CP-201600387, Transmittal of Year 2015 Radioactive Effluent Release Report

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Transmittal of Year 2015 Radioactive Effluent Release Report
ML16126A228
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/28/2016
From: Thomas McCool, Peters K
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201600387, TXX-16062
Download: ML16126A228 (54)
v • d • e


Text

II Kenneth .J. Peters Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Kenneth.Peters@Luminant.com Glen Rose, TX 76043 Luminant T 254 897 6565 c 817 776 0037 F 254 897 6652 CP-201600387 Ref. # Tech. Spec. 5.6.3 Log# TXX-16062 10CFR50.36a April 28, 2016 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 2015 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, 2015 through December 31, 2015.

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

~efuj.P~

fl.

Thomas McCo~l Site Vice President

U. S. Nuclear Regulatory Commission TXX-16062 Page 2 04/28/2016 Enclosures 1. Comanche Peak 2015 Radioactive Effluent Release Report c- M. L. Dapas, Region IV K. M. Kennedy, Region IV M. Watford, NRR Resident Inspectors, Comanche Peak

Enclosure 1 Comanche Peak 2015 Radioactive Effluent Release Report

~

CPNPP _~~ ~~-~~

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7 Comanche Peak Nuclear Power Plant .

2015 RADIOACTIVE EFFLUENT RELEASE REPORT January 1, 2015 - December 31, 2015 Prepared By: Don Rebstock Date 4/20/ 16 Reviewed By: Dave Valentine Date 4/20/16 Date 4/20/16 Pa e 1 of 51

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 51

TABLE OF CONTENTS 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 Suµnnation 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.l 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 51

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 Page 4 of 51

1.0 Introduction This Radioactive Effluent Release Report, for Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 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, 2015, through December 31, 2015. The data in this report was calculated in accordance with the CPNPP ODCM using the Canberra OpenEMS software.

1.1 Executive Summary The radioactive effluent monitoring program for the calendar year 2015 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, Evaluating and Reporting Radioactive Material in 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 2015:

Gaseous Waste 2014 2015 Comments Tritium 30.l Ci 38.2 Ci 1 C-14 Activity 23.45 Ci 25.31 Ci Total Fission and Activation Activity 0.49 Ci 0.55 Ci Total Particulate Activity 3.72 E-06 Ci 0 Ci 2 Gross Alpha Activity 0 Ci 0 Ci 2 Iodine Activity 0 Ci 0 Ci 2 Calculated Gamma Air Dose 4.05E-04 mRad 3.71E-04 mRad Calculated Beta Air Dose 1.53 E-04 mRad 1.62E-04 mRad Total Whole body dose 0.09mRem O.IOmRem 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 are related to the type of fuel used (i.e.,

18-month fuel) the core life, power output, and number of core cycles. The small increase from 2014 to 2015 is within the historical statistical variation.

2. No particulate, Iodine, or alpha activity was released.

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 2015.

Pa e 5 of 51

Liquid Effluents:

A summary of all the radioactive liquid releases to the environment during 2015:

Liquid Waste 2014 2015 Comments Total Activity (excluding tritium) 8.61E-4 Ci l.83E-3 Ci 2 Tritium Activity 2080 Ci 1950 Ci 1 Total Whole Body Dose 0.182 mRem 0.189 mRem 2 Total Volume Released 929,987 gal 665,178 gal 1 Comments

1. There was 1 refueling outage in 2015.
2. Although the total curies released are slightly higher in 2015, the specific isotopes released in 2014
  • have higher dose factors. Therefore, the dose for 2015 is approximately the same as the 2014 dose.

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Meteorological Data The CPNPP meteorological system achieved a greater than 97% mean 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 2015 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 2015.

Solid Waste Summary of the solid waste production Total Waste 2014 2015  % Error Shipped (m3 ) 343 316 25%

Shipped (Ci) 608 52.l 25%

Buried (m3 ) 38.7 44.5 25%

Buried (Ci) 608 52.l 25%

Comments In 2015 CPNPP continued to ship and bury stored Class B and Class C wastes at the compact disposal facility in Andrews, Texas. Buried volume during 2015 is lower reflecting Class A waste associated with a single outage and these wastes represent an order of magnitude more volume than Class B and Class C wastes packaged in about 3 cubic meter containers.

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Groundwater Tritium Sentinel Well location CP-A near the Water Plant and Monitor Well 11 (which is directly down gradient from CP-A) continued showing intermittent positive results for tritium. In 2013, 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. The leaking pipe has been repaired. However, in 2015, the water treatment plant's Filter Water Storage Tank's (FWST) lining began leaking treated Squaw Creek Reservoir (SCR) water. Because SCR water contains a low background tritium concentration, SCR water that leaks from the plant will contain a similar concentration of tritium. All of these samples were well below the state drinking water reportable criterion of 20,000 pCi/L and the environmental reportable criterion of 30,000 pCi/L.

All other monitoring well samples during 2015 were< Minimum Detectable Activity (MDA) for tritium.

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 51

1.2 Historical Trend Graphs Total Gaseous Fission and Activation Activity Released

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,.... ,.... 1.27 1.00 1.00 0.881 o.489 °*~ 7 0 .10 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year Total Gaseous Tritium Released 90.00 80.00

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0.00 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year Pa e 9 of 51

Total Whole Body Dose due to Gaseous Activity Released 0 .12 2007 inc rease resulted from inc reasing SFP evapo ration rates due 0.11

- to larger amounts of stored fuel. Beyond 2007, increases attributed to Unit power upra tes: Unit 1, 2008, and Unit 2, 2009.

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0.00 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 201 3 2014 2015 Year Total Volume Liquid Effluents Released 28005284 18733509 10000000 iii E.

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1155673 929987 697886 - 665171 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 201 3 2014 2015 Year Pa e10of51

Total Activity (Excluding H3) Released in Liquid Effluents 400.00 350.00 -

358.00 300.00 .

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- r--o n 3.75 n 6.56 r""'I n 3.47 0.86 1.84 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 201 0 2011 201 2 2013 201 4 201 5 Year Total Curies of Tritium Released in Liquid Effluents 3000 2790 2500 -*-~

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Total Whole Body Dose Due to Liquid Effluents Released

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1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 201 4 2015 Year Total Curies of Solid Radwaste Buried 1800 1620 1600 1400

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249 235 52.1 2.34 18.9 0.149 2.98 n 0 11 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 201 4 2015 Year Pa e 12 of 51

Total Volume of Solid Radwaste Buried 200 .00 180.00 180.00 160.00 140.00 I!! 120.00

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2.0 SUPPLEMENTAL INFORMATION 2.1 Regulatory 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 lodine-131, lodine-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 2.0E-4 µCi/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 Pa e 14 of 51

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:

(264N) * :Ej 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 (µCi/mL ),

V = volume of resins in the pond (gallons), and 264 = conversion factor (µCi/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 2.0E-04 µCi/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 I-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 ofCarbon-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 was one normal, unplanned gaseous effluent monitored release and no abnormal or unplanned liquid effluent releases during 2015. Refer to CR-2015-001594 and gas release permit 02015-031. A brief description of the normal, unplanned gas release is in section 8.5.l of this report.

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.

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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 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 2015 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 ~d site tours through the CPNPP Visitors Center.

The highest dose occurred in the evaluation for fishing, resulting in a dose of 3.28E-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 2015 is retained onsite. This data is available for review by the NRC upon request. Joint Frequency Tables are included in Attachment 10. During 2015, the goal of >90%

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

Meteorolo2ical Data Recovery Channel  % Recoverv 10 m Wind Speed 99.2 10 m Wind Direction 99.5 Delta Temperature A 97.8 Delta Temperature B 97.7 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 2015 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 2015 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 Effluent Release There was one normal, unplanned gaseous effluent release in 2015. This release occurred while performing maintenance on the Waste Gas Decay Tank (WGDT) X-07 inlet valve. During this maintenance, gas escaped from GDT X-02 as a result of the bank isolation valve leaking by on the clearance. The GDT X-07 inlet valve was reinstalled prior to the end of the shift which terminated the gas release. The release was vented to the environment through an effluent radiation monitored flowpath via the plant ventilation system. An unplanned, non-routine release permit was generated for the release. More information regarding this release can be found in CR-2015-001594 and gas

  • release permit G2015-03 l. No gas effluent radiation monitor alarms occurred as a result of this release.

