Text

2021 Annual Radiological Environmental Operating Report
	ML22119A049
Person / Time
Site:	Limerick
Issue date:	04/29/2022
From:	Sturniolo F; Constellation Energy Generation
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	LG-22-033, TS 6.9.1.7
	Download: ML22119A049 (116)
	v • d • e

Constellation TS 6.9.1.7 LG-22-033 April 29, 2022 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

2021 Annual Radiological Environmental Operating Report In accordance with the requirements of Section 6.9.1.7 of Limerick Generating Station (LGS)

Units 1 and 2 Technical Specifications (TS), and Section 6.1 of the LGS Units 1 and 2 Offsite Dose Calculation Manual (ODCM), this letter submits the 2021 Annual Radiological Environmental Operating Report. This report provides the 2021 results for the Radiological Environmental Monitoring Program (REMP), as called for in the ODCM.

In assessing the data collected for the REMP, it has been concluded that the operation of LGS, Units 1 and 2 had no adverse impact on the environment. No plant-produced fission or activation products were found in any pathway modeled by the REMP. The results of the groundwater protection program are also included in this report.

There are no commitments contained in this letter.

If you have any questions or require additional information, please contact Amanda Sborz at 610-718-2700.

Respectfully, Digitally signed by Sturniolo, Frank Date: 2022.04.28 12:42:35 -04'00' Frank Sturniolo Site Vice President - Limerick Generating Station Constellation Energy Generation, LLC

Attachment:

2021 Annual Radiological Environmental Operating Report cc: Administrator, Region I, USNRC (w/attachment)

LGS USNRC Senior Resident Inspector (w/attachment)

M. Henrion, Inspector Region I, USNRC (w/attachment)

V. Sreenivas, LGS Senior Project Manager-NRR, USNRC (w/attachment)

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR THE LIMERICK GENERATING STATION UNITS 1 AND 2 January 1 - December 31, 2021 Prepared by M. Aument A. M. Barnett EXELON GENERATION EXELON NUCLEAR GENERATION APRIL 2022

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 TABLE OF CONTENTS LIST OF FIGURES ...................................................................................................................... ii

LIST OF TABLES ....................................................................................................................... iii

I.

SUMMARY

.................................................................................................................................4

II. LIMERICK GENERATING STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ..........................................................................................13

II.A. INTRODUCTION ....................................................................................................................................... 13

II.B. PROGRAM .................................................................................................................................................. 14

II.B.1 Objectives ............................................................................................................................................. 14

II.B.2 Sample Collection ................................................................................................................................ 14

II.B.3 Data Interpretation .............................................................................................................................. 16

II.B.4 Program Exceptions............................................................................................................................. 17

II.C. RESULTS AND DISCUSSIONS ................................................................................................................. 19

II.C.1 Aquatic Environment ........................................................................................................................... 19

II.C.1.a Surface and Drinking Water ............................................................................................................ 20

II.C.1.b Aquatic Organisms ............................................................................................................................ 20

II.C.1.c Shoreline Sediment ............................................................................................................................ 20

II.C.2 Atmospheric Environment .................................................................................................................. 21

II.C.2.a Air Particulate Filters ....................................................................................................................... 21

II.C.2.b Air Iodine .......................................................................................................................................... 21

II.C.3 Terrestrial Environment .................................................................................................................... 22

II.C.3.a Vegetation .......................................................................................................................................... 22

II.C.3.b Milk .................................................................................................................................................... 22

II.C.4 Direct Radiation ................................................................................................................................... 22

II.D. CONCLUSION ............................................................................................................................................. 24

V. REFERENCES ........................................................................................................................28

APPENDIX A Sample Locations for the REMP .....................................................................30

APPENDIX B Analysis Results for the REMP ........................................................................42

APPENDIX C Quality Assurance Program ..............................................................................62

APPENDIX D Land Use Survey................................................................................................91

APPENDIX E Annual Radiological Groundwater Protection Program Report for Limerick Generating Station ......................................................................................................94

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 LIST OF FIGURES Figure Title Page A-1 Limerick Generating Station Sample Locations ................................................................34

A-2 Limerick Generating Station Sample Locations ................................................................35

A-3 Limerick Generating Station Sample Locations ................................................................36

A-4 Gross Beta in Public Water for the Last Ten Years ...........................................................37

A-5 Gross Beta in Air for the Last Ten Years ..........................................................................38

A-6 Annual Trending of Air Activity (Gross Beta) ..................................................................39

A-7 2021 Monthly Gross Beta Concentrations in Drinking Water, (16C2) ............................40

A-8 2021 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers .......................................................................................................................41

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 LIST OF TABLES Table Title Page 1 Synopsis of 2021. Limerick Generating Station Radiological Environmental Monitoring Program ..............................................................................................................................25

2 Annual Summary of Radioactivity in the Environs of the Limerick Generating Station ..27

A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station ......32

A-2 Locations of Environmental Sampling Stations for the Limerick Generating Station ......33

B-1 Concentration of Tritium, Gamma Emitters and Gross Beta in Surface and Drinking Water ..................................................................................................................................44

B-2 Concentration of Gamma Emitters in the Flesh of Edible Fish .........................................46

B-3 Concentration of Gamma Emitters in Sediment ................................................................47

B-4 Concentration of Iodine-131 in Filtered Air ......................................................................48

B-5 Concentration of Beta Emitters in Air Particulates - Onsite Samples...............................50

B-6 Concentration of Gamma Emitters in Air Particulates ......................................................53

B-7 Concentration of Gamma Emitters in Vegetation Samples ...............................................54

B-8 Concentration of Gamma Emitters (including I-131) in Milk ...........................................55

B-9 Typical MDA Ranges for Gamma Spectrometry ...............................................................57

B-10 Typical LLDs for Gamma Spectrometry ............................................................................58

B-11 Quarterly DLR Results for Limerick Generating Station, 2021 .........................................59

C-1 Results of Participation in Cross Check Programs ............................................................65

C-2 Results of Quality Assurance Program ..............................................................................73

C-2a Results of Quality Assurance Program Co-Located Air Samplers ....................................84

C-2b Results of Quality Assurance Program Co-Located Air Samplers ....................................87

C-3 Limerick Generating Station ODCM Required LLDs .......................................................90

D-1 Land Use Survey ................................................................................................................91

E-1 Locations of Onsite Radiological Groundwater Protection Program - Limerick Generating Station, 2021 .................................................................................................108

E-2 Routine Well Water Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2021 ..................................................................109

E-3 Routine Precipitation Sample Locations for the Radiological Groundwater Protection Program, Limerick Generating Station, 2021 ..................................................................110

E-4 Hard to Detects in Groundwater .......................................................................................111

E-5 Concentration of Radiostrontium in Groundwater ............................................................112

E-6 Concentration of Tritium in Groundwater ........................................................................113

E-7 Concentration of Tritium in Surface Water, Precipitation, and Subsurface Drainage ......114

iii

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 I.

SUMMARY

The following sections of the summary are meant to help define key concepts, provide clarity, and give context of the monitoring program and results to the readers of this report.

Annual Reports The Nuclear Regulatory Commission (NRC) is the federal agency who has the role to protect public health and safety related to nuclear energy. Nuclear Power Plants have made many commitments to the NRC to ensure the safety of the public. As part of these commitments, they provide two reports annually to specifically address how the stations operation impacts the environment of the local communities. The NRC then reviews these reports and makes them available to the public. The names of the reports are the Annual Radioactive Effluent Release Report (ARERR) and the Annual Radiological Environmental Operating Report (AREOR).

