Text

Submittal of 2018 Radiological Environmental Operating Report
	ML19122A195
Person / Time
Site:	Palisades
Issue date:	05/02/2019
From:	Hardy J; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PNP 2019-018
	Download: ML19122A195 (55)
	v • d • e

,.

-===-Entergy Entergy Nuclear Operations, Inc Palisades Nuclear Plant 27780 Blue Star Memorial Hwy Covert, MI 49043 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager PNP 2019-018 Technical Specification 5.6.2 May 2,2019 A TIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

2018 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 Technical Specification 5.6.2. The period covered by the enclosed report is January 1, 2018, through December 31, 2018.

If you have any questions regarding this submittal, please contact Mike Soja, Chemistry Manager, at 269-764-2536.

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

Respectfully, JAH/bed

Enclosure:

Annual Radiological Environmental Operating Report CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ENCLOSURE Plant: Palisades Page 1 of 54 YEAR: 2018 Document Number: PNP 2019*018 Annual Radiological Environmental Operating Report

Plant: Palisades I

Year: 2018 I Page 2 of 54 Annual Radiological Environmental Operating Report TABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

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

2.0 INTRODUCTION

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

SUMMARY

......................... 20 ATTACHMENTS - Sample Deviations....................................................................................................... 25 - Monitoring Results Tables............................................................................................ 26 - Interlaboratory Comparison Program Results............................................................... 50 - Previous AREOR ERRATA.......................................................................................... 53

Plant: Palisades I

Year: 2018 I Page 3 of 54 Annual Radiological Environmental Operating Report 1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report (AREOR) presents data obtained through analyses of environmental samples collected for the Palisades Nuclear Plant (PNP) Radiological Environmental Monitoring Program (REMP). The reporting period for this report is from January 1 through December 31,2018. This report fulfills the requirements of PNP Technical Specification 5.6.2.

All required lower limit of detection (LLD) capabilities were achieved for all sample analyses during 2018, as required by the REMP. No measurable levels of radiation above baseline levels attributable to PNP operation were detected in the environment. The 2018 REMP thus substantiated the adequacy of source control and effluent monitoring at PNP with no observed impact of plant operations-on the environment.

PNP established the REMP prior to the station becoming operational to provide data on background radiation and radioactivity normally present in the area. PNP has continued to monitor the environment by sampling air, water, sediment, broad leaf vegetation, fish and food products, as well as measuring direct radiation. PNP also samples milk, if milk-producing animals used for human consumption are present within five miles (8 km) of the plant. The requirements of the REMP are formally described in a site specific regulatory document referred to as the Offsite Dose Calculation Manual (ODCM).

The REMP includes sampling indicator and control locations. The REMP utilizes indicator locations near PNP to identify buildup of radioactivity and control locations to provide a comparison for indicator locations. Indicator, control, and pre-operational results are used to assess any impact PNP operation might have had on the surrounding environment.

The results of the 2018 REMP support the conclusion that the surrounding environment is minimally affected by PNP effluents. No activity in any REMP sample from 2018 was attributed to PNP effluents.

1.2 Reporting Levels No samples equaled or exceeded reporting levels.

1.3 Sample Deviations During 2018, environmental sampling was performed for seven media types (airborne, surface water, drinking water, sediment, broad leaf vegetation, fish, and food products) addressed in the ODCM and for direct radiation. All REMP samples were obtained as required by the ODCM in 2018 with the exception of four thermoluminescent dosimeters (TLDs). Attachment 1 contains the listing of all sample deviations and additional relevant details.

Plant: Palisades I

Year: 2018 I

Page 4 of 54 Annual Radiological Environmental Operating Report 1.4 Program Modifications

1.

There was one program modifications as a result of the 2018 land use census which will result in a change to the 2019 REMP sampling regiment. The 2018 land use census identified the availability of goat milk samples at a location within five miles of PNP. Therefore, goat milk sampling will begin as the goat milk becomes available (summer months). Due to the fact that there is insufficient goat milk indicator locations to meet the requirement of three milk indicator sampling locations, the broad leaf vegetation samples will continue to be collected in accordance with the PNP ODCM. This programmatic change has no effect on the radiological effluents program. As discussed in the 2018 Annual Radioactive Effluent Release Report (ARERR) there was no change in the critical receptors used to model dose consequence of PNP effluents.

2.0 INTRODUCTION

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

2.2 Pathways Monitored The airborne, direct radiation, waterborne, and ingestion pathways are monitored as required by Table 1 through Table 4.

Section 4.0 of this report provides a discussion of 2018 sampling results and Section 5.0 provides a summary of results for the monitored exposure pathways.

2.3 Land Use Census PNP conducts a land use census annually to identify changes in uses of land within five miles of the site that would require modifications to the REMP and the ODCM.

This census is performed to identify critical receptor pathways for the purpose of effluent modeling and REMP sampling.

Plant: Palisades I-Year: 2018 Page 5 of 54 Annual Radiological Environmental Operating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway - Airborne Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency RADIOIODINE AND PARTICULATES A8 (0.595 miles NE) - onsite Continuous sampler operation 1-131 analysis weekly for each filter change.

Six samples total. Four samples from within 6 near state park with sample collection every week, Gross beta radioactivity analysis weekly for each or more frequently if required by km (3.7 miles) of the site boundary in different A 19 (0.423 miles SSE) -

dust loading.

filter change.

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

annual average ground level deposition factor.

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

Covert township performed on the filter.

A5 (3.590 miles ESE) - offsite in Covert township A 10 (50.765 miles NE) -

offsite near Grand Rapids

Plant: Palisades Year: 2018

_~ Page 6 of 54 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency TLDS TLD-1 (0.213 miles E) - on site Quarterly Gamma dose (units of milliRoentgen, abbreviated mR) 23 routine monitoring stations either with two inner ring TLD quarterly or more dosimeters or with one instrument for TLD-8 (0.602 miles NE)- inner ring measuring and recording dose rate TLD continuously, placed as follows:

TLD-13 (0.530 miles NNE) - inner One on site TLD in the vicinity of the plant. An ring TLD inner ring of stations consisting of one in each overland meteorological sector, one in the TLD-14 (0.551 miles NE)- inner general area of the state park camping area in ring TLD the NE sector, and one in the general area of TLD-15 (0.834 miles EN E)- inner the site boundary.

ring TLD TLD-16 (0.804 miles E)- inner ring TLD TLD-17 (0.572 miles ESE) - inner ring TLD TLD-18 (0.469 miles SE) - inner ring TLD TLD-19 (0.443 miles SSE)- inner ring TLD TLD-20 (0.412 miles S)- inner ring TLD TLD-21 (0.382 miles SSW) - inner ring TLD

Plant: PalisadesL__ -'Year: 20~ 8 __ J Page 7 of 54 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency An outer ring of stations, one in each overland TLD-2 (5.560 miles SE) - outer Quarterly Gamma dose (mR) quarterly meteorological sector, within the 12 km range ring TLD from the site.

TLD-3 (5.684 miles SSE) - outer Three control stations sufficiently far from the ring TLD plant as to not be affected by the plant.

TLD-4 (3.668 miles S) - outer ring TLD TLD (3.475 miles ESE) - outer ring TLD TLD (5.314 miles NE) - outer ring TLD TLD-7 (4.115 miles NNE) - outer ring TLD TLD-9 (1.670 miles SSW) - outer ring TLD TLD-23 (3.189 miles EN E) - outer ring TLD TLD-24 (6.021 miles E) - outer ring i

TLD TLD-10 (50.746 miles NE)-

control TLD TLD-11 (39.472 miles E) - control TLD TLD-12 (27.971 miles SSE) -

control TLD

Plant: Palisades Year: 2018 Page 8 of 54 Annual Radiological Environmental Operating Report Table 3, Exposure Pathway - Waterborne Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency SURFACE WATER Lake in - Lake Michigan intake water Daily samples are used to Gamma isotopic and tritium analysis monthly.

Lake in (plant intake lake water).

used in plant systems. Sample is make a monthly composite collected onsite.

sample.

Daily South Haven drinking Gamma isotopic and tritium analysis monthly.

water samples are used to DRINKING WATER City of South Haven drinking water make a monthly composite intake structure (5.6 miles NNE of sample.

South Haven drinking water and Palisades PNP) 1 grab sample of Palisades Gamma isotopic and tritium analysis monthly when Park (Pal Park) community drinking water is sampled when in operation (summer months).

Pal Park community drinking water Park (Pal Park) community operational.

(0.7 miles SSW of PNP) drinking water is sampled monthly when in operation (summer months).

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

intake water from Ludington Pump-sample.

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

surface water.

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

North sediment sample.

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

I

Plant: Palisades Year: 2018 Page 9 of 54 Annual Radiological Environmental Operating Report Table 4, Exposure Pathway - Ingestion Requirement Sample Point Description Distance Sampling and Collection Type and Frequency Of Analyses and Direction Frequency MILK For 2018 there were no available milking Monthly Gamma isotopic and 1-131 monthly Samples from milking animals in 3 locations animals to sample at the specified distance between 5-8km distance from the plant.

One sample from milking animals at a control location.

Broad leaf Vegetation 0.7 miles SE from PNP.

Monthly during growing Gamma isotopic and 1-131 monthly during growing Samples of three different kinds of broad leaf 0.4 miles SSE from PNP.

season season vegetation grown nearest each of two 13.6 miles NNE from PNP.

different offsite locations of highest predicted annual average ground level deposition and one sample of each of the similar broad leaf vegetation grown 15-30 km distance in the least prevalent wind direction IF milk sample is not performed.

