ML061280626

Annual Environmental Operating Report

ML061280626
Person / Time
Site:	Callaway
Issue date:	04/20/2006
From:	Keith Young AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC05276
Download: ML061280626 (63)

Text

AmerenUE Callaway Plant PO Box 620 Fulton, MO 65251 April 20, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC05276 Ladies and Gentlemen:

viiAmeref Ut DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.FACILITY OPERATING LICENSE NPF-30 2005 ANNUAL ENVIRONMENTAL OPERATING REPORT Please find enclosed the 2005 Annual Environmental Operating Report for the Callaway Plant. This report is submitted in accordance with Section 5.6.2 of the Technical Specification and Appendix B to the Callaway Plant Operating License.Sincerely, eith D. Young Manager, Regulatory Affairs HAO/slk

Enclosure:

Annual Environmental Operating Report iiE 7-'~ --Z a subsidiary of Ameren Corporation ULNRC05277 April 20, 2006 Page 2 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)Attn: Document Control Desk Mail Stop P 1- 137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-7Dt Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Edward Everett ANI Account Engineer 95 Glastonbury, Glastonbury, CT 06033 Regional Administrator Department of Natural Resources Central Regional Office P.O. Box 176 Jefferson City, MO 65102-0176 2005 Callaway Plant Annual Radiological Environmental Operating Report wamere UF Docket no. 50-483 Table of Contents 1.0 Executive Summary ..........................................

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

2 2.1 Introduction

..........................................

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

2 2.3 Program Description

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2 2.4 Sampling Program Execution and Results ....................................

10 2.4.1 Program Modifications and Exceptions

.10 2.4.2 Detection and Reporting Limits .10 2.4.3 Quality Control Program .12 2.4.4 Data Interpretations

.12 2.4.5 Waterborne Pathway .12 2.4.6 Airborne Pathway .15 2.4.7 Ingeston Pathway .17 2.4.8 Direct Radiation Exposure Pathway .18 2.4.9 Other Exposure Pathways .19 2.5 Land Use Census ..21 2.6 Cross Check Results ..22 2.7 Data Reporting Conventions

..29 2.8 Radiological Environmental Monitoring Program Annual Summary .. 29 2.9 Individual Sample Results ..35 3.0 Non-Radiological Monitoring Program ...............................

57 List of Figure I List of Tables I 11 III IV V V!I VIl X XlI)(ll XII XV X\A Al Al s Distant Collection Locations Near Site Collection Locations REMP Sample Locations REMP Sample Collection Frequencies and Required Analysis Minimum Detection Capabilities for REMP Sample Analysis Land Use Census Results 2005 Cross Check Results REMP Summary Airborne Beta & Iodine Airborne Gamma Composites Soil Vegetation Surface Water Ground Water Sediments Fish Milk Supplemental REMP Samples Direct Radiation I 1.0 Executive Summary This Annual Radiological Environmental Operating Report describes the Union Electric Company, Callaway Plant Radiological Environmental Monitoring Program (REMP), and the program results for the calendar year 2005. It is submitted in accordance with section 5.6.2 of the Callaway Plant Technical Specifications.

Section 2.0 describes the Radiological Environmental Monitoring Program. Included is the identification of sampling locations, descriptions of sampling and analysis procedures, analysis results, data interpretations, and program modifications.

Quality assurance results, sampling deviations, unavailable samples, and program changes are also discussed.

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

During 2005 the Callaway Plant operated in compliance with the Offsite Dose Calculation Manual (ODCM) requirements.

Comparison of results for 2005 to preoperational data and data from previous years show no significant differences.

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

1

~- 2.0 Radiological Monitoring Program 2.1 Introduction This report presents an analysis of the results of the REMP conducted during 2005 for Union Electric Company, Callaway Plant.The radiological environmental monitoring program began in April 1982.The objectives of the REMP are to monitor potential critical pathways of radioactive effluent to man and determine the radiological impact on the environment caused by operation of Callaway Plant.Callaway Plant consists of one 1239 MWe pressurized water reactor, which achieved initial criticality on October 2, 1984. The plant is located on a plateau approximately ten miles southeast of the City of Fulton in Callaway County, Missouri and approximately eighty miles west of the St. Louis metropolitan area. The Missouri Riverflows bythe site in an easterly direction approximately five miles south of the site at its closest point.2.2 Program Design The sample locations, frequency of sampling, and sample analysis requirements originate from the Callaway Plant Off Site Dose Calculation Manual, NPDES Permit, and continuation of the Callaway Plant Pre-Operational Environmental Monitoring Program.Samples are collected from waterborne, airborne, ingestion, and direct radiation pathways.The types of sample media collected are: milk, surface water, ground water, shoreline sediment, bottom sediment, soil, wetlands, fish, vegetation, airborne particulate, airborne radioiodine, and direct radiation (TLD). Indicator samples are collected from locations which could be influenced by plant effluents.

Control samples are collected at locations that are not significantly affected by plant operation.

Samples are collected by Union Electric personnel or contractors to Union Electric and shipped to Environmental Inc. -Midwest Laboratory (EIML) and Framatone for analysis.The data is reported monthly and summarized in the annual report.2.3 Program Description Sample locations for the REM P are shown in Figures I and 11. Table I identifies the location code, description, and sample type. Table II specifies the collection frequency and required analysis.2

.Figure I Distant Collection LocationslFM-0230 01 01 LEGEND:.* = 7LD * = MILK A = AIR * = SOIL* -WATER 0 = FISH. SEDIMENT* = VEGETATION 3

Figure 11 Near Site Collection Locations La I ESE\ MET~: TOWER V E S .*F05 lFMT-024l*O50 01-30-01 LEGEND:* = ILD * = MILK A = AIR * = SOIL* = WATER 0 = FISH. SEDIMENT* = VEGETATION 4 1=

Table I REMP Sample Locations Location Code Sample Location Code Sample Types 2 Description 1 l Types Ia 10.8 mi. NW; City of Fulton on IDM Hwy Z, 0.65 mi. East of Business 54, West of Campus Apartments.

3 1.2mi.NW;0.1 mi.WestofHwy IDM CC on Gravel Road, 0.8 mi. South Hwy 0, Callaway Electric Cooperative Utility Pole No. 18559.5 1.3 mi. ENE; Primary IDM Meteorological Tower.6 2.0 mi. W; County Road 428,1.2 IDM mi. West of Hwy CC, Callaway Electric Cooperative Utility Pole No. 18609.7 1.4 mi. S; County Road 459,2.6 IDM mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole No.35097.9 3.8 mi. S; NW Side of the County IDM Road 459 and Hwy 94 Junction, Callaway Electric Cooperative Utility Pole No. 06754.10 3.9 mi. SSE; Hwy 94,1.8 mi. East IDM of County Road 459, Callaway Electric Cooperative Utility Pole No. 12182.11a 4.7 mi. SE; City of Portland, IDM Callaway Electric Cooperative Utility Pole No.12110.14 4.9 mi. ESE; SE Side of IDM Intersection D and 94, Callaway Electric Cooperative Utility Pole No.11940..2 Description 1 17 3.8 mi. E; County Road 4053, 0.3 mi. East of Hwy 94, Kingdom Telephone Company Pole No.3X12.18a 3.7 mi. ENE; East side of Hwy D, 0.5 mi. South of 0, Callaway Electric Cooperative Utility Pole No.38579.20 4.7 mi. NE; City of Readsville, Callaway Electric Cooperative Utility Pole No. 12830.21 3.8 mi. NNE; County Road 155, 1.9 mi. North of Hwy 0, Callaway Electric Cooperative Utility Pole No.19100.22a 1.9 mi. NNE; North side of Hwy 0, 100 feet East of County Road 150, Callaway Electric Cooperative Utility Pole No.31094.23 6.6 mi. NNE; City of Yucatan, Callaway Electric Cooperative Utility Pole No. 12670.263 11.7 mi. E; Town of Americus, Callaway Cooperative Utility Pole No. 11159.273 9.3 mi. ESE; Town of Bluffton, Callaway Electric Cooperative Utility Pole No. 11496.IDM IDM ICDM IDM IDM IDM IDM IDM 30a 4.4 mi. SSW; City of Steedman, N IDM side of Belgian Dr., 150 feet East of Hwy CC, Callaway Electric Cooperative Utility Pole No. 06557.5 Table I REMP Sample Locations Continued Location Code Sample Location Code Description 1 I ypes 31a 7.8 mi. SW; City of Mokane, IDM Junction Hwy C and County Road 400,0.9 mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole.32 5.4 mi. WSW; Hwy W, 0.6 mi. West IDM of County Road 447, Callaway Electric Cooperative Utility Pole No.27031.32a 5.0 mi. WSW; County Road 447, IDM Callaway Electric Cooperative Utility Pole No. 06354.33 7.4 mi. W; City of Hams Prairie, SE IDM of Hwy C and AD Junction.34 9.5 mi. WNW; NE Side of Hwy C IDM and County Road 408 Junction.35 5.8 mi. NNW; City of Toledo, IDM Callaway Electric Cooperative Utility Pole No. 17684.36 4.9 mi. N; County Road 155,0.8 mi. IDM South of County Road 132, Callaway Electric Cooperative Utility Pole No.19137.37 0.5 mi. SSW; County Road 459, IDM 0.9 mi. South of Hwy CC, Callaway Electric Cooperative Utility Pole No. 35077.38 4.6 mi. NNW; County Road 133, IDM 1.5 mi. South of Hwy UU, Callaway Electric Cooperative Utility Pole No. 34708.;4 .Description 1 Sample Types 2 39 5.4 mi. NW; County Road 111, Callaway Electric Cooperative Utility Pole No. 17516.39a 5.0 mi. NW; County Road 111, Callaway Electric Cooperative Utility Pole No. 17526.40 4.2 mi. WNW; NE Side of County Road 112 and Hwy O, Callaway Electric Cooperative Utility Pole No. 18145.41 4.9 mi. W; Hwy AD, 2.8 mi. East of Hwy C, Callaway Electric Cooperative Utility Pole No.18239.42 4.4 mi. SW; County Road 447, 2.6 mi. North of County Road 463, Callaway Electric Cooperative Utility Pole No. 06326.43 0.5 mi. SW; County Road 459, 0.7 mi. South of Hwy CC, Callaway Electric Cooperative Utility Pole No. 35073.44 1.6 mi. WSW; Hwy CC, 1.0 mi.South of County Road 459, Callaway Electric Cooperative Utility Pole No. 18769.45 1.0 mi. WNW; County Road 428, 0.1 mi. West of Hwy CC, Callaway Electric Cooperative Utiility Pole No. 18580.IDM IDM IDM IDM IDM IDM IDM IDM 6 Table I REMP Sample Locations Continued Location Code Sample Location Code Description' 46 1.5 mi. NNW; NE Side of Hwy CC and County Road 466 Intersection, Callaway Electric Cooperative Utility Pole No. 28242.47 1.0 mi. N; County Road 448,0.9 mi. South of Hwy 0, Callaway Electric Cooperative Utility Pole No.28151.48 0.4 mi. NE; County Road 448,1.5 mi. South of Hwy 0, Plant Security Sign Post.49 1.6 mi. E; County Road 448, Callaway Electric Cooperative Utility Pole No. 06959, Reform Wildlife Management Parking Area.50 0.9 mi. SSE; County Road 459, 3.3 mi. North of Hwy 94, Callaway Electric Cooperative Utility Pole No. 35086.51a 0.3 mi. SE; Owner Control Fence, SE of the Water Treatment Plant.52 0.4 mi. ESE; Light Pole Near the East Plant Security Fence.603 13.5 mi. SW; Callaway Electric Cooperative Utility Pole No. 43744 just past Tebbetts City sign.Iypes'IDM IDM IDM IDMI: lDM IDMI IDM[DM APT, AIO Description 1 A7 9.5 mi. NW; C. Bartley Farm.A8 0.9 mi. NNE; County Road 448, 0.9 miles South of Hwy 0.A9 1.9 mi. NNW; Community of Reform.B3 1.8 mi. NNW; 0.3 mi. East of the O and CC Junction, Callaway Electric Cooperative Utility Pole No.50422.D01 5.0 mi. SE; Holzhouser Grocery Store/Tavern (Portland, MO).F05 0.9 mi. SSE; Onsite Groundwater Monitoring Well.F15 0.4 mi. NNE; Onsite Groundwater Monitoring Well.PW1 Callaway Cafeteria.

