ULNRC-05141, Annual Environmental Operating Report

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


Text

-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 Ladies and Gentlemen: ULNRC-05141 w'Ameren UtE 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 subsidiaryofAmeren 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 g 1Ad.

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 REMP Sample Locations I REMP Sample Collection Frequencies and Required Analysis Minimum Detection Capabilities for REMP Sample Analysis Land Use Census Results V 2004 Cross Check Results VI REMP Summary VII Airborne Beta & Iodine VlIl Airborne Gamma Composites Soil X Vegetation a Surface Water f r';

Ground Water 011 Sediments XIV Fish XV Milk XA Supplemental REMP Samples Direct Radiation XVIII X\AII 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.

1

2.0 Radiological Monitoring Program 2.1 Introduction Samples are collected from waterborne, This report presents an analysis of the results of airborne, ingestion, and direct radiation pathways.

the REMP conducted during 2004 for Union The types of sample media collected are: milk, Electric Company, Callaway Plant. surface water, ground water, shoreline sediment, bottom sediment, soil, wetlands, fish, vegetation, The radiological environmental monitoring airborne particulate, airborne radioiodine, and program began inApril 1982. direct radiation (TLD). Indicator samples are The objectives of the REMP are to monitor collected from locations which could be influenced potential critical pathways of radioactive effluent to by plant effluents. Control samples are collected man and determine the radiological impact on the at locations that are not significantly affected by environment caused by operation of Callaway plant operation.

Plant. Samples are collected by Union Electric Callaway Plant consists of one 1239 MWe personnel or contractors to Union Electric and pressurized water reactor, which achieved initial shipped to Environmental Inc. - Midwest criticality on October 2, 1984. The plant is located Laboratory (EIML) for analysis. The data is on a plateau approximately ten miles southeast of reported monthly and summarized in the annual the City of Fulton in Callaway County, Missouri and report. In2004, thermolumescent dosimeters approximately eighty miles west of the St. Louis (TLD) were analyzed by Union Electric personnel.

metropolitan area. The Missouri Riverflows by the Beginning in 2005, TLD processing will be site in an easterly direction approximately five

  • performed by a contract laboratory.

miles south of the site at its closest point.

2.3 Program Description 2.2 Program Design Sample locations for the REMP are shown in The sample locations, frequency of sampling, Figures I and 11. Table I identifies the location code, and sample analysis requirements originate from description, and sample type. Table II specifies the Callaway Plant Off Site Dose Calculation the collection frequency and required analysis.

Manual, NPDES Permit, and continuation of the Callaway Plant Pre-Operational Environmental Monitoring Program.

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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 Sample Location Sample Code Description' Types.2 Code Description' Types 2 Ia 10.8 mi. NW; City of Fulton on IDM 17 3.8 mi. E; County Road 4053,0.3 IDM Hwy Z, 0.65 mi. East of Business mi. East of Hwy 94, Kingdom 54, West of CampusApartments. Telephone Company Pole No.

3X12.

3 1.2 mi. NW; 0.1 mi. West of Hwy IDM CC on Gravel Road, 0.8 mi. South 18a 3.7 mi. ENE; East side of Hwy D, IDM Hwy 0, Callaway Electric 0.5 mi. South of 0, Callaway Cooperative Utility Pole No. 18559. Electric Cooperative Utility Pole No.38579.

5 1.3 mi. ENE; Primary IDM Meteorological Tower. 20 4.7 mi. NE; City of Readsville, IDM Callaway Electric Cooperative

- 6 2.0 mi. W; County Road 428,1.2 IDM Utility Pole No. 12830.

mi. West of Hwy CC, Callaway Electric Cooperative Utility Pole 21 3.8 mi. NNE; County Road 155, IDM No. 18609. 1.9 mi. North of Hwy 0, Callaway Electric Cooperative Utility Pole 7 1.4 mi. S; County Road 459,2.6 IDM No. 19100.

mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole 22a 1.9 mi. NNE; North side of Hwy O, IDM No.35097. 100 feet East of County Road 150, Callaway Electric Cooperative 9 3.8 mi. S; NW Side of the County IDM Utility Pole No.31094.

Road 459 and Hwy 94 Junction, Callaway Electric Cooperative 23 6.6 mi. NNE; City of Yucatan, IDM Utility Pole No. 06754. Callaway Electric Cooperative Utility Pole No. 12670.

10 3.9 mi. SSE; Hwy 94,1.8 mi. East IDM of County Road 459, Callaway 263 11.7 mi. E; Town of Americus, IDM Electric Cooperative Utility Pole Callaway Cooperative Utility Pole No. 12182. No.11159.

11a 4.7 mi. SE; City of Portland, IDM 273 9.3 mi. ESE; Town of Bluffion, IDM Callaway Electric Cooperative Callaway Electric Cooperative Utility Pole No. 12110. Utility Pole No. 11496.

14 4.9 mi. ESE; SE Side of IDM 30a 4.4 mi. SSW; City of Steedman, N IDM Intersection D and 94, Callaway side of Belgian Dr., 150 feet East Electric Cooperative Utility Pole of Hwy CC, Callaway Electric No. 11940. Cooperative Utility Pole No. 06557.

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Table I REMP Sample Locations Continued Location Sample Location Sample

- Code Description' I,ypes;Z .

Code Description' Types 2 31a 7.8 mi. SW; City of Mokane, IDM 39 5.4 mi. NW; County Road 111, IDM Junction Hwy C and County Road Callaway Electric Cooperative 400,0.9 mi. North of Hwy 94, Utility Pole No. 17516.

Callaway Electric Cooperative Utility Pole. 39a 5.0 mi. NW; County Road 111, Callaway Electric Cooperative IDM 32 5.4 mi. WSW; Hwy W, 0.6 mi. West IDM Utility Pole No. 17526.

of County Road 447, Callaway Electric Cooperative Utility Pole No. 40 4.2 mi. WNW; NE Side of IDM 27031. County Road 112 and Hwy O, Callaway Electric Cooperative 32a 5.0 mi. WSW; County Road 447, IDM Utility Pole No. 18145.

Callaway Electric Cooperative Utility Pole No. 06354. 41 4.9 mi. W; Hwy AD, 2.8 mi. East IDM of Hwy C, Callaway Electric 33 7.4 mi. W; City of Hams Prairie, SE IDM Cooperative Utility Pole No.

of Hwy C and AD Junction. 18239.

34 9.5 mi. WNW; NE Side of Hwy C IDM 42 4.4 mi. SW; County Road 447, IDM and County Road 408 Junction. 2.6 mi. North of County Road 463, Callaway Electric Cooperative 35 5.8 mi. NNW; City of Toledo, IDM Utility Pole No. 06326.

Callaway Electric Cooperative Utility Pole No. 17684. 43 0.5 mi. SW; County Road 459, IDM 0.7 mi. South of Hwy CC, 36 4.9 mi. N; County Road 155,0.8 mi. IDM Callaway Electric Cooperative South of County Road 132, Callaway Utility Pole No. 35073.

Electric Cooperative Utility Pole No.

19137. 44 1.6 mi. WSW; Hwy CC,1.0 mi. IDM South of County Road 459, 37 0.5 mi. SSW; County Road 459, IDM Callaway Electric Cooperative 0.9 mi. South of Hwy CC, Utility Pole No. 18769.

Callaway Electric Cooperative Utility Pole No. 35077. 45 1.0 mi. WNW; County Road 428, IDM 0.1 mi. West of Hwy CC, Callaway 38 4.6 mi. NNW; County Road 133, IDM Electric Cooperative Utiility Pole 1.5 mi. South of Hwy UU, No. 18580.

Callaway Electric Cooperative Utility Pole No. 34708.

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Table I REMP Sample Locations Continued Location Sample Location Sample Code Description' I[ypes - Code Description' Types2 46 1.5 mi. NNW; NE Side of Hwy CC IDM A7 9.5 mi. NW; C. Bartley Farm. APT, and County Road 466 Intersection, AIO Callaway Electric Cooperative Utility Pole No. 28242. A8 0.9 mi. NNE; County Road 448, APT, 0.9 miles South of Hwy 0. AIO 47 1.0 mi. N; County Road 448,0.9 IDM mi. South of Hwy 0, Callaway A9 1.9 mi. NNW; Community of APT, Electric Cooperative Utility Pole Reform. AIO No. 28151.

B3 1.8 mi. NNW; 0.3 mi. East of the APT, 48 0.4 mi. NE; County Road 448, 1.5 IDM O and CC Junction, Callaway AIO mi. South of Hwy 0, Plant Security Electric Cooperative Utility Pole Sign Post. No. 50422.

49 1.6 mi. E; County Road 448, IDM D01 5.0 mi. SE; Holzhouser Grocery WWA Callaway Electric Cooperative Store/Tavern (Portland, MO).

Utility Pole No. 06959, Reform Wildlife Management Parking F05 0.9 mi. SSE; Onsite WWA Area. Groundwater Monitoring Well.

50 0.9 mi. SSE; County Road IDM F15 0.4 mi. NNE; Onsite WWA 459, 3.3 mi. North of Hwy 94, Groundwater Monitoring Well.

Callaway Electric Cooperative Utility Pole No. 35086. PW1 Callaway Cafeteria. WWA 51a 0.3 mi. SE; Owner Control Fence, IDM M6 2.6 mi. NW; Pierce's Farm MLK SE of the Water Treatment Plant. (Cow's Milk).

52 0.4 mi. ESE; Light Pole Nearthe IDM M83 18.7 mi. WSW, Kissock's Farm, MLK East Plant Security Fence. South of New Bloomfield, MO (Cow's Milk).

603 13.5 mi. SW; Callaway Electric IDM Cooperative Utility Pole No. 43744 M13 2.53 mi. SSE; Miller's Farm, MLK just past Tebbetts City sign. located on Highway 448.

Al 1.3 mi. ENE; Primary APT, V33 15.0 mi. SW; Beazley Farm, SOL Meteorological Tower. AIO West of Tebbetts, MO.

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Table I REMP Sample Locations Continued Location Sample Location IISample Code Description' Tvnue 2 Code Description' Types 2 FP-V9 2.0 mi. WNW; Meehan Farm. FPL W4 0.68 mi. SSE; Callaway Plant SOL Wetlands, SW Bank.

VI0 3.4 mi. SSW; Brandt Farm. FPL W2 0.60 mi. SSE; Callaway Plant SOL VII 3.2 mi. NW; Hickman Farm. FPL Wetlands, InletArea.

