc.

Corporate Executive Director Provides radiation protection consulting and project services for operating and decommissioning nuclear power plants and other users of radioactive material. These services include calculations and measurements as well as serving in an advisory role for program operations, data management, MARSSIM implementation, internal dosimetry and external dosimetry.

Participated in the technical review of a draft revision of the MARSSIM manual.

Principal investigator for four industry EPRI guidance documents. Two of these documents were related to the control of transuranic source terms at nuclear power plants and two were related to groundwater monitoring.

Served as a key member of the EPRI groundwater assessment team performing groundwater assessments at operating nuclear power plants.

Served as an expert panel member for the NRCs advisory committee on nuclear waste and on groundwater monitoring and modeling.

Assisted two Canadian Nuclear Power facilities in dose reconstruction activities for large cohorts of workers to potential transuranic intakes using monte carlo statistical tools.

Developed a unique criticality detection system and has a patent pending application for the development of a unique beta radiation simulation instrument for training of workers and technicians.

Principal designer of several RSCS software products including DeCAT -

Decommissioning Cost Analysis Tool, and, ADMS - Analytical Data Management System and has performed many decommissioning cost estimates in support of a variety of projects.

RSCS Director Lead for the development of a decommissioning cost estimation computer program for the Korean PWR nuclear power plants (KHNP) in conjunction with KOPEC Exhibit 1

Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP 2

which was completed in March 2009 and modified in 2011 to include collective dose (p-rem).

Participated in the NIOSH dose reconstruction project for the Department of Energy performing Dose Reconstruction calculations.

In support of several client projects, was the technical lead for several internal dose assessments involving a variety of source terms including: transuranics, natural and enriched uranium, mixed fission products, and Sr-90.

Performed various program audits for a variety of clients and topics including: alpha program implementation at nuclear power plants, radiation protection program implementation for the USGS and at large medical teaching institutions, and dose modeling review for a decommissioning NPP.

Project manager for the development of soil screening criteria and surface contamination release criteria for Canadian Nuclear Laboratorys Chalk River Site.

7/03 - 4/06 Radiation Safety & Control Services, Inc.

Yankee Rowe License Termination Project Manager As an RSCS Executive Director, was assigned to this project and was responsible for radiological closure of the site including development of the License Termination Plan, Groundwater Monitoring Program, site exposure model development and development/calculation of DCGLs, and Final Status Survey methodologies.

7/99 - 7/03 Radiation Safety & Control Services, Inc.

Bechtel Integrated Site Closure Manager for the Connecticut Yankee (CY)

Decommissioning As an RSCS Executive Director, was assigned to this project in a variety of positions including; LTP Technical Project Manager, Project Health Physicist, and HP Technical Group Lead.

Responsible for radiological and non-radiological closure of the CY site including development of the License Termination Plan.

Groundwater Monitoring Program, site exposure model development, and, development/calculation of the site DCGLs.

Expert witness for the CY LTP hearings 6/97 - 7/99 Radiation Safety & Control Services, Inc.

Connecticut Yankee Atomic Power Company Technical Specialist As an RSCS Executive Director, assigned to this project for a variety of responsibilities including the internal dosimetry program, the HP count room, and all radiological analysis.

Performed many radiological safety analysis (10CFR50.59), FSAR changes, internal dose evaluations, and offsite dose calculations.

Participated in an extensive re-write of HP procedures to support the Radiation Protection Improvement Program.

Exhibit 1

Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP 3

Instituted alpha contamination and internal dosimetry controls, and provided HP and site-wide training in support of the unique transuranic source term at this site.

4/91 - 7/97 North Atlantic Energy Services Corporation Health Physics Supervisor/Sr. Health Physicist/HP Support Group Responsible for the technical maintenance and development of the Radiation protection program at Seabrook Station.

Served as the HP department training liaison responsible for implementation of the training and qualification programs for department staff and technicians.

Served on the Health Physics Curriculum Advisory Committee (CAC).

Emergency response positions included: 1) Emergency Operations Facility (EOF)

Coordinator, and 2) Dose Assessment Specialist.

Provided technical oversight and direction for regulatory compliance, radiation measurements, dosimetry and other areas.

Performed HP program assessments and procedure maintenance and development and he was responsible to provide direction in technical projects and evaluations.

Participated in QA and regulatory audits.

Member: Radiation Data Management System (General Atomic) Oversight Committee, and the Station Operating Review Committee (SORC).

4/87 - 4/91 New Hampshire Yankee Health Physics Supervisor Dosimetry Responsible for the operation of the Internal and External Dosimetry laboratory employing 5 people (Technicians and professional staff).

Provided technical oversight and direction of the routine operation of each laboratory and many other projects including: development and use of a neutron spectroscopy system using He 3 and TEPC detectors, development of a Hot Particle Dose Rate Meter, and dose analysis of PASS operation against 10CFR50, GDC 19. Member: RDMS oversight committee.

8/86-4/87 New Hampshire Yankee Sr. Health Physicist HP Support Group Work involved providing technical direction, review and development for a variety of HP areas. These areas included the Digital Radiation Monitoring System, the Radiation Calibration Facility, Emergency Planning offsite dose assessment, HP training, instrument calibration, and contamination monitoring. Member, RDMS oversight committee.

1/85 - 8/86 Yankee Atomic Electric Company Titled Engineer HP Methods and Measurements Section Exhibit 1

Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP 4

Work involved a variety of activities relative to radiation measurement needs of operational and pre operational nuclear power plants and of the Environmental Laboratory.

This involvement included the development of a Panasonic Environmental Dosimetry Program, a Vinten Instruments Extremity Dosimetry Program, and a Portable Automated Extrapolation Chamber Measurement System.

Additional activities included assistance to the Radiation Dosimetry Section in dosimetry algorithm development, TLD badge design, in plant beta radiation field measurements (Steam Generators) and evaluation utilizing the Extrapolation chamber System, software design and development, plant process and effluent monitor calibrations, special plant audits in support of RETS and dosimetry areas, INVIVO and INVITRO program specifications, and an alpha analysis program for an air sampling program.

Involved in upgrade of the Laboratory NRC by product material license and served on the Laboratory Radiation Safety Committee.

10/81 - 1/85 Yankee Atomic Electric Company Radiation Dosimetry Section Work involved the support of dosimetry service provided to three nuclear power stations.

This work included primary and secondary calibrations of equipment and sources for measurements of beta and gamma personnel doses, operation of the in house dosimetry systems, and maintenance of the systems within the quality control program.

Duties also included special projects work within radiation measurements activities for the power stations.

8/79 - 10/81 Yankee Atomic Electric Company Radiation Protection Engineer Work included Health Physics and Emergency Planning Responsibilities in support of three nuclear power stations.

HP responsibilities involved assisting the plant HP departments in various disciplines ranging from administrative control of personnel exposures to technical considerations of radiation measurements.

Emergency Plan responsibilities ranged from the design and calibration of accident area and process radiation monitoring systems to the development of detailed technical and administrative Emergency Plans and Emergency Plan Implementation Procedures including dose assessment nomogram and computer program development.

Duties also included the development and administration of several detailed Emergency Exercise Scenarios which included radiological and operational sequences.

9/78 - 8/79 Yankee Atomic Electric Company Research Consultant Work involved a comprehensive analysis of the response of a state of the art personnel dosimetry system to different types of radiations and the effect of environmental stresses on it.

Exhibit 1

Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP 5

An extensive study of the beta response of TLD systems and subsequent correlation to average absorbed skin dose was also evaluated.

EDUCATION/ QUALIFICATIONS University of Lowell, Lowell, MA.

M.S. Radiological Sciences and Protection, January 1985.

Thesis: LiF TLD Beta Particle Dosimetry B.S. Radiological Health Physics, June 1978.

American Board of Health Physics Comprehensive Certification, October, 1985.

INDUSTRY COMMITTEES Advisory Committee on Nuclear Waste (ACNW) Working Group on NRC Decommissioning Guidance, June 2005, November 2006, June 2007, December 2007; Expert Panel Member.

Connecticut Yankee License Termination Plan ASLB Hearings, April 2003, Expert Witness Panel.

NBS Joint Planning Committee for Radiation Survey Instrument and Calibration, 1983.

ASTM Task Group E 10.04.16, How to Perform Field Measurements of Beta Spectra, 1985.

Voting Member: ANSI N13.1 Sampling And Monitoring Releases Of Airborne Radioactive Substances From The Stacks And Ducts Of Nuclear Facilities.

ANSI N13, Radiation Protection standards; Individual Technical Expert Member.

ANSI/HPS N13.2-2018, Performance Testing of Extremity Dosimeters, Working Group Chair PROFESSIONAL SOCIETIES National Health Physics Society New England Chapter Health Physics Society Exhibit 1

Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake Technical Support Document No.21-083 Revision 01 Prepared by:______________________________________________________________

William Cash, Sr. Health Physicist Reviewed by: _____________________________________________________________

Robert Leddy, Sr. Health Physicist/Project Manager Calculations Reviewed By:_______________________________________________

Robert Leddy, Sr. HP/Project Manager Approved by: _____________________________________________________________

Radiation Safety & Control Services, Inc 93 Ledge Road, Seabrook, NH 03874 1-800-525-8339 (603) 778-2871 (Outside USA) www.radsafety.com Date Completed: 10/28/2021 Ron Thurlow, Sr Director of Operations Exhibit 2 RSCS Radiation Safety & Control Services phone: 1-800-525-8339

fax: 603-778-6879 info@radsafety.com

www.radsa f et y.com

RSCS TSD 21-083 Rev. 01 Page 2 of 5 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake TSD Title Table of Contents

1.

Scope....................................................................................................................................................... 3

2.

Methods.................................................................................................................................................. 3

3.

Results..................................................................................................................................................... 4

4.

Conclusion............................................................................................................................................... 5

5.

Recommendations.................................................................................................................................. 5

6.

Attachments............................................................................................................................................ 5 Exhibit 2

RSCS TSD 21-083 Rev. 01 Page 3 of 5 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake TSD Title

1. Scope RSCS was asked to provide a review the Columbia Generation Station calculation which will be used to answer the Nuclear Regulatory Commissions question on the estimated value of Derived Air Concentration (DAC) for the two primary individuals exposed in the RWCU pipe cutting incident. Review included validation the formulae used and the calculational results.

Alternate calculation methods were also used to help validate and bound the results.

2. Methods Supplied supporting documents were reviewed and the calculation for workers # 1 and #2 were reviewed. A spreadsheet was created to assist in calculation verification (Spreadsheet will be provided with transmittal of this TSD). Additionally, DAC-Hours and % of Annual Limit on Intake (ALI), based on the estimated concentration breathed by workers #1 and #2, were assessed.

The spreadsheet analyses time integrated peak and average air concentrations the workers inhaled and provides data to help support vs the regulatory limits. Based on estimated time integrated concentrations and assumed worker breathing rate, exposure durations can be estimated.