M6 2.6 mi. NW; Pierce's Farm (Cow's Milk).M8 3 18.7 mi. WSW, Kissock's Farm, South of New Bloomfield, MO (Cow's Milk).M13 2.53 mi. SSE; Miller's Farm, located on Highway 448.V3 3 15.0 mi. SW; Beazley Farm, West of Tebbetts, MO.Sample Types 2 APT, AIO APT, AIO APT, AIO APT, AIO WWA WWA WWA WWA MLK MLK MLK SOL Al 1.3 mi. ENE; Primary Meteorological Tower.7 Table I REMP Sample Locations Continued Location Code Sample Types 2 Location Code Sample Types 2 Description' Description' V9 2.0 mi. WNW; Meehan Farm.V10 3.4 mi. SSW; Brandt Farm.V11 3.2 mi. NW; Hickman Farm.V12 3 18.7 mi. WSW; Kissock's Farm, South of New Bloomfield, MO.V1 3s 2.02 mi. W; Buchholz's Farm, County Road 428,1.2 mi. West of Hwy CC.A 3 4 4.9 mi. SSE; 0.6 River Miles Upstream of Discharge North Bank.C4 4.9 mi. SE; 1.0 River Miles Downstream of Discharge North Bank.S01 3 4.7 mi. SSE; 105 feet Upstream of Discharge North Bank.S02 4.9 mi. SE; 1.1 River Miles Downstream of Discharge North Bank.F2 1.64 mi. SW; Callaway Plant Forest Ecology Plot F2.F6 1.72 mi. NE; Callaway Plant Forest Ecology Plot F6.PR3 1.02 mi. ESE; Callaway Plant Prairie Ecology Plot PR3.PR7 0.45 mi. NNW; Callaway Plant Prairie Ecology Plant PR7.FPL FPL FPL FPL FPL AQS, AQS, ACF SWA SWA SOL SOL SOL: SOL.W4 0.68 mi. SSE; Callaway Plant Wetlands, SW Bank.W2 0.60 mi. SSE; Callaway Plant Wetlands, InletArea.

W1 3 0.61 mi. SE; Callaway Plant Wetlands, High Ground.W3 0.72 mi. SSE; Callaway Plant Wetlands, Discharge Area.GWS5 Ground Water Sump, Plant East of containment and Spent Fuel Pool Bldg.936, Diesel Fuel Remediation Well, Plant SE of Spent Fuel Pool Bldg.937& Monitoring Well, Plant East of Radwaste Building Drum Stor age.937Ds Monitoring Well, Plant South of Discharge MonitorTanks.

I All distances are measured from the midpoint of the two reactors as described in Final Safety Analysis Report (FSAR) Section 2.1.1.1.2 AIO =Air lodine,APT

=Air Particulate,AQF

= Fish, AQS Sediment, FPL = Leafy Green Vegetables, GWS = Ground Water Sump, IDM = TLD, MLK =Milk, SOL = Soil, SWA = Surface Water, WWA =Ground Water.3 Control Location.4 The fish collection area for location "A" is between 0.6 and 3.0 river miles upstream of the plant discharge on the north bank and for location "C" is between discharge area and 1.5 miles downstream of the discharge on the north bank. The expanded collection areas are needed to guarantee there is sufficient habitat for sampling to insure the ability to collect the required number of fish species.5 New REMP location for 2005.SOL SOL SOL SOL VWAA VW\A WA VRA 8 Table 11 REMP Sample Collection Frequencies and Required Analysis 1 Sample Sample Collection Required Type Code Frequency Analysis Airborne Iodine AIO Weekly 1 -131 weekly Air Particulate APT Weekly Gross Beta weekly 2 and Gamma Isotopic of quarterly filter composite Fish AQF Semiannually (April 1 stand Oct 1 st) Gamma Isotopic Sediment (Shoreline AQS Semiannually (April 1 stand Oct Ist) Gamma Isotopic and Bottom) (Bottom sample NPDES requirement)

Leafy Green FPL Monthly during the GrossAlpha, Gross Beta, Vegetables growing season (2nd Tues. of month)3 1 -131, and Gamma Isotopic TLD Milk Soil Surface Water Drinking / Ground Water IDM MLK SOL SWA WWA Quarterly (1 st day of each quarter)Semimonthly when animals are on pasture; monthly otherwise Gamma Dose 1-131 and Gamma Isotopic Annually (November 1 st) GrossAlpha, Gross Beta Gamma Isotopic (Continuation of preoperational program)Monthly composite (2nd Tues. of month) H-3 and Gamma Isotopic Quarterly Grab (1st day of each quarter) H-3 and Gamma Isotopic t Samples required by ODCM and NPDES permit.Additional sampling is performed as a continuation of the preoperational monitoring program.2 If gross beta activity is greater than the established base line activity level, gamma isotopic analysis is performed on the individual sample.I The growing season is defined as the months of May through November; however, the growing season will vary from year to year due to weather conditions.

9 Radiological Monitoring Program 2.4 Sampling Program Execution and Results 2.4.1 Program Modifications and Exceptions During 2005, no significant changes were made to the Radiological Environmental Monitoring Program.The Radiological Environmental Monitoring Program was executed as described in the ODCM with any exceptions listed in this report.2.4.2 Detection and Reporting Limits Table Ill gives the minimun required detection limits for radiological environmental sample analysis.

For each sample type, the table lists the detection level for each isotope. The lower limit of detection (LLD) used in this report is described in NRC Regulatory Guide 4.1 Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants" and the NRC Radiological Assessment Branch Technical Position, Rev. 1, November 1979, "An Acceptable Radiological Environmental Monitoring Program".Positive sample results are reported with a 2 sigma counting uncertainty (corresponding to the 95% confidence level). Cases where the activity is found to be below the sample analysis minimum detection level are reported as Not Detected (ND).Aerial view of the Callaway Plant site. Included is some of the land worked by a local farmer to produce feed for cattle and for growing soybeans for commercial use.10 Table III Minimum Detection Capabilities for REMP Sample Analysis 1 Food Soil and Water Airborne Fish Milk Products Sediment Analysis (pCi/1) (pCi/m 3) (pCi/kg wet) (pCi/1) (pCi/kg wet) (pCi/kg dry)Gross beta H-3 Mn-54 Fe-59 Co-58/60 Zn-65 Zr-Nb-95 2 1-1 31 4 3000/20003 15 30 15 30 15 1 000/13 0.01 130 260 130 260 0.07 1 60 Cs-1 34 Cs-1 37 Ba-La-1402 15 18 0.05 0.06 130 150 15 18 60 80 150 180 15 15 I This list does not mean only these nuclides will be detected and reported.

Other peaks which are measurable and identifiable will be reported.2 Total activity, parent plus daughter activity.3 LLDs for Surface and Drinking / Ground water are the same, with the exception of H-3 and 1-131. The drinking/ground water LLDs for H-3 and 1-131 are 2000 and 1 pCi/liter respectively.

11 Radiological Monitoring Program 2.4.3 Quality Control Program The vendor laboratory, Environmental Inc. -Midwest Laboratory, maintains a quality assessment (QC) program in accordance with Regulatory Guide 4.15. The program includes laboratory procedures designed to prevent cross contamination and to ensure accuracy and precision of analyses.

QC checks include blind, duplicate, and spiked samples as necessary to verify laboratory analysis activities are being maintained at a high level of accuracy.The contractor laboratory participates in the Department of Energy's Environmental Measurements Laboratory QualityAssessment Program (EML), Mixed Analyte Performance Evaluation Program (MAPEP), and Environmental Resource Associates (ERA). The results of these cross check programs are presented in Section 2.6.The Environmental TLDs are processed by Framatome.

This lab meets the required quality control beg maintaining a NVLAP (National Voluntary Laboratory Accreditation Program)Certification.

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

2.4.5 Waterborne Pathway Surface Water Analysis Tritium: A 60-70 ml aliquot of water is purified by distillation.

A portion of the distillate is transferred to a counting vial and scintillation fluid added. The contents of the vial are thoroughly mixed and counted in a liquid scintillation counter.Gamma Spectrometry:

Asuitable aliquot of sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.2.4.4 Data Interpretations Sample analysis results are evaluated to determine if the result was due to the operation of the Callaway Plant or other sources.One evaluation method used is the indicator-control concept. Most sample types are collected at both indicator (areas potentially affected by plant operations) and control locations (areas not significantly affected by plant-discharge).

A possible plant effect would be indicated if the detected level at an indicator location was statistically greater than at the control location.Another method involves determining if the result originated from weapons testing. The indicator or control sample result can be Sampling and Frequency Monthly composite samples of surface water from the Missouri River are collected from one indicator location (S02) and from one control location (SO1) and shipped to EIML for analysis.Results The indicator water sampler (S02) was operational 90.7% of the time during 2005.Sampler operability is verified shiftly (every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) by use of a dial up modem. Actions are promptly taken to return the sampler to service when a problem is identified.

If the sampler does not collect >250 mIs per day, daily grab samples are collected and composited.

Most of the thirty-three days of indicator water 12 Radiological Monitoring Program Sampling of the Missouri River is accom-plished using an automated compositor.

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

The control water sampler (SO1) was operational 91.2% of the time in 2005. This sampler is checked weekly. Actions are taken to promptly return the sampler to service when a problem is identified.

If the sampler cannot be returned to service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, daily grab samples are collected.

Eight of the thirty-two days of inoperability in April, was due to scheduled power outages, 7 days in June to replace and repairthe sample pump (JOB 05104857), 2 days in September to repair sampler piping (CAR 200506775), and 15 days in October to replace the sample pump and piping (CAR 200508313).

Deviations during 2005 included a grab sample in September that could not be obtained in the pre-designated location due to debris that had accumulated along the shoreline of the Missouri River. The sample was obtained several yards upstream of the normal grab sample location at the steam generator loading dock (CAR 200506775).

Tritium was the only radionuclide detected in surface water samples collected during 2005.Five of the twelve samples collected at the control location S01 contained measurable levels of tritium with a mean concentration of 332.7 pCi/L.This is due to tritium recirculation into the intake from the plant outfall CARs 200502277, 200507774, and 200505407.

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

Drinking I Ground Water Analysis Tritium: A 60-70 ml aliquot of water is purified by distillation.

A portion of the distillate is transferred to a counting vial and scintillation fluid added. The contents of the vial are thoroughly mixed and counted in a liquid scintillation counter.Gamma Spectrometry:

A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are sampler inoperability (S02) were due to the pump or piping iailures.(CARs 200503122, 200504843, 200509665, and 200510134).

Deviations during 2005 included a missed grab sample on December 8th due to snow and ice on the shoreline of the Missouri River when the composite sampler had failed. (CAR 200510055).

