PNP 2021-016, 2020 Radiological Environmental Operating Report

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2020 Radiological Environmental Operating Report
ML21132A068
Person / Time
Site: Palisades Entergy icon.png
Issue date: 05/12/2021
From: Dotson B
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2021-016
Download: ML21132A068 (46)
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Text

Entergy Nuclear Operations, Inc Palisades Nuclear Plant

. Entergy 27780 Blue Star Memorial Hwy Covert, Ml 49043 Tel 269 764 2000 Barbara E. Dotson Regulatory Assurance Manager (Acting)

PNP 2021-016 Technical Specification 5.6.2 May 12, 2021 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

2020 Radiological Environmental Operating Report Palisades Nuclear Plant Docket 50-255 Renewed Facility 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, 2020, through December 31, 2020.

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, BED/mrp

Enclosure:

Annual Radiological Environmental Operating Report cc: Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

ENCLOSURE ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT PNP 2021-016 44 Pages Follow

....-Entergy Page 1 of 44 Plant: Palisades YEAR: 2020 Document Number: 2021-016 Annual Radiological Environmental Operating Report

Plant: Palisades I Year: 2020 I Page 2 of 44 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 ..... ................................................................................ .. ...... ...... .. ...26 - Monitoring Results Tables ............................................................................................27 - lnterlaboratory Comparison Program Results ............................................................... 44

Plant: Palisades I Year: 2020 I Page 3 of 44 Annual Radiological Environmental Operating Report 1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report presents data obtained through analyses of environmental samples collected for Palisades Radiological Environmental Monitoring Program (REMP) for the period January 1 through December 31, 2020. This report fulfills the requirements of Palisades Technical Specification 5.6.2.

No measurable levels of radiation above baseline levels attributable to Palisades operation were detected in the vicinity of Palisades in 2020. The 2020 REMP thus substantiated the adequacy of source control and effluent monitoring at Palisades with no observed impact of plant operations on the environment.

Palisades established the REMP prior to the station becoming operational to provide data on background radiation and radioactivity normally present in the area.

Palisades has continued to monitor the environment by sampling air, water, sediment, broad leaf vegetation, fish, and food products, as well as measuring direct radiation.

Palisades also samples milk if milk-producing animals used for human consumption are present within five miles (8 km) of the plant. All analyses have required, nuclide specific, lower limit of detections (LLDs) which must be achieved. The requirements of the REMP are formally described in the offsite dose calculation manual (ODCM), a site specific regulatory document.

The REMP includes sampling indicator and control locations. The REMP utilizes indicator locations near the site to show any increases or buildup of radioactivity that might occur due to station operation and control locations farther away from the site to indicate the presence of only naturally occurring radioactivity. Palisades personnel compare indicator results with control and preoperational results to assess any impact Palisades operation might have had on the surrounding environment.

In 2020, REMP samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. All 2020 REMP results support the conclusion that the surrounding environment is minimally affected by Palisades' effluents. No activity in any REMP sample from 2020 was attributed to Palisades' effluents.

1.2 Reporting Levels No samples equaled or exceeded reporting levels.

1.3 Sample Deviations During 2020, environmental sampling was performed for eight media types (airborne, surface water, drinking water, offsite groundwater, sediment, broad leaf vegetation, fish, and food products) and for direct radiation. All REMP samples were obtained as required by the ODCM in 2020 with the exception of three instances of sample deviations which are further discussed in Attachment 1 Table 8.

1.4 Program Modifications There were no program modifications during the reporting period.

Plant: Palisades I Year:2020 I Page 4 of 44 Annual Radiological Environmental Operating Report

2.0 INTRODUCTION

2.1 Radiological Environmental Monitoring Program Palisades established the REMP, as defined in the ODCM, to fulfill 10 CFR Part 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 Palisades ODCM. These requirements are also listed in this report in Table 1 through Table 4.

Section 4.0 of this report provides a discussion of 2020 sampling results and Section 5.0 providing a summary of results for the monitored exposure pathways.

2.3 Land Use Census Palisades 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. The purpose of this census is to identify critical receptor pathways for the purpose of effluent modeling and REMP sampling .

Plant: Palisades Year: 2020 Page 5 of44 Annual Radiolo 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway-Airborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency RADIOIODINE AND PARTICULATES . AB (0 .595 miles NE) - onsite Continuous sampler operation 1-131 analysis weekly for each filter change.

near state park with sample collection every week, Six samples total. Four samples from within 6 Gross beta radioactivity analysis weekly for each or more frequently if required by km (3.7 miles) of the site boundary in different A19 (0.423 miles SSE) - filter change.

dust loading.

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 IF 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 A10 (50 .765 miles NE)-

offsite near Grand Rapids

Plant: Palisades Page 6 of 44 Annual Radiolo ort Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLDS . TLD-1 (0.213 miles E) - onsite Quarteny Gamma dose (units of milliRoentgen, abbreviated mR) inner ring TLD quarteny 23 routine monitoring stations either with two 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 onsite 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 ENE)- inner the site boundary.

ring TLD An outer ring of stations one in each overland TLD-16 (0.804 miles E)- inner ring meteorological sector within the 12 km range TLD from the site.

TLD-17 (0.572 miles ESE) - inner Three control stations sufficientiy far from the ring TLD plant as to not be affected from the plant.

TLD-18 (0.469 miles SE) - inner

. ringTLD 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: Palisades Year: 2020 Page 7 of44 Annual Radiolo Table 2, Exposure Pathway - Direct Radiation Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency TLD-2 (5.560 miles SE) - outer Quarterly Gamma dose (units of milliRoentgen, abbreviated mR) ring TLD quarterly TLD-3 (5.684 miles SSE) - outer ring TLD 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 ENE) - outer

. ring TLD TLD-24 (6.021 miles E) - outer ring

. 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 Page 8 of44 Annual Radiolo Table 3, Exposure Pathway -Waterborne Sample Point Description Sampling and Collection Requirement Type and Frequency Of Analyses Distance and Direction Frequency Lake in - Lake Michigan intake water Daily samples are used to Gamma isotopic, gross beta (not ODCM required), and SURFACE WATER used in plant systems. Sample is make a monthly composite tritium analysis monthly Lake in (plant intake lake water) collected onsite. sample.

Daily South Haven drinking Gamma isotopic, gross beta, 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 South Haven drinking water sample.

Palisades)

Palisades Park (Pal Park) community drinking 1 grab sample of Palisades Gamma isotopic, gross beta (not ODCM required), and Pal Park community drinking water water is sampled when in operation (summer Park (Pal Park) community tritium analysis monthly when operational (0.7 miles SSW of Palisades) months) drinking water is sampled Domestic water is sampled onsite from monthly when in operation Domestic water (not ODCM required) is any potable water source, typically an (summer months). Gamma isotopic, gross beta, and tritium analysis monthly sampled onsite. eye wash station.

Daily samples are used to make a monthly composite.

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

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

surface water.

OFFSITE GROUNDWATER 1 grab sample is sampled Gamma isotopic, gross beta, and tritium analysis monthly monthly when in operation Palisades Park (Pal Park) commercial water 0.7 miles S of Palisades (summer months) is sampled when in operation (summer months). This sample is not ODCM required.

SEDIMENT FROM SHORELINE 1 sample between the north site Semiannually Gamma isotopic analysis semiannually.

