0CAN052201, Annual Radiological Environmental Operating Report for 2021

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Annual Radiological Environmental Operating Report for 2021
ML22130A789
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 05/10/2022
From: Keele R
Entergy Operations
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
0CAN052201
Download: ML22130A789 (68)


Text

Riley D. Keele, Jr.

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

0CAN052201 10 CFR 50, Appendix I

May 10, 2022

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Annual Radiological Environmental Operating Report for 2021

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

Reference:

Entergy Operations, Inc. (Entergy) letter to NRC, Annual Radioactive Effluent Release Report for 2021, Arkansas Nuclear One, Units 1 and 2 (0CAN042202), (ML22104A104), dated April 14, 2022

In accordance with Arkansas Nuclear One (ANO), Unit 1 Technical Specification (TS) 5.6.2 and Unit 2 TS 6.6.2, the submittal of an annual radiological envir onmental operating report for the previous year is required by May 15 of each year. The subject ANO report for the calendar year 2021 is enclosed. This report fulfills the reporting requirements of the referenced TSs.

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

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

This letter contains no new regulatory commitments.

Entergy Operations, Inc. 1448 S.R 333 Russellville, AR 72802 0CAN052201 Page 2 of 2

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

Respectfully,

ORIGINAL SIGNED BY RILEY D. KEELE, JR.

Riley Keele

RDK/rwc

Enclosure:

Annual Radiological Environmental Operating Report for 2021

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

0CAN052201

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2021 Plant: Arkansas Nuclear One Page 1 of 65 Year: 2021 Document Number: 0CAN052201 Annual Radiological Environmental Operating Report

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

1.0 EXECUTIVE

SUMMARY

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

2.0 INTRODUCTION

.......................................................................................................................... 5

3.0 RADIOLOGICAL ENVIRONMENTAL SAMPLING PROGRAM REQUIREMENTS...................... 6

4.0 INTERPRETATION AND TRENDS OF RESULTS..................................................................... 17

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

.......................... 24

ATTACHMENTS

- Sample Deviations......................................................................................................... 29

- Monitoring Results Tables.............................................................................................. 30

- Interlaboratory Comparison Program Results................................................................ 45

Attachment 4 - ERRATA......................................................................................................................... 61 Plant: Arkansas Nuclear One Year: 2021 Page 3 of 65 Annual Radiological Environmental Operating Report

1.0 EXECUTIVE

SUMMARY

1.1 Radiological Environmental Monitoring Program

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

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

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

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

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

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

1.2 Reporting Levels

No samples equaled or exceeded reporting levels.

Plant: Arkansas Nuclear One Year: 2021 Page 4 of 65 Annual Radiological Environmental Operating Report

1.3 Comparison to State and/or Federal Program

ANO personnel compared REMP data to state monitoring programs as results became available. Historically, the programs used for comparison have included the U.S. Nuclear Regulatory Commission (NRC) Thermoluminescent Dosimeter (TLD)

Direct Radiation Monitoring Network and the Arkansas Department of Health.

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

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

Both programs have obtained similar results over previous years.

1.4 Sample Deviations

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

Attachment 1, Sample Deviations contains the listing of sample deviations and actions taken.

1.5 Program Modifications

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

No changes were made to ANO ODCM in 2021.

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

2.0 INTRODUCTION

2.1 Radiological Environmental Monitoring Program

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

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

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

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

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

2.2 Pathways Monitored

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

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

2.3 Land Use Census

ANO conducts a land use census biennially, as required by Section B 2.5.2 of the ODCM. The purpose of this census is to identify changes in uses of land within five miles of ANO that would require modifications to the REMP and the ODCM. The most important criteria during this census are to determine the location of the nearest milk animal, the nearest residence, and the nearest garden of greater than 500 ft 2 producing fresh leafy vegetables in each of the 16 meteorological sectors within a 5-mile distance from one reactor (containment).

Plant: Arkansas Nuclear One Year: 2021 Page 13 of 65 Annual Radiological Environmental Operating Report

Figure 1, Exposure Pathway

Plant: Arkansas Nuclear One Year: 2021 Page 14 of 65 Annual Radiological Environmental Operating Report

Figure 2, Sample Collection Sites -Near Field

SR 333 152 3

108 Training 145 Center

146

109 147

13 1 West Access Rd. 10 56

2 8C 36

Scott Ln.

