Text

2002 Annual Radioactive Effluent Release Report, Table of Contents - Section 1.5
	ML030690146
Person / Time
Site:	Saint Lucie
Issue date:	02/28/2003
From:	Jernigan D; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2003-033, TS 6.14, TS 6.9.17
	Download: ML030690146 (140)
	v • d • e

FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT UNITS NO. I & 2 LICENSE NUMBERS DPR-67 & NPF-16 COMBINED ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE PERIOD JANUARY 1, 2002 THROUGH DECEMBER 31, 2002

TABLE OF CONTENTS DESCRIPTION PAGE EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION.

VISITOR DOSE RESULTS FOR CALENDAR YEAR..............................

6 OFFSITE DOSE CALCULATION MANUAL REVISIONS.....................

6 SOLID WASTE AND IRRADIATED FUEL SHIPMENTS.......................

6 PROCESS CONTROL PROGRAM REVISIONS.......................................

6 LIQUID EFFLUENTS:

Summation of all Releases Unit # 1..................................

7 Summation of all Releases Unit # 2..................................

9 Nuclide Summation by Quarter Unit # 1...........................

11 Nuclide Summation by Quarter Unit # 2...............................

15 Liquid Effluent Dose Unit # I.................................

19 Liquid Effluent Dose Unit # 2...............................

20 GASEOUS EFFLUENT:

Summation of all Releases Unit # 1................................

21 Summation of all Releases Unit # 2................................

23 Nuclide Summation by Quarter Unit # 1...............................

25 Nuclide Summation by Quarter Unit # 2...............................

29 Gas Effluent Dose Unit # 1.................................

33 Gas Effluent Dose Unit # 2...............................

34 SOLID WASTE DISPOSAL - TABLE 3.9 Shipment Summations.................

35 Attachment - A UNPLANNED RELEASE of Gas Decay Tank 2A 39 Attachment - B C-200, ODCM Revision 25 Attachment - C C-200, ODCM Revisions 24 and 25 Mark Up Pages

EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION

1. Regulatory Limits 1.1 For Liquid Waste Effluents A. The concentration of radioactive material released from the site shall be limited to ten 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 2E-4 micro-Curies/ml total activity.

B. The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive material in liquid effluents released, from each reactor unit, to UNRESTRICTED AREAS shall be limited to:

During any calendar quarter to <= 1.5 mrems to the Total Body and to <= 5 mrems to any organ, and During any calendar year to

<= 3 mrems to the Total Body and to <= 10 mrems to any organ.

1.2 For Gaseous Waste Effluents:

A. The dose rate in UNRESTRICTED AREAS due to radioactive materials released in gaseous effluents from the site shall be limited to:

For Noble Gases: <= 500 mrems/yr to the total body and

<= 3000 mrems/yr to the skin, and For Iodine-131, Iodine-133, Tritium, and all radionuclides in particulate form with half-lives greater than 8 days:

<= 1500 mrems/yr to any organ.

B. 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:

During any calendar quarter, to <= 5 mrads for gamma radiation, and

<= 10 mrads for beta radiation and, during any calendar year, to <= 10 mrads for gamma radiation and

<= 20 mrads for beta radiation.

C. The dose to a MEMBER OF THE PUBLIC from lodine-131, Iodine-1 33, Tritium, and all radionuclides in particulate form, with half lives > 8 Days in gaseous effluents released, from each unit to areas at and beyond the site boundary, shall be limited to the following:

During any calendar quarter to <= 7.5 mrem to any organ, and During any calendar year to

<= 15 mrem to any organ The calculated doses contained in an annual report shall not apply to any ODCM Control. The reported values are based on actual release conditions instead of historical conditions that the ODCM Control dose calculations are based on. The ODCM Control dose limits are therefore included in Item I of the report, for information only.

1

EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION (Continued)

2. Effluent Concentration Limits (ECL)

Water: Ten times the 10 CFR Part 20, Appendix B, Table 2, Column 2, except for entrained or dissolved noble gases as described in 1.1.A of this report.

Air:

Release concentrations are limited to dose rate limits described in 1.2.A. of this report.

3. Average energy of fission and activation gases in gaseous effluents is not applicable.

4. Measurements and Approximations of Total Radioactivity Where alpha, tritium, ýand listed nuclides are shown as zero Curies released, this should be interpreted as "no activity was detected on the samples using the ODCM Control analyses techniques to achieve required Lower Limit of Detection (LLD) sensitivity for radioactive effluents."

A summary of liquid effluent accounting methods is described in Table 3.1.

A summary of gaseous effluent accounting methods is described in Table 3.2.

4.1 Estimate of Errors LIQUID GASEOUS Error Topic Avg %

Max %

Avg %

Max %

Release Point Mixing 2

5 NA NA Sampling 1

5 2

5 Sample Preparation 1

5 1

5 Sample Analysis 3

10 3

10 Release Volume 2

5 4

15 Total Percent i

9 30 10 35 The predictability of error for radioactive releases can only be applied to nuclides that are predominant in sample spectrums.

Nuclides that are near background relative to the predominant nuclides in a given sample could easily have errors greater than the above listed maximums.

2

EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION (Continued)

4. Measurements and Approximations of Total Radioactivity (Continued) 4.2 Methods of Analyses TABLE 3.1 RADIOACTIVE LIQUID EFFLUENT SAMPLING AND ANALYSIS Liquid Sampling Method of Source Frequency Type of Analysis Analysis Each Batch Principal Gamma Emitters p.h.a.

Monitor Monthly Tritium L.S.

Tank Composite Gross Alpha AIC Releases Quarterly Sr-89, Sr-90, Fe-55, C-14, Ni-63 Composite C.S.

Continuous Daily Principal Gamma Emitters Releases Grab

& 1-131 for p.h.a.

Samples 4/M Composite Analysis Dissolved & Entrained Gases One Batch/ Month p.h.a.

Tritium Composite Monthly L.S.

Alpha Composite Monthly AIC Sr-89, Sr-90, Fe-55, C-14, Ni-63 Composite Quarterly C.S.

p.h.a.- Gamma Spectrum Pulse Height Analysis using Germanium Detectors. All peaks are identified and quantified.

L.S.- Liquid Scintillation Counting C.S.- Chemical Separation AIC - Air Ion Chamber 4/M - Four per Month 3

EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION (Continued)

4. Measurements and Approximations of Total Radioactivity (Continued) 4.2 Methods of Analyses (Continued)

TABLE 3.2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS Gaseous Sampling Method of Source Frequency Type of Analysis Analysis Waste Gas Decay Tank Each Batch Principal Gamma Emitters p.h.a.

Releases Containment Principal Gamma Emitters p.h.a Purge Each Purge Releases Tritium L.S.

4/M Principal Gamma Emitters p.h.a.

Tritium L.S.

Plant Monthly Particulate Vent Composite Gross Alpha AIC Quarterly Particulate Composite Sr-89 & Sr-90 C.S.

p.h.a.- Gamma Spectrum Pulse Height Analysis using Germanium Detectors. All peaks are identified and quantified.

L.S.- Liquid Scintillation Counting C.S.- Chemical Separation AIC.- Air Ion Chamber 4/M - Four per Month 4

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 & 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION (Continued)

5. Batch Releases IA. Liquid I Unit I Unit 2 Eng. Unit

1. Number of batch releases 34 34

2. Total time period for batch releases 25,217 25,217 minutes 3 Maximum time period for a batch release 1,181 1,181 minutes

4. Average time period for a batch release 742 742 minutes

5. Minimum time period for a batch release 1

1 minutes

6. Average dilution stream flow during the period 992,084 992,084 gpm All liquid releases are summarized in Tables 1B. Gaseous I Unit I Unit 2 Eng. Unit

1. Number of batch releases 17 109

2. Total time period for batch releases 4,397 7,089 minutes

3. Maximum time period for a batch release 1,035 282 minutes

4. Average time period for a batch release 259 65 minutes

5. Minimum time period for a batch release 25 28 minutes All gaseous waste releases are summarized in Tables

6. Unplanned Releases A. Liquid Unit I Unit 2 1Eng. Unit

1. Number of releases 1

0 0

2. Total activity of releases 0.00E+00 0.OOE+00 Curies B. Gaseous Unit 1 Unit 2 Eng. Unit

1. Number of releases 0

1

2. Total activity of releases 0.00E+001 4.75E-03 Curies C. See Attachment - A for Unit 2 Unplanned Gas Release

1. A description of the event and equipment involved.

2. Cause(s) for the unplanned release.

3. Actions taken to prevent a recurrence.

4. Consequences of the unplanned release.

5

EFFLUENT AND WASTE DISPOSAL SUPPLEMENTAL INFORMATION (Continued)

7. Assessment of radiation dose from radioactive effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY assumes the VISITOR onsite for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months per day for 312 days per year at a distance of 1.6 kilometers in the South East Sector. The VISITOR received exposure from each of the two reactors on the Site. Actual Met Data was used to calculate Visitor Dose for Calendar Year 2002.

VISITOR DOSE RESULTS FOR CALENDAR YEAR 2002 were:

NOBLE GAS Gamma Air Dose Beta Air Dose DOSE mrad 4.14E-04 1.11 E-03 Gas Particulate

& Iodine Dose Bone Liver Thyroid Kidney Lung GI-LLI Total Body

8. Offsite Dose Calculation Manual (ODCM) Revision(s):

Two revisions were made to the ODCM during 2002. The first revision was in response to Condition Report 01-0140 and provided additional guidance to loss or alarms of "effluent" channels The second revised Action Statements 35 and 45 to allow continued liquid releases if the liquid monitor is out of service, as long as two independent samples are analyzed and the release calculations and valve line-ups are independently verified.

9. Solid Waste and Irradiated Fuel Shipments:

No irradiated fuel shipments were made from the site.

Common Solid waste from St. Lucie Units 1 and 2 were shipped jointly.

A tabulated summation of these shipments is provided in this report as Table 3.9.

10. Process Control Program (PCP) Revisions:

There were no changes during the reporting interval.

11.

Major Changes to Radioactive Liquid, Gaseous and Solid Waste Treatment Systems:

There were no changes during the reporting interval.

6 Dose mrem 3.22E-04 8.35E-04 1.58E-03 5.39E-04 4.36E-04 3.99E-04 7.66E-04

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.3-1 LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES UNIT QTR#1 QTR#2 A. Fission and Activation Products

1. Total Release - (Not including Tritium, Gases, and Alpha)

2. Average Diluted Concentration During Period Ci uCi/ml 3.99E-02 2.12E-02 7.93E-11 4.17E-1 1 B. Tritium

1. Total Release

2. Average Diluted Concentration During Period Ci 6.OOE+01 6.59E+01 uCi/ml 1.19E-07 1.30E-07 C. Dissolved and Entrained Gases

1. Total Release

2. Average Diluted Concentration During Period Ci uCi/rrl 1.25E-02 2.85E-02 2.48E-1 1 5.62E-11 D. Gross Alpha Radioactivity

1. Total Release Ci 0.OOE+0O O.OOE+00 E. Volume of Waste Released (Prior to Dilution)

F. Volume of Dilution Water Used During Period Liters Liters 6 60E+05 1.34E+06 5.03E+11 5.07E+11 7

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.3-1 LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES (Continued)

UNIT QTR#3 QTR#4 A. Fission and Activation Products

1. Total Release - (Not including Tritium, Gases, and Alpha)

2. Average Diluted Concentration During Period Ci uCi/ml 5.14E-02 8.19E-02 1.01E-10 1.80E-10 B. Tritium

1. Total Release

2. Average Diluted Concentration During Period Ci uCi/ml 1.16E+02 9.76E+01 2.27E-07 2.15E-07 C. Dissolved and Entrained Gases

1. Total Release

2. Average Diluted Concentration During Period D. Gross Alpha Radioactivity

1. Total Release E. Volume of Waste Released (Prior to Dilution)

F. Volume of Dilution Water Used During Period uCi/ml 4.89E-10 3.91E-10 Ci O.OOE+00 O.OOE+00 Liters Liters 1.88E+06 1.88E+06 5.11E+11 4.54E+11 8

Ci 2.50E-01 1.77E-01

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.3-2 LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES UNIT QTR#1 QTR#2 A. Fission and Activation Products

1. Total Release - (Not including Tritium, Gases, and Alpha)

2. Average Diluted Concentration During Period Ci uCi/ml 3.99E-02 2.12E-02 7.93E-11 4.17E-11 B. Tritium

1. Total Release

2. Average Diluted Concentration During Period C. Dissolved and Entrained Gases

1. Total Release

2. Average Diluted Concentration During Period D. Gross Alpha Radioactivity

1. Total Release E. Volume of Waste Released (Prior to Dilution)

F. Volume of Dilution Water Used During Period Ci 6 OOE+01 6.59E+01 uCi/ml Ci uCi/ml 1.19E-07 1.30E-07 1.25E-02 2.85E-02 2.48E-1 I 5.62E-11 Ci O.OOE+00 0.OOE+00 Liters Liters 6.60E+05 1.34E+06 5.03E+11 5.07E+11 9

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.3-2 LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES (Continued)

UNIT QTR#3 QTR#4 A. Fission and Activation Products

1. Total Release - (Not including Tritium, Gases, and Alpha)

2. Average Diluted Concentration During Period Ci uCi/ml 5.14E-02 1.01E-10 8.19E-02 1.80E-10 B. Tritium

1. Total Release

2. Average Diluted Concentration During Period Ci 1.16E+02 9.76E+01 uCi/ml 2.27E-07 2.15E-07 C. Dissolved and Entrained Gases

1. Total Release 2.50E-01 1.77E-01 Ci

2. Average Diluted Concentration During Period uCi/ml 4.89E-10 3.91E-10 D. Gross Alpha Radioactivity

1. Total Release Ci E. Volume of Waste Released (Prior to Dilution)

F. Volume of Dilution Water Used During Period Liters Liters 0.OOE+00 0.OOE+00 1.88E+06 1.88E+06 5.11E+11 4.54E+11 10

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-1 LIQUID EFFLUENTS NUCIJDES RELEASED C-14 Na-24 Cr-51 Mn-54 Fe-55 Mn-S 6 Co-57 Co-58 Fe-59 Co-60 Ni-63 Zn-65 Ni-65 Br-82 Rb-8 S Sr-89 Sr-90 Y-90 Sr-9 1 Sr-92 Y-92 Zr-95 Nb-95 Zr-97 Nb-97 Tc-99m Mo-99 Ru-103 Ag-110 Sn-1 13 Sb-122 Sb-124 Sb-125 Continuous Mode UNIT QTR#1 QTRII2 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Cim Ci Cim Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci O.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOEO00 0.00E 00 0.OOE 00 0.00E 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOEO00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#1 QTR#2 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOEO00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOEO00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE+00 1.26E-04 1.54E-03 1.77E-04 3.65E-03 0.OOE+00 5.OOE-06 4.94E-03 1.27E-04 7.97E-04 0.OOE 00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 2.3 8E-06 2.3 8E-06 0.OOE+00 3.74E-05 0.OOE+00 2.09E-04 3.16E-04 1.46E-05 3.84E-05 0.OOE+00 3.29E-05 1.25E-05 1.85E-04 1.29E-04 1.30E-04 4.32E-03 1.53E-02 1.87E-03 0.OOE+00 6.79E-04 4.03E-04 4.48E-03 0.OOE+00

1. 12E-05 1.71E-03 5.68E-05 2.86E-03 5.3 6E-04 4.83E-05 5.45E-05 0.OOE+00 0.OOE+00 0.OOE+00 1.0 1E-06 1.0 1E-06 0.OOE+00 1.48E-04 0.OOE+00 1.64E-04 3.77E-04 0.OOE+00 6,58E-05 0.OOE+00 0.OOE+00 0.OOE+00 6.18E-04 1.89E-05 6.84E-05 2.41E-04 4.96E-03 11

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-1 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED Te-129 Te-129m 1-130 1-131 Te-132 1-132 1-133 1-134 Cs-134 1-135 Cs-136 Cs-137 Cs-138 Ba-140 La-140 Ce-141 Ce-144 Pr-144 W-187 Np-239 TOTAL FOR PERIOD Ar-41 Kr-85m Kr-85 Kr-87 Kr-88 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Continuous Mode UNIT QTR#1 QTR#2 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.OOE 00 0.OOE 00 0.OOE+00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#I QTR#2 0.OOE 00 0.OOE 00 0.OOE+00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 3.04E-04 2.36E-03 0.OOE+00 5.90E-05 1.33E-05 3.83E-05 2.79E-06 0.OOE+00 2.50E-03 0.OOE+00 5.87E-05 2.48E-03 0.00E+00 0.OOE+00 0.OOE+00 0.00E+00 0.OOE+00 0.OOE+00 1.56E-05 0.00E+00 Ci 0.OOE+00 0.00E+00 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.00E 00 0.00E 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 1.92E-05 2.09E-04 1.05E-05 1.27E-05 7.75E-06 8.05E-05 8.42E-06 0.00E+00 7.20E-04 0.00E+00 0.OOE+00 7.12E-04 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00 1.42E-05 0.OOE+00 0.00E+00 0.OOE+00 3.99E-02 2.12E-02 0.00E 00 0.00E 00 0.OOE 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 3.86E-05 0.00E+00 1.16E-02 0.00E+00 0.OOE+00 5.05E-04 2.37E-05 5.27E-05 2.89E-04 0.OOE+00 2.22E-07 0.OOE+00 2.85E-02 1.16E-05 0.00E+00 0.00E+00 0.00E+00 3.01E-06 1.60E-05 0.OOE+00 12

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-1 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED C-14 Na-24 Cr-51 Mn-54 Fe-55 Mn-56 Co-57 Co-58 Fe-59 Co-60 Ni-63 Zn-65 Ni-65 Br-82 Rb-88 Sr-89 Sr-90 Y-90 Sr-91 Sr-92 Y-92 Zr-95 Nb-95 Zr-97 Nb-97 Tc-99m Mo-99 Ru-103 Ag-110 Sn-i 13 Sb-122 Sb-124 Sb-125 UNIT Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Continuous Mode QTR#3 QTR#4 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 0.00E 00 Batch Mode QTR#3 QTR#4 7.33E-03 5.10E-03 0.00E 00 0.OOE 00 2.97E-04 2.50E-02 4.78E-04 7.62E-04 3.15E-02 1.76E-02 0.00E 00 0.00E 00 2.96E-05 6.62E-05 1.11E-03 1.69E-02 6.43E-05 1.76E-03 4.27E-03 4.57E-03 6.51E-04 1.01E-03 3.25E-05 0.00E 00 0.00E 00 0.OOE 00 0.00E 00 0.00E 00 0.00E 00 0.OOE 00 0.00E 00 8.45E-06 0.00E 00 2.82E-06 0.OOE 00 2.82E-06 0.00E 00 0.00E 00 2.62E-04 1.66E-04 0.00E 00 0.00E 00 8.73E-05 1.63E-03 2.55E-04 2.00E-03 0.00E 00 0.00E 00 1.1OE-05 2.50E-05 0.00E 00 0.00E 00 1.38E-04 1.06E-03 0.00E 00 0.00E 00 5.93E-04 0.00E 00 4.73E-05 5.17E-04 2.34E-05 0.00E 00 5.65E-06 0.00E 00 1.69E-03 2.22E-03 13

