ML23206A244

Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054

ML23206A244
Person / Time
Site:	Columbia
Issue date:	07/25/2023
From:	Leidich A, Lepre M, Walsh T Energy Northwest, Pillsbury, Winthrop, Shaw, Pittman, LLP
To:	Office of Nuclear Reactor Regulation, NRC Region 4, Document Control Desk
Shared Package
ML23206A243	List: ML23206A244
References
EA-23-054, IR 2023092
Download: ML23206A244 (1)

Text

Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW l Washington, DC 20036 l tel 202.663.8000 l fax 202.663.8007 Michael G. Lepre tel: +1.202.663.8193 michael.lepre@pillsburylaw.com July 25, 2023 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Energy Northwest Columbia Generating Station Docket Number 50-397 Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 On behalf of Energy Northwest, I am submitting the enclosed Response to the Apparent Violation in NRC Inspection Report 05000397/2023092 (EA-23-054) dated June 1, 2023 (Inspection Report). The NRC previously agreed to extend the due date for this response to July 25.

The Inspection Report alleges that Energy Northwest violated NRC regulations (specifically 10 CFR § 20.1204(a)) and Energy Northwests internal procedures when it evaluated the radiation dose received by two pipefitters during an event at Energy Northwests Columbia Generating Station on May 28, 2021. Specifically, the Inspection Report alleges one apparent violation with a preliminary white finding:

Energy Northwests failure to take suitable and timely combination of measurements, including radioactive material in air in work areas, and urine and fecal samples to properly evaluate alpha emitters [specifically Pu-239/240] in the body contributing to the accrued internal dose, resulting in an inability of the licensee to properly assess the dose accrued by the pipefitters following the reactor water cleanup (RWCU) contamination event on May 28, 2021.

As this Response explains in detail, Energy Northwest has investigated the NRCs allegations and determined that, consistent with 10 CFR § 20.1204(a), NRC guidance, industry standards, and Energy Northwests own procedures, Energy Northwest did indeed take suitable and timely measurements of a combination of (1) radioactive material in air in work areas (through air samples); (2) quantities of radionuclides in the body (through whole body counts); and (3) quantities of radionuclides excreted from the body (through 24-hour urinalysis).

As also explained below, contrary to the Inspection Reports allegations, the data and evidence did not at the time of the event, nor in subsequent analyses, indicate the www.pillsburylaw.com 4866-7463-6146.v1

July 25, 2023 Page 2 presence of Pu-239/240 in any of the samples. And, based on that data, Energy Northwest did not violate its procedures or NRC regulations.

Energy Northwest requests that Exhibits A and C be withheld from public disclosure because they contain personal privacy information regarding individual dose assessments.

If you have any questions or require additional information, please contact Mike Lepre at 202-663-8193.

Sincerely,

-h > 2 {/ (U Michael G. Lepre Timothy J.V. Walsh Anne Leidich Counsel for Energy Northwest

Enclosure:

Attachment I - Response to Apparent Violation (EA-23-054) cc: Director, Division of Radiological Safety and Security, U.S. NRC, Region IV 1600 East Lamar Blvd.,

Arlington, Texas 76011-4511 Resident Inspector Columbia Generating Station www.pillsburylaw.com 4866-7463-6146.v1

Attachment I Response to Notice of Apparent Violation (EA-23-054) www.pillsburylaw.com 4866-7463-6146.v1

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I I. The White Finding NRC Inspection Report 05000397/2023092 dated June 1, 2023 (the Inspection Report),

identified a preliminary white finding associated with Energy Northwests alleged failure to adequately determine the initial radiation dose two pipefitters received during an event that took place on May 28, 2021, at Energy Northwests Columbia Generating Station.

According to the NRC, Energy Northwest violated 10 CFR § 20.1204(a) because it allegedly failed to take suitable and timely measurements of concentrations of: (1) radioactive material in air in work areas; (2) quantities of radionuclides in the body; (3) quantities of radionuclides excreted from the body; or (4) combinations of these measurements, and therefore failed to properly assess the internal dose of two pipefitters. 1 The Inspection Report adds:

[T]he licensee failed to use a combination of measurements, based on steps noted in their dose assessment procedures, PPM 11.2.4.5, PPM 11.2.4.6, and HPI-5.9 to adequately assess the internal dose. The licensee only took one 24-hour urine sample from each pipefitter, day 2 post the uptake event, and did not continue these in vitro assessments to establish elimination rates, nor did they take radioactive material in air in work area, evaluate the [whole-body count (WBC)] and survey assessments to determine that fecal sampling was needed to appropriately measure hard-to-detect radionuclides, including alpha emitters. 2 The Inspection Report also states that at least one alpha emitter of [Plutonium-239/240 (Pu-239/240)], was not properly addressed or evaluated by the licensee. 3 As support for this claim, the Inspection Report points to internal dose assessment data for the workers that allegedly show[s] the presence of an alpha emitter based on the following: the RWCU pipe smear had positive alpha counts for Pu-239/240, the air sampler within the RWCU heat exchanger room had indications of Pu-239/240 (no air sampling was completed in the breathing zone of the workers), and one of the pipefitters had a positive count for Pu-239/240 within their urine sample. 4 Based on this, the Inspection Report claims that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters. 5 1

Inspection Report at 6, 7.

2 Inspection Report at 6.

3 Inspection Report at 5.

4 Inspection Report at 5.

5 Inspection Report at 6. The Inspection Report further states, Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters. In support of this conclusion, the internal dose assessment performed by the licensees vendor stated, Additional 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion because the initial intake data performed by the vendor was not matching the licensees WBC data, as provided.

Paragraphs 16 and 17 of the attached Affidavit of Mr. Eric Darois (the Darois Affidavit), Executive Director of www.pillsburylaw.com 1 4866-7463-6146.v1

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I II. Energy Northwests Response A. Factual Background As the Inspection Report explains, on May 28, 2021, while performing weld preparations on the RWCU heat exchanger system piping at Columbia Generating Station, an airborne radioactivity event occurred that caused 22 positive intakes of radioactive materials, including significant uptakes of radioactive material by two pipefitters. After this event, Energy Northwest followed its applicable procedures and conservatively assessed dose to the two pipefitters following an evaluation of numerous whole body counts (WBCs), job coverage contamination surveys, smear samples from the RWCU pipe, a sample from the filter of the air sampler in use during the event, and a 24-hour urinalysis from each of these two pipefitters, in compliance with the requirements of 10 CFR § 20.1204.

Specifically, Energy Northwest first used a whole-body count to assess the initial scope of the anticipated dose. Shortly after the event, Radiation Support then ordered a 24-hour urinalysis for the two pipefitters to identify hard-to-detect isotopes and sent out work area samples for analysis.

As described in more detail below, existing test data and activity ratios in the work area indicated minimal alpha activity. As a result, Radiation Support was primarily concerned with identifying hard-to-detect beta-gamma emitters through urinalysis. Energy Northwest continued WBCs for the two pipefitters to determine elimination rates. In fact, one pipefitter underwent 16 total WBCs from May 28 (shortly before midnight) to June 7, 2021, while the other pipefitter underwent 25 total WBCs from May 29 (shortly after midnight) to June 9, 2021. 6 After the whole-body counting was complete and a few weeks had passed, Energy Northwest received additional work area activity data, including an analysis of an area air sample and a RWCU pipe smear. This information was utilized by a third-party contractor to determine dose for the two pipefitters. 7 Energy Northwest then used a separate third-party contractor to check and confirm the first contractors dose analysis. 8 B. Discussion

1. Energy Northwest complied with applicable NRC regulations.

10 CFR §§ 20.1502 and 20.1204 contain the NRCs sole formal regulatory requirements related to the collection of measurements to determine internal radiation exposure. 10 CFR § 20.1502 states in relevant part that [e]ach licensee shall monitor (see § 20.1204) the occupational intake of radioactive material by and assess the committed effective dose equivalent to[a]dults likely Radiation Safety and Control Services (RSCS) (the vendor referenced in this quotation), describes how the Inspection Report has misinterpreted and taken this quotation out of context.

6 Exhibit A [Whole-body count datasheets].

7 Exhibit C [Compendium Laboratories Report] at PDF p. 195, 251.

8 Darois Affidavit at ¶ 9. RSCS also independently evaluated dose for these intakes. See Exhibit C [Compendium Laboratories Report] at PDF p. 75.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I to receive, in 1 year, an intake in excess of 10 percent of the applicable annual limit on intakes (ALI(s)), or 500 mrem committed effective dose equivalent.

Under 10 CFR § 20.1204(a), the licensee is required to take suitable and timely measurements of (1) Concentrations of radioactive materials in air in work areas; or (2) Quantities of radionuclides in the body; or (3) Quantities of radionuclides excreted from the body; or (4)

Combinations of these measurements. The Inspection Report claims that Energy Northwest violated 10 CFR § 20.1204(a) (and therefore 10 CFR § 20.1502), because it did not take [a]

suitable and timely combination of measurements. 9 That claim is incorrect.

As an initial matter, 10 CFR § 20.1204(a) does not require licensees to take a suitable and timely combination of measurements. The four subsections of the regulation are connected by the word or (not and), meaning that performing any one of the measurements listed in

§ 20.1204(a)(1)-(4) in a suitable and timely manner satisfies the regulations plain language. A reading of § 20.1204(a) that give[s] effect, if possible, to every clause and word as required by U.S. Supreme Court precedent would clearly and unambiguously indicate that only one of the measurements in § 20.1204(a) must be performed. 10 Energy Northwest cannot be found to have violated that regulation by failing to take a combination of measurements because under the regulations plain language doing so was one of four options and not explicitly required.

Moreover, the Inspection Reports broad claims that the licensee failed to take suitable and timely measurements of concentrations of radioactive materials in air in work areas, urine and fecal samples, as well as properly evaluate alpha emitters in the body contributing to the accrued internal dose 11 are factually misleading. While it was not obligated to do so under 10 CFR

§ 20.1204(a), Energy Northwest actually took a combination of all these measurements, doing more than what the regulation required, by taking (1) work area air samples 12 (in addition to pipe smears); 13 (2) numerous whole-body counts; 14 and (3) 24-hour urine samples from each pipefitter (note that 10 CFR § 20.1204(a)(3) does not specify whether excretions must be urine or fecal samples).

Accordingly, Energy Northwest clearly complied with 10 CFR § 20.1204(a). On that basis alone the NRC should withdraw the Apparent Violation as a matter of law.

9 Inspection Report at 7.

10 Duncan v. Walker, 533 U.S. 167, 174 (2001). See also Kisor v. Wilkie, 139 S. Ct. 2400, 2409 (2019) (explaining that courts are to interpret regulations using the traditional rules of construction).

11 Inspection Report at 11.

12 See, e.g., Exhibit B [Air Sample 1097086 Spreadsheet]; Exhibit C [Compendium Laboratories Report] at PDF p.

323.

13 See, e.g., Exhibit D [Survey VSDS_Prod-M-20210529-13]; Exhibit E [Survey VSDS_Prod-M-20210513-33];

Exhibit C [Compendium Laboratories Report] at PDF p. 326.

14 Exhibit A [Whole-body count datasheets]. In total, one pipefitter underwent 16 total WBCs from May 28 (shortly before midnight) to June 7, 2021, while the other pipefitter underwent 25 total WBCs from May 29 (shortly after midnight) to June 9, 2021.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I

2. Energy Northwests actions were suitable and timely, consistent with NRC guidance and industry practice.

It is also clear that all of Energy Northwests measurements were suitable and timely because they were consistent with (1) Regulatory Guide 8.9, which the NRC staff published as non-mandatory general guidance for meeting the requirements set forth in 10 CFR §§ 20.1502 and 20.1204; and (2) industry practice.

For a radiation intake like this onegreater than 10% of ALI (annual limit on intake)Reg.

Guide 8.9 recommends multiple bioassay measurements and an evaluation of available workplace monitoring data. 15 However, it does not mandate a particular type of bioassay measurement (in vivo or in vitro). Rather, Reg. Guide 8.9 says measurement types should be selected based on the physical and biological characteristics of the radioactive material. 16 And that is precisely what Energy Northwest did.

For example, under Reg. Guide 8.9, in vivo lung or total body measurements shortly following exposure generally provide reliable estimates of intakes for most gamma emitting radionuclides, (like Co-60 and Co-58) while in vitro measurements should be used for radionuclides that emit little or no gamma radiation. 17 To the extent that in vitro measurements are selected, Reg. Guide 8.9 does not state a preference for feces sample collection over urine samples or otherwise require a specific duration of sampling. 18 Here, Energy Northwest used numerous whole-body counts (an in vivo measurement) along with a 24-hour urine sample (an in vitro measurement) of each pipefitter as its multiple bioassay measurements. With initial workplace monitoring data indicating a statistically insignificant quantity of alpha emitters, 19 and subsequent workplace monitoring indicating a significant presence of Co-60 and Co-58 (both gamma emitters), 20 the analysis appropriately focused on whole body counts (in vivo measurements) with a confirmatory 24-hour urinalysis (in vitro measurements) to identify hard-to-detect isotopes, including hard-to-detect beta/gamma emitters.

Having performed this analysis and identified the isotopes in the intake, Energy Northwests outside consultants at Hanford Mission Integration Solutions (HMIS) were then able to determine an appropriate retention and excretion curve in accordance with Reg. Guide 8.9, leading to a dose assessment. 21 This dose assessment was later independently reviewed and 15 Reg. Guide 8.9 at 8.9-4.

16 Id.

17 Id.

18 See generally id.

19 See infra at Section B.3.a.

20 See, e.g., infra at Section B.3.b; Exhibit C [Compendium Laboratories Report] at PDF p. 256.

21 See Exhibit C [Compendium Laboratories Report] at PDF pp. 256-257. While the initial data was not a good fit for historical retention and excretion curves, a subsequent review of the published literature found a similar fit in a publication from 2007. Id. at 257.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I confirmed by RSCS. 22 Thus, Energy Northwests analysis was performed in compliance with published NRC guidance.

Beyond Reg. Guide 8.9, the NRC has otherwise declined to define suitable and timely measurements under 10 CFR § 20.1204. Rather, according to the NRC, whether measurements are suitable and timely is a matter of professional judgement in a good radiation protection program. 23 Energy Northwest exercised sound professional judgment consistent with industry standards. In the absence of more specific regulatory requirements, the Electric Power Research Institute (EPRI) has developed a voluntary set of Alpha Monitoring and Control Guidelines for Operating Nuclear Power Stations (the Guidelines) with more detail on how to comply with US regulations. 24 These Guidelines were developed, by consensus, by a group of radiation safety professionals representing twenty six US and six international nuclear companies shar[ing] their collective experiences and expertise. 25 The Guidelines establish the use of activity ratios and provide further detail on the need for monitoring to indicate the potential presence of alpha emitter exposure in individuals. 26 These Guidelines are consistent with the requirements of Reg. Guide 8.9, although they provide more detailed guidance. Specifically, the Guidelines provide that whole-body counting (as noted previously, both pipefitters underwent numerous whole-body counts) may be used to investigate a low level intake from alpha emitting nuclides (for example, above the screening level of 10 mrem committed effective dose), using scaling factors determined from representative characterization samples from the work area at times soon after exposure, such as [a]ir samples or smears from the work area. 27 That is, if the activity ratio is Level I, as it was here, 28 the alpha dose can be inferred from the gamma dose using a scaling factor from air samples and smears from the work area. Under the 22 Darois Affidavit at ¶ 9.

23 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html.

24 EPRI Alpha Monitoring and Control Guidelines for Operating Nuclear Power Stations, Revision 2 (2013)

(ADAMS Accession No. ML14083A589) [hereinafter EPRI Alpha Monitoring Report]. EPRI is the Electric Power Research Institute, an independent non-profit energy research, development, and deployment organization, with three specialized labs.

