ML18141A689

Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2017

ML18141A689
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Site:	Pilgrim
Issue date:	05/15/2018
From:	Miner P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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• ~*Entergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth , MA 02360 May15,2018 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington , DC 20555-0001

SUBJECT:

Annual Radiological Environmental Operating Report for January 1 through December 31 , 2017 Pilgrim Nuclear Power Station Docket No. 50-293 Renewed License No. DPR-35 LETTER NUMBER: 2.18.039

Dear Sir or Madam:

In accordance with Pilgrim Nuclear Power Station Technical Specification 5.6.2, Entergy Nuclear Operations, Inc. submits the attached Annual Radiological Environmental Operating Report for January 1 through December 31 , 2017.

If you have any questions or require additional information , please contact me at (508) 830-7127.

There are no regulatory commitments contained in this letter.

Peter J ner Manage , Regulatory Assurance PJM/mp

Attachment:

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report

Entergy Nuclear Operations, Inc. Letter No. 2.18.039 Pilgrim Nuclear Power Station Page 2 of 2 cc: Mr. David C. Lew Acting Regional Administrator, Region I U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard , Suite 100 King of Prussia, PA 19406-2713 Mr. John Lamb , Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 8 B1A Wash ington , DC 20555 Mr. John Giarrusso, Jr.

Planning , Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham , MA 01702 NRC Senior Resident Inspector Pilgrim Nuclear Power Station

Attachment Letter Number 2.18.039 Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report

PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 Annual Radiological Environmental Operating Report January 1 through December 31, 2017

• --==-*Entergy Page 1

• • _::;;-Entergy PILGRIM NUCLEAR POWER STATION Facility Operating License DPR-35 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31, 2017 L. Hageman Senior HP/C emistry Specialist Reviewed by: -=#i ~~/~

't. . Blankenbiller Ch.emis?,*Man~ ,

Reviewedby: .k. 4 S~Brewer acting for L. Pepple 5 / 10/,.(

Radiation Protection Manager Page 2 2

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2017 TABLE OF CONTENTS SECTION SECTION TITLE PAGE EXECUTIVE

SUMMARY

6

1.0 INTRODUCTION

8 1.1 Radiation and Radioactivity 8 1.2 Sources of Radiation 9 1.3 Nuclear Reactor Operations 10 1.4 Radioactive Effluent Control 16 1.5 Radiolog ical Impact on Humans 18 2 .0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 23 2.1 Pre-Operational Monitoring Results 23 2.2 Environmental Monitori ng Locations 24 2.3 Interpretation of Radioactivity Analyses Results 27 2.4 Ambient Radiation Measurements 28 2 .5 A ir Particu late Filter Radioactivity Analyses 29 2.6 Charcoal Cartridge Radioactivity Analyses 30 2.7 Milk Radioactivity Analyses 30 2.8 Forage Rad ioactivity Analyses 31 2.9 VegetableNegetation Radioactivity Analyses 31 2.10 Cranberry Radioactivity Analyses 32 2.11 Soil Radioactivity Analyses 32 2.12 Surface Water Radioactivity Analyses 32 2.13 Sediment Radioactivity Analyses 33 2.14 Irish Moss Radioactivity Analyses 33 I

2.15 Shellfish Rad ioactivity Analyses 33 2.16 Lobster Rad ioactivity Analyses 34 2.17 Fish Radioactivity Analyses 34 3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS 68

4.0 REFERENCES

70 APPENDIX A Special Studies 71 APPENDIX B Effluent Release Information 72 APPENDIX C Land Use Census 82 APPENDIX D Environmental Monitori ng Program Discrepancies 83 APPENDIX E Environmental Dosimetry Company Annual Quality Assurance 86 Status Report APPENDIX F Teledyne Brown Engineering Environmental Services Annual 101 2017 Quality Assurance Report Page 3 3

Pilgrim Nuclear Power Station Annual Radiologica l Environmental Operating Report January-December 2017 LIST OF TABLES TABLE TABLE TITLE PAGE 1.2-1 Radiation Sources and Corresponding Doses 9 1.3-1 PNPS Operating Capacity Factor During 2017 10 2.2-1 Routine Rad iological Environmental Sampling Locations 35 2.4-1 Offsite Environmental TLD Resu lts 37 2.4-2 Onsite Environmental TLD Results 39 2.4-3 Average TLD Exposures By Distance Zone During 2017 40 2.5-1 Air Particulate Filter Radioactivity Analyses 41 2.6-1 Charcoal Cartridge Radioactivity Analyses 42 2.7-1 Milk Radioactivity Analyses 43 2.8-1 Forage Radioactivity Analyses 44 2.9-1 VegetableNegetation Rad ioactivity Analyses 45 2.10-1 Cranberry Radioactivity Analyses 46 2.12-1 Surface Water Radioactivity Analyses 47 2.13-1 Sediment Radioactivity Analyses 48 2.14-1 Irish Moss Rad ioactivity Ana lyses 49 2.15-1 Shellfi sh Radioactivity Analyses 50 2.16-1 Lobster Radioactivity Analyses 51 2.17-1 Fish Radioactivity Analyses 52 3.0-1 Radiation Doses From 2017 Pilgrim Station Operations 69 8 .1 Supplemental Information 73 8 .2-A Gaseous Effluents Summation of All Releases 74 B.2-8 Gaseous Effluents - Elevated Releases 75 B.2-C Gaseous Effluents - Ground Level Releases 77 B.3-A Liqu id Effluents Summation of All Releases 79 8 .3-8 Liquid Effluents: January-December 2017 80 Page 4 4

Pilgrim Nuclear Power Station Annual Radiological Environmental Operating Report January-December 2017 LIST OF FIGURES FIGURE FIGURE TITLE PAGE 1.3-1 Radioactive Fission Product Formation 12 1.3-2 Radioactive Activation Product Formation 13 1.3-3 Barriers to Confine Radioactive Materials 14 1.5-1 Radiation Exposure Pathways 20 2.2-1 Environmental TLD Locations Within the PNPS Protected Area 53 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer 55 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers 57 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers 59 2.2-5 Terrestrial and Aquatic Sampling Locations 61 2.2-6 Environmental Sampling and Measurement Control Locations 63 2.5-1 Airborne Gross Beta Radioactivity Levels: Near Station Monitors 65 2.5-2 Airborne Gross Beta Radioactivity Levels: Property Line Monitors 66 2.5-3 Airborne Gross Beta Radioactivity Levels: Offsite Monitors 67 Page 5 5

EXECUTIVE

SUMMARY

ENTERGY NUCLEAR PILGRIM NUCLEAR POWER STATION ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT JANUARY 01 THROUGH DECEMBER 31 , 2017 INTRODUCTION This report summarizes the results of the Entergy Nuclear Radiological Environmental Monitoring Program (REMP) conducted in the vicinity of Pilgrim Nuclear Power Station (PNPS) during the period from January 1 to December 31 , 2017. This document has been prepared in accordance with the requirements of PNPS Technical Specifications section 5.6.2.

The REMP has been established to monitor the radiation and radioactivity released to the environment as a result of Pilgrim Station's operation . This program , initiated in August 1968, includes the collection , analysis , and evaluation of radiological data in order to assess the impact of Pilgrim Station on the environment and on the general public.

SAMPLING AND ANALYSIS The environmental sampling media collected in the vicinity of PNPS and at distant locations include air particulate filters , charcoal cartridges, animal forage , vegetation , cranberries, seawater, sediment, Irish moss, shellfish , American lobster, and fishes .

During 2017 , there were 1,239 samples collected from the atmospheric, aquatic, and terrestrial environments. In addition , 450 exposure measurements were obtained using environmental thermoluminescent dosimeters (TLDs) .

A small number of inadvertent issues were encountered during 2017 in the collection of environmental samples in accordance with the PNPS Offsite Dose Calculation Manual (ODCM). Equipment failures and power outages resulted in a small number of instances in which lower than normal volumes were collected at the airborne sampling stations . 566 of 572 air particulate and charcoal cartridges were collected and analyzed as required . A full description of any discrepancies encountered with the environmental monitoring program is presented in Appendix D of this report.

There were 1,283 analyses performed on the environmental media samples. Analyses were performed by Teledyne Brown Engineering Laboratory in Knoxville , TN . Samples were analyzed as required by the PNPS ODCM .

LAND USE CENSUS The annual land use census in the vicinity of Pilgrim Station was conducted as required by the PNPS ODCM between August 30 and November 8, 2017. A total of 21 vegetable gardens having an area of more than 500 square feet were identified within five kilometers (three miles) of PNPS . No new milk or meat animals were located during the census . Of the 21 garden locations identified , samples were collected at or near four of the gardens as part of the environmental monitoring program . Other samples of natural vegetation were also collected in predicted high-deposition areas .

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RADIOLOGICAL IMPACT TO THE ENVIRONMENT During 2017, samples (except charcoal cartridges) collected as part of the REMP at Pilgrim Station continued to contain detectable amounts of naturally-occurring radioactive materials. No samples indicated any detectable radioactivity attributable to Pilgrim Station operations. Offsite ambient radiation measurements using environmental TLDs beyond the site boundary ranged between 44 and 86 milliRoentgens per year. The range of ambient radiation levels observed with the TLDs is consistent with natural background radiation levels for Massachusetts.

RADIOLOGICAL IMPACT TO THE GENERAL PUBLIC During 2017, radiation doses to the general public as a result of Pilgrim Station 's operation continued to be well below the federal limits and much less than the collective dose due to other sources of man-made (e.g., X-rays , medical , fallout) and naturally-occurring (e .g., cosmic, radon) radiation .

The calculated total body dose to the maximally exposed member of the general public from radioactive effluents and ambient radiation resulting from PNPS operations for 2017 was approximately 0.8 mrem for the year. This conservative estimate is well below the EPA's annual dose limit to any member of the general public and is a fraction of a percent of the typical dose received from natural and man-made radiation .

CONCLUSIONS The 2017 Radiological Environmental Monitoring Program for Pilgrim Station resulted in the collection and analysis of hundreds of environmental samples and measurements. The data obtained were used to determine the impact of Pilgrim Station's operation on the environment and on the general public.

An evaluation of direct radiation measurements , environmental sample analyses, and dose calculations showed that all applicable federal criteria were met. Furthermore, radiation levels and resulting doses were a small fraction of those that are normally present due to natural and man-made background radiation .

Based on this information , there is no significant radiological impact on the environment or on the general public due to Pilgrim Station's operation.

Page 7 7

1.0 INTRODUCTION

The Radiological Environmental Monitoring Program for 2017 performed by Entergy Nuclear Company for Pilgrim Nuclear Power Station (PNPS) is discussed in this report. Since the operation of a nuclear power plant results in the release of small amounts of radioactivity and low levels of radiation , the Nuclear Regulatory Commission (NRC) requires a program to be established to monitor radiation and radioactivity in the environment (Reference 1). This report, which is required to be published annually by Pilgrim Station's Technical Specifications section 5.6.2, summarizes the results of measurements of radiation and radioactivity in the environment in the vicinity of the Pilgrim Station and at distant locations during the period January 1 to December 31 , 2017.

The Radiological Environmental Monitoring Program consists of taking radiation measurements and collecting samples from the environment, analyzing them for radioactivity content, and interpreting the resu lts . With emphasis on the critical radiation exposure pathways to humans, samples from the aquatic, atmospheric, and terrestrial environments are collected . These samples include, but are not limited to : air, animal forage , vegetation , cranberries , seawater, sediment, Irish moss, shellfish ,

American lobster, and fish . Thermoluminescent dosimeters (TLDs) are placed in the environment to measure gamma radiation levels. The TLDs are processed and the environmental samples are analyzed to measure the very low levels of radiation and radioactivity present in the environment as a result of PNPS operation and other natural and man-made sources . These results are reviewed by PNPS's Chemistry staff and have been reported semiannually or annually to the Nuclear Regulatory Commission and others since 1972.

In order to more fully understand how a nuclear power plant impacts humans and the environment, background information on radiation and radioactivity, natural and man-made sources of radiation ,

reactor operations , radioactive effluent controls , and radiological impact on humans is provided. It is believed that this information will assist the reader in understanding the radiological impact on the environment and humans from the operation of Pilgrim Station.

1.1 Radiation and Radioactivity All matter is made of atoms. An atom is the smallest part into which matter can be broken down and still maintain all its chemical properties. Nuclear radiation is energy , in the form of waves or particles that is given off by unstable, radioactive atoms.

Radioactive material exists naturally and has always been a part of our environment. The earth's crust, for example , contains radioactive uranium, radium , thorium , and potassium . Some radioactivity is a result of nuclear weapons testing . Examples of radioactive fallout that is normally present in environmental samples are cesium-137 and strontium-90. Some examples of radioactive materials released from a nuclear power plant are cesium-137 , iodine-131 , strontium-90, and cobalt-60 .

Radiation is measured in units of millirem , much like temperature is measured in degrees. A millirem is a measure of the biological effect of the energy deposited in tissue. The natural and man-made radiation dose received in one year by the average American is approximately 620 mrem (References 2, 3 , 4) .

Radioactivity is measured in curies. A curie is that amount of radioactive material needed to produce 37 ,000 ,000 ,000 nuclear disintegrations per second . This is an extremely large amount of radioactivity in comparison to environmental radioactivity . That is why radioactivity in the environment is measured in picocuries. One picocurie is equal to one trillionth of a curie .

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1.2 Sources of Radiation As mentioned previously , naturally occurring radioactivity has always been a part of our environment.

Table 1.2-1 shows the sources and doses of radiation from natural and man-made sources .

Table 1.2-1 Radiation Sources and Corresponding Doses <1l NATURAL MAN-MADE Radiation Dose Radiation Dose Source (millirem/year) Source (millirem/year)

Internal , inhalation<2l 230 Medica1<3 l 300 4

External , space 30 Consumer<l 12 5

Internal, ingestion 30 lndustria1<l 0.6 External , terrestrial 20 Occupational 0.6 Weapons Fallout < 1 Nuclear Power Plants < 1 Approximate Total 310 Approximate Total 315 Combined Annual Average Dose: Approximately 620 to 625 millirem/year 1

( ) Information from NCRP Reports 160 and 94 2

( l Primarily from airborne radon and its radioactive progeny 3

( l Includes CT (150 millirem), nuclear medicine (74 mrem), interventional fluoroscopy (43 mrem) and conventional radiography and fluoroscopy (30 mrem) 4

( l Primarily from cigarette smoking (4.6 mrem), commercial air travel (3.4 mrem) , building materials (3.5 mrem) , and mining and agriculture (0.8 mrem) 5

<l Industrial, security, medical , educational , and research Cosmic radiation from the sun and outer space penetrates the earth's atmosphere and continuously bombards us with rays and charged particles. Some of this cosmic radiation interacts with gases and particles in the atmosphere , making them radioactive in turn . These radioactive byproducts from cosmic ray bombardment are referred to as cosmogenic radionuclides . Isotopes such as beryllium-?

and carbon-14 are formed in this way. Exposure to cosmic and cosmogenic sources of radioactivity results in approximately 30 mrem of radiation dose per year.

Additionally , natural radioactivity is in our body and in the food we eat (approximately 30 millirem/yr) ,

the ground we walk on (approximately 20 millirem/yr) and the air we breathe (approximately 230 millirem/yr). The majority of a person's annual dose results from exposure to radon and thoron in the air we breathe. These gases and their radioactive decay products arise from the decay of naturally occurring uranium, thorium and radium in the soil and building products such as brick, stone, and concrete . Radon and thoron levels vary greatly with location , primarily due to changes in the concentration of uranium and thorium in the soil. Residents at some locations in Colorado, New York ,

Pennsylvania, and New Jersey have a higher annual dose as a result of higher levels of radon/thoron gases in these areas. In total , these various sources of naturally-occurring radiation and radioactivity contribute to a total dose of approximately 310 mrem per year.

In addition to natural radiation , we are normally exposed to radiation from a number of man-made sources. The single largest doses from man-made sources result from therapeutic and diagnostic Page 9 9

appl ications of x-rays and radiopharmaceuticals . The annual dose to an individual in the U.S. from med ical and dental exposure is approximately 300 mrem. Consumer activities, such as smoking ,

commercial air travel , and building materials contribute approximately 13 mrem/yr. Much smaller doses result from weapons fallout (less than 1 mrem/yr) and nuclear power plants. Typically, the average person in the United States receives approximately 314 mrem per year from man-made sources. The collective dose from naturally-occurring and man-made sources results in a total dose of approximately 620 mrem/yr to the average American .

1.3 NuciearReactorOperations Pilgrim Station generates approximately 700 megawatts of electricity at full power, which is enough electricity to supply the entire city of Boston , Massachusetts . Pilgrim Station is a boiling water reactor whose nuclear steam supply system was provided by General Electric Co . The nuclear station is located on a 1600-acre site approximately eight kilometers (five miles) east-southeast of the downtown area of Plymouth, Massachusetts. Commercial operation began in December 1972.

Pilgrim Station was operational during most of 2017 , with the following exceptions : a shutdown in Feb-2017 for blizzard conditions ; a downpower in Apr-2017 due to Main Condenser delta T; a shutdown in Apr- May 2017 for refueling outage 21 ; two downpowers Oct-2017 for high Sea Water inlet temperature and a steam leak repair. The resulting monthly capacity factors are presented in Table 1.3-1 .

TABLE1 .3-1 PNPS OPERATING CAPACITY FACTOR DURING 2017 (Based on rated reactor thermal power of 2028 Megawatts-Thermal)

Month Percent Capacity January 99 .8%

February 85.3%

March 98.4 %

April 95 .2%

May 81 .2%

June 98 .5%

July 99 .9%

August 98 .7%

September 98 .2%

October 97.5 %

November 99 .9%

December 99.8%

Annual Average 97 .3%

Nuclear-generated electricity is produced at Pilgrim Station by many of the same techniques used for conventional oil and coal-generated electricity. Both systems use heat to boil water to produce steam .

Page 10 10

The steam turns a turbine , which turns a generator, producing electricity. In both cases , the steam passes through a condenser where it changes back into water and recirculates back through the system . The cooling water source for Pilgrim Station is the Cape Cod Bay.

The key difference between Pilgrim's nuclear power and conventional power is the source of heat used to boil the water. Conventional plants burn fossil fuels in a boiler, while nuclear plants make use of uranium in a nuclear reactor.

Inside the reactor, a nuclear reaction called fission takes place . Particles , called neutrons, strike the nucleus of a uranium-235 atom, causing it to split into fragments called radioactive fission products .

The splitting of the atoms releases both heat and more neutrons. The newly-released neutrons then collide with and split other uranium atoms , thus making more heat and releasing even more neutrons, and on and on until the uranium fuel is depleted or spent. This process is called a chain reaction .

The operation of a nuclear reactor results in the release of small amounts of radioactivity and low levels of radiation . The radioactivity originates from two major sources, radioactive fission products and radioactive activation products.

Radioactive fission products, as illustrated in Figure 1.3-1 (Reference 5) , originate from the fissioning of the nuclear fuel. These fission products get into the reactor coolant from their release by minute amounts of uranium on the outside surfaces of the fuel cladding , by diffusion through the fuel pellets and cladding and , on occasion , through defects or failures in the fuel cladding. These fission products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive fission products on the pipes and equipment emit radiation . Examples of some fission products are krypton-85 (Kr-85) , strontium-90 (Sr-90) , iodine-131 (1-131) , xenon-133 (Xe-133) , and cesium-137 (Cs-137) .

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Nuclear Fission Fission is the splitting of the uranium-235 atom by a neutron to release heat and more neutrons, creating a chain reaction .

Radiation and fission products are by-products of the process.

L 1..,.

L Uranium Neutrons

~

Neutron Uranium Fission Products . .

Uranium Fission Products Figure 1.3-1 Radioactive Fission Product Formation Page 12 12

Rad ioactive activation products (see Figure 1.3-2) , on the other hand , originate from two sources.

The first is by neutron bombardment of the hydrogen , oxygen and other gas (helium, argon , nitrogen) molecules in the reactor cooling water. The second is a result of the fact that the internals of any piping system or component are subject to minute yet constant corrosion from the reactor cooling water. These minute metallic particles (for example: nickel , iron, cobalt, or magnesium) are transported through the reactor core into the fuel region , where neutrons may react with the nuclei of these particles , producing radioactive products. So , activation products are nothing more than ordinary naturally-occurring atoms that are made unstable or radioactive by neutron bombardment.

These activation products circulate along with the reactor coolant water and will deposit on the internal surfaces of pipes and equipment. The radioactive activation products on the pipes and equipment emit radiation . Examples of some activation products are manganese-54 (Mn-54) , iron-59 (Fe-59) , cobalt-60 (Co-60) , and zinc-65 (Zn-65) .

_G) Co-59 Stable Radioactive Neutron Cobalt Nucleus Cobalt Nucleus Figure 1.3-2 Radioactive Activation Product Formation At Pilgrim Nuclear Power Station there are five independent protective barriers that confine these radioactive materials. These five barriers , which are shown in Figure 1.3-3 (Reference 5), are :

• fuel pellets ;

• fuel cladding ;

• reactor vessel and piping ;

• primary containment (drywell and torus) ; and ,

• secondary containment (reactor building).

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SIMPLIFIED DIAGRAM OF A BOILING WATER REACTOR

4. PRIMARY CONTAINMENT

3. REACTOR VESSEL

1. FUEL PELLETS

5. SECONDARY CONTAINMENT

@========@

CONDENSER REACTOR BUILDING DRYWELL Figure 1.3-3 Barriers To Confine Radioactive Materials Page 14 14

The ceramic uranium fuel pellets provide the first barrier. Most of the radioactive fission products are either physically trapped or chemically bound between the uranium atoms , where they will remain .

However, a few fission products that are volatile or gaseous may diffuse through the fuel pellets into small gaps between the pellets and the fuel cladding .

The second barrier, the fuel cladding , consists of zirconium alloy tubes that confine the fuel pellets.

The small gaps between the fuel and the cladding contain the noble gases and volatile iodines that are types of radioactive fission products. This radioactivity can diffuse to a small extent through the fuel cladding into the reactor coolant water.

