CP-202200145, (CPNPP) - 2021 Annual Radioactive Effluent Release Report

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(CPNPP) - 2021 Annual Radioactive Effluent Release Report
ML22108A226
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/18/2022
From: Hicks J
Luminant, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202200145, TXX-22032
Download: ML22108A226 (59)
v • d • e


Text

m Jack C. H icks Manager, Regulatory Affairs Comanche Peak Nuclear Power Plant (Vistra Operations Company LLC)

Luminant P.O. Box 1002 6322 North FM 56 Glen Rose , TX 76043 T 254.897.6725 CP-202200145 TXX-22032 April 18, 2022 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.36(a)

ATTN: Document Control Desk TS 5.6.3 Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 2021 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

Dear Sir or Madam:

Vistra Operations Company LLC ("Vistra OpCo") hereby submits the Comanche Peak Nuclear Power Plant {CPNPP) 2021 Annual Radioactive Effluent Release Report. The enclosed report is provided pursuant to 10 CFR 50.36a and CPNPP Technical Specification 5.6.3. The report covers the period from January 1, 2021 to December 31, 2021.

This letter contains no new regulatory commitments for CPNPP Unit 1 and Unit 2.

If you have any questions regarding this submittal, please contact Garry Struble at (254) 897-6628 or garry.struble@luminant.com.

Sincerely, JakC.llicks

Enclosure:

CPNPP 2021 Annual Radioactive Effluent Release Report c (email) - Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

2021 ANNUAL RADIOLOGICAL EFFLUENTS RELEASE REPORT January 1, 2021 - December 31, 2021 Preparer: Jeremx: Quist Date: 3/22/2022 Reviewer: Donald Rebstock Date: 3/22/2022 Approval: Michael Long ~ Date: 4/09/2022 Chemistry Manager

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 (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 of58

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 Low Volume Waste (LVW) Pond 8.7 Changes to the Liquid, Gaseous, and Solid Waste Treatment Systems 8.8 Groundwater Tritium Monitoring Program 8.9 Independent Spent Fuel Storage Installation (ISFSI) 9.0 EFFLUENT TABLES 9 .1 Liquid and Gaseous Batch Release Summary 9.2 Abnormal Liquid and Gaseous Batch Release Summary 9 .3 Gaseous Effluents - Summation of All Releases 9.4 Gaseous Effluents - Ground Level Releases 9.5 Liquid Effluents - Summation of All Releases 9.6 Liquid Effluents

9. 7 Dose Due to Liquid Releases 9.8 Air Dose Due to Gaseous Releases 9.9 Dose Due to Radioiodines, Particulates, Tritium, and Carbon-14 in Gaseous Releases 9 .10 Solid Radwaste and Irradiated Fuel Shipments Page 3 of 58

10.0 ATTACHMENTS 10.1 Meteorological Joint Frequency Distribution Tables 10.2 Atmospheric Dispersion (X/Q) and Deposition (D/Q) Calculation Methodology Discussion 10.3 Carbon-14 Supplemental Information 10.4 Putting Radiation Dose in Context 10.5 Errata from Previous Annual Radioactive Effluent Release Reports Page 4 of58

ACRONYMS AND ABBREVIATIONS ARBOR Annual Radiological Environmental Operating Report CPR Code of Federal Regulations CPNPP Comanche Peak Nuclear Power Plant ECL Effluent Concentration Limit HIC High Integrity Containers ISFSI 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 OOS Out of Service PET Primary Effluent Tanks pCi Pico-Curie REC Radiological Effluent Control SORC Station Operations Review Committee

µCi Micro-Curie WMT Waste Monitor Tanks WWHT Waste Water Holdup Tanks Page 5 of 58

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, 2021 through December 31, 2021. Data in this report were calculated in accordance with the CPNPP ODCM using the Canberra OpenEMS software.

1.1 Executive Summary The radioactive effluent monitoring program for 2021 was conducted as described in the following report. Results of the monitoring program indicate 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 Ejjluents 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, improvements in the mitigation of other isotopes have made C-14 more prominent. Attachment 10.3 provides more detail about C-14.

Page 6 of 58

1.1 Executive Summary (continued)

Gaseous Effluents:

Two-year summary of all the radioactive gaseous releases to the environment:

Gaseous Waste 2020 2021 Comments Tritium (Ci) 22.3 33.3 I C-14 (Ci) 25.2 25.3 2 Total Fission and Activation Products (Ci) 0.51 0.44 3 Total Particulate (Ci) 0 0 4 Gross Alpha (Ci) 0 0 4 Iodine (Ci) 0 0 4 Calculated Gamma Air Dose (mRad) 4.5 lE-04 4.04E-04 5 Calculated Beta Air Dose (mRad) 1.65E-04 l.46E-04 5 Total Body Dose (mRem) 0.08 0.09 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.

2. C-14 activity released from the site is estimated using reactor power in accordance with EPRI document "Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents".
3. Ar-41 is the major constituent of the total radioactive gas released from the site. Non-radioactive argon gas is routinely added to the Reactor Coolant System (RCS) and then activated to radioactive Ar-41 to enhance detection of primary to secondary leakage. Total Fission and Activation Products can vary year to year depending on how much Argon was added to the Reactor Coolant System.
4. No detectable particulate, gross alpha, or iodine activity was released during 2020 and 202 l.
5. Calculated air dose will change from year to year based on the nuclides and their quantities being released . Each nuclide has a different dose factor. Therefore, annual air dose varies based on the nuclide mix and activity.

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 any fuel defects during the year of this report.

Page 7 of 58

1.1 Executive Summary (continued)

Liquid Effluents:

Two-year summary of all the radioactive liquid releases to the environment:

Liquid Waste 2020 2021 Comments Total Activity Excluding Tritium (Ci) 7.85E-04 6.22E-04 Tritium Activity (Ci) 1370 1840 1 Total Body Dose (mRem) 0.11 0.12 Total Volume Released (Gallons) 1,178,336 660,501 2 Comments:

1. Tritium released values can vary significantly from year to year based on a couple of factors.

First, reactor coolant tritium production changes based on fuel burnup characteristics. Tritium activity increases following reactor startup, then plateaus mid-cycle, and begins to decline towards the end of cycle. Second, the tritium released value is dependent upon how many outages there were during a calendar year. More liquid waste is processed and released during unit outages. There was only one scheduled outage in 2021, however, Unit 2 experienced a forced outage in June of 2021 when the RCS tritium value was near its peak for the cycle.

2. More liquid waste is generated and released during refueling outages. There were two refueling outages in 2020 and only one refueling outage in 2021.

Meteorological Data During 2021, the CPNPP meteorological system achieved a 96.9% 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 2021, there were no Technical Specification/ODCM effluent radiation monitors out of service (OOS) for >30 days.

ODCM Changes There were no revisions to the ODCM during 2021.