25 Id. at v.

26 See generally id.

27 Id. at 5-2 to 5-3.

28 Energy Northwests job coverage contamination surveys that existed at the time of the event generally indicated that the activity ratio of the area was consistent with a Level I Area, i.e., an area with a derived air concentration (DAC) fraction ratio (or ratio of alpha to beta-gamma activity) below 0.1. EPRI Alpha Monitoring Report, at 2-3, 2-6. More specifically, air samples taken on May 28 from 9:20 pm until 11:05 pm and analyzed a few hours later indicated a DAC fraction ratio of only 0.01. See Exhibit B [Air Sample 1097086 Spreadsheet]. According to industry standards, [i]n Level I Areas, the relative abundance of loose alpha contamination compared with www.pillsburylaw.com 5 4866-7463-6146.v1

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I Guidelines, whole-body counting can be used until alpha doses reach 100 mrem or the activity ratio is greater than Level I. 29 If alpha exposures are expected to exceed 100 mrem then 24-hour sampling is required, and if alpha exposures are expected to exceed 500 mrem, then excreta sampling is required for five days. 30 Energy Northwest followed these industry Guidelines. In (1) a Level I area, with (2) evidence of minimal alpha activity (see Section B.3.a below), and (3) anticipated alpha exposures expected to be below 100 mrem based on activity ratios, whole-body counting was sufficient to establish dose. Yet, Energy Northwest also performed 24-hour urinalyses on both pipefitters and confirmed (as also described in Section B.3.b below) that there was no statistically significant, conclusive indication of any alpha emitters in the urine. 31 More significant samples were not recommended under the Guidelines unless alpha exposure was expected to reach 500 mrem, 32 a level beyond even the approximately 100 mrem alleged (improperly as described in paragraph 17 of the Darois Affidavit) in the NRC Inspection Report. 33 For these reasons, Energy Northwest complied with consensus industry standards and no additional sampling was necessary. 34 Mr. Darois agrees, stating in paragraph 12 of his Affidavit: Based on my review of these measurements results, and my 46 years of experience in this industry, my professional opinion is that Energy Northwests measurements were suitable and timely measurements such that under standard industry practice, either at the time of the incident or at any point thereafter, Energy Northwest did not need to take additional in vitro measurements to determine internal exposure . . ..

The NRC cannot credibly conclude that Energy Northwest failed to exercise professional judgment when it followed well established industry practice, NRC regulatory guidance, and the applicable regulations. Nor can the NRC use enforcement actions to impose new requirements on its licensees without adequate prior notice. As the Supreme Court has explained, regulated parties should know what is required of them so they may act accordingly precision and guidance are necessary so that those enforcing the law do not act in an arbitrary or discriminatory way. Federal Communications Commission v. Fox Television Stations, Inc.,

567 U.S. 239, 253 (2012).

beta-gamma contamination is minimal, and [i]nternal exposure from loose alpha emitters is not likely to exceed 10% of the total internal dose. Id. at 1-2.

29 Id. at 5-3.

30 Id. at 5-4.

31 Infra at B.3.b.

32 EPRI Alpha Monitoring Report at 5-4.

33 Inspection Report at 6. (Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters.)

34 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I

3. The Inspection Report incorrectly asserts that Pu-239/240 is a significant contributor to dose.

While Energy Northwest complied with regulatory requirements, guidance, and industry standards, the Inspection Report nevertheless alleges that Energy Northwest should have taken additional excrement samples due to data for the workers show[ing] the presence of Pu-239/240. 35 The Inspection Report misreads the relevant data. Energy Northwest did not need to take additional internal dose measurements because: (1) at the time of the event, when Radiation Support decided on the tests to measure internal dose, available data did not show the presence of Pu-239/240; and (2) even now, there is still no data showing that Pu-239/240 was detectable or present.

a. Contrary to the Inspection Report, at the time of the event (when Radiation Support decided on the tests to measure internal dose), available data did not show the presence of Pu-239/240.

Energy Northwest reviewed numerous tests indicating that the RWCU system (on which the pipefitters were working), and the work area itself contained minimal (if any) alpha emitters. As such, Energy Northwest in its professional judgement had no reason to believe that Pu-239/240, or any other alpha emitter, would be a significant contributor to the pipefitters dose.

As an initial matter, Energy Northwest had an independent laboratory report from December 2020 showing that water in the RWCU system at issue here contained no alpha emitters. 36 That report states that all analyzed alpha emitters, including Pu-239/240, were not detected above the

[Minimum Detection Limit (MDL)], [Minimum Detectable Activity (MDA)], 37 [Minimum Detectable Concentration (MDC)] or [Limit of Detection (LOD)]. 38 Pu-239/240 specifically was noted in the RWCU system at 2.01E-5 uCi/g, below the Minimum Detection Amount for Pu-239/240 of 6.23E-5 uCi/g. 39 In addition, Energy Northwests job coverage contamination surveys from the time of the event indicated that the activity ratio of the area was consistent with a Level I Area under the EPRI 35 Inspection Report at 5.

36 See Exhibit F [2020 RWCU Sample Results] at PDF p. 26.

37 A minimum detectable activity is used to determine the capabilities of the counting system used and to ensure that the action levels appropriate for the analysis are statistically distinguishable from background, typically at a 95% confidence level. EPRI Alpha Monitoring Report at D-7. This is related to the lower limit of detection which is generally the point at which a radioactive material will be detected with at least 95% probability and with no greater than a 5% probability of falsely concluding that a blank observation represents a real signal.

NUREG/CR-4007, Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements at 67 (1984) (ADAMS Accession No. ML16152A647).

38 Exhibit F [2020 RWCU Sample Results] at PDF p. 26.

39 Id.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I Alpha Monitoring Guidelines described previously. 40 According to EPRI, [i]n Level I Areas, the relative abundance of loose alpha contamination compared with beta-gamma contamination is minimal, and [i]nternal exposure from loose alpha emitters is not likely to exceed 10% of the total internal dose. 41 Air samples taken on May 28 contemporaneous with the event (from 9:20 pm until 11:05 pm) and analyzed a few hours later indicated a ratio of alpha to beta-gamma activity (DAC fraction ratio) of only 0.01, within the bounds of a Level 1 area. 42 The minimal (if any) presence of alpha emitters demonstrated by the DAC ratio was further confirmed by smear data taken from the RWCU heat exchanger room and analyzed on the morning of May 29. That data indicated alpha activity from the smear below the decision level 43 of the measurement device, 44 consistent with prior smear data taken from RWCU piping on May 13 that also indicated alpha activity below the decision level of the measurement device. 45 In short, available data at the time showed minimal alpha activity in the area, and there was no indication of any specific alpha emitters of concern, including Pu-239/240. As a result, at the time of the event there was no indication that either pipefitter had an intake of hard-to-detect radionuclides or specific alpha emitters sufficient to require in vitro bioassay sampling in addition to the 24-hour urinalyses that Energy Northwest conducted. As paragraph 17 of the Darois Affidavit states, there is no evidence that alpha emitters were present for the subject intake and this data represents a beta to alpha ratio of greater than 200,000:1. From this, it is apparent that fecal sampling and analysis would not have been needed to assess the dose.

b. Contrary to the Inspection Report, there is still no reason to believe that Pu-239/240 was detectable or present.

Even without any indication of significant alpha activity, Energy Northwest continued to evaluate the event and obtained additional data including 24-hour urine samples from the pipefitters (requested by Radiation Support), along with smear samples and the filter from the air sampler in use during the event. Based on the Inspection Report, we have inferred that the NRC may be relying on some of this data to claim that Pu-239/240 was present and to also claim that further tests should have been conducted. But the NRC has misinterpreted the data, which actually shows that there is no reason to believe Pu-239/240 was present during the event.

Shortly after the event, Energy Northwest obtained 24-hour urine samples that were evaluated by HMIS labs and GEL Laboratories, LLC (GEL Labs). 46 One pipefitters (Person 1) 24-hour 40 See supra, note 27.

41 EPRI Alpha Monitoring Report at 1-2.

42 See Exhibit B [Air Sample 1097086 Spreadsheet].

43 A decision level is generally the amount of a count as final instrument measurement of a quantity of analyte at or above which a decision is made that the analyte is definitely present. See DOE, Decision Level (Lc), available at https://www.directives.doe.gov/terms_definitions/decision-level-lc 44 See Exhibit D [Survey VSDS_Prod-M-20210529-13.]

45 See Exhibit E [Survey VSDS_Prod-M-20210513-33.]

46 As noted previously, HMIS also performed dose assessment, which was independently reviewed by RSCS.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I urine sample indicated the presence of only Co-60 and Co-58. No other isotopes were detected at levels above the decision level, including all alpha emitters and Plutonium isotopes. 47 Specifically, as set forth on page 263 of Exhibit C (upon which we believe the Inspection Reports conclusions may rely, in part), Pu-239/240 was noted in the urine sample at 3.96E-3 pCi/s. But this value was below the Decision Level for Pu-239/240 of 4.61E-3 pCi/s. The lab decision level was set at twice the total propagated uncertainty 48 (2-sigma), which is a statistical determination of detection with a 95% confidence interval. 49 This data can only be read as showing, contrary to the Inspection Reports claim, that Pu-239/240 was not validly detected with statistical confidence in the pipefitters (Person 1) 24-hour urine sample. The Darois Affidavit at paragraph 13 agrees that the only reasonable way to interpret that data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

The other pipefitters (Person 2) 24-hour urine sample also indicated the presence of Co-60 and Co-58, in addition to Tc-99. No other isotopes were detected at levels above the Decision Level, including all alpha emitters and Plutonium isotopes. 50 In fact, Pu-239/240 was noted in this pipefitters urine sample at negative 3.55E-4 pCi/s. This absence of any validly detectable alpha emitters in the urine samples only further demonstrates the absence of any significant alpha intake, and that Energy Northwests dose assessment met NRC regulations, NRC guidance, and industry standards as explained above in Section II.B.1-2.

Additional data obtained weeks after the event further confirmed the lack of any alpha emitters.

Energy Northwest obtained additional information from both an air sample of the room and an additional pipe smear taken at the time of the incident.

Regarding the air sample, PDF page 323 of Exhibit C (upon which we believe the Inspection Reports conclusions may rely, in part) indicates the presence of various isotopes including gamma emitters Co-60 and Co-58. But no alpha emitters were detected at levels above the Minimum Detectable Activity, including Plutonium isotopes. 51 In fact, Pu-239/240 was noted at negative 1.27E-6 uCi/filter in the air sample, and the U in the Qualifier column (as defined in the footnotes) means that Pu239/240 was not detected above the MDL, MDA, MDC or LOD. 52 Accordingly, this data also can only be read as showing that Pu-239/240 was not validly detected with statistical confidence in the air sample taken at the time of the incident. As the Darois Affidavit at paragraph 13 again confirms, the only reasonable way to interpret that 47 Exhibit C [Compendium Laboratories Report] at PDF page 263.

48 Total Propagated Uncertainty (or TPU) includes uncertainties not only in sample peak determination but also uncertainties in the isotopic abundance, relative absorption factor (where appropriate), decay factor, aliquoting, weighing, blank correction, peak overlap (where appropriate), impurities etc. Exhibit C [Compendium Laboratories Report] at PDF page 255.

49 Id. at PDF p. 255.

50 See id. at PDF p. 207.

51 See id. at PDF p. 323.

52 Id.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

The Inspection Report also appears to allege that Pu-239/240 was identified on the May 17 pipe smear. 53 That is also incorrect. Pu-239/240 was not identified in this smear sample. In fact, Pu-239/240 was again noted at negative 7.23E-07 uCi/filter in the smear, and the U in the Qualifier column (as defined in the footnotes) means that Pu239/240 was not detected above the MDL, MDA, MDC or LOD. 54 In short, contrary to the Inspection Reports claim, there is no statistically significant indication of the presence of Plutonium-239/240 in any of the measurements from the event, including the pipe smear, the air sample from the room, and the urinalysis data, nor is Energy Northwest aware of any available measured data associated with the event suggesting that alpha activity was a significant contributor to the dose (unless the NRC has additional information on which it is relying but has not specifically cited in the Inspection Report, to which Energy Northwest would be pleased to respond).

Accordingly, the Inspection Reports central claim that more testing was necessary because data showed the presence of alpha emitters is based on a misreading or misinterpretation of the relevant data.

4. Energy Northwest complied with its own procedures.

The Inspection Report also claims that, due to the alleged presence of alpha emitters, Energy Northwest failed to comply with its own dose assessment procedures. For many of the reasons set forth above, this claim is incorrect.

Energy Northwests procedures cited by the NRCPPM 11.2.4.6, PPM 11.2.4.5, and HPI-5.9 govern the need for in vitro samples to determine internal exposures as needed to comply with 10 CFR § 20.1204. These procedures allow Radiological Support and Radiation Protection to exercise significant discretion in determining the necessary tests based on the specific facts of each potential exposure. Given that alpha emitters were not detectable or present in a statistically significant quantity, Radiation Support exercised its discretion, in accordance with its procedures, and determined to pursue 24-hour urinalysis, numerous whole-body counts, the smear, and air sample data to calculate dose.

Energy Northwest procedure PPM 11.2.4.6 provides that Radiation Protection supervision or Radiological Support determine when in vitro bioassay sampling is necessary to assess an 53 Inspection Report at 4-5.

54 See Exhibit C [Compendium Laboratories Report] at PDF p. 326. There was a relatively small amount of Pu-238 identified in this pipe smear taken 11 days prior to the event. Id. Those results, however, were not available to Energy Northwest until 3 weeks after the event, and such a small amount of Pu-238 would have resulted in only approximately 6 mrem of dose. See Darois Affidavit at ¶ 18. In addition, the presence of Pu-238 was not reliably detected in any of the other measurements from the site, including either urinalysis sample.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I individuals intake of radioactive material. 55 The procedure states that [i]n vitro bioassay sampling is not normally conducted at Energy Northwest, and is initiated only when whole body count results, air sample results, or personnel contamination events indicate the possibility that an individual has had an intake of hard-to-detect radionuclides (e.g., C-14, Fe-55, Sr-90, H-3, Am-241, Pu-239). 56 Section 3.1 of PPM 11.2.4.6 identifies several events that may trigger the determination to conduct in vitro bioassay sampling. 57 It is important to note that this language is permissive; the occurrence of any one of the events does not explicitly require in vitro bioassay sampling.

For one example, PPM 11.2.4.6 Section 3.1 states that in vitro bioassay sampling may be triggered if intake of alpha contamination (other than naturally occurring) has occurred or is suspected and the magnitude of the intake is unknown. 58 As detailed throughout this Response, work area data indicated that the individuals were not likely to have an intake of hard-to-detect radionuclides or alpha emitters.

Section 3.1 also states that the determination to conduct in vitro bioassay sampling may be triggered based on a positive whole body count which indicates an intake greater than or equal to Action Level 1 (0.001 ALI or 5 mrem Committed Effective Dose Equivalent (CEDE)), as described in PPM 11.2.4.5. 59 That was the case here.

But importantly, PPM 11.2.4.6 does not dictate the type or frequency of in vitro bioassay sample.

Rather, PPM 11.2.4.6 explicitly states that [t]he type and frequency of in vitro sampling is determined on a case-by-case basis, and should be based on the physical, chemical, and biological characteristics of the radionuclides. 60 In addition, PPM 11.2.4.6 Section 5.1 directs that the procedures Attachment 8.1 be consulted for guidelines for type of sample needed for various radionuclides. 61 Attachment 8.1, in turn, provides recommended sample types (urine or urine and feces) for various the radionuclides H-3 (Tritium), C-14, Fe-55, Sr-90, I-131, U-234/235/238, Pu-239/240, and Am-241. 62 In this case, as described above data showed that the most prevalent isotopes in the work area were Co-60 and Co-58. Neither of these isotopes are identified on Attachment 8.1. Thus, the 55 PPM 11.2.4.6 at 3.1.

56 PPM 11.2.4.6 at 2.0.

57 PPM 11.2.4.6 at 3.1.

58 Id. at 3.1.2. This is consistent with procedure PPM 11.2.4.5, which provides in relevant part IF an intake of alpha emitting radionuclides is suspected, THEN EVALUATE the need to perform excreta sampling per PPM 11.2.4.6. PPM 11.2.4.5 at 5.4.1(d).

59 Id. at 3.1.1.

60 Id. at 2.0.

61 Id. at 5.1.1.

62 Id. at Attachment 8.1.

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COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I procedure did not suggest (let alone require) that Energy Northwest undertake either urine sampling or urine and feces sampling.

Furthermore, both Co-60 and Co-58 are gamma emitters, while no data indicated the presence of alpha emitters in statistically significant quantities. Accordingly, there was no clear need for in vitro sampling to assess [the] individuals intake of radioactive material from alpha emitters under Section 3.1.

Energy Northwests actions were also consistent with PPM 11.2.4.5. Section 5.4.3(d) of PPM 11.2.4.5 states in part, [f]or an intake equivalent to or greater than 3000 nanoCuries of Co-60 (an approximate CEDE of 1 rem), EVALUATE the contribution to the CEDE from alpha emitters. 63 While there was sufficient intake of Co-60 to require a separate evaluation of alpha emitters in accordance with Section 5.4.3(d) of PPM 11.2.4.5, the 24-hour urinalysis Energy Northwest conducted was sufficient under its procedures to demonstrate that further evaluation was not required.

Nor was there any clear need to continue excreta collection until the elimination rates are well-established, 64as the Inspection Report allegesgiven that elimination rates were needed for radioisotopes better identified through whole-body counting and a published elimination rate was later found to fit these circumstances. 65 As such, 24-hour urinalysis, in combination with the other data available, met the requirements of PPM 11.2.4.5 and 11.2.4.6, subject to the discretion of Radiological Support and Radiation Protection.