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

South sediment sample (not ODCM required) 1 sample from beach near south Semiannually Gamma isotopic analysis semiannually.

boundary of site property

Plant: Palisades Page 9 of44 Annual Radiolo Table 4, Exposure Pathway - Ingestion Sample Point Description Distance Sampling and Collection Requirement Type and Frequency Of Analyses and Direction Frequency MILK For 2020 goat milk samples were not Monthly Gamma isotopic and 1-131 monthly available to be sampled from the indicator Samples from milking animals in 3 locations locations. Therefore no control samples between 5-Bkm distance were obtained, and broad leaf vegetation 1 sample from milking animals at a control was sampled as described below.

location.

Broad leaf Vegetation 0.7 miles SE from Palisades. Monthly during growing Gamma isotopic and 1-131 monthly during growing season season Samples of three different kinds of broad leaf vegetation grown nearest each of two different offsite locations of highest predicted 0.4 miles SSE from Palisades.

annual average ground level deposition and one sample of each of the similar broad leaf vegetation grown 15-30 km distance in the 13.6 miles NNE from Palisades.

least prevalent wind direction IF milk sample is not performed.

E!fil! The indicator sample is obtained from Lake Semiannually Gamma isotopic analysis semiannually Michigan onsite within a few hundred feet of Sample 2 species of commercially and/or the main liquid discharge point.

recreationally important species in the vicinity of the plant discharge area. The control sample is obtained from Lake Michigan near Ludington Ml (201 km North 1 sample of the same species in areas not of Palisades).

influenced by plant discharge.

FOOD PRODUCTS (blueberries) 3.7 to 4.7 miles SE or ESE Annually at time of harvest Gamma isotopic and 1-131 annually from Palisades 1 sample of each of two principal fruit crops (blueberries and apples). (apples) 3.5 to 3.7 miles E or SE from Palisades

Plant: Palisades I Year: 2020 I Page 10 of 44 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway NUCLEAR POWER PLANT 1

/.,...,.

LIQUID EFFLUENT

/ 1rrid~tion * .,

1

~ L TRANSPORT

\ --

--=-'... -

-8 J

Exposure pathways to man

Plant: Palisades I Year:2020 I Page 11 of 44 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field The locations in Figure 2 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

Plant: Palisades I Year: 2020 I Page 12 of 44 Annual Radioloaical 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: Palisades I Year: 2020 I Page 13 of 44 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample There were 311 air samples collected and analyzed for gross beta and 1-131 during 2020. Air iodine and particulate samples are collected weekly from six air-sampling locations. Air is metered into the sampling unit through a 47-mm air filter (for particulate) and an air iodine cartridge. The filters are in series 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 Brown 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 2.22E-02 pCi/m 3 and was 2.1SE-02 pCi/m 3 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 (Be-7) were naturally occurring radionuclides which are not attributed to plant effluents.

Palisades' pre-operational environmental study showed naturally occurring gross beta radiation between 0.03 and 3.0 pCi/m 3 with a similar trend between stations onsite, in the surrounding community, and control stations. The activity results from 2020 indicate there is no measurable change between pre-operational airborne gross beta activity and present day airborne gross beta activity.

There was three REMP deviations in 2020 involving air sampling. Two of the deviations involved a failed sampling pump and the third instance involved a tripped power supply. All REMP air sampling pumps are replaced at least once every 2 years to minimize pump failures.

These instances are discussed in more detail in Attachment 1 Table 8.

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 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP air samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I Year: 2020 I Page 14 of 44 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results Palisades 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 all 9 overland compass sectors surrounding Palisades. To assess the effect of direct and shine radiation from Palisades 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. If a value is measured outside the baseline additional follow-up investigation is performed to evaluate the cause. During 2020 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. Table 5 shows the consistent trend of average inner ring, outer ring, and control TLDs.

TLD measurements taken as part of Palisades' 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 measurable effect on the environment.

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

Table 5, Direct Radiation Annual Summary Inner Ring Control Location Year Outer Ring (mR/Qtr)

(mR/Qtr) (mR/Qtr) 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 2019 9.4 11.2 11.0 2020 9.3 11.2 11.1

Plant: Palisades I Year:2020 I Page 15 of 44 Annual Radiological Environmental Operating Report 4.3 Waterborne Sample Results During 2020 Palisades implemented the REMP in accordance with the ODCM for collection of surface, drinking, and groundwater. 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 Palisades. 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 2020 the only radionuclide activity detected in Ludington Control water was naturally occurring isotopes (K-40 and Th-228). Of the twelve Ludington Control samples collected in 2020, five contained detectable gross beta with an average value of 3.08 pCi/L. The gross beta activity is a result of naturally occurring radionuclide and is not attributed to Palisades' 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 Palisades' intake structure and traveling screens. 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 radionuclide detected (K-40 and Th-228) were naturally occurring and are not attributed to Palisades' effluents. Four out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2. 78 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results for surface water showed consistently measurable results for gross beta activity between 11 - 18

(+/- 5) pCi/L.

The surface water sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP surface water samples from 2020 contained measurable radiological materials attributed to Palisades' 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". All samples are analyzed for gamma, tritium, and gross beta by Teledyne Brown Engineering Environmental Services.

Plant: Palisades I Year: 2020 I Page 16 of 44 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. All radionuclide detected (K-40, and Th-228) were naturally occurring and are not attributed to Palisades' effluents.

Four out of the twelve monthly samples contained measurable gross beta activity with the average detectable gross beta activity at 2.90 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide. Domestic water is not required by the ODCM for the REMP. This sample is collected as part of the NRC bulletin 80-10 commitments and is included in this report because the data strengthens the REMP.

South Haven Drinking Water is collected from the City of South Haven Water Treatment facility located in South Haven. All radionuclide detected (K-40) were naturally occurring and are not attributed to Palisades' effluents. Five out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2. 73 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

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

This sample is analyzed for gamma, tritium, and gross beta activity. No radionuclides were detected via gamma spectroscopy and no tritium was detected in any samples.

One out of the six monthly samples contained measurable gross beta activity with an activity of 2.42 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide. Gross beta activity is not required by the ODCM for this sample but is performed for trending purposes and to strengthen the REMP.

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

The drinking water sample results collected, in accordance with the REMP, support the conclusions of the effluents monitoring program for 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP drinking water samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I Year: 2020 I Page 17 of 44 Annual Radiological Environmental Operating Report 4.3.3 Groundwater Palisades implements an extensive groundwater monitoring program in accordance with NEl-0707, "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 onsite groundwater program are described in the Annual Radioactive Effluent Release Report (ARERR).

Palisades samples one offsite groundwater location. This sample is not required by Palisades' 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 Palisades while the facility is operational (summer months).

This sample is analyzed for gamma, tritium, and gross beta activity by Teledyne Brown Engineering Environmental Services. No radionuclides were detected via gamma spectroscopy and no tritium was detected in any samples. Four out of the five monthly samples contained measurable gross beta with the average detectable gross beta activity at 4.87 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results were that five well water samples from Palisades 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 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP groundwater samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I Year: 2020 I Page 18 of 44 Annual Radiological Environmental Operating Report 4.4 Sediment 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 radionuclide. In 2020, the only radionuclides detected were naturally occurring (K-40, Ra-226, Th-228, and Th-232) isotopes which are not attributed to Palisades' effluents. In accordance with the ODCM, no control sample is collected for this sample type.

Soil samples were not specifically part of the Palisades' pre-operational environmental study however a study of Cs-137 found in soil (due to global events such as historical atomic testing and fallout) was performed by Palisades in 2011.

