Text

Annual Monitoring Report, Cover Letter Through Part D, Groundwater Monitoring
	ML091380403
Person / Time
Site:	Point Beach
Issue date:	04/30/2009
From:	Jim Costedio; Nextera Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	FOIA/PA-2010-0209, NRC-2009-0046
	Download: ML091380403 (92)
	v • d • e

NExTera ENERGY POINT BEACH April 30, 2009 NRC 2009-0046 10 CFR 72.44 TS 5.6.2 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266, 50-301 and 72-005 Renewed License Nos. DPR-24 and DPR-27 2008 Annual Monitoring Report In accordance with Point Beach Nuclear Plant (PBNP) Technical Specification 5.6.2, enclosed is the Annual Monitoring Report for PBNP Units 1 and 2, for the period January 1 through December 31, 2008.

The Annual Monitoring Report contains information relating to the effluent impact upon the public, as well as information relating to plant releases, solid waste shipments, results from the radiological environmental monitoring program and miscellaneous monitoring activities which occurred in 2008. The report also covers the results of radiological monitoring of the PBNP Independent Spent Fuel Storage Installation (ISFSI), as required by 10 CFR 72.44.

Enclosure 2 contains the PBNP Environmental Manual which was revised in November 2008.

This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.

Very truly yours, NextEra Energy Point Beach, LLC James Costedio Licensing Manager Enclosures cc: Administrator, Region III, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW American Nuclear Insurers WI Division of Public Health, Radiation Protection Section NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Enclosure 1 ANNUAL MONITORING REPORT 2008 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT DOCKETS 50-266 (UNIT 1), 50-301 (UNIT 2),72-005 (ISFSI)

RENEWED LICENSES DPR-24 and DPR-27 January 1, 2008, through December 31, 2008

TABLE OF CONTENTS Summary 1 Part A: Effluent Monitoring 1.0 Introduction 3 2.0 Radioactive Liquid Releases 4 3.0 Radioactive Airborne Releases 9 4.0 Radioactive Solid Waste Shipments 12 5.0 Nonradioactive Chemical Releases 15 6.0 Circulating Water System Operation 16 Part B: Miscellaneous Reporting Requirements 7.0' Additional Reporting Requirements 17 Part C: Radiological Environmental Monitoring 8.0 Introduction 18 9.0 Program Description 19 10.0 Results 30 11.0 Discussion 34 12.0 REMP Conclusion 42 Part D: Groundwater Monitoring 13.0 Program Description 43 14.0 Results 46 15.0 Groundwater Summary 51 Appendix 1: Environmental, Inc. Midwest Laboratory, Radiological Environmental Monitoring Program (REMP) for the Point Beach Nuclear Plant, Two Rivers, Wisconsin.

Appendix 2: University of Waterloo (Ontario) Environmental Isotope Laboratory, precipitation i

LIST OF TABLES Table 2-1 Comparison of 2008 Liquid Effluent Calculated Doses to 10 CFR 50 Appendix I Design Objectives 4 Table 2-2 Summary of Circulating Water Discharge 6 Table 2-3 Isotopic Composition of Circulating Water Discharges (Curies) 7 Table 2-4 Subsoil System Drains - Tritium Summary 8 Table 3-1 Comparison of 2008 Airborne Effluent Calculated Doses to 10 CFR 50 Appendix I Design Objectives 10 Table 3-2 Radioactive Airborne Effluent Release Summary 10 Table 3-3 Isotopic Composition of Airborne Releases 11 Table 4-1 Quantities and Types of Waste Shipped from PBNP 12 Table 4-2 2008 Estimated Solid Waste Major Radionuclide Composition 13 Table 4-3 2008 PBNP Radioactive Waste Shipments 14 Table 6-1 Circulating Water System Operation for 2008 16 Table 9-1 PBNP REMP Sample Analysis and Frequency 21 Table 9-2 PBNP REMP Sampling Locations 22 Table 9-3 ISFSI Sampling Sites 26 Table 9-4 Minimum Acceptable Sample Size 26 Table 9-5 Deviations from Scheduled Sampling and Frequency 27 Table 9-6 Sample Collection for the State of Wisconsin 27 Table 10-1 Summary of Radiological Environmental Monitoring Results for 2008 32 Table 10-2 ISFSI Fence TLD Results for 2008 34 Table 11-1 Average Indicator TLD Results from 1993-2008 34 Table1 1-2 Average ISFSI Fence TLD Results (mR/7days) 35 Table 11-3 Average TLD Results Surrounding the ISFSI (mR/7days) 35 Table 11-4 Average Gross Beta Measurements in Air 36 Table 11-5 Average Gross Beta Concentrations in Soil 40 Table 14-1 Intermittent Streams and Bogs 46 Table 14-2 2008 Beach Drain Tritium 47 Table 14-3 U2 Fagade Subsurface Drainage Sump H-3 48 Table 14-4 Yard Manhole Tritium 48 Table 14-5 2008 Fagade Well Water Tritium 49 Table 14-6 2008 Well Water Tritium 50 Table 14-7 Precipitation H-3 51 LIST OF FIGURES Figure 9-1 PBNP REMP Sampling Sites 23 Figure 9-2 Map of REMP Sampling Sites Located Around PBNP 24 Figure 9-3 Enhanced Map Showing REMP Sampling Sites Closest to PBNP 25 Figure 11-1 2008 Airborne Gross Beta Concentration (pCi/m 3) vs. Time 37 Figure 13-1 Groundwater Monitoring Locations 45 ii

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SUMMARY

The Annual Monitoring Report for the period of January 1, 2008, through December 31, 2008, is submitted in accordance with Point Beach Nuclear Plant (PBNP) Units 1 and 2, Technical Specification 5.6.2 and filed under Dockets 50-266 and 50-301 for Facility Operating Licenses DPR-24 and DPR-27, respectively. It also contains results of monitoring in support of the Independent Spent Fuel Storage Installation (ISFSI), Docket 72-005. The report presents the results of effluent and environmental monitoring programs, solid waste shipments, non-radioactive chemical releases, and circulating water system operation.

During 2008 the following Curies (Ci) of radioactive material were released via the liquid and atmospheric pathways:

Liquid Atmospheric Tritium (Ci) 534 64.2 Particulate' (Ci) 0.120 0.00002 Noble Gas (Ci) (-) 1.11

(-) Noble gases in the liquids are added to the atmospheric release totals.

1 Atmospheric particulate includes radioiodine (1-131, 1-133).

For the purpose of compliance with the effluent design objectives of Appendix I to 10 CFR 50, doses from effluents are calculated for the hypothetical maximally exposed individual (MEI) for each age group and compared to the Appendix I objectives. Doses less than or equal to the Appendix I values are considered to be evidence that PBNP releases are as low as reasonably achievable (ALARA). The maximum annual calculated doses in millirem (mrem) or millirad (mrad) are shown below and compared to the corresponding design objectives of 10 CFR 50, Appendix I.

LIQUID RELEASES Dose Category Calculated Dose Appendix I Dose Whole body dose 0.0065 mrem 6 mrem Organ dose 0.0116 mrem 6 mrem ATMOSPHERIC RELEASES Dose Category Calculated Dose Appendix I Dose Organ dose 0.0254 mrem 30 mrem Noble gas beta air dose 0.00013 mrad 40 mrad Noble gas gamma ray air dose 0.00026 mrad 20 mrad Noble gas dose to the skin 0.00039 mrem 30 mrem Noble gas dose to the whole body 0.00025 mrem 10 mrem The results show that during 2008, the doses from PBNP effluents were a small percentage (0.11% at the most) of the Appendix I design objectives. Therefore, operation of PBNP continues to be ALARA.

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A survey of land use with respect to the location of dairy cattle was made pursuant to Section 2.5 of the PBNP Environmental Manual. As in previous years, no dairy cattle were found to be grazing at the site boundary. Therefore, the assumption that cattle graze at the site boundary used in the evaluation of doses from PBNP effluents remains conservative.

The 2008 Radiological Environmental Monitoring Program (REMP) collected 806 samples for radiological analyses and 116 sets of thermoluminescent dosimeters (TLDs) to measure ambient radiation in the vicinity of PBNP and the ISFSI. Air monitoring from six different sites showed only background radioactivity from naturally occurring radionuclides. Terrestrial monitoring consisting of soil, vegetation and milk found no influence from PBNP. Similarly, samples from the aquatic environment, consisting of lake and well water, fish and algae, revealed no buildup of PBNP radionuclides released in liquid effluents. Therefore, the data show no plant effect on its environs.

There were no dry storage casks added to the ISFSI in 2008. The total number remains at 25 dry storage casks. Sixteen are the ventilated, vertical storage casks (VSC-24) and nine are the NUHOMS, horizontally stacked storage modules. The subset of the PBNP REMP samples used to evaluate the environmental impact of the PBNP ISFSI showed no environmental impact from its operation.

The environmental monitoring conducted during 2008 confirmed that the effluent control program at PBNP ensured a minimal impact on the environment.

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Part A EFFLUENT MONITORING

1.0 INTRODUCTION

The PBNP effluent monitoring program is designed to comply with federal regulations for ensuring the safe operation of PBNP with respect to releases of radioactive material to the environment and its subsequent impact on the public. Pursuant to 10 CFR 50.34a, operations should be conducted to keep the levels of radioactive material in effluents to unrestricted areas as low as reasonably achievable (ALARA). In 10 CFR 50, Appendix I, the Nuclear Regulatory Commission (NRC) provides the numerical values for appropriate ALARA design objectives upon which the licensee's calculated effluent doses may be compared. These doses are a small fraction of the dose limits specified by 10 CFR 20.1301 and lower than the Environmental Protection Agency (EPA) limits specified in 40 CFR 190.

10 CFR 20.1302 directs NextEra Point Beach to make the appropriate surveys of radioactive materials in effluents released to unrestricted and controlled areas. Liquid wastes are monitored by inline radiation monitors as well as by isotopic analyses of samples of the waste stream prior to discharge from PBNP. Airborne releases of radioactive wastes are monitored in a similar manner. Furthermore, for both liquid and atmospheric releases, the appropriate portions of the radwaste treatment systems are used as required to keep releases ALARA. Prior to release, results of isotopic analyses are used to adjust the release rate of discrete volumes of liquid and atmospheric wastes (from liquid waste holdup tanks and from gas decay tanks) such that the concentrations of radioactive material in the air and water beyond PBNP are below the PBNP Technical Specification concentration limits for liquid effluents and release rate limits for gaseous effluents.

Solid wastes are shipped offsite for disposal at NRC licensed facilities. The amount of radioactivity in the solid waste is determined prior to shipment in order to determine the proper shipping configuration as regulated by the Department of Transportation and the NRC.

A General License was granted, pursuant to 10 CFR 72.210, for an Independent Spent Fuel Storage Installation (ISFSI) facility. The release of radioactive materials from the operation of the ISFSI must also comply with the limits of Part 20 and Part 50 Appendix I design objectives. Per 10 CFR 72.44(d) (3), the results of radiological effluent monitoring are to be reported annually. The dose criteria for effluents and direct radiation specified by 10 CFR 72.104 states that during normal operations and anticipated occurrences, the annual dose equivalent to any real individual beyond the controlled area must not exceed 25 mrem to the whole body, 75 mrem to the thyroid, and 25 mrem to any other critical organ. The dose from naturally occurring radon and its decay products are exempt. The doses from effluents due to the loading process will be assessed and quantified as part of the PBNP Radiological Effluent Control Program, Holders of a Part 72 license are allowed to submit the report required by 72.44(d)(3) concurrent with the effluent report required by 10 CFR 50.36a(a)(2). (

Reference:

64 FR 33178) 3

because the loading of the storage casks occurs within the primary auxiliary building of PBNP.

2.0 RADIOACTIVE LIQUID RELEASES The radioactive liquid release path to the environment is via the circulating water discharge. A liquid waste treatment system in conjunction with administrative controls is used to minimize the impact on the environment and maintain doses to the public ALARA from the liquid releases.

2.1 Doses From Liquid Effluent Doses from liquid effluent are calculated using the methodology of the Offsite Dose Calculation Manual (ODCM). These calculated doses use parameters such as the amount of radioactive material released, the total volume of liquid, the total volume of dilution water, and usage factors (e.g., water and fish consumption, shoreline and swimming factors). These calculations produce a conservative estimation of the dose. For compliance with 10 CFR 50, Appendix I design objectives, the annual dose is calculated to the hypothetical maximally exposed individual (MEI). The MEI is assumed to reside at the site boundary in the highest %/Qsector and is maximized with respect to occupancy, food consumption, and other uses of this area. As such, the MEI represents an individual with reasonable deviations from the average for the general population in the vicinity of PBNP. A comparison of the calculated doses to the 10 CFR 50, Appendix I design objectives is presented in Table 2-1. The conservatively calculated dose to the MEI is a very small fraction of the Appendix I design objective.

Table 2-1 Comparison of 2008 Liquid Effluent Calculated Doses to 10 CFR 50 Appendix I Design Objectives Annual Limit [mrem] Highest Total Calculated Dose [mrem] % of Design Objective 6 (whole body) 0.0065 0.11 %

20 (any organ) 0.0116 0.06 %

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2.2 2008 CirculatinQ Water Radionuclide Release Summary Radioactive liquid releases via the circulating water discharge are summarized by individual source and total curies released on a monthly basis and presented in Table 2-2. These releases are composed of processed waste, wastewater effluent, and blowdown from Units 1 and 2. The wastewater effluent consists of liquid from turbine hall sumps, plant well house backwashes, sewage treatment plant effluent, water treatment plant backwashes, and the Unit 1 and 2 facade sumps.

2.3 2008 Isotopic Composition of Circulating Water Discharges The isotopic composition of circulating water discharges during the current reporting period is presented in Table 2-3. The noble gases released in liquids are reported with the airborne releases in Section 3. The isotopic distribution shows slight change from 2007, with tritium (H-3) down slightly from 2006 and 2007 values and close to 2005 value. Tritium continues to be the major radionuclide released via liquid discharges.

2.4 Beach Drain System Releases Tritium Summary The quarterly results of monitoring the beach drains are presented in Table 2-4.

These six drains are sampled once a month. The total monthly flow is calculated assuming that the flow rate at the time of sampling persists for the whole month.

During 2008, no tritium was observed in any of the beach drains at the effluent LLDs used to detect and quantify tritium released from discreet volumes such as hold up tanks and waste distillate tanks. However, these drains are subject to ground water inleakage so they are sampled as part of the ground water monitoring program. Results range from not detected (52 +/- 96 pCi/I) to a high of 1103 +/- 124 pCi/I. Most results are in the 200 - 400 pCi/I range. Based on the environmental analyses of beach drain discharges and the associated monthly flows, 0.017 Ci of H-3 would be added to the 534 Ci released via discharges for which permits are used. Ground water monitoring results are presented in Part D of this Annual Monitoring Report.

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Table 2-2 Summary of Circulating Water Discharge January 1, 2008, through December 31, 2008 Total Annual Jan-Jan Feb Mar Apr May Jun Jun Jul Aug Sep Oct Nov Dec Total Total Activity Released (Ci)

Gamma Scan (+Fe-55) 1.13E-03 2.44E-03 1.60E-03 3.23E-03 2.48E-02 1.67E-03 3.49E-02 2.39E-03 4.40E-03 4.07E-03 3.73E-03 5.91E-02 1.17E-02 1.20E-01 Gross Alpha 0.00E+00 1.27E-13 2,02E-06 0.00E+00 6.55E-06 0.00E+00 8.57E-06 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 9.15E-06 0.OOE+00 2.56E-05 Tritium 1.29E+02 1.45E+02 5.63E+01 1.35E+01 4.02E+01 1.52E+01 3.99E+02 2.32E+01 3.57E+01 2.52E+01 2.34E+01 1.95E+01 7.98E+00 5.34E+02 Strontium (89190192) 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 4.37E-06 5.43E-07 4.91 E-06 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00 5.41E-06 0.00E+00 1.03E-05 Total Vol Released (gal)

Processed Waste 5.75E+04 9.44E+04 1.05E+05 8.30E+04 1.44E+05 3.34E+04 5.17E+05 3.36E+04 3.99E+04 5.03E+04 6.39E+04 1.10E+05 4.16E+04 8.57E+05 Waste Water Effluent* 4.78E+06 3.99E+06 4.49E+06 4.34E+06 3.54E+06 3.28E+06 2,44E+07 3.37E+06 3.99E+06 3.47E+06 3.91 E+06 4.41 E+06 5.10E+06 4.87E+07 UI SG Blowdown 1.17E+06 2.27E+06 2.60E+06 2.51E+06 2.62E+06 2.41E+06 1.36E+07 2.68E+06 2.67E+06 2.59E+06 5.22E+05 3.49E+06 5,12E+06 3.07E+07 U2 SG Blowdown 2.55E+06 2.47E+06 2.30E+06 2.00E+06 2.64E+06 2.31E+06 1.43E+07 2.36E+06 2.34E+06 2.43E+06 2.53E+06 2.16E+06 2.55E+06 2.86E+07 Total Gallons 8.56E+06 8.82E+06 9.50E+06 8.93E+06 8.95E+06 8.02E+06 5.28E+07 8.44E+06 9.04E+06 8.54E+06 7.02E+06 1.02E+07 1.28E+07 1.09E+08 Total cc 3.24E+10 3.34E+10 3.60E+10 3.38E+10 3.39E+10 3.04E+10 2.00E+11 3.19E+10 3.42E+10 3.23E+10 2,66E+10 3.86E+10 4.84E+10 4.12E+11 Dilution vol(cc)" 6.622+13 6.20E+13 6,62E+13 5.59E+13 9.60E+13 1.11E+14 4.57E+14 1.15E+14 1.15E+14 1.11E+14 6.78E+13 8.90E+13 6.68E+13 1.70E+15 Avg diluted discharge conc (pCi/cc)

Gamma Scan (+Fe-55) 1.71E-11 3.95E-11 2.42E-11 5.78E-11 2.58E-10 1.50E-11 2.08E-11 3.83E-11 3.67E-11 5.00E-12 6.64E-10 1.75E-10 Gross Alpha 0.00E+00 1.27E-13 3.05E-14 0.00E+00 6.82E-14 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.03E-13 0.00E+00 Tritium 1.95E-06 2.34E-06 8.50E-07 2.42E-07 4.19E-07 1.37E-07 2.02E-07 3.11E-07 2.27E-07 3.45E-07 2.20E-07 1.19E-07 Strontium (89/90192) 0.002+00 0.00E+00 0.00E+00 0.00E+00 4.55E-14 4.90E-15 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.08E-14 0.OOE+00 Max Batch Discharge Conc (ICi/cc)

Tritium 4,05E-05 3.94E-05 2.04E-05 9.22E-06 1.24E-05 1.31 E-05 1.33E-05 1.53E-05 9.85E-06 1.21 -05 7.74E-06 9.62E-06 Gamma Scan 1.16E-09 3.75E-09 1.36E-09 2.50E-09 9.99E-09 1.37E-09 1.42E-09 2.12E-09 2.22E-09 2.03E-09 1.77E-08 5.62E-09

The waste water effluent system replaced the Retention Pond which was taken out of service in September 2002.

- Circulating water discharge from both units.

