ML14139A475

Annual Radioactive Effluent Release Report for January 1 Through December 31, 2013

ML14139A475
Person / Time
Site:	Pilgrim
Issue date:	05/15/2014
From:	Jeffery Lynch Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.14.039
Download: ML14139A475 (128)

Text

Entergy Entergy Nuclear Operations, Inc.

600 Rocky Hill Road Plymouth, MA 02360 Pilgrim Nuclear Power Station May 15, 2014 U.S. Nu'clear Regulatory Commission Attn: 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 Radioactive Effluent Release Report for January 1 through December 31, 2013 LETTER NUMBER: 2.14.039

Dear Sir or Madam:

In accordance with Pilgrim Technical Specification 5.6.3, Entergy Nuclear Operations, Inc submits the attached Annual Radioactive Effluent Release Report for January 1, 2013 through December 31, 2013.

This letter contains no commitments.

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

Sincerely, Joseph R. Lynch Manager, Regulatory Assurance

Attachment:

Pilgrim Annual Radioactive Effluent Release Report for January 1, 2013 through December 31, 2013 cc: U.S. Nuclear Regulatory Commission Ms. Nadiyah Morgan, Project Manager Region 1 Division of Operating Reactor Licensing 2100 Renaissance Blvd, Suite 100 Office of Nuclear Reactor Regulation King of Prussia, PA 19406-2713 U.S. Nuclear Regulatory Commission Mail Stop O-8-F2 USNRC Senior Resident Inspector 11555 Rockville Pike Pilgrim Nuclear Power Station Rockville, MD. 20852

Attachment 1 Letter Number 2.14.038 Pilgrim Annual Radiological Environmental Operating Report for January 1, 2013 through December 31, 2013

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Annual Radiological Environmental Operating Report January 1 through December 31, 2013

• -Entergy Page 1

-Entergy PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2013 Prepared by: 0-;,-/A. -zo //-/

K.J. 96k ( ""aj Senior HPTChemistry Specialist Reviewed by:

6.\"43anke-nbiller Chemis Superintendent Reviewed by:

RBrewer Radiation Protection Manager Page 2

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2013 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 Vegetable/Vegetation Radioactivity Analyses 31 2.10 Cranberry Radioactivity Analyses 32 2.11 Soil Radioactivity Analyses 32 2.12 Surface Water Radioactivity Analyses 32 2.13 Sediment Radioactivity Analyses 33 2.14 Irish Moss Radioactivity Analyses 33 2.15 Shellfish Radioactivity Analyses 33 2.16 Lobster Radioactivity Analyses 34 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 Environmental Dosimetry Company Annual Quality Assurance Status Report APPENDIX F J.A. Fitzpatrick Interlaboratory Comparison Program APPENDIX G GEL Laboratories LLC 2013 Annual Quality Assurance Report Page 3

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2013 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 9 1.3-1 PNPS Operating Capacity Factor During 2013 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 2013 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 Vegetable/Vegetation 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 2013 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 2013 80 Page 4

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2013 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 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2013 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, 2013. 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 2013, there were 1,230 samples collected from the atmospheric, aquatic, and terrestrial environments. In addition, 431 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs).

A small number of inadvertent issues were encountered during 2013 in the collection of environmental samples in accordance with the PNPS Offsite Dose Calculation Manual (ODCM).

Nine out of 440 TLDs were unaccounted for during the quarterly retrieval process. However, the 431 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 563 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 1,286 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 09 and September 20, 2013. A total of 30 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 30 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 2013, 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 40 and 76 milliRoentgens per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts.

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2013, 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 2013 was about 0.9 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 2013 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 2013 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, 2013.

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, American 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 Chemistry 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 about 620 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 (1)

NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem/year)

Internal, inhalation(2) 230 Medica1(3) 300 External, space 30 Consumerý4 ) 12 Internal, ingestion 30 Industrial(5) 0.6 External, terrestrial 20 Occupational 0.6 Weapons Fallout < 1 Nuclear Power Plants < 1 Approximate Total 310 Approximate Total 315 Combined Annual Average Dose: Approximately 620 to 625 milliremryear (1) Information from NCRP Reports 160 and 94 (2) Primarily from airborne radon and its radioactive progeny (3) Includes CT (150 millirem), nuclear medicine (74 mrem), interventional fluoroscopy (43 mrem) and conventional radiography and fluoroscopy (30 mrem)

(4) Primarily from cigarette smoking (4.6 mrem), commercial air travel (3.4 mrem), building materials (3.5 mrem), and mining and agriculture (0.8 mrem)

(5) Industrial, security, medical, educational, and research 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 30 millirem/yr), the ground we walk on (about 20 millirem/yr) and the air we breathe (about 230 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.

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In total, these various sources of naturally-occurring radiation and radioactivity contribute to a total dose of about 310 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 300 mrem. Consumer activities, such as smoking, commercial air travel, and building materials contribute about 13 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 314 mrem per year from man-made sources. The collective dose from naturally-occurring and man-made sources results in a total dose of approximately 620 mrem/yr to the average American.

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 2013, with the exception of the refueling outage that occurred between mid-April through May. The resulting monthly capacity factors are presented in Table 1.3-1.

TABLE 1.3-1 PNPS OPERATING CAPACITY FACTOR DURING 2013 (Based on rated reactor thermal power of 2028 Megawatts-Thermal)

Month Percent Capacity January 69.3%

February 68.8%

March 92.8%

April 38.9%

May 1.8%

June 97.0%

July 99.6%

August 76.8%

September 67.7%

October 76.7%

November 99.0%

December 86.8%

Annual Average 72.9%

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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 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 Uranium Neutrons Radiation Neutron S( Neutrons Uranium 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).

Co-59 C0-60 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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1. FUEL PELLETS

2. FUE 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 filtration 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 ifthe 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 operators 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 from the 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 2013 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 LIQUID EFFLUENTS

-64. DIRECT RADIATION (SOIL DEPOSITION)

(AIR SUBMERSION)

1. SHORELINE DIRECT RADIATION (FISHING, PICNICJNG) _ 1

5. CONSUMPTION (VEGETATION)

DEPOSITION

2. DIRECT RADIATION (IMMERSION IN OCEAN, BOATING, SWIMMING) f DEPOSITION INGESTION #N -

• I

• . ~(FISH, SHELLFISH)

INIGESTION 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;

• 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:

0 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-131, 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 40CFR190.10 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 2013 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 2013 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 environment 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-1 37 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 in 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 2013 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.

• Specialized analysis of sediment for plutonium isotopes was removed.

" 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 2013 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 2013 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 2013 results of these programs are summarized in Appendix E. These results indicate that the analyses and measurements performed during 2013 exhibited acceptable precision and accuracy.

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2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2013. 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-1 37), 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 the 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 41). Gross beta (GR-B) analyses were performed on 563 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, 511 out of 511 samples indicated detectable activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 511 indicator station samples was 0.014 +/- 0.0049 (1.4E-2 +/- 4.9E-3) pCi/m3. Individual values ranged from 0.00047 to 0.035 (4.7E 3.5E-2) pCi/m 3.

The monitoring station which yielded the highest mean concentration was the Control location EW (East Weymouth), which yielded a mean concentration of 0.014 +/- 0.0053 pCi/m 3 , based on 52 Page 27

observations. Individual values ranged from 0.0044 to 0.030 pCi/m 3. Fifty-two of the fifty-two samples showed detectable activity at the three-sigma level.

At the control location, 52 out of 52 samples yielded detectable gross beta activity, for an average concentration of 0.014 +/- 0.0043 pCi/m 3 . Individual samples at the control location ranged from 0.0044 to 0.030 pCi/m 3.

Referring to the next-to-last entry row in the table, analyses for cesium-1 37 (Cs-1 37) were performed 43 times (quarterly composites for 11 stations

• 4 quarters, minus one quarterly sample). No samples exceeded ten times the mean control station concentration. The required LLD value Cs-137 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 2013, 431 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 ranged from 40 to 154 mR/yr. The average exposure rate at control locations greater than 15 km from Pilgrim Station (i.e., Zone 4) was 60.2 +/- 10.9 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 27 and 93 mR/yr. The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 40 to 81 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). Due to heightened security measures following September 11 2001, members for the general public do not have access to such locations within the owner-controlled area.

One TLD, located in the basement of the Plymouth Memorial Hall, indicated an annual exposure of 76 mR in 2013. 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 71.6

+/- 2113 mR/yr to 62.2 +/- 8.9 mR/yr. Additionally, exposure rates measured at areas beyond Entergy's control did not indicate any 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 62.1 +/- 7.7 mR/yr, which compares quite well with the average control location exposure of 62.2 +/- 8.9 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), 563 samples were collected and analyzed during 2013.

Several air sampling stations lost power during winter storm Nemo during the week of 05-Feb through 12-Feb 2014. Another problem occurred at location WR when tree trimming activities on 14-Aug-2012 resulted in damage to the electrical service and sampling station. The sampler was not repaired until 28-Feb-2013, resulting in the loss of sampling capabilities at this location for the last 21 weeks of 2012, and the first eight weeks of 2013. This event is described in Condition Report CR-PNP-2012-3545. There were also 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 563 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 563 of the filter samples collected, including 52 of the 52 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 1 of 4 control samples. No airborne radioactivity attributable to Pilgrim Station was Page 29

detected in any of the samples collected during 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.6 Charcoal Cartrid-ge 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), 563 samples were collected and analyzed during 2013. Several air sampling stations lost power during winter storm Nemo during the week of 05-Feb through 12-Feb 2014. Another problem occurred at location WR when tree trimming activities on 14-Aug-2012 resulted in damage to the electrical service and sampling station. The sampler was not repaired until 28-Feb-2013, resulting in the loss of sampling capabilities at this location for the last 21 weeks of 2012, and the first eight weeks of 2013. This event is described in Condition Report CR-PNP-2012-3545. There were also 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 2013, required LLDs were met on 563 of the 563 cartridges collected during 2013.

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

No airborne radioactive iodine attributable to Pilgrim Station 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 no suitable 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) had been collected in the past from the Plymouth County Farm, and from control locations in Bridgewater. However, due to the absence of any grazing animals within a five-mile radius of Pilgrim Station that are used for generation of food products (milk or meat), no samples of forage were collected during 2013. A number of wild vegetation samples were collected within a five mile radius of Pilgrim Station as part of the vegetable/vegetation sampling effort, and the results of this sampling would provide an indication of any radioactivity potentially entering the forage-milk or forage-meat pathways. Results of the vegetable/vegetation sampling effort are discussed in the following section.

2.9 VecietableNegetation Radioactivity Analyses Samples of vegetables and naturally-growing vegetation have historically been collected from the Plymouth County Farm and from the control locations in Bridgewater, Sandwich, and Norton. 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 factors. All of the various samples of vegetables/vegetation are collected annually and analyzed by gamma spectroscopy.

Twenty-three samples of vegetables/vegetation were collected and analyzed as required during 2013. 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 several of the samples collected. Cesium-137 was also detected in four out of 15 samples of vegetation collected from indicator locations, and one of eight control samples collected, with concentrations ranging from non-detectable (<12 pCi/kg) up to 61 pCi/kg. The highest concentration of 61 pCi/kg was detected in a sample of natural vegetation collected from the Pine Hills area of the Pine Hills south of PNPS. This Cs-137 result is within of the normal range of average values expected for weapons-testing fallout (75 to 145 pCi/kg as projected from the pre-operational sampling program).

It should be noted that natural vegetation samples collected in the 1990s often showed detectable Cs-137 from nuclear weapons tests up into the range of 300 to 400 pCi/kg, whereas soil samples often indicated concentrations in excess of 2000 pCi/kg. Cs-137 has a 30-year half-life, and measureable concentrations still remain in soil and vegetation as a result of atmospheric nuclear weapons testing performed during the 1950s through 1970s. Weekly particulate air filters collected from the Cleft Rock sampling station within 400 meters of where the vegetation was sampled indicated no detectable Cs-137. A review of effluent data presented in Appendix B indicates that there were no measurable airborne releases of Cs-137 from Pilgrim Station during 2013 that could have attributed to this level. The sample with the highest level of Cs-137 also contained high levels of Ra-226 and AcTh-228, indicating appreciable soil content on the vegetation. This sample of natural vegetation was analyzed "as is" without any measure to clean the samples as normally would be performed prior to consuming vegetables, and would have detected any Cs-1 37 in soil adhering to those leaves collected. Certain species of plants such as sassafras are also known to concentrate chemical elements like cesium, and this higher-than-expected level is likely due to a combination of external soil contamination and bioconcentration in the leaves of the plants sampled. These levels are not believed to be indicative of any releases associated with Pilgrim Station. No radioactivity attributable to Pilgrim Station was detected in any of the vegetable/vegetation samples collected during 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.10 Cranberry Radioactivity Analyses Samples of cranberries are normally 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. In 2012, the bog on Bartlett Road 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.

Two samples of cranberries were collected and analyzed during 2013. One of the bogs normally sampled along Bartlett Road is no longer in production. Results of the gamma analyses of cranberry samples are summarized in Table 2.10-1. Cranberry samples collected during 2013 yielded detectable levels of naturally-occurring beryllium-7, potassium-40, and radium-226. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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 these quarterly samples.

A total of 36 samples (3 locations

• 12 sampling periods) of surface water were collected and analyzed as required during 2013. 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 surface water samples collected during 2013.

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 Radioactive Effluent Release Report.

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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 of twelve required samples of sediment were collected during 2013. 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 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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 (Brant Rock). 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 2013 were obtained and analyzed.

Results of the gamma analyses of these samples are summarized in Table 2.14-1. 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 2013, 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 2013 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 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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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.

Five samples of lobsters were collected as required during 2013. 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 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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.

Eight samples of fish were collected during 2013. The autumn sample of Group I Fish (flounder) was not available during the October sampling period due to seasonal unavailability as the fish moved away from the Discharge Outfall to deeper water. 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 2013, 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 Radioloqical Environmental Samplingq 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 Forae 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 Radioloqical Environmental Sampling Locations Pil.rim 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* Quarterl Exposure - mR/quarter (Value +/- Std.Dev.)

