ULNRC-06942, Annual Radiological Environmental Operating Report January 1 to December31,2024

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Annual Radiological Environmental Operating Report January 1 to December31,2024
ML25108A173
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Site: Callaway  Ameren icon.png
Issue date: 04/17/2025
From:
Ameren Missouri, Teledyne Brown Engineering, Union Electric Co
To:
Office of Nuclear Reactor Regulation
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ML25105A171 List:
References
AM001-3EREMPCALL-24, ULNRC-06942
Download: ML25108A173 (1)


Text

dba Ameren Missouri Project No. AM001 -3EREMPCALL-24 to

ii PREFACE This Annual Radiological Environmental Operating Report (AREOR) describes the Ameren Missouri Callaway Energy Center Radiological Environmental Monitoring Program (REMP), and the program results for the calendar year 2024. It is submitted in accordance with section 5.6.2 of the Callaway Energy Center Technical Specifications.

Staff members of Teledyne Brown Engineering Laboratory in Knoxville, TN were responsible for the acquisition of data presented in this report. Environmental samples were collected by Ameren Missouri personnel or contractors to Ameren Missouri and shipped to Teledyne Brown Engineering Laboratory-Knoxville and Stanford Dosimetry, LLC, for analysis.

The report was prepared by Teledyne Brown Engineering and the Ameren Missouri Callaway Energy Center.

iii TABLE OF CONTENTS No.

Page PREFACE..................................................................................................................... ii List of Tables................................................................................................................. v List of Figures............................................................................................................... vi

1.0 INTRODUCTION

........................................................................................................... 1 2.0

SUMMARY

.................................................................................................................... 2 3.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM............................... 3 3.1 Program Design and Data Interpretation......................................................... 3 3.2 Program Description........................................................................................ 4 3.3 Program Execution.......................................................................................... 5 3.4 Laboratory Procedures.................................................................................... 7 3.5 Program Modifications..................................................................................... 8 3.6 Detection and Reporting Limits........................................................................ 8 3.7 Land Use Census............................................................................................. 8 3.8 Errata from previous AREORs........................................................................ 9 4.0 RESULTS AND DISCUSSION................................................................................... 10 4.1 Atmospheric Nuclear Detonations and Nuclear Accidents............................ 10 4.2 Program Findings........................................................................................... 10 5.0 TABLES..................................................................................................................... 13

6.0 REFERENCES

CITED................................................................................................ 25 APPENDICES A

Interlaboratory Comparison Program Results......................................................... A-1 B

Synopsis of Analytical Procedures........................................................................... B-1 C

Non-Radiological Monitoring Program..................................................................... C-1 D

Sampling Location Maps.......................................................................................... D-1

iv TABLE OF CONTENTS (continued)

PART II Page Data Tabulations and Analyses.................................................................................... ii

v LIST OF TABLES No.

Page 5.1 Sampling Locations, Ameren Missouri, Callaway Energy Center.............................. 14 5.2 Collection Frequencies and Required Analyses......................................................... 18 5.3 Minimum Required Detection Capabilities for REMP Sample Analysis..................... 19 5.4 Results of the Land Use Census................................................................................ 20 5.5 Missed Collections and Analyses............................................................................... 21 5.6 Radiological Environmental Monitoring Program Summary....................................... 22 5.7 Direct Radiation Dose (mrem/90 days) for the Period 2000-2023.............................. 24 In addition, the following tables are in the Appendices:

Appendix A A-1 Analytics Environmental Radioactivity Cross Check ProgramA-3 A-2 DOEs Mixed Analyte Performance Evaluation Program (MAPEP)...A-5 A-3 ERA Environmental Radioactivity Cross Check ProgramA-7

vi LIST OF FIGURES Appendix D No.

Page D-1 Radiological Environmental Sampling Locations 1, 2, 3 mile radius from site location................................ D-2 D-2 Radiological Environmental Sampling Locations 3, 4, 5, 6 mile radius from site location............................................................................................................... D-3 D-3 Radiological Environmental Sampling Locations 5, 10, 15 mile radius from site location...................................................................................................................... D-4 D-4 Non-Potable Groundwater Monitoring Wells, 600 ft radius....................................... D-5 D-5 Non-Potable Groundwater Monitoring Wells Collection............................................ D-6

1

1.0 INTRODUCTION

This report presents an analysis of the results of the Radiological Environmental Monitoring Program (REMP) conducted during 2024 for the Union Electric Company (dba Ameren Missouri) Callaway Energy Center.

The objectives of the REMP are to monitor potential critical pathways of radioactive effluent to man and determine the radiological impact on the environment caused by operation of the Callaway Energy Center. The Radiological Environmental Monitoring Program was initiated in April 1982.

The Callaway Energy Center consists of one 3565 MWt pressurized water reactor, which achieved initial criticality on October 2, 1984. The plant is located on a plateau approximately ten miles southeast of the City of Fulton in Callaway County, Missouri and approximately eighty miles west of the St. Louis metropolitan area. The Missouri River flows by the site in an easterly direction approximately five miles south of the site at its closest point.

Tabulation of the individual analyses for the year 2024 is included in Part II of this report.

2 2.0

SUMMARY

The Radiological Environmental Monitoring Program, as required by the U.S. Nuclear Regulatory Commission (NRC) Technical Specifications for the Callaway Energy Center is described herein.

Results for the year 2024 are summarized and discussed.

For the year, the Callaway Energy Center was operated in compliance with Offsite Dose Calculation Manual (ODCM) and Radiological Effluent Controls (REC) requirements. Results from the REMP indicate the Callaway Energy Center has had no significant radiological impact on the health and safety of the public or on the environment.

3 3.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 3.1 Program Design and Data Interpretation The purpose of the Radiological Environmental Monitoring Program at the Callaway Energy Center is to assess the impact of the plant on its environment. For this purpose, samples are collected from waterborne, airborne, ingestion and terrestrial pathways and analyzed for radioactive content.

Direct radiation levels are monitored by thermoluminescent dosimeters (TLDs).

Sources of environmental radiation can include the following:

(1)

Natural background radiation arising from cosmic rays and primordial radionuclides; (2)

Fallout from atmospheric nuclear detonations; (3)

Releases from nuclear power plants, planned or accidental; and (4)

Industrial and medical radioactive waste.

Effects due to operation of the Callaway Energy Center must be distinguished from those due to other sources in interpreting the data.

The indicator-control concept is a major interpretive aid; where feasible the design of the Callaway Energy Center program has both indicator and control stations. Most types of samples are collected at indicator locations (nearby, downwind, or downstream) and at control locations (distant, upwind, or upstream). A station effect would be indicated if the radiation level at an indicator location was significantly larger than that at the control location. The difference would have to be greater than could be accounted for by typical fluctuations in radiation levels arising from other sources.

The monitoring program includes analyses for iodine-131, a fission product, and tritium, which is produced by cosmic rays, atmospheric nuclear detonations, and also by nuclear power plants.

Most samples are analyzed for gamma-emitting isotopes, with results for the following groups quantified: zirconium-95, cesium-137, and cerium-144. These three gamma-emitting isotopes are selected as radiological impact indicators because of the different characteristic proportions in which they appear in the fission product mix produced by a nuclear reactor and that produced by a nuclear detonation. Each of the three isotopes is produced in roughly equivalent amounts by a reactor: each constitutes about 10% of the total activity of fission products ten days after reactor shutdown. On the other hand, ten days after a nuclear explosion, the contributions of zirconium-95, cerium-144, and cesium-137 to the activity of the resulting debris are in the approximate ratio 4:1:0.03 (Eisenbud,1963).

The other group quantified consists of niobium-95, ruthenium-103 and -106, cesium-134, barium-lanthanum-140, and cerium-141. These isotopes are released in small quantities by nuclear power plants, but to date their major source of injection into the general environment has been atmospheric nuclear testing. Nuclides of the next group, manganese-54, cobalt-58 and-60, and zinc-65, are activation products and arise from activation of corrosion products. They are typical components of nuclear power plant effluents but are not produced in significant quantities by nuclear detonation.

Nuclides of the final group, beryllium-7, which is of cosmogenic origin, and potassium-40, a naturally-occurring isotope, were chosen as analytical monitors and should not be considered radiological impact indicators.

Other means of distinguishing sources of environmental radiation can be employed in interpreting the data. Current radiation levels can be compared with previous levels, including pre-operational data. Results of the monitoring program can be related to those obtained in other parts of the world. Finally, results can be related to events known to cause elevated levels of radiation in the environment, e.g., a nuclear accident.

4 3.2 Program Description The sampling and analysis schedules for the environmental radiological monitoring program at the Callaway Energy Center are summarized in Tables 5.1 and 5.2 and briefly reviewed below. Table 5.1 identifies sampling locations and specifies as to type (indicator or control) and its distance, and direction relative to the reactor site. The types of samples collected at each location, required analyses and the frequency of collections are presented in Table 5.2.

To monitor the air environment, airborne particulate and airborne iodine samples are collected by continuous pumping, at six locations. The airborne particulates are collected on glass fiber filters and the airborne iodine through activated charcoal cartridges. Both filters and cartridges are exchanged weekly. Airborne particulates are analyzed for gamma-emitting isotopes. Charcoal cartridges are analyzed for iodine-131.

The ingestion pathway is monitored by sampling of milk (if available), fish and green leafy vegetation.

Milk samples are collected semimonthly when animals are on pasture and monthly the rest of the year. There were no milk indicator or control stations identified by the Land Use Census for the subject year. Milk samples are analyzed for iodine-131 and gamma-emitting isotopes when available.

Monthly during the growing season, edible green leafy vegetation is collected from both indicator and control locations. Vegetation samples typically consist of mustard greens, turnip greens, cabbage, lettuce, collards, radish greens, swiss chard, broccoli and poke. Other edible broad leaf vegetation is collected if primary varieties are not available. The samples are analyzed for iodine-131 and other gamma-emitting isotopes.

The waterborne pathway is monitored by sampling surface water, groundwater and drinking water, and shoreline sediments. Water samples are analyzed for tritium and gamma-emitting isotopes, and sediments are analyzed for gamma-emitting isotopes.

The waterborne pathway is also monitored by upstream and downstream semiannual collections of fish. The five most abundant recreational or commercial fish species are collected. The edible portions of the samples are analyzed for gamma-emitting isotopes.

Monthly composite samples of surface water from the Missouri River are collected from one indicator location (S02) and from one control location (S01). The surface water samples are composites of daily collections by automatic river samplers.

Onsite surface water from ponds is analyzed for tritium and gamma-emitting isotopes. The collection frequencies are semiannually.

To monitor possible sources of ground water contamination due to plant operations, non-potable ground water samples were collected monthly or quarterly from well locations both onsite and along the discharge pipeline. The samples were analyzed for tritium and gamma-emitting isotopes.

Potable well water samples are collected quarterly from the plant drinking water supply and neighboring property owners. The samples were analyzed for tritium and gamma-emitting isotopes.

Shoreline sediment is collected semiannually at the plant's intake (A) and discharge (C). These samples are collected within two feet of the edge of the water. The samples are analyzed for gamma-emitting isotopes.

5 3.2 Program Description (continued)

The direct ambient gamma radiation pathway is also considered. This exposure is monitored by thermoluminescent dosimeters (TLDs) at forty-four locations in and around the Callaway site. The TLDs are placed in 16 sectors around the plant as specified in the ODCM-RECS. Five of the TLD stations have neutron monitoring capability and three locations are designated as controls. TLDs are exchanged and analyzed quarterly.

Soil is collected annually from seven indicator locations (F2, F6, PR3, PR7, W2, W5 and W6) and two control locations (M9, W1) to monitor the terrestrial environment. The samples are analyzed for gamma-emitting isotopes.

3.3 Program Execution The program was executed as described in the preceding section with the following exceptions.

(1) Airborne Particulate and Iodine:

The GFCI was found tripped on 01/25/2024 at Air Station A-11. Due to low air volume, the required detection limits for Cs-134, Cs-137 and I-131 could not be met (CR# 202400564).

