Text

Annual Environmental Operating Report
	ML051160373
Person / Time
Site:	Callaway
Issue date:	04/19/2005
From:	Keith Young; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05141
	Download: ML051160373 (64)
	v • d • e

-1n Union Electric One Ameren Plaza 1901 Chouteau Avenue PO Box 66149 St. Louis, MIO 63166G149 314.521.3222 April 19, 2005 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P 1-137 Washington, DC 20555-0001 w'Ameren UtE Ladies and Gentlemen:

ULNRC-05141 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 2004 ANNUAL ENVIRONMENTAL OPERATING REPORT Please find enclosed the 2004 Annual Environmental Operating Report for the Callaway Plant. This report is submitted in accordance with Section 5.6.2 of the Technical Specification and Appendix B to the Callaway Plant Operating License.

Very truly yours, Wtm 0,r Keith D.

ng Manager, Regulatory Affairs DJW/jdg Enclosure a subsidiary ofAmeren Corporation

ULNRC-05141 April 19, 2005 Page 2 cc:

U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Gerhard K. Samide ANI Account Engineer Town Center, Suite 3005 29 S. Main St.

West Hartford, CT 06107-2445 Regional Administrator Department of Natural Resources Central Regional Office P.O. Box 176 Jefferson City, MO 65102-0176

2004 Callaway Plant Annual Radiological Environmental Operating Report 1, EDUMUDGMMOMl age1 1Ad.

g wameren UF Docket no. 50483

-O

Table of Contents 1.0 Executive Summary.........................................

1 2.0 Radiological Monitoring Program.........................................

2 2.1 Introduction.........................................

2 2.2 Program Design.........................................

2 2.3 Program Description.........................................

2 2.4 Sampling Program Execution and Results 10 2.4.1 Program Modifications and Exceptions................

........................ 10 2.4.2 Detection and Reporting Limits........................................ 10 2.4.3 Quality Control Program........................................

12 2.4.4 Data Interpretations........................................

12 2.4.5 Waterborne Pathway........................................

12 2.4.6 Airborne Pathway........................................

15 2.4.7 Ingeston Pathway........................................

17 2.4.8 Direct Radiation Exposure Pathway........................................

19 2.4.9 Other Exposure Pathways........................................

19 2.5 Land Use Census 21 2.6 Cross Check Results 22 2.7 Data Reporting Conventions 28 2.8 Radiological Environmental Monitoring Program Annual Summary..

28 2.9 Individual Sample Results 34 3.0 Non-Radiological Monitoring Program...............................

53 List of Figures I

Distant Collection Locations I

Near Site Collection Locations List of Tables I

I V

VI VII VlIl X

a 011 XIV XV XA XVIII X\\AII REMP Sample Locations REMP Sample Collection Frequencies and Required Analysis Minimum Detection Capabilities for REMP Sample Analysis Land Use Census Results 2004 Cross Check Results REMP Summary Airborne Beta & Iodine Airborne Gamma Composites Soil Vegetation Surface Water f

r';

Ground Water Sediments Fish Milk Supplemental REMP Samples Direct Radiation NRC Information Notice 2004-05 Samples i

1.0 Executive Summary This Annual Radiological Environmental Operating Report describes the Union Electric Company, Callaway Plant Radiological Environmental Monitoring Program (REMP), and the program results for the calendar year 2004. It is submitted in accordance with section 5.6.2 of the Callaway Plant Technical Specifications.

Section 2.0 describes the Radiological Monitoring Program.

Included is the identification of sampling locations, descriptions of sampling and analysis procedures, analysis results, data interpretations, and program modifications. Quality assurance results, sampling deviations, unavailable samples, and program changes are also discussed.

Section 3.0 describes the Non-Radiological Monitoring Program. Included are any unusual or important events, Environmental Protection Plan noncompliance, non-routine reports, and plant design and operation environmental evaluations.

During 2004 the Callaway Plant operated in compliance with the Offsite Dose Calculation Manual (ODCM) requirements.

Comparison of results for 2004 to preoperational data and data from previous years show no significant differences.

Results from the REMP indicate the Callaway Plant has had no significant radiological impact on the health and safety of the public or on the environment.

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2.0 Radiological Monitoring Program 2.1 Introduction This report presents an analysis of the results of the REMP conducted during 2004 for Union Electric Company, Callaway Plant.

The radiological environmental monitoring program began in April 1982.

The objectives of the REMP are to monitor potential critical pathways of radioactive effluent to man and determine the radiological impact on the environment caused by operation of Callaway Plant.

Callaway Plant consists of one 1239 MWe pressurized water reactor, which achieved initial criticality on October 2, 1984. The plant is located on a plateau approximately ten miles southeast of the City of Fulton in Callaway County, Missouri and approximately eighty miles west of the St. Louis metropolitan area. The Missouri Riverflows by the site in an easterly direction approximately five miles south of the site at its closest point.

2.2 Program Design The sample locations, frequency of sampling, and sample analysis requirements originate from the Callaway Plant Off Site Dose Calculation Manual, NPDES Permit, and continuation of the Callaway Plant Pre-Operational Environmental Monitoring Program.

Samples are collected from waterborne, airborne, ingestion, and direct radiation pathways.

The types of sample media collected are: milk, surface water, ground water, shoreline sediment, bottom sediment, soil, wetlands, fish, vegetation, airborne particulate, airborne radioiodine, and direct radiation (TLD). Indicator samples are collected from locations which could be influenced by plant effluents. Control samples are collected at locations that are not significantly affected by plant operation.

Samples are collected by Union Electric personnel or contractors to Union Electric and shipped to Environmental Inc. - Midwest Laboratory (EIML) for analysis. The data is reported monthly and summarized in the annual report. In 2004, thermolumescent dosimeters (TLD) were analyzed by Union Electric personnel.

Beginning in 2005, TLD processing will be

performed by a contract laboratory.

2.3 Program Description Sample locations for the REMP are shown in Figures I and 11. Table I identifies the location code, description, and sample type. Table II specifies the collection frequency and required analysis.

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Figure I Distant Collection Locations lFMT-230 01 01 LEGEND:

= TLD 21 = MILK A = AIR

= SOIL

= WATER

= FISH. SEDIMENT

= VEGETATION col 3

Figure 11 Near Site Collection Locations SSE S

" EF05 l FMT-024 l

*50 01-30-01 LEGEND:

TLD FM1 = MILK A

AIR

= SOIL

= WATER 0

= FISH. SEDIMENT

= VEGETATION Cant-~

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Table I REMP Sample Locations Location Code Sample Location Code Sample Types2 Description' Types Ia 10.8 mi. NW; City of Fulton on IDM Hwy Z, 0.65 mi. East of Business 54, West of CampusApartments.

3 1.2 mi. NW; 0.1 mi. West of Hwy IDM CC on Gravel Road, 0.8 mi. South Hwy 0, Callaway Electric Cooperative Utility Pole No. 18559.

5 1.3 mi. ENE; Primary IDM Meteorological Tower.

6 2.0 mi. W; County Road 428,1.2 IDM mi. West of Hwy CC, Callaway Electric Cooperative Utility Pole No. 18609.

7 1.4 mi. S; County Road 459,2.6 IDM mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole No.35097.

9 3.8 mi. S; NW Side of the County IDM Road 459 and Hwy 94 Junction, Callaway Electric Cooperative Utility Pole No. 06754.

10 3.9 mi. SSE; Hwy 94,1.8 mi. East IDM of County Road 459, Callaway Electric Cooperative Utility Pole No. 12182.

11a 4.7 mi. SE; City of Portland, IDM Callaway Electric Cooperative Utility Pole No. 12110.

14 4.9 mi. ESE; SE Side of IDM Intersection D and 94, Callaway Electric Cooperative Utility Pole No. 11940.

.2 Description' 17 3.8 mi. E; County Road 4053,0.3 mi. East of Hwy 94, Kingdom Telephone Company Pole No.

3X12.

18a 3.7 mi. ENE; East side of Hwy D, 0.5 mi. South of 0, Callaway Electric Cooperative Utility Pole No.38579.

20 4.7 mi. NE; City of Readsville, Callaway Electric Cooperative Utility Pole No. 12830.

21 3.8 mi. NNE; County Road 155, 1.9 mi. North of Hwy 0, Callaway Electric Cooperative Utility Pole No. 19100.

IDM IDM IDM IDM 22a 1.9 mi. NNE; North side of Hwy O, IDM 100 feet East of County Road 150, Callaway Electric Cooperative Utility Pole No.31094.

23 6.6 mi. NNE; City of Yucatan, Callaway Electric Cooperative Utility Pole No. 12670.

263 11.7 mi. E; Town of Americus, Callaway Cooperative Utility Pole No.11159.

273 9.3 mi. ESE; Town of Bluffion, Callaway Electric Cooperative Utility Pole No. 11496.

30a 4.4 mi. SSW; City of Steedman, N side of Belgian Dr., 150 feet East of Hwy CC, Callaway Electric Cooperative Utility Pole No. 06557.

IDM IDM IDM IDM 5

Table I REMP Sample Locations Continued Location Code Sample Location Code Sample Types2 Description' I,ypes 31a 7.8 mi. SW; City of Mokane, IDM Junction Hwy C and County Road 400,0.9 mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole.

32 5.4 mi. WSW; Hwy W, 0.6 mi. West IDM of County Road 447, Callaway Electric Cooperative Utility Pole No.

27031.

32a 5.0 mi. WSW; County Road 447, IDM Callaway Electric Cooperative Utility Pole No. 06354.

33 7.4 mi. W; City of Hams Prairie, SE IDM of Hwy C and AD Junction.

34 9.5 mi. WNW; NE Side of Hwy C IDM and County Road 408 Junction.

35 5.8 mi. NNW; City of Toledo, IDM Callaway Electric Cooperative Utility Pole No. 17684.

36 4.9 mi. N; County Road 155,0.8 mi. IDM South of County Road 132, Callaway Electric Cooperative Utility Pole No.

19137.

37 0.5 mi. SSW; County Road 459, IDM 0.9 mi. South of Hwy CC, Callaway Electric Cooperative Utility Pole No. 35077.

38 4.6 mi. NNW; County Road 133, IDM 1.5 mi. South of Hwy UU, Callaway Electric Cooperative Utility Pole No. 34708.

Z Description' 39 5.4 mi. NW; County Road 111, Callaway Electric Cooperative Utility Pole No. 17516.

39a 5.0 mi. NW; County Road 111, Callaway Electric Cooperative Utility Pole No. 17526.

40 4.2 mi. WNW; NE Side of County Road 112 and Hwy O, Callaway Electric Cooperative Utility Pole No. 18145.

41 4.9 mi. W; Hwy AD, 2.8 mi. East of Hwy C, Callaway Electric Cooperative Utility Pole No.

18239.

42 4.4 mi. SW; County Road 447, 2.6 mi. North of County Road 463, Callaway Electric Cooperative Utility Pole No. 06326.

43 0.5 mi. SW; County Road 459, 0.7 mi. South of Hwy CC, Callaway Electric Cooperative Utility Pole No. 35073.

44 1.6 mi. WSW; Hwy CC,1.0 mi.

South of County Road 459, Callaway Electric Cooperative Utility Pole No. 18769.

45 1.0 mi. WNW; County Road 428, 0.1 mi. West of Hwy CC, Callaway Electric Cooperative Utiility Pole No. 18580.

IDM IDM IDM IDM IDM IDM IDM IDM 6

Table I REMP Sample Locations Continued Location Code Sample Location Code Sample Types2 Description' I

46 1.5 mi. NNW; NE Side of Hwy CC and County Road 466 Intersection, Callaway Electric Cooperative Utility Pole No. 28242.

47 1.0 mi. N; County Road 448,0.9 mi. South of Hwy 0, Callaway Electric Cooperative Utility Pole No. 28151.

48 0.4 mi. NE; County Road 448, 1.5 mi. South of Hwy 0, Plant Security Sign Post.

49 1.6 mi. E; County Road 448, Callaway Electric Cooperative Utility Pole No. 06959, Reform Wildlife Management Parking Area.

50 0.9 mi. SSE; County Road 459, 3.3 mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole No. 35086.

51a 0.3 mi. SE; Owner Control Fence, SE of the Water Treatment Plant.

52 0.4 mi. ESE; Light Pole Nearthe East Plant Security Fence.

