ML101320085

Annual Radiological Environmental Operating Report, and Independent Spent Fuel Storage Facility

ML101320085
Person / Time
Site:	San Onofre
Issue date:	05/10/2010
From:	St.Onge R Southern California Edison Co
To:	Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML101320085 (124)

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I~\j SOUTHERN CALIFORNIA Richard J. St. Onge I~ EDISON Director Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company Tech Spec Section 06.9.1.3 Tech Spec Section 5.7.1.2 May 10, 2010 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Docket Nos. 50-206, 50-361, 50-362 and 72-41 2009 Annual Radiological Environmental Operating Report San Onofre Nuclear Generating Station Units 1, 2 anda and Independent Spent Fuel Storage Facility

Dear Sir or Madam:

As required byTechnical Specification (TS) Section 06.9.1.3 of San Onofre Nuclear Generating Station (SONGS) Unit 1 Facility Operating License DPR-13, and TS Section 5.7.1.2 of Facility Operating Licenses NPF-10 and NPF-15 for SONGS Units 2 and 3, respectively, this letter transmits the 2009 Annual Radiological Environmental Operating Report (AREOR) for SONGS Units 1,2 and 3.

The AREOR covers the operation of SONGS during the calendar year 2009 and includes summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program.

In addition, the AREOR includes the results for direct radiation monitoring near the Independent Spent Fuel Storage Installation.

If you require any additional information, please contact Mr. Clay E. Williams at (949) 368-6707.

Sincerely, P.O. Box 128 San Clemente, CA 92674

Document Control Desk May 10, 2010 Enclosure cc: E. E. Collins, Regional Administrator, NRC Region IV J. E. Whitten, Region IV, San Onofre Unit 1 R. E. Lantz, NRC Region IV, San Onofre Units 2 & 3 R. Hall, NRC Project Manager, San Onofre Units 2 and 3 S. Helton, NRC Project Manager, San Onofre ISFSI G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Public Health

2009 Radiological Environmental Operating Report San Onofre Nuclear Generating Station Southern California Edison An Edison International Company Docket Nos. 50-206,50-361,50-362 License Nos. DPR-13, NPF-10, NPF-15 April 2010 An EDISON INTERNATIONAL " Compan y

TABLE OF CONTENTS Page Table of Contents......................................................................................................................................... i EXECUTIVE

SUMMARY

/ INTRODUCTION ....................................................................................... 1 Objectives ..............................................................................................................................................2 Sample Collection..................................................................................................................................2 Regulatory Limits, Guidance, and Requirements ..................................................................................2 Data Management ..................................................................................................................................4 Detection Limit Terminology ................................................................................................................5 Conclusion .............................................................................................................................................6 References..............................................................................................................................................6 APPENDIX A - Sample Type and Sampling Location .............................................................................. 7 Table A-1 REMP Sample Locations.................................................................................................8 Table A-2 Sector and Direction Designation for REMP Sample Location Map ............................13 Figure 5-1 San Onofre REMP - One Mile Radius...........................................................................14 Figure 5-2 San Onofre REMP - Two Mile Radius ..........................................................................15 Figure 5-3 San Onofre REMP - Five Mile Radius ..........................................................................16 Figure 5-4 San Onofre REMP - 30 Mile North ...............................................................................17 Figure 5-5 San Onofre REMP - 45 Mile South ...............................................................................18 APPENDIX B - Summary, Results, and Discussions of 2009 Environmental Data................................ 19 Summary ..............................................................................................................................................20 Results and Discussions of 2009 Environmental Data ........................................................................21 Figure 5-6 2009 Kelp Sample Locations .........................................................................................28 Table B-1 Summary of SONGS Related Gamma Isotopic Analysis Confirmed above MDC.......29 Table B-2 REMP Sample Analysis Summary for 2009 .................................................................31 Statistical Summary of Remp Data for 2009 .......................................................................................32 Table 1A Quarterly Gamma exposure (millirem) ........................................................................ 33 i

Table 2 Weekly Airborne Particulates - Gross Beta Activity ................................................... 34 Table 3 Weekly Radioiodine I-131 Activity ............................................................................. 35 Table 4A Quarterly Composite Airborne Particulates Gamma.................................................... 36 Table 5 Monthly Ocean Water Gamma Spectral Analysis ....................................................... 37 Table 7 Quarterly Composite Ocean Water Tritium Activity ................................................... 39 Table 9A Monthly Drinking Water Analysis ............................................................................... 40 Table 10 Semi-Annual Shoreline Sediment Gamma Spectral Analysis ..................................... 43 Table 11 Semi-Annual Ocean Bottom Sediment Gamma Spectral Analysis.............................. 44 Table 12A Semi-Annual Non-Migratory Marine Animals Analysis - Flesh ................................. 45 Table 13A Semi-Annual Local Crops Gamma Spectral Analysis ................................................. 50 Table 14 Annual Soil Analysis.................................................................................................... 53 Table 15 Semi-Annual Kelp Analysis......................................................................................... 54 APPENDIX C - Summary of Quality Control Programs......................................................................... 55 Interlaboratory Cross-Check Program .................................................................................................56 Quarterly Duplicate TLDs ...................................................................................................................57 Annual Duplicate TLDs.......................................................................................................................58 Comparison of TLD to PIC Data .........................................................................................................58 Calibration of Air Sampler Volume Meters.........................................................................................58 Table C-1 Analytics Cross-Check Program Summary ...................................................................59 APPENDIX D - Comparison of Operational to Preoperational Data and Analysis of Trends................. 67 Comparison of Operational to Preoperational Data and Analysis of Trends.......................................68 Table D - 1A Shoreline Sediments Concentration (pCi/g, wet weight) PreOperational and Operational Data SONGS Units 2/3 .............................................................................................72 Table D-1B Ocean Bottom Sediments Concentration (pCi/g, wet weight) PreOperational and Operational Data SONGS Units 2/3 .............................................................................................72 Table D-2 Marine Species Concentrations (pCi/g, wet weight) PreOperational and Operational Data SONGS Units 2/3 ....................................................................................................74 Table D-3 Soil PreOperational and Operational Data (pCi/g, wet weight) SONGS Units 2/3.......79 ii

Table D-4 Kelp PreOperational and Operational Data (pCi/g, wet weight) SONGS Units 2/3 .....79 APPENDIX E - Deviations from ODCM Sampling Requirements in 2009 ............................................ 80 Deviations from ODCM Sampling Requirements in 2009..................................................................81 Part I Terrestrial Sampling...............................................................................................................81 Part II Marine Sampling....................................................................................................................82 APPENDIX F - Land Use Census ............................................................................................................ 83 Introduction..........................................................................................................................................84 The Study Area ....................................................................................................................................84 Methodology ........................................................................................................................................84 Definitions............................................................................................................................................84 Table F-1 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet .................................87 Table F-2 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet .................................88 Table F-3 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet .................................89 APPENDIX G - Figures for 2009............................................................................................................. 90 Figure 1 Potential Radiation Exposure Pathways Leading to Man..................................................91 Figure 2A Direct Radiation Monitoring 1981 to 1999....................................................................92 Figure 2B Direct Radiation Monitoring 1995 to 2009....................................................................93 Figure 3A Monthly Average Airborne Particulates Gross Beta Activity Preoperational and Operational Data for SONGS Unit 2/3 ................................................................................................94 Figure 3B Monthly Average Airborne Particulates Gross Beta Activity SONGS Units 2 and 3 from Jan 1988 to Dec 1997..................................................................................................................95 Figure 3C Monthly Average Airborne Particulates Gross Beta Activity SONGS Units 2 and 3 Jan 1998 to Dec 2009 .................................................................................................................................96 Figure 3D Weekly Airborne Particulate Gross Beta Activity SONGS Units 2 and 3 January to December 2009 ....................................................................................................................................97 Figure 4 I-131 In Aquatic Kelp .......................................................................................................98 iii

APPENDIX H - Errata to the 2008 AREOR ............................................................................................ 99 APPENDIX I - REMP TLD's Co-located with DHS TLDs During 2008.............................................. 100 APPENDIX J - ISFSI TLD DATA......................................................................................................... 102 Table J-1 ISFSI TLD DATA .......................................................................................................105 Table J-2 REMP TLD DATA for TLDs within the EAB............................................................108 Figure 6-1 ISFSI TLDs and REMP TLDs within the EAB...........................................................111 Figure 6-2 ISFSI TLDs and Selected REMP TLDs near to the ISFSI Foundation.......................112 Figure 6A Direct Radiation Monitoring ISFSI & Select REMP TLDs - Quarterly Gamma Exposure (Mr/STD Quarter) ..............................................................................................................113 APPENDIX K - Local Drinking Water Wells ....................................................................................... 114 Figure 7-1 Drinking Water Wells ..................................................................................................116 Figure 7-2 Protected Area Wells ...................................................................................................117 iv

Executive Summary The data from the San Onofre Nuclear Generating Station (SONGS) Radiological Environmental Monitoring Program (REMP) indicate that SONGS had a negligible radiological environmental impact during 2009.

Preparation of the 2009 Annual Radiological Environmental Operating Report (AREOR) used the data reduction protocol described in NUREG/CR-4007. A meaningful analysis of data at, near, or below the detection limit must necessarily involve a consideration of the degrees of uncertainty associated with the data. The data have been summarized in the Statistical Summary of REMP Data found in Appendix B. The plant related radionuclides, including Cs-137 (cesium-137) in soil and sediment, as well as I-131 (iodine-131) in kelp, detected above the a posteriori MDC (minimum detectable concentration) are attributable to fallout from nuclear weapons testing (Cs-137) and medical administrations of radionuclides (I-131). These isotopes have been detected at indicator as well as control locations in past years. The naturally occurring radionuclides, including Be-7 (beryllium-7), K-40 (potassium-40), and Th-228 (thorium-228),

were detected in both control and indicator locations at substantially similar concentrations and are not related to the operation of SONGS. Tritium (H-3, hydrogen-3) was detected in one ocean water sample at a level below the a priori LLD. The single detection of tritium in ocean water in 2009 is attributable to the sampling being taken shortly after the planned, controlled discharge of a waste stream from SONGS. Subsequent samples did not detect tritium in ocean water.

Refer to Appendix B for a more detailed discussion. No other SONGS related radionuclides were detected in REMP samples during 2009.

INTRODUCTION SONGS consists of two pressurized water nuclear reactors housed in separate containment buildings. Unit 1 attained initial criticality June 1967, was permanently retired from service in November 1992. The removal of Unit 1 structures was completed in 2008. Unit 2 attained initial criticality in July 1982 and Unit 3 in August 1983. Both units continue to operate today.

The purpose of the REMP is to quantify ambient radiation levels in the environs of SONGS, and to identify and quantify concentrations of radioactivity in various environmental media in the vicinity of SONGS that have a potential radiation exposure pathway to a member of the general public. Thermoluminescent dosimeters (TLDs) are used to measure direct radiation levels.

Sampled environmental media include soil, shoreline sediment (beach sand), air (particulate &

iodine), local crops, non-migratory marine species, kelp, drinking water, ocean water, and ocean bottom sediments. Each of the samples was analyzed for both naturally-occurring and SONGS-related radionuclides.

The REMP is conducted in accordance with Section 5.0 of the SONGS Offsite Dose Calculation Manual (ODCM).

To conform with 10 CFR Part 50, Appendix I, Section IV B.2, data on measurable levels of radiation and radioactive materials in the environment have been compared against predicted (calculated) values to evaluate the relationship between quantities of radioactive material 1

released in effluents and resultant radiation doses to individuals from principal pathways of exposure. Refer to Appendix B for a correlation of effluent to environmental concentrations.

A land use census was performed in 2009 to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the monitoring program are made if required by the results of this census. Appendix F of the report identifies changes to the census and the resultant dose increase, if any, to individuals from principal pathways of exposures in conformance with 10CFR Part 50, Appendix I, Section IV. B.3.

OBJECTIVES

1. To fulfill the radiological environmental monitoring requirements of the ODCM

2. To detect any significant increase in the concentration of radionuclides in critical pathways.

3. To detect any significant change in ambient gamma radiation levels.

4. To verify that the operation of SONGS Units 2 and 3 has a negligible effect on the health and safety of the public and the environment.

SAMPLE COLLECTION Samples of various environmental media were obtained to meet the stated objectives. The selection of sample types was based on established critical pathways for the transfer of radionuclides through the environment to individuals, and the evaluation of data during the operational phase. Sampling locations were selected with consideration given to site meteorology, local demography, and land uses. Refer to Appendix A for a complete list of REMP sample locations as described in Table 5-4 of the ODCM.

Sampling locations were divided into two classes, indicator and control. Control stations were at locations considered to be unaffected by SONGS operations. All others are considered indicator locations and may be potentially affected by SONGS operations.

REGULATORY LIMITS, GUIDANCE, AND REQUIREMENTS

• 10CFR50 The Code of Federal Regulations Title 10, Part 50, Appendix I.

• 40CFR190 The Environmental Protection Agency (EPA) has established environmental radiation protection standards for nuclear power plants in 40CFR190. The standards for normal operation recommend that the dose from all discharges of radioactivity should not exceed 25 mrem/yr. These limits are applicable to the sum of both liquid and gaseous effluents 2

and direct radiation. The environmental doses calculated at SONGS are a small fraction of the dose limits established by the EPA.

• 10CFR20 10CFR20, Appendix B, Table II, Effluent Concentrations and Appendix C, Concentration for Release to Sewerage Guidance:

• Regulatory Guide 4.1 Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants, 1975

• Regulatory Guide 4.2 Preparation of Environmental Reports for Nuclear Power Stations, 1976

• Regulatory Guide 4.8 Environmental Technical Specifications for Nuclear Power Plants, 1975

• Regulatory Guide 4.13 Performance, Testing, and Procedural Specification for Thermoluminescent Dosimetry:

Environmental Applications, 1977

• NUREG-0133 Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants

• Regulatory Guide 1.109 Calculation of Annual Doses to Man from Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR Part 50, Appendix I, 1977

• NUREG-1301 Offsite Dose Calculations Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors, Generic Letter 89-01, Supplement No. 1, 1991

• ANSI N545 (TLD's)

American National Standard Performance, Testing, And Procedural Specifications for Thermoluminesence Dosimetry (Environmental Application), 1975 3

• Regulatory Guide 4.15 Quality Assurance for Radiological Monitoring Programs (Normal Operations) -

Effluent Streams and the Environment, 1979

• NUREG 1576 MARLAP Multi-agency Radiological Laboratory Analytical Protocols

• NUREG/CR-4007 Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements, 1984 DATA MANAGEMENT The tabulated means, ranges and standard deviations presented in Appendix B were calculated following the standard format specified in Regulatory Guide 4.8, the Radiological Assessment Branch Technical Position, Revision 1, 1979, and in accordance with the protocol outlined in NUREG/CR-4007. A custom data management software package was used to perform the statistical analysis and tabulation of the data.

The REMP data are reviewed for accuracy and comparison against NRC reporting levels, and then entered into the REMP database. One of the REMP menus flags measurements exceeding the administrative levels (10% of the NRC reporting levels) established by Southern California Edison (SCE). The a posteriori MDC is compared to the maximum value for the a priori Lower Limit of Detection (LLD) specified in the ODCM. This ensures that regulatory limits for the maximum LLD are met.

The impact of SONGS on the surrounding environment was assessed through a series of analyses. These analyses included: data reduction, comparisons of indicator to control locations, and summary (Appendix B); comparison of operational to preoperational environmental data (Appendix D); summary of deviations from sampling requirements and corrective actions taken (Appendix E); and the results of the 2009 Land Use Census (Appendix F).

All Radiological Environmental Monitoring activities for San Onofre are assessed in accordance with Quality Assurance requirements as defined in Regulatory Guide 4.15. The Contracted Environmental Analysis Laboratory (CEAL) participated in an interlaboratory comparison program in partial fulfillment of the quality assurance requirements for environmental monitoring. The CEAL participated in cross check programs which meet the intent of Reg.

Guide 4.15. Refer to Appendix C.

4

DETECTION LIMIT TERMINOLOGY This report utilizes three distinct terms to describe the concept of lower limit of detection at various detection confidence levels. The terms are briefly defined below. For a more thorough discussion, the reader should refer to NUREG/CR-4007.

Critical level - Defined as 1.64 sigma. For a sufficiently large database of [isotopically analyzed] sample results, with the true activity being equal to zero, approximately 5% of the results are expected to be above the critical level.

Lower Limit of Detection (LLD) - The LLD is the a priori (before the fact) lower limit of detection. This value is calculated for each isotope and every matrix based on typical or expected values of decay time, sample size, counter efficiency, etc. These values are listed in the ODCM and represent the maximum permissible value for the lower limit of detection for specified sample media.

Minimum Detectable Concentration (MDC) - The MDC is the a posteriori (after the fact) lower limit of detection based on actual decay time, measured sample size, counting efficiency as determined by recent calibration, etc. The MDC is compared to the LLD to verify that the measurement met the ODCM requirements for the maximum value of the LLD for the listed analytes. Values above the MDC are presumed to represent detected activity at the 95%

detection confidence level. Refer to NUREG 1576.

The 2009 SONGS REMP data required by the ODCM have been summarized in the Statistical Summary of REMP Data found in Appendix B.

5

CONCLUSION Levels of radioactivity in environmental media are a function of several factors including: site release rates; meteorology; number, location, size and date of nuclear weapons tests; seasonal variability of fallout; soil conditions; local terrain and variability in the natural environment.

Radiological environmental data collected throughout 2009 have been evaluated to determine the impact, if any, of San Onofre operations on the surrounding environment. To accomplish this, several methods of evaluation were employed, namely:

1. Compilation and verification of all data, as well as a determination of those data considered to be significantly greater than background levels.

2. Correlation of effluent concentrations to concentrations in the environment. Refer to Appendix B.

3. Examination of time-dependent variations of pertinent radioisotopes in selected environmental media throughout the year at both indicator and control locations.

4. Comparison of radioactivity in various media in 2009 against the levels observed in pre-operational years.

5. Historical trending of radionuclides in various media during operational years.

In comparing these findings to the conservatively-defined limits of the facility operating licenses, it is concluded that the radiological environmental impact of the operation of SONGS through 2009 has been negligible, and the resulting dose to a member of the general public is negligible.

REFERENCES

1. 10CFR50, Appendix I

2. Land Use Census for SONGS Units l, 2 and 3 Radiological Environmental Monitoring Program, October 2008.

3. SONGS Offsite Dose Calculation Manual (ODCM) Revision 1, Section 5.0, 2008.

4. SONGS Radiological Monitoring (RM) Procedures: SO123-RM-1 (SO123-IX-1.10).

5. L. Currie. 1968 Limits for the Qualitative Detection and Quantitative Determination -

Application to Radiochemistry, Analytical Chemistry, vol. 40 pp. 586-593 6

APPENDIX A SAMPLE TYPE AND SAMPLING LOCATION 7

TABLE A-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SAMPLE LOCATIONS TYPE OF SAMPLE AND SAMPLING LOCATION DISTANCE* DIRECTION*

(Omitted sample numbers are due to program modifications) (miles) (Sector)

Direct Radiation 1 City of San Clemente (Former SDG&E Offices) 5.7 NW 2 Camp San Mateo - MCB 3.6 N 3 Camp San Onofre - MCB 2.8 NE 4 Camp Horno - MCB 4.4 E 6 Old Route 101 (East-Southeast) 3.0 ESE 8 Noncommissioned Officers' Beach Club 1.4 NW 10 Bluff (Adjacent to PIC #1) 0.7 WNW 11 Former Visitors' Center 0.4 ** NW 12 South Edge of Switchyard 0.2 ** E 13 Southeast Site Boundary (Bluff) 0.4 ** ESE 15 Southeast Site Boundary (Office Building) 0.1 ** SSE 16 East Southeast Site Boundary 0.4 ** ESE 19 San Clemente Highlands 4.9 NNW 22 Former US Coast Guard Station - San Mateo Point 2.7 WNW 23 SDG&E Service Center Yard 8.1 NW 31 Aurora Park - Mission Viejo (Control) 18.6 NNW 33 Camp Talega - MCB 5.9 N 34 San Onofre School - MCB 1.9 NW 35 Range 312 - MCB 4.8 NNE 36 Range 208C - MCB 4.1 NE 38 San Onofre State Beach Park 3.4 SE 40 SCE Training Center - Mesa (Adjacent to PIC #3) 0.7 NNW 41 Old Route 101 - East 0.3 ** E 44 Fallbrook Fire Station 17.7 E

• Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM Rev. 2.

Direction determined from degrees true north.

• • Distances are within the Units 2/3 CAB/EAB (Controlled Area Boundary/Exclusion Area Boundary)

• • • Soil samples are not required by Technical Specifications.

• • • • Kelp samples are not required by Technical Specifications.