V12 3 18.7 mi. WSW; Kissock's FPL WI 3 0.61 mi. SE; Callaway Plant SOL Farm, South of New Bloomfield, Wetlands, High Ground.

MO.

Vl 3s 2.02 mi. W; Buchholz's Farm, FPL W3 0.72 mi. SSE; Callaway Plant SOL County Road 428, 1.2 mi. West Wetlands, Discharge Area.

of Hwy CC.

GWS, Ground Water Sump, Plant VV0

- A3 .4 4.9 mi. SSE; 0.6 River Miles AQS, East of containment and Spent Upstream of Discharge North AQF Fuel Pool Bldg.

Bank.

936S Diesel Fuel Remediation Well, VWAA C4 4.9 mi. SE; 1.0 River Miles AQS, Plant SE of Spent Fuel Pool Bldg.

Downstream of Discharge North AQF Bank. 937C5 Monitoring Well, Plant East of VWAA Radwaste Building Drum Stor S0l34.7 mi. SSE; 105 feet Upstream SWA age.

of Discharge North Bank.

937Ds Monitoring Well, Plant South of WAA S02 4.9 mi. SE; 1.1 River Miles SWA Discharge MonitorTanks.

Downstream of Discharge North Bank. 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.

F2 1.64 mi. SW; Callaway Plant SOL 2 AIO = Air lodine, APT = Air Particulate, AQF = Fish, Forest Ecology Plot F2. AQS = Sediment, FPL = Leafy Green Vegetables, GWS = Ground Water Sump, IDM = TLD, MLK =

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

F6 1.72 mi. NE; Callaway Plant SOL. Ground Water.

Forest Ecology Plot F6. 3 Control Location.

4 The fish collection area for location "A" is PR3 1.02 mi. ESE; Callaway Plant SOL: between 0.6 and 3.0 river miles upstream of the Prairie Ecology Plot PR3. 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 PR7 0.45 mi. NNW; Callaway Plant SOL bank. The expanded collection areas are needed to guarantee there is sufficient habitat for Prairie Ecology Plant PR7. sampling to insure the ability to collect the required number of fish species.

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 AIO Weekly 1-131 weekly Air Particulate APT Weekly Gross Beta weekly 2 and Gamma Isotopic of quarterly filter composite Fish AQF Semiannually (April 1stand Oct 1st) Gamma Isotopic Sediment (Shoreline AQS Semiannually (April 1stand Oct 1st) Gamma Isotopic and Bottom) (Bottom sample NPDES requirement)

Leafy Green FPL Monthly during the Gross Alpha, Gross Beta, Vegetables growing season (2nd Tues. of month) 3 I -131, and Gamma Isotopic TLD IDM Quarterly (Ist day of each quarter) Gamma Dose Milk MLK Semimonthly when animals are 1-131 and Gamma Isotopic on pasture; monthly otherwise Soil SOL Annually (November 1st) GrossAlpha, Gross Beta Gamma Isotopic (Continuation of preoperational program)

Surface Water SWA Monthly composite (2nd Tues. of month) H-3 and Gamma Isotopic Drinking / Ground WWA Quarterly Grab (1st day of each quarter) H-3 and Gamma Isotopic Water I Samples required by ODCM and NPDES permit. 3 The growing season is defined as the months of May Additional sampling is performed as a continuation of the through November; however, the growing season will vary preoperational monitoring program. from year to year due to weather conditions.

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

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Radiological Monitoring Program 2.4 Sampling Program Execution 2.4.2 Detection and Reporting and Results Limits Table IlIl gives the minimun required detection 2.4.1 Program Modifications and limits for radiological environmental sample Exceptions analysis. For each sample type, the table lists the detection level for each isotope. The lower limit of During 2004, no significant changes were detection (LLD) used in this report is described in made to the Radiological Environmental NRC Regulatory Guide 4.1 Rev. 1, "Program for Monitoring Program. Monitoring Radioactivity in the Environs of Nuclear Power Plants" and the NRC Radiological The Radiological Environmental Monitoring Assessment Branch Technical Position, Rev. 1, Program was executed as described in the November 1979, "An Acceptable Radiological ODCM with any exceptions listed in this report. 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.

10 Q03

Table III Minimum Detection Capabilities for REMP Sample Analysis1 Food Soil and Water Airborne Fish Milk Products Sediment Analysis (pCi/1) (pCi/m 3 ) (pCi/kg wet) (pCi/1) (pCilkg wet) (pCi/kg dry)

Gross beta 4 0.01

- H-3 3000/20003 Mn-54 15 130 Fe-59 30 260 Co-58/60 15 130 Zn-65 30 260 Zr-Nb-95 2 15 1-131 1000/13 0.07 I 60 Cs-134 15 0.05 130 15 60 150 Cs-1 37 18 0.06 150 18 80 180 Ba-La-1 402 15 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 affected by plant operations) and control locations (areas not significantly affected by The vendor laboratory, Environmental Inc. -

plant discharge). A possible plant effect would Midwest Laboratory, maintains a quality be indicated if the detected level at an indicator assessment (QC) program in accordance with location was statistically greater than at the Regulatory Guide 4.15. The program includes control location.

laboratory procedures designed to prevent cross contamination and to ensure accuracy and Another method involves determining if the precision of analyses. QC checks include blind, result originated from weapons testing. The duplicate, and spiked samples as necessary to indicator or control sample result can be verify laboratory analysis activities are being compared to established environmental levels maintained at a high level of accuracy. produced from weapons testing.

The contractor laboratory participates in the Sample results can also be compared with Department of Energy's Environmental preoperational levels or samples collected in Measurements Laboratory QualityAssessment other parts of the country. Results can also be Program (EML), Mixed Analyte Performance related to events known to have caused Evaluation Program (MAPEP), and Environmental elevated levels of radiation inthe environment.

Resource Associates (ERA). The results of these cross check programs are presented in Section 2.6. 2.4.5 Waterborne Pathway The Callaway Plant Personnel Dosimetry program is accredited by the National Voluntary Surface Water LaboratoryAccreditation Program (NVLAP) of the Analysis National Institute of Standards and Technology (NIST). The Environmental TLD Program has Tritium: A 60-70 ml aliquot of water is purified demonstrated compliance with the by distillation. A portion of the distillate is recommendations of Regulatory Guide 4.13. transferred to a counting vial and scintillation Quality control checks are performed including fluid added. The contents of the vial are blanks, blind samples, daily performance checks, thoroughly mixed and counted in a liquid and quarterly cross checks. scintillation counter.

Gamma Spectrometry: Asuitable aliquotof CAR 200402348 discusses failure of a liquid sample is placed in a standard calibrated Fe-55 cross check by EIML. The investigation container and specific nuclides are identified of the failure revealed that the wrong sample and quantified using a germanium detector was used in the analysis. coupled to a computer based multichannel analyzer.

2.4.4 Data Interpretations Sampling and Frequency Sample analysis results are evaluated to Monthly composite samples of surface water determine if the result was due to the operation of from the Missouri River are collected from one the Callaway Plant or other sources. indicator location (S02) and from one control One evaluation method used is the location (SO1) and shipped to EIML for analysis.

indicator-control concept. Most sample types are collected at both indicator (areas potentially 12

Radiological Monitoring Program 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 Sampling of the Missouri River is accom-for 2004 were less than 1.5% of the reporting limit plished using an automated compositor.

Samples are collected on an hourly basis in surface water and well within regulatory and mixed to make the monthly composite requirements. Tritium results at S02 are being sample. Riversampling verifies that trended along with monthly liquid H-3 releases and Callaway Plant discharges meet stringent Missouri riverflow. The analysis results are regulatory requirements. consistent with previous operational levels and there was no significant radiological impact on the health and safety of the public or on the Results environment.

The indicator water sampler (S02) was The control water sampler (S01) was operational 96% of the time during 2004 operational 99.2% of the time in 2004. This compared to the 92% for 2003. Sampler sampler is checked weekly. Immediate actions operability is verified shiftly (every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) by use are taken to return the sampler back to service of a dial up modem. Immediate actions are taken when a problem is identified. If the sampler to return the sampler to service when a problem is cannot be returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, daily identified. If the sampler does not collect >250 grab samples are collected. Exceptions during mis per day, daily grab samples are collected and 2004 included 3 days of inoperability in July, due composited. to a scheduled power outage.

Eight of the thirteen days of indicator water The gamma analysis results for surface water sampler inoperability (S02) were due to the pump samples were consistent with previously tripping repeatedly in February (CAR accumulated data and no plant operational effects 200401298). Additional operational problems were identified.

with indicator water sampler (S02) included a Drinking / Ground Water pump leak on October 12, 2004 that caused two days of inoperability. CAR 200402341 discusses Analysis sample proportioning (D-Y) valve leakage/ Tritium: A 60-70 ml aliquot of water is purified by oscillations on May 15,2004. One day of distillation. A portion of the distillate is transferred inoperability in September was for routine sampler to a counting vial and scintillation fluid added. The 13

Radiological Monitoring Program contents of the vial are thoroughly mixed and Bottom Sediment counted in a liquid scintillation counter. Analysis Gamma Spectrometry: A suitable aliquot of Gamma Spectrometry: A suitable aliquot of prepared sample is placed in a standard prepared sample is placed in a standard calibrated container and specific nuclides are calibrated container and specific nuclides are identified and quantified using a germanium identified and quantified using a germanium detector coupled to a computer based detector coupled to a computer based multichannel analyzer. Analysis for 1-131 is multichannel analyzer.

accomplished using chemical separation followed by gas flow proportional counting techniques. Sampling and Frequency Sampling and Frequency Bottom sediment samples are collected semiannually from one indicator location (C) and Ground water samples are collected quarterly one control location (A). The samples are taken from two sampling wells (FO5 and F1 5) and two from water at least 2 meters deep to prevent drinking waterwells (DO1 and PW1). Four influence of bank erosion. A Ponar dredge is used additional shallow wells (GWS/936/937C/937D) to obtain the samples, consisting of the uppermost were added to the Callaway REMP due to positive layer of sediment. Each sample is placed, without tritium results found in these on site aquifers. The preservative, in a plastic bag, sealed and shipped samples were taken as a result of NRC to EIML for analysis.