603 13.5 mi. SW; Callaway Electric Cooperative Utility Pole No. 43744 just past Tebbetts City sign.

[ypes IDM IDM IDM IDM IDM IDM IDM IDM

APT, AIO Description' A7 9.5 mi. NW; C. Bartley Farm.

A8 0.9 mi. NNE; County Road 448, 0.9 miles South of Hwy 0.

A9 1.9 mi. NNW; Community of Reform.

B3 1.8 mi. NNW; 0.3 mi. East of the O and CC Junction, Callaway Electric Cooperative Utility Pole No. 50422.

D01 5.0 mi. SE; Holzhouser Grocery Store/Tavern (Portland, MO).

F05 0.9 mi. SSE; Onsite Groundwater Monitoring Well.

F15 0.4 mi. NNE; Onsite Groundwater Monitoring Well.

PW1 Callaway Cafeteria.

M6 2.6 mi. NW; Pierce's Farm (Cow's Milk).

M83 18.7 mi. WSW, Kissock's Farm, South of New Bloomfield, MO (Cow's Milk).

M13 2.53 mi. SSE; Miller's Farm, located on Highway 448.

V33 15.0 mi. SW; Beazley Farm, West of Tebbetts, MO.

APT, AIO

APT, AIO WWA WWA WWA WWA MLK MLK MLK SOL Al 1.3 mi. ENE; Primary Meteorological Tower.

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Table I REMP Sample Locations Continued Location Code Sample Tvnue 2 Location Code Description' Description' II V9 2.0 mi. WNW; Meehan Farm.

VI0 3.4 mi. SSW; Brandt Farm.

VII 3.2 mi. NW; Hickman Farm.

V12 318.7 mi. WSW; Kissock's Farm, South of New Bloomfield, MO.

Vl 3s 2.02 mi. W; Buchholz's Farm, County Road 428, 1.2 mi. West of Hwy CC.

A3.4 4.9 mi. SSE; 0.6 River Miles Upstream of Discharge North Bank.

C4 4.9 mi. SE; 1.0 River Miles Downstream of Discharge North Bank.

S0l34.7 mi. SSE; 105 feet Upstream of Discharge North Bank.

S02 4.9 mi. SE; 1.1 River Miles Downstream of Discharge North Bank.

F2 1.64 mi. SW; Callaway Plant Forest Ecology Plot F2.

F6 1.72 mi. NE; Callaway Plant Forest Ecology Plot F6.

PR3 1.02 mi. ESE; Callaway Plant Prairie Ecology Plot PR3.

PR7 0.45 mi. NNW; Callaway Plant Prairie Ecology Plant PR7.

FP-FPL FPL FPL FPL FPL

AQS, AQF

AQS, AQF SWA SWA SOL SOL.

SOL:

SOL W4 0.68 mi. SSE; Callaway Plant Wetlands, SW Bank.

W2 0.60 mi. SSE; Callaway Plant Wetlands, InletArea.

WI 3 0.61 mi. SE; Callaway Plant Wetlands, High Ground.

W3 0.72 mi. SSE; Callaway Plant Wetlands, Discharge Area.

GWS, Ground Water Sump, Plant East of containment and Spent Fuel Pool Bldg.

936S Diesel Fuel Remediation Well, Plant SE of Spent Fuel Pool Bldg.

937C5 Monitoring Well, Plant East of Radwaste Building Drum Stor age.

937Ds Monitoring Well, Plant South of Discharge MonitorTanks.

1 All distances are measured from the midpoint of the two reactors as described in Final Safety Analysis Report (FSAR) Section 2.1.1.1.

2 AIO = Air lodine, APT = Air Particulate, AQF = Fish, AQS = Sediment, FPL = Leafy Green Vegetables, GWS = Ground Water Sump, IDM = TLD, MLK =

Milk, SOL = Soil, SWA = Surface Water, WWA=

Ground Water.

3 Control Location.

4 The fish collection area for location "A" is between 0.6 and 3.0 river miles upstream of the plant discharge on the north bank and for location 'C" is between discharge area and 1.5 miles downstream of the discharge on the north bank. The expanded collection areas are needed to guarantee there is sufficient habitat for sampling to insure the ability to collect the required number of fish species.

Sample Types2 SOL SOL SOL SOL VV0 VWAA VWAA WAA 6 New REMP location for 2005.

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Table 11 REMP Sample Collection Frequencies and Required Analysis1 Sample Sample Collection Required Type Code Frequency Analysis Airborne Iodine Air Particulate AIO Weekly 1-131 weekly APT Weekly Gross Beta weekly2 and Gamma Isotopic of quarterly filter composite Fish AQF Semiannually (April 1 stand Oct 1 st)

Gamma Isotopic Sediment (Shoreline and Bottom)

Leafy Green Vegetables Isotopic AQS FPL Semiannually (April 1 stand Oct 1st)

Monthly during the growing season (2nd Tues. of month)3 Gamma Isotopic (Bottom sample NPDES requirement)

Gross Alpha, Gross Beta, I -131, and Gamma TLD IDM Milk MLK Quarterly (Ist day of each quarter)

Semimonthly when animals are on pasture; monthly otherwise Annually (November 1 st)

Gamma Dose 1-131 and Gamma Isotopic GrossAlpha, Gross Beta Gamma Isotopic (Continuation of preoperational program)

Soil SOL Surface Water Drinking / Ground Water SWA Monthly composite (2nd Tues. of month) H-3 and Gamma Isotopic WWA Quarterly Grab (1st day of each quarter) H-3 and Gamma Isotopic I Samples required by ODCM and NPDES permit.

Additional sampling is performed as a continuation of the preoperational monitoring program.

2 If gross beta activity is greater than the established base line activity level, gamma isotopic analysis is performed on the individual sample.

3 The growing season is defined as the months of May through November; however, the growing season will vary from year to year due to weather conditions.

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Radiological Monitoring Program 2.4 Sampling Program Execution and Results 2.4.1 Program Modifications and Exceptions During 2004, no significant changes were made to the Radiological Environmental Monitoring Program.

The Radiological Environmental Monitoring Program was executed as described in the ODCM with any exceptions listed in this report.

2.4.2 Detection and Reporting Limits Table IlIl gives the minimun required detection limits for radiological environmental sample analysis. For each sample type, the table lists the detection level for each isotope. The lower limit of detection (LLD) used in this report is described in NRC Regulatory Guide 4.1 Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants" and the NRC Radiological Assessment Branch Technical Position, Rev. 1, November 1979, "An Acceptable Radiological Environmental Monitoring Program".

Positive sample results are reported with a 2 sigma counting uncertainty (corresponding to the 95% confidence level). Cases where the activity is found to be below the sample analysis minimum detection level are reported as Not Detected (ND).

Aerial view of the Callaway Plant site. Included is some of the land worked by a local farmer to produce feed for cattle and for growing soybeans for commercial use.

Q03 10

Table III Minimum Detection Capabilities for REMP Sample Analysis1 Food Soil and Water Airborne Fish Milk Products Sediment Analysis (pCi/1)

(pCi/m3)

(pCi/kg wet)

(pCi/1)

(pCilkg wet) (pCi/kg dry)

Gross beta 4

0.01 H-3 Mn-54 Fe-59 3000/20003 15 30 130 260 Co-58/60 Zn-65 Zr-Nb-952 1-131 Cs-134 Cs-1 37 Ba-La-1 402 15 130 30 260 15 1000/13 15 18 15 0.07 I

60 0.05 0.06 130 150 15 18 60 80 150 180 15 I This list does not mean only these nuclides will be detected and reported. Other peaks which are measurable and identifiable will be reported.

2 Total activity, parent plus daughter activity.

3 LLDs for Surface and Drinking / Ground water are the same, with the exception of H-3 and 1-131. The drinking/ground water LLDs for H-3 and 1-131 are 2000 and 1 pCi/liter respectively.

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Radiological Monitoring Program 2.4.3 Quality Control Program The vendor laboratory, Environmental Inc. -

Midwest Laboratory, maintains a quality assessment (QC) program in accordance with Regulatory Guide 4.15. The program includes laboratory procedures designed to prevent cross contamination and to ensure accuracy and precision of analyses. QC checks include blind, duplicate, and spiked samples as necessary to verify laboratory analysis activities are being maintained at a high level of accuracy.

The contractor laboratory participates in the Department of Energy's Environmental Measurements Laboratory QualityAssessment Program (EML), Mixed Analyte Performance Evaluation Program (MAPEP), and Environmental Resource Associates (ERA). The results of these cross check programs are presented in Section 2.6.

The Callaway Plant Personnel Dosimetry program is accredited by the National Voluntary LaboratoryAccreditation Program (NVLAP) of the National Institute of Standards and Technology (NIST). The Environmental TLD Program has demonstrated compliance with the recommendations of Regulatory Guide 4.13.

Quality control checks are performed including blanks, blind samples, daily performance checks, and quarterly cross checks.

CAR 200402348 discusses failure of a liquid Fe-55 cross check by EIML. The investigation of the failure revealed that the wrong sample was used in the analysis.

2.4.4 Data Interpretations Sample analysis results are evaluated to determine if the result was due to the operation of the Callaway Plant or other sources.

One evaluation method used is the indicator-control concept. Most sample types are collected at both indicator (areas potentially 12 affected by plant operations) and control locations (areas not significantly affected by plant discharge). A possible plant effect would be indicated if the detected level at an indicator location was statistically greater than at the control location.

Another method involves determining if the result originated from weapons testing. The indicator or control sample result can be compared to established environmental levels produced from weapons testing.

Sample results can also be compared with preoperational levels or samples collected in other parts of the country. Results can also be related to events known to have caused elevated levels of radiation in the environment.

2.4.5 Waterborne Pathway Surface Water Analysis Tritium: A 60-70 ml aliquot of water is purified by distillation. A portion of the distillate is transferred to a counting vial and scintillation fluid added. The contents of the vial are thoroughly mixed and counted in a liquid scintillation counter.

Gamma Spectrometry: Asuitable aliquotof sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Sampling and Frequency Monthly composite samples of surface water from the Missouri River are collected from one indicator location (S02) and from one control location (SO1) and shipped to EIML for analysis.

Radiological Monitoring Program Sampling of the Missouri River is accom-plished using an automated compositor.

Samples are collected on an hourly basis and mixed to make the monthly composite sample. Riversampling verifies that Callaway Plant discharges meet stringent regulatory requirements.

inlet piping inspection/replacement. These conditions were repaired and/or corrected and the sampler was returned to service. Other conditions such as electric power outages also contributed to sampler inoperability (CAR 200408752 &

200408756).

Deviations during 2004 included a missed grab sample on November 25th due to snow and ice on the shoreline of the Missouri River (CAR 200408756).

Tritium was the only radionuclide detected in surface water samples collected during 2004.

Two of the twelve samples collected at indicator location S02 contained measurable levels of tritium with a mean concentration of 423.5 pCi/L (CAR 200402526). The Tritium results from S02 for 2004 were less than 1.5% of the reporting limit in surface water and well within regulatory requirements. Tritium results at S02 are being trended along with monthly liquid H-3 releases and Missouri riverflow. The analysis results are consistent with previous operational levels and there was no significant radiological impact on the health and safety of the public or on the environment.

The control water sampler (S01) was operational 99.2% of the time in 2004. This sampler is checked weekly. Immediate actions are taken to return the sampler back to service when a problem is identified. If the sampler cannot be returned to service within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , daily grab samples are collected. Exceptions during 2004 included 3 days of inoperability in July, due to a scheduled power outage.

The gamma analysis results for surface water samples were consistent with previously accumulated data and no plant operational effects were identified.

Drinking / Ground Water Analysis Tritium: A 60-70 ml aliquot of water is purified by distillation. A portion of the distillate is transferred to a counting vial and scintillation fluid added. The Results The indicator water sampler (S02) was operational 96% of the time during 2004 compared to the 92% for 2003. Sampler operability is verified shiftly (every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ) by use of a dial up modem. Immediate actions are taken to return the sampler to service when a problem is identified. If the sampler does not collect >250 mis per day, daily grab samples are collected and composited.

Eight of the thirteen days of indicator water sampler inoperability (S02) were due to the pump tripping repeatedly in February (CAR 200401298). Additional operational problems with indicator water sampler (S02) included a pump leak on October 12, 2004 that caused two days of inoperability. CAR 200402341 discusses sample proportioning (D-Y) valve leakage/

oscillations on May 15,2004. One day of inoperability in September was for routine sampler 13

Radiological Monitoring Program contents of the vial are thoroughly mixed and counted in a liquid scintillation counter.

