ML23137A103
| ML23137A103 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/11/2023 |
| From: | Bates A Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML23137A103 (1) | |
Text
SOUTHERN CALIFORNIA EDI SON An EDISON INTERNATIONAL' Company ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 May 11, 2023
Subject:
Docket Nos. 50-206, 50-361, 50-362 and 72-41 Al Bates Manager, Nuclear Regulatory Affairs & Technical Assistant to theCNO 10 CFR 50, Appx. I 2022 Annual Radiological Environmental Operating Report San Onofre Nuclear Generating Station (SONGS), Units 1, 2 and 3 and Independent Spent Fuel Storage Installation In accordance with the San Onofre Nuclear Generating Station (SONGS) Licensee Controlled Specification 5.7.1.2, Southern California Edison (SCE) is submitting the 2022 Annual Radiological Environmental Operating Report (AREOR) for SONGS Units 1, 2 and 3. The AREOR covers the operation of SONGS during January 1, 2022 through December 31, 2022 and includes summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program (REMP).
In addition, the AREOR includes the results for direct radiation monitoring near the Independent Spent Fuel Storage Installation.
There are no commitments in this letter or the enclosure.
If you have any questions, please contact me at (949) 368-7024.
Sin;f~
tcr A. 8J-e-<;,
Enclosure:
2022 San Onofre Nuclear Generating Station Annual Radiological Environmental Operating Report cc:
R.J. Lewis, Regional Administrator (Acting), NRC Region IV A.M. Snyder, NRC Project Manager, SONGS Units 1, 2 and 3 and ISFSI R. K. Lupo, California Department of Public Health 5000 Pacific Coast Highway San Clemente, CA 92672
ENCLOSURE 2022 San Onofre Nuclear Generating Station Annual Radiological Environmental Operating Report
San Onofre Nuclear Generating Station 2022 Annual Radiological Environmental Operating Report El EUDI SORN License Numbers:
DPR-13, NPF-10, NPF-1 5 An EDISON INTERNATIONAL Company
2022AREOR This 2022 Annual Radiological Environmental Operating Report (AREOR) for the San Onofre Nuclear Generating Station (SONGS) fulfills the requirements of the SONGS Licensee Controlled Specification 5.7.1.2 and the Independent Spent Fuel Storage Installation (ISFSI) facility. The 2022 AREOR covers the results of the environmental monitoring performed around SONGS during the time period January 1, 2022 through December 31, 2022.
Page Ii
2022AREOR Table of Contents 1
Executive Summary................................................................................................................ 1 2
Radiological Environmental Monitoring Program.................................................................... 3 3
Land Use Census Results..................................................................................................... 1 O 4
Quality Assurance................................................................................................................. 11 5
Program Deviations............................................................................................................... 11 6
Conclusion............................................................................................................................ 12 7
References............................................................................................................................ 12 APPENDIX A.
SAMPLE TYPE AND SAMPLING LOCATIONS.............................................. 13 APPENDIX B.
RESULTS AND DISCUSSIONS OF 2022 ENVIRONMENTAL DATA............ 23 APPENDIX C.
SUMMARY
OF QUALITY CONTROL PROGRAMS....................................... 36 APPENDIX D.
COMPARISON OF 2022 REMP DATA TO HISTORICAL DATA....,................ 44 APPENDIX E.
DEVIATIONS FROM ODCM SAMPLING REQUIREMENTS IN 2022............ 54 APPENDIX F.
ERRATA TO PREVIOUS AREORs................................................................. 57 APPENDIX G.
CDPH CO-LOCATED TLDs............................................................................ 58 APPENDIX H.
ISFSI TLD DATA............................................................................................. 59 Glossary...................................................................................................................................... 63 FIGURES Figure 1 - SONGS 45 mile REMP Radius....................................................................... 4 Figure 2 - SONGS Location............................................................................................ 5 Figure 3 - Examples of Exposure Pathways.................................................................. 10 Figure 4 - SONGS REMP One Mile Radius.................................................................. 18 Figure 5 - SONGS REMP Two Mile Radius.................................................................. 19 Figure 6 - SONGS REMP Five Mile Radius.................................................................. 20 Figure 7 - SONGS REMP 30-mile Radius North........................................................... 21 Figure 8 - SONGS REMP 45-mile Radius South.......................................................... 22 Figure 9 - Monthly Average Airborne Particulate Gross Beta (1976 - 2022)................. 47 Figure 10 - SONGS ISFSI and Selected REMP TLD Locations.................................... 62 Page I ii
2022AREOR TABLES Table 1 - Maximum LLDs as Specified in SONGS ODCM.............................................. 9 Table 2 - Direct Radiation Measuring Locations............................................................ 13 Table 3 - Airborne Radioactivity Sampling Locations.................................................... 15 Table 4 - Soil Sampling Locations................................................................................. 15 Table 5 - Ocean Water Radioactivity Sampling Locations............................................. 15 Table 6 - Shoreline Sediment Radioactivity Sampling Locations.................................. 15 Table 7 - Local Crops Sampling Locations.................................................................... 16 Table 8 - Non-Migratory Marine Animal Sampling Locations........................................ 16 Table 9 - Kelp Sampling Locations................................................................................ 16 Table 10 - Ocean Bottom Sediment Sampling Locations.............................................. 16 Table 11 - Sector and Direction Designations............................................................... 17 Table 12 - SONGS REMP TLD Data............................................................................. 26 Table 13 -Weekly Airborne Particulates Gross Beta................................................... 31 Table 14 - Quarterly Composite Airborne Particulate Gamma Activity......................... 31 Table 15 - Monthly Ocean Water Activity...................................................................... 32 Table 16 - Quarterly Ocean Water Tritium.................................................................... 32 Table 17 - Semi-annual Shoreline Sediment Gamma Activity (pCi/g)........................... 33 Table 18 - Semi-annual Ocean Bottom Sediment Gamma Activity (pCi/g)................... 33 Table 19 - Semi-annual Marine Animal Gamma Activity (pCi/g)................................... 34 Table 20 - Semi-annual Local Crops Gamma Activity (pCi/g)....................................... 34 Table 21 -Annual Soil Gamma Activity, 3" Depth (pCi/g).............................................. 35 Table 22 - Semi-Annual Kelp Gamma Activity (pCi/g)................................................... 35 Table 23 - 2022 Quarterly Duplicate TLD Data Comparison......................................... 36 Table 24 - 2022 Annual Duplicate TLD Data Comparison............................................. 37 Table 25 - Non-migratory marine animals analysis results - Potassium-40.................. 39 Table 26 - Non-migratory marine animals analysis results - Cesium-137..................... 40 Table 27 - CDPH and SONGS split sample tritium in ocean water............................... 41 Table 28 - Shoreline Sediment Concentration............................................................... 48 Table 29 - Ocean Bottom Sediment Concentration....................................................... 49 Table 30 - Marine Species Concentration..................................................................... 50 Table 31 - Soil Concentration........................................................................................ 52 Table 32 - Kelp Concentration....................................................................................... 53 Table 33 - 2022 State of California Data from the CDPH TLD program (mR)............... 58 Table 34 - 2022 ISFSI TLD Data................................................................................... 60 Page I iii
Acronyms AREOR ARERR CDPH CEAL DOE EAB EPA ISFSI LCS LLD LUC MDC ND NEI NRC ODCM QA QC REMP TLD Annual Radiological Environmental Operating Report Annual Radioactive Effluent Release Report California Department of Public Health Contracted Environmental Analysis Laboratory Department of Energy Exclusion Area Boundary U.S. Environmental Protection Agency Independent Spent Fuel Storage Installation Licensee Controlled Specifications Lower Limit of Detection Land Use Census Minimum Detectable Concentration Not Detectable Nuclear Energy Institute U.S. Nuclear Regulatory Commission Offsite Dose Calculation Manual Quality Assurance Quality Control Radiological Environmental Monitoring Program Thermoluminescent Dosimeter 2022AREOR Page I iv
2022AREOR 1
Executive Summary On June 12, 2013, Southern California Edison notified the Nuclear Regulatory Commission (NRC) that it had permanently ceased operation for both Units 2 & 3 on June 7, 2013. While all power operations have ceased, spent fuel remains stored on site. San Onofre Nuclear Generating Station (hereafter referred to as San Onofre or SONGS) continues to fulfill its regulatory commitment to monitor the environment and potential exposure pathways. The Radiological Environmental Monitoring Program (REMP) supports the conclusion that San Onofre has had no significant environmental impact and that it is well within applicable state and federal regulations.
The REMP includes the sampling of environmental media and measuring radiation levels in the environment surrounding SONGS. Its purpose is to identify any levels of radioactivity or radiation associated with SONGS that have a potential exposure to a member of the general public. This is accomplished through the measurement of direct radiation and by the sampling and analysis of various environmental media, including:
air particulate direct radiation (TLDs) local crops ocean water non-migratory marine species shoreline sediment (beach sand) ocean bottom sediments Samples are analyzed for both naturally-occurring and SONGS plant-related radionuclides.
A detailed description of the 2022 sample types and locations are included in Appendix A of this report.
The California Department of Public Health (CDPH) Drinking Water and Radiation Laboratory participated in an inter-laboratory split sampling program with SONGS, including ocean water tritium samples and gamma isotopic samples from various environmental media. The results are discussed in Appendix C. The CDPH also conducted a direct radiation (TLD) monitoring program in conjunction with SONGS. Refer to Appendix G.
This report describes the REMP as conducted at SONGS during the period from January 1, 2022 through December 31, 2022. The REMP produces scientifically defensible data indicating SONGS had no significant radiological environmental impact in 2022. This report fulfills applicable license commitments, as described in the Offsite Dose Calculation Manual (ODCM).
Page 11
2022AREOR Beyond the immediate area of the ISFSI, the REMP data collected during 2022 continues to be representative of background levels, as in previous years. The data is summarized in the Statistical Summary of REMP Data found in Appendix B. As in previous years, cesium-137 (Cs-137) was identified in soil and fish. Cs-137 in soil is attributable to fallout from nuclear weapons testing and sources external to SONGS, such as the Chernobyl accident. The Cs-137 in fish is consistent with concentrations detected in other West Coast marine species and may be attributable to the legacy Pacific Ocean discharges from Fukushima. Cs-137 has been detected at both indicator and control locations in past years, consistent with a source that is not related to SONGS. Naturally occurring radionuclides, including beryllium-7 (Be-7), potassium-40 (K-40), thorium-228 (Th-228) and thorium-230 (Th-230) were detected in both control and indicator locations at similar concentrations and are not related to SONGS.
Background radiation includes both natural and manmade contributions. Natural background is comprised of the terrestrial and cosmic radiation sources while manmade background results from past weapons testing fallout and routine medical applications. Prior to the construction of SONGS Units 2 & 3, environmental samples and measurements were collected and analyzed to determine the baseline radiation levels. The results from the indicator stations are compared to this pre-operational data, as well as control samples, to evaluate if changes in any radiation levels can be attributed to SONGS or other causes such as natural variations in the environment or manmade contributions external to SONGS.
In summary, the environmental monitoring data collected during 2022 supports a conclusion of no adverse effect on the population or the environment from SONGS. The radiation exposures to people living in the surrounding area from SONGS remain less than the detection level, and are a small fraction of the radiation exposures in the environment from the natural background from terrestrial and cosmic radiation.
Page 12
2022AREOR 2
Radiological Environmental Monitoring Program Program Overview The purpose of the REMP is to characterize the radiological environment outside of the Site Boundary and to detect potential radiological impacts resulting from activities at SONGS Units 2
& 3. The REMP monitors credible pathways of exposure to the public and fulfills the radiological environmental monitoring requirements of the ODCM.
Exposure pathways are the different routes by which people can potentially be exposed to radiation or radioactive materials. The pathways may be characterized into four general types, shown below along with a brief description of the monitoring as performed at SONGS:
AIRBORNE. The airborne pathway represents the inhalation intake of airborne radioactive materials. This pathway is sampled in areas around SONGS by continuously drawing air through specialized filters 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week. Although both units at SONGS ceased operation in June 201 3, these air samples continue to be collected on a weekly basis.
WATERBORNE. The waterborne pathways include the exposure to radioactive materials accumulated in surface water, ocean bottom sediment, and shoreline sediments. Ocean water is monitored through the collection of monthly samples in the environment around the plant. Sediment samples are collected to evaluate any long-term buildup in the environment.
INGESTION. The ingestion pathways include both terrestrial and marine categories.
The terrestrial ingestion pathway includes broadleaf vegetation, agricultural products, and food products. Atmospheric releases from the plant can deposit on these food products, representing an intake exposure pathway through the consumption of these food products. Semiannual samples of crops (e.g., tomato, lettuce, sorrel) are collected from the local area around the plant to evaluate any impact on the terrestrial ingestion pathway.
The marine ingestion pathway includes marine biota (fish, shellfish). Liquid waste discharges can be incorporated into these biota. Semiannual fish and invertebrate samples are used to evaluate any impact on the marine ingestion pathway.
DIRECT RADIATION. The direct radiation pathway represents external exposure from sources on the plant site and directly from any radioactive effluents released to the air or water. This direct environmental radiation dose is measured through the use of direct measurement dosimeters, such as thermoluminescent dosimeters (TLDs) that are placed around the plant site and in the local environment.
Page 13
2022AREOR Site Area and Description San Onofre Nuclear Generating Station is located next to San Onofre State Beach, adjoining Camp Pendleton Marine Corps Base, in San Diego County, 64 miles south of Los Angeles, California. At this time there are no operating reactors, but in the past, there were three operating pressurized water reactors with a total rated capacity of 2664 net megawatts electrical.
Figure 1 - SONGS 45 mile REMP Radius Unit 1, rated at 410 net megawatts electrical, was supplied by Westinghouse Electric Company.
Unit 1 began commercial operation on January 1, 1968. The unit was permanently shut down on November 30, 1992, and all above-ground structures have been dismantled. By August 31,
2004, all fuel was transferred to the ISFSI. By November 29, 2006, all remaining monitored effluent pathways were permanently removed from service or routed to Unit 2 discharge to the outfall. The remaining portions of Unit 1 are owned by Southern California Edison (80%) and San Diego Gas and Electric (20%).
Unit 2 and Unit 3 were supplied by Combustion Engineering, Inc., with turbine generators supplied by G.E.C. Turbine Generators, Ltd., of England. The units began commercial operation in August 1983, and April 1984, respectively, and were rated at 1127 net megawatts electrical each. The twin units are owned by Southern California Edison (78.21 %), San Diego Gas and Electric (20%), and the City of Riverside (1.79%}.
Page 14
=
7**-- *---* =
~
ThQ!J_sa~,n=d-~~~
e Oalcs-a HH
~
---:i,,--..-.b Illa Molllca Mounlali!*
- 11ion,.i ~lionAtH Malibu Pacific Ocean Sent*Clt--
r.-
Pacific Oce_ n
...... d Figure 2 - SONGS Location 2022AREOR AITowhead @
!Ilg e
San Onofre Nuclear Generating Station Effective December 29, 2006, the City of Anaheim transferred its ownership interests in San Onofre Units 2 & 3 and the entitlement to the Units 2 & 3 output to Southern California Edison Company, except that it retains its ownership interests in its spent nuclear fuel and the ISFSI for Units 2 & 3 located on the facility's site. In addition, the City of Anaheim retains financial responsibility for its spent fuel and for a portion of the Units 2 & 3 decommissioning costs. The City of Anaheim remains a licensee for purposes of its retained interests and liabilities.
Southern California Edison notified the NRG on June 12, 2013, that it had permanently ceased operation of Units 2 & 3 on June 7, 2013. The NRG notification, called a Certification of Permanent Cessation of Power Operations, set the stage for SCE to begin preparations for decommissioning. In a letter to the NRG dated August 7, 2020, SCE certified that all spent fuel had been removed from the Spent Fuel Pools of Units 2 & 3 and on August 10, 2020 SCE had put in place programmatic changes that were previously approved by the NRG for ISFSI-Only operation. SCE continues to monitor environmental conditions in accordance with 10 CFR 50, Appendix I.