Tritium was the only radionuclide detected in surface water samples collected during 2005.Five of the twelve samples collected at indicator location S02 contained measurable levels of tritium with a mean concentration of 327.6 pCi/L.The Tritium results from S02 for 2005 were less than 1.5% of the reporting limit in surface water and well within regulatory requirements.

Tritium results at S02 are being trended along with monthly liquid H-3 releases and Missouri river flow.The analysis results are consistent with previous operational levels and there was no significant radiological impact on the health and safety of the public or on the environment.

13 Radiological Monitoring Program identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Analysis for 1-131 is accomplished using chemical separation followed by gas flow proportional counting techniques.

Sampling and Frequency Ground water samples are collected quarterly from two sampling (deep) wells (FO5 and F1 5)and two (deep) drinking water wells (D01 and PW1). Four additional shallow wells (GWS/936/937C/937D) were added to the Callaway REMP due to positive tritium results found in these on site aquifers.

The samples were taken as a result of NRC Information Notice 2004-05, Spent Fuel Pool Leakage to Onsite Groundwater at Salem. An exhaustive study of the source of tritium was conducted in 2004 and determined to be from recirculation of liquid effluents (CAR 200403826).

The study indicated that no additional pathways, other than those identified in the Callaway ODCM, were affected.Bottom Sediment Analysis-Gamma Spectrometry:

A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.*Sampling and Frequency: Bottom sediment samples are collected semiannually from one indicator location (C) and one control location (A). The samples are taken from water at least 2 meters deep to prevent* influence of bank erosion. A Ponar dredge is used to obtain the samples, consisting of the uppermost layer of sediment.

Each sample is placed, without preservative, in a plastic bag, sealed and shipped to EIML for analysis.: Results The well samples are collected using an electric pump that is located in the well. The drinking water samples are collected from a faucet after allowing the line to flush for two minutes. The shallow well samples are collected by Engineering Surveys & Services.

Samples are shipped to EIML for analysis.Results Tritium was the only radionuclide detected in the shallow wells collected during 2005. Twelve of the sixteen samples collected contained measurable levels of tritium with a mean concentration of 333.0 pCi/L.The analysis results for all drinking/ground water samples were consistent with previously accumulated data and no plant operational effects were identified. (Note: groundwater samples are analyzed with the more conservative LLD limits associated with drinking water.)The analysis results for bottom sediment samples in 2005 were consistent with previously

accumulated data including pre-operation and no plant operational effects were identified.

Shoreline Sediment Analysis Gamma Spectrometry:

A suitable aliquot of: prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.Sampling and Frequency Shoreline sediment samples are collected semiannually in the same area as bottom sediment.

These samples are collected within two feet of the edge of the water and consist of 2 six-: inch diameter by two-inch deep sediment plugs.Each sample is placed in a plastic bag, sealed and shipped to EIML for analysis.14 Radiological Monitoring Program Results Cs-137 was the only isotope identified in one of the two samples from the control location (A). The level of Cs-1 37 was consistent with the levels identified during pre-operation of the plant. This was documented in CAR 200507792.

The analysis results for shoreline sediment samples in 2005 were consistent with previously accumulated data including pre-operation and no plant operational effects were identified.

Results Cesium 137 (Cs-i 37) was detected in the Wetlands soil samples. Station (WI) indicated 103 pCi/Kg dry, station (W2) indicated 181 pCi/Kg dry, station (W3) indicated 139 pCi/Kg dry, and station (W4) indicated 44 pCi/Kg dry.The analysis results for Wetlands soil samples in 2005 were consistent with previously accumulated data and no plant operational effects were identified.

The Cs-I 37 activity is due to world wide fallout from atmospheric nuclear testing.Shoreline sediment samples are collected two feet from the edge of the water in the same location as the bottom sediment samples. Sediment samples indicate there has been no impact on the environment from 6/ Callaway Plant liquid discharges/effluents.

2.4.6 Airborne Pathway Airborne Analysis Gross Beta: The filters are analyzed approximately five days after collection to allow for decay of natural short-lived radionuclides.

Aglass fiber type filter is placed into a stainless steel planchet and counted for gross beta radioactivity using a proportional counter.Iodine: Each Charcoal cartridge is placed on the germanium detector and counted. A peak of 0.36 MeV is used to calculate the concentration at counting time. The equilibrium concentration at the end of the collection is then calculated.

Decay correction for the time interval between sample collection and counting is then made.Gamma Spectrometry:

Filters are composited according to location and counted using a germanium detector coupled to a computer based multichannel analyzer.

The resulting spectrum is analyzed by computer and specific nuclides, if present, identified and quantified.

Wetlands Soil Analysis Gamma Spectrometry:

Asuitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.Sampling and Frequency Wetlands soil samples are collected annually from 3 indicator locations (W2, W3, and W4) and one control location (Wi). Two 6-inch square soil plugs consisting of the uppermost two-inch layer of soil are taken at each location.

The samples are placed in plastic bags, sealed and shipped to EIML for analysis..11 .Sampling and Frequency Airborne particulate samples are collected on a 47mm diameter glass fiber filter type A/E (99 percent removal efficiency at 1 micron particulate) at a volumetric rate of one and one-half cubic feet per minute.15 Radiological Monitoring Program Each airborne particulate air sampler is equipped with a charcoal cartridge filter in-line after the particulate filter holder.The filters are collected weekly and shipped to EIML for analysis.All five sample locations are considered indicator locations (Al, A7, A8, A9, and B3). One indicator station (A9) is located at the community with the highest D/Q.Results Air station A7, A9, and B3 were operational 100% of the time in 2005 with the annual sampler calibration change out the only out of service time assigned.Air station Al was operable 100% of the time in 2005, but was inoperable 0.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in May to replace a defective fitting (CAR200503542).

Air station B3 had an hour meterfailure.

No out of service time was warranted for B3 due to the run time being calculated based on the power usage of the air station (CAR 200504019).

In September, an overgrown weeping willow tree in the vicinity of air station A7 was found affecting its ability to sample the environs.

The area surrounding the air station was cleared as noted in CAR 200506938.

Air Station A8 was operational for 96.0% of the time in 2005. Most of the inoperability is due to hour meter failures or loss of power to the sample pump as documented in CARs 200508165, 200507874, 200507586, 200506015, and 200505830.

This sampler is located in an area where it is exposed to a dustier environment than any of the other samplers and this may be a contributing factor to the repeated failures at this location.A deviation to the sampling occurred for all the air stations for the week of March 24, 2005 to March 30, 2005 when the air samples were lost in shipping to the vendor lab (CAR 200502314).

A second deviation is when the samples were sent with a cooling tower blowdown sample on September 29, 2005. The samples were dried by the lab and analyzed.

The results of the air samples do not appear to have been impacted due to the samples getting wet in transport (CAR 200506304).

Gross beta activity sample results ranged from 0.005 to 0.052 pCi/M 3.The average gross beta activity for all sample locations was 0.024 pCi/m 3.In 2005, there were 16 weekly samples with gross beta activities greater then the base line action level of 0.037 pCi/M 3.Gamma spectral analysis was performed on these filters and no gamma emitting isotopes of plant origin were detected.The analysis results for airborne samples are consistent with previously accumulated data and no plant operational effects were identified.

Airborne samples are continuously col-lected. Particulates are gathered on a glass fiber filter. A charcoal filter is in line after the-> particulate filter to collect iodines. Air samples indicate the Callaway Plant has had no impact on the surrounding environment 16 Radiological Monitoring Program 2.4.7 Ingestion Pathway Milk Analysis Iodine-1 31: Two liters of milk containing standar(G.ed Iodine carrier is stirred with anion exchange resin for one hour. The resin is washed with NaCI and the iodine is eluted with sodium Hypochlorite.

Iodine in the iodate form is reduced to 12 and the elemental iodine extracted into CCI 4 , back-extracted into water, then precipitated as palladium iodide. The precipitate is counted for 1-131 using a proportional counter.Gamma Spectrometry:

An aliquot of milk is placed in a standard counting container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.

Analysis for 1-131 is accomplished using chemical separation followed by gas proportional counting techniques.

When available, one-gallon milk samples are collected semimonthly during the grazing season (typically April through September) and monthly during the winter from two indicator stations near the Plant (M6 and Ml 3) and one control location away from the Plant (M8). Milk samples have sodium bisulfite added as a preservative, and are shipped on ice to EIML for analysis within eight days after collection.

Results Milk samples were unavailable due to animals not producing milk during the following periods: Location M13: Milk samples were unavailable 1/11,2/6, 4/12,4/26, 5/10, 5/24,6/14, 6/28,7/12, and 12/12 (CARs 200503066, 200500059, and 200501269).

Location M8 & M6: All samples were collected as scheduled.

Samples were collected monthly in January, February, March, and December (stored feed). Samples were collected semimonthly for all other months since the milking animal was spending a portion of it's time grazing.The analysis results for milk samples were consistent with previously accumulated data and no plant operational effects were identified.

Fish Analysis Gamma Spectrometry:

A prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.Sampling and Frequency The five most abundant recreational or commercial fish species are collected semiannually from one indicator location (C) and one control location (A). After collection, fish samples are shipped on ice to EIML analysis.Sampling and Frequency Fish are collected by Union Electric biolo-gists. Fish samples indicate there has been no impact on the environment due to opera-tion of the Callaway Plant.17 Radiological Monitoring Program Results The analysis results for fish samples were v consistent with previously accumulated data and no plant operational effects were identified.

Vegetation Analysis lodine-l :31: Asuitable aliquot of wet (as received) sample is placed into a standard calibrated container and counted using a germanium detector coupled to a computer based, multichannel analyzer.

A peak of 0.36 MeV is used to calculate the concentration at counting time. The equilibrium concentration at the end of collection is calculated by decay correcting for the time interval between sample collection and counting.Gamma Spectrometry:

A suitable aliquot of wet (as received) sample is placed into a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based multichannel analyzer.Sampling and Frequency Monthly during the growing season, green leafy vegetation is collected from four indicator locations V9, VI 0, VI1, and VI 3 and from one control location VI 2. Vegetation samples consisted of mustard greens, turnip greens, cabbage, lettuce, collards, radish greens, swiss chard, broccoli, and poke. Other broad leaf vegetation is requested and/or collected if primary varieties are not available.

Samples are shipped to EIML for analysis.Results Vegetation samples were collected as available from May through December due to unseasonably milder temperatures in November and December.

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

Location V9: June through November.Location Vi 0: May through July, and September through November.Location VI 1: May through December Location V1 2: May through October Location VI 3: May, June, and August The analysis results for vegetation samples were consistent with previously accumulated data and no plant operational effects were identified.

2.4.8 Direct Radiation Exposure Pathway Direct Radiation Analysis The Union Electric program uses the Panasonic Model UD-814 TLD dosimeter.

Each dosimeter consists of three elements of CaSO 4:Tm. The dosimeters are sealed in a water proof plastic bag and placed inside a polypropylene mesh cylindrical holder in the environment.

After exposure in the environment the dosimeters are read and the result is adjusted to a standard quarter of 90 days.Sampling and Frequency Thermoluminescent Dosimetry (TLD) is used to determine direct radiation levels in and around the Callaway site. Forty-three dosimeters are placed in 16 sectors around the plant as specified in the ODCM. The dosimeters are read once per quarter. Three locations are designated as controls (IDM26, IDM27 and IDM60).18 Radiological Monitoring Program Results Direct radiation data for IDM- 0 was unavailable in the second quarter, apparently due to vandalism (CAR 200503541).

The fourth quarter IDM-5 sample was lost during processing by the vendor.The analysis results for TLD samples were consistent with previously accumulated data and no plant rperational effects were identified.