8S 151 148

Cemetery May Rd. Bunker Hill Bunker Ln.

Hill Rd.

150 4 149 110

Arkansas Nuclear One REMP Sample Locations (Near Field)

Lake Dardanelle

Revised 24May05

Plant: Arkansas Nuclear One Year: 2021 Page 15 of 65 Annual Radiological Environmental Operating Report

Figure 3, Sample Collection Sites - Far Field

Plant: Arkansas Nuclear One Year: 2021 Page 16 of 65 Annual Radiological Environmental Operating Report

Figure 4, Sample Collection Sites

62

58

STR-3

Switch Yard STR-2

STR-4 STR-6

West Access Road 64

STR-5 63

STR-1

N Lake Dardanelle

W E

S

Arkansas Nuclear One REMP Sample Locations Site Map Plant: Arkansas Nuclear One Year: 2021 Page 17 of 65 Annual Radiological Environmental Operating Report

4.0 INTERPRETATION AND TRENDS OF RESULTS

4.1 Air Particulate and Radioiodine Sample Results - Example

The REMP has detected radioactivity in t he airborne pathway attributable to other sources. These include the 25th Chinese nuclear test explosion in 1980, the radioactive plume release due to reactor core degradation at Chernobyl Nuclear Power Plant in 1986, and the Fukushima Daiichi Nuclear Power Plant accident (March 11, 2011).

In 2021 there were no samples above the LLD for I-131. Indicator gross beta air particulate results for 2021 were comparable to results obtained from 2011-2020 of the operational REMP, but less than 2013 when the annual average was 0.043. Also, the 2021 gross beta annual average was less than the average for preoperational levels. Results are reported as annual average picocuries per cubic meter (pCi/m 3).

Monitoring Period Result 2011 - 2020 (Minimum Value) 0.017 2021 Average Value 0.022 2011 - 2020 (Maximum Value) 0.043 Preoperational 0.050

In the absence of plant-related gamma radionuclides, gross beta activity is attributed to naturally occurring radionuclides. Table 9, Air Particulate Data Summary Table, includes gross beta concentrations and provides a comparison of the indicator and control means and ranges emphasizes the consistent trends seen in this pathway to support the presence of naturally occurring activity. Therefore, it can be concluded that the airborne pathway continues to be unaffected by ANO operations.

Plant: Arkansas Nuclear One Year: 2021 Page 18 of 65 Annual Radiological Environmental Operating Report

4.2 Thermoluminescent Dosimetry (TLD) Sample Results - Example

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

Table 5, Direct Radiation Annual Summary

Year Inner Ring (mR/Qtr) Special Interest Control Location (mR/Qtr) (mR/Qtr)

2011 8.5 7.6 6.9

2012 8.0 7.2 7.0

2013 8.3 7.6 6.8

2014 7.8 6.9 6.1

2015 7.6 6.9 6.1

2016 8.0 6.7 6.5

2017 8.2 7.2 6.7

2018 7.7 6.4 5.7

2019 7.7 6.9 6.9

2020 7.6 6.9 6.0

2021 7.8 7.2 6.5

4.3 Waterborne Sample Results

Analytical results for 2021 drinking water and ground water samples were similar to those reported in previous years. Gamma radionuclides analytical results for 2021 surface water samples were similar to those reported in previous years. Tritium in ANO surface water indicator samples continue to be detected, but at levels below those experienced in 2013 and below the ODCM-required LLD. These results are further explained below.

Plant: Arkansas Nuclear One Year: 2021 Page 19 of 65 Annual Radiological Environmental Operating Report

4.3.1 Surface Water

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

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

Preoperational 200.0

  • Indicates value from 2013

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

4.3.2 Drinking Water

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

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

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 20 of 65 Annual Radiological Environmental Operating Report

Radionuclide 2021 2020 2011 - 2019** Preoperational Gross Beta 1.71 2.07* 2.18 2.0 Iodine-131 < LLD < LLD < LLD < LLD Gamma < LLD < LLD < LLD < LLD Tritium < LLD < LLD < LLD 200.0

  • Average for the control sample during 2020, gross beta was 2.07 pCi/L which is > MDC, but < LLD.
    • Average of the results from the years 2011-2019.

