3F0423-02, 2022 Annual Radioactive Effluent Release Report

2022 Annual Radioactive Effluent Release Report

ML23108A264
Person / Time
Site:	Crystal River
Issue date:	04/18/2023
From:	Dixon P ADP CR3
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
3F0423-02
Download: ML23108A264 (1)

Text

A April 18, 2023 3F0423-02 ADPCR3,LLC U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Crystal River Nuclear Plant 2760 South Falkenburg Rd Riverview, FL 33578 Docket 50-302 Docket 72-1035 Operating License No. DPR-72 10 CFR 50.36a(a)(2)

ODCM

Subject:

Crystal River Unit 3 - 2022 Annual Radioactive Effluent Release Report

Dear Sir or Madam:

ADP CR3, LLC, hereby provides the 2022 Radioactive Effluent Release Report for Crystal River Unit 3 (CR3) in accordance with 10 CFR 50.36a(a)(2) and the Offsite Dose Calculation Manual (ODCM). The attached report (Attachment 1) includes a summary of the quantities of radioactive liquid and gaseous effluents, and solid waste released from the CR3 site during 2022. The data provided in this report is consistent with the objectives outlined in the ODCM and the Process Control Program (PCP), and is in conformance with 10 CFR 50, Appendix I, Section IV.B.1.

A CR3 administrative procedure requires submittal of licensee initiated changes to the ODCM as part of the Radioactive Effluent Release Report for the period of the report in which any changes were made. The ODCM was revised in 2022; changes are described in this report and a copy of the ODCM is attached (Attachment 2). The PCP was not revised in 2022.

This letter contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Ms. Holly Van Sicklen, Licensing Manager, at (352) 634-1028.

Sincerely, Phyllis A. Dixon ISFSI Manager PAD/hvs : 2022 Annual Radioactive Effluent Release Report : CR3 Offsite Dose Calculation Manual cc:

NMSS Project Manager Regional Administrator, Region I

ADP CR3, LLC DOCKET NUMBER 50-302 / 72-1035 LICENSE NUMBER DPR-72 ATTACHMENT 1 2022 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 2022 CR3 ADP, LLC CRYSTAL RIVER UNIT 3 Facility Operating License No. DPR-72 Docket No. 50-302

CONTENTS Introduction....................................................................................................................

1 Tabular Data Summaries Gaseous Effluents - Quarters 1 to 4...............................................................

2 Liquid Effluents - Quarters 1 to 4....................................................................

7 Batch Release Summary.............................................................................................. 10 Abnormal Release Summary........................................................................................ 12 Dose Evaluation............................................................................................................ 14 Appendix I Dose Summary........................................................................................... 16 Radwaste Shipments.................................................................................................... 18 Unplanned Releases..................................................................................................... 19 Radioactive Waste Treatment Systems....................................................................... 19 Annual Land Use Census............................................................................................. 19 Effluent Monitor Instrument Operability........................................................................ 19 Assessment of Direct Radiation from ISFSI................................................................. 19 Meteorology Instrumentation Evaluation...................................................................... 20 ODCM Changes............................................................................................................ 20 Process Control Program Changes.............................................................................. 21 Carbon-14 Evaluation................................................................................................... 21 NEI 07-07 Required Data.............................................................................................. 21 Additional Information on CR3 Plant Shutdown........................................................... 23

1 INTRODUCTION This report is submitted as required by procedure CP-500, section 4.2.1.b. All dose limits have been met. There were no NEI 07-07 groundwater protection reportable events in 2022.

The scope of this report includes:

A summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant.

Quarterly and annual dose summaries.

A list and description of unplanned releases to unrestricted areas (there were none in 2022).

A description of any changes to the:

Process Control Program (PCP), and Offsite Dose Calculation Manual (ODCM).

Significant changes to any radioactive waste treatment system.

A list of new dose calculation location changes identified by the annual land-use census.

Information relating to effluent monitors or required supporting instrumentation being inoperable for 30 or more days.

Information required to be included in this report per NEI 07-07 Industry Ground Water Protection Initiative-Final Guidance Document issued in August 2007.

Note for reporting purposes, N/D = Not Detected.

2 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 1A - Regulatory Guide 1.21 Gaseous Effluents - Summation of All Releases Unit: 3 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Est. Total

% Error A. Fission & Activation Gases

1. Total Release Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.00E+01

2. Average Release Rate for Period uCi/sec 0.00E+00 0.00E+00 0.00E+00 0.00E+00 B. Iodines

1. Total Iodine-131 Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.00E+01

2. Average Release Rate for Period uCi/sec 0.00E+00 0.00E+00 0.00E+00 0.00E+00 C. Particulates

1. Particulates with half-lives > 8 days Curies 2.98E-07 0.00E+00 0.00E+00 0.00E+00 3.00E+01

2. Average Release Rate for Period uCi/sec 3.83E-08 0.00E+00 0.00E+00 0.00E+00

3. Gross Alpha Radioactivity Curies 0.00E+00 0.00E+00 0.00+00 0.00E+00 D. Tritium

1. Total Release Curies 6.29E-02 1.18E-01 1.19E-01 4.76E-02 3.00E+01

2. Average Release Rate for Period uCi/sec 8.08E-03 1.50E-02 1.50E-02 5.99E-03

3 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 1B - Regulatory Guide 1.21 Gaseous Effluents - Elevated Batch Mode Unit: 3 (This Table Does Not Apply to Crystal River Unit 3)

Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Gases Total Curies N/D N/D N/D N/D Iodines Total Curies N/D N/D N/D N/D Particulates Total Curies N/D N/D N/D N/D H-3 Curies N/D N/D N/D N/D Gross Alpha Curies N/D N/D N/D N/D

4 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 1B - (Continued) Regulatory Guide 1.21 Gaseous Effluents - Elevated Continuous Mode Unit: 3 (This Table Does Not Apply to Crystal River Unit 3)

Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Gases Total Curies N/D N/D N/D N/D Iodines Total Curies N/D N/D N/D N/D Particulates Total Curies N/D N/D N/D N/D H-3 Curies N/D N/D N/D N/D Gross Alpha Curies N/D N/D N/D N/D

5 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 1C - Regulatory Guide 1.21 Gaseous Effluents - Ground Batch Mode Unit: 3 (This Table Does Not Apply to Crystal River Unit 3)

Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Gases Total Curies N/D N/D N/D N/D Iodines Total Curies N/D N/D N/D N/D Particulates Total Curies N/D N/D N/D N/D H-3 Curies N/D N/D N/D N/D Gross Alpha Curies N/D N/D N/D N/D

6 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 1C - (Continued) Regulatory Guide 1.21 Gaseous Effluents - Ground Continuous Mode Unit: 3 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Gases Total Curies N/D N/D N/D N/D Iodines Total Curies N/D N/D N/D N/D Particulates Co-60 Curies N/D N/D N/D N/D Cs-137 Curies 2.98E-07 N/D N/D N/D Total Curies 2.98E-07 N/D N/D N/D H-3 Curies 6.29E-02 1.18E-01 1.19E-01 4.76E-02 Gross Alpha Curies N/D N/D N/D N/D

7 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 2A - Regulatory Guide 1.21 Liquid Effluents - Summation of All Releases Unit: 3 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Est. Total

% Error A. Fission & Activation Products

1. Total Release (not including tritium, gases, alpha)

Curies 3.68E-02 2.20E-02 7.95E-03 3.34E-03 2.50E+01

2. Average diluted concentration during period uCi/ml 2.78E-09 1.64E-09 5.81E-10 2.45E-10

3. Percent of Applicable Limit 6.17E-03 2.71E-03 1.99E-03 5.66E-04 B. Tritium

1. Total Release Curies 1.05E+00 1.19E+00 1.66E-01 3.68E-03 3.00E+01

2. Average diluted concentration during period uCi/ml 7.93E-08 8.92E-08 1.21E-08 2.70E-10

3. Percent of Applicable Limit 7.93E-04 8.92E-04 1.21E-04 2.70E-06 C. Dissolved and Entrained Gases

1. Total Release Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 2.50E+01

2. Average diluted concentration during period uCi/ml 0.00E+00 0.00E+00 0.00E+00 0.00E+00

3. Percent of Applicable Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 D. Gross Alpha Radioactivity

1. Total Release Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.00E+01 E. Waste Volume Released (Pre-Dilution)

Liters 2.76E+05 5.57E+05 5.26E+05 2.78E+05 1.00E+01 F.

