CP-201500445, Transmittal of Year 2014 Radioactive Effluent Release Report

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Transmittal of Year 2014 Radioactive Effluent Release Report
ML15132A281
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/30/2015
From: Flores R, Madden F
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201500445, TXX-15055
Download: ML15132A281 (56)
v • d • e


Text

Rafael Flores Luminant Power BI Senior Vice President

& Chief Nuclear Officer Rafael.flores@Luminant.com P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 Luminant T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201500445 Ref. # Tech. Spec. 5.6.3 Log # TXX-15055 10CFR50.36a April 30, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 TRANSMITTAL OF YEAR 2014 RADIOACTIVE EFFLUENT RELEASE REPORT

Dear Sir or Madam:

In accordance with Comanche Peak Nuclear Power Plant Units 1 and 2 Technical Specifications (TS) 5.6.3 and Section 6.9.1.4 of the Comanche Peak Offsite Dose Calculation Manual (ODCM), enclosed is the Radioactive Effluent Release Report which covers the reporting period from January 1, 2014 through December 31, 2014.

The tabular summaries of radioactive liquid and gaseous releases are provided in the format defined in Appendix B of Regulatory Guide 1.21, Rev. 1, dated June, 1974.

During this reporting period there were no revisions to the ODCM.

If there are any questions regarding this report, please contact Steve Dixon at (254) 897-5482 or Kerry Cooper at (254) 897-0462.

Sincerely, Luminant Generation Company LLC Rafael Flores By: A4 .*

/fred W. Madden Director, External Affairs ilZ~6~~

U. S. Nuclear Regulatory Commission TXX-15055 Page 2 04/30/2015 Enclosures - 1. Comanche Peak 2014 Radioactive Effluent Release Report c- M. L. Dapas, Region IV K. M. Kennedy, Region IV B. Singal, NRR Resident Inspectors, Comanche Peak

Enclosure 1 Comanche Peak 2014 Radioactive Effluent Release Report

ý-v CPNPP Comanche Peak Nuclear Power Plant 2014 RADIOACTIVE EFFLUENT RELEASE REPORT January 1, 2014 - December 31, 2014 Prepared By: David Valentine Date 3/18/15 Reviewed By: Don Rebstock Date 3/18/15 Approved By: Kerry Cooper Date 3/18/15 Page 1 of 53

TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS

1.0 INTRODUCTION

1.1 Executive Summary 1.2 Historical Trend Graphs 2.0 SUPPLEMENTAL INFORMATION 2.1 Regulatory Limits 2.2 Effluent Concentration Limits 2.3 Measurements and Approximations of Total Radioactivity 2.4 Batch Releases 2.5 Abnormal or Unplanned Releases 3.0 GASEOUS EFFLUENTS 4.0 LIQUID EFFLUENTS 5.0 SOLID WASTES 6.0 RADIOLOGICAL IMPACT ON MAN 6.1 Dose Due to Liquid Effluents 6.2 Dose Due to Gaseous Effluents 6.3 Dose Due to Radioiodines, Tritium, and Particulates 6.4 40CFR190 Dose Evaluation 6.5 Dose to a MEMBER OF THE PUBLIC from Activities inside the Site Boundary 7.0 METEROLOGICAL DATA 7.1 Meteorological Monitoring Program 8.0 RELATED INFORMATION 8.1 Operability of Liquid and Gaseous Monitoring Instrumentation 8.2 Changes to the Offsite Dose Calculation Manual Page 2 of 53

8.3 New Locations for Dose Calculations or Environmental Monitoring 8.4 Liquid Holdup and Gas Storage Tanks 8.5 Noncompliance with Radiological Effluent Control Requirements 8.6 Resin Releases to the LVW Pond 8.7 Changes to the Liquid, Gaseous, and Solid Waste Treatment Systems 8.8 Groundwater Tritium Monitoring Program 9.0 TABLES 9.1 Site Liquid and Gaseous Batch Release Summary 9.2 Site Abnormal Batch Liquid and Gaseous Release Summary 9.3 Site Gaseous Effluents-Summation of All Releases 9.4 Site Gaseous Effluents-Ground Level Releases 9.5 Site Liquid Effluents Summation of All Releases 9.6 Site Liquid Effluents 9.7 Dose to a member of the public due to Liquid Releases 9.8 Dose Due to Gaseous Releases-Site 9.9 Dose to a Member of the Public Due To Radioiodines, Tritium, and Particulates in Gaseous Releases 9.10 Solid Waste and Irradiated Fuel Shipments 10.0 ATTACHMENTS 10.1 Meteorological Joint Frequency Distribution Tables 10.2 Atmospheric Dispersion (x/q) and Deposition (d/q) Calculation Methodology Discussion 10.3 Carbon 14 Supplemental Information Page 3 of 53

ACRONYMS AND ABBREVIATIONS CFR Code of Federal Regulations CPNPP Comanche Peak Nuclear Power Plant ECL Effluent Concentration Limit IFSFI Independent Spent Fuel Storage Installation LDCR Licensing Document Change Request LHMT Laundry Holdup and Monitor Tanks LVW Low Volume Waste ODCM Offsite Dose Calculation Manual PET Primary Effluent Tanks pCi Pico-Curie REC Radiological Effluent Control SORC Station Operations Review Committee uCi Micro-Curie WMT Waste Monitor Tanks WWHT Waste Water Holdup Tanks 4 of 53

1.0 Introduction This Radioactive Effluent Release Report, for Comanche Peak Nuclear Power Plant Unit I and Unit 2, is submitted as required by Technical Specification 5.6.3 and Offsite Dose Calculation Manual (ODCM) Administrative Control 6.9.1.4 for the period January 1, 2014, through December 31, 2014.The data in this report was calculated in accordance with the CPNPP ODCM and using the Canberra OpenEMS software.

1.1 Executive Summary The radioactive effluent monitoring program for the calendar year 2014 was conducted as described in the following report. The results of the monitoring program indicate the continued effort to maintain the release of radioactive effluents to the environment as low as reasonably achievable (ALARA).

In June 2009, the NRC provided revised guidance in Regulatory Guide 1.21, Measuring, Evaluatingand Reporting Radioactive Materialin Liquid and Gaseous Effluents and Solid Waste, Revision 2, establishing an updated approach for identifying principal radionuclides. Because the overall quantity of radioactive releases has steadily decreased due to improvements in power plant operations, carbon 14 (C-14) now qualifies as a "principal radionuclide" (anything greater than one percent of overall radioactivity in effluents) under federal regulations at many plants. In other words, C-14 has not increased and C-14 is not a new nuclear plant emission. Rather, the improvements in the mitigation of other isotopes have made C-14 more prominent.

Attachment 10.3 on page 50 provides more detail about C-14.

Gaseous Effluents:

A summary of all the radioactive gaseous releases to the environment during 2014:

Gaseous Waste 2013 2014 Comments Tritium 35.8 Ci 30.1 Ci 1 C-14 Activity 23.4 Ci 23.45 Ci Total Fission and Activation Activity 0.88 Ci 0.49 Ci 2 Total Particulate Activity 0 Ci 3.72 E-06 Ci 3 Gross Alpha Activity 0 Ci 0 Ci 4 Iodine Activity 0 Ci 0 Ci 4 Calculated Gamma Air Dose 3.86E-04 mRad 4.05E-04 mRad 5 Calculated Beta Air Dose 2.33E-04 mRad 1.53 E-04 mRad 2 Total Whole body dose 0.09 mRem 0.09 mRem Comments:

1. The major contributor to gaseous tritium activity is evaporation from the spent fuel pools.

Factors contributing to the tritium activity in the pools is related to the type of fuel used (i.e.,

18-month fuel) the core life, power output, and number of core cycles.

