0CAN052201, Annual Radiological Environmental Operating Report for 2021

Annual Radiological Environmental Operating Report for 2021

ML22130A789
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/10/2022
From:	Keele R Entergy Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
0CAN052201
Download: ML22130A789 (68)

Text

Entergy Operations, Inc. 1448 S.R 333 Russellville, AR 72802 0CAN052201 10 CFR 50, Appendix I May 10, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Annual Radiological Environmental Operating Report for 2021 Arkansas Nuclear One - Units 1 and 2 NRC Docket Nos. 50-313, 50-368, and 72-13 Renewed Facility Operating License Nos. DPR-51 and NPF-6

Reference:

Entergy Operations, Inc. (Entergy) letter to NRC, Annual Radioactive Effluent Release Report for 2021, Arkansas Nuclear One, Units 1 and 2 (0CAN042202), (ML22104A104), dated April 14, 2022 In accordance with Arkansas Nuclear One (ANO), Unit 1 Technical Specification (TS) 5.6.2 and Unit 2 TS 6.6.2, the submittal of an annual radiological environmental operating report for the previous year is required by May 15 of each year. The subject ANO report for the calendar year 2021 is enclosed. This report fulfills the reporting requirements of the referenced TSs.

The radionuclides detected by the radiological environmental monitoring program during 2021 were significantly below the regulatory limits. The operation of the ANO station during 2021 had no harmful radiological effects nor resulted in any irreversible damage to the local environment.

No environmental samples from the monitoring program equaled or exceeded the reporting levels for radioactivity concentration due to ANO effluents when averaged over any calendar quarter. A map of sampling locations and a corresponding table providing the respective distances and directions from the reactor containment building is included in the Offsite Dose Calculation Manual submitted as part of the referenced Annual Radioactive Effluent Release Report.

This letter contains no new regulatory commitments.

Riley D. Keele, Jr.

Manager, Regulatory Assurance Arkansas Nuclear One Tel 479-858-7826

0CAN052201 Page 2 of 2 Should you have any questions or require additional information, please contact Riley Keele, Manager, Regulatory Assurance, at (479) 858-7826.

Respectfully, ORIGINAL SIGNED BY RILEY D. KEELE, JR.

Riley Keele RDK/rwc

Enclosure:

Annual Radiological Environmental Operating Report for 2021 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official

ENCLOSURE 0CAN052201 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2021

Plant: Arkansas Nuclear One Page 1 of 65 Year: 2021 Document Number: 0CAN052201 Annual Radiological Environmental Operating Report

Plant: Arkansas Nuclear One Year: 2021 Page 2 of 65 Annual Radiological Environmental Operating Report TABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

.............................................................................................................. 3

2.0 INTRODUCTION

.......................................................................................................................... 5 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS...................... 6 4.0 INTERPRETATION AND TRENDS OF RESULTS..................................................................... 17 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

.......................... 24 ATTACHMENTS - Sample Deviations......................................................................................................... 29 - Monitoring Results Tables.............................................................................................. 30 - Interlaboratory Comparison Program Results................................................................ 45 - ERRATA......................................................................................................................... 61

Plant: Arkansas Nuclear One Year: 2021 Page 3 of 65 Annual Radiological Environmental Operating Report 1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report presents data obtained through analyses of environmental samples collected for the Arkansas Nuclear One (ANO) Radiological Environmental Monitoring Program (REMP) for the period January 1 through December 31, 2021. This report fulfills the requirements of Arkansas Nuclear One Unit 1 Technical Specification (TS) 5.6.2 and Unit 2 TS 6.6.2.

All required lower limit of detection (LLD) capabilities were achieved in all sample analyses during 2021, as required by the ANOs Offsite Dose Calculation Manual (ODCM). No measurable levels of radiation above baseline levels attributable to ANO operation were detected in the vicinity of ANO. The 2021 REMP thus substantiated the adequacy of source control and effluent monitoring at ANO with no observed impact of plant operations on the environment.

ANO established the REMP prior to the stations becoming operational (1974) to provide data on background radiation and radioactivity normally present in the area.

ANO has continued to monitor the environment by sampling air, water, sediment, fish, and food products, as well as measuring direct radiation. ANO also samples milk if milk-producing animals used for human consumption are present within five miles (8 km) of the plant.

The REMP includes sampling indicator and control locations within an approximate 20-mile radius of the plant. The REMP utilizes indicator locations near the site to show any increases or buildup of radioactivity that might occur due to station operation and control locations farther away from the site to indicate the presence of only naturally occurring radioactivity. ANO personnel compare indicator results with control and preoperational results to assess any impact ANO operation might have had on the surrounding environment.

In 2021, environmental samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. It was concluded that no significant relationship exists between ANO operation and effect on the area around the plant. The review of 2021 data showed radioactivity levels in the environment were undetectable in many locations and near background levels in significant pathways.

1.2 Reporting Levels No samples equaled or exceeded reporting levels.

Plant: Arkansas Nuclear One Year: 2021 Page 4 of 65 Annual Radiological Environmental Operating Report 1.3 Comparison to State and/or Federal Program ANO personnel compared REMP data to state monitoring programs as results became available. Historically, the programs used for comparison have included the U.S. Nuclear Regulatory Commission (NRC) Thermoluminescent Dosimeter (TLD)

Direct Radiation Monitoring Network and the Arkansas Department of Health.

The NRC TLD Network Program was discontinued in 1998. Historically, these results have compared to those from the ANO REMP. ANO TLD results continue to remain consistent with the historical average and continue to verify that plant operation is not affecting the ambient radiation levels in the environment.

The Arkansas Department of Health and the ANO REMP entail similar radiological environmental monitoring program requirements. These programs include collecting air samples and splitting or sharing sample media such as water, sediment, and fish.

Both programs have obtained similar results over previous years.

1.4 Sample Deviations During 2021, environmental sampling was performed for eight (8) media types addressed in the ODCM and for direct radiation. A total of 289 samples of the 292 scheduled were obtained. Of the scheduled samples, 99% were collected and analyzed in accordance with the requirements specified in the ODCM., Sample Deviations contains the listing of sample deviations and actions taken.

1.5 Program Modifications No changes were made to ANO REMP Procedure EN-CY-130-01 in 2021.

No changes were made to ANO ODCM in 2021.

Plant: Arkansas Nuclear One Year: 2021 Page 5 of 65 Annual Radiological Environmental Operating Report

2.0 INTRODUCTION

2.1 Radiological Environmental Monitoring Program ANO established the REMP to ensure that plant operating controls properly function to minimize any associated radiation endangerment to human health or the environment. The REMP is designed for:

Analyzing applicable pathways for anticipated types and quantities of radionuclides released into the environment.

Considering the possibility of a buildup of long-lived radionuclides in the environment and identifying physical and biological accumulations that may contribute to human exposures.

Considering the potential radiation exposure to plant and animal life in the environment surrounding ANO.

Correlating levels of radiation and radioactivity in the environment with radioactive releases from station operation.

2.2 Pathways Monitored The airborne, direct radiation, waterborne and ingestion pathways are monitored as required by the ANO ODCM. A description of the REMP utilized to monitor the exposure pathways is described in the attached Tables and Figures.

Section 4.0 of this report provides a discussion of 2021 sampling results with Section 5.0 providing a summary of results for the monitored exposure pathways.

2.3 Land Use Census ANO conducts a land use census biennially, as required by Section B 2.5.2 of the ODCM. The purpose of this census is to identify changes in uses of land within five miles of ANO that would require modifications to the REMP and the ODCM. The most important criteria during this census are to determine the location of the nearest milk animal, the nearest residence, and the nearest garden of greater than 500 ft2 producing fresh leafy vegetables in each of the 16 meteorological sectors within a 5-mile distance from one reactor (containment).

Plant: Arkansas Nuclear One Year: 2021 Page 6 of 65 Annual Radiological Environmental Operating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway - Airborne Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses RADIOIODINE AND PARTICULATES 3 samples close to the Site Boundary, in (or near) different sectors with the highest calculated annual average ground level D/Q.

Station 2 (243° - 0.5 miles) -

South of the sewage treatment plant.

Station 56 (264° - 0.4 miles) -

West end of the sewage treatment plant.

Station 1 (88° - 0.5 miles) - Near the meteorology tower.

Continuous sampler operation with sample collection every two weeks, or more frequently if required by dust loading.

Radioiodine Canisters - I-131 analysis every two weeks.

Air Particulate - Gross beta radioactivity analysis following filter change.

RADIOIODINE AND PARTICULATES 1 sample from the vicinity of a community having the highest calculated annual average ground level D/Q.

Station 6 (111° - 6.8 miles) -

Local Entergy office, 305 South Knoxville Avenue, Russellville.

Continuous sampler operation with sample collection every two weeks, or more frequently if required by dust loading.

Radioiodine Canisters - I-131 analysis every two weeks.

Air Particulate - Gross beta radioactivity analysis following filter change.

RADIOIODINE AND PARTICULATES 1 sample from a control location. For example, 15 - 30 km distance and in the least prevalent wind direction.

Station 7 (210° - 19.0 miles) -

Entergy Supply Yard on Highway 10 in Danville. (Control)

Continuous sampler operation with sample collection every two weeks, or more frequently if required by dust loading.

Radioiodine Canisters - I-131 analysis every two weeks.

Air Particulate - Gross beta radioactivity analysis following filter change.

Plant: Arkansas Nuclear One Year: 2021 Page 7 of 65 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses TLDs 16 inner ring stations with two or more dosimeters in each meteorological sector in the general area of the site boundary.

Station 1 (88° - 0.5 miles) - On a pole near the meteorology tower.

Station 2 (243° - 0.5 miles) - South of the sewage treatment plant.

Station 3 (5 - 0.7 miles) - West of ANO Gate #2 on State Highway 333 (approximately 0.35 miles).

Station 4 (181° - 0.5 miles) - West of May Cemetery entrance on south side of the road.

Station 56 (264° - 0.4 miles) - West end of the sewage treatment plant.

Station 108 (306° - 0.9 miles) - South on Flatwood Road on a utility pole.

Station 109 (291° - 0.6 miles) - Utility pole across from the junction of Flatwood Road and Round Mountain Road.

Station 110 (138° - 0.8 miles) -

Bunker Hill Lane on the first utility pole on the left.

Station 145 (28° - 0.6 miles) - Near west entrance to the Reeves E. Richie Training Center (RERTC) on a utility pole.