The ARERR reports the results of the analyses of samples taken from the effluent release paths at the station. An effluent is a liquid or gaseous waste, containing plant-related radioactive material emitted at the boundary of the facility.

The AREOR reports the results of the analyses of samples obtained in the environment surrounding the station. Environmental samples include air, water, vegetation, and other sample types that are identified as potential pathways radioactivity can reach humans.

Graphic 1. Examples of Gaseous and Liquid Effluent Pathways Dri nki ng S urface Water or Groundwatef" 4

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Graphic 1 demonstrates some potential exposure pathways from Limerick Generating Station.

The ARERR and AREOR together ensure Nuclear Power Plants are operating in a manner that is within established regulatory commitments meant to adequately protect the public.

Understanding Radiation Generally radiation is defined as emitted energy in the form of waves or particles. radiation has enough energy to displace electrons from an atom it is termed ionizing, otherwise it is non-ionizing. Non-Ionizing radiation includes light, heat given off from a stove, radiowaves and microwaves. Ionizing radiation occurs in atoms, particles too small for the eye to see. So, what are atoms and how does radiation come from them?

Graphic 2. Types of Radiation, from NASA Hubblesite The El&ctromagnetic Spectrum Wavelen!,J1h I n mete-rs

.-3 -:s -Ii, .-'I ffl *t o to 11m, to 110 h10 _ 1 ili0 4 10 Albouf th* s lz* ,of:

B uildin,g1;1 Grai n~ Prolozoan s Baomria Mol ecule,s, .Atoms of eugiar An atom is the smallest part of an element that maintains the characteristics of that element.

Atoms are made up of three parts: protons, neutrons, and electrons.

Graphic 3. Structure of an Atom The number of protons in an atom determines the element. For example, a hydrogen atom will always have one proton while an oxygen atom will always have eight protons. The protons are clustered with the neutrons forming the nucleus at the center of the atom. Orbiting around the nucleus are the relatively small electrons.

Isotopes are atoms that have the same number of protons but different numbers of neutrons.

Different isotopes of an element will all have the same chemical properties and many isotopes are radioactive while other isotopes are not radioactive. A radioactive isotope can emit radiation 5

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 because it contains excess energy in its nucleus. Radioactive atoms and isotopes are also referred to as radionuclides and radioisotopes.

There are two basic ways that radionuclides are produced at a nuclear power plant. The first is fission, which creates radionuclides that are called fission products.

Fission occurs when a very large atom, such as uranium-235 (U-235) or plutonium- 239 (Pu-239), absorbs a neutron into its nucleus making the atom unstable. The unstable atom can then split into smaller atoms. When fission occurs, there is a large amount of energy released in the form of heat. A nuclear power plant uses the heat generated to boil water that spins turbines to produce electricity.

The second way a radionuclide is produced at a nuclear power plant is through a process called activation and the radionuclides produced in this method are termed activation products. Pure water that passes over the fissioning atoms is used to cool the reactor and also produce steam to turn the turbines. Although this water is considered to be very pure, there are always some contaminants within the water from material used in the plants construction and operation.

These contaminants are exposed to the fission process and may become activation products. The atoms in the water itself can also become activated and create radionuclides.

Over time, radioactive atoms will reach a stable state and no longer be radioactive. To do this they must release their excess energy. This release of excess energy is called radioactive decay.

The time it takes for a radionuclide to become stable is measured in units called half-lives. A half-life is the amount of time it takes for half of the original radioactivity to decay. Each radionuclide has a specific half-life.

Some half-lives can be very long and measured in years while others may be very short and measured in seconds.

Graphic 4. Radioactive Decay Half-Life Half-life Th e amount of time it takes for half of the origina l radioactivity to decay 600 Activity 200 lhatf-llfe 2 half-lives 3half-llves 4ha l f-llves In the annual reports you will see both man made and naturally occurring radionuclides listed, for example potassium-40 (K-40, natural) and cobalt-60 (Co-60, man-made). We are mostly concerned about man-made radionuclides because they can be produced as by-products when generating electricity at a nuclear power plant. It is important to note that there are also other ways man-made radionuclides are produced, such as detonating nuclear weapons. Weapons testing has deposited some of the same man-made radionuclides into the environment as those generated by nuclear power, and some are still present today because of long half-lives.

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Measuring Radiation There are four different but interrelated units for measuring radioactivity, exposure, absorbed dose, and dose equivalent. Together, they are used to scientifically report the amount of radiation and its effects on humans.

x Radioactivity refers to the amount of ionizing radiation released by a material. The units of measure for radioactivity used within the AREOR and ARERR are the Curie (Ci).

Small fractions of the Ci often have a prefix, such as the microCurie (Ci), which means 1/1,000,000 of a Curie.

x Exposure describes the amount of radiation traveling through the air. The units of measure for exposure used within the AREOR and ARERR are the Roentgen (R).

Traditionally direct radiation monitors placed around the site are measured milliRoentgen (mR), 1/1,000 of one R.

x Absorbed dose describes the amount of radiation absorbed by an object or person. The units of measure for absorbed dose used within the AREOR and ARERR are the rad.

Noble gas air doses are reported by the site are measured in millirad (mrad), 1/1,000 of one rad.

x Dose equivalent (or effective dose) combines the amount of radiation absorbed and the health effects of that type of radiation. The units used within the AREOR and ARERR are the Roentgen equivalent man (rem). Regulations require doses to the whole body, specific organ, and direct radiation to be reported in millirem (mrem), 1/1,000 of one rem.

Sources of Radiation People are exposed to radiation every day of their lives and have been since the dawn of mankind. Some of this radiation is naturally occurring while some is man- made. There are many factors that will determine the amount of radiation individuals will be exposed to such as where they live, medical treatments, etc. The average person in the United States is exposed to approximately 620 mrem each year. 310 mrem comes from natural sources and 310 from man-made sources. The Graphic 5 shows what the typical sources of radiation are for an individual over a calendar year:

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Graphic 5. Sources of Radiation Exposure in the U.S., from NCRP Report No. 160 Sources of Radiation Exposure in the U.S.

Industrial and Terrestrial (Soil) - 3% Occupational Internal - 5% <0.1%

Consumer - 2%

Nuclear Medicine 12%

D Natural Sources - 50%

~310 millirem (0.3 1 rem)

(D Manmade Sources - 50%

~310 millirem (0.31 rem)

Sourc,e: NCRP Report No, 160 (2009t Full re pert is available on the NCRPwebsite atwww.NCRPonline,orR The radiation from a nuclear power plant is included in the chart as part of the Industrial and Occupational fraction, <0.1%. The largest natural source of radiation is from radon, because radon gas travels in the air we breathe. Perhaps you know someone who had a CT scan at a hospital to check his or her bones, brain, or heart. CT scans are included in the chart as Medical Procedures, which make up the next largest fraction. Graphic 6 on the following page shows some of the common doses humans receive from radiation every year.