2. There were 3 gas decay tanks released in 2013 and 0 in 2014.
3. Released during Unit 1 outage. Dose to the public from this activity is within the required limits of 10CFR50 Appendix I.
4. No alpha or iodine activity was released.

Page 5 of 53

5. There were 2 refueling outages in 2014 contributing to a slightly higher gamma air dose.

Overall the gaseous radioactivity releases from CPNPP are well controlled and maintained ALARA.

CPNPP is well below all applicable limits for gaseous releases. Neither unit had fuel defects during 2014.

Liquid Effluents:

A summary of all the radioactive liquid releases to the environment during 2014:

Liquid Waste 2013 2014 Comments Total Activity (excluding tritium) 3.47E-03 Ci 8.61E-4 Ci 1 Tritium Activity 919 Ci 2080 Ci 2 Total Whole Body Dose 0.175 mRem 0.182 mRem 3 Total Volume Released 697886 gal 929987 gal 2 Comments

1. Radwaste replaced a Cs-specific resin ion exchanger (IX) with a cation resin IX in their waste processing equipment. This change resulted in a significant reduction of liquid activity released.
2. There were 2 refueling outages in 2014.
3. Although the total curies released are slightly lower in 2013, the specific isotopes released have the highest dose factors and are approximately the same as those in 2014. Thus although the activity released was slightly higher in 2014, the dose is approximately the same as that from 2013.

Page 6 of 53

Meteorological Data The CPNPP meteorological system achieved a.greater than 99.9% recoverable data rate for the joint frequency parameters required by Regulatory Guide 1.23 for wind speed, wind direction and delta temperature. See section 7.1 for the actual recovery percentages.

Monitors OOS > 30 Days During 2014 there were no Technical Specification/ODCM effluent radiation monitors out of service for

>30 days.

ODCM Changes There were no changes made to the ODCM during 2014.

Solid Waste Summary of the solid waste production Total Waste 2013 2014  % Error Shipped (m3) 412 343 25%

Shipped (Ci) 235 608 25%

Buried (m3) 49.1 38.7 25%

Buried (Ci) 235 608 25%

Comments In 2014 CPNPP continued to ship and bury stored Class B and Class C wastes at the compact disposal facility in Andrews, Texas. In advance of the compliance date for 10 CFR 37, waste containers with the highest radioactivity, particularly those exceeding category two quantities, were chosen to be shipped. In 2013, CPNPP had just began shipments to the new Andrews, Texas disposal facility and the waste containers chosen for shipment represented lower total activity to allow the staff to become familiar with the new procedure processes required by the new facility. Buried volume in both years are similar since these values are normally associated with Class A Dry Active Waste that represents an order of magnitude more volume than Class B and Class C wastes packaged in 120 cubic feet, or about 3 cubic meter, containers.

Groundwater Tritium Sentinel Well location CP-A near the Water Plant and Monitor Well 11 (which is directly down gradient from CP-A) both showed positive for tritium. The source of the tritium was from a leaking pipe in 2013 that goes from the Water Treatment Plant and Microfiltration Building sumps to the Low Volume Waste (LVW) Pond. Because Squaw Creek Reservoir (SCR) water contains a low background concentration of tritium, SCR water used in the plant will contain similar concentrations. All of these samples were well below the state drinking water reportable criteria of 20,000 pCi/L and the environmental reportable criteria of 30,000 pCi/L. The leaking pipe has been repaired.

All other monitoring well samples during 2014 were < Minimum Detectable Activity (MDA) for tritium.

Page 7 of 53

See section 8.8 for details.

Conclusion Overall, the radioactive effluent monitoring program has been conducted in an appropriate manner to ensure the activity released and associated dose to the public has been maintained as low as reasonably achievable (ALARA)

Page 8 of 53

1.2 Historical Trend Graphs Total Gaseous Fission and Activation Activity Released from CPNPP 996.9 0

C 0

0 U

0 0

En (U

C, 0

I-Year Total Gaseous Tritium Released from CPNPP 90.00 80.00 77.60 70.00-61.27 0 50.0 - l43.2 0 43.90 43.60432 o lI40.50 U40.00-3.

300029.60 30.1 20.00-10.00-0 .00 .....

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Page 9 of 53

Total Whole Body Dose due to Gaseous Activity released from CPNPP 0.12 0 2007 increase resulted from increasing SFP 0.11 0.11 evaporation rates due to larger amounts of stored fuel. Beyond 2007, increases attributed 0.10 0to Unit 1 and 2 power uprates: Unit 1, 2008, and Unit 2, 2009. 0.90.09 0.09

  • 0 0.0 00.0 8 .0 0.08 .0
  • ~0.06 - - 0.06 0.2 0.00 -

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Total Volume Liquid Effluents Released from CPNPP 100000000 10000000 0

1000D00 100000 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Page 10 of 53

Total Activity (Excluding H3) Released in Liquid Effluents from CPNPP E

g%200.00 199 1997 1998 1M99 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Total Curies of Tritium Released in Liquid Effluents from CPNPP 3000-2790 2500- 2426 2430 2080 2000-______

t1623 0 1430 1480 1520 986 1080

-j 1000 ___

669 0

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Page 11 of 53

Total Volume of Solid Radwaste Buried from CPNPP 1800 1620 1600 1400 1200 E 1000 800 E

608 600 400

%I 66 47 475I,559 . ,.. ., ,.

200 0

1998 1997 199 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Page 12 of 53

Total Curies of Solid Radwaste Buried from CPNPP 200.00 180.00 180.00 160.00 10 140.00

_120.00 000 90.20 80.00 -70.7 65,6m

  • 60.0046.8 49.

40.0038.7 2.g 187 193 16.2.

2000-271 19.0 0.00 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Year Page 13 of 53

2.0 SUPPLEMENTAL INFORMATION 2.1 Re2ulatory Limits The ODCM Radiological Effluent Control limits applicable to the release of radioactive material in liquid and gaseous effluents are described in the following sections.

2.1.1 Fission and Activation Gases (Noble Gases)

The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 500 mRem/yr to the whole body and less than or equal to 3000 mRem/yr to the skin.

The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the site boundary shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mRad for gamma radiation and less than or equal to 10 mRad for beta radiation, and
b. During any calendar year: Less than or equal to 10 mRad for gamma radiation and less than or equal to 20 mRad for beta radiation.

2.1.2 Iodine-131. Iodine-133, Tritium and Radioactive Material in Particulate Form The dose rate due to iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, released in gaseous effluents from the site to areas at and beyond the site boundary, shall be limited to less than or equal to 1500 mRem/yr to any organ.

The dose to a MEMBER OF THE PUBLIC from iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released, from each unit, to areas at and beyond the site boundary, shall be limited to the following:

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.

2.1.3 Liquid Effluents The concentration of radioactive material released in liquid effluents to unrestricted areas shall be limited to 10 times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.OE-4 gCi/ml total activity.

