Text

2021 Radiological Environmental Operating Report
	ML22132A110
Person / Time
Site:	Palisades
Issue date:	05/12/2022
From:	Dotson B; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PNP 2022-004
	Download: ML22132A110 (50)
	v • d • e

) entergy PNP 2022-004 May 12, 2022 A TIN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Barbara E. Dotson Manager, Regulatory Assurance Palisades Nuclear Plant 269-764-2265 Technical Specification 5.6.2

Subject:

2021 Radiological Environmental Operating Report Palisades Nuclear Plant Docket 50-255 Renewed Facility License No. DPR-20

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is submitting the enclosed Radiological Environmental Operating Report for the Palisades Nuclear Plant. This report was prepared in accordance with the requirements of Technical Specification 5.6.2. The period covered by the enclosed report is January 1, 2021, through December 31, 2021.

If you have any questions regarding this submittal, please contact Bill Turco, Chemistry Manager, at 269-764-2537.

This letter contains no new commitments and no revision to existing commitments.

Respectfully, BED/ mrp

Enclosure:

Annual Radiological Environmental Operating Report cc:

Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC Entergy Nuclear Operations, Inc., 27780 Blue Star Memorial Hwy, Covert, Ml 49043

ENCLOSURE ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT PNP 2022-004

Plant: Palisades Page 1 of 48 YEAR: 2021 Document Number: 2022-004 Annual Radiological Environmental Operating Report

Plant: Palisades I

Year: 2021 I

Page 2 of 48 Annual Radioloaical Environmental Qperatina Report TABLE OF CONTENTS 1.0 EXECUTIVE

SUMMARY

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

2.0 INTRODUCTION

........................................................................................................................ 4 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS...................... 5 4.0 INTERPRETATION AND TRENDS OF RESULTS................................................................... 13 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

......................... 21 ATTACHMENTS - Sample Deviations....................................................................................................... 27 - Monitoring Results Tables............................................................................................ 29 - lnterlaboratory Comparison Program Results............................................................... 47

1.0

1.1 Plant

Palisades I

Year: 2021 I

Page 3 of 48 Annual Radioloaical Environmental Operatina Report EXECUTIVE

SUMMARY

Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Report presents data obtained through analyses of environmental samples collected for Palisades Radiological Environmental Monitoring Program (REMP) for the period January 1 through December 31, 2021. This report fulfills the requirements of Palisades Technical Specification 5.6.2.

No measurable levels of radiation above baseline levels attributable to Palisades operation were detected in the vicinity of Palisades in 2021. The 2021 REMP thus substantiated the adequacy of source control and effluent monitoring at Palisades with no observed impact of plant operations on the environment.

Palisades established the REMP prior to the station becoming operational to provide data on background radiation and radioactivity normally present in the area.

Palisades has continued to monitor the environment by sampling air, water, sediment, broad leaf vegetation, fish, and food products, as well as measuring direct radiation.

Palisades also samples milk if milk-producing animals used for human consumption are present within five miles (8 km) of the plant. All analyses have required, nuclide specific, lower limit of detections (LLDs) which must be achieved. The requirements of the REMP are formally described in the offsite dose calculation manual (ODCM), a site specific regulatory document.

The REMP includes sampling indicator and control locations. The REMP utilizes indicator locations near the site to show any increases or buildup of radioactivity that might occur due to statie.n operation and control locations farther away from the site to indicate the presence of only naturally occurring radioactivity. Palisades personnel compare indicator results with control and preoperational results to assess any impact Palisades operation might have had on the surrounding environment.

In 2021, REMP samples were collected for radiological analysis. The results of indicator locations were compared with control locations and previous studies. All 2021 REMP results support the conclusion that the surrounding environment is not affected by Palisades' effluents. No activity in any REMP sample from 2021 was attributed to Palisades' effluents.

1.2 Reporting Levels 1.3 No samples equaled or exceeded reporting levels.

Sample Deviations During 2021, environmental sampling was performed for eight media types (airborne, surface water, drinking water, offsite groundwater, sediment, broad leaf vegetation,

. fish, and food products) and analyzed for direct radiation. All REMP samples were obtained as required by the ODCM in 2021 with the exception of 3 instances of sample deviations which are further discussed in Attachment 1 Table 8.

1.4 Program Modifications There were no program modifications during the reporting period.

2.0

2.1 Plant

Palisades I

Year: 2021 I

Page 4 of 48 Annual Radiological Environmental Operating Report INTRODUCTION Radiological Environmental Monitoring Program Palisades established the REMP, as defined in the ODCM, to fulfill 10 CFR Part 50 Appendix I Section IV.B.2. The REMP supplements the radiological effluent monitoring program by verifying that the concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

2.2 Pathways Monitored The airborne, direct radiation, waterborne and ingestion pathways are monitored as required by Palisades ODCM. These requirements are also listed in this report in Table 1 through Table 4.

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

2.3 Land Use Census Palisades conducts a land use census annually to identify changes in uses of land within five miles of the site that would require modifications to the REMP and the ODCM. The purpose of this census is to identify critical receptor pathways for the purpose of effluent modeling and REMP sampling.

Plant: Palisades I

Year: 2021 I

Page 5 of 48 Annual Radiological Environmental Operating Report 3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS Table 1, Exposure Pathway - Airborne Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency RADIOIODINE AND PARTICULATES A8 (0.595 miles NE) - onsite Continuous sampler operation 1-131 analysis weekly for each filter change.

Six samples total. Four samples from within 6 near state park with sample collection every week, Gross beta radioactivity analysis weekly for each or more frequently if required by km (3.7 miles) of the site boundary in different A 19 (0.423 miles SSE) -

dust loading.

filter change.

sectors. One sample from the vicinity of a onsite near Bluestar Hwy Gamma isotopic analysis quarterly for a composite of community having the highest calculated annual average ground level deposition factor.

A9 (1.525 miles SSW) - offsite all filters collected.

One control sample in the least prevalent wind near blue star highway IF filter gross beta is greater than 10 times the yearly direction (considering practical direction and A4 (3.882 miles SE) - offsite in mean of the control sample THEN gamma isotopic is distance).

Covert township performed on the filter.

AS (3.590 miles ESE) - offsite in Covert township A10 (50.765 miles NE)-

offsite near Grand Rapids

Plant: Palisades I

Year: 2021 I

Page 6 of 48 Annual Radiological Environmental QperatinQ Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency TLDS TLD-1 (0.213 miles E) - onsite Quarterly Gamma dose (units of milliRoentgen, abbreviated mR) 23 routine monitoring stations either with two inner ring TLD quarterly

! or more dosimeters or with one instrument for TLD-8 (0.602 miles NE)- inner ring measuring and recording dose rate TLD continuously, placed as follows:

TLD-13 (0.530 miles NNE) - inner One onsite TLD in the vicinity of the plant. An ring TLD inner ring of stations consisting of one in each TLD-14 (0.551 miles NE)- inner overland meteorological sector, one in the general area of the state park camping area in ring TLD the NE sector, and one in the general area of TLD-15 (0.834 miles ENE)- inner the site boundary.

ring TLD An outer ring of stations one in each overland TLD-16 (0.804 miles E)- inner ring meteorological sector within the 12 km range from the site.

TLD Three control stations sufficiently far from the TLD-17 (0.572 miles ESE) - inner plant as to not be affected from the plant.

ring TLD TLD-18 (0.469 miles SE) - inner ring TLD TLD-19 (0.443 miles SSE)- inner ringTLD TLD-20 (0.412 miles S)- inner ring TLD TLD-21 (0.382 miles SSW) - inner ring TLD

Plant: Palisades I

Year: 2021 I

Page 7 of 48 Annual Radiological Environmental Operating Report Table 2, Exposure Pathway - Direct Radiation Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency I

TLD-2 (5.560 miles SE) - outer Quarterly Gamma dose (units of milliRoentgen, abbreviated mR) ring TLD quarterly I

TLD-3 (5.684 miles SSE) - outer I

ringTLD TLD-4 (3.668 miles S) - outer ring J

TLD TLD (3.475 miles ESE) - outer ring TLD TLD (5.314 miles NE) - outer ring TLD TLD-7 (4.115 miles NNE) - outer ring TLD TLD-9 (1.670 miles SSW) - outer ring TLD TLD-23 (3.189 miles ENE) - outer ring TLD TLD-24 (6.021 miles E) - outer ring TLD

\\

I TLD-10 (50.746 miles NE) -

i, control TLD i

TLD-11 (39.472 miles E) - control I

TLD TLD-12 (27.971 miles SSE) -

control TLD k

Plant: Palisades I

Year: 2021 I Page 8 of 48 Annual Radioloaical Environmental Operatina Recort Table 3, Exposure Pathway-Waterborne Requirement Sample Point Description Sampling and Collection Type and Frequency Of Analyses Distance and Direction Frequency SURFACE WATER Lake in - Lake Michigan intake water Daily samples are used to Gamma isotopic, gross beta (not ODCM required), and used in plant systems. Sample is make a monthly composite tritium analysis monthly Lake in (plant intake lake water) collected onsite.

sample.

Daily South Haven drinking Gamma isotopic, gross beta, and tritium analysis monthly DRINKING WATER City of South Haven drinking water water samples are used to make a monthly composite South Haven drinking water intake structure (5.6 miles NNE of sample.

Palisades)

Palisades Park (Pal Park) community drinking Pal Park community drinking water 1 grab sample of Palisades Gamma isotopic, gross beta (not ODCM required), and water is sampled when in operation (summer (0.7 miles SSW of Palisades)

Park (Pal Park) community tritium analysis monthly when operational months) drinking water is sampled Domestic water is sampled onsite from monthly when in operation Domestic water (not ODCM required) is any potable water source, typically an (summer months).

Gamma isotopic, gross beta, and tritium analysis monthly sampled onsite.

eye wash station.

Daily samples are used to make a monthly composite.

Surface Water and Drinking Water Control Daily samples are used to Gamma isotopic, gross beta, and tritium analysis monthly Lake water from Ludington Pump-house is Ludington Control - Lake Michigan make a monthly composite intake water from Ludington Pump-sample.

analyzed as a control sample for drinking and house (201 km North of Palisades).

surface water.