FISH The indicator sample is obtained from Lake Semiannually Gamma isotopic analysis semiannually Sample two species of commercially and/or Michigan onsite within a few hundred feet of recreationally important species in the vicinity the main liquid discharge point.

of the plant discharge area.

The control sample is obtained from Lake One sample of the same species in areas not Michigan near Ludington MI (201 km North influenced by plant discharge.

of PNP).

FOOD PRODUCTS 3.7 miles SE from PNP.

Annually at time of harvest Gamma isotopic and 1-131 annually One sample of each of two principal fruit crops (blueberries and apples).

Plant: Enter Plant Name I

Year: YEAR I Page 10 of 54 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway NUCLEAR POWER PLANT l

Exposure pathways to man lIQUIO EFFLUENT 1 -

Plant: Palisades I

Year: 2018 I Page 11 of 54 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field

\\,,

\\

I 2 '\\h Ave

--, / -------8 --

The locations in Figure 2 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

Plant: Palisades 1

Year: 2018 I Page 12 of 54 Annual Radiological Environmental Operating Report Figure 3, Sample Collection Sites - Far Field The locations in Figure 3 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

Plant: Enter Plant Name 1

Year: YEAR I Page 13 of 54 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample Results There were 313 air samples collected and analyzed for gross beta and 1-131 during 2018. Air iodine/particulate samples are collected weekly from six 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. 80th filters are in-line with one another and housed within the same filter holder. An "as found" and "as left" leak test is performed at each station during each sample collection. Weekly samples were sent to Teledyne 8rown Engineering Environmental Services for analysis.

Analysis of the airborne particulate sample data, between the five near-site indicator locations and the control location, indicate no difference between indicator and control locations. The average concentration of gross beta activity among all indicator locations was 2.24E-02 pCi/m3 and was 2.21 E-02 pCi/m3 for the control location. All 1-131 activity results, for both indicator and control locations, were below the minimum detectable activity (MDA). Gamma isotopic analysis is performed quarterly on a quarterly composite of the filter papers. All radionuclides detected (8e-7 and K-40) were naturally occurring radionuclides which are not attributed to plant effluents.

PNP pre-operational environmental study showed naturally occurring gross beta radiation between 0.03 and 3.0 pCi/m3 with a similar trend between stations on-site, in the surrounding community, and control stations. The activity results from 2018 indicate there is no measureable change between pre-operational airborne gross beta activity and present day airborne gross beta activity.

In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. The air sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP air samples from 2018 contained measureable radiological materials attributed to PNP effluents.

Plant: Palisades I

Year: 2018 I Page 14 of 54 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results PNP reports measured dose as net exposure (subtracting transit reading) normalized to 92 days. TLDs are oriented in an inner ring, outer ring, and control locations. The inner ring consists of 11 TLDs, the outer ring consists of 9 TLDs, and there are 3 control locations. This orientation allows for monitoring of all 9 overland compass sectors surrounding PNP. To assess the effect of direct and shine radiation from PNP to the enVironment, the inner ring, outer ring, and control TLDs are compared to one another. Additionally, each individual TLD location is compared to a baseline of data which was created from a comprehensive review of data from 2011 through 2016. The high and low values for the baseline are based upon two standard deviations for each data point from 2011 through 2016. Upon receiving a value outside the baseline, additional follow-up investigation is performed to evaluate the cause. During 2018, all TLDs trended normal and no TLDs were outside the baseline. This evaluation identified no noticeable trend that would indicate that the ambient radiation levels are being affected by plant operations. During 2018, there were three instances in deviations from the REMP involving four total TLDs. These instances are discussed in Attachment 1, Table 8. Table 5 shows the consistent trend of average inner ring, outer ring, and control TLDs.

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

Activity from TLD measurements in the environment is attributed to naturally occurring background radiation and not from PNP direct or shine radiation.

Table 5, Direct Radiation Annual Summary Year Inner Ring Outer Ring (mRlQtr)

Control Location (mRlQtr)

(mRlQtr) 2011 9.7 11.4 11.5 2012 9.7 11.9 11.6 2013 9.9 11.6 11.7 2014 9.1 10.9 10.7 2015 9.5 11.2 10.9 2016 9.6 11.3 11.2 2017 9.3 11.2 10.9 2018 9.3 11.1 11.0

Plant: Palisades I

Year: 2018 I Page 15 of 54 Annual Radiological Environmental O~erating Re~ort 4.3 Waterborne Sample Results During 2018, PNP implemented the REMP in accordance with the aDCM for collection of surface, drinking, and groundwater without any deviations. For all surface, drinking, and groundwater indicator samples, the same control sample is used as a baseline for comparison. That control sample is referred to as the "Ludington Control," and is collected 201 km north of PNP. The Ludington Control sample is analyzed monthly and is a composite of daily samples. The Ludington Control sample is analyzed for gamma radionuclide, tritium, and gross beta activity.

In 2018, the only radionuclide activity detected was naturally occurring isotopes (K-40). In 2018, three out of the twelve Ludington Control samples contained detectable gross beta with an average value of 2.64 pCi/L. The gross beta activity is a result of naturally occurring radionuclide (K-40) and is not attributed to PNP effluents.

4.3.1 Surface Water The indicator surface water samples collected and analyzed for the REMP include "Lake In" water. This sample is Lake Michigan water after it has traveled through the PNP traveling screens. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclides and tritium onsite. This sample is also analyzed by Teledyne Brown Engineering Environmental Services for gamma, tritium, and gross beta activity. During 2018, zero Lake In samples contained detectable tritium. All radionuclides detected (Ra-226) were naturally occurring and are not attributed to PNP effluents. Three out of the twelve monthly samples contained measureable gross beta with the average detectable gross beta activity at 3.01 pCi/L.

PNP pre-operational environmental study established a baseline of gross beta activity for the site before PNP was operational. The study results for surface water showed consistently measurable results for gross beta activity between 11 - 18 (+1-5) pCi/L.

The surface water sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP surface water samples from 2018 contained measureable radiological materials attributed to PNP effluents.

4.3.2 Drinking Water The indicator drinking water samples collected and analyzed for the REMP include "Domestic Water," "South Haven Drinking Water," and "Palisades Park Community Water." Gross beta analysis is not required for these samples, however, gross beta analysis is performed to strengthen the REMP and provide an additional metric used for trending data.

Plant: Palisades I

Year: 2018 I

Page 16 of 54 Annual Radiological Environmental Operating Report Domestic water is collected onsite from a potable water system, typically an eyewash station. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclide and tritium onsite. This sample is also analyzed by Teledyne Brown Engineering Environmental Services for gamma, tritium, and gross beta activity. All radionuclides detected (Th-228) were naturally occurring and are not attributed to PNP effluents. There was no detectable tritium in this sample in 2018.

Five out of the twelve monthly samples contained measureable gross beta activity with the average detectable gross beta activity at 2.62 pCi/L. The gross beta activity is attributed to naturally occurring radionuclides.

South Haven Drinking Water is collected from the City of South Haven Water Treatment facility located in South Haven. The sample is analyzed monthly for gamma, tritium, and gross beta activity. All radionuclides detected (K-40 and Ra-226) were naturally occurring and are not attributed to PNP effluents. There was no detectable tritium for samples collected in 2018. Six out of the twelve monthly samples contained measureable gross beta with the average detectable gross beta activity at 2.86 pCi/L. The gross beta activity is attributed to naturally occurring radionuclides.

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

This sample is analyzed for gamma, tritium, and gross beta activity. All radionuclides detected (K-40 and Th-228) were naturally occurring and are not attributed to PNP effluents. There was no detectable tritium in this sample in 2018. Two out of the six monthly samples contained measureable gross beta activity with the average detectable gross beta activity at 2.99 pCi/L. The gross beta activity is attributed to naturally occurring radionuclides.

PNP pre-operational environmental study established a baseline of gross beta activity for the site before PNP was operational. The study relied upon for a baseline for drinking water analysis results are the same results as with surface water, which is consistent gross beta activity between 11 - 18 (+1-5) pCi/L.

The drinking water sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP drinking water samples from 2018 contained measureable radiological materials attributed to PNP effluents.

Plant: Palisades I

Year: 2018 I Page 17 of 54 Annual Radiological Environmental Operating Report 4.3.3 Groundwater PNP implements an extensive groundwater monitoring program in accordance with NEI 07-07, "Industry Ground Water Protection Initiative - Final Guidance Document."

This program is designed to identify onsite leaks to groundwater to allow for prompt repair or isolation of the leak. The results of the on site groundwater program are described in the ARERR. PNP samples one offsite groundwater location. This sample is not required by PNP ODCM, but is procedurally implemented to strengthen the program overall. The REMP groundwater sample is the "Palisades Park Commercial Well Water" sample. This sample is collected once per month as a grab sample from a community just south of PNP while the facility is operational (summer months). This sample is analyzed for gamma, tritium, and gross beta activity. All radionuclides detected (K-40) were naturally occurring and are not attributed to PNP effluents. There was no detectable tritium in this sample in 2018. Five out of the six monthly samples contained measureable gross beta with the average detectable gross beta activity at 3.65 pCi/L. The gross beta activity is attributed to naturally occurring radionuclides.