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

4.3.3 Groundwater

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

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

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

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

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

Determine if any change to the ODCM is required.

Determine if a corrective action/remediation is required.

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

Plant: Arkansas Nuclear One Year: 2021 Page 21 of 65 Annual Radiological Environmental Operating Report

Radionuclide 2021 2011 - 2020 Iodine-131 < LLD < LLD Gamma < LLD < LLD Tritium < LLD < LLD Gross Beta 4.38* 4.14**

  • Average for Indicator and control wells for 2021.
    • Only 2014-2020 gross beta data available for review as historical data. Value is historical average of indicator and control wells.

4.4 Soil Sample Results - Example

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

Monitoring Period Result 2011 - 2020 (Minimum Value) 253.0 2021 Value < LLD 2011 - 2020 (Maximum Value) 661.0

Sediment samples were collected from two locations in 2021 and analyzed for gamma radionuclides. Although Cesium-137 has been detected in years prior to 2021, all gamma radionuclides from 2021 samples were below detectable limits.

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

4.5 Ingestion Sample Results - Example

4.5.1 Milk Sample Results

Milk samples were not collected during 2021 due to the unavailability of indicator locations within five miles of ANO.

4.5.2 Fish Sample Results

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

4.5.3 Food Product Sample Results

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

Plant: Arkansas Nuclear One Year: 2021 Page 22 of 65 Annual Radiological Environmental Operating Report

In 2021, food product samples were collected when available from two locations and analyzed for Iodine-131 and gamma radionuclides. The 2021 levels remained undetectable, as has been the case in previous years. Therefore, based on these measurements, ANO operations had no significant radiological impact upon the environment or public by this ingestion pathway.

4.6 Land Use Census Results

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 23 of 65 Annual Radiological Environmental Operating Report

Table 6, Land Use Census - [2021] Nearest Residence Within Five Miles

Range (Miles)

Sector Direction Comment Nearest Residence Garden Meat Nearest Milk Animal

1 N 1.1 N/A > 5 > 5 None

2 NNE 1.3 N/A 2.8 > 5 1

3 NE 0.9 N/A > 5 > 5 None

4 ENE 0.8 N/A > 5 > 5 None

5 E 0.8 N/A > 5 > 5 None

6 ESE 0.8 N/A > 5 > 5 None

7 SE 0.8 N/A > 5 > 5 None

8 SSE 0.8 N/A > 5 > 5 None

9 S 0.8 N/A > 5 > 5 None

10 SSW 0.7 N/A > 5 > 5 None

11 SW 2.8 N/A > 5 > 5 None

12 WSW 0.7 N/A > 5 > 5 None

13 W 0.8 N/A > 5 > 5 2

14 WNW 0.8 N/A > 5 > 5 None

15 NW 1.0 N/A > 5 > 5 None

16 NNW 0.9 N/A > 5 > 5 None

  1. Comment

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

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

Plant: Arkansas Nuclear One Year: 2021 Page 24 of 65 Annual Radiological Environmental Operating Report

4.7 Interlaboratory Comparison Results

Attachment 3 contains result summaries for the Interlaboratory Comparison Program for Teledyne Brown Engineering and Environmental Dosimetry Group.

5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

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

Plant: Arkansas Nuclear One Year: 2021 Page 30 of 65 Annual Radiological Environmental Operating Report Attachment 2 Page 1 of 15 Monitoring Results Tables

Table 9, Air Particulate Data Summary Table

Analysis: Gross Beta Units: pCi/m3

Start Date End Date Station 1 [Note 1] Station 2 Station 56 Station 6[Note 1] Station 7 (Indicator) (Indicator) (Indicator) (Control) (Control)