OFFSITE GROUNDWATER 1 grab sample is sampled Gamma isotopic, gross beta, and tritium analysis monthly Palisades Park (Pal Park) commercial water 0.7 miles S of Palisades monthly when in operation is sampled when in operation (summer (summer months) months). This sample is not ODCM required.

SEDIMENT FROM SHORELINE 1 sample between the north site Semiannually Gamma isotopic analysis semiannually.

North sediment sample boundary and Van Buren State Park beach, approximately 1/2 mile north of the plant discharge.

South sediment sample (not ODCM required) 1 sample from beach near south Semiannually Gamma isotopic analysis semiannually.

boundary of site property

Plant: Palisades I

Vear: 2021 I

Page 9 of 48 Annual RadioloQical Environmental Operating Report Table 4, Exposure Pathway-Ingestion Requirement Sample Point Description Distance Sampling and Collection Type and Frequency Of Analyses and Direction Frequency MILK For 2021 goat milk samples were not Monthly Gamma isotopic and 1-131 monthly Samples from milking animals in 3 locations available to be sampled from the indicator locations. Therefore no control samples between 5-8km distance were obtained, and broad leaf vegetation 1 sample from milking animals at a control was sampled as described below.

location.

Broad leaf Vegetation 0.7 miles SE from Palisades.

Monthly during growing Gamma isotopic and 1-131 monthly during growing Samples of three different kinds of broad leaf season season vegetation grown nearest each of two 0.4 miles SSE from Palisades.

different offsite locations of highest predicted annual average ground level deposition and one sample of each of the similar broad leaf 13.6 miles NNE from Palisades.

vegetation grown 15-30 km distance in the least prevalent wind direction IF milk sample is not performed.

FISH The indicator sample is obtained from Lake Semiannually Gamma isotopic analysis semiannually Sample 2 species of commercially and/or Michigan onsite within a few hundred feet of recreationally important species in the vicinity the main liquid discharge point.

of the plant discharge area.

The control sample is obtained from Lake 1 sample of the same species in areas not Michigan near Ludington Ml (201 km North influenced by plant discharge.

of Palisades).

FOOD PRODUCTS (blueberries) 3.7 to 4.7 miles SE or ESE Annually at time of harvest Gamma isotopic and 1-131 annually 1 sample of each of two principal fruit crops from Palisades (blueberries and apples).

(apples) 3.5 to 3.7 miles E or SE from Palisades

Plant: Palisades I

Year: 2021 I Page 10 of 48 Annual Radiological Environmental Operating Report Figure 1, Exposure Pathway NUCLEAR POWER PLANT

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Exposure pathways to man

Plant: Palisades I

Year: 2021 Annual Radiological Environmental Qperatim:a Report Figure 2, Sample Collection Sites -Near Field

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I I Page 11 of 48 I

2 th Ave The locations in Figure 2 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

WNW w

WSW Plant: Palisades I

Vear: 2021 I Page 12 of 48 Annual Radiological Environmental Operating Report Figure 3, Sample Collection Sites - Far Field NW N

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The locations in Figure 3 correspond to the TLD and Air Sampler locations in Table 1 and Table 2.

4.0

4.1 Plant

Palisades I

Year: 2021 I Page 13 of 48 Annual Radiological Environmental Operating Report INTERPRETATION AND TRENDS OF RESULTS Air Particulate and Radioiodine Sample There were 318 air samples collected and analyzed for gross beta and 1-131 during 2021.

Three of the air samples were not used in the analytical results in this report. This is discussed in Attachment 1 Table 8. Air iodine and particulate samples are collected weekly from six air-sampling locations. Air is metered into the sampling unit through a 47-mm air filter (for particulate) and an air iodine cartridge. The filters are in series with one another and housed within the same filter holder. An "as found" and "as left" leak test is performed at each station during each sample collection. Weekly samples were sent to Teledyne Brown Engineering Environmental Services for analysis.

Analysis of the airborne particulate sample data, between the five near-site indicator locations and the control location, indicate no difference between indicator and control locations. The average concentration of gross beta activity among all indicator locations was 2.69E-02 pCi/m3 and was 2.52E-02 pCi/m3 for the control location. All 1-131 activity results, for both indicator and control locations, were below the minimum detectable activity (MDA). Gamma isotopic analysis is performed quarterly on a quarterly composite of the filter papers. All radionuclides detected (Be-7, K-40,) were naturally occurring radionuclides which are not attributed to plant effluents.

Palisades' pre-operational environmental study showed naturally occurring gross beta radiation between 0.03 and 3.0 pCi/m3 with a similar trend between stations onsite, in the surrounding community, and control stations. The activity results from 2021 indicate there is no measurable change between pre-operational airborne gross beta activity and present day airborne gross beta activity.

There was five REMP deviations in 2021 involving air sampling. Two of the deviations involved the as-found leak test at an air sample station. The other three deviations involved a failed air sample station sampling pump. All REMP air sampling pumps are replaced at least once every 2 years to minimize pump failures. These instances are discussed in more detail in Attachment 1 Table 8.

In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. The air sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP air samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I

Year: 2021 I Page 14 of 48 Annual Radiological Environmental Operating Report 4.2 Thermoluminescent Dosimetry (TLD) Sample Results Palisades reports measured dose as net exposure (subtracting transit reading) normalized to 92 days. TLDs are oriented in an inner ring, outer ring, and control locations. The inner ring consists of 11 TLDs, the outer ring consists of 9 TLDs, and there are 3 control locations. This orientation allows for monitoring all 9 overland compass sectors surrounding Palisades. To assess the effect of direct and shine radiation from Palisades to the environment the inner ring, outer ring, and control TLDs are compared to one another. Additionally, each individual TLD location is compared to a baseline of data which was created from a comprehensive review of data from 2011 through 2016. The high and low values for the baseline are based upon two standard deviations for each data point from 2011 through 2016. If a value is measured outside the baseline additional follow-up investigation is performed to evaluate the cause. During 2021 all TLDs trended normal and no TLDs were outside the baseline. This evaluation identified no noticeable trend that would indicate that the ambient radiation levels are being affected by plant operations. Table 5 shows the consistent trend of average inner ring, outer ring, and control TLDs.

TLD measurements taken as part of Palisades' pre-operational environmental study used different instrumentation which had difficulty in achieving desired sensitivity and accuracy. A more sensitive type of TLD was implemented in 1971 and the present day TLD device used is the industry standard. TLD data has trended consistently throughout the several most recent independent spent fuel storage installation (ISFSI) loading campaigns which indicates these loading campaigns have had no measurable effect on the environment.

Activity from TLD measurements in the environment is attributed to naturally occurring background radiation and not from Palisades' direct or shine radiation.

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

Control Location (mR/Qtr)

(mR/Qtr) 2014 9.1 10.9 10.7 2015 9.5 11.2 10.9 T

2016 9.6 11.3 11.2 2017 9.3 11.2 10.9 2018 9.3 11.1 11.0 2019 9.4 11.2 11.0 2020 9.3 11.2 11.1 2021 9.3 11.3 11.1

Plant: Palisades I

Vear: 2021 I Page 15 of 48 Annual Radiological Environmental Operating Report 4.3 Waterborne Sample Results During 2021 Palisades implemented the REMP in accordance with the ODCM for collection of surface, drinking, and groundwater. For all surface, drinking, and groundwater indicator samples, the same control sample is used as a baseline for comparison. That control sample is referred to as the "Ludington Control" and is collected 201 km north of Palisades. The Ludington Control sample is analyzed monthly and is a composite of daily samples. The Ludington Control sample is analyzed for gamma radionuclide, tritium, and gross beta activity. In 2021 the only radionuclide activity detected in Ludington Control water was naturally occurring isotopes (K-40 and Th-228). Of the twelve Ludington Control samples collected in 2021, five contained detectable gross beta with an average value of 3.08 pCi/L. The gross beta activity is a result of naturally occurring radionuclide and is not attributed to Palisades' effluents.

4.3.1 Surface Water The indicator surface water samples collected and analyzed for the REMP include "Lake In" water. This sample is Lake Michigan water after it has traveled through the Palisades' intake structure and traveling screens. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclide and tritium onsite. This sample is also analyzed by Teledyne Brown Engineering Environmental Services for gamma, tritium, and gross beta activity. All radionuclide detected (Th-228) were naturally occurring and are not attributed to Palisades' effluents. Five out of the twelve monthly samples contained measurable gross beta with the average det~ctable gross beta activity at 3.29 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results for surface water showed consistently measurable results for gross beta activity between 11 - 18

(+/- 5) pCi/L.

The surface water sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP surface water samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

4.3.2 Drinking Water The indicator drinking water samples collected and analyzed for the REMP include "Domestic Water", "South Haven Drinking Water", and "Palisades Park Community Water". All samples are analyzed for gamma, tritium, and gross beta by Teledyne Brown Engine~ring Environmental Services.

Plant: Palisades I

Year: 2021 I Page 16 of 48 Annual Radioloaical Environmental Operating Report Domestic Water is collected onsite from a potable water system. This sample is collected daily and composited into a monthly sample which is analyzed for gamma radionuclide and tritium onsite. All radionuclide detected (Ra-226) were naturally occurring and are not attributed to Palisades' effluents. Four out of the twelve monthly samples contained measurable gross beta activity with the average detectable gross beta activity at 2.88 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide. Domestic water is not required by the ODCM for the REMP. This sample is collected as part of the NRC bulletin 80-10 commitments and is included in this report because the data strengthens the REMP.

South Haven Drinking Water is collected from the City of South Haven Water Treatment facility located in South Haven. All radionuclide detected (Th-228 and Ra-226) were naturally occurring and are not attributed to Palisades' effluents. Two out of the twelve monthly samples contained measurable gross beta with the average detectable gross beta activity at 2.51 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades Park Community Water is collected once per month as a grab sample from a community just south of Palisades while the facility is operational (summer months).