Analysis was performed of soil in the surrounding area (Southwest Michigan) which showed Cs-137 concentrations between 1.41E-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 in soil 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 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP sediment samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

4.5 Ingestion Sample Results 4.5.1 Milk Sample Results Indicator milk samples were not available to be collected during 2020.

4.5.2 Broad leaf Sample Results In accordance with Palisades ODCM three different kinds of broad leaf vegetation is 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 radionuclide detected in broad leaf vegetation (Be-7 and K-40) are not attributed to Palisades' effluents. Cs-137 detected in broad leaf vegetation was attributed to historical global atomic testing and biological uptake. Cs-137 was detected at location BV1 (0.4 miles SSE) for four out of the five monthly samples. The average concentration of Cs-137 was 1.22E+02 pCi/kg. Cs-137 was detected in one out five samples at location BVC with the one sample having a result of 102 pCi/kg. It is not abnormal to detect Cs-137 in broad leaf samples. Palisades procedurally implements a conservative administrative action value to perform additional reviews if the activity of broad leaf samples exceeds 146 pCi/kg Cs-137. The absence of Cs-134 and the absence of other radionuclides measured in the plant effluent and coolant systems further support that the Cs-137 detected in broadleaf is not a result of Palisades activity.

Plant: Palisades I Year: 2020 I Page 19 of 44 Annual Radiological Environmental Operating Report The pre-operational environmental study consisted in part of Cs-137 and Sr-90 analysis for crops and milk. These (and broadleaf) sample results are a result of historical global atomic testing 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.

The broad leaf sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP broadleaf samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

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 Palisades lake-out discharge point. At least 2 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 Palisades near Ludington, Ml. In 2020, the only radionuclides detected among all fish samples were naturally occurring radionuclides (K-40) which were not attributed to Palisades' effluents.

Palisades' 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 global atomic testing. 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 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP fish water samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

4.5.4 Food Product Sample Results Two principal fruit crops are collected once per year and analyzed for gamma radionuclides including lodine-131 in accordance with the REMP. The two crops sampled in 2020 were blueberries and apples. The results of all sample analysis show that only naturally occurring radionuclides (K-40) were present. In accordance with the ODCM, no control sample is collected for this sample type.

Palisades' 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.

Plant: Palisades I Year: 2020 I Page 20 of 44 Annual Radiological Environmental Operating Report The fruit sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2020. This conclusion is that the surrounding environment is minimally affected by Palisades' effluents. No REMP fruit samples from 2020 contained measurable radiological materials attributed to Palisades' effluents.

4.6 Land Use Census Results The latest land use census (performed in 2020) did not identify any new locations that prompt a change to the REMP or to the atmospheric dispersion or deposition factors used for offsite dose modeling. The sectors in Table 6 include all overland compass sectors.

Table 6, Land Use Census -2020 Nearest Residence Within Five Miles Sector Direction Residence Garden Beef Cattle Dairy Cow Goat 2 NNE 1.67 2.52 >5 >5 >5 3 NE 1.14 2.76 >5 >5 >5 4 ENE 1.19 3.96 2.29 >5 >5 5 E 1.62 2.46 3.51 >5 3.46 6 ESE 1.35 2.04 2.04 >5 2.04 7 SE 0.87 2.20 3.88 >5 3.88 8 SSE 0.80 0.70 >5 >5 >5 9 s 0.51 3.51 >5 >5 >5 10 SSW 0.48 >5 >5 >5 >5 4.7 lnterlaboratory Comparison Results Attachment 3 contains result summary for lnterlaboratory 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 2020 REMP program.

Plant: Palisades Year: 2020 Page 21 of 44 Annual Radiolo Table 7, Radiological Environmental Monitoring Program Summary Location (Note 31 Number of Indicator Locations Mean (F)[Note 2) Control Sample Type Type/ Number LLD [Note1) Non-Routine Mean (F)IN°1* 21 [Highest Locations Mean (Units) of Analyses [Range] Results [Note

[Range] Annual Mean] (F)INote 21 [Range] 4)

Air (pCi/m 3) GB/ 311 0.01 2.22E-02 (259/259) Station A19 2.39E-02 2.15E-02 (52/52) 0

[8.98E 4.23E-02) (0.423 miles (52/52) [1.17E SSE) [1.13E 3.92E-02) 4.13E-021 1-131 / 311 0.07 <MDA (0/259) N/A N/A <MDA<0/52) 0 Cs-134/ 24 0.05 <MDA(0/20) N/A N/A <MDA(0/4) 0 Cs-137 / 24 0.06 <MDA(0/20) N/A N/A <MDA<0/4) 0 Inner Ring Gamma/ 56 Sensitivity of 3 9.28 (44/44) Station 1 10.43 (4/4) 11.14 (12/12) 0 TLDs (mR/Qtr) mR [7.75 -10.82) (onsite 0.213 [9.98 - 10.82] [9.97 - 12.05) 0 miles El Outler Ring Gamma/ 48 Sensitivity of 3 11 .17 (36/36) Station 2 13.82 (4/4) 11.14 (12/12) 0 TLDs (mR/Qtr) mR [9.15-14.20) (5.560 miles S) [13.35 - 14.20) [9.97 - 12.05]

Plant: Palisades Year: 2020 Page 22 of44 Annual Radiolo ort Table 7, Radiological Environmental Monitoring Program Summary Location (Note 31 Number of Indicator Locations Mean (F)[Note 2J Control Sample Type Type/ Number LLD Mean (F)INote 2J Non-Routine (Note1] [Highest Locations Mean Results (Note (Units) of Analyses [Range] (F)INote z1 [Range]

[Range) Annual Mean] 4]

Gross Beta I 24 4.0 2.78 (4112) Lake In (Plant 2.78 (4112) 3.08 (5112) 0

[2.51 - 3.16] lake intake) [2.51 - 3.16] [2.28 - 3.88]

H-3I24 2000 <MDA (0112) NIA NIA <MDA (0112) 0 Mn-54124 15 <MDA(0l 12) NIA NIA <MDA (0112) 0 Fe-59I24 30 <MDA(0l 12) NIA NIA <MDA (0112) 0 Co-58124 15 <MDA(0l 12) NIA NIA <MDA (0112) 0 Surface Water Co-60I24 15 <MDA (0112) NIA NIA <MDA (0112) 0 (pCilL) Zn-65I 24 30 <MDA(0l 12) NIA NIA <MDA (0112) 0 Zr-95I24 15 <MDA (0112) NIA NIA <MDA (0112) 0 Nb-95124 15 <MDA (0112) NIA NIA <MDA (0112) 0 Cs-134I24 15 <MDA (0112) NIA NIA <MDA (0112) 0 Cs-137I24 18 <MDA (0112) NIA NIA <MDA (0112) 0 Ba-140 I 24 60 <MDA (0112) NIA NIA <MDA (0112) 0 La-140124 15 <MDA (0112) NIA NIA <MDA (0112) 0

Plant: Palisades Year: 2020 Page 23 of44 Annual Radiolo ort Table 7, Radiological Environmental Monitoring Program Summary Location (Note 31 Number of Indicator Locations Mean (F)INote 21 Control Sample Type Type / Number LLD [Note1) Mean (F)INote 21 Non-Routine

[Highest Locations Mean Results [Note (Units) of Analyses [Range)