Beyond these two procedures, HPI-5.9 requires that Energy Northwest use information from either in vitro bioassay measurements in addition to lapel or breathing zone air samples, scaling factors from air sampling in the work area, scaling factors from known contamination levels in the work area, or other plant scaling factors in the event of potential alpha intake. 66 Since as described above the data showed that Energy Northwest had no reason to believe that alpha intake potentially occurred, this step was not required. However, Energy Northwest still obtained plant radiological data from other samples described above, including the air sample from the work area and pipe smears.

In sum, Energy Northwest reasonably interpreted and complied with its own procedures, which left significant discretion with Radiological Support and Radiation Protection. The NRC Staff has not provided evidence demonstrating that Energy Northwest deviated from its procedures or any reasonable interpretation of them. There was no violation of the procedures, particularly in a field where the NRC admittedly relies heavily on professional judgement. 67 63 PPM 11.2.4.5 at 5.4.3(d).

64 Inspection Report at 5.

65 See Exhibit C [Compendium Laboratories Report] at PDF p. 257.

66 HPI-5.9 at § 4.5.

67 NRC Health Physics Questions and Answers - Question 372, available at https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/qa372.html www.pillsburylaw.com 12 4866-7463-6146.v1

COLUMBIA GENERATING STATION RESPONSE TO NRC INSPECTION REPORT 05000397/2023092; EA-23-054 ATTACHMENT I III. Conclusion In summary, Energy Northwests actions to measure and to assess dose complied with applicable requirements and guidance. The worker internal dose was assessed in accordance with 10 CFR

§ 20.1204 and Energy Northwests procedures, as well as regulatory guidance and industry standards. Accordingly, Energy Northwest did not violate 10 CFR § 20.1204 and respectfully requests that the NRC withdraw the Apparent Violation.

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AFFIDAVIT STATE OF NEW HAMPSHIRE )

) ss COUNTY OF ROCKINGHAM )

I, Eric L. Darois, hereby affirm and state as follows:

1. I am currently the Executive Director of Radiation Safety & Control Services, Inc.

(RSCS). I have served in that position for 34 years.

2. In that role, I have been a consultant for radiation protection project services for approximately 50 operating and decommissioning nuclear power plants and many more other users of radioactive material, including environmental laboratories, fuel fabrication facilities, Naturally Occurring Radioactive Material sites, medical and laboratory facilities, and other industrial sites. These services include providing calculations and measurements and serving in an advisory role for program operations, data management, Multi-Agency Radiation Survey and Site Investigation Manual implementation, internal dosimetry, and external dosimetry.

3. Over the course of my career I have performed many dose assessments and dose reconstructions, including dose reconstructions under the Energy Employees Occupational Illness Compensation Program Act of 2000. During my employment, I was responsible for technical support groups at Seabrook Station and Connecticut Yankee and responsible for internal and external dosimetry assessments and instrumentation operations and use. I have delivered dozens of presentations and training classes through my career (including statistical analysis and dose analysis) and was recipient of the Jason Jang Award in 2017 from the Organization for Economic Cooperation and Developments Nuclear Energy Agency North American Technical Centre and the Nuclear Energy Institutes Radiological Effluents and Environmental Workshop Steering Committee.

4. I have an M.S. degree in Radiological Sciences and Protection and a B.S. degree in Radiological Health Physics from the University of Massachusetts - Lowell, and am a practicing American Board of Health Physics-certified Health Physics professional.

5. I also served as an expert panel member for the Nuclear Regulatory Commissions Advisory Committee on Nuclear Waste (now merged into the Advisory Committee on Reactor Safeguards). I am currently a member of the Nuclear Energy Institutes Radiological Protection, Environmental and Radiological Waste Decommissioning Issues Task Force.

6. For four years, I was the principal investigator for four nuclear industry Electric Power Research Institute guidance documents relating to alpha contamination control programs and groundwater monitoring at nuclear power plants.

7. I have assisted two Canadian nuclear power facilities in dose reconstruction activities for large cohorts of workers to potential transuranic intakes. I also participated in the Energy Employees Occupational Illness Compensation Program Act of 2000 for the National Institute for Occupational Safety and Health Dose Reconstruction Project for the Department of Energy by performing dose reconstruction calculations for current and former workers of DOE and atomic weapons employees.

8. A copy of my curriculum vitae is attached to this Affidavit as Exhibit 1.

9. In support of this matter, in 2021 RSCS was contracted by Energy Northwest to perform two tasks: 1) An independent dose calculation from the intakes (completed in July 2021);

and 2) A review of the sites calculation of estimated air concentration for the workers intake (completed in October 2021). Our staff performed the first task and I reviewed and approved that document (TSD 21-052). That document contained in Exhibit C, PDF page 75, of Energy Northwests Response. Our staff performed, peer reviewed, and approved another document (TSD 21-083) in support of the second task. That document is attached to this Affidavit as Exhibit 2.

10. Also in support of this Affidavit, I reviewed the NRCs preliminary white finding in NRC Inspection Report EA-23-054 dated June 1, 2023. As part of that review, I performed a follow up second review of the initial calculation and of RSCSs previous internal review of this calculation, including the laboratory results of the air sample and smear analysis. I also have read the Response to which this Affidavit is attached.

11. In this proceeding, Energy Northwest utilized whole-body counting, a 24-hour urine sample for each pipefitter, area air sampling, and swab sampling for the purposes of assessing dose to the two pipefitters.

12. Based on my review of these measurements results, and my 46 years of experience in this industry, my professional opinion is that Energy Northwests measurements were suitable and timely measurements such that under standard industry practice, Energy Northwest, either at the time of the incident or at any point thereafter, did not need to take additional in vitro measurements to determine internal exposure, especially given that (based on my understanding from having read page 7 of the Responses description of an independent laboratory report from December 2020 showing that water in the RWCU system at issue here contained no alpha emitters) the site staff was aware of the isotopic characterization of the source-term responsible for the unplanned airborne event.

13. In addition, based on my review of those results, which I understand Energy Northwest provided to the NRC, I agree with Energy Northwests assertions in its Response at pages 8-10 that the only reasonable way to interpret that data is to conclude that PU239/240 was not detectable or otherwise present in a statistically significant quantity.

14. According to the NRCs Inspection Report at page 6: Based on NRCs assessment of these failures and review of the provided data, the ability to fully evaluate the internal 2

dose was compromised in that inadequate procedures resulted in program failures that could have resulted in the licensees failure to account for more than 100 millirem of unassigned dose to at least one of the pipefitters from alpha emitters. In support of this conclusion, the internal dose assessment performed by the licensees vendor stated, Additional 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion because the initial intake data performed by the vendor was not matching the licensees WBC data, as provided.

15. RSCS is the vendor referenced in the last sentence of this quotation. For proper context, however, the following is a more complete excerpt from our document, TSD 21-052, page 7, The initial intake, using NUREG CR/4884 for Class Y Co-60 and the 24-hour urine sample, does not seem to match the IMBA initial intake using the WBC data. It is a factor of 20 lower for the initial intake. Based on the WBC data, this may indicate that a significant portion of the intake cleared via the ingestion path or clearance out of the lung is slower than the standard Cobalt kinetic modeling. A couple 24-hour fecal samples would have been needed to determine how much of the initial intake cleared through ingestion.

16. We included the above statement in our assessment as merely an observation regarding the initial clearance of the material, not as a comment that Energy Northwest should have undertaken fecal sampling. This component of the intake would contribute a very small fraction of the assigned dose and would only have been used to reconcile the rapid clearance of the initial portion of the intake.

17. The NRC may have taken this statement from our report out of context. Based on my review of the smear and air sample data, there is no evidence that alpha emitters were present for the subject intake and this data represents a beta to alpha ratio of greater than 200,000:1. This ratio confirms that fecal sampling and analysis would not have been needed to assess the dose because there was no reason for Energy Northwest to believe at the time of the event or thereafter that a dose exceeding 100 mrem from alpha emitters occurred, and, in fact, a dose exceeding 100 mrem from alpha emitters did not occur.

18. Finally, although not referenced in the Inspection Report, I note that there was a relatively small amount of Pu-238 identified in the pipe smear taken 11 days prior to the event. Applying the ratio of the Co-60 to Pu-238 activity level in the air sample of 291,000 to 1 to the intake of 7.07E6 pCi of Co-60 equates to a scaled expected intake of Pu-238 of 24.3 pCi. The stochastic ALI for Pu-238 (Y form) is 2E-02 Ci or 20,000 pCi.

This equates to a CEDE of 24.3/20,000 x 5,000 mrem = 6 mrem. In summary, this small amount of Pu-238 would have resulted in only approximately 6 mrem of dose.

19. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

3

Eric L. Darois, M.S., CHP Executive Director Radiation Safety & Control Services, Inc.

Sworn to and subscribed before me:

This ____ day of ________________, 2023 Notary Public 4

Exhibit 1 Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP CAREER PROFILE A broad-based ABHP-certified Health Physics professional with over 40 years of experience in various technical and managerial positions in nuclear power facilities, decommissioning sites, environmental laboratories, fuel fabrication facilities, NORM sites, medical and laboratory facilities and other industrial sites. Excellent experience in alpha contamination controls, internal and external dosimetry, groundwater contamination investigations, neutron measurements, instrumentation, decommissioning cost estimation, MARSSIM implementation and statistical analysis. Authored many professional papers and presentations and provided his experience as a consultant and technical expert to many clients dealing with radiation exposures, radiation detection and regulatory compliance, for both US and international clients. He was also the principal investigator for several nuclear industry -EPRI- guidance documents relating to alpha contamination control programs and groundwater monitoring programs. MS and BS in radiological sciences. Currently a member of NEIs RP, Environmental and Radwaste Decommissioning Issues Task Group.

PROFESSIONAL EXPERIENCE 4/89 - Present Radiation Safety & Control Services, Inc.

Corporate Executive Director

• Provides radiation protection consulting and project services for operating and decommissioning nuclear power plants and other users of radioactive material. These services include calculations and measurements as well as serving in an advisory role for program operations, data management, MARSSIM implementation, internal dosimetry and external dosimetry.

• Participated in the technical review of a draft revision of the MARSSIM manual.

• Principal investigator for four industry EPRI guidance documents. Two of these documents were related to the control of transuranic source terms at nuclear power plants and two were related to groundwater monitoring.

• Served as a key member of the EPRI groundwater assessment team performing groundwater assessments at operating nuclear power plants.

• Served as an expert panel member for the NRCs advisory committee on nuclear waste and on groundwater monitoring and modeling.

• Assisted two Canadian Nuclear Power facilities in dose reconstruction activities for large cohorts of workers to potential transuranic intakes using monte carlo statistical tools.

• Developed a unique criticality detection system and has a patent pending application for the development of a unique beta radiation simulation instrument for training of workers and technicians.

• Principal designer of several RSCS software products including DeCAT -

Decommissioning Cost Analysis Tool, and, ADMS - Analytical Data Management System and has performed many decommissioning cost estimates in support of a variety of projects.

• RSCS Director Lead for the development of a decommissioning cost estimation computer program for the Korean PWR nuclear power plants (KHNP) in conjunction with KOPEC 1

Exhibit 1 Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP which was completed in March 2009 and modified in 2011 to include collective dose (p-rem).

• Participated in the NIOSH dose reconstruction project for the Department of Energy performing Dose Reconstruction calculations.

• In support of several client projects, was the technical lead for several internal dose assessments involving a variety of source terms including: transuranics, natural and enriched uranium, mixed fission products, and Sr-90.

• Performed various program audits for a variety of clients and topics including: alpha program implementation at nuclear power plants, radiation protection program implementation for the USGS and at large medical teaching institutions, and dose modeling review for a decommissioning NPP.

• Project manager for the development of soil screening criteria and surface contamination release criteria for Canadian Nuclear Laboratorys Chalk River Site.

7/03 - 4/06 Radiation Safety & Control Services, Inc.

Yankee Rowe License Termination Project Manager

• As an RSCS Executive Director, was assigned to this project and was responsible for radiological closure of the site including development of the License Termination Plan, Groundwater Monitoring Program, site exposure model development and development/calculation of DCGLs, and Final Status Survey methodologies.

7/99 - 7/03 Radiation Safety & Control Services, Inc.

Bechtel Integrated Site Closure Manager for the Connecticut Yankee (CY)

Decommissioning

• As an RSCS Executive Director, was assigned to this project in a variety of positions including; LTP Technical Project Manager, Project Health Physicist, and HP Technical Group Lead.

• Responsible for radiological and non-radiological closure of the CY site including development of the License Termination Plan.

• Groundwater Monitoring Program, site exposure model development, and, development/calculation of the site DCGLs.

• Expert witness for the CY LTP hearings 6/97 - 7/99 Radiation Safety & Control Services, Inc.

Connecticut Yankee Atomic Power Company Technical Specialist

• As an RSCS Executive Director, assigned to this project for a variety of responsibilities including the internal dosimetry program, the HP count room, and all radiological analysis.

• Performed many radiological safety analysis (10CFR50.59), FSAR changes, internal dose evaluations, and offsite dose calculations.

• Participated in an extensive re-write of HP procedures to support the Radiation Protection Improvement Program.

2

Exhibit 1 Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP

• Instituted alpha contamination and internal dosimetry controls, and provided HP and site-wide training in support of the unique transuranic source term at this site.

4/91 - 7/97 North Atlantic Energy Services Corporation Health Physics Supervisor/Sr. Health Physicist/HP Support Group

• Responsible for the technical maintenance and development of the Radiation protection program at Seabrook Station.

• Served as the HP department training liaison responsible for implementation of the training and qualification programs for department staff and technicians.

• Served on the Health Physics Curriculum Advisory Committee (CAC).

• Emergency response positions included: 1) Emergency Operations Facility (EOF)

Coordinator, and 2) Dose Assessment Specialist.

• Provided technical oversight and direction for regulatory compliance, radiation measurements, dosimetry and other areas.

• Performed HP program assessments and procedure maintenance and development and he was responsible to provide direction in technical projects and evaluations.

• Participated in QA and regulatory audits.

• Member: Radiation Data Management System (General Atomic) Oversight Committee, and the Station Operating Review Committee (SORC).

4/87 - 4/91 New Hampshire Yankee Health Physics Supervisor Dosimetry

• Responsible for the operation of the Internal and External Dosimetry laboratory employing 5 people (Technicians and professional staff).

• Provided technical oversight and direction of the routine operation of each laboratory and many other projects including: development and use of a neutron spectroscopy system using He 3 and TEPC detectors, development of a Hot Particle Dose Rate Meter, and dose analysis of PASS operation against 10CFR50, GDC 19. Member: RDMS oversight committee.

8/86- 4/87 New Hampshire Yankee Sr. Health Physicist HP Support Group

• Work involved providing technical direction, review and development for a variety of HP areas. These areas included the Digital Radiation Monitoring System, the Radiation Calibration Facility, Emergency Planning offsite dose assessment, HP training, instrument calibration, and contamination monitoring. Member, RDMS oversight committee.

1/85 - 8/86 Yankee Atomic Electric Company Titled Engineer HP Methods and Measurements Section 3

Exhibit 1 Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP

• Work involved a variety of activities relative to radiation measurement needs of operational and pre operational nuclear power plants and of the Environmental Laboratory.

• This involvement included the development of a Panasonic Environmental Dosimetry Program, a Vinten Instruments Extremity Dosimetry Program, and a Portable Automated Extrapolation Chamber Measurement System.

• Additional activities included assistance to the Radiation Dosimetry Section in dosimetry algorithm development, TLD badge design, in plant beta radiation field measurements (Steam Generators) and evaluation utilizing the Extrapolation chamber System, software design and development, plant process and effluent monitor calibrations, special plant audits in support of RETS and dosimetry areas, INVIVO and INVITRO program specifications, and an alpha analysis program for an air sampling program.

• Involved in upgrade of the Laboratory NRC by product material license and served on the Laboratory Radiation Safety Committee.

10/81 - 1/85 Yankee Atomic Electric Company Radiation Dosimetry Section

• Work involved the support of dosimetry service provided to three nuclear power stations.

• This work included primary and secondary calibrations of equipment and sources for measurements of beta and gamma personnel doses, operation of the in house dosimetry systems, and maintenance of the systems within the quality control program.

• Duties also included special projects work within radiation measurements activities for the power stations.

8/79 - 10/81 Yankee Atomic Electric Company Radiation Protection Engineer

• Work included Health Physics and Emergency Planning Responsibilities in support of three nuclear power stations.

• HP responsibilities involved assisting the plant HP departments in various disciplines ranging from administrative control of personnel exposures to technical considerations of radiation measurements.

• Emergency Plan responsibilities ranged from the design and calibration of accident area and process radiation monitoring systems to the development of detailed technical and administrative Emergency Plans and Emergency Plan Implementation Procedures including dose assessment nomogram and computer program development.

• Duties also included the development and administration of several detailed Emergency Exercise Scenarios which included radiological and operational sequences.

9/78 - 8/79 Yankee Atomic Electric Company Research Consultant

• Work involved a comprehensive analysis of the response of a state of the art personnel dosimetry system to different types of radiations and the effect of environmental stresses on it.