This sample is analyzed for gamma, tritium, and gross beta activity. No radionuclide were detected from gamma spectroscopy or tritium analysis. One out of the six monthly samples contained measurable gross beta activity with an activity of 3.05 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide. Gross beta activity is not required by the ODCM for this sample but is performed for trending purposes and to strengthen the REMP.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results relied upon as a baseline for drinking water analysis are the same results as with surface water, that being consistent gross beta activity between 11 - 18 (+/- 5) pCi/L.

The drinking water sample results collected, in accordance with the REMP, support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP drinking water samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I

Vear: 2021 I Page 17 of 48 Annual Radiological Environmental Operating Report 4.3.3 Groundwater Palisades implements an extensive groundwater monitoring program in accordance with NEl-0707, "Industry Ground Water Protection Initiative - Final Guidance Document". This program is designed to identify onsite leaks to groundwater to allow for prompt repair or isolation of the leak. The results of the onsite groundwater program are described in the Annual Radioactive Effluent Release Report {ARERR).

Palisades samples one offsite groundwater location. This sample is not required by Palisades' ODCM but is procedurally implemented to strengthen the program overall.

The REMP groundwater sample is the "Palisades Park Commercial Well Water" sample. This sample is collected once per month as a grab sample from a community just south of Palisades while the facility is operational {summer months).

This sample is analyzed for gamma, tritium, and gross beta activity by Teledyne Brown Engineering Environmental Services. No radionuclide were detected from gamma spectroscopy or tritium analysis. Four out of the Six monthly samples contained measurable gross beta with the average detectable gross beta activity at 4.93 pCi/L. The gross beta activity is attributed to naturally occurring radionuclide.

Palisades' pre-operational environmental study established a baseline of gross beta activity for the site before Palisades was operational. The study results were that five well water samples from Palisades contained gross beta activity above 5 pCi/L with the highest value being 16 pCi/L. Two samples from Covert Park well water contained gross beta activity at 6 and 7 pCi/L.

The groundwater sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP groundwater samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

Plant: Palisades I

Year: 2021 I Page 18 of 48 Annual Radiological Environmental ODerating Report 4.4 Sediment Sample Results Sediment samples are collected two times per year north and south of the plant from the beach on Lake Michigan. One sample is collected at the southern edge of the property and a second sample is collected approximately 0.5 miles north of the plant.

The sample south of the plant is not required by the ODCM but is collected and analyzed to strengthen the REMP. Both the north and south sediment samples are analyzed for gamma radionuclide. In 2021, the only radionuclides detected (K-40, Th-228, Th-232, and Ac-228} were naturally occurring isotopes which are not attributed to Palisades' effluents. In accordance with the ODCM, no control sample is collected for this sample type.

Soil samples were not specifically part of the Palisades' pre-operational environmental study however a study of Cs-137 found in soil (due to global events such as historical atomic testing and fallout} was performed by Palisades in 2011.

Analysis was performed of soil in the surrounding area (Southwest Michigan) which showed Cs-137 concentrations between 1.41 E-08 uCi/g and 5.68E-07 uCi/g with an average of 2.68E-07 uCi/g. Considering similar studies performed by other utilities, a conservative (low} background of 1.BE-07 uCi/g Cs-137 in soil is assumed to be due to global fallout.

The sediment sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP sediment samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

4.5 Ingestion Sample Results 4.5.1 Milk Sample Results Indicator milk samples were not available to be collected during 2021. In accordance with Palisades ODCM, broadleaf sampling is performed when milk sampling is not performed.

Plant: Palisades I

Year: 2021 I Page 19 of 48 Annual Radiological Environmental Operating Report 4.5.2 Broad leaf Sample Results In accordance with Palisades ODCM three different kinds of broad leaf vegetation is sampled from two onsite (indicator) locations and one offsite (control) location due to the fact that milk sampling is not performed. Broad leaf samples are collected once per month during the growing season and analyzed for gamma radionuclides including iodine-131. Naturally occurring radionuclide detected in broad leaf vegetation (Be-7 and K-40) are not attributed to Palisades' effluents. Cs-137 detected in broad leaf vegetation was attributed to historical global atomic testing and biological uptake. Cs-137 was detected at location BV1 (0.4 miles SSE) for four out of the five monthly samples. Cs-137 was detected in BV2 tor one out of five monthly samples. The average concentration of Cs-137 among all indicator locations was 59.8 pCi/kg. Cs-137 was detected in none of the samples from location BVC. It is not abnormal to detect Cs-137 in broad leaf samples. Palisades procedurally implements a conservative administrative action value to perform additional reviews if the activity of broad leaf samples exceeds 146 pCi/kg Cs-137. This administrative action value was developed in 2013 based upon Cs-137 trends in broadleaf samples.

The absence of other more prominent radionuclides measured in the plant effluent and coolant systems further support that the Cs-137 detected in broadleaf is not a result of Palisades activity.

The pre-operational environmental study consisted in part of Cs-137 and Sr-90 analysis for crops and milk. These (and broadleaf) sample results are a result of historical global atomic testing and biological uptake. The pre-operational study identified Cs-137 in milk samples ranging from 2 to 70 pCi/L and Sr-90 ranging from 5 to 15 pCi/L. For crop samples, gross gamma activity was generally between 0.11 and 0.22 pCi/g and gross beta activity was generally between 0.72 to 3.31 pCi/g.

The broad leaf sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP broadleaf samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

4.5.3 Fish Sample Results Indicator and Control fish samples are collected and analyzed twice per year. The filet of the fish is analyzed for gamma radionuclide. The indicator fish are collected near Palisades lake-out discharge point. At least 2 species of commercial or recreational importance are collected and analyzed. At least one sample of the same species is collected as a control sample. The control fish are collected 201 km north of Palisades near Ludington, Ml. In 2021, the only radionuclides detected among all fish samples were naturally occurring radionuclides (K-40) which were not attributed to Palisades' effluents.

Palisades' pre-operational environmental study established a baseline for radiological material in fish. The study established that gross beta activity is generally between 2

and 4 pCi/g and gross gamma activity is generally between 0.04 and 0.4 pCi/g in fish.

Cs-137 and Sr-90 were measured in the pre-operational study and were expected to be measured due to known worldwide contamination from historical global atomic testing. Cs-137 detected was generally between 0.10 and 0.25 pCi/g and Sr-90 detected was generally between 0.01 to 0.04 pCi/g in the pre-operational environmental study.

Plant: Palisades I

Year: 2021 I Page 20 of 48 Annual Radiological Environmental Operating Report The fish sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP fish water samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

4.5.4 Food Product Sample Results Two principal fruit crops are collected once per year and analyzed for gamma radionuclides including lodine-131 in accordance with the REMP. The two crops sampled in 2021 were blueberries and apples. The results of all sample analysis show that only naturally occurring radionuclides (K-40) were present. In accordance with the ODCM, no control sample is collected for this sample type.

Palisades' pre-operational environmental study performed radiological analysis on a variety of crop samples. Gross gamma activity was generally between 0.11 and 0.22 pCi/g and gross beta activity was generally between 0.72 to 3.31 pCi/g.

The fruit sample results collected in accordance with the REMP support the conclusions of the effluents monitoring program for 2021. This conclusion is that the surrounding environment is not affected by Palisades' effluents. No REMP fruit samples from 2021 contained measurable radiological materials attributed to Palisades' effluents.

4.6 Land Use Census Results Sector 2

3 4

5 6

7 8

9 10 The latest land use census (performed in 2021) did not identify any new locations that prompt a change to the REMP or to the atmospheric dispersion or deposition factors used for offsite dose modeling. The sectors in Table 6 include all overland compass sectors.

Table 6, Land Use Census -2021 Nearest Residence Within Five Miles Direction Residence Garden Beef Cattle Dairy Cow NNE 1.67 2.52

>5

>5 NE 1.14 2.76

>5

>5 ENE 1.19 2.11 2.29

>5 E

1.62 2.46 3.51

>5 ESE 1.35 1.66 2.04

>5 SE 0.87 2.20 3.88

>5 SSE 0.80 0.70

>5

>5 s

0.51 3.51

>5

>5 SSW 0.48

>5

>5 Goat

>5

>5 3.46 2.04 3.88

>5

Plant: Palisades I

Year: 2021 I Page 21 of 48 Annual Radiological Environmental Operating Report

4. 7 lnterlaboratorv Comparison Results contains result summary for lnterlaboratory Comparison program for Teledyne Brown Engineering.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

1.

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

Plant: Palisades I

Vear: 2021 I Page 22 of 48 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 31 Control Number of Sample Type Type/ Number LLD [Note1)

Mean (f)(Note 21

[Highest Mean (f)[Note 2)

Locations Mean Non-Routine (Units) of Analyses

[Range]

Annual Mean]

[Range]

(f)!Note 21 [Range]

Results [Note '

4]

l Air (pCi/m3)

GB/ 315 0.01 2.69E-02 (262/262)

Station 8SP 3.25E-02 2.52E-02 (53/53) 0

[1.19E 4.82E-02]

(0.595 miles (53/53)

[1.22E NE)

[1.46E, ll 4.01 E-02]

4.82E-02]

1-131 / 315 0.07

<MDA (0/259)

NIA NIA

<MDA (0/52) 0 Cs-134 / 24 0.05

<MDA (0/20)

NIA NIA

<MDA (0/4) 0 Cs-137 /.24 0.06

<MDA (0/20)

NIA N/A

<MDA (0/4) 0 Inner Ring Gamma/56 Sensitivity of 3 9.28 (44/44)

Station 1 10.68 (4/4) 11.14 (12/12) 0 TLDs (mR/Qtr) mR

[7.26 - 11.22]

(onsite 0.213

[10.44 - 11.22]

[9.84 - 12.80]

0 miles E)

Cutter Ring

Gamma/ 48 Sensitivity of 3 11.26 (36/36)

Station 2 14.12 (4/4) 11.14 (12/12) 0 TLDs (mR/Qtr) mR

[9.20 - 15.54]

(5.560 miles S)