Page 15
2022AREOR Sample Collection and Analyses Samples of environmental media were obtained in accordance with the requirements of the ODCM to meet the regulatory requirements. Refer to Appendix A for a complete list of REMP sample locations as described in Table 5-4 of the ODCM.
Indicator samples close to SONGS are compared to control samples located in areas that are beyond the measurable influence of San Onofre. The control sample results are considered representative of background levels with no potential contribution from releases and sources at SONGS. The control stations also serve as indicators of radioactive sources unrelated to activities at SONGS, such as remote sewage plant discharges of nuclear medicine applications or radioactive material attributable to external sources (legacy fallout from nuclear weapons, the nuclear accident at Chernobyl, and the nuclear accident at Fukushima). The indicator location samples are used to detect environmental radioactivity attributable to SONGS. Indicator sample locations can be located either onsite or offsite.
The SONGS REMP is conducted in accordance with a Quality Assurance Program, meeting the requirements of NRC Regulatory Guide 4.15, Rev. 1. Samples are collected using approved methods; radiochemical analyses of these samples are performed using standardized analytical methods. The Contracted Environmental Analysis Laboratory (CEAL) participates in an inter-laboratory comparison program in partial fulfillment of the quality assurance requirements for environmental monitoring. The CEAL participated in cross check programs which meet the intent of Reg. Guide 4.15. See Appendix C for additional details.
Detection Limit Terminology The NRC requires that equipment and analytical methods used for radiological monitoring must be able to detect specified minimum limits for the type sample and the radionuclide of the analysis. The a priori detection capability for the analytical system used for the measurement is referred to as the Lower Limit of Detection (LLD). This LLD ensures that radiation measurements are sufficiently sensitive to detect any levels of concern and small changes in the environment. Samples with no detectable radioactivity are typically referred to as less than the Minimum Detectable Concentration (MDC). The MDC is evaluated for each sample and is used to ensure that the specific analysis has sufficient sensitivity to detect levels consistent with the requirements for analysis by the system LLD. For a more thorough discussion, refer to NUREG/CR-4007.
Lower Limit of Detection (LLD) - The LLD is the a priori (before the fact) lower limit of detection for the method used for the analysis. It is a measure of the detection capability for the analytical method and not for any single sample analysis. This value is calculated for each isotope and every matrix based on typical or expected values of decay time, sample size, counter efficiency, etc. The required LLD values are listed in the ODCM and represent the detection capability that the analytical methods must meet for each of the specified sample media.
Minimum Detectable Concentration (MDC) - The MDC is the a posteriori (after the fact) lower limit of detection based on actual decay time, measured sample size, and counting efficiency for an individual sample analysis. The MDC is compared to the LLD to verify that the measurement met the ODCM requirements for the maximum value of the LLD for the listed radionuclides. Values flagged by the CEAL as being confirmed above the MDC are presumed to be valid detected levels of radioactivity.
Page 16
2022AREOR Not Detected (ND} - The term ND refers to TLD data analyzed per ANSI N13.37-2014 (Environmental Dosimetry-Criteria for System Design and Implementation) that is less than the ANSI calculated detection limit above a specific location's baseline.
A baseline is calculated per ANSI methods for each specific location because the direct radiation signal is a strong function of very local conditions. If the TLD data for a specific location is less than that specific location's baseline plus the ANSI calculated detection limit, then the value is "ND" for that specific measurement.
The sampling and analyses for the REMP are conducted in accordance with the ODCM and the applicable regulatory requirements.
Regulations and Guidance 10 CFR 50. Appendix I 1 O CFR 50, Appendix I establishes the per unit limits on releases of radioactivity to the environment and the resulting dose to the public. These limits are more restrictive than the 1 O CFR 20 limits. The 10 CFR 50, Appendix I limits are:
Source Liquid Effluent Gaseous Effluents - Noble Gases NRC Limits for SONGS Less than or equal to 3 mrem/yr to whole body from all pathways of exposure Less than or equal to 1 O mrem/yr to any organ from all pathways of exposure Less than or equal to 1 O mrad/yr gamma air dose Less than 20 mrad/yr beta air dose Tritium and particulates with half-life greater than 8 days Less than or equal to 15 mrem to any organ for an offsite individual from all pathways of exposure 40 CFR 190 The Environmental Protection Agency (EPA) has established environmental radiation protection standards in 40 CFR 190 for the uranium fuel cycle that includes nuclear power plants. These limits are applicable to the sum of liquid effluent, gaseous effluents and direct radiation.
The dose limits from all applicable pathways to any offsite individual are:
o 25 mrem/year to the whole body o
75 mrem/year to the thyroid o
25 mrem to any other organ As discussed in the 2022 SONGS ARERR, the calculated dose to a member of the public as a result of SONGS is a small fraction of the dose standard established by the EPA. This conclusion is supported by the results of the REMP, as reflected by the absence of measurable levels of radiation or radioactive materials in the offsite environment attributable to SONGS.
Page 17
2022AREOR Other Guidance The following regulatory and industry guidance has been identified as applicable to the SONGS REMP.
US NRC Regulatory Guide 4.1, Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants, 1975 US NRC Regulatory Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, 1976 US NRC Regulatory Guide 1.109, Calculation of Annual Doses to Man from Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, 1977 NUREG-1301, Offsite Dose Calculations Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors, Generic Letter 89-01, Supplement No. 1, 1991 US NRC Regulatory Guide 4.13, Revision 2, June 2019, Environmental Dosimetry Performance Specifications, Testing, and Data Analysis ANSI/HPS N13.37, "Environmental Dosimetry-Criteria for System Design and Implementation", 2014 US NRC Regulatory Guide 4.15, Rev. 1, Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment, 1979 NUREG-1576, Multi-agency Radiological Laboratory Analytical Protocols NUREG/CR-4007, Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements, 1984 NRC Reporting Limits The NRC has established required reporting levels that represent thresholds above which an investigation is needed to evaluate and ensure compliance with radiation safety standards for the public. Licensed nuclear facilities must prepare a special report if any environmental sample value exceeds the corresponding reporting limit. SONGS did not submit any special reports to the NRC in 2022 as no reporting limits were exceeded.
Summary of Analysis of Results and Trends The 2022 SONGS REMP was conducted in accordance with 10 CFR 50, Appendix I, the SONGS LCS and Section 5.0 of the SONGS ODCM. The REMP sample data have been summarized in the format specified in NUREG-1301 (consistent with the format specified in Radiological Assessment Branch Technical Position, Revision 1, November 1979). Data have been evaluated to identify the levels of any plant-related environmental radioactivity above background levels (i.e., plant-related contributions that are distinguishable from background).
For data distinguishable from background, a comparison has been made between current environmental monitoring results and pre-operational or previous operational data as appropriate, for trending environmental radioactivity.
To conform with 10 CFR 50, Appendix I, Section IV 8.2, data on measurable levels of radiation and radioactive materials in the environment are provided to allow for a comparison to the predicted (calculated) values in the environment from radioactive material released in effluents.
Page 18
2022AREOR The tabulated means, ranges, and standard deviations are presented in Appendix B.
Comparisons with background and pre-operational baseline data are presented in Appendix D.
The REMP data are reviewed for accuracy and are compared against NRC reporting levels.
Measurements exceeding the administrative levels (10% of the NRC reporting levels) are flagged. Analyses are performed using instrumentation and methods that provide analytical results with a level of detection as required by the ODCM. The a posteriori MDC is compared to the maximum value for the a priori LLD specified in the ODCM. This ensures that regulatory limits for the maximum LLD are met.
Table 1 - Maximum LLDs as Specified in SONGS ODCM Airborne Marine Local Particulate Animals Crops Water or Gases (pCi/kg, (pCl/kg, Analysis (pCi/L)
(pCi/m3) wet) wet)
I Gross beta i 4
Mn-54 1 15 130 Co-58, 60 I 15 130 I
Zn-65 I 30 260 Cs-134 I 15 SE-02 130 60 I
Cs-1 37 '
18 6E-02 150 80 Sediment (pCi/kg, dry) 150 180 I
l J
]!
The impact of SONGS on the surrounding environment is assessed through a series of analyses. These analyses include: comparisons of indicator to control locations (Appendix B);
comparison of 2022 REMP data to historical environmental data (Appendix D); and the summary of deviations from sampling requirements and corrective actions taken (Appendix E).
A detailed discussion of the 2022 analytical results is presented in this report. Analytical values from offsite indicator sample stations continue to trend with the control stations. The data indicate that SONGS had no significant radiological impact on the environment during 2022.
In addition, dose to members of the public attributable to SONGS-related radiological activities remain well below regulatory limit of 100 mrem per year, as specified in 10 CFR 20.1301 and in keeping with the philosophy of "as low as is reasonably achievable" (ALARA), as specified in 1 O CFR 20.1101(b).
The data are summarized in the Statistical Summary of REMP Data found in Appendix B. The level of Cs-137 found in control and indicator samples is consistent with historical and expected data. The Cs-137 is attributable to fallout from legacy atmospheric nuclear weapons testing, to fallout from Chernobyl, and to the legacy Fukushima discharges into the Pacific Ocean. lodine-131 (1-131) is routinely observed in Kelp samples; this 1-131 is due to medical waste and not related to SONGS. Naturally occurring radionuclides, including beryllium-7 (Be-7), potassium-40 (K-40), thorium-228 (Th-228) and thorium-230 (Th-230) were detected in both control and indicator locations at similar concentrations and are not related to SONGS. Refer to Appendix B for a more detailed discussion.
Page 19
2022AREOR 3
Land Use Census Results Figure 3 - Examples of Exposure Pathways In accordance with the ODCM, each year a Land Use Census (LUC) is performed to identify any changes in the use of areas at and beyond the site boundary. Modifications to the monitoring program may be made if the LUC identifies either new pathways of exposure, or significant changes to the existing pathways around the plant. The 2022 LUC did not identify any new pathways.
Summary of Changes to the LUC:
The 2022 LUC did identify minor changes to the occupancy and location of some existing receptors. The critical receptor and critical locations for each exposure pathway remained the same as those from 2021.
Land Use Changes identified in the 2022 LUC report:
Camp San Onofre Sewage Treatment Plant #11 was found to cross between B and C sectors. This location was previously identified as C sector and had been determined to be out of active use during the 2021 LUC. It was found that the plant remains in active use and locations O-B1 and O-C1 were added to the 2022 LUC to account for occupancy at this location.
The nearest potential locations for harvest of deer were determined to be 0.8 mi in the NNE through E directions {Sectors B-E). The highest exposure for a hunter is conservatively estimated using these locations with 200 hr./year exposure time. The Teen age group was added to dose calculations for hunting based on Camp Pendleton hunting regulations allowing hunters as young as 12 years old.
The maximum occupancy for an adult at Endless Summer Surf Camp was estimated to be 2,880 hours0.0102 days <br />0.244 hours <br />0.00146 weeks <br />3.3484e-4 months <br /> in 2022.
Page 110
2022AREOR 4
Quality Assurance A portion of REMP sampling activity is devoted to quality assurance. All REMP activities, including support contractors, are assessed as defined in Regulatory Guide 4.15, Rev. 1. The quality assurance program's main aspects include process quality control, instrument quality control, comprehensive data reviews, cross-check analyses, and audits. Routine REMP assessments ensure that the program, procedures and personnel are performing satisfactorily.
Samples are collected using approved methods; radiochemical analyses of these samples are performed using standardized analytical methods. Quality audits and independent technical reviews help determine areas that need attention. These areas are addressed in accordance with the station's Corrective Action Program. See Appendix C for detailed QA measurement data.
The CDPH participates in a split sampling program in accordance with the site's REMP procedures. Duplicate radiological split sampling is performed by SONGS to demonstrate repeatability of the sample collection, preparation, and analysis process. Split sample analysis is performed for the evaluation of the precision and bias trends of the method of analysis without the added variables introduced by sampling. The 2022 CDPH data resulted in similar conclusions to the 2022 SONGS REMP data.
GEL Laboratories, LLC (GEL) performs the radiochemistry analysis of samples noted within this report. GEL performs the requested analysis under its Quality Assurance Program, which meets the requirements of 10 CFR 50, Appendix B, ASME NQA-1 and Regulatory Guide 4.15 Revision 1. The measurement capabilities of the radiological laboratory are demonstrated by participating in an inter-laboratory measurement assurance program and performing duplicate and split sample analyses. Approximately 10% of the analyses performed are quality control samples, consisting of inter-laboratory measurement assurance program samples, duplicate samples, and split samples. The inter-laboratory measurement assurance program provides samples that are similar in matrix and size to those sampled and measured by the REMP. This program assures that equipment calibrations and sample preparation methods accurately measure radioactive material in samples.
Stanford Dosimetry performs the environmental TLD analyses noted in this report. Stanford Dosimetry performs the requested analyses under its Quality Assurance Program which meets the requirement of 10 CFR 50, Appendix B, ASME NQA-1, Regulatory Guide 4.15 Revision 1 and Regulatory Guide 4.13 Revision 2 (Environmental Dosimetry - Performance Standards, Testing and Data Analysis).
5 Program Deviations Any deviation in the conduct of the program as required, either in terms of sample collection or analysis, requires an investigation as to the cause and identification of measures to prevent recurrence. Deviations from the sampling program or sensitivity requirements are acknowledged and explained in Appendix E to this report.
Page I 11
2022AREOR 6
Conclusion Radiological environmental data collected throughout 2022 have been evaluated to determine if SONGS had any measurable impact on the surrounding environment.
The Cs-137 detected in soil and fish is due to factors external to SONGS. The Cs-137 in soil is attributable to the legacy fallout from nuclear weapons testing and to the fallout from the Chernobyl accident. The Cs-137 in fish is attributable to the legacy discharges to the Pacific Ocean from Fukushima. The work process at SONGS during 2022 had no significant radiological impact on the environment.
7 References
- 1. SONGS Offsite Dose Calculation Manual (ODCM), Section 5.0.
- 2. SONGS Radiological Monitoring (RM) Procedures established for the Radiological Environmental Monitoring Program.
- 3. NUREG/CR-4007, "Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements," August 1984.
- 4. The Procedures Manual of the Environmental Measurements Laboratory (US DOE HASL-300)
Page 112
APPENDIX A 2022AREOR APPENDIX A.
SAMPLE TYPE AND SAMPLING LOCATIONS Notes used for Table 2 through Table 10:
a Distance (miles) and Direction (sector) are measured relative to Units 2/3 midpoint as described in the ODCM. Direction determined from degrees true north.
b Distances are within the Units 2/3 Exclusion Area Boundary (EAB) c Soil samples are not required by the SONGS ODCM.
d Kelp samples are not required by the SONGS ODCM.
e TLD Location was removed from the ODCM during 2022.
MCB = Marine Corps Base (Camp Pendleton)
Table 2 - Direct Radiation Measuring Locations (based on ODCM Rev 16) 1 City of San Clemente {Former SDG&E Offices) {Control) 5.7 NW 2
Camp San Mateo - {MCB, Camp Pendleton) 3.6 N
3 Camp San Onofre - {MCB, Camp Pendleton) 2.8 NE 4
Camp Homo - (MCB, Camp Pendleton) 4.4 E
6 Old El Camino Real {AKA Old Highway 101) 3.0 ESE 8
Noncommissioned Officers' Beach Club 1.4 NW 10 Bluff 0.7 WNW 11 Former Visitors' Center 0.4b NW 12 South Edge of Switchyard 0.2b E
138 Southeast Site Boundary (Bluff)
Q.4b ESE 15 Southeast Site Boundary (Office Building) 0.1 b SSE 16 East Southeast Site Boundary 0.4b ESE 19 San Clemente Highlands 4.9 NNW 22 Former US Coast Guard Station - San Mateo Point 2.7 WNW 238 SDG&E Service Center Yard {Control) 8.1 NW 31 8 Aurora Park - Mission Viejo {Control) 18.6 NNW 338 Camp Talega - {MCB, Camp Pendleton) (Control) 5.9 N
34 San Onofre School - {MCB, Camp Pendleton) 1.9 NW 35 Range 312 -(MCB, Camp Pendleton) 4.8 NNE 36 Range 208C - (MCB, Camp Pendleton) 4.1 NE 388 San Onofre State Beach Park 3.4 SE 40 SCE Training Center - Mesa 0.7 NNW 41 Old Route 101 - East 0.3b E
44e Fallbrook Fire Station {Control) 17.7 E
Page 113
APPENDIX A 2022AREOR
_<<,*;:if;,
-~.,,.