Once per 92 days.

mR exposure quarterly.

Plant: Arkansas Nuclear One Year: 2021 Page 8 of 65 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses TLDs 16 inner ring stations with two or more dosimeters in each meteorological sector in the general area of the site boundary.

Station 146 (45° - 0.6 miles) - South end of east parking lot at RERTC on a utility pole.

Station 147 (61° - 0.6 miles) - West side of Bunker Hill Road, approximately 100 yards from intersection with State Highway 333.

Station 148 (122° - 0.6 miles) -

Intersection of Bunker Hill Road with Scott Lane on county road signpost.

Station 149 (156° - 0.5 miles) - On a utility pole on the south side of May Road.

Station 150 (205° - 0.6 miles) - North side of May Road on a utility pole past the McCurley Place turn.

Station 151 (225° - 0.4 miles) - West side of sewage treatment plant near the lake on a metal post.

Station 152 (338° - 0.8 miles) - South side of State Highway 333 on a road signpost.

Once per 92 days.

mR exposure quarterly.

Plant: Arkansas Nuclear One Year: 2021 Page 9 of 65 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses TLDs 8 stations with two or more dosimeters in special interest areas such as population centers, nearby residences, schools, and in 1 -

2 areas to serve as control locations.

Station 6 (111° - 6.8 miles) - Local Entergy office, 305 South Knoxville Avenue, Russellville.

Station 7 (210° - 19.0 miles) -

Entergy Supply Yard on Highway 10 in Danville.

Station 111 (120° - 2.0 miles) -

Marina Road on a utility pole on the left just prior to curve.

Station 116 (318° - 1.8 miles) - State Highway 333 and State Highway 64 in London on a utility pole north of the railroad tracks.

Station 125 (46° - 8.7 miles) - College Street on a utility pole at the southeast corner of the red brick school building.

Station 127 (100° - 5.2 miles) -

Arkansas Tech Campus on a utility pole across from Paine Hall.

Station 137 (151° - 8.2 miles) -

Junction State Highway 7 and State Highway 28. TLD is on a utility pole on the left in front of the Moore R.

Morris Arkansas National Guard Armory.

Station 153 (304° - 9.2 miles) -

Knoxville Elementary School near the school entrance gate on a utility pole.

Once per 92 days.

mR exposure quarterly.

Plant: Arkansas Nuclear One Year: 2021 Page 10 of 65 Annual Radiological Environmental Operating Report Table 3, Exposure Pathway - Waterborne Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses SURFACE WATER 1 indicator location (influenced by plant discharge).

1 control location (uninfluenced by plant discharge).

Station 8 (166° - 0.2 miles) - Plant discharge canal.

Station 10 (95° - 0.5 miles) - Plant intake canal.

Grab samples every 92 days.

Gamma isotopic analysis and tritium analysis quarterly.

Drinking Water 1 indicator location (influenced by plant discharge).

1 control location (uninfluenced by plant discharge).

Station 14 (70° - 5.1 miles) -

Russellville city water system from the Illinois Bayou.

Station 57 (208° - 19.5 miles) -

Danville public water supply treatment on Fifth Street.

Once per 92 days.

I-131, gross beta, gamma isotopic and tritium analyses once per 92 days.

Plant: Arkansas Nuclear One Year: 2021 Page 11 of 65 Annual Radiological Environmental Operating Report Table 3, Exposure Pathway - Waterborne Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses GROUNDWATER 1 control location up gradient from the Protected Area.

2 sample locations of Groundwater from indicator locations down gradient from the protected area.

Station 58 (GWM-1, 22° - 0.3 miles) -

North of Protected Area in Owner Control Area (OCA). West of Security North Check Point, east side of access road.

Station 62 (GWM-101, 34° - 0.5 miles) - North of Protected Area in OCA. East of outside receiving building.

Station 63 (GWM-103, 206° - 0.1 miles) - South of Protected area in OCA. North-east of Stator Rewind Building near wood line.

Station 64 (GWM-13, 112° - 0.1 miles) - South of Oily Water Separator facility, northwest corner of ANO-2 Intake Structure. Inside Protected area.

Grab samples every 92 days.

Gamma isotopic, gross beta, and tritium analysis quarterly.

SEDIMENT FROM SHORELINE 1 indicator location (influenced by plant discharge).

1 control location (uninfluenced by plant discharge).

Station 8 (243° - 0.9 miles) - Plant discharge canal.

Station 16 (287° - 5.5 miles) - Panther Bay on south side of Arkansas River across from mouth of Piney Creek.

Once per 365 days.

Gamma isotopic analysis annually.

Plant: Arkansas Nuclear One Year: 2021 Page 12 of 65 Annual Radiological Environmental Operating Report Table 4, Exposure Pathway - Ingestion Requirement Sample Point Description Distance and Direction Sampling and Collection Frequency Type and Frequency Of Analyses MILK If commercially available, 1 sample from milking animals within 5 miles distant where doses are calculated to be greater than 1 mrem per year.

1 sample from milking animals at a control location 15 - 30 km distant when an indicator location exists.

Currently, no available milking animals within 5 miles of ANO.

Gamma isotopic and I-131 analyses once per 92 days.

Gamma isotopic and I-131 analyses once per 92 days.

FISH AND INVERTEBRATES 1 sample of a commercially and/or recreationally important species in vicinity of plant discharge area.

1 sample of similar species in area not influenced by plant discharge.

Station 8 (212° - 0.5 miles) - Plant discharge canal.

Station 16 (287° - 5.5 miles) - Panther Bay on south side of Arkansas River across from mouth of Piney Creek.

Once per 365 days.

Gamma isotopic analysis on edible portions annually.

FOOD PRODUCTS 1 sample of one type of broadleaf vegetation grown near the SITE BOUNDARY location of highest predicted annual average ground level D/Q if milk sampling is not performed.

1 sample of similar broadleaf vegetation grown 15 - 30 km distant, if milk sampling is not performed.

Station 13 (273° - 0.5 miles) - West from ANO toward Gate 4 onto Flatwood Road.

Station 55 (217° - 13.1 miles) - Ozark National Forest north of Danville.

Three per 365 days.

Gamma. isotopic and I-131 analyses three times per 365 days.

Plant: Arkansas Nuclear One Year: 2021 Page 13 of 65 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway

Plant: Arkansas Nuclear One Year: 2021 Page 14 of 65 Annual Radiological Environmental Operating Report Figure 2, Sample Collection Sites -Near Field Lake Dardanelle Arkansas Nuclear One REMP Sample Locations (Near Field)

Revised 24May05 West Access Rd.

Cemetery May Rd.

Bunker Hill Rd.

Bunker Hill Ln.

Scott Ln.

Training Center SR 333 150 4

149 8S 110 148 8C 36 56 2

13 109 10 1

147 146 145 108 152 3

151

Plant: Arkansas Nuclear One Year: 2021 Page 15 of 65 Annual Radiological Environmental Operating Report Figure 3, Sample Collection Sites - Far Field

Plant: Arkansas Nuclear One Year: 2021 Page 16 of 65 Annual Radiological Environmental Operating Report Figure 4, Sample Collection Sites Lake Dardanelle Switch Yard 58 63 STR-3 STR-2 STR-4 STR-1 STR-5 West Access Road Arkansas Nuclear One REMP Sample Locations Site Map N

S E

W STR-6 62 64

Plant: Arkansas Nuclear One Year: 2021 Page 17 of 65 Annual Radiological Environmental Operating Report 4.0 INTERPRETATION AND TRENDS OF RESULTS 4.1 Air Particulate and Radioiodine Sample Results - Example The REMP has detected radioactivity in the airborne pathway attributable to other sources. These include the 25th Chinese nuclear test explosion in 1980, the radioactive plume release due to reactor core degradation at Chernobyl Nuclear Power Plant in 1986, and the Fukushima Daiichi Nuclear Power Plant accident (March 11, 2011).

In 2021 there were no samples above the LLD for I-131. Indicator gross beta air particulate results for 2021 were comparable to results obtained from 2011-2020 of the operational REMP, but less than 2013 when the annual average was 0.043. Also, the 2021 gross beta annual average was less than the average for preoperational levels. Results are reported as annual average picocuries per cubic meter (pCi/m3).

Monitoring Period Result 2011 - 2020 (Minimum Value) 0.017 2021 Average Value 0.022 2011 - 2020 (Maximum Value) 0.043 Preoperational 0.050 In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. Table 9, Air Particulate Data Summary Table, includes gross beta concentrations and provides a comparison of the indicator and control means and ranges emphasizes the consistent trends seen in this pathway to support the presence of naturally occurring activity. Therefore, it can be concluded that the airborne pathway continues to be unaffected by ANO operations.

Plant: Arkansas Nuclear One Year: 2021 Page 18 of 65 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results - Example ANO reports measured dose as net exposure (field reading less transit reading) normalized to 92 days and relies on comparison of the indicator locations to the control as a measure of plant impact. ANOs comparison of the inner ring and special interest area TLD results to the control, as seen in Table 5, Direct Radiation Annual Summary, identified no noticeable trend that would indicate that the ambient radiation levels are being affected by plant operations. In addition, the inner ring value of 7.8 millirem (mrem) shown in Table 5 for 2021 is within the historical bounds of 2011 - 2020 annual average inner ring results, which have ranged from 7.6 to 8.5 mrem. Overall, ANO concluded that the ambient radiation levels are not being affected by plant operations.

Table 5, Direct Radiation Annual Summary Year Inner Ring (mR/Qtr)

Special Interest (mR/Qtr)

Control Location (mR/Qtr) 2011 8.5 7.6 6.9 2012 8.0 7.2 7.0 2013 8.3 7.6 6.8 2014 7.8 6.9 6.1 2015 7.6 6.9 6.1 2016 8.0 6.7 6.5 2017 8.2 7.2 6.7 2018 7.7 6.4 5.7 2019 7.7 6.9 6.9 2020 7.6 6.9 6.0 2021 7.8 7.2 6.5 4.3 Waterborne Sample Results Analytical results for 2021 drinking water and ground water samples were similar to those reported in previous years. Gamma radionuclides analytical results for 2021 surface water samples were similar to those reported in previous years. Tritium in ANO surface water indicator samples continue to be detected, but at levels below those experienced in 2013 and below the ODCM-required LLD. These results are further explained below.