8

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Graphic 6 .Relative Doses from Radiation Sources, from EPA Radiation Doses and Sources RELATIVE DOSES FROM RADIATION SOURCES All doses from the Natfonal Councll on Radiation Protection & Measurement.s, Report No. 160 (unless: otherwise denoted}

Whole body CT 1,000 mllHrem

( single procedure)

UpSM:r G. .trolntMUBIII x-r*y exam with ftuoroscopy 600 mllllrem (single procedure)

Radon In average: U.S. home 228 mllllrem (annual) 200H-d mllllrem CT . , '

(single procedure}

Co*mlc radia tion llvlng In Denver

{high e l evation )

approxlmately 80 mllllrem (annual)

Mammogram 42 mllUrem ~

(single procedure) Co1mlc radiati on ltvlna at ..,.

From l CRP 2007 level (low e ..vatlon) approximately 30 mllllrem (annual)

Rad latIon In the body 29 mllltrem (annual)

TerNStrlal radioactivity 21 mllllrem

( annual)

Ch*tx-ray 10 millirem

( single procedure)

Uvl ng n. .,

nudNr power station

< 1 mllllrem (annual) mrem

9

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Radiation Risk Current science suggests there is some risk from any exposure to radiation. However, it is very hard to tell whether cancers or deaths can be attributed to very low doses of radiation or by something else. U.S. radiation protection standards are based on the premise that any radiation exposure carries some risk.

The following graph is an example of one study that tries to relate risk from many different factors. This graph represents risk as Days of Lost Life Expectancy. All the categories are averaged over the entire population except Male Smokers, Female Smokers, and individuals that are overweight. Those risks are only for people that fall into those categories. The category for Nuclear Power is a government estimate based on all radioactivity releases from nuclear power, including accidents and wastes.

Graphic 7. Days of Lost Life Expectancy, Adapted from the Journal of American Physicians and Surgeons Volume 8 Number 2 Summer 2003 Days of Lost Life Expectancy Smoking - Men Heart Disease Smoking - Women Cancer Every 10 lbs overweight Stroke Motor Vehicle Accident Air Pollution I Radon Chemical Residue in Foods Drowning Hurricanes and Tornadoes Lightning Nuclear Power 0 500 1000 1500 2000 2500 3000 Days of Lost Life Expectancy Hurricanes and Tornadoes Lightning Nuclear Power I 0 0.2 0.4 0.6 0.8 1.2 1.4 1.6 1.8 10

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 In 2021, the Limerick Generating Station released to the environment through the radioactive effluent liquid and gaseous pathways approximately 132 curies of noble gas, fission and activation products and approximately 36 curies of tritium. The dose from both liquid and gaseous effluents was conservatively calculated for the Maximum Exposed Member of the Public. The results of those calculations and their comparison to the allowable limits were as follows:

Summary of Gaseous and Liquid Effluent Doses to Members of the Public at the Highest Dose Receptors Maximum % of Applicable Estimated Age Individual Applicable Limit Unit Noble Gas Dose Dose Group Limit Gamma Air Nearest Residence 1.97E-02 All 9.85E-02 20 mRad Dose Beta Air

Nearest Residence 1.26E-02 All 3.15E-02 40 mRad Dose Nearest Residence Total Body 1.89E-02 All 1.89E-01 10 Mrem

Nearest Residence Skin 3.26E-02 All 1.09E-01 30 Mrem

Iodine, Particulate, C-14

& Tritium Vegetation Bone 1.27E+00 Child 4.24E+00 30 Mrem

Liquid

Aqua PA Total Body 7.84E-02 Child 1.31E+00 6 Mrem

Aqua PA Thyroid 7.90E-02 Child 3.95E-01 20 Mrem

The calculated doses, from the radiological effluents released from Limerick, were a very small percentage of the allowable limits.

This report on the Radiological Environmental Monitoring Program conducted for the Limerick Generating Station (LGS) by Exelon covers the period 1 January 2021 through 31 December 2021. During that time period, 1,514 analyses were performed on 1,370 samples.

Surface and drinking water samples were analyzed for concentrations of tritium (H-3), low level iodine-131 (I-131) and gamma-emitting nuclides. Drinking water samples were also analyzed for concentrations of total gross beta. Total gross beta activities detected were consistent with those detected in previous years. No other fission or activation products were detected.

Fish (predator and bottom feeder) samples were analyzed for concentrations of gamma-emitting nuclides. Concentrations of naturally occurring potassium-40 11

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 (K-40) were consistent with those detected in previous years. No fission or activation products were detected in fish.

Sediment samples were analyzed for concentrations of gamma-emitting nuclides. No station-produced fission or activation products were found in sediment. For results, discussion, and dose to member of the public calculation see Section II.B.6.

Air particulate samples were analyzed for concentrations of gross beta and gamma- emitting nuclides. Gross beta and cosmogenic, naturally occurring beryllium-7 (Be-7) were detected at levels consistent with those detected in previous years. No fission or activation products were detected.

High-sensitivity I-131 analyses were performed on weekly air samples. All results were less than the minimum detectable concentration.

The air monitoring systems employed in the nuclear industry have proven to be capable of detecting very low levels of activity in the atmosphere, as activity from both the Chernobyl and Fukushima events was detected at many of the worlds nuclear power plants, including Limerick Generating Station.

Cow milk samples were analyzed for concentrations of I-131 and gamma-emitting nuclides.

Concentrations of naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were found.

Broadleaf vegetation samples were analyzed for gamma-emitting nuclides. Only naturally occurring activity was detected. K-40 was detected in all samples. Be-7 was found in 30 of 33 samples. Radium-226 (Ra-226) was found in 11 of 33 samples.

Thorium-228 (Th-228) was found in 18 of 32 samples. No activity due to plant operations were detected.

Review of the gamma spectroscopy results from the surface water samples located at the Limerick intake (24S1) and downstream of the 10 CFR 20.2002 permitted storage area showed no evidence of offsite radionuclide transport from the 2002 permitted storage area.

Environmental ambient gamma radiation measurements were performed quarterly using Dosimeters of Legal Record (DLR). Levels detected were consistent with those observed in previous years and no facility-related dose was detected. A review of the dosimetry data for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) indicates no direct dose was received.

A Radiological Groundwater Protection Program (RGPP) was established in 2006 as part of an Exelon Nuclear fleetwide assessment of potential groundwater intrusion from the operation of the Station. Results and Discussion of groundwater samples are covered in Appendix E.

In assessing the data gathered for this report and comparing these results with preoperational data, it was concluded that the operation of LGS had no adverse radiological impact on the environment.

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 II. LIMERICK GENERATING STATION RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM II.A. INTRODUCTION The Limerick Generating Station (LGS), consisting of two 3,515 MW boiling water reactors owned and operated by Exelon Corporation, is located adjacent to the Schuylkill River in Montgomery County, Pennsylvania. Unit No. 1 went critical on 22 December 1984. Unit No. 2 went critical on 11 August 1989. The site is located in Piedmont countryside, transversed by numerous valleys containing small tributaries that feed into the Schuylkill River. On the eastern riverbank, elevation rises from approximately 110 to 300 feet mean sea level (MSL). On the western riverbank elevation rises to approximately 50 feet MSL to the western site boundary.

A Radiological Environmental Monitoring Program (REMP) for LGS was initiated in 1971.

Review of the 1971 through 1977 REMP data resulted in the modification of the program to comply with changes in the Environmental Report Operating License Stage (EROL) and the Branch Technical Position Paper (Rev. 1, 1979). The preoperational period for most media covers the periods 1 January 1982 through 21 December 1984 and was summarized in a separate report. This report covers those analyses performed by Exelon Industrial Services (EIS), Mirion Technologies, and Teledyne Brown Engineering (TBE)/GEL Laboratories (GEL) on samples collected during the period 1 January 2021 through 31 December 2021.