The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to unrestricted areas shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mRem to the whole body and to less than or equal to 5 mRem to any organ, and Page 14 of 53

2.1.3 b. During any calendar year to less than or equal to 3 mRem to the whole body and to less than or equal to 10 mRem to any organ.

2.1.4 LVW Pond Resin Inventory The quantity of radioactive material contained in resins transferred to the LVW pond shall be limited by the following expression:

(264/V)

  • Yj A/Cj < 1.0 excluding tritium, dissolved or entrained noble gases and radionuclides with less than an 8 day half life, where:

Aj = pond inventory limit for a single radionuclide j (Curies),

Cj = 10CFR20, Appendix B, Table 2 Column 2, concentration for a single radionuclide j (gCi/mL),

V = volume of resins in the pond (gallons), and 264 = conversion factor ([iCi/Ci per mL/gal) 2.1.5 Total Dose The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mRem to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mRem.

2.2 Effluent Concentration Limits 2.2.1 Gaseous Effluents For gaseous effluents, effluent concentration limits (ECL) values are not directly used in release rate calculations since the applicable limits are expressed in terms of dose rate at the site boundary.

2.2.2 Liquid Effluents The values specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 are used as the ECL for liquid radioactive effluents released to unrestricted areas. A value of 2.OE-04 [tCi/mL is used as the ECL for dissolved and entrained noble gases in liquid effluents.

2.3 Measurements and Approximations of Total Radioactivity Measurements of total radioactivity in liquid and gaseous radioactive effluents were accomplished in accordance with the sampling and analysis requirements of Tables 4.11-1 and 4.11-2, respectively, of the CPNPP ODCM.

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2.3.1 Liquid Radioactive Effluents Each batch release was sampled and analyzed for gamma emitting radionuclides using gamma spectroscopy. Composite samples were analyzed monthly and quarterly for the Primary Effluent Tanks (PET), Waste Monitor Tanks (WMT), Laundry Holdup and Monitor Tanks (LHMT) and Waste Water Holdup Tanks (WWHT). Composite samples were analyzed monthly for tritium and gross alpha radioactivity in the onsite laboratory using liquid scintillation and gas flow proportional counting techniques, respectively. Composite samples were analyzed quarterly for Sr-89, Sr-90, Fe-55, and Ni-63 by a contract laboratory. The results of the composite analyses from the previous month or quarter were used to estimate the quantities of these radionuclides in liquid effluents during the current month or quarter. The total radioactivity in liquid effluent releases was determined from the measured and estimated concentrations of each radionuclide present and the total volume of the effluent released during periods of discharge.

For batch releases of powdex resin to the LVW pond, samples were analyzed for gamma emitting radionuclides, using gamma spectroscopy techniques. Composite samples were analyzed quarterly for Sr-89 and Sr-90 by a contract laboratory.

For continuous releases to the Circulating Water Discharge from the LVW pond, daily grab samples were obtained over the period of pond discharge. These samples were composited and analyzed for gamma emitting radionuclides, using gamma spectroscopy techniques. Composite samples were also analyzed for tritium and gross alpha radioactivity using liquid scintillation and gas flow proportional counting techniques respectively. Composite samples were analyzed quarterly for Sr-89, Sr-90, Fe-55, and Ni-63 by a contract laboratory.

2.3.2 Gaseous Radioactive Effluents Each gaseous batch release was sampled and analyzed for radioactivity prior to release. Waste Gas Decay Tank samples were analyzed for gamma emitting radionuclides. Containment Building charcoal (iodine), particulate, noble gas, and tritium grab samples were also analyzed for radioactivity prior to each release. The results of the analyses and the total volume of effluent released were used to determine the total amount of radioactivity released in the batch mode.

For continuous effluent release pathways, noble gas and tritium grab samples were collected and analyzed weekly. Samples were analyzed for gamma emitting radionuclides by gamma spectroscopy and liquid scintillation counting techniques. Continuous release pathways were continuously sampled using radioiodine adsorbers and particulate filters. The radioiodine adsorbers and particulate filters were analyzed weekly for 1-131 and gamma emitting radionuclides using gamma spectroscopy. Results of the noble gas and tritium grab samples, radioiodine adsorber and particulate filter analyses from the current week and the average effluent flow rate for the previous week were used to determine the total amount of radioactivity released in the continuous mode. Monthly composites of particulate filters were analyzed for gross alpha activity, in the onsite laboratory using the gas flow proportional counting technique. Quarterly composites of particulate filters were analyzed for Sr-89 and Sr-90 by a contract laboratory.

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C-14 was estimated in accordance with the methodology in the EPRI report Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents. EPRI, Palo Alto, CA: 2010, 1021106. See attachment 10.3 on page 50 for more information on C-14.

2.4 Batch Releases A summary of information for liquid and gaseous batch releases is included in Table 9.1.

2.5 Abnormal or Unplanned Releases Abnormal or unplanned releases are defined as the unintended discharge of a volume of liquid or airborne radioactivity to the environment. There were no abnormal (monitored) or unplanned gaseous effluent releases during 2014.

3.0 GASEOUS EFFLUENTS The quantities of radioactive material released in gaseous effluents are summarized in Tables 9.3 and 9.4. All releases of radioactive material in gaseous form are considered to be ground level releases.

4.0 LIQUID EFFLUENTS The quantities of radioactive material released in liquid effluents are summarized in Tables 9.5 and 9.6.

5.0 SOLID WASTES The quantities of radioactive material released as solid effluents are summarized in Table 9.10.

6.0 RADIOLOGICAL IMPACT ON MAN 6.1 Dose Due to Liquid Effluents The dose to an adult from the fish and cow-meat consumption pathways from Squaw Creek Reservoir were calculated in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in table 9.7.

6.2 Dose Due to Gaseous Effluents The air dose due to gamma emissions and the air dose due to beta emissions were calculated using the highest annual average atmospheric dispersion factor at the Site Boundary location, in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table 9.8.

6.3 Dose Due to Radioiodines, Tritium and Particulates The dose to an adult, teen, child, and infant from radio-iodines and particulates, for the pathways listed in Part II, Table 2.4 of the ODCM, were calculated using the highest dispersion and deposition factors, as appropriate, in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table Page 17 of 53

9.9. Because of pathway similarity, C-14 dose is included in this table.

6.4 40CFR190 Dose Evaluation ODCM Radiological Effluent Control 3.11.4 requires dose evaluations to demonstrate compliance with 40 CFR Part 190 only if the calculated quarterly or yearly dose exceed two times the applicable quarterly or annual dose limits. At no time during 2014 were any of these limits exceeded, therefore no evaluations are required.

6.5 Dose to a MEMBER OF THE PUBLIC From Activities Inside the Site Boundary Three activities are considered in this evaluation: fishing on Squaw Creek Reservoir, recreation activities at the CPNPP employee recreational area and site tours through the CPNPP Visitors Center.

The highest dose occurred in the evaluation for fishing, resulting in a dose of 1.42E-03 mRem/yr.

The dose to a MEMBER OF THE PUBLIC (fisherman) on Squaw Creek Reservoir was calculated based on fishing twice a week, five hours each day, six months per year. Pathways included in the calculation were gaseous inhalation and submersion. Liquid pathways are not considered since all doses are calculated at the point of circulation water discharge into the reservoir.

