PNP 2012-047, 2011 Radiological Environmental Operating Report, Letter Through Attachment 3

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2011 Radiological Environmental Operating Report, Letter Through Attachment 3
ML12215A334
Person / Time
Site: Palisades Entergy icon.png
Issue date: 05/14/2012
From: Gustfson O
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2012-047
Download: ML12215A334 (51)


Text

.=::. Entergy PNP 2012-047 May 14, 2012 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert. MI 49043 Tel 269 764 2000 Otto W. Gustfson Licensing Manager 10 CFR 50, Appendix I Technical Specification 5.6.2

Subject:

2011 Radiological Environmental Operating Report Palisades Nuclear Plant Docket 50-255 License No. DPR-20

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is submitting the enclosed Radiological Environmental Operating Report for the Palisades Nuclear Plant. This report was prepared in accordance with the requirements of 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, IV.C, and Technical Specification 5.6.2. The period covered by the enclosed report is January 1, 2011, through December 31,2011.

This letter contains no new commitments and no revision to existing commitments.

Sincerely, OWG/bed

Enclosure:

Radiological Environmental Operating Report, January 1 2011, Through December 31,2011 CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ENCLOSURE RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 1, 2011, THROUGH DECEMBER 31, 2011 TABLE OF CONTENTS I.

INTRODUCTION..............................................................................

1 II.

NON-ROUTINE REPORTS..............................................................

1 III. DISCUSSION AND INTERPRETATION OF RESULTS A.

B.

C.

D.

E.

F.

G.

H.

I.

J.

K.

Air Samples............................................................................

Lake Water.............................................................................

Drinking Water.........................................................................

Milk.........................................................................................

TLDs - Gamma Dose.............................................................

Crops......................................................................................

Sediment.................................................................................

Fish........................................................................................

Broad Leaf Vegetation...........................................................

Non-Routine Samples.............................................................

Gaseous and Liquid Radwaste Effluent Composite Samples.

IV. ASSESSMENT OF PALISADES OPERATION 1

2 2

3 3

4 4

4 5

7 7

ENVIRONMENTAL IMPACT..................................................................

8 V. TABLES A.

B.

C.

Table 10.4-1 Sampling and Analysis Summary......................

Table 10.4-2 Sample Data Summary.....................................

Table 10.4-3 Greatest Mean Sampling Location....................

VI. ATTACHMENTS

1.

Sample Collection Anomalies

2.

2011 Land Use Census Report 9

10 12

3.

Chemistry Procedure CH 6.10, "Radiological Environmental Program"

4.

REMP Year End Report for PAll for 2011 - Palisades REMP

5.

GEL Laboratories, LLC, Interlaboratory Comparison Program Results

6.

Data Graphs 1.

Palisades Air Particulate Gross Beta Pre-Operational vs.

Operational Comparison Graphs, 1968-1969 (pre-op) and 2003-2011 Page i of ii

T able of Contents Cont...

2.

Water Samples Gross Beta 2003-2011

3.

Palisades Quarterly Thermoluminescent Dosimeters Pre-Op and 2003-2011 Page ii of ii

ENCLOSURE RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 1, 2011, THROUGH DECEMBER 31, 2011 I.

INTRODUCTION The Radiological Environmental Operating Report provides a summary and data interpretation of the Palisades Nuclear Plant (PNP) Radiological Environmental Monitoring Program (REMP) as conducted during the 2011 reporting period. This report was prepared in accordance with the requirements of 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, IV.C, and Technical Specification 5.6.2.

II.

NON-ROUTINE REPORTS No reportable events occurred during this reporting period.

III. DISCUSSION AND INTERPRETATION OF RESULTS A.

Air Samples There were 260 air samples collected and analyzed for gross beta and 1-131. Air iodine/particulate samples are collected weekly from five air-sampling locations. Air is metered into the sampling unit at an approximate one cubic foot per minute flow rate through a 47-mm air filter (air particulate) and an air iodine cartridge. Both filters are in-line with each other and housed within the same filter holder. Weekly samples were sent to GEL Laboratories for analysis.

Analysis of the airborne particulate sample data, between the four near-site indicator locations and the control location, demonstrated no statistical difference. The average concentration of gross beta for both indicator and control locations were 0.050 pCi/m3 and 0.046 pCi/m3, respectively. The indicator location 5PR had the highest average concentration of 0.061 pCi/m3.

There were 11 positive indications of 1-131 during the report period.

These occurred between 3/19/11 and 4/8/11 on various air stations, including the control. The average concentration of 1-131 for both indicator and control locations were 0.066 pCi/m3 and 0.122 pCi/m3, respectively. The indicator location 4JS had the highest average concentration of 0.095 pCi/m3* The reporting level for 1-131 is 0.9 pCi/m3.

These were attributed to the Fukushima Daiichi event that occurred in Japan on March 11,2011. This is supported by the fact that the control values were higher than the four indicator station results. This is further supported by the fact that the DC Cook REMP air stations and milk sampling program also detected 1-131 during this time frame. All other Page 1 of 13

1-131 activity results were below the minimum detectable concentration (MDC) levels.

During 2011, effluent samples obtained from PNP REMP air stations, including control, identified detectable concentrations of 1-131 that could be related to Fukushima Daiichi event from March 11, 2011, through approximately March 20, 2011. The concentrations detected were above levels historically observed for the plant's operational status during that period. Concentrations returned to those historically observed levels after April 9, 2011. Given the events of March 2011 at the Fukushima Daiichi plant in Japan, and the subsequent trans-Pacific transportation, it is reasonably concluded that the slightly elevated concentrations detected at the PNP REMP air stations are attributed to the Fukushima Daiichi plant releases.

B.

Lake Water (Surface Water)

Palisades' Lake In (Indicator) and Ludington (Control) lake water samples were collected daily and combined into monthly composite samples. One gallon each of Palisades Lake-In and Ludington Lake-in composites were sent to GEL Laboratories for monthly analysis for gross beta and tritium.

No treatment of the water samples with preservative is required.

No statistical difference was found between the indicator and control location samples and no PNP Offsite Dose Calculation Manual (ODCM)

Appendix A, reporting limits were exceeded. The gross beta mean values for the indicator and control locations were 5.42 pCi/L and 4.43 pCi/L, respectively. Tritium was not detected in any indicator or control samples.

There is no ODCM reporting criterion for gross beta; if gross beta activity is > 10 pCi/L, then a gamma analysis is performed. Sample results remain slightly higher since 2008 due to a change in vendor performing analyses and how positive results are determined when each activity is compared to its listed minimum detectable concentration.

C.

Drinking Water Palisades' Domestic Water and South Haven Municipal Raw Water (Indicators) and Ludington (Control) water samples were collected daily and combined into monthly composite samples. One gallon each of these composites were sent to GEL Laboratories for analysis and analyzed for gross beta and tritium. No treatment of the water samples with preservative is required.

One South Haven Raw Water sample and two Ludington Control samples had gross beta concentration greater than MDC. The average gross beta concentrations for Ludington Control sample was 4.43 pCi/L and the Page 2 of 13

South Haven Raw Water concentration was 3.75 pCi/L. Tritium was not detected in any indicator or control sample. There is no ODCM reporting level for gross beta; if gross beta activity is > 10 pCi/L, then a gamma analysis is performed. Sample results remain slightly higher since 2008 due to a change in vendor performing analyses and how positive results are determined when each activity is compared to its listed minimum detectable concentration.

South Haven Raw Water sample from October experienced sample container breach during transit and the entire sample was lost.

CR-PLP-2012-2964 documents this loss of sample.

D.

Milk There are no dairy farms meeting the sampling criteria of being within eight kilometers (km) of PNP. Because of a lack of dairy farms, PNP analyzes broad leaf vegetation samples as a substitute for milk sampling.

E.

Thermoluminescent Dosimeters (TLD) - Gamma Dose Environmental gamma doses are measured quarterly by placement of TLDs at designated locations. Sensitivity for the TLDs is 3 millirem, with a linear response of 1 millirem to 50 rem.

