Text

Annual Radiological Environmental Operating Report for 2015
	ML16137A503
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/12/2016
From:	Pyle S; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	0CAN051604
	Download: ML16137A503 (49)
	v • d • e

~Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One OCAN051604 May 12, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Annual Radiological Environmental Operating Report for 2015 Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6

REFERENCE:

Entergy letter dated March 28, 2016, "Annual Radioactive Effluent Release Report for 2015" (OCAN041602)

Dear Sir or Madam:

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 2015 is enclosed.

This report fulfills the reporting requirements of the TSs referenced above.

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The radionuclides detected by the radi0logical environmental monitoring program during 2015 were significantly below the regulatory limits. The operation of the ANO station during 2015 had no harmful radiological effects nor resulted in any irreversible damage to the local environment.

Samples from the four REMP locations were also analyzed for gross beta in 2015. These data were also available for 2014, but were inadvertently overlooked when preparing the 2014 REMP report. For both years, although positive detections occurred, the samples were low in activity, occurred in both control and indicator locations, and were sporadic, showing no discernable trends of concern. Gross beta data for 2015 are included in Table 8.1 and 2014 data omitted from the 2014 report are included in Table 8.3 of the enclosed report.

Based on ANO's review, 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 all sampling locations and a corresponding table providing the respective distances and directions from the reactor building is included in the Offsite Dose Calculation Manual (ODCM) submitted as part of the referenced Annual Radioactive Effluent Release Report.

OCAN051604 Page 2 of 2 This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact me.

Sincerely,

Enclosure:

Annual Radiological Environmental Operating Report for 2015 cc: Mr. Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Stephen Koenick MS 0-8B1A One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot#30 Little Rock, AR 72205

Enclosure to OCAN051604 Annual Radiological Environmental Operating Report for 2015

Enclosure to OCAN051604 Page 1of46 Table of Contents Summary............................................................................................................................... 2 1.0 Introduction.................................................................................................................. 6 1.1 Radiological Environmental Monitoring Program ............................................... 6 1.2 Pathways Monitored.......................................................................................... 6 1.3 Land Use Census ..................................................................:........................... 6 2.0 Interpretation and Trends of Results............................................................................ 17 2.1 Air Particulate and Radioiodine Sample Results................................................ 17 2.2 Thermoluminescent Dosimetry (TLD) Sample Results ........ .............. ................ 17 2.3 Water Sample Results ..................... :................................................................. 17 ..)

2.4 Sediment Sample Results ...................................... :.......................................... 20 2.5 Milk Sample Results .............................................................:............................ 20 2.6 Fish Sample Results.......................................................................................... 20

2. 7 Food Product Sample Results........................................................................... 20 2.8 lnterlaboratory Comparison Results.................................................................. 21 2.9 Land Use Census Results................................................................................. 21 3.0 Radiological Environmental Monitoring Program Summary ......................................... 22 3.1 2015 Program Results Summary....................................................................... 22 Tables Table 1.1 Radiological Environmental Sampling Program ...................,............ ............. .. 8 Table 2.1 2015 Land Use Census .................................................................................. 22 Table 3.1 Radiological Environmental Monitoring Program Summary ............................ 23 Figures Figure 1-1 Sample Collection Sites - NEAR FIELD......................................................... 14 Figure 1-2 Sample Collection Sites- FAR FIELD............................................................ 15 Figure 1-3 Sample Collection Sites - SITE M~P......................... .. ............. ............... ....... 16 Attachments Summary of Monitoring Results.................................................................. 28 lnterlaboratory Comparison Program.......................................................... 42 Sediment Dose Calculations ............................................................... ....... 45

Enclosure to OCAN051604 Page 2 of 46 Summary The Annual Radiological Environmental Operating Report (AREOR) presents data obtained through analyses of environmental samples collected for Arkansas Nuclear One's (ANO's)

Radiological Environmental Monitoring Program (REMP) for the period January 1, 2015 through December 31, 2015. This report fulfills the requirements of ANO Unit 1 Technical Specification (TS} 5.6.2 and Unit 2 TS 6.6.2.

During 2015, as in previous years, ANO detected tritium attributable to plant operations at the discharge location (Station 8) where previously monitored liquid radioactive effluent from the plant is periodically discharged in accordance with the regulatory criteria established in the Offsite Dose Calculation Manual (ODCM). ANO personnel routinely monitor results from this area in order to note any trends. The review of results from this area indicates tritium levels in the surface water media continue to be below regulatory reporting and lower limit of detection (LLD) limits, and are consistent with concentrations that would typically be seen at this location as discussed in Section 2.3 of this AREOR Gross beta concentrations at the Station 14 (City of Russellville) indicator drinking water location continue to remain consistent with previous operational measurements and similar to the levels detected at the Station 57 (City of Danville) control drinking water location. One of .

five samples collected from Station 57 showed detectable levels,of gross beta, but levels were below the LLD limits (see Section 2.3 for details}. Similarly, slightly elevated levels of gross beta in groundwater samples have been observed. Data from 2014 and 2015 are included in this report. However, even though positive detections occurred, the samples were low in activity, occurred in both control and indicator locations, and were sporadic, showing no discernable trends of concern.

Radiological Environmental Monitoring Program ANO established the REMP prior to the station 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 radiation directly. ANO also samples milk, if milk-producing animals are present commercially within five miles of the plant, but no milk-producing animals were present for sampling in 2015.

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 2015, ANO personnel collected environmental samples for radiological analysis. Personnel compared results of indicator locations with control locations and previous studies and concluded that overall, no significant relationship exists between ANO operation and effect on the plant environs. The review of 2015 data, in most cases, showed undetectable radiation levels in the environment and in all instances, no definable trends related to significant pathways associated with ANO.

Enclosure to OCAN051604 Page 3 of 46 Harmful Effects or Irreversible Damage The REMP monitoring did not detect any harmful effects or evidence of irreversible damage in 2015. Therefore, no analysis or planned course of action to alleviate problems was necessary.

Reporting Levels ANO's review indicates that no samples equaled or exceeded reporting levels for radioactivity concentration in environmental samples due to ANO effluents, as outlined in ODCM Table 2.5-2, when averaged over any calendar quarter. Therefore, 2015 results did not trigger any Radiological Monitori.ng Program special reports.

Radioactivity Not Attributable to ANO The ANO REMP has detected radioactivity attributable to other sources. These include the 25th Chinese nuclear test explosion in 1980 and the radioactivity plume release due to reactor core degradation at the Chernobyl Nuclear Power Plant in 1986. Prior to 1981, the ANO REMP detected radioactivity resulting from nuclear weapons testing, with Cesium-137 continuing to be periodically detected although none was detected in 2015. In 2011, ANO detected 1-131 radioactivity attributed to the Fukushima Daiichi Nuclear Power Plant accident (March 11, 2011 ).

Comparison to Federal and State Programs 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 (NRG) Thermoluminescent Dosimeter (TLD) Direct Radiation Monitoring Network and the Arkansas Department of Health (ADH).

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

The ADH 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.

Sample Deviations

Milk The REMP did not include milk sampling within five miles of ANO in 2015 due to unavailability~ The ODCM requires collection of milk samples, if available commercially within five (5) miles of the plant. ANO personnel collected vegetation samples to monitor the ingestion pathway, as specified in the ODCM, because of milk unavailability.

Lower Levels of Detection (LLDs) during this reporting period were within the acceptable limits required by Table 2.5-1 of the ODCM.

Enclosure to OCAN051604 Page 4 of 46

Air Samples Listed below are air sampler deviations that occurred during 2015 due to electrical power outages and equipment failure. These deviations did not result in exceeding LLD values specified in the ODCM. As described in ODCM, B 2.5.1, Actions A.1 and A.2, deviations are permitted from the required sampling schedule due to malfunction of sampling equipment and other legitimate reasons.

Station(s) Sampling Period Comment As documented on 03/10/2015, the sample pump was not running. The sample pump 7 02/24/2015- 03/10/2015 was replaced and sample flow was verified to be 30 liters per minute as required by OP-1608.005 (CR-ANO-C-2015-00676).

As documented on 04/08/2015, totalizer run time for the listed sampling period was approximately three hours less than calculated run time. The lower reading was attributed to 2,56 03/24/2015 - 04/07/2015 the loss of power from the London line on 03/30/2015 which affected the west side of ANO. The totalizer was verified to work as designed (CR-ANO-C-2015-01030).

As documented on 05/26/2015, the equipment at these air stations was out of service due to the power outage that affected ANO on the evening of 05/25/2015. Power was restored 1, 2, 56 05/19/2015 - 06/02/2015 on 5/26/15; the stations were sampled at the normal bi-weekly interval and the installed totalizers recorded the appropriate power I run times (CR-ANO-C~2015-01703).

Surface Water Station(s) Sampling Period Comment As documented on 05/26/2015, the discharge canal composite sampler was out of service due to the power outage that affected ANO on 8 04/30/2015- 05/31/2015 the evening of 05/25/2015. Power was

- restored on 05/26/2015 and discharge canal samples were collected as scheduled on 05/31/2015 (CR-ANO-C-2015-01703).