Gamma Spectrometry: A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer. Analysis for 1-131 is accomplished using chemical separation followed by gas flow proportional counting techniques.

Sampling and Frequency Ground water samples are collected quarterly from two sampling wells (FO5 and F1 5) and two drinking waterwells (DO1 and PW1). Four additional shallow wells (GWS/936/937C/937D) were added to the Callaway REMP due to positive tritium results found in these on site aquifers. The samples were taken as a result of NRC Information Notice 2004-05, Spent Fuel Pool Leakage to Onsite Groundwater at Salem. An exhaustive study of the source of tritium was conducted and determined to be from recirculation of liquid effluents. The study indicated that no additional pathways, other than those identified in the Callaway ODCM, were affected (CAR 200403826, CAR 200401807, and CAR 200401931).

The well samples are collected using an electric pump that is located in the well. The drinking water samples are collected from a faucet after allowing the line to flush for two minutes. The shallow well samples are collected by Engineering Surveys & Services. Samples are shipped to EIML for analysis.

Bottom Sediment Analysis Gamma Spectrometry: A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Sampling and Frequency Bottom sediment samples are collected semiannually from one indicator location (C) and one control location (A). The samples are taken from water at least 2 meters deep to prevent influence of bank erosion. A Ponar dredge is used to obtain the samples, consisting of the uppermost layer of sediment. Each sample is placed, without preservative, in a plastic bag, sealed and shipped to EIML for analysis.

Results The analysis results for bottom sediment samples in 2004 were consistent with previously accumulated data including pre-operation and no plant operational effects were identified.

Shoreline Sediment Analysis Gamma Spectrometry: Asuitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Results The analysis results for all drinking/ground water samples were consistent with previously accumulated data and no plant operational effects were identified. (Note: groundwater samples are analyzed with the more conservative LLD limits associated with drinking water.)

Sampling and Frequency Shoreline sediment samples are collected semiannually in the same area as bottom sediment. These samples are collected within two feet of the edge of the water and consist of 2 six-inch diameter by two-inch deep sediment plugs.

Each sample is placed in a plastic bag, sealed and shipped to EIML for analysis.

14

Radiological Monitoring Program Results Results The analysis results for shoreline sediment samples in 2004 were consistent with previously accumulated data including pre-operation and no plant operational effects were identified.

..

-

-t

--

-- a--

Shoreline sediment samples are collected two feet from the edge of the water in the same location as the bottom sediment samples. Sediment samples indicate there has been no impact on the environment from Calla way Plant liquid discharges/effluents.

Wetlands Soil Analysis Gamma Spectrometry: A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Sampling and Frequency Wetlands soil samples are collected annually from 3 indicator locations (W2, W3, and W4) and one control location (WI). Two 6-inch square soil plugs consisting of the uppermost two-inch layer of soil are taken at each location. The samples are placed in plastic bags, sealed and shipped to EIML analysis.

Cesium 137 (Cs-1 37) was detected in the Wetlands soil samples. Station (WI) indicated 188 pCi/Kg dry, station (W2) indicated 79 pCi/Kg dry, and station (W3) indicated 169 pCi/Kg dry.

The analysis results for Wetlands soil samples in 2004 were consistent with previously accumulated data and no plant operational effects were identified. The Cs-1 37 activity is due to world wide fallout from atmospheric nuclear testing.

2.4.6 Airborne Pathway Airborne Analysis Gross Beta: The filters are analyzed approximately five days after collection to allow for decay of natural short-lived radionuclides. A glass fiber type filter is placed into a stainless steel planchet and counted for gross beta radioactivity using a proportional counter.

Iodine: Each Charcoal cartridge is placed on the germanium detector and counted. A peak of 0.36 MeV is used to calculated the concentration at counting time. The equilibrium concentration at the end of the collection is then calculated. Decay correction for the time interval between sample collection and counting is then made.

Gamma Spectrometry: Filters are composited according to location and counted using a germanium detector coupled to a computer based multichannel analyzer. The resulting spectrum is analyzed by computer and specific nuclides, if present, identified and quantified.

Sampling and Frequency Airborne particulate samples are collected on a 47mm diameter glass fiber filter type A/E (99 percent removal efficiency at 1 micron particulate) at a volumetric rate of one and one-half cubic feet per minute.

Each airborne particulate air sampler is equipped with a charcoal cartridge filter in-line after the particulate filter holder.

15

Radiological Monitoring Program Each airborne particulate air sampler is equipped with a charcoal cartridge filter in-line after the particulate filter holder.

The filters are collected weekly and shipped to EIML for analysis.

All five sample locations are considered indicator locations (Al, A7, A8, A9, and B3). One indicator station (A9) is located at the community with the highest D/Q.

Results Air station Al and A7 were operational 100% of the time in 2004 with the annual sampler calibration change out of 0.1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the only out of service time assigned.

Air station A8 was operational for 96.2% of the time in 2004. A regulatorfailure during the last week of January was responsible for 163.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of inoperability (CAR 200400888), and another 168.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of inoperability in February due to low sample flow for the week (CAR 200401468). In both cases, sampler replacement was performed and the defective samplers sent to the on site calibration facility for repair and recalibration. The filters were sent to EIML for analysis and assigned a conservative flow rate.

Air station B3, was operational 98.1 % of the time during 2004. During May of 2004 the samplerfailed a leak check following a routine filter change out (CAR 200404692). The defective fitting was replaced and a conservative flow rate was assigned to the samples for the previous week. The sampler was assigned 170.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of out of service time for this occurrence. The air samples were sent to EIML for analysis.

Air station A9 was operational 99.9% of the time in 2004. During the sampler changeout for calibration in June, the replacement sampler did not provide the proper sample flow rate. This sampler was replaced and as a result, 1.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of inoperability was assigned to air station A9.

Gross beta activity ranged from 0.010 to 0.049 pCi/M3 in all samples. The average gross beta activity at all locations was 0.023 pCi/M3. In 2004, there were 17 weekly samples with gross beta activities greater then the base line action level of 0.037 pCi/M3. Gamma spectral analysis was performed on these filters and no gamma emitting isotopes of plant origin were detected.

The analysis results for airborne samples are consistent with previously accumulated data and no plant operational effects were identified.

Ay)J Airborne samples are continuously col-lected. Particulates are gathered on a glass fiber filter. A charcoal filter is in line after the particulate filter to collect iodines. Air samples indicate the Callaway Plant has had no impact on the surrounding environment.

16

Radiological Monitoring Program 2.4.7 Ingestion Pathway Milk Analysis lodine-1 31: Two liters of milk containing standardized Iodine carrier is stirred with anion exchange resin for one hour. The resin is washed with NaCI and the iodine is eluted with sodium Hypochlorite. Iodine in the iodate form is reduced to 12 and the elemental iodine extracted into CC14, back-extracted into water, then precipitated as palladium iodide. The precipitate is counted for 1-131 using a proportional counter.

Gamma Spectrometry: An aliquot of milk is placed in a standard counting container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer. Analysis for 1-131 is accomplished using chemical separation followed by gas proportional counting techniques.

Sampling and Frequency When available, one-gallon milk samples are collected semimonthly during the grazing season (typically April through September) and monthly during the winterfrom two indicator stations near the Plant (M6 and M13) and one control location away from the Plant (M8). Milk samples have sodium bisulfite added as a preservative, and are shipped on ice to EIML for analysis within eight days after collection.

Results Milk samples were unavailable/limited due to animals not producing milk during the following periods:

Location M13:

Milk samples were unavailable on 1/13,1/26, and 2/9 due to gestation (CAR 200400978).

Milk samples were not collected as scheduled on 12/14 due to unreturned phone calls from the REMP participant. Samples were collected forthe month on 12/31 (CAR 200500059).

Location M8:

Milk samples were unavailable on 11/23 and 12/14 due to gestation (CAR 200500059).

Location M6:

All samples were collected as scheduled.

Samples were collected monthly in January, February, March, and December (stored feed). Samples were collected semimonthly for all other months since the milking animal was spending a portion of it's time grazing.

The analysis results for milk samples were consistent with previously accumulated data and no plant operational effects were identified.

Fish are collected by Union Electric biolo-gists. Fish samples indicate there has been no impact on the environment due to opera-tion of the Callaway Plant.

17

Radiological Monitoring Program Fish Analysis Gamma Spectrometry: A prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Sampling and Frequency The five most abundant recreational or commercial fish species are collected semiannually from one indicator location (C) and one control location (A). After collection, fish samples are shipped on ice to EIML analysis.

During fish sampling in October, Union Electric Environmental Services biologists reported problems collecting certain species from both the control and indicator stations. For example, smallmouth buffalo was collected from the control location, but not at the indicator station. The biologists were also able to collect several additional species at both locations.

These species included black buffalo, blue sucker, and shorthead redhorse. The biologists determined that black buffalo would be sent for analysis instead of the blue sucker which is considered a rare species in Missouri and since it would not be a good indication of the ingestion pathway (CAR 200408140).

counting time. The equilibrium concentration at the end of collection is calculated by decay correcting for the time interval between sample collection and counting.

Gamma Spectrometry: A suitable aliquot of wet (as received) sample is placed into a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Sampling and Frequency Monthly during the growing season, green leafy vegetation is collected from three indicator locations V9, V1 0, and V11 and from one control location V1 2. Vegetation samples consisted of mustard greens, turnip greens, cabbage, lettuce, collards, radish greens, swiss chard, broccoli, and poke. Other broad leaf vegetation is requested and/or collected if primary varieties are not available. Samples are shipped to EIML for analysis.

Results Vegetation samples were collected as available from May through December due to unseasonably milder temperatures in November and December.

The following indicates the months where no vegetation samples were collected:

Location V9:

Januarythrough May, and August.

Location V1 0:

January through April, and September.

Location V1 1:

January through May, and December Location V1 2:

January through April, and December The analysis results for vegetation samples were consistent with previously accumulated data and no plant operational effects were identified.

Results The analysis results for fish samples were consistent with previously accumulated data and no plant operational effects were identified.

Vegetation Analysis Iodine-131: A suitable aliquot of wet (as received) sample is placed into a standard calibrated container and counted using a germanium detector coupled to a computer based, multichannel analyzer. A peak of 0.36 MeV is used to calculate the concentration at 18

Radiological Monitoring Program 2.4.8 Direct Radiation Exposure Pathway Direct Radiation Analysis The Union Electric program uses the Panasonic Model UD-814 TLD and Model UD-71 OA automatic dosimeter reader. Each dosimeter consists of three elements of CaSO4:Tm. The dosimeters are sealed in a water proof plastic bag and placed inside a polypropylene mesh cylindrical holder in the environment. After exposure in the environment the dosimeters are read and the result is adjusted to a standard quarter of 90 days. For 2005, multiple UD-814 TLDs, and Optically stimulated thermolumescent dosimeters (OSLD) have been placed at each location to evaluate this new type of dosimeter in the field.

Sampling and Frequency Thermoluminescent Dosimetry (TLD) is used to determine direct radiation levels in and around the Callaway site. Forty-three dosimeters are placed in 16 sectors around the plant as specified in the ODCM. The dosimeters are read once per quarter. Three locations are designated as controls (IDM26, IDM27 and IDMI60).

Results Direct radiation data for IDM- 0 was unavailable in the second quarter. The apparent cause for the missing TLD was due to vandalism (CAR 200406027). The TLD at sample station IDMI 0 was promptly replaced.

The analysis results for TLD samples were consistentwith previously accumulated data and no plant operational effects were identified.

Pictured is one of the forty three dosim-eterlocations used to measure direct radia-tion. Direct radiation data indicates there has been no impact from the operation of the Callaway Plant.

2.4.9 Other Exposure Pathways Soil Analysis Gamma Spectrometry: A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based, multichannel analyzer.

Sampling and Frequency Soil samples are collected annually from four indicator locations (F2, PR3, F6, and PR7) and one control location (V3). To ensure only the most recent deposition is sampled, the uppermost two-inch layer of soil is taken at each location.

Samples consist of 2 six-inch square soil plugs.

The litter at the surface and the root mat is considered part of the sample. The samples are placed in plastic bags, sealed and shipped to EIML for analyses.