Plant: Arkansas Nuclear One Year: 2021 Page 19 of 65 Annual Radiological Environmental Operating Report 4.3.1 Surface Water Samples were collected and analyzed for gamma radionuclides and tritium. Gamma radionuclides were below detectable limits which is consistent with results seen in previous operational years. Tritium continues to be detected at the indicator location (Station 8) where previously monitored liquid radioactive effluent from the plant is periodically discharged in accordance with the regulatory criteria established in the ODCM and, for 2021, at levels considerably lower than the ODCM-required LLD of 3000 pCi/l. Furthermore, unlike the elevated tritium levels observed in 2013 attributable to a particular plant event, no elevated levels attributable to particular events were observed in 2021. Results are reported as annual average pCi/l.

Monitoring Period Result 2011 - 2020 (Minimum Value) 427.0 2021 Value 610.0 2011 - 2020 (Maximum Value) 2940*

Preoperational 200.0

• Indicates value from 2013 ANO personnel have noted no definable increasing trends associated with the tritium levels at the discharge location. Levels detected during 2021 and previous operational years have been well below regulatory reporting limits. Therefore, the operation of ANO had no definable impact on this waterborne pathway during 2021 and levels of radionuclides remain similar to those obtained in previous operational years.

4.3.2 Drinking Water Samples were collected from two locations (indicator and control). Although ANO personnel utilize Station 14 (City of Russellville) as an indicator location due to the potential for the drinking water pathway to exist, the City of Russellville has not withdrawn water from Lake Dardanelle in the past several years.

Drinking water samples were analyzed for gross beta radionuclides, I-131, gamma radionuclides and tritium. Gamma radionuclides, gross beta radionuclides, I-131, and tritium concentrations were below the LLD limits at the indicator and control locations, which is consistent with the preoperational and operational years as shown below.

Results from 2021 are summarized in table below. Results are reported as annual average pCi/L. The indicator location has historically shown gross beta above Minimum Detectable Concentration (MDC) but less than LLD, while the control location is below MDC and LLD. However, in 2021 the first and fourth quarter samples at the indicator were 1.58 and 1.91 pCi/L. This is above MDC bus less than LLD. The second and third quarters 2021 samples were less than MDC and LLD.

The value for Gross Beta at the control location in 2021 was 2.29 pCi/L which is greater than MDC but less than LLD.

Plant: Arkansas Nuclear One Year: 2021 Page 20 of 65 Annual Radiological Environmental Operating Report Radionuclide 2021 2020 2011 - 2019**

Preoperational Gross Beta 1.71 2.07*

2.18 2.0 Iodine-131

< LLD

< LLD

< LLD

< LLD Gamma

< LLD

< LLD

< LLD

< LLD Tritium

< LLD

< LLD

< LLD 200.0 Average for the control sample during 2020, gross beta was 2.07 pCi/L which is > MDC, but < LLD.

• • Average of the results from the years 2011-2019.

ANO personnel have noted no definable trends associated with drinking water results at the indicator location. Therefore, the operation of Arkansas Nuclear One had no definable impact on this waterborne pathway during 2021 and levels of radionuclides remain similar to those obtained in previous operational years.

4.3.3 Groundwater Samples were collected from four REMP locations (2 control and 2 indicator locations). During 2011, ANO incorporated sixteen additional groundwater monitoring wells into the Groundwater Protection Initiative (GPI) site program. Sample data are compiled, organized, and reviewed annually to:

Analyze for increasing or decreasing trends at individual sample points, wells, or groups of wells.

Review the radionuclides detected to determine whether changes should be made to the analysis sites or sampling frequencies for each sampling location.

Evaluate the locations of radionuclides in ground water to determine if changes should be made to the sampling locations.

Review current investigation levels and determine if changes should be made.

Determine if any change to the ODCM is required.

Determine if a corrective action/remediation is required.

Groundwater samples from the four REMP locations were analyzed for tritium and gamma radionuclides. Tritium and gamma concentrations were below the LLD limits at all four locations. Listed below is a comparison of 2021 indicator results to past operational years. Results are reported as annual average pCi/l. REMP Groundwater data are captured in the table below. ANO operations had no significant impact on the environment or public by this waterborne pathway.

Plant: Arkansas Nuclear One Year: 2021 Page 21 of 65 Annual Radiological Environmental Operating Report Radionuclide 2021 2011 - 2020 Iodine-131

< LLD

< LLD Gamma

< LLD

< LLD Tritium

< LLD

< LLD Gross Beta 4.38*

4.14**

Average for Indicator and control wells for 2021.

• • Only 2014-2020 gross beta data available for review as historical data. Value is historical average of indicator and control wells.

4.4 Soil Sample Results - Example Sediment samples were collected from two locations in 2021 and analyzed for gamma radionuclides. Listed below is a comparison of 2021 indicator results to the 2011 - 2020 operational years. ANO operations had no significant impact on the environment or public by this waterborne pathway. Results are reported as pCi/kg.

Monitoring Period Result 2011 - 2020 (Minimum Value) 253.0 2021 Value

< LLD 2011 - 2020 (Maximum Value) 661.0 Sediment samples were collected from two locations in 2021 and analyzed for gamma radionuclides. Although Cesium-137 has been detected in years prior to 2021, all gamma radionuclides from 2021 samples were below detectable limits.

These results are consistent with previous years results. Therefore, ANO operations had no significant impact on the environment or public by this waterborne pathway.

4.5 Ingestion Sample Results - Example 4.5.1 Milk Sample Results Milk samples were not collected during 2021 due to the unavailability of indicator locations within five miles of ANO.

4.5.2 Fish Sample Results Fish samples were collected from two locations and analyzed for gamma radionuclides. In 2021, gamma radionuclides were below detectable limits which are consistent with the preoperational monitoring period and operational results since 1997. Therefore, based on these measurements, ANO operations had no significant radiological impact upon the environment or public by this ingestion pathway.

4.5.3 Food Product Sample Results The REMP has detected radionuclides prior to 1990 that are attributable to other sources. These include the radioactive plume release due to reactor core degradation at Chernobyl Nuclear Power Plant in 1986 and atmospheric weapons testing.

Plant: Arkansas Nuclear One Year: 2021 Page 22 of 65 Annual Radiological Environmental Operating Report In 2021, food product samples were collected when available from two locations and analyzed for Iodine-131 and gamma radionuclides. The 2021 levels remained undetectable, as has been the case in previous years. Therefore, based on these measurements, ANO operations had no significant radiological impact upon the environment or public by this ingestion pathway.

4.6 Land Use Census Results The latest land use census (performed in 2021) did not identify any new locations that yielded a calculated dose or dose commitment greater than those currently calculated in Table 6, Land Use Census - [2021] Nearest Residence Within Five Miles.

One cattle farm was observed in the NNE sector. An interview with the owner was performed and he stated that the cattle were for breeding. ANO personnel chose not to perform a garden census in 2021, but instead to sample broadleaf vegetation which is allowed by ODCM Section L 2.5.2. As allowed by NRC Regulatory Guide 1.21, Revision 2, Section 3.2, broadleaf vegetation sampling in the meteorological sector (Sector 13) with a D/Q value within 10% of the sector with the highest D/Q (Sector 12) was performed.

Plant: Arkansas Nuclear One Year: 2021 Page 23 of 65 Annual Radiological Environmental Operating Report Table 6, Land Use Census - [2021] Nearest Residence Within Five Miles Sector Direction Range (Miles)

Comment Nearest Residence Garden Meat Nearest Milk Animal 1

N 1.1 N/A

> 5

> 5 None 2

NNE 1.3 N/A 2.8

> 5 1

3 NE 0.9 N/A

> 5

> 5 None 4

ENE 0.8 N/A

> 5

> 5 None 5

E 0.8 N/A

> 5

> 5 None 6

ESE 0.8 N/A

> 5

> 5 None 7

SE 0.8 N/A

> 5

> 5 None 8

SSE 0.8 N/A

> 5

> 5 None 9

S 0.8 N/A

> 5

> 5 None 10 SSW 0.7 N/A

> 5

> 5 None 11 SW 2.8 N/A

> 5

> 5 None 12 WSW 0.7 N/A

> 5

> 5 None 13 W

0.8 N/A

> 5

> 5 2

14 WNW 0.8 N/A

> 5

> 5 None 15 NW 1.0 N/A

> 5

> 5 None 16 NNW 0.9 N/A

> 5

> 5 None Comment 1

While performing the Land Use Census, a cattle farm was identified. A phone interview was performed with the owner of the farm. The owner stated the cattle were mainly for breeding purposes but could provide an animal for consumption. The meat pathway is not required per ANO ODCM.

2 A new house has been constructed on Galaxy Lane in the West sector since the last Land Use Census conducted in 2019.

Plant: Arkansas Nuclear One Year: 2021 Page 24 of 65 Annual Radiological Environmental Operating Report 4.7 Interlaboratory Comparison Results contains result summaries for the Interlaboratory Comparison Program for Teledyne Brown Engineering and Environmental Dosimetry Group.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1.

Table 7, Radiological Environmental Monitoring Program Summary, summarizes data for the 2021 REMP program.