8.5.2 AbnormaL Unplanned Gaseous Effluent Release No abnormal, unplanned gaseous effluent releases occurred during 2015.

8.5.3 Abnormal, Unplanned Liquid Effluent Releases No abnormal, unplanned liquid effluent releases occurred during 2015.

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8.6 Resin Releases to the L VW Pond 3

A total of 1960 ft of powdex resin was transferred to the LVW pond during the period covered by this report. The cumulative activity deposited in the L VW pond since operations began through the end of 2015 is 2.0le-3 Curies, consisting of Co-58, Co-60, Cs-134, Cs-137, I-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.

Pa e 21of51

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 Treatment Plant. CR-2016-001459 documents this issue.

The primary source of tritium intrusion to these wells is likely from the percolation of treated Squaw Creek Reservoir (SCR) water leaking at a rate of 13 to 20 gpm from the Water Treatment Plant's Filter Water Storage Tank (FWST). Because SCR water always contains low background concentrations of tritium, SCR water used in the plant will contain similar concentrations. All of these sample results were well below the state drinking water reportable criteria of 20,000 pCi/L and the environmental reportable criteria of 30,000 pCi/L.

Other areas also monitored, but 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) water 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.

Page 22 of 51

Ground Water Tritium Results (pCi/L)

MW 02/19/14 05/14/14 07/15/14 12/10/14 03/25/15 06/24/15 9/22/15 11/18/15 Location 9 <778 <688 <709 <603 <665 <661 <638 <630 10 <778 <688 <709 <603 <665 <661 <638 <630 11 908 12) 2470 12) 287d2l 150012) <665 341013 ) 2270 13 ) 2270 13) 12 <788 <688 <709 <603 <665 <661 <638 <630 14 <788 <688 <709 <603 <665 <661 <638 <630 15 DRY DRY DRY DRY DRY DRY DRY DRY 16 <778 <688 <709 <603 <665 <661 <638 <630 19 <778 <688 <709 <603 <665 <661 <638 <630 25 <788 <688 <709 <603 <665 <661 <638 <630 CP-A 1290011) 9290 11) 164011) <603 <665 <661 130013) 325013)

CP-B <788 <688 <709 <603 <665 <661 <638 <630 CP-C <788 <688 <709 <603 <665 <661 <638 <630 OSGSF DRY DRY DRY DRY DRY DRY DRY DRY (1) CR-2013-012215; Result was attributed to a leak in a water treatment plant line (lake water)

(2) CR-2014-007981; MW-11 is directly down gradient from CP-A (3) CR-2016-001459; SCR lake water leakage via Water Treatment Plant's Filter Water Storage Tank (FWST).

Pa e 23 of 51

Ground Water Tritium Monitoring Well Ma EXPLANATION

  • Monitoring Well Location (Wea:tmed G!en Rose Formation) g  !.foniri>ring Wei loc.1tion (Onweathered Glen Rose Fc.rm.31icn)

(1iS..6:J Water level Ema1icn (Ft r.tSt)

(NM c Not Mi?asured) 790- GroundwaQrBevation Codour (R !.\SL) Ccnmur tnavaF to Ft K.ate:

1. WellsNos.10. t5. 19,CP-A. CP-B.andCP-C were not used to amstruct pot=ntiometric surface cantJurs for this figure because these wells are not a:nsidered to be- in hydrauric comedian with the od1er wells.
2. Groond1'1'31er Eoleiaiion contours were constructed based on predomirt3.n+/-Yl3"slevetemaiicns fl order to e~ate the overall hydratlicgr.acfJEnt.rt the Sile.and thus contour!i may net be ~1irefy ccnsis<.art mth the individual elevationsatollwells.

'1 I l  !

II ~--]1I I ~I

---i_ j i

i r*--*-

-*-*~*

j Scale in Fe-at 12.5 L1 1~--.....

Source: Created film TXU 8eclric CPSES Site Map SGrd-01.

I i

i

_,/ LUMINANT - CPNPP

,,./'

l-----*--**-------*/ ................................../

,,.,."* UNWEATHERED GLEN ROSE FORMATION* GROUNDWATER Agure23 ELEVATIONS *AUG. 29, 2010 PROJECT: 17B5 BY:AJD REVISIONS:

PASTOR, BEHLING & WHEELER, LLC CONSULTING ENGINEERS AND SCJENTISTS Pa e 24 of 51

SECTION 9.0 EFFLUENT TABLES PaQe 25 of 51

Table 9.1 Site Liquid and Gaseous Batch Release Summary (2015)

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

1. Number of batch releases 4 6 10 14 34
2. Total time period for Batch releases (Minutes) 1.42E+03 2.01E+03 3.36E+03 4.66E+03 1.14E+04
3. Maximum time period for a batch release (Minutes) 3.93E+02 3.95E+02 3.59E+02 4.10E+02 4.10E+02
4. Average time period for a batch release (Minutes) 3.55E+02 3.34E+02 3.36E+02 3.33E+02 3.36E+02
5. Minimum time period for a batch release (Minutes) 3.20E+02 2.85E+02 3.15E+02 3.09E+02 2.85E+02 B. Gaseous Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual
1. Number of batch releases 31 29 33 28 121
2. Total time period for batch releases (Minutes) l.18E+04 1.02E+04 l.12E+04 1.13E+04 4.46E+04
3. Maximum time period for a batch release (Minutes) 1.74E+03 4.23E+02 4.00E+02 1.72E+03 1.74E+03
4. Average time period for a batch release (Minutes) 3.80E+02 3.53E+02 3.39E+02 4.05E+02 3.68E+02
5. Minimum time period for a batch release (Minutes) 2.34E+02 3.02E+02 2.87E+02 3.SOE+Ol 3.SOE+Ol Page 26 of 51

Table 9.2 Site Abnormal Liquid and Gaseous Batch Release Summary (2015)

A. Liquid Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Totals

1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO B. Gas Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Totals
1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 27 of 51

Table 9.3 Site Gaseous Effluents - Summation of All Releases (2015)

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

1. Total Release Curies 1.64E-01 l.IOE-01 1.59E-01 1.ISE-01 5.47E-01
2. Average Release rate for period uCi/sec 2.llE-02 1.40E-02 1.99E-02 1.44E-02 1.74E-02
3. Percent of Applicable Limit  % * * * *
  • B. Radioiodines
1. Total Iodine-131 O.OOE+OO O.OOE+OO 8.23E-07 O.OOE+OO 8.23E-07
2. Average Release rate for period O.OOE+OO O.OOE+OO 1.04E-07 O.OOE+OO 2.61E-08
3. Percent of Applicable Limit  % * * * *
  • C. Particulates
1. Particulates ( Half-Lives > 8 Days ) O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
2. Average Release rate for period O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
3. Percent of Applicable Limit  % * * * *
1. H3 Release Curies 6.27E+OO 1.09E+Ol 1.18E+Ol 9.28E+OO 3.82E+Ol
2. Average Release rate for period uCi/sec 8.07E-01 1.38E+OO 1.49E+OO 1.17E+OO 1.21E+OO
3. Percent of Applicable Limit  % * * * *
1. C 14 Release Curies 6.64E+OO 6.64E+OO 6.79E+OO 5.23E+OO 2.53E+Ol
2. Average Release rate for period uCi/sec 8.55E-01 8.41E-01 8.57E-01 6.59E-01 8.03E-01
3. Percent of Applicable Limit  % * * * *
  • E. Gross Alpha
1. Total Release Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is< 1.0%

Page 28 of 51

Table 9.4 Site Gaseous Effluents - Ground Level Releases (2015)

Continuous Mode Nuclides Released Units Quarter 1 Quarter2 Quarter 3 Quarter 4 Total Fission Gases Ar-41 Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Iodines No Nuclides Found Curies NIA NIA NIA NIA NIA Particulates No Nuclides Found Curies NIA NIA NIA NIA NIA Tritium & C-14 H-3 Curies 6.25E+OO l.08E+Ol l.18E+Ol 9.23E+OO 3.81E+Ol C14 C-14 Curies 1.99E+OO l.99E+OO 2.04E+OO 1.57E+OO 7.59E+OO Gross Alpha No Nuclides Found Curies NIA NIA NIA NIA NIA Page 29 of 51

Table 9.4 {cont)

Site Gaseous Effluents - Ground Level Releases {2015)