Information Notice 2004-05, Spent Fuel Pool Leakage to Onsite Groundwater at Salem. An Results exhaustive study of the source of tritium was conducted and determined to be from recirculation The analysis results for bottom sediment of liquid effluents. The study indicated that no samples in 2004 were consistent with previously additional pathways, other than those identified in accumulated data including pre-operation and no the Callaway ODCM, were affected (CAR plant operational effects were identified.

200403826, CAR 200401807, and CAR Shoreline Sediment 200401931).

Analysis The well samples are collected using an electric pump that is located in the well. The drinking Gamma Spectrometry: Asuitable aliquot of water samples are collected from a faucet after prepared sample is placed in a standard allowing the line to flush for two minutes. The calibrated container and specific nuclides are shallow well samples are collected by Engineering identified and quantified using a germanium Surveys & Services. Samples are shipped to detector coupled to a computer based EIML for analysis. multichannel analyzer.

Results Sampling and Frequency The analysis results for all drinking/ground water Shoreline sediment samples are collected samples were consistent with previously semiannually in the same area as bottom accumulated data and no plant operational effects sediment. These samples are collected within two were identified. (Note: groundwater samples are feet of the edge of the water and consist of 2 six-analyzed with the more conservative LLD limits inch diameter by two-inch deep sediment plugs.

associated with drinking water.) 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 Cesium 137 (Cs-1 37) was detected in the samples in 2004 were consistent with previously Wetlands soil samples. Station (WI) indicated accumulated data including pre-operation and no 188 pCi/Kg dry, station (W2) indicated 79 pCi/Kg plant operational effects were identified. dry, and station (W3) indicated 169 pCi/Kg dry.

The analysis results for Wetlands soil samples in 2004 were consistent with previously

- -t -. --

-- a--

- 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 Shoreline sediment samples are collected Gross Beta: The filters are analyzed two feet from the edge of the water in the approximately five days after collection to allow for same location as the bottom sediment decay of natural short-lived radionuclides. A glass samples. Sediment samples indicate there fiber type filter is placed into a stainless steel has been no impact on the environment from Calla way Plant liquid discharges/effluents. planchet and counted for gross beta radioactivity using a proportional counter.

Wetlands Soil Iodine: Each Charcoal cartridge is placed on Analysis the germanium detector and counted. A peak of 0.36 MeV is used to calculated the concentration Gamma Spectrometry: A suitable aliquot of at counting time. The equilibrium concentration at prepared sample is placed in a standard the end of the collection is then calculated. Decay calibrated container and specific nuclides are correction for the time interval between sample identified and quantified using a germanium collection and counting is then made.

detector coupled to a computer based multichannel analyzer.

Gamma Spectrometry: Filters are composited according to location and counted using a Sampling and Frequency germanium detector coupled to a computer based multichannel analyzer. The resulting spectrum is Wetlands soil samples are collected annually analyzed by computer and specific nuclides, if from 3 indicator locations (W2, W3, and W4) and present, identified and quantified.

one control location (WI). Two 6-inch square soil plugs consisting of the uppermost two-inch layer of Sampling and Frequency soil are taken at each location. The samples are Airborne particulate samples are collected on a placed in plastic bags, sealed and shipped to 47mm diameter glass fiber filter type A/E (99 EIML analysis. 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 Gross beta activity ranged from 0.010 to 0.049 equipped with a charcoal cartridge filter in-line pCi/M 3 in all samples. The average gross beta after the particulate filter holder. activity at all locations was 0.023 pCi/M 3. In 2004, there were 17 weekly samples with gross beta The filters are collected weekly and shipped to activities greater then the base line action level of EIML for analysis.

0.037 pCi/M 3 . Gamma spectral analysis was All five sample locations are considered performed on these filters and no gamma emitting indicator locations (Al, A7, A8, A9, and B3). One isotopes of plant origin were detected.

indicator station (A9) is located at the community The analysis results for airborne samples are with the highest D/Q.

consistent with previously accumulated data and Results no plant operational effects were identified.

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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the only out of service time assigned.

Air station A8 was operational for 96.2% of the Ay)J time in 2004. A regulatorfailure during the last week of January was responsible for 163.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of inoperability (CAR 200400888), and another 168.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 Airborne samples are continuously col-time in 2004. During the sampler changeout for lected. Particulates are gathered on a glass calibration in June, the replacement sampler did fiber filter. A charcoal filter is in line after the not provide the proper sample flow rate. This particulate filter to collect iodines. Air sampler was replaced and as a result, 1.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of samples indicate the Callaway Plant has had inoperability was assigned to air station A9. no impact on the surrounding environment.

16

Radiological Monitoring Program 2.4.7 Ingestion Pathway Milk samples were not collected as scheduled on 12/14 due to unreturned phone Milk calls from the REMP participant. Samples Analysis were collected forthe month on 12/31 (CAR 200500059).

lodine-1 31: Two liters of milk containing standardized Iodine carrier is stirred with anion Location M8:

exchange resin for one hour. The resin is washed Milk samples were unavailable on 11/23 and with NaCI and the iodine is eluted with sodium 12/14 due to gestation (CAR 200500059).

Hypochlorite. Iodine in the iodate form is reduced to 12 and the elemental iodine extracted into CC14 , Location M6:

back-extracted into water, then precipitated as All samples were collected as scheduled.

palladium iodide. The precipitate is counted for Samples were collected monthly in January, 1-131 using a proportional counter. February, March, and December (stored feed). Samples were collected semimonthly Gamma Spectrometry: An aliquot of milk is for all other months since the milking animal placed in a standard counting container and was spending a portion of it's time grazing.

specific nuclides are identified and quantified using a germanium detector coupled to a The analysis results for milk samples were computer based multichannel analyzer. Analysis consistent with previously accumulated data and for 1-131 is accomplished using chemical no plant operational effects were identified.

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: Fish are collected by Union Electric biolo-Milk samples were unavailable on 1/13,1/26, gists. Fish samples indicatethere has been and 2/9 due to gestation (CAR 200400978). no impact on the environment due to opera-tion of the Callaway Plant.

17

Radiological Monitoring Program Fish counting time. The equilibrium concentration at Analysis the end of collection is calculated by decay correcting for the time interval between sample Gamma Spectrometry: A prepared sample is collection and counting.

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

commercial fish species are collected Sampling and Frequency semiannually from one indicator location (C)and one control location (A). After collection, fish Monthly during the growing season, green leafy samples are shipped on ice to EIML analysis. vegetation is collected from three indicator locations V9, V1 0, and V11 and from one control During fish sampling in October, Union location V1 2. Vegetation samples consisted of Electric Environmental Services biologists mustard greens, turnip greens, cabbage, lettuce, reported problems collecting certain species collards, radish greens, swiss chard, broccoli, and from both the control and indicator stations. For poke. Other broad leaf vegetation is requested example, smallmouth buffalo was collected from and/or collected if primary varieties are not the control location, but not at the indicator available. Samples are shipped to EIML for station. The biologists were also able to collect analysis.

several additional species at both locations.

These species included black buffalo, blue Results sucker, and shorthead redhorse. The biologists determined that black buffalo would be sent for Vegetation samples were collected as available analysis instead of the blue sucker which is from May through December due to unseasonably considered a rare species in Missouri and since milder temperatures in November and December.

it would not be a good indication of the ingestion The following indicates the months where no pathway (CAR 200408140). vegetation samples were collected:

Location V9:

Results Januarythrough May, and August.

The analysis results for fish samples were Location V1 0:

consistent with previously accumulated data and January through April, and September.

no plant operational effects were identified.

Location V1 1:

Vegetation January through May, and December Analysis Location V1 2:

Iodine-131: A suitable aliquot of wet (as January through April, and December received) sample is placed into a standard The analysis results for vegetation samples calibrated container and counted using a were consistent with previously accumulated data germanium detector coupled to a computer and no plant operational effects were identified.

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 CaSO 4 :Tm. The dosimeters are sealed in a water proof plastic bag and placed inside a Pictured is one of the forty three dosim-polypropylene mesh cylindrical holder in the eterlocations used to measure direct radia-environment. After exposure inthe environment tion. Direct radiation data indicates there has the dosimeters are read and the result is been no impact from the operation of the adjusted to a standard quarter of 90 days. For Callaway Plant.

2005, multiple UD-814 TLDs, and Optically stimulated thermolumescent dosimeters (OSLD) have been placed at each location to 2.4.9 Other Exposure Pathways evaluate this new type of dosimeter in the field.

Soil Sampling and Frequency Analysis Thermoluminescent Dosimetry (TLD) is used to determine direct radiation levels in and Gamma Spectrometry: A suitable aliquot of around the Callaway site. Forty-three prepared sample is placed in a standard dosimeters are placed in 16 sectors around the calibrated container and specific nuclides are plant as specified in the ODCM. The identified and quantified using a germanium dosimeters are read once per quarter. Three detector coupled to a computer based, locations are designated as controls (IDM26, multichannel analyzer.

IDM27 and IDMI60).

Sampling and Frequency Results Soil samples are collected annually from four Direct radiation data for IDM- 0 was indicator locations (F2, PR3, F6, and PR7) and unavailable in the second quarter. The apparent one control location (V3). To ensure only the most cause for the missing TLD was due to recent deposition is sampled, the uppermost vandalism (CAR 200406027). The TLD at two-inch layer of soil is taken at each location.

sample station IDMI 0 was promptly replaced. Samples consist of 2 six-inch square soil plugs.

The analysis results for TLD samples were The litter at the surface and the root mat is consistentwith previously accumulated data and considered part of the sample. The samples are no plant operational effects were identified. 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 REMP Supplemental Samples station V3 at 277 pCi/Kg dry, while the highest Several supplemental samples were taken indicator station result was 817 pCi/L dry.

during 2004 which were not required by FSAR-SP The analysis results for soil samples in 2004 Table 16.11-7. Samples of beef, venison, and were consistent with previously accumulated data soybeans were collected to further assess the including pre-operation and no plant operational

  • impact of plant operation on the environment effects were identified. The Cs-1 37 activity is due (CAR 200407337). The venison samples were to worldwide fallout from atmospheric nuclear taken from an animal that grazes on vegetation testing. grown within the site boundary. The soybean During a training evolution it was identified that
  • samples were taken from a field within the site the 2003 soil sample location PR3 was actually boundary. The soybean field within the site taken at the site for soil sample location PR4. boundarywas harvested for commercial Soil sample location PR4 was previously removed purposes. The beef sample was taken from a cow from the REMP (CAR200407907). GPS that has grazed on land within the site boundary.

coordinates were added to the procedure to

The samples were sent to EIML for analysis.

prevent any future reoccurence.