19

Radiological Monitoring Program Results Cesium 137 (Cs-1 37) was detected at control station V3 at 277 pCi/Kg dry, while the highest indicator station result was 817 pCi/L dry.

The analysis results for soil samples in 2004 were consistent with previously accumulated data including pre-operation and no plant operational effects were identified. The Cs-1 37 activity is due to worldwide fallout from atmospheric nuclear testing.

During a training evolution it was identified that the 2003 soil sample location PR3 was actually taken at the site for soil sample location PR4.

Soil sample location PR4 was previously removed from the REMP (CAR200407907). GPS coordinates were added to the procedure to prevent any future reoccurence.

The analysis results for soil samples were consistent with previously accumulated data. Soil sampling is a continuation of the preoperational environmental monitoring program.

REMP Supplemental Samples Several supplemental samples were taken during 2004 which were not required by FSAR-SP Table 16.11-7. Samples of beef, venison, and soybeans were collected to further assess the

impact of plant operation on the environment (CAR 200407337). The venison samples were taken from an animal that grazes on vegetation grown within the site boundary. The soybean

samples were taken from a field within the site boundary. The soybean field within the site boundarywas harvested for commercial purposes. The beef sample was taken from a cow that has grazed on land within the site boundary.

The samples were sent to EIML for analysis.

The results are listed in Table XVI and are consistent with previously accumulated data and no plant operational effects were identified.

_;.V

-NV.!L This photo shows some of the wildlife in a wetland area near Callaway Nuclear Power Plant.

20

Radiological Monitoring Program 2.5 Land Use Census The Land Use Census is performed annually during the growing season within a five-mile radius of the Callaway Plant. The location of the nearest resident, milking animal, and garden greater than 50 m2 (500 ft2) is identified by contacting residents by phone and/or in field surveys for each of the sixteen meteorological sectors using the midpoint of the two units.

The Union Electric Real Estate Department conducted the 2004 Land Use Census in August, a month earlier than in 2003, for improved garden identification.

Results The results of the 2004 Land Use Census are presented in Table IV. The table includes radial direction and distance from the Callaway Plant for each location. These parameters were determined using a combination of map position, aerial photography, and a Global Positioning System (GPS) receiver.

Nearest Resident The distance of the nearest resident with the highest D/Q was unchanged for 2004. This resident lives 1.82 miles from the plant in the NNW sector. New construction was observed during the field inspection; however, none qualified as closest resident in any of the sectors.

Milking Animals No new residents with milking animals were located in any of the sectors.

Comparison of the current REMP milk sample participants with residents identified as having milking animals in the 2004 Land Use Census indicates that no changes are necessary.

Vegetable Gardens As was the case in 2003, a residence in sector R (NNW) with a vegetable garden was determined to have a 20% higher average ground level D/Q than current REMP sample participants.

The Union Electric Real Estate Dept. made several attempts to request their participation in the Callaway REMP. However, after several calls and letters, it was determined that the resident was not interested (CAR 200500526).

A resident in sector N was identified as having a vegetable garden with a size over 50 m2 (500 ft2) has agreed to participate in the 2005 REMP program. This location is identified as V1 3 (CAR 200500526).

View of land near the Callaway Plant during late Winter. In the background is the Missouri River.

21

Table IV 2004 Land Use Census Results Closest Receptor in Miles Sector N(A)

NNE(B)

NE(C)

ENE(D)

E(E)

ESE(F)

SE(G)

SSE(H)

S(J)

SSW(K)

SW(L)

WSW(M)

W(N)

WNW(P)

NW(Q)

NNW(R)

Residence 2.2 2.2 2.3 1.7 3.5 2.1 2.2 2.5 2.7 2.4 2.6 1.2 1.6 1.9 2.1 1.8 Garden1 Milk' 4.7 2.4 4.0 2.9 N1 4.4 4.7 2.5 NI 2.8 3.1 4.0 2.0 1.9 3.2 3.2 NI NI NI NI 2.5 N!

N1 4.0 NI 2.6 NI

' NI = None Identified 2.6 Cross Check Results The cross check results performed by the vendor laboratory during 2004 are presented in Table V. The results indicate satisfactory laboratory performance.

22

Table V 2004 EML Cross Check Results Reported Value' Reference Value Control Limits2 Date Type Nuclide Result Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Mar-04 Water Water Water Water Water Water Water Water Water Water Soil Soil Soil Soil Soil Soil Vegetation Vegetation Vegetation Vegetation Vegetation Vegetation Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Gr. Alpha Gr. Beta Am-241 Co-60 Cs-1 37 H-3 Pu-238 Pu-239/40 Sr-90 Uranium Am-241 Cs-137 K-40 Pu-239/40 Sr-90 Uranium Am-241 Co-60 Cs-137 K-40 Pu-239/40 Sr-90 Am-241 Co-60 Cs-1 34 Cs-137 Pu-238 Pu-239/40 Sr-90 Uranium Gr. Alpha Gr. Beta 208.00 +/- 20.70 1063.00 +/- 27.00 1.21+/- 0.02 152.30 + 0.30 50.40 + 0.90 263.50 + 10.00 1.03 +/- 0.04 2.90 0.10 5.20 +0.30 4.35 +/- 0.21 14.1 +4.30 1292.00 +/- 13.00 563.00 +/- 83.00 20.70 1.10 72.10 +/- 5.80 139.10 +/- 10.20 4.50 +/- 0.20 14.10 +/- 0.40 573.90 + 6.00 709.00 +/- 19.30 6.60 + 0.50 766.50 +/- 51.30 0.11+/- 0.01 30.90 +/- 1.08 12.30 +/- 1.30 24.90 +/- 0.60 0.04 +/- 0.01 0.17 0.02 1.80 + 0.20 0.17 0.01 1.09 +/- 0.06 2.68 + 0.05 326.00 1170.00 1.31 163.20 51.95 186.60 1.10 3.08 4.76 4.62 13.00 1323.00 539.00 22.82 51.00 180.22 4.93 14.47 584.67 720.00 6.81 734.00 0.10 35.40 18.20 26.40 0.04 0.16 1.76 0.17 1.20 2.85 0.55-1.31 0.75-1.65 0.66-1.56 0.87-1.17 0.90- 1.25 0.69 - 191 0.68 - 1.33 0.62-1.38 0.73-1.65 0.40- 1.45 0.52 - 2.41 0.74-1.40 0.70- 1.59 0.62 - 1.99 0.58 - 2.96 0.27 - 1.48 0.58 - 2.86 0.64-1.49 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS FAIL3 PASS PASS PASS PASS PASS PASS PASS 0.75 -

0.45 -

0.60 -

0.50 -

1.48 1.51 1.98 1.37 0.62-1.93 0.74-1.25 0.70- 1.21 0.72-1.32 0.61 - 1.55 0.67-1.58 0.62 - 2.26 0.79 - 2.88 0.82-1.58 0.75-1.94

'Results are reported as follows: Water Bq/L, Air Filters Bq/Filter, Soil and Vegetation Bq/Kg.

2Control Limits are defined by MAPEP and ERA.

3Probable effect of summation peaks and slight difference in filter geometry.

23

Table V 2004 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits2 Result May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Am-241 Co-57 Co-60 Cs-134 Cs-137 Fe-55 H-3 Mn-54 Ni-63 Pu-238 Pu-239/40 Sr-90 Tc-99 U-233/4 U-238 Zn-65 Gr. Alpha Gr. Beta 0.56 + 0.07 184.10 + 13.50 164.40 +/- 11.70 201.10 + 14.00 245.50 +/- 15.80 37.60 + 25.30 76.50 +/- 5.40 272.10 +/- 17.50 94.4 +/- 3.20 1.11 +/- 0.09 0.01 +/- 0.01 6.20 +/- 1.10 10.70 + 1.00 0.14+/- 0.02 0.94 + 0.05 219.60 +/- 27.90 1.20 0.10 4.30 0.10 0.60 185.00 163.00 208.00 250.00 33.00 83.00 267.00 100.00 1.20 0.000 7.00 10.00 0.12 0.90 208.00 1.20 4.10 0.42 - 0.78 129.50 - 240.50 114.10 - 211.90 145.60 - 270.40 175.00 - 325.00 23.10 -42.90 58.10 - 107.90 186.90 - 347.10 70.00 - 130.00 0.84 -1.56 0.000 - 0.10 4.90 - 9.10 7.00- 13.00 0.08 - 0.16 0.63 - 1.17 145.60 - 270.40 0.00 - 2.40 2.05 - 6.15 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Am-241 Co-57 Co-60 Cs-134 Cs-1 37 K-40 Ni-63 Tc-99 U-233/4 U-238 Zn-65 65.90 +/- 4.50 388.90 +/- 4.00 524.80 +/- 7.10 403.40 +/- 4.60 829.10 +/- 7.60 620.60 +/- 29.50 254.80 +/- 8.40 59.00 +/- 6.00 24.70 +/- 3.60 24.20 +/- 3.50 743.00 +/- 13.10 66.97 399.60 518.00 414.40 836.20 604.00 357.05 117.66 37.00 38.85 699.30 46.88 - 87.06 279.72 - 519.48 362.60 - 673.40 290.08 - 538.72 585.34 - 1088.00 422.80 - 785.20 249.94 - 464.17 82.36 - 152.96 25.90 - 48.40 27.20 - 50.51 489.51 - 909.09 PASS PASS PASS PASS PASS PASS PASS FAIL4 FAIL3 FAIL3 PASS

'Results are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.

2Control Limits are defined by MAPEP and ERA.

Failure due to incomplete dissolution of the sample.

Reanalysis of the sample produced the same results. Uranium is not measured in soil matrices at Callaway. Interlaboratory comparisons in matrices other than soil were successfully completed.

4A spiked soil sample was prepared. Known actiivity; 32.98 pCi/g; laboratory result 33.47 pCi/g.

'A 11 -+

Table V 2004 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits2 Result May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 May-04 Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Gr. Alpha Gr. Beta Am-241 Co-57 Co-60 Cs-134 Cs-137 Mn-54 Pu-238 Pu-239/40 Sr-90 U-233/4 U-238 Zn-65 0.06 +/- 0.02 1.37 +/- 0.08 0.08 +/- 0.03 2.07 +/- 0.06 2.11+/- 0.08 1.78 +/- 0.08 1.76 +/- 0.08 2.84+/- 0.11 0.12 +/- 0.01 0.08 +/- 0.01 0.66 +/- 0.19 0.23 +/- 0.03 0.23 +/- 0.03 3.90 +/- 0.22 0.40 1.20 0.10 2.40 2.30 2.90 2.00 3.00 0.13 0.09 0.80 0.21 0.22 4.00 0.00 - 0.80 0.60- 1.80 0.07 - 0.13 1.68 - 3.12 1.61 - 2.99 2.03 - 3.77 1.40 -2.60 2.10 - 3.90 0.09 - 0.17 0.06 -0.12 0.56-1.04 0.15 - 0.27 0.15 - 0.29 2.80 - 5.20 PASS PASS PASS PASS PASS FAIL3 PASS PASS PASS PASS PASS PASS PASS PASS

'Results are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.

2Control Limits are defined by MAPEP and ERA.

3A low bias for Cs-1 34 activity has been observed in the past. No errors have been found in the library or efficiency. Additional spike analysis will be performed and a correction factored into the calculation.