[Range) Annual Mean] (F)IN°1e21 [Range) 4)

Gross Beta/ 42 4 2.77 (10 / 30) Domestic 2.90 (4112) 3.08 (5112) 0

[2.42 - 3.29] Water (onsite) [2.61 - 3.29] [2.28 - 3.88]

H-3142 2000 <MDA(0l 30) NIA NIA <MDA (0112) 0 Mn-54142 15 <MDA(0 / 30) NIA NIA <MDA (0112) 0 Fe-59 / 42 30 <MDA (0130) NIA NIA <MDA (0112) 0 Co-58142 15 <MDA(0 130) NIA NIA <MDA (0112) 0 Drinking Water Co-60 / 42 15 <MDA (0130) NIA NIA <MDA (0112) 0 (pCi/L) Zn-65142 30 <MDA (0130) NIA NIA <MDA (0112) 0 Zr-95142 15 <MDA (0130) NIA NIA <MDA (0 / 12) 0 Nb-95142 15 <MDA (0130) NIA NIA <MDA (0112) 0 Cs-134142 15 <MDA (0130) NIA NIA <MDA (0112) 0 Cs-137142 18 <MDA (0130) NIA NIA <MDA (0112) 0 Ba-140 / 42 60 <MDA (0130) NIA NIA <MDA (0112) 0 La-140142 15 <MDA (0130) NIA NIA <MDA (0112) 0 Mn-54111 130 <MDA(0l6) NIA NIA <MDA (015) 0 Fe-59111 260 <MDA(0l 6) NIA NIA <MDA (015) 0 Co-58111 130 <MDA(0l 6) NIA NIA <MDA(0 15) 0 Fish (pCilkg) Co-60111 130 <MDA(0 16) NIA NIA <MDA (015) 0 Zn-65111 260 <MDA(0l6) NIA NIA <MDA (015) 0 Cs-134111 130 <MDA (016) NIA NIA <MDA (015) 0 Cs-137111 150 <MDA (016) NIA NIA <MDA(0 15) 0

Plant: Palisades Year: 2020 Page 24 of44 Annual Radiolo Ort Table 7, Radiological Environmental Monitoring Program Summary Location (Note 31 Number of Indicator Locations Mean (F)INote 2J Control Sample Type Type/ Number LLD (Note1J Mean (F)INote 21 Non-Routine

[Highest Locations Mean Results (Note (Units) of Analyses [Range] (F)[Note 2) [Range]

[Range) Annual Mean] 4) 1-131 /2 60 <MDA (012) NIA NIA Control sample not 0 Food Products (pCi/kg) Cs-134 / 2 60 <MDA(0/2) NIA NIA required 0 Cs-13712 80 <MDA(0/ 2) NIA NIA 0 1-131115 60 <MDA (0110) NIA NIA <MDA(0l 5) 0 Broad leaf Cs-134115 60 <MDA(Ol 10) NIA NIA <MDA(0l 5) 0 Vegetation (pCilkg) Cs-137 / 15 80 122 (4 / 10) BV1 (onsite 0.4 122 (415) 102 (1 15) 0

[103 - 1311 miles SSE) [103 - 1311 [NIA]

Sediment Cs-13414 150 <MDA(0l4) NIA NIA Control sample not 0 (pCi/kg) Cs-137 / 4 180 <MDA(0l4) NIA NIA required 0

Plant: Palisades Year: 2020 Page 25 of44 Annual Radiolo Table 7, Radiological Environmental Monitoring Program Summary Location (Note 31 Number of Indicator Locations Mean (F)(Note 2J Control Sample Type Type/ Number LLD (Note11 Non-Routine Mean (F)IN°t* 21 [Highest Locations Mean (Units) of Analyses [Range] Results [Note

[Range] Annual Mean] (F)(Note 2J [Range] 4]

Gross Beta / 17 4 4.87 (415) Pal Park 4.87 (415) 3.08 (5112) 0 Commercial [2.28 - 3.88]

[4.11 - 5.35] [4.11 - 5.35]

Well (0.7 miles SSW)

H-3 I 17 2000 <MDA (016) NIA NIA NIA 0 Mn-54117 15 <MDA (016) NIA NIA NIA 0 Fe-59117 30 <MDA (016) NIA NIA NIA 0 Offsite Groundwater Co-58117 15 <MDA (016) NIA NIA NIA 0 (Pal Park Co-60117 15 <MDA(0l 6) NIA NIA NIA 0 Commercial Zn-65117 30 <MDA(0l6) NIA NIA 0 Well) (pCilL) NIA Zr-95117 15 <MDA(0 16) N/A NIA NIA 0 Nb-95117 15 <MDA(0 16) NIA NIA NIA 0 Cs-134117 15 <MDA (016) NIA NIA NIA 0 Cs-137117 18 <MDA(Ol6) NIA NIA NIA 0 Ba-140117 60 <MDA(0l6) NIA NIA NIA 0 La-140117 15 <MDA(0l6) NIA NIA NIA 0

[Note 1] - LLD = Required lower limit of detection

[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 reactor site.

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

Plant: Palisades Year: 2020 Page 26 of44 Annual Radiolo ical Environmental 0 ort Attachment 1 Page 1 of 1 Sample Deviations Table 8, Sample Deviations Table Sample Comment Sample Media Date Problem Evaluation / Actions No. Location Affected During normal weekly sample collection (on 12/21/2020) the sampling pump was found off. Restarting the pump was not successful and therefore the pump Sample Pump was replaced (within one hour of finding the pump off). The sample volume Air Failure 1 AS 12/21/2020 collected was about one third of what was expected indicating that the pump Sample was off for approximately the previous 4 days. The sample volume was sufficient to perform analytical analysis of the filter paper and iodine cartridge.

The reauired lower limit of detection was achieved for this samole.

During normal weekly sample collection (on 11/30/2020) the sampling pump failed to restart after the new filter paper and iodine cartridge were installed. A Air Sample Pump 2 A10 11/30/2020 new sampling pump was installed approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later. The missed Sample Failure sampling time had a minor impact to the total sample volume, and all required lower limit of detection was achieved for this sample.

During normal weekly sample collection (on 08/17/2020) the GFCI outlet the sampling pump is plugged into was found tripped off. The outlet was reset and the power was restored to the sampling pump. The sample volume was very Air Loss of Power 3 A9 08/17/2020 low for the filter paper and iodine cartridge collected indicating that the pump Sample Supply was not running for approximately 6.5 of the previous 7 days. Therefore, the results of the filter paper and iodine cartridge analysis were not included in this report.