Enclosure to OCAN051604 Page 5 of 46

Groundwater samples Gross Beta data for 2014 groundwater samples inadvertently not included in 2014 AREOR, but are included in this report (CR~ANO-C-2016-01694). See Section 2.3 for more details.

Groundwater samples collected quarterly for 2014-2015, but not always every 92 +/-23 days as required by the ODCM (CR-ANO-C-2016-01981). See Section 2.3 for more details.

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Missed Samples Third quarter environmental TLD Station #149 missing (CR-ANO-C-2015-04157)

Fourth quarter environmental TLD Stations #148 and #149 missing (CR-ANO-C-2016-00135)

Unavailable Results No results on air volume sampled for the period 02/24/2015 - 03/10/2015 at Station #7 are available due to pump failure (CR-ANO-C-2015-00676).

Program Modifications The following changes were made to OP-1608.005, "Radiological Environmental Monitoring Program (REMP)" in 2015. These changes were prompted by the condition documented in CR-ANO-C-2015-0500 which resulted in the issuance of Revision 42 to OP-1608.005.

Added reference to CR-ANO-C-2015-00500, CA-02, for inclusion of information for the counting and shipping of REMP samples.

Added precaution step to reference OP-1052.023 for the handling of materials with trace levels of tritium.

Added notes and guidance from OP-1052.023, Rev. 019, for the counting and shipping of REMP samples.

Attachments contains results of air, TLD, water, sediment, fish, and food product samples collected in 2015. TLDs were analyzed by Environmental Dosimetry Company (EDC). All remaining samples were analyzed by Teledyne Brown Engineering (TSE). contains TBE's participation in the inter-laboratory comparison program during 2015. contains dose calculations performed for sediment using a generalized equation from Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Efflu~nts for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

Revision 1.

Enclosure to OCAN051604 Page 6 of 46 1.0 Introduction 1.1 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.

1.2 Pathways Monitored The airborne, direct radiation, waterborne and ingestion pathways are monitored as required by the ODCM. A description of the ANO REMP used to monitor the exposure pathways is described in Table 1.1 and shown in Figures 1-1, 1-2 and 1-3.

Section 2.0 of this report provides a discussion of 2015 sampling results and Section 3.0 provides a summary of results for the monitored exposure pathways.

1.3 Land Use Census ANO personnel conduct the land use census every 24 months as required by ODCM Surveillance (S) 2.5.2.1. The land use census was conducted in 2015. This census serves to identify changes in land use within five miles of ANO that would require modifications to the REMP or ODCM. The most important concerns during this census are to determine location in each sector of the nearest:

1) Residence

2) Animal milked for human consumption

3) Garden of greater than 500 square feet producing fresh leafy (broadleaf) vegetables*

ANO personnel did not perform a garden census since an ODCM Limitation (L) 2.5.2 Note allows the routine sampling of broadleaf vegetation in the highest D/Q sector near the site boundary in lieu of the garden census.

Enclosure to OCAN051604 Page 7 of 46

The method used by ANO personnel for conducting the land use census was as follows:

ANO personnel conducted door-to-door (drive by) field surveys in order to locate the nearest resident in each meteorological sector.

Consultation with local agricultural authorities was used to identify commercial milk providers within five-miles of the Unit 1 reactor building.

I

As a result of these surveys, the following information was obtained in each meteorological sector:

1) Nearest permanent residence

2) Nearest milking animal

ANO personnel identify locations on the map, measure distances to ANO (or use a GPS system) and record results.

Locations, if any, are identified which yield a calculated dose or dose commitments greater than those currently calculated in the ODCM.

- ANO personnel compare results to previous census.

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I

Enclosure to OCAN051604 Page 8 of 46 TABLE 1.1 RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Sampling and. Collection I Type and Frequency Of Requirement Pathway. Distance and Direction Frequency Analyses Station 2 (243° - 0.5 miles) . South Radioiodine and Particulates . of the sewage treatment plant.

3 samples close to the Site Boundary, in Station 56 (264° - 0.4 miles) -West (or near) different sectors with the end of the sewage treatment plant.

highest calculated annual. average ground level D/Q. Statio.n 1 (88° - 0.5 miles) - Near

../ the meteorology tower . Radioiodine Canister -

Analyze at least once per Continuous operation of 14 days for 1-131.

Radioiodine and Particulates Airborne Station 6 (111° - 6.8 miles) - sampler with sample collection 1 sample from the vicinity of a Entergy local office in Russellville as required by dust loading but Particulate Sampler -

community having the highest calculated (305 South Knoxville Avenue). at least once per 14 days. Analyze for gross beta annual average ground level D/Q. radioactivity following filter change.

Radioiodine and Particulates Station 7 (210° - 19.0 miles) -

1 sample from a control location Entergy Supply Yard on Highway 1O 15 - 30 km (10- 20 miles) distance. in Danville.

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

Station 2 (243° - 0.5 miles) - South Thermoluminescent dosimet!Y (TLDs} of the sewage treatment plant.

Direct 16 inner ring stations with two or more Station 3 (5° - 0.7 miles)-West of Gamma Dose - Once per Radiation Once per 92 days.

dosimeters in each meteorological sector ANO Gate #2 on Highway 333 92 days.

in the general area of the site boundary. (approximately 0.35 miles)

.)

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

Enclosure to OCAN051604 Page 9 of 46 TABLE 1.1 (continued)

RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Sampling and Collection Type and Frequency Of Requirement Pathway Distance and Direction Frequency Analyses 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 TLDs pole on the left.

Direct 16 inner ring stations with two or more Gamma Dose - Once per Station 145 (28° - 0.6 miles) - Near Once per 92 days.

Radiation dosimeters in each meteorological sector 92 days.

in the general area of the site boundary west entrance to the RERTC on a utility pole.

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 sign post.

Enclosure to OCAN051604

Page 10 of 46 TABLE 1.1 (continued)

RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Sampling and Collection Type and Frequency Of Requirement Pathway Distance and Direction Frequency Analyses Station 149 (156° - 0.5 miles)- On a utility pole on the south side of May Road.

Station 150 (205° - 0.6 miles) -

TLDs North side of May Road on a utility 16 inner ring stations with two or more pole past the Mccurley Place turn.

dosimeters in each meteorological sector Station 151 (225° - 0.4 miles)-

in the.general area of the Site Boundary. 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 sign post.

Direct Gamma Dose - Once per Radiation Station 6 (111° - 6.8 miles) - Once per 92 days.

92 days.

Entergy local office in Russellville (305 South Knoxville Avenue).

Station 7 (210° - 19.0 miles) -

TLDs Entergy Supply Yard on Highway 10 8 stations with two or more dosimeters in in Danville.

special interest areas such as population Station 111 (120° - 2.0 miles) -

centers, nearby residences, schools, and Marina Road on a utility pole on the in 1 - 2 areas to serve as control left just prior to curve.

locations. -

Station 116 (318° - 1.8 miles) -

Highway 333 and Highway 64 in London on a utility pole north of the .

railroad tracks.

Enclosure to OCAN051604 Page 11 of 46 TABLE 1.1 (continued)

RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Sampling and Collection Requirement Type and Frequency Of Analyses Pathway Distance and Direction Frequency 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) -

TLDs Arkansas Tech Campus on a utility 8 stations with two or more dosimeters in pole across from Paine Hall.

Direct special interest areas such as population Station 137 (151° - 8.2 miles) - On Once per 92 days. Gamma Dose - Once per 92 days.

Radiation centers, nearby residences, schools, and a speed limit sign on the right in in 1 - 2 areas to serve as control front of the Morris R. Moore locations.

Arkansas National Guard Armory.

Station 153 (304° - 9.2 miles) -

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

Surface Water Station 8 (166° - 0.2 miles) - Plant 1 indicator location (influenced by plant discharge canal. Gamma isotopic and tritium discharge) Once per 92 days.

Station 1O (95° - 0.5 miles) - Plant analyses once per 92 days.

1 control location (uninfluenced by plant intake canal.

discharge)

Waterborne Station 14 (70° - 5.1 miles) -

Drinking Water Russellville city water system from 1 indicator location (influenced by plant the Illinois Bayou. 1-131, gross beta, gamma isotopic discharge) Once per 92 days. and tritium analyses once per Station 57 (208°

19.5 miles) - 92 days.

1 control location (uninfluenced by plant Danville public water supply discharge) treatment on Fifth Street.

Enclosure to OCAN051604 Page 12 of 46

TABLE 1.1 (continued}

RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Sampling and Collection Requirement Type and Frequency Of Analyses Pathway Distance and Direction Frequency Sediment Station 8 (243° - 0.9 miles) - Plant discharge canal.

1 indicator location (influenced by plant Station 16 (287° - 5.5 miles) - Gamma isotopic analysis once per Waterborne discharge) Once per 365 days.

Panther Bay on south side of 365 days.

1 control location (uninfluenced by plant Arkansas River across from mouth discharge) ,

of Piney Creek.

Milk 1 indicator sample location within five-Currently, no available milking* Gamma isotopic and 1-131 mile distance if commercially available. Once per 92 days.

animals within 5 mile~ of ANO. analyses once per 92 days.