Batch Mode Nuclides Released Unit Quarter 1 Quarter2 Quarter 3 Quarter 4 Total Fission Gases Ar-41 Curies 8.60E-02 9.26E-02 l.19E-01 8.06E-02 3.78E-01 Kr-85 Curies 7.81E-02 l.74E-02 3.90E-02 5.22E-04 l.35E-01 Xe-131m Curies O.OOE+OO O.OOE+OO O.OOE+OO l.36E-05 l.36E-05 Xe-133m Curies O.OOE+OO O.OOE+OO O.OOE+OO 7.45E-04 7.45E-04 Xe-133 Curies 5.lOE-05 O.OOE+OO 4.02E-04 2.54E-02 2.59E-02 Xe-135m Curies O.OOE+OO O.OOE+OO O.OOE+OO 6.20E-06 6.20E-06 Xe-135 Curies O.OOE+OO O.OOE+OO O.OOE+OO 7.28E-03 7.28E-03 Total For Period Curies 1.64E-01 l.lOE-01 1.59E-01 1.15E-01 5.47E-01 Iodines Br-82 Curies O.OOE+OO O.OOE+OO 8.23E-07 O.OOE+OO 8.23E-07 Particulates No Nuclides Found Curies NIA NIA NIA NIA NIA Tritium H-3 Curies 2.58E-02 4.48E-02 4.71E-02 4.65E-02 1.64E+Ol Carbon 14 C-14 Curies 4.65E+OO 4.65E+OO 4.75E+OO 3.66E+OO 1.77E+Ol Gross Alpha Curies NIA NIA NIA NIA NIA No Nuclides Found

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

Page 30 of 51

Table 9.5 Site Liquid Effluents - Summation Of All Releases (2015)

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

1. Total Release (not including tritium, gases, Curies 2.03E-04 7.53E-05 8.00E-04 7.65E-04 l.84E-03 alpha)
2. Average diluted concentration during period uCi/ml 5.27E-11 1.04E-11 6.47E-11 4.41E-11 4.51E-11
3. Percent of Applicable Limit  % * * * *
1. Total Release Curies 8.09E+Ol 3.48E+02 9.10E+02 6.11E+02 l.95E+03
2. Average diluted concentration during period uCi/ml 2.lOE-05 4.SOE-05 7.36E-05 3.52E-05 4.78E-05
3. Percent of Applicable Limit  % * * * *
  • C. Dissolved and Entrained Gases
1. Total Release Curies O.OOE+OO 1.88E-05 5.42E-05 l.87E-04 2.60E-04
2. Average diluted concentration during period uCi/ml O.OOE+OO 2.59E-12 4.38E-12 1.0SE-11 6.36E-12
3. Percent of Applicable Limit  % * * * *
  • D: Gross Alpha Radioactivity
1. Total Release Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
2. Average diluted concentration during period uCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO E: Waste Vol Release (Pre-Dilution) Liters 3.02E+05 4.36E+05 7.52E+05 l.03E+06 2.52E+06 F. Volume of Dilution Water Used Liters 3.86E+09 7.26E+09 1.24E+10 1.74E+10 4.08E+10
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is< 1.0%

Page 31of51

Table 9.6 Site Liquid Effluents (2015)

Continuous Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission & Activation Products No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Tritium H-3 Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Dissolved And Entrained Gases No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Gross Alpha Radioactivity Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Batch Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission & Activation Products Mn-54 Curies O.OOE+OO O.OOE+OO 4.32E-05 1.07E-05 5.39E-05 Fe-55 Curies O.OOE+OO O.OOE+OO O.OOE+OO 1.45E-04 1.45E-04 Co-57 Curies O.OOE+OO O.OOE+OO 3.43E-06 O.OOE+OO 3.43E-06 Co-58 Curies 1.34E-04 6.14E-05 1.91E-04 1.53E-04 5.39E-04 Co-60 Curies 6.92E-05 1.39E-05 5.62E-04 2.27E-04 8.72E-04 Ni-63 Curies O.OOE+OO O.OOE+OO O.OOE+OO 2.26E-04 2.26E-04 Ce-143 Curies O.OOE+OO O.OOE+OO O.OOE+OO 3.64E-06 3.64E-06 Total For Period Curies 2.03E-04 7.53E-05 8.00E-04 7.65E-04 1.84E-03 Tritium H-3 Curies 8.09E+Ol 3.48E+02 9.10E+02 6.11E+02 1.95E+03 Dissolved And Entrained Gases Xe-133 Curies O.OOE+OO 1.88E-05 5.42E-05 1.82E-04 2.55E-04 Xe-135 Curies O.OOE+OO O.OOE+OO O.OOE+OO 5.31E-06 5.31E-06 Total for Period Curies O.OOE+OO 1.88E-05 5.42E-05 1.87E-04 2.60E-04 Gross Alpha Activity No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO IfNot Detected, Nuclide is Not Reported. Zeroes in this table indicates that no radioactivity was present at detectable levels.

Page 32 of 51

Table 9.7 Dose to a member of the public due to Liquid Releases (2015)

Organ Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Bone mRem O.OOE+OO O.OOE+OO O.OOE+OO 3.17E-05 3.17E-05 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.000 0.000 0.000 0.001 0.000 Liver mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Total Body mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 1.5 1.5 1.5 1.5 3 Percent of Limit  % 3.025 2.895 3.156 3.532 6.304

  • Thyroid mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Kidney mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Lung mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 GI-Lli mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Page 33 of 51

Table 9.8 Air Dose Due To Gaseous Releases - Site (2015)

Quarter Quarter Quarter Quarter NG Dose Units Annual 1 2 3 4 Gamma Air mRad 8.38E-05 9.02E-05 l.16E-04 8.08E-05 3.71E-04 Limit mRad 5 5 5 5 10 Percent of Limit  % 0.002 0.002 0.002 0.002 0.004 BetaAir mRad 4.54E-05 3.53E-05 4.89E-05 3.25E-05 l.62E-04 Limit mRad 10 10 10 10 20 Percent of Limit  % 0.000 0.000 0.000 0.000 0.001 Page 34 of 51

Table 9.9 Dose to A Member Of The Public Due To Radioiodines, Tritium, and Particulates in Gaseous Releases (2015)

Organ Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Annual Liver mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Total Body mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Thyroid mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Kidney mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Lung mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 GI-Lli mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Bone mRem 6.30E-02 6.30E-02 6.44E-02 4.96E-02 2.40E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.84 0.84 0.86 0.66 1.60 Page 35 of 51

TABLE9.10 SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2015 A. Solid Waste Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)

Shipped Shipped Buried Buried Percent

1. Type of Waste m3 m3 Ci Ci Error
a. Spent resins/filters 3.40E+OO 5.20E+Ol 3.40E+OO 5.20E+Ol 25%
b. Dry active waste 3.13E+02 5.82E-02 4.llE+Ol 6.12E-02 25%
c. Irradiated components NIA
d. Other (oil/miscellaneous liquids sent to NIA processor for volume reduction)

TOTAL 3.16E+02 5.21E+Ol 4.45E+Ol 5.21E+Ol 25%

Note: Shipped volunies and curies are not always equal to the buried volumes and curies as a result of volume reducing processing, and 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.

% Activity

2. Estimate of Major Nuclide Composition (by type of waste) Nuclide Abundance (Ci)
a. Spent resins/filters Ni-63 81.51 4.24E+Ol Fe-55 6.88 3.58E+OO Co-60 6.27 3.26E+OO Sb-125 2.19 l.14E+OO Cs-137 1.61 8.37E-01 C-14 0.25 l.32E-01 Tc-99 <0.01 l.12E-03 H-3 LLD 1-129 LLD Other (t) 1.29 6.68E-01 Total 100.00 5.20E+Ol
b. Dry active waste Fe-55 36.11 2.lOE-02 Co-60 26.25 l.53E-02 Ni-63 18.29 1.06E-02 Co-58 9.39 5.46E-03 Cr-51 2.78 1.61E-03 Nb-95 1.95 l.13E-03 Mn-54 1.79 1.04E-03 Zr-95 1.13 6.54E-04 C-14 0.71 4.30E-04 H-3 LLD Tc-99 LLD 1-129 LLD Other (Z) 1.60 9.38E-04 Total 100.00 5.82E-02
d. Other (oil/miscellaneous liquids sent to processor for volume reduction) NIA NIA NIA (1) Nuclides representing <l % of total shipped activity: Mn-54, Co-57, Co-58, Ni-59, Sr-90, Zr-95, Nb-95, Cs-134, Ce-144, Pu-238, Pu-239/40, Am-241, and Cm-243/44.

(2) Nuclides representing <1 % of total shipped activity: Co-57, Sr-90d, Nb-94, Sn-113, Sb-125, Cs-134, Cs-137d, Ce-144d, Pu-239/40, andAm-241/243.