Plant: Arkansas Nuclear One Year: 2021 Page 25 of 65 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Air Particulates (pCi/m3)

GB / 130 0.01 0.0232 (78 / 78)

[0.0213 - 0.0250]

Station 1 (88°,0.5 mi) 0.0250 (26 / 26)

[0.0156 - 0.0619]

0.0217 (52 / 52)

[0.0201 - 0.0232]

0 Airborne Iodine (pCi/ m3)

I-131 / 130 0.07

< LLD N/A N/A

< LLD 0

Inner Ring TLDs (mR/Qtr)

Special Interest TLDs (mR/Qtr)

Control TLD (mR/Qtr)

Gamma / 64 Gamma / 28 Gamma / 4

[Note 6]

[Note 6]

[Note 6]

7.8 (64 / 64)

[5.8 - 9.5]

7.2 (26 / 28)

[5.3 - 8.4]

N/A Station 56 (264°, 0.4 mi)

Station 137 (151° - 8.2 mi)

N/A 9.5 (4 / 4)

[8.7 - 10.1]

8.4 (4 / 4)

[7.9 - 8.9]

N/A N/A N/A 6.5 (4 / 4)

[6.0 - 7.3]

0 0

0

Plant: Arkansas Nuclear One Year: 2021 Page 26 of 65 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Surface Water (pCi/l)

H-3 / 8 GS / 24 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-95 Nb-95 I-131 Cs-134 Cs-137 Ba-140 La-140 3000 15 30 15 15 30 30 15 15 15 18 60 15 687.3 (4 / 4)

[378 - 1120]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD Station 8 (166°,

0.2 mi)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 610.0 (4 / 4)

[378 - 1120]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

0 0

0 0

0 0

Plant: Arkansas Nuclear One Year: 2021 Page 27 of 65 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Drinking Water (pCi/1)

GB / 8 I-131 / 8 H-3 / 8 GS / 8 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-95 Nb-95 Cs-134 Cs-137 Ba-140 La-140 4

1 2000 15 30 15 15 30 30 15 15 18 60 15 1.71 (4 / 4)

[1.58 - 1.91]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD Station 57 (208°, 19.5 mi)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 2.29 (4 / 4)

[2.17 - 2.70]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 2.29 (4 / 4)

[2.17 - 2.70]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

0 0

0 0

0 0

0 Fish (pCi/kg)

GS / 2 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Cs-134 Cs-137 130 260 130 130 260 130 150

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

Plant: Arkansas Nuclear One Year: 2021 Page 28 of 65 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Food Products (pCi/kg)

I-131 / 6 GS / 6 Cs-134 Cs-137 60 60 80

< LLD

< LLD

< LLD N/A N/A N/A N/A N/A N/A N/A N/A N/A 0

0 0

LEGEND:

[Note 1] - GB = Gross beta; I-131 = Iodine-131; H-3 = Tritium; GS = Gamma scan.

[Note 2] - LLD = Required lower limit of detection based on ANO Units 1 and 2 ODCM Table 2.5-1.

[Note 3] - Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

[Note 4] - Locations are specified (1) by name and (2) degrees relative to reactor site.

[Note 5] - Non-routine results are those which exceed ten times the control station value. If no control station value is available, the result is considered non-routine if it exceeds ten times the preoperational value for the location.

[Note 6] - LLD is not defined in ANO Units 1 and 2 ODCM Table 2.5-1.

Plant: Arkansas Nuclear One Year: 2021 Page 29 of 65 Annual Radiological Environmental Operating Report Page 1 of 1 Sample Deviations Table 8, Sample Deviations Table Comment No.

Sample Media Affected Sample Location Date Problem Evaluation / Actions 1

Air Sample Air Station 56 01/26/2021 Pin holes in particulate filter While performing the biweekly Air Particulate & Iodine Sampling in accordance with EN-CY-130-01 (Radiological Environmental Monitoring Program), Air Station # 56 air particulate filter was found with a single pin hole. The air station sample flow, discharge line, and overall station integrity was found satisfactory as expected. The particulate filter also showed normal coloration to indicate proper filtration. CR-ANO-C-2021-0208.

2 Air Sample Air Station 1

05/04/2021 Loss of power Air Station #1 had a power loss on 04/26/2021 @ 22:24 hrs and was restored on 04/27/2021 @ 04:55 hrs. Second power loss event was on 04/28/2021 @ 03:13 hrs and power was restored on 04/28/2021 at 08:08 hrs. CR-ANO-C-2021-1294.

3 TLD TLD 150 04/20/2021 Missing TLD During the 2nd quarter Environmental TLD change out per procedure EN-CY-130-01 (REMP) the 1st quarter TLD number 150 (located near boat ramp across from plant site) was missing. TLD cage was present but bottom cap was missing.

CR-ANO-C-2021-1151.

4 Air Sample Air Station 1

06/15/2021 Loss of power Air Station #1 had multiple power losses over a period of four days from 06/10/2021 to 06/14/2021. Total Run time loss added up to 23.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. Run time loss was due to Ground-Fault Circuit Interrupter (GFCI) tripping on all occasions. CR-ANO-C-2021-1586 5

Air Sample Air Station 1 and 6 06/29/2021 Loss of power and pin hole in filter Air Station #1 had a power loss on 06/16/2021 due to GFCI tripping. Total run time loss added up to 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The GFCI was replaced which resulted in 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> power loss and Air Station has not tripped since.

Air Station #6 air filter was found with a pin hole in it. All coloration and run time on filter was normal, indicating that no air escaped the filter. CR-ANO-C-2021-1705.

6 TLD TLD 127 7/13/21 Missing TLD TLD 127 was missing from station location. The cage for TLD 127 was attached with both top and bottom caps missing. CR-ANO-C-2021-1846 7

TLD TLD 137 10/12/2021 Missing TLD TLD 137 was missing from station location. The cage for TLD 137 was attached to a post and bottom cap was missing. CR-ANO-C-2021-2727.

8 Air Sample Air Station 1

12/14/2021 Pin holes in particulate filter Air Station #1 air particulate filter was found with a pin hole in it. CR-ANO-C-2021-3186.

9 Air Sample Air Station 1

12/21/2021 Pin holes in particulate filter Air Station #1 air particulate filter was found with several pin holes in it.

CR-ANO-C-2021-3243.

Plant: Arkansas Nuclear One Year: 2021 Page 30 of 65 Annual Radiological Environmental Operating Report Page 1 of 15 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta Units: pCi/m3 Start Date End Date Station 1 [Note 1]

(Indicator)

Station 2 (Indicator)

Station 56 (Indicator)

Station 6[Note 1]

(Control)

Station 7 (Control)

REQUIRED LLD 1E-02 1E-02 1E-02 1E-02 1E-02 12/29/2020 1/12/2021 2.80E-02 1.69E-02 1.90E-02 1.90E-02 1.46E-02 1/12/2021 1/26/2021 3.50E-02 2.00E-02 1.79E-02[Note 2]

2.23E-02 1.28E-02 1/26/2021 2/9/2021 6.19E-02 2.90E-02 2.63E-02 3.00E-02 1.79E-02 2/9/2021 2/23/2021 2.64E-02 2.36E-02 2.57E-02 2.67E-02 1.66E-02 2/23/2021 3/9/2021 1.97E-02 1.50E-02 1.65E-02 2.22E-02 1.03E-02 3/9/2021 3/23/2021 1.74E-02 1.75E-02 1.96E-02 2.02E-02 1.11E-02 3/23/2021 4/6/2021 2.17E-02 2.04E-02 2.28E-02 2.25E-02 1.49E-02 4/6/2021 4/20/2021 1.66E-02 1.57E-02 1.59E-02 1.66E-02 8.65E-03 4/20/2021 5/4/2021 2.11E-02[Note 2]

1.95E-02 2.21E-02 2.30E-02 1.91E-02 5/4/2021 5/18/2021 1.74E-02 1.78E-02 1.92E-02 1.84E-02 1.70E-02 5/18/2021 6/1/2021 1.56E-02 1.54E-02 1.55E-02 1.60E-02 1.62E-02 6/1/2021 6/15/2021 1.64E-02[Note 2]

1.53E-02 1.83E-02 1.71E-02 2.03E-02 6/15/2021 6/29/2021 2.19E-02[Note 2]

2.03E-02 2.30E-02 1.87E-02[Note 2]

2.24E-02 6/29/2021 7/13/2021 1.88E-02 1.60E-02 2.02E-02 1.76E-02 1.70E-02 7/13/2021 7/27/2021 2.18E-02 1.70E-02 2.34E-02 2.27E-02 1.98E-02 7/27/2021 8/10/2021 3.35E-02 3.08E-02 3.35E-02 3.03E-02 3.26E-02 8/10/2021 8/24/2021 1.71E-02 1.62E-02 1.73E-02 1.60E-02 1.59E-02 8/24/2021 9/7/2021 2.25E-02 2.11E-02 2.24E-02 2.16E-02 1.75E-02 9/7/2021 9/21/2021 2.29E-02 2.07E-02 2.37E-02 2.26E-02 2.20E-02 9/21/2021 10/5/2021 2.00E-02 2.16E-02 2.28E-02 2.12E-02 1.94E-02 10/5/2021 10/19/2021 2.56E-02 2.30E-02 2.32E-02 2.37E-02 2.26E-02 10/19/2021 11/2/2021 2.49E-02 2.05E-02 2.15E-02 2.56E-02 2.34E-02 11/2/2021 11/16/2021 3.02E-02 2.98E-02 3.03E-02 3.19E-02 3.07E-02 11/16/2021 11/30/2021 2.72E-02 2.56E-02 2.85E-02 2.91E-02 3.19E-02 11/30/2021 12/14/2021 3.93E-02[Note 2]

3.86E-02 3.95E-02 3.94E-02 3.82E-02

Plant: Arkansas Nuclear One Year: 2021 Page 31 of 65 Annual Radiological Environmental Operating Report Page 2 of 15 Monitoring Results Tables Table 9, Air Particulate Data Summary Table Analysis: Gross Beta Units: pCi/m3 Start Date End Date Station 1 [Note 1]

(Indicator)

Station 2 (Indicator)

Station 56 (Indicator)

Station 6[Note 1]

(Control)

Station 7 (Control) 12/14/2021 12/21/2021 2.82E-02[Note 2]

2.98E-02 3.40E-02 2.97E-02 3.06E-02 Station Yearly Average 2.50E-02 2.13E-02 2.32E-02 2.32E-02 2.01E-02

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

Table 10, Radioiodine Cartridge Data Table Summary Analysis: I-131 Units: pCi/m3 Start Date End Date Station 1 (Indicator)

Station 2 (Indicator)

Station 56 (Indicator)

Station 6 (Control)

Station 7 (Control) 12/29/2020 1/12/2021

< 7.89E-03

< 1.59E-02

< 1.58E-02

< 1.60E-02

< 1.61E-02 1/12/2021 1/26/2021

< 1.23E-02

< 1.15E-02

< 1.15E-02[Note 1]

< 1.14E-02

< 1.13E-02 1/26/2021 2/9/2021

< 7.56E-03

< 1.49E-02

< 1.49E-02

< 1.51E-02

< 1.50E-02 2/9/2021 2/23/2021

< 2.07E-02

< 2.07E-02

< 8.70E-03

< 2.08E-02

< 2.05E-02 2/23/2021 3/9/2021

< 2.06E-02

< 2.07E-02

< 2.07E-02

< 8.64E-03

< 2.06E-02 3/9/2021 3/23/2021

< 1.65E-02

< 1.65E-02

< 1.65E-02

< 7.72E-03

< 1.64E-02 3/23/2021 4/6/2021

< 2.66E-02

< 2.65E-02

< 2.65E-02

< 1.26E-02

< 2.62E-02 4/6/2021 4/20/2021

< 1.46E-02

< 1.46E-02

< 1.22E-02

< 1.45E-02

< 1.44E-02 4/20/2021 5/4/2021

< 8.09E-03[Note 1]