2.4.9 Other Exposure Pathways Soil Analysis Gamma Spectrometry:

A suitable aliquot of prepared sample is placed in a standard calibrated container and specific nuclides are identified and quantified using a germanium detector coupled to a computer based, multichannel analyzer.Sampling and Frequency Soil samples are collected annually from four indicator locations (F2, PR3, F6, and PR7) and one control location (V3). To ensure only the most recent deposition is sampled, the uppermost two-inch layer of soil is taken at each location.

Samples consist of 2 six-inch square soil plugs; The litter at the surface and the root mat is considered part of the sample. The samples are placed in plastic bags, sealed and shipped to EIML foranalyses.

Pictured is one of the forty three dosim-eter locations used to measure direct radia-tion. Direct radiation data indicates there has been no impact from the operation of the Callaway Plant.The analysis results for soil samples in 2005 were consistent with previously accumulated data including pre-operation and no plant operational effects were identified.

The Cs-I 37 activity is due to worldwide fallout from atmospheric nuclear testing.The analysis results for soil samples were consistent with previously accumulated data. Soil sampling is a continuation of the preoperational environmental monitoring program.Results Cesium 137 (Cs-137) was detected at control station V3 at 308 pCi/Kg dry, while the highest indicator station result was 873 pCi/L dry.19 Radiological Monitoring Program REMP Supplemental Samples Several supplemental samples were taken during 2005 which were not required by FSAR-SP Table 16.11-7. A corn sample was collected from a field within the site bourndary to further assess the impadt of plant operation on the environment.

The corn field within the site boundary was harvested for commercial purposes.

Sample results are listed in Table XVI.Vegetation samples were also taken during the growing season in areas of the field near and away from the pipe break to assess the impact on the vegetation in the area. The results are also reported in table XVI.The samples were sent to EIML for analysis.The results listed in Table XVI are consistent with previously accumulated data and no plant operational effects were identified.

In January 2005, it was identified that the plant discharge line had ruptured in a field near the Missouri river where a cement crossing was created to facilitate bringing Callaway's replacement steam generators and low pressure turbines from the river (CAR 200500214).

Soil and water samples were taken from the area and the results are documented in Table XVI.This photo shows some of the wildlife in a wetland area near Callaway Nuclear Power Plant 20 Radiological Monitoring Program 2.5 Land Use Census The Land Use Census is performed annually during the growing season within a five-mile radius of the Callaway Plant. The location of the nearest resident, milking animal, and garden greater than 50 m 2 (500 ft 2) is identified by contacting residents by phone and/or in field surveys for each of the sixteen meteorological sectors using the midpoint of the two units.The Union Electric Real Estate Department conducted the 2005 Land Use Census the last two days of August and the first day of September.

Results The results of the 2005 Land Use Census are presented in Table IV. The table includes radial direction and distance from the Callaway Plant for each location.

These parameters were determined using a combination of map position, aerial photography, and a Global Positioning System (GPS) receiver.Nearest Resident The distance of the nearest resident with the highest DIQ was unchanged for 2005. This resident lives 1.82 miles from the plant in the NNW sector. New construction was observed during the field inspection; however, none qualified as closest resident in any of the sectors.Milking Animals No new residents with milking animals were located in any of the sectors.Comparison of the current REMP milk sample participants with residents identified as having milking animals in the 2005 Land Use Census indicates that no changes are necessary.

Vegetable Gardens No new residents with vegetable gardens were determined to have a 20% higher average ground level D/Q than current REMP sample participants.

Therefore, no changes to the REMP vegetable garden sampling are necessary.

View of land near the Callaway Plant during late Winter. In the background is the Missouri River.21 Table IV 2005 Land Use Census Results Closest Receptor in Miles Sector N(A)NNE(B)NE(C)ENE(D)E(E)ESE(F)SE(G)SSE(H)S(J)SSW(K)SW(L)WSW(M)W(N)WNW(P)NW(Q)NNW(R)Residence 2.2 2.2 2.3 1.7 3.5 2.1 2.2 2.5 2.7 2.4 2.6 1.2 1.6 1.9 2.1 1.8 Garden 1 Milk 1 Nl 2.4 4.0 2.9 NI 2.1 2.2 2.5 NI 3.2 3.1 3.2 2.0 1.9 3.2 3.1 Nl NI NI NI NI NI NI 2.5 NI NI NI NI 4.0 NI 2.6 NI' NI = None Identified 2.6 Cross Check Results The cross check results performed by the vendor laboratory during 2005 are presented in Table V. The results indicate satisfactory laboratory performance.

22 Table V 2005 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value 1 Value Limits 2 Result Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Am-241 Co-57 Co-60 Cs-134 Cs-137 Fe-55 H-3 Mn-54 Ni-63 Pu-238 Pu-239/40 Sr-90 Tc-99 U-233/4 U-238 Zn-65 Gr. Alpha Gr. Beta Am-241 Co-57 Co-60 Cs-134 Cs-137 K-40 Mn-54 Ni-63 Pu-238 Pu-239/40 Sr-90 U-23314 U-238 Zn-65 1.62 +/- 0.12 239.40 +/- 1.20 248.70 +/- 1.00 115.50 +/- 1.80 328.50 +/- 1.70 64.90 +/- 7.00 304.00 +/- 9.70 334.80 +/- 1.90 7.10 +/- 1.60 0.01 +/- 0.02 2.50 +/- 0.14 0.70 +/- 0.80 43.20 +/- 1.40 3.31+/- 0.20 3.38 +/- 0.20 538.40 +/- 27.90 0.45 + 0.10 1.90 + 0.10 1.72 227.00 251.00 127.00 332.00 75.90 280.00 331.00 9.00 0.20 2.40 0.00 42.90 3.24 3.33 496.00 0.53 1.67 1.20 -2.24 158.90 -295.10 175.70 -326.30 88.90- 165.10 232.40 -431.60 53.13 -98.67 196.00 -364.00 231.70 -430.30 0.00 -20.00 0.00- 1.00 1.68 -3.12 0.00 -5.00 30.03 -55.77 2.27 -4.21 2.33 -4.33 347.20 -644.80 0.00 -1.05 0.84 -2.51 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS 96.60 +/- 10.00 264.00 +/- 2.00 226.50 +/- 2.20 760.60 +/- 4.60 336.20 +/- 3.60 663.70 +/- 18.00 541.30 +/- 3.90 924.30 +/- 17.20 0.60 +/- 0.80 78.0 +/- 4.80 514.60 +/- 18.70 47.90 +/- 4.00 226.30 +/- 8.60 851.30 +/- 7.30 109.00 242.00 212.00 759.00 315.00 604.00 485.00 1220.00 0.48 89.50 640.00 62.50 249.00 810.00 76.30- 141.70 169.40 -314.60 148.40 -275.60 531.30 -986.70 220.50 -409.50 422.80 -785.20 339.50 -630.50 854.00- 1586.00 0.00- 1.00 62.65 -116.35 448.00 -832.00 43.75 -81.25 174.30 -323.70 567.000 -1053.00 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS'Results are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.2 Control Limits are defined by MAPEP and ERA.23 d Table V 2005 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits 2 Result Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Air Filter Air Filter Air Filter Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Gr. Alpha Gr. Beta Am-241 Co-57 Co-60 Cs-1 34 Cs-137 Mn-54 Pu-238 Pu-239/40 Sr-90 U-233/4 U-238 Zn-65 0.11 +/- 0.03 0.38 +/- 0.05 0.10 +/- 0.04 4.76 +/- 0.64 2.84+/- 0.22 3.54 +/- 0.37 2.20 +/- 0.27 3.15+/- 0.21 0.16 +/- 0.04 0.17 +/- 0.02 2.24 +/- 0.34 0.34 +/- 0.02 0.35 +/- 0.02 3.12 +/- 0.15 0.23 0.30 0.10 4.92 3.03 3.51 2.26 3.33 0.20 0.17 1.35 0.34 0.35 3.14 0.00 -0.46 0.15 -0.45 0.07 -0.13 3.44 -6.40 2.12 -3.94 2.46 -4.56 1.58 -2.94 2.33 -4.33 0.14 -0.25 0.14 -0.25 0.95- 1.76 0.24 -0.44 0.25 -0.46 2.20 -4.08 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS FAIL 3 PASS PASS PASS Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Jan-05 Veg Veg Veg Veg Veg Veg Co-57 Co-60 Cs- 134 Cs-1 37 Mn-54 Zn-65 10.60 +/- 0.20 3.00 +/- 0.20 4.80 +/- 0.40 4.10 +/- 0.30 5.10 +/- 0.30 6.20 +/- 0.50 9.88 3.15 5.00 4.11 5.18 6.29 6.92- 12.84 2.21 -4.10 3.50 -6.50 2.88 -5.34 3.63 -6.73 4.40 -8.18 PASS PASS PASS PASS PASS PASS IResults are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.2 Control Limits are defined by MAPEP and ERA.3 Strontium carbonate precipitates were redissolved and processed.

The average of the three analyses was 1.34, although recovery was only 30%. The result of the new analysis was 1.56 pCi/L.24 Table V 2005 MAPEP Cross Check Results Reported Reference Control Date Type Nuclide Value 1 Value Limits 2 Result Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Soil Am-241 Co-57 Co-60 Cs-134 Cs-137 Fe-55 H-3 Mn-54 Ni-63 Pu-238 Pu-239/40 Sr-90 Tc-99 U-233/4 U-238 Zn-65 Gr. Alpha Gr. Beta 2.21 +/- 0.13 239.20 +/- 7.30 275.70 +/- 1.30 171.80 +/- 4.00 342.10 +/- 2.20 167.80 +/- 9.30 514.20 +/- 12.60 437.00 +/- 2.50 105.10 +/- 3.60 1.64 +/- 0.12 2.32 +/- 0.13 9.20 +/- 1.30 72.30 + 2.30 4.11+/- 0.18 4.14 +/- 0.18 364.60 +/- 4.90 0.57 +/- 0.05 1.36 +/- 0.05 2.23 272.00 261.00 167.00 333.00 196.00 527.00 418.00 100.00 1.91 2.75 8.98 66.50 4.10 4.26 330.00 0.79 1.35 1.56 -2.90 190.40 -353.60 182.70 -339.30 116.90 -217.10 233.10 -432.90 137.20 -254.80 368.90 -685.10 292.60 -543.40 70.00- 130.00 1.34 -2.48 1.93 -3.58 6.29- 11.67 46.55 -86.45 2.87 -5.33 2.98 -5.54 231.00 -429.00 0.21 -1.38 0.85 -1.92 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS Am-241 Co-57 Co-60 Cs-134 Cs-137 K-40 Mn-54 Ni-63 Pu-238 Pu-239/40 Sr-90 U-233/4 U-238 Zn-65 48.40 +/- 3.90 608.30 +/- 2.80 322.70 +/- 2.40 632.10 +/- 5.20 512.40 +/- 4.20 720.50 +/- 19.00 516.80 +/- 5.10 366.50 +/- 13.30 68.80 +/- 15.00 0.00 +/- 0.00 602.90 +/- 17.20 61.50 +/- 1.00 164.50 +/- 16.70 874.70 +/- 8.40 81.10 524.00 287.00 568.00 439.00 604.00 439.00 445.00 60.80 0.00 757.00 52.50 168.00 823 56.77 -105.43 366.80 -681.20 200.90 -373.10 397.60 -738.40 307.30 -570.70 422.80 -785.20 307.30 -570.70 311.50 -578.50 42.56 -79.04 0.00 -0.00 529.90 -984.10 36.75 -68.25 117.60- 218.40 576.10- 1070.00 FAIL 3 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS'Results are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.2 Control Limits are defined by MAPEP and ERA.3 Incorrect sample weight used in calculation.