Plant: Palisades l Year: 2020 I Page 27 of 44 Annual Radioloaical Environmental Operating Report Attachment 2 Page 1 of 17 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m 3 Station Station Station A4 Station AS Station AB Station AS A19(Note1) A10(Note2]

Start Date End Date (Indicator) (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 12/30/19 01/07/20 2.llE-02 2.32E-02 2.12E-02 2.39E-02 2.32E-02 2.08E-02 01/07/20 01/13/20 1.59E-02 1.53E-02 1.78E-02 1.56E-02 1.85E-02 1.82E-02 01/13/20 01/20/20 2.97E-02 3.36E-02 3.09E-02 3.22E-02 3.25E-02 l.78E-02 01/20/20 01/27/20 1.86E-02 1.82E-02 1.94E-02 1.75E-02 2.02E-02 1.78E-02 01/27/20 02/04/20 1.16E-02 1.39E-02 9.75E-03 8.98E-03 1.13E-02 1.48E-02 02/04/20 02/10/20 1.54E-02 1.85E-02 1.97E-02 l.92E-02 2.llE-02 1.43E-02 02/10/20 02/18/20 1.68E-02 1.87E-02 1.61E-02 l.70E-02 2.00E-02 2.38E-02 02/18/20 02/24/20 2.97E-02 2.56E-02 3.llE-02 2.67E-02 3.93E-02 2.44E-02 02/24/20 03/02/20 2.0lE-02 2.05E-02 2.13E-02 2.02E-02 2.41E-02 l.95E-02 03/02/20 03/09/20 1.83E-02 1.57E-02 l.99E-02 1.73E-02 1.89E-02 1.55E-02 03/09/20 03/16/20 2.03E-02 2.67E-02 2.02E-02 2.49E-02 2.84E-02 2.06E-02 03/16/20 03/23/20 1.82E-02 1.77E-02 2.15E-02 l.65E-02 2.32E-02 2.12E-02 03/23/20 03/30/20 1.95E-02 1.69E-02 1.71E-02 l.92E-02 2.47E-02 l.96E-02 03/30/20 04/06/20 1.56E-02 l.77E-02 1.65E-02 l.52E-02 1.66E-02 l.17E-02 04/06/20 04/13/20 2.08E-02 2.50E-02 2.37E-02 2.02E-02 2.41E-02 2.18E-02 04/13/20 04/20/20 1.94E-02 1.98E-02 2.05E-02 2.12E-02 2.26E-02 1.61E-02 04/20/20 04/27/20 1.68E-02 l.99E-02 1.83E-02 l.77E-02 2.42E-02 1.24E-02 04/27/20 05/04/20 1.l0E-02 1.75E-02 1.50E-02 1.47E-02 l.82E-02 l.43E-02 05/04/20 05/11/20 1.18E-02 l.30E-02 9.77E-03 1.27E-02 1.53E-02 l.36E-02 05/11/20 05/18/20 1.74E-02 l.68E-02 1.54E-02 1.45E-02 2.02E-02 2.13E-02 05/18/20 05/26/20 1.72E-02 2.39E-02 2.04E-02 1.95E-02 2.llE-02 1.43E-02 05/26/20 06/01/20 1.44E-02 1.61E-02 2.22E-02 1.25E-02 1.58E-02 1.61E-02 06/01/20 06/08/20 2.30E-02 2.13E-02 3.22E-02 2.26E-02 2.24E-02 1.74E-02 06/08/20 06/15/20 l.52E-02 l.34E-02 l.84E-02 l.57E-02 l.61E-02 l.43E-02 06/15/20 06/22/20 2.0lE-02 2.53E-02 2.82E-02 2.42E-02 2.43E-02 2.62E-02 06/22/20 06/29/20 2.35E-02 2.18E-02 2.0lE-02 2.17E-02 2.lOE-02 2.34E-02

Plant: Palisades l Year: 2020 I Page 28 of 44 Annual Radioloaical Environmental Operating Report Attachment 2 Page 2 of 17 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m 3 Station Station Station A4 Station A5 Station AS Station A9 A19[Note1] A10[Note 2]

Start Date End Date (Indicator) (Indicator) (Indicator) (Indicator)

(Indicator) (Control) 06/29/20 07/06/20 2.42E-02 2.99E-02 2.18E-02 2.93E-02 2.49E-02 3.28E-02 07/06/20 07/13/20 2.64E-02 2.89E-02 3.12E-02 3.29E-02 2.89E-02 2.39E-02 07/13/20 07/20/20 1.91E-02 2.58E-02 2.02E-02 2.l0E-02 2.17E-02 3.92E-02 07/20/20 07/27/20 l.94E-02 l.93E-02 2.07E-02 2.02E-02 l.86E-02 l.84E-02 07/27/20 08/03/20 l.67E-02 l.83E-02 l.75E-02 1.98E-02 l.97E-02 l.80E-02 08/03/20 08/10/20 2.08E-02 l.89E-02 l.95E-02 1.68E-02 2.12E-02 l.82E-02 08/10/20 08/17/20 l.87E-02 2.00E-02 l.57E-02 [Note 3]

2.15E-02 2.31E-02 08/17/20 08/24/20 2.37E-02 2.34E-02 2.54E-02 2.72E-02 2.65E-02 2.45E-02 08/24/20 08/31/20 2.70E-02 3.50E-02 3.12E-02 2.70E-02 3.20E-02 2.69E-02 08/31/20 09/07/20 2.08E-02 l.80E-02 2.13E-02 l.94E-02 2.30E-02 2.07E-02 09/07/20 09/14/20 1.73E-02 l.63E-02 l.76E-02 l.68E-02 l.85E-02 l.58E-02 09/14/20 09/21/20 2.02E-02 2.47E-02 2.30E-02 2.36E-02 2.llE-02 2.39E-02 09/21/20 09/28/20 3.77E-02 3.38E-02 3.75E-02 3.20E-02 4.06E-02 3.83E-02 09/28/20 10/05/20 l.47E-02 l.17E-02 l.77E-02 l.16E-02 l.67E-02 l.19E-02 10/05/20 10/12/20 2.77E-02 3.36E-02 2.97E-02 2.83E-02 3.04E-02 2.90E-02 10/12/20 10/19/20 l.86E-02 1.90E-02 1.96E-02 1.96E-02 2.68E-02 2.26E-02 10/19/20 10/26/20 l.90E-02 2.llE-02 2.09E-02 1.97E-02 2.30E-02 1.88E-02 10/26/20 11/02/20 2.SlE-02 2.30E-02 2.84E-02 2.75E-02 2.79E-02 2.68E-02 11/02/20 11/09/20 3.85E-02 4.23E-02 3.90E-02 3.69E-02 4.13E-02 3.82E-02 11/09/20 11/16/20 3.06E-02 2.98E-02 3.lOE-02 2.76E-02 2.81E-02 2.71E-02 11/16/20 11/23/20 2.24E-02 2.22E-02 2.51E-02 2.19E-02 2.45E-02 2.17E-02 11/23/20 12/01/20 2.18E-02 2.03E-02 2.60E-02 2.29E-02 2.67E-02 3.14E-02 12/01/20 12/07/20 2.99E-02 3.36E-02 3.28E-02 2.75E-02 2.SlE-02 2.22E-02 12/07/20 12/14/20 3.20E-02 3.39E-02 3.61E-02 3.19E-02 3.28E-02 2.65E-02 12/14/20 12/21/20 3.0lE-02 3.18E-02 3.28E-02 2.97E-02 3.58E-02 2.65E-02 12/21/20 12/28/20 1.36E-02 l.78E-02 l.75E-02 l.73E-02 l.98E-02 2.13E-02

[Note 1] - Station with highest annual mean.

