Text

Annual Radiological Environmental Operating Report
	ML24114A050
Person / Time
Site:	Palisades
Issue date:	04/23/2024
From:	Noval W; Holtec Decommissioning International
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	HDI PNP 2024-009
	Download: ML24114A050 (1)
	v • d • e

HOLTEC DECOMMISSIO I G INTER ATIONAL Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax(856)797-0909 HDI PNP 2024-009 April 23, 2024

. U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket Nos. 50-255 and 72-007 Renewed Facility Operating License No. DPR-20

Subject:

Annual Radiological Environmental Operating Report Technical Specification 5.6.2 In accordance with the requirements of Palisades Nuclear Plant (PNP) Defueled Technical Specifications Section 5.6.2, Radiological Environmental Operating Report, Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades, LLC (Holtec Palisades) is submitting the 2023 Radiological Environmental Operating Report for PNP. The report was prepared in accordance with the requirements of 10 CFR 50, Appendix I, Section IV.B and 1 V.C. The period covered by the enclosed report is January 1, 2023, through December 31, 2023.

This letter contains no new and no revised regulatory commitments.

Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Manager at (269) 764-2945.

Respectfully, William Naval William Naval Digitally signed by William Noval DN: cn=William Noval, c=US, o=HDI, ou=Regulatory Affairs, email=w.noval@holtec.com Date: 2024.04.23 08:14:04 -04'00' Director Regulatory Affairs Holtec Decommissioning International, LLC

Enclosure:

Annual Radiological Environmental Operating Report cc:

NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Palisades Nuclear Plant NRC NMSS Project Manager - Palisades Nuclear Plant

Enclosure to HDI PNP 2024-009 Annual Radiological Environmental Operating Report

Plant: Palisades Page 1 of 41 YEAR: 2023 Document Number: 2024-009 Annual Radiological Environmental Operating Report

Plant: Palisades I

Year: 2023 I

Page 2 of 41 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 RES UL TS.................................................................... 13 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

.......................... 19 ATTACHMENTS - Sample Deviations........................................................................................................ 24 - Monitoring Results Tables............................................................................................ 25 - lnterlaboratory Comparison Program Results............................................................... 39

1.0 1.1 1.2

1.3 Plant

Palisades Year: 2023 I

Page 3 of 41 Annual Radiological Environmental Operating Report EXECUTIVE

SUMMARY

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, 2023. 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 2023. The 2023 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 a variety of environmental media as well as measuring direct radiation. 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 was modified in 2023, which is discussed in more detail in Section 1.4.

The REMP includes sampling indicator and control locations. The REMP utilizes indicator locations near the site to determine if any increases of radioactivity has occurred 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 2023, REMP samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. All 2023 REMP results support the conclusion that the surrounding environment is not adversely affected by Palisades' effluents. No activity in any REMP sample from 2023 was attributed to Palisades' effluents.

Reporting Levels No samples equaled or exceeded reporting levels.

Sample Deviations During 2023, environmental sampling was performed for six media types (airborne, surface water, drinking water, offsite groundwater, sediment, and fish) and analyzed for direct radiation. All REMP samples were obtained as required by the ODCM in 2023 apart from two instances of sample deviations which are further discussed in Table 8.

1.4 2.0 2.1

2.2 Plant

Palisades I

Year: 2023 I

Page 4 of 41 Annual Radiological Environmental Operating Report Program Modifications The REMP was modified via the ODCM change process and the changes went into effect on May 8th, 2023. The modification was based on the changing source term, which was an expected result of power cessation which occurred in May 2022, and aligns with industry best practice. The REMP related changes included removal of sample media from the program for which the basis is iodine monitoring. These samples include milk, food crop, and broadleaf vegetation. The requirement to identify the critical garden and residence were also removed from the land use census. A redundant sample point ( offsite drinking water) was removed from the program because the upstream city water supply is sampled. All sampling which was discontinued was seasonally required sampling which was discontinued before the season began, and therefore there are no milk, food crop, broadleaf vegetation, or the offsite Palisades Park drinking water sample for 2023.

All changes were made via the Offsite Dose Calculation Manual (ODCM) change process (Technical Specification 5.5.1 c.). As required by the ODCM change process, the revised ODCM is included in the 2023 Annual Radioactive Effluent Release Report (ARERR).

INTRODUCTION 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.

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 2023 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: 2023 I Page 5 of 41 Annual Radiological Environmental Operating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway -Airborne Requirement Sample Point Description Distance and Sampling and Type and Frequency Of Analyses Direction Collection Frequency RADIOIODINE AND PARTICULATES A8 (0.595 miles NE) - onsite near state park Continuous sampler 1-131 analysis weekly for each filter change.

Six samples total. Four samples from within 6 A 19 (0.423 miles SSE) - onsite near Bluestar operation with sample This analysis was discontinued after collection every week, or 5/8/2023.

km (3.7 miles) of the site boundary in different Hwy more frequently if required sectors. One sample from the vicinity of a A9 (1.525 miles SSW) - offsite near blue star by dust loading.

Gross beta radioactivity analysis weekly for community having the highest calculated each filter change.

annual average ground level deposition factor.

highway Gamma isotopic analysis quarterly for a One control sample in the least prevalent wind A4 (3.882 miles SE) - offsite in Covert composite of all filters collected.

direction (considering practical direction and township

,distance). Geographic location is depicted in IF filter gross beta is greater than 10 times Figure 2 and Figure 3.

A5 (3.590 miles ESE) - offsite in Covert the yearly mean of the control sample THEN township gamma isotopic is performed on the filter.

A10 (50.765 miles NE) - offsite near Grand Rapids

Plant: Palisades I

Year: 2023 I

Page 6 of 41 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Distance and Sampling and Type and Frequency Of Analyses Direction Collection Frequency TLDS TLD-1 (0.213 miles E) - onsite inner ring TLD Quarterly Gamma dose (units of milliRoentgen, abbreviated 21 routine monitoring stations either with two TLD-8 (0.602 miles NE)- inner ring TLD mR) quarterly or more dosimeters or with one instrument for measuring and recording dose rate TLD-13 (0.530 miles NNE) - inner ring TLD continuously, placed as follows:

TLD-14 (0.551 miles NE)- inner ring TLD One onsite TLD in the vicinity of the facility.

