ML101440179

Annual Radiological Environmental Operating Report for January 1 Through December 31, 2009

ML101440179
Person / Time
Site:	Pilgrim
Issue date:	05/13/2010
From:	Jeffery Lynch Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.10.029
Download: ML101440179 (105)

Text

v-IEn terg Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 May 13, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Annual Radiological Environmental Operating Report for January 1 through December 31, 2009 LETTER NUMBER: 2.10.029

Dear Sir or Madam:

In accordance with Pilgrim Technical Specification 5.6.2, Entergy Nuclear Operations, Inc.

submits the attached Annual Radiological Environmental Operating Report for January 1 through December 31, 2009.

Should you have questions or require additional information, I can be contacted at (508) 830-8403.

This letter contains no commitments.

Sincerely, Joseph R. Lynch Manager, Licensing JRL/wgI

Attachment:

Pilgrim Nuclear Power Station Radiological Environmental Operating Report, January 1 through December 31, 2009 cc: U.S. Nuclear Regulatory Commission Mr. James S. Kim, Project Manager Region I Plant Licensing Branch I-1 475 Allendale Road Division of Operator Reactor Licensing King of Prussia, PA 19406 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North O-8C2 Senior Resident Inspector 11555 Rockville Pike Rockville, MD 20852 31169-

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Annual Radiological Environmental Operating Report January 1 through December 31, 2009

'"ýEntergy'*-

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2009 Prepared by:

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Reviewed by:

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Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2009 TABLE OF CONTENTS SECTION SECTION TITLE PAGE EXECUTIVE

SUMMARY

6

1.0 INTRODUCTION

8 1.1 Radiation and Radioactivity 8 1.2 Sources of Radiation 9 1.3 Nuclear Reactor Operations 10 1.4 Radioactive Effluent Control 16 1.5 Radiological Impact on Humans 18 2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 23 2.1 Pre-Operational Monitoring Results 23 2.2 Environmental Monitoring Locations 24 2.3 Interpretation of Radioactivity Analyses Results 27 2.4 Ambient Radiation Measurements 28 2.5 Air Particulate Filter Radioactivity Analyses 29 2.6 Charcoal Cartridge Radioactivity Analyses 30 2.7 Milk Radioactivity Analyses 30 2.8 Forage Radioactivity Analyses 31 2.9 VegetableNegetation Radioactivity Analyses 31 2.10 Cranberry Radioactivity Analyses 31.,

2.11 Soil Radioactivity Analyses 32 2.12 Surface Water Radioactivity Analyses 32 2.13 Sediment Radioactivity Analyses 32 2.14 Irish Moss Radioactivity Analyses 33 2.15 Shellfish Radioactivity Analyses 33 2.16 Lobster Radioactivity Analyses 33 2.17 Fish Radioactivity Analyses 34 3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS 68

4.0 REFERENCES

70 APPENDIX A Special Studies 71 APPENDIX B Effluent Release Information 72 APPENDIX C Land Use Census 82 APPENDIX D Environmental Monitoring Program Discrepancies 83 APPENDIX E J.A. Fitzpatrick Interlaboratory Comparison Program 85 Page 3

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2009 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 9 1.3-1 PNPS Operating Capacity Factor During 2009 10 2.2-1 Routine Radiological Environmental Sampling Locations 35 2.4-1 Offsite Environmental TLD Results 37 2.4-2 Onsite Environmental TLD Results 39 2.4-3 Average TLD Exposures By Distance Zone During 2009 40 2.5-1 Air Particulate Filter Radioactivity Analyses 41 2.6-1 Charcoal Cartridge Radioactivity Analyses 42 2.7-1 Milk Radioactivity Analyses 43 2.8-1 Forage Radioactivity Analyses 44 2.9-1 VegetableNegetation Radioactivity Analyses 45 2.10-1 Cranberry Radioactivity Analyses 46 2.12-1 Surface Water Radioactivity Analyses 47 2.13-1 Sediment Radioactivity Analyses 48 2.14-1 Irish Moss Radioactivity Analyses 49 2.15-1 Shellfish Radioactivity Analyses 50 2.16-1 Lobster Radioactivity Analyses 51 2.17-1 Fish Radioactivity Analyses 52, 3.0-1 Radiation Doses From 2009 Pilgrim Station Operations 69 B. 1 Supplemental Information 73 B.2-A Gaseous Effluents Summation of All Releases 74 B.2-B Gaseous Effluents - Elevated Releases 75 B.2-C Gaseous Effluents - Ground Level Releases 77 B.3-A Liquid Effluents Summation of All Releases 79 B.3-B Liquid Effluents: January-December 2009 80 E.3-1 Ratio of Agreement 88 E.4-1 Interlaboratory Intercomparison Program 89 Page 4

Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report January-December 2009 LIST OF FIGURES FIGURE FIGURE TITLE PAGE 1.3-1 Radioactive Fission Product Formation 12 1.3-2 Radioactive Activation Product Formation 13 1.3-3 Barriers to Confine Radioactive Materials 14 1.5-1 Radiation Exposure Pathways 20 2.2-1 Environmental TLD Locations Within the PNPS Protected Area 53 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer 55 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers 57 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers 59 2.2-5 Terrestrial and Aquatic Sampling Locations 61 2.2-6 Environmental Sampling and Measurement Control Locations 63 2.5-1 Airborne Gross Beta Radioactivity Levels: Near Station Monitors 65 2.5-2 Airborne Gross Beta Radioactivity Levels: Property Line Monitors', 66 2.5-3 Airborne Gross Beta Radioactivity Levels: Offsite Monitors 67 Page 5

EXECUTIVE

SUMMARY

ENTERGY NUCLEAR PILGRIM NUCLEAR POWER STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REPORT JANUARY 01 THROUGH DECEMBER 31; 2009 INTRODUCTION This report summarizes the results of the Entergy Nuclear Radiological Environmental Monitoring Program (REMP) conducted in the vicinity of Pilgrim Nuclear Power Station (PNPS) during the period from January 1 to December 31, 2009. This document has been prepared in accordance with the requirements of PNPS Technical Specifications section 5.6.2.

The REMP has been established to monitor the radiation and radioactivity released to the environment as a result of Pilgrim Station's operation. This program, initiated in August 1968, includes the collection, analysis, and evaluation of radiological data in order to assess the impact of Pilgrim Station on the environment and on the general public.

SAMPLING AND ANALYSIS The environmental sampling media collected in the vicinity of PNPS and at distant locations include air particulate filters, charcoal cartridges, animal forage, -vegetation, cranberries, seawater, sediment, Irish moss, shellfish, American lobster, and fishes.

During 2009, there were 1,231 samples collected from the atmospheric, aquatic, and terrestrial environments. In addition, 438 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs).

A small number of inadvertent issues were encountered during 2009 in the collection of environmental samples in accordance with the PNPS Offsite Dose Calculation Manual (ODCM).

Two out of 440 TLDs were unaccounted for during the quarterly retrieval process. However, the 429 TLDs that were collected provided the information necessary to assess ambient radiation levels in the vicinity of Pilgrim Station. Equipment failures and power outages resulted in a small number of instances in which lower than normal volumes were collected at the airborne sampling stations. In some cases, outages were of sufficient duration to yield no sample, and 564 of 572 air particulate and charcoal cartridges were collected and analyzed as required. A full description of any discrepancies encountered with the environmental monitoring program is presented in Appendix D of this report.

There were 1,289 analyses performed on the environmental media samples. Analyses were performed by the J.A. Fitzpatrick Environmental Laboratory in Fulton, New York. Samples were analyzed as required by the PNPS ODCM.

LAND USE CENSUS The annual land use census in the vicinity of Pilgrim Station was conducted as required by the PNPS ODCM between September 04 and September 24, 2009. A total of 23 vegetable gardens having an area of more than 500 square feet were identified within five kilometers (three miles) of PNPS. No new milk or meat animals were located during the census. Of the 23 garden locations identified, samples were collected at or near three of the gardens as part of the environmental Page 6

monitoring program. Other samples of natural vegetation were also collected in predicted high-deposition areas.

RADIOLOGICAL IMPACT TO THE ENVIRONMENT During 2009, samples (except charcoal cartridges) collected as part of the REMP at Pilgrim Station continued to contain detectable amounts of naturally-occurring and man-made radioactive materials.

No samples indicated any detectable radioactivity attributable to Pilgrim Station operations. Offsite ambient radiation measurements using environmental TLDs beyond the ,site boundary ranged between 45 and 87 milliRoentgens per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts as determined by the Environmental Protection Agency (EPA).

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2009, radiation doses to the general public as a result of Pilgrim Station's operation continued to be well below the federal limits and much less than the collective dose due to other sources of man-made (e.g., X-rays, medical, fallout) and naturally-occurring (e.g., cosmic, radon) radiation.

The calculated total body dose to the maximally exposed member of the general public from radioactive effluents and ambient radiation resulting from PNPS operations, for 2009 was about 1.4 mrem for the year. This conservative estimate is well below the EPA's annual dose limit to any member of the general public and is a fraction of a percent of the typical dose received from natural and man-made radiation.

CONCLUSIONS The 2009 Radiological Environmental Monitoring Program for Pilgrim Station resulted in the collection and analysis of hundreds of environmental samples and measurements. The data obtained were used to determine the impact of Pilgrim Station's operation on the environment and on the general public.

An evaluation of direct radiation measurements, environmental sample analyses, and dose calculations showed that all applicable federal criteria were met. Furthermore, radiation levels and-resulting doses were a small fraction of those that are normally present due to natural and man-made background radiation.

Based on this information, there is no significant radiological impact on the environment or on the general public due to Pilgrim Station's operation.

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1.0 INTRODUCTION

The Radiological Environmental Monitoring Program for 2009 performed by Entergy Nuclear Company for Pilgrim Nuclear Power Station (PNPS) is discussed in this report. Since the operation of a nuclear power plant results in the release of small amounts of radioactivity and low levels of radiation, the Nuclear Regulatory Commission (NRC) requires a program to be established to monitor radiation and radioactivity in the environment (Reference 1)., This report, which is required to be published annually by Pilgrim Station's Technical Specifications section 5.6.2, summarizes the results of measurements of radiation and radioactivity in the environment in the vicinity of the Pilgrim Station and at distant locations during the period January 1 to December 31, 2009.

The Radiological Environmental Monitoring Program consists of taking radiation measurements and collecting samples from the environment, analyzing them for radioactivity content, and interpreting the results. With emphasis on the critical radiation exposure pathways to humans, samples from the aquatic, atmospheric, and terrestrial environments are collected. These samples include, but are not limited to: air, animal forage, vegetation, cranberries, seawater, sediment, Irish moss, shellfish, lobster, and fish. Thermoluminescent dosimeters (TLDs) are placed in the environment to measure gamma radiation levels. The TLDs are processed and the environmental samples are analyzed to measure the very low levels of radiation and radioactivity present in the environment as a result of PNPS operation and other natural and man-made sources. These results are reviewed by PNPS's radiological staff and have been reported semiannually or annually to the Nuclear Regulatory Commission and others since 1972.

In order to more fully understand how a nuclear power plant impacts humans and the environment, background information on radiation and radioactivity, natural and man-made sources of radiation, reactor operations, radioactive effluent controls, and radiological impact on humans is provided. It is believed that this information will assist the reader in understanding the radiological impact on the environment and humans from the operation of Pilgrim Station.

1.1 Radiation and Radioactivity All matter is made of atoms. An atom is the smallest part into which matter can be broken down and still maintain all its chemical properties. Nuclear radiation is energy, in the form of waves or particles that is given off by unstable, radioactive atoms.

Radioactive material exists naturally and has always been a part of our environment. The earth's crust, for example, contains radioactive uranium, radium, thorium, and potassium. Some radioactivity is a result of nuclear weapons testing.. Examples of radioactive fallout that is normally present in environmental samples are cesium-137 and strontium-90. Some examples of radioactive materials released from a nuclear power plant are cesium-1 37, iodine-1 31, strontium-90, and cobalt-60.

Radiation is measured in units of millirem, much like temperature is measured in degrees. A millirem is a measure of the biological effect of the energy deposited in tissue. The natural and man-made radiation dose received in one year by the average American is 300 to 400 mrem (References 2, 3, 4).

Radioactivity is measured in curies. A curie is that amount of radioactive material needed to produce 37,000,000,000 nuclear disintegrations per second. This is an extremely large amount of radioactivity in comparison to environmental radioactivity. That is why radioactivity in the environment is measured in picocuries. One picocurie is equal to one trillionth of a curie.

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1.2 Sources of Radiation As mentioned previously, naturally, occurring radioactivity has always been a part of our environment. Table 1.2-1 shows the sources and doses of radiation from natural and man-made sources.

Table 1.2-1 Radiation Sources and Corresponding Doses NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem!/ear Cosmic/cosmogenic 30 Medical/Dental X-Rays 39 Internal 40 Nuclear Medicine 14 Terrestrial 30 Consumer Products 10 Radon/Thoron 200 Weapons Fallout 1 Nuclear Power Plants 1 Approximate Total 300 Approximate Total [ 60 Cosmic radiation from the sun and outer space penetrates the earth's atmosphere and continuously bombards us with rays and charged particles. Some of this cosmic radiation interacts with gases and particles in the atmosphere, making them radioactive in turn. These radioactive byproducts from cosmic ray bombardment are referred to as cosmogenic radionuclides. Isotopes such as beryllium-7 and carbon-14 are formed in this way. Exposure to cosmic and cosmogenic sources of radioactivity results in about 30 mrem of radiation dose per year.

Additionally, natural radioactivity is in our body and in the food we eat (about 40 millirem/yr), the ground we walk on (about 30 millirem/yr) and the air we breathe (about 200 millirem/yr). The majority of a person's annual dose results from exposure to radon and thoron in the air we breathe. These gases and their radioactive decay products arise from the decay of naturally occurring uranium, thorium and radium in the soil and building products such as brick, stone, and concrete. Radon and thoron levels vary greatly with location, primarily due to changes in the concentration of uranium and thorium in the soil. Residents at some locations in Colorado, New York, Pennsylvania, and New Jersey have a higher annual dose as a result of higher levels of radon/thoron gases in these areas.

In total, these various sources of naturally-occurring radiation and radioactivity contribute to a total dose of about 300 mrem per year.

In addition to natural radiation, we are normally exposed to radiation from a number of man-made sources. The'single largest doses from man-made sources result from therapeutic and diagnostic applications of x-rays and radiopharmaceuticals. The annual dose to an individual in the U.S. from medical and dental exposure is about 50 mrem. Consumer products, such as televisions and smoke detectors, contribute about 10 mrem/yr. Much smaller doses result from weapons fallout (less than 1 mrem/yr) and nuclear power plants. Typically, the average person in the United States receives about 60 mrem per year from man-made sources.

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1.3 Nuclear Reactor Operations Pilgrim Station generates about 700 megawatts of electricity at full power, which is enough electricity; to supply the entire city of Boston, Massachusetts. Pilgrim Station is a boiling water reactor whose nuclear steam supply system was provided by General Electric Co. The nuclear station is located on a 1600-acre site about eight kilometers (five miles) east-southeast .of the downtown area of Plymouth, Massachusetts. Commercial operation began in December 1972.

Pilgrim Station was operational during most of 2009, with the exception of a refueling outage in April and May. The resulting monthly capacity factors are presented in Table 1.3-1.

TABLE 1.3-1 PNPS OPERATING CAPACITY FACTOR DURING 2009 (Based on rated reactor thermal power)

Month Percent Capacity January 99.9%

February 98.0%

March 99.7%

April 53.6%

May 36.8%

June 99.6%

July 99.3%

August 99.2%

September 99.8%

October 99.2%

November 99.9%

December 99.8%

Annual Average . 90.4%

Nuclear-generated electricity is produced at Pilgrim Station by many of the same techniques used for conventional oil and coal-generated electricity. Both systems use heat to boil water to produce steam, The steam turns a turbine, which turns a generator, producing electricity. In both cases, the steam passes through a condenser where it changes back into water and recirculates back through the system. The cooling water source for Pilgrim Station is the Cape Cod Bay.

The key difference between Pilgrim's nuclear power and conventional power is the source of heat used to boil the water. Conventional plants bum fossil fuels in a boiler, while nuclear plants make use of uranium in a nuclear reactor.

Inside the reactor; a nuclear reaction called fission takes place. Particles, called neutrons, strike the nucleus of a uranium-235 atom, causing it to split into fragments called radioactive fission products.

The splitting of the atoms releases both heat and more neutrons. The newly-released neutrons then collide with and split other uranium atoms, thus making more heat and releasing even more Page 10

neutrons, and on and on until the uranium fuel is depleted or spent. This process is called a chain reaction.

The operation of a nuclear reactor results in the release of small amounts of radioactivity and low levels of radiation. The radioactivity originates from two major sources, radioactive fission products and radioactive activation products.

Radioactive fission products, as illustrated in Figure 1.3-1 (Reference 5), originate from the fissioning of the nuclear fuel. These fission products get into the reactor coolant from their release by minute amounts of uranium on the outside surfaces of the fuel cladding, by diffusion through the fuel pellets and cladding and, on occasion, through defects or failures in the fuel cladding. These fission products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive fission products on the pipes and equipment emit radiation.

Examples of some fission products are krypton-85 (Kr-85), strontium-90 (Sr-90), iodine-131 (1-131),

xenon-1 33 (Xe-1 33), and cesium-1 37 (Cs-1 37).

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Nuclear Fission Fission is the splitting of the uranium-235 atom by a neutron to release heat and more neutrons, creating a chain reaction.

Radiation and fission products are by-products of the process.

Radiation Radiation Neutron Uranium SNeurs Uranium Fission Products Figure 1.3-1 Radioactive Fission Product Formation Page 12

Radioactive activation products (see Figure 1.3-2), on the other hand, originate from two sources.

The first is by neutron bombardment of the hydrogen, oxygen and other gas (helium, argon, nitrogen) molecules in the reactor cooling water. The second is a result of the fact that the internals of any piping system or component are subject to minute yet constant corrosion from the reactor cooling water. These minute metallic particles (for example: nickel, iron, cobalt, or magnesium) are transported through the reactor core into the fuel region, where neutrons may react with the nuclei of these particles, producing radioactive products. So, activation products are nothing more than ordinary naturally-occurring atoms that are made unstable or radioactive by neutron bombardment.

These activation products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive activation products on the pipes and equipment emit radiation. Examples of some activation products are manganese-54 (Mn-54), iron-59 (Fe-59), cobalt-60 (Co-60), and zinc-65 (Zn-65).

-- 0 Co-59 Neutron Stable Radioactive Cobalt Nucleus Cobalt Nucleus Figure 1.3-2 Radioactive Activation Product Formation At Pilgrim Nuclear Power Station there are five independent protective barriers that confine these radioactive materials. These five barriers, which are shown in Figure 1.3-3 (Reference 5), are:

" fuel pellets;

• fuel cladding;

" reactor vessel and piping;

• primary containment (drywell and torus); and,

• secondary containment (reactor building).

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SIMPLIFIED DIAGRAM OF A BOILING WATER REACTOR

1. FUEL PELLETS

2. FU 5. SECONDARY CONTAINMENT REACTOR BUILDING DRYWELL Figure 1.3-3 Barriers To Confine Radioactive Materials Page 14

The ceramic uranium fuel pellets provide the first barrier. Most of the radioactive fission products are either physically trapped or chemically bound between the uranium atoms, where they will remain.

However, a few fission products that are volatile or gaseous may diffuse through the fuel pellets into small gaps between the pellets and the fuel cladding.

The second barrier, the fuel cladding, consists of zirconium alloy tubes that confine the fuel pellets.

The small gaps between the fuel and the cladding contain the noble gases and volatile iodines that are types of radioactive fission products. This radioactivity can diffuse to a small extent through the fuel cladding into the reactor coolant water.

The third barrier consists of the reactor pressure vessel, steel piping and equipment that confine the reactor cooling water. The reactor pressure vessel, which holds the reactor fuel, is a 65-foot high by 19-foot diameter tank with steel walls about nine inches thick. This provides containment for radioactivity in the primary coolant and the reactor core. However, during the course of operations and maintenance, small amounts of radioactive fission and activation products can escape through valve leaks or upon breaching of the primary coolant system for maintenance.

The fourth barrier is the primary containment. This consists of the drywell and the torus. The drywell is a steel lined enclosure that is shaped like an inverted light bulb. An approximately five foot thick concrete wall encloses the drywell's steel pressure vessel. The torus is a donut-shaped pressure suppression chamber. The-steel walls of the torus are nine feet in diameter with the donut itself having an outside diameter of about 130 feet. Small amounts of radioactivity may be released from primary containment during maintenance.

The fifth barrier is the secondary containment or reactor building. The reactor building is the concrete building that surrounds the primary containment. This barrier is an additional safety feature to contain radioactivity that may escape from the primary containment. This reactor building is equipped with a filtered ventilation system that is used when needed to reduce the radioactivity that escapes from the primary containment.

The five barriers confine most of the radioactive fission and activation products. However, small amounts of radioactivity do escape via mechanical failures and maintenance on valves, piping, and equipment associated with the reactor cooling water system. The small amounts of radioactive liquids and gases that do escape the various containment systems are further controlled by the liquid purification and ventilation filt'ation systems. Also, prior to a release to the environment, control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable. The control of radioactive effluents at Pilgrim Station will be discussed in more detail in the next section.

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1.4 Radioactive Effluent Control The small amounts of radioactive liquids and gases that might escape the five barriers are purified in the liquid and gaseous waste treatment systems, then monitored for radioactivity, and released only if the radioactivity levels are below the federal release limits.

Radioactivity released from the liquid effluent system to the environment is limited, controlled, and monitored by a variety of systems and procedures which include:

• reactor water cleanup system;

• liquid radwaste treatment system;

" sampling and analysis of the liquid radwaste tanks; and,

• liquid waste effluent discharge header radioactivity monitor.

The purpose of the reactor water cleanup system is to continuously purify the reactor cooling water by removing radioactive atoms and non-radioactive impurities that may become activated by neutron bombardment. A portion of the reactor coolant water is diverted from the primary coolant system and is directed through ion exchange resins where radioactive elements, dissolved and suspended in the water, are removed through chemical processes. The net effect is a substantial reduction of the radioactive material that is present in the primary coolant water and consequently the amount of radioactive material that might escape from the system.

Reactor cooling water that might escape the primary cooling system and other radioactive water sources are collected in floor and equipment drains. These drains direct this radioactive liquid waste to large holdup tanks. The liquid waste collected in the tanks is purified again using the liquid radwaste treatment system, which consists of a filter and ion exchange resins.

Processing of liquid radioactive waste results in large reductions of radioactive liquids discharged into Cape Cod Bay. Of all wastes processed through liquid radwaste treatment, 90 to 95 percent of all wastes are purified and the'processed liquid is re-used in plant systems.

Prior to release, the radioactivity in the liquid radwaste tank is sampled and analyzed to determine if the level of radioactivity is below the release limits and to quantify the total amount of radioactive liquid effluent that would be released. If the levels are below the federal release limits, the tank is drained to the liquid effluent discharge header.

This liquid waste effluent discharge header is provided with a shielded radioactivity monitor. This detector is connected to a radiation level meter and a strip chart recorder in the Control Room. The radiation alarm is set so that the detector will alarm before radioactivity levels exceed the release limits. The liquid effluent discharge header has an isolation valve. If an alarm is received, the liquid effluent discharge valve will automatically close, thereby terminating the release to the Cape Cod Bay and preventing any liquid radioactivity from being released that may, exceed the release limits.