Dilution Water Volume During Period Liters 1.33E+10 1.34E+10 1.37E+10 1.36E+10 1.00E+01

8 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 2B - Regulatory Guide 1.21 Liquid Effluents - Batch Mode Unit: 3 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Products Co-60 Curies 2.47E-03 2.19E-03 3.92E-03 1.19E-03 Ni-63 Curies 5.93E-03 1.68E-02 2.47E-03 1.79E-03 Fe-55 Curies 2.14E-02 2.98E-04 1.71E-04 N/D Cs-137 Curies 7.07E-03 2.73E-03 1.39E-03 3.54E-04 Total Curies 3.68E-02 2.20E-02 7.95E-03 3.34E-03 Dissolved and Entrained Gases Total Curies N/D N/D N/D N/D H-3 Curies 1.05E+00 1.19E+00 1.66E-01 3.68E-03 Gross Alpha Curies N/D N/D N/D N/D

9 EFFLUENT and WASTE DISPOSAL REPORT-2022 Table 2B - (Continued) Regulatory Guide 1.21 Liquid Effluents - Continuous Mode Unit: 3 (This Table Does Not Apply to Crystal River Unit 3)

Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Fission & Activation Products Total Curies N/D N/D N/D N/D Dissolved and Entrained Gases Total Curies N/D N/D N/D N/D H-3 Curies N/D N/D N/D N/D Gross Alpha Curies N/D N/D N/D N/D

10 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Gaseous Batch Release Summary Unit: 3 (This Table Does Not Apply to Crystal River Unit 3)

Jan - Jun Jul - Dec Number of Batch Releases 0

0 Total Time Period for Batch Releases 0.00E+00 min 0.00E+00 min Maximum Time Period for a Batch Release 0.00E+00 min 0.00E+00 min Average Time Period for a Batch Release 0.00E+00 min 0.00E+00 min Minimum Time Period for a Batch Release 0.00E+00 min 0.00E+00 min

11 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Liquid Batch Release Summary Unit: 3 Jan - Jun Jul - Dec Number of Batch Releases 3

3 Total Time Period for Batch Releases 5.73E+03 min 2.01E+02 min Maximum Time Period for a Batch Release 3.83E+03 min 8.32E+02 min Average Time Period for a Batch Release 1.91E+03 min 6.71E+02 min Minimum Time Period for a Batch Release 9.20E+02 min 5.90E+02 min Average Stream Flow During Release Periods 2.70E+04 gpm 2.70E+04 gpm

12 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Gaseous Abnormal Release Summary Unit: 3 Jan - Jun Jul - Dec Number of Abnormal Releases 0

0 Total Time Period for Abnormal Releases 0.00E+00 min 0.00E+00 min Maximum Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Average Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Minimum Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Total Activity for Abnormal Releases 0.00E+00 Ci 0.00E+00 Ci

13 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Liquid Abnormal Release Summary Unit: 3 Jan - Jun Jul - Dec Number of Abnormal Releases 0

0 Total Time Period for Abnormal Releases 0.00E+00 min 0.00E+00 min Maximum Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Average Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Minimum Time Period for an Abnormal Release 0.00E+00 min 0.00E+00 min Total Activity for Abnormal Releases 0.00E+00 Ci 0.00E+00 Ci

14 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Gaseous NNG Organ Dose Unit: 3 Receptor Name: Child at Site Boundary 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Calendar Year Organ Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Bone 2.93E-03 3.90E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Liver 2.91E-03 3.88E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Total Body 2.61E-03 3.48E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Thyroid 2.56E-03 3.41E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Kidney 2.68E-03 3.57E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Lung 2.60E-03 3.47E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 GI-Lli 2.56E-03 3.42E-03 4.53E-04 6.03E-03 4.57E-04 6.09E-03 1.82E-04 2.43E-03 1.38E-03 9.23E-03 Maximum Organ was BONE. All units mrem.

15 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Liquid Organ & Whole Body Dose Unit: 3 Receptor Name: Adult at Site Boundary 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Calendar Year Organ Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Dose

% of ODCM Limit Bone 1.67E-03 3.34E-02 5.21E-03 1.04E-01 2.47E-04 4.95E-03 6.65E-05 1.33E-03 7.19E-03 7.19E-02 Liver 9.98E-04 2.00E-02 6.27E-04 1.25E-02 6.56E-05 1.31E-03 9.01E-06 1.80E-04 1.70E-03 1.70E-02 Total Body 2.90E-04 1.93E-02 3.61E-04 2.41E-02 5.43E-05 3.62E-03 7.45E-06 4.97E-04 7.13E-04 2.38E-02 Thyroid 3.42E-07 6.84E-06 2.01E-06 4.02E-05 8.07E-08 1.61E-06 7.48E-10 1.50E-08 2.43E-06 2.43E-05 Kidney 3.36E-05 6.71E-04 6.83E-05 1.37E-03 9.85E-06 1.97E-04 1.04E-06 2.08E-05 1.13E-04 1.13E-03 Lung 4.97E-04 9.94E-03 5.91E-05 1.18E-03 9.15E-06 1.83E-04 3.47E-07 6.93E-06 5.66E-04 5.56E-03 GI-Lli 5.99E-04 1.20E-02 5.40E-04 1.08E-02 2.30E-04 4.59E-03 2.90E-05 5.80E-04 1.40E-03 1.40E-02 All units mrem Liquid Effluent Dose Limits Total Body:

1.5 mrem/quarter, 3 mrem/year Any Organ:

5 mrem/quarter, 10 mrem/year

16 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 Liquid App I Dose Assessment Unit: 3 Adult at Site Boundary Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Maximum Organ Dose mrem 1.67E-03 5.21E-03 2.47E-04 6.65E-05 7.19E-03 ODCM Limit mrem 5.00 5.00 5.00 5.00 10.00

% of ODCM Limit 3.34E-02 1.04E-01 4.95E-03 1.33E-03 7.19E-02 Maximum Organ was Bone Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Total Body mrem 2.90E-04 3.61E-04 5.43E-05 7.45E-06 7.13E-04 ODCM Limit mrem 1.50 1.50 1.50 1.50 3.00

% of ODCM Limit 1.93E-02 2.41E-02 3.62E-03 4.97E-04 2.38E-02

17 EFFLUENT and WASTE DISPOSAL REPORT-2022 Regulatory Guide 1.21 App I Dose Assessment Unit: 3 Airborne Noble Gas Doses Child Site Boundary Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Beta Air mRad 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 ODCM Limit mRad 10.00 10.00 10.00 10.00 20.00

% of ODCM Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Gamma Air mRad 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 ODCM Limit mRad 5.00 5.00 5.00 5.00 10.00

% of ODCM Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Airborne Iodine/ Particulates /Tritium Doses Child Site Boundary Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Annual Critical Organ - Bone mrem 2.93E-04 4.53E-04 4.57E-04 1.82E-04 1.38E-03 ODCM Limit mrem 7.50 7.50 7.50 7.50 15.00

% of ODCM Limit 3.90E-03 6.03E-03 6.09E-03 2.43E-03 9.23E-03 Gaseous Release Dose Summary - There was no measurable noble gases released in 2021 due to the plant shutdown in 2009. All fuel has since been moved to the ISFSI pad.

Gaseous Effluent Dose Limits Gamma Air Dose: 5 mrad/quarter, 10 mrad/year Beta Air Dose: 10 mrad/quarter, 20 mrad/year Any Organ:

7.5 mrem/quarter, 15 mrem/year

18 TABLE 3 EFFLUENT and WASTE DISPOSAL REPORT-2022 SOLID WASTE AND IRRADIATED FUEL SHIPMENTS A.

SOLID WASTE SHIPPED OFFSITE FOR PROCESSING OR BURIAL (Non-irradiated fuel)

1.

Type of waste Unit 12-month period Est. Total Error %

a.

Spent resins, filter sludge, evaporator bottoms, etc.

m3 Ci 1.77E+1 7.43E+1 25

b.

Dry compressible waste, contaminated equipment, etc.

m3 Ci 3.40E+3 2.78E+0 25

c.

Irradiated components, control rods, etc.

m3 Ci 0

0 25

d.

Other - Garnet cutting fines used for Reactor Pressure Vessel internals segmentation.

m3 Ci 4.59E+0 5.46E+1 25

2.

Estimate of major nuclide composition (by type of waste in %) *

a.

Fe-55 20.23 Co-60 48.84 Ni-63 30.59 NA NA

b.

C-14 1.45 Fe-55 5.03 Co-60 59.38 Ni-63 28.72 Cs-137 4.74 NA NA

c.

NA NA NA

d.

Fe-55 20.90 Co-60 50.11 Ni-63 28.71 NA NA

• Curie values and principal radionuclides are estimates based on a combination of direct and indirect methods.

3.

Solid Waste Disposition Number of Shipments Mode of Transportation Destination (Truck Shipment) 10.00 10 Interstate Ventures Waste Control Specialists 3

Landstar Waste Control Specialists (Rail Shipments) 54 Florida Northern Railroad Waste Control Specialists B.

IRRADIATED FUEL SHIPMENTS (Disposition)

Number of Shipments Mode of Transportation Destination 0

N/A N/A

19 Unplanned Releases There were no unplanned releases in 2022.

Radioactive Waste Treatment Systems There were no changes to the radwaste liquid treatment system in 2022. Contaminated water was processed through the NUS demineralizer system prior to release via the RC Bleed Tanks in the Auxiliary Building.

Annual Land Use Census The 2022 land-use census did not identify any new dose calculation locations.

Effluent Monitor Instrument Operability For the year 2022, there were two gaseous effluent pathways - one for the Reactor Building and one for the Auxiliary Building - same as in 2021.The particulate filter sample is collected continuously over a period of about one month whereas the tritium sample is collected every six months as a grab sample with a typical collection time of around 1-2 hours. There were no documented occurrences of prolonged effluent monitor inoperability in 2022.

Liquid effluents are released in a batch mode from specific tanks and are not radiologically monitored as the release is occurring. Instead, the tank is fully characterized prior to release and the release rate is verified to ensure all applicable ODCM and procedural limits are met.

Assessment of Direct Radiation from ISFSI The Independent Spent Fuel Storage Installation (ISFSI) was loaded with spent fuel beginning June 2017 and completed January 2018. Calculations performed prior to fuel movement into dry storage, documents a conservative annual dose estimate at 700 meters from the ISFSI pad of approximately 0.06 mrem gamma and neutron (Ref. N16-0003, Table 11-17). The gamma component contributes most of the dose. A small added gamma dose contribution (< 1%) from Greater than Class C (Ref. N18-0002) is compensated for by conservatism in the spent fuel dose calculation. The nearest non-resident member of the public in the unrestricted area works at the Mariculture Center, which is approximately 1200 meters from the center of the ISFSI pad. The nearest full-time resident is over 3 miles away. The small gamma dose (direct and skyshine) from ISFSI in the unrestricted area is not distinguishable from normal background. REMP TLD results for 2022 show no detectable changes in dose beyond the expected fluctuations. Annual total dose from CR3 effluents, also conservatively estimated, is also a small fraction of 1 mrem. Therefore, the maximum combined dose to a real individual in the unrestricted area is < 1 mrem, meeting the annual total dose limit of 25 mrem imposed by 40 CFR 190 and 10 CFR 72.