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

sampling is a continuation of the preoperational environmental monitoring program.

_;.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 Nearest Resident The Land Use Census is performed annually The distance of the nearest resident with the during the growing season within a five-mile radius highest D/Q was unchanged for 2004. This of the Callaway Plant. The location of the nearest resident lives 1.82 miles from the plant in the NNW resident, milking animal, and garden greater than sector. New construction was observed during the 50 m2 (500 ft2) is identified by contacting residents field inspection; however, none qualified as by phone and/or in field surveys for each of the closest resident in any of the sectors.

sixteen meteorological sectors using the midpoint of the two units. Milking Animals The Union Electric Real Estate Department No new residents with milking animals were conducted the 2004 Land Use Census in August, located in any of the sectors.

a month earlier than in 2003, for improved garden Comparison of the current REMP milk sample identification. participants with residents identified as having milking animals in the 2004 Land Use Census Results indicates that no changes are necessary.

The results of the 2004 Land Use Census are presented in Table IV. The table includes radial Vegetable Gardens direction and distance from the Callaway Plant for As was the case in 2003, a residence in sector each location. These parameters were R (NNW) with a vegetable garden was determined using a combination of map position, determined to have a 20% higher average ground aerial photography, and a Global Positioning level D/Q than current REMP sample participants.

System (GPS) receiver. 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 backgroundis the MissouriRiver.

21

Table IV 2004 Land Use Census Results Closest Receptor in Miles Sector Residence Garden 1 Milk' N(A) 2.2 4.7 NI NNE(B) 2.2 2.4 NI NE(C) 2.3 4.0 NI ENE(D) 1.7 2.9 NI E(E) 3.5 N1 ESE(F) 2.1 4.4 SE(G) 2.2 4.7 SSE(H) 2.5 2.5 2.5 S(J) 2.7 NI N!

SSW(K) 2.4 2.8 SW(L) 2.6 3.1 N1 WSW(M) 1.2 4.0 W(N) 1.6 2.0 4.0 WNW(P) 1.9 1.9 NI NW(Q) 2.1 3.2 2.6 NNW(R) 1.8 3.2 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 Reference Control Date Type Nuclide Value' Value Limits2 Result Mar-04 Water Gr. Alpha 208.00 +/- 20.70 326.00 0.55- 1.31 PASS Mar-04 Water Gr. Beta 1063.00 +/- 27.00 1170.00 0.75- 1.65 PASS Mar-04 Water Am-241 1.21+/- 0.02 1.31 0.66- 1.56 PASS Mar-04 Water Co-60 152.30 + 0.30 163.20 0.87- 1.17 PASS Mar-04 Water Cs-1 37 50.40 + 0.90 51.95 0.90- 1.25 PASS Mar-04 Water H-3 263.50 + 10.00 186.60 0.69 - 191 PASS Mar-04 Water Pu-238 1.03 +/- 0.04 1.10 0.68 - 1.33 PASS Mar-04 Water Pu-239/40 2.90 0.10 3.08 0.62-1.38 PASS Mar-04 Water Sr-90 5.20 +0.30 4.76 0.73- 1.65 PASS Mar-04 Water Uranium 4.35 +/- 0.21 4.62 0.40- 1.45 PASS Mar-04 Soil Am-241 14.1 +4.30 13.00 0.52 - 2.41 PASS Mar-04 Soil Cs-137 1292.00 +/- 13.00 1323.00 0.74-1.40 PASS Mar-04 Soil K-40 563.00 +/- 83.00 539.00 0.70- 1.59 PASS Mar-04 Soil Pu-239/40 20.70 1.10 22.82 0.62 - 1.99 PASS Mar-04 Soil Sr-90 72.10 +/- 5.80 51.00 0.58 - 2.96 PASS Mar-04 Soil Uranium 139.10 +/- 10.20 180.22 0.27 - 1.48 PASS Mar-04 Vegetation Am-241 4.50 +/- 0.20 4.93 0.58 - 2.86 PASS Mar-04 Vegetation Co-60 14.10 +/- 0.40 14.47 0.64- 1.49 PASS Mar-04 Vegetation Cs-137 573.90 + 6.00 584.67 0.75 - 1.48 PASS Mar-04 Vegetation K-40 709.00 +/- 19.30 720.00 0.45 - 1.51 PASS Mar-04 Vegetation Pu-239/40 6.60 + 0.50 6.81 0.60 - 1.98 PASS Mar-04 Vegetation Sr-90 766.50 +/- 51.30 734.00 0.50 - 1.37 PASS Mar-04 Air Filter Am-241 0.11+/- 0.01 0.10 0.62- 1.93 PASS Mar-04 Air Filter Co-60 30.90 +/- 1.08 35.40 0.74- 1.25 PASS Mar-04 Air Filter Cs-1 34 12.30 +/- 1.30 18.20 0.70- 1.21 FAIL3 Mar-04 Air Filter Cs-137 24.90 +/- 0.60 26.40 0.72- 1.32 PASS Mar-04 Air Filter Pu-238 0.04 +/- 0.01 0.04 0.61 - 1.55 PASS Mar-04 Air Filter Pu-239/40 0.17 0.02 0.16 0.67-1.58 PASS Mar-04 Air Filter Sr-90 1.80 + 0.20 1.76 0.62 - 2.26 PASS Mar-04 Air Filter Uranium 0.17 0.01 0.17 0.79 - 2.88 PASS Mar-04 Air Filter Gr. Alpha 1.09 +/- 0.06 1.20 0.82- 1.58 PASS Mar-04 Air Filter Gr. Beta 2.68 + 0.05 2.85 0.75-1.94 PASS

'Results are reported as follows: Water Bq/L, Air Filters 3 Probable effect of summation peaks and slight difference in Bq/Filter, Soil and Vegetation Bq/Kg. filter geometry.

2 Control Limits are defined by MAPEP and ERA.

23

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

'Results are reported as: Bq/Kg or Bq/L for MAPEP and 4 A spiked soil sample was prepared. Known actiivity; pCi/L for ERA. 32.98 pCi/g; laboratory result 33.47 pCi/g.

2 Control 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.

'A -+

11

Table V 2004 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits 2 Result May-04 Air Filter Gr.Alpha 0.06 +/- 0.02 0.40 0.00 - 0.80 PASS May-04 Air Filter Gr. Beta 1.37 +/- 0.08 1.20 0.60- 1.80 PASS May-04 Air Filter Am-241 0.08 +/- 0.03 0.10 0.07 - 0.13 PASS May-04 Air Filter Co-57 2.07 +/- 0.06 2.40 1.68 - 3.12 PASS May-04 Air Filter Co-60 2.11+/- 0.08 2.30 1.61 - 2.99 PASS May-04 Air Filter Cs-134 1.78 +/- 0.08 2.90 2.03 - 3.77 FAIL 3 May-04 Air Filter Cs-137 1.76 +/- 0.08 2.00 1.40 -2.60 PASS May-04 Air Filter Mn-54 2.84+/- 0.11 3.00 2.10 - 3.90 PASS May-04 Air Filter Pu-238 0.12 +/- 0.01 0.13 0.09 - 0.17 PASS May-04 Air Filter Pu-239/40 0.08 +/- 0.01 0.09 0.06 -0.12 PASS May-04 Air Filter Sr-90 0.66 +/- 0.19 0.80 0.56-1.04 PASS May-04 Air Filter U-233/4 0.23 +/- 0.03 0.21 0.15 - 0.27 PASS May-04 Air Filter U-238 0.23 +/- 0.03 0.22 0.15 - 0.29 PASS May-04 Air Filter Zn-65 3.90 +/- 0.22 4.00 2.80 - 5.20 PASS