.'.u..,,: .-.'f,*~,
-.~;{\\1,ffi,flc~"~;;'.J, lit-~
~~-
- I.*<1* J*\\1 C
- "'; >,C' _i DIRECT RADIATION Nl~SURlNG LOCATION miles)
($~clot) 46 San Onofre State Beach Park 1.0 SE 478 Camp Las Flores - (MCB, Camp Pendleton) (Control) 8.6 SE 498 Camp Chappo - MCB (Control) 12.9 ESE 50 Oceanside Fire Station (Control) 15.6 SE 538 San Diego County Operations Center (Control) 44.2 SE 54e Escondido Fire Station (Control) 31.8 ESE 55 San Onofre State Beach (U1 West) 0.2b WNW 56 San Onofre State Beach (U1 West) 0.2b w
57 San Onofre State Beach (Unit 2) 0.1b SW 58 San Onofre State Beach (Unit 3) 0.1b s
598 SONGS Meteorological Tower 0.3b WNW 61 Mesa - East Boundary 0.7 N
62 MCB - Camp Pendleton 0.7 NNE 63 MCB - Camp Pendleton 0.6 NE 64 MCB - Camp Pendleton 0.6 ENE 65 MCB - Camp Pendleton 0.7 E
66 San Onofre State Beach 0.6 ESE 678 Fonner SONGS Evaporation Pond 0.6 NW 68 Range 21 0C - (MCB, Camp Pendleton) 4.4 ENE 73 South Yard Facility 0.4b ESE 748 Oceanside City Hall (Backup Control) 15.6 SE 75 Gate 25 MCB 4.6 SE 76 Fonner El Camino Real Mobil Station 4.6 NW 77e Area 62 Heavy Lift Pad 4.2 N
788 Homo Canyon (AKA Sheep Valley) 4.4 ESE Page 114
APPENDIX A 2022AREOR Table 3 - Airborne Radioactivity Sampling Locations AIRBORNE (AP) S~.UNG LOCAI ION 1
City of San Clemente (City Hall) 5.1 NW 9
State Beach Park 0.6 ESE 10 Bluff 0.7 WNW 12 Former SONGS Evaporation Pond 0.6 NW 13 Marine Corp Base (Camp Pendleton East) 0.7 E
16 San Luis Rey Substation (Control) 16.7 SE Table 4 - Soil Sampling Locations 1
Camp San Onofre 2.8 NE 2
Old Route 101 -(East Southeast) 3.0 ESE 3
Basilone Road / 1-5 Freeway Off ramp 2.0 NW 5
Former Visitors Center NW 7
Prince of Peace Abbey - Oceanside (Control) 15 SE Table 5-Ocean Water Radioactivity Sampling Locations A
Station Discharge Outfall - Unit 1 0.6 SW B
Outfall - Unit 2 1.5 SW C
Outfall - Unit 3 1.2 SSW D
Newport Beach (Control) 30.0 NW Table 6 - Shoreline Sediment Radioactivity Sampling Locations 1
San Onofre State Beach (Southeast) 0.6 SE 2
San Onofre Surfing Beach 0.8 WNW 3
San Onofre State Beach (Southeast) 3.5 SE 4
Newport Beach North End (Control) 29.2 NW Page 115
APPENDIX A Table 7 - Local Crops Sampling Locations LOCAL CROPS SAMPLING LOC~JION 2
Oceanside (Control) 6 SONGS Garden Mesa EOF Table 8 - Non-Migratory Marine Animal Sampling Locations MA~NE ANIUL (MOA) SAMPLING LOCATION A
Unit 1 Outfall B
Units 2/3 Outfall C
Laguna Beach (Control)
Table 9 - Kelp Sampling Locations A
San Onofre Kelp Bed B
San Mateo Kelp Bed C
Barn Kelp Bed E
Salt Creek (Control)
Table 10 - Ocean Bottom Sediment Sampling Locations B
Unit 1 Outfall C
Unit 2 Outfall D
Unit 3 Outfall E
Laguna Beach (Control)
F SONGS Up-coast
.DISTANCE*
(miles) 15 to 25 0.7 0.9 1.5 I 20 to 25 1.5 3.8 6.3 11 to 13 0.8 1.6 1.2 20-25 0.9 2022AREOR DJ~C'{IQ/11 *
(Sector)
SE to ESE NNW WSW SSW WNWtoNW s
WNW SSE to SE WNW to NW SSW SW SSW NW WSW Page 116
APPENDIX A 2022AREOR Table 11 - Sector and Direction Designations Sector Center Sector 22.5° Direction Limit Line Limit Sector 348.75 0 &360 11.25 A
N 11.25 22.5 33.75 B
NNE 33.75 45.0 56.25 C
NE 56.25 67.5 78.75 D
ENE 78.75 90.0 101.25 E
E 101.25 112.0 123.75 F
ESE 123.75 135.0 146.25 G
SE 146.25 157.0 168.75 H
SSE 168.75 180.0 191.25 J
s 191.25 202.5 213.75 K
SSW 213.75 225.0 236.25 L
SW 236.25 247.5 258.75 M
WSW 258.75 270.0 281.25 N
w 281.25 292.5 303.75 p
WNW 303.75 315.0 326.25 Q
NW 326.25 337.5 348.75 R
NNW Page 117
APPENDIX A 0 *,.
()
e
- PACIFIC OCU '
Figure 5-1 San Onofre REMP One-Mile Radius INS2'3a.lpCllll
/Ill Ollp 0llmll Sldl1W!l1 Ol:llilrlwa&
~
SIii lLD lolllflrlllal la:al--
Ramd G2S
=--- !!!!Z:%"¥'t:):1':---'
~.....
r.-._......,.......,_,._.
=====-=---===-------
- ea--....... -................
2022AREOR Figure 4 - SONGS REMP One Mile Radius Page 118
APPENDIX A TLD22 Rgure 5-2 San Onofre REMP
~MileRadus 0
~24.......
~
., c..,.
Kolp Nmll\\,law....... ~tNMMA)
() 0c---*f09S)
~ 0c... w-
-Sad-
~ Sail no 025 I
,......... -~-~
---.......... ~.,
l
..........,._...,.. __.... _ bDillaeMN..,... *
,~............ _,......_. ___ __
~..................._..__...... ~
09C1.
2-rmle ra1fius Sector N w
SectorM WSW inont!bmp
,.,._s_/J1<<1 1lne raltius
..,.,.F Ocon-rS-pH~
OB
--*-JR
/
i!I() OBS Sa,plt 0 OBSS-ltC() ~-rS-p&.B SectorJ s
Figure 5 - SONGS REMP Two Mile Radius Sectof"B NNE SectorH SSE SectorC NE 2022AREOR Page I 19
APPENDIX A Rgure 5-3 San Onofre REMP Ave-Mlle Radius 0 ~=--
C>ap w..
- ~--l'IUIIAJ
() c..---toes,
~ ac--
+ -s-
~
1'U)
. +
0 lillillH
,........ 11 aa,.....,...,_.
.............. ~~.,
n
.,._..._..,...,,._.....,...,,... MMN*N*
IN...
- ca.....__..__....,_....._
Sector N w
SectorM WSW Sector L SW OB~
OcNnW SectorK SSW Figure 6 - SONGS REMP Five Mile Radius 2022AREOR Page 120
APPENDIX A 0 *,,
~
~
+
~
Rgure 5--4 San Onofre REMP 30-Mile North U..21316dpoint lwS.,....
c....,
llall'
-~--(NUMA) 0e-----101S1 OeHII---*
TLD c::J.eount, 8wnda,y 2
0 M
- 2 I
._..,_ =~D~l
!ME tllll/2alD
~--..--_.._,.c.r.. MOl..a*
1111
..............,..._...... QII,........ -----
.....................u...ac....................
IL
- ee..._ *.....,._.._ _ _._...,...,__
2022 AREOR Figure 7 - SONGS REMP 30-mile Radius North Page 121
APPENDIX A Figure 5-5 San Onofre REMP 45-Mile South 0
l.-213lli,lpaalt
- '-S...-
4P c,,,p lfalp -~--
() 01:---t<>HJ
~ OcunWaler
+ --*
Soil n.o c:::J Countr Bow,d:a,,-
0 - -:..
li I
.......... --...... -~......
.._.... ----~
,.a.-..__..~.......... ~--- -
................ ~
.......................U..,.&
...............,........ a.ac-........
t;,K~
Figure 8 - SONGS REMP 45-mile Radius South 2022AREOR Page 122
APPENDIX B APPENDIX B.
Summary RESULTS AND DISCUSSIONS OF 2022 ENVIRONMENTAL DATA 2022AREOR The 2022 REMP analysis results support the conclusion that the measured levels of radioactivity in samples collected are attributable to sources external to SONGS (fallout and liquid discharges to the Pacific Ocean from the nuclear accident at the Fukushima Daiichi Nuclear Power Station, Chernobyl, and residual fallout from legacy atmospheric nuclear weapons testing). Cs-137 has been intermittently detected in the indicator and in the control soil samples in past years and no correlation between Cs-137 level in soil and proximity to the plant has been observed. The Cs-137 detected in both indicator and control samples of non-migratory marine animals is attributable to sources external to SONGS. The direct radiation results (from TLD data) are ND (not detected) outside the immediate area of the ISFSI.
Results and Discussions of 2022 Environmental Data Direct Radiation Direct gamma radiation is monitored in the environment by calcium sulfate (CaSO4) TLDs placed at 34 locations and analyzed quarterly per the methodology described in Regulatory Guide 4.13 revision 2 (based on ANSI/HPS N13.37-2014, "Environmental Dosimetry-Criteria for System Design and Implementation"). During 2022 the ODCM Revision 17 reduced the number of TLD locations to 34, where previously there were 49. The TLDs that were removed were not TLDs that were classified as inner ring or outer ring locations. In most cases, the TLDs were too distant from the site to provide credible monitoring and were not required by ODCM Table 5-1 (TLDs 23, 31, 33, 44, 47, 49, 53, 54, and 74 were in this category and were >5 miles from the site). Some TLDs that were within 5 miles of the site were removed due to redundancy with required TLDs in the same sector and were less desirable than the required locations (TLDs 13, 38, 59, 67, 77, and 78 were in this category). Removal of the TLDs was evaluated as part of the ODCM change and the decrease in the number of locations did not adversely impact monitoring of SONGS direct radiation exposure.
The Annual Public Dose, as referenced in Table 12, is based on the potential exposure for member of the public at the listed locations. For onsite locations, at or near the Site Boundary, the occupancy factor is determined per site procedure for Direct Radiation Exposure Controls and Monitoring.
The 2022 quarterly dose measurements at all TLD locations outside the SONGS EAB were ND (Not Detected). The criteria for establishing a detectable dose, in accordance with Reg. Guide 4.13, is 5 mrem per quarter above the quarterly baseline and 1 O mrem per year above the annual baseline background for that location. Dose measurements less than these values are reported as ND. In accordance with ANSI N13.37, the annual facility-related dose is calculated using the sum of the four quarterly dose measurements and subtracting the annual baseline. If quarterly data is missing, then the average of the available quarters is substituted for the missing data to determine the annual dose. If occupancy adjustment of a facility-related dose results in < 1 mrem then dose to a member of the public is reported as ND, per ANSI/HPS N13.37-2014, Section 7.3.5. Refer to Table 12 for a summary of all 2022 SONGS REMP TLD data.
REMP TLD 55 had a detectable quarterly dose measurement during the last quarter of 2022.
This location (on the beach walkway between the ISFSI and the ocean) is readily accessible to Page 123
APPENDIX B 2022AREOR the general public. REMP TLD 55 data includes the estimated dose due to neutron radiation.
Elevated doses at TLD 55 may be due to both different background dose characteristics and elevated dose rates due to the ISFSI. Environmental dose determined using TLDs is variable, depending on the types of rock and building material near the monitoring location, and a long-term background dose cannot be accurately determined for TLDs along the seawall or ISFSI due to potential dose contributions from the site and ISFSI.
The annual dose measurements at TLDs 55 and 73 were also detectable. The detectable dose measurement at TLD 73 (located within the site boundary) is attributable to the transport, loading and storage of radioactive materials at SONGS.
Separate TLDs were used to compensate for transit dose and a fade TLD was used to evaluate for the time and temperature dependent "fade" that may affect dosimeter data. After the samples were analyzed, the measured doses were corrected for pre and post field-exposure times.
A neutron dosimeter package was co-located with REMP TLD 55 and at selected ISFSI TLD locations around the ISFSI. Any detected neutron dose was added to the gamma dose to report a total dose for each station with a neutron package. The maximum detected neutron dose at a SONGS ISFSI location in any quarter of 2022 was 2.4 mrem.
Direct Radiation baseline evaluation and estimation of natural background An in-depth baseline exposure analysis of the environmental radiation results for the period of 2001 through 2010 was completed for all the REMP TLD monitoring locations. It was determined that if the standard deviation was low and no additional exposure above background was identified at a particular station, the average of that station's radiation exposure results should be equal to natural background (baseline) at that location. The baseline results for REMP TLDs have been summarized with the annual and quarterly values in Table 12.
Natural background radiation is variable and a small change in TLD location or positioning can yield a measurable change in background radiation, depending on concentrations of natural radioactive materials in the area such as rocks and soil or building materials. Therefore, if a TLD is moved, the baseline (background) for that location may be affected. The natural direct gamma radiation varies according to location because of differences in the natural radioactive materials in the soil, soil moisture content, buildings, and other factors.
The baseline environmental exposure analysis included an assessment of the standard deviation of the quarterly results and annual totals at each location. This is an appropriate methodology to determine the ability to detect radiation exposure above background, described in ANSI/HPS N13.37-2014. The 2022 quarterly and annual results expressed in Table 12 are positive exposures if they exceed either 5 mrem above the baseline quarterly or 10 mrem above the baseline annually. If not, the measurement is noted as ND.
In 1980 the Department of Energy (DOE) conducted an Aerial Radiological Survey of SONGS and the surrounding area. The currently used baseline/background value of 15.8 mrem per standard quarter within the SONGS EAB is consistent with the 1980 gamma exposure rates reported by the DOE for the areas immediately north and south of SONGS, taking into account the reduction in environmental radioactivity and background dose rates caused by the decay of atmospheric nuclear weapons testing fallout since 1980.
An empirical determination of the baseline background dose for stations within the EAB is not possible due to the known plant-related radiological activities (e.g., storage and transport of Page 124
APPENDIX B 2022AREOR radioactive materials) that occurred during the baseline calculation study period. The average of nearby proxy locations outside the EAB was used to estimate the baseline within the EAB. A value of 15.8 mrem per quarter was determined as the appropriate baseline for the REMP stations located within the EAB. However, local baseline variations within the EAB are possible because the baseline study period did not predate the introduction of licensed material to the REMP TLD locations within the EAB.
Page 125
APPENDIX B 2022AREOR Table 12-SONGS REMP TLD Data i~ --~~:; _*,; _:. *,..
TLD,_,;:
' Dlnln Qtr.
2022 Quarterly Results Baall~ Adjusted Quarterly Ann.
Annual Annual Annual
. *\\
):-:cs.. BaMOne *
(nnm)..
-Results Basellrl*
Total FacllHy Public*
' ~
~
,_...,:y.,,.
~
~,_.,-,,*,'
.i<f
, (iliNiil)
Dose Dose
(~&IIJ).* :
~--
~ ~if,
~ r
~(~lies)
- (ml'lm) '
1 2
3 4
1 2
s 4
(mreni)
(mrem)
(mrem)
(mrem)
'-'I;,*........