The PNP direct radiation monitoring program consists of TLDs placed at 23 locations. There are ten inner ring TLDs, one on-site TLD, nine outer ring TLDs and three control TLDs located in Grand Rapids, Kalamazoo and Dowagiac.

Ninety-two TLDs were collected and analyzed during 2011. The on-site TLD is included with the inner ring (site boundary) TLDs for evaluating any dose effect that could be attributed to PNP.

The TLD data evaluations were performed by comparing the inner ring TLDs and the outer ring TLDs against the control TLDs.

The quarterly average gamma readings in mrem were:

Inner Ring 9.7 Outer Ring 11.4 Control 11.5 The highest average reading was observed at outer ring location number 2 with a value of 14.5 mrem and a maximum reading of 16.41 mrem. The average control dose, 11.5 mrem, plus 2 standard deviations was 13.9 mrem. No Inner Ring reading exceeded this amount. This Page 3 of 13

demonstrates that there was no direct radiation effect due to PNP operations.

Note: TLD readings are lower in 2011 than in the previous two years. This is due to the TLDs being analyzed by a different vendor who subtracts transit dose. However, it should be noted that the critical aspect of environmental TLD monitoring is the comparison between indicator and control TLD dose in the same monitoring period - more so than the comparison from one year to the next.

F.

Crops Two principal area crops, apples and blueberries, were collected.

Approximately 1 kg of sample is placed in a plastic bag for shipment to the vendor for analysis. No special treatment of the samples with a preservative is necessary.

Blueberries and apples were collected at indicator station 4-JS (3.5 miles SE). There was no activity detected in the crop samples except for naturally occurring K-40 in both berry and apple samples.

G.

Sediment Sediment samples are collected semi-annually from a location Y2 mile north of the plant along the waterline. No treatment of the samples with a preservative is necessary prior to shipment to the vendor for analysis.

There was no activity detected in the sediment samples except for naturally occurring K-40, Bi-214, Pb-212, and Pb-214. Note: Historical pre-operational environmental data for sediment samples could not be located.

H.

Fish Fish samples are collected semi-annually. Samples consist of species of commercially and/or recreational important species near the plant discharge area. Control samples are obtained in an area not influenced by plant discharge. Each one-liter quantity of fish sample is frozen for preservation for shipment to GEL Laboratories for analYSis.

Four fish samples were collected in the vicinity of PNP and one control sample was collected from Ludington Pumped Storage Facility. Cs-137 was detected in four PNP samples with an average concentration of 13.9 pCi/kg, and in three Ludington samples with an average concentration of 23.0 pCi/kg. The reporting level for Cs-137 in fish is 2000 pCi/kg. The control sample that was obtained in 2011 was not Page 4 of 13

shipped to the vendor for analysis in a timely manner. This allowed for the sample to spoil and it was not shipped or analyzed. 2010 control data was used in lieu of current control data. This is documented in CR-PLP-2012-2785.

I.

Broad Leaf Vegetation Various different kinds of broad leaf vegetation in the South and SSE sectors along the site boundary were sampled monthly during the growing season. Similar broad leaf vegetation samples were obtained in the NE sector approximately 9 to 18 miles distant from the plant. Sample sizes are 1 kg per sample - nine samples total per month. Samples were sent to GEL Laboratories for gamma isotopic and lodine-131 analyses. No treatment of the samples with a preservative is necessary.

This sampling was completed for the months of June through September.

Thirty samples were obtained. Cs-137 was detected in 9 of the 20 indicator samples. The average Cs-137 concentration was 52.2 pCi/kg.

The reporting level for Cs-137 is 2000 pCi/kg. Cs-137 was detected in 1 of the 10 control samples. The average Cs-137 concentration was 13.6 pCi/kg. The reporting level for Cs-137 is 2000 pCi/kg.

The following documentation is provided from Condition Repot CR-PLP-2011-2205, corrective action 24, evaluating Cs-137 concentration in the environment Twenty samples were obtained, 10 of broadleaf, and 10 of sediment/soil.

Sediment samples were obtained from the same location as the leaves.

These samples were obtained approximately 10 to 40 miles from PNP in several different sectors. The leaves of oak and/or maples were targeted in areas where the trees looked to be in the 40 to 50 year old range. The sediment samples were obtained from the topsoil (top 0.5 to1 inch of soil).

GPS coordinates were obtained at the sample locations. The following provides this information:

1 10/31/11 at 1335 predominantly fallen and attached maple leaves, GPS coordinates are 42.41662N and 86.16771 W.

2 10/31/11 at 1400 predominantly fallen and attached oak and maple leaves, GPS coordinates are 42.39303N and 86.01734W.

3 10/31/11 at 1430 predominantly fallen maple and oak leaves, GPS coordinates are 42.36990N and 85.70859W.

4 10/31/11 at 1600 predominately fallen and attached maple leaves, GPS coordinates are 42.14949N and 86.26147W.

5 10/31/11 at 1630 predominately fallen maple and oak leaves, GPS coordinates are 42.00874N and 86.20403W.

Page 5 of 13

6 10/31/11 at 1700 predominately fallen maple and oak leaves, GPS coordinates are 42.06865N and 86.15239W.

7 10/31/11 at 1745 predominantly fallen oak and maple leaves, GPS coordinates are 42.01193N and 85.96369W.

8 10/31/11 at 1700 predominantly fallen oak and maple leaves, GPS coordinates are 42.48382N and 86.04583W.

9 10/31/11 at 1805 predominantly fallen oak and maple leaves, GPS coordinates are 42.62994N and 85.89885W.

10 10/31/11 at 1825 predominantly fallen oak and maple leaves, GPS coordinates are 42.58925N and 85.99632W.

These samples were submitted to GEL Laboratories for gamma spectroscopy analysis. Natural radionuclides Be-7, K-40, TI-208, Pb-210, Pb-212, Pb-214, Bi-214, and Ac-228 were identified in various samples.

Natural radionuclide results are not evaluated for this action.

The positively identified radionuclides and concentration follow:

1. Sediment, Cs-137, 568 pCi/kg. Broadleaf, none detected.
2. Sediment, CS-137, 216 pCi/kg. Broadleaf, Cs-137 23.8 pCi/kg.
3. Sediment, Cs-137, 65.5 pCi/kg. Broadleaf, none detected.
4. Sediment, Cs-137, 124 pCi/kg. Broadleaf, none detected.
5. Sediment, Cs-137, 123 pCi/kg. Broadleaf, none detected.
6. Sediment, none detected. Broadleaf, none detected.
7. Sediment, CS-137, 174 pCi/kg. Broadleaf, none detected.
8. Sediment, Cs-137, 492 pCi/kg. Broadleaf, CS-137, 13.9 pCi/kg.
9. Sediment, Cs-137, 394 pCi/kg. Broadleaf, Cs-137, 296 pCi/kg.
10. Sediment, Cs-137, 506 pCi/kg. Broadleaf, Cs-137, 107 pCi/kg.

In accordance with National Council on Radiation Protection and Measurements (NCRP) Releases Report No. 154, "Cs-137 in the Environment: Radioecology and Approaches to Assessment and Management," the primary source of Cs-137 in the biosphere is atmospheric nuclear weapons testing by the United States and the former Soviet Union from the 1940s to the 1960s. Of the roughly 2.73E7 Curies of Cs-137 released to the biosphere, -90% (2.45E7 Curies) was produced by atmospheric testing. Approximately 6% (1.64E6 Curies) was produced by the Chernobyl accident and roughly 4% (1.09E6 Curies) by nuclear fuel reprocessing facilities. Because of the chemical properties of cesium, it is readily transported through the environment and food chain. When in solution it can be efficiently taken up by plants and assimilated by animals because of its chemical similarity to the essential nutrient, potassium.