20 Meteorology Instrumentation Evaluation In 2015 the metrology tower was abandoned. It was concluded that an on-site meteorological data collection system was no longer needed at CR3 to support its effluents program because:

There is no explicit regulatory requirement or license condition to maintain an on-site meteorological program for a decommissioning unit (or facility), and From a technical perspective, a reasonably conservative estimate of dose to a member of the public in the unrestricted area can be performed without periodically assessing changes in atmospheric dispersion and deposition based on our low site source term and the conservative nature of the dispersion factors.

Offsite Dose Calculation Manual (ODCM) Changes The ODCM was revised in 2022 to revision #42 under document change number WCDRR2022-001 to support various system and facility changes. The following changes were incorporated:

PAGE CHANGE Cover Page Revised titles and reviewer and preparer designations ii & iii TOC: Deleted Methodologies Section 3.0. Revised List of Tables and List of Figures to reflect nomenclature change and deletion of one map 3

Corrected specification number in Surveillance Requirement 2.2.2 5

Table 2-1: Edited footnote d to add recirculation volume requirement formerly in Section 3.0, Sampling Methods, now deleted.

12 NOTE: Deleted sentence about ISFSI dose calculation and dose results in the note.

The purpose of the note (not part of the original specification) was to relate 10CFR72.104 public dose requirements to the dose requirements of specification 2.7 which originate with 10CFR190 (Ref. Audit Observation #3: CR-2021-000145).

14 Table 2-3: Revised TLD location descriptions and deleted out of date note in Direct Radiation section 16 Table 2-4: Deleted footnote (b) as it applied to short-lived radionuclides previously listed but removed in revision 41 17 & 18 Table 2-5: Deleted old footnote (c) as it applied to short-lived radionuclides previously listed but removed in revision 41. Footnotes d and e changed to c and d.

25 Edited Flow Rates section for clarity, and deleted reference to Seawater Room Exhaust fans which are no longer in service.

27 Deleted dose projection methodology for gaseous releases as the specification for dose projection was removed in a prior revision.

28 Section 3.0: Deleted, as information is contained in Tables 2-1 and 2-2 or footnotes.

42 Table 5-1: Updated sample station descriptions and distances

21 PAGE CHANGE 44 & 45 Tables 5-3 & 5-4: Edited table titles and updated distances 46 & 47 Figures 5.1 & 5.2: Updated to provide more precise sample station locations and to consolidate direction radiation (TLD) stations with other sample media. This resulted in one map for the site (and nearby areas) and one map for areas more distant from site. Figure 5.3: Deleted (old page 48). TLD station C78 in Figure 5.3 is not in new Figure 5.1 as it was deleted from the program (Table 2-3) in revision 38 of the ODCM.

48 Figure 5.4 designation changed to Figure 5.3 to account for deletion of prior Figure 5.3.

Note: Punctuation and spelling corrections not listed Process Control Program (PCP) Changes No changes to the PCP document were made in 2022.

Carbon-14 Evaluation The plant has not operated since 2009 so there is no source term generation for carbon-14 production. Since the decision to retire the facility has been announced, there will be no C-14 source term generated ever again at CR-3.

Nuclear Electric Institute (NEI) Required Information The following environmental data is being included in this report per objective 2.4.b.i and 2.4.b.ii of NEI 07-07 Industry Ground Water Protection Initiative, as this groundwater well data is used to assist in evaluation of groundwater at the site, but is not officially included in the Radiological Environmental Monitoring Program (REMP) or the Offsite Dose Calculation Manual (ODCM).

These two graphs are of tritium measurements in units of pCi/liter, taken from groundwater monitoring wells located west of CR-3 on either side (north and south) of the site settling percolation ponds. There are many other groundwater monitoring wells included in the REMP that are used for evaluating the groundwater in the vicinity of the CR-3 site. These two wells are providing supplemental information. The LLD for tritium measurement of these environmental well samples is ~180 pCi/liter. Measurements over the past several years have not showed tritium above LLD.

22 0

100 200 300 400 500 600 10/10/06 07/06/09 04/01/12 12/27/14 09/22/17 06/18/20 03/15/23 pCi/l Tritium Measurements GW Well # MWC-IF2 All measurements LLD after 2012 0

200 400 600 800 1000 1200 1400 10/10/06 07/06/09 04/01/12 12/27/14 09/22/17 06/18/20 03/15/23 pCi/l Tritium Measurements GW Well # MWC-27 All measurements LLD after 2010

23 Additional Information On February 5, 2013, Duke Energy decided to permanently retire Crystal River Unit 3. The decision was made due to the risk associated with repairing the containment buildings delaminated concrete wall. The company placed the facility in a SAFSTOR status until Sept 30th, 2020. Beginning on October 1st 2020, the site radiological license was transferred from Duke Energy to ADP CR3, LLC and active decommissioning commenced. Also in 2020, CR3 received approval from the NRC to reduce the licensed area of the site to 884 acres as part of the Partial Site Release project. This had no effect on any REMP sample location or REMP sample frequency. Additionally, all spent nuclear fuel was transferred from the spent fuel pool to the onsite Independent Spent Fuel Storage Installation (ISFSI) for dry storage in January 2018 and most plant systems have been abandoned.

ADP CR3, LLC DOCKET NUMBER 50-302 / 72-1035 LICENSE NUMBER DPR-72 ATTACHMENT 2 CR3 OFFSITE DOSE CALCULATION MANUAL

CRYSTAL RIVER UNIT 3 OFF-SITE DOSE CALCULATION MANUAL WCDRR-2022-001 PREPARED BY: Pete Ezzell Radiological Engineer TECHNICAL REVIEW BY: Chuck Burtoff INDEPENDENT SAFETY REVIEW BY: Guy Mccallum APPROVED BY: Bryant Akins __;;~.gw,..::~Li..lk~;z::::~---

APPROVED BY: Billy Reid

. anager

/

DATE: 0 "J /t J/ /.u; 2. 2.

l 7

REVISION: _,R_

I

INTRODUCTION The Off-Site Dose Calculation Manual (ODCM) is provided to support implementation of the Crystal River Unit 3 radiological effluent controls. The ODCM is divided into two parts.

Part I contains the specifications for liquid and gaseous radiological effluents and the radiological environmental monitoring program which were relocated from the Technical Specifications in accordance with the provisions of Generic Letter 89-01 issued by the NRC in January 1989. Part II of the ODCM contains the calculation methods used in determining the dose to members of the public resulting from routine radioactive effluents released from Crystal River Unit 3.

The ODCM shall become effective after acceptance by the Decommissioning Program Manager and the Manager of Radiation Protection and Chemistry, and in accordance with plant procedures. Changes to the ODCM shall be documented and records of reviews performed shall be retained. This documentation shall contain sufficient information to support the change (including analyses or evaluations), and a determination that the change will maintain the level of radioactive effluent control required by the regulations listed in CP-500 and not adversely impact the accuracy or reliability of effluent or dose calculations.

Changes shall be submitted to the NRC in the form of a complete and legible copy of the entire ODCM as part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g. month/year) the change was implemented.

TABLE OF CONTENTS PAGE Off-Site Dose Calculation Manual Rev. 42 Page i PART I - SPECIFICATIONS 1.0 DEFINITIONS.................................................................................................................. 1

Frequency............................................................................................................. 1

Liquid Radwaste Treatment System...................................................................... 1

Member Of The Public.......................................................................................... 1

Offsite Dose Calculation Manual (ODCM)............................................................. 1

Site Boundary........................................................................................................ 1

Unplanned Release............................................................................................... 1

Unrestricted Area.................................................................................................. 2 2.0 SPECIFICATIONS........................................................................................................... 2

LIQUID RADWASTE TREATMENT SYSTEM...................................................... 2

Liquid Effluents Concentration.............................................................................. 3

Liquid Effluents - Dose.......................................................................................... 6

Gaseous Effluents - Dose Rate............................................................................ 7

Dose - Noble Gases.............................................................................................. 7

Dose - Tritium And Radioactive Particulates...................................................... 11

Total Dose........................................................................................................... 12

Radiological Environmental Monitoring............................................................... 13

Land Use Census................................................................................................ 19

Interlaboratory Comparison Program.................................................................. 20 3.0 SPECIFICATION BASES............................................................................................... 21

Liquid Radwaste Treatment System Basis.......................................................... 21

Liquid Effluents Concentration Basis................................................................... 21

Liquid Effluents Dose Basis................................................................................. 21

Gas Effluents Dose RATE Basis......................................................................... 21

Gaseous Effluents Dose: Tritium And Radioactive Particulate Basis.................. 22

Total Dose Basis................................................................................................. 23

Radiological Environmental Monitoring Program Basis....................................... 23

Radiological Environmental Monitoring Program Land Use Census Basis................................................................................................................... 23

Radiological Environmental Monitoring Interlaboratory Comparison Program Basis..................................................................................................... 23

TABLE OF CONTENTS PAGE Off-Site Dose Calculation Manual Rev. 42 Page ii PART II - METHODOLOGIES................................................................................................................. 24 1.0 Pre-Release Calculations............................................................................................................ 25 2.0 Radioactive Effluents Dose Projection Calculations.................................................................... 27 3.0 Deleted........................................................................................................................................ 28 4.0 Radioactive Effluents Dose Calculations..................................................................................... 29 5.0 Environmental Monitoring............................................................................................................ 41