4

Exhibit 1 Radiation Safety & Control Services, Inc.

93 Ledge Road Seabrook, NH 03874 800-525-8339 www.radsafety.com ERIC L. DAROIS, M.S., CHP

• An extensive study of the beta response of TLD systems and subsequent correlation to average absorbed skin dose was also evaluated.

EDUCATION/ QUALIFICATIONS University of Lowell, Lowell, MA.

M.S. Radiological Sciences and Protection, January 1985.

Thesis: LiF TLD Beta Particle Dosimetry B.S. Radiological Health Physics, June 1978.

American Board of Health Physics Comprehensive Certification, October, 1985.

INDUSTRY COMMITTEES

• Advisory Committee on Nuclear Waste (ACNW) Working Group on NRC Decommissioning Guidance, June 2005, November 2006, June 2007, December 2007; Expert Panel Member.

• Connecticut Yankee License Termination Plan ASLB Hearings, April 2003, Expert Witness Panel.

• NBS Joint Planning Committee for Radiation Survey Instrument and Calibration, 1983.

• ASTM Task Group E 10.04.16, How to Perform Field Measurements of Beta Spectra, 1985.

• Voting Member: ANSI N13.1 Sampling And Monitoring Releases Of Airborne Radioactive Substances From The Stacks And Ducts Of Nuclear Facilities.

• ANSI N13, Radiation Protection standards; Individual Technical Expert Member.

• ANSI/HPS N13.2-2018, Performance Testing of Extremity Dosimeters, Working Group Chair PROFESSIONAL SOCIETIES National Health Physics Society New England Chapter Health Physics Society 5

Exhibit 2 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake Technical Support Document No.21-083 Revision 01 Prepared by:______________________________________________________________

William Cash, Sr. Health Physicist Reviewed by: __________________________________________________ ___________

Robert Leddy, Sr. Health Physicist/Project Manager Calculations Reviewed By:_______________________________________________

Robert Leddy, Sr. HP/Project Manager Approved by: _____________________________________________________________

Ron Thurlow, Sr Director of Operations Radiation Safety & Control Services, Inc RSCS 93 Ledge Road, Seabrook, NH 03874 1-800-525-8339 (603) 778-2871 (Outside USA) www.radsafety.com Radiation Safety & Control Services Date Completed: 10/28/2021 phone: 1-800-525-8339

• fax: 603-778-6879 info@radsafety .com

• www .radsa f et y .com

Exhibit 2 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake RSCS TSD 21-083 Rev. 01 TSD Title Page 2 of 5 Table of Contents

1. Scope .......................................................................................................................................................3

2. Methods ..................................................................................................................................................3

3. Results .....................................................................................................................................................4

4. Conclusion ...............................................................................................................................................5

5. Recommendations ..................................................................................................................................5

6. Attachments............................................................................................................................................5

Exhibit 2 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake RSCS TSD 21-083 Rev. 01 TSD Title Page 3 of 5

1. Scope RSCS was asked to provide a review the Columbia Generation Station calculation which will be used to answer the Nuclear Regulatory Commissions question on the estimated value of Derived Air Concentration (DAC) for the two primary individuals exposed in the RWCU pipe cutting incident. Review included validation the formulae used and the calculational results.

Alternate calculation methods were also used to help validate and bound the results.

2. Methods Supplied supporting documents were reviewed and the calculation for workers # 1 and #2 were reviewed. A spreadsheet was created to assist in calculation verification (Spreadsheet will be provided with transmittal of this TSD). Additionally, DAC-Hours and % of Annual Limit on Intake (ALI), based on the estimated concentration breathed by workers #1 and #2, were assessed.

The spreadsheet analyses time integrated peak and average air concentrations the workers inhaled and provides data to help support vs the regulatory limits. Based on estimated time integrated concentrations and assumed worker breathing rate, exposure durations can be estimated.

The average DAC fraction breathed by Worker #1 in various time increments was estimated using the following formula:

(Equation 1)

Intake DAC Ave =

BR T 1. 0E 08 Where:

Intake = 4.34 uCi for worker #1 and 3.22 uCi for worker #2 DACAve=Co-60 DAC fraction for period T (1 min, 2, 3, 4, or 5 min)

Breathing Rate = 20000 cc/min T = Exp. Duration in mins - 1 min, 2 min, etc.

1 E-8 µCi/cc = Co-60 DAC from 10CFR20 The same assumptions used in the client (Calc. 21-02 Rev. 0) calculation were used in this TSD to validate the results and exposure models. RSCS wants to point out that the equation as it appears in reference 8 Table 7.2 is not derived in the reference and appears to contain two Time terms, both T and (1-exp-T)/. However, the relationship as appears in your calculation can be derived by integrating the expression for concentration as a function of time; C0e-T, so we see no issue with the calculation or your methodology. Once you calculate this Initial concentration value you could use it to estimate intakes for longer durations. However, the initial concentration

Exhibit 2 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake RSCS TSD 21-083 Rev. 01 TSD Title Page 4 of 5 calculated using this method only accounts for removal rate by ventilation (i.e., the room removal rate is applied to the cloud), which for a puff event does not include the significant contributions to concentration changes from cloud diffusion/dispersion.

3. Results Calculations using the same methodology as used in Calc 21-02 Rev.0 confirm the accuracy of the calculated values in the calculation. Table 1 summarizes the results below.

Table 1: Comparison of Calc. 21-02 Rev 0 DAC Fractions vs RSCS Calculated Values Exp. Duration T, Peak DAC Fraction Peak DAC Fraction Peak DAC Fraction Peak DAC Fraction min Worker #1 Cal 21- Worker #1 RSCS Worker #2 Cal 21- Worker #2 RSCS 02 Calc 02 Calc 1 23,000 23,028 17,000 17,085 2 12,000 12,204 9,100 9,055 3 8,600 8,613 6,400 6,391 4 6,800 6,831 5,100 5,068 5 5,800 5,771 4,300 4,282 Table 2: Average DAC fraction Using Eq 1 Above Exp. Duration, min Avg. DAC Fraction for Avg. DAC Fraction for Exposure Duration, Exposure Duration, Worker #1 Worker #2 1 21,700 16,100 2 10,850 8,050 3 7,233 5,367 4 5,425 4,025 5 4,340 3,220 Using the average DAC fraction methodology reduces the calculated values for worker # 1 by approximately 6% at T= 1 min and up to 25% at T= 5 min and for worker #2 by approximately the same values, respectively. Using the peak values is obviously more conservative and may not be challenged by external reviewers.

Based upon the data presented here and on the recollection of the workers in the field as to exposure duration, this was a short duration elevated DAC fraction exposure. The actual intakes of the workers could have occurred in 1-2 minutes based on a puff release.

Exhibit 2 Review of Columbia Generating Station Calculation 21-02 R0 Estimated Air Concentration For Intake RSCS TSD 21-083 Rev. 01 TSD Title Page 5 of 5

4. Conclusion Whether the time integrated or average DAC calculation methods are use, the initial concentration breathed by workers #1 and #2 was substantial. The fact that RP stopped the work and had the workers exit upon observation of the glove bag failure, prevented a potential for over exposure.

5. Recommendations

1. The figure showing the circumstances of the work site is not clear for positioning of the HEPA unit, the air sample, workers # 1 and 2, and the shield wall removal. A better depiction of the work site including an elevation view would be helpful to the external reader.

2. We would suggest not citing equation in Table 7.2 of Maiellos book since it doesnt seem right (it includes two Time terms in the equation). Equation 2 in Calc 21-02 can be derived by replacing the Conc x Time term in Eq 1. with Conc0 x e-T x dT and integrating from time T=0 to Time T to account for the change in concentration as a function of time.

3. In case you have not reviewed HPPOS- 232: Enforcement Guidance Concerning Substantial Potential for Over exposure or Releases, the hyperlink is provided for your use. https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos232.html

6. Attachments None

Exhibit B Alpha Alpha 3rd 2nd Count -

Count - Alpha Uncom Alpha Uncom 2nd Alpha pensat 3rd Total Alpha 1st Alpha - Alpha 1st pensat Count - 3rd Alpha Alpha Alpha ed Count - Chemist Iodine Air PlantCo Air Air Sampler Sample Sample Sample Sample Beta/Gamma - Beta/Gamma - Sampler Beta/Gamma - Alpha Iso- Alpha 1st Alpha 1st Alpha 1st Alpha 1st Count - Sample Count - Alpha Alpha 2nd Alpha 2nd Alpha 2nd Alpha 2nd ed DAC Count - 3rd 3rd 3rd Gross DAC ry Gamm DAC Sample SampleDateTim ndShort Elevati Sample RWP Sampler - - Cal Due Sample Start Flow - Sample Stop Flow - Beta/Gamma Beta/Gamma Beta/Gamma Bkgd Counts Counts Run Average Sample Count DAC Beta/Gamma Count Count Alpha/Beta- Total Count - Count - Count - Count - Compe Gross Count DAC LLD Min Count - Count - Count - Count - Gross Fractio Instr Count - Count - Count - Counts Fractio Sample a Spec Fractio Noble Numbe SampleID e Name on Location Purpose Type Number Serial # Date Start Date Time On Stop Date Time Off - Instr Type - Instr ID - Instr Eff (CPM) (counts) Time Flow Volume Fraction LLD (DAC-Hr) Required Required Gamma DAC Instr Type Instr ID Instr Eff Bkgd nsated Counts Time (min) Fraction (DAC-Hr) Volume Instr Type Instr ID Instr Eff Bkgd Counts n Type Instr ID Instr Eff Bkgd n ID# Co-60 Co-58 Zn-65 Mn-54 DAC n Gas r Units:

Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units:  % Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units: Units:

None Units: None Units: None None None None Units: None None None CFM None None CFM Units: None Units: None Units: None Units: CPM Units: Counts minutes CFM CF Units: % DAC Units: DAC None None Units: N/A DAC None None None CPM None Counts Units: MIN Units: DAC DAC CFM None None None CPM Counts DAC None None None CPM Counts DAC None uCi/cc uCi/cc uCi/cc uCi/cc DAC DAC DAC None 1097086 5/29/2021 3:34 Mode 5 Rx 548 RWCU HX ROOM Lapping Cut #3 for Weld G/A 30004732 6069 11/12/2021 5/28/2021 2120 1.5 5/28/2021 2305 1.5 Model-2 F062 0.1 200 200000 105 1.5 157.5 20.3 0.01 Required Required 0.01 33.4 iMatic iMatic 0.14 0.5 No 14 10 0.26 0.26 138.24 iMatic iMatic 0.14 0.6 9 < 0.30 21-1180 3.30E-07 3.32E-08 4.65E-09 3.37E-09 33.1

Exhibit D VSDS Standard Map Survey Report DIC 1517 I

Survey VSDS_Prod-M-20210529-13 I

..... General Information

Title:

I RB 548 RWCU HX Rm Post Post Decon I Survey Date/Time: I5/29/2021 11:28 I Lead Surveyor: IEmily McKaig I Survey Type: IPost-Decontamination I Work Order/Task #: I021459042701 I Counted By: ITimothy Campbell 5/29/2021 11:30 I RWP #: I30004713 I Rx % Pwr: I0% I Status: IApproved by: Brenda Nordhaus, 5/30/2021 I

..... Dose Rate (DR) Object Prefixes/Suffixes Dose Rates with Prefixes: Dose Rates with No Prefixes: Default Prefixes: Default Suffixes:

HS = Hot Spot "n" = Neutron "b" = Beta "c" = Corrected i

Postings Legend CA=Contaminated Area LHRA=Locked High Radiation Area

- Instruments Used Instrument Instrument

1. Model Serial #

1 L-177 F098 2 451B RV-09 11 3 Model 3 IA022 I HPT Dose (mrem): 34 Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 1 of 5

Exhibit D VSDS Standard Map Survey Report DIC 1517 RB 548' RWCU HX Room Survey #: VSDS_Prod-M-20210529-13 Date/Time: 5/29/2021 11:28

• S,e a ffo.ld Deck RCC Scaffol t:I over Lead' Hut 8

LHRA Declc

~ Area Posted: GA

@)

~ ~ A

~~

L1

@ @ Dain Struct cral s1:1 pports Comments: Summary of Highest Readings (All available values may not be listed)

Smears Air Samples & Wipes

2) 1800000 dpm/100cm2 A/S 1) <0.1 DAC Particulate

2) <DL dpm/100cm2 Type: Post-Decontamination Symbol Legend (for example only) RWP #: 30004713

~ Reactor Power = 0%

ontact fl'ea!illng Posfing em Reai:ling eperal~a Qrip,B*ag

.RM ~ lro1pe Dose rates in mrem/hr & Smears <1k dpm/100 cm2 unless noted Lead Surveyor: Emily McKaig Status: Approved by: Brenda Nordhaus, 5/30/2021 Location Code: RB Bldg/Area Name: 548 Location

Description:

RB 548 RWCU HX Room HPT Dose (mrem): 34 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 2 of 5

Exhibit D VSDS Standard Map Survey Report DIC 1517 Data Point Details Survey #: VSDS_Prod-M-20210529-13 Map: RB\RB-548-RWCU-HX-Room

1. Type Inst. Value Units Position Notes 1 Smear N/A 200000 dpm/100cm2 Inside Cut #3 N/A <DL dpm/100cm2 2 Smear N/A 1800000 dpm/100cm2 Inside Cut #3 N/A <DL dpm/100cm2 3 Smear N/A 2000 dpm/100cm2 Top scaffold deck 4 Smear N/A 3000 dpm/100cm2 On lead on cut #3 5 Smear N/A 3000 dpm/100cm2 Top scaffold deck 6 Smear N/A 15000 dpm/100cm2 Top scaffold deck 7 Smear N/A 3000 dpm/100cm2 Middle scaffold deck 8 Smear N/A 1000 dpm/100cm2 Middle scaffold deck 9 Smear N/A 4000 dpm/100cm2 Middle scaffold deck 10 Smear N/A 1000 dpm/100cm2 Lower scaffold deck 11 Smear N/A 1000 dpm/100cm2 Lower scaffold deck 12 Smear N/A <1000 dpm/100cm2 Lower scaffold deck 13 Smear N/A <1000 dpm/100cm2 Ladder 14 Smear N/A <1000 dpm/100cm2 Ladder 15 Smear N/A <1000 dpm/100cm2 Ladder 16 Smear N/A 5000 dpm/100cm2 Underneath scaffolds 17 Smear N/A 4000 dpm/100cm2 Underneath scaffolds 18 Smear N/A 4000 dpm/100cm2 Underneath scaffolds 19 Smear N/A 10000 dpm/100cm2 On floor 20 Smear N/A 10000 dpm/100cm2 On floor 21 Smear N/A 4000 dpm/100cm2 On floor 22 Smear N/A 4000 dpm/100cm2 On floor 23 Smear N/A 4000 dpm/100cm2 On floor 24 Smear N/A 5000 dpm/100cm2 On floor 25 Smear N/A 10000 dpm/100cm2 On floor 26 Smear N/A 2000 dpm/100cm2 On floor 27 Smear N/A 3000 dpm/100cm2 On floor 28 Smear N/A 4000 dpm/100cm2 On floor 29 Smear N/A 6000 dpm/100cm2 On floor 30 Smear N/A 1000 dpm/100cm2 On floor 31 Smear N/A 1000 dpm/100cm2 On floor 32 Smear N/A 1000 dpm/100cm2 On floor 33 Smear N/A 3000 dpm/100cm2 On floor drain 34 Smear N/A 4000 dpm/100cm2 On floor 35 Smear N/A 4000 dpm/100cm2 On floor 36 Smear N/A 4000 dpm/100cm2 On floor 37 Smear N/A 5000 dpm/100cm2 On floor 38 Smear N/A 3000 dpm/100cm2 On floor 39 Smear N/A 5000 dpm/100cm2 On floor 40 Smear N/A 3000 dpm/100cm2 On floor 41 Smear N/A 5000 dpm/100cm2 On floor 42 Smear N/A <1000 dpm/100cm2 On scaffold for cut #4 43 Smear N/A <1000 dpm/100cm2 On scaffold for cut #4 44 Smear N/A 5000 dpm/100cm2 On RCC scaffold 45 Smear N/A 2000 dpm/100cm2 On RCC scaffold 46 Smear N/A 2000 dpm/100cm2 On scaffold over lead hut 47 Smear N/A 1000 dpm/100cm2 On scaffold over lead hut HPT Dose (mrem): 34 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 3 of 5

Exhibit D VSDS Standard Map Survey Report DIC 1517 Data Point Details Survey #: VSDS_Prod-M-20210529-13 Map: RB\RB-548-RWCU-HX-Room

1. Type Inst. Value Units Position Notes 1 Air Sample <0.1 DAC Particulate General Area A/S Air Sample Nuclear IQ # 1097129 Gooseneck #42833 Cal Due 11/12/21 Posting LHRA CA Posting LHRA Posted at Gate CA HPT Dose (mrem): 34 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 4 of 5

Exhibit D VSDS Standard Map Survey Report DIC 1517 Comments:

Air Sample Nuclear IQ # 1097129 Gooseneck #42833 Cal Due 11/12/21 HPT Dose (mrem): 34 Survey #: VSDS_Prod-M-20210529 Printed On: 10/7/2021 13:40 Page 5 of 5

Exhibit E VSDS Standard Map Survey Report DIC 1517 I

Survey VSDS_Prod-M-20210513-33 I

..... General Information

Title:

I RB 548 Cut and remove RWCU Piping in RWCU HX RM I Survey Date/Time: I5/13/2021 14:20 I Lead Surveyor: ITimothy Campbell I Survey Type: IJob Coverage I Work Order/Task #: I02145904-04-01 I Counted By: ITimothy Campbell 5/13/2021 15:55 I RWP #: I30004697 I Rx % Pwr: I0% I Status: IApproved by: Brenda Nordhaus, 5/19/2021 I Beta Radiation Detected

..... Dose Rate (DR) Object Prefixes/Suffixes Dose Rates with Prefixes: Dose Rates with No Prefixes: Default Prefixes: Default Suffixes:

• = Contact Gen Area HS = Hot Spot "n" = Neutron

+ = 30cm "b" = Beta "c" = Corrected

- Postings Legend Alpha 2=Alpha Level 2 HCA=High Contamination Area RA=Radiation Area CA=Contaminated Area LHRA=Locked High Radiation Area

- Instruments Used Instrument Instrument

1. Model Serial #

1 451B RV-11 2 Telepole 2 T-11 3 RAS HP-EQ-C001561 4 RAS HP-EQ-C0042583 5 RAS HP-EQ-C0042869 6 Lud 177 F098 7 Lud 3 A016 HPT Dose (mrem): 336 Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 1 of 4

Exhibit E VSDS Standard Map Survey Report DIC 1517 RB 548' RWCU HX Room Survey #: VSDS_Prod-M-20210513-33 Date/Time: 5/13/2021 14:20 Cut # llad watei; .drain I§!