The third barrier consists of the reactor pressure vessel , steel piping and equipment that confine the reactor cooling water. The reactor pressure vessel , which holds the reactor fuel , is a 65-foot high by 19-foot diameter tank with steel walls approximately nine inches thick . This provides containment for radioactivity in the primary coolant and the reactor core . However, during the course of operations and maintenance, small amounts of radioactive fission and activation products can escape through valve leaks or upon breaching of the primary coolant system for maintenance.

The fourth barrier is the primary containment. This consists of the drywell and the torus. The drywell is a steel lined enclosure that is shaped like an inverted light bulb. An approximately five foot thick concrete wall encloses the drywell's steel pressure vessel. The torus is a donut-shaped pressure suppression chamber. The steel walls of the torus are nine feet in diameter with the donut itself having an outside diameter of approximately 130 feet. Small amounts of radioactivity may be released from primary containment during maintenance .

The fifth barrier is the secondary containment or reactor building . The reactor building is the concrete building that surrounds the primary containment. This barrier is an additional safety feature to contain radioactivity that may escape from the primary containment. This reactor building is equipped with a filtered ventilation system that is used when needed to reduce the radioactivity that escapes from the primary containment.

The five barriers confine most of the radioactive fission and activation products. However, small amounts of radioactivity do escape via mechanical failures and maintenance on valves, piping , and equipment associated with the reactor cooling water system. The small amounts of radioactive liquids and gases that do escape the various containment systems are further controlled by the liquid purification and ventilation filtration systems. Also , prior to a release to the environment, control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable. The control of radioactive effluents at Pilgrim Station will be discussed in more detail in the next section .

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1.4 Radioactive Effluent Control The small amounts of radioactive liquids and gases that might escape the five barriers are purified in the liquid and gaseous waste treatment systems, then monitored for radioactivity, and released only if the radioactivity levels are below the federal release limits .

Radioactivity released from the liquid effluent system to the environment is limited , controlled , and mon itored by a variety of systems and procedures which include:

• reactor water cleanup system ;

• liquid radwaste treatment system ;

• sampling and analysis of the liquid radwaste tanks; and ,

• liquid waste effluent discharge header radioactivity monitor.

The purpose of the reactor water cleanup system is to continuously purify the reactor cooling water by removing radioactive atoms and non-radioactive impurities that may become activated by neutron bombardment. A portion of the reactor coolant water is diverted from the primary coolant system and is directed through ion exchange resins where radioactive elements , dissolved and suspended in the water, are removed through chemical processes. The net effect is a substantial reduction of the radioactive material that is present in the primary coolant water and consequently the amount of radioactive material that might escape from the system.

Reactor cooling water that might escape the primary cooling system and other radioactive water sources are collected in floor and equipment drains . These drains direct this radioactive liquid waste to large holdup tanks. The liquid waste collected in the tanks is purified again using the liquid radwaste treatment system , which consists of a filter and ion exchange resins .

Processing of liquid radioactive waste results in large reductions of radioactive liquids discharged into Cape Cod Bay. Of all wastes processed through liquid radwaste treatment, 90 to 95 percent of all wastes are purified and the processed liquid is re-used in plant systems.

Prior to release , the radioactivity in the liquid radwaste tank is sampled and analyzed to determine if the level of radioactivity is below the release limits and to quantify the total amount of radioactive liquid effluent that would be released . If the levels are below the federal release limits , the tank is drained to the liquid effluent discharge header.

This liquid waste effluent discharge header is provided with a shielded radioactivity monitor. This detector is connected to a radiation level meter and a strip chart recorder in the Control Room . The radiation alarm is set so that the detector will alarm before radioactivity levels exceed the release limits. The liquid effluent discharge header has an isolation valve . If an alarm is received , the liquid effluent discharge valve will automatically close, thereby terminating the release to the Cape Cod Bay and preventing any liquid radioactivity from being released that may exceed the release limits. An audible alarm notifies the Control Room operator that this has occurred .

Some liquid waste sources which have a low potential for containing radioactivity, and/or may contain very low levels of contamination , may be discharged directly to the discharge canal without passing through the liquid radwaste discharge header. One such source of liquids is the neutralizing sump.

However, prior to discharging such liquid wastes , the tank is thoroughly mixed and a representative sample is collected for analysis of radioactivity content prior to being discharged .

Another means for adjusting liquid effluent concentrations to below federal limits is by mixing plant cooling water from the condenser with the liquid effluents in the discharge canal. This larger volume of cooling water further dilutes the radioactivity levels far below the release limits.

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The preceding discussion illustrates that many controls exist to reduce the rad ioactive liquid effluents released to the Cape Cod Bay to as far below the release limits as is reasonably achievable.

Radioactive releases from the radioactive gaseous effluent system to the environment are limited ,

controlled , and monitored by a variety of systems and procedures which include:

• reactor building ventilation system ;

• reactor building vent effluent radioactivity monitor;

• sampling and analysis of reactor building vent effluents;

• standby gas treatment system ;

• main stack effluent radioactivity monitor and sampling ;

• sampling and analysis of main stack effluents;

• augmented off-gas system ;

• steam jet air ejector (SJAE) monitor; and ,

• off-gas radiation monitor.

The purpose of the reactor building ventilation system is to collect and exhaust reactor building air.

Air collected from contaminated areas is filtered prior to combining it with air collected from other parts of the building . This combined airflow is then directed to the reactor building ventilation plenum that is located on the side of the reactor build ing . This plenum , which vents to the atmosphere, is equipped with a radiation detector. The radiation level meter and strip chart recorder for the reactor building vent effluent radioactivity monitor is located in the Control Room . To supplement the information continuously provided by the detector, air samples are taken periodically from the reactor building vent and are analyzed to quantify the total amount of tritium and radioactive gaseous and particulate effluents released .

If air containing elevated amounts of noble gases is routed past the reactor building vent's effluent radioactivity monitor, an alarm will alert the Control Room operators that release limits are being approached . The Control Room operators , according to procedure , will isolate the reactor building ventilation system and initiate the standby gas treatment system to remove airborne particulates and gaseous halogen radioactivity from the reactor building exhaust. This filtration assembly consists of high-efficiency particulate air fi lters and charcoal adsorber beds . The purified air is then directed to the main stack. The main stack has dilution flow that further reduces concentration levels of gaseous releases to the environment to as far below the release limits as is reasonably achievable.

The approximately 335 foot tall main stack has a special probe inside it that withdraws a portion of the air and passes it through a radioactivity monitoring system. This main stack effluent radioactivity monitoring system continuously samples radioactive particulates , iodines , and noble gases. Grab samples for tritium analysis are also collected at this location . The system also contains radioactivity detectors that monitor the levels of radioactive noble gases in the stack flow and display the result on radiation level meters and strip chart recorders located in the Control Room. To supplement the information continuously provided by the detectors, the particulate , iodine, tritium, and gas samples are analyzed periodically to quantify the total amount of radioactive gaseous effluent being released.

The purpose of the augmented off-gas system is to reduce the radioactivity from the gases that are removed from the condenser. This purification system consists of two 30-minute holdup lines to reduce the radioactive gases with short half-lives, several charcoal adsorbers to remove radioactive iodines and further retard the short half-life gases , and offgas filters to remove radioactive particulates. The recombiner collects free hydrogen and oxygen gas and recombines them into water.

This helps reduce the gaseous releases of short-lived isotopes of oxygen that have been made radioactive by neutron activation .

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The radioactive off-gas from the condenser is then directed into a ventilation pipe to which the off-gas radiation monitors are attached . The radiation level meters and strip chart recorders for this detector are also located in the Control Room . If a radiation alarm setpoint is exceeded , an audible alarm will sound to alert the Control Room operators . In addition , the off-gas bypass and charcoal adsorber inlet valve will automatically re-direct the off-gas into the charcoal adsorbers if they are temporarily being bypassed . If the radioactivity levels are not returned to below the alarm setpoint within 13 minutes, the off-gas releases will be automatically isolated , thereby preventing any gaseous radioactivity from being released that may exceed the release limits.

Therefore, for both liquid and gaseous releases, radioactive effluent control systems exist to collect and purify the radioactive effluents in order to reduce releases to the environment to as low as is reasonably achievable. The effluents are always monitored , sampled and analyzed prior to release to make sure that radioactivity levels are below the release limits . If the release limits are being approached, isolation valves in some of the waste effluent lines will automatically shut to stop the release, or Control Room operators will implement procedures to ensure that federal regulatory limits are always met.

1.5 Radiological Impact on Humans The final step in the effluent control process is the determination of the radiological dose impact to humans and comparison with the federal dose limits to the public. As mentioned previously , the purpose of continuous radiation monitoring and periodic sampling and analysis is to measure the quantities of radioactivity being released to determine compliance with the radioactivity release limits.

This is the first stage for assessing releases to the environment.

Next, calculations of the dose impact to the general public from Pilgrim Station's radioactive effluents are performed . The purpose of these calculations is to periodically assess the doses to the general public resulting from radioactive effluents to ensure that these doses are being maintained as far below the federal dose limits as is reasonably achievable. This is the second stage for assessing releases to the environment.

The types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during each given year are reported to the Nuclear Regulatory Commission annually. The 2017 Radioactive Effluents are provided in Appendix B and will be discussed in more detail in Section 3 of this report. These liquid and gaseous effluents were well below the federal release limits and were a small percentage of the PNPS ODCM effluent control limits.

These measurements of the physical and chemical nature of the effluents are used to determine how the radionuclides will interact with the environment and how they can result in radiation exposure to humans. The environmental interaction mechanisms depend upon factors such as the hydrological (water) and meteorological (atmospheric) characteristics in the area . Information on the water flow ,

wind speed , wind direction, and atmospheric mixing characteristics are used to estimate how radioactivity will distribute and disperse in the ocean and the atmosphere .

The most important type of information that is used to evaluate the radiological impact on humans is data on the use of the environment. Information on fish and shellfish consumption , boating usage ,

beach usage, locations of cows and goats, locations of residences, locations of gardens, drinking water supplies , and other usage information are utilized to estimate the amount of radiation and radioactivity received by the general public.

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The radiation exposure pathway to humans is the path radioactivity takes from its release point at Pilgrim Station to its effect on man . The movement of radioactivity through the environment and its transport to humans is portrayed in Figure 1.5- 1.

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EXAMPLES OF PILGRIM STATION 'S RADIATION EXPOSURE PATHWAYS LIQUID EFFLUENTS

3. DIRECT RADIATION J[/

(STATION), 2. AIR INHALATION

1. DIRECT RADIATION

• t , c/ (AIR SUBMERSION) t

1. SHORELINE DIRECT RADIATION (FISHING , PICNIC.ING) ~ 5. CONSUMPTION (VEGETATION)

~ cl DEPOSITION

2. DIRECT RADIATION (IMMERSION IN OCEAN, (OAT; ,SWIMMING)

DEPOSITION Figure 1.5-1 Radiation Exposure Pathways Page 20 20

There are three major ways in which liquid effluents affect humans :

• external radiation from liquid effluents that deposit and accumulate on the shoreline ;

• external radiation from immersion in ocean water containing radioactive liquids; and ,

• internal radiation from consumption of fish and shellfish containing radioactivity absorbed from the liquid effluents.

There are six major ways in which gaseous effluents affect humans:

• external radiation from an airborne plume of radioactivity ;

• internal radiation from inhalation of airborne radioactivity ;

• external radiation from deposition of radioactive effluents on soil ;

• ambient (direct) radiation from contained sources at the power plant ;

• internal radiation from consumption of vegetation containing radioactivity deposited on vegetation or absorbed from the soil due to ground deposition of radioactive effluents ; and ,

• internal radiation from consumption of milk and meat containing radioactivity deposited on forage that is eaten by cattle and other livestock.

In addition , ambient (direct) radiation emitted from contained sources of radioactivity at PNPS contributes to radiation exposure in the vicinity of the plant. Radioactive nitrogen-16 contained in the steam flowing through the turbine accounts for the majority of this "sky shine" radiation exposure immediately adjacent to the plant. Smaller amounts of ambient radiation result from low-level radioactive waste stored at the site prior to shipping and disposal.

To the extent possible , the radiological dose impact on humans is based on direct measurements of radiation and radioactivity in the environment. When PNPS-related activity is detected in samples that represent a plausible exposure pathway, the resulting dose from such exposure is assessed (see Appendix A). However, the operation of Pilgrim Nuclear Power Station results in releases of only small amounts of radioactivity , and , as a result of dilution in the atmosphere and ocean , even the most sensitive radioactivity measurement and analysis techniques cannot usually detect these tiny amounts of radioactivity above that which is naturally present in the environment. Therefore , radiation doses are calculated using radioactive effluent release data and computerized dose calculations that are based on very conservative NRG-recommended models that tend to result in over-estimates of resulting dose. These computerized dose calculations are performed by or for Entergy Nuclear personnel. These computer codes use the guidelines and methodology set forth by the NRC in Regu latory Guide 1.109 (Reference 6) . The dose calculations are documented and described in detail in the Pilgrim Nuclear Power Station's Offsite Dose Calculation Manual (Reference 7) , which has been reviewed by the NRC.

Monthly dose calculations are performed by PNPS personnel. It should be emphasized that because of the very conservative assumptions made in the computer code calculations , the maximum hypothetical dose to an individual is considerably higher than the dose that would actually be received by a real individual.

After dose calculations are performed , the results are compared to the federal dose limits for the public. The two federal agencies that are charged with the responsibility of protecting the public from radiation and radioactivity are the Nuclear Regulatory Commission (NRC) and the Environmental Protection Agency (EPA) .

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The NRC , in 10CFR 20 .1301 (Reference 8) limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of:

• less than or equal to 100 mrem per year to the total body .

In addition to this dose limit, the NRC has established design objectives for nuclear plant licensees.

Conformance to these guidelines ensures that nuclear power reactor effluents are maintained as far below the legal limits as is reasonably achievable.

The NRC, in 10CFR 50 Appendix I (Reference 9) establishes design objectives for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to:

• less than or equal to 3 mrem per year to the total body ; and ,

• less than or equal to 1O mrem per year to any organ .

The air dose due to release of noble gases in gaseous effluents is restricted to :

• less than or equal to 1O mrad per year for gamma radiation ; and ,

• less than or equal to 20 mrad per year for beta radiation .

The dose to a member of the general public from iodine-131 , tritium , and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to :

• less than or equal to 15 mrem per year to any organ .

The EPA, in 40CFR190 .1O Subpart B (Reference 10), sets forth the environmental standards for the uranium fuel cycle . During normal operation , the annual dose to any member of the public from the entire uranium fuel cycle shall be limited to:

• less than or equal to 25 mrem per year to the total body ;

• less than or equal to 75 mrem per year to the thyroid ; and ,

• less than or equal to 25 mrem per year to any other organ .

The summary of the 2017 radiological impact for Pilgrim Station and comparison with the EPA dose limits and guidelines, as well as a comparison with natural/man-made radiation levels, is presented in Section 3 of this report.

The third stage of assessing releases to the environment is the Radiological Environmental Monitoring Program (REMP) . The description and results of the REMP at Pilgrim Nuclear Power Station during 2017 is discussed in Section 2 of this report.

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2.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 2.1 Pre-Operationa l Monitoring Results The Radiological Environmental Monitoring Program (REMP) at Pilgrim Nuclear Power Station was first initiated in August 1968, in the form of a pre-operational monitoring program prior to bringing the station on-line . The NRC's intent (Reference 11) with performing a pre-operational environmental monitoring program is to :

• measure background levels and their variations in the environment in the area surrounding the licensee's station ; and ,

• evaluate procedures, equipment, and techniques for monitoring radiation and radioactivity in the environment.

The pre-operational program (Reference 12) continued for approximately three and a half years, from August 1968 to June 1972. Examples of background radiation and radioactivity levels measured during this time period are as follows :

• Airborne Radioactivity Particulate Concentration (gross beta): 0.02 - 1.11 pCi/m 3 ;

• Ambient Radiation (TLDs) : 4.2 - 22 micro-R/hr (37 - 190 mR/yr) ;

• Seawater Radioactivity Concentrations (gross beta) : 12 - 31 pCi/liter;

• Fish Radioactivity Concentrations (gross beta) : 2,200 - 11 ,300 pCi/kg ;

• Milk Radioactive Cesium-137 Concentrations : 9.3 - 32 pCi/liter;

• Milk Radioactive Strontium-90 Concentrations: 4.7 - 17.6 pCi/liter;

• Cranberries Radioactive Cesium-137 Concentrations : 140 - 450 pCi/kg ;

• Forage Radioactive Cesium-137 Concentrations : 150 - 290 pCi/kg .

This information from the pre-operational phase is used as a basis for evaluating changes in radiation and radioactivity levels in the vicinity of the plant following plant operation . In April 1972, just prior to initial reactor startup (June 12, 1972), Boston Edison Company implemented a comprehensive operational environmental monitoring program at Pilgrim Nuclear Power Station . This program (Reference 13) provides information on radioactivity and radiation levels in the environment for the purpose of:

• demonstrating that doses to the general public and levels of radioactivity in the environment are within established limits and legal requirements ;

• monitoring the transfer and long-term buildup of specific radionuclides in the environment to revise the monitoring program and environmental models in response to changing conditions ;

• checking the condition of the station's operation , the adequacy of operation in relation to the adequacy of containment, and the effectiveness of effluent treatment so as to provide a mechanism of determining unusual or unforeseen conditions and , where appropriate , to trigger special environmental monitoring studies;

• assessing the dose equivalent to the general public and the behavior of radioactivity released during the unlikely event of an accidental release ; and ,

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• determining whether or not the radiological impact on the environment and humans is significant.

The Nuclear Regulatory Commission requires that Pilgrim Station provide monitoring of the plant environs for radioactivity that will be released as a result of normal operations, including anticipated operational occurrences , and from postulated accidents. The NRC has established guidelines (Reference 14) that specify an acceptable monitoring program. The PNPS Radiological Environmental Monitoring Program was designed to meet and exceed these guidelines. Guidance contained in the NRC's Radiological Assessment Branch Technical Position on Environmental Monitoring (Reference 15) has been used to improve the program . In add ition , the program has incorporated the provisions of an agreement made with the Massachusetts Wildlife Federation (Reference 16). The program was supplemented by including improved analysis of shellfish and sediment at substantially higher sensitivity levels to verify the adequacy of effluent controls at Pilgrim Station .

2.2 Environmental Monitoring Locations Sampling locations have been established by considering meteorology, population distribution ,

hydrology, and land use characteristics of the Plymouth area. The sampling locations are divided into two classes , indicator and control. Indicator locations are those that are expected to show effects from PNPS operations , if any exist. These locations were primarily selected on the basis of where the highest predicted environmental concentrations would occur. While the indicator locations are typically within a few kilometers of the plant, the control stations are generally located so as to be outside the influence of Pilgrim Station. They provide a basis on which to evaluate fluctuations at indicator locations relative to natural background radiation and natural radioactivity and fallout from prior nuclear weapons tests .

The environmental sampling media collected in the vicinity of Pilgrim Station during 2017 included air particulate filters , charcoal cartridges , animal forage, vegetation , cranberries , seawater, sediment, Irish moss, shellfish , American lobster, and fishes. The sampling medium, station description , station number, distance, and direction for indicator and control samples are listed in Table 2.2-1 . These sampling locations are also displayed on the maps shown in Figures 2.2-1 through 2.2-6.

The radiation monitoring locations for the environmental TLDs are shown in Figures 2.2-1 through 2.2-

4. The frequency of collection and types of radioactivity analysis are described in Pilgrim Station's ODCM , Sections 3/4.5 .

The land-based (terrestrial) samples , seawater, and monitoring devices are collected by Entergy personnel. The aquatic samples are collected by Normandeau Associates, Inc. The radioactivity analysis of samples are performed by the Teledyne Brown Engineering Laboratory , and the environmental dosimeters are analyzed by Stanford Dosimetry ..

The frequency , types, minimum number of samples , and maximum lower limits of detection (LLD) for the analytical measurements, are specified in the PNPS ODCM . During 2003, a revision was made to the PNPS ODCM to standard ize it to the model program described in NUREG-1302 (Reference 14) and the Branch Technical Position of 1979 (Reference 15) . In accordance with this standardization, a number of changes occurred regarding the types and frequencies of sample collections .

In regard to terrestrial REMP sampling , routine collection and analysis of soil samples was discontinued in lieu of the extensive network of environmental TLDs around PNPS , and the weekly collection of air samples at 11 locations. Such TLD monitoring and air sampling would provide an early indication of any potential deposition of radioactivity, and follow-up soil sampling could be performed on an as-needed basis. Also , with the loss of the indicator milk sample at the Plymouth County Farm and the lack of a sufficient substitute location that could provide suitable volumes for Page 24 24

analysis , it was deemed unnecessary to continue to collect and analyze control samples of milk.

Consequently , routine milk sampling was also dropped from the terrestrial sampling program . NRC guidance (Reference 14) contains provisions for collection of vegetation and forage samples in lieu of milk sampling . Such samples have historically been collected near Pilgrim Station as part of the routine REMP program .

In the area of marine sampling , a number of the specialized sampling and analysis requirements implemented as part of the Agreement with the Massachusetts Wildlife Federation (Reference 16) for licensing of a second reactor at PNPS were dropped . This agreement, made in 1977, was predicated on the construction of a second nuclear unit, and was set to expire in 1987. However, since the specialized requirements were incorporated into the PNPS Technical Specifications at the time , the requirements were continued . When the ODCM was revised in 1999 in accordance with NRC Generic Letter 89-01 , the sampling program description was relocated to the ODCM . When steps were taken in 2003 to standardize the PNPS ODCM to the NUREG-1302 model , the specialized marine sampling requirements were changed to those of the model program. These changes include the following:

• A sample of the surface layer of sediment is collected, as opposed to specialized depth-incremental sampling to 30 cm and subdividing cores into 2 cm increments .

• Standard LLD levels of approximately 150 to 180 pCi/kg were established for sediment, as opposed to the specialized LLDs of 50 pCi/kg.