< 1.63E-02

< 1.63E-02

< 1.65E-02

< 1.64E-02 5/4/2021 5/18/2021

< 1.39E-02

< 1.40E-02

< 9.34E-03

< 1.39E-02

< 1.39E-02 5/18/2021 6/1/2021

< 8.83E-03

< 2.10E-02

< 2.10E-02

< 2.09E-02

< 2.09E-02 6/1/2021 6/15/2021

< 1.08E-02[Note 1]

< 2.40E-02

< 2.40E-02

< 2.38E-02

< 2.37E-02 6/15/2021 6/29/2021

< 1.06E-02[Note 1]

< 1.05E-02

< 1.05E-02

< 1.05E-02[Note 1]

< 1.05E-02 6/29/2021 7/13/2021

< 2.23E-02

< 2.24E-02

< 9.38E-03

< 2.22E-02

< 2.21E-02 7/13/2021 7/27/2021

< 1.04E-02

< 1.04E-02

< 1.04E-02

< 1.04E-02

< 1.04E-02 7/27/2021 8/10/2021

< 1.75E-02

< 1.75E-02

< 1.75E-02

< 1.75E-02

< 8.40E-03 8/10/2021 8/24/2021

< 1.39E-02

< 1.39E-02

< 1.39E-02

< 1.38E-02

< 6.55E-03 8/24/2021 9/7/2021

< 1.69E-02

< 1.69E-02

< 1.69E-02

< 1.69E-02

< 7.06E-03

Plant: Arkansas Nuclear One Year: 2021 Page 32 of 65 Annual Radiological Environmental Operating Report Page 3 of 15 Monitoring Results Tables Table 10, Radioiodine Cartridge Data Table Summary Analysis: I-131 Units: pCi/m3 Start Date End Date Station 1 (Indicator)

Station 2 (Indicator)

Station 56 (Indicator)

Station 6 (Control)

Station 7 (Control) 9/7/2021 9/21/2021

< 8.58E-03

< 2.05E-02

< 2.05E-02

< 2.04E-02

< 2.04E-02 9/21/2021 10/5/2021

< 1.58E-02

< 1.58E-02

< 6.62E-03

< 1.57E-02

< 1.57E-02 10/5/2021 10/19/2021

< 1.10E-02

< 5.63E-03

< 1.10E-02

< 1.10E-02

< 1.10E-02 10/19/2021 11/2/2021

< 8.75E-03

< 2.09E-02

< 2.09E-02

< 2.08E-02

< 2.08E-02 11/2/2021 11/16/2021

< 2.01E-02

< 8.46E-03

< 2.02E-02

< 2.01E-02

< 2.00E-02 11/16/2021 11/30/2021

< 1.55E-02

< 1.55E-02

< 1.55E-02

< 1.56E-02

< 7.41E-03 11/30/2021 12/14/2021

< 1.72E-02[Note 1]

< 1.72E-02

< 1.15E-02

< 1.71E-02

< 1.71E-02 12/14/2021 12/21/2021

< 2.11E-02[Note 1]

< 2.11E-02

< 2.11E-02

< 2.10E-02

< 9.52E-03 Station Yearly Average

< LLD

< LLD

< LLD

< LLD

< LLD

[Note 1] - Reference Attachment 1.

Plant: Arkansas Nuclear One Year: 2021 Page 33 of 65 Annual Radiological Environmental Operating Report Page 4 of 15 Monitoring Results Tables Table 11, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mrem Station 1st Qtr

[2021]

2nd Qtr

[2021]

3rd Qtr

[2021]

4th Qtr

[2021]

Annual Mean

[2021]

1 8.0 8.1 9.4 9.3 8.7 2

7.5 8.1 8.9 9.1 8.4 3

5.8 5.4 5.9 6.0 5.8 4

8.3 7.5 7.9 9.1 8.2 56[Note 1]

9.0 8.7 10.1 10 9.5 108 8.2 7.4 8.9 9.0 8.4 109 8.0 7.6 8.4 8.7 8.2 110 8.1 7.2 7.9 8.4 7.9 145 7.6 7.5 8.0 8.6 7.9 146 7.5 7.2 7.4 7.9 7.5 147 6.8 6.3 8.0 7.1 7.1 148 8.1 7.8 8.3 8.3 8.1 149 6.8 7.4 7.4 8.0 7.4 150 0.0[Note 2]

9.0 9.6 9.7 7.1 151 7.8 7.2 8.8 9.4 8.3 152 6.1 5.9 7.1 7.8 6.7

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

Plant: Arkansas Nuclear One Year: 2021 Page 34 of 65 Annual Radiological Environmental Operating Report Page 5 of 15 Monitoring Results Tables Table 12, Thermoluminescent Dosimeters - Special Interest Areas Analysis: Gamma Dose Units: mrem Station 1st Qtr [2021]

2nd Qtr [2021]

3rd Qtr [2021]

4th Qtr [2021]

Annual Mean

[2021]

6 7.1 7.6 6.9 8.1 7.4 111 5.7 6.3 5.3 5.9 5.8 116 8.6 8.1 7.9 8.3 8.2 125 5.1 4.9 5.1 6.0 5.3 127 7.3 0.0 [Note 2]

7.4 8.4 7.7 137 [Note 1]

7.9 8.5 0.0 [Note 2]

8.9 8.4 153 7.1 7.7 8.4 7.9 7.8

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

Table 13, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mrem Station 1st Qtr [2021]

2nd Qtr [2021]

3rd Qtr [2021]

4th Qtr [2021]

Annual Mean

[2021]

7 6.1 6.0 6.5 7.3

6.5 Plant

Arkansas Nuclear One Year: 2021 Page 35 of 65 Annual Radiological Environmental Operating Report Page 6 of 15 Monitoring Results Tables Table 14, Surface Water - Gamma Analysis: Gamma Isotopic Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD 15 15 30 15 30 15 30 15 15 18 60 15 Station 8 (Indicator) 12/31/2020 01/31/2021

< 1.19

< 1.56

< 3.77

< 1.59

< 2.67

< 1.61

< 3.03

< 11.6

< 1.33

< 1.31

< 17.5

< 7.52 Station 10 (Control) 12/31/2020 01/31/2021

< 2.91

< 4.11

< 9.02

< 5.33

< 10.2

< 4.91

< 7.83

< 4.75

< 5.57

< 3.70

< 18.6

< 7.23 Station 8 (Indicator) 01/31/2021 02/28/2021

< 1.15

< 1.41

< 3.40

< 1.28

< 2.62

< 1.46

< 2.60

< 13.9

< 1.31

< 1.20

< 18.3

< 6.55 Station 10 (Control) 01/31/2021 02/28/2021

< 4.73

< 3.52

< 8.93

< 3.78

< 9.37

< 5.88

< 7.28

< 14.2

< 4.55

< 3.78

< 28.6

< 11.5 Station 8 (Indicator) 02/28/2021 03/31/2021

< 1.74

< 1.87

< 4.17

< 1.80

< 3.32

< 2.05

< 3.25

< 8.43

< 1.82

< 1.67

< 15.9

< 5.97 Station 10 (Control) 02/28/2021 03/31/2021

< 5.13

< 6.73

< 14.0

< 5.39

< 14.9

< 7.59

< 8.56

< 10.9

< 6.41

< 6.96

< 31.2

< 13.1 Station 8 (Indicator) 03/31/2021 04/30/2021

< 3.04

< 3.07

< 6.34

< 3.62

< 3.91

< 4.03

< 6.43

< 13.9

< 3.53

< 3.69

< 24.8

< 10.3 Station 10 (Control) 03/31/2021 04/30/2021

< 5.32

< 6.51

< 9.94

< 5.12

< 12.0

< 6.54

< 8.93

< 8.39

< 9.68

< 6.05

< 25.6

< 7.33 Station 8 (Indicator) 04/30/2021 05/31/2021

< 1.66

< 1.87

< 4.26

< 1.80

< 3.31

< 1.84

< 3.27

< 6.66

< 1.86

< 1.73

< 1.31

< 4.59 Station 10 (Control) 04/30/2021 05/31/2021

< 8.36

< 8.51

< 11.3

< 9.11

< 16.4

< 6.48

< 12.8

< 8.93

< 9.38

< 8.44

< 24.3

< 11.3

Plant: Arkansas Nuclear One Year: 2021 Page 36 of 65 Annual Radiological Environmental Operating Report Page 7 of 15 Monitoring Results Tables Table 14, Surface Water - Gamma Analysis: Gamma Isotopic Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 Station 8 (Indicator) 05/31/2021 06/30/2021

< 1.73

< 1.99

< 4.93

< 1.70

< 3.16

< 2.16

< 3.42

< 10.0

< 1.85

< 1.81

< 19.0

< 6.61 Station 10 (Control) 05/31/2021 06/30/2021

< 5.76

< 7.50

< 17.6

< 6.74

< 14.9

< 8.61

< 12.4

< 12.3

< 8.70

< 7.85

< 29.8

< 12.2 Station 8 (Indicator) 06/30/2021 07/31/2021

< 1.04

< 1.22

< 2.81

< 1.26

< 2.30

< 1.26

< 2.08

< 5.92

< 1.12

< 1.13

< 11.0

< 3.68 Station 10 (Control) 06/30/2021 07/31/2021

< 6.63

< 6.43

< 16.2

< 3.91

< 12.1

< 5.88

< 12.0

< 11.4

< 8.61

< 8.25

< 29.5

< 11.3 Station 8 (Indicator) 07/31/2021 08/31/2021

< 1.65

< 1.67

< 4.06

< 1.77

< 3.35

< 1.77

< 3.15

< 7.29

< 1.79

< 1.69

< 14.4

< 4.59 Station 10 (Control) 07/31/2021 08/31/2021

< 6.60

< 6.29

< 14.8

< 7.20

< 13.8

< 6.73

< 11.7

< 7.65

< 7.40

< 7.39

< 28.4

< 8.68 Station 8 (Indicator) 08/31/2021 09/30/2021

< 1.64

< 1.82

< 4.33

< 1.63

< 3.54

< 1.89

< 3.23

< 9.45

< 1.78

< 1.56

< 17.3

< 6.02 Station 10 (Control) 08/31/2021 09/30/2021

< 5.61

< 7.07

< 15.8

< 6.65

< 14.7

< 6.57

< 14.0

< 9.90

< 7.19

< 6.74

< 33.5

< 10.4 Station 8 (Indicator) 09/30/2021 10/31/2021

< 1.99

< 2.24

< 4.87

< 2.11

< 4.37

< 2.37

< 4.32

< 9.20

< 2.27

< 2.17

< 18.2

< 5.78 Station 10 (Control) 09/30/2021 10/31/2021

< 6.49

< 6.86

< 11.4

< 6.79

< 14.4

< 6.58

< 10.7

< 7.72

< 8.02

< 5.62

< 25.1

< 7.24

Plant: Arkansas Nuclear One Year: 2021 Page 37 of 65 Annual Radiological Environmental Operating Report Page 8 of 15 Monitoring Results Tables Table 14, Surface Water - Gamma Analysis: Gamma Isotopic Units: pCi/L Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 Station 8 (Indicator) 10/31/2021 11/30/2021