An audible alarm notifies the Control Room operator that this has occurred.

Some liquid waste sources which have a low potential for containing radioactivity, and/or may contain very low levels of contamination, may be discharged directly to the discharge canal without passing through the liquid radwaste discharge header. One such source of liquids is the neutralizing sump. However, prior to discharging such liquid wastes, the tank is thoroughly mixed and a representative sample is collected for analysis of radioactivity content prior to being discharged.

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Another means for adjusting liquid effluent concentrations to below federal limits is by mixing plant cooling water from the condenser with the liquid effluents in the discharge canal. This larger volume of cooling water further dilutes the radioactivity levels far below the release limits.

The preceding discussion illustrates that many controls exist to reduce the radioactive liquid effluents released to the Cape Cod Bay to as far below the release limits as is reasonably achievable.

Radioactive releases from the radioactive gaseous effluent system to the environment are limited, controlled, and monitored by a variety of systems and procedures which include:

• reactor building ventilation system;

" reactor building vent effluent radioactivity monitor;

• sampling and analysis of reactor building vent effluents;

• standby gas treatment system;

" main stack effluent radioactivity monitor and sampling;

" sampling and analysis of main stack effluents;

• augmented off-gas system;

• steam jet air ejector (SJAE) monitor; and,

• off-gas radiation monitor.

The purpose of the reactor building ventilation system is -to collect and exhaust reactor building air.

Air collected from contaminated areas is filtered prior to combining it with air collected from other parts of the building. This combined airflow is then directed to the reactor building ventilation plenum that is located on the side of the reactor building. This plenum, which vents to the atmosphere, is equipped with a radiation detector. The radiation level meter and strip chart recorder for the reactor building vent effluent radioactivity monitor is located in the Control Room. To supplement the information continuously provided by the detector, air samples are taken periodically from the reactor building vent and are analyzed to quantify the total amount of tritium and radioactive gaseous and particulate effluents released.

If air containing elevated amounts of noble gases is routed past the reactor building vent's effluent radioactivity monitor, an alarm will alert the Control Room operatorý that release limits are being approached. The Control Room operators, according to procedure, will isolate the reactor building ventilation system and initiate the standby gas treatment system to remove airborne particulates and gaseous halogen radioactivity from the reactor building exhaust. This filtration assembly consists of high-efficiency particulate air filters and charcoal adsorber beds. The purified air is then directed to the main stack. The main stack has dilution flow that further reduces concentration levels of gaseous releases to the environment to as far below the release limits as is reasonably achievable.

The approximately 335 foot tall main stack has a special probe inside it that withdraws a portion of the air and passes it through a radioactivity monitoring system. This main stack effluent radioactivity monitoring system continuously samples radioactive particulates, iodines, and noble gases. Grab samples for a tritium analysis are also collected at this location. The system also contains radioactivity detectors that monitor the levels of radioactive noble gases in the stack flow and display the result on radiation level meters and strip chart recorders located in the Control Room. To supplement the information continuously provided by the detectors, the particulate, iodine, tritium, and gas samples are analyzed periodically to quantify the total amount of radioactive gaseous effluent being released.

The purpose of the augmented off-gas system is to reduce the radioactivity from the gases that are removed from the condenser. This purification system consists of two 30-minute holdup lines to Page 17

reduce the radioactive gases with short half-lives, several charcoal adsorbers to remove radioactive iodines and further retard the short half-life gases, and offgas filters to remove radioactive particulates. The recombiner collects free hydrogen and oxygen gas and recombines them into water. This helps reduce the gaseous releases of short-lived isotopes of oxygen that have been made radioactive by neutron activation.

The radioactive off-gas fromthe condenser is then directed into a ventilation pipe to which the off-gas radiation monitors are attached. The radiation level meters and strip chart recorders for this detector are also located in the Control Room. If a radiation alarm setpoint is exceeded, an audible alarm will sound to alert the Control Room operators. In addition, the off-gas bypass and charcoal adsorber inlet valve will automatically re-direct the off-gas into the charcoal adsorbers if they are temporarily being bypassed. If the radioactivity levels are not returned to below the alarm setpoint within 13 minutes, the off-gas releases will be automatically isolated, thereby preventing any gaseous radioactivity from being released that may exceed the release limits.

Therefore, for both liquid and gaseous releases, radioactive effluent control systems exist to collect and purify the radioactive effluents in' order to reduce releases to the environment to as low as is reasonably achievable. The effluents are always monitored, sampled and analyzed prior to release to make sure that radioactivity levels are below the release limits. If the release limits are being approached, isolation valves in some of the waste effluent lines will automatically shut to stop'the release, or Control Room operators will implement procedures to ensure that federal regulatory limits are always met.

1.5 Radiological Impact on Humans The final step in the effluent control process is the determination of the radiological dose impact to humans and comparison with the federal dose limits to the public. As mentioned previously, the purpose of continuous radiation monitoring and periodic sampling and analysis is to measure the quantities of radioactivity being released to determine compliance with the radioactivity release limits.

This is the first stage for assessing releases to the environment.

Next, calculations of the dose impact to the general public from Pilgrim Station's radioactive effluents are performed. The purpose of these calculations is to periodically assess the doses to the general public resulting from radioactive effluents to ensure that these doses are being maintained as far below the federal dose limits as is reasonably achievable. This is the second stage for assessing releases to the environment.

The types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during each given year are reported to the Nuclear Regulatory Commission annually. The 2009 Radioactive Effluents are provided in Appendix B and will be discussed in more detail in Section 3 of this report. These liquid and gaseous effluents were well below the federal release limits and were a small percentage of the PNPS ODCM effluent control limits.

These measurements of the physical and chemical nature of the effluents are used to'determine how the radionuclides" will interact with the environment and how they can result in radiation exposure to humans. The environmental interaction mechanisms depend upon factors such as the hydrological (water) and meteorological (atmospheric) characteristics in the area. Information on the water flow, wind speed, wind direction, and atmospheric mixing characteristics are used to estimate how radioactivity will distribute and disperse in the ocean and the atmosphere.

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The most important type of information that is used to evaluate the radiological impact on humans is data on the use of the environment. Information on fish and shellfish consumption, boating usage, beach usage, locations of cows and goats, locations of residences, locations of gardens, drinking water supplies, and other usage information are utilized to estimate the amount of radiation and radioactivity received by the general public.

The radiation exposure pathway to humans is the path radioactivity takes from its release point at Pilgrim Station to its effect on man. The movement of radioactivity through the environment and its transport to humans is portrayed in Figure .1.5-1.

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EXAMPLES OF PILGRIM STATION'S RADIATION EXPOSURE PATHWAYS

... ...ASE0US..*..*.-*.*.

... . ... E.P.F:LU:EN.Tq.*

LIQUID EFFLUENTS

3. DIRECT RADIATION

4. DIRECT RADIATION (SOIL DEPOSITION)

(AIR SUBMERSION)

1. SHORELINE DIRECT RADIATIOC (FISHING, PICNICING) 5. CONSUMPTION (VEGETATION)

DEPOSITION

2. DIRECT RADIATION (IMMERSION IN OCEAN, BOATING, SWIMMING)

(\ 1*

DEPOSITION INGESTION Figure 1.5-1 Radiation Exposure Pathways Page 20

There are three major ways in which liquid effluents affect humans:

• external radiation from liquid effluents that deposit and accumulate on the shoreline; 0 external radiation from immersion in ocean water containing radioactive liquids; and,

" internal radiation from consumption of fish and shellfish containing radioactivity absorbed from the liquid effluents.

There are six major ways in which gaseous effluents affect humans:

• external radiation from an airborne plume of radioactivity;

" internal radiation from inhalation of airborne radioactivity;

• external radiation from deposition of radioactive effluents on soil;

" ambient (direct) radiation from contained sources at the power plant;

" internal radiation from consumption of vegetation containing radioactivity deposited on vegetation or absorbed from the soil due to ground deposition of radioactive effluents; and,

• internal radiation from consumption of milk and meat containing radioactivity deposited on forage that is eaten by cattle and other livestock.

In addition, ambient (direct) radiation emitted from contained sources of radioactivity at PNPS contributes to radiation exposure in the vicinity of the plant. Radioactive nitrogen-16 contained in the steam flowing through the turbine accounts for the majority of this "sky shine" radiation exposure immediately adjacent to the plant. Smaller amounts of ambient radiation result from low-level radioactive waste stored at the site prior to shipping and disposal.

To the extent possible, the radiological dose impact on humans is based on direct measurements of radiation and radioactivity in the environment. When PNPS-related activity is detected in samples that represent a plausible exposure pathway, the resulting dose from such exposure is assessed (see Appendix A). However, the operation of Pilgrim Nuclear Power Station results in releases of only small amounts of radioactivity, and, as a result of dilution in the atmosphere and ocean, even the most sensitive radioactivity measurement and analysis techniques cannot usually detect these tiny amounts of radioactivity above that which is naturally present in the environment. Therefore, radiation doses are calculated using radioactive effluent release data and computerized dose calculations that are based on very conservative NRC-recommended models that tend to result in over-estimates of resulting dose. These computerized dose calculations are performed by or for Entergy Nuclear personnel. These computer codes use the guidelines and methodology set forth by the NRC in Regulatory Guide 1.109 (Reference 6). The dose calculations are documented and described in detail in the Pilgrim Nuclear Power Station's Offsite Dose Calculation Manual (Reference 7), which has been reviewed by the NRC.

Monthly dose calculations are performed by PNPS personnel. It should be emphasized, that because of the very conservative assumptions made in the computer code calculations, the maximum hypothetical dose to an individual is considerably higher than the dose that would actually be received by a real individual.

After dose calculations are performed, the results are compared to the federal dose limits for the public. The two federal agencies that are charged with the responsibility of protecting the public from radiation and radioactivity are the Nuclear Regulatory Commission (NRC) and The, Environmental Protection Agency (EPA).

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The NRC, in 10CFR 20.1301 (Reference 8) limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of:

• less than or equal to 100 mrem per year to the total body.

In addition to this dose limit, the NRC has established design objectives for nuclear plant licensees.

Conformance to these guidelines ensures that nuclear power reactor effluents are maintained as far below the legal limits as is reasonably achievable.

The NRC, in 10CFR 50 Appendix I (Reference 9) establishes design objectives for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to:

• less than or equal to 3 mrem per year to the total body; and,

• less than or equal to 10 mrem per year to any organ.

The air dose due to release of noble gases in gaseous effluents is restricted to:

• less than or equal to 10 mrad per year for gamma radiation; and,

" less than or equal to 20 mrad per year for beta radiation.

The dose to a member of the general public from iodine-1 31, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to:

• less than or equal to 15 mrem per year to any organ.

The EPA, in 40CFR1 90.10 Subpart B (Reference 10), sets forth the environmental standards for the uranium fuel cycle. During normal operation, the annual dose to any member of the public from the entire uranium fuel cycle shall be limited to:

• less than or equal to 25 mrem per year to the total body;

• less than or equal to 75 mrem per year to the thyroid; and,

" less than or equal to 25 mrem per year to any other organ.

The summary of the 2009 radiological impact for Pilgrim Station and comparison with the EPA dose limits and guidelines, as well as a comparison with natural/man-made radiation levels, is presented in Section 3 of this report.

The third stage of assessing releases to the environment is the Radiological Environmental Monitoring Program (REMP). The description and results of the REMP at Pilgrim Nuclear Power Station during 2009 is discussed in Section 2 of this report.

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2,0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.1 Pre-Operational Monitoring Results The Radiological Environmental Monitoring Program (REMP) at Pilgrim Nuclear Power Station was first initiated in August 1968, in the form of a pre-operational monitoring program prior to bringing the station on-line. The NRC's intent (Reference 11) with performing a pre-operational environmental monitoring program is to:

• measure background levels and their variations in the envirohment in the area surrounding the licensee's station; and,

• evaluate procedures, equipment, and techniques for monitoring radiation and radioactivity in the environment.

The pre-operational program (Reference 12) continued for approximately three and a half years, from August 1968 to June 1972. Examples of background radiation and radioactivity levels measured during this time period are as follows:

• Airborne Radioactivity Particulate Concentration (gross beta): 0.02 - 1.11 pCi/m 3 ;

• Ambient Radiation (TLDs): 4.2 - 22 micro-R/hr (37 - 190 mR/yr);

• Seawater Radioactivity Concentrations (gross beta): 12 - 31 pCi/liter;

• Fish Radioactivity Concentrations (gross beta): 2,200 - 11,300 pCi/kg;

• Milk Radioactive Cesium-137 Concentrations: 9.3 - 32 pCi/liter;

• Milk Radioactive Strontium-90 Concentrations: 4.7 - 17.6 pCi/liter;

• Cranberries Radioactive Cesium-1 37 Concentrations: 140 - 450 pCi/kg;

• Forage Radioactive Cesium-1 37 Concentrations: 150- 290 pCi/kg.

This information from the pre-operational phase is used as a basis for evaluating changes in radiation and radioactivity levels in the vicinity of the plant following plant operation. In April 1972, just prior to initial reactor startup (June 12, 1972), Boston Edison Company implemented a comprehensive operational environmental monitoring program at Pilgrim Nuclear Power Station.

This program (Reference 13) provides information on radioactivity and radiation levels in 'the environment for the purpose of:

• demonstrating that doses to the general public and levels of radioactivity in the environment are within established limits and legal requirements;

• monitoring the transfer and long-term buildup of specific radionuclides in the environment to revise the monitoring program and environmental models iný response to changing conditions; checking the condition of the station's operation, the adequacy of operation in relation to the adequacy of containment, and the effectiveness of effluent treatment so as to provide a mechanism of determining unusual or unforeseen conditions and, where appropriate, to trigger special environmental monitoring studies; assessing the dose equivalent to the general public and the behavior of radioactivity released during the unlikely event of an accidental release; and, Page 23

• determining whether or not the radiological impact on the environment and humans is significant.

The Nuclear Regulatory Commission requires that Pilgrim Station provide monitoring of the plant environs for radioactivity that will be released as a result of normal operations, including anticipated operational occurrences, and from postulated accidents. The NRC has established guidelines (Reference 14) that specify an acceptable monitoring program. The PNPS Radiological Environmental Monitoring Program was designed to meet and exceed these guidelines. Guidance contained' in the NRC's Radiological Assessment Branch Technical Position on Environmental Monitoring (Reference 15) has been used to improve the program. In addition, the program has incorporated the provisions of an agreement made with the Massachusetts Wildlife Federation (Reference 16). The program was supplemented by including improved analysis of shellfish and sediment at substantially higher sensitivity levels to verify the adequacy of effluent controls at Pilgrim Station.

2.2 Environmental Monitoring Locations Sampling locations have been established by considering meteorology, population distribution, hydrology, and land use characteristics of the Plymouth area. The sampling locations are divided into two classes, indicator and control. Indicator locations are those that are expected to show effects from PNPS operations, if any exist. These locations were primarily selected on the basis of where the highest predicted environmental concentrations would occur. While the indicator locations are typically within a few kilometers of the plant, the control stations are generally located so as to be outside the influence of Pilgrim Station. They provide a basis on which to evaluate fluctuations at indicator locations relative to natural background radiation and natural radioactivity and fallout from prior nuclear weapons tests.

The environmental sampling media collected in the vicinity of Pilgrim Station during 2009 included air particulate filters, charcoal cartridges, animal forage, vegetation, cranberries, seawater, sediment, Irish moss, shellfish, American lobster, and fishes: The sampling medium, station description, station number, distance, and direction for indicator and control samples are listed in Table 2.2-1.

These sampling locations are also displayed on the maps shown in Figures 2.2-1 through 2.2-6.

The radiation monitoring locations for the environmental TLDs are shown in Figures 2.2-1 through 2.2-4. The frequency of collection and types of radioactivity analysis are described in Pilgrim Station's ODCM, Sections 3/4.5.

The land-based (terrestrial) samples and monitoring devices are collected by Entergy personnel. The aquatic samples are collected by Marine Research, Inc. The radioactivity analysis of samples and the processing of the environmental TLDs are performed by Entergy's J.A. Fitzpatrick Environmental Laboratory.

The frequency, types, minimum number of samples, and maximum lower limits of detection (LLD) for the analytical measurements, are specified in the PNPS ODCM. During 2003, a revision was made to the PNPS ODCM to standardize it to the model program described in NUREG-1302 (Reference

14) and the Branch Technical Position of 1979 (Reference 15). In accordance with this standardization, a number of changes occurred regarding the types and frequencies of sample collections.

In regard to terrestrial REMP sampling, routine collection and analysis of soil samples was discontinued in lieu of the extensive network of environmental TLDs around PNPS, and the weekly collection of air samples at 11 locations. Such TLD monitoring and air sampling would provide an early indication of any potential deposition of radioactivity, and follow-up soil sampling could be performed on an as-needed basis. Also, with the loss of the indicator milk sample at the Plymouth Page 24

County Farm and the lack of a sufficient substitute location that could provide suitable volumes for analysis, it was deemed unnecessary to continue to collect and analyze control samples of milk.

Consequently, routine milk sampling was also dropped from the terrestrial sampling program. NRC guidance (Reference 14) contains provisions for collection of vegetation and forage samples in lieu of milk sampling. Such samples have historically been collected near Pilgrim Station as part of the.

routine REMP program..

In the area of marine sampling, a number of the specialized sampling and analysis requirements implemented as part of the Agreement with the Massachusetts Wildlife Federation (Reference 16) for licensing of a second reactor at PNPS were dropped. This agreement, made in 1977, was predicated on the construction of a second nuclear unit, and was set to expire in 1987. However, since the specialized requirements were incorporated into the PNPS Technical Specifications at the time, the requirements were continued. When the ODCM was revised in 1999 in accordance with NRC Generic Letter 89-01, the sampling program description was relocated to the ODCM. When steps were taken in 2003 to standardize the PNPS ODCM to the NUREG-1302 model, the specialized marine sampling requirements were changed to those of the model program. These changes include the following:

• A sample of the surface layer of sediment is collected, as opposed to specialized depth-incremental sampling to 30 cm and subdividing cores into 2 cm-increments.

• Standard LLD levels of about 150 to 180 pCi/kg were established for sediment, as opposed to the specialized LLDs of 50 pCi/kg.

e 'Specialized analysis of sediment for plutonium isotopes was removed.

0 Sampling of Irish moss, shellfish, and fish was rescheduled to a semiannual period, as opposed -to a specialized quarterly sampling interval.,

• Analysis of only .the edible portions of shellfish (mussels and clams), as opposed to specialized additional analysis of the shell portions.

• Standard LLD levels of 130 to 260 pCi/kg were established for edible portions of shellfish, as opposed to specialized LLDs of 5 pCi/kg.

The PNPS ODCM was revised in 2009. In conjunction with this revision, two changes were made to the environmental sampling program. Due to damage from past storms to the rocky areas at Manomet Point, there is no longer a harvestable population of blue mussels at this site. Several attempts have been made over the past years to collect samples from this location, but all efforts were unsuccessful. Because of unavailability of mussels at this location as a Viable human foodchain exposure pathway, this location was dropped from the sampling program. The other change involved the twice per year sampling of Group II fishes in the vicinity of the PNPS discharge outfall, represented by species such as cunner and tautog. Because these fish tend to move away from the discharge jetty during colder months, they are not available for sampling at a six-month semi-annual sampling period. The sampling program was modified to reduce the sampling for Group II fishes to once per year, when they are available during warmer summer months.

Upon receipt of the analysis results from the analytical laboratories, the PNPS staff reviews the results. If the radioactivity concentrations are above the reporting levels, the NRC must be notified within 30 days. For radioactivity that is detected that is attributable to Pilgrim Station's operation, calculations are performed to determine the cumulative dose contribution for the current year.

Depending upon the circumstances, a special study may also be completed (see Appendix A for 2009 special studies). Most importantly, if radioactivity levels in the environment become elevated as a result of the station's operation, an investigation is performed and corrective actions are recommended to reduce the amount of radioactivity to as far below the legal limits as is reasonably achievable.

The radiological environmental sampling locations are reviewed annually, and modified if necessary.

A garden and milk animal census is performed every year to identify changes in the use of the environment in the vicinity of the station to permit modification of the monitoring and sampling locations. The results of the 2009 Garden and Milk Animal Census are reported in Appendix C.

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The accuracy of the data obtained through Pilgrim Station's Radiological Environmental Monitoring Program is ensured through a comprehensive Quality Assurance (QA) programs. PNPS's QA program has been established to ensure confidence in the measurements and results of the radiological monitoring program through:

• Regular surveillances of the sampling and monitoring program;

• An annual audit of the analytical laboratory by the sponsor companies;

• Participation in cross-check programs;

• Use of blind duplicates for comparing separate analyses of the same sample; and,

• Spiked sample analyses by the analytical laboratory.

QA audits and inspections of the Radiological Environmental Monitoring Program are performed by the NRC, American Nuclear Insurers, and by the PNPS Quality Assurance Department.

The J.A. Fitzpatrick Environmental Laboratory conducts extensive quality assurance and quality control programs. The 2009 results of these programs are summarized in Appendix E. These results indicate that the analyses and measurements performed during 2009 exhibited acceptable precision and accuracy.

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N 2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2009. Data for each environmental medium are included in a separate section. A table that summarizes the year's data for each type of medium follows a discussion of the sampling program and results. The unit of measurement for each medium is listed at the top of each table. The left hand column contains the radionuclides being reported, total number of analyses of that radionuclide, and the number of measurements that exceed ten times the yearly average for the control station(s). The latter are classified as "non-routine" measurements. The next column lists the Lower Limit of Detection (LLD) for those radionuclides that have detection capability requirements specified in the PNPS ODCM.

Those sampling stations within the range of influence of Pilgrim.Station and which could conceivably be affected by its operation are called "indicator" stations. Distant stations, which are beyond plant influence, are called "control" stations. Ambient radiation monitoring stations are broken down into four separate zones to aid in data analysis.

For each sampling medium, each radionuclide is presented with a set of statistical parameters. This set of statistical parameters includes separate analyses for (1) the indicator stations, (2) the station having the highest annual mean concentration, and (3) the control stations. For each of these three groups of data, the following values are calculated:

• The mean value of detectable concentrations, including only those values above LLD;

• The standard deviation of the detectable measurements;

• The lowest and highest concentrations; and,

• The number of positive measurements (activity which is three times greater than the standard deviation), out of the total number of measurements.

Each single radioactivity measurement datum is based on a single measurement and is reported as a concentration plus or minus one standard deviation. The quoted uncertainty represents only the random uncertainty associated with the measurement of the radioactive decay process (counting statistics), and not the propagation of all possible uncertainties in the sampling and analysis process.

A sample or measurement is considered to contain detectable radioactivity if the measured value (e.g., concentration) exceeds three times its associated standard deviation. For example, a vegetation sample with a cesium-137 concentration of 85 +/- 21 pCi/kilogram would be considered "positive" (detectable Cs-137), whereas another sample with a concentration of 60 +/- 32 pCi/kilogram would be considered "negative", indicating no detectable cesium-137. The latter sample may actually contain cesium-1 37, but the levels counted during its analysis were not significantly different than background levels.

As an example of how to interpret data presented in the results tables, refer to the first entry on the table for air particulate filters (page 37). Gross beta (GR-B) analyses were performed on 564 routine samples. None of the samples exceeded ten times the average concentration at the control location. The lower limit of detection (LLD) required by the ODCM is 0.01 pCi/m 3 .