The average DAC fraction breathed by Worker #1 in various time increments was estimated using the following formula:

(Equation 1) 08 0

.1

=

E T

BR Intake DAC Ave Where:

Intake = 4.34 uCi for worker #1 and 3.22 uCi for worker #2 DACAve=Co-60 DAC fraction for period T (1 min, 2, 3, 4, or 5 min)

Breathing Rate = 20000 cc/min T = Exp. Duration in mins - 1 min, 2 min, etc.

1 E-8 µCi/cc = Co-60 DAC from 10CFR20 The same assumptions used in the client (Calc. 21-02 Rev. 0) calculation were used in this TSD to validate the results and exposure models. RSCS wants to point out that the equation as it appears in reference 8 Table 7.2 is not derived in the reference and appears to contain two Time terms, both T and (1-exp-T)/. However, the relationship as appears in your calculation can be derived by integrating the expression for concentration as a function of time; C0e-T, so we see no issue with the calculation or your methodology. Once you calculate this Initial concentration value you could use it to estimate intakes for longer durations. However, the initial concentration Exhibit 2

RSCS TSD 21-083 Rev. 01 Page 4 of 5 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake TSD Title calculated using this method only accounts for removal rate by ventilation (i.e., the room removal rate is applied to the cloud), which for a puff event does not include the significant contributions to concentration changes from cloud diffusion/dispersion.

3. Results Calculations using the same methodology as used in Calc 21-02 Rev.0 confirm the accuracy of the calculated values in the calculation. Table 1 summarizes the results below.

Table 1: Comparison of Calc. 21-02 Rev 0 DAC Fractions vs RSCS Calculated Values Exp. Duration T, min Peak DAC Fraction Worker #1 Cal 21-02 Peak DAC Fraction Worker #1 RSCS Calc Peak DAC Fraction Worker #2 Cal 21-02 Peak DAC Fraction Worker #2 RSCS Calc 1

23,000 23,028 17,000 17,085 2

12,000 12,204 9,100 9,055 3

8,600 8,613 6,400 6,391 4

6,800 6,831 5,100 5,068 5

5,800 5,771 4,300 4,282 Table 2: Average DAC fraction Using Eq 1 Above Exp. Duration, min Avg. DAC Fraction for Exposure Duration, Worker #1 Avg. DAC Fraction for Exposure Duration, Worker #2 1

21,700 16,100 2

10,850 8,050 3

7,233 5,367 4

5,425 4,025 5

4,340 3,220 Using the average DAC fraction methodology reduces the calculated values for worker # 1 by approximately 6% at T= 1 min and up to 25% at T= 5 min and for worker #2 by approximately the same values, respectively. Using the peak values is obviously more conservative and may not be challenged by external reviewers.

Based upon the data presented here and on the recollection of the workers in the field as to exposure duration, this was a short duration elevated DAC fraction exposure. The actual intakes of the workers could have occurred in 1-2 minutes based on a puff release.

Exhibit 2

RSCS TSD 21-083 Rev. 01 Page 5 of 5 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake TSD Title

4. Conclusion Whether the time integrated or average DAC calculation methods are use, the initial concentration breathed by workers #1 and #2 was substantial. The fact that RP stopped the work and had the workers exit upon observation of the glove bag failure, prevented a potential for over exposure.

5. Recommendations

1. The figure showing the circumstances of the work site is not clear for positioning of the HEPA unit, the air sample, workers # 1 and 2, and the shield wall removal. A better depiction of the work site including an elevation view would be helpful to the external reader.

2. We would suggest not citing equation in Table 7.2 of Maiellos book since it doesnt seem right (it includes two Time terms in the equation). Equation 2 in Calc 21-02 can be derived by replacing the Conc x Time term in Eq 1. with Conc0 x e-T x dT and integrating from time T=0 to Time T to account for the change in concentration as a function of time.

3. In case you have not reviewed HPPOS-232: Enforcement Guidance Concerning Substantial Potential for Over exposure or Releases, the hyperlink is provided for your use. https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos232.html

6. Attachments None Exhibit 2

SampleID SampleDateTim e

PlantCo ndShort Name Elevati on Location Purpose Sample Type RWP Number Air Sampler -

Serial #

Air Sampler

- Cal Due Date Sample Start Date Sample Start Time Sample Flow -

On Sample Stop Date Sample Stop Time Sample Flow -

Off Beta/Gamma

- Instr Type Beta/Gamma

- Instr ID Beta/Gamma

- Instr Eff Beta/Gamma -

Bkgd Counts (CPM)

Beta/Gamma -

Counts (counts)

Total Sampler Run Time Average Flow Sample Volume Beta/Gamma -

Count DAC Fraction Beta/Gamma LLD (DAC-Hr)

Alpha Count Required Iso-Count Required Alpha/Beta-Gamma Total DAC Alpha 1st Count -

Instr Type Alpha 1st Count -

Instr ID Alpha 1st Count -

Instr Eff Alpha 1st Count -

Bkgd Compe nsated Alpha 1st Count -

Gross Counts Alpha -

Sample Count Time (min)

Alpha 1st Count -

DAC Fraction Alpha LLD (DAC-Hr)

Min Volume Alpha 2nd Count -

Instr Type Alpha 2nd Count -

Instr ID Alpha 2nd Count -

Instr Eff Alpha 2nd Count -

Bkgd Alpha 2nd Count -

Uncom pensat ed Gross Counts Alpha 2nd Count -

DAC Fractio n

Alpha 3rd Count -

Instr Type

Alpha 3rd Count -

Instr ID Alpha 3rd Count -

Instr Eff Alpha 3rd Count -

Bkgd Alpha 3rd Count -

Uncom pensat ed Gross Counts Alpha 3rd Count -

DAC Fractio n

Chemist ry Sample ID#

Co-60 Co-58 Zn-65 Mn-54 Gamm a Spec DAC Iodine DAC Fractio n

Noble Gas Air Sample Numbe r

Units:

None Units: None Units: None Units:

None Units:

None Units: None Units:

None Units:

CFM Units:

None Units:

CFM Units: None Units: None Units: None Units: CPM Units: Counts Units:

minutes Units:

CFM Units:

CF Units: % DAC Units: DAC Units:

None Units:

None Units: N/A Units:

DAC Units:

None Units:

CPM Units:

None Units:

Counts Units: MIN Units: DAC Units:

DAC Units:

CFM Units:

None Units:

CPM Units:

Counts Units:

DAC Units:

None Units:

CPM Units:

Counts Units:

DAC Units:

None Units:

uCi/cc Units:

DAC Units:

None 1097086 5/29/2021 3:34 Mode 5 Rx 548 RWCU HX ROOM Lapping Cut #3 for Weld G/A 30004732 6069 11/12/2021 5/28/2021 2120 1.5 5/28/2021 2305 1.5 Model-2 F062 0.1 200 200000 105 1.5 157.5 20.3 0.01 Required Required 0.01 33.4 iMatic iMatic 0.14 0.5 No 14 10 0.26 0.26 138.24 iMatic iMatic 0.14 0.6 9 < 0.30 21-1180 3.30E-07 3.32E-08 4.65E-09 3.37E-09 33.1 Exhibit B

DIC 1517 VSDS Standard Map Survey Report Survey VSDS_Prod-M-20210529-13 General Information RB 548 RWCU HX Rm Post Post Decon

Title:

Survey Date/Time: 5/29/2021 11:28 Survey Type: Post-Decontamination Counted By: Timothy Campbell 5/29/2021 11:30 021459042701 Emily McKaig Lead Surveyor:

Work Order/Task #:

RWP #: 30004713 Rx % Pwr: 0%

Approved by: Brenda Nordhaus, 5/30/2021 Status:

Dose Rate (DR) Object Prefixes/Suffixes HS = Hot Spot Dose Rates with Prefixes:

Dose Rates with No Prefixes:

Default Prefixes:

Default Suffixes:

"n" = Neutron "b" = Beta "c" = Corrected Postings Legend CA=Contaminated Area LHRA=Locked High Radiation Area Instruments Used Model Serial #

Instrument Instrument 1 L-177 F098 2 451B RV-09 3 Model 3 A022 Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 1 of 5 HPT Dose (mrem): 34 Exhibit D I

I I

I i

11 I

I

VSDS Standard Map Survey Report DIC 1517 Date/Time: 5/29/2021 11:28 Survey #: VSDS_Prod-M-20210529-13 RB 548' RWCU HX Room Comments:

Post-Decontamination Type:

RWP #: 30004713 Reactor Power = 0%

Symbol Legend (for example only)

Dose rates in mrem/hr & Smears <1k dpm/100 cm2 unless noted Air Samples & Wipes Smears Summary of Highest Readings (All available values may not be listed)

2) 1800000 dpm/100cm2

2) <DL dpm/100cm2 A/S 1) <0.1 DAC Particulate Status: Approved by: Brenda Nordhaus, 5/30/2021 Lead Surveyor: Emily McKaig Location Code: RB Bldg/Area Name: 548 Location

Description:

RB 548 RWCU HX Room Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 2 of 5 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 34 Exhibit D LHRA

~

Area Posted: GA ontact fl'ea!illng em Reai:ling eperal~a '

~

Posfing Qrip,B*ag

.RM

~

lro1pe RCC Scaffolt:I Declc

~

S,ea ffo.ld Deck over Lead' Hut

@)

8

~

A L1 ~~

Dain Structcral s1:1pports

VSDS Standard Map Survey Report DIC 1517 Data Point Details Notes Type Inst.