I from cuts-and worter,:s !SOPj:

Smears 5, , _ _ _ .J

! p:.A I were eyacuat~ after Floor Posted: I 6 , 71aken second cut The f11!}El ~ as 'Fi_j,,

5/14/21 I

0[1 not rower~, Workers 1e1t I I

@1ttoo the jqb tllLdraln]g,g \'(!IS I I

I PZ:l H IT--$P.i9il PD PL- FIT-SR ,9.,J JL~ j lrm j i

i 1 PSP,-FIT.,':;P.i9.l'f Cutst~&.Ei j 520 Ion !

Ion = close rates w ith ion ctiaml:ler. A ll ottier doserate-s w ith telepole UJWA's were 45D loll establlstled ror machiaists to cut# !lad a*si9.nmcant amoWlt obse,;,,,e, cuts of w:ater i:l~aTn lhtO'the metii1

-catch basin tub (ha-If run) Sortie-w..ater could nof be ooniained ~t the secMd cul. Water s,p !led tpc floor treJn.w. Wq.r:fter-s'eva.cuated dUnng- drairiTng. Tyt ek spror1S-wom on wor,kers alter<lfzjnin,g,

@uFizl 4V D mra cll tu j 0W Comments: Lud 2: 0.4 BKGD; 2 Min count; 14.4% Eff. ; DL = 5.7 dpm Summary of Highest Readings Air Samples. #1: 1095575; #2:1095602; #3:1095688; #4: (All available values may not be listed) 1095689; #5: 1095690 Smears Air Samples & Wipes DAC values for Beta/Gamma 6) 2000K dpm/100cm2 A/S 1) .05 DAC Particulate Alpha disposition being determined by Rad Services per Jeremy 2) 4800 mrad/hr/100 cm2 Soma.

7) <DL dpm/100cm2 Type: Job Coverage Symbol Legend (for example only) RWP #: 30004697

~ Reactor Power = 0%

ontact fl'ea!illng Posfing Beta Radiation Detected em Reai:ling eperal~a Qrip_

B*ag

.RM ~ lro1pe Dose rates in mrem/hr & Smears <1k dpm/100 cm2 unless noted Lead Surveyor: Timothy Campbell Status: Approved by: Brenda Nordhaus, 5/19/2021 Location Code: RB Bldg/Area Name: 548 Location

Description:

RB 548 RWCU HX Room HPT Dose (mrem): 336 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 2 of 4

Exhibit E VSDS Standard Map Survey Report DIC 1517 Data Point Details Survey #: VSDS_Prod-M-20210513-33 Map: RB\RB-548-RWCU-HX-Room

1. Type Inst. Value Units Position Notes DR N/A

• 5200 mrem/hr Pipe N/A + 1400 mrem/hr N/A 900 mrem/hr DR N/A 220 mrem/hr DR N/A

• 800 mrem/hr Pipe N/A + 380 mrem/hr DR N/A 1000 mrem/hr DR N/A 500 mrem/hr DR N/A 750 mrem/hr DR N/A 450 mrem/hr DR N/A

• 5600 mrem/hr Pipe N/A + 1300 mrem/hr DR N/A 230 mrem/hr DR N/A 760 mrem/hr DR N/A 220 Ion mrem/hr DR N/A 130 Ion mrem/hr DR N/A 3 mrem/hr DR N/A 1100 mrem/hr DR N/A 640 mrem/hr DR N/A 480 mrem/hr DR N/A 450 mrem/hr DR N/A 400 mrad/hr DR N/A 5600 mrad/hr DR N/A 275 Ion mrem/hr DR N/A 520 Ion mrem/hr DR N/A 450 Ion mrem/hr DR N/A 425 Ion mrem/hr 1 Smear 1 120 mrad/hr/100 cm2 Inside Pipe WET 2 Smear 1 4800 mrad/hr/100 cm2 Inside Pipe Wet 3 Smear 6 40K dpm/100cm2 Scaffod 4 Smear 6 250K dpm/100cm2 Floor Post spill Wet 5 Smear 6 800K dpm/100cm2 Inside cut Drain Line 7 <DL dpm/100cm2 6 Smear 6 2000K dpm/100cm2 Inside Cut #3 Pipe 7 <DL dpm/100cm2 7 Smear 6 1800K dpm/100cm2 Inside Cut #4 Pipe 7 <DL dpm/100cm2 1 Air Sample .05 DAC Particulate 2 Air Sample .04 DAC Particulate 3 Air Sample .01 DAC Particulate 4 Air Sample .01 DAC Particulate 5 Air Sample <0.01 DAC Particulate Text All readings taken at the plane of the cuts Text Floor Posted:

Text Ion = dose rates with ion chamber.

All other doserates with telepole HPT Dose (mrem): 336 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 3 of 4

Exhibit E VSDS Standard Map Survey Report DIC 1517 Data Point Details Survey #: VSDS_Prod-M-20210513-33 Map: RB\RB-548-RWCU-HX-Room

1. Type Inst. Value Units Position Notes Posting LHRA Posting HCA Posting CA Posting RA Posting Alpha 2 HPT Dose (mrem): 336 Image File: RB\RB-548-RWCU-HX-Room Survey #: VSDS_Prod-M-20210513 Printed On: 10/7/2021 13:29 Page 4 of 4

Exhibit F

~

• ILaboratories LLC PO Box30712 Cha~eslon SC29417 a member of The GEL Group INC 2040 Sa~age Road Cl1arteston SC 29407 P 843 556.8171 F 84~.766.11i8 gel. com March 09, 2021 Mr. Mike Nolan Energy Northwest none Richland, Washington 99352 Re: Part 61 Analysis Work Order: 533227

Dear Mr. Nolan:

GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the sample(s) we received on January 26, 2021. This original data report has been prepared and reviewed in accordance with GELs standard operating procedures.

Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards, with any exceptions noted. The results reported relate only to the items tested and to the sample as received by the laboratory. These results may not be reproduced except as full reports without approval by the laboratory.

Copies of GELs accreditations and certifications can be found on our website at www.gel.com.

Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs on time every time. We trust that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate to call me at (843) 556-8171, ext. 4708.

Sincerely, Kerry PM_SIGN_HERE OBarr for Taylor Cannon Project Manager Purchase Order: 338920 Chain of Custody: 21-01 Enclosures problem solved

Exhibit F Table of Contents General Narrative...............................................................................3 Chain of Custody and Supporting Documentation.........................5 Laboratory Certifications................................................................10 Radiological Analysis.......................................................................12 Case Narrative..........................................................................13 Sample Data Summary............................................................25 Quality Control Summary.......................................................29

Exhibit F General Narrative Page 1 of 38 SDG: 533227

Exhibit F General Narrative for Energy Northwest Part 61 Analysis SDG: 533227 March 09, 2021 Laboratory Identification:

GEL Laboratories LLC 2040 Savage Road Charleston, South Carolina 29407 (843) 556-8171 Summary Sample receipt The sample(s) arrived at GEL Laboratories, LLC, Charleston, South Carolina on January 26, 2021, for analysis.

Chain of Custody form did not contain a relinquished signature. All sample containers arrived without any visible signs of tampering or breakage. There are no additional comments concerning sample receipt.

Sample Identification The laboratory received the following sample:

Laboratory Sample Identification Description 533227001 RCU (RWCU Resins) 20-2431/20-026-HP Case Narrative Sample analyses were conducted using methodology as outlined in GEL Laboratories, LLC (GEL) Standard Operating Procedures. Any technical or administrative problems during analysis, data review, and reduction are contained in the analytical case narratives in the enclosed data package.

Data Package The enclosed data package contains the following sections: General Narrative, Chain of Custody and Supporting Documentation, and data from the following fractions: Radiochemistry. This package, to the best of my knowledge, is in compliance with technical and administrative requirements.

GEL Laboratories, LLC appreciates this opportunity to provide you with analytical results and trusts that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate in contacting me at (843) 556-8171.

I PM_SIGN_HERE Kerry r

OBarr for Taylor Cannon Project Manager Page 2 of 38 SDG: 533227

Exhibit F Chain of Custody and Supporting Documentation Page 3 of 38 SDG: 533227

Page: ___ ] _ _ __ I GEL Laboratories, I.LC Project#: GEL Chain of Custody and Analytical Request 2040 Savage Road GEL Contract#: 338920 **See www.gel.com for GEL's Sample Acceptance SOP**

Charleston, SC 29407 COC Number<'>:_ 21-01 GEL Work Order Number: Phone: (843) 556-8171 GEL Quote Number: 633;)?- 7 Page 4 of 38 Fax: (8431766-1178 Client Name: Energy Northwest Phone#: 509-372-5305 5 Sample Analysis Requested <> (Fill in the number of containers for each test)

Project/Site Name: Columbia Generating Station r..-mail :-;cmcnutt@encrg,-nor1.hwcs.t..com  :§ ~ -¥i E C <-- Preservative Type (6)

E -!~ *;;

g E *;;

.C ~ C Address: P.O. Box 968, Mail Stop PE-12 Richland WA 99352 c

{I') <I'/

s ..,,. ]' ]'

0 8-o: ~ Comments Collected by: Various

...,_8 Send Results To: Steve McNutt

" ..,,. 0"0  ::; ..,,.

~ ~ fl0 N

SDG: 533227 ..

.0 "' ~ N

~~

g,~,]

c:; ~ -g :a Note: extra sample is "Time E u z'°"' "E..,,.:2 "'"'~  ::c

"' ~

• Date Collected i  ::, §$ ~- ~ ~ ce ES g required for sample C

Co!!cclcd QC Field Sample *=>

~

0: C)Z

=~  !:E V1 Sample ID E E -g_

(Military) Code O> Filtered (JJ Matrix("f1 .,, ~ u .0 specific QC

"' For composites - indicate start and stop date/time (mm-dd-yy) ~

0 "C (hhmm) i'.: F-- i u z 0

RCU (RWCU Resins) 20-2431 / 20-026-HP 12/1/2020 8:19 N ss X XI X X XIXIXIX IXIXIX X xtt, X I

TAT Requested: Normal: X. Rush: _ Specify: __ __ (Subjecl lo Surcharge) Email Results: Yes I No Circle Deliverable: C of A I QC Summary / Level I I Level 2 / Level 3 / Level 4 Remarks: Are there any known hazards applicable to these samples? ljso, please list the hazards All samples are radioactive.

Contact dose rates are as follows: Sample Collection Time Zone RWCU Sample - 3.5 mRemlhr on contact. Please ensure extended count times are used for hard to measures(!-! 29, C-14, H-3, I;; _ Tc-99). Please send drum, shields and Ea stcm Pacific voam back to Energy Northwest. Central Other Mountain Chain of Custody Signatures Sample Shipping and Delivery Details Rclinquished l3y (Signed) Date Time Received by (signed) Date Time GEL PM:

Ii /kroo-* f/111 /-tf-z/ 1~ l~~ o HB-l.J Method of Shipment: Date Shipped:

4~ A , ' ' / II A: *.,,,n#-

Ai*b11l #:

I.) Chain of Custody Number= Client Determined 2.) QC Codes: N ""Normal Sample, TB= Trip Blank, FD= Field Duplicate, EB= Equipment Blank, MS= Matrix Spike For Lab /ieceiving Use Only Sample, MSD = ~fatrix Spike Duplicate Sample. G = Grab, C = Composite 3.) Field Filtered: For liquid matrices, indicate with a~ Y

• for yes the sample was field ftltercd or~ N ~'?~I:~arnple was not field filtered 4.) Matrix Codes: DW""Drinking Water, GW=-Groundwater. SW=-Surface Water. WW=Waste Water. \V=Water. ML:c=Misc Custody Seal Intact?

Liquid, SO,,,,Soil, Sll=-Serliment~ SL=S!udge, SSc:::Solid Waste. Q.soQil, F=-Fiher, P""'Wipe, U=Urine, F=Fecal. N=cNasnl 5.) Sample Analysis Requested: Anal)1ical method requested (i.e. 8260B, 60J0B/7470A) and number or containers provided YI:~\' NO for each (i.e. 82608 - 3, 60/0/J.7470A - 1) 6.) Preser\'alive Type: HA-= Hydrochloric Acid, NI= Nitric Acid, SH= Sodium Hydroxide, SA= Sulfuric Acid. AA=

Ascorbic Acid, HX = Hexane, ST""' ~odium Thiosulfate, Ifno preservative is added= !C!l.ve field blank WHITE= LABORATORY YELLOW= FILE PINK= CLIENT Exhibit F

Exhibit F Page _1_ of_1_ Emergency Response Information Shipment# --'2"'"'1~-0~1'----

Radioactive Material, Excepted Package - Limited Quantity of Material OR Instruments or Articles Proper Shipping Names {Check One):

p Radioactive Material, Excepted Package - Limited Quantity of Material, 7, UN2910 Radioactive Material, Excepted Package - Instruments or Articles, 7, UN2911

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1 1 Larll".r~I.Q.* ol .r::,dio.lc:ii'..**r;l n~tGri.:lJ, VOi!<t' l=rt11 r.:1;dk:.1S::.n h.:.zorc: LC* i::-=;c::-l.;:,.

C1J.:,:.ntity of rr...:i.1.:-ni.:i! prc.::.ont:: kr.t{ r~J:::li.:?..':i n :"i:t::.:!.rd [~ n:.b::::;cd h-::,;;;i p.:i;c.~u.gQ dudr:9 ;Jccid;;,nt Semo r.::.:H iJctvo r:i.i::.rbl:. c;:innc-t I::<. :fo'2jJ:7;o,-:::I b-.,* ,:cii1rr1::-nh* ::t\1 ::.:ik1b!c: in!:-tru:non~.

P*;:,:,d:z::lQ;.- do r-.1ot hi:r,.*.-:* ~!.t~1.C*ICl',.CTrVt: L II, C~: ill l,:?l::~;;,1;;~ Sorn.-;. m::i.v h.:rvo Sf,J1PTY 1.:tb:.,i:. or mJ~1 h;,r;;:, :ho *,t-.fcrd* . . ;::;::-:lic,:i.ctf-~ - in !ha p;.:,C.::..;~G 1T,;-,..r:';.;i:-.;i.

~f ~m,* r.Jcfic~.,=!ivc cc ;d.:J:nin::i::bn o::cuc:;., i1 *.r..iil 00 .:;.;::rorr.,;:.lv la"...- iv,n:il.

FIR= C,A bXPL6t.-10N .

Sc-:-nei *=*i th-:!:. m;::~*ri lz. ITT;:J\' bum .* b!.:I mc-:::t* :lo ;,.::,t i8ni~;., ra,::.dil_.,.ft

.

i:::lic,:u:thrii:v dog_c-. n.c::: ch.:ir~--:.: fi:::.r;:i,m~blfr:y or ,:,th,.;; i:ror:-..:;1.io.::; cf m;;,1.::-rbb.