Off-Site Dose Calculation Manual Rev. 42 Page iii PART I LIST OF TABLES Table Page 2-1 Radioactive Liquid Waste Sampling and Analysis Program....................................................... 4 2-2 Radioactive Gaseous Waste Sampling and Analysis Program.................................................. 8 2-3 Operational Radiological Environmental Monitoring Program.................................................. 14 2-4 Reporting Levels for Radioactivity Concentrations in Environmental Samples........................ 16 2-5 Maximum Values for the Lower Limits of Detection (LLD)....................................................... 17 PART II LIST OF TABLES Table 4-1 Inhalation Dose Factors (Ri) - Child......................................................................................... 33 4-2 Ingestion Dose Factors (Ri) - Child......................................................................................... 35 4-3 Deleted..................................................................................................................................... 36 4-4 Dose Factors Ground Plane Pathway...................................................................................... 38 4-5 Liquid Effluent - Adult Ingestion Dose Factors......................................................................... 40 5-1 Environmental Radiological Monitoring Station's Locations..................................................... 42 5-2 Environmental Radiological Monitoring Station's Locations Groundwater Monitoring Wells....................................................................................................................... 43 5-3 Inner Ring TLDs...................................................................................................................... 44 5-4 Outer Ring TLDs..................................................................................................................... 45 LIST OF FIGURES Figure 5.1 Environmental Monitoring Sample Station Locations - Outlying Areas.................................... 46 5.2 Environmental Monitoring Sample Station Locations - Site and Adjacent Areas..................... 47 5.3 CR3 Groundwater Monitoring Well Locations.......................................................................... 48 Change Summary................................................................................................................................... 49

Off-Site Dose Calculation Manual Rev. 42 Page iv PART I SPECIFICATIONS

Off-Site Dose Calculation Manual Rev. 42 Page 1 1.0 DEFINITIONS FREQUENCY P

Completed prior to each release M

At least once per 31 days.

Q At least once per 92 days.

S At least once per 6 months.

NOTE:

Surveillance frequencies are met if the surveillance is performed within 1.25 times the interval specified, as measured from the previous performance or as measured from the time a specified condition of the frequency is met.

LIQUID RADWASTE TREATMENT SYSTEM The Liquid Radwaste Treatment System shall be any available equipment (e.g., filters) capable of reducing the quantity of radioactive material, in liquid effluents, prior to discharge.

MEMBER OF THE PUBLIC Member of The Public means an individual in a controlled or unrestricted area. However, an individual is not a member of the public during any period in which the individual receives an occupational dose.

OFFSITE DOSE CALCULATION MANUAL (ODCM)

The ODCM contains the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, and in the conduct of the Radiological Environmental Monitoring Program (REMP). The ODCM also contains information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports.

SITE BOUNDARY The Site Boundary shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee. The CR3 site boundary is the same as the CR3 Controlled Area Boundary and encloses approximately 884 acres as defined in the January 2019 Partial Site Release Request, subsequently approved by the NRC January 2020 UNPLANNED RELEASE An Unplanned Release is an unintended discharge of liquid or airborne radioactivity to the environment. Due to plant shutdown, the chance of having an unplanned release is significantly reduced. Minor equipment failures which cause an increase in plant releases are not unplanned as it is expected that minor failures will occur from time-to-time. Human error which results in a release of radioactivity to the environment is considered unplanned.

EXAMPLES:

1.

Releasing the wrong waste tank.

2.

Plant leakage which exceeds reporting limits such as those of 10 CFR 50.72 and 10 CFR 50.73.

Off-Site Dose Calculation Manual Rev. 42 Page 2 UNRESTRICTED AREA An Unrestricted Area shall be any area at or beyond the site boundary, access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or industrial, commercial, institutional, and/or recreational purposes.

2.0 SPECIFICATIONS LIQUID RADWASTE TREATMENT SYSTEM The Liquid Radwaste Treatment System shall be used, as required, to reduce radioactive materials in liquid wastes prior to their discharge, when projected monthly doses due to liquid effluents discharged to Unrestricted Areas would exceed the following values:

a.

0.06 mrem whole body

b.

0.2 mrem to any organ APPLICABILITY: At all times.

ACTION:

a.

When radioactive liquid waste, in excess of the above limits, is discharged without prior treatment, prepare and submit to the Commission within 30 days, a Special Report which includes the following information:

1.

Identification of inoperable equipment and the reasons for inoperability.

2.

Actions taken to restore the inoperable equipment to operable status.

3.

Actions taken to prevent recurrence.

SURVEILLANCE REQUIREMENTS 2.1.1 Doses due to liquid releases shall be projected at least once per 31 days if a liquid release was made.

Off-Site Dose Calculation Manual Rev. 42 Page 3 LIQUID EFFLUENTS CONCENTRATION The concentration of radioactive material released to Unrestricted Areas shall be less than or equal to 10 times the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases.

APPLICABILITY: At all times.

ACTION:

a.

With the concentration of radioactive materials released to Unrestricted Areas exceeding the above limits, without delay restore the concentration of radioactive materials being released to Unrestricted Areas to within the above limits.

SURVEILLANCE REQUIREMENTS 2.2.1 Radioactive liquid wastes shall be sampled and analyzed in accordance with the sampling and analysis program of Table 2-1.

2.2.2 The results of the radioactivity analyses shall be used to assure the concentrations of radioactive material released from the site are maintained in accordance with Specification 2.2.

Off-Site Dose Calculation Manual Rev. 42 Page 4 TABLE 2-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Liquid Release Type Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

(µCi/ml)a A. Batch Waste Release Tanks d,e P

Each Batch P

Each Batch Principal Gamma Emittersf 5x10-7 P

Each Batch S

Compositeb,c H-3 1x10-5 P

Each Batch Q

Compositeb,c Gross Alpha 1x10-7 Sr-90 5x10-8 Fe-55, Ni-63 1x10-6 TABLE NOTATION

a.

The LLD* is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66sb / (2.22x106 E V Y e-t)

Where:

LLD is the lower limit of detection as defined above (as microcurie per unit mass or volume),

sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute),

E is the counting efficiency (as counts per disintegration),

V is the sample size (in units of mass or volume),

2.22x106 is the number of disintegrations per minute per microcurie, Y is the fractional radiochemical yield (when applicable),

is the radioactive decay constant for the particular radionuclide, and t is the elapsed time between midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

Typical values of E, V, Y, and t shall be used in the calculation.

The LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Off-Site Dose Calculation Manual Rev. 42 Page 5 TABLE 2-1 (Continued)

TABLE NOTATION

b.

A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.

c.

Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent release.

d.

A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed (minimum of two volume recirculation) to assure representative sampling.

e.

Means shall exist to determine waste volume, waste discharge flow rate, and dilution flow rate for each batch release.

f.

The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Co-60 and Cs-137. This list does not mean that only these nuclides are to be detected and reported. Other peaks, which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses shall be reported as "less than" the nuclide's LLD, and shall not be reported as being present at the LLD level for that nuclide. The "less than" values shall not be used in the required dose calculations.

Off-Site Dose Calculation Manual Rev. 42 Page 6 LIQUID EFFLUENTS - DOSE The dose or dose commitment to a Member of The Public from radioactive materials in liquid effluents released to Unrestricted Areas shall be limited as follows:

a.

During any calendar quarter to less than or equal to 1.5 mrem to the total body and less than or equal to 5 mrem to any organ.

b.

During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission, within 30 days, which includes:

1.

Identification of the cause for exceeding the limit(s);

2.

Corrective action taken to reduce the release of radioactive materials in liquid effluents during the remainder of the current calendar quarter and during the remainder of the current calendar year so that the dose or dose commitment to a Member of The Public from this source is less than or equal to 3 mrem total body and less than or equal to 10 mrem to any organ during the calendar year.

SURVEILLANCE REQUIREMENTS 2.3.1 DOSE CALCULATIONS. Cumulative dose contributions from liquid effluents shall be determined at least once per 31 days if a release has been made.

Off-Site Dose Calculation Manual Rev. 42 Page 7 Gaseous Effluents - Dose Rate The dose rate at or beyond the Site Boundary, due to radioactive materials released in gaseous effluents, shall be limited as follows:

a.

Tritium and radioactive particulates with half-lives of greater than 8 days: less than or equal to 1500 mrem/year to any organ.

APPLICABILITY: At all times ACTION:

a.

With dose rate (s) exceeding the above limits, without delay decrease the dose rate to within the above limit(s). Note: Due to the long period of time that the plant has been shut down, any potential dose or dose rate contribution from noble gas is now negligible and does not require sampling.

SURVEILLANCE REQUIREMENTS 2.4.1 The dose rate due to radioactive materials specified above in gaseous effluents shall be determined to be within the above limits by obtaining representative samples and performing analyses in accordance with Table 2-2.

2.4.2 Miscellaneous gaseous release pathways - such as the RB equipment hatch, RB personnel hatch, Aux Building doorways and Turbine Building - should be monitored with a portable air sampler when active decommissioning is occurring that could result in a release. It is noted that building ventilation is designed to maintain a negative pressure so as to minimize open-door pathway releases.

Dose - Noble Gases Due to the long period of time that the plant has been shut down, any potential dose or dose rate contribution from noble gas is now negligible. There is no means to create these fission gases with the only significant quantities of Kr-85 remaining in the spent fuel being located in the ISFSI.

Off-Site Dose Calculation Manual Rev. 42 Page 8 TABLE 2-2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Gaseous Release Type (See note below)

Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

(µCi/ml)a Auxiliary Building and Fuel Handling Area Exhaust b Reactor Building Exhaust b Grab Sample c M

Particulate Sample Principal Gamma Emitters d (Others) 1x10-11 Grab Sample c Q

Composite Particulate Sample Gross Alpha, Sr-90 Fe-55, Ni-63 1x10-11 Grab Sample c S

H-3 1x10-6 Note: These are Continuous release types as opposed to Batch releases per NUREG 1301. CR3 no longer has Batch gaseous releases.