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-1 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED Te-129 Te-129m 1-130 1-131 Te-132 1-132 1-133 1-134 Cs-134 1-135 Cs-136 Cs-137 Cs-138 Ba-140 La-140 Ce-141 Ce-144 Pr-144 W-187 Np-239 TOTAL FOR PERIOD Ar-41 Kr-85m Kr-85 Kr-87 Kr-88 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Xe-138 UNIT Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Continuous Mode QTR#3 QTR#4 O.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.OOE 00 0.0GE 00 0.OOE 00 0.OOE 00 0.OOE 00 Ci 0.00E+00 0.OOE+00 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#3 QTR#4 6 96E-04 1.05E-03 2.OOE-04 0.OOE 00 0.OOE 00 0.OOE 00 1.86E-05 6.36E-05 0.OOE 00 4.82E-05 2.34E-06 0.OOE 00 7.65E-06 0.OOE 00 0.00E 00 0.OOE 00 6.91E-04 5.51E-05 0.OOE 00 0.00E 00 4.90E-06 0.OOE 00 8.56E-04 1.66E-04 0.OOE 00 0.OOE 00 1.47E-05 0.OOE 00 1.91E-05 0.00E 00 0.OOE 00 0.OOE 00 0.00E 00 5.55E-05 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 5.14E-02 8.19E-02 0.OOE 00 2.58E-06 1.62E-01 2.87E-05 4.48E-05 6.40E-03 1.84E-04 8.14E-02 5.20E-05 5.98E-06 0.OOE 00 0.OOE 00 0.OOE 00 1.34E-01 0.OOE 00 0.OOE 00 5.38E-03 0.OOE 00 3.75E-02 4.27E-05 0.OOE 00 7.40E-04 14

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-2 LIQUID EFFLUENTS NUCLIDES RELEASED C-14 Na-24 Cr-51 Mn-54 Fe-55 Mn-56 Co-57 Co-58 Fe-59 Co-60 Ni-63 Zn-65 Ni-65 Br-82 Rb-S88 Sr-S 9 Sr-90 Y-90 Sr-91 Sr-92 Y-92 Zr-95 Nb-95 Zr-97 Nb-97 Tc-99m Mo-99 Ru-103 Ag-i 10 Sn-113 Sb-122 Sb-124 Sb-125 UNIT Ci Ci Ci Ci Ci Ci Ci Cir Ci Ci Ci Ci Ci Cim Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Cir Ci Continuous Mode QTR#1 QTR#2 0.00E 00 0.00E 00 0.00E 00 0.OOEO00 0.OOEO 00

.OOEO00 0.OOEO 00

.00E00 0.OOEO 00

.00E00 O.OOEO 00

.OOEO00 0.OOE 00 0.OOE 00 0.OOEO 00

.00E00 0.OOEO 00

.OOEO00 0.OOEO 00

.00E00 0.00E 00 0.OOEO00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.00E 00 0.OOEO00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOEO00 0.OOEO 00

.OOEO00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOEO 00

.OOEO00 0.OOEO 00

.OOE 00 Batch Mode QTR#1 QTR#2 0.OOE+00 1.87E-03 1.26E-04 0.OOE+/-00 1.54E-03 6.79E-04 1.77E-04 4.03E-04 3.65E-03 4.48E-03 0.OOE+00 0.OOE+00 5.OOE-06 1.12E-05 4.94E-03 1.71E-03 1.27E-04 5.68E-05 7.97E-04 2.86E-03 0.OOE 00 5.36E-04 0.OOE+00 4.83E-05 O.OOE+00 5.45E-05 O.OOE+00 0.OOE+00 0.OOE+O0 0.OOE+00 0.OOE+00 0.OOE+00 2.38E-06 1.O1E-06 2.38E-06 1.O1E-06 0.00E+00 0.OOE+00 3.74E-05 1.48E-04 0.OOE+00 0.OOE+00 2.09E-04 1.64E-04 3.16E-04 3.77E-04 1.46E-05 0.OOE+00 3.84E-05 6.58E-05 0.OOE+00 0.OOE+00 3.29E-05 0.OOE+00 1.25E-05 0.OOE+00 1.85E-04 6.18E-04 1.29E-04 1.89E-05 1.30E-04 6.84E-05 4.32E-03 2.41E-04 1.53E-02 4.96E-03 15

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-2 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED Te-129 Te-129m 1-130 1-131 Te-132 1-132 1-133 1-134 Cs-134 1-135 Cs-136 Cs-137 Cs-138 Ba-140 La-140 Ce-141 Ce-144 Pr-144 W-187 Np-239 TOTAL FOR PERIOD Ar-41 Kr-85m Kr-85 Kr-87 Kr-88 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Continuous Mode UNIT QTR#1 QTR#2 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Ci 0.00E+00 0.OOE+00 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.00E 00 0.00E 00 0.OOE 00 0.00E 00 0.00E 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#1 QTR#2 3.04E-04 2.36E-03 0.00E+00 5.90E-05 1.33E-05 3.83E-05 2.79E-06 0.OOE+00 2.50E-03 0.0OE+00 5.87E-05 2.48E-03 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 0.00E+00 1.56E-05 0.00E+00 1.92E-05 2.09E-04 1.05E-05 1.27E-05 7.75E-06 8.05E-05 8.42E-06 0.OOE+00 7.20E-04 0.OOE+00 0.OOE+00 7.12E-04 0.OOE+00 0.00E+00 0.00E+00 0.OOE+00 1.42E-05 0.OOE+00 0.OOE+00 0.OOE+00 3.99E-02 2.12E-02 3.86E-05 0.OOE+00 1.16E-02 0.00E+00 0.00E+00 5.05E-04 2.37E-05 5.27E-05 2.89E-04 0.00E+00 2.22E-07 0.OOE+00 2.85E-02 1.16E-05 0.OOE+00 0.OOE+00 0.00E+00 3.01E-06 1.60E-05 0.00E+00 16

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-2 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED C-14 Na-24 Cr-51 Mn-54 Fe-55 Mn-56 Co-57 Co-58 Fe-59 Co-60 Ni-63 Zn-65 Ni-65 Br-82 Rb-88 Sr-89 Sr-90 Y-90 Sr-91 Sr-92 Y-92 Zr-95 Nb-95 Zr-97 Nb-97 Tc-99m Mo-99 Ru-103 Ag-110 Sn-1 13 Sb-122 Sb-124 Sb-125 UNIT Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Continuous Mode QTR#3 QTR#4 O.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#3 QTR#4 7.33E-03 5.1OE-03 0.OOE 00 0.OOE 00 2.97E-04 2.50E-02 4.78E-04 7.62E-04 3.15E-02 1.76E-02 0.OOE 00 0.OOE 00 2.96E-05 6.62E-05 1.L1E-03 1.69E-02 6.43E-05 1.76E-03 4.27E-03 4.57E-03 6.51E-04 1.01E-03 3.25E-05 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 8.45E-06 0.OOE 00 2.82E-06 0.OOE 00 2.82E-06 0.OOE 00 0.00E 00 2.62E-04 1.66E-04 0.00E 00 0.OOE 00 8.73E-05 1.63E-03 2.55E-04 2.00E-03 0.OOE 00 0.0E00 1.10E-05 2.50E-05 0.00E 00 0.00E 00 1.38E-04 1.06E-03 0.00E 00 0.00E 00 5.93E-04 0.00E 00 4.73E-05 5.17E-04 2.34E-05 0.OOE 00 5.6513-06 0.OOE 00 1.6913-03 2.22E-03 17

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.4-2 LIQUID EFFLUENTS (Continued)

NUCLIDES RELEASED Te-129 Te-129m 1-130 1-131 Te-132 1-132 1-133 1-134 Cs-134 1-135 Cs-136 Cs-137 Cs-138 Ba-140 La-140 Ce-141 Ce-144 Pr-144 W-187 Np-239 TOTAL FOR PERIOD Ar-41 Kr-85m Kr-85 Kr-87 Kr-88 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Xe-138 UNIT Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Continuous Mode QTR#3 QTR#4 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 0 0.00E00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Ci 0.OOE+00 0.OOE+00 Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Batch Mode QTR#3 QTR#4 6.96E-04 1.05E-03 2.OOE-04 0.OOE 00 O.OOE 00 0.OOE 00 1.86E-05 6.36E-05 0.OOE 00 4.82E-05 2.34E-06 0.OOE 00 7.65E-06 0.OOE 00 0.OOE 00 0.OOE 00 6.91E-04 5.51E-05 0.OOE 00 0.OOE 00 4.90E-06 0.OOE 00 8.56E-04 1.66E-04 0.OOE 00 0.00E 00 1.47E-05 0.OOE 00 1.91E-05 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 5.55E-05 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 5 14E-02 8.19E-02 0.OOE 00 2.58E-06 1.62E-01 2.87E-05 4.48E-05 6.40E-03 1.84E-04 8.14E-02 5.20E-05 5.98E-06 0.OOE 00 0.OOE 00 0.OOE 00 1.34E-01 0.OOE 00 0.OOE 00 5.38E-03 0.OOE 00 3.75E-02 4.27E-05 0.OOE 00 7.40E-04 18

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.5-1 LIQUID EFFLUENTS - DOSE SUMMATION AGE GROUP:

ADULT FISH AND SHELLFISH ORGAN Bone Liver Thyroid Kidney Lung GI-LLI Total Body LOCATION:

ANY ADULT DOSE mrem 4.69E-02 2.09E-01 6.42E-04 9.49E-04 2.42E-0 1 1.15E-01 5.61 E-02 19

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.5-2 LIQUID EFFLUENTS - DOSE SUMMATION AGE GROUP:

ADULT FISH AND SHELLFISH ORGAN Bone Liver Thyroid Kidney Lung GI-LLI Total Body LOCATION:

ANY ADULT DOSE mrem 4.69E-02 2.09E-01 6.42E-04 9.49E-04 2.42E-01 1.15 E-0 1 5.6 1E-02 20

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT# 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.6-1 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES UNIT QTR#1 QTR#2 A. Fission and Activation Gases

1. Total Release

2. Average Release Rate For Period Ci 5.1OE-01 5.40E-03 uCi/sec 6.49E-02 6.87E-04 B. lodines

1. Total Iodine-131

2. Average Release Rate For Period Ci 0.OOE 0 0.OOE 00 uCi/sec 0.OOE+00 0.OOE+00 C. Particulates

1. Particulates (Half Life > 8 days)

2. Average Release Rate For Period

3. Gross Alpha Radioactivity Ci 2.29E-05 1.40E-04 uCi/sec 2.92E-06 1.78E-05 Ci 5.58E-07 2.36E-07 D. Tritium

1. Total Release

2. Average Release Rate For Period Ci 3.82E+00 0.OOE+00 uCi/sec 4.86E-01 0.OOE+00 21

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT 9 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.6-1 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES (Continued)

UNIT QTR#3 QTR#4 A. Fission and Activation Gases

1. Total Release

2. Average Release Rate For Period Ci 5.72E+01 1.54E+01 uCi/sec 7.27E+00 1.96E+00 B. lodines

1. Total Iodine-131

2. Average Release Rate For Period Ci 0.OOE 00 6.35E-05 uCi/sec O.OOE+00 0.OOE+00 C. Particulates

1. Particulates (Half Life > 8 days)

2. Average Release Rate For Period

3. Gross Alpha Radioactivity Ci 1.67E-06 2.37E-05 uCi/sec 2.13E-07 3.01E-06 Ci 3.37E-07 5.30E-07 D. Tritium

1. Total Release

2. Average Release Rate For Period Ci 3.57E-02 O.OOE+00 uCi/sec 4.54E-03 0.OOE+00 22

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.6-2 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES A. Fission and Activation Gases

1. Total Release

2. Average Release Rate For Period UNIT QTR#1 QTR#2 Ci 2.66E-01 3.13E-01 uCi/sec 3.38E-02 3.99E-02 B. lodines

1. Total Iodine-131

2. Average Release Rate For Period Ci 0.OOE 00 0.OOE 00 uCi/sec 0.OOE+00 0.OOE+00 C. Particulates

1. Particulates (Half Life > 8 days)

2. Average Release Rate For Period

3. Gross Alpha Radioactivity Ci 1.87E-05 1.91E-05 uCi/sec 2.37E-06 2.43E-06 Ci 5.04E-07 1.74E-07 D. Tritium

1. Total Release

2. Average Release Rate For Period Ci 1.38E+00 2.71E+00 uCi/sec 1.76E-01 3.44E-01 23

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.6-2 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES (Continued)

UNIT QTR#3 QTR#4 A. Fission and Activation Gases

1. Total Release Ci

2. Average Release Rate For Period 4.13E-01 2.82E-01 uCi/sec 5.26E-02 3.59E-02 B. lodines

1. Total Iodine-131

2. Average Release Rate For Period Ci 0.OOE 00 0.OOE 00 uCi/sec 0.00E+00 0.OOE+00 C. Particulates

1. Particulates (Half Life > 8 days)

2. Average Release Rate For Period

3. Gross Alpha Radioactivity Ci 1.67E-06 1.92E-06 uCi/sec 2.13E-07 2.44E-07 Ci 6.82E-07 5.45E-07 D. Tritium

1. Total Release

2. Average Release Rate For Period Ci 1.99E-01 6.04E-02 uCi/sec 2.53E-02 7.69E-03 24

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-1 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES Nuclides Continuous Mode Batch Mode Released Unit QTR#1 QTR#2 QTR#1 QTR#2

1. Fission Gases Ar-41 Ci 0.00E-I00 0.OOE 00 0.OOE 00 0.OOE+00 Kr-85m Ci 0.OOE+0O 0.OOE 00 0.OOE 00 0.OOE 00 Kr-85 Ci 0.OOE+00 0.OOE 00 4.91E-01 0.00E 00 Kr-87 Ci 0.OOE+00 0.OOE 00 0.00E 00 0.00E 00 Kr-88 Ci 0.OOE+00 0.OOE 00 000OE 00 0.OOE 00 Kr-89 Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.00E 00 Kr-90 Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-I 27 Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-i 31 m Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-I 33m Ci 0.OOE+00 0.OOE 00 0.00E 00 0.OOE+00 Xe-I 33 Ci 0.OOE+00 0.OOE 00 1.94E-02 5.40E-03 Xe-135m Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE+00 Xe-I 35 Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE+0O Xe-I 37 Ci 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-i 38 Ci 0.OOE+00 0.00E 00 0.OOE 00 0.OOE 00 Total for Period Ci O.OOE+00 0.OOE+00 5.10E-01 5.40E-03

2. lodiries 1-13 1 Ci 0.OOE 00 0.OOE 00 1-132 Ci 0.OOE 00 0.OOE 00 1-133 Ci 0.OOE+00 0.OOE 00 1-134 Ci 0.OOE 00 0.OOE 00 1-135 Ci 0,OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00

3. Particulates (>8 Days)

Cr-5I Ci 0.OOE 00 0.OOE 00 Mn-54 Ci 0.OOE 00 0.OOE 00 Fe-55 Ci 0.OOE 00 0.OOE 00 Co-57 Ci 0.OOE 00 0.OOE 00 Co-58 Ci 0.OOE 00 3.91E-06 Fe-59 Ci 0.OOE 00 0.OOE 00 Co-60 Ci 0.OOE 00 0.OOE 00 Zn-65 Ci 0.OOE 00 0.OOE 00 Zr-95 Ci 0.OOE 00 0.OOE 00 Nb-95 Ci 0.OOE 00 0.OOE 00 25

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT# 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3 7-1 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Continuous Mode Nuclides Unit QTR#1 QTR#2 Released

3. Particulates (> 8 Days) (continued)

Sr-89 Ci I 83E-05 3 88E-06 Sr-90 Ci 1.99E-06 1.86E-07 Y-90 Ci 1.99E-06 1.86E-07 Ru-103 Ci 0 00E 00 0 00E 00 Ag-1 10 Ci O.OOE 00 0 O0E 00 Sn-1 13 Ci 0.OOE 00 0 OE 00 Sb-124 Ci 0 O0E 00 0.00E 00 Sb-125 Ci 0 00E 00 0.OOE 00 Te-129m Ci 0 OOE 00 0.OOE 00 Cs-134 C1 0 O0E 00 6 77E-05 Cs-136 Ci 0 OOE 00 0 OOE 00 Cs-137 Ci 6 49E-07 6 39E-05 Ba-140 Ca 0 OOE 00 0.OOE 00 Ce-141 Ci 0 OOE 00 0.OOE 00 Ce-144 Ci 0 OOE 00 0.OOE 00 Total for Period Ci 2 29E-05 1.40E-04

4. Particulates (< 8 Days)

Mn-56 Ci 0.OOE 00 0 OOE 00 Ni-65 Ci 0.OOE 00 0 OOE 00 Br-82 Ci 0.OOE 00 0 O0E 00 Rb-88 Ci 0.OOE 00 0 O0E 00 Rb-89 Ci OOE 00 0

E00 Sr-91 Ci 0 00E 00 0 00E 00 Sr-92 Ci 0 00E 00 0 00E 00 Y-92 Ci 0 00E 00 0 OQE 00 Zr-97 Ci 0 OOE 00 0 OOE 00 Nb-97 Ca 0 OOE 00 0 OOE 00 Tc-99m Ca 0 OOE 00 0.OOE 00 Mo-99 Ci 0 O0E 00 0.OOE 00 Sb-122 Ci 0 OOE 00 0.OOE 00 Te-129 Ci 0 OOE 00 0.OOE 00 Te-1 32 Ci 0 OOE 00 0.OOE 00 Cs-138 Ci 0 OOE 00 0 OOE 00 La-140 Ci 0 OOE 00 0 OOE 00 Pr-144 Ci 0 OOE 00 0 OOE 00 W-187 Ci 0.OOE 00 0 OOE 00 Np-239 Ci 0.OOE 00 0 OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00 26

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT# 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-1 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Nuclides Continuous Mode Batch Mode Released Unit QTR#3 QTR#4 QTR#3 QTR#4

1. Fission Gases Ar-41 Ci 0.OOE 00 0.OOE 00 5.2 1E-02 0.OOE 00 Kr-85m Ci 0.OOE 00 0.OOE 00 1.66E-03 0.OOE 00 Kr-85 Ci 0.OOE 00 0.OOE 00 6.95E+00 5.07E+00 Kr-87 Ci 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 Kr-88 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Kr-89 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.0E00 Kr-90 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-127 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-131 m Ci 0.OOE 0 0.OOE 00 3.15E-02 1.76E-01 Xe-1 33m Ci 0.OOE 00 0.OOE 00 5.22E-02 0.OOE 00 Xe-133 Ci 4.21E+01 8.24E+00 4.21E+00 1.89E+00 Xe-135m Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-1 35 Ci 3.69E+00 0.OOE 00 3.75E-02 0.OOE 00 Xe-1 37 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-138 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Total for Period Ci 4.58E+01 8.24E+00 1.13E+01 7.14E+00

2. lodines 1-131 Ci 0.OOE 00 6.35E-05 1-132 Ci 0.OOE 00 0.OOE 00 1-133 Ci 1.37E-04 0.00E 00 1-134 Ci 0.OOE 00 0.OOE 00 1-135 Ci 0.00E 00 0.00E 00 Total for Period Ci 1.37E-04 6.35E-05