A potential environmental air sampler trend was discovered. During the completion of the RP Department Semi Annual Trend Report for Q3 and Q4 of 2023, a total of 5 condition reports were identified pertaining to environmental air samplers. All these condition reports were written due to air sampler equipment issues. (CR#s 202400564, 202304751, 202306177, 202305701, 202305289).

Air Station A-7 was found without power on 05/30/2024, 09/26/2024 and 10/03/2024. The samples collected on 05/30/2024 and 10/03/2024 were missed. However, the station A-7 air sample collected on 09/26/2024 was analyzed and no deviations were found (CR#s 202403920, 202406158 & 202406303).

LAS-4205-HP at Air Station 7 lost flow for some time and the sample volume was lower than typical for the 08/08/2024 sample collection at this station. The sample was analyzed, and no deviations were found (CR#202405262).

On 07/25/2024 it was found that the Air Station A-8 sampler had a broken hose, so the sample volume was lower than normal. The sample was analyzed, and no deviations were found (CR#20245036).

(2) Direct Radiation:

Posted dosimetry location changes. Stores 2 X-Ray machine has not been used for some years, and we have no plans to use it in the future, the Posted Dosimetry for this location (locations 135 & 136) are being removed from the Posted Dosimetry program. HTP-ZZ-01462-DTI-Posted Dosim, Rev 016, has been updated and published (CR#202400389).

(3) Milk Collection:

Milk samples were unable to be collected at location CA-MLK-M11 on 10/08/2024, 10/22/2024, 11/26/2024 and 12/23/2024. The new milk provider was not prepared for the commitment to provide milk samples on time and eventually changed their mind about being a provider (CR#s 202406406, 202406683, 202407288, & 202407681).

6 (4) Food Products-Leafy Green Vegetables:

There were no environmental vegetation samples available for collection in April 2024 (CR#

202402620).

Environmental vegetation sample CA-FPL-V-9 was unavailable on 08/05/2024 (CR#202405200).

(5) Drinking Water:

The drinking water at location CA-DWA-4 was unavailable on both 05/08/2024 and 08/05/2024 (CR#s 202403427 & 202405264).

(6) Surface Water:

CA-SWA-S01 was not obtainable at intake structure due to unsafe weather conditions. There was an ice storm in progress at the time. Resume grab sampling when weather permits and continue to work job to fix intake river sampler (CR#202400463).

The Intake River Sampler is leaking approximately 4 drops per min when the pump is running. The leak is in at the first connection upstream of the D-Y valve inside the cabinet.

The leak only occurs when the pump is running which is about 5 minutes every hour. The leak currently does not affect the operability of the pump (CR#202401327).

The Portland River sampler was found to be sampling at a reduced flow rate of ~15 ml (grams) per hour. The sampler has been getting the minimum volume of 250 ml (grams) for the day, but the reduced sample rate has triggered RPTS to get a daily grab sample if the 250ml is not obtained. Job 24001459 written to troubleshoot & repair. (CR#202403004).

The Portland River sampler has been trending low sample volumes since 06/27/2024. Two to eight times a day, notifications are received that sample volume is less the 18mL.

Procedurally we need a sample volume between 20mL and 30mL, currently we are still making our 250mL a day to meet the ODCM requirement (CR#202404554).

During op checks on the Portland sampler pump vault, it was determined that the water level is too high (at the base of the pump) and the Portland pump vault flooded. Job 24003233 was written to pump out the vault (CR#202406161).

Intake River sampler leakage discovered. The Intake River sampler weekly collection bottle was found at a higher level than expected (8 days worth over 7 days). When performing an op check, during manual sampling, excessive dripping was observed. Although the amount of the manual sample and weekly collection was still within a satisfactory band, troubleshooting, and/or repair/replacement of the D-Y valve needs to be completed before the O-rings completely fail. Job 24003512 was written to correct the condition. (CR#202406748).

A technician was sent to the river and found the intake river sampler to be oversampling at a rate of 32 ml per hour, which is greater than the 20-30 ml/Hr required. The sampler was shut down. A daily grab sample for 10/27/2024 was not needed since the sampler had >250 ml for the day. Job 24003513 was initiated to investigate and repair the problem.

(CR#202406778).

7 (7) Non-potable Wells:

The well samples scheduled to be collected on 02/21/24 at locations CA-WWA-U1MW-047 and CA-WWA-U1MW-005 could not be collected due to dry well conditions.

(CR#202401290).

U1MW-939R was found open during operator rounds. Technicians involved in the June sampling were interviewed and did not recall forgetting to cover the well. These wells are flush mounted and cannot be locked against inadvertent access. Therefore, inadvertent access cannot be ruled out at this time. Sent site wide communications regarding not tampering with these wells. (CR#202404848).

The well sample CA-WWA-U1MW-047 was unable to be collected on 08/07/2024 due to an insufficient water level for sampling (CR#202405412).

Analysis of CA-WWA-U1MW-017 collected on 11/15/2024 identified an isotope that was not detected historically. A back-up sample was provided for reanalysis, and the previous preliminary result was considered invalid (CR#202407531).

The well sample CA-WWA-U1MW-047 was sampled on 11/15/2024 until dry (CR#202407285).

The well sample CA-WWA-U1MW-004 was unable to be collected on 11/20/2024 because the well was dry (CR#202407285).

3.4 Laboratory Procedures Gamma-spectroscopic analyses were performed with HPGe detectors. Levels of iodine-131 in vegetation and concentrations of airborne iodine-131 in charcoal samples were also determined by gamma spectroscopy.

Tritium was measured by liquid scintillation.

The procedures and specifications followed in the laboratory for these analyses are as required in the Teledyne Brown Engineering Quality Assurance manual and are explained in the Teledyne Brown Engineering Analytical Procedures. A synopsis of analytical procedures used for the environmental samples is provided in Appendix B. In addition to internal quality control measures performed by Teledyne Brown Engineering, the laboratory also participates in an Interlaboratory Comparison Program. Participation in this program ensures that independent checks on the precision and accuracy of the measurements of radioactive material in environmental samples are performed. The results of the Interlaboratory Comparison are provided in Appendix A.

Radiological analyses of environmental media characteristically approach and frequently fall below the detection limits of state-of-the-art measurement methods. The less than values in the data tables were calculated from each specific analysis and are dependent on sample size, detector efficiency, length of counting time, chemical yield (when appropriate) and the radioactive decay factor from time of counting to time of collection. Teledyne Brown Engineerings analytical methods meet or are below the Lower Limit of Detection (LLD) requirements given in Table 2 of the USNRC Branch Technical Position, Radiological Monitoring Acceptable Program (November 1979, Revision 1). Appendix B contains a discussion of the LLD formulas.

Environmental TLDs are processed by Environmental Dosimetry Company, affiliated with Stanford Dosimetry, LLC.

8 3.5 Program Modifications Milk Collection - Restored M9 as Milk control and M11 as new milk provider near the plant. This does not meet the ODCM milk requirement, so broadleaf vegetables will still be collected. Added map to assist locating M11.

3.6 Detection and Reporting Limits Table 5.3 gives the minimum required detection limits for radiological environmental sample analysis. For each sample type, the table lists the detection level for each isotope. The lower limit of detection (LLD) used in this report is described in NRC Regulatory Guide 4.1 Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants" and the NRC Radiological Assessment Branch Technical Position, Rev. 1, November 1979, "An Acceptable Radiological Environmental Monitoring Program".

3.7 Land Use Census The Land Use Census is performed annually during the growing season. In 2024 the field inspection of the sectors was conducted October 16, 2024, within a five-mile radius of the Callaway Energy Center. The area around the plant was divided into 16 meteorological sectors. The locations of the nearest resident, nearest milk animal, and nearest garden of greater than 500 square feet producing broadleaf vegetation were identified.

The results of the census are presented in Table 5.4. The table includes radial direction and distance from the Callaway Energy Center for each location. The bearings listed in Table 5.4 were measured from the Callaway Plant to the sample location.

There are no changes to the closest residents in 2024. No milking animals were located during the survey however one resident in Sector R expressed interest in providing samples for milk. There is one new participant for garden samples in Sector H. All residents included in the summary report were verified by the Callaway County Assessors GIS aerial photography.

The Missouri Department of Natural Resources has not identified any new water wells along the Mud Creek or Logan Creek corridors.

The US Army Corps of Engineers was contacted, and they confirmed that no new drinking water intakes have been located along the Missouri River within ten (10) river miles downstream from the Callaway Plant. Also, no irrigation uses of the Missouri River were identified between the discharge point and Portland, MO during the survey.

9 3.8 Errata from previous Annual Radiological Environmental Operating Reports None.

10 4.0 RESULTS AND DISCUSSION All collections and analyses were made as scheduled, except for those listed in Table 5.5.

Results are summarized in Table 5.6 as recommended by the Nuclear Regulatory Commission.

For each type of analysis and sample medium, the table lists the mean and range of all indicator and control locations, as well as that location with the highest mean and range.

The tabulated results of all measurements are not included in this section, although references to these results will be made in the discussion. A complete tabulation of results for 2024 is contained in Part II of the Annual Report on the Radiological Environmental Monitoring Program for the Callaway Energy Center.

4.1 Atmospheric Nuclear Detonations and Nuclear Accidents The Fukushima Daiichi nuclear accident occurred March 11, 2011. There were no reported accidents involving significant release to the environment at nuclear reactor facilities in 2024. The last reported atmospheric test was conducted on October 16, 1980, by the Peoples Republic of China. There were no reported atmospheric nuclear tests in 2024.

4.2 Program Findings Airborne Particulates and Iodine No gamma-emitting isotopes were identified other than naturally occurring Be-7. There was no I-131 activity detected in any of the charcoal canister samples.

Air sampling for 2024 indicates no radiological effects of plant operation.

Direct Radiation (TLDs)

Forty-four gamma sensitive TLDs were placed in 16 sectors around the Callaway site each quarter.

Measurements from forty-one indicator locations averaged 14.53 mrem/quarter and the three control locations averaged 13.76 mrem/quarter. Readings ranged from 10.07 to 16.91 mrem

/quarter, with the highest quarterly average from the indicator location CA-IDM-10, averaging 15.93 mrem/quarter. The TLD readings were consistent with the results for the years 2000 through 2023 as detailed in table 5.7.

Five neutron sensitive TLDs were placed in locations at the Site Boundary closest to the Independent Spent Fuel Storage Facility Installation (ISFSI) and at a control location approximately 14 miles from the site. There was no significant measurable neutron dose and there was no effect from the ISFSI in 2024.

Milk No milking animals were located during the 2024 Land Use Census survey. Sampling was restored at M9 as a milk control location and M11 as a new milk provider. However, there are not enough sampling locations to fulfill the ODCM milk sampling requirement, so leafy green (broadleaf) vegetation sampling was still performed. There was no I-131 activity detected in milk samples. No gamma-emitting isotopes were detected in milk samples except for naturally occurring potassium-

40.

11 4.2 Program Findings (continued)

Broadleaf Vegetation There was no I-131 activity detected in broadleaf vegetation samples. No gamma-emitting isotopes were detected in broadleaf vegetation samples except for naturally occurring potassium-40.

Vegetation data for 2024 show no radiological effects of plant operation.

Fish Edible portions of fish were analyzed by gamma spectroscopy. No gamma-emitting isotopes, except for naturally occurring potassium-40, were detected in fish.

Soil Cesium-137 activity was detected at one of the seven indicator sample locations at a concentration of 353 pCi/kg dry. The cesium-137 activity is consistent with levels observed from 1999 through 2023; these levels are attributable to the deposition of fallout from previous decades.

Surface Water Tritium was detected in three out of the twelve samples tested in 2024 at the downstream location S02 ranging from 241 pCi/L to 326 pCI/L. No gamma-emitting isotopes were detected in any of the samples taken in 2024.