Off-Site Dose Calculation Manual Rev. 42 Page 9 TABLE 2-2 (Continued)

TABLE NOTATION

a.

The LLD* is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66sb/(2.22x106 EVY e-t)

Where:

LLD is the lower limit of detection as defined above (as microcurie per unit mass or volume),

sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute),

E is the counting efficiency (as counts per disintegration),

V is the sample size (in units of mass or volume),

2.22x106 is the number of disintegrations per minute per microcurie, Y is the fractional radiochemical yield (when applicable),

is the radioactive decay constant for the particular radionuclide, and t is the elapsed time between midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

Typical values of E, V, Y, and t shall be used in the calculation.

The LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Off-Site Dose Calculation Manual Rev. 42 Page 10 TABLE 2-2 (Continued)

TABLE NOTATION

b.

Means shall exist to determine ventilation exhaust flow rate. Samples shall be obtained using calibrated samplers

c.

The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with the Specifications 2.7 and 2.9.

d.

The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Co-60 and Cs-137. This list does not mean that only these nuclides are to be detected and reported. Other peaks, which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses shall be reported as "less than" the nuclide's LLD and shall not be reported as being present at the LLD level for that nuclide. The "less than" values shall not be used in the required dose calculations.

Off-Site Dose Calculation Manual Rev. 42 Page 11 DOSE - TRITIUM AND RADIOACTIVE PARTICULATES The dose to a Member of The Public from Tritium and radioactive particulates with half-lives greater than 8 days in gaseous effluents released from the site to areas at or beyond the Site Boundary shall be limited as follows:

a.

During any calendar quarter: less than or equal to 7.5 mrem to any organ, and

b.

During any calendar year: less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of Tritium and radioactive particulates with greater than 8 day half-lives, in gaseous effluents, exceeding any of the above limits, prepare and submit to the Commission, within 30 days, a report which includes:

1)

Identification of the cause for exceeding the limits(s);

2)

Corrective action to reduce those releases during the remainder of the current calendar quarter and the remainder of the current calendar year so that the average dose to any organ is less than or equal to 15 mrem.

b.

If the projected monthly dose exceeds 0.3 mrem to any organ, then action shall be taken to reduce the quantity of radioactive material in the effluents.

SURVEILLANCE REQUIREMENTS 2.6.1 DOSE CALCULATIONS: Cumulative dose calculations for the current calendar quarter and current calendar year shall be determined at least once per 31 days.

2.6.2 DOSE PROJECTIONS: Dose shall be projected at least once per 31 days.

Off-Site Dose Calculation Manual Rev. 42 Page 12 TOTAL DOSE The calendar year dose or dose commitment to any Member Of The Public, due to releases of radioactivity and radiation, from uranium fuel cycle sources shall be limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which shall be limited to less than or equal to 75 mrem).

APPLICABILITY: At all times.

ACTION:

a.

With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specification 2.6.a or 2.6.b, calculations should be made, which include direct radiation contributions from the reactor, to determine whether the total dose limits above have been exceeded. If such is the case, prepare and submit to the Commission within 30 days, a report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This report, as defined in 10 CFR Part 20.2203, shall include an analysis that estimates the radiation exposure (dose) to a Member of the Public from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations. If the estimated dose(s) exceeds the above limits, and if the release condition resulting in violation of 40 CFR Part 190 has not already been corrected, the report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS 2.7.1 DOSE CALCULATIONS -

Total dose must also consider shine from the ISFSI pad and must be less than 25 mrem in a year as per 40 CFR 190.

NOTE: Procedure ISFS-212, section 5.2.1, equates the ISFSI controlled area boundary to CR3s owner controlled area boundary as described in the DSAR. Real individuals beyond the controlled area are where the ISFSI dose limits of 72.104 apply. These are the same dose limits imposed by 40 CFR 190, which is the basis for the limits of ODCM Specification 2.7 above.

Off-Site Dose Calculation Manual Rev. 42 Page 13 RADIOLOGICAL ENVIRONMENTAL MONITORING The radiological environmental monitoring program shall be conducted as specified in Table 2-3.

APPLICABILITY: At all times.

ACTION:

a.

With the radiological environmental monitoring program not being conducted as specified in Table 2-3, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

b.

With the level of radioactivity, resulting from plant effluents, in an environmental sampling medium exceeding the reporting levels of Table 2-4 when averaged over any calendar quarter, prepare and submit to the Commission, within 30 days of obtaining analytical results from the affected sampling period, a report, which identifies the cause(s) for exceeding the limit(s) and defines corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a Member of the Public is less than the calendar year limits of Specifications 2.4, 2.5, and 2.6. When more than one of the radionuclides in Table 2-4 are detected in the sampling medium, this report shall be submitted if:

concentration (1) + concentration (2) +.. 1.0 limit level (1) limit level (2)

When radionuclides other than those in Table 2-4 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to a Member Of The Public is greater than or equal to the calendar year limits of Specifications 2.4, 2.5, and 2.6. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report.

c.

With fresh leafy vegetation samples unavailable from one or more of the sample locations required by Table 2-3, identify the cause of the unavailability of samples and identify locations for obtaining replacement samples in the next Annual Radiological Environmental Operating Report. The locations from which samples were unavailable may then be deleted from those required by Table 2-3, provided the locations from which the replacement samples were obtained are added to the environmental monitoring program as replacement locations.

SURVEILLANCE REQUIREMENTS 2.8.1 The radiological environmental monitoring samples shall be collected pursuant to Table 2-3 from the locations given in the table and Figures 5.1, 5.2 and 5.3 and shall be analyzed pursuant to the requirements of Tables 2-3 and 2-5.

Off-Site Dose Calculation Manual Rev. 42 Page 14 TABLE 2-3 OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway and/or Sample Number of Samples and Locations Sampling/

Collection Frequency Type/Frequency of Analysis

1. AIRBORNE particulates One sample each:

C07, C18, C40, C41, C46 and Control Location C47 Continuous sampler/

Weekly collection Particulate sampler:

a)

Gross at 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/

following weekly filter change.

b)

Composite gamma special analysis (by location)/

quarterly. (Gamma Spectral Analysis shall also be performed on individual samples if gross beta activity of any sample is greater than 1.0 pCi/m3 and which is also greater than ten times the control sample activity.

2. DIRECT RADIATION

1) Inner Ring :

C60, C61, C62, C63, C64, C65, C66, C67, C68, C69, C41, C70, C27, C71, C72, C73

2) Outer Ring :

C18, C03, C04, C74, C75, C76, C08, C77, C09, C14G, C01, C79

3) Control Location:

C47 (Orlando)

Continuous placement/Quarterly collection Gamma exposure rate/quarterly

Off-Site Dose Calculation Manual Rev. 42 Page 15 TABLE 2-3 (Continued)

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway and/or Sample Number of Samples and Locations Sampling/

Collection Frequency Type/Frequency of Analysis

3. WATERBORNE Seawater Ground water Site Ground Water Drinking water Shoreline Sediment One sample each:

C14H, C14G, Control Location C13 One sample:

C40 (Control Location)

One sample each:

CR3-1S, CR3-1D, CR3-2, CR3-3S, CR3-3D, CR3-4, CR3-5, CR3-6S, CR3-6D, CR3-7 CR3-8, CR3-9, CR3-10 One sample each:

C07, C10, C18 (All Control Locations)

One sample each:

C14H, C14M, C14G, Control Location C09 Grab sample/Monthly Grab sample/semiannual Grab sample/quarterly Grab sample/quarterly Semiannual sample Gamma spectral analysis/monthly Tritium analysis on each sample or on a quarterly composite of monthly samples Gamma spectral and Tritium analysis/each sample Gamma spectral and Tritium analysis/each sample Gamma spectral and Tritium analysis/each sample Gamma spectral analysis/each sample

4. INGESTION Fish &

Invertebrates One sample each:

C29, Control Location C30 Quarterly:

Oysters and carnivorous fish Gamma spectral analysis on edible portions/each sample Food Products One sample each:

C48a, C48b, Control Location C47 One sample: C19 One sample: C04 Monthly (when available): Sample comprised of three (3) types of broad leaf vegetation from each location Annual during harvest:

Citrus Annual during harvest:

Watermelon Gamma spectral analysis/each sample Gamma spectral analysis/each sample Gamma spectral analysis/each sample

Off-Site Dose Calculation Manual Rev. 42 Page 16 TABLE 2-4 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Analysis Water (pCi/l)

Airborne Particulate or Gases (pCi/m3)

Fish (pCi/Kg, wet)

Milk (pCi/l)

Food Products (pCi/Kg, wet)

H-3 20,000(a)

Co-60 300 10,000 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 (a)

For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/l may be used. At the Crystal River site, there is no drinking water pathway due to the direction of groundwater flow being west-southwest towards the Gulf of Mexico and the fact that the groundwater at the site is too saline for human consumption.

Off-Site Dose Calculation Manual Rev. 42 Page 17 TABLE 2-5 MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION (LLD) a, c Analysis Water (pCi/l)

Airborne Particulate or Gases (pCi/m3)

Fish (pCi/Kg, wet)

Milk (pCi/l)

Food Products (pCi/Kg, wet)

Sediment (pCi/Kg, dry) gross beta 0.01 3H 2000b 60Co 15 130 134Cs 15 0.05d 130 15 60 150 137Cs 18 0.06d 150 18 80 180

Off-Site Dose Calculation Manual Rev. 42 Page 18 TABLE 2-5 (Continued)

TABLE NOTATION

a.