On 6 July 1996, a 10 CFR 20.2002 permit was issued to Limerick for storage of slightly contaminated soils, sediments and sludges obtained from the holding pond, cooling tower and spray pond systems. These materials will decay to background while in storage. Final disposition will be determined at Station decommissioning.

On 21 July 2008, an ISFSI pad was put into service. The ISFSI is dry cask storage, where spent nuclear fuel is stored.

13

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 II.B. PROGRAM II.B.1 Objectives A. Objective of the REMP The objectives of the REMP are to:

1. Provide data on measurable levels of radiation and radioactive materials in the site environs;

2. Validate the radioactive effluent control program by evaluating the relationship between quantities of radioactive material released from the plant and resultant radiation doses to individuals from principal pathways of exposure.

B. Implementation of the Objectives The implementation of the objectives is accomplished by:

1. Identifying significant exposure pathways

2. Establishing baseline radiological data of media within those pathways

3. Continuously monitoring those media before and during station operation to assess station radiological effects (if any) on man and the environment II.B.2 Sample Collection and Analysis Samples for the LGS REMP were collected for Exelon Nuclear by contractors to, or personnel of, EIS according to applicable procedures (Ref 6,12,13). Control locations are sample locations that are not expected to be impacted by plant operations and are used to determine a baseline in the environment for each type of sample. This section describes the general collection methods used to obtain environmental samples for the LGS REMP in 2021.

The locations of the individual sampling stations are listed in Table A-1 and A-2 and shown in Figures A-1, A-2, and A-3.

Analyses are performed in accordance with applicable procedures (Ref 7,10,11,13) and results are provided in Appendix B for primary REMP Analysis. Analysis results for quality assurance are provided in Appendix C. Analysis results for LGS RGPP are provided in Appendix E.

All Samples were collected and analyzed as required except as noted in section II.B.4 Program exceptions.

II.B.2.a Aquatic Environment The aquatic environment was evaluated by performing radiological analyses on samples of surface water, drinking water, fish, and sediment. Two-gallon water samples were collected 14

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 monthly from composite samplers located at two surface water locations (13B1 and 24S1) and four drinking water locations (15F4, 15F7, 16C2, and 28F3). Control locations were 24S1, and 28F3. All samples were collected in new unused plastic bottles, which were rinsed at least twice with source water prior to collection. Fish samples comprising of the flesh of two groups, bottom feeder (Carp / Northern Hogsucker / Norther Sucker / White Sucker) and predator (American Eel

/ Black Crappie / Bluegill / Brown Trout / Channel Catfish / Flathead Catfish / Green Sunfish /

Smallmouth Bass / Yellow Perch), were collected semiannually at two locations, 16C5 and 29C1 (control). Sediment samples composed of recently deposited substrate were collected at three locations semiannually, 16B2, 16C4, and 33A2 (control).

II.B.2.b Atmospheric Environment The atmospheric environment was evaluated by performing radiological analyses on samples of air particulate, airborne iodine, and milk. Airborne iodine and particulate samples were collected and analyzed weekly at seven locations (6C1, 10S3, 11S1, 13S4, 14S1, 15D1, and 22G1). The control location was 22G1. Airborne iodine and particulate samples were obtained at each location, using a vacuum pump with charcoal and glass fiber filters attached. The pumps were run continuously and sampled air at the rate of approximately one cubic foot per minute. The filters were replaced weekly and sent to the laboratory for analysis.

II.B.2.c Terrestrial Environment Milk samples were collected biweekly at four locations (18E1, 19B1, 23F1, and 25C1) from April through November, and monthly from December through March. Location 23F1 was the control. All samples were collected in new unused two gallon plastic bottles from the bulk tank at each location, preserved with sodium bisulfite, and shipped promptly to the laboratory.

Broadleaf vegetation was collected monthly, during the growing season, at three locations (11S3, 13S3, and 31G1). The control location was 31G1.

Twelve different kinds of vegetation samples were collected and placed in new unused plastic bags and sent to the laboratory for analysis.

II.B.2.d Ambient Gamma Radiation Direct Radiation measurements were made using thermoluminescent dosimeters. The DLR locations were placed on and around the LGS site as follows:

A site boundary ring consisting of 16 locations (36S2, 3S1, 5S1, 7S1, 10S3, 11S1, 13S2, 14S1, 18S2, 21S2, 23S2, 25S2, 26S3, 29S1, 31S1, and 34S2) near and within the site perimeter representing fence post doses (i.e., at locations where the doses will be potentially greater than maximum annual off-site doses) from LGS releases.

An intermediate distance ring consisting of 16 locations (36D1, 2E1, 4E1, 7E1, 10E1, 10F3, 13E1, 16F1, 19D1, 20F1, 24D1, 25D1, 28D2, 29E1, 31D2, and 34E1) extending to approximately 5 miles from the site designed to measure possible exposures to close-in population.

The balance of eight locations (5H1, 6C1, 9C1, 13C1, 15D1, 17B1, 20D1, and 31D1) representing control and special interest areas such as population centers, schools, etc.

15

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 The balance of eight locations (5H1, 6C1, 9C1, 13C1, 15D1, 17B1, 20D1, and 31D1) representing control and special interest areas such as population centers, schools, etc.

The specific dosimetry locations were determined by the following criteria:

1. The presence of relatively dense population,

2. Site meteorological data taking into account distance and elevation for each of the sixteen-22 1/2-degree sectors around the site, where estimated annual dose from LGS, if any, would be most significant,

3. On hills free from local obstructions and within sight of the vents (where practical);

4. And near the closest dwelling to the vents in the prevailing downwind direction.

Two dosimeters were placed at each location in a mesh basket tube located approximately three feet above ground level. The dosimeters were exchanged quarterly and sent to Mirion Technologies for analysis.

II.B.2.e 10 CFR 20.2002 Permit Storage Area In 1996, the Limerick Generating Station received NRC approval to store slightly contaminated soils, sludges, and sediments on site per the requirements of 10 CFR 20.2002. These materials will be stored until end of the site's renewed operating license. At that time the material will be evaluated along with the site for decommissioning. The area is approximately 1.5 acres in size and was evaluated to hold a maximum of 1.12E+06 cubic feet with no more than 7E+04 cubic feet added to the area in any single year. After each material placement on the storage area, the area is graded and seeded to prevent erosion. Since all groundwater movement is to the river, the use of the REMP surface water sampling program is used as a check on potential groundwater movement from the pad. In 2021, 0 cubic feet of cooling water sludge was placed on the permitted storage area.

II.B.2.f Independent Spent Fuel Storage Installation (ISFSI)

The results from the dosimeter locations 36S2 and 3S1 were used to determine the direct radiation exposure to the nearest residence from the ISFSI pad.

II.B.3 Data Interpretation The radiological and direct radiation data collected prior to LGS becoming operational was used as a baseline with which these operational data were compared. For the purpose of this report, LGS was considered operational at initial criticality. In addition, data were compared to previous years' operational data for consistency and trending. Several factors were important in the interpretation of the data:

1. Lower Limit of Detection and Minimum Detectable Concentration The lower limit of detection (LLD) is defined as the smallest concentration of radioactive material in a sample that would yield a net count (above background) that would be detected with only a 5% probability of falsely concluding that a blank observation represents a "real" signal. The LLD is intended as a before the fact estimate of a system (including instrumentation, procedure, and sample type) and not as an after the fact criteria for the 16

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 presence of activity. All analyses are designed to achieve the required LGS detection limits for environmental sample analysis.