Value Units Position Survey #: VSDS_Prod-M-20210529-13 Map: RB\\RB-548-RWCU-HX-Room Inside Cut #3 1

Smear N/A 200000 dpm/100cm2 N/A

<DL dpm/100cm2 Inside Cut #3 2

Smear N/A 1800000 dpm/100cm2 N/A

<DL dpm/100cm2 Top scaffold deck 3

Smear N/A 2000 dpm/100cm2 On lead on cut #3 4

Smear N/A 3000 dpm/100cm2 Top scaffold deck 5

Smear N/A 3000 dpm/100cm2 Top scaffold deck 6

Smear N/A 15000 dpm/100cm2 Middle scaffold deck 7

Smear N/A 3000 dpm/100cm2 Middle scaffold deck 8

Smear N/A 1000 dpm/100cm2 Middle scaffold deck 9

Smear N/A 4000 dpm/100cm2 Lower scaffold deck 10 Smear N/A 1000 dpm/100cm2 Lower scaffold deck 11 Smear N/A 1000 dpm/100cm2 Lower scaffold deck 12 Smear N/A

<1000 dpm/100cm2 Ladder 13 Smear N/A

<1000 dpm/100cm2 Ladder 14 Smear N/A

<1000 dpm/100cm2 Ladder 15 Smear N/A

<1000 dpm/100cm2 Underneath scaffolds 16 Smear N/A 5000 dpm/100cm2 Underneath scaffolds 17 Smear N/A 4000 dpm/100cm2 Underneath scaffolds 18 Smear N/A 4000 dpm/100cm2 On floor 19 Smear N/A 10000 dpm/100cm2 On floor 20 Smear N/A 10000 dpm/100cm2 On floor 21 Smear N/A 4000 dpm/100cm2 On floor 22 Smear N/A 4000 dpm/100cm2 On floor 23 Smear N/A 4000 dpm/100cm2 On floor 24 Smear N/A 5000 dpm/100cm2 On floor 25 Smear N/A 10000 dpm/100cm2 On floor 26 Smear N/A 2000 dpm/100cm2 On floor 27 Smear N/A 3000 dpm/100cm2 On floor 28 Smear N/A 4000 dpm/100cm2 On floor 29 Smear N/A 6000 dpm/100cm2 On floor 30 Smear N/A 1000 dpm/100cm2 On floor 31 Smear N/A 1000 dpm/100cm2 On floor 32 Smear N/A 1000 dpm/100cm2 On floor drain 33 Smear N/A 3000 dpm/100cm2 On floor 34 Smear N/A 4000 dpm/100cm2 On floor 35 Smear N/A 4000 dpm/100cm2 On floor 36 Smear N/A 4000 dpm/100cm2 On floor 37 Smear N/A 5000 dpm/100cm2 On floor 38 Smear N/A 3000 dpm/100cm2 On floor 39 Smear N/A 5000 dpm/100cm2 On floor 40 Smear N/A 3000 dpm/100cm2 On floor 41 Smear N/A 5000 dpm/100cm2 On scaffold for cut #4 42 Smear N/A

<1000 dpm/100cm2 On scaffold for cut #4 43 Smear N/A

<1000 dpm/100cm2 On RCC scaffold 44 Smear N/A 5000 dpm/100cm2 On RCC scaffold 45 Smear N/A 2000 dpm/100cm2 On scaffold over lead hut 46 Smear N/A 2000 dpm/100cm2 On scaffold over lead hut 47 Smear N/A 1000 dpm/100cm2 Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 3 of 5 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 34 Exhibit D

VSDS Standard Map Survey Report DIC 1517 Data Point Details Notes Type Inst.

Value Units Position Survey #: VSDS_Prod-M-20210529-13 Map: RB\\RB-548-RWCU-HX-Room Air Sample Nuclear IQ # 1097129 General Area A/S 1

Air Sample

<0.1 DAC Particulate Gooseneck #42833 Cal Due 11/12/21 Posting LHRA CA Posted at Gate Posting LHRA CA Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 4 of 5 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 34 Exhibit D

DIC 1517 VSDS Standard Map Survey Report Comments:

Air Sample Nuclear IQ # 1097129 Gooseneck #42833 Cal Due 11/12/21 Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 5 of 5 HPT Dose (mrem): 34 Exhibit D

DIC 1517 VSDS Standard Map Survey Report Survey VSDS_Prod-M-20210513-33 General Information RB 548 Cut and remove RWCU Piping in RWCU HX RM

Title:

Survey Date/Time: 5/13/2021 14:20 Survey Type: Job Coverage Counted By: Timothy Campbell 5/13/2021 15:55 02145904-04-01 Timothy Campbell Lead Surveyor:

Work Order/Task #:

RWP #: 30004697 Rx % Pwr: 0%

Approved by: Brenda Nordhaus, 5/19/2021 Status:

Beta Radiation Detected Dose Rate (DR) Object Prefixes/Suffixes

= Contact

+ = 30cm Gen Area HS = Hot Spot Dose Rates with Prefixes:

Dose Rates with No Prefixes:

Default Prefixes:

Default Suffixes:

"n" = Neutron "b" = Beta "c" = Corrected Postings Legend Alpha 2=Alpha Level 2 CA=Contaminated Area HCA=High Contamination Area LHRA=Locked High Radiation Area RA=Radiation Area Instruments Used Model Serial #

Instrument Instrument 1 451B RV-11 2 Telepole 2 T-11 3 RAS HP-EQ-C001561 4 RAS HP-EQ-C0042583 5 RAS HP-EQ-C0042869 6 Lud 177 F098 7 Lud 3 A016 Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 1 of 4 HPT Dose (mrem): 336 Exhibit E I

I I

I

VSDS Standard Map Survey Report DIC 1517 Date/Time: 5/13/2021 14:20 Survey #: VSDS_Prod-M-20210513-33 RB 548' RWCU HX Room Lud 2: 0.4 BKGD; 2 Min count; 14.4% Eff. ; DL = 5.7 dpm Air Samples. #1: 1095575; #2:1095602; #3:1095688; #4:

1095689; #5: 1095690 DAC values for Beta/Gamma Alpha disposition being determined by Rad Services per Jeremy Soma.

Comments:

Job Coverage Type:

RWP #: 30004697 Reactor Power = 0%

Beta Radiation Detected Symbol Legend (for example only)

Dose rates in mrem/hr & Smears <1k dpm/100 cm2 unless noted Air Samples & Wipes Smears Summary of Highest Readings (All available values may not be listed)

6) 2000K dpm/100cm2

2) 4800 mrad/hr/100 cm2

7) <DL dpm/100cm2 A/S 1).05 DAC Particulate Status: Approved by: Brenda Nordhaus, 5/19/2021 Lead Surveyor: Timothy Campbell Location Code: RB Bldg/Area Name: 548 Location

Description:

RB 548 RWCU HX Room Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 2 of 4 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 336 Exhibit E Cut # llad watei;.drain Smears 5, from cuts-and worter,:s were eyacuat~ after Floor Posted:

6, 71aken second cut The f11!}El ~ as

'Fi_j,,

0[1 5/14/21 not rower~, Workers 1e1t

@1ttoo the jqb tllLdraln]g,g \\'(!IS PDPL-F IT-SR,9.,J 1JL~j lrm j Cutst~&.Ei i Ion = close rates w ith ion ctiaml:ler. A ll ottier doserate-s w ith telepole cut# !lad a* si9.nmcant amoWlt of w:ater i:l~aTn lhtO'the metii1

-catch basin tub (ha-If run) Sortie-w..ater could nof be ooniained ~t the secMd cul. Water s,p !led tpc floor treJn.w. Wq.r:fter-s'eva.cuated dUnng-drairiTng. Tyt ek spror1S-wom on wor,kers alter<lfzjnin,g, ontact fl'ea!illng em Reai:ling eperal~a '

~

Posfing Qrip_B*ag

.RM ~

lro1pe 45D loll I

!SOPj:

I§!

, ___.J I

! p:.A I I

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I PZ:lH IT--$P.i9il i

PSP,-FIT.,':;P.i9.l'f j 520 Ion !

UJWA's were establlstled ror machiaists to obse,;,,,e, cuts

@uFizl 4V D mra clltu j 0W

VSDS Standard Map Survey Report DIC 1517 Data Point Details Notes Type Inst.

Value Units Position Survey #: VSDS_Prod-M-20210513-33 Map: RB\\RB-548-RWCU-HX-Room Pipe DR

N/A

5200 mrem/hr N/A

+ 1400 mrem/hr N/A 900 mrem/hr DR

N/A 220 mrem/hr Pipe DR

N/A

800 mrem/hr N/A

+ 380 mrem/hr DR

N/A 1000 mrem/hr DR

N/A 500 mrem/hr DR

N/A 750 mrem/hr DR

N/A 450 mrem/hr Pipe DR

N/A

5600 mrem/hr N/A

+ 1300 mrem/hr DR

N/A 230 mrem/hr DR

N/A 760 mrem/hr DR

N/A 220 Ion mrem/hr DR

N/A 130 Ion mrem/hr DR

N/A 3 mrem/hr DR

N/A 1100 mrem/hr DR

N/A 640 mrem/hr DR

N/A 480 mrem/hr DR

N/A 450 mrem/hr DR

N/A 400 mrad/hr DR

N/A 5600 mrad/hr DR

N/A 275 Ion mrem/hr DR

N/A 520 Ion mrem/hr DR

N/A 450 Ion mrem/hr DR

N/A 425 Ion mrem/hr WET Inside Pipe 1

Smear 1

120 mrad/hr/100 cm2 Wet Inside Pipe 2

Smear 1

4800 mrad/hr/100 cm2 Scaffod 3

Smear 6

40K dpm/100cm2 Wet Floor Post spill 4

Smear 6

250K dpm/100cm2 Inside cut Drain Line 5

Smear 6

800K dpm/100cm2 7

<DL dpm/100cm2 Inside Cut #3 Pipe 6

Smear 6

2000K dpm/100cm2 7

<DL dpm/100cm2 Inside Cut #4 Pipe 7

Smear 6

1800K dpm/100cm2 7

<DL dpm/100cm2 1

Air Sample

.05 DAC Particulate 2

Air Sample

.04 DAC Particulate 3

Air Sample

.01 DAC Particulate 4

Air Sample

.01 DAC Particulate 5

Air Sample

<0.01 DAC Particulate Text All readings taken at the plane of the cuts Text Floor Posted:

Text Ion = dose rates with ion chamber.

All other doserates with telepole Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 3 of 4 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 336 Exhibit E

VSDS Standard Map Survey Report DIC 1517 Data Point Details Notes Type Inst.

Value Units Position Survey #: VSDS_Prod-M-20210513-33 Map: RB\\RB-548-RWCU-HX-Room Posting LHRA Posting HCA Posting CA Posting RA Posting Alpha 2 Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 4 of 4 Image File: RB\\RB-548-RWCU-HX-Room HPT Dose (mrem): 336 Exhibit E

March 09, 2021 Mr. Mike Nolan Energy Northwest none Richland, Washington 99352 Re: Part 61 Analysis Work Order: 533227

Dear Mr. Nolan:

GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the sample(s) we received on January 26, 2021. This original data report has been prepared and reviewed in accordance with GELs standard operating procedures.

Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards, with any exceptions noted. The results reported relate only to the items tested and to the sample as received by the laboratory. These results may not be reproduced except as full reports without approval by the laboratory.

Copies of GELs accreditations and certifications can be found on our website at www.gel.com.

Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs on time every time. We trust that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate to call me at (843) 556-8171, ext. 4708.