1 City of San Clemente 5.7 18.4 17.1 17.0 17.3 19.7 ND ND ND ND 73.6 71.1 ND ND 2
Camp San Mateo - MCB 3.6 19.6 18.5 18.8 18.9 20.2 ND ND ND ND 78.2 76.4 ND ND 3
Camp San Onofre - MCB 2.8 17.2 15.8 15.8 17.5 18.7 ND ND ND ND 69.0 67.8 ND ND 4
Camp Homo - MCB 4.4 19.0 17.1 16.6 17.6 19.1 ND ND ND ND 76.1 70.4 ND ND 6
Old Route 101 (ESE) 3.0 12.0 10.9 10.5 11.1 12.3 ND ND ND ND 47.9 44.9 ND ND 8
Noncommissioned Officers' 1.4 16.2 15.1 14.8 14.8 15.4 ND ND ND ND 64.8 60.0 ND ND Beach Club 10 Bluff 0.7 17.2 16.8 15.9 15.6 17.9 ND ND ND ND 69.0 66.2 ND ND 11 Former Visitors' Center 0.4*
15.8 15.0 15.2 16.6 16.8 ND ND ND ND 63.1 63.5 ND ND 12 South Edge of Switchyard 0.2*
15.8 16.7 17.2 15.8 16.2 ND ND ND ND 63.1 65.8 ND ND 15° Southeast Sile Boundary 0.1*
15.8 16.9 16.2 17.0 18.3 ND ND ND ND 63.1 68.4 ND ND 16° East Southeast Site Boundary 0.4*
15.8 16.6 15.0 15.5 16.8 ND ND ND ND 63.1 63.8 ND ND 19 San Clemente Highlands 4.9 18.7 18.4 18.6 17.8 19.5 ND ND ND ND 74.8 74.3 ND ND 22 Former US Coast Guard Station 2.7 18.8 18.1 18.0 18.8 19.9 ND ND ND ND 75.3 74.8 ND ND 34 San Onofre School - MCB 1.9 17.0 16.2 16.6 15.8 17.7 ND ND ND ND 68.1 66.3 ND ND 35 Range 312-MCB 4.8 17.8 14.6 14.6 15.6 17.1 ND ND ND ND 71.1 62.0 ND ND 36 Range 208C - MCB 4.1 20.5 18.5 18.7 19.3 20.9 ND ND ND ND 82.0 77.3 ND ND 40 SCE Training Center - Mesa 0.7 18.0 16.8 17.1 17.1 18.9 ND ND ND ND 71,9 69.8 ND ND 41 ° Old Route 101 - East 0.3*
15.8 15.6 15.3 15.6 17.4 ND ND ND ND 63.1 63.9 ND ND 46 b San Onofre State Beach Park 1.0 12.8 12.5 13.2
. b
. b ND ND N/A N/A 51.3 51.3 ND ND 50 Oceanside Fire Station (Control) 15.6 17.4 16.4 16.6 15.8 18.8 ND ND ND ND 69.8 67.5 ND ND 55 a, b, d San Onofre State Beach (U1 0.2*
15.8 18.5 17.9 20.5 22.9 ND ND ND 7.1 63.1 79.8 16.7 ND West}
56
- San Onofre Stale Beach (U1 0.2*
15.8 17.8 17.8 17.5 17.9 ND ND ND ND 63.1 71.0 ND ND West) 57 I,b San Onofre State Beach (Unit 2) 0.1*
15.8 16.5 16.3
.b
-b ND ND N/A NIA 63.1 65.7 ND ND 58 ° San Onofre State Beach (Unit 3) 0.1*
15.8 16.9 16.8 16.8 18.4 ND ND ND ND 63.1 68.9 ND ND 61 Mesa - East Boundary 0.7 16.2 14.7 15.5 14.9 16.7 ND ND ND ND 64.8 61.8 ND ND 62 Camp Pendleton 0.7 13.9 12.5 12.5 12.2 14.1 ND ND ND ND 55.5 51.3 ND ND 63 Camp Pendleton 0.6 14.6 13.2 14.0 13.0 15.0 ND ND ND ND 58.4 55.1 ND ND 64 Camp Pendleton 0.6 15.8 15.3 14.7 14.6 16.9 ND ND ND ND 63.1 61.5 ND ND 65 Camp Pendleton 0.7 14.1 12.7 12.9 12.7 15.1 ND ND ND ND 56.3 53.3 ND ND 66 San Onofre State Beach 0.6 14.7 13.5 13.8 13.7 16.2 ND ND ND ND 58.9 57.2 ND ND Page 126
APPENDIX B 2022AREOR 1,
- 'i Baseline :Adjusted Quarterly Annual 1'1.1)'
Qlr.
2022 ~uarterly Results Ann.
Annual SaNIIIHI ~-
(mtem)
~.......
Banllne Total Facility it~::*~~~-~---' *it;;: t~#1t.
- (~~~
/~~.12
~*
(SCE-1iljj<'.
"'/'t~,;
.. 1'f>: :f.CIIIMl (mMn) :-
~
(mrem)
(mrem)
Dose
- i*'
... 1*.
1, 1
2 3
1 z
a 4
(mrem) 68 Range 210C-MCB 4.4 15.8 15.6 15.4 16.6 17.2 ND ND ND ND 63.1 64.8 ND 73
- South Yard Facility 0.4*
15.8 18.0 18.0 18.2 20.3 ND ND ND ND 63.1 74.6 11.5 75 Gate 25 MCB 4.6 16.7 14.8 16.0 13.9 17.0 ND ND ND ND 66.9 61.7 ND 76 El Camino Real Mobil Station 4.6 18.2 16.9 17.2 16.8 19.3 ND ND ND ND 72.7 70.2 ND 13 1 Southeast Site Boundary {Bluff)
- 0.4*
15.8 16.5 16.6 I
I ND ND NIA NIA 63.1 66.2 ND SDG&E Service Center Yard I
23 1 (Control) 8.1 16.6 15.7 15.1 ND ND N/A NIA 66.4 61.5 ND Aurora Park - Mission Viejo I
I 31 1 (Control) 18.6 19.4 19.1 18.4 ND ND NIA NIA n.8 74.9 ND 33 1 Camp Talega - MCB (Control) 5.9 19.9 18.2 19.8 I
I ND ND NIA NIA 79.5 76.1 ND 38 1 San Onofre State Beach Park 3.4 15.0 9.6 9.7 I
I ND ND NIA NIA 60.1 38.6 ND 44 1 Fallbrook Fire Station (Control) 17.7 14.7 13.9 14.6 I
I ND ND NIA NIA 58.9 57.0 ND Camp Las Flores - MCB I
I 47 1 (Control) 8.6 14.0 15.3 15.7 ND ND NIA NIA 55.9 62.1 ND 49 1 Camp Chappo - MCB {Control) 12.9 14.9 14.6 13.8 I
I ND ND NIA NIA 59.7 56.8 ND San Diego County Operations I
I 53 '
Center (Control) 44.2 19.1 18.9 19.0 ND ND N/A NIA 76.5 75.7 ND 54 '
Escondido Fire Station (Control) 31.8 16.9 17.6 17.5 I
I ND ND NIA NIA 67.7 70.3 ND 59 *.,
SONGS Meteorological Tower 0.3*
15.8 I
I I
I NIA NIA NIA NIA 63.1 0.0 NIA I 67 1 Former SONGS Evaporation 0.6 17.8 16.7 17.1 16.6 18.9 ND ND ND ND 71.1 69.2 ND Pond Oceanside City Hall (Backup I
I 74 1 Control) 15.6 14.0 13.4 13.8 ND ND NIA NIA 55.9 54.3 ND 77 '
Area 62 Heavy Lift Pad 4.2 20.2 18.7 19.0 I
I ND ND NIA NIA 80.7 75.5 ND 78 1 HornoCanyon 4.4 11.7 11.9 12.0 I
I ND ND NIA NIA 46.7 47.8 ND Indicates that the station is within the EAB. The baseline has been estimated to be 15.8 mrem per standard 91-day quarter within the EAB.
a b
C d
e The dose to members of the public is based on a beach annual occupancy time of 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> per year near the SONGS sea wall.
TLD 46 and TLD 57 were discovered missing during both the 3022 and 4022 TLD exchanges. The annual dose was estimated based on the remaining two quarter's data.
This location is not accessible to members of the general public A neutron dosimeter was collocated with REMP TLD 55 and selected ISFSI TLDs. The estimated neutron dose was added to the gamma dose.
Adjusted for occupancy in accordance with Radiation Monitoring and Exposure Controls procedure. Where adjusted dose is < 1 mrem, Public Dose is reported as ND per ANSI/HPS N13.37-2014.
TLDs 13, 23, 31, 33, 38, 44, 47, 49, 53, 54, 59, 74, 77, and 78 were retired following second quarter 2022 based on ODCM Rev 17. TLD 67 was maintained through 2022 due to collocation with the annual QA TLD, though the location has been removed from the SONGS ODCM.
Page 127 Annual PubllC-Dose (mrem)
ND ND ND ND ND ND ND ND ND ND ND ND ND ND N/A 1 ND ND ND ND
APPENDIX B 2022 AREOR Quality Control Duplicate Direct Radiation Samples Duplicate Quality Control (QC) TLDs were installed adjacent to TLD 66 and TLD 67. The duplicate TLDs agreed closely with the indicator TLDs, see Appendix C for results. These TLDs were not required by the ODCM and are not included in the Statistical Summary of REMP Data.
ISFSI Direct Radiation Samples ISFSI TLDs were placed in the vicinity of the ISFSI. Though data from these TLDs are not included in the statistical summary of REMP data because they are not part of the ODCM, the ISFSI data are listed and discussed in Appendix I.
Airborne Particulate and Composite Isotopic Analyses Air particulate samples were collected on a weekly basis from seven locations including four required indicator locations, one optional indicator location, one temporary location and one control location. Temporary air sampler AS-20 was established within the site boundary near TLD 12 due to long-term loss of AS-13 caused by a downed power line; samples were obtained from AS-20 through 12/28/2022 to obtain baseline data and compare 7-and 14-day sample frequency results. The samples were analyzed for gross beta activity and composited quarterly for gamma isotopic analysis. Sample locations were selected according to the requirements of theODCM.
Gross beta analysis is a measure of total radioactivity of beta-emitting radionuclides in a sample. Beta radiation is emitted by many radionuclides and the gross beta measurements are used to identify samples with elevated levels of beta activity that would warrant further analysis.
All of the weekly gross beta activity analysis results were above the MDC. The indicator data trends closely with the control data. Seasonal variability observed in the data is attributable to a factor external to SONGS. The 2022 gross beta data is similar to the gross beta data from recent years.
Gross beta analysis does not identify specific radionuclides. To identify specific radionuclides, the weekly particulate samples are composited quarterly and analyzed for gamma emitters.
During 2022, only naturally-occurring radionuclides were identified and no SONGS-related radionuclides were detected. Beryllium-7 (a naturally occurring radionuclide) was present in all of the quarterly composites.
Ocean Water Monthly ocean water samples were collected from three indicator locations near each station discharge and from the control location at Newport Beach. The samples were analyzed for naturally occurring and SONGS-related gamma-emitting radionuclides, including tritium.
Quarterly composite ocean water samples were analyzed for tritium for the first two quarters of 2022 according to ODCM requirements and were discontinued following publication of ODCM Rev 17. The composite samples were redundant to the tritium analyses that were already being performed on monthly samples.
Throughout 2022, only naturally occurring radionuclides were detected in the monthly gamma spectral analyses of ocean water. Monthly ocean water samples were also analyzed for tritium, consistent with the CDPH split sample program. During 2022, all SONGS REMP and duplicate CPDH tritium ocean water sample results were less than detectable.
The data indicate that SONGS had no measurable impact on the environment as measured in ocean water.
Page 128
APPENDIX B 2022AREOR Shoreline Sediment (Beach Sand)
Beach sand was collected semiannually in 2022 from three indicator locations and from a control location situated in Newport Beach. After collection, the samples were analyzed for plant-related and naturally occurring radionuclides. Only naturally occurring radionuclides were detected in all samples. No plant-related radionuclides were reported above the MDC. SONGS had no impact on the environment as measured in beach sand.
Ocean Bottom Sediments Ocean bottom sediments were collected from four indicator locations and the Laguna Beach control location. The samples were analyzed by gamma spectral analysis for naturally occurring and station-related radionuclides. Only naturally occurring radionuclides were detected in ocean bottom sediment samples collected during 2022. The Ocean Bottom Sediments analyzed in 2022 did not yield any radionuclides attributable to SONGS.
Marine Species (Flesh)
Species of adult fish, crustacean and mollusks were collected on a semi-annual basis at the SONGS Unit 1 outfall, the SONGS Units 2/3 outfall, and from the Laguna Beach control location. The edible portion of each sample type was analyzed for gamma-emitting station-related and naturally-occurring radionuclides. The results were subsequently reported to SONGS in terms of wet sample weights. Because results based on a wet sample weight are most useful for calculating doses, the results of sample analyses are summarized in terms of "as received" wet weights.
Cs-137 was detected in one indicator (fish) samples above the MDC and below the required LLD. The concentration identified is consistent with results from previous years at both control and indicator locations. This is consistent with the conclusion that the Cs-137 is attributable to sources external to SONGS. The Cs-137 result (greater than the MDC but less than the LLD) is consistent with results from marine species samples collected at other West Coast locations.
Publicly available research from scientific organizations indicates that the presence of Cs-137 in Pacific Ocean sea creatures is attributable to the legacy radioactive contamination from global weapons testing, Chernobyl, and Fukushima (Woods Hole Oceanographic Institution website 3-30-2022). Naturally occurring radionuclides, such as K-40, were also detected in marine species samples collected during 2022. Some samples were split with the CDPH; refer to Table 25 and Table 26 for comparison results. SONGS had no measurable impact on the environment as measured by this sample medium.
Local Crops Fleshy and leafy crops were collected semiannually in 2022 from the SONGS garden and from the control location (Bonsall Farms) 21 miles ESE from SONGS Units 2/3 midpoint. Only naturally occurring radionuclides were identified and no plant-related radioactivity was detected in Crop samples during 2022. SONGS had no measurable impact on local crops.
Soil To determine if there is evidence of a build-up of radionuclides in the land near SONGS, indicator soil samples were collected from Camp San Onofre, Old Route 101, Basilone Road and the East Site Boundary (Former Visitors Center). A control sample was obtained from Prince of Peace Abbey in Oceanside. Surface soil was collected from all indicator and control locations at the depth of three inches. The sampling protocol is consistent with the procedure described in HASL-300. Soil sampling is not required by the ODCM.
Page 129
APPENDIX B 2022AREOR Soil samples were analyzed for naturally occurring and SONGS-related gamma-emitting radionuclides using gamma spectral analysis. The 2022 soil samples showed measurable levels of naturally occurring radionuclides and measurable Cs-137, which is consistent with the decay of legacy Cs-137 in soil attributable to factors external to SONGS (e.g., residual nuclear weapons testing fallout and the Chernobyl accident).
Cs-137 and strontium-90 (Sr-90) were detected in soil profile analyses conducted in previous years. These radionuclides are attributable to nuclear weapon testing fallout depositing on soil; Cs-137 and Sr-90 are retained in the soil for extended periods due to their long half-lives and biogeochemical characteristics. The presence of Cs-137 in indicator and in control samples at similar levels supports the conclusion that the source of this radionuclide is due to a factor external to SONGS (fallout deposition). During 2022, SONGS did not have a detectable effect on the environment as measured by soil samples.
Kelp One Kelp sample (from the Control location) was available during the April 2022 sample event.
No Kelp samples were available during the October 2022 sampling event. Kelp sampling is not required by the ODCM.
Cs-137 was not detected in Kelp during 2022. 1-131 was detected at a low level; this is consistent with historical results and is due to medical wastes, not SONGS.
Correlation of Effluent Concentration to Concentrations in the Environment In accordance with 10 CFR 50 Appendix I, Section IV, B.2, data on measurable levels of radiation and radioactive materials in the environment have been evaluated to determine the relationship between quantities of radioactive material released in effluents and resultant radiation doses to individuals from principal pathways of exposure.
REMP samples, both terrestrial and marine, indicated no accumulation of plant-related radioactivity in the environs. Samples with detectable activity were not statistically different from control samples. Non-natural radionuclides detected during 2022 were attributed to sources external to SONGS (past nuclear weapons fallout, Chernobyl, and Fukushima) or due to medical waste (1-131 ). The regulatory requirement to evaluate the relationship between quantities of radioactive materials released in effluents and the resultant radiation doses to individuals may be summarized by the following conclusion:
Effluent program releases are evaluated annually to determine the receptor(s) with the highest hypothetical dose. The 2022 REMP sample data indicated no detectible accumulation of plant-related radionuclides in the environment attributable to SONGS, confirming the adequacy of the in-plant effluent controls program and dose assessments. Furthermore, the SONGS REMP data are consistent with the conclusion that SONGS has had no significant radiological impact on the environment in 2022.