For samples collected from the ten indicator stations, 513 out of 513 samples indicated detectable activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 513 indicator station samples was 0.012 +/- 0.005 (1.2E-2 +/- 4.7E-3) pCi/m 3 . Individual values ranged from 0.001 to 0.025 (1.OE 2.5E-2) pCi/m 3.

The monitoring station which yielded the highest mean concentration was station WS (Medical Building), which yielded a mean concentration of 0.013 +/- 0.005 pCi/m 3, based on 52 observations.

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Individual values ranged from 0.0060 to 0.024 pCi/m 3. Fifty-two of the fifty-two samples showed detectable activity at the three-sigma level.

At the control location, 51 out of 51 samples yielded detectable gross beta activity, for an average concentration of 0.012 +/- 0.005 pCi/m 3. Individual samples at the control location ranged from 3

0.0050 to 0.023 pCi/m .

Referring to the last entry row in the table, analyses for cesium-137 (Cs-137) were performed 44 times (quarterly composites for 11 stations

• 4 quarters). No samples exceeded ten times the mean control station concentration. The required LLD value Cs-1 37 in the PNPS ODCM is 0.06 pCi/m 3 .

At the indicator stations, all 40 of the Cs-137 measurements were below the detection level. The same was true for the four measurements made on samples collected from the control location.

2.4 Ambient Radiation Measurements The primary technique for measuring ambient radiation exposure in the vicinity of Pilgrim Station involves posting environmental thermoluminescent dosimeters (TLDs) at given monitoring locations and retrieving the TLDs after a specified time period. The TLDs are then taken to a laboratory and processed to determine the total amount of radiation exposure received over the period. Although TLDs can be used to monitor radiation exposure for short time periods, environmental TLDs are typically posted for periods of one to three months. Such TLD monitoring yields average exposure rate measurements over a relatively long time period. The PNPS environmental TLD monitoring program is based on a quarterly (three month) posting period, and a total of 110 locations are monitored using this technique. In addition, 27 of the 110 TLDs are located onsite, within the PNPS protected/restricted area, where the general public does not have access.

Out of the 440 TLDs (110 locations

• 4 quarters) posted during 2009, 438 were retrieved and processed. Those TLDs missing from their monitoring locations were lost to storm damage, and/or building renovation, and their absence is discussed in Appendix D. The results for environmental TLDs located offsite, beyond the PNPS protected/restricted area fence, are presented in Table 2.4-

1. Results from onsite TLDs posted within the restricted area are presented in Table 2.4-2. In addition to TLD results for individual locations, results from offsite TLDs were grouped according to geographic zone to determine average exposure rates as a function of distance. These results are summarized in Table 2.4-3. All of the listed exposure values represent continuous occupancy (2190 hr/qtr or 8760 hr/yr).

Annual exposure rates measured at locations beyond the PNPS protected area boundary eanged from 45 to 204 mR/yr. The average exposure rate at control locations greater than 15 km ,from Pilgrim Station (i.e., Zone 4) was 62.5 +/- 9.3 mR/yr. When the 3-sigma confidence interval is calculated based on these control measurements, 99% of all measurements of background ambient exposure would be expected to be between 35 and 93 mR/yr. The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 45 to 87 mR/yr, which compares favorably with the preoperational results of 37 - 190 mR/yr.

Inspection of onsite TLD results listed in Table 2.4-2 indicates that all of those TLDs located within the PNPS protected/restricted area yield exposure measurements higher than the average natural background. Such results are expected due to the close proximity of these locations to radiation sources onsite. The radionuclide nitrogen-16 (N-16) contained in steam flowing through the turbine accounts for most of the exposure onsite. Although this radioactivity is contained within the turbine and is not released to the atmosphere, the "sky shine" which occurs from the turbine increases the ambient radiation levels in areas near the turbine building.

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A small number of offsite TLD locations in close proximity to the protected/restricted area indicated ambient radiation exposure above expected background levels. All of these locations are on Pilgrim Station controlled property, and experience exposure increases due to turbine sky shine (e.g.,

locations OA, TC, PB, and P01) and/or transit and storage of radwaste onsite (e.g., locations BLE and BLW). A hypothetical maximum exposed member of the public accessing these near-site areas

ýon Pilgrim Station controlled property-for limited periods of time would receive a maximum dose of about 1A4 mrem/yr above their average ambient background dose of 63 mrem/yr.

One TLD, located in the basement of the Plymouth Memorial Hall, indicated an annual exposure of 77 mR in 2009. The higher exposure within the building at this location is due to the close proximity of stone building material, which contains higher levels of naturally-occurring radioactivity, as well as from the buildup of radon in this area of the building.

It should be noted that several of the TLDs used to calculate the Zone 1 averages presented in Table 2.4-3 are located on Pilgrim Station property., If the Zone 1 value is corrected for the near-site TLDs (those less than 0.6 km from the Reactor Building), the Zone 1 mean falls from a value of 76.4

+/- 27.1 mR/yr to 65.3 +/- 10.8 mR/yr. Additionally, exposure rates measured at areas beyond Entergy's control did not indicate a ny increase in ambient exposure from Pilgrim Station operation.

For example, the annual exposure rate calculated from the two TLDs adjacent to the nearest offsite residence 0.80 kilometers (0.5 miles) southeast of the PNPS Reactor Building was 66.1 +/- 16.1 mR/yr, which compares quite well with the average control location exposure of 62.5 +/--9.3 mR/yr.

In conclusion, measurements of ambient radiation exposure around Pilgrim Station do not indicate any significant increase in exposure levels. Although some increases in ambient radiation exposure level were apparent on Entergy property very close to Pilgrim Station, there were no measurable increases at areas beyond Entergy's control.

2.5 Air Particulate Filter Radioactivity Analyses Airborne particulate radioactivity is sampled by drawing a stream of air through a glass fiber filter that has a very high efficiency for collecting airborne particulates. These samplers are operated continuously, and the resulting filters are collected weekly for analysis. Weekly filter samples are analyzed for gross beta radioactivity, and the filters are then composited on a quarterly basis for each location for gamma spectroscopy analysis. PNPS uses this technique to monitor 10 locations in the Plymouth area, along with the control location in East Weymouth.

Out of 572 filters (11 locations

• 52 weeks), 564 samples were collected and analyzed during 2009.

There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes. All of these discrepancies are noted in Appendix D.

The results of the analyses performed on these 564 filter samples are summarized in Table 2.5-1.

Trend plots for the gross beta radioactivity levels at the near station, property line, and offsite airborne monitoring locations, are shown in Figures 2.5-1, 2.5-2 and 2.5-3, respectively. Gross beta radioactivity was detected in 564 of the filter samples collected, including 51 of the 51 control location samples. This gross beta activity arises from naturally-occurring radionuclides such as radon decay daughter products. Naturally-occurring beryllium-7 was detected in 44 out of 44 of the quarterly composites analyzed with gamma spectroscopy. Naturally-occurring potassium-40 (K-40) was detected in 10 of 40 indicator samples, and in none of four control samples. No airborne radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.6 Charcoal Cartridae Radioactivity Analyses Airborne radioactive iodine is sampled by drawing a stream of air through a charcoal cartridge after it has passed through the high efficiency glass fiber filter. As is the case with the air particulate filters, these samplers are operated continuously, and the resulting cartridges are collected weekly for analysis. Weekly cartridge samples are analyzed for radioactive iodine. The same eleven locations monitored for airborne particulate radioactivity are also sampled for airborne radioiodine.

Out of 572 cartridges (11 locations

• 52 weeks), 564 samples were collected and analyzed during 2009. There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes.

All of these discrepancies are noted in Appendix D. Despite such events during 2009, required LLDs were met on 564 of the 564 cartridges collected during 2009.

The results of the analyses performed on these charcoal cartridges are summarized in Table 2.6-1.

No airborne radioactive iodine was detected in any of the charcoal cartridges collected.

2.7 Milk Radioactivity Analyses In July 2002, the Plymouth County Farm ceased operation of its dairy facility. This was historically the only dairy facility near Pilgrim Station, and had been sampled continuously since Pilgrim Station began operation in 1972. Although attempts were made to obtain samples from an alternate indicator location within 5 miles as specified in NRC guidance (Reference 14), a suitable substitute location could not be found. Thus, milk collection at an indicator location was discontinued in July 2002, but control samples of milk continued to be collected and analyzed in the event an indicator location could be secured. In conjunction with the standardization of the ODCM during 2003, the decision was made to remove milk sampling from the PNPS Radiological Environmental Monitoring Program since suitable no milk sampling location existed in the vicinity of Pilgrim Station.

The nearest milk animals to Pilgrim Station are located at the Plimoth Plantation, approximately 2.5 miles west of PNPS, in a relatively upwind direction. Due to the limited number of milk animals available, this location is not able to provide the necessary volume of 4 gallons of milk every two weeks to facilitate the milk sampling program and meet the required detection sensitivities. Although milk sampling is not performed at Plimoth Plantation, effluent dose calculations are performed for this location assuming the presence of a milk ingestion pathway, as part of the annual Effluent and Waste Disposal Report (Reference 17).

As included in a provision in standard ODCM guidance in NUREG-1302 (Reference 13), sampling and analysis of vegetation from the offsite locations calculated to have the highest D/Q deposition factor can be performed in lieu of milk sampling. Such vegetation sampling has been routinely performed at Pilgrim Station as part of the radiological environmental monitoring program, and the results of this sampling are presented in Section 2.9.

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2.8 Forage Radioactivity Analyses Samples of animal forage (hay) are collected from the Plymouth County Farm, and from control locations in Bridgewater. Samples are collected annually and analyzed by gamma spectroscopy.

Two samples of forage were collected and analyzed as required during 2009. Results of the gamma analyses of forage samples are summarized in Table 2.8-1. Naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228 were detected in forage samples collected during 2009. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.9 VegetableNegetation Radioactivity Analyses Samples of vegetables had historically been collected from the Plymouth County Farm and from the control location in Bridgewater. In addition, samples of vegetables or leafy vegetation were collected at or near a number of gardens identified during the Annual Land Use Census. Results of this census are discussed in Appendix C. In addition to these garden samples, naturally-growing vegetation is collected from locations yielding the highest D/Q deposition fact6?s. All of the various samples of vegetables/vegetation are collected annually and analyzed by gamma spectroscopy.

Nineteen samples of vegetables/vegetation were collected and analyzed as required during 2009.

Results of the gamma analyses of these samples are summarized in Table 2.9-1. Naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228 were identified in most of the samples collected. Cesium-137 was also detected in seven out of 12 samples of naturally-growing vegetation collected, and two out of seven control samples collected, with concentrations ranging from 3 to 89 pCi/kg. The highest concentration of 89 pCi/kg was detected in a sample of natural vegetation collected from a control location in Sandwich. These Cs-137 results are in the range expected for weapons-testing fallout (75 to 145 pCi/kg), and are not indicative of any releases associated with Pilgrim Station. Cs-137 has a 30-year half-life, and measureable concentrations still remain in soil and vegetation as a result of atmospheric weapons testing performed during the 1950s through 1970s. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.10 Cranberry Radioactivity Analyses Samples of cranberries are routinely collected from two bogs in the Plymouth area and from the control location in Kingston. Samples of cranberries are collected annually and analyzed by gamma spectroscopy. InW2002, the bog at Manomet Point ceased harvesting operations, and a sample was collected from an alternate location along Beaver Dam Road. Samples were also not available from the historical control location in Halifax, and a substitute control sample was collected from a bog in Kingston. These discrepancies are noted in Appendix D.

Three samples of cranberries were collected and analyzed during 2009. Results of the gamma analyses of cranberry samples are summarized in Table 2.10-1. Cranberry samples collected during 2009 yielded detectable levels of naturally-occurring potassium-40 and radium-226. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results, of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.11 Soil Radioactivity Analyses In the past, a survey of radioactivity in soil had been conducted once every three years at the 10 air sampling stations in the Plymouth area and the control location in East Weymouth. However, in conjunction with standardization of the ODCM during 2003, the soil survey effort was abandoned in favor of the extensive TLD monitoring effort at Pilgrim Station. Prior to ending the soil survey effort, there had been no apparent trends in radioactivity measurements at these locations.

2.12 Surface Water Radioactivity Analyses Samples of surface water are routinely collected from the discharge canal, Bartlett Pond in Manomet and from the control location at Powder Point Bridge in Duxbury. Grab samples are collected weekly from the Bartlett Pond and Powder Point Bridge locations. Samples of surface water are composited every four weeks and analyzed by gamma spectroscopy and low-level iodine analysis. These monthly composites are further composited on a quarterly basis and tritium analysis is performed on this quarterly sample.

A total of 36 samples (3 locations

• 12 sampling periods) of surface water were collected and analyzed as required during 2009. Results of the analyses of water samples are summarized in Table 2.12-1. Naturally-occurring potassium-40, radium*-226, and actinium/thorium-228 were detected in several of the' samples, especially those composed primarily of seawater. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

In response to the Nuclear Energy Institute' Groundwater Protection Initiative, Pilgrim Station installed a number of groundwater monitoring wells within the protected area in late 2007. Because all of these wells are onsite, they are not included in the offsite radiological monitoring program, and are not presented in this report. Details regarding Pilgrim Station's groundwater monitoring effort can be found in the Annual Radiological Effluent Release Report.

2.13 Sediment Radioactivity Analyses Samples of sediment are routinely collected from the outfall area of the discharge canal and from three other locations in the Plymouth area (Manomet Point, Plymouth Harbor and Plymouth Beach),

and from control locations in Duxbury and Marshfield. Samples are collected twice per year and are analyzed by'gamma spectroscopy.

Twelve samples of sediment were collected during 2009. Gamma analyses were performed on these samples. Results of the gamma analyses of sediment samples are summarized in Table 2.13-

1. Naturally-occurring beryllium-7, potassium-40, radium-226, and actinium/thorium-228 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.14 Irish Moss Radioactivity Analyses Samples of Irish moss are collected from the discharge canal outfall and two other locations in the Plymouth area (Manomet Point, Ellisville), and from a control location in Marshfield (Green Harbor).

All samples are collected on a semiannual basis, and processed in the 'laboratory for gamma spectroscopy analysis.

Eight samples of Irish moss scheduled for collection during 2009 were obtained and analyzed.

Results of the gamma analyses of these samples are summarized in Table 2.14-1. Naturally-occurring beryllium-7, potassium-40, and actinium/thorium-228 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.15 Shellfish Radioactivity Analyses Samples of blue mussels, soft-shell clams and quahogs are collected from the discharge canal outfall and one other location in the Plymouth area (Plymouth Harbor), and from control locations in Duxbury and Marshfield. All samples are collected on a semiannual basis, and edible portions processed in the laboratory for gamma spectroscopy analysis.

Ten of the 10 required samples of shellfish meat scheduled for collection during 2009 were obtained and analyzed. Results of the gamma analyses of these samples are summarized in Table 2.15-1.

Naturally-occurring potassium-40 and radium-226 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.16 Lobster Radioactivity Analyses Samples of lobsters are routinely collected from the outfall area of the discharge canal and from control locations in Cape Cod Bay and Vineyard Sound. Samples are collected monthly from the discharge canal outfall from June through September and once annually from the control locations.

All lobster samples are normally analyzed by gamma spectroscopy.

Six samples of lobsters were collected as required during 2009. Results of the gamma analyses of these samples are summarized in Table 2.16-1. Naturally-occurring potassium-40 and radium-226 were detected in a number of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.17 Fish Radioactivity Analyses Samples of fish are routinely collected from the area at the outfall of the discharge canal and from the control locations in Cape Cod Bay and Buzzard's Bay. Fish species are grouped into four major categories according to their biological requirements and mode of life. These major categories and the representative species are as follows:

" Group I - Bottom Oriented: Winter Flounder, Yellowtail Flounder

" Group II - Near-Bottom Distribution: Tautog, Cunner, Pollock, Atlantic Cod, Hake

" Group III - Anadromous: Alewife, Smelt, Striped Bass

" Group IV - Coastal Migratory: Bluefish, Herring, Menhaden, Mackerel Group I fishes are sampled on a semiannual basis from the outfall area of the discharge canal, and on an annual basis from a control location. Group II, Ill, and IV fishes are sampled annually from the discharge canal outfall and control location. All samples of fish are analyzed by gamma spectroscopy.

Nine samples of fish were collected during 2009. Results of the gamma analyses of fish samples collected are summarized in Table 2.17-1. The only radionuclides detected in any of the samples were naturally-occurring potassium-40 and radium-226. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2009, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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Table 2.2-1 Routine Radiological Environmental Sampling Locations Pilgrim Nuclear Power Station, Plymouth, MA Description Code Distance Direction Air Particulate Filters, Charcoal Cartridges Medical Building WS 0.2 km SSE East Rocky Hill Road ER 0.9 km SE West Rocky Hill Road WR 0.8 km WNW Property Line PL 0.5 km NNW Pedestrian Bridge PB 0.2 km N Overlook Area OA 0.1 km W East Breakwater EB 0.5 km ESE Cleft Rock CR 1.3 km SSW Plymouth Center PC 6.7 km W Manomet Substation MS 3.6 km SSE East Weymouth Control EW 40 km NW Foraoe Plymouth County Farm CF 5.6 km W Hansen Farm Control HN 35 km W Vegetation Plymouth County Farm CF 5.6 km W Hansen Farm Control HN 35 km W Cranberries Bartlett Road Bog BT 4.3 km SSE Beaverdam Road Bog MR 3.4 km S Hollow Farm Bog Control HF 16 km WNW Page 35

Table 2.2-1 (continued)

Routine Radiological Environmental Sampling Locations Pilgrim Nuclear Power Station, Plymouth, MA Description Code Distance Direction Surface Water Discharge Canal DIS 0.2 km N Bartlett Pond BP 2.7 km SE Powder Point Control PP 13 km NNW Sediment Discharge Canal Outfall DIS 0.8 km NE Plymouth Harbor Ply-H 4.1 km W Duxbury Bay Control Dux-Bay 14 km NNW Plymouth Beach PLB 4.0 km WNW Manomet Point MP 3.3 km ESE Green Harbor Control GH 16 km NNW Irish Moss Discharge Canal Outfall DIS 0.7 km NNE Manomet Point MP 4.0 km ESE Ellisville EL 12 km SSE Brant Rock Control BR 18 km NNW Shellfish Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor Ply-H 4.1 km W Duxbury Bay Control Dux-Bay 13 km NNW Manomet Point MP 4.0 km ESE Green Harbor Control GH 16 km NNW Lobster Discharge Canal!Outfall DIS 0.5 km N Plymouth Harbor Ply-H 6.4 km WNW Duxbury Bay Control Dux-Bay 11 km NNW Fishes Discharge Canal Outfall DIS 0.5 km N Priest Cove Control PC 48 km SW Jones River Control JR 13 km WNW Vineyard Sound Control MV 64 km SSW Buzzard's Bay Control BB 40 km SSW Cape Cod Bay Control CC-Bay 24 km ESE Page 36

Table 2.4-1 Offsite Environmental TLD Results TLD Station TLD Location* Quartery Exposure - mRlquarter (Value + Std.Dev.)

ID Description Distance/Direction Jan-Mar- Apr-Jun f 1 Jul-Sep Oct-Dec 2009 Annual*