Page 8 of58

1.1 Executive Summary (continued)

Solid Waste Two-year summary of the solid waste production:

Total Waste 2020 2021  % Error Shipped (m 3) 118 296 25%

Shipped (Ci) 394 253 25%

Buried (m 3) 118 296 25%

Buried (Ci) 394 253 25%

Comments:

The increase in waste volume buried in 2021 is due to an effort to reduce our backlog of radwaste stored on site. A significant backlog of radwaste has built up over the past few years and the station has implemented a multi-year plan to reduce and ultimately eliminate this backlog.

Page 9 of58

Groundwater Tritium Monitoring Program The monitoring well network at CPNPP includes 12 wells completed in the un-weathered and weathered portions of the Glen Rose Formation. Two monitoring wells are located near the Refueling Water Storage Tank (one at each RWST). Three wells are near or down-gradient of the fuel building (East Side). Four other wells are situated on the periphery North, South and West of the Power Block. Three monitoring wells were placed along the wastewater management system underground piping. Each of the wells are sampled on a quarterly frequency to test for contamination via gamma spectroscopy and Liquid Scintillation.

Water wells used to monitor CPNPP for tritium leaks into the groundwater all had results that were less than the minimum detectable activity (MDA), with the exception of Monitoring Well 11 (MW-11) during 2021 as indicated in Table 1. MW-11 rendered positive results for the first three quarters of 2021.

Tracking Report TR-2021-002450 was initiated due to the first quarter result of 2470 pCi/L on Monitoring Well No. 11. Two follow-up samples were analyzed to verify the elevated result. No known sources of elevated tritium could be determined outside of leaking water from the Filtered Water Storage Tank that contains tritiated lake water (from permitted releases). All of these sample results were less than the drinking water limit of 20,000 pCi/L.

On November 6, 2021, a pipe failure on the Condensate Polishing Resin Transfer Line resulted in the leak of over 100 gallons outside of the Northwest corner of the U2 Turbine Building. This leak resulted in approximately 2.7 millicuries of tritium being released at a pipe joint four feet below grade. After testing results were concluded a courtesy notification was made to the Texas Commission on Environmental Quality, the Nuclear Regulatory Commission Resident Inspectors, Texas Department of State Health Services, American Nuclear Insurers and the Nuclear Energy Institute. The leaked contaminant quantity was well below the reportable limit of 100 curies [per Title 30 of the Texas Administrative Code

§327.4(a)(l)], but the voluntary communication was made based on guidance from NEI 07-07, Rev. 1.

Estimated potential dose to a member of the public would be negligible based on site geology. Larger quantities of tritium have been postulated by the Final Safety Analysis Report and determined to decay before reaching the bottom of the Glen Rose Formation to potable water. The only other pathway of exposure is for the tritiated water to reach Squaw Creek. Prior to reaching Squaw Creek the tritiated water would become highly diluted in Squaw Creek Reservoir which averages 3601.5 acre-feet of water (one acre-foot is 325,851 gallons). Such a large body of water would dilute the contaminant to 6.0SE-10 microcuries per milliliter (well below any typical means of laboratory detection).

A Hydrogeology study performed by Golder Associates, Inc., described that CPNPP has perched water above an impermeable layer of bedrock. The 160 to 270 foot thick Glen Rose Formation (the top layer) is not considered a source of useful groundwater in the vicinity of CPNPP as it carries very little water and is unreliable in times of drought. The thickness and mostly impermeable nature of the Glen Rose Formation prevents migration of potentially contaminated groundwater to the underlying Twin Mountains Fonnation.

Continued monitoring of perched water sample points will occur as part of the Groundwater Monitoring Program (STA-654) and any new sources of tritium or increase in the activity will be evaluated and remediated as necessary.

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Table 1. Perched Groundwater Samples for 2021 in Units of Picocuries Per Liter.

MW 3/24/2021 4/7/2021

  • 4/14/2021
  • 6/16/2021 9/14/2021 12/8/2021 Location 9 <891 <958 <1010 <1040 10 <891 <958 <1010 <1040 11 2470 3360 3220 3040 2800 <1040 12 <891 <958 <1010 <1040 14 <891 <958 <1010 <1040 15 <891 <958 <1010 <1040 16 <891 <958 <1010 <1040 19 <891 <958 <1010 <1040 25 <891 <958 <1010 <1040 CP-A <891 <958 <1010 <1040 CP-B <891 <958 <1010 <1040 CP-C <891 <958 <1010 <1040
  • Special samples were collected on these dates for the MW Location 11 only.

Conclusion During 2021, the radiological effluent monitoring program was 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).

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1.2 Historical Trend Graphs Total Gaseous Fission and Activation Activity 0.60 Released 0.55 0.51 0.50 ~

0.43 0.44

- 0.42 -

(.) 0.40 -

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ti)

i 0

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0.00 2015 2016 2017 2018 2019 2020 2021 Year Year Total Gaseous Fission and Activation Activity Released Comments All Ar-41 is the major constituent of the total radioactive gas released from the site. Non-radioactive argon gas is routine ly added to the Reactor Coolant System (RCS) and then activated to radioactive Ar-41 to enhance detection of primary to secondary leakage.

Total Fission and Activation Products can vary year to year depending on how much Argon was added to the Reactor Coolant System.

2020 2020 radioactive nob le gaseous activity released was higher than 2019 due to more Argon-41 (Ar-4 1) gas activity released. Leaks in each unit' s argon injection system were found and repaired late 2019, allowing more Argon to be injected into the RCS. This resulted in higher Ar-41 activity released in 2020 compared to the 2019 activity released (CR-2019-007553).

Page 12 of 58

Total Gaseous Tritium Released 45.00

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0.00 2015 2016 2017 2018 2019 2020 2021 Year Year Total Gaseous Tritium Released Comments All The major contributor to gaseous tritium activity is evaporation from the spent fuel pools. Factors contributing to the tritium activity in the pools is related to the type of fuel used (i.e., 18-month fuel) the core life, power output, and number of core cycles.

Page 13 of 58

Total Body Dose due to Gaseous Activity Released 0.12 0.10 n~n 0.10 0.09 0.09 0.08 n no n no

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0.00 2015 2016 2017 2018 2019 2020 2021 Year Total Body Dose due to Gaseous Activity Released Comments Year NIA No comments.

Page 14 of58

Total Volume Liquid Effluents Released 10,000, 000 1,231,176 998,679 1,178,336

~~,;: 17R 67R.996 - 694 848 - ~n1

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1 2015 201 6 2017 2018 2019 2020 2021 Year Year Total Volume Liquid Effluents Released Comments All Total volume of liquid effluents released can vary significantly from year to year depending on the number of refueling and maintenance outages. More liquid waste is processed and released during these outages.