Page 36 of 51

TABLE9.10 SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2015

'! c-, _... _...........

te Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)

Waste Container Number of Waste Type Destination Class Type Shipments Waste Control

a. Resin/filters B PolyIDC* 1 Specialists, Andrews, TX Energy Solutions
b. Dry active waste A General Design 5 Oak Ridge, TN
d. Other NA NA NA NA
  • High Integrity Container B. Irradiated Fuel Shipments (Disposition)

Number of Shipments Mode of Transportation Destination 0 NIA NIA Page 37 of 51

Attachment 10.1 2015 Meteorological Joint Frequency Table Page 38 of 51

, Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS A ELEVATION:

10 m WIND Wind Speed (mph)

DIRECrlON 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 9 10 16 11 4 50 NNE 2 18 24 6 50 NE 9 27 21 1 58 ENE 8 23 3 34 E 6 16 2 1 25 ESE 2 42 21 65 SE 2 28 36 4 70 SSE 1 34 63 18 116 s 22 61 14 97 SSW 1 10 5 16 SW 4 1 5 WSW w 1 1 WNW 1 1 1 3 NW 1 3 4 NNW 2 6 4 9 14 35 VARIABLE 11 1 12 TOTAL 45 243 251 71 27 4 641 Periods of calm (hours): 0 Hours of missinq data: 4 Page 39 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS B ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 6 15 9 6 36 NNE 4 19 18 4 45 NE 10 20 10 1 41 ENE 10 11 4 25 E 4 17 1 22 ESE 1 20 20 2 43 SE 2 19 24 6 1 52 SSE 1 20 55 25 1 102 s 13 49 41 5 108 SSW 1 8 22 13 44 SW 2 6 14 3 25 WSW 1 3 4 1 9 w 3 1 4 WNW 1 1 NW 6 3 9 1 19 NNW 1 6 8 16 7 38 VARIABLE 13 2 15 TOTAL 53 177 247 131 21 629 Periods of calm (hours): 0 Hours of missinQ data: 6 Page 40 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS ELEVATION:

c 10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 3 3 12 26 7 51 NNE 1 12 13 11 7 44 NE 3 8 2 13 ENE 9 14 2 25 E 5 15 3 23 ESE 3 29 6 38 SE 3 17 28 3 1 52 SSE 3 20 58 36 4 121 s 2 16 40 48 9 115 SSW 2 14 35 18 69 SW 4 10 22 9 45 WSW 3 9 7 2 21 w 1 4 1 3 9 WNW 2 2 NW 6 10 8 2 26 NNW 1 6 18 35 16 3 79 VARIABLE 16 16 TOTAL 59 183 255 203 46 3 749 Periods of calm (hours): 1 Hours of missinq data: 2 Page 41 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS D ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 21 156 237 117 10 541 NNE 11 88 111 50 2 262 NE 16 63 74 16 169 ENE 15 49 42 3 109 E 21 81 8 110 ESE 36 122 51 209 SE 18 195 317 34 1 565 SSE 12 120 416 197 18 2 765 s 6 69 303 158 11 2 549 SSW 8 65 137 54 3 267 SW 11 33 39 7 90 WSW 15 29 23 5 72 w 4 17 7 7 35 WNW 2 51 30 29 3 115 NW 14 38 51 21 9 1 134 NNW 8 53 126 65 15 2 269 VARIABLE 54 21 11 1 87 TOTAL 272 1250 1983 764 72 7 4348 Periods of calm (hours): 3 Hours of missing data: 55 Page 42 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS E ELEVATION:

10 m WIND Wind Speed (m Jh)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 11 13 12 36 NNE 7 22 12 41 NE 1 11 4 16 ENE 3 6 1 10 E 18 39 4 61 ESE 24 86 5 115 SE 27 280 122 1 430 SSE 18 159 204 8 389 s 17 62 59 2 140 SSW 15 47 71 6 139 SW 13 15 19 2 49 WSW 6 13 8 3 30 w 8 10 7 25 WNW 5 25 13 3 46 NW 16 55 14 1 86 NNW 8 15 9 32 VARIABLE 54 10 3 67 TOTAL 251 868 567 26 1712 Periods of calm (hours): 9 Hours of missing data: 13 Page 43 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS F ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 1 1 NNE NE ENE 1 1 E 2 2 ESE 3 5 8 SE 5 25 11 1 42 SSE 8 15 5 28 s 13 19 5 37 SSW 22 13 10 45 SW 19 15 5 39 WSW 26 19 13 58 w 6 4 2 12 WNW 11 7 1 19 NW 12 32 2 46 NNW 3 2 1 6 VARIABLE 32 4 36 TOTAL 164 160 55 1 380 Periods of calm (hours): 2 Hours of missinq data:

Page 44 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS G ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N

NNE NE ENE E

ESE SE 3 1 4 SSE 6 1 7 s 5 10 15 SSW 10 5 2 17 SW 20 11 1 32 WSW 11 29 8 48 w 10 4 14 WNW 6 8 14 NW 10 25 1 36 NNW 4 2 6 VARIABLE 12 12 TOTAL 97 96 12 205 Periods of calm (hours):

Hours of missing data:

Page 45 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS ALL ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 36 187 286 168 34 4 715 NNE 25 159 178 71 9 442 NE 39 129 109 19 1 297 ENE 46 103 52 3 204 E 56 168 18 1 243 ESE 69 304 103 2 478 SE 60 565 538 49 3 1215 SSE 49 369 801 284 23 2 1528 s 43 211 517 263 25 2 1061 SSW 59 162 282 91 3 597 SW 69 94 101 21 285 WSW 62 102 63 11 238 w 32 41 17 10 100 WNW 25 92 44 36 3 200 NW 52 163 81 42 12 1 351 NNW 27 90 166 125 52 5 465 VARIABLE 192 38 14 1 245 TOTAL 941 2977 3370 1196 166 14 8664 Periods of calm (hours): 15 Hours of missinQ data: 81 Page 46 of 51

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

Calculation Methodology Discussion Page 47 of 51

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 committed, 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 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 Radiological 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-2016-002632 was initiated to document the evaluation of prevailing wind directions for all stability classes over the calendar year 2015. This evaluation is performed annually in accordance with Chemistry Guideline 25 to ensure the predominant wind direction has not changed based on the last 5 years of meteorological data including the current year. The 2015 predominant wind direction for the ALL stability class categories did not change when compared with the five year rolling average which includes 2015. No recalculations ofX/Q or D/Q values are required at this time.

Page 48 of 51

Attachment 10.3 Carbon 14 Supplemental Information Page 49 of 51

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, Evaluating and Reporting Radioactive Material in 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 EPRl (Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents, EPRl, 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 Series no. 421, "Management of Waste Containing Tritium and 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 EPRl Report Characterization of Carbon-14 Generated by the Nuclear Power Industry, EPRl 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-0133 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.

Page 50 of 51

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 ofradiation 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 0.009mRem 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 5mRem reasonablv achievable (ALARA)

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

  • Coal is naturally radioactive.

Sources: US. Environmental Protection Agency, Health Physics Society.

Page 51of51

II Kenneth .J. Peters Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Kenneth.Peters@Luminant.com Glen Rose, TX 76043 Luminant T 254 897 6565 c 817 776 0037 F 254 897 6652 CP-201600387 Ref. # Tech. Spec. 5.6.3 Log# TXX-16062 10CFR50.36a April 28, 2016 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 2015 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, 2015 through December 31, 2015.

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

~efuj.P~

fl.

Thomas McCo~l Site Vice President

U. S. Nuclear Regulatory Commission TXX-16062 Page 2 04/28/2016 Enclosures 1. Comanche Peak 2015 Radioactive Effluent Release Report c- M. L. Dapas, Region IV K. M. Kennedy, Region IV M. Watford, NRR Resident Inspectors, Comanche Peak

Enclosure 1 Comanche Peak 2015 Radioactive Effluent Release Report

~

CPNPP _~~ ~~-~~

"~

7 Comanche Peak Nuclear Power Plant .

2015 RADIOACTIVE EFFLUENT RELEASE REPORT January 1, 2015 - December 31, 2015 Prepared By: Don Rebstock Date 4/20/ 16 Reviewed By: Dave Valentine Date 4/20/16 Date 4/20/16 Pa e 1 of 51

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 51

TABLE OF CONTENTS 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 Suµnnation 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.l 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 51

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 Page 4 of 51

1.0 Introduction This Radioactive Effluent Release Report, for Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 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, 2015, through December 31, 2015. The data in this report was calculated in accordance with the CPNPP ODCM using the Canberra OpenEMS software.