The dose to a MEMBER OF THE PUBLIC engaged in recreational activities at the CPNPP employee recreational park was calculated based on one visit a week, five hours each day, six months per year. Pathways included in the calculation were gaseous inhalation, submersion and ground plane.

The dose to a MEMBER OF THE PUBLIC during site tours through the CPNPP Visitors Center was calculated based on two visits per year, thirty minutes each visit. Pathways included in the calculation were gaseous inhalation and submersion.

All calculations were performed in accordance with the methodology and parameters in the ODCM.

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7.0 METEROLOGICAL DATA 7.1 Meteorological Monitoring Program.

In accordance with ODCM Administrative Control 6.9.1.4, a summary of hourly meteorological data, collected during 2014, is retained onsite. This data is available for review by the NRC upon request. Joint Frequency Tables are included in Attachment 10. During 2014, the goal of >90%

joint data recovery was met. The individual percent recoveries are listed below:

Meteorological Data Recoverv I Channel  % Recovery Wind Speed 99.9%

Wind Direction 99.9%

Delta Temperature A 99.9%

Delta Temperature B 99.9%

8.0 RELATED INFORMATION 8.1 Operability of Liquid and Gaseous Monitoring Instrumentation ODCM Radiological Effluent Controls 3.3.3.4 and 3.3.3.5 require an explanation of why designated inoperable liquid and gaseous monitoring instrumentation was not restored to operable status within thirty days.

During the period covered by this report, there were no instances where these instruments were inoperable for more than thirty days.

8.2 Changes to the Offsite Dose Calculation Manual (ODCM)

During the period covered by this report, there were no changes to the ODCM.

8.3 New Locations for Dose Calculations or Environmental Monitoring ODCM Administrative Control 6.9.1.4 requires any new locations for dose calculations and/or environmental monitoring, identified by the Land Use Census, to be included in the Radioactive Effluent Release Report. Based on the 2014 Land Use Census, no new receptor locations were identified which resulted in changes requiring a revision in current environmental sample locations. Values for the current nearest resident, milk animal, garden, X/Q and D/Q values in all sectors surrounding CPNPP were included in the 2014 Land Use Census.

8.4 Liquid Holdup and Gas Storage Tanks ODCM Administrative Control 6.9.1.4 requires a description of the events leading to liquid holdup or gas storage tanks exceeding the limits required to be established by Technical Specification 5.5.12. Technical Requirements Manual 13.10.33 limits the quantity of radioactive material contained in each unprotected outdoor tank to less than or equal to ten curies, excluding tritium and dissolved or entrained noble gases. Technical Requirements Manual 13.10.32 limits the quantity of radioactive material contained in each gas storage tank to less than or equal to 200,000 curies of noble gases (considered as Xe-133 equivalent). These limits were not exceeded during the period covered by this report.

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8.5 Noncompliance with Radiological Effluent Control Requirements This section provides a listing and description of Abnormal Releases, issues that did not comply with the applicable requirements of the Radiological Effluents Controls given in Part I of the CPNPP ODCM and/or issues that did not comply with associated Administrative Controls and that failed to meet CPNPP expectations regarding Station Radioactive Effluent Controls. Detailed documentation concerning evaluations of these events and corrective actions is maintained onsite.

8.5.1 Normal, Unplanned Gaseous Release There were no normal, unplanned gaseous effluent releases occurred during 2014.

8.5.2 Abnormal, Unplanned Gaseous Effluent Release No abnormal, unplanned gaseous effluent releases occurred during 2014.

8.5.3 Abnormal, Unplanned Liquid Effluent Releases No abnormal, unplanned liquid effluent releases occurred during 2014.

Page 20 of 53

8.6 Resin Releases to the LVW Pond A total of 252 ft3 of powdex resin was transferred to the LVW pond during the period covered by this report. The cumulative activity deposited in the LVW pond since operations began through the end of 2014 is 2.03e-3 Curies, consisting of Co-58, Co-60, Cs-134, Cs-137, 1-131, Sr-90 and Sb-125.

8.7 Changes to the Liquid. Gaseous, and Solid Waste Treatment Systems In accordance with the CPNPP Process Control Program, Section 6.2.6.2, changes to the Radwaste Treatment Systems (liquid, gaseous and solid) should be summarized and reported to the Commission in the Radioactive Effluent Release Report if the changes implemented required a 10CFR50.59 safety evaluation.

For the reporting period of this report, no changes to the Radwaste Treatment Systems occurred that meet the reporting criteria of the Process Control Program.

Paqe 21 of 53

8.8 Groundwater Tritium monitoring Program The wells used to monitor CPNPP for tritium leaks into the ground water all had results that were less than detectable with the exception of sentinel well CP-A and MW-11 near the Water Plant during the third and fourth quarters of 2013 and most of 2014. CR-2013-012215 documents this issue. By quarter 4 of 2014, CP-A tritium was back to less than detectable.

MW- 11, which is directly down gradient from CP-A, showed positive tritium results for the last 3 quarters of 2014. This is documented by CR-2014-007981.

The source of the tritium was from a leaking pipe that goes from the Water Treatment Plant and Microfiltration Building sumps to the Low Volume Waste (LVW) Pond. Because Squaw Creek Reservoir (SCR) water always contains a low background concentration of tritium, SCR water used in the plant will contain similar concentrations. All of these samples were well below the state drinking water reportable criteria of 20,000 pCi/L and the environmental reportable criteria of 30,000 pCi/L. The leaking pipe has been repaired.

Other areas that are also monitored, but are not considered part of the ground monitoring program include the seepage sump, and Leachate Basins A,B, and C. These sample points are actually of perched (surface) and not indicative of ground water tritium.

Previous hydrogeology studies performed by Pastor, Behling and Wheeler LLC, showed that this perched water sits above an impermeable layer of bedrock. This prevents the migration of the tritiated perched water into the Twin Mountain Aquifer and a potential new pathway to drinking water sources but is re-routed back to Squaw Creek Reservoir.

Groundwater monitoring wells below the perched layer have not identified any tritium above the MDA and confirm the claims of the hydrogeology study. Based on this information and the guidance in NEI 07-07, there is no requirement for notification to the NRC or local officials and no requirement for remediation as it is not considered licensed material. Continued monitoring of these perched water sample points will occur as part of the Groundwater Monitoring Program (STA-654) and any new sources of tritium or increase in the activity will be evaluated and remediated as necessary.