Surface Water, Ponds No tritium or gamma activity was detected in any of the twelve pond samples analyzed in 2024.

Drinking Water Wells (potable water)

Sixty-two samples from sixteen different locations were analyzed for tritium and gamma-emitting isotopes in 2024. No tritium or gamma-emitting isotopes were detected.

Wells and Ponds (non-potable water)

Eight groundwater samples from deep wells F-05 and F-15 were analyzed for tritium and gamma-emitting isotopes. No tritium or gamma emitting isotopes detected form any of the deep well samples taken in 2024.

Twenty-five samples from the wells that were part of the limited site investigation (LSI) in 2014 were analyzed for tritium in 2024 including wells CA-WWA-U1MW-031, CA-WWA-U1MW-034, CA-WWA-U1MW-036, CA-WWA-U1MW-039, CA-WWA-U1MW-047, CA-WWA-U1MW-058 and CA-WWA-U1MW-059. Tritium activity was detected in one of the wells, CA-WWA-U1MW-031 at a concentration of 321 pCi/L. These levels were a decline from 2023 and show that the contamination is being remedied by natural attenuation as described in previous AREORs.

Wells, CA-WWA-U1MW-GWS, CA-WWA-U1MW-937B, CA-WWA-U1MW-937D, CA-WWA-U1MW-939R, CA-WWA-U1MW-940, CA-WWA-U1MW-941 and CA-WWA-U1MW-IFSFI (sump) are in the Plant Protected Area adjacent to the power block. As described in previous AREORs, the tritium activity in the wells within the power block are believed to be the result of washout from gaseous effluents. The 2024 results are consistent with the results from 2015 through 2023 and demonstrate the continued decline from previous years due to natural attenuation.

12 4.2 Program Findings (continued)

Sediments Two samples of shoreline sediments were collected in March and again in October of 2024 at both an indicator and a control location and analyzed for gamma-emitting isotopes. No gamma-emitting isotopes were detected except for naturally occurring potassium-40 in any of the sediment samples.

13 5.0 TABLES

14 Table 5.1. Sampling Locations. (TLDs) Update with additions (if any) and deletions Location Distance /

Sample Code Direction 1 Description Types 2 1a 10.8 mi. 310 o NW City of Fulton on Hwy Z, 0.65 mi. E of Bus. 54, W of Campus Apartments IDM 3

1.2 mi. 308 o NW 0.1 mi. West of Hwy CC on Gravel Rd., 0.8 mi. South Hwy O IDM 5

1.3 mi. 79 o ENE Meteorological Tower IDM 6

2.0 mi. 274 o W Cty Rd. 428, 1.2 mi. West of Hwy CC IDM 7

1.4 mi. 184 o S Cty Rd. 459, 2.6 mi. North of Hwy 94 IDM 9

3.8 mi. 183 o S NW Side of the Cty Rd. 459 and Hwy 94 Junction IDM 10 3.9 mi. 159 o SSE Hwy 94, 1.8 mi. East of Cty Rd. 459 IDM 11a 4.7 mi. 139 o SE City of Portland IDM 14 4.9 mi. 122 o ESE SE Side of Intersection Hwy D and Hwy 94 IDM 17 3.7 mi. 88 o E Cty Rd. 4053, 0.3 mi. E of Hwy 94 IDM 18a 3.7 mi. 67 o ENE East side of Hwy D, 0.5 mi. South of Hwy O IDM 20 4.7 mi. 46 o NE City of Readsville IDM 21 3.8 mi. 23 o NNE Cty Rd. 155, 1.9 mi. North of Hwy O IDM 22a 0.9 mi. 10 o NNE Cty Rd 448, 0.9 mi south of HWY O, co-located with air station A8 IDM 23 6.6 mi. 15 o NNE City of Yucatan IDM 26 3 11.7 mi. 82 o E Town of Americus IDM 27 3 9.3 mi. 114 o ESE Town of Bluffton IDM 30a 4.4 mi. 206 o SSW City of Steedman, N side of Belgian Dr., 150 ft. East of Hwy CC IDM 31a 7.8 mi. 224 o SW City of Mokane, Jct. Hwy C and Cty Rd. 400, 0.9 mi. N. of Hwy 94 IDM 32 5.4 mi. 250 o WSW Hwy VV, 0.6 mi. west of Cty Rd. 447 IDM 32a 5.0 mi. 243 o WSW Cty Rd. 447 IDM 33 7.4 mi. 272 o W City of Hams Prairie, SE of Hwy C and Hwy AD Junction IDM 34 9.5 mi. 292 o WNW NE Side of Hwy C and Cty Rd. 408 Junction IDM 35 5.8 mi. 340 o NNW City of Toledo IDM 36 4.9 mi. 7 o N Cty Rd. 155, 0.8 mi. South of Cty Rd. 132 IDM 37 0.5 mi. 195 o SSW Cty Rd. 459, 0.9 mi. South of Hwy CC IDM 38 4.6 mi. 334 o NNW Cty Rd. 133, 1.5 mi. South of Hwy UU IDM 39 5.4 mi. 312 o NW Cty Rd. 111 IDM 39a 5.0 mi. 308 o NW Cty Rd. 111 IDM 40 4.2 mi. 292 o WNW NE Side of Cty Rd. 112 and Hwy O Junction IDM 41 5.2 mi. 277 o W Hwy AD, 2.5 mi. East of Hwy C IDM 42 4.4 mi. 231 o SW Cty Rd. 447, 2.6 mi. North of Cty Rd. 463 IDM 43 0.5 mi. 223 o SW Cty Rd. 459, 0.7 mi. South of Hwy CC IDM 44 1.7 mi. 254 o WSW Hwy CC, 1.0 mi. South of Cty Rd. 459 IDM 45 1.0 mi. 285 o WNW Cty Rd. 428, 0.1 mi. West of Hwy CC IDM 46 1.5 mi. 328 o NNW NE Side of Hwy CC and Cty Rd. 466 Intersection IDM 47 1.0 mi. 10 o N Cty Rd. 448, 0.9 mi. South of Hwy O IDM 48 0.4 mi. NE Cty Rd. 448, 1.5 mi. South of Hwy O, Plant Security Sign Post IDM 49 1.6 mi. 95 o E Cty Rd. 448, Reform Wildlife Mgmt. Parking Area, Gate Post.

IDM 50 0.9 mi. 168 o SSE Cty Rd. 459, 3.3 mi. North of Hwy 94 IDM 51a 0.3 mi. 150o SE Owner Control Fence, SE of the Water Treatment Plant IDM 52 0.4 mi. 111 o ESE Light Pole Near the East Plant Security Fence IDM 60 3 13.5 mi. 224 o SW Just past Tebbetts City sign IDM

15 Table 5.1. Sampling Locations. (TLDs, continued)

Location Code Distance /

Direction 1 Description Sample Types 2 60N 3 13.5 mi 224 o SW Co-located with location 60 IDM 61 1.9 mi 334 o NNW Community of Reform, Corner of CC and O IDM 61N 1.9 mi 334 o NNW Co-located with location 61 IDM 62N 1.2 mi. 308 o NW Co-located with location 3 IDM 63N 0.9 mi. 10 o NNE Co-located with air station A8 and location 22a IDM 64N 1.0 mi. 285 o WNW Co-located with location 45 IDM Table 5.1. Sampling Locations (Airborne Radioiodine and Particulate samples, Surface Ponds, Potable Water)

A1 1.3 mi. 79 o ENE Meteorological Tower APT, AIO A7 9.5 mi. 312 o NW C. Bartley Farm, Fulton, MO APT, AIO A8 0.9 mi. 10 o NNE County Road 448, 0.9 miles South of Hwy 0 APT, AIO A9 1.9 mi. 334 o NNW Community of Reform APT, AIO A10 0.89 mi 276 o W EOF Parking lot APT, AIO A11 0.71 mi 166 o SSE Sludge lagoons lift pumps area APT, AIO 3

2.9 mi. 168 o SSE Potable water, County Road 448 Ward Residence DWA 4

2.6 mi. 158 o SSE Potable water, County Road 448 Miller Residence DWA 5

2.5 mi. 153 o SSE Potable water, County Road 448 Brucker Brothers Farm DWA 7

2.1 mi. 108 o ESE Potable water, County Road 448 S. Kriete Residence DWA 8 4 3.4 mi. 193 o SSW Potable water, County Road 457 Curry Residence DWA 9

2.9 mi. 204 o SSW Potable water, County Road 457 Clardy Residence DWA 10 2.7 mi. 208 o SSW Potable water, County Road 457 T. Dillon Residence DWA 12 3.6 mi. 165 o SSE Potable water, County Road 464 J. Dillon Residence DWA 21 2.4 mi. 120 o ESE Potable water, County Road 469 Baumgarth Residence DWA 22 4.8 mi. 140 o SE Potable water, State Road 94 Plummer Residence DWA 23 5.6 mi. 142 o SE Potable water, County Road 466 Curdt Residence DWA 24 2.9 mi. 203 o SSW Potable water, County Road 457 Farley Residence DWA 25 1.89 mi. 79 o E Potable water, County Road 448 M. Kriete Residence DWA V16 1.64 mi. 255 o WSW Potable water, Hwy CC Wallendorf Farm, Steedman, MO DWA V19 3.28 MI. 162 o SSE Potable water, Dillon Drive, Dillon Farm, Portland, MO DWA PW1 Callaway Cafeteria, 0.13 mi. 234 o SW Potable water, Unit 1 Construction well #3 open from 400-1400 DWA Pond 01 0.6 mi. 264 o W Fishing Pond SWA Pond 02 0.7 mi. 232 o SW Fishing Pond SWA Outfall 010 0.6 mi. 42 o NE Stormwater Run-Off Pond SWA Wetlands 01 0.6 mi. 152 o SSE Wetlands Pond #1 SWA Wetlands 02 0.7 mi. 160 o SSE Wetlands Pond #2 SWA Sludge Lagoon

~0.8 mi. 153 o SSE 5 In-service Sludge Lagoon SWA S01 3 4.8 mi. 150 o SSE 555 feet Upstream of Discharge North Bank SWA S02 4.9 mi. 138 o SE 1.1 River Miles Downstream of Discharge North Bank SWA

16 Table 5.1. Sampling Locations, Non-potable Groundwater Wells Location Code Distance /

Direction 1 Description Sample Types 2 U1MW-937B Plant Peninsula Area, 0.04 mi. 209 o SSW Monitoring Well, West of the Turbine Bldg.

WWA U1MW-937D Plant Peninsula Area, 0.1 mi. 92 o E Monitoring Well, North of Discharge Monitor Tanks WWA U1MW-939R Plant Peninsula Area, 0.05 mi. 109 o ESE Monitoring Well, East of the Fuel Bldg.

WWA U1MW-940 Plant Peninsula Area, 0.05 mi. 78 o ENE Monitoring Well, West of the Radwaste Bldg.

WWA U1MW-941 Plant Peninsula Area, 0.07 mi. 81 o E Monitoring Well, West of the Radwaste Bldg.

WWA U1MW-GWS Plant Peninsula Area, 0.02 mi. 135 o SE Ground Water Sump, West of Reactor Bldg. and Fuel Bldg.

WWA U1MW-ISFSI ISFSI sump, 0.08 mi. 21 o NNE Near ISFSI pad WWA U1MW-004 3.7 mi. 165 o SSE South of Dillon residence, Groundwater Monitoring Well WWA U1MW-005 3.8 mi. 160 o SSE South of Brownlee / Hudson residence, Groundwater Monitoring Well WWA U1MW-006 3.0 mi. 171 o S South of Ward Residence, Groundwater Monitoring Well WWA U1MW-010 3.1 mi. 173 o S Old Pipeline Bed, Groundwater Monitoring Well WWA U1MW-013 0.8 mi. 159 o SSE Pipeline Corridor, south of sludge ponds WWA U1MW-014 3.7 mi. 171 o S Pipeline Corridor, near manhole 6B WWA U1MW-015 3.9 mi. 162 o SSE Pipeline Corridor, North of HWY 94.