• Specialized analysis of sediment for plutonium isotopes was removed .

• Sampling of Irish moss, shellfish , and fish was rescheduled to a semiannual period , as opposed to a specialized quarterly sampling interval.

• Analysis of only the edible portions of shellfish (mussels and clams) , as opposed to specialized additional analysis of the shell portions.

• Standard LLD levels of 130 to 260 pCi/kg were established for edible portions of shellfish , as opposed to specialized LLDs of 5 pCi/kg.

The PNPS ODCM was revised in 2009. In conjunction with this revision , two changes were made to the environmental sampling program. Due to damage from past storms to the rocky areas at Manomet Point, there is no longer a harvestable population of blue mussels at this site. Several attempts have been made over the past years to collect samples from this location , but all efforts were unsuccessful. Because of unavailability of mussels at this location as a viable human foodchain exposure pathway, this location was dropped from the sampling program . The other change involved the twice per year sampling of Group II fishes in the vicinity of the PNPS discharge outfall ,

represented by species such as cunner and tautog . Because these fish tend to move away from the discharge jetty during colder months, they are not available for sampling at a six-month semi-annual sampling period . The sampling program was modified to reduce the sampling for Group II fishes to once per year, when they are available during warmer summer months.

Upon receipt of the analysis results from the analytical laboratories, the PNPS staff reviews the results. If the radioactivity concentrations are above the reporting levels , the NRC must be notified within 30 days. For radioactivity that is detected that is attributable to Pilgrim Station's operation ,

calculations are performed to determine the cumulative dose contribution for the current year.

Depending upon the circumstances , a special study may also be completed (see Appendix A for 2017 special studies). Most importantly, if radioactivity levels in the environment become elevated as a result of the station's operation, an investigation is performed and corrective actions are recommended to reduce the amount of radioactivity to as far below the legal limits as is reasonably achievable.

The radiological environmental sampling locations are reviewed annually, and modified if necessary.

A garden and milk animal census is performed every year to identify changes in the use of the environment in the vicinity of the station to permit modification of the monitoring and sampling locations . The results of the 2017 Garden and Milk Animal Census are reported in Appendix C.

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The accuracy of the data obtained through Pilgrim Station 's Radiological Environmental Monitoring Program is ensured through a comprehensive Quality Assurance (QA) programs. PNPS's QA prog ram has been established to ensure confidence in the measurements and results of the radiological monitoring program through :

• Regular surveillances of the sampling and monitoring program ;

• An annual audit of the analytical laboratory by the sponsor companies ;

• Participation in cross-check programs ;

• Use of blind duplicates for comparing separate analyses of the same sample ; and ,

• Spiked sample analyses by the analytical laboratory.

QA audits and inspections of the Radiological Environmental Monitoring Program are performed by the NRC, American Nuclear Insurers, and by the PNPS Quality Assurance Department.

The Teledyne Brown Engineering Laboratory conducts extensive quality assurance and quality control programs . The 2017 results of these programs are summarized in Appendix E. These results indicate that the analyses and measurements performed during 2017 exhibited acceptable precision and accuracy.

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2.3 Interpretation of Radioactivity Analyses Results The following pages summarize the analytical results of the environmental samples collected during 2017. Data for each environmental medium are included in a separate section . A table that summarizes the year's data for each type of medium follows a discussion of the sampling program and results. The unit of measurement for each medium is listed at the top of each table . The left hand column contains the radionuclides being reported , total number of analyses of that radionuclide ,

and the number of measurements that exceed ten times the yearly average for the control station(s).

The latter are classified as "non-routine" measurements. The next column lists the Lower Limit of Detection (LLD) for those radionuclides that have detection capability requirements specified in the PNPS ODCM.

Those sampling stations within the range of influence of Pilgrim Station and which could conceivably be affected by its operation are called "indicator" stations. Distant stations , which are beyond plant influence, are called "control" stations. Ambient radiation monitoring stations are broken down into four separate zones to aid in data analysis.

For each sampling medium, each radionuclide is presented with a set of statistical parameters. This set of statistical parameters includes separate analyses for (1) the indicator stations , (2) the station having the highest annual mean concentration , and (3) the control stations . For each of these three groups of data , the following values are calculated :

• The mean value of detectable concentrations, including only those values above LLD ;

• The standard deviation of the detectable measurements;

• The lowest and highest concentrations ; and ,

• The number of measurements with results greater than the Minium Detectable Activity (activity which is three times greater than the standard deviation), out of the total number of measurements.

Each single radioactivity measurement datum is based on a single measurement and is reported as a concentration plus or minus one standard deviation . The quoted uncertainty represents only the random uncertainty associated with the measurement of the radioactive decay process (counting statistics), and not the propagation of all possible uncertainties in the sampling and analysis process .

A sample or measurement is considered to contain detectable radioactivity if the measured value (e .g., concentration) exceeds three times its associated standard deviation . For example , a vegetation sample with a cesium-137 concentration of 85 +/- 21 pCi/kilogram would be considered "positive" (detectable Cs-137) , whereas another sample with a concentration of 60 +/- 32 pCi/kilogram would be considered "negative", indicating no detectable cesium-137 . The latter sample may actually contain cesium-137 , but the levels counted during its analysis were not significantly different than the background levels.

The analytical laboratory that analyzes the various REMP samples employs a background subtraction correction for each analysis. A blank sample that is known not to contain any plant-related activity is analyzed for radioactivity, and the count rate for that analysis is used as the background correction .

That background correction is then subtracted from the results for the analyses in that given set of samples. For example , if the blank/background sample produces 50 counts , and a given sample being analyzes produces 47 counts, then the net count for that sample is reported as -3 counts . That negative value of -3 counts is used to calculate the concentration of radioactivity for that particular analysis. Such a sample result is technically more valid than reporting a qualitative value such as

"<LLD" (Lower limit of Detection) or "NOA" (No Detectable Activity)".

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As an example of how to interpret data presented in the results tables , refer to the first entry on the table for air particulate filters (page 41 ). Gross beta (GR-B) analyses were performed on 577 routine samples. None of the samples exceeded ten times the average concentration at the control location .

The lower limit of detection (LLD) required by the ODCM is 0.01 pCi/m 3 .

For samples collected from the ten indicator stations , 514 out of 514 samples indicated detectable gross beta activity at the three-sigma (standard deviation) level. The mean concentration of gross beta activity in these 514 indicator station samples was 0.015 +/- 0.0042 (1 .5E-2 +/- 4.2E-3) pCi/m 3

• Individual values ranged from 0.0048 to 0.055 (4 .8E 5.5E-2) pCi/m 3 .

The monitoring station which yielded the highest mean concentration was the control location EW (East Weymouth) , which yielded a mean concentration of 0.016 +/- 0.0036 pCi/m 3 , based on 52 detectable indications out of 52 samples observations . Individual values ranged from 0.0071 to 0.024 pCi/m 3 .

At the control location , 52 out of 52 samples yielded detectable gross beta activity , for an average concentration of 0.016 +/- 0.0036 pCi/m 3 . Individual samples at the East Weymouth control location ranged from 0.0071 to 0.024 pCi/m 3 .

Analyses for cesium-137 (Cs-137) were performed 44 times (quarterly composites for 11 stations

• 4 quarters) . No samples exceeded ten times the mean control station concentration . The required LLD value Cs-137 in the PNPS ODCM is 0.06 pCi/m 3 .

Analyses for Beryllium-? (Be-7) are used to indicate representative sampl ing for air samplers in environmental appl ications.

At the indicator stations , all 40 of the Cs-137 measurements were below the detection level. The same was true for the four measurements made on samples collected from the control location .

2.4 Ambient Radiation Measurements The primary techn ique for measuring ambient radiation exposure in the vicinity of Pilgrim Station involves posting environmental thermoluminescent dosimeters (TLDs) at given monitoring locations and retrieving the TLDs after a specified time period . The TLDs are then taken to a laboratory and processed to determine the total amount of radiation exposure received over the period . Although TLDs can be used to monitor radiation exposure for short time periods , environmental TLDs are typically posted for periods of one to three months. Such TLD monitoring yields average exposure rate measurements over a relatively long time period . The PNPS environmental TLD monitoring program is based on a quarterly (three month) posting period , and a total of 113 locations are monitored using this technique. In addition, 27 of the 113 TLDs are located onsite, within the PNPS protected/restricted area , where the general public does not have access.

Out of the 452 TLDs (113 locations

• 4 quarters) posted during 2017, 450 were retrieved and processed . During the fourth 2017/first 2018 quarter exchange period , the offsite TLD located at Cleft Rock was inadvertently not exchanged , and the TLD will remain at this location for a six-month posting period rather than a three-month posting period . When this TLD is collected during the first/second 2018 quarter exchange , the accumulated exposer recorded will be logged for both the fourth 2017 and first 2018 quarters. This discrepancy is discussed in Appendix D. The results for environmental TLDs located offsite , beyond the PNPS protected/restricted area fence , are presented in Table 2.4-1 . Results from onsite TLDs posted within the restricted area are presented in Table 2.4-

2. In addition to TLD results for individual locations, results from offsite TLDs were grouped according to geographic zone to determine average exposure rates as a function of distance. These results are summarized in Table 2.4-3. All of the listed exposure values represent continuous occupancy (2190 hr/qtr or 8760 hr/yr) .

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Annual exposure rates measured at locations beyond the PNPS protected area boundary ranged from 44 to 216 mR/yr. The average exposure rate at control locations greater than 15 km from Pilgrim Station (i.e. , Zone 4) was 62 .6 +/- 8.8 mR/yr. When the 3-sigma confidence interval is calculated based on these control measurements , 99% of all measurements of background ambient exposure would be expected to be between 36 and 89 mR/yr. The results for all TLDs within 15 km (excluding those Zone 1 TLDs posted within the site boundary) ranged from 44 to 86 mR/yr, wh ich compares favorably with the preoperational results of 37 - 190 mR/yr.

Inspection of onsite TLD results listed in Table 2.4-2 indicates that all of those TLDs located within the PNPS protected/restricted area yield exposure measurements higher than the average natural background . Such results are expected due to the close proximity of these locations to radiation sources onsite . The radionuclide nitrogen-16 (N-16) contained in steam flowing through the turbine accounts for most of the exposure onsite . Although this radioactiv ity is contained within the turbine and is not released to the atmosphere , the "sky shine" which occurs from the turbine increases the ambient radiation levels in areas near the turbine building.

A small number of offsite TLD locations in close proximity to the protected/restricted area indicated ambient radiation exposure above expected background levels. All of these locations are on Pilgrim Station controlled property, and experience exposure increases due to turbine sky shine and proximity to the onsite fuel storage pad (e .g., locations OA , TC , PB , and P01) and/or transit and storage of radwaste onsite (e.g ., locations BLE and BLW) . Due to heightened security measures following September 11 2001 , members for the general public do not have access to such locations within the owner-controlled area .

It should be noted that several of the TLDs used to calculate the Zone 1 averages presented in Table 2.4-3 are located on Pilgrim Station property . If the Zone 1 value is corrected for the near-site TLDs (those less than 0.6 km from the Reactor Building) , the Zone 1 mean falls from a value of 78 .8 +/- 29 .5 mR/yr to 60 .3 +/- 7.7 mR/yr. Additionally , exposure rates measured at areas beyond Entergy's control did not indicate any increase in ambient exposure from Pilgrim Station operation . For example , the annual exposure rate calculated from the TLD adjacent to the nearest offsite residence 0.80 kilometers (0.5 miles) southeast of the PNPS Reactor Building was 63 .3 +/- 2.1 mR/yr, which compares quite well with the average control location exposure of 62.6 +/- 8.9 mR/yr.

In conclusion , measurements of ambient radiation exposure around Pilgrim Station do not indicate a,ny significant increase in exposure levels. Although some increases in ambient radiation exposure level were apparent on Entergy property very close to Pilgrim Station , there were no measurable increases at areas beyond Entergy's control.

2.5 Air Particulate Filter Radioactivity Analyses Airborne particulate radioactivity is sampled by drawing a stream of air through a glass fiber filter that has a very high efficiency for collecting airborne particulates . These samplers are operated continuously, and the resulting filters are collected weekly for analysis . Weekly filter samples are analyzed for gross beta radioactivity , and the filters are then composited on a quarterly basis for each location for gamma spectroscopy analysis. PNPS uses this technique to monitor 1O locations in the Plymouth area , along with the control location in East Weymouth .

Out of 572 filters (11 locations

• 52 weeks) , 566 samples were collected and analyzed during 2017 .

There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations, resulting in lower than normal sample volumes . There were six occasions where the loss of power was sufficiently long that the minimum sample volumes needed to achieve required detection limits were not met. Although these filters were analyzed , the Page 29 29

LLDs were not met and these analyses were not included with the other results . All of these discrepancies are noted in Appendix D.

The results of the analyses performed on these 566 filter samples are summarized in Table 2.5-1 .

Trend plots for the gross beta radioactivity levels at the near station , property line , and offsite airborne monitoring locations are shown in Figures 2.5-1, 2.5-2 and 2.5-3 , respectively. Gross beta radioactivity was detected in 566 of the filter samples collected , including 52 of the 52 control location samples. This gross beta activity arises from naturally-occurring radionuclides such as radon decay daughter products. Naturally-occurring beryllium-? was detected in 44 out of 44 of the quarterly composites analyzed with gamma spectroscopy. No airborne radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program .

2.6 Charcoal Cartridge Radioactivity Analyses Airborne radioactive iodine is sampled by drawing a stream of air through a charcoal cartridge after it has passed through the high efficiency glass fiber filter. As is the case with the air particulate filters ,

these samplers are operated continuously , and the resulting cartridges are collected weekly for analysis . Weekly cartridge samples are analyzed for radioactive iodine. The same eleven locations monitored for airborne particulate radioactivity are also sampled for airborne radioiodine .

Out of 572 charcoal cartridges (11 locations

• 52 weeks) , 566 samples were collected and analyzed during 2017 . There were a few instances where power was lost or pumps failed during the course of the sampling period at some of the air sampling stations , resulting in lower than normal sample volumes. There were four occasions where the incident was sufficiently long that the minimum sample volumes needed to achieve required detection limits were not met. Although these cartridges were analyzed , the LLDs were not met and these four analyses were not included with the other results. All of these discrepancies are noted in Appendix D.

The results of the analyses performed on these charcoal cartridges are summarized in Table 2.6-1 .

No airborne radioactive iodine attributable to Pilgrim Station was detected in any of the charcoal cartridges collected .

2.7 Milk Radioactivity Analyses In July 2002, the Plymouth County Farm ceased operation of its dairy facility. This was historically the only dairy facility near Pilgrim Station , and had been sampled continuously since Pilgrim Station began operation in 1972. Although attempts were made to obtain samples from an alternate indicator location within 5 miles as specified in NRC guidance (Reference 14), a suitable substitute location could not be found . Thus, milk collection at an indicator location was discontinued in July 2002, but control samples of milk continued to be collected and analyzed in the event an indicator location could be secured. In conjunction with the standardization of the ODCM during 2003, the decision was made to remove milk sampling from the PNPS Radiological Environmental Monitoring Program since no suitable milk sampling location existed in the vicinity of Pilgrim Station.

The nearest milk animals to Pilgrim Station are located at the Plimoth Plantation, approximately 2.5 miles west of PNPS , in a relatively upwind direction . Due to the limited number of milk animals available , this location is not able to provide the necessary volume of 4 gallons of milk every two weeks to facilitate the milk sampling program and meet the required detection sensitivities. Although milk sampling is not performed at Plimoth Plantation , effluent dose calculations are performed for this location assuming the presence of a milk ingestion pathway, as part of the annual Effluent and Waste Disposal Report (Reference 17).

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As included in a provision in standard ODCM guidance in NUREG -1302 (Reference 13), sampling and analysis of vegetation from the offsite locations calculated to have the highest D/Q deposition factor can be performed in lieu of milk sampling. Such vegetation sampling has been routinely performed at Pilgrim Station as part of the radiological environmental monitoring program, and the results of this sampling are presented in Section 2.9.

2.8 Forage Radioactivity Analyses Samples of animal forage (hay) had been collected in the past from the Plymouth County Farm , and from control locations in Bridgewater. However, due to the absence of any grazing animals within a five-mile radius of Pilgrim Station that are used for generation of food products (milk or meat), no samples of forage were collected during 2017. A number of wild vegetation samples were collected within a five mile radius of Pilgrim Station as part of the vegetable/vegetation sampling effort, and the resu lts of this sampling would provide an indication of any radioactivity potentially entering the forage-milk or forage-meat pathways . Results of the vegetable/vegetation sampling effort are discussed in the following section .

2.9 VegetableNegetation Radioactivity Analyses Samples of vegetables and naturally-growing vegetation have historically been collected from the Plymouth County Farm and from the control locations in Bridgewater, Sandwich, and Norton . Results of the land-use census are discussed in Appendix C. In addition to these garden samples , naturally-growing vegetation is collected from locations yielding the highest D/Q deposition factors . All of the various samples of vegetables/vegetation are collected annually and analyzed by gamma spectroscopy .

Seventeen samples of vegetables/vegetation were collected and analyzed as required during 2017.

Results of the gamma analyses of these samples are summarized in Table 2.9-1 . Naturally-occurring beryllium-7 and potassium-40 were identified in several of the samples collected . No Cesium-137 was detected in any of the samples of vegetation collected as had been the case in prior years . Such Cs-137 is the result weapons-testing fallout (75 to 145 pCi/kg as projected from the pre-operational sampling program) . It should be noted that natural vegetation samples collected in the 1990s often showed detectable Cs-137 from nuclear weapons tests up into the range of 300 to 400 pCi/kg ,

whereas soil samples often indicated concentrations in excess of 2000 pCi/kg . Cs-137 has a 30-year half-life, and measureable concentrations still remain in soil and vegetation as a result of atmospheric nuclear weapons testing performed during the 1950s through 1970s. No radioactivity attributable to Pilgrim Station was detected in any of the vegetable/vegetation samples collected during 2017 , and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program .

Page 31 31

2.10 Cranberry Radioactivity Analyses Samples of cranberries are normally collected from two bogs in the Plymouth area and from the control location in Kingston . Samples of cranberries are collected annually and analyzed by gamma spectroscopy. In 2012, the bogs on Bartlett Road and Beaverdam Road ceased harvesting operations , and no samples were available from indicator locations within 5-miles of Pilgrim Station .

Samples were also not available from the historical control location in Halifax, and a substitute control sample was collected from a bog in Kingston . These discrepancies are noted in Appendix D.

One sample of cranberries was collected and analyzed during 2017 . Results of the gamma analyses of cranberry samples are summarized in Table 2.10-1 . Cranberry samples collected during 2017 yielded detectable levels of naturally-occurring potassium-40. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring prog ram .

2.11 Soil Radioactivity Analyses In the past, a survey of radioactivity in soil had been conducted once every three years at the 1O air sampling stations in the Plymouth area and the control location in East Weymouth . However, in conjunction with standardization of the ODCM during 2003, the soil survey effort was abandoned in favor of the extensive TLD monitoring effort at Pilgrim Station . Prior to ending the soil survey effort, there had been no apparent trends in radioactivity measurements at these locations .

2.12 Surface Water Radioactivity Analyses Samples of surface water are routinely collected from the discharge canal , Bartlett Pond in Manomet and from the control location at Powder Point Bridge in Duxbury. Grab samples are collected weekly from the Bartlett Pond and Powder Point Bridge locations. Samples of surface water are composited every four weeks and analyzed by gamma spectroscopy and low-level iodine analysis. These monthly composites are further composited on a quarterly basis and tritium analysis is performed on these quarterly samples.

A total of 36 samples (3 locations

• 12 sampling periods) of surface water were collected and analyzed as required during 2017. Results of the analyses of water samples are summarized in Table 2.12-1. Naturally-occurring potassium-40 was detected in several of the samples, especially those composed primarily of seawater. No radioactivity attributable to Pilgrim Station was detected in any of the surface water samples collected during 2017 .

In response to the Nuclear Energy Institute Groundwater Protection Initiative, Pilgrim Station installed a number of groundwater monitoring wells within the protected area in late 2007. Because all of these wells are onsite , they are not included in the offsite radiological monitoring program, and are not presented in this report. Details regarding Pilgrim Station's groundwater monitoring effort can be found in the Annual Radioactive Effluent Release Report.

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2.13 Sediment Radioactivity Analyses Samples of sediment are routinely collected from the outfall area of the discharge canal and from three other locations in the Plymouth area (Manomet Point, Plymouth Harbor and Plymouth Beach),

and from control locations in Duxbury and Marshfield . Samples are collected twice per year and are analyzed by gamma spectroscopy .

Twelve of twelve required samples, plus one extra sample of sediment were collected during 2017.

Gamma analyses were performed on these samples. Results of the gamma analyses of sediment samples are summarized in Table 2.13-1 . Naturally-occurring potassium-40 and actinium/thorium-228 were detected in all of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2.14 Irish Moss Radioactivity Analyses Samples of Irish moss are collected from the discharge canal outfall and two other locations in the Plymouth area (Manomet Point, Ellisville), and from a control location in Marshfield (Brant Rock) . All samples are collected on a semiannual basis , and processed in the laboratory for gamma spectroscopy analysis.

Eight required , plus one extra samples of Irish moss scheduled for collection during 2017 were obtained and analyzed . Results of the gamma analyses of these samples are summarized in Table 2.14-1. Naturally-occurring potassium-40 was detected in all of the samples, and beryllium-? was detected in three of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

2 .15 Shellfish Radioactivity Analyses Samples of blue mussels, soft-shell clams and quahogs are collected from the discharge canal outfall and one other location in the Plymouth area (Plymouth Harbor), and from control locations in Duxbury and Marshfield . All samples are collected on a semiannual basis, and edible portions processed in the laboratory for gamma spectroscopy analysis .

Ten of the ten required , plus one extra , samples of shellfish meat scheduled for collection during 2017 were obtained and analyzed . Results of the gamma analyses of these samples are summarized in Table 2.15-1 . Naturally-occurring potassium-40 was detected in eleven of the eleven the samples .