Exposure I I mR/year Zone 1 TLDs: 0-3 kn 0-3 km 18.8 +/- 5.7 18.2 +/- 5.1 20.7 +/- 8.1 18.7 +/- 7.7 76.4 27.1 BLW BOAT LAUNCH WEST 0.11 km E 32.8 +/- 2.2 31.8 +/- 1.4 40.0 +/- 1.5 33.7 +/- 1.4 138.2 + 15.2 OA OVERLOOK AREA 0.15 kmW 47.6+/- 1.7 38.4+/-2.2 59.1 +/-2.7 60.3+/-2.6 205.4+/-41.6 TC HEALTH CLUB 0.15 km WSW 21.0 +/- 0.9 17.5 +/- 0.7 25.8 +/- 0.9 23.4 +/- 0.9 87.7 14.3 BLE BOAT LAUNCH EAST 0.16 km ESE 25.9 +/- 1.7 25.8 +/- 1.4 33.6 +/- 1.0 28.2 +/- 1.2 113.4 +/- 14.9 PB PEDESTRIAN BRIDGE 0.21 km N 26.6 +/- 0.8 23.4 +/- 1.6 27.9 +/- 1.4 28.8 +/- 0.9 106.7 +/- 9.8 P01 SHOREFRONT SECURITY 0.22 km NNW 21.6 +/- 0.8 18.7 +/- 1.0 24.4 +/- 0.9 23.6 +/- 0.9 88.3 +/- 10.4 WS MEDICAL BUILDING 0.23 km SSE 21.2 +/- 0.8 24.9 +/- 1.9 30.4 +/- 1.3 23.1 +/- 0.7 99.7 +/- 16.1 CT PARKING LOT 0.31 km SE 17.3 +/- 0.8 16.7 +/- 2.1 24.5 +/- 1.4 19.7 +/- 0.6 78.1 +/- 14.4 PA SHOREFRONT PARKING 0.35 km NNW 18.6 +/- 0.8 17.4 +/- 3.1 20.9 +/- 1.4 18.7 +/- 0.7 75.6 +/- 7.0 A STATION A 0.37 km WSW 16.2 +/- 0.6 18.5 +/- 1.2 17.8 +/- 1.2 18.4 +/- 1.9 70.9 +/- 5.0 F STATION F 0.43 km NW 17.8 +/- 0.8 17.9 +/- 0.8 17.3 +/- 0.7 16.3 +/- 0.8 69.2 +/- 3.3 EB EAST BREAKWATER 0.44 km ESE 15.9 +/- 0.7 16.1 +/- 1.2 21.9 +/- 1.9 15.1 +/- 0.6 69.1 +/- 12.7 B STATION B 0.44 km S 22.2 +/- 0.9 22.2 +/- 1.0 22.5 +/- 1.3 20.1 +/- 0.8 87.0 +/- 4.8 PMT PNPS METTOWER 0.44 krn WNW 18.5 +/- 0.7 19.8 +/- 1.0 19.4 +/- 1.1 17.9 +/- 0.8 75.6 +/-3.9 H STATION H 0.47 km SW 22.2 +/- 0.8 Missing 19.9 +/- 0.7 17.9 +/- 0.9 79.9 +/- 8.7 I STATION I 0.48 km WNW 17.4 +/- 0.6 16.8 +/- 1.0 17.3 +/- 0.7 16.0 +/- 0.7 67.5 +/-3.0 L STATION L 0.50 km ESE 18.4 +/- 0.7 19.6 +/- 1.3 24.8 +/- 1.5 17.2 +/- 0.9 80.0 13.5 G STATION G 0.53 km W 16.4 +/- 0.6 12.4 +/- 1.2 16.8 +/- 1.1 16.2 +/- 0.9 61.8 +/-8.4 D STATION D 0.54 km NNW 19.4 +/- 0.9 19.4 +/- 1.0 18.3 +/- 0.7 16.2 +/- 0.8 73.3 +/-6.1 P.L PROPERTY LINE 0.54 km NW 17.3 +/- 0.7 14.2 +/- 0.6 18.5:+/- 1.2 17.2 +/- 1.1 67.2 +/-7.6 C STATION C 0.57 km ESE 17.3 +/- 0.7 18.3 +/- 1.1 23.3 +/- 1.1 17.6 +/- 1.0 76.5 +/-11.5 HB HALL'S BOG 0.63 km SE 16.8 +/- 0.7 18.0 +/- 0.9 25.2 +/- 1.1 16.9 +/- 0.7 76.9 +/-16.0 GH GREENWOOD HOUSE 0.65 km ESE 20.0 +/- 2.4 19.5 +/- 0.9 26.1 +/- 1.4 19.5 +/- 0.7 85.2 13.3 WR W ROCKY HILL ROAD 0.83 km WNW 19.8 +/- 1.0 25.8 +/- 7.8 21.1 +/- 0.9 20.6 +/- 0.6 87.2+/- 13.5 ER E ROCKY HILL ROAD 0.89 km SE 14.5 +/- 1.0 12.2 +/- 0.9 15.5 +/- 0.8 13.1 +/- 0.9 55.3 + 6.2 MT MICROWAVE TOWER 1.03 km SSW 17.7 +/- 0.7 15.0 +/- 1.1 18.2 +/- 1.0 17.0 +/- 0.8 67.9 +/- 5.8 CR CLEFT ROCK 1.27 km SSW 17.7+/-0.6 15.1 +/- 1.0 19.1 +/- 1.3 17.5 +/- 0.6 69.4+/-6.9 B) BAYSHORE/GATE RD 1.34 km WNW 16.6 +/- 0.6 17.1 +/- 1.0 17.0+/-10.7 15.9 +/- 0.7 66.6 +/-2.5 MR MANOMET ROAD 1.38 km S 19.2 +/- 1.0 20.3 +/- 1.5 19.0 +/- 1.2 16.9 +/- 0.9 75.4 +/- 6.0 DR DIRT ROAD 1.48 kmýSW 14.9 +/- 1.1 14.6 +/- 0.8 14.6 +/- 0.9 13.4 +/- 0.7 57.5 +/- 3.2 EM EMERSON ROAD 1.53 km SSE 16.6 +/- 1.2 14.6+/- 1.2 15.1 +/- 0.6 15.2 +/- 0.9 61.4 +/-4.0 EP EMERSON/PRISCILLA 1.55 km SE 16.2 +/- 0.6 14.0 +/- 0.6 15.5 +/- 0.6 15.4 +/- 0.6 61.0 +/- 3.9 AR EDISON ACCESS ROAD 1.59 km SSE 15.3 +/- 0'6 16.0 +/- 1.0 15.9 +/- 0.8 , 13.9 +/- 0.8 61.1 +/- 4.1 BS BAYSHORE 1.76 km W 18.6 +/- 1.0 20.1 +/- 1.2 18.6 +/- 1.0 18.0 +/- 1.0 75.3 +/-4.1 E STATION E 1.86 km S 17.2 +/- 1.6 17.3 +/- 1.2 17.2 +/- 0.8 15.3 +/- 0.6 67.0 +/-4.4 JG JOHN GAULEY 1.99 kmW 17.1 +/-1.0 17.8+/-1.0 17.6+/-0.8 16.6+/-0.6 69.1 +/-2.7 J STATION J 2.04 km SSE 16.5 +/- 0.6 15.9 +/- 1.0 17.2 +/- 0.7 14.5 +/- 0.7 64.1 +/- 4.8 WH WHITEHORSE ROAD 2.09 km SSE 17.3 +/- 1.6 14.6 +/- 0.7 15.2 +/- 1.0 16.2 +/- 0.7 63.2 +/- 5.2 RC PLYMOUTH YMCA 2.09 km WSW 16.7 +/- 0.8 17.5 +/- 0.9 16.3.+/- 0.8 14.8 +/- 0.9 65.4 +/- 4.8 K STATION K 2.17 km S 14.4 +/- 1.4 14.4 +/- 0.6 13.7 +/- 0.8 13.4 +/- 0.6 55.9 +/- 2.7 TT TAYLOR/THOMAS 2.26 km SE 15.7 +/- 1.4 13.9 +/- 1.3 14.4 +/- 0.7 14.9 +/- 0.7 58.9+/- 3.7 YV YANKEE VILLAGE 2.28 km WSW 17.1 +/-0.7 16.7+/- 1.3 16.0 +/- 0.9 16.6+/-0.8 66.5+/-2.6 GN GOODWIN PROPERTY 2.38 km SW 12.7 +/- 0.6 13.8 +/- 0.6 12.1 +/- 0.6 11.3 +/- 0.5 50.0 +/- 4.3 RW RIGHT OF WAY 2.83 km S 13.2 +/- 1.6 11.9 +/- 0.6 12.2 +/- 0.5 13.4 +/- 0.7 50.8 +/- 3.5 TP TAYLOR/PEARL 2.98 km SE 14.6+/-1.2 14.2+/-2.9 13.5+/- 1.7 14.2+/-0.8 56.5+/-4.1

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

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Table 2.4-1 (continued)

Offsite Environmental TLD Results TLD Station TLD Location* Quarterl Exposure - mR/quarter (Value +/- Std.Dev.)

II 2009 Annualr ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure Zone 2 TLDs: 3-8km 3-8km 15.6+/- 1.8 14.5+/- 1.7 15.6+/-2.3 14.8+/-2.2 60.5+/-8.1 VR VALLEY ROAD 3.26 km SSW 14.1 +/- 0.5 14.4 +/- 1.1 16.0 +/- 0.7 13.8 +/- 1.0 58.2 +/- 4.3 ME MANOMET ELEM 3.29 km SE 17.8 +/- 1.0 14.3 +/- 0.7 14.2 +/- 0.6 15.4 +/- 1.9 61.7 +/- 7.0 WC WARREN/CLIFFORD 3.31 kmW 14.9+/- 1.0 15.4+/- 1.3 15.2+/-0.6 15.0+/- 1.1 60.4+/-2.2 BB RT.3AJBARTLETT RD 3.33 km SSE 16.3 +/- 0.8 16.0 +/- 0.8 17.2 +/- 1.1 15.6 +/- 0.8 65.0 +/- 3.1 MP MANOMET POINT 3.57 km SE 15.2 +/- 1.2 13.7 +/- 0.8 13.8 +/- 0.6 15.2 +/- 1.1 57.9 +/- 4.0 MS MANOMET SUBSTATION 3.60 km SSE 18.5 +/- 1.0 15.9 +/- 1.0 20.3 +/- 0.8 19.4 +/- 0.6 74.1 +/- 7.8 BW BEACHWOOD ROAD 3.93 km SE 16.2 +/- 1.8 14.6 +/- 1.1 14.2 +/- 0.5 14.9 +/- 0.8 59.9 +/- 4.1 PT PINES ESTATE 4.44 km SSW 14.8 +/- 1.0 12.4 +/- 1.1 13.7 +/- 0.6 14.3 +/- 0.8 55.2 +/- 4.5 EA EARL ROAD 4.60 km SSE 15.2 +/- 1.2 15.6 +/- 1.2 16.4 +/- 0.9 13.7 +/- 0.9 60.8 +/- 4.9 SP S PLYMOUTH SUBST 4.62 kmW 16.2+/- 1.4 17.1 +/-1.1 18.6+/-2.5 14.8+/-0.6 66.7+/-7.1 RP ROUTE 3 OVERPASS 4.81 km SW 15.8 +/- 1.0 15.7 +/- 1.8 17.3 +/- 0.9 14.5 +/- 1.4 63.3 +/- 5.3 RM RUSSELL MILLS RD 4.85 km WSW 14.0 +/- 1.1 15.1 +/- 0.8 15.8 +/- 0.7 14.7 +/- 1.1 59.6 +/- 3.5 HD HILLDALE ROAD 5.18 kmW 16.2+/-0.8 15.9+/-1.0 16.3+/-1.0 16.5+/-1.1 64.9+/-2.1 MB MANOMET BEACH 5.43 km SSE 16.0 +/- 1.1 14.4 +/- 1.0 15.1 +/- 0.6 14.9 +/- 0.8 60.3 +/- 3.3 BR BEAVERDAM ROAD 5.52 km S 16.5 +/- 0.7 14.9 +/- 1.1 15.2 +/- 0.9 15.5 +/- 1.4 62.1 +/- 3.5 PC PLYMOUTH CENTER 6.69 kmW 13.1 +/-1.0' 10.0+/- 1.5 10.6+/-0.7 11.1 +/-0.5 44.8+/-5.8 LD LONG POND/DREW RD 6.97 km WSW 14.0 +/- 0.5 13.5 +/- 0.7 14.2 +/- 0.7 12.8 +/- 0.7 54.5 +/- 2.8 HR HYANNIS ROAD 7.33 km SSE 14.3 +/- 1.7 13.1 +/- 0.7 13.7 +/- 0.5 13.9 +/- 0.8 55.0 +/- 2.9 SN SAQUISH NECK 7.58 km NNW 12.7 +/- 0.8 11.9 +/- 1.1 17.3 +/- 1.5 10.9 +/- 0.6 52.7 +/-11.5 MH MEMORIAL HALL 7.58 km WNW 20.3 +/- 0.9 16.8 +/- 0.7 19.8 +/- 1.1 20.2 +/- 1.2 77.1 + 7.0 CP COLLEGE POND 7.59 km SW 14.8 +/- 0.7 13.6 +/- 1.3 13.3 +/- 0.8 13.7 +/- 1.3 55.5 +/-3.3 Zone 3 TLDs: 8-15 km 8-15 km 14.9 +/- 1.5 13.6 +/- 2.0 13.8 +/- 1.9 14.1 +/- 1.3 56.4 +/- 6.7 DW DEEP WATER POND 8.59 kmW 15.9+/-0.6 15.3+/-1.1 14.7+/-0.6 15.7+/-0.8 61.6+/-2.7 LP LONG POND ROAD 8.88 km SSW 13.9 +/- 1.4 12.0 +/- 1.2 12.3 +/- 0.9 13.0 +/- 0.5 51.2 +/- 4.0 NP NORTH PLYMOUTH 9.38 km WNW 18.1 +/- 0.8 18.5 +/- 1.6 17.4 +/- 0.7 16.1 +/- 0.6 70.1 +/- 4.8 SS STANDISH SHORES 10.39 km NW 14.9 +/- 0.6 12.5 +/- 0.8 15.0 +/- 1.4 14.4 +/- 0.8 56.8 +/- 5.1 EL ELLISVILLE ROAD 11.52 km SSE 15.8 +/- 1.0 13.6 +/- 0.7 14.8 +/- 0.8 15.2 +/- 0.7 59.4 +/- 4.0 UC UP COLLEGE POND RD 11.78 km SW 12.8 +/- 0.5 12.0 +/- 1.1 11.9 +/- 0.9 12.3 +/- 0.5 49.0 +/- 2.3 SH SACRED HEART 12.92 km W 14.9 +/- 1.1 13.8 +/- 0.7 12.2 +/- 0.6 13.9 +/- 1.1 54.7 +/- 4.7 KC KING CAESAR ROAD 13.11 km NNW 13.8 +/- 0.8 12.6 +/- 1.1 14.9 +/- 1.3 13.6 +/- 0.7 54.9 +/- 4.3 BE BOURNE ROAD 13.37 km S 14.3 +/- 0.6 12.8 +/- 0.9 12.3 +/- 0.8 12.9 +/- 0.6 52.3 +/- 3.7 SA SHERMAN AIRPORT 13.43 km WSW 15.0 +/- 0.7 13.1 +/- 0.9 12.2 +/- 0.6 14.2 +/- 1.4 54.5 +/- 5.3 Zone4TLDs: >15km >15km 16.4+/-2.2 14.2+/- 1.4 16.7+/-2.6 15.3+/-2.6 62.5+/-9.3 CS CEDARVILLE SUBST 15.93 km S 17.3 +/- 0.9 14.9 +/- 0.8 15.6 +/- 1.0 15.8 +/- 0.6 63.5 +/- 4.2 KS KINGSTON SUBST 16.15 km WNW 14.9 +/- 0.7 14.4 +/- 1.2 14.4 +/- 0.6 14.3 +/- 0.6 57.9 +/- 1.9 LR LANDING ROAD 16.46 km NNW 15.7 +/- 0.6 12.8 +/- 0.9 16.5 +/- 0.8 14.3 +/- 0.6 59.3 +/- 6.7 CW CHURCH/WEST 16.56 km NW 13.3 +/- 1.1 12.0 +/- 1.0 15.5 +/- 1.1 11.7 +/- 0.5 52.5 +/- 7.2 MM MAIN/MEADOW 17.02 km WSW 15.7 +/- 0.6 14.1 +/- 0.7 14.4 +/- 0.7 13.9 +/- 0.6 58.1 +/- 3.4 DMF DIV MARINE FISH 20.97 km SSE 19.1 +/- 1.1 1 16.1 +/- 0.9 20.9 +/- 0.9 17.2 +/- 0.5 73.2 +/- 8.7 EW E WEYMOUTH SUBST 39.69 km NW .19.0 +/- 1.7 15.0 +/- 1.3 19.5 +/- 1.1 19.6 +/- 0.9 73.1 +/- 9.2

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 38

Table 2.4-2 Onsite Environmental TLD Results TLD Station TLD Location* Quarter)i Exposure - mR/quarter (Value + Std.Dev.)

2009 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure

__ mRlyear Onsite TLDs P21 O&M/RXB. BREEZEWAY 50 m SE 24.6 +/- 1.2 25.4 +/- 1.1 27.3 +/- 1.0 27.1 +/- 1.3 104.4 +/- 5.7 P24 EXEC.BUILDING 57mW 41.5 +/- 1.5 Missing 52.7 +/- 1.9 45.6 +/- 2.1 186.4 +/- 23.1 P04 FENCE-R SCREENHOUSE 66 m N 58.8 +/- 2.5 64.1 +/- 2.3 68.1 +/- 3.7 63.4 +/- 1.9 254.3 +/- 16.1 P20 O&M - 2ND W WALL 67mSE 26.8+/- 1.6 26.6+/- 1.4 32.0+/-1.7 28.6+/- 1.4 113.9+/- 10.4 P25 EXEC.BUILDING LAWN 76 m WNW 49.9 +/- 1.7 85.3 +/- 7.0 116.4 +/- 4.2 135.7 +/- 4.8 387.2 +/- 150.6 P05 FENCE-WATER TANK 81 m NNE 24.2 +/- 0.8 23.0 +/- 1.6 24.9 +/- 1.1 27.4 +/- 1.1 99.4 +/- 7.7 P06 FENCE-OIL STORAGE 85 m NE 30.9 +/- 1.9 30.2 +/- 1.6 35.4 +/- 1.7 35.9 +/- 1.5 132.4 +/- 12.3 P19 O&M - 2ND SW CORNER 86 m S 21.9 +/- 0.9 20.1 +/- 1.0 21.8 +/-0.8 26.5 +/-1.7 90.2 +/-11.1 P18 O&M- 1ST SW CORNER 90mS 26.9+/- 1.9 26.3+/- 1.1 32.4+/- 1.2 32.5+/-2.7 118.2+/- 14.0 P08 COMPRESSED GAS STOR 92 m E 28.9 +/- 1.6 29.5 +/- 2.0 36.3 +/- 2.8 35.2 +/- 1.2 129.9 +/- 15.7 P03 FENCE-L SCREENHOUSE 100 m NW 35.6 +/- 1.1 34.8 +/- 1.7 40.8 +/- 1.4 42.0 _ 1.9 153.0 +/- 14.9 P17 FENCE-EXEC.BUILDING 107 m W 56.0 +/- 1.9 55.9 +/- 2.9 75.7 +/- 2.6 67.3 +/- 2.0 255.0 +/- 38.8 P07 FENCE-INTAKE BAY 121 m ENE 27.0 +/- 1.9 25.9 +/- 1.1 29.6 +/- 1.7 30.6 +/- 1.3 113.1 +/- 9.3 P23 O&M - 2ND S WALL 121 m SSE 21.9 +/- 1.1 20.5 +/- 1.0 24.3 +/- 1.3 27.2 +/- 0.9 93.9 +/- 12.0 P26 FENCE-WAREHOUSE 134 m ESE 27.9 +/- 1.3 27.8 +/- 1.3 32.1 +/- 2.0 30.7 +/- 1.4 118.5 +/- 9.1 P02 FENCE-SHOREFRONT 135 m NW 26.3 +/- 1.0 27.3 +/- 1.5 30.0 +/- 1.6 30.6 +/- 1.0 114.2 +/- 8.8 P09 FENCE-W BOAT RAMP 136 m E 25.2 +/- 1.9 24.0 +/- 1.3 28.5 +/- 0.9 28.2 +/- 1.3 105.9 +/- 9.3 P22 O&M - 2ND N WALL 137 rn SE 29.3 +/- 1.5 30.5 +/- 1.4 36.8 +/- 1.3 38.7 +/-2.1 135.2 +/- 18.7 P16 FENCE-W SWITCHYARD 172 m SW 42.8 +/- 3.0 42.5 +/- 3.4 90.9 +/- 2.7 78.4 +/- 3.7 254.6 +/- 99.3 P11 FENCE-TCF GATE 183 m ESE 35.9 +/- 2.4 37.3 +/- 1.8 50.5 +/- 1.7 37.2 +/- 1.4 160.9 +/- 27.8 P27 FENCE-TCF/BOAT RAMP 185 m ESE 23.0 +/- 2.3 23.2 +/- 1.3 24.8 +/- 1.5 21.3 +/- 0.8 92.2 +/- 6.5 P12 FENCE-ACCESS GATE 202 m SE 22.7 +/- 1.5 21.4 +/- 1.1 25.0 +/- 2.6 26.5 +/- 1.2 95.6 +/- 9.6 P15 FENCE-E SWITCHYARD 220 m S 34.5 +/- 2.6 82.2 +/- 4.3 86.8 +/- 3.3 26.2 +/- 1.6 229.7 +/- 126.1 P10 FENCE-TCF/INTAKE BAY 223 m E 28.0 +/- 2.4 25.9 +/- 1.5 28.8 +/- 1.2 24.5 +/- 1.0 107.2 +/- 8.5 P13 FENCE-MEDICAL BLDG. 224 m SSE 24.7 +/- 1.8 21.5 +/- 1.1 25.4 +/- 1.3 25.6 +/- 1.3 97.2 +/- 8.2 P14 FENCE-BUTLER BLDG 228m S 20.4 +/- 1.4 19.2 +/- 1.1 21.5 +/- 0.9 23.5 +/- 1.1 84.6 +/- 7.6 P28 FENCE-TCF/PRKNG LOT 259 m ESE 51.2 +/- 1.7 81.0 +/- 5.2 87.4 +/- 3.9 112.7 +/- 6.7 332.3 +/- 101.6

/

Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 39

Table 2.4-3 Average TLD Exposures By Distance Zone During 2009 Average Exposure - Standard Deviation: mR/Ienod Exposure Zone 1* Zone 2 Zone 3 Zone 4 Period 0-3 km 1 3-8 km 8-15 km >15 km Jan-Mar 18.8 +/- 5.7 15.6 +/- 1.8 14.9 +/- 1.5 16.4 +/- 2.2 Apr-Jun 18.2 +/- 5.1 14.5 +/- 1.7 13.6 +/- 2.0 14.2 +/- 1.4 Jul-Sep 20.7 +/- 8.1 15.6 +/- 2.3 13.8 +/- 1.9 16.7 +/- 2.6 Oct-Dec 18.7 +/- 7.7 14.8 +/- 2.2 14.1 +/- 1.3 15.3 +/- 2.6 Jan-Dec 1 76.4 +/- 27.1* 60.5 +/- 8.1 56.4 +/- 6.7 62.5 +/- 9.3

• Zone 1 extends from the PNPS restricted/protected area boundary outward to 3 kilometers (2 miles), and includes several TLDs located within the site boundary.

• • When corrected for TLDs located within the site boundary, the Zone 1 annual average is calculated to be 65.3 +/- 10.8 mR/yr.

Page 40

Table 2.5-1 Air Particulate Filter Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: Air Particulates (AP) UNITS: pCi/cubic meter Indicator Stations Station with Highest Mean Control Stations Mean + Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Gross Beta 564 0.01 1.2E-2 +/- 4.7E-3 WS: 1.3E-2 +/- 4.5E-3 1.2E-2 +/- 4.7E-3 0 1.OE 2.5E-2 6.OE 2.4E-2 5.OE 2.3E-2 513/513 52/52 51/51 Be-7 44 1.2E-1 +/- 2.2E-2 PC: 1.3E-1 +/- 3.4E-2 9.8E-2 +/- 1.1E-2 0 7.4E 1.9E-1 1.1E 1.8E-1 8.7E 1.OE-1 40/40 4/4 4/4 K-40 44 7.5E-2 +/- 1.4E-2 CR: 8.8E-2 +/- 1.8E-2 <LLD 0 <LLD - 9.4E-2 <LLD - 8.8E-2 <LLD 10/40 1/4 0/4 Cs-134 44 0.05 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/4 0/4 Cs-137 44 0.06 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/4 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 41

Table 2:6-1 '

Charcoal Cartridge Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: Charcoal Cartridge (CF) UNITS: pCi/cubic meter Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD 1-131 564 0.07 <LLD <LLD <LLD 1-131 _____

05 ___ I <LLD-0/513

<LLD 0 /52

<LLD 0 /51

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 42

Table 2.7-1 Milk Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

No milk sampling was performed during 2009, as no suitable indicator locations were available for sampling within 5 miles of Pilgrim Station.