MCB Marine Corps Base Camp Pendleton PIC Pressurized Ion Chamber 8

TABLE A-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SAMPLE LOCATIONS TYPE OF SAMPLE AND SAMPLING LOCATION DISTANCE* DIRECTION*

(Omitted sample numbers are due to program modifications) (miles) (Sector)

Direct Radiation (Continued) 46 San Onofre State Beach Park 1.0 SE 47 Camp Las Flores - MCB 8.6 SE 49 Camp Chappo - MCB 12.9 ESE 50 Oceanside Fire Station (Control) 15.6 SE 53 San Diego County Operations Center 44.2 SE 54 Escondido Fire Station 31.8 ESE 55 San Onofre State Beach (U1 West) 0.2 ** W 56 San Onofre State Beach (U1 West) 0.2 ** W 57 San Onofre State Beach (Unit 2) 0.1 ** WSW 58 San Onofre State Beach (Unit 3) 0.1 ** S 59 SONGS Meteorological Tower 0.3 ** WNW 61 Mesa - East Boundary (Adjacent to PIC #4) 0.7 N 62 MCB - Camp Pendleton (Adjacent to PIC #5) 0.7 NNE 63 MCB - Camp Pendleton (Adjacent to PIC #6) 0.6 NE 64 MCB - Camp Pendleton (Adjacent to PIC #7) 0.6 ENE 65 MCB - Camp Pendleton (Adjacent to PIC #8) 0.7 E 66 San Onofre State Beach (Adjacent to PIC #9) 0.6 ESE 67 Former SONGS Evaporation Pond (Adjacent to PIC #2) 0.6 NW 68 Range 210C - MCB 4.4 ENE 73 South Yard Facility 0.4 ** ESE 74 Oceanside City Hall (Backup Control) 15.6 SE 75 Gate 25 MCB 4.6 SE 76 El Camino Real Mobil Station 4.6 NW 77 Area 62 Heavy Lift Pad 4.2 N 78 Sheep Valley 4.4 ESE

• Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM Rev. 2.

Direction determined from degrees true north.

• • Distances are within the Units 2/3 CAB/EAB (Controlled Area Boundary/Exclusion Area Boundary)

• • • Soil samples are not required by Technical Specifications.

• • • • Kelp samples are not required by Technical Specifications.

MCB Marine Corps Base Camp Pendleton PIC Pressurized Ion Chamber 9

TABLE A-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SAMPLE LOCATIONS TYPE OF SAMPLE AND SAMPLING LOCATION DISTANCE* DIRECTION*

(Omitted sample numbers are due to program modifications) (miles) (Sector)

Airborne 1 City of San Clemente (City Hall) 5.1 NW 7 AWS Roof 0.18 ** NW 9 State Beach Park 0.6 ESE 10 Bluff 0.7 WNW 11 Mesa EOF 0.7 NNW 12 Former SONGS Evaporation Pond 0.6 NW 13 Marine Corp Base (Camp Pendleton East) 0.7 E 15 Oceanside City Hall (Control) 15.6 SE 16 San Luis Rey Substation (Control)1 16.7 SE Soil Samples ***

1 Camp San Onofre 2.8 NE 2 Old Route 101 - East Southeast 3.0 ESE 3 Basilone Road / I-5 Freeway Off ramp 2.0 NW 5 Former Visitor=s Center 0.4 ** NW 7 Prince of Peace Abbey (Control) 15 SE 1 Air Sampler # 16 will replace Air Sampler #15 as the control air sampler during the week of December 26, 2010

• Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM Rev. 2.

Direction determined from degrees true north.

• • Distances are within the Units 2/3 CAB/EAB (Controlled Area Boundary/Exclusion Area Boundary)

• • • Soil samples are not required by Technical Specifications.

• • • • Kelp samples are not required by Technical Specifications.

MCB Marine Corps Base Camp Pendleton PIC Pressurized Ion Chamber 10

TABLE A-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SAMPLE LOCATIONS TYPE OF SAMPLE AND SAMPLING LOCATION DISTANCE* DIRECTION*

(Omitted sample numbers are due to program modifications) (miles) (Sector)

Ocean Water A Station Discharge Outfall - Unit 1 0.6 SW B Outfall - Unit 2 1.5 SW C Outfall - Unit 3 1.2 SSW D Newport Beach (Control) 30.0 NW 51 Unit 2 Conduit (not listed in the ODCM) 0.1 SW 52 Unit 3 Conduit (not listed in the ODCM) 0.1 SSW Drinking Water 4 Camp Pendleton Drinking Water Reservoir 2.0 NNW 5 Oceanside City Hall (Control) 15.6 SE Shoreline Sediment (Beach Sand) 1 San Onofre State Beach (SE) 0.6 SE 2 San Onofre Surfing Beach 0.8 WNW 3 San Onofre State Beach (SE) 3.5 SE 4 Newport Beach North End (Control) 29.2 NW Local Crops 2 Oceanside (Control) 15-25 SE to ESE 4 San Clemente Residence (Ola Vista) with Garden 4.4 NW 6 SONGS Garden 0.4 NNW Non-Migratory Marine Animals A Unit 1 Outfall 0.9 WSW B Units 2/3 Outfall 1.5 SSW C Laguna Beach (Control) 15 to 150 WNW to NW

• Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM Rev.2.

Direction determined from degrees true north.

• • • Soil samples are not required by Technical Specifications.

• • • • Kelp samples are not required by Technical Specifications.

MCB Marine Corps Base Camp Pendleton PIC Pressurized Ion Chamber 11

TABLE A-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SAMPLE LOCATIONS TYPE OF SAMPLE AND SAMPLING LOCATION DISTANCE* DIRECTION*

(Omitted sample numbers are due to program modifications) (miles) (Sector)

Kelp ****

A San Onofre Kelp Bed 1.5 S B San Mateo Kelp Bed 3.8 WNW C Barn Kelp Bed 6.3 SSE E Salt Creek (Control) 11 to 13 WNW to NW Ocean Bottom Sediments B Unit 1 Outfall (0.6 mile West) 0.8 SSW C Unit 2 Outfall 1.6 SW D Unit 3 Outfall 1.2 SSW E Laguna Beach (Control) 17-19 NW F SONGS Upcoast 0.9 WSW 51 Unit 2 Conduit (not listed in the ODCM) 0.1 SW 52 Unit 3 Conduit (not listed in the ODCM) 0.1 SSW

• Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM Rev.2.

Direction determined from degrees true north.

• • • Soil samples are not required by Technical Specifications.

• • • • Kelp samples are not required by Technical Specifications.

MCB Marine Corps Base Camp Pendleton PIC Pressurized Ion Chamber 12

TABLE A-2 SECTOR AND DIRECTION DESIGNATION FOR REMP SAMPLE LOCATION MAP DEGREES TRUE NORTH FROM SONGS 2 AND 3 MIDPOINT NOMENCLATURE Sector Center Sector 22.50 Limit Line Limit Sector Direction 348.75 0 & 360 11.25 A N 11.25 22.5 33.75 B NNE 33.75 45.0 56.25 C NE 56.25 67.5 78.75 D ENE 78.75 90.0 101.25 E E 101.25 112.0 123.75 F ESE 123.75 135.0 146.25 G SE 146.25 157.0 168.75 H SSE 168.75 180.0 191.25 J S 191.25 202.5 213.75 K SSW 213.75 225.0 236.25 L SW 236.25 247.5 258.75 M WSW 258.75 270.0 281.25 N W 281.25 292.5 303.75 P WNW 303.75 315.0 326.25 Q NW 326.25 337.5 348.75 R NNW 13

EL CA MIN OR EAL Sector A Sector R N

0

§

¨ c

TLD 8 NNW 5 Sector Q Sector B BE NW AC H

CL NNE TLD 61 0 UB RD Air Sampler 11 c

& TLD 40 ¢ TLD 62 0

c Sector C NE PACIFIC Sector P OCEAN WNW SAN ONOFRE Crop STATE BEACH TLD 63 Air Sampler 12 Sample 6 0 c

& TLD 67 ¢ Shoreline Sediment Sample 2 G

¢ Sector D Air Sampler 10 Soil Sample 5 X0 c ENE

& TLD 10 TLD 11 TLD 64 0

c Figure 5-1 1-mile TLD 59 0 c ¢ Air Sampler 7 San Onofre REMP radius TLD 55 0 c

One-Mile Radius Sector N TLD 56 0 c

0 c TLD 41 Sector E Air Sampler 13 Units 2/3 Midpoint W 0 c TLD 12 E TLD 57 0 c & TLD 65

¢ Air Sampler ¢ 0

c Crop TLD 58 0 c TLD 15 0

c TLD 73

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Non-Migratory Marine Animals (NMMA) 0 c TLD 16 2

d Ocean Bottom Sediment (OBS) TLD 13 Air Sampler 9 m

! Ocean Water 0 c

¢ & TLD 66 G Shoreline Sediment Sector F X Soil ESE Sector M Shoreline G 0

c TLD Sediment Freeway WSW Sample 1 Major Road Local Street Railroad TLD 46

µ Sector L Sector G 0 c

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APPENDIX B

SUMMARY

, RESULTS, AND DISCUSSIONS OF 2009 ENVIRONMENTAL DATA 19

SUMMARY

To assess the changes or trends in the radioactivity level in the environment over the past year, the data from January 2009 to December 2009 were evaluated. The 2009 REMP data were evaluated according to the criteria described in NUREG/CR-4007 and with the methodology described by Currie (1968).* The REMP data above the critical level (1.64 times one sigma) for selected radionuclides, were reduced and tabulated in the Statistical Summary of REMP Data in accordance with the format specified in Reg. Guide 4.8. The 2009 SONGS REMP database, when examined in accordance with the Currie data reduction protocol, leads to the conclusion that SONGS had no statistically significant radiological environmental impact. A summary of the type and number of REMP samples obtained in 2009 appears in Table B-2.

As noted above, the SONGS REMP data base behaves substantially similar to a data base with values statistically indistinguishable from zero for station related isotopes. The exceptions, summarized in Table B-1, include isotopically analyzed samples with station related activity reported above the a posteriori MDC. All sample values were significantly less than the NRC reporting levels. I-131 was detected in kelp, tritium was detected in ocean water, and Cs-137 was detected in soil. These radionuclides have been detected in control as well as indicator locations in previous years. Cs-137 is commonly detected in environmental sediment samples because of fallout from weapons testing. Cs-137 has been intermittently detected in the indicator and in the control soil samples in past years and no correlation between Cs-137 level in soil and proximity to the plant has been observed. The data strongly suggest that the low level Cs-137 in certain soil samples is due to fallout from nuclear weapons testing and from Chernobyl. We conclude that the low level Cs-137 in soil is not due to the operation of SONGS. I-131 is a medically administered radionuclide which is often detected in sewage plant outfalls The I-131 detected in the kelp samples is attributable to sewage plant discharges external to SONGS.

Tritium in one ocean water indicator sample was detected at a level less than the a priori LLD (lower limit of detection) but greater than the lower, sample specific, a posteriori MDC (minimum detectable concentration). The detected ocean water tritium is attributable to the operation of SONGS. We conclude that SONGS had a negligible radiological environmental impact during 2009.

Historical trending of data near and below the detection limits is necessarily limited. The concentration of radionuclides in the environs of SONGS has trended downward since the early to mid 1980s. In the past decade only a few REMP analysis results have been above the detection limit. These isotopes are detected in control as well as indicator locations and there are known sources for these radionuclides external to SONGS. The overall trend of the REMP data at SONGS is de minimis levels of anthropogenic radioactivity with occasional samples showing radioactivity above the a posteriori MDC.

• L. Currie. 1968 Limits for the Qualitative Detection and Quantitative Determination - Application to Radiochemistry, Analytical Chemistry, vol. 40 pp. 586-593 20

RESULTS AND DISCUSSIONS OF 2009 ENVIRONMENTAL DATA A. Direct Radiation The purpose of this program element was to measure the quarterly environmental gamma radiation in the vicinity of SONGS. To accomplish this task, calcium sulfate (CaSO4) thermoluminescent dosimeters (TLDs) were placed at 38 indicator and 11 control locations.

They were collected and analyzed quarterly in accordance with ANSI-N545 standards. TLDs within five miles of SONGS were considered indicator locations. TLDs located greater than five miles from SONGS are considered control locations. The indicator locations are selected as inner and outer rings as required by the ODCM. Additional TLDs are placed at locations of interest such as schools and hospitals.

Six laboratory control TLDs were analyzed quarterly. TLD numbers 17, 18, and 60 are used for background dose normalization. TLDs #A and #B are used to compensate for transit dose. A fader TLD is used to evaluate for the time and temperature dependent "fade" that may affect dosimeter data.

After the samples were analyzed, the measured doses were corrected for pre and post field exposure times. The average indicator location dose was 17.26 mR with a range of 10.65 to 24.94 mR. The average control location dose was 16.47 mR with a range of 12.88 to 20.11 mR.

The routine 2009 REMP TLD data has been grouped into four categories based on distance from SONGS for the purposes of trending any correlation between distance from SONGS and total annual dose.

2009 REMP TLD data (Average Dose vs. Distance from SONGS)

Average Quarterly Dose in mR TLDs 0.5 miles from SONGS 19.10 TLDs > 0.5 miles AND 1.0 mile from SONGS 15.24 TLDs > 1.0 mile AND 5.0 miles from SONGS 16.97 TLDs > 5 miles from SONGS (Control TLDs) 16.47 Statistically, the control and indicator doses beyond the EAB (Exclusion Area Boundary)are the same value. The routine indicator location at the South Yard Facility (0.4 miles ESE from the Units 2/3 midpoint) had the highest TLD average in 2009. The operation of SONGS had no impact beyond the EAB as measured by this sample medium.

Figure 2A compares environmental radiation levels of indicator and control locations for the operational year 2009 and for previous years. This figure shows the close correlation between the control and indicator location TLD dose data.

21

Quality Control Duplicate Direct Radiation Samples Duplicate QC TLDs were installed adjacent to TLD #66 and TLD #67. Refer to Appendix C for results. These TLDs were not required by the ODCM and are not included in the Statistical Summary of REMP Data.

ISFSI Direct Radiation Samples ISFSI (Independent Spent Fuel Storage Installation) TLDs were deployed in the vicinity of the ISFSI. Data from these TLDs have not been included in the statistical summary of REMP data since these TLDs are not required by the ODCM. The ISFSI data are listed and discussed in Appendix J.

B. Airborne Particulate, Iodine, and Composite Isotopic Analyses Air particulate samples were collected on a weekly basis from eight indicator locations and from one control location. The samples were analyzed for gross beta activity, I-131, and composited quarterly for gamma isotopic analysis. Sample locations were selected according to the requirements of the ODCM.

Gross beta analysis is a measure of total radioactivity of beta-emitting radionuclides in a sample.

Beta radiation is emitted by many radionuclides, but beta decay gives a continuous energy spectrum rather than the discrete energy lines or peaks associated with gamma radiation. Gross beta measurements only indicate whether the sample contains normal or abnormal concentrations of beta-emitting radionuclides and does not identify specific radionuclides. Gross beta measurement data serves as a screening tool to determine if further analysis is required.

All gross beta activity analysis results were above the a posteriori MDC. The concentration of gross beta activity in the samples collected from the indicator locations ranged from 0.0169 to 0.0862 pCi/m3, averaging 0.0438 pCi/m3 of air. The concentrations of gross beta activity in the samples from the control locations ranged from 0.0225 to 0.0777 pCi/m3, averaging 0.0441 pCi/m3 of air. Figure 3D shows the variation in gross beta activity level in 2009 at different locations. This graph show a close correlation between the indicator and control location data.

Per the requirements of the ODCM, Section 5, Table 5.1, an assessment was performed to determine whether the gross beta activity of the indicators exceeded 10 times the background (control location #15). The results showed that indicator locations maximum gross beta activity in air in 2009 was 0.0862 pCi/m3 and the 2008 control location average was 0.0416 pCi/m3. No action was taken since no indicator location value exceeded ten times the annual average gross beta activity of the control location data from the previous year.

All samples analyzed for I-131 were less than the a posteriori MDC and all I-131 samples were less than the a priori lower limit of detection (LLD). The airborne indicator and control I-131 REMP samples taken in 2009 at SONGS were statistically indistinguishable from zero.

No samples yielded station related isotopic results confirmed above the a posteriori MDC.

Quarterly composite gamma spectral analysis analyses yielded naturally occurring beryllium-7 (Be-7) above the a posteriori MDC.

22

We conclude that the operation of SONGS had no impact on the environment as measured by this sample medium.

C. Ocean Water Monthly ocean water samples were collected from three indicator locations in the vicinity of each station discharge and from the control location at Newport Beach. The samples were analyzed for naturally-occurring and SONGS-related gamma-emitting radionuclides. Quarterly composite ocean water samples were analyzed for tritium according to ODCM requirements.

Throughout 2009, only naturally occurring radionuclides were detected in the monthly gamma spectral analyses of ocean water. Monthly ocean water samples were also analyzed for tritium, consistent with the State of California Department of Public Health (DPH) split sample program.

The sample taken in October 2009 near the Unit 2 diffusers represents surface water in the vicinity of the Unit 2 diffuser discharge plume. The October 2009 station B, Unit 2 Outfall, indicator ocean water tritium analysis results were below the a priori LLD, but above the a posteriori MDC. The concentration of H-3 (tritium) measured in ocean water was consistent with a calculated value based on the level of radioactivity in a planned, controlled discharge of a waste stream from SONGS approximately three hours before the sample was taken and on the known mixing conditions. The October 2009 station B H-3 sample result was 613 pCi/l with an MDC of 425 pCi/l. The California Department of Public Healths analysis of the October 2009 station B split sample yielded a sample result of 387 pCi/l H-3 with an MDA (Minimum Detectable Activity) of 238 pCi/l. The amount of H-3 detected in ocean water is well below all regulatory limits. Because no drinking water pathway exists at SONGS, the public dose consequence is negligible. The remaining 2009 monthly DPH and SONGS ocean water tritium analysis results were less than the a posteriori MDC.

Naturally occurring potassium-40 (K-40) was detected in all ocean water samples obtained in 2009. Excluding naturally occurring radionuclides, the ocean water gamma isotopic database is statistically indistinguishable from a database with zero activity.

The data indicate that the operation of SONGS had a negligible impact on the environment as measured by this sample medium.Monthly ocean water samples were collected from three indicator locations in the vicinity of each station discharge and from the control location at Newport Beach. The samples were analyzed for naturally-occurring and SONGS-related gamma-emitting radionuclides. Quarterly composite ocean water samples were analyzed for tritium according to ODCM requirements.

D. Drinking Water In 2009, drinking water samples were collected on a monthly basis from one indicator location and from the Oceanside control location. Samples were analyzed for tritium, gross beta, and naturally-occurring and SONGS-related gamma emitting radionuclides. There is no drinking water pathway for liquid effluent at SONGS.

23

No station related radionuclides were detected in drinking water during 2009. The gross beta activity is due to naturally occurring radionuclides. The drinking water gamma isotopic database is statistically indistinguishable from a database with zero activity. The operation of SONGS had no impact on this sample medium.

E. Shoreline Sediment (Beach Sand)

Beach sand was collected semiannually in 2009 from three indicator locations and from a control location situated in Newport Beach. After collection, the samples were analyzed for plant-related and naturally-occurring radionuclides. Naturally occurring K-40 and thorium-228 (Th-228) were detected in all samples. No plant related radionuclides were reported above the a posteriori MDC. The operation of SONGS had no impact on the environment as measured by this sample medium.

F. Ocean Bottom Sediments Ocean bottom sediments were collected in the vicinity of each of the three SONGS discharge locations and at the Newport Beach control location. The samples were analyzed by gamma-spectral analysis for naturally-occurring and station-related radionuclides. Naturally occurring K-40 and Th-228 were detected in ocean bottom sediment samples collected during 2009.

Four non-ODCM ocean bottom sediment samples were obtained from two locations, Unit 2 outfall conduit and Unit 3 outfall conduit. The conduit samples were collected to measure the radiological environmental effect potentially resulting from the minor conduit leakage. During 2009, all of the conduit sample analysis results were below the MDC for station related radionuclides.

We conclude that the operation of SONGS had no measurable impact on the environment as measured by this sample medium.

G. Non-Migratory Marine Species (Flesh)

Species of adult fish, crustacea and mollusks, were collected on a semi-annual basis at the SONGS Unit l outfall, the SONGS Units 2/3 outfall and from Laguna Beach control location.

The flesh portion of each sample type was analyzed for gamma-emitting station-related and naturally occurring radionuclides. The results were subsequently reported to SCE in terms of wet sample weights. Because results based on a wet sample weight are most useful for calculating doses, the results of sample analyses are summarized in terms of "as received" wet weights. No plant related radionuclides were detected above the a posteriori MDC.

Naturally-occurring K-40 was detected in most marine species samples collected during 2009.

No plant related isotopes were reported above the a posteriori MDC. The operation of SONGS had no impact on the environment as measured by this sample medium. The potential dose to members of the public from consumption of marine species near SONGS is negligible.

24

H. Local Crops Fleshy and leafy crops were collected semiannually in 2009 from the SONGS garden and from the control location 21 miles from SONGS Units 2/3 midpoint in sector F. The crop samples were analyzed quantitatively for naturally occuring and plant related radionuclides. Only naturally occurring radionuclides were detected. SONGS had no measurable impact on this sample medium.

I. Soil To determine if there is evidence of a build-up of radionuclides in the land near SONGS, indicator soil samples were collected from the East Site Boundary (Former Visitor's center), Old Route 101, Basilone Road, and Camp San Onofre. A control sample was obtained from Oceanside. Surface soil was collected from all indicator and control locations at the depth of 3 inches. The sampling protocol is consistent with the procedure described in HASL-300. Soil sampling is not required by the ODCM.