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

2 Control 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 Water Sr-89 36.5 + 6.5 44.9 36.2 - 53.6 PASS Feb - 04 Water Sr-90 13.4 + 0.8 11.6 2.9 - 20.3 PASS Feb - 04 Water Ba-1 33 60.9 + 2.8 63.2 52.3 - 74.1 PASS Feb- 04 Water Co-60 95.2 +/- 1.5 96.4 87.7 - 105.0 PASS Feb- 04 Water Cs-134 71.2 + 5.4 75.8 67.1 - 84.5 PASS Feb- 04 Water Cs-137 157.0+/-6.5 155.0 142.0 - 168.0 PASS Feb- 04 Water Zn-65 103.0+/- 1.1 102.0 84.4-120.0 PASS Feb- 04 Water Gr. Alpha 15.6 +/- 1.2 16.6 7.9 - 25.3 PASS Feb- 04 Water Gr. Beta 46.3 +/-4.4 41.5 32.8 - 50.2 PASS Feb - 04 Water Ra-226 8.7 0.2 9.3 6.9- 11.7 PASS Feb - 04 Water Ra-228 16.6 0.4 18.2 10.3 -26.1 PASS Feb - 04 Water Uranium 34.2 0.8 33.0 27.8 - 38.2 PASS May-04 Water Sr-89 39.7 +/- 3.3 45.9 37.2 - 54.6 PASS May- 04 Water Sr-90 12.4 0.9 11.6 2.9 - 20.3 PASS May- 04 Water Ba-133 96.9 2.4 101.0 83.5 - 118.0 PASS May- 04 Water Co-60 39.9 +/- 0.5 41.6 32.9 - 50.3 PASS May- 04 Water Cs-134 48.8 +/- 0.8 50.5 41.8 - 59.2 PASS May- 04 Water Cs-137 82.6 2.3 82.5 73.8 - 91.2 PASS May- 04 Water Zn-65 77.5 1.5 75.2 62.2 - 88.2 PASS May- 04 Water Gr. Alpha 32.4 2.1 38.8 22.0 - 55.6 PASS May-04 Water Gr. Beta 63.4+/- 3.5 59.6 42.3 - 76.9 PASS May- 04 Water 1-131 25.2 +/- 0.4 25.1 19.9 - 30.3 PASS May- 04 Water Ra-226 16.0 +/- 1.1 17.3 12.8 - 21.8 PASS May- 04 Water Ra-228 12.6 +/- 0.9 10.3 5.8- 14.8 PASS May- 04 Water Uranium 13.0 +/- 0.0 12.7 7.5- 17.9 PASS May - 04 Water H-3 32043 +/- 166 30900 25600 - 36200 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 Water Sr-89 16.1 +/-1.9 20.0 11.3 - 28.7 PASS Aug - 04 Water Sr-90 13.4 0.1 13.6 4.9 - 22.3 PASS Aug - 04 Water Ba-133 30.2 + 3.9 32.1 23.4 -40.8 PASS Aug - 04 Water Co-60 24.9+/- 1.9 24.0 15.3 - 32.7 PASS Aug -04 Water Cs-134 21.4 + 3.4 21.6 12.9 - 30.3 PASS Aug - 04 Water Cs-137 205.6 + 4.3 193.0 176.0 - 210.0 PASS Aug -04 Water Zn-65 145.5 + 3.0 143.0 118.0 - 168.0 PASS Aug - 04 Water Gr. Alpha 47.7 + 9.1 57.0 32.3 - 81.7 PASS Aug -04 Water Gr. Beta 28.1 +/-2.5 20.0 11.3 - 28.7 PASS Aug - 04 Water Gr. Beta 28.1 +/-2.5 20.0 11.3 - 28.7 PASS Aug -04 Water Ra-226 6.9 0.5 6.3 4.6 - 7.9 PASS Aug -04 Water Ra-228 13.1 +/-1.4 14.7 8.3 - 21.1 PASS Aug - 04 Water Uranium 6.0 0.1 6.2 1.0 - 11.4 PASS Nov - 04 Water Sr-89 42.2 +/- 3.5 45.7 37.0 - 51.5 PASS Nov- 04 Water Sr-90 37.3 +/- 1.3 36.6 27.9 -45.3 PASS Nov - 04 Water Ba-133 75.5 0.8 78.4 64.8 - 92.0 PASS Nov- 04 Water Co-60 12.2 0.7 11.7 3.0 - 20.4 PASS Nov - 04 Water Cs-134 43.6 +/- 0.5 42.9 34.2 - 51.6 PASS Nov - 04 Water Cs-137 59.5 2.9 60.1 51.4 - 68.8 PASS Nov-04 Water Zn-65 50.7 3.2 50.9 42.1 - 59.7 PASS Nov-04 Water Gr. Alpha 23.9 +/- 2.2 31.7 18.0 -45.4 PASS Nov-04 Water Gr. Beta 35.8 +/- 1.3 36.3 27.6 -45.0 PASS Nov -04 Water 1-131 22.4 +/- 1.9 22.0 16.9 - 27.3 PASS Nov - 04 Water Ra-226 9.8 0.4 9.2 6.8 - 11.6 PASS Nov - 04 Water Ra-228 8.6 0.3 7.1 7.0- 10.2 PASS Nov- 04 Water Uranium 11.1+/- 0.3 11.4 6.2 - 16.6 PASS Nov- 04 Water H-3 21218 +/- 285 20700 17100 - 24300 PASS

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

2 Control Limits are defined by ERA.

¶27-

Radiological Monitoring Program 2.7 Data Reporting Conventions 2.8 Radiological Environmental Monitoring Program Annual Summary.

Lower Limit of Detection The REMP Summary is presented inTable VI in The lower limit of detection (LLD) used in this accordance with NRC Regulatory Guide 4.1, report is per NRC Regulatory Guide 4.1, Rev. 1, Rev. 1,"Program for Monitoring Radioactivity in "Program for Monitoring Radioactivity in the the Environs of Nuclear Power Plants", and the Environs of Nuclear Power Plants", and the NRC NRC Branch Technical Position, November Branch Technical Position, November 1979, "An 1979, "An Acceptable Radiological Acceptable Radiological Environmental Environmental Monitoring Program". Incases Monitoring Program". The LLD is defined as the where the activity is found to be below the smallest concentration of radioactivity material in a sample analysis minimum, the activity is sample that will yield a net count (above system reported as < LLD.

background) that will be detected with 95%

probability with only 5% probability of falsely With the exception of a small indication of concluding that a blank observation represents a tritium in riverwater, there was no measurable

real" signal. impact on the environment due to plant operation.

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).

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 424 (2/12) S02 424 (2/12) < LLD 0 (pCi/l) (190 - 657) 4.9 mi SE (190 - 657)

Gross Beta (24) 4 7.6 (24/24) S02 7.9 (12/12) 7.3 (12/12) 0 (5.4- 11.7) 4.9 mi SE (5.4- 11.7) SO1 4.7 Mi SSE Mn-54 (24) 15 < LLD < LLD < LLD 0 Fe-59 (24) 30 < LLD < LLD < LLD 0 Co-58/60 (24) 15 < LLD < LLD < LLD 0 Zn-65 (24) 30 < LLD < LLD < LLD 0 Zr-95 (24) 30 < LLD < LLD < LLD 0 Nb-95 (24) 15 < LLD < LLD < LLD 0 1-131 (24) 1000 < LLD < LLD < LLD 0 Cs-134 (24) 15 < LLD < LLD < LLD 0 Cs-I 37 (24) 18 < LLD < LLD < LLD 0 Ba-La-I 403 (24) 15 < LLD < LLD < LLD 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 H-3 (16) 2000 < LLD < LLD 0 Water Gross Beta (16) 4 7.1 (16/16) F05 9.8 (4/4) 0 (3.2 - 10.5) 0.9 Mi SSE (9.1 - 10.5)

(pCi/l) Mn-54 (16) 15 < LLD < LLD 0 Fe-59 (16) 30 < LLD < LLD 0 Co-58/60 (16) 15 < LLD < LLD 0 Zn-65 (16) 30 < LLD < LLD 0 Zr-95 (16) 30 < LLD < LLD 0 Nb-95 (16) 15 < LLD < LLD 0 1-131 (16) 1 < LLD < LLD 0 Cs-134 (16) 15 < LLD < LLD 0 Cs-1 37 (16) 18 < LLD < LLD 0 Ba-La-140 3 (16) 15 < LLD < LLD 0 Ingestion Pathway Vegetation 1-131 (57) 60 < LLD < LLD < LLD 0 (pCi/kg - wet) Cs-134 (57) 60 < LLD < LLD < LLD 0 Cs-1 37 (57) 80 < LLD -- < LLD < LLD 0 z-AI

( ( ( (

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 (f2 Reported Measurement) Performed (LLD)' Range Direction Range Measurements Ingestion Pathway Milk 1-131 (56) 1.0 <LLD <LLD <LLD 0 Cs-1 34 (56) 15 <LLD <LLD <LLD 0 Cs-137 (56) 18 <LLD <LLD <LLD 0 Ba-140 (56) 60 <LLD <LLD <LLD 0 La-140 (56) 15 <LLD <LLD <LLD 0 Fish Mn-54 (20) 130 <LLD <LLD <LLD 0 (pCi/kg - wet) Fe-59 (20) 260 <LLD <LLD <LLD 0 Co-58/60 (20) 130 <LLD <LLD <LLD 0 Zn-65 (20) 260 <LLD <LLD <LLD 0 Cs-134 (20) 130 <LLD <LLD <LLD 0 Cs-1 37 (20) 150 <LLD <LLD <LLD 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 Gamma (171) - 16.1 (159/160) 10 17.2 (3/4)4 15.3 (12/12) 0 (mRem/Standard Dose (10.4 -19.9) 3.9 mi. SSE (16.7- 18.1) (10.1 -19.4)

Quarter)

Airborne Pathway Airborne Particulate Gross (260) 0.010 (0.009 - 0.041) A-9 0.023 (52/52) 0 (pCi/M 3 ) Beta 1.9 mi. NNW (0.011 - 0.049) 1-131 (260) 0.070 < LLD < LLD 0 Cs-134 (17) 0.050 < LLD < LLD 0 Cs-137 (17) 0.060 < 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 (8) 150 < LLD < LLD 0 Cs-1 37 (8) 180 < LLD < LLD 0 Soil (pCi/Kg, dry) Cs-134 (18) 150 < LLD < LLD 0 Cs-137 (18) 180 388 (12/14) F2 705 (2/2) 226 (4/4) 0 (66 - 817) 1.64 Mi SW (184 - 277)

'Minimum Detection Capabilities for REMP sample analysis.

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

3 Total activity, parent plus daughter activity.

4 TLD 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 0.019 0.020 0.021 0.020 0.021 7-1 0.019 0.021 0.017 0.018 0.019 1-8 0.029 0.032 0.029 0.029 0.033 7-8 0.010 0.014 0.011 0.013 0.013 1-15 0.038 0.034 0.034 0.037 0.040 7-15 0.018 0.020 0.017 0.019 0.019 1-23 0.036 0.031 0.028 0.030 0.031 7-22 0.022 0.020 0.019 0.023 0.022 1-29 0.030 0.024 0.026 0.029 0.028  : 7-29 0.019 0.021 0.018 0.020 0.021 2-5 0.040 0.038 0.045 0.0221 0.042 8-5 0.025 0.026 0.021 0.026 0.026 2-12 0.044 0.042 0.041 0.048 0.046 8-12 0.017 0.017 0.016 0.018 0.017 2-19 0.029 0.027 0.028 0.024 0.030 8-19 0.028 0.027 0.028 0.026 0.033 2-26 0.023 0.022 0.021 0.0202 0.024 8-26 0.017 0.016 0.017 0.017 0.019 3-4 0.018 0.015 0.016 0.015 0.017 9-2 0.015 0.017 0.015 0.015 0.016 3-11 0.015 0.012 0.012 0.016 0.016 9-10 0.023 0.024 0.018 0.022 0.022 3-18 0.019 0.016 0.014 0.016 0.016 9-16 0.020 0.021 0.019 0.019 0.021 3-25 0.019 0.017 0.014 0.017 0.016 9-23 0.023 0.022 0.021 0.020 0.023 4-1 0.012 0.012 0.010 0.011 0.011 9-30 0.024 0.023 0.022 0.021 0.025 4-8 0.020 0.019 0.015 0.018 0.018 10-7 0.019 0.022 0.017 0.019 0.021 4-15 0.016 0.013 0.014 0.016 0.017 10-14 0.020 0.019 0.013 0.018 0.020 4-22 0.022 0.018 0.018 0.021 0.022 10-21 0.017 0.017 0.013 0.014 0.017 4-29 0.012 0.013 0.010 0.012 0.014 :10-28 0.018 0.018 0.015 0.018 0.020 5-6 0.019 0.018 0.013 0.015 0.017 11-4 0.012 0.014 0.013 0.012 0.013 5-13 0.024 0.0203 0.023 0.023 0.021 11-12 0.030 0.029 0.025 0.031 0.032 5-20 0.012 0.014 0.012 0.013 0.011 :11-18 0.022 0.021 0.022 0.020 0.023 5-27 0.014 0.013 0.012 0.013 0.013 :11-26 0.021 0.022 0.018 0.020 0.023 6-3 0.014 0.012 0.011 0.012 0.015 12-2 0.015 0.019 0.018 0.020 0.020 6-10 0.017 0.018 0.014 0.014 0.0174 12-10 0.038 0.041 0.037 0.041 0.049 6-17 0.017 0.014 0.011 0.014 0.018 :12-16 0.023 0.025 0.022 0.026 0.026 6-24 0.013 0.011 0.015 0.014 0.015 12-22 0.025 0.028 0.025 0.027 0.030 12-29 0.034 0.034 0.030 0.033 0.033 1Regulator 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 Table VilI (All results are the effect of natural background)