< 1.58

< 1.71

< 3.85

< 1.72

< 2.99

< 1.87

< 3.19

< 6.11

< 1.83

< 1.69

< 13.5

< 4.97 Station 10 (Control) 10/31/2021 11/30/2021

< 6.41

< 8.64

< 12.2

< 6.58

< 14.1

< 6.29

< 12.8

< 8.29

< 8.12

< 7.50

< 21.9

< 11.6 Station 8 (Indicator) 11/30/2021 12/31/2021

< 1.70

< 1.82

< 4.34

< 1.77

< 2.97

< 1.92

< 3.26

< 8.71

< 1.82

< 1.65

< 15.9

< 5.10 Station 10 (Control) 11/30/2021 12/31/2021

< 7.34

< 7.54

< 17.6

< 9.31

< 14.1

< 7.77

< 11.8

< 9.78

< 7.60

< 8.52

< 33.3

< 10.4

Plant: Arkansas Nuclear One Year: 2021 Page 38 of 65 Annual Radiological Environmental Operating Report Page 9 of 15 Monitoring Results Tables Table 15, Surface Water - Tritium Analysis: H-3 Units: pCi/L Location Start Date End Date H-3 REQUIRED LLD 3000 Station 8 (Indicator) 12/31/2020 03/31/2021 1120 Station 10 (Control) 12/31/2020 03/31/2021

< 372 Station 8 (Indicator) 03/31/2021 06/30/2021 477 Station 10 (Control) 03/31/2021 06/30/2021

< 336 Station 8 (Indicator) 06/30/2021 09/30/2021

< 378 Station 10 (Control) 06/30/2021 09/30/2021

< 384 Station 8 (Indicator) 09/30/2021 12/31/2021 465 Station 10 (Control) 09/30/2021 12/31/2021

< 361

Plant: Arkansas Nuclear One Year: 2021 Page 39 of 65 Annual Radiological Environmental Operating Report Page 10 of 15 Monitoring Results Tables Table 16, Drinking Water -Gamma, GB, I-131 Analysis: Gamma Isotopic, Gross Beta, I-131 Units: pCi/L Location Collection Date Gross Beta Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD 4.0 15 15 30 15 30 15 30 1.0 15 18 60 15 Station 14 (Indicator) 01/12/2021 1.58

< 4.48

< 4.04

< 7.86

< 4.82

< 9.71

< 4.51

< 7.39

< 4.53

< 4.21

< 4.37

< 14.0

< 5.05 Station 57 (Control) 01/12/2021 2.70

< 4.13

< 3.92

< 7.55

< 4.72

< 8.01

< 3.73

< 8.05

< 4.85

< 4.95

< 4.32

< 16.6

< 5.48 Station 14 (Indicator) 04/06/2021

< 1.68

< 5.03

< 6.51

< 12.0

< 3.97

< 8.95

< 5.81

< 10.1

< 10.1

< 5.37

< 5.52

< 28.8

< 9.04 Station 57 (Control) 04/06/2021

< 1.76

< 4.80

< 4.77

< 8.61

< 6.44

< 10.7

< 6.10

< 10.4

< 8.40

< 5.23

< 6.08

< 27.6

< 9.72 Station 14 (Indicator) 07/13/2021

< 1.66

< 6.88

< 5.19

< 15.8

< 5.31

< 13.8

< 5.46

< 9.05

< 7.03

< 8.41

< 7.05

< 19.6

< 2.67 Station 57 (Control) 07/13/2021 2.52

< 4.44

< 5.40

< 11.1

< 7.74

< 16.6

< 5.97

< 7.94

< 6.28

< 6.64

< 5.41

< 21.5

< 8.04 Station 14 (Indicator) 10/12/2021 1.91

< 6.48

< 6.35

< 15.6

< 7.70

< 14.5

< 6.80

< 11.0

< 7.83

< 6.84

< 6.11

< 28.4

< 10.2 Station 57 (Control) 10/12/2021 2.17

< 6.04

< 7.97

< 13.8

< 8.05

< 12.4

< 6.53

< 14.2

< 7.59

< 8.43

< 6.69

< 21.7

< 10.9

Plant: Arkansas Nuclear One Year: 2021 Page 40 of 65 Annual Radiological Environmental Operating Report Page 11 of 15 Monitoring Results Tables Table 17, Drinking Water - Tritium Analysis: H-3 Units: pCi/L Location Collection Date H-3 REQUIRED LLD 2000 Station 14 (Indicator) 01/12/2021

< 373 Station 57 (Control) 01/12/2021

< 368 Station 14 (Indicator) 04/06/2021

< 382 Station 57 (Control) 04/06/2021

< 380 Station 14 (Indicator) 07/13/2021

< 351 Station 57 (Control) 07/13/2021

< 347 Station 14 (Indicator) 10/12/2021

< 312 Station 57 (Control) 10/12/2021

< 314 Table 18, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 REQUIRED LLD 150 180 Station 8 (Indicator) 04/13/2021

< 125

< 107 Station 16 (Control) 04/02/2021

< 113

< 109

Plant: Arkansas Nuclear One Year: 2021 Page 41 of 65 Annual Radiological Environmental Operating Report Page 12 of 15 Monitoring Results Tables Table 19, Fish Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 REQUIRED LLD 130 130 260 130 260 130 150 Station 8 (Indicator) 03/05/2021

< 66.2

< 88.2

< 105

< 74.1

< 154

< 54.3

< 67.3 Station 16 (Control) 5/21/2021

< 53.7

< 58.4

< 124

< 60.1

< 119

< 46.5

< 50.9 Table 20, Food Products Analysis: I-131, Gamma Isotopic Units: pCi/kg Location Collection Date I-131 Cs-134 Cs-137 REQUIRED LLD 60 60 80 Station 13 (Indicator) 06/15/2021

< 35.9

< 37.9

< 33.5 Station 55 (Control) 06/15/2021

< 44.5

< 42.2

< 47.7 Station 13 (Indicator) 07/13/2021

< 34.4

< 33.9

< 32.6 Station 55 (Control) 07/13/2021

< 35.8

< 37.0

< 27.1 Station 13 (Indicator) 08/10/2021

< 34.7

< 31.8

< 25.9 Station 55 (Control) 08/10/2021

< 35.8

< 31.5

< 29.0

Plant: Arkansas Nuclear One Year: 2021 Page 42 of 65 Annual Radiological Environmental Operating Report Page 13 of 15 Monitoring Results Tables Table 21, Groundwater - Gamma and Iodine Analysis: Gross Beta, I-131, Gamma Isotopic Units: pCi/L Location Collection Date Gr-B Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD N/A[Note 1]

15 15 30 15 30 15 30 15 15 18 60 15 Station 58 (Control) 3/10/2021 1.87

< 4.81

< 5.04

< 9.52

< 3.71

< 8.46

< 5.61

< 8.39

< 14.2

< 5.09

< 5.02

< 27.2

< 9.93 Station 62 (Control) 3/09/2021

< 3.79

< 4.76

< 5.58

< 12.4

< 5.96

< 8.10

< 5.45

< 9.61

< 14.0

< 5.21

< 4.94

< 36.0

< 14.0 Station 63 (Indicator) 3/09/2021 6.12

< 4.61

< 5.67

< 11.9

< 5.51

< 10.8

< 4.40

< 9.88

< 14.5

< 5.14

< 5.52

< 37.0

< 9.57 Station 64 (Indicator) 3/10/2021 3.05

< 5.26

< 4.75

< 11.9

< 6.36

< 9.46

< 6.17

< 9.67

< 14.5

< 6.10

< 5.12

< 34.3

< 14.1 Station 58 (Control) 6/08/2021

< 2.00

< 5.15

< 3.65

< 8.79

< 4.75

< 10.3

< 5.41

< 7.55

< 7.29

< 4.79

< 3.87

< 21.6

< 6.89 Station 62 (Control) 6/08/2021

< 1.95

< 5.35

< 4.17

< 9.59

< 5.28

< 10.6

< 5.67

< 9.73

< 7.96

< 6.32

< 5.12

< 22.9

< 8.41 Station 63 (Indicator) 6/08/2021 7.56

< 5.16

< 4.89

< 9.34

< 5.50

< 8.88

< 6.23

< 8.78

< 7.88

< 6.03

< 6.15

< 22.5

< 7.05 Station 64 (Indicator) 6/09/2021

< 3.34

< 7.31

< 7.06

< 13.7

< 6.66

< 11.2

< 7.07

< 10.8

< 9.77

< 6.53

< 5.92

< 28.9

< 11.0 Station 58 (Control) 9/07/2021

< 1.72

< 6.84

< 7.78

< 14.7

< 9.85

< 14.7

< 7.92

< 12.1

< 9.86

< 6.13

< 7.46

< 30.7

< 9.79 Station 62 (Control) 9/07/2021

< 2.80

< 6.74

< 7.11

< 12.3

< 7.40

< 12.3

< 7.39

< 11.1

< 10.1

< 6.82

< 6.63

< 29.7

< 4.59 Station 63 (Indicator) 9/07/2021 2.99

< 5.86

< 7.24

< 14.3

< 9.50

< 16.4

< 6.77

< 11.5

< 8.84

< 6.85

< 6.72

< 22.0

< 14.7 Station 64 (Indicator) 9/08/2021

< 2.51

< 5.73

< 6.44

< 12.6

< 6.54

< 14.4

< 6.03

< 9.96

< 8.98

< 6.74

< 6.44

< 28.3

< 9.98 Station 58 (Control) 12/07/2021

< 2.11

< 5.82

< 7.23

< 11.9

< 7.72

< 11.8

< 10.3

< 11.4

< 9.19

< 7.58

< 6.93

< 25.9

< 8.12

Plant: Arkansas Nuclear One Year: 2021 Page 43 of 65 Annual Radiological Environmental Operating Report Page 14 of 15 Monitoring Results Tables Table 21, Groundwater - Gamma and Iodine Analysis: Gross Beta, I-131, Gamma Isotopic Units: pCi/L Location Collection Date Gr-B Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 I-131 Cs-134 Cs-137 Ba-140 La-140 REQUIRED LLD N/A[Note 1]