Note: Dissolved noble gases detected in liquid effluents (e.g., Xe-133, Xe-135, etc.) are added to the atmospheric release summaries 6

Table 2-3 Isotopic Composition of Circulating Water Discharges (Ci)

January 1, 2008, through December 31, 2008 Total Total Nuclide Jan Feb Mar Apr May Jun Jan-Jun Jul Aug Sep Oct Nov Dec Jan-Dec H-3 1.29E+02 1.45E+02 5.63E+01 1.35E+01 4.02E+01 1.52E+01 3.99E+02 2.32E+01 3.57E+01 2.52E+01 2.34E+01 1.95E+01 7.98E+00 5.34E+02 F-18 0.00E+00 2.08E-04 3.53E-04 1.69E-04 2.64E-04 2.07E-04 1.20E-03 1.67E-04 1.59E-04 2.50E-05 1.65E-05 1.26E-04 2,81 E-04 1.97E-03 Cr-51 2.78E-05 2.29E-05 1.90E-05 2.87E-04 8.25E-03 1.13E-04 8,72E-03 1,66E-04 1.59E-04 1.58E-04 3.88E-05 1.01E-02 1.25E-03 2.06E-02 Mn-54 0.00E+00 6.70E-06 6.29E-06 2.21E-06 2.66E-04 9.42E-06 2.91E-04 1.22E-05 1.49E-05 9.57E-06 5.86E-07 2.44E-04 8.95E-05 6.62E-04 Fe-55 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 8.19E-04 0.00E+00 8.19E-04 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 2.95E-03 1.73E-03 5.50E-03 Fe-59 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 9.95E-05 0.00E+00 9.95E-05 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.80E-04 4,15E-05 5.21E-04 Co-57 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 5.83E-07 0.00E+00 5.83E-07 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00 7.17E-05 2.14E-05 2.72E-04 Co-58 9.73E-06 1.30E-04 4.75E-05 1.07E-04 2.82E-03 8.36E-05 3.20E-03 7.87E-05 7.11E-05 3.83E-05 3.25E-04 3.02E-02 3.90E-03 3.70E-02 Co-60 5.66E-05 4.97E-04 5.35E-04 4.48E-04 4.14E-03 4.25E-04 6.10E-03 4.62E-04 4.59E-04 3.06E-04 1.30E-04 2.43E-03 1.09E-03 1.10E-02 Zn-65 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.27E-04 0.00E+00 1.27E-04 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 2.83E-05 0.00E+00 1.55E-04 As-76 0.00E+00 0.00E+00 0.00E+00 7.09E-06 0.00E+00 0.00E+00 7.09E-06 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 7.09E-06 Sr-89 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Sr-90 0.00E+00 0.00E+00 0.00E+00 0.00E+00 4.37E-06 5.43E-07 4.91E-06 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.41E-06 0.00E+00 1.03E-05 Nb-95 0.00E+00 0.00E+00 3.01E-06 1.92E-05 1.34E-03 3.55E-05 1.40E-03 3.67E-05 4.20E-05 3.86E-05 1.05E-05 1.78E-03 6.09E-04 3.92E-03 Nb-97 7.14E-07 0.00E+00 2.45E-06 0.00E+00 4.65E-06 7.20E-06 1.50E-05 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.50E-05 Zr-95 0.00E+00 0.00E+00 0.00E+00 3.64E-06 7.13E-04 1.15E-05 7,28E-04 1.06E-05 1.78E-05 4.53E-06 0.00E+00 1.06E-03 3.04E-04 2.12E-03 Ag-110m 8.95E-06 5.83E-04 5.57E-05 1.17E-04 6.96E-04 1.63E-04 1.62E-03 2.33E-05 4.47E-05 5.75E-05 7.10E-05 3.00E-04 5.54E-04 2.67E-03 Sn-113 1.24E-06 4.55E-06 0.00E+00 5.24E-06 2.102-04 0.00E+00 2.21E-04 0.00E+00 5.65E-06 0.00E+00 0.00E+00 8.07E-04 1.87E-04 1.22E-03 Sn-117m 2.66E-05 4.42E-05 0.00E+00 2.42E-04 2.05E-03 4.67E-05 2.41E-03 1.31E-04 4.33E-05 1.45E-04 1.65E-04 1.22E-03 2.22E-04 4.34E-03 Sb-122 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Sb-124 0.00E+00 7.04E-06 0.00E+00 0.00E+00 3.01E-04 0.00E+00 3.08E-04 0.00E+00 0.00E+00 0.00E+00 6.51E-05 5.99E-04 2.24E-04 1.20E-03 Sb-125 9.99E-04 9.35E-04 5.65E-04 1.80E-03 2.71E-03 5.66E-04 7.58E-03 1.31E-03 3.39E-03 3.28E-03 2.89E-03 6.75E-03 1.21E-03 2.64E-02 1-131 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 9.32E-07 0.00E+00 0.00E+00 9.32E-07 1-132 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.10E-05 0.00E+00 0.00E+00 1.10E-05 1-133 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.53E-06 0.00E+00 0.00E+00 0.00E+00 1.53E-06 Te-132 0.00E+00 0.00E+00 0.00E+00 2.43E-06 0.00E+00 0.00E+00 2.43E-06 0.00E+00 0.00E+00 0.00E+00 1.14E-05 0.00E+00 0.00E+00 1.38E-05 Cs-137 0.00E+00 4.75E-06 9.76E-06 1.47E-05 5.82E-06 2.38E-06 3.74E-05 0.00E+00 0.00E+00 0.00E+00 8.29E-06 4.20E-05 5.85E-06 9.35E-05 Ru-103 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.05E-05 0.00E+00 2.05E-05 Te-131 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.002+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.002+00 0.002+00 0.002+00 Na-24 0.00E+00 0.00E+00 0.00E+00 0.00E+00 5.50E-06 0.00E+00 5.50E-06 0.002+00 0.002+00 0.002+00 0.002+00 0.00E+00 0.00E+00 5.50E-06 Note: The dissolved noble gases detected in liquid effluents (e.g., Xe-1 33, Xe-1 35, etc.) are added to the atmospheric release summaries.

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Table 2-4 Subsoil System Drains - Tritium Summary January 1, 2008, through December 31, 2008 S-1 S-3 S-7 S-8 S-9 S-10 1st Qtr H-3 (Ci) 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 Volume (gal) 6.22E+06 1.24E+06 3.35E+05 4.46E+04 4.46E+04 4.46+05 2nd Qtr H-3 (Ci) O.OOE+00 O.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 Volume (gal) 1.17E+06 5.12E+05 0.OOE+00 5.18E+05 0.OOE+00 0.OOE+00 3rd Qtr H-3 (Ci) 0.OOE+00 Q.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 Volume (gal) 3.76E+05 2.47E+05 0.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 4th Qtr H-3 (Ci) 0.O0E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 Volume (gal) 1.44E+05 8.86E+04 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 2.6 Land ADDlication of Sewaae Sludae The Wisconsin Department of Natural Resources has approved the disposal of PBNP sewage by land application on various NextEra Energy Point Beach properties surrounding the plant. This sewage sludge, which may contain trace amounts of radionuclides, is to be applied in accordance with methodologies approved by the NRC on January 13, 1988, pursuant to 10 CFR 20.302(a). The approved methodology requires analyses prior to every disposal. Based upon an investigation of the source of the radionuclides, a combination of engineering modifications and administrative controls has eliminated plant generated radiological inputs to the sewage. This was verified by sludge analyses using the environmental lower level of detection (LLD) criteria. No byproduct radionuclides were found in the sludge after the controls and modifications were completed. Sludge is routinely monitored and no radionuclides attributable to PBNP have been found.

There was no disposal of sewage by land application during 2008. All disposals were done at the Manitowoc Sewage Treatment Plant.

8

3.0 RADIOACTIVE AIRBORNE RELEASES The release paths to the environment contributing to radioactive airborne release totals during this reporting period were the Auxiliary Building Vent Stack, the Drumming Area Vent Stack, the Letdown Gas Stripper, the Unit 1 Containment Purge Stack and the Unit 2 Containment Purge Stack. A gaseous radioactive effluent treatment system in conjunction with administrative controls is used to minimize the impact on the environment from the airborne releases and maintain doses to the public ALARA.

3.1 Doses from Airborne Effluent Doses from airborne effluent are calculated for the maximum exposed individual (MEI) following the methodology contained in the PBNP ODCM. These calculated doses use parameters such as the amount of radioactive material released, the concentration at and beyond the site boundary, the average site weather conditions, the locations of the exposure pathways (e.g., cow milk, vegetable gardens and residences), and usage factors (e.g., breathing rates, food consumption). In addition to the MEI doses, the energy deposited in the air by noble gas beta particles and gamma rays is calculated and compared to the corresponding Appendix I design objectives. A comparison of the annual Appendix I design objectives for atmospheric effluents to the highest organ dose and the noble gas doses calculated using ODCM methodology is listed in Table 3-1.

The doses demonstrate that releases from PBNP to the atmosphere continue to be ALARA.

3.2 Radioactive Airborne Release Summary Radioactivity released in airborne effluents for 2008 are summarized in Table 3-2.

3.3 Isotopic Airborne Releases The monthly isotopic airborne releases for 2008, from which the airborne doses were calculated, are presented in Table 3-3. When both the equipment hatch and the Elevation 66' hatch are open during an outage, there is a measurable, convective flow out the upper hatch. Because this air is not filtered, whatever is measured in containment air (particulates, tritium, noble gases, radioiodine) is assumed to be carried out the hatch, through the facade, and into the environment thereby contributing to the effluent and the calculated dose.

9

Table 3-1 Comparison of 2008 Airborne Effluent Calculated Doses to 10 CFR 50 Appendix I Design Objectives Annual Appendix I Design January-December Percent of Appendix I Category Objective Calculated Dose Design Objective Particulate 30 mrem/organ 0.0254 mrem 0.088 Noble gas 40 mrad (beta air) 0.00013 mrad 0.0003 Noble gas 20 mrad (gamma air) 0.00026 mrad 0.0013 Noble gas 30 mrem/skin 0.00039 mrem 0.0012 Noble gas 10 mrem (whole body) 0.00025 mrem 0.0025 Table 3-2 Radioactive Airborne Effluent Release Summary January 1, 2008, through December 31, 2008 Total Jan Feb Mar Apr May Jun J-Jun Jul Aug Sep Oct Nov Dec Total Total NG from Liq (Ci) 2.39E-03 4.72E-03 7.16E-03 5.19E-04 4.21E-03 5372E-05 1.91E-02 8.76E-05 8.76E-05 8.09E-05 6.09E-04 0.OOE+00 1.05E-04 2.00E-02 Total Noble Gas (Ci)l 6.48E-02 8.12E-02 3.79E-01 4.66E-02 8.13E-02 4.99E-02 7.03E-01 5.30E-02 4.27E-02 4.46E-02 1.04E-01 7.03E-02 8.78E-02 1.11E+00 Total Radioiodines (Ci) 0.OOE+00 0.00E+00 0.00E+00 3.20E-06 0.00E+00 0.OOE+00 3.20E-06 0.00E+00 0.OOE+00 0.00E+00 2.1OE-07 0.00E+00 0.OOE+00 3.41E-06 Total Particulate (Ci)2 0.00E+00 0.OOE+00 0.OOE+00 1.99E-05 1.43E-07 3,88E-06 2.39E-05 0.OOE+00 0.00E+00 0.OOE+00 4.60E-07 5.68E-07 0.OOE+00 2.50E-05 Alpha (Ci) 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 Strontium(Ci) 0,00E+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 All other beta + gamma (Ci) 0.OOE+00 0.OOE+00 0.00E+00 1.99E-05 1.43E-07 3.88E-06 2.39E-05 0.OOE+00 0.OOE+00 0.OOE+00 4.60E-07 5.68E-07 0.00E+00 2.50E-05 Total Tritium (Ci) 6.37E+00 4.42E+00 4.84E+00 8.81E+00 3.17E+00 2.70E+00 3.03E+01 2.70E+00 4.68E+00 4.32E+00 5.83E+00 5.22E+00 1.11E+01 6.42E+01 Max NG WrlyRel.(Ci/sec) 5.68E-08 2.19E-06 4.64E-07 4,14E-08 1.18E-07 6.49E-08 3.82E-08 3.71E-08 5.55E-08 3.68E-08 6.39E-08 5.89E-07 Total noble gas (airborne + liquid releases).

Total Particulate is the sum of alpha, strontium, and others. It does not include radioiodines or F-18. F-18 and other airborne particulates with half-lives less than 8 days are not considered for dose calculations. Airborne radioiodines only include 1-131 and 1-133.

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TABLE 3-3 Isotopic Composition of Airborne Releases January 1, 2008, through December 31, 2008 Jan Feb Mar Apr May Jun Semi- Jul Aug Sep Oct Nov Dec Total Nuclide (Ci) (Ci) (Ci) (Ci) (Ci) (Ci) Annual (Ci) (Ci) (Ci) (Ci) (Ci) (Ci) (Ci)

H-3 6.37E+00 4.42E+00 4.84E+00 8.81E+00 3.17E+00 2.70E+00 3.03E+01 2.70E+00 4.68E+00 4.32E+00 5.83E+00 5.22E+00 1.11E+01 6.42E+01 Ar-41 4.10E-02 4.86E-02 6.07E-02 2.05E-02 3.46E-02 3.56E-02 2.41E-01 4.52E-02 3.69E-02 3.69E-02 2.32E-02 5.17E-02 6.30E-02 4.98E-01 Kr-85 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 1.37E-03 1.37E-03 Kr-85m 0.OOE+00 1.15E-04 0.OOE+00 0.00E+00 0.00E+00 0.OOE+00 1.15E-04 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0,00E+00 7.32E-04 8.47E-04 Kr-87 0.00E+00 2.38E-04 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 2.38E-04 0.OOE+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 1.86E-03 2.10E-03 Kr-88. 0.OOE+00 7.94E-04 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 7.94E-04 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 4.06E-03 1.65E-03 6.50E-03 Xe-131m 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 1.67E-03 3.02E-05 1.70E-03 Xe-133 2.35E-02 2.82E-02 4.93E-02 2.54E-02 4.60E-02 1.37E-02 1.86E-01 7.28E-03 5.66E-03 6.94E-03 8.10E-02 1.28E-02 1.68E-03 3.01E-01 Xe-133m 2.02E-04 0.00E+00 1.05E-04 1.19E-05 5.57E-06 0.OOE+00 3.24E-04 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 7.48E-06 3.32E-04 Xe-135 1.00E-04 1.78E-03 2.68E-01 7.56E-04 7.32E-04 4.21E-04 2.72E-01 4.93E-04 2.12E-04 8.04E-04 8.17E-05 0.OOE+00 3.74E-03 2.77E-01 Xe-135m 0.00E+00 4.03E-04 0.OOE+00 0.OOE+0O 0.OOE+00 1.29E-04 5.32E-04 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 6.68E-05 3.45E-03 4.05E-03 Xe-138 0.OOE+00 1.13E-03 0.0OE+00 0.00E+00 0.00E+00 0.00E+00 1.13E-03 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 1.03E-02 1.14E-02 Cr-51 0.OOE+00 0.OOE+00 0.OOE+00 9.36E-06 0.00E+00 0.OOE+00 9.36E-06 0.OOE+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 9.36E-06 Mn-54 0.00E+00 0.OOE+00 0.00E+00 2.23E-07 0.OOE+00 0.00E+00 2.23E-07 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 2.23E-07 Co-57 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.O0E+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 Co-58 0.00E+00 0.OOE+00 0.00E+00 4.91 E-06 1.43E-07 0.00E+00 5.05E-06 0.00E+00 0.OOE+00 0.OOE+00 2.87E-07 1.99E-07 0.00E+00 5.54E-06 Co-60 0.00E+00 0.00E+00 0.00E+00 8.64E-06 0.00E+00 0o.00E+00 8.64E-06 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 8.64E-06 Nb-95 0.00E+00 0.OOE+00 0.00E+00 2.93E-06 0.00E+00 0.00E+00 2.93E-06 0.00E+00 0.00E+00 O.OOE+00 3.78E-16 2.23E-07 0.OOE+00 3.15E-06 Zr-95 0.00E+00 0.00E+00 0.OOE+00 1.58E-06 0.00E+00 0.OOE+00 1.58E-06 0.00E+00 0.00+E00 0.00E+00 0.00E+00 9.03E-08 0.00E+00 1.67E-06 Ag-110m 0.00E+00 0.OOE+00 O.OOE+00 O.OOE+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 O.OOE+0O 0.OOE+00 0.00E+00 Sn-113 0.00E+00 0.00E+00 0.OOE+00 1.91E-07 0.00E+00 0.OOE+00 1.91E-07 0.00E+00 0.00E+00 0,00E+00 0.00E+00 0.00E+00 0.00E+00 1.91E-07 Sb-124 0.OOE+00 0.00E+00 0.00E+00 5.73E-07 0.00E+00 0.00E+00 5.73E-07 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 5.73E-07 Sb-125 O.OOE+00 0.OOE+00 0.OOE+00 2.54E-08 0.00E+00 0.00E+00 2.54E-08 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 2.54E-08 1-131 0.00E+00 0.00E+00 0.00E+00 3.20E-06 0.OOE+00 0.OOE+00 3.20E-06 0.OOE+00 0.OOE+00 0.OOE+00 2.10E-07 0.OOE+00 0.OOE+00 3.41E-06 1-133 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Cs-137 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 1.07E-07 2.57E-08 0.00E+00 1.33E-07 Sn-117m 0.00E+00 0.00E+00 O.OOE+00 1.14E-07 0.00E+00 0.00E+00 1.14E-07 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 1.142-07 Zn-65 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.57E-08 0.00E+00 0.002E+0 6.572-08 Note: The Noble Gases listed above include the liquid contribution 11

4.0 RADIOACTIVE SOLID WASTE SHIPMENTS 4.1 Tvyes. Volumes. and Activity of ShiDped Solid Waste The following types, volumes, and activity of solid waste were shipped from PBNP for offsite disposal or burial during 2008. There was no type C shipments and no irradiated fuel was shipped offsite. The volume, activity, and type of waste are listed in Table 4-1.

Table 4-1 Quantities and Types of Waste Shipped from PBNP Type of Waste Quantity Activity A. Spent resins, filter sludge, evaporator bottoms, etc. 7.50 m3 73.220 Ci 263.20 ftW B. Dry compressible waste, contaminated equipment, etc. 224.60' m3 44.478 Ci 7,930.60 fte C. Irradiated components, control rods, etc. N/A N/A D. Other (Steam Generator Chemical Cleaning Solvent) 151.70 m 3 0.001 Ci 1__ 1 5,356.16 ftW 4.2 Maior Nuclide Composition (by Type of Waste)

The major radionuclide content of the 2008 solid waste was determined by gamma isotopic analysis and the application of scaling factors for certain indicator radionuclides based on the measured isotopic content of representative waste stream samples. The estimated isotopic content is presented in Table 4-2.