The LLD* is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66sb / (2.22 E V Y e-t)

Where:

LLD is the lower limit of detection as defined above (as picocurie per unit mass or volume),

sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute),

E is the counting efficiency (as counts per disintegration),

V is the sample size (in units of mass or volume),

2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield (when applicable),

is the radioactive decay constant for the particular radionuclide, and t is the elapsed time between environmental collection, or end of the sample collection period, and time of counting.

Typical values of E, V, Y, and t shall be used in the calculation.

The LLD is defined as an a priori (before the fact) limit representing the capability of the measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLD's will be achieved under routine conditions. Occasionally, background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLD's unachievable. In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report.

b.

LLD for drinking water. If no drinking water pathway exists, a value of 3000 pCi/l may be used.

c.

Other peaks which are measurable and identifiable, together with the radionuclides in Table 2.5, shall be identified and reported.

d.

Cs-134, and Cs-137 LLD's apply only to the quarterly composite gamma spectral analysis, not to analyses of single particulate filters.

Off-Site Dose Calculation Manual Rev. 42 Page 19 LAND USE CENSUS A land use census shall be conducted and shall identify the location of the nearest milk animal (if any), the nearest residence and the nearest garden* of greater than 500 square feet producing fresh leafy vegetables in each of the land based meteorological sectors within a distance of five miles.

APPLICABILITY: At all times.

ACTION:

a.

With a land use census identifying a location(s) that yields a calculated dose or dose commitment greater than the values currently being calculated by Specification 2.6, identify the new location in the next Annual Radiological Environmental Operating Report.

b.

With a land use census identifying a location(s) which yields a calculated dose or dose commitment (via the same exposure pathway) which is at least 20% greater than at a location from which samples are currently being obtained in accordance with Specification 2.8, this location shall be added to the radiological environmental monitoring program within 30 days. The new sampling location shall replace the present sampling location, which has the lower calculated dose or dose commitment (via the same exposure pathway), after June 30 following this land use census. Identification of the new location and revisions of the appropriate figures shall be submitted with the next Radioactive Effluent Release Report.

• Broad leaf vegetation sampling may be performed at the site boundary in the direction sector with the highest D/Q in lieu of the garden census.

SURVEILLANCE REQUIREMENTS 2.9.1 The land use census shall be conducted at least once per 12 months during the growing season by a door-to-door survey, aerial survey, or by consulting local agriculture authorities, using that information which will provide adequate results.

Off-Site Dose Calculation Manual Rev. 42 Page 20 INTERLABORATORY COMPARISON PROGRAM Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program which has been approved by the Commission. A summary of the results obtained from this program shall be included in the Annual Radiological Environmental Operating Report.

APPLICABILITY: At all times.

ACTION:

a.

With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report.

SURVEILLANCE REQUIREMENTS 2.10.1 No surveillance requirements other than those required by the Interlaboratory Comparison Program.

Off-Site Dose Calculation Manual Rev. 42 Page 21 3.0 SPECIFICATION BASES LIQUID RADWASTE TREATMENT SYSTEM BASIS Use of the Liquid Radwaste Treatment System will implement the ALARA requirements of 10 CFR 50, Appendix I and the guidance specified in Chapter 4 of the CR3 DSAR.

LIQUID EFFLUENTS CONCENTRATION BASIS This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to Unrestricted Areas will be less than 10 times the effluent concentration limits (ECLs) specified in 10 CFR Part 20. This limitation provides additional assurance that the levels of radioactive materials in bodies of water in Unrestricted Areas will result in exposures within the Section II.A design objectives of Appendix I, 10 CFR 50, to a Member of The Pubic.

There are no Noble gases seen in the typical waste water due to lengthy radioactive decay.

LIQUID EFFLUENTS DOSE BASIS This specification is provided to implement the requirements of Sections II.A, Ill-A and IV.A of Appendix I, 10 CFR Part 50. It also implements the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable" (ALARA). The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

GAS EFFLUENTS DOSE RATE BASIS These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a member of the public, either within or outside the site boundary, to annual average concentrations exceeding 10 times the concentration limits specified in Appendix B, Table 2 of 10 CFR 20.

Off-Site Dose Calculation Manual Rev. 42 Page 22 GASEOUS EFFLUENTS DOSE: TRITIUM AND RADIOACTIVE PARTICULATE BASIS This specification is provided to implement the requirements of Sections II.C, III.A, and IV.A of Appendix I, 10 CFR Part 50 and assures that the releases of radioactive materials in gaseous effluent will be kept "as low as is reasonably achievable" (ALARA). The methods for calculating the dose due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate specifications for Tritium, and radioactive particulates with half-life greater than eight days are dependent on the existing radionuclide pathways to man, in areas at and beyond the site boundary. The pathways which were examined in the development of these calculations were:

1)

Individual inhalation of airborne radionuclides,

2)

Deposition of radionuclides onto green leaf vegetation with subsequent consumption by man,

3)

Deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and

4)

Deposition on the ground with subsequent exposure of man.

Off-Site Dose Calculation Manual Rev. 42 Page 23 TOTAL DOSE BASIS This specification is provided to meet the dose limitations of 40 CFR Part 190 that have now been incorporated into 10 CFR Part 20 by 46 FR 18525. This specification applies to Members Of The Public beyond the site boundary (i.e. in the unrestricted area). The specification requires the preparation and submittal of a report whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I.

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM BASIS The radiological monitoring program required by this specification provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of Member Of The Public resulting from the station operation. This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways. Program changes may be initiated based on operational experience.

The LLD's required by Table 2-5 are considered optimum for routine environmental measurements in industrial laboratories. The LLD's for drinking water meet the requirements of 40 CFR 141.

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM LAND USE CENSUS BASIS This specification is provided to ensure that changes in the use of areas at or beyond the Site Boundary are identified and that modifications to the monitoring program are made if required by the results of this census. Adequate information gained from door-to-door or aerial surveys or through consultation with local agricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 500 square feet provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumption were used:

1) that 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and

2) a vegetation yield of 2 kg/square meter.

RADIOLOGICAL ENVIRONMENTAL MONITORING INTERLABORATORY COMPARISON PROGRAM BASIS The requirement for participation in an Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.

Off-Site Dose Calculation Manual Rev. 42 Page 24 PART II METHODOLOGIES Section 1.0 PRE-RELEASE CALCULATIONS

Off-Site Dose Calculation Manual Rev. 42 Page 25 PRE-RELEASE CALCULATION 1-1 GASEOUS RADWASTE RELEASE I.

INTRODUCTION Prior to initiating a release of gaseous radwaste, it must be determined that the concentration of radionuclides to be released, and the flow rates at which they are released will not cause the dose rate limitation of 1500 mrem/yr (any organ via the inhalation pathway) to be exceeded from tritium and radioactive particulates with greater than 8 day half-lives at the Site Boundary.

II.

INFORMATION REQUIRED Results of appropriate Nuclide Analysis III.

CALCULATIONS Tritium, Radioactive Particulates Dose Rate (T,P) = (X/Q)PiQi mrem/yr.

where:

Pi = The dose parameter for radionuclides other than noble gases for the inhalation pathway, in mrem/yr per µCi/m3. (See Table 4-1).

Qi = The release rate of radionuclide, i, in gaseous effluent from individual release sources, in µCi/sec (per unit, unless otherwise specified). Qi = Effluent stream nuclide concentration x flow rate.

Flow Rates: Building ventilation exhaust flow rates per Engineering.

(X/Q) = 2.35 x 10-5 sec/m3 for all vent releases. The highest calculated annual average relative concentration for any area at or beyond the site boundary. Reference - CR3 Calculation N18-0003, June 2019.

Off-Site Dose Calculation Manual Rev. 42 Page 26 PRE-RELEASE CALCULATION 1-2 LIQUID RADWASTE RELEASE I.

INTRODUCTION Prior to initiating a release of liquid radwaste, it must be determined that the concentration of radionuclides to be released and the flow rates at which they will be released will not lead to a release concentration greater than the limits of 10 times the effluent concentrations specified by 10 CFR 20 at the point of discharge.

II.

INFORMATION REQUIRED Results of appropriate Nuclide Analysis III.

CALCULATIONS Discharge Concentration = 0.1

where:

C i

=

The concentration of isotope i, in the gamma spectrum excluding dissolved or entrained noble gases.

T C

=

Tritium Concentration from most recent analysis.

a C

=

Gross alpha concentration from most recent analysis.

S C

=

Sr-90 concentration from most recent analysis.

CNi

=

Ni-63 concentration from most recent analysis.

Fe C

=

Fe-55 concentration from most recent analysis.

E

=

Effluent Stream Flow Rate D

=

Raw Water Flow Rate EC L =

10 CFR 20 Appendix B, effluent concentration limit.

If Discharge Concentration is less than or equal to 1, the discharge may be initiated. If Discharge Concentration is greater than 1, then release parameters must be changed to assure that Discharge Concentration is not greater than 1. Changes include reducing tank concentration by decay or dilution, reducing the waste stream release rate, or increasing dilution water flow rate.

Off-Site Dose Calculation Manual Rev. 42 Page 27 SECTION 2.0 RADIOACTIVE EFFLUENTS DOSE PROJECTION CALCULATIONS

Dose Projection Methodology - Liquid Radwaste Calculation Dose projection calculations will be necessary if there is a malfunction of liquid radwaste treatment system equipment and liquid radwaste must be released without prior treatment.

Dp = 31Dc/NDQ where:

Dp

=

Projected Dose (monthly).

Dc

=

Current quarter cumulative dose, including projection for release under evaluation.

NDQ =

Number of days into quarter, where the quarterly periods are:

January 1 through March 31, April 1 through June 30, July 1 through September 30, October 1 through December 31.