REQUIRED LLD 1E-02 1E-02 1E-02 1E-02 1E-02

12/29/2020 1/12/2021 2.80E-02 1.69E-02 1.90E-02 1.90E-02 1.46E-02

1/12/2021 1/26/2021 3.50E-02 2.00E-02 1.79E-02[Note 2] 2.23E-02 1.28E-02

1/26/2021 2/9/2021 6.19E-02 2.90E-02 2.63E-02 3.00E-02 1.79E-02

2/9/2021 2/23/2021 2.64E-02 2.36E-02 2.57E-02 2.67E-02 1.66E-02

2/23/2021 3/9/2021 1.97E-02 1.50E-02 1.65E-02 2.22E-02 1.03E-02

3/9/2021 3/23/2021 1.74E-02 1.75E-02 1.96E-02 2.02E-02 1.11E-02

3/23/2021 4/6/2021 2.17E-02 2.04E-02 2.28E-02 2.25E-02 1.49E-02

4/6/2021 4/20/2021 1.66E-02 1.57E-02 1.59E-02 1.66E-02 8.65E-03

4/20/2021 5/4/2021 2.11E-02[Note 2] 1.95E-02 2.21E-02 2.30E-02 1.91E-02

5/4/2021 5/18/2021 1.74E-02 1.78E-02 1.92E-02 1.84E-02 1.70E-02

5/18/2021 6/1/2021 1.56E-02 1.54E-02 1.55E-02 1.60E-02 1.62E-02

6/1/2021 6/15/2021 1.64E-02[Note 2] 1.53E-02 1.83E-02 1.71E-02 2.03E-02

6/15/2021 6/29/2021 2.19E-02[Note 2] 2.03E-02 2.30E-02 1.87E-02[Note 2] 2.24E-02

6/29/2021 7/13/2021 1.88E-02 1.60E-02 2.02E-02 1.76E-02 1.70E-02

7/13/2021 7/27/2021 2.18E-02 1.70E-02 2.34E-02 2.27E-02 1.98E-02

7/27/2021 8/10/2021 3.35E-02 3.08E-02 3.35E-02 3.03E-02 3.26E-02

8/10/2021 8/24/2021 1.71E-02 1.62E-02 1.73E-02 1.60E-02 1.59E-02

8/24/2021 9/7/2021 2.25E-02 2.11E-02 2.24E-02 2.16E-02 1.75E-02

9/7/2021 9/21/2021 2.29E-02 2.07E-02 2.37E-02 2.26E-02 2.20E-02

9/21/2021 10/5/2021 2.00E-02 2.16E-02 2.28E-02 2.12E-02 1.94E-02

10/5/2021 10/19/2021 2.56E-02 2.30E-02 2.32E-02 2.37E-02 2.26E-02

10/19/2021 11/2/2021 2.49E-02 2.05E-02 2.15E-02 2.56E-02 2.34E-02

11/2/2021 11/16/2021 3.02E-02 2.98E-02 3.03E-02 3.19E-02 3.07E-02

11/16/2021 11/30/2021 2.72E-02 2.56E-02 2.85E-02 2.91E-02 3.19E-02

11/30/2021 12/14/2021 3.93E-02[Note 2] 3.86E-02 3.95E-02 3.94E-02 3.82E-02 Plant: Arkansas Nuclear One Year: 2021 Page 31 of 65 Annual Radiological Environmental Operating Report

Attachment 2 Page 2 of 15 Monitoring Results Tables

Table 9, Air Particulate Data Summary Table

Analysis: Gross Beta Units: pCi/m3

Start Date End Date Station 1 [Note 1] Station 2 Station 56 Station 6[Note 1] Station 7 (Indicator) (Indicator) (Indicator) (Control) (Control)

12/14/2021 12/21/2021 2.82E-02[Note 2] 2.98E-02 3.40E-02 2.97E-02 3.06E-02

Station Yearly Average 2.50E-02 2.13E-02 2.32E-02 2.32E-02 2.01E-02

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

Table 10, Radioiodine Cartridge Data Table Summary Analysis: I-131 Units: pCi/m3

Start Date End Date Station 1 Station 2 Station 56 Station 6 Station 7 (Indicator) (Indicator) (Indicator) (Control) (Control)