1 control sample location at a distance of

>five-miles when an indicator exists.

Fish Station 8 (212° - 0.5 miles) - Plant 1 sample of commercially and/or discharge canal.

recreationally important species in Station 16 (287° - 5.5 miles) - Gamma isotopic on edible portions Or:ice per 365 days.

vicinity of plant discharge. Panther Bay on south side of once per 365 days.

1 sample of same species in area not Arkansas River across from mouth Ingestion influenced by plant discharge. of Piney Creek.

Food Products 1 sample of broadleaf (edibie or non-edible) near the site boundary from one Station 13 (273° - 0.5 miles) - West of the highest anticipated annual average from ANO toward Gate 4 onto ground level D/Q sectors, if milk Flatwood Road. Gamma. isotopic and 1-131 Three per 365 days.

sampling is not performed. analyses three times per 365 days Station 55 (208° -16.5 miles)-

1 sample location of broadleaf vegetation Intersection of Highway 27 and 154.

(edible o'r non-edible) from a control location 15 - 30 km (10- 20 miles) distant, if milk sampling is not performed. -

Enclosure to OCAN051604 Page 13 of 46 TABLE 1.1 (continued)

RADIOLOGICAL ENVIRONMENT SAMPLING PROGRAM Exposure Sample Point Description, Distance and Sampling and Collection Type and Frequency Of Requirement Pathway Direction Frequency Analyses Station 58 (GWM-1, 22° - 0.3 miles)- Once per 92 days Control, Tritium, Gross Beta North of Protected Area on Owner Control and Gamma Isotopic, once per Area (OCA). West of Security North Check 92 days.

Point, east side of access road.

2 sample locations of Groundwater from Station 62 (GWM-101, 34° - 0.5 miles)- Once per 92 days Control, Tritium, Gross Beta a control location up gradient from the North of Protected Area on OCA. East of and Gamma Isotopic, once per protected area outside receiving building. 92 days.

Ground water 2 sample locations of Groundwater from Station 63 (GWM-103, 206° - 0.1 miles)- Once per 92 days Indicator, Tritium, Gross Beta indicator locations down gradient from South of Protected area on OCA. North- and Gamma Isotopic, once per the protected area. east of Stator Rewind Bldg. near wood line. 92 days.

Station 64 (GWM-13, 112° - 0.1 miles)- Once per 92 days Indicator, Tritium, Gross Beta South of Oily W?ter Separator facility, and Gamma Isotopic, once per northwest corner of U-2 Intake Structure. 92.days.

Inside Protected area.

Enclosure to OCAN051604 Page 14 of 46 FIGURE 1-1 SAMPLE COLLECTION SITES - NEAR FIELD

Enclosure to OCAN051604 Page 15 of 46 FIGURE 1-2 SAMPLE COLLECTION SITES - FAR FIELD 1

/'

5 DANVILLE INSET Arkansas Nuclear One REMP Sample Locations (Far Field)

Enclosure to OCAN051604 Page 16 of 46 FIGURE 1-3 SAMPLE COLLECTION SITES - SITE MAP Switch.

Yard.

STR-1 Arkansas Nuclear One REM P Sample ,

Locations Site Map

Enclosure to OCAN051604 Page 17 of 46 2.0 Interpretation and Trends of Results 2.1 Air Particulate and Radioiodine Sample Results The REMP has detected radioactivity in the airborne pathway attributable to other sources.

These include the 25th Chinese nuclear test explosion in 1980, t.he radioactive plume release due to reactor core degradation at Chernobyl Nuclear Power Plant in 1986 and the Fukushima Daiichi Nuclear Power Plant accident (Mach 11, 2011 ). '

As in past years, there were no other detections of 1-131. The mean indicator gross beta air particulate concentration for 2015 was less than values for 2013, 2014, the preoperational period and the mean maximum for the 2000- 2012 time frame. Lastly, the value was equal to the mean minimum value for the 2000 - 2012 time frame. Results are reported as annual average picocuries per cubic meter (pCi/m 3 ).

Monitoring Period Result 2000-2012 (Minimum Value) 0.020 2015 Value 0.020 2000-2012 (Maximum Value) 0.032 2014 Value 0.035 2013 Value 0.043 Preoperational 0.050 In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. Table 3.1, which includes gross beta concentrations, 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.

2.2 Thermoluminescent Dosimetry (TLD) Sample Results 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. ANO's comparison of the inner ring and special interest area TLD results to the control, as seen in Table 3.1, 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 7.63 millirem (mrem) shown in Table 3.1 for 2015 is within the historical bounds of 2000 - 2013 annual average results, which have ranged from 6.6 to 8.9 mrem. Furthermore, the 2015 inner ring average is less than that for 2014, which was 7.83 mrem. Overall, ANO concluded that the ambient radiation levels are not being affected by plant operations.

2.3 Water Sample Results Analytical results for 2015 drinking water and ground water samples were similar to those reported in previous years. Gamma radionuclides analytical results for 2015 surface water samples were similar to those reported in previous years. Tritium detection in ANO surface water indicator samples continues, but at levels below those experienced in 2013 and below the ODCM-required LLD. These results are further explained below.

Enclosure to OCAN051604 Page 18 of 46 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 2015, at levels considerably lower than the ODCM-required LLD of 3000 pCi/I. Results are reported as annual average pCi/1; note, however,* the footnote for the 2015 value.

Monitoring Period Result 2000-2013 (Minimum Value) ' 277.1 2014 Value 554.5 2015 Value* 721.0 2000-2013 (Maximum Value) 1003.5 Preoperational 200.0

Reflects mean of values above Minimum Detectable Concentration (MDC) recorded in the second, third, and fourth quarters; value for first quarter was< MDC. In 2014, values for all four quarters was> MDC.

ANO personnel have noted no definable increasing trends associated with the tritium levels at the discharge location. Levels detected during 2015 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 2015 and levels of radionuclides remain similar to those obtained in previous operational years.

Drinking water samples were collected from two locations (indicator and control). Five (5) sets of samples were collected in 2015 even though the requirement was for quarterly sampling; five set of samples were collected to assure compliance with the 92-day frequency requirement in the ODCM. 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, 1-131, gamma radionuclides and tritium. Gross beta radionuclides, 1-131, gamma radionuclides and tritium concentrations were below the LLD limits at the indicator and control locations, which is consistent with 2013, 2014 and comparable to the 2000 - 2012 preoperational and operational years as shown below. -Results from 2015 are summarized in Table 3.1. Results are reported as annual average pCi/I.

Radionuclide 2015 2014 2013 2000-2012 Preoperational Gross Beta <LLD* <LLD <LLD 2.59 2.0 lodine-131 <LLD <LLD <LLD <LLD <LLD Gamma <LLD <LLD <LLD <LLD <LLD Tritium <LLD <LLD <LLD <LLD 200.0

For the control sample collected 1/15/15, gross beta was 3.16 pCi/L which is >MDC but <LLD; documented via CR-ANO-C-2015-00351.

Enclosure to OCAN051604 Page 19 of 46 ANO personnel have noted no definable trends associated with drinking water results at the indicator location. Therefore, the operation of ANO had no definable impact on this waterborne pathway during 2015 and levels of radionuclides remain similar to those obtained in previous operational years.

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 d~tected to determine whether changes should be made to the scope of analysis 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 actions/remediation is required.

Groundwater samples from the four REMP locations were analyzed for tritium and gamma radionuclides. Listed below is a comparison of 2015 indicator results to 2014 indicator results and to past operational years. Results are reported as annual average pCi/I. Tritium and gamma concentrations were below the LLD limits at all four REMP locations. Therefore, ANO operations had no significant impact on the environment or public by this waterborne pathway.

Groundwater data are captured in Tables 8.1 and 8.2.

Radionuclide 2015 2014 ' 2006-)2013 lodine-131 <LLD <LLD <LLD Gamma <LLD <LLD <LLD Tritium <LLD <LLD <LLD Samples from the four REMP locations were also analyzed for gross beta in 2015: These data were also available for 2014, but were inadvertently overlooked when preparing the 2014 REMP report; this omission was documented via CR-ANO-C-2016-01694. For both years, although positive detections occurred, the samples were low in activity, occurred in both control and indicator locations, and were sporadic, showing no discernable trends of concern. Gross beta data for 2015 are included in Table 8.1 and 2014 data omitted from the 2014 report are included in Table 8.3.

Based on investigations to determine the Extent of Condition for the above cited CR-ANO-C-2016-01694, another condition relative to groundwater sampling was discovered and documented in CR-ANO-C-2016-01981. The condition documented in CR-ANO-C-2016-01981 relates to complying with the sampling frequency required by ANO's ODCM. The ODCM

Erclosure to OCAN051604 Page 20 of 46 requires groundwater sample collection every 92 days with an allowed 25% extension (23 days) thus time allowed between groundwater sample collections cannot exceed 115 days. As documented in CR-ANO-C-2016-01981, three instances were found for groundwater samples collected in the 2014 - 2016 time period where the time between sample collections was greater than 115 days. For clarification, no samples were missed and groundwater samples were collected in each quarter of the years cited. The condition is that the sample frequency was not maintained. Peculiar to groundwater samples is the fact that unlike other samples collected in the REMP, groundwater sampling is riot scheduled and tracked using a surveillance work order (SWO). Using an SWO assures affected parties are aware of the need to collect samples by a specified date and the structure of the SWO program assures this task is scheduled on a recurring basis.