Sincerely, PM_SIGN_HERE Taylor Cannon Project Manager Purchase Order: 338920 Chain of Custody: 21-01 Enclosures Kerry OBarr for Exhibit F

~

I Laboratories LLC a member of The GEL Group INC problem solved PO Box30712 Cha~eslon SC29417 2040 Sa~age Road Cl1arteston SC 29407 P 843 556.8171 F 84~.766.11i8 gel. com

Table of Contents General Narrative...............................................................................3 Chain of Custody and Supporting Documentation.........................5 Laboratory Certifications................................................................10 Radiological Analysis.......................................................................12 Case Narrative..........................................................................13 Sample Data Summary............................................................25 Quality Control Summary.......................................................29 Exhibit F

General Narrative Page 1 of 38 SDG: 533227 Exhibit F

General Narrative for Energy Northwest Part 61 Analysis SDG: 533227 March 09, 2021 Laboratory Identification:

GEL Laboratories LLC 2040 Savage Road Charleston, South Carolina 29407 (843) 556-8171 Summary Sample receipt The sample(s) arrived at GEL Laboratories, LLC, Charleston, South Carolina on January 26, 2021, for analysis.

Chain of Custody form did not contain a relinquished signature. All sample containers arrived without any visible signs of tampering or breakage. There are no additional comments concerning sample receipt.

Sample Identification The laboratory received the following sample:

Laboratory Identification Sample Description 533227001 RCU (RWCU Resins) 20-2431/20-026-HP Case Narrative Sample analyses were conducted using methodology as outlined in GEL Laboratories, LLC (GEL) Standard Operating Procedures. Any technical or administrative problems during analysis, data review, and reduction are contained in the analytical case narratives in the enclosed data package.

Data Package The enclosed data package contains the following sections: General Narrative, Chain of Custody and Supporting Documentation, and data from the following fractions: Radiochemistry. This package, to the best of my knowledge, is in compliance with technical and administrative requirements.

GEL Laboratories, LLC appreciates this opportunity to provide you with analytical results and trusts that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate in contacting me at (843) 556-8171.

PM_SIGN_HERE Taylor Cannon Project Manager Kerry OBarr for Page 2 of 38 SDG: 533227 Exhibit F I r

Chain of Custody and Supporting Documentation Page 3 of 38 SDG: 533227 Exhibit F

Page 4 of 38 SDG: 533227 Exhibit F Page: ___ ] ___ _

I Project#:

GEL Chain of Custody and Analytical Request GEL Contract#: 338920 COC Number<'>:_

21-01 GEL Work Order Number:

GEL Quote Number:

- See www.gel.com for GEL's Sample Acceptance SOP**

633;)?-7 GEL Laboratories, I.LC 2040 Savage Road Charleston, SC 29407 Phone: (843) 556-8171 Fax: (8431766-1178 Client Name: Energy Northwest Phone#: 509-372-5305 Sample Analysis Requested <5

> (Fill in the number of containers for each test)

Project/Site Name: Columbia Generating Station r..-mail :-;cmcnutt@encrg,-nor1.hwcs.t..com Address: P.O. Box 968, Mail Stop PE-12 Richland WA 99352 Collected by: Various Send Results To: Steve McNutt Sample ID

"' For composites - indicate start and stop date/time

Date Collected "Time Co!!cclcd QC Field (mm-dd-yy)

(Military)

Code O> Filtered (JJ (hhmm)

RCU (RWCU Resins) 20-2431 / 20-026-HP 12/1/2020 8:19 N

I Sample Matrix("f1 ss

§ ~ -¥i

E -!~

g E *;;

.C

~ C

{I')

<I'/ s

=

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X

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c XIXIXIXIXIXIX

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Comments g,~,]

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Note: extra sample is c:;

~

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a ce

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required for sample V1 E

-g_

specific QC

.0 u

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X xtt, X TAT Requested: Normal:

X.

Rush: _

Specify: __

__ (Subjecl lo Surcharge) Email Results:

Yes I

No Circle Deliverable: C of A I QC Summary / Level I I Level 2

/ Level 3 / Level 4 Remarks: Are there any known hazards applicable to these samples? ljso, please list the hazards All samples are radioactive. Contact dose rates are as follows:

Sample Collection Time Zone RWCU Sample - 3.5 mRemlhr on contact. Please ensure extended count times are used for hard to measures(!-! 29, C-14, H-3, Tc-99). Please send drum, shields and Eastcm Pacific I;;

Central Other voam back to Energy Northwest.

Mountain Chain of Custody Signatures Rclinquished l3y (Signed)

Date Time Ii /kroo-* f/111 /-tf-z/ 1~ l~~o 4~

Received by (signed)

Date Time HB-l.J GEL PM:

Method of Shipment:

A,/ II A: *.,,,n#-

Ai*b11l #:

I.) Chain of Custody Number= Client Determined 2.) QC Codes: N ""Normal Sample, TB= Trip Blank, FD= Field Duplicate, EB= Equipment Blank, MS= Matrix Spike Sample, MSD = ~fatrix Spike Duplicate Sample. G = Grab, C = Composite 3.) Field Filtered: For liquid matrices, indicate with a~ Y

for yes the sample was field ftltercd or~ N ~'?~I:~arnple was not field filtered Sample Shipping and Delivery Details Date Shipped:

4.) Matrix Codes: DW""Drinking Water, GW=-Groundwater. SW=-Surface Water. WW=Waste Water. \\V=Water. ML:c=Misc Liquid, SO,,,,Soil, Sll=-Serliment~ SL=S!udge, SSc:::Solid Waste. Q.soQil, F=-Fiher, P""'Wipe, U=Urine, F=Fecal. N=cNasnl 5.) Sample Analysis Requested: Anal)1ical method requested (i.e. 8260B, 60J0B/7470A) and number or containers provided for each (i.e. 82608 - 3, 60/0/J.7470A - 1) 6.) Preser\\'alive Type: HA-= Hydrochloric Acid, NI= Nitric Acid, SH= Sodium Hydroxide, SA= Sulfuric Acid. AA= Ascorbic Acid, HX = Hexane, ST""' ~odium Thiosulfate, Ifno preservative is added= !C!l.ve field blank WHITE= LABORATORY YELLOW= FILE PINK= CLIENT For Lab /ieceiving Use Only Custody Seal Intact?

YI:~\\'

NO

Page 5 of 38 SDG: 533227 Exhibit F Page _1_ of_1_

Emergency Response Information Shipment# --'2"'"'1~-0~1'----

Radioactive Material, Excepted Package - Limited Quantity of Material OR Instruments or Articles Proper Shipping Names {Check One):

p Radioactive Material, Excepted Package - Limited Quantity of Material, 7, UN2910 Radioactive Material, Excepted Package - Instruments or Articles, 7, UN2911

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C1J.:,:.ntity of rr...:i.1.:-ni.:i! prc.::.ont:: kr.t{ r~J:::li.:?..':i n :"i:t::.:!.rd [~ n:.b::::;cd h-::,;;;i p.:i;c.~u.gQ dudr:9 ;Jccid;;,nt Semo r.::.:HiJctvo r:i.i::.rbl:. c;:innc-t I::<. :fo'2jJ:7;o,-:::I b-.,*,:cii1rr1::-nh* ::t\\1::.:ik1b!c: in!:-tru:non~.

P*;:,:,d:z::lQ;.- do r-.1ot hi:r,.*.-:* ~!.t~1.C*ICl',.CTrVt: L II, C~: ill l,:?l::~;;,1;;~ Sorn.-;. m::i.v h.:rvo Sf,J1PTY 1.:tb:.,i:. or mJ~1 h;,r;;:, :ho *,t-.fcrd*... ;::;::-:lic,:i.ctf-~ - in !ha p;.:,C.::..;~G 1T,;-,..r:';.;i:-.;i.

~f ~m,* r.Jcfic~.,=!ivc cc ;d.:J:nin::i::bn o::cuc:;., i1 *.r..iil 00.:;.;::rorr.,;:.lv la"...- iv,n:il.

FIR= C,A bXPL6t.-10N Sc-:-nei *=*i th-:!:. m;::~*ri lz. ITT;:J\\' bum.* b!.:I mc-:::t* :lo ;,.::,t i8ni~;., ra,::.dil_.,.ft

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i:::lic,:u:thrii:v dog_c-. n.c::: ch.:ir~--:.: fi:::.r;:i,m~blfr:y or,:,th,.;; i:ror:-..:;1.io.::; cf m;;,1.::-rbb.

CALL

,lpplng FaPer ArSL

?rlacttes.1ar reS,Cl.l,g, IL'ie:savlng, nrs.~ aid. and oornr*ol,,1 lire i!lld a1he r 11az2,ds are

i,gt,er,nan !Ile D11or~y ror rre*l!!sllf1ng rac11a:,-0n ewl.s.

~:::di.:1::.Jon,liJJL---:crit~* rnur.1 I::.,~ r:c~ifix,::::.:.i.*:ci:lr,J,nt c:.::,n:::litbn~..J c1:i b u.:;u;:i!f,* :;;;:,:;p:;r.:~il:~~

f:;;,r wdbloJ:Ji~l d;;~=1:::ion:;;.

l;;d.::ii;.1 ;;i::l! or io;:ih ;::nc..-J irr.r..oc:;:ttc;f~* for ::.I k:,.:i:::,1 2:, :::, t:*:i m;;-,t.;;s:; iEO ::*=* 1 £.:,.:~o(l in :7JII 6r.,z-,:::bn=**

S~:,y up,.-in:::1.

tr..c,;1:,,.n*;.o*u.... 1hcrizc1C ;:ii~r.;,,:,nn;;il :::.:6..,-.:rv.

Dcil~in.:1.I"id k,,:,f.:it;-.d ur.b}ur~d oon:*=*n~ or ~~:..1iprr:;.,nt ::u :;p"ctcd t:, ~ c-=,n1,:1.rnin.x.~:t: -:lokr:-*

d;:G'..:or:'::lrnin:i1icn ::mC ci;:anup t.rnt!l in::.trucli::;,n/;; :irw r.:,:c.!\\*.:ici fn:,r::1 !'1<J.ci::Jlc-r,.Au-:_-t--r::,riN.

PRdt~ClrJ= t..;L.blrtiNG

c

::ifr *..-c on:,;::.~ura ;;.;;.Ji~ccnt:,:kicd '::,r.;;,~Lhin1':J.:i::o::iri:itI.J!. t:SCEJ1.:,.:ir:d ~-1ru*=L'J*~i ::ir.:-,figh1cr::*

1::xc,toct:v~* ch:1:tdn1;1 wii! pn:ri.ld,:.i ::do-_qu::.1,~;.-. pro1,m:;tJc-n.

tUII Larg;:Sp,JI Fire Ct1n::.k:for inifi.::t.! dci~vni>vln:1,;;,\\i*.:10::unt;-=1-:-1 for :::I ~.,._~!:I 1,:0 mol;:,r:; r:;;:m loc~'.1.

ri;,

: -.:in.co c,t r:dio.:icfr~* I<* rn::r;;;irbh:, *.:,,*:II n::it *:h.:.in:;;;;,- cff,;:c:}v.;.0;-;,:::; cJ.~ir;:a co:-.::rol ti:-,d,ni=tuc.c..

r\\'1Cl\\f0 c.-:,nL:!,b;;ir.:. frc,rn iiri7i :::m,~ if \\'C*l.J c;:.n,:k, r~ ',llit!-:,:,:..rl ri!:k smau f=I~'.; :"'l-=,1 )'7.lC\\,l ;:.i" d::irr~:i;;;;.::I p:.';;*;:k"::go:.: :nc<,!O urd.'.lrr+::.;itX!.::,':ick:igc::: cul ::*l Hrw ;:-:,f',;;<.