2. Reporting of Results Gamma spectroscopy analyzes samples for the full range of nuclides. All nuclides that identified positive results for non-natural gamma emitters are reported. Each type of sample also looks for specific nuclides which must meet LLD requirements as described above. The required nuclides and their LLDs for each type of sample are provided in Table C-3.

Means and standard deviations of positive results were calculated. The standard deviations represent the variability of measured results for different samples rather than single analysis uncertainty.

3. Minimum Detectable Activity Many results in environmental monitoring occur at or below the minimum detectable activity (MDA). In this report, all results at or below the relevant MDA are reported as being

"<MDA indicating less than the MDA value of all non-natural gamma emitters.

II.B.4 Program Exceptions For 2021 the LGS REMP had a sample recovery rate of greater than 99%. Program exceptions are listed below:

1. 2021 REMP Self-assessment Gap 1 that questions why a particular milk control location was not located for the REMP program.

An exception to ODCM Table 3.3-1 for control milk sample was found in the 2020 AREOR. Milk control location does not meet the specifications described in the ODCM. The ODCM requires 1 sample from milking animals at a control location (15-30km distance) and in the least prevalent wind direction. We currently have two control locations for milk, the distances for the two locations are 7.58km and 8.08km.

The annual land use survey required by the ODCM determined that there are no milk farms available at 15-30km in the least prevalent wind direction. (IR 04446062)

2. Telemetry indicated that power supply was lost on 5/24/21 at LGS REMP air station 13S4, located on Long View across from the substation. It was determined that power supply was lost from the pole to the sampler housing. Insufficient sample volume was collected for the week ending 06/01/21. Site electricians restored power and no further loss of sampling occurred. (IR 04426002)

3. On 8/9/21 during a routine weekly water collection it was discovered that there was a fire at the Phoenixville Water Treatment Plant on 8/7/21. This caused the basement to 17

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 fill with approximately 4ft of water. The 15F7 ISCO water sampler was overturned and possibly submerged during the flood. This caused the sample to be lost and no grab sample was able to be collected as the plant was not processing drinking water due to damage. The missed sample is allowed by the ODCM under Table 3.3-1 Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons (IR 04440941).

4. Vegetation samples at 31G1 were unavailable for collection on 09/20/21 due to plants being tilled in by the farm owner. (IR 04447818)

Each program exception was reviewed to understand the causes of the program exception.

Occasional equipment breakdowns were unavoidable. The overall sample recovery rate indicates that the appropriate procedures and equipment are in place to assure reliable program implementation.

II.B.5 Program Changes Revision 33 was approved and implemented on 12/14/21. Major changes include removal of the information center, addition of the hold pond as a release point, and an update to the X/Q factor for the milk receptor.

II.B.6 Compliance with 40CFR 190 Limits

1. Dose to Members of the Public at or Beyond Site Boundary Per the ODCM Control 6.2, the Annual Radioactive Effluent Release Report shall include an assessment of the radiation doses to the hypothetically highest exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources. The ODCM does not require population doses to be calculated. For purposes of this calculation the following assumptions were made:

x Long term annual average meteorology X/Q and D/Q and x actual gaseous effluent releases were used.

x Gamma air dose, Beta air dose, Total Body and Skin doses were attributed to noble gas releases.

x Critical organ and age group dose attributed to iodine, particulate, Carbon-14 and tritium releases.

x 100 percent occupancy factor was assumed.

x Dosimetry measurements obtained from the REMP for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) was used to determine direct radiation exposure.

x The highest doses from the critical organ and critical age group for each release pathway was summed and added to the net dosimetry measurement from nearest residence to the ISFSI for 40 CFR 190 compliance.

18

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 40 CFR 190 Compliance:

The maximum calculated dose to a real individual would not exceed 0.26 mRem (total body),

1.27 mRem (organ), or 0.26 mRem (thyroid).

All doses calculated were below all ODCM and 40 CFR Part 190 limits to a real individual.

40 CFR 190 Compliance Gaseous Effluents Particulate, Net % of Liquid Noble Iodine, C- Direct Total Applicable Limit Unit Effluents 14 Radiation Limit Gas & Tritium

Total Body Dose 1.89E-02 2.55E-01 7.83E-02 0.00E+00 3.52E-01 1.41E+00 25 mrem Organ Dose 3.26E-02 1.27E+00 7.84E-02 0.00E+00 1.38E+00 5.52E+00 25 mrem Thyroid Dose NA 2.56E-01 7.89E-02 0.00E+00 3.35E-01 4.47E-01 75 mrem II.C. RESULTS AND DISCUSSIONS All the environmental samples collected during the year were analyzed using Exelon Industrial Services laboratory procedures CY-ES-205 and CY-ES-206, except Tritium which was analyzed by GEL Laboratories (GL-RAD-A-002 REV# 24), in accordance with analytical method EPA 906.0 Modified, and Dosimetry analysis by Mirion Technologies. The analytical results for this reporting period are presented in Appendix B and are also summarized in Table 2. For discussion, the analytical results are divided into four categories. The categories are Aquatic Environment, Atmospheric Environment, Terrestrial Environment, and Direct Radiation. These categories are further divided into subcategories according to sample type (e.g. Surface Water/Drinking Water and Aquatic Organisms for Aquatic Environment).

II.C.1 Aquatic Environment The aquatic environment was evaluated by performing radiological analyses on samples of surface water, drinking water, fish, and sediment. Two-gallon water samples were collected monthly from composite samplers located at two surface water locations (13B1 and 24S1) and four drinking water locations (15F4, 15F7, 16C2, and 28F3). Control locations were 24S1, and 28F3. All samples were collected in new unused plastic bottles, which were rinsed at least twice with source water prior to collection. Fish samples comprising of the flesh of two groups, bottom feeder (Northern Hognose Sucker / Quillback / White Sucker) and predator (American Eel /

19

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Black Crappie / Channel Catfish / Flathead Catfish / Red-Breast Sunfish / Rock Bass /

Smallmouth Bass / Yellow Bullhead / White Perch), were collected semiannually at two locations, 16C5 and 29C1 (control). Sediment samples composed of recently deposited substrate were collected at three locations semiannually, 16B2, 16C4, and 33A2 (control).

II.C.1.a Surface and Drinking Water Surface and drinking water samples were analyzed for concentrations of tritium (H-3), low level iodine-131 (I-131) and gamma-emitting nuclides. Drinking water samples were also analyzed for concentrations of total gross beta. Total gross beta activities detected were consistent with those detected in previous years. No other fission or activation products were detected.

Gamma and gross beta analysis were performed on all water samples on a monthly basis Composites are made from the weekly samples. Results for all water Gamma and gross beta analyses are listed in Table B-1.

Tritium analysis was performed on all water samples on a quarterly basis. Composites are made from the weekly samples. Tritium data is given in Table B-1.

Review of the gamma spectroscopy results from the surface water samples located at the Limerick intake (24S1) and downstream of the 10 CFR 20.2002 permitted storage area showed no evidence of offsite radionuclide transport from the 2002 permitted storage area.

A Radiological Groundwater Protection Program (RGPP) was established in 2006 as part of an Exelon Nuclear fleetwide assessment of potential groundwater intrusion from the operation of the Station. Results and Discussion of groundwater samples are covered in Appendix E.