12/29/2020 1/12/2021 < 7.89E-03 < 1.59E-02 < 1.58E-02 < 1.60E-02 < 1.61E-02

1/12/2021 1/26/2021 < 1.23E-02 < 1.15E-02 < 1.15E-02[Note 1] < 1.14E-02 < 1.13E-02

1/26/2021 2/9/2021 < 7.56E-03 < 1.49E-02 < 1.49E-02 < 1.51E-02 < 1.50E-02

2/9/2021 2/23/2021 < 2.07E-02 < 2.07E-02 < 8.70E-03 < 2.08E-02 < 2.05E-02

2/23/2021 3/9/2021 < 2.06E-02 < 2.07E-02 < 2.07E-02 < 8.64E-03 < 2.06E-02

3/9/2021 3/23/2021 < 1.65E-02 < 1.65E-02 < 1.65E-02 < 7.72E-03 < 1.64E-02

3/23/2021 4/6/2021 < 2.66E-02 < 2.65E-02 < 2.65E-02 < 1.26E-02 < 2.62E-02

4/6/2021 4/20/2021 < 1.46E-02 < 1.46E-02 < 1.22E-02 < 1.45E-02 < 1.44E-02

4/20/2021 5/4/2021 < 8.09E-03[Note 1] < 1.63E-02 < 1.63E-02 < 1.65E-02 < 1.64E-02

5/4/2021 5/18/2021 < 1.39E-02 < 1.40E-02 < 9.34E-03 < 1.39E-02 < 1.39E-02

5/18/2021 6/1/2021 < 8.83E-03 < 2.10E-02 < 2.10E-02 < 2.09E-02 < 2.09E-02

6/1/2021 6/15/2021 < 1.08E-02[Note 1] < 2.40E-02 < 2.40E-02 < 2.38E-02 < 2.37E-02

6/15/2021 6/29/2021 < 1.06E-02[Note 1] < 1.05E-02 < 1.05E-02 < 1.05E-02[Note 1] < 1.05E-02

6/29/2021 7/13/2021 < 2.23E-02 < 2.24E-02 < 9.38E-03 < 2.22E-02 < 2.21E-02

7/13/2021 7/27/2021 < 1.04E-02 < 1.04E-02 < 1.04E-02 < 1.04E-02 < 1.04E-02

7/27/2021 8/10/2021 < 1.75E-02 < 1.75E-02 < 1.75E-02 < 1.75E-02 < 8.40E-03

8/10/2021 8/24/2021 < 1.39E-02 < 1.39E-02 < 1.39E-02 < 1.38E-02 < 6.55E-03

8/24/2021 9/7/2021 < 1.69E-02 < 1.69E-02 < 1.69E-02 < 1.69E-02 < 7.06E-03 Plant: Arkansas Nuclear One Year: 2021 Page 32 of 65 Annual Radiological Environmental Operating Report

Attachment 2 Page 3 of 15 Monitoring Results Tables

Table 10, Radioiodine Cartridge Data Table Summary Analysis: I-131 Units: pCi/m3

Start Date End Date Station 1 Station 2 Station 56 Station 6 Station 7 (Indicator) (Indicator) (Indicator) (Control) (Control)

9/7/2021 9/21/2021 < 8.58E-03 < 2.05E-02 < 2.05E-02 < 2.04E-02 < 2.04E-02

9/21/2021 10/5/2021 < 1.58E-02 < 1.58E-02 < 6.62E-03 < 1.57E-02 < 1.57E-02

10/5/2021 10/19/2021 < 1.10E-02 < 5.63E-03 < 1.10E-02 < 1.10E-02 < 1.10E-02

10/19/2021 11/2/2021 < 8.75E-03 < 2.09E-02 < 2.09E-02 < 2.08E-02 < 2.08E-02

11/2/2021 11/16/2021 < 2.01E-02 < 8.46E-03 < 2.02E-02 < 2.01E-02 < 2.00E-02

11/16/2021 11/30/2021 < 1.55E-02 < 1.55E-02 < 1.55E-02 < 1.56E-02 < 7.41E-03

11/30/2021 12/14/2021 < 1.72E-02[Note 1] < 1.72E-02 < 1.15E-02 < 1.71E-02 < 1.71E-02

12/14/2021 12/21/2021 < 2.11E-02[Note 1] < 2.11E-02 < 2.11E-02 < 2.10E-02 < 9.52E-03

Station Yearly Average < LLD < LLD < LLD < LLD < LLD

[Note 1] - Reference Attachment 1.