3. Particulates (> 8 Days)

Cr-51 Ci 0.OOE 00 6.85E-06 Mn-54 Ci 0.00E 00 0.OOE 00 Fe-55 Ci 0.OOE 00 0.OOE 00 Co-57 Ci 0.00E 00 0.OOE 00 Co-58 Ci 0.OOE 00 1.04E-05 Fe-59 Ci 0.OOE 00 0.OOE 00 Co-60 Ci 0.OOE 00 1.99E-06 Zn-65 Ci 0.OOE 00 0.OOE 00 Zr-95 Ci 0.OOE 00 0.OOE 00 Nb-95 Ci 0.OOE 00 O.OOE 00 Sr-89 Ci 1.62E-06 3.75E-06 Sr-90 Ci 2.65E-08 0.OOE 00 27

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-1 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Continuous Mode Nuclides Unit QTR#3 QTR#4 Released

3. Particulates (> 8 Days) (continued)

Y-90 Ci 2.65E-08 0.OOE 00 Ru-1 03 Ci 0.OOE 00 O.OOE 00 Ag-110 Ci O.OOE 00 0.OOE 00 Sn-1 13 Ci 0.OOE 00 0.OOE 00 Sb-124 Ci 0.00E 00 0.OOE 00 Sb-125 Ci O.OOE 00 0.OOE 00 Te-129m Ci 0.OOE 00 0.OOE 00 Cs-1 34 Ci 0.OOE 00 0.OOE 00 Cs-1 36 Ci 0.OOE 00 0.OOE 00 Cs-1 37 Ci 0.OOE 00 6.72E-07 Ba-1 40 Ci 0.OOE 00 0.00E 00 Ce-141 Ci 0.OOE 00 0.OOE 00 Ce-144 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 1.67E-06 2.37E-05

4. Particulates (< 8 Days)

Mn-56 Ci O.OOE 00 0.OOE 00 Ni-65 Ci 0.OOE 00 0.OOE 00 Br-82 Ci 0.OOE 00 0.OOE 00 Rb-88 Ci 0.OOE 00 0.OOE 00 Rb-89 Ci 0.OOE 00 0.OOE 00 Sr-91 Ci 0.OOE 00 0.OOE 00 Sr-92 Ci 0.OOE 00 0.OOE 00 Y-92 Ci 0.OOE 00 0.OOE 00 Zr-97 Ci 0.OOE 00 0.OOE 00 Nb-97 Ci 0.OOE 00 0.OOE 00 Tc-99m Ci 0.OOE 00 0.OOE 00 Mo-99 Ci 0.OOE 00 0.OOE 00 Sb-1 22 Ci 0.OOE 00 0.OOE 00 Te-129 Ci 0.OOE 00 0.OOE 00 Te-132 Ci 0.OOE 00 0.OOE 00 Cs-1 38 Ci 0.OOE 00 0.OOE 00 La-140 Ci 0.OOE 00 0.OOE 00 Pr-144 Ci 0.OOE 00 0.OOE 00 W-187 Ci 0.OOE 00 0.OOE 00 Np-239 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00 28

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-2 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES Nuclides Continuous Mode Batch Mode Released Unit QTR#1 QTR#2 QTR#1 QTR#2

1. Fission Gases Ar-41 Ci 0.OOE 00 0.OOE 00 2.19E-01 2.35E-01 Kr-85m Ci 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 Kr-85 Ci O.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 Kr-87 Ci O.00E 00 0.OOE 00 0.OOE 00 O.OOE 00 Kr-88 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Kr-89 Ci 0.00E 00 0.OOE 00 0.00E 00 0.OOE 00 Kr-90 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-127 Ci 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-131m Ci 0.OOE 00 0.OOE 00 0.OOE 00 6.02E-04 Xe-133m Ci 0.OOE 00 0.OOE 00 1.58E-03 6.64E-04 Xe-1 33 Ci 0.OOE 00 0.OOE 00 4.43E-02 7.70E-02 Xe-1 35m Ci 0.00E 00 0.OOE 00 0.OOE 00 2.53E-04 Xe-135 Ci 0.00E 00 0.OOE 00 1.08E-03 4.59E-05 Xe-1 37 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Xe-1 38 Ci 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00 2.66E-01 3.13E-01

2. lodines 1-131 Ci 0.OOE 00 0.OOE 00 1-132 Ci 0.OOE 00 0.OOE 00 1-133 Ci 0.OOE 00 0.OOE 00 1-134 Ci 0.OOE 00 0.OOE 00 1-135 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00

3. Particulates (> 8 Days)

Cr-51 Ci 0.OOE 00 0.OOE 00 Mn-54 Ci 0.00E 00 0.OOE 00 Fe-55 Ci 0.OOE 00 0.OOE 00 Co-57 Ci 0.OOE 00 0.OOE 00 Co-58 Ci 0.OOE 00 0.OOE 00 Fe-59 Ci 0.OOE 00 0.OOE 00 Co-60 Ci 0.OOE 00 0.OOE 00 Zn-65 Ci 0.OOE 00 0.OOE 00 Zr-95 Ci 0.OOE 00 0.OOE 00 Nb-95 Ci 0.OOE 00 0.OOE 00 29

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-2 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Continuous Mode Nuclides Unit QTR#1 QTR#2 Released

3. Particulates (> 8 Days) (continued)

Sr-89 Ci 1.45E-05 1.75E-05 Sr-90 Ci 1.37E-06 5.OOE-07 Y-90 Ci 1.37E-06 5.OOE-07 Ru-1 03 Ci 0.OOE 00 0.OOE 00 Ag-1 10 Ci 0.OOE 00 0.OOE 00 Sn-1 13 Ci 0.OOE 00 0.OOE 00 Sb-1 24 Ci 0.OOE 00 0.OOE 00 Sb-125 Ci 0.OOE 00 0.OOE 00 Te-129m Ci 0.OOE 00 0.OOE 00 Cs-1 34 Ci O.OOE 00 0.00E 00 Cs-1 36 Ci O.OOE 00 0.OOE 00 Cs-137 Ci 1.43E-06 6.36E-07 Ba-1 40 Ci 0.00E 00 0.OOE 00 Ce-141 Ci 0.OOE 00 0.OOE 00 Ce-144 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 1.87E-05 1.91 E-05

4. Particulates (< 8 Days)

Mn-56 Ci 0.OOE 00 0.OOE 00 Ni-65 Ci 0.OOE 00 0.OOE 00 Br-82 Ci 0.OOE 00 0.OOE 00 Rb-88 Ci 0.OOE 00 0.OOE 00 Rb-89 Ci 0.OOE 00 O.OOE 00 Sr-91 Ci 0.OOE 00 0.OOE 00 Sr-92 Ci 0.OOE 00 0.OOE 00 Y-92 Ci 0.OOE 00 0.OOE 00 Zr-97 Ci 0.OOE 00 0.OOE 00 Nb-97 Ci 0.OOE 00 0.OOE 00 Tc-99m Ci 0.OOE 00 0.OOE 00 Mo-99 Ci 0.OOE 00 0.OOE 00 Sb-122 Ci 0.OOE 00 0.OOE 00 Te-129 Ci 0.OOE 00 0.OOE 00 Te-132 Ci 0.OOE 00 0.OOE 00 Cs-1 38 Ci 0.OOE 00 0.OOE 00 La-1 40 Ci 0.OOE 00 0.OOE 00 Pr-144 Ci 0.OOE 00 0.OOE 00 W-187 Ci 0.OOE 00 0.OOE 00 Np-239 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00 30

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY I, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-2 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Nuclides Released

1. Fission Gases Ar-41 Kr-85m Kr-85 Kr-87 Kr-88 Kr-89 Kr-90 Xe-127 Xe-1 31m Xe-133m Xe-1 33 Xe-1 35m Xe-1 35 Xe-1 37 Xe-1 38 Total for Period

2. lodines 1-131 1-132 1-133 1-134 1-135 Total for Period

3. Particulates (>

Cr-51 Mn-54 Fe-55 Co-57 Co-58 Fe-59 Co-60 Zn-65 Zr-95 Nb-95 Unit Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci 8 Days)

Ci Ci Ci Ci Ci Ci Ci Ci Ci Ci Continuous Mode QTR#3 QTR#4 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.00E 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE 00 0.00E 00 O.OOE 00 0.OOE 00 Batch Mode QTR#3 QTR#4 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE+00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 O.OOE+00 O.OOE 00 O.OOE 00 O.OOE 00 O.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 2.51E-01 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 1.62E-01 0.OOE 00 9.93E-04 0.OOE 00 0.OOE 00 4.13E-01 2.35E-01 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 0.OOE 00 4.62E-02 0.OOE 00 1.08E-03 0.OOE 00 0.OOE 00 2.82E-01 31

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.7-2 GASEOUS EFFLUENTS - GROUND LEVEL RELEASES (Continued)

Continuous Mode Nuclides Unit QTR#3 QTR#4 Released

3. Particulates (> 8 Days) (continued)

Sr-89 Ci 1.62E-06 3.98E-07 Sr-90 Ci 2.65E-08 0.OOE 00 Y-90 Ci 2.65E-08 0.00E 00 Ru-1 03 Ci 0.OOE 00 0.OOE 00 Ag-110 Ci 0.00E 00 0.OOE 00 Sn-113 Ci 0.00E 00 0.OOE 00 Sb-124 Ci 0.OOE 00 O.OOE 00 Sb-125 Ci 0.OOE 00 0.OOE 00 Te-129m Ci 0.OOE 00 0.OOE 00 Cs-1 34 Ci 0.00E 00 0.OOE 00 Cs-1 36 Ci 0.OOE 00 0.OOE 00 Cs-1 37 Ci 0.OOE 00 1.52E-06 Ba-140 Ci 0.OOE 00 0.OOE 00 Ce-141 Ci O.OOE 00 0.OOE 00 Ce-1 44 Ci 0.00E 00 0.OOE 00 Total for Period Ci 1.67E-06 1.92E-06

4. Particulates (< 8 Days)

Mn-56 Ci 0.O0E 00 O.OOE 00 Ni-65 Ci 0.OOE 00 0.OOE 00 Br-82 Ci 0.00E 00 O.OOE 00 Rb-88 Ci 0.00E 00 0.OOE 00 Rb-89 Ci 0.00E 00 O.OOE 00 Sr-91 Ci O.00E 00 O.OOE 00 Sr-92 Ci 0.00E 00 0.OOE 00 Y-92 Ci 0.OOE 00 0.OOE 00 Zr-97 Ci 0.OOE 00 0.OOE 00 Nb-97 Ci 0.OOE 00 0.00E 00 Tc-99m Ci 0.OOE 00 0.OOE 00 Mo-99 Ci 0.OOE 00 0.OOE 00 Sb-122 Ci 0.OOE 00 0.OOE 00 Te-129 Ci 0.OOE 00 0.OOE 00 Te-132 Ci 0.OOE 00 0.OOE 00 Cs-1 38 Ci 0.OOE 00 0.OOE 00 La-140 Ci 0.OOE 00 0.OOE 00 Pr-144 Ci 0.OOE 00 0.OOE 00 W-187 Ci 0.OOE 00 0.OOE 00 Np-239 Ci 0.OOE 00 0.OOE 00 Total for Period Ci 0.OOE+00 0.OOE+00 32

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 1 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.8-1 GASEOUS EFFLUENTS - DOSE SUMMATION AGE GROUP:

ADULT Bone Liver Thyroid Kidney Dose Pathway mrem mrem mrem mrem Inhalation 6.28E-06 9.25E-05 1.16E-04 9.12E-05 Grass-Goat-Milk 2.55E-04 5.82E-04 1.11E-03 3.09E-04 Ground Plane O.OOE+00 O.OOE+00 O.OOE+00 O.OOE+00 Garden 3.22E-05 5.11E-05 2.44E-04 4.05E-05 Meat 1.211E-05 5.1OE-05 6.27E-05 4.03E-05 Total Dose 3.06E-04 7.76E-04 1.53E-03 4.81 E-04 Lung GI-LLI Total Body Dose Pathway mrem mrem mrem Inhalation 9.24E-05 9.06E-05 9.23E-05 Grass-Goat-Milk 2.13E-04 1.78E-04 4.82E-04 Ground Plane O.OOE+00 O.OOE+00 1.04E-04 Garden 3.57E-05 3.61 E-05 5.08E-05 Meat 3.66E-05 3.62E-05 4.76E-05 Total Dose 3.78E-04 3.41 E-04 7.77E-04

-Sector : SE Range:

1.5 Noble Gases mrad Gamma Air Dose 7.09E-04 Beta Air Dose 2.41 E-03 Sector: SE Range: 1.5 miles miles 33

FLORIDA POWER & LIGHT COMPANY ST. LUCIE UNIT # 2 ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31, 2002 TABLE 3.8-2 GASEOUS EFFLUENTS - DOSE SUMMATION AGE GROUP:

ADULT Bone Liver Thyroid Kidney Dose Pathway mrem mrem mrem mrem Inhalation 5.86E-06 1.92E-04 1.92E-04 1.92E-04 Grass-Goat-Milk 4.54E-06 2.38E-05 2.19E-05 2.26E-05 Ground Plane 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 Garden 8.58E-06 1.63E-05 1.61E-05 1.61E-05 Meat 4.01 E-07 5.36E-06 5.29E-06 5.32E-06 Total Dose 1.94E-05 2.37E-04 2.35E-04 2.36E-04 Lung GI-LLI Total Body Dose Pathway mrem mrem mrem Inhalation 1.93E-04 1.92E-04 1.92E-04 Grass-Goat-Milk 2.22E-05 2.21 E-05 2.38E-05 Ground Plane 0.OOE+00 0.OOE+00 9.61 E-06 Garden 1.61 E-05 1.66E-05 1.78E-05 Meat 5.30E-06 5.34E-06 5.41 E-06 Total Dose 2.37E-04 2.36E-04 2.49E-04 Sector: SE Range:

1.5 miles Noble Gases mrad Gamma Air Dose 2.29E-04 Beta Air Dose 8.91 E-05 Sector: SE Range: 1.5 miles 34

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT ANNUAL REPORT JANUARY 1, 2002 THROUGH DECEMBER 31,2002 UNITS 1 AND 2, TABLE 3.9 A.

Solid Waste Shipped Off-Site for Burial or Disposal

1. Type of Waste

a. Spent Resin, Process Filters

b. Dry Compressible Waste (Note 5)

c. Irradiated Components

d. Other Unit 12 Mo. Period M3 1.89E+ 1 Cl 5.03E+2 M3 1.67E+ 1 Ci 7.50E+0 M3 0

Cl 0

M3 0

Ci 0

2.Estimate of Major Nuclide Composition (By Waste Type)

Title:

OFFSITE DOSE CALCULATION MANUAL (ODCM)

Responsible Department: CHEMISTRY Revision Summary Revision 25 - Revised Action Statements 35 and 45 such that releases via the pathway may continue as long as prior to release, two independent samples of tank's contents are analyzed, and two technically qualified members of the facility staff independently verify the release rate calculations and discharge valve lineup. (Al Locke, 05/14/02)

Revision 24 - Made changes per CR 01-0140 and periodic review. (R. E. Cox, 02/14/02)

Revision 23A - Changed cover page description for revision 23 to read "goat (milk)" instead of "gaot (milk)". (Bonnie Gilmour, 05/01/01)

Revision 23 - Specified pressure loss criteria, added actions 37 for the S/G Blowdown Radioactivity Monitor to meet the expectation of the new EPRI industry standard, ensured grab samples will be taken, included Carbon-14 & Nickel-63 in liquid sampling/analysis, changed gaseous continuous vent release pathway, standardized St. Lucie with Turkey Points ODCM wording, included goat (milk) animal to the Radiological Environmental Monitoring Program, and included new dose conversion factors. (R. E. Cox, 01/19/01)

Revision 22 - Unit 2 Tech Spec Amendment 105 adopting the same Dose Equivalent Iodine-131 definition as Unit 1. (R.E. Cox, 04/20/00)

Revision FRG Review Date 0

04/22/82 Revision FRG Review Date 25 05/14/02 Approved By C. M. Wethy Piant General Manager Approved By D. Rose Plant General Manager N/A Approval Date 04/27/82 Approval Date 05/14/02 S

OPS DATE DOCT PROCEDURE DOCN C-200 SYS COMP COMPLETED ITM 25 Designated Approver N/A Designated Approver (minor correction)

Page 2 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

1.0 TITLE

OFFSITE DOSE CALCULATION MANUAL (ODCM) 2.0 REVIEW AND APPROVAL:

See cover page

Page 3 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INDEX PAGE INTRO DUCTIO N 8

CONTROLS SECTION DEFINITIONS FOR CONTROLS SECTION..........................

10 1.1 A CT IO N...............................................

10 1.4 CHANNEL CALIBRATION..................................

10 1.5 CHANNEL CHECK.......................................

10 1.6 CHANNEL FUNCTIONAL TEST..............................

10 1.10 DOSE EQUIVALENT 1-131 11 1.13 FREQUENCY NOTATION..................................

11 1.17 MEMBER(S) OF THE PUBLIC...............................

11 1.18 OFFSITE DOSE CALCULATION MANUAL......................

11 1.19 OPERABLE - OPERABILITY................................

12 1.20 OPERATIONAL MODE - MODE..............................

12 1.24 PURGE -PURGING 12 1.25 RATED THERMAL POWER.................................

12 1.27 REPORTABLE EVENT....................................

12 1.30 SITE BOUNDARY........................................

13 1.31 SOURCE CHECK........................................

13 1.33 THERMAL POW ER.......................................

13 1.34 UNPLANNED RELEASE...................................

13 1.35 UNRESTRICTED AREA....................................

14 1.39 VENTILATION EXHAUST TREATMENT SYSTEM 14 1.40 VENTING..............................................

15 1.41 WASTE GAS HOLDUP SYSTEM.............................

15 3/4 CONTROLS AND SURVEILLANCE REQUIREMENTS 17 3/4.0 APPLICABILITY.........................................

17 INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION 18 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION.. 24 3/4.11 RADIOACTIVE EFFLUENTS 3/4.11.1 LIQUID EFFLUENTS CONCENTRATION 36 D O S E.............................................

40 LIQUID RADWASTE TREATMENT........................

41

Page 4 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INDEX CONTROLS SECTION PAGE CONTROL AND SURVEILLANCE STATEMENTS FOR CONTROL SECTION 3/4.11 RADIOACTIVE EFFLUENTS (Continued) 3/4.11.2 GASEOUS EFFLUENTS DOSE RATE........................................

42 DOSE - NOBLE GAS..................................

46 DOSE - IODINE-131, IODINE-133, TRITIUMS AND RADIONUCLIDES IN PARTICULATE FORM...............

47 GASEOUS RADWASTE TREATMENT.....................

48 3/4.11.3 (NOT USED) 3/4.11.4 TOTAL DOSE.......................................

50 3/4.11.5 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS (ADMINISTRATIVE CONTROL)..........................

52 3/4.11.6 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT TO THE COMMISSION (ADMINISTRATIVE CONTROL) 53 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM..............................

56 3/4.12.2 LAND USE CENSUS..................................

65 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM.............

67 3/4.12.4 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (ADMINISTRATIVE CONTROL)...................

68 BASES for CONTROLS SECTION 3/4.11 RADIOACTIVE EFFLUENTS 3.3.3.9 INSTRUMENTATION..................................

70 3/4.11.1 LIQUID EFFLUENTS..................................