Gamma Isotopic' (pCiIm3 )

A-1 QTR1 QTR2 QTR3 QTR 4 Be-7 0.062 0.084 0.062 0.057 A-7 QTR1 QTR2 QTR3 QTR 4 Be-7 0.049 0.069 0.070 0.053 A-8 QTR1 QTR2 QTR3 QTR 4 Be-7 0.048 0.071 0.076 0.056 A-9 QTR1 QTR2 QTR3 QTR4 Be-7 0.055 0.072 0.076 0.057 B-3 QTR1 QTR2 QTR3 QTR4 Be-7 0.055 0.070 0.072 0.056 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 10,982 15,334 16,186 15,249 12,634 Gross Beta 20,390 24,596 26,872 29,434 23,288 K-40 11,507 11,184 11,731 11,639 10,861 Cs-1 37 817 592 674 642 461 PR3 PR7 PR7 V3 V3 11/2/04 11/2/04 11/2/04 11/2/04 11/2/04 Gross Alpha 10,411 12,831 14,327 11,443 9,632 Gross Beta 21,090 23,074 20,864 22,301 26,556 K40 11,004 11,291 10,753 13,831 15,780 Cs-1 37 306 311 371 254 277 WI WI W2 W2 W3 11/2/04 11/2/04 11/2/04 11/2/04 11/2/04 Gross Alpha 16,695 12,808 10,372 11,325 15,914 Gross Beta 25,746 24,022 22,886 21,775 27,655 K-40 15,377 16,151 12,981 13,376 15,454 Cs-1 37 188 184 79 66 169 W3 W4 W4 11/2/04 11/2/04 11/2/04 Gross Alpha 20,373 16,904 14,578 Gross Beta 25,382 18,885 17,590 K-40 15,445 8,726 8,506 Cs-1 37 169 ND ND

'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 6/21/04 7/12/04 7/12/04 9/13/04 Lettuce Cabbage Lettuce Cabbage Lettuce Gross Alpha 40 56 60 58 ND Gross Beta 4,152 2,794 6,845 5,108 4,709 K-40 5,133 3,473 4,592 3,081 4,468 9/13/04 9/13/04 10/13/03 10/13/03 10/13/03 Collards Mustard Lettuce Cabbage Collards Gross Alpha ND ND ND ND ND Gross Beta 4,879 4,533 3,882 4,625 4,404 K-40 4,862 5,083 4,049 2,910 3,669 10/13/03 10/13/03 10/25/04 10/25/04 10/25/04 Turnips Radish Lettuce Cabbage Collards Gross Alpha ND 131 ND ND ND Gross Beta 4,158 4,625 4,020 4,816 4,852 K-40 3,395 2,910 4,117 3,812 4,768 10/25/04 10/25/04 11/8/04 11/8/04 11/8/04 Turnips Radish Lettuce Cabbage Collards Gross Alpha ND ND 106 75 96 1

Gross Beta 4,887 3,791 4,489 3,411 4,990 K-40 4,766 3,209 4,351 2,099 4,308 1Mn-54, Co-58, Co-60, 1-131, Cs-1 34, Cs-1 37, and ND = Not Detectable.

38

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

Gamma Isotopic' (pCilkg wet)

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

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

39

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

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

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

40

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

Gamma Isotopic' (pCi/kg wet)

VII 5/10/04 5/10/04 6/7/04 6/7/04 7/13/04 Lettuce Cabbage Lettuce Swiss Chard Lettuce Gross Alpha ND ND 123 212 320 Gross Beta 4,925 3,684 5,909 6,507 4,402 K-40 4,597 3,708 6,137 6,695 3,325 7/13/04 7/13/04 8/9/04 8/9/04 9/13/04 Cabbage Broccoli Swiss Chard Broccoli Cabbage Gross Alpha 60 82 ND 150 177 Gross Beta 2,512 4,734 4,548 7,363 3,008 K-40 1,898 4,481 4,039 5,886 3,150 9/13/04 10/11/04 10/11/04 11/8/04 11/8/04 Broccoli Cabbage Turnips Cabbage Turnips Gross Alpha 175 226 93 ND ND Gross Beta 7,477 2,207 3,929 2,837 5,126 K-40 7,450 2,562 3,847 2,614 3,403 12/13/04 12/13/04 Cabbage Turnips Gross Alpha ND ND Gross Beta 2,764 5,571 K-40 3,065 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 6/8/04 7/12/04 8/9/04 9/13/04 Vegetation Poke Lettuce Cabbage Cabbage

- Gross Alpha 148 131 ND ND ND Gross Beta 6,601 7,764 6,000 3,763 3,886 K-40 6,614 6,619 4,956 3,866 4,204 10/11/04 11/8/04 Cabbage Cabbage Gross Alpha ND ND Gross Beta 3,168 3,203 K-40 3,634 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 2/11/04 3/9/04 4/13/04 5/11/04 6/8/04 Gross Alpha 2.3 2.5 3.2 2.5 2.7 4.4 Gross Beta 5.6 5.9 5.9 7.9 7.0 9.3 H-3 ND ND ND ND ND ND 7/13/04 8/10/04 9/14/04 10/12/04 11/9/04 12/15/04 Gross Alpha 4.2 5.7 4.3 3.1 2.5 1.3 Gross Beta 9.4 8.6 8.3 6.6 6.8 5.9 H-3 ND ND ND ND ND ND S02 1/13/04 2/11/04 3/9/04 4/13/04 5/11/04 6/8/04 Gross Alpha 3.3 ND 2.8 2.6 4.5 5.3 Gross Beta 5.4 6.4 7.7 6.6 7.7 8.8 H-3 ND 657 190 ND ND ND 7/13/04 8/10/04 9/14/04 10/12/04 11/9/04 12/15/04 Gross Alpha 3.9 7.0 ND 2.7 3.6 1.9 Gross Beta 10.7 11.7 8.1 7.0 9.0 6.1 H-3 ND ND ND ND ND 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 QTR2 QTR3 QTR4 All ND ND ND ND F05 QTR1 QTR2 QTR3 QTR4 All ND ND ND ND F015 QTR1 QTR2 QTR3 QTR4 All ND ND ND ND PWOO1 QTR1 QTR2 QTR 3 QTR4 All ND ND ND ND

'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 4-11 5-18 7-9 8-2 10-11 4 4 Beta 2.2 8.1 9.0 H-3 366 363 2512 399 ND 3 9361 4-11 5-18 7-9 8-2 10-11 Beta 4 4 11.1 8.9 15.2 H-3 368 406 176 429 414 937C1 4-11 5-18 7-9 8-2 10-11 4 2 Beta 4 5.5 8.7 2

H-3 164 NY ND3 199 937D1 4-11 5-18 7-9 8-2 10-11 4

Beta 4 5.6 7.7 9.2 H-3 427 304 ND3 249 NEY

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

2 No sample from this location for given date.

3 ND = 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 K-40 12,226 11,641 K-40 12,217 12,292 Cs-1 37 ND ND Cs-1 37 ND ND Shoreline Sediments A C 4/29/04 10/19/04 4/29/04 10/19/04 K-40 13,318 12,773 K-40 13,634 12,255 Cs-137 ND ND Cs-137 ND 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 4/29/04 4/29/04 4/29/04 4/29/04 Freshwater Channel Bigmouth River Carp Drum Catfish Buffalo Carpsucker

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

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

'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 1/13/04 2/10/04 3/9/04 4/13/04 4/28/04 5/11/04 K-40 1660 1,301 1,187 1,361 1,167 1,231 5/25/04 6/8/04 6/22/04 7/13/04 7/27/04 8/10/04 K-40 1,173 1,142 1,252 1,315 1,190 1,318 8/24/04 9/14/04 9/28/04 10/12/04 10/26/04 11/9/04 K-40 1,226 1,341 1,227 1,230 1,170 1,405 11/23/04 12/14/04 K-40 1,092 1,411 M8 1/13/04 1/26/04 2/9/04 3/8/04 4/12/04 4/27/04 K-40 1,387 1,313 1,296 1,375 1,371 1,245 5/10/04 5/24/04 6/7/04 6/21/04 7/12/04 7/26/04 K-40 1,328 1,159 1,225 1,177 1,348 1,370 8/9/04 8/24/04 9/14/04 9/21/04 10/12/04 10/26/04 K-40 1,266 1,228 1,275 1,456 1,233 1,100 11/9/04 K-40 1,269 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 4/12/04 4/27/04 5/10/04 5/24/04 6/7/04 K-40 1,706 1,862 1,501 1,394 1,520 1,521 6/21/04 7/12/04 7/26/04 8/10/04 8/23/04 9/13/04 K-40 1,546 1,528 1,525 1,589 1,593 1,492 9/27/04 10/12/04 10/26/04 11/8/04 12/31/04 K-40 1,408 1,295 1,605 1,288 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 2104 2 Gamma Isotopic ND ND Soybeans 7/16/04 9/28/04 Gamma Isotopic ND ND Gross Alpha 133 ND Gross Beta 4239 4035 K-40 2784 3511

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

2 Results for K-40 not reported by EIML.

50

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

Gamma Dose (mrem)