25

Table V 2004 ERA Cross Check Results Reported Reference Control Date Type Nuclide Value1 Value Limits2 Result Feb - 04 Feb - 04 Feb - 04 Feb- 04 Feb- 04 Feb- 04 Feb- 04 Feb- 04 Feb- 04 Feb - 04 Feb - 04 Feb - 04 May-04 May- 04 May- 04 May- 04 May- 04 May- 04 May- 04 May- 04 May-04 May- 04 May- 04 May- 04 May- 04 May - 04 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Sr-89 Sr-90 Ba-1 33 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta Ra-226 Ra-228 Uranium Sr-89 Sr-90 Ba-133 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta 1-131 Ra-226 Ra-228 Uranium H-3 36.5 + 6.5 13.4 + 0.8 60.9 + 2.8 95.2 +/- 1.5 71.2 + 5.4 157.0+/-6.5 103.0+/- 1.1 15.6 +/- 1.2 46.3 +/-4.4 8.7 0.2 16.6 0.4 34.2 0.8 39.7 +/- 3.3 12.4 0.9 96.9 2.4 39.9 +/- 0.5 48.8 +/- 0.8 82.6 2.3 77.5 1.5 32.4 2.1 63.4+/- 3.5 25.2 +/- 0.4 16.0 +/- 1.1 12.6 +/- 0.9 13.0 +/- 0.0 32043 +/- 166 44.9 11.6 63.2 96.4 75.8 155.0 102.0 16.6 41.5 9.3 18.2 33.0 45.9 11.6 101.0 41.6 50.5 82.5 75.2 38.8 59.6 25.1 17.3 10.3 12.7 30900 36.2 - 53.6 2.9 - 20.3 52.3 - 74.1 87.7 - 105.0 67.1 - 84.5 142.0 - 168.0 84.4-120.0 7.9 - 25.3 32.8 - 50.2 6.9-11.7 10.3 -26.1 27.8 - 38.2 37.2 - 54.6 2.9 - 20.3 83.5 - 118.0 32.9 - 50.3 41.8 -59.2 73.8 -91.2 62.2 - 88.2 22.0 - 55.6 42.3 - 76.9 19.9 - 30.3 12.8 - 21.8 5.8-14.8 7.5-17.9 25600 - 36200 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS

'Results are reported as: pCi/l for ERA.

2Control Limits are defined by ERA.

26

Table V 2004 ERA Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits2 Result Aug - 04 Aug - 04 Aug - 04 Aug - 04 Aug -04 Aug - 04 Aug -04 Aug - 04 Aug -04 Aug - 04 Aug -04 Aug -04 Aug - 04 Nov -04 Nov- 04 Nov - 04 Nov- 04 Nov - 04 Nov - 04 Nov-04 Nov-04 Nov-04 Nov -04 Nov - 04 Nov - 04 Nov- 04 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Sr-89 Sr-90 Ba-133 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta Gr. Beta Ra-226 Ra-228 Uranium Sr-89 Sr-90 Ba-133 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta 1-131 Ra-226 Ra-228 Uranium H-3 16.1 +/-1.9 13.4 0.1 30.2 + 3.9 24.9+/- 1.9 21.4 + 3.4 205.6 + 4.3 145.5 + 3.0 47.7 + 9.1 28.1 +/-2.5 28.1 +/-2.5 6.9 0.5 13.1 +/-1.4 6.0 0.1 42.2 +/- 3.5 37.3 +/- 1.3 75.5 0.8 12.2 0.7 43.6 +/- 0.5 59.5 2.9 50.7 3.2 23.9 +/- 2.2 35.8 +/- 1.3 22.4 +/- 1.9 9.8 0.4 8.6 0.3 11.1+/- 0.3 21218 +/- 285 20.0 13.6 32.1 24.0 21.6 193.0 143.0 57.0 20.0 20.0 6.3 14.7 6.2 45.7 36.6 78.4 11.7 42.9 60.1 50.9 31.7 36.3 22.0 9.2 7.1 11.4 20700 11.3 -28.7 4.9 - 22.3 23.4 -40.8 15.3 - 32.7 12.9 - 30.3 176.0 - 210.0 118.0 - 168.0 32.3 - 81.7 11.3 -28.7 11.3 -28.7 4.6 - 7.9 8.3 -21.1 1.0 - 11.4 37.0 - 51.5 27.9 -45.3 64.8 - 92.0 3.0 - 20.4 34.2 - 51.6 51.4 - 68.8 42.1 - 59.7 18.0 -45.4 27.6 -45.0 16.9 -27.3 6.8 - 11.6 7.0- 10.2 6.2 - 16.6 17100 - 24300 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS Nov- 04 Water

'Results are reported as: pCi/I for ERA.

2Control Limits are defined by ERA.

¶27-

Radiological Monitoring Program 2.7 Data Reporting Conventions Lower Limit of Detection The lower limit of detection (LLD) used in this report is per NRC Regulatory Guide 4.1, Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants", and the NRC Branch Technical Position, November 1979, "An Acceptable Radiological Environmental Monitoring Program". The LLD is defined as the smallest concentration of radioactivity material in a sample that will yield a net count (above system background) that will be detected with 95%

probability with only 5% probability of falsely concluding that a blank observation represents a

real" signal.

The maximum LLDs for radiological environmental sample analysis is presented in Table l1l.

Data Reporting Positive sample results are reported with a 2 sigma counting uncertainty (corresponding to the 95% confidence level). In cases where the activity is found to be below the sample analysis minimum, the activity is reported as Not Detected (ND).

2.8 Radiological Environmental Monitoring Program Annual Summary.

The REMP Summary is presented in Table VI in accordance with NRC Regulatory Guide 4.1, Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants", and the NRC Branch Technical Position, November 1979, "An Acceptable Radiological Environmental Monitoring Program". In cases where the activity is found to be below the sample analysis minimum, the activity is reported as < LLD.

With the exception of a small indication of tritium in riverwater, there was no measurable impact on the environment due to plant operation.

"

View of the Missouri River looking west from Portland Missouri. In the distance, you can see the Callaway Nuclear Power Plant intake structure.

28

(

((

Table VI REMP Summary Type and All Location With Highest Medium or Pathway Total Lower Indicator Annual Mean Control Number of Sampled Number Limit of Locations Name Mean (f)2 Location Non-routine (Unit of of Analysis Detection Mean (f)2 Distance and Range Mean (f)2 Reported Measurement)

Performed (LLD)'

Range Direction Range Measurements Waterborne Pathway Surface Water H-3 (24) 3000 (pCi/l) 424 (2/12)

(190 - 657) 7.6 (24/24)

(5.4-11.7)

S02 4.9 mi SE 424 (2/12)

(190 - 657) 7.9 (12/12)

(5.4-11.7)

< LLD 0

Gross Beta (24) 4 S02 4.9 mi SE 7.3 (12/12)

SO1 4.7 Mi SSE

< LLD 0

Mn-54 (24)

Fe-59 (24)

Co-58/60 (24)

Zn-65 (24)

Zr-95 (24)

Nb-95 (24) 1-131 (24)

Cs-134 (24)

Cs-I 37 (24)

Ba-La-I 403 (24) 15

< LLD

< LLD 0

30 15 30 30 15 1000 15 18 15

< LLD

< LLD 0

0 0

29

(

Table VI REMP Summary Type and All Location With Highest Medium or Pathway Total Lower Indicator Annual Mean Control Number of Sampled Number Limit of Locations Name Mean (f2 Location Non-routine (Unit of of Analysis Detection Mean (f 2 Distance and Range Mean (fl2 Reported Measurement)

Performed (LLD)'

Range Direction Range Measurements Waterborne Pathway Drinking / Ground Water H-3 (16)

Gross Beta (16) 2000

< LLD

< LLD 0

4 7.1 (16/16)

(3.2 - 10.5)

< LLD F05 0.9 Mi SSE 9.8 (4/4)

(9.1 - 10.5)

< LLD 0

(pCi/l)

Mn-54 (16) 15 0

Fe-59 (16)

Co-58/60 (16)

Zn-65 (16)

Zr-95 (16)

Nb-95 (16) 1-131 (16)

Cs-134 (16)

Cs-1 37 (16)

Ba-La-1403 (16)

Ingestion Pathway 30 15 30 30 15 1

15 18 15

< LLD

< LLD 0

0 0

Vegetation (pCi/kg - wet) 1-131 Cs-134 (57)

(57) 60 60

< LLD

< LLD 0

0 Cs-1 37 (57) 80

< LLD

< LLD 0

z-A I

(

Table VI REMP Summary Type and All Location With Highest Medium or Pathway Total Lower Indicator Annual Mean Control Number of Sampled Number Limit of Locations Name Mean (f2 Location Non-routine (Unit of of Analysis Detection Mean (f 2 Distance and Range Mean (f2 Reported Measurement)

Performed (LLD)'

Range Direction Range Measurements Ingestion Pathway Milk 1-131 (56)

Cs-1 34 (56)

Cs-137 Ba-140 La-140 (56)

(56)

(56) 1.0 15 18 60 15

<LLD

<LLD 0

0 0

Fish (pCi/kg - wet)

Mn-54 (20)

Fe-59 Co-58/60 Zn-65 Cs-134 Cs-1 37 (20)

(20)

(20) 130 260 130 260 130 150

<LLD

<LLD 0

< LLD

<LLD

<LLD 0

0 0

31

(

k Table VI REMP Summary Type and All Location With Highest Medium or Pathway Total Lower Indicator Annual Mean Control Number of Sampled Number Limit of Locations Name Mean (f)2 Location Non-routine (Unit of of Analysis Detection Mean (f2 Distance and Range Mean (f 2 Reported Measurement)

Performed (LLD)'

Range Direction Range Measurements Direct Radiation Quarterly TLDs (mRem/Standard Quarter)

Gamma (171)

Dose 16.1 (159/160)

(10.4 -19.9) 10 3.9 mi. SSE 17.2 (3/4)4 (16.7-18.1) 15.3 (12/12)

(10.1 -19.4) 0 Airborne Pathway Airborne Particulate Gross (260) 0.010 (0.009 - 0.041)

A-9 (pCi/M3 )

Beta 1.9 mi. NNW 0.023 (52/52)

(0.011 - 0.049)

< LLD 0

1-131 (260) 0.070 Cs-134 (17) 0.050 Cs-137 (17) 0.060

< LLD 0

< LLD

< LLD 0

< LLD

< LLD 0

32

(

(k Table VI REMP Summary Type and All Location With Highest Medium or Pathway Total Lower Indicator Annual Mean Control Number of Sampled Number Limit of Locations Name Mean (f)2 Location Non-routine (Unit of of Analysis Detection Mean (f)2 Distance and Range Mean (f)2 Reported Measurement)

Performed (LLD)'

Range Direction Range Measurements Sediments (pCi/Kg, dry)

Cs-1 34 Cs-1 37 (8)

(8) 150 180

< LLD

< LLD 0

0 Soil (pCi/Kg, dry)

Cs-134 Cs-137 (18)

(18) 150 180

< LLD 388 (12/14)

(66 - 817)

F2 1.64 Mi SW

< LLD 705 (2/2) 226 (4/4)

(184 - 277) 0 0

'Minimum Detection Capabilities for REMP sample analysis.

2Mean and range are based upon detectable measurements only. Fraction of detectable measurements is indicated in parentheses.

3Total activity, parent plus daughter activity.

4TLD Missing from location 10 for second quarter 2004 (CAR200406027).

33

Radiological Monitoring Program 2.9 Individual Sample Results The REMP Individual sample results are presented in Tables VII through XVI.

The following acronyms are used in these tables:

ND = Not Detected (Result below analysis detection limit)

NA= NotAvailable (Circumstances discussed in body of report)

/

-

rrr7rT?.

V

'1 The area surrounding the Callaway Plant includes the Reform Conservation Area. The 7,044 acres that comprise this area is owned by Union Electric and managed by the Missouri Department of Conservation.

34

Airborne Beta & Iodine Table VII (All results are the effect of natural background)

Gross Beta data is listed. All lodine-131 results are <0.07. All results are in pCiIm3.