Page 15 of 58

Total Activity (Excluding Triti um) Released in Liquid Effluents 2.50 1 n -,

2.00 1.83 -

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0.00 2015 2016 2017 2018 201 9 2020 2021 Year Year Total Activity (Excluding Tritium) Released in Liquid Effluents Comments All Total activity released in liquid effluents can vary year to year depending on the number of refueling and maintenance outages, as well as other factors.

Page 16 of 58

Total Curies of Tritium Released in Liquid Effluents 3000 251 0 21 20

(.)

2000 1950 HS4U 0

C 0 1390 1370

(.) - 1210 -

M

I: -

"O 1000 -~ ~

I er
J 0

2015 2016 2017 2018 2019 2020 2021 Year Year Total Curies of Tritium Released in Liquid Effluents Comments All Tritium released values can vary significantly from year to year based on a couple of factors. First, reactor coolant tritium production changes based on fuel burnup characteristics. Tritium activity increases fo llowing reactor startup, then plateaus mid-cycle, and begins to decline towards the end of cycle. Second, the tritium released value is dependent upon on how many outages there were during a calendar year. More liquid waste is processed and re leased during unit outages.

2017 More tritium was released due to multiple outages during the year.

2021 There was only one schedu led outage in 2021 , however, Unit 2 experienced a forced outage in June of 2021 when the RCS tritium value was near its peak for the cycle.

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Total Body Dose Due to Liquid Effluents Released 0.20

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0.00 2015 2016 2017 2018 2019 2020 2021 Year Year Total Bod Dose Due to Li uid Effluents Released Comments NIA No comments.

Page 18 of 58

Total Volume of Solid Radwaste Buried 350 296 300 -

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2015 n2016 2017 n

2018 2019 2020 2021 Year Total Volume of Solid Radwaste Buried Comments Year 2019 The waste volume increase over the previous year was due to an effort to reduce onsite waste inventory. The spent resin inventory was near capacity and a resin shipping campaign was undertaken shipping 5 HICs offsite to make space to support interim resin storage for planned plant operational needs. Additionally, we had several Energy Solutions Sea Land containers stored onsite containing Dry Active Waste (DAW). To avoid continuing to pay rental costs on these containers and to reduce waste inventory, 10 Sea Lands were returned to Energy Solutions in a DAW shipping campaign.

2020 In 2020, the decrease in shipped and buried waste volume was due to making only two DAW shipments compared to five in 2019. Additionally, only three High Integrity Containers of spent resins were shipped in 2020 as compared to five in 2019.

2021 The increase in waste volume buried in 2021 is due to an effort to reduce our backlog of radwaste stored on site. A significant backlog of radwaste has built up over the past few years and the station has implemented a multi-year plan to reduce and ultimately eliminate this backlog.

Page 19 of 58

Total Curies of Solid Radwaste Buried 1200 1,030.0 1000 -

800 ti)

Q)

"i: 600

J u

394.0 400 253.0 172.0 200

- ~

52.1 45.6 22.5 0 17 II .------,

2015 2016 2017 2018 2019 2020 2021 Year Year Total Curies of Solid Radwaste Buried Comments 2018 During 20 18, CPNPP shipped off 5 High Integrity Containers (HlCs) containing high activity resin in order to make room for future resi n transfers and filter changes. These sh ipments were necessary to ensure the expected volume of resin transferred from the plant during 2019 could be properly stored on site. These shipments led to higher values for Curies shipped and buried for 20 18 .

2019 The majority of waste shipped offsite was Dry Active Waste (DAW) with low activity . While the total volume buried increased significantly over the previous years (refer to Total Volume of Solid Radwaste Buried histogram on next page), the Curies buried was much lower.

2020 The shipped and buried total activity was more than double the activity shipped in 2019. One of the High Integrity Containers shipped in 2020 was a Waste Class C shipment which by itself had an activity level 30% greater than the total sum of all activity shipped in 20 19.

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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 Iodine-131, lodine-133, Tritium and Radioactive Material in Particulate Form The dose rate due to iodine-131, iodine-13 3, 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.

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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
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 L VW pond shall be limited by the following expression:

(264/V)

  • ri A/Ci < 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 (~tCi/Ci per mL/gal)

This expression limits the total quantity of radioactive materials in resins discharged to the LVW Pond to a value such that the average concentration in the resins, calculated over the total volume of resins in the pond, will not exceed one times the Effluent Concentration Limits specified in 10 CPR 20, Appendix B, Table 2, Column 2.

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 7 5 mRem.

Page 22 of58

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 CPR 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.

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 L VW 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 L VW pond, daily grab samples were obtained over the period of pond discharge. These samples wete 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.

Page 23 of 58

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.

C-14 was estimated in accordance with the methodology in the EPRI report Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents. EPRI, Palo Alto, CA: 2010, 1021106. See Attachment 10.3 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 (Unplanned) Releases Abnormal releases are defmed as unplanned or uncontrolled releases of radioactive material from the site boundary. There were no abnormal (unplanned) liquid or gaseous radioactive effluent releases during 2021.

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 ofradioactive material released as solid wastes are summarized in Table 9.10.

Page 24 of58

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 was 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 Air doses due to gaseous effluent gamma and beta emissions were calculated using the highest annual average atmospheric dispersion factor at the Site Boundary location, in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table 9.8.

6.3 Dose Due to Radioiodines, Tritium, and Particulates in Gaseous Releases The dose to an adult, teen, child, and infant from radioiodines 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 2021 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 Dose to a Member of the Public from activities inside the site boundary was evaluated. The highest dose resulted from recreational fishing on Squaw Creek Reservoir. A dose of 3.13E-03 mRem/yr was calculated based on an individual 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.

Page 25 of 58

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 2021 is retained onsite. These data are available for review by the NRC upon request. Joint Frequency Tables are included in Attachment 10.1. During the year of this report, the goal of> 90% joint data recovery was met:

Meteorolo2:ical Data Recovery Channel  % Recovery 10 m Wind Speed 95.1 10 m Wind Direction 93.2 Delta Temperature A 99.7 Delta Temperature B 99.7 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 2021, there were no instances where these instruments were inoperable for more than thirty days.

8.2 Changes to the Offsite Dose Calculation Manual No changes were made to the ODCM during 2021.

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 2021 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 2021 Land Use Census.

Page 26 of58

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 10 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.

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 Abnormal (Unplanned) Gaseous Effluent Release No abnormal (unplanned) gaseous effluent releases occurred during 2021.

8.5.2 Abnormal (Unplanned) Liquid Effluent Releases No abnormal (unplanned) liquid effluent releases occurred during 2021.

Page 27 of 58

8.6 Resin Releases to the Low Volume Waste (LVW) Pond A total of 23 6 ft 3 of powdex resin was transferred to the L VW pond during 2021. The cumulative activity deposited in the LVW pond Elince operations began through the end of 2021 is l.80E-03 Curies, consisting ofCo-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.

During 2021, no changes to the Radwaste Treatment Systems occurred meeting the reporting criteria of the Process Control Program.