Soil samples were analyzed for naturally-occurring and SONGS-related gamma-emitting radionuclides using gamma spectral analysis. All 2009 soil samples yielded naturally occurring K-40 and Th-228. Cs-137 was detected in two indicator samples, as well as the control sample.

Cs-137 is often detected in environmental sediment samples and the presence of Cs-137 is most likely related to nuclear weapons testing fallout.

Cs-137 and strontium-90 (Sr-90) were detected in soil profile analyses conducted in previous years. These radionuclides are mostly due to the nuclear weapons testing fallout depositing on soil and retention of these radionuclides due to their long half lives. The presence of Cs-137 in the indicator and the control locations in previous years supports the conclusion that the major source of this radionuclide is fallout deposition. During 2009, the operation of SONGS had a negligible impact on the environment as measured by this sample medium.

J. Kelp Sampling Kelp was collected in April and October of 2009 from the San Onofre kelp beds, San Mateo kelp bed, Barn kelp bed, the Dana Point Kelp Bed, the Capistrano Beach Reef, the San Clemente Pier, the Wheeler North Artificial Reef, and from the Salt Creek control location. Upon collection, the samples were analyzed by gamma-spectral analysis for naturally-occurring and Station-related radionuclides. The radionuclides detected in 2009 included K-40 and I-131. K-40 is naturally occurring and not related to the operation of SONGS. I-131 was detected in all sixteen kelp samples collected during 2009 and is most likely attributable to the San Juan Sewage Plant effluents.

I-131 has been detected at indicator and control locations in previous years. The northern control locations are too far away and in the predominantly upstream current direction for the I-131 activity to be attributable to SONGS. The I-131 activity in kelp data, graphically presented in Figure 4, shows a relatively close correlation between indicator and control locations over a 25 year period - further supporting the assessment that the likely source for this radionuclide is external to SONGS. Refer to Figure 5-6 for the relative location of the kelp beds, the San Juan Sewage Plant outfall, and the SONGS outfalls.

25

K. Deer Sampling Deer meat and bone samples were collected in 2009 because locally harvested deer meat is a potential pathway to humans. Road kill deer were sampled in accordance with a California Fish and Game scientific take permit issued to the Camp Pendleton Game Warden. The 2009 analysis results were less than the a posteriori MDC (Minimum Detectable Concentration) for SONGS related radionuclides. The deer meat and bone data collected to date are consistent with the activity attributable to fallout. Effects from the operation of SONGS were not detected in this sample media.

L. Correlation of Effluent Concentrations to Concentrations in the Environment In accordance with 10 CFR 50 Appendix I, IV.b.2 data on measurable levels of radiation and radioactive materials in the environment have been evaluated to determine the relationship between quantities of radioactive material released in effluents and resultant radiation doses to individuals from principal pathways of exposure.

The REMP soil Cs-137 levels in the control and indicator samples are statistically equal which leads to the conclusion that Cs-137 in soil is attributable to residual fallout from external anthropogenic factors such as nuclear weapons testing and Chernobyl. The predicted concentration for Cs-137 in soil (based on effluent data reported in the 2008 SONGS Annual Radioactive Effluent Release Report) is about 2 to 3 orders of magnitude lower than the measured concentration of Cs-137 in soil. The effluent based correlation calculation indicates that even if there were no Cs-137 in soil from sources external to SONGS, the Cs-137 concentration in soil attributable to the operation of SONGS would be undetectable and the resultant doses to individuals would be negligible.

Data from 2009 continue to support the historical conclusion that the measured concentration of I-131 in kelp is not increasing near SONGS, and is not statistically higher around SONGS than it is at the control locations. I-131 in kelp is due to the release of medical administrations to the ocean from sewage treatment facilities. The data showing that environmental concentrations are not statistically higher around SONGS than at the control locations are consistent with the low levels of radio-iodine released during 2009. The effluent based correlation calculation indicates that I-131 activity in kelp attributable to the operation of SONGS would be undetectable and the resultant doses to individuals would be negligible.

The control and indicator samples of deer meat and bone samples collected during 2009 are statistically equal and all less than the a posteriori MDC for SONGS related radionuclides. This data is consistent with the low levels of Sr-90 and Cs-137 released from SONGS. The evaluation indicates that Cs-137 activity in deer meat attributable to the operation of SONGS would be undetectable and the resultant doses to individuals would be negligible.

26

The collection of an ocean water sample within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of a batch release from SONGS caused the October 2009 Station B ocean water tritium sample tritium analysis to be > a posteriori MDC. Unique sampling conditions (collection closely timed with a release) and the variability of the local current conditions may have led to detectable concentrations of tritium in these samples and would be expected. The remaining samples show no detectable concentration of tritium and demonstrate that environmental concentrations are consistent with the low levels of tritium released during 2009. The evaluation indicates that tritium activity in ocean water attributable to the operation of SONGS would result in negligible doses to individuals.

27

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Survey and Mapping Section.

TABLE B-1 Summary of SONGS related Gamma Isotopic Analyses confirmed above MDC Sample Media & location Radionuclide Sample Value MDC (a posteriori)

Aquatic Kelp San Onofre Kelp Bed I-131 (92 +/- 11) E-3 pCi/g 7 E-3 pCi/g Station A 20APR09 Aquatic Kelp San Mateo Kelp Bed I-131 (78 +/- 10) E-3 pCi/g 8 E-3 pCi/g Station B 20APR09 Aquatic Kelp Barn Kelp Bed I-131 (74 +/- 9) E - 3 pCi/g 7 E-3 pCi/g Station C 20APR09 Aquatic Kelp Salt Creek I-131 (113 +/- 13) E-3 pCi/g 8 E-3 pCi/g Station E 20APR09 Aquatic Kelp Dana Point Kelp Bed I-131 (114 +/- 11) E-3 pCi/g 7 E-3 pCi/g Station F 20APR09 Aquatic Kelp Capistrano Beach Reef I-131 (110 +/- 11) E-3 pCi/g 6 E-3 pCi/g Station G 20APR09 Aquatic Kelp San Clemente Pier I-131 (89 +/- 11) E-3 pCi/g 9 E-3 pCi/g Station H 20APR09 Aquatic Kelp Wheeler North Artificial Reef I-131 (152 +/- 14) E-3 pCi/g 7 E-3 pCi/g Station I 20APR09 Soil Camp San Onofre Cs-137 (51 +/- 39) E-3 pCi/g 44 E-3 pCi/g Location # 1 21SEP09 Soil Old El Camino Real Cs-137 (393 +/- 51) E-3 pCi/g 32 E-3 pCi/g Location #2 21SEP09 Soil Prince of Peace Abbey Cs-137 (267 +/- 40) E-3 pCi/g 26 E-3 pCi/g Location #7 22SEP09 Aquatic Kelp San Onofre Kelp Bed I-131 (10 +/- 7) E - 3 pCi/g 7 E-3 pCi/g Station A 19OCT09 29

Sample Media & location Radionuclide Sample Value MDC (a posteriori)

Aquatic Kelp San Mateo Kelp Bed I-131 (11 +/- 6) E-3 pCi/g 7 E-3 pCi/g Station B 19OCT09 Aquatic Kelp Barn Kelp Bed I-131 ( 11 +/- 6) E - 3 pCi/g 7 E-3 pCi/g Station C 19OCT09 Aquatic Kelp Salt Creek I-131 (45 +/- 6) E-3 pCi/g 6 E-3 pCi/g Station E 19OCT09 Aquatic Kelp Dana Point Kelp Bed I-131 (46 +/- 7) E-3 pCi/g 7 E-3 pCi/g Station F 19OCT09 Aquatic Kelp Capistrano Beach Reef I-131 (32 +/- 6) E-3 pCi/g 6 E-3 pCi/g Station G 19OCT09 Aquatic Kelp San Clemente Pier I-131 (29 +/- 7) E-3 pCi/g 5 E-3 pCi/g Station H 19OCT09 Aquatic Kelp Wheeler North Artificial Reef I-131 (32 +/- 6) E-3 pCi/g 5 E-3 pCi/g Station I 19OCT09 Ocean Water Station B H-3 (613 +/- 315) pCi/l 425 pCi/l Unit 2 Outfall 19OCT09 30

TABLE B-2 REMP SAMPLE ANALYSIS

SUMMARY

FOR 2009 Sampling # of Total # of Medium Analysis Type Frequency Locations Analyses 1

in 2009 Direct Radiation Dosimetry Quarterly 49 195 Airborne Particulates Gross Beta Weekly 10 487 Charcoal Cartridge I-131 Weekly 10 453 Airborne Particulates Ge (Li) Scan Quarterly 10 38 Ocean Water Ge (Li) Scan, H-3 Monthly 4 48 Ocean Water H-3 Quarterly 4 16 Ocean Water Conduit Ge (Li) Scan Semi-Annually 2 4 Drinking Water, Ge (Li) Scan, Monthly 3 33 Unfiltered H-3 3 33 Gross Beta 3 33 Shoreline Sediment Ge (Li) Scan Semi-Annually 4 8 Ocean Bottom Sediment Ge (Li) Scan Semi-Annually 7 14 Marine Species, Flesh Ge (Li) Scan Semi-Annually 3 24 Crops Ge (Li) Scan Semi-Annually 2 8 Kelp Ge (Li) Scan Semi-Annually 8 16 Soil Ge (Li) Scan Annually 5 5

1. The total number of analyses listed above include REMP samples not required by the ODCM, including air sampler # 14, air sampler # 16, San Clemente drinking water sample # 2, and additional control kelp samples. These samples were not collected for all of 2009. Collection of air sampler # 14 was discontinued in 2009. Collection of air sampler # 16 (control) was started in 2009. The San Clemente drinking water sample (collection requested by the City of San Clemente) was not available for three months during 2009. One ODCM specified direct radiation sample was not available during 2009. Additional control kelp samples were obtained to track I-131 (iodine-131) activity in kelp attributable to municipal waste water discharges. Therefore, the total number of analyses will not always equal the product of the ODCM specified sample frequency times the total number of ODCM locations.

31

STATISTICAL

SUMMARY

OF REMP DATA FOR 2009 32

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Quarterly Gamma Exposure - Table 1A (mR/std quarter)

Gamma 195 5 17.26 (151/151) South Yard Facility, 23.18 (4/4) 16.47 (44/44) 0 (10.65 - 24.94) 0-4, ESE (20.15 - 24.94) (12.88 - 20.11)

(1) Indicator location TLDs include all REMP TLDs 5.0 miles or closer to SONGS 2/3 midpoint.

(2) Control location TLDs include all REMP TLDs more than 5.0 miles from SONGS 2/3 midpoint.

(3) TLD data excludes QC TLDs, transit dose TLDs, and ISFSI TLDs.

33

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Weekly Airborne Particulates Gross Beta Activity - Table 2 (pCi/cu.m)

Gross Beta 487 0.01 0.0438 (386/386) Mesa Medical 0.0562 (22/22) 0.0441 (101/101) 0 (0.0169 - 0.0862) Facility (0.0238 - 0.0804) (0.0225 - 0.0777) 0.7 Mi. NNW 34

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Weekly Radioiodine I-131 Activity - Table 3 (pCi/cu.m)

I-131 453 0.07 0.0085 (25/386) Marine Corp Base 0.0100 (7/52) 0.0084 (5/67) 0 (0.0040 - 0.0299) (Camp Pendleton (0.0053 - 0.0299) (0.0052 - 0.0160)

East) 0.7 Mi. E This table summarizes the weekly air iodine 131 cartridge data above the critical level (1.64 x one sigma). Note that in an ideal gamma isotopic database, consisting entirely of sample values with no detectable radioactivity, approximately 5% of the data will be greater than the critical level. Iodine 131 was not detected during 2009 in this media.

35

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Quarterly Comp. Airborne Particulates Gamma - Table 4A (pCi/cu.m)

Be-7 38 - 0.27 (30/30) Mesa EOF 0.29 (4/4) 0.26 (8/8) 0 (0.16 - 0.35) 0.7 Mi. NNW (0.23 - 0.34) (0.20 - 0.33)

Cs-134 38 0.05 3.65E-4 (2/30) City of San Clemente 4.72E-4 (1/4) <LLD (0/8) 0 (2.57E 4.72E-4) (City Hall) (4.72E 4.72E-4) (-)

5.1 Mi. NW Cs-137 38 0.06 3.37E-4 (4/30) City of San Clemente 3.98E-4 (1/4) <LLD (0/8) 0 (2.87E 3.98E-4) (City Hall) (3.98E 3.98E-4) (-)

5.1 Mi. NW Be-7 (Beryllium 7) is a naturally occurring radioactive isotope produced by cosmic radiation. Be-7 was confirmed above the detection limit in all the SONGS air particulate quarterly composite samples analyzed in 2009. The results for all plant related radionuclides were less than the a posteriori MDC.

The term "< LLD," as used above, means that all results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background. The numerical values for Cs-134 (Cesium-134) and Cs-137 (Cesium-137) listed in this table are those values above the critical level and do not indicate that these radionuclides were detected in any samples.

36

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway Number of Limit of Locations Mean Nonroutine sampled (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Monthly Ocean Water Gamma Spectral Analysis - Table 5 (pCi/l)

Ba-140 52 15 5.11 (3/40) Unit 3 Conduit 6.19 (1/2) 4.20 (4/12) 0 (4.29 - 6.19) 0.1 Mi. SSW (6.19 - 6.19) (3.61 - 4.78)

Be-7 52 - 8.28 (1/40) Unit 3 Conduit 8.28 (1/2) < LLD (0/12) 0 (8.28 - 8.28) 0.1 Mi SSW (8.28 - 8.28) (-)

Co-58 52 15 1.21 (1/40) (C) Outfall -Unit 3 1.21 (1/12) < LLD (1/12) 0 (1.21 - 1.21) 1.2 Mi. SSW (1.21 - 1.21) (-)

Co-60 52 15 1.27 (5/40) (A) Station Outfall - 1.42 (2/12) < LLD (0/12) 0 (1.10 - 1.62) Unit 1 (1.22 - 1.62) (-)

0.6 Mi. SW Cs-134 52 15 1.65 (7/40) Unit 3 Conduit 2.31 (1/2) < LLD (0/12) 0 (1.34 - 2.31) 0.1 Mi. SSW (2.31 - 2.31) (-)

Cs-137 52 18 1.21 (4/40) (A) Station Outfall - 1.75 (1/12) 1.35 (1/12) 0 (0.89 - 1.75) Unit 1 (1.75 - 1.75) (1.35 - 1.35) 0.6 Mi. SW Fe-59 52 30 4.87 (1/40) (B) Outfall - Unit 2 4.87 (1/12) < LLD (0/12) 0 (4.87 - 4.87) 1.5 Mi. SW (4.87 - 4.87) (-)

H-3 52 3000 349.00 (4/40) (B) Outfall - Unit 2 613.00 (1/12) 303.00 (1/12) 0 (247.00 - 613.00) 1.5 Mi. SW (613.00 - 613.00) (303.00 - 303.00) 37

Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway Number of Limit of Locations Mean Nonroutine sampled (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Monthly Ocean Water Gamma Spectral Analysis - Table 5 (pCi/l)

I-131 52 15 1.43 (3/40) (B) Outfall - Unit 2 1.46 (2/12) < LLD (0/12) 0 (1.37 - 1.52) 1.5 Mi. SW (1.40 - 1.52) (-)

K-40 52 - 338.85 (40/40) Unit 2 Conduit 350.50 (2/2) 338.00 (12/12) 0 (288.00 - 390.00) 0.1 Mi. SW (327.00 - 374.00) (2/2) (295.00 - 384.00)

La-140 52 15 1.65 (1/40) (A) Station Discharge 1.65 (1/12) < LLD (0/12) 0 (1.65 - 1.65) Outfall - Unit 1 (1.65 - 1.65) (-)

0.6 Mi. SW Mn-54 52 15 < LLD (0/40) ---- (0/12) < LLD (0/12) 0

(-) (-) (-)

Nb-95 52 15 1.59 (12/40) Unit 2 Conduit 4.29 (1/2) 1.12 (1/12) 0 (0.91 - 4.29) 0.1 Mi. SW (4.29 - 4.29) (1.12 - 1.12)

Zn-65 52 30 < LLD (0/40) ---- (0/2) < LLD (0/12) 0

(-) (-) (-)

Zr-95 52 15 2.35 (4/40) Unit 2 Conduit 3.14 (1/2) < LLD (0/12) 0 (1.72 - 3.14) 0.1 Mi. SW (3.14 - 3.14) (-)

The naturally occurring radioactive isotope K-40 (Potassium 40) was detected in all SONGS Ocean water samples analyzed in 2009. The analysis results for all other radionuclides were less than the detection limit.

The term "< LLD," as used above, means that all results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background. The numerical values listed in this table are those values above the critical level and do not indicate that these radionuclides were detected in any samples.

This table is a statistical summary of the radionuclides detected in 2009 (K-40) and the radionuclides listed in the ODCM 38

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Quarterly Composite Ocean Water Tritium Activity - Table 7 (pCi/l)

H-3 16 3000 249.00 (1/12) (B) Outfall - Unit 2 249.00 (1/4) < LLD (0/4) 0 (249.00 - 249.00) 1.5 Mi. SW (249.00 - 249.00) (-)

39

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Number Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway of Limit of Locations Mean Nonroutine sampled (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Monthly Drinking Water Analysis -

Table 9A (pCi/l)

Ba-140 33 15 < LLD (0/21) --- (0/12) < LLD (0/12) 0

(-) (-) (-)

Be-7 33 - 11.82 (2/21) San Clemente Golf Course 11.82 (2/9) < LLD (0/12) 0 (9.94 - 13.70) Well (9.94 - 13.70) (-)

3.3 Mi. NW Co-58 33 15 0.99 (1/21) Oceanside (Control) 1.02 (1/12) 1.02 (1/12) 0 (0.99 - 0.99) 15.6 Mi. SE (1.02 - 1.02) (1.02 - 1.02)

Co-60 33 15 < LLD (0/21) --- (0/12) < LLD (0/12) 0

(-) (-) (-)

Cs-134 33 15 1.66 (4/21) Oceanside (Control) 2.07 (1/12) 2.07 (1/12) 0 (1.56 - 1.79) 15.6 Mi. SE (2.07 - 2.07) (2.07 - 2.07)

Cs-137 33 18 0.93 (2/21) Oceanside (Control) 1.37 (3/12) 1.37 (3/12) 0 (0.87 - 0.98) 15.6 Mi. SE (0.96 - 1.96) (0.96 - 1.96)

Fe-59 33 30 2.39 (3/21) San Clemente Golf Course 2.41 (2/9) 2.04 (2/12) 0 (2.00 - 2.81) Well (2.00 - 2.81) (1.68 - 2.40) 3.3 Mi. NW Gross Beta 33 4 4.69 (15/21) San Clemente Golf Course 5.86 (9/9) 5.46 (11/12) 0 (2.06 - 8.29) Well (2.76 - 8.29) (1.94 - 13.90) 3.3 Mi. NW H-3 33 3000 < LLD (0/21) ---- (0/12) < LLD (0/12) 0

(-) (-) (-)

40

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Location with Highest Annual Mean Medium or Type and Total Lower All Indicator Control Locations Number of Pathway Number of Limit of Locations Mean Nonroutine sampled (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Monthly Drinking Water Analysis -

Table 9A (pCi/l)

I-131 33 15 1.25 (1/21) Camp Pendleton 1.25 (1/12) < LLD (0/12) 0 (1.25 - 1.25) 2.2 Mi NNW (1.25 - 1.25) (-)

K-40 33 - 30.00 (5/21) Oceanside (Control) 59.30 (1/12) 59.30 (1/12) 0 (23.50 - 35.50) 15.6 Mi. SE (59.30 - 59.30) (59.30 - 59.30)

La-140 33 15 < LLD (0/21) ---- (0/12) < LLD (0/12) 0

(-) (-) (-)

Mn-54 33 15 1.90 (1/21) San Clemente Golf Course 1.90 (1/9) < LLD (0/12) 0 (1.90 - 1.90) Well (1.90 - 1.90) (-)

3.3 Mi. NW Nb-95 33 15 2.23 (11/21) Camp Pendleton 2.27 (9/12) 1.48 (4/12) 0 (1.25 - 4.26) 2.2 Mi. NNW (1.25 - 4.26) (1.12 - 1.95)

Zn-65 33 30 3.75 (3/21) Camp Pendleton 4.99 (1/12) 2.01 (1/12) 0 (2.42 - 4.99) 2.2 Mi. NNW (4.99 - 4.99) (2.01 - 2.01)

Zr-95 33 15 1.89 (2/21) Oceanside (Control) 2.48 (1/12) 2.48 (1/12) 0 (1.80 - 1.98) 15.6 Mi. SE (2.48 - 2.48) (2.48 - 2.48)

During 2009 gross beta was confirmed above the a posteriori MDC in most drinking water samples. Gross beta is attributable to naturally occurring radionuclides.

All the other analysis results were less than detectable for SONGS related radionuclides.

The term "< LLD," as used above, means that all results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background. The numerical values listed in this table are those values above the critical level and do not indicate that these radionuclides were detected in any samples.