1.1 Executive Summary The radioactive effluent monitoring program for the calendar year 2015 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, Evaluating and Reporting Radioactive Material in 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 2015:

Gaseous Waste 2014 2015 Comments Tritium 30.l Ci 38.2 Ci 1 C-14 Activity 23.45 Ci 25.31 Ci Total Fission and Activation Activity 0.49 Ci 0.55 Ci Total Particulate Activity 3.72 E-06 Ci 0 Ci 2 Gross Alpha Activity 0 Ci 0 Ci 2 Iodine Activity 0 Ci 0 Ci 2 Calculated Gamma Air Dose 4.05E-04 mRad 3.71E-04 mRad Calculated Beta Air Dose 1.53 E-04 mRad 1.62E-04 mRad Total Whole body dose 0.09mRem O.IOmRem 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 are related to the type of fuel used (i.e.,

18-month fuel) the core life, power output, and number of core cycles. The small increase from 2014 to 2015 is within the historical statistical variation.

2. No particulate, Iodine, or alpha activity was released.

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 2015.

Pa e 5 of 51

Liquid Effluents:

A summary of all the radioactive liquid releases to the environment during 2015:

Liquid Waste 2014 2015 Comments Total Activity (excluding tritium) 8.61E-4 Ci l.83E-3 Ci 2 Tritium Activity 2080 Ci 1950 Ci 1 Total Whole Body Dose 0.182 mRem 0.189 mRem 2 Total Volume Released 929,987 gal 665,178 gal 1 Comments

1. There was 1 refueling outage in 2015.
2. Although the total curies released are slightly higher in 2015, the specific isotopes released in 2014
  • have higher dose factors. Therefore, the dose for 2015 is approximately the same as the 2014 dose.

Pa e 6 of 51

Meteorological Data The CPNPP meteorological system achieved a greater than 97% mean 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 2015 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 2015.

Solid Waste Summary of the solid waste production Total Waste 2014 2015  % Error Shipped (m3 ) 343 316 25%

Shipped (Ci) 608 52.l 25%

Buried (m3 ) 38.7 44.5 25%

Buried (Ci) 608 52.l 25%

Comments In 2015 CPNPP continued to ship and bury stored Class B and Class C wastes at the compact disposal facility in Andrews, Texas. Buried volume during 2015 is lower reflecting Class A waste associated with a single outage and these wastes represent an order of magnitude more volume than Class B and Class C wastes packaged in about 3 cubic meter containers.

Pa e 7 of 51

Groundwater Tritium Sentinel Well location CP-A near the Water Plant and Monitor Well 11 (which is directly down gradient from CP-A) continued showing intermittent positive results for tritium. In 2013, 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. The leaking pipe has been repaired. However, in 2015, the water treatment plant's Filter Water Storage Tank's (FWST) lining began leaking treated Squaw Creek Reservoir (SCR) water. Because SCR water contains a low background tritium concentration, SCR water that leaks from the plant will contain a similar concentration of tritium. All of these samples were well below the state drinking water reportable criterion of 20,000 pCi/L and the environmental reportable criterion of 30,000 pCi/L.

All other monitoring well samples during 2015 were< Minimum Detectable Activity (MDA) for tritium.

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 51

1.2 Historical Trend Graphs Total Gaseous Fission and Activation Activity Released

.,.,. nn 996.9 1000.00 ,....

228.00 148.00 100.00 -

Q. 25.20 0

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- 3.89 - 3.73 2.60

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1.60 1.60 1.48

~ - 1.30

,.... ,.... 1.27 1.00 1.00 0.881 o.489 °*~ 7 0 .10 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year Total Gaseous Tritium Released 90.00 80.00

- - CA 70.00 61.27

~ 60.00 "" o;;n

,.... " '* OU

- 56.2

- 55.80 0 51.6 0

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- 40.50

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- 29.60 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 2015 Year Pa e 9 of 51

Total Whole Body Dose due to Gaseous Activity Released 0 .12 2007 inc rease resulted from inc reasing SFP evapo ration rates due 0.11

- to larger amounts of stored fuel. Beyond 2007, increases attributed to Unit power upra tes: Unit 1, 2008, and Unit 2, 2009.

0.11 0.10 0.11 0.10 0.10 0.09 0.09 0.09 - -

0.08 0.08 0.08 0.08

'E

~

.s 0.06 .-- -

rn 0

0.06 U.UI>

0.05 0.05 0 - -

0.04 >-

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0.00 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 201 3 2014 2015 Year Total Volume Liquid Effluents Released 28005284 18733509 10000000 iii E.

E

J

~ 1 ~8~2'l168826 1489742

.... 1057913 74134 1203435 1000000 - - ,....

1098400 -

ll7 4 "llll: ... ,.... f - - 909767 969860 ru::'uv 70079i38000

- 955200 -

1155673 929987 697886 - 665171 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 201 3 2014 2015 Year Pa e10of51

Total Activity (Excluding H3) Released in Liquid Effluents 400.00 350.00 -

358.00 300.00 .

I

  • 250.00 227 .9023= 1 0 0

.§.

~ 200.00 - '

0 er: 150.00 144.00 -

- 124.80 100.00 - ~ -

110.00

- - - ~

111.90

- ~ - -

108.70 50.00 - ~

- - - ~ ~ -

17.60 21 .60 15.00 16.4 13.8 0.00 n n 5.68 7.60

- r--o n 3.75 n 6.56 r""'I n 3.47 0.86 1.84 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 201 0 2011 201 2 2013 201 4 201 5 Year Total Curies of Tritium Released in Liquid Effluents 3000 2790 2500 -*-~

2080

~

~

2000 -

-L.ruo..

cj 1623 c:

u 0

(')

1500 1455 -

1550

    • --- 1480 1520 1340 J:

1223 -

'C 1080 C"

i 1000 986

-=~ - --- - - - - - - -*-- -

669 500 532 0

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Year Pae11of51

Total Whole Body Dose Due to Liquid Effluents Released

'E 0.60 Q)

°'.§. 0.50 + - - - - --

Q)

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0 0 0.40 -<-----------------------------------------~

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 201 4 2015 Year Total Curies of Solid Radwaste Buried 1800 1620 1600 1400

  • **A 1200 I/) 1000 Q)
J 0 800 608 600 --- *rA 400 ~**

474

~*n 475 255 200 190

- n n *-

249 235 52.1 2.34 18.9 0.149 2.98 n 0 11 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 201 4 2015 Year Pa e 12 of 51

Total Volume of Solid Radwaste Buried 200 .00 180.00 180.00 160.00 140.00 I!! 120.00

~

!: 100.00

~

90.20 u

c ~

6 80.00 8

~-

70.7

, 65.6 r 60.00 '"" -

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- 38.7 44.5

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27.10 19.20 27.90

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rf n n i:*. -

0.00 11 Il II I

  • 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 201 4 201 5 Year Pa e 13 of 51

2.0 SUPPLEMENTAL INFORMATION 2.1 Regulatory 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 lodine-131, lodine-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 2.0E-4 µCi/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 Pa e 14 of 51

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:

(264N) * :Ej 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 (µCi/mL ),

V = volume of resins in the pond (gallons), and 264 = conversion factor (µCi/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 2.0E-04 µCi/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.

Pa e 15 of 51

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 I-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.

Pa e 16 of 51

C-14 was estimated in accordance with the methodology in the EPRI report Estimation ofCarbon-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 was one normal, unplanned gaseous effluent monitored release and no abnormal or unplanned liquid effluent releases during 2015. Refer to CR-2015-001594 and gas release permit 02015-031. A brief description of the normal, unplanned gas release is in section 8.5.l of this report.

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.

Pa e 17 of 51

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 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 2015 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 ~d site tours through the CPNPP Visitors Center.

The highest dose occurred in the evaluation for fishing, resulting in a dose of 3.28E-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.

Pa e 18 of 51

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 2015 is retained onsite. This data is available for review by the NRC upon request. Joint Frequency Tables are included in Attachment 10. During 2015, the goal of >90%

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

Meteorolo2ical Data Recovery Channel  % Recoverv 10 m Wind Speed 99.2 10 m Wind Direction 99.5 Delta Temperature A 97.8 Delta Temperature B 97.7 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 2015 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 2015 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.