Page j 30
APPENDIX B 2022 AREOR Statistical Summary of REMP Data for 2022 For Table 13 through Table 22 below, the numbers in parentheses next to the mean value indicate the number of samples with positive results compared to the total number of samples. The smaller font numbers in parentheses indicate the range of results.
Table 13-Weekly Airborne Particulates Gross Beta Air Filter Inhalation (pCi/m3)
Gross Beta 333 0.01 0.032 (282/282)
(0.010 - 0.074)
San Luis Rey Substation 16.7 mi. SE 0.036 (51/51)
(0.017-0.085) 0.036 (51/51)
(0.017 - 0.085) 0 NOTES:
a Air Sampler# 13 was unavailable from approximately 3/4/2022 through 3/23/2022 due to damaged power lines. A partial sample from 3/1-3/4/2022 was not included in the analysis summary, above. A temporary monitoring station was established within the site boundary near TLD 12. The temporary station was designated AS-20 and has been included in the sample results summary, above. AS-20 was operated from 3/17/2022 through 12/28/2022 with a total of 30 samples, with some of the time including weekly samples and some including bi-weekly samples.
Table 14 -Quarterly Composite Airborne Particulate Gamma Activity Air Filter Inhalation (pCi/m3)
NOTES:
Cs-134 Cs-137 28 0.05
< MDC (0/24) 28 0.06
< MDC (0/24)
<MDC
< MDC
<MDC
<MDC
< MDC (0/4)
< MDC (0/4)
Non-routine Reported Measurements 0
0 a
Naturally occurring Be-7 was detected in all quarterly composite air particulate samples. Other naturally occurring radionuclides (such as K-40) were observed in some 2022 quarter1y composite air samples.
b The analyses reported in Table 14 include four quarterly results from temporary Air Sampler 20, which was in service from 3/17/2022 through 12/28/2022.
Page I 31
APPENDIX B Table 15 - Monthly Ocean Water Activity H-3 48 500 b
< MDC(0/36)
<MDC
<MDC Mn-54 48 15
< MDC(0/36)
< MDC
<MDC Co-58 48 15
< MDC(0/36)
<MDC
<MDC Ocean Water Co-60 48 15
< MDC(0/36)
<MDC
<MDC (pCi/L)
Zn-65 48 30
< MDC(0/36)
< MDC
<MDC Cs-134 48 15
< MDC(0/36)
<MDC
<MDC Cs-137 48 18
< MDC(0/36)
<MDC
<MDC NOTES:
a Naturally occurring K-40 was observed in all 2022 ocean water samples.
b The maximum LLD for H-3 is 3,000 pCi/I in ODCM Table 5-3. SONGS administratively limits the LLD to 500 pCi/1.
Table 16-Quarterly Ocean Water Tritium
<MDC
<MDC NOTES:
< MDC (0/12)
< MDC(0/12)
< MDC(0/12)
< MDC(0/12)
< MDC(0/12)
< MDC(0/12)
0 0
0 0
0 0
Non-routine Reported Measurements 0
a Quarterly tritium composite requirements were removed from the ODCM in Rev 17. Only two quarterly tritium composites were performed on Ocean Water during 2022. Tritium analyses are included for each monthly sample.
b The maximum LLD for H-3 is 3,000 pCi/1 in ODCM Table 5-3. SONGS administratively limits the LLD to 500 pCi/1.
Page 132
APPENDIX B 2022AREOR Table 17 - Semi-annual Shoreline Sediment Gamma Activity (pCi/g)
Beach Sand Cs-134 8
0.150
< MDC (0/6)
<MDC
<MDC
< MDC (0/2) 0 Direct Exposure (pCi/g)
Cs-137 8
0.180
< MDC (0/6)
<MDC
<MDC
< MDC (0/2) 0 NOTES:
a Naturally occurring K-40 was detected in all 2022 shoreline sediment samples.
Table 18 - Semi-annual Ocean Bottom Sediment Gamma Activity (pCi/g)
Waterborne Cs-134 10 0.150
< MDC (0/8)
< MDC Ocean Bottom
<MDC
< MDC (0/2) 0 Sediment (pCi/g)
Cs-137 10 0.180
< MDC (0/8)
<MDC
< MDC
< MDC (0/2) 0 NOTES:
a Naturally occurring radionuclides (K-40 and others) were detected in the 2022 ocean bottom sediment samples.
Page 133
APPENDIX B 2022 AREOR Table 19 - Semi-annual Marine Animal Gamma Activity (pCi/g) ll!""r.~~~~!'llllr'!~~"":\\"':"-Z,""'."'!"'---:ii:~~~...... '."""!'1';~~~-,:-~~~~""."'.!"~:--'.r-.:-::"'."'"---::----:"-,
Non-routine Reportea Measurements Mn-54 24 0.130
< MDC (0/16)
<MDC
< MDC
< MDC (0/8) 0 Co-58 24 0.130
< MDC (0/16)
<MDC
<MDC
< MDC (0/8) 0 Non-Migratory Co-60 24 0.130
< MDC (0/16)
<MDC
<MDC
< MDC (0/8) 0 Marine Animals Zn-65 24 0.260
< MDC (0/16)
<MDC
<MDC
< MDC (0/8) 0 (pCi/g)
Cs-134 24 0.130
< MDC (0/16)
<MDC
< MDC
< MDC (0/8) 0 Cs-137 24 0.150 0.0104 (1/16)
Unit 1 Outfall 0.0104 (1/8)
<MDC (0/8)
Ob (0.0104- 0.0104) 0.9mi. WSW (0.0104- 0.0104)
NOTES:
a Naturally occurring radionuclides (K-40 and others) were detected in the 2022 non-migratory marine animal samples.
b Cs-137 has been routinely identified in Non-Migratory Marine Animal samples taken for SONGS REMP. The levels of Cs-137 identified have been consistent between Control and Indicator samples and these low levels of activity are expected based on environmental Cs-137 levels attributable to fallout and accidents such as Fukushima Daiichi.
Table 20- Semi-annual Local Crops Gamma Activity (pCi/g)
Range)
Local Crops Cs-134 8
0.06
< MDC (0/4)
<MDC ingestion Cs-137 8
0.08 (pCi/gl __
< MDC (0/4)
<MDC NOTES:
a Naturally occurring radionuclides (K-40 and others) were observed in the 2022 local crop samples.
< MDC
< MDC (0/4)
<MDC
< MDC (0/4)
Non-routine Reported Measurements 0
0 Page 134
APPENDIX B 2022AREOR Table 21 -Annual Soil Gamma Activity, 3" Depth (pCi/g)
Soil Cs-134 5
0.150
< MDC (0/4)
<MDC
<MDC
< MDC (0/1) 0 Direct Exposure 0.0673 (2/4)
Prince of Peace Abby 0.132 (1/1) 0.132 (1/1)
(pCi/g)
Cs-137 b 5
0.180
{Control) 0 (0.0518 - 0.0828) 15 mi. SE (0.132 -0.132)
(0.132-0.132)
NOTES:
a K-40 and other naturally occurring radionuclides were detected in the 2022 REMP soil samples.
b Cs-137 was detected in the Control and in two Indicator samples at similar concentrations {approximately 0.1 pCi/g). This has been observed in previous AREORs and is due to factors external to SONGS {legacy fallout from nuclear weapons testing and Chernobyl) and are not attributable to SONGS.
Table 22 - Semi-Annual Kelp Gamma Activity (pCi/g)
Kelp Ingestion (pCi/g)
NOTES:
1-131 C 1
0.06 a
Kelp sampling is not required by the ODCM.
N/A (0/0)
Salt Creek (CONTROL) 0.0528 (1/1) 11 to 13 mi. WNW - NW (0.0528 - 0.0528) 0.0528 (1/1}
(0.0528 - 0.0528) 0 b
Only one Kelp sample was available during 2022; this sample was from the Control location. K-40 and other naturally occurring radionuclides were detected in the 2022 kelp sample.
c 1-131 was identified in the Control sample during 2022 and was confirmed by re-count. 1-131 has been observed in kelp previously and is not related to SONGS. Other potentially plant-related gamma nuclides were not detected.
Page j 35
APPENDIXC 2022AREOR APPENDIX C.
SUMMARY
OF QUALITY CONTROL PROGRAMS Summary All REMP samples are collected, shipped, and analyzed in accordance with Regulatory Guide 4.15. Marine radiological environmental samples are collected by a vendor, MBC Aquatic Sciences, per the vendor's Quality Assurance manual.
REMP sample analysis is performed by GEL in accordance with GEL's Laboratory Quality Assurance Plan. GEL participates in three independent cross check programs. GEL's QA programs consists of these testing vendors: Eckert & Ziegler Analytics, U.S. DOE MAPEP, ERA's MRaD-Multimedia Radiochemistry Proficiency test program and ERA's lnterLaB RadCheM Proficiency Testing Program.
Non-agreement results were resolved in accordance with GEL's corrective action program.
The CEAL for REMP TLDs was Stanford Dosimetry. The raw data for TLDs was reported as milli-Roentgen/standard quarter and converted to millirem per standard quarter using conversion factors in ANSI N13.37. In 2022, routine quality control (QC) testing was performed for the types of environmental TLDs issued by the Environmental Dosimetry Company (EDC). During 2022, 100% (72n2) of individual dosimeters evaluated against the EDC internal performance acceptance criteria (high-energy photons only) met the criterion for accuracy and 100% (72n2) met the criterion for precision. Independent testing was also performed and 100% (6/6 data sets) passed the performance criteria. One internal assessment was performed during 2022 and there were no findings.
The GEL and Stanford Dosimetry performance meets the criteria described in Reg. Guide 4.15 and ANSI/HPS N13.37-2014.
Quarterly Duplicate TLDs SONGS deployed a duplicate TLD package, TLD 200, in the same canister as TLD 66. The quarterly dose measured by the duplicate TLD package was statistically equivalent.
Table 23 - 2022 Quarterly Duplicate TLD Data Comparison
~~~~~~~~al TLD66 13.52 +/- 0.70 13.78 +/- 0.54 13.74 +/- 0.65 16.21 +/- 1.23 TLD 200 13.60 +/- 0.68 13.81 +/- 0.70 13.99 +/- 0.88 15.10+/-0.82 Page 136
APPENDIX C 2022AREOR Annual Duplicate TLDs SONGS deployed an annual duplicate TLD package, TLD 201, in the same location and canister as REMP TLD 67. The average of the four quarterly TLD 67 exposure results is statistically equal to the annual TLD 201 results for 2022 expressed as mR/91 days.
Table 24-2022 Annual Duplicate TLD Data Comparison TLD 67 17.31 +/- 0.46 TLD 201 17.58+/- 0.42 Calibration of Air Sampler Volume Meters All REMP air sampler flow meters are calibrated annually using standards referenced to National Institute of Standard and Technology.
Calibration of all REMP air samplers is verified quarterly to ensure the flow meters remain within limits. Meters are removed from service if they fail the quarterly test. Additionally, a review of the air particulate beta results over the course of the year did not indicate bias for any particular sampler. The trends in the beta results over the course of the year were consistent, within the limitations of the gross beta method of analysis and natural variation between sample locations.
Page 137
APPENDIXC 2022AREOR lnterlaboratory Cross-Check Program As discussed in the Appendix C Summary section above, the laboratories providing analysis results for SONGS have robust QA programs that include interlaboratory cross-checks. Both labs performed acceptably.
Additionally, the CDPH participates in a comprehensive radiological environmental split sampling program in conjunction with SONGS.
In 2022, the CDPH acquired split samples, collected by an independent third party, from the following SONGS media: non-migratory marine animals, kelp, ocean water gamma emitters, and ocean water tritium. The CDPH also conducts parallel atmospheric radioactivity and terrestrial direct radiation (TLD) measurement efforts at SONGS, {refer to Appendix H for a discussion of the CDPH TLD data).
CDPH Atmospheric Radioactivity Gross Beta and quarterly gamma analysis results were similar to the SONGS results for the same media. As expected, both the CDPH Drinking Water and Radiation Laboratory {DWRL) and the SONGS contracted GEL found a gross beta signal above the detection limit. Both labs detected naturally occurring Be-7 in the quarterly composite gamma particulate media samples. Both labs did not detect anthropogenic radionuclides in the split samples with the exception of non-migratory marine animals and one positive result for 1-131 in kelp identified by the SONGS contracted laboratory.
Since ocean water tritium and non-migratory marine animals have the potential for human consumption, their raw data are tabulated below. Fifteen split sample analyses for marine species were conducted. Analysis methodologies are different in that the SONGS contracted laboratory reported a wet weight result, where the CDPH lab reported a dry weight result. Low level Cs-137 was detected above MDC in some samples. The variability in the detection of positive results is due to the low activity of the samples, the differences in sample processing, the uncertainty of isotope detection and detection limits at low concentrations. {For a discussion on the presence of Cs-137 in fish, refer to Appendix B.)
Page 138
APPENDIX C 2022AREOR Table 25 - Non-migratory marine animals analysis results - Potassium-40 4/6/2022 Crustacean 0.257 Potassium-40 3.19 +/- 0.27 0.07 14.60 +/- 0.79 0.51 Outfall-4/20/2022 Fish 0.224 Potassium-40 4.01 +/- 0.45 0.1 1 19.10 +/- 0.86 0.20 A
Unit 1 10/19/2022 Mollusk 0.264 Potassium-40 2.27 +/- 0.19 0.03 10.30 +/- 0.57 0.44 10/26/2022 Fish 0.232 Potassium-40 3.76+/-0.19 0.04 16.10 +/- 0.82 0.45 4/6/2022 Fish 0.235 Potassium-40 4.23 +/- 0.31 0.07 17.70 +/- 0.90 0.45 4/6/2022 Mollusk 0.246 Potassium-40 2.11 +/- 0.24 0.10 9.10+/-0.56 0.57 B
Outfall-10/19/2022 Fish 0.228 Potassium-40 3.56 +/- 0.27 0.07 16.90 +/- 0.86 0.40 Units 2 & 3 10/19/2022 Crustacean 0.246 Potassium-40 3.26 +/- 0.24 0.05 14.90 +/- 0.78 0.45 10/19/2022 Mollusk 0.264 Potassium-40 2.00 +/- 0.19 0.05 9.92 +/- 0.55 0.41 4/21/2022 Fish 0.253 Potassium-40 3.84 +/- 0.43 0.11 15.80 +/- 0.71 0.39 4/21/2022 Crustacean 0.27 Potassium-40 3.51 +/- 0.43 0.11 14.00 +/- 0.84 0.66 Laguna 4/21/2022 Mollusk 0.208 Potassium-40 2.59 +/- 0.39 0.07 10.30 +/- 1.67 3.16 C
Beach-Control 10/3/2022 Fish 0.251 Potassium-40 3.48 +/- 0.23 0.05 16.30 +/- 0.82 0.40 10/3/2022 Crustacean 0.266 Potassium-40 3.40 +/- 0.19 0.04 14.60 +/- 0.80 0.80 10/3/2022 Mollusk 0.239 Potassium-40 2.02 +/- 0.17 0.04 9.96 +/- 0.59 0.51 Page 139
APPENDIX C 2022 AREOR Table 26 - Non-migratory marine animals analysis results - Cesium-137 A
B C
Outfall-Unit 1 4/6/2022 Crustacean 0.257 Cesium-137 6.55E-3 +/- 6.98E-3 (UI) 5.19E-3 1.47E-2 +/- 7.16E-3 1.78E-2 4/20/2022 Fish 0.224 Cesium-137 4.84E-3 +/- 8.56E-3 1.54E-2 2.85E-2 +/- 6.45E-3 9.45E-3 10/19/2022 Mollusk 0.264 Cesium-137
-3. 7 4E-3 +/- 3.86E-3 5.18E-3 4.45E-3 +/- 5.26E-3 1.25E-2 10/26/2022 Fish 0.232 Cesium-137 1.04E-2+/-4.99E-3 4.27E-3 1.74E-2+/-8.28E-3 1.83E-2 4/6/2022 Fish 0.235 Cesium-137 7.81E-3 +/- 7.51E-3 (UI) 6.33E-3 2.54E-2 +/- 9.72E-3 2.13E-2 4/6/2022 Mollusk 0.246 Cesium-137 2.93E-3+/-5.28E-3 9.16E-3 2.35E-3+/-6.77E-3 1.58E-2 Outfall-Units 2 & 3 1--1_0_11_9_12_0_2_2-+ __
Fi_sh __ 1--_o_.2_2_a_+-_c_e_si_u_m_-1_3_7--+_8._13_E_-_3_+/-_9_.1_8_E-_3...;(_U_l)-+-_7_.o_7_E_-3_-+_2_._04_E_-2_ +/-_a_.o_1 _E-_3_-+-_1_. 7_4_E_-2---1 Laguna Beach -
Control 10/19/2022 Crustacean 0.246 Cesium-137 2.05E-3 +/- 4.49E-3 7.66E-3 8.32E-3 +/- 7.76E-3 1.77E-2 10/19/2022 Mollusk 0.264 Cesium-137
-1.1 1E-3+/-4.07E-3 5.77E-3 2.87E-3+/-4.99E-3 1.17E-2 4/21/2022 Fish 0.253 Cesium-137 2.31E-3 +/- 6.84E-3 1.25E-2 1.50E-2 +/- 7.85E-3 1.75E-2 4/21/2022 Crustacean 0.270 Cesium-137 9.29E-3 +/- 1.70E-2 (UI) 8.61E-3 2.43E-2 +/- 1.05E-2 2.71 E-2 4/21/2022 Mollusk 0.208 Cesium-137
-4.21 E-3 +/- 6. 72E-3 8.96E-3 1.29E-2 +/- 4.36E-2 1.02E-1 10/3/2022 Fish 0.251 Cesium-137 6.12E-3+/-3.97E-3 7.72E-3 1.59E-2+/-8.77E-3 1.97E-2 10/3/2022 Crustacean 0.266 Cesium-137 4.91E-3 +/- 6.39E-3 (UI) 4.54E-3 8.74E-3 +/- 7.69E-3 1.84E-2 10/3/2022 Mollusk 0.239 Cesium-137 3.14E-5+/-2.49E-3 4.21E-3 2.86E-3+/-6.36E-3 1.49E-2 UI - Uncertain identification for gamma spectroscopy result.