II.C.1.b Aquatic Organisms Fish (predator and bottom feeder) samples were analyzed for concentrations of gamma-emitting nuclides. Concentrations of naturally occurring potassium-40 (K-40) were consistent with those detected in previous years. No fission or activation products were detected in fish.

II.C.1.c Shoreline Sediment Sediment samples were analyzed for concentrations of gamma-emitting nuclides. No station-produced fission or activation products were found in sediment. For results, discussion, and dose to member of the public calculation see Section II.B.6.

20

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 II.C.2 Atmospheric Environment The atmospheric environment was evaluated by performing radiological analyses on samples of air particulate, airborne iodine, and milk. Airborne iodine and particulate samples were collected and analyzed weekly at seven locations (6C1, 10S3, 11S1, 13S4, 14S1, 15D1, and 22G1). The control location was 22G1. Airborne iodine and particulate samples were obtained at each location, using a vacuum pump with charcoal and glass fiber filters attached. The pumps were run continuously and sampled air at the rate of approximately one cubic foot per minute. The filters were replaced weekly and sent to the laboratory for analysis.

II.C.2.a Air Particulate Filters Air particulate samples were analyzed for concentrations of gross beta and gamma- emitting nuclides. Gross beta and cosmogenic, naturally occurring beryllium-7 (Be-7) were detected at levels consistent with those detected in previous years. No fission or activation products were detected.

Based on weekly comparisons, there was no statistical difference between the Control and Indicator radioactive particulate concentrations. The averages for the control samples were 0.021 pCi/m3, and the averages for the indicators were 0.021 pCi/m3 for the period of January to December, 2021. Maximum weekly concentrations for each station were less than 0.039 pCi/m3.

The particulate filters from each sampling location were saved and a 13 week composite was made. A gamma isotopic analysis was performed for each sampling location and corrected for decay. The results of these analyses are listed in Table B-6 II.C.2.b Air Iodine High-sensitivity I-131 analyses were performed on weekly air samples. All results were less than the minimum detectable concentration.

The air monitoring systems employed in the nuclear industry have proven to be capable of detecting very low levels of activity in the atmosphere, as activity from both the Chernobyl and Fukushima events was detected at many of the worlds nuclear power plants, including Limerick Generating Station.

Radioiodine cartridges are placed at seven locations. These cartridges are changed and analyzed each week. No positive analytical results were found on any sample. A list of values for these cartridges is given in Table B-4.

21

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 II.C.3 Terrestrial Environment

II.C.3.a Vegetation Broadleaf vegetation was collected monthly, during the growing season, at three locations (11S3, 13S3, and 31G1). The control location was 31G1.

Eleven different kinds of vegetation samples were collected and placed in new unused plastic bags and sent to the laboratory for analysis.

Broadleaf vegetation samples were analyzed for gamma-emitting nuclides. Only naturally occurring activity was detected. K-40 was detected in all samples. Be-7 was found in 30 of 33 samples. Radium-226 (Ra-226) was found in 11 of 33 samples.

Thorium-228 (Th-228) was found in 10 of 33 samples. No activity due to plant operations were detected.

Data for Non Natural Gamma Emitters is given in Table B-7.

II.C.3.b Milk Milk samples were collected biweekly at four locations (18E1, 19B1, 23F1, and 25C1) from April through November, and monthly from December through March. Location 23F1 was the control. All samples were collected in new unused two gallon plastic bottles from the bulk tank at each location, preserved with sodium bisulfite, and shipped promptly to the laboratory.

Cow milk samples were analyzed for concentrations of I-131 and gamma-emitting nuclides.

Concentrations of naturally-occurring K-40 were consistent with those detected in previous years. No fission or activation products were found.

Gamma isotopic data is given in Table B-8.

II.C.4 Direct Radiation Environmental ambient gamma radiation measurements were performed quarterly using Dosimeters of Legal Record (DLR). Levels detected were consistent with those observed in previous years and no facility-related dose was detected. A review of the dosimetry data for the nearest residence to the Independent Spent Fuel Storage Installation (ISFSI) indicates no direct dose was received.

22

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Ambient Gamma Radiation Direct Radiation measurements were made using thermoluminescent dosimeters. The DLR locations were placed on and around the LGS site as follows:

A site boundary ring consisting of 16 locations (36S2, 3S1, 5S1, 7S1, 10S3, 11S1, 13S2, 14S1, 18S2, 21S2, 23S2, 25S2, 26S3, 29S1, 31S1, and 34S2) near and within the site perimeter representing fence post doses (i.e., at locations where the doses will be potentially greater than maximum annual off-site doses) from LGS releases.

An intermediate distance ring consisting of 16 locations (36D1, 2E1, 4E1, 7E1, 10E1, 10F3, 13E1, 16F1, 19D1, 20F1, 24D1, 25D1, 28D2, 29E1, 31D2, and 34E1) extending to approximately 5 miles from the site designed to measure possible exposures to close-in population.

The balance of eight locations (5H1, 6C1, 9C1, 13C1, 15D1, 17B1, 20D1, and 31D1) representing control and special interest areas such as population centers, schools, etc.

The specific dosimetry locations were determined by the following criteria:

1. The presence of relatively dense population,

2. Site meteorological data taking into account distance and elevation for each of the sixteen-22 1/2-degree sectors around the site, where estimated annual dose from LGS, if any, would be most significant.

3. On hills free from local obstructions and within sight of the vents (where practical),

4. And near the closest dwelling to the vents in the prevailing downwind direction.

Two dosimeters were placed at each location in a mesh basket tube located approximately three feet above ground level. The dosimeters were exchanged quarterly and sent to Mirion Technologies for analysis.

10 CFR 20.2002 Permit Storage Area In 1996, the Limerick Generating Station received NRC approval to store slightly contaminated soils, sludges, and sediments on site per the requirements of 10 CFR 20.2002. These materials will be stored until end of the site's renewed operating license. At that time the material will be evaluated along with the site for decommissioning. The area is approximately 1.5 acres in size and was evaluated to hold a maximum of 1.12E+06 cubic feet with no more than 7E+04 cubic feet added to the area in any single year. After each material placement on the storage area, the area is graded and seeded to prevent erosion. Since all groundwater movement is to the river, the use of the REMP surface water sampling program is used as a check on potential groundwater movement from the pad. In 2021, 0 cubic feet of cooling water sludge was placed on the permitted storage area.

Independent Spent Fuel Storage Installation (ISFSI)

The results from the dosimeter locations 36S2 and 3S1 were used to determine the direct radiation exposure to the nearest residence from the ISFSI pad.

23

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 II.D. CONCLUSION In assessing the data gathered for this report and comparing these results with preoperational data, it was concluded that the operation of LGS had no adverse radiological impact on the environment.

In 2021, the Limerick Generating Station released to the environment through the radioactive effluent liquid and gaseous pathways approximately 132 curies of noble gas, fission and activation products and approximately 36 curies of tritium. The dose from both liquid and gaseous effluents was conservatively calculated for the Maximum Exposed Member of the Public.

