ML061160297

ISFSI Annual Radioactive Effluent Release Report

ML061160297
Person / Time
Site:	North Anna
Issue date:	04/17/2006
From:	Jennifer Davis Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
06-293
Download: ML061160297 (122)

Text

{{#Wiki_filter:VIRGINIA ELE CTRIC ANI) POWER COMPANY RICi[MOND, VIRGINIA 23261 April 17, 2006 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Serial No. 06-293 NAPS/JRP Docket Nos. 50-338 50-339 72-16 License Nos. NPF-4 NPF-7 SNM-2507 Gentlemen: VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Annual Radioactive Effluent Release Report for the January 1, 2005 through December 31, 2005, reporting period. It is provided pursuant to North Anna Units l and 2, Technical Specifications 5.6.3 [10 CFR 50.36a] and North Anna Independent Spent Fuel Storage Installation (ISFSI) Technical Specification 5.5.2.c [10 CFR 72.44(d)(3)]. If you have any questions or require additional information, please contact Page Kemp at (540) 894-2295. Very truly ours, . Davis te Vice President Enclosure Commitments made in this letter: None _:
) t5 48

cc: U. S. Nuclear Regulatory Commission Region 11 Atlanta Federal Center '31 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Director, Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT NORTH ANNA POWER STATION (JANUARY 01, 2005 TO DECEMBER 31, 2005) PREPARED BY:/ Supervisor Radiological Analysis REVIEWED BY:- Supervisor Health Physics Technical Services APPROVED BY:____ Manager Radiological Protection and Chemistry

FORWARD This report is submitted in accordance with North Anna Unit 1 and 2 Technical Specification 5.6.3 and North Anna Independent Spent Fuel Storage Installation (ISFSI) Technical Specification 5.5.2.c and 10CFR72.44(d)(3).

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE NORTH ANNA POWER STATION JANUARY 01, 2005 TO DECEMBER 31, 2005 INDEX Sublect Section No. Page 1 2 3 4 EXECUTIVE

SUMMARY

PURPOSE AND SCOPE................................... DISCUSSION.................................................. SUPPLEMENTAL INFORMATION....................... Effluent Release Data................................. Annual and Quarterly Doses........................ Revisions to Offsite Dose Calculation Manual (ODCM)........................................ Major Changes to Radioactive Liquid, Gaseous, and Solid Waste Treatment Systems.................................................. Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation........................................ Unplanned Releases................................. Lower Limits of Detection (LLD) for Effluent Sample Analysis........................... 1 - 2 2 3 - 4 4 - 5 6 7 8 9 10 11 12 - 13

1.0 EXECUTIVE

SUMMARY

The Annual Radioactive Effluent Release Report describes the radioactive effluent control program conducted at the North Anna Power Station and Independent Spent Fuel Storage Installation (ISFSI) during the 2005 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from the North Anna Power Station and ISFSI in accordance with R;G. 1.21 during the period January 1 through December 31, 2005, and includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents. There were no releases from the ISFSI during 2005. There was one gaseous unplanned release, but no unplanned liquid release, meeting the reporting criteria of section 6.7.2.a.3 of the Offsite Dose Calculation Manual during this reporting period. Based on the 2005 effluent release data, 10 CFR 50, Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The results of these pathway dose calculations indicate the following:

a.

The total body dose due to liquid effluents was 3.81 E-1 mrem, which is 6.35E+0% of the dose limit and the critical organ dose due to liquid effluents was 4.04E-1 mrem, which is 2.02E+0% of the dose limit.

b.

The air dose due to noble gases was 4.99E-4 mrad gamma, which is 2.49E-3% of the annual gamma dose limit, and 8.90E-4 mrad beta, which is 2.23E-3% of the annual beta dose limit.

c.

The critical organ dose for 1-131, 1-133, H-3, and Particulates with half-lives greater than 8 days was 8.26E-2 mrem, which is 2.75E-1% of the annual dose limit. There was no major change to radioactive liquid and solid waste treatment systems during this reporting period. Changes to the gaseous waste treatment system are explained in Attachment 4. There were 2 revisions to the Offsite Dose Calculation Manual during this reporting period. Attachment 3 provides the changes to VPAP-2103N. 1

1.0 EXECUTIVE

SUMMARY

(cont.) Based on the levels of radioactivity observed during this reporting period and the dose calculations performed, the operations of the North Anna Nuclear Power Station Units 1, 2, and ISFSI have resulted in negligible dose consequences to the maximum exposed member of the public in unrestricted areas. 2.0 PURPOSE AND SCOPE The Radioactive Effluent Release Report includes, in Attachment 1, a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, "Measuring, Evalualing, 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 for Table 1 and 2 and on an annual basis on Table 3. The report submitted before May 1st of each year includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site during the previous calendar year. The report also includes a list of unplanned releases during the reporting period, in. As reqL ired by Technical Specification, changes to the Offsite Dose Calculation Manual (ODCM) for the time period covered by this report are included in Attachment 3. Major clanges to radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, section 6.7.2.a.4. Information to support the reason(s) for the change(s) and a summary of the 10 CFR 50.59 evaluation are included. In lieu of reporting major changes in this report, major changes to the radioactive waste treatment systems may be submitted as part of FSAR updates. As required by the ODCM, sections 6.2.2.b.2 and 6.3.2.b.3, a list and explanation for the inoperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 of this report. 2

3.0 DISCUSSION The basis for the calculation of the percent of Technical Specification for the critical organ in Table 1A of is the ODCM, section 6.3.1, which requires that the dose rate for iodine-131 & ioiine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days shall be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary. The critical organ is the child's thyroid via the inhalation pathway. The basis for the calculation of percent of Technical Specification for the total body and skin in Table 1 A of is the ODCM, section 6.3.1, which requires that the dose rate for noble gases to areas at or beyond the site boundary shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin. The basis for the calculation of the percent of Technical Specification in Table 2A in Attachment 1 is the ODCM section 6.2.1, which states that the concentrations of radioactive material released in liquid effluents to unrestricted areas shall be limited to 10 times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.OE-4 ItCi/ml. Percent of Technical Specification calculations are based on the total gaseous or liquid effluents released for that respective quarter. The annual and quarterly doses, as reported in Attachment 2, were calculated according to the,methodology presented in the ODCM. The beta and gamma air doses due to noble gases released from the site were calculated at site boundary. The maximum exposed member of the public from the releases of airborne iodine-1 31 & iodine-1 33, tritium and all radionuclides in particulate form with half-lives greater than 8 days, is defined as a child, exposed through the vegetation pathway, with the critical organ being the thyroid gland. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas is defined as a child. The total body dose was determined for this individual. The critical organ was determined to be the child liver. As shown in Attachment 6 there was one unplanned gaseous release, but no unplanned liquid releases meeting the requirements of 6.7.2.a.3 of the ODCM. 3

3.0 DISCUSSION (cont.) The typical Lower Limit of Detection (LLD) capabilities of the radioactive effluent analysis instrumentation are presented in Attachment 7. These LLD values are based upon conservative conditions (i.e., minimum sample volume and maximum delay time prior to analysis). Actual LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed, then the activity of that radioisotope was reported as Not Detectable (N/D) on Attachment 1 of this report. If an analysis for an isotope was not performed, then the activity was reported as Not Applicable (N/A). 4.0 SUPPLEMENTAL INFORMATION As required by the ODCM, section 6.6.2, evaluation of the Land Use Census is made to determine if new location(s) have been identified for the radiological environmental monitoring program pursuant to the ODCM. No changes were made. Section 6.6.1.b.4 of the ODCM requires identification of the cause(s) for the unavailability of milk or leafy vegetation samples, and the identification of new locations for obtaining replacement samples. Milk samples, as required by the ODCM, section 6.6.1, were available during the time period covered by this report. Milk samples from Station 27 could not be collected for the months November and December, due to the milch animal no longer being available. The leafy vegetation samples for vegetation stations 14, 15, 16, 21, 23 and 26, as applicable, were not collected for the months of January, February, March, April, September, October, November and December 2005 due to seasonal unavailability. All other vegetation samples were obtained and analyzed as required during the time period covered by this report. Plant issue N-2005-4278 identified a privately owned milch goat within the 5 mile boundary, which had a calculated dose 25% greater than current milk sample locations. Neither of the two current locations was removed from the program. The owners were contacted and agreed that milk samples could be obtained from the location. This was added to the environmental sample program as Station 27. When the first sample was to be obtained, the animal was no longer at the location, the owners stating that they no longer had any milch animals. Plant issue N-2005-5231 was submitted to document this fact. All other milk samples were obtained and analyzed as required during the time period covered by this report. Typographical errors were identified in the 2004 Radiological Environmental Operating Report. These were:

• Page 47, Table 3-5, Air Particulate; Gamma Spectra results: The reported value for Be-7 at Station 3 of should be 93.0+/- 30 pCi/M3 vice 930+/- 30 pCVM3 4

4.0 SUPPLEMENTAL INFORMATION (cont.)

• Page 39, Table 3-3, Air Particulate; Gross Beta results. The ending dates for station 07, 21, 22, 23, and 24 should be 01/14/04 through 06/30/04 vice 07/07/04 through 12129/04.
• Pages 44 and 45 Table 3-4 Iodine results. The date should be 07/14/04 vice 07/21/04 5

ATTACHMENT 1 EFFLUENT RELEASE DATA (01/05 - 12/05) This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste, as outlined in Regulatory Guide 1.21, Appendix B, except that in accordance with Step 6.7.2.a.1 of the ODCM liquid and gaseous data is summarized on a quarterly basis and solid waste is summarized on an annual basis. 6

TABLE 1 A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF ALL GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Page 1 of 2 1 ST 2 ND ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%) A. Fission and Activiation Gases:

1. Total Release Curies 1.66E-01 3.67E-01 1.80E+1

2. Average Release Rate For Period giCi/sec 2.13E-02 4.67E-02 B.

Iodines:

1. Total Iodine-131 Release Curies N/D N/D 2.80E+1

2. Average Release Rate For Period iCi/sec N/D N/D C. Particulate (T1/2> 8 days):

1. Total Particulate (T1i/2>8days) Release Curies 4.40E-11 5.09E-08 2.80E+1

2. Average Release Rate For Period giCi/sec 5.66E-12 6.47E-09

3. Gross Alpha Radioactivity Release Curies 7.56E-08 5.29E-07 D. Tritium:

1. Total Release Curies 1.40E+01 3.64E+01 3.10E+1

2. Average Release Rate For Period iCi/sec 1.80E+00 4.62E+00 E.

Percentage Of Technical Specification Limits

1. Total Body Dose Rate 1.64E-04 6.28E-06

2. Skin Dose Rate 4.04E-05 2.01 E-06

3. Critical Organ Dose Rate 1.13E-03 3.07E-03

TABLE 1 A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF ALL GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Pag^ 2 -f 2 3 RD 4 TH ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%) A. Fission and Activiation Gases:

1. Total Release Curies 1.05E+00 3.70E+00 1.80E+1

2. Average Release Rate For Period pCi/sec 1.32E-01 4.65E-01 B.

lodines:

1. Total lodine-131 Release Curies N/D 3.47E-05 2.80E+1

2. Average Release Rate For Period pCi/sec N/D 4.36E-06 C. Particulate (T1/2 > 8 days):

1. Total Particulate (T1i/2>8days) Release Curies 1.05E-06 1.78E-05 2.80E+1

2. Average Release Rate For Period

[tCi/sec 1.32E-07 2.24E-06

3. Gross Alpha Radioactivity Release Curies 3.45E-07 3.18E-07 D.

Tritium:

1. Total Release Curies 2.91 E+01 9.03E+01 3.1 OE+1

2. Average Release Rate For Period pCi/sec 3.65E+00 1.14E+01 E.

Percentage Of Technical Specification Limits

1. Total Body Dose Rate 1.37E-05 1.72E-04

2. Skin Dose Rate 4.72E-06 7.14E-05

3. Critical Organ Dose Rate 2.39E-03 7.96E-03

TABLE 1 B NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Page 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases: Krypton - 85 Ci N/D N/D 1.40E-02 N/D Krypton - 85m Ci N/D N/D N/D N/D Krypton - 87 Ci N/D N/D N/D N/D Krypton - 88 Ci N/D N/D N/D N/D Xenon-131m Ci N/D N/D N/D N/D Xenon - 133 Ci 7.04E-02 3.55E-01 NAD 2.88E-04 Xenon-133m Ci N/D N/D N/D N/D Xenon-135 Ci N/D NAD N/D N/D Xenon-135m Ci 1.73E-03 N/D N/D N/D Xenon-137 Ci N/D N/D N/D N/D Xenon-138 Ci N/D NAD NA) N/D Other (Specify) N/D N/D NAD N/D Argon - 41 Ci N/D 1.15E-02 N/D NAD Total For Period Ci 7.21E-02 3.67E-01 1.40E-02 2.88E-04 lodines: Iodine-131 Ci NA) N/D N/D NAD Iodine-133 Ci N/D N/D N/D NAD Iodine-135 Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D Particulates: Manganese-54 Ci N/D N/D N/D N/D Cobalt - 58 Ci N/D N/D N/D NAD Iron - 59 Ci N/D N/D N/D N/D Cobalt - 60 Ci NAD 1.252-08 N/D N/D Zinc - 65 Ci N/D N/D N/D N/D Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D Cesium-134 Ci N/D N/D NAD NAD Cesium-136 Ci N/D NAD N/D N/D Cesium - 137 Ci NA) 3.84E-08 N/D NAD

TABLE lB NORTH ANNA POWER STATION ANNUAL. RALMOACT!VE EFF!UE^NT-rMc CALEA' r'cr'r"- MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.) Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium-141 Ci N/D N/D N/D N/D Cerium -144 Ci N/D N/D N/D N/D Other (Specify) Ci N/D N/D N/D N/D TotalforPeriod (T1/2 > 8days) Ci N/D 5.09E-08 N/D N/D TotalforPeriod (T1/2 < 8days) Ci N/D N/D N/D N/D Total For Period Ci N/D 5.09E-08 N/D N/D GROSS ALPHA: Ci 2.09E-10 7.18E-10 N/D N/D TRITIUM: Ci 1.58E+00 2.1 5E+00 1.40E-04 5.37E-05

TABLE 1 B NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases: Krypton - 85 Ci N/D N/D N/D 3.15E-01 Krypton - 85m Ci N/D N/D N/D 5.99E-07 Krypton -87 Ci N/D N/D N/D NtD Krypton - 88 Ci N/D N/D N/D N/D Xenon - 131m Ci N/D N/D N/D 6.64E-03 Xenon-133 Ci 1.03E+00 5.03E-01 3.75E-04 7.61 E-01 Xenon - 133m Ci N/D N/D N/D 7.57E-03 Xenon-135 Ci N/D N/D N/D 3.17E-02 Xenon-135m Ci N/D N/D N/D N/) Xenon-137 Ci N/D N/D N/D N/D Xenon-138 Ci N/D NAD N/D NAD Other (Specify) Argon - 41 Ci 1.71 E-02 N/D N/D N/D Total For Period Ci 1.05E+00 5.03E-01 3.75E-04 1.12E+00 lodines: Iodine-131 Ci N/D 1.84E-07 N/D NAD Iodine-132 Ci N/D 9.74E-08 N/D N/D Iodine-133 Ci N/D N/D N/D N/D odine - 135 Ci N/D N/D N/D N/D tal For Period Ci N/D 2.81 E-07 N/D N/D Particulates: Manganese - 54 Ci N/D N/D N/D N/D Cobalt - 58 Ci N/D N/D N/D N/D Iron - 59 Ci N/D N/D N/D N/D Cobalt - 60 Ci N/D 1.34E-08 N/D N/D Zinc - 65 Ci N/D N/D NAD N/D Strontium - 85 Ci NAD N/D N/D N/D Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D Cesium-134 Ci N/D N/D N/D N/D Cesium-136 Ci NA) N/D N/D N/D Cesium - 137 Ci N/D 2.85E-08 N/D N/D