Page 140
APPENDIX C 2022 AREOR Table 27 below shows the results from ocean water tritium samples. All the SONGS and the available CDPH results for 2022 tritium in ocean water were less than detectable. The December 2022 CDPH data was not available at the time of reporting.
NOTE: When sample results are analyzed to be lower in activity than the laboratory background result, the result is depicted as a negative value.
Table 27 - CDPH and SONGS split sample tritium in ocean water r-. *, '.;*
- 1 -:~-i)Wrc'!-**,.~"'l, **-;i,tll~;: ir- {\\-Jl~'Jr:n.... ~i:--~~;-Jt~j*W~~JJ 1-.:
, * -~:fl *r:*i._a t.. 1tf*.-;; *.~;l~:~:--~*/<.:.~i..... ~-
--.. ~-~4~1, :ru
.~-:.:~....
(._:.?-
~ _;:.:,
~
,...,,.. :. -
- s~. *..,,. ""',., '""" ~~7r""I"*'".,.,., * ~~,.,. i:,1' '1w1 :'I.,.,,~
, H
,' I 1,1
,0 I a,.*. J 1 *~!.,,
- 11,d~ I
~ I
.. * """!'\\.<-~i"-**-t(-,:.>~
I!'
~,..
- -**.f"*w*** _,_
t"-~
~-- **'1,J(
~~J
- ~ ~
~,, 4:
'~*
.* ~)c,t- ~. ~
\\;
. -~
i,.,*
,:1'
~~,..._t to~-
~'\\;a
~
~I
(,-;r
-~'*" "._~j;,/b.:J.:.,,;,J;Ji::
.J.L
~w.1'.
1/17/2022
-101 +/- 249 428 123 +/- 140 235 2/17/2022
-95.6 +/- 242 417 5.0 +/- 138 238 3/15/2022 5.2 +/- 218 365
-48.8 +/- 137 238 4/18/2022
-12.2 +/- 264 445
-3.9 +/- 135 232 5/16/2022 9.3 +/- 252 423
-84.8 +/- 132 232 Station Discharge 6/16/2022
-1.8 +/- 173 291
-2.0 +/- 145 249 A
Outfall - Unit 1 7/18/2022 17.1 +/- 266 444 2.0 +/- 145 249 8/15/2022
-71.8 +/- 226 386
-9.3 +/- 150 257 9/19/2022 178 +/- 285 467
-61.3 +/- 149 257 10/17/2022
-125 +/- 257 444 26.8 +/- 148 253 11/17/2022 39.0 +/- 204 335
-28.9 +/- 147 253 12/15/2022 135 +/- 239 387 a
a Page 141
APPENDIXC 2022 AREOR 1/17/2022
-173 +/- 248 434 23.5 +/- 137 235 2/17/2022 6.5 +/- 252 423 78.6 +/- 140 238 3/15/2022
-71.6 +/- 207 355 34.8 +/- 139 238 4/18/2022
-142 +/- 259 454 63.6 +/- 136 232 5/16/2022 42.0 +/- 261 436
-48.2 +/- 133 232 6/16/2022
-35.0 +/- 165 291 46.5 +/- 146 249 B
Outfall - Unit 2 7/18/2022
-95.6 +/- 253 436 66.8 +/- 147 249 8/15/2022 10.2 +/- 227 380 5.6 +/- 150 257 9/19/2022 145 +/- 270 443 79.9 +/- 152 257 10/17/2022
-18.1 +/- 269 453
-57.7 +/- 146 253 11/17/2022 15.5 +/- 203 338
-57.7 +/- 146 253 12/15/2022 0.3 +/-218 366 a
a 1/17/2022
-68.6 +/- 253 431 142 +/- 141 235 2/17/2022
-118 +/- 243 422 9.0 +/- 138 238 3/15/2022 27.0 +/- 218 363
-7.0 +/- 138 238 4/18/2022
-72.2 +/- 263 452
-79.0 +/- 132 232 5/16/2022 78.2 +/-265 439
-53.9 +/- 133 232 6/16/2022 64.5 +/- 197 305 64.7 +/- 147 249 C
Outfall - Unit 3 7/18/2022
-22.8 +/- 261 441
-24.2 +/- 149 257 8/15/2022 59.5 +/- 226 374 37.2 +/- 151 257 9/19/2022 179 +/-284 465
-52.0 +/- 149 257 10/17/2022
-99.0 +/- 267 458 43.3 +/- 149 253 11/17/2022 68.4 +/- 213 345
-59.8 +/- 146 253 12/15/2022
-230 +/- 217 389 a
a Page I 42
APPENDIXC 2022AREOR 1/17/2022
-53.4 +/- 256 436
-50.0 +/- 135 235 2/17/2022
-132 +/- 236 411 72.6 +/- 140 238 3/15/2022
-99.9 +/- 201 349
-54.7 +/- 137 238 4/18/2022
-115 +/- 266 462
-11.6+/-134 232 5/16/2022 91.3 +/- 262 434
-42.4 +/- 134 232 6/16/2022 34.0 +/- 183 293 58.7 +/- 146 249 D
Newport Beach (Control) 7/18/2022 103 +/- 272 445 20.2 +/- 145 249 8/15/2022 30.7 +/- 225 375
-74.3 +/- 148 257 9/19/2022 50.9 +/- 265 442
-92.9 +/- 148 257 10/17/2022
-274 +/- 257 461 57.7 +/- 149 253 11/17/2022 69.7 +/-204 330 101 +/- 150 253 12/15/2022
-24.0+/- 213 359 a
a Note that the EPA drinking water maximum permissible tritium activity is 20,000 pCi / liter. Both labs only detected naturally occurring radionuclides in ocean water. No plants related radionuclides were reported above the MDC.
Notes:
(a) The CDPH data for December 2022 was not available at the time of report generation.
Page 143
APPENDIX D APPENDIX D.
COMPARISON OF 2022 REMP DATA TO HISTORICAL DATA 2022 AREOR Comparison of 2022 REMP data to Historical Data and Analysis of Trends Unit 1 achieved criticality on June 14, 1967 and was permanently retired from service on November 30, 1992. Unit 2 attained initial criticality on July 26, 1982 and Unit 3 on August 29, 1983.
A variety of environmental samples were analyzed and the analytical results (January 1, 1979 to July 31, 1982) were compared with the 2022 REMP data obtained for SONGS Units 2/3.
The following media were evaluated and compared with the operational data of SONGS Units 1, 2&3:
External Radiation Air Particulates Ocean Water Shoreline Sediment (Sand)
Ocean Bottom Sediments Marine Species Local Crops Soil Kelp The measurements obtained from the SONGS Unit 1 operational Radiological Environmental Monitoring Program (REMP) during the period from January 1979 to July 1982 are used as the pre-operational baseline for SONGS Units 2/3. This is in accordance with San Onofre Units 2/3, Environmental Report, Operating License Stage, Appendix 6A, Pre-operational Radiological Environmental Monitoring, May 31, 1978. Comparisons of pre-operational data to 2022 REMP data are possible for each of the following exposure pathways: (1) direct radiation, (2) air particulates (inhalation), and (3) ocean water (marine pathway for ingestion). Comparisons can also be made between pre-operational and 2022 REMP data for ocean bottom sediment data to ascertain if there has been any significant increase in radioactivity in ocean bottom sediments near the SONGS Units 2/3 outfalls.
Currently, the pre-operational data are higher than the 2022 REMP data. The decrease in radioactivity is due primarily to the cessation of atmospheric nuclear weapons testing, decreased liquid discharge activity, and the decay of fallout radionuclides. There is a close correlation between indicator and control data over several decades. There are no indications of adverse effects from SONGS on the environment.
Page 144
APPENDIX D 2022AREOR Direct Radiation The direct radiation measurements for the SONGS REMP were made by TLDs on a quarterly collection cycle at 48 locations for 1 Q22 and 2Q22 and 33 locations during 3022 and 4Q22.
(See Appendix I for ISFSI TLD data) The second half of the year included fewer TLDs following ODCM Rev 17 implementation; two of the required TLDs were missing during both 3022 and 4Q22 and one non-required TLD (TLD 67) was maintained throughout 2022. The TLDs were located at inner ring, outer ring, special interest, and control locations as specified by the ODCM. During the pre-operational period from January 1979 to July 31, 1982, the indicator stations ranged from 16.1 to 46.6 mrem per quarter. The preoperational indicator average was 25.3 mrem per quarter. The pre-operational control range was 19.3 to 30.1 mrem per quarter and the control mean was 23.1 mrem per quarter.
During the 2022 REMP year for Units 2/3, the SONGS REMP TLD data was processed in accordance with ANSI/HPS N13.37-2014. Accordingly, the data from individual REMP TLD locations are evaluated against the baseline for each location. The individual REMP TLD locations are not compared with distant control locations for evaluation per the current regulatory guidance, Reg. Guide 4.13 Revision 2, 2019 (Environmental Dosimetry -
Performance Specifications, Testing, and Data Analysis). Refer to Appendix B for a detailed discussion of the REMP TLD data evaluation process.
Factors such as meteorology, local geology, the fallout from atmospheric nuclear weapons testing, and seasonal fluctuations account for the variability in the data as observed during the preoperational period for each location. The decrease in radiation levels at all TLD sample locations is attributable to the curtailment of the atmospheric nuclear weapons testing, and the continued decay of the manmade background from fallout from past nuclear weapons tests.
Simultaneous variation in the radiation levels at both the control and indicator locations shows that the variations are due to factors external to SONGS. Outside the EAB there were no measurable levels of increased direct radiation associated with SONGS as measured by TLDs.
Airborne Particulates From January 1979 through December 1982 (considered to be the pre-operational period for SONGS Units 2/3), there was a noticeably higher gross beta activity in air at all sample locations. This period extends from the fourth quarter of 1980 through the fourth quarter of 1981. These higher activity levels were attributable to the Chinese atmospheric nuclear weapons test conducted on October 15, 1980.
A chart showing the monthly-average gross beta results for SONGS indicator and control locations from January 1976-December 2022 is presented in Figure 9. The chart includes results from current sample locations including the Control sampler at San Luis Rey Substation (SLR), AS-1 (San Clemente), AS-9 (State Beach Park), and AS-10 (Bluff). Additionally, data is presented for former Control locations at Oceanside City Hall (Oside, 1997-2011) and at the Huntington Beach Generating Station (HB, 1976-1997).
Several notable features of the chart support the sensitivity of air monitoring around SONGS and the lack of a detectible impact due to plant activities. Increased monthly average gross beta results can be seen following atmospheric nuclear weapon testing (1970's and 1980s), the Chernobyl accident (1986), and the Fukushima Daiichi accident (2011). Annual variations gross beta are due to seasonal mixing of the upper and lower atmosphere and long-term variations Page I 45
APPENDIX D 2022AREOR related to solar cycles are visible. The trends clearly show that Indicator and Control results are equivalent.
For 2022, the maximum annual average airborne particulate gross beta result was 0.036 pCi/m3 at the San Luis Rey Substation CONTROL location. This result is consistent with recent trends and is consistent with the conclusion that SONGS decommissioning work had no detectible impact on REMP air sample results during 2022.
Page 146
APPENDIX D 0.6 0.5 0.4 0.3 0.2 0.1 0
Falloot from Cllnese Nudea" Weapons Testing, Sept 1977 Falo1Hrom Cllnese Nuclea-Wellll(lllS Tesfng.
Oct 1980 SONGS U2
- Statup, J~1982 2022AREOR
--Average of HB Control
--Average of Oside Control
--Average of SLR Control
~ -
111!1-~- yl _
1
--Average of San Clemente
--Average of State Beach Park Average of Bluff Figure 9 - Monthly Average Airborne Particulate Gross Beta (1976-2022) in units of pCi/m3*
Page 147
APPENDIX D 2022AREOR Ocean Water Monthly ocean water samples were collected near each of the Station discharge outfalls, and from the Newport Beach control location. The ocean water samples are analyzed for naturally occurring and station-related gamma-emitting radionuclides. Samples were composited quarterly and analyzed for tritium.
During the pre-operational period, naturally occurring potassium-40 was detected in each of the samples collected from both indicator and control locations. Other gamma-emitting radionuclides were detected in only one ocean water sample. In May 1980, Co-58, Co-60, Cs-134, and Cs-137 were detected in an ocean water sample collected from the SONGS Unit 1 outfall. Concentrations of the radionuclides in this sample were 11, 6, 380, and 430 pCi/1, respectively. Tritium was also detected in two of the ocean water samples collected in May 1980 from the SONGS Unit 2 outfall and in and from the Newport Beach control location.
No plant-related radionuclides were detected in ocean water during 2022. SONGS had no impact on the environment as measured by this exposure pathway in 2022.
Shoreline Sediments (Sand)
Beach sand is collected semiannually from three indicator locations and from a control location situated at Newport Beach. The samples are analyzed for naturally occurring and plant-related radionuclides.
To assess the impact of SONGS operations on this environmental medium, pre-operational data were compared to the 2022 REMP data (refer to Table 28). The radionuclide detected in shoreline sediment in the preoperational time frame was Cs-137 with a range of 0.012 to 0.022 pCi/g, averaging 0.019 in five sediment samples. One control sample with a Cs-137 activity of 0.032 pCi/g was observed in July 1979. The presence of Cs-137 in both control and indicator locations during the preoperational period leads to the conclusion that the activity is external to SONGS and is most likely attributable to atmospheric nuclear weapons testing. No SONGS-related radionuclides were detected in shoreline sediment during 2022. SONGS had no impact on the environment as measured by this exposure pathway in 2022.