[Note 2] - The sample date range is accurate to plus or minus 2 days for station A 1O

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table

Plant: Palisades I Year: 2020 I Page 29 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 3 of 17 Monitoring Results Tables Table 10, Air Radioiodine Data Table Summary Analysis: 1-131 Units: pCi/m 3 Station Station Station A4 Station AS Station AS Station A9 A10[Note 1)

Start Date End Date A19 (Indicator) (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 12/30/19 01/07/20 <MDA <MDA <MDA <MDA <MDA <MDA 01/07/20 01/13/20 <MDA <MDA <MDA <MDA <MDA <MDA 01/13/20 01/20/20 <MDA <MDA <MDA <MDA <MDA <MDA 01/20/20 01/27/20 <MDA <MDA <MDA <MDA <MDA <MDA 01/27/20 02/04/20 <MDA <MDA <MDA <MDA <MDA <MDA 02/04/20 02/10/20 <MDA <MDA <MDA <MDA <MDA <MDA 02/10/20 02/18/20 <MDA <MDA <MDA <MDA <MDA <MDA 02/18/20 02/24/20 <MDA <MDA <MDA <MDA <MDA <MDA 02/24/20 03/02/20 <MDA <MDA <MDA <MDA <MDA <MDA 03/02/20 03/09/20 <MDA <MDA <MDA <MDA <MDA <MDA 03/09/20 03/16/20 <MDA <MDA <MDA <MDA <MDA <MDA 03/16/20 03/23/20 <MDA <MDA <MDA <MDA <MDA <MDA 03/23/20 03/30/20 <MDA <MDA <MDA <MDA <MDA <MDA 03/30/20 04/06/20 <MDA <MDA <MDA <MDA <MDA <MDA 04/06/20 04/13/20 <MDA <MDA <MDA <MDA <MDA <MDA 04/13/20 04/20/20 <MDA <MDA <MDA <MDA <MDA <MDA 04/20/20 04/27/20 <MDA <MDA <MDA <MDA <MDA <MDA 04/27/20 05/04/20 <MDA <MDA <MDA <MDA <MDA <MDA 05/04/20 05/11/20 <MDA <MDA <MDA <MDA <MDA <MDA 05/11/20 05/18/20 <MDA <MDA <MDA <MDA <MDA <MDA 05/18/20 05/26/20 <MDA <MDA <MDA <MDA <MDA <MDA 05/26/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA 06/01/20 06/08/20 <MDA <MDA <MDA <MDA <MDA <MDA 06/08/20 06/15/20 <MDA <MDA <MDA <MDA <MDA <MDA 06/15/20 06/22/20 <MDA <MDA <MDA <MDA <MDA <MDA 06/22/20 06/29/20 <MDA <MDA <MDA <MDA <MDA <MDA

Plant: Palisades I Year:2020 I Page 30 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 4 of 17 Monitoring Results Tables Table 10, Air Radioiodine Data Table Summary Analysis: 1-131 Units: pCi/m 3 Station Station Station A4 Station A5 Station AS Station A9 A10[Note 1)

Start Date End Date A19 (Indicator) (Indicator) (Indicator) (Indicator)

(Indicator) (Control) 06/29/20 07/06/20 <MDA <MDA <MDA <MDA <MDA <MDA 07/06/20 07/13/20 <MDA <MDA <MDA <MDA <MDA <MDA 07/13/20 07/20/20 <MDA <MDA <MDA <MDA <MDA <MDA 07/20/20 07/27/20 <MDA <MDA <MDA <MDA <MDA <MDA 07/27/20 08/03/20 <MDA <MDA <MDA <MDA <MDA <MDA 08/03/20 08/10/20 <MDA <MDA <MDA <MDA <MDA <MDA 08/10/20 08/17/20 <MDA <MDA <MDA [Note2J <MDA <MDA 08/17/20 08/24/20 <MDA <MDA <MDA <MDA <MDA <MDA 08/24/20 08/31/20 <MDA <MDA <MDA <MDA <MDA <MDA 08/31/20 09/07/20 <MDA <MDA <MDA <MDA <MDA <MDA 09/07/20 09/14/20 <MDA <MDA <MDA <MDA <MDA <MDA 09/14/20 09/21/20 <MDA <MDA <MDA <MDA <MDA <MDA 09/21/20 09/28/20 <MDA <MDA <MDA <MDA <MDA <MDA 09/28/20 10/05/20 <MDA <MDA <MDA <MDA <MDA <MDA 10/05/20 10/12/20 <MDA <MDA <MDA <MDA <MDA <MDA 10/12/20 10/19/20 <MDA <MDA <MDA <MDA <MDA <MDA 10/19/20 10/26/20 <MDA <MDA <MDA <MDA <MDA <MDA 10/26/20 11/02/20 <MDA <MDA <MDA <MDA <MDA <MDA 11/02/20 11/09/20 <MDA <MDA <MDA <MDA <MDA <MDA 11/09/20 11/16/20 <MDA <MDA <MDA <MDA <MDA <MDA 11/16/20 11/23/20 <MDA <MDA <MDA <MDA <MDA <MDA 11/23/20 12/01/20 <MDA <MDA <MDA <MDA <MDA <MDA 12/01/20 12/07/20 <MDA <MDA <MDA <MDA <MDA <MDA 12/07/20 12/14/20 <MDA <MDA <MDA <MDA <MDA <MDA 12/14/20 12/21/20 <MDA <MDA <MDA <MDA <MDA <MDA 12/21/20 12/28/20 <MDA <MDA <MDA <MDA <MDA <MDA

[Note 1] - The sample date range is accurate to plus or minus 2 days for station A 10

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

Plant: Palisades I Year: 2020 I Page 31 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 5 of 17 Monitoring Results Tables Table 11, Air Sample Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/m 3 Location Start Date End Date Cs-134 Cs-137 Be-7[Note 1)

REQUIRED LLD 0.05 0.06 NA Station A4 12/30/19 03/30/20 <MDA <MDA 1.06E-01 Station A4 03/30/20 06/29/20 <MDA <MDA 1.66E-01 Station A4 06/29/20 09/28/20 <MDA <MDA 1.46E-01 Station A4 09/28/20 12/28/20 <MDA <MDA 9.63E-02 Station AS 12/30/19 03/30/20 <MDA <MDA 1.28E-01 Station AS 03/30/20 06/29/20 <MDA <MDA 1.61E-01 Station AS 06/29/20 09/28/20 <MDA <MDA 1.SBE-01 Station AS 09/28/20 12/28/20 <MDA <MDA 7.60E-02 Station AB 12/30/19 03/30/20 <MDA <MDA 1.0lE-01 Station AB 03/30/20 06/29/20 <MDA <MDA 1.70E-01 Station AB 06/29/20 09/28/20 <MDA <MDA 1.SlE-01 Station AB 09/28/20 12/28/20 <MDA <MDA 8.lSE-02 Station A9 12/30/19 03/30/20 <MDA <MDA 1.22E-01 Station A9 03/30/20 06/29/20 <MDA <MDA 1.33E-01 Station A9 06/29/20 09/28/20 <MDA <MDA 1.42E-01 Station A9 09/28/20 12/28/20 <MDA <MDA 7.99E-02 Station A19 12/30/19 03/30/20 <MDA <MDA 1.28E-01 Station A19 03/30/20 06/29/20 <MDA <MDA l.62E-01 Station A19 06/29/20 09/28/20 <MDA <MDA l.0lE-01 Station A19 09/28/20 12/28/20 <MDA <MDA 1.31E-01 Station Al0 12/30/19 03/30/20 <MDA <MDA 1.0SE-01 Station AlO 03/30/20 06/29/20 <MDA <MDA 1.56E-01 Station AlO 06/29/20 09/28/20 <MDA <MDA 1.34E-01 Station Al0 09/28/20 12/28/20 <MDA <MDA 8.17E-02

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

Table 12, Thermoluminescent Dosimeters -Inner Ring Analysis: Gamma Dose Units: mR Annual Station 1st Qtr 2020 2 nd Qtr 2020 3 rd Qtr 2020 4th Qtr 2020 Mean l[Note 1] 10.82 9.98 10.59 10.31 10.43 8 10.09 9.15 9.91 10.10 9.81 13 9.40 8.69 9.25 9.55 9.22 14 8.13 7.75 8.20 8.21 8.07

Plant: Palisades I Year: 2020 I Page 32 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 6 of 17 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mR Annual Station 1st Qtr 2020 2nd Qtr 2020 3rd Qtr 2020 4th Qtr 2020 Mean 15 9.21 8.63 8.89 9.33 9.02 16 9.38 8.49 9.11 9.38 9.09 17 8.68 8.25 8.53 8.80 8.57 18 9.97 8.96 9.65 9.97 9.64 19 9.49 8.82 9.30 9.81 9.36 20 9.15 8.84 9.26 10.02 9.32 21 9.66 9.16 9.73 9.71 9.57

[Note 1] - Station with highest annual mean.