8.8 Groundwater Tritium Monitoring Program The monitoring well network at CPNPP includes 12 wells completed in the un-weathered and weathered portions of the Glen Rose Formation. Two monitoring wells are located near the Refueling Water Storage Tank (one at each RWST). Three wells are near or down-gradient of the fuel building (East Side). Four other wells are situated on the periphery North, South and West of the Power Block. Three monitoring wells were placed along the wastewater management system underground piping. Each of the wells are sampled on a quarterly frequency to test for contamination via gamma spectroscopy and Liquid Scintillation.

Water wells used to monitor CPNPP for tritium leaks into the groundwater all had results that were less than the minimum detectable activity (MDA), with the exception of Monitoring Well 11 (MW-11) during 2021 as indicated in Table 1. MW-11 rendered positive results for the first three quarters of 2021. Tracking Report TR-2021-002450 was initiated due to the first quarter result of 2470 pCi/L on Monitoring Well No. 11. Two follow-up samples were analyzed to verify the elevated result. No known sources of elevated tritium could be determined outside of leaking water from the Filtered Water Storage Tank that contains tritiated lake water (from permitted releases). All of these sample results were much less than the drinking water limit of 20,000 pCi/L.

On November 6, 2021, a pipe failure on the Condensate Polishing Resin Transfer Line resulted in the leak of over 100 gallons outside of the Northwest comer of the U2 Turbine Building. This leak resulted in approximately 2.7 millicuries of tritium being released at a pipe joint four feet below grade. After testing results were concluded a courtesy notification was made to the Texas Commission on Environmental Quality, the Nuclear Regulatory Commission Resident Inspectors, Texas Department of State Health Services, American Nuclear Insurers and the Nuclear Energy Institute. The leaked contaminant quantity was well below the reportable limit of 100 curies [per Title 30 of the Texas Administrative Code §327.4(a)(l)], but the voluntary communication was made based on guidance from NEI 07-07, Rev. 1. Estimated potential dose to a member of the public would be negligible based on site geology. Larger quantities of tritium have been postulated by the Final Safety Analysis Report and determined to decay before reaching the bottom of the Glen Rose Formation to potable water. The only other pathway of exposure is for the tritiated water to reach Squaw Creek. Prior to reaching Squaw Creek the tritiated water would become highly diluted in Squaw Creek Reservoir which averages 3601.5 acre-feet of water (one acre-foot Page 28 of 58

is 325,851 gallons). Such a large body of water would dilute the contaminant to 6.08E-10 microcuries per milliliter (well below any typical means of laboratory detection).

A Hydrogeology study performed by Golder Associates, Inc., described that CPNPP has perched water above an impermeable layer of bedrock. The 160 to 270 foot thick Glen Rose Formation (the top layer) is not considered a source of useful groundwater in the vicinity of CPNPP as it carries very little water and is unreliable in times of drought. The thickness and mostly impermeable nature of the Glen Rose Formation prevents migration of potentially contaminated groundwater to the underlying Twin Mountains Formation.

Continued monitoring of 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.

Table 2. Perched Groundwater Samples for 2021 in Units of Picocuries Per Liter.

MW 3/24/2021 4/7/2021

  • 4/14/2021
  • 6/16/2021 9/14/2021 12/8/2021 Location 9 <891 <958 <1010 <1040 10 <891 <958 <1010 <1040 11 2470 3360 3220 3040 2800 <1040 12 <891 <958 <1010 <1040 14 <891 <958 <1010 <1040 15 <891 <958 <1010 <1040 16 <891 <958 <1010 <1040 19 <891 <958 <1010 <1040 25 <891 <958 <1010 <1040 CP-A <891 <958 <1010 <1040 CP-B <891 <958 <1010 <1040 CP-C <891 <958 <1010 <1040
  • Special samples were collected on these dates for the MW Location 11 only.

Page 29 of58

Groundwater Tritium M onitoring Well Map

~II.!~~

EXPLANATION

  • Moni\tlrinGWeU LOC.ltiC11 (Wea'ihered Glen Rose Formalion)

Q, Manitoring Wel localion (Unwi!athaed Glen Rose Fonnaiion)

H-* ** - * *** - - - - ** . -- ..... . .

(iJB.63) Water Level E~ tion (Ft MSL]

(NM== Not Meas med)

-- - - <<,::,:::," ~- 790- Groundwater Elev31ion Conloo.r (Ft MSl ) Coo1oUJ' lntenaF 10ft 1== = = = :;.r.:,w *~

__ ,J,,,,

/ (;: : -8*-~~~'°U.TU/lliCICll!'.IIOU'O- _ ~- * *o~ Note:

"t.'"weas Nos. ID, 15. HI, CP.-A. CP-B, and CP-C to oonslnJd po1entiomeiric $j,Jrfuce oontou.-s were not

,,,~_,,/ '*..,'**--- - -- - --

used for this tigUTI! because these wells a re not oonsidered to be in hydraulic connection wil.h 1he other wells.

  • No. ,
2. Groundwater ele11.rtion contours WeA! comtrucied b ased on predomin.mt water lev-el eleva1iorn; II order SO ev-atuate

~

~ the overall hydrauf)C gradient id the Site. and thus T*~*r;t*

contDU"S may nOI be entiref'/ tonsis1ent with lhe individual elel.ations at aU wells.

I

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ffl'USJ i 1 ~~~ I u

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Creaied from TXU Bec:b'"ic CPSES She- Map SGM-01 .

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  • - - =-==Jjr~~

j I I

/ LUMINANT - CPNPP

./ Fi!Jlre 23

- _,w1 *-*/'

UNWEATHERED GLEN ROSE FORMATION - GROUNDWATER ELEVATIONS

  • AUG. 29, 2010 PROJECT: 1785 I BY: AJO REVISIONS:

.. - -*-** -**- **- **-**-**~ 10ATE: AUG.* 2D 12 I CHECKED: RJM I PASTOR, BEHLING & WHEELER, LLC CONSULTING ENGINEERS AND SCIENTISTS Page 30 of 58

8.9 Independent Spent Fuel Storage Installation (ISFSI)

There are no radiological effluents released from the ISFSI. Direct dose from this installation is monitored using the normal environmental direct dose program and reported in the Annual Radiological Environmental Operating Report (ARBOR).