TLD-15 (0.834 miles ENE)- inner ring TLD An inner ring of stations consisting of one in each overland meteorological sector in the TLD-16 (0.804 miles E)- inner ring TLD general area of the site boundary and one TLD-17 (0.572 miles ESE) - inner ring TLD additional location near the State Park camping area in the NE sector.

TLD-18 (0.469 miles SE) - inner ring TLD An outer ring of stations one in each overland TLD-19 (0.443 miles SSE)- inner ring TLD meteorological sector within the 12 km range from the site.

TLD-20 (0.412 miles S)- inner ring TLD One control TLD between 25 and 55 miles TLD-21 (0.382 miles SSW) - inner ring TLD from the site. Geographic location is depicted in Figure 2 and Figure 3.

Plant: Palisades Year: 2023 I

Page 7 of 41 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sam pie Point Description Distance and Sampling and Type and Frequency Of Analyses Direction Collection Frequency TLD-2 (5.560 miles S) - outer ring TLD Quarterly Gamma dose (units of milliRoentgen, abbreviated TLD-3 (5.684 miles SSE) - outer ring TLD mR) quarterly TLD-4-21 (3.882 miles SE) - outer ring TLD TLD-5-21 (3.590 miles ESE) - outer ring TLD TLD-6 (5.314 miles NE) - outer ring TLD TLD-7 (4.115 miles NNE) - outer ring TLD TLD-9-21 (1.525 miles SSW) - outer ring TLD TLD-23 (3.189 miles ENE) - outer ring TLD TLD-24 (6.021 miles E) - outer ring TLD TLD-11-21 (28.72 miles E) - control TLD

Plant: Palisades I

Year: 2023 I

Page 8 of 41 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, gross beta (not ODCM required), and used in plant systems. Sample is make a monthly composite tritium analysis monthly Lake in (plant intake lake water) collected onsite.

sample.

DRINKING WATER City of South Haven drinking water Daily South Haven drinking Gamma isotopic, gross beta, and tritium analysis monthly intake structure (5.6 miles NNE of water samples are used to South Haven drinking water Palisades) make a monthly composite sample.

Domestic water (not ODCM required) is Domestic water is sampled onsite from sampled onsite.

any potable water source, typically an Daily samples are used to Gamma isotopic, gross beta, and tritium analysis monthly eye wash station.

make a monthly composite.

Surface Water and Drinking Water Control Daily samples are used to Gamma isotopic, gross beta, and tritium analysis monthly Lake water from Ludington Pump-house is Ludington Control - Lake Michigan make a monthly composite 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 Palisades Park (Pal Park) commercial water 0.7 miles S of Palisades monthly when in operation is sampled when in operation (summer (summer months) months). This sample is not ODCM required.

SEDIMENT FROM SHORELINE 1 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.

South sediment sample (not ODCM required) 1 sample from beach near south boundary of site property Semiannually Gamma isotopic analysis semiannually

Plant: Palisades Year: 2023 I

Page 9 of 41 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 FISH The indicator sample is obtained from Lake Semiannually Gamma isotopic analysis semiannually Sample 2 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 1 sample of the same species in areas not Michigan near Ludington Ml (201 km North influenced by plant discharge.

of Palisades).

Plant: Palisades Year: 2023

/

Page 10 of 41 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway 0 :,

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LTRA SPORT Exposure pathways to man

Plant: Palisades I

Year: 2023 Page 11 of 41 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field I

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Plant: Palisades I

Year: 2023 Page 12 of 41 Annual Radiological Environmental Operating Report Figure 3, Sample Collection Sites - Far Field N

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5 MILE SW SE I s The locations in Figure 3 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

Plant: Palisades Year: 2023 Page 13 of 41 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample There were 312 air samples collected and analyzed for gross beta and 114 air samples collected and analyzed for I-131 during 2023. Air particulate samples are collected weekly from six air-sampling locations five of which are indicator locations and one of which is a control location. Air iodine samples were collected at the same stations up until the REMP modification which went into effect on 5/8/2023. During the weekly collection, an "as found" and "as left" leak test is performed at each station. 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, validates that the surrounding environment is not adversely affected by Palisades' effluents. The average concentration of gross beta activity among all indicator locations was 2.61E-02 pCi/m3 and was 2.41E-02 pCi/m3 for the control location. All I-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 and K-40) 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/m3 with a similar trend between stations onsite, in the surrounding community, and control stations. The activity results from 2023 indicate there is no measurable change between pre-operational airborne gross beta activity and present day airborne gross beta activity.

There were two REMP deviations in 2023 involving air sampling. Both deviations involved a tripped GFCI outlet. Sufficient volume was obtained from all REMP air samples to perform analysis and all results were incorporated in the statistics in this report. 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 2023. This conclusion is that the surrounding environment is not adversely affected by Palisades' effluents. No REMP air samples from 2023 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades Year: 2023 Page 14 of 41 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results Palisades reports measured dose as net exposure (subtracting transit reading) normalized to 91 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 is 1 control location. 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 2023, none of the TLD values were greater than the baseline. One TLD reading was less than the baseline, which is attributed to statistical variance. There was no REMP deviations in 2023 involving TLDs.

During 2021, four additional locations were added (identified as 4-21, 5-21, 9-21, and 11-21) to establish a new baseline at these locations. Starting in the first quarter of 2022, locations 4, 5, 9, 10, 11, and 12 were discontinued and locations 4-21, 5-21, 9-21, and 11-21 were implemented into the program. Essentially this resulted in a relocation of three of the outer ring TLDs, a relocation of one of the control TLDs, and a discontinuation of two control TLDs. All changes made were in accordance with the ODCM and the ODCM change process (technical specification 5.5.1 c.).

Table 5 shows the consistent trend of average inner ring, outer ring, and control TLD average measurements.

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.

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

Outer Ring (mR/Qtr)

Control Location (mR/Qtr) 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 Year: 2023 Page 15 of 41 Annual Radiological Environmental Operating Report Table 5, Direct Radiation Annual Summary Year Inner Ring (mR/Qtr)

Outer Ring (mR/Qtr)

Control Location (mR/Qtr) 2021 9.3 11.3 11.1 2022 9.7 11.4 12.0 2023 9.5 11.2 11.8 4.3 Waterborne Sample Results During 2023 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, tritium, and gross beta activity. In 2023 the only radionuclide activity detected in Ludington Control water was naturally occurring isotopes (Ra-226 and Th-228). Of the twelve Ludington Control samples collected in 2023, two contained detectable gross beta with an average value of 3.29 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 (Th-228) were naturally occurring and are not attributed to Palisades effluents. Three out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 4.56 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 2023. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP surface water samples from 2023 contained measurable radiological materials attributed to Palisades effluents.