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Ground Water Tritium Results (pCi/L)

MW 02/19/13 05/14/13 08/14/13 11/27/13 02/19/14 05/14/14 07/15/14 12/10/14 Location 9 <649 <616 <766 <775 <778 <688 <709 <603 10 <649 <616 <766 <775 <778 <688 <709 <603 11 <649 <616 <766 <775 908** 2470** 2870** 1500**

12 <649 <616 <766 <775 <788 <688 <709 <603 14 <649 <616 <766 <775 <788 <688 <709 <603 15 DRY DRY DRY DRY DRY DRY DRY DRY 16 <649 <616 <766 <775 <778 <688 <709 <603 19 <649 <616 <766 <775 <778 <688 <709 <603 25 <649 <616 <766 <775 <788 <688 <709 <603 CP-A <649 <616 6020* 12200* 12900* 9290* 1640* <603 CP-B <649 <616 <766 <775 <788 <688 <709 <603 CP-C <649 <616 <766 <775 <788 <688 <709 <603 OSGSF DRY DRY DRY DRY DRY DRY DRY DRY

  • CR-2013-0122 f5 Result was attributed to a leak in a water treatment plant line (lake water)
    • CR-2014-007981 MW- Il is directly down gradient from CP-A Page 23 of 53

Ground Water Tritium Monitoring Well Map EXPLANATION (WealheredGIet R-~ Foo.T,*)

(U-eeJ.t.d GIW,Rms F-9.lie)

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TM M  : R4 IREMIEENS:

PASTOR, BEHLING & WHEELER LLC CONSULTINGENGMIEENSAND SCIENTISTS Page 24 of 53

SECTION 9.0 EFFLUENT TABLES Page 25 of 53

Table 9.1 Site Liquid and Gaseous Batch Release Summary (2014)

A. Liquid Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual

1. Number of batch releases 19 9 8 11 47
2. Total time period for Batch releases (Minutes) 6.32E+03 3.06E+03 2.69E+03 3.67E+03 1.57E+04
3. Maximum time period for a batch release (Minutes) 3.62E+02 3.67E+02 3.65E+02 3.66E+02 3.67E+02
4. Average time period for a batch release (Minutes) 3.33E+02 3.40E+02 3.36E+02 3.34E+02 3.35E+02
5. Minimum time period for a batch release (Minutes) 2.84E+02 3.16E+02 3.09E+02 2.90E+02 2.84E+02 B. Gaseous Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual
1. Number of batch releases 34 27 28 34 123
2. Total time period for batch releases (Minutes) 1.34E+04 1.85E+04 9.33E+03 1.83E+04 5.94E+04
3. Maximum time period for a batch release (Minutes) 1.71E+03 8.46E+03 3.81E+02 7.15E+03 8.46E+03
4. Average time period for a batch release (Minutes) 3.93E+02 6.85E+02 3.33E+02 5.37E+02 4.83E+02
5. Minimum time period for a batch release (Minutes) 1.36E+02 2.94E+02 2.64E+02 5.50E+01 5.50E+01 Page 26 of 53

Table 9.2 Site Abnormal Liquid and Gaseous Batch Release Summary (2014)

A. Liquid Abnormal Release Totals Units Quarter I Quarter 2 Quarter 3 Quarter 4 Totals

1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 B. Gas Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Totals
1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 Page 27 of 53

Table 9.3 Site Gaseous Effluents - Summation of All Releases (2014)

Type of Effluent Units Quarter Quarter Quarter Quarter Total 1 2 3 4 A. Fission And Activation Gases

1. Total Release Curies 1.42E-01 1.06E-01 1.07E-01 1.34E-01 4.89E-01
2. Average Release rate for period uCi/sec 1.83E-02 1.35E-02 1.34E-02 1.68E-02 1.55E-02
  • t
3. Percent of Applicable Limit B. Radioiodines
1. Total Iodine-131 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 O.OOE+00
2. Average Release rate for period 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 O.OOE+00
3. Percent of Applicable Limit C. Particulates
1. Particulates ( Half-Lives > 8 Days

) 0.OOE+00 0.OOE+00 0.OOE+00 3.72E-06 3.72E-06

2. Average Release rate for period 0.OOE+00 0.OOE+00 0.OOE+00 4.68E-07 1.18E-07
3. Percent of Applicable Limit D. Tritium
1. H3 Release Curies 5.05E+00 8.97E+00 9.33E+00 6.71E+00 3.01E+01
2. Average Release rate for period uCi/sec 6.50E-01 1.14E+00 1. 17E+00 8.44E-01 9.53E-01
3. Percent of Applicable Limit D. C14
1. C14 Release Curies 6.33E+00 5.66E+00 6.74E+00 4.73E+00 2.35E+01
2. Average Release rate for period uCi/sec 8.15E-01 7.19E-01 8.45E-01 5.95E-01 2.97E+00
3. Percent of Applicable Limit Gross Alpha
1. Total Release Curies 0.OOE+00 0.OOE+00' 0.00E+00 0.OOE+00 0.OOE+00
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is < 1.0%

Page 28 of 53

Table 9.4 Site Gaseous Effluents - Ground Level Releases (2014)

ContinuousMode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total Fission Gases No Nuclides Found Curies N/A N/A N/A N/A N/A lodines No Nuclides Found Curies N/A N/A N/A N/A N/A Particulates Co-58 Curies O.OOE+00 O.OOE+00 O.OOE+00 3.72E-06 3.72E-06 Tritium & C-14 H-3 Curies 4.98E+00 8.90E+00 9.29E+00 6.67E+00 2.98E+01 C14 C-14 Curies 1.90E+00 1.70E+00 2.02E+00 1.42E+00 7.04E+00 Gross Alpha No Nuclides Found Curies N/A N/A N/A N/A N/A Page 29 of 53

Table 9.4 (cont)

Site Gaseous Effluents - Ground Level Releases (2014)

Batch Mode Nuclides Released Unit Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total Fission Gases Xe-127 Curies 0.OOE+00 0.OOE+00 0.OOE+00 1.86E-05 1.86E-05 Ar-41 Curies 1.16E-01 8.51E-02 9.78E-02 1.14E-01 4.12E-01 Kr-85m Curies 6.77E-05 0.00 E+00 0.OOE+00 2.50E-05 9.27E-05 Kr-85 Curies 1.22E-03 9.78E-03 0.OOE+00 3.25E-03 1.43E-02 Kr-87 Curies 0.OOE+00 0.OOE-i00 0.OOE+00 2.46E-05 2.46E-05 Kr-88 Curies 0.OOE+00 2.79E-06 0.OOE+00 8.70E-05 8.98E-05 Kr-89 Curies 0.OOE+00 0.OOE+00 0.OOE+00 5.08E-06 5.08E-06 Xe-131m Curies 9.86E-06 7.97E-06 0.OOE+00 0.OOE+00 1.78E-05 Xe-133m Curies 7.45E-05 O.OOE+00 0.OOE+00 3.12E-04 3.86E-04 Xe-133 Curies 1.82E-02 1.15E-02 8.96E-03 1.39E-02 5.25E-02 Xe-135m Curies 5.93E-05 0.OOE+00 0.OOE+00 1.9 1E-05 7.83E-05 Xe-135 Curies 6.67E-03 0.OOE+00 0.OOE+00 2.16E-03 8.84E-03 Xe-138 Curies 0.OOE+00 0.OOE+00 0.OOE+00 1.10E-04 1.1OE-04 Total For Period Curies 1.42E-01 1.06E-01 1.07E-01 1.34E-01 4.89E-01 lodines No Nuclides Found Curies N/A N/A N/A N/A N/A Particulates No Nuclides Found Curies N/A N/A N/A N/A N/A Tritium H-3 Curies 7.08E-02 7.37E-02 3.37E-02 3.74E-02 2.16E-01 Carbon 14 C-14 Curies 4.43E+00 3.96E+00 4.72E+00 3.31E+00 1.64E+01 Gross Alpha Curies N/A N/A N/A N/A N/A No Nuclides Found

  • Zeroes in this table indicate that no radioactivity was present at detectable levels.