2.4 Sediment Sample Results Sediment samples were collected from two locations in 2015 and analyzed for gamma radionuclides. Listed below is a comparison of 2015 indicator results to 2013, 2014, and the 2000 - 2012 operational years. ANO operations had no significant impact oli the environment or public by this waterborne pathway. Results are reported as picocuries per kilogram (pCi/kg).

Monitoring Period Result 2000-2012 (Minimum Value) 41.79 2013 Value <LLD 2014 Value <LLD 2015 Value <LLD 2000 ~ 2012 (Maximum Value) 1170.0 Since reporting levels for radionuclides in sediment have not been established, an evaluation of potential dose to the public from this media was performed as shown in Attachment 3.

2.5 Milk Sample Results Milk samples were not collected during 2015 due to the unavailability of indicator locations within five-miles of ANO.

2.6 Fish Sample Results Fish samples were collected from two locations and analyzed for gamma radionuclides. In 2015, gamma radionuclides were below detectable limits which are consistent with the preoperational monitoring period and operc,itional results since 1997. Therefore, based on these measurements, ANQ operations had no significant radiological impact upon the environment or public by this ingestion pathway.

2.7 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.

Enclosure to OCAN051604 Page 21of46 In 2015, food product samples were collected from two locations and analyzed for 1-131 and

gamma radionuclides. The 2015 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.

2.8 lnterlaboratory Comparison Results Teledyne Brown Engineering analyzed interlaboratory comparison samples to fulfill the requirements of ODCM Section 2.5.3. Attachment 2 contains these results.

2.9 Land Use Census Results The land use census performed in 2015 did not identify any new locations that yielded a

calculated dose or dose commitment greater than those currently calculated (see Table 2.1 ).

Also, the land use census identified no milk-producing animals within a five-mile radius of the plant site. ANO personnel chose not to perform a garden census in 2015, but instead to sample broadleaf vegetation which is allowed by ODCM Section L 2.5.2. As allowed by NRG Regulatory Guide 1.21, Rev. 2, Section 3.2, broadleaf vegetation sampling in the meteorological sector (Sector 13) with a D/Q value within 10% of tre sector with the highest D/Q (Sector 12) was performed.

Enclosure to OCAN051604 Page 22 of 46 TABLE 2.1 2015LANDUSECENSUS Nearest Residence Within Five Miles Direction Sector Distance (miles)

N 1 0.9 NNE 2 1.3 NE 3 0.9 ENE 4 0.8 E 5 0.8 ESE 6 0.8 SE 7 0.8

' SSE 8 0.8 s 9 0.8 SSW 10 0.7 SW 11 2.8

WSW 12 0.7 w 13 0.8 WNW 14 0.8 NW 15 1.0 NNW 16 0.9 3.0 Radiological Environmental Monitoring Program Summary 3.1 2014 Program Results Summary Table 3.1 summarizes the 2015 REMP results.

Enclosure to OCAN051604 Page 23 of 46 TABLE 3.1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

Name of Facility: ANO - Units 1 and 2 Docket No: 50-313 and 50-368.

Location of Facility: Pope County. Arkansas Reporting Period: January - December 2015 Type/ Indicator Location with Highest Annual Mean Control Number of Sample Type LL Db Number of Locations Mean Locations Mean Non-Routine (Units) ~

Locationd Mean (F)c [Range] Resultse Analysesa (F)c [Range] (Ft [Range]

Air Particulates 0.0198 (81 I 81) Station 1 0.0209 (27 I 27) 0.0198 (54 I 54)

GB I 135 0.01 0 (pCi/m3) [0.009 - 0.033] (88°, 0.5 mi) [0.011 - 0.032] [0.009 - 0.035]

Airborne Iodine 1-131I135 0.07 <LLD N/A N/A <LLD 0 (pCi/ m 3)

(f)

Inner Ring TLDs Gamma/61 7.63 (61 I 64) Station 56 9.3 (4 I 4) N/A 0 (mR/Qtr) [5.1 - 9.9] (264°, 0.4 mi) [8.9-9.9]

Special Interest Gamma/28 (f) 6.92 (28 I 28) Station 116 8.7 (4 I 4) NIA 0 TLDs (mR/Qtr) [4.6- 9.8] (318°, 1.8 mi) [8.2-9.8]

Control TLD Gamma/4 (f)

N/A N/A N/A 6.1 (4/4) 0 (mR/Qtr) [5.7 - 6.5]

Enclosure to OCAN051604

. Page 24 of 46 TABLE 3.1 (continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

Type/ Indicator Location with Highest Annual Mean Control Number of Sample Type LLDb Number of Locations Mean Locations Mean Non-Routine (Units) Locationd Mean (F)c [Range]

Analyses 8 (Ft [Range] (Ft [Range] Results0 H-3 / 8 3000 721 (3* I 4) Station 8 721 (3* I 4) <LLD 0

[333- 988] (166°, 0.2 mi) [333-988]

GS/24 Mn-54 15 <LLD N/A N/A <LLD 0 Fe-59 30 <LLD N/A N/A <LLD 0 Co-58 15 <LLD N/A N/A <LLD 0 Co-60 15 <LLD N/A N/A <LLD 0 Surface Water Zn-65 30 <LLD N/A N/A <LLD 0 (pCi/I)

Zr-95 30 <LLD N/A N/A <LLD 0 Nb-95 15 <LLD N/A N/A <LLD 0 1-131 15 <LLD N/A N/A <LLD 0 Cs-134 15 <LLD N/A N/A <LLD 0 Cs-137 18 <LLD N/A N/A <LLD 0 Ba-140 60 <LLD N/A N/A <LLD 0 La-140 15 <LLD N/A N/A <LLD -0

Positive tritium results (>MDC).

Enclosure to OCAN051604 Page 25 of 46 TABLE 3.1 (continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

Type/ Indicator Location with Highest Annual Mean Control Number of Sample Type LLDb Number of Locations Mean Locations Mean Non-Routine (Units) Locationd Mean (Ft [Range]

Analysesa (F)c [Range] (F)c [Range] Resultse GB/ 10 4 <LLD N/A N/A <LLD 09 1-131 /10 1 <LLD N/A N/A <LLD 0 H-3I10 2000 <LLD N/A N/A <LLD 0 GS/ 10 Mn-54 15 <LLD N/A N/A <LLD 0 Drinking Water Fe-59 30 <LLD N/A N/A <LLD 0 (pCi/1) Co-58 15 <LLD N/A N/A <LLD 0 Co-60 15 <LLD N/A

~

N/A <LLD 0 Zn-65 30 <LLD NIA N/A <LLD 0 Zr-95 30 <LLD N/A N/A <LLD 0 Nb-95 15 <LLD N/A N/A <LLD 0 Cs-134 15 <LLD N/A N/A <LLD 0 Cs-137 18 <LLD N/A N/A <LLD 0 Ba-140 60 <LLD N/A N/A <LLD 0 La-140 15 <LLD N/A N/A <LLD 0 Bottom GS/2 Sediment Cs-134 150 <LLD N/A <LLD <LLD 0 (pCi/kg) Cs-137 180 <LLD N/A <LLD <LLD 0

Positive GB results (>MDC).

Enclosure to OCAN051604 Page 26 of 46 TABLE 3.1 (continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

Indicator Location with Highest Annual Control Type/ Number of Sample Type LL Db Locations Mean Locations Number of Non-Routine (Units) Mean (F)c Mean (F)c Analysesa Locationd Mean (Ft [Range] Results 0

[Range] [Range]

GB/ 16 4 4.4 (3* / 8) Station 64 4.4 (3* / 4) <LLD 0

[3.65 - 5.24] (112°, 0.1 mi) [3.65 - 5.24]

1-131/16 15 <LLD N/A N/A <LLD 0 H-3I16 3000 <LLD N/A NIA <LLD 0 GS/ 16 Mn-54 15 <LLD N/A NIA <LLD 0 Groundwater Fe-59 30 <LLD N/A N/A <LLD 0 (pCi/1) Co-58 15 <LLD N/A NIA <LLD 0 Co-60 15 <LLD N/A NIA <LLD 0 Zn-65 30 <LLD N/A N/A <LLD 0 Zr-95 30 <LLD N/A NIA <LLD 0 Nb-95 15 <LLD N/A N/A <LLD 0 Cs-134 15 <LLD N/A NIA <LLD 0 Cs-137 18 <LLD N/A NIA <LLD 0 Ba-140 60 <LLD N/A NIA <LLD 0 La-140 15 <LLD N/A NIA <LLD 0

Positive GB results (> MDC).