TABLE 1 B NORTH ANNA PnWFR PTAT!ON ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/05 - 12105) Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS OUARTER QUARTER QUARTER QUARTER Particulates: (cont.) Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium - 141 Ci N/D N/D N/D N/D Cerium - 144 Ci N/D N/D N/D N/D Other (Specify) Ci N/D N/D N/D N/D TotalforPeriod (T1/2 > 8days) Ci N/D 4.19E-08 N/D N/D TotalforPeriod (T1/2 < 8days) Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D GROSS ALPHA: Ci 2.37E-10 1.82E-10 N/D N/D TRITIUM: Ci 2.25E+00 4.52E-01 6.68E-05 9.01 E-03

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Paae 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases: Krypton - 85 Ci N/D N/D N/D N/D Krypton - 85m Ci N/D N/D 1.89E-04 N/D Krypton - 87 Ci N/D N/D N/D N/D Krypton-88 Ci N/D N/D N/D N/D Xenon-131m Ci N/D N/D N/D N/D Xenon-133 Ci N/D N/D 1.13E-03 N/D Xenon - 133m Ci N/D N/D N/D N/D Xenon - 135 Ci N/D N/D 1.23E-03 N/D Xenon-135m Ci N/D N/D N/D N/D Xenon-138 Ci N/D N/D 1.80E-03 N/D Other (Specify) Ci Argon - 41 Ci N/D N/D 7.52E-02 N/D Total For Period Ci N/D N/D 7.95E-02 N/ID lodines: Iodine-130 Ci N/D N/ID N/D N/D Iodine-131 Ci N/ID N/D N/D N/D Iodine-132 Ci N/D) N/D N/D N/D Iodine-133 Ci N/D N/D N/D N/D Iodine-135 Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D Particulates: Manganese - 54 Ci N/D N/D N/D N/D Cobalt - 58 Ci N/D N/D N/D N/D Iron - 59 Ci N/D N/D N/D N/D Cobalt - 60 Ci N/ID N/D N/D N/D 7N;-e KI/n N /n Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D Cesium-134 Ci N/ID N/ID N/D N/D Cesium - 136 Ci N/D N/D N/D NID

TABLE 1C NORTH ANNA POWER STATION ANN.UAL RAD!OACT!'!E EFF!U'NT. R'cLEAS a 'ncnR GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/05-12/05) Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.) Cesium -137 Ci N/D N/D N/D N/D Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium -141 Ci N/D N/D N/D N/D Cerium -144 Ci N/D N/D N/D N/D Other (Specify) Ci N/D N/D N/D N/D Zn-65 (T1/2 > 8 days) Ci 4.40E-1 1 N/D N/D N/D Zirconium-95 (T1/2 > 8 days) Ci N/D N/D N/D N/D Niobium-95 (T1/2 > 8 days) Ci N/D N/D N/D N/D Total for Period (T1/2 > 8 days) Ci 4.40E-1 1 N/D N/D N/D Total for Period (T1/2 < 8 days) Ci N/D N/D N/D N/D Total For Period Ci 4.40E-1 1 N/D N/D N/D GROSS ALPHA: Ci 7.54E-08 5.28E-07 N/D N/D TRITIUM: Ci 1.23E+01 3.42E+01 4.27E-02 1.06E-06

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/05 - 12/05) Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS OUARTER OUARTER QUARTER QUARTER Fission & Activation Gases: Krypton - 85 Ci N/D N/D N/D 3.17E-02 Krypton - 85m Ci N/D N/D N/D 3.18E-04 Krypton -87 Ci N/D N/D N/D N/D Krypton -88 Ci N/D N/D N/D N/D Xenon-131m Ci N/D N/D N/D 1.02E-03 Xenon - 133 Ci NID N/D N/D 1.97E+00 Xenon-133m Ci N/D N/D N/D 9.84E-03 Xenon-135 Ci N/D N/D N/D 5.53E-02 Xenon-135m Ci N/D N/D N/D N/D Xenon-138 Ci N/D NAD N/D N/D Other (Specify) Ci Argon - 41 Ci N/D N/D N/D NAD Total For Period Ci N/D N/D N/D 2.07E+00 lodines: Iodine-130 Ci N/D N/D N/D N/D Iodine-131 Ci N/D 3.43E-05 N/D 1.79E-07 Iodine - 132 Ci N/D NAD N/D 2.39E-06 Iodine-133 Ci N/D N/D N/D N/D Iodine-135 Ci N/D N/D N/D NAD Total For Period Ci N/D 3.43E-05 N/D 2.57E-06 Particulates: Manganese - 54 Ci N/D N/D N/D NAD Cobalt - 58 Ci N/D 2.46E-06 N/D 2.03E-07 Iron - 59 Ci N/D NAD N/D N/D Cobalt-60 Ci N/D NAD N/D 3.13E-07 anc-f5 Ci N/D NAD N/D N/D Strontium - 89 Ci N/D NID NAD NID Strontium - 90 Ci N/D NAD N/D N/D Cesium - 134 Ci N/D NAD N/D NAD

TABLE 1C NORTH ANNA POWER STATION ANhA&tLA nADIOACTr9IVEf UrE-L3 inELEASE inEPin GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/05 -1205) Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER OUARTER OUARTER Particulates: (cont.) Cesium - 137 Ci 1.05E-06 N/D N/D 1.37E-05 Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium-141 Ci N/D N/D N/D N/D Cerium - 144 Ci N/D N/D N/D N/D Other (Specify) Chromium - 51 (T1/2 > 8 days) Ci N/D N/C N/D N/D Zirconium-95 (T1/2 > 8 days) Ci N/D N/D N/D N/D Niobium-95 (T1/2 > 8 days) Ci N/D 1.13E-06 N/D 8.95E-08 Total for Period (T1/2 > 8 days) Ci 1.05E-06 3.59E-06 N/D 1.43E-05 Total for Period (T1/2 < 8 days) Ci N/D N/D N/D N/D Total For Period Ci 1.05E-06 3.59E-06 N/D 1.43E-05 GROSS ALPHA: Ci 3.45E-07 3.18E-07 N/D N/D TRITIUM: Ci 2.68E+01 8.22E+01 1.25E-03 7.60E+00

TABLE 2A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT-SUMMATION OFALL RELEASES FOR (01/05 - 12/05) Page 1 of 2 1 ST 2ND ESTIMATED TOTAL UNiTS QUARTER QUARTER PERCENT ERROR A. Fission and Activiation Products:

1. Total Release (not including tritium, noble gas, and gross alpha).

Curies 2.03E-02 3.05E-02 2.OOE+01

2. Average diluted concentration during the period.

AiCi/ml 4.24E-1 1 4.57E-1 1

3. Percent of applicable limit (T.S.)

3.84E-05 7.37E-05 B. Tritium:

1. Total release activity.

Curies 5.98E+01 5.22E+01 2.OOE+01

2. Average diluted concentration during the period.

piCi/ml 1.25E-07 7.82E-08

3. Percent of applicable limit (T.S.)

1.25E-03 7.82E-04 C. Dissolved and Entrained Gases:

1. Total release activity.

Curies 1.63E-04 N/D 2.OOE+01

2. Average diluted concentration during the period.

jtCi/ml 3.40E-1 3 N/D

3. Percent of applicable limit (T.S.)

1.70E-07 N/D D. Gross Alpha Radioactivity:

1. Total release activity.

Curies N/D N/D 2.OOE+01 E. Volume of waste released: (prior to dilution). Liters 1.49E+08 1.70E+08 3.OOE+00 F. Total volume of dilution water used during the period. Liters 4.79E+1 1 6.67E+1 1 3.OOE+00

TABLE 2A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT-SUMMATION OF ALL RELEASES FOR (01/05 - 12/05) Page 2of 2 3 RD 4 TH ESTIMATED TOTAL UNrrS QUARTER QUARTER PERCENT ERROR (%) A. Fission and Activiation Products:

1. Total Release (not including tritium, noble gas, and gross alpha).

Curies 1.05E-01 8.08E-02 2.OOE+01

2. Average diluted concentration during the period.

,uCi/ml 1.20E-1 0 1.51 E-1 0

3. Percent of applicable limit (T.S.)

2.46E-04 1.91 E-04 B. Tritium:

1. Total release activity.

Curies 8.49E+02 9.22E+01 2.OOE+01

2. Average diluted concentration during the period.

glCi/ml 9.70E-07 1.72E-07

3. Percent of applicable limit (T.S.)

9.70E-03 1.72E-03 C. Dissolved and Entrained Gases:

1. Total release activity.

Curies 2.90E-04 N/D 2.OOE+01

2. Average diluted concentration during the period.

glCi/ml 3.31 E-13 N/D

3. Percent of applicable limit (T.S.)

1.66E-07 N/D D. Gross Alpha Radioactivity:

1. Total release activity.

Curies N/D N/D 2.OOE+01

c.

VoUuJIle 01 wHSie reieased: (prior to dilution). Liters 1.70E+08 1.31 E+08 3.OOE+00 F. Total volume of dilution water used during the period. Liters 8.75E+1 1 5.35E+1 1 3.OOE+00

TABLE 2B NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/05 - 12/05) Page 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Products: Manganese - 54 Ci N/D 1.48E-04 N/A N/A Iron - 55 Ci N/D 1.38E-02 N/A N/A Cobalt - 58 Ci 4.14E-04 2.89E-04 N/A N/A Cobalt - 60 Ci 3.45E-03 1.33E-02 N/A N/A Strontium - 89 Ci N/D N/D N/A N/A Strontium - 90 Ci N/D N/D N/A N/A Niobium - 95 Ci 1.26E-04 1.87E-04 N/A N/A Ruthenium - 106 Ci N/D N/D N/A N/A Silver - 11 Om Ci 3.67E-04 1.77E-03 N/A N/A iodine-131 Ci N/D N/D N/A N/A Iodine-133 Ci N/D N/D N/A N/A Cesium - 134 Ci N/D N/D N/A N/A Cesium - 136 Ci N/D N/D N/A N/A Cesium - 137 Ci 6.04E-05 N/D N/A N/A Barium-Lathanum - 140 Ci N/D N/D N/A N/A Cerium-141 Ci N/D N/D N/A N/A Antimony-124 Ci N/D N/D N/A N/A Antimony-125 Ci 1.53E-02 9.50E-04 N/A N/A Other (Specify) Ci Zirconium - 95 (T1/2 > 8 days) Ci N/D N/D N/A N/A Chromium -51 (T1/2> 8 days) Ci N/D N/D N/A N/A Iron - 59 (T 1/2 > 8 days) Ci 1.23E-04 N/D N/A N/A Tin-113(T1/2>8 days) Ci 1.22E-04 N/D N/A N/A Indium - 113m (T1/2 < 8 days) Ci 1.22E-04 N/D N/A N/A Silver-1 08m (T1/2 > 8 days) 2.90E-05 5.72E-05 Niobium-95m (T1/2 < 8 days) 7.27E2-05 N/D Tellurium - 129 (T1/2 < 8 days) Ci 4.44E-05 N/D N/A N/A Tellurium-129m (T1/2 > 8 days) Ci 4.44E-05 N/D N/A N/A Molydenum-99 (T1/2 >8 days) Ci N/D N/D N/A N/A Technitium-99 (T1/2 < 8 days) Ci N/D N/D N/A N/A Total for Period Ci 2.03E-02 3.05E-02 N/A N/A

TABLE 2B NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RFI FASF RFPORT LIQUID EFFLUENT RELEASES FOR (01/05 - 12/05) Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Dissolved & Entrained Noble Gases: Xenon -133 Ci N/D N/D N/A N/A Xenon - 133m Ci N/D N/D N/A N/A Xenon -135 Ci N/D N/D N/A N/A Xenon - 135m Ci N/D N/D N/A N/A Other (Specify) Ci N/D N/D N/A N/A Kr-88 (T1/2 <8 days) Ci 1.63E-04 N/D N/A N/A Kr-85 (T1/2 > 8 days) Ci N/D N/D N/A N/A Total for Period Ci 1.63E-04 N/D N/A N/A Tritium Ci 5.98E+01 5.22E+01 N/A N/A Gross Alpha Ci N/D N/D N/A N/A

TABLE 2B NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/05 - 12/05) Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Products: Manganese - 54 Ci 1.10E-03 5.46E-04 N/A N/A Iron - 55 Ci 1.02E-02 4.52E-03 N/A N/A Cobalt - 58 Ci 1.19E-04 5.35E-03 N/A N/A Cobalt - 60 Ci 5.74E-02 1.94E-02 N/A N/A Strontium - 89 Ci N/D N/D N/A N/A Strontium - 90 Ci N/D N/D N/A N/A Niobium - 95 Ci 7.05E-05 9.97E-04 N/A N/A Ruthenium - 106 Ci N/D N/D N/A N/A Silver-1Om Ci 7.53E-03 2.21E-03 N/A N/A Iodine-131 Ci N/D N/D N/A N/A Iodine-133 Ci N/D N/D N/A N/A Cesium - 134 Ci N/D 1.15E-04 N/A N/A Cesium - 137 Ci 7.00E-05 1.09E-03 N/A N/A Barium-Lathanum - 140 Ci N/D N/D N/A N/A Cerium - 141 Ci N/D N/D N/A N/A Antimony-124 Ci N/D 3.20E-03 N/A N/A Antimony-125 Ci 2.66E-02 3.55E-02 N/A N/A Other (Specify) Tellurium-1 29 (T1/2 < 8 days) Ci 1.62E-05 N/D N/A N/A Tellurium-129m(T1/2 >8 days) Ci 1.62E-05 N/D N/A N/A Tungsten-187 (T1/2 <8 days) Ci 1.59E-03 N/D N/A N/A Sodium-24 (T1/2 < 8 days) Ci N/D 9.97E-04 N/A N/A Zirconium-95 (T1/2 > 8 days) Ci N/D 4.37E-04 N/A N/A Silver-108m (T1/2 > 8 days) Ci 4.31 E-05 1.09E-04 N/A N/A Antimony-122(T1/2 <8 days) Ci N/D 2.11E-04 N/A N/A Antimony-126 (T1/2 > 8 days) Ci N/D 1.49E-04 Iron-59 (T1/2 > 8 days) Ci N/D 2.28E-04 N/A N/A Chromium-51 (T1/2> 8 days) Ci N/D 5.76E-03 N/A N/A Total for Period Ci 1.05E-01 8.08E-02 N/A N/A

TABLE 2B NORTH ANNA POWER STATION ANNUAL RAninAAVTIUE EFFLUENT RE' EASE REPORDT LIQUID EFFLUENT RELEASES FOR (01/05 - 12/05) Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Dissolved & Entrained Noble Gases: Xenon - 133 Ci 2.90E-04 N/D N/A N/A Xenon - 133m Ci N/D N/D N/A N/A Xenon-135 Ci N/D N/D N/A N/A Xenon-135m Ci N/D N/D N/A N/A Other (Specify) Argon -41 (T1/2 < 8 days) Ci N/D N/D N/A N/A Krypton - 85 (T1/2 > 8 days) Ci N/D N/ID N/A N/A Total for Period Ci 2.90E-04 N/D N/A N/A Tritium Ci 8.49E+02 9.22E+01 N/A N/A Gross Alpha Ci N/D N/ID N/A N/A I I

TABLE 3 NORTH ANNA POWER STATION RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF SOLID RADIOACTIVE WASTE AND IRRADIATED FUEL SHIPMENTS FOR 01-01-05 THROUGH 12-31-05 Page 1 cf 2 A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (NOT IRRADIATED FUEL) 12-Month Estimated Total

1. Type of Waste Unit Period Percent Error (%)

a.