Pa e 19 of 51

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 Effluent Release There was one normal, unplanned gaseous effluent release in 2015. This release occurred while performing maintenance on the Waste Gas Decay Tank (WGDT) X-07 inlet valve. During this maintenance, gas escaped from GDT X-02 as a result of the bank isolation valve leaking by on the clearance. The GDT X-07 inlet valve was reinstalled prior to the end of the shift which terminated the gas release. The release was vented to the environment through an effluent radiation monitored flowpath via the plant ventilation system. An unplanned, non-routine release permit was generated for the release. More information regarding this release can be found in CR-2015-001594 and gas

  • release permit G2015-03 l. No gas effluent radiation monitor alarms occurred as a result of this release.

8.5.2 AbnormaL Unplanned Gaseous Effluent Release No abnormal, unplanned gaseous effluent releases occurred during 2015.

8.5.3 Abnormal, Unplanned Liquid Effluent Releases No abnormal, unplanned liquid effluent releases occurred during 2015.

Pa e 20 of 51

8.6 Resin Releases to the L VW Pond 3

A total of 1960 ft of powdex resin was transferred to the LVW pond during the period covered by this report. The cumulative activity deposited in the L VW pond since operations began through the end of 2015 is 2.0le-3 Curies, consisting of Co-58, Co-60, Cs-134, Cs-137, I-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.

Pa e 21of51

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 Treatment Plant. CR-2016-001459 documents this issue.

The primary source of tritium intrusion to these wells is likely from the percolation of treated Squaw Creek Reservoir (SCR) water leaking at a rate of 13 to 20 gpm from the Water Treatment Plant's Filter Water Storage Tank (FWST). Because SCR water always contains low background concentrations of tritium, SCR water used in the plant will contain similar concentrations. All of these sample results were well below the state drinking water reportable criteria of 20,000 pCi/L and the environmental reportable criteria of 30,000 pCi/L.

Other areas also monitored, but 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) water 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.

Page 22 of 51

Ground Water Tritium Results (pCi/L)

MW 02/19/14 05/14/14 07/15/14 12/10/14 03/25/15 06/24/15 9/22/15 11/18/15 Location 9 <778 <688 <709 <603 <665 <661 <638 <630 10 <778 <688 <709 <603 <665 <661 <638 <630 11 908 12) 2470 12) 287d2l 150012) <665 341013 ) 2270 13 ) 2270 13) 12 <788 <688 <709 <603 <665 <661 <638 <630 14 <788 <688 <709 <603 <665 <661 <638 <630 15 DRY DRY DRY DRY DRY DRY DRY DRY 16 <778 <688 <709 <603 <665 <661 <638 <630 19 <778 <688 <709 <603 <665 <661 <638 <630 25 <788 <688 <709 <603 <665 <661 <638 <630 CP-A 1290011) 9290 11) 164011) <603 <665 <661 130013) 325013)

CP-B <788 <688 <709 <603 <665 <661 <638 <630 CP-C <788 <688 <709 <603 <665 <661 <638 <630 OSGSF DRY DRY DRY DRY DRY DRY DRY DRY (1) CR-2013-012215; Result was attributed to a leak in a water treatment plant line (lake water)

(2) CR-2014-007981; MW-11 is directly down gradient from CP-A (3) CR-2016-001459; SCR lake water leakage via Water Treatment Plant's Filter Water Storage Tank (FWST).

Pa e 23 of 51

Ground Water Tritium Monitoring Well Ma EXPLANATION

  • Monitoring Well Location (Wea:tmed G!en Rose Formation) g  !.foniri>ring Wei loc.1tion (Onweathered Glen Rose Fc.rm.31icn)

(1iS..6:J Water level Ema1icn (Ft r.tSt)

(NM c Not Mi?asured) 790- GroundwaQrBevation Codour (R !.\SL) Ccnmur tnavaF to Ft K.ate:

1. WellsNos.10. t5. 19,CP-A. CP-B.andCP-C were not used to amstruct pot=ntiometric surface cantJurs for this figure because these wells are not a:nsidered to be- in hydrauric comedian with the od1er wells.
2. Groond1'1'31er Eoleiaiion contours were constructed based on predomirt3.n+/-Yl3"slevetemaiicns fl order to e~ate the overall hydratlicgr.acfJEnt.rt the Sile.and thus contour!i may net be ~1irefy ccnsis<.art mth the individual elevationsatollwells.

'1 I l  !

II ~--]1I I ~I

---i_ j i

i r*--*-

-*-*~*

j Scale in Fe-at 12.5 L1 1~--.....

Source: Created film TXU 8eclric CPSES Site Map SGrd-01.

I i

i

_,/ LUMINANT - CPNPP

,,./'

l-----*--**-------*/ ................................../

,,.,."* UNWEATHERED GLEN ROSE FORMATION* GROUNDWATER Agure23 ELEVATIONS *AUG. 29, 2010 PROJECT: 17B5 BY:AJD REVISIONS:

PASTOR, BEHLING & WHEELER, LLC CONSULTING ENGINEERS AND SCJENTISTS Pa e 24 of 51

SECTION 9.0 EFFLUENT TABLES PaQe 25 of 51

Table 9.1 Site Liquid and Gaseous Batch Release Summary (2015)

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

1. Number of batch releases 4 6 10 14 34
2. Total time period for Batch releases (Minutes) 1.42E+03 2.01E+03 3.36E+03 4.66E+03 1.14E+04
3. Maximum time period for a batch release (Minutes) 3.93E+02 3.95E+02 3.59E+02 4.10E+02 4.10E+02
4. Average time period for a batch release (Minutes) 3.55E+02 3.34E+02 3.36E+02 3.33E+02 3.36E+02
5. Minimum time period for a batch release (Minutes) 3.20E+02 2.85E+02 3.15E+02 3.09E+02 2.85E+02 B. Gaseous Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual
1. Number of batch releases 31 29 33 28 121
2. Total time period for batch releases (Minutes) l.18E+04 1.02E+04 l.12E+04 1.13E+04 4.46E+04
3. Maximum time period for a batch release (Minutes) 1.74E+03 4.23E+02 4.00E+02 1.72E+03 1.74E+03
4. Average time period for a batch release (Minutes) 3.80E+02 3.53E+02 3.39E+02 4.05E+02 3.68E+02
5. Minimum time period for a batch release (Minutes) 2.34E+02 3.02E+02 2.87E+02 3.SOE+Ol 3.SOE+Ol Page 26 of 51

Table 9.2 Site Abnormal Liquid and Gaseous Batch Release Summary (2015)

A. Liquid Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Totals

1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO B. Gas Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Totals
1. Number of abnormal releases 0 0 0 0 0
2. Total activity of abnormal releases Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 27 of 51

Table 9.3 Site Gaseous Effluents - Summation of All Releases (2015)

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

1. Total Release Curies 1.64E-01 l.IOE-01 1.59E-01 1.ISE-01 5.47E-01
2. Average Release rate for period uCi/sec 2.llE-02 1.40E-02 1.99E-02 1.44E-02 1.74E-02
3. Percent of Applicable Limit  % * * * *
  • B. Radioiodines
1. Total Iodine-131 O.OOE+OO O.OOE+OO 8.23E-07 O.OOE+OO 8.23E-07
2. Average Release rate for period O.OOE+OO O.OOE+OO 1.04E-07 O.OOE+OO 2.61E-08
3. Percent of Applicable Limit  % * * * *
  • C. Particulates
1. Particulates ( Half-Lives > 8 Days ) O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
2. Average Release rate for period O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
3. Percent of Applicable Limit  % * * * *
1. H3 Release Curies 6.27E+OO 1.09E+Ol 1.18E+Ol 9.28E+OO 3.82E+Ol
2. Average Release rate for period uCi/sec 8.07E-01 1.38E+OO 1.49E+OO 1.17E+OO 1.21E+OO
3. Percent of Applicable Limit  % * * * *
1. C 14 Release Curies 6.64E+OO 6.64E+OO 6.79E+OO 5.23E+OO 2.53E+Ol
2. Average Release rate for period uCi/sec 8.55E-01 8.41E-01 8.57E-01 6.59E-01 8.03E-01
3. Percent of Applicable Limit  % * * * *
  • E. Gross Alpha
1. Total Release Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is< 1.0%

Page 28 of 51

Table 9.4 Site Gaseous Effluents - Ground Level Releases (2015)