No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017 , and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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2.16 Lobster Radioactivity Analyses Samples of lobsters are routinely collected from the outfall area of the discharge canal and from control locations in Cape Cod Bay and Vineyard Sound . Samples are collected monthly from the discharge canal outfall from June through September and once annually from the control locations.

All lobster samples are normally analyzed by gamma spectroscopy.

Five samples of lobsters were collected as required during 2017. Results of the gamma analyses of these samples are summarized in Table 2.16-1 . Naturally-occurring potassium-40 was detected in five of the five of the samples. No radioactivity attributable to Pilgrim Station was detected in any of the samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program .

2.17 Fish Radioactivity Analyses Samples of fish are routinely collected from the area at the outfall of the discharge canal and from the control locations in Cape Cod Bay and Buzzard's Bay. Fish species are grouped into four major categories according to their biological requirements and mode of life. These major categories and the representative species are as follows :

• Group I - Bottom-Oriented : Winter Flounder, Yellowtail Flounder

• Group II - Near-Bottom Distribution : Tautog , Gunner, Pollock, Atlantic Cod , Hake

• Group Ill - Anadromous : Alewife , Smelt, Striped Bass

• Group IV - Coastal Migratory: Bluefish , Herring , Menhaden , Mackerel Group I fishes are sampled on a semiannual basis from the outfall area of the discharge canal , and on an annual basis from a control location . Group II , Ill , and IV fishes are sampled annually from the discharge canal outfall and control location . All samples of fish are analyzed by gamma spectroscopy.

Eight samples of fish were collected during 2017 . The seasonal sample of Group Ill fish (alewife ,

smelt, striped bass) from the Discharge Outfall was not available due to inability to collect samples as a result of heavy predation from harbor seals that have taken up residence on the breakwater. These discrepancies are discussed in Appendix D. Results of the gamma analyses of fish samples collected are summarized in Table 2.17-1 . The only radionuclide detected in any of the fish samples was naturally-occurring potassium-40 . No radioactivity attributable to Pilgrim Station was detected in any of the fish samples collected during 2017, and results of any detectable naturally-occurring radioactivity were similar to those observed in the preoperational monitoring program.

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Table 2.2-1 Routine Radiological Environmental Sam12ling Locations Pilgrim Nuclear Power Station, Plymouth, MA Description Code Distance Direction Air Particulate Filters, Charcoal Cartridges Medical Building ws 0.2 km SSE East Rocky Hill Road ER 0.9 km SE West Rocky Hill Road WR 0.8 km WNW Property Line PL 0.5 km NNW Pedestrian Bridge PB 0.2 km N Overlook Area OA 0.1 km w East Breakwater EB 0.5 km ESE Cleft Rock CR 1.3 km SSW Plymouth Center PC 6.7 km w Manomet Substation MS 3.6 km SSE East Weymouth Control EW 40 km NW Forage Plymouth County Farm CF 5.6 km w Hansen Farm Control HN 35 km w Vegetation Plymouth County Farm CF 5.6 km w Hansen Farm Control HN 35 km w Cranberries Bartlett Road Bog BT 4.3 km SSE Beaverdam Road Bog MR 3.4 km s Hollow Farm Bog Control HF 16 km WNW Page 35 35

Table 2.2-1 (continued)

Routine Radiological Environmental Samgling Locations Pilgrim Nuclear Power Station, Plymouth, MA Description Code Distance Direction Surface Water Discharge Canal DIS 0.2 km N Bartlett Pond BP 2.7 km SE Powder Point Control pp 13 km NNW Sediment Discharge Canal Outfall DIS 0.8 km NE Plymouth Harbor Ply-H 4.1 km w Duxbury Bay Control Dux-Bay 14 km NNW Plymouth Beach PLB 4.0 km WNW Manomet Point MP 3.3 km ESE Green Harbor Control GH 16 km NNW Irish Moss Discharge Canal Outfall DIS 0.7 km NNE Manomet Point MP 4.0 km ESE Ellisville EL 12 km SSE Brant Rock Control BR 18 km NNW Shellfish Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor Ply-H 4.1 km w Duxbury Bay Control Dux-Bay 13 km NNW Manomet Point MP 4.0 km ESE Green Harbor Control GH 16 km NNW Lobster Discharge Canal Outfall DIS 0.5 km N Plymouth Harbor Ply-H 6.4 km WNW Duxbury Bay Control Dux-Bay 11 km NNW Fishes Discharge Canal Outfall DIS 0.5 km N Priest Cove Control PC 48 km SW Jones River Control JR 13 km WNW Vineyard Sound Control MV 64 km SSW Buzzard's Bay Control BB 40 km SSW Cape Cod Bay Control CC-Bay 24 km ESE Page 36 36

Table 2.4-1 Offsite Environmental TLD Results TLD Station TLD Location* Quarterly Exposure - mR/quarter (Va lue +/- Std.Dev.)

2017 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/vear Zone 1 TLDs : 0-3 km 0-3 km 18.8 +/- 5.4 19.2+/-6.4 20.6 +/- 9.4 20.2 +/- 7.8 78 .8 +/- 29 .5 BLW BOAT LAUNCH WEST 0.11kmE 32.3 +/- 1.6 40.1 +/- 1. 7 47 .6 +/- 2.4 39.7+/-1 .6 159.7 +/- 25 .2 OA OVERLOOK AREA 0.15kmW 42 .3 +/- 2.6 47.3 +/- 3.3 66.2 +/- 3.1 60.1+/-3.0 215.8 +/- 44.7 TC HEALTH CLUB 0.15 km WSW 21.1 +/- 1.2 22 .3+/-1 .1 27.3 +/- 1.2 25.0+/-1 .1 95.7+/-11.3 BLE BOAT LAUNCH EAST 0.16 km ESE 29.3 +/- 1.3 30.6 +/- 1.4 35.0 +/- 1.3 35.6 +/- 1.4 130.4 +/- 12.9 PB PEDESTRIAN BRIDGE 0.21 km N 29.5 +/- 1.9 28.4 +/- 1.9 30.9 +/- 1.4 29.2 +/- 1.6 118.0+/-5.4 ISF-3 ISFSl-3 0.21 kmW 27.1 +/- 1.2 20.7 +/- 0.9 37.3 +/- 1.3 M+/-M 113.4+/-33.7 P01 SHOREFRONT SECURITY 0.22 km NNW 18.8 +/- 0.8 19.6 +/- 0.9 21.4+/-1 .2 20 .1+/-1 .2 80.0 +/- 4.9 WS MEDICAL BUILDING 0.23 km SSE 21 .8+/-1 .3 20.4 +/- 0.9 25 .5 +/- 1.2 22 .9 +/- 1.6 90.5 +/- 9.0 ISF-2 ISFSl-2 0.28 kmW 20.4 +/- 1.0 30.4 +/- 1.5 24 .2 +/- 1.3 22.9 +/- 1.2 97.8 +/- 17.2 CT PARKING LOT 0.31 km SE 20.1 +/- 1.1 20.0 +/- 1.1 23 .6 +/- 1.2 22.4 +/- 1.2 86.0 +/- 7.6 ISF-1 ISFSl-1 0.35 km SW 18.5 +/- 0.8 19.7 +/- 1.2 20.2 +/- 0.9 20 .7 +/- 0.9 79.2 +/- 4.3 PA SHOREFRONT PARKING 0.35 km NNW 19.4+/-1 .0 19.6+/-1 .0 19.8 +/- 0.9 20.9+/-1 .1 79.7 +/- 3.3 A STATION A 0.37 km WSW 16.7+/-1 .3 17.3 +/- 0.9 17.9+/-1.4 17.8 +/- 0.8 69.6 +/- 3.2 F STATION F 0.43 km NW 15.8 +/- 0.9 16.3 +/- 0.8 16.3 +/- 0.7 16.8 +/- 0.9 65.2 +/- 2.2 EB EAST BREAKWATER 0.44 km ESE 18.3+/-1 .1 18.3 +/- 0.8 19.3 +/- 0.9 19.9 +/- 0.8 75.8 +/- 3.7 8 STATION 8 0.44 km S 21.4+/-1.0 22 .2 +/- 1.0 22 .8 +/- 1.2 22 .6 +/- 1.0 89 .0 +/- 3.2 PMT PNPS MET TOWER 0.44 km WNW 18.4+/-0.9 19.7+/-0.9 19.1 +/- 0.7 19.6 +/- 1.0 76 .8 +/- 2.9 H STATION H 0.47 km SW 18.2 +/- 0.9 18.4+/-1 .2 18.9+/-1.0 18.3+/-1 .1 73 .8 +/- 2.5 I STAT ION I 0.48 km WNW 16.2+/-1 .0 17.2+/-0.7 17.5 +/- 0.8 18.0 +/- 0.8 68 .9 +/- 3.4 L STAT ION L 0.50 km ESE 18.3 +/- 0.8 17.4 +/- 0.8 19.1 +/- 0.8 20.5 +/- 1.0 75.3 +/- 5.4 G STATION G 0.53 kmW 16.5+/-1 .0 16.2 +/- 0.8 16.5 +/- 0.7 17.9+/-1.4 67 .1 +/- 3.6 D STATION D 0.54 km NNW 17.5+/-1 .0 17.7 +/- 0.9 18.3 +/- 0.6 18.5+/-1 .1 71 .8+/-2.7 PL PROPERTY LINE 0.54 km NW 17.1 +/- 1.0 16.8+/-0.9 17.7 +/- 0.7 17.5+/-1 .5 69 .1+/-2.7 C STATION C 0.57 km ESE 16.8 +/- 0.8 17.2 +/- 1.2 17.9 +/- 1.0 18.6 +/- 0.8 70.6 +/- 3.7 HS HALL'S BOG 0.63 km SE 18.1 +/- 1.1 18.2 +/- 1.1 18.3+/-1.1 18.7 +/- 0.9 73.3 +/- 2.3 GH GREENWOOD HOUSE 0.65 km ESE 18.5+/-1 .0 17.2 +/- 0.7 16.7+/-0.6 18.1+/-0.9 70.5 +/- 3.6 WR W ROCKY HILL ROAD 0.83 km WNW 21 .9 +/- 0.9 20.6 +/- 1.0 21 .6+/-1.4 21 .5 +/- 1.0 85.6 +/- 3.2 ERE ROCKY HILL ROAD 0.89 km SE 16.1 +/- 0.8 15.5+/-0.7 15.5 +/- 0.6 16.1+/-0.9 63.3 +/- 2.1 MT MICROWAVE TOWER 1.03 km SSW 18.5+/-1 .0 16.8 +/- 0.8 17.1 +/- 0.9 19.0 +/- 0.9 71.5 +/- 4.6 CR CLEFT ROCK 1.27 km SSW 17.2 +/- 0.9 16.7 +/- 0.9 16.8 +/- 0.7 M+/-M 67.7 +/- 2.3 BO BAYSHORE/GATE RD 1.34 km WNW 17.5 +/- 0.9 17.2 +/- 0.8 17.7+/-1. 1 18.6+/-0.8 71.0 +/- 2.9 MR MANOMET ROAD 1.38 km S 17.7 +/- 1.1 18.4 +/- 1.4 17.7 +/- 0.8 18.4+/-1 .0 72.2 +/- 2.8 DR DIRT ROAD 1.48 km SW 13.8+/-0.9 14.4 +/- 0.8 14.5 +/- 0.7 15.4 +/- 0.8 58.2 +/- 3.1 EM EMERSON ROAD 1.53 km SSE 16.3+/-0.9 15.8 +/-0.7 15.9 +/- 0.7 16.5 +/- 0.7 64.5 +/- 2.0 EP EMERSON/PRISCILLA 1.55 km SE 16.3 +/- 0.7 15.7 +/- 0.9 16.3+/-1.2 16.0 +/- 0.8 64.3 +/- 2.2 AR EDISON ACCESS ROAD 1.59 km SSE 14.6 +/- 0.8 14.8 +/- 0.7 14.6 +/- 0.6 15.7 +/- 0.8 59.6 +/- 2.5 BS BAYSHORE 1.76 kmW 17.8 +/- 0.9 19.0 +/- 1.2 18.2 +/- 0.7 19.6 +/- 1.5 74.6 +/- 3.9 E STATION E 1.86 km S 15.4+/-1.2 16.3 +/- 0.8 16.8 +/- 0.7 17.4 +/- 0.9 65 .8 +/- 3.9 JG JOHN GAULEY 1.99 kmW 16.7 +/- 0.9 17.6+/-1 .0 17.2 +/- 0.9 17.4+/-1 .1 68 .9 +/- 2.4 J STATION J 2.04 km SSE 15.9 +/- 0.8 15.4 +/- 0.9 15.6 +/- 0.8 16.1+/-0.9 63.0 +/- 2.0 WH WHITEHORSE ROAD 2.09 km SSE 15.8+/-0.9 15.8+/-1 .2 16.6 +/- 0.7 16.3+/-0.9 64.4 +/- 2.4 RC PLYMOUTH YMCA 2.09 km WSW 15.4 +/- 0.9 15.3 +/- 0.9 15.5 +/- 0.8 16.3 +/- 0.8 62 .5 +/- 2.5 K STATION K 2.17kmS 14.3 +/- 0.8 14.8+/-1 .1 14.2 +/- 0.7 15.5+/-1 .0 58.9 +/- 3.0 TT TAYLOR/THOMAS 2.26 km SE 14.5 +/- 0.7 14.7 +/- 0.9 14.7 +/- 0.9 14.7+/- 0.9 58.6 +/- 1.7 YV YANKEE VILLAGE 2.28 km WSW 16.9 +/- 0.8 17.2 +/- 0.9 16.9 +/- 0.7 17.5+/-1.0 68.4 +/- 2.1 GN GOODWIN PROPERTY 2.38 km SW 12.2 +/- 0.7 12.3+/-0.6 12.4 +/- 0.7 13.7 +/- 0.8 50.6 +/- 3.1 RW RIGHT OF WAY 2.83 km S 12.6 +/- 0.9 12.0 +/- 0.6 12.8 +/- 0.6 13.0+/-1.0 50.4 +/- 2.3 TP TAYLOR/PEAR L 2.98 km SE 14.8 +/- 0.8 15.0+/-0.7 14.9 +/- 0.9 14.8 +/- 1.0 59.4 +/- 1.8

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithm etic mean of the observed quarterly values multiplied by four quarters/year.

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Table 2.4-1 (continued)

Offsite Environmental TLD Results TLD Station TLD Location* Quarterl1 Exposure - mR/auarter (Value +/- Std .Dev.)

2017 Annual**

ID Description Distance/Direction Jan-Mar Apr-J un Jul-Sep Oct-Dec Exposure mR/vear Zone 2 TLDs : 3-8 km 3-8 km 15.0+/-1 .9 14.8 +/- 2.0 15.1 +/- 1.8 15.4 +/- 2.2 60 .3 +/- 7.8 VR VALLEY ROAD 3.26 km SSW 13.7 +/- 0.8 13.7 +/- 0.7 13.9+/-0.7 13.8+/-1.0 55 .1+/-1.6 ME MANOMET ELEM 3.29 km SE 16.6 +/- 0.9 15.9 +/- 0.8 16.8+/-1 .0 16.0 +/- 0.7 65.4 +/- 2.5 WC WARREN/CLIFFORD 3.31 kmW 14.9 +/- 0.8 15.3+/-0.7 15.2 +/- 0.9 M+/-M 60.6 +/- 2.1 BB RT.3A/BARTLETT RD 3.33 km SSE 15.6 +/- 0.8 16.1 +/- 0.8 15.9 +/- 0.6 17.4 +/- 1.0 65.0 +/- 3.6 MP MANOMET POINT 3.57 km SE 14.7+/-1.3 14.1 +/- 0.6 14.5 +/- 0.8 14.6+/-0.9 57 .8 +/- 2.1 MS MANOMET SUB STATION 3.60 km SSE 18.4 +/-0.9 17.6+/-1.4 17.5 +/- 0.7 18.4 +/- 0.8 71 .8 +/- 2.8 BW BEACHWOOD ROAD 3.93 km SE 16.0 +/- 1.0 15.6 +/- 0.7 15.8+/-1 .1 16.0+/-1.1 63.3 +/- 2.1 PT PINES ESTATE 4.44 km SSW 14.0 +/- 0.8 13.8 +/- 0.8 14.0 +/- 0.9 14.1 +/- 1.3 56.0 +/- 2.0 EA EARL ROAD 4.60 km SSE 14.4 +/- 0.9 14.9 +/- 0.7 M+/-M 15.7 +/- 0.8 60 .1 +/- 3.0 SP S PLYMOUTH SUBST 4.62 kmW 15.4 +/- 0.8 14.9 +/- 0.9 16.1+/-0.9 15.5 +/- 0.9 61 .9+/-2.7 RP ROUTE 3 OVERPASS 4.81 km SW 16.1+/-1 .0 15.4 +/- 0.8 16.3 +/- 0.7 16.3+/-1 .0 64.1 +/- 2.5 RM RUSSELL MILLS RD 4.85 km WSW 14.8 +/- 1.0 14.8 +/- 0.6 15.0+/- 0.9 15.3 +/- 1.2 59.9 +/- 2.1 HD HILLDALE ROAD 5.18 kmW 15.6+/-1 .0 16.0 +/- 0.9 15.4+/-1 .1 17.0 +/- 0.7 64.0 +/- 3.4 MB MANO MET BEACH 5.43 km SSE 15.6 +/-1 .0 16.4 +/- 1.3 16.1+/-0.9 16.7 +/- 0.6 64.7 +/- 2.6 BR BEAVERDAM ROAD 5.52 km S 15.5 +/- 0.8 16.0+/-0.7 15.9 +/- 0.9 16.4 +/- 0.9 63.8 +/- 2.2 PC PLYMOUTH CENTER 6.69 kmW 11 .2+/-0.6 10.6 +/- 0.6 10.7 +/- 0.6 11.9+/-1 .0 44 .4 +/- 2.7 LO LONG POND/DREW RD 6.97 km WSW 12.7 +/- 0.9 12.5 +/- 0.7 13.4 +/- 0.6 12.8 +/- 0.7 51.4+/-2.1 HR HYANNIS ROAD 7.33 km SSE 14.7 +/- 0.9 14.0 +/- 0.7 14.0 +/- 0.5 14.8 +/- 0.8 57.5 +/- 2.2 SN SAQUIS H NECK 7.58 km NNW 11 .6+/-0.9 11 .0+/-0.7 12.1 +/- 0.6 11 .1 +/- 1.0 45.8 +/- 2.5 MH MEMORIAL HALL 7.58 km WNW 19.5 +/- 0.8 19.2 +/- 1.4 18.5 +/- 0.8 20.4 +/- 1.2 77.7 +/- 3.8 CP COLLEGE POND 7.59 km SW 14.1 +/- 0.7 13.5 +/- 0.7 14.6 +/- 0.8 14.7+/-0.6 56.9 +/- 2.7 Zone 3 TLDs : 8-15 km 8-15 km 14.7+/-1.8 14.1+/-1.5 15.1 +/- 1.4 14.9+/-1.8 58.7 +/- 6. 3 OW DEEP WATER POND 8.59 kmW 16.5 +/- 1.0 15.4 +/- 0.7 17.2 +/- 0.9 16.9+/- 1.2 66.1 +/-3.7 LP LONG POND ROAD 8.88 km SSW 13.0+/-0.8 13.3 +/- 0.8 14.1+/-0.8 13.6+/-1 .3 54 .0 +/- 2.7 NP NORTH PLYMO UTH 9.38 km WNW 17.9 +/- 0.9 16.8 +/- 1.0 16.8+/-0.7 18.4 +/- 0.9 69.9 +/- 3.6 SS STANDISH SHORES 10.39 km NW 15.2+/-1 .0 14.9 +/- 0.9 15.1+/-0.9 14.5 +/- 0.8 59 .8 +/- 2.2 EL ELLISVILLE ROAD 11 .52 km SSE 15.2 +/- 1.0 15.1 +/-0.8 14.9 +/- 0.8 16.0 +/- 0.7 61 .2 +/- 2.6 UC UP COLLEGE POND RD 11 .78 km SW 13.0 +/- 1.0 12.0 +/- 0.6 13.4 +/- 0.7 13.0 +/- 0.8 51 .3+/-2.8 SH SACRED HEART 12.92 km W 14.4+/- 0.7 13.9+/-1 .0 14.5 +/- 0.7 15.3 +/- 0.9 58.1 +/- 2.8 KC KING CAESAR ROAD 13.11 km NNW Missina 13.8 +/- 0.9 16.7 +/- 1.2 14.0 +/- 0.8 59.4 +/- 6.9 BE BOURNE ROAD 13.37 km S 12.8 +/- 0.7 12.6 +/- 0.7 13.8 +/- 0.6 13.0 +/- 0.8 52 .3 +/- 2.5 SA SHERMAN AIRPORT 13.43 km WSW 14.0 +/- 0.9 12.9 +/- 0.6 13.9+/-0.7 14.4 +/- 0.7 55.2 +/- 2.9 Zone 4 TLDs: >15 km >15 km 15.5+/-2.1 15.3 +/- 2.3 16.0 +/- 2.2 15.9+/-2.7 62.6 +/- 8.8 CS CEDARVILLE SUBST 15.93 km S 16.3+/-1 .0 15.7+/-0.8 15.0 +/- 0.6 15.6 +/- 1.1 62.6 +/- 2.7 KS KINGSTON SUBST 16.15 km WNW 15.3 +/- 0.9 15.0 +/- 0.8 15.5 +/- 0.9 16.1+/-0.9 61 .9 +/- 2.6 LR LANDING ROAD 16.46 km NNW 13.7 +/- 0.6 13.7 +/- 0.7 15.1 +/- 0.6 14.1 +/- 0.8 56 .6 +/- 3.0 CW CHURCH/WEST 16.56 km NW 12.1+/-0.9 11 .9 +/- 1.0 13.4 +/- 0.7 12.1+/-0.8 49.5 +/- 3.3 MM MAIN/MEADOW 17.02 km WSW 15.1+/-1 .0 14.6+/-0.7 15.2+/-0.7 15.4+/-0.7 60.2 +/- 2.1 DMF DIV MAR INE FISH 20.97 km SSE 18.5 +/- 0.7 18.6+/-1 .0 18.4 +/- 0.9 20.7 +/- 0.9 76.2 +/- 4.8 EW E WEYMOUTH SUBST 39.69 km NW 17.2 +/- 0.7 17.3+/-1 .0 19.6+/-1.4 17.2+/-1 .1 71.3+/-5.1

• Distance and direction are measured from centerline of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

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Table 2.4-2 Onsite Environmental TLD Results TLD Station TLD Location* Quarterl, Exposure - mR/quarter (Value +/- Std .Dev.)