Page 31 of 58

SECTION 9.0 EFFLUENT TABLES Page 32 of 58

Table 9.1 Liquid and Gaseous Batch Release Summary A. Liquid Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual

1. Number of batch releases 3 8 13 12 36
2. Total time period for Batch releases Minutes 8.80E+02 2.09E+03 3.88E+03 3.84E+03 1.07E+04
3. Maximum time period for a batch release Minutes 3.35E+02 3.40E+02 3.85E+02 3.45E+02 3.85E+02
4. Average time period for a batch release Minutes 2.93E+02 2.61E+02 2.98E+02 3.20E+02 2.97E+02
5. Minimum time period for a batch release Minutes 2.25E+02 1.80E+02 5.S0E+0l 2.87E+02 5.S0E+0l B. Gaseous Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual
1. Number of batch releases 31 36 33 33 133
2. Total time period for batch releases Minutes l.11E+04 1.28E+04 l.10E+04 l.51E+04 5.00E+04
3. Maximum time period for a batch release Minutes 4.19E+02 4.22E+02 4.04E+02 2.42E+03 2.42E+03
4. Average time period for a batch release Minutes 3.59E+02 3.55E+02 3.33E+02 4.57E+02 3.76E+02
5. Minimum time period for a batch release Minutes 2.16E+02 l.94E+02 2.85E+02 2.63E+02 l.94E+02 Page 33 of 58

Table 9.2 Abnormal Liquid and Gaseous Batch Release Summary A. Liquid Abnormal Release Totals Units Quarter 1 Quarter 2 Quarter3 Quarter4 Totals I. 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 Quarter3 Quarter 4 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 34 of58

Table 9.3 Gaseous Effluents - Summation of All Releases Quarter Quarter Quarter Quarter Type of Effluent Units Total 1 2 3 4 A. Fission and Activation Gases

1. Total Release Curies 9.37E-02 9.09E-02 1.05E-01 1.51E-01 4.40E-01
2. Average Release rate for period µCi/sec 1.21E-02 l.15E-02 1.32E-02 1.90E-02 l.40E-02
3. Percent of Applicable Limit  % * * * *
  • B. Radioiodines
1. Total Iodine-131 Curies 0.00E+O0 0.00E+00 0.00E+00 0.00E+00 0.00E+00
2. Average Release rate for period µCi/sec 0.00E+00 O.00E+00 O.00E+00 0.00E+00 0.00E+00
3. Percent of Applicable Limit  % * * * *
  • C. Particulates
1. Particulates (Half-Lives> 8 Curies 0.00E+00 0.00E+O0 0.00E+00 0.00E+00 0.00E+00 Days)
2. Average Release rate for period µCi/sec 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00
3. Percent of Applicable Limit  % * * * *
1. H-3 Release Curies 3.87E+00 7.52E+00 1.13E+0l 1.06E+0l 3.33E+0l
2. Average Release rate for period µCi/sec 4.97E-0l 9.57E-01 1.43E+00 l.33E+00 1.06E+00
3. Percent of Applicable Limit  % * * * *
1. C-14 Release Curies 6.72E+00 6.36E+00 6.92E+00 5.27E+0O 2.53E+Ol
2. Average Release rate for period µCi/sec 8.64E-0l 8.I0E-01 8.75E-01 6.62E-01 8.02E-01
3. Percent of Applicable Limit  % * * * *
  • F. Gross Alpha
1. Total Release Curies 0.00E+00 0.00E+00 O.00E+00 0.0OE+00 0.00E+00
  • Applicable limits are expressed in terms of dose.

Estimated Total Error for All Values Reported Is< 1.0%

Page 35 of 58

Table 9.4 Gaseous Effluents - Ground Level Releases Continuous Mode N uclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Total Fission Gases No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Iodines No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Particulates No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Tritium H-3 Curies 3.82E+00 7.45E+00 l.13E+0l l.05E+0l 3.31E+Ol Carbon-14 C-14 Curies 2.02E+00 l.91E+00 2.07E+0O 1.58E+00 7.58E+O0 Gross Alpha No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 O.0OE+00 If Not Detected, Nuclide is Not reported.

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

Page 36 of58

Table 9.4 (continued)

Gaseous Effluents - Ground Level Releases Batch Mode N uclides Released Unit Quarter 1 Quarter 2 Quarter3 Quarter 4 Total Fission Gases Ar-41 Curies 9.24E-02 8.97E-02 l.02E-01 l.30E-01 4.13E-01 Kr-85m Curies 0.00E+00 0.00E+00 2.68E-03 3.0lE-05 2.71E-03 Xe-133m Curies 0.00E+00 0.00E+00 0.00E+00 1.45E-04 l.45E-04 Xe-133 Curies l.32E-03 5.64E-04 5.74E-04 l.43E-02 l.67E-02 Xe-135m Curies 0.00E+00 0.00E+00 0.00E+00 3.52E-05 3.52E-05 Xe-135 Curies 0.00E+00 0.00E+00 0.00E+00 7.38E-03 7.38E-03 Total for Period Curies 9.37E-02 9.02E-02 l.0SE-01 l.51E-01 4.40E-01 Iodines No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.O0E+00 Particulates No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.O0E+00 Tritium H-3 Curies 4.87E-02 7.00E-02 3.98E-02 4.79E-02 2.06E-01 Carbon-14 C-14 Curies 4.71E+00 4.45E+00 4.84E+00 3.69E+00 l.77E+0l Gross Alpha No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 If Not Detected, Nuclide is Not reported.

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

Page 37 of 58

Table 9.5 Liquid Effluents - Summation Of All Releases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual A. Fission and Activation Products

1. Total Release ( excludes tritium, gases, Curies 1.22E-04 4.llE-05 7.96E-05 3.79E-04 6.22E-04 alpha)
2. Average diluted concentration during period µCi/rnL 4.94E-11 5.31E-12 5.47E-12 2.73E-11 1.61E-11
3. Percent of Applicable Limit  % * * * *
1. Total Release Curies 7.75E+Ol 4.40E+02 8.60E+02 4.59E+02 1.84E+03
2. Average diluted concentration during period µCi/rnL 3.13E-05 5.67E-05 5.91E-05 3.31E-05 4.75E-05
3. Percent of Applicable Limit  % * * * *
  • C. Dissolved and Entrained Gases I. Total Release Curies O.OOE+OO O.OOE+OO 1.28E-04 5.66E-05 1.84E-04
2. Average diluted concentration during period µCi/rnL O.OOE+OO O.OOE+OO 8.78E-12 4.09E-12 4.77E-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 µCi/rnL O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO E: Waste Vol Release (Pre-Dilution) Liters 2.38E+05 5.28E+05 8.61E+05 8.70E+05 2.50E+06 F. Volume of Dilution Water Used Liters 2.47E+09 7.75E+09 1.45E+l0 l.38E+IO 3.86E+l0
  • Applicable limits are expressed in terms of dose.