Off-Site Dose Calculation Manual Rev. 42 Page 28 SECTION 3.0 Deleted

Off-Site Dose Calculation Manual Rev. 42 Page 29 SECTION 4.0 RADIOACTIVE EFFLUENTS DOSE CALCULATIONS

Off-Site Dose Calculation Manual Rev. 42 Page 30 4.1 DOSE CALCULATION (TRITIUM & PARTICULATES)

The dose to an individual at or beyond the Site Boundary due to Tritium and radioactive particulates with half-lives of greater than 8 days is calculated as follows:

D = 3.17 x 10-8 WRiQi mrem where:

D

=

The radiation dose to an individual at or beyond the Site boundary, in mrem.

Ri

=

The dose factor for each identified radionuclide, i, in m2(mrem/year) per µCi/sec or mrem/year per µCi/m3.

W

=

X/Q for inhalation pathway, 2.35 x 10-5 sec/m3 at the site boundary.

W

=

D/Q for food and ground plane pathway, 1.67 x 10-7m-2 at the site boundary.

Qi

=

Total µCi of isotope i released during the calendar quarter or calendar year, as appropriate 3.17 x 10-8 = The number of years in one second Note: This dose calculation is done to confirm the ALARA dose limits of Specification 2.6 are met.

Those limits apply to the limiting real person in the unrestricted area. By using the highest site boundary X/Q and D/Q values, this calculation models a person residing at the site boundary (the receptor), which is less than one-third of a mile from the release point rather than miles away as identified in the annual land use census, making the results very conservative. Doses can be recalculated using more representative dispersion and deposition factors if the need arises. Reference calculation N18-0003 for X/Q and D/Q values for the site boundary, and residences and worker locations in the unrestricted area.

Reference:

NUREG 0133, Section 5.3.1

Off-Site Dose Calculation Manual Rev. 42 Page 31 4.2 DOSE CALCULATION (LIQUID EFFLUENTS)

The dose or dose commitment to a Member Of The Public from radioactive materials in liquid effluents released to Unrestricted Areas is calculated as follows:

D =

A t C F i

i k

k ik k

where:

D

=

The cumulative dose commitment to the total body or any organ, T, from the liquid effluents for the total time period tk in mrem. The receptor location is at the end of the discharge canal.

tk

=

The length of the kth time period over which Cik is averaged for all liquid releases, in hours.

Cik

=

The average concentration of radionuclide, i, in undiluted liquid effluent during time period tk from any liquid release, in µCi/ml.

Ai

=

The site related ingestion dose commitment factor to the total body or any organ for each identified principal gamma and beta emitter as shown in Table 4-5 of this manual, in mrem-ml per hour-µCi.

FK

=

Waste flow rate / (Waste flow rate + Dilution flow rate)

Dilution flow rate = 27,000 gpm (Ref. Calculation N19-0001).

References:

1) NUREG 0133, Section 4.3.

Off-Site Dose Calculation Manual Rev. 42 Page 32 4.3 CALCULATION OF INHALATION PATHWAY DOSE FACTOR (Ri)

R = K BR DFA mrem / year per uCi / m i

i 3

where:

K

=

A constant unit of conversion - 106 pCi/µCi BR

=

The Breathing Rate of the represented age group:

1400 m3/yr - infant 3700 m3/yr - child 8000 m3/yr - teen 8000 m3/yr - adult DFAi

=

The maximum organ inhalation dose factor for the represented age group for the ith radionuclide, in mrem/pCi. From Reference 2 below. This is conservative and consistent with more current radiation protection guidance (e.g. Federal Guidance Report 11 and ICRP-56).

References:

1) NUREG-0133, Section 5.3.1.1

2) Regulatory Guide 1.109, Table E-5, and Tables E-7 through E-10

Off-Site Dose Calculation Manual Rev. 42 Page 33 TABLE 4-1 Inhalation Dose Factors (Ri) - Child Nuclide Bone Liver T. Body Thyroid Kidney Lung GI-LLI H-3 1.12E3 1.12E3 1.12E3 1.12E3 1.12E3 1.12E3 1.12E3 Fe-55 4.74E4 2.52E4 7.77E3 ND ND 1.11E5 2.87E3 Co-60 ND 1.31E4 2.26E4 ND ND 7.07E6 9.62E4 Ni-63 8.21E5 4.63E4 2.80E4 ND ND 2.75E5 6.33E3 Sr-90 1.01E8 ND 6.44E6 ND ND 1.48E7 3.43E5 Cs-134 6.51E5 1.01E6 2.25E5 ND 3.30E5 1.21E5 3.85E3 Cs-137 9.07E5 8.25E5 1.28E5 ND 2.82E5 1.04E5 3.62E3

Off-Site Dose Calculation Manual Rev. 42 Page 34 4.4 Calculation of Ingestion Dose Factor - Vegetation Pathway

R D / Q K

r Y

DFL U f e-t U f e-t i

v v

i +

w i a a

L L

i L a

s g

i h

where: Units = m2mrem/yr per µCi/sec.

Reference Table, R.G. 1.109

K

=

A constant of unit conversion, 106 pCi/µCi.

Ua L

=

The consumption rate of fresh leafy vegetation by the E-5 receptor in age group (a), in kg/yr.

Infant 0 Child 26 Teen 42 Adult 64 Ua s

=

The consumption rate of stored vegetation by the E-5 receptor in age group (a), in kg/yr Infant 0 Child 520 Teen 630 Adult 520

DFL a i

=

The maximum organ ingesting dose factor for the ith E-11 to E-14 radionuclide for the receptor in age group (a), in mrem/pCi.

fL

=

The fraction of the annual intake of fresh leafy E-15 vegetation grown locally. (default 1.0) fg

=

The fraction of the annual intake of stored vegetation E-15 grown locally. (default 0.76) tL

=

The average time between harvest of leafy vegetation E-15 and its consumption, 8.6 x 104 seconds (1 day) th

=

The average time between harvest of stored vegetation E-15 and its consumption, 5.18 x 106 seconds (60 days)

Yv

=

The vegetation areal density, 2.0 kg/m 2

E-15 r

=

Fraction of deposited activity retained on the E-15 vegetation 0.2 particulates i

=

The decay constant for the ith radionuclide, in sec-1 w

=

The decay constant for removal of activity on leaf and E-15 plant surfaces by weathering, 5.73 x 10-7 sec-1 (corresponding to a 14 day half-life).

Note: The above equation does not apply to the concentrations of tritium in vegetation. A separate equation is provided in NUREG 0133, section 5.3.1.5 to determine tritium values.

Reference:

The equation deriving Ri v

(D/Q) was taken from NUREG 0133, Section 5.3.1.5.

Off-Site Dose Calculation Manual Rev. 42 Page 35 TABLE 4-2 Ingestion Dose Factors (Ri) for Vegetation Pathway-Child Nuclide Bone Liver T. Body Thyroid Kidney Lung GI-LLI H-3 4.01E3 4.01E3 4.01E3 4.01E3 4.01E3 4.01E3 4.01E3 Fe-55 8.00E8 4.24E8 1.31E8 ND ND 2.40E8 7.86E7 Co-60 ND 3.78E8 1.12E9 ND ND ND 2.10E9 Ni-63 3.95E10 2.11E9 1.34E9 ND ND ND 1.42E8 Sr-90 1.24E12 ND 3.15E11 ND ND ND 1.67E10 Cs-134 1.60E10 2.63E10 5.55E9 ND 8.15E9 2.92E9 1.42E8 Cs-137 2.39E10 2.29E10 3.38E9 ND 7.46E9 2.68E9 1.43E8

Off-Site Dose Calculation Manual Rev. 42 Page 36 OLD TABLE 4-3 (Deleted table)

Off-Site Dose Calculation Manual Rev. 42 Page 37 4.5 Calculation of Dose Factors - in the Ground Plane Pathway (

G i

R [D/Q])

R D / Q K K SF DFG 1-e it i

G i

/

i where: units = m2 mrem/yr per uCi/sec Reference Table, R.G. 1.109

K

=

A constant unit of conversion, 106 pCi/µCi.

K

=

A constant unit of conversion, 8760 hr/yr S F

=

The shielding factor, 0.7(dimensionless)

E-15 i

=

The decay constant for the ith radionuclide, sec-1 t

=

The exposure period, 4.73 x 108 sec (15 years)

DFGi

=

The ground plane dose conversion factor for the E-6 ith radionuclide (mrem/hr per pCi/m2)

Reference:

The equation deriving G

i R [D/Q] was taken from NUREG 0133, Section 5.3.1.2.

Off-Site Dose Calculation Manual Rev. 42 Page 38 Table 4-4 Dose Factors Ground Plane Pathway (

G i

R [D/Q])

Nuclide T. Body Skin Fe-55 0

0 Co-60 2.15E10 2.53E10 Ni-63 0

0 Cs-134 6.85E9 8.00E9 Cs-137 1.03E10 1.20E10 Units are m2mrem/yr per µCi/sec

Off-Site Dose Calculation Manual Rev. 42 Page 39 4.6 CALCULATION OF LIQUID EFFLUENT ADULT INGESTION - DOSE FACTORS

A 1.14E5 21BF 5BI DF i =

i +

i i

Ai

=

Composite dose parameter for the total body or critical organ of an adult for nuclide i, for all appropriate pathways, mrem/hr per µCi/ml 1.14E5 =

units conversion factor, 106pci/µci x 103 ml/kg 8760 hr/yr BFi

=

Bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L, from Table A-1 of Regulatory Guide 1.109 (Rev. 1) or Table A-8 of Regulatory Guide 1.109 (original draft).

BIi

=

Bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L, from Table A-1 of Regulatory Guide 1.109 (Rev. 1) or Table A-8 of Regulatory Guide 1.109 (original draft).