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Table 11, Thermoluminescent Dosimeters - Inner Ring Analysis: Gamma Dose Units: mrem

2nd Qtr 3rd Qtr 4th Qtr Annual Station 1st Qtr [2021] [2021] [2021] [2021] Mean

[2021]

1 8.0 8.1 9.4 9.3 8.7

2 7.5 8.1 8.9 9.1 8.4

3 5.8 5.4 5.9 6.0 5.8

4 8.3 7.5 7.9 9.1 8.2

56[Note 1] 9.0 8.7 10.1 10 9.5

108 8.2 7.4 8.9 9.0 8.4

109 8.0 7.6 8.4 8.7 8.2

110 8.1 7.2 7.9 8.4 7.9

145 7.6 7.5 8.0 8.6 7.9

146 7.5 7.2 7.4 7.9 7.5

147 6.8 6.3 8.0 7.1 7.1

148 8.1 7.8 8.3 8.3 8.1

149 6.8 7.4 7.4 8.0 7.4

150 0.0[Note 2] 9.0 9.6 9.7 7.1

151 7.8 7.2 8.8 9.4 8.3

152 6.1 5.9 7.1 7.8 6.7

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

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Table 12, Thermoluminescent Dosimeters - Special Interest Areas Analysis: Gamma Dose Units: mrem

Station 1st Qtr [2021] 2nd Qtr [2021] 3rd Qtr [2021] 4th Qtr [2021] Annual Mean [2021]

6 7.1 7.6 6.9 8.1 7.4

111 5.7 6.3 5.3 5.9 5.8

116 8.6 8.1 7.9 8.3 8.2

125 5.1 4.9 5.1 6.0 5.3 127 7.3 0.0 [Note 2] 7.4 8.4 7.7

137 [Note 1] 7.9 8.5 0.0 [Note 2] 8.9 8.4

153 7.1 7.7 8.4 7.9 7.8

[Note 1] - Station with highest annual mean.

[Note 2] - Reference Attachment 1.

Table 13, Thermoluminescent Dosimeters - Control Analysis: Gamma Dose Units: mrem

Station 1st Qtr [2021] 2nd Qtr [2021] 3rd Qtr [2021] 4th Qtr [2021] Annual Mean [2021]

7 6.1 6.0 6.5 7.3 6.5

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Table 15, Surface Water - Tritium

Analysis: H-3 Units: pCi/L

Location Start Date End Date H-3

REQUIRED LLD 3000

Station 8 (Indicator) 12/31/2020 03/31/2021 1120

Station 10 (Control) 12/31/2020 03/31/2021 < 372

Station 8 (Indicator) 03/31/2021 06/30/2021 477

Station 10 (Control) 03/31/2021 06/30/2021 < 336

Station 8 (Indicator) 06/30/2021 09/30/2021 < 378

Station 10 (Control) 06/30/2021 09/30/2021 < 384

Station 8 (Indicator) 09/30/2021 12/31/2021 465

Station 10 (Control) 09/30/2021 12/31/2021 < 361

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Table 22, Groundwater - Tritium

Analysis: H-3 Units: pCi/L

Location Collection Date H-3

REQUIRED LLD 3000

Station 58 (Control) 3/10/2021 < 369

Station 62 (Control) 3/09/2021 < 364

Station 63 (Indicator) 3/09/2021 < 358

Station 64 (Indicator) 3/10/2021 < 350

Station 58 (Control) 6/08/2021 < 394

Station 62 (Control) 6/08/2021 < 380

Station 63 (Indicator) 6/08/2021 < 375

Station 64 (Indicator) 6/09/2021 < 387

Station 58 (Control) 9/07/2021 < 355

Station 62 (Control) 9/07/2021 < 348

Station 63 (Indicator) 9/07/2021 < 347

Station 64 (Indicator) 9/08/2021 < 360

Station 58 (Control) 12/08/2021 < 320

Station 62 (Control) 12/08/2021 < 325

Station 63 (Indicator) 12/08/2021 < 330

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1.0

SUMMARY

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

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

1. Analytics Evaluation Criteria

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

2. ERA Evaluation Criteria

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

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

3. DOE Evaluation Criteria

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

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

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

of the reference value.