Enclosure to OCAN051604 Page 27 of 46 TABLE 3.1 (continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

___/

Type/ Indicator Location with Highest Annual Mean Control Number of Sample Type LL Db Number of Locations Mean Locations Mean Non-Routine (Units) Locationd Mean (F)c [Range]

Analyses8 (F)c [Range] (F)c [Range] Resultse GS/2

-~ Mn-54 130 <LLD N/A N/A <LLD 0 Fe-59 260 <LLD N/A N/A <LLD 0 Co-58 130 <LLD N/A N/A <LLD 0 Fish (pCi/kg)

Co-60 130 <LLD N/A N/A <LLD 0 Zn-65 260 <LLD N/A N/A <LLD 0 Cs-134 130 <LLD N/A N/A <LLD 0 Cs-137 150 <LLD N/A N/A <LLD 0 1-131 I 6 60 <LLD N/A N/A N/A 0 Food Products (pCi/kg)

GS/6 Cs-134 60 <LLD N/A N/A N/A 0 Cs-137 80 <LLD N/A N/A N/A 0 a GB= Gross beta; 1-131 = lodine-131; H-3 =Tritium; GS= Gamma scan.

b LLD= Require~ lower limit of detection based on ANO Units 1 and 2 ODCM Table 2.5-1.

c Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

d Locations are specified (1) by name and (2) degrees relative to reactor site.

e 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.

1 LLD is not defined in ANO Units 1 and 2 ODCM Table 2.5-1.

9 Control sample on 1/15/15 was >Minimum Detectable Concentration (MDC) but< LLD. Control samples for remaining 2015 dates were< MDC and< LLD.

Enclosure to OCAN051604 Page 28 of 46 ATTACHMENT 1

SUMMARY

OF MONITORING RESULTS

Enclosure to OCAN051604 Page 29 of 46 Table of Contents Table 1.1 Air Particulate ............ .... ... .. .......... .... ... .. .. ..... ............... ..... .............................. 30 Table 1.2 Radioiodine Cartridge***********************************************************************'-************ 31 Table2.1 Thermoluminescent Dosimeters (Inner Ring).................................................. 32 Table 2.2 Thermoluminescent Dosimeters (Special Interest Areas)................................ 33 Table 3.1 Surface Water (Gamma Isotopic).................................................................... 34 Table 3.2 Surface Water (Tritium) ............................................... ........ ........................... 35 Table 4.1 Drinking Water (Gross beta, 1-131 and Gamma Isotopic)................................ 36 Table 4.2 Drinking Water (Tritium) .................................. .,............................................... 37 Table 5.1 Sediment .*.. -. ............................ ........ ..... ................ ........ ............... .. .. ..... ...... .... 37 Table 6.1 Fish................................................................................................................ 37 Table 7.1 Food Products ........ .. .............. ..... ...... .. .... ....... ........... ... ... ........ .. ............. .. ..... . 38 Table 8.1 Groundwater Data (Gross Beta and Gamma Isotopic).................................... 39 Table 8.2 Groundwater Data (Tritium)............................................................................ 40 Table 8.3 Groundwater Data (Gross Beta for 2014) ........................................................... 41

Enclosure to OCAN051604 Page 30 of 46 Table 1.1 Sample Type: Air Particulate Analysis: Gross Beta Units: QCi/m 3 Station 1* Station 2 Station 56 Station 6 Station 7 Start Date End Date (Indicator) (Indicator) (Indicator) (Control) (Control)

Reguired LLD + 0.01 0.01 . 0.01 0.01 0.01 12/30/2014 01/13/2015 0.024 0.026 0.023 0.021 0.019 01/13/2015 01/27/2015 0.020 0.022 0.018 0.022 0.013 01/27/2015 02/10/2015 0.022 0.018 0.017 0.023 0.020 02/10/2015 02/24/2015 . 0.025 0.025 0.020 0.021 0.024 02/24/2015 03/10/201.5 0.019 0.018 0.015 0.018 0.014 03/10/2015 03/24/2015 0.015 0.016 0.012 0.014 0.015 03/24/2015 04/07/2015 0.018 0.015 0.019 0.014 0.016 04/07/2015 04/21/2015 0.016 0.016 0.014 0.014 0.014 04/21/2015 05/05/2015 0.016 0.016 0.014 0.015 0.017 05/05/2015 05/19/2015 0.011 0.013 0.013 0.013 0.012 05/19/2015 06/02/2015 0.012 0.009. 0.011 0.010 0.009 06/02/2015 06/16/2015 0.025 0.025 0.019 0.022, 0.021 06/16/2015 06/30/2015 0.032 0.033 0.032 0.035 0.033 06/30/2015 07/14/2015 0.018 0.017 0.014 0.014 0.016 07/14/2015 07/28/2015 0.019 0.018 0.017 0.017 0.015 07/28/2015 08/11/2015 0.022 0.021 0.018 0.022 0.023 08/11/2015 08/25/2015 0.023 0.024 0.019 0.018 0.022 08/25/2015 09/08/2015 0.031 0.030 0.027 0.034 0.028 09/08/2015 09/22/2015 0.018 0.019 0.019 0.021 0.018 09/22/2015 10/06/2015 0.023 0.021 0.020 0.022 0.024 10/06/2015 10/20/2015 0.022 0.021 0.020 0.022 0.021 10/20/2015 11/03/2015 0.021 0.021 0.018 0.022 0.019 11/03/2015 11/17/2015 0.025 0.018 0.022 0.023 0.023 11/17/2015 12/01/2015 0.013 0.013 0.012 0.013 0.012 12/01/2015 12/15/2015 0.031 0.027 0.027 0.029 0.035 12/15/2015 12/29/2015 0.021 0.022 0.017 0.024 0.020 12/29/2015 01/12/2016 0.023 0.021 0.020 0.019 0.022

Station with highest annual mean.

Enclosure to OCAN051604 Page 31of46 Table 1.2 Sample Type: Radioiodine Cartridge Analysis: lodine-131 Units: QCi/m 3 Station 1 Station 2 Station 56 Station 6 Station 7 Start Date End Date (Indicator) (Indicator) * (Indicator) (Control) (Control)

Reguired LLD + 0.07 0.07 0.07 0.07 0.07 12/30/2014 01/13/2015 < 0.019 < 0.034 < 0.034 < 0.034 < 0.034 01/13/2015 01/27/2015 < 0.025 < 0.064 < 0.064 < 0.064 < 0.064 01/27/2015 02/10/2015 < 0.061 < 0.061 < 0.026 < 0.062 < 0.062 02/10/2015 02/24/2015 < 0.024 < 0.046 < 0.046 < 0.046 < 0.046 02/24/2015 03/10/2015 < 0.011 < 0.020 < 0.020 < 0.020 < 0.020 03/10/2015 03/24/2015 <0.014 <0.034 <0.034 <0.034 <0.034 03/24/2015 04/07/2015 < 0.013 < 0.035 < 0.035 < 0.035 < 0.034 04/07/2015 - 04/21/2015 < 0.068 < 0.068 < 0.029 < 0.068 < 0.068 04/21/2015 05/05/2015 < 0.032 < 0.032 < 0.032 < 0.032 < 0.017 05/05/2015 05/19/2015 < 0.012 < 0.032 < 0.032 < 0.032 < 0.032 05/19/2015 06/02/2015 < 0.025 < 0.026 < 0.022 < 0.020 < 0.020 06/02/2015 06/16/2015 < 0.015 < 0.015 < 0.022 < Q.015 < 0.021 06/16/2015 06/30/2015 < 0.066 < 0.066 < 0.028 < 0.065 < 0.065 06/30/2015 07/14/2015 < 0.035 < 0.034 < 0.035 < 0:035 < 0.019 07/14/2015 07/28/2015 < 0.041 < 0.016 < 0.041 < 0.041 < 0.040 07/28/2015 08/11/2015 < 0.018 < 0.018 < 0.008 < 0.018 < 0.018 08/11/2015 08/25/2015 < 0.026 < 0.026 < 0.014 < 0.026 < 0.026 08/25/2015 09/08/2015 < 0.022 < 0.022 < 0.022 < 0.022 < 0.012 09/08/2015 09/22/2015 < 0.037 < 0.037 < 0.037 < 0.016 < 0.037 09/22/2015 10/06/2015 < 0.019 < 0.020 < 0.008 < 0.020 < 0.020 10/06/2015 10/20/2015 < 0.014 < 0.006 <.0.014 < 0.014 < 0.014 ,,

10/20/2015 11/03/2015 < 0.020 < 0.020 < 0.020 < 0.008 < 0.020 11/03/2015 11/17/2015 < 0.014 < 0.034 < 0.034 < 0.034 <0.035 11/17/2015 12/01/2015 < 0.057 < 0.024 < 0.057 < 0.058 < 0.058 12/01/2015 12/15/2015 < 0.045 < 0.045 < 0.045 < 0.018 < 0.045

/

12/15/2015 12/29/2015 < 0.032 < 0.017 < 0.032 < 0.031 < 0.031 12/29/2015 01/12/2016 < 0.010 < 0.024 < 0.024 < 0.024 < 0.024

Enclosure to OCAN051604 Page 32 of 46 Table 2.1 Sample Type: Thermoluminescent Dosimeters Analysis: Gamma Dose Units: mrem/Qtr

'--- Inner Ring (Indicators) 1st Qtr '15 2nd Qtr '15 3rd Qtr '15 4th Qtr '15 Annual Mean '15 Station (mrem) (mrem) (mrem) (mrem) (mrem) 1 7.9 8.5 8.3 8.3 8.3 2 6.9 7.7 8.5 8.3 7.9 3 5.1 5.4 5.2 6.3 5.5 4 7.3 8.0 7.7 7.7 7.7

56 9.1 8.9 9.3 9.9 9.3 108 '8.0 8.1 8.1 8.2 8.1 109 8.6 8.2 9.0 8.3 8.5 110 7.3 7.7 8.1 8.2 7.8 145 6.7 7.7 7.8 7.8 7.5 146 7.7 8.1 7.1 8.1 7.8 147 7.1 6.6 6.4 6.9 6.8 148 7.5 8.0 7.8 LOST 7.8 149 7.7 7.0 LOST LOST 7.4 150 8.1 7.4 6.8 6.8 7.3 151 8.1 8.1 9.0 8.0 8.3 152 6.0 6.5 5.9 6.7 6.3

Station with highest annual mean.