41

This table is a statistical summary of the analysis results confirmed above the a posteriori MDC in 2009 (Gross Beta) as well as those radionuclides listed in the ODCM Starting in October 2006 San Clemente Well # 6 was sampled and analyzed as a courtesy to the City of San Clemente. This table includes the City of San Clemente drinking water analysis results.

42

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway Number of Analysis Limit of Locations Mean Nonroutine sampled (Unit of Performed Detection Mean Name, Distance Mean (Range) Reported Measurement) (LLD) (Range) and Direction (Range) Measurements Semi-annual Shoreline Sediment Gamma Spectral Analysis - Table 10 (pCi/g)

Cs-134 8 0.15 0.0222 (1/6) San Onofre State Beach 0.0222 (1/2) 0.0151 (1/2) 0 (0.0222 - 0.0222) 0.6 Mi. SE (0.0222 - 0.0222) (0.0151 - 0.0151)

Cs-137 8 0.18 <LLD (0/6) ---- (0/2) <LLD (0/2) 0

(-) (-) (-)

K-40 8 - 13.49 (6/6) Newport Beach North End 23.15 (2/2) 23.15 (2/2) 0 (5.07 - 20.90) 29.2 Mi. NW (21.80 - 24.50) (21.80 - 24.50)

Th-228 8 - 0.35 (6/6) San Onofre State Beach 0.61 (2/2) 0.34 (2/2) 0 (0.20 - 0.95) 3.5 Mi. SE (0.28 - 0.95) (0.30 - 0.38)

During 2009 naturally occurring Th-228 (thorium 228) and K-40 (potassium 40) were confirmed above the a posteriori MDC in most shoreline sediment samples.

The term "< LLD," used above, indicates that all analysis results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background. The numerical values listed in this table for Cs-137 are those values above the critical level and do not indicate that Cs-137 was detected in any samples.

This table is a statistical summary of the analysis results confirmed above the a posteriori MDC in 2009 (K-40 and Th-228) as well as those radionuclides listed in the ODCM 43

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Number of Pathway sampled Number of Limit of Locations Locations Nonroutine Reported (Unit of Analysis Detectio Mean Name, Distance Mean Mean Measurements Measurement) Performed n (LLD) (Range) and Direction (Range) (Range)

Semi-Annual Ocean Bottom Sediment Gamma Spectral Analysis - Table 11 (pCi/g)

Cs-134 14 0.15 0.0494 (5/12) (E) Laguna Beach 0.0686 (1/2) 0.0686 (1/2) 0 (0.0265 - 0.0728) 18.2 Mi. NW (0.0686 - 0.0686) (0.0686 - 0.0686)

Cs-137 14 0.18 0.0235 (1/12) (D) Unit 3 Outfall 0.0235 (1/2) < LLD (0/2) 0 (0.0235 - 0.0235) 1.2 Mi. SSW (0.0235 - 0.0235) (-)

K-40 14 - 17.25 (12/12) Unit 2 Conduit 19.15 (2/2) 13.30 (2/2) 0 (14.30 - 19.70) 0.1 Mi. SSW (18.60 - 19.70) (11.60 - 15.00)

Th-228 14 0.46 (12/12) (C) Unit 2 Outfall 0.80 (2/2) 0.58 (2/2) 0 (0.14 - 0.93) 1.6 Mi. SW (0.67 - 0.93) (0.11 - 1.05)

During 2009, naturally occurring Th-228 (thorium 228) and K-40 (potassium 40) were confirmed above the a posteriori MDC in most ocean bottom sediment samples.

The term "< LLD," used above, indicates that all analysis results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background. The numerical values listed in this table for Cs-137 are those values above the critical level and do not indicate that Cs-137 was detected in any samples.

This table is a statistical summary of the analysis results confirmed above the a posteriori MDC in 2009 (K-40 and Th-228) as well as those radionuclides listed in the ODCM 44

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Number of Pathway sampled Number of Limit of Locations Locations Nonroutine (Unit of Analysis Detectio Mean Name, Distance Mean Mean Reported Measurement) Performed n (LLD) (Range) and Direction (Range) (Range) Measurements Semi-Annual Non-Migratory Marine Animals (Flesh) Analysis - Table 12A (pCi/g)

Black Perch Co-58 4 0.13 < LLD (0/3) ---- (0/2) < LLD (0/1) 0

(-) (-) (-)

Black Perch Co-60 4 0.13 < LLD (0/3) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Black Perch Cs-134 4 0.13 0.0023 (1/3) (B) Units 2 and 3 0.0023 (1/1) < LLD (0/1) 0 Outfall (-)

(0.0023 - 0.0023) (0.0023 - 0.0023) 1.5 Mi. SSW Black Perch Cs-137 4 0.15 0.0031 (1/3) (A) Unit 1 Outfall 0.0031 (1/2) < LLD (0/1) 0 (0.0031 - 0.0031) 0.9 Mi. WSW (0.0031 - 0.0031) (-)

Black Perch Fe-59 4 0.26 0.0051 (1/3) (B) Units 2 and 3 0.0051 (1/1) < LLD (0/1) 0 (0.0051 - 0.0051) Outfall (0.0051 - 0.0051) (-)

1.5 Mi. SSW Black Perch K-40 4 - 3.19 (3/3) (A) Unit 1 Outfall 3.31 (2/2) 3.04 (1/1) 0 (2.95 - 3.50) 0.9 Mi. WSW (3.11 - 3.50) (3.04 - 3.04)

Black Perch Mn-54 4 0.13 < LLD (0/3) ---- (0/2) < LLD (0/1) 0

(-) (-) (-)

Black Perch Zn-65 4 0.26 < LLD (0/3) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

<LLD results are less than the critical level 1.64 sigma.

45

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Number of Pathway sampled Number of Limit of Locations Locations Nonroutine (Unit of Analysis Detectio Mean Name, Distance Mean Mean Reported Measurement) Performed n (LLD) (Range) and Direction (Range) (Range) Measurements Semi-Annual Non-Migratory Marine Animals (Flesh) Analysis - Table 12A (pCi/g)

Blacksmith Co-58 2 0.13 < LLD (0/1) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Blacksmith Co-60 2 0.13 < LLD (0/1) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Blacksmith Cs-134 2 0.13 < LLD (0/1) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Blacksmith Cs-137 2 0.15 0.0026 (1/1) (B) Units 2 and 3 0.0026 (1/1) < LLD (0/1) 0 (0.0026 - 0.0026) Outfall (0.0026 - 0.0026) (-)

1.5 Mi. SSW Blacksmith Fe-59 2 0.26 0.0055 (1/1) (B) Units 2 and 3 0.0055 (1/1) < LLD (0/1) 0 (0.0055 - 0.0055) Outfall (0.0055 - 0.0055) (-)

1.5 Mi. SSW Blacksmith K-40 2 - 3.50 (1/1) (C) Laguna Beach 3.58 (1/1) 3.58 (1/1) 0 (3.50 - 3.50) 18.2 Mi. NW (3. 58 - 3.58) (3. 58 - 3.58)

Blacksmith Mn-54 2 0.13 < LLD (0/1) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Blacksmith Zn-65 2 0.26 < LLD (0/1) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

<LLD results are less than the critical level 1.64 sigma.

46

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Number of Pathway sampled Number of Limit of Locations Locations Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean Mean Reported Measurement) Performed (LLD) (Range) and Direction (Range) (Range) Measurements Semi-Annual Non-Migratory Marine Animals (Flesh) Analysis - Table 12A (pCi/g)

California Mussel Co-58 6 0.13 0.0022 (1/4) (A) Unit 1 Outfall 0.0022 (1/2) < LLD (0/2) 0 (0.0022 - 0.0022) 0.9 Mi. WSW (0.0022 - 0.0022) (-)

California Mussel Co-60 6 0.13 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

California Mussel Cs-134 6 0.13 0.0035 (1/4) (A) Unit 1 Outfall 0.0035 (1/2) < LLD (0/2) 0 (0.0035 - 0.0035) 0.9 Mi. WSW (0.0035 - 0.0035) (-)

California Mussel Cs-137 6 0.15 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

California Mussel Fe-59 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

California Mussel K-40 6 - 1.85 (4/4) (B) Units 2 and 3 1.91 (2/2) 1.49 (2/2) 0 (1.67 - 1.96) Outfall (1.86 - 1.96) (1.47 - 1.50) 1.5 Mi. SSW California Mussel Mn-54 6 0.13 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

California Mussel Zn-65 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

<LLD results are less than the critical level 1.64 sigma.

47

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Semi-Annual Non-Migratory Marine Animals (Flesh) Analysis - Table 12A (pCi/g)

Sheephead Co-58 6 0.13 < LLD (0/4) (C) Laguna Beach 0.0077 (1/2) 0.0077 (1/2) 0

(-) 18.2 Mi NW (0.0077 - 0.0077) (0.0077 - 0.0077)

Sheephead Co-60 6 0.13 0.0044 (1/4) (A) Unit 1 Outfall 0.0044 (1/2) < LLD (0/2) 0 (0.0044 - 0.0044) 0.9 Mi. WSW (0.0044 - 0.0044) (-)

Sheephead Cs-134 6 0.13 0.0022 (1/4) (B) Units 2 and 3 0.0022 (1/2) < LLD (0/2) 0 (0.0022 - 0.0022) Outfall (0.0022 - 0.0022) (-)

1.5 Mi. SSW Sheephead Cs-137 6 0.15 0.0045 (3/4) (A) Unit 1 Outfall 0.0060 (1/2) 0.0031 (1/2) 0 (0.0037 - 0.0060) 0.9 Mi. WSW (0.0060 - 0.0060) (0.0031 - 0.0031)

Sheephead Fe-59 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Sheephead K-40 6 - 3.64 (4/4) (B) Units 2 and 3 3.77 (2/2) 3.00 (2/2) 0 (3.48 - 3.98) Outfall (3.56 - 3.98) (2.43 - 3.56) 1.5 Mi. SSW Sheephead Mn-54 6 0.13 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Sheephead Zn-65 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

<LLD results are less than the critical level 1.64 sigma.

48

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Semi-Annual Non-Migratory Marine Animals (Flesh) Analysis - Table 12A (pCi/g)

Spiny Lobster Co-58 6 0.13 < LLD (0/4) (C) Laguna Beach 0.0032 (1/2) 0.0032 (1/2) 0

(-) 18.2 Mi NW (0.0032 - 0.0032) (0.0032 - 0.0032)

Spiny Lobster Co-60 6 0.13 0.0221 (1/4) (C) Laguna Beach 0.0113 (1/2) 0.0113 (1/2) 0 (0.0221 - 0.0221) 18.2 Mi NW (0.0113 - 0.0113) (0.0113 - 0.0113)

Spiny Lobster Cs-134 6 0.13 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Spiny Lobster Cs-137 6 0.15 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Spiny Lobster Fe-59 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Spiny Lobster K-40 6 - 3.39 (4/4) (A) Unit 1 Outfall 3.44 (2/2) 3.28 (2/2) 0 (2.97 - 3.71) 0.9 Mi. WSW (3.38 - 3.49) (3.04 - 3.51)

Spiny Lobster Mn-54 6 0.13 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Spiny Lobster Zn-65 6 0.26 < LLD (0/4) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

LLD results are less than the critical level 1.64 sigma.

49

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Semi-Annual Local Crops Gamma Spectral Analysis - Table 13A (pCi/g)

Cabbage Be-7 1 < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Cabbage Cs-134 1 0.06 < LLD (0/0) South East of Oceanside 0.0050 (1/1) 0.0050 (1/1) 0

(-) 22 Mi. SE (0.0050 - 0.0050) (0.0050 - 0.0050)

Cabbage Cs-137 1 0.08 < LLD (0/0) South East of Oceanside 0.0061 (1/1) 0.0061 (1/1) 0

(-) 22 Mi. SE (0.0061 - 0.0061) (0.0061 - 0.0061)

Cabbage I-131 1 0.06 < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Cabbage K-40 1 - < LLD (0/0) South East of Oceanside 1.28 (1/1) 1.28 (1/1) 0

(-) 22 Mi. SE (1.28 - 1.28) (1.28 - 1.28)

Lettuce Be-7 1 - < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Lettuce Cs-134 1 0.06 < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Lettuce Cs-137 1 0.08 < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

50

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Number of Pathway sampled Number of Limit of Locations Control Locations Nonroutine (Unit of Analysis Detecti Mean Mean Reported Measurement) Performed on (Range) Name, Distance Mean (Range) Measurements (LLD) and Direction (Range)

Semi-Annual Local Crops Gamma Spectral Analysis - Table 13A (pCi/g)

Lettuce I-131 1 0.06 < LLD (0/0) ---- (0/1) < LLD (0/1) 0

(-) (-) (-)

Lettuce K-40 1 - < LLD (0/0) South East of 1.77 (1/1) 1.77 (1/1) 0

(-) Oceanside (1.77 - 1.77) (1.77 - 1.77) 22 Mi. SE Sorrel Be-7 2 - 0.32 (2/2) SONGS Garden 0.32 (2/2) < LLD (0/0) 0 (0.30 - 0.33) 0.4 Mi. NNW (0.30 - 0.33) (-)

Sorrel Cs-134 2 0.06 0.0054 (2/2) SONGS Garden 0.0054 (2/2) < LLD (0/0) 0 (0.0038 - 0.0070) 0.4 Mi. NNW (0.0038 - 0.0070) (-)

Sorrel Cs-137 2 0.08 < LLD (0/2) ---- (0/2) < LLD (0/0) 0

(-) (-) (-)

Sorrel I-131 2 0.06 0.0041 (1/2) SONGS Garden 0.0041 (1/2) < LLD (0/0) 0 (0.0041 - 0.0041) 0.4 Mi. NNW (0.0041 - 0.0041) (-)

Sorrel K-40 2 - 4.64 (2/2) SONGS Garden 4.64 (2/2) < LLD (0/0) 0 (3.71 - 5.56) 0.4 Mi. NNW (3.71 - 5.56) (-)

Tomato Be-7 4 - 0.0200 (1/2) SONGS Garden 0.0200 (1/2) < LLD (0/2) 0 (0.0200 - 0.0200) 0.4 Mi. NNW (0.0200 - 0.0200) (-)

51

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/3/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Number of Pathway sampled Number of Limit of Locations Location with Highest Annual Mean Control Locations Nonroutine (Unit of Analysis Detection Mean Mean Reported Measurement) Performed (LLD) (Range) Name, Distance Mean (Range) Measurements and Direction (Range)

Semi-Annual Local Crops Gamma Spectral Analysis - Table 13A (pCi/g)

Tomato Cs-134 4 0.06 < LLD (0/2) South East of Oceanside 0.0045 (1/2) 0.0045 (1/2) 0

(-) 22 Mi. SE (0.0045 - 0.0045) (0.0045 - 0.0045)

Tomato Cs-137 4 0.08 < LLD (0/2) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Tomato I-131 4 0.06 < LLD (0/2) ---- (0/2) < LLD (0/2) 0

(-) (-) (-)

Tomato K-40 4 - 2.02 (2/2) SONGS Garden 2.02 (2/2) 1.85 (2/2) 0 (1.90 - 2.14) 0.4 Mi. NNW (1.90 - 2.14) (1.40 - 2.30)

During 2009, naturally occurring K-40 (potassium 40) and Be-7 (Beryllium 7) were confirmed above the a posteriori MDC in local crop samples.

The term "< LLD," used above, indicates that all analysis results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular analysis result should be considered as other than background. The numerical values listed in this table for Cs-137 are those values above the critical level and do not indicate that Cs-137 was detected in any samples.

This table is a statistical summary of the analysis results confirmed above the a posteriori MDC in 2009 (K-40) as well as those radionuclides listed in the ODCM 52

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/1/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Annual Soil Analysis - Depth 3 -

Table 14 (pCi/g)

Cs-134 5 0.15 0.0559 (2/4) Former Visitors Center 0.0628 (1/1) 0.0244 (1/1) 0 (0.0490 - 0.0628) (East Site Boundary) (0.0628 - 0.0628) (0.0244 - 0.0244) 0.4 Mi. NW Cs-137 5 0.18 0.22 (2/4) Old Route 101 - East 0.39 (1/1) 0.27 (1/1) 0 (0.0513 - 0.39) Southeast (0.39 - 0.39) (0.27 - 0.27) 3 Mi. ESE K-40 5 - 14.76 (4/4) Camp San Onofre 19.50 (1/1) 4.18 (1/1) 0 (8.55 - 19.50) 2.6 Mi NE (19.50 - 19.50)

(4.18 - 4.18)

Th-228 5 0.67 (4/4) Former Visitors Center 0.77 (1/1) 0.25 (1/1) 0 (0.51 - 0.77) (East Site Boundary) (0.77 - 0.77)

(0.25 - 0.25) 0.4 Mi. NW During 2009, naturally occurring Th-228 (thorium 228) and K-40 (potassium 40) were confirmed above the a posteriori MDC in all soil samples. Cs-137 (Cesium 137) was detected in four samples and is attributable to fallout from nuclear weapons testing and from Chernobyl.

The term < LLD, used above, indicates that all analysis results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background.

This table is a statistical summary of the analysis results for K-40 and those radionuclides listed in the ODCM for sediment samples.

53

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM

SUMMARY

SAN ONOFRE NUCLEAR GENERATING STATION DOCKET NOS. 50-206, 50-361, 50-362 SAN DIEGO COUNTY, CALIFORNIA Reporting Period: 1/3/2009 to 12/31/2009 Medium or Type and Total Lower All Indicator Location with Highest Annual Mean Control Locations Number of Pathway sampled Number of Limit of Locations Mean Nonroutine (Unit of Analysis Detection Mean Name, Distance Mean (Range) Reported Measurement) Performed (LLD) (Range) and Direction (Range) Measurements Semi-Annual Kelp Analysis - Table 15 (pCi/g)

Cs-134 16 0.06 <LLD (0/6) ( - ) (0/2) 0

< LLD (0/10)

(-)

(-)

Cs-137 16 0.08 <LLD (0/6) Capistano Beach Reef 0.0047 (1/2) 0.0045 (2/10) 0

(-) 9.3 Mi. NW (0.0047 - 0.0047) (0.0043 - 0.0047)

I-131 16 0.06 0.0459 (6/6) Wheeler North Artificial 0.0922 (2/2) 0.0762 (10/10) 0 (0.0103 - 0.0917) Reef (0.0324 - 0.15) (0.0294 - 0.15)

(See*** Mi.

K-40 16 - 9.82 (6/6) (E) Salt Creek 11.20 (2/2) 10.16 (10/10) 0 (8.25 - 11.70) (CONTROL) (9.40 - 13.00) (7.52 - 13.00) 11 Mi. NNW During 2009, naturally occurring K-40 (potassium 40) were confirmed above the a posteriori MDC in all kelp samples. I-131 (iodine 131) was also confirmed above the a posteriori MDC in twelve samples. I-131 is known to be a constituent of sewage plant discharges due to medically administered I-131. The activity of I-131 in the control sample (Salt Creek - about 11 miles up coast from SONGS) has is historically been higher than the I-131 activity in kelp closer to SONGS. I-131 in kelp is attributable to sewage plant effluents.

The term < LLD, used above, indicates that all analysis results were less than the critical level (1.64 x one sigma). The critical level is used to determine if a bias exists in the database and is not used to determine if a particular sample result should be considered other than background.

• • • The April 2009 Wheeler North Artificial Reef Kelp sample was collected 5.4 miles WNW. The October 2009 sample was 5.2 miles WNW.

54

APPENDIX C

SUMMARY

OF QUALITY CONTROL PROGRAMS 55

All REMP samples are collected, shipped, and analyzed in accordance with NRC Regulatory Guide 4.15. Marine radiological environmental samples are collected by a vendor, MBC Environmental, per the vendor=s Quality Assurance manual. REMP sample analysis is performed by the Contracted Environmental Analysis Laboratory (CEAL) in accordance with the Laboratory Quality Assurance Plan. During 2009 the CEAL was GEL (General Engineering Laboratory). The CEAL for REMP TLDs was Areva.

INTERLABORATORY CROSS-CHECK PROGRAM:

The CEAL participates in a number of independent cross check programs, including the National Institute of Standards and Technology (NIST) and Analytics cross-check programs. A summary of the cross check data is included in Table C-1. The CEAL=s performance meets the criteria described in Reg. Guide 4.15. Discrepancies and non-agreement results are resolved through a formal Condition Report evaluation process.

56

QUARTERLY DUPLICATE TLDs SONGS deployed a duplicate TLD package in the same location and canister as TLD 66. The quarterly dose measured by these separate TLD packages is statistically equal.

DUPLICATE TLD DATA COMPARISON 1ST QUARTER 2ND QUARTER 3RD QUARTER 4TH QUARTER TLD 66 14.40 +/- 1.42 13.99 +/- 0.70 15.97 +/- 1.15 13.56 +/- 0.74 TLD 200 14.67 +/- 0.84 14.49 +/- 1.06 15.89 +/- 0.79 14.08 +/- 0.66

• Data is reported as mR per standard quarter +/- 1 sigma 57

ANNUAL DUPLICATE TLDs An annual duplicate TLD package is collocated with TLD 67.