Table 28 - Shoreline Sediment Concentration Cs-137 PreOp 0.012 - 0.022 0.019
< LLD - 0.032
< LLD 2022
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD radionuclides 2022
< LLD
< LLD
< LLD
< LLD NOTES:
a Preoperational period is January 1979 - July 1982.
b LLD for operational data are listed in Appendix B Page I 48
APPENDIX D 2022AREOR Ocean Bottom Sediments In 2022 and during the pre-operational periods, representative samples of ocean bottom sediments were collected semiannually from each of the Station discharge outfalls and from a control station in Laguna Beach. The samples were analyzed for naturally occurring and SONGS-related radionuclides.
Table 29 compares historical information versus 2022 sample results. During the pre-operational period, manganese-54 (Mn-54) was detected in 5 of the 28 samples. Cobalt-58 (Co-58) was detected in nine samples. Cobalt-60 (Co-60) was measured in 15 of the 28 samples. Cs-137 was detected in 16 of the 28 samples. The concentrations of Cs-137 in the samples ranged from 0.014 to 0.090 pCi/g, averaging 0.039 pCi/g. Cerium-144 (Ce-144) was found in two samples.
No SONGS-related radionuclides were detected in ocean bottom sediment samples during 2022. SONGS had no impact on the environment as measured by this exposure pathway in 2022.
Table 29 - Ocean Bottom Sediment Concentration Mn-54 PreOp 0.015 - 0.49 0.129
< LLD
<LLD 2022
< LLD
<LLD
< LLD
<LLD Co-58 PreOp 0.013-1.160 0.199
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Co-60 PreOp 0.014-8.100 0.788
< LLD
< LLD 2022
< LLD
< LLD
< LLD
<LLD Ag-110m PreOp
< LLD- 0.020
< LLD
< LLD
<LLD 2022
< LLD
< LLD
< LLD
<LLD Cs-137 PreOp 0.014 - 0.090 0.039
< LLD
<LLD 2022
< LLD
<LLD
< LLD
< LLD Ce-144 PreOp 0.060 - 0.260 0.160
< LLD
<LLD 2022
<LLD
< LLD
< LLD
<LLD
< LLD
< LLD
< LLD radionuclides 2022
<LLD
< LLD
< LLD
< LLD NOTES:
a Preoperational period is January 1979-July 1982.
b LLD for operational data are listed in Appendix B Page 149
APPENDIX D 2022 AREOR Marine Species (Flesh)
Non-migratory marine species are collected semi-annually near SONGS. Non-migratory marine animals are collected near the SONGS outfalls and from Laguna Beach and analyzed for gamma-emitting radionuclides as specified in the ODCM. The results are subsequently reported as pCi/g, wet weight.
Results for several marine species for both 2022 and for the pre-operational period for Units 2/3 are summarized in Table 30. The marine species used for purposes of comparison include: two species of fish, Bay Mussel (a mollusk), and Spiny Lobster (a crustacean). Radionuclides analyzed, but not included in Table 30, were below the lower limits of detection for both the pre-operational and operational periods.
During 2022, one sample had low level Cs-137 activity> MDC and< LLD, as reported in Table 19. The result is consistent with Pacific Ocean marine organism samples at other locations and consistent with the levels of Cs-137 in marine samples that may be attributable to the ocean water discharges from Fukushima. The data indicate no accumulation trends attributable to SONGS. SONGS had no significant impact on the environment as measured by this exposure pathway in 2022.
Table 30 - Marine Species Concentration Co-58 PreOp 0.016 - 0.030 0.023
< LLD
< LLD 2022 b
<LLD
< LLD
< LLD
< LLD Co-60 PreOp 0.005 - 0.044 0.017
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Ag-11 0m PreOp
< LLD - 0.004
< LLD
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Cs-137 PreOp 0.004 - 0.018 0.007 0.005 - 0.012 0.007 2022
< LLD
< LLD
<LLD
< LLD
< LLD
< LLD
< LLD radionuclides 2022
< LLD
< LLD
< LLD
< LLD Co-58 PreOp 0.009-0.011 0.010
< LLD
< LLD 2022
< LLD
< LLD
< LLD
<LLD Co-60 PreOp 0.004-0.045 0.017
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Ag-1 10m PreOp 0.002-0.009 0.006
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Cs-1 37 PreOp 0.003-0.015 0.008 0.004-0.014 0.009 2022
< LLD
<LLD
< LLD
< LLD
< LLD
< LLD
< LLD radionuclides 2022
< LLD
< LLD
< LLD
< LLD Page I 50
APPENDIX D 2022AREOR Mn-54 PreOp 0.009 - 0.025 0.017
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Co-58 PreOp 0.008 - 0.080 0.028 2022
< LLD
< LLD
< LLD
< LLD Co-60 PreOp 0.005 - 0.400 0.077
< LLD
<LLD 2022
< LLD
< LLD
< LLD
< LLD Cs-137 PreOp 0.003 - 0.006 0.004
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Ru-103 PreOp
< LLD - 0.045
< LLD
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD Radionuclides 2022c
< LLD
< LLD
< LLD
< LLD s
Co-58 PreOp 0.007 - 0.270 0.086
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Co-60 PreOp 0.014 - 0.210 0.060
< LLD
< LLD 2022
< LLD
< LLD
< LLD
< LLD Cs-137 PreOp 0.005 - 0.011 0.008 0.004 - 0.015 0.008 2022
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD radionuclides 2022c
< LLD
< LLD
< LLD
< LLD NOTES:
a Preoperational period is January 1979 - July 1982.
b LLD for the 2022 data are listed in Appendix B C
During 2022, all station-related radionuclides from all sample locations were < LLD d
Samples collected in 2022 include crustacea, mollusks, and two adult species of fish at each location and collection evolution.
Local Crops In the preoperational period of January 1979 through July 1982, Sr-90 was detected in the control samples of kale, parsley, and squash. Naturally occurring K-40 was detected in cucumber, kale, and tomato samples from the indicator and control locations. Ce-144 and Zr-95 were detected in one sample of parsley at the control location at concentrations of 0.12 and 0.09 pCi/g, wet weight respectively.
During 2022, only natural radionuclides were identified in local crops at both the indicator and control locations. SONGS had no impact on the environment as measured by this exposure pathway in 2022.
Page I 51
APPENDIX D 2022AREOR Soil A comparison of operational and preoperational data does not reveal any accumulation pattern of SONGS-related isotopes in soil (refer to Table 31). The intermittent detection of Cs-137 in both indicator and control locations is due to residual fallout from atmospheric nuclear weapons testing. SONGS had no impact on the environment as measured by this exposure pathway in 2022.
Table 31 - Soil Concentration Sr-90 8 PreOp 0.02-0.08 0.044
< LLD-0.03
< LLD 2022 N/A N/A N/A N/A Cs-137 PreOp 0.02-0.20 0.096
< LLD-0.06
< 0.10 2022
<LLD
<LLD
<LLD
<LLD All other SONGS PreOp
< LLD
< LLD
< LLD
< LLD radionuclides 2022
< LLD
< LLD
< LLD
< LLD Notes:
a Sr-90 analyses were not required for soil samples during 2022.
Page I 52
APPENDIX D 2022AREOR Kelp Kelp is normally collected semiannually from three indicator locations and from a control location situated at Salt Creek when kelp canopy is available. Kelp sampling is not required by the ODCM. The samples are analyzed by gamma-spectral analysis for naturally occurring and SONGS-related radionuclides.
To assess the impact of SONGS on kelp, pre-operational data were compared to 2022 REMP data in Table 32. Radionuclides detected during the pre-operational period for SONGS included Mn-54, Co-60, Zr-95, 1-131, and Cs-137.
Although 1-131 activity has been detected in kelp since 1977, there is no evidence that the concentrations of 1-131 are a result of operations at SONGS. The presence of 1-131 in kelp is due to the sewer release of medical administrations of radioisotopes, since it has been detected consistently in control as well as indicator locations. Since 1988, the concentration of 1-131,
when detected, has typically been highest at the control locations. There is correlation between indicator and control sample locations over an extended period of time.
During 2022, kelp was collected at the Control location in April. The kelp canopy was missing from all other locations in 2022. Cs-137 was not detected in 2022, but has been observed previously. 1-131 was detected in the Control kelp sample during 2022 (See Table 22 for Kelp sample results).
Table 32 - Kelp Concentration Mn-54 PreOp
< LLD - 0.005
< LLD
< LLD
< LLD
< LLD Co-60 PreOp 0.006 - 0.009 0.008
< LLD
< LLD
< LLD Zr(Nb)-95 PreOp 0.014 - 0.090 0.046 0.018 - 0.053 0.036 2022 NIA
< LLD
< LLD
< LLD 1-131 PreOp 0.006 - 0.024 0.013 0.008 - 0.030 0.014 2022 NIA NIA 0.053 - 0.053 0.053 Cs-137 PreOp 0.004 - 0.071 0.027
< LLD
< LLD
< LLD
< LLD
< LLD
< LLD radionuclides 2022 NIA NIA
< LLD
< LLD Notes:
a No Indicator Kelp samples were available during 2022 sample events.
Page I 53
APPENDIX E APPENDIX E.
DEVIATIONS FROM ODCM SAMPLING REQUIREMENTS IN 2022 DEVIATIONS FROM ODCM SAMPLING REQUIREMENTS 2022AREOR Deviations from the ODCM sampling requirements are identified below in accordance with section 5.0 of the ODCM. During 2022, the ODCM specified a priori LLD was achieved for all REMP samples. Deviations from the ODCM were associated with external factors not within the control of REMP personnel such as limited availability of marine samples at the locations specified in the ODCM, external power outages, and other unavoidable deviations. The 2022 ODCM deviations had no meaningful impact on the REMP data and do not compromise the validity of the reported conclusions.
Direct Radiation Thermoluminescent Dosimeters (TLDs)
- 1) TLDs 55 and 56 were found to be missing on 7/6/2022 (2022 sample period). These TLDs from along the State Beach walking path along the SONGS seawall, along with three non-required TLDs in the vicinity, were found to be missing on 7/5/2022. TLD 55 was found by a member of the public on 6/19/2022 and was returned to SOS on 7/6/2022. TLD 56 was found by SOS Security and was returned on 7/5/2022. The cause of the TLDs being removed from the monitoring locations is not known, but appears to be due to vandalism. The containers were held to metal poles with metal straps and the straps appeared to have been pried off of the pole. A different metal strap design was pursued that is more resistant to removal. The results from 2022 for TLDs 55 and 56 trend well with other data and have been reported in Table 12 and Table 34.
- 2) TLD 46 was missing during 3022 and 4022 sample events. Following the 3022 sample event, the missing TLD was replaced and the container seemed to be intact. When the TLD was found missing again in 4022, the container was found to have had the bottom pried loose so that it could be removed and replaced. The container was replaced with a container that was in good condition and a sign was added to dissuade vandalism.
- 3) TLD 57 was missing during 3022 and 4022 sample events. There was no sign of the container or metal straps during the 3022 sample event and it is presumed that the container had been pried off of the pole, as happened to other TLDs during 2022.
During the 4022 sampling event, one strap remained on the pole while the other strap and the sample container were both missing. The container was replaced with extra straps added. A sign was also added to this TLD and others along the walkway to dissuade vandalism.
Page I 54
APPENDIX E 2022AREOR Air Sampling At SONGS, the ODCM requires a total of four Indicator stations and one Control station.
Downtime for each air sampler in 2022 was due to weekly sample collection, quarterly rotameter flow comparison checks, scheduled air sampler motor assembly / rotameter change-outs, and preventative air sampler motor assembly change-outs which was conducted if a motor assembly was observed to show signs of degraded performance (excessive bearing noise, vane erosion, flow decline, etc.).
Downtime events exceeding one hour for each ODCM-required air sample are addressed below:
- 1) All required Air Samples (AS-1, AS-9, AS-12, AS-13, AS-16) were not collected on 1/11/2022. The samples were left running for approximately 14 days, rather than the ODCM-required 7-day sample frequency. The samples could not be collected due to personnel availability. An additional worker became qualified during Spring 2022 to help ensure that samples could be collected at the specified frequency.
- 2) Air Sample 13 (AS-13) was found without power on 3/8/2022 due to power line failure on Camp Pendleton property. The partial sample from 3/8/22 was analyzed and results were not consistent with other samples from the week, therefore, the sample was removed from the database. AS-13 remained out of service until 3/23/2022 when power was restored following repair of the downed line and the pump was restarted. Three weeks of sample coverage were missed due to this unpreventable failure.
- 3) Air Sampler 16 (AS-16) timer indicated the following downtimes:
- a. Approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> during 4/26/2022 sample event.
- b. Approximately 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during the 8/2/2022 sample event.
- c. Approximately 4.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the 9/20/2022 sample event.
This air sample location is adjacent to the San Luis Rey substation in Oceanside, CA.
The sampler was operating correctly at the time of sample collection in each case. The loss of sample observed on 4/26/2022 was confirmed to be associated with a loss of power to the area on 4/20/2022. A cause could not be determined for the other two instances of missing sample time; however, temporary loss of source power is the most likely cause. These losses of sample time were not preventable.
Ocean Water Sampling No deviations were observed.
Shoreline Sediments No deviations were observed.
Ocean Bottom Sediments No deviations were observed.
Marine Species (Flesh)
No deviations were observed.
Local Crops No deviations were observed.
Page 155
APPENDIX E 2022AREOR Soil No deviations were observed.
Kelp Kelp samples are not required by Section 5.1 of the ODCM. Normally, four kelp beds are collected twice a year for a total of eight kelp samples. Only the control sample was available during April 2022 and no samples were available during October 2022. The Kelp canopy was absent at the remaining locations during the sample events. Kelp sampling is not required and this did not constitute a deviation from the ODCM.
Page I 56
APPENDIX F 2022AREOR APPENDIX F.
ERRATA TO PREVIOUS AREORs The 2021 AREOR indicated on page 10 that:
The Camp San Onofre wastewater treatment plant (LUC # 0-10) was not operational for all of 2021. This facility has been placed in long term standby and is no longer an employment location. It is being retained in the data pending possible future use.
The location was reported as being 'placed in long term standby' in the 2021 Land Use Census based on the best available information from the Camp Pendleton Community Plans and Liaison Office. During the 2022 Land Use Census, SONGS was informed that the Camp San Onofre wastewater treatment plant remained in service during 2021. The LUC data received from the relevant authority is assumed to be accurate and the error was not due to SONGS. The 2021 AREOR should have the referenced bullet associated with LUC # 0-10 removed for accuracy and continuity; however, the location is not a potential critical receptor and the error does not affect the accuracy of the reported data in the SONGS ARE OR or ARERR.
Page I 57
APPENDIXG 2022AREOR APPENDIX G.
CDPH CO-LOCATED TLDs DATA FROM THE CDPH TLDs CO-LOCATED WITH SONGS REMP TLDs DURING 2022 CDPH maintains a TLD program in the environs of SONGS. Per CDPH request, the 2022 exposure results from the CDPH dosimeters are reported in Table 33, below. The Location Numbers refer to the current SONGS DecommissioningSo/utions (SOS) alphanumeric location identifier and the current CDPH location number.
Table 33 - 2022 State of California Data from the CDPH TLD program (mR/Qtr.)
Location Numbers Location Name 1st 2nd 3rd 4th Qtr.
Qtr.
Qtr.
Qtr.
SDS-1, CDPH #2 City of San Clemente 22 21 26 24 SDS-22, CDPH #4 Former US Coast Guard Station -
23 22 25 23 San Mateo Point SDS-34, CDPH #5 San Onofre Elementary School 19 19 24 25 SDS-10, CDPH #6 Bluff (Adjacent to PIC #1) (San 21 19 26 23 Onofre Surfing Beach)
SDS-16, CDPH #7 East Southeast Site Boundary 19 18 20 21 SDS-2, CDPH #8 Camp San Mateo 24 23 29 25 SDS-3, CDPH #9 Camp San Onofre 21 22 25 23 SDS-6, CDPH #10 Old El Camino Real (Old Highway 17 17 18 18 101) (ESE)
SDS-50, CDPH #13 Oceanside Fire Station 21 19 24 23 The CDPH TLD program does not conform to the same environmental dosimeter standard Reg.