24

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Table 1 Synopsis of 2021 Limerick Generating Station Radiological Environmental Monitoring Program Sample Type Sampling Number of Number Analysis Analysis Number Frequency1 Locations Collected Frequency1 Analyzed Aquatic Environment Surface Water, MC 6 72 Gamma MC 72 Drinking Water Gross Beta MC 48 Tritium QC 24 Fish2 SA 2 8 Gamma SA 8 Shoreline Sediment SA 3 3 Gamma SA 3 Atmospheric Environment Air Iodine3 W 7 370 I-131 W 370 Air Particulates4 W 7 370 Gross Beta W 370 Gamma QC 28 25

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Table 1 Synopsis of 2021 Limerick Generating Station Radiological Environmental Monitoring Program Sample Type Sampling Number of Number Analysis Analysis Number Frequency1 Locations Collected Frequency1 Analyzed Terrestrial Environment Milk5 M/BW 4 88 Gamma W 88 Vegetation6 M 3 33 Gamma M 33 Dosimetry Q 40 320 Direct Radiation Q 320 1

W=Weekly, BW=BiWeekly (15 days), M=Monthly (31 days), Q=Quarterly (92 days), SA=Semiannual, A=Annual, C=Composite

2 Twice during fishing season including at least four species

3 The collection device contains activated charcoal

4 Beta counting is performed >= 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following filter change. Gamma spectroscopy performed on quarterly composite of weekly samples

5 Bi-Weekly during growing season.

6 Monthly during growing season. Samples include broad leaf vegetation

26

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Table 2 Annual Summary of Radioactivity in the Environs of the Limerick Generating Station Medium or Type and Total Lower Limit of Indicator Location with Highest Annual Control Locations Pathway Sampled Number of Analyses Detection (LLD) Locations Mean Highest Annual Mean (F) / Range1 Mean (F)/Range (Unit of Performed (F)/Range1 Mean Measurement) Name/Distance &

Direction2 Aquatic Environment Surface Water, Gross Beta (48) 4 3 (36/36) AQUA Water 3 (12/12) 3 (12/12)

Drinking Water (1.43-4.38) 15F4 (1.94-4.38) (2.44-4.45)

(pCi/L) 13.9 km Atmospheric Environment Air Particulates Gross Beta (370) 1.0 2.1 (317/317) Spring City Sub. 2.3 (52/52) 2.1 (53/53)

(10-2 pCi/m3) (0.9-3.9) 15D1 (1.2-3.8) (1.0-3.6) 5.14 km SE Dosimetry Thermoluminescent NA 17.9(312/312) 500KV Substation 22.6 (8/8) 22.1 (8/8)

(mrem/Qtr) Dosimetry (320) (11.5-27.5) 13S2 (14.5-27.5) (19.6-24.7) 0.04 km SE 1

Mean and range based upon detectable measurements only. Fraction (F) of detectable measurements at specified location is indicated in parentheses

2 From the centerpoint of the containment building

27

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 V. REFERENCES (1) Environmental Report Operating License Stage, Limerick Generating Station, Units 1 and 2, Volumes 1-5 Philadelphia Electric Company (2) NUREG-1302 Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors (3) Branch Technical Position Paper, Regulatory Guide 4.8, Revision 1, November 1979 (4) Pre-operational Radiological Environmental Monitoring Program Report, Limerick Generating Station Units 1 and 2, 1 January 1982 through 21 December 1984, Teledyne Isotopes and Radiation Management Corporation (5) CY-LG-170-301 Current Revision, Limerick Generating Station Units 1 and 2 Offsite Dose Calculation Manual (6) Exelon Industrial Services Sampling Procedures

a. CY-ES-214, Collection of RGPP Water Samples for Radiological Analysis

b. CY-ES-237, Air Iodine and Air Particulate Sample Collection for Radiological

c. CY-ES-239, EIS Collection Exchange of Field Dosimeters for Radiological Analysis

d. CY-ES-241, Vegetation Sample Collection for Radiological Analysis

e. CY-ES-242, Soil and Sediment Sample Collection for Radiological Analysis

f. CY-ES-247, Precipitation Sampling and Collection for Radiological Analysis (7) Exelon Industrial Services Analytical Procedures

a. CY-ES-204, Sample Preparation for Gamma Analysis

b. CY-ES-205, Operation of HPGE Detectors with the Genie PC Counting System

c. CY-ES-206, Operation of the Tennelec S5E Proportional Counter

d. CY-ES-246, Sample Preparation for Gross Beta Analysis (8) Limerick Generating Station 2021 Land use Survey (9) CY-AA-170-1000, Radiological Environmental Monitoring Program (REMP) and Meteorological Program Implementation.

(10) Teledyne Browne Engineering, (TBE) 2018 Analysis Procedures Current Revisions

a. TBE-2001 Alpha Isotopic and Pu-241

b. TBE-2006 Iron-55 Activity in Various Matrices

c. TBE-2007 Gamma Emitting Radioisotope Analysis

d. TBE-2008 Gross Alpha and/or Gross Beta Activity in Various Matrices

d. TBE-2011 Tritium Analysis in Drinking Water by Liquid Scintillation

e. TBE-2013 Radionickel Activity in Various Matrices 28

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353

f. TBE-2019 Radiostrontium Analysis by Ion Exchange (11) GEL Laboratory Procedures

a. GL-RAD-A-002 Tritium

b. GL-RAD-A-022 Ni-63

c. GL-RAD-A-004 Sr89/90, Liquid

d. GL-RAD-A-040 Fe-55 (12) Normandeau Associates, Inc. (NAI) Sampling Procedures Current Revisions

a. Procedure No. ER20 Collection of Bottom Sediment for Radiological Analysis (13) Mirion Technologies, Proprietary procedures (14) Teledyne Browne Engineering Environmental Services, 4th Quarter 2021 Quality Assurance Report, January - December 2021 (15) GEL 2021 Annual Environmental QA Report

29

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 APPENDIX A Sample Locations for the REMP Appendix A contains information concerning the environmental samples which were collected during this operating period.

Sample locations and specific information about individual locations for the Limerick Generating Station are given in Table A-1 and A-2. Figure A-1 shows the Environmental Sampling Locations within 1 mile of the Limerick Generating Station. Figures A-2 shows the Environmental Sampling Locations Between 1 and 5 miles and A-3 shows the locations Greater than 5 miles from Limerick Generating Station

30

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 TABLE OF CONTENTS - SAMPLING LOCATIONS Table Title Page A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station ......32

A-2 Locations of Environmental Sampling Stations for the Limerick Generating Station ......33

Figure Title Page A-1 Limerick Generating Station Sample Locations ................................................................34

A-2 Limerick Generating Station Sample Locations Locations ...............................................35

A-3 Limerick Generating Station Sample Locations ................................................................36

A-4 Gross Beta in Public Water for the Last Ten Years ...........................................................37

A-5 Gross Beta in Air for the Last Ten Years ..........................................................................38

A-6 Annual Trending of Air Activity (Gross Beta) ..................................................................39

A-7 2021 Monthly Gross Beta Concentrations in Drinking Water, (16C2) ............................40

A-8 2021 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers .......................................................................................................................41