Page 43

Table 2.8-1 Forage Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - D1ecember 2009)

RACM I " KA C I

rr, I

HK11TQ

, f./

r1il -- #

H.111 D -4I/llI},IW Fola,*

II :VF-L.I Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 2 5.OE+3 +/- 2.6E+1 CF: 5.OE+3 +/- 2.6E+1 5.8E+1 +/- 1.8E+1 0 5.OE+3 - 5.OE+3 5.OE+3 - 5.OE+3 5.8E+1 - 5.8E+1

______1/1 1/1 1/1 K-40 2 5.6E+3 + 3.OE+1 CF: 5.6E+3 + 3.OE+1 2.9E+3 + 5.5E+1 0 5.6E+3 - 5.6E+3 5.6E+3 - 5.6E+3 2.9E+3 - 2.9E+3 1/1 1/1 1/1 1-131 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/2 0/2 Cs-134 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/2 0/2 Cs-137 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/2 0/2 Ra-226 2 3.9E+2 +/- 2.0E+1 CF: 3.9E+2 +/- 2.OE+1 2.1E+2 +/- 3.3E+1 0 3.9E+2 - 3.9E+2 3.9E+2 - 3.9E+2 2.1 E+2 - 2.1 E+2 1/1 1/1 1/1 AcTh-228 2 5.2E+1 +/- 3.6E+0 CF: 5.2E+1 +/- 3.6E+0 2.4E+1 +/- 6.8E+0 0 5.2E+1 - 5.2E+1 5.2E+1 - 5.2E+1 2.4E+1 - 2.4E+1 1/1 1/1 1/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 44

Table 2.9-1 VegetableNegetation RadioactivityAnalyses Radiological Environmental Program Summary Pilgrm Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: Vegetation (TF) UNITS: oCi/ka wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 19 4.1 E+3 t- 2.6E+3 GrnWd: 7.5E+3 +/--9.2E+1 1.4E+3 +/-- 1.8E+3 0 <LLD - 7.5E+3 7.5E+3 - 7.5E+3 <LLD - 4.5E+3 10/12 1/1 5/7 K-40 19 4.5E+3 +/- 2.2E+3 CF: 5.7E+3 +/- 2.4E+3 3.8E+3 +/- 1.5E+3 0 1.2E+3 - 8.8E+3 3.OE+3 - 8.8E+3 2.5E+3 - 6.7E+3

- 12/12 4/4 7/7 1-131 19 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/17 ,0/5 0/4 Cs-134 19 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/17 0/5 0/4 Cs-137 19 80 3.3E+1 +/- 2.4E+1 DMF: 8.9E+1 - 6.OE+0 5.OE+1 +/- 5.5E+1 0 <LLD - 6.OE+1 8.9E+1 - 8.9E+1 <LLD - 8.9E+1 7/12 1/1 2/7 Ra-226 19 4.1E+2 +/- 1.9E+2 PinHil: 7.4E+2 +/- 3.6E+1 3.OE+2 +/- 1.7E+2 0 <LLD - 7.4E+2 7.4E+2 - 7.4E+2 1.3E+2 - 5.6E+2 11/12 1/1 1 7/7 AcTh-228 19 1.1E+2 +/- 1.1E+2 PinHil: 3.7E+2 +/- 8.4E+0 7.2E+1 +/- 6.5E+1 0 <LLD - 3.7E+2 3.7E+2 - 3.7E+2 8.7E+0 - 1.5E+2 11/12 1/1 7/7

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 45

Table 2.10-1 Cranberry Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: Cranberries (CB) UNITS: pCi/ka wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 3 5.5E+2 +/- 3.OE+2 Bart: 7.6E+2 +/- 7.1E+1 <LLD 0 3.5E+2 - 7.6E+2 7.6E+2 - 7.6E+2 <LLD 2/2 1 /1 0/1 K-40 3 1.5E+3 +/- 5.6E+2 HolBog: 2.2E+3 +/- 1.5E+2 2.2E+3 +/- 1.5E+2 0 1.1E+3 - 1.9E+3 2.2E+3 - 2.2E+3 2.2E+3 - 2.2E+3

ý2/2 1 /1 1/ 1 1-131 3 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/2 0/1 0/1 Cs-134 3 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/2 0/1 0/1 Cs-137 3 80 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/2 0/1 0/1 Ra-226 3 2.8E+2 +/- 1.6E+2 Bart: 3.8E+2 +/- 1.2E+2 2.3E+2 +/- 1.2E+2 0 1.8E+2 - 3.8E+2 3.8E+2 - 3.8E+2 2.3E+2 - 2.3E+2 2/2 1/1 1/1 AcTh-228 3 9.6E+1 +/- 7.4E+1 Bart: 1.5E+2 +/- 2.6E+1 <LLD 0 4.5E+1 - 1.5E+2 1.5E+2 - 1.5E+2 <LLD 2/2 1/1 0/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 46

Table 2.12-1 Surface Water Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: Surface Water (WS) UNITS: pCi/kq Radionuclide No.Analyses Required Indicator Stations Station with Highest Mean Control Stations H-3 12 3000 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/4 0/4 Be-7 36 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 K-40 36 3.6E+2 +/- 2.0E+2 PP: 5.4E+2 +/- 2.1E+2 5.4E+2 +/- 2.1E+2 0 <LLD - 8.2E+2 3.3E+2 - 1.OE+3 3.3E+2 - 1.0E+3 23/24 12/12 12/12 Mn-54 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Fe-59 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Co-58 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Co-60 36 15 - <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Zn-65 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Zr-95 36 30 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Nb-95 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 1-131 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Cs-134 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Cs-137 36 18 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Ba-140 36 60 <LLD <LLD <LLD.

0 <LLD <LLD <LLD 0/24 0/12 0/12 La-140 36 15 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 Ra-226 36 9.4E+1 +/- 3.1E+1 PP: 9.5E+1 +/- 5.3E+1 9.5E+1 +/- 5.3E+1 0 <LLD - 1.7E+2 4.5E+1 - 2.4E+2 4.5E+1 - 2.4E+2 22/24 12/12 12/12 AcTh-228 36 1.2E+1 +/- 5.4E+0 BP: 1.3E+1 +/- 6.8E+0 1.3E+1 +/- 4.2E+0 0 <LLD - 2.5E+1 <LLD - 2.5E+1 <LLD - 1.8E+1 12/24 6/12 6/12

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 47

Table 2.13-1 Sediment Radioactivity Analyses Radiological Environmental Program Summary Pilgrm Nuclear Power Station, Plymouth, MA (January - December 2009)

I INIIT*" nl*i/kn 1n, MEDIHKAo Q im-t ISE' UNITS: Ci/k d Indicator Stations Station with Highest Mean

• Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 12 4.2E+2 +/- 1.5E+2 GH: 5.2E+2 +/- 1.3E+2 5.2E+2 +/- 1,3E+2 0 <LLD - 4.2E+2 <LLD - 5.2E+2 <LLD - 5.2E+2 1/8 1/2 1/4 K-40 12 1.3E+4 +/- 2.5E+3 DIS: 1.4E-4 +/- 2.6E+3 1.3E+4 +/-11.2E+3 0 9.3E+3 - 1.7E+4 1.3E+4 - 1.6E+4 1.1 E+4 - 1.4E+4 8/8 2/2 4/4 Cs-134 12 50 <LLD <LLD ý<LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Cs-137 12 50 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/8 0/2 0/4 Ra-226 12 1.3E+3 +/- 5.2E+2 MP: 1.7E+3 +/-13.4E+2 1.6E+3 +/- 6.3E+2 0 <LLD- 1.8E+3 <LLD- 1.7E+3 <LLD- 2.1E+3 5/8 1/2 3/4 AcTh-228 12 3.8E+2 +/- 1.2E+2 DUX: 6.OE+2 +/- 1.1 E+2 5.1E+2 +/- 1.3E+2 0 1.9E+2 - 6.1E+2 5.4E+2 - 6.5E+2 3.9E+2 - 6.5E+2 8/8 2/2 4/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 48

Table 2.14-1 Irish Moss Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MFfII11M" Irish Mex* (Al IJNITS: nCi/kn wet MEDIHM- Irish Moss (ALI UNITS- nri/kri wpt

• Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 8 3.7E+2 +/- 7.5E+1 BR: 5.5E+2 +/- 1.2E+2 5.5E+2 +/- 1.2E+2 0 <LLD - 4.4E+2 <LLD - 5.5E+2 <LLD - 5.5E+2 3/6 1/2 1/2 K-40 8 6.3E+3 +/- 1.5E+3 EL: 7.2E+3 +/- 6.8E+2 6.OE+3 +/- 1.4E+3 0 4.2E+3 - 7.6E+3 6.7E+3 - 7.6E+3 5.1E+3 - 7.OE+3 6/6 2/2 2/2 Mn-54 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Fe-59 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Co-58 8 130 <LLD <LLD <LLD 0 .<LLD <LLD <LLD 0/6 0/2 0/2 Co-60 .8 130 . <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Zn-65 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 1-131 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Cs-134 8 130 <LLD <LLD <LLD 0 <LLD <LLD . <LLD 0/6 0/2

• 0/3 Cs-137 8 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Ra-226 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 AcTh-228 8 1.1E+2+/-3.9E+1 EL: 1.1E+2+/-3.9E+1 <LLD 0 <LLD-1.1E+2 <LLD-1.1E+2 <LLD 1/6 1/2 0/2 Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 49

Table 2.15-1 Shellfish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

KAIMIHAA Ok 11P. k QC HK11TQ r'UL- -

I Il WI-d el~ll s I ,,1 1 i ,* 6 V~~l Jq llbIVq Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD ge-7 10 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 K-40 10 2.8E+3+/-1.1E+3 DIS: 3.3E+3+/-2.1E+3 2.3E+3+/- 4.OE+2 0 <LLD - 4.7E+3 1.8E+3 - 4.7E+3 1.8E+3 - 2.7E+3 5/6 2/2 4/4 Mn-54 10 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Fe-59 10 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Co-58 10 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Co-60 10 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Zn-65 10 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Cs-134 10 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Cs-137 10 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 Ra-226 10 7.4E+2+/-5.1E+2 DIS: 1.3E+3 +/- 3.3E+2 1.0E+3+/- 3.1E+2 0 <LLD - 1.3E+3 <LLD - 1.3E+3 <LLD - 1.OE+3 3/6 1/2 1/4 AcTh-228 10 <LLD <LLD <LLD 0 <LLD <LLD <LLD

<0/6 0/4 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 50

Table 2.16-1 Lobster Radioactivity Analyses Radiological Environmenta! Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

MEDIUM: American Lobster (HA) UNITS: oCi/ka wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 6 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 K-40 6 3.8E+3 +/- 1.7E+3 DIS: 3.8E+3 +/- 1.7E+3 3.3E+3 +/- 2.6E+2 0 2.3E+3 - 5.8E+3 2.3E+3 - 5.8E+3 3.2E+3 - 3.4E+3 4/4 4/4 2/2 Mn-54 6 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Fe-59 6 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Co-58 6 130 <LLD <LLD <LLD

-0 <LLD <LLD <LLD 0/4 0/4 0/1 C0-60, 6 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Zn-65 6 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Cs-134 6 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Cs-137 6 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Ra-226 6 6.7E+2 +/- 3.6E+2 BuzBay: 7.9E+2 +/- 2.7E+2 7.9E+2 +/- 2.7E+2 0 <LLD - 8.9E+2 7.9E+2 - 7.9E+2 <LLD - 7.9E+2 2/4 1/1 1/2 AcTh-228 6 <LLD <LLD <LLD 0 <LLD <LLD <LLD I _0/4 0/4 0/1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 51

Table 2.17-1 Fish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2009)

I INIIT*; ,-,C1i/ln ,~*

hAr-ni"KAF M.h IPWI SVS*SVS o=* ~ I ** NITh . C I/k*x v~ L Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station: Mean +/- Std.Dev. Mean +/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 9 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 K-40 9 4.9E+3 +/- 6.3E+2 BuzBay: 7.OE+3 +/- 7.OE+2 5.7E+3 +/- 9.4E+2 0 4.4E+3 - 5.8E+3 7.OE+3 - 7.OE+3 5.OE+3 - 7.OE+3 5/5 1/1 4/4 Mn-54 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Fe-59 9 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Cc-58 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Co-60 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Zn-65 9 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 C0-134 9 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Cs-137 9 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4 Ra-226 9 8.1E+2 +/-2.1E+2 BuzBay: 1.6E+3+/- 6.4E+2 1.1E+3+/- 7.2E+2 0 <LLD - 9.2E+2 1.6E+3 - 1.6E+3 <LLD - 1.6E+3 3/5 1/1 2/4 AcTh-228 9 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/6 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 52

Figure 2.2-1 Environmental TLD Locations Within the PNPS Protected Area TLD Station Location*

Description Code Distance/Direction TLDs Within Protected Area O&M/RXB. BREEZEWAY P21 50 m SE, EXEC.BUILDING P24 57 m W FENCE-R SCREENHOUSE P04 66 m N O&M-2ND W WALL P20 67 m SE EXEC.BUILDING LAWN P25 76 m WNW FENCE-WATER TANK P05 81 m NNE FENCE-OIL STORAGE P06 85 m NE O&M-2ND SW CORNER P19 86 m S O&M- 1ST SW CORNER P18 90 m S COMPRESSED GAS STOR P08 92 m E FENCE-L SCREENHOUSE P03 100 m NW FENCE-EXEC.BUILDING P17 107 m W O&M - 2ND S WALL P23 121 m ENE FENCE-INTAKE BAY P07 121 m SSE "*

FENCE-WAREHOUSE P26 134 m ESE FENCE-SHOREFRONT P02 135 m ,NW FENCE-W BOAT RAMP P09 136 m E O&M - 2ND N WALL P22 -137 m SE FENCE-W SWITCHYARD P16- 172 m SW FENCE-TCF GATE P11 183 m ESE FENCE-TCF/BOAT RAMP P27 185 m ESE FENCE-ACCESS GATE P12 202 m SE FENCE-E SWITCHYARD P15 220 m Sý FENCE-TCF/INTAKE BAY P10 223 m E FENCE-MEDICAL BLDG. P13 224 m SSE FENCE-BUTLER BLDG P14 228 m S FENCE-TCF/PRKNG LOT P28 259 m ESE Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 53

Figure 2.2-1 (continued)

Environmental TLD Locations Within the PNPS Protected Area iuu meters OP13

,{

I, I

Page 54

Figure 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer TLD Station Location* Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km BOAT LAUNCH WEST BLW 0.11 km E OVERLOOK AREA OA 0.15 km W OVERLOOK AREA OA 0.15 km W PEDESTRIAN BRIDGE PB 0.21 km N HEALTH CLUB TC 0.15 km WSW MEDICAL BUILDING WS 0.23 km SSE BOAT LAUNCH EAST BLE 0.16 km ESE EAST BREAKWATER EB 0.44 km ESE PEDESTRIAN BRIDGE PB 0.21 km N PROPERTY LINE PL 0.54 km NNW SHOREFRONT SECURITY P01 0.22 km NNW W ROCKY HILL ROAD WR 0.83 km WNW MEDICAL BUILDING WS 0.23 km SSE E ROCKY HILL ROAD ER 0.89 km SE PARKING LOT CT 0.31 km SE SHOREFRONT PARKING PA 0.35 km NNW STATION A A 0.37 km WSW STATION F F 0.43 km NW STATION B B 0.44 km S EAST BREAKWATER EB 0.44 km ESE PNPS MET TOWER PMT 0.44 km WNW STATION H H 0.47 km SW STATION I I 0.48 km WNW STATION L L 0.50 km ESE STATION G G 0.53 km W STATION D D 0.54 km NW PROPERTY LINE PL 0.54 km NNW STATION C C 0.57 km ESE HALL'S BOG HB 0.63 km SE GREENWOOD HOUSE GH 0.65 km ESE W ROCKY HILL ROAD WR 0.83 km WNW E ROCKY HILL ROAD ER 0.89 kmn SE Page 55

Figure 2.2-2 (continued)

TLD and Air Sampling Locations: Within 1 Kilometer Page 56

Figure 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers TLD Station Location* Air Sampling Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km MICROWAVE TOWER MT 1.03 km SSW CLEFT ROCK CR 1.27 km SSW CLEFT ROCK CR 1.27 km SSW MANOMET SUBSTATION MS 3.60 km SSE BAYSHORE/GATE RD BD 1.34 km WNW MANOMET ROAD MR 1.38 km S DIRT ROAD DR 1.48 km SW EMERSON ROAD EM 1.53 km SSE EMERSON/PRISCILLA EP 1.55 km SE EDISON ACCESS ROAD AR 1.59 km SSE BAYSHORE BS 1.76 km W STATION E E 1.86 km S JOHN GAULEY JG 1.99 km W STATION J J 2.04 km SSE WHITEHORSE ROAD WH 2.09 km SSE PLYMOUTH YMCA RC 2.09 km WSW STATION K K 2.17 km S TAYLOR/THOMAS TT 2.26 km SE YANKEE VILLAGE YV 2.28 km WSW GOODWIN PROPERTY GN 2.38 km SW RIGHT OF WAY RW 2.83 km S TAYLOR/PEARL TP 2.98 km SE Zone 2 TLDs: 3-8 km VALLEY ROAD VR 3.26 km SSW MANOMET ELEM ME 3.29 km SE WARREN/CLIFFORD WC 3.31 km W RT.3A/BARTLETT RD BB 3.33 km SSE MANOMET POINT MP 3.57 km SE MANOMET SUBSTATION MS 3.60 km SSE BEACHWOOD ROAD BW 3.93 km SE PINES ESTATE PT 4.44 km SSW EARL ROAD EA 4.60 km SSE S PLYMOUTH SUBST SP 4.62 km W ROUTE 3 OVERPASS RP 4.81 km SW RUSSELL MILLS RD RM 4.85 km WSW

. Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 57

Figure 2.2-3 (continued)

TLD and Air Sampling Locations: 1 to 5 Kilometers Page 58

Figure 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers TLD Station Location* Air Sampling Station Location*

-Description Code Distance/Direction Description Code Distance/Direction Zone 2 TLDs: 3-8 km HILLDALE ROAD HD 5.18 km W PLYMOUTH CENTER PC 6.69 km W MANOMET BEACH MBl 5.43 km SSE BEAVER DAM ROAD BR 5.52 km S PLYMOUTH CENTER PC 6.69 km W LONG POND/DREW RD LD 6.97 km WSW HYANNIS ROAD HR 7.33 km SSE MEMORIAL HALL MH 7.58 km WNW SAQUISH NECK SN 7.58 km NNW COLLEGE POND CP 7.59 km SW Zone 3 TLDs: 8-15 km DEEP WATER POND DW 8.59 km W LONG POND ROAD LP 8.88 km SSW NORTH PLYMOUTH NP 9.38 km WNW STANDISH SHORES SS 10.39 km NW ELLISVILLE ROAD EL 11.52 km SSE UP COLLEGE POND RD UC 11.78 km SW SACRED HEART SH 12.92 km W KING CAESAR ROAD KC 13.11 km NNW BOURNE ROAD BE 13.37 km S SHERMAN AIRPORT SA 13.43 km WSW Zone 4 TLDs: >15 km CEDARVILLE SUBST CS 15.93 km S KINGSTON SUBST KS 16.15 km WNW LANDING ROAD LR 16.46 km NNW CHURCH/WEST CW 16.56 km NW MAIN/MEADOW MM 17.02 km WSW DIV MARINE FISH DMF 20.97 km SSE Distance and direction are measured from centerline of Reactor Building to the monitoring location.

Page 59

Figure 2.2-4 (continued)

TLD and Air Sampling Locations: 5 to 25 Kilometers Page 60

Figure 2.2-5 Terrestrial and Aquatic Sampling Locations Description Code Distance/Direction* Description Code Distance/Direction*

FORAGE SURFACE WATER Plymouth County Farm CF 5.6 km W Discharge Canal DIS 0.2 km N.

Bridgewater Control BF 31 km W Bartlett Pond BP 2.7 km SE Hanson Farm Control HN 34 km W Powder Point Control PP 13 km NNW SEDIMENT Discharge Canal Outfall DIS 0.8 km NE Plymouth Beach PLB 4.0 km W Manomet Point MP 3.3 km ESE VEGETABLESNEGETATION Plymouth Harbor PLY-H 4.1 km W Site Boundary C BC 0.5 km SW Duxbury Bay Control DUX-BAY 14 km NNW Site Boundary B BB 0.5 km ESE Green Harbor Control GH 16 km NNW Rocky Hill Road RH 0.9 km SE Site Boundary D Bd 1.1 km S IRISH MOSS Site Boundary A BA 1.5 km SSW Discharge Canal Outfall DIS 0.7 km NNE Clay Hill Road CH 1.6 km W Manomet Point MP 4.0 km ESE Brook Road BK 2.9 km SSE Ellisville EL 12 km SSE Beaver Dam Road BD 3.4 km S Brant Rock Control BK 18 km NNW Plymouth County Farm CF 5.6 km W Hanson Farm Control HN 34 km W SHELLFISH.

Norton Control NC 50 km W Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor PLY-H 4.1 km W CRANBERRIES Manomet Point MP 4.0 km ESE Bartlett Road Bog BT 4.3 km SSE Duxbury Bay Control DUX-BAY 13 km NNW Beaverdam Road Bog MR 3.4 km S Powder Point Control PP 13 km NNW Hollow Farm Bog Control HF .16 km WNW Green Harbor Control GH 16 km NNW LOBSTER Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km W Plymouth Harbor PLY-H 6.4 km WNW Duxbury Bay Control DUX-BAY 11 km NNW FISHES Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km W Jones River Control JR 13 km WNW Cape Cod Bay Control CC-BAY 24 km ESE N River-Hanover Control NR 24 km NNW Cataumet Control CA 32 km SSW Provincetown Control PT 32 km NE Buzzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 61

Figure 2.2-5 (continued)

Terrestrial and Aquatic Sampling Locations 24 KILOMETERS NORTH-NORTHWEST SYMBOL KEY, SHELLFISH (M BLUE MUSSEL)

(S SOFT-SHELL)

(H HARD-SHELL)

O IRISH MOSS LOBSTER FISHES SURFACE WATER

- SEDIMENT

<) CRANBERRY m VEGETATION 0 MfILES 2 SCALE 31 KILOMETERS WEST 34 KILOMETERS WEST 32 KILOMETERS NORTHEAST 50 KILOMETERS WEST EAST WHITEHORSE BEACH I B TAY ta~ 24E1 METERS EAST-SOUTHEAST r4 KILOMETERS

'0- SOUTHWEST 40 KILOMETERS 64 KIL SOUTH-SOUTHWEST SOUTI

& 4SOUTH-SOUTHEAST KILOMETERS Page 62

Figure 2.2-6 Environmental Sampling And Measurement Control Locations Description Code Distance/Direction* Description Code Distance/Direction*

TLD SURFACE WATER Cedarville Substation CS 16 km S Powder Point Control PP 13 km NNW Kingston Substation KS 16 km WNW Landing Road LR 16 km NNW SEDIMENT Church & West Street CW 17 km NW Duxbury Bay Control DUX-BAY 14 km NNW Main & Meadow Street MM 17 km WSW Green Harbor Control GH 16 km NNW Div. Marine Fisheries DMF 21 km SSE East Weymouth Substation EW *40 km NW IRISH MOSS Brant Rock Control BK 18 km NNW AIR SAMPLER East Weymouth Substation EW 40 km NW SHELLFISH Duxbury Bay Control DUX-BAY 13 km NNW FORAGE Powder Point Control PP 13 km NNW Bridgewater Control BF 31 km W Green Harbor Control GH 16 km NNW Hanson Farm Control HN 34 km W LOBSTER VEGETABLESNEGETATION Duxbury Bay Control DUX-BAY 11 km NNW Hanson Farm Control HN 34 km W Norton Control NC 50 km W FISHES Jones River Control JR 13 km WNW Cape Cod Bay Control CC-BAY 24 km ESE CRANBERRIES N River-Hanover Control NR 24 km NNW Hollow Farm Bog Control HF 16 km WNW Cataumet Control CA 32 km SSW Provincetown Control PT 32 km NE Buzzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 63

Figure 2.2-6 (continued)

Environmental Sampling And Measurement Control Locations CAPECODBAY

<ZBAY Page 64

Airborne Gross-Beta Radioactivity Levels Near-Station Monitors 5.0 E-02 4.0 E-02

$ 3.0 E-02 E

C.)

0 0 2.0 E-02 1.0 E-02 0.OE+00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2009

.AP-00 Warehouse. -a--AP-07 Pedestrian Bridge

-- AP-08 Overlook Area ---. AP-09 East Breakwater

---

AP-21 East Weymouth Control Figure 2.5-1 Airborne Gross-Beta Radioactivity Levels: Near Station Monitors Page 65

Airborne Gross-Beta Radioactivity Levels Property Line Monitors 5.0 E-02 4.0 E-02 (D 3.OE-02 E

._9 C..

. 2.0E-02

.0 1.0 E-02 O.OE+00 ' , ,

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2009 AP-01 E. Rocky Hill Road -- m--AP-03 W. Rocky Hill Road AP-06 Property Line --- AP-21 East Weymouth Control Figure 2.5-2 Airborne Gross-Beta Radioactivity Levels: Property Line Monitors Page 66

Airborne Gross-Beta Radioactivity Levels Offsite-Monitors 5.0 E-02 4.0 E-02

• $ 3.0 E-02 E

.)

-o 0)

.8 2.0 E-02 1.