DC Cook Nuclear Plant, which is located approximately 25 miles to the south of PNP, conducted a Cs-137 soil study and determined that an Page 6 of 13

"average" background for Cs-137 was 171 pCi/kg in soil. Due to the fact that the Lower Limit of Detection (LLD) for sediment (180 pCi/kg) is larger than the LLD for food (80 pCi/kg) it is conceivable that broad leaf could be positive even while not having any indication from sediment. Positive indication of Cs-137 in broadleaf samples has occurred at DC Cook Nuclear Plant also. It has been attributed to uptake by the plant and deposition on the leaf surface.

Table 5.12 to NCRP Releases Report No. 154 provides a list of crops, soil types, and concentration ratios. This table indicates that there can be substantial differences in these ratios due to soil types. Since local soils typically have a combination of these, the uptake can vary, as is evidenced by the sample results provided here. The ratios of the sample data supplied here vary from 0.03 to 0.75. This could result from a variety of items ranging from topsoil movement through meteorological conditions, or man interfacing from as far back as 30 years ago, which could be unidentifiable today (e.g. fill dirt disposal).

In conclusion, there is ample documented evidence that Cs-137 exists in the environment from activities 25 to 50 plus years ago. Cs-137 has a 30.17 year half life so there is still plenty of the originally estimated 2.45E7 Curies left in the biosphere. Cesium is readily transported through the environment due to its chemical properties. When in solution (during rainfall events) it can be efficiently taken up by plants. The evidence presented here documents the fact that there is a fairly wide ranging span of Cs-137 concentration in the environment that is far enough away from the site to not have been deposited there from plant effluents.

J.

Non-Routine Samples Six monthly samples were taken from the closest commercial well water at the seasonal Palisades Park housing subdivision south of PNP. Another six samples were taken from the community well, of which there are two cross-tied sources, at the seasonal Palisades Park facility also. Tritium and beta results were less than minimum detectable activity for all samples obtained.

K.

Gaseous and Liquid Radwaste Effluent Composite Samples Gaseous and liquid radwaste effluent composite samples are collected and analyzed on site and by GEL Laboratories. No special sample treatment with a preservative is required prior to laboratory analysis. The monthly liquid effluent composite sample is produced from samples collected from each batch release. I he gaseous radwaste effluent weekly composite sample results are based on analyzing weekly stack gas filters.

Page 7 of 13

Although not a direct reporting component in the PNP Annual Radiological Environmental Operating Report, results of the gaseous and liquid monthly radwaste effluent composite samples are evaluated against overall environmental trending data. This evaluation is the basis for determining isotopic dispersion and deposition patterns within the surrounding environs of PNP. All gaseous and liquid effluent results are compared to the PNP Offsite Dose Calculation Manual (ODCM),

Appendix A, reporting levels.

IV.

ASSESSMENT OF PALISADES OPERATION ENVIRONMENTAL IMPACT In reviewing the 2011 PNP radiological environmental monitoring data, and comparing it to previous operational and pre-operational data, all trending parameters continue to indicate that the operation of PNP has minimal environmental impact. Most isotopic activity is at environmental background levels. Evidence of an overall environmental isotopic buildup (attributable to plant effluents) remains negligible as well. The positive Cs-137 results detected in sediment, broadleaf, and fish samples are attributed to atmospheric weapons testing and Chernobyl accident source term.

Page 8 of 13

Palisades Nuclear Plant, Van Buren County, MI Docket 50-255 Annual Radiologi~al EnvirQllmental O~ratiDg RegQrt January 1, 2011 to December 31, 2011 Sampling and Analysis Summary Table 10.4-1 Number of Collection Samples Frequency of Medium Description Location Collected Type of Analysis Analysis Continuous at Air appx 1 cfm Stations 4, 5, 8, 9 and 10 260 Gross Beta, 1-1 31 Weekly 1 gallon Lake Water composite Lake Intake 12 Gross Beta, Tritium Monthly Lake Water-1 gallon Control composite Ludington Lake In 12 Gross Beta, Tritium Monthly South Haven Municipal 1 gallon (treated) and South Haven Drinking Wat ~r composite Raw 23 Gross Beta, Tritium Monthly Inner Ring, Outer Ring, TLD Continuous Controls 92 Gamma dose Quarterly At time of Food Produc s 1 kg grab 4-JS, 3.5 miles SE 2

Gamma isotopic and 1-1 31 harvest Discharge 112 mile north of Sediment 1 L grab Palisades 2

Gamma isotopic Semiannually Fish 1 L grab Discharge and Control 4

Gamma isotopic Semiannually Plant boundary - S and SSE Monthly during Broad leaf sectors, Control 9 to 1 8 miles growing Vegetation 1 kg grab NNE of plant 30 Gamma isotopic and 1-1 31 season Page 9 of 13

Environmental Radiological Monitoring Program Summary Sample Data Summary Table 10.4-2 Name of Fac lity Palisades Nuclear Plant Docket No 50-255 Location of acility (County, State)

Van Buren, Michigan Reporting Period Jan 1, 201 1 to Dec 31, 201 1 Medium or Pathway Type/Total Lower Umit All Indicator Greatest Greatest Control Number of Samp ed Number of of Detection" Locations Mean Mean (f)b Locations Reportable (Unit of M ~asure)

Analyses (MDC)

Mean (ft Name Rangeb Mean (ft Occurrences Performed Rangeb Distance &

Rangeb Direction 0.0659 0.0949 0.122 1-131 / 260 0.07 (9/208) 4JS 3.9 mi SE (2/52)

(2/52) 0 0.0464 -

0.0778 -

0.121 - 0.123 Air (pCi/m3 0.112 0.112 0.050 0.061 Gross beta /

(208/208) 5PR (52/52) 0.046 0.01 (52/52) 0 260 0.023 -

5.8 mi ESE 0.031 -

0.125 0.125 0.025 - 0.100 Gross beta /

5.42 Lake In 5.42 4.43 24 4.0

( 4/12)

Palisades (4/12)

(2/12) 0 Lake Water (pCi/L) 3.51 - 8.30 3.51 - 8.30 3.78 - 5.07 Tritium / 24 2000

< MDC NA

< MDC

< MDC 0

(0/12)

(0/24)

(0/12)

Gross beta /

3.75 South Haven 3.75 4.43 Drinking We 35 4.0 (1/23 )

raw water (1/11)

(2/12) 0 ter 3.75 5.5 mi NNE 3.75 3.78 - 5.07 (pCi/L)

<MDC

< MDC

<MDC Tritium / 35 2000 (0/23)

NA (0/35)

(0/12) 0 Page 10 of 13

Environmental Radiological Monitoring Program Summary Sample Data Summary Table 10.4-2 Medium or Pathway Type/Total Lower Limit All Indicator Greatest Greatest Control Number of Sam~ led Number of of Detection" Locations Mean Mean (f)b Locations Reportable (Unit of ~ easure)

Analyses (MOC)

Mean (ft Name Rangeb Mean (ft Occurrences Performed Rangeb Distance &

Rangeb Direction Gamma Dose Sensitivity of 9.7 Station # 1 10.7 11.5 Inner Ring LD (44/44)

Palisades (414)

(12/12) 0 (Gamma m~)

156 3 per vendor 7.31 - 12.4 9.4 - 12.4 10.1-13.7 Gamma Dose Sensitivity of 11.4 Station # 2 14.5 11.5 Outer Ring (36/36)

(414)

(12/12) 0 (Gamma m ~)

148 3 per vendor 8.6 - 16.4 5.6 miles S 12.6 - 16.4 10.1-13.7 1-131 / 2 60

< MDC NA

< MDC Control sample 0

(012)

(012) not required Food Crops Cs-134 1 2 60

< MDC NA

< MDC Control sample 0

(pCi/kg we )

(012)

(012) not required C5-137 1 2 80

< MDC NA

< MDC Control sample 0

(0/2)

(012) not required Page 11 of 13

Environmental Radiological Monitoring Program Summary Greatest Mean Sampling Location Table 10.4-3 Medium or Pathway TypelTotal Lower Limit All Indicator Greatest Greatest Control Number of SamJ led Number of of Detection" Locations Mean Mean (ft Locations Reportable (Unit of ~ easure)

Analyses (MDC)