Plant: Palisades Year: 2023 Page 16 of 41 Annual Radiological Environmental Operating Report 4.3.2 Drinking Water The indicator drinking water samples collected and analyzed for the REMP include "Domestic Water" and "South Haven Drinking Water. All samples are analyzed for gamma, tritium, and gross beta by Teledyne Brown Engineering Environmental Services.

Domestic Water is collected onsite from a potable water system. 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) 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 3.23 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, MI. All radionuclide detected (K-40 and Th-228) were naturally occurring and are not attributed to Palisades effluents. Three out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2.94 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 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 2023. This conclusion is that the surrounding environment is not affected by Palisades effluents. No REMP drinking water samples from 2023 contained measurable radiological materials attributed to Palisades effluents.

4.3.3 Groundwater Palisades implements an extensive groundwater monitoring program in accordance with NEI-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 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 collected offsite from a neighboring community and is identified as, "Palisades Park Commercial Well Water". 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. In 2023, no radionuclides were detected in this sample, including tritium. Four out of the six monthly samples contained measurable gross beta with the average detectable gross beta activity at 4.54 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Plant: Palisades Year: 2023 Page 17 of 41 Annual Radiological Environmental Operating Report 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 2023. This conclusion is that the surrounding environment is not adversely affected by Palisades' effluents. No REMP groundwater samples from 2023 contained measurable radiological materials attributed to Palisades effluents.

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 2023, the only radionuclides detected (K-40, Th-228) were naturally occurring 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 2023. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP sediment samples from 2023 contained measurable radiological materials attributed to Palisades effluents.

4.5 Ingestion Sample Results 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, MI. In 2023, the only radionuclides detected among all fish samples were naturally occurring radionuclides (K-40) which were not attributed to Palisades effluents.

Plant: Palisades Year: 2023 Page 18 of 41 Annual Radiological Environmental Operating Report 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 2023. This conclusion is that the surrounding environment is not adversely affected by Palisades effluents. No REMP fish water samples from 2023 contained measurable radiological materials attributed to Palisades effluents.

4.6 Land Use Census Results The latest land use census (performed in 2023) did not identify any new locations that prompt a change to the REMP. Similarly, there was no impact to the Radiological Effluents Control Program. The method used to perform the census was a visual survey. The sectors in Table 6 include all overland compass sectors.

In accordance with the REMP, the census was restricted to 2.5 miles after it was confirmed that the existing cow and goat in the ESE sector would be the critical receptor (for dose modeling purposes) even if a cow or goat were identified greater than 2.5 miles from Palisades in the other sectors.

Table 6, Land Use Census Sector Direction Cow (miles)

Goat (miles) 2 NNE

> 2.5

> 2.5 3

NE

> 2.5

> 2.5 4

ENE 2.29

> 2.5 5

E 3.51 3.46 6

ESE 2.04 2.04 7

SE 3.88 3.88 8

SSE

> 2.5

> 2.5 9

S

> 2.5

> 2.5 10 SSW

> 2.5

Plant: Palisades Year: 2023 Page 19 of 41 Annual Radiological Environmental Operating Report 4.7 Interlaboratory Comparison Results contains a summary of the results for the Interlaboratory Comparison program for Teledyne Brown Engineering Environmental Services.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1.

Table 7, Radiological Environmental Monitoring Program Summary, summarizes data for the 2023 REMP program.

Plant: Palisades Year: 2023 Page 20 of 41 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses LLD [Note 1]

Indicator Locations Mean (F)[Note 2]

[Range]

Location [Note 3]

[Highest Annual Mean]

Mean (F)[Note 2]

[Range]

Control Locations Mean (F)[Note 2] [Range]

Number of Reportable Occurrences

[Note 4]

Air (pCi/m3)

GB / 312 0.01 2.61E-02 (260/260)

[1.25E 4.50E-02]

Station A4 (3.882 miles SE) 2.94E-02 (52/52)

[1.49E 4.50E-02]

2.41E-02 (52/52)

[1.31E 3.59E-02]

0 I-131 / 114 0.07

<MDA (0/95)

N/A N/A

<MDA (0/19) 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 TLDs (mR/Qtr)

Gamma / 48 Sensitivity of 3 mR 9.45 (44/44)

[7.70 - 11.40]

Station 1 (onsite 0.213 miles E) 10.77 (4/4)

[10.11 - 11.40]

11.78 (4/4)

[10.95 - 12.48]

0 Outter Ring TLDs (mR/Qtr)

Gamma / 40 Sensitivity of 3 mR 11.18 (36/36)

[8.87 - 14.87]

Station 2 (5.560 miles S) 14.16 (4/4)

[13.56 - 14.87]

11.78 (4/4)

[10.95 - 12.48]

0

Plant: Palisades Year: 2023 Page 21 of 41 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses LLD [Note 1]

Indicator Locations Mean (F)[Note 2]

[Range]

Location [Note 3]

[Highest Annual Mean]

Mean (F)[Note 2]

[Range]

Control Locations Mean (F)[Note 2] [Range]

Number of Reportable Occurrences

[Note 4]

Surface Water (pCi/L)

Gross Beta / 24 H-3 / 24 Mn-54 / 24 Fe-59 / 24 Co-58 / 24 Co-60 / 24 Zn-65 / 24 Zr-95 / 24 Nb-95 / 24 Cs-134 / 24 Cs-137 / 24 Ba-140 / 24 La-140 / 24 4.0 2000 15 30 15 15 30 30 15 15 18 60 15 4.56 (3 / 12)

[2.52 -8.08]

<MDA (0 / 12)

Lake In (Plant lake intake)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 4.56 (3 / 12)

[2.52 -8.08]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3.29 (2 / 12)

[2.68 - 3.90]

<MDA (0 / 12)

<MDA (0 / 12) 0 0

0 0

0

Plant: Palisades Year: 2023 Page 22 of 41 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses LLD [Note 1]

Indicator Locations Mean (F)[Note 2]

[Range]

Location [Note 3]

[Highest Annual Mean]

Mean (F)[Note 2]

[Range]

Control Locations Mean (F)[Note 2] [Range]

Number of Reportable Occurrences

[Note 4]

Drinking Water (pCi/L)