QTR1 QTR2 QTR3 QTR4 QTR1 QTR2 QTR3 QTR4 1a 14.9 16.1 14.3 16.3 34 14.6 17.4 15.6 15.9 3 17.3 17.1 15.2 17.4 35 14.2 16.8 14.4 14.6 5 12.7 15.5 12.5 14.8 36 14.7 17.5 16.1 17.8 6 16.8 18.2 14.7 17.6 37 15.7 15.5 14.9 16.3 7 15.0 17.0 14.8 14.6 38 10.4 12.4 10.5 12.3 9 14.9 16.6 14.6 16.1 39 14.5 17.0 15.8 16.4 10 16.7 16.7 18.1 39a 17.2 18.0 16.1 16.8 11a 16.7 17.2 16.5 17.5 40 15.1 18.2 16.7 18.1 14 14.6 16.2 15.4 18.5 41 16.6 15.5 15.9 16.3 17 14.4 16.2 16.2 18.0 42 11.8 14.3 13.4 14.3 18a 15.2 17.4 16.3 18.3 43 15.5 16.6 14.9 16.0 20 14.9 16.0 17.3 19.3 44 17.1 15.8 16.2 17.7 21 17.0 17.1 16.1 18.1 45 14.3 16.5 14.2 15.6 22a 15.2 15.9 16.0 16.4 46 16.4 16.1 16.2 19.9 23 15.3 16.9 16.3 16.8 47 16.8 15.0 14.2 16.7 26 10.1 12.8 11.3 12.4 48 14.8 18.5 16.3 18.5 27 17.1 16.2 17.0 19.4 49 15.5 17.0 15.5 16.2 30a 16.1 15.4 15.3 15.4 50 15.6 16.5 15.0 17.4 31a 17.8 16.9 16.3 17.4 51a 15.5 19.2 15.7 17.9 32 17.0 16.4 16.4 17.5 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 1 6116-17 4 7/1 1 7/2 4 7/29-30 4 9/1 I 9/24 4 10/1 1 10/6 £ 10/13 4 11/5

- 4 4 UHS Pond 443 349 479 Clearwell 278 321 Pond 12 <161 173 297 Pond 13 <156 Potable water <156 <157 Unit 2 Pond <161 / 224 229 215 Oily Waste Effluent 329 Oily Waste Ungrd Tk. 272 Sludge Pit 308 Supematant Sump 272 170 Settling Ponds 3/4 320 351 Equalization Basin <161 <157 71 Raw water/\WTP (river) <161 <157 Rainwater (5/13) <161 Cooling Tower Basin, <165 642 I 562 <158 <154 304 1107/1204 <172 <172 114 <159 Settling Pond 1 <158 Settling Pond 2 <158 Parking lot drainage <161 273 /203 (Unit 2 Pond efuent) 273 /203 S/G B/D NRHX <158 Service Water <158 CCWB 764 SFP Leak Detection - .1. 4 4. - 4 4.7E+07 - 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 During 2004, there were nine plant design and Union Electric Company, d.b.a.AmerenUE, in operation changes that could have involved a accordance with federal regulations and a desire potentially significant unreviewed environmental to maintain the quality of the local environment question. The interpretations and conclusions around Callaway Plant has implemented an regarding these plant changes along with a Environmental Protection Plan, (EPP) contained in description of the change are presented below.

Appendix B of the Callaway Plant Operating License. Callawav Modification 03-1017A The objective of the EPP is to provide for protection of non-radiological environmental Description of Change:

values during operation of the Callaway Plant.

This report describes the conduct of the EPP for Modification 03-1017A consists of several the Callaway Plant during 2004. improvements at the Callaway Plant gun range.

The main improvements are listed below:

1. Construct an enclosed Shooting Tower (16'xl 6' 3.2 Unusual or Important Events & elevated 35').

No unusual or important events reportable under 2. Relocate access road.

the EPP Section 4.1 were identified during 2004. 3. Construct chain link fence surrounding the perimeter of the entire range.

4. Construct classroom/office facility building 3.3 EPP Noncompliances (approx. 100' x 40'), including restroom During 2004 there were no noncompliances facilities.

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

3.4 Nonroutine Reports 6. Construct parking facility adjacent to There were no nonroutine reports submitted in classroom/office facility 7. Provide at least an accordance with the EPP, Section 5.4.2 in 2004. 8' high backstop at impact area of pop-up target range.

Evaluation of Change:

3.5 Plant Design and Operation All work underthis modification is at or Environmental Evaluations. surrounding the existing gun range. Some of this This section lists all changes in the plant design, area has been previously graded/excavated to operation, tests or experiments installed during install a moving target range, 100 yard covered 2004, which could have involved a potentially firing position, elevated 200 yard firing position, significant unreviewed environmental question in large background berm and miscellaneous accordance with section 3.1 of Appendix B. 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 "ACultural Resources Management test is planned to be conducted with no Plan for Residual Lands at the Union Electric condensate polishing. Blowdown demineralizers Company Nuclear Power Plant, Callaway County, will be used for secondary system cleanup Missouri." however; condensate polishers may be required from time to time for additional cleanup. During All construction being performed to complete the test period, MPAwill be fed to the secondary the modifications to the existing gun range system at a target feedwater concentration of 8-16 described above will require excavation of an area ppm. If operation with one condensate polisher is greater than one acre and less than 5 acres.

necessary, it is expected that MPAwill be present These areas will be controlled by appropriate in liquid radwaste discharges from polisher means to limit any potential soil erosion. All regeneration waste. This may result in a MPA excavated areas surrounding the road and training concentration of near 3 ppm in the batch releases facility will be surface stabilized as part of this via Ouffall 001. With no condensate polishing, modification. Any grading of the gun range area only insignificant quantities of MPA are expected and new road will route rainfall in an acceptable to be discharged through Outfall 001 due to minor water runoff pattern to account for the effects of system leakage.

local intense precipitation described in Section 2.4.2.3 of the Site FSAR Addendum. Stormwater Evaluation of Change:

discharge from the area disturbed to complete this modification will be discharged through a Methoxyproplyamine has not been previously permitted stormwater outfall. An application was identified in the Callaway NPDES Permit submitted to the Missouri Department of Natural Application or in the NPDES Permit. Therefore, a Resources for a Land Disturbance Storm Water letter was submitted to the Missouri Department of Permit. Natural Resources on 3/17/04 to notify them of our intended use of this product. No additional This modification will not significantly affect the authorization is required at this time. As stated in concentrations, frequencies or types of effluent the letter to DNR, the regularwhole effluent toxicity being discharged from the plant, and does not (WET) test required by our NPDES Permit will affect the current plant power level. Therefore, this also be conducted during the MPAtest program.

change does not constitute an unreviewed Should the decision be made to use MPA on a environmental question per Section 3.1 of permanent basis, the Missouri Department of Appendix B to the Callaway Plant Operating Natural Resources will be notified in writing at that License.

time.

This modification will not significantly affect the Callaway Procedure ETP-AQ-ST004. 3-concentrations, frequencies or types of effluent Methoxypropylamine Test Program being discharged from the plant, and does not affect the current plant power level. Therefore, this Description of Change: change does not constitute an unreviewed environmental question per Section 3.1 of Test procedure ETP-AQ-ST004 allows the Appendix B to the Callaway Plant Operating addition of Methoxyproplyamine (MPA) for pH License.

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 54

360 Non-Radiological Monitoring Program Callaway Modification 02-2002: licensee (AmerenUE) to the U.S. Army Corps of Engineers to satisfy requirements associated Description of Change: with construction activities performed adjacent to and affecting the Missouri River.

To prepare for Missouri River barge delivery of the Replacement Steam Generators (RSGs) for An application package for a Land the Callaway Steam Generator Replacement Disturbance Storm Water Permit (<5 acres) was (SGR), a docking facility will be constructed, and submitted to the Missouri Department of Natural required upgrades will be made to the haul route Resources and a permit was issued.

designated for transport of the RSGs from the This modification will not significantly affect the docking facility to the Callaway Plant. concentrations, frequencies or types of effluent The main activities consist of: being discharged from the plant, and does not affect the current plant power level. Therefore,

-Construction of a docking/offload facility this change does not constitute an unreviewed adjacent to the Missouri River, upstream of the environmental question per Section 3.1 of existing Callaway Plant intake structure to be Appendix B to the Callaway Plant Operating located between Missouri River mile 115.4 and License.

115.5. The docking/offload facility site is located within AmerenUE owner-controlled property. Callaway Modification 02-2003

  • Construction of a river access road from the docking/offload facility to existing State Route Description of Changae:

94, within the confines of AmerenUE owner-controlled property. This change is to construct a Steam Generator

-Construction of a permanent bridge structure Replacement Project (SGRP) Support Building over Mud Creek for transit of the transported within the Protected Area (PA) to support project RSGs from Route 94 to the Heavy Haul Road activities and forfuture plant use. The size of this (County Road 459). This permanent bridge structure will be approximately 100 feet by 110 structure will be constructed at the existing Mud feet. As an office and warehouse structure, the Creek low water crossing. SGRP Support Facility has numerous technical requirements to ensure its present and future uses will be appropriately designed for, including Evaluation of Change: factors such as building size, functionality for materials handling and materials/records Construction of the RSG docking/offload facility storage, safe occupancy of personnel, provision and upgrades to the haul route performed by and operation of equipment.

Modification Package 02-2002 will be constructed Evaluation of Change:

in a site area that has been previously surveyed, evaluated and determined to not be associated with cultural resources identified in "A Cultural The facility will be constructed in a site area Resources Management Plan for Residual Lands that has been previously disturbed, evaluated, and determined to not be associated with cultural at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri." resources identified in "A Cultural Resources Management Plan for Residual Lands at the As part of Modification Package 02-2002, an Union Electric Company Nuclear Power Plant, application was made by the Callaway Plant Callaway County, Missouri."

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3.0 Non-Radiological Monitoring Program Callaway Modification 02-2003 - Continued Callaway Modification 03-1007 Construction of the SGRP Support Facility will require excavation of the structure's foundation, Descriotion of Chanae:

and these activities will be controlled by means appropriate to limit any potential soil erosion. Modification Package 03-1007 permanently The areas surrounding the facility will be surface constructs an Old Steam Generator (OSG) stabilized as part of this modification. Grading Storage Facility (OSGSF) outside of the of the area of the SGRP Support Facility Protected Area and within the site Owner construction will route rainfall to an acceptable Controlled Area to provide temporary storage of water runoff pattern to account for the effects of the OSGs removed from the Unit 1 containment local intense precipitation described in Section as part of the Callaway Steam Generator 2.4.2.3 of the Site FSARAddendum. Any Replacement (SGR) Project.

rainwater from this disturbed area during At the election of AmerenUE, the OSGSF construction of the SGRP Support Facility that design includes an additional storage area that could result in stormwater runoff being will accommodate future temporary storage of the discharged through a point source to the waters existing reactor vessel closure head (RVCH), as of the state will be discharged through Outfall part of potential replacement of that component.