[13.14-15.54]

[9.84 - 12.80]

Plant: Palisades I

Year: 2021 I Page 23 of 48 Annual Radiological Environmental OperatinQ Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location [Note 31 Control Number of Sample Type Type/ Number LLD [Note1]

Mean (f)[Note 2)

[Highest Mean (f)CNote 21 Locations Mean Non-Routine (Units}

of Analyses

[Range]

Annual Mean]

[Range]

(F)INote 2) [Range]

Results [Note

4)

Gross Beta I 24 4.0 3.29 (5 / 12)

Lake In (Plant 3.29 (5 I 12) 2.29 (4 I 12) 0

' P

[2.52 - 5.20]

lake intake)

[2.52 - 5.20]

[2.05 - 2.68]

H-3 I 24 2000

<MDA (0 I 12)

NIA NIA

<MDA (0 I 12) 0 Mn-54124 15

<MDA (0 I 12)

NIA NIA

<MDA (0 I 12) 0 Fe-59 I 24 30

<MDA (0 I 12)

NIA NIA

<MDA (0 I 12) 0 Co-58124 15

<MDA (0 / 12)

N/A N/A

<MDA (0 / 12) 0 Surface Water Co-60 I 24 15

<MDA (0 I 12)

N/A NIA

<MDA (0 / 12) 0 (pCi/L}

Zn-65 / 24 30

<MDA (0 / 12)

N/A NIA

<MDA (0 / 12) 0 Zr-95 I 24 15

<MDA (0 I 12)

NIA N/A

<MDA (0 I 12) 0 Nb-95 I 24 15

<MDA (0 / 12)

N/A N/A

<MDA (0 I 12) 0 Cs-134124 15

<MDA (0112)

NIA NIA

<MDA (0 I 12) 0 Cs-137 I 24 18

<MDA (0 I 12)

NIA NIA

<MDA (0 I 12) 0 Ba-140124 60

<MDA (0 I 12)

N/A NIA

<MDA (0 I 12) 0 La-140124 15

<MDA (0 I 12)

NIA N/A

<MDA (0 / 12) 0

Plant: Palisades I

Vear: 2021 I Page 24 of 48 Annual Radiological Environmental OperatinQ Report Table 7, Radiological Environmental Monitoring Program Summary Number of Sample Type Type/ Number Indicator Locations Location [Note 31 Mean (F)CNote 21 Control Non-Routine LLD [Note1]

Mean (F)CN01e 21

[Highest Locations Mean (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)CNote 21 [Range]

Results [Nole 4]

Gross Beta/ 42 4

2.80 (7 / 30)

Pal Park

[2.40 - 3.42]

Community(O. 7 3.05 (1 / 6) 2.29 (4 / 12) 0 miles SSW)

[3.05 - 3.05]

[2.05 - 2.68]

H-3 / 42

<MDA (0/ 30)

N/A N/A

<MDA (0 / 12) 0 2000 Mn-54/ 42

<MDA (0 / 30)

N/A N/A

<MDA (0 / 12) 0 15 Fe-59 / 42

<MDA (0 / 30)

N/A NIA

<MDA (0 / 12) 0 30 N/A

<MDA (0 / 12) 0 Co-58 / 42 15

<MDA (0/ 30)

N/A Drinking Water Co-60 / 42

<MDA (0/ 30)

N/A N/A

<MDA (0 / 12) 0 (pCi/L) 15 N/A

<MDA (0 / 12) 0 Zn-65 / 42 30

<MDA (0/ 30)

N/A Zr-95 / 42

<MDA (0 / 30)

N/A N/A

<MDA (0 / 12) 0 15 Nb-95 / 42 15

<MDA (0 / 30)

N/A N/A

<MDA (0 / 12) 0 I:

N/A

<MDA (0 / 12) 0 Cs-134 / 42 15

<MDA (0/ 30)

N/A Cs-137 / 42 18

<MDA (0/ 30)

N/A N/A

<MDA (0 / 12) 0 Ba-140 / 42 60

<MDA (0/ 30)

N/A N/A

<MDA (0 / 12) 0 N/A

<MDA (0 / 12) 0 La-140 / 42 15

<MDA (0 / 30)

N/A Mn-54 / 10 130

<MDA (0/ 6)

NIA NIA

<MDA (0 / 4) 0 Fe-59 / 10 260

<MDA (0 / 6)

N/A N/A

<MDA (0/ 4) 0 Co-58 I 10 130

<MDA (0 / 6)

N/A N/A

<MDA (0/ 4) 0 Fish (pCi/kg)

Co-60 / 10 130

<MDA (0/ 6)

N/A N/A

<MDA (0/ 4) 0 Zn-65 I 10 260

<MDA (0/ 6)

N/A N/A

<MDA (0/ 4) 0 Cs-134 / 10 130

<MDA (0 / 6)

N/A N/A

<MDA (0/ 4) 0 Cs-137 / 10 150

<MDA (0 / 6)

N/A N/A

<MDA (0/ 4) 0

Plant: Palisades I

Year: 2021 I Page 25 of 48 Annual Radiological Environmental Operating Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location (Note 31 Control Number of Sample Type Type/ Number LLD (Note 1]

Mean (F)INote 21

[Highest Mean (F)!Note 21 Locations Mean Non-Routine (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)INote 21 [Range]

Results (Note 4]

Food Products 1-131 /2 60

<MDA (0 / 2)

N/A N/A Control sample not 0

(pCi/kg)

Cs-134 / 2 60

<MDA (0/ 2)

N/A N/A required 0

Cs-137 / 2 80

<MDA (0 / 2)

N/A N/A 0

1-131 / 15 60

<MDA (0 / 10)

N/A N/A

<MDA (0 / 5) 0 Broad leaf Cs-134 / 15 60

<MDA (0 / 10)

N/A N/A

<MDA (0/ 5) 0 Vegetation (pCi/kg)

Cs-137 / 15 80 59.8 (5 / 10)

BV2 (onsite 0.7 76.4 (1 / 5)

<MDA (0 / 5) 0 r3s.9 - 81.61 miles SE) r16.4 - 76.41

[N/A]

Sediment Cs-134 / 4 150

<MDA (0/ 4)

N/A N/A Control sample not 0

(pCi/kg)

Cs-137 / 4 180

<MDA (0/ 4)

N/A N/A required 0

Plant: Palisades I

Year: 2021 I Page 26 of 48 Annual RadioloQical Environmental OperatinQ Report Table 7, Radiological Environmental Monitoring Program Summary Indicator Locations Location !Note 31 Control Number of Sample Type Type / Number LLD £Note 11 Mean (F)INote 2J

[Highest Mean (F)[Note 2)

Locations Mean Non-Routine (Units) of Analyses

[Range]

Annual Mean]

[Range]

(F)[Note 2] [Range]

Results [Note

4)

Gross Beta/ 18 4

4.93 (4 / 6)

Pal Park 4.93 (4 / 6) 2.29 (4 / 12) 0

[3.94 - 6.25]

Commercial

[3.94 - 6.25]

[2.05 - 2.68]

Well (0. 7 miles S)

H-3 / 18 2000

<MDA (O / 6)

N/A N/A N/A 0

Mn-54 / 18 15

<MDA (0/ 6)

N/A N/A N/A 0

Offsite Fe-59 / 18 30

<MDA (0/ 6)

N/A N/A N/A 0

Groundwater Co-58 / 18 15

<MDA (0/ 6)

NIA N/A N/A 0

(Pal Park Co-60 / 18 15

<MDA (0 / 6)

N/A N/A N/A 0

Commercial Zn-65 / 18 30

<MDA (0 / 6)

N/A N/A N/A 0

Well) (pCi/L)

Zr-95 I 18 15

<MDA (0 / 6)

N/A N/A N/A 0

Nb-95 / 18 15

<MDA (0/ 6)

N/A N/A N/A 0

Cs-134 / 18 15

<MDA (0/ 6)

N/A N/A N/A 0

Cs-137 I 18 18

<MDA (0/ 6)

N/A N/A N/A 0

Ba-140 I 18 60

<MDA (0 / 6)

N/A N/A NIA 0

La-140 / 18 15

<MDA (0/ 6)

N/A N/A N/A 0

[Note 1] - LLD = Required lower limit of detection

[Note 2)- Mean and range based upon detectable measurements only. Fraction of detectable measurements at specified locations is indicated in parenthesis (F).

[Note 3] - Locations are specified (1) by name and (2) compass sector relative to reactor site.

[Note 4] - A reportable occurrence is a situation in which an NRC report was submitted in accordance with the requirements in Palisades ODCM.

Plant: Palisades I

Year: 2021 I Page 27 of 48 Annual Radioloqical Environmental Operatina Reoort Page 1 of 2 Sample Deviations Table 8, Sample Deviations Table Comment Sample Sample Media Date Problem Evaluation/ Actions No.

Affected Location During normal weekly sample collection (on 01/18/21) the as-found leak test did not Air As-found pass. An as-found and as-left leak test is performed to ensure all sample volume is 1

Sample A9 01/18/21 leak test did being pulled through the filter media. The sample results (2.85E-02 pCi/m3) trended not pass normal for the station. It is unknown how much of the sample volume by-passed the filter media and therefore the sample results were not included in this report.

During normal weekly sample collection (on 02/02/21) the as-found leak test did not pass. An as-found and as-left leak test is performed to ensure all sample volume is being pulled through the filter media. The sample results (1.59E-02 pCi/m3) trended Air As-found lower but still within the minimum to maximum annual range for the station. It is 2

Sample A9 02/02/21 leak test did unknown how much o~ the sample volume by-passed the filter media and therefore the not pass sample results were not included in this report.

A suspected degraded fitting was replaced on the inlet tubing to the sample pump and this has corrected the issue.

During normal weekly sample collection (on 01/18/21) the GFCI outlet the sampling pump is plugged into was found tripped off. The outlet was reset and the pump did not Air Sample turn back on. The pump was replaced the same day the condition was discovered, and 3

Sample A19 01/18/21 Pump Failure flow was restored to the monitoring station. The sample volume was very low for the filter paper and iodine cartridge collected indicating that the pump was not running for approximately 6.5 of the previous 7 days. Therefore, the results of the filter paper and iodine cartridqe analysis were not included in this reoort.