Mean (f)b Name Rangeb Mean (f)b Occurrences Performed Rangeb Distance &

Rangeb Direction Cs-134 I 2 150

<MOC NA

<MOC Control sample 0

Sediment (~ Ci/kg dry)

(0/21 (0/2) not re~uired

<MOC

<MOC Control sample Cs-137 I 2 180 (0/2)

NA (0/2) not required 0

Mn-54 I 4 130

<MOC NA

<MOC

<MOC*

0 (0/4)

(0/9)

(0/4)

Fe-59 I 4 260

<MOC NA

<MOC

<MOC*

0 (0/4)

(0/9)

(0/4)

Co-58 14 130

<MOC NA

<MOC

<MOC*

0 (0/4)

(0/9)

(0/4)

Co-60 I 4 130

<MOC NA

<MOC

<MOC*

0 Fish (pCi/kg wet)

(0/4)

(0/9)

(0/4)

Zn-65 14 260

<MOC NA

<MOC

<MOC*

0 (0/4)

(0/9)

(0/4)

Cs-134 I 4 130

<MOC NA

<MOC

<MOC*

0 (0/4)

(0/9)

(0/4) 13.2 20.2 23.0

Palisades (4/4)

(3/4) 0 5.6 -20.2 20.2 6.9-33.8 1-131 130 60

<MOC NA

<MOC

<MDC 0

(0/20)

(0/20)

(0/10)

Broad Leaf Cs-134 I 30 60

<MOC NA

<MOC

<MOC 0

Vegetation (0/2Q)

(0/20)

(0/10)

(pCi/kg wet) 52.2 BV23 115 13.6 Cs-137 I 30 80 (9/20) 0.43 miles S (2/3)

(1/10) 0 7.8 -467.0 71.9 - 223 13.6 a Nominal LOI/\\ er Limit of Detection (LLD) as defined in table notation c of aDCM Appendix A Table E-3 b Mean and ra rge based on detectable measurements only.

f Fraction of dE tectable measurements at specific locations is indicated in parenthesis

Medium or Pathway Sampled (unit of measurement)

Air (pCi/m3)

Lake Water (pCilL)

Drinking Water (pCilL)

Inner Ring TLO (gamma mR)

Outer Ring TLO (gamma mR)

Crops (pCi/kg wet)

Sediment (pCi/kg dry)

Fish (pCi/gm wet)

Broad leaf vegetation (pCilkg wet)

Greatest Mean Sampling Location January 1,2011 to December 31,2011 Type of Analysis Location High 1-131 4JS 0.112 Gross Beta 5PR 0.125 Lake In-Gross Beta Palisades 8.30 Tritium NA

<MOC Gross Beta South Haven Raw 3.75 Tritium NA

<MOC Quarterly

  1. 1 (Palisades) 12.4
  1. 2 Quarterly 5.6 miles S 16.4 1-131 NA

<MOC Other Gamma NA

<MOC Gamma Emitters NA

<MOC Gamma Emitters Palisades 20.2 Site Boundary Gamma South Emitters 223 Page 13 of 13 Low Mean 0.0778 0.0949 0.031 0.061 3.51 5.42

<MOC

<MOC 3.75 3.75

<MOC

<MOC 9.4 10.7 12.6 14.5

<MOC

<MOC

<MOC

<MOC

<MOC

<MOC 20.2 20.2 71.9 115

ATTACHMENT 1 SAMPLE COLLECTION ANOMOLIES Sample Location Date Problem Evaluation Affected I Air Sample Station 9TP 8/8/11 Power outage I Power restored after storm i

(CR-PLP-2011-3893}

Air Sample Station 4JS 12/20/11 Pump found Filters were analyzed. Volume of not running air was 48.14 m3. Required LLD were not met. Pump replaced.

'Drinking (CR-PLP-2011-6977)

South Haven Oct 11 Sample lost Oct 11 monthly composite sample Water sample Raw Water during transit from South Haven had sample container breached during transit, sample lost. (CR-PLP-2012-2964)

FiSh samples Control 2011 Sample was One control sample obtained, but not analyzed not shipped to vendor in timely manner and subsequently spoiled and was discarded.

. (CR-PLP-2012-2785)

[ land Use Palisades 19 Oct 11 Untimely 1 LUC perfonned during Oct 11, but I Census documentation not documented until 4/23/12.

(CR-PLP-2012-3197}

Page 1 of 1

ATTACHMENT 2 2011 LAND USE CENSUS REPORT The attached tables are the results of the Palisades Land Use Census conducted on October 19, 2011. The first table references the distance from Palisades Nuclear Plant (PNP) to the nearest residence, garden (greater than 500 square feet), beef cattle, dairy cattle and goat, per meteorological sector. The next table identifies the locations of the nearest residence, garden, beef/dairy cattle and goats within a five mile radius of PNP, per meteorological sector.

The last table lists the critical receptor locations used to calculate offsite doses by the GASPAR computer program.

Closest Receptor by Sector Sector Residence Garden Beef Cattle Dairy Cow Goat NNE 1.68 1.75

>5

>5

>5 NE 1.14 1.67

>5

>5

>5 ENE 1.19

>5

>5

>5

>5 E

1.67 2.80

>5

>5 2.62 ESE 0.99 1.78

>5

>5

>5 SE 0.90 1.01

>5

>5

>5 SSE 0.80 2.28

>5

>5

>5 S

0.72 1.39

>5

>5

>5 SSW 0.49 4.82

>5

>5

>5 (Distance is in miles)

Locations Sector Location Description Item Distance from Plant (miles)

NNE 22514 Oak St Residence 1.68 SW corner of 20m and 0 fire lane Garden 1.75 NE Ruggles Road, State Park Manager Residence 1.14 21175 Blue Star Hwy Garden 1.67 ENE 77198 24m Avenue Residence 1.19 25112 76m Street Residence.

1.67 E

73689 28m Avenue Garden 2.8 Corner of M-140 and 24m Ave Goat 2.62 ESE 77555 28m Ave Residence 0.99 28594 76m Street Garden 1.78 SE 28563 29m Ave Residence 0.9 30423 77 Y2 Street Garden 1.01 SSE 78983 Ravine Way Residence 0.8 76890 34tn Avenue Garden 2.28 S

Ravine Way, Palisades Park Residence 0.72

'::11 CC1 DI. "" C+.... r Uta"

~,..r""',",,""

.~

'""........ ~.

SSW Shorewood Walk, Palisades Park Residence 0.49 Corner of 82no and Blue Star Hwy Garden 4.82 Page 1 of 2

Critical Receptors Sector Item Distance X/Q (sec/m;$)

D/Q (11m2)

(miles)

SSE Site Boundary 0.48 2.41 E-6 2.07E-8 SSE Residence 0.80 1.11 E-6 8.93E-9 SE Garden 1.01 6.86E-7 5.91 E-9 E

Goat 2.62 1.15E-7 6.73E-10 Page 2 of 2

ATTACHMENT 3 CHEMISTRY PROCEDURE CH 6.10 "RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM" 31 Pages Follow

Procedure No CH 6.10 Revision 4 Effective Date 2/2/10 PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Approved: JBBurnett Procedure Sponsor I Process Applicability Exclusion New Procedure/Revision Summary:

Specific Changes Revision 4 - DRN-10-00168 Added an additional map showing Control sample locations.