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

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

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

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

a. The ERA millirad (MRAD) March 2021 Water Fe-55 result was evaluated as Not Acceptable. The reported value for Fe-55 was 579 pCi/L and the known result was 275 pCi/L (acceptance range 162 - 400 pCi/L). When reviewing the original sample data, it was found that the carrier yield was 52.6% (lower than typical water samples). Looking at the etched plate that was counted, it appeared that some loss of sample could have occurred. The sample was logged for reanalysis and used as the workgroup duplicate. The results were acceptable at 197 and 221 respectively. Yields were 97.4% and 105.7% and the plated samples were centered with no apparent loss of sample. The loss of sample during plating resulted in a low yield which produced an artificially high sample result. (NCR 21-01)
b. The MAPEP February 2021 AP Gross Alpha result was evaluated as Not Acceptable. The reported value was 0.371 Bq/sample and the known result was 1.77 Bq/sample (acceptance range 0.53 - 3.01 Bq/sample). A similar failure had occurred several years prior due to the filter being placed with the wrong side up on the detector. At that time, a small dot was placed on the top of the filter prior to removal from the package to indicate the correct side for counting. The current sample was still in the detector when the result was received (dot side facing the detector). The sample was recounted with a similar result and was flipped and recounted. The flipped result was 0.661 Bq/sample, within the acceptable range. Because TBE cannot rely on receiving correct packaging from the provider, MAPEP AP cross-checks will be counted on both sides going forward. NOTE: The August sample had the same packaging issue (upside down). (NCR 21-02)
c. The MAPEP February 2021 soil Ni-63 was evaluated as Not Acceptable.

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

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

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

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

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e. The ERA October 2021 water Tritium result was evaluated as Not Acceptable. The reported value was 13,800 pCi/L and the known was 17,200 pCi/L (acceptance range 15,000 - 18,900 pCi/L). The 2-sigma error was 1,430, placing the result within the acceptable range. TBEs internal QC acceptance is 70% - 130%, while ERAs for this sample was 87% - 110%. All QA was reviewed with no anomalies. A Quick Response follow-up cross-check was analyzed with a result of 17,500 pCi/L (known 17,800 pCi/L). (NCR 21-11)
f. The MAPEP August 2021 soil Ni-63 result was evaluated as Not Acceptable. The reported value was 546 Bq/kg and the known result was 1,280 Bq/kg (acceptance range 896 - 1,664 Bq/kg). All QC was reviewed, and no anomalies found. The procedure revision to remove added MAPAP interferences was ineffective for this sample. No client soil matrix samples were analyzed for Ni-63 in 2020 or 2021. The root cause investigation is still ongoing at this time. (NCR 21-13)
g. The ERA December 2021 Quick Response Water Gross Beta result was evaluated as Not Acceptable. The reported value was 47.6 pCi/L and the known was 39.8 pCi/L or 120% of the known (acceptance range of 26.4 -

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

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

(NCR 21-14)

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

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ENVIRONMENTAL DOSIMETRY COMPANY ANNUAL QUALITY ASSURANCE STATUS REPORT January - December 2021 10 Ashton Lane Sterling, MA 01564 Plant: Arkansas Nuclear One Year: 2021 Page 49 of 65 Annual Radiological Environmental Operating Report

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2.0 EXECUTIVE

SUMMARY

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

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

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

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

3.0 INTRODUCTION

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

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

3.1 QC Program

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

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

3.2 QA Program

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

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4.0 PERFORMANCE EVALUATION CRITERIA

4.1 Acceptance Criteria for Internal Evaluations

1. Bias

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

HH 100 ii H i

Where:

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

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

2. Mean Bias

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

HH 1 ii 100 Hn i

Where:

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

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

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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 i th dosimeter is:

HH 1 ii 100 Hn i

Where:

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

Hi = the mean reported exposure; i.e.

n = the number of dosimeters in the test group

4. EDC Internal Tolerance Limits

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

4.2 QC Investigation Criteria and Result Reporting

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

1. No investigation is necessary when an individual QC result falls outside the QC performance criteria for accuracy.
2. Investigations are initiated when the mean of a QC processing batch is outside the performance criterion for bias.