2022-004 I

Rev. 2021 I Page 28 of 48 Annual Radiological Environmental OperatinQ Report Page 2 of 2 Sample Deviations Table 8, Sample Deviations Table Comment Sample Sample Media Date Problem Evaluation / Actions No.

Affected Location During normal weekly sample collection (on 02/08/21) the GFCI outlet the sampling pump is plugged into was found tripped off. The outlet was reset and the pump did not Air Sample turn back on. The pump was replaced the same day the condition was discovered, and 4

Sample AB 02/08/21 Pump Failure flow was restored to the monitoring station. The sample volume was about 75% of what is typically observed for this location indicating the sample pump was not running for approximately 2 days. These sample results were included in this report because all analysis requirements were met.

During normal weekly sample collection (on 06/14/21) the sampling pump was found seized. The pump was replaced the same day the condition was discovered, and flow 5

Air A4 06/14/21 Sample was restored to the monitoring station. The sample volume was about 60% of what is Sample Pump Failure typically observed for this location indicating the sample pump was not running for approximately 3 days. These sample results were included in this report because all analysis requirements were met.

Plant: Palisades I

Year: 2021 I Page 29 of 48 Annual Radioloaical Environmental Operatina Report Page 1 of 17 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Station A4 Station AS Station Station A9 Station Station Start Date End Date Aa[Note 1)

A19 A1Q[Note2]

(Indicator)

(Control)

REQUIRED LLD 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 1.00E-02 12/28/20 1/5/21 2.09E-02 2.48E-02 2.68E-02 1.91E-02 2.71E-02 2.44E-02 1/5/21 1/11/21 3.33E-02 2.55E-02 3.18E-02 2.63E-02 3.02E-02 3.20E-02 2.85E-02 1.41E-01 1/11/21 1/18/21 3.49E-02 3.47E-02 3.13E-02

[Note 3}

2.94E-02 1/18/21 1/25/21 1.84E-02 l.56E-02 l.93E-02 1.62E-02 l.50E-02 1.61E-02 1.59E-02 1/25/21 2/2/21 1.70E-02 2.l0E-02 l.96E-02

[Note 3}

l.71E-02 l.62E-02 2.87E-02 2/2/21 2/8/21 2.53E-02 2.62E-02

[Note3}

2.77E-02 2.42E-02 l.88E-02 2/8/21 2/15/21 2.21E-02 2.20E-02 3.17E-02 2.82E-02 2.31E-02 2.23E-02 2/15/21 2/22/21 3.17E-02 3.24E-02 4.48E-02 3.00E-02 2.65E-02 3.86E-02 2/22/21 3/1/21 2.41E-02 2.25E-02 2.99E-02 l.91E-02 2.12E-02 1.56E-02 3/1/21 3/8/21 2.l0E-02 2.25E-02 2.38E-02 l.69E-02 2.17E-02 2.15E-02 3/8/21 3/15/21 1.82E-02 2.63E-02 3.27E-02 2.06E-02 2.09E-02 2.70E-02 3/15/21 3/22/21 2.72E-02 2.72E-02 3.87E-02 2.30E-02 2.82E-02 1.83E-02 3/29/21 4/5/21 3.07E-02 2.84E-02 4.14E-02 3.08E-02 2.98E-02 2.48E-02 3/22/21 3/29/21 l.81E-02 2.08E-02 2.69E-02 2.07E-02 1.99E-02 2.77E-02 4/5/21 4/12/21 l.73E-02 2.25E-02 l.98E-02 1.73E-02 1.72E-02 2.74E-02 4/12/21 4/19/21 1.83E-02 l.53E-02 2.12E-02 1.35E-02 l.73E-02 1.70E-02 4/19/21 4/26/21 2.60E-02 2.78E-02 3.11E-02 2.60E-02 2.03E-02 2.75E-02 4/26/21 5/3/21 2.24E-02 2.28E-02 3.38E-02 2.48E-02 1.9SE-02 2.S8E-02 5/3/21 5/11/21 1.19E-02 l.64E-02 l.46E-02 1.S0E-02 l.26E-02 1.22E-02 5/11/21 5/17/21 2.25E-02 2.16E-02 2.23E-02 2.13E-02 l.9SE-02 1.94E-02 5/17/21 5/24/21 2.57E-02 3.04E-02 3.28E-02 2.07E-02 2.56E-02 3.09E-02 5/24/21 6/1/21 2.12E-02 2.09E-02 2.86E-02 2.19E-02 2.05E-02 1.87E-02 6/1/21 6/8/21 2.58E-02 3.24E-02 3.75E-02 2.83E-02 2.89E-02 3.3SE-02 6/8/21 6/14/21 2.55E-Q2[Note 3}

2.59E-02 3.47E-02 2.53E-02 2.49E-02 2.02E-02 6/14/21 6/21/21 1.77E-02 2.52E-02 2.94E-02 2.14E-02 2.21E-02 1.91E-02

Plant: Palisades I

Year: 2021 I Page 30 of 48 Annual Radioloaical Environmental Ooeratina Report Page 2 of 18 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Station A4 Station AS Station Station A9 Station Station Start Date End Date AS[Note1J A19 A10[Note2J (Indicator)

(Indicator)

(Control) 6/21/21 6/28/21 l.93E-02 l.62E-02 2.33E-02 1.49E-02 l.61E-02 l.68E-02 6/28/21 7/6/21 2.29E-02 2.80E-02 2.94E-02 2.14E-02 2.13E-02 2.12E-02 7/6/21 7/12/21 2.24E-02 l.99E-02 2.71E-02 l.99E-02 2.00E-02 2.52E-02 7/12/21 7/19/21 2.67E-02 2.79E-02 3.0SE-02 2.26E-02 2.38E-02 2.26E-02 7/19/21 7/26/21 2.88E-02 3.18E-02 3.79E-02 2.74E-02 2.88E-02 2.88E-02 7/26/21 8/2/21 2.39E-02 2.40E-02 3.0SE-02 2.35E-02 2.59E-02 1.85E-02 8/2/21 8/9/21 2.94E-02 3.29E-02 3.84E-02 2.76E-02 2.80E-02 2.63E-02 8/9/21 8/17/21 1.66E-02

1. 74E-02 2.27E-02 l.SOE-02 l.65E-02 2.28E-02 8/17/21 8/23/21 3.39E-02 3.49E-02 4.58E-02 3.37E-02 3.64E-02 3.54E-02 8/23/21 8/30/21 3.02E-02 3.37E-02 3.80E-02 2.56E-02 2.56E-02 3.46E-02 8/30/21 9/7/21 2.65E-02 2.93E-02 3.59E-02 2.SlE-02 3.06E-02 2.43E-02 9/7/21 9/13/21 2.95E-02 3.85E-02 4.46E-02 3.28E-02 3.llE-02 3.71E-02 9/13/21 9/20/21 3.08E-02 3.02E-02 4.53E-02 3.02E-02 3.20E-02 2.62E-02 9/20/21 9/27/21 2.32E-02 2.67E-02 2.98E-02 2.llE-02 2.28E-02 2.23E-02 9/27/21 10/4/21 3.39E-02 3.36E-02 4.63E-02 3.92E-02 3.45E-02 3.03E-02 10/4/21 10/11/21 2.95E-02 3.46E-02 4.34E-02 3.0lE-02 2.93E-02 3.17E-02 10/11/21 10/18/21 2.86E-02 2.78E-02 3.94E-02 2.75E-02 2.76E-02 2.90E-02 10/18/21 10/25/21 2.49E-02 2.83E-02 3.12E-02 2.89E-02 2.93E-02 2.49E-02 10/25/21 11/2/21 l.60E-02 2.00E-02 2.37E-02 l.95E-02 2.0SE-02 1.97E-02 11/2/21 11/8/21 2.99E-02 3.69E-02 4.68E-02 3.57E-02 2.90E-02 2.72E-02 11/8/21 11/16/21 2.68E-02 2.83E-02 3.7SE-02 2.58E-02 2.76E-02 2.34E-02 11/16/21 11/22/21 2.73E-02 2.90E-02 3.40E-02 2.54E-02 2.37E-02 2.93E-02 11/22/21 11/29/21 2.04E-02 2.38E-02 3.28E-02 2.28E-02 l.99E-02 l.92E-02 11/29/21 12/6/21 l.87E-02 2.43E-02 2.58E-02 2.35E-02 2.lSE-02 2.52E-02 12/6/21 12/13/21 2.99E-02 3.lSE-02 3.6SE-02 3.0SE-02 3.21E-02 2.42E-02 12/13/21 12/21/21 2.97E-02 3.0lE-02 2.52E-02 2.84E-02 2.37E-02 3.17E-02 12/21/21 12/27/21 4.06E-02 4.82E-02 4.82E-02 4.80E-02 4.03E-02 4.0lE-02

Plant: Palisades I

Year: 2021 I Page 31 of 48 Annual Radiological Environmental Operating Report Page 3 of 18 Monitoring Results Tables Table 9, Air Gross Beta Data Summary Table Analysis: Gross Beta Units: pCi/m3 Station A4 Station AS Station Station A9 Station Start Date End Date A8{Note1]

A19 (Indicator)

(Indicator)

(Indicator) 12/27/21 1/4/22 3.04E-02 4.38E-02 3.84E-02 3.72E-02 3.43E-02 Note 1 - Station with"hi hest annual mean.