12

Table 4-2 2008 Estimated Solid Waste Major Radionuclide Composition TYPE A TYPE B TYPE C TYPE D PretPretPercent Percent Nuclide Percent Nuclide Percent Nuclide Nuclide Abundance Abundance Abundance Abundance Ni-63 70.6% Co-60 56.54% Fe-55 61.76%

Co-60 16.0% Ni-63 32.51% Co-60 24.02%

Fe-55 4.5% Fe-55 7.73% Zn-65 12.19%

H-3 3.1% Sb-125 1.58% Ce-144 1.62%

Sb-125 1.9% Ag-110m 0.46% Cs-137 0.41%

Cs-137 1.2% Nb-95 0.32%

Mn-54 0.9% Cs-137 0.25%

Ni-59 0.7% Mn-54 0.20%

Co-58 0.4% Ru-106 0.09%

Co-57 0.3% Co-58 0.09%

Pu-241 0.2% Zr-95 0.05%

Ag-110m 0.1% H-3 0.05%

Ce-144 0.1% Tc-99 0.04%

Sr-90 0.0% Zn-65 0.02%

Tc-99 0.0% C-14 0.01%

Cm-243 0.0% Ce-144 0.01%

Am-241 0.0% Pu-241 0.01%

C-14 0.0% Am-241 0.00%

Pu-239 0.0% Sr-90 0.00%

Pu-238 0.0% Ag-108m 0.00%

Sr-89 0.0% Ni-59 0.00%

Cm-242 0.0% Co-57 0.00%

Pu-239 0.00%

Sr-89 0.00%

Cm-243 0.00%

Pu-238 0.00%

Cm-244 0.00%

Cs-134 0.00%

Pu-240 0.00%

Cm-242 0.00%

Cr-51 0.00%

U-235 0.00%

Nb-94 0.00%

Np-237

_ 0.00%

Sn-I 13 0.00%

Sb-124 0.00%

13

4.3 Solid Waste Disposition There were sixteen (16) solid waste shipments from PBNP during 2008. The dates and destinations are shown in Table 4-3. There were four (4) separate shipments on 11/21/08 and on 12/1/08.

Table 4-3 2008 PBNP Radioactive Waste Shipments Date Destination Total Volume (ft3) 02/20/08 Oak Ridge, TN 183.2 03/03/08 Erwin, TN 80.0 04/01/08 Oak Ridge, TN 2160.0 04/24/08 Oak Ridge, TN 1720.0 06/24/08 Barnwell 120.3 06/27/08 Barnwell 120.3 09/15/08 Oak Ridge, TN 2360.0 10/29/08 Oak Ridge, TN 1450.0 11/21/2008 (4) Richland, WA 2909.0 12/1/2008 (4) Richland, WA 2447.2 14

5.0 NONRADIOACTIVE CHEMICAL RELEASES 5.1 Scheduled Chemical Waste Releases Scheduled chemical waste releases to the circulating water system from January 1, 2008, to June 30, 2008, included 3.59E+06 gallons of neutralized wastewater. The wastewater contained 1.74E+02 pounds of suspended solids and 4.51 E+03 pounds of dissolved solids.

Scheduled chemical waste releases to the circulating water system from July 1, 2008, to December 31, 2008, included 4.32E+06 gallons of neutralized wastewater. The wastewater contained 3.OE+01 pounds of suspended solids and 2.92E+01 pounds of dissolved solids.

Scheduled chemical waste releases are based on the average analytical results obtained from sampling a representative number of neutralizing tanks.

5.2 Miscellaneous Chemical Waste Releases Miscellaneous chemical waste releases from the wastewater effluent (based on effluent analyses) to the circulating water for January 1, 2008, to June 30, 2008, included 2.43E+07 gallons of clarified wastewater. The wastewater contained 2.69E+03 pounds of suspended solids.

Miscellaneous chemical waste releases from the Wastewater Effluent (based on effluent analyses) to the circulating water for July 1, 2008, to December 31, 2008, included 2.44E+07 gallons of clarified wastewater. The wastewater contained 3.14E+03 pounds of suspended solids.

Miscellaneous chemical waste released directly to the circulating water, based on amount of chemicals used from January 1, 2008, to June 30, 2008, included 2.14E+05 pounds of sodium bisulfite and 1.80E+05 pounds of sodium hypochlorite.

Miscellaneous chemical waste released directly to the circulating water, based on amount of chemicals used from July 1, 2008, to December 31, 2008, included 2.72E+05 pounds of sodium bisulfite and 3.21 E+05 pounds of sodium hypochlorite.

15

6.0 CIRCULATING WATER SYSTEM OPERATION The circulating water system operation during this reporting period for periods of plant operation is described in Table 6-1.

Table 6-1 Circulating Water System Operation for 2008 January 1, 2008, through June 30, 2008 UNIT JAN FEB MAR APR* MAY* JUN Average Volume Cooling 1 282.2 282.2 282.5 433.2 480.5 487.1 Water Discharge [million gal/day]** -2 282.2 282.2 282.5 252.6 417.2 489.7 Average Cooling Water 1 36.4 37.1 37.3 42.4 48.1 48.9 Intake Temperature [OF] 2 36.3 37.7 38.3 42.2 49.1 49.9 Average Cooling Water 1 52.9 64.7 69.0 64.8 66.9 67.7 Discharge Temperature [OF] 2 70.6 71.5 70.5 63.7 64.1 68. 1 Average Ambient Lake Temperature [OF] 33.2 32.9 33.4 38.4 44.0 44.7

Unit 1 outage April 5, 2008 - May 5, 2008.

- For days with cooling water discharge flow.

Table 6-1 (continued)

Circulating Water System Operation for 2008 July 1, 2008, through December 31, 2008

_________________UNIT JUL AUG SEP OCT* NOV* DEC Average Volume Cooling 1 489.6 489.6 487.0 358.4 394.8 284.5_

Water Discharge [million gal/dayl** 2 489.6 489.6 487.3 495.4 495.3 284.5 Average Cooling Water 1 52.8 68.5 60.2 59.0 42.1 36.9 Intake Temperature [OF] 2 53.9 69.6 61.2 52.4 43.1 38.1 Average Cooling Water 1 71.8 88.0 79.5 70.0 55.5 68.4 Discharge Temperature [OF] 2 72.4 93.6 85.7 76.6 66.3 76.4 Average Ambient Lake Temperature [OF) _ 55.7 65.5 60.6 49.6 45.0 33.61

Unit 2 outage October 4, 2008 - November 12, 2008

- For days with cooling water discharge flow.

16

Part B Miscellaneous Reporting Requirements 7.0 ADDITIONAL REPORTING REQUIREMENTS 7.1 Revisions to the PBNP Effluent and Environmental Programs The Offsite Dose Calculation Manual (ODCM) was not revised in 2008. The Environmental Manual (EM) was revised in November 2008 to identify specific' valves used for sampling the site well (Enclosure 2).

7.2 Inter-Laboratory Comparison Program Environmental, Inc, Midwest Laboratory, the analytical laboratory contracted to perform the radioanalyses of the PBNP environmental samples, participated in the Department of Energy's Mixed Analyte Performance Evaluation Program (MAPEP) as well as in the interlaboratory comparison studies administered by Environmental Resources Associates (ERA) during 2008. The ERA environmental crosscheck program replaces the Environmental Measurements Laboratory (EML) Quality Assessment Program which was discontinued. The results of these comparisons can be found in Appendix A of this Annual Monitoring Report (AMR).

7.3 Special Circumstances No special circumstances report regarding operation of the explosive gas monitor for the waste gas holdup system was needed during 2008.

17

RADIOLOGICAL ENVIRONMENTAL Part C MONITORING M

8.0 INTRODUCTION

The objective of the PBNP Radiological Environmental Monitoring Program (REMP) is to determine whether the operation of PBNP or the ISFSI has radiologically impacted the environment. To this end, the REMP collects and analyzes air, water, milk, soil, vegetation, and fish samples for radionuclides and uses TLDs to determine the ambient radiation background. These measurements also serve as a check of the efficacy of PBNP effluent controls. The REMP fulfills the requirements of 10 CFR 20.1302, PBNP General Design Criterion (GDC) 17, GDC 64 of Appendix A to 10 CFR 50 and Sections IV.B.2 and IV.B.3 of Appendix I to 10 CFR 50 for the operation of the plant.

Therefore, the REMP collects samples from various environmental media in order to provide data on measurable levels of radiation and radioactive materials in the principal pathways of environmental exposure.

A subset of the PBNP REMP samples, consisting of air, soil and vegetation also fulfills 10 CFR 72.44(d)(2) for operation of the ISFSI. Additionally, thermoluminescent dosimeters (TLDs) provide the means to measure changes in the ambient environmental radiation levels at sites near the ISFSI and at the PBNP site boundary to ensure that radiation levels from the ISFSI are maintained within the dose limits of 10 CFR 72.104.

Because the ISFSI is within the PBNP site boundary, radiation doses from PBNP and the ISFSI, combined, must be used to assess compliance with 10 CFR 72.122 and 40 CFR 190. Therefore; radiological environmental monitoring for the ISFSI is provided by selected sampling sites, which are part of the PBNP REMP.

For the aquatic environment, the samples include water as well as the biological integrators, such as fish and filamentous algae. As a result of their migratory behavior, fish are wide area integrators. In contrast, the filamentous algae periphyton is attached to shoreline rocks and concentrate nuclides from the water flowing by their point of attachment. Grab samples of lake water provide a snapshot of radionuclide concentrations at the time the sample is taken; whereas analysis of fish and filamentous algae yield concentrations integrated over time.

The air-grass-cow-milk exposure pathway unites the terrestrial and atmospheric environments. This pathway is important because of the many dairy farms around PBNP. Therefore, the REMP includes samples of air, general grasses and milk from the PBNP environs. An annual land use survey is conducted to determine whether the assumptions on the location of dairy cattle remain conservative with respect to dose calculations for PBNP effluents. The dose calculations assume that the dairy cattle are located at the south site boundary, the highest depositional sector. In addition, soil samples are collected and analyzed in order to monitor the potential for long-term buildup of radionuclides in the vicinity of PBNP.

18

For the measurement of ambient environmental radiation levels that may be affected by direct radiation from PBNP or by noble gas effluents, the REMP employs a series of TLDs situated around PBNP and the ISFSI.

9.0 PROGRAM DESCRIPTION 9.1 Results Reporting Convention The vendor used by PBNP to analyze the environmental samples is directed to report analysis results as measured by a detector, which can meet the required lower limit of detection (LLD) as specified in Table 2-2 of the Environmental Manual for each sample. The report provided by the vendor (see Appendix 1) contains values, which can be either negative, positive or zero plus/minus the two sigma counting uncertainty, which provides the 95% confidence level for the measured value.

The LLD is an a prioriconcentration value that specifies the performance capability of the counting system used in the analyses of the REMP samples.

The parameters for the a priori LLD are chosen such that only a five percent chance exists of falsely concluding a specific radionuclide is present when it is not present at the specified LLD.. Based on detector efficiency and average background activity, the time needed to count the sample in order to achieve the desired LLD depends upon the sample size. Hence, the desired LLD may be achieved by adjusting various parameters. When a suite of radionuclides is required to be quantified in an environmental sample such as lake water, the count time used is that required to achieve the LLD for the radionuclide with the longest counting time. Therefore, in fulfilling the requirement for the most difficult to achieve radionuclide LLD, the probability of detecting the other radionuclides is increased because the counting time used is longer than that required to achieve the remaining radionuclide LLDs.

The REMP results are reported as averages of the measurements made throughout the calendar year plus/minus the associated standard deviation. If all of the net sample concentrations are equal to or less than zero, the result is reported as "Not Detectable" (ND), indicating no detectable level of activity present in the sample. If all of the net sample concentrations indicate a positive result statistically greater than zero, all of the data reported are used to generate the reported statistics. As a result of the statistical nature of radioactive decay, when the radionuclide of interest is not present in the sample, negative and positive results centered about zero will be seen. Excluding validly measured concentrations artificially inflates the calculated average value, whether negative or as small positive values below the LLD. Therefore, all generated data are used to calculate the statistical values (i.e., average, standard deviation) presented in this report. The calculated average may be a negative number.

Just because a result is statistically greater than zero does not necessarily indicate that the radionuclide is present in an environmental sample. False positives may be obtained by fluctuations in background during the counting process. This phenomenon is most prevalent for concentrations at or near the LLD. Therefore, other information such as PBNP emissions records and 19

radionuclide half-life must be used to evaluate whether the result is real or a statistical artifact.

In interpreting the data, effects due to the plant must be distinguished from those due to other sources. A key interpretive aid in assessment of these effects is the design of the PBNP REMP, which is based upon the indicator-control concept.

Most types of samples are collected at both indicator locations and at control locations. A plant effect would be indicated if the radiation level at an indicator location was significantly larger than that at the control location. The difference would have to be greater than could be accounted for by typical fluctuation in radiation levels arising from other sources.

9.2 Samplinq Parameters Samples are collected and analyzed at the frequency indicated in Table 9-1 from the locations described in Table 9-2 and shown in Figures 9-1, 9-2, and 9-3. (The latter two figures show sampling locations not shown in preceding figures due to space limitations. The location of the former retention pond, retired and remediated to NRC unrestricted access criteria, is indicated in Figure 9-3). The list of PBNP REMP sampling sites used to determine environmental impact around the ISFSI is found in Table 9-3. The minimum acceptable sample size is found in Table 9-4. In addition, Table 9-1 indicates the collection and analysis frequency of the ISFSI fence TLDs.

9.3 Deviations from Required Collection Frequency Deviations from the collection frequency given in Table 9-1 are allowed because of hazardous conditions, automatic sampler malfunction, seasonal unavailability, and other legitimate reasons (Section 2.2.6 of the Environmental Manual).

Table 9-5 lists the deviations from the scheduled sampling frequency that occurred during the reporting period.

9.4 Assistance to the State of Wisconsin The Radiation Protection Unit of the Wisconsin Department of Health Services maintains a radiological environmental monitoring program to confirm the results from the PBNP REMP. PBNP personnel also collect certain environmental samples (Table 9-6) for the State from sites that are near PBNP sampling sites, or are co-located.

9.5 Proqram Modifications No changes were made to the REMP during 2008. Changes to the Ground Water Monitoring Program are discussed in Part D.

20

Table 9-1 PBNP REMP Sample Analysis and Frequency Sample Type Sample Codes Analyses Frequency Environmental Radiation E-01, -02, -03, -04, -05 TLD Quarterly Exposure -06, -07, -08, -09, -12

-14, -15, -16, -17, -18,

-20, -22, -23, -24, -25,

-26, -27, -28, -29, -30,

-31, -32, -38, -39, -TC Vegetation E-01, -02, -03, -04, -06, Gross Beta 3x/yr as available

-08, -09, -20, Gamma Isotopic Analysis Algae E-05, -12 Gross Beta 3x/yr as available Gamma Isotopic Analysis Fish E-13 Gross Beta 3x/yr as available Gamma Isotopic Analysis (Analysis of edible portions only)

Well Water E-10 Gross Beta, H-3 Quarterly Sr-89, 90, 1-131 Gamma Isotopic Analysis (on total solids)

Lake Water E-01, -05, -06, -33 Gross Beta Monthly / Quarterly composite of monthly collections 1-131 Monthly Gamma Isotopic Analysis Monthly (on total solids)

Milk E-11, -40, -21 Sr-89, 90 Monthly 1-131 Gamma Isotopic Analysis Air Filters E-01, -02, -03, -04, Gross Beta Weekly (particulate)

-08, -20 1-131 Weekly (charcoal)

Gamma Isotopic Analysis Quarterly (on composite particulate filters)

Soil E-01, -02, -03, -04, Gross Beta 2x/yr

-06, -08, -09, -20, Gamma Isotopic Analysis Shoreline Sediment E-01, -05, -06, -12, -33, Gross Beta 2x/yr Gamma Isotopic Analysis ISFSI Ambient North, East, South, Radiation West TLD Quarterly Exposure Fence Sections 21

Table 9-2 PBNP REMP Sampling Locations Location Code Location Description E-01 Primary Meteorological Tower South of the Plant E-02 Site Boundary Control Center - East Side of Building E-03 Tapawingo Road, about 0.4 Miles West of Lakeshore Road E-04 North Boundary E-05 Two Creeks Park Point Beach State Park - Coast Guard Station; TLD located South of the Lighthouse on E-06 Telephone pole E-07 WPSC Substation on County V, about 0.5 Miles West of Hwy 42 E-08 G.J. Francar Property at Southeast Corner of the Intersection of Cty. B and Zander Road E-09 Nature Conservancy E-10 PBNP Site Well E-1 I Dairy Farm about 3.75 Miles West of Site E-12 Discharge Flume/Pier E-13 Pumphouse E-14 South Boundary, about 0.2 miles East of Site Boundary Control Center E-15 Southwest Corner of Site E-1 6 WSW, Hwy 42, a residence about 0.25 miles North of Nuclear Road E-17 North of Mishicot, Cty. B and Assman Road, Northeast Corner of Intersection E-1 8 Northwest of Two Creeks at Zander and Tannery Roads E-20 Reference Location, 17 miles Southwest, at Silver Lake College E-21 Local Dairy Farm just South of Site on Lakeshore and Irish Roads E-22 West Side of Hwy 42, about 0.25 miles North of Johanek Road E-23 Greenfield Lane, about 4.5 Miles South of Site, 0.5 Miles East of Hwy 42 E-24 North Side of County Rt. V, near intersection of Saxonburg Road E-25 South Side of County Rt. BB, about 0.5 miles West of Norman Road E-26 804 Tapawingo Road, about 0.4 miles East of Cty. B, North Side of Road E-27 Intersection of Saxonburg and Nuclear Roads, Southwest Corner, about 4 Miles WSW E-28 TLD site on Western most pole between the 2nd and 3d parking lots.

E-29 Area of North Meteorological Tower.

E-30 NE corner at Intersection of Tapawingo and Lakeshore Roads.

E-31 On utility pole North side of Tapawingo Road closest to the gate at the West property line.

E-32 On a tree located at the junction of property lines, as indicated by trees and shrubs, about 500 feet East of the West gate on Tapawingo Road and about 1200 feet south of Tapawingo Road. The location is almost under the power lines between the blue and gray transmission towers.

Lake Michigan shoreline accessed from the SE corner of KNPP parking lot. Sample South of E-33 creek.

E-38 Tree located at the West end of the area previously containing the Retention Pond.

E-39 Tree located at the East end of the area previously containing the Retention Pond.

E-40 Local Dairy Farm, W side of Hwy 42, about 1.8 miles north of the Nuclear Rd intersection E-TC Transportation Control; Reserved for TLDs 22

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.... W -MILE 0rKILOMETER MAY2005 Figure 9-1 PBNP REMP Sampling Sites 23

FIGURE2-1b SITE MAP POINT BEACH NUCLEAR PLANT

~S I TE BODrARY 0I amGII 1600 I I I F E 4w 20 2=~

ENVIRONMENTAL MONITORING STATIONS

TLD 00 TLD & AIR AL& OTHER COS FILE 10T48 Figure 9-2 Map of REMP Sampling Sites Located Around PBNP 24

FIGUR 2-IC C-29 LAKE MICH [AN IJffERuSTI~wf S1Ri.W 1~,

is 1,

L OODS Figure 9-3 Enhanced Map Showing REMP Sampling Sites Closest to PBNP 25

Table 9-3 ISFSI Sampling Sites Ambient Radiation Monitoring Soil, Vegetation (TLD) and Airborne Monitoring E-03 E-02 E-28 E-03 E-29 E-04 E-30 E-31 E-32 Table 9-4 Minimum Acceptable Sample Size Sample Type Size Vegetation 100-1000 grams Lake Water 8 liters 250 m3 Air Filters (volume of air)

Well Water 8 liters Milk 8 liters Algae 100-1000 grams Fish (edible portions) 1000 grams Soil 500-1000 grams Shoreline Sediment 500-1000 grams 26

Table 9-5 Deviations from Scheduled Sampling and Frequency Sample Location Collection Date Reason for not conducting Plans for Preventing Type REMP as required Recurrence E-02 03/19/2008 Pump Not Running GFI failure, replace GFI E-02 09/03/2008 Equipment failure Replace pump AP/AIE-03 1230/2008 Power loss Restore power E-04 06/1920/08 Power loss Restore power E-01 12/17/08 Lake Frozen Samples Collected Next Month After Thaw Lake Water E-06 12/17/08 Lake Frozen Samples Collected Next I 0 Le Month After Thaw Table 9-6 Sample Collections for State of Wisconsin Sample Type Location Frequency Lake Water E-01 Weekly, Composited Monthly Air Filters E-07 Weekly E-08 Fish E-13 Quarterly, As Available Precipitation E-04 Twice a month, E-08 As Available Milk E-1 1 Monthly E-19 Well Water E-1 0 Twice per year 27

9.6 Analytical Parameters The types of analyses and their frequencies are given in Table 9-1. The LLDs for the various analyses are found in the Section 10 (Table 10-1) with the summary of the REMP results. All environmental LLDs listed in Table 2-2 of the Environmental Manual (also in Table 10-1) were achieved during 2008.