71 3/4.11.2 GASEOUS EFFLUENTS 73 3/4.11.3 (NOT USED) 3/4.11.4 TOTAL DOSE.......................................

76 3/4.12 RADIOACTIVE ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM..............................

78 3/4.12.2 LAND USE CENSUS..................................

78 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM.............

79

Page 5 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INDEX CONTROLS SECTION PAGE LIST OF FIGURES for CONTROLS SECTION FIGURE 1-1 SITE AREA MAP & ENVIRONMENTAL SAMPLE LOCATIONS 225 1-2 ENVIRONMENTAL SAMPLE LOCATIONS (10 MILES) 226 LIST OF TABLES for CONTROLS SECTION TABLE 1-1 FREQUENCY NOTATION 16 3.3-12 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION....................................

19 3.3-13 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION....................................

25 3.3-14 RADIOACTIVE EFFLUENT MONITOR SETPOINT BASIS.........

29 3.12-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM.....

58 3.12-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES...........................

61 4.3-8 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS 22 4.3-9 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.........

33 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM...............................

37 4.11-2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM...............................

43 4.12-1 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS LOWER LIMIT OF DETECTION (LLD)...............

62

Page 6 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INDEX METHODOLOGY SECTION PAGE Glossary for Methodology Section.................................

81 1.0 LIQUID RELEASES METHODOLOGY.........................

84 1.1 Radioactive Liquid Effluent Model Assumptions..............

85 1.2

Determining the Fraction (F) of 10 CFR Part 20 Effluent Concentration Limits (ECL) for a Liquid Release Source........

86 1.3 Determining Setpoints for Radioactive Liquid Effluent Monitors......................................

89 1.4 Determining the Dose for Radioactive Liquid Releases.........

93 1.5 Projecting Dose for Radioactive Liquid Effluents..............

97 2.0 Radioactive Releases of Gaseous Effluents.....................

98 2.1 Gaseous Effluent Model Assumptions.....................

99 2.2 Determining the Total Body and Skin Dose Rates for Noble Gas Releases and Establishing Setpoints for Effluent Monitors..................................

100 2.3 Determining the Radioiodine and Particulate Dose Rate to Any Organ From Gaseous Releases...................

114 2.3.1 Inhalation...................................

116 2.3.2 Ground Plane................................

118 2.3.3 M ilk.......................................

119 2.3.4 Tritium.....................................

121 2.3.5 Total Dose Rate by Release Source................

123 2.4 Determining the Gamma Air Dose for Radioactive Noble Gas Releases 123 2.5 Determining the Beta Air Dose for Radioactive Noble Gas Releases 126 2.6 Determining the Radioiodine and Particulate Dose to Any Age Group's Organ From Cumulative Releases........

128 DISCUSSION 2.6.1 Inhalation...................................

130 2.6.2 Ground Plane................................

131 2.6.3 M ilk.......................................

132

Page 7 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INDEX METHODOLOGY SECTION PAGE 2.6 (continued) 2.6.4 M eat.......................................

2.6.5 Vegetation 2.6.6 Tritium (All pathways)..........................

2.6.7 Total Organ Dose.............................

2.7 Projecting Dose for Radioactive Gaseous Effluents..........

3.0 40 CFR 190 Dose Evaluation...............................

4.0 Annual Report Format..........................

141 Appendix A - ECL, Dose Factor and Historical Meteorological Tables....................................

Appendix B - Current R.E.M. Sample Point Locations..................

Appendix C - Description of Meteorological Dispersion Formulas Utilized for Historical Data and Methodology for Determining Actual MET Data..............................

Appendix D - Description of the Interlaboratory Comparison Program.......

133 135 137 138 139 140 156 221 227 229

Page 8 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INTRODUCTION The ODCM consists of the Controls Section followed by the Methodology Section.

The Controls Section provides the Control Statements, Limits, ACTION Statements, Surveillance Requirements and BASES for ensuring that Radioactive Liquid and Gaseous Effluents released to UNRESTRICTED AREAS and/or the SITE BOUNDARY will be maintained within the requirements of 10 CFR Part 20, 40 CFR Part 190, 10 CFR 50.36.a and 10 CFR Part 50 Appendix-I radioactive release criteria. All Control Statements and most Administrative Control Statements in the ODCM are directly tied to and reference the Plant Technical Specification (TS) Administrative Section. The Administrative Control for Major Changes to Radioactive Liquid, Gaseous and Solid Treatment Systems is as per the guidance of NUREG-1301, April 1991, Supplement No. 1 to NRC Generic Letter 89-01. The numbering sequences of Control Statements also follow the guidance of NUREG-1301 as applicable, to minimize differences.

Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations ) - Effluent Streams and the Environment, 6.3.1 and 6.3.2, provide the background for the need to maintain Quality Assurance programs for effluent releases and radiological environmental monitoring.

The Methodology Section uses the models suggested by NUREG-0133, November, 1978 and Regulatory Guide 1.109 to provide calculation methods and parameters for determining results in compliance with the Controls Section of the ODCM. Simplifying assumptions have been applied where applicable to provide a more workable document for implementing the Control requirements. Alternate calculation methods may be used from those presented as long as the overall methodology does not change or as long as most up-to-date revisions of the Regulatory Guide 1.109 dose conversion factors and environmental transfer factors are substituted for those currently included and used in this document.

RECORDS AND NOTIFICATIONS All records of reviews performed for changes to the ODCM shall be maintained in accordance with QI 17-PSL-1.

All FRG approved changes to the ODCM, with required documentation of the changes per TS 6.14, shall be submitted to the NRC in the Annual Effluent Release Report. Procedures that directly implement, administer or supplement the requirements of the ODCM Controls and Surveillances are:

COP-01.05, Processing Aerated Liquid Waste COP-01.06, Processing Gaseous Wastes COP-05.02, Conduct of Chemistry - Met Tower Data Processing COP-05.04, Chemistry Department Surveillances and Parameters COP-07.05, Process Monitor Setpoints The Radiological Environmental Monitoring Program is performed by the State of Florida as per FPL Juno Nuclear Plant Services Corporate Environmental Procedure Number NBS-NPS-HP-WP-002.

Page 9 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

CONTROLS AND SURVEILLANCE REQUIREMENTS St. Lucie Plant ODCM Controls

Page 10 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM The defined terms of this section appear in capitalized type and are applicable throughout these Controls.

ACTION 1.1 ACTION shall be that part of a Control that prescribes remedial measures required under designated conditions.

CHANNEL CALIBRATION 1.4 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.

CHANNEL CHECK 1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 1.6 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY of alarm, interlock and/or trip functions. The CHANNEL FUNCTIONAL TEST shall include adjustments, as necessary, of the alarm, interlock and/or Trip Setpoints such that the setpoints are within the required range and accuracy.

St. Lucie Plant ODCM Controls

Page 11 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM DOSE EQUIVALENT 1-131 1.10 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microCurie/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134 and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be the thyroid dose conversion factors listed in ICRP-30, Supplement to Part 1, Pages 192-212, Tables entitled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity (Sv/Bq)." Reference PLA #98-007, PMAI 99-06-170, PLA #97-005, PMAI 00-01-036.

FREQUENCY NOTATION 1.13 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

MEMBER (S) OF THE PUBLIC 1.17 MEMBER OF THE PUBLIC means an individual in a controlled or unrestricted area.

However, an individual is not a member of the public during any period in which the individual receives an occupational dose.

OFFSITE DOSE CALCULATION MANUAL 1.18 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by TS section 6.8.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by TS 6.9.1.7 and 6.9.1.8.

St. Lucie Plant ODCM Controls

Page 12 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM OPERABLE - OPERABILITY 1.19 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

OPERATIONAL MODE - MODE 1.20 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.2 of the St. Lucie Plant TS.

PURGE - PURGING 1.24 PURGE or PURGING shall be any controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

RATED THERMAL POWER 1.25 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 2700 MWt.

REPORTABLE EVENT 1.27 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 of 10 CFR Part 50.

St. Lucie Plant ODCM Controls

Page 13 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM SITE BOUNDARY 1.30 SITE BOUNDARY means that line beyond which the land or property is not owned, leased or otherwise controlled by the licensee.

SOURCE CHECK 1.31 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

THERMAL POWER 1.33 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

UNPLANNED RELEASE 1.34 UNPLANNED RELEASE is the unintended discharge of a volume of liquid or airborne radioactivity to the environment. The following guidance is presented to classify differences between unplanned releases and other releases that are not considered as an UNPLANNED RELEASE:

Is an UNPLANNED RELEASE if:

1.

The wrong waste gas decay tank or liquid radwaste release tank is released off site.

2.

Failure of process system to automatically divert a process stream to a radioactive treatment system upon radioactivity being present in the process at the detection level or at a certain level of activity, and the result is a discharge off site occurs.

3.

Large losses from unexpected pipe or valve leaks where the resulting loss of radioactive material to off site such that a 10 CFR Part 50.72 or 10 CFR Part 50.73 report is required.

St. Lucie Plant ODCM Controls

Page 14 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM UNPLANNED RELEASE (continued) 1.34 (continued)

4.

For Gas Decay Tank, if a Gas Decay Tank loses greater than 2 psig per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for 9 consecutive shifts, or 18 psig in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , AND the losses were determined to be to the Reactor Auxiliary Building Atmosphere, then declare the losses as an UNPLANNED RELEASE (reference CR 00-2038).

Is not an UNPLANNED RELEASE if:

1.

It cannot be shown that the release went off site, i.e., gas went to another part of the system(s) that contained the loss.

2.

Normal losses through the Plant Vent due to valve and pipe leakage and purging activities to make the system safe for maintenance activities.

UNRESTRICTED AREA 1.35 UNRESTRICTED AREA means an area, access to which is neither limited nor controlled by the licensee.

VENTILATION EXHAUST TREATMENT SYSTEM 1.39 A VENTILATION EXHAUST TREATMENT SYSTEM shall be any system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal absorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment. Such a system is not considered to have any effect on noble gas effluents.

Engineered Safety Features Atmospheric Cleanup Systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

St. Lucie Plant ODCM Controls

Page 15 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.0 DEFINITIONS for CONTROLS SECTION OF ODCM VENTING 1.40 VENTING shall be the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING.

Vent, used in system names, does not imply a VENTING process.

WASTE GAS HOLDUP SYSTEM 1.41 A WASTE GAS HOLDUP SYSTEM shall be any system designed and installed to reduce radioactive gaseous effluents by collecting Reactor Coolant System offgases from the Reactor Coolant System and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment.

St. Lucie Plant ODCM Controls

Page 16 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 1.1 FREQUENCY NOTATION NOTATION S

D w

4/M*

M Q

SA R

S/U N.A.

p**

FREQUENCY At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

At least once per 7 days.

At least 4 per month at intervals of no greater than 9 days and minimum of 48 per year.

At least once per 31 days.

At lease once per 92 days.

At least once per 184 days.

At least once per 18 months.

Prior to each reactor startup.

Not Applicable.

Completed prior to each release

For Radioactive Effluent Sampling

- For Radioactive Batch Releases Only St. Lucie Plant ODCM Controls

Page 17 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 3/4 CONTROLS AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY CONTROLS 3.0.1 Compliance with the Controls contained in the succeeding controls is required during the conditions specified therein; except that upon failure to meet the Control, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a Control shall exist when the requirements of the Control and associated ACTION requirements are not met within the specified time intervals.

If the Control is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the conditions specified for individual Controls unless otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:

a.

A maximum allowable extension not to exceed 25% of the surveillance interval.

St. Lucie Plant ODCM Controls 3/4

Page 18 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION CONTROLS 3.3.3.9 In accordance with St. Lucie Plant TS 6.8.4.f.1), the radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Control 3.11.1.1 are not exceeded. The Alarm/Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITY:

At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above control, immediately suspend the release of radioactive liquid effluents monitored by the affected channel or declare the channel inoperable or change the setpoint so it is acceptably conservative.

b.

With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-12.

Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Annual Radioactive Effluent Release Report why this inoperability was not corrected in a timely manner.

c.

Report all deviations in the Annual Radioactive Effluent Release Report.

SURVEILLANCE REQUIREMENTS 4.3.3.9 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table 4.3-8.

St. Lucie Plant ODCM Controls

Page 19 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-12 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE ACTION

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release a)

Liquid Radwaste Effluent Line 1

35 b)

Steam Generator Blowdown 1/SG 36, 37 Effluent Line

2. Flow Rate Measurement Devices a)

Liquid Radwaste Effluent Line N.A.

38 b)

Discharge Canal N.A.

38 c)

Steam Generator Blowdown N.A.

38 Effluent Lines SG - Denotes Steam Generator St. Lucie Plant ODCM Controls

Page 20 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-12 (Continued)

ACTION STATEMENTS ACTION 35 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may continue provided that prior to initiating a release:

/R25

a.

At least two independent samples are analyzed in accordance with the Surveillance Requirement for concentration limit of Control 4.11.1.1.1. and

b.

At least two technically qualified members of the Facility Staff independently verify the release rate calculations and discharge line valving.

Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 36 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are analyzed for gross radioactivity (beta or gamma) at a limit of detection of at least 2.E-07 micro-Curie/ml:

a.

At least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (') when the specific activity of the secondary coolant is greater than 0.01 micro-Curies/gram DOSE EQUIVALENT 1-131 or

b.

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (') when the specific activity of the secondary coolant is less than or equal to 0.01 micro-Curies/gram DOSE EQUIVALENT 1-131.

St. Lucie Plant ODCM Controls

Page 21 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-12 (Continued)

ACTION STATEMENTS (continued)

ACTION 37 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, isotopic grab samples shall be obtained and analyzed at a Lower Limit of Detection for 1-131, Co-58, Co-60, Cs-134, and Cs-137 to achieve detection sensitivity capable of detecting a primary-to-secondary leak rate of 5 gallons per day, provided that the Reactor Coolant System has sufficient activity present.

The applicable frequency shall be:

In MODES 1, 2, 3, 4

a.

At least once per day(') for isotopic activity on the affected Steam Generator, provided that the Air Ejector Gas Activity Monitor is OPERABLE, OR

b.

At least every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (') for isotopic activity on the affected Steam Generator, if the Air Ejector Gas Activity Monitor is INOPERABLE.

This requirement is intended to meet EPRI PWR Primary-to-Secondary Leak Guidelines (TR-104788-R2) per reference PMAI 00-08-109.

ACTION 38 - Minimum system design flow of required running pumps shall be utilized for ECL calculations for discharge canal flow and maximum system design flow be utilized for ECL calculations for effluent line flow.

TABLE 3.3-12 Notation (1) -

The initial sample shall be completed prior to the frequency interval specified.

Subsequent samples (of the same INOPERABLE condition) may be performed per ODCM surveillance requirement 4.0.2 (a maximum allowable extension not to exceed 25% of the surveillance interval).

St. Lucie Plant ODCM Controls

Page 22 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.3-8 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS (4)

St. Lucie Plant ODCM Controls CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL INSTRUMENT CHECK CHECK CALIBRATION TEST

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release a)

Liquid Radwaste Effluent D

R (2)

Q (1)

Line b) Steam Generator Blowdown Effluent Line

2. Flow Rate Measurement Devices a)

Liquid Radwaste Effluent D (3)

N.A.

R Q

Line b)

Discharge Canal D (3)

N.A.

R Q

c)

Steam Generator Blowdown Effluent Line

Page 23 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.3-8 (Continued)

TABLE NOTATIONS (1)

The CHANNEL FUNCTIONAL TEST shall also demonstrate automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm/trip setpoint or

2.

Circuit failure or

3.

Instrument indicates a downscale failure or

4.

Instrument controls not set in operate mode.

(2)

The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards traceable to the National Institute of Standards & Technology (NIST) or using standards that have been calibrated against standards certified by the NIST. These standards should permit calibrating the system over its intended range of energy and rate capabilities that are typical of normal plant operation.

For subsequent CHANNEL CALIBRATION, button sources that have been related to the initial calibration may be used.

(3)

CHANNEL CHECK shall consist of verifying indication of flow during periods of release.

CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic or batch releases are made.

(4)

The requirements to perform the surveillances is not applicable, if Table 3.3-12 list the INSTRUMENT MINIMUM CHANNELS OPERABLE as not applicable (N.A.).

(Reference CR 99-0361, PMAI 99-04-106).

St. Lucie Plant ODCM Controls

Page 24 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION CONTROLS 3.3.3.10 In accordance with St. Lucie Plant TS 6.8.4.f.1), the radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Control 3.11.2.1.are not exceeded.

The Alarm/Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-13 ACTION:

a.

With a radioactive gaseous effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above control, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel or declare the channel inoperable or change the setpoint so it is acceptably conservative.

b.

With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13.

Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Annual Radioactive Effluent Release Report why this inoperability was not corrected in a timely manner.

c.

Report all deviations in the Annual Radioactive Effluent Release Report.

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table 4.3-9.

St. Lucie Plant ODCM Controls

Page 25 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-13 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

1. Waste Gas Holdup System a)

Noble Gas Activity Monitor Providing Alarm and Automatic Termination of Release

2. Condenser Evacuation System a)

Noble Gas Activity Monitor 1/Rx 47 Modes 1, 2, 3, 4 48

3. Plant Vent System a)

Noble Gas Activity Monitor 1/Rx 47 (Low Range) b)

Iodine Sampler 1/Rx 51 c)

Particulate Sampler 1/Rx 51 d)

Flow Rate Monitor N.A.

53 e)

Sampler Flow Rate Monitor 1/Rx 46

4. Fuel Storage Area Ventilation System a)

Noble Gas Activity Monitor 1/Rx 47 (Low Range) b)

Iodine Sampler 1/Rx 51 c)

Particulate Sampler 1/Rx 51 d)

Flow Rate Monitor N.A.

53 e)

Sampler Flow Rate Monitor 1/Rx 46 St. Lucie Plant ODCM Controls

Page 26 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-13 (Continued)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

5. Laundry Area Ventilation System a)

Noble Gas Activity Monitor lIRx 47 (Low Range) b)

Iodine Sampler 1/Rx 51 c)

Particulate Sampler 1/Rx 51 d)

Flow Rate Monitor N.A.

53 e)

Sampler Flow Rate Monitor 1/Rx 46

6. Steam Generator Blowdown Building Vent a)

Noble Gas Activity Monitor 1

47 (Low Range) b)

Iodine Sampler 1

51 c)

Particulate Sampler 1

51 d)

Flow Rate Monitor N.A.

53 e)

Sampler Flow Rate Monitor 1

46 St. Lucie Plant ODCM Controls

Page 27 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-13 (Continued)

TABLE NOTATIONS

- At all times while making releases via this pathway

- At all times when air ejector exhaust is not directed to plant vent.

Rx

- Denotes reactor ACTION STATEMENTS ACTION 45 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank(s) may be released to the environment provided that prior to initiating a release:

/R25

a.

At least two independent samples of the tank's contents are analyzed and

b.

At least two technically qualified members of the facility staff independently verify the release rate calculations and discharge valve lineup.

Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 46 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ACTION 47 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE, effluent releases via this pathway may continue for up to 30 days provided:

a.

If channel inoperability is due to loss of activity indication, Then grab samples are taken at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (l) and these samples are analyzed for isotopic activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

OR

b.

If channel inoperability is due to loss of Control Room alarm annunciation discovered during a channel functional test because of any one or more of the following reasons listed, Then channel checks are performed once per hour0') to verify normal indication and current assigned setpoints are NOT exceeded.