012, which is an existing Stormwater Outfall The facility also provides areas for temporary permitted by the State of Missouri. As such, no storage of miscellaneous radioactive/

additional stormwater permit is required for the radiologically contaminated materials/items construction of this facility. associated with the SGR and general plant As part of SGRP Support Facility design, operation.

connections will be made to the plant potable The facility is designed to accommodate water and sewage systems. With respect to the temporary storage until site decommissioning capacity limits for these systems described in commences, at which time the facility itself, along Section 9.2.4 of the Site FSAR Addendum, with its contents, will be decommissioned. The there are no significant increases to the duties OSGSF is located within the Owner Controlled of the potable water and sewage systems that Area on the eastern sector of the site (oriented to would result through expected use of the facility. Plant North), across from the Maintenance Shop Although SGR personnel will use the SGRP Annex.

Support Facility potable water and sewage services, the large number of personnel who Evaluation of Change:

mobilize to the site for the construction phase of the project (i.e., just priorto and immediately As part of Modification Package 03-1007, both following the SGR outage) will utilize vendor- the ER and FES-OL were reviewed for any provided drinking water and Porta-johns for previously evaluated adverse environmental these services. impacts and any adverse environmental impacts This modification will not significantly affect not previously evaluated. No such environmental the concentrations, frequencies or types of impacts were identified.

effluent being discharged from the plant, and The facility will be constructed in a site area does not affect the current plant power level. that has been previously evaluated and Therefore, this change does not constitute an determined to not be associated with cultural unreviewed environmental question per Section resources identified in "A Cultural Resources 3.1 of Appendix B to the Callaway Plant Management Plan for Residual Lands at the Operating License. Union Electric Company Nuclear Power Plant, Callaway County, Missouri."

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3.0 Non-Radiological Monitoring Program Callawav Modification 03-1007 - continued standards for design, construction, and operation of security/safeguards features for the Callaway Construction of the OSGSF will require Nuclear Plant. In summary, Modification Package excavation of the structure's foundation, and these 02-101 0 will:

activities will be controlled by means appropriate 1.Prepare the ground surfaces of the designated to limit any potential soil erosion. The areas new PA security boundary and permanently surrounding the facility will be surface stabilized as erect the required double security fences and part of this modification. Grading of the area of install other necessary security boundary the OSGSF construction will route rainfall to an physical hardware. This includes required acceptable water runoff pattern to account for the physical isolation of gratings/openings/culverts effects of local intense precipitation described in within the zone between the inner and outer new Section 2.4.2.3 of the Site FSARAddendum. The security boundary fences.

stormwater runoff will ultimately be discharged

2. Provide appropriate access points to the through outfall 014 which is a stormwater outfall in extended PA security boundary area.

our NPDES permit. The actions taken to minimize soil erosion along with the retention pond for this 3. Permanently install required area lighting and outfall will maintain all limited parameters within monitoring/detection/alarm systems.

our NPDES limits. 4. Provide for covering and surface stabilization of This modification will not significantly affect the

  • the new PA security boundary areas adjacent concentrations, frequencies ortypes of effluent and within the inner and outer security boundary being discharged from the plant, and does not fences for acceptable water runoff, as well as for affect the current plant power level. Therefore, this functionality of detection systems.

change does not constitute an unreviewed 5. Perform functional qualification of the detection environmental question per Section 3.1 of and alarm systems so that proper transition to Appendix Bto the Callaway Plant Operating the new permanent PA security boundary and License. coordinated removal of the pre-modification (defunct) security boundary fences may be Callaway Modification 02-1010 accomplished.

Evaluation of Change:

Description of Change:

This change is to permanently expand the The construction activities to extend the PA protected area security boundary to encompass security boundary undertaken by Modification the area outside security fence on the eastern Package 02-1010 will be performed in a site area most (oriented to Plant North) side of the existing that has been previously evaluated and site protected area (PA) boundary to the portion of determined to not be associated with cultural the Unit 2 excavation that has been backfilled in. resources identified in "A Cultural Resources Under separate modification packages, various Management Plan for Residual Lands at the Union SGR support facilities, both temporary and Electric Company Nuclear Power Plant, Callaway permanent, are being erected in this backfilled County, Missouri."

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 57

- 3.0 Non-Radiological Monitoring Program Callawav Modification 02-1 010 - continued Reinforced concrete pits will be constructed at Certain minor excavation and soil surface each end of the sally port and contain hydraulic lift disturbing activities will be required to extend the tables that when raised up will create a road PA security boundary as implemented by surface across the pits. The sally port will include Modification Package 02-1010. These activities a full canopy over the search area and the pits. It will be controlled by means appropriate to limit any will also include a pre-fab steel building (relocated potential soil erosion. The areas surrounding the from the Owner Controlled Area Access Facility security boundary fence will be surface stabilized Lane 3) for environmental protection of the security as part of this modification. Grading of the area of officers and their specialized vehicle search the PAsecurity boundary extension will route equipment.

rainfall to an acceptable water runoff pattern to Evaluation of Change:

account forthe effects of local intense All work under this modification is within the precipitation described in Section 2.4.2.3 of the Owner Controlled Area (OCA) or surrounding Site FSAR Addendum. Any stormwater runoff portions of the OCA fence and has been from this disturbed area will be routed through previously disturbed during plant construction. The Outfall 010 or Outfall 012. Each of these only excavation to be completed will be located stormwater outfalls are covered by an existing plant north of the CPF in the current employee permit issued by the State of Missouri. As such, parking lot or roadway to the Main Access Facility no additional stormwater permit is required for (MAF). Changes to the plant included in this extending the security fence or for removal of the modification will not affect any cultural resources.

existing section of fence.

The only excavation included for this This modification will not significantly affect the modification will be the two concrete pits located concentrations, frequencies or types of effluent at each end of the new search area. These are being discharged from the plant, and does not located in the current roadway directly plant north affect the current plant power level. Therefore, this of the CPF. This entire excavation area is less change does not constitute an unreviewed than one acre and will not adversely affect environmental question per Section 3.1 of stormwater runoff. Regardless of the small area Appendix B to the Callaway Plant Operating disturbed, any material removed during this minor License.

excavation will be contained or removed to prevent discharge to stormwater.

Callaway Modification 03-1017E This modification will not significantly affect the Description of Change: concentrations, frequencies or types of effluent being discharged from the plant, and does not This modification constructs a Vehicle Barrier affect the current plant power level. Therefore, this System (VBS) surrounding the plant site. Rows of change does not constitute an unreviewed large concrete blocks will be placed in environmental question per Section 3.1 of approximately a 1Y2mile ring around the plant site Appendix B to the Callaway Plant Operating to provide a barrier to prevent unauthorized License.

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.

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3.0 Non-Radiological Monitoring Program Callawav Modification 03-1017F permitted stormwaterOuffalls. In addition all unsurfaced areas will be restored by planting.

Description of Chanae: This modification will not significantly affect the concentrations, frequencies or types of effluent This revision of the plant security modification being discharged from the plant, and does not will include building new chain link fencing inside affect the current plant power level. Therefore, this the Protected Area routed around the plant N, E, change does not constitute an unreviewed and W sides of the power block; new chain link environmental question per Section 3.1 of fencing outside of the gas yard that will connect Appendix B to the Callaway Plant Operating with the Plant South Protected Area (P.A.) fence; a License.

new sidewalk along two roads inside the Protected Area; new barriers constructed inside of Callaway Modification 04-1020A culvert pipes near the P.A. boundary; extending a culvert and installing earthen fill in a low drainage Description of Change:

area plant south of the P.A.; and road widening and construction of a new section of road plant This modification will include the installation of a south of the gas yard (the new road will connect new 60 meter met tower, instrumentation and with the road by the cooling tower). The filling of electronics to provide real time meteorological the low area and the new road construction will information to the plant control room in place of the involve grading and constructing earthen fill. The existing met tower. The new tower will be located total area of land to be disturbed is estimated to near the EOF and the existing backup met Tower be approximately 2 acres. 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 Evaluation of Change: CC to the current backup met tower at the EOF will also be extended (same road width) to provide All work under this modification is within the an all weather road to the new met tower.

Owner Controlled Area (OCA) and has been previously disturbed during plant construction. Evaluation of Change:

Excavation to be completed includes digging holes for the new chain link fencing, installing new sidewalks along two existing plant roads within the As part of this evaluation for Modification protected area, installing earthen fill in a low Package 04-1 020A, both the ER and FES-OL drainage area plant south of the protected area, were reviewed for any previously evaluated and road widening and construction of a new adverse environmental impacts and any adverse section of road plant south of the gas yard. environmental impacts not previously evaluated.

Changes to the plant included in this modification No environmental impacts were identified. This will not affect any cultural resources. new met tower will be replacing the existing 90 meter met tower and function to meet the The estimated area of land to be disturbed is requirements of Reg Guide 1.23. The original 90 approximately two acres and is located within the meter met tower and supporting equipment were OCA. Stormwater runoff will be routed to already described in detail in the ER and FES-OL.

permitted stormwater runoff ponds. Regardless of the small area disturbed, any material removed The new met tower and supporting equipment during this minor excavation will be contained or will be installed adjacent to the existing backup removed to prevent discharge of sediment to the met tower and nearthe EOF. Marked up drawings 59

3.0 Non-Radiological Monitoring Program Callaway Modification 04-1 020A - continued

  • These activities will be controlled by means showing the intended location have been appropriate (i.e. the use of hay bales or silt reviewed by Environmental Services to confirm fences) to limit any potential soil erosion.

that no cultural resources or archeological sites Because the total area to be disturbed is less than are located near the area where the new met one half acre, no stormwater permit is required for tower will be constructed. No recorded sites will the minor construction necessary to complete this be impacted by this construction as the nearest modification.

site (#303) is located approximately 750 feet

  • This modification will not significantly affect the NNW of this area. concentrations, frequencies or types of effluent Minor excavation will be required to extend the being discharged from the plant, and does not service road, run 2" conduit from the met tower to affect the current plant power level. Therefore, this the EOF, complete the tower base and install change does not constitute an unreviewed supports for the guide wires. 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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