Page 30 of 53

Table 9.5 Site Liauid Effluents - Summation Of All Releases (2014)

Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual A. Fission And Activation Products

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

Curies 3.10E-04 1.00E-04 1.22E-04 3.29E-04 8.61E-04

2. Average diluted concentration during period uCi/ml 1.74E- I 8.75E-12 1.21E-11 2.64E-11 1.66E-11
3. Percent of Applicable Limit B. Tritium
1. Total Release Curies 1.24E+03 1.98E+02 3.37E+02 3.08E+02 2.08E+03
2. Average diluted concentration during period uCi/m% 6.99E-05 1.72E-05 3.34E-05 2.47E-05 4.02E-05
3. Percent of Applicable Limit C. Dissolved and Entrained Gases
1. Total Release Curies 1.02E-03 7.12E-05 0.OOE+00 8.85E-05 1.18E-03
2. Average diluted concentration during period uCi/ml 5.76E-11 6.21E-12 0.OOE+00 7.10E-12 2.28E-11
3. Percent of Applicable Limit D: Gross Alpha Radioactivity
1. Total Release Curies 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00
2. Average diluted concentration during period uCi/ml 0.00E+00 0.OOE+00 0.00E+00 0.OOE+00 E: Waste Vol Release (Pre-Dilution) Liters 1.43E+06 6.72E+05 5.95E+05 8.18E+05 3.52E+06 F. Volume of Dilution Water Used Liters 1.78E+10 1.15E+10 1.01E+10 1.25E+10 5.18E+10
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is < 1.0%

Page 31 of 53

Table 9.6 Site Liquid Effluents (20 14)

ContinuousMode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission & Activation Products No Nuclides Found Curies O.OOE+O0 O.OOE+O0 O.OOE+O0 O.OOE+O0 O.OOE+O0 Tritium H-3 Curies O.OOE+O0 O.OOE+O0 O.OOE+O0 O.OOE-i-O O.OOE+OO Dissolved And Entrained Gases No Nuclides Found Curies O.OOE+O0 O.OOE+OO O.OOE+O0 O.OOE+O0 O.OOE+O0 Gross Alpha Radioactivity Curies O.OOE+O0 O.OOE+OO O.OOE+O0 O.OOE+O0 O.OOE+O0 Page 32 of 53

Table 9.6 (cont.)

Site Liquid Effluents (2014)

Batch Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual A. Fission & Activation Products Co-57 Curies 8.08E-08 3.53E-07 O.OOE+O0 1.85E-07 6.19E-07 Co-58 Curies 4.59E-05 9.27E-05 1.17E-04 3.1OE-04 5.66E-04 Co-60 Curies 8.31E-06 7.24E-06 4.81E-06 1.89E-05 3.93E-05 Ni-63 Curies 2.55E-04 O.OOE+O0 O.OOE+O0 O.OOE+OO 2.55E-04 Total For Period Curies 3.10E-04 1.OOE-04 1.22E-04 3.29E-04 8.61E-04 B. Tritium H-3 Curies 1.24E+03 1.98E+02 3.37E+02 3.08E+02 2.08E+03 C. Dissolved And Entrained Gases Xe-133 Curies 1.02E-03 7.12E-05 O.OOE+OO 8.85E-05 1.18E-03 D. Gross Alpha Activity No Nuclides Found Curies O.OOE+O0 O.OOE+O0 O.OOE+O0 O.OOE+O0 O.OOE+O0 If Not Detected, Nuclide is Not Reported. Zeroes in this table indicates that no radioactivity was present at detectable levels.

Page 33 of 53

Table 9.7 Dose to a member of the public due to Liquid Releases (2014)

Organ Dose Units Quarter I Quarter 2 Quarter 3 Quarter 4 Annual Bone mRem 4.71E-05 0.OOE+00 0.OOE+00 0.OOE+00 4.71E-05 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.001 0.00 0.00 0.00 0.00 Liver mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.759 0.88 0.988 1.022 1.824 Total Body mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 1.5 1.5 1.5 1.5 3 Percent of Limit  % 2.528 2.933 3.292 3.408 6.081 Thyroid mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.758 0.88 0.988 1.022 1.824 Kidney mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.758 0.88 0.988 1.022 1.824 Lung mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.758 0.88 0.988 1.022 1.824 GI-Lli mRem 3.79E-02 4.40E-02 4.94E-02 5.11E-02 1.82E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.758 0.88 0.988 1.022 1.824 Page 34 of 53

Table 9.8 Air Dose Due To Gaseous Releases - Site (2014)

NG Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Gamma Air mRad 1.15E-04 8.33E-05 9.55E-05 1. 12E-04 4.05E-04 Limit mRad 5 5 5 5 10 Percent of Limit 0.002 0.002 0.002 0.002 0.004 Beta Air mRad 4.37E-05 3.25E-05 3.45E-05 4.20E-05 1.53E-04 Limit mRad 10 10 10 10 20 Percent of Limit 0 0 0 0 0.001 Page 35 of 53

Table 9.9 Dose to A Member Of The Public Due To Radioiodines, Tritium, and Particulates in Gaseous Releases (2014)

Organ Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Liver mRem 1.85E-02 2.28E-02 2.52E-02 1.79E-02 8.44E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.246 0.304 0.336 0.239 0.563 Total Body mRem 2.33E-02 2.33E-02 2.54E-02 2.02E-02 9.23E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.310 0.311 0.339 0.269 0.615 Thyroid mRem 2.33E-02 2.33E-02 2.54E-02 2.02E-02 9.23E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % .0.310 0.311 0.339 0.269 0.615 Kidney mRem 2.33E-02 2.33E-02 2.54E-02 2.02E-02 9.23E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.310 0.311 0.339 0.269 0.615 Lung mRem 2.33E-02 2.33E-02 2.54E-02 2.02E-02 9.23E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.310 0.311 0.339 0.269 0.615 GI-Lli mRem 2.33E-02 2.33E-02 2.54E-02 2.02E-02 9.23E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.310 0.311 0.339 0.269 0.615 Bone mRem 5.88E-02 5.26E-02 6.27E-02 4.39E-02 2.18E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.78 0.70 0.84 0.59 1.45 Page 36 of 53

TABLE 9.10 SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2014 A. Solid Waste Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)

Shipped Shipped Buried Buried Percent I. Type of Waste M Ci Ci W Error

a. Spent resins/filters 1.70E+01 6.08E+02 1.70E+01 6.08E+02 25%
b. Dry active waste 3.26E+02 9.22E-02 2.17E+01 7.23E-02 25%
c. Irradiated components N/A
d. Other (oil/miscellaneous liquids sent to processor for volume N/A reduction)

TOTAL 3.43E+02 6.08E+02 3.87E+O1 6.08E+02 25%

Note: Shipped volumes and curies are not always equal to the buried volumes and curies since some disposal occurs outside the twelve month time period in which shipments occurred.

Dry active waste also includes some low-level radioactive resins, tank sediments and filters that are handled and processed in a manner that is consistent with this waste stream.