TLD 67 TLD 201 (annual duplicate) average dose in mR dose in mR per standard quarter per standard quarter (July 2008 to July 2009) (July 2008 to July 2009) 17.35 17.08 COMPARISON OF TLD TO PIC DATA, PIC 1 PIC 3 PIC 4 PIC 8 16.83 17.33 17.81 13.36 TLD 10 TLD 40 TLD 61 TLD 65 15.38 17.86 18.74 11.09 PIC data converted to mR per standard quarter compared to the 4th Quarter co-located 2009 TLD data.

CALIBRATION OF AIR SAMPLER VOLUME METERS The Shop Services and Instrumentation Division of SCE performs an annual calibration procedure using standards referenced to NIST on all REMP air sampler gas meters. When the gas meters are removed from service, the meter is calibrated and the calibration reports are reviewed for bias. This is an a posteriori review of the gas meter performance to evaluate method bias and to identify possible outlier analysis results. In 2009, three (3) gas meter failed to meet this criterion at all calibrated flow rates and one gas meter was inoperable. A review of the affected gross beta data has revealed no meaningful anomalies. Thus no discernable impact to the REMP database or conclusions resulted from use of the out of tolerance gas meter.

58

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable E6375-278 4th/2008 Milk Sr-90 pCi/L 10.90 12.6 0.86¹ Acceptable E6376-278 4th /2008 Milk I-131 pCi/L 76.6 79.9 0.96¹ Acceptable E6376-278 4th /2008 Milk Ce-141 pCi/L 179 191 0.93¹ Acceptable E6376-278 4th /2008 Milk Cr-51 pCi/L 248 246 1.01¹ Acceptable E6376-278 4th /2008 Milk Cs-134 pCi/L 128 134 0.95¹ Acceptable E6376-278 4th /2008 Milk Cs-137 pCi/L 123 120 1.03¹ Acceptable E6376-278 4th /2008 Milk Co-58 pCi/L 101 104 0.97¹ Acceptable E6376-278 4th /2008 Milk Mn-54 pCi/L 151 152 0.99¹ Acceptable E6376-278 4th /2008 Milk Fe-59 pCi/L 103 100 1.02¹ Acceptable E6376-278 4th /2008 Milk Zn-65 pCi/L 193 183 1.05¹ Acceptable E6376-278 4th /2008 Milk Co-60 pCi/L 139 133 1.05¹ Acceptable E6377-278 4th /2008 Water I-131 pCi/L 63.7 64.1 0.99¹ Acceptable E6377-278 4th /2008 Water Ce-141 pCi/L 224 224 1.00¹ Acceptable E6377-278 4th /2008 Water Cr-51 pCi/L 278 288 0.96¹ Acceptable E6377-278 4th /2008 Water Cs-134 pCi/L 159 157 1.01¹ Acceptable E6377-278 4th /2008 Water Cs-137 pCi/L 148 140 1.05¹ Acceptable E6377-278 4th /2008 Water Co-58 pCi/L 126 122 1.03¹ Acceptable E6377-278 4th /2008 Water Mn-54 pCi/L 192 178 1.08¹ Acceptable E6377-278 4th /2008 Water Fe-59 pCi/L 128 117 1.09¹ Acceptable E6377-278 4th /2008 Water Zn-65 pCi/L 238 214 1.11¹ Acceptable E6377-278 4th /2008 Water Co-60 pCi/L 168 156 1.08¹ Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

59

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable RAD-75 4th /2008 Water Sr-89 pCi/L 44.3 48.7 38.2 - 56.1 Acceptable RAD-75 4th /2008 Water Sr-90 pCi/L 38.2 33.6 24.6 - 38.8 Acceptable RAD-75 4th /2008 Water Gross Alpha pCi/L 17.6 26.9 13.6 - 35.5 Acceptable RAD-75 4th /2008 Water Gross Beta pCi/L 28.8 38 25.1 - 45.5 Acceptable RAD-75 4th /2008 Water H-3 pCi/L 2100 2220 1830 - 2460 Acceptable E6582-278 1st/2009 Cartridge I-131 pCi 7.77E + 01 7.94E + 01 0.98¹ Acceptable E6584-278 1st/2009 Milk Ce-141 pCi/L 9.78E + 01 9.49E + 01 1.03¹ Acceptable E6584-278 1st/2009 Milk Co-58 pCi/L 1.23E + 02 1.19E + 02 1.03¹ Acceptable E6584-278 1st/2009 Milk Co-60 pCi/L 1.50E + 02 1.42E + 02 1.05¹ Acceptable E6584-278 1st/2009 Milk Cr-51 pCi/L 2.97E+ 02 3.05E + 02 0.97¹ Acceptable E6584-278 1st/2009 Milk Cs-134 pCi/L 9.06E+ 01 9.37E + 01 0.97¹ Acceptable E6584-278 1st/2009 Milk Cs-137 pCi/L 1.16E + 02 1.11E + 02 1.04¹ Acceptable E6584-278 1st/2009 Milk Fe-59 pCi/L 1.16E + 02 7.61E + 00 1.16¹ Acceptable E6584-278 1st/2009 Milk I-131 pCi/L 7.97E + 01 7.93E + 01 1.01¹ Acceptable E6584-278 1st/2009 Milk Mn-54 pCi/L 1.33E + 02 1.28E + 02 1.04¹ Acceptable E6584-278 1st/2009 Milk Zn-65 pCi/L 1.72E + 02 1.56E + 02 1.1¹ Acceptable E6585-278 1st/2009 Water Ce-141 pCi/L 1.22E + 02 1.20E + 02 1.02¹ Acceptable E6585-278 1st/2009 Water Co-58 pCi/L 1.59E + 02 1.51E + 02 1.05¹ Acceptable E6585-278 1st/2009 Water Co-60 pCi/L 1.92E + 02 1.80E + 02 1.06¹ Acceptable E6585-278 1st/2009 Water Cr-51 pCi/L 3.92E + 02 3.87E + 02 1.01¹ Acceptable E6585-278 1st/2009 Water Cs-134 pCi/L 1.19E + 02 1.19E + 02 1.00¹ Acceptable E6585-278 1st/2009 Water Cs-137 pCi/L 1.44E + 02 1.41E + 02 1.02¹ Acceptable E6585-278 1st/2009 Water Fe-59 pCi/L 1.28E + 02 1.27E + 02 1.01¹ Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

60

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable E6585-278 1st/2009 Water I-131 pCi/L 7.55E + 01 6.90E + 01 1.09¹ Acceptable E6585-278 1st/2009 Water Mn-54 pCi/L 1.80E + 02 1.62E + 02 1.11¹ Acceptable E6585-278 1st/2009 Water Zn-65 pCi/L 2.24E + 02 1.97E + 02 1.13¹ Acceptable RAD - 76 1st/2009 Water Gross Alpha pCi/L 51.3 52.3 27.3 - 65.5 Acceptable RAD - 76 1st/2009 Water Gross Beta pCi/L 41.9 46.1 31.0 - 53.3 Acceptable RAD - 76 1st/2009 Water H-3 pCi/L 3760.0 4230 3610 - 4660 Acceptable RAD - 76 1st/2009 Water I-131 pCi/L 25.1 22.2 18.4 - 26.5 Acceptable RAD - 76 1st/2009 Water Sr-89 pCi/L 72.8 65 52.7 - 73.0 Acceptable RAD - 76 1st/2009 Water Sr-90 pCi/L 36.5 41.9 30.8 - 48.1 Acceptable E6729-278 2nd/2009 Cartridge I-131 pCi 9.27E + 01 9.55E + 01 0.97¹ Acceptable E6730-278 2nd/2009 Milk Sr-89 pCi/L 8.51E + 01 1.12E + 02 0.76¹ Acceptable E6730-278 2nd/2009 Milk Sr-90 pCi/L 1.09E + 01 1.67E + 01 0.65¹ Not Acceptable E6731-278 2nd/2009 Milk Ce-141 pCi/L 2.84E + 02 2.84E + 02 1¹ Acceptable E6731-278 2nd/2009 Milk Co-58 pCi/L 9.48E + 01 9.19E + 01 1.03¹ Acceptable E6731-278 2nd/2009 Milk Co-60 pCi/L 3.15E + 02 3.12E + 02 1.01¹ Acceptable E6731-278 2nd/2009 Milk Cr-51 pCi/L 4.04E + 02 4.00E + 02 1.01¹ Acceptable E6731-278 2nd/2009 Milk Cs-134 pCi/L 1.58E + 02 1.66E + 02 0.95¹ Acceptable E6731-278 2nd/2009 Milk Cs-137 pCi/L 1.92E + 02 1.92E + 02 1¹ Acceptable E6731-278 2nd/2009 Milk Fe-59 pCi/L 1.23E + 02 1.22E + 02 1.01¹ Acceptable E6731-278 2nd/2009 Milk I-131 pCi/L 8.98E + 01 1.02E + 02 0.88¹ Acceptable E6731-278 2nd/2009 Milk Mn-54 pCi/L 1.42E + 02 1.37E + 02 1.04¹ Acceptable E6731-278 2nd/2009 Milk Zn-65 pCi/L 1.79E + 02 1.75E + 02 1.02¹ Acceptable E6732-278 2nd/2009 Water Ce-141 pCi/L 2.29E + 02 2.16E + 02 1.06¹ Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

61

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable E6732-278 2nd/2009 Water Co-58 pCi/L 7.21E + 01 6.98E + 01 1.03¹ Acceptable E6732-278 2nd/2009 Water Co-60 pCi/L 2.42E + 02 2.37E +02 1.02¹ Acceptable E6732-278 2nd/2009 Water Cr-51 pCi/L 3.11E + 02 3.04E + 02 1.02¹ Acceptable E6732-278 2nd/2009 Water Cs-134 pCi/L 1.37E + 02 1.26E + 02 1.09¹ Acceptable E6732-278 2nd/2009 Water Cs-137 pCi/L 1.51E + 02 1.46E + 02 1.04¹ Acceptable E6732-278 2nd/2009 Water Fe-59 pCi/L 9.04E + 01 9.29E + 01 0.97¹ Acceptable E6732-278 2nd/2009 Water I-131 pCi/L 8.52E + 01 8.83E + 01 0.97¹ Acceptable E6732-278 2nd/2009 Water Mn-54 pCi/L 1.07E + 02 1.04E + 02 1.03¹ Acceptable E6732-278 2nd/2009 Water Zn-65 pCi/L 1.38E + 02 1.33E + 02 1.04¹ Acceptable MAPEP 09-GrF20 2nd/2009 Filter Gross Alpha Bq 0.069 0.35 >0.0 - 0.696 Acceptable MAPEP 09-GrF20 2nd/2009 Filter Gross Beta Bq 0.297 0.28 0.140 - 0.419 Acceptable MAPEP 09-GrW20 2nd/2009 Water Gross Alpha Bq/L 0.506 0.64 >0.0 - 1.270 Acceptable MAPEP 09-GrW20 2nd/2009 Water Gross Beta Bq/L 1.337 1.27 0.64 - 1.91 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Co-57 Bq/kg -0.30 0.00 ----- Acceptable MAPEP 09-MaS20 2nd/2009 Soil Co-60 Bq/kg 3.6 4.113 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Cs-134 Bq/kg 468 467 327 - 607 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Cs-137 Bq/kg 622 605 424 - 787 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Fe-55 Bq/kg 844.7 983 688 - 1278 Acceptable MAPEP 09-MaS20 2nd/2009 Soil K-40 Bq/kg 608.7 570 399 - 741 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Mn-54 Bq/kg 322.3 307 215 - 399 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Ni-63 Bq/kg 550.3 514.9 360.4 - 669.4 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Sr-90 Bq/kg 262.33 257 180 - 334 Acceptable MAPEP 09-MaS20 2nd/2009 Soil Zn-65 Bq/kg 261 242 169 - 315 Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

62

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable MAPEP 09-MaW20 2nd/2009 Water Co-57 Bq/L 18.8 18.9 13.2 - 24.6 Acceptable MAPEP 09-MaW20 2nd/2009 Water Co-60 Bq/L 16.8 17.21 12.05 - 22.37 Acceptable MAPEP 09-MaW20 2nd/2009 Water Cs-134 Bq/L 21.9 22.5 15.8 - 29.3 Acceptable MAPEP 09-MaW20 2nd/2009 Water Cs-137 Bq/L 0.0 0 ----- Acceptable MAPEP 09-MaW20 2nd/2009 Water Mn-54 Bq/L 15.1 14.66 10.26 - 19.06 Acceptable MAPEP 09-MaW20 2nd/2009 Water Ni-63 Bq/L 52.7 53.5 37.45 - 69.55 Acceptable MAPEP 09-MaW20 2nd/2009 Water Sr-90 Bq/L 7.43 7.21 5.05 - 9.37 Acceptable MAPEP 09-MaW20 2nd/2009 Water Zn-65 Bq/L 14.6 13.6 9.5 - 17.7 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Co-57 Bq 1.347 1.30 0.91 - 1.69 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Co-60 Bq 1.413 1.22 0.85 - 1.59 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Cs-134 Bq 2.763 2.93 2.05 - 3.81 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Cs-137 Bq 1.487 1.52 1.06 - 1.98 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Mn-54 Bq 2.403 2.27 1.5896 - 2.9522 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Sr-90 Bq 0.692 0.64 0.448 - 0.832 Acceptable MAPEP 09-RdF20 2nd/2009 Filter Zn-65 Bq 1.613 1.36 0.95 - 1.77 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Co-57 ug/sample 2.557 2.63 1.65 - 3.07 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Co-60 ug/sample -0.010 0.00 ---- Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Cs-134 ug/sample 3.430 3.40 2.38 - 4.42 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Cs-137 ug/sample 0.907 0.93 0.65 - 1.21 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Mn-54 ug/sample 2.353 2.30 1.61 - 2.99 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Sr-90 ug/sample 1.160 1.26 0.882 - 1.638 Acceptable MAPEP 09-RdV20 2nd/2009 Vegetation Zn-65 ug/sample 1.350 1.35 0.948 - 1.760 Acceptable E6843 - 278 3rd/2009 Cartridge I-131 pCi 9.54E + 01 9.21E + 01 1.04¹ Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

63

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable E6844 - 278 3rd/2009 Milk Sr-89 pCi/L 1.19E + 02 1.07E + 02 1.12¹ Acceptable E6844 - 278 3rd/2009 Milk Sr-90 pCi/L 1.68E + 01 1.88E + 01 0.89¹ Acceptable E6845 - 278 3rd/2009 Milk Ce-141 pCi/L 2.83E + 02 2.75E + 02 1.03¹ Acceptable E6845 - 278 3rd/2009 Milk Co-58 pCi/L 1.04E + 02 9.94E + 01 1.05¹ Acceptable E6845 - 278 3rd/2009 Milk Co-60 pCi/L 1.58E + 02 1.60E + 02 0.99¹ Acceptable E6845 - 278 3rd/2009 Milk Cr-51 pCi/L 2.43E + 02 2.21E + 02 1.1¹ Acceptable E6845 - 278 3rd/2009 Milk Cs-134 pCi/L 1.23E + 02 1.23E + 02 1.00¹ Acceptable E6845 - 278 3rd/2009 Milk Cs-137 pCi/L 1.92E + 02 1.85E + 02 1.04¹ Acceptable E6845 - 278 3rd/2009 Milk Fe-59 pCi/L 1.64E + 02 1.47E + 02 1.11¹ Acceptable E6845 - 278 3rd/2009 Milk I-131 pCi/L 1.01E + 02 9.86E + 01 1.02¹ Acceptable E6845 - 278 3rd/2009 Milk Mn-54 pCi/L 2.11E + 02 2.06E + 02 1.02¹ Acceptable E6845 - 278 3rd/2009 Milk Zn-65 pCi/L 2.24E+ 02 2.04E + 02 1.1¹ Acceptable E6846 -278 3rd/2009 Water Ce-141 pCi/L 2.72E + 02 2.64E + 02 1.03¹ Acceptable E6846 -278 3rd/2009 Water Co-58 pCi/L 9.65E + 01 9.54E + 01 1.01¹ Acceptable E6846 -278 3rd/2009 Water Co-60 pCi/L 1.56E + 02 1.54E + 02 1.01¹ Acceptable E6846 -278 3rd/2009 Water Cr-51 pCi/L 2.21E + 02 2.12E + 02 1.04¹ Acceptable E6846 -278 3rd/2009 Water Cs-134 pCi/L 1.18E + 02 1.18E + 02 1.00¹ Acceptable E6846 -278 3rd/2009 Water Cs-137 pCi/L 1.86E + 02 1.77E + 02 1.05¹ Acceptable E6846 -278 3rd/2009 Water Fe-59 pCi/L 1.48E + 02 1.41E + 02 1.05¹ Acceptable E6846 -278 3rd/2009 Water I-131 pCi/L 1.02E + 02 9.84E + 01 ¹1.04 Acceptable E6846 -278 3rd/2009 Water Mn-54 pCi/L 2.11E + 02 1.98E + 02 1.07¹ Acceptable E6846 -278 3rd/2009 Water Zn-65 pCi/L 2.19E + 02 1.95E + 02 1.12¹ Acceptable RAD - 78 3rd/2009 Water Gross Alpha pCi/L 43.8 55.3 28.9 - 69.0 Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

64

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable RAD - 78 3rd/2009 Water Gross Beta pCi/L 53.6 64.7 44.8 - 71.3 Acceptable RAD - 78 3rd/2009 Water H-3 pCi/L 9440.0 10000 8690 - 11000 Acceptable RAD - 78 3rd/2009 Water I-131 pCi/L 28.4 26.3 21.8 - 31.0 Acceptable RAD - 78 3rd/2009 Water Sr-89 pCi/L 59.6 59.1 47.4 - 66.9 Acceptable RAD - 78 3rd/2009 Water Sr-90 pCi/L 33.7 37.4 27.4 - 43.1 Acceptable MAPEP 09-GrF21 4th/2009 Filter Gross Alpha Bq 0.069 0.35 >0.0 - 0.696 Acceptable MAPEP 09-GrF21 4th/2009 Filter Gross Beta Bq 0.297 0.28 0.140 - 0.419 Acceptable MAPEP 09-GrW21 4th/2009 Water Gross Alpha Bq/L 0.982 1.05 >0.0 - 2.094 Acceptable MAPEP 09-GrW21 4th/2009 Water Gross Beta Bq/L 7.277 7.53 3.77 - 11.30 Acceptable MAPEP 09-MaS21 4th/2009 Soil Co-57 Bq/kg 572.30 586.00 410 - 762 Acceptable MAPEP 09-MaS21 4th/2009 Soil Co-60 Bq/kg 332.3 327.000 229 - 425 Acceptable MAPEP 09-MaS21 4th/2009 Soil Cs-134 Bq/kg 0 0 ----- Acceptable MAPEP 09-MaS21 4th/2009 Soil Cs-137 Bq/kg 683 669 468 - 870 Acceptable MAPEP 09-MaS21 4th/2009 Soil Fe-55 Bq/kg 810.0 796 557 - 1035 Acceptable MAPEP 09-MaS21 4th/2009 Soil K-40 Bq/kg 401.3 375 263 - 488 Acceptable MAPEP 09-MaS21 4th/2009 Soil Mn-54 Bq/kg 834.7 796 557 - 1035 Acceptable MAPEP 09-MaS21 4th/2009 Soil Ni-63 Bq/kg 640.0 680.0 476 - 884 Acceptable MAPEP 09-MaS21 4th/2009 Soil Sr-90 Bq/kg 423.30 455 319 - 592 Acceptable MAPEP 09-MaS21 4th/2009 Soil Zn-65 Bq/kg 1293 1178 825 - 1531 Acceptable MAPEP 09-MaW21 4th/2009 Water Co-57 Bq/L 35.7 36.6 25.6 - 47.6 Acceptable MAPEP 09-MaW21 4th/2009 Water Co-60 Bq/L 15.3 15.4 10.8 - 20.0 Acceptable MAPEP 09-MaW21 4th/2009 Water Cs-134 Bq/L 31.6 32.2 22.5 - 41.9 Acceptable MAPEP 09-MaW21 4th/2009 Water Cs-137 Bq/L 40.4 41.2 28.8 - 53.6 Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

65

TABLE C-1 ANALYTICS CROSS-CHECK PROGRAM

SUMMARY

Acceptance Ratio/

Sample Quarter / Sample Analyte / Reported Known Acceptance Number Year Media Nuclide Units Value Value Range¹ Evaluation E6374-278 4th/2008 Cartridge I-131 Pci 56.50 53.2 1.06 Acceptable MAPEP 09-MaW21 4th/2009 Water Mn-54 Bq/L 0.07 0.00 ---- Acceptable MAPEP 09-MaW21 4th/2009 Water Ni-63 Bq/L 45.8 44.2 30.9 - 57.5 Acceptable MAPEP 09-MaW21 4th/2009 Water Sr-90 Bq/L 16.40 12.99 9.09 - 16.89 Acceptable MAPEP 09-MaW21 4th/2009 Water Zn-65 Bq/L 28.9 26.9 18.8 - 35.0 Acceptable MAPEP 09-RdF21 4th/2009 Filter Co-57 Bq 6.730 6.48 4.54 -8.42 Acceptable MAPEP 09-RdF21 4th/2009 Filter Co-60 Bq 1.127 1.03 0.72 - 1.34 Acceptable MAPEP 09-RdF21 4th/2009 Filter Cs-134 Bq 0.034 0.00 ----- Acceptable MAPEP 09-RdF21 4th/2009 Filter Cs-137 Bq 1.397 1.40 0.98 - 1.82 Acceptable MAPEP 09-RdF21 4th/2009 Filter Mn-54 Bq 5.697 5.49 3.84 - 7.14 Acceptable MAPEP 09-RdF21 4th/2009 Filter Sr-90 Bq 0.778 0.84 0.585 - 1.086 Acceptable MAPEP 09-RdF21 4th/2009 Filter Zn-65 Bq 4.350 3.93 2.75 - 5.11 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Co-57 ug/sample 8.333 8.00 5.6 - 10.4 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Co-60 ug/sample 2.637 2.57 1.80 -3.34 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Cs-134 ug/sample -0.014 0.00 ---- Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Cs-137 ug/sample 2.443 2.43 1.70 - 3.16 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Mn-54 ug/sample 8.407 7.90 5.5 -10.3 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Sr-90 ug/sample 1.577 1.78 1.25 - 2.31 Acceptable MAPEP 09-RdV21 4th/2009 Vegetation Zn-65 ug/sample -0.029 0.00 ----- Acceptable

¹ The acceptable ratio is +/- 25% of the known value for Analytics.