Enclosure to OCAN051604 Page 33 of 46 Table 2.2 Sample Type: Thermoluminescent Dosimeters Analysis: Gamma Dose Units: mrem/Qtr Special Interest Areas - (Population Centers & Schools) 1st Qtr '15 2nd Qtr '15 3rd Qtr '15 4th Qtr '15 Annual Mean '15 Station (mrem) (mrem) (mrem) (mrem) (mrem) 6 7.5 7.5 6.8 6.8 7.2 111 5.3 5.4 5.4 5.4 5.4 116* 8.2 8.5 8.2 9.8 8.7 125 4.6 4.7 4.6 5.3 4.8 127 7.0 7.2 7.0 8.1 7.3 137 8.2 7.6 8.0 8.3 8.0 153 6.5 7.5 7.0 7.4 7.1

Stations with highest annual mean.

Special Interest Areas - (Control) 1st Qtr '15 2nd Qtr '15 3rd Qtr '15 4th Qtr '15 Annual Mean '15 Station (mrem) (mrem) (mrem) (mrem) (mrem) 7 6.0 5.7 6.2 6.5 6.1

Enclosure to OCAN051604 Page 34 of 46 Table 3.1 Sample Type: Surface Water Analysis: Gamma Isotopic Units: pCi/I Location Start Date End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 1-131 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) 12/31/2014 01/31/2015 <1.02 <1.28 <2.86 <1.01 <2.12 <1.35 <2.34 <13.5 <0.99 <1.09 <17.4 <6.05 Station 10 (Control) 12/31/2014 01/31/2015 <1.13 <1.19 <2.51 <1.11 <2.24 <1.25 <2.13 <3.74 <1.07 <1.18 <8.15 <2.61 Station 8 (Indicator) 01/31/2015 02/28/2015 <1.41 <1.58 <3.59 <1.26 <2.72 <1.76 <3.05 <11.3 <1.42 <1.50 <16.4 <4.60 Station 10 (Control) 01/31/2015 02/28/2015 <2.20 <2.19 <5.17 <2.02 <4.32 <2.24 <4.04 <4.18 <1.99 <2.28 <11.6 <4.19 Station 8 (Indicator) 02/28/2015 03/31/2015 <1.73 <1.82 <4.50 <1.58 <3.23 <2.09 <3.74 <11.6 <1.62 <1.87 <20.5 <6.63 Station 10 (Control) 02/28/2015 03/31/2015 <2.01 <1.90 <4.13 <2.14 <3.91 <1.95 <3.54 <3.57 <1.71 <2.11 <9.44 <3.07 Station 8 (Indicator) 03/31/2015 04/30/2015 <1.30 <1.49 <3.53 <1.22 <2.55 <1.60 <2.73 <10.0 <1.24 <1.33 <15.6 <4.93 Station 1O (Control) 03/31/2015 04/30/2015 <1.50 <1.56 <3.38 <1.51 <3.20 <1.61 <2.63 <3.33 <1.46 <1.58 <8.41 <2.81 Station 8 {Indicator) 04/30/2015 05/31/2015 <1.43 <1.77 <3.68 <1.59 <2.72 <1.72 <2.84 <12.3 <1.37 <1.45 <17.8 <7.16 Station 10 (Control) 04/30/2015 05/31/2015 <1.88 <2.05 <4.49 <1.86 <3.67 <1.92 <3.37 <5.49 <1.78 <1.76 <12.6 <4.00 Station 8 (Indicator) 05/31/2015 06/30/2015 <1.99 <2.31 <5.21 <1.95 <4.29 <2.34 <4.20 <14.5 <1.90 <2.25 <23.9 <6.33 Station 10 (Control) 05/31/2015 06/30/2015 <2.80 <3.14 <8.01 <3.41 <5.60 <3.54 <6.09 <7.89 <3.02 <2.88 <19.3 <7.14 Station 8 (Indicator) 06/30/2015 07/31/2015 <2.35 <2.67 <6.35 <2.37 <4.91 <2.78 <4.85 <12.4 <2.25 <2.38 <23.5 <8.32 Station 10 (Control) 06/30/2015 07/31/2015 <1.54 <1.79 <3.83 <1.55 <3.28 <1.99 <3.36 <10.1 <1.52 <1.66 <17.4 <4.97 Station 8 (lndicato~) 07/31/2015 08/31/2015 <2.07 <2.14 <5.38 <1.89 <3.94 <2.09 <4.49 <14.5 <1.86 <1.91 <25.3 <8.33 Station 10 (Control) 07/31/2015 08/31/2015 <7.41 <7.80 <16.0 <7.13 <17.5 <10.7 <12.1 <9.39 <7.88 <9.19 <28.6 <7.77 Station 8 (Indicator) 08/31/2015 09/30/2015 <2.82 <3.03 <6.96 <2.50 <5.84 <3.06 <6.00 <14.5 <2.69 <2.94 <27.1 <9.31 Station 10 (Control) 08/31/2015 09/30/2015 <5.31 <6.38 <13.1 <6.74 <13.9 <5.50 <13.0 <8.47 <6.33 <8.19 <33.0 <11.1 Station 8 (Indicator) 09/30/2015 10/31/2015 <1.76 <2.11 <4.02 <1.57 <3.44 <2.21 <3.87 <14.9 <2.09 <2.04 <22.1 <4.50 Station 10 (Control) 09/30/2015 10/31/2015 <6.22 <7.67 <13.1 <7.37 <15.5 <6.86 <13.4 <10.1 <7.00 <6.44 <40.4 <10.5 Station 8 {Indicator) 10/31/2015 11/30/2015 <2.71 <3.07 <7.61 <2.80 <5.88 <3.51 <4.99 <14.70 <2.79 <2.92 <26.90 <7.47 Station 1O (Control) 10/31/2015 11/30/2015 <8.78 <6.99 <17.30 <4.51 <14.60 <8.25 <13.10 <9.06 <8.12 <7.35 <34.00 <7.99 Station 8 (Indicator) 11/30/2015 12/31/2015 <1.32 <1.54 <3.37 <1.22 <2.41 <1.61 <2.79 <12.30 <1.32 <1.31 <18.10 <5.14 Station 10 (Control) 11/30/2015 12/31/2015 <4.89 <4.71 <10.50 <3.55 <10.30 <4.85 <8.68 <12.30 <4.87 <4.08 <26.50 <8.80

Enclosure to OCAN051604 Page 35 of 46 Table 3.2 Sample Type: Surface Water Analysis: Tritium Units: pCi/I Location Begin Date End Date H-3 Reguired LLD + 3000 Station 8 (Indicator) 12/31/2014 03/31/2015 <300 Station 1O (Control) 12/31/2014 03/31/2015 <322 Station 8 (Indicator) 03/31/2015 06/30/2015 333 Station 1O (Control) 03/31/2015 06/30/2015 < 197 Station 8 (Indicator) 06/30/2015 09/30/2015 988 Station 1O (Control) 06/30/2015 09/30/2015 < 386 Station 8 (Indicator) 09/30/2015 12/31/2015 842 Station 1O (Control) 09/30/2015 12/31/2015 <340