WWA U1MW-016 4.5 mi. 151 o SSE Pipeline Corridor, near heavy haul road at intake structure WWA U1MW-017 3.68 mi. 171 o S Pipeline Corridor, near manhole 6B WWA U1MW-018 3.75 mi. 172 o S Pipeline Corridor, near manhole 6B WWA U1MW-019 3.71 mi.172 o S Pipeline Corridor, near manhole 5 WWA U1MW-020 3.88 mi.164 o SSE Pipeline Corridor, near manhole 3B WWA U1MW-031 0.18 mi. 78 o ENE

~1m from manhole 86-2 & 1m from HDPE discharge pipeline WWA U1MW-034 0.21 mi. 98 o E

~130m from manhole 86-2, HDPE discharge line bedding WWA U1MW-036 0.26 mi. 122 o ESE

~300m from MH 86-2, HDPE discharge line bedding at cross connection pipe WWA U1MW-039 0.61 mi. 168 o SSE

~1100m from manhole 86-2, HDPE discharge line bedding outside OCA WWA U1MW-047 4.56 mi. 151 o SSE Upstream side of HDPE gate valve vault at intake structure inside HDPE pipeline bedding WWA U1MW-058 0.31 mi. 132 o SE

~400m from manhole 86-2, Techite discharge line bedding WWA U1MW-059 1.04 mi. 166 o SSE

~1700m from MH86-2, Techite discharge line bedding outside OCA WWA U2 MW 2S 1.8 mi. 5 o N Located on the periphery of the plateau WWA U2 MW 5S 1.1 mi. 261 o W Located on the periphery of the plateau WWA U2 MW 8 0.4 mi. 12 o NNE Located radially outward from central part of the plateau WWA U2 MW 16 2.9 mi. 203 o SSW Located along Mud Creek, Farley Property, screened for CJC aquifer WWA F05 0.9 mi. 169 o S CJC aquifer monitoring well WWA F15 0.4 mi. 29 o NNE Outside OCA fence in center portion of plateau, screened for CJC aquifer WWA

17 Table 5.1. Sampling Locations, Soil, Food Products, Milk, Fish, and Sediments.

Location Code Distance /

Direction 1 Description Sample Types 2 F2 1.0 mi. 235 o SW Callaway Plant Forest Ecology Plot F2.

SOL F6 1.6 mi. 51 o NE Callaway Plant Forest Ecology Plot F6.

SOL PR3 0.95 mi. 108 o ESE Callaway Plant Forest Ecology Plot PR3.

SOL PR7 0.46 mi. 320 o NNW Callaway Plant Forest Ecology Plot PR7.

SOL W1 3 0.52 mi. 150 o SSE Callaway Plant Wetlands #1, High Ground.

SOL W2 0.55 mi. 155 o SSE Callaway Plant Wetlands #1, Inlet Area.

SOL W5

~0.8 mi. 153 o SSE5 In-service Sludge Lagoon.

SOL W6 0.67 mi. 154 o SSE Callaway Plant Wetlands #2, inlet area SOL M9 3 13 mi. 228 o SW Ferguson Farm, Tebbetts, MO.

SOL M9 3 13 mi. 228 o SW Ferguson Farm, Tebbetts, MO.

MLK M11 2.12 mi. 345 o NNW Akers Farm, Steedman, MO.

MLK V9 1.9 mi. 294 o WNW Meehan Farm, Steedman, MO FPL V16 1.64 mi. 255 o WSW Wallendorf Farm, Steedman, MO FPL V19 3.28 mi. 162 o SSE Richard and Amy Dillon Farm FPL V20 17.73 mi. 238 o WSW Nathaniel Kline, 3651 State Road AA, Holts Summit, MO FPL A 3,6

~4.8 mi. 150 o SSE Between 0.6 and 10.0 river miles upstream of the plant intake.

AQF A 3,

~4.8 mi. 150 o SSE Upstream of the plant intake.

AQS C 6

~4.9 mi. 138 o SE Downstream, of the plant discharge, between the confluence of the Missouri River and Logan Creek and the Portland boat ramp AQF C

~4.9 mi. 138 o SE Vicinity of Portland - north bank AQS 1 Distances are measured from the midpoint of the two reactors as described in Final Safety Analysis Report (FSAR) Sec.

2.1.1.1.

2 AIO = Air Iodine, APT = Air Particulate, AQF = Fish, AQS = Sediment, FPL = Leafy Green Vegetables, FC = Food Crops, IDM = TLD, MLK = Milk, SOL = Soil, SWA = Surface Water, DWA = Drinking Water, WWA = Ground Water.

3 Control Location.

4 Property ownership changed from Brandt to Curry in 2022.

5 The coordinates of the in-service sludge lagoon are determined at the time of sampling in accordance with HTP-ZZ-07101-DTI-REMP-SMPL-SCHED.

6 The expanded collection areas provide sufficient habitat to collect the required number of species, see HTP-ZZ-07101-DTI-REMP-SMPL-SCHED.

18 Table 5.2. Collection Frequencies and Required Analyses 1 (January 1 through December 31, 2024)

Sample Type Media Code Collection Frequency Required Analyses Direct radiation IDM Quarterly Gamma dose for each sample.

Neutron dose for the samples monitoring ISFSI direct radiation.

Airborne iodine AIO Weekly 131I Air particulate APT Weekly PGE3 each sample Surface water (river)

SWA Monthly composite PGE and 3H Surface water (onsite ponds)

SWA Semiannually PGE and 3H. If contaminated with gamma emitting nuclides of plant origin, analyze for HTD4 nuclides.

Groundwater (not potable)

WWA Quarterly5 PGE and 3H. If contaminated with gamma emitting nuclides of plant origin, analyze for HTD4 nuclides. 6 Well water-potable DWA Quarterly PGE and 3H. If contaminated with gamma emitting nuclides of plant origin, analyze for HTD4 nuclides.

Shoreline sediment AQS Semiannually PGE Sludge pond sediment SOL Annually PGE Soil SOL Annually PGE Milk animal MLK Semimonthly when animals are on pasture, monthly other times PGE and 131I Leafy green vegetables FPL Monthly when available 2 PGE and 131I Fish AQF Semiannually PGE on edible portion 1 Samples required by ODCM unless specified otherwise.

2 The growing season is defined as the months April 1-November 1 but will vary according to weather conditions.

3 Principal Gamma Emitters (PGE) are defined as 54Mn, 59Fe, 58Co, 60Co, 65Zn, 95Zr/Nb, 134Cs, 137Cs, 140Ba/La and other gamma-emitting nuclides that may be identified during the gamma spectroscopy analysis.

4 Hard to Detect (HTD) nuclides are defined as 89Sr, 90Sr, 55Fe, 63Ni, 237Np, 238Pu, 239/240Pu, 241Pu, 241Am, 242Cm and 243/244Cm.

5 Monthly for locations U1MW-937B, U1MW-937D, U1MW-939R, U1MW-940, U1MW-941 and U1MW-GWS.

6 Wells ISFSI Sump, U1MW-18, U1MW-19, U1MW-20, U1MW-31, U1MW-34, U1MW-36, U1MW-39, U1MW-47, U1MW-58, U1MW-59, U2MW-2S, U2MW-5S, U2MW-8, and U2MW-16 are analyzed for tritium only.

19 Table 5.3. Minimum Required Detection Capabilities for REMP Sample Analysis1 Analysis Water (pCi/L)

Airborne (pCi/m3)

Fish (pCi/kg wet)

Milk (pCi/L)

Food Products (pCi/kg wet)

Non-Food Products (pCi/kg wet)

Soil and Sediment (pCi/kg dry)

H-3 3000/20003 3000 Mn-54 15 130 Fe-59 30 260 Co-58/60 15 130 Zn-65 30 260 Zr-Nb-95 2 15 I-131 1000/13 0.07 1

60 Cs-134 15 0.05 130 15 60 60 150 Cs-137 18 0.06 150 18 80 80 180 Ba-La-140 2 15 15 1 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 I-131. The Drinking / Ground water LLDs for H-3 and I-131 are 2000 and 1 pCi/liter respectively.

20 Table 5.4 2024 Land Use Census Results.

Closest Receptor in Miles Sector Residence Garden 1, 2 Milk 1 N(A) 2.37 NI NI NNE(B) 2.16 2.97 NI NE(C) 2.26 NI NI ENE(D) 2.86 NI NI E(E) 3.51 NI NI ESE(F) 2.11 4.47 NI SE(G) 2.72 NI NI SSE(H) 3.11 3.28 NI S(J) 2.86 NI NI SSW(K) 2.38 NI NI SW(L) 2.63 2.72 NI WSW(M) 1.20 1.96 NI W(N) 1.56 3.55 NI WNW(P) 1.93 1.93 NI NW(Q) 2.07 NI NI NNW(R) 1.81 2.12 NI 1 NI = None Identified.

2 Broadleaf Vegetation

21 Table 5.5. Missed Collections and Analyses, Callaway Energy Center Sample Collection Date Type Analysis Location(s) or Period Comments WWA H-3 CA-WWA-U1MW-047 02/21/2024 No water due to dry well (CR#202401290).

WWA Gamma, H-3 CA-WWA-U1MW-005 02/21/2024 No water due to dry well (CR#202401290).

FPL Gamma (CA-FPL-V9, CA-FPL-V16, CA-FPL-V19, CA-FPL-V20)

April 2024 No environmental vegetation samples available (CR#202402620).

DWA Gamma CA-DWA-4 05/08/2024 Sample was unavailable (CR#202403427).

AIO I-131 CA-AIO-A7 05/30/2024 Air station A-7 found without power (CR#202403920).

APT Gamma CA-APT-A7 05/30/2024 Air station A-7 found without power (CR#202403920).

FPL Gamma CA-FPL-V9 08/05/2024 Sample was unavailable (CR#202405200).

DWA Gamma CA-DWA-4 08/05/2024 Sample was unavailable (CR#202405264).

WWA H-3 CA-WWA-U1MW-047 08/07/2024 Insufficient water level for sampling (CR#202405412).

AIO I-131 CA-AIO-A7 10/03/2024 Air station A-7 found without power (CR#202406303).

APT Gamma CA-APT-07 10/03/2024 Air station A-7 found without power (CR#202406303).

MLK Gamma CA-MLK-M11 10/08/2024 New milk provider was unprepared (CR#202406406).

MLK Gamma CA-MLK-M11 10/22/2024 New milk provider was unprepared (CR#202406683).

WWA H-3 CA-WWA-U1MW-047 11/15/2024 No water due to dry well (CR#202407285).

WWA Gamma, H-3 CA-WWA-U1MW-004 11/20/2024 No water due to dry well (CR#202407285).

MLK Gamma CA-MLK-M11 11/26/2024 New milk provider was unprepared (CR#202407288).

MLK Gamma CA-MLK-M11 12/23/2024 New milk provider was unprepared (CR#202407288).