Spent resins, sludges, filters sludge, m3 3.21 E+01* 2.50E+01 evaporator bottoms, etc., Ci 1.76E+02 2.50E+01

b.

Dry compressible waste, contaminated m3 1.66E+02** 2.50E+01 equipment, etc., Ci 3.14E+00 2.50E+01

c.

Irradiated components, control rods, m3 0.OOE+00 2.50E+01 etc., Ci 0.OOE+00 2.50E+01

d.

Other (describe) Used Oil, Blast media, Sewage, Gravel, m3 1.01 E+01*** 2.50E+01 Dessicant, Soil, Construction Debris Ci 1.27E-04 2.50E+01

2. Estimate of major nuclide composition Estimated Total JOy type of waste)

(%) (Ci) Percent Error (%)

a.

Co-58 22.38 3.94E+01 2.50E+01 Co-60 21.89 3.85E+01 2.50E+01 Ni-63 20.64 3.63E+01 2.50E+01 Fe-55 14.29 2.51 E+01 2.s0E+01 Cs-137 8.73 1.53E+01 2.50E+01 Cs-1 34 4.30 7.57E+00 2.50E+01 Mn-54 4.15 7.30E+00 2.50E+01 Sb-125 2.68 4.71E+00 2.50E+01 Co-57 0.37 6.51 E-01 2.50E+01 Ce-1 44 0.12 2.16E-01 2.50E+01 Ni-59 0.12 2.06E-01 2.50E+01

b.

Cs-137 68.96 2.17E+00 2.50E+01 Co-60 15.02 4.72E-01 2.50E+01 Ni-63 8.97 2.82E-01 2.50E+01 Nb-95 1.36 4.27E-02 2.50E+01 Cs-1 34 1.11 3.48E-02 2.50E+01 Co-58 0.99 3.12E-02 2.50E+01 Zr-95 0.97 3.05E-02 2.50E+01 Mn-54 0.46 1.44E-02 2.50E+01 Cr-51 0.29 9.06E-03 2.50E+01 Fe-55 0.10 3.OOE-03 2.50E+01 Sb-125 0.01 3.51 E-04 2.50E+01 Zn-65 0.00 7.22E-05 2.50E+01

c.

No shipments

d.

H-3 97.95 1.24E-04 2.50E+01 Cs-137 1.12 1.42E-06 2.50E+01 Co-60 0.71 8.99E-07 2.50E+01 Ce-144 0.08 1.06E-07 2.50E+01 Co-58 0.00 1.39E-09 2.50E+01

TABLE 3 NORTH ANNA POWER STATION RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF SOLID RADIOACTIVE WASTE AND IRRADIATED FUEL SHIPMENTS FOR 01-01-05 THROUGH 12-31-05 Page 2 of 2

3. Solid Waste Disposition Number of Shipments Mode of Transportation Destination 2

Truck Barnwell,SC 7 Truck Oak Ridge,TN (Duratek) 1 Truck Gainsville, FL (Perma-Fix) B. Irradiated Fuel Shipments (Disposition) Number of Shipments Mode of Transportation Destination 1 Truck Idaho National Laboratory

• (3) shipments containing resins/sludge were shipped to a licensed waste processor for processing and/cr volume reduction.
• (1) shipment of resin was shipped to licensed facility for disposal
  • (3) shipments containing contaminated equipment, dry compressible waste / incinerable waste were shipped to a licensed waste processor for processing and/or volume reduction.

(1) shipment of dry compressible waste / incinerable waste was shipped to licensed facility for disposal (1) shipment of mixed waste was shipped to licensed facility for disposal (2) shipments containing soil and other material were shipped to a licensed waste processor for volume reduction.

ATTACHMENT 2 ANNUAL AND QUARTERLY DOSES (01/05 - 12/05) An assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site for each calendar quarter for the calendar year of this report, along with an annual total of each effluent pathway will be made as required by ODCM Section 6.7.2. 1st 2nd 3rd 4th Annual Quarter Quarter Quarter Quarter Total Total Body Dose (mrem) 2.15E-2 1.91 E-2 3.03E-1 3.77E-2 3.81 E-1 Critical Organ Dose (mreMI 2.25E-2 1.90E-2 3.02E-1 6.01 E-2 4.04E-1 1 st 2nd 3rd 4th Annual Quarter Quarter Quarter Quarter Total Noble Gas Gamma Dose (mrad) 2.13E-4 8.83E-6 1.99E-5 2.57E-4 4.99E-4 Noble Gas Beta Dose (mrad) 8.05E-5 1.56E-5 4.33E-5 7.51 E-4 8.90E-4 Critical Organ Dose for 1-13 1, 1-133, H-3, 6.32E-3 1.72E-2 1.36E-2 4.55E-2 8.26E-2 Particulates with T1/2/2 > 8 davs (mrem) 7

ATTACHMENT 3 REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM) (01/05 - 12/05) As required by Technical Specification 6.15, revisions to the ODCM, effective for the time period covered by this report, are summarized in this attachment. There were two revisions made to the ODCM in 2005. Revision 9, which was effective 01/31/2005, revised calculations for the ingestion pathway from grass-cow-milk to garden. Revision 10, which was effective 12/19/2005, revised surveillance, operability, and reporting criteria for the Service Water effluent radiation monitor, 1-SW-RM-108. 8

ATTACHMENT 4 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS, AND SOLID WASTE TREATMENT SYSTEMS (01/05 - 12/05) As required by the ODCM, Section 6.7.2.a.4, major changes to radioactive liquid, gaseous and solid waste treatment systems for the time period covered by this report are synopsized in this attachment. Supporting information as to the reason(s) for the change(s) and a summary of the 10 CFR 50.59 evaluations are included, as applicable. There was no major change to radioactive liquid, gaseous, and solid waste treatment systems for 2005. 9

ATTACHMENT 5 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION (01/05 - 12/05) As required by the ODCM, Sections 6.2.2.b.2 and 6.3.2.b.3, a list and explanation for extended inciperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in this attachment. 1-RM-SW-108 was out-of-service from 07 January 2005 until 21 February 2005. The cause of this condition was a seized pump. Grab samples were taken during periods of discharge via this pathway as required by VPAP-2103N, Offsite Dose Calculation Manual. No radioactivity was detected in any sample. 1-BR-LT-1 12B, level transmitter for "B" Boron Recovery Test Tank was out-of-service from 01 January 2005 through 31 December 2005 due to failure of the transmitter. The transmitter is obsolete and an evaluation is being performed to cetermine if a replacement transmitter meets all applicable requirements. Upon completion of the evaluation final disposition of the transmitter will be made. There were neither additions to nor discharges from the tank during this period. 10