[

)

g

[Note 2] - The sample date range is accurate to plus or minus 2 days for station A 1 O

[Note 3] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table Table 10, Air Radioiodine Data Table Summary Analysis: 1-131 Units: pCi/m3 Station A4 Station AS Station AS Station A9 Station Start Date End Date (Indicator)

(Indicator)

A19 (Indicator)

REQUIRED LLD -+

7.00E-02 7.00E-02 7.00E-02 7.00E-02 7.00E-02 12/28/20 1/5/21

<MDA

<MDA 1/5/21 1/11/21

<MDA

<MDA 1/11/21 1/18/21

<MDA

<MDAINote2)

<MDAINote2) 1/18/21 1/25/21

<MDA

<MDA 1/25/21 2/2/21

<MDA

<MDA[Note2J

<MDA 2/2/21 2/8/21

<MDA

<MDA[Note2)

<MDA

<MDA 2/8/21 2/15/21

<MDA

<MDA 2/15/21 2/22/21

<MDA

<MDA 2/22/21 3/1/21

<MDA

<MDA 3/1/21 3/8/21

<MDA

<MDA 3/8/21 3/15/21

<MDA

<MDA 3/15/21 3/22/21

<MDA

<MDA 3/29/21 4/5/21

<MDA

<MDA 3/22/21 3/29/21

<MDA

<MDA 4/5/21 4/12/21

<MDA

<MDA 4/12/21 4/19/21

<MDA

<MDA 4/19/21 4/26/21

<MDA

<MDA 4/26/21 5/3/21

<MDA

<MDA 5/3/21 5/11/21

<MDA

<MDA Station A10[Note2]

(Control) 3.46E-02 Station A10[Note1]

(Control) 7.00E-02

<MDA

Plant: Palisades I

Vear: 2021 I Page 32 of 48 Annual Radiological Environmental Operating Report Page 4 of 18 Monitoring Results Tables Table 10, Air Radioiodine Data Table Summary Analysis: 1-131 Units: pCi/m3 Station A4 Station A5 Station A8 Station A9 Station Station Start Date End Date (Indicator)

(Indicator)

A19 A10(Note1)

(Indicator)

(Control) 5/11/21 5/17/21

<MDA

<MDA 5/17/21 5/24/21

<MDA

<MDA 5/24/21 6/1/21

<MDA

<MDA 6/1/21 6/8/21

<MDA

<MDA 6/8/21 6/14/21

<MDA (Note 2]

<MDA

<MDA 6/14/21 6/21/21

<MDA

<MDA 6/21/21 6/28/21

<MDA

<MDA 6/28/21 7/6/21

<MDA

<MDA 7/6/21 7/12/21

<MDA

<MDA 7/12/21 7/19/21

<MDA

<MDA 7/19/21 7/26/21

<MDA

<MDA 7/26/21 8/2/21

<MDA

<MDA 8/2/21 8/9/21

<MDA

<MDA 8/9/21 8/17/21

<MDA

<MDA 8/17/21 8/23/21

<MDA

<MDA 8/23/21 8/30/21

<MDA

<MDA 8/30/21 9/7/21

<MDA

<MDA 9/7/21 9/13/21

<MDA

<MDA 9/13/21 9/20/21

<MDA

<MDA 9/20/21 9/27/21

<MDA

<MDA 9/27/21 10/4/21

<MDA

<MDA 10/4/21 10/11/21

<MDA

<MDA 10/11/21 10/18/21

<MDA

<MDA 10/18/21 10/25/21

<MDA

<MDA 10/25/21 11/2/21

<MDA

<MDA 11/2/21 11/8/21

<MDA

<MDA 11/8/21 11/16/21

<MDA

Plant: Palisades I

Vear: 2021 I Page 33 of 48 Annual Radioloaical Environmental Operating Report Page 5 of 18 Monitoring Results Tables Table 1 O, Air Radioiodine Data Table Summary Analysis: 1-131 Units: pCi/m3 Station A4 Station A5 Station AS Station A9 Station Station Start Date End Date (Indicator)

(Indicator)

A19 A10[Note1]

(Indicator)

(Control) 11/16/21 11/22/21

<MDA

<MDA 11/22/21 11/29/21

<MDA

<MDA 11/29/21 12/6/21

<MDA

<MDA 12/6/21 12/13/21

<MDA

<MDA 12/13/21 12/21/21

<MDA

<MDA 12/21/21 12/27/21

<MDA

<MDA 12/27/21 1/4/22

<MDA

[Note 1] - The sample date range is accurate to plus or minus 2 days for station A 1 O

[Note 2] - Reference Attachment 1, Sample Deviations, Table 8, Sample Deviations Table, Table 11, Air Sample Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/m3 Location Start Date End Date Cs-134 Cs-137 Be-71Note 1]

K-40[Note 1]

REQUIRED LLD +

0.05 0.06 NA NA Station A4 12/28/2021 3/29/2021

<MDA

<MDA 1.54E-01

<MDA Station A4 3/29/2021 6/28/2021

<MDA

<MDA 1.17E-01

<MDA Station A4 6/28/2021 9/27/2021

<MDA

<MDA 1.65E-01

<MDA Station A4 9/27/2021 1/4/2022

<MDA

<MDA 1.0SE-01

<MDA Station AS 12/28/2021 3/29/2021

<MDA

<MDA 1.29E-01

<MDA Station AS 3/29/2021 6/28/2021

<MDA

<MDA 1.69E-01

<MDA Station AS 6/28/2021 9/27/2021

<MDA

<MDA 1.14E-01

<MDA Station AS 9/27/2021 1/4/2022

<MDA

<MDA 1.17E-01

<MDA Station AB 12/28/2021 3/29/2021

<MDA

<MDA 1.61E-01

<MDA Station AB 3/29/2021 6/28/2021

<MDA

<MDA 1.92E-0l

<MDA Station A8 6/28/2021 9/27/2021

<MDA

<MDA 1.9SE-01

<MDA Station AB 9/27/2021 1/4/2022

<MDA

<MDA 1.40E-01

<MDA Station A9 12/28/2021 3/29/2021

<MDA

<MDA 1.02E-01

<MDA Station A9 3/29/2021 6/28/2021

<MDA

<MDA 1.S3E-01 2.21E-02 Station A9 6/28/2021 9/27/2021

<MDA

<MDA 1.17E-01

<MDA Station A9 9/27/2021 1/4/2022

<MDA

<MDA 1.20E-01

<MDA Station A19 12/28/2021 3/29/2021

<MDA

<MDA l.18E-01

<MDA Station A19 3/29/2021 6/28/2021

<MDA

<MDA 1.70E-01

<MDA Station A19 6/28/2021 9/27/2021

<MDA

<MDA 1.16E-01

<MDA Station A19 9/27/2021 1/4/2022

<MDA

<MDA 1.0lE-01

<MDA

Plant: Palisades I

Year: 2021 I Page 34 of 48 Annual Radioloaical Environmental Qperatina Report Page 6 of 18 Monitoring Results Tables Station AlO 12/28/2021 3/29/2021

<MDA

<MDA 1.44E-01

<MDA Station Al0 3/29/2021 6/28/2021

<MDA

<MDA l.82E-01

<MDA Station AlO 6/28/2021 9/27/2021

<MDA

<MDA 1.45E-01

<MDA Station AlO 9/27/2021 1/4/2022

<MDA

<MDA l.07E-01

<MDA

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 12, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2020 2nd Qtr 2020 3rd Qtr 2020 4th Qtr 2020 Annual Mean 1 (Note 1) 10.44 10.51 11.22 10.56 10.68 8

9.44 9.72 10.9 9.82 9.97 13 9.81 9.06 10.16 9.21 9.56 14 8.21 7.26 9

7.86 8.08 15 8.86 8.14 10.15 8.49 8.91 16 8.96 8.19 10.14 8.51 8.95 17 8.74 8.1 9.27 8.03 8.54 18 9.13 9.17 10.8 9.2 9.58 19 8.84 8.72 10.14 8.89 9.15 20 8.74 8.78 10.33 8.83 9.17 21 9.08 9.35 10.1 9.38 9.48

[Note 1] - Station with highest annual mean.

Table 13, Thermoluminescent Dosimeters -Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2020 2nd Qtr 2020 3rd Qtr 2020 4th Qtr 2020 Annual Mean 2(Note 1]

13.14 14.14 15.54 13.66 14.12 3

10.75 10.81 11.9 10.65 11.03

-.:;..c_

4 11.43 12.26 12.99 11.81 12.12

Plant: Palisades I

Year: 2021 I Page 35 of 48 Annual Radiological Environmental Operating Report Page 7 of 18 Monitoring Results Tables Table 13, Thermoluminescent Dosimeters-Outer Ring Analysis: Gamma Dose Units: mR Station 1st Qtr 2020 2nd Qtr 2020 3rd Qtr 2020 4th Qtr 2020 Annual Mean 5

10.89 11.02 12.07 11.01 11.25 6

10.35 10.7 11.44 10.87 10.84 7

9.73 9.27 10.31 9.2 9.63 9

9.76 9.76 11.01 9.73 10.07 23 10.35 10.66 11.65 10.65 10.83 24 11.14 11.35 12.45 10.82 11.44

[Note 1] - Station with highest annual mean.