Result of recalculation

97.0 +/- 7.8 25 k- Table V 2005 MAPEP Cross Check Results Reported Value'Reference Value Control Limits 2 Date Type Nuclide Result Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Jul-05 Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Air Filter Veg Veg Veg Veg Veg Veg Veg Veg Veg Veg Veg Veg Gr. Alpha Gr. Beta Am-241 Co-57 Co-60 Cs-1 34 Cs-1 37 Mn-54 Pu-238 Pu-239/40 Sr-90 U-233/4 U-238 Zn-65 Am-241 Co-57 Co-60 Cs-1 34 Cs-1 37 Mn-54 Pu-238 Pu-239/40 Sr-9o U-233/4 U-238 Zn-65 0.30 +/- 0.04 0.97 +/- 0.06 0.14 +/- 0.03 5.81 +0.17 2.79 +/- 0.14 3.67 +/- 0.12 2.93 +/- 0.23 4.11+/- 0.26 0.11 + 0.02 0.10 + 0.01 2.25 + 0.29 0.28 0.02 0.28 + 0.02 4.11 +0.26 0.18 +/- 0.03 15.90 +/- 0.20 4.80 + 0.10 4.60 + 0.20 5.90 + 0.30 7.20 +/- 0.20 0.13 0.02 0.13 +/- 0.02 2.80 +/- 0.30 0.28 +/- 0.03 0.33 +/- 0.04 11.00 +/- 0.50 0.48 0.83 0.16 6.20 2.85 3.85 3.23 4.37 0.10 0.09 2.25 0.27 0.28 4.33 0.23 13.30 4.43 4.09 5.43 6.57 0.00 0.16 2.42 0.23 0.35 10.20 0.00 -0.80 0.55 -1.22 0.11 -0.21 4.34 -8.06 2.00 -3.71 2.70 -5.01 2.26 -4.20 3.06 -5.68 0.07 -0.13 0.06 -0.12 1.58 -2.93 0.19 -0.35 0.20 -0.37 3.06 -5.68 0.16 -0.30 9.31- 17.29 3.10 -5.76 2.86 -5.32 3.80 -7.06 4.60 -8.54 0.00- 1.00 0.11 -0.21 1.69 -3.15 0.23 -0.43 0.24 -0.45 7.14- 13.26 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS'Results are reported as: Bq/Kg or Bq/L for MAPEP and pCi/L for ERA.2 Control Limits are defined by MAPEP and ERA.26 Table V 2005 ERA Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits 2 Result Feb -05 Feb -05 Feb -05 Feb -05 Feb -05 Feb -05 Feb -C&5 Feb -05 Feb- 05 Feb -05 Feb -05 Feb- 05 May- 05 May- 05 May- 05 May- 05 May- 05 May- 05 May- 05 May- 05 May -05 May -05 May -05 May -05 May -05 Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Water Sr-89 Sr-90 Ba-1 33 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta Ra-226 Ra-228 Uranium Sr-89 Sr-90 Ba-133 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta 1-131 Ra-226 Ra-228 Uranium H-3 28.0 +/- 1.2 25.1 +/-0.7 52.9 +/- 2.8 54.4 +/- 0.4 67.7 +/- 1.8 39.6 +/- 1.8 159.7 3.0 55.1 +/- 1.8 46.8 +/- 1.3 13.7 1.5 13.3 + 0.6 5.1 +/-0.2 45.1 +/-4.1 7.5 0.9 87.1 +/-2.0 38.4 0.8 75.3 +/- 0.7 201.0 +/- 8.4 130.0 +/- 6.7 42.7 +/- 2.9 34.0 +/- 0.4 14.7 +/- 0.5 6.6 + 0.1 19.3 0.7 9.6 + 0.1 24,100 +/- 109 29.4 24.4 53.4 56.6 64.9 40.2 161.0 67.9 51.1 14.1 13.7 5.0 41.3 5.9 88.4 37.0 78.6 194.0 118.0 37.0 34.2 15.5 7.6 18.9 10.1 20.7 -38.1 15.7 -33.1 44.2 -62.6 47.9 -65.3 56.2 -73.6 31.5 -48.9 133.0- 189.0 38.5 -97.3 38.5 -97.3 10.4- 17.8 7.8- 19.6 0.0- 10.2 32.6 -50.0 0.0- 14.6 73.1 -104.0 28.3 -45.7 69.9- 87.3 184.0 -218.0 97.6 -138.0 21.0 -53.0 25.5 -42.9 10.3 -20.7 5.6-9.5 10.7 -27.1 4.9- 15.3 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS May -05 Water 24,400 20,200 -28,600 1 Results are reported as: pCi/I for ERA.2 Control Limits are defined by ERA.27 Table V 2005 ERA Cross Check Results Reported Reference Control Date Type Nuclide Value' Value Limits 2 Result Aug -05 Aug- 05 Aug -05 v1~ Aug- 05 Aug -05 Aug -05 Aug -05 Aug- 05 Aug-05 Aug-05 Aug -05 Aug- 05 Water Water Water Water Water Water Water Water Water Water Water Water Sr-89 Sr-90 Ba-133 Co-60 Cs-1 34 Cs-137 Zn-65 Or. Alpha Gr. Beta Ra-226 Ra-228 Uranium 29.1 +/-3.0 36.0 +/- 0.6 107.0 +/- 1.7 15.2 +/- 0.2 89.1 +/- 0.3 72.1 +/- 1.0 67.4 +/- 1.4 44.3 +/- 1.5 58.4 +/- 2.1 16.6 +/- 1.5 6.2 +/- 0.3 4.5 +/- 0.1 28.0 33.8 106.0 13.5 92.1 72.7 65.7 55.7 61.3 16.6 6.2 4.5 19.3 -36.7 25.1 -42.5 87.7- 124.0 4.8 -22.2 83.4- 101.0 64.0 -81.4 54.3 -77.1 31.6 -79.8 44.0 -78.6 12.3 -20.9 3.5 -8.9 0.0 -9.7 PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS PASS Nov- 05 Nov -05 Nov -05 Nov -05 Nov -05 Nov -05 Nov- 05 Nov- 05 Nov -05 Nov -05 Nov -05 Nov -05 Nov -05 Water Water Water Water Water Water Water Water Water Water Water Water Water Sr-89 Sr-90 Ba-133 Co-60 Cs-134 Cs-137 Zn-65 Gr. Alpha Gr. Beta 1-131 Ra-226 Ra-228 Uranium H-3 20.6 +/- 0.4 15.0 +/- 0.3 31.8 +/- 1.8 85.0 +/- 1.4 37.2 +/- 2.1 27.8 +/- 0.7 109.0 +/- 1.0 41.1 +/- 1.2 42.7 +/- 0.5 20.5 +/- 0.6 7.8 +/- 0.6 5.5 +/- 0.6 15.5+/- 0.3 12,500.0 +/- 238 19.0 16.0 31.2 84.1 33.9 28.3 105.0 23.3 39.1 17.4 8.3 3.5 16.1 10.3 -27.7 7.3 -24.7 22.5 -39.9 75.4 -92.8 25.2 -42.6 19.6 -37.0 86.8 -123.0 13.2 -33.4 30.4 -47.8 12.2 -22.6 6.2 -10.5 2.0 -5.0 10.9 -21.3 PASS PASS PASS PASS PASS PASS PASS Fail 3 PASS PASS PASS Fail 4 PASS PASS Nov -0O Water 12,200.0 10,100.0 -14,300.0'Results are reported as: pCi/l for ERA.2 Control Limits are defined by ERA.3The orignal samples were calculated using an Am-241 efficiency.

The samples were spiked with Th-232.Samplese were recounted and calculated using the Th-232 efficiency.

Tesults of the recount: 27.01 +/- 2.35 pCi/L.4 Decay of short-lived radium daughters contributed to a higher counting rate. Delay of counting for 100 minutes provided better results. The reported result was the average of the first cycle of 100 minutes, the average of the second cycle counts was 4.01 pCi/L.28 Radiological Monitoring Program 2.7 Data Reporting Conventions Lower Limit of Detection The lower limit of detection (LLD) used in this report is per NRC Regulatory Guide 4. 1, Rev. 1,"Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants", and the NRC Branch Technical Position, November 1979, "An Acceptable Radiological Environmental Monitoring Program".

The LLD is defined as the smallest concentration of radioactivity material in a sample that will yield a net count (above system background) that will be detected with 95%probability with only 5% probability of falsely concluding that a blank observation represents a"real" signal.The maximum LLDs for radiological environmental sample analysis is presented in Table ll.Data Reporting Positive sample results are reported with a 2 sigma counting uncertainty (corresponding to the 95% confidence level). In cases where the activity is found to be below the sample analysis minimum, the activity is reported as Not Detected (ND).2.8 Radiological Environmental Monitoring Program Annual Summary.The REMP Summary is presented in Table VI in accordance with NRC Regulatory Guide 4.1, Rev. 1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants", and the NRC Branch Technical Position, November 1979, "An Acceptable Radiological Environmental Monitoring Program".

In cases where the activity is found to be below the sample analysis minimum, the activity is reported as < LLD.With the exception of a small indication of tritium in riverwater, there was no measurable impact on the environment due to plant operation.

View of the Missouri River looking west from Portland Missouri.

In the distance, you can see the Callaway Nuclear Power Plant intake structure.

29

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

Performed (LLD)1 Range Direction Range Measurements Waterborne Pathway Surface Water H-3 (24)3000 293.5 (10/24)(171 -429)S02 327.6 (5/12)(222 -383)(pCi/I)4.9 mi SE 332.7 (5/12)(171 -429)Sol 4.7 Mi SSE 0 Gross Beta (24)4 8.0 (24/24)(4.5-13.0)

S02 8.0 (12/12)(4.7- 12.8)4.9 mi SE 8.1 (12/12)(4.5- 13.0)Sol 4.7 Mi SSE 0 Mn-54 (24)Fe-59 (24)Co-58/60 (24)Zn-65 (24)Zr-95 (24)Nb-95 (24)1-131 (24)Cs-I 34 (24)Cs-1 37 (24)Ba-La-140 3 (24)15 30 15 30 30 15 1000 15 18 15< LLD< LLD< LLD 0< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD 0 0 0 0 0 0 0 0 0 30

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

Performed (LLD)' Range Direction Range Measurements Waterborne Pathway Drinking / Ground Water (pCi/I)H-3 (16)Gross Beta (16)2000< LLD< LLD 0 4 7.3 (16/1 6)(1.4- 13.5)F05 9.8 (4/4)(7.2 -11.3)0 0.9 mi. SSE Shallow Monitoring Wells (pCi/I)H-3 (16)2000 333.0 (12- 16)GWS 449.5 (4/4)0 4 Gross Beta (16)4 8.4 (16/16)(3.2- 10.5)936 (225 -985)10.7 (4/4)(4.0 -14.6)0 5 Drinking / Ground Mn-54 (16)Water,& Monitoring Fe-59 (16)Wells (pCi/I) Co-58/60 (16)Zn-65 (16)Zr-95 (16)Nb-95 (16)1-131 (16)Cs-134 (16)Cs-137 (16)Ba-La-140 3 (16)15 30 15 30 30 15 1 15 18 15< LLD< LLD 0< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD 0 0 0 0 0 0 0 0 0 31

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

Performed (LLD)1 Range Direction Range Measurements Vegetation (pCi/kg -wet)1-131 Cs-1 34 (57)(57)Cs-1 37 (57)Milk 1-131 (56)Cs-1 34 (56)Cs-137 Ba-140 La-140 (56)(56)(56)60 60 80 1.0 15 18 60 15 130 260 130 260 130 150< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD Fish (pCi/kg -wet)Mn-54 (20)Fe-59 Co-58/60 Zn-65 Cs-1 34 Cs-1 37 (20)(20)(20)(20)(20)< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD< LLD 32