2017 Annual**

ID Description Distance/Direction Jan-Mar Apr-Jun Jul-Sep Oct-Dec Exposure mR/year Onsite TLDs P21 O&M/RXB . BREEZEWAY 50 m SE 31 .3+/-1.4 50.9 +/- 2.2 43 .1+/-1 .5 28.1 +/- 1.3 153.4 +/- 42.4 P24 EXEC.BUILDING 57mW 40.0 +/- 1.8 48.3 +/- 2.3 61 .3 +/- 2.8 54.8 +/- 2.4 204 .4 +/- 36 .9 P04 FENCE-R SCREENHOUSE 66 m N 50.3 +/- 2.1 57.5 +/- 3.5 60.8 +/- 2.8 51 .6 +/- 2.4 220.1 +/- 20 .7 P20 O&M - 2ND W WALL 67 m SE 28.2 +/- 1.4 33.8 +/- 1.7 42 .9 +/- 2.1 37.1+/-1 .8 142.1+/-25.0 P25 EXEC .BUILDING LAWN 76 m WN-N 47.1 +/- 2.3 53.3 +/- 3.0 73 .0 +/- 5.9 57.0 +/- 3.2 230 .5 +/- 44 .7 P05 FENCE-WATER TANK 81 m NNE 23 .9 +/- 0.9 27.1 +/- 2.1 26 .5 +/- 1.2 24.6 +/- 1.6 102.0 +/- 6.9 P06 FENCE-OIL STORAGE 85 m NE 30.9 +/- 1.3 32 .8 +/- 1.5 35 .0 +/- 1.4 34.0+/-1 .5 132.6 +/- 7.8 P19 O&M - 2ND SW CORNER 86 m S 21 .7+/-0.8 23.7+/-1 .2 28 .6 +/- 1.2 25.0 +/- 1.0 99.0+/-11.9 P18 O&M - 1ST SW CORNER 90 m S 28.4+/-1 .7 33.9 +/- 1.9 46 .6 +/- 3.3 37.5 +/- 3.4 146.4 +/- 31 .0 P08 COMPRESSED GAS STOR 92 m E 33.5 +/- 3.2 39 .2 +/- 1.9 49 .6 +/- 2.1 40.3 +/- 2.2 162.7 +/- 27 .1 P03 FENCE-L SCREENHOUSE 100 m NW 34 .8 +/- 1.4 38.0 +/- 2.4 51.0 +/- 2.1 42.4 +/- 2.0 166.1+/-28.4 P17 FENCE-EXEC .BUILDING 107 mW 132.6 +/- 4.5 139.6 +/- 6.2 163.2 +/- 6.2 146.5 +/- 7.1 581 .9 +/- 53 .8 P07 FENCE-INTAKE BAY 121 m ENE 29 .9 +/- 1.6 31.5+/-1.4 37.3+/-1 .7 32.0 +/- 1.4 130.8+/-13.3 P23 O&M - 2ND S WALL 121 m SSE 28.5 +/- 1.3 34.4 +/- 1.9 44 .1 +/- 1.3 34.1+/-1 .3 141 .1 +/- 26 .0 P26 FENCE-WAREHOUSE 134 m ESE 29 .8 +/- 2.0 32 .2 +/- 1.6 38 .9 +/- 2.5 34.3 +/- 2.2 135.3 +/- 15.9 P02 FENCE-SHOREFRONT 135 m NW 28.8 +/- 1.4 28.9 +/- 1.3 37 .2+/-1 .7 31.6 +/- 1.3 126.6 +/- 16.0 P09 FENCE-W BOAT RAMP 136 m E 27.8 +/- 1.3 29.4 +/- 1.8 35.6 +/- 1.5 30 .8+/- 1.1 123.5 +/- 13.9 P22 O&M - 2ND N WALL 137 m SE 21 .6+/-1 .0 22 .2 +/- 0.9 23.8 +/- 1.0 21 .7 +/- 1.1 89.4 +/- 4.6 P16 FENCE-W SWITCHYARD 172 m SW 73.3 +/- 4.3 87 .3 +/- 4.6 125.1 +/- 4.3 104.8 +/- 4.9 390.4 +/- 90.1 P11 FENCE-TCF GATE 183 m ESE 38 .7+/-1 .7 37 .5 +/- 1.6 43.0 +/- 2.8 44.9 +/- 1.8 164.1 +/- 14.5 P27 FENCE-TCF/BOAT RAMP 185 m ESE 24 .9 +/- 1.5 24.9 +/- 1.6 30.2 +/- 1.8 28.5 +/- 2.0 108.5 +/- 11 .3 P12 FENCE-ACCESS GATE 202 m SE 24 .0 +/- 1.0 25.2 +/- 1.3 30.6 +/- 1.6 26.8 +/- 1.0 106.6+/-11.7 P15 FENCE-E SWITCHYARD 220 m S 22 .5+/-1 .1 25.7 +/- 1.3 30.4 +/- 1.2 26.6 +/- 1.0 105.2 +/- 13.2 P10 FENCE-TCF/INTAKE BAY 223 m E 27 .6 +/- 1.2 28.0 +/- 2.0 32 .5 +/- 1.9 34.5 +/- 2.9 122 .6 +/- 14.2 P13 FENCE-MEDICAL BLDG . 224 m SSE 22.7+/-1 .0 25 .0 +/- 1.0 31 .0+/-1.4 25.9 +/- 1.0 104.7+/-14.1 P14 FENCE-BUTLER BLDG 228 m S 19.1 +/- 1.4 20 .4 +/- 1.3 23 .9 +/- 1.6 20.6+/-1 .1 84.1 +/-8.7 P28 FENCE-TCF/PRKNG LOT 259 m ESE 48.3 +/- 3.0 56 .9 +/- 2.8 60.0 +/- 2.2 49.1+/-2.0 214.4 +/- 23 .6

• Distance and direction are measured from centerli ne of Reactor Building to the monitoring location.

• • Annual value is based on arithmetic mean of the observed quarterly values multiplied by four quarters/year.

Page 39 39

Table 2.4-3 Average TLD Exposures By Distance Zone During 2017 Averaqe Exposure +/- Standard Deviation : mR/oeriod Exposure Zone 1* Zone 2 Zone 3 Zone 4 Period 0-3 km 3-8 km 8-15 km >15 km Jan-Mar 18.8+/-5.4 15.0 +/- 1.9 14.7 +/- 1.8 15.5 +/- 2.1 Apr-Jun 19.2+/-6.4 14.8 +/- 2.0 14.1+/-1 .5 15.3 +/- 2.3 Jul-Sep 20.6 +/- 9.4 15.1+/-1 .8 15.1+/-1.4 16.0 +/- 2.2 Oct-Dec 20 .2 +/- 7.8 15.4 +/- 2.2 14.9 +/- 1.8 15.9 +/- 2.7 Jan-Dec 78 .8 +/- 29.5 60.3 +/- 7.8 58 .7 +/- 6.3 62.6 +/- 8.8

• Zone 1 extends from the PNPS restricted/protected area boundary outward to 3 kilometers (2 miles) , and includes several TLDs located within the site boundary.

• • When corrected for TLDs located within the site boundary , the Zone 1 annual average is calculated to be 60.3 +/- 7.7 mR/yr.

Page 40 40

Table 2.5-1 Air Particulate Filter Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth , MA (January - December 2017)

I MEDIUM : Air Particulates (AP) UNITS : gCi/cubic meter Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station : Mean+/- Std.Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction >LLD Gross Beta 566 0.01 1.5E-2 +/- 4.2E-3 EW : 1.6E-2 +/- 3.6E-3 1.6E-2 +/- 3.6E-3 0 4.8E 5.5E-2 7.1 E 2.4E-2 7.1 E 2.4E-2 I 514 / 514 52152 52152 Be-7 44 1.2E-1 +/- 1.8E-2 PC : 1.3E-1 +/- 2.0E-2 1.2E-1 +/-3.0E -2 0 7.8E 1.5E-1 1.1E 1.5E-1 9.6E 1.5E-1 40 / 40 4/4 4/4 Cs-134 44 0.05 -3 .0E-4 +/- 7.9E-4 EB : 6.8E-5 +/- 8.5E-4 -3.5E-4 +/- 8.2E-4 0 -2.4E 1.5E-3 -6.5E 7.3E-4 -9.8E 5.7E-4 I 0140 0/4 0/4 Cs-137 44 0.06 1.2E-1 +/- 1.8E-2 PC: 1.3E-1 +/- 2.0E-2 1.2E-1 +/- 3.0E-2 0 7.8E 1.5E-1 1.1E-1 -1 .5E-1 9.6E 1.5E-1 0140 0140 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 41 41

Table 2.6-1 Charcoal Cartridge Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

MEDIUM: Charcoal Cartridge (CF) UNITS : pCi/cubic meter Ind icator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station: Mean+/- Std .Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD 1-131 569 0.07 -4.0E-4 +/- 1.0E-2 WS: 3.2E-4 +/- 8.7E-3 -1.BE-4 +/- 9.2E-3 0 -5.5E 2.9E-2 -1.9E 2.7E-2 -2.1E 2.3E-2 01517 0152 0152

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 42 42

Table 2.7-1 Milk Radioactivity Analyses Rad iolog ical Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

No milk sampling was performed during 2017 , as no suitable indicator locations for milk production were available for sampling within 5 miles of Pilgrim Station .

Page 43 43 L__

Table 2 .8-1 Forage Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth , MA (January - December 2017)

No forage sampling was performed during 2017, as no grazing anima ls used for food products were available at any indicator locations within 5 miles of Pilgrim Station .

Page 44 44

Table 2.9-1 VegetableNegetation Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

MEDIUM : Vegetation /TF) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station : Mean+/- Std .Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 17 1.3E+3 +/- 1.7E+3 CftRk: 3.9E+3 +/- 2.1 E+2 3.2E+2 +/- 8.2E+2 0 -5.2E+1 - 3.9E+3 3.9E+3 - 3.9E+3 -1.3E+2 - 2.5E+3 4/8 1/ 1 1/ 9 K-40 17 2.2E+3 +/- 4.7E+2 DMF : 2.9E+3 +/- 1.9E+2 2.3E+3 +/- 1.4E+3 0 1.7E+3 - 3.1E+3 2.9E+3 - 2.9E+3 6.9E+2 - 5.2E+3 8/8 1/ 1 9/9 1-131 17 60 1.1 E+O +/- 1.3E+1 CftRk: 2.4E+1 +/- 1.3E+1 9.7E-1 +/- 7.8E+O 0 -1.4E+1 - 2.4E+1 2.4E+1 - 2.4E+1 -9.7E+ 0 -1.1E+1 0/8 0/ 1 0/9 Cs-134 17 60 1.8E+O +/- 5.7E+O EBkWtr: 7.5E+O +/- 6.8E+O -2.3E+O +/- 7.4E+O 0 -6.1 E+O - 7.8E+O 7.5E+O - 7.5E+O -1.7E+1 - 5.8E+O 0/8 0/ 1 0/9 Cs-137 17 80 1.9E+1 +/- 3.4E+1 PnHISum : 9.8E+1 +/- 1.6E+1 1.6E+O +/- 8.0E+O 0 -9 .7E+O - 9.8E+1 9.8E+1 - 9.8E+1 -1 .2E+1 - 9.2E+O 1/ 8 1/ 1 0/9 AcTh-228 17 NOA NOA NOA 0 NOA NOA NOA 0/8 0/ 1 0/9

• Non-Routine refers to those radionuclid es that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 45 45

Table 2.10-1 Cranberry Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

MEDIUM : Cranberries (CB) UNITS : pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station: Mean+/- Std.Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-rou tine* LLD Fraction>LLD Fraction>LLD Fraction>LLD Be-7 1 BogHlw: 2.0E+2 +/- 4.0E+1 2.0E+2 +/- 4.0E+1 0 No Samples Collected 2.0E+2 - 2.0E+2 2.0E+2 - 2.0E+2 1/ 1 1/ 1 K-40 1 BogHlw: 6.1 E+2 +/- 8.8E+1 6.1E+2 +/- 8.8E+1 0 No Samples Collected 6.1E+2-6.1E+2 6.1E+2 - 6.1E+2 1/ 1 1/ 1 1-131 1 60 BogHlw: 7.3E-1 +/- 6.2E+O 7.3E-1 +/- 6.2E+O 0 No Samples Collected 7.3E 7.3E-1 7.3E 7.3E-1 0/1 0/ 1 Cs-134 1 60 BogHlw: 1.6E+O +/- 4.0E+O 1.6E+O +/- 4.0E+O 0 No Samples Collected 1.6E+O - 1.6E+O 1.6E+O - 1.6E+O 0/ 1 0/1 Cs-137 1 80 BogHlw 3.4E+O +/- 4.4E+O 3.4E+O +/- 4.4E+O 0 No Samples Collected 3.4E+O - 3.4E+O 3.4E+O - 3.4E+O 0/ 1 0/ 1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 46 46

Table 2.12-1 Surface Water Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

MEDIUM : S urface Water (WS) UNITS : pCi/L Radionuclide No. Analyses Required Indicator Stations Station with Hiqh est Mean Control Stations H-3 12 3000 -7.5E+O +/- 6.0E+1 DIS: 5.6E+O +/- 7.8E+1 -1.6E+1 +/- 6.9E+1 0 -8.8E+1 - 5.4E+ 1 -8 .8E+1 - 5.4E+1 -7.5E+1 - 5.5E+1 0/8 0/4 0/4 K-40 36 1.5E+2 +/- 1.4E+2 DIS: 2.8E+2 +/- 1.9E+1 2.8E+2 +/- 3.8E+1 0 -3.4E+1 - 3.2E+2 2.6E+2 - 3.2E+2 2.3E+2 - 3.4E+2 13 / 24 12 / 12 12 / 12 Mn-54 36 15 -1.8E-1 +/- 1.0E+O DIS: 6 .5E-2 +/- 8.8E-1 -4 .1E-2 +/- 1.2E+O 0 -3 .2E+O - 1.4E+O -1.4E+O - 1.4E+O -2 .6E+O - 1.3E+O 0 / 24 0 / 12 0 / 12 Fe-59 36 30 8.1 E-1 +/- 2.0E+O BarPnd : 9.3E- 1 +/- 2.7E+O 8.8E-1 +/- 2.2E+ O 0 -2 .7E+O - 6 .3E+O -2 .7E+O - 6.3E+O -2 .7E+O - 3.5E+O 0 / 24 0 / 12 0 / 12 Co-58 36 15 -4.5E-1 +/- 1.1 E+O DIS: -3.1E-1 +/- 9.9E-1 -4.4E-1 +/- 6 .9E-1 0 -2 .3E+O - 1.9E+O -1.7E+O - 1.2E+O -1.1E+O- 7 .1E-1 0 / 24 0 / 12 0 / 12 Co-60 36 15 3.1E-1 +/- 1.2E+O BarPnd : 6 .3E-1 +/- 1.3E+O 3.8E-1 +/- 1.0E+O 0 -2.5E+O - 3.1E+O -1.8E+ O - 3.1E+O -1.3E+O - 2 .3E+O 0/ 24 0 / 12 0 / 12 Zn-65 36 30 -2.6E+O +/- 3.1 E+O BarPnd :-1.8E+O +/- 3.6E+O -2.3E+O +/- 3.1E+O 0 -9.1 E+O - 3.5E+O -9 .1 E+O - 3.5E+O -8 .6E+0 -1.1E+ O 0 / 24 0 / 12 0 / 12 Zr-95 36 30 2.9E-1 +/- 2.3E+O BarPnd : 6.7E-1 +/- 2.8E+O -3 .1 E-1 +/- 2.4E+O 0 -4.4E+O - 6.0E+O -4.4E+O - 6.0E+O -6 .1 E+O - 3.0E+O 0 / 24 0 / 12 0 / 12 Nb-95 36 15 4.1E-1 +/- 1.3E+O BarPnd :1.1E+O +/- 1.4E+O 1.5E-1 +/- 1.3E+O 0 -2.6E+O - 3.3E+O -5.6E 3.3E+O -1.4E+O - 2.6E+O 0 / 24 0 / 12 0 / 12 1-131 36 15 -2.1 E-1 +/- 3.4E+O DIS: 8.2E-1 +/- 2 .8E+O -1.1 E+O +/- 3.8E+O 0 -9 .2E+O - 5.1 E+O -3 .7E+O - 5.1E+O -8 .9E+O - 3.3E+O 0/ 24 0 / 12 0 / 12 Cs-134 36 15 -7.9E-2 +/- 8.0E-1 BarPnd :1.8E-2 +/- 7.2E- 1 -2.2E-1 +/- 1.5E+O 0 -1.5E+O - 1.7E+O -6.8E 1.7E+O -2 .3E+O - 2 .6E+O 0 / 24 0 / 12 0 / 12 Cs-137 36 18 1.0E-1 +/- 8.6E-1 BarPnd : 4.3E- 1 +/- 8.5E- 1 4.4E-3 +/- 9.9E-1 0 -1 .6E+O - 1.9E+O -6.5E 1.9E+O -1.6E+O - 2.0E+O 0 / 24 0 / 12 0 / 12 Ba-140 36 60 9.7E-1 +/- 6.2E+O PwdPt: 1.5E+O +/- 7 .8E+O 1.5E+O +/- 7.8E+O 0 -9.7E+O - 1.0E+1 -1 .5E+1 - 1.4E+1 -1.5E+ 1 - 1.4E+1 0 / 24 0 / 12 0 / 12 La-140 36 15 -1 .4E-1 +/- 2.3E+O DIS : -1 .2E-1 +/- 1.7E+O -1.8E+O +/- 3.4E+O 0 -5 .3E+O - 6 .1 E+O -1 .9E+O - 3.9E+O -7 .6E+O - 3.1E+O 0 / 24 0 / 12 0 / 12

• Non-Routine refers to th ose radionu clides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 47 47

Table 2.13-1 Sediment Radioactivity Analyses Radiolog ical Environmental Program Summary Pilgrim Nuclear Power Station, Plymouth, MA (January - December 2017)

MEDIUM : Sediment {SE) UNITS: pCi/kg dry Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station: Mean+/- Std .Dev. Mean +/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routi ne* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 13 1.1E+4 +/- 2.8E+3 DuxBay: 1.5E+4 +/- 6.7E+3 1.3E+4 +/- 4.0E+3 0 8.0E+3 - 1.7E+4 1.0E+4 - 2.0E+4 1.0E+4 - 2.0E+4 8/8 2/2 5/5 Cs-134 13 150 1.8E+ 1 +/- 1.7E+1 DuxBay: 5.1E+ 1 +/- 8.4E +1 4 .2E+1 +/- 4.3E+1 0 2.3E+O - 4.7E+1 -7 .0E+0-1 .1E+2 -7.0E+0-1 .1E+2 0/8 0/2 0/5 Cs-137 13 180 5.9E+O +/- 2.4E+1 PlyHbr: 1.7E+1 +/- 1.2E+1 1.0E+1 +/- 1.2E+1 0 -3.4E+1 - 3.7E+1 1.3E+ 1 - 2.0E+ 1 -1.3E+O - 2.3E+1 0/8 0/2 0/5 AcTh-228 13 5.1 E+2 +/- 3.0E+2 DIS: 8.2E+2 +/- 4.3E+2 4.7E+2 +/- 2.5E+2 0 1.8E+2- 1.1E+3 5.2E+2 - 1.1E+3 1.9E+2- 8.7E+2 8/8 2/2 5/5

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 48 48

Table 2.14-1 Irish Moss Radioact ivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth , MA (Janua ry

• December 2017)

MEDIUM : Irish Moss (All UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std .Dev. Station : Mean+/- Std .Dev. Mean +/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction >LLD Fraction>L LD Fraction >LLD Be-7 9 4.0E+2 +/- 1.7E+2 DIS : 4.6E+2 +/- 3.4E+2 1.7E+2 +/- 7.4E+1 0 2.3E+2

• 6.9E+2 2.3E+2

• 6.9E+2 9.9E+1

• 2.2E+2 4/6 1/2 1/ 3 K-40 9 6.7E+3 +/- 1.1 E+3 DIS: 7.7E+3 +/- 8.8E+2 4.6E+3 +/- 5.6E+2 0 5.4E+3

• 8.3E+3 7.1 E+3

• 8.3E+3 4.2E+3

• 5.2E+3 6/6 2/2 3/3 Mn-54 9 130 2.3E+O +/- 9.BE+O Ellsvl:9.1 E+O +/- 4.2E+O -1.4E+O +/- 6.9E+O 0 -1.1 E+1

• 1.0E+1 8.2E+O

• 1.0E+1 -4 .7E+O

• 4.4E+O 0/6 0/2 0/3 Fe-59 9 260 -1 .7E+1 +/- 1.8E+1 ManPt: -4.0E+O +/- 1.5E+ 1 -1.4E+1 +/- 3.1E+1 0 -4.6E+1

• 2.7E+O -1.1 E+ 1

• 2.7E+O -4 .8E+1

• 5.5E+O 0/6 0/2 0/3 Co-58 9 130 -9.0E+O +/- 7.5E+O BntRck:-6 .1 E+O +/- 1.5E+1 -6.1 E+O +/- 1.5E+1 0 -2.0E+1 * -1.2E+O -1.7 E+1