9.7 Description of Analytical Parameters in Table 9-1 9.7.1 Gamma isotopic analysis Gamma isotopic analysis consists of a computerized scan of the gamma ray spectrum from 80 keV to 2048 keV. Specifically included in the scan are Mn-54, Fe-59, Co-58, Co-60, Zr-95, Nb-95, Ru-103, Ru-106,1-131, Ba-La-140, Cs-134, Cs-137, Ce-141, and Ce-144.

However, other detected nuclear power plant produced radionuclides also are noted. The above radionuclides detected by gamma isotopic analysis are decay corrected to the time of collection. Frequently detected, but not normally reported in this Annual Monitoring Report, are the naturally occurring radionuclides Ra-226, Bi-214, Pb-212, TI-208, Ac-228, Be-7, and K-40.

9.7.2 Gross Beta Analysis Gross beta analysis is a non-specific analysis that consists of measuring the total beta activity of the sample. No individual radionuclides are identifiable by this method. Gross beta analysis is a quick method of screening samples for the presence of elevated activity that may require additional, immediate analyses.

9.7.3 Water Samples Water samples include both Lake Michigan and well water. The Lake Michigan samples are collected along the shoreline at two locations north and two locations south of PBNP. The well water is sampled from the on-site PBNP well. Gross beta and gamma isotopic analytical results for water are obtained by measurements on the solids remaining after evaporation of the unfiltered sample to dryness. Hence, the results are indicated as "on total solids" in Table 10-1.

9.7.4 Air Samples Particulate air filters are allowed to decay at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months before gross beta measurements are made in order for naturally occurring radionuclides to become a negligible part of the total activity. Gross beta measurements serve as a quick check for any unexpected activity that may require immediate investigation. Quarterly composites of the particulate air filters are analyzed for long-lived radionuclides such as Cs-1 34 and Cs-137. Charcoal canisters for radioiodine are counted as soon as possible so the 1-131 will undergo only minimal decay prior to 28

analyses. The weekly charcoal canisters are screened for 1-131 by counting them at the same time to achieve a lower LLD. If a positive result is obtained, each canister is counted individually.

To ensure that the air sampling pumps are operating satisfactorily, a gross leak check is performed weekly. The pumps are changed out annually for calibration and maintenance beyond what can be accomplished in the field.

9.7.5 Vegetation Vegetation samples consist predominantly of green, growing plant material (grasses and weeds most likely to be eaten by cattle if they were present at the sampling site). Care is taken not to include dirt associated with roots by cutting the vegetation off above the soil line.

9.7.6 Environmental Radiation Exposure The 2008 environmental radiation exposure measurements were made using TLD cards. The TLD card is a small passive detector which integrates radiation exposure. Each TLD consists of a Teflon sheet coated with a crystalline, phosphorus material (calcium sulfate containing dysprosium) which absorbs the gamma ray energy deposited in them. Each TLD is read in four distinct areas to yield four exposure values which-are averaged. Prior to the third quarter of 2001, exposure data were obtained using three lithium fluoride (LiF) TLD chips sealed in black plastic. The difference in material types can impact the amount of exposure measured. As seen in 2001, the Environmental Inc. TLD cards typically produce a slightly higher measured exposure value, although within the uncertainty of that value recorded by the TLD chips.

The reported field exposure is the arithmetic average of the four exposure values obtained minus the exposure received while the field TLD is in storage and transit.

The gamma rays may originate from PBNP produced radionuclides or from naturally occurring radionuclides. The TLDs remain at the monitoring site for roughly three months prior to analyses and the results are reported as mrem per seven days. Because the TLDs are constantly bombarded by naturally occurring gamma radiation, even during shipment to and from PBNP, the amount of exposure during transportation is measured using transportation controls with each shipment of TLDs to and from the laboratory. The doses recorded on the transportation controls are subtracted from the monitoring TLDs in order to obtain the net in situ dose.

29

9.7.7 ISFSI Ambient Radiation Exposure Although the ISFSI fence TLDs are not considered part of the REMP because of their location directly on site, their results can be used indirectly to determine whether the operation of the ISFSI is having an impact on the ambient environmental radiation beyond the site boundary. Impacts are determined by comparison of fence TLD results to the results of the monitoring at PBNP site boundary and other selected locations.

10.0 RESULTS Summary of 2008 REMP Results Radiological environmental monitoring conducted at PBNP from January 1, 2008, through December 31, 2008, consisted of analysis of air filters, milk, lake water, well water, soil, fish, shoreline sediments, algae, vegetation and TLDs. The results summarized in Table 10-1 include the following information:

Sample: Type of the sample medium

Description:

Type of measurement LLD: A priori lower limit of detection N: Number of samples analyzed Average: Average value +/- the standard deviation of N samples High: Highest measured value +/- it's associated 2 sigma counting error Units: Units of measurement For certain analyses, an LLD which is lower than that required by REMP is used because the lower value derives from the time required to obtain the LLDs for radionuclides that are more difficult to detect. For these analyses, both LLDs are listed with the REMP LLD given in parentheses. The results are discussed in the narrative portion of this report (Section 11). Blank values have not been subtracted from the results presented in Table 10-1. A listing of the individual results obtained from the contracted analytical laboratory is presented in Appendix 1, along with the results from the laboratory's radioanalytical quality assurance and the Interlaboratory Crosscheck Program.

In Table 10-1, no results are reported as <LLD. A ND radionuclide is one for which none of the individual measurements was statistically different from zero. When one or more of the measured radionuclide concentrations was positive and statistically different from zero, the average reported in Table 10-1 is the average +/- one standard deviation. Both the positive and negative results were used to calculate the average and standard deviation. Some of the reported averages are negative because many of the measured concentrations for that sample category were negative. The highest positive value and its 2-sigma error are reported only when one or more measured values are statistically greater than zero based on counting statistics.

The method of determining averages is provided in NUREG-0475 (1978), Radiological Environmental Monitoring by NRC Licensees for Routine Operations of Nuclear Facilities Task Force Report, and in Health Physics Society Committee Report HPSR-1 (1980),

Upgrading Environmental Radiation Data, released as document EPA 520/1-80-012 and 30

in more recent documents such as ANSI N42.23-1996, Instrument Quality Assurance for Radioassay Laboratories; ANSI N 13.30-1996, Performance Criteria for Radiobioassay; DE91-013607, Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance and NUREG-1576 Multi-Agency Radiological Laboratory Analytical Protocols Manual.

Table 10-2 contains the ISFSI fence TLD results.

31

Table 10-1 Summary of Radiological Environmental Monitoring Results for 2008 Average +/- Standard Sample Description N LLD (a) Deviation (b) High +/- 2 sigma Units TLD Environmental Radiation 112 1 mrem 1.05 +/- 0.17 1.50 +/- 0.11 mR/7days Control (E-20) 4 1 mrem 1.03 +/- 0.20 1.24 +/- 0.10 mR/7days Air Gross Beta 256 0.01 0.023 +/- 0.010 0.053 +/- 0.004 pCi/m3 Control (E-20) Gross beta 52 0.01 0.025 +/- 0.011 0.060 +/- 0.004 pCifm3 1-131 256 0.030 (0.07) ND pCi/m3 Control (E-20) 1-131 52 0.030 (0.07) ND pCi/m3 Cs-134 20 0.05 ND pCi/m3 Control (E-20) Cs-1 34 4 0.05 ND pCi/m3 Cs-137 20 0.06 ND pCi/m3 Control (E-20) Cs-137 4 0.06 ND pCi/m3 Other gamma emitters 20 0.1 0.0001 +/- 0.0003 0.0010 + 0.0007 pCi/m3 Control (E-20) Other 4 0.1 ND pCi/m3 Milk Sr-89 36 5 ND pCi/L Sr-90 36 1 0.9 +/- 0.4 1.8 + 0.4 pCi/L 1-131 36 0.5 ND pCi/L Cs-1 34 36 5 (15) ND pCi/L Cs-137 36 5 (15) ND pCi/L Ba-La-140 36 5 (15) -0.3 +/- 1.7 2.6 +/- 2.1 pCi/L Other gamma emitters 36 15 0.1 +/- 1.3 3.6 +/- 2.4 pCi/L Well Gross beta 4 4 0.9 +/- 0.6 1.5 +/- 0.5 pCi/L Water H-3 4 500 (3000) ND - pCi/L Sr-89 4 10 ND - pCi/L Sr-90 4 1 (2) ND - pCi/L 1-131 4 0.5 (2) ND - pCi/L Mn-54 4 10 (15) ND - pCi/L Fe-59 4 30 ND - pCi/L Co-58 4 15 ND - pCi/L Co-60 4 15 ND - pCi/L Zn-65 4 30 ND - pCi/L Zr-Nb-95 4 15 ND - pCi/L Cs-134 4 15 ND - pCi/L Cs-137 4 18 ND - pCi/L Ba-La-140 4 15 ND - pCi/L Other gamma emitters 4 30 ND - pCi/L Algae Gross beta 6 0.25 8.68 +/- 2.28 10.55 +/- 1.23 pCi/g Co-58 6 0.25 0.006 +/- 0.005 0.015 +/- 0.007 pCi/g Co-60 6 0.25 0.006 +/- 0.008 0.019 +/- 0.007 pCi/g Cs-134 6 0.25 ND pCi/g Cs-137 6 0.25 0.025 +/- 0.011 0.038 + 0.017 pCi/g (a) The required LLD per the PBNP REMP is enclosed in the parentheses.

(b) "ND" indicates that the sample result is Not Detectable, i.e., sample concentrations were statistically equivalent to zero.

32

Table 10-1 (continued)

Summary of Radiological Environmental Monitoring Results for 2008 Average +/- Standard Sample Description N LLD (a) Deviation (b) High +/- 2 sigma Units Lake Water Gross beta 46 4 1.6 +/- 0.9 3.4 +/- 1.0 pCi/L 1-131 46 0.5 (2) 0.01 +/- 0.1 0.32 +/- 0.26 pCi/L Mn-54 46 10(15) 0.1 +/- 1.1 2.8 +/- 1.7 pCi/L Fe-59 46 30 0.0 +/- 2.2 4.5 +/- 3.6 pCi/L Co-58 46 15 0.2 +/- 1.1 2.8 +/- 2.7 pCi/L Co-60 46 15 ND - pCi/L Zn-65 46 30 ND - pCi/L Zr-Nb-95 - 46 15 ND - pCi/L Cs-134 46 10(15) ND - pCi/L Cs-1 37 46 10(18) 0.0 +/- 1.2 4.8 +/- 3.0 pCi/L Ba-La-140 46 15 -0.1 +/- 2.1 4.3 +/- 4.0 pCi/L Ru-103 (Other gamma) 46 30 -0.5 +/- 1.2 4.0 +/- 2.8 pCi/L Sr-89 16 5 ND - pCi/L Sr-90 16 1 (2) 0.34 +/- 0.12 0.57 +/- 0.27 pCi/L H-3 16 500 (3000) 137 +/- 301 1251 +/- 132 pCi/L Fish Gross beta 8 0.5 3.82 +/- 0.56 4.34 +/- 0.16 pCi/g Mn-54 8 0.13 ND - pCi/g Fe-59 8 0.26 0.001 +/- 0.020 0.040 + 0.026 pCi/g Co-58 8 0.13 ND - pCi/g Co-60 8 0.13 ND - pCi/g Zn-65 8 0.26 ND - pCi/g Cs-1 34 8 0.13 -0.002 +/- 0.008 0.010 + 0.009 pCi/g Cs-137 8 0.15 0.033 +/- 0.022 0.070 +/- 0.025 pCi/g Other gamma emitters 8 0.5 0.000 +/- 0.008 0.011 + 0.009 pCi/g Shoreline Gross beta 10 2 13.86 +/- 6.10 25.60 +/- 2.70 pCi/g Sediment Cs-137 10 0.15 0.025 +/- 0.011 0.038 +/- 0.015 pCi/g Soil Gross beta 16 2 30.03 +/- 8.19 41.37 +/- 3.30 pCi/g Cs-1 37 16 0.15 0.16 +/- 0.09 0.35 +/- 0.03 pCi/g Vegetation Gross beta 24 0.25 7.61 +/- 2.03 9.89 +/- 0.30 pCi/g 1-131 24 0.06 0.004 +/- 0.010 0.026 +/- 0.014 pCi/g Cs-134 24 0.06 0.000 +/- 0.006 0.014 +/- 0.012 pCi/g Cs-137 24 0.08 0.005 +/- 0.008 0.019 +/- 0.013 pCi/g Other gamma emitters 24 0.06 0.001 +/- 0.006 0.018 +/- 0.016 pCi/g (a) The required LLD per the PBNP REMP is enclosed in the parentheses.

(b) "ND" indicates that the sample result is Not Detectable, i.e., sample concentrations were statistically equal to zero.

Other gamma emitters typically refer to Co-60 if not specifically called out in the analyses. See explanation on Page 1 of the Environmental Inc., report which is Appendix A of this Annual Monitoring Report 33

Table 10-2 ISFSI Fence TLD Results for 2008 Fence Location Average Standard Deviation Units North 2.64 0.25 mR/7 days East 2.37 0.26 mR/7 days South 1.36 0.17 mR/7 days West 5.36 0.46 mR/7 days 11.0 DISCUSSION 11.1 TLD Cards The ambient radiation was measured in the general area of the site boundary, at an outer ring four - five miles from the plant, at special interest areas, and at one control location, roughly 17 miles southwest of the plant. The average of the indicator TLD cards is 1.05 mR/7-days and 1.03 mR/7-days at the control location.

These results are not significantly different from each other nor from those observed from 2001 through 2008 (tabulated below in Table 11-1). The change in TLD types in 2001 accounts for the increase in average TLD readings (i.e. prior to third quarter 2001 TLD LiF chips were used versus the TLD cards (see Section 9.7.6 for additional information) from 2000 to 2001. Therefore, the operation of the plant has had no effect on the ambient gamma radiation.

Table 11-1 Average Indicator TLD Results from 1993 - 2008 Year Average Std. Dev* Units 1993 0.82 0.15 mR/7 days 1994 0.90 0.12 mR/7 days 1995 0.87 0.13 mR/7 days 1996 0.85 0.12 mR/7 days 1997 0.87 0.11 mR/7 days 1998 0.79 0.13 mR/7 days 1999 0.79 0.21 mR/7 days 2000 0.91 0.15 mR/7 days 2001 1.06 0.19 mR/7 days 2002 1.17 0.21 mR/7 days 2003 1.10 0.20 mR/7 days 2004 1.10 0.22 mRI7 days 2005 1.04 0.21 mR/7 days 2006 1.14 0.21 mR/7 days 2007 1.08 0.20 mR/7 days

Std. Dev = Standard Deviation 34

There were no new cask additions in 2008 with no significant change in the average annual ISFSI fence TLD results (Table 11-2) The North and West fence TLDs continue to record higher doses than the South and East fence TLDs (Table 11-2) corresponding to the location of the storage units at the NW corner of the site.

Compared to the background site (E-20), most of the indicator sites for the ISFSI (Table 11-3) show increases with the placement of casks at the ISFSI with the highest values at E-03 which is the closest to the ISFSI [see Figs. 9-1 and 9-2 for locations]. The results near the site boundary (E-31, 1.12 +/- 0.07; E-32, 1.03 + 0.14) are comparable to the background site E-20 (1.00 +/- 0.16) within the associated measurement error, indicating no measurable increase in ambient gamma radiation at the site boundary due to the operation of the ISFSI.

Table 11-2 Average ISFSI Fence TLD Results (mR/7 days)

North East South West 195 D.9W 11.10

. 12 iT95 197rnT5 .5 -7=

1.2 -77n7-1.0 -w-T.

1.6 1998 2.08 1.37 1.02 1.96 7999 2.57 .84 1.11 3.26 2000 .T72 =2. 1T.25 5.05 MOT -- 7T TT --. N _ _UF-2.79 2.74 1.42 6.46 2003 2.70 2.60 1.50 6.88 20W 2.61 21.41 6.50 2006 2.7 2.5 138 58 2007 2.7 27 1 5.47 2008 2.64 2.37 1.36 5.36 Table 11-3 Average TLD Results Surrounding the ISFSI (mR/7 days)

E-03 E-28 E-29 E-30 E-31** E-32** E-20***

Pre-Operation* 0.93 0.87 0.87 0.81 0.93 0.98 0.88 1996 0.87 0.78 0.81 0.79 0.93 1.00 0.78 1997 0.91 0.89 0.84 0.84 0.89 0.97 0.79 1998 0.82 0.68 0.80 0.82 0.91 0.85 0.77 1999 0.88 0.83 0.76 0.80 0.90 0.99 0.78 2000 0.98 0.88 0.92 0.99 0.98 1.06 0.90 2001 1.31 0.95 1.07 1.02 1.10 1.04 1.03 2002 1.45 0.91 1.22 1.10 1.26 1.25 1.14 2003 1.29 0.82 0.94 1.02 1.20 1.15 0.99 2004 1.35 0.80 0.96 1.05 1.23 1.18 1.06 2005 1.30 0.72 0.96 0.98 1.15 1.04 1.00 2006 1.44 0.80 1.19 1.07 1.21 1.07 1.11 2007 1.37 0.78 1.07 1.05 1.18 0.97 1.05 2008 1.33 0.75 0.81 1.00 1.12 1.03 1.00

Pre-operation data are the averages of the years 1992 through 3rd quarter of 1995.

- Sites E-31 and E-32 are located at the Site Boundary to the west and south-west of the ISFSI.

E-20 is located approximately 17 miles WSW of the ISFSI.

35

11.2 Milk Except for Sr-90, the annual average radionuclide concentrations in milk continue to be statistically not different from zero. The Sr-90 concentrations result from the cycling of this radionuclide in the biosphere after the atmospheric weapons tests of the '50s, '60s, and '70s and the Chernobyl accident. Although these tests also introduced Cs-1 37 into the environment, Cs-1 37 binds more strongly to soils and is therefore less likely to be ingested by cows. As summarized in Table 3-2, PBNP did not release airborne Sr-90 in 2008. The 2008 average Sr-90 concentration of 0.9 +/- 0.4 pCi/I is statistically identical to the 2007 average and comparable to previous years (see below):

Year Annual Average Sr-90 Year Annual Average Sr-90 Concentration (pCi/I) Concentration (pCi/I) 1997 1.2 +/- 0.5 2003 1.1 +/- 0.4 1998 1.1 +/- 0.5 2004 1.1 +/- 0.4 1999 1.0 +/- 0.3 2005 0.9 +/- 0.4 2000 1.2 +/- 0.6 2006 0.9 +/- 0.3 2001 1.2 +/- 0.5 2007 0.8 +/- 0.4 2002 1.1 +/- 0.7 2008 0.9 +/- 0.4 Based upon the above data, it is concluded that the milk data for 2008 show no radiological effects of PBNP operation.