1.

Failure to annunciate when testing alarm/trip setpoints.

2.

Circuit failure.

3.

Downscale failure.

4.

Controls NOT set in OPERATE mode.

St. Lucie Plant ODCM Controls

Page 28 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-13 (Continued)

TABLE NOTATIONS ACTION STATEMENTS (continued)

ACTION 48 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, noble gas isotopic grab samples shall be obtained and analyzed at a Lower Limit of Detection for Ar-41, Kr-88, Xe-133, Xe-133m, and Xe-135 to achieve detection sensitivity capable of detecting a primary-to-secondary leak rate of 5 gallons per day, provided that the Reactor Coolant System has sufficient activity present.

The applicable frequency shall be:

a.

At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (1')'2) for noble gas isotopic activity on the Air Ejector Exhaust provided that each affected Unit's Steam Generator Blowdown Monitor is OPERABLE, OR

b.

At least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (1)'(2) for noble gas isotopic activity on the Air Ejector Exhaust if either of the affected Unit's Steam Generator Blowdown Monitors is INOPERABLE.

This requirement is intended to meet EPRI PWR Primary-to-Secondary Leak Guidelines (TR-104788-R2), therefore grab samples shall be taken regardless of the Alignment of the Air Ejector Exhaust while in Modes 1, 2, 3, 4. (Reference PMAI 00-08-109.)

ACTION 51 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the affected pathway may continue for up to 30 days provided samples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.

ACTION 53 - Maximum system flows shall be utilized in the determination of the instantaneous release monitor alarm setpoint.

TABLE 3.13-13 NOTATION (1) - The initial sample shall be completed prior to the frequency interval specified.

Subsequent samples (of the same INOPERABLE condition) may be performed per ODCM surveillance requirement 4.0.2 (a maximum allowable extension not to exceed 25 percent of the surveillance interval).

(2) - If there is no steam flow to the air ejector nozzles while the Reactor is in Mode 4, Then the sample may be omitted, but the steam flow condition (status) to the air ejector shall be reverified once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to initiate grab samples if steam flow to the air ejector nozzles is established.

St. Lucie Plant ODCM Controls

Page 29 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-14 RADIOACTIVE EFFLUENT MONITOR SETPOINT BASIS ODCM Effluent Gas Channels CHANNEL BASIS ALERT HIGH ID DOCUMENT SETPOINT*

SETPOINTe 1 VLOW RANGE GAS 01-05 C-0a5xBgq Allotted % Of Site Allotted % Of Site 1FHB LOW RANGE GAS 04-05 C-200a 5 x Bkg.

Limitg 2A PV PIG LOW RANGE GAS 423 C-200a 5 x Bkg.q Allotted % Of Site Limitg For Plant 2B PV PIG LOW RANGE GAS 433 C-200a 5 x Bkg.

Vent #2 Allotted % Of Site 2FHB LOW RANGE GAS 413 C-200a 5 x Bkg.

llotte Allotted % Of Site SGBDB LOW RANGE GAS 45-6 C-200" 5 x Bkg.

limite 1 CONDENSER AIR EJECTOR 35 C-200 2 x Bkg.b 3 x Bkg.

2 CONDENSER AIR EJECTOR 403 C-200 2 x Bkg.b 3 x Bkg.

1 BATCH GAS EFFLUENT 42 C-200a As Per COP-01.06 As Per COP-01.06a"h 2 BATCH GAS EFFLUENT 203 C-200a As Per COP-01.06 As Per COP-01.06,h 2PV WRGM Chan Low Range Gas 621 624P C-200a 5 x Bkg? uCi/sec Allotted % Of Site Mid Range Gas 622 Limitp uCi/sec High Range Gas 623 2A ECCS WRGM Chan Low Range Gas 601 604P C.200a 0.75 x Highp Allotted % Of Site Mid Range Gas 602 uCi/sec Limitp uCi/sec High Range Gas 603 2B ECCS WRGM Chan Low Range Gas 611 614P C.200a 0.75 x Highp Allotted % Of Site Mid Range Gas 612 uCi/sec Limitp uCi/sec High Range Gas 613 ODCM Related Particulate Channels CHANNEL BASIS ALERT HIGH ID DOCUMENT SETPOINT8 SETPOINTO 1PV PARTICULATE 01-01 FUSAR 5000 CPM 10,000 CPMC 1FHB PARTICULATE 04-01 FUSAR & TSd 5000 CPM 10,000 CPMC 2A PV PIG PARTICULATE 421 FUSAR 5000 CPM 10,000 CPMC 28 PV PIG PARTICULATE 431 FUSAR 5000 CPM 10,000 CPMC 2FHB PARTICULATE 411 FUSAR & TSd 5000 CPM 10,000 CPMC SGBDB PARTICULATE 45-4 FUSAR 5000 CPM 10,000 CPMC St. Lucie Plant ODCM Controls

Page 30 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-14 (continued)

RADIOACTIVE EFFLUENT MONITOR SETPOINT BASIS ODCM Related Iodine Channels CHANNEL BASIS ALERT HIGH ID DOCUMENT SETPOINTe SETPOINT' 1PV IODINE 01-03 FUSAR 5000 CPM 10,000 CPMC 1FHB IODINE 04-03 FUSAR 5000 CPM 10,000 CPMC 2A PV PIG IODINE 422 FUSAR 5000 CPM 10,000 CPMC 2B PV PIG IODINE 432 FUSAR 5000 CPM 10,000 CPMC 2FHB IODINE 412 FUSAR 5000 CPM 10,000 CPMC SGBDB IODINE 45-5 FUSAR 5000 CPM 10,000 CPMc ODCM Related Liquid Channels CHANNEL BASIS ALERT HIGH ID DOCUMENT SETPOINTe SETPOINTO 1A S/G BLOWDOWN 44 C-200 2 x Bkg.

2.E-04 uCi/mlf'm 1 B S/G BLOWDOWN 45 C-200 2 x Bkg.

2.E-04 uCi/mlf'm 2A S/G BLOWDOWN 121 C-200 2 x Bkg.

2.E-04 uCiml t m 2B S/G BLOWDOWN 122 C-200 2 x Bkg.

2.E-04 uCi/mlm 1 BATCH LIQUID EFFLUENT R6627 C-200 As Per As Per COP-01.05 COP-01.05" 2 BATCH LIQUID EFFLUENT 301 C-200 As Per As Per COP-01.05 COP-01.05n Monitor channels not listed are covered per COP-07.05 Table Notations:

a -

ODCM Control 3.11.2.1a b -

ODCM Table 4.11-1 Note (7) c -

ODCM Control 3.11.2.1.b d -

TS Table 3.3-6 required instrument 2.a.ii with setpoint per ODCM e -

Setpoints may be rounded for analog and digital display input limitations.

f -

The channel setpoint to be in cpm equivalent to this activity g -

per ODCM Methodology Step 2.2.2 h -

Batch Gaseous Release Rate and Maximum activity limits shall be used such that Plant Vent (PV)

Release HIGH setpoints should not be exceeded.

St. Lucie Plant ODCM Controls

Page 31 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-14 (continued)

RADIOACTIVE EFFLUENT MONITOR SETPOINT BASIS Table Notations: (continued) i, j, k, and I not used in notation for clarity m - Continuous Liquid setpoint methodology per ODCM 1.3.2 n -

Batch liquid setpoint methodology per ODCM 1.3.1 o -

Note "oscar" is not used in this table notation p -

The individual Channel 621, 622 and 623 (Plant Vent No. 2)

Channel 601, 602 and 603 (ECCS 2A) and Channel 611, 612 and 613 (ECCS 2B)

Data Base Alert and High Alarm Setpoint Items do not provide activation of a Control Room Alarm.

Only the Skid's Effluent Channel Setpoint provides an alarm function. After the first Alert and High Effluent Channel Alarms are received they will stay locked in if the release is increasing to higher activity levels. Transfer of Skid internal control to Effluent Channel input from the Mid or High Range Gas Channels will not reset an alarm, nor provide additional alarms. The Effluent Channel on the respective Skid has to be reset to new Setpoints by I&C. References to "Alert Alarm" and "High Alarm" settings for the Low Mid and High Channels are for display information only. This is why Table 3.3-14 only list Channel 624, 604 and 614 as the Channel ID for Alarm Setpoints.

These are the respective Skid's Alarm Channel.

Channel ID number 604 and 614 are the uCi/sec indication and ALERT/HIGH Alarm channels for ECCS 2A and ECCS 2B respectively. The ECCS exhaust pathways each have a single fan. Their Skid's Monitor Item #059 will be set per the measured ft3/minute exhaust rate. Their Skid's Monitor Item #060 (Accident Flow rate) will be set to zero since there is only one flow rate possible for these ECCS pathways. The uCi/sec value indicated on ECCS skids should be valid regardless of Normal or Accident conditions.

The Channel ID number 624 (generically called the Plant Vent 2 Skid's Channel 4) is the uCi/sec and Control Room active ALERT/HIGH Alarm that is Common (shared by) to the Low (621), Mid (622), and High (623) Range Gas Channels. The Plant Vent 2's skid Monitor Item #059 will be set for the maximum ft3/minute flow rate that could occur under all circumstances. The Plant Vent 2 Channel 624's actual uCi/sec is dependent what is set in Monitor Item #059 and Monitor Item

060 as follows:

The NORMAL value for the Common Channel 624 uCi/sec indication and ALERT/High Alarms should be based on the equivalent uCi/sec of the 5 x Bkg (use COP-07.05) uCi/cc of the Low Range Channel #621 and RIM 26-90 Monitor Item #059 (the MAXIMUM process ft3/minute flow rate that could occur in the Unit 2 Plant Vent.

St. Lucie Plant ODCM Controls

Page 32 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.3-14 (continued)

RADIOACTIVE EFFLUENT MONITOR SETPOINT BASIS Table Notations: (continued) p -

(continued)

The ACCIDENT value for the Common Channel 624's uCi/sec is based on the Skid switching (at a preset activity value) input from the Low Range Channel to calculate/display a uCi/sec value based on receiving activity uCi/cc input from either the Mid Range Channel 622 (OR from the High Range Channel 623) and RIM 26-90 Monitor Item #060 6,600 ft3/minute (use COP-07.05) flow rate that is expected during a LOCA Safety Injection sequence.

During an ACCIDENT you have to access the running status of 2-HVE-6A, 2-HVE-6B, 2-HVE-7A, 2-HVE-7B, 2-HVE-8A, 2-HVE-8B, 2-HVE-10A and 2-HVE-10B to determine actual Plant Vent exhaust flow rate ft3/minute. This is the flow rate that should be inserted into Plant Vent #2 Skid's Monitor Item #060 with new Setpoints for Alert and High Alarms in units of uCi/sec calculated by using the actual Plant Vent exhaust flow during the Accident. If fan operating status changes, the Effluent Channel 624 uCi/sec indication and existing Alert and High Alarm Setpoints will not be valid for a new flow rate. This is the reason that EPIP-09 does not utilize Channel 624 indication for calculating off-site dose.

q -

During an outage, the Low Range gas activity ALERT Alarm Setpoint may be set to slightly above outage anticipated activity levels, but shall always be set to a value less than the High Alarm Setpoint. Examples of outage activities are initiating a Containment Main Purge and venting the S/G primary side bowls.

FUSAR - Channel listed in fusar, but not required by ODCM Control 3.3.10 Table 3.3-13. The setpoints are used to provide alarm well before exceeding ODCM Control 3.11.2.1.b Site Dose Rate Limit. The inoperability of a fusar channel above does not involve an ACTION statement unless TS (Technical Specification) is noted.

2 x Bkg, 3 x Bkg., 5 x Bkg etc., denotes the number of times the normal channel reading is the appropriate Alarm Setting. These type of setpoints should be periodically evaluated to insure alarm sensitivity is maintained as per COP-07.05.

St. Lucie Plant ODCM Controls

Page 33 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.3-9 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS (4)

Modes in CHANNEL which CHANNEL SOURCE CHANNEL FUNCTIONAL surveillance INSTRUMENT CHECK CHECK CALIBRATION TEST required

1. Waste Gas Holdup System a)

Noble Gas Activity Monitor - Providing AlarmandP P

R (3)

Q (1)

Automatic Termination of Release

2. Condenser Evacuation System a)

Noble Gas Activity D

M R (3)

Q (2)

Monitor

3. Plant Vent System a) Noble Gas Activity D

M R (3)

Q (2)

Monitor b) Iodine Sampler W

N.A.

c) Particulate Sampler W

N.A.

d) Flow Rate Monitor D

N.A.

R Q

e) Sampler Flow Rate D

N.A.

R N.A.

Monitor

4. Fuel Storage Area Ventilation System a)

Noble Gas Activity D

M R (3)

Q (2)

Monitor b)

Iodine Sampler W

N.A.

c)

Particulate Sampler W

N.A.

d)

Flow Rate Monitor D

N.A.

R Q

e)

Sampler Flow Rate D

N.A.

R N.A.

Monitor St. Lucie Plant ODCM Controls

Page 34 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.3-9 (Continued)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS (4)

St. Lucie Plant ODCM Controls Modes in CHANNEL which CHANNEL SOURCE CHANNEL FUNCTIONAL surveillance INSTRUMENT CHECK CHECK CALIBRATION TEST required

5. Laundry Area Ventilation System a)

Noble Gas Activity D

M R (3)

Q (2)

Monitor b)

Iodine Sampler W

N.A.

c)

Particulate Sampler W

N.A.

d)

Flow Rate Monitor D

N.A.

R Q

e)

Sampler Flow Rate D

N.A.

R N.A.

Monitor

6. Steam Generator Blowdown Building Vent a)

Noble Gas Activity D

M R (3)

Q (2)

Monitor b)

Iodine Sampler W

N.A.

c)

Particulate Sampler W

N.A.

d)

Flow Rate Monitor D

N.A.

R Q

e)

Sampler Flow Rate D

N.A.

R N.A.

Monitor

Page 35 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.3-9 (Continued)

TABLE NOTATIONS

-At all times when making releases via this pathway.

-At all times when air ejector exhaust is not directed to plant vent.

(1)

The CHANNEL FUNCTIONAL TEST shall also demonstrate automatic isolation of this pathway and control room alarm annunciation occurs if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm/trip setpoint or

2.

Circuit failure or

3.

Instrument indicates a downscale failure or

4.

Instrument controls not set in operate mode.

(2)

The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm/trip setpoint or

2.

Circuit failure or

3.

Instrument indicates a downscale failure or

4.

Instrument controls not set in operate mode.

(3)

The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards traceable to the National Institute of Standards & Technology (NIST) or using standards that have been calibrated against standards certified by the NIST. These standards should permit calibrating the system over its intended range of energy and rate capabilities that are typical of normal plant operation.

For subsequent CHANNEL CALIBRATION, button sources that have been related to the initial calibration may be used.

(4)

The requirements to perform the surveillances is not applicable, if Table 3.3-13 list the INSTRUMENT MINIMUM CHANNELS OPERABLE as not applicable (N.A.).

(Reference CR 99-0361, PMAI 99-04-106).

St. Lucie Plant ODCM Controls

Page 36 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 3/4.11 RADIOACTIVE EFFLUENTS 3/4.11.1 LIQUID EFFLUENTS CONCENTRATION CONTROLS 3.11.1.1 In accordance with the St. Lucie Plant TS 6.8.4.f.2) and 3), the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see TS Figure 5.1-1) shall be limited to ten times the concentrations specified in 10 CFR Part 20.1001-20.2401, 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.E-04 micro-Curie/ml total activity.

APPLICABILITY: At all times.

ACTION:

a.

With the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, immediately restore the concentration to within the above limits.

SURVEILLANCE REQUIREMENTS 4.11.1.1.1 Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program of Table 4.11-1.

4.11.1.1.2 The results of the radioactivity analyses shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of Control 3.11.1.1.

4.11.1.1.3 Post-release analyses of samples composited from batch releases shall be performed in accordance with Table 4.11-1 and results of the previous post-release analyses shall be used with the calculational methods in the ODCM to assure that the concentrations at the point of release were maintained within the limits of Control 3.11.1.1.

St. Lucie Plant ODCM Controls

Page 37 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Liquid Release Sampling Minimum Lower Limit of Li ee Sampling Analysis Type of Activity Detection Type Frequency Frequency Analysis LLD (1) (pCi/ml)

A. Batch Waste p

P.G.E. (3) 5.E-07 Release Each Batch Each Batch P-13) 1.E-06 Tanks (2)

PDissolved and One Batch/M M

Entrained Gases 1.E-05 (Gamma Emitters)

P M

H-3 1.E-05 Each Batch Composite (4)

Gross Alpha 1.E-07 P

Q Sr-89, Sr-90 5.E-08 Each Batch Composite (4) C-14, Fe-55, Ni-63 1.E-06 B. Continuous 4/M P.G.E.(3) 5.E-07 Releases (5, 6)

Daily Composite 1-131 1.E-06 Daily 4/M Dissolved and Entrained Gases 1.E-05 Grab Sample Composite (Gamma Emitters)

M H-3 1.E-05 Composite Gross Alpha 1.E-07 Daily Q

Sr-89, Sr-90 5.E-08 DailyComposite C-14, Fe-55, Ni-63 1.E-06 C. Settling W

W P.G.E. (3) 5.E-07 Basin (7)

Grab Sample 1-131 1.E-06 D. Settling Basin P.G.E. (3) 5.E-07 as a Batch 1-131 1.E-06 Release P

Each Batch Dissolved and Pathway. (9)

Each Batch (8)

Ec ac isle n

(Reference Entrained Gases 1.E-05 CR 99-1165 (Gamma Emitters)

PMAI 99-08-084 H-3 i.E-O5 PMAI-01-04-115 Each Batch Each Batch Gross Alpha 1.E-07 Sr-89, Sr-90 5.E-08

[_C-14, Fe-55, Ni-63 1.E-06 P.G.E. -

Denotes Principal Gamma Emitter St. Lucie Plant ODCM Controls

Page 38 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-1 (Continued)

TABLE NOTATION (1) The LLD is defined for purposes of these controls, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a real signal.

For a particular measurement system, which may include radiochemical separation:

LLD =4.66 Sb E - V - 2.22E+06 - Y - exp (-X. AT)

Where:

LLD

=

the a priori lower limit of detection (micro-Curie per unit mass or volume),

Sb

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

E

=

the counting efficiency (counts per disintegration),

V

=

the sample size (units of mass or volume),

2.22E+06

=

the number of disintegrations per minute per micro-Curie.,

Y

=

the fractional radiochemical yield, when applicable, x.=

the radioactive decay constant for the particular radionuclide (sec-') and AT

=

the elapsed time between the midpoint of sample collection and the time of counting (sec).

Typical values of E, V, Y and AT should be used in the calculation.

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

St. Lucie Plant ODCM Controls

Page 39 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-1 (Continued)

TABLE NOTATIONS (Continued)

(2) A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated and then thoroughly mixed by a method described in the ODCM to assure representative sampling.

(3) The principal gamma emitters for which the LLD control applies include the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137 and Ce-141 and Ce-144. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radioactive Effluent Release Report pursuant to Control 3.11.2.6 in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974.

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

(5)

A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g., from a volume of a system that has an input flow during the continuous release.