Table 13, Thermoluminescent Dosimeters -Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2020 2nd Qtr 2020 3rd Qtr 2020 4th Qtr 2020 Annual Mean 2[Note l] 14.15 13.58 14.20 13.35 13.82 3 11.03 10.47 11.18 11.46 11.04 4 11.85 11.65 12.20 12.33 12.01 5 10.85 10.76 10.94 11.08 10.91 6 10.91 9.95 10.64 10.93 10.61 7 9.15 9.20 9.50 9.77 9.41 9 10.19 9.46 10.31 10.24 10.05 23 11.22 10.55 10.96 11.40 11.03 24 11.51 11.18 11.42 12.70 11.70

[Note 1] - Station with highest annual mean.

Plant: Palisades I Year: 2020 I Page 33 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 7 of 17 Monitoring Results Tables Table 14, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mR Annual Mean Station 1st Qtr [2020] 2nd Qtr [2020] 3rd Qtr [2020] 4th Qtr [2020]

[2020]

10 10.91 9.97 10.59 10.9 10.59 11 11.97 11.26 12.05 12.01 11.82 12 11.08 10.71 11.09 11.19 11.02 Table 15, Surface Water- Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 K-40 Th-228 Date REQUIRED LLD 15 15 30 15 30 15 15 15 18 60 15 [NotelJ [Note1J Lake In 01/01/20 02/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 02/01/20 03/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 03/01/20 04/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 04/01/20 05/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 05/01/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 06/01/20 07/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 07/01/20 08/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 08/01/20 09/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 25.18 <MDA Lake In 09/01/20 10/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 10/01/20 11/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Lake In 11/01/20 12/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4.29 Lake In 12/01/20 01/01/21 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 30.25 <MDA Ludington 01/01/20 02/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 02/01/20 03/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 28.19 <MDA Control

Plant: Palisades I Year: 2020 I Page 34 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 8 of 17 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-S4 Co-S8 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 K-40 Th-228 Date Ludington 03/01/20 04/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 04/01/20 05/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 05/01/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3.96 Control Ludington 06/01/20 07/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 07/01/20 08/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 08/01/20 09/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 09/01/20 10/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 10/01/20 11/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 11/01/20 12/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Control Ludington 12/01/20 01/01/21 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 36.47 <MDA Control

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

Table 16, Surface Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta REQUIRED LLD + 2000 4.00 Lake In 01/01/20 02/01/20 <MDA <MDA Lake In 02/01/20 03/01/20 <MDA 2.65 Lake In 03/01/20 04/01/20 <MDA <MDA

Plant: Palisades I Year: 2020 I Page 35 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 9 of 17 Monitoring Results Tables Table 16, Surface Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta Lake In 04/01/20 05/01/20 <MDA <MDA Lake In 05/01/20 06/01/20 <MDA <MDA Lake In 06/01/20 07/01/20 <MDA <MDA Lake In 07/01/20 08/01/20 <MDA <MDA Lake In 08/01/20 09/01/20 <MDA 2.51 Lake In 09/01/20 10/01/20 <MDA <MDA Lake In 10/01/20 11/01/20 <MDA 3.16 Lake In 11/01/20 12/01/20 <MDA <MDA Lake In 12/01/20 01/01/21 <MDA 2.80 Ludington Control 01/01/20 02/01/20 <MDA <MDA Ludington Control 02/01/20 03/01/20 <MDA <MDA Ludington Control 03/01/20 04/01/20 <MDA 3.88 Ludington Control 04/01/20 05/01/20 <MDA <MDA Ludington Control 05/01/20 06/01/20 <MDA 3.06 Ludington Control 06/01/20 07/01/20 <MDA <MDA Ludington Control 07/01/20 08/01/20 <MDA <MDA Ludington Control 08/01/20 09/01/20 <MDA 3.87 Ludington Control 09/01/20 10/01/20 <MDA 2.31 Ludington Control 10/01/20 11/01/20 <MDA 2.28 Ludington Control 11/01/20 12/01/20 <MDA <MDA Ludington Control 12/01/20 01/01/21 <MDA <MDA

Plant: Palisades I Year:2020 I Page 36 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 10 of 17 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 K-40 Th-228 Date REQUIRED LLD + 15 15 30 15 30 15 15 15 18 60 15 (NotelJ [Note l]

Domestic 01/01/20 02/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 02/01/20 03/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 03/01/20 04/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 21.03 <MDA Water Domestic 04/01/20 05/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 6.19 Water Domestic 05/01/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 06/01/20 07/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 07/01/20 08/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 08/01/20 09/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 09/01/20 10/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 10/01/20 11/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 42.00 <MDA Water Domestic 11/01/20 12/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Domestic 12/01/20 01/01/21 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Water Pal Park 01/01/20 02/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park 02/01/20 03/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park 03/01/20 04/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community

Plant: Palisades I Year: 2020 I Page 37 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 11 of 17 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Start Location End Date Mn-S4 Co-S8 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 K-40 Th-228 Date REQUIRED LLD + 15 15 30 15 30 15 15 15 18 60 15 (Notel] (Note l ]

Pal Park 04/01/20 05/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park 05/01/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community Pal Park 06/01/20 07/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Community South 01/01/20 02/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 02/01/20 03/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 03/01/20 04/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 44.27 <MDA Haven South 04/01/20 05/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 05/01/20 06/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 06/01/20 07/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 07/01/20 08/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 48.66 <MDA Haven South 08/01/20 09/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 34.93 <MDA Haven South 09/01/20 10/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 10/01/20 11/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 11/01/20 12/01/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Haven South 12/01/20 01/01/21 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 27.86 <MDA Haven

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

Plant: Palisades I Year: 2020 I Page 38 of 44 Annual Radioloaical Environmental Operating Report Attachment 2 Page 12 of 17 Monitoring Results Tables Table 18, Drinking Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta REQUIRED LLD + 2000 4.00 Domestic Water 01/01/20 02/01/20 <MDA <MDA Domestic Water 02/01/20 03/01/20 <MDA 3.07 Domestic Water 03/01/20 04/01/20 <MDA 2.61 Domestic Water 04/01/20 05/01/20 <MDA <MDA Domestic Water 05/01/20 06/01/20 <MDA <MDA Domestic Water 06/01/20 07/01/20 <MDA <MDA Domestic Water 07/01/20 08/01/20 <MDA <MDA Domestic Water 08/01/20 09/01/20 <MDA 2.62 Domestic Water 09/01/20 10/01/20 <MDA <MDA Domestic Water 10/01/20 11/01/20 <MDA <MDA Domestic Water 11/01/20 12/01/20 <MDA <MDA Domestic Water 12/01/20 01/01/21 <MDA 3.29 Pal Park Community 05/26/20 NA[Notel]