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

The groundwater sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP groundwater samples from 2018 contained measureable radiological materials attributed to PNP effluents.

Plant: Palisades I

Year: 2018 I Page 18 of 54 Annual Radiological Environmental Operating Report 4.4 Soil Sample Results Sediment samples are collected two times per year north and south of the plant from the beach on Lake Michigan. One sample is collected at the southern edge of the property and a second sample is collected approximately 0.5 miles north of the plant.

The sample south of the plant is not required by the ODCM but is collected and analyzed to strengthen the REMP. Both the north and south sediment samples are analyzed for gamma radionuclides. In 2018, the only radionuclides detected were naturally occurring (K-40, Ra-226, Th-228, Th-232) isotopes which are not attributed to PNP effluents. In accordance with the ODCM, no control sample is collected for this sample type.

Soil samples were not specifically part of the PNP pre-operational environmental study however, a study of Cs-137 found in soil (due to historical atomic testing and fallout) was performed by PNP in 2011. Analysis was performed of soil in the surrounding area (Southwest Michigan) which showed Cs-137 concentrations between 1.41 E-08 uCi/g and 5.68E-07 uCi/g with an average of 2.68E-07 uCi/g.

Considering similar studies performed by other utilities, a conservative (low) background of 1.8E-07 uCi/g Cs-137 is assumed to be due to global fallout.

The sediment sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP sediment samples from 2018 contained measureable radiological materials attributed to PNP effluents.

4.5 Ingestion Sample Results 4.5.1 Milk Sample Results Milk samples were not collected during 2018 due to the unavailability of indicator locations within five miles of PNP.

4.5.2 Broad leaf Sample Results In accordance with PNP ODCM, three different kinds of broad leaf vegetation are sampled from two onsite (indicator) locations and one offsite (control) location due to the fact that milk sampling is not performed. Broad leaf samples are collected once per month during the growing season and analyzed for gamma radionuclides, including iodine-131. Naturally occurring radionuclides detected in broad leaf vegetation (Be-7, K-40, and Th-228) are not attributed to PNP effluents. Cs-137 detected in broad leaf vegetation was attributed to historical global atomic testing, fallout, and biological uptake. Cs-137 was detected at location BV1 (0.4 miles SSE).

The average concentration of Cs-137 was 62.6 pCi/kg. It is not abnormal to detect Cs-137 in broad leaf samples. PNP procedurally implements a conservative administrative action value to perform additional reviews if the activity of broad leaf samples exceeds 146 pCi/kg Cs-137.

Plant: Palisades I

Year: 2018 I

Page 19 of 54 Annual Radiological Environmental Operating Report Broad leaf sampling is performed due to the lack of milk producing animals near PNP.

The pre-operational environmental study consisted in part of Cs-137 and Sr-90 analysis for crops and milk. These samples, along with broad leaf samples, are a result of fallout and biological uptake. The pre-operational study identified Cs-137 in milk samples ranging from 2 to 70 pCi/L and Sr-90 ranging from 5 to 15 pCi/L. For crop samples gross gamma activity was generally between 0.11 and 0.22 pCi/g and gross beta activity was generally between 0.72 to 3.31 pCi/g.

4.5.3 Fish Sample Results Indicator and Control fish samples are collected and analyzed twice per year. The filet of the fish is analyzed for gamma radionuclide. The indicator fish are collected near PNP lake-out discharge point. At least two species of commercial or recreational importance are collected and analyzed. At least one sample of the same species is collected as a control sample. The control fish are collected 201 km north of PNP near Ludington, MI. In 2018, the only radionuclides detected among all fish samples were naturally occurring radionuclides (K-40 and Ra-226) which were not attributed to PNP effluents.

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

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

The fish sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP fish water samples from 2018 contained measureable radiological materials attributed to PNP effluents.

4.5.4 Food Product Sample Results Two principal fruit crops are collected once per year and analyzed for gamma isotopic and 1-131 in accordance with the REMP. The two crops sampled in 2018 were blueberries and apples. The results of all sample analyses show that only naturally occurring radionuclide (K-40) was present. In accordance with the ODCM, no control sample is collected for this sample type.

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

The fruit Sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2018. This conclusion is that the surrounding environment is minimally affected by PNP effluents. No REMP fruit samples from 2018 contained measureable radiological materials attributed to PNP effluents.

Plant: Palisades I

Year: 2018 I Page 20 of 54 Annual Radiological Environmental Operating Report 4.6 Land Use Census Results Sector 2

3 4

5 6

7 8

9 10 The 2018 land use census results are tabulated in Table 6. The results of the census yielded no new critical receptors for dose modeling purposes. The results of the land use census did reveal a new goat location from which goat milk could be sampled.

Goat milk sampling will be performed as available (seasonally) in 2019.

Table 6, Land Use Census - 2018 Nearest Receptors (units = miles)

Direction Residence Garden Beef Cattle Dairy Cow NNE 1.67 2.52

>5

>5 NE 1.14 3.95

>5

>5 ENE 1.19

>5 2.29

>5 E

1.67 2.46 3.51

>5 ESE 1.35 2.04 2.04

>5 SE 0.87

>5 3.88

>5 SSE 0.80 0.70

>5

>5 S

0.51

>5

>5 SSW 0.48

>5

>5 4.7 Interlaboratory Comparison Results contains a summary for Interlaboratory Comparison program for Teledyne Brown Engineering.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1.

Table 7, Radiological Environmental Monitoring Program Summary, summarizes data for the 2018 REMP program.

Goat

>5 2.45

>5 3.26

>5 3.88

>5

Plant: Enter Plant Name T

Year: YEAR 1 Page 21 of 54 Annual Radiological Environmental O~erating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 3]

Control Number of Sample Type Type I Number LLD [Note 1]

Mean (F)[Note 2]

[Highest Mean (F)[Note 2]

Locations Mean Reportable (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)[Note 2] [Range]

Occurrences

[Note 4]

Gross Beta I 0.01 0.0224 (260 I 260)

Station A8 0.0238 (52/52) 0.0221 (53 153) 0 313

[0.0134 - 0.0459i (0.595 miles NE)

[0.0155 - 0.0459] [0.0109 - 0.0462]

Air (pCi/m3) 1-131/313 0.07

< MDA (0 I 260)

N/A N/A

< MDA (0 I 53) 0 Cs-134 I 24 0.05

< MDA (0/20)

N/A N/A

< MDA (0 I 4) 0 Cs-137 I 24 0.06

< MDA (0 I 20)

N/A N/A

< MDA (0 I 4) 0 Inner Ring Gamma I 55 Sensitivity of 3 9.29 (43 I 43)

Station 1 (onsite 10.63 (4 I 4) 11.01 (12/12) 0 TLDs (mRlQtr) rnR per vendor

[7.73 - 11.15]

0.213 miles E)

[10.28 - 11.15]

[10.18-11.82]

Outer Ring Gamma I 46 Sensitivity of 3 11.13 (34 I 34)

Station 2 (5.560 13.85(4/4) 11.01 (12112) 0 TLDs (mRlQtr) rnR per vendor

[9.17 - 14.21]

miles SE)

[13.44 - 14.21]

[10.18-11.82]

Gross Beta I 24 4.0 3.01 (3 112)

Lake In (Plant 3.01 (3 112) 2.64 (3 112) 0 (2.46 - 4.02) lake intake)

(2.46 - 4.02)

(2.31 - 3.10)

H-3 I 24 2000

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Mn-54 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Fe-59 I 24 30

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Co-58 124 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Lake Water Co-60 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 (pCi/L)

Zn-65 I 24 30

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Zr-95 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Nb-95 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Cs-134 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Cs-137 I 24 18

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 Ba-140 I 24 60

<MDA (0 112)

N/A N/A

<MDA (0 112) 0 La-140 I 24 15

<MDA (0 112)

N/A N/A

<MDA (0 112) 0

Plant: Enter Plant Name Year: YEAR

. I Page 22 of 54 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 3]

Control Number of !

Sample Type Type I Number LLD [Note 1]

Mean (F)[Note 2]

[Highest Mean (F)[Note 2]

Locations Mean Reportable (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)[Note 2] [Range]

Occurrences

[Note 4]

Gross Beta 142 4

2.80 (14 I 30)

Pal Park 2.99 (2 I 6) 2.64 (3 112) 0

[2.27 - 3.96]

Community

[2.57 - 3.40]

[2.31 - 3.10]

Water (0.7 miles H-3 I 42 SSW)

N/A

<MDA (0 112) 0 2000

<MDA (0 I 30)

N/A Mn-54 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Fe-59 I 42 30

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Co-58 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Drinking Water Co-60 I 42 15

<MDA (0 I 30)

N/A

<MDA (0 112) 0 (pCi/L)

N/A Zn-65 I 42 30

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Zr-95 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Nb-95 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Cs-134 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Cs-137 I 42 18

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Ba-140 I 42 60

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 La-140 I 42 15

<MDA (0 I 30)

N/A N/A

<MDA (0 112) 0 Mn-54 112 130

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0 Fe-59 112 260

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0 Co-58 112 130

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0 Fish (pCi/kg)

Co-60 112 130

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0 Zn-65 112 260

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0 Cs-134 112 130

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0

~

Cs-137 112 150

<MDA (0 I 30)

N/A N/A

<MDA (0 I 30) 0

Plant: Enter Plant Name I

Year: YEAR I Page 23 of 54 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 3]