1.0 E-02 0.OE+00 + , 1 I I I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2009 AP-10 Cleft Rock --- AP-1 5 Plymouth Center

- AP-17 Manomet Substation -- AP-21 East Weymouth Control r

Figure 2.5-3 Airborne Gross-Beta Radioactivity Levels: Offsite Monitors Page 67

3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS, The radiological impact to humans from the Pilgrim Station's radioactive liquid and gaseous releases has been estimated using two methods:

• calculations based on measurements of plant effluents; and

• calculations based on measurements of environmental samples.

The first method utilizes data from the radioactive effluents (measured at the point of release) together with conservative.models that calculate the dispersion and transport of radioactivity through the environment to humans (Reference 7). The second method is based on actual measurements of radioactivity in the environmental samples and on dose conversion factors recommended by the Nuclear Regulatory Commission. The measured types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during 2009 were reported to the Nuclear Regulatory Commission, copies of which are provided in Appendix B. The measured levels of radioactivity in the environmental samples that required dose calculations are listed in Appendix A.

The maximum individual dose from liquid effluents was calculated using the following radiation exposure pathways:-

• shoreline external radiation during fishing and recreation at the Pilgrim Station Shorefront;

" external radiation from the ocean during boating and swimming; and

" ingestion of fish and shellfish.

For gaseous effluents, the maximum individual dose was calculated using the following radiation exposure pathways:

• external radiation from cloud shine and submersion in gaseous effluents;

" inhalation of airborne radioactivity;

" extemal radiation from soil deposition;

• consumption of vegetables; and

" consumption of milk and meat.

The results from the dose calculations based on PNPS operations are presented in Table 3.0-1.

The dose assessment data presented were taken from the "Radioactive Effluent Release Report" for the period of January 1 through December 31, 2009 (Reference 17).

Page 68

Table 3.0-1 Radiation Doses from 2009 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway - mrem/yr Gaseous Liquid Ambient Receptor Effluents* Effluents Radiation** Total Total Body 0.048 0.000031 1.4 1.4 Thyroid 0.083 0.000013 1.4 1.5 Max. Organ 0.083 0.00014 1.4 1.5

• Gaseous effluent exposure pathway includes combined dose from particulates, iodines and tritium in addition to noble gases, calculated at the nearest residence.

• • Ambient radiation dose for the hypothetical maximum-exposed individual at a location on PNPS property yielding highest ambient radiation exposure value as measured with TLDs.

Two federal agencies establish dose limits to protect the public from radiation and radioactivity. The Nuclear Regulatory Commission (NRC) specifies a whole body dose limit of 100 mrem/yr to be received by the maximum exposed member of the general public. This limit is set forth in Section 1301, Part 20, Title 10, of the U.S. Code of Federal Regulations (10CFR20). By comparison, the Environmental Protection Agency (EPA) limits the annual whole body dose to 25 mrem/yr, which is specified in Section 10, Part 190, Title 40, of the Code of Federal Regulations (40CFR190).

Another useful "gauge" of radiation exposure is provided by the amount of dose a typical individual receives each year from natural and man-made (e.g., diagnostic X-rays) sources of radiation. The typical American receives 300 to 400 mrem/yr from such sources.

As can be seen from the doses resulting from Pilgrim Station Operations during 2009, all values are well within the federal limits specified by the NRC and EPA. In addition, the calculated doses from PNPS operation represent only a fraction of a percent of doses from natural and man-made radiation.

In conclusion, the radiological impact of Pilgrim Station operations, whether based on actual environmental measurements or calculations made from effluent releases, would yield doses well within any federal dose limits set by the NRC or EPA. Such doses represent only a small percentage of the typical annual dose received from natural and man-made sources of radiation.

Page 69

4.0 REFERENCES

1) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix A Criteria 64.

2) Donald T. Oakley, "Natural Radiation Exposure in the United States." U. S. Environmental Protection Agency, ORP/SID 72-1, June 1972.

3) National Council on Radiation Protection and Measurements, Report No. 93, "Ionizing Radiation, Exposures of the Population of the United States," September 1987.

4) United States Nuclear Regulatory Commission, Regulatory Guide 8.29, "Instructions Concerning Risks from Occupational Radiation Exposure," Revision 0, July 1981.

5) Boston Edison Company, "Pilgrim Station" Public Information Brochure 100M, WNTHP, September 1989.

,6) United States Nuclear Regulatory Commission, Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977.

7) Pilgrim Nuclear Power Station Offsite Dose Calculation Manual, Revision 9, June 2003.

8) United States of America, Code of Federal Regulations, Title 10, Part 20.1301.

9) United States of America, Code of Federal Regulations, Title 10, Part 50, Appendix I.

10) United States of America, Code of Federal Regulations, Title 40, Part 190.

11) United States Nuclear Regulatory Commission, Regulatory Guide 4.1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants," Revision 1, April 1975.

12) ICN/Tracerlab, "Pilgrim Nuclear Power Station Pre-operational Environmental Radiation Survey Program, Quarterly Reports," August 1968 to June 1972.

13) International Commission of Radiological Protection, Publication No. 43, "Principles of Monitoring for the Radiation Protection of the Population," May 1984.

14) United States Nuclear Regulatory Commission, NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," April 1991.

15) United States Nuclear Regulatory Commission, Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program," Revision 1, November 1979.

16) Settlement Agreement Between Massachusetts Wildlife Federation and Boston Edison Company Relating to Offsite Radiological Monitoring - June 9, 1977.

17) Pilgrim Nuclear Power Station, "Radioactive Effluent Release Report", May 2009.

Page 70

APPENDIX A SPECIAL STUDIES None of the samples collected as part of the .radiological environmental monitoring program during 2009 indicated any detectable radioactivity attributable to Pilgrim Station operations. Therefore, no special dose analyses were performed.

Page 71

APPENDIX B Effluent Release Information TABLE TITLE PAGE B.1 Supplemental Information 73 B.2-A Gaseous Effluents Summation of All Releases 74 B.2-B Gaseous Effluents - Elevated Releases 75 B.2-C Gaseous Effluents - Ground Level Releases 77 B.3-A Liquid Effluents Summation of All Releases 79 B.3-B Liquid Effluents 80 Page 72

Table B.1 Pilgrim Nuclear Power Station Radioactive Effluent Release Report Supplemental Information January-December 2009 FACILITY: PILGRIM NUCLEAR POWER STATION LICENSE: DPR-35

1. REGULATORY LIMITS

a. Fission and activation gases: 500 mrem/yr total body and 3000 mrem/yr for skin at site boundary b,c. lodines, particulates with half-life: 1500 mrem/yr to any organ at site boundary

>8 days, tritium

d. Liquid effluents: 0.06 mrem/month for whole body and 0.2 mrem/month for any organ I (without radwaste treatment)

2. EFFLUENT CONCENTRATION LIMITS

a. Fission and activation gases: 10CFR20 Appendix B Table II

b. lodines: 10CFR20 Appendix B Table II

c. Particulates with half-life > 8 days: 10CFR20 Appendix B Table II

d. Liquid effluents: 2E-04 pCi/mL for entrained noble gases; 10CFR20 Appendix B Table II values for all other.

• __radionuclides

3. AVERAGE ENERGY Not Applicable

4. MEASUREMENTS AND APPROXIMATIONS OF TOTAL RADIOACTIVITY

a. Fission and activation gases: High purity germanium gamma spectroscopy for all

b. lodines: gamma emitters; radiochemistry analysis for H-3,

c. Particulates: Fe-55 (liquid effluents), Sr-89, and Sr-90

d. Liquid effluents:

5. BATCH RELEASES Jan-Mar" Apr-Jun Jul-Sep Oct-Dec Jan-Dec 2009 .2009 2009 2009 2009

a. Liquid Effluents

1. Total number of releases: 1 3 0 0 4

2. Total time period (minutes): 1.05E+02 2.70E+02 0.OOE+00 0.OOE+00 3.75E+02

3. Maximum time period 1.05E+02 9.OOE+01 0.OOE+00 0.OOE+00 1.05E+02 (minutes):

4. Average time period (minutes): 1.05E+02 9.OOE+01 0.OOE+00 0.OOE+00 9.38E+01

5. Minimum time period (minutes): 1.05E+02 9.OOE+01 0.OOE+00 0.OOE+00 9.OOE+01

6. Average stream flow during periods of release of efflueintperintosa lowigetr1.17E+06 7.82E+05 N/A N/A 8.92E+05 effluents into a flowing stream (Liters/min):

b. Gaseous Effluents None None None None None

6. ABNORMAL RELEASES

a. Liquid Effluents None None None None None

b. Gaseous Effluents None None None None None Page 73

Table B.2-A Pilgrim Nuclear Power Station Radioactive Effluent Release Report Gaseous Effluents - Summation of All Releases January-December 2009 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2009 2009 2009 2009 2009 Error A. FISSION AND ACTIVATION GASES Total Release: Ci 9.75E+01 1.20E+01 2.82E+00 2.73E+00 1.15E+02 Average Release Rate: jiCi/sec 1.24E+01 1.52E+00 3.57E-01 3.46E-01 3.65E+00 +/-22%

Percent of Effluent Control Limit* * * * *

• B. IODINE-131 Total Iodine-131 Release: Ci 1.92E-03 1.41E-03 5.09E-04 3.99E-04 4.24E-03 Average Release Rate: [LCi/sec 2.43E-04 1.79E-04 6.46E-05 5.06E-05 1.34E-04 +/-20%

Percent of Effluent Control Limit*. ....

C. PARTICULATES WITH HALF-LIVES > 8 DAYS Total Release: Ci 1.06E-02 2.71E-03 1.18E-03 9.32E-04 1.54E-02 Average Release Rate: jiCi/sec 1.34E-03 3.43E-04 1.49E-04 I1.1 8E-04 4.88E-04 Percent of Effluent Control Limit* +/-21%

Gross Alpha Radioactivity: Ci NDA NDA NDA NDA NDA D. TRITIUM Total Release: Ci 2.66E+01 1.07E+01 1.34E+01 1.70E+01 6.76E+01 Average Release Rate: ýiCi/sec 3.37E+00 1.35E+00 1.70E+00 2.15E+00 2.14E+00 +/-20%

Percent of Effluent Control Limit*. ....

Notes for Table 2.2-A:

• Percent of Effluent Control Limit values based on dose assessments are provided in Section 7 of this report.

1. NDA stands for No Detectable Activity.

2. LLD for airborne gross alpha activity listed as NDA is 1E-1 1 piCi/cc.

Page 74

,A

Table B.2-B Pilgrim Nuclear Power Station -

Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2009 CONTINUOUS MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Sep 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION GASES: Ci Ar-41 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Kr-85 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 Kr-85m 2.58E-02 2.37E-01 2.78E-01 0.OOE+00 5.40E-01 Kr-87 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Kr-88 0.OOE+00 4.25E-02 0.OOE+00 0.OOE+00 4.25E-02 Xe-131m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-133 0.OOE+00 6.08E-01 3.37E-01 0.00E+00 9.45E-01 Xe-1 33m 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 Xe-135 5.24E-01 2.35E+00 0.OOE+00 0.OOE+00 2.87E+00 Xe-135m 8.35E-01 1.OOE+00 0.OOE+00 0.OOE+00 1.83E+00 Xe-137 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-138 6.94E+00 0.OOE+00 0.OOE+00 0.OOE+00 6.94E+00 Total for Period 8.33E+00 4.24E+00 6.14E-01 O.OOE+00 1.32E+01

2. IODINES: Ci 1-131 1.17E-04 7.68E-05 2.41E-05 2.03E-05 2.38E-04 1-133 1.69E-04 1.19E-04 3.61E-05 2.68E-05 3.51E-04 Total for Period 2.86E-04 1.96E-04 6.02E-05 4.71 E-05 5.89E-04

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 0.OOE+00 1.18E-06 0.OOE+00 0.OOE+00 1.18E-06 Mn-54 0.OOE+00 1.32E-06 0.OOE+00 0.OOE+00 1.32E-06 Fe-59 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Co-58 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Co-60 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Zn-65 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Sr-89 9.26E-06 5.40E-06 2.88E-06 2.94E-06 2.05E-05 Sr-90 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Ru-103 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 Cs-134 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Cs-1 37 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Ba/La-140 7.03E-05 5.19E-06 0.OOE+00 0.OOE+00 7.55E-05 Total for Period - 7.95E-05 1.31 E-05 2.88E-06 2.94E-06 9.84E-05

4. TRITIUM: Ci H-3 9.56E-02 3.25E-02 4.43E-02. 4.18E-02 2.14E-01 Notes for Table 2.2-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 pCi/cc lodines: 1E-12 ipCi/cc Particulates: 1E-11 iCi/cc Page 75

Table B.2-B (continued)

Pilgrim Nuclear Power Station Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2009 BATCH MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Sep 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION GASES: Ci Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A N/A N/A' N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A N/A Kr-88 N/A N/A N/A N/A N/A Xe-131 m N/A N/A N/A N/A N/A Xe-1 33 N/A N/A N/A N/A N/A Xe-1 33m N/A N/A N/A N/A N/A Xe-i 35 N/A N/A N/A N/A N/A Xe-1 35m N/A N/A N/A N/A N/A Xe-1 37 N/A N/A N/A N/A N/A Xe-1 38 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 N/A N/A N/A N/A N/A Mn-54 N/A N/A N/A N/A N/A Fe-59 N/A N/A N/A N/A N/A Co-58 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Ru-103 N/A N/A N/A N/A N/A Cs-134 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A N/A Notes for Table 2.2-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 piCi/cc lodines: 1E-12 jiCi/cc Particulates: 1E-11 pCi/cc Page 76

Table B.2-C Pilgrim Nuclear Power Station Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2009 CONTINUOUS MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Sep 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION GASES: Ci Ar-41 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 Kr-85 0.00E+00 0.00E+00 0.00E+00 0.00E+00 - 0.OOE+00 Kr-85m 0.00E+00 O.OOE+00 0.00E+00 0.00E+00 0.00E+00' Kr-87 0.00E+00 0.00E+00 0.OOE+00 0.00E+00 0.00E+00 Kr-88 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-131m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-133 0.OOE+00 3.33E-01 0.OOE+00 0.00E+00 3.33E-01 Xe-133m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-135 2.91E+00 0.OOE+00 2.53E-01 9.69E-01 4.13E+00 Xe-135m 8.90E+00 1.94E+00 0.OOE+00 0.OOE+00 1.08E+01 Xe-1 37 3.77E+01 0.OOE+00 0.OOE+00 0.OOE+00 3.77E+01 Xe-138 3.96E+01 5.47E+00 1.95E+00 1.76E+00 4.88E+01 Total for period 8.91 E+01 7.75E+00 2.20E+00 2.73E+00 1.02E+02

2. IODINES: Ci 1-131 1.80E-03 1.33E-03 4.85E-04 3.79E-04 4.OOE-03 1-133 5.41 E-03 1.43E-03 8.01 E-04 8.32E-04 8.47E-03 Total for period 7.21E-03 2.76E-03 1.29E-03 1.21E-03 1.25E-02

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 0.OOE+00 6.82E-05 0.OOE+00 0.OOE+00 6.82E-05 Mn-54 3.27E-06 1.24E-04 0.OOE+00 0.OOE+00 1.27E-04 Fe-59 0.OOE+00 7.73E-06 0.OOE+00 0.OOE+00 7.73E-06 Co-58 0.OOE+00 6.01E-06 0.OOE+00 0.OOE+00 6.01E-06 Co-60 0.OOE+00 7.36E-05 0.OOE+00 0.OOE+00 7.36E-05 Zn-65 0.OOE+00 8.59E-06 0.OOE+00 0.OOE+00 8.59E-06 Sr-89 1.22E-03 2.58E-04 1.74E-04 1.06E-04 1.76E-03 Sr-90 1.79E-06 0.OOE+00 0.OOE+00 0.OOE+00 1.79E-06 Ru-1 03 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Cs-134 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Cs-137 0.OOE+00 9.45E-06 8.75E-06 0.OOE+00 1.82E-05 Ba/La-140 9.27E-03 2.14E-03 9.91E-04 8.23E-04 1;32E-02 Total for period 1.05E-02 2.69E-03 1.17E-03 9.29E-04 1.53E-02

4. TRITIUM: Ci H-3 2.65E+01 1.06E+01 1.33E+01 1.69E+01 6.74E+01 Notes for Table 2.2-C:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 ýiCi/cc lodines: 1E-12 [tCi/cc Particulates: 1 E-11 ýiCi/cc Page 77

Table B.2-C (continued)

Pilgrim Nuclear Power Station Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2009 BATCH MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Sep 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION GASES: Ci Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A N/A N/A N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A N/A Kr-88 N/A N/A N/A N/A N/A Xe-131m N/A N/A N/A N/A N/A Xe-133 N/A N/A N/A N/A N/A Xe-133m N/A N/A N/A N/A N/A Xe-1 35 N/A N/A N/A N/A N/A Xe-i 35m N/A N/A N/A N/A N/A Xe-1 37 N/A N/A N/A N/A N/A Xe- 138 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Total for period N/A N/A N/A t N/A N/A

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 N/A N/A N/A N/A N/A Mn-54 N/A N/A N/A N/A N/A Fe-59 N/A N/A N/A N/A N/A Co-58 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Ru-103 N/A N/A N/A N/A N/A Cs-134 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A N/A' N/A. N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A N/A Notes for Table2.2-C:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NDA are as follows:

Fission Gases: 1E-04 piCi/cc lodines: 1E-12 pCi/cc Particulates. 1E-11 pCi/cc Page 78

Table B.3-A Pilgrim Nuclear Power Station Radioactive Effluent Release Report Liquid Effluents - Summation of All Releases January-December 2009 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec. Total 2009 2009 2009 2009 2009 Error A. FISSION AND ACTIVATION PRODUCTS Total Release (not including 3.93E-05 1.32E-03 N/A N/A 1.35E-03 tritium, gases, alpha): Ci Average Diluted Concentration 2.59E-13 1.21 E-11 N/A N/A 2.37E-12 +/-12%

During Period: liCi/mL Percent of Effluent ConcentraionEflimt 2.09E-05% 9.32E-05% N/A N/A 2.33E-05%

Concentration Limit*

B. TRITIUM Total Release: Ci 2.08E-02 1.96E+00 N/A N/A 1.98E+00 Average Diluted Concentration 1.37E-10 1.79E-08 N/A N/A 3.46E-09

.During Period: gCi/mL +/-9.4%

Percent of Effluent N/A N/A 3.46E-04%

Concentration Limit* 1.37E-05% 1.79E-03%

C. DISSOLVED AND ENTRAINED GASES Total Release: Ci N/A N/A N/A N/A N/A Average Diluted Concentration N/A N/A N/A N/A N/A During Period: pCi/mL N+/-16%

Percent of Effluent Concentration Limit* N/A N/A N/A N/A N/A D. GROSS ALPHA RADIOACTIVITY Total Release: Ci N/A N/A N/A N/A N/A +/-34%

E. VOLUME OF WASTE RELEASED PRIOR TO DILUTION Waste Volume: Liters 3.92E+04 2.04E+05 N/A N/A 2.44E+05 +/-5.7%

F. VOLUME OF DILUTION WATER USED DURING PERIOD

-Dilution Volume: Liters 1.52E+11 1.09E+11 1.55E+11 1.55E+11 5.71E+11 +/-10%

Notes for Table 2.3-A:

• Additional percent of Effluent Control Limit values based on dose assessments are provided in Section 7 of this report.

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLD for dissolved and entrained gases listed as NDA is 1E-05 1 iCi/mL.

4. LLD for liquid gross alpha activity listed as NDA is 1E-07 ltCi/mL.

Page 79

Table B.3-B Pilgrim Nuclear Power Station Radioactive Effluent Release Report Liquid Effluents January-December 2009 CONTINUOUS MODE RELEASES Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Sep 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION PRODUCTS: Ci Cr-51 N/A N/A N/A N/A N/A Mn-54 N/A N/A N/A N/A N/A Fe-55 N/A N/A N/A N/A N/A Fe-59 N/A N/A N/A N/A N/A Co-58 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Zn-69m N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A N/A Sr-90 N/A N/A N/A N/A N/A Zr/Nb-95 N/A N/A N/A N/A N/A Mo/Tc-99 N/A N/A N/A N/A N/A Ag-110m N/A N/A N/A N/A N/A Sb-124 N/A N/A N/A N/A N/A 1-131 - N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Cs-i 34 N/A N/A N/A N/A N/A Cs-1 37 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Ce-141 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. DISSOLVED AND ENTRAINED GASES: Ci Xe-i 33 N/A N/A N/A N/A N/A Xe-i 35 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A Notes for Table 2.3-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for liquid radionuclides listed as NDA are as follows:

Strontium: 5E-08 pCi/mL lodines: 1E-06 jiCi/mL Noble Gases: 1E-05 gCi/mL All Others: 5E-07 piCi/mL Page 80

'N Table B.3-B (continued)

Pilgrim Nuclear Power Station Radioactive Effluent Release Report Liquid Effluents January-December 2009 BATCH MODE RELEASES Nuclide Released Jan-Mar 2009 Apr-Jun 2009 Jul-Se 2009 Oct-Dec 2009 Jan-Dec 2009

1. FISSION AND ACTIVATION PRODUCTS: Ci Cr-51 NDA 2.38E-05 N/A N/A 2.38E-05 Mn-54 4.21E-06 1.05E-03 N/A N/A 1.06E-03 Fe-55 NDA NDA N/A N/A NDA Fe-59 NDA 3.20E-05 N/A N/A 3.20E-05 Co-58 NDA 1.96E-05 N/A N/A 1.96E-05 Co-60 7.99E-06 1.87E-04 N/A N/A 1.95E-04 Zn-65 NDA NDA N/A N/A NDA Zn-69m NDA NDA N/A N/A NDA Sr-89 NDA NDA N/A N/A NDA Sr-90 1.55E-06 NDA N/A N/A 1.55E-06 Zr/Nb-95 NDA NDA N/A N/A NDA Mo/Tc-99 NDA NDA N/A N/A NDA

_Ag-110m NDA NDA N/A N/A NDA Sb-124 NDA NDA N/A N/A NDA 1-131 NDA NDA N/A N/A NDA 1-133 NDA NDA N/A N/A NDA Cs-1 34 2.26E-06 NDA N/A N/A 2.26E-06 Cs-1 37 2.33E-05 NDA N/A N/A 2.33E-05 Ba/La-140 NDA NDA N/A N/A NDA Ce-141 NDA NDA N/A N/A NDA Total for period 3.93E-05 1.32E-03 N/A N/A 1.35E-03

2. DISSOLVED AND ENTRAINED GASES: Ci Xe-1 33 N/A N/A N/A N/A N/A Xe-I 35 N/A N/A N/A N/A N/A Total for period N/A NDA NDA NDA NDA Notes for Table 2.3-B:

1. N/A stands for not applicable.

2. NDA stands for No Detectable Activity.

3. LLDs for liquid radionuclides listed as NDA are as follows:

Strontium: 5E-08 [iCi/mL lodines: 1E-06 pCi/mL Noble Gases: 1E-05 jiCi/mL All Others: 5E-07 p.Ci/mL Page 81

APPENDIX C LAND USE CENSUS RESULTS The annual land use census for gardens and milk and meat animals in the vicinity of Pilgrim Station was performed between September 04 and September 24, 2009. The census was conducted by driving along each improved road/street in the Plymouth area within 5 kilometers (3 miles) of Pilgrim Station to survey for visible gardens with an area of greater than 500 square feet. In compass sectors where no gardens were identified within 5 km (SSW, WNW, NW, and NNW sectors), the survey was extended to 8 km (5 mi). A total of 23 gardens were identified in the vicinity of Pilgrim Station. In addition, the Town of Plymouth Animal Inspector was contacted for information regarding milk and meat animals.