Gross Beta / 36 H-3 / 36 Mn-54 / 36 Fe-59 / 36 Co-58 / 36 Co-60 / 36 Zn-65 / 36 Zr-95 / 36 Nb-95 / 36 Cs-134 / 36 Cs-137 / 36 Ba-140 / 36 La-140 / 36 4

2000 15 30 15 15 30 30 15 15 18 60 15 3.10 (7 / 24)

[2.49 - 3.95]

<MDA (0 / 30)

Domestic Water (On-site)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3.23 (4 / 12)

[2.66 - 3.95]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3.29 (2 / 12)

[2.68 - 3.90]

<MDA (0 / 12)

<MDA (0 / 12) 0 0

0 0

0 Fish (pCi/kg)

Mn-54 / 8 Fe-59 / 8 Co-58 / 8 Co-60 / 8 Zn-65 / 8 Cs-134 / 8 Cs-137 / 8 130 260 130 130 260 130 150

<MDA (0 / 5)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

<MDA (0 / 3)

<MDA (0 / 3) 0 0

0 0

0

Plant: Palisades Year: 2023 Page 23 of 41 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses LLD [Note 1]

Indicator Locations Mean (F)[Note 2]

[Range]

Location [Note 3]

[Highest Annual Mean]

Mean (F)[Note 2]

[Range]

Control Locations Mean (F)[Note 2] [Range]

Number of Reportable Occurrences

[Note 4]

Sediment (pCi/kg)

Cs-134 / 4 Cs-137 / 4 150 180

<MDA (0 / 4)

N/A N/A N/A N/A Control sample not required 0

0 Offsite Groundwater (Pal Park Commercial Well) (pCi/L)

Gross Beta / 18 H-3 / 18 Mn-54 / 18 Fe-59 / 18 Co-58 / 18 Co-60 / 18 Zn-65 / 18 Zr-95 / 18 Nb-95 / 18 Cs-134 / 18 Cs-137 / 18 Ba-140 / 18 La-140 / 18 4

2000 15 30 15 15 30 30 15 15 18 60 15 4.54 (4 / 6)

[2.17 - 5.79]

<MDA (0 / 6)

Palisades Park Commercial Well (0.7 miles S)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 4.54 (4 / 6)

[2.17 - 5.79]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 3.29 (2 / 12)

[2.68 - 3.90]

<MDA (0 / 12)

<MDA (0 / 12) 0 0

0 0

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: 2023 Page 24 of 41 Annual Radiological Environmental Operating Report Page 1 of 1 Sample Deviations Table 8, Sample Deviations Table Comment No.

Sample Media Affected Sample Location Date Problem Evaluation / Actions 1

Air Sample A4 04/10/23 GFCI trip During normal weekly sample collection (on 04/10/23) the pump at air sample station A4 was found tripped off. The GFCI outlet was reset, and the pump resumed sampling as normal. The volume of air sampled indicates that the pump was running for about 25% of the previous week. The sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report. The cause for the deviation is believed to be from an area power outage.

2 Air Sample A4 05/22/23 GFCI trip During normal weekly sample collection (on 05/22/23) the pump at air sample station A4 was found tripped off. The GFCI outlet was reset, and the pump resumed sampling as normal. The volume of air sampled indicates that the pump was running for about 50% of the previous week. The sample volume was sufficient to analyze the filter media and incorporate the results into the statistics in this report. Since this was the second occurrence at this location within a short time period, the outlet was validated to be working correctly. The cause for the deviation is believed to be from an area power outage.

Plant: Palisades Year: 2023 Page 25 of 41 Annual Radiological Environmental Operating Report Page 1 of 14 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Start Date End Date Station A4[Note 1]

(Indicator)

Station A5 (Indicator)

Station A8 (Indicator)

Station A9 (Indicator)

Station A19 (Indicator)

Station A10[Note 2]

(Control)

REQUIRED LLD 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 01/03/23 01/09/23 3.89E-02 2.52E-02 2.68E-02 2.46E-02 2.45E-02 2.39E-02 01/09/23 01/16/23 4.43E-02 3.17E-02 3.28E-02 3.12E-02 3.10E-02 2.80E-02 01/16/23 01/23/23 2.40E-02 1.93E-02 2.90E-02 1.75E-02 2.16E-02 1.93E-02 01/23/23 01/30/23 4.50E-02 3.34E-02 3.16E-02 3.18E-02 3.12E-02 3.05E-02 01/30/23 02/06/23 3.99E-02 3.14E-02 3.23E-02 3.65E-02 2.96E-02 2.63E-02 02/06/23 02/13/23 3.25E-02 2.88E-02 2.71E-02 2.50E-02 2.31E-02 2.55E-02 02/13/23 02/21/23 3.83E-02 2.81E-02 3.06E-02 2.90E-02 2.62E-02 2.80E-02 02/21/23 02/28/23 2.77E-02 2.29E-02 1.85E-02 2.14E-02 1.95E-02 1.69E-02 02/28/23 03/07/23 3.40E-02 2.48E-02 2.00E-02 2.67E-02 2.31E-02 2.60E-02 03/07/23 03/14/23 3.08E-02 2.57E-02 2.44E-02 2.09E-02 2.29E-02 2.16E-02 03/14/23 03/20/23 4.36E-02 3.20E-02 3.08E-02 2.88E-02 3.10E-02 2.31E-02 03/20/23 03/27/23 3.35E-02 3.37E-02 3.13E-02 3.57E-02 2.83E-02 2.50E-02 03/27/23 04/03/23 4.07E-02 3.10E-02 3.20E-02 3.63E-02 3.25E-02 2.78E-02 04/03/23 04/10/23 4.01E-02[Note 3]

2.71E-02 2.34E-02 2.35E-02 2.62E-02 2.40E-02 04/10/23 04/18/23 2.65E-02 2.24E-02 2.41E-02 2.28E-02 1.98E-02 2.44E-02 04/18/23 04/24/23 2.61E-02 2.08E-02 1.78E-02 1.93E-02 1.80E-02 1.45E-02 04/24/23 05/02/23 1.49E-02 1.54E-02 1.63E-02 1.64E-02 1.25E-02 1.45E-02 05/02/23 05/08/23 2.03E-02 2.28E-02 1.73E-02 1.71E-02 1.57E-02 1.58E-02 05/08/23 05/15/23 2.25E-02 2.22E-02 2.29E-02 2.58E-02 1.97E-02 1.98E-02 05/15/23 05/22/23 2.52E-02[Note 3]