(2004)

A-1 B-3 A-7 A-8 A-9 A-1 B-3 A-7 A-8 A-9 1-2 1-8 1-15 1-23 1-29 2-5 2-12 2-19 2-26 3-4 3-11 3-18 3-25 4-1 4-8 4-15 4-22 4-29 5-6 5-13 5-20 5-27 6-3 6-10 6-17 6-24 0.019 0.029 0.038 0.036 0.030 0.040 0.044 0.029 0.023 0.018 0.015 0.019 0.019 0.012 0.020 0.016 0.022 0.012 0.019 0.024 0.012 0.014 0.014 0.017 0.017 0.013 0.020 0.032 0.034 0.031 0.024 0.038 0.042 0.027 0.022 0.015 0.012 0.016 0.017 0.012 0.019 0.013 0.018 0.013 0.018 0.0203 0.014 0.013 0.012 0.018 0.014 0.011 0.021 0.029 0.034 0.028 0.026 0.045 0.041 0.028 0.021 0.016 0.012 0.014 0.014 0.010 0.015 0.014 0.018 0.010 0.013 0.023 0.012 0.012 0.011 0.014 0.011 0.015 0.020 0.029 0.037 0.030 0.029 0.0221 0.048 0.024 0.0202 0.015 0.016 0.016 0.017 0.011 0.018 0.016 0.021 0.012 0.015 0.023 0.013 0.013 0.012 0.014 0.014 0.014 0.021 7-1 0.033 7-8 0.040 7-15 0.031 7-22 0.028 : 7-29 0.042 8-5 0.046 8-12 0.030 8-19 0.024 8-26 0.017 9-2 0.016 9-10 0.016 9-16 0.016 9-23 0.011 9-30 0.018 10-7 0.017 10-14 0.022 10-21 0.014 :10-28 0.017 11-4 0.021 11-12 0.011

11-18 0.013 :11-26 0.015 12-2 0.0174 12-10 0.018 :12-16 0.015 12-22 12-29 0.019 0.010 0.018 0.022 0.019 0.025 0.017 0.028 0.017 0.015 0.023 0.020 0.023 0.024 0.019 0.020 0.017 0.018 0.012 0.030 0.022 0.021 0.015 0.038 0.023 0.025 0.034 0.021 0.014 0.020 0.020 0.021 0.026 0.017 0.027 0.016 0.017 0.024 0.021 0.022 0.023 0.022 0.019 0.017 0.018 0.014 0.029 0.021 0.022 0.019 0.041 0.025 0.028 0.034 0.017 0.011 0.017 0.019 0.018 0.021 0.016 0.028 0.017 0.015 0.018 0.019 0.021 0.022 0.017 0.013 0.013 0.015 0.013 0.025 0.022 0.018 0.018 0.037 0.022 0.025 0.030 0.018 0.013 0.019 0.023 0.020 0.026 0.018 0.026 0.017 0.015 0.022 0.019 0.020 0.021 0.019 0.018 0.014 0.018 0.012 0.031 0.020 0.020 0.020 0.041 0.026 0.027 0.033 0.019 0.013 0.019 0.022 0.021 0.026 0.017 0.033 0.019 0.016 0.022 0.021 0.023 0.025 0.021 0.020 0.017 0.020 0.013 0.032 0.023 0.023 0.020 0.049 0.026 0.030 0.033 1 Regulator failure==> 163.2 hrs inoperability 2Sample flow abnormality==> 168.8 hrs inoperability 3Leak check failure==> 170.2 hrs inoperability 4Fitting leaking after filter change==> 1.1 hrs inoperability 35

Airborne Gamma Composites (All results are the effect of natural background)

Table VilI Gamma Isotopic' (pCiIm3)

A-1 QTR1 0.062 QTR2 0.084 QTR3 0.062 QTR 4 0.057 Be-7 Be-7 Be-7 Be-7 A-7 QTR1 QTR2 QTR3 QTR 4 0.049 0.069 0.070 0.053 A-8 QTR1 QTR2 QTR3 QTR 4 0.048 0.071 0.076 0.056 A-9 QTR1 QTR2 QTR3 QTR4 0.055 0.072 0.076 0.057 B-3 QTR1 0.055 QTR2 0.070 QTR3 0.072 QTR4 0.056 Be-7 1Co-58, Co-60,Zr-95, Nb-95, Cs-134, Cs-137, Ba-140, La-140, Ce-1 44, and ND = Not Detectable.

3b

Soil Table IX (All results are the effect of natural background)

Gamma Isotopic' (pCilkg)

F2 F2 F6 F6 PR3 11/2/04 11/2/04 11/10/04 11/10/04 11/2/04 Gross Alpha Gross Beta K-40 Cs-1 37 Gross Alpha Gross Beta K40 Cs-1 37 Gross Alpha Gross Beta K-40 Cs-1 37 10,982 20,390 11,507 817 15,334 24,596 11,184 592 16,186 26,872 11,731 674 15,249 29,434 11,639 642 12,634 23,288 10,861 461 PR3 PR7 PR7 V3 V3 11/2/04 11/2/04 11/2/04 11/2/04 11/2/04 10,411 12,831 14,327 11,443 9,632 21,090 23,074 20,864 22,301 26,556 11,004 11,291 10,753 13,831 15,780 306 311 371 254 277 WI WI W2 W2 W3 11/2/04 11/2/04 11/2/04 11/2/04 11/2/04 16,695 12,808 10,372 11,325 15,914 25,746 24,022 22,886 21,775 27,655 15,377 16,151 12,981 13,376 15,454 188 184 79 66 169 W3 11/2/04 W4 11/2/04 16,904 18,885 8,726 ND W4 11/2/04 14,578 17,590 8,506 ND Gross Alpha Gross Beta K-40 Cs-1 37 20,373 25,382 15,445 169

'Mn-54, Fe-59, Co-58, Co-60, Zr-95, Nb-95, Cs-134, Ba-140, La-140, and ND = Not Detectable.

37

Vegetation Table X (All results are the effect of natural background)

Gamma Isotopic' (pCilkg wet)

V9 6/21/04 Lettuce 6/21/04 Cabbage 7/12/04 Lettuce 7/12/04 Cabbage 9/13/04 Lettuce Gross Alpha Gross Beta K-40 40 4,152 5,133 56 2,794 3,473 60 6,845 4,592 58 5,108 3,081 ND 4,709 4,468 9/13/04 Collards 9/13/04 Mustard 10/13/03 Lettuce 10/13/03 Cabbage 10/13/03 Collards Gross Alpha Gross Beta K-40 ND 4,879 4,862 ND 4,533 5,083 ND 3,882 4,049 ND 4,625 2,910 ND 4,404 3,669 10/13/03 Turnips 10/13/03 Radish 10/25/04 Lettuce 10/25/04 Cabbage 10/25/04 Collards Gross Alpha Gross Beta K-40 ND 4,158 3,395 131 4,625 2,910 ND 4,020 4,117 ND 4,816 3,812 ND 4,852 4,768 10/25/04 Turnips 10/25/04 Radish 11/8/04 Lettuce 11/8/04 Cabbage 11/8/04 Collards 1

Gross Alpha ND Gross Beta 4,887 K-40 4,766 1Mn-54, Co-58, Co-60, 1-131, Cs-1 34, Cs-1 37, and ND = Not Detectable.

ND 3,791 3,209 106 4,489 4,351 75 3,411 2,099 96 4,990 4,308 38

Vegetation Table X (All results are the effect of natural background)

Gamma Isotopic' (pCilkg wet)

V9 (continued) 11/8/04 Turnips 11/8/04 Radish 12/13/04 Lettuce 12/13/04 Cabbage 12/13/04 Collards Gross Alpha Gross Beta K-40 Gross Alpha Gross Beta K-40 ND 4,588 4,724 91 4,553 3,955 ND 4,315 4,943 ND 4,032 3,817 ND 5,164 4,282 11/8/04 Turnips ND 5,062 4,588

'Mn-54, Co-58, Co-60, 1-131, Cs-134, Cs-137, and ND = Not Detectable.

39

Vegetation (All results are the effect of natural background)

Table X Gamma Isotopic' (pCi/kg wet) v1o 6/8/04 Lettuce 84 5,174 5,334 7/13/04 Lettuce ND 4,253 3,803 7/13/04 Lettuce 59 2,333 2,772 8/10/04 Turnips 88 5,413 3,121 10/12/04 Turnips ND 4,271 4,496 Gross Alpha Gross Beta K-40 11/9/04 Turnips 11/9/04 Cabbage ND 3,890 3,736 Gross Alpha Gross Beta K-40 ND 4,366 4,364

'Mn-54, Co-58, Co-60, 1-131, Cs-134, Cs-1 37, and ND = Not Detectable.

40

Vegetation (All results are the effect of natural background)

Table X Gamma Isotopic' (pCi/kg wet)

VII 5/10/04 Lettuce 5/10/04 Cabbage 6/7/04 Lettuce 6/7/04 Swiss Chard 7/13/04 Lettuce Gross Alpha Gross Beta K-40 ND 4,925 4,597 ND 3,684 3,708 123 5,909 6,137 212 6,507 6,695 320 4,402 3,325 7/13/04 Cabbage 7/13/04 Broccoli 8/9/04 Swiss Chard 8/9/04 Broccoli 9/13/04 Cabbage Gross Alpha Gross Beta K-40 60 2,512 1,898 82 4,734 4,481 ND 4,548 4,039 150 7,363 5,886 177 3,008 3,150 Gross Alpha Gross Beta K-40 9/13/04 Broccoli 175 7,477 7,450 10/11/04 Cabbage 226 2,207 2,562 10/11/04 Turnips 93 3,929 3,847 11/8/04 Cabbage ND 2,837 2,614 11/8/04 Turnips ND 5,126 3,403 Gross Alpha Gross Beta K-40 12/13/04 Cabbage ND 2,764 3,065 12/13/04 Turnips ND 5,571 3,918 1Mn-54, Co-58, Co-60, 1-131, Cs-1 34, Cs-1 37, and ND = Not Detectable.

41

Vegetation Table X (All results are the effect of natural background)

Gamma Isotopic' (pCi/kg wet)

V12 5/10/04 Vegetation 6/8/04 Poke 7/12/04 Lettuce 8/9/04 Cabbage 9/13/04 Cabbage Gross Alpha Gross Beta K-40 148 6,601 6,614 131 7,764 6,619 ND 6,000 4,956 ND 3,763 3,866 ND 3,886 4,204 10/11/04 Cabbage 11/8/04 Cabbage Gross Alpha Gross Beta K-40 ND 3,168 3,634 ND 3,203 2,853

'Mn-54, Co-58, Co-60, 1-131, Cs-134, Cs-137, and ND = Not Detectable.

49

Surface Water Table Xl (All results except tritium are the effect of natural background)

Gamma Isotopic' (pCi/L)

Sol 1/13/04 Gross Alpha Gross Beta H-3 2.3 5.6 ND 2/11/04 2.5 5.9 ND 3/9/04 3.2 5.9 ND 4/13/04 2.5 7.9 ND 5/11/04 2.7 7.0 ND 6/8/04 4.4 9.3 ND 7/13/04 8/10/04 9/14/04 10/12/04 11/9/04 12/15/04 Gross Alpha Gross Beta H-3 Gross Alpha Gross Beta H-3 4.2 9.4 ND 5.7 8.6 ND 4.3 8.3 ND 3.1 6.6 ND 2.5 6.8 ND 1.3 5.9 ND S02 1/13/04 3.3 5.4 ND 2/11/04 ND 6.4 657 3/9/04 2.8 7.7 190 4/13/04 2.6 6.6 ND 5/11/04 4.5 7.7 ND 6/8/04 5.3 8.8 ND 7/13/04 8/10/04 9/14/04 10/12/04 11/9/04 12/15/04 Gross Alpha Gross Beta H-3 3.9 10.7 ND 7.0 11.7 ND ND 8.1 ND 2.7 7.0 ND 3.6 9.0 ND 1.9 6.1 ND 1Mn-54, Fe-59, Co-58, Co-60, Zn-65, Zr-95, Nb-95,1-131, Cs-134, Cs-137, Ba-140, La-140, and ND = Not Detectable.

43

Table X1I Ground Water Gamma Isotopic' (pCi/L)

DOI QTR1 ND QTR2 ND QTR3 ND QTR4 ND All All All F05 QTR1 QTR2 QTR3 QTR4 ND ND ND ND F015 QTR1 QTR2 QTR3 QTR4 ND ND ND ND PWOO1 QTR1 ND QTR2 ND QTR 3 ND QTR4 ND All

'H-3, 1-131, Mn-54, Fe-59, Co-58, Co-60, Zn-65, Zr-95, Nb-95, Cs-134, Cs-137, Ba-140, La-140, and ND = Not Detectable.

44

Table XAl Ground Water GWS1 Beta H-3 4-11 4

366 5-18 4

363 7-9 2.2 2512 8-2 8.1 399 10-11 9.0 ND3 9361 Beta H-3 4-11 4

368 5-18 4

406 7-9 11.1 176 8-2 8.9 429 10-11 15.2 414 937C1 Beta H-3 4-11 4

164 5-18 4

NY 7-9 5.5 ND3 8-2 2

2 10-11 8.7 199 937D1 Beta H-3 4-11 4

427 5-18 4

304 7-9 5.6 ND3 8-2 7.7 249 10-11 9.2 NEY

'Samples taken in response to NRC information notice 2004-05: SFP Leakage to onsite Groundwater.

2No sample from this location for given date.