2013 Annual-ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure I I mR/year Zone 1 TLDs: 0-3 km 0-3 km 17.1 +/- 5.1 16.5 +/- 4.8 18.4 +/- 5.8 19.6 +/- 5.2 71.6 +/- 21.3 BLW BOAT LAUNCH WEST 0.11 km E 32.6+/- 1.6 33.1 +/- 1.0 35.5+/-2.1 34.4_+/-2.9 135.6+/-6.7 OA OVERLOOK AREA 0.15kmW 37.9+/-2.0 30.3+/- 1.4 42.9+/-2.5 43.2+/- 1.7 154.3+/-24.3 TC HEALTH CLUB 0.15 km WSW 18.4 +/- 0.8 16.5 +/- 0.6 20.5 +/- 0.8 20.6 +/- 0.9 76.0 +/- 7.9 BLE BOAT LAUNCH EAST 0.16 km ESE 27.0 +/- 1.9 31.7 +/- 2.4 31.8 +/- 1.2 29.1 +/- 1.8 119.5 +/-9.9 PB PEDESTRIAN BRIDGE 0.21 km N 26.2 +/- 1.4 24.4 +/- 0.8 26.9 +/- 1.1 27.4 +/- 1.5 104.9 +/- 5.9 P01 SHOREFRONT SECURITY 0.22 km NNW 15.9 +/- 0.8 16.5 +/- 0.7 18.1 +/- 1.2 18.6 +/- 1.0 69.1 +/- 5.5 WS MEDICAL BUILDING 0.23 km SSE 18.6 +/- 1.2 18.2 +/- 0.8 20.0 +/- 1.0 21.0 +/- 1.0 77.8 +/- 5.5 CT PARKING LOT 0.31 km SE 19.2 +/- 1.3 18.2 +/- 0.6 20.9 +/- 0.8 19.0 +/- 0.7 77.3 +/- 4.9 PA SHOREFRONT PARKING 0.35 km NNW 16.3 +/- 0.9 17.8 +/- 0.7 19.7 +/- 1.0 18.7 +/- 0.9 72.5 +/- 6.0 A STATION A 0.37 km WSW 14.6 +/- 1.5 14.4 +/- 0.8 16.5 +/- 0.8 18.9 +/- 0.9 64.4 +/- 8.6 F STATION F 0.43 km NW 15.0 +/- 0.7 14.0 +/- 0.8 16.4 +/- 0.7 18.8 +/- 1.0 64.2 +/- 8.4 EB EAST BREAKWATER 0.44 km ESE 16.0 +/- 0.9 17.5 +/- 1.0 18.6 +/- 0.7 19.0 +/- 0.9 71.1 +/- 5.7 B STATION B 0.44 km S 22.7 +/- 0.9 18.6 +/- 0.7 21.5 +/- 1.2 23.4 +/- 1.2 86.2 +/- 8.7 PMT PNPS MET TOWER 0.44 km WNW 17.3 +/- 0.9 15.7 +/- 1.0 17.7 +/- 0.7 20.8 +/- 1.1 71.5 +/- 8.7 H STATION H 0.47 km SW 17.7 +/- 1.4 16.6 +/- 0.6 19.6 +/- 1.0 21.9 +/- 1.1 75.8 +/- 9.5 I STATION I 0.48 km WNW 15.9 +/- 1.0 13.9 +/- 0.7 16.9 +/- 0.8 19.5 +/- 0.9 66.2 +/- 9.5 L STATION L 0.50 km ESE 15.4 +/- 0.7 18.6 +/- 0.7 19.2 +/- 0.8 18.5 +/- 1.0 71.7 +/- 7.0 G STATION G 0.53 kmW 15.3+/-0.9 14.1+/-0.8 16.1 +/-0.7 16.2+/-0.8 61.8+/-4.2 D STATION D 0.54 km NNW 18.5 +/- 0.9 15.5 +/- 0.6 17.3 +/- 1.0 20.2 +/- 1.0 71.5 +/- 8.1 PL PROPERTY LINE 0.54 km NW 15.4+/-0.8 15.9+/-0.8 16.6+/- 1.1 16.8+/-0.9 64.7+/-3.2 C STATION C 0.57 km ESE 16.0 +/- 0.8 14.7 +/- 0.6 18.4 +/- 1.2 17.8 +/- 0.9 66.8 +/- 6.9 HB HALL'S BOG 0.63 km SE 14.6 +/- 0.8 17.3 +/- 0.6 19.1 +/- 1.0 Missing 67.9 +/- 9.2 GH GREENWOOD HOUSE 0.65 km ESE 16.4 +/- 0.9 17.0 +/- 0.7 Missing 17.7 +/- 0.8 68.1 +/- 3.4 WR W ROCKY HILL ROAD 0.83 km WNW 19.6 +/- 0.8 19.2 +/- 0.9 20.9 +/- 0.9 20.8 +/- 1.0 80.5 +/- 3.8 ER E ROCKY HILL ROAD 0.89 km SE 14.0 +/- 0.9 14.2 +/- 0.7 14.4 +/- 0.8 15.2 +/- 0.8 57.8 +/- 2.6 MT MICROWAVE TOWER 1.03 km SSW 14.4 +/- 0.6 18.0 +/- 0.7 16.0 +/- 0.8 16.9-+/- 0.9 65.2 +/- 6.4 CR CLEFT ROCK 1.27 km SSW 18.3 +/- 0.8 17.5 +/- 0.9 15.9 +/- 1.1 17.3 +/- 1.2 68.9 +/- 4.4 BD BAYSHORE/GATE RD 1.34 km WNW 14.9 +/- 0.7 14.8 +/- 0.6 16.7 +/- 0.8 17.8 +/- 0.9 64.2 +/- 6.0 MR MANOMET ROAD 1.38 km S 16.0 +/- 0.7 15.2 +/- 0.6 17.4 +/- 0.7 20.3 +/- 1.0 68.9 +/- 9.2 DR DIRT ROAD 1.48 km SW 12.9+/-0.6 11.7+/-0.5 13.4+/-0.6 16.8+/- 1.2 54.8+/-8.9 EM EMERSON ROAD 1.53 km SSE 15.9 +/- 0.8 14.2 +/- 0.6 16.1 +/- 0.7 16.9 +/- 1.0 63.1 +/- 4.8 EP EMERSON/PRISCILLA 1.55 km SE Missing 14.5 +/- 0.8 16.4 +/- 0.9 17.4 +/- 0.9 64.5 +/- 6.2 AR EDISON ACCESS ROAD 1.59 km SSE 13.1 +/- 0.7 12.8 +/- 0.6 14.3 +/- 0.7 17.2 +/- 0.8 57.5 +/- 8.2 BS BAYSHORE 1.76 km W 16.1 +/- 0.8 15.4 +/- 0.8 17.3 +/- 0.7 20.3 +/- 1.0 69.1 +/- 8.9 E STATION E 1.86 km S 15.1 +/- 0.7 13.7 +/- 0.5 15.6 +/- 0.6 17.9 +/- 1.0 62.3 +/- 7.2 JG JOHN GAULEY 1.99 km W 15.4 +/- 0.7 14.6 +/- 0.6 16.4 +/- 0.8 18.1 +/- 1.2 64.5 +/- 6.2 J STATION J 2.04 km SSE 13.5 +/- 0.7 13.1 +/- 0.5 15.1 +/- 1.2 17.4 +/- 0.8 59.2 +/- 8.0 WH WHITEHORSE ROAD 2.09 km SSE 15.6 +/- 0.6 14.5 +/- 0.5 16.2 +/- 0.8 17.1 +/- 0.8 63.4 +/- 4.7 RC PLYMOUTH YMCA 2.09 km WSW 14.0_+/-0.6 14.0_+/-0.6 15.3+/-0.7 18.8+/- 1.0 62.1 +/-9.2 K STATION K 2.17 krn S 13.5 +/- 0.6 13.1 +/- 0.8 14.2 +/- 0.8 17.0 +/- 0.8 57.9 +/- 7.1 TT TAYLOR/THOMAS 2.26 km SE 15.2 +/- 0.8 12.8 +/- 0.7 15.0 +/- 0.7 16.0 +/- 1.0 59.0 +/- 5.6 YV YANKEE VILLAGE 2.28 km WSW 14.7 +/- 0.6 14.4 +/- 0.6 15.2 +/- 1.3 18.6 +/- 0.9 62.9 +/- 8.0 GN GOODWIN PROPERTY 2.38 km SW 11.2+/- 0.8 10.1+/-0.6 11.5+/- 0.5 14.9+/- 1.0 47.8+/- 8.4 RW RIGHT OF WAY 2.83 km S 12.7+/-0.8 11.4+/-0.9 12.9+/-0.6 13.0+/-+0.7 50.0_+/-3.4 TP TAYLORIPEARL 2.98 km SE 15.0 +/- 0.7 12.6 +/- 0.6 15.0 +/- 1.4 15.3 +/- 0.9 57.8+/- 5.4 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.)

2013 Annual-ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure

/ 1mR/year Zone 2 TLDs: 3-8km 3-8km 14.2+/-2.3 13.0+/- 1.9 14.8+/-2.0 15.9+/-2.0 57.8+/-9.0 VR VALLEY ROAD 3.26 km SSW 14.2 +/- 0.8 11.7 +/- 0.6 14.3 +/- 0.9 Missing 53.6 +/- 6.2 ME MANOMET ELEM 3.29 km SE 14.8 +/- 0.7 13.1 +/- 0.8 15.4 +/- 0.7 Missing 57.8 +/- 5.0 WC WARREN/CLIFFORD 3.31 km W 12.7 +/- 0.6 12.3 +/- 0.7 Missing 16.9 +/- 0.9 55.9 + 10.5 BB RT.3A/BARTLETT RD 3,33 km SSE 14.9 +/- 0.8 13.5 +/- 0.5 14.9 +/- 0.6 18.1 +/- 1.1 61.4 7.9 MP MANOMET POINT 3.57 km SE 15.0 +/- 0.7 13.0 +/- 1.0 15.1 +/- 0.7 14.9 +/- 0.8 57.9 +/-4.3 MS MANOMET SUBSTATION 3.60 km SSE 16.9 +/- 0.6 17.1 +/- 0.9 17.5 +/- 0.8 17.8 +/- 0.9 69.2 +/- 2.3 BW BEACHWOOD ROAD 3.93 km SE 15.6 +/- 0.7 12.6 +/- 0.7 15.6 +/- 0.8 16.4 +/- 1.1 60.3 +/- 6.9 PT PINES ESTATE 4.44 km SSW 13.2 +/- 0.7 11.6 +/- 0.6 14.1 +/- 0.7 14.2 +/- 0.8 53.2 +/-4.9 EA EARL ROAD 4.60 km SSE 11.9+/-0.6 12.1+/-0.6 12.8+/- 1.0 16.4+/- 1.1 53.2+/-8.7 SP S PLYMOUTH SUBST 4.62 km W 15.8 +/- 1.1 13.4 +/- 0.5 15.8 +/- 1.2 15.6 +/- 0.8 60.6 5.1 RP ROUTE 3 OVERPASS 4.81 km SW 15.8 +/- 1.2 13.6 +/- 0.6 16.0 +/- 0.7 15.8 +/- 0.7 61.2++/-5.0 RM RUSSELL MILLS RD 4.85 km WSW 14.3 +/- 1.2 12.4 +/- 0.6 14.9 +/- 0.7 15.1 +/- 0.8 56.7 +/- 5.3 HD HILLDALE ROAD 5,18 km W 13.8 +/- 1.0 13.6 +/- 0.9 15.2 +/- 0.9 17.7 +/- 0.9 60.2 +/- 7.7 MB MANOMET BEACH 5,43 km SSE 15.7 +/- 0.8 13.4 +/- 0.6 15.7 +/- 1.0 16.3 +/- 0.9 61.2 +/- 5.4 BR BEAVERDAM ROAD 5.52 km S 15.0 +/- 1.3 13.4 +/- 0.6 15.7 +/- 1.5 16.0 +/- 0.8 60.1 +/- 5.0 PC PLYMOUTH CENTER 6.69 km W 9.7 +/- 0.7 9.9 +/- 0.6 9.9 +/- 0.8 11.0 +/- 0.6 40.5 +/- 2.7 LD LONG POND/DREW RD 6.97 km WSW 10.9 +/- 0.5 14.0 +/- 0.6 13.7 +/- 0.6 16.5 +/- 0.9 55.2 +/- 9.2 HR HYANNIS ROAD 7.33 km SSE Missing Missing 14.0 +/- 0.7 15.0 +/- 0.7 57.9 +/- 3.4 SN SAQUISH NECK 7.58 km NNW 10.6 +/- 1.1 9.2 +/- 0.4 11.8 +/-0.9 12.8 +/- 0.9 44.6 +/- 6.5 MH MEMORIAL HALL 7.58 km WNW 19.1 +/- 0.7 17.6 +/- 0.7 19.4 0.8 19.9 +/- 0.9 76.0 +/- 4.2 CP COLLEGE POND 7.59 km SW 13.3 +/- 0.7 13.3 +/- 0.6 14.3 +/- 0.8 Missing 54.4 +/- 3.0 Zone3TLDs: 8-15km 8-15 km 13.8+/- 1.1 13.0+/- 1.7 14.1 +/- 1.7 15.9+/- 1.9 56.7+/-7.6 DW DEEP WATER POND 8.59 km W 15.3 +/- 0.9 14.4 +/- 0.5 16.9 +/- 1.1 18.8 +/- 1.4 65.3 +/- 8.0 LP LONG POND ROAD 8.88 km SSW 13.2 +/- 0.7 12.2 +/- 0.6 13.1 +/- 0.6 14.8 +/- 0.7 53.3 +/- 4.5 NP NORTH PLYMOUTH 9.38 km WNW 15.3 +/- 0.7 17.4 +/- 1.0 17.3 +/- 1.0 19.5 +/- 1.5 69.4 +/- 7.3 SS STANDISH SHORES 10.39 krn NW 13.3+/-0.6 11.9+/-0.6 13.5+/-0.7 15.1 +/- 1.0 53.9+/-5.4 EL ELLISVILLE ROAD 11.52 km SSE 14.6 +/- 0.9 12.7 +/- 0.6 14.0 +/- 0.9 15.3 +/- 0.8 56.7 +/- 4.6 UC UP COLLEGE POND RD 11.78 kmSW 11.7+/- 1.5 11.6+/-0.4 12.2+/-0.8 13.7+/-0.8 49.2+/-4.3 SH SACRED HEART 12.92 km W 14.3 +/- 0.8 12.6 +/- 0.8 13.8 +/- 0.6 15.7 +/- 0.8 56.5 +/- 5.4 KC KING CAESAR ROAD 13.11 km NNW 13.6 +/- 0.8 12.1 +/- 0.5 13.4 +/- 0.6 15.8 +/- 0.8 54.8 +/- 6.3 BE BOURNE ROAD 13.37 km S 13.4 +/- 0.7 12.1 +/- 0.5 12.9 +/- 0.5 14.4 +/- 1.1 52.8 +/- 4.0 SA SHERMAN AIRPORT 13.43 km WSW 13.1 +/- 0.6 12.5 +/- 0.7 13.5 +/- 0.7 15.8 +/- 1.0 54.9 +/- 5.9 Zone 4 TLDs: >15 km >15 km 14.7 +/- 2.9 13.9 +/- 3.0 15.2 +/- 2.6 16.4 +/- 2.5 60.2 +/-10.9 CS CEDARVILLE SUBST 15.93 km S 15.8 +/- 0.7 13.9 +/- 0.6 16.3 +/- 0.8 17.3 +/- 1.4 63.3 +/- 6.1 KS KINGSTON SUBST 16.15 km WNW 15.3 +/- 0.8 14.3 +/- 0.5 15.2 +/- 0.7 16.6 +/- 0.9 61.4 +/-4.1 LR LANDING ROAD 16.46 km NNW 13.4 +/- 0.9 12.8 +/- 0.5 14.6 +/- 0.7 15.2 +/- 0.9 56.0 +/- 4.6 CW CHURCH/WEST 16.56 km NW 9.1 +/-0.5 8.5 0.5 10.4 +/- 0.9 11.7 +/- 0.7 39.7 +/-5.9 MM MAIN/MEADOW 17.02 km WSW 14.4 +/-0.7 13.4 +/-0.8 14.5 +/- 1.0 16.7 +/- 1.3 59.0 +/-5.8 DMF DIV MARINE FISH 20.97 km SSE 17.5 +/-0.9 17.8 +/-1.3 17.6 +/- 0.7 19.4 +/- 0.9 72.4 +/-4.0 EW E WEYMOUTH SUBST 39.69 km NW 17.6 +/- 1.0 16.4 +/- 0.9 17.9 +/- 0.7 18.0 +/- 1.2 69.9 +/- 3.5