Guide 4.13 (ANSI N13.37-2014) used to generate direct radiation data for the SONGS REMP TLD program. The CDPH reports results in different units of measurement and is therefore not technically equivalent to the SONGS TLD data set. The different methodologies and the different units of measurement make it unsuitable to directly compare individual REMP data to the corresponding individual CDPH TLD data. However, the CDPH results are consistent with the conclusion that beyond the Site Boundary there is no detectable direct radiation that is attributable to SONGS.
Page 158
APPENDIX H 2022AREOR APPENDIX H.
ISFSI TLD DATA Summary Per 10 CFR 72.126, SONGS implemented an area monitoring TLD program in the vicinity of the ISFSI.
An evaluation of the entire REMP TLD database yielded an estimated background exposure rate of approximately 15.8 mrem/std. quarter (91 days). However, some local variability within the SONGS EAB is known to exist and cannot be precisely known at every location within SONGS. This value would need to have been measured before SONGS was constructed and TLD technology did not exist at that time. Therefore, a comparison of pre-operational data to the 2022 data needs to be considered in conjunction with a comparison of ISFSI TLD data and the estimated baseline background exposure rate within the EAB.
Environmental exposure rates are variable and small changes in TLD location can measurably change the data. SONGS REMP TLD data show an environmental seasonal variability that is not related to any activities at SONGS. The ISFSI TLD data gathered to date follow a similar seasonal variability.
The measured exposure rates for the ISFSI TLDs close to the ISFSI are consistent with the exposure rates expected from known radiological work activities and storage of spent fuel and radioactive material in the ISFSI.
Publicly accessible REMP TLDs include SCE-55, SCE-56 and SCE-57. In 2022, ISFSI TLDs SCE-55 (San Onofre State Beach, U1 West) recorded measurable annual facility doses for 4022 and annual evaluation periods. The occupancy-adjusted doses to a member of the general public are less than one (1) mrem per year and are reported as ND per ANSI/HPS N13.37-2014. This result was reported in the 2022 Annual Radioactive Effluent Release Report.
The 2022 neutron TLDs identified low levels of neutron radiation from the ISFSI. Neutron TLDs were added to several locations around the ISFSI prior to the off load of spent fuel from Units 2
& 3 to obtain neutron dose information. Currently, neutron dosimeters are collocated with ISFSI TLDs 311, 326, 339-344, and REMP TLD 55.
As discussed in Appendix E, REMP TLDs 55 and 56 were found to be missing at the end of 2022; ISFSl-07 (for monitoring neutron dose) was also found to be missing with collocated TLD
- 55. The missing dosimeters were returned to SOS and were analyzed with the other TLDs; results were consistent with other quarters and were included in Table 12 and Table 34.
Additionally, TLD 57 was missing during 3022 and 4022 and was not recovered.
A dose equivalent conversion factor for the TLD neutron signal based on a similar ISFSI facility at another site was adopted to estimate the neutron dose rate at SONGS. This conversion factor is being applied to the SONGS TLD results to provide an estimate of the neutron dose equivalent being measured. The neutron dose has been included in the quarterly results for these locations in Table 34. The results from all locations at the fence around the ISFSI pad show that the dose to a member of the public, when adjusted for occupancy, would be less than one (1) mrem per year.
Page 159
APPENDIX H 2022AREOR Table 34 - 2022 ISFSI TLD Data
/r I......
i '
Ff*
- ,J
.-;/*~:
--?/-'~.....
301 302 303 304 307 308 309 310 311 312 314 315 316 317 318 319 320 321 326 339 340 341 342 343 344
~f~Y:~ :*T ~~:::-/. i'!-~L-.;. *- *:.,, *,-
~ -,-_--;;:~,;;:-*.:~* ~:;*: -::. * - ~:-.*
- -: :**-. -.., ** /';.. 1~
.. ~~~~1tr..., _...
~..,ti!
- t.. 1-*...,i-
- .* :;.,.... ~*
~
~ 7tlf.,
~:i (,{:*,o~-
--dtti' ~81111~. =r :r ~-*IJn*'~t1j~~Q~~i11y R~~~1.i,-. '.' Anffila.,'~* >. ~. AIJnilal
~:p"'*
'~.
' 4t,'
\\t.
~
-~-
~,-~
'f,
., -,. -';If
., Faclllty
~
- °"C\\
,*-r..i,,
- :e-
,,~.~,~.... : *:'
- *)>
C
- -;~
\\*
'.}nose*, * {'* *..
- ,~Di-~:~.
~ ** -:.,t'*,._I' i'"'
.:;.:;., :~.*- ~-: '\\ -~,
,-~~ **, **
.. *,* *. l)oa9 r,,,.... ~_.,~--~;,._"'1, *.:
,........ *-~~****".*'-':""':**_: *...
~-.-
- f,:*
(mrem)* '*:*;t*.. )
,,, ~** -_-'1'~**. :~~.}~,h,* * ;.~ -1...:-*
.~
- .-!'. mrem
,,t.*,,,,,:,°'-,,--~,.. --
.,*'f,~
- f ***~*.,,._,
~-
1 2
- -* * *. _ _,_c
- _, '-- ~-
~ ~ -~
~
_,"'t "
4 15.8 I 17.8 I 18.1 I 17.8 I 19.9 I ND I
ND I
ND I
ND I
73.6 I
10.5 15.8 21.3 I 21.7 I 21.2 I 24.1 5.6 5.9 5.4 8.4 88.4 25.3 15.8 21.3 I 21.0 I 20.4 I 23.7 5.5 5.3 ND 7.9 86.4 23.3 15.8 20.0 I 19.7 I 19.2 I 22.4 ND ND ND 6.6 81.3 18.3 15.8 18.7 I 19.4 I 18.4 I 20.6 ND ND ND ND 77.0 13.9 15.8 17.5 I 18.3 I 17.7 I 20.0 ND ND ND ND 73.5 10.5 15.8 18.3 I 19.6 I 18.6 I 20.2 ND ND ND ND 76.8 13.7 15.8 19.7 I 20.8 I 19.4 I 21.9 ND ND ND 6.1 81.8 18.7 ISFSl-01" 15.8 18.8 I 19.4 I 18.2 I 22.5 ND ND ND 6.7 78.9 15.9 15.8 14.7 I 15.7 I 14.2 I 17.1 ND ND ND ND 61.7 ND 15.8 18.8 I 20.4 I 18.7 I 21.7 ND ND ND 5.9 79.6 16.6 15.8 18.2 I 18.9 I 17.9 I 20.0 ND ND ND ND 75.1 12.0 15.8 16.1 I 16.1 I 16.3 I 19.0 ND ND ND ND 67.4 ND 15.8 15.3 I 16.7 I 16.4 I 18.3 ND ND ND ND 66.7 ND 15.8 17.6 I 19.4 I 18.2 I 21.2 ND ND ND 5.4 76.4 13.3 15.8 18.8 I 20.4 I 18.8 I 21.5 ND ND ND 5.8 79.6 16.5 15.8 18.7 I 20.1 I 18.5 I 20.9 ND ND ND 5.1 78.1 15.0 15.8 18.2 I 18.6 I 18.4 I 21.3 ND ND ND 5.6 76.6 13.5 ISFSI-02c 15.8 21.4 I 21.7 I 19.7 I 22.8 5.6 5.9 ND 7.1 85.6 22.5 ISFSI-08C 15.8 22.9 I 23.9 I 22.3 I 25.5 7.2 8.1 6.6 9.7 94.7 31.6 ISFSI-09C 15.8 21.2 I 21.9 I 19.1 I 23.3 5.4 6.2 ND 7.5 85.5 22.4 ISFSI-1oc 15.8 22.6 I 22.4 I 22.3 I 24.5 6.8 6.6 6.5 8.7 91.7 28.7 ISFSl-11e 15.8 24.8 I 24.7 I 24.1 I 27.4 9.0 8.9 8.3 11.6 100.9 37.9 ISFSl-12c 15.8 20.3 I 21.0 I 20.5 I 24.6 ND 5.2 ND 8.8 86.3 23.3 15.8 18.7 I 19.7 I 19.2 I 21.6 ND ND ND 5.8 79.2 16.1 I
- Annual Public Doseb (mrem)
Page 160
APPENDIX H 2022AREOR San Onofre State 55 d, e Beach (U 1 West) 15.8 18.5 17.9 20.5 22.9 ND ND ND 7.1 79.8 16.7 ISFSI-07C 56 d San Onofre State 15.8 17.8 17.8 17.5 17.9 ND ND ND ND 71.0 ND Beach U 1 West 57 d San Onofre State 15.8 16.5 16.3 ND ND N/A N/A 65.7 ND Beach Unit 2 Notes:
a ISFSI TLDs (SCE-301 through SCE-344} are placed around the ISFSI pad, and not in locations accessible to the general public.
b Public dose is not applicable for those TLDs that are not accessible to the general public.
ND ND ND c
Station has a collocated neutron dosimeter package. The neutron dose is estimated using a neutron signal conversion factor measured at a similar ISFSI installation.
d These TLDs are publicly accessible. The public dose is based on an estimated occupancy of 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> per year.
e For TLD 55, the estimated neutron dose contributed to the total measured dose in 2022.
f For locations with a collocated neutron dosimetry package the estimated neutron dose (if any} is included in the reported dose.
Page 161
APPENDIX H ISFSI Tl.Os and selected REMP Tl.Os near the ISFSI Fol.l'ldation
+
- w.
s
,oo 0
2022 AREOR Figure 10 - SONGS ISFSI and Selected REMP TLD Locations Page 162
Glossary Glossary a posteriori a priori ALARA Cosmogenic nuclides After the fact Before the fact 2022AREOR As Low As is Reasonably Achievable means making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.
Radionuclides (or isotopes) created when a hrgh-energy cosmic ray interacts with the nucleus of an atom. These isotopes are produced within Earth materials such as rocks or soil, in Earth's atmosphere, and in extraterrestrial items such as meteorites. Radioactive isotopes beryllium-7 and beryllium-10 fall into this series of three light elements (lithium, beryllium, boron) formed mostly by cosmic ray spallation nucleosynthesis, both of these nuclides have half-lives too short for them to have been formed before the formation of the Solar System, and thus they cannot be primordial nuclides. Since the cosmic ray spallation route is the only possible source of beryllium-7 and beryllium-10 occurrence naturally in the environment, they are therefore cosmogenic.
Below is a list of radioisotopes formed by the action of cosmic rays in the atmosphere; the list also contains the production mode of the isotope.
Isotope Mode of formation Isotope Mode of formation 3H 14N (n, 12c)3H 32p Spallation (Ar)
(tritium) 7Be Spallation (N and 0) 34mc1 Spallation (Ar) 10Be Spallation (N and 0) 3ss Spallation (Ar) 11c Spallation (N and 0) 3sc1 35CI (n, y)36CI 14c 14N (n, p) 14c 37Ar 37CI (p, n}37 Ar 1aF 180 (p, n)18F and 3BCI Spallation (Ar)
Spallation (Ar) 22Na Spallation (Ar) 39Ar 3BAr (n, y)39Ar 24Na Spallation (Ar) 39Ct 40Ar (n, np)39CI &
spallation (Ar) 2sMg Spallation (Ar) 41Ar 40Ar (n, y)41Ar 31Si Spallation (Ar) a1Kr 8°Kr (n, y) 81Kr 32Si Spallation (Ar)
Page 163
Glossary Decay Series Distinguishable from background Dose Exclusion Area Boundary (EAB)
Half-life Gamma Spectroscopy Gross Beta Liquid Scintillation millirem (mrem) 2022AREOR There are three naturally occurring decay series of heavy elements that transform into a series of various radioactive elements by releasing energy in the form of particles, (such as alpha or beta), and/or gamma rays to end in a stable form of non-radioactive Lead. All three decay series start with extremely long lived radioactive, heavy elements that can be measured in geologic time units. They are Uranium-238 with an approximate half-life of 4.5 billion years, Uranium-235 with a half-life of about 700 million years, and Thorium-232 with a half-life of 14 billion years. All three series contain some more well-known radioactive species, Radium and Radon.
Detectable concentration of a radionuclide that is statistically different from the background concentration of that radionuclide at that location.
The amount of radiation that is absorbed by a person's body. In the radiation field the term dose is sometimes used interchangeably with dose equivalent.
The boundary used for routine effluent calculations required by 10 CFR 20 at San Onofre Units 2 & 3; formed by two semi-circles with radii of 1967.5 ft. from the containment centers with a tangent connecting the landward and the seaward arcs.
A measure of how fast half the mass of a radioactive element will transform itself into another element. Each radioactive element has its own unique rate of transformation. Consequently, if a radioactive element, such as lodine-131 has a half-life of 8 days, then in 8 days half of the original amount of lodine-131 will be gone; in another 8 days half of that half will be left and so on.
A scientific method used to analyze gamma rays emanating from radioactive elements. The analytical system determines the gamma ray energy which acts as a "fingerprint" for specific radioactive materials.
For example, Potassium-40 (K-40) has a very, distinctive gamma energy at 1460 keV. This uniqueness allows the instrument to positively identify the K-40 1460 keV energy as its own unique fingerprint. A keV is an abbreviation for kilo electron volt, which is a measure of energy at the atomic level. A kilo is a scientific prefix for the multiplier 1,000.
A screening technique employed to measure the total number of beta particles emanating from a radioactive sample, without isotopic identification. At SONGS samples with an elevated gross beta are analyzed by gamma spectroscopy to identify the specific radionuclides causing the elevated gross beta signal. A beta particle is a negatively charged particle a mass equal to that of an orbiting electron.
The analytical technique by which tritium activity is measured in water.
A sample is placed in a glass vial containing scintillation cocktail. The mixture is sealed and homogenized. When the tritium decays it emits a very low energy beta particle. The beta interacts with the scintillating medium and produces a light pulse that is counted by the instrument.
One thousandth (1/1000) of a rem.
Page 164
Glossary mllliRoentgen (mR) pCi/kg pCi/1 Rem Roentgen Skyshine Thermolumines-cent Dosimeters (TLD)
Tritium (Hydrogen-3 or H-3) 2022AREOR One thousandth (1/1000) of a Roentgen An acronym for a pico-curie per kilogram, which is a concentration unit that defines how much radioactivity is present in a unit mass, such as a kilogram. A "pico" is a scientific prefix for an exponential term that is equivalent to one trillionth (1/1,000,000,000,000).
An acronym for a pico-curie per liter, which is a concentration unit that defines how much radioactivity is present in a unit volume, such as a liter.
An acronym for roentgen equivalent man. It is a conventional unit of dose equivalent that is based on how much of the radiation energy is absorbed by the body multiplied by a quality factor, which is a measure of the relative hazard of energy transfer by different particles, (alpha, beta, neutrons, protons, etc.), gamma rays or x-rays. In comparison the average natural background radiation dose equivalent to the United States population is estimated to be 292 millirems per year, or 0.8 millirem per day, with 68% of that dose coming from radon. A millirem is one thousandth, (1/1000), of a rem.
A special unit of exposure named after the discoverer of X-Rays, Wilhelm Roentgen. It is a measure of how much ionization is produced in the air when it is bombarded with X-Rays or Gamma Rays. Ionization is described as the removal of an orbital electron from an atom.
Radiation from a radioactive source that bounces off air molecules in the sky, much like a cue ball does off the banking of a billiard table, and is scattered/redirected back down to the earth.
Very small plastic-like phosphors or crystals that are placed in a small plastic cage and mounted on trees, posts, etc. to absorb any radiation that impinges on the material. Special readers are then used to heat the plastic to release the energy that was stored when the radiation was absorbed by the plastic. The energy released is in the form of light and that light is counted by the TLD reader. The intensity of the light emitted from the crystals is directly proportional to the amount of radiation that the TLD phosphor was exposed to.
H-3 is the naturally occurring radioactive form of Hydrogen. All radioactive elements are represented as a combination of their chemical symbol and their mass number. Therefore, Tritium, which is a heavy form of the Hydrogen molecule with one proton and two neutrons in the nucleus of its atom, is abbreviated and represented by its chemical symbol, H-3, for Hydrogen and 3 for the number of particles in its nucleus, or mass number. Similarly, other radioactive elements, such as Potassium-40, can be represented and abbreviated as K-40, and so on.
Page I 65