Enclosure to OCAN051604 Page 36 of 46 Table 4.1 Sample Type: Drinking Water Analysis: Gross Beta 1 lodine-131 1 Gamma lsoto12ic Units: 12Ci/I Collection Gross Location 1-131 Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Date Beta Reguired LLD + 4.0 1.0 15 15 30 15 30 15 30 15 18 60 15 Station 14 (Indicator) 01/15/2015 < 1.43 < 0.460 <4.97 < 6.32 - < 8.91 < 4.28 < 11.8 < 5.22 < 7.80 < 5.61 < 4.83 <25.8 < 10.1 Station 57 (Control} 01/15/2015 3.16* < 0.419 < 5.54 < 5.94 < 12.2 < 6.70 < 11.0 < 7.38 < 11.2 < 6.08 < 6.18 < 29.0 < 9.94 Station 14 (Indicator) 03/24/2015 < 1.60 < 0.637 < 4.16 < 4.68 < 11.3 <4.64 < 10.5 < 5.58 < 9.73 < 5.02 < 5.72 <28.7 < 7.51 Station 57 (Control} 03/24/2015 < 1.65 < 0.411 < 5.63 <5.79 < 13.5 < 5.47 < 12.3 < 6.84 < 10.3 < 6.05 < 6.19 <33.3 < 12.4 Station 14 (Indicator) 07/14/2015 <2.50 < 0.605 < 6.34 < 6.09 < 13.0 <5.70 < 14.0 < 6.25 < 11.4 <4.29 < 6.45 < 30.7 < 12.9 Station 57 (Control) 07/14/2015 < 1.66 < 0.687 < 8.35 < 6.16 < 17.7 < 9.14 < 16.8 < 7.33 < 12.2 < 7.31 < 7.30 < 36.3 < 10.9 Station 14 (Indicator) 09/18/2015 < 2.48 < 0.352 < 6.50 < 6.61 < 10.8 <5.59 < 12.2 < 7.33 < 10.0 < 5.06 < 6.46 < 22.3 < 9.60 Station 57 (Control) 09/18/2015 <2.88 < 0.450 < 6.03 < 5.70 < 12.7 < 7.06 < 18.0 < 6.01 < 12.5 < 6.51 <7.76 <30.0 < 10.5 Station 14 (Indicator) 12/01/2015 < 1.82 < 0.216' <4.85 <4.84 < 12.0 < 6.27 < 10.4 < 5.16 < 9.52 < 4.45 < 6.55 <27.9 < 9.15 Station 57 (Control} 12/01/2015 < 3.14 < 0.228 < 7.11 < 8.84 < 13.4 < 7.21 < 14.5 < 7.59 < 12.0 < 6.23 < 6.85 < 32.8 < 10.5

Re-analysis of this sample by the analytical vendor produced a value of 1.92 pCi/L; this condition was documented in CR-ANO-C-2015-00351.

Enclosure to OCAN051604 Page 37 of 46 Table 4.2 Sample Type: Drinking Water Analysis: Tritium

Units: pCi/1 Location Collection Date H-3 Reguired LLD + 2000 Station 14 (Indicator) 01/15/2015 < 322 Station 57 (Control) 01/15/2015 < 316 Station 14 (Indicator) 03/24/2015 < 178 Station 57 (Control) 03/24/2015 < 180 Station 14 (Indicator) 07/14/2015 <343 Station 57 (Control) 07/14/2015 <350 Station 14 (Indicator) 09/18/2015 <344 Station 57 (Control) 09/18/2015 < 349 Station 14 (Indicator) 12/01/2015 <356 Station 57 (Control) 12/01/2015 <354 Table 5.1 Sample Type: Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 Reguired LLD ~ 150 180 Station 8 (Indicator) 9/23/2015 < 17.20 < 19.00 Station 16 (Control)* 9/23/2015 < 12.80 < 15.30 Table 6.1 Sample Type: Fish Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 Reguired LLD ~ 130 130 260 130 260 130 150 Station 8 (Indicator) 9/17/2015 < 13.00 < 15.20 < 33.50 < 12.80 < 27.40 < 12.80 < 13.20 Station 16 (Control) 9/07/2015 < 13.30 < 15.60 < 39.10 < 12.00 < 27.40 < 12.10 < 12.40

Enclosure to OCAN051604 Page 38 of 46 Table7.1 Sample Type: Food Products Analysis: lodine-131, Gamma Isotopic Units: pCi/kg Location Collection Date 1-131 Cs-134 Cs-137 Reguired LLD + 60 60 80 Station 13 (Indicator) 06/16/2015 < 38.90 < 13.10 < 14.30 Station 55 (Control) 06/16/2015 < 48.90 < 14.80 < 16.50 Station 13 (Indicator) 07/09/2015 < 45.50 < 23.80 < 23.30 Station 55 (Contro.1) 07/09/2015 < 50.70 < 28.80 < 29.80 Station 13 (Indicator) 08/11/2015 < 53.00 < 16.70 < 19.30

- Station 55 (Control) 08/11/2015 < 54.00 < 18.60 < 18.70

Enclosure to OCAN051604 Page 39 of 46 Table 8.1 j

Sample Type: Groundwater Analysis: lodine-131 1 Gamma lsotogic Units: gCi/I Gross Sample Collection Beta 1-131 Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95

Zr-95 Cs-134 Cs-137 Ba-140 La-140

Date 2015 Reguired LLD + 4.0 --'15 15 15 30 15 30 15 30 15 18 60 15 58* 03/23/15 <2.54 < 12.70 < 4.40 <5.24 < 9.95 < 4.11 < 11.10 <4.96 < 8.61 <4.59 < 5.55 < 28.50 < 6.28 62* 03/23/15 < 3.14 < 13.00 <5.54 <5.75 < 13.20 <5.74 < 11.90 < 5.35 < 9.43 <5.25 < 5.29 < 35.20 < 9.76 63 03/23/15 <3.26 < 13.20 < 5.31 <5.62 < 10.50 <7.25 < 11.10 < 5.89 < 10.70 <4.90 < 5.50 < 33.50 < 10.20 64 03/23/15 4.31 < 13.50 <4.23 <4.69 < 9.62 <5.54 < 9.91 < 5.54 <8.04 <4.77 < 5.39 < 26.90 < 11.90 58* 06/15/15 <2.24 < 12.20 < 6.91 <7.85 < 13.70 < 6.29 < 12.80 < 7.18 < 10.50 < 6.18 < 7.08 < 25.70 < 13.60 62* 06/15/15 <3.08 < 14.70 < 6.83 <6.96 < 17.00 <8.23 < 13.20 < 7.66 < 14.10 < 7.86 < 7.69 < 43.50 < 11.90 63 06/15/15 <3.11 < 11.20 <5.52 <5.94 < 6.33 < 6.58 < 10.70 < 2.35 < 10.60 <4.67 < 6.93 < 26.30 < 9.26 64 06/16/15 5.24 < 14.90 < 6.02 <7.50 < 17.80 < 8.07 < 13.80 < 9.17 < 11.10 < 6.40 < 7.67 < 39.6 < 14.50 58* 08/03/15 <2.39 < 13.30 < 6.42 < 7.00 < 13.80 <6.36 < 14.30 < 8.14 < 10.90 < 6.75 <6.43 < 31.30 < 14.70 62* 08/03/15 < 1.95 < 9.60 < 5.13 <5.05 < 9.34 < 5.78 < 10.80 <5.72 < 8.92 <4.33 < 4.80 < 25.50 < 10.80 63 08/03/15 <2.29 < 11.50 < 3.85 < 6.08 < 11.00 <3.80 < 9.69 < 6.28 < 9.35 <4.76 <5.27 < 34.70 < 9.69 64 08/04/15 <3.13 < 13.10 < 5.43 .<5.28 < 11.60 <5.69 < 13.40 < 6.18 < 9.69 <5.58 < 5.85 < 32.30 < 9.57 58* 12/02/15 < 1.99 < 10.2 < 4.90 <5.05 < 9.55 < 6.05 < 11.2 < 6.74 < 8.45 <4.99 < 6.23 < 32.4 <7.36 62* 12/02/15 < 3.18 < 13.0 < 5.68 < 5.46 < 10.9 <5.84 < 15.0 < 6.45 < 10.4 <6.33 <6.95 < 33.0 < 9.45 63 12/02/15 < 2.31 < 12.6 < 7.39 < 9.11 < 19.0 < 9.57 < 14.5 < 9.09 < 13.2 < 8.19 < 9.39 < 42.8 < 12.9 64 12/02/15 3.65 < 14.5 <7.05 < 7.78 < 16.0 < 6.26 < 17.2 < 7.94 < 14.4 < 7.43 < 8.16 < 38.8 < 12.3

Identifies Control Locations

Enclosure to OCAN051604 Page 40 of 46 Table 8.2 Sample Type: Groundwater Analysis: Tritium Units: pCi/I Location Collection Date H-3 Reguired LLD + 3000 Station 58 (Control) 03/23/2015 <324 Station 62 (Control) 03/23/2015 < 320 Station 63 (Indicator) 03/23/2015 < 321 Station 64 (Indicator) 03/23/2015 < 388 Station 58 (Control) 06/15/2015 < 339 Station 62 (Control) 06/15/2015 <334 Station 63 (Indicator) 06/15/2015 < 333 Station 64 (Indicator) 06/16/2015 < 341 Station 58 (Control) 08/03/2015 <342 Station 62 (Control) 08/03/2015 <343 Station 63 (Indicator) 08/03/2015 <343 Station 64 (Indicator) 08/04/2015 < 193 Station 58 (Control) 12/02/2015 < 392 Station 62. (Control) 12/02/2015 < 396 Station 63 (Indicator) 12/02/2015 < 393 Station 64 (Indicator) 12/02/2015 < 387