1.75E-02 1.63E-02 1.92E-02 1.72E-02 1.70E-02 05/22/23 05/30/23 2.63E-02 2.20E-02 2.82E-02 2.56E-02 2.01E-02 1.99E-02 05/30/23 06/05/23 3.20E-02 2.71E-02 2.75E-02 3.01E-02 2.56E-02 2.93E-02 06/05/23 06/12/23 2.44E-02 2.12E-02 2.32E-02 2.24E-02 1.89E-02 2.22E-02 06/12/23 06/19/23 1.81E-02 1.58E-02 1.65E-02 1.68E-02 1.54E-02 1.83E-02 06/19/23 06/26/23 2.30E-02 2.05E-02 2.08E-02 2.27E-02 2.34E-02 1.69E-02 06/26/23 07/03/23 2.45E-02 2.93E-02 2.62E-02 2.38E-02 2.33E-02 2.49E-02

Plant: Palisades Year: 2023 Page 26 of 41 Annual Radiological Environmental Operating Report Page 2 of 14 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Start Date End Date Station A4[Note 1]

(Indicator)

Station A5 (Indicator)

Station A8 (Indicator)

Station A9 (Indicator)

Station A19 (Indicator)

Station A10[Note 2]

(Control) 07/10/23 07/17/23 2.14E-02 2.38E-02 1.79E-02 1.71E-02 2.11E-02 2.78E-02 07/03/23 07/10/23 2.50E-02 2.24E-02 2.62E-02 1.96E-02 1.98E-02 2.54E-02 07/17/23 07/24/23 2.33E-02 2.06E-02 1.90E-02 2.13E-02 1.94E-02 1.94E-02 07/24/23 08/01/23 2.37E-02 2.40E-02 2.27E-02 2.09E-02 2.05E-02 2.60E-02 08/01/23 08/07/23 3.05E-02 2.59E-02 2.96E-02 2.47E-02 2.73E-02 2.66E-02 08/07/23 08/14/23 2.95E-02 3.21E-02 2.75E-02 3.07E-02 2.71E-02 2.48E-02 08/14/23 08/21/23 2.13E-02 3.02E-02 2.33E-02 2.25E-02 2.10E-02 2.17E-02 08/21/23 08/29/23 3.38E-02 2.41E-02 3.46E-02 2.70E-02 3.10E-02 2.44E-02 09/05/23 09/11/23 2.46E-02 2.31E-02 1.98E-02 1.86E-02 1.68E-02 2.07E-02 09/11/23 09/18/23 2.06E-02 1.99E-02 2.60E-02 2.44E-02 2.09E-02 3.59E-02 08/29/23 09/05/23 2.67E-02 2.88E-02 2.58E-02 2.98E-02 2.46E-02 2.51E-02 09/18/23 09/25/23 4.02E-02 4.09E-02 3.24E-02 3.00E-02 3.54E-02 3.55E-02 09/25/23 10/02/23 2.54E-02 2.66E-02 2.82E-02 3.01E-02 2.39E-02 2.50E-02 10/02/23 10/10/23 3.25E-02 2.25E-02 2.70E-02 2.46E-02 2.77E-02 3.26E-02 10/10/23 10/16/23 2.34E-02 1.89E-02 1.90E-02 1.84E-02 2.11E-02 1.73E-02 10/16/23 10/23/23 2.64E-02 2.21E-02 2.52E-02 2.20E-02 2.17E-02 2.61E-02 10/23/23 10/30/23 3.15E-02 2.96E-02 3.02E-02 2.66E-02 3.07E-02 3.34E-02 11/06/23 11/13/23 2.54E-02 2.14E-02 2.78E-02 1.78E-02 2.28E-02 2.87E-02 10/30/23 11/06/23 4.01E-02 4.08E-02 4.38E-02 4.06E-02 4.04E-02 1.94E-02 11/13/23 11/20/23 3.03E-02 3.37E-02 3.06E-02 2.91E-02 2.40E-02 2.41E-02 11/20/23 11/27/23 2.69E-02 2.44E-02 2.49E-02 2.68E-02 2.61E-02 2.32E-02 11/27/23 12/04/23 2.97E-02 3.06E-02 2.73E-02 2.87E-02 2.62E-02 2.06E-02 12/04/23 12/11/23 2.95E-02 3.64E-02 2.59E-02 2.62E-02 2.39E-02 2.99E-02 12/11/23 12/18/23 3.47E-02 3.63E-02 2.72E-02 2.74E-02 3.12E-02 3.09E-02 12/18/23 12/26/23 3.36E-02 3.79E-02 2.89E-02 2.82E-02 2.98E-02 3.21E-02 12/26/23 01/02/24 2.10E-02 2.14E-02 1.81E-02 2.19E-02 1.62E-02 1.31E-02

[Note 1] - Station with highest annual mean.

Plant: Palisades Year: 2023 Page 27 of 41 Annual Radiological Environmental Operating Report Page 3 of 14 Monitoring Results Tables

[Note 2] - The sample date range is accurate to plus or minus 2 days for station A10

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table Table 10, Air Radioiodine Data Table Summary Analysis: I-131 Units: pCi/m3 Start Date End Date Station A4 (Indicator)

Station A5 (Indicator)

Station A8 (Indicator)

Station A9 (Indicator)

Station A19 (Indicator)

Station A10[Note 1]

(Control)

REQUIRED LLD 7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 01/03/23 01/09/23

<MDA

<MDA 01/09/23 01/16/23

<MDA

<MDA 01/16/23 01/23/23

<MDA

<MDA 01/23/23 01/30/23

<MDA

<MDA 01/30/23 02/06/23

<MDA

<MDA 02/06/23 02/13/23

<MDA

<MDA 02/13/23 02/21/23

<MDA

<MDA 02/21/23 02/28/23

<MDA

<MDA 02/28/23 03/07/23

<MDA

<MDA 03/07/23 03/14/23

<MDA

<MDA 03/14/23 03/20/23

<MDA

<MDA 03/20/23 03/27/23

<MDA

<MDA 03/27/23 04/03/23

<MDA

<MDA 04/03/23 04/10/23

<MDA[Note 2]