Estimated Total Error for All Values Reported is< 1.0%

Page 38 of58

Table 9.6 Liquid Effluents Continuous Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Fission and Activation Products No Nuclides Found Curies 0.00E+00 0.00E+00 0.00E+00 O.0OE+00 0.00E+OO Tritium H-3 Curies 0.OOE+00 0.00E+00 0.00E+00 0.00E+00 0.00E+OO Dissolved and Entrained Gases No Nuclides Found Curies O.00E+00 0.00E+00 0.O0E+00 0.00E+00 0.00E+O0 Gross Alpha Radioactivity Curies O.00E+00 0.00E+00 0.00E+0O 0.OOE+00 0.00E+O0 Batch Mode Nuclides Released Units Quarter 1 Quarter 2 Quarter3 Quarter 4 Annual A. Fission and Activation Products Cr-51 Curies 0.00E+00 0.00E+00 0.00E+00 l .79E-05 l.79E-05 Mn-54 Curies 0.00E+00 0.00E+00 0.00E+00 8.74E-06 8.74E-06 Co-58 Curies 0.00E+00 3.3 IE-06 4.95E-06 1.49E-04 1.57E-04 Co-60 Curies 0.00E+00 3.78E-05 7.46E-05 2.04E-04 3.16E-04 Ni-63 Curies l.22E-04 0.00E+00 0.00E+00 0.00E+00 l.22E-04 Total for Period Curies 1.22E-04 4.l IE-05 7.96E-05 3.79E-04 6.22E-04 B. Tritium H-3 Curies 7.75E+0l 4.40E+02 8.60E+02 4.59E+02 l.84E+03 C. Dissolved and Entrained Gases Xe-133 Curies 0.00E+00 0.00E+00 l.28E-04 5.66E-05 1.84E-04 D. Gross Alpha Activity No Nuclides Found Curies 0.0OE+O0 0.0OE+00 0.00E+00 0.O0E+00 0.00E+0O If Not Detected, Nuclide is Not reported.

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

Page 39 of58

Table 9.7 Dose Due to Liquid Releases Organ Dose Units Quarter 1 Quarter 2 Quarter3 Quarter 4 Annual Bone mRem 2.25E-05 0.00E+00 0.00E+00 0.00E+00 2.25E-05 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.000 0.000 0.000 0.000 0.000 Liver mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 l.20E-0l Limit mRem 5 5 5 5 10 Percent of Limit  % 0.615 0.582 0.558 0.648 1.202 Total Body mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 1.20E-01 Limit mRem 1.5 1.5 1.5 1.5 3 Percent of Limit  % 2.049 1.941 1.860 2.161 4.005 Thyroid mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 1.20E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.615 0.582 0.558 0.648 1.202 Kidney mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 l.20E-0l Limit mRem 5 5 5 5 10 Percent of Limit  % 0.615 0.582 0.558 0.648 1.202 Lung mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 1.20E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.615 0.582 0.558 0.648 1.202 GI-Lli mRem 3.07E-02 2.91E-02 2.79E-02 3.24E-02 1.20E-01 Limit mRem 5 5 5 5 10 Percent of Limit  % 0.615 0.582 0.558 0.648 1.202 Page 40 of 58

Table 9.8 Air Dose Due To Gaseous Releases NG Dose Units Quarter 1 Quarter2 Quarter3 Quarter 4 Annual Gamma Air mRad 9.00E-05 8.73E-05 9.88E-05 l.28E-04 4.04E-04 Limit mRad 5 5 5 5 10 Percent of Limit  % 0.002 0.002 0.002 0.003 0.004 Beta Air mRad 3.19E-05 3.08E-05 3.54E-05 4.80E-05 l.46E-04 Limit mRad 10 10 10 10 20 Percent of Limit  % 0 0 0 0 0.001 NG Total Body mRem 8.55E-05 8.30E-05 9.39E-05 l.22E-04 3.84E-04 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.001 0.002 0.001 0.002 0.003 NG Skin mRem 1.25E-04 l.21E-04 l.38E-04 l.79E-04 5.63E-04 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.002 0.002 0.002 0.003 0.004 Page 41 of 58

Table 9.9 Dose Due to Radioiodines 2 Particulates 2 Tritium 2 and Carbon-14 in Gaseous Releases Organ Dose Units Quarter 1 Quarter 2 Quarter3 Quarter 4 Annual Liver mRem l.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 Total Body mRem l.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 Thyroid mRem 1.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 Kidney mRem l.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 Lung mRem* l.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 GI-Lli mRem l.61E-02 2.07E-02 2.69E-02 2.32E-02 8.69E-02 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.215 0.276 0.359 0.309 0.579 Bone mRem 5.56E-02 5.26E-02 5.72E-02 4.36E-02 2.09E-01 Limit mRem 7.5 7.5 7.5 7.5 15 Percent of Limit  % 0.741 0.701 0.763 0.581 1.393 Page 42 of58

Table 9.10 Solid Radwaste and Irradiated Fuel Shipments AS 0 rId W aste Sh"1ppe dOff:'t . I or D"1sposaI (N 0 t I rra d"1ated F ueI) s1 e fior B una Shipped Shipped Buried Buried Percent

1. Type of Waste m3 m3 Ci Ci Error
a. Spent resins/filters l.95E+0l 2.53E+02 l.95E+0l 2.53E+02 +/-25%
b. Dry active waste 2.76E+02 l.35E-01 5.66E+0l 8.58E-02 +/-25%
c. Irradiated components 0 0 0 0 NIA
d. Other (oil/miscellaneous liquids sent 0 0 0 0 NIA to processor for volume reduction)

TOTAL 2.96E+02 2.53E+02 2.96E+02 2.53E+02 +/-25%

Note: Shipped volumes 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 84.84 2.14E+02 Fe-55 9.61 2.43E+0l Co-60 3.60 9.l0E+00 C-14 0.74 l.88E+00 Ni-59 0.55 l.39E+00 Cs-137d 0.45 l.13E+00 Tc-99 0.15 3.79E-01 1-129 <0.02 4.72E-02 H-3 <0.02 4.55E-02 Other (I) 0.02 7.30E-Ol Total 100.00 3.94E+02
b. Dry active waste Fe-55 44.00 5.93E-02 Co-60 23.84 3.21E-02 Ni-63 15.91 2.14E-02 Co-58 10.58 l.42E-02 Nb-95 1.36 l.83E-03 Mn-54 0.95 l.27E-03 Sb-125 0.90 l.21E-03 Zr-95 0.62 8.39E-04 Cr-51 0.58 7.82E-04 Cs-137d 0.40 5.38E-04 C-14 0.38 5.16E-04 Tc-99 0.29 3.84E-04 H-3 LLD 1-129 LLD Other C2J 0.19 6.00E-4 Total 100.00 l.35E-01 (1) Nuclides representing <1 % of total shipped activity: Sb-125, Sr-90d, Mn54, Pu-241, Co-57, Am-241, Cm-243/244, Pu-238, Pu-239/240, Co-58, Nb-95, Zr-95, and Cr-51.

(2) Nuclides representing <1 % of total shipped activity: Co-57.