<MDA <MDA Pal Park Community 06/22/20 NAINotel)

<MDA <MDA Pal Park Community 07/20/20 NAINotel)

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

<MDA <MDA Pal Park Community 09/07/20 NA[Notel)

<MDA 2.42 Pal Park Community 10/08/20 NAINotel]

<MDA <MDA South Haven 01/01/20 02/01/20 <MDA <MDA South Haven 02/01/20 03/01/20 <MDA 2.89 South Haven 03/01/20 04/01/20 <MDA <MDA

Plant: Palisades I Year:2020 I Page 39 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 13 of 17 Monitoring Results Tables Table 18, Drinking Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta South Haven 04/01/20 05/01/20 <MDA <MDA South Haven 05/01/20 06/01/20 <MDA 2.62 South Haven 06/01/20 07/01/20 <MDA <MDA South Haven 07/01/20 08/01/20 <MDA <MDA South Haven 08/01/20 09/01/20 <MDA 2.46 South Haven 09/01/20 10/01/20 <MDA <MDA South Haven 10/01/20 11/01/20 <MDA 2.77 South Haven 11/01/20 12/01/20 <MDA <MDA South Haven 12/01/20 01/01/21 <MDA 2.91

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

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 + 150 180 [Note 1] [Note 1] [Note 1] [Note 1]

North Sediment 06/02/20 <MDA <MDA 4854 <MDA 266.4 340.8 North Sediment 09/15/20 <MDA <MDA 3314 <MDA 313.7 <MDA South Sediment 06/02/20 <MDA <MDA 3810 884.6 178.1 274.3 South Sediment 09/15/20 <MDA <MDA 4453 <MDA 89.1 <MDA

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

Plant: Palisades I Year:2020 I Page 40 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 14 of 17 Monitoring Results Tables Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location/

Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 species REQUIRED LLD + 130 130 260 130 260 130 150 [Note 1)

Ludington/

05/12/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2187 Redhorse Ludington / Drum 05/21/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 1688 Ludington I Carp 05/26/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2792 Ludington/

08/14/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3370 Catfish Ludington/

08/14/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3019 Walleye Palisades / Carp 06/09/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3879 Palisades/

06/09/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2097 Quillback Carp Palisades / Drum 06/09/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2773 Palisades/

08/13/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 2287 Catfish Palisades/

08/13/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3219 Quillback Carp Palisades/

08/13/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3701 smallmouth bass Palisades/

08/13/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4744 Walleye

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

Plant: Palisades I Year: 2020 I Page 41 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 15 of 17 Monitoring Results Tables Table 21, Food Products Analysis: 1-131, Gamma Isotopic Units: pCi/kg Sample / Location Collection Date 1-131 Cs-134 Cs-137 K-40 REQUIRED LLD + 60 60 80 [Note 1)

Blueberries / Covert

<MDA <MDA <MDA 1503 Ml 07/09/20 Apples/ Covert Ml 08/20/20 <MDA <MDA <MDA 2226

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

Table 22, Offsite Groundwater - Gamma isotopic Analysis: Gamma Isotopic Units: pCi/L Collection Location Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Date REQUIRED LLD 15 15 30 15 30 15 15 15 18 60 15 Pal Park Commercial 06/22/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 07/20/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 08/18/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 09/07/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well Pal Park Commercial 10/08/20 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA Well

Plant: Palisades I Year: 2020 I Page 42 of 44 Annual Radiological Environmental Operating Report Page 16 of 17 Monitoring Results Tables Table 23, Offsite Groundwater - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Collection Date Tritium Gross Beta REQUIRED LLD + 2000 4.00 Pal Park Commercial 6/22/2020 <MDA 4.11 Well Pal Park Commercial 7/20/2020 <MDA <MDA Well Pal Park Commercial 8/18/2020 <MDA 5.05 Well Pal Park Commercial 9/7/2020 <MDA 5.35 Well Pal Park Commercial 10/8/2020 <MDA 4.98 Well 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 REQUIRED LLD -+ 60 60 80 [Note 1] [Note 1]

Location BV1, 0.4 05/26/20 <MDA <MDA <MDA 2381 375.3 miles SSE Location BV1, 0.4 06/22/20 <MDA <MDA 123.5 3369 1118 miles SSE Location BV1, 0.4 07/16/20 <MDA <MDA 103.4 2352 1705 miles SSE Location BV1, 0.4 08/18/20 <MDA <MDA 131.1 2204 2480 miles SSE Location BV1, 0.4 09/11/20 <MDA <MDA 128.6 3975 2903 miles SSE Location BV2, 0.7 05/26/20 <MDA <MDA <MDA 3645 609.1 miles SSE Location BV2, 0.7 06/22/20 <MDA <MDA <MDA 5418 840.8 miles SSE

Plant: Palisades I Year: 2020 I Page 43 of 44 Annual Radiological Environmental Operating Report Attachment 2 Page 17 of 17 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 Location BV2, 0.7 07/16/20 <MDA <MDA <MDA 4677 1645 miles SSE Location BV2, 0.7 miles SSE 08/18/20 <MDA <MDA <MDA 4655 3626 Location BV2, 0. 7 miles SSE 09/11/20 <MDA <MDA <MDA 3133 3104 Location BVC, 13.6 miles SSE 05/26/20 <MDA <MDA <MDA 3902 685.2 Location BVC, 13.6 miles SSE 06/22/20 <MDA <MDA <MDA 4233 564.2 Location BVC, 13.6 07/16/20 <MDA <MDA <MDA 4016 1178 miles SSE Location BVC, 13.6 miles SSE 08/18/20 <MDA <MDA <MDA 3965 2694 Location BVC, 13.6 miles SSE 09/11/20 <MDA <MDA 102.4 3181 4326

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

Plant: Palisades I Year: 2020 I Page 44 of 44 Annual Radiological Environmental Operating Report Attachment 3 Page 1 of 1 lnterlaboratory Comparison Program Results 1.0 Summary Teledyne Brown Engineering (TBE) laboratory participates in three overlapping interlaboratory cross check programs, those being, Analytics Environmental Cross Check Program, Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP), and Environmental Resource Associates (ERA) . Each program has its own grading criteria for pass or fail. All failures are tracked by TBE with a non-conformance report to determine the cause of the failure.

A total of 28 nuclides associated with six media types (air filter, charcoal, milk, soil, vegetation, and water) were analyzed. From all analyses in 2020 five non-conformance reports (NCR's) were initiated.

NCR 20-19-One Sr-89 in milk (provided by Analytics) was outside the acceptance criteria.

NCR 20 One air particulate U-234 and U-238 (provided by DOE) were outside acceptance criteria.

NCR 20 One Ni-63 in soil (provide by DOE) was outside acceptance criteria.

NCR 20 One Gross Alpha/Gross Beta in water (provided by ERA) was outside acceptance criteria.

NCR 20-18 -One 1-131 in water (provided by ERA) was outside acceptance criteria.

TBE NCR's are reviewed by Palisades and validated that the overall impact to the REMP are acceptable. The interlaboratory comparison program is being adequately implemented by TBE. The interlaboratory program overall is one indicator that the REMP results are accurate.

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