• 9.BE+O -1.7E+1

• 9.BE+O 0/6 0/3 0/3 Co-60 9 130 3.6E-1 +/- 7.9E+O DIS: 6.4E+O +/- 8. 7E+O -7.0E+O +/- 1.1E+1 0 -8.2E+O

• 9.4E+O 3.3E+O

• 9.4E+O -1.8E+1

• 7.4E-1 0/6 0/2 0/3 Zn-65 9 260 -7.BE-1 +/- 3.6E+1 DIS : 2.4E+1 +/- 5.5E+1 6.9E+O +/- 3.1E+ 1 0 -3.8E+1

• 6.0E+1 -1 .2E+1

• 6.0E+1 -2 .6E+1

• 3.2E+1 0/6 0/2 0/3 Cs-134 9 130 1.BE+O +/- 1.1E+1 Ellsvl : 4.3E+O +/- 4.7E+O -2.3E+O +/- 1.7E+1 0 -1.7E+1

• 1.3E+1 3.BE+O

• 4.9E+O -2 .0E+1 -1 .1E+1 0/6 0/2 0/3 Cs-137 9 150 5.3E+O +/- 5.7E+O ManPt: 9.2E+O +/- 8.9E+O -1.9E+O +/- 1.7E+1 0 2.7E+O

• 1.4E+1 4.3E+ O

• 1.4E+1 -1.6E+1

• 1.5E+1 0/6 0/2 0/3

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 49 49

Table 2.15-1 Shellfish Radioactivity Analyses Radiological Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth , MA (January - December 2017)

MEDIUM : Shellfish (SF) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean +/- Std.Dev. Station : Mean +/- Std .Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routi ne* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 11 1.7E+3 +/- 3.8E+2 DIS: 1.8E+3 +/- 3.3E+2 1.5E+3 +/- 4.9E+2 0 1.3E+3- 2.1E+3 1.7E+3 - 2.0E+3 9.4E+ 2 - 1.9E+3 6/6 2/2 5/5 Mn-54 11 130 -1 .5E+O +/- 1.3E+1 DIS: 4.9E+O +/- 1.1 E+ 1 -3.7E+O +/- 1.5E+1 0 -1.7E+1 - 9.5E+O 3.1 E 9.5E+O -2 .0E+1 - 7.4E+O 0/ 6 0/2 0/5 Fe-59 11 260 -6.7E+O +/- 3.0E+1 DIS: -5.5E+O +/- 4.0E+1 -2.4E+1 +/- 3.8E+1 0 -3.8E+1 - 2.8E+1 -3 .1 E+1 - 2.0E+1 -7.6E+1 -1.0E+1 0/6 0/2 0/5 Co-58 11 130 -6.BE+O +/- 2.5E+1 DuxBay: 9.1E+O +/- 2.2E+1 -3.1 E+O +/- 2.0E+1 0 -3.3E+1 - 2.6E+1 -5 .6E+ O - 2.4E+ 1 -2.8E+1 - 2.4E+1 0 /5 0/2 0 /5 Co-60 11 130 6.6E+O +/- 1.6E+ 1 PlyHbr: 1.1E+1 +/- 1.9E+1 4.0E+O +/- 1.7E+ 1 0 -5.9E+O - 3.5E+1 -9.9E 3.5E+1 -1.5E+1 - 2.3E+1 0/6 0/4 0/5 Zn-65 11 260 -4.5E+1 +/- 4.9E+1 DIS: -4 .3E+O +/- 2.4E+1 -4 .8E+1 +/- 3.2E+1 0 -9.6E+1 - -2.1E-1 -8 .4E+O - -2 .1E- 1 -8.7E+1 - -1.1 E+1 0/6 0/ 2 0/5 Cs-134 11 130 1.1E+O +/- 1.2E+1 PlyHbr: 2.6E+O +/- 1.5E+1 -1 .7E+1 +/- 1.3E+1 0 -1.0E+1 - 1.5E+1 -1.0E+1 - 1.5E+1 -2.5E+1 - -4.0E+O 0/6 0/4 0/5 Cs-137 11 150 3.4E+O +/- 1.2E+1 PlyHbr: 8.3E+O +/- 1.2E+1 -1.BE+O +/- 1.4E+1 0 -8 .0E+O - 1.9E+1 7.6E 1.9E+1 -1.4E+1 - 1.6E+1 0/6 0/4 0/5

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 50 50

Table 2.16-1 Lobster Radioactivity Analyses Radiologica l Environmental Program Summary Pilgrim Nuclear Power Station , Plymouth, MA (January - December 2017)

MEDIUM: American Lobster (HA) UNITS: pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station: Mean+/- Std.Dev. Mean+/- Std.Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 5 2.2E+3 +/- 5.3E+2 DIS: 2.2E+3 +/- 5.3E+2 2.1 E+3 +/- 4.4E+2 0 1.7E+3 - 2.7E+3 1.7E+3- 2.7E+3 2.1E+3 - 2.1E+3 4/4 4/4 1/ 1 Mn-54 5 130 1.1 E+1 +/- 1.4E+1 DIS: 1.1E+1 +/- 1.4E+1 -4.2E+O +/- 1.5E+1 0 -1 .1E+O - 2.1E+1 -1.1E+O - 2.1E+1 -4.2E+O - -4.2E+O 0/4 0/4 0/1 Fe-59 5 260 1.2E+ 1 +/- 6.5E+ 1 DIS : 1.2E+1 +/- 6.5E+1 -2 .3E+1 +/- 2.8E+1 0 -4 .6E+1 - 9.5E+1 -4 .6E+1 - 9.5E+1 -2 .3E+1 - -2.3E+1 0/4 0/4 0/ 1 Co-58 5 130 8.3E+O +/- 2.0E+1 DIS: 8.3E+O +/- 2.0E+1 1.4E+O +/- 1.4E+1 0 -1.5E+1 - 2.1E+1 -1.5E+1 - 2.1E+1 1.4E+O - 1.4E+O 0/4 0/4 0/ 1 Co-60 5 130 3.BE+O +/- 2.7E+1 CCBay: 8.9E+O +/- 1.2E+1 8.9E+O +/- 1.2E+1 0 -3 .0E+1 - 2.5E+1 8.9E+O - 8.9E+O 8.9E+O - 8.9E+O 0/4 0/ 1 0/ 1 Zn-65 5 260 -2.8E+1 +/- 5.5E+1 DIS: -2 .8E+1 +/- 5.5E+1 -3.3E+1 +/- 4 .0E+1 0 -7 .7E+1 - 4 .2E+1 -7 .7E+1 - 4.2E+1 -3.3E+1 - -3.3E+1 0/4 0/4 0/ 1 Cs -134 5 130 -3.5E+O +/- 1.9E+1 CCBay: 3.7E+O +/- 1.5E+1 3.7E+O +/- 1.5E+1 0 -2.1E+1 - 1.6E+1 3.7E+O - 3.7E+O 3.7E+O - 3.7E+O 0/4 0/ 1 0/ 1 Cs-137 5 150 4.0E+O +/- 3.7E+1 DIS : 4.0E+O +/- 3.7E+1 2.5E+O +/- 1.9E+1 0 -3.0E+1 - 4.9E+1 -3.0E+1 - 4.9E+1 2.5E+O - 2.5E+O 0/4 0/4 0/ 1

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 51 51

Table 2.17-1 Fish Radioactivity Analyses Radiologica l Environmental Program Summary Pilgrim Nuclear Power Station . Plymouth , MA (January - December 2017)

MEDIUM : Fish /FH) UNITS : pCi/kg wet Indicator Stations Station with Highest Mean Control Stations Mean+/- Std .Dev. Station : Mean +/- Std.Dev. Mean+/- Std .Dev.

No. Analyses Required Range Range Range Radionuclide Non-routine* LLD Fraction>LLD Fraction>LLD Fraction>LLD K-40 8 4.1 E+3 +/- 1.6E+3 DIS: 4.1E+3 +/- 1.6E+3 3.7E+3 +/- 9.4E+2 0 2.7E+3 - 6.4E+3 2.7E+3 - 6.4E+3 2.7E+3 - 4.9E+3 4/4 4/4 4/4 Mn-54 8 130 9.BE+O +/- 1.8E+1 DIS: 9.BE+O +/- 1.8E+1 -2.5E+O +/- 9.5E+O 0 -5 .2E+ O - 3.2E+1 -5.2E+O - 3.2E+1 -6.6E+O - 4.4E+O 0/4 0/4 0/4 Fe-59 8 260 3.9E+O +/- 2.7E+1 CCBay:2.2E+1 +/- 2.9E+ 1 -5.5E+O +/- 3.8E+1 0 -1 .2E+1 - 3.3E+1 2.2E+1 - 2.2E+1 -3.9E+1 - 2.4E+1 0/4 0/ 1 0/4 Co-58 8 130 -8 .2E-1 +/- 2.0E+1 CCBay: 6.1E+O +/- 1.1E+1 -4.3E+O +/- 2.1E+1 0 -2.4E+1 - 1.6E+1 6.1E+0 - 6.1E+O -2.7E+1 - 1.6E+1 0/4 0/1 0/4 Co-60 8 130 1.7E+1 +/- 2.0E+1 DIS: 1.7E+1 +/- 2.0E+1 7.2E+O+/- 1.8E+1 0 -6.2E+O - 3.BE+ 1 -6.2E+O - 3.8E+1 -2.1 E+O - 3.1 E+1 0/4 0/4 0/4 Zn-6 5 8 260 -2.7E+ 1 +/- 5.4E+1 BuzBay: 4.6E+1 +/- 5.6E+1 3.9E+1 +/- 4.8E+1 0 -6 .5E+1 - 4.1 E+1 -5.0E+O - 9.5E+ 1 -5.0E+O - 9.5E+1 0/4 0/3 0 /4 Cs-134 8 130 9.BE+ O +/- 1.9E+1 DIS: 9.BE+O +/- 1.9E+1 -1.8E+O +/- 1.4E+ 1 0 -8.9E 3.3E+1 -8.9E 3.3E+1 -1.4E+1 - 8.7E+O 0/4 0/4 0/4 Cs -137 8 150 -1.3E+1 +/- 3.4E+1 CCBay: 1.7E+1 +/- 1.2E+1 -6.2E+O +/- 2.1E+ 1 0 -5.6E+ 1 - 1.9E+1 1.7E+1 - 1.7E+1 -2.8E+1 - 1.7E+1 0/4 0/ 1 0/4

• Non-Routine refers to those radionuclides that exceeded the Reporting Levels in ODCM Table 3.5-4.

Page 52 52

Figure 2.2-1 Environmental TLD Locations Within the PNPS Protected Area TLD Station Location*

Description Code Distance/Direction TLDs Within Protected Area O&M/RXB. BREEZEWAY P21 50 m SE EXEC.BU ILDING P24 57 m w FENCE-R SCREENHOUSE P04 66 m N O&M - 2ND W WALL P20 67 m SE EXEC .BU ILDING LAWN P25 76 m WNW FENCE-WATER TANK P05 81 m NNE FENCE-O IL STORAGE P06 85 m NE O&M - 2ND SW CORNER P19 86 m s O&M - 1ST SW CORNER P18 90 m s COMPRESSEDGASSTOR P08 92 m E FENCE-L SCREENHOUSE P03 100 m NW FENCE-EXEC.BUILDING P17 107 m w O&M - 2ND S WALL P23 121 m ENE FENCE-INTAKE BAY P07 121 m SSE FENCE-WAREHOUSE P26 134 m ESE FENC E-SHOREFRONT P02 135 m NW FENCE-W BOAT RAMP P09 136 m E O&M - 2ND N WALL P22 137 m SE FENCE-W SWITCHYARD P16 172 m SW FENCE-TCF GATE P11 183 m ESE FENCE-TCF/BOAT RAMP P27 185 m ESE FENCE-ACCESS GATE P12 202 m SE FENCE-E SWITCHYARD P15 220 m s FENCE-TCF/INTAKE BAY P10 223 m E FENCE-MEDICAL BLDG . P13 224 m SSE FENCE-BUTLER BLDG P14 228 m s FENCE-TCF/PRKNG LOT P28 259 m ESE

• Distance and direction are measured from centerline of Reactor Building to the monitoring location .

Page 53 53

Figure 2.2-1 (continued)

Environmental TLD Locations Within the PNPS Protected Area Page 54 54

Figure 2.2-2 TLD and Air Sampling Locations: Within 1 Kilometer

...................... .................... TLD Station

.............. Location*

.................................................. .... ..........................Air.Sampling _Station Locatio n*

Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs: 0-3 km BOAT LAUNCH WEST BLW 0.11 km E OVERLOOK AREA OA 0.15 km w OVERLOOK AREA OA 0.15 km w PEDESTRIAN BR IDGE PB 0.21 km N HEALTH CLUB TC 0.15 km WSW MEDICAL BUILDING ws 0.23 km SSE BOAT LAUNCH EAST BLE 0.16 km ESE EAST BREAKWATER EB 0.44 km ESE PEDESTRIAN BRIDGE PB 0.21 km N PROPERTY LINE PL 0.54 km NNW ISFSI DOSE #3 ISF-3 0.21 km w W ROCKY HILL ROAD WR 0.83 km WNW SHOREFRONTSECURITY P01 0.22 km NNW E ROCKY HILL ROAD ER 0.89 km SE MEDICAL BUILDING ws 0.23 km SSE ISFSI DOSE #2 ISF-2 0.29 km w PARKING LOT CT 0.31 km SE ISFSI DOSE #1 ISF-1 0.35 km SW SHOREFRONT PARKING PA 0.35 km NNW STATION A A 0.37 km WSW STATION F F 0.43 km NW STAT ION B B 0.44 km s EAST BREAKWATER EB 0.44 km ESE PNPS MET TOWER PMT 0.44 km WNW STATION H H 0.47 km SW STATION I I 0.48 km WNW STATION L L 0.50 km ESE STATION G G 0.53 km w STATION D D 0.54 km NW PROPERTY LINE PL 0.54 km NNW STATION C C 0.57 km ESE HALL'S BOG HB 0.63 km SE GREENWOOD HOUSE GH 0.65 km ESE W ROCKY HILL ROAD WR 0.83 km WNW E ROCKY HILL ROAD ER 0.89 km SE Page 55 55

Figure 2.2-2 (continued)

TLD and Air Sampling Locations: Within 1 Kilometer Page 56 56

Figure 2.2-3 TLD and Air Sampling Locations: 1 to 5 Kilometers TLD Station Location* Air SamplinQ Station Location

• Description Code Distance/Direction Description Code Distance/Direction Zone 1 TLDs : 0-3 km MICROWAVE TOWER MT 1.03 km SSW CLEFT ROCK CR 1.27 km SSW CLEFT ROCK CR 1.27 km SSW MANOMET SUBSTATION MS 3.60 km SSE BAYSHORE/GATE RD BO 1.34 km WNW MANOMET ROAD MR 1.38 km s DIRT ROAD DR 1.48 km SW EMERSON ROAD EM 1.53 km SSE EMERSO N/PRISCILLA EP 1.55 km SE EDISON ACCESS ROAD AR 1.59 km SSE BAYSHORE BS 1.76 km w STATION E E 1.86 km s JOHN GAULEY JG 1.99 km w STATION J J 2.04 km SSE WHITEHORSE ROAD WH 2.09 km SSE PLYMOUTH YMCA RC 2.09 km WSW STATION K K 2.17 km s TAYLOR/THOMAS TT 2.26 km SE YANKEE VILLAGE YV 2.28 km WSW GOODWIN PROPERTY GN 2.38 km SW RIGHT OF WAY RW 2.83 km s TAYLOR/PEARL TP 2.98 km SE Zone 2 TLDs : 3-8 km VALLEY ROAD VR 3.26 km SSW MANOMET ELEM ME 3.29 km SE WARREN/CLIFFORD WC 3.31 km w RT.3A/BARTLETT RD BB 3.33 km SSE MANOMET POINT MP 3.57 km SE MANOMET SUBSTATION MS 3.60 km SSE BEACHWOOD ROAD BW 3.93 km SE PINES ESTATE PT 4.44 km SSW EARL ROAD EA 4.60 km SSE S PLYMOUTH SUBST SP 4.62 km w ROUTE 3 OVERPASS RP 4.81 km SW RUSSELL MILLS RD RM 4.85 km WSW

• Distance and direction are measured from centerline of Reactor Building to the monitoring location .

I Page 57 57

Figure 2.2-3 (continued)

TLD and Air Sampling Locations: 1 to 5 Kilometers Page 58 58

Figure 2.2-4 TLD and Air Sampling Locations: 5 to 25 Kilometers TLD Station Location* Air Samplinq Station Location*

Description Code Distance/Direction Description Code Distance/Direction Zone 2 TLDs: 3-8 km HILLDALE ROAD HD 5.18 km w PLYMOUTH CENTER PC 6.69 km W MANOMET BEACH MB 5.43 km SSE BEAVER DAM ROAD BR 5.52 km s PLYMOUTH CENTER PC 6.69 km w LONG POND/DREW RD LD 6.97 km WSW HYANNIS ROAD HR 7.33 km SSE MEMOR IAL HALL MH 7.58 km WNW SAQUISH NECK SN 7.58 km NNW COLLEGE POND CP 7.59 km SW Zone 3 TLDs: 8-15 km DEEP WATER POND DW 8.59 km w LONG POND ROAD LP 8.88 km SSW NORTH PLYMOUTH NP 9.38 km WNW STANDISH SHORES ss 10.39 km NW ELLISVILLE ROAD EL 11 .52 km SSE UP COLLEGE POND RD UC 11 .78 km SW SACRED HEART SH 12.92 km w KING CAESAR ROAD KC 13.11 km NNW BOURNE ROAD BE 13.37 km s SHERMAN AIRPORT SA 13.43 km WSW Zone 4 TLDs : >15 km CEDARVILLE SUBST cs 15.93 km s KINGSTON SUBST KS 16.15 km WNW LANDING ROAD LR 16.46 km NNW CHURCH/WEST cw 16.56 km NW MAIN/MEADOW MM 17.02 km WSW DIV MARINE FISH DMF 20.97 km SSE

• Distance and direction are measured from centerline of Reactor Building to the monitoring location .

Page 59 59

Figure 2.2-4 ( continued)

TLD and Air Sam pling Locations: 5 to 25 Kilometers J

ft~

Page 60 60

Figure 2.2-5 Terrestrial and Aquatic Sampling Locations Description Code Distance/Direction* Description Code Distance/Direction*

FORAGE SURFACE WATER Plymouth County Farm CF 5.6 km w Discharge Canal DIS 0.2 km N Bridgewater Control BF 31 km w Bartlett Pond BP 2.7 km SE Hanson Farm Control HN 34 km w Powder Point Control pp 13 km NNW SEDIMENT Discharge Canal Outfall DIS 0.8 km NE Plymouth Beach PLB 4.0 km w Manomet Point MP 3.3 km ESE VEGETABLESNEGETATION Plymouth Harbor PLY-H 4.1 km w Site Boundary C BC 0.5 km SW Duxbury Bay Control DUX-BAY 14 km NNW Site Boundary B BB 0.5 km ESE Green Harbor Control GH 16 km NNW Rocky Hill Road RH 0.9 km SE Site Boundary D Bd 1.1 km s IRISH MOSS Site Boundary A BA 1.5 km SSW Discharge Canal Outfall DIS 0.7 km NNE Clay Hill Road CH 1.6 km w Manomet Point MP 4.0 km ESE Brook Road BK 2.9 km SSE Ellisville EL 12 km SSE Beaver Dam Road BD 3.4 km s Brant Rock Control BK 18 km NNW Plymouth County Farm CF 5.6 km w Hanson Farm Control HN 34 km w SHELLFISH Norton Control NC 50 km w Discharge Canal Outfall DIS 0.7 km NNE Plymouth Harbor PLY-H 4.1 km w CRANBERRIES Manomet Point MP 4.0 km ESE Bartlett Road Bog BT 4.3 km SSE Duxbury Bay Control DUX-BAY 13 km NNW Beaverdam Road Bog MR 3.4 km s Powder Point Control pp 13 km NNW Hollow Farm Bog Control HF 16 km WNW Green Harbor Control GH 16 km NNW LOBSTER Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km w Plymouth Harbor PLY-H 6.4 km WNW Duxbury Bay Control DUX-BAY 11 km NNW FISHES Discharge Canal Outfall DIS 0.5 km N Plymouth Beach PLB 4.0 km w Jones River Control JR 13 km WNW Cape Cod Bay Control CC-BAY 24 km ESE N River-Hanover Control NR 24 km NNW Cataumet Control CA 32 km SSW Provincetown Control PT 32 km NE Buzzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 61 61

Figure 2.2-5 (continued)

Terrestrial and Aquatic Samplin Locations

~

\ l4 KILOMETERS NORTH-NORTHWEST SYMBOL KEY 0 ~~EiCUl~ussEL)

(S SOFT-SHELL)

(H HARD-SHELL)

Q IRISH MOSS C3: LOBSTER

~ FISHES

'iJ SURFACE WATER D SEDIMENT 0 CRANBERRY D VEGETATION

-a-@

31 KILOMETERS WEST CAPE COD BAY

-..-§ 34 ¥.JLOMETERS WEST

~

.5Cl KILOMETERS 32 KILOMETERS NORTHEAST

~-

WF.ST 48 KILOMETERS EAST WHITEHORSE BEACH S::-BAY 24 KJLO ETERS CARVER EAST-SOUTHEAST

~

~ 48 KILOMETERS SOUTHWEST

/

<<l KILOMETERS 64 KlLOMETERS 32 KILOMETERS SOUTH-SOUTHWEST SOUTH-SOUTH'NEST e:: ~

I I

~ 48 KILOMETERS

~ SOUTH-SOUTHEAST

\

Page 62 62

Figure 2.2-6 Envi ronme ntal Sampling And Measurement Control Locations Description Code Distance/Direction* Description Code Distance/Direction*

TLD S URFACE WATER Cedarville Substation cs 16 km s Powder Point Control pp 13 km NNW Kingston Substation KS 16 km WNW Landing Road LR 16 km NNW SEDIMENT Church & West Street cw 17 km NW Duxbury Bay Control DUX-BAY 14 km NNW Main & Meadow Street MM 17 km WSW Green Harbor Control GH 16 km NNW Div. Marine Fisheries DMF 21 km SSE East Weymouth Substation EW 40 km NW IRISH MOSS Brant Rock Control BK 18 km NNW AIR SAMPLER East Weymouth Substation EW 40 km NW SHELLFISH Duxbury Bay Control DUX-BAY 13 km NNW FORAGE Powder Point Control pp 13 km NNW Bridgewater Control BF 31 km w Green Harbor Control GH 16 km NNW Hanson Farm Control HN 34 km w LOBSTER VEGETABLESNEGETAT ION Duxbury Bay Control DUX-BAY 11 km NNW Hanson Farm Control HN 34 km w Norton Control NC 50 km w FISHES Jones River Control JR 13 km WNW Cape Cod Bay Control CC-BAY 24 km ESE CRANBERRIES N River-Hanover Control NR 24 km NNW Hollow Farm Bog Control HF 16 km WNW Cataumet Control CA 32 km SSW Provincetown Control PT 32 km NE Buzzards Bay Control BB 40 km SSW Priest Cove Control PC 48 km SW Nantucket Sound Control NS 48 km SSE Atlantic Ocean Control AO 48 km E Vineyard Sound Control MV 64 km SSW

• Distance and direction are measured from the centerline of the reactor to the sampling/monitoring location.