11.3 Air The average annual gross beta concentrations (plus/minus the one-sigma uncertainty) in weekly airborne particulates at the indicator and control locations were 0.023 +/- 0.010 pCi/m 3 and 0.025 +/- 0.011 pCi/m 3, respectively, and are similar to levels observed from 1993 through 2007 (Table 11-4).

Table 11-4 Average Gross Beta Measurements in Air Year Average (pCi/m3) Year Average (pCi/m3) 1993 0.022 2001 0.023 1994 0.022 2002 0.023 1995 0.021 2003 0.023 1996 0.021 2004 0.021 1997 0.021 2005 0.024 1998 0.022 2006 0.021 1999 0.024 2007 0.025 2000 0.022 2008 0.023 36

The gross beta concentration variation over the year usually reveals higher concentrations in the fall and winter as compared to the spring and summer. This is present again during 2008. However, for 2008, as in previous years, more scatter is observed during July-September (Figure 11-1). The cause for this scatter is likely due to a shift in land use or weather patterns.

Figure 11-1.

2008 Airborne Gross Beta Concentration (pCi/m 3) vs. Time 2008 Airborne Gross Beta

" 0.060 -

E 0.050 - . E-01

" X

__' -E-02 0.0040 (U0-

.~0020 x E-08 S0.010-

.E-20 c 0.000 -

"p,,o.,

op OV 01, 01> 01, Date In 2005, the new method of evaluating airborne 1-131 was instituted. Instead of counting each charcoal cartridge separately, all six cartridges for the week are counted as one sample in a predetermined geometry to screen the samples for 1-131. If any airborne radioiodine is detected, each sample cartridge is counted individually. With no detectable 1-131, the reported analytical result is the minimum detectable activity (MDA) conservatively calculated using the smallest of the six sample volumes. The reported MDAs ranged from 0.007 pCi/m 3 to 0.029 pCi/m 3. The LLD analysis is based on counting only one cartridge. The use of six cartridges, or roughly six times the sample volume with the same count time as would be needed to achieve the desired LLD for only one sample, results in the actual LLD to be about six times lower than the programmatic value given in Table 10-1. Similarly, the actual MDA is about one-sixth of that reported, or in the range of 0.001 pCi/m 3 to 0.005 pCi/m 3 . Based upon the absence of any 1-131 detected, the release of small amounts of radioiodine during April and October (Table 3-2) had no measurable impact on the environment.

Gamma spectroscopic analysis of quarterly composites of air particulate filters yielded similar results for indicator and control locations. Except for location E-04 near the site north boundary, no other indicator location or the control location shows results which are significantly different than zero. The second quarter result has a small, positive value for Co-60 ("Other"). About 9 pCi 37

of airborne Co-60 was released in April (Table 3-3) of the second quarter. The observed result is likely a false positive as evidenced by the prevailing wind direction and the absence of Co-58 which was also released during the same month of that quarter. By comparison, the measured concentration of naturally occurring Be-7 was 0.075 pCi/m 3 in the E-04 sample, as well as at the background site E-20. Be-7 is not required to be measured by the PBNP REMP; however, it serves as a means to monitor the internal consistency of the vendor's analytical program and for comparisons to radionuclides that may be in PBNP airborne effluent.

In summary, the 2008 air data do not demonstrate a significant environmental impact from the operation of PBNP.

11.4 Lake Water For the suite of REMP-specified gamma emitting radionuclides listed in Table 10-1, reported concentrations continue to occur as small negative and positive values scattered around zero, indicating no radiological impact from the operation of PBNP. Lake Michigan water samples are collected north (E-33 and E-05) and south (E-01 and E-06) of Point Beach (see Figure 9-1). Only 46 lake water samples were collected because environmental conditions precluded sample collection at site E-01 and E-06 during December.

There were nine positive indications of gamma emitters during 2008. Of the 46 lake water samples 1 of 46 was statistically greater than zero for radionuclides Co-58, Mn-54, 1-131, Ru-1 03, and Cs-1 37, while 2 of 46 were positive for Fe-59 and Ba/La-140. By comparison to liquid effluents for those months in which the positive lake water results were obtained, the Fe-59, Co-58, Ru-1 03, Ba/La-140, and 1-131 are false positives, as none of these radionuclides were discharged in the months these samples were collected. In addition, positive results were detected for Fe-59, Mn-54, Co-58, and Cs-1 37 in various locations upstream of PBNP and hence are not attributable to PBNP. It should be noted that positive Cs-1 37 results are obtained for Lake Michigan water both north and south of PBNP due to the recycling of this long-lived radionuclide in the environment. Its source is the atmospheric weapons testing of the fifties and sixties with additional inputs from the Chernobyl accident. Based on these results and their occurrences, it is concluded that these results do not indicate a measurable impact of PBNP liquid discharges on Lake Michigan.

Aliquots of the monthly samples are composted quarterly and analyzed for Sr-89/90 and for tritium. Sr-90, like Cs-1 37, still persists in Lake Michigan from radioactive fallout. Therefore it is not surprising that positive results still occur.

Nine of the sixteen composites were positive. No Sr-89 was detected in the samples. Tritium, in addition to being produced by water-cooled reactors such as PBNP, also is a naturally occurring radionuclide. The quarterly composite lake water samples collected and analyzed for H-3 in 2008 ranged from non-detectable to 1251 pCi/I. Only 4 of the 16 composites showed a detectable H-3 concentration and 3 of the 4 positives were north or upstream of PBNP. The individual months used to composite the sample yielding 1251 pCi/I were individually analyzed. Two of the months had non-detectable H-3. The April 38

result was 4,057 pCi/I indicating the sample was obtained on the day of a discharge from the Kewaunee Power Station.

11.5 Algae Filamentous algae attached to rocks along the Lake Michigan shoreline are known to concentrate radionuclides from the water with concentration factor over a thousand for certain radionuclides. All six samples had small, positive concentrations of Cs-137. Co-58 and Co-60 were positive only in the June sample obtained near the PBNP discharge. All three radionuclides had been discharged the previous months. Since Cs-137 also occurrs north of the plant, it is likely that the Cs-1 37 detected is that which remains in the lake from atmospheric weapons testing conducted decades ago. By contrast, no cobalts were found in the algae in the August and October samples even though both cobalt isotopes had been discharged at comparable levels from January -

October. Typically, the only fission product observed in algae is Cs-1 37. This year's average Cs-1 37 of 0.025 +/- 0.011 pCi/g, is consistent with previous results (see below).

Year Cs-1 37 Activity (pCi/M) Year Cs-1 37 Activity (pCi/g) 1995 0.034 2002 0.019 1996 0.05 2003 0.010 1997 0.03 2004 0.018 1998 0.027 2005 0.014 1999 0.031 2006 ND 2000 0.027 2007 0.014 2001 0.019 2008 0.025 By contrast, the concentrations of naturally occurring Be-7 and K-40 are higher:

1.49 pCi/g and 2.73 pCi/g, respectively. These results indicate only a minor, if any, effect by PBNP upon the environs.

11.6 Fish No specified fission/corrosion radionuclide concentrations in fish greater than the required LLD were found in 2008. There were 2 fish with small, positive results for Cs-134. Because no Cs-134 was released during 2008, these results are considered to be false positives. Similarly, the one occurrence of Fe-59 also is interpreted as a false positive because the first discharge of Fe-59 occurred after the fish sample was obtained. The short half-life of Fe-59 makes it unlikely that positive result resulted from previous Fe-59 discharges which occurred in the second quarter of 2007. One fish did show a small amount of Ru-103, small quantities of which had been released in November 2008. Statistically positive Cs-1 37 concentrations were found in 7 of the 8 fish. The high Cs-1 37 value of 0.070 +/- 0.025 pCi/g is comparable to the 0.049 and 0.055 pCi/g found in 2007 and 2006 but is lower than the high of 0.172 pCi/g in 2005 and considerably lower than the 2.8 pCi/g seen in PBNP samples obtained in the mid-1970s during the Chinese weapons tests. However, the Cs-137 results in fish are consistent with accumulation due to the recycling of atmospheric weapons 39

testing fallout of Cs-1 37 in Lake Michigan. By comparison, the concentration of naturally occurring K-40 (1.63-4.34 pCi/g) is about 20-60 times higher than the highest Cs-1 37 concentration. Based on these results, it is concluded that there is but a minor indication of a plant effect.

11.7 Well Water No plant-related radionuclides were detected in well water during 2008 as all results were not significantly different from zero. The gross beta values result from naturally occurring radionuclides. There is no evidence of PBNP effluents reaching the aquifer supplying drinking water to PBNP.

11.8 Soil Cs-1 37 is present in the soils throughout North America and the world. The main contributor to this worldwide distribution is the weapons testing in the 1950s and 1960s with lesser amounts from Chinese atmospheric nuclear tests in the 1970s and the 1986 Chernobyl accident. Soil is an integrating sample media in that it is a better indicator of long term buildup of Cs-137 as opposed to current deposition for local sources. The main modifiers of soil Cs-1 37 concentration levels are erosion and radioactive decay. The PBNP REMP results indicate that low levels of Cs-1 37 from fallout continue to be present in soil samples at about 1% of the levels of naturally occurring K-40. Fifteen of the 16 samples have Cs-1 37 concentrations statistically greater than zero ranging from 0.07 +/- 0.02 to 0.35 +/- 0.03 pCi/g. Gross beta for 2008 is consistent with the results for the last few years but higher than the averages from the 1990s (Table 11-5). Also, the results are quite uniform with the result close to the plant (E-01: 26 - 36 pCi/g) not being different from the background site some 17 miles away in the lowest x/Q sector (E-20: 34 pCi/g). Therefore, there is no indication of a plant effect base on the comparison of indicator and background results.

Table 11-5 Average Gross Beta Concentrations in Soil Activity Year Activity (pCi/9) Year (pCi/g) 1993 23.6 2001 23.5 1994 19.4 2002 21.9 1995 18.0 2003 22.5 1996 19.4 2004 24.3 1997 22.8 2005 29.1 1998 20.0 2006 27.4 1999 23.1 2007 31.0 2000 22.1 2008 30.0 40

11.9 Shoreline Sediment Shoreline sediment consists of sand and other sediments washed up on the Lake Michigan shore. As in soil samples, the only non-naturally occurring radionuclide found in these samples is Cs-137. All 10 samples have Cs-137 concentrations statistically different from zero. The Cs-1 37 concentrations of the shoreline sediment are about one-tenth of that found in soils. This is expected because Cs-1 37 in the geological media is bound to clay as opposed to the sand found on the beach. Wave action winnows clay particles from the beach leaving the heavier sand; hence the lower Cs-137 concentrations in beach samples. In contrast to K-40 which is actually part of the minerals making up the clay and sand, Cs-137 is attached to soil/sand particle surfaces and is present at concentrations 1 % or less of the naturally occurring concentrations of K-40.

Lake Michigan sediments are a known reservoir of fallout Cs-1 37. In conclusion, the shoreline sediment data indicate no radiological effects from plant operation.

11.10 Veqetation The naturally occurring radionuclides Be-7 and K-40 are found in all of the vegetation samples. The source of Be-7 is atmospheric deposition. It is continuously formed in the atmosphere by cosmic ray spallation of oxygen, carbon, and nitrogen atoms. In contrast, K-40 is a primordial radionuclide which is incorporated into vegetation from the soil during the growing process. Cs-137 can represent both pathways. Fresh Cs-137 fallout is associated, like Be-7, with deposition on the plant surface. Old fallout from the fifties and sixties is now being incorporated into growing plants in the same manner as potassium because it is in the same chemical family as potassium. Cs-137 has been consistently present in vegetation from E-06, a campground area in the Point Beach State Forest. As has been demonstrated at other sites in the United States which are far from any nuclear plants, Cs-1 37 fallout from the 1950s and 1960s is present in the ash produced by burning the wood in fireplaces.

Typically, campground fires are put out using water and the ashes are spread on the ground. The ash acts as a fertilizer, releasing the cesium and potassium into the soil where they are available for uptake by growing plants and trees. The Cs-1 37 results from E-06 demonstrate that Cs-1 37 fallout from the Chernobyl accident and from atmospheric weapons tests continues to be recycled in the environment by the spreading of wood ash at camp sites. It is concluded that the Cs-1 37 found in the 4 of the 5 vegetation samples are not due to PBNP emissions because Cs-1 37 was not found in air samples where Be-7 was detected.

The two remaining programmatically specified radionuclides, 1-131 and Cs-1 34, had positive results 6 of 24 and 1 of 24 times, respectively. Cs-1 34 is a false positive because there were no airborne Cs-1 34 releases. Even though small amounts of 1-131 were released during April and October, the results are determined to be false positives because 1-131 was not detected in the air samples from the same locations as the vegetation, and because the concentrations at the indicator site are equal to the background site. Had the 1-131 originated from the plant, the concentrations at the background site would be several orders of magnitude lower, based on the dilution which occurs during 41

the transport. Supporting this conclusion is the absence of Cs-137 in air samples obtained at these sites. Based on the 2008 vegetation sampling results, no effect from PBNP effluents are noted.

11.11 Land Use Census In accordance with the requirements of Section 2.5 of the Environmental Manual, a visual verification of animals grazing in the vicinity of the PBNP site boundary was completed in 2008. No significant change in the use of pasturelands or grazing herds was noted. Therefore, the existing milk-sampling program continues to be acceptable and the use of the PBNP south site boundary for calculating doses via the grass-cow-milk pathway remains conservative.

12.0 REMP CONCLUSION Based on the analytical results from the 806 environmental samples and from 116 sets of TLDs that comprised the PBNP REMP for 2008, PBNP effluents had no discernable, permanent effect on the surrounding environs. These results demonstrate that PBNP continues to have good controls on fuel integrity and on effluent releases. The control of effluents from PBNP continues to be acceptable pursuant to the ALARA criteria of 10 CFR 50.34a.

42

13.0 PROGRAM DESCRIPTION The Point Beach Nuclear Plant monitors groundwater for tritium. During 2008 the sampling program consisted of six beach drains, five intermittent creek and bog locations, four drinking water wells, four fagade wells, eight yard electrical manholes, six ground water monitoring wells, and the Unit 2 facade subsurface drainage system sump.

In the 1980s, the beach drains entering Lake Michigan were found to contain tritium. The beach drains are the discharge points for yard drainage system which carries storm water runoff and are known to be infiltrated by groundwater as observed by discharges even when no rain has occurred. In the 1980s, the source of H-3 for this pathway was postulated to be spent fuel pool leakage into the groundwater under the plant based on the observation that after modifications were made to the pool, the tritium concentrations decreased below detectability. Beach drain effluents continue to be monitored and are accounted for in the monthly effluent quantification process. Because the beach drains are susceptible to groundwater in-leakage from other sources such as the area around the former retention pond which is known to contain H-3, the beach drains are monitored as part of the groundwater monitoring program.

The intermittent streams and the Energy Center (EC) well were added to the groundwater monitoring program in the late 1990s when it was discovered that tritium diffusion from the then operable, earthen retention pond was observable in the intermittent streams which transverse the site in a NW to SE direction. These streams pass on the east and west sides of the former retention pond and empty into Lake Michigan about half a mile south of the plant near the site's meteorological tower. The intermittent stream samples track H-3 in the surface groundwater.

The groundwater monitoring program also includes two bogs or ponds on site. One is located about 400 feet SSE of the former retention pond; the other, about 1500 feet N.

In addition to the main plant well, three other drinking water wells also are monitored. The Site Boundary Control Center well located at the plant entrance, the Warehouse 6 well on the north side of the plant, and the EC well located south of the plant. These wells do not draw water from the top 20 - 30 feet of soil which is known to contain H-3. These wells monitor the deeper (200 - 350 feet), drinking water aquifer from which the main plant well draws its water. The two soil layers are separated by a gray, very dense till layer of low permeability identified by hydrological studies.

Manholes in the plant yard and for the subsurface drainage (SSD) system under the plant are available for obtaining ground water samples. The plant yard manholes for accessing electrical conduits are susceptible to ground water in-leakage. Therefore, a number of these were sampled. The SSD were designed to control the flow of water 43

under the plant and around the perimeter of the foundation walls. The SSD system flows to a sump in the Unit 2 facade. A monthly composite from this sump is analyzed as well as part of the program.

In the 1990s, two wells were sunk in each units fagade to monitor the groundwater levels and look evidence of concrete integrity as part of the ISI IWE Containment Inspection Program. These wells are stand pipes which are sampled periodically for chemical analyses. Beginning in 2007, samples for the groundwater program were drawn as well.

These wells are sampled at least three times a year.

The groundwater sampling sites (other than the beach drains, SSDs and manholes) are shown in Figure 13.1.

44

Figure 13-1 Groundwater Monitoring Locations 45

14.0 RESULTS 14.1 Streams and Bogs The results from the groundwater monitoring associated with the former retention pond are presented in Table 14-1. For the most part, the creek results are barely above the detection level. There are more positive values for the East Creek than for the West Creek or for the confluence of the two creeks south of the plant near Lake Michigan. GW-08 is a bog near the former retention pond.

Table 14-1 Intermittent Streams and Bogs H-3 Concentration (pCiII)

Month GW-01 (E-01) GW-02 GW-03 GW-17 BOGS MDA Creek

____ Confluence E. Creek W. Creek STP GW_07 GW_0 Jan++++/-

Feb+ +/-

Mar ND++/- 276 +/-101 135 +/-96 252 +/-100+/-+ 171 Apr ND +/- 342 +/- 107ND +/- 123 +/- 99 + 178 May ND++/- ND++/- 168 +/-80 +ND+/- ND+/- 145 Jun ND++/- 165 +/- 92 ND +/- +++ 172 Jul ND++/- ND++/- ND +/- ++ + 150 Aug+++ 152 ND+/-

Sep +ND + ND +/- +/-+/-+ 147 Oct ND++/- 141 +/-83 ND +/- 180 +/- 85 ++ 153 Nov ND++/- ND++/- ND +/- +/-+ 147 Dec + I 1 1 133

1. A blank indicates no sample was available. Streams are sampled monthly; bogs, annually.

2. Values are presented as the measured value and the 95% confidence level counting error.

3. ND = not statistically different from zero at the 95% confidence level.

46

14.2 Beach Drains and SSD Sump The results for the beach drains (Table 14-2) show low H-3 concentrations with most results in the 200 - 400 pCi/I range with one outlier, S-3, at 1100 pCi/I. The drain data from left to right in the table are in the order of the drains from north to south. S-1 exhibits the most consistent and uniform H-3 concentration. Based on the flow direction of the intermittent streams around the former retention pond, S-3 would be the drain most susceptible to contain tritiated groundwater in-leakage from the area around the former retention pond. S-1 is connected to the SSD sump in the Unit 2 fagade and also is impacted by groundwater in-leakage. The monthly SSD sump composite results (Table 14-3) are generally higher than the S-1 results (Table 14-2). Beach drains S-7 and S-10 are fed by runoff from the Unit 2 and Unit 1 roofs respectively. Flow is not expected unless there is precipitation on the sampling day or there is melt-off of accumulated snow. S-8 and S-9 drain the small yard area between the plant and the lake. It is not known why the only occurrence of water flow from either S-8 or S-9 should have a measurable amount of H-3. However, it may be associated with groundwater in-leakage as electrical manholes M-1 and M-2 in the area have been found to contain low concentrations of H-3.