2. Estimate of Major Nuclide Composition (by type of Nuclide  % Activity waste) Abundance. (Ci)

Ni-63 56.89 3'.46e+02 Fe-55 16.99 1.03E+02 Co-60 8.25 5.02E÷01 Cs-137d 6.30 3.83E+01 Co-58 4.64 2.82E+01 H-3 2.00 1.22E+01

a. Spent resins/filters Cs-134 1.96 1.19E+01 C-14 1.09 6.64E+00 Tc-99 <0.01 9.13E-03 1-129 LLD OTHER* 1.88 1.14E+01 TOTAL 100.00 6.08E+02
  • Nuclides representing < 1% of total shipped activity: Mn-54,Co-5 7,Ni-59,Zn-65,Sr-90,Zr-95,Nb-94,Nb-95,Sn- 113,Sb- 125,Ce-144,Pu-238,Pu-239/40,Am-241 ,Cm-243/44.

Page 37 of 53

TABLE 9.10 (cont.)

SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2014 A. Solid Waste Shipped Offsite for Burial or Disposal (Not Irradiated Fuel) cont.

2. Estimate of Major Nuclide Composition (by type of Nuclide  % Activity waste) Abundance. (Ci)

Ni-63 37.29 3.44E-02 Fe-55 29.41 2.71E-02 Co-60 29.11 2.68E-02 Sb-125 1.21 1.12E-03 Mn-54 1.21 1.11E-03

b. Dry active waste C-14 0.32 2.94E-04 H-3 LLD Tc-99 LLD 1-129 LLD Other* 1.45 1.34E-03 Total 100.00 9.22E-02
  • Nucli(des representing <1% of total shipped activity: K-40,Cr-5 1,Co-57,Co-58,Sr-90d,Zr-95,Nb-94,Nb-95,Sn- 113,Cs- 134,Cs-137d,Ce- 144d,Hg-203,Pu-239/40,Am-241, Am-243.
2. Estimate of Major Nuclide Composition (by type of Nuclide 0 Activity waste) Abundance. (Ci)
d. Other (oil/miscellaneous liquids sent to processor for volume N/A N/A N/A reduction)

Waste Type Waste Container Number of Class Type Shipments Destination Waste Control B Poly HIC* 4 Specialists, Andrews, TX

a. Resin/filters Waste Control C Poly HIC* 1 Specialists, Andrews, TX
b. Dry active waste Energy A General Design 5 Solutions Oak Ridge, TN.
d. Other NA NA NA NA
  • TT* I T ....

H-lgn integrity Contalner B. Irradiated Fuel Shipments (Disposition)

Number of Shipments Mode of Transportation Destination 0 N/A N/A Page 38 of 53

Attachment 10.1 2014 Meteorological Joint Frequency Table Page 39 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS A ELEVATION:

10m.

114 NNE

+

NNE + + t I NE ENE E

ESE SE SSE S

SSW SW WSW W

WNW NW NNW VARIABLE TOTAL Periods of calm (hours):

Hours of missing data:

Page 40 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS B ELEVATION:

1Om.

114 NNE NE ENE E

ESE SE SSE S

SSW SW WSW W

WNW NW NNW VARIABLE TOTAL 1 Periods of calm (hours):

Hours of missing data:

Page 41 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY C CLASS ELEVATION:

1Om.

N NNE 3 3 NE ENE E

ESE SE SSE S

SSW SW WSW W

WNW NW NNW 22 VARIABLE TOTAL 325 Periods of calm (hours):

Hours of missing data:

Page 42 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS D ELEVATION:

1Om.

1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 44 114 88 26 1 273 NNE 3 18 18 9 1 49 NE 16 49 1 66 ENE 1 32 46 2 81 E 87 70 5 162 ESE 2 118 163 20 303 SE 1 76 282 161 44 564 SSE 1 79 313 460 132 4 989 S 51 154 201 63 8 478 SSW 3 39 58 33 6 139 SW 46 28 13 87 WSW 1 35 22 16 2 76 W 3 30 30 14 2 79 WNW 2 47 58 36 9 6 158 NW 61 120 118 90 8 397 NNW 3 72 221 285 97 7 685 VARIABLE TOTAL 20 851 1746 1463 472 34 4585 Periods of calm (hours):

Hours of missing data: 1 Page 43 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS E ELEVATION:

1Om.

1I4 4 1 rJl::

ODDZ0zI 4 i*l #'l Z

NNE 8 10 3 21 NE 1 11 15 2 29 ENE 1 31 16 48 E 6 120 16 1 143 ESE 2 189 192 9 392 SE 5 221 552 120 8 906 SSE 7 118 338 199 45 4 711 S 5 88 191 85 24 393 SSW 7 75 61 29 9 181 SW 3 63 35 16 3 120 WSW 10 54 27 5 96 W 4 42 32 14 92 WNW 3 73 94 27 1 198 NW 4 67 62 51 9 2 195 NNW 4 57 104 36 14 4 219 VARIABLE TOTAL 63 1252 1800 602 115 11 3843 Periods of calm (hours):

Hours of missing data:

Page 44 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS F ELEVATION:

1Om.

114 NNE NE ENE E

ESE 1 4 5 SE 1 10 3 14 SSE 6 21 1 28 S 7 22 18 47 SSW 4 34 9 47 SW 2 38 7 47 WSW 3 30 5 38 W 9 12 21 WNW 2 30 5 37 NW 1 12 4 17 NNW 1 1 2 VARIABLE TOTAL 36 214 52 1 303 Periods of calm (hours):

Hours of missing data:

Page 45 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS G ELEVATION:

1Om.

IN4 NNE NE I 1-t 1 ENE E

ESE SE SSE 1 1 S 2 2 SSW 2 2 4 SW 4 4 WSW 1 4 5 W

WNW 1 3 4 NW 1 1 NNW VARIABLE TOTAL 2 16 3 21 Periods of calm (hours):

Hours of missing data:

Page 46 of 53

REG. Guide 1.21 Joint Frequency Table LUMINANT HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2014 00:00 to 31-DEC-2014 23:59 STABILITY CLASS ALL ELEVATION:

10m.

,4 -Tr* ,1e*j N1 I IU IOU LO L afz NNE 3 30 28 12 1 74 NE 1 27 64 3 95 ENE 2 63 62 2 129 E 6 207 86 6 305 ESE 5 311 355 29 700 SE 7 307 837 281 52 1484 SSE 14 219 652 659 177 8 1729 S 12 163 363 287 87 8 920 SSW 14 150 130 62 15 371 SW 5 151 70 29 3 258 WSW 15 123 54 21 2 215 W 16 84 62 28 2 192 WNW 8 153 157 63 10 6 397 NW 5 140 187 169 99 10 610 NNW 7 130 327 322 111 11 908 VARIABLE TOTAL 121 2337 3603 2066 587 45 8759 Periods of calm (hours):

Hours of missing data: 1 Page 47 of 53

Attachment 10.2 Atmospheric Dispersion (x/q) and Deposition (d/q)

Calculation Methodology Discussion Page 48 of 53

CR-2013-001059 evaluated the atmospheric dispersion (x/q) and deposition (d/q) calculation methodology and frequency as they relate to the meteorological data to ensure they are up to date. The CPNPP ODCM does not require a re-evaluation on any frequency or specific criteria for comparison. The NRC guidance documents cited in the ODCM also do not provide any requirements for re-evaluation. Revision 2 of Regulatory Guide 1.21, to which we are not obligated, recommends that 5 years of meteorological data be used to evaluate the dispersion factors and that variation in the factors be within 10% in the non-conservative direction. The re-evaluation of our meteorological data included 6 years of data and meets the criteria.