Dr~* c.ht*mk~L CC2. v,;::ilo; ::pr~Y~ c; rr.r9i..:k1.: f-=.:ern.

Large Flras.

vv~.::il.;:<r :-::ir~v. ioi:i Hk,cdinA.;J.r;:"'lC'Ji"';J:::-t.

SPILL OA LEAK Do r-t:,11c1Jch d:.rr.a9:,:d p;;;-:k":lgo::, c; !:-J:*';\\lv:,:::1 mw~-u>rh:il.

LlQTJlid$plll5 C:.1~r,;;n *~vill-7 ::.::.rd. *:.l:ir;h, c,r c thG: non* o::,m'::,:.;::;';11:;lo ::i:.:,:;,::,r;:..::,nt rr... :,.tw:i~.l.

C:cr,r::ir J:JCMl'dcr :p1!!-J...-ill-: p!.::,:.ti= :;hGG-1 er t;~ to mirJ:nU:-;;, ~:i:roiJdir;i.

~.11odic..-:il pro=-1Qrr,:; !eke. p6=,:-it~* c:,,1c;; r;:i:::lia(c.;;}=.:1J ccn::c;rr::;.

1:...1:.oii rir:it.:i.'ci tnz,:;;1monl ~a=crdinQ -:o tho n.:i~ r...i cf. ~hv Jr,iur11'.

~~Ii

~~i~~~~1~~;~:I:~~~f ~~~:\\:i,~~\\*hii~~ro~ =re*=~.

~ ~: :: ~~.ci.~~;~.~*~ilr:, :.w::i!::.;:m,;:.::,, imrn.odi.:ttDt:,* 7lu:h ~-:'d:-: cir ;:.\\*G-:;*1,;i~h ru-r;.n;n8'1i;:t~;;.r for lr1,iurod i:Kirn=*7'"1t "l,,,h,::, cont::=*~:;:d :'~l-o.::i~;-... :.:1 rn.:.t.:;.r!-::.:1 mew b-:; J r.iii:C'=" c-.:*rr1,111in::.t.'-.ion c,r,:,blorri :*;:.

cc,nt:::i=:z,d i:..;.r::c1~:., oc1..1i:,r:,c.r:,.:i.,d f~ciH1ic:-;:;.

'.:;nctJrc.. lM:.:.1 moCicwl :;.;:.r:.-::*rinttl ~r;;. ;:tN::lr'C' of Li..;.;;. rn:.tcrinl(:.) irr,.**:,t.. *1:;;:d, ::,:rd t.:.:.ko pr,;;c:.:iut}::,;1::- lc prc~r.ict lho;n.::..;;:h-*c::..

CALL STATION 24-HOUR EMERGENCY RESPONSE NUMBER FOR EMERGENCY ASSISTANCE

1.

Emergency Response Contact (Title): CHEMTREC - 206168)

2.

Emergency Phone Number: (800) 424-9300 Drivers signature:

Date:

Page 6 of 38 SDG: 533227 Exhibit F

5. SHIPPER - NAME AND FACILITY SHIPMENT ID NUMBER

7. RMSR SHIPPING PAPER PAGE 1 OF

_ 1_PAGES

8. MANIFEST NUMBER Energy Northwest RADIOACTIVE MATERIAL Columbia Generating Station RMSR MATERIAL DESCRIP.

PAGES (Use lhi-s numbef' on a; conrinuation PO Box 968, North Power Plant Loop COLLECTOR NOT APPLICABLE PAGES page,.)

SHIPPING RECORD Richland, WA 99352-0968 PROCESSOR ADDITIONAL INFORMATION

_ 1_PAGES 21-01 SHIPPING PAPER USER PERMIT NUMBER I

SHIPMENT NUMBER X

GENERATOR TYPE

8. CONSIGNEE - Name and Facility Address CONTACT

1. EMERGENCY TELEPHONE NUMBER (Include Area Code) 362 21-01 NP GEL Labs Taylor Cannon 800-424-9300 2040 Savage RD CONTACT TELEPHONE NUMBER Charleston, SC 29407

~i~}a~f.!BER SteveMcNutt (509) 372-5305 ORGANIZATION Chemtrac (# 208168)

6. CARRIER - Name and Address EPA 1.D. NUMBER SIGNATURE

- Authonzed C0n$ignee acknowledging malarial recefp(

DATE FEDERAL EXPRESS NA NOT APPLICABLE NOT APPLICABLE

2. l~IS AN EXCLUSIVE USE SHIPMENT?

3. TOTAi. NUMBER OF l 3670 HACKS CROSS RD. BLDG., G 2 YES PACKAGES IDENTIFIED 1

MEMPHIS, TN 38125 SHIPPING OA TE NO ON THIS MANIFEST 1/1312021

====>

This is lo certify th.I:!! the herein named tna:.erlals are property dassificd, de.scribed. packaged, marked, and labcled and

4. DOES EPA REGULATED td YES EPA MANIFEST NUMBER CONTACT J,illf.';\\\\',\\j't;~rBER are in proper condition tor transportation occ:orcling to lho applicable rcgukltlons of lho Department of Tran$p0ffation MATERIAL REQUIRING A NA CUSTOMER SERVICE 1-BOD-463-3339 MANIFEST ACCOMPANY NO THIS SHIPMENT?

SIGNATURE* Authorized earner ackncwledgng maienru. receipt DATE A_!JTHORIZEosIGNATURE

L.-,-

lmLE Rw -r 5 IOATE If 'Ye-.s' provide manifest NUTiber====>

)fo;e_ f)l<t-)..._(3/4-~/;

r-/(3/2.i

11. U.S. DEPARTMENT OF TRANSPORTATION DESCRIPTION

12.

13.

14.

15.

16.

17.

18. TOTAL WEIGHT

19. IDENTIFICATION (Include prcpor srupping name, hazard clas:i, UN ID number, OOTLAIJEL TRANSPORT PHYSICAL ANO INDIVIDUAL TOTAL PACKAGE LSNSCO OR VOLUME NUMBER OF and any other informaUon RADIOACTIVE fNDEX CHEMICAL FORM RADIONUCLIDES ACTIVITY IN SI UNITS CLASS (Use appropriate unils)

PACKAGE UN2910,Radioactive Material, excepted package-- limited quantity of NA NA Solid Co-60 Mn-54 Zn-65 Ag*110m Co-58 3.45E-01 MBq NA 57.6 kg material, 7 - Part 61 RWCU Sample, 1 Metal Drum Metal Oxides (9.31E-03 mCi)

(127.0 lbs) 11-178-055 0294 M 02' 0. "

5 ul Pl?- JO 33130fJ6 2040 SAVAGER[:

@]

FOR CONSIGNEE USE ONLY CHARl ESTDN. SC 294 0 7-4731-40 458-6009Fl f IP: 20

?U:Sfl. !Uti y 1?47GU"(!B6BO ISIP (06-2014)

Page 7 of 38 SDG: 533227 Exhibit F

~

/ Labocatories LLG T('1 SAMPLE RECEIPT & REVIEW FOR.M Client:

ti :;"' EN*~)() SDG/AR/COC/WorkOrrlcr:

.:::::._ '2.. ~ ';)...,::l.. /*

- -A/

Dute Received:

/ /

2 tf/,,.2 * /

Received Ily:

Carrier and Tracking Number Suspected Hazonl lufomiatlon A)Shioocd,s

DOT H=dous?

B) Di<l the client cL!siguati:: the samples rul! to bl!

received as radioactive?

C) Did the RSO cl,ssify the sJ111ples,s r:ulio:mive?

D) Did the client do?Sil!na<e somnlcs = h:u:a,dous'/

E) Did the RSO identifv nnssible hnzaids'/

Sample Receipt Critcrlu Shipping conl3iners received intact and l scaled?

2 Chain of custody document; included will1 shipmeot?

3 Samples requiring cold preservation witl1in (0 5 6 deg. C)?*

4 Daily check perfonred and pa5scd on IR lempc,rature gun?

5 Sample containers intact and scaled'!

6 Samplc.s requiring cherrticai preservation at proper pH?

7 Do any !>:!mplcs require Volatile Analysis?

8 Samples received within holding lime?

9 Sample !D's on COC match ID'; on bo1tles?

10 Date & tim! on COC match date & time on bottles?

11 Number of Ctlnt:tloer; received match number indicated on COC?

v V

fl l,/

/

/'

I/

/

... -- 7

.I CU'dc Appli01btc:

,.,,.,, FedEx Grnund UPS Field Services Courier Olher I

If Net Counts> IOOcpm on s,mplo?S not m:ui<<d. "r,dlo:ictive*', cont*ct the R:uliation s,fcty Group for further investig*tio1L ltiz:ird Cl,s.s Shipped:

UN#: *<.. Cf'/ v If UN29IO, !s the R:,diooctive Shipmc11t Survey Compli*nt? Y~' No_

COC notation or ratlio:Jctivi: stickers on c:o11t.:Unc:~ equ:i.l dil!nt di!sigiiation.

Ma.,intum Net Counts Observed* ~iJ.* cJ Counts* Arco Ilockground Counts): -il_

CPM / M;.,/

Clnsslficd as: Rod l /Jod 2 / Rod 3

(.___/

'\\..,./'

/

COC um.it.ion or haz:.1t<l lubcb: 011 c:o11tainc:rs i::quaJ clii:11t d~ign.:ttion.

[f Dor E is )'CS, sclec~ Hazards below.

/

PCB's Fl:immabk Foreign Soil RCR,\\

Asb,:stos

. Iloryllium Other.

< z

Jl;' I*

J;.

~

11

@~ ll

-.. ~

Comments/Qualifiers (Required ror Non-ConJ'orn>lng Items)

Circle Applic.iblc:: Seals broken 0Jm:Jgcd conl:Jincr Le:tki.ng con1.:1incr Other (dcscnOt!)