Page 63 63

Figure 2.2-6 (continued)

Environmental Sampling And Measurement Control Locations SYMBOL KEY LJ SHELLFISH (M BLUE MUSSEL)

(S SOFT-SHELL CLAM)

(H HARD-SHELL CLAM) 0 IRISH MOSS D LOBSTER MASSACHUSETTS BAY ex FISHES 0 SURFACE WATER D SEDIMENT 0 CRANBERRY

,/

LJ VEGETATIONIFORAGE D AIR SAMPLER QTLD 0 MILES 10 SCALE

<ff!

CAPECODBAY

~ BAY BUZZARD'S BAY NANTUCKET SOUND Page 64 64

Figure 2.5-1 Airborne Gross-Beta Radioactivity Levels : Near Station Monitors Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2017

~ AP -00 Warehouse ---e- AP-07 Pedestrian Bridge

---

A- AP-08 Overlook Area -*- AP-09 East Breakwater

- - - AP -21 East Weymouth Control Page 65 65

Figure 2.5-2 Airborne Gross-Beta Radioactivity Levels: Property Line Monitors Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2017

~ AP-01 E. Rocky Hill Road - AP-03 W. Rocky Hill Road

-A- AP-06 Property Line - * - AP-21 East Weymouth Control Page 66 66

Figure 2.5-3 Airborne Gross-Beta Radioactivity Levels: Offsite Monitors Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month - 2017

~ AP-10 Cleft Rock ---a- AP -15 Plymouth Center

-A- AP -17 Manomet Substation -e-- AP-21 East W eymouth Control

- Refer to REMP sample exclusions located on page 84 for details describi ng Cleft Rock high result for sample 3/13- 3/21/17.

Page 67 67

3.0

SUMMARY

OF RADIOLOGICAL IMPACT ON HUMANS The radiological impact to humans from the Pilgrim Station's radioactive liquid and gaseous releases has been estimated using two methods:

• calculations based on measurements of plant effluents; and

• calculations based on measurements of environmental samples.

The first method utilizes data from the radioactive effluents (measured at the point of release) together with conservative models that calculate the dispersion and transport of radioactivity through the environment to humans (Reference 7) . The second method is based on actual measurements of radioactivity in the environmental samples and on dose conversion factors recommended by the Nuclear Regulatory Comm ission . The measured types and quantities of radioactive liquid and gaseous effluents released from Pilgrim Station during 2017 were reported to the Nuclear Regulatory Commission , copies of which are provided in Appendix B. The measured levels of radioactivity in the en vironmental samples that required dose calculations are listed in Appendix A.

The maximum individual dose from liquid effluents was calculated using the following radiation exposure pathways :

• shoreline external radiation during fishing and recreation at the Pilgrim Station Shorefront;

• external radiation from the ocean during boating and swimming ; and

• ingestion of fish and shellfish .

For gaseous effluents , the maximum individual dose was calculated using the following radiation exposure pathways :

• external radiation from cloud shine and submersion in gaseous effluents ;

• inhalation of airborne radioactivity;

• external radiation from soi l deposition ;

• consumption of vegetables ; and

• consumption of milk and meat.

The results from the dose calculations based on PNPS operations are presented in Table 3.0-1 . The dose assessment data presented were taken from the "Radioactive Effluent Release Report" for the period of January 1 through December 31 , 2017 (Reference 17).

Page 68 68

Table 3.0-1 Radiation Doses from 2017 Pilgrim Station Operations Maximum Individual Dose From Exposure Pathway - mrem/yr Gaseous Liquid Ambient Receptor Effluents* Effluents Radiation** Total Total Body 0.015 0.000000062 0.69 0.71 Thyroid 0.015 0.000000036 0.69 0.71 Max. Organ 0.071 0.00000011 0.69 0.76

• Gaseous effluent exposure pathway includes combined dose from particulates , iodines and tritium in addition to noble gases, calculated at the nearest residence or receptor location yielding the highest projected dose from all exposure pathways.

• • Ambient radiation dose for the hypothetical maximum-exposed individual at a location beyond the PNPS owner-controlled area yielding highest ambient radiation exposure value as measured with TLDs .

Two federal agencies establish dose limits to protect the public from radiation and radioactivity. The Nuclear Regulatory Commission (NRC) specifies a whole body dose limit of 100 mrem/yr to be received by the maximum exposed member of the general public . This limit is set forth in Section 1301 , Part 20 , Title 10, of the U.S. Code of Federal Regulations (1 OCFR20). By comparison , the Environmental Protection Agency (EPA) limits the annual whole body dose to 25 mrem/yr, which is specified in Section 10, Part 190, Title 40 , of the Code of Federa l Regulations (40CFR190) .

Another useful "gauge" of radiation exposure is provided by the amount of dose a typical individual receives each year from natural and man-made sources of radiation . Such radiation doses are summarized in Table 1.2-1 . The typical American receives approximately 620 mrem/yr from such sources .

As can be seen from the doses resulting from Pilgrim Station Operations during 2017 , all values are well within the federal limits specified by the NRC and EPA. In addition , the calculated doses from PNPS operation represent only a fraction of a percent of doses from natural and man-made radiation .

In conclusion , the radiological impact of Pilgrim Station operations, whether based on actual environmental measurements or calculations made from effluent releases, would yield doses well within any federal dose limits set by the NRC or EPA. Such doses represent only a small percentage of the typica l annual dose received from natural and man-made sources of radiation .

Page 69 69

4.0 REFERENCES

1) United States of America , Code of Federal Regulations , Title 10, Part 50 , Appendix A Criteria 64.

2) Donald T. Oakley, "Natural Radiation Exposure in the United States ." U. S. Environmental Protection Agency , ORP/SID 72-1 , June 1972 .

3) National Council on Radiation Protection and Measurements, Report No . 93, "Ionizing Radiation Exposures of the Population of the United States," September 1987.

4) United States Nuclear Regulatory Commission , Regulatory Guide 8.29, "Instructions Concerning Risks from Occupational Radiation Exposure," Revision 0, July 1981 .

5) Boston Edison Company , "Pilgrim Station" Public Information Brochure 1QOM , WNTHP ,

September 1989.

6) United States Nuclear Regulatory Commission , Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50 , Appendix I," Revision 1, October 1977.

7) Pilgrim Nuclear Power Station Offsite Dose Calculation Manual , Revision 9, June 2003 .

8) United States of America , Code of Federal Regulations , Title 10, Part 20.1301 .

9) United States of America , Code of Federal Regulations , Title 10, Part 50 , Appendix I.

10) United States of America , Code of Federal Regulations , Title 40 , Part 190.

11) United States Nuclear Regulatory Commission , Regulatory Gu ide 4.1, "Program for Monitoring Radioactivity in the Environs of Nuclear Power Plants ," Revision 1, April 1975.

12) ICN/Tracerlab , "Pilgrim Nuclear Power Station Pre-operational Environmental Radiation Survey Program , Quarterly Reports ," August 1968 to June 1972.

13) International Commission of Radiological Protection , Publication No . 43 , "Principles of Monitoring for the Rad iation Protection of the Population ," May 1984.

14) United States Nuclear Regulatory Commission , NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," April 1991 .

15) United States Nuclear Regulatory Commission , Branch Technical Position , "An Acceptable Radiological Environmental Monitoring Program ," Revision 1, November 1979.

16) Settlement Agreement Between Massachusetts Wildlife Federation and Boston Edison Company Relating to Offsite Radiological Monitoring - June 9, 1977.

17) Pilgrim Nuclear Power Station , "Annual Radioactive Effluent Release Report", May 2017.

Page 70 70

APPENDIX A SPECIAL STUDIES There were no environmental samples collected during 2017 that contained plant-related radioactivity .

Therefore, no special studies were required to estimate dose from plant-related radioactivity.

Page 71 71

APPENDIX B Effluent Release Information TABLE TITLE PAGE B.1 Supplemental Information 73 B.2-A Gaseous Effluents Summation of All Releases 74 B.2-B Gaseous Effluents - Elevated Releases 75 B.2-C Gaseous Effluents - Ground Level Releases 77 B.3-A Liquid Effluents Summation of All Releases 79 B.3-B Liquid Effluents 80 Page 72 72

Table B.1 Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Supplemental Information January-December 2017 FACILITY: PILGRIM NUCLEAR POWER STATION LICENSE: DPR-35

1. REGULATORY LIMITS

a. Fission and activation gases: 500 mrem/yr total body and 3000 mrem/yr for skin at site boundary b,c. Iodines, particulates with half-life: 1500 mrem/yr to any organ at site boundary

>8 days, tritium

d. Liquid effluents: 0.06 mrem/month for whole body and 0.2 mrem/month for any organ (without radwaste treatment)

2. EFFLUENT CONCENTRATION LIMITS

a. Fission and activation gases: 10CFR20 Appendix B Table II

b. Iodines: 10CFR20 Appendix B Table II C. Particulates with half-life > 8 days: 10CFR20 Appendix B Table II

d. Liquid effluents: 2E-04 ~tCi/mL for entrained noble gases; 10CFR20 Appendix B Table II values for all other radionuclides

3. AVERAGE ENERGY Not Applicable

4. MEASUREMENTS AND APPROXIMATIONS OF TOTAL RADIOACTIVITY

a. Fission and activation qases: High purity germanium gamma spectroscopy for all

b. Iodines: gamma emitters; radiochemistry analysis for H-3, C. Particulates: Fe-55 (liquid effluents) , Sr-89 , and Sr-90

d. Liquid effluents:

5. BATCH RELEASES Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec 2017 2017 2017 2017 2017

a. Liquid Effluents

1. Total number of releases: 1.00E+OO 1.00E+OO NIA NIA 2.00E+OO

2. Total time period (minutes): 9.30E+ 02 8.90E+02 NIA NIA 1.82E+ 03

3. Maximum time period (minutes): 9.30E+ 02 8.90E+02 NIA NIA 9.30E+02

4. Averaqe time period (minutes) : 9.30E+02 8.90E+02 NIA NIA 9.10E+02

5. Minimum time period (minutes) : 9.30E+ 02 8.90E+02 NIA NIA 8.90E+02

6. Average stream flow during periods of release of 1.18E+06 6.81 E+04 NIA N/A 6.26E+05 effluents into a flowing stream (Liters/min):

b. Gaseous Effluents None None None None None

6. ABNORMALRELEASES

a. Liquid Effluents None None None None None

b. Gaseous Effluents None None None None None Page 73 73

Table B.2-A Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Summation of All Releases January-December 2017 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2017 2017 2017 2017 2017 Error A. FISSION AND ACTIVATION GASES Total Release: Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Average Release Rate: µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO +/-22%

Percent of Effluent Control Limit* * * * *

• B. IODINE-131 Total lodine-131 Release: Ci 1.25E-04 6.51 E-05 4.30E-05 2.86E-05 2.6.2E-04 Averar:ie Release Rate: µCi/sec 1.59E-05 8.25E-06 5.45E-06 3.63E-06 8.30E-06 +/-20%

Percent of Effluent Control Limit* * * * *

• C. PARTICULATES WITH HALF-LIVES> 8 DAYS Total Release: Ci 2.62E-04 4.07E-04 1.38E-05 O.OOE+OO 6.83E-04 Averaqe Release Rate: LtCi/sec 3.33E-05 5.16E-05 1.75E-06 O.OOE+OO 2.17E-05

+/-21%

Percent of Effluent Control Limit* * * * *

• Gross Alpha Rad ioactivity: Ci NOA NOA NOA NOA NOA D. TRITIUM Total Release: Ci 1.68E+01 7.57E+OO 1.18E+01 1.19E+01 4.81 E+01 Averar:ie Release Rate: LtCi/sec 2.13E+OO 9.60E-01 1.50E+OO 1.51 E+OO 1.53E+OO +/-20%

Percent of Effluent Control Limit* * * * *

• E. CARBON-14 Total Release: Ci 1.95E+OO 1.06E+OO 2.10E+OO 2.10E+OO 7.22E+OO Averar:ie Release Rate: LtCi/sec 2.48E-01 1.34E-01 2.66E-01 2.67E-01 2.29E-01 NIA Percent of Effluent Control Limit* * * * *

• Notes for Table B.2-A:

• Percent of Effluent Control Limit values based on dose assessments are provided in Section 6 of this report .

1. NOA stands for No Detectable Activity .

2. LLD for airborne gross alpha activity listed as NOA is 1E-11 ~tCi/cc.

3. N/A stands for not applicable.

Page 74 74

Table B.2-B Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2017 CONTINUOUS MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION GASES: Ci Ar-41 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-85 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE +OO O.OOE+OO Kr-85m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-87 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-88 O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-131m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-133m O.OOE+OO O.OOE+ OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-135 O.OOE +OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-135m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-137 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-138 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Total for Period O.OO E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

2. IODINES: Ci 1-131 5.81 E-07 3.07E-07 O.OOE+OO 4 .84E-07 1.37E-06 1-133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Total for Period 5.81 E-07 3.07E-07 O.OOE+OO 4 .84E-07 1.37E-06

3. PARTICULATES WITH HALF-LIVES> 8 DA VS: Ci Cr-51 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Mn-54 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Fe-59 O.OOE+OO O.OOE+O O O.OOE+OO O.OOE+OO O.OOE+OO Co-58 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE +O O O.OOE+OO Co-60 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO Zn-65 O.OOE+OO O.OOE +OO O.OOE+OO O.OOE+OO O.OOE+OO Sr-89 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE +OO O.OOE+OO Sr-90 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Ru-103 O.OOE+OO O.OOE+OO O.OOE +OO O.OOE+OO O.OOE+OO Cs-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE +OO Cs-137 O.OOE+OO O.OO E+OO O.OOE+OO O.OOE+OO O.OOE+OO Ba/La-140 O.OOE+ OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Total for Period O.OOE+OO O.OOE+OO O.OOE+OO O.OOE +OO O.OOE+OO

4. TRITIUM: Ci H-3 3.25E-02 1.61 E-02 4 .58E-02 4.72E-02 1.42E-01

5. CARBON-14: Ci C-14 1.90E+OO 1.03E+OO 2.04E+OO 2.04E+OO 7.00E+OO Notes for Table B.2-B:

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity.

3. LLOs for airborne radionuclides listed as NOA are as follows:

Fission Gases: 1E-04 µCi/cc Iodines: 1E-12 µCi/cc Particulates: 1E-11 µCi/cc Page 75 75

Table 8 .2-8 (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Elevated Release January-December 2017 BATCH MODE RELEASES FROM ELEVATED RELEASE POINT Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION GASES: Ci Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A N/A N/A N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A N/A Kr-88 N/A N/A N/A N/A N/A Xe-131m N/A N/A N/A N/A NIA Xe-133 N/A N/A N/A N/A N/A Xe-133m N/A N/A N/A N/A N/A Xe-135 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A N/A N/A Xe-137 N/A N/A N/A N/A N/A Xe-138 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A NIA 1-133 NIA N/A N/A N/A NIA Total for period N/A N/A N/A N/A N/A

3. PARTICULATES WITH HALF-LIVES> 8 DAYS: Ci Cr-51 N/A N/A N/A N/A N/A Mn-54 NIA N/A N/A N/A N/A Fe-59 N/A N/A N/A NIA N/A Co-58 N/A N/A N/A N/A N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Sr-89 N/A N/A N/A N/A NIA Sr-90 N/A N/A N/A N/A N/A Ru-103 N/A N/A NIA N/A N/A Cs-134 N/A N/A N/A N/A N/A Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A N/A N/A N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A N/A

5. CARBON-14: Ci C-14 N/A NIA N/A NIA N/A Notes for Table B.2-B:

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity .

3. LLDs for airborne radionuclides listed as NOA are as follows:

Fission Gases: 1E-04 µCi/cc Iodines: 1E-12 µCi/cc Particulates: 1E-11 µCi/cc Page 76 76

Table B.2-C Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2017 CONTINUOUS MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION GASES: Ci Ar-41 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-85 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-85m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-87 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Kr-88 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-1 31m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-133m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-135 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-135m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-137 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Xe-138 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Total for period O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

2. IODINES: Ci 1-131 1.25E-04 6.48E-05 4 .30E-05 2 .81E-05 2 .60E-04 1-133 6 .86E-04 2 .12E-04 1.90E-04 2 .34E-04 1.32E-03 Total for period 8.11E-04 2.77E-04 2.33E-04 2.62E-04 1.58E-03

3. PARTICULATES WITH HALF-LIVES> 8 DAYS : Ci Cr-51 O.OOE+OO 7.10E-05 O.OOE+OO O.OOE+OO 7.10E-05 Mn-54 9.33E-05 1.24E-04 O.OOE+OO O.OOE+OO 2.17E-04 Fe-59 O.OOE+OO 1.22E-05 O.OOE+OO O.OOE+OO 1.22E-05 Co-58 1.13E-05 9.83E-06 O.OOE+OO O.OOE+OO 2.11 E-05 Co-60 6.54E-05 8.64E-05 O.OOE+OO O.OOE+OO 1.52E-04 Zn-65 5.19E-05 8.16E-05 O.OOE+OO O.OOE+OO 1.33E-04 Sr-89 1.65E-05 2.24E-05 1.38E-05 O.OOE+OO 5.28E-05 Sr-90 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Ru-103 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Cs-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Cs-137 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Ba/La-140 2.41E-05 O.OOE+OO O.OOE+OO O.OOE+OO 2.41 E-05 Total for period 2.62E-04 4.07E-04 1.38E-05 O.OOE+OO 6.83E-04

4. TRITIUM: Ci H-3 1.68E+01 7.55E+OO 1.18E+01 1.19E+01 4.80E+01

5. CARBON-14: Ci C-14 5.86E-02 3.24E-02 6.23E-02 6.31 E-02 2.16E-01 Notes for Table B.2-C:

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity .

3. LLDs for airborne radionuclides listed as NOA are as follows:

Fission Gases: 1E-04 µCi/cc Iodines: 1E-12 ~1Ci/cc Particulates: 1E-11 ~1Ci/cc Page 77 77

Table B.2-C (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Gaseous Effluents - Ground-Level Release January-December 2017 BATCH MODE RELEASES FROM GROUND-LEVEL RELEASE POINT Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION GASES: Ci Ar-41 N/A N/A N/A N/A N/A Kr-85 N/A N/A NIA NIA N/A Kr-85m N/A N/A N/A N/A N/A Kr-87 N/A N/A N/A N/A NIA Kr-88 N/A N/A N/A N/A N/A Xe-131m N/A N/A N/A N/A N/A Xe-133 N/A N/A NIA N/A N/A Xe-133m N/A N/A N/A NIA N/A Xe-135 N/A N/A N/A N/A N/A Xe-135m N/A N/A N/A NIA N/A Xe-137 N/A N/A N/A N/A N/A Xe-138 N/A N/A N/A N/A N/A Total for period N/A N/A N/A NIA N/A

2. IODINES: Ci 1-131 N/A N/A N/A N/A N/A 1-133 N/A N/A N/A N/A N/A Total for period N/A N/A N/A NIA N/A

3. PARTICULATES WITH HALF-LIVES > 8 DA VS: Ci Cr-5 1 N/A N/A N/A N/A N/A Mn-54 N/A N/A N/A N/A N/A Fe-59 NIA N/A NIA N/A N/A Co-58 N/A N/A N/A NIA N/A Co-60 N/A N/A N/A N/A N/A Zn-65 N/A N/A N/A N/A N/A Sr-89 N/A N/A NIA N/A N/A Sr-90 N/A N/A N/A N/A N/A Ru-103 N/A N/A N/A N/A N/A Cs-134 N/A N/A N/A N/A NIA Cs-137 N/A N/A N/A N/A N/A Ba/La-140 N/A N/A N/A N/A N/A Total for period N/A NIA N/A N/A N/A

4. TRITIUM: Ci H-3 N/A N/A N/A N/A NIA

5. CARBON-14: Ci C-14 N/A N/A N/A N/A N/A Notes for Table B.2-C:

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity.

3. LLDs for airborne radionuclides listed as NOA are as follows:

Fission Gases: 1E-04 µCi/cc Iodines: 1E-12 µCi/cc Particulates: 1E-11 µCi/cc Page 78 78

Table B.3-A Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents - Summation of All Releases January-December 2017 Est.