CALL ,lpplng FaPer ArSL

?rlacttes.1ar reS,Cl.l,g, IL'ie:savlng, nrs.~ aid. and oornr*ol ,,1 lire i!lld a1he r 11az2,ds are

i,gt,er ,nan !Ile D11or~y ror rre*l!!sllf1ng rac11a:,-0n ewl.s.

~:::di.:1::.Jon ,liJJL---:crit~* rnur.1 I::.,~ r:c~ifix ,:::: .:.i.*:ci:lr,J,nt c:.::,n:::litbn~ . .J c1:i b u.:;u;:i!f,* :;;;:,:;p:;r.:~il:~~

f:;;,r wdbloJ:Ji~l d;;~=1:::ion:;;.

l;;d.::ii;.1 ;;i::l! or io;:ih ;::nc..-J irr.r..oc:;:ttc;f~* for ::.I k:,.:i:::,1 2:, :::, t:*:i m;;-,t.;;s:; iEO ::*=* 1 £.:, .:~o(l in :7JII 6r.,z-,:::bn=**

S~:,y up,.-in:::1.

tr..c,;1:, ,.n*;.o*u....1hcrizc1C ;:ii~r.;,,:,nn;;il :::.:6..,-.:rv.

Dcil~in .:1.I"id k,,:,f.:it;-.d ur.b}ur~d oon:*=*n~ or ~~:..1iprr:;.,nt ::u :;p"ctcd t:, ~ c-=,n1,:1.rnin.x.~:t: -:lokr:-*

d;:G'..:or:'::lrnin:i1icn ::mC ci;:anup t.rnt!l in::.trucli::;,n/;; :irw r.:,:c.!\*.:ici fn:,r::1 !'1<J.ci::Jlc-r,.Au-:_-t--r::,riN.

PRdt~ClrJ= t..;L.blrtiNG

c

• ::ifr*..-c on:,;::.~ura ;;.;;.Ji~ccnt:,:kicd '::,r.;;,~Lhin 1':J .:i::o::iri:itI.J!. t:SCEJ1.:, .:ir:d ~-1ru*=L'J*~i ::ir.:-,figh1cr::*

1::xc,toct:v~* ch:1:tdn1;1 wii! pn:ri.ld,:.i ::do-_qu::.1,~;.-. pro1,m:;tJc-n.

tUII Larg;:Sp,JI Ct1n::.k:for inifi.::t.! dci~vni>vln:1 ,;;,\i*.:10::unt;-=1-:-1 for :::I ~.,._~!:I 1,:0 mol;:,r:; r:;;:m loc~'.1.

Fire

ri;,

-.:in.co c,t r:dio.:icfr~* I<* rn::r;;;irbh:, *.:,,*:II n::it *:h.:.in:;;;;,- cff,;:c:}v.;.0;-;,:::; cJ .~ir;:a co:-.::rol ti:-,d,ni=tuc.c..

r\'1Cl\f0 c.-:,nL:!,b;;ir.:. frc,rn iiri7i :::m,~ if \'C*l.J c;:.n ,:k, r~ ',llit!-:,:,:..rl ri!:k smau f=I~'.;  :"'l-=,1 )'7.lC\,l ;:.i" d::irr~:i;;;;.::I p:.';;*;:k"::go:.: :nc<,!O urd.'.lrr+::.;itX! .::,':ick:igc::: cul ::*l Hrw  ;:-:,f',;;<.

Dr~* c.ht*mk~L CC2. v,;::ilo; ::pr~Y~ c; rr.r9i..:k1.: f-=.:ern.

Large Flras.

vv~.::il.;:<r :-::ir~v. ioi:i Hk,cdinA .;J.r;:"'lC'Ji"';J:::-t.

SPILL OA LEAK Do r-t:,11c1Jch d:.rr.a9:,:d p;;;-:k":lgo::, c; !:-J:*';\lv:,:::1 mw~-u>rh:il.

LlQTJlid$plll5 C:.1~r,;;n *~vill-7 ::.::.rd. *:.l:ir;h, c,r c thG: non* o::,m'::,:.;::;';11:;lo ::i:.:,:;,::,r;:..::,nt rr. .:,.tw:i~.l.

C:cr,r::ir J:JCMl'dcr :p1!!-J...-ill-: p!.::,:.ti= :;hGG-1 er t;~ to mirJ:nU:-;;, ~:i:roiJdir;i.

~.11odic..-:il pro=-1Qrr,:; !eke. p6=,:-it~* c:,,1c;; r;:i:::lia(c.;;}=.:1J ccn::c;rr::;.

1

...1:.oii rir:it .:i.'ci tnz,:;;1monl ~a=crdinQ -:o tho n.:i~ r...i cf. ~hv Jr,iur 1'. 1

~~Ii

• ~~i~~~~1~~;~:I:~~~f~~~:\:i,~~\*hii~~ro~ =re*=~.

~ ~

:: ~~.ci.~~;~.~*~ilr:, :.w::i!::.;:m,;:.::,, imrn.odi.:ttDt:,* 7lu:h ~-:'d:-: cir ;:.\*G-:;*1,;i~h ru-r;.n;n8'1i;:t~;;.r for lr1,iurod i:Kirn=*7'"1t "l,,,h,::, cont::=*~:;:d :'~l-o.::i~;-...:.:1 rn.:.t.:;.r!-::.:1 mew b-:; J r.iii:C'=" c-.:*rr1,111in::.t.'-.ion c,r,:,blorri :*;:.

cc,nt:::i=:z,d i:..;.r::c1~:., oc 1..1i:,r:,c.r:, .:i. ,d f~ciH1ic:-;:;.

'.:;nctJrc.. lM:.:.1 moCicwl :;.;:.r:.-::*rinttl ~r;;. ;:tN::lr'C' of Li..;.;;. rn:.tcrinl(:.) irr,.**:,t..*1:;;:d, ::,:rd t.:.:.ko pr,;;c:.:iut}::,;1::- lc prc~r.ict lho;n.::..;;:h-*c::..

CALL STATION 24-HOUR EMERGENCY RESPONSE NUMBER FOR EMERGENCY ASSISTANCE

1. Emergency Response Contact (Title): CHEMTREC - 206168)

2. Emergency Phone Number: (800) 424-9300 Drivers signature: Date:

Page 5 of 38 SDG: 533227

5. SHIPPER - NAME AND FACILITY SHIPMENT ID NUMBER Energy Northwest 7. RMSR SHIPPING PAPER 1 PAGE 1 OF _ _PAGES 8. MANIFEST NUMBER Columbia Generating Station RMSR MATERIAL DESCRIP. _ _PAGES RADIOACTIVE MATERIAL (Use lhi-s numbef' on a; conrinuation PO Box 968, North Power Plant Loop COLLECTOR NOT APPLICABLE _ _ PAGES page,.)

Richland, WA 99352-0968 SHIPPING RECORD ADDITIONAL INFORMATION 21-01 PROCESSOR _ 1 _PAGES SHIPPING PAPER USER PERMIT NUMBER SHIPMENT NUMBER X GENERATOR TYPE 8. CONSIGNEE - Name and Facility Address CONTACT 362 21-01 Page 6 of 38

1. EMERGENCY TELEPHONE NUMBER (Include Area Code) 800-424-9300 I NP GEL Labs Taylor Cannon CONTACT 2040 Savage RD TELEPHONE NUMBER Charleston, SC 29407 ORGANIZATION SteveMcNutt (509) 372-5305 Chemtrac (# 208168) ~i~}a~f.!BE R

6. CARRIER - Name and Address EPA 1.D. NUMBER FEDERAL EXPRESS SIGNATURE ** Authonzed C0n$ignee acknowledging malarial recefp( DATE

2. l~IS AN EXCLUSIVE USE SHIPMENT? 3. TOTAi. NUMBER OF 3670 HACKS CROSS RD. BLDG., G 2 NA NOT APPLICABLE YES NOT APPLICABLE PACKAGES IDENTIFIED 1 MEMPHIS, TN 38125 ON THIS MANIFEST l SHIPPING OATE NO ""*

1/1312021

====> This is lo certify th.I:!! the herein named tna:.erlals are property dassificd, de.scribed. packaged, marked, and labcled and

4. DOES EPA REGULATED YES EPA MANIFEST NUMBER CONTACT are in proper condition tor transportation occ:orcling to lho applicable rcgukltlons of lho MATERIAL REQUIRING A CUSTOMER SERVICE J,illf.';\\',\j't;~rB ER Department of Tran$p0ffation NA MANIFEST ACCOMPANY td NO 1-BOD-463-3339 THIS SHIPMENT?

SIGNATURE* Authorized earner ackncwledgng maienru. receipt DATE SDG: 533227 If 'Ye-.s' provide manifest NUTiber ====> A_!JTHORIZEosIGNATURE ;L.-,- lmLE Rw -r 5 IOATE

11. U.S. DEPARTMENT OF TRANSPORTATION DESCRIPTION

)fo;e_ f)l<t-)..._(3/4- ~ / ; r-/(3/2.i

12. 13. 14.

(Include prcpor srupping name, hazard clas:i, UN ID number, OOTLAIJEL 15. 16. 17. 18. TOTAL WEIGHT TRANSPORT PHYSICAL ANO 19. IDENTIFICATION and any other informaUon INDIVIDUAL TOTAL PACKAGE LSNSCO RADIOACTIVE fNDEX CHEMICAL FORM OR VOLUME NUMBER OF RADIONUCLIDES ACTIVITY IN SI UNITS CLASS UN2910,Radioact ive Material, excepted package-- limited quantity of (Use appropriate unils) PACKAGE NA NA Solid Co-60 material, 7 - Part 61 RWCU Sample, 1 Metal Drum Mn-54 Zn-65 Ag*110m Co-58 3.45E-01 MBq NA 57.6 kg Metal Oxides (9.31E-03 mCi)

(127.0 lbs) 11-178-055 0294 M 02' 05. "

. ul Pl?- JO 33130fJ6 FOR CONSIGNEE USE ONLY 2040 SAVAGER[: @]

CHARl ESTDN. SC 294 0 7-4731-40 458-6 009Fl f IP: 20 ?U:Sfl. !Uti y 1?47GU"(!B6BO ISIP (06-2014)

Exhibit F

Exhibit F

~ / Labocatories LLG T(' SAMPLE RECEIPT & REVIEW

• ti :;"' EN *~) () FOR.M 1

Client:

.:::::._ '2.. ~ ';)...,::l../ *

- -A/

SDG/AR/COC/WorkOrrlcr:

Received Ily: Dute Received:

... -- 7

/ /

.I 2 tf/,,.2 */

CU'dc Appli01btc:

,.,,.,, FedEx Grnund UPS Field Services Courier Olher Carr ier and Track ing Num ber I

Suspected Hazonl lufomiatlon

• If Net Counts> IOOcpm on s,mplo

?S not m:ui<<d. "r,dlo:ictive*', cont*c t the R:ulia tion s,fcty Group for further investi g*tio1L A)Shioocd ,s

• DOT H=d ous?

ltiz:ird Cl,s.s Shipped:

If UN29IO, !s the R:,diooctive Shipm UN#: *<..

c11t Survey Compli*nt?

Cf'/ v Y~' No_

B) Di<l the client cL!siguati:: the sampl received as radioactive?

es rul! to bl!

v COC notation or ratlio:Jctivi: sticke rs on c:o11t.:Unc:~ equ:i.l dil!nt di!sigi iation.

C) Did the RSO cl,ssify the sJ111p les V

Ma.,intum Net Counts Observed*

~iJ.*cJ Counts* Arco Ilockground Counts): -il _CPM / M ;

/Jod 2 /

,s r:ulio:mive? Clnsslficd as: Rod l Rod 3 .

.,/

(.__ _/

=

'\..,./ '

D) Did the client do?Sil!na<e somnlcs / COC um.it.ion or haz:.1t<l lubcb:

h:u:a,dous'/ 011 c:o11tainc:rs i::quaJ clii:11t d~ign.:ttion.

[f Dor E is )'CS, sclec~ Hazards below E) Did the RSO identifv nnssible / PCB's Fl:immabk hnzaids'/ Foreign Soil RCR,\ Asb,:stos . Iloryllium Other.

Sample Receipt Critcrlu z<

fl

,. Comments/Qualifiers (Required ror Shipping conl3iners received intact Non-ConJ'orn>lng Items)

I*

l and :Jl;' Circle Applic.iblc:: Seals broken scaled? l,/ 0Jm:Jgcd conl:Jincr Le:tki.ng con1.:1incr Other (dcscnOt!)

2 Chain of custody document; includ will1 shipmeot?

ed

/ J;. Circle Applic:ibk:: Client cont:lctcd :ind pro\idcd COC cqc cre;Hcd upon receipt icetyi

~

3 Samples requiring cold preservatio n

Preservation Method: Wet (o, Ice Packs Dry

-*- Other:'

witl1in (0 5 6 deg. C)?* / "all temperatures ari: recorded in Cl!lsius TEM P:A t/

11 Daily check perfonred and pa5sc Tcmpcruturc Device Scrlul #:

,* //,r 4 d on IR c v lempc,rature gun? /' Second:uy Temp,,,,itu,e Device Se,i:t t r:J l # (If Applicable):

@~

5 Sample containers intact and Samplc.s requiring cherrticai prese scaled'!

rvation I/ ll

-..~

S:1mpk JO's J.nd Containers Affecte 6 d:

at proper pH?

ff Po:sl!r\':Hion added. Lotfl:

If Yes, ore Encores or Soil Kits p<escn t for solids? Yes No NA Do any !>:!mplcs require Volatile Do liquid VOA vials contain acid (If ;,:s, toke to VOA Freezer) 7 preservation? Yes ***No Analysis? Arc liquid VOA vials fo:e ofheadspac NA (If unknown, scleC< No) c? Yes _ No_ NA _

Sampf,: ID"s .:ind concaincrs Jffl!ctc d:

8 Samples received within holding !D's ru1d tests ,ff<ctcd:

lime?

Sample !D's on COC match ID';

9 on [D's =o1d cont.1in-e:rs :t.ffcctcd:

bo1tles?

Date & tim! on COC match date 10 on bottles?

& time

/ Circle Applicable: No elates on conr:tlncrs Na timts on co1uaine~ COC missing info Othcr(dl.!sciibe) zt*

Number of Ctlnt:tloer; received match I/- ~

11 Circle Applicablo: No container count number indicated on COC? on COC Other (dcsctil>!)

1, Are sample coot:tloer; identifiable as

- GEL orm*ided bv use of GEL labels 13::J:C:::OC~~fo~r~m~i~s~p;ru~p~e::rly~si;!s!!!

? *

• 1t::

~

relinquished/received sectitlnS?nc~d~i:!..n:4~*~-J~~!_ Chde Applicable:  ;!(ot relinquism!VOthcr (descril>!)

Comments (Use Continuation Form if ne.111:d):

PM (or PMA) t~vkw: [niti:tls *-**

---

\A.,,{):;

"- ____ _ Date _ _..,_\\!-';).""-

I

• .'=--+/___ Page _l_ of _J_

GL-CHL-SR-001 Rev7 Page 7 of 38 SDG: 533227

Exhibit F Laboratory Certifications Page 8 of 38 SDG: 533227

Exhibit F List of current GEL Certifications as of 09 March 2021 State Certification Alabama 42200 Alaska 17018 Alaska Drinking Water SC00012 Arkansas 880651 CLIA 42D0904046 California 2940 Colorado SC00012 Connecticut PH0169 DoD ELAP/ ISO17025 A2LA 2567.01 Florida NELAP E87156 Foreign Soils Permit P3301500283, P3301500253 Georgia SC00012 Georgia SDWA 967 Hawaii SC00012 Idaho SC00012 Illinois NELAP 200029 Indiana CSC01 Kansas NELAP E10332 Kentucky SDWA 90129 Kentucky Wastewater 90129 Louisiana Drinking Water LA024 Louisiana NELAP 03046 (AI33904)

Maine 2019020 Maryland 270 Massachusetts MSC012 Massachusetts PFAS Approv Letter Michigan 9976 Mississippi SC00012 Nebraska NEOS2613 Nevada SC0001220211 New Hampshire NELAP 2054 New Jersey NELAP SC002 New Mexico SC00012 New York NELAP 11501 North Carolina 233 North Carolina SDWA 45709 North Dakota R158 Oklahoma 2019165 Pennsylvania NELAP 6800485 Puerto Rico SC00012 S. Carolina Radiochem 10120002 Sanitation Districts of L 9255651 South Carolina Chemistry 10120001 Tennessee TN 02934 Texas NELAP T1047042352119 Utah NELAP SC00012202034 Vermont VT87156 Virginia NELAP 460202 Washington C780 Page 9 of 38 SDG: 533227

Exhibit F Radiological Analysis Page 10 of 38 SDG: 533227

Exhibit F Case Narrative Page 11 of 38 SDG: 533227

Exhibit F Radiochemistry Technical Case Narrative Energy Northwest SDG #: 533227 Product: Alphaspec Am241, Cm, Solid High Rad Analytical Method: DOE EML HASL-300, Am-05-RC Modified Analytical Procedure: GL-RAD-A-011 REV# 28 Analytical Batch: 2095447 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758781 Method Blank (MB) 1204758782 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758783 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Alphaspec Pu242, Solid High Rad Analytical Method: DOE EML HASL-300, Pu-11-RC Modified Analytical Procedure: GL-RAD-A-011 REV# 28 Analytical Batch: 2095448 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758784 Method Blank (MB) 1204758785 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758786 Laboratory Control Sample (LCS)

Page 12 of 38 SDG: 533227

Exhibit F The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Alphaspec Np, Solid High Rad Analytical Method: ASTM C 1475-00 Modified Analytical Procedure: GL-RAD-A-069 REV# 0 Analytical Batch: 2095452 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758790 Method Blank (MB) 1204758791 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758792 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this Page 13 of 38 SDG: 533227

Exhibit F report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Gammaspec, Gamma, solid High Rad Analytical Method: DOE HASL 300, 4.5.2.3/Ga-01-R Analytical Procedure: GL-RAD-A-013 REV# 27 Analytical Batch: 2085575 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204740613 Method Blank (MB) 1204740614 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204740615 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met The following detection limits were not achieved due to high sample activity.