Control Number of Sample Type Type I Number LLD [Note 1]

Mean (F)[Note 2]

Reportable I

[Highest Locations Mean (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)[Note 2] [Range]

Occurrences

[Note 4]

1-131/2 60

<MDA (0/2)

N/A N/A Control sample 0

Food Products Cs-134/2 60

<MDA (0/2)

N/A N/A not required 0

(pCi/kg)

Cs-137/2 80

<MDA (0/2)

N/A N/A 0

1-131/15 60

<MDA (0/10)

N/A N/A

<MDA (0/5) 0 Broad leaf Cs-134 1 15 60

<MDA (0/10)

N/A N/A

<MDA (0/5) 0 Vegetation (pCi/kg)

Cs-137 1 15 80 62.6 (5/10)

BV1 (onsite 0.4 62.6 (5/5)

<MDA (0/5) 0

[39.7 - 92.3]

miles SSE)

[39.7 - 92.3]

Sediment Cs-134/4 150

<MDA (0/4)

N/A N/A Control sample 0

(pCi/kg)

Cs-137/4 180

<MDA (0/4)

N/A N/A not required 0

Plant: Enter Plant Name r - --Year: YEAR Page 24 of 54 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 3]

Control Number of Sample Type Type I Number LLD [Note 1]

Mean (F)[Note 2]

[Highest Mean (F)[Note 2]

Locations Mean Reportable (Units) of Analyses

[Range]

Occurrences

[Range]

Annual Mean]

(F)[Note 2] [Rangej

[Note 4]

Gross Beta I 18 4

3.65 (5 I 6)

Pal Park 3.65 (5 16) 2.64 (3 112) 0

[3.17 - 4.38]

Commercial Well

[3.17 - 4.38]

[2.31 - 3.10]

(0.7 miles SSW)

H-3 118 2000

<MDA (0 I 6)

N/A N/A N/A 0

Mn-54 118 15

<MDA (0 I 6)

N/A N/A N/A 0

Fe-59 118 30

<MDA (0 I 6)

N/A N/A N/A 0

Offsite N/A Groundwater Co-58 118 15

<MDA (0 I 6)

N/A N/A 0

(Pal Park Co-60 118 15

<MDA (0 I 6)

N/A N/A N/A 0

Commercial Zn-65 118 30

<MDA (0 I 6)

N/A N/A N/A 0

Well) (pCi/L)

Zr-95 118 15

<MDA (0 I 6)

N/A N/A N/A 0

Nb-95 118 15

<MDA (0 I 6)

N/A N/A N/A 0

Cs-134 118 15

<MDA (0 I 6)

N/A N/A N/A 0

Cs-137 118 18

<MDA (0 I 6)

N/A N/A N/A 0

Ba-140 118 60

<MDA (0 I 6)

N/A N/A N/A 0

La-140 118 15

<MDA (0 I 6)

N/A N/A N/A 0

LEGEND:

[Note 1] - LLD = Required lower limit of detection based upon PNP Offsite Dose Calculation Manual (ODCM).

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

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

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

I

Plant: Enter Plant Name Year: YEAR-I Page 25 of 54 Annual Radiological Environmental Operating Report Page 1 of 1 Sample Deviations Table 8, Sample Deviations Table Comment Sample Sample Media Date Problem Evaluation I Actions No.

Affected Location The first quarter 2018 TLD #6 was discovered on the ground -20 yards from where it is typically installed. It appears the TLD was dislodged from its housing and moved by the wind. This TLD location is 5.314 miles from the plant in the Equipment NE sector. Upon discovery, a new TLD was installed in the correct location.

1 TLD TLD#6 4/23/18 Malfunction The TLD discovered on the ground was analyzed and the results were slightly less (lower mR/quarter) than normal. All TLD readings are interpreted to determine the effect of direct and shine from PNP on the environmental. For first quarter 2018 the effect of direct and shine from PNP on the environment was less than measurable.

During the weekly REMP air sample collection it was noticed that TLD #18 was missing. The immediate area was searched and the TLD could not be located.

Equipment A new TLD was placed in the location. It is suspected that high wind was a 2

TLD TLD #18 1/15/19 Malfunction cause for the missing TLD. An action to improve upon the TLD housing was initiated. TLD #18 is located in the SE sector as part of the inner ring TLDs. An evaluation of all 4th quarter 2018 TLD results indicate no direct radiation was measureable from PNP.

During the fourth quarter TLD collection it was noticed that TLD #3 and TLD #23 were missing. The immediate area was searched and the TLDs could not be TLD#3 located. A new TLD was placed at each location. It is suspected that high wind I

3 TLD 1/25/19 Equipment was a cause for the missing TLDs. An action to improve upon the TLD housing TLD #23 Malfunction was initiated. Both TLD #3 and TLD #23 are part of the outer ring TLDs. An evaluation of all 4th quarter 2018 TLD results indicate no detectable direct radiation was measureable from PNP.

--~

Plant: Enter Plant Name I

Year: YEAR I

Page 26 of 54 Annual Radiological Environmental Operating Rel!ort Page 1 of 24 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta I

Units: pCi/m;j Start Station Station Station Station Station Station End Date A5 AS [Note 1)

A9 A19 A10[Note2)

Date A4(lndicator) (Indicator) (Indicator) (Indicator) (Indicator) (Control)

REQUIRED LLD..

1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 01/02/18 01/08/18 2.86E-02 2.80E-02 2.54E-02 2.34E-02 2.68E-02 2.32E-02 01/08/18 01/15/18 2.64E-02 2.47E-02 2.16E-02 2.62E-02 2.36E-02 1.74E-02 01/15/18 01/22/18 2.44E-02 3.03E-02 3.17E-02 2.58E-02 2.35E-02 3.14E-02 01/22/18 01/29/18 1.85E-02 2.37E-02 1.85E-02 2.17E-02 1.80E-02 2.48E-02 01/29/18 02/05/18 1.82E-02 2.05E-02 1.89E-02 1.93E-02 2.20E-02 1.70E-02 02/05/18 02/12/18 2.55E-02 2.80E-02 2.92E-02 3.04E-02 2.50E-02 2.58E-02 02/12/18 02/20/18 2.55E-02 3.58E-02 2.96E-02 2.66E-02 2.48E-02 1.09E-02 02/20/18 02/26/18 1.73E-02 1.95E-02 2.33E-02 2.11E-02 1.93E-02 1.71E-02 02/26/18 03/05/18 2.63E-02 3.21E-02 3.14E-02 2.67E-02 2.60E-02 2.92E-02 03/05/18 03/12/18 1.51E-02 1.72E-02 1.89E-02 1.34E-02 1.70E-02 1.34E-02 03/12/18 03/19/18 2.30E-02 2.77E-02 2.82E-02 2.72E-02 2.21E-02 2.64E-02 03/19/18 03/26/18 1.77E-02 1.95E-02 1.76E-02 1.76E-02 1.58E-02 1.59E-02 03/26/18 04/02/18 1.91E-02 1.91E-02 2.25E-02 1.83E-02 2.06E-02 1.94E-02 04/02/18 04/09/18 2.10E-02 2.56E-02 2.45E-02 2.11E-02 2.04E-02 2.40E-02 04/09/18 04/16/18 1.98E-02 2.56E-02 1.99E-02 2.32E-02 2.60E-02 1.33E-02 04/16/18 04/23/18 1.61E-02 1.71E-02 2.15E-02 1.46E-02 1.70E-02 1.96E-02 04/23/18 04/30/18 1.99E-02 2.14E-02 2.09E-02 1.83E-02 1.60E-02 1.94E-02 04/30/18 05/07/18 2.19E-02 2.37E-02 2.42E-02 2.05E-02 2.04E-02 2.37E-02 05/07/18 05/14/18 1.81E-02 2.41E-02 2.34E-02 1.67E-02 1.59E-02 2.27E-02 05/14/18 OS/21/18 1.89E-02 2.00E-02 2.63E-02 1.87E-02 1.89E-02 1.74E-02 OS/21/18 OS/29/18 2.14E-02 2.59E-02 2.93E-02 2.26E-02 2.28E-02 2.42E-02 OS/29/18 06/04/18 1.76E-02 1.97E-02 1.83E-02 1.84E-02 1.90E-02 1.93E-02 06/04/18 06/11/18 1.57E-02 2.06E-02 1.77E-02 1.85E-02 1.73E-02 1.88E-02 06/11/18 06/18/18 2.05E-02 1.95E-02 2.11E-02 2.10E-02 2.19E-02 2.17E-02 06/18/18 06/25/18 1.40E-02 1.79E-02 2.15E-02 1.55E-02 1.54E-02 1.74E-02 06/25/18 07/02/18 2.58E-02 2.58E-02 2.41E-02 2.22E-02 2.55E-02 2.77E-02 07/02/18 07/09/18 2.16E-02 2.58E-02 2.14E-02 2.07E-02 2.15E-02 2.50E-02 07/09/18 07/16/18 2.50E-02 2.59E-02 2.63E-02 2.44E-02 2.66E-02 2.78E-02 07/16/18 07/23/18 2.06E-02 2.49E-02 1.90E-02 2.27E-02 1.80E-02 2.21E-02 07/23/18 07/30/18 1.76E-02 2.00E-02 1.84E-02 1.90E-02 2.06E-02 2.03E-02 07/30/18 08/07/18 2.71E-02 2.98E-02 2.90E-02 2.80E-02 2.45E-02 3.72E-02 08/07/18 08/13/18 2.81E-02 2.84E-02 3.29E-02 3.10E-02 2.67E-02 2.04E-02 08/13/18 08/20/18 2.11E-02 2.73E-02 2.78E-02 2.75E-02 2.66E-02 3.02E-02 08/20/18 08/27/18 2.49E-02 2.97E-02 2.72E-02 3.19E-02 2.72E-02 2.52E-02 08/27/18 09/03/18 2.02E-02 2.00E-02 1.97E-02 1.78E-02 2.05E-02 1.66E-02 09/03/18 09/10/18 1.86E-02 1.50E-02 1.80E-02 1.64E-02 1.51E-02 1.48E-02 09/10/18 09/17/18 1.99E-02 2.02E-02 2.03E-02 2.04E-02 2.32E-02 2.13E-02 09/17/18 09/24/18 1.61E-02 1.87E-02 1.80E-02 1.63E-02 1.68E-02 1.81E-02