ATTACHMENT 6 UNPLANNED RELEASES (01/05 - 12/05) As required by the ODCM, Section 6.7.2.a.3, a list of unplanned releases, from the site to unrestricted areas, of radioactive material in gaseous and liquid effluents occurring during the reporting period, is made in this attachment. One unplanned gaseous release occurred during this reporting period. Although this release is not required to be reported since: 1) %TS limits were not exceeded; 2) it did not involve the release of the contents of the wrong Waste Gas Decay Tank; and 3) it was not due to a large valve or pipe failure, RP supervision determined that it is appropriate to report it as it was a valve status control event. A valve, 1-BR-75 was in the open position, when it should have been in the closed position. This provided a vent path from "B" Gas Stripper gas space to "B" Vent Stack. An alarm was received on the "B" Vent Stack radiation Monitor, 1 -VG-RM--180. The highest reading was about 1200 [tCi/sec. The duration of the release was 67.33 minutes. The peak dose rate to the Total Body was 25.7 mrem/yr and the peak % Technical Specification was 5.13%. The average dose rate for the release was 1.57 mrem/yr and the average % Technical Specifications was 0.314%. Nuclide release rates and concentrations are provided in the tables below. NUCLIDE PEAK PEAK CONCENTRATION RELEASE j1Ci/cc RATE [tCi/sec H-3 2.78E-06 7.74E+01 Ar-41 1.09E-05 3.04E+02 Kr-85m 2.73E-08 7.60E-01 Xe-133 1.64E-07 4.57E+00 Xe-1 35 1.79E-07 4.99E+00 Xe-1 38 2.62E-07 7.30E+00 NUCLIDE AVERAGE AVERAGE ACTIVITY CONCENTRATION RELEASE RELEASED [LCVcc RATE [tCi/sec [Ci H-3 3.78E-07 1.06E+01 4.27E+04 Ar-41 6.66E-07 1.86E+01 7.52E+04 Kr-85m 1.67E-09 4.67E-02 1.89E+02 Xe-133 1.OOE-08 2.79E-01 1.13E+03 Xe-1 35 1.09E-08 3.05E-01 1.23E+03 Xe-138 1.59E-08 4.44E-01 1.80E+03 An investigation revealed that a periodic test, 0-PT-57.9 had been performed earlier. O-PT-57.9 had single point vulnerability in that the performer writes the "as found" position of the valves down. The "as found" position was written down incorrectly as open when it was actually closed. When the valves were returned to theik "as left" positions, the valve was incorrectly opened. Corrective action included identifying and suspending use of periodic tests to eliminate this vulnerability; revising periodic tests and conducting training on this event. 11

ATTACHMENT 7 LOWER LIMITS OF DETECTION FOR EFFLUENT SAMPLE ANALYSIS (01/05 - 12/05) Gaseous Effluents: Required L.L.D. Typical L.L.D. Radioisotope (uCi/ml) (uCVml) Krypton - 87 1.OOE-4 1.O0E-8 4.OOE-8 Krypton - 88 1.OOE-4 6.OOE-8 9.OOE-8 Xenon - 133 1.OOE-4 2.50E-8 6.OOE-8 Xenon - 133m 1.OOE-4 6.50E-8 2.OOE-7 Xenon - 135 1.OOE-4 1.OOE-8 4.OOE-8 Xenon - 135m 1.OOE-4 7.40E-8 1.80E-7 Xenon - 138 1.OOE-4 1.20E-7 3.10E-7 Iodine - 131 1.OOE-12 3.60E-14 7.OOE-14 Iodine - 133 1.OOE-10 2.50E-13 9.5.OE-11 Manganese - 54 1.OOE-11 3.40E-14 6.OOE-14 Cobalt - 58 1.OOE-1 1 2.50E-14 6.30E-14 Iron - 59 1.OOE-11 6.50E-14 2.OOE-13 Cobalt - 60 1.OOE-11 3.20E-14 7.80E-14 Zinc - 65 1.OOE-11 5.50E-14 2.80E-13 Strontium - 89 1.OOE-11 1.30E-13 1.80E-13 Strontium - 90 1.OOE-11 2.50E-14 6.OOE-14 Molybdenum - 99 1.OOE-11 6.OOE-13 1.OOE-14 Cesium-134 1.OOE-11 8.50E-15 2.70E-14 Cesium - 137 1.OOE-11 4.OOE-14 6.50E-14 Cerium-141 1.OOE-11 3.OOE-14 9.OOE-14 Cerium-144 1.OOE-11 1.70E-13 6.OOE-13 Gross Alpha 1.OOE-11 5.OOE-15 7.50E-15 Tritium 1.OOE-6 4.OOE-9 7.80E-9 12

ATTACHMENT 7 LOWER LIMITS OF DETECTION FOR EFFLUENT SAMPLE ANALYSIS (01/05 - 12/05) Liquid Effluents: Radioisotope Krypton - 87 Krypton - 88 Xenon - 133 Xenon - 133m Xenon - 135 Xenon - 135m Xenon - 138 Iodine - 131 LA-A Required L.L.D. (uCi/ml) 1.OOE-5 1.OOE-5 1.OOE-5 1.OOE-5 1.OOE-5 1.OOE-5 1.OOE-5 1.OOE-6 fnI 3.OOE 4.OOE 2.50E-8.40E-5.OOE-3.50E* 8.OOE-3.OOE-o) nr%= Typical L.L.1). (uCVmI) -8 9.OOE-8 -8 2.OOE-7 -8 8.50E-8 -8 2.OOE-7 -9 1.40E-8 -8 2.OOE-7 -8 7.00E-7 -8 7.OOE-8 CM= o IviaiiaieSb 4 U.vuUC-/ I.UU---o Iron - 55 1.OOE-6 2.40E-7 4.60E-i Cobalt - 58 5.OOE-7 1.OOE-8 8.OOE-8 Iron - 59 5.OOE-7 2.80E-8 5.OOE-8 Cobalt - 60 5.OOE-7 2.50E-8 7.OOE-8 Zinc - 65 5.OOE-7 3.50E-8 5.80E-8 Strontium - 89 5.OOE-8 2.80E-8 4.00E-8 Strontium - 90 5.OOE-8 2.90E-8 4.5 OE-8 Molybdenum - 99 5.OOE-7 5.OOE-8 9.20E-8 Cesium - 134 5.OOE-7 8.OOE-8 3.OOE-7 Cesium - 137 5.OOE-7 4.50E-8 7.OOE-8 Cerium - 141 5.OOE-7 6.OOE-8 9.OOE-8 Cerium - 144 5.OOE-7 1.50E-7 4.OOE-7 Gross Alpha 1.OOE-7 3.OOE-8 8.20E-8 Tritium 1.OOE-5 2.50E-6 4.50E-6 13

Station "0 Dominione Administrative Procedure

Title:

Offsite Dose Calculation Manual (North Anna) Process / Program Owner: Manager Radiological Protection and Chemistry (North Anna) Procedure Number Revision Number Effective Date VPAP-2103N 10 On File Revision Summary Revise in response to ET N-05-0025 to update radioactive liquid effluent monitoring instrumentation surveillance requirements. Details:

• Updated references:
• Added 3.1.25: ET N-05-0025, Justification for removing 1-SW-RM-108 from service when not in use.
• Added 3.1.27: O-PT-75.21, 1-SW-RM-108 Flow Verification.
• Revised 6.2.2.b.2 to update radioactive liquid effluent monitoring instrumentation operability to provide instructions for channels that are required to be in service:
• O]d - Attempt to return the instruments to operable status within 30 days. If unsuccessful, explain in the next Annual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.
• New - Attempt to return the instruments to operable status within 30 days. If unsuccessful and the channel is required to be in service, then explain in the next Annual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.
• Revised Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) to update requirements for 1-SW-RM-108:
• Added Note 4: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, 0-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.
• Re-vised Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 2) to update requirements for 1-SW-RM-108:
• Changed item 1 (e) from "1-SW-RM-108, Service Water System Effluent Monitor" to "1-SW-RM-108, SW Effluent Monitor (NOTE 14)".
• Added Note 14: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, 0-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