Sample Analyte Value 1204740614 (RCU (RWCU Resins) Result 0 < MDA 0.00434 > RDL 0.001 Cesium-137 20-2431/20-026-HPDUP) uCi/g Result 0.00115 < MDA 0.00389 > RDL Niobium-94 0.0002 uCi/g 533227001 (RCU (RWCU Resins) Result -0.000488 < MDA 0.00376 > RDL Niobium-94 20-2431/20-026-HP) 0.0002 uCi/g Qualifier Information Qualifier Reason Analyte Sample Client Sample Results are considered a RCU (RWCU Resins)

UI false positive due to low Antimony-125 533227001 20-2431/20-026-HP abundance.

Page 14 of 38 SDG: 533227

Exhibit F RCU (RWCU Resins) 1204740614 20-2431/20-026-HP(5332 RCU (RWCU Resins)

Cesium-137 1204740614 20-2431/20-026-HP(5332 RCU (RWCU Resins)

Niobium-95 533227001 20-2431/20-026-HP Product: Gamma Ni59, Solid High Rad Analytical Method: DOE RESL Ni-1 Analytical Procedure: GL-RAD-A-022 REV# 19 Analytical Batch: 2095455 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758799 Method Blank (MB) 1204758800 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758801 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed double nickel precipitation for removal of interferences.

Qualifier Information Qualifier Reason Analyte Sample Client Sample Results are considered a RCU (RWCU Resins)

UI false positive due to high Nickel-59 533227001 20-2431/20-026-HP counting uncertainty.

RCU (RWCU Resins) 1204758800 20-2431/20-026-HP(5332 Page 15 of 38 SDG: 533227

Exhibit F Product: Gamma I129, Solid High Rad Analytical Method: DOE EML HASL-300,I-01 Modified Analytical Procedure: GL-RAD-A-006 REV# 21 Analytical Batch: 2095982 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759553 Method Blank (MB) 1204759554 Laboratory Control Sample (LCS) 1204759555 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met Sample (See Below) did not meet the detection limit due to limited sample volume. Sample was counted the maximum count time in order to achieve the lowest MDAs possible.

Sample Analyte Value 533227001 (RCU (RWCU Resins) Result -0.000275 < MDA 0.000402 > RDL Iodine-129 20-2431/20-026-HP) 0.00008 uCi/g Product: Liquid Scint Pu241, Solid High Rad Analytical Method: DOE EML HASL-300, Pu-11-RC Modified Analytical Procedure: GL-RAD-A-035 REV# 21 Analytical Batch: 2095450 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758787 Method Blank (MB) 1204758788 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP)

Page 16 of 38 SDG: 533227

Exhibit F 1204758789 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed second columns for removal of iron interferences.

Quality Control (QC) Information RDL Met Samples (See Below) did not meet the detection limits, however the 10CFR61 limitations were met.

Sample Analyte Value 1204758788 (RCU (RWCU Resins) Result -0.00146 < MDA 0.00361 > RDL Plutonium-241 20-2431/20-026-HPDUP) 0.0035 uCi/g 533227001 (RCU (RWCU Resins) Result 0.00123 < MDA 0.00405 > RDL Plutonium-241 20-2431/20-026-HP) 0.0035 uCi/g Product: Liquid Scint Ni63, Solid High Rad Analytical Method: DOE RESL Ni-1, Modified Analytical Procedure: GL-RAD-A-022 REV# 19 Analytical Batch: 2095454 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758796 Method Blank (MB) 1204758797 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758798 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Page 17 of 38 SDG: 533227

Exhibit F Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed double nickel precipitation for removal of interferences.

Product: LSC, Rapid Sr-89 and Sr-90, High Rad Solids Analytical Method: GL-RAD-A-051 Analytical Procedure: GL-RAD-A-051 REV# 8 Analytical Batch: 2095456 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204758802 Method Blank (MB) 1204758803 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204758804 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Quality Control (QC) Information RDL Met Samples (See Below) did not meet the detection limits, however the 10CFR61 limitations were met.

Sample Analyte Value Result -0.00000716 < MDA 0.00011 > RDL 1204758802 (MB) Strontium-90 0.00004 uCi/g 533227001 (RCU (RWCU Resins) Result 0.000777 < MDA 0.00118 > RDL Strontium-90 20-2431/20-026-HP) 0.00004 uCi/g Page 18 of 38 SDG: 533227

Exhibit F Product: LSC, Tritium Dist, Solid High Rad Analytical Method: EPA 906.0 Modified Analytical Procedure: GL-RAD-A-002 REV# 23 Analytical Batch: 2095983 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759556 Method Blank (MB) 1204759557 Laboratory Control Sample (LCS) 1204759558 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Liquid Scint C14, Solid High Rad Analytical Method: EPA EERF C-01 Modified Analytical Procedure: GL-RAD-A-003 REV# 16 Analytical Batch: 2095984 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759559 Method Blank (MB) 1204759560 Laboratory Control Sample (LCS) 1204759561 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable.

Product: Liquid Scint Tc99, Solid High Rad Analytical Method: DOE EML HASL-300, Tc-02-RC Modified Analytical Procedure: GL-RAD-A-059 REV# 5 Page 19 of 38 SDG: 533227

Exhibit F Analytical Batch: 2095989 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204759565 Method Blank (MB) 1204759566 Laboratory Control Sample (LCS) 1204759567 Laboratory Control Sample Duplicate (LCSD)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Preparation Information Preparation Information Performed a double iron scavenge and all part 61 clean ups and rinses to reduce interferences.

Technical Information Recounts Samples 1204759566 (LCS) and 1204759567 (LCSD) were recounted due to low recovery. The recounts are reported.

Product: Liquid Scint Fe55, Solid High Rad Analytical Method: DOE RESL Fe-1, Modified Analytical Procedure: GL-RAD-A-040 REV# 13 Analytical Batch: 2098494 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 19 Preparation Batch: 2094219 The following samples were analyzed using the above methods and analytical procedure(s).

GEL Sample ID# Client Sample Identification 533227001 RCU (RWCU Resins) 20-2431/20-026-HP 1204764651 Method Blank (MB) 1204764652 533227001(RCU (RWCU Resins) 20-2431/20-026-HP) Sample Duplicate (DUP) 1204764653 Laboratory Control Sample (LCS)

The samples in this SDG were analyzed on an "as received" basis.

Data Summary:

All sample data provided in this report met the acceptance criteria specified in the analytical methods and Page 20 of 38 SDG: 533227

Exhibit F procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions.

Technical Information Sample Re-prep/Re-analysis Samples were reprepped due to high recovery. The re-analysis is being reported.

Certification Statement Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless otherwise noted in the analytical case narrative.

Page 21 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com ENNO002 Energy Northwest Client SDG: 533227 GEL Work Order: 533227 Sample(s) Contained within this report:

Lab Sample ID Client Sample ID Sample Description Collected 533227001 RCU (RWCU Resins) 20- N/A 12/01/2020 08:19 2431/20-026-HP Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the Certificate of Analysis.

This data report has been prepared and reviewed in accordance with GEL Laboratories LLC standard operating procedures. Please direct any questions to your Project Manager, Taylor Cannon.

Reviewed by

~~

Signature: Name: Theresa Austin Date: 10 MAR 2021

Title:

Group Leader Page 22 of 38 SDG: 533227

Exhibit F Sample Data Summary Page 23 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Radiological Certificate of Analysis GEL Sample ID: 533227001 Client: Energy Northwest Client Sample ID: RCU (RWCU Resins) 20-2431/20-026-HP Collect Date: December 01, 2020 Matrix: Misc Solid Receive Date: January 26, 2021 Report Date: March 10, 2021 2

Analyte Run Date Qualifier Activity 2 Sigma 1 Uncertainty MDA RL Units H-3 02/26/21 U 8.82E-04 1.50E-03 2.58E-03 4.00E-02 uCi/g C-14 02/26/21 3,U 2.23E-04 1.87E-04 3.10E-04 8.00E-03 uCi/g Fe-55 03/03/21 3 6.92E+01 8.47E-01 1.61E-01 7.00E-01 uCi/g Ni-63 03/02/21 3 1.52E+00 3.00E-02 5.66E-03 3.50E-03 uCi/g Sr-89 02/26/21 3,U 6.18E-03 4.06E-03 6.59E-03 7.00E-01 uCi/g Sr-90 02/26/21 3,U 7.77E-04 7.04E-04 1.18E-03 4.00E-05 uCi/g Tc-99 03/02/21 3 6.49E-03 4.74E-04 4.61E-04 3.00E-03 uCi/g Pu-241 03/02/21 U 1.23E-03 2.36E-03 4.05E-03 3.50E-03 uCi/g Alpha Spec Np-237 03/01/21 U -7.88E-06 9.91E-06 3.31E-05 1.00E-04 uCi/g Pu-238 03/01/21 U 1.54E-05 4.19E-05 7.23E-05 1.00E-04 uCi/g Pu-239/240 03/01/21 U 2.01E-05 4.20E-05 6.23E-05 1.00E-04 uCi/g Pu-242 03/01/21 U -7.34E-06 2.50E-05 6.97E-05 1.00E-04 uCi/g Am-241 03/01/21 U 9.24E-06 2.93E-05 4.42E-05 1.00E-04 uCi/g Cm-242 03/01/21 U -1.82E-06 3.02E-05 6.40E-05 2.00E-02 uCi/g Cm-243/244 03/01/21 U -1.25E-06 2.08E-05 4.39E-05 1.00E-04 uCi/g Gamma Spec Cr-51 01/27/21 U -1.44E-02 4.41E-02 7.62E-02 uCi/g Mn-54 01/27/21 3 1.66E+00 1.09E-02 5.82E-03 uCi/g Fe-59 01/27/21 U 2.77E-03 1.59E-02 2.73E-02 uCi/g Co-57 01/27/21 3 2.08E-03 1.09E-03 1.40E-03 uCi/g Co-58 01/27/21 3 3.53E-02 6.64E-03 8.22E-03 uCi/g Co-60 01/27/21 3 1.73E+01 2.01E-02 5.90E-03 7.00E-01 uCi/g Ni-59 03/01/21 UI 0.00E+00 1.15E-02 7.05E-03 2.20E-01 uCi/g Zn-65 01/27/21 3 4.17E-01 1.99E-02 1.40E-02 uCi/g Zr-95 01/27/21 U -4.47E-03 8.60E-03 1.41E-02 uCi/g Nb-94 01/27/21 U -4.88E-04 2.81E-03 3.76E-03 2.00E-04 uCi/g Nb-95 01/27/21 UI 0.00E+00 6.34E-03 7.93E-03 uCi/g Ru-103 01/27/21 U 2.84E-03 4.62E-03 7.81E-03 uCi/g Ag-110m 01/27/21 3 3.79E-02 7.21E-03 9.02E-03 uCi/g Sn-113 01/27/21 U 4.96E-04 2.64E-03 4.52E-03 uCi/g Sb-124 01/27/21 U 1.49E-03 1.78E-03 3.05E-03 uCi/g Sb-125 01/27/21 UI 0.00E+00 6.81E-03 7.90E-03 uCi/g I-129 02/26/21 U -2.75E-04 2.52E-04 4.02E-04 8.00E-05 uCi/g Cs-134 01/27/21 U 4.74E-04 3.39E-03 5.55E-03 uCi/g Cs-136 01/27/21 U -2.12E-02 8.65E-02 1.49E-01 uCi/g Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

UI Gamma Spectroscopy--Uncertain identification Page 24 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Radiological Certificate of Analysis GEL Sample ID: 533227001 Client: Energy Northwest Client Sample ID: RCU (RWCU Resins) 20-2431/20-026-HP Collect Date: December 01, 2020 Matrix: Misc Solid Receive Date: January 26, 2021 Report Date: March 10, 2021 2

Analyte Run Date Qualifier Activity 2 Sigma 1 Uncertainty MDA RL Units Cs-137 01/27/21 3 6.98E-03 3.43E-03 4.19E-03 1.00E-03 uCi/g Ba-133 01/27/21 U -2.31E-04 1.83E-03 3.15E-03 uCi/g Ba-140 01/27/21 U -5.51E-02 1.53E-01 2.57E-01 uCi/g La-140 01/27/21 U 3.56E-04 1.02E-02 1.74E-02 uCi/g Ce-141 01/27/21 U 2.47E-03 4.70E-03 7.62E-03 uCi/g Ce-144 01/27/21 U 2.42E-03 7.31E-03 1.10E-02 uCi/g Hf-181 01/27/21 U -1.65E-03 4.70E-03 7.94E-03 uCi/g Ta-182 01/27/21 U 2.59E-03 8.72E-03 1.49E-02 uCi/g Co-60 Ratio(C-14 02/22/21 4.94E+00 none Aliquot/Sample)

Note(s): 1. Calculated MDAs are a-posteriori values at the 95% confidence level.

2. Activity is reported on a dry weight basis unless otherwise indicated in the case narrativeand is decay corrected to the sample collect date.

3. Results are statistically positive at the 95% confidence level. (activity is greater than or equal to the two sigma uncertainty)

U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

UI Gamma Spectroscopy--Uncertain identification Page 25 of 38 SDG: 533227

Exhibit F GEL LABORATORIES, LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com 10 CFR Part 50/61 Isotope Abundance Report GEL Sample ID: 533227001 Client: Energy Northwest Client Sample ID: RCU (RWCU Resins) 20-2431/20-026-HP Collect Date: December 01, 2020 Matrix: Misc Solid Receive Date: January 26, 2021 Analyte Activity Units  % Abundance Ni-63 1.52E+00 uCi/g 001.69 Fe-55 6.92E+01 uCi/g 076.74 Alpha Spec Gamma Spec Co-58 3.53E-02 uCi/g 000.04 Co-60 1.73E+01 uCi/g 019.16 Mn-54 1.66E+00 uCi/g 001.84 Ag-110m 3.79E-02 uCi/g 000.04 Zn-65 4.17E-01 uCi/g 000.46 Total Activity: 9.01E+01 Total % Abundance: 100.00 Note: The parmname will appear only if the abundance, if present, is above the minimum level of 0.01 Page 26 of 38 SDG: 533227

Exhibit F Quality Control Summary Page 27 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Report Date: March 10, 2021 Energy Northwest Page 1 of 11 none Richland, Washington

Contact:

Mr. Mike Nolan Workorder: 533227 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 QC1204740614 533227001 DUP Antimony-124 U 0.00149 U 0.000592 uCi/g N/A N/A JXB7 01/28/21 09:03 Uncertainty +/-0.00178 +/-0.00188 Antimony-125 UI 0.000 UI 0.000 uCi/g N/A N/A Uncertainty +/-0.00681 +/-0.00626 Barium-133 U -0.000231 U 0.000133 uCi/g N/A N/A Uncertainty +/-0.00183 +/-0.00188 Barium-140 U -0.0551 U -0.0431 uCi/g N/A N/A Uncertainty +/-0.153 +/-0.167 Cerium-141 U 0.00247 U -0.000136 uCi/g N/A N/A Uncertainty +/-0.00470 +/-0.00489 Cerium-144 U 0.00242 U 0.00333 uCi/g N/A N/A Uncertainty +/-0.00731 +/-0.00689 Cesium-134 U 0.000474 U 0.00353 uCi/g N/A N/A Uncertainty +/-0.00339 +/-0.00348 Cesium-136 U -0.0212 U 0.0382 uCi/g N/A N/A Uncertainty +/-0.0865 +/-0.0943 Cesium-137 0.00698 UI 0.000 uCi/g 46.6 (0% - 100%)