The reason for the high H-3 concentration at S-3 in January is unknown.

However, recounts gave results at the comparable level: 1257 +/- 130 and 1301 +

137 pCi/I. A gamma scan of the sample for the radionuclides required for lake water did not detect Cs, Fe, Mn, Zn, Co, or other gamma emitters. Further analyses for Sr-89/90 also did not detect these strontium isotopes.

TABLE 14-2 2008 BEACH DRAIN TRITIUM H-3 CONCENTRATION (pCi/I)

Month S-1 S-7 S-8 S-9 S-10 S-3 Jan 355 +/- 97 187 +/-90 194 + 102 ND +/- 320 +/- 107 1103 +/- 124 Feb 302 +/- 77 NF + NF + NF NF ++/- NF NF Mar 300 +/- 107 NF + NF + NF +/- NF + 317 +/- 108 Apr 391 +/- 96 NF + 215 +/- 89 NF +/- NF + 401 +/- 97 May 275 +/- 93 NF NF + NF +/- NF + 266 +/- 92 Jun 357 +/- 101 NF +/- NF + NF +/- NF + 425 +/- 103 Jul 352 +/- 95 NF + NF + NF +/- NF +/- 142 +/- 86 Aug 292 +/- 88 NF +/- NF + NF +/- NF +/- 277 +/- 87 Sep 78 +/- 77 NF +/- NE NF +/- NF + 356 +/- 89 Oct 350 +/- 111 NF +/- NF + NF +/- NF + 127 +/- 102 Nov 313 +/- 88 NF +/- NE NE N+F 254 +/- 85 Dec NF NF NF + NF +/- NF+ NEF Average 306 205 367 Std dev= 83 15 277 NF = no sample due to no flow 47

Table 14-3 U2 FACADE SUBSURFACE DRAIN SUMP H-3 CONCENTRATION (pCi/I)

Month pCi/I 2a Jan 462 + 112 Feb 322 + 92 Mar 566 + 107 Apr 482 + 112 May 387 + 91 Jun 452 + 103 Jul 424 + 96 Aug 394 + 113 Sep 485 + 116 Oct 509 + 113 Nov 393 + 89 Dec 610 _ 124 Samples are monthly composites.

14.3 Electrical Manholes The manhole sample locations selected during 2008, are shown in Table 14-4.

Manholes for access to below ground electrical facilities are susceptible to groundwater in-leakage as is evident by very low concentrations of H-3. MH-6, MH-7, and MH-8 collect groundwater draining from the switch yard.

Table 14-4 YARD MANHOLE TRITIUM Activity (pCi/l)

Man Hole pCi/I 2a MH-6 ND +

MH-7 242 + 105 MH-8 139 + 101 MH-67A 247 +/- 96 MH-67B 309 +/- 99 MH-67C 241 + 96 MH-67D 155 + 92 MH-68 223 + 95 Average= 198 + 87 ND = not detected The manhole series M-67 A-D run from south to north on the east side of the Unit 2 Turbine Building. M-67A is located near the U2 truck bay and M-67D is 48

just east of the EDG Building. MH-68 is in the west side of this building, opposite MH-67D. Except for MH-6, in which no H-3 was detected, there is no statistical difference in the H-3 concentrations found in these manholes.

14.4 Fac;ade Wells Two wells are located in each unit's fagade, one on each side of containment approximately 1800 apart. Results for 2008 finds that the concentrations have been fairly constant in 2008 with slight decreasing trends in wells, 1Z-361A and 2Z-361B (Table 14-5).

Table 14-5 2008 FACADE WELL WATER TRITIUM H-3 Concentration (pCi/I)

UNIT 1 UNIT 2 Month 1Z-361A 1Z-361B 2Z-361A 2Z-361B Jan Feb Mar 210+/-87 Apr 1169+/-122 ND ND 268 +/-88 May Jun Jul 1066+/-118 83+/-81 ND 464+/-97 Aug Sep Oct 929+/-117 102+/-82 ND 110+/-82 Nov Dec ND = not detected By comparison to 2007, the 2008 H-3 concentrations in 1Z-361A (on the SE side of the U1 containment) are down about 400 pCi/I from their high of 1,525 pCi/I in 2007 whereas the concentrations at 1Z-361B (on the NE side of U1 containment) remain comparable, but slightly lower that the 2007 results. The biggest change occurred in 2Z-361B which has decreased from a 2007 high of 4,200 pCi/I to the current 110 pCi/I. What also remains apparent is the difference between the H-3 concentrations on opposite sides of each containment. This difference indicates that the groundwater H-3 is not uniformly distributed under the plant.

14.5 Potable Water and Monitoring Wells In addition to the main plant well (Section 11.7), nine other wells are monitored for H-3. These consist of three potable water wells, GW-04, GW-05, and GW-06, and six H-3 groundwater monitoring wells, GW-1 1 through GW-16 installed 49

in 2007 (Figure 13-1). The monitoring wells are located at the periphery of the area affected by diffusion from the former retention pond and known spent fuel pool leakage during the 1970s. Two of the potable water wells are for buildings close to the plant (GW-04 and GW-05); the other (GW-06) is at the Site Boundary Control Center 3200 feet from the former retention pond. The potable water wells are from the deep aquifer whereas the monitoring wells are in the shallow (< 30 feet), surface water aquifer above the thick, impermeable clay layer separating the two. The EC well is sampled monthly and the other two potable wells, quarterly.

The results are presented in Table 14-6 show that two of the potable water results (GW-04 and GW-06) are considered positive, i.e. detected. However, the two positive results do not meet the minimum detectable activity (>MDA) criterion for being sufficiently different from background at the 95% confidence level. In conclusion, potable water wells GW-04, GW-05 and GW-06 had no statistically detectable H-3. Also analyses for gamma emitters, 1-131, and Sr-90, did not find any of the radionuclides in GW-05 and GW-06 well water.

Table 14-6 2008 WELL WATER TRITIUM H-3 Concentration (pCi/I)

EIC Warehouse SBCC WELL 6 Well Well MW-01 MW-02 MW-06 MW-05 MW-04 MW-03 Month GW-04 GW-05 GW-06 GW-11 GW-12 GW-13 GW-14 GW-15 GW-16 Jan ND ND ND ND ND 110+/-96 96+/-96 456+/-109 NS Feb ND ND ND ND 96+/-92 404+/-105 204+/-97 Mar ND 138+/-93 ND 108+/-91 124+/-92 450+/-105 232+/-97 Apr ND ND 107+/-84 ND ND ND 86+/-82 466+/-98 182+/-86 May ND 108+/-77 ND 125+/-78 189+/-81 450+/-93 262+/-85 Jun ND 124+/-91 ND 102+/-90 138+/-91 533+/-107 334+/-99 Jul ND ND ND 97+/-82 ND ND ND 433+/-94 198+/-84 Aug ND 86+/-80 ND 104+/-81 96+/-81 507+/-100 150+/-83 Sep ND ND ND ND ND 434+/-111 202+/-102 Oct ND ND ND 106+/-85 ND ND ND 542+/-104 151+/-87 Nov ND ND ND ND ND 344+/-88 ND Dec 121+/-106 ND 85+/-74 79+/-74 ND 396+/-88 213+/-80 ND = not detected, NS = no sample April gamma scans, 1-131, and Sr analyses of GW-05 and GW-06 found no activity July gamma scans, 1-131, and Sr analyses of GW-05 and GW-06 found no activity Applying the same statistical criteria to samples from monitoring wells GW-1 1 through GW-14 reveals that for GW-14, the only positive result which met >MDA occurred in May. All of the measured concentrations at GW-1 5 and all of GW-16, except for August and November, met the >MDA criterion. The highest H-3 concentration occurred at GW-1 5, the well nearest the location of the former retention pond. This well is near the area where the pond pre-remediation groundwater survey found a tritium concentration of 14,000 pCi/I. Although 50

GW-1 6 is eastward of GW-1 5 in the direction groundwater would flow, the concentrations are lower.

14.6 Miscellaneous Sampling In addition to groundwater, analyses have been made of rainwater. Rainwater H-3 measurements were undertaken in order to obtain information on potential background levels of tritium. Another reason for sampling the rainwater is to determine whether it is possible to see the outwash of atmospheric H-3 releases from PBNP. Therefore, a sampler was placed at the Site Boundary Control Center (E-04), which is located in the highest x/Q sector and near the western (E-03) and northern (E-04) boundaries. Results do not indicate significant washout of H-3 at the site boundary (Table 14-7).

Table 14-7 2008 PRECIPITATION H-3 Collection E-02 E-03 E-04 Date pCiIl 2a pCi/I 2a pCi/I 2a 1/23/2008 62 52 - - - -

4/3/2008 94 52 54 52 66 52 5/8/2008 76 52 50 52 67 52 9/10/2008 44 52 31 52 40 52 10/9/2008 52 52 69 52 61 52 11/6/2008 <19 52 34 52 34 52 12/3/2008 66 52 48 52 <19 52 15.0 GROUNDWATER

SUMMARY

Groundwater monitoring indicates that low levels of tritium continue to occur in the upper soil layer but not in the deep, drinking water aquifer. These results also indicate that the low levels of tritium are restricted to a small, well defined area close to the plant. Except for the monitoring wells downstream from the former retention pond, the monitoring well tritium concentrations are not different from zero.

Results will continue to be evaluated to determine whether additional groundwater monitoring sites are needed.

51

ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 2008 ANNUAL MONITORING REPORT ENVIRONMENTAL MANUAL REVISION 20 NOVEMBER 11, 2008 36 pages follow

EM ENVIRONMENTAL MANUAL DOCUMENT TYPE: Controlled Reference REVISION: 20 EFFECTIVE DATE: November 11, 2008 APPROVAL AUTHORITY: Plant Manager PROCEDURE OWNER (title): Group Head OWNER GROUP: Chemistry

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE 1.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PRO GRA M ADM IN ISTRA TION ............................................................................ 5 1.1 D efinition and Basis ................................................................................................... 5 1.1.1 D efinition ................................................................................................... 5 1.1.2 Basis ............................................................................................................... 5 1.2 Responsibilities for Program Im plementation ........................................................... 6 1.2.1 Chem istry Functions ................................................................................. 6

a. Program scope ................................................................................. 6

b. Record keeping ............................................................................... 6

c. D ata monitoring ............................................................................... 7

d. D ata summary ................................................................................. 7

e. Contractor com munications ........................................................... 7

f. Reportable item s ............................................................................. 8 1.2.2 N on-Chem istry Functions ......................................................................... 9

a. Manual control and distribution ..................................................... 9

b. Program coordination...................................................................... 9 1.3 Quality A ssurance/Quality Control ........................................................................... 10 1.4 Program Revisions .................................................................................................... 11 Page 2 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING .............................. 11 2.1 Program Overview........................................................................... 11 2.1.1 Purpose ........................................................................... 11 2.1.2 Samples ........................................................................... 11 2.1.3 Monitoring sensitivity ........................................................... 11 2.2 Program Parameters ......................................................................... 12 2.2.1 Contamination avoidance ....................................................... 12 2.2.2 Sample size ....................................................................... 12 2.2.3 Lower limit of detection......................................................... 13 2.2.4 Notification levels................................................................ 14 2.2.5 Sampling locations ............................................................... 15 2.2.6 Sampling media and frequency ............................................ *.....15 2.2.7 Sample labeling .................................................................. 16 2.2.8 Sample shipping.................................................................. 16 2.2.9 Sample analyses and frequency................................................. 17 2.2.10 Analytical laboratory ............................................................ 17 2.3 Assistance to the State of Wisconsin ....................................................... 17 2.4 Specification of Sampling Procedures ..................................................... 18 2.4.1 Vegetation ........................................................................ 18 2.4.2 Thermoluminescent dosimeters (TLDs)........................................ 18 2.4.3 Lake water........................................................................ 19 2.4.4 Well water ........................................................................ 19 2.4.5 Air................................................................................. 19 2.4.6 Milk ............................................................................... 23 2.4.7 Algae .............................................................................. 24 2.4.8 Fish................................................................................ 25 2.4.9 Soil ................................................................................ 25 2.4.10 Shoreline Sediment ....................................................... ....... 26 2.5 Milk Survey .................................................................................. 26 Page 3 of 36 Page 3of 36INFORMATION USE

POINT B3EACH- NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE OF CONTENTS SECTION TITLE PAGE TABLE 2-1 RECOMMENDED MINIMUM SAMPLE SIZES ..................................... 27 TABLE 2-2 SAMPLE TYPES AND ASSOCIATED LOWER LEVEL OF DETECTION (LLD) AND NOTIFICATION LEVEL VALUES..................... 28 TABLE 2-3 RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ............... 30 TABLE 2-4 PBNP RADIOLOGICAL ENVIRONMENTAL SAMPLE COLLECTION AND ANALYSIS FREQUENCY ....................................................... 32 TABLE 2-5 SAMPLES COLLECTED FOR STATE OF WISCONSIN ........................... 33 FIGURE 2-l a RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ............... 34 FIGURE 2-lb RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ............... 35 FIGURE 2-1c RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ............... 36 Page 4 of 36 Page 4of 36INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 1.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ADMINISTRATION 1.1 Definition and Basis 1.1.1 Definition Radiological environmental monitoring is the measurement of radioactivity in samples collected from the atmospheric, aquatic and terrestrial environment around the Point Beach Nuclear Plant (PBNP). Monitoring radioactivity in effluent streams at or prior to the point of discharge to the environment is not part of the Radiological Environmental Monitoring Program (REMP).

1.1.2 Basis The REMP is designed to fulfill the requirements of 10 CFR 20.1302, PBNP GDC 17, GDC 64 of Appendix A to 10 CFR 50, and Sections IV.B.2 and IV.B.3 of Appendix I to 10 CFR 50.

No significant radionuclide concentrations of plant origin are expected in the plant environs because radioactivity in plant effluent is continuously monitored to ensure that releases are well below levels which are considered safe upper limits. The REMP is conducted to demonstrate compliance with applicable standards, to assess the radiological environmental impact of PBNP operations, and to monitor the efficacy of inplant effluent controls. The REMP, as outlined in Tables 2-2 through 2-4 is designed to provide sufficient sample types and locations to detect and to evaluate changes in environmental radioactivity.

Radioactivity is released in liquid and gaseous effluents. Air samplers and thermoluminescent dosimeters placed at various locations provide means of detecting changes in environmental radioactivity as a result of plant releases to the atmosphere. Because the land area around PBNP is used primarily for farming and dairy operations, sampling of vegetation is conducted to detect changes in radiological conditions at the base of the food chain. Sampling of area-produced milk is conducted because dairy farming is a major industry in the area.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL Water, periphyton, and fish are analyzed to monitor radionuclide levels in Lake Michigan in the vicinity of PBNP. Periphyton, attached algae, along with lake water samples, provide a means of detecting changes which may have a potential impact on the radionuclide concentrations in Lake Michigan fish. Because of the migratory behavior of fish, fish sampling is of minimal value for determining radiological impact specifically related to the operation of the Point Beach Nuclear Plant. However, fish sampling is carried out as a conservative measure with emphasis on species which are of intermediate trophic level and which exhibit minimal migration in order to monitor the status of radioactivity in fish.

Vegetation, algae, and fish sampling frequencies are qualified on an "as available" basis recognizing that certain biological samples may occasionally be unavailable due to environmental conditions.

1.2 Responsibilities for Program Implementation 1.2.1 Chemistry Functions Chemistry together with Regulatory Affairs (RA) provides the Plant Manager with the technical, regulatory, licensing, and administrative support necessary for the implementation of the program. The Chemistry administrative functions relating to the REMP fall into the six broad areas outlined below.

a. Program scope The scope of the REMP is determined by the cognizant Chemist based on sound radiological principles for the fulfillment of PBNP Technical Specifications (TS) and the applicable Federal Regulations. Based on the scope, the Environmental Manual (EM) is written to accomplish the collection and analyses of the necessary environmental samples. The EM is revised as necessary to conform to changes in procedures and scope.

Chemistry monitors the REMP effectiveness and compliance with TS and with the procedures and directives in the EM. In order to verify compliance with TS, Nuclear Oversight arranges for program audits and Supplier Assessments of the contracted radioanalytical laboratory.

b. Record keeping The monthly radioanalytical results from the contracted laboratory are reviewed by Chemistry and one copy of the monthly radioanalytical results from the contracted laboratory is kept for the lifetime of the plant.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

c. Data monitoring Chemistry reviews and interprets all program analytical results on a monthly basis as they are reported. Trends, if any, are noted. Any resulting corrections, modifications and additions to the data are made by Chemistry. Inconsistencies are investigated by Chemistry with the cooperation of Radiation Protection (RP) and contractor personnel, as required. Unusual results as evidenced by radioactivity levels exceeding administrative notification levels are also investigated. Results of the investigation will be conveyed to the Plant Manager. Chemistry will promptly inform the Plant Manager of any sample exceeding Nuclear Regulatory Commission (NRC) regulatory notification levels and will initiate an investigation. A formal report shall be provided to the Plant Manager upon completion of the investigation.

d. Data summary REMP results shall be summarized annually for inclusion in the PBNP Annual Monitoring Report. This summary advises the Plant Manager of the radiological status of the environment in the vicinity of PBNP. The summary shall include the numbers and types of samples as well as the averages, statistical confidence limits and the ranges of analytical results.

Methods used in summarizing data are at the discretion of Chemistry.

e. Contractor communications Communication with the contractor regarding data, analytical procedures, lower limits of detection, notification levels and contractual matters are normally conducted by Chemistry. Communication regarding sample shipment may be done by either RP or Chemistry as appropriate.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

f. Reportable items

1. Chemistry shall generate all technically-specified reports related to the operation of the REMP. The material included shall be sufficient to fulfill the objectives outlined in Sections IV.B.2 and IV.B.3 of Appendix I to 10 CFR 50. The following items and occurrences, are required to be reported in the PBNP Annual Monitoring Report:

(a) Summary and discussion of monitoring results including number and type of samples and measurements, and all detected radionuclides, except for naturally occurring radionuclides; (b) Unavailable, missing, and lost samples and plans to prevent recurrence and comments on any significant portion of the REMP not conducted as indicated in Tables 2-3 through 2-4.

(c) New or relocated sampling locations and reason for change; (d) LLDs that are higher than specified in Table 2-2 and factors contributing to inability to achieve specified LLDs; (e) Notification that the analytical laboratory does not participate in an interlaboratory comparison program and corrective action taken to preclude a recurrence; and (f) Results of the annual milk sampling program land use census "milk survey" to visually verify that the location of grazing animals in the vicinity of the PBNP site boundary so as to ensure that the milk sampling program remains as conservative as practicable.