<MDA

<MDA 04/10/23 04/18/23

<MDA

<MDA 04/18/23 04/24/23

<MDA

<MDA 04/24/23 05/02/23

<MDA

<MDA 05/02/23 05/08/23

<MDA

<MDA 05/08/23 05/15/23

<MDA[Note 3]

[Note 4]

[Note 1] - The sample date range is accurate to plus or minus 2 days for station A10

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

[Note 3] - Sample was collected and analyzed even though not required by ODCM

[Note 4] - No sample was collected. Sample not required per the ODCM

Plant: Palisades Year: 2023 Page 28 of 41 Annual Radiological Environmental Operating Report Page 4 of 14 Monitoring Results Tables Table 11, Air Sample Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/m3 Location Start Date End Date Cs-134 Cs-137 Be-7[Note 1]

K-40[Note 1]

REQUIRED LLD 0.05 0.06 NA NA Station A4 01/03/23 04/03/23

<MDA

<MDA 8.68E-02

<MDA Station A4 04/03/23 07/03/23

<MDA

<MDA 1.52E-01

<MDA Station A4 07/03/23 10/02/23

<MDA

<MDA 1.11E-01

<MDA Station A4 10/02/23 01/02/24

<MDA

<MDA 8.44E-02

<MDA Station A5 01/03/23 04/03/23

<MDA

<MDA 1.12E-01

<MDA Station A5 04/03/23 07/03/23

<MDA

<MDA 1.34E-01

<MDA Station A5 07/03/23 10/02/23

<MDA

<MDA 1.12E-01

<MDA Station A5 10/02/23 01/02/24

<MDA

<MDA 9.90E-02

<MDA Station A8 01/03/23 04/03/23

<MDA

<MDA 1.30E-01

<MDA Station A8 04/03/23 07/03/23

<MDA

<MDA 1.63E-01

<MDA Station A8 07/03/23 10/02/23

<MDA

<MDA 1.15E-01

<MDA Station A8 10/02/23 01/02/24

<MDA

<MDA 1.08E-01

<MDA Station A9 01/03/23 04/03/23

<MDA

<MDA 1.08E-01

<MDA Station A9 04/03/23 07/03/23

<MDA

<MDA 1.62E-01

<MDA Station A9 07/03/23 10/02/23

<MDA

<MDA 1.15E-01

<MDA Station A9 10/02/23 01/02/24

<MDA

<MDA 8.09E-02 2.47E-02 Station A19 01/03/23 04/03/23

<MDA

<MDA 8.48E-02

<MDA Station A19 04/03/23 07/03/23

<MDA

<MDA 1.07E-01

<MDA Station A19 07/03/23 10/02/23

<MDA

<MDA 1.09E-01

<MDA Station A19 10/02/23 01/02/24

<MDA

<MDA 7.44E-02

<MDA Station A10 01/03/23 04/03/23

<MDA

<MDA 1.11E-01

<MDA Station A10 04/03/23 06/27/23

<MDA

<MDA 1.59E-01

<MDA Station A10 06/27/23 10/02/23

<MDA

<MDA 1.26E-01

<MDA Station A10 10/02/23 01/02/24

<MDA

<MDA 7.37E-02

<MDA

[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 Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 1[Note 1]

10.33 11.40 10.11 11.23 10.77 8

10.03 10.61 9.18 10.57 10.10 13 9.25 9.57 9.03 9.97 9.46 14 8.48 9.00 7.70 8.68 8.47

Plant: Palisades Year: 2023 Page 29 of 41 Annual Radiological Environmental Operating Report Page 5 of 14 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 15 8.57 9.46 8.55 9.43 9.00 16 8.85 9.68 8.45 9.68 9.17 17 8.66 9.05 8.46 9.21 8.85 18 9.73 10.27 9.29 10.06 9.84 19 9.21 9.69 8.93 9.74 9.39 20 9.21 9.68 8.94 9.81 9.41 21 9.13 9.96 9.05 9.83 9.49

[Note 1] - Station with highest annual mean.

Table 13, Thermoluminescent Dosimeters - Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 2[Note 1]

13.56 14.87 13.86 14.36 14.16 3

10.44 11.64 10.85 11.77 11.18 4-21 9.93 10.90 9.90 10.63 10.34 5-21 11.19 12.81 10.94 12.56 11.88 6

10.12 11.12 10.13 11.04 10.60 7

9.56 10.13 8.87 10.14 9.68 9-21 9.46 10.20 10.95 9.86 10.12 23 10.93 11.80 10.55 11.42 11.18 24 11.22 12.27 10.95 11.65 11.52

[Note 1] - Station with highest annual mean.

Plant: Palisades Year: 2023 Page 30 of 41 Annual Radiological Environmental Operating Report Page 6 of 14 Monitoring Results Tables Table 14, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mR Station 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Mean 11-21 11.52 12.48 10.95 12.17 11.78 Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Zr-95 Nb-95 Cs-134 Cs-137 Ba-140 La-140 Ra-226 Th-228 REQUIRED LLD 15 15 30 15 30 30 15 15 18 60 15

[Note 1]

Lake In 01/01/23 02/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 02/01/23 03/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 03/01/23 04/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 3.31 Lake In 04/01/23 05/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 05/01/23 06/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 06/01/23 07/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 4.93 Lake In 07/01/23 08/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 08/01/23 09/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 09/01/23 10/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 10/01/23 11/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 11/01/23 12/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Lake In 12/01/23 01/01/24 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 01/01/23 02/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 69.1

<MDA Ludington Control 02/01/23 03/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 9.71 Ludington Control 03/01/23 04/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA

Plant: Palisades Year: 2023 Page 31 of 41 Annual Radiological Environmental Operating Report Page 7 of 14 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Zr-95 Nb-95 Cs-134 Cs-137 Ba-140 La-140 Ra-226 Th-228 Ludington Control 04/01/23 05/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA 49.4

<MDA Ludington Control 05/01/23 06/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 06/01/23 07/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 07/01/23 08/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 08/01/23 09/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 09/01/23 10/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 10/01/23 11/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 11/01/23 12/01/23 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA Ludington Control 12/01/23 01/01/24 <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA <MDA

<MDA

[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 01/01/23 02/01/23

<MDA

<MDA Lake In 02/01/23 03/01/23

<MDA

<MDA Lake In 03/01/23 04/01/23

<MDA

<MDA Lake In 04/01/23 05/01/23

<MDA

Plant: Palisades Year: 2023 Page 32 of 41 Annual Radiological Environmental Operating Report Page 8 of 14 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 05/01/23 06/01/23