Plant: Enter Plant Name I

Year: YEAR I Page 27 of 54 Annual Radiological Environmental Operating Report Page 2 of 24 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta I

Units: pCi/m3 Start Station Station Station Station Station Station End Date A5 AS[Note 1)

A9 A19 A10[Note2)

Date A4(lndicator) (Indicator) (Indicator) (Indicator) (Indicator) (Control) 09/24/18 10/02/18 1.68E-02 2.04E-02 2.10E-02 2.0sE-02 1.78E-02 2.06E-02 10/02/18 10/09/18 1.96E-02 1.9sE-02 2.01E-02 1.6sE-02 1.68E-02 l.ssE-02 10/09/18 10/16/18 1.79E-02 1.83E-02 2.22E-02 1.94E-02 l.s4E-02 2.20E-02 10/16/18 10/22/18 1.72E-02 1.73E-02 1.87E-02 1.92E-02 1.90E-02 2.03E-02 10/22/18 10/29/18 1.60E-02 1.87E-02 1.5sE-02 1.87E-02 1.63E-02 1.48E-02 10/29/18 11/05/18 1.79E-02 1.73E-02 2.43E-02 2.23E-02 2.00E-02 2.08E-02 11/05/18 11/12/18 1.6sE-02 1.91E-02 1.6sE-02 1.82E-02 l.s8E-02 2.0sE-02 11/12/18 11/19/18 2.70E-02 2.43E-02 2.82E-02 2.56E-02 2.s3E-02 2.22E-02 11/19/18 11/27/18 2.70E-02 2.96E-02 3.09E-02 2.71E-02 2.4sE-02 2.42E-02 11/27/18 12/03/18 1.97E-02 1.91E-02 2.84E-02 2.07E-02 2.29E-02 2.02E-02 12/03/18 12/10/18 2.1sE-02 3.00E-02 2.64E-02 2.76E-02 2.69E-02 2.66E-02 12/10/18 12/17/18 4.37E-02 3.8sE-02 4.s9E-02 4.07E-02 3.93E-02 4.62E-02 12/17/18 12/25/18 2.39E-02 2.79E-02 2.64E-02 2.33E-02 2.33E-02 3.21E-02 12/25/18 12/31/18 2.7sE-02 2.47E-02 2.s7E-02 1.94E-02 2.56E-02 2.ssE-02 12/27/18 01/02/19 NAlNote3J NAlNote3J NAlNote3J NAlNote3J J NAlNote3J 1.91E-02

[Note 1] - Station with highest annual mean.

[Note 2] - The sample date range for the last three samples for A10 is from 12/17/18 - 12/21/18, 12/21/18 - 12/27/18, and 12/27/18 - 01/02/19.

[Note 3] - There is no sample result for the indicator stations from 12127118 - 01/02/19 because the date ranges ended on 12/31/19 for these samples. Note 2 described the date ranges for the last three Station A 10 samples.

Table 10, Air Sample Radioiodine Cartridge Data Table Summary Analysis: 1-131 I

Units: pCi/m3 Start Station Station Station Station Station Station End Date A5 AS A9 A19 A 1 O[Note 1)

Date A4(lndicator) (Indicator) (Indicator) (Indicator) (Indicator) (Control)

REQUIRED LLD +

7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 01/08/18 01/15/18

<MDA

<MDA 01/15/18 01/22/18

<MDA

<MDA 01/22/18 01/29/18

<MDA

<MDA 01/29/18 02/05/18

<MDA

<MDA 02/05/18 02/12/18

<MDA

<MDA 02/12/18 02/20/18

<MDA

<MDA 02/20/18 02/26/18

<MDA

<MDA 02/26/18 03/05/18

<MDA

<MDA 03/05/18 03/12/18

<MDA

<MDA 03/12/18 03/19/18

<MDA

Plant: Enter Plant Name I

Year: YEAR I Page 28 of 54 Annual Radiological Environmental Operating Report Page 3 of 24 Monitoring Results Tables Table 10, Air Sample Radioiodine Cartridge Data Table Summary Analysis: 1-131 I

Units: pCi/m" Start Station Station Station Station Station Station End Date A5 A8 A9 A19 A10[Note 1)

Date A4(lndicator) (Indicator) (Indicator) (Indicator) (Indicator) (Control) 03/19/18 03/26/18

<MDA

<MDA 03/26/18 04/02/18

<MDA

<MDA 04/02/18 04/09/18

<MDA

<MDA 04/09/18 04/16/18

<MDA

<MDA 04/16/18 04/23/18

<MDA

<MDA 04/23/18 04/30/18

<MDA

<MDA 04/30/18 05/07/18

<MDA

<MDA 05/07/18 05/14/18

<MDA

<MDA 05/14/18 OS/21/18

<MDA

<MDA OS/21/18 OS/29/18

<MDA

<MDA OS/29/18 06/04/18

<MDA

<MDA 06/04/18 06/11/18

<MDA

<MDA 06/11/18 06/18/18

<MDA

<MDA 06/18/18 06/25/18

<MDA

<MDA 06/25/18 07/02/18

<MDA

<MDA 07/02/18 07/09/18

<MDA

<MDA 07/09/18 07/16/18

<MDA

<MDA 07/16/18 07/23/18

<MDA

<MDA 07/23/18 07/30/18

<MDA

<MDA 07/30/18 08/07/18

<MDA

<MDA 08/07/18 08/13/18

<MDA

<MDA 08/13/18 08/20/18

<MDA

<MDA 08/20/18 08/27/18

<MDA

<MDA 08/27/18 09/03/18

<MDA

<MDA 09/03/18 09/10/18

<MDA

<MDA 09/10/18 09/17/18

<MDA

<MDA 09/17/18 09/24/18

<MDA

<MDA 09/24/18 10/02/18

<MDA

<MDA 10/02/18 10/09/18

<MDA

<MDA 10/09/18 10/16/18

<MDA

<MDA 10/16/18 10/22/18

<MDA

<MDA 10/22/18 10/29/18

<MDA

<MDA 10/29/18 11/05/18

<MDA

<MDA 11/05/18 11/12/18

<MDA

<MDA 11/12/18 11/19/18

<MDA

<MDA 11/19/18 11/27/18

<MDA

<MDA 11/27/18 12/03/18

<MDA

<MDA 12/03/18 12/10/18

<MDA

<MDA 12/10/18 12/17/18

<MDA

Plant: Enter Plant Name I

Year: YEAR I Page 29 of 54 Annual Radiological Environmental Operating Report Page 4 of 24 Monitoring Results Tables Table 10, Air Sample Radioiodine Cartridge Data Table Summary Analysis: 1-131 I

Units: pCi/m3 Start Station Station Station Station Station Station End Date A5 A8 A9 A19 A10[Note 1]

Date A4(lndicator) (Indicator) (Indicator) (Indicator) (Indicator) (Control) 12/17/18 12/25/18

<MDA

<MDA 12/25/18 12/31/18

<MDA

<MDA 12/27/18 01/02/19 NA[Note2]

NA[Note2]

NALNote2J J NALNote2J

<MDA

[Note 1] - The sample date range for the last three samples for A10 is from 12/17/18 - 12/21/18, 12/21/18 - 12/27/18, and 12/27/18 - 01/02/19.

[Note 2] - There is no sample result for the indicator stations from 12/27/18 - 01/02119 because the date ranges ended on 12/31/18 for these samples. Note 1 described the date ranges for the last three Station A 10 samples.