Atmospheric deposition (D/Q) values at the locations of the identified gardens were compared to those for the existing sampling program locations. These comparisons enabled PNPS personnel to ascertain the best locations for monitoring for releases of airborne radionuclides. Gardens yielding higher D/Q values than those currently in the sampling program were also sampled as part of the radiological environmental monitoring program.

Based on assessment of the gardens identified during the 2009 land use census, samples of garden-grown vegetables or naturally-growing vegetation (e.g. grass, leaves from bushes'or trees, etc.) were collected at or near the closest gardens in each of the following landward compass sectors. These locations, and their distance and direction relative to the PNPS Reactor Building, are as follows:

Rocky Hill Road 0.9 km SE Beaver Dam Road 3.4 km S Clay Hill Road 1.6 km W In addition to these special sampling locations identified and sampled in conjunction with the 2009 land use census, samples were also collected at or near the Plymouth County Farm (5.6 km W), and from control locations in Bridgewater (31 km W) and Norton (49 km W).

Samples of naturally-growing vegetation were also collected in the vicinity of the site boundary locations yielding the highest deposition (D/Q) factors for each of the two release points. These locations, and their distance and direction relative to the PNPS Reactor Building, are as follows:

Highest Main Stack D/Q: 1.5 km SSW Highest Reactor Building Vent D/Q: 0.5 km ESE 2n highest D/Q, both release points: 1.1 km S No new milk or meat animals were identified during the land use census. In addition, the Town of Plymouth Animal Inspector stated that their office is not aware of any animals at locations other than the Plimoth Plantation. Samples of milk and forage had historically been collected from the Plymouth County Farm, and forage samples from that location were part of the 2009 sampling program in lieu of milk sampling, as allowed in NRC guidance (Reference 14). Although milk sampling is not performed at Plimoth Plantation, effluent dose calculations are performed for this location assuming the presence of a milk ingestion pathway, as part of the annual Effluent and Waste Disposal Report (Reference 17).

Page 82

APPENDIX D ENVIRONMENTAL MONITORING PROGRAM DISCREPANCIES There were a number of instances during 2009 in which inadvertent issues were encountered in the collection of environmental samples. All of these issues were minor in nature and did not have an Iadverse effect on the results or integrity of the monitoring program. Details of these various problems are given below.

During 2009, one offsite thermoluminescent dosimeter (TLD) and one onsite TLD were not recovered from their assigned locations during the quarterly retrieval process. Degradation of the plastic cages housing the TLDs resulted in the loss of the following TLDs: Station H (Qtr 2). In this case, the plastic cage holding the TLD were replaced and a new TLD posted. In situations involving suspected vandalism, the TLD,cages were relocated to be less conspicuous, or raised up in height to deter further vandalism. The TLD inside the Executive Building (P24) was lost during painting and building renovation activities. Despite these losses, the 438 TLDs that were collected (99.5%) allowed for adequate assessment of the ambient radiation levels in the vicinity of Pilgrim Station.

Within the air sampling program, there were a few instances in which continuous sampling was interrupted at the eleven airborne sampling locations during 2009. Most of these interruptions were due to short-term power losses and were sporadic and of limited duration (less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> out of the weekly sampling period). Such events did not have any significant impact on the scope and purpose of the sampling program, and lower limits of detection (LLDs) were met for both particulates and iodine-131 on 564 of the 564 filters/cartridges collected.

The configuration of air samplers that had been in use at Pilgrim Station since the early 1980s, was replaced between June and August of 2009. Both the pumps and dry gas meters were replaced, and operating experience since changing over to the new configuration has been favorable. Although the occurrence of pump failures and gas meter problems have been largely eliminated, the new configuration is still subject to trips of the ground fault interrupt circuit (GFCI). The following table contains a listing of larger problems encountered with air sampling stations during 2009, many of which resulted in loss of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a sampling period.

Location Sampling Sampling Problem Description Period Hours Lost WS 12/29/08 to 46 of 192 GFCI outlet tripped during storm; reset.

01/06/09 PB 02/02 to 02/09 No Hours Gas meter seized; replaced 02/09.

Lost EW 03/31 to 04/07 No Hours Sampling station inaccessible due to construction at Lost substation; filters left on for 2-week period, with no interruption of sampling; all required LLDs were achieved.

CR 04/07 to 04/14 No Hours Gas meter seized; replaced 04/14.

Lost OA 04/20 to 04/28 23 of 192 GFCI outlet tripped during storm; reset.

EB 08/25 to 09/29 No Hours' Sampling station inaccessible due to safety concerns; Lost filters left on for 4-week period, with no interruption of

'sampling; all required LLDs were achieved.

EW 10/27 to 11/04 No Hours Gas meter seized; replaced 11/04.

Lost Page 83

Location Sampling Sampling Problem Description Period Hours Lost EW 11/04 to 11/10 76 of 145 Power lost during substation construction activities; power restored on 11/10.

EB 11/04 to 11/10 23 of 141 GFCI outlet tripped during storm; reset.

PL 12/15 to 12/22 No Hours Sampling station inaccessible due to snow drifts; Lost filters left on for 2-week period, with no interruption of sampling. ; all required LLDs were achieved.

Despite the lower-than-normal sampling volumes in the various instances involving power interruptions and equipment failures, required LLDs were met on 564 of the 564 particulate filters, and 564 of the 564 of the iodine cartridges collected during 2009. When viewed collectively during the entire year of 2009, the following sampling recoveries were achieved in the airborne sampling program:

Location Recovery Location Recovery Location Recovery WS 99.4% PB 99.9% PC 100.0%

ER 99.9% OA 99.7% IMS 99.9%

WR 99.9% EB 99.7% EW 99.1%

PL 99.2% CR 100.0%

An alternate location had to be found for sampling control vegetable samples in the Bridgewater area.

In past years, samples had been collected at the Bridgewater County Farm, associated with the Bridgewater Correctional Facility. Due to loss of state funding for garden projects during 2006, no garden was grown. An alternate location was found at the Hanson Farm in Bridgewater, located in the same compass sector, and at approximately the same distance as the Bridgewater County Farm.

As expected for control samples, vegetables collected at this location only contained naturally-occurring radioactivity (Be-7, K-40, and Ac/Th-228).

Some problems were encountered in collection of crop samples during 2009. Crops which had normally been sampled in the past (lettuce, tomatoes, potatoes, and onions) were not grown at the Plymouth County Farm (CF) during 2009. Pumpkins and squash were substituted for the edible 'hard' vegetables, whereas samples of naturally-growing leafy vegetation (grass, leaves from trees and bushes, etc.) were substituted for the lettuce. No radionuclides attributed to PNPS operations were detected in any of the samples.

Naturally-growing leafy vegetation (grass, leaves from trees and bushes, etc.) was collected near some gardens identified during the annual land use census. Due to the unavailability of crops grown in several -of these gardens, these substitute samples were collected as near as practicable to the gardens of interest. No radionuclides attributed to PNPS operations were detected in any of the samples. Additional details regarding the land use census can be found in Appendix C of this report.

The cranberry bog at Pine Street Bog in Halifax was not in production during 2009, so a sample could not be obtained from this location. A substitute sample was collected-from a bog (Hollow Bog) in Kingston, beyond the influence of Pilgrim Station.

In summary, the various problems encountered in collecting and analyzing environmental samples during 2009 were relatively minor when viewed in the context of the entire monitoring program. These discrepancies were promptly corrected when issue was identified. None of the discrepancies resuited in an adverse impact on the overall monitoring program.

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APPENDIX E J.A. FITZPATRICK INTERLABORATORY COMPARISON PROGRAM E.1 Program Description The Offsite Dose Calculation Manual (ODCM), Part 1, Section 5.3 requires that the licensee participate in an Interlaboratory Comparison Program. The Interlaboratory Comparison Program shall include sample media for which samples are routinely collected and for which comparison samples are commercially available. Participation in an Interlaboratory Comparison Program ensures that independent checks on the precision and accuracy of the measurement of radioactive material in the environmental samples are performed as part of the Quality Assurance Program for environmental monitoring. To fulfill the requirement for an Interlaboratory Comparison Program, the JAF Environmental Laboratory has engaged the services of Eckert & Ziegler Analytics, Incorporated in Atlanta, Georgia.

Analytics supplies sample media as blind sample spikes, which contain certified levels of radioactivity unknown to the analysis laboratory. These samples are prepared and analyzed by the JAF Environmental Laboratory using standard laboratory procedures. Analytics issuesa statistical summary report of the results. The JAF Environmental Laboratory uses predeterminedacceptance criteria methodology for evaluating the laboratory's performance.

The JAF Environmental Laboratory also analyzes laboratory blanks. The analysis of laboratory blanks provides a means to detect and measure radioactive contamination of analytical samples. The analysis of analytical blanks also provides information on the adequacy of background subtraction, Laboratory blank results are analyzed using control charts.

Page 85

E.2 Program Schedule Water Gross Beta 3 Water Tritium 5 Water 1-131 4 Water MixedGamma 4 Air Gross Beta 3 Air 1-131 4 Air Mixed Gamma 2 Milk 1-131 3 Milk Mixed Gamma 3 Soil Mixed Gamma 1 Vegetation Mixed Gamma 2 TOTAL SAMPLE INVENTORY 34 E.3 Acceptance Criteria Each sample result is evaluated to determine the accuracy and precision of the laboratory's analysis result. The sample evaluation method is discussed below.

E.3.1 Sample Results Evaluation Samples provided by Analytics are evaluated using what is specified as the NRC method. This method is based on the calculation of the ratio of results reported by the participating laboratory (QC result) to the Vendor Laboratory Known value (reference result).

An Environmental Laboratory analytical result is evaluated using the following calculation:

The value for the error resolution is calculated.

Error Resolution = Reference Result Reference Results Error (1 sigma)

Using the appropriate row under the Error Resolution column in Table E.3-1, a corresponding Ratio of Agreement interval is given.

The value for the ratio is then calculated.

Ratio of agreement QC Result Reference Result Page 86

If the Value falls within the agreement interval, the result is acceptable.

TABLE E.3-1 ERROR RESOLUTION. RATIO OF AGREEMENT~

<4 No Comparison 4 to 7 0.5-2.0 8 to 15 0.6-1.66 16 to 50 0.75-1.33 51 to 200 0.8-1.25

>200 0.85-1.18 This acceptance test is generally referred to as the "NRC" method. The acceptance criteria are contained in Procedure EN)-CY-102. The NRC method generally results in an acceptance range of approximately + 25% of the Known value when applied to sample results from the Eckert & Ziegler Analytics Interlaboratory Comparison Program. This method is used as the procedurally required assessment method and requires the generation of a deviation from QA/QC program report when results are unacceptable.,

E.4 Program Results Summary The Interlaboratory Comparison Program numerical results are provided on Table E.4"-1.

.E.4.1 Eckert & Ziegler Analytics QA Samples Results Thirty-four QA blind spike samples were analyzed as part of' Analytics 2009 Interlaboratory Comparison Program. The following sample media were evaluated as part of the comparison program.

• Air Charcoal Cartridge: 1-131

• Air Particulate Filter: Gross Beta, Mixed Gamma Emitters

• Water: *Gross Beta, Tritium, 1-131, Mixed Gamma Emitters

• Milk: 1-131, Mixed Gamma Emitters

• Vegetation: Mixed Gamma Emitters

• Soil: Mixed Gamma Emitters The JAF Environmental Laboratory performed 130 individual analyses on the 34 QA samples. Of the 130 analyses performed, 129 were in agreement using the NRC acceptance criteria for a 99.2%

agreement ratio.

There was one nonconformity in the 2009 program.

E.4.1.1 Eckert & Ziegler Analytics Sample Nonconformity Eckert & Ziegler Analytics Sample 6570-05, Fe-59 on Air Filter Nonconformity No. 2009-02 Corrective Action No. CR-JAF-2009-01758 A spiked mixed gamma on. an air particulate filter sample supplied by Eckert & Ziegler Analytics, Inc., was analyzed in accordance with standard laboratory procedures. The sample contained a total of nine radionuclides for analysis. Nine of the nine radionuclides present were quantified. Eight of the nine Page 87

radionuclides were quantified within the acceptable range. The mean result for Fe-59 was determined to be outside the QA Acceptance Criteria resulting in sample nonconformity and subsequent corrective action.

The filter was analyzed three times using three different detectors. An average Fe-59 value of 153 pCi was reported. The known result for the sample was 121 pCi as determined by the supplier. All nine radionuclides values quantified at the E-lab were biased high when compared to reference values.

INITIAL RESULTS ON FILTER (NON-CONFORMITY ON Fe-59)

Sample Media: Filter Sample Date: 3/19/2009 Analytics #: E56570-05 Sample Units: pCi Radionuclide JAF REFERENCE %Recovery Ce-141 131 + 1.3 115 +/- 1.92 114%

Cr-51 435 +/- 7.9 370 +/- 6.18 118%

Cs-134 134 +/- 2.0 114 +/- 1.9 118%

Cs-137 150 +/- 1.8 135 +/- 2.25 111%

Co-58 168. +/- 2.0 145 +/- 2.41 116%

Mn-54 191 + 2.1 155 +/- 2.59 123%

Fe-591 153 + 2.3 121 +/- 2.02 126%

Zn-65 233 +/- 3.9 189 +/- 3.16 123%

Co-60 193 +/- 1.7 173 '+/- 2.88 112%

Reviewed JAF E-lab data from prior years and observed a high bias for this media starting in 2008. In November of 2007, a new 16SF source geometry was purchased. The 16SF source geometry is a quarterly composite filter geometry. It was very similar to the old 16SF geometry. However, the petri dish used in our new 16SF source geometry is slightly deeper and the filters used in our new source geometry aren't as tightly packed as the old model. Sample geometry should match source geometry as close as possible to ensure accurate measurements are obtained. Existing guidance for preparing a QC filter composite sample directs the use of extra material to ensure filters are compressed; however this was for the old 16SF source geometry. Extra material to compress the filters when preparing the QC filter composite sample is no longer needed. We have stopped using extra material to compress QC filters when preparing for analysis.

To validate the cause and resolution for exceeding 25% error on Fe-59, the QC sample was prepared again without using additional packing material. The results were in good agreement and are presented below.

REANALYSIS ON FILTER WITH OUT PACKING MATERIAL Sample Media: Filter Sample Date: 3/19/2009.

Analytics #: E56570-05 Sample Units: pCi Radionuclide JAF REFERENCE %Recovery Ce-141 107 + 4.2 115 +/- 1.92 93%

Cr-51 326 + 34.0 370 +/- 6.18 88%

Cs-134 120 +/- 3.2 114 +/- 1.9 106%

Cs-137 131 +/- 2.8 135' +/- 2.25 97%

Co-58 141 +/- 4.1 145 +/- 2.41 97%

Mn-54 , 164 +/- 3.4 155 +/- 2.59 106%

Fe-59 126 +/- 6.1 121 +/- 2.02 104%

Zn-65 202 +/- 6.5 189 +/- 3.16 107%

Co-60 174 +/- 2.8 173 +/- 2.88 100%

Page 88

The E-lab "Guidance for the Processing and Reporting of' Blind Spike Quality Assurance Samples" was updated in the Procedures Reference and Laboratory Manual. In addition, a section was added to the guidance document concerning impact of future geometry changes to the JAF E-lab QA program. The following results were obtained on next available QA Spiked Air Particulate Filter.

BLINDQA SPIKE SAMPLE FOLLOWING CHANGE Sample Media: Filter Sample Date: 9/17/2009 Analytics #: E6838-05 Sample Units: pci Radionuclide - JAF REFERENCE %Recovery Ce-141 232 + 2.1 234 +/- 3.91 99%

Cr-51 180 +/- 8.2 188 +/- 3.15 96%

Cs-134 111 + 2.3 105 +/- 1.75 106%

Cs-137 156 +/- 2.2 158 +/- 2.63 99%

Co-58 83.3 +/- 1.7 84.8 +/- 1.42 98%

Mn-54 185 +/- 2.5 176 +/- 2.93 105%

Fe-59 136 +/- 2.7 126 +/- 2.1* 108%

Zn-65 192 +/- 4.2 174 +/- 2.9 110%

Co-60 132 +/- 1.7 137 +/- 2.28 96%

Note: The geometry change did not have an impact on client filters as they are not compressed prior to analysis. Additionally, no plant related radionuclides have been detected in client air particulate filter composites in the past 2 years.

Page 89

-I

E.4.3 Numerical Results Tables Table E.4-1 Interlaboratory Intercomparison Program i-131 Gamma Analysis of Air Charcoal Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

ID No. . pCi +1 sigma pCi +/- 1 sigma 83.0 +/- i.55 3/19/2009 E65 4-09 Air 1-131 86.0 +/- 3.04 79.3 1.32 1.07 A 85.0 +/- 3.21 Mean 84.7 +/- 1.56 92.0 +/- 2.57 6/18/2009 E6761-05 Air 1-131 87.9 +/- 2.49 94.7 + 1.58, 0.95 A 89.0 +/- 1.34-Mean = 89.6 +/- 1.27 89.8 +/- 2.63 9/17/2009 E6840-05 Air 1-131 87.4 +/- 2.98 91.9 +/- 1.54 0.96 A 86.7 +/- 3.04

._Mean 88.0 +/- 1.67 92.4 +/- 2.74 9/17/2009 E6831-09 Air 1-131 91.7 +/-+/- 1.69 91.7 + 1.53 1.00 A 91.3 2.93 Mean= 91.8 +/- 1.45 '

Sample provided by Eckert & Ziegler Analytics, Inc. (" Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gross Beta Analysis of Air Particulate Filter JAF E-LAB Results Reference Lab* Ratio 0)

Date Sample ID No.

Medium

[pCiAnalysis +/-:1 sigma pCi +/- 1 sigma 115.4 +/- 1.90 06/18/2009 E6758-05 Filter Gross Beta 117.5 +/- 1.92 108.0 +/- 1.80 1.08 A 116.0 +/- 1.91 Mean= 116.3 +/- 1.10 105.3 +/- 1.82 103.9 +/-1.81 *9. +/-165 .0 A 06/18/2009 E6723-09 Filter Gross Beta 98.8 1.65 1.07 106.8 +/- 1.83 Mean 105.3 +/- 1.05 107.9 +/- 2.56 12/10/2009 E6960-05 Filter Gross Beta 107.3 +/- 2.55 98.0 +/- 1.64 1.09 A 106.7 +/- 2.54 Mean = 107.3 +/- 1.47 Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Air Particulate Filter Date Sample IMedium Anai JAF E-LAB Results Reference Lab* Ratio ID No. pCi +/- I sigma pCi +/- I sigma 3/19/2009 E6570-05 Filter 133.0 +/- 1.69 Ce-141 131.0 +/- 3.28 115.0 +/- 1.92 1.14 A 130.0 +/- 1.52 Mean= 131.3 +/- 1.33 428.0 +/- 10.10 Cr-'51 463.0 +/- 19.40 370.0 +/- 6.18 1.18 A Sk415.0 +/- 9.20 Mean = 435.3 +/- 7.91 133.0 +/- 2.20 Cs-134 133.0 +/- 5.10 114.0 +/- 1.90 1.18 A 136.0 +/- 2.40 Mean= 134.0 +/- 2.02 152.0 +/- 2.14 144.0 +/- 4.55 Cs-i 37 135.0 +/- 2.25 1.11 A 153.0 +/- 2.15 Mean= 149.7 +/- 1.82 170.0 +/- 2.30 Co-58 165.0 +/- 4.94 145.0 +/- 2.41 1.16 A 169.0 +/- 2.27 Mean= 168.0 +/- 1.97 189.0 +/- 2.46 Mn-54 192.0 +/- 5.32 155.0 +/- 2.59 1.23 A 193.0 +/- 2.52 Mean = 191.3 +/- 2.13 158.0 +/- 2.81 Fe-59 142.0 +/- 5.72 121.0' +/- 2.02 1.26 U 158.0 +/- 2.76 Mean= 152'.7 +/- 2.31 233.0 +/- 4.53 I 229.0 +/- 9.63 Zn-65 229.0 +/- 9.63 189.0 +/- 3.16 1.23 A 237.0 +/- 4.59 Mean= 233.0 +/- 3.86 195.0 +/- 1.96 Co-60 189.0 +/- 4.34 173.0 +/- 2.88 1.12 A 195.0 +/- 2.04 Mean= 193.0 +/- 1.73

• Sample provided by Eckert & Ziegler Analytics, Inc. Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 91

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Air Particulate Filter Date Sample ID No.

i Analysis JAF E-LAB Results Reference Lab*

pCu+/- I sigma pCi+/-+/-1 sigma !t 9/17/2009 E6838-05 Filter 236.0 +/- 4.09 230.0 +/- 1.95 Ce-141 234.0 + 3.91 0.99 A 230.0 + 4.44 Mean = 232.0 +/- 2.11 167.0 +/- 15.80 Cr-51 179.0 +/- 8.12 188.0 +/- 3.15 0.96 A 194.0 +/- 16.90 Mean 180.0 +/- 8.17

• 104.0 +/- 4.61 Cs-1i34 113.0 +/- 2.18 105.0 +/- 1.75 1.06 A 117.0 +/- 4.64 Mean= 111.3 +/- 2.30 157.0 +/- 4.36 Cs-137 151.0 +/- 2.28 158.0 +/- 2.63 0.99 A 161.0 +/- 4.39 Mean= 156.3 +/- 2.20 85.0 +/- 3.53 84.2 +/- 1.83 Co-58 84.8 +/- 1.42 0.98 A 80.8 +/- 3.39 Mean= 83.3 +/- 1.74 184.0 +/- 4.87 Mn-54 177.0 +/- 2.57 176.0 +/- 2.93 1.05 A 193.0 +/- 5.02 Mean = 184.7 +/- 2.48 140.0 +/- 5.35 Fe-59 141.0 +/- 2.90 126.0 +/- 2.10 1.08 A 128.0 +/- 5.32 Mean= 136.3 +/- 2.69 188.0 +/- 8.32 Zn-65 198.0 +/- 4.35 174.0 +/- 2.90 1.10 A 190.0 +/- 8.48 Mean= 192.0 +/- 4.22 138.0 +/- 3.45 132.0 +/- 1.86 Co-60 137.0 +/- 2.28 0.96 A 126.0 +/- 3.32 Mean = 132.0 +/- 1.71

• Sample provided by Eckert & Ziegler.Analytics, Inc. ý')Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 92

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Soil Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

I ID No. pCI +/- 1 sigma pCi +/- 1 sigma 6/18/2009 E6760-05 Soil 0.458 +/- 0.0118 0.439 +/- 0.0242 Ce-141 0.462 +/- 0.0077 0.96 A 0.433 +/- 0.0236 Mean = 0.443 +/- 0.0090 0.689 +/- 0.0685 0.678 +/- 0.1110 Cr-51 0.652 +/- 0.0109 1.03 A 0.646 +/- 0.1050 Mean = 0.671 +/- 0.0419 0.294 +/- 0.0093 0.250 +/- 0.0193 Cs-134 0.270 +/- 0.0045 1.00 A 0.269 +/- 0.0169 Mean = 0.271 +/- 0.0068 _