North Anna Radiological Protection is required to submit each revision of this procedure to the Management Safety Review Committee (MSRC) Coordinator. Approvals on File

DOMINION VPAP-2103N REVISION 10 PAGE 2 OF 86 TABLE OF CONTENTS Section Page 1.0 PURPOSE 5 2.0 SCOPE 5

3.0 REFERENCES

/ COMMITMENT DOCUMENTS 6

4.0 DEFINITIONS 7 5.0 RESPONSIBILITIES 11 6.0 INSTRUCTIONS 12 6.1 Sampling and Monitoring Criteria 12 6.2 Liquid Radioactive Waste Effluents 12 6.2.1 Liquid Effluent Concentration Limitations 12 6.2.2 Liquid Monitoring Instrumentation 13 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 18 6.2.5 Liquid Sampling 19 6.3 Gaseous Radioactive Waste Effluents 19 6.3.1 Gaseous Effluent Dose Rate Limitation 19 6.3.2 Gaseous Monitoring Instrumentation 22 6.3.3 Noble Gas Effluent Air Dose Limit 25 6.3.4 I-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 27 6.3.5 Gaseous Radwaste Treatment 29 6.4 Radioactive Liquid and Gaseous Release Permits 31 6.4.1 Liquid Waste Batch Release Permits 31 6.4.2 Continuous Release Permit 31 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 32 6.4.4 Reactor Containment Release Permits 32 6.4.5 Miscellaneous Gaseous Release Permit 32

DOMINION VPAP.-2103N REVISION 10 PAGE $ OF 86 TABLE OF CONTENTS (continued) Section Page 6.4.6 Radioactive Liquid and Gaseous Release Controls 32 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 34 6.6.1 Monitoring Program 34 6.6.2 Land Use Census 36 6.6.3 Interlaboratory Comparison Program 37 6.7 Reporting Requirements 38 6.7.1 Annual Radiological Environmental Operating Report 38 6.7.2 Annual Radioactive Effluent Release Report 39 6.7.3 Annual Meteorological Data 41 6.7.4 Changes to the ODCM 42 7.0 RECORDS 43

DOMINION VPAP-2103N REVISION 10 PAGE 4 OF 86 TABLE OF CONTENTS (continued) Section Page ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 44 2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements 46 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Gaseous Effluent Dose Factors 56 6 Radioactive Gaseous Effluent Monitoring Instrumentation 59 7 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 62 8 Critical Organ Dose Factors 65 9 Radiological Environmental Monitoring Program 67 10 Environmental Sampling Locations 72 11 Detection Capabilities for Environmental Sample Analysis 76 12 Reporting Levels for Radioactivity Concentrations in Environmental Samples 78 13 Meteorological, Liquid, and Gaseous Pathway Analysis 79

DOMINION VPAP -2103N REVISION 10 PAGE 5 OF 86 1.0 'PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive E:ffluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, 1:o calculate gaseous and liquid effluent monitoring alarm / trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that: Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CFR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 jiCi/ml for dissolved or entrained noble gases. Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CFR 50, Appendix I Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to: Noble gases - less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin I131, 1133, and H3, and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CFR 50, Appendix I, and AExposure to a real individual will not exceed 40 CFR 190 dose limits 2.0 SCOPE '[his procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at North Anna Power Station.

DOMINION VPAP--2103N REVISION 10 PAGE 6 OF 86 3.0 ]REFERENCES / COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 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, Rev. 1, U.S. NRC, June 1974 3.1.6 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.50, Appendix I, Rev. 1, U.S. NRC, October 1977 3.1.7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 North Anna Technical Specifications 3.1.9 North Anna Technical Requirements Manual (TRM) 3.1.10 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.11 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.12 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.13 WASH 1258, Vol.2, July 1973, Numerical Guides forDesign Objectives andLimiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.14 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.15 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.16 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.17 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliancc: With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.18 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Proposed Rev. 3, March 1982

DOMINION VPAP-2103N REVISION 10 PAGE 7 OF 86 3.1.19 Environmental Measurements Laboratory, DOE HASL 300 Manual 3.1.20 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.21 North Anna UFSAR 3.1.22 Nuclear Reactor Environmental Radiation Monitoring Quality Control Manual, IWL-0032-361 3.1.23 North Anna Circulating Water System Modifications

a. DC-85-37-1 Unit 1

b. DC-85-38-2 Unit 2 3.1.24 Plant Issue (Deviation) N-1994-1137, Improper Placement of Emergency TLI)s 3.1.25 ET N-05-0025, Justification for removing 1-SW-RM-108 from service when not in use 3.1.26 VPAP-2802, Notifications and Reports 3.1.27 O-PT-75.21, 1-SW-RM-108 Flow Verification 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number C 90-22, Management Safety Review Committee, Observation 03C, January 17, 1991 3.2.2 Quality Assurance Audit Report Number 91-03, Observation 08N 3.2.3 Quality Assurance Audit Report Number 92-03, Observation 02N 3.2.4 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.5 Plant Issue (Deviation) N-1997-0926, Annual Radiological Effluent Release Report 4.0 DEFINITIONS 4.1 Channel Calibration A channel calibration shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The channel calibration shall encompass all devices in the channel required for channel operability. The channel calibration may be performed by means of any series of sequential, overlapping, or total channel steps.

DOMINION VPAP**2103N REVIS[ON 10 PAGE 8 OF 86 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and status with other indications or status derived from independent instrumentation channels measuring the same parameter. 4.3 Channel Operational Test A. Channel Operational Test (COT) shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all device:, in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps. 4.4 Critical Organ '[hat organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. Dose calculations to the critical organ will be evaluated in accordance with 'Technical Specifications 5.5.4 dose rate limits specified for any organ to verify these limits have not been exceeded. 4.5 Dose Equivalent I-131 That concentration of 1131 (pCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I131, i132, i133, 1134, and I135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP*2103N REVIS ION 10 PAGE 9 OF 86 4.6

Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent.

NOTATION FREQUENCY D -Daily At least once per 24 hours W - Weekly At least once per 7 days MI - Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA - Semi-annually At least once per 184 days R - Refueling At least once per 18 months S/U - Start-up Prior to each reactor start-up ]' - Prior to release Completed prior to each release N.A. - Not applicable Not applicable DR - During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers, waste gas surge tanks, and waste gas diaphragm compressor. 4.8 General Nomenclature = Chi: concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies) = Emission rate (continuous; grams per second, curies per second) = Emission rate (continuous line source; grams per second per meter) 4.9 ILower Limit of Detection (LLD) '[he smallest concentration of radioactive material in a sample that will yield a net count (above system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

DOMINION VPAP-2103N REVISION 10 PAGE 10 OF 86 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association witf1 the Station. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive rmaterials. 4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required 1:o purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., North Anna - 2893 MWt). 4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land. 4.15 Source Check A qualitative assessment of channel response when a channel sensor is exposed to rad-ation. This applies to installed radiation monitoring systems. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VPAP-2802, Notifications and Reports. 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

DOMINION VPAP.-2103N REVIS:[ON 10 PAGE 11 OF 86 4.18 'Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional and/or recreational purposes. 4.19 'Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and ]-Iigh Efficiency Particulate Air (HEPA) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components. 5.0 ]RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry '[he Manager Radiological Protection and Chemistry is responsible for: 5.1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment. 5.1.2 Surveying, sampling, and analyzing plant effluents and environmental monitori ng, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5.1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

DOMINION VPAP-2103N REVISION 10 PAGE 12 OF 86 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 13). 6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2

Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

a. Liquid waste concentrations discharged from the Station shall not exceed the following limits:

1. For radionuclides (other than dissolved or entrained noble gases), liquid effluent concentrations released to unrestricted areas shall not exceed ten times the effluent concentration values specified in 10 CFR 20, Appendix B, Table 2, Column 2.