Continuous Mode Nuclides Released Units Quarter 1 Quarter2 Quarter 3 Quarter 4 Total Fission Gases Ar-41 Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Iodines No Nuclides Found Curies NIA NIA NIA NIA NIA Particulates No Nuclides Found Curies NIA NIA NIA NIA NIA Tritium & C-14 H-3 Curies 6.25E+OO l.08E+Ol l.18E+Ol 9.23E+OO 3.81E+Ol C14 C-14 Curies 1.99E+OO l.99E+OO 2.04E+OO 1.57E+OO 7.59E+OO Gross Alpha No Nuclides Found Curies NIA NIA NIA NIA NIA Page 29 of 51

Table 9.4 {cont)

Site Gaseous Effluents - Ground Level Releases {2015)

Batch Mode Nuclides Released Unit Quarter 1 Quarter2 Quarter 3 Quarter 4 Total Fission Gases Ar-41 Curies 8.60E-02 9.26E-02 l.19E-01 8.06E-02 3.78E-01 Kr-85 Curies 7.81E-02 l.74E-02 3.90E-02 5.22E-04 l.35E-01 Xe-131m Curies O.OOE+OO O.OOE+OO O.OOE+OO l.36E-05 l.36E-05 Xe-133m Curies O.OOE+OO O.OOE+OO O.OOE+OO 7.45E-04 7.45E-04 Xe-133 Curies 5.lOE-05 O.OOE+OO 4.02E-04 2.54E-02 2.59E-02 Xe-135m Curies O.OOE+OO O.OOE+OO O.OOE+OO 6.20E-06 6.20E-06 Xe-135 Curies O.OOE+OO O.OOE+OO O.OOE+OO 7.28E-03 7.28E-03 Total For Period Curies 1.64E-01 l.lOE-01 1.59E-01 1.15E-01 5.47E-01 Iodines Br-82 Curies O.OOE+OO O.OOE+OO 8.23E-07 O.OOE+OO 8.23E-07 Particulates No Nuclides Found Curies NIA NIA NIA NIA NIA Tritium H-3 Curies 2.58E-02 4.48E-02 4.71E-02 4.65E-02 1.64E+Ol Carbon 14 C-14 Curies 4.65E+OO 4.65E+OO 4.75E+OO 3.66E+OO 1.77E+Ol Gross Alpha Curies NIA NIA NIA NIA NIA No Nuclides Found

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

Page 30 of 51

Table 9.5 Site Liquid Effluents - Summation Of All Releases (2015)

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

1. Total Release (not including tritium, gases, Curies 2.03E-04 7.53E-05 8.00E-04 7.65E-04 l.84E-03 alpha)
2. Average diluted concentration during period uCi/ml 5.27E-11 1.04E-11 6.47E-11 4.41E-11 4.51E-11
3. Percent of Applicable Limit  % * * * *
1. Total Release Curies 8.09E+Ol 3.48E+02 9.10E+02 6.11E+02 l.95E+03
2. Average diluted concentration during period uCi/ml 2.lOE-05 4.SOE-05 7.36E-05 3.52E-05 4.78E-05
3. Percent of Applicable Limit  % * * * *
  • C. Dissolved and Entrained Gases
1. Total Release Curies O.OOE+OO 1.88E-05 5.42E-05 l.87E-04 2.60E-04
2. Average diluted concentration during period uCi/ml O.OOE+OO 2.59E-12 4.38E-12 1.0SE-11 6.36E-12
3. Percent of Applicable Limit  % * * * *
  • D: Gross Alpha Radioactivity
1. Total Release Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
2. Average diluted concentration during period uCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO E: Waste Vol Release (Pre-Dilution) Liters 3.02E+05 4.36E+05 7.52E+05 l.03E+06 2.52E+06 F. Volume of Dilution Water Used Liters 3.86E+09 7.26E+09 1.24E+10 1.74E+10 4.08E+10
  • Applicable limits are expressed in terms of dose.

Estimated Total Error For All Values Reported Is< 1.0%

Page 31of51

Table 9.6 Site Liquid Effluents (2015)

Continuous Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission & Activation Products No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Tritium H-3 Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Dissolved And Entrained Gases No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Gross Alpha Radioactivity Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Batch Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission & Activation Products Mn-54 Curies O.OOE+OO O.OOE+OO 4.32E-05 1.07E-05 5.39E-05 Fe-55 Curies O.OOE+OO O.OOE+OO O.OOE+OO 1.45E-04 1.45E-04 Co-57 Curies O.OOE+OO O.OOE+OO 3.43E-06 O.OOE+OO 3.43E-06 Co-58 Curies 1.34E-04 6.14E-05 1.91E-04 1.53E-04 5.39E-04 Co-60 Curies 6.92E-05 1.39E-05 5.62E-04 2.27E-04 8.72E-04 Ni-63 Curies O.OOE+OO O.OOE+OO O.OOE+OO 2.26E-04 2.26E-04 Ce-143 Curies O.OOE+OO O.OOE+OO O.OOE+OO 3.64E-06 3.64E-06 Total For Period Curies 2.03E-04 7.53E-05 8.00E-04 7.65E-04 1.84E-03 Tritium H-3 Curies 8.09E+Ol 3.48E+02 9.10E+02 6.11E+02 1.95E+03 Dissolved And Entrained Gases Xe-133 Curies O.OOE+OO 1.88E-05 5.42E-05 1.82E-04 2.55E-04 Xe-135 Curies O.OOE+OO O.OOE+OO O.OOE+OO 5.31E-06 5.31E-06 Total for Period Curies O.OOE+OO 1.88E-05 5.42E-05 1.87E-04 2.60E-04 Gross Alpha Activity No Nuclides Found Curies O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO IfNot Detected, Nuclide is Not Reported. Zeroes in this table indicates that no radioactivity was present at detectable levels.

Page 32 of 51

Table 9.7 Dose to a member of the public due to Liquid Releases (2015)

Organ Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Bone mRem O.OOE+OO O.OOE+OO O.OOE+OO 3.17E-05 3.17E-05 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.000 0.000 0.000 0.001 0.000 Liver mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Total Body mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 1.5 1.5 1.5 1.5 3 Percent of Limit  % 3.025 2.895 3.156 3.532 6.304

  • Thyroid mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Kidney mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Lung mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 GI-Lli mRem 4.54E-02 4.34E-02 4.73E-02 5.30E-02 1.89E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.907 0.869 0.947 1.060 1.891 Page 33 of 51

Table 9.8 Air Dose Due To Gaseous Releases - Site (2015)

Quarter Quarter Quarter Quarter NG Dose Units Annual 1 2 3 4 Gamma Air mRad 8.38E-05 9.02E-05 l.16E-04 8.08E-05 3.71E-04 Limit mRad 5 5 5 5 10 Percent of Limit  % 0.002 0.002 0.002 0.002 0.004 BetaAir mRad 4.54E-05 3.53E-05 4.89E-05 3.25E-05 l.62E-04 Limit mRad 10 10 10 10 20 Percent of Limit  % 0.000 0.000 0.000 0.000 0.001 Page 34 of 51

Table 9.9 Dose to A Member Of The Public Due To Radioiodines, Tritium, and Particulates in Gaseous Releases (2015)

Organ Dose Units Quarter 1 Quarter 2 Quarter 3 Quarter4 Annual Liver mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Total Body mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Thyroid mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Kidney mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Lung mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 GI-Lli mRem 2.lOE-02 2.74E-02 2.91E-02 2.26E-02 1.00E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.280 0.365 0.388 0.301 0.667 Bone mRem 6.30E-02 6.30E-02 6.44E-02 4.96E-02 2.40E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.84 0.84 0.86 0.66 1.60 Page 35 of 51

TABLE9.10 SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2015 A. Solid Waste Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)

Shipped Shipped Buried Buried Percent

1. Type of Waste m3 m3 Ci Ci Error
a. Spent resins/filters 3.40E+OO 5.20E+Ol 3.40E+OO 5.20E+Ol 25%
b. Dry active waste 3.13E+02 5.82E-02 4.llE+Ol 6.12E-02 25%
c. Irradiated components NIA
d. Other (oil/miscellaneous liquids sent to NIA processor for volume reduction)

TOTAL 3.16E+02 5.21E+Ol 4.45E+Ol 5.21E+Ol 25%

Note: Shipped volunies and curies are not always equal to the buried volumes and curies as a result of volume reducing processing, and 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.