66

APPENDIX D COMPARISON OF OPERATIONAL TO PREOPERATIONAL DATA AND ANALYSIS OF TRENDS 67

Comparison of Operational to Preoperational Data and Analysis of Trends Unit 1 achieved criticality on June 14, 1967 and was permanently retired from service on November 30, 1992. Unit 2 attained initial criticality on July 26, 1982 and Unit 3 on August 29, 1983.

A variety of environmental samples were analyzed and the analytical results (January 1, 1979 to July 31, 1982) were compared with the 2009 operational data obtained for SONGS Units 2/3.

The following media were evaluated and compared with the operational data of SONGS Units 1, 2 and 3:

A. External Radiation F. Ocean Bottom Sediments B. Air Particulates G. Marine Species C. Radioiodine H. Local Crops D. Ocean Water I. Soil E. Shoreline Sediment (sand) J. Kelp K. Drinking Water All of the measurements obtained from the SONGS Unit 1 operational Radiological Environmental Monitoring Program (REMP) during the period from January 1979 to July 1982 are used as the preoperational baseline for SONGS Units 2/3. This is in accordance with San Onofre Units 2/3, Environmental Report, Operating License Stage, Appendix 6A, Pre-operational Radiological Environmental Monitoring, May 31, 1978. Comparisons of preoperational data to 2009 operational data are possible for each of the exposure pathways to man, namely: (1) direct radiation, (2) air particulates (inhalation), and (3) ocean water (waterborne). Comparisons can also be made between preoperational and operational data for ocean bottom sediment data to ascertain if there has been any significant increase in radioactivity in ocean bottom sediments in the vicinity of the SONGS Units 2/3 outfalls.

Overall, the preoperational data are much higher than the operational data. The decrease in radioactivity is due primarily to the cessation of nuclear weapons testing and to the decay of fallout radionuclides. There is a close correlation between indicator and control data over several decades. See Figures 2A, 2B, 3A, 3B, 3C and 4. There are no indications of adverse effects from SONGS on the environment.

A. Direct Radiation SONGS Units 2/3:

Direct radiation measurements for the SONGS REMP were made quarterly at 38 indicator locations and 11 control locations in 2009. (See Appendix I for ISFSI TLD data). Direct radiation samples (TLDs) were collected at a number of inner and outer ring locations as specified by the ODCM. During the preoperational period from January 1979 to July 31, 1982, the indicator stations ranged from 16.1 to 46.6 millirem. The preoperational indicator average was 25.3 mR. The preoperational control range was 19.3 to 30.1 and the control mean was 23.1 mR. During the 2009 operational year for Units 2/3, the routine indicator TLD locations ranged 68

from 10.65 to 24.94 millirem, averaging 17.26 millirem while the control locations ranged from 12.88 to 20.11 millirem with an average of 16.47 millirem.

Factors such as meteorology, geographic location, the fallout from atmospheric nuclear weapons testing, and seasonal fluctuations account for the variability in the data seen during the preoperational period for each location. The decrease in radiation levels at all TLD sample locations is attributable to the curtailment of the atmospheric nuclear weapons testing, and the continued decay of fission products from previous nuclear weapons tests.

The average direct radiation doses were larger at both indicator and control locations during the preoperational period than during the 2009 operational period for SONGS Units 2/3. The larger average observed during the preoperational time span may be attributable to Chinese atmospheric nuclear weapons tests on March 14, 1978 and on October 15, 1980. The large average of the annual direct radiation levels seen at most TLD sample locations during 1986 and 1987 is attributable to the Chernobyl Nuclear Power Plant accident that occurred April 26, 1986.

Figure 2A and 2B compares the environmental radiation levels of selected indicator and control locations. Simultaneous variation in the radiation levels at both the control and indicator locations show that the variations are due to factors external to SONGS. The operation of SONGS had no impact on the environment as measured by this sample medium.

B. Air Particulates SONGS Units 2/3:

From January 1979 through July 1982 (considered to be the preoperational period for SONGS Units 2/3), there is a period of noticeably higher gross beta activity in air at all sample locations.

This period extends from the fourth quarter of 1980 through the fourth quarter of 1981. These higher activity levels are attributable to the Chinese atmospheric nuclear weapons test conducted on October 15, 1980.

Figures 3A, 3B, and 3C compare the monthly average gross beta particulate in air activity levels of selected indicator locations with the control location over a period of 32 years (January 1976 to December 2009). The data clearly show a close correlation between the indicator and control locations for the entire time period covered. The various spike increases in gross beta activity at all sample locations are closely grouped and timed to coincide with known events external to SONGS with worldwide radiological impact. These events include: Chinese atmospheric nuclear weapons testing on September 17, 1977; March 14, 1978; October 15, 1980; and the April 1986 Chernobyl accident. The graphs (Figures 3A, 3B and 3C) show that the environmental levels of gross beta remained substantially similar at both the indicator and the control locations over an extended period of time, with both control and indicator locations showing simultaneous variations of equal magnitude. The fluctuations in gross beta activity are not attributable to SONGS and are the result of other environmental phenomena and seasonal variations.

69

C. Radioiodine SONGS Units 2/3:

Most of the preoperational and all of the 2009 operational data for I-131 level were below the detection limit.

D. Ocean Water SONGS Units 2/3:

Ocean water samples were collected on a monthly basis in the vicinity of each of the Station discharge outfalls, which served as indicator locations, and from the Newport Beach control location. The ocean water samples are analyzed for naturally-occurring and station-related gamma-emitting radionuclides. They are composited quarterly and analyzed for tritium.

During the preoperational period, naturally-occurring potassium-40 was detected in each of the samples collected from both indicator and control locations. Other gamma-emitting radionuclides were detected in only one ocean water sample. In May 1980, Co-58, Co-60, Cs-l34, and Cs-137 were detected in an ocean water sample collected from the SONGS Unit l outfall. Concentrations of the radionuclides in this sample were 11, 6, 380, and 430 pCi/l, respectively. Tritium was also detected in two of the ocean water samples collected in May 1980 from the SONGS Unit 2 outfall and from the Newport Beach control location.

Tritium was detected in one indicator ocean water sample was below the a priori LLD but above the a posteriori MDC. The data for all other SONGS related radionuclides at all other ocean water locations during the 2009 operational period were below both the a priori LLD and the lower a posteriori MDC. We conclude that the operation of SONGS had a negligible impact on the environment as measured by this sample medium.

E. Shoreline Sediments (Sand)

SONGS Units 2/3:

Beach sand is collected semiannually from three indicator locations and from a control location situated at Newport Beach. The samples are analyzed for naturally-occurring and plant-related radionuclides.

To assess the impact of SONGS operations on this environmental medium, preoperational data were compared to 2009 operational data. The radionuclide detected in shoreline sediment in the preoperational time frame was Cs-137 with a range of 0.012 to 0.022 pCi/g, averaging 0.019 in 5 sediment samples. One control sample with a Cs-137 activity of 0.032 pCi/g was observed in July 1979. The presence of Cs-137 in both control and indicator locations during the preoperational period leads to the conclusion that the root cause is external to SONGS and is most likely attributable to atmospheric nuclear weapons testing. No SONGS-related radionuclides were detected in shoreline sediment during the 2009 operational period. Thus the 70

impact of SONGS on the environment as measured by the sample medium is considered to be negligible.

F. Ocean Bottom Sediments SONGS Units 2/3:

During the preoperational and operational periods, representative samples of ocean bottom sediments were collected semiannually from each of the Station discharge outfalls and from a control station in Laguna Beach. The samples were analyzed for naturally occurring and SONGS related radionuclides. The results of the analyses are listed in Table D-1B.

SONGS-related radionuclides were also detected in samples collected during preoperational period. Manganese-54 (Mn-54) was detected in 5 of the 28 samples. The concentrations of Mn-54 in these samples ranged from 0.015 to 0.49 pCi/g, averaging 0.13 pCi/g. Cobalt-58 (Co-58) was detected in nine samples. The concentration of Co-58 in the samples ranged from 0.013 to 1.16 pCi/g, averaging 0.20 pCi/g. Cobalt-60 (Co-60) was measured in 15 of the 28 samples. The concentration of Co-60 in the sample ranged from 0.014 to 8.l pCi/g, averaging 0.79 pCi/g. Cs-137 was also detected in 16 of the 28 samples. The concentrations of Cs-137 in the samples ranged from 0.014 to 0.090 pCi/g, averaging 0.039 pCi/g. Cerium-144 (Ce-144) was found in two samples. The concentration of Ce-144 in the samples was 0.06 and 0.26 pCi/g, respectively.

The results indicate that there has not been a build-up of radionuclides with time in ocean bottom sediments near SONGS. The results also indicate notable decrease in the concentrations of plant-related radionuclides in the ocean bottom sediment. Although Co-58, Co-60, and Cs-137 are normally associated with nuclear power operations, preoperational study reveals no accumulation trend for these radionuclides, and no increase in levels for these radionuclides was detected during the operational period.

The concentration of station-related radionuclides in all ocean bottom sediment samples analyzed in 2009 was below the a posteriori MDC. We conclude that operation of SONGS Units 2/3 has had a negligible impact upon this environmental medium.

71

TABLE D-1A SHORELINE SEDIMENTS CONCENTRATION (pCi/g, wet weight)

PREOPERATIONAL AND OPERATIONAL DATA*

SONGS UNITS 2/3 INDICATOR CONTROL Radionuclide** Period Range Average Range Average Cs-137 PreOp 0.012-0.022 0.019 <LLD-0.032 <LLD All other measured PreOp < LLD < LLD < LLD < LLD SONGS related radionuclides Operational < LLD < LLD < LLD < LLD TABLE D-1B OCEAN BOTTOM SEDIMENTS CONCENTRATION (pCi/g, wet weight)

PREOPERATIONAL AND OPERATIONAL DATA*

SONGS UNITS 2/3 INDICATOR CONTROL Radionuclide Period Range Average Range Average Mn-54 PreOp 0.0150-0.49 0.129 <LLD <LLD Co-58 PreOp 0.013-1.160 0.199 <LLD <LLD Co-60 PreOp 0.014-8.100 0.788 <LLD <LLD Ag-110m PreOp <LLD-0.020 <LLD <LLD <LLD Cs-137 PreOp 0.014-0.090 0.039 <LLD-0.043 <LLD Cs-137 Operational <LLD <LLD <LLD <LLD Ce-144 PreOp 0.060-0.260 0.160 <LLD <LLD All other measured PreOp < LLD < LLD < LLD < LLD SONGS related radionuclides Operational < LLD < LLD < LLD < LLD

• PreOp = January 1979 to July 1982; Operational - January to December 2009

• • During January to December 2009 all station related Radionuclides from all sample locations were < LLD LLD Lower limits of detection for operational data are listed in Appendix B.

72

G. Marine Species (Flesh)

SONGS Units 2/3:

Non-migratory marine species were collected semi-annually near SONGS to determine the amount of radioactivity that could be consumed by man or that was present in the food chain to man. Marine species caught by the SONGS outfalls and from Laguna Beach include two species of adult fish, crustacea and mollusks. Upon collection, the flesh portion is analyzed for gamma-emitting, radionuclides as specified in the ODCM. The results are subsequently reported as pCi/gram wet weight.

Results for several marine species for both the preoperational and 2009 operational periods for Units 2/3 are summarized in Table D-2. The marine species used for purposes of comparison include: sheephead (a fish), Blacksmith, black perch (a fish), bay mussel (a mollusk), spiny lobster (a crustacea), and keyhole limpet (a mollusk). Radionuclides analyzed but not included in Table D-2 were below the lower limits of detection for both the preoperational and operational periods.

During the 2009 operational period, no SONGS related radionuclides were detected at either the a priori LLD or the lower a posteriori MDC. The data indicate no accumulation trends. The operation of SONGS Units 2/3 in 2009 had no impact on the environment as measured by this sample medium.

73

TABLE D-2 MARINE SPECIES CONCENTRATIONS (pCi/g, wet weight) PREOPERATIONAL AND 2009 OPERATIONAL DATA (SONGS UNITS 2/3)*

Sheephead Flesh**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Co-58 PreOp 0.016-0.030 0.023 <LLD <LLD Co-60 PreOp 0.005-0.044 0.017 <LLD <LLD Ag-110m PreOp <LLD-0.004 <LLD <LLD <LLD Cs-137 PreOp 0.004-0.018 0.007 0.005-0.012 0.007 All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational < LLD < LLD < LLD < LLD radionuclides Black Perch Flesh**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Co-58 PreOp 0.009-0.011 0.010 <LLD <LLD Co-60 PreOp 0.004-0.045 0.017 <LLD <LLD Ag-110m PreOp 0.002-0.009 0.006 <LLD <LLD Cs-137 PreOp 0.003-0.015 0.008 0.004-0.014 0.009 All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational < LLD < LLD < LLD < LLD radionuclides

• PreOp = January 1979 to July 1982; Operational = January to December 2009. The species collected in 2009 were Bay Mussel, California Mussel, Black Perch, Blacksmith, Kelp Bass, Sheephead, and Spiny Lobster.

• • During January to December 2009 all station related Radionuclides from all sample locations were < LLD LLD Lower limits of detection for operational data are listed in Appendix B.

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TABLE D-2 MARINE SPECIES CONCENTRATIONS (pCi/g, wet weight) PREOPERATIONAL AND 2009 OPERATIONAL DATA (SONGS UNITS 2/3)*

Mussel Flesh (Bay or California)**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Mn-54 PreOp 0.009-0.025 0.017 <LLD <LLD Co-58 PreOp 0.008-0.080 0.028 -- --

Co-60 PreOp 0.005-0.40 0.077 <LLD <LLD Cs-137 PreOp 0.003-0.006 0.004 <LLD <LLD Ru-103 PreOp <LLD-0.045 <LLD <LLD <LLD All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational --- --- --- ---

radionuclides Spiny Lobster Flesh**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Co-58 PreOp 0.007-0.270 0.086 <LLD <LLD Co-60 PreOp 0.014-0.210 0.060 <LLD <LLD Cs-137 PreOp 0.005-0.011 0.008 0.040-0.015 0.008 All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational < LLD < LLD < LLD < LLD radionuclides

• PreOp = January 1979 to July 1982; Operational = January to December 2009. The species collected in 2009 were Bay Mussel, California Mussel, Black Perch, Blacksmith, Kelp Bass, Sheephead, and Spiny Lobster.

• • During January to December 2009 all station related Radionuclides from all sample locations were < LLD LLD Lower limits of detection for operational data are listed in Appendix B.

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TABLE D-2 MARINE SPECIES CONCENTRATIONS (pCi/g, wet weight) PREOPERATIONAL AND 2009 OPERATIONAL DATA (SONGS UNITS 2/3)*

Sea Hare Flesh**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Co-57 PreOp 0.006-0.017 0.009 <LLD <LLD Co-58 PreOp 0.006-12.4 1.233 <LLD <LLD Co-60 PreOp 0.016-2.000 0.448 0.003-0.027 0.013 Zn-65 PreOp <LLD-0.10 <LLD <LLD <LLD Ag-110m PreOp 0.018-0.50 0.138 0.020-0.039 0.030 Cs-137 PreOp <LLD-0.004 <LLD <LLD-0.005 <LLD All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational --- --- --- ---

radionuclides Keyhole Limpet (Flesh)**

INDICATOR CONTROL Radionuclide Period Range Average Range Average Co-58 PreOp 0.007-0.101 0.054 <LLD-0.190 <LLD Co-60 PreOp 0.021-0.040 0.033 <LLD-0.022 0.022 Ag-110m PreOp 0.033-0.101 0.054 0.005-0.042 0.022 Cs-137 PreOp <LLD <LLD <LLD-0.005 <LLD All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational --- --- --- ---

Radionuclides

• PreOp = January 1979 to July 1982; Operational = January to December 2009

• • Sea Hare and Keyhole Limpet samples were not collected in 2009 LLD Lower limits of detection for operational data are listed in Appendix B.

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H. Local Crops SONGS Units 2/3:

In the preoperational period of January 1979 through July 1982, Sr-90 was detected in the control samples of kale, parsley, and squash. Naturally occurring K-40 was detected in cucumber, kale, and tomato samples from the indicator and control locations. Ce-144 and Zr-95 were detected in one sample of parsley at the control location at concentrations of 0.12 and 0.09 pCi/g, wet weight respectively.

In the 2009 operational period, only naturally occurring radionuclides were detected in the crop samples. The operation of SONGS had no impact on the environment as measured by this sample medium.

I. Soil SONGS Units 2/3:

A comparison of operational and preoperational data does not reveal any accumulation pattern of SONGS related isotopes in soil. The intermittent detection of Cs-137 in both indicator and control locations is due to residual fallout from atmospheric nuclear weapons testing.

J. Kelp SONGS Units 2/3:

Kelp is collected semiannually from three indicator locations and from a control location situated in Laguna Beach. After collection, the samples are analyzed by gamma-spectral analysis for naturally-occurring and SONGS-related radionuclides. During 2009 four additional control sample locations were analyzed.

To assess the impact of SONGS operations on kelp, preoperational data were compared to 2009 operational data in Table D-4. Radionuclides detected during the preoperational period for SONGS Units 2/3 include Mn-54, Co-60, Zr-95, I-131, and Cs-137.

During the 2009 operational period, I-131 was detected in all samples. No other station related isotopes were detected in kelp samples during the 2009 operational period. Figure 4 (I-131 in Kelp) shows a close correlation between indicator and control sample locations over an extended period of time.

Although I-131 activity has been randomly detected in kelp since 1977, there is no evidence that the concentration of I-131 or other station related radionuclides in kelp is increasing near SONGS. I-131 in kelp is due to the sewer release of medical administrations, since it has been detected consistently in control as well as indicator locations. Since 1988 the concentration of I-131, when detected, has typically been highest at the control location. These data support the conclusion that during the Units 2/3 operational period, the detection of I-131 in kelp is primarily due to factors external to SONGS.

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K. Drinking Water No plant related radionuclides were detected during the 2009 operational period. Gross beta activity was detected during both the operational and preoperational periods at both the indicator and the control locations. No trends have been noted. There is no drinking water pathway for SONGS. The operation of SONGS had no impact on the environment as measured by this sample medium.

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TABLE D-3 SOIL PREOPERATIONAL AND OPERATIONAL DATA* (pCi/g, dry weight)

SONGS UNITS 2/3 INDICATOR CONTROL Radionuclide Period Range Average Range Average Sr-90 PreOp 0.02-0.08 0.044 <LLD-0.03 <LLD Cs-137 PreOp 0.02-0.20 0.096 <LLD-0.06 <LLD Cs-137 Operational < LLD-0.393 0.111 0.267 0.267 All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational < LLD < LLD < LLD < LLD radionuclides TABLE D-4 KELP PREOPERATIONAL AND OPERATIONAL DATA* (pCi/g, wet weight)

SONGS UNITS 2/3 INDICATOR CONTROL Radionuclide Period Range Average Range Average Mn-54 PreOp <LLD-0.005 <LLD <LLD <LLD Co-60 PreOp 0.006-0.009 0.008 <LLD <LLD Zr(Nb)-95 PreOp 0.014-0.090 0.046 0.018-0.053 0.036 I-131 PreOp 0.006-0.024 0.013 0.008-0.030 0.014 I-131 Operational 0.010 - 0.092 0.046 0.029 - 0.152 0.076 Cs-137 PreOp 0.004-0.009 0.006 <LLD <LLD All other PreOp < LLD < LLD < LLD < LLD measured SONGS related Operational < LLD < LLD < LLD < LLD radionuclides

• PreOp = January 1979 to July 1982; Operational = January to December 2009 LLD Lower Limit of Detection for operational data are listed in Appendix B.

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APPENDIX E DEVIATIONS FROM ODCM SAMPLING REQUIREMENTS IN 2009 80

DEVIATIONS FROM ODCM SAMPLING REQUIREMENTS Deviations from the ODCM sampling requirements are identified below in accordance with section 5.0 of the ODCM. The performance standard for environmental data collection of 95%

was met for all sample types. During 2009, the ODCM specified a priori LLD was achieved for most REMP samples. Deviations from the ODCM were associated with external factors not within the control of REMP personnel such as limited availability of marine samples at the locations specified in the ODCM. The 2009 ODCM deviations had no meaningful impact on the REMP database and did not compromise the validity of the reported conclusions.