0.386 +/- 0.0102 0.376 +/- 0.0209 Cs-137 0.406 +/- 0.0068 0.96 A 0.404 +/- 0.0185 Mean = r0,389 +/- 0.0074 0.138 +/- 0.0076 Co-58 0.137 +/- 0.0165 0.150 +/- 0.0025 0.97 A 0.161 +/- 0.0147 Mean 0.145 +/- 0.0058 0.235 +/- 0.0091 0,216 +/- 0.0213 Mn-54 0.223 +/- 0.0037 1.02 A 0.234 +/- 0.0169 Mean = 0.228 +/- 0.0072 0.214 +/- 0.0106 0.188 +/- 0.0234 Fe-59 0.199 +/- 0.0033 1.04 A 0.216 +/- 0.0202 Mean = 0.206 +/- 0.0082 0.319 +/- 0.0157 0.318 +/- 0.0337 Zný65 0.286 +/- 0.0048 1.13 A 0.330 +/- 0.0301 Mean= 0.322 +/- 0.0120 0.523 +/- 0.0092 0.497 +/- 0.0187 Co-60 0.507 +/- 0.0085 0.98 A 0.478 +/- 0.0156 Mean = 0.499 +/- 0.0065

~1)Ratio = JAF Mean/Analytics

• Sample provided by Eckert & Ziegler Analytics, Inc. ý"Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 93

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Vegetation Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

ID No. pCi+/-+1 sigma pCi+/- 1 sigma 6/18/2009 E6762-05 Vegetation 0.393 +/- 0.0126 0.396 +/- 0.0146 Ce-141 0.387 +/- 0.0069 0.410 +/- 0.0069 0.96 A 0.394 +/- 0.0120 Mean = 0.393 +/- 0.0059 0.488 +/- 0.0504 0.519 +/- 0.0588 Cr-51 0.533 +/- 0.0328 0.578 +/- 0.0097 0.95 A 0.647 +/- 0.0581 Mean = 0.547 +/- 0.02

+

0.263 +/- 0.0109 0.264 +/- 0.0150 Cs-134 0.275 +/- 0.0073 0.239 +/- 0.0040 1 1.10 A 0.250 +/- 0.0082 Mean = 0.263 +/- 0.0054 0.265 +/- 0.0105 0.272 +/- 0.0132 Cs-1 37 0.250 +/- 0.0067 0.277 +/- 0.0046 1 0.95 A 0.266 +/- 0.0078 Mean = 0.263 +/- 0.0049 0.121 +/- 0.0078 0.123 +/- 0.0106 Co-58 0.118 +/- 0.0050 0.133 +/- 0.0022 0.91, A 0,120 +/- 0.0074 Mean = 0.121 +/- 0.0040 0.197 +/- 0.0099 0.191 +/- 0.0129 Mn-54 0.186 +/- 0.0065 0.198 +/- 0.0033 0.98 A 0.205 +/- 0.0087 Mean= 0.195 +/- 0.0049 0.168 +/- 0.0113 0.183 +/- 0.0147 Fe-59 0.164 +/- 0.0082 0.177 +/- 0.0030 0.97 A 0.171 +/- 0.0112 Mean= 0.172 +/- 0.0058 0.237 +/- 0.0193 0.252 +/- 0.0230 Zn-65 0.233 +/- 0.0135 0.253 , +/- 0.0042 0.98 A 0.273 +/- 0.0138 Mean = 0.249 +/- 0.0089 0.440 +/- 0.0103 0.427 +/- 0.0132 Co-60 0.428 +/- 0.0070 0.450 +/- 0.0075 0.95 A 0.416 +/- 0.0078 Mean = 0.428 +/- 0.0049

• Sample provided by Eckert & Ziegler Analytics, Inc. (1) Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 94

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Vegetation Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

ID No. pCI +/- 1 sigma pCI +/- I sigma 9/17/2009 E6832-09 Vegetation 0.692 +/- 0.0150 0.691 +/- 0.0093 0.654 +/- 0.0109 Ce-141 1.07 A 0.715 +/- 0.0155 Mean= 0.699 +/- 0.0078 0.512 +/- 0.0580 0.544 +/- 0.0383 Cr-51 0.526 +/- 0.0088 1.03 A 0.569 +/- 0.0652 Mean = 0.542 +/- 0.0318 0.372 +/- 0.0125 Cs-134 0.342 +/- 0.0080 0.293 +/- 0.0049 1.22 A 0.359 +/- 0.0124 Mean = 0.358 +/- 0.0064 0.476 +/- 0.0132 0.457 +/- 0.0083 Cs-137 0.440 +/- 0.0074 1.04 A 0.444 +/- 0.0127

/ Mean = 0.459 +/- 0.0067 0.242 +/- 0.0108 0.250 +/- 0.0067 Co-58 0.237 +/- 0.0040 -1.03 A 0.243 +/- 0.0104 Mean 0.245 +/- 0.0055 0.532 +/- 0.0144 0:544 +/- 0.0092 Mn-54 0.491 +/- 0.0082 1.10 A 0.547 +/- 0.0141 Mean = 0.541 +/- 0.0074 0.388 +/- 0.0156 Fe-59 0.397 +/- 0.0101 0.350 +/- 0.0059 1.10 A 0.371 +/- 0.0154 Mean = 0.385 +/- 0.0080 0.574 +/- 0.0250 0.540 +/- 0.0158 Zn-65 0.485 +/- 0.0081 1.13 A 0.528 +/- 0.0240 Mean = 0.547 +/- 0.0127 0.401 +/- 0.0101 0.397 . +/- 0.0063 Co-60 0.382 +/- 0.0064 1.04 A 0.399 +/- 0.0096 Mean = 0.399 +/- 0.0038

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 95

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Milk DateDateID No.

Sample Medium Analysis pCl JAF +/- 1 sigma E-LAB Results pCi t 1 sigma Reference Lab* Rai Ratio()

3/19/2009 E6545-09 Milk 91.9 +/- 8.41 88.3 +/- 8.48 Ce-141 98.6 +/- 3.75 94.9 +/- 1.58 0.98 A 93.6 +/- 3.55 Mean = 93.1 +/- 3.25 318.0 +/- 44.40 302.0 +/- 45.20 Cr-51 294.0 +/- 20.40 .305.0 + 5.10 1.00 A 304.0 +/- 17.40 Mean 304.5 +/- 17.20 89.7 +/- 7.19 91.7 +/- 7.67 Cs-134 92.5 +/- 2.94 93.7 +/- 1.57 0.98 A 92.6 +/- 2.99 Mean 91.6 +/- 2.83 110.0 +/- 7.56 98.1 +/- 7.53 Cs-137 109.0 +/- 3.15 111.0 +/- 1.86 0.95 A 105.0 +/- 3.17 Mean= 105.5 +/- 2.89 110.0 +/- 7.89 119.0 +/- 8.32 Co-58 119.0 +/- 3.47 119.0 +/- 1.99 0.98 A 117.0, +/- 3.48 Mean= 116.3 +/- 3.12 142.0 +/- 8.51 122.0 +/- 8.28 Mn-54 142.0 +/- 3.61 128.0 +/- 2.13 1.05 A 130.0 +/- 3.49 Mean= 134.0 +/- 3.22 102.0 +/- 9.68 89.4 +/- .9.85 Fe-59 113.0 +/- 4.35 99.9 +/- 1.67 1.01 A 101.0 +/- 4.29 Mean 101.4 +/- 3.78 148.0 +/- 15.80 Zn-65 151.0 +/- 6.52 156.0 +/- 2.60 0.99 A 163.0 +/- 6.63 Mean 154.0 +/- 6.11 143.0 +/- 6.60 155.0 +/- 6.91 Co-60 134.0 +/- 2.73 142.0 + 2.38 1.02 A 146.0 +/- 2.91 Mean = 144.5 +/- 2.59 86.3 +/- 2.54 102.0 +/- 7.17 1-131** 81.4 +/- 5.34 79.3 +/- 1.32 1.09 A 77.3 + 3.59 Mean = 86.8 +/- 2.49

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 96

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Milk Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

ID No. pCi 11 sigma pCi +/-1 sigma 6/18/2009 E6759-05 Milk 299.0 +/- 3.04 300.0 +/- 6.52 284.0 +/- 4.74 1.05 A Ce-141 295.0 +/- 8.38 Mean = 298.0 +/- 3.68 417.0 +/- 11.10 391.0 +/- 26.10 Cr-51 400.0 +/- 6.69 0.99 A 379.0 +/- 35.10 Mean = 395.7 +/- 15.04 178.0 +/- 2.04 Cs-134 155.0 +/- 8.58 166.0 +/- 2.77 1.01 A 172.0 +/- 6.73 Mean 168.3 +/- 3.70 195.0 +/- 2.14 Cs-137 197.0 +/- 5.28 192.0 +/- 3.20 1.00 A 185.0 +/- 6.96 Mean= 192.3 +/- 3.00 97.1 +/- 1.59 Co-58 89.1 +/- 3 91.9 +/- 1.53 1.00 A 90.6 +/- 5.74 Mean = 92.3 +/- 2.38 145.0 +/- 1.95 142.0 +/- 4.54 Mn-54. 141.0 +/- 6.56 .137.0 +/- 2.29 1.04 A Mean= 142.7 +/- 2.74 130.0 +/- 2.27 129.0 +/- 5.47 Fe-59 129.0 +/- 2.04 1.05 A 126.0 +/- 7.83 Mean 128.3 +/- 3.27 191.0 +/- 3.66 Zn-65 186.0 +/- 8.64 175.0 +/- 2.93 1.06 A 182.0 +/- 12.60 Mean= 186.3 +/- 5.24 318.0 +/- 2.05 Co-60 311.0 +/- 4.92 312.0 +/- 5.21 1.00 A 310.0 +/- 6.99 Mean= 313.0 +/- 2.93 91.7 +/- 0.90 93:8 +/- 2.70 1-131** 102.0 +/- 1.70 0.92 A 95.0 +/- 2.56 Mean = 93.5 +/- 1.28

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 97

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Milk Date I Sample ID No. Medium J Analysis JAF E-LAB Results pCi 1 sigma Reference Lab*

pCi +/- 1 sigma 1Ratio (1) 9/17/2009 E6839-05 Milk 284.0 + 7.55 274.0 +/- 3.93 Ce-141 275.0 +/- 4.59 1.02 A 286.0 +/- 7.43 Mean= 281.3 +/- 3.77 216.0 +/- 25.70 Cr-51 193.0 +/- 15.50 221.0 +/- 3.69 0.94 A 213.0 +/- 28.60 Mean 207:3 +/- 13.82 117.0 *+/- 7.61 Cs-134 130.0 +/- 2.57 123.0 +/- 2.06 1.01 A 127.0 +/- 4.73 Mean 124.7 +/- 3.11 171.0 +/- 4.94 Cs-137 177.0 +/- 2.88 185.0 +/- 3.09 0.95 A 179.0 +/-5.63 Mean = 175.7 +/- 2.67 106.0 +/- 4.03 Co-58 101.0 2.28 .99.4 +/- 1.66 1.01 A 92.9 +/- 4.75 Mean = 100.0 +/- 2.21 215.0 +/- 5.51 Mn-54 222.0 +/- 3.20 206.0 +/- 3.44 1.04 A 204.0 +/- 5.98 Mean = 213.7 +/- 2.91 149.0 +/- 5.67 Fe-59 159.0 +/- 3.40 147.0 +/- 2.46 1.05 A 156.0 +/- 6.85 Mean = 154.7 +/- 3.17 216.0 +/- 9.24 Zn-65 221.0 +/- 5.43 204.0 +/- 3.40 1.07 A 219.0 +/- 10.70 Mean= 218.7 +/- 5.05 159.0 +/- 3.67 Co-60 162.0 +/- 2.13 160.0 +/- 2.68 1.00 A 157.0 +/- 4.26 Mean = 159.3 +/- 2.00 93.6 +/- 1.14 91.2 +/- 2.82 1-131"* 98.6 +/- 1.65 0.93 A 89.1 +/- 2.98 Mean= 91.3 +/- 1.42

• Sample provided by Eckert & Ziegler Analytics, Inc.

• Sample prvided by Eckert & Ziegler Analytics, Inc. "' Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 98

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gross Beta Analysis of Water Sample e M u 1 JAF E-LAB Results I Reference Lab* I (1)

Date ID No. pCi +/- 1 sigma pCi +1 sigma 234.4 +/- 2.40 03/19/2009 E6571-05 Water Gross Beta 232.6 +/- 2.40 235.0 +/- 3.92 0.99 A 230.8 +/- 2.40 Mean = 232.6 +/- 1.39 259.3 +/- 2.60 06/18/2009 E6763-05 Water Gross Beta 2607 +/- 2.60 277.0 +/- 4.63 0.93 A 254.9 +/- 2.60 Mean = 258.3 +/- 1.50 219.5 +/- 2.30 09/17/2009 E6841-05 Water Gross Beta 214.7 +/- 2.30 223.0 + 3.72 0.98 A 220.2 +/- 2.30 Mean= 218.2 +/- 1.33 Sample provided by Eckeit & Ziegler Analytics, Inc. (1)Ratio JAF Mean/Analytics A = Acceptable U = Unacceptable Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Tritium Analysis of Water Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (I)

ID No. pCi +/-1I sigma pCi 1 sigma 4814 +/- 164.0 3/19/2009 E6568-05 Water H-3 4939 +/- 165.0 4480 +/- 74.8 1.09 A 4861 +/- 165.0 Mean= 4871 +/- 95.1 939 +/- 132.0 955 +/- 132.0 6/18/2009 E6757-05 Water H-3 971 +/- 16.2 0.99 A 995 +/- 133.0 Mean= 963 +/- 76.4 1052 +/- 134.0 9/17/2009 E6842-05 Water H-3 910 +/- 133.0 991 +/- 16.6 1.00 A 1010 +/- 133.0 Mean= 991 +/- 77.0 14932 +/- 230.0 12/10/2009 E6957-09 Water H-3 14501 +/- 228.0 14000 +/- 233.0 1.04 A 14326 +/- 227.0 Mean= 14586 +/- 131.8 14491 +/- 228.0 14259 +/- 226.0 12/10/2009 E6958-09 Water H-3 14000 +/- 233.0 1.03 A 14501 +/- 228.0 Mean= 14417 +/- 131.3

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics A = Acceptable U = Unacceptable Page 99

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Water Date Sample Medium Analysis JAF E-LAB Results. Reference Lab* Ratio (1)

IID No. I I pCi +/- 1 sigma . pCi +/- 1 sigma 3/19/2009 E6569-05 Water 122.0 +/- 4.90 124.0 +/- 3.61 Ce-141 120.0 +/- 2.01 1.03 A 123.0 +/- 3.67 Mean = 123.0 +/- 2.37 411.0 +/- 25.30 I

Cr-51 373.0 +/- 16.8 387.0 +/- 6.46 1.04 A 427.0 +/- 18.20 Mean= 403.7 +/- 11.80 126.0 +/- 3.99 Cs-134 128.0 +/- 3.13 119.0 +/- 1.98 1.06 A 125.0 +/- 3.33 Mean= 126.3 +/- 2.02 146.0 +/- 4.33 Cs-137 142.0 t 3.03 141.0 +/- 2.36 1.00 A 136.0 +/- 3.11 Mean = 141.3 +/- 2.04 163:0 +/- 4.38 Co-58 153.0 +/- 3.03 151.0 +/- 2.52 1.04 A 153.0 +/- 3.35 Mean= 156.3 +/- 2.10 169.0 +/- 4.50 Mn-54 169.0 +/- 3.34 162.0 +/- 2.70 1.05 A 173.0 +/- 3.40 Mean= 170.3 +/- 2.18 135.0 +/- 4.85 Fe-59 139.0 +/- 3.46 127.0 +/- 2.11 1.07 A 2

135.0 +/- 3.81 Mean = 136.3 +/- 2.36 213.0 +/- 8.07 Zn-65 212.0 +/- 5.69 197.0 +/- 3.30 1.05 A 197.0 +/- 6.25 Mean= 207.3 +/- 3.90 188.0 +/- 3.69 Co-60 189.0 +/- 2.63 180.0 +/- 3.01 1.05 A 188.0 +/- 2.70 Mean= 188.3 +/- 1.76 72.0 +/- 2.15 68.7 +/- 1.07 1-131* 69.0 +/- 1.15 1.02 A 70.4 +/- 0.98 Mean = 70.4 +/- 0.86 Sample provided by Eckert & Ziegler Analytics, Inc. (1) Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 100

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Water Date Sample Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1)

ID No. pCI t I sigma pCi t I sigma 6/18/2009 E6722-09 Water 219.0 +/- 7.10 218.0 +/- 7.42 Ce-141 216.0 +/- 3.60 1.02 A 222.0 +/- 4.21 Mean= 219.7 +/- 3.70 277.0 +/- 31.20 C5193.0 309.0 +/- 31.40 20.20 304.0 +/- 5.08 0.96 A Mean = 293.0 +/- 16.22 124.0 +/- 4.58 Cs-134 127.0 +/- 4.80 126.1 +/- 2.10 1.03 A 138.0 +/- '3.13 Mean = 129.7 +/- 2.45 140.0 +/- 4.66 Cs-137 144.0 +/- 473 146.0 +/- 2.43 0.98 A 145.0 +/- 3.01 Mean = 143.0 +/- 2.43 67.4 +/- 3.96 Co-58 71.2 +/- 4.14 69.8 +/- 1.17 1.02 A 75.4 +/- 2.55 Mean = 71.3 +/- 2.09 107.0 +/- 4.23 Mn-54 107.0 +/- 4.51 104.0 +/- 1.74 1.03 A 107.0 +/- 2.87 Mean= 107.0 +/- 2.27 102.0 +/- 5.50 Fe-59 96.3 +/- 5.65 92.9 +/- 1.55 1.06 A 96.6 +/- 3.75 Mean= 98.3 +/- 2.91 141.0 +/- 8.34 Zn-65 157.0 +/- 8.56 133.0 +/- 2.22 1.10 A 139.0 +/- 5.26 Mean = 145.7 +/- 4.35 253.0 +/- 4.63 Co-60 243.0 +/- 4.72 237.0 +/-- 3.95 1.04 A 242.0 +/- 2.99 Mean = 246.0 +/- 2.42 84.1 +/- 4.42 92.6 +/- 4.28 1-131* 88.3 +/- 1.47 1 1.03 A 95.5 +/- 3.98 Mean = 90.7 +/- 1.83

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 101

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Water I IDNo. III pCi +/- I sigma I pCi + I sigma I Date IDaNo. Medium Analysis JAF E-LAB Results Reference Lab* Ratio (1) 9/17/2009 E6837-05 Water 277.0 +/- 3.61 269.0 +/- 6.49 Ce-141 264.0 +/- 4.40 1.02 A 261.0 +/- 6.66 Mean = 269.0 +/- 3.33 224.0 +/- 12.60 210.0 +/- 22.20 Cr-51 212.0 +/- 3.54 1.03 A 220.0 +/- 28.20 Mean= 218.0 +/- 12.68 126.0 +/- 2.15 Cs-134121.0 +/- 4.13 118.0 +/- 1.97 1.05 A 125.0 +/- 5.23 Mean= 124.0 +/- 2.33 177.0 +/- 2.40 Cs-137 176.0 +/- 4.67 177.0 +/- 2.96 1.00 A 179.0 +/- 5.37 Mean= 177.3 +/- 2.50 96.4 +/- 1.91 o-58 99.0 +/- 4.02 95.4 +/- 1.59 1.00 A 91.2 +/- 4.23 Mean= 95.5 +/- 2.05 214.0 +/- 2.64 Mn-54 208.0 +/- 5.07 198.0 +/- 3.30 1.05 A

• 204.0 +/- 5.96 Mean = 208.7 +/- 2.75 155.0 +/- 2.73 152.0 +/- 5.29

'Fe-59 152.0 +/- 5.29 141.0 +/- 2.36 1.08 A 148.0 +/- 6.36 Mean = 151.7 +/- 2.90 214.0 +/- 4.25 Zn-65 225.0 +/- 8.57 195.0, +/- 3.26 1.10 A 205.0 +/- 9.89 Mean= 214.7 +/- 4.59 155.0 +/- 1.73 Co-60153.0 +/- 3.42 154.0 +/- 2.57 1.01 A 158.0 +/- 4.11 Mean = 155.3 +/- 1.87 100.0 +/- 1.19 99.1 +/- 3.05 1-131** 98.4 +/- 1.64 1.02 A 101.0 +/- 2.92 Mean = 100.0 +/- 1.46

• Sample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysisl A = Acceptable U = Unacceptable Page 102

Table E.4-1 (Continued)

Interlaboratory Intercomparison Program Gamma Analysis of Water Date Sample Medium Analysis E-LAB JAFpCi Results Reference Lab*

PC! +/-:I sigma Ratio (1)

ID No. +/- I sigma 12/10/2009 E6959-09 Water 214.0 +/- 8.89 214.0 +/- 4.58 Ce-141 204.0 +/- 3.41 1.03 A 201.0 +/- 9.53 Mean = 209.7 +/- 4.60 1540.0 +/- 43.50 537.0 +/- 21.10 Cr-51 554.0 +/- 9.25 0.97 A 536.0 +/- 46.40 Mean = 537.7 +/- 22.34 262.0 +/- 7.33 Cs-134 260.0 +/- 3.69 255.0 +/- 4.26 1.03 A 267.0 +/- 7.12 Mean = 263.0 +/- 3.62 164.0 +/- 5.87 Cs-137 162.0 +/- 3.00 181.0 +/- 3.02 0.96 A 177.0 +/- 5.71 Mean = 174.3 +/- 2.91 218.0 +/- 6.96 Co-58 214.0 +/- 3.28 213.0 +/- 3.56 1.03 A 228.0 +/- 6.54 Mean = 220.0 +/- 3.37 199.0 +/- 6.21 Mn-54 194.0 +/- 3.12 179.0 +/- 3.00 1.09 A 193.0 +/- 6.25 Mean 195.3 +/- 3.12 185.0 +/- 8.16 Fe-59 190.0 +/- 3.99 179.0 +/- 3.00 1.07 A 202.0 +/- 8.10 Mean = 192.3 +/- 4.06 382.0 +/- 13.40 Zn-65 372.0 +/- 6.54 348.0 +/- 5.82 1.10 A 396.0 +/- 13.20 Mean = 383.3 +/- 6.64 262.0 +/- 5.43 260.0 +/-2.61 Co-60 +/- 258.0 +/- 4.31 1.01 A 258.0 +/- 5.18 Mean = 260.0 +/- 2.65 94.1 +/- 2.11 93.7 +/- 5.70 1-131"* 96.1 +/- 1.61 0.97 A 90.5 +/- 6.83 Mean = 92.8 +/- 3.05

• Sample provided by Eckert & Ziegler Analytics, Inc.

ReSample provided by Eckert & Ziegler Analytics, Inc. (1)Ratio = JAF Mean/Analytics

• • Result determined by Resin Extraction/Gamma Spectral Analysis. A = Acceptable U = Unacceptable Page 103

E.5 References E.5.1 Radioactivity and Radiochemistry, The Counting Room: Special Edition, 1994 Caretaker Publications, Atlanta, Georgia.

E.5.2 Data Reduction and Error Analysis for the Physical Sciences, Bevington P.R., McGraw Hill, New York (1969).

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