( ( ( C ( ( ( (( ( (Table VI REMP Summary Medium or Pathway Sampled (Unit of Measurement)

Type and Total Number of Analysis Performed Lower Limit of Detection (LLD)1 All Indicator Locations Mean (f)2 Range Location With Highest Annual Mean Name Mean (f)2 Distance and Range Direction Control Location Mean (f2 Range Number of Non-routine Reported Measurements Direct Radiation QuarterlyTLDs (mRem/Standard Quarter)Gamma (170)Dose-16.2 (158/160)(11.1 -19.3)20 4.7 mi. NE 17.7 (4/4)(15.6 -18.4)14.9 (12/12)(10.1 -19.0)0 Airborne Pathway Airborne Particulate (pCi/m 3)Gross Beta 1-131 Cs-134 Cs-137 (255)(255)(24)(24)0.010 (0.005 -0.052)(255/260)0.070 < LLD 0.050 < LLD 0.060 < LLD B -3 1.8 mi. NNW 0.026 (51/52)(0.008 -0.052)< LLD< LLD< LLD 0 0 0 0 33

( ( ( ( ( ( ( ( ( ( C Table VI REMP Summary Medium or Pathway Sampled (Unit of Measurement)

Type and Total Number of Analysis Performed Lower Limit of Detection (LLD)1 All Indicator Locations Mean (f)2 Range Location With Highest Annual Mean Name Mean (f)2 Distance and Range Direction Control Location Mean (f2 Range Number of Non-routine Reported Measurements Sediments (pCi/Kg, dry)Cs-134 Cs-1 37 (8)(8)150 180< LLD< LLD< LLD< LLD 30.5 (1/4)0 0 (pCi/Kg, dry)Cs-1 34 Cs-137 (18)(18)150 180< LLD 368 (12/14)(44 -873)F6 1.72 Mi NE< LLD 802 (2/2)(731 -873)213 (3/4)(103 -308)0 0'Minimum Detection Capabilities for REMP sample analysis.2 Mean and range are based upon detectable measurements only. Fraction of detectable measurements is indicated in parentheses.

3 Total activity, parent plus daughter activity.4 Ground Water Sump, Plant East of containment and Spent Fuel Pool Bldg.5 Diesel Fuel Remediation Well, Plant SE of Spent Fuel Pool Bldg.34 Radiological Monitoring Program 2.9 Individual Sample Results The REMP Individual sample results are presented in Tables VII through XVI.The following acronyms are used in these tables: ND = Not Detected (Result below analysis detection limit)NA= NotAvailable (Circumstances discussed in body of report)The area surrounding the Callaway Plant includes the Reform Conservation Area. The 7,044 acres that comprise this area is owned by Union Electric and managed by the Missouri Department of Conservation.

35 I ,

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

Gross Beta data is listed.All Iodine-I 31 results are <0.07. All I results are in pCi/M 3.A:I al A-(2005)1-6 1-14 so 1-20 1-27 2-3 2-10 2-17 2-24 3-3 3-10 v- 3-17 3-24 3-30 4-7 4.14 4.21 4-29 5-5 5-13 5-19 5-26 6-2 6-9 6-16 6-23 6-30-1 B-3 bA A8 AM 0.016-0.033 0.026 0.030 0.026 0.023 0.028 0.030 0.029 0.025 0.017 0.012 ND'0.014 0.013 0.020 0.013 0.015 X 0.024 0.017 0.013 0.016 0.017 0.007 0.016 0.037 0.019 0.037 0.031 0.035 0.029 0.027 0.028 0.035 0.039 0.028 0.021 0.015 ND'0.020 0.019 0.024 0.018 0.019 0.031 0.023 0.017 0.026 0.028 0.008 0.016 0.034 0.016 0.034 0.026 0.026 0.026 0.024 0.027 0.028 0.028 0.019 0.015 0.011 ND'0.014 0.014 0.020 0.014 0.018 0.023 0.018 0.015 0.018 0.021 0.005 0.018 0.031 0.017 0.033 0.026 0.029 0.025 0.026 0.026 0.029 0.030 0.021 0.017 0.014 ND'0.014 0.015 0.022 0.014 0.017 0.025 0.017 0.014 0.021 0.020 0.008 0.019 0.033 0.019 0.039 0.029 0.032 0.033 0.029 0.035 0.033 0.035 0.026 0.019 0.014 ND'0.018 0.016 0.022 0.014 0.016 0.027 0.018 0.014 0.018 0.022 0.010 0.020 0.025 7-7 7-14 7-21 7-28 8-4 8-11 8-18 8-25 9-1 9-8 9-15 9-22 9-29 10-6 10-13 10-20 10-28 11-3 11-10 11-18 11-23 12-1 12-9 12-15 12-22 12-29 0.013 0.028 0.032 0.021 0.027 0.025 0.018 0.020 0.026 0.033 0.036 0.019 0.023 0.021 0.018 0.036 0.014 0.028 0.031 0.020 0.019 0.022 0.041 0.017 0.033 0.037 0.016 0.028 0.023 0.019 0.030 0.026 0.017 0.014 0.030 0.034 0.039 0.021 0.023 0.022 0.016 0.041 0.015 0.032 0.035 0.025 0.025 0.027 0.052 0.024 0.042 0.048 0.014 0.024 0.021 0.017 0.029 0.027 0.022 0.018 0.026 0.036 0.038 0.020 0.017 0.018 0.017 0.035 0.014 0.025 0.031 0.019 0.021 0.019 0.037 0.018 0.028 0.038 0.014 0.026 0.022 0.019 0.029 0.026 0.017 0.012 0.028 0.034 0.041 0.023 0.022 0.023 0.013 0.032 0.015 0.031 0.033 0.023 0.021 0.020 0.039 0.020 0.036 0.042 0.017 0.030 0.026 0.020 0.027 0.027 0.015 0.018 0.026 0.033 0.039 0.022 0.023 0.020 0.018 0.037 0.017 0.029 0.034 0.019 0.022 0.021 0.041 0.022 0.033 0.044 I Samples lost in transit; delivery vendor unable to locate.(CAR 200502314) v Airborne Gamma Composites (All results are the effect of natural background)

Table VI1I Gamma Isotopic 1 (pCi/m 3)A-1 QTR1 QTR2 0.072 QTR3 0.071 QTR4 0.047 Be-7 0.074 Be-7 Be-7 Be-7 A-7 QTR1 QTR2 QTR3 QTR4 0.057 0.080 0.068 0.052 A-8 QTR1 QTR2 QTR3 QTR4 0.060 0.082 0.069 0.054 A-9 QTR1 QTR2 QTR3 QTR4 0.080 0.080 0.057 0.046 B-3 QTRI QTR2 0.082 QTR3 0.076 QTR4 0.061 Be-7 0.082'Co-58, Co-60, Zr-95, Nb-95, Cs-134, Cs-1 37, Ba-140, La-140, and Ce-1 44. ND = Not Detectable.

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

Gamma Isotopic 1 (pCi/kg)F2 F2 F6 F6 PR3 11/23/05 11/23/05 11/23/05 11/23/05 11/23/05 Gross Alpha Gross Beta K-40 Cs-137 18,924 25,613 13,475 505 20,515 23,248 11,871 337 14,496 24,861 11,766 731 13,691 24,259 12,118 873 11,418 21,686 10,992 512 PR3 PR7 PR7 V3 V3 11/23/05 11/22/05 11/22/05 11/22/05 11/22/05 Gross Alpha Gross Beta K-40 Cs-1 37 6,510 21,658 10,870 349 13,07 25,053 11,606 362 12,751 24,371 11,869 310 13,383 30,410 15,411 229 14,664 26,023 15,203 308 WI WI W2 W2 W3 11/22/05 11/22/05 11/22/05 11/22/05 11/22/05 8,532 9,912 9,996 13,752 12,340 18,848 24,082 19,965 19,383 13,855 14,035 13,020 15,386 15,972 12,956 ND 103 75 181 139 v- Gross Alpha Gross Beta K-40 Cs-1 37 W3 W4 W4 11/22/05 11/22/05 11/22/05 Gross Alpha Gross Beta K-40 Cs-1 37 12,673 21,851 11,509 ND 13,194 25,817 9,296 ND 18,454 23,998 11,466 44 MIMn-54, Fe-59, Co-58, Co-60, Zr-95, Nb-95, Cs-134, Ba-140, and La-140. ND = Not Detectable.

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

Gamma Isotopic' (pCilkg wet)V9 6/27/05 Lettuce 6/27/05 Cabbage 7/25/05 Cabbage 8/22/05 Cabbage 8/22/05 Collards Gross Alpha Gross Beta K-40 133 7,751 7,316 76 5,119 4,229 203 6,416 5,492 115 4,879 3,048 85 5,169 4,115 9/12/05 Collards 9/12/05 Cabbage 9/26/05 Lettuce 9/26/05 Mustard 10/10/05 Mustard Gross Alpha Gross Beta K40 99 5,984 4,676 82 6,867 4,966 ND 4,319 5,209 245 7,143 5,464 ND 6,269 6,085 10/10/05 Collards 10/10/05 Cabbage 10/24/05 Turnips 10/24/05 Mustard 11/7/05 Collards Gross%- Gross K-40 Alpha Beta ND 5,252 4,850 ND 6,204 4,634 11/7/05 Mustard 146 ND 4,311 3,442 ND 5,381 4,479 101 5,511 4,196 11/7/05 Turnips Gross Alpha Gross Beta K-40 101 4,694 5,464 3,936 3,577 IMn-54, Co-58, Co-60, 1-131, Cs-134, and Cs-137. ND = Not Detectable.

39 Vegetation (All results are the effect of natural background)

Table X Gamma Isotopic' (pCi/kg wet)v1o 5/10/05 Turnips 5/10/05 Lettuce 5/10/05 Mustard 6/14/05 Cabbage 6/14/05 Spinach Gross Alpha Gross Beta K-40 53 3,512 3,497 6/14/05 Lettuce 58 3,227 2,932 6/14/05 Mustard ND 5,367 4,932 65 3,832 4,044 6/14/05 Turnips ND 4,163 3,540 ND 3,087 3,130 7/26/05 Mustard 172 6,646 5,879 ND 4,833 5,288 7/26/05 Lettuce 171 7,745 6,409 Gross Alpha Gross Beta K-40 ND 4,014 3,425 Gross Gross K-40 Alpha Beta 7/26/05 Cabbage 76 4,618 3,570 9/27/05 Mustard 147 3,241 3,888 10/11/05 Mustard ND 3,806 4,012 10/11/05 Turnips ND 3,845 3,570 10/25/05 Turnips ND 4,294 4,157 10/25/05 Lettuce 10/25/05 Mustard 11/8/05 Lettuce 11/8/05 Turnips 11/8/05 Mustard Gross Alpha Gross Beta K-40 161 5,707 3,572 121 5,789 4,619 51 3,136 3,798 198 4,012 3,361 126 5,035 3,744 IMn-54, Co-58, Co-60, 1-131, Cs-1 34, and Cs-137. ND = Not Detectable.