Circle Applic:ibk::

Client cont:lctcd :ind pro\\idcd COC

cqc cre;Hcd upon receipt Preservation Method: Wet (o, Ice Packs Dry icetyi "all temperatures ari: recorded in Cl!lsius

,* //,r Tcmpcruturc Device Scrlul #:

c v t r:J Second:uy Temp,,,,itu,e Device Se,i:tl # (If Applicable):

S:1mpk JO's J.nd Containers Affected:

ff Po:sl!r\\':Hion added. Lotfl:

Other:'

TEMP:A t/

If Yes, ore Encores or Soil Kits p<escnt for solids? Yes No NA (If ;,:s, toke to VOA Freezer)

Do liquid VOA vials contain acid preservation? Yes

- - No NA (If unknown, scleC< No)

Arc liquid VOA vials fo:e ofheadspacc? Yes_ No_ NA_

Sampf,: ID"s.:ind concaincrs Jffl!ctcd:

!D's ru1d tests,ff<ctcd:

[D's =o1d cont.1in-e:rs :t.ffcctcd:

Circle Applicable: No elates on conr:tlncrs Na timts on co1uaine~

COC missing info Othcr(dl.!sciibe)

I/-~

Circle Applicablo: No container count on COC Other (dcsctil>!)

1, Are sample coot:tloer; identifiable as zt*

- GEL orm*ided bv use of GEL labels?

1 ~13::J:C:::OC~~fo~r~m~i~s~p;ru~p~e::rly~si;!s!!!nc~d~i:!..n:4~*~-J~~!_

Chde Applicable:

t::

relinquished/received sectitlnS?

Comments (Use Continuation Form if ne.111:d):

!(ot relinquism!VOthcr (descril>!)

PM (or PMA) t~vkw: [niti:tls *-**----"-

\\A.,,{):;_ ____ Date __..,_\\\\!-';).""-*

.'=--+/ ___ Page _l_ of _J_

I GL-CHL-SR-001 Rev7

Laboratory Certifications Page 8 of 38 SDG: 533227 Exhibit F

State Certification Alabama Alaska Alaska Drinking Water Arkansas CLIA California Colorado Connecticut DoD ELAP/ ISO17025 A2LA Florida NELAP Foreign Soils Permit Georgia Georgia SDWA Hawaii Idaho Illinois NELAP Indiana Kansas NELAP Kentucky SDWA Kentucky Wastewater Louisiana Drinking Water Louisiana NELAP Maine Maryland Massachusetts Massachusetts PFAS Approv Michigan Mississippi Nebraska Nevada New Hampshire NELAP New Jersey NELAP New Mexico New York NELAP North Carolina North Carolina SDWA North Dakota Oklahoma Pennsylvania NELAP Puerto Rico S. Carolina Radiochem Sanitation Districts of L South Carolina Chemistry Tennessee Texas NELAP Utah NELAP Vermont Virginia NELAP Washington 42200 17018 SC00012 880651 42D0904046 2940 SC00012 PH0169 2567.01 E87156 P3301500283, P3301500253 SC00012 967 SC00012 SC00012 200029 CSC01 E10332 90129 90129 LA024 03046 (AI33904) 2019020 270 MSC012 Letter 9976 SC00012 NEOS2613 SC0001220211 2054 SC002 SC00012 11501 233 45709 R158 2019165 6800485 SC00012 10120002 9255651 10120001 TN 02934 T1047042352119 SC00012202034 VT87156 460202 C780 List of current GEL Certifications as of 09 March 2021 Page 9 of 38 SDG: 533227 Exhibit F

Radiological Analysis Page 10 of 38 SDG: 533227 Exhibit F

Case Narrative Page 11 of 38 SDG: 533227 Exhibit F

Radiochemistry Technical Case Narrative Energy Northwest SDG #: 533227 Product: Alphaspec Am241, Cm, Solid High Rad Analytical Method: DOE EML HASL-300, Am-05-RC Modified Analytical Procedure: GL-RAD-A-011 REV# 28 Analytical Batch: 2095447 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758781 Method Blank (MB) 1204758782 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758783 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Alphaspec Pu242, Solid High Rad Analytical Method: DOE EML HASL-300, Pu-11-RC Modified Analytical Procedure: GL-RAD-A-011 REV# 28 Analytical Batch: 2095448 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758784 Method Blank (MB) 1204758785 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758786 Laboratory Control Sample (LCS)

Page 12 of 38 SDG: 533227 Exhibit F

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Alphaspec Np, Solid High Rad Analytical Method: ASTM C 1475-00 Modified Analytical Procedure: GL-RAD-A-069 REV# 0 Analytical Batch: 2095452 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758790 Method Blank (MB) 1204758791 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758792 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this Page 13 of 38 SDG: 533227 Exhibit F

report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Gammaspec, Gamma, solid High Rad Analytical Method: DOE HASL 300, 4.5.2.3/Ga-01-R Analytical Procedure: GL-RAD-A-013 REV# 27 Analytical Batch: 2085575 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204740613 Method Blank (MB) 1204740614 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204740615 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met The following detection limits were not achieved due to high sample activity.

Sample Analyte Value 1204740614 (RCU (RWCU Resins) 20-2431/20-026-HPDUP)

Cesium-137 Result 0 < MDA 0.00434 > RDL 0.001 uCi/g Niobium-94 Result 0.00115 < MDA 0.00389 > RDL 0.0002 uCi/g 533227001 (RCU (RWCU Resins) 20-2431/20-026-HP)

Niobium-94 Result -0.000488 < MDA 0.00376 > RDL 0.0002 uCi/g Qualifier Information Qualifier Reason Analyte Sample Client Sample UI Results are considered a false positive due to low abundance.

Antimony-125 533227001 RCU (RWCU Resins) 20-2431/20-026-HP Page 14 of 38 SDG: 533227 Exhibit F

1204740614 RCU (RWCU Resins) 20-2431/20-026-HP(5332 Cesium-137 1204740614 RCU (RWCU Resins) 20-2431/20-026-HP(5332 Niobium-95 533227001 RCU (RWCU Resins) 20-2431/20-026-HP Product: Gamma Ni59, Solid High Rad Analytical Method: DOE RESL Ni-1 Analytical Procedure: GL-RAD-A-022 REV# 19 Analytical Batch: 2095455 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758799 Method Blank (MB) 1204758800 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758801 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed double nickel precipitation for removal of interferences.

Qualifier Information Qualifier Reason Analyte Sample Client Sample UI Results are considered a false positive due to high counting uncertainty.

Nickel-59 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758800 RCU (RWCU Resins) 20-2431/20-026-HP(5332 Page 15 of 38 SDG: 533227 Exhibit F

Product: Gamma I129, Solid High Rad Analytical Method: DOE EML HASL-300,I-01 Modified Analytical Procedure: GL-RAD-A-006 REV# 21 Analytical Batch: 2095982 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759553 Method Blank (MB) 1204759554 Laboratory Control Sample (LCS) 1204759555 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met Sample (See Below) did not meet the detection limit due to limited sample volume. Sample was counted the maximum count time in order to achieve the lowest MDAs possible.

Sample Analyte Value 533227001 (RCU (RWCU Resins) 20-2431/20-026-HP)

Iodine-129 Result -0.000275 < MDA 0.000402 > RDL 0.00008 uCi/g Product: Liquid Scint Pu241, Solid High Rad Analytical Method: DOE EML HASL-300, Pu-11-RC Modified Analytical Procedure: GL-RAD-A-035 REV# 21 Analytical Batch: 2095450 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758787 Method Blank (MB) 1204758788 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP)

Page 16 of 38 SDG: 533227 Exhibit F

1204758789 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed second columns for removal of iron interferences.

Quality Control (QC) Information RDL Met Samples (See Below) did not meet the detection limits, however the 10CFR61 limitations were met.

Sample Analyte Value 1204758788 (RCU (RWCU Resins) 20-2431/20-026-HPDUP)

Plutonium-241 Result -0.00146 < MDA 0.00361 > RDL 0.0035 uCi/g 533227001 (RCU (RWCU Resins) 20-2431/20-026-HP)

Plutonium-241 Result 0.00123 < MDA 0.00405 > RDL 0.0035 uCi/g Product: Liquid Scint Ni63, Solid High Rad Analytical Method: DOE RESL Ni-1, Modified Analytical Procedure: GL-RAD-A-022 REV# 19 Analytical Batch: 2095454 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758796 Method Blank (MB) 1204758797 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758798 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Page 17 of 38 SDG: 533227 Exhibit F

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed double nickel precipitation for removal of interferences.

Product: LSC, Rapid Sr-89 and Sr-90, High Rad Solids Analytical Method: GL-RAD-A-051 Analytical Procedure: GL-RAD-A-051 REV# 8 Analytical Batch: 2095456 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758802 Method Blank (MB) 1204758803 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758804 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met Samples (See Below) did not meet the detection limits, however the 10CFR61 limitations were met.

Sample Analyte Value 1204758802 (MB)

Strontium-90 Result -0.00000716 < MDA 0.00011 > RDL 0.00004 uCi/g 533227001 (RCU (RWCU Resins) 20-2431/20-026-HP)

Strontium-90 Result 0.000777 < MDA 0.00118 > RDL 0.00004 uCi/g Page 18 of 38 SDG: 533227 Exhibit F

Product: LSC, Tritium Dist, Solid High Rad Analytical Method: EPA 906.0 Modified Analytical Procedure: GL-RAD-A-002 REV# 23 Analytical Batch: 2095983 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759556 Method Blank (MB) 1204759557 Laboratory Control Sample (LCS) 1204759558 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Liquid Scint C14, Solid High Rad Analytical Method: EPA EERF C-01 Modified Analytical Procedure: GL-RAD-A-003 REV# 16 Analytical Batch: 2095984 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759559 Method Blank (MB) 1204759560 Laboratory Control Sample (LCS) 1204759561 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Liquid Scint Tc99, Solid High Rad Analytical Method: DOE EML HASL-300, Tc-02-RC Modified Analytical Procedure: GL-RAD-A-059 REV# 5 Page 19 of 38 SDG: 533227 Exhibit F

Analytical Batch: 2095989 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759565 Method Blank (MB) 1204759566 Laboratory Control Sample (LCS) 1204759567 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed a double iron scavenge and all part 61 clean ups and rinses to reduce interferences.

Technical Information Recounts Samples 1204759566 (LCS) and 1204759567 (LCSD) were recounted due to low recovery. The recounts are reported.

Product: Liquid Scint Fe55, Solid High Rad Analytical Method: DOE RESL Fe-1, Modified Analytical Procedure: GL-RAD-A-040 REV# 13 Analytical Batch: 2098494 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204764651 Method Blank (MB) 1204764652 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204764653 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and Page 20 of 38 SDG: 533227 Exhibit F

procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Technical Information Sample Re-prep/Re-analysis Samples were reprepped due to high recovery. The re-analysis is being reported.

Certification Statement Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless otherwise noted in the analytical case narrative.

Page 21 of 38 SDG: 533227 Exhibit F

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com ENNO002 Energy Northwest Client SDG: 533227 GEL Work Order: 533227 Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the Certificate of Analysis.

This data report has been prepared and reviewed in accordance with GEL Laboratories LLC standard operating procedures. Please direct any questions to your Project Manager, Taylor Cannon.