PART I TERRESTRIAL SAMPLING A. WEEKLY AIR SAMPLING Downtime for each air sampler in 2009 due to weekly sample collection, annual preventive maintenance (PM), and the annual gas meter change out was approximately 46 minutes for each sampler.

Weekly Change out: Approximately 0.5 minutes x 52 = 26 minutes Annual PM: Approximately 15 minutes Annual Gas Meter change out: Approximately 5 minutes Down times in excess of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> are described below for each ODCM required air sample.

Air Sampler 1 (City of San Clemente): No deviations were observed.

Air Sampler 9 (State Beach Park): No deviations were observed Air Sampler 12 (Former SONGS Evaporation Pond): No deviations were observed Air Sampler 13 (Camp Pendleton East): This sampler had 11.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of down time due to external power outages.

Air Sampler 15 (Oceanside Control): No deviations were observed.

Summary of Air Sampler Corrective Actions The useful life of the vacuum pump motor assemblies is estimated to be five years based on the recommendation of the manufacturer and upon experience. If the internal components (motor and control valve) are replaced the useful life may be extended. During 2009 the REMP air samplers experienced no down time attributable to motor or vacuum pump assembly failure.

Thus there were no avoidable air sampler deviations from the ODCM during 2009.

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B. DIRECT RADIATION TLD # 34 was not on station for the first quarter 2009. The TLD canister was found broken.

C. LOCAL CROPS No deviations were observed.

D. SHORELINE SEDIMENTS No deviations were observed.

E. DRINKING WATER No deviations were observed.

F. SOIL No deviations were observed.

PART II MARINE SAMPLING A. NON-MIGRATORY MARINE ANIMALS Samples were collected from the specified ODCM sample location when samples were available at that location. When the specified sample type was not available at the ODCM listed location, alternate locations were selected based on sample availability and proximity to the specified sample location. All indicator samples were obtained within two miles of the associated outfall. In some cases the indicator species is not the same as the control species due to limited availability at the indicator location. Most non-migratory marine species samples were not available at the locations specified in the ODCM. All indicator marine animal samples were collected within 2 miles of the Units 2

& 3 discharge diffusers.

B. OCEAN WATER SAMPLING No deviations were observed.

C. OCEAN BOTTOM SEDIMENTS No deviations were observed.

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APPENDIX F LAND USE CENSUS 83

INTRODUCTION Southern California Edison conducted the annual 2009 Land Use Census (LUC) in accordance with section 5.2 of the ODCM. The purpose of the LUC is to identify important radiological exposure pathways to humans. The LUC identifies the nearest residences, milk animals, meat animals, gardens of at least 500 square feet that produce fleshy or leafy vegetables, and other specified uses (campgrounds, employment, etc.) in each of the meteorological landward sectors within five miles of SONGS. Results are summarized in Table F-1 and F-2 at the end of this appendix.

THE STUDY AREA The study area includes half of the city of San Clemente (population estimated at 68,316 as of January 1, 2009), the San Clemente State Park, U.S. Marine Corps Base Camp Pendleton (MCB), San Onofre State Beach and Park, the San Clemente Ranch (now known as Seaview Farm), the former U. S. Coast Guard Station at San Mateo Point, and SONGS.

METHODOLOGY A review of the 2009 LUC and documentation notebook was conducted. Verification and revision of the 2009 data was accomplished by inquiry to the cognizant agency, organization, or individual possessing direct knowledge of the item being verified.

The garden census was performed by examining aerial photographs taken. The photographic image areas which appeared to correspond to likely garden locations were converted to street addresses. The corresponding residences were observed from the nearest public road to determine if a garden was present. If the entire property was not visible from the street then a garden was assumed to be present.

The closest residence was established in each sector by correspondence with cognizant authorities (City of San Clemente Planning Department and USMC Camp Pendleton). The meat and milk animal survey was performed by contacting the natural resources office on Camp Pendleton, the Orange County Agricultural Commissioner, and the County of San Diego Department of Agriculture. Information on other uses was obtained by contacting the appropriate organizations.

DEFINITIONS Residence is defined as any structure (single-family house, apartment, mobile home, barracks or similar unit) occupied by individual(s) for three months (2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) or longer per year.

Other Specified Use is defined as a location occupied by members of the general population as other than their primary residence. The use is divided into two categories: employment and non-employment related.

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Employment use is defined as a location occupied by members of the general population engaged in normal work activities regardless of the length of time spent at the location, and regardless of its permanence, including concession stands, restaurants, markets and guard shacks.

Non-employment-related use is defined as a location occupied by members of the general population who are not engaged in normal work activities, including campgrounds, temporary housing, time-share condominiums, motels, hotels, schools and beaches.

Milk animals include, but are not limited to cows, goats and sheep, whose milk is used in dairy products for human consumption.

Meat animals include, but are not limited to deer, other game animals, cattle, goats and sheep, whose meat is used for human consumption.

Leafy vegetables include, but are not limited to lettuce, cabbage, collard greens, Bok choi, sorrel, and spinach.

Fleshy vegetables include, but are not limited to tomatoes, cucumbers, cauliflower, squash, beans, zucchini, and sweet corn.

SUMMARY

OF CHANGES Summary of Changes

1. Unnecessary information, not specified in the procedure, has been removed from the LUC report. Non-residential uses further away than the closest residence have been deleted.

2. Obsolete references to the distance from the Unit1 plant vent stack have been deleted.

3. San Onofre III housing was completed and occupied during 2009. This is the closest permanent structure residence for all age groups in Sectors Q and R.

4. LUC # R-R3 - Camp Mesa Dry Camping had an estimated occupancy of 3100 hours0.0359 days <br />0.861 hours <br />0.00513 weeks <br />0.00118 months <br /> in 2009.

5. Age group data has been included for transient residences. Permanent residences are presumed to be occupied by all age groups. Permanent residences known to be occupied only by adults (Camp Pendleton barracks) are identified.

85

6. The San Onofre State Beach campground was occupied by only one surf camp in 2009. LUC

1. O-2C - Surfcamp.com and O-2B YMCA surf camp did not occupy camping spaces at San Onofre during 2009.

7. The Camp Pendleton hunting take for the period July 1, 2008 to June 30, 2009 is listed in Table 2 of the 2009 LUC. Per the base wildlife biologist, the exact location of a particular kill is not known. The reported take area should be interpreted as an estimate of approximate location.

Thus a deer reported as taken in hunting area Alpha 2 may actually have been taken in an adjacent hunting area (such as Romeo 3 or Bravo 3). There are no changes to the estimated distances from SONGS to the nearest vegetation potentially consumed by deer for 2009.

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TABLE F-1 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet Estimated Hours of Maximum Occupancy Units Miles 2/3 From Sector LUC # Residence U2/3 A R-A1 Camp San Mateo 3.6 FTR R-A2 SONGS Camp Mesa 0.4 8,030 B

C R-C2 Camp San Onofre Fire Station 2.4 3,744 R-C1 Camp San Onofre Barracks 524101 2.8 FTR D R-D1 Camp San Onofre Barracks 3.0 FTR E R-E1 Camp Horno Barracks 4.1 FTR F

G Sectors H, J, K, L,M, and N have no identified land uses These Sectors are primarily the Pacific Ocean and contain only a small portion of the plant site, and a beach walkway providing access for state beach park users north & south of SONGS.

P R-P3 San Onofre Rec Beach (SORB) 1.0 FTR R-P2 San Mateo Point Housing 2.7 FTR R-P1 Cotton Point Estates 2.7 FTR Q R-Q5 SORB Resident Employee 1.1 FTR R-Q2 San Onofre III (See notes for Table 1) 1.4 FTR R-Q3 San Mateo Point Housing 2.7 FTR R R-R2 SONGS Camp Mesa (See notes for Table 1) 0.4 8,030 R-R3 SONGS Dry Camping PL12 0.7 3,100 R-R1 San Onofre III (See notes for Table 1) 1.3 FTR Bolt Text indicates changes from 2008 LUC Data as of 10-1-2009 FTR - Full Time Residence 87

TABLE F-2 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet Units Miles 2/3 From Sector LUC # Gardens U2/3 A

B C

D E

F G

Sectors H, J, K, L,M, and N have no identified land uses These Sectors are primarily the Pacific Ocean and contain only a small portion of the plant site, and a beach walkway providing access for state beach park users north & south of SONGS.

P G-3 Cotton Point Estate 2.8 Q G-8 2240 Ave Salvador 4.1 G-5 1706 S Ola Vista 4.4 G-6 1315 S Ola Vista 4.6 R G-10 SONGS Garden 0.4 Bolt Text indicates changes from 2008 LUC Data as of 10-1-2009 FTR - Full Time Residence 88

TABLE F-3 2009 SONGS Units 2/3 LUC Five-Mile Radius Summary Sheet Estimated Hours of Maximum Units Miles 2/3 From Occupancy Sector LUC # Other Specified Uses U2/3 A O-8 Camp San Mateo Motor Pool 3.6 2,000 22 SCE Land Uses 0.4 ---

B O-9 USMC CP Sanitary Land Fill 2.1 624 C O-10 Camp San Onofre (STP #11) 2.2 2,000 D

E O-5 Camp Horno Motor Pool 4.0 2500 F O-1 San Onofre State Beach Guard Shack 0.8 1,500 31A Border Patrol Checkpoint (NB) 1.9 2,256 31B Hwy Patrol Weigh Sta (NB) 2.1 1,960 G O-2 San Onofre Beach Campground 1.8 720 32 Hwy Patrol Weigh Sta (SB) 2.1 1,960 O-2A Surf Camp Employees / Campground Host 2.8 4,380 Sectors H, J, K, L,M, and N have no identified land uses These Sectors are primarily the Pacific Ocean and contain only a small portion of the plant site, and a beach walkway providing access for state beach park users north & south of SONGS.

P O-6 Surf Beach (Lifeguard) 0.5 800 3 Trestles Beach Lookout Tower 1.8 500 Q O-3 State Park Office Trailer 0.6 2,000 5 Surf Beach Guard Shack 0.7 1,500 18 SORB Lifeguard Tower 1.2 2,000 1A SORB Campground Checkin 1.3 2000 R

Bolt Text indicates changes from 2008 LUC Data as of 10-1-2009 FTR - Full Time Residence 89

APPENDIX G FIGURES FOR 2009 90

MARINE ECOS YSTEM AQUATIC ECOS YSTEM

~ I_ TERRESTRIAL

- -- - - -- - - . . 1 - -- - - - - - - ECOSYSTEM ~I

---

l~

~---------y-----~

ESTUARINE ECOSYSTEM NuReg/CRm;u,QRPlb~()S,-------------------------------------------~

"Radiological Assessment" Figure 1. Potential Radiation Exposure Pathways Leading to Man 91

Direct Radiation Monitoring 1981 to 1999 Quarterly Environmental TLD dose measurements in mR Selected TLDs located very close to SONGS vs. Selected CONTROL TLDs 50 40 30 20 10 0

TLD 11 .... 0.4 miles NW CONTROL TLD 44 .... 17.7 miles E TLD 12 .... 0.2 miles E TLD 58 .... 0.1 miles S Mean of CONTROL TLDs 31 & 50 TLD 59 .... 0.3 miles WNW Figure 2A 92

Direct Radiation Monitoring 1996 to 2009 Quarterly Environmental TLD dose measurements in mR Selected TLDs located very close to SONGS vs. Selected CONTROL TLDs 50 40 30 20 10 0

TLD 11 .... 0.4 miles NW CONTROL TLD 44 .... 17.7 miles E TLD 12 .... 0.2 miles E TLD 58 .... 0.1 miles S Mean of CONTROL TLDs 31 & 50 TLD 59 .... 0.3 miles WNW Figure 2B 93

Monthly Average Airborne Particulate Gross Beta Activity 0.5 Preoperational and Operational Data for SONGS Units 2 and 3 fallout from Chinese Atmospheric Nuclear 0.4 Weapons Test fallout from Sept. 1977 Chernobyl fallout from Chinese 0.3 Atmospheric Nuclear Weapons Test March 1978 fallout from Chinese 0.2 Atmospheric Nuclear Weapons Test Oct. 1980 SONGS Unit 2 start up July 26, 1982 SONGS Unit 3 0.1 start up August 29, 1983 0

San Clemente City Hall .... 5.1 Miles NW State Beach Park .... 0.6 Miles ESE Huntington Beach (CONTROL) .... 31.1 Miles NW Bluff .... 0.7 Miles WNW Figure 3A 94

Monthly Average Airborne Particulates Gross Beta Activity SONGS Units 2 and 3 from January 1988 to December 1997 0.5 0.4 0.3 0.2 0.1 0

City of San Clemente (City Hall) Huntington Beach (CONTROL) Marine Corp Base (Camp Pendleton East)

Figure 3B 95

Monthly Average Airborne Particulates Gross Beta Activity SONGS Units 2 and 3 January 1998 to December 2009 0.5 0.4 0.3 0.2 0.1 0

City of San Clemente (City Hall) Marine Corp Base (Camp Pendleton East) Oceanside City Hall (CONTROL)

Figure 3C 96

"Weekly Airborne Particulate Gross Beta Activity SONGS Units 1, 2 and 3" 0.1 0.09 0.08 0.07 0.06 0.05 0.04 0.03 0.02 0.01 0

City of San Clemente (City Hall)

Marine Corp Base (Camp Pendleton East)

Oceanside City Hall (CONTROL)

Figure 3D 97

I-131 in Aquatic Kelp 0.4 0.35 0.3 0.25 NOTE: CONTROL location samples are obtained from either Laguna Beach or Salt Creek 0.2 0.15 0.1 0.05 0

San Onofre Kelp Bed Barn Kelp Bed San Mateo Kelp Bed CONTROL Figure 4 98

APPENDIX H ERRATA TO THE 2008 AREOR All data required by the ODCM in 2008 was reported in the 2008 AREOR. There are no errata to be appended to the 2008 AREOR.

99

APPENDIX I REMP TLDs CO-LOCATED WITH DPH TLDs DURING 2009 100

APPENDIX I REMP TLDs CO-LOCATED WITH DPH TLDs DURING 2009 Requirements in the standard Technical Specifications adopted under the Technical Specifications Improvement Program include reporting results of those thermoluminescent dosimeters (TLDs) that are co-located with NRC dosimeters. The NRC no longer deploys TLDs in the environs of SONGS. Some SCE TLDs are located adjacent to the former NRC TLD locations and these SCE TLDs are listed below.

California Department of Public Health (DPH) also maintains a TLD program in the environs of SONGS.

The below listed quarterly TLD data is from the SCE TLDs adjacent to the DPH TLD programs.

The NRC location numbers refer to the locations in the old NRC program.

2009 Data from SCE TLDs 1st 2nd 3rd 4th Location Number Location Name Qtr Qtr Qtr Qtr SCE 1 , NRC 7, DPH #2 San Clemente 18.45 17.95 18.9 18.98 SCE 2, NRC 23, DPH #8 Camp San Mateo 19.48 17.47 21.97 18.73 SCE 3, NRC 19, DPH #9 Camp San Onofre 17.33 14.92 18.95 16.15 SCE 6, DPH #10 Old Route 101 13.16 11.04 12.52 11.91 (East-Southeast)

SCE 10, NRC 12, DPH #6 San Onofre Surfing Beach 18.18 15.35 18.23 16.83 SCE 16, DPH #7* ESE Site boundary 19.67 15.63 19.95 16.78 SCE 22, NRC 11, DPH #4 Coast Guard Station 18.99 16.34 20.49 18.79 SCE 34, NRC 14, DPH #5 San Onofre Elementary

---

* 14.65 17.73 15.6 School SCE 41, NRC 25, Old Route 101 (Unit 3) 17.04 14.55 17.44 15.49 DPH #11**

SCE 50, NRC 32, DPH #13 Oceanside Fire Station 17.5 16.81 18.63 16.44

• 1 1st quarter 2009 TLD data for SCE-34 is not available

• SCE 16 is approximately 15 meters from DPH 7. DPH 7 is across Basilone Rd

• • SCE 41 is approximately 120 meters from DPH 11. Results included per DPH request 101

Appendix J ISFSI (Independent Spent Fuel Storage Installation) TLD Data 102

ISFSI (Independent Spent Fuel Storage Installation) TLD Data Per 10 CFR 72.126, SONGS implemented an environmental TLD program in the vicinity of the ISFSI. In the fourth quarter of 2001, 21 pre-operational TLDs were deployed in the area around the ISFSI foundation then under construction. The pre-operational TLDs data are compared to the data obtained after the commencement of used fuel storage in the ISFSI for the purposes of estimating the additional dose potentially attributable to the operation of the ISFSI.

An evaluation of the entire REMP TLD database yielded estimated background dose rate of approximately 15 mR / std quarter. However, some local variability within the CAB / EAB are to be attributable to factors external to SONGS (such as micro-geological variations). Another variable for the measured dose rate is transit dose to and from the TLD lab. The transit dose is variable and is corrected by the lab but the issue of TLD shipment packaging geometry can not be readily corrected. Therefore, a comparison of pre-operational data and operational data needs to be considered in conjunction with a comparison of ISFSI TLD data and the background dose rate estimate. Using this information, we conclude that the dose rate at the CAB (10 CFR 72 Controlled Area Boundary) is less than detectable. The dose attributable to the operation of the ISFSI as indicated by this media is not measurable beyond the immediate area of the ISFSI.

During the fourth quarter 2009 the storage of the original Steam Generators from Unit 2 near the ISFSI in the NIA (North Industrial Area) elevated the dose rate measurably in the immediate area of the ISFSI. The original steam generators did not affect the dose rate at the CAB/ EAB.

Environmental dose rates are variable. The REMP TLD data show a seasonal variability that does not appear to be related to any activities at SONGS. Data from the REMP indicator and control TLDs increase and decrease in a synchronous manner. The data support the conclusion that macro-environmental factors are the causative agents for the variations. Refer to Figure 2a and 2b. The ISFSI TLD data gathered to date appears to follow a similar seasonal variability.

Refer to Figures 6-1, 6-2, and 7a. In addition to environmental factors, some non-ISFSI work activities at Unit 1 have elevated the pre-operational measured ISFSI TLD dose. The storage and transport of radioactive materials and waste near the location of the ISFSI foundation area in 2001 and 2002 appears to have elevated the dose rates of TLDs 306 to 315. In addition, the removal of the Unit 1 reactor vessel in October 2002 caused a noticeable increase in the measured dose for TLDs 301 to 315. Refer to Tables J-1 and J-2 which list all the REMP and ISFSI TLD data within the 10 CFR 72 Controlled Area Boundary and the 10 CFR 50 EAB (Exclusion Area Boundary).

The measured dose rate for the ISFSI TLDs close to the ISFSI is consistent with the dose rate expected from known radiological work activities. The elevated dose rate from TLDs 336,337 and 338 is due to the movement and storage of used fuel at the ISFSI.

The TLDs close to the ISFSI foundation (TLDs 306 to 315) all showed a decrease in measured dose after the commencement of used fuel storage in the ISFSI. Refer to Table J-1. This decrease in measured dose may be attributable to the aforementioned seasonal variability of environmental dose rates or it may be attributable to the decrease in non-ISFSI radioactive material work activity in the Unit 1 area.

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In the fourth quarter 2008, 5 TLDs were placed on the perimeter fence west, southwest, and southeast of the ISFSI module. These TLDs (322, 323, 324, 325, and 326) showed the highest measured dose in 2009. The closest publicly accessible location SW of the ISFSI is the San Onofre Beach access road. The TLDs located along the access road measured a dose indistinguishable from background in 2009.

Starting in the fourth quarter 2009 neutron dosimeters were placed in ISFSI TLD canisters 311, 324, 325, and 326. The neutron signal from these TLDs is consistent with the projected neutron dose rates (calculation SCE-23-0508) and is consistent with known ISFSI radiological conditions. The measured ISFSI gamma TLD dose rates were also determined to be consistent with the calculated ISFSI dose rates and known radiological conditions.

We conclude that dose attributable to the storage of used fuel in the ISFSI is not measurable beyond the immediate area of the ISFSI and is well below regulatory limits. We further conclude that dose to a member of the general public attributable to all SONGS related radiological activities at the CAB / EAB is below regulatory limits.