Page 43 of 58

Table 9.10 {continued)

Solid Radwaste and Irradiated Fuel Shipments

3. Solid Waste Disposition (Mode of Transportation: Truck)

Waste Container Number of Waste Type Destination Class Type Shipments A Poly HIC* 3

a. Resin/filters C Poly HIC* 1 Waste Control Specialists, Andrews, TX
b. Dry active waste A General Design 5
  • High Integrity Container B. Irradiated Fuel Shipments (Disposition)

Number of Shipments Mode of Transportation Destination 0 NIA NIA Page 44 of 58

Attachment 10.1 Meteorological Joint Frequency Distribution Tables Page 45 of 58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS A ELEVATION:

10 m r

i",

Iru~1ae.eo,nT1 :int~,rt; y; lfj 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 3 7 1 0 11 NNE 0 10 18 5 0 0 33 NE 0 16 4 0 0 0 20 ENE 2 20 7 0 0 0 29 E 2 19 9 2 0 0 32 ESE 1 22 34 0 0 0 57 SE 1 23 22 3 0 0 49 SSE 0 25 56 42 0 0 123 s 0 7 32 29 3 0 71 SSW 0 3 7 1 0 0 11 SW 0 1 0 0 0 0 1 WSW 0 0 2 0 0 0 2 w 0 1 12 0 0 0 13 WNW 0 0 0 0 0 0 0 NW 0 0 3 4 6 0 13 NNW 0 2 13 23 7 0 45 VARIABLE 0 4 12 4 0 0 20 TOTAL 6 153 234 120 17 0 530 Periods of calm (hours): 0 Hours of missinq data: 4 Page 46 of58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS B ELEVATION:

10 m

>.,"'"" ~ ~,, ,:\k\111[;]Q.;)C:Jf .I IF

MZ ',~

'*'°

1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 4 5 0 0 9 NNE 1 4 5 2 0 0 12 NE 1 10 1 0 0 0 12 ENE 0 16 0 0 0 0 16 E 1 14 4 1 0 0 20 ESE 2 32 21 0 0 0 55 SE 2 15 13 3 0 0 33 SSE 0 25 28 26 0 0 79 s 0 18 48 52 5 0 123 SSW 1 2 12 9 0 0 24 SW 0 8 3 2 0 0 13 WSW 0 1 5 5 0 0 11 w 0 1 4 0 0 0 5 WNW 0 0 0 0 0 0 0 NW 0 1 1 5 4 3 14 NNW 0 9 8 15 6 0 38 VARIABLE 1 3 4 1 0 0 9 TOTAL 9 159 161 126 15 3 473 Periods of calm (hours): 0 Hours of missinQ data: 0 Page 47 of58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS C ELEVATION:

10 m 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 12 4 1 1 18 NNE 0 5 7 1 0 0 13 NE 2 8 2 0 0 0 12 ENE 5 15 2 0 0 0 22 E 6 17 5 1 0 0 29 ESE 1 47 21 0 0 0 69 SE 1 29 24 3 0 0 57 SSE 2 19 37 27 3 0 88 s 2 23 48 47 8 0 128 SSW 1 11 22 16 3 0 53 SW 0 11 15 7 0 0 33 WSW 0 5 4 4 0 0 13 w 0 3 7 3 0 0 13 WNW 0 0 8 0 0 0 8 NW 0 4 5 13 5 3 30 NNW 0 7 10 12 8 1 38 VARIABLE 1 3 8 4 0 0 16 TOTAL 21 207 237 142 28 5 640 Periods of calm 0 Hours of missin data: 0 Page 48 of58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS D ELEVATION:

10 m ii!iiiicO!

/< ., ff.ES <<

,II<

,,:,,:,,,,,,,;u-

' *f'IHm</<<'ii </<<

Wl/i</ ,H<<<<<

4-7 8-12 13-18 19-24 >24 TOTAL N 0 24 87 56 0 0 167 NNE 1 46 57 14 2 0 120 NE 6 35 29 4 0 0 74 ENE 7 51 29 2 0 0 89 E 28 108 47 6 1 0 190 ESE 36 175 53 2 0 0 266 SE 24 237 237 18 0 0 516 SSE 28 142 370 183 23 0 746 s 26 97 286 144 32 5 590 SSW 19 50 56 36 5 0 166 SW 17 34 31 7 2 0 91 WSW 11 31 16 4 1 0 63 w 13 28 46 9 5 0 101 WNW 2 19 24 23 6 4 78 NW 3 29 28 57 18 5 140 NNW 2 26 100 103 30 1 262 VARIABLE 14 33 63 25 0 0 135 TOTAL , 237 1165 1559 693 125 15 3794 Periods of calm (hours): 5 Hours of missinq data: 14 Page 49 of 58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS E ELEVATION:

10 m 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 1 10 9 0 0 0 20 NNE 0 28 10 0 0 0 38 NE 6 9 2 0 0 0 17 ENE 5 6 0 0 0 0 11 E 22 31 1 0 0 0 54 ESE 46 102 4 0 0 0 152 SE 37 336 126 0 0 0 499 SSE 29 191 208 1 0 0 429 s 50 95 56 6 0 0 207 SSW 35 47 25 9 1 0 117 SW 17 28 5 4 1 0 55 WSW 25 23 9 1 0 0 58 w 16 19 6 4 0 0 45 WNW 7 21 26 4 0 0 58 NW 13 37 23 4 0 0 77 NNW 1 13 13 1 0 0 28 VARIABLE 29 18 3 0 0 0 50 TOTAL 339 1014 526 34 2 0 1915 Periods of calm 12 0

Page 50 of58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION

,PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS F ELEVATION:

10 m Jti!!r,li'{Wi ott. SpeJ~Q .rn nn,,*-"' ,,,,,,t,,,*i::*~*

>,,: ,:,:<:,;:~:5,-,-,:,>, ,,,,,,,,

,, ,,,,.,,' ;,;(jijJ" ' "' '

J,!{if~il!w}lsl ,u, './'{;;{at~{j\_tc{>',""__!_<ci:is:,.

1-3 4-7 8-12 13-18 19-24

-E"',3-<cr::-;-**-

>24 TOTAL N 0 0 0 0 0 0 0 NNE 0 1 0 0 0 0 1 NE 0 0 0 0 0 0 0 ENE 1 0 0 0 0 0 1 E 4 3 0 0 0 0 7 ESE 5 4 1 0 0 0 10 SE 9 60 3 0 0 0 72 SSE 21 25 5 0 0 0 51 s 22 15 5 0 0 0 42 SSW 42 21 7 0 0 0 70 SW 26 10 4 0 0 0 40 WSW 26 10 2 0 0 0 38 w 10 7 3 0 0 0 20 WNW 17 10 1 0 0 0 28 NW 6 15 10 0 0 0 31 NNW 2 3 0 0 0 0 5 VARIABLE 24 1 0 0 0 0 25 TOTAL 215 185 41 0 0 0 441 Periods of calm (hours): 1 Hours of missing data: 0 Page 51 of58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS G ELEVATION:

10 m rid/,.~ \lofl J !}/

M c*Cf/ *f

.,.g J 13-18 19-24 >24 TOTAL N 0 0 0 0 0 0 0 NNE 0 0 0 0 0 0 0 NE 0 0 0 0 0 0 0 ENE 0 0 0 0 0 0 0 E 0 0 0 0 0 0 0 ESE 0 0 0 0 0 0 0 SE 10 6 0 0 0 0 16 SSE 2 1 0 0 0 0 3 s 12 1 2 0 0 0 15 SSW 20 14 0 0 0 0 34 SW 15 6 0 0 0 0 21 WSW 17 9 1 0 0 0 27 w 17 5 1 0 0 0 23 WNW 17 7 0 0 0 0 24 NW 11 15 0 0 0 0 26 NNW 1 0 0 0 0 0 1 VARIABLE 21 3 0 0 0 0 24 TOTAL 143 67 4 0 0 0 214 Periods of calm (hours): 0 Hours of missing data: 0 Page 52 of 58

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD: 1-JAN-2021 00:00 to 31-DEC-2021 23:59 STABILITY CLASS ALL ELEVATION:

10 m

~ ~

'+

Cl"'.- ::rn IJ!JllDJj""' (;,/

13-18 19-24 >24 TOTAL N 1 34 115 72 2 1 225 NNE 2 94 97 22 2 0 217 NE 15 78 38 4 0 0 135 ENE 20 108 38 2 0 0 168 E 63 192 66 10 1 0 332 ESE 91 382 134 2 0 0 609 SE 84 706 425 27 0 0 1242 SSE 82 428 704 279 26 0 1519 s 112 256 477 278 48 5 1176 SSW 118 148 129 71 9 0 475 SW 75 98 58 20 3 0 254 WSW 79 79 39 14 1 0 212 w 56 64 79 16 5 0 220 WNW 43 57 59 27 6 4 196 NW 33 101 70 83 33 11 331 NNW 6 60 144 154 51 2 417 VARIABLE 90 65 90 34 0 0 279 TOTAL 970 2950 2762 1115 187 23 8007 Periods of calm (hours): 18 Hours of missing data: 18 Page 53 of 58

2021 Wind Rose and Stability Class Graphs 2021 N

NNW __ -..tr%--- ...

NNE NW NE WNW .

\ ENE >24 mph I

I 19-24 mph

'1 W j' i 1 I t l 13-18 mph II II E 1 ', 8-12 m h I, \ '-

/ 4 -7 mph WSW \

1-3 mph ESE SW SE SSW SSE s

2021 Stability Class To,t al Hours 5000 4000 3000 2000 1000 0

A. B C D E F G Page 54 of 58

Attachment 10.2 Atmospheric Dispersion (X/Q) and Deposition (D/0)

Calculation Methodology Discussion Introduction CR-2014-001059 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.

Discussion 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 infonnation 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. 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 dose to the public.

TR-2022-000094 was initiated to document the evaluation of prevailing wind directions for all stability classes over the calendar year 2021. This evaluation is perfonned 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 2021 predominant wind direction (SSE) and stability class category (Pasquill Class D) did not change when compared with the five year rolling average which includes 2021. No recalculations ofX/Q or D/Q values are required at this time.

Page 55 of58

Attachment 10.3 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-I ife 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 EPRI (Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents, EPRI, Palo Alto, CA: 2010, l 021106) 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 EPRI Report Characterization of Carbon-14 Generated by the Nuclear Power Industry, EPRI Palo Alto, CA: 1995, TR-105715 , measured C-14 releases from PWRs indicating a range of 70% to 95% organic. The average value was indicated to be 80% organic with the remainder being carbon dioxide. As a result, a value of 80% organic C-14 is assumed by the CPNPP Radioactive Effluent Release Report methodology.

The public dose estimates from airborne C-14 in the CPNPP Effluent report are performed using dose models from NUREG-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 56 of 58

Attachment 10.4 Putting Radiation Dose in Context Humans are exposed to radiation every day. The majority comes from natural sources including the earth, food and water consumption, the air, the sun and outer space. A smaller :fraction radiation comes from man-made source such as X-rays, nuclear medical treatments, building materials, nuclear power plants, smoke detectors and televisions.

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

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

Source Average Annual Dose Smoke detector in the home 0.008 mRem Live within 50 miles of a nuclear power plant 0.009mRem 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 reasonably achievable (ALARA)

Round trip flight from New York City to Los Angeles 5mRem Medical X-ray l0mRem EPA limit for dose to the public from the commercial nuclear fuel cycle 25 mRem Food and water consumed throughout the course of one year 30mRem NRC limit for dose to the public from nuclear power plants l00mRem Mammogram 100 mRem Average annual exposure for a nuclear power plant worker 120mRem Average annual exposure from background radiation 300mRem CT scan 1,000 mRem NRC's annual limit for occupational exposure 5,000 mRem Cardiac catheterization or coronary angiogram 5,000mRem

  • Coal is naturally radioactive.

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

Page 57 of58

Attachment 10.5 Errata from Previous Annual Radioactive Effluent Release Reports

1. The 2015 ARERR has a typographical error in Table 9 .4 on page 30. The total tritium for the year was shown as l.64e+Ol. It should have read l.64E-01 Tritium value for the dose calculations was the correct value. AI-TR-2017-009339
2. The 2016 ARERR has an incorrect title on page 13 in the comments section. The title reads: "Total Body Dose due to Gaseous Activity Released Comments" and should read "Total Volume Liquid Effluents Released Comments" Comments in the box regarding the graph on page 13 were correct. IR-2018-001484
3. 2017 ARERR: p. 9- CPNPP should be added to "Water Plant" to clarify that it is the Comanche Peak water plant and not a public facility; p. 18- Comments Table should read "Total Volume of Solid Radwaste Buried" rather than "Total Body Dose due to Liquid Effluents Released"; p. 26- Third paragraph needs to be reworded for clarification. The 2018 ARERR was updated with these comments from TR-2019-000972.
4. 2020 ARERR: Liquid Effluents Table 9.6 on page 38 contains liquid effluent data per Unit vice per Site (exactly one-half of the Site values). However, Table 9.5, Liquid Effluents, Summation of All Releases data on page 37 is correct. Since dose contributions from liquid effluents is calculated using the summation values, dose values for liquid effluents are correct. The reporting error was limited to Table 9.6 and the Executive Summary for liquid effluents on page 8.
5. 2020 and 2021 ARERRs: Several post-release gaseous effluent permits used estimated vs. actual plant vent stack flow rates during 2020 and 2021. Plant vent stack (PVS) flow rates were estimated using the number of fans in service and summing their corresponding flow rates. This is an acceptable practice.

Normally, actual PVS flow rates are derived from plant computer data. However, during these times, the actual values were unavailable when a part of the plant computer system was out of service. The impact to offsite calculated dose rates was insignificant since the only radioisotope released is usually tritium, and its activity is normally very low. This issue was documented in Comanche Peak's corrective action program (CR-2021-003323).

Page 58 of 58

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