Table 14, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mR Station P 1 Qtr [2021]

2nd Qtr [2021]

3rd Qtr [2021]

4th Qtr [2021]

Annual Mean

[2021]

10 10.98 9.84 11.38 10.26 10.62 11 11.73 11.72 12.8 10.89 11.79 12 10.87 10.55 12.11 10.55 11.02 Table 15, Surface Water-Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Nb-95 Location Start End Date Mn-54 Co-58 Fe-59 Co*60 Zn-65 and Cs-134 Cs-137 Ba-140 La-140 K-40 Th-228 Ra-226 Date Zr-95 REQUIRED LLD 15 15 30 15 30 15 15 18 60 15

[Note 1)

[Notel)

Lake In 01/01/21 02/01/21

<MDA

<MDA Lake In 02/01/21 03/01/21

<MDA

<MOA

<MDA

<MOA

<MDA

<MDA 3.50

<MDA -

Lake In 03/01/21 04/01/21

<MOA

<MDA

<MOA

<MDA Lake In 04/01/21 05/01/21

<MDA

<MDA C

Plant: Palisades I

Vear: 2021 I Page 36 of 48 Annual Radiological Environmental Operating Report Page 8 of 18 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Nb-95 Location Start End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 and Cs-134 Cs-137 Ba-140 La-140 K*40 Th-228 Ra-226 Date Zr-95 Lake In 05/01/21 06/01/21

<MDA

<MOA

<MDA

<MDA Lake In 06/01/21 07/01/21

<MDA

<MDA Lake In 07/01/21 08/01/21

<MDA

<MOA

<MDA

<MDA lake In 08/01/21 09/01/21

<MDA

<MDA Lake In 09/01/21 10/01/21

<MDA

<MDA Lake In 10/01/21 11/01/21

<MDA

<MDA Lake In 11/01/21 12/01/21

<MDA

<MDA 5.20

<MDA Lake In 12/01/21 01/01/22

<MDA

<MDA Ludington 01/01/21 02/01/21

<MDA

<MDA Control Ludington 02/01/21 03/01/21

<MDA

<MDA Control Ludington 03/01/21 04/01/21

<MDA

<MDA Control Ludington 04/01/21 05/01/21

<MDA

<MDA Control 40.8 Ludington 05/01/21 06/01/21

<MDA

<MOA Control Ludington 06/01/21 07/01/21

<MDA

<MDA Control 45.8 Ludington 07/01/21 08/01/21

<MDA

<MDA Control Ludington 08/01/21 09/01/21

<MDA

<MDA Control Ludington 09/01/21 10/01/21

<MDA

<MDA Control Ludington 10/01/21 11/01/21

<MDA

<MDA Control

Plant: Palisades I

Vear: 2021 I Page 37 of 48 Annual Radioloaical Environmental Operatina Report Page 9 of 18 Monitoring Results Tables Table 15, Surface Water - Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Nb-95 location Start End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 and Cs-134 Cs-137 Ba-140 la-140 K-40 Th-228 Ra-226 Date Zr-95 Ludington 11/01/21 12/01/21

<MDA

<MDA Control Ludington 12/01/21 01/01/22

<MDA

<MDA Control

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 16, Surface Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta REQUIRED LLD +

2000 4.00 Lake In 01/01/21 02/01/21

<MDA

<MDA Lake In 02/01/21 03/01/21

<MDA

<MDA Lake In 03/01/21 04/01/21

<MDA

<MDA Lake In 04/01/21 05/01/21

<MDA 2.87 Lake In 05/01/21 06/01/21

<MDA

<MDA Lake In 06/01/21 07/01/21

<MDA

<MDA Lake In 07/01/21 08/01/21

<MDA 3.21 Lake In 08/01/21 09/01/21

<MDA 2.63 Lake In 09/01/21 10/01/21

<MDA 2.52 Lake In 10/01/21 11/01/21

<MDA 2.68 Lake In 11/01/21 12/01/21

<MDA

<MDA Lake In 12/01/21 01/01/22

<MDA

<MDA Ludington Control 01/01/21 02/01/21

<MDA 2.05

Plant: Palisades I

Year: 2021 I Page 38 of 48 Annual Radiological Environmental Operating Report Page 10 of 18 Monitoring Results Tables Table 16, Surface Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta Ludington Control 02/01/21 03/01/21

<MDA 2.68 Ludington Control 03/01/21 04/01/21

<MDA

<MDA Ludington Control 04/01/21 05/01/21

<MDA

<MDA Ludington Control 05/01/21 06/01/21

<MDA

<MDA Ludington Control 06/01/21 07/01/21

<MDA

<MDA Ludington Control 07/01/21 08/01/21

<MDA

<MDA Ludington Control 08/01/21 09/01/21

<MDA 2.25 Ludington Control 09/01/21 10/01/21

<MDA 2.19 Ludington Control 10/01/21 11/01/21

<MDA

<MDA Ludington Control 11/01/21 12/01/21

<MDA

<MDA Ludington Control 12/01/21 01/01/22

<MDA

<MDA Table 17, Drinking Water-Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 (Note 1)

{Note 1)

Domestic 01/01/21 02/01/21 <MDA

<MDA

<MDA Water Domestic 02/01/21 03/01/21 <M,DA

<MDA

<MOA

<MDA 44.5 Water Domestic 03/01/21 04/01/21 <MDA

<MDA

<MOA

<MDA

<MDA Water Domestic 04/01/21 05/01/21 <MDA

<MDA

<MOA

<MDA

<MDA Water

Plant: Palisades I

Vear: 2021 I Page 39 of 48 Annual Radiological Environmental Operating Report Page 11 of 18 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Date Mn*S4 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 (Note 1)

(Note I]

Domestic 05/01/21 06/01/21 <MDA

<MDA

<MDA Water Domestic 06/01/21 07/01/21 <MDA

<MDA

<MDA Water Domestic 07/01/21 08/01/21 <MDA Water

<MDA

<MDA Domestic 08/01/21 09/01/21 <MDA

<MDA

<MDA Water Domestic 09/01/21 10/01/21 <MDA

<MDA

<MDA <MDA

<MDA

<MDA Water Domestic 10/01/21 11/01/21 <MDA

<MDA

<MDA Water Domestic 11/01/21 12/01/21 <MDA

<MDA

<MDA <MDA

<MDA

<MDA 42.5 Water Domestic 12/01/21 01/01/22 <MDA Water

<MDA

<MDA <MDA

<MDA

<MDA Pal Park 05/17/21 NA

<MDA

<MDA Community Pal Park 06/14/21 NA

<MDA

<MDA Community Pal Park 07/15/21 NA

<MDA

<MDA <MDA

<MDA

<MDA Community Pal Park 08/17/21 NA

<MDA

<MDA <MDA <MDA

<MDA

<MDA Community Pal Park 09/20/21 NA

<MDA

<MDA Community Pal Park 10/04/21 NA

<MDA

<MDA <MDA

<MDA

<MDA Community South 01/01/21 02/01/21 <MDA

<MDA

<MDA Haven

Plant: Palisades I

Year: 2021 I Page 40 of 48 Annual Radiological Environmental Operating Report Page 12 of 18 Monitoring Results Tables Table 17, Drinking Water -Gamma Isotopic Analysis: Gamma Isotopic Units: pCi/L Location Start End Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 La-140 Th-228 RA-226 Date REQUIRED LLD +

15 15 30 15 30 15 15 15 18 60 15 (Notel)

(Note 1)

South 02/01/21 03/01/21 <MDA Haven

<MDA

<MDA South 03/01/21 04/01/21 <MDA Haven

<MDA

<MDA South 04/01/21 05/01/21 <MDA Haven

<MDA

<MDA South 05/01/21 06/01/21 <MDA Haven

<MDA

<MDA South 06/01/21 07/01/21 <MDA Haven

<MDA

<MDA South 07/01/21 08/01/21 <MDA Haven

<MDA

<MDA South 08/01/21 09/01/21 <MDA

<MDA

<MDA Haven South 09/01/21 10/01/21 <MDA Haven

<MDA

<MDA South 10/01/21 11/01/21 <MDA Haven

<MDA

<MDA South 11/01/21 12/01/21 <MDA

<MDA

<MOA

<MDA

<MDA 3.15

<MDA Haven South 12/01/21 01/01/22 <MDA

<MDA

<MDA 74.0 Haven rNote 11-This nuclide is natµrallv occurrino and there is no ODCM required LLD.

Table 18, Drinking Water-Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location I

Start Date End Date Tritium Gross Beta REQUIRED LLD +

2000 4.00 Domestic Water I

01/01/21 02/01/21

<MDA 2.63

Plant: Palisades I

Year: 2021 I Page 41 of 48 Annual Radiological Environmental Operating Report Page 13 of 18 Monitoring Results Tables Table 18, Drinking Water -Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta Domestic Water 02/01/21 03/01/21

<MDA 2.91 Domestic Water 03/01/21 04/01/21

<MDA

<MDA Domestic Water 04/01/21 05/01/21

<MDA

<MDA Domestic Water 05/01/21 06/01/21

<MDA

<MDA Domestic Water 06/01/21 07/01/21

<MDA

<MDA Domestic Water 07/01/21 08/01/21

<MDA

<MDA Domestic Water 08/01/21 09/01/21

<MDA

<MDA Domestic Water 09/01/21 10/01/21

<MDA 2.55 Domestic Water 10/01/21 11/01/21

<MDA 3.42 Domestic Water 11/01/21 12/01/21

<MDA

<MDA Domestic Water 12/01/21 01/01/22

<MDA

<MDA Pal Park Community 05/17/21 NA[Notell

<MDA 3.05 Pal Park Community 06/14/21 NAINotell

<MDA

<MDA Pal Park Community 07/15/21 NA[Note 1}

<MDA

<MDA Pal Park Community 08/17/21 NAINote 11

<MDA

<MDA Pal Park Community 09/20/21 NAINote 1}

<MDA

<MDA Pal Park Community 10/04/21 NAINote l}

<MDA

<MDA South Haven 01/01/21 02/01/21

<MDA

<MDA South Haven 02/01/21 03/01/21

<MDA

<MDA South Haven 03/01/21 04/01/21

<MDA

<MDA South Haven 04/01/21 05/01/21

<MDA

<MDA South Haven 05/01/21 06/01/21

<MDA

Plant: Palisades I

Vear: 2021 I Page 42 of 48 Annual Radiological Environmental Operating Report Page 14 of 18 Monitoring Results Tables Table 18, Drinking Water - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Start Date End Date Tritium Gross Beta South Haven 06/01/21 07/01/21

<MDA

<MDA South Haven 07/01/21 08/01/21

<MDA

<MDA South Haven 08/01/21 09/01/21

<MDA

<MDA South Haven 09/01/21 10/01/21

<MDA 2.62 South Haven 10/01/21 11/01/21

<MDA 2.40 South Haven 11/01/21 12/01/21

<MDA

<MDA South Haven 12/01/21 01/01/22

<MDA

[Note 1] - This is a grab sample and therefore there is no end date.

Table 19, Sediment Analysis: Gamma Isotopic Units: pCi/kg Location Collection Date Cs-134 Cs-137 K-40 Th-228 Th-232 Ac-228 REQUIRED LLD _.