2. The following items are required to be reported to the NRC within 30 days of occurrence pursuant to the criteria of Section 2.2.4:

(a) Confirmed environmental radionuclide concentrations, attributable to PBNP effluents, in excess of notification levels; (b) Confirmed results of weighted sum calculations involving radionuclide concentrations, attributable to PBNP effluents, in environmental samples in excess of the specified notification level; and Page 8 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL (c) The report shall, to the extent possible, identify the cause(s) for exceeding the limit(s) and define the corrective actions taken to reduce radioactivity in effluents so that the potential dose to a member of the public will not exceed the annual limits.

3. The annual results from the contracted REMP analytical laboratory as well as the laboratories analytical QA/QC results, in-house blanks, interlaboratory comparisons, etc., shall be transmitted to the NRC, Region III, with, or as a separate concurrent submittal, the Annual Monitoring Report.

4. The Annual Monitoring Report for the previous 12 month period, or fraction thereof, ending December 31, shall be submitted to the NRC by April 30 of the following year.

1.2.2 Non-Chemistry Functions The primary responsibility for the implementation of the PBNP REMP and for any actions to be taken at PBNP, based on the results of the program, resides with the Plant Manager.

a. Manual control and distribution The distribution of the PBNP Environmental Manual is the responsibility of Document Control.

b. Program coordination The daily operation of the program is conducted by PBNP Radiation Protection personnel, and other qualified personnel as required, under the supervision of an RP staff member who consults, as needed, with Chemistry. The daily administrative functions of the RP Management Employee address those functions required for the effective operation of the PBNP Radiological Environmental Monitoring Program. These administrative functions include the following:

1. Ensuring that samples are obtained in accordance with the type and frequency in Table 2-4 following procedures outlined in this manual;

2. Ensuring adequate sampling supplies and calibrated, operable equipment are available at all times;

3. Ensuring that air sampling pumps are maintained, repaired and calibrated as required and that an adequate number of backup pumps are readily available at all times; Page 9 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

4. Reporting lost or unavailable samples as well as other potential deviations from the sampling regime in Table 2-4 via the Corrective Action Program and notifying the cognizant Chemist.

5. Assisting the State of Wisconsin in obtaining samples at co-located and other sampling sites based upon a yearly, renewable agreement; and

6. Assisting Chemistry, as necessary, with investigations into elevated radioactivity levels in environmental samples.

1.3 Quality Assurance/Quality Control Quality assurance considerations are an integral part of PBNP's Radiological Environmental Monitoring Program. The program involves the interaction of Chemistry, site quality assurance and the contracted analytical vendor. The contracted vendor shall participate in an interlaboratory comparison program. The laboratory is audited periodically, either by PBNP or by an independent third party.

Quality control for the PBNP portion of the Radiological Environmental Monitoring Program is achieved by following the procedures contained in this manual. Health Physics Technologists (HPTs) collect, package and ship environmental samples under the supervision of Radiation Protection supervisors. They are advised by Radiation Protection Management who has immediate responsibility for the overall technical operation of the environmental sampling functions. The HPTs receive classroom training as well as on-the-job training in carrying out these procedures.

An audit of the PBNP Radiological Environmental Monitoring Program and its results shall be completed periodically as a means of monitoring program effectiveness and assuring compliance with program directives. The audit shall be performed in accordance with Section 1.4 of the ODCM.

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POINT BEACH NUCLEAR PLANT .EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 1.4 Program Revisions This manual describes the current scope of the PBNP Radiological Environmental Monitoring Program. Program items or procedures periodically may be updated or changed, consistent with good radiologically monitoring practices, either to reflect new conditions or to improve program effectiveness. Technical and program features described in this manual may be changed with the approval of the PORC and Plant Manager pursuant to the requirements stated in the ODCM.

2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING 2.1 Program Overview 2.1.1 Purpose No significant or unexpected radionuclide concentrations of plant origin are expected because each normal effluent pathway at PBNP is monitored at or before the release point. However, the REMP is conducted to verify that plant operations produce no significant radiological impact on the environment and to demonstrate compliance with applicable standards.

2.1.2 Samples Samples for the REMP are obtained from the aquatic, terrestrial and atmospheric environment. The sample types represent key indicators or critical pathways identified by applying sound radiological principles to the PBNP environment.

2.1.3 Monitoring sensitivity The effectiveness of the REMP in fulfilling its purpose depends upon the ability to accurately determine the nature and origins of fluctuations in low levels of environmental radioactivity. This requires a high degree of sensitivity so that it is possible to correctly discriminate between fluctuations in background radiation levels and levels of radioactivity that may be attributable to the operation of PBNP. Therefore, personnel actively participating in the monitoring program should make every effort to minimize the possibility of contaminating environmental samples and to obtain samples of the appropriate size.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2 Program Parameters 2.2.1 Contamination avoidance Contamination prevents the accurate quantification of environmental radioactivity and the correct differentiation between fluctuating background radioactivity and levels of radioactivity attributable to the operation of PBNP.

Therefore, it is necessary that all personnel associated with collecting and handling radiological environmental samples take the appropriate precautions to minimize the possibility of contaminating the samples. Some of the precautions that should be taken and which will help to minimize contamination are listed below:

a. Equipment which has been on the controlled side, even if released clean, should not normally be used in conjunction with radiological environmental monitoring. An exception to this is the HPTI equipment used to calibrate the air flow calibrator.

b. Store sampling equipment in radiologically clean areas only;

c. Store radiological environmental samples only in radiologically clean areas when samples cannot be shipped to the contractor on the same day they are collected;

d. Treat each sample as a possible source of contamination for other samples so as to minimize the possibility of cross-contamination;

e. Radiological environmental monitoring equipment should be repaired in clean-side shops;

f. Contamination avoidance for environmental TLDs is covered in Section 2.4.2; and

g. Avoid entering contaminated areas prior to collecting environmental samples.

2.2.2 Sample size Sample size affects the sensitivity achievable in quantifying low levels of environmental radioactivity. Therefore, sampling personnel must attempt to attain the quantities of sample specified in Table 2-1. When a range is given, every effort should be made to obtain a quantity at the upper part of the range.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2.3 Lower limit of detection The sensitivity required for a specific analysis of an environmental sample is defined in terms of the lower limit of detection (LLD). The LLD is the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with a 95% probability and have only a 5% probability of falsely concluding that a blank observation represents a real signal. Mathematically, the LLD is defined by the formula LLD-LLD

=4.66 Sb E x V x 2.22 x Y x EXP(-XA T)

Where LLD the a priori lower limit of detection in picocuries per unit volume or mass, as applicable; Sb the standard deviation of the background counting rate or the counting rate of a blank sample, as appropriate, in counts per minutes; E counting efficiency in counts per disintegration; V sample size in units of volume or mass, as applicable; 2.22 number of disintegrations per minute per picocurie; Y = the fractional chemical yield as applicable;

2. = the radioactive decay constant for the particular radionuclide; and AT the elapsed time between sample collection, or the end of the collection period, and the time of counting.

Typical values of E, V, Y, and AT are used to calculate the LLD. As defined, the LLD is an apriori limit representing the capability of a measuring system and not an a posteriori limit for a particular measurement.

The required analysis for each environmental sample and the highest acceptable LLD associated with each analysis are listed in Table 2-2.

Whenever LLD values lower than those specified in Table 2-2 are reasonably achievable, the analytical contractor for the radiological environmental samples will do so. When the LLDs listed in Table 2-2 are not achieved, a description of the factors contributing to the higher LLD shall be reported in the next PBNP Annual Monitoring Report.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2.4 Notification levels The Notification Level (NL) is that measured quantity of radioactivity in an environmental sample which, when exceeded, requires a notification of such an occurrence be made to the appropriate party. Regulatory and administrative notification levels are listed in Table 2-2.

a. Regulatory notification levels The regulatory notification levels listed in Table 2-2 represent the concentration levels at which NRC notification is required. If a measured level of radioactivity in any radiological environmental monitoring program sample exceeds the regulatory notification level listed in Table 2-2, resampling and/or reanalysis for confirmation shall be completed within 30 days of the determination of the anomalous result. If the confirmed measured level of radioactivity remains above the notification level, a written report shall be submitted to the NRC. If more than one of the radionuclides listed in Table 2-2 are detected in any environmental medium, a weighted sum calculation shall be performed if the measured concentration of a detected radionuclide is greater than 25%

of the notification levels. For those radionuclides with LLDs in excess of 25% of the notification level, a weighted sum calculation needs to be performed only if the reported value exceeds the LLD. Radionuclide concentration levels, called Weighted Sum Action Levels, which trigger a weighted sum calculation are listed in Table 2-2.

The weighted sum is calculated as follows:

concentration (1) + concentration (2) + ... =weighted sum notification level (1) notification level (2)

If the calculated weighted sum is equal to or greater than 1, resampling and/or reanalysis for confirmation shall be completed within 30 days of the determination of the anomalous result. If the confirmed calculated weighted sum remains equal to or greater than 1, a written report shall be submitted to the NRC. This calculation requirement and report is not required if the measured level of radioactivity was not the result of plant effluents.

b. Administrative notification levels The administrative notification levels are the concentration levels at which the contracted analytical laboratory promptly notifies the cognizant Chemistry Specialist by phone, followed by a formal written communication. The administrative notification levels are set lower than the NRC regulatory notification levels and lower than, or equal to, the weighted sum action levels so that the nature and origin of the increased level of environmental radioactivity may be expeditiously ascertained and corrective actions taken if required.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2.5 Sampling locations A list of sampling locations and the corresponding location codes appear in Table 2-3. The locations also are shown in Figures 2-la, 2-1b, and 2-1c. It is conceivable that samples may become unavailable from specified sample locations. If this were to occur, new locations for obtaining replacement samples shall be identified and added to the Radiological Environmental Monitoring Program. If milk or vegetation samples become unavailable from the specified sampling locations, new sampling locations will be identified within 30 days. The specific locations where samples were unavailable may be deleted from the monitoring program. A formal, written reason for the new site and its location shall be transmitted to Chemistry who will make the appropriate changes to the Environmental Manual. Any significant changes in existing sampling location and the criteria for the change shall be reported in the Annual Monitoring Report for the period in which the change occurred.

Additional sampling locations may be designated if deemed necessary by cognizant company personnel. Figures and tables in this manual shall be revised to reflect the changes.

2.2.6 Sampling media and frequency The sampling frequency for the environmental media required by the PBNP REMP is found in Table 2-4. In addition to samples required by the former Technical Specifications, the Radiological Environmental Monitoring Program also includes the sampling of soil and shoreline sediment. To ensure that all samples are obtained at the appropriate times, a checklist is used. The checklist provides a month-by-month indication of all samples, to be obtained at each sampling location (PBF-4121a through 41211). These checklists also identify the schedule for the annual milk survey and provides space for recording the date samples were shipped offsite for analysis. In addition, the checklist lists each sampling location to identify all samples, to be obtained and the collection date. Because the weekly air samples require additional information, a separate checklist is used for each individual air sampling location for calculations and other information as shown in PBF-4078.

It is recognized that on occasions samples will be lost or that samples cannot be collected at the specified frequency because of hazardous conditions, seasonable unavailability, automatic sampling equipment malfunctions and other legitimate reasons. Reasonable efforts will be made to recover lost or missed samples if warranted and appropriate. If samples are not obtained at the indicated frequency or location, the reasons or explanations for deviations from the sampling frequency specified in Table 2-4 shall be submitted to the PBNP Corrective Action Program.

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POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2.7 Sample labeling All samples must be properly labeled to ensure that the necessary information is conveyed to the analytical contractor and that the results are associated with the correct geographical location. Each label (PBF-4026) must contain the following:

a. Sample type;

b. Sample location from Table 2-3;

c. Date and time (as appropriate) collected;

d. Air samples must show the total volume in m3; volumes for water and milk are in gallons; vegetation, sediment, soil, and algae are indicated as

<1000 grams; and fish Ž1000 grams;

e. Analyses for routine samples are indicated as "per contract." For special samples, the Radiation Protection manager or another Radiation Protection Management Employee will designate the analyses required; and

f. Name of person collecting the sample.

A permanent or indelible ink type felt-tip marker shall be used.

A separate sample label is needed for each sample type and location.

Labels are securely attached to each sample container. In addition to sample labels, other identifying markings may be placed on sample containers as appropriate.

2.2.8 Sample shipping All environmental samples are shipped to a contractor for analysis. The samples shall be packaged and shipped in such a way as to minimize the possibility of cross-contamination, loss, spoilage and leakage. Each sample shipment shall have a typed cover letter and, when appropriate, a contractor data collection sheet. Included in the letter shall be the same information required for the sample labels as well as the specific analyses .required. The original cover letter and data collection sheet shall be sent to the contractor under separate cover; one copy of each is to be used as a packing list and a copy of each shall be kept in the appropriate PBNP file.

Page 16 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.2.9 Sample analyses and frequency The PBNP REMP samples shall be analyzed for designated parameters at the frequency listed in Table 2-4. Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to effluents from PBNP. Typically, this entails the scanning of the spectrum from 80 to 2048 keV and decay correcting identified radionuclides to the time of collection. The analysis specifically includes, but is not limited to, Mn-54, Fe-59, Zn-65, Co-58, Co-60, Zr-Nb-95, Ru-103, 1-131, Cs-134, Cs-137, Ba-La-140, Ce-141, and Ce-144.

2.2.10 Analytical laboratory The analyses shall be performed by a laboratory that participates in an interlaboratory crosscheck program. If the laboratory is not participating in such a program, a report shall be made pursuant to 1.2.1 .f. 1.(e). The current laboratory is:

Environmental Incorporated Midwest Laboratory 700 Landwehr Road Northbrook, IL 60062-4517 (847) 564-0700 This laboratory performs the analyses in such a manner as to attain the desired LLDs. The contracted laboratory participates in an inter-laboratory comparison crosscheck program.

The contractor is responsible for providing prompt notification to the cognizant Chemist regarding any samples found to exceed the administrative notification levels as identified in Table 2-2.

2.3 Assistance to the State of Wisconsin As a courtesy and convenience, PBNP personnel obtain certain environmental samples for the Section of Radiation Protection, Department of Health and Family Services of the State of Wisconsin as listed in Table 2-5. A checklist is used. In addition, a State of Wisconsin air sampling data sheet is submitted with each sample obtained at Wisconsin air sampling locations serviced by PBNP personnel.

State of Wisconsin precipitation samples collected twice a month (or as available) require a state sample tag to be placed in a box with the quart cubitainer. State supplied labels for air particulate filters require start and stop time, date and beginning and ending volume. Fish sent to the state identify only the quarter and the year using a PBNP label (PBF-4026). The monthly lake water sample may be picked up by state personnel and in which case these samples require only that the date and location be written on the box for the cubitainer. The well water samples, 2 times/year, may be picked similar to lake water samples.

Page 17 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL Samples obtained for the State of Wisconsin are either given directly to state personnel or shipped as required. The department address is:

State Lab of Hygiene Radiochemistry Unit 2601 Agriculture Dr.

PO Box 7996 Madison, Wisconsin 53707-7996 2.4 Specification of Sampling Procedures General radiological environmental sampling procedures follow the directives presented in Sections 2.1 and 2.2. Specific information for handling individual sample types follow.

2.4.1 Vegetation Vegetation samples consist of green, growing grasses and weeds and are obtained three times per year, as available, from specified locations. New growth, not dead vegetation, should be used because these samples are indicators of recent atmospheric deposition. Use a scissors or other sharp cutting tool to cut the grasses and weeds off as close to the ground as possible.

Do not include plant roots and take care not to contaminate the sample with soil. Total sample collected should exceed 500 grams and ideally should be 1000 grams. Place entire sample in an appropriate container, such as a plastic bag (tape the bag shut) and label the container as described in Section 2.2.7.

2.4.2 Thermoluminescent dosimeters (TLDs)

TLDs capable of multiple, independent measurements of the same exposure are posted at locations specified in Table 2-4 and are changed quarterly. The utmost care in handling is required to minimize unnecessary exposure during transit, storage and posting because the TLDs begin recording all radiation from the moment they are annealed (heated to rezero) at the contractor's laboratory. Packages of TLDs in transit should be marked "DO NOT X-RAY."

Transportation control (TLDs) shall accompany the new batch in transit from the contractor's laboratory to the plant. The control TLDs shall accompany the batch during brief storage and subsequent posting. The same control TLDs shall accompany the "old" or exposed batch on its way back to the contractor. Therefore, each control represents the sum of approximately half the in-transit exposure of the two batches. This control system is able to identify any unusual in-transit exposure.

Page 18 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL Environmental TLDs should never be brought into the plant RCA or any other area with elevated radiation, but may be stored for brief periods in a shielded enclosure in the RP Office Area or other low background area, such as the Energy Information Center or the Site Boundary Control Center. The contractor is to time shipments to coincide as closely as possible with the beginning of a calendar quarter. TLDs should be shipped back to the contractor immediately or within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of removal. The contractor is instructed to process the samples immediately upon receipt. The contractor shall report removal data and cumulative readings in mR for all locations and control, correct for in-transit exposure and express results in net mR/7 days.

Labels of the exposed set for shipment to contractor should show both posting and removal dates.

2.4.3 Lake water Lake water samples are obtained monthly at specified locations. The contractor is responsible for the compositing for quarterly analyses. Collect approximately 8000 ml of lake water in the required number of cubitainers, or other appropriate containers, at each location and label as directed in Section 2.2.7.

Also, lake water is collected for the State of Wisconsin pursuant to Table 2-5.

The sample is collected, labeled, and forwarded to the appropriate State agency.

2.4.4 Well water Well water samples are obtained quarterly from the single onsite well.

Sample should be obtained from PW-80, T-90 Hydro-pneumatic Tank Drain After purging 8 gallons, collect approximately 8000 ml of well water using the required number of cubitainers or other appropriate containers. Label as directed in Section 2.2.7.

2.4.5 Air

a. Sample collection Air filters are changed weekly at specified locations and placed in glassine envelopes for shipment to the vendor for analyses. Take precautions to avoid loss of collected material and to avoid contamination when handling filters. Washing hands before leaving the plant to change filters is a recommended practice.

Page 19 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL Both particulate filters and charcoal cartridges are employed at each sampling location. Particulate filters are analyzed for gross beta activity after waiting for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to allow for the decay of short-lived radon and thoron daughter products. The contractor makes quarterly composites of the weekly particulate samples for gamma isotopic analyses.

A regulated pump (Eberline Model RAS-1 or equivalent) is used at each air sampling location. Because of the automatic flow regulation, rotameter readings at the beginning and ending of the sampling period should be nearly identical. Substantial differences in readings usually require some investigation to determine the cause. The rotameters attached to the pumps are calibrated in liters per minute. When new filters are installed, flow rate should be about 28-30 lpm. Flow rates less than 26 1pm or greater than 32 1pm require that the pump regulator be readjusted. The correct flow rate is determined by multiplying the rotameter reading by the correction factor indicated on the calibration sticker affixed to the.

rotameter.

Some pumps are equipped with an elapsed time meter which reads in hours. Form PBF-4078 is used for recording pertinent air sampling data for each location. At a normal filter change, the following procedure will apply:

1. Record "date off" and "time off."

2. Record rotameter reading for end of period (R2 ).

.3. Turn off pump, if necessary, and record hour meter reading or actual time for end of period (t2 ).

4. Before removing the filter, label the sample envelope as directed in Section 2.2.7. Also enter any other pertinent information at this time. Always write data on the envelope before inserting the particulate filter in the envelope.