(6)

If Component Cooling Water activity is > 1.E-5 gCi/ml, perform a weekly gross activity on the Intake Cooling Water System outlet to ensure the activity level is less than or equal to 2.E-07 gCi/ml LLD limit. If ICW is >2.E-07 gCi/ml, perform analysis in accordance with a Plant Continuous Release on this Table.

(7)

Grab samples to be taken when there is confirmed primary to secondary system leakage indicated by the air ejector monitor indicating greater than or equal to 2x background.

(8)

At least two independent samples are analyzed in accordance with the surveillance requirement for concentration limit of control 4.11.1.1.1 and at least two technically qualified members of the facility staff independently verify the release rate calculations.

(9)

The settling basin(s) may receive low level activity per the guidance of COP-01.05, therefore these samples shall be taken regardless of the absence of a primary-to-secondary leak (note (7) on liquid release type C. settling, basin does not apply to liquid release type D. settling basin as a batch release pathway).

St. Lucie Plant ODCM Controls

Page 40 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS DOSE CONTROLS 3.11.1.2 In accordance with St. Lucie Plant TS 6.8.4.f.4) and 6.8.4.f.5), the dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS (see TS Figure 5.1-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrems to the whole body and to less than or equal to 5 mrems to any organ and

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

APPLICABILITY:

At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS 4.11.1.2 Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

St. Lucie Plant ODCM Controls

Page 41 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS LIQUID RADWASTE TREATMENT SYSTEM CONTROLS 3.11.1.3 In accordance with St. Lucie Plant TS 6.8.4.f.6), the Liquid Radwaste Treatment System shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see TS Figure 5.1-1) would exceed 0.06 mrem to the whole body or 0.2 mrem to any organ in a 31-day period.

APPLICABILITY: At all times.

ACTION:

a. With radioactive liquid waste being discharged without treatment and in excess of the above limits and any portion of the Liquid Radwaste Treatment System not in operation, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that includes the following information:

1.

Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems and the reason for the inoperability,

2.

Action(s) taken to restore the inoperable equipment to OPERABLE status and

3.

Summary description of action(s) taken to prevent a recurrence.

SURVEILLANCE REQUIREMENTS 4.11.1.3.1 Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when Liquid Radwaste Treatment Systems are not being fully utilized.

4.11.1.3.2 The installed Liquid Radwaste Treatment System shall be demonstrated OPERABLE by operating the liquid radwaste treatment system equipment for at least 30 minutes at least once per 92 days unless the liquid radwaste system has been utilized to process radioactive liquid effluents during the previous 92 days.

St. Lucie Plant ODCM Controls

Page 42 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS DOSE RATE CONTROLS 3.11.2.1 In accordance with St. Lucie Plant TS 6.8.4.f.3) and 7), the dose rate resulting from radioactive materials released in gaseous effluents to areas at or beyond the SITE BOUNDARY (see TS Figure 5.1-1) shall be limited to the following:

a. For noble gases: Less than or equal to 500 mrems/yr to the total body and less than or equal to 3000 mrems/yr to the skin and

b. For Iodine-1 31, for Iodine-1 33, for tritium and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ APPLICABILITY:

At all times.

ACTION:

a. With the dose rate(s) exceeding the above limits, immediately restore the release rate to within the above limit(s).

SURVEILLANCE REQUIREMENTS 4.11.2.1.1 The dose rate due to noble gases in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM.

4.11.2.1.2 The dose rate due to Iodine-131, Iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 4.11-2.

St. Lucie Plant ODCM Controls

Page 43 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-2 RADIOACTIVE GASEOUS WASTE SAMPLING & ANALYSIS PROGRAM P.G.E. -

Denotes Principal Gamma Emitters St. Lucie Plant ODCM Controls Gaseous Release Sampling Minimum Type of Activity Lower Limit of Type Frequency Analysis Analysis Detection Frequency (LLD) (1)

(gCi/cc)

1.

Waste Gas P

P Noble Gas 1.E-04 Storage Tank Each Tank Each Tank P.G.E. (2)

Grab Sample

2.

Containment P

P Noble Gas 1.E-04 Purge Each Purge (6) Each Purge (6)

P.G.E. (2)

Grab Sample (7)

H-3 1.E-06

3.

Vents:

4/M 4/M (7)

Noble Gas 1.E-04

a. Plant Grab Sample P.G.E. (2)

b. Fuel Bldg (5)

c. Laundry H-3 1.E-06

d. S/G Blowdown Bldg.

4.

All Release Continuous (3) 4/M 1-131 1.E-12 Types as Charcoal listed in 3.

Sample (4) above 4/M P.G.E.

1.E-11 Particulate Sample (4) 4/M Gross Alpha 1.E-11 Particulate Sample Q

Sr-89, Sr-90 1.E-11 Composite Particulate Sample Noble Gas Noble Gases 1.E-06 Monitor Gross Beta or Gamma TABLE 4.11-2 R DIO TI E

Page 44 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-2 (Continued)

TABLE NOTATIONS (1) The LLD is defined for purposes of these controls, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a real signal.

For a particular measurement system, which may include radiochemical separation:

LLD =

4.66 Sb E

V 2.22E+06 - Y - exp (-

AT)

Where:

LLD

=

the a priori lower limit of detection (micro-Curie per unit mass or volume),

Sb=

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

E

=

the counting efficiency (counts per disintegration),

V

=

the sample size (units of mass or volume),

2.22E+06

=

the number of disintegrations per minute per micro-Curie.,

Y

=

the fractional radiochemical yield, when applicable,

=

the radioactive decay constant for the particular radionuclide (sec1 )

and AT

=

the elapsed time between the midpoint of sample collection and the time of counting (sec).

Typical values of E, V, Y and AT should be used in the calculation.

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

St. Lucie Plant ODCM Controls

Page 45 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.11-2 (Continued)

TABLE NOTATIONS (Continued)

(2) The principal gamma emitters for which the LLD control applies include the following radionuclides:

Kr-87,Kr-88, Xe-133, Xe-133m, Xe-135 and Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, 1-131, Cs-134, Cs-137, Ce-141 and Ce-144 in Iodine and particulate releases. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radioactive Effluent Release Report pursuant to Control 3.11.2.6 in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974.

(3) The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Controls 3.11.2.1, 3.11.2.2 and 3.11.2.3.

(4) Samples shall be changed at least four times per month and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing or after removal from sampler. Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least 7 days following each shutdown, startup or THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement does not apply if: (1) analysis shows that the DOSE EQUIVALENT 1-131 concentration in the reactor coolant has not increased more than a factor of 3; and (2) the noble gas monitor shows that effluent activity has not increased by more than a factor of 3.

(5) Tritium grab samples shall be taken at least 4/M from the ventilation exhaust from the spent fuel pool area, whenever spent fuel is in the spent fuel pool.

(6) Sampling and analysis shall also be performed following shutdown, startup or a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months unless (1) analysis shows that the DOSE EQUIVALENT 1-131 concentration in the primary coolant has not increased more than a factor of 3; and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3.

(7) Tritium analysis may be delayed for up to 14 days if the LLD is still attainable at the new counting time.

St. Lucie Plant ODCM Controls

Page 46 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS DOSE - NOBLE GASES CONTROLS 3.11.2.2 In accordance with St. Lucie Plant TS 6.8.4.f.5) and 8), the air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY (see TS Figure 5.1-1) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation and

b. During any calendar year: Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

APPLICABILITY:

At all times.

ACTION:

a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS 4.11.2.2 Cumulative dose contributions for the current calendar quarter and current calendar year for noble gases shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

St. Lucie Plant ODCM Controls

Page 47 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS DOSE -

IODINE-131, IODINE-133, TRITIUM AND RADIOACTIVE MATERIAL IN PARTICULATE FORM CONTROLS 3.11.2.3 In accordance with St. Lucie Plant TS 6.8.4.f.5) and 9), the dose to a MEMBER OF THE PUBLIC from Iodine-131, Iodine-1 33, 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 (see TS Figure 5.1-1) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any organ and,

b. During any calendar year: Less than or equal to 15 mrems to any organ.

APPLICABILITY:

At all times.

ACTION:

a. With the calculated dose from the release of Iodine-131, Iodine-133, tritium and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS 4.11.2.3 Cumulative dose contributions for the current calendar quarter and current calendar year for Iodine-1 31, Iodine-1 33, tritium and radionuclides in particulate form with half-lives greater than 8 days shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

St. Lucie Plant ODCM Controls

Page 48 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS GASEOUS RADWASTE TREATMENT SYSTEM CONTROLS 3.11.2.4 In accordance with St. Lucie Plant TS 6.8.4.f.6), the VENTILATION EXHAUST Treatment System and the WASTE GAS HOLDUP SYSTEM shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see TS Figure 5.1-1) would exceed:

a.

0.2 mrad to air from gamma radiation or

b.

0.4 mrad to air from beta radiation or

c.

0.3 mrem to any organ.

APPLICABILITY:

At all times.

ACTION:

a. With radioactive gaseous waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that includes the following information:

1.

Identification of any inoperable equipment or subsystems and the reason for the inoperability,

2.

Action(s) taken to restore the inoperable equipment to OPERABLE status and I

3.

Summary description of action(s) taken to prevent a recurrence.

St. Lucie Plant ODCM Controls

Page 49 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS GASEOUS RADWASTE TREATMENT SYSTEM (Continued)

SURVEILLANCE REQUIREMENTS 4.11.2.4.1 Doses due to gaseous releases from each unit to areas at and beyond the SITE BOUNDARY shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when Gaseous Radwaste Treatment Systems are not being fully utilized.

4.11.2.4.2 The installed VENTILATION EXHAUST TREATMENT SYSTEM and WASTE GAS HOLDUP SYSTEM* shall be demonstrated OPERABLE by operating the WASTE GAS HOLDUP SYSTEM equipment and VENTILATION EXHAUST TREATMENT SYSTEM equipment for at least 30 minutes, at least once per 92 days unless the appropriate system has been utilized to process radioactive gaseous effluents during the previous 92 days.

If the WASTE GAS HOLDUP SYSTEM is not being fully utilized, an Administrative FUNCTIONAL TEST on the WASTE GAS HOLDUP SYSTEM shall also be performed (in addition to the requirements of 4.11.2.4.2's "at least 30 minutes") once per 92 days, by performing the following:

1)

Place a Gas Decay Tank (containing less than 30 psi) in service.

2)

With a Waste Gas Compressor, charge the Gas Decay Tank to at least 150 psi.

3)

Following appropriate holdup decay time, sample and release the Gas Decay Tank with an OPERABLE Waste Gas Holdup System Noble Gas Activity Monitor (per TABLE 3.3-13).

4)

If discrepancies exist, repairs shall be made and the WASTE GAS HOLDUP SYSTEM Administrative FUNCTIONAL TEST shall be repeated until completed successfully.

St. Lucie Plant ODCM Controls

Page 50 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.4 TOTAL DOSE CONTROLS 3.11.4 In accordance with St. Lucie Plant TS 6.8.4.f.1 0), 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 mrems to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

APPLICABILITY:

At all times.

ACTION:

a. With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Control 3.11.1.2.a, 3.11.1.2.b, 3.11.2.2.a, 3.11.2.2.b, 3.11.2.3.a or 3.11.2.3.b, calculations shall be made including direct radiation contributions from the units (including outside storage tanks etc.) to determine whether the above limits of Control 3.11.4 have been exceeded. If such is the case, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in Subpart M of 10 CFR Part 20, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved and the cause of the exposure levels or concentrations.

If the estimated dose(s) exceeds the above limits and if the release condition resulting in violation of 40 Part 190 has not already been corrected, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request and a variance is granted until staff action on the request is complete.

St. Lucie Plant ODCM Controls

Page 51 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.4 TOTAL DOSE (Continued)

SURVEILLANCE REQUIREMENTS 4.11.4.1 Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Controls 4.11.1.2, 4.11.2.2 and 4.11.2.3 and in accordance with the methodology and parameters in the ODCM.

4.11.4.2 Cumulative dose contributions from direct radiation from the units (including outside storage tanks etc.) shall be determined in accordance with the methodology and parameters in the ODCM. This requirement is applicable only under conditions set forth in ACTION a. of Control 3.11.4.

St. Lucie Plant ODCM Controls

Page 52 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.5 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS*

ADMINISTRATIVE CONTROLS 3.11.2.5 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid):

1) Shall be reported to the Commission in the Annual Radioactive Effluent Release Report for the period in' which the evaluation was reviewed by the Facility Review Group (FRG). The discussion of each shall contain:

a)

A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59.

b)

Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; c)

A detailed description of the equipment, components and processes involved and the interfaces with other plant systems; d)

An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; e)

An evaluation of the change which shows the expected maximum exposure to individuals in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto; f)

A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period when the changes are to be made; g)

An estimate of the exposure to plant operating personnel as a result of the change; and h)

Documentation of the fact that the change was reviewed and found acceptable by the FRG.

2) Shall become effective upon review and acceptance by the FRG.

Licensees may choose to submit the information called for in this Administrative Control as part of the annual FUSAR update.

St. Lucie Plant ODCM Controls

Page 53 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.6 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT TO THE COMMISSION*

ADMINISTRATIVE CONTROLS 3.11.2.6 As per Technical Specification 6.9.1.7, a Annual Radioactive Effluent Release Report covering the operation of each unit during the previous 12 months of operation shall be submitted within 60 days after January 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from each unit. The material provided shall be (1) consistent with the objectives outlined in by items a) through f) below, using the example report format in the ODCM and (2) be in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

a. The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

b. The Radioactive Effluent Release Report to be submitted within 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability and precipitation (if measured) or in the form of joint frequency distributions of wind speed, wind direction and atmospheric stability.** This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

In lieu of submission with the Radioactive Effluent Release Report, the licensee has the option of retaining this summary of required meteorological data on site in a file that shall be provided to the NRC upon request.

St. Lucie Plant ODCM Controls

Page 54 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.6 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT TO THE COMMISSION (Continued)

ADMINISTRATIVE CONTROLS 3.11.2.6 (Continued)

b. (Continued) previous calendar year. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY (see TS Figure 5.1-1) during the report period.

All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be included in these reports. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses, or an approximate and conservative method used in lieu of actual meteorological measurements.

The iassessment of radiation doses shall be performed in accordance with the methodology and parameters in the ODCM.

c. Every 2 years using the previous 6 months release history for isotopes, determine the controlling age group for liquid pathways. Every 2 years using the previous 1 year or longer interval (to include a refueling outage) and historical meteorological data determine the controlling age group for gaseous pathways. If changed from current submit change to ODCM to reflect new tables for these groups and use the new groups in subsequent dose calculations.

d. The Radioactive Effluent Release Report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation doses to the likely most exposed MEMBER OF THE PUBLIC from reactor releases for the previous calendar year. Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109 March 1976.

St. Lucie Plant ODCM Controls

Page 55 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS 3/4.11.6 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT TO THE COMMISSION (Continued)

ADMINISTRATIVE CONTROLS 3.11.2.6 (Continued)

e. The Radioactive Effluent Release Reports shall include the following information for each class of solid waste (as defined by 10 CFR Part 61) shipped offsite during the report period:

1.

Volume

2.

Total Curie quantity (specify whether determined by measurement or estimate)

3.

Principal radionuclides (specify whether determined by measurement or estimate)

4. Type of waste (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms)

5.

Type of container (e.g., LSA, Type A, Type B, Large Quantity) and

6.

Solidification agent or absorbent (e.g., cement, urea formaldehyde).

f.

The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

g. The Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the Land Use Census of ODCM Control 3.12.2.

h. The format for an Annual Radioactive Effluent Release Report is provided in ODCM Methodology Section 4.0. The information contained in an annual report shall not apply to any ODCM Control Dose Limit(s) since the methodology for the annual report is based on actual meteorological data, instead of historical conditions that the ODCM Controls and Control required calculations are based on.

St. Lucie Plant ODCM Controls

Page 56 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM CONTROLS 3.12.1 In accordance with St. Lucie Plant TS 6.8.4.g.1), the Radiological Environmental Monitoring Program shall be conducted as specified in Table 3.12-1.

APPLICABILITY:

At all times.

ACTION:

a. With the Radiological Environmental Monitoring Program not being conducted as specified in Table 3.12-1, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Control 3.12.4, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

b. With the confirmed* level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 3.12-2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Plant TS 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose** to a MEMBER OF THE PUBLIC is less than the calendar year limit of Controls 3.11.1.2, 3.11.2.2 or 3.11.2.3.

When more than one of the radionuclides in Table 3.12-2 are detected in the sampling medium, this report shall be submitted if:

concentration (1)

+ concentration (2)

+ > or = 1.0 reporting level (1) reporting level (2)

When radionuclides other than those in Table 3.12-2 are A confirmatory reanalysis of the original, a duplicate or a new sample may be desirable, as appropriate. The results of the confirmatory analysis shall be completed at the earliest time consistent with the analysis but in any case within 30 days.

The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report.

St. Lucie Plant ODCM Controls

Page 57 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM Controls (Continued)

Action b. (Continued) detected and are the result of plant effluents, this report shall be submitted if the potential annual dose, to a MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of Control 3.11.1.2, 3.11.2.2 or 3.11.2.3. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Control 3.12.4.

c. With milk or broad leaf vegetation samples unavailable from one or more of the sample locations required by Table 3.12-1, identify specific locations for obtaining replacement samples and add them within 30 days to the Radiological Environmental Monitoring Program given in the ODCM. The specific locations from which samples were unavailable may then be deleted from the monitoring program.

Pursuant to Control 3.11.2.6, submit in the next Annual Radioactive Effluent Release Report documentation for a change in the ODCM including a revised figure(s) and table for the ODCM reflecting the new location(s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of the new location(s) for obtaining samples.

SURVEILLANCE REQUIREMENTS 4.12.1 The radiological environmental monitoring samples shall be collected pursuant to Table 3.12-1 from the specific locations given in the table and figure(s) in the ODCM and shall be analyzed pursuant to the requirements of Table 3.12-1 and the detection capabilities required by Table 4.12-1.

St. Lucie Plant ODCM Controls

Page 58 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.12-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMa)

NUMBER OF EXPOSURE REPRESENTATIVE PATHWAY SAMPLES AND SAMPLING AND TYPE AND and/or SAMPLE COLLECTION FREQUENCY d) OF SAMPLE LOCATIONSb) c)

FREQUENCYd)

ANALYSIS

1. Direct Radiatione) 27 Monitoring Continuous Gamma exposure rate Locations monitoring with quarterly sample collection quarterly ')

2. Airbome Continuous sampler Radioiodine filter:

Radioiodine and 5 Locations operation with 1-131 analysis weekly Particulates sample collection Particulate Filter:

weekly or more Gross beta radioactivity frequently if analysis >24 hours required by dust following a filter loading change')

Gamma isotopich) analysis of composite 9)

(by location) quarterly

3. Waterborne a)

Surfacek) 1 Locationm" Weekly Gamma isotopic') &

tritium analyses weekly 1 Location n Monthly Gamma isotopich) &

tritium analyses monthly b)

Sediment from 2 Locations Semiannually Gamma isotopich) shoreline analyses semiannually

4. Ingestion a)

Fish and Invertebrates

1) Crustacea 2 Locations Semiannually Gamma isotopich) analyses semiannually

2) Fish 2 Locations Semiannually Gamma isotopic ')

analyses semiannually b)

Food Products

1) Broad leaf 3 Locations')

Monthly when Gamma isotopich) and vegetation available 1-131 analyses monthly

2) Milk 1 Location Quarterly when Gamma isotopich) available St. Lucie Plant ODCM Controls

Page 59 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.12-1 (Continued)

TABLE NOTATIONS

a.

Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment or other legitimate reasons.

If specimens are unobtainable due to sampling equipment malfunction, corrective action shall be taken prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4.

b.

Specific parameters of distance and direction sector from the centerline of one reactor and additional description where pertinent, shall be provided for each sample location required by Table 3.12-1, in Appendix-B and applicable figures.

c.

At times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time.

In these instances suitable alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program.

d.

The following definition of frequencies shall apply to Table 3.12-1 only:

Weekly -

Not less than once per calendar week. A maximum interval of 11 days is allowed between the collection of any two consecutive samples.

Semi-Monthly - Not less than 2 times per calendar month with an interval of not less than 7 days between sample collections. A maximum interval of 24 days is allowed between collection of any two consecutive samples.

Monthly -

Not less than once per calendar month with an interval of not less than 10 days between sample collections.

Quarterly -

Not less than once per calendar quarter.

Semiannually - One sample each between calendar dates (January 1 - June 30) and (July 1 - December 31). An interval of not less than 30 days will be provided between sample collections.

The frequency of analyses is to be consistent with the sample collection frequency.

St. Lucie Plant ODCM Controls

Page 60 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.12-1 (Continued)

TABLE NOTATIONS (Continued)

e.

One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of or in addition to, integrating dosimeters.

For purposes of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters.

f.

Refers to normal collection frequency. More frequent sample collection is permitted when conditions warrant.

g.

Airborne particulate sample filters are analyzed for gross beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and thoron daughter decay. In addition to the requirement for a gamma isotopic on a composite sample a gamma isotopic is also required for each sample having a gross beta radioactivity which is >1.0 pCi per cubic meters and which is also >10 times that of the most recent control sample.

h.

Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

k.

Discharges from the St. Lucie Plant do not influence drinking water or ground water pathways.

m.

Atlantic Ocean, in the vicinity of the public beaches along the eastern shore of Hutchinson Island near the St. Lucie Plant (grab sample)

n.

Atlantic Ocean, at a location beyond influence from plant effluents (grab sample).

p.

Samples of broad leaf vegetation grown nearest each of two different offsite locations of highest predicted annual average ground level D/Q and one sample of similar broad leaf vegetation at an available location 15-30 kilometers distant in the least prevalent wind direction based upon historical data in the ODCM.

[i, j, I (lower case) and o are not used on notation for clarity reasons]

St. Lucie Plant ODCM Controls

Page 61 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 3.12-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS as in pCi/I denotes liter Since no drinking water pathway exists, a value of 30,000 pCi/I is used.

For drinking water samples, a value of 20,000 pCi/I is used; this is 40 CFR Part 141 value.

Applies to drinking water pathway exists, 2 pCi/I is the limit for drinking water.

An equilibrium mixture of the parent daughter isotopes which corresponds to the reporting value of the parent isotope.

St. Lucie Plant ODCM Controls AIRBORNE FOOD ANALYSIS WATER PARTICULATE FISH MILK FOOD pCi/I OR GASES pCi/kg, wet pCi/I P

C t

pCi/m 3 pCi/kg, wet H-3 30,000*

Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr Nb-95***

1-131 2**

0.9 3

100 Cs-134 30 10 1,000 60 1,000 Cs-1 37 50 20 2,000 70 2,000 Ba La1 200 300 La-140"***

Page 62 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE 4.12-1 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS(1 )(2)

LOWER LIMIT OF DETECTION (LLD)(3)

AIRBORNE FOOD WATER PARTICULATE FISH MILK FOOD SEDIMENT pCi/I OR GASES pCi/kg, wet pCi/I PC t

pCi/kg dry pCi/m3 pCi/kg, wetp Gross Beta 4

0.01 H-3 3000*

Mn-54 15 130 Fe-59 30 260 Co-58, 15 130 Co-60 Zn-65 30 260 Zr-95, Nb-95(4 )

15 1-131 1**

0.07 1

60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-1 40, La-140,4) 15 15 No drinking water pathway exists, a value of 2000 pCi/I is for drinking water.

LLD for drinking water samples.

If no drinking water pathway exists, the LLD of gamma isotopic analysis may be used.

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TABLE 4.12-1 (Continued)

TABLE NOTATIONS (1)

This list does not mean that only these nuclides are to be considered. Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4.

(2)

Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

(3)

The LLD is defined for purposes of these controls, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a real signal.

For a particular measurement system, which may include radiochemical separation:

4.66 Sb LLD -

E. V. 2.22 ° Y o exp (-

. AT)

Where:

LLD

=

the a priori lower limit of detection (pico-Curie per unit mass or volume),

Sb

=

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

E

=

the counting efficiency (counts per disintegration),

V

=

the sample size (units of mass or volume),

2.22

=

the number of disintegrations per minute per pico-Curie, Y

=

the fractional radiochemical yield, when applicable, k

=

the radioactive decay constant for the particular radionuclide (sec1) and AT

=

the elapsed time between the midpoint of sample collection and the time of counting (sec).

Typical values of E, V, Y and AT should be used in the calculation.

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TABLE 4.12-1 (Continued)

TABLE NOTATIONS (Continued)

It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4.

(4)

An equilibrium mixture of the parent and daughter isotopes which corresponds to 15 pCi/Liter of the parent isotope.

St. Lucie Plant ODCM Controls

Page 65 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSUS CONTROLS 3.12.2 In accordance with St. Lucie Plant TS 6.8.4.g.2), a Land Use Census shall be conducted and shall identify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence and the nearest garden* of greater than 50 square meters (500 square feet) producing broad leaf vegetation.

APPLICABILITY: At all times.

ACTION:

a. With a Land Use Census identifying a location(s) that yields a calculated dose or dose commitment greater than the values currently being calculated in Control 4.11.2.3, pursuant to Control 3.11.2.6, identify the new location(s) in the next Annual Radioactive Effluent Release Report.

b. With a Land Use Census identifying a location(s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with Control 3.12.1, add the new location(s) within 30 days to the Radiological Environmental Monitoring Program given in the ODCM.

The sampling location(s), excluding the control station location, having the lowest calculated dose or dose commitment(s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was conducted. Pursuant to TS 6.14, submit in the next Annual Radioactive Effluent Release Report documentation for a change in the ODCM including a revised figure(s) and table(s) for the ODCM reflecting the new location(s) with information supporting the change in sampling locations.

Broad leaf vegetation sampling may be performed at the SITE BOUNDARY in each of two different direction sectors with the highest predicted D/Qs in lieu of the garden census. Controls for broad leaf vegetation sampling in Table 3.12-1, Part 4.b., shall be followed, including analysis of control samples.

St. Lucie Plant ODCM Controls

Page 66 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSUS (Continued)

SURVEILLANCE REQUIREMENTS 4.12.2 The Land Use Census shall be conducted during the growing season at least once per 12 months using that information that will provide the best results, such as by a door-to-door survey, aerial survey or by consulting local agriculture authorities. The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4.

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RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM CONTROLS 3.12.3 In accordance with St. Lucie Plant TS 6.8.4.g.3), analyses shall be performed on all radioactive materials, supplied as part of an Interlaboratory Comparison Program that correspond to samples required by Table 3.12-1.

APPLICABILITY: At all times.

ACTION:

a. With analyses not being performed as required above, report the corrective action taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4.

SURVEILLANCE REQUIREMENTS 4.12.3 A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report pursuant to Control 3.12.4. If the Interlaboratory Comparison Program is other than the program conducted by the EPA, then the Interlaboratory Comparison Program shall be described in the ODCM.

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RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.4 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (AREOR)*

ADMINISTRATIVE CONTROLS 3.12.4 In accordance with St. Lucie Plant TS 6.9.1.8, an Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries, interpretations and information based on trend analysis of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided in the AREOR shall be consistent with the objectives outlined below and with Sections IV.B.2, IV.B.3 and IV.C of Appendix I to 10 CFR Part 50.

The Annual Radiological Environmental Operating Reports shall include summaries, interpretations and information based on trend analysis of the results of the radiological environmental surveillance activities for the report period, including a comparison, as appropriate, with preoperational studies, with operational controls and with previous environmental surveillance reports and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of land use census required by Control 3.12.2.

The Annual Radiological Environmental Operating Reports shall include the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the Table and Figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following:

a summary description of the radiological environmental monitoring program; at least two legible maps** covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of the Interlaboratory Comparison Program, required by Control 3.12.3; discussion of all deviations from the sampling schedule of Table 3.12-1; and discussion of all analyses in which the LLD required by Table 4.12-1 was not achievable.

A single submittal may be made for multiple unit station.

One map shall cover stations near the SITE BOUNDARY; a second shall include the more distant stations.

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BASES for the CONTROLS AND SURVEILLANCE REQUIREMENTS NOTE The BASES contained in succeeding pages summarize the reasons for the Controls in Section 3.0 and 4.0, but are not part of these Controls.

St. Lucie Plant ODCM Controls - Bases

Page 70 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

INSTRUMENTATION BASES 3.3.3.9 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluent during actual or potential releases of liquid effluents.

The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

3.3.3.10 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluent during actual or potential releases of gaseous effluents. The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

St. Lucie Plant ODCM Controls - Bases

Page 71 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 3/4.11 RADIOACTIVE EFFLUENTS BASES 3/4.11.1 LIQUID EFFLUENTS 3/4.11.1.1 CONCENTRATION This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table 2, Column 2. This limitation provides additional assurance that the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II.A design objectives of Appendix 1, 10 CFR Part 50, to a MEMBER OF THE PUBLIC and (2) the limits of 10 CFR Part 20. The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its ECL in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

This control applies to the release of radioactive materials in liquid effluents from all units at the site.

The required detection capabilities for radioactive materials in liquid waste samples are tabulated in terms of the lower limits of detection (LLDs). Detailed discussion of the LLD and other detection limits can be found in Currie, L.A., Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements, NUREG/CR-4007 (September 1984) and in the HASL Procedures Manual, HASL-300.

3/4.11.1.2 DOSE This control is provided to implement the requirements of Sections II.A, III.A and IV.A of Appendix 1, 10 CFR Part 50. The Control implements the guides set forth in Section II.A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept as low as is reasonably achievable. Also, for fresh water sites with drinking water supplies that can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR Part 141. The dose calculation St. Lucie Plant ODCM Controls - Bases

Page 72 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 3/4.11 RADIOACTIVE EFFLUENTS (Continued)

BASES 3/4.11.1 LIQUID EFFLUENTS (Continued) 3/4.11.1.2 DOSE (Continued) methodology and parameters in the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, Revision 1, October 1977 and Regulatory Guide 1.113, Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I, April 1977.

This control applies to the release of radioactive materials in liquid effluents from each unit at the site. For units with shared Radwaste Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system.

3/4.11.1.3 LIQUID RADWASTE TREATMENT SYSTEM The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept as low as is reasonably achievable. This control implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objective given in Section II.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix 1, 10 CFR Part 50 for liquid effluents.

This control applies to the release of radioactive materials in liquid effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system.

St. Lucie Plant ODCM Controls - Bases

Page 73 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS BASES 3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 DOSE RATE This control is provided to ensure that the dose at any time at and beyond the SITE BOUNDARY from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 to UNRESTRICTED AREAS. The annual dose limits are the doses associated with the concentration of 10 CFR Part 20, Appendix B, Table 2, Column I. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either within or outside the SITE BOUNDARY, to an annual average concentration exceeding the limits specified in Appendix B, Table 2 of 10 CFR Part 20 (Subpart D of 10 CFR Part 20).

For MEMBERS OF THE PUBLIC who may at times be within the SITE BOUNDARY, the occupancy of that MEMBER OF THE PUBLIC will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrems/year to the total body or to less than or equal to 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrems/year.

This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

The required detection capabilities for radioactive materials in gaseous waste samples are tabulated in terms of the lower limits of detection (LLDs). Detailed discussion of the LLD and other detection limits can be found in Currie, L. A., Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements, NUREG/CR-4007 (September 1984) and in the HASL Procedures Manual, HASL-300.

St. Lucie Plant ODCM Controls - Bases

Page 74 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS BASES 3/4.11.2.1 DOSE - NOBLE GASES This control is provided to implement the requirements of Sections II.B, III.A and IV.A of Appendix 1, 10 CFR Part 50. The control implements the guides set forth in Section I.B of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept as low as is reasonably achievable.

The Surveillance Requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The dose calculation methodology and parameters established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, Revision 1, October 1977 and Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Cooled Reactors, Revision 1, July 1977.

The ODCM equations provided for determining the air doses at and beyond the SITE BOUNDARY are based upon the historical average atmospheric conditions.

This control applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the gaseous effluents from the shared system are to be proportioned among the units sharing that system.

3/4.11.2.3 DOSE - IODINE-131, IODINE-133, TRITIUM AND RADIOACTIVE MATERIAL IN PARTICULATE FORM This control is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix 1, 10 CFR Part 50. The Controls are the guides set forth in Section II.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept as low as is reasonably achievable. The ODCM calculational methods specified in the St. Lucie Plant ODCM Controls - Bases

Page 75 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS BASES 3/4.11.2.1 DOSE - NOBLE GASES (Continued) 3/4.11.2.3 DOSE - IODINE-131, IODINE-133, TRITIUM AND RADIOACTIVE MATERIAL IN PARTICULATE FORM (Continued)

Surveillance Requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject material are consistent with the methodology provided in Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, Revision 1, October 1977 and Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors, Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate controls for Iodine-1 31, Iodine-1 33, tritium and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the existing radionuclide pathways to man in the areas at and beyond the SITE BOUNDARY. The pathways that were examined in the development of the calculations were: (1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man and (4) deposition on the ground with subsequent exposure of man.

This control applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

St. Lucie Plant ODCM Controls - Bases

Page 76 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS BASES 3/4.11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM The OPERABILITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST TREATMENT SYSTEM ensure that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept as low as is reasonably achievable. This control implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objective given in Section II.D of Appendix I to 10 CFR Part

50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Section II.B and IL.C of Appendix 1, 10 CFR Part 50 for gaseous effluents.

This control applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

3/4.11.2.5 NOT USED 3/4.11.2.6 NOT USED 3/4.11.3 NOT USED 3/4.11.4 TOTAL DOSE This control is provided to meet the dose limitations of 10 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525.

The control requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and to radiation from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems. For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix I,and if direct radiation doses from the units (including outside storage tanks, etc.) are kept small. The Special Report will describe a course of action that should result in the limitation St. Lucie Plant ODCM Controls - Bases

Page 77 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

RADIOACTIVE EFFLUENTS BASES 3/4.11.4 TOTAL DOSE (Continued) of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits.

For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 kilometers must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 and Subpart M of 10 CFR Part 20, is considered to be a timely request and fulfills the requirements of 40 CFR Part 190 until NRC staff action is completed.

The variance only relates to the limits of 40 CFR Part 190 and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in Controls 3.11.1.1 and 3.11.2.1.

An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.

St. Lucie Plant ODCM Controls - Bases

Page 78 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE NO. C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM) 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING BASES 3/4.12.1 MONITORING PROGRAM The Radiological Environmental Monitoring Program required by this control provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposure of MEMBERS OF THE PUBLIC resulting from the plant operation. This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and thereby supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring, Revision 1, November 1979. The initially specified monitoring program will be effective for at least the first three years of commercial operation. Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table 4.12-1 are considered optimum for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Detailed discussion of the LLD and other detection limits can be found in Currie, L. A.,

Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements, NUREG/CR-4007 (September 1984) and in the HASL Procedures Manual, HASL-300.

3/4.12.2 LAND USE CENSUS This control is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made if required by the results of this census.

The best information from the door-to-door survey, from aerial survey or from consulting with local agricultural authorities shall be used.

St. Lucie Plant ODCM Controls - Bases

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RADIOLOGICAL ENVIRONMENTAL MONITORING BASES 3/4.12.2 LAND USE CENSUS (Continued)

This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50.

Restricting the census to gardens of greater than 50 square meters provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kilograms/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child.

To determine this minimum garden size, the following assumptions were made: (1) 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage) and (2) a vegetation yield of 2 kilograms per square meter.

3/4.12.3 INTERLABORATORY COMPARISON PROGRAM This requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

St. Lucie Plant ODCM Controls - Bases

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METHODOLOGY SECTION METHODOLOGY for the CONTROLS AND SURVEILLANCE REQUIREMENTS

Page 81 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION GLOSSARY OF COMMONLY USED TERMS IN METHODOLOGY SECTION DB CC or cc Ci C,

CFR Control(s)

Dose Dose Factor Dose Pathway Dose Rate (D/Q)

ECL Dose from Beta Radiation Cubic centimeter Curies - a unit of radioactivity see gCi Activity or concentration of a nuclide in the release source. Units of gCi, gCi/cc or gCi/ml Code of Federal Regulations Regulations for operating, controlling, monitoring and reporting radioactive effluent related activity as indicated by the Controls Section of the ODCM.

The exposure, in mrem or mrad, the organ or the individual receives from radioactive effluents Normally, a factor that converts the effect of ingesting radioactive material into the body, to dose to a specific organ. Body elimination, radioactive decay and organ uptake are some of the factors that determine a dose factor for a given nuclide A specific path that radioactive material physically travels through prior to exposing an individual to radiation. The Grass-Cow-Milk Infant is a dose pathway The dose received per unit time A long term D over Q - a factor with units of 1/M2 which describes the deposition of particulate matter from a plume at a point downrange from the source. It can be thought of as what part of the cloud is going to fallout and deposit over one square meter of ground. (See Appendix C).

Effluent Concentration Limit Final Updated Safety Analysis Report.

FUSAR

Page 82 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION GLOSSARY OF COMMONLY USED TERMS IN METHODOLOGY SECTION (continued)

Y A gamma photon - The dose from Gammas in air, etc.

Ground Plane H-3 Radioactive material deposited uniformly over the ground emits radiation that produces an exposure pathway when an individual is standing, sitting, etc., in the area. It is assumed that an adult receives the same exposure as an infant, regardless of the physical height differences. Only the whole body is considered for the ODCM.

Hydrogen-3 or Tritium, a weak Beta emitter 1&8DP Radioiodines and particulates with half-lives greater than 8 days Cubic Meters Square Meters m

2 nuclide For the purposes of this manual, a radioactive isotope.

Nuclide (i) signifies a specific nuclide, the 1st, 2nd, 3rd one under consideration. If nuclide (i) is 1-131, then the Mi (dose factor) under consideration should be M,.131 for example.

For the ODCM either the bone, liver, thyroid, kidney, lung, GI-LLI or the Whole Body. Whole Body is considered an organ for ease of writing the methodology in the ODCM.

Organ pCi 1 pico-Curie = 1.E-12 Curies.

(Q Dot),

Q, Radioiodines (Q Dot), - Denotes a release rate in giCi/sec for nuclide (i).

Denotes [tCi of nuclide (i) released over a specified time interval.

Iodine-131 and Iodine 1-133 for gaseous release pathways.

Page 83 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION GLOSSARY OF COMMONLY USED TERMS IN METHODOLOGY SECTION (continued)

Receptor The individual receiving the exposure in a given location or who ingests food products from an animal for example. A receptor can receive dose from one or more pathways.