150 180 (Note 1)

(Note 1]

(Note1)

(Note 1]

North Sediment 3/10/21

<MDA

<MDA 4328 342 356 328 North Sediment 10/20/21

<MDA

<MDA 4132 197

<MDA

<MDA South Sediment 3/10/21

<MDA

<MDA 1562 1033 1329

<MDA South Sediment 10/20/21

<MDA

<MDA 3292 515

<MDA

[Note 1) - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 20, Fish Analysis: Gamma l~otopic Units: pCi/kg Location I Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 species REQUIRED LLD _.

130 130 260 130 260 130 150 (Note 1)

Ludington / Drum 5/12/21

<MDA

<MDA 2966

Plant: Palisades I

Vear: 2021 I Page 43 of 48 Annual RadioloQical Environmental OperatinQ Report Page 15 of 18 Monitoring Results Tables Table 20, Fish Analysis: Gamma Isotopic Units: pCi/kg Location/

Collection Date Mn-54 Co-58 Fe-59 Co-60 Zn-65 Cs-134 Cs-137 K-40 species Ludington / Shad 8/15/21

<MDA

<MDA 2873 Ludington / Trout 5/5/21

<MDA

<MDA 3397 Ludington/

5/30/21

<MDA

<MDA 3593 Walleye Palisades / Carp 5/18/21

<MDA

<MDA 2665 Palisades / Drum 5/27/21

<MDA

<MDA 2792 Palisades / Shad 7/7/21

<MDA

<MDA 2282 Palisades/

5/27/21

<MDA

<MDA 4090 Walleye Palisades / White 5/27/21

<MDA

<MDA 3214 Bass Palisades / White 7/7/21

<MDA

<MDA 2936 perch

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Table 21, Food Products Analysis: 1-131, Gamma Isotopic Units: pCi/kg Sample / Location Collection Date 1-131 Cs-134 Cs-137 K-40 REQUIRED LLD +

60 60 80

[Note 1)

Blueberries / Covert

<MDA

<MDA 966 Ml 07/06/21 Apples / Covert Ml 09/28/21

<MDA

<MDA 1629

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I

Vear: 2021 I Page 44 of 48 Annual Radioloaical Environmental Ooeratina Reoort Page 16 of 18 Monitoring Results Tables Table 22, Offsite Groundwater~ Gamma isotopic Analysis: Gamma Isotopic Units: pCi/L Location Collection Mn-54 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Cs-134 Cs-137 Ba-140 Date La-140 REQUIRED LLD 15 15 30 15 30 15 15 15 18 60 15 Pal Park Commercial 05/17/21

<MDA

<MOA Well Pal Park Commercial 06/14/21

<MOA

<MDA

<MDA Well Pal Park Commercial 07/15/21

<MDA

<MDA Well Pal Park Commercial 08/17/21

<MDA

<MDA Well Pal Park Commercial 09/20/21

<MDA

<MDA Well Pal Park Commercial 10/04/21

<MDA

<MDA Well

Plant: Palisades I

Year: 2021 I Page 45 of 48 Annual Radiological Environmental Operating Report Page 17 of 18 Monitoring Results Tables Table 23, Offsite Groundwater - Tritium and Gross Beta Analysis: Tritium and Gross Beta Units: pCi/L Location Collection Date Tritium Gross Beta REQUIRED LLD 2000 4.00 Pal Park Commercial 05/17/21

<MDA 5.29 Well Pal Park Commercial 06/14/21

<MDA 4.24 Well Pal Park Commercial 07/15/21

<MDA

<MDA Well Pal Park Commercial 08/17/21

<MDA 3.94 Well Pal Park Commercial 09/20/21

<MDA 6.25 Well Pal Park Commercial 10/04/21

<MDA

<MDA Well Table 24, Broad Leaf Vegetation Analysis: 1-131, Gamma Isotopic Units: pCi/kg Location Collection Date 1-131 Cs-134 Cs-137 K-40 Be-7 REQUIRED LLD +

60 60 80

[Note 1]

(Note 1]

Location BV1, 0.4 05/14/21

<MDA

<MDA 40.3 3053 1115 miles SSE Location BV1, 0.4 06/14/21

<MDA

<MDA 35.9 2265 603 miles SSE Location BV1, 0.4 07/15/21

<MDA

<MDA 2881 2760 miles SSE Location BV1, 0.4 08/17/21

<MDA

<MDA 64.5 1679 5438 miles SSE Location BV1, 0.4 09/20/21

<MDA

<MDA 81.6 1814 3152 miles SSE Location BV2, 0.7 05/14/21

<MDA

<MDA 3850 1278 miles SSE

Plant: Palisades I

Year: 2021 I Page 46 of 48 Annual Radiological Environmental Operating Report Page 18 of 18 Monitoring Results Tables Table 24, Broad Leaf Vegetation Analysis: 1-131, Gamma Isotopic Units: pCi/kg Location Collection Date 1-131 Cs-134 Cs-137 K-40 Be-7 Location BV2, 0.7 06/15/21

<MDA

<MDA 76.4 3720 422 miles SSE Location BV2, 0.7 07/15/21

<MDA

<MDA 4332 1953 miles SSE Location BV2, 0.7 08/17/21

<MDA

<MDA 3833 5529 miles SSE Location BV2, 0.7 09/20/21

<MDA

<MDA 3421 2680 miles SSE Location SVC, 13.6 05/14/21

<MDA

<MDA 4208 592 miles SSE Location BVC, 13.6 06/14/21

<MDA

<MDA 3941 274 miles SSE Location BVC, 13.6 07/15/21

<MDA

<MDA 5225 1784 miles SSE Location BVC, 13.6 08/17/21

<MDA

<MDA 4237 1558 miles SSE Location BVC, 13.6 09/20/21

<MDA

<MDA 2847 1285 miles SSE

[Note 1] - This nuclide is naturally occurring and there is no ODCM required LLD.

Plant: Palisades I

Year: 2021 I Page 47 of 48 Annual Radioloaical Environmental Qperatina Report Page 1 of 2 lnterlaboratory Comparison Program Results 1.0 Summary Teledyne Brown Engineering (TBE) laboratory participates in three overlapping interlaboratory cross check programs, those being, Analytics Environmental Cross Check Program, Department of Energy (DOE) Mixed Analyte Performance Evaluation Program (MAPEP), and Environmental Resource Associates (ERA). Each program has its own grading criteria for pass or fail. All failures are tracked by TBE with a non-conformance report to determine the cause of the failure. The interlaboratory program is one indicator that the REMP results are accurate.

A total of 27 nuclides associated with six media types (air filter, charcoal, milk, soil, vegetation, and water) were analyzed. From all cross-check analyses in 2021 seven non-conformance reports (NCR's) were initiated.

NCR 21 MRAD water Fe-55 result of 579 pCi/L was not within the acceptance criteria of 162 - 400 pCi/L. The likely cause for the high result was sample loss in the plating process. Coaching was provided to lab and count-room technicians to more closely inspect plates for possible sample loss.

NCR 21 MAPEP air particulate gross alpha result of 0.371 Sq/sample was not within the acceptance criteria of 0.53 to 3.01 Sq/sample. After investigation it was determined that the sample filter was sent to the lab upside down in the container.

The sample is marked to indicate which side is spiked upon receipt and when the sample was reanalyzed facing the other direction the result passed testing. This is not likely to affect a real sample since real samples are dark on the side collecting the sample.

NCR 21 MAPEP soil Ni-63 result of 31 O Bq/kg was not within acceptance criteria of 482 - 896 Bq/kg. The cause could be due to interferences not completely removed in the separation process. The procedure for soils was re-evaluated against other national standards and re-written to better remove known interferences in samples and to ensure that there is limited loss of Ni during the process.

NCR 21-1 o - ERA gross beta in water result of 63.0 pCi/L was outside the acceptance criteria of 38.1 - 62.6 pCi/L. Considering other QA acceptance criteria and the 2 sigma uncertainty of the analysis no corrective actions for this result were pursued other than repeating the analysis with a new unknown cross-check.

NCR 21 ERA tritium in water result of 13,800 pCi/L was outside acceptance criteria of 15,000 - 18,900 pCi/L. This was the first "not acceptable" for tritium on record. Although ERA deemed the result as "not acceptable" the result falls within Teledyne Browns passing QC standard. Considering other QA acceptance criteria and the 2 sigma uncertainty of the analysis no corrective actions for this result were pursued other than repeating the analysis with a new unknown cross-check.

NCR 21 MAPEP Ni-63 result in soil result of 546 Bq/kg was outside the acceptance criteria range of 896 - 1664 Bq/kg. It is believed interferences in the cross-check sample are affecting the results, so a procedure change was made to matrix spike all client samples of this type.

Plant: Palisades I

Year: 2021 I Page 48 of 48 Annual Radiological Environmental Operating Report Page 2 of 2 lnterlaboratory Comparison Program Results NCR 21 ERA gross beta in water result of 47.6 pCi/L was outside the range of 26.4 - 47.3 pCi/L. Considering other QA acceptance criteria and the 2 sigma uncertainty of the analysis no corrective actions for this result were pursued other than repeating the analysis using a different detector which yielded results within the ERA acceptance criteria.

Thermoluminescent dosimeters (TLDs) are analyzed by an offsite vendor, "Environmental Dosimetry Company" (EDC). The TLDs used are Panasonic 814 Environmental dosimeters. EDC implements an internal quality assurance program and audits the program annually. Some of EDC's vendors also perform independent testing on the TLDs accuracy and precision. During 2021 100% (72n2) of the individual dosimeters met the criterion for accuracy and precision (plus or minus 12.8%). Also, 100% (12/12) of the dosimeter sets evaluated met EDC acceptance criteria for mean bias and precision and 100% (6/6) of independent testing passed the performance criteria. One internal assessment was performed in 2021. There were no findings identified.

PNP 2022-004, 2021 Radiological Environmental Operating Report

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PNP 2022-004, 2021 Radiological Environmental Operating Report

Text

Subject:

Dear Sir or Madam:

Enclosure:

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2.0 INTRODUCTION

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1.1 Plant

SUMMARY

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4.1 Plant

SUMMARY

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