22 Table 5.6 Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type and Number of Analyses(a)

Req'd LLD(b)

Indicator Locations

Mean, Fraction, Range (c)

Location with Highest Annual Mean Control Locations

Mean, Fraction, Range (c)

Number Non-Routine Results(e)

Location (d)

Mean, Fraction, Range (c)

Waterborne Pathway Surface Water (pCi/L)

H-3 24 3000 284 (3/12)

(241-326)

ND 0

GS 24 (b)

ND ND 0

Surface Water, Ponds (pCi/L)

H-3 12 3000 ND None 0

GS 12 (b)

ND None 0

Potable Wells (pCi/L)

H-3 62 2000 ND ND 0

GS 62 (b)

ND ND 0

Wells (non-potable)

(pCi/L)

H-3 171 3000 519 (25/171)

(181-919)

CA-U1MW-939R 0.05 mi. 109 o / ESE 680 (12/12)

(315-919)

None 0

GS 114 (b)

ND None 0

Sediments (pCi/kg) dry Cs-134 4

150 ND ND 0

Cs-137 4

180 ND ND 0

Airborne Pathway Airborne Particulates (pCi/m3)

GS 311 (b)

ND None 0

Airborne Iodine (pCi/m3)

I-131 311 0.07 ND None 0

Soil Soil (pCi/kg) dry Cs-134 9

150 ND ND 0

Cs-137 9

180 353 (1/7)

(353)

F-006 1.6 mi. 51 o / NE 353 (1/1)

ND 0

23 Table 5.6 Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type and Number of Analyses(a)

Req'd LLD(b)

Indicator Locations

Mean, Fraction, Range (c)

Location with Highest Annual Mean Control Locations

Mean, Fraction, Range (c)

Number Non-Routine Results(e)

Location (d)

Mean, Fraction, Range (c)

Ingestion Pathway Food Products Leafy Green Vegetables (pCi/kg wet)

GS 56 (b)

ND ND 0

Fish Edible Flesh (pCi/kg) wet GS 20 (b)

ND ND 0

Milk (pCi/L)

I-131 4

1 ND ND 0

GS 4

(b)

ND ND 0

Direct Radiation (Quarterly TLDs)

(mrem/Qtr)

Gamma 176 14.5 (164/164)

(10.1-16.9)

CA-IDM-10 3.9 mi. 159 o SSE 15.9 (3/3)

(15.5-16.5) 13.8 (12/12)

(10.0-16.7) 0 Neutron 20 ND ND 0

(a) GS = gamma spectroscopy.

(b) LLD = nominal lower limit of detection based on a 4.66 sigma counting error for background sample. LLD's for gamma spectroscopy are in Table 5.3.

(c) Mean and range are based on detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parentheses (F). ND= not detected.

(d) Locations are specified by station code (Table 5.2) and distance (miles) and direction relative to reactor site.

(e) Non-routine results are those which exceed ten times the control station value. If no control station value is available, the result is considered non-routine if it exceeds ten times the preoperational value for the location.

(f) Units: pCi/L.

24 Table 5.7 Direct Radiation Dose (mrem/90 days) for the Period 2000-2023.

Station Code Mean 3

Mean + 3 Max CA-IDM-1A 15.8 2.8 18.6 18.0 CA-IDM-3*

16.8 2.8 19.5 20.0 CA-IDM-5 14.2 2.7 16.9 17.1 CA-IDM-6 16.1 3.5 19.7 19.0 CA-IDM-7 16.0 3.1 19.1 19.0 CA-IDM-9 14.9 2.5 17.3 17.0 CA-IDM-10 16.9 2.6 19.5 19.3 CA-IDM-11A 16.9 2.9 19.8 19.3 CA-IDM-14 15.8 2.6 18.4 18.7 CA-IDM-17 15.8 3.0 18.9 18.3 CA-IDM-18A 16.0 4.3 20.3 18.9 CA-IDM-20 16.4 2.9 19.2 19.3 CA-IDM-21 16.2 3.4 19.5 19.0 CA-IDM-22A*

14.1 5.3 19.4 18.0 CA-IDM-23 16.5 2.5 19.0 19.0 CA-IDM-26(C) 11.3 2.3 13.6 13.1 CA-IDM-27(C) 17.0 2.9 19.9 20.0 CA-IDM-30A 15.6 2.7 18.2 18.2 CA-IDM-31A 16.8 2.6 19.5 19.0 CA-IDM-32 16.6 2.7 19.4 19.0 CA-IDM-32A 15.9 3.9 19.7 20.0 CA-IDM-33 15.8 2.7 18.5 18.0 CA-IDM-34 15.2 2.8 18.0 18.0 CA-IDM-35 14.6 2.6 17.2 17.3 CA-IDM-36 15.2 3.6 18.7 18.7 CA-IDM-37 15.7 2.7 18.4 18.0 CA-IDM-38 11.3 2.2 13.5 13.9 CA-IDM-39 15.6 3.2 18.8 19.0 CA-IDM-39A 16.2 3.4 19.5 19.0 CA-IDM-40 16.7 3.4 20.1 19.2 CA-IDM-41 15.6 3.2 18.7 19.0 CA-IDM-42 13.6 2.5 16.1 16.2 CA-IDM-43 15.8 2.9 18.7 18.7 CA-IDM-44 16.0 3.3 19.3 19.0 CA-IDM-45*

14.6 3.2 17.8 20.0 CA-IDM-46 16.3 2.7 19.0 19.9 CA-IDM-47 15.5 2.7 18.2 18.0 CA-IDM-48 16.4 2.9 19.3 19.0 CA-IDM-49 15.2 3.1 18.3 18.0 CA-IDM-50 16.1 3.0 19.0 20.0 CA-IDM-51A 16.9 2.7 19.6 19.8 CA-IDM-52 16.5 2.8 19.3 19.1 CA-IDM-60(C)*

15.9 2.6 18.5 18.0 CA-IDM-61*

14.2 3.8 17.9 15.7

  • ISFSI monitoring (C) Control location

25

6.0 REFERENCES

Arnold, J. R. and H. A. Al-Salih. 1955. Beryllium-7 Produced by Cosmic Rays. Science 121: 451-453.

Eisenbud, M. 1963. Environmental Radioactivity, McGraw-Hill, New York, New York, pp. 213, 275-276.

Teledyne Brown Engineering Knoxville Laboratory, 2024.

2024.

Quality Manual, Rev. 37, 31 May 2024.

Gold, S., H. W. Barkhau, B. Shlein, and B. Kahn, 1964. Measurement of Naturally Occurring Radionuclides in Air, in the Natural Environment, University of Chicago Press, Chicago, Illinois, 369-382.

Hammer, Gregory R.,Climate of Missouri, monograph available from the National Climatic Data Center (NCDC) of the National Oceanic and Atmospheric Administration (NOAA). January, 2006.

National Center for Radiological Health, 1968. Radiological Health and Data Reports, Vol. 9, Number 12, 730-746.

Stanford Dosimetry, LLC, 24 March 2024. Environmental Dosimetry Company, Annual Quality Assurance Status Report, January-December, 2024.

Teledyne Brown Engineering Environmental Services, Knoxville Laboratory 2024-2025. Environmental Radiological Monitoring Program for the Callaway Plant, Annual Report - Part II, Data Tabulations and Analyses, January

- December, 2024.

U.S. Environmental Protection Agency, 2007. RadNet, formerly Environmental Radiation Ambient Monitoring System, Gross Beta in Air (MO) 1981 - 2006, Gross Beta in Drinking Water (MO) 1982-2004.

USNRC Branch Technical Position, Radiological Monitoring Acceptable Program (November 1979, Revision 1).

Wilson, D. W., G. M. Ward and J. E. Johnson. 1969. Environmental Contamination by Radioactive Materials, International Atomic Energy Agency. p.125.

APPENDIX A

SUMMARY

OF INTRALABORATORY COMPARISONS A-1

INTERLABORATORY COMPARISION PROGRAM The purpose of the Interlaboratory Comparison Program (ICP) is to confirm the accuracy of results produced by Teledyne Brown Engineering. Samples of various matrices (i.e. soil, water, vegetation, air filters, and milk) are spiked with known amounts of radioactivity by commercial vendors of this service and by departments within the government. TBE participates in three programs. Two are commercial, Analytics Inc. and Environmental Resource Associates (ERA) and one is a government sponsored program, the Department of Energy's (DOE) Mixed Analyte Performance Evaluation Program (MAPEP). The DOE's MAPEP was created to mimic conditions found at DOE sites which do not resemble typical environmental samples obtained at commercial nuclear power facilities.

All three programs are blind performance evaluation studies in which samples with known activities are sent to TBE for analysis. Once analyzed, TBE submits the results to the respective agency for evaluation. The results of these evaluations are published in TBE's quarterly and annual QA reports.

The National Institute of Standards and Technology (NIST) is the approval authority for laboratory providers participating in Intercomparison Study Programs; however, at this

time, there are no approved laboratories for environmental and/or radiochemical isotope analyses.

For the TBE laboratory, 152 out of 167 required analyses performed met the specified acceptance criteria.

Fifteen analyses did not meet the specified acceptance criteria and were addressed through the TBE Corrective Action Program. A summary of the NCR dispositions is provided.

A-2

Month/Year Identification Number Matrix Nuclide Units TBE Reported Value Known Value (a)

Ratio of TBE to Analytics Result Evaluation (b)

March 2024 E14089 Milk Sr-89 pCi/L 79.6 78.2 1.02 A

Sr-90 pCi/L 12.6 11.9 1.06 A

E14090 Milk Ce-141 pCi/L 75.6 85.0 0.89 A

Co-58 pCi/L

-0.069 Not Measured Co-60 pCi/L 139 158 0.88 A

Cr-51 pCi/L 212 230 0.92 A

Cs-134 pCi/L 167 198 0.84 A

Cs-137 pCi/L 158 171 0.93 A

Fe-59 pCi/L 81.1 86.5 0.94 A

I-131 pCi/L 80.9 90.8 0.89 A

Mn-54 pCi/L 173 183 0.95 A

Zn-65 pCi/L 165 176 0.93 A

E14091 Charcoal I-131 pCi 90.1 90.3 1.00 A

E14092 AP Ce-141 pCi 68.1 67.5 1.01 A

Co-58 pCi 1.73 Not Measured Co-60 pCi 168 126 1.34 N(1)

Cr-51 pCi 182 183 0.99 A

Cs-134 pCi 157 157 1.00 A

Cs-137 pCi 132 136.0 0.97 A

Fe-59 pCi 70.3 68.6 1.02 A

Mn-54 pCi 144 145 0.99 A

Zn-65 pCi 125 140 0.89 A

E14093 Soil Ce-141 pCi/g 0.106 0.071 1.48 N(1)

Co-58 pCi/g

-0.005 Not Measured Co-60 pCi/g 0.121 0.133 0.91 A

Cr-51 pCi/g 0.198 0.194 1.02 A

Cs-134 pCi/g 0.206 0.166 1.24 W

Cs-137 pCi/g 0.207 0.209 0.99 A

Fe-59 pCi/g 0.063 0.073 0.87 A

Mn-54 pCi/g 0.140 0.153 0.91 A

Zn-65 pCi/g 0.149 0.148 1.01 A

E14094 AP Sr-89 pCi 83.9 90.6 0.93 A

Sr-90 pCi 11.7 13.8 0.85 A

September 2024 E14095 Milk Sr-89 pCi/L 88.0 92.3 0.95 A

Sr-90 pCi/L 12.4 15.2 0.82 A

E14096 Milk Ce-141 pCi/L 124 124 1.00 A

Co-58 pCi/L 154 150 1.03 A

Co-60 pCi/L 232 236 0.98 A

A.1 Analytics Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services (Page 1 of 6)

A-3

Month/Year Identification Number Matrix Nuclide Units TBE Reported Value Known Value (a)

Ratio of TBE to Analytics Result Evaluation (b)

A.1 Analytics Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services Cr-51 pCi/L 284 274 1.04 A