104

TABLE J-1 ISFSI TLD DATA ISFSI TLD 2001 2002 2003 2004 Number Location 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr (1) 1st Qtr 2nd Qtr 3rd Qtr (2) 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr TLD 301 (3) 17.3 18.42 17.91 18.51 24.56 17.23 18.47 17.09 17.39 18.86 18 17.7 15.49 TLD 302 (3) 20.28 20.67 19.59 19.46 125.78 20.32 20.77 19.3 21.97 23.57 26.37 20.02 19.11 TLD 303 (3) 18.96 18.82 18.26 18.11 156.89 20.45 25.74 26.56 27.06 28.54 29.98 24.59 24.72 TLD 304 (3) 18.06 19.1 18.28 17.95 64.53 19.57 28.34 33.25 31.8 34.72 33.22 29.74 28.44 TLD 305 (3) 18.99 20.49 19.68 19.82 147.33 TLD 306 (3) 17.23 18.56 16.91 17.07 29.6 19.03 19.75 17.3 17.27 18.85 17.31 15.7 16.08 TLD 307 (3) 17.34 19.61 17.68 17.36 23.35 24.07 20.3 16.24 16.82 18.07 17.62 15.53 15.11 TLD 308 (3) 18.75 20.11 18.9 18.68 27.22 21.82 21.31 18.35 18.73 20.55 21.72 18.11 15.82 TLD 309 (3) 18.74 23.09 23.43 24.43 30.53 21.78 20.49 18.44 16.85 20.15 21.44 18.72 17.34 TLD 310 (3) 19.79 25.82 23.47 21.49 25.8 20.74 19.05 18.96 17.59 21.17 21.28 18.19 17.15 TLD 311 (3) 21.29 29.93 25.33 26.43 26.61 25.24 23.59 21.8 19.99 19.06 20.43 18.04 17.52 TLD 312 (3) 21.86 34.08 28.45 30.07 26.45 28.46 27.71 19.88 16.15 15.5 13.87 15.23 13.35 TLD 313 (3) 24.95 36.84 28.78 26.49 25.44 25.78 26.34 25.6 23.4 22.87 21.14 20.68 20.0 TLD 314 (3) 20.67 22.28 20.15 19.58 18.8 19.74 20.23 19.3 19.85 18.84 19.06 17.68 15.83 TLD 315 (3) 23.37 25.7 22.77 22.58 20.82 24.06 23.18 22.77 21.49 20.89 21.36 19.26 18.13 TLD 316 (4) 16.96 18.81 17.83 16.29 18.01 16.72 17.76 16.01 14.97 16.68 19.06 15.15 14.45 TLD 317 (4) 18.07 19.87 20.62 17.95 18.43 16.86 18.82 17.12 16.02 17.41 17.51 16.96 14.94 TLD 318 (4) 17.86 18.91 19.59 18.4 18.3 17.62 19.01 17.72 16.95 18.15 18.31 16.34 16.37 TLD 319 (4) 17.78 19.76 20.01 19.02 18.35 19.14 19.54 18.57 15.88 17.22 19.19 16.48 16.54 TLD 320 (4) 17.83 19.39 19.11 18.34 18.25 17.78 19.41 17.8 16.94 16.36 19.18 16.34 15.93 TLD 321 (4) 18.52 19.84 20.45 18.67 19.41 19.83 21.1 18.46 17.82 18.89 20.8 16.92 15.5 TLD 336 39.12 31.35 30.77 24.63 TLD 337 36.03 49.65 65.77 47.51 TLD 338 45.83 38.84 36.06 30.27 (1) Large Component Removal and start of the long term storage of the Unit 1 Reactor Vessel.

(2) Fuel loaded into the ISFSI pad September 2003.

(3) These TLDs are in an area where radiological materials have been stored or transported.

(4) These TLDs are not in the proximity of radiological activities.

105

TABLE J-1 ISFSI TLD DATA 2005 2006 2007 2008 ISFSI TLD rd rd Number 3 2nd 3 3rd 3rd 1st Qtr 2nd Qtr 4th Qtr 1st Qtr 4th Qtr 1st Qtr 2nd Qtr 4th Qtr 1st Qtr 2nd Qtr 4th Qtr Location Qtr Qtr Qtr Qtr Qtr TLD 301 (3) 22.05 33.23 31.2 27.44 31.54 26.99 20.41 18.96 18.11 15.62 19.39 15.76 16.09 15.69 17.96 17.59 TLD 302 (3) 31.04 45.99 41 40.43 40.3 35.93 28.72 20.75 19.98 17.1 20.76 16.98 17.43 19.22 19.57 19.55 TLD 303 (3) 33.14 49.45 41.54 38.53 39.16 34.51 29.14 25.08 24.93 21.13 20.21 18.09 18.2 21.83 20.85 20.74 TLD 304 (3) 34.63 42.62 41.1 37.05 36.66 37.95 29.07 29.71 27.48 25.27 21.85 16.89 17.64 19.77 20.4 19.6 TLD 306 (3) 19.92 20.4 20.44 19.24 19.68 24.01 17.65 18.5 19.04 15.95 19.56 17.00 17.42 18.59 19.04 19.55 TLD 307 (3) 20.26 24.94 22.08 20.98 21.48 23.22 16.98 16.66 16.93 14.97 19.26 19.07 17.72 25.3 27.32 24.1 TLD 308 (3) 21.81 25.3 23.88 23.1 23.42 23.89 18.01 17.82 18.00 14.94 20.56 20.41 18.42 19.22 19.72 20.14 TLD 309 (3) 22.1 20.61 19.53 18.14 18.95 22.54 17.08 19.25 17.83 16.86 19.76 19.09 17.09 19.56 20.43 19.67 TLD 310 (3) 20.66 20.91 21.08 20.26 20.27 24.21 17.92 19.01 19.21 17.36 20.63 19.22 17.03 19.33 19.54 19.95 TLD 311 (3) 21.85 20.94 20.61 19.35 19.48 23.91 17.82 19.49 19.51 16.88 19.27 18.08 16.88 18.23 19.26 18.04 TLD 312 (3) 16.88 15.67 15.57 13.81 14.99 19.36 16.18 16.08 15.29 13.47 15.84 14.24 13.13 13.72 14.6 14.62 TLD 313 (3) 26.97 26.36 26.45 25.93 26.33 33.12 36.28 25.34 22.97 20.26 20.33 TLD 314 (3) 21.79 20.26 20.83 20.05 20.67 28.09 45.96 24.18 18.31 15.54 17.7 17.12 15.92 16.31 17.84 18.8 TLD 315 (3) 22.84 20.28 20.61 19.65 20.61 28.62 36.53 22.32 18.54 16.36 18.67 18.36 16.57 16.91 17.82 18.52 TLD 316 (4) 19.02 18.62 19.70 19.50 19.34 21.30 14.77 16.59 17.15 13.08 16.18 15.76 14.54 15.08 17.16 17.54 TLD 317 (4) 20.04 21.48 21.19 19.89 21.21 23.92 17.57 16.77 17.54 14.28 17.21 15.88 15.08 16.02 17.53 16.71 TLD 318 (4) 21.56 19.82 19.23 18.44 19.22 23.38 16.96 17.93 20.25 15.77 20.37 17.59 17.95 17.15 18.90 18.58 TLD 319 (4) 20.94 19.42 19.02 18.13 18.23 21.76 15.88 16.45 19.86 15.11 18.31 17.52 16.75 16.99 18.58 17.58 TLD 320 (4) 21.89 19.91 20.42 19.54 20.39 23.05 17.29 17.10 19.68 15.64 18.66 16.89 17.17 16.73 18.80 17.51 TLD 321 (4) 21.34 20.15 20.83 20.12 20.75 23.67 17.90 18.03 20.48 16.71 18.91 17.94 17.06 17.38 19.21 18.39 TLD 322 17.84 TLD 323 18.14 TLD 324 21.3 TLD 325 18.37 TLD 326 21.09 TLD 336 39.5 63.71 67.54 73.3 78.47 51.74 61.25 34.02 60.62 61.1 64.19 TLD 337 54.46 64.07 59.43 68.36 62.62 92.87 116.8 44.67 54.8 39.09 43.46 TLD 338 40.18 44.51 42.75 46.49 42.78 45.02 51.58 36.63 34.45 26.48 29.42 (1) Large Component Removal and start of the long term storage of the Unit 1 Reactor Vessel.

(2) Fuel loaded into the ISFSI pad September 2003.

(3) These TLDs are in an area where radiological materials have been stored or transported.

(4) These TLDs are not in the proximity of radiological activities.

106

TABLE J-1 ISFSI TLD DATA ISFSI TLD 2009 2009 2009 2009 Number Location 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr TLD 301 (3) 17.48 17.07 19.32 27.07 TLD 302 (3) 19.22 18.31 22.4 50.95 TLD 303 (3) 21.41 20.36 22.6 41.75 TLD 304 (3) 20.67 19.63 22.09 35.49 TLD 306 (3) 20.31 18.69 20.8 25.33 TLD 307 (3) 20.16 16.56 18.76 21.19 TLD 308 (3) 20.5 19.45 20.78 20.96 TLD 309 (3) 20.3 19.6 21.79 20.41 TLD 310 (3) 20.27 19.46 21.35 20.04 TLD 311 (3) 19.62 18.48 21.41 19.03 TLD 312 (3) 15.32 14.29 16.41 14.9 TLD 313 (3)

TLD 314 (3) 19.21 17.84 21.12 18.76 TLD 315 (3) 18.94 17.77 18.81 18.33 TLD 316 (4) 17.04 15.87 17.79 18.03 TLD 317 (4) 17 15.69 16.92 19.34 TLD 318 (4) 20.16 17.15 19.51 18.65 TLD 319 (4) 19.18 17.39 19.7 18.86 TLD 320 (4) 18.18 16.58 19.83 18.55 TLD 321 (4) 19.2 17.75 20.04 19.07 TLD 322 19.12 17.92 20.4 19.02 TLD 323 20.09 19.45 20.92 21.74 TLD 324 24.28 24.14 25.55 35.08 TLD 325 20.79 22.4 27.74 106.39 TLD 326 26.29 28.3 30.26 38.73 TLD 336 TLD 337 TLD 338 (1) Large Component Removal and start of the long term storage of the Unit 1 Reactor Vessel.

(2) Fuel loaded into the ISFSI pad September 2003.

(3) These TLDs are in an area where radiological materials have been stored or transported.

(4) These TLDs are not in the proximity of radiological activities.

107

TABLE J-2 REMP TLDs WITHIN THE EAB REMP 2001 2002 2003 2004 TLD Number 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Location (1) (2) 11 13.61 15.63 13.89 16.57 15.39 17.2 15.17 14.38 13.89 17.43 15.29 14.93 16.02 15.35 15.52 14.26 12 13.59 16.28 14.81 15.79 15.75 16.4 16.01 13.93 14.96 17.64 16.04 15.19 16.49 16.25 15.01 14.22 13 28.13 33.16 38.84 31.06 31.03 37.64 38.2 22.62 27.26 28.38 33.11 21.08 21.67 20.34 22.45 22.84 15 15.63 18.37 16.07 17.76 17.32 20.82 16.79 15.63 16.52 19.11 15.44 16.36 17.37 16.23 19.52 16.95 16 17.46 18.16 19.61 17.66 17.14 18.25 17.91 13.61 15.04 18.48 17.77 15.53 19.27 17.62 16.31 15.37 41 13.51 16.47 14.3 14.63 15.24 17.41 15.13 13.32 15.98 16.41 14.32 15.03 16.26 14.45 14.85 13.85 55 17.11 19.37 15.93 18.98 20.11 19.89 17.67 17.84 18.08 19.86 18.04 18.2 20.06 16.67 18.67 16.72 56 16.39 19.17 15.57 18.77 18.11 20.12 17.31 17.05 17.84 19.71 17.11 17.26 19.12 17.63 17.63 16.69 57 15.88 18.51 16.29 19.19 17.96 19.09 16.03 15.8 16.18 17.44 16.69 15.85 17.8 16.64 15.56 16.69 58 16.29 18.97 16.22 17.45 17.4 18.65 16.39 15.88 16.75 18.94 17.39 (3) 18.17 17.66 18.08 15.88 59 14.65 17.56 16.14 16.54 17.45 18.31 17.12 16.11 16.88 18.79 17.23 15.51 19.0 20.07 18.18 17.08 73 22.97 25.29 22.41 22.71 22.94 23.48 24.9 21.47 22.1 23.91 22.53 22.47 23.02 22.02 23.64 20.67 108

TABLE J-2 REMP TLDs WITHIN THE EAB REMP 2005 2006 2007 2008 TLD rd rd Number 3 3 3rd 2nd 3rd 1st Qtr 2nd Qtr 4th Qtr 1st Qtr 2nd Qtr 4th Qtr 1st Qtr 2nd Qtr 4th Qtr 1st Qtr 4th Qtr Location Qtr Qtr Qtr Qtr Qtr 11 15.96 15.49 16.04 14.38 15.44 16.62 15.06 17.08 16.07 14.14 17.28 14.29 15.68 14.68 15.61 15.66 12 17.79 16.14 16.59 14.81 14.87 18.82 13.82 17.3 17.12 14.21 17.7 14.75 15.76 16.28 17.14 16.66 13 24.28 29.32 25.68 17.95 23.52 31.94 34.84 28.16 32.85 24.77 27.52 30.7 28.29 28.45 24.57 28.26 15 20.94 19.06 19.29 17.7 18.84 20.97 18.69 20.14 21.28 18.98 21.51 18.99 20.06 20.67 19.78 21.31 16 22.12 18.18 17.2 16.16 15.78 20.39 19.88 20.84 22.69 18.43 19.25 17.58 18.36 17.3 17.2 18.92 41 16.66 17.04 15.45 14.47 14.76 17.71 14.95 15.84 16.12 14.82 17.12 14.98 14.32 15.14 16.62 15.46 55 21.64 21.73 19.07 20.51 20.95 21.69 18.44 16.78 19.99 16.64 20.34 15.34 18.53 19.4 18.38 18.89 56 20.66 21.39 19.59 18.75 20.7 22.99 18.84 17.76 19.5 16.73 19.76 15.79 16.78 19.01 17.75 18.63 57 21.4 21.79 19.86 19.1 18.73 21.63 17.7 18.41 20.02 16.89 21.00 16.84 18.71 19.37 18.22 18.69 58 20.19 20.15 19.93 18.2 17.71 20.78 16.78 18.16 19.53 16.32 21.4 17.44 18.03 18.06 19.64 19.33 59 21.18 22.58 21.52 20.35 20.07 22.08 17.89 19.74 19.94 17.93 20.53 16.59 18.04 17.67 18.96 20.03 73 26.83 24.81 23.35 22.34 21.12 23.52 24.27 25.2 26.60 22.96 24.05 20.37 24.05 22.59 21.95 22.48 109

TABLE J-2 REMP TLDs WITHIN THE EAB REMP 2009 2009 2009 2009 TLD Number 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Location 11 16.92 15.29 17.99 15.7 12 16.6 15.02 17.78 15.05 13 24.39 18.67 22.93 20.76 15 21.62 19.66 21.95 19.94 16 19.67 15.63 19.95 16.78 41 17.04 14.55 17.44 15.49 55 18.41 16.78 21.17 18.81 56 19.87 17.01 20.15 18.44 57 19.14 17.83 21.53 19.09 58 19.84 18.39 22.21 18.6 59 19.88 19.06 21.66 19.3 73 24.34 23.3 24.94 20.15 77 18.56 18.46 23.54 19.63 110

BE A UB CL CH TLD 63  !

P Air Sampler 12 & TLD 67  !

P Air Sampler 10 & TLD 10  !

P P

TLD 11 EAB (10 CFR 50 Exclusion Area Boundary)

SAN ONOFRE STATE BEACH and CAB (10 CFR 72 Controlled Area Boundary)

G G G G G G GG G GG G P

TLD 59 GG G G G G G

G G G G GG G G G TLD 55  !

P G TLD 41  !

P Figure 6-1  !

P UNIT 2 TLD 56 ISFSI TLDs and REMP TLDs UNIT 3 P TLD 12

! EL C AM IN O

RE AL within the EAB  !

P TLD 57 F

G ISFSI TLDs P

0 c REMP TLDs TLD 58 P TLD 15 TLD 73 EAB (10 CFR 50 Exclusion Area Boundary)  !

P and CAB (10 CFR 72 Controlled Area Boundary)  !

P TLD 16 Seawall/Fenceline Railroad Major Road Local Street P TLD 13

µ P

Air Sampler 9 &

TLD 66 500 0 500 Feet SAN ONOFRE STATE BEACH File Name: 2009AREOR_Figure6-1_11x8.mxd Path: \SONGS\AREOR\MXD\AREOR2009 Date: 03/19/2010 Reproduced with permission granted by THOMAS BROS MAPS

© Thomas Bros. Maps. All rights reserved.

PACIFIC OCEAN Features depicted herein are planning level accuracy, and intended for informational purposes only. Distances and locations may be distorted at this scale. Always consult with the proper legal 111 documents or agencies regarding such features. © Corporate Real Estate Department, REO -- Survey and Mapping Section.

G 321 OL D

HW Y1 G 316 G 320 01 Unit 1 G 319 Reactor Vessel G 308 G 317 G 307 G 318 G 306 REMP G 301G 304 G 309 TLD 59 G 326 0

c G 303 G 310 G 325 336 #

G 302 G 311 337 #

G 324 G 312 TLD Elevation Relative to ISFSI Pad 318 87 338 #

• G 322 319 86 321 83 Figure 6-2 G 323 320 84 ISFSI Foundation ISFSI TLDs and 316 37 G 314 selected REMP TLDs REMP 317 42 TLD 55 304 33 near the ISFSI foundation G ISFSI TLDs 0

c G 315 303 33 302 32

• Removed TLDs 307 7 0

c REMP TLDs 306 4 Seawall/Fenceline 308 9 Major Road 301 78 Local Street 324 4

µ 323 4 325 4 REMP 326 3 100 0 100 TLD 56 315 4 Feet 0 c 314 4 File Name: 2009AREOR_Figure6-2_11x8_surveyv3.mxd Path: \SONGS\AREOR\MXD\AREOR2009 309 3 Date: 01/20/2010 Reproduced with permission granted by THOMAS BROS MAPS 322 3

© Thomas Bros. Maps. All rights reserved.

Features depicted herein are planning level accuracy, and intended for 312 4 informational purposes only. Distances and locations may be distorted at this scale. Always consult with the proper legal documents or agencies Pacific Ocean 311 3 112 310 3 regarding such features. © Corporate Real Estate Department, REO --

Survey and Mapping Section.

Direct Radiation Monitoring ISFSI & Selected REMP TLDs - Quarterly Gamma Exposure (mR/ std quarter) 25 Unit 1 Large Component Removal 20 15 Start Spent Fuel Storage 10 5

0 TLD 31 - 18.6 miles NNW TLD 56 ISFSI 318 TLD 59 TLD 55 ISFSI 321 Figure 6A 113

Appendix K Local Drinking Water Wells 114

Local Drinking Water Well Data No drinking water pathway exists at SONGS. Refer to Figures 7-1 and 7.2 for a general indication of groundwater flow in the vicinity of SONGS.

In accordance with the GPI (Groundwater Protection Initiative) samples were collected the SONGS GPI monitoring wells (see figure 7-2). The analysis results for PA-1, PA-2, PA-3, PA-4, OCA-1, OCA-2, and OCA-3 were less than the a posteriori MDC (Minimum Detectable Concentration) and the for all plant related radionuclides during 2009.

The analysis results for wells NIA-1 and NIA-2 were all less that the a priori (LLD) for all plant related radionuclides. Tritium was detected in wells NIA-1 and NIA-2 at a level below a priori (LLD) , but above the lower, analysis specific a posteriori MDC (Minimum Detectable Concentration). We conclude that the operation of SONGS had no affect on drinking water wells in the vicinity of SONGS.

115

O PIC D

AV N

EL CAM INO Sector A REA L Sector R N

NNW Sector B NNE Orang e Cou RD nty OS San D IAN N iego C SA S

IT A

Sector Q Sector C oun ty RE M ATEO IST NW CAMINO CR NE EL RD Well PACIFIC

• 1. 6 #

L OCEAN

• 61521

§

¨ 5

• 61511 Sector P RD 5-mile WNW NE radius LO S SI BA Figure 7-1 52028 ##

• • 52023 Drinking Water Wells 2-mile radius Units 2/3 Midpoint 1-mile

• Drinking Water Wells radius Groundwater Flow Direction Sector N W

SONGS Facilities County Boundary Freeway Major Road Local Street SAN ONOFRE STATE BEACH Railroad O LD

µ H

WY 10 Sector M 1 WSW Se 0.5 0 0.5 Miles File Name: 2009AREOR_Figure7-1_11x8.mxd Path: \SONGS\AREOR\MXD\AREOR2009 Date: 01/20/2010 Reproduced with permission granted by THOMAS BROS MAPS

© Thomas Bros. Maps. All rights reserved.

Features depicted herein are planning level accuracy, and intended for informational purposes only. Distances and locations may be distorted at this scale. Always consult with the proper legal documents or agencies regarding such features. © Corporate Real Estate Department, REO --

Survey and Mapping Section.

Sector L 116 S G

GW-OCA-1 GW-NIA-2 !

Figure 7-2 Protected Area Wells GW-NIA-1 !

GW-OCA-2 !

GW-PA-1 ! OL D

HW Groundwater Flow Direction Y GW-PA-2 ! 10 1

Units 2/3 Midpoint

! Groundwater Monitoring Wells Power Block GW-PA-3 !

SONGS Facilities GW-PA-4 !

County Boundary Freeway Major Road Local Street Railroad GW-OCA-3 !

0.1

µ 0 0.1 Miles File Name: 2009AREOR_Figure7-2PAW_11x8.mxd Path: \SONGS\AREOR\MXD\AREOR2009 Date: 03/22/2010 Reproduced with permission granted by THOMAS BROS MAPS

© Thomas Bros. Maps. All rights reserved.

Features depicted herein are planning level accuracy, and intended for informational purposes only. Distances and locations may be distorted at this scale. Always consult with the proper legal documents or agencies regarding such features. © Corporate Real Estate Department, REO --

Survey and Mapping Section. 117