Reviewed by Sample(s) Contained within this report:

533227001 Lab Sample ID Client Sample ID Sample Description RCU (RWCU Resins) 20-2431/20-026-HP N/A Collected 12/01/2020 08:19 Signature:

Name:

Date:

Title:

10 MAR 2021 Theresa Austin Group Leader Page 22 of 38 SDG: 533227 Exhibit F

~~

Sample Data Summary Page 23 of 38 SDG: 533227 Exhibit F

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

UI Gamma Spectroscopy--Uncertain identification Radiological Certificate of Analysis GEL Sample ID:

Matrix:

Client:

Collect Date:

Receive Date:

Client Sample ID:

533227001 Misc Solid Energy Northwest December 01, 2020 January 26, 2021 RCU (RWCU Resins) 20-2431/20-026-HP Report Date: March 10, 2021 Analyte Run Date Activity MDA Qualifier 2 Sigma Uncertainty RL Alpha Spec Gamma Spec H-3 C-14 Fe-55 Ni-63 Sr-89 Sr-90 Tc-99 Pu-241 Np-237 Pu-238 Pu-239/240 Pu-242 Am-241 Cm-242 Cm-243/244 Cr-51 Mn-54 Fe-59 Co-57 Co-58 Co-60 Ni-59 Zn-65 Zr-95 Nb-94 Nb-95 Ru-103 Ag-110m Sn-113 Sb-124 Sb-125 I-129 Cs-134 Cs-136 02/26/21 02/26/21 03/03/21 03/02/21 02/26/21 02/26/21 03/02/21 03/02/21 03/01/21 03/01/21 03/01/21 03/01/21 03/01/21 03/01/21 03/01/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 03/01/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 02/26/21 01/27/21 01/27/21 8.82E-04 2.23E-04 6.92E+01 1.52E+00 6.18E-03 7.77E-04 6.49E-03 1.23E-03

-7.88E-06 1.54E-05 2.01E-05

-7.34E-06 9.24E-06

-1.82E-06

-1.25E-06

-1.44E-02 1.66E+00 2.77E-03 2.08E-03 3.53E-02 1.73E+01 0.00E+00 4.17E-01

-4.47E-03

-4.88E-04 0.00E+00 2.84E-03 3.79E-02 4.96E-04 1.49E-03 0.00E+00

-2.75E-04 4.74E-04

-2.12E-02 1.50E-03 1.87E-04 8.47E-01 3.00E-02 4.06E-03 7.04E-04 4.74E-04 2.36E-03 9.91E-06 4.19E-05 4.20E-05 2.50E-05 2.93E-05 3.02E-05 2.08E-05 4.41E-02 1.09E-02 1.59E-02 1.09E-03 6.64E-03 2.01E-02 1.15E-02 1.99E-02 8.60E-03 2.81E-03 6.34E-03 4.62E-03 7.21E-03 2.64E-03 1.78E-03 6.81E-03 2.52E-04 3.39E-03 8.65E-02 2.58E-03 3.10E-04 1.61E-01 5.66E-03 6.59E-03 1.18E-03 4.61E-04 4.05E-03 3.31E-05 7.23E-05 6.23E-05 6.97E-05 4.42E-05 6.40E-05 4.39E-05 7.62E-02 5.82E-03 2.73E-02 1.40E-03 8.22E-03 5.90E-03 7.05E-03 1.40E-02 1.41E-02 3.76E-03 7.93E-03 7.81E-03 9.02E-03 4.52E-03 3.05E-03 7.90E-03 4.02E-04 5.55E-03 1.49E-01 4.00E-02 8.00E-03 7.00E-01 3.50E-03 7.00E-01 4.00E-05 3.00E-03 3.50E-03 1.00E-04 1.00E-04 1.00E-04 1.00E-04 1.00E-04 2.00E-02 1.00E-04 7.00E-01 2.20E-01 2.00E-04 8.00E-05 U

3,U 3

3 3,U 3,U 3

U U

U 3

3 3

UI 3

U U

UI U

3 U

U UI U

U U

1 2

uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Units Page 24 of 38 SDG: 533227 Exhibit F

GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

UI Gamma Spectroscopy--Uncertain identification Radiological Certificate of Analysis GEL Sample ID:

Matrix:

Client:

Collect Date:

Receive Date:

Client Sample ID:

533227001 Misc Solid Energy Northwest December 01, 2020 January 26, 2021 RCU (RWCU Resins) 20-2431/20-026-HP Report Date: March 10, 2021 Analyte Run Date Activity MDA Qualifier 2 Sigma Uncertainty RL Cs-137 Ba-133 Ba-140 La-140 Ce-141 Ce-144 Hf-181 Ta-182 Co-60 Ratio(C-14 Aliquot/Sample) 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 01/27/21 02/22/21 6.98E-03

-2.31E-04

-5.51E-02 3.56E-04 2.47E-03 2.42E-03

-1.65E-03 2.59E-03 4.94E+00 3.43E-03 1.83E-03 1.53E-01 1.02E-02 4.70E-03 7.31E-03 4.70E-03 8.72E-03 4.19E-03 3.15E-03 2.57E-01 1.74E-02 7.62E-03 1.10E-02 7.94E-03 1.49E-02 1.00E-03 3

U U

U 1

2 uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g none Units Page 25 of 38 SDG: 533227 Exhibit F

GEL LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Isotope Abundance Report Note: The parmname will appear only if the abundance, if present, is above the minimum level of 0.01 GEL Sample ID:

Matrix:

Client:

Collect Date:

Receive Date:

Client Sample ID:

533227001 Misc Solid Energy Northwest December 01, 2020 January 26, 2021 RCU (RWCU Resins) 20-2431/20-026-HP Analyte Activity Alpha Spec Gamma Spec Ni-63 Fe-55 Co-58 Co-60 Mn-54 Ag-110m Zn-65 1.52E+00 6.92E+01 3.53E-02 1.73E+01 1.66E+00 3.79E-02 4.17E-01 uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Units

% Abundance 001.69 076.74 000.04 019.16 001.84 000.04 000.46 Total Activity:

9.01E+01 Total % Abundance:

100.00 Page 26 of 38 SDG: 533227 Exhibit F

Quality Control Summary Page 27 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 Batch Antimony-124 Antimony-125 Barium-133 Barium-140 Cerium-141 Cerium-144 Cesium-134 Cesium-136 Cesium-137 Chromium-51 Cobalt-57 Cobalt-58 Cobalt-60 Hafnium-181 Parmname Mr. Mike Nolan

Contact:

Energy Northwest none Richland, Washington March 10, 2021 Report Date:

Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 01/28/21 09:03 QC 0.000592 0.000 0.000133

-0.0431

-0.000136 0.00333 0.00353 0.0382 0.000 0.00397 0.00266 0.0371 18.3 0.00523 NOM Sample 0.00149 0.000

-0.000231

-0.0551 0.00247 0.00242 0.000474

-0.0212 0.00698

-0.0144 0.00208 0.0353 17.3

-0.00165 Range N/A N/A N/A N/A N/A N/A N/A N/A (0% - 100%)

N/A (0% - 100%)

(0% - 100%)

(0%-20%)

N/A Qual U

UI U

U U

U UI U

U QC1204740614 533227001 N/A N/A N/A N/A N/A N/A N/A N/A 46.6 N/A 24.4 4.86 5.57 N/A REC%

DUP 533227 Workorder:

U UI U

U U

U

+/-0.00178

+/-0.00681

+/-0.00183

+/-0.153

+/-0.00470

+/-0.00731

+/-0.00339

+/-0.0865

+/-0.00343

+/-0.0441

+/-0.00109

+/-0.00664

+/-0.0201

+/-0.00470

+/-0.00188

+/-0.00626

+/-0.00188

+/-0.167

+/-0.00489

+/-0.00689

+/-0.00348

+/-0.0943

+/-0.00292

+/-0.0463

+/-0.00111

+/-0.00758

+/-0.0211

+/-0.00558 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 1 of 11 Page 28 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 Batch Iron-59 Lanthanum-140 Manganese-54 Niobium-94 Niobium-95 Ruthenium-103 Silver-110m Tantalum-182 Tin-113 Zinc-65 Zirconium-95 Americium-241 Antimony-124 Antimony-125 Barium-133 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 01/28/21 09:03 01/27/21 10:12 QC 0.00161

-0.00425 1.76 0.00115 0.00339

-0.000444 0.0382

-0.00161 0.000272 0.397 0.000424 0.0699

-2.74E-05 8.02E-05

-3.22E-05 NOM Sample 0.00277 0.000356 1.66

-0.000488 0.000 0.00284 0.0379 0.00259 0.000496 0.417

-0.00447 Range N/A N/A (0%-20%)

N/A N/A N/A (0% - 100%)

N/A N/A (0%-20%)

N/A (75%-125%)

Qual U

U U

QC1204740615 N/A N/A 5.79 N/A N/A N/A 0.763 N/A N/A 4.77 N/A REC%

104 0.0669 LCS 533227 Workorder:

U U

U UI U

U U

U

+/-0.0159

+/-0.0102

+/-0.0109

+/-0.00281

+/-0.00634

+/-0.00462

+/-0.00721

+/-0.00872

+/-0.00264

+/-0.0199

+/-0.00860

+/-0.0166

+/-0.0114

+/-0.0116

+/-0.00247

+/-0.00742

+/-0.00484

+/-0.00746

+/-0.00903

+/-0.00273

+/-0.0194

+/-0.00895

+/-0.00313

+/-0.000160

+/-0.000450

+/-0.000176 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 2 of 11 Page 29 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 Batch Barium-140 Cerium-141 Cerium-144 Cesium-134 Cesium-136 Cesium-137 Chromium-51 Cobalt-57 Cobalt-58 Cobalt-60 Hafnium-181 Iron-59 Lanthanum-140 Manganese-54 Niobium-94 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 01/27/21 10:12 QC

-1.65E-05 4.45E-05

-0.000264 8.28E-05 3.04E-06 0.0217

-0.000547 3.62E-05 2.20E-05 0.0141

-5.46E-05

-0.000134 5.53E-05 0.000931 0.000166 NOM Sample Range (75%-125%)

(75%-125%)

Qual U

U U

U REC%

97.3 112 0.0223 0.0125 533227 Workorder:

+/-0.000573

+/-0.000154

+/-0.000692

+/-0.000163

+/-0.000221

+/-0.000989

+/-0.00107

+/-9.06E-05

+/-0.000137

+/-0.000908

+/-0.000198

+/-0.000348

+/-6.33E-05

+/-0.000482

+/-0.000137 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 3 of 11 Page 30 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 Batch Niobium-95 Ruthenium-103 Silver-110m Tantalum-182 Tin-113 Zinc-65 Zirconium-95 Antimony-124 Antimony-125 Barium-133 Barium-140 Cerium-141 Cerium-144 Cesium-134 Cesium-136 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 01/27/21 10:12 01/27/21 07:53 QC