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4.3 Reporting of Environmental Dosimetry Results to EDC Customers

1. All results are to be reported in a timely fashion.
2. If the QA Officer determines that an investigation is required for a process, the results shall be issued as normal. If the QC results prompting the investigation have a mean bias from the known of greater than +/-20%, the results shall be issued with a note indicating that they may be updated in the future, pending resolution of a QA issue.
3. Environmental dosimetry results do not require updating if the investigation has shown that the mean bias between the original results and the corrected results, based on applicable correction factors from the investigation, does not exceed +/-20%.

5.0 DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2021

5.1 General Discussion

Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4.

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

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

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

5.2 Result Trending

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

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

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6.0 STATUS OF EDC CONDITION REPORTS (CR)

No condition reports were issued during this annual period.

7.0 STATUS OF AUDITS/ASSESSMENTS

1. Internal

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

2. External

None.

8.0 PROCEDURES AND MANUALS REVISED DURING JANUARY - DECEMBER 2021

Several procedures were reissued with no changes as part of the 5-year review cycle.

9.0 CONCLUSION

AND RECOMMENDATIONS

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

10.0 REFERENCES

1. EDC Quality Control and Audit Assessment Schedule, 2021.
2. EDC Manual 1, Quality System Manual, Rev. 4, September 28, 2020.

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TABLE 1

PERCENTAGE OF INDIVIDUAL DOSIMETERS THAT PASSED EDC INTERNAL CRITERIA JANUARY - DECEMBER 2021(1), (2)

Dosimeter Type Number Tested % Passed Bias % Passed Precision Criteria Criteria

Panasonic Environmental 72 100 100

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

(2)Environmental dosimeter results are free in air.

TABLE 2

MEAN DOSIMETER ANALYSES (N=6)

JANUARY - DECEMBER 2021(1), (2)

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

% 15%

5/04/2021 33 0.6 0.9 Pass 5/06/2021 120 -0.2 1.4 Pass 5/26/2021 53 -3.8 1.6 Pass 7/27/2021 67 2.8 1.4 Pass 8/04/2021 91 -1.8 2.3 Pass 9/14/2021 47 -0.2 2.3 Pass 11/01/2021 28 3.7 0.6 Pass 11/03/2021 74 1.9 1.9 Pass 11/09/2021 103 1.1 1.1 Pass 01/26/2022 37 2.6 1.9 Pass 01/30/2022 85 -4.2 1.1 Pass 02/06/2022 58 2.9 1.2 Pass

(1)This table summarizes results of tests conducted by EDC for TLDs issued in 2021.

(2)Environmental dosimeter results are free in air.

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TABLE 3

SUMMARY

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

Issuance Period Client Mean Standard Pass / Fail Bias % Deviation %

1st Qtr. 2021 SONGS -3.8 1.4 Pass 1st Qtr. 2021 SONGS -4.7 1.1 Pass 2nd Qtr.2021 Seabrook 3.1 1.0 Pass 3rd Qtr. 2021 Millstone -4.7 1.4 Pass 4th Qtr.2021 PSEG(PNNL) 50mR 1.3 0.8 Pass 4th Qtr.2021 PSEG(PNNL) 100mR 1.8 0.8 Pass 4th Qtr.2021 PSEG(PNNL) 150mR -0.6 0.5 Pass 4th Qtr.2021 PSEG(PNNL) 200mR -2.6 2.0 Pass 4th Qtr.2021 Seabrook 2.6 1.4 Pass

(1) Performance criteria are +/- 15%.

(2) Blind spike irradiations using Cs-137

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APPENDIX A

DOSIMETRY QUALITY CONTROL TRENDING GRAPHS

ISSUE PERIOD JANAURY - DECEMBER 2021

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