DFi

=

Dose conversion factor for nuclide i, for adults in pre-selected organ, in mrem/pCi, from Table E-11 or Regulatory Guide 1.109 (Rev. 1) or Table A-3 of Regulatory Guide 1.109 (original draft).

Reference:

The equation for Saltwater sites from NUREG 0133, Section 4.3.1, where Uw/Dw = 0 since no drinking water pathway exists.

Off-Site Dose Calculation Manual Rev. 42 Page 40 Table 4-5 Liquid Effluent - Adult Ingestion Dose Factors (Ai)

Nuclide Bone Liver T. Body Thyroid Kidney Lung GI-LLI H-3 2.82E-1 2.82E-1 2.82E-1 2.82E-1 2.82E-1 2.82E-1 2.82E-1 Fe-55 5.11E4 3.53E4 8.23E3 ND ND 1.97E4 2.03E4 Co-60 ND 1.73E3 3.82E3 ND ND ND 3.25E4 Ni-63 4.96E4 3.44E3 1.67E3 ND ND ND 7.18E2 Sr-90 1.23E5 ND 3.01E4 ND ND ND 3.55E3 Sb-124 2.77E2 5.23E0 1.09E2 6.71E-1 ND 2.15E2 7.83E3 Cs-134 6.84E3 1.63E4 1.33E4 ND 5.27E3 1.75E3 2.85E2 Cs-137 8.78E3 1.20E4 7.85E3 ND 4.07E3 1.35E3 2.32E2

Off-Site Dose Calculation Manual Rev. 42 Page 41 SECTION 5.0 ENVIRONMENTAL MONITORING

Off-Site Dose Calculation Manual Rev. 42 Page 42 Table 5-1 Environmental Radiological Monitoring Stations Locations (Non-TLDs)

STATION LOCATION DIRECTION FROMPLANT APPROX.DISTANCE FROMPLANT(mi)

C04 Near State Park Old Dam and Lake Rousseau ENE 10 C07 Crystal River Public Water Plant ESE 7.4 C09 Fort Island Gulf Beach S

3.2 C10 Crystal River Water Supply ESE 6.0 C13 Mouth of Intake Canal WSW 3.4 C14H Head of Discharge Canal N

0.1 C14M Between head and end of Discharge Canal W

1.2 C14G End of Discharge Canal W

1.5 C18 Yankeetown Water Dept. (at water tower)

N 5.3 C19 Near intersection of State Road 495 and W.

Riverbend Rd.

ENE 9

C29 Discharge Area beyond end of canal W

2.0 C30 Intake Area WSW 3.6 C40 Air sampler near Duke Energy Well #5. Ground water at Well #12 E

3.5/3.7 C41 Former meteorological tower site SW 0.4 C46 Adjacent to Duke Energy Pump Station N

0.4 C47 Office of Radiation Control, Orlando ESE 78 C48A Near C46 and Duke Energy Pump Station N

0.4 C48B Near Duke Energy Mariculture Center NNE 0.9 NOTE: Distances are approximate. More than one type of sample media (e.g. air and water) are obtained at some stations. For multi-media stations there may be minor difference in distance for each type of sample. Crop collection locations for stations C04 (watermelon) and C19 (citrus) are highly variable.

Off-Site Dose Calculation Manual Rev. 42 Page 43 Table 5-2 Environmental Radiological Monitoring Stations Locations-Groundwater Monitoring Wells STATION LOCATION DIRECTION FROMPLANT APPROX.DISTANCE FROMPLANT(mi)

• CR3-1S CR-3 Site Perimeter, Just Outside of Protected Area Fence ENE 0.2

• CR3-1D CR-3 Site Perimeter, Just Outside of Protected Area Fence ENE 0.2 CR3-2 CR-3 Site Perimeter, Just Outside of Protected Area Fence E

0.1

• CR3-3S CR-3 Site Perimeter, Just Outside of Protected Area Fence ESE 0.1

• CR3-3D CR-3 Site Perimeter, Just Outside of Protected Area Fence ESE 0.1 CR3-4 CR-3 Site Perimeter, Just Outside of Protected Area Fence SSE 0.086 CR3-5 CR-3 Site Perimeter, Just Outside of Protected Area Fence SSW 0.051 CR3-6S CR-3 Site Perimeter, Just Outside of Protected Area Fence W

0.038 CR3-6D CR-3 Site Perimeter, Just Outside of Protected Area Fence W

0.038 CR3-7 CR-3 Site Perimeter, Just Outside of Protected Area Fence WNW 0.060 CR3-8 CR-3 Site Perimeter, Just Outside of Protected Area Fence WNW 0.073 CR3-9 CR-3 Site Perimeter, Just Outside of Protected Area Fence NW 0.1 CR3-10 CR-3 Site Perimeter, Just Outside of Protected Area Fence NNE 0.1 The above listed wells have been included in the REMP as a result of information provided in the groundwater flow study completed January 22, 2007 by EnHydro, LLC.

These wells added to REMP as a result of recommendations made from groundwater flow study completed 11/01/2012 by Gaydos Hydro Services, LLC.

Off-Site Dose Calculation Manual Rev. 42 Page 44 TABLE 5-3 INNER RING TLDs LOCATION DIRECTION APPROX. DISTANCE (Mi.)

C27 W

0.7 C60 N

0.9 C61 NNE 0.9 C62 NE 1.2 C63 ENE 0.9 C64 E

0.8 C65 ESE 0.3 C66 SE 0.4 C67 SSE 0.3 C68 S

0.3 C69 SSW 0.3 C41 SW 0.4 C70 WSW 0.7 C71 WNW 0.6 C72 NW 0.3 C73 NNW 0.7

Off-Site Dose Calculation Manual Rev. 42 Page 45 TABLE 5-4 OUTER RING TLDs LOCATION DIRECTION APPROX. DISTANCE (Mi.)

C18 N

5.3 C03 NNE 4.9 C04 NE 6.0 C74 ENE 5.1 C75 E

4.0 C76 ESE 5.6 C08 SE 5.7 C77 SSE 3.4 C09 S

3.3 C14G W

2.0 C01 NW 4.8 C79 NNW 5.0

Off-Site Dose Calculation Manual Rev. 42 Page 46 FIGURE 5.1 Environmental Monitoring Sample Station Locations Outlying Areas Figure 5.1 shows outlying environmental station locations (Ref. Table 5-4) for direct radiation (TLDs), as well as locations for other pathways and sample types (Ref. Table 2-3). Site boundary is shown in the DSAR.

Waterborne, Airborne, & Direct Radiation Ingestion & Direct Radiation C07 Air Drinking Water (Control)

C04 TLD, Watermelon C09 TLD, Sediment (Control)

C19 Citrus C10 Drinking Water (Control)

C29 Fish & Oysters C13 Seawater (Control)

C30 Fish & Oysters (Control)

C14G &14M TLD, Seawater, Sediment C18 TLD, Air, Drinking Water (Control)

C40 Air, Ground Water (Control)

Off-Site Dose Calculation Manual Rev. 42 Page 47 FIGURE 5.2 Environmental Monitoring Sample Station Locations Site and Adjacent Areas Figure 5.2 shows site environmental station locations (Ref. Table 5-3) for direct radiation (TLDs), as well as locations for other pathways and sample types (Ref. Table 2-3). Site boundary is shown in the DSAR.

Waterborne, Airborne, Ingestion C14H Sediment, Seawater C41 Air C46 Air C48A Vegetation C48B Vegetation

Off-Site Dose Calculation Manual Rev. 42 Page 48 FIGURE 5.3

CR3 Groundwater Monitoring Well Locations Deep Wells Are Also Installed at #s 1, 3, 6

Off-Site Dose Calculation Manual Rev. 42 Page 49 Summary of Changes WCDRR-2022-001 PAGE CHANGE Cover Page Revised titles and reviewer and preparer designations ii & iii TOC: Deleted Methodologies Section 3.0. Revised List of Tables and List of Figures to reflect nomenclature change and deletion of one map 3

Corrected specification number in Surveillance Requirement 2.2.2 5

Table 2-1: Edited footnote d to add recirculation volume requirement formerly in Section 3.0, Sampling Methods, now deleted.

12 NOTE: Deleted sentence about ISFSI dose calculation and dose results in the note.

The purpose of the note (not part of the original specification) was to relate 10CFR72.104 public dose requirements to the dose requirements of specification 2.7 which originate with 10CFR190 (Ref. Audit Observation #3: CR-2021-000145).

14 Table 2-3: Revised TLD location descriptions and deleted out of date note in Direct Radiation section 16 Table 2-4: Deleted footnote (b) as it applied to short-lived radionuclides previously listed but removed in revision 41 17 & 18 Table 2-5: Deleted old footnote (c) as it applied to short-lived radionuclides previously listed but removed in revision 41. Footnotes d and e changed to c and d.

25 Edited Flow Rates section for clarity, and deleted reference to Seawater Room Exhaust fans which are no longer in service.

27 Deleted dose projection methodology for gaseous releases as the specification for dose projection was removed in a prior revision.

28 Section 3.0: Deleted, as information is contained in Tables 2-1 and 2-2 or footnotes.

42 Table 5-1: Updated sample station descriptions and distances 44 & 45 Tables 5-3 & 5-4: Edited table titles and updated distances 46 & 47 Figures 5.1 & 5.2: Updated to provide more precise sample station locations and to consolidate direction radiation (TLD) stations with other sample media. This resulted in one map for the site (and nearby areas) and one map for areas more distant from site.

Figure 5.3: Deleted (old page 48). TLD station C78 in Figure 5.3 is not in new Figure 5.1 as it was deleted from the program (Table 2-3) in revision 38 of the ODCM.

48 Figure 5.4 designation changed to Figure 5.3 to account for deletion of prior Figure 5.3.

Note: Punctuation and spelling corrections not listed