<MDA

<MDA Lake In 06/01/23 07/01/23

<MDA

<MDA Lake In 07/01/23 08/01/23

<MDA

<MDA Lake In 08/01/23 09/01/23

<MDA 8.08 Lake In 09/01/23 10/01/23

<MDA

<MDA Lake In 10/01/23 11/01/23

<MDA 3.07 Lake In 11/01/23 12/01/23

<MDA

<MDA Lake In 12/01/23 01/01/24

<MDA 2.52 Ludington Control 01/01/23 02/01/23

<MDA

<MDA Ludington Control 02/01/23 03/01/23

<MDA

<MDA Ludington Control 03/01/23 04/01/23

<MDA

<MDA Ludington Control 04/01/23 05/01/23

<MDA

<MDA Ludington Control 05/01/23 06/01/23

<MDA

<MDA Ludington Control 06/01/23 07/01/23

<MDA

<MDA Ludington Control 07/01/23 08/01/23

<MDA 3.90 Ludington Control 08/01/23 09/01/23

<MDA

<MDA Ludington Control 09/01/23 10/01/23

<MDA

<MDA Ludington Control 10/01/23 11/01/23

<MDA 2.68 Ludington Control 11/01/23 12/01/23

<MDA

<MDA Ludington Control 12/01/23 01/01/24

<MDA

Plant: Palisades Year: 2023 Page 33 of 41 Annual Radiological Environmental Operating Report Page 9 of 14 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic 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 Ba-140 La-140 K-40 Th-228 REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15

[Note 1]

Domestic Water 01/01/23 02/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 20.5

<MDA Domestic Water 02/01/23 03/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 03/01/23 04/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 04/01/23 05/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 05/01/23 06/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 06/01/23 07/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 07/01/23 08/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 27.9

<MDA Domestic Water 08/01/23 09/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 09/01/23 10/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 10/01/23 11/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 36.7

<MDA Domestic Water 11/01/23 12/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA Domestic Water 12/01/23 01/01/24 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 01/01/23 02/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 02/01/23 03/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 03/01/23 04/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

Plant: Palisades Year: 2023 Page 34 of 41 Annual Radiological Environmental Operating Report Page 10 of 14 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic 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 Ba-140 La-140 K-40 Th-228 REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15

[Note 1]

South Haven 04/01/23 05/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 05/01/23 06/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 06/01/23 07/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 07/01/23 08/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 46.8

<MDA South Haven 08/01/23 09/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 24.9 5.57 South Haven 09/01/23 10/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 10/01/23 11/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA 25.9

<MDA South Haven 11/01/23 12/01/23 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

<MDA South Haven 12/01/23 01/01/24 <MDA

<MDA

<MDA <MDA <MDA <MDA <MDA

<MDA

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

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 01/01/23 02/01/23

<MDA

<MDA Domestic Water 02/01/23 03/01/23

<MDA

<MDA Domestic Water 03/01/23 04/01/23

<MDA

Plant: Palisades Year: 2023 Page 35 of 41 Annual Radiological Environmental Operating Report Page 11 of 14 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 Domestic Water 04/01/23 05/01/23

<MDA 3.55 Domestic Water 05/01/23 06/01/23

<MDA

<MDA Domestic Water 06/01/23 07/01/23

<MDA

<MDA Domestic Water 07/01/23 08/01/23

<MDA 2.66 Domestic Water 08/01/23 09/01/23

<MDA

<MDA Domestic Water 09/01/23 10/01/23

<MDA

<MDA Domestic Water 10/01/23 11/01/23

<MDA 3.95 Domestic Water 11/01/23 12/01/23

<MDA 2.75 Domestic Water 12/01/23 01/01/24

<MDA

<MDA South Haven 01/01/23 02/01/23

<MDA

<MDA South Haven 02/01/23 03/01/23

<MDA

<MDA South Haven 03/01/23 04/01/23

<MDA

<MDA South Haven 04/01/23 05/01/23

<MDA 3.06 South Haven 05/01/23 06/01/23

<MDA

<MDA South Haven 06/01/23 07/01/23

<MDA

<MDA South Haven 07/01/23 08/01/23

<MDA 2.49 South Haven 08/01/23 09/01/23

<MDA

<MDA South Haven 09/01/23 10/01/23

<MDA

<MDA South Haven 10/01/23 11/01/23

<MDA 3.27 South Haven 11/01/23 12/01/23

<MDA

<MDA South Haven 12/01/23 01/01/24

<MDA

Plant: Palisades Year: 2023 Page 36 of 41 Annual Radiological Environmental Operating Report Page 12 of 14 Monitoring Results Tables Table 19, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 K-40 Th-228 REQUIRED LLD 150 180

[Note 1]

North Sediment 04/07/23

<MDA

<MDA 3309 167.6 North Sediment 10/03/23

<MDA

<MDA 6347

<MDA South Sediment 04/07/23

<MDA

<MDA 4078 112.4 South Sediment 10/03/23

<MDA

<MDA 4488

<MDA

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

Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location /

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

[Note 1]

Ludington /

River Redhorse 05/21/23

<MDA

<MDA 2604 Ludington /

Lake Trout 05/26/23

<MDA

<MDA 2419 Ludington /

Drum 09/09/23

<MDA

<MDA 2658 Palisades /

River Redhorse 05/16/23

<MDA

<MDA 3464 Palisades /

Lake Trout 05/23/23

<MDA

<MDA 2749 Palisades /

Drum 08/24/23

<MDA

<MDA 4089 Palisades /

Gizzard Shad 08/24/23

<MDA

<MDA 2689 Palisades /

Catfish 08/24/23

<MDA

<MDA 3373

Plant: Palisades Year: 2023 Page 37 of 41 Annual Radiological Environmental Operating Report Page 13 of 14 Monitoring Results Tables

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

Table 21, Offsite Groundwater - Gamma isotopic Analysis: Gamma Isotopic Units: pCi/L Location Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD 15 15 30 15 30 15 30 15 18 60 15 Pal Park Commercial Well 05/22/22

<MDA

<MDA Pal Park Commercial Well 06/13/22

<MDA

<MDA Pal Park Commercial Well 07/12/22

<MDA

<MDA Pal Park Commercial Well 08/15/22

<MDA

<MDA Pal Park Commercial Well 09/13/22

<MDA

<MDA Pal Park Commercial Well 10/03/22

<MDA

Plant: Palisades Year: 2023 Page 38 of 41 Annual Radiological Environmental Operating Report Page 14 of 14 Monitoring Results Tables Table 22, 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 Palisades Park Commercial Well 05/17/23