Cs-134 pCi/L 180.0 187 0.96 A

Cs-137 pCi/L 126 127 0.99 A

Fe-59 pCi/L 127.0 113 1.12 A

I-131 pCi/L 85.3 89.0 0.96 A

Mn-54 pCi/L 162 162 1.00 A

Zn-65 pCi/L 294 275 1.07 A

E14097 Charcoal I-131 pCi 98.8 92.6 1.07 A

E14098 AP Ce-141 pCi 82.0 76.7 1.07 A

Co-58 pCi 91.0 92.6 0.98 A

Co-60 pCi 180 146 1.23 W

Cr-51 pCi 208 170 1.22 W

Cs-134 pCi 116 116 1.00 A

Cs-137 pCi 83.1 78.9 1.05 A

Fe-59 pCi 75.6 70.2 1.08 A

Mn-54 pCi 101 100 1.01 A

Zn-65 pCi 167 170 0.98 A

E14099 Soil Ce-141 pCi/g 0.224 0.222 1.01 A

Co-58 pCi/g 0.249 0.268 0.93 A

Co-60 pCi/g 0.420 0.423 0.99 A

Cr-51 pCi/g 0.492 0.492 1.00 A

Cs-134 pCi/g 0.278 0.336 0.83 A

Cs-137 pCi/g 0.276 0.295 0.94 A

Fe-59 pCi/g 0.233 0.204 1.14 A

Mn-54 pCi/g 0.279 0.290 0.96 A

Zn-65 pCi/g 0.538 0.494 1.09 A

E14100 AP Sr-89 pCi 79.8 82.7 0.96 A

Sr-90 pCi 12.0 13.6 0.88 A

E14197 Liquid Gr-A (Am241) pCi/L 47.6 50.1 0.95 A

Gr-B (Cs137) pCi/L 248 270 0.92 A

(a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b)

Analytics evaluation based on TBE internal QC limits:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (Page 2 of 6)

A-4

Month/Year Identification Number Matrix Nuclide Units TBE Reported Value Known Value (a)

Acceptance Range Evaluation (b)

February 2024 24-MaS50 Soil Fe-55 Bq/kg 297 650 455 - 845 N(3)

Ni-63 Bq/kg 1070 1530 1071 - 1989 N(4)

Tc-99 Bq/kg 325 336 235 - 437 A

Th-228 Bq/kg 34.6 48.8 34.2 - 63.4 W

Th-230 Bq/kg 49.7 54.0 38.0 - 70.0 A

Th-232 Bq/kg 36.4 45.1 31.6 - 58.6 A

24-MaSU50 Urine Cs-134 Bq/L 1.12 1.36 0.95-1.77 A

Cs-137 Bq/L 2.00 2.23 1.56-2.90 A

Co-57 Bq/L 1.06 1.26 0.88 - 1.64 A

Co-60 Bq/L 2.26 2.38 1.67 - 3.09 A

K-40 Bq/L

-1.80 NR Mn-54 Bq/L 1.44 1.51 1.06 - 1.96 A

U-234 Bq/L 0.00101 (1)

A U-238 Bq/L 0.00228 (1)

A Zn-65 Bq/L

-0.42 0.84 0.59-1.09 NE(5) 24-MaW50 Water Ni-63 Bq/L 0.338 0.80 (2)

A Tc-99 Bq/L 9.95 7.47 5.23 - 9.71 N(6) 24-RdV50 Vegetation Cs-134 Bq/sample 2.80 3.67 2.57 - 4.77 W

Cs-137 Bq/sample 2.21 2.57 1.80 - 3.34 A

Co-57 Bq/sample 2.23 2.53 1.77 - 3.29 A

Co-60 Bq/sample 2.42 2.96 2.07 - 3.85 A

Mn-54 Bq/sample 0.033 (1)

A Sr-90 Bq/sample 0.276 0.529 0.370 - 0.688 N(7)

Zn-65 Bq/sample 6.83 8.02 5.61 - 10.43 A

August 2024 24-MaS51 Soil Fe-55 Bq/kg (8) 780 546-1014 N(9)

Ni-63 Bq/kg 1140.00 1450.00 1015 - 1885 W

Tc-99 Bq/kg 155.00 171.00 120 - 222 A

Th-228 Bq/kg 38.00 43.30 30.3 - 56.3 A

Th-230 Bq/kg 46.10 44.00 30.8 - 57.2 A

Th-232 Bq/kg 38.90 42.60 29.8 - 55.4 A

24-MaW51 Water Ni-63 Bq/L 0.60 (1)

A Tc-99 Bq/L 11.90 11.20 7.8 - 14.6 A

24-RdV51 Vegetation Cs-134 Bq/sample 3.12 2.89 2.02 - 3.76 A

Cs-137 Bq/sample 2.18 1.91 1.34 - 2.48 A

Co-57 Bq/sample 0.00 (1)

A Co-60 Bq/sample 2.24 2.01 1.41 - 2.61 A

Mn-54 Bq/sample 3.76 3.53 2.47 - 4.59 A

Sr-90 Bq/sample 0.95 2.39 1.67 - 3.11 N(10)

Zn-65 Bq/sample 10.30 9.13 6.39 - 11.87 A

A.2 DOE's Mixed Analyte Performance Evaluation Program (MAPEP)

Teledyne Brown Engineering Environmental Services (Page 3 of 6)

A-5

(a) The MAPEP known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) DOE/MAPEP evaluation:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (1) False positive test (2) Sensitivity evaluation (3) See CAR 23-31 (4) See NCR 24-08 (5) Not Evaluated, re-reported as Falst Pos by MAPEP (6) See NCR 24-10 (7) See NCR 24-11 (Page 4 of 6)

A-6

Month/Year Identification Number Matrix Nuclide Units TBE Reported Value Known Value (a)

Acceptance Limits Evaluation (b)

March 2024 MRAD-40 Water Am-241 pCi/L 101 139 95.4 - 178 A

Fe-55 pCi/L 2185 2480 1460- 3610 A

Pu-238 pCi/L 62.0 70.4 42.3 - 91.2 A

Pu-239 pCi/L 61.2 76.5 47.3 - 94.3 A

Soil Am-241 pCi/kg NR 1880 1020 - 2660 Pu-238 pCi/kg 667 512 255 - 778 A

Pu-239 pCi/kg 562 545 297 - 784 A

Sr-90 pCi/kg 4050 3630 1130 - 5650 A

U-234 pCi/kg 3040 4360 2040 - 5710 A

U-238 pCi/kg 3270 4320 2370 - 5800 A

AP Am-241 pCi/filter 38.8 55.0 39.3 - 73.3 N(1)

Fe-55 pCi/filter 387 386 141 - 616 A

Pu-238 pCi/filter 45.9 41.1 31.0 - 50.5 A

Pu-239 pCi/filter 54.9 56.1 41.9 - 67.7 A

U-234 pCi/filter 11.1 11.6 8.60 - 13.6 A

U-238 pCi/filter 12.8 11.5 8.68 - 13.7 A

GR-A pCi/filter 116 95.9 50.1 - 158 A

GR-B pCi/filter 42.1 22.2 13.5 - 33.5 N(2)

April 2024 RAD-137 Water Ba-133 pCi/L 62.8 65.9 50.1 - 81.7 A

Cs-134 pCi/L 51.0 57.8 42.8 - 72.8 A

Cs-137 pCi/L 153 186 149 - 223 A

Co-60 pCi/L 92.1 98.8 79.7 - 118 A

Zn-65 pCi/L 208 240 188 - 292 A

GR-A pCi/L 35.2 52.6 39.6 - 65.6 N(3)

GR-B pCi/L 49 46.5 33.9 - 59.1 A

U-Nat pCi/L 56.0 59.3 52.8-65.8 A

H-3 pCi/L 19,000 21,300 18,200 - 24,400 A

Sr-89 pCi/L 48.9 52.2 37.8 - 66.6 A

Sr-90 pCi/L 32.6 37.6 32.0 - 43.2 A

I-131 pCi/L 21.8 25.1 21.7 - 28.5 A

September 2024 MRAD-41 Water Am-241 pCi/L 108.0 117.0 80.3-150 A

Fe-55 pCi/L 615 1230 723-1790 N(4)

Pu-238 pCi/L 99 103 61.9-133 A

Pu-239 pCi/L 123 133 82.3-164 A

Soil Am-241 pCi/kg 1320 1110 599-1570 A

Pu-238 pCi/kg 1380 1860 928-2830 A

Pu-239 pCi/kg 796 1030 561-1480 A

Sr-90 pCi/kg 3240 4730 1470-7370 A

A.3 ERA Environmental Radioactivity Cross Check Program Teledyne Brown Engineering Environmental Services (Page 5 of 6)

A-7

U-234 pCi/kg 2540 2860 1340-3750 A

U-238 pCi/kg 2390 2840 1560-3810 A

AP Am-241 pCi/filter 27.0 29.1 20.8-38.8 A

Fe-55 pCi/filter 644 800 292-1280 A

Pu-238 pCi/filter 22.3 21.5 16.2-26.4 A

Pu-239 pCi/filter 30.6 32.4 24.2-39.1 A

U-234 pCi/filter 14.0 31.1 23.1-36.4 N(5)

U-238 pCi/filter 14.2 30.9 23.3-36.9 N(5)

GR-A pCi/filter 80.0 72.4 37.8-119 A

GR-B pCi/filter 57.5 47.9 29.0-72.4 A

October 2024 RAD-139 Water Ba-133 pCi/L 30.3 27.4 15.5-39.3 A

Cs-134 pCi/L 73.3 80.2 63.0-97.4 A

Cs-137 pCi/L 46.6 46.3 23.3-69.3 A

Co-60 pCi/L 44.2 45.3 31.6-59.0 A

Zn-65 pCi/L 104 114.0 75.0-153 A

GR-A pCi/L 47.6 51.7 38.9-64.5 A

GR-B pCi/L 44.2 48.1 35.2-61.0 A

U-Nat pCi/L 28.3 26.90 23.6-30.2 A

H-3 pCi/L 4,690 5,320 3870-6770 A

Sr-89 pCi/L 57.5 44.2 30.6-57.8 A

Sr-90 pCi/L 37.3 35.6 30.2-41.0 A

I-131 pCi/L 28.3 26.3 22.7-29.9 A

(a) The ERA known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation.

(b) ERA evaluation:

A = Acceptable - Reported value falls within the Acceptance Limits N = Not Acceptable - Reported value falls outside of the Acceptance Limits (1) See NCR 24-02 (2) See NCR 24-03 (3) See NCR 24-05 (4) See NCR 24-15 (Page 6 of 6)

A-8

A.

NCR 24-02: ERA March MRAD-40 study with Air Particulate AM-241 evaluated as Not Acceptable. TBE reported 38.8 pCi/filter and the known value returned at 55.0 pCi/filter (range 39.3-73.3). The root cause investigation determined that the sample was not logged into the system correctly and therefore not prepared with the required tracer. To correct and prevent recurrence, personnel involved are to utilize a template to ensure all analyses are logged as required and the QA Manager will perform sample log review as a back up to ensure accuracy.

Acceptable results returned in a later sample study, supporting effectiveness of corrective action.

B.

NCR 24-03: ERA March MRAD-40 air particulate study GR-B evaluated as Not Acceptable. TBE reported 42.1 pCi/filter and the known value returned at 22.2 pCi/filter (range 13.5-33.5). The root cause investigation determined that alpha-to-beta crosstalk was more significant than normal which caused the beta activity to report falsely high data. To correct and prevent recurrence, personnel involved are to adjust the alpha-to-beta crosstalk via correction calculation measures when high alpha activities are observed. Acceptable results returned in a later sample study, supporting effectiveness of corrective action.

C.

NCR 24-05: ERA April RAD-137 water study GR-A evaluated as Not Acceptable. TBE reported 35.2 pCi/L and the known value returned at 52.6 pCi/L (range 39.6-65.6). The root cause investigation determined that the provided samples contained a solids content that was significantly higher than the typical client samples tested by the laboratory. A set aliquot volume for prior ERA samples was used and not adjusted to account for the sudden increase in solid content. To correct and prevent recurrence, new sample types were ordered from ERA that used Am-241 to better reflect client sample testing and acceptable results were achieved. Acceptable results returned in a later sample study, supporting effectiveness of corrective action.

D.

NCR 24-06: E&Z Analytics March E14092 air particulate study Co-60 evaluated as Not Acceptable. TBE reported 168 pCi and the known value returned at 126 pCi. Additionally, March E14093 soil Ce-141 evaluated as Not Acceptable. TBE reported 0.106pCi/g and the known value returned at 0.071pCi/g. The root cause investigation was unable to determine any anomaly thus no proposed corrective action. No recurrence has occurred.