40 Vegetation (All results are the effect of natural background)

Table X Gamma Isotopic' (pCi/kg wet)V11 5/9/05 Cabbage 6/13/05 Spinach 6/13/05 Lettuce 6/13/05 Swiss Chard 7/11/05 Lettuce 7/11/05 Cabbage Gross Alpha Gross Beta K-40 114 4,833 4,041 173 7,036 6,814 188 2,734 3,072 69 4,216 3,913 79 5,243 4,157 77 3,095 2,764 7/11/05 Swiss Chard 8/8/05 Cabbage 8/8/05 Lettuce 8/22/05 Swiss Chard 9/12/05 9/12/05 Swiss Chard Cabbage Gross Alpha Gross Beta K-40 226 8,104 5,474 91 4,573 4,266 87 5,856 4,011 266 3,907 3,225 ND 4,326 4,232 105 4,893 4,215 Gross Alpha Gross Beta K-40 9/26/05 Turnips 191 4,934 4,482 10/10/05 10/10/05 Swiss Chard Turnips ND 76 4,384 5,048 3,855 4,234 10/24/05 Cabbaae 170 4,496 2,911 11/7/05 Swiss Chard 204 6,239 5,175 11/7/05 Kale 93 3,318 3,439 Gross Alpha-- Gross Beta K-40 11/21/05 Cabbage 169 4,112 4,562 12/12/05 12/12/05 Swiss Chard Turnips 378 471 6,907 7,826 6,336 7,587 I Mn-54, Co-58, Co-60, 1-131, Cs-1 34, and Cs-137. ND =Not Detectable.

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

Gamma Isotopic' (pCi/kg wet)V12 5/23/05 Poke Gross Gross K-40 Alpha Beta ND 8,977 7,072 6/14/05 Lettuce ND 3,590 3,341 7/11/05 Lettuce ND 7,916 7,226 7/25/05 Cabbage 137 6,745 4,104 I 8/9/05 Cabbage 9/12/05 Cabbage 9/27/05 Poke 10/11/05 Cabbage Gross Alpha Gross Beta K-40 124 5,753 5,286 153 4,327 3,531 ND 5,947 6,666 ND 3,891 3,121 I Mn-54, Co-58, Co-60, 1-131, Cs-1 34, and Cs-1 37. ND = Not Detectable.

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

Gamma Isotopic' (pCi/kg wet)V13 5/24/05 Turnips 6/28/05 Beet Leaves 6/28/05 Turnips 6/28/05 Cabbage 8/9/05 Lettuce Gross Alpha Gross Beta K-40 327 5,719 4,514 ND 9,876 7,546 224 7,332 4,824 88 6,474 4,099 124 6,642 3,431 1 Mn-54, Co-58, Co-60, 1-131, Cs-1 34, and Cs-1 37. ND = Not Detectable.

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

Gamma Isotopic 1 (pCi/L)Sol 1/11/05 Gross Alpha Gross Beta H-3 2.9 5.7 ND 2/8/05 ND 7.1 ND 3/15/05 3.7 4.5 ND 4/13/05 ND 8.5 ND 5/11/05 6.8 9.6 2452 6/14/05 3.7 13.0 ND 7/12/05 8/9/05 9/13/05 10/11/05 11/8/05 12/14/05 Gross Alpha Gross Beta l H-3 4.3 11.5 2.1 5.9 3.9 8.0 171 2.6 8.1 276 1.7 7.7 ND 2.7 7.3 ND 429 176 S02 1/11/05 2/8/05 3/15/05 Gross Alpha Gross Beta H-3 4.1 8.3 ND ND 6.7 ND 4.9 4.7 370 4/13/05 3.1 8.4 ND 5/11/05 2.6 9.3 3833 6/14/05 2.7 12.8 ND 7/12/05 8/9/05 9/13/05 10/11/05 11/8/05 12/14/05 Gross Alpha Gross Beta H-3 3.4 3.4 9.3 222 6.1 ND 2.5 8.4 282 3.1 6.6 381 1.1 7.1 2.7 7.8 ND ND 1 Mn-54, Fe-59, Co-58, Co-60, Zn-65, Zr-95, Nb-95,1-131, Cs-1 34, Cs-1 37, Ba-1 40, and La-140.ND = Not Detectable.

2 Reanalyais of sample 225, Backup sample 205 3 Backup sample 278 44 Table XII Ground Water Gamma Isotopic 1 (pCi/L)D01 Beta H-3 QTR1 7.7 ND QTR2 1.4 ND QTR3 2.2 ND QTR4 3.9 ND Beta H-3 Beta H-3 F05 QTR1 QTR2 QTR3 QTR4 8.3 11.3 7.2 10.4 ND ND ND ND F015 QTR1 QTR2 QTR3 QTR4 9.3 6.5 5.4 10.6 ND ND ND ND PwOOM Beta H-3 QTR1 7.1 ND QTR2 13.5 ND QTR3 4.3 ND QTR4 7.1 ND 1-131, Mn-54, Fe-59, Co-58, Co-60, Zn-65, Zr-95, Nb-95, Cs-134, Cs-137, Ba-140, and La-140 ND =Not Detectable.

45 Table XII Ground Water GWS1 QTR1 QTR2 QTR3 QTR4 Beta H-3 Beta H-3 Beta H-3 Beta H-3 5.1 10.7 3.0 12.6 225 264 985 324 9361 QTR1 QTR2 QTR3 QTR4 4.0 10.8 14.6 13.2 ND, 301 269 529 937C1 QTR1 QTR2 QTR3 QTR4 3.3 9.7 8.0 5.1 178 165 ND 255 937D1 QTR1 QTR2 QTR3 QTR4 8.8 8.0 11.5 5.7 238 NDE ND 263'Samples taken in response to NRC information notice 2004-05: SFP Leakage to onsite Groundwater.

2 ND = Not Detectable.

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

Gamma Isotopic 1 (pCilkg dry)Bottom Sediments A C 5/5/05 10/17/05 5/5/05 10/17/05 13,891 ND K-40 Cs-1 37 13,981 ND 14,052 ND K-40 Cs-1 37 12,989 ND Shoreline Sediments A C 5/5/05 10/17/05 5/5/05 10/17/05 K-40 Cs-137 15,018 30.5 15,248 ND K-40 Cs-137 14,136 ND 14,071 ND 1 Mn-54, Fe-59, Co-58, Co-60, Zr-95, Nb-95, Cs-1 34, Cs-137, Ba-1 40, and La-1 40. ND = Not Detectable.

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

-~ Gamma Isotopic' (pCi/kg wet)A K-40 5/5/05 Carp 2,944 10/17/05 Carp 5/5/05 Freshwater Drum 3,562 10/17/05 Freshwater Drum 2,652 5/5/05 Channel Catfish 2,915 10/17/05 Channel Catfish 2,790 5/5/05 Bigmouth Buffalo 3,017 10/17/05 Shorthead Redhorse 3,081 5/5/05 River Carpsucker 2,839 10/17/05 River Carpsucker 2,858 K-40 2,991 C K-40 5/5/05 Carp 3,072 10/17/05 Carp 5/5/05 Freshwater Drum 3,105 10/17/05 Freshwater Drum 5/5/05 Channel Catfish 2,807 10/17/05 Channel Catfish 5/5/05 Bigrmouth Buffalo 3,060 10/17/05 Shorthead Redhorse 5/5/05 River Carpsucker 3,125 10/17/05 River Carpsucker K-40 3,326'Mn-54, Fe-59, Co-58, Co-60, Zn-65, Cs-134, and Cs-1 37. ND = Not Detectable.

3,839 3,026 3,272 2,990 48 Milk Table XV (All results are the effect of natural background)

Gamma Isotopic and Iodine' (pCi/L)M6 K-40 K-40 K-40 K-40 1/11/05 1,153 5/24/05 1,377 8/23/05 1,161 12/13/05 1,273 2/8/05 1,188 6/14/05 1,208 9/13/05 1,304 3/8/05 1,258 6/28/05 1,182 9/27/05 1,132 4/12/05 1,216 7/12/05 1,414 10/11/05 1,123 4/26/05 1,308 7/26/05 1,491 10/25/05 1,223 5/10/05 1,385 8/9/05 1,298 11/8/05 1,335 M8 K-40 K140 K-40 1/9/05 1,261 5/24/05 1,001 8/23/05 970 2/6/05 1,360 6/14/05 530 9/13/05 1,116 3/6/05 1,188 6/28/05 1,216 9/27/05 1,194 4/11/05 1,256 7/11/05 1,231 10/10/05 1,051 4/26/05 1,148 7/24/05 1,299 10/25/05 1,217 5/8/05 1,260 8/8/05 1,162 11/6/05 1,068 12/12/05 K40 1,265'1-131, Zn-65, Cs-134, Cs-137, Ba-140,and La-140. ND = Not Detectable.

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

Gamma Isotopic and Iodine' (pCi/L)M13 3/31/05 1,146 8/1/05 1,555 8/8/05 1,661 8/23/05 1,467 9/13/05 1,599 9/27/05 1,526 K-40 10/10/05 1,537 10/24/05 1,364 11/7/05 1,526 11/21/05 1,455 v K-40 1- 131, Zn-65, Cs-1 34, Cs-1 37, Ba-1 40, and La-1 40. ND =Not Detectable.

50 Supplemental REMP Samples Table XVI Activity Deposited In Area of Discharge Line Break (uCi)H-3 Sb-125 Ni-63 Ru-103 Gs-137 Cr-51 Co-60 Co-58 927 1 .47E-01 4.07E-01 2.94E-02 1 .46E-02 1.19E-01 2.69E-02 3.07E-02 Soybeans / Other Vegetation at Discharge Pipe Repair Location 7/29/05 Location 1 Location 2 Location 3 Location 42 Gross Alpha Gross Beta K-40 Gamma Isotopic Gamma Isotopic (pCilkg)wet 110 7281 6507 ND'246 6892 5159 ND'126 8506 5116 ND'90 5158 4741 ND'1 Mn-54, Fe-59, Co-58, Co-60, Zr-Nb-95, Cs-134, Cs-137, Ba-140, and La-140. ND = Not Detectable.

2 Control location for area of pipe break. Area was undisturbed and up grade of area where repair was performed.

51 Supplemental REMP Samples Table XVI Gamma Isotopic and Iodine 1 (pCiKg -dry soil)Discharge Line Break Misc. Samples Cs-1 37 H-3 H-3 (pCi/L)1/13/05 44 43 ND 1/13/05 46 413 1/13/05 69 ND 1/13/05 ND 34 1/13/05 ND ND 1/13/05 ND ND 1/18/05 1/18/05 1/18/05 1/18/05 1/18/05 1/18/05 Cs-137 ND ND 60 92 ND ND H-3 207 ND ND ND ND ND 1/19/05 1/19/05 1/19/05 1/19/05 1/19/05 1/19/05 Cs-137 66 ND 69 ND 113 ND H-3 ND ND 191 317 82 ND 1/19/05 1/19/05 1/19/05 1/21/05 Cs-137 ND 57 81 H-3 ND 60 62 52/42 1 Mn-54, Fe-59, Co-58, Co-60, Zr-Nb-95, Cs-1 34, Cs-1 37, Ba-140, and La-140. ND = Not Detectable.

52 Supplemental REMP Samples Table XVI (All results Gamma Isotopic' (pCi/kg)wet Gros& Beta K-40 Gamma Isotopic are the effect of natural background)

Corn 6/17/05 2330 2359 ND'Mn-54, Fe-59, Co-58, Co-60, Zr-Nb-95, Cs-1 34, Cs-137, Ba-140, and La-140. ND = Not Detectable.

53 Supplemental REMP Samples Table XVI* f Cooling Tower Blowdown 1/13/05 ND2 2/3/05 ND2 3/2/05 313 4/7/05 335 5/3/05 1207 H-3 H-3 H-3 H-3 6/2/05 7/6/05 7/6/053 7/15/05 7/27/05 ND2 4190 4438 1780 644 8/3/05 8/16/05 8/18/05 8/24/05 8/31/05 845 132 158 336 2258 9/7/05 9/26/05 11/8/05 12/7/05 12/21/05 1926 479 1755 ND NDa 12/28/05 ND H-3'Tritium Samples taken due to plant outfall recirculation into intake.2 ND = Not Detectable.