5. Remove particulate filter being careful to handle filter only by edges, place in the glassine envelope.

6. Remove charcoal cartridge, place in plastic bag, and label as directed in Section 2.2.7.

7. Install new charcoal cartridge and particulate filter being sure to check the charcoal cartridge for breaks and the particulate filter for holes in the filter surface. Discard unacceptable filter media.

Page 20 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

8. Record "date on."

9. Record hour meter reading or time for beginning of period (tj).

10. Turn pump on (if necessary).

11. Perform weekly gross leak test by blocking the air flow with a large rubber stopper. (For this test only, the rofameter ball may register zero or drop all the way to the bottom. The difference between zero and the bottom is not significant.)

12. Record rotameter reading for beginning of period (R1).

13. Record correction factor as indicated on calibration sticker affixed to rotameter (C).

14. Observe that the starting rotameter reading (R1 ) is close to the previous ending reading (R2 ). A substantial difference indicates need for further investigation because the regulator will generally maintain constant flow regardless of filter loading.

15. Calculate total volume for period and enter on data sheet (m 3). (This step may be performed at a later time.)

16. Any unusual conditions or observations should be referenced under

(*) and recorded under "*NOTES" at the bottom of the data sheet.

Air samples are collected for the State of Wisconsin at two locations, one of which is co-located with a PBNP air sampling site. They are handled in a manner similar to PBNP samples except that no charcoal cartridges are involved. However, state samplers are equipped with volume integrating meters. Therefore, clock time must be recorded in addition to the ending and beginning volumes.

Label and forward samples to the State.

Page 21 of 3 6 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

b. Air sampling system description The air monitoring equipment for the PBNP air sampling program consists of a Regulated Rate Control System. The Regulated Rate Control System is used at PBNP because of its simplicity and reliability. It is designed to minimize both calibration difficulties and the potential for leaks. The regulated rate control system includes a pump, a flow regulator, the appropriate filter holders and a minimum of tubing. Also, it may include an elapsed time meter. In this system, the total volume sampled can be calculated simply and accurately from the elapsed time and the flow rate which is kept constant by the regulator regardless of filter loading.

The air samplers are Eberline Model RAS-1 (or equivalent) and have built-in rotameters which read in liters per minute. The systems also include an Eberline WPH-1 (or equivalent) weatherproof housing and an iodine cartridge holder and mounting kit and may include an electric hour meter. Glass fiber, 47 mm diameter, particulate filters capable of collecting 95% of 1 micron diameter particles and iodine impregnated charcoal cartridges (Scott or equivalent) constitute the filter media.

c. Calibration Calibrate the pump rotameter at initial installation and at yearly intervals thereafter by connecting a laboratory-quality reference flow meter with NIST traceable calibration to the filter face with the particulate filter and charcoal cartridge in position. Upon completion, a calibration sticker indicating the correction factor is affixed to, or near, the built-in rotameter.

The results are recorded on Form PBF-4020.

d. Inspection and maintenance Weekly gross leak checks shall be accomplished as indicated in the appropriate PBNP procedure.

Page 22 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL For normal operation, the regulators should be adjusted to maintain a true flow rate of 28-30 liters per minute. Adjustments are made by turning the screw marked FLOW ADJUST located on the side of the regulator body:

counterclockwise increases flow, clockwise decreases flow. Flow rates should be observed at all filter changes. Flow rates less than 26 1pm or more than 32 1pm require readjustment of the regulator. Particular attention should be paid to flow rate readings with the "old," loaded filter and with new, unused filters in position. Because of the regulator, the difference in flow should be barely perceptible, perhaps no more than one lpm. Significant differences in flow rates require further investigation to determine the cause.

Preventive maintenance shall be performed as indicated in the appropriate PBNP procedure on all environmental air samplers and the results recorded on Form PBF-4020.

e. Pump repair and replacement The pumps can operate for long periods of time with minimal or no maintenance. The vane assembly of the pump is most susceptible to failure, indicated by excessive noise or inability to maintain sufficient flow across loaded filters. At least one standby pump should be available for temporary service during the repair period. In the event of motor failures due to causes other than defective connections, complete replacement of the unit may be necessary. All pump repairs should be done in a clean-side shop with clean tools.

2.4.6 Milk Because of iodine decay and protein binding of iodine in aging milk samples, speed is imperative in processing and samples must be kept cool to avoid degradation and spoilage of the samples. Milk samples are obtained monthly in conjunction with the State of Wisconsin Milk Sampling Program from three individual dairy farmers located north, south, and west of the site. Milk sampling data can also be obtained from the Kewaunee Nuclear Power Plant, whose radiological environmental monitoring program includes samples taken from a dairy in Green Bay, WI. This location could act as a control location.

Because two of the three sites are co-located, the PBNP pickup is coordinated to coincide with the State arranged schedule. The pickup usually will be the first Wednesday of the month.

The following sequence should be followed:

a. After verifying the State milk pickup date with the Manitowoc Public Health Department (Mr. Mark Chatenka, phone number 683-4454), notify Mr. Leon Strutz (755-2060) of the pickup date. This must be done because the Strutz farm (PBNP sampling location E-21) is not a State of Wisconsin sampling site.

Page 23 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL

b. Because the milk must be kept cool, but not frozen, fill enough cubitainers, or other appropriate containers, with water and freeze to be able to put one in each shipping container. Fill the containers with water and freeze the day preceding the pickup.

c. The milk from the Strutz farm (E-21) must be picked up before 0900 because that is the time the Strutz milk is shipped. A late arrival may mean a missed sample. Milk from sites E-1 1 and E-40 may be picked up any time after the Strutz pickup.

d. Identify yourself and the nature of your business at each milk pickup site.

Collect two one-gallon samples from each site, using a funnel if necessary.

If shipment cannot occur on the collection day, store the milk in a clean-side refrigerator overnight. DO NOT FREEZE.

e. Complete a PBNP sample tag according to Section 2.2.7 for each gallon sample and place in the box with the sample. Do not seal the box. Place the samples in insulated containers and turn them over to Ready Stores personnel for shipment. Make sure that the cover letter and, as appropriate, the contractor data collection sheets are sent according to Section 2.2.8 of this manual.

2.4.7 Algae Filamentous algae are collected from pilings or rocks three times per year, as available, from two locations. The long, grassy, dark green algae can normally be cut with scissors. The shorter, light green algae normally must be scraped from rocks or pilings. When scraping algae, be careful not to include pieces of rock in the sample. The sample can be lightly rinsed in the same medium in which it is growing. This rinse will help rid the sample of pieces of rock and gravel that may have been inadvertently collected with the sample. Because rocks and sediment contain naturally occurring radioactive materials, their inclusion may give false sample results. Collect between 100 and 1000 gma of algae. A sample greater than 500 gm is preferred. Place the algae in a wide-mouth poly bottle or other appropriate container and label the container as director in Section 2.2.7. The algae must be kept cool to prevent spoilage.

Page 24 of 36 Page24 o 36INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL 2.4.8 Fish Fish are obtained three times per year (March, August and December) as available either from the traveling screens as washed into the fish basket or by other methods as required. For any given sampling period, three fish, or a sufficient number to yield at least 1000 gm of fillets, should be provided.

Place fish in plastic bags and tape and/or tie tightly closed. Fish are stored briefly in a radiologically clean freezer. It may be desirable in warm weather to coordinate milk and fish sampling, thereby allowing simultaneous shipment in insulated containers. Pack fish samples with ice if needed. Label bags as directed in Section 2.2.7, being sure to indicate fish species when possible.

Following packaging of fish, remove and discard any fish left in the freezer.

This avoids sending fish that are not representative of the sampling period.

Fish are obtained four times per year (March, June, September and December) for the State of Wisconsin. Fish sampling for the State is performed in the same manner as that for the plant. Approximately four fish should be sent to the state at each sampling period.

2.4.9 Soil Soil integrates atmospheric deposition and acts as a reservoir for long-lived radionuclides. Although soil sampling is a poor technique for assessing small incremental releases and for monitoring routine releases, it does provide a means of monitoring long-term trends in atmospheric deposition in the vicinity of PBNP. Therefore, soil samples are obtained two times per year from specified locations.

Clear the vegetation from a 6" x 6" area, being careful to leave the top layer of soil relatively intact. Remove root bound soil by shaking the soil onto the cleared area or into the sample container before discarding the roots. When necessary, it is preferable to leave some roots in the soil rather than to lose the top layer of soil.

Remove the soil to a depth of three inches. If necessary, expand the area, instead of digging deeper, to obtain the required amount of sample. If an area larger than 6" x 6" is used, notify Chemistry of the area used. The minimum acceptable quantity is 500 grams. Place the entire soil sample in a wide-mouth poly bottle or another appropriate container. If a plastic bag is used, seal the bag with tape. Label the sample as directed in Section 2.2.7.

Page 25 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL This procedure assumes that the samples are obtained from undisturbed land; land that has not been plowed within approximately the last 25 years. If the land has been plowed, the soil should be sampled to the plow depth which typically is eight inches. Place the soil in a clean bucket or appropriate size plastic bag, homogenize the soil and place 1000 grams of the well mixed soil sample in a plastic bag, or other appropriate container, and label as described Above.

2.4.10 Shoreline Sediment Shoreline sediment consisting of sand and smaller grain size material is sampled two times per year from specified locations. The 1000 gram sample is collected, from beach areas near the water ridge. At each location collect representative samples of sediment types roughly in proportion to their occurrence. For example, at E-06 avoid collecting a sample which consists exclusively of the dark-brown to black sediments which occur in layers up to several inches thick. Package the sample in a wide-mouth poly bottle or other appropriate container and label as described in Section 2.2.7.

2.5 Milk Survey The milk sampling program is reviewed annually, including a visual verification of animal grazing in the vicinity of the site boundary, to ensure that sampling locations remain as conservative as practicable. The verification is conducted each summer by cognizant PBNP personnel. Because it is already assumed that milk animals may graze up to the site boundary, it is only necessary to verify that these animals have not moved onto the site. No animal census is required. Upon completion of the visual check, RP personnel will notify Chemistry in writing. To ensure performance of the annual verification, "milk review" is identified on the sampling checklist (i.e., the PBF-4121 a-l series).

Page 26 of 36 Page26 o 36INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-1 RECOMMENDED MINIMUM SAMPLE SIZES Sample Type Size Vegetation 100-1000 gm Lake Water 8 liters (2 gal) 3 Air Filters 250 m Well Water 8 liters (2 gal)

Milk 8 liters (2 gal)

Algae 100-1000 gm Fish (edible portions) 1000 gm Soil 500-1000 gm Shoreline Sediment 500-1000 gm Page 27 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-2 SAMPLE TYPES AND ASSOCIATED LOWER LEVEL OF DETECTION (LLD) AND NOTIFICATION LEVEL VALUES NOTIFICATION LEVELS WEIGHTED SAMPLE REPORTING NRC PBNP1 '* SUM TYPE UNIT PARAMETER LLD(a) (Regulatory) (Admin.) ACTION LEVEL Vegetation pCi/g wet Gross Beta 0.25 --- 60 ---

Cs-137 0.08 2 0.40 0.50 Cs-134 0.06 1 0.20 0.25 1-131 0.06 0.1 0.06 0.06 Other(c) 0.25 --- 2.0 ---

Shoreline pCi/g dry Gross Beta 2.0 --- 100 ---

Sediment and Cs-137 0.15 --- 20 ---

Soil Other(c) 0.15 --- 20 ---

Algae pCi/g wet Gross Beta 0.25 --- 12 ---

Cs-137 0.25 10 1 2.5 Cs-134 0.25 10 1 2.5 Co-58 0.25 10 1 2.5 Co-60 0.25 10 1 2.5 Other(c) 0.25 --- 1 ---

Fish pCi/g wet Gross Beta 0.5 --- 125 ---

Cs-137 0.15 2 0.40 0.50 Cs-134 0.13 1 0.20 0.25 Co-58 0.13 30 3 7.5 Co-60 0.13 10 1 2.5 Mn-54 0.13 30 3 7.5 Fe-59 0.26 10 1 2.5 Zn-65 0.26 20 2 5.0 Other(c) 0.5 --- 6 ---

TLDs mR/7 days Gamma Exposure lmR/TLD --- 5mR/7 days LakewaterW) pCi/L-T.S.(d) Gross Beta 4 --- 100 ---

and Well Water Cs-134 15 30 15 15 Cs-137 18 50 18 18 Fe-59 30 400 40 100 Zn-65 30 300 30 75 Zr-Nb-95 15 400 40 100 Ba-La-140 15 200 20 50 Co-58 15 1,000 100 250 Co-60 15 300 30 75 Page 28 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-2 Lakewater pCi/L-T.S.(d) Mn-54 15 1,000 100 250 and Well Water 1-131 2 2 (Continued) Other 30 100 H-3 3,000 30,000 3,000 7,500 Sr-89 10 50 Sr-90 2 20 Milk pCi/L Sr-89 5 100 Sr-90 1 100 1-131 0.5 3 0.5 0.75 Cs-134 15 60 15 15 Cs-137 18 70 18 18 Ba-La- 140 15 300 30 75 OtherCc) 15 30 3

Air Filter pCi/m Gross Beta 0.01 1.0 1-131 0.07 0.9 0.09 0.2 Cs-137 0.06 20 2.0 5.0 Cs-134 0.05 10 1.0 2.5 Other(c) 0.1 1.0 (a) The LLDs in this column are the maximum acceptable values.

(b) The values in this column are not technical specifications.

(c) Other refers to non-specified identifiable gamma emitters.

(d) T.S. = total solids.

(e) No drinking water Page 29 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-3 RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Location Code Location Description E-01 Primary Meteorological Tower, South of the plant E-02 Site Boundary Control Center - East Side of Building E-03 Tapawingo Road, about 0.4 Miles West of Lakeshore Road E-04 North Boundary E-05 Two Creeks Park E-06 Point Beach State Park - Water and shoreline sediment samples at the Coast Guard Station; soil and vegetation from the Point Beach State Park campground area N of the Coast Guard Station and on the W side of County Road 0; TLD located South of lighthouse on telephone pole.

E-07 WPSC Substation on County Rt. V, about 0.5 Miles West of Hwy. 42 E-08 G. J. Francar Property, at the Southeast Corner of the Intersection of Cty. B and Zander Road E-09 Nature Conservancy E-10 PBNP Site Well E-l I Dairy Farm (W. Funk), about 3.75 Miles West of Site E-12 On fence at U-2 discharge flume E-13 Pumphouse E-14 South Boundary, about 0.2 miles East of Site Boundary Control Center E-15 Southwest Corner of Site E-1 6 WSW, Hwy. 42, Residence, about 0.25 miles North of Nuclear Road E-1 7 North of Mishicot, Cty. B and Assman Road, Northeast Corner of Intersection E-18 Northwest of Two Creeks at Zander and Tannery Roads E-20 Reference Location, 17 miles Southwest, at Silver Lake College E-21 Local Dairy Farm just South of Site (L. Strutz) on Lakeshore and Irish Roads E-22 West Side of Hwy. 42, about 0.25 miles North of Johanek Road E-23 Greenfield Lane, about 4.5 Miles South of Site, 0.5 Miles East of Hwy. 42 E-24 North Side of County Rt. V, near intersection of Saxonburg Road E-25 South Side of County Rt. BB, about 0.5 miles West of Norman Road E-26 804 Tapawingo Road, about 0.4 miles East of Cty. B. North Side of Road E-27 Intersection of Saxonburg and Nuclear Roads, Southwest Corner, about 4 Miles WSW E-28 TLD on westernmost pole between the 2nd and 3rd parking lots, E-29 On fence near propane tank NE of Warehouse #8 E-30 NE corner at Intersection of Tapawingo and Lakeshore Roads.

E-31 On utility pole North side of Tapawingo Road closest to the gate at the West property line Page 30 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-3 E-32 On a tree located at the junction of property lines, as indicated by trees and shrubs, about 500 feet east of the west gate in line with first designated treeline on Tapawingo Road and about 1200 feet south of Tapawingo Road. The location is almost under the power lines between the blue and gray transmission towers.

E-33 Lake Michigan shoreline accessed from SE comer of KNPP parking lot. Sample south of creek.

E-38 On tree W of former Retention Pond site E-39 On tree E of former Retention Pond site E-40 Local Dairy Farm, about 1.8 miles north of intersection of Highway 42 and Nuclear Road (Manitowoc County), on West side of Highway 42.

E-TC Transportation Control; Reserved for TLDs Page 31 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-4 PBNP RADIOLOGICAL ENVIRONMENTAL SAMPLE COLLECTION AND ANALYSIS FREQUENCY Sample Type Sample Codes Analyses Frequency Environmental Radiation E-01, -02, -03, -04, -05, TLD Quarterly Exposure -06, -07, -08, -09, -12,

-14, -15, -16, -17, -18,

-20, -22, -23, -24, -25,.

-26, -27, -28, -29, -30,

-31, -32,

-38, -39, -TC Vegetation E-01, -02, -03, -04, -06, Gross Beta 3x/yr as available

-08, -09, -20, Gamma Isotopic Analysis Algae E-05, -12 Gross Beta 3x/yr as available Gamma Isotopic Analysis Fish E-13 Gross Beta 3x/yr as available Gamma Isotopic Analysis (Analysis of edible portions only)

Well Water E-10 Gross Beta, H-3 Quarterly Sr-89, 90, 1-131 Gamma Isotopic Analysis (on total solids)

Lake Water E-01, -05, -06, Gross Beta Monthly

-33 H-3, Sr-89, 90 Quarterly composite of monthly collections 1-131 Monthly Gamma Isotopic Analysis Monthly (on total solids)

Milk E- 1, -21, -40 Sr-89, 90 Monthly 1-131 Gamma Isotopic Analysis Air Filters E-01, -02, -03, -04, Gross Beta Weekly (particulate)

-08, -20 1-131 Weekly (charcoal)

Gamma Isotopic Analysis Quarterly (on composite particulate filters)

Soil E-01, -02, -03, -04, Gross Beta 2x/yr

-06, -08, -09, -20, Gamma Isotopic Analysis Shoreline Sediment E-01, -05, -06, -12, Gross Beta 2x/yr

-33 Gamma Isotopic Analysis Page 32 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL TABLE 2-5 SAMPLES COLLECTED FOR STATE OF WISCONSIN Sample Type Location Frequency I. Lake Water E-01 Monthly

2. Air Filters E-07 Weekly E-08

3. Fish E- 13 Quarterly, As Available

4. Precipitation E-04 Twice a month, E-08 As Available

5. Milk E-1 I Monthly E-40

6. Well Water E-10 2 times/year Page 33 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL FIGURE 2-1a RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Ml 1-C, C'

I, POINT BEACH NUCLEAR PLANT RADIOLOGICAL ENVIRONMENTAL MONITORING 0 PROGRAM 1 SITES

........ ,MILE 1

KILOMETER 0 r

5111E,010 MAY 2005 Page 34 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL.

FIGURE 2-lb RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS Page 35 of 36 INFORMATION USE

POINT BEACH NUCLEAR PLANT EM ENVIRONMENTAL MANUAL Revision 20 November 11, 2008 ENVIRONMENTAL MANUAL FIGURE 2-1c RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS P801 650C.dgn /30/2'005 8:11:44 AM Page 36 of 36 INFORMATION USE

NRC-2009-0046, Annual Monitoring Report, Cover Letter Through Part D, Groundwater Monitoring

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NRC-2009-0046, Annual Monitoring Report, Cover Letter Through Part D, Groundwater Monitoring

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