3ND = Not Detectable.

'Not analyzed for Gross Beta.

45

Sediments Table XIII (All results are the effect of natural background)

Gamma Isotopic' (pCi/kg dry)

Bottom Sediments A

C 4/29/04 10/19/04 4/29/04 10/19/04 12,292 ND K-40 Cs-1 37 12,226 ND 11,641 ND K-40 Cs-1 37 12,217 ND Shoreline Sediments A

C 4/29/04 10/19/04 4/29/04 10/19/04 12,255 ND K-40 Cs-137 13,318 ND 12,773 ND K-40 Cs-137 13,634 ND

'Mn-54, Fe-59, Co-58, Co-60,Zr-95, Nb-95, Cs-134, Cs-137, Ba-1 40, La-1 40, and ND = Not Detectable.

46

Fish Table XIV (All results are the effect of natural background)

Gamma Isotopic' (pCi/kg wet)

A 4/29/04 Carp 4/29/04 Freshwater Drum 4/29/04 Channel Catfish 4/29/04 Bigmouth Buffalo 4/29/04 River Carpsucker K-40 3,117 3,050 2,404 2,776 2,527 10/19/04 Carp 10/19/04 Freshwater Drum 2,646 10/19/04 River Carpsucker 2,551 10/19/04 Shorthead Redhorse 3,215 10/19/04 Black Buffalo 2,936 K-40 2,896 C

4/29/04 Carp 2,842 4/29/04 Freshwater Drum 2,711 4/29/04 Channel Catfish 2,712 4/29/04 Bigmouth Buffalo 2,843 4/29/04 River Carpsucker 2,939 K-40 10/19/04 Carp 3,221 10/19/04 Freshwater Drum 2,974 10/19/04 River Carpsucker 3,325 10/19/04 Shorthead Redhorse 3,217 10/19/04 Black Buffalo 2,587 K-40

'Mn-54, Fe-59, Co-58, Co-60, Zn-65, Cs-134, Cs-1 37, and ND = Not Detectable.

47

Milk Table XV (All results are the effect of natural background)

Gamma Isotopic and Iodine' (pCi/L)

M6 K-40 K-40 K-40 K-40 1/13/04 1660 5/25/04 1,173 8/24/04 1,226 11/23/04 1,092 2/10/04 1,301 6/8/04 1,142 9/14/04 1,341 12/14/04 1,411 3/9/04 1,187 6/22/04 1,252 9/28/04 1,227 4/13/04 1,361 7/13/04 1,315 10/12/04 1,230 4/28/04 1,167 7/27/04 1,190 10/26/04 1,170 5/11/04 1,231 8/10/04 1,318 11/9/04 1,405 M8 K-40 K-40 K-40 1/13/04 1,387 5/10/04 1,328 8/9/04 1,266 1/26/04 1,313 5/24/04 1,159 8/24/04 1,228 2/9/04 1,296 6/7/04 1,225 9/14/04 1,275 3/8/04 1,375 6/21/04 1,177 9/21/04 1,456 4/12/04 1,371 7/12/04 1,348 10/12/04 1,233 4/27/04 1,245 7/26/04 1,370 10/26/04 1,100 11/9/04 1,269 K-40 11-131, Zn-65, Cs-134, Cs-137, Ba-140, La-140, and ND = Not Detectable.

48

Milk Table XV (All results are the effect of natural background)

Gamma Isotopic and Iodine' (pCi/L)

M13 3/22/04 1,706 4/12/04 4/27/04 1,862 1,501 5/10/04 1,394 5/24/04 1,520 6/7/04 1,521 K-40 6/21/04 K-40 1,546 7/12/04 1,528 7/26/04 1,525 8/10/04 1,589 8/23/04 1,593 9/13/04 1,492 9/27/04 K-40 1,408 10/12/04 1,295 10/26/04 1,605 11/8/04 1,288 12/31/04 1,354 11-131,Zn-65, Cs-134, Cs-137, Ba-140, La-140, and ND =Not Detectable.

49

Supplemental REMP Samples Table XVI (All results are the effect of natural background)

Gamma Isotopic' (pCi/kg)wet Beef Venison 9/23/04 12/3004 K-40 Gamma Isotopic 2104 ND 2

ND Soybeans 7/16/04 9/28/04 Gamma Isotopic Gross Alpha Gross Beta K-40 ND 133 4239 2784 ND ND 4035 3511

'Mn-54, Fe-59, Co-58, Co-60, Zr-Nb-95, Cs-134, Cs-137, Ba-La-140, and ND = Not Detectable.

2Results for K-40 not reported by EIML.

50

Direct Radiation (All results are the effect of natural background)

Table XVII Gamma Dose (mrem) 1a 3

5 6

7 9

10 11a 14 17 18a 20 21 22a 23 26 27 30a 31a 32 QTR1 14.9 17.3 12.7 16.8 15.0 14.9 16.7 16.7 14.6 14.4 15.2 14.9 17.0 15.2 15.3 10.1 17.1 16.1 17.8 17.0 QTR2 16.1 17.1 15.5 18.2 17.0 16.6 17.2 16.2 16.2 17.4 16.0 17.1 15.9 16.9 12.8 16.2 15.4 16.9 16.4 QTR3 14.3 15.2 12.5 14.7 14.8 14.6 16.7 16.5 15.4 16.2 16.3 17.3 16.1 16.0 16.3 11.3 17.0 15.3 16.3 16.4 QTR4 16.3 17.4 14.8 17.6 14.6 16.1 18.1 17.5 18.5 18.0 18.3 19.3 18.1 16.4 16.8 12.4 19.4 15.4 17.4 17.5 34 35 36 37 38 39 39a 40 41 42 43 44 45 46 47 48 49 50 QTR1 14.6 14.2 14.7 15.7 10.4 14.5 17.2 15.1 16.6 11.8 15.5 17.1 14.3 16.4 16.8 14.8 15.5 15.6 17.4 16.8 17.5 15.5 12.4 17.0 18.0 18.2 15.5 14.3 16.6 15.8 16.5 16.1 15.0 18.5 17.0 16.5 19.2 15.6 14.4 16.1 14.9 10.5 15.8 16.1 16.7 15.9 13.4 14.9 16.2 14.2 16.2 14.2 16.3 15.5 15.0 15.7 QTR2 QTR3 QTR4 15.9 14.6 17.8 16.3 12.3 16.4 16.8 18.1 16.3 14.3 16.0 17.7 15.6 19.9 16.7 18.5 16.2 17.4 17.9 51a 15.5 1 TLD and holder missing from assigned location. Installed 3rd Quarter TLD and new holder.

51

(

(.

C.

NRC Information Notice 2004-05 Samples Table XVIII H-3 Results are in pCi/L Sample ( pCiIL) 5/14 5/21 6/2 6116-17 7/1 7/2 7/29-30 9/1 9/24 10/1 10/6 10/13 11/5 4

4 1

4 4

I 4

1

£ 4

UHS Pond 443 Clearwell 278 Pond 12

<161 Pond 13

<156 Potable water

<156 Unit 2 Pond

<161 / 224 Oily Waste Effluent 329 Oily Waste Ungrd Tk.

272 Sludge Pit 308 Supematant Sump 272 Settling Ponds 3/4 320 Equalization Basin

<161 Raw water/\\WTP (river)

<161 Rainwater (5/13)

<161 Cooling Tower Basin, Settling Pond 1 Settling Pond 2 Parking lot drainage

<161 (Unit 2 Pond efuent)

S/G B/D NRHX Service Water CCWB SFP Leak Detection 349 321 479

<157 229 170 351

<157

<157 642 I 562 273 /203 273 /203 173

<154

<158

<158 297 215 4.7E+07 71 114

<165

<158

<158 764 304 1107/1204

<172

<159

.1.

4

4.

4 4

.4.

I Periodic higher levels of H-3 due to recirculation of plant effluents at the intake structure.

52

3.0 Non-Radiological Monitoring Program 3.1 Introduction Union Electric Company, d.b.a.AmerenUE, in accordance with federal regulations and a desire to maintain the quality of the local environment around Callaway Plant has implemented an Environmental Protection Plan, (EPP) contained in Appendix B of the Callaway Plant Operating License.

During 2004, there were nine plant design and operation changes that could have involved a potentially significant unreviewed environmental question. The interpretations and conclusions regarding these plant changes along with a description of the change are presented below.

Callawav Modification 03-1017A The objective of the EPP is to provide for protection of non-radiological environmental values during operation of the Callaway Plant.

This report describes the conduct of the EPP for the Callaway Plant during 2004.

3.2 Unusual or Important Events No unusual or important events reportable under the EPP Section 4.1 were identified during 2004.

3.3 EPP Noncompliances During 2004 there were no noncompliances with the EPP.

3.4 Nonroutine Reports There were no nonroutine reports submitted in accordance with the EPP, Section 5.4.2 in 2004.

Description of Change:

Modification 03-1017A consists of several improvements at the Callaway Plant gun range.

The main improvements are listed below:

1. Construct an enclosed Shooting Tower (1 6'xl 6'

& elevated 35').

2. Relocate access road.

3. Construct chain link fence surrounding the perimeter of the entire range.

4. Construct classroom/office facility building (approx. 100' x 40'), including restroom facilities.

5. Construction of an in-ground holding tank (no larger than 10,000 gallons) for collection of sanitary waste water.

6. Construct parking facility adjacent to classroom/office facility 7. Provide at least an 8' high backstop at impact area of pop-up target range.

Evaluation of Change:

3.5 Plant Design and Operation Environmental Evaluations.

This section lists all changes in the plant design, operation, tests or experiments installed during 2004, which could have involved a potentially significant unreviewed environmental question in accordance with section 3.1 of Appendix B.

All work underthis modification is at or surrounding the existing gun range. Some of this area has been previously graded/excavated to install a moving target range, 100 yard covered firing position, elevated 200 yard firing position, large background berm and miscellaneous storage and temporary shooting positions.

Additional excavation work outside of this previously disturbed area, including the new road, is not associated with any cultural resources 53

3.0 Non-Radiological Monitoring Program identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

All construction being performed to complete the modifications to the existing gun range described above will require excavation of an area greater than one acre and less than 5 acres.

These areas will be controlled by appropriate means to limit any potential soil erosion. All excavated areas surrounding the road and training facility will be surface stabilized as part of this modification. Any grading of the gun range area and new road will route rainfall in an acceptable water runoff pattern to account for the effects of local intense precipitation described in Section 2.4.2.3 of the Site FSAR Addendum. Stormwater discharge from the area disturbed to complete this modification will be discharged through a permitted stormwater outfall. An application was submitted to the Missouri Department of Natural Resources for a Land Disturbance Storm Water Permit.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Procedure ETP-AQ-ST004. 3-Methoxypropylamine Test Program Description of Change:

Test procedure ETP-AQ-ST004 allows the addition of Methoxyproplyamine (MPA) for pH control in the secondary system as a replacement for ethanolamine (ETA). This test program is being conducted during Cycle 14 to determine the optimum concentration of MPAfor controlling erosion corrosion in the secondary system. The test is planned to be conducted with no condensate polishing. Blowdown demineralizers will be used for secondary system cleanup however; condensate polishers may be required from time to time for additional cleanup. During the test period, MPAwill be fed to the secondary system at a target feedwater concentration of 8-16 ppm. If operation with one condensate polisher is necessary, it is expected that MPAwill be present in liquid radwaste discharges from polisher regeneration waste. This may result in a MPA concentration of near 3 ppm in the batch releases via Ouffall 001. With no condensate polishing, only insignificant quantities of MPA are expected to be discharged through Outfall 001 due to minor system leakage.

Evaluation of Change:

Methoxyproplyamine has not been previously identified in the Callaway NPDES Permit Application or in the NPDES Permit. Therefore, a letter was submitted to the Missouri Department of Natural Resources on 3/17/04 to notify them of our intended use of this product. No additional authorization is required at this time. As stated in the letter to DNR, the regularwhole effluent toxicity (WET) test required by our NPDES Permit will also be conducted during the MPAtest program.

Should the decision be made to use MPA on a permanent basis, the Missouri Department of Natural Resources will be notified in writing at that time.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

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360 Non-Radiological Monitoring Program Callaway Modification 02-2002:

Description of Change:

To prepare for Missouri River barge delivery of the Replacement Steam Generators (RSGs) for the Callaway Steam Generator Replacement (SGR), a docking facility will be constructed, and required upgrades will be made to the haul route designated for transport of the RSGs from the docking facility to the Callaway Plant.