• 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* Quarterl Exposure- mR/quarter (Value+/- Std.Dev.)

2013 Annual-ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec I I I 1mR/year Exposure Onsite TLDs P21 O&M/RXB. BREEZEWAY 50 m SE 28.2 +/- 1.2 29.0 +/- 1.2 26.5 +/- 1.2 24.5 +/- 1.1 108.2 +/-8.4 P24 EXEC.BUILDING 57 m W 42.7 +/- 1.5 41.1 +/- 1.5 47.7 +/- 2.4 50.8 +/- 2.8 182.4 +/- 18.5 P04 FENCE-R SCREENHOUSE 66 m N 36.5 +/- 1.3 41.2 +/- 2.0 43.4 +/- 1.8 44.0 +/- 1.8 165.2 +/- 14.1 P20 O&M - 2ND W WALL 67 m SE 27.3 +/- 1.7 24.1 +/- 0.8 28.0 +/- 2.2 28.3 +/- 1.9 107.7 +/-8.4 P25 EXEC.BUILDING LAWN 76 m WNW 33.9 +/- 1.7 43.0 +/- 2.1 43.1 +/- 2.5 47.4 +/- 3.2 167.4 +/- 23.2 P05 FENCE-WATER TANK 81 m NNE 21.1 +/- 0.9 21.7 +/- 1.0 22.5 +/- 0.9 24.2 +/- 0.9 89.4 +/- 5.6 P06 FENCE-OIL STORAGE 85m NE 29.4+/- 1.2 29.4+/- 1.4 30.3+/- 1.8 31.5+/-2.4 120.6+/-5.4 P19 O&M - 2ND SW CORNER 86 m S 20.2 +/- 1.0 19.8 +/- 0.8 20.8 +/- 1.2 22.4 +/- 1.1 83.2 +/-4.9 P18 O&M - 1ST SW CORNER 90mS 24.3+/- 1.4 23.5+/-0.8 29.8+/- 1.1 31.3+/-2.0 108.9+/- 15.8 P08 COMPRESSED GAS STOR 92 rn E 31.9 +/- 2.4 31.5 +/- 2.5 32.4 +/- 1.3 34.2 +/- 1.6 130.0 +/- 6.2 P03 FENCE-L SCREENHOUSE 100 m NW 33.7 +/- 1.2 29.0 +/- 0.9 32.8 +/- 1.2 35.0 +/- 2.4 130.5 +/- 10.7 P17 FENCE-EXEC.BUILDING 107 m W 51.0 +/- 2.9 42.9 +/- 3.3 52.5.+/- 2.1 52.9 +/- 1.9 199.3+/- 19.4 P07 FENCE-INTAKE BAY 121 rn ENE 25.4 +/- 1.3 25.5 +/- 1.3 28.7 +/- 1.2 28.2 +/- 1.1 107.8 +/- 7.5 P23 O&M- 2ND S WALL 121 mSSE 26.0+/- 1.3 23.4+/-0.9 27.1 +/- 1.4 29.2_+/- 1.4 105.8+/- 10.0 P26 FENCE-WAREHOUSE 134 m ESE 28.3 +/- 1.2 31.1 +/- 1.2 29.6 +/- 1.7 30.4 +/- 1.7 119.4 +/-5.7 P02 FENCE-SHOREFRONT 135m MNW 25.4 +/- 1.2 23.5 +/- 0.8 28.7 +/- 1.7 29.7 +/- 1.2 107.4+/- 11.8 P09 FENCE-W BOAT RAMP 136 m E 26.1 +/- 1.2 25.9 +/- 1.5 27.5 +/- 1.6 26.5 +/- 1.5 106.0 +/- 4.1 P22 O&M - 2ND N WALL 137 m SE 20.6 +/- 1.1 20.7 +/- 0.8 21.8 +/- 0.9 22.2 +/- 1.2 85.3 +/- 3.7 P16 FENCE-W SWITCHYARD 172 m SW 69.1 +/- 2.7 56.4 +/- 3.3 76.1 +/- 4.0 75.4 +/- 5.0 276.9 37.3 P11 FENCE-TCF GATE 183 m ESE 40.1 +/- 1.7 53.0 +/- 1.6 51.5 +/- 3.0 38.4 +/- 1.8 183.0+/- 30.5 P27 FENCE-TCF/BOAT RAMP 185 m ESE 21.8+/- 1.0 23.6+/- 1.1 25.0+/- 1.9 23.5+/- 1.3 93.9+/-5.8 P12 FENCE-ACCESS GATE 202 m SE 23.9 +/- 1.0 21.8 +/- 0.7 23.5 +/- 1.3 25.3 +/- 1.3 94.6 +/- 6.2 P15 FENCE-E SWITCHYARD 220 m S 22.0 +/- 1.1 21.7 +/- 1.0 24.5 +/- 0.9 25.1 +/- 1.7 93.2 +/- 7.4 P10 FENCE-TCF/INTAKE BAY 223 m E 24.9 +/- 1.7 28.6 +/- 1.2 29.6 +/- 1.6 24.8 +/- 1.1 107.9 +/- 10.2 P13 FENCE-MEDICAL BLDG. 224 m SSE 21.5+/- 1.2 20.3+/- 1.5 22.9+/- 1.4 24.7+/- 1.4 89.4+/-8.1 P14 FENCE-BUTLER BLDG 228 m S 20.8 +/- 0.9 18.9 +/- 1.1 21.1 +/- 0.9 22.9 +/- 1.3 83.7 +/- 6.7 P28 FENCE-TCF/PRKNG LOT 259 m ESE 68.2 +/- 2.3 53.1 +/- 2.8 80.0 +/- 4.7 55.7 +/- 2.1 257.1 +/- 50.0

• 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 2013 Average Exposure +/- Standard Deviation: mR/)eriod Exposure Zone 1* 1 Zone 2 Zone 3 Zone 4 Period 0-3 km 3-8 km 8-15 km >15 km Jan-Mar 17.1 +/- 5.1 14.2 +/- 2.3 13.8 +/- 1.1 14.7 +/- 2.9 Apr-Jun 16.5 +/- 4.8 13.0 +/- 1.9 13.0 +/- 1.7 13.9 +/- 3.0 Jul-Sep 18.4 +/- 5.8 14.8 +/- 2.0 14.1 +/- 1.7 15.2 +/- 2.6 Oct-Dec 19.6 +/- 5.2 15.9 +/- 2.0 15.9 +/- 1.9 16.4 +/- 2.5 Jan-Dec 71.6 +/- 21.3** 57.8 +/- 9.0 56.7 +/- 7.6 60.2 +/- 10.9 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 62.2 +/- 8.9 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 2013)

KAr-n1"KA* W, AD j 9 Fj_

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 563 0.01 1.3E-2 +/- 4.9E-3 EW: 1.4E-2 +/- 5.3E-3 1.4E-2 +/- 5.3E-3 0 4.7E 3.5E-2 4.4E 3.OE-2 4.4E 3.OE-2 511/511 52/52 52/52 Be-7 43 1.0E-1 +/- 1.gE-2 EW: 1.2E-1 +/- 1.9E-2 1.2E-1 +/- 1.9E-2 0 6.3E 1.4E-1 1.0E 1.4E-1 1.0E 1.4E-1 40/40 4/4 4/4 K-40 43 <LLD 5.9E-2 +/- 1.3E-2 5.9E-2 +/- 1.3E-2 0 <LLD <LLD - 5.gE-2 <LLD - 5.9E-2 0/40 1/4 1/4 Cs-134 43 0.05 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/40 0/4 Cs-137 43 0.06 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/40 0/40 0/4 Ra-226 43 <LLD <LLD <LLD 0 <LLD <LLD <LLD 1 0/40 0/40 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 2013)

MEDIUM: Charcoal Cartridae (CF) UNITS: DCi/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 1-131 563 0.07 <LLD <LLD <LLD 0 <LLD <LLD <LLD 1 0/511 0/52 0/52

• 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 2013)

No milk sampling was performed during 2013, as no suitable indicator locations for milk production 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 - December 2013)

No forage sampling was performed during 2013, as no grazing animals used for food products were available at any indicator locations within 5 miles of Pilgrim Station.

Page 44

Table 2.9-1 Vegetable/Vegetation Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2013)

I*Ar-pll IIA- X/-lf~fir-" C-r- "Kirre -  ; 11 IVIVI.

UIU V

• L L "I j I '., h!

J - liW Q,,lll W.: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 23 1.5E+3 +/- 8.9E+2 DMF: 3.5E+3 +/- 1.3E+2 2.OE+3 +/- 1.5E+3 0 <LLD - 2.8E+3 3.5E+3 - 3.5E+3 <LLD - 3.5E+3 10/15 1/1 3/8 K-40 23 3.2E+3 +/- 8.7E+2 Norton: 7.7E+3 +/- 2.5E+2 3.7E+3 +/- 2.2E+3 0 2.1E+3 - 5.3E+3 7.7E+3 - 7.7E+3 1.OE+3 - 7.7E+3 15/15 1/1 8/8 1-131 23 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/15 0/15 0/8 Cs-134 23 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/15 0/15 0/8 Cs-137 23 80 3.7E+1 +/- 1.9E+1 Pine Hills: 6.1E+1 +/- 7.1E+0 9.2E+0 +/- 4.1E+0 0 <LLD - 6.1E+1 6.1E+1 - 6.1E+1 <LLD - 9.2E+0 4/15 1/1 1/8 Ra-226 23 4.8E+2 +/- 3.6E+2 Ply Cnty: 7.4E+2 +/- 1.3E+2 4.OE+2 +/- 2.OE+2 0 <LLD - 7.4E+2 <LLD - 7.4E+2 <LLD - 5.7E+2 2/15 1/4 4/8 AcTh-228 23 2.5E+2 +/- 2.6E+2 Greenwood: 6.4E+2 +/- 3.OE+1 1.IE+2 +/- 6.4E+1 0 <LLD - 6.4E+2 6.4E+2 - 6.4E+2 <LLD - 1.7E+2 4/15 1/1 3/8

• 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 2013)

RA~rnllIKA. Pr' k r;* PD I K -1I0t /* 1 . .

IVraInVI errlU*II e L'*s D , Jl myL pc* I~Iwe, 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 2.7E+2 +/- 4.8E+1 BvdamRd: 2.7E+2 +/- 4.8E+1 <LLD 0 2.7E+2 - 2.7E+2 2.7E+2 - 2.7E+2 <LLD 1/1 1/1 0/1 K-40 2 8.4E+2 +/- 9.2E+1 HollowBog: 9.7E+2 +/- 8.5E+1 9.7E+2 +/- 8.5E+1 0 8.4E+2 - 8.4E+2 9.7E+2 - 9.7E+2 9.7E+2 - 9.7E+2 1/1 1/1 1/1 1-131 2 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 0/1 Cs-134 2 60 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 0/1 Cs-137 2 80 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 0/1 Ra-226 2 2.3E+2 +/- 1.OE+2 HollowBog: 3.5E+2 1.2E+2 3.5E+2 +/- 1.2E+2 0 2.3E+2 - 2.3E+2 3.5E+2 - 3.5E+2 3.5E+2 - 3.5E+2

_____ ____1/1 1/1 1/1 AcTh-228 2 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/1 0/1 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 2013)

MEDIUM: Surface Water MWS) UNITS: oCi/ke Radionuclide No. Analyses Required Indicator Stations Station with Highest Mean Control Stations H-3 12 3000 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 #N/A 0/4 Be-7 36 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/24 0/12 0/12 K-40 36 2.8E+2 +/- 1.5E+2 PP: 3.9E+2 +/- 8.3E+1 3.9E+2 +/- 8.3E+1 0 <LLD - 5.8E+2 3.OE+2 - 5.2E+2 3.0E+2 - 5.2E+2 20/24 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 9.2E+1 1 2.7E+1 PP: 9.8E+1 +/- 2.9E+1 9.8E+1 +/- 2.9E+1 0 <LLD - 1.5E+2 <LLD - 1.5E+2 <LLD - 1.5E+2 18/24 9/12 9/12 AcTh-228 36 8.2E+0 +/- 2.2E+0 DIS: 8.7E+0 +/- 2.6E+0 8.4E+0 +/- 3.1E+0 0 <LLD- 1.2E+1 <LLD- 1.2E+1 <LLD - 1.4E+1 8/24 5/12 9/12 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 Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2013)

RA=r'%l "KA Qý; 0 = " KIITo. .- fWL6 A..