Release Source(s)

A subsystem, tank or vent where radioactive material can be released independently of other radioactive release points.

TS The St. Lucie Plant Standard Technical Specifications Total Body Same as Whole Body in Control Statements

.Ci micro Curies. 1 jiCi = 10-6 Curies. The gCi is the standard unit of radioactivity for all dose calculations in the ODCM.

(X/Q)

A long term Chi over Q. It describes the physical dispersion characteristics of a semi-infinite cloud of noble gases as the cloud traverses downrange from the release point. Since Noble Gases are inert, they do not tend to settle out on the ground. (See Appendix C).

(X/Q)D A long term Depleted Chi over Q. It describes the physical dispersion characteristics of a semi-infinite cloud of radioactive iodines and particulates as the cloud travels downrange. Since lodines and particulates tend to settle out (fallout of the cloud) on the ground, the (X/Q)D represents what physically remains of the cloud and its dispersion qualities at a given location downrange from the release point. (See Appendix F).

dt, At or delta t A specific delta time interval that corresponds with the release interval data etc.

Page 84 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.0 LIQUID RELEASES METHODOLOGY

Page 85 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.1 Radioactive Liquid Effluent Model Assumptions The FUSAR contains the official description of the site characteristics. The description that follows is a brief summary for dose calculation purposes:

The St. Lucie Plant is located on an island surrounded on two sides by the Atlantic Ocean and the Indian River, an estuary of the Atlantic Ocean.

Normally, all radioactive liquid releases enter the Atlantic Ocean where the Circulating Water Discharge Pipe terminates on the ocean floor at a point approximately 1200 feet offshore (Figure 1-1 Point "L"). No credit is taken for subsequent mixing of the discharge flume with the ocean. The diffusion of radioactive material into the ocean is dependent on the conditions of tide, wind and some eddy currents caused by the Gulf Stream. The conditions are sufficiently random enough to distribute the discharges over a wide area and no concentrating effects are assumed.

There are no direct discharge paths for liquid effluents to either of the north or south private property boundary lines. The Big Mud Creek (part of the Indian River) does connect to a normally locked shut dam, that is intended to provide an emergency supply of circulating water to the Intake Cooling Water Canal in the event a Hurricane causes blockage of the Intake Canal. No radioactive water could be discharged directly into the Intake Cooling Water Canal because all plant piping is routed to the discharge canal and no back flow can occur. Consult the FUSAR for a detailed description of characteristics of the water bodies surrounding the plant site.

Only those nuclides that appear in the Liquid Dose Factor Tables will be considered for dose calculation.

Page 86 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.2 Determining the Fraction F of 10 CFR Part 20 ECLs Limits for A Liguid Release Source Discussion - Control 3.11.1.1 requires that the sampling and analysis results of liquid waste (prior to discharge) be used with calculation methods in the in-plant procedures to assure that the concentration of liquid radioactive material in the unrestricted areas will not exceed ten times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2. Chemistry Procedure COP-01.05 "Processing Aerated Liquid Waste" provides instruction for ensuring batch release tanks will be sampled after adequate mixing. This section presents the calculation method to be used for this determination. This method only addresses the calculation for a specific release source. The in-plant procedures will provide instructions for determining that the summation of each release source's F values do not exceed the site's 10 CFR Part 20 ECL. The values for release rate, dilution rate, etc., will also have to be obtained from in-plant procedures. The basic equation is:

R n

C, D

i=1 (ECL),

Where:

FL

=

the fraction of 10 CFR Part 20 ECL that would result if the release source was discharged under the conditions specified.

R

=

The undiluted release rate in gpm of the release source.

Liquid Rad Waste = 170 gpm for Waste Monitor Tank Steam Generator = 125 gpm/Steam Generator Liquid Rad Waste = 60 gpm for AWST #2 Liquid Rad Waste = 60 gpm for Laundry Drain Pumps 2A/2B D

=

The dilution flow in gpm of Intake Cooling Water or Circulating Water Pumps Intake Cooling flow is 14,500 gpm/pump Circulating Water flow is 121,000 gpm/pump C

=

The undiluted concentration of nuclide (i) in gCi/ml from sample assay (ECL),

=

The Effluent Concentration Limit of nuclide (i) in gCi/ml from Table L-1. For dissolved or entrained noble gases the ECL value is 2 X 10.4 Ci/ml for the sum of all gases.

Page 87 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.2 (continued)

The fraction of the 10 CFR Part 20 ECL limit may be determined by a nuclide-by-nuclide evaluation or for purposes of simplifying the calculation by a cumulative activity evaluation. If the simplified method is used, the value of 3 X 10"' gCi/ml (unidentified ECL value) should be substituted for (ECL), and the cumulative concentration (sum of all identified radionuclide concentrations) or the gross concentration should be substituted for C,. As long as the diluted concentration (Ctota R/D) is less than 3 X 10.8 p.Ci/ml, the nuclide-by-nuclide calculation is not required to demonstrate compliance with the 10 CFR Part 20 ECL.

The following section provides a step-by-step procedure for determining the ECL fraction.

1.

Calculation Process for Solids A.

Obtain from the in-plant procedures, the release rate value (R) in gpm for the release source.

B.

Obtain from the in-plant procedures, the dilution rate (D) in gpm. No credit is taken for any dilution beyond the discharge canal flow.

C. Obtain (C,), the undiluted assay value of nuclide (i), in iiCi/ml. If the simplified method is used, the cumulative concentration (Ctotal) is used.

D.

From Table L-1, obtain the corresponding (ECL) for nuclide (i) in gCi/ml.

The value of 3 X 10-8 jiCi/ml should be used for the simplified method.

E.

Divide C, by (ECL), and write down the quotient F.

If the simplified method is used, proceed to the next step. If determining the ECL fraction by the nuclide-by-nuclide evaluation, repeat steps 1.2.1.C through 1.2.1.E for each nuclide reported in the assay, for H3 from previous month composite and for SR89/90 and Fe55 from previous quarter composite with known results.

Page 88 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.2 (continued)

1.

(continued)

G. Add each C/(ECL) quotient from step 1.2.1.E and solve for FL as follows:

R n

C, FL= -D i=1 (ECL) i FL = a unit-less value where:

the value of FL could be < or >1. The purpose of the calculation is to determine what the initial value of FL is for a given set of release conditions.

H. The FL value just obtained is for one release pathway. The TS and ODCM control 3.11.1.1 allow for a site limit of FL less than or equal to 10.

Chemistry Procedure COP-01.05 administratively controls each pathway's allocation. Compare your FL result with the administrative control for the release pathway in COP-01.05.

2.

Calculation Process for Gases in Liquid A.

Sum the gCi/ml of each noble gas activity reported in the release.

B.

The values of R and D from 1.2.1 above shall be used in the calculations below:

Fg -

(sum of 1.2.2.A) lCiml x R 1

D C.

Fg shall be less than 2 X 10-4 pCi/ml for the site for all releases in progress.

Each release point will be administratively controlled. Consult COP-01.05 procedure for instructions.

Page 89 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.3 Determininq Setpoints for Radioactive Liquid Effluent Monitors 1.3.1 Setpoints for Batch Liquid Release Monitors channel numbers R6627 and 301 on Table 3.3-14, Radioactive Effluent Monitor Setpoint Basis, are the Batch Liquid Effluent Monitors.

Discussion - Control 3.3.3.9 requires that the liquid effluent monitoring instrumentation alarm/trip setpoints be set to initiate an alarm or trip so that the radioactivity concentration in water in the unrestricted area does not exceed the concentration of 10 CFR Part 20, Appendix B, Table 2 as a result of radioactivity in liquid effluents (Control 3.11.1.1).

Gross cpm vs. total liquid activity curves are available for Batch Liquid Effluent Monitors based on a composite of real release data. A direct correlation between gross cpm and the concentrations that would achieve 10 CFR Part 20 ECL levels in the discharge canal can be estimated. The 1978 liquid release data from annual reports was used to determine the average undiluted release concentration. These concentrations were then projected to a diluted concentration in the discharge canal assuming a 1 gpm release rate and a constant dilution flow of 121,000 gpm from 1 circ. water pump. This diluted activity was divided by the nuclide's respective 10 CFR Part 20 ECL value (Table L-1) to obtain the Mi column on the table that follows:

Page 90 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.3 (continued)

TABLE 1.3 NUCLIDE SYMBOL 1978 UNDILUTED giCi/mf1 M,2 (no units) 1-131 4.43 E-5 3.66 E-4 1-132 2.23 E-7 1.84 E-8 1-133 3.17 E-6 3.74 E-6 1-135 1.31 E-6 3.61 E-7 Na-24 1.72 E-7 2.84 E-8 Cr-51 2.51 E-5 4.15 E-7 Mn-54 5.64 E-6 1.55 E-6 Mn-56 1.11 E-9 1.31 E-10 Co-57 3.69 E-7 5.08 E-8 Co-58 1.51 E-4 6.24 E-5 Fe-59 2.92 E-6 2.41 E-6 Co-60 3.66 E-5 1.01 E-4 Zn-65 4.55 E-7 7.52 E-7 Ni-65 8.23 E-7 6.8 E-8 Ag-110 1.96 E-6 2.70 E-6 Sn-113 5.75 E-7 1.58 E-7 Sb-1 22 2.15 E-6 1.78 E-6 Sb-1 24 8.40 E-6 9.92 E-6 W-187 3.51 E-6 9.67 E-7 Np-239 1.57 E-7 6.49 E-8 Br-82 3.64 E-7 7.52 E-8 Zr-95 2.82 E-5 1.17 E-5 Zr-97 4.05 E-6 3.72 E-6 Mo-99 3.24 E-6 1.34 E-6 Ru-1 03 3.84 E-8 1.06 E-8 Sb-1 25 2.26 E-6 6.23 E-7 Cs-134 2.14 E-5 1.97 E-4 Cs-1 36 7.82 E-7 1.08 E-6 Cs-1 37 4.85 E-5 4.01 E-4 Ba-140 6.44 E-7 6.65 E-7 Ce-1 41 3.04 E-8 8.38 E-9 Ce-1 44 2.37 E-6 6.53 E-6 Atot=

4.01 E-4 MTotai=

1.18 E-3 (1) 1978 Undiluted Release Volume = 7 E 9 ml.

(release rate)

(2)

M, - 1978 Undil. Act Nuclide (J) X 1 gpm ECL, (from Table L-1) 121000 gpm ( dil ra te)

Page 91 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.3 (continued)

ATot is the total average gCi/ml concentration of the reference mixture and MTot is the fraction of the MPC of all nuclides for the release conditions specified. Dividing ATot by MTot yields AMax, which is the maximum total activity concentration equivalent to the ECL limit for the nuclide distribution typical of radwaste discharges. The Technical Specifications allow 10 times the ECL limit where the Site Limit is 10 times AMax as follows:

A Max ATot

_ 4.01 E-4 = 0.34 gCi/ml = ECL Limit MTot 1.18 E-3 Site Limit = 10 x AMax = 10 x 0.34 = 3.4 gCi/ml To provide conservative administrative control, AMax of 0.34 gCi/ml should be used as follows:

1.

If the effluent monitor requires counts per minute units, a (Cmax) value in cpm should be obtained for the Am. (0.34 gCi/ml) from the release sources radioactive liquid effluent monitor curve of cpm vs. [iCi/ml.

NOTE This setpoint is for a specified release of 1 gpm into 121000 gpm dilution flow.

2.

For establishing the setpoint prior to liquid radwaste discharges, the Ama (or Cmax) will be adjusted as needed to account for actual release conditions (i.e., actual design maximum discharge flow rate, dilution flow rate and the contribution of dissolved and entrained Nobles Gas Activity to the Monitor Activity Level).

Page 92 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.3 (continued) 1.3.2 Setpoints for Continuous Liquid Release Monitors Discussion - The activity mixture described in 1.3.1 for Liquid Batch Release Monitors cannot be used for Continuous Liquid Pathways since the Steam Generator (S/G) Blowdown Secondary Side is subject to what the current Reactor Coolant System (RCS) activity and primary-to secondary leakage exist at any time. Although S/G blowdown is not normally aligned to the Site Liquid Radwaste Release Point (Figure 1-1),

the monitor setpoints will be based on the ODCM maximum design S/G blowdown rate of 125 gpm with 1 Circulating Water Pump (CWP) 121,000 gpm in operation. The ODCM and COP-01.05, Processing Liquid Waste assume that the fraction of solids entering the Discharge Canal to the site release point are controlled less than or equal to 1.0, with batch release using 80% and the remaining 20% allocated to continuous sources on site. The actual site limit for solids is 10 times the concentration specified in 10 CFR Part 20, therefore a conservation factor of 10 is already included in the administrative site limit.

Since source in-leakage to a S/G cannot be controlled, a High alarm monitor setpoint is calculated based on one S/G releasing to the discharge canal at design blowdown rate while attaining the 20 percent of the site limit (FL) assuming all the gross solid activity is 1-131. The contribution from Dissolved and Entrained Gases is assumed to be zero with all of the gaseous activity going to the Steam Condenser and Air Ejector pathway.

FL at 20%

= 0.2 = Design blowdown rate x 1-131 uCi/mI (S/G) 1 1 CWP Dilution rate 1-131 uCi/ml (Table L-1ECL)

FL at 20%

0.2

125 qal/min x

1-131 uCi/ml (S/G) 1 121,000 gal/min 1.E-06 uCi/mI (1-131 Table L-1ECL)

Solving for the S/G High Alarm Setpoint 1-131 Activity, 1-131 uCi/mI (S/G) = -2E-04 uCi/ml 1-131 is the maximum S/G activity that could be allowed such that 20 percent of the administrative discharge canal limit would not be exceeded.

Page 93 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.3 (continued) 1.3.2 (continued)

This S/G Monitor High Alarm Setpoint activity may be converted to cpm using Liquid Monitor uC/ml to cpm conversion constants.

This Setpoint is conservative given that the actual Liquid Site Limit is a factor of ten times higher than the administrative limit used for calculation purposes, that 1-131's ECL is conservative vs other isotope mixtures, and that it is unlikely that more than one S/G would be allowed to operate with a 20 gallon per day primary-to-secondary leak rate.

1.4 Determining the Dose for Radioactive Liquid Releases Discussion - Control 3.11.1.2 requires calculations be performed at least once per 31 days to verify that cumulative radioactive liquid effluents do not cause a dose in excess of 1.5 mrem to the whole body and 5 mrem to any organ during any calendar quarter and not in excess of 3 mrem to the whole body and 10 mrem to any organ during any calendar year. This section presents calculational method to be used for this verification.

This method is based on the methodology suggested by sections 4.3 and 4.3.1 of NUREG-0133 Revision 1, November, 1978. The dose factors are a composite of both the fish and shellfish pathways so that the fish-shellfish pathway is the only pathway for which dose will be calculated. The dose for adult, child and teenager can also be calculated by ýthis method provided that their appropriate dose factors are used for the organ of interest. An infant is excluded from Liquid Dose Pathway at St. Lucie since they do not eat fish-shellfish. The effluent supervisor will track which age group is the controlling (most restrictive) age group (see control 3.11.2.6.c). Only those nuclides that appear in the Tables of this manual will be considered.

Page 94 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.4 (continued)

1.

This method provides for a dose calculation to the whole body or any organ for a given age group based on real release conditions during a specified time interval for radioactive liquid release sources. The equation is:

AT dt1 Q,I (DF)1 Where:

D1

=

dose commitment in mrem received by organ T of age group (to T

be specified) during the release time interval dt1.

A,-

=

the composite dose factor for the fish-shellfish pathway for nuclide (i) for organ T of age group (to be specified). The A,, values listed in the Tables in this manual are independent of any site specific information and have the units mrem-ml jiCi-hr dt1

=

the number of hours that the release occurs.

Q,

=

The total quantity of nuclide (i) release during dt1 (uiCi)

(DF),

=

The total volume of dilution that occurred during the release time period dt, (i.e., the circulating water flow times time)

The doses associated with each release may then be summed to provide the cumulative dose over a desired time period (e.g., sum all doses for release during a 31 day period, calendar quarter or a year).

Dtotal, = I D1, Where:

DT the total dose commitment to organ T due to all releases during the T

desired time interval (mrem)

Page 95 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.4 (continued)

1.

(continued)

NOTE Table 1.4 may be used for compiling the dose accounting.

A.

Determine the time interval dt, in hours that the release took place. For once per 31 day dose calculations dt, would be for the entire month's hours.

For quarterly dose calculations dt, would be the hours in the quarter, and for annual dose calculations dt, would be the hours in the year. If required, dt, may be hours of duration of a single release to evaluate a batch release.

B.

Obtain (DF), for the time period dt, from Liquid Waste Management Records for the release source(s) of interest.

C. Obtain Q,I for nuclide (i) for the time period dt1 from the Liquid Waste Management Records D.

Obtain A, from the appropriate Liquid Dose Factor Table Age Group Dose Factor Table Infant N/A Child L-4 Teen L-3 Adult L-2

Page 96 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.4 (continued)

1.

(continued)

TABLE 1.4 FISH AND SHELLFISH PATHWAY TIME/DATE START:

_/

/

TIME/DATE STOP:

/

HOURS TOTAL DILUTION VOLUME:

mIs AGE GROUP:-

ORGAN:

DOSE FACTOR TABLE #:

TOTAL DOSET =

mrem E.

Solve for Dose (i)

QIdt A, Dose (i) 0, 1

-T (DO) 1 NUCLIDE (i)

C, (pCi)

AU-I DOSE (i) mrem ii t

4-4-

t

+

1-I 4-

+

1

-I.

+

I I

i i

1-i I

4 i

I i

i I

I

-

I I-1 4

Page 97 of 230 ST. LUCIE PLANT CHEMISTRY OPERATING PROCEDURE C-200, REVISION 25 OFFSITE DOSE CALCULATION MANUAL (ODCM)

METHODOLOGY SECTION 1.4 (continued)

1.

(continued)

F.

For the age group(s) of interest, repeat steps 1.4.1.C through 1.4.1.E for each nuclide reported and each organ required.

G. For the age group(s) of interest, sum the Dose (i) values to obtain the total dose to organ T from the fish-shellfish pathway.

1.5 Proiecting.Dose for Radioactive Liquid Effluents Discussion - Control 3.11.1.3 requires that appropriate subsystems of the liquid radwaste treatment system be used to reduce radioactive material in liquid effluents when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see TS Figure 5.1-1) would exceed 0.06 mrem to the whole body or 0.2 mrem to any organ in a 31 day period. The following calculation method is provided for performing this dose projection. The method is based on dose as calculated in section 1.4 with the adult as the bases for projecting.

1.

For the controlling age group obtain the latest result of the monthly calculation of the whole body dose and the highest organ dose. These doses can be obtained from the in-plant records.

2.

Divide each dose by the number of days the reactor plant was operational during the month.

3.

Multiply the quotient of each dose by the number of days the reactor plant is projected to be operational during the next month. The products are the projected dose for the next month. These values should be adjusted as needed to account for any changes in failed fuel or other identifiable operating conditions that could significantly alter the actual releases.

4.

If the projected dose is greater than 0.06 mrem to the whole body or greater than 0.2 mrem to the adults highest exposed organ, the liquid radwaste system shall be used.

ML030690146

Text

Title:

1.0 TITLE

0.2

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