15 15 30 15 30 15 30 15 15 18 60 15 Station 62 (Control) 12/07/2021

< 3.49

< 5.82

< 6.25

< 9.06

< 6.68

< 14.3

< 4.62

< 11.7

< 6.87

< 5.55

< 6.35

< 22.4

< 6.15 Station 63 (Indicator) 12/07/2021

< 2.85

< 4.70

< 5.08

< 12.5

< 7.63

< 12.5

< 6.17

< 8.66

< 6.93

< 4.94

< 4.88

< 17.9

< 6.11 Station 64 (Indicator) 12/08/2021 4.38

< 8.43

< 4.16

< 15.6

< 10.4

< 16.4

< 11.1

< 13.8

< 12.1

< 7.28

< 7.11

< 32.2

< 11.5

[Note 1] - Per ANOs ODCM there is no Gross Beta LLD for groundwater or a reportable detectable concentration.

Plant: Arkansas Nuclear One Year: 2021 Page 44 of 65 Annual Radiological Environmental Operating Report Page 15 of 15 Monitoring Results Tables Table 22, Groundwater - Tritium Analysis: H-3 Units: pCi/L Location Collection Date H-3 REQUIRED LLD 3000 Station 58 (Control) 3/10/2021

< 369 Station 62 (Control) 3/09/2021

< 364 Station 63 (Indicator) 3/09/2021

< 358 Station 64 (Indicator) 3/10/2021

< 350 Station 58 (Control) 6/08/2021

< 394 Station 62 (Control) 6/08/2021

< 380 Station 63 (Indicator) 6/08/2021

< 375 Station 64 (Indicator) 6/09/2021

< 387 Station 58 (Control) 9/07/2021

< 355 Station 62 (Control) 9/07/2021

< 348 Station 63 (Indicator) 9/07/2021

< 347 Station 64 (Indicator) 9/08/2021

< 360 Station 58 (Control) 12/08/2021

< 320 Station 62 (Control) 12/08/2021

< 325 Station 63 (Indicator) 12/08/2021

< 330 Station 64 (Indicator) 12/09/2021

< 319

Plant: Arkansas Nuclear One Year: 2021 Page 45 of 65 Annual Radiological Environmental Operating Report Page 1 of 16 Interlaboratory Comparison Program Results 1.0

SUMMARY

1.1 Summary of Results - Inter-laboratory Comparison Program (ICP)

The TBE Laboratory analyzed Performance Evaluation (PE) samples of air particulate (AP), air iodine, milk, soil, vegetation, and water matrices for various analytes. The PE samples supplied by Analytics Inc., Environmental Resource Associates (ERA) and Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP), were evaluated against the following pre-set acceptance criteria:

1.

Analytics Evaluation Criteria Analytics evaluation report provides a ratio of TBEs result and Analytics known value. Since flag values are not assigned by Analytics, TBE evaluates the reported ratios based on internal QC requirements based on the DOE MAPEP criteria.

2.

ERA Evaluation Criteria ERAs evaluation report provides an acceptance range for control and warning limits with associated flag values. ERAs acceptance limits are established per the US Environmental Protection Agency (EPA), National Environmental Laboratory Accreditation Conference (NELAC), state-specific Performance Testing (PT) program requirements or ERAs Standard Operating Procedure (SOP) for the Generation of Performance Acceptance Limits, as applicable.

The acceptance limits are either determined by a regression equation specific to each analyte or a fixed percentage limit promulgated under the appropriate regulatory document.

3.

DOE Evaluation Criteria MAPEPs evaluation report provides an acceptance range with associated flag values. MAPEP defines three levels of performance:

Acceptable (flag = A) - result within +/- 20% of the reference value.

Acceptable with Warning (flag = W) - result falls in the +/- 20% to +/- 30%

of the reference value.

Not Acceptable (flag = N) - bias is greater than 30% of the reference value.

Note: The Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP) samples are created to mimic conditions found at DOE sites which do not resemble typical environmental samples obtained at commercial nuclear power facilities.

Plant: Arkansas Nuclear One Year: 2021 Page 46 of 65 Annual Radiological Environmental Operating Report Page 2 of 16 Interlaboratory Comparison Program Results

4.

For the TBE laboratory, 146 out of 154 analyses performed met the specified acceptance criteria. Seven analyses did not meet the specified acceptance criteria and were addressed through the TBE Corrective Action Program.

NOTE: One analysis (soil for Tc-99) that did not meet acceptance criteria was performed for TBE information and is not on the list of required Inductively Coupled Plasma (ICP) analyses. A summary is found below:

a.

The ERA millirad (MRAD) March 2021 Water Fe-55 result was evaluated as Not Acceptable. The reported value for Fe-55 was 579 pCi/L and the known result was 275 pCi/L (acceptance range 162 - 400 pCi/L). When reviewing the original sample data, it was found that the carrier yield was 52.6% (lower than typical water samples). Looking at the etched plate that was counted, it appeared that some loss of sample could have occurred. The sample was logged for reanalysis and used as the workgroup duplicate. The results were acceptable at 197 and 221 respectively. Yields were 97.4% and 105.7% and the plated samples were centered with no apparent loss of sample. The loss of sample during plating resulted in a low yield which produced an artificially high sample result. (NCR 21-01)

b.

The MAPEP February 2021 AP Gross Alpha result was evaluated as Not Acceptable. The reported value was 0.371 Bq/sample and the known result was 1.77 Bq/sample (acceptance range 0.53 - 3.01 Bq/sample). A similar failure had occurred several years prior due to the filter being placed with the wrong side up on the detector. At that time, a small dot was placed on the top of the filter prior to removal from the package to indicate the correct side for counting. The current sample was still in the detector when the result was received (dot side facing the detector). The sample was recounted with a similar result and was flipped and recounted. The flipped result was 0.661 Bq/sample, within the acceptable range. Because TBE cannot rely on receiving correct packaging from the provider, MAPEP AP cross-checks will be counted on both sides going forward. NOTE: The August sample had the same packaging issue (upside down). (NCR 21-02)

c.

The MAPEP February 2021 soil Ni-63 was evaluated as Not Acceptable.

The reported value was 310 Bq/kg and the known result was 689 Bq/kg (acceptance range 482 - 896 Bq/kg). All workgroup QC was reviewed with no anomalies. The analytical procedure had been revised prior to this analysis to eliminate added interferences. The sample yield was

> 100%, indicative of incomplete separation from interferences, leading to a lower result. The procedure was again revised after acceptable results were obtained. (NCR 21-03)

d.

The ERA October 2021 water Gross Beta result was evaluated as Not Acceptable. The reported value was 63.0 pCi/L and the known was 55.7 pCi/L (acceptance range 38.1 - 62.6 pCi/L) or 113% of the known.

The 2-sigma error was 6.8, placing the reported result well within the acceptable range. All QA was reviewed with no anomalies. A follow-up Quick Response cross-check was analyzed with a 120% ratio (see item 7). (NCR 21-10)

Plant: Arkansas Nuclear One Year: 2021 Page 47 of 65 Annual Radiological Environmental Operating Report Page 3 of 16 Interlaboratory Comparison Program Results

e.

The ERA October 2021 water Tritium result was evaluated as Not Acceptable. The reported value was 13,800 pCi/L and the known was 17,200 pCi/L (acceptance range 15,000 - 18,900 pCi/L). The 2-sigma error was 1,430, placing the result within the acceptable range. TBEs internal QC acceptance is 70% - 130%, while ERAs for this sample was 87% - 110%. All QA was reviewed with no anomalies. A Quick Response follow-up cross-check was analyzed with a result of 17,500 pCi/L (known 17,800 pCi/L). (NCR 21-11)

f.

The MAPEP August 2021 soil Ni-63 result was evaluated as Not Acceptable. The reported value was 546 Bq/kg and the known result was 1,280 Bq/kg (acceptance range 896 - 1,664 Bq/kg). All QC was reviewed, and no anomalies found. The procedure revision to remove added MAPAP interferences was ineffective for this sample. No client soil matrix samples were analyzed for Ni-63 in 2020 or 2021. The root cause investigation is still ongoing at this time. (NCR 21-13)

g.

The ERA December 2021 Quick Response Water Gross Beta result was evaluated as Not Acceptable. The reported value was 47.6 pCi/L and the known was 39.8 pCi/L or 120% of the known (acceptance range of 26.4 -

47.3) pCi/L. The 2-sigma error was 6.1, placing the reported result well within the acceptable range. All QA was reviewed with no anomalies.

The original sample was recounted on a different detector with a result of 40.3 +/- 6.27 pCi/L. The failure of this sample and the RAD-127 was due to the narrow upper acceptance ranges assigned (119% and 112%)

(NCR 21-14)

5.

The Inter-Laboratory Comparison Program provides evidence of in control counting systems and methods, and that the laboratories are producing accurate and reliable data.

Plant: Arkansas Nuclear One Year: 2021 Page 48 of 65 Annual Radiological Environmental Operating Report Page 4 of 16 Interlaboratory Comparison Program Results ENVIRONMENTAL DOSIMETRY COMPANY ANNUAL QUALITY ASSURANCE STATUS REPORT January - December 2021 10 Ashton Lane Sterling, MA 01564

Plant: Arkansas Nuclear One Year: 2021 Page 49 of 65 Annual Radiological Environmental Operating Report Page 5 of 16 Interlaboratory Comparison Program Results 2.0 EXECUTIVE

SUMMARY

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

During this annual period 100% (72/72) of the individual dosimeters, evaluated against the EDC internal performance acceptance criteria (high-energy photons only),

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

One internal assessment was performed in 2021. There were no findings.