Im IVI[,- OlJll:lL eVI l -I -. l l I '* Lt - II l yJ 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 4.4E+2 +/- 1.1E+2 Manmt Pt: 4.4E+2 +/- 1.1E+2 <LLD 0 <LLD - 4.4E+2 <LLD - 4.4E+2 <LLD 1/8 1/2 0/4 K-40 12 9.4E+3 +/- 1.5E+3 Gm Hrbr: 1.1E+4 +/- 5.OE+3 1.1E+4 +/- 3.OE+3 0 6.8E+3- 1.2E+4 7.5E+3- 1.5E+4 7.5E+3 - 1.5E+4 8/8 2/2 4/4 Cs-134 12 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Cs-137 12 180 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Ra-226 12 5.5E+2 +/- 3.6E+2 Manmt Pt: 8.7E+2 +/- 2.6E+2 5.1E+2 +/- 4.1E+2 0 <LLD - 9.8E+2 <LLD - 8.7E+2 <LLD - 9.6E+2 6/8 1/2 3/4 AcTh-228 12 4.1E+2 +/- 1.2E+2 Ply Hbr: 5.2E+2 +/- 1.1E+2 3.9E+2 +/- 1.3E+2 0 <LLD - 5.9E+2 4.5E+2 - 5.9E+2 2.5E+2 - 5.4E+2 I 1 5/8 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 2013)

MEDIUM: Irsh Moss (AL) 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 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 K-40 8 6.OE+3 +/- 1.5E+3 Ellisville: 7.4E+3 +/- 1.8E+3 5.4E+3 +/- 1.9E+3 0 4.2E+3 - 8.7E+3 6.2E+3 - 8.7E+3 4.1E+3 - 6.8E+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 0/2 Cs-137 8 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/2 0/2 Ra-226 8 4.2E+2 +/- 1.4E+2 Ellisville: 4.5E+2 + 1.6E+2 3.3E+2 +/- 1.4E+2 0 <LLD - 4.5E+2 <LLD - 4.5E+2 <LLD - 3.3E+2 2/6 1/2 1/2 AcTh-228 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD I _0/6 0/2 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 2013) hK4nII IA" Ch,-lif.~ K Q C I KIIT*, U~"*llI*A

. k I  : 61- a XLES 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 10 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/6 0/4 0/4 K-40 10 2.3E+3+/-9.9E+2 PlyHrbr:2.5E+3+/-1.1E+3 1.6E+3+/- 1.7E+3 0 1.2E+3 - 3.8E+3 1.5E+3 - 3.8E+3 1.3E+2 - 3.2E+3 6/6 4/4 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 5.9E+2 +/- 2.8E+2 Gm Hrbr: 7.3E+2 +/-3.OE+2 7.3E+2 +/- 3.OE+2 0 <LLD - 5.9E+2 <LLD - 7.3E+2 <LLD - 7.3E+2 1/6 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 Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2013)

MEDIfHIiFrA: I IW-IA I IMITC- U.-'jI/,,

LI L i~~l~~l~l~~l,1

• L I I

• I* . M1e1

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

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 5 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 K-40 5 2.8E+3+/- 5.4E+2 DIS: 2.8E+3+/- 5.4E+2 1.7E+3+/- 2.4E+2 0 2.1E+3 - 3.4E+3 2.1E+3 - 3.4E+3 1.7E+3 - 1.7E+3 4/4 4/4 1/1 Mn-54 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Fe-59 5 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Co-58 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Co-60 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Zn-65 5 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Cs-134 5 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Cs-137 5 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/4 0/4 0/1 Ra-226 5 6.7E+2 +/- 2.3E+2 DIS: 6.7E+2 +/- 2.3E+2 5.4E+2 +/- 3.OE+2 0 <LLD - 7.OE+2 <LLD - 7.OE+2 5.4E+2 - 5.4E+2 2/4 2/4 1/1 AcTh-228 5 <LLD <LLD <LLD 0 <LLD <LLD <LLD 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 2013)

RA~i[1 IIA- M ke CU'W 1 111170 rý fl, 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 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 K-40 8 4.8E+3 +/- 8.1E+2 DIS: 4.8E+3 +/- 8.1E+2 4.5E+3 +/- 5.2E+2 0 3.9E+3 - 5.7E+3 3.9E+3 - 5.7E+3 3.9E+3 - 4.9E+3 4/4 4/4 4/4 Mn-54 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Fe-59 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Co-58 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Co-60 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Zn-65 8 260 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Cs-134 8 130 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 014 Cs-137 8 150 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 0/4 Ra-226 8 1.3E+3+/- 5.7E+2 DIS: 1.3E+3+/- 5.7E+2 8.1E+2+/- 1.8E+2 0 <LLD - 1.7E+3 <LLD - 1.7E+3 <LLD - 8.8E+2 2/4 2/4 3/4 AcTh-228 8 <LLD <LLD <LLD 0 <LLD <LLD <LLD 0/5 0/5 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-2NDW 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 Pll 183 m ESE FENCE-TCF/BOAT RAMP P27 185 m ESE FENCE-ACCESS GATE P12 202 m SE FENCE-E SWITCHYARD P15 220 m S 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 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 krn SE SHOREFRONT PARKING PA 0.35 km NNW STATION A A 0.37 kmn WSW STATION F F 0.43 km NW STATION B B 0.44 krn 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 km SE J 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 MB 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 3TLDs7 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 Zone4TLDs >15km 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 kn 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 VEGETABLES/VEGETATION 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 kmT 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 SHELLFIS Norton Control NC 50 km W Discharge Canal Outfall DIS 0.7 kIn NNE Plymouth Harbor PLY-H 4.1 km W CRANBýRRIES 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 Samplinq Locations SYMBOL KEY SHELLFISH (M BLUE MUSSEL)

(S SOFT-SHELL)

(H HARD-SHELL)

Q IRISH MOSS LOBSTER FISHES U SURFACE WATER D SEDIMENT cZ CRANBERRY f VEGETATION 0 MILES 2 SCALE 31 KILOMETERS WSITIfMTR 34 EILOMETEBS WEST 32 KILOMETERS NORTHEAST 50 KILOM ETERS WES*

K5M E T EES EAST WHITEHORSE BEACH

'Ef 24 C-BAY SH 24KILOMETERS EAST-SOUTHEAST 48 KILOMETERS

,."w SOUTHWEST 40 KILOMET' S SOUTH-SOUTHWEST 45 KILOMETERS SOUTH-SOUTHEAST Page 62

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

ILD 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 AIRSAMPLEE 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 SYMBOL KEY (M BLUE MUSSEL)

(S SOFrT-SHLRL CLAM)

(H HARD-SHELL CLAM) o I-,u MoSs

[I LOBSTMR

<cX FL~S MAS5ACHUS=-T5 BAY

\7 SUR*FACE WATE*

] SEDIMENT (3 CRANBERRY VEGETATIONIFORAGE C AIR SAMPLER II © TLD 0 MILES 10 SCALE CAPE CODBAY

<ZBAY Page 64

Airborne Gross-Beta Radioactivity Levels Near-Station Monitors (D

E 0.

.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2013

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

- AP-08 Overlook Area -V-- AP-09 East Breakwater U 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 E

C.2 (D

a) 0 0

CL Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2013 AP-01 E. Rocky Hill Road -- AP-03 W. Rocky Hill Road

- AP-06 Property Line -u-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.OE-02 4.OE-02 S3.OE-02 E

4.)

A.)

.0 2.OE-02 1.OE-02 O.OE+00 .

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2013

- AP-10 Cleft Rock w AP-15 Plymouth Center

- - AP-17 Manomet Substation -x- AP-21 East Weymouth Control 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 2013 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;

• external 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, 2013 (Reference 17).

Page 68

Table 3.0-1 Radiation Doses from 2013 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway - mrem/yr Gaseous Liquid Ambient Receptor Effluents* Effluents Radiation** Total Total Body 0.032 0.0027 0.43 0.47 Thyroid 0.037 0.00027 0.43 0.47 Max. Organ 0.066 0.0021 0.43 0.50

• 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 sources of radiation. Such radiation doses are summarized in Table 1.2-1. The typical American receives about 620 mrem/yr from such sources.

As can be seen from the doses resulting from Pilgrim Station Operations during 2013, 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) ICNFTracerlab, "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, "Annual Radioactive Effluent Release Report", May 2013.

Page 70

APPENDIX A SPECIAL STUDIES There were no environmental samples collected during 2013 that contained plant-related radioactivity.

Therefore, no special studies were required to estimate dose from plant-related activity.

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 Annual Radioactive Effluent Release Report Supplemental Information January-December 2013 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 (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 i.tCi/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

_ 2013 2013 2013 2013 2013

a. Liquid Effluents

1. Total number of releases: 5.OOE+00 1.20E+01 N/A 4.OOE+00 2.10E+01

2. Total time period (minutes): 6.29E+02 1.18E+03 N/A 2.36E+03 4.16E+03

3. Maximum time period 1.70E+02 1.22E+02 N/A 6.35E+02 6.35E+02 (minutes):

4. Average time period (minutes): 1.26E+02 9.81E+01 N/A 5.89E+02 2.71E+02

5. Minimum time period (minutes): 9.90E+01 7.50E+01 N/A 5.20E+02 7.50E+01

6. Average stream flow during efflueintperiods of release of peintosa lowingest1.20E+06 9.39E+05 N/A 1.17E+06 effluents into a flowing stream 1.11E+06 (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 Annual Radioactive Effluent Release Report Gaseous Effluents - Summation of All Releases January-December 2013 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2013 2013 2013 2013 2013 Error A. FISSION AND ACTIVATION GASES Total Release: Ci 0.00E+00 0.OOE+00 2.91 E-01 O.OOE+00 2.91E-01 Average Release Rate: i.tCi/sec 0.00E+00 0.00E+00 3.69E-02 0.00E+00 9.23E-03 +/-+22%

Percent of Effluent Control Limit*... E B. IODINE-131 Total Iodine-131 Release: Ci J 1.84E-04 9.29E-05 5.91E-05 1.71E-04 5.08E-04 Average Release Rate: .Ci/sec 2.34E-05 1.18E-05 7.50E-06 2.17E-05 1.61E-05 +/-20%

Percent of Effluent Control Limit*. ....

C. PARTICULATES WITH HALF-LIVES > 8 DAYS Total Release: Ci 2.78E-04 1.72E-04 5.50E-05 1.62E-04 6.67E-04 Average Release Rate: l.LCi/sec 3.53E-05 2.18E-05 6.97E-06 2.05E-05 2.12E-05 Percent of Effluent Control Limit*......

Gross Alpha Radioactivity: Ci NDA NDA NDA NDA NDA D. TRITIUM Total Release: Ci 6.24E+00 6.44E+00 2.34E+01 2.79E+01 6.40E+01 Average Release Rate: iiCi/sec 7.91 E-01 8.17E-01 2.97E+00 3.53E+00 2.03E+00 +/-20%

Percent of Effluent Control Limit*. ....

E. CARBON-14 Total Release: Ci 1.51E+00 9.73E-01 1.90E+00 1.87E+00 6.26E+00 Average Release Rate: ptCi/sec 1.91 E-01 1.23E-01 2.41 E-01 2.38E-01 1.98E-01 N/A Percent of Effluent Control Limit*. ....

Notes for Table B.2-A:

• Percent of Effluent Control Limit values based on dose assessments are provided in Section 6 of this report.

1. NDA stands for No Detectable Activity.

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

3. N/A stands for not applicable.

Page 74

Table B.2-B Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2013 CONTINUOUS MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released I Jan-Mar 2013 Apr-Jun2013 Jul-Sep2013 Oct-Dec2013 Jan-Dec2013

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 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Kr-85m 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Kr-87 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Kr-88 0.OOE+00 0.OOE+00 0.00E+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 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-133m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-135 0.OOE+00 0.OOE+00 2.91 E-01 0.OOE+00 2.91 E-01 Xe-135m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-137 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-1 38 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Total for Period 0.OOE+00 0.OOE+00 2.91 E-01 0.OOE+00 2.91E-01

2. IODINES: Ci 1-131 1.24E-05 1.52E-06 4.34E-06 3.90E-06 2.21 E-05 1-133 1.14E-05 0.OOE+00 0.OOE+00 0.OOE+00 1.14E-05 Total for Period 2.38E-05 1.52E-06 4.34E-06 3.90E-06 3.35E-05

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 Mn-54 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 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 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 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 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 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Ba/La-140 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Total for Period 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00

4. TRITIUM: Ci H-3 1.53E-02 2.97E-02 5.30E-02 3.77E-02 1.36E-01

5. CARBON-14: Ci C-14 1.46E+00 9.43E-01 1.85E+00 1.82E+00 6.07E+00 Notes for Table B.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 p.Ci/cc Particulates: 1E-1i1 iCi/cc Page 75

Table B.2-B (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2013 BATCH MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released I Jan-Mar 2013 Apr-Jun 2013 Jul-Sep2013 I Oct-Dec 2013 Jan-Dec 2013

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- 133 N/A N/A N/A N/A N/A Xe-133m N/A N/A N/A N/A N/A Xe- 135 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A N/A N/A Xe-137 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 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-1 03 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

5. CARBON-14: Ci C-14 N/A N/A N/A N/A N/A Notes for Table B.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 lICi/cc lodines: 1 E-12 iLCi/cc Particulates: 1 E-1 1 jiCi/cc Page 76

Table B.2-C Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2013 CONTINUOUS MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released I Jan-Mar2013 Apr-Jun2013 Jul-Sep2013 Oct-Dec2013 Jan-Dec2013