-7.06E-05 4.62E-05 3.84E-05

-0.000200

-0.000125

-0.000294 0.000292 9.66E-06 1.83E-05 1.47E-05

-4.30E-07

-1.06E-05

-2.63E-05 4.39E-07 4.17E-05 NOM Sample Range Qual U

U U

QC1204740613 REC%

MB 533227 Workorder:

+/-0.000120

+/-0.000144

+/-0.000215

+/-0.000337

+/-0.000189

+/-0.000394

+/-0.000358

+/-1.89E-05

+/-7.57E-05

+/-3.16E-05

+/-0.000101

+/-3.88E-05

+/-0.000132

+/-2.89E-05

+/-3.05E-05 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 4 of 11 Page 31 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 Batch Cesium-137 Chromium-51 Cobalt-57 Cobalt-58 Cobalt-60 Hafnium-181 Iron-59 Lanthanum-140 Manganese-54 Niobium-94 Niobium-95 Ruthenium-103 Silver-110m Tantalum-182 Tin-113 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 01/27/21 07:53 QC

-2.93E-05

-0.000184

-5.56E-06 2.56E-05 3.03E-05 1.79E-05

-4.56E-05 3.23E-05

-2.16E-05 2.92E-06

-9.26E-06 7.59E-07

-2.03E-05

-1.33E-05 9.04E-06 NOM Sample Range Qual U

U U

REC%

533227 Workorder:

+/-3.80E-05

+/-0.000202

+/-2.19E-05

+/-2.60E-05

+/-7.03E-05

+/-2.99E-05

+/-4.76E-05

+/-3.16E-05

+/-2.69E-05

+/-2.50E-05

+/-2.87E-05

+/-2.38E-05

+/-3.51E-05

+/-0.000108

+/-3.33E-05 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 5 of 11 Page 32 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2085575 2095447 2095448 Batch Batch Batch Zinc-65 Zirconium-95 Americium-241 Curium-242 Curium-243/244 Americium-241 Curium-242 Curium-243/244 Americium-241 Curium-242 Curium-243/244 Plutonium-238 Plutonium-239/240 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXB7 TC1 TC1 01/27/21 07:53 03/01/21 15:32 03/01/21 15:31 03/01/21 15:32 03/01/21 15:32 QC 6.56E-06

-4.64E-05 1.58E-05

-1.81E-06 2.89E-06 0.000168 9.38E-07 0.000170

-3.60E-07

-5.41E-07 1.72E-06

-1.05E-05 4.79E-06 NOM Sample 9.24E-06

-1.82E-06

-1.25E-06 1.54E-05 2.01E-05 Range N/A N/A N/A (75%-125%)

(75%-125%)

N/A N/A Qual U

U U

QC1204758782 533227001 QC1204758783 QC1204758781 QC1204758785 533227001 N/A N/A N/A N/A N/A REC%

90.4 81.9 0.000186 0.000207 DUP LCS MB DUP 533227 Workorder:

U U

U

+/-2.93E-05

+/-3.02E-05

+/-2.08E-05

+/-4.19E-05

+/-4.20E-05

+/-6.58E-05

+/-5.44E-05

+/-3.57E-05

+/-2.99E-05

+/-2.93E-05

+/-3.11E-05

+/-4.12E-06

+/-3.09E-05

+/-3.01E-06

+/-3.03E-06

+/-5.12E-06

+/-2.42E-05

+/-3.39E-05 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 6 of 11 Page 33 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2095448 2095450 2095452 Batch Batch Batch Plutonium-242 Plutonium-238 Plutonium-239/240 Plutonium-242 Plutonium-238 Plutonium-239/240 Plutonium-242 Plutonium-241 Plutonium-241 Plutonium-241 Neptunium-237 Neptunium-237 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time TC1 TC1 TC1 03/01/21 15:32 03/01/21 15:32 03/01/21 15:32 03/02/21 13:51 03/02/21 14:07 03/02/21 13:35 03/01/21 16:50 03/01/21 16:50 QC

-7.18E-06 1.35E-06 0.000209 2.51E-06 1.83E-07 3.67E-06

-2.78E-07

-0.00146 0.00274

-0.000127

-4.94E-06 0.000398 NOM Sample

-7.34E-06 0.00123

-7.88E-06 Range N/A (75%-125%)

N/A (75%-125%)

Qual U

U U

QC1204758786 QC1204758784 QC1204758788 533227001 QC1204758789 QC1204758787 QC1204758791 533227001 QC1204758792 N/A N/A N/A REC%

111 93.5 96.7 0.000187 0.00293 0.000412 LCS MB DUP LCS MB DUP LCS 533227 Workorder:

U U

U

+/-2.50E-05

+/-0.00236

+/-9.91E-06

+/-2.45E-05

+/-2.57E-06

+/-2.05E-05

+/-3.03E-06

+/-3.89E-06

+/-5.49E-06

+/-4.00E-06

+/-0.00195

+/-0.000234

+/-0.000165

+/-9.36E-06

+/-3.19E-05 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 7 of 11 Page 34 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2095452 2095454 2095455 2095456 Batch Batch Batch Batch Neptunium-237 Nickel-63 Nickel-63 Nickel-63 Nickel-59 Nickel-59 Nickel-59 Strontium-89 Strontium-90 Strontium-89 Strontium-90 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time TC1 TC1 TC1 TC1 03/01/21 16:50 03/02/21 09:57 03/02/21 10:03 03/02/21 09:41 03/01/21 12:08 03/01/21 12:10 03/01/21 12:07 02/26/21 16:55 02/26/21 17:11 QC

-1.09E-06 1.52 0.0156

-0.000322 0.000 0.0233 7.18E-05 0.00516 0.000709 0.0705 0.00216 NOM Sample 1.52 0.000 0.00618 0.000777 Range (0%-20%)

(75%-125%)

N/A (75%-125%)

N/A (0% - 100%)

(75%-125%)

Qual U

U UI U

U QC1204758790 QC1204758797 533227001 QC1204758798 QC1204758796 QC1204758800 533227001 QC1204758801 QC1204758799 QC1204758803 533227001 QC1204758804 0.271 N/A N/A 9.14 REC%

114 119 87.1 106 0.0137 0.0195 0.0809 0.00204 MB DUP LCS MB DUP LCS MB DUP LCS 533227 Workorder:

UI U

U

+/-0.0300

+/-0.0115

+/-0.00406

+/-0.000704

+/-2.65E-06

+/-0.0299

+/-0.000726

+/-0.000304

+/-0.00739

+/-0.00212

+/-0.000472

+/-0.00440

+/-0.000423

+/-0.000692

+/-5.92E-05 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 8 of 11 Page 35 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2095456 2095982 2095983 2095984 Batch Batch Batch Batch Strontium-89 Strontium-90 Iodine-129 Iodine-129 Iodine-129 Tritium Tritium Tritium Carbon-14 Carbon-14 Carbon-14 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time TC1 JXB7 JXB7 TC1 02/26/21 16:40 02/26/21 11:37 02/26/21 14:11 02/26/21 11:36 02/26/21 17:05 02/26/21 17:22 02/26/21 16:49 02/26/21 09:01 02/26/21 09:17 02/26/21 08:45 QC 1.75E-06

-7.16E-06 0.000223 0.000225 8.53E-07 0.000984 0.00106 1.22E-05 0.000389 0.000382

-9.50E-06 NOM Sample Range (75%-125%)

(0%-20%)

(75%-125%)

(0%-20%)

(75%-125%)

(0%-20%)

Qual U

U U

QC1204758802 QC1204759554 QC1204759555 QC1204759553 QC1204759557 QC1204759558 QC1204759556 QC1204759560 QC1204759561 QC1204759559 0.891 7.39 1.98 REC%

111 112 87 93.7 101 99.3 0.000201 0.000201 0.00113 0.00113 0.000384 0.000384 MB LCS LCSD MB LCS LCSD MB LCS LCSD MB 533227 Workorder:

+/-7.58E-05

+/-6.44E-05

+/-2.45E-05

+/-1.96E-05

+/-3.55E-06

+/-0.000153

+/-0.000156

+/-8.94E-05

+/-2.11E-05

+/-2.12E-05

+/-9.62E-06 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Page 9 of 11 Page 36 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2095989 2098494 Batch Batch Technetium-99 Technetium-99 Technetium-99 Iron-55 Iron-55 Iron-55 Parmname Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time TC1 TC1 03/02/21 09:38 03/02/21 09:55 03/02/21 04:42 03/03/21 18:45 03/03/21 19:01 03/03/21 18:28 QC 0.000452 0.000419 9.04E-06 64.8 0.0244 7.29E-05 NOM Sample 69.2 Range (75%-125%)

(0%-20%)

(75%-125%)

Qual U

U QC1204759566 QC1204759567 QC1204759565 QC1204764652 533227001 QC1204764653 QC1204764651 The Qualifiers in this report are defined as follows:

7.52 6.44 REC%

85.1 78.9 89.6 0.000531 0.000531 0.0272 LCS LCSD MB DUP LCS MB 533227 Workorder:

BD FA H

J J

K L

M M

N/A Analyte is a Tracer compound Result is less than value reported Result is greater than value reported Results are either below the MDC or tracer recovery is low Failed analysis.

Analytical holding time was exceeded See case narrative for an explanation Value is estimated Analyte present. Reported value may be biased high. Actual value is expected to be lower.

Analyte present. Reported value may be biased low. Actual value is expected to be higher.

M if above MDC and less than LLD REMP Result > MDC/CL and < RDL RPD or %Recovery limits do not apply.

+/-0.847

+/-3.23E-05

+/-3.13E-05

+/-1.69E-05

+/-0.811

+/-0.00145

+/-0.000702 RPD%

Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Notes:

Counting Uncertainty is calculated at the 95% confidence level (1.96-sigma).

Page 10 of 11 Page 37 of 38 SDG: 533227 Exhibit F

QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com Parmname Page 11 of 11 Units Anlst Date Time QC NOM Sample Range Qual REC%

533227 Workorder:

N1 ND NJ Q

R U

UI UJ UL X

Y

^

h See case narrative Analyte concentration is not detected above the detection limit Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier One or more quality control criteria have not been met. Refer to the applicable narrative or DER.

Sample results are rejected Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

Gamma Spectroscopy--Uncertain identification Gamma Spectroscopy--Uncertain identification Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.

Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Other specific qualifiers were required to properly define the results. Consult case narrative.

RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry.

Preparation or preservation holding time was exceeded N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc. by a factor of 4 or more or %RPD not applicable.

^ The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/- the RL is used to evaluate the DUP result.

Indicates that a Quality Control parameter was not within specifications.

For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.

Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the QC Summary.

RPD%

Page 38 of 38 SDG: 533227 Exhibit F

ML23206A244

Text

Enclosure:

Title:

Description:

Title:

Description:

Dear Mr. Nolan:

Title:

Contact:

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