Table 11, Air Sample Gamma Isotopic Analysis: Gamma Isotopic I

Units: pCi/m3 Location Start Date End Date Cs-134 Cs-137 K_40[Note 1]

Be_7[Note 1]

REQUIRED LLD -+

0.05 0.06 NA NA Station A4 1/2/18 4/2/18

<MDA

<MDA 0.103 Station A4 4/2/18 7/2/18

<MDA

<MDA Station A4 7/2/18 10/2/18

<MDA

<MDA Station A4 10/2/18 12/31/18

<MDA

<MDA 0.0995 Station AS 1/2/18 4/2/18

<MDA

<MDA 0.0297 0.0939 Station AS 4/2/18 7/2/18

<MDA

<MDA Station AS 7/2/18 10/2/18

<MDA

<MDA 0.176 Station AS 10/2/18 12/31/18

<MDA

<MDA 0.0710 Station A8 1/2/18 4/2/18

<MDA

<MDA 0.144 Station A8 4/2/18 7/2/18

<MDA

<MDA Station A8 7/2/18 10/2/18

<MDA

<MDA 0.0330

<MDA Station A8 10/2/18 12/31/18

<MDA

<MDA 0.0989 Station A9 1/2/18 4/2/18

<MDA

<MDA 0.118 Station A9 4/2/18 7/2/18

<MDA

<MDA 0.0156

<MDA Station A9 7/2/18 10/2/18

<MDA

<MDA 0.182 Station A9 10/2/18 12/31/18

<MDA

<MDA 0.0642 Station A19 1/2/18 4/2/18

<MDA

<MDA Station A19 4/2/18 7/2/18

<MDA

<MDA Station A19 7/2/18 10/2/18

<MDA

<MDA Station A19 10/2/18 12/31/18

<MDA

<MDA 0.0230

<MDA Station Al0 1/2/18 4/2/18

<MDA

<MDA 0.121 Station Al0 4/2/18 7/2/18

<MDA

<MDA 0.207 Station Al0 7/2/18 10/1/18

<MDA

<MDA Station Al0 10/2/18 12/27/18

<MDA

<MDA 0.0934

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

Plant: Enter Plant Name I

Year: YEAR I Page 30 of 54 Annual Radiological Environmental Operating Report Page 5 of 24 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose I

Units: mR Station 1st atr 2018 2nd Qtr 2018 3rd atr 2018 4th atr 2018 Annual Mean l[Note 1]

10.50 11.15 10.28 10.59 10.63 8

9.68 10.22 10.28 10.07 10.06 13 9.53 9.49 9.05 8.87 9.24 14 8.23 7.99 7.99 7.73 7.99 15 9.14 9.37 8.44 8.78 8.93 16 9.33 9.54 8.72 9.08 9.17 17 8.63 8.93 8.34 8.42 8.58 18 9.52 9.60 9.56 NA[Note 2]

9.56 19 9.09 9.41 9.27 9.20 9.24 20 9.45 9.75 9.30 9.22 9.43 21 9.58 9.59 9.34 9.28 9.45

[Note 1] - Station with the highest annual mean

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table

Plant: Enter Plant Name I

Year: YEAR I Page 31 of 54 Annual Radiological Environmental Operating Report Page 6 of 24 Monitoring Results Tables Table 13, Thermoluminescent Dosimeters - Outer Ring Analysis: Gamma Dose Units: mR Station 1st atr 2018 2nd atr 2018 3rd Qtr 2018 4th atr 2018 Annual Mean 2[Note I[

13.44 14.21 14.01 13.74 13.85 3

10.74 10.42 10.71 NA[Note2J 10.62 4

11.93 12.19 11.92 11.53 11.89 5

10.93 11.26 10.97 10.92 11.02 6

9.96[Note 2J 10.42 9.95 10.49 10.21 7

9.34 9.74 9.17 9.48 9.43 9

10.39 10.41 10.23 9.97 10.25 23 11.92 11.15 11.07 NA[Note2J 11.38 24 11.54 11.31 11.42 11.60 11.47

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table Table 14, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mR Station 1st atr 2018 2nd atr 2018 3rd Qtr 2018 4th atr 2018 Annual Mean 10 10.18 10.29 10.29 10.61 10.34 11 11.58 11.82 11.55 11.79 11.69 12 10.80 11.38 10.31 11.54 11.01

Plant: Palisades I

Year: 2018 I Page 32 of 54 Annual Radiological Environmental Operating Report Page 7 of 24 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic I

Units: pCilL Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Ra-226 K-40 REQUIRED LLD +

15 15 30 15 30 15 30 15 18 60 15 NA NA

[Note 1]

Lake In 01/01/18 02/01/18

<MDA

<MDA (Indicator)

Lake In 02/01/18 03/01/18

<MDA

<MDA (Indicator)

Lake In 03/01/18 04/01/18

<MDA

<MDA (Indicator)

Lake In 04/01/18 05/01/18

<MDA

<MDA 66.6

<MDA (Indicator)

Lake In 05/01/18 06/01/18

<MDA

<MDA (Indicator)

Lake In 06/01/18 07/01/18

<MDA

<MDA (Indicator)

Lake In 07/01/18 08/01/18

<MDA

<MDA (Indicator)

Lake In 08/01/18 09/01/18

<MDA

<MDA (Indicator)

Lake In 09/01/18 10/01/18

<MDA

<MDA (Indicator)

Plant: Palisades I

Year: 2018 I Page 33 of 54 Annual Radiological Environmental Operating Report Page 8 of 24 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic I

Units: pCilL Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 8a-140 La-140 Ra-226 K-40 Lake In 10/01/18 11/01/18

<MDA

<MDA (Indicator)

Lake In 11/01/18 12/01/18

<MDA

<MDA (Indicator)

Lake In 12/01/18 01/01/19

<MDA

<MDA (Indicator)

Ludington 01/01/18 02/01/18

<MDA

<MDA (Control)

Ludington 02/01/18 03/01/18

<MDA

<MDA (Control)

Ludington 03/01/18 04/01/18

<MDA

<MDA (Control)

Ludington 04/01/18 05/01/18

<MDA

<MDA (Control)

Ludington 05/01/18 06/01/18

<MDA

<MDA (Control)

Ludington 06/01/18 07/01/18

<MDA

<MDA (Control)

Ludington 07/01/18 08/01/18

<MDA

<MDA (Control)

Plant: Palisades Year: 2018 I Page 34 of 54 Annual Radiological Environmental Operating Report Page 9 of 24 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic I

Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 8a-140 La-140 Ra-226 K-40 Ludington 08/01/18 09/01/18

<MDA

<MDA 27.5 (Control)

Ludington 09/01/18 10/01/18

<MDA

<MDA (Control)

Ludington 10/01/18 11/01/18

<MDA

<MDA I

(Control)

Ludington 11/01/18 12/01/18

<MDA

<MDA (Control)

Ludington 12/01/18 01/01/19

<MDA

<MDA 36.2 (Control)

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

Plant: Palisades I

Year: 2018 I Page 35 of 54 Annual Radiological Environmental Operating Report Page 10 of 24 Monitoring Results Tables Table 16, Surface Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date H-3 Gross Beta REQUIRED LLD +

2000 4.00 Lake In (Indicator) 01/01/18 02/01/18

<MDA

<MDA Lake In (Indicator) 02/01/18 03/01/18

<MDA

<MDA Lake In (Indicator) 03/01/18 04/01/18

<MDA

<MDA Lake In (Indicator) 04/01/18 05/01/18

<MDA

<MDA Lake In (Indicator) 05/01/18 06/01/18

<MDA

<MDA Lake In (Indicator) 06/01/18 07/01/18

<MDA 4.02 Lake In (Indicator) 07/01/18 08/01/18

<MDA

<MDA Lake In (Indicator) 08/01/18 09/01/18

<MDA

<MDA Lake In (Indicator) 09/01/18 10/01/18

<MDA 2.54 Lake In (Indicator) 10/01/18 11/01/18

<MDA

<MDA Lake In (Indicator) 11/01/18 12/01/18

<MDA 2.46 Ludington (Control) 01/01/18 02/01/18

<MDA

<MDA Ludington (Control) 02/01/18 03/01/18

<MDA

-~-

-~

Plant: Palisades Year: 2018 I Page 36 of 54 Annual Radiological Environmental Operating Report Page 11 of 24 Monitoring Results Tables Table 16, Surface Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date H-3 Gross Beta Ludington (Control) 03/01/18 04/01/18

<MDA

<MDA Ludington (Control) 04/01/18 05/01/18

<MDA

<MDA Ludington (Control) 05/01/18 06/01/18

<MDA

<MDA Ludington (Control) 06/01/18 07/01/18

<MDA 2.50 Ludington (Control) 07/01/18 08/01/18

<MDA

<MDA I

Ludington (Control) 08/01/18 09/01/18

<MDA

<MDA Ludington (Control) 09/01/18 10/01/18

<MDA 3.10 Ludington (Control) 10/01/18 11/01/18

<MDA 2.31 Ludington (Control) 11/01/18 12/01/18

<MDA

<MDA Ludington (Control) 12/01/18 01/01/19

<MDA

Plant: Palisades I

Year: 2018 I Page 37 of 54 Annual Radiological Environmental Operating Report Page 12 of 24 Monitoring Results Tables Table 17, Drinking Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Mn-Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-Cs-Ba-La-K-40 Th-Ra-Date Date 54 134 137 140 140 228 226 REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 NA NA NA

[Note 2)

Domestic 01/01/18 02/01/18

<MDA

<MDA Water Domestic 02/01/18 03/01/18

<MDA

<MDA 6.08

<MDA Water Domestic 03/01/18 04/01/18

<MDA

<MDA Water Domestic 04/01/18 05/01/18

<MDA

<MDA Water Domestic 05/01/18 06/01/18

<MDA

<MDA Water Domestic 06/01/18 07/01/18

<MDA

<MDA Water Domestic 07/01/18 08/01/18

<MDA

<MDA Water Domestic 08/01/18 09/01/18

<MDA

<MDA Water Domestic 09/01/18 10/01/18

<MDA

<MDA Water

Plant: Palisades 1

Year: 2018 I Page 38 of 54 Annual Radiological Environmental Operating Report Page 13 of 24 Monitoring Results Tables Table 17, Drinking Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Mn-Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-Cs-8a-La-K-40 Th-Ra-Date Date 54 134 137 140 140 228 226 REQUIRED LLD -+