1. FISSION AND ACTIVATION GASES: Ci Ar-41 0.00E+00 O.OOE+00 0.00E+00 0.OOE+00 O.OOE+00 Kr-85 O.OOE+00 0.00E+00 O.OOE+00 O.OOE+00 0.00E+00 Kr-85m O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 0.00E+00 Kr-87 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 Kr-88 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 Xe-131m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-133 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 Xe-133m 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Xe-135 0.OOE+00 O.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 Xe-135m 0.OOE+00 0.OOE+00 0.00E+00 0.00E+00 0.OOE+00 Xe-137 0.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 O.OOE+00 Xe-138 O.OOE+00 O.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 Total for period O.OOE+00 O.OOE+00 o.OOE+00 O.OOE+00 0.OOE+00

2. IODINES: Ci 1-131 1.72E-04 9.14E-05 5.48E-05 1.68E-04 4.85E-04 1-133 6.23E-04 1.39E-04 1.80E-04 5.21 E-04 1.46E-03 Total for period 7.94E-04 2.30E-04 2.35E-04 6.89E-04 1.95E-03

3. PARTICULATES WITH HALF-LIVES > 8 DAYS: Ci Cr-51 0.OOE+00 2.1OE-05 0.OOE+00 O.OOE+00 2.1OE-05 Mn-54 2.84E-06 1.56E-05 5.08E-06 1.42E-05 3.77E-05 Fe-59 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 Co-58 O.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 Co-60 0.OOE+00 6.34E-05 1.63E-05 2.74E-05 1.07E-04 Zn-65 0.OOE+00 1.73E-05 O.OOE+00 6.14E-06 2.34E-05 Sr-89 O.OOE+00 0.OOE+00 1.02E-05 1.96E-05 2.98E-05 Sr-90 0.OOE+00 O.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 Ru-103 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 Cs-134 0.OOE+00 O.OOE+00 0.OOE+00 O.OOE+00 O.OOE+00 Cs-137 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 Ba/La-140 2.75E-04 5.47E-05 2.34E-05 9.45E-05 4.48E-04 Total for period 2.78E-04 1.72E-04 5.50E-05 1.62E-04 6.67E-04

4. TRITIUM: Ci H-3 6.22E+00 6.41 E+00 2.34E+01 2.78E+01 6.38E+01

5. CARBON-14: Ci C-14 4.53E-02 2.92E-02 5.71E-02 5.62E-02 1.88E-01 Notes.for Table B.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 pCi/cc lodines: 1E-12 lICi/cc Particulates: 1E-1 1 liCi/cc Page 77

Table B.2-C (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2013 BATCH MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released I Jan-Mar 2013 Apr-Jun 2013 Jul-Sep 2013 Oct-Dec 2013 Jan-Dec 2013

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- 135 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A N/A N/A Xe-137 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 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-1 03 N/A N/A N/A N/A N/A Cs-1 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 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

5. CARBON-14: Ci C-14 N/A N/A N/A N/A N/A Notes for Table B.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: 1 E-04 piCi/cc lodines: 1 E-12 itCi/cc Particulates: 1 E-11 [tCi/cc Page 78

Table B.3-A Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents - Summation of All Releases January-December 2013 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2013 2013 2013 2013 1 2013 jError A. FISSION AND ACTIVATION PRODUCTS Total Release (not including 3.98E-06 1.89E-02 N/A 2.93E-05 1.89E-02 tritium, gases, alpha): Ci Average Diluted Concentration 2.73E-14 1.74E-10 N/A 1.89E-13 3.36E-11 +/-12%

During Period: lCi/mL Percent of Effluent Concentraion Eflimt 9.11 E-08% 2.47E-03% N/A 1.32E-05% 4.81 E-04%

Concentration Limit*

B. TRITIUM Total Release: Ci 8.10E-01 5.25E+00 N/A 1.57E-01 6.21E+00 Dunverag Average ioutd: Cioncentration___________

Diluted Concentration 5.57E-09 4.81E-08 N/A 1.01E-09 1.1OE-08 During Period: ýtCi/mL_ +/-9.4%

Concentraion Eflmt* 5.57E-04% 4.81 E-03% N/A 1.01 E-04% 1.1 OE-03%

Concentration Limit*

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

Percent of Effluent_

Pecn0fEfun __I_

.00E+00% 0.00E+00% N/A

_I _ _ __

0.00E+00% 0.00E+00%

Concentration Limit*

D. GROSS ALPHA RADIOACTIVITY Total Release: Ci NDA N/A N/A N/A NDA +/-34%

E. VOLUME OF WASTE RELEASED PRIOR TO DILUTION Waste Volume: Liters 2.11E+05 8.30E+05 N/A 1.37E+05 1.18E+06 I +/-5.7%

F. VOLUME OF DILUTION WATER USED DURING PERIOD Dilution Volume: Liters 1.46E+11 1.09E+11 I 1.55E+11 1.55E+11 5.65E+11 I +/-10%

Notes for Table B.3-A:

• Additional percent of Effluent Control Limit values based on dose assessments are provided in Section 6 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 ýLCi/mL.

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

Page 79

Table B.3-B Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents January-December 2013 CONTINUOUS MODE RELEASES Nuclide Released Jan-Mar 2013 Apr-Jun 2013 Jul-Sep 2013 Oct-Dec 2013 Jan-Dec 2013

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-1 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-1 33 N/A N/A N/A N/A N/A Xe-1 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 B.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 gCi/mL lodines: 1E-06 ZCi/mL Noble Gases: 1E-05 ýiCi/mL All Others: 5E-07 ItCi/mL Page 80

Table B.3-B (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents January-December 2013 BATCH MODE RELEASES Nuclide Released Jan-Mar 2013 Apr-Jun 2013 Jul-Sep 2013 Oct-Dec 2013 Jan-Dec 2013

1. FISSION AND ACTIVATION PRODUCTS: Ci Na-24 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Cr-51 0.00E+00 4.50E-03 N/A 0.OOE+00 4.50E-03 Mn-54 3.98E-06 3.73E-03 N/A 3.02E-06 3.74E-03 Fe-55 0.OOE+00 5.72E-04 N/A 0.00E+00 5.72E-04 Fe-59 0.OOE+00 1.11E-03 N/A 0.OOE+00 1.11E-03 Co-58 0.OOE+00 4.89E-04 N/A 0.OOE+00 4.89E-04 Co-60 0.OOE+00 5.73E-03 N/A 8.86E-06 5.74E-03 Zn-65 0.OOE+00 1.57E-03 N/A 0.OOE+00 1.57E-03 Zn-69m 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Sr-89 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Sr-90 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Zr/Nb-95 0.OOE+00 4.69E-05 N/A 0.OOE+00 4.69E-05 Mo/Tc-99 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Ag-110m 0.OOE+00 1.08E-03 N/A 0.00E+00 1.08E-03 Sb-124 0.OOE+00 9.60E-05 N/A 0.OOE+00 9.60E-05 1-131 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 1-133 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Cs-1 34 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Cs-137 0.OOE+00 0.OOE+00 N/A 1.74E-05 1.74E-05 Ba/La-140 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Ce-141 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Ce-144 0.OOE+00 0.OOE+00 N/A 0.OOE+00 0.OOE+00 Total for period 3.98E-06 1.89E-02 N/A 2.93E-05 1.89E-02

2. DISSOLVED AND ENTRAINED GASES: Ci Xe-1 33 NDA NDA N/A NDA NDA Xe-1 35 NDA NDA N/A NDA NDA Total for period NDA NDA N/A NDA NDA Notes for Table B.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 piCi/mL lodines: 1E-06 4.Ci/m L Noble Gases: 1E-05 4Ci/mL All Others: 5E-07 pCi/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 09 and September 20, 2013. 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 30 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 2013 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 Rocky Hill Road 1.8 km SSE Clay Hill Road 1.6 km W Additional samples of naturally-growing vegetation were collected at the site boundary in the ESE and SE sectors to monitor for atmospheric deposition in the vicinity of the nearest resident in the SE sector.

In addition to these special sampling locations identified and sampled in conjunction with the 2013 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), Sandwich (21 km SSE), 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. 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 Radioactive Effluent Release Report (Reference 17).

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APPENDIX D ENVIRONMENTAL MONITORING PROGRAM DISCREPANCIES There were a number of instances during 2013 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 adverse effect on the results or integrity of the monitoring program. Details of these various problems are given below.

During 2013, nine offsite thermoluminescent dosimeters (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: Emerson & Priscilla - EP (Qtr 1); Greenwood House - GH (Qtr 3); Warren & Clifford - WC (Qtr 3); Hall's Bog - HB (Qtr 4); Manomet Elementary -

ME (Qtr 4); and College Pond - CP (Qtr 4). In each of these cases, the plastic cage holding the TLD were replaced and a new TLD posted. The TLD at Hyannis Road - HR was vandalized during both the 1st and 2 nd quarters of 2013. The TLD at this location was relocated a short distance to be less conspicuous. Turing the 4 th Quarter exchange of TLDs in early January- 2014, the TLD at Valley Road - VR could not be retrieved due to snow-covered roads leading to this remote location. The TLD was recovered during the retrieval of 1t Quarter 2014 TLDs in April 2014, and will be analyzed to determine the average dose at that location during the two periods represented by that TLD.

Despite these losses, the 431 TLDs that were collected (98.0%) 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 2013. 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 airborne particulates and iodine-1 31 on 563 of the 563 filters/cartridges collected.

Out of 572 filters (11 locations

• 52 weeks), 563 samples were collected and analyzed during 2013.

A problem occurred at location WR when tree trimming activities on 14-Aug-2012 resulted in damage to the electrical service and sampling station. The sampler was not repaired until 28-Feb-2013, resulting in the loss of sampling capabilities at this location for the last 21 weeks of 2012, and the first eight weeks of 2013. This event is described in Condition Report CR-PNP-2012-3545.

There were also 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 required LLDs were achieved on these samples. Winter Storm Nemo resulted in wide-scale loss of power during the week of 05-Feb through 12-Feb-2103. Power interruptions of greater than 24-hours occurred from this storm at Property Line, Pedestrian Bridge, Cleft Rock, Manomet Substation, East Rocky Hill Road, East Breakwater; and Medical Building.

The configuration of air samplers that had been in use at Pilgrim Station since the early 1980s, was replaced between June and August of 2012. 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). Such problems can be encountered at air samplers located at the East Breakwater and Pedestrian Bridge. Both of these locations are immediately adjacent to the shoreline and are subject to significant wind-blown salt water, and are prone to tripping of the GFCI. The following table contains a listing of larger problems encountered with air sampling stations during 2013, 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.

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Location Sampling Period Sampling Problem Description Hours Lost WR 01/02 to 02/28 1375 of 1375 Sampling station damaged during tree trimming activities in Aug-2012; condition report CR-PNP-2012-3545; repaired 02/28/2013 PL 02/05 to 02/12 36.1 of 174.9 Power loss from Winter Storm Nemo PB 02/05 to 02/12 57.4 of 170.3 Power loss from Winter Storm Nemo CR 02/05 to 02/12 33.3 of 170.5 Power loss from Winter Storm Nemo MS 02/05 to 02/12 30.7 of 170.3 Power loss from Winter Storm Nemo ER 02/05 to 02/12 90.8 of 173.9 Power loss from Winter Storm Nemo EB 02/05 to 02/12 36.1 of 170.5 Power loss from Winter Storm Nemo WS 02/05 to 02/12 36.1 of 168.8 Power loss from Winter Storm Nemo OA 04/22 to 05/01 72.1 of 220 Load shed activity of power feed from Main Stack during refueling outage.

WS 06/11 to 06/17 139 of 139 Faulty circuit breaker feeding power to sampling station.

WR 6/25 to 07/09 None Filter left on for 2-week period due to inaccessibility at 0.0 of 336.5 location of sampler PB 10/14 to 10/21 39.3 of 156.3 Loss of offsite power caused GFCI outlet to trip PB 10/21 to 10/29 23.1 of 191.2 Trip of GFCI outlet PB 12/10 to 12/17 60.5 of 168.0 Trip of GFCI outlet CR 12/10 to 12/23 None Filter left on for 2-week period due to inaccessibility at 0.0 of 311.3 location of sampler PB 12/17 to 12/23 134.5 of 143.3 Pump experienced mechanical failure Despite the lower-than-normal sampling volumes in the various instances involving power interruptions and equipment failures, required LLDs were met on 563 of the 563 particulate filters, and 563 of the 563 of the iodine cartridges collected during 2013. When viewed collectively during the entire year of 2013, the following sampling recoveries were achieved in the airborne sampling program:

Location Recovery Location Recovery----

Location Loato - --

Recovery Loato -Re WS 98.7% PB 96.1% PC 99.9%

ER 98.9% OA 98.0% MS 99.6%

WR 84.2% EB 99.6% EW 99.9%

PL 99.5% CR 99.5%

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. Additional samples of naturally-occurring vegetation were collected from distant control locations in Sandwich and Norton. As expected for control samples, vegetables and vegetation collected at these locations only contained naturally-occurring radioactivity (Be-7, K-40, and Ac/Th-228).

Some problems were encountered in collection of crop samples during 2013. Crops which had normally been sampled in the past (lettuce, tomatoes, potatoes, and onions) were not grown at the Plymouth County Farm (CF) during 2013. Leafy material from pumpkin plants and corn plants were substituted for the lettuce to analyze for surface deposition of radioactivity on edible plants.

Samples of squash, tomatoes, cucumbers, zucchini, and grape leaves were also collected from two other locations in the immediate vicinity of Pilgrim Station. No radionuclides attributed to PNPS operations were detected in any of the samples.

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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.

As presented in Table 2.9-1, several samples of naturally-occurring vegetation (leaves from trees, bushes, and herbaceous plants) were collected at a number of locations where the highest atmospheric deposition would be predicted to occur. Some of these samples indicated Cs-137 at concentrations ranging from non-detectable up to 61 pCi/kg. The highest concentration of 61 pCi/kg was detected in a sample of natural vegetation collected from the Pine Hills area of the Pine Hills south of PNPS. This Cs-137 result is within of the normal range of average values expected for weapons-testing fallout (75 to 145 pCi/kg as projected from the pre-operational sampling program).