1 Added requirement that air sample pumps should be changed out every three years.

211/10 Date

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page i TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Table of Contents 1.0 PURPOSE...................................................................................................................... 1

2.0 REFERENCES

............................................................................................................... 1 2.1 SOURCE DOCUMENTS................................................................................ 1 2.2 REFERENCE DOCUMENTS......................................................................... 1 2.3 COMMITMENTS............................................................................................ 2 3.0 PREREQUISITES.......................................................................................................... 2 4.0 PRECAUTIONS AND LIMITATIONS............................................................................. 2 5.0 PROCEDURE................................................................................................................. 3 5.1 LAKE-IN WATER SAMPLE COLLECTION - DAILy.................................... 3 5.2 DRINKING WATER SAMPLE COLLECTION - DAILY................................. 4 5.3 ENVIRONMENTAL AIR SAMPLE COLLECTION - WEEKLY...................... 4 5.4 SOUTH HAVEN RAW WATER SAMPLE COLLECTION - MONTHLY........ 5 5.5 BROADLEAF VEGETATION SAMPLE COLLECTION - MONTHLY........... 6 5.6 ENVIRONMENTAL TLD COLLECTION - QUARTERLY.............................. 6 5.7 PLANT AIR SAMPLE COLLECTION - QUARTERLy.................................. 6 5.8 SEPTIC SYSTEM SAMPLE COLLECTION - QUARTERLy........................ 7 5.9 FISH SAMPLE COLLECTION - IN SEASON............................................... 7 5.10 SEDIMENT SAMPLE COLLECTION - SEMIANNUALLy............................. 8 5.11 FOOD PRODUCT SAMPLE COLLECTION - yEARLy................................ 8 5.12 MISCELLANEOUS SAMPLES...................................................................... 8 5.13 MONTHLY SAMPLE COLLECTION VERIFICATION................................... 8 5.14 REVIEW OF SAMPLE ANALYSIS RESULTS............................................... 9 5.15 SPECIAL REPORT...................................................................................... 10 6.0 ATTACHMENTS AND RECORDS............................................................................... 11 6.1 ATTACHMENTS.......................................................................................... 11 6.2 RECORDS................................................................................................... 11 7.0 SPECIAL REVIEWS.................................................................................................... 11

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page ii TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Table of Contents ATTACHMENTS, "Environmental Sample Collection Schedule", REMP Sample Locations", "Sample Shipment Identification", "Sample Packaging and Shipment", "Environmental Air Sample Data Sheet", REMP Sample Collection Checklist", REMP Analytical Requirements", "Environmental Monitoring Locations"

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 1 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REFERENCE USE Procedure and Procedure Precautions and Limitations are at the work location for reference.

Review and understand segments before performing any steps.

Signoff steps are completed, when included, before starting the next step.

Place keep in accordance with EN*HU*102, "Human Performance Tools."

Review the Procedure to verify segments have been completed.

1.0 PURPOSE This procedure provides instructions for collection of environmental samples in support of the Radiological Environmental Monitoring Program (REMP) as required by the Offsite Dose Calculation Manual (ODCM). In addition to the ODCM required samples, additional required sampling is listed.

2.0 REFERENCES

2.1 SOURCE DOCUMENTS 2.1.1 Reg Guide 4.15(7) 2.1.2 10CFR50, Appendix I 2.1.3 Offsite Dose Calculation Manual (ODCM) 2.1.4 Branch Technical Position (Revision 4, 1979), "Radiological Portion of the Environmental Monitoring Program" 2.1.5 NRC IE Bulletin 80-10, "Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment" 2.2 REFERENCE DOCUMENTS 2.2.1 Palisades ODCM, Appendix A, Sections IIU, IV.C, and Tables E-1 and E-2 2.2.2 Entergy Procedure EN-AD-103, "Document Control and Records Management Programs" 2.2.3 Entergy Procedure EN-HU-102, "Human Performance Tools"

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 2 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.3 COMMITMENTS 2.3.1 CMT 022011097, IE Bulletin 80-10 Response - "Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment" 2.3.2 CMT 032011144, IE Bulletin 80-10 Response - "Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment" 3.0 PREREQUISITES None 4.0 PRECAUTIONS AND LIMITATIONS 4.1 Any revisions to this procedure shall be reviewed against Palisades ODCM Specifications to verify compliance to all requirements.

4.2 Deviations from the required sampling schedule shall be documented in the Annual Radiological Environmental Operating Report.

4.3 Every effort shall be made to complete corrective action on malfunctioning sampling equipment prior to the end of the next sampling period.

4.4 If it is not possible to obtain the required samples, suitable alternative media and locations shall be substituted within 30 days.

4.5 Samples shall be collected, prepared, and shipped for analysis in a timely manner to ensure detection requirements are met. Other specific handling precautions for sample media are indicated in Section 5.0 as required.

4.6 Any deviation in the Radiological Environmental Monitoring Program including missing samples, unusual analytical results, elevated LLDs, etc, shall be investigated, evaluated, corrected, and documented.

4.7 If an air sampling unit is discovered not operating, attempt to find the cause and repair. If this cannot be done, replace applicable component and document on air sample collection data sheet.

4.8 Calibrate airflow meters annually.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 3 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 4.9 Change out airflow meters prior to the expiration of calibration dates.

4.10 Change out air sample pumps every three years.

4.11 Ensure trees and bushes in the vicinity of air sampler locations are removed, along with any branches extending over the top of the sampler. The goal is to keep every station away from the drip line (with the exception of station 9, which has an existing canopy 50 feet above the station).

4.12 In the event that the Radiological Environmental Monitoring Programs sampling are not substantially conducted as described in Palisades aDCM Appendix A, Specification IILJ, or an unusual or important event occurs from Plant operation that causes a significant environmental impact or affects a potential environmental impact, a report shall be submitted to the NRC within 30 days.

5.0 PROCEDURE REFERENCE USE Procedure and Procedure Precautions and Limitations are at the work location for reference.

Review and understand segments before performing any steps.

Signoff steps are completed, when included, before starting the next step.

Place keep in accordance with EN-HU-102, "Human Performance Tools."

Review the Procedure to verify segments have been completed.

5.1 LAKE-IN WATER SAMPLE COLLECTION - DAILY CMT 032011144 5.1.1 Fill a 500 ml sample bottle from water downstream of "bio-box" located in the screen house.

5.1.2 Add the sample to the composite container (carboy).

5.1.3 At end of the month obtain a 1-gallon sample from carboy.

5.1.4 Package and ship sample per Attachment 4.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 4 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5.2 DRINKING WATER SAMPLE COLLECTION - DAILY 5.2.1 Obtain a 500 ml sample from any potable water sink.

5.2.2 Add the sample to the monthly sample container (carboy).

5.2.3 At end of the month obtain a 1-gallon sample from carboy.

5.2.4 Package and ship sample per Attachment 4.

5.3 ENVIRONMENTAL AIR SAMPLE COLLECTION - WEEKLY 5.3.1 Open cover at air sample station.

5.3.2 Determine "As Found Leakage" by blocking air flow and checking air flow meter for movement.

a.

If no leakage, then mark N in As Found Leakage column on Air Sample Data Sheet.

b.

If leakage is indicated, then mark Y in As Found Leakage column, determine cause and repair.

5.3.3 Remove old sampler assembly.

5.3.4 Remove protective cover from new sampler assembly and place on old sampler assembly.

5.3.5 Install new sampler assembly.

5.3.6 Determine "As Left Leakage" by blocking air flow and checking air flow meter for movement.

a.

If no leakage, then mark N in As Left Leakage column.

b.

If leakage is indicated, then determine cause and repair.

5.3.7 Record the Flow Meter Cal Due Date, Removed Date, Removed Time, Removed Meter Reading (ft3) and Pump Replacement Date.

5.3.8 Close and latch the air sample station cover.

5.3.9 Proceed to the next station and continue process.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 5 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5.3.10 After completing air sample change out, complete the following for each sampler assembly:

a.

Remove particulate filter and place in glassine envelope.

b.

Place filter envelope and charcoal cartridge in labeled zip-lock bag

c.

Clean out any residue or moisture buildup in sampler head.

d.

Check condition of O-rings, replace if necessary.

5.3.11 Place new particulate filter (fuzzy side out) and charcoal cartridge in sampler assembly and screw on cap.

5.3.12 Place protective cover on sampler assembly.

5.3.13 Prepare new air sample packages for following week.

5.3.14 Transfer data to vendor Chain of Custody sample data sheet.

5.3.15 5.4 NOTE:

5.4.1 5.4.2 5.4.3 5.4.4

a.

If volume is less than 150 m3, then notify REMP/RETS analyst.

When control air sample is obtained, then package and ship samples per.