Uncertainty +/-0.00343 +/-0.00292 Chromium-51 U -0.0144 U 0.00397 uCi/g N/A N/A Uncertainty +/-0.0441 +/-0.0463 Cobalt-57 0.00208 0.00266 uCi/g 24.4 (0% - 100%)

Uncertainty +/-0.00109 +/-0.00111 Cobalt-58 0.0353 0.0371 uCi/g 4.86 (0% - 100%)

Uncertainty +/-0.00664 +/-0.00758 Cobalt-60 17.3 18.3 uCi/g 5.57 (0%-20%)

Uncertainty +/-0.0201 +/-0.0211 Hafnium-181 U -0.00165 U 0.00523 uCi/g N/A N/A Uncertainty +/-0.00470 +/-0.00558 Page 28 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 2 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 Iron-59 U 0.00277 U 0.00161 uCi/g N/A N/A JXB7 01/28/21 09:03 Uncertainty +/-0.0159 +/-0.0166 Lanthanum-140 U 0.000356 U -0.00425 uCi/g N/A N/A Uncertainty +/-0.0102 +/-0.0114 Manganese-54 1.66 1.76 uCi/g 5.79 (0%-20%)

Uncertainty +/-0.0109 +/-0.0116 Niobium-94 U -0.000488 U 0.00115 uCi/g N/A N/A Uncertainty +/-0.00281 +/-0.00247 Niobium-95 UI 0.000 U 0.00339 uCi/g N/A N/A Uncertainty +/-0.00634 +/-0.00742 Ruthenium-103 U 0.00284 U -0.000444 uCi/g N/A N/A Uncertainty +/-0.00462 +/-0.00484 Silver-110m 0.0379 0.0382 uCi/g 0.763 (0% - 100%)

Uncertainty +/-0.00721 +/-0.00746 Tantalum-182 U 0.00259 U -0.00161 uCi/g N/A N/A Uncertainty +/-0.00872 +/-0.00903 Tin-113 U 0.000496 U 0.000272 uCi/g N/A N/A Uncertainty +/-0.00264 +/-0.00273 Zinc-65 0.417 0.397 uCi/g 4.77 (0%-20%)

Uncertainty +/-0.0199 +/-0.0194 Zirconium-95 U -0.00447 U 0.000424 uCi/g N/A N/A Uncertainty +/-0.00860 +/-0.00895 QC1204740615 LCS Americium-241 0.0669 0.0699 uCi/g 104 (75%-125%) 01/27/21 10:12 Uncertainty +/-0.00313 Antimony-124 U -2.74E-05 uCi/g Uncertainty +/-0.000160 Antimony-125 U 8.02E-05 uCi/g Uncertainty +/-0.000450 Barium-133 U -3.22E-05 uCi/g Uncertainty +/-0.000176 Page 29 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 3 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 Barium-140 U -1.65E-05 uCi/g JXB7 01/27/21 10:12 Uncertainty +/-0.000573 Cerium-141 U 4.45E-05 uCi/g Uncertainty +/-0.000154 Cerium-144 U -0.000264 uCi/g Uncertainty +/-0.000692 Cesium-134 U 8.28E-05 uCi/g Uncertainty +/-0.000163 Cesium-136 U 3.04E-06 uCi/g Uncertainty +/-0.000221 Cesium-137 0.0223 0.0217 uCi/g 97.3 (75%-125%)

Uncertainty +/-0.000989 Chromium-51 U -0.000547 uCi/g Uncertainty +/-0.00107 Cobalt-57 U 3.62E-05 uCi/g Uncertainty +/-9.06E-05 Cobalt-58 U 2.20E-05 uCi/g Uncertainty +/-0.000137 Cobalt-60 0.0125 0.0141 uCi/g 112 (75%-125%)

Uncertainty +/-0.000908 Hafnium-181 U -5.46E-05 uCi/g Uncertainty +/-0.000198 Iron-59 U -0.000134 uCi/g Uncertainty +/-0.000348 Lanthanum-140 U 5.53E-05 uCi/g Uncertainty +/-6.33E-05 Manganese-54 0.000931 uCi/g Uncertainty +/-0.000482 Niobium-94 U 0.000166 uCi/g Uncertainty +/-0.000137 Page 30 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 4 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 Niobium-95 U -7.06E-05 uCi/g JXB7 01/27/21 10:12 Uncertainty +/-0.000120 Ruthenium-103 U 4.62E-05 uCi/g Uncertainty +/-0.000144 Silver-110m U 3.84E-05 uCi/g Uncertainty +/-0.000215 Tantalum-182 U -0.000200 uCi/g Uncertainty +/-0.000337 Tin-113 U -0.000125 uCi/g Uncertainty +/-0.000189 Zinc-65 U -0.000294 uCi/g Uncertainty +/-0.000394 Zirconium-95 U 0.000292 uCi/g Uncertainty +/-0.000358 QC1204740613 MB Antimony-124 U 9.66E-06 uCi/g 01/27/21 07:53 Uncertainty +/-1.89E-05 Antimony-125 U 1.83E-05 uCi/g Uncertainty +/-7.57E-05 Barium-133 U 1.47E-05 uCi/g Uncertainty +/-3.16E-05 Barium-140 U -4.30E-07 uCi/g Uncertainty +/-0.000101 Cerium-141 U -1.06E-05 uCi/g Uncertainty +/-3.88E-05 Cerium-144 U -2.63E-05 uCi/g Uncertainty +/-0.000132 Cesium-134 U 4.39E-07 uCi/g Uncertainty +/-2.89E-05 Cesium-136 U 4.17E-05 uCi/g Uncertainty +/-3.05E-05 Page 31 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 5 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 Cesium-137 U -2.93E-05 uCi/g JXB7 01/27/21 07:53 Uncertainty +/-3.80E-05 Chromium-51 U -0.000184 uCi/g Uncertainty +/-0.000202 Cobalt-57 U -5.56E-06 uCi/g Uncertainty +/-2.19E-05 Cobalt-58 U 2.56E-05 uCi/g Uncertainty +/-2.60E-05 Cobalt-60 U 3.03E-05 uCi/g Uncertainty +/-7.03E-05 Hafnium-181 U 1.79E-05 uCi/g Uncertainty +/-2.99E-05 Iron-59 U -4.56E-05 uCi/g Uncertainty +/-4.76E-05 Lanthanum-140 U 3.23E-05 uCi/g Uncertainty +/-3.16E-05 Manganese-54 U -2.16E-05 uCi/g Uncertainty +/-2.69E-05 Niobium-94 U 2.92E-06 uCi/g Uncertainty +/-2.50E-05 Niobium-95 U -9.26E-06 uCi/g Uncertainty +/-2.87E-05 Ruthenium-103 U 7.59E-07 uCi/g Uncertainty +/-2.38E-05 Silver-110m U -2.03E-05 uCi/g Uncertainty +/-3.51E-05 Tantalum-182 U -1.33E-05 uCi/g Uncertainty +/-0.000108 Tin-113 U 9.04E-06 uCi/g Uncertainty +/-3.33E-05 Page 32 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 6 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2085575 Zinc-65 U 6.56E-06 uCi/g JXB7 01/27/21 07:53 Uncertainty +/-6.58E-05 Zirconium-95 U -4.64E-05 uCi/g Uncertainty +/-5.44E-05 Batch 2095447 QC1204758782 533227001 DUP Americium-241 U 9.24E-06 U 1.58E-05 uCi/g N/A N/A TC1 03/01/21 15:32 Uncertainty +/-2.93E-05 +/-3.57E-05 Curium-242 U -1.82E-06 U -1.81E-06 uCi/g N/A N/A Uncertainty +/-3.02E-05 +/-2.99E-05 Curium-243/244 U -1.25E-06 U 2.89E-06 uCi/g N/A N/A Uncertainty +/-2.08E-05 +/-2.93E-05 QC1204758783 LCS Americium-241 0.000186 0.000168 uCi/g 90.4 (75%-125%) 03/01/21 15:31 Uncertainty +/-3.11E-05 Curium-242 U 9.38E-07 uCi/g Uncertainty +/-4.12E-06 Curium-243/244 0.000207 0.000170 uCi/g 81.9 (75%-125%)

Uncertainty +/-3.09E-05 QC1204758781 MB Americium-241 U -3.60E-07 uCi/g 03/01/21 15:32 Uncertainty +/-3.01E-06 Curium-242 U -5.41E-07 uCi/g Uncertainty +/-3.03E-06 Curium-243/244 U 1.72E-06 uCi/g Uncertainty +/-5.12E-06 Batch 2095448 QC1204758785 533227001 DUP Plutonium-238 U 1.54E-05 U -1.05E-05 uCi/g N/A N/A TC1 03/01/21 15:32 Uncertainty +/-4.19E-05 +/-2.42E-05 Plutonium-239/240 U 2.01E-05 U 4.79E-06 uCi/g N/A N/A Uncertainty +/-4.20E-05 +/-3.39E-05 Page 33 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 7 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2095448 Plutonium-242 U -7.34E-06 U -7.18E-06 uCi/g N/A N/A TC1 03/01/21 15:32 Uncertainty +/-2.50E-05 +/-2.45E-05 QC1204758786 LCS Plutonium-238 U 1.35E-06 uCi/g 03/01/21 15:32 Uncertainty +/-2.57E-06 Plutonium-239/240 0.000187 0.000209 uCi/g 111 (75%-125%)

Uncertainty +/-2.05E-05 Plutonium-242 U 2.51E-06 uCi/g Uncertainty +/-3.03E-06 QC1204758784 MB Plutonium-238 U 1.83E-07 uCi/g 03/01/21 15:32 Uncertainty +/-3.89E-06 Plutonium-239/240 U 3.67E-06 uCi/g Uncertainty +/-5.49E-06 Plutonium-242 U -2.78E-07 uCi/g Uncertainty +/-4.00E-06 Batch 2095450 QC1204758788 533227001 DUP Plutonium-241 U 0.00123 U -0.00146 uCi/g N/A N/A TC1 03/02/21 13:51 Uncertainty +/-0.00236 +/-0.00195 QC1204758789 LCS Plutonium-241 0.00293 0.00274 uCi/g 93.5 (75%-125%) 03/02/21 14:07 Uncertainty +/-0.000234 QC1204758787 MB Plutonium-241 U -0.000127 uCi/g 03/02/21 13:35 Uncertainty +/-0.000165 Batch 2095452 QC1204758791 533227001 DUP Neptunium-237 U -7.88E-06 U -4.94E-06 uCi/g N/A N/A TC1 03/01/21 16:50 Uncertainty +/-9.91E-06 +/-9.36E-06 QC1204758792 LCS Neptunium-237 0.000412 0.000398 uCi/g 96.7 (75%-125%) 03/01/21 16:50 Uncertainty +/-3.19E-05 Page 34 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 8 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2095452 QC1204758790 MB Neptunium-237 U -1.09E-06 uCi/g TC1 03/01/21 16:50 Uncertainty +/-2.65E-06 Batch 2095454 QC1204758797 533227001 DUP Nickel-63 1.52 1.52 uCi/g 0.271 (0%-20%) TC1 03/02/21 09:57 Uncertainty +/-0.0300 +/-0.0299 QC1204758798 LCS Nickel-63 0.0137 0.0156 uCi/g 114 (75%-125%) 03/02/21 10:03 Uncertainty +/-0.000726 QC1204758796 MB Nickel-63 U -0.000322 uCi/g 03/02/21 09:41 Uncertainty +/-0.000304 Batch 2095455 QC1204758800 533227001 DUP Nickel-59 UI 0.000 UI 0.000 uCi/g N/A N/A TC1 03/01/21 12:08 Uncertainty +/-0.0115 +/-0.00739 QC1204758801 LCS Nickel-59 0.0195 0.0233 uCi/g 119 (75%-125%) 03/01/21 12:10 Uncertainty +/-0.00212 QC1204758799 MB Nickel-59 U 7.18E-05 uCi/g 03/01/21 12:07 Uncertainty +/-0.000472 Batch 2095456 QC1204758803 533227001 DUP Strontium-89 U 0.00618 U 0.00516 uCi/g N/A N/A TC1 02/26/21 16:55 Uncertainty +/-0.00406 +/-0.00440 Strontium-90 U 0.000777 0.000709 uCi/g 9.14 (0% - 100%)

Uncertainty +/-0.000704 +/-0.000423 QC1204758804 LCS Strontium-89 0.0809 0.0705 uCi/g 87.1 (75%-125%) 02/26/21 17:11 Uncertainty +/-0.000692 Strontium-90 0.00204 0.00216 uCi/g 106 (75%-125%)

Uncertainty +/-5.92E-05 Page 35 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 9 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2095456 QC1204758802 MB Strontium-89 U 1.75E-06 uCi/g TC1 02/26/21 16:40 Uncertainty +/-7.58E-05 Strontium-90 U -7.16E-06 uCi/g Uncertainty +/-6.44E-05 Batch 2095982 QC1204759554 LCS Iodine-129 0.000201 0.000223 uCi/g 111 (75%-125%) JXB7 02/26/21 11:37 Uncertainty +/-2.45E-05 QC1204759555 LCSD Iodine-129 0.000201 0.000225 uCi/g 0.891 112 (0%-20%) 02/26/21 14:11 Uncertainty +/-1.96E-05 QC1204759553 MB Iodine-129 U 8.53E-07 uCi/g 02/26/21 11:36 Uncertainty +/-3.55E-06 Batch 2095983 QC1204759557 LCS Tritium 0.00113 0.000984 uCi/g 87 (75%-125%) JXB7 02/26/21 17:05 Uncertainty +/-0.000153 QC1204759558 LCSD Tritium 0.00113 0.00106 uCi/g 7.39 93.7 (0%-20%) 02/26/21 17:22 Uncertainty +/-0.000156 QC1204759556 MB Tritium U 1.22E-05 uCi/g 02/26/21 16:49 Uncertainty +/-8.94E-05 Batch 2095984 QC1204759560 LCS Carbon-14 0.000384 0.000389 uCi/g 101 (75%-125%) TC1 02/26/21 09:01 Uncertainty +/-2.11E-05 QC1204759561 LCSD Carbon-14 0.000384 0.000382 uCi/g 1.98 99.3 (0%-20%) 02/26/21 09:17 Uncertainty +/-2.12E-05 QC1204759559 MB Carbon-14 U -9.50E-06 uCi/g 02/26/21 08:45 Uncertainty +/-9.62E-06 Page 36 of 38 SDG: 533227

Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 10 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time High Rad Testing Batch 2095989 QC1204759566 LCS Technetium-99 0.000531 0.000452 uCi/g 85.1 (75%-125%) TC1 03/02/21 09:38 Uncertainty +/-3.23E-05 QC1204759567 LCSD Technetium-99 0.000531 0.000419 uCi/g 7.52 78.9 (0%-20%) 03/02/21 09:55 Uncertainty +/-3.13E-05 QC1204759565 MB Technetium-99 U 9.04E-06 uCi/g 03/02/21 04:42 Uncertainty +/-1.69E-05 Batch 2098494 QC1204764652 533227001 DUP Iron-55 69.2 64.8 uCi/g 6.44 (0%-20%) TC1 03/03/21 18:45 Uncertainty +/-0.847 +/-0.811 QC1204764653 LCS Iron-55 0.0272 0.0244 uCi/g 89.6 (75%-125%) 03/03/21 19:01 Uncertainty +/-0.00145 QC1204764651 MB Iron-55 U 7.29E-05 uCi/g 03/03/21 18:28 Uncertainty +/-0.000702 Notes:

Counting Uncertainty is calculated at the 95% confidence level (1.96-sigma).

The Qualifiers in this report are defined as follows:

• • Analyte is a Tracer compound

< Result is less than value reported

> Result is greater than value reported BD Results are either below the MDC or tracer recovery is low FA Failed analysis.

H Analytical holding time was exceeded J See case narrative for an explanation J Value is estimated K Analyte present. Reported value may be biased high. Actual value is expected to be lower.

L Analyte present. Reported value may be biased low. Actual value is expected to be higher.

M M if above MDC and less than LLD M REMP Result > MDC/CL and < RDL N/A RPD or %Recovery limits do not apply.

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Exhibit F GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com QC Summary Workorder: 533227 Page 11 of 11 Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time N1 See case narrative ND Analyte concentration is not detected above the detection limit NJ Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Q One or more quality control criteria have not been met. Refer to the applicable narrative or DER.

R Sample results are rejected U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD.

UI Gamma Spectroscopy--Uncertain identification UJ Gamma Spectroscopy--Uncertain identification UL Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias.

X Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Y Other specific qualifiers were required to properly define the results. Consult case narrative.

^ RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry.

h Preparation or preservation holding time was exceeded N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc. by a factor of 4 or more or %RPD not applicable.

^ The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/- the RL is used to evaluate the DUP result.

• Indicates that a Quality Control parameter was not within specifications.

For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations.

Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the QC Summary.

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