It should be noted that natural vegetation samples collected in the 1990s often showed detectable Cs-137 from nuclear weapons tests up into the range of 300 to 400 pCi/kg, whereas soil samples often indicated concentrations in excess of 2000 pCi/kg. Cs-137 has a 30-year half-life, and measureable concentrations still remain in soil and vegetation as a result of atmospheric nuclear weapons testing performed during the 1950s through 1970s. A review of effluent data presented in Appendix B indicates that there were no measurable airborne releases of Cs-137 from Pilgrim Station during 2013 that could have attributed to these detectable levels. The sample with the highest level of Cs-137 also contained high levels of Ra-226 and AcTh-228, indicating appreciable soil content on the vegetation. This sample of natural vegetation was analyzed "as is" without any measure to clean the samples as normally would be performed prior to consuming vegetables, and would have detected any Cs-1 37 in soil adhering to those leaves collected. Certain species of plants such as sassafras are also known to concentrate chemical elements like cesium, and this higher-than-expected level is likely due to a combination of external soil contamination and bioconcentration in the leaves of the plants sampled. These levels are not believed to be indicative of any releases associated with Pilgrim Station. No radioactivity attributable to Pilgrim Station was detected in any of the vegetable samples collected during 2013, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

The cranberry bog at Pine Street Bog in Halifax was not in production during 2013, 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 addition, the cranberry bog along Bartlett Road suspended operation during 2013, and was not producing cranberries. Samples were collected from a single indicator location located along Beaverdam Road.

During the week of 05-Feb through 12-Feb-2013, water samples could not be collected from the sampling locations at the Pedestrian Bridge and Bartlett Pond. Both areas were inaccessible due to damage from Winter Storm Nemo.

Additional problems were encountered with composite water samples collected from the Discharge Canal during the weeks of 12-Feb to 19-Feb-2013, and 16-Apr to 22-Apr-2013 when the lift pump suspended in the Discharge Canal failed and water was not provided to the composite sampler.

Grab samples were obtained at the time of filter collection to substitute for the normal composite samples that would have been collected during the week. No radioactive liquid discharges were occurring during either of these two periods.

Failure of the peristaltic tubing in the composite sampler also occurred during the weeks of 18-Mar to 25-Mar, and 01-May to 07-May-2013, and grab samples were also substituted for the composite samples. One radioactive liquid discharge of 9686 gallons containing 0.086 Curies of tritium occurred during the week of 18-Mar to 25-Mar, but the dilution in the discharge canal would have resulted in a tritium concentration of about 7.3 pCi/L, which is well below the detection sensitivity for tritium in REMP samples. No tritium was detected in the quarterly composite for the second quarter of 2013. No radioactive liquid discharges occurred during the period covered by the composite sample for the week of 01-Mat to 07-May.

Page 85

Group I fishes, consisting of winter flounder or yellow-tail flounder are normally collected twice each year in the spring and in the autumn from the vicinity of the Discharge Canal Outfall. When fish sampling occurred in the September to November collection period, no samples of Group I fish could be collected, as the species had already moved to deeper water for the upcoming winter. Repeated and concerted efforts were made to collect these species, but failed to produce any samples.

In summary, the various problems encountered in collecting and analyzing environmental samples during 2013 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 resulted in an adverse impact on the overall monitoring program.

Page 86

APPENDIX E ENVIRONMENTAL DOSIMETRY COMPANY Annual Quality Assurrance Status Report January - December 2013

ENVIRONMENTAL DOSIMETRY COMPANY ANNUAL QUALITY ASSURANCE STATUS REPORT January - December 2013 Prepared By: Date: z?

A

/

Approved By: Date: -- A24{+/-L..

Environmental Dosimetry Company 10 Ashton Lane Sterling, MA 01564

TABLE OF CONTENTS Page LIST O F TABLES ....................................................................................................................... iii EXECUTIVE

SUMMARY

.................................................................................................... iv I. INTRODUCTION ............................................................................................................ 1 A. QC Program .................................................................................................. 1 B. QA Program .................................................................................................. 1 II. PERFORMANCE EVALUATION CRITERIA ............................................................... 1 A. Acceptance Criteria for Internal Evaluations ..................................................... 1 B. QC Investigation Criteria and Result Reporting .............................................. 3 C. Reporting of Environmental Dosimetry Results to EDC Customers .................. 3 Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2013 ............. 3 A. General Discussion ......................................................................................... 3 B. Result Trending .............................................................................................. 4 IV. STATUS O F EDC CONDITION REPO RTS (CR) ...................................................... 4 V, STATUS OF AUDITS/ASSESSM ENTS ..................................................................... 4 A. Inte rn a l................................................................................................................ 4 B. External ........................................................................................................ 4 VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2013... 4 VII. CONCLUSION AND RECOM MENDATIONS ............................................................ 4 VIII. REFERENCES ............................................................................................................... 4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS

-ii-

LIST OF TABLES Paqe

1. Percentage of Individual Analyses Which Passed EDC Internal Criteria, January - December 2013 5

2. Mean Dosimeter Analyses (n=6), January - December 2013 5

3. Summary of Independent QC Results for 2013 5

-iii-

EXECUTIVE

SUMMARY

Routine quality control (QC) testing was performed for dosimeters issued by the Environmental Dosimetry Company (EDC).

During this annual period, 100% (72/72) of the individual dosimeters, evaluated against the EDC internal performance acceptance criteria (high-energy photons only), met the criterion for accuracy and 100% (72/72) met the criterion for precision (Table 1). In addition, 100% (12/12) of the dosimeter sets evaluated against the internal tolerance limits met EDC acceptance criteria (Table 2) and 100% (6/6) of independent testing passed the performance criteria (Table 3). Trending graphs, which evaluate performance statistic for high-energy photon irradiations and co-located stations are given in Appendix A.

One internal assessment was performed in 2013. There were no findings.

-iv-

1. INTRODUCTION The TLD systems at the Environmental Dosimetry Company (EDC) are calibrated and operated to ensure consistent and accurate evaluation of TLDs. The quality of the dosimetric results reported to EDC clients is ensured by in-house performance testing and independent performance testing by EDC clients, and both internal and client directed program assessments.

The purpose of the dosimetry quality assurance program is to provide performance documentation of the routine processing of EDC dosimeters. Performance testing provides a statistical measure of the bias and precision of dosimetry processing against a reliable standard, which in turn points out any trends or performance changes. Two programs are used:

A. QC Program Dosimetry quality control tests are performed on EDC Panasonic 814 Environmental dosimeters. These tests include: (1) the in-house testing program coordinated by the EDC QA Officer and (2) independent test perform by EDC clients. In-house test are performed using six pairs of 814 dosimeters, a pair is reported as an individual result and six pairs are reported as the mean result.

Results of these tests are described in this report.

Excluded from this report are instrumentation checks. Although instrumentation checks represent an important aspect of the quality assurance program, they are not included as process checks in this report. Instrumentation checks represent between 5-10% of the TLDs processed.

B. QA Program An internal assessment of dosimetry activities is conducted annually by the Quality Assurance Officer (Reference 1). The purpose of the assessment is to review procedures, results, materials or components to identify opportunities to improve or enhance processes and/or services.

I1. PERFORMANCE EVALUATION CRITERIA A. Acceptance Criteria for Internal Evaluations

1. Bias For each dosimeter tested, the measure of bias is the percent deviation of the reported result relative to the delivered exposure. The percent deviation relative to the delivered exposure is calculated as follows:

H.' - H.

'-100 Hi where:

H' the corresponding reported exposure for the im dosimeter (i.e., the reported exposure)

H= the exposure delivered to the ith irradiated dosimeter (i.e., the delivered exposure) 1 of 6

2. Mean Bias For each group of test dosimeters, the mean bias is the average percent deviation of the reported result relative to the delivered exposure. The mean percent deviation relative to the delivered exposure is calculated as follows:

H'H1-1 100 where:

H; = the corresponding reported exposure for the ith dosimeter (i.e., the reported exposure)

Hi = the exposure delivered to the ith irradiated test dosimeter (i.e., the delivered exposure) n = the number of dosimeters in the test group

3. Precision For a group of test dosimeters irradiated to a given exposure, the measure of precision is the percent deviation of individual results relative to the mean reported exposure. At least two values are required for the determination of precision. The measure of precision for the ith dosimeter is:

100 where:

HI' =the reported exposure for the ith dosimeter (i.e., the reported exposure)

H = the mean reported exposure; i.e., H = i n = the number of dosimeters in the test group

4. EDC Internal Tolerance Limits All evaluation criteria are taken from the "EDC Quality System Manual,"

(Reference 2). These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs-1 37) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +

12.8% for precision.

2 of 6

B. QC Investigation Criteria and Result Reporting EDC Quality System Manual (Reference 2) specifies when an investigation is required due to a QC analysis that has failed the EDC bias criteria. The criteria are as follows:

1. No investigation is necessary when an individual QC result falls outside the QC performance criteria for accuracy.

2. Investigations are initiated when the mean of a QC processing batch is outside the performance criterion for bias.

C. Reporting of Environmental Dosimetry Results to EDC Customers

1. All results are to be reported in a timely fashion.

2. If the QA Officer determines that an investigation is required for a process, the results shall be issued as normal. If the QC results, prompting the investigation, have a mean bias from the known of greater than +/-20%, the results shall be issued with a note indicating that they may be updated in the future, pending resolution of a QA issue.

3. Environmental dosimetry results do not require updating if the investigation has shown that the mean bias between the original results and the corrected results, based on applicable correction factors from the investigation, does not exceed +/-20%.

Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2013 A. General Discussion Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4.

Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period, 100% (72/72) of the individual dosimeters, evaluated against these criteria met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision.

A graphical interpretation is provided in Figures 1 and 2.

Table 2 provides the Bias + Standard deviation results for each group (N=6) of dosimeters evaluated against the internal tolerance criteria. Overall,100%

(12/12) of the dosimeter sets evaluated against the internal tolerance performance criteria met these criteria. A graphical interpretation is provided in Figures 3 Table 3 presents the independent blind spike results for dosimeters processed during this annual period. All results passed the performance acceptance criterion. Figure 4 is a graphical interpretation of Seabrook Station blind co-located station results.

3 of 6

B. Result Trending One of the main benefits of performing quality control tests on a routine basis is to identify trends or performance changes. The results of the Panasonic environmental dosimeter performance tests are presented in Appendix A. The results are evaluated against each of the performance criteria listed in Section II, namely: individual dosimeter accuracy, individual dosimeter precision, and mean bias.

All of the results presented in Appendix A are plotted sequentially by processing date.

IV. STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period.

V. STATUS OF AUDITS/ASSESSMENTS A. Internal EDC Internal Quality Assurance Assessment was conducted during the fourth quarter 2013. There were not any findings as a result of this assessment.

B. External No external assessments were conducted in 2013.

VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2013 No procedures or manuals were revised in 2013.

VII. CONCLUSION AND RECOMMENDATIONS The quality control evaluations continue to indicate the dosimetry processing programs at the EDC satisfy the criteria specified in the Quality System Manual. The EDC demonstrated the ability to meet all applicable acceptance criteria.

VIII. REFERENCES

1. EDC Quality Control and Audit Assessment Schedule, 2013.

2. EDC Manual 1, Quality System Manual, Rev. 3, August 1, 2012.

4 of 6

TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY- DECEMBER 2013(1)' (2)

DNumber%  % Passed Precision Dosimeter Type Tested %PassedBiasCriteria Criteria Panasonic Environmental 72 100 100 (1)This table summarizes results of tests conducted by EDC.

(2)Environmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES (N=6)

JANUARY- DECEMBER 2013(1)' (2)

Standard Tolerance Process Date Mean Bias % Deviation % Limit +1-15%

4/22/2013 4.1 1.9 Pass 4/24/2013 4.5 1.2 Pass 5/23/2013 -1.1 1.9 Pass 7/24/2013 0.8 1.0 Pass 8/4/2013 -1.1 1.6 Pass 8/6/2013 0.1 2.3 Pass 10/31/2013 1.5 1.2 Pass 11/10/2013 0.1 1.7 Pass 11/15/2013 -1.8 1.0 Pass 1/27/2014 3.7 2.3 Pass 1/31/2014 2.6 0.9 Pass 2/5/2014 0.7 0.6 Pass (1-This table summarizes results of tests conducted by EDC for TLDs issued in 2013.

(2)Environmental dosimeter results are free in air.

TABLE 3

SUMMARY

OF INDEPENDENT DOSIMETER TESTING JANUARY - DECEMBER 2013(')' (2)

Standard Pass I Fail Issuance Period Client Mean Bias% Deviation %

2nd Qtr.2013 Millstone 0.7 1.5 Pass 27_Qtr.2013 Seabrook -2.3 2.7 Pass 3r' Qtr. 2013 Millstone -4.7 4.0 Pass 4t' Qtr.2013 Seabrook -0.9 0.9 Pass (1)Performance criteria are +/- 30%.

(2)Blind spike irradiations using Cs-137 5 of 6

APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2013 6 of 6

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APPENDIX F J.A. Fitzpatrick Interlaboratory Comparison Program January - December 2013

8.0 QUALITY ASSURANCE / QUALITY CONTROL PROGRAM 8.1 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 James A.

FitzPatrick Nuclear Power Plant (JAF) Environmental Laboratory has engaged the services of Eckert

& Ziegler Analytics, Incorporated in Atlanta, Georgia.

Eckert & Ziegler 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. Eckert &

Ziegler Analytics issues a statistical summary report of the results. The JAF Environmental Laboratory uses predetermined acceptance 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.