15 15 30 15 30 15 15 15 18 60 15 NA NA NA

[Note 2)

Domestic 10/01/18 11/01/18

<MDA

<MDA 3.23

<MDA Water Domestic 11/01/18 12/01/18

<MDA

<MDA Water Domestic 12/01/18 01/01/19

<MDA

<MDA Water Pal Park 05/14/18 NA[Note 1]

<MDA

<MDA Community Pal Park 06/15/18 NA[Note 1]

<MDA

<MDA Community Pal Park 07/18/18 NA[Note 1]

<MDA

<MDA Community Pal Park 08/20/18 NA[Note 1]

<MDA

<MDA Community Pal Park 09/24/18 NA[Note 1]

<MDA

<MDA 57.0

<MDA

<MDA I

Community Pal Park 10/11/18 NA[Note 1]

<MDA

<MDA Community

Plant: Palisades 1

Year: 2018 I Page 39 of 54 Annual Radiological~rlyJronmental Operating Report Page 14 of 24 Monitoring Results Tables Table 17, Drinking Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Mn-Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-Cs-Ba-La-K-40 Th-Ra-Date Date 54 134 137 140 140 228 226 REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 NA NA NA

[Note 2]

South 01/01/18 02/01/18

<MDA

<MDA Haven South 02/01/18 03/01/18

<MDA

<MDA Haven South 03/01/18 04/01/18

<MDA

<MDA Haven South 04/01/18 05/01/18

<MDA

<MDA 54.1

<MDA

<MDA Haven South 05/01/18 06/01/18

<MDA

<MDA Haven South 06/01/18 07/01/18

<MDA

<MDA Haven South 07/01/18 08/01/18

<MDA

<MDA Haven South Haven 08/01/18 09/01/18

<MDA

<MDA South 09/01/18 10/01/18

<MDA

<MDA Haven

~ ----

Plant: Palisades I

Year: 2018 I Page 40 of 54 Annual Radiological Environmental Operating Report Page 15 of 24 Monitoring Results Tables Table 17, Drinking Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCilL Location Start End Mn-Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-Cs-Ba-La-K-40 Th-Ra-Date Date 54 134 137 140 140 228 226 REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 NA NA NA

[Note 2]

South 10/01/18 11/01/18

<MDA

<MDA 46.7 Haven South 11/01/18 12/01/18

<MDA

<MDA Haven South 12/01/18 01/01/19

<MDA

<MDA Haven I

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

[Note 2] - This nuclide is naturally occurring and there is no aDeM required LLD.

7 Tabl Drinkina W T...

dG B

Analysis: H-3 l

Units: pCi/L Location Start Date End Date H-3 Gross Beta REQUIRED LLD +

2000 4.00 Domestic Water 01/01/18 02/01/18

<MDA

<MDA Domestic Water 02/01/18 03/01/18

<MDA

<MDA Domestic Water 03/01/18 04/01/18

<MDA

Plant: Palisades Year: 2018 Page 41 of 54 Annual Radiological Environmental Operating_Report Page 16 of 24 Monitoring Results Tables Table 18. Drinkina W T '.'

dG B

Analysis: H-3 I

Units: pCi/L Location Start Date End Date H-3 Gross Beta Domestic Water 04/01/18 05/01/18

<MDA

<MDA Domestic Water 05/01/18 06/01/18

<MDA 2.70 Domestic Water 06/01/18 07/01/18

<MDA 3.28 Domestic Water 07/01/18 08/01/18

<MDA

<MDA Domestic Water 08/01/18 09/01/18

<MDA

<MDA Domestic Water 09/01/18 10/01/18

<MDA 2.27 Domestic Water 10/01/18 11/01/18

<MDA

<MDA Domestic Water 11/01/18 12/01/18

<MDA 2.33 Domestic Water 12/01/18 01/01/19

<MDA 2.52 Pal Park Community 05/14/18 NA[Note 1)

<MDA

<MDA Pal Park Community 06/15/18 NA[Note 1)

<MDA

<MDA Pal Park Community 07/18/18 NA[Note 1)

<MDA

<MDA Pal Park Community 08/20/18 NA[Note 1)

<MDA

<MDA Pal Park Community 09/24/18 NA[Note 1)

<MDA 3.40 Pal Park Community 10/11/18 NA[Note 1)

<MDA 2.57 South Haven 01/01/18 02/01/18

<MDA

Plant: Palisades I

Year: 2018 I Page 42 of 54 Annual Radiological Environmental Operating Report Page 17 of 24 Monitoring Results Tables Table 18. Drinkina Wat Trif dG Bet Analysis: H-3 I

Units: pCi/L Location Start Date End Date H-3 Gross Beta South Haven 02/01/18 03/01/18

<MDA

<MDA South Haven 03/01/18 04/01/18

<MDA

<MDA South Haven 04/01/18 05/01/18

<MDA

<MDA South Haven 05/01/18 06/01/18

<MDA 2.40 South Haven 06/01/18 07/01/18

<MDA 2.54 South Haven 07/01/18 08/01/18

<MDA

<MDA South Haven 08/01/18 09/01/18

<MDA

<MDA South Haven 09/01/18 10/01/18

<MDA 3.96 South Haven 10/01/18 11/01/18

<MDA 2.69 South Haven 11/01/18 12/01/18

<MDA 3.00 South Haven 12/01/18 01/01/19

<MDA

<MDA I

I

Plant: Palisades I

Year: 2018 I Page 43 of 54 Annual Radiological Environmental Operating Report Page 18 of 24 Monitoring Results Tables Table 19, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 K-40 Ra-226 Th-228 Th-232 REQUIRED LLD..

NA NA NA NA 150 180

[Note 1)

North Sediment 06/15/18

<MDA

<MDA 4590 1240 143

<MDA North Sediment 10/11/18

<MDA

<MDA 3550

<MDA 369

<MDA South Sediment 06/15/18

<MDA

<MDA 2840 1420 325 472 South Sediment 10/11/18

<MDA

<MDA 3370

<MDA 115

<MDA

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

Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location I Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 Ra-226 species REQUIRED LLD..

130 130 260 130 260 130 150 NA NA

[Note 1)

PNP 1 Carp 05/09/18

<MDA

<MDA 2670 1630 PNP 1 Carp 09/18/18

<MDA

<MDA 2960

<MDA PNP 1 Drum 05/16/18

<MDA

<MDA 2790

<MDA I

PNP 1 Gizzard 05/16/18

<MDA

<MDA 3790

<MDA Shad

Plant: Palisades 1

Year: 2018 1 Page 44 of 54 Annual Radiological Environmental Operating Report Page 19 of 24 Monitoring Results Tables Table 20, Fish Analysis: Gamma Isotopic Units: pCilkg Location I Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 Ra-226 species PNP 1 Redhorse 09/05/18

<MDA

<MDA 3970

<MDA Sucker PNP 1 Small mouth 09/18/18

<MDA

<MDA 3390

<MDA Bass Ludington 1 Carp 05/14/18

<MDA

<MDA 3110

<MDA Ludington 1 Drum 05/28/18

<MDA

<MDA 3220

<MDA Ludington 1 Drum 09/14/18

<MDA

<MDA 2880

<MDA Ludington 1 09/13/18

<MDA

<MDA 3090

<MDA Redhorse Sucker Ludington 1 Trout 05/14/18

<MDA

<MDA 3350

<MDA Ludington 1 Trout 09/22/18

<MDA

<MDA 2660

<MDA

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

Plant: Palisades I

Year: 2018 I Page 45 of 54 Annual Radiological Environmental Operating Report Page 20 of 24 Monitoring Results Tables Table 21, Food Products Analysis: 1-131, Gamma Isotopic Units: pCi/kg Sample I Location Collection Date 1-131 Cs-134 Cs-137 K-40 REQUIRED LLD -+

60 60 80 NA

[Note 1)

Blueberries 1 Covert

<MDA

<MDA 1260 MI 06/28/2016 Apples 1 Covert MI 06/28/2016

<MDA

<MDA 836

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

Table 22, Groundwater - Gamma and Iodine Analysis: Gamma Isotopic I

Units: pCi/L J

Location Collection Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 8a-140 La-140 K-40 Date REQUIRED LLD -+

15 15 30 15 30 15 15 15 18 60 15 NA

[Note 1)

Pal Park Commercial 05/14/18

<MDA

<MDA 40.4 Well Pal Park Commercial 06/15/18

<MDA

<MDA I

Well

Plant: Palisades 1

Year: 2018 I Page 46 of 54 Annual Radiological Environmental Operating Report Page 21 of 24 Monitoring Results Tables Table 22, Groundwater - Gamma and Iodine Analysis: Gamma Isotopic I

Units: pCi/L Location Collection Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 K-40 Date REQUIRED LLD..

15 15 30 15 30 15 15 15 18 60 15 NA

[Note 11 Pal Park Commercial 07118118

<MDA

<MDA Well Pal Park Commercial 08/20/18

<MDA

<MDA Well Pal Park Commercial 09/24/18

<MDA

<MDA Well Pal Park Commercial 10/11/18

<MDA

<MDA Well

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

Plant: Palisades 1

Year: 2018 I Page 47 of 54 Annual Radiological Environmental Operating Report Page 22 of 24 Monitoring Results Tables Table 23, Groundwater - Tritium and Gross Beta Activity Analysis: H-3 Units: pCi/L Location Collection Date H-3 Gross Beta REQUIRED LLD..