RELEASE PERIOD Jan-Mar Apr-Jun Jul-Sep Oct-Dec Jan-Dec Total 2017 2017 2017 2017 2017 Error A. FISSION AND ACTIVATION PRODUCTS Total Release (not including NOA 1.77E-06 N/A N/A 1.77E-06 tritium , Qases, alpha): Ci Average Diluted Concentration NOA 1.68E-14 N/A N/A 3.14E-15 +/-12%

DurinQ Period: µCi/ml Percent of Effluent Concentration O.OOE+OO% 1.68E-06 % N/A N/A 3.14E-07%

Limit*

B. TRITIUM Total Release: Ci 4.18E-4 3.98E-04 N/A N/A 8.16E-04 Average Diluted Concentration 2.83E-12 3.79E-12 N/A NIA 1.45E-12 DurinQ Period : ~tCi/mL +/-9.4%

Percent of Effluent Concentration 2.83E-07% 3.79E-07 % N/A N/A 1.45E-07%

Limit*

C. DISSOLVED AND ENTRAINED GASES Total Release: Ci N/A NOA NOA N/A NOA Average Diluted Concentration NIA NOA NOA N/A NOA DurinQ Period : ~1Ci/ml +/-16%

Percent of Effluent Concentration Limit*

NIA O.OOE+OO% O.OOE+OO% N/A O.OOE+OO %

D. GROSS ALPHA RADIOACTIVITY Total Release: Ci N/A NOA NOA N/A NOA +/-34%

E. VOLUME OF WASTE RELEASED PRIOR TO DILUTION Waste Volume: Liters 3.67E+04 3.29E+04 O.OOE+OO O.OOE+OO 6.95E+04 +/-5.7%

F. VOLUME OF DILUTION WATER USED DURING PERIOD Dilution Volume: Liters 1.48E+11 1.05E+11 1.55E+11 1.55E+11 5.63E+11 +/-10%

Notes for Table B.3-A:

• Additional percent of Effluent Control Limit values based on dose assessments are provided in Section 6 of this report.

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity.

3. LLD for dissolved and entrained gases listed as NOA is 1E-05 µCi/ml.

4. LLD for liquid gross alpha activity listed as NOA is 1E-07 µCi/ml.

Page 79 79

Table 8.3-B Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents January-December 2017 CONTINUOUS MODE RELEASES Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION PRODUCTS: Ci Cr-51 NIA NIA NIA NIA NIA Mn-54 NIA NIA NIA NIA NIA Fe-55 NIA NIA NIA NIA NIA Fe-59 NIA NIA NIA NIA NIA Co-58 NIA NIA NIA NIA NIA Co-60 NIA NIA NIA NIA NIA Zn-65 NIA NIA NIA NIA NIA Zn-69m NIA NIA NIA NIA NIA Sr-89 NIA NIA NIA NIA NIA Sr-90 NIA NIA NIA NIA NIA ZrlNb-95 NIA NIA NIA NIA NIA Mo/Tc-99 NIA NIA NIA NIA NIA Ag-110m NIA NIA NIA NIA NIA Sb-124 NIA NIA NIA NIA NIA 1-1 31 NIA NIA NIA NIA NIA 1-133 NIA NIA NIA NIA NIA Cs-134 NIA NIA NIA NIA NIA Cs-137 NIA NIA NIA NIA NIA BalLa-140 NIA NIA NIA NIA NIA Ce-141 NIA NIA NIA NIA NIA Total for period NIA NIA NIA NIA NIA

2. DISSOLVED AND ENTRAINED GASES: Ci Xe-133 NIA NIA NIA NIA NIA Xe-135 NIA NIA NIA NIA NIA Total for period NIA NIA NIA NIA NIA Notes for Table 8 .3-B:

1. NIA stands for not applicable.

2. NOA stands for No Detectable Activity.

3. llDs for liquid radionuclides listed as NOA are as follows:

Strontium : 5E-08 ~1Ci/ml Iodines: 1E-06 ~1Ci/ml Noble Gases: 1E-05 µCi/ml All Others: 5E-07 µCi/ml Page 80 80

Table B.3-B (continued)

Pilgrim Nuclear Power Station Annual Radioactive Effluent Release Report Liquid Effluents January-December 2017 BATCH MODE RELEASES Nuclide Released Jan-Mar 2017 Apr-Jun 2017 Jul-Sep 2017 Oct-Dec 2017 Jan-Dec 2017

1. FISSION AND ACTIVATION PRODUCTS: Ci Na-24 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Cr-51 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Mn-54 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Fe-55 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Fe-59 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Co-58 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Co-60 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Zn-65 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Zn-69m O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Sr-89 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Sr-90 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO ZrlNb-95 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Mo/Tc-99 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Aq-11 0m O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Sb-124 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO 1-131 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO 1-133 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Cs-134 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Cs-137 O.OOE+OO 1.77E-06 NIA NIA 1.77E-06 Bal la-140 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Ce-141 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Ce-144 O.OOE+OO O.OOE+OO NIA NIA O.OOE+OO Total for period O.OOE+OO 1.77E-06 NIA NIA 1.77E-06

2. DISSOLVED AND ENTRAINED GASES: Ci Xe-133 NOA NOA NIA NIA NOA Xe-135 NOA NOA NIA NIA NOA Total for period NOA NOA NIA NIA NOA Notes for Table B.3-B:

1. N/A stands for not applicable.

2. NOA stands for No Detectable Activity.

3. LLDs for liquid radionuclides listed as NOA are as follows:

Strontium: 5E-08 ~tCi/mL Iodines: 1E-06 ~tCi/mL Noble Gases: 1E-05 ~tCi/mL All Others: 5E-07 ~tCi/mL Page 81 81

APPENDIX C LAND USE CENSUS RESULTS The annual land use census for gardens and milk and meat animals in the vicinity of Pilgrim Station was performed between August 30 and November 8 2017. The census was conducted by driving along each improved road/street in the Plymouth area within 5 kilometers (3 miles) of Pilgrim Station to survey for visible gardens with an area of greater than 500 square feet. In compass sectors where no gardens were identified within 5 km (SSW, WNW, NW, and NNW sectors) , the survey was extended to 8 km (5 mi) . A total of 21 gardens were identified in the vicinity of Pilgrim Station . In addition , the Town of Plymouth Animal Inspector was contacted for information regarding milk and meat animals.

Atmospheric deposition (D/Q) values at the locations of the identified gardens were compared to those for the existing sampling program locations. These comparisons enabled PNPS personnel to ascertain the best locations for monitoring for releases of airborne rad ionuclides . Samples of naturally-growing vegetation were collected at the site boundary in the ESE and SE sectors to monitor for atmospheric deposition in the vicinity of the nearest resident in the SE sector.

In addition to these special sampling locations identified and sampled in conjunction with the 2017 land use census , samples were also collected from control locations in Bridgewater (31 km W)and Sandwich (21 km SSE) .

Samples of naturally-growing vegetation were also collected in the vicinity of the site boundary locations yielding the highest deposition (D/Q) factors for each of the two release points . These locations, and their distance and direction relative to the PNPS Reactor Building , are as follows :

Highest Main Stack D/Q : 1.2 km SSW Hi~hest Reactor Building Vent D/Q: 0.6 km SE 2n highest D/Q , both release points : 1.1 km S No new milk or meat animals were identified during the land use census . In addition , the Town of Plymouth Animal Inspector stated that their office is not aware of any animals at locations other than the Plimoth Plantation . Although milk sampling is not performed at Plimoth Plantation , effluent dose calculations are performed for this location assuming the presence of a milk ingestion pathway, as part of the Annual Radioactive Effluent Release Report (Reference 17).

Page 82 82

APPENDIX D ENVIRONMENTAL MONITORING PROGRAM DISCREPANCIES There were a number of instances during 2017 in which inadvertent issues were encountered in the collection of environmental samples. All of these issues were minor in nature and did not have an adverse effect on the results or integrity of the monitoring program. The PNPS TLD placement still far exceeds that prescribed by NUREG-1302. Details of these various problems are given below.

Within the air sampling program , there were a few instances in which continuous sampling was interrupted at the eleven airborne sampling locations during 2017 . Most of these interruptions were due to short-term power losses and were sporadic and of limited duration (less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> out of the weekly sampling period). Such events did not have any significant impact on the scope and purpose of the sampling program, and lower limits of detection (LLDs) were met for both airborne particulates and iodine-131 on 566 of the 572 filters/cartridges collected .

Out of 572 filters (11 locations

• 52 weeks) , 570 samples were collected and analyzed during 2017. In accordance with ODCM Table 3.5-1 , offsite REMP air particulate filters and charcoal cartridges are to be collected at a weekly interval. Weekly is defined as once every seven days with a one-day grace period before and after the scheduled date. Samples for Week 01 were collected on Wed : 11-Jan-2017, meaning that Week 02 samples should have been collected on or before Thurs :19-Jan.

Sample collection for Week 02 was started early on Mon :16-Jan , due to manpower constraints .

Similarly Week 05 were collected on Mon :6-Feb 2017, meaning that Week 6 samples should have been collected on or before Tue: 14-Feb, but due to inclement weather Week 6 were started past the required time on Wed : 15-Feb. Although two samples were collected earlier than the required weekly due date, all filters were collected and there was no period of time during which sampling/monitoring was not continuous . Again, it must be emphasized that the station continued to sample during the duration and no monitoring time was lost.

The configuration of air samplers that had been in use at Pilgrim Station since the early 1980s, was replaced between June and August of 2012 . Both the pumps and dry gas meters were replaced , and operating experience since changing over to the new configuration has been favorable. Although the occurrence of pump failures and gas meter problems have been largely eliminated , the new configuration is still subject to trips of the ground fault interrupt circuit (GFCI) . Such problems can be encountered at air samplers located at the East Breakwater and Pedestrian Bridge. Both of these locations are immediately adjacent to the shoreline and are subject to significant wind-blown salt water, and are prone to tripping of the GFCI. The following table contains a listing of larger problems encountered with air sampling stations during 2017 , many of which resulted in loss of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the sampling period .

Page 83 83

Location Sampling Sampling Hours Problem Description/Resolution Period Lost CR 03/13 to 03/21 142.2of191 .9 Ground Fault Circuit Interrupt (GFCI) tripped; sample volume 43 .6 cubic meters insufficient to meet LLDs.

CR 03/28 to 04/04 80.3 of 166.8 Ground Fault Circuit Interrupt (GFCI) tripped due to weather conditions; sample volume 134.9 cubic meters insufficient to meet LLDs.

EB 03/28 to 04/04 88.1 of 167.3 Ground Fault Circuit Interrupt (GFCI) tripped due to weather conditions; sample volume 176.1 cubic meters insufficient to meet LLDs.

CR 8/29 to 9/5 No hours lost, Filter was found off center with less particulates than 169.4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> normal for sample point resulting in lower than average sample period results.

PC 10/28 to 11 /01 No hours lost; Due to the town building being vacated , there was no 309.4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> access to change out the air sample station media.

sample period Sample was collected on Tue: 07-Nov-2017. Sampling was continuous during this period , and no hours were lost.

PB 11 / 14 to 11 /21 53 .9 of 169.7 Ground Fault Circuit Interrupt (GFCI ) tripped; sample volume 228 .1 cubic meters.

PC 11 / 14 to 11 /21 162.0 of 164.8 Ground Fault Circuit Interrupt (GFCI) tripped ; sample volume 5.6 cubic meters insufficient to meet LLDs.

PC 11/21 to 11/28 143.3 of 143.3 Gas Meter digits were not advancing , sample was discarded.

Despite the lower-than-normal sampling volumes in the various instances involving power interruptions and equipment failures, required LLDs were met on 566 of the 570 particulate fi lters, and 566 of the 570 of the iodine cartridges collected during 2017 . When viewed collectively during the entire year of 2017 , the following sampling recoveries were achieved in the airborne sampling program :

Location Recovery Location Recovery Location Recovery ws 99 .8% PB 98 .5% PC 98 .1%

ER 100.0% OA 99 .5% MS 99 .9%

WR 99 .5% EB 98.4% EW 99 .9%

PL 100.0% CR 97 .1%

An alternate location had to be found for sampling control vegetable samples in the Bridgewater area .

In past years , samples had been collected at the Bridgewater County Farm , associated with the Bridgewater Correctional Facility . Due to loss of state funding for garden projects during 2006 , no garden was grown. An alternate location was found at the Hanson Farm in Bridgewater, located in the same compass sector, and at approximately the same distance as the Bridgewater County Farm .

Addit ional samples of naturally-occurring vegetation were collected from a distant control location in Sandwich . As expected for control samp les , vegetables and vegetation collected at these locations only contained naturally-occurring radioactivity (Be-7 and K-40) .

Some problems were encountered in collection of crop samples during 2017 . Crops which had normally been sampled in the past (lettuce, tomatoes , potatoes , and onions) were not collected at the Plymouth County Farm (CF) during 2017 . Samples of peppers , tomatoes, cucumbers , broccoli ,

onions , carrots , potatoes , and lettuce were also collected from another locations in the immediate vicinity of Pilgrim Station. No radionuclides attributed to PNPS operations were detected in any of the edible crop samples collected during 2017 .

Naturally-growing leafy vegetation (grass, leaves from trees and bushes , etc.) was collected near some gardens identified during the annual land use census . Due to the unavailability of crops grown Page 84 84

in several of these gardens, these substitute samples were collected as near as practicable to the gardens of interest. No radionuclides attributed to PNPS operations were detected in any of the samples. Additional details regarding the land use census can be found in Appendix C of this report.

The cranberry bog at the control location Pine Street Bog in Halifax was not in production during 2017 , so a sample could not be obtained from this location . A substitute control sample was collected from a bog (Hollow Bog) in Kingston , beyond the influence of Pilgrim Station . In addition , the cranberry bog along Bartlett Road suspended operation during 2016, and was not producing cranberries during 2017 . No samples were collected from any indicator locations.

Additional problems were encountered with composite water samples collected from the Discharge Canal. During the week of 11-Apr to 17-Apr a power supply issue stopped the submersible pump feeding water from the Discharge Canal up to the sampling lab at the Pedestrian Bridge. Therefore ,

water flow to the sampler was interrupted for an unknown portion during the weekly sampling period ,

and the normal sample was replaced with a grab sample collected from the Discharge Canal. No radioactive liquid discharges were occurring during this weekly period .

Group Ill fishes , consisting of alewife, smelt, or striped bass are normally collected once each year in the summer from the vicinity of the Discharge Canal Outfall. A resident population of harbor seals inhabiting the rock breakwater outboard of Pilgrim Station resulted in no sample being collected during 2017 , as the seals would intercept and eat any caught fish before they could be landed .

Repeated and concerted efforts were made to collect these species , but failed to produce any samples.

In summary , the various problems encountered in collecting and analyzing environmental samples during 2017 were relatively minor when viewed in the context of the entire mqnitoring program . These discrepancies were promptly corrected when issue was identified , where possible. None of the discrepancies resulted in an adverse impact on the overall monitoring program.

Page 85 85

APPENDIX E Environmental Dosimetry Company Annual Quality Assurance Status Report 86

ENVIRONMENTAL DOSIMETRY COMPANY ANNUAL QUALITY ASSURANCE STATUS REPORT January - December 2017 Prepared By: Date: 1!1/1P

,,--;(J Approved By: Date: '3[1' (le-I Environmental Dosimetry Company 10 Ashton Lane Sterling, MA 01564 87

TABLE OF CONTENTS Page LIST OF TABLES ...... ................. ........... ... .......... ..... .. ............. .......... ........... ....... .. .. ...... ...... .. ...... iii EXECUTIVE

SUMMARY

..................................... ..... ....... ......... ............ ...................................... iv I. INTRODUCTION .... ... .... .................... ............. ...... ... ..... ... .. .. ... .......................... ... ..... .... .. 1 A. QC Program .. .. ..... ... ..... ..... ............................. .. ... .. .. .. .. ..... ... .. ..... .. .... .................. . 1 B. QA Program .. .............. .... ................................ .... ......... ...... ...... ...... ..... ..... ..... ...... 1 II. PERFORMANCE EVALUATION CRITERIA ...... ...... ... ...... .. ........................... ...... ........... 1 A. Acceptance Criteria for Internal Evaluations .. ... .. .... ........ ......... ... ... ... ...... ..... ... ..... 1 B. QC Investigation Criteria and Result Reporting ... ... ........ .... ..... ....... .... .......... .... ... 3 C. Reporting of Environmental Dosimetry Results to EDC Customers .... ... ... ........... 3 Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2017 ..... .... .... .... 3 A. General Discussion ....... ..... .... ... ....... ............ ..... .. ...... .......... .... ...... .......... ... ....... .. 3 B. Result Trending .... .... ....... .......... ... ........ ........ ...... ...... ...... ...... ........ ........ ..... ... .. .. .. 4 IV. STATUS OF EDC CONDITION REPORTS (CR) ... ........ ...... ....... ............................. .. .... 4 V. STATUS OF AUDI TS/ASSESSMENTS .............. ............... ......... ..... ... ... ..... .... ...... ..... ..... 4 A. Internal ..... ......... ... ........ ............ ..... ...... ........... ... ...... .......... ..... ............ ................. 4 B. External ... ..... ... .. .... ...... ........ ........... ...... ... ........ ......... ........ ..... ....... ...... ...... .. ...... .. 4 VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2017 .. . 4 VII. CONCLUSION AND RECOMMENDATIONS .......... .. .......... .. ... ...... ....... ............... ..... ..... 4 VIII. REFERENCES ..... ... ..... ................ ....................... .... .. ........... .. ... ... ... ........ ....................... 4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS

-ii-88

LIST OF TABLES

1. Percentage of Individual Analyses Which Passed EDC Internal Criteria ,

January - December 2017 5

2. Mean Dosimeter Analyses (n=6) , January - December 2017 5

3. Summary of Independent QC Results for 2017 5

-iii-89

EXECUTIVE

SUMMARY

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

During this annual period100% (72/72) of the individual dosimeters, evaluated against the EDC internal performance acceptance criteria (high-energy photons only) , met the criterion for accuracy and 100% (72/72) met the criterion for precision (Table 1) . In addition , 100% (12/12) of the dosimeter sets evaluated against the internal tolerance limits met EDC acceptance criteria (Table 2) and 100% (6/6) of independent testing passed the performance criteria (Table

3) . Trending graphs, which evaluate performance statistic for high-energy photon irradiations and co-located stations are given in Appendix A.

One internal assessment and one external audit were performed in 2017.There were no findingsidentified .

-iv-90

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

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

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

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

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

II. PERFORMANCE EVALUATION CRITERIA A. Acceptance Criteria for Internal Evaluations

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

( H'. - H)

I I 100 H;

where:

H; = the corresponding reported exposure for the i1h dosimeter (i.e ., the reported exposure)

H; = the exposure delivered to the i1h irradiated dosimeter (i.e., the delivered exposure) 1 of 6 91

- - - - - - - -- ~ ---- -*- -

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

where:

H; = the corresponding reported exposure for the ;th dosimeter (i.e., the reported exposure)

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

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

where:

H; = the reported exposure for the ;th dosimeter (i.e., the reported exposure)

H = the mean reported exposure ; i.e., R= LH;(~)

n = the number of dosimeters in the test group

4. EDC Internal Tolerance Limits All evaluation criteria are taken from the "EDC Quality System Manual ,"

(Reference 2) . These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs-137) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +/-

12.8% for precision .

2 of 6 92

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

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

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

C. Reporting of Environmental Dosimetry Results to EDC Customers

1. All results are to be reported in a timely fashion.

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

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

Ill. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2017 A. General Discussion Results of performance tests conducted are summarized and discussed in the following sections . Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4 .

Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period 100% (72/72) of the individual dosimeters , evaluated against these criteria ,

met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision. A graphical interpretation is provided in Figures 1 and 2.

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

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

3 of 6 93

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

namely: individual dosimeter accuracy, individual dosimeter precision , and mean bias.

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

IV. STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period .

V. STATUS OF AUDITS/ASSESSMENTS

1. Internal EDC Internal Quality Assurance Assessment was conducted during the fourth quarter 2017 . There were no findings identified .

2. External The DTE Energy and NextEra Energy Audit 17-007 was conducted on August 8-9, 2017. There were no findings identified .

VI. PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2017 Two procedures and the Quality System Manual were reissued with no changes as part of the 5 year review cycle .

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

VIII. REFERENCES

1. EDC Quality Control and Audit Assessment Schedule, 2017 .

2. EDC Manual 1, Quality System Manual, Rev. 3, August 1, 2017.

4 of 6 94

TABLE 1 PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 201i 1l, (2)

Number  % Passed Precision Dosimeter Type  % Passed Bias Criteria Tested Criteria Panasonic Environmental 72 100 100 1

( )This table summarizes results of tests conducted by EDC .

2

( )Environmental dosimeter results are free in air.

TABLE 2 MEAN DOSIMETER ANALYSES (N=G)

JANUARY - DECEMBER 2017! 1), (2 )

Standard Tolerance Process Date Exposure Level Mean Bias% Deviation Limit+/-

% 15%

5/01/2017 31 1.0 0.9 Pass 5/08/2017 57 -0.4 1.0 Pass 5/08/2017 85 0.8 2.4 Pass 7/25/2017 36 -2 .5 1.7 Pass 07/29/2017 67 5.5 1.0 Pass 8/8/2017 123 -3 .8 0.9 Pass 10/23/2017 44 3.8 2.8 Pass 10/31/2017 74 1.7 1.2 Pass 11/12/2017 94 0.5 1.0 Pass 2/01/2018 27 2.6 1.4 Pass 2/06/2018 50 3.0 0.6 Pass 2/08/2018 105 0.5 2.0 Pass 1

( )This table summarizes results of tests conducted by EDC for TLDs issued in 2017.

2

( )Environmental dosimeter results are free in air.

TABLE 3

SUMMARY

OF INDEPENDENT DOSIMETER TESTING JANUARY - DECEMBER 2017! 1), !2 l Standard Pass I Fail Issuance Period Client Mean Bias%

Deviation%

1st Qtr. 2017 Millstone 2.9 1.5 Pass 2na Qtr.2017 Millstone 2.8 1.2 Pass 3rd Qtr. 2017 Millstone 1.1 2.7 Pass 4tn Qtr.2017 Millstone -3.5 2.4 Pass 4tn Qtr.2017 Seabrook 8.6 1.6 Pass 1

( )Performance criteria are+/- 30% .

2

( >s1ind spikeirradiations using Cs-137 5 of 6 95

APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2017 6 of 6 96

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