8-1

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 36 of 58 FIGURE 1 COBALT-60 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Cobalt-60 Performance Evaluation Results and % Bias .... Co-60 100.0 SLower Control Limit 75.0 Upper Control Lim it 50.0 25.0 0.0

-25.0

-50.0

-75.0

-100.0 January 2013 - December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 37 of 58 FIGURE 2 CESIUM-1 37 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Cesium-137 Performance Evaluation Results and % Bias 100.0 75.0 50.0 Cs-1 37 25.0 CD

---

Lower Control 0.0 Limit 0' - - Upper Control

-25.0 Limit

-50.0

-75.0

-100.0 January 2013- December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 38 of 58 FIGURE 3 TRITIUM PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Tritium Performance Evaluation Results and % Bias 100.0 75.0 50.0 S--

H-3 25.0

-R ---- Lower Control 0.0 Limit Upper Control

-25.0 Lim it

-50.0

-75.0

-100.0 January 2013 - December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 39 of 58 FIGURE 4 STRONTIUM-90 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Strontium-90 Performance Evaluation Results and % Bias 100.0 50.0

- Strontium-90 In ---- Lower Control 0.0 Limit

---

Upper Control Limit

-50.0

-100.0 January 2013 - December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 40 of 58 FIGURE 5 GROSS ALPHA PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Gross Alpha Performance Evaluation Results and % Bias 100.0 50.0 Gross Alpha Co Cu .....- Lower Control 0.0 Limit

- - - - Upper Control Limit

-50.0

-100.0 January 2013 - December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 41 of 58 FIGURE 6 GROSS BETA PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Gross Beta Performance Evaluation Results and % Bias 100.0 50.0

- Gross Beta IA

---

Lower Control 0.0 Limit

- --- Upper Control Limit

-50.0

-100.0 January 2013 -December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 42 of 58 FIGURE 7 IODINE-131 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Iodine-131 Performance Evaluation Results and % Bias 100.0 75.0 50.0 Iodine-131 25.0 In w5 0.0

... .Lower Control Limit

---

Upper Control

-25.0 Lim it

-50.0

-75.0

-100.0 January 2013 - December 2013

I Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 43 of 58 FIGURE 8 AMERICIUM-241 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Americium-241 Performance Evaluation Results and % Bias 100.0 75.0 50.0

-.- Am-241 25.0 w

- - -- Lower Control 0,0 Lim it

- - - Upper Control

-25.0 Lim it

-50.0

-75.0

.100.0 January 2013 - December 2013

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 44 of 58 FIGURE 9 PLUTONIUM-238 PERFORMANCE EVALUATION RESULTS AND % BIAS 2013 Plutonium-238 Performance Evaluation Results and %Bias 100.0 75.0 50.0 Plutonium-238 25.0 (I -- - - Lower Control 0.0 Limit

-25.0 Upper Control Limit

-50,0

-750

-1000 January 2013 - December 2013

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 45 of 58 TABLE 6 REMP INTRA-LABORATORY DATA

SUMMARY

BIAS AND PRECISION BY MATRIX Bias Criteria Precision Criteria REMP 2013 (+ / -25%/) (Note1 WITHIN OUTSIDE WITHIN OUTSIDE CRITERIA CRITERIA CRITERIA CRITERIA MILK Gamma Iodine-131 41 0 131 0 Gas Flow Sr 2nd count 46 0 49 0 Gas Flow Total Strontium 35 0 35 0 Gamma Spec Liquid RAD A-013 with Ba, La 61 0 120 0 SOLID LSC Iron-55 5 0 5 0 Gamma Spec Solid RAD A-013 28 0 31 0 LSC Nickel 63 5 0 5 0 Gas Flow Sr 2nd count 4 0 4 0 Gas Flow Total Strontium 8 0 8 0 Gamma Spec Solid RAD A-013 with Ba, La 7 0 10 0 Gamma Spec Solid RAD A-013 with Iodine 6 0 7 0 FILTER Gamma Spec Filter RAD A-013 4 0 4 0 Gas Flow Sr 2nd Count 5 0 5 0 Alpha Spec Am241Curium 3 0 3 0 Gas Flow Total Strontium 3 0 3 0 Gross A & B 526 0 527 0 Gamma Spec Filter 45 0 51 0 LIQUID Alpha Spec Uranium 8 0 9 0 Tritium 336 0 337 0 Plutonium 1 0 1 0 LSC Iron-55 40 0 42 0 LSC Nickel 63 41 0 43 0 Gamma Spec Liquid RAD A-013 7 0 7 0 Gamma Iodine-131 33 0 33 0 Alpha Spec Plutonium 10 0 10 0 Gas Flow Sr 2nd count 20 0 20 0 Alpha Spec Am241 Curium 17 0 17 0 Gas Flow Total Strontium 161 0 163 0 Gross Alpha Non Vol Beta 102 0 104 0 Gamma Spec Liquid RAD A-013 with Ba, La 129 0 209 0 Gamma Spec Liquid RAD A-013 with Iodine 56 0 85 0 TISSUE

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 46 of 58 Gamma SDec Solid RAD A-013 45 0 48 0 LSC Nickel 63 2 0 2 0 Gas Flow Sr 2nd count 10 0 10 0 Gas Flow Total Strontium 17 0 17 0 Gamma Spec Solid RAD A-013 with Ba, La 6 0 5 0 Gamma Spec Solid RAD A-013 with Iodine 17 0 17 0 SEA WATER LSC Iron-55 2 0 2 0 LSC Nickel 63 2 0 2 0 Gas Flow Total Strontium 1 0 1 0 Gross Alpha Non Vol Beta 1 0 1 0 Gamma Spec Liquid RAD A-013 with Iodine 1 0 1 0 VEGETATION Gas Flow Sr 2nd count 9 0 9 0 Gamma Spec Solid RAD A-013 with Iodine 91 0 93 0 AIR CHARCOAL Gamma Iodine 131 RAD A-013 623 0 645 0 Carbon-14 (Ascarite/Soda Lime Filter per Liter) 46 0 47 0 DRINKING WATER Tritium 51 0 52 0 LSC Iron-55 24 0 22 0 LSC Nickel 63 23 0 21 0 Gamma Iodine-131 38 0 38 0 Gas Flow Sr 2nd count 16 0 16 0 Gas Flow Total Strontium 31 0 31 0 Gross Alpha Non Vol Beta 103 0 103 0 Gamma Spec Liquid RAD A-013 with 0 Ba, La 44 0 98 Total 2996 3359 Note 1: The RPD must be 20 percent or less, if both samples are greater than 5 times the MDC. If both results are less than 5 times MDC, then the RPD must be equal to or less than 100%. If one result is above the MDC and the other is below the MDC, then the RPD can be calculated using the MDC for the result of the one below the MDC. The RPD must be 100% or less. In the situation where both results are above the MDC but one result is greater than 5 times the MDC and the other is less than 5 times the MDC, the RPD must be less than or equal to 20%. If both results are below MDC, then the limits on % RPD are not applicable.

MI Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 47 of 58 TABLE 7 ALL RADIOLOGICAL INTRA-LABORATORY DATA

SUMMARY

BIAS AND PRECISION BY MATRIX Bias Criteria Precision Criteria

(+ / 25/o (Noe 1)

ENVIRONMENTAL 2013 WITHIN CRITERIA OUTSIDE CRITERIA WITHIN CRITERIA J OUTSIDE CRITERIA MILK Gamma Spec Liquid RAD A-013 8 0 8 0 Gamma Iodine-129 1 0 1 0 Gamma Iodine-131 41 0 131 0 Gas Flow Sr 2nd count 50 0 51 0 Gas Flow Strontium 90 10 0 10 0 Gas Flow Total Strontium 35 0 35 0 Gamma Spec Liquid RAD A-013 with Ba, La 61 0 120 0 Gamma Spec Liquid RAD A-013 with Iodine 5 0 3 0 SOLID Gas Flow Radium 228 29 0 29 0 Tritium 266 0 312 0 Carbon-14 136 0 227 0 LSC Iron-55 146 0 165 0 Alpha Spec Polonium Solid 19 0 22 0 Gamma Nickel 59 RAD A-022 138 0 157 0 LSC Chlorine-36 in Solids 8 0 13 0 Gamma Spec Ra226 RAD A-013 35 0 42 0 Gamma Spec Solid RAD A-013 701 0 893 0 LSC Nickel 63 176 0 201 0 LSC Plutonium 223 0 245 0 Technetium-99 309 0 339 0 Gamma Spec Liquid RAD A-013 4 0 4 0 ICP-MS Technetium-99 in Soil 75 0 74 0 LSC Selenium 79 5 0 5 0 Total Activity, 2 0 3 0 Tritium 5 0 5 0 Alpha Spec Am243 33 0 42 0 Gamma Iodine-129 172 0 199 0 Gas Flow Lead 210 18 0 19 0 Total Uranium KPA 10 0 18 0 Alpha Spec Uranium 278 0 380 0 LSC Promethium 147 4 0 4 0 LSC, Rapid Strontium 89 and 90 106 0 120 0 Alpha Spec Thorium 207 0 288 0 Gas Flow Radium 228 2 0 2 0 ICP-MS Uranium-233, 234 in Solid 6 0 5 0

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 48 of 58 Alpha Spec Plutonium 242 0 263 0 ICP-MS Technetium-99 Prep in Soil 78 0 74 0 LSC Calcium 45 2 0 2 0 Alpha Spec Neptunium 234 0 256 0 Alpha Spec Plutonium 157 0 195 0 Alpha Spec Radium 226 7 0 8 0 Gamma Spec Solid with Ra226, Ra228 5 0 6 0 Gas Flow Sr 2nd count 15 0 18 0 Gas Flow Strontium 90 187 0 207 0 Gas Flow Total Radium 1 0 1 0 Lucas Cell Radium 226 71 0 93 0 Total Activity Screen 10 0 13 0 Alpha Spec Am241 Curium 292 0 336 0 Alpha Spec Total Uranium 5 0 6 0 Gas Flow Total Strontium 40 0 44 0 Gross Alpha Non Vol Beta 3 0 3 0 ICP-MS Uranium-233, 234 Prep in Solid 5 0 5 0 ICP-MS Uranium-235, 236, 238 in Solid 7 0 8 0 Alpha Spec Polonium Solid 6 0 4 0 Gamma Spec Solid RAD A-013 with Ba, La 7 0 10 0 Gamma Spec Solid RAD A-013 with Iodine 6 0 7 0 Gamma Spec Solid RAD A-013 (pCi/Sample) 0 0 2 0 Tritium 3 0 3 0 ICP-MS Uranium-234, 235, 236, 238 in Solid 245 0 234 0 ICP-MS Uranium-235, 236, 238 Prep in Solid 5 0 5 0 Gross Alpha/Beta 297 0 405 0 Gross Alpha/Beta (Americium Calibration) Solid 0 0 1 0 ICP-MS Uranium-234, 235, 236, 238 Prep in Solid 122 0 115 0 Lucas Cell Radium 226 by DOE HASL 300 Ra-04 Solid 2 0 2 0 FILTER Alpha Spec Uranium 18 0 24 0 Alpha Spec Polonium 0 0 54 0 Gamma 1-131, filter 4 0 4 0 LSC Plutonium Filter 143 0 169 3 Tritium 134 0 201 0 Carbon-14 82 0 140 0 Nickel-63 0 0 4 0 LSC Iron-55 147 0 161 0 Gamma Nickel 59 RAD A-022 140 0 159 0 Gamma Iodine 131 RAD A-013 2 0 2 0

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 49 of 58 LSC Nickel 63 138 0 162 0 Technetium-99 103 0 137 0 Gamma Spec Filter RAD A-013 195 0 245 0 AIphaspec Np Filter per Liter 30 0 42 0 AIphaspec Pu Filter per Liter 14 0 29 0 Gamma Iodine-125 13 0 0 0 Gamma Iodine-129 114 0 127 0 Gross Alpha/Beta 0 0 1 0 Alpha Spec Am243 13 0 42 0 Gas Flow Lead 210 0 0 4 0 LSC Plutonium Filter per Liter 36 0 43 0 Total Uranium KPA 11 0 18 0 Alpha Spec Uranium 83 0 114 0 LSC, Rapid Strontium 89 and 90 144 0 168 0 Alpha Spec Thorium 45 0 57 0 Gas Flow Radium 228 0 0 2 0 Alpha Spec Plutonium 107 0 123 0 Alpha Spec Neptunium 112 0 129 0 Alpha Spec Plutonium 142 0 183 0 Alpha Spec Polonium,(Filter/Liter) 0 0 10 0 Alpha Spec Radium 226 0 0 1 0 Gas Flow Sr 2nd Count 93 0 101 0 Gas Flow Strontium 90 59 0 78 0 Gas Flow Total Radium 0 0 4 0 Lucas Cell Radium-226 0 0 2 0 Alpha Spec Am24lCurium 157 0 198 0 Gas Flow Total Strontium 5 0 5 0 Total Activity in Filter, 0 0 7 0 Alphaspec Am241 Curium Filter per Liter 33 0 42 0 Tritium 106 0 108 0 Gamma Spec Filter PAD A-013 Direct Count 7 0 8 0 Carbon-14 44 0 44 0 Direct Count-Gross Alpha/Beta 72 0 0 0 Gross Alpha/Beta 74 0 81 0 ICP-MS Uranium-234, 235, 236, 238 in Filter 8 0 4 0 Alpha Spec U 31 0 60 0 Gross A & B 639 0 584 0 LSC Iron-55 39 0 51 0 Technetium-99 37 0 55 0 Gas Flow Sr-90 29 0 35 0 LSC Nickel 63 37 0 44 0 Carbon-14 (Ascarite/Soda Lime Filter per Liter) 2 0 2 0 Gas Flow Pb-210 25 0 46 0 Gas Flow Ra-228 24 0 35 0

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 50 of 58 Gamma Iodine 129 47 0 47 0 ICP-MS Uranium-234, 235, 236, 238 Prep in Filter 6 0 3 0 Gamma Spec Filter 142 0 163 0 Lucas Cell Ra-226 32 0 47 0 Alpha Spec Thorium 27 0 46 0 IJQUIDD Alpha Spec Uranium 418 0 607 0 Alpha Spec Polonium 2 0 3 0 Electrolytic Tritium 19 0 29 0 Tritium 1415 0 1503 0 Tritium by Combustion 1 0 1 0 Carbon-14 181 0 204 0 Plutonium 81 0 89 0 Chlorine-36 in Liquids 2 0 3 0 Iodine-131 6 0 3 0 LSC Iron-55 290 0 347 0 Gamma Nickel 59 RAD A-022 29 0 33 0 Gamma Iodine 131 RAD A-013 3 0 3 0 Gamma Radium 228 RAD A-013 1 0 1 0 LSC Nickel 63 328 0 370 0 LSC Radon 222 5 0 12 0 Technetium-99 303 0 365 0 Gamma Spec Liquid RAD A-013 874 0 875 0 Alpha Spec Total U RAD A-011 0 0 2 0 LSC Selenium 79 1 0 1 0 Total Activity, 6 0 6 0 Alpha Spec Am243 12 0 20 0 Gamma Iodine-129 84 0 117 0 Gamma Iodine-131 33 0 33 0 ICP-MS Technetium-99 in Water 5 0 28 0 Gas Flow Lead 210 83 0 94 0 Total Uranium KPA 96 0 226 2 LSC Promethium 147 3 0 3 0 LSC, Rapid Strontium 89 and 90 15 0 15 0 Alpha Spec Thorium 205 0 278 0 Gas Flow Radium 228 244 0 318 0 Gas Flow Radium 228 36 0 35 0 Gas Flow Radium 228 1 0 1 0 Alpha Spec Plutonium 317 0 436 0 Alpha Spec Neptunium 110 0 127 0 Alpha Spec Plutonium 61 0 86 0 Alpha Spec Radium 226 0 0 1 0 Gas Flow Sr 2nd count 283 0 316 0 Gas Flow Strontium 90 499 0 568 0 Gas Flow Strontium 90 2 0 2 0 Gas Flow Total Radium 92 0 129 0 ICP-MS Technetium-99 Prep in Water 5 0 28 0