SOUTH HAVEN RAW WATER SAMPLE COLLECTION - MONTHLY Water treatment plant personnel add approximately 125 ml of raw water per day to sam Ie containers.

Prepare a 1-gallon container labeled "SHRAW," "PAL," month and year.

Drop off container at the South Haven Municipal Water Treatment Plant.

Pick up previous month's container.

Package and ship samples per Attachment 4.

5.5 5.5.1 5.5.2 5.5.3 5.5.4 5.6 5.6.1 NOTE:

5.6.2 5.6.3 PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 6 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM BROADLEAF VEGETATION SAMPLE COLLECTION - MONTHLY Obtain 1 kg (2.2 Ibs) samples of three different kinds of broadleaf vegetation in both the South and SSE sectors.

Obtain 1 kg (2.2 Ibs) samples of the similar broad leaf vegetation 15 - 30 km (9.3 to 18.6 miles) distant in the NNE sector.

Obtain samples monthly during growing season.

Package and ship samples per Attachment 4.

ENVIRONMENTAL TLD COLLECTION - QUARTERLY Upon receipt of TLDs from the laboratory contractor, inventory all TLDs and place in lead cave.

Remove field TLDs from the lead cave only for delivery to their proper locations.

All control TLDs remain in the lead cave throu hout the entire ex osure eriod.

Change-out TLDs at each sample location.

For any missing TLDs, then:

a.

Search immediate area.

b.

If lost TLD is found, collect it and perform standard change out procedure.

c.

If lost TLD is not found, post the new TLD in proper location.

5.6.4 Store collected field TLDs in lead cave along with control TLDs until ready for mailing to laboratory contractor.

5.6.5 Package and ship samples per Attachment 4.

5.7 PLANT AIR SAMPLE COLLECTION - QUARTERLY 5.7.1 Obtain 1-liter air samples from Air Receiver Tanks T-8A, 88 and 8C.

CMT 0220011097 5.7.2 Count samples for 2000 seconds on MCA.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 7 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5.8 SEPTIC SYSTEM SAMPLE COLLECTION - QUARTERLY 5.8.1 Obtain a 1 liter liquid sample from sanitary system septic tank.

5.8.2 Count sample for 2000 seconds on MCA.

5.8.3 Package and ship samples per Attachment 4.

5.9 FISH SAMPLE COLLECTION - IN SEASON 5.9.1 Precautions

a.

At least one individual in the collection party is required to have Michigan Department of Environmental Quality (MDEQ) Cultural and Scientific Fish Collectors Permit if gill net is used.

b.

If logistical problems prevent use of a boat to set gill nets from the lake side of Palisades, then the nets can be set offshore from the site boundary (by wading). Notify Security prior to using offshore wading method for beach access.

5.9.2 Notify district MDEQ Fisheries biologist prior to sample collection 5.9.3 Collect samples twice during the season of greatest abundance (typically May through October) as follows:

a.

Collect at least two species of commercially and/or recreationally important fish in the vicinity of the Plant discharge area and the same species in an area not influenced by the Plant discharge (eg, Ludington Pump Storage Plant). One liter of flesh should be collected for each species caught for analysis accuracy.

b.

Normally fish will be collected first from the vicinity of the discharge, then the same species at Ludington control station.

5.9.4 Label all containers with sample type, location, and date.

5.9.5 Package and ship samples per Attachment 4.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 8 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5.10 SEDIMENT SAMPLE COLLECTION - SEMIANNUALLY 5.10.1 Collect a 1-liter sediment sample semiannually 1/2 mile north of discharge.

5.10.2 Label containers with sample type, location, and date.

5.10.3 Package and ship samples per Attachment 4.

5.11 FOOD PRODUCT SAMPLE COLLECTION - YEARLY 5.11.1 Obtain one sample each of approximately 1 kg each of blueberries and apples from the Arrellanos' store.

5.11.2 Label containers with sample type, location, and date.

5.11.3 Package and ship samples per Attachment 4.

5.12 MISCELLANEOUS SAMPLES 5.12.1 Ludington - Control Lake-In daily composite samples are collected daily and shipped to Palisades monthly.

5.12.2 Package and ship samples per Attachment 4.

5.13 MONTHLY SAMPLE COLLECTION VERIFICATION 5.13.1, "REMP Sample Collection Checklist," may be used to track collection and shipment of Environmental Samples.

5.13.2 Verify that the indicated number and type of samples required by the ODCM were collected.

a.

Document any unusual collection conditions or missing samples.

5.13.3 Verify that a minimum of 150 m3 of air sample volume was obtained to ensure that analytical Lower Limit of Detection (LLD) requirements are met.

a.

Evaluate, correct and document any significant deviations.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 9 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5.13.4 Identify new locations for obtaining replacement samples and add them to the Radiological Environmental Monitoring Program (REMP) within thirty (30) days if milk or fresh leafy vegetable samples become unavailable from one or more of the sample locations. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause(s) of sample unavailability and list the new location(s) for obtaining replacement samples in the next Annual Radiological Environmental Operating Report.

5.14 REVIEW OF SAMPLE ANALYSIS RESULTS 5.14.1 The sample analysis results should be reviewed by the REMP/RETS Analyst upon receipt of the analyses from the laboratory contractor.

5.14.2 Compare the monthly analytical results to the appropriate ODCM requirements (Attachment 7) to verify the following:

a.

The required analyses were performed.

b.

Any results exceeding the action level shall be checked against ODCM Specification reporting requirements.

c.

LLD sensitivity levels were reached. If sample LLDs are not reached, evaluate and document contributing factors.

d.

The action taken if either isotopic action levels and/or NRC reporting levels are exceeded.

e.

Any specific types of evaluation required.

f.

Any action related to unusual or missing sample results.

5.15 5.15.1 PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 10 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM SPECIAL REPORT Prepare and submit to the NRC (within 30 days) a special report identifying the following, if the level of radioactivity as a result of Plant effluents in an environmental sampling medium at a specified location exceeds Palisades ODCM, Appendix A, Table E-2, reporting levels when averaged over any calendar quarter.

a.

The cause(s) for exceeding the limit(s).

b.

Corrective action(s) taken to reduce radioactive effluents.

5.15.2 The NRC Special Report shall be submitted if ~

than.Q.!l§. (1) of the radionuclides listed in the specifications (Palisades ODCM, Appendix A, Table E-2) are detected in an environmental sample medium and:

Concentration (1) + Concentration (2)

+... ~ 1.0 Reporting Level (1)

Reporting Level (2)

The quarterly sum of fractions calculation shall be completed within 90 days of end of quarter.

5.15.3 If radionuclides other than those listed in the specifications (Palisades ODCM, Appendix A, Table E-2) are detected and are the result of Plant effluents, the NRC Special Report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits specifications (Palisades ODCM, Appendix A, III.H, III.C, and III.D). An NRC Special Report is not required if the measured level of radioactivity is not the result of Plant effluents. The condition shall be described in the Annual Radiological Environmental Operating Report.

Under all conditions, any radiological environmental surveillance sample possessing sufficient isotopic activity above the action level where an action level is listed in but still below aDCM reporting requirements shall be evaluated. If no action level is listed in Attachment 2, any isotopic activity trending up shall be evaluated.

PALISADES NUCLEAR PLANT HEALTH PHYSICS PROCEDURE Proc No CH 6.10 Revision 4 Page 11 of 11 TITLE: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 6.0 ATTACHMENTS AND RECORDS 6.1 ATTACHMENTS 6.1.1, "Environmental Sample Collection Schedule" 6.1.2, REMP Sample Locations" 6.1.3, "Sample Shipment Identification" 6.1.4, "Sample Packaging and Shipment" 6.1.5, "Environmental Air Sample Data Sheet" 6.1.6, REMP Sample Collection Checklist" 6.1.7, REMP Analytical Requirements" 6.1.8, "Environmental Monitoring Locations" 6.2 RECORDS 6.2.1 Records generated by this procedure shall be filed in accordance with Entergy Procedure EN-AD-103, "Document Control and Records Management Programs."