E.

CAR 24-02 (CAR 23-31): MAPEP February 24-MaS50 soil study Fe-55 evaluated as Not Acceptable. TBE reported 297 Bq/Kg and the known value returned at 650 Bq/Kg (range 455-845). The root cause investigation suspects that the current analytical procedure is not sufficient to add the interferences added to the sample by MAPEP. This investigation is still ongoing (See NCR 24-16) as the suggested corrective action did not provide desired results.

F.

NCR 24-08: MAPEP February 24-MaS50 soil study Ni-63 evaluated as Not Acceptable. TBE reported 1070 Bq/Kg and the known value returned at 1530 Bq/Kg (range 1071-1989). The root cause investigation suspected that the sample contained added interferences that are not typically seen in client samples. All QC efforts associated with the sample were acceptable and no anomalies found, even after reanalysis. To correct and prevent recurrence, samples suspected of additional interferences will include the addition of Ni-59 tracer to determine yield results when calculating results. TBE analytical procedure TBE-2013 was updated to include this change.

A-9

G.

NCR 24-09: MAPEP February 24-MaSU50 urine study Zn-65 evaluated as Not Acceptable. The root cause investigation determined that the sample was spiked lower than TBEs typical detection limit and client requirements. The report was revised by MAPEP indicating Not Evaluated, resulting in this nuclide to not be considered a failure.

H.

NCR 24-10: MAPEP February 24-MaW50 water study Tc-99 evaluated as Not Acceptable. TBE reported 9.95Bq/L and the known value returned 7.47Bq/L (range 5.23-9.71).

The root cause investigation suspects Thorium interference that was not removed during the column separation process of the analytical procedure; however, it cannot be confirmed as all QC efforts associated with the sample were acceptable and with no anomalies found. To potentially correct and prevent recurrence, an additional rinse step was added to the procedure. Acceptable results returned in a later sample study, supporting effectiveness of corrective action.

I.

NCR 24-11: MAPEP February 24-RdV50 vegetation study Sr-90 evaluated as Not Acceptable. TBE reported 0.276Bq/sample and the known value returned 0.529Bq/sample (range 0.370-0.688). The root cause investigation determined a laboratory accident resulting in a spilled (loss) of sample. No corrective action was performed as the cause was an unintentional sample spill.

J.

NCR 24-14: ERA September MRAD-41 air particulate study U-234/238 evaluated as Not Acceptable. TBE reported 14.0/14.2 pCi/filter and the known value returned at 31.1/30.9 pCi/filter (range 23.1-36.9). The root cause investigation determined that the laboratory technician placed double the amount of tracer in the sample by error. To correct and prevent recurrence, samples that have been digested/leached with carrier/tracer added will have a label placed over the cap indicating it has already been added. Additionally, the beaker that aliquot is put in should have markings to indicate carrier/tracer has already been added to the sample.

K.

NCR 24-15: ERA September MRAD-41 water study Fe-55 evaluated as Not Acceptable. TBE reported 615 pCi/L and the known value returned at 1230 pCi/L (range 723-1790). The root cause is still under investigation.

L.

NCR 24-16: MAPEP August 24-MaS51 soil study Fe-55 evaluated as Not Acceptable.

TBE did not report a value and the known value returned 780Bq/Kg (range 546-1014). The root cause is still under investigation.

M.

NCR 24-17: MAPEP August 24-RdV51 vegetation study Sr-90 evaluated as Not Acceptable. TBE reported 0.95Bq/sample and the known value returned 2.39Bq/sample (range 1.67-3.11). The root cause is still under investigation.

A-10

APPENDIX B SYNOPSIS OF ANALYTICAL PROCEDURES B-1

SYNOPSIS OF ANALYTICAL PROCEDURES Appendix B is a synopsis of the analytical procedures performed during this reporting period on samples collected for Ameren Missouri Callaway Energy Center's Radiological Environmental Monitoring Program. All analyses have been mutually agreed upon by Callaway Energy Center and Teledyne Brown Engineering and include those recommended by the USNRC Branch Technical Position, Rev.

1, November 1979.

ANALYSIS TITLE PAGE Gross Beta Analysis of Air Particulate Samples....................................................................B-3 Air Particulates...........................................................................................................B-3 Determination of Gross Beta Activity in Water Samples......................................................B-4 Introduction................................................................................................................B-4 Detection Capabilities................................................................................................B-4 Analysis of Samples for Tritium (Liquid Scintillation).........................................................B-5 Water..........................................................................................................................B-5 Analysis of Samples for Iodine-131......................................................................................B-6 Milk or Water.............................................................................................................B-6 Gamma Spectrometry of Samples.........................................................................................B-7 Milk or Water.............................................................................................................B-7 Dried Solids other than Soils and Sediment..............................................................B-7 Fish...........................................................................................................................B-7 Soils and Sediments...................................................................................................B-7 Charcoal Cartridges (Air Iodine)..............................................................................B-7 Airborne Particulates.................................................................................................B-8 Addendum to Gamma Spectrometry Procedure...................................................................B-9 B-2

GROSS BETA ANALYSIS OF AIR PARTICULATE SAMPLES Air Particulates After a delay of five or more days, allowing for the radon-222 and radon-220 (thoron) daughter products to decay, the filters are counted in a gas-flow proportional counter.

Calculations of the results, the two sigma error and the lower limit of detection (LLD):

RESULT (pCi/m 3)

=

((S/T) - (B/t))/(2.22 V E)

TWO SIGMA ERROR (pCi/m 3)

=

2((S/T

2) + (B/t2))1/2/(2.22 V E)

LLD (pCi/m 3)

=

4.66(B 1/2)/(2.22 V E t) where:

S

=

Gross counts of sample including blank B

=

Counts of blank E

=

Counting efficiency T

=

Number of minutes sample was counted t

=

Number of minutes blank was counted V

=

Sample aliquot size (cubic meters)

B-3

DETERMINATION OF GROSS BETA ACTIVITY IN WATER SAMPLES Introduction The procedures described in this section are used to measure the overall radioactivity of water samples without identifying the radioactive species present. No chemical separation techniques are involved.

One liter of the sample is evaporated on a hot plate. A smaller volume may be used if the sample has a significant salt content as measured gravimetrically. If requested by the customer, the sample is filtered through No. 54 filter paper before evaporation, removing particles greater than 30 microns in size.

After evaporating to a small volume in a beaker, the sample is rinsed into a 2-inch diameter stainless steel planchette, which is stamped with a concentric ring pattern to distribute residue evenly. Final evaporation to dryness takes place under heat lamps.

Residue mass is determined by weighing the planchette before and after mounting the sample. The planchette is counted for beta activity on an automatic proportional counter. Results are calculated using empirical self-absorption curves which allow for the change in effective counting efficiency caused by the residue mass.

Detection Capability Detection capability depends upon the sample volume actually represented on the planchette, the background and the efficiency of the counting instrument, and upon self-absorption of beta particles by the mounted sample. Because the radioactive species are not identified, no decay corrections are made and the reported activity refers to the counting time.

The minimum detectable level (MDL) for water samples is nominally 1.6 picoCuries per liter for gross beta at the 4.66 sigma level (1.0 pCi/L at the 2.83 sigma level), assuming that 1 liter of sample is used and that 0.5 gram of sample residue is mounted on the planchette. These figures are based upon a counting time of 50 minutes and upon representative values of counting efficiency and background of 0.2 and 1.2 cpm, respectively The MDL becomes significantly lower as the mount weight decreases because of reduced self-absorption. At a zero mount weight, the 4.66 sigma MDL for gross beta is 0.9 pCi/L. These values reflect a beta counting efficiency of 0.38.

B-4

ANALYSIS OF SAMPLES FOR TRITIUM (Liquid Scintillation)

Water Ten milliliters of water are mixed with 10 ml of a liquid scintillation "cocktail" and then the mixture is counted in an automatic liquid scintillator.

Calculation of the results, the two sigma error and the lower limit detection (LLD) in pCi/L:

RESULT

=

(N-B)/(2.22 V E)

TWO SIGMA ERROR

=

2((N + B)/t) 1/2/ (2.22 V E)

LLD

=

4.66(B/t) 1/2/(2.22 V E )

where:

N

=

the gross cpm of the sample B

=

the background of the detector in cpm 2.22

=

conversion factor changing dpm to pCi V

=

volume of the sample in ml E

=

efficiency of the detector t

=

counting time for the sample B-5

ANALYSIS OF SAMPLES FOR IODINE-131 Milk or Water Two or more liters of sample are first equilibrated with stable iodide carrier. A batch treatment with anion exchange resin is used to remove iodine from the sample. The iodine is then stripped from the resin with sodium hypochlorite solution, is reduced with hydroxylamine hydrochloride and is extracted into carbon tetrachloride as free iodine. It is then back-extracted as iodide into sodium bisulfite solution and is precipitated as palladium iodide. The precipitate is weighed for chemical yield and is mounted on a nylon planchette for low-level beta counting.

Calculations of results, two sigma error and the lower limit of detection (LLD) in pCi/L:

RESULT

=

(N/t-B)/(2.22 E V Y DF)

TWO SIGMA ERROR

=

2((N/t+B)/t) 1/2/(2.22 E V Y DF)

LLD

=

4.66(B/t) 1/2/(2.22 E V Y DF) where:

N

=

total counts from sample (counts) t

=

counting time for sample (min)

B

=

background rate of counter (cpm) 2.22

=

dpm/pCi V

=

volume or weight of sample analyzed Y

=

chemical yield of the mount or sample counted DF

=

decay factor from the collection to the counting date E

=

efficiency of the counter for I-131, corrected for self absorption effects by the formula E

=

Es(exp-0.0061M)/(exp-0.0061Ms)

Es

=

efficiency of the counter determined from an I-131 standard mount Ms

=

mass of Pd12 on the standard mount, mg M

=

mass of PdI2 on the sample mount, mg B-6

GAMMA SPECTROMETRY OF SAMPLES Milk or Water A 1.0 or 4.0 liter Marinelli beaker is filled with a representative aliquot of the sample. The sample is then counted until detection limits are met with a shielded high purity germanium (HPGe) detector coupled to a VAX-based data acquisition system, which performs pulse height analysis.

Dried Solids other than Soils and Sediments A large quantity of the sample is dried at a low temperature, less than 100°C.

As much as possible (up to the total sample) is loaded into a tare, standard 240 cc container and weighed. The sample is then counted until detection limits are met with a shielded HPGe detector coupled to a VAX-based data acquisition system, which performs pulse height analysis.

Fish As much as possible (up to the total sample) of the edible portion of the sample is loaded into a tared Marinelli and weighed. The sample is then counted until detection limits are met with a shielded HPGe detector coupled to a VAX-based data acquisition system, which performs pulse height analysis.

Soils and Sediments Soils and sediments are dried at a low temperature, less than 100°C. The soil or sediment is loaded fully into a tared, standard 240 cc container and weighed. The sample is then counted until detection limits are met with a shielded HPGe detector coupled to a VAX-based data acquisition system, which performs pulse height and analysis.

Charcoal Cartridges (Air Iodine)

Charcoal cartridges are counted up to five at a time, with one positioned on the face of an HPGe detector and up to four on the side of the HPGe detector. Each HPGe detector is calibrated for both positions. The detection limit for iodine-131 of each charcoal cartridge can be determined (assuming no positive iodine-131) uniquely from the volume of air, which passed through it. In the event iodine-131 is observed in the initial counting of a set, each charcoal cartridge is then counted separately, positioned on the face of the detector.

B-7

Air Particulates The thirteen airborne particulate filters for a quarterly composite for each field station are aligned one in front of another and then counted until detection limits are met with a shielded HPGe detector coupled to a VAX-based data acquisition system which performs pulse height analysis.