Enclosure to OCAN051604 Page 41 of 46 Table 8.3 2014 Data Sample Type: Groundwater Analysis: Gross Beta Units: pCi/I Location Collection Date Gross Beta Reguired LLD ~ 4.0 Station 58 (Control) 02/18/2014 1.31 Station 62 (Control) 02/18/2014 < 1.44 Station 63 (Indicator) 02/19/2014 7.70 Station 64 (Indicator) 02/18/2014 < 2.76 Station 58 (Control) 04/28/2014 < 2.71 Station 62 (Control) 04/28/2014 < 2.97 Station 63 (Indicator) 04/28/2014 < 2.12 Station 64 (Indicator) 04/29/2014 < 1.83 Station 58 (Control) 08/26/2014 < 3.15 Station 62 (Control) 08/26/2014 < 3.45

Station 63 (Indicator) 08/26/2014 < 3.78 Station 64 (Indicator) 08/25/2014 < 3.46 Station 58 (Control) 10/27/2014 <3.69 Station 62 (Control) 10/27/2014 <3.73 Station 63 (Indicator) 10/27/2014 <3.39 Station 64 (Indicator) 10/27/2014 <2.96

Enclosure to OCAN051604 Page 42 of 46 ATTACHMENT2 INTERLABORATORY COMPARISON PROGRAM

Enclosure to OCAN051604 Page 43 of 46 lnterlaboratory Comparison Report provided by Teledyne Brown Engineering For the Teledyne Brown Engineering {TBE) laboratory, 129 out of 139 analyses performed met the specified acceptance criteria. Ten analyses (AP - Cr-51, U-234/233, Gr A, Sr-90; Soil Sr-90; Water - Ni-63, Sr-89/90, U natural; Vegetation Sr-90 samples) did not meet the specified acceptance criteria for the following reasons and were addressed through the TBE Corrective Action Program:

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.

1. TBE's Analytics' June 2015 air particulate Cr-51 result of 323 +/- 45.5 pCi was higher than the known value of 233 pCi with a ratio of 1.39. The upper ratio of 1.30 (acceptable with warning) was exceeded. The air particulate sample is counted at a distance above the surface of the detector to avoid detector summing which could alter the results.

Chromium-51 has the shortest half-life (27.7 days) and the lowest gamma energy (320.08 keV) of this mixed nuclide sample. Additionally, Cr-51 has only one gamma energy and also has a low intensity (9.38 gamma photons produced per 100 disintegrations). This geometry produces a larger error for the Cr-51 and other gamma emitters as any distance from the detector decreases the counting rate and the probability of accurately detecting the nuclide energy. Taking into consideration the uncertainty, the activity of Cr-51 overlaps with the known value at a ratio of 1.19, which would statistically be considered acceptable. Non Conformance Report (NCR) 15-18

2. TBE's MAPEP March 2015 soil Sr-90 result of .286 Total Bq/kg was lower than the known value of 653 Bq/kg, exceeding the lower acceptance range of 487 Bq/kg. The failure was due to incomplete digestion of the sample. Incomplete digestion of samples causes some of the sample to be left behind and is not present in the digested sample utilized for analysis. Th~ procedure has been updated to include a more robust digestion using stirring during the heating phase. The MAPEP September 2014 soil Sr-90 series prior to this study was evaluated as acceptable with a result of 694 and an acceptance range of 601 - 1115 Bq/kg. The MAPEP September 2015 series soil Sr-90 after this study was evaluated as acceptable with a result of 429 and an acceptance range of 298 - 553 Bq/kg. We feel the issue is specific to the March 2015 MAPEP sample. NCR 15-13 ,

3. TBE's MAPEP March 2015 air particulate U-234/233 result of 0.0211 +/- 0.0120 Sq/sample was higher than the known value of 0.0155 Sq/sample, exceeding the upper acceptance range of 0.0202 Sq/sample. Although evaluated as a failure, taking into consideration the uncertainty, TBE's result would overlap with the known value, which is statistically considered acceptable. MAP~P spiked the sample with significantly more U-238 activity (a found to known ratio of 0.96) than the normal U-234/233. Due to the extremely low

activity, it was difficult to quantify the U-234/2~3. NCR 15-13

4. TBE's MAPEP March 2015 air particulate gross alpha result of 0.448 Sq/sample was

lower than the known value of 1.77 Sq/sample, exceeding the lower acceptance range of 0.53 Sq/sample. The instrument,efficiency used for gross alpha is determined using a non-attenuated alpha standard,.- The MAPEP filter has the alphas embedded in the filter, requiring an' attenuated efficiency. When samples contain alpha particles that are embedded in the sample media, due to the size of the alpha particle, some of the alpha particles are absorbed by the media and cannot escape to be counted. When the sample media absorbs the alpha particles this is known as self-absorption or

Enclosure to OCAN051604 Page 44 of 46 attenuation. The calibration must include a similar configuration/media to correct for the attenuation. In order to correct the low bias, TSE will create an attenuated efficiency for MAPEP air particulate filters. The MAPEP September series air particulate gross alpha result of 0.47 Sq/sample was evaluated as acceptable with a range of 0.24 - 1.53 Sq/sample. Unlike the MAPEP samples, air particulate Gross alpha analyses for power plants are not evaluated as a direct count sample. Power plant air particulate filters for gross alpha go through an acid digestion process prior to counting and the digested material is analyzed. NCR 15-13

5. TSE's MAPEP September water Ni-63 result of 11.8 +/- 10.8 Sq/l was higher than the known value of 8.55 Sq/l, exceeding the upper acceptance range of 11.12 Sq/L. The Ni-63 half-life is approximately 100 years. Nickel-63 is considered to be a "soft" or low energy beta emitter, which means that the beta energy is very low. The maximum beta energy for Ni-63 is approximately 65 keV, much lower than other more common nuclides such as Co-60 (maximum beta energy of 1549 keV). The original sample was run with a 1O ml aliquot which was not sufficient for the low level of Ni-63 in the sample. The rerun aliquot of 30 ml produced an acceptable result of 8.81 Sq/L. NCR 15-21

6. TSE's MAPEP September air particulate Sr-90 result of 1AB Sq/sample WflS lower than the known value of 2.18 Sq/sample, exceeding the lower acceptance range of 1.53 Sq/sample. In the past, MAPEP has added substances (unusual compounds found in DOE complexes) to various matrices that have resulted in incomplete removal of the isotope of interest for the laboratorles analyzing the cross checks. TSE suspects that this may be the cause of this error. Many compounds, if not properly accounted for or '

removed in the sample matrix, can cause interferences to either indicate lower activity or higher activity. TSE will no longer analyze the air particulate Sr-90 through MAPEP but will participate in the Analytics cross check program to perform both Sr-89 and Sr-90 in the air particulate matrix. NCR 15-21

7. TSE's MAPEP September vegetation Sr-90 result of 0.386 Sq/sample was lower than the known value of 1.30 Sq/sample, exceeding the lower acceptance range of 0.91 Sq/sample. In the past, MAPEP has added substances (unusual compounds found in DOE complexes) to various matrices that have resulted in incomplete removal of the isotope of interest for the laboratories analyzing the cross checks. TSE suspects that this maybe the cause of this error. Many compounds, if not properly accounted for or removed in the sample matrix, can cause interferences to either indicate lower activity or higher activity. Results from previous performance evaluations were reviewed and shown to be acceptable. NCR 15-21

8. & 9. TSE's ERA May water Sr-89/90 results of 45.2 and 28.0 pCi/l, respectively were lower than the known values of 63.2 and 41.9 pCi/l, respectively, exceeding the lower acceptance limits of 51.1 and 30.8 pCi/l, respectively. The yields were on the high side of the TSE acceptance range, which indicates the present of excess calcium contributed to the yield, resulting in low results. NCR 15-09 t

10. TSE's ERA November water Uranium natural result of 146.9 pCi/l was higher than the known value of 56.2 pCi/l, exceeding the upper acceptance limit of 62.4 pCi/L. The technician failed to dilute the original sample, but used the entire 12 ml sample. When the results were recalculated without the dilution and using the 12 ml aliquot, the result of 57.16 agreed with the assigned value of 56.2. NCR 15-19 Raw data supporting this report are not included here; these data, however, are available upon request to Chemistry Department, Arkansas Nuclear One, Entergy Corporation.

Enclosure to OCAN051604 Page 45 of 46 ATTACHMENT 3 SEDIMENT DOSE CALCULATIONS

Enclosure to OCAN051604 Page 46 of 46 Sediment Sample Results Sediment samples were collected from two locations in 2015 and analyzed for gamma radionuclides. Although Cesium-137 has been detected in previous years prior to 2013, all gamma radionuclides from 2015 samples were below detectable limits. These results are consistent with 2013 and 2014 results where all gamma radi9nuclides were also below detectable limits. Therefore, ANO operations had no significant impact on the environment or public by this waterborne pathway.

In previous reports, ANO has included annual maximum dose calculations to the skin and total body. However since gamma radionuclides were below detectable limits, no calculation is being provided since there is no associated dose.

~Entergy Entergy Operations, Inc.