<MDA 5.79 Palisades Park Commercial Well 06/12/23

<MDA 2.17 Palisades Park Commercial Well 07/10/23

<MDA

<MDA Palisades Park Commercial Well 08/01/23

<MDA 5.63 Palisades Park Commercial Well 09/05/23

<MDA

<MDA Palisades Park Commercial Well 10/02/23

<MDA 4.56

Plant: Palisades Year: 2023 Page 39 of 41 Annual Radiological Environmental Operating Report Page 1 of 3 Interlaboratory Comparison Program Results 1.0 Summary Summary of Results - Interlaboratory Comparison Program (ICP)

The TBE Laboratory analyzed Performance Evaluation (PE) samples of air particulate (AP), air iodine, milk, soil, vegetation, and water matrices that represent test & matrix combinations available for REMP programs. 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 TBEs result and Analytics known value. Since flag values are not assigned by Analytics, TBE evaluates the reported ratios based on internal QC requirements based on the DOE MAPEP criteria.

B.

ERA Evaluation Criteria ERAs evaluation report provides an acceptance range for control and warning limits with associated flag values. ERAs acceptance limits are established per the US EPA, National Environmental Laboratory Accreditation Conference (NELAC), state-specific Performance Testing (PT) program requirements or ERAs 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 MAPEPs evaluation report provides an acceptance range with associated flag values. MAPEP defines three levels of performance:

x Acceptable (flag = A) - result within +/- 20% of the reference value x

Acceptable with Warning (flag = W) - result falls in the +/- 20% to +/- 30% of the reference value x

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 always resemble typical environmental samples obtained at commercial nuclear power facilities.

For the TBE laboratory, 124 out of 131 analyses performed met the specified acceptance criteria. Seven analyses did not meet the specified acceptance criteria and were addressed through the TBE Corrective Action Program. A summary is found below:

1.

The MAPEP February 2023 Soil Ni-63 result was evaluated as Not Acceptable. TBEs reported value was 294 Bq/kg and the known result was 1130 Bq/kg (range 791 - 1469).

The sample was reprepped by a different (senior) lab technician with results of 1120 &

1250 Bq. It was determined that there was a difference between the two techs during the sample prep (technique) and the procedure was revised to reflect these differences

Plant: Palisades Year: 2023 Page 40 of 41 Annual Radiological Environmental Operating Report Page 2 of 3 Interlaboratory Comparison Program Results including using a specific aliquot amount. (NCR 23-08) 2.

The MAPEP February 2023 vegetation Sr-90 result was evaluated as Not Acceptable.

The reported value was 0.05 Bq (not detected) and the known result was a false positive.

This was considered to be a statistical failure because TBEs reported result with 3 times the uncertainty resulted in a slightly positive net result (0.03194 Bq/kg). The reported result was significantly below TBEs average detection limit for vegetation samples.

(NCR 23-09) 3.

The ERA RAD February 2023 water Ba-133 result was evaluated as Not Acceptable. The reported value was 26.0 pCi/L and the known was 22.3 (acceptance range 17.1 - 25.8 pCi) or 117% of the known (acceptable for TBE QC). The sample was used as the workgroup duplicate with a result of 25.4 (114%). The sample had also been counted on a different detector with a result of 21.9 (98%). The was TBEs first failure for Ba-133.

(NCR 23-10) 4.

The MAPEP August 2023 soil Fe-55 result was evaluated as Not Acceptable. The reported value was 346 Bq/kg and the known result was 1280 (acceptance range of 896-1664 Bq/kg). This was TBEs initial evaluation for Fe-55 in soils. The result was received at the end of December and the root cause in under investigation. No client samples were associated with this cross-check. (CAR 23-31) 5.

The Analytics September 2023 milk Sr-90 result was evaluated as Not Acceptable. The reported result was 7.28 pCi/L and the known result was 12.8 (57% of known). This sample was used as the workgroup duplicate and the carrier yields for both samples were 107% and 75%. The LCS recovery for the workgroup was at 106%. The ERA drinking water Sr-90 cross check that was analyzed around the same time was acceptable at 108%. There was no explanation for the failure. This is the first low biased failure for Sr-90 milk. The last failure (high) was in 2016. (NCR 23-24) 6.

The ERA RAD October 2023 water Gross Alpha result was evaluated as Not Acceptable.

The reported result was 53.2 pCi/L and the known result was 70.6 (acceptable range of 54.0 - 87.2 pCi/L). The reported result was the workgroup duplicate and was within 75%

of the known value (within TBE QC range). The original result was 63.3 pCi/L (90% of the known). Because the LCS result was biased slightly high, the decision was made to report the lower value. (NCR 23-20) 7.

The ERA RAD October 2023 water I-131 result was evaluated as Not Acceptable. The reported value was 23.5 pCi/L and the known result was 29.7 (acceptable range of 25.8 -

33.6) The reported result was 79% of the known, which is within the acceptable TBE QC range. The workgroup was reviewed with no anomalies found. The LCS/LCSD results were 109% and 86.1%. The sample was not processed in a timely manner as per the ERA instructions which stated to analyze shortly after receipt due to the short half-life.

Going forward, the QA &/or Lab Mgr. will ensure that this analysis is started sooner.

(NCR 23-21)

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

Plant: Palisades Year: 2023 Page 41 of 41 Annual Radiological Environmental Operating Report Page 3 of 3 Interlaboratory Comparison Program Results Thermoluminescent dosimeters (TLDs) are analyzed by an offsite vendor, Environmental Dosimetry Company (EDC). The TLDs used are Panasonic 814 Environmental dosimeters.

EDC implements an internal quality assurance program and audits the program annually. There were no findings from the 2023 audit. An external audit of EDC was performed in 2023 which also resulted in no identified findings. Some of EDCs vendors also perform independent testing on the TLDs accuracy and precision. During 2023, 100% (72/72) of the individual dosimeters met the criterion for accuracy and precision. Also, 100% (12/12) of the dosimeter sets met the criterion for mean bias and precision and 100% (10/10) of independent blind testing passed the performance criteria for mean bias and precision. Acceptance criteria for mean bias is +/-15%

and for precision is +/-12.8% in accordance with EDC Quality System Manual.

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