A VAX software program defines peaks by certain changes in the slope of the spectrum. The program also compares the energy of each peak with a library of peaks for isotope identification and then performs the radioactivity calculation using the appropriate fractional gamma ray abundance, half-life, detector efficiency, and net counts in the peak region.

The calculation of results, two sigma error and the lower limit of detection (LLD) in pCi/volume or pCi/mass:

RESULT

=

(S-B)/(2.22 t E V F DF)

TWO SIGMA ERROR

=

2(S+B) 1/2/(2.22 t E V F DF)

LLD

=

4.66(B) 1/2/(2.22 t E V F DF) where:

S

=

Area, in counts, of sample peak and background (region of spectrum of interest)

B

=

Background area, in counts, under sample peak, determined by a linear interpolation of the representative backgrounds on either side of the peak t

=

length of time in minutes the sample was counted 2.22

=

dpm/pCi E

=

detector efficiency for energy of interest and geometry of sample V

=

sample aliquot size (liters, cubic meters, kilograms, or grams)

F

=

fractional gamma abundance (specific for each emitted gamma)

DF

=

decay factor from the mid-collection date to the counting date B-8

ADDENDUM TO GAMMA SPECTROMETRY PROCEDURE Ba-140 (half-life =12.8d) decays to LA-140 (half-life 40 hrs) and the daughter radionuclide, La-140 approaches 90 % of the Ba-140 activity within 6 days. The La-140 photon energy at 1596 keV is used to quantify the Ba-140 activity due to its high photon emission probability yield (96%) producing a higher count rate when present and therefore, a smaller associated counting error.

Zr-95 (half-life = 65d) decays to Nb-95 (half-life = 35d). The photon energy of Nb-95 (765 keV) is used to quantify Zr-95 because of the high photon emission probability yield (100%) yielding a higher count rate and an associated lower counting error. The daughter radionuclide, Nb-95 approaches the Zr-95 activity after a time period of 65 days, an estimated time interval occurring between sample exposure, collection and shipping, and analysis.

B-9

Appendix C. NON-RADIOLOGICAL MONITORING PROGRAM 1.0. Introduction Union Electric Company Callaway Plant, d.b.a. Ameren Missouri Callaway Energy Center, in accordance with federal regulations and a desire to maintain the quality of the local environment around Callaway Plant has implemented an Environmental Protection Plan, (EPP) contained in Appendix B of the Callaway Plant Operating License.

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

This report describes the conduct of the EPP for the Callaway Plant during 2024.

2.0. Unusual or Important Events No unusual or important events reportable under the EPP Section 4.1 were identified during 2024.

3.0. EPP Non-compliances During 2024, there was zero non-compliance with the EPP.

4.0. Nonroutine Reports There were no nonroutine reports submitted in accordance with the EPP, Section 5.4.2 in 2024.

5.0. Plant Design and Operation Environmental Evaluations.

This section lists all changes in the plant design, operation, tests or experiments installed during 2024, which could have involved a potentially significant unreviewed environmental question in accordance with section 3.1 of Appendix B.

During 2024, no major plant changes were completed that could have involved a potentially significant unreviewed environmental question.

APPENDIX D Sampling Location Maps D-1

Figure Dl. Radiological Environmental Sampling Locations 1, 2, 3, mile radius from site location.

mapping:

I D-2

Figure D-2. Radiological Environmental Sampling Locations 3, 4, 5, 6 mile radius from site location.

,9A (5 miles)

I

- *..___ii) 20 44.7 miles) \\\\

I I

I

,\\

61N (1.9 miles)

\\

1 40 (4.2 miles) 61(4TW 7jIrniles)

\\

18A (3.7 miles)

I 41 (4.9 miLes) 62N (1.2 miles),,7J/,4),,7,71

\\

j I

(1 miles)

/

5.4ils)

\\

I

(1.64 miles,J___J

)

L (3.8 miles)

\\

I

\\

\\

F05 (0.9 miles)

I

\\

1 S

I

/

-çç).%//-

,1 32 (6.4 miles)

\\

q S

. 14 (4.9 miles 32A(5miles)

S D

S

_5S V19 (3.28 miles) 42 (4.4 miles)

V19\\3.22 miles) hA (4.7 miles)

SSS%ss555 S

(3.4 miles)

D 72 S02 4.9 miles)

\\

30A (4AThil D

9 (3 miles)

AQF-C (4.9,miles)

  • 55

S 9

AQS.C,(4.9 miles)

-S S S5 I

Mokane N

0 0.5 1 A 4/

Radiological EnvIronmental Sampling LocatIons 3,4,5,6 mile radius from Site location WAmeren Callaway MISSOURI Energy Center Drinking Well Water Non-Potable Groundwater Wells

. Fish and Sediment 0

Soil

. Farm Crops 0

Surface Water (Ponds) 0 Food Products-Leafy Green Vegetables 0

Surface Water (River)

D-3

Figure D-3. Radiological Environmental Sampling Locations 5, 10, 15 mile radius from site location.

0 1

2 -

Miles N A

rt..

ViAmeren MISSOURI

$.!.if mapping Callaway Energy Center Radlologlcal Environmental Sampling Locations 5, 10, 15 mile radius from Site location C Airborne Radlolodlne & Particulate J Milk

!!) Direct Radiation Dosimeter O Non*Potable Groundwater Wells 0 Drinking Well Water A

Fish and Sediment w SoD e Fann Crops O Surface Waler (Ponds) 0 Food Products-Leafy Green Vegetables Surface Water (River)

D-4

Figure D-4. Non-Potable Groundwater Monitoring Wells, 600 ft radius from Site.

D-5

Figure D-5. Non-Potable Groundwater Monitoring Wells Collection.

Radiological Environmental Sampling Locations Non-Potable Groundwater Wells Collection Discharge Pipeline D-6

  • n*roo Callaway M'SSOUil Energy Genter AMEREN MISSOURI CALLAWAY ENERGY CENTER FULTON, MISSOURI Docket Numbers 50-483 and72-1045 AN N UAL RADIOLOG ICAL ENVI RON M ENTAL OPERATI NG REPORT THE UNITED STATES NUCLEAR REGULATORY COMMISSION Part ll DATA TABULATIONS AND ANALYSES January 1 to December31,2024 Prepared by Teledyne Brown Engineering (Knoxville, Tennessee) and Ameren Missouri Callaway Energy Center Submitted by UNION ELECTRIC CO.

dba Ameren Missouri to Project No. AM001 -3EREMPCALL-24

Section 1.0 2.0 List of Tables Introduction Analytical Data Tables Table of Contents 11 Page iii IV V

1.0 Introduction The following constitutes a supplement to the Annual Report for the Radiological Environmental Monitoring Program conducted at the Ameren Missouri, Callaway Energy Center, Fulton, Missouri in 2024.

Results of completed analyses are presented in the attached tables.

For information regarding sampling locations, type and frequency of collection, and sample codes, refer to Part I, Tables 5.1 - 5.2 and the figures in Appendix D.

Analyses results from additional sampling may be found in Appendix A.

iv

Table List of Tables Description 1.0 Airborne particulate and charcoal sample analysis results for gamma emitters and I-131 2.0 Milk sample analysis results for iodine 131 and gamma emitters 3.0 Vegetation sample analysis results for gamma emitters 4.0 Soil sample analysis results for gamma emitters 5.0 Surface water analysis results for tritium and gamma emitters 6.0 Pond water analysis results for tritium and gamma emitters 7.0 Well water (drinking) analysis results for tritium and gamma emitters 8.0 Well water (non-potable) analysis results for tritium and gamma emitters 9.0 Shoreline sediment analysis results for gamma emitters iii Section 1-1 2-1 3-1 4-1 5-1 6-1 7-1 8-1 9-1 10-1 10.0 Fish analysis results for gamma emitters 11.0 Direct radiation gamma dose and neutron dose 11-1

2.0 Analytical Data Tables for Callaway Energy Center v

1

(a)

(a) No air volume. See Part I, Section 3.3 Program Execution

  • No Sample - Please refer to section 1.0 List of Missing Sample 2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

Table 11a. Direct Radiation (quarterly exposure)

CA-IDM-1A CA-IDM-3*

CA-IDM-5 CA-IDM-6 CA-IDM-7 CA-IDM-9 CA-IDM-10 CA-IDM-11A CA-IDM-14 CA-IDM-17 CA-IDM-18A CA-IDM-20 CA-IDM-21 CA-IDM-22A*

CA-IDM-23 CA-IDM-26(C)

CA-IDM-27(C)

CA-IDM-30A CA-IDM-31A CA-IDM-32 CA-IDM-32A CA-IDM-33 CA-IDM-34 CA-IDM-35 CA-IDM-36 CA-IDM-37 CA-IDM-38 CA-IDM-39 CA-IDM-39A CA-IDM-40 CA-IDM-41 CA-IDM-42 CA-IDM-43 CA-IDM-44 CA-IDM-45*

CA-IDM-46*

CA-IDM-47 CA-IDM-48 CA-IDM-49 CA-IDM-50 CA-IDM-51A CA-IDM-52 CA-IDM-60(C)*

CA-IDM-61*

15.68 15.68 13.31 14.65 15.19 14.39 16.53 15.81 14.94 14.29 14.75 15.30 14.94 12.59 16.18 10.28 16.65 14.89 16.07 16.28 14.68 15.08 14.10 12.78 13.58 14.70 10.38 14.82 14.28 15.19 14.22 12.75 14.69 14.57 14.08 15.51 14.45 15.38 14.04 14.54 16.52 15.82 15.01 14.72 QTR 1 15.88 15.01 12.99 13.76 14.90 13.76 15.87 15.70 15.37 14.07 14.70 15.00 14.62 11.97 15.37 10.26 15.83 14.72 15.66 15.66 14.28 15.00 14.63 14.01 14.57 15.04 10.56 14.80 14.97 15.15 14.37 13.29 15.04 15.51 13.52 15.82 15.26 15.88 13.99 14.55 14.93 14.68 14.63 13.22 QTR 2 14.39 15.24 12.71 15.11 15.10 13.92 15.79 15.62 14.98 13.75 14.93 14.58 14.77 11.68 16.25 10.34 16.09 15.19 15.71 15.83 14.63 15.17 14.99 14.07 13.71 15.15 10.07 14.20 14.29 14.90 13.87 12.97 14.87 15.07 14.44 14.97 13.98 16.02 14.49 15.01 16.87 16.91 15.82 13.72 QTR 3 15.15 14.88 12.85 14.79 14.67 13.42 15.52 15.64 14.76 14.20 14.50 14.92 14.57 11.83 15.60 10.01 15.56 13.75 15.41 15.65 14.45 14.73 14.75 13.65 13.23 13.74 10.44 14.10 14.36 15.52 13.44 12.10 14.10 14.29 12.57 14.31 15.27 15.44 13.42 14.27 14.81 14.38 14.65 12.97 QTR 4 Location Gamma Dose (mrem/90 days)

(C)

ISFSI monitoring Controls 19

Table 11b. Direct Radiation Neutron (quarterly exposure)

Location Neutron Dose (mrem/90 days)

QTR 1 QTR 2 QTR 3 QTR 4 CA-IDM-60N (C)

CA-IDM-61N CA-IDM-62N CA-IDM-63N CA-IDM-64N 0.0 +/- 1.0 0.0 +/- 0.9 0.0 +/- 1.8 0.0 +/- 0.8 0.0 +/- 1.7 0.0 +/- 1.0 0.0 +/- 0.7 0.0 +/- 0.5 0.0 +/- 0.8 0.0 +/- 0.6 0.0 +/- 2.2 0.0 +/- 1.1 0.0 +/- 0.6 0.0 +/- 0.9 0.0 +/- 1.1 0.0 +/- 1.2 0.0 +/- 1.0 0.0 +/- 0.7 0.0 +/- 0.7 0.0 +/- 3.7 (C) Controls 20