7.0 SPECIAL REVIEWS None

Proc No CH 6.10 ENVIRONMENTAL SAMPLE COLLECTION SCHEDULE Attachment 1 Sample Number of Samples and Locations Airborne 4 within a 10 km Particulates and radius lodines 1 at 25 - 89 km distant Drinking Water 1 - South Haven Municipal - Raw Drinking Water 1 - Plant drinking water Lake Surface 1 - Lake In, Screen-house downstream of "bio-box" Lake Surface 1 - Control at Ludington Sediment Sediment - Y2 mile north of plant Food Products 1 sample each of blueberries and apples Food Products 1 sample each of three different kinds of broadleaf vegetation in two sectors near plant boundary 1 - sample of each of similar broadleaf vegetation 15 - 30 km distant (9 to 18 miles)

Fish 2 - location in vicinity of plant discharge 2 - Ludington Control Sample Type Continuous at approximately 1 cfm Daily 125 sample collection to obtain a one-gallon composite Daily 500 sample collection to obtain a one-gallon composite Daily 500 sample collection to obtain a one-gallon composite Daily composite to obtain one-gallon sample One-liter grab 1 kg grab sample 1 kg grab samples One-liter of fish flesh from two different species.

Obtain same species from control IULcniul lif available)

Revision 4 Page 1 of2 Collection! Analysis Frequency Weekly Monthly Monthly Monthly Monthly Semi-annually At time of harvest Monthly during growing season Sample in season or semiannually if they are not seasonal

Sample TLD Waste Water Plant Air Proc No CH 6.10 ENVIRONMENTAL SAMPLE COLLECTION SCHEDULE Attachment 1 Number of Samples and Locations 9 - General vicinity of Site Boundary 9 - Within 12 km radius 3 - Control Stations 1 - septic system 3 - T-8A, B & C Sample Type Continuous 1 liter grab 1 liter grab Revision 4 Page 2 of2 Collection! Analysis Fre~uency_

Quarterly Quarterly Quarterly

Proc No CH 6.10 Revision 4 REMP SAMPLE LOCATIONS Page 1 of 3 Station Code Location Air Part.

Lake Milk Food Sediment TLD Fish and Water Products Iodine 1

ST Palisades Nuclear Plant Onsite, on tree near nw comer of X

X bag crew bldg.

1 ST Palisades Nuclear Plant Plant discharge area X

2 TH RR3 TLD located on Becht Road, west Coloma, MI side on post, 50 yards south of 48 th X

5.6 miles S Ave.

3 HS 76182 48th Ave Along 48th Ave, 1/4 mile west of Covert, MI 76th St. In barnyard 50 yds off north X

5.8 miles SSE side of road.

4 JS 36197 M-140 Hwy Just north of Arellannos fruit stand, Covert, MI in grape arbor.

X X

3-1/2 miles SE 4

JS 36" Avenue, Yo miles South side of road X

east of M-140 5

PR 72723 CR 378 Along CR 378, 3/4 mile east of Covert, MI M-140, 30 ft off north side of road.

3-1/2 miles ESE TLD located at Paul Rood residence; X

X on tree in back yard just past driveway.

6 RB RR 3 South Haven, MI Along 12th Ave (CR 384), tum nw 4-1/2 miles NE past maple grove, go 1/4 mile X

located in orchard on north side of road.

7a SN21 Emergency Siren 21 On Monroe Blvd, at comer of 76Ul X

I 4.1 miles NNE and 11th Street.

8 SP State Park 1 mile N Onsite along the dump road, north of Plant. One mile from main gate.

X X

Near State Park boundary, on side of road as road turns west.

9 TP Covert Township Park Along 32nd Ave, 1/4 mile west of 1.5 miles SSW Blue Star Hwy. 5 ft off south side of road. TLD located at end of road, at X

X entrance to residence on beach, attached to emergency siren SN38.

10 GR Grand Rapids, MI Grand Rapids Service Center, in 55 miles NNE storage area. Air sample on west X

X side near shed. Control TLD 100 feet north of air sample station.

Proc No CH 6.10 Revision 4 REMP SAMPLE LOCATIONS Page 2 of 3 Station Code Location Air Part.

Lake Milk Food Sediment TLD Fish and Water Products Iodine Kalamazoo, MI35 miles Kalamazoo Service Center, in 11 KZ E

parking area on post in SE comer X

Control TLD.

58399 Wilbur Road, TLD located on pole appx 20 yards 12 DG Dowagiac, MI30 miles X

SSE from road, NE of house.

Past #8 along dirt road. Proceed west up dune path at right of Perimeter of Palisades containment test structure. At first 13 ST NNE crest, turn north and proceed up X

adjacent hill to #13 at top (approx 50 yds from crest). Near State Park fence line.

Perimeter of Palisades 25 yards of east of Station #34 14 ST between State Park and DFS X

NE Building.

Perimeter of Palisades North along Blue Star Hwy, 15 ST 0.75 miles from access road, 10 ft X

E off west side of road.

Perimeter of Palisades North along Blue Star Hwy, 0.4 miles 16 ST E

from access road, 50 ft off west side X

of road.

Perimeter of Palisades Along access road, 25 yds south of 17 ST southem power line, 15 yds off east X

ESE side of road.

Perimeter of Palisades 20 yds from access road along south 18 ST X

SE road. 40 yds off south road.

Perimeter of Palisades 0.2 miles along south road from 19 ST access road, 30 ft off north side of X

SSE road.

Perimeter of Palisades 0.4 miles along south road from 20 ST access road, 20 ft off south side of X

S road.

Perimeter of Palisades 0.7 miles along south road from 21 ST access road, just past top of hill.

X SSW Near Lake Michigan Bluff.

22 PW Palisades Warehouse Control TLD in lead cave.

X 23 SN19 Emergency Siren 19 On CR380.

X 3 miles ENE

Proc No CH 6.10 Revision 4 REMP SAMPLE LOCATIONS Page 3 of 3 Station Code Location Air Part.

Lake Milk Food Sediment TLD Fish and Water Products Iodine 24 SN26 Emergency Siren 26 On 67th Street.

X 6 miles E 25 SH South Haven, MI South Haven Water Treatment X

5-1/2 miles NNE Plant.

30 STN 1/2 mile N of discharge X

32 LP Ludington Pumped X

X Storage 125 Miles N 45 CV Alternate Control Air 10 miles NNE of Plant X

Sample Station

Location South Haven Lake In Plant Drinking Water Ludington - Lake

% mile N of Plant Sanitary Wastewater Palisades Perimeter Control Arellannos Market Arellannos Market Palisades Control SAMPLE SHIPMENT IDENTIFICATION Palisades Type Date Amount Raw Water Monthly 1 Gallon Composite -

Lake Water Monthly 1 Gallon Composite -

Domestic Water Monthly 1 Gallon Com~osite -

Control Monthly 1 Gallon Sample Composite -

Sediment 1 Liter Wastewater 1 liter Vegetation 6 kg Vegetation 3 kg Blueberries 1 kg Apples 1 kg Fish 1 kg Fish 1 kg Proc No CH 6.10 Revision 4 Page 1 of 1 Remarks

SAMPLE PACKAGING AND SHIPMENT

1.

Label samples clearly as to their contents.

2.

Seal liquid sample containers with tape to prevent leakage.

Proc No CH 6.10 Revision 4 Page 1 of 1

3.

Use sufficient packing material to avoid sample container damage during shipment.

4.

Package air filters in glassine or plastic envelopes.

5.

For TLD shipments, ensure that vendor's shipment instructions are followed.

6.

Ship samples to vendor laboratory with minimal delay after collection so as to avoid elevated analytical levels of detection.

7.

Record sample information on Attachment 3, "Sample Shipment Identification," or, "Environmental Air Sample Data Sheet," or per vendor's instructions as applicable. Include applicable form with shipment.