The main activities consist of:

-Construction of a docking/offload facility adjacent to the Missouri River, upstream of the existing Callaway Plant intake structure to be located between Missouri River mile 115.4 and 115.5. The docking/offload facility site is located within AmerenUE owner-controlled property.

Construction of a river access road from the docking/offload facility to existing State Route 94, within the confines of AmerenUE owner-controlled property.

-Construction of a permanent bridge structure over Mud Creek for transit of the transported RSGs from Route 94 to the Heavy Haul Road (County Road 459). This permanent bridge structure will be constructed at the existing Mud Creek low water crossing.

Evaluation of Change:

Construction of the RSG docking/offload facility and upgrades to the haul route performed by Modification Package 02-2002 will be constructed in a site area that has been previously surveyed, evaluated and determined to not be associated with cultural resources identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

As part of Modification Package 02-2002, an application was made by the Callaway Plant licensee (AmerenUE) to the U.S. Army Corps of Engineers to satisfy requirements associated with construction activities performed adjacent to and affecting the Missouri River.

An application package for a Land Disturbance Storm Water Permit (<5 acres) was submitted to the Missouri Department of Natural Resources and a permit was issued.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Modification 02-2003 Description of Changae:

This change is to construct a Steam Generator Replacement Project (SGRP) Support Building within the Protected Area (PA) to support project activities and forfuture plant use. The size of this structure will be approximately 100 feet by 110 feet. As an office and warehouse structure, the SGRP Support Facility has numerous technical requirements to ensure its present and future uses will be appropriately designed for, including factors such as building size, functionality for materials handling and materials/records storage, safe occupancy of personnel, provision and operation of equipment.

Evaluation of Change:

The facility will be constructed in a site area that has been previously disturbed, evaluated, and determined to not be associated with cultural resources identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

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3.0 Non-Radiological Monitoring Program Callaway Modification 02-2003 - Continued Construction of the SGRP Support Facility will require excavation of the structure's foundation, and these activities will be controlled by means appropriate to limit any potential soil erosion.

The areas surrounding the facility will be surface stabilized as part of this modification. Grading of the area of the SGRP Support Facility construction will route rainfall to an acceptable water runoff pattern to account for the effects of local intense precipitation described in Section 2.4.2.3 of the Site FSARAddendum. Any rainwater from this disturbed area during construction of the SGRP Support Facility that could result in stormwater runoff being discharged through a point source to the waters of the state will be discharged through Outfall 012, which is an existing Stormwater Outfall permitted by the State of Missouri. As such, no additional stormwater permit is required for the construction of this facility.

As part of SGRP Support Facility design, connections will be made to the plant potable water and sewage systems. With respect to the capacity limits for these systems described in Section 9.2.4 of the Site FSAR Addendum, there are no significant increases to the duties of the potable water and sewage systems that would result through expected use of the facility.

Although SGR personnel will use the SGRP Support Facility potable water and sewage services, the large number of personnel who mobilize to the site for the construction phase of the project (i.e., just priorto and immediately following the SGR outage) will utilize vendor-provided drinking water and Porta-johns for these services.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level.

Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Modification 03-1007 Descriotion of Chanae:

Modification Package 03-1007 permanently constructs an Old Steam Generator (OSG)

Storage Facility (OSGSF) outside of the Protected Area and within the site Owner Controlled Area to provide temporary storage of the OSGs removed from the Unit 1 containment as part of the Callaway Steam Generator Replacement (SGR) Project.

At the election of AmerenUE, the OSGSF design includes an additional storage area that will accommodate future temporary storage of the existing reactor vessel closure head (RVCH), as part of potential replacement of that component.

The facility also provides areas for temporary storage of miscellaneous radioactive/

radiologically contaminated materials/items associated with the SGR and general plant operation.

The facility is designed to accommodate temporary storage until site decommissioning commences, at which time the facility itself, along with its contents, will be decommissioned. The OSGSF is located within the Owner Controlled Area on the eastern sector of the site (oriented to Plant North), across from the Maintenance Shop Annex.

Evaluation of Change:

As part of Modification Package 03-1007, both the ER and FES-OL were reviewed for any previously evaluated adverse environmental impacts and any adverse environmental impacts not previously evaluated. No such environmental impacts were identified.

The facility will be constructed in a site area that has been previously evaluated and determined to not be associated with cultural resources identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

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3.0 Non-Radiological Monitoring Program Callawav Modification 03-1007 - continued Construction of the OSGSF will require excavation of the structure's foundation, and these activities will be controlled by means appropriate to limit any potential soil erosion. The areas surrounding the facility will be surface stabilized as part of this modification. Grading of the area of the OSGSF construction will route rainfall to an acceptable water runoff pattern to account for the effects of local intense precipitation described in Section 2.4.2.3 of the Site FSARAddendum. The stormwater runoff will ultimately be discharged through outfall 014 which is a stormwater outfall in our NPDES permit. The actions taken to minimize soil erosion along with the retention pond for this outfall will maintain all limited parameters within our NPDES limits.

This modification will not significantly affect the concentrations, frequencies ortypes of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Modification 02-1010 standards for design, construction, and operation of security/safeguards features for the Callaway Nuclear Plant. In summary, Modification Package 02-101 0 will:

1. Prepare the ground surfaces of the designated new PA security boundary and permanently erect the required double security fences and install other necessary security boundary physical hardware. This includes required physical isolation of gratings/openings/culverts within the zone between the inner and outer new security boundary fences.

2. Provide appropriate access points to the extended PA security boundary area.

3. Permanently install required area lighting and monitoring/detection/alarm systems.

4. Provide for covering and surface stabilization of the new PA security boundary areas adjacent and within the inner and outer security boundary fences for acceptable water runoff, as well as for functionality of detection systems.

5. Perform functional qualification of the detection and alarm systems so that proper transition to the new permanent PA security boundary and coordinated removal of the pre-modification (defunct) security boundary fences may be accomplished.

Evaluation of Change:

Description of Change:

This change is to permanently expand the protected area security boundary to encompass the area outside security fence on the eastern most (oriented to Plant North) side of the existing site protected area (PA) boundary to the portion of the Unit 2 excavation that has been backfilled in.

Under separate modification packages, various SGR support facilities, both temporary and permanent, are being erected in this backfilled area as well. Modification Package 02-1010 confines its scope to the ensuring that the permanent extension of the PA security boundary meets all required regulations, codes, and The construction activities to extend the PA security boundary undertaken by Modification Package 02-1010 will be performed in a site area that has been previously evaluated and determined to not be associated with cultural resources identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

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3.0 Non-Radiological Monitoring Program Callawav Modification 02-1 010 - continued Certain minor excavation and soil surface disturbing activities will be required to extend the PA security boundary as implemented by Modification Package 02-1010. These activities will be controlled by means appropriate to limit any potential soil erosion. The areas surrounding the security boundary fence will be surface stabilized as part of this modification. Grading of the area of the PAsecurity boundary extension will route rainfall to an acceptable water runoff pattern to account forthe effects of local intense precipitation described in Section 2.4.2.3 of the Site FSAR Addendum. Any stormwater runoff from this disturbed area will be routed through Outfall 010 or Outfall 012. Each of these stormwater outfalls are covered by an existing permit issued by the State of Missouri. As such, no additional stormwater permit is required for extending the security fence or for removal of the existing section of fence.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Modification 03-1017E Description of Change:

This modification constructs a Vehicle Barrier System (VBS) surrounding the plant site. Rows of large concrete blocks will be placed in approximately a 1 Y2mile ring around the plant site to provide a barrier to prevent unauthorized vehicle entry. This area includes the Protected Area, the Switchyard, the Central Processing Facility (CPF) and the Gas Yard. The modification also includes a new vehicle search area to be constructed plant north of the CPF. The search area will be a sally port with adequate space to contain a tractor trailer for necessary searchingprior to entry inside the VBS.

Reinforced concrete pits will be constructed at each end of the sally port and contain hydraulic lift tables that when raised up will create a road surface across the pits. The sally port will include a full canopy over the search area and the pits. It will also include a pre-fab steel building (relocated from the Owner Controlled Area Access Facility Lane 3) for environmental protection of the security officers and their specialized vehicle search equipment.

Evaluation of Change:

All work under this modification is within the Owner Controlled Area (OCA) or surrounding portions of the OCA fence and has been previously disturbed during plant construction. The only excavation to be completed will be located plant north of the CPF in the current employee parking lot or roadway to the Main Access Facility (MAF). Changes to the plant included in this modification will not affect any cultural resources.

The only excavation included for this modification will be the two concrete pits located at each end of the new search area. These are located in the current roadway directly plant north of the CPF. This entire excavation area is less than one acre and will not adversely affect stormwater runoff. Regardless of the small area disturbed, any material removed during this minor excavation will be contained or removed to prevent discharge to stormwater.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

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3.0 Non-Radiological Monitoring Program Callawav Modification 03-1017F Description of Chanae:

This revision of the plant security modification will include building new chain link fencing inside the Protected Area routed around the plant N, E, and W sides of the power block; new chain link fencing outside of the gas yard that will connect with the Plant South Protected Area (P.A.) fence; a new sidewalk along two roads inside the Protected Area; new barriers constructed inside of culvert pipes near the P. A. boundary; extending a culvert and installing earthen fill in a low drainage area plant south of the P. A.; and road widening and construction of a new section of road plant south of the gas yard (the new road will connect with the road by the cooling tower). The filling of the low area and the new road construction will involve grading and constructing earthen fill. The total area of land to be disturbed is estimated to be approximately 2 acres.

Evaluation of Change:

permitted stormwaterOuffalls. In addition all unsurfaced areas will be restored by planting.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

Callaway Modification 04-1020A Description of Change:

This modification will include the installation of a new 60 meter met tower, instrumentation and electronics to provide real time meteorological information to the plant control room in place of the existing met tower. The new tower will be located near the EOF and the existing backup met Tower and will be supported on a concrete slab. Three guide wires will be supported by concrete anchors (each 3'X5'X6' depth). The road access from Hwy CC to the current backup met tower at the EOF will also be extended (same road width) to provide an all weather road to the new met tower.

Evaluation of Change:

All work under this modification is within the Owner Controlled Area (OCA) and has been previously disturbed during plant construction.

Excavation to be completed includes digging holes for the new chain link fencing, installing new sidewalks along two existing plant roads within the protected area, installing earthen fill in a low drainage area plant south of the protected area, and road widening and construction of a new section of road plant south of the gas yard.

Changes to the plant included in this modification will not affect any cultural resources.

The estimated area of land to be disturbed is approximately two acres and is located within the OCA. Stormwater runoff will be routed to already permitted stormwater runoff ponds. Regardless of the small area disturbed, any material removed during this minor excavation will be contained or removed to prevent discharge of sediment to the As part of this evaluation for Modification Package 04-1 020A, both the ER and FES-OL were reviewed for any previously evaluated adverse environmental impacts and any adverse environmental impacts not previously evaluated.

No environmental impacts were identified. This new met tower will be replacing the existing 90 meter met tower and function to meet the requirements of Reg Guide 1.23. The original 90 meter met tower and supporting equipment were described in detail in the ER and FES-OL.

The new met tower and supporting equipment will be installed adjacent to the existing backup met tower and nearthe EOF. Marked up drawings 59

3.0 Non-Radiological Monitoring Program Callaway Modification 04-1 020A - continued showing the intended location have been reviewed by Environmental Services to confirm that no cultural resources or archeological sites are located near the area where the new met tower will be constructed. No recorded sites will be impacted by this construction as the nearest site (#303) is located approximately 750 feet NNW of this area.

Minor excavation will be required to extend the service road, run 2" conduit from the met tower to the EOF, complete the tower base and install supports for the guide wires.

These activities will be controlled by means appropriate (i.e. the use of hay bales or silt fences) to limit any potential soil erosion.

Because the total area to be disturbed is less than one half acre, no stormwater permit is required for the minor construction necessary to complete this modification.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.

View of a sunrise at Callaway Nuclear Power Plant.

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ULNRC-05141, Annual Environmental Operating Report

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TLD FM1 = MILK A

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ULNRC-05141, Annual Environmental Operating Report

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TLD FM1 = MILK A

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