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 51of 58 ICP-MS Uranium-233, 234 in Uquid 1 0 1 0 Lucas Cell Radium 226 372 0 487 0 Lucas Cell Radium-226 17 0 21 0 Total Activity Screen 3 0 3 0 Chlorine-36 in Liquids 4 0 10 0 Alpha Spec Am241 Curium 307 0 405 0 Gas Flow Total Strontium 231 0 241 0 Gross Alpha Non Vol Beta 1313 0 1554 0 LSC Phosphorus-32 2 0 2 0 Lucas Cell Radium 226 by Method Ra-04 3 0 3 0 ICP-MS Uranium-233, 234 Prep in Liquid 1 0 1 0 Tritium in Drinking Water by EPA 906.0 11 0 14 0 Gamma Spec Liquid RAD A-013 with Ba, La 131 0 211 0 Gamma Spec Liquid RAD A-013 with Iodine 159 0 205 0 Gas Flow Strontium 89 & 90 6 0 0 0 ICP-MS Uranium-235, 236, 238 in Liquid 2 0 2 0 Gas Flow Total Alpha Radium 13 0 11 0 Gross Alpha Co-precipitation 7 0 9 0 ICP-MS Uranium-235, 236, 238 Prep in Liquid 1 0 1 0 ICP-MS Uranium-234, 235, 236, 238 in Liquid 22 0 98 0 Gross Alpha Beta (Americium Calibration) Liquid 16 0 21 0 ICP-MS Uranium-234, 235, 236, 238 Prep in Liquid 14 0 51 0 Alpha/Beta (Americium Calibration)

Drinking Water 5 0 4 0 TISSUE Carbon-14 2 0 2 0 LSC Iron-55 3 0 3 0 Gamma Nickel 59 RAD A-022 2 0 2 0 Gamma Spec Solid RAD A-013 71 0 79 0 LSC Nickel 63 4 0 4 0 LSC Plutonium 1 0 1 0 Technetium-99 2 0 2 0 Tritium 1 0 1 0 Gamma Iodine-129 2 0 2 0 Gas Flow Lead 210 2 0 2 0 Alpha Spec Uranium 5 0 5 0 Alpha Spec Thorium 2 0 2 0 Alpha Spec Plutonium 10 0 10 0 Alpha Spec Neptunium 4 0 4 0 Alpha Spec Plutonium 2 0 2 0 Gas Flow Sr 2nd count 10 0 10 0

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 52 of 58 Gas Flow Strontium 90 20 0 23 0 Alpha Spec Am241 Curium 9 0 9 0 Gas Flow Total Strontium 19 0 19 0 Gamma Spec Solid RAD A-013 with Ba, La 6 0 5 0 Gamma Spec Solid RAD A-013 with Iodine 17 0 17 0 Gross Alpha/Beta 2 0 2 0 SEA WATER LSC Iron-55 2 0 2 0 LSC Nickel 63 2 0 2 0 Gas Flow Total Strontium 1 0 1 0 Gross Alpha Non Vol Beta 1 0 1 0 Gamma Spec Liquid RAID A-013 with Iodine 1 0 1 0 VEGETAT-ION Gamma Nickel 59 RAD A-022 3 0 3 0 Gamma Spec Solid RAD A-013 31 0 31 0 LSC Nickel 63 3 0 3 0 LSC Plutonium 1 0 1 0 Technetium-99 6 0 6 0 Tritium 9 0 9 0 Gamma Iodine-129 1 0 1 0 Gas Flow Lead 210 8 0 7 0 Total Uranium KPA 4 0 4 0 Alpha Spec Uranium 23 0 21 0 Alpha Spec Thorium 7 0 7 0 Alpha Spec Plutonium 15 0 12 0 Alpha Spec Neptunium 1 0 1 0 Alpha Spec Plutonium 1 0 1 0 Gas Flow Sr 2nd count 9 0 9 0 Gas Flow Strontium 90 19 0 18 0 Gas Flow Total Radium 2 0 3 0 Alpha Spec Am241 Curium 11 0 8 0 Gamma Spec Solid RAID A-013 with Iodine 91 0 93 0 Gamma Spec Solid RAID A-013 (pCi/Sample) 5 0 3 0 Alpha Spec Am241 (pCi/Sample) 3 0 2 0 ICP-MS Uranium-234, 235, 236, 238 in Solid 9 0 7 0 Alpha Spec Uranium 1 0 17 0 Gross Alpha/Beta 4 0 4 0 Alpha Spec Plutonium 2 0 2 0 Gas Flow Strontium 90 4 0 2 0 ICP-MS Uranium-234, 235, 236, 238 Prep in Solid 7 0 5 0 AIR CHARCOAL Gamma Iodine 131 RAD A-013 623 0 645 0

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 53 of 58 Gamma Iodine-129 0 0 1 0 Carbon-14 (Ascarite/Soda Lime Filter per Liter) 89 0 88 0 DRINKING WATER Alpha Spec Uranium 7 0 8 0 Tritium 51 0 52 0 Iodine-131 1 0 2 0 LSC Iron-55 24 0 22 0 LSC Nickel 63 23 0 21 0 LSC Radon 222 96 0 96 0 Gamma Spec Liquid RAD A-013 24 0 24 0 Total Activity, 2 0 2 0 Gamma Iodine-129 2 0 2 0 Gamma Iodine-131 38 0 38 0 Total Uranium KPA 15 0 28 0 Gas Flow Radium 228 42 0 42 0 Alpha Spec Plutonium 6 0 6 0 Gas Flow Sr 2nd count 16 0 16 0 Gas Flow Strontium 90 25 0 24 0 Lucas Cell Radium-226 58 6 78 0 Alpha Spec Am241 Curium 6 0 6 0 Gas Flow Total Strontium 31 0 31 0 Gross Alpha Non Vol Beta 343 0 287 0 Tritium in Drinking Water by EPA 906.0 37 0 34 0 Gamma Spec Liquid RAD A-013 with Ba, La 44 0 98 0 Gas Flow Strontium 89 & 90 20 0 13 0 Gas Flow Total Alpha Radium 1 0 1 0 Gross Alpha Co-precipitation 105 0 87 0 Alpha/Beta (Americium Calibration)

Drinking Water 13 0 13 0 ECLS-R-GA NJ 48 Hr Rapid Gross Alpha 8 0 8 0 Total 20148 23892 Note 1: The RPD must be 20 percent or less, if both samples are greater than 5 times the MDC. If both results are less than 5 times MDC, then the RPD must be equal to or less than 100%. Ifone result is above the MDC and the other is below the MDC, then the RPD can be calculated using the MDC for the result of the one below the MDC. The RPD must be 100% or less. In the situation where both results are above the MDC but one result is greater than 5 times the MDC and the other is less than 5 times the MDC, the RPD must be less than or equal to 20%. If both results are below MDC, then the limits on % RPD are not applicable.

MLaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 54 of 58 TABLE 8 2013 CORRECTIVE ACTION REPORT

SUMMARY

CORRECTIVE ACTION ID#

& DISPOSITION PE FAILURE CARR130513-789 Root Cause Analysis of MAPEP-1 3-RdV28 Uranium-234/233, Uranium-235, Uranium-238 and Total ISO Documentation of PT Failures in Uranium MAPEP-13-RdV28 for Uranium in Vegetation by ICP/MS and Alpha Following reviews of our process and data and conversations Spec with personnel from the affected laboratories, it was determined that all failures were due to an analyst error during sample preparation. Glass instead of Teflon beakers were used during the sample digestion which contained Hydrofluoric (HF) acid. Per Standard Operating Procedure SOP) GL-RAD-A-015 section 11.2.4, the sample should have been transferred to a Teflon beaker. In this instance, this step was omitted. The digestion was performed in glass beakers so trace amounts of Uranium were leached from the glass into the sample, resulting in high bias in the results. Normal procedure dictates that glass is not used when using HF in the digestion process due to the presence of natural Uranium in the glassware.

In order to prove that this was an isolated incident and that our overall process is in control a series of digestions were performed in the glass beakers to confirm our conclusion.

• HCL /HNO 3 only digestion - Uranium was not detected.

" HCL, HNO 3, and HF digestion - Enough Uranium activity was detected to account for the high bias (as many as 70 counts in a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and 40 minute count).

" HF only digestion - Results similar to HCL, HNO 3, and HF were observed A second PT was successfully analyzed for this matrix.

CARR130522-791 Following a review of our processes, the data and conversations with personnel from the affected laboratories, it ISO Documentation of PT Failures in was determined that our normal procedure for preparing soil

-MRAD-18 for Cesium-1 34, Cesium- samples is not sufficient for this soil matrix. Per the Standard 137 and Zinc-65 in Soil Operating Procedure (SOP) GL-RAD-A-021, the sample was

[Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 55 of 58 dried, homogenized, and passed through a 28 mesh sieve.

However, approximately 20-30% of the sample consists of particles greater than the 28 mesh sieve size. These larger particles were not affected by our normal homogenization process. In accordance with the SOP, the larger particles were removed prior to preparing the container for gamma counting.

Upon receipt of the graded report, the following steps were taken to prove that this was an isolated incident and that our overall process is in control.

1. A recount of the initially prepared sample performed and confirmed the originally reported results.

2. A new container was then prepared from the original sample but omitting the preparation step and counted.

This produced acceptable results.

3. A second sample was prepared per the SOP; however, only a portion of the sample was removed during the sieving steps. This sample produced similar high biased results.

An aliquot of the sample was then pulverized prior to gamma counting. This approach also produced acceptable results.

Permanent Corrective/Preventive Actions or Improvements:

In the future, these samples will be pulverized to ensure that all the material passes through the 28 mesh sieve; thus, eliminating the need to remove any of the original sample. A comment has been added to the set-up for the solid matrix.

A second PT was successfully analyzed for this matrix.

ILaboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 56 of 58 CARR130826-810 For Failures of RAD-94 for Gross Root Cause Analysis of Gross Alpha Alpha/Bea and Strontium 89/90 in After a review of the data, an apparent reason for this Water discrepancy could not be determined. The following steps were taken to prove that this high bias was an isolated occurrence and that our overall process is within control.

1. The batch quality control samples were reviewed and found to be compliant. The LCS recovered at 110%. While the recovery is slightly elevated, it is well within the 80%-120% acceptance range.

2. Laboratory control data were also reviewed for trends. None were noted.

3. The instrument calibrations were reviewed for positive biases that could have attributed to this failure. None were noted.

4. Two sample duplicates were also prepared and counted along with the reported result. Both results fell within the method's acceptance range for duplicate. One of the results also fell within the acceptance range of the study.

5. The original sample was also recounted and the results fell within the acceptance range.

Root Cause Analysis of Strontiurn-89 (Sr-89)

LAB PBMS A-004 After a review of the data, an apparent reason for this discrepancy could not be determined. The following steps were taken to prove that this high bias was an isolated occurrence and that our overall process is within control.

1. The batch quality control samples were reviewed and found to be compliant. The LCS recovered at 98.1%.

2. Laboratory control data were also reviewed for trends. None were noted.

3. The instrument calibrations were reviewed for positive biases that could have attributed to this failure. None were noted.

4. Sample duplicates were also prepared and counted along with the reported result. Duplicate results fell within the acceptance range of the study.

Root Cause Analysis of Strontium-89 (Sr-89)

EPA 905.0 After a review of the data, an apparent reason for this discrepancy could not be determined. The following steps were taken to prove that this high bias was an isolated

Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 57 of 58 occurrence and that our overall process is within control.

1. The batch quality control samples were reviewed and found to be compliant. The LCS recovered at 102%.

2. Laboratory control data were also reviewed for trends. None was noted.

3. The instrument calibrations were reviewed for positive biases that could have attributed to this failure. None were noted.

4. Sample duplicates were also prepared and counted along with the reported result. All results fell within the method's acceptance range for duplicates.

Permanent CorrectivelPreventive Actions or Improvements:

Gross Alpha The laboratory must assume an unidentified random error caused the high bias because all quality control criteria were met for the batch. The lab will continue to monitor the recoveries of this radionuclide to ensure that there are no issues.

Strontium-89 (Sr-89)

LAB PBMS A-004 and EPA 905.0 To summarize our efforts (including the initial result), the laboratory had 3 analysts, two different methods, processed with 2 calibrations and two separate Y carriers used in the analysis of this sample and only one acceptable result for Sr-

89. All LCS results have met acceptance criteria. This leads the laboratory to conclude that there is possibly an error in the original make-up of the PT sample. The instructions list stable Sr and Y as being included but they are not at levels greater than are normally listed so we suspect that the make up of the sample was the cause. The laboratory will continue to monitor the recoveries from these two methods to ensure that there are no issues.

[Laboratories LLC P.O. Box 30712, Charleston, SC 29417 2013 ANNUAL QUALITY ASSURANCE REPORT Page 58 of 58 Root Cause Analysis CARRI 31205-845 These elevated results were obtained following our routine For failures of MRAD-19 for Uranium- procedure. The reported result for U-234 was less than the 234 and Total Uranium in Vegetation MDA and had a elevated uncertainty. This high U-234 result also attributed to the high Total-U result.

Upon receipt of the graded report, the following steps were taken to prove that this was an isolated incident and that our overall process is in control.

• A recount of the initially prepared sample performed and confirmed the originally reported results.

" The sample was reanalyzed using a larger aliquot and results that fell within the acceptance range were achieved.

Permanent CorrectivelPreventive Actions or Improvements In the future when the result is below the MDA and are not compatible with other analytical technologies, the laboratory will attempt to use a larger sample aliquot with hopes of achieve a result above the MDA or with a lower uncertainty. If the matrix and larger sample size do not provide useable data, the results may not be report.