Meteorological data collected for the original FSAR, the NuBuild FSAR and historical Effluent reports were reviewed. The data list the predominant wind direction, as a percentage, averaged for all speeds and stability classes within the period. For periods not summarized and when the plant was operable (1990-2000) only 1990, 1995 and 1996 show the predominant wind direction to be from the SSE. This information was not included, however, since the data should include a summary of at least 5 years of data. The original dispersion and deposition factors were calculated based on meteorological data collected and summarized from 1972 through 1976 at Comanche Peak. This data show the predominant wind direction to be from the South but only slightly more than winds originating from the SSE. The historical data from 1957-1976 was included in the original FSAR for comparison and show more bias toward the southerly direction but was collected from the Dallas-Fort Worth Airport location. Wind patterns for the DFW Airport were reviewed on the National Weather Service website for 1981-2010 and show that the prevailing wind direction remains, from the South. This accounts for the slight variation in prevailing winds between historical and current data collected on site. During the New Build project for Units 3&4 and from OE 25286 the meteorological data were again summarized from 1997-2006, for Comanche Peak, and showed that the predominant wind direction shifted to the SSE. Using this data, new dispersion and.deposition factors were calculated. The new factors were less conservative when compared to the original dispersion and deposition factors at the Exclusion Area Boundary (See Reference 3). The conclusion was to continue reporting offsite exposures based on the original values. The last column of data in Table 1 is summarized for the purposes of this evaluation and includes meteorological data since the New Build evaluation through 2012. This data, like the NuBuild data, show the predominant wind direction to be from the SSE.

==

Conclusion:==

Although the predominant wind direction frequency changes slightly from SSE to S when comparing the NuBuild Data to the original FSAR and Historical Data, the NuBuild calculations show that dispersion and deposition factors do not increase. Following the NuBuild evaluation, the wind direction remains the same and does not impact the calculation of the dispersion and deposition. Using the original factors would be conservative when calculating doses to the public.

CR-2015-002395 was initiated to document the evaluation of prevailing wind directions for all stability classes over the calendar year 2014. This evaluation is performed annually in accordance with Chemistry Guideline 25, RO to ensure the predominant wind direction has not changed based on the last 5 years of meteorological data including the current year. 2014 predominant wind directions for the ALL stability class category did not Page 49 of 53

change when compared with the five year average including 2014. No recalculation of X/Q or D/Q values are required at this time.

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Attachment 10.3 Carbon 14 Supplemental Information Page 51 of 53

Carbon-14 Supplemental Information Carbon-14 (C-14) is a naturally occurring isotope of carbon produced by interactions with cosmic radiation in the atmosphere with a half-life of 5730 years. Nuclear weapons testing in the 1950s and 1960s significantly increased the amount of C-14 in the atmosphere. C-14 is also produced in commercial nuclear reactors, but the amounts are much less than the amounts produced from natural formation or from weapons testing.

In June 2009, the NRC provided revised guidance in Regulatory Guide 1.21, Measuring,Evaluatingand Reporting Radioactive Materialin Liquid and Gaseous Effluents and Solid Waste, Revision 2, establishing an updated approach for identifying principal radionuclides. Because the overall quantity of radioactive releases has steadily decreased due to improvements in power plant operations, C-14 now qualifies as a "principal radionuclide" (anything greater than one percent of overall radioactivity in effluents) under federal regulations at many plants. In other words, C-14 has not increased and C-14 is not a new nuclear plant emission. Rather, the improvements in the mitigation of other isotopes have made C-14 more prominent.

The dose contribution of C- 14 from liquid radioactive waste is essentially insignificant compared to that contributed by gaseous radioactive waste. Therefore the evaluation of C-14 in liquid radioactive waste is not required by the new Reg. Guide 1.21, Rev. 2. The Reg. Guide 1.21, Rev. 2 also states that the quantity of gaseous C- 14 released to the environment can be estimated by use of a C- 14 source term production model.

A recent study produced by EPRI (Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents, EPRI, Palo Alto, CA: 2010, 1021106) developed a model for estimation of C-14 source production. This model was used by CPNPP for the 2010 Radioactive Effluent Release Report. Also in the CPNPP report, the assumption that 70% of the C-14 gaseous effluent is estimated to be from batch releases (e.g.

WGDTs), and 30% of C-14 gaseous effluent is estimated to be from continuous releases through the unit vents (Ref. IAEA Technical Reports Seiries no. 421, "Management of Waste Containing Tritium aiid.

Carbon-14", 2004).

The C-14 released from PWR's is primarily a mix of organic carbon and carbon dioxide released from the waste gas system. The C-14 species initially produced are primarily in the organic form, such as methane.

The C-14 in the primary coolant can be converted to an inorganic chemical form of primarily carbon dioxide through a chemical transformation. Studies documented by the EPRI Report Characterizationof Carbon-14 Generatedby the NuclearPower Industty, EPRI Palo Alto, CA: 1995, TR-105715, measured C-14 releases from PWRs indicating a range of 70% to 95% organic. The average value was indicated to be 80% organic with the remainder being carbon dioxide. As a result, a value of 80% organic C-14 is assumed by the CPNPP Radioactive Effluent Release Report methodology.

The public dose estimates from airborne C-14 in the CPNPP Effluent report are performed using dose models from NUREG-0 133 and Regulatory Guide 1.109. The dose models and assumptions used for the dose estimates of C-14 are documented in the 2011 ODCM changes. The estimated C-14 dose impact on the maximum organ dose from airborne effluents released during 2011 is well below the 10CFR50, Appendix I, ALARA design objective of 15 mRem/yr per unit.

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Putting Radiation Dose in Context Humans are exposed to radiation every day. The majority comes from natural sources including the earth, food and water consumption, the air, the sun and outer space. A smaller fraction radiation comes from man-made source such as X-rays, nuclear medical treatments, building materials, nuclear power plants, smoke detectors and televisions.

Radiation is measured in units called millirem (mRem). One mRem is a very small amount of exposure. On average, Americans receive 620 mRem of radiation dose every year. Approximately one-half of the dose comes from natural sources and the other half comes from medical procedures such as CAT scans.

The table below can help to give some perspective to dose from various sources.

Source Average Annual Dose Smoke detector in the home 0.008 mRem Live within 50 miles of a nuclear power plant 0.009 lnRem Live within 50 miles of a coal-fired power plant* 0.03 mRem NRC guideline for keeping radiation dose from nuclear power plants as low as 5 mRem reasonably achievable (ALARA)

Round trip flight from New York City to Los Angeles 5 mRem Medical X-ray 10 mRem EPA limit for dose to the public from the commercial nuclear fuel cycle 25 mRem Food and water consrimed throughout the course of one year 30 mRem NRC limit for dose to the public from nuclear power plants 100 mRem Mammogram 100 mRem Average annual exposure for a nuclear power plant worker 120 mRem Average annual exposure from background radiation 300 mRem CT scan 1,000 mRem NRC's annual limit for occupational exposure 5,000 mRem Cardiac catheterization or coronary angiogram 5,000 mRem

  • Coal is naturally radioactive.

Sources: U.S. EnvironmentalProtectionAgency, Health Physics Society.

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