% Activity

2. Estimate of Major Nuclide Composition (by type of waste) Nuclide Abundance (Ci)
a. Spent resins/filters Ni-63 81.51 4.24E+Ol Fe-55 6.88 3.58E+OO Co-60 6.27 3.26E+OO Sb-125 2.19 l.14E+OO Cs-137 1.61 8.37E-01 C-14 0.25 l.32E-01 Tc-99 <0.01 l.12E-03 H-3 LLD 1-129 LLD Other (t) 1.29 6.68E-01 Total 100.00 5.20E+Ol
b. Dry active waste Fe-55 36.11 2.lOE-02 Co-60 26.25 l.53E-02 Ni-63 18.29 1.06E-02 Co-58 9.39 5.46E-03 Cr-51 2.78 1.61E-03 Nb-95 1.95 l.13E-03 Mn-54 1.79 1.04E-03 Zr-95 1.13 6.54E-04 C-14 0.71 4.30E-04 H-3 LLD Tc-99 LLD 1-129 LLD Other (Z) 1.60 9.38E-04 Total 100.00 5.82E-02
d. Other (oil/miscellaneous liquids sent to processor for volume reduction) NIA NIA NIA (1) Nuclides representing <l % of total shipped activity: Mn-54, Co-57, Co-58, Ni-59, Sr-90, Zr-95, Nb-95, Cs-134, Ce-144, Pu-238, Pu-239/40, Am-241, and Cm-243/44.

(2) Nuclides representing <1 % of total shipped activity: Co-57, Sr-90d, Nb-94, Sn-113, Sb-125, Cs-134, Cs-137d, Ce-144d, Pu-239/40, andAm-241/243.

Page 36 of 51

TABLE9.10 SOLID RADWASTE AND IRRADIATED FUEL SHIPMENTS 2015

'! c-, _... _...........

te Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)

Waste Container Number of Waste Type Destination Class Type Shipments Waste Control

a. Resin/filters B PolyIDC* 1 Specialists, Andrews, TX Energy Solutions
b. Dry active waste A General Design 5 Oak Ridge, TN
d. Other NA NA NA NA
  • High Integrity Container B. Irradiated Fuel Shipments (Disposition)

Number of Shipments Mode of Transportation Destination 0 NIA NIA Page 37 of 51

Attachment 10.1 2015 Meteorological Joint Frequency Table Page 38 of 51

, Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS A ELEVATION:

10 m WIND Wind Speed (mph)

DIRECrlON 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 9 10 16 11 4 50 NNE 2 18 24 6 50 NE 9 27 21 1 58 ENE 8 23 3 34 E 6 16 2 1 25 ESE 2 42 21 65 SE 2 28 36 4 70 SSE 1 34 63 18 116 s 22 61 14 97 SSW 1 10 5 16 SW 4 1 5 WSW w 1 1 WNW 1 1 1 3 NW 1 3 4 NNW 2 6 4 9 14 35 VARIABLE 11 1 12 TOTAL 45 243 251 71 27 4 641 Periods of calm (hours): 0 Hours of missinq data: 4 Page 39 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS B ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 6 15 9 6 36 NNE 4 19 18 4 45 NE 10 20 10 1 41 ENE 10 11 4 25 E 4 17 1 22 ESE 1 20 20 2 43 SE 2 19 24 6 1 52 SSE 1 20 55 25 1 102 s 13 49 41 5 108 SSW 1 8 22 13 44 SW 2 6 14 3 25 WSW 1 3 4 1 9 w 3 1 4 WNW 1 1 NW 6 3 9 1 19 NNW 1 6 8 16 7 38 VARIABLE 13 2 15 TOTAL 53 177 247 131 21 629 Periods of calm (hours): 0 Hours of missinQ data: 6 Page 40 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS ELEVATION:

c 10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 3 3 12 26 7 51 NNE 1 12 13 11 7 44 NE 3 8 2 13 ENE 9 14 2 25 E 5 15 3 23 ESE 3 29 6 38 SE 3 17 28 3 1 52 SSE 3 20 58 36 4 121 s 2 16 40 48 9 115 SSW 2 14 35 18 69 SW 4 10 22 9 45 WSW 3 9 7 2 21 w 1 4 1 3 9 WNW 2 2 NW 6 10 8 2 26 NNW 1 6 18 35 16 3 79 VARIABLE 16 16 TOTAL 59 183 255 203 46 3 749 Periods of calm (hours): 1 Hours of missinq data: 2 Page 41 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS D ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 21 156 237 117 10 541 NNE 11 88 111 50 2 262 NE 16 63 74 16 169 ENE 15 49 42 3 109 E 21 81 8 110 ESE 36 122 51 209 SE 18 195 317 34 1 565 SSE 12 120 416 197 18 2 765 s 6 69 303 158 11 2 549 SSW 8 65 137 54 3 267 SW 11 33 39 7 90 WSW 15 29 23 5 72 w 4 17 7 7 35 WNW 2 51 30 29 3 115 NW 14 38 51 21 9 1 134 NNW 8 53 126 65 15 2 269 VARIABLE 54 21 11 1 87 TOTAL 272 1250 1983 764 72 7 4348 Periods of calm (hours): 3 Hours of missing data: 55 Page 42 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS E ELEVATION:

10 m WIND Wind Speed (m Jh)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 11 13 12 36 NNE 7 22 12 41 NE 1 11 4 16 ENE 3 6 1 10 E 18 39 4 61 ESE 24 86 5 115 SE 27 280 122 1 430 SSE 18 159 204 8 389 s 17 62 59 2 140 SSW 15 47 71 6 139 SW 13 15 19 2 49 WSW 6 13 8 3 30 w 8 10 7 25 WNW 5 25 13 3 46 NW 16 55 14 1 86 NNW 8 15 9 32 VARIABLE 54 10 3 67 TOTAL 251 868 567 26 1712 Periods of calm (hours): 9 Hours of missing data: 13 Page 43 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS F ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 1 1 NNE NE ENE 1 1 E 2 2 ESE 3 5 8 SE 5 25 11 1 42 SSE 8 15 5 28 s 13 19 5 37 SSW 22 13 10 45 SW 19 15 5 39 WSW 26 19 13 58 w 6 4 2 12 WNW 11 7 1 19 NW 12 32 2 46 NNW 3 2 1 6 VARIABLE 32 4 36 TOTAL 164 160 55 1 380 Periods of calm (hours): 2 Hours of missinq data:

Page 44 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS G ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N

NNE NE ENE E

ESE SE 3 1 4 SSE 6 1 7 s 5 10 15 SSW 10 5 2 17 SW 20 11 1 32 WSW 11 29 8 48 w 10 4 14 WNW 6 8 14 NW 10 25 1 36 NNW 4 2 6 VARIABLE 12 12 TOTAL 97 96 12 205 Periods of calm (hours):

Hours of missing data:

Page 45 of 51

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2015 00:00 to 31-DEC-2015 23:59 STABILITY CLASS ALL ELEVATION:

10 m WIND Wind Speed (mph)

DIRECTION 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 36 187 286 168 34 4 715 NNE 25 159 178 71 9 442 NE 39 129 109 19 1 297 ENE 46 103 52 3 204 E 56 168 18 1 243 ESE 69 304 103 2 478 SE 60 565 538 49 3 1215 SSE 49 369 801 284 23 2 1528 s 43 211 517 263 25 2 1061 SSW 59 162 282 91 3 597 SW 69 94 101 21 285 WSW 62 102 63 11 238 w 32 41 17 10 100 WNW 25 92 44 36 3 200 NW 52 163 81 42 12 1 351 NNW 27 90 166 125 52 5 465 VARIABLE 192 38 14 1 245 TOTAL 941 2977 3370 1196 166 14 8664 Periods of calm (hours): 15 Hours of missinQ data: 81 Page 46 of 51

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

Calculation Methodology Discussion Page 47 of 51

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 committed, 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 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 Radiological 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-2016-002632 was initiated to document the evaluation of prevailing wind directions for all stability classes over the calendar year 2015. This evaluation is performed annually in accordance with Chemistry Guideline 25 to ensure the predominant wind direction has not changed based on the last 5 years of meteorological data including the current year. The 2015 predominant wind direction for the ALL stability class categories did not change when compared with the five year rolling average which includes 2015. No recalculations ofX/Q or D/Q values are required at this time.

Page 48 of 51

Attachment 10.3 Carbon 14 Supplemental Information Page 49 of 51

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, Evaluating and Reporting Radioactive Material in 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 EPRl (Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents, EPRl, 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 Series no. 421, "Management of Waste Containing Tritium and 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 EPRl Report Characterization of Carbon-14 Generated by the Nuclear Power Industry, EPRl 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-0133 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.

Page 50 of 51

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 ofradiation 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 0.009mRem 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 5mRem reasonablv achievable (ALARA)

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

  • Coal is naturally radioactive.

Sources: US. Environmental Protection Agency, Health Physics Society.

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