3 Duplicate Sample.54 Direct Radiation (All results are the effect of natural background)

Table XVII Gamma Dose (mrem)Q TR 1 QTR 2 1a 3 5 6 7 9 10 11a 14 17 18a 20 21 22a 23 26 27 30a 31a 32 32a 17.4 18.2 16.0 18.4 17.8 17.0 19.3 18.7 17.6 18.3 17.4 18.4 18.4 17.7 17.7 12.3 19.0 17.2 18.5 18.3 17.9 16.4 17.3 14.4 16.8 18.1 15.5 17.5 17.7 17.7 17.6 18.4 17.9 17.0 17.9 12.3 17.8 16.2 17.1 17.1 17.5 16.3 15.5 15.8 13.5 15.0 14.7 14.2 17.0 17.2 16.0 15.9 16.3 17.3 17.2 16.1 16.7 11.3 17.0 16.3 17.7 17.0 17.6 16.4 QTR4 14.0 14.8 2 14.6 14.7 13.7 15.6 15.5 14.2 14.7 15.3 15.6 15.0 13.9 15.0 10.1 15.5 14.2 14.7 14.9 14.7 14.0 34 35 36 37 38 39 39a 40 41 42 43 44 45 46 47 48 49 50 51a 52 60 QTR1 17.8 16.7 17.7 18.0 12.8 18.4 18.7 19.0 18.1 15.6 17.5 17.4 16.3 18.5 16.1 17.6 17.9 18.0 17.9 16.9 17.3 QTR 2 16.2 15.1 15.6 17.2 11.6 15.4 17.3 17.7 16.4 14.6 17.7 17.1 16.9 17.5 16.7 17.2 15.9 17.0 17.0 16.9 16.3 QTR3 QTR4 15.5 15.2 16.1 16.9 12.2 16.6 17.1 17.4 16.2 13.9 16.7 17.2 15.5 16.1 15.6 16.7 16.5 15.7 17.0 16.7 16.2 13.3 13.4 15.2 14.1 11.1 14.4 15.3 14.9 13.9 12.5 14.2 15.7 13.0 15.3 14.4 15.2 14.7 14.0 16.3 15.1 13.9 33 17.9' TLD and holder missing from assigned location.

Installed 3rd Quarter TLD and new holder.2 TLD lost by the vendor during the reading process.55 3.0 Non-Radiological Monitoring Program 3.1 Introduction Union Electric Company, d. b.a. AmerenU E, in accordance with federal regulations and a desire to maintain the quality of the local environment around Callaway Plant has implemented an Environmental Protection Plan, (EPP) contained in Appendix B of the Callaway Plant Operating License.The objective of the EPP is to provide for protection of non-radiological environmental values during operation of the Callaway Plant.This report describes the conduct of the EPP for the Callaway Plant during 2005.3.2 Unusual or Important Events No unusual or important events reportable under the EPP Section 4.1 were identified during 2005.3.3 EPP Noncompliance During 2005 there were no noncompliances with the EPP.3.4 Nonroutine Reports There were no nonroutine reports submitted in accordance with the EPP, Section 5.4.2 in 2005.3.5 Plant Design and Operation Environmental Evaluations.

This section lists all changes in the plant design, operation, tests or experiments installed during 2005, which could have involved a potentially significant unreviewed environmental question in accordance with section 3.1 of Appendix B.During 2005, there was one plant design and one operation activity that could have involved a potentially significant unreviewed environmental question.

The interpretations and conclusions regarding these plant changes along with a description of the change are presented below.Callaway Discharge Line Break Description of Activity: On January 11, 2005 Steam Generator Replacement Project (SGRP) Contractor identified a hole in the ground with water bubbling up nearthe new concrete crossing installed plant east of the Intake Structure Access Road.AmerenUE Engineering personnel went to investigate later that day and noted there was a hole but no water bubbling or movement.

After checking with Radwaste Department, it was discovered that blowdown flow was raised from around 2700 gpm to 5700 gpm from 0200 until 1000 for Discharge Monitor Tank (DMT) discharge activity.

A planned increase in blowdown flow was subsequently performed on January 12 at 1000.Personnel were in position prior to the blowdown flow increase and again noted no water level in crease or bubbling within the hole. After approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, bubbling and some minor water flow within the hole was identified.

This indicated that the 24" diameter discharge line was leaking somewhere in the vicinity of the new concrete crossing installed to support the SGRP transportation activities at certain flow rates.The amount of the leak was believed to correspond to Missouri River level since the river level was above the pipe discharge elevation, thereby causing a slight backpressure on the discharge line. The river elevation on 1/11 was around 513' and 1/12 was around 510'. It was a high 526' within the last couple of weeks.56 v~ 3.0 Non-Radiological Monitoring Program With lower river levels and under normal plant blowdown conditions (approx. 2700 gpm), there were no indications of leakage. Repair of the piping was completed on January 21, 2005 when the weather and soil conditions permitted excavation and access for equipment and personnel.

Evaluation of Activity: The continued use of the discharge line in its degraded condition until repairs can be completed was evaluated.

As noted in the description, there are no conditions of lower river level and low discharge flow that resulted in not visible indications of discharge line leakage. A Missouri River level of 511 feet or less at the Callaway Plant intake structure combined with limiting the cooling tower blowdown discharge and bypass flow to 2700 gallons per minute or less resulted in no surface indications of discharge line leakage.The leakage from the discharge line is located approximately 400 yards upstream from the discharge point to the Missouri River. The site is located south of highway 94 in the Missouri River Flood plain. The discharge line is buried 10 to 12 feet deep in the area of the break. In this area the subsurface water is hydraulically connected to the Missouri River.Discharge from the cooling tower blowdown and bypass are the highest volume outfalls that are discharged from the discharge line. These outfalls have no radioactive component and are regulated by the Missouri Department of Natural Resources (MDNR). The MDNR has been advised of the degraded condition of the discharge line and that conditions are such that the line repairs can not be initiated until river level decreases.

It was acceptable to continue discharge from the cooling tower as long as flow is limited to 2700 gpm even if river level is greater than 511 feel at the Callaway Intake.Discharge from the Radwaste Treatment System is also regulated by the MDNR for non radiological components, but it also has a radioactive component that is regulated by the N RC. The system is such that after the radwaste system discharge has mixed with the water from the cooling tower blowdown or bypass, it will meet the 10 CFR 20 limits. This mixing would be complete long before it reaches the location of the discharge line that is degraded.

If the flow from the cooling tower is limited to 2700 gpm and the river level is at or below 511 feet at the Callaway intake, it is acceptable to discharge from the radwaste treatment system. This was with current conditions of the discharge line and no surface indications of a leak. While discharging from the radwaste system the surface indications should be checked periodically for leakage indications.

All chemical and radiological releases will be within the established limits for the plant. In addition, the compensatory actions imposed will minimize any adverse environmental impact that would be expected from this deviation from our discharge location.This activity did not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.57 3.0 Non-Radiological Monitoring Program Callaway Modification 02-2002: Description of Modification:

This modification allowed the installation of approximately 8567 feet of 3 inch Class 200 PVC piping to provide potable water to the new Callaway Plant Gun Range Facility.

This piping is an extension from the existing potable water system (tie in Plant South of the power block near the circ/service water pump house) to the new facility.

It was estimated that approximately 0.4 acres of land will be disturbed to install this piping in a trench with a maximum width of 2 feet and a depth of 48 inches. Since this modification does involve a drinking water supply, permitting is required by the State of Missouri Department of Natural Resources prior to beginning any construction.

Evaluation of Change: Both the ER and FES-OL were reviewed against Modification 04-9030 Revision C for any previously evaluated adverse environmental impacts and any adverse environmental impacts not previously evaluated.

No adverse environmental impacts were identified.

The installation of this potable water piping described above has no effect upon effluents or power level.Some'excavation will be required to install the new section of potable water piping. It is estimated that approximately 0.4 acres will be disturbed to install this 3 inch PVC piping. The routing of this new pipe was reviewed against "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri." Although land will be disturbed outside of the Callaway Plant owner controlled area, no identified cultural resources will be affected by the installation of this piping.The entire area to be excavated is estimated to be less than one half acres and will not adversely effect stormwater runoff. Because of the total area to be disturbed is less than one half acre, no stormwater permit is required.

However, any material excavated to install this piping will be contained or removed to prevent discharge to stormwater.

Installation of most of the new potable water piping will be in locations where any rainfall that could result in stormwater runoff being discharged through a point source to the waters of the state, will be discharged through Outfall 010 and Outfall 011. These Callaway Plant Stormwater Outfalls are currently permitted by the State of Missouri.Installation of this potable water piping will not result in a new, different or increased discharge of pollutants that could affect the NPDES Permit.This modification to install the potable water piping does not create an oil waste stream that could be released to the environment.

Petroleum use by facility construction equipment is controlled and contained to accepted equipment standards.

This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License. Construction of the OSGSF will require excavation of the structure's foundation, and these activities will be controlled by means appropriate to limit any potential soil erosion. The areas surrounding the facility will be surface stabilized as part of this modification.

Grading of the area of the OSGSF construction will route rainfall to an acceptable water runoff pattern to account for the effects of local intense precipitation described in Section 2.4.2.3 of the Site FSARAddendum.

The stormwater runoff will ultimately be discharged through outfall 014 which is a stormwater outfall in our NPDES permit. The actions taken to minimize soil erosion along with the retention pond for this outfall will maintain all limited parameters within our NPDES limits. This modification will not significantly affect the concentrations, frequencies or types of effluent being discharged from the plant, and does not affect the current plant power level. Therefore, this change does not constitute an unreviewed environmental question per Section 3.1 of Appendix B to the Callaway Plant Operating License.58 v, 3.0 Non-Radiological Monitoring Program Callaway Modification 02-1010 Evaluation of Change: Description of Change: This change is to permanently expand the protected area security boundary to encompass the area outside security fence on the eastern v most (oriented to Plant North) side of the existing site protected area (PA) boundary to the portion of the Unit 2 excavation that has been backfilled in.Under separate modification packages, various SGR support facilities, both temporary and permanent, are being erected in this backfilled area as well. Modification Package 02-1010 confines its scope to the ensuring that the permanent extension of the PA security boundary meets all required regulations, codes, and standards for design, construction, and operation of security/safeguards features for the Callaway Nuclear Plant. In summary, Modification Package 02-1 010 will: 1. Prepare the ground surfaces of the designated new PAsecurity boundary and permanently erect the required double security fences and install other necessary security boundary physical hardware.

This includes required physical isolation of gratings/openings/culverts within the zone between the inner and outer new security boundary fences.2. Provide appropriate access points to the extended PA security boundary area.-3. Permanently install required area lighting and monitoring/detection/alarm systems.4. Provide for covering and surface stabilization of the new PA security boundary areas adjacent and within the inner and outer security boundary fences for acceptable water runoff, as well as for functionality of detection systems.5. Perform functional qualification of the detection and alarm systems so that proper transition to-the new permanent PA security boundary and coordinated removal of the pre-modification (defunct) security boundary fences may be accomplished.

The construction activities to extend the PA security boundary undertaken by Modification Package 02-101 0 will be performed in a site area that has been previously evaluated and determined to not be associated with cultural resources identified in "A Cultural Resources Management Plan for Residual Lands at the Union Electric Company Nuclear Power Plant, Callaway County, Missouri." 59