2000 4.00 I

Pal Park Commercial 05/14/18

<MDA 3.17 Well Pal Park Commercial 06/15/18

<MDA 3.25 Well Pal Park Commercial 07/18/18

<MDA 4.22 Well Pal Park Commercial 08/20/18

<MDA 4.38 Well Pal Park Commercial 09/24/18

<MDA

<MDA Well Pal Park Commercial 10/11/18

<MDA 3.21 Well

Plant: Palisades I

Year: 2018 1 Page 48 of 54 Annual Radiological Environmental Operating Report Page 23 of 24 Monitoring Results Tables Table 24, Broad Leaf Vegetation Analysis: 1-131, Gamma Isotopic Units: pCi/kg Location I Collection Date 1-131 Cs-134 Cs-137 K-40 Be-7 K-40 Th-228 REQUIRED LLD -+

60 60 80 NA NA NA NA

[Note 1)

Location BV1, 0.4

<MDA

<MDA miles SSE 05/29/18 92.3 1260 1240 2360 55.0 Location BV1, 0.4

<MDA

<MDA miles SSE 06/25/18 46.4 836 3860 1740

<MDA Location BV1, 0.4

<MDA

<MDA miles SSE 07/25/18 72.6

<MDA 3410 1610

<MDA Location BV1, 0.4

<MDA

<MDA miles SSE 08/24/18 62.1

<MDA 3230 2040

<MDA Location BV1, 0.4

<MDA

<MDA miles SSE 09/24/18 39.7

<MDA 5000 2130

<MDA Location BV2, 0.7

<MDA

<MDA miles SSE 05/29/18

<MDA

<MDA 634 4010

<MDA Location BV2, 0.7

<MDA

<MDA miles SSE 06/25/18

<MDA

<MDA 1530 2430

<MDA Location BV2, 0.7

<MDA

<MDA miles SSE 07/25/18

<MDA

<MDA 1570 2920

<MDA Location BV2, 0.7

<MDA

<MDA miles SSE 08/24/18

<MDA

<MDA 832 2900

<MDA

Plant: Palisades Year: 2018 I Page 49 of 54 Annual Radiological Environmental Operating Report Page 24 of 24 Monitoring Results Tables Table 24, Broad Leaf Vegetation Analysis: 1-131, Gamma Isotopic Units: pCi/kg Location Collection Date 1-131 Cs-134 Cs-137 K-40 Be-7 K-40 Th-228 Location BV2, 0.7

<MDA

<MDA 1700 2660

<MDA miles SSE 09/24/18 Location BVC, 13.6

<MDA

<MDA 1390 3820

<MDA miles SSE 05/29/18 Location BVC, 13.6

<MDA

<MDA 1320 2910 51.1 miles SSE 06/25/18 Location BVC, 13.6

<MDA

<MDA 1330 2900

<MDA miles SSE 07/25/18 Location BVC, 13.6

<MDA

<MDA 2230 3160

<MDA miles SSE 08/24/18 Location BVC, 13.6

<MDA

<MDA 1810 4170

<MDA miles SSE 09/24/18 I

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

Plant: Palisades I

Year: 2018 I Page 50 of 54 Annual Radiological Environmental Operating Report Page 1 of 3 Interlaboratory Comparison Program Results 1.0 Summary Summary of Results - Inter-laboratory Comparison Program (ICP)

The Teledyne Brown Engineering (TBE) Laboratory analyzed Performance Evaluation (PE) samples of air particulate, air iodine, milk, soil, vegetation, and water matrices for various analytes. The PE samples supplied by Analytics Inc.,

Environmental Resource Associates (ERA) and Department of Energy (DOE)

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

A.

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

B.

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

C.

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

Acceptable (flag = "A") - result within +/- 20% of the reference value Acceptable with Warning (flag = "W") - result falls in the +/- 20% to +/- 30% of the reference value Not Acceptable (flag = "N") - bias is greater than 30% of the reference value Note: The Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP) samples are created to mimic conditions found at DOE sites which do not resemble typical environmental samples obtained at commercial nuclear power facilities.

Plant: Palisades I

Year: 2018 I Page 51 of 54 Annual Radiological Environmental Operating Report Page 2 of 3 Interlaboratory Comparison Program Results For the TBE laboratory, 166 out of 172 analyses performed met the specified acceptance criteria. Six analyses did not meet the specified acceptance criteria for the following reasons and were addressed through the TBE Corrective Action Program.

1.

TBE was unable to report the February 2018 DOE MAPEP vegetation Sr-90 result due to QC failure and limited sample amount. (NCR 18-09)

2.

The Analytics September 2018 milk Fe-59 result was evaluated as Not Acceptable (Ratio of TBE to known result at 133%). The reported value was 158 +/- 17.6 pCi/L and the known value was 119 +/- 19.9 pCi/L. No cause for the failure could be determined. TBE has passed 24 of the previous 27 milk cross-check results since 2012. This sample was run in duplicate on a different detector with comparable results (162 +/- 16 pCi/L). NOTE: TBE's 4h Otr result passed at 105% (NCR 18-20)

3.

The Analytics September milk 1-131 result was evaluated as Not Acceptable (Ratio of TBE to known result at 143%). Due to a personnel change in the gamma prep lab, the sample was not prepped/counted in a timely manner such as to accommodate the 1-131 8-day half-life. Analysts have been made aware of the urgency for this analysis and it will be monitored more closely by QA. NOTE: TBE's 4h Otr result passed at 101%

(NCR 18-24)

4.

The Analytics September soil Cr-51 result was evaluated as Not Acceptable (Ratio of TBE to known result at 131 %). As with #3 above, the sample was not prepped/counted in a timely manner such as to accommodate the Cr-51 27-day half-life. The same corrective action applies here as in #3. (NCR 18-21)

5.

The MAPEP November vegetation Sr-90 result of 0.338 Becquerel/sample was evaluated as Not Acceptable (Lower acceptable range was 0.554 Bq/sample). It appears that there has been incomplete dissolution of Sr-90 due to the composition of the MAPEP vegetation "matrix." To resolve this issue, the TBE-2018 procedure has been modified to add H20 2 to assist in breaking down the organic material that comprises this "matrix." This corrective action will be monitored closely by QA. (NCR 18-25).

Plant: Palisades I

Year: 2018 I Page 52 of 54 Annual Radiological Environmental Operating Report Page 3 of 3 Interlaboratory Comparison Program Results

6.

The Environmental Resource Associates (ERA) November 2018 water Sr-90 sample was evaluated as Not Acceptable. TBE's initial reported result of 36.8 pCi/L exceeded the upper acceptance range (22.9 - 36.4 pCi/L). After reviewing the data for this sample, it was discovered that there was a typographical error at the time the results were entered at the ERA website. The correct result in Laboratory Information Management System (LlMS) of 36.2 should have been submitted instead. This result is within ERA's acceptance limits. In addition to the typo error, ERA's very stringent upper acceptance limit of 116% is not a reflection of TBE's ability to successfully perform this analysis. (NCR 18-23)

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

Plant: Palisades I

Year: 2018 I Page 53 of 54 Annual RadiologJcal Environmental Operating Report Page 1 of 2 Previous AREOR ERRATA The 2017 PNP AREOR contained one section which should have been elaborated upon. As part of this report, a change to the 2017 report is being issued in the ERRATA section. The change to the 2017 report is that the statement, "All detectable radionuclide in 2017 REMP water were naturally occurring isotopes which are not attributed to PNP effluents" is being added to Section III, page 5 of 14.

This change is on the following page of this report. The change is noted by a vertical revision bar in the margin. The change is considered a "small error" following the Regulatory Guide 1.21, Revision 2 guidance in that the "error" does not "impede the NRC's ability to adequately assess the information by the licensee or... alter the intent of the report." In the 2017 report, the acronyms "PNP" is Palisades Nuclear Plant and "MDC" is minimum detectable concentration.

Plant: Palisades I

Year: 2018 I Page 54 of 54 Annual Radiological Environmental Operating Report Page 2 of 2 Previous AREOR ERRATA Gross beta activity was detected in 8 of the 12 Ludington (Control) samples. The average gross beta concentration in these samples was 3.09 pCi/L.

Out of the 20 samples which had detectable gross beta activity, 3 of those samples' activity was greater than 2 sigma above the MDC. All 3 of those samples were Ludington (Control) samples. No statistical difference was found between the indicator and control location samples and no PNP ODCM, reporting limits were exceeded.

All detectable radionuclides in 2017 REMP water were naturally occurring isotopes which are not attributed to PNP effluents.

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 (TLDs) - Gamma Dose Environmental gamma doses are measured quarterly by placement of TLDs at designated locations. Sensitivity for the TLDs is 3 mrem, with a linear response of 1 mrem 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, MI.

TLDs are collected and sent to an offsite vendor quarterly for analysis. All environmental TLDs were collected and analyzed during 2017 with no deviations from the sampling program. The on-site TLD is included with the inner ring (site boundary) TLDs for evaluating any dose effect that could be attributed to PNP operations.

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 = 9.3 mrem Outer Ring = 11.1 mrem Control =

10.9 mrem The highest average quarterly reading was observed at outer ring location number 2 with an average value of 14.1 mrem and a maximum reading of 14.6 mrem. This location is historically the highest among the outer ring

PNP 2019-018, Submittal of 2018 Radiological Environmental Operating Report

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