3.0 INTRODUCTION

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

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

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

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 50 of 65 Annual Radiological Environmental Operating Report Page 6 of 16 Interlaboratory Comparison Program Results 4.0 PERFORMANCE EVALUATION CRITERIA 4.1 Acceptance Criteria for Internal Evaluations

1.

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

i i

i H

H 100 H

Where:

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

Hi = the exposure delivered to the ith irradiated dosimeter (i.e., the delivered exposure)

2.

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

i i

i H

H 1

100 H

n Where:

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 51 of 65 Annual Radiological Environmental Operating Report Page 7 of 16 Interlaboratory Comparison Program Results

3.

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

i i

i H

H 1

100 H

n Where:

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

Hi = the mean reported exposure; i.e.

n = the number of dosimeters in the test group

4.

EDC Internal Tolerance Limits All evaluation criteria are taken from the EDC Quality System Manual, (Reference 2). These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs 137) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +/- 12.8% for precision.

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

1.

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

2.

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

Plant: Arkansas Nuclear One Year: 2021 Page 52 of 65 Annual Radiological Environmental Operating Report Page 8 of 16 Interlaboratory Comparison Program Results 4.3 Reporting of Environmental Dosimetry Results to EDC Customers

1.

All results are to be reported in a timely fashion.

2.

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

3.

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

5.0 DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2021 5.1 General Discussion Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4.

Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period 100% (72/72) of the individual dosimeters, evaluated against these criteria, met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision. A graphical interpretation is provided in Figures 1 and 2.

Table 2 provides the bias and standard deviation results for each group (N=6) of dosimeters evaluated against the internal tolerance criteria. Overall,100% (12/12) of the dosimeter sets, evaluated against the internal tolerance performance criteria, met these criteria. A graphical interpretation is provided in Figure 3.

Table 3 presents the independent blind spike results for dosimeters processed during this annual period. All results passed the performance acceptance criterion. Figure 4 is a graphical interpretation of Seabrook Station blind co-located station results.

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 53 of 65 Annual Radiological Environmental Operating Report Page 9 of 16 Interlaboratory Comparison Program Results 6.0 STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period.

7.0 STATUS OF AUDITS/ASSESSMENTS

1.

Internal EDC Internal Quality Assurance Assessment was conducted during the fourth quarter 2021. There were no findings identified.

2.

External None.

8.0 PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2021 Several procedures were reissued with no changes as part of the 5-year review cycle.

9.0 CONCLUSION

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

10.0 REFERENCES

1.

EDC Quality Control and Audit Assessment Schedule, 2021.

2.

EDC Manual 1, Quality System Manual, Rev. 4, September 28, 2020.

Plant: Arkansas Nuclear One Year: 2021 Page 54 of 65 Annual Radiological Environmental Operating Report Page 10 of 16 Interlaboratory Comparison Program Results TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 2021(1), (2)

Dosimeter Type Number Tested

% Passed Bias Criteria

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

(2)Environmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES (N=6)

JANUARY - DECEMBER 2021(1), (2)

Process Date Exposure Level Mean Bias %

Standard Deviation Tolerance Limit +/-

15%

5/04/2021 33 0.6 0.9 Pass 5/06/2021 120

-0.2 1.4 Pass 5/26/2021 53

-3.8 1.6 Pass 7/27/2021 67 2.8 1.4 Pass 8/04/2021 91

-1.8 2.3 Pass 9/14/2021 47

-0.2 2.3 Pass 11/01/2021 28 3.7 0.6 Pass 11/03/2021 74 1.9 1.9 Pass 11/09/2021 103 1.1 1.1 Pass 01/26/2022 37 2.6 1.9 Pass 01/30/2022 85

-4.2 1.1 Pass 02/06/2022 58 2.9 1.2 Pass (1)This table summarizes results of tests conducted by EDC for TLDs issued in 2021.

(2)Environmental dosimeter results are free in air.

Plant: Arkansas Nuclear One Year: 2021 Page 55 of 65 Annual Radiological Environmental Operating Report Page 11 of 16 Interlaboratory Comparison Program Results TABLE 3

SUMMARY

OF INDEPENDENT DOSIMETER TESTING JANUARY - DECEMBER 2021(1), (2)

Issuance Period Client Mean Bias %

Standard Deviation %

Pass / Fail 1st Qtr. 2021 SONGS

-3.8 1.4 Pass 1st Qtr. 2021 SONGS

-4.7 1.1 Pass 2nd Qtr.2021 Seabrook 3.1 1.0 Pass 3rd Qtr. 2021 Millstone

-4.7 1.4 Pass 4th Qtr.2021 PSEG(PNNL) 50mR 1.3 0.8 Pass 4th Qtr.2021 PSEG(PNNL) 100mR 1.8 0.8 Pass 4th Qtr.2021 PSEG(PNNL) 150mR

-0.6 0.5 Pass 4th Qtr.2021 PSEG(PNNL) 200mR

-2.6 2.0 Pass 4th Qtr.2021 Seabrook 2.6 1.4 Pass (1) Performance criteria are +/- 15%.

(2) Blind spike irradiations using Cs-137

Plant: Arkansas Nuclear One Year: 2021 Page 56 of 65 Annual Radiological Environmental Operating Report Page 12 of 16 Interlaboratory Comparison Program Results APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2021

Plant: Arkansas Nuclear One Year: 2021 Page 57 of 65 Annual Radiological Environmental Operating Report Page 13 of 16 Interlaboratory Comparison Program Results

Plant: Arkansas Nuclear One Year: 2021 Page 58 of 65 Annual Radiological Environmental Operating Report Page 14 of 16 Interlaboratory Comparison Program Results

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Plant: Arkansas Nuclear One Year: 2021 Page 60 of 65 Annual Radiological Environmental Operating Report Page 16 of 16 Interlaboratory Comparison Program Results

Plant: Arkansas Nuclear One Year: 2021 Page 61 of 65 Annual Radiological Environmental Operating Report Page 1 of 5 ERRATA In the 2020 AREOR, Table 7, there are mistakes in the non-routine results column for the Air Particulate and Charcoal as well as the Special Interest TLDs. The number 9 for the Air Particulates and Airborne Iodine should be 0 as there were no samples that were greater than ten times the control location for 2020. Additionally, the Special Interest TLDs number 1 should be 0 as there were no samples that were greater than ten times the control location. See corrected Table 7 from the 2020 AREOR below.

Table 23, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Air Particulates (pCi/m3)

GB / 130 0.01 0.0175(78 / 78)

[0.0166 - 0.0184]

Station 6 (88°,0.5 mi) 0.0192 (26 / 26)

[0.0103 - 0.0331]

0.0171 (52 / 52)

[0.0165 - 0.0192]

0 Airborne Iodine (pCi/ m3)

I-131 / 130 0.07

< LLD N/A N/A

< LLD 0

Inner Ring TLDs (mR/Qtr)

Special Interest TLDs (mR/Qtr)

Control TLD (mR/Qtr)

Gamma / 64 Gamma / 28 Gamma / 4

[Note 6]

[Note 6]

[Note 6]

7.6 (64 / 64)

[5.1 - 9.4]

6.9 (28 / 28)

[5.1 - 8.5]

N/A Station 56 (264°, 0.4 mi)

Station 116 (318° - 1.8 mi)

N/A 9.4 (4 / 4)

[8.3 - 11.2]

8.5 (4 / 4)

[8.1 - 9.1]

N/A N/A N/A 6.0 (4 / 4)

[5.3 - 6.9]

0 0

0

Plant: Arkansas Nuclear One Year: 2021 Page 62 of 65 Annual Radiological Environmental Operating Report Page 2 of 5 ERRATA Table 23, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Surface Water (pCi/l)

H-3 / 8 GS / 24 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-95 Nb-95 I-131 Cs-134 Cs-137 Ba-140 La-140 3000 15 30 15 15 30 30 15 15 15 18 60 15 707.0 (4 / 4)

[370 - 986]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD Station 8 (166°,

0.2 mi)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 707.0 (4 / 4)

[370 - 986]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

0 0

0 0

0 0

Plant: Arkansas Nuclear One Year: 2021 Page 63 of 65 Annual Radiological Environmental Operating Report Page 3 of 5 ERRATA Table 23, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Drinking Water (pCi/1)

GB / 8 I-131 / 8 H-3 / 8 GS / 8 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-95 Nb-95 Cs-134 Cs-137 Ba-140 La-140 4

1 2000 15 30 15 15 30 30 15 15 18 60 15 1.72 (4 / 4)

[1.57 - 1.88]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD Station 57 (208°, 19.5 mi)

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 2.07 (4 / 4)

[1.74 - 2.35]

N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 2.07 (4 / 4)

[1.74 - 2.35]

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

0 0

0 0

0 0

0

Plant: Arkansas Nuclear One Year: 2021 Page 64 of 65 Annual Radiological Environmental Operating Report Page 4 of 5 ERRATA Table 23, Radiological Environmental Monitoring Program Summary Sample Type (Units)

Type / Number of Analyses

[Note 1]

LLD [Note 2]

Indicator Locations Mean (F)[Note 3]

[Range]

Location [Note 4] [Highest Annual Mean]

Control Locations Mean (F)[Note 3] [Range]

Number of Non-Routine Results [Note 5]

Location Mean (F)[Note 3]

[Range]

Fish (pCi/kg)

GS / 2 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Cs-134 Cs-137 130 260 130 130 260 130 150

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD

< LLD 0

0 0

0 0

0 0

Food Products (pCi/kg)

I-131 / 6 GS / 6 Cs-134 Cs-137 60 60 80

< LLD

< LLD

< LLD N/A N/A N/A N/A N/A N/A N/A N/A N/A 0

0 0

LEGEND:

[Note 1] - GB = Gross beta; I-131 = Iodine-131; H-3 = Tritium; GS = Gamma scan.

[Note 2] - LLD = Required lower limit of detection based on ANO Units 1 and 2 ODCM Table 2.5-1.

[Note 3] - Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

[Note 4] - Locations are specified (1) by name and (2) degrees relative to reactor site.

Plant: Arkansas Nuclear One Year: 2021 Page 65 of 65 Annual Radiological Environmental Operating Report Page 5 of 5 ERRATA

[Note 5] - Non-routine results are those which exceed ten times the control station value. If no control station value is available, the result is considered non-routine if it exceeds ten times the preoperational value for the location.

[Note 6] - LLD is not defined in ANO Units 1 and 2 ODCM Table 2.5-1.