31

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 TABLE A-1 Locations of Environmental Sampling Stations for the Limerick Generating Station Distance and Direction from Site Station Description (KM) (Miles) (Sector) 10S3 10S3 0.8 0.5 E 11S1 11S1 0.6 0.4 ESE 11S3 Training Center 0.6 0.3 ESE 13B1 PA American 2.8 1.7 SE 13S3 500 Kv Sub 0.4 0.2 SE 13S4 13S4 0.4 0.2 SE 14S1 14S1 1.0 0.6 SSE 15D1 15D1 5.1 3.2 SE 15F4 15F4 13.9 8.6 SE 15F7 15F7 10.2 6.3 SSE 16B2 16B2 2.2 1.3 SSE 16C2 16C2 4.3 2.7 SSE 16C4 16C4 3.5 2.2 SSE 16C5 16C5 -- -- Downstream of Discharge 18E1 18E1 6.8 4.2 S 19B1 19B1 3.1 2.0 SSW 22G1 22G1 (Control) 28.5 17.7 SW 23F1 23F1 (Control) 8.1 5.0 SW 24S1 24S1 (Control) 0.3 0.2 SW 25C1 25C1 4.3 2.7 WSW 28F3 28F3 (Control) 9.4 5.8 WNW 29C1 29C1 (Control) -- -- Upstream of Intake 31G1 31G1 (Control) 21.9 13.6 NW 33A2 33A2 (Control) 1.4 0.8 NNW 6C1 6C1 3.4 2.1 Ne 11S2 11S2 (QC collocated with 11S1) 0.6 0.4 ESE

32

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 TABLE A-2 Locations of Environmental Dosimetry for the Limerick Generating Station Distance and Direction from Site Location Location Description (KM) (Miles) (Sector)

Inner Ring 36S2 Evergreen & Sanatoga Road 1.0 0.6 N 3S1 Sanatoga Road 0.7 0.4 NNE 5S1 Possum Hollow Road 0.7 0.4 NE 7S1 LGS Training Center 0.9 0.6 ENE 10S3 Keen Road 0.8 0.5 E 11S1 LGS Information Center 0.6 0.4 ESE 13S2 500 KV Substation 0.7 0.4 SE 14S1 Longview Road 1.0 0.6 SSE 18S2 Rail Line along Longview Road 0.4 0.3 S 21S2 Near Intake Building 0.3 0.2 SSW 23S2 Transmission Tower 0.9 0.5 SW 25S2 Sector Site Boundary 0.7 0.5 WSW 26S3 Met. Tower #2 0.6 0.4 W 29S1 Sector Site Boundary 0.9 0.5 WNW 31S1 Sector Site Boundary 0.4 0.3 NW 34S2 Met. Tower #1 0.9 0.6 NNW Outer Ring *36D1 Siren Tower No. 147 5.6 3.5 N

2E1 Laughing Waters GSC 7.7 4.8 NNE

4E1 Neiffer Road 7.7 4.8 NE

7E1 Pheasant Road 6.9 4.3 ENE

10E1 Royersford Road 6.3 4.0 E

10F3 Trappe Substation 9.0 5.6 ESE

13E1 Vaughn Substation 6.9 4.3 SE

16F1 Pikeland Substation 8.1 5.0 SSE

19D1 Snowden Substation 5.6 3.5 S

20F1 Sheeder Substation 8.4 5.2 SSW

24D1 Porters Mill Substation 6.4 4.0 SW

25D1 Hoffecker & Keim Streets 6.4 4.0 WSW

28D2 W. Cedarville Road 6.2 4.0 W

29E1 Prince Street 8.0 5.0 WNW

31D2 Popular Substation 6.2 4.0 NW 34E1 Varnell Road 7.4 4.6 NNW Control & 5H1 C Birch Substation (control) 40.0 24.8 NE Special Interest 6C1 Limerick Airport 3.4 2.1 NE 9C1 Reed Road 3.5 2.2 E 13C1 King Road 4.6 2.8 SE 15D1 Spring City Substation 5.1 3.2 SE 17B1 Linfield Substation 2.6 1.6 S 20D1 Ellis Woods Road 5.0 3.0 SSW 31D1 Lincoln Substation 4.8 3.0 WNW 33

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-1 Limerick Generating Station Sample Locations Environmental Sampling Locations Within 1 mile of the Limerick Generating Station, 2021

RIDGE PIKE N

NE ENE s

I '*500 750 1,SOO F: i 34

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-2 Limerick Generating Station Sample Locations Environmental Sampling Locations Between 1 and 5 miles from the Limerick Generating Station, 2021

35

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-3 Limerick Generating Station Sample Locations Environmental Sampling Locations Greater than 5 miles from the Limerick Generating Station, 2021 36

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-4 Gross Beta in Public Water for the Last Ten Years 2012-2021 Gross Beta in Public Water for the Last Ten Years 10

~ : l\J\~ ~-l~~xrv)A~ ) '11r~~!*

0

'I ~

1013 1014 I0IS 1016 1011 2018 1019 1010 1011 1012

. - 15F4 (AQUA water company) -+- I SF7 (Phoenl,vlue water works) 16C2 (PA AmHiean) ..- 2BF3 (Pottstown Borougtt Autnority, water DistribUUon Division) n Show Y*ax1s on I ooanthm1c sc::ale 37

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-5 Gross Beta in Air for the Last Ten Years 2012-2021 Gross Beta In Air ror the last Ten Years MS

,., 006 E

-.. 004 0

a.

001 0

2011 201* 1015 IOlo 1017 1018 1019 IOlO 2011

10S3 (Kttn R~d) + 11s1(LGS Inrorm1Uon Ctclttr) 13S4 (longvltW Rold, nu, ~oo ICY Yard) ... 14S1 (Longview Road)

.._ 1501 (Spring City SubsUIUon) + 2201 (Manoi Substation) 6C1 (Llmtrick Alrpor1) 0 Show Y*axts oo Loganthmlc scale

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-6 Annual Trending of Air Activity (Gross Beta) 2021WeeklyGrossBetaConcentrationsinAirParticulateSamplescollectedforthe

LimerickRadiologicalEnvironmentalMonitoringProgramas102pCi/m3 7.50 6.50 5.50 4.50 3.50 102 pCi/cubicmeter 2.50 1.50 0.50 1/4/2021 2/4/2021 3/4/2021 4/4/2021 5/4/2021 6/4/2021 7/4/2021 8/4/2021 9/4/2021 10/4/2021 11/4/2021 12/4/2021 Calendar 6C1 10S3 11S1 14S1 15D1 22G1 13S4 39

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-7 2021 Monthly Gross Beta Concentrations in Drinking Water, (16C2)

Split between EIS and TBE 10.00 9.00 8.00 7.00 6.00 5.00 pCi/Liter 4.00 3.00 2.00 1.00 0.00 3Feb21 3Mar21 3Apr21 3May21 3Jun21 3Jul21 3Aug21 3Sep21 3Oct21 3Nov21 3Dec21 3Jan22 Calendar EIS TBE

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 Figure A-8 2021 Weekly Gross Beta Concentrations in Air Particulate Samples from Co-Located Air samplers 11S1 and 11S2 analyzed by EIS and TBE as 10-2pCi/m3 7.50 6.50 5.50 4.50 3.50 E2pCi/cubicmeter 2.50 1.50 0.50 1/4/2021 2/4/2021 3/4/2021 4/4/2021 5/4/2021 6/4/2021 7/4/2021 8/4/2021 9/4/2021 10/4/2021 11/4/2021 12/4/2021 Calendar 11S1 11S2 41

January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 APPENDIX B Analysis Results for the REMP Appendix B is a presentation of the analytical results for the Limerick Generating Station radiological environmental monitoring programs.

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January 1 - December 31, 2021 Docket Nos. 50-352, 50-353 TABLE OF CONTENTS - ANALYTICAL RESULTS Table Title Page B-1 Concentration of Tritium, Gamma Emitters and Gross Beta in Surface and Drinking Water ..................................................................................................................................44