As Found AlS Sta ion Leakage LY IN) 8SP 9TP 4JS 5PR Comme nts Comple ed By Review ~d By ENVIRONMENTAL AIR SAMPLE DATA SHEET PALISADES As Left Removed Removed Flow Meter Leakage Date Time Reading (ft3)

{Y/NJ Date Date Flow Meter Cal Due Date Proc No CH Attachment Revision 4 Page 1 of 1 Pump Replacement Date 6.10 5

REMP SAMPLE COLLECTION CHECKLIST Month ______

Year _____ _

WEEKLY Air Samples Week 1 Week 2 Week 3 Week 4 WeekS MONTHLY Broadleaf Veg Lake In Drinking Water SHRAW Ludington Ctrl Collected Shipped Proc No CH 6.10 Revision 4 Page 1 of2

REMP SAMPLE COLLECTION CHECKLIST Year _____ _

QUARTERLY TLDs 10 20 30 40 Sanitary Wastewater 10 20 30 40 Plant Air 10 20 30 40 SEMI-ANNUAL Sediment 1

2 Fish - Indicator 1

2 Fish - Control 1

2 ANNUAL Blueberries Apples Collected This form is not required to be retained as a quality record.

Shipped Proc No CH 6.10 Revision 4 Page 2 of2

Proc No CH 6.10 REMP ANALYTICAL REQUIREMENTS Revision 4 Page 1 of2 Sampling Required NRCf Unusual Resultsh

~ edia Interval Analysis LLD Regorting Levels Action Level Action Reguired Direc t by TLD Quarterly Gamma Dose 10 mR J

AirGa seous Weekly 1-131 0.07 pCi/m3 0.9 pCi/m3 0.2 pCi/m3 Notify I

AirPa ~iculate Weekly Gross Beta 0.01 pCi/m3 See note 9 Notify and Gammaaj perform gamma Cs-134 0.05 pCi/m3 10 pCi/m3 5 pCi/m3 isotopic.

Cs-137 0.06 pCi/m3 20 pCi/m3 5 pCi/m3 Water Monthly H-3i 2000 pCi/L 20,000 pCi/L 1000 pCi/L Notify Surf ce Gross Beta 4 pCi/L 10 pC ilL Notify within 24 h Orin ing Gammaa,i 1000 pCi/L if beta ~1 0 pCi/L.

Mn-54 15 pC ilL 400 pCi/L Perform gamma Fe-59 30 pC ilL 1000 pCi/L analysis.

Co-58 15 pC ilL 300 pCi/L Co-60 15 pCi/L 300 pCi/L Zn-65 30 pCi/L 400 pCi/L Any gamma Notify Zr-95 15 pCi/L 400 pCi/L

~30 pCi/L Nb-95 15 pCilL 30 pCi/L Cs-134 15 pC ilL 50 pC ilL Cs-137 18 pCi/L 200 pCi/L BaLa-140 15 pC ilL 2 pCi/L 1-131 1 pCi/L 2 pCi/L Notify Sedir lent Semiannual Gammai Any gamma Notify Cs-134 150 pCi/g

~1 pCi/g Cs-137 180 pCi/g

Proc No CH 6.10 REMP ANALYTICAL REQUIREMENTS Revision 4 Page 2 of 2 Sampling Required NRCf Unusual Resultsh

~ edia Interval Anal:llsis LLD Rel20rting Levels Action Level Action Reguired Fish Semiannual Gammai Any gamma Notify Mn-54 0.13 pCi/g 30 pCi/g

~1 pCi/g Fe-59 0.26 pCi/g 10 pCi/g Co-58 0.13 pCi/g 30 pCi/g Co-60 0.13 pCi/g 10 pCi/g Zn-65 0.26 pCi/g 20 pCi/g Cs-134 0.13 pCi/g 1 pCi/g Cs-137 0.15 pCi/g 2 pCi/g Sroa ~ Leaf Monthly when 1-131 0.06 pCi/g 0.1 pCi/g 0.1 pCi/g Notify Vege tation available Gammai Any gamma Notify Cs-134 0.08 pCi/g 1 pCi/g

~1 pCi/g Cs-137 0.08 pCi/g 2 pCi/g Food Products At time of Gammai Any gamma Notify harvest Cs-134 0.08 pCi/g 1 pCi/g

~1 pCi/g Cs-137 0.08 pCi/g 2 pCi/g aSupph mentary analysis only.

dRadio ilctivity levels may cause LLD levels to be exceeded.

eMonth y composite of weekly filters.

fRepon ng levels per ODCM, Appendix A,Section III.J and Table E-2.

91f gros s beta activity is greater than or equal to 1 pCi/m3 or greater than or equal to ten times last years mean of control sample s, perform gamma analysis on the individual samples.

hWhenl wer the Unusual Results Action Level is reached or exceeded, the word "Notify" under the Action Required column

~ignifie s that the Contract Laboratory performing the analysis is required to notify Palisades.

~Not ree uired for South Haven raw water sample.

IGamm FiI isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attribut ~ble to the effluents from the facility.

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.4)-,r-----'----...J10 BaldwfnW-~l.cl<;. 1.'--ttj.!~&M Proc No CH 6.10 Revision 4 Page 3 of 5

ENVIRONMENTAL MONITORING LOCATIONS TLDs Location Coordinates Distance (mi)

Degrees Stack N 421923.5 W 8618 51.6 1

N 421920.7 0.507 96.09 W 861836.1 Inner Ring 13 N 421947.2 0.518 28.62 W 861834.1 8

N 421946.8 0.594 41.21 W 8618 24.0 14 N 421941.1 0.548 51.93 W 8618 21.2 15 N 421942.3 0.838 64.94 W 861758.1 16 N 421928.0 0.814 83.9 W 861754.6 17 N 42 19 10.5 0.590 114.98 W 861813.9 18 N 42194.2 0.491 138.96 W 8618 28.9 19 N42190.9 0.465 158.69 W 861839.7 20 N 4219 1.1 0.432 174.42 W 8618 48.8 21 N42193.4 0.397 194.02 W 861858.4 Outer Ring 7

N 42 22 40.8 4.102 22.6 W 86170.4 6

N 42 22 30.6 5.309 47.42 W 861415.9 23 N 42 20 44.7 3.191 60.75 W 861535.3 24 N 421959.4 6.029 83.4 W 861149.4 5

N 421827.6 3.491 107.87 W 8614 57.5 4

N 421710.8 3.690 133.63 W 8615 43.5 3

N 4214 38.0 5.704 163.82 vv 00 10 O~.I 2

N 421433.4 5.578 183.62 W 86 19 16.4 Sector E

NNE NE NE ENE E

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Proc No CH 6.10 Revision 4 Page 4 of 5

ENVIRONMENTAL MONITORING LOCATIONS 9

N42181.6 1.686 201.22 W 8619 34.6 Control TLDs 10 N 425316.5 50.727 39.51 W 85 4036.1 11 N 42 1524.4 39.749 96.42 W 853249.4 12 N 41 5654.3 27.989 157.61 W 86 6 24.5 SSW NE E

SSE Proc No CH 6.10 Revision 4 Page 5 of 5 TLD # 10 is located within the Consumers Energy Grand Rapids service facility attached to a pole located adjacent to the south fence.

TLD # 11 is located within the Consumers Energy Kalamazoo service facility attached to a pole in the far NE corner of the facility - past the employee parking lot.

TLD # 12 is located approximately 30 yards from the road, NE and next to a private residence located at 58399 Wilbur Road, Dowagiac, MI.

A' S I St f Ir ample a Ions Location Coordinates Distance (mi)

Degrees Sector A8 (State Park)

N 421946.8 0.587 40.38 NE W 8618 24.8 A9 (Township N 42184.6 1.539 190.40 S

Park)

W 861911.2 A4 (Covert)

N421712.1 3.903 130.22 SE W 861521.7 A5 (Rood)

N 421830.5 5.804 106.36 ESE W 8614 47.8 A10 (Grand N 42 5316.5 50.727 39.51 NE Rapids)

W 85 4036.1 Air Sample Station # 10 is located within the Consumers Energy Grand Rapids service facility, south side, next to a small service building and due East of TLD # 10.

Control fish and water samples are obtained from the Consumers Energy Pump Storage Facility located in Ludington, MI