2. For dissolved or entrained noble gases, concentrations shall not exceed 2E-4 pCi/ml.

b. If the concentration of liquid effluent exceeds the limits in Step 6.2.1.a., promptly reduce concentrations to within limits.

DOMINION VPAP-2103N REVISION 10 PAGE 1'- OF 86

c. Daily concentrations of radioactive materials in liquid waste released to unrestricted areas shall meet the following:

Volume of Waste Discharged + Volume of Dilution Water> 1 (1) Volume of Waste Discharged x gCimlW -ACW. where: gCi/mli = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluent concentration value in unrestricted areas cf nuclide i, expressed as p.Ci/ml from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4,uCi/ml for dissolved or entrained noble gases 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effluent Monitoring Instrumentation Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be operable with their alarm / trip setpoints set to ensure that Step 6.2.1.a. limits are not exceeded.

1. Alarm / trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.2.2.d., Setpoint Calculation.

2. If a radioactive liquid effluent monitoring instrumentation channel alarm / trip setpoint is less conservative than required by Step 6.2.2.a., perform one of the following:

• Promptly suspend release of radioactive liquid effluents monitored by the affected channel
• Declare the channel inoperable
• Change the setpoint to an acceptable, conservative value

DOMINION VPAP-2103N REVISION 10 PAGE 141 OF 86

b. Radioactive Liquid Effluent Monitoring Instrumentation Operability Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated operable by performing a Channel Check, Source Check, Channel Calibration, and Channel Operational Test at the frequencies shown in Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 2).

1. If the number of operable channels is less than the minimum required by the tables in Radioactive Liquid Effluent Monitoring Instrumentation (Attachment

1) perform the action shown in those tables.

2. Attempt to return the instruments to operable status within 30 days. If unsuccessful and the channel is required to be in service, then explain in the next Annual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

c. Applicable Monitors Liquid effluent monitors for which alarm / trip setpoints shall be determined are:

Release Point Instrument Number Liquid Radwaste Effluent Line 1-LW-RM-1 11 Service Water System Effluent Line 1-SW-RM-108 Condenser Circulating Water Line 1-SW-RM-130 2-SW-RM-230 Steam Generator High Capacity 1-SS-RM-125 Blowdown Line 2-SS-RM-225

DOMINION VPAP.-2103N REVIS[ON 10 PAGE 1i OF 86

d. Setpoint Calculation NOTE: This methodology does not preclude use of more conservative setpoints.

1. Maximum setpoint values shall be calculated by:

CFD S =F (2) FE where: S

the setpoint, in iCi/ml, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C

the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station, in gCi/ml FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as: D = FE + (218,000 gpm x number of circ. pumps in service)

2. Each of the condenser circulating water channels (e.g., SW-130, SW-230) monitors the effluent (service water, including component cooling serv,.ce water, circulating water, and liquid radwaste) in the circulating water discharge tunnel beyond the last point of possible radioactive material addition. No dilution is assumed for this pathway. Therefore, Equation (2) becomes:

S = C (3) The setpoint for Station monitors used to implement 10 CFR 20 for the site becomes the effluent concentration limit.

3. In addition, for added conservatism, setpoints shall be calculated for the liquid radwaste effluent line LW-1Il and the Service Water System effluent line SW-108.

DOMINION VPAP-2103N REVISION 10 PAGE 16 OF 86

4. For the liquid radwaste effluent line, Equation (2) becomes:

C= FDKLW FE where: KLW = The fraction of the effluent concentration limit, used to implement 10 CFR 20 for the site, attributable to the liquid radwaste effluent line pathway

5. For the Service Water System effluent line, Equation (2) becomes:

= CFDKSW (5) FE where: Ksw = The fraction of the effluent concentration limit, used to implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

6. The sum KLW + Ksw shall not be greater than 1.0.

6.2.3 Liquid Effluent Dose Limit

a. Requirement At least once per 31 days, perform the dose calculations in Step 6.2.3.c. to ensure the dose or dose commitment to the maximum exposed member of the publ ic from radioactive materials in liquid releases (from each reactor unit) to unrestricted areas is limited to:

1. During any calendar quarter:

• Less than or equal to 1.5 mrem to the total body
• Less than or equal to 5 mrem to the critical organ

2. During any calendar year:

• Less than or equal to 3 mrem to the total body
• Less than or equal to 10 mrem to the critical organ

DOMINION VPAP.-2103N REVIS [ON 10 PAGE 17 OF 86

b. Action If the calculated dose from release of radioactive materials in liquid effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that identifies causes for exceeding limits and defines corrective actions taken to reduce releases of radioactive materials in liquid effluents to ensure that subsequent releases will be in compliance with the above limits.

c. Dose Contribution Calculations Dose contribution shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on:

D = EQixBi (6) i Where: Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem Bi = Dose Commitment Factors (mrem/Ci) for each age group of interest. Values for Bi are provided in code file for North Anna Power Station liquid pathway critical organ calculations Qi = Total released activity for the considered period and the ith nuclide Qi = t x Ci x Waste Flow (7) Where: t = the period for which Ci and F are averaged for all liquid releases, in hours Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period, t, from any liquid releases, in pCi/ml

DOMINION VPAP-2103N REVISION 10 PAGE 18 OF 86

d. Quarterly Composite Analyses For radionuclides not determined in each batch or weekly composite, dose contribution to current monthly or calendar quarter cumulative summation may be approximated by assuming an average monthly concentration based on previous monthly or quarterly composite analyses. However, for reporting purposes, calculated dose contribution shall be based on the actual composite analyses.

6.2.4 Liquid Radwaste Treatment Historical data pertaining to the volumes and radioactivity of liquid effluents released in connection with specific station functions, such as maintenance or refueling outages, shall be used in projections as appropriate.

a. Requirement

1. The Liquid Radwaste Treatment System shall be used to reduce the radioactive materials in liquid waste prior to discharge when projected dose due to liquid effluent, from each reactor unit, to unrestricted areas would exceed 0.06 mrem to total body or 0.2 mrem to the critical organ in a 31-day period.

2. Doses due to liquid releases shall be projected at least once per 31 days.

b. Action If radioactive liquid waste is discharged without treatment and in excess of the above limits prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that includes the following:

1. An explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or sub-system, and the reason for the inoperability.

2. Actions taken to restore inoperable equipment to operable status.

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body Dose Calculation

1. Determine DTB, the total body dose from liquid effluents in the previous 3l-day period, per Equation (6).

DOMINION VPAP-2103N REVISION 10 PAGE 19 OF 86

2. Estimate RI, the ratio of the estimated volume of liquid effluent releases in the present 31-day period to the volume released in the previous 31-day period.

3. Estimate FI, the ratio of the estimated liquid effluent radioactivity concentration in the present 31-day period to liquid effluent concentration in the previous 31-day period (gCi/ml).

4. Determine PDTB, the projected total body dose in a 31-day period.

PDTB = DTB(RlFl) (8)

d. Projected Critical Organ Dose Calculation

1. Determine DOI the critical organ dose from liquid effluents in the previous 3 1-day period, per Equation (6).

2. Estimate R1 as in Step 6.2.4.c.2.

3. Estimate F1 as in Step 6.2.4.c.3.

4. Determine PDO = projected critical organ dose in a 31-day period.

PDO = DO(R1 F1) (9) 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). 6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation

a. Requirement Dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to:

1. The dose rate limit for noble gases shall be < 500 mrem/year to the total body and < 3000 mrem/year to the skin.

DOMINION VPAP-2103N REVISION 10 PAGE 20 OF 86

2. The dose rate limit for l13', 1133, for tritium, and for all radioactive materials in particulate form with half-lives greater than 8 days shall be

• 1500 mrem/year to the critical organ.

b. Action

1. If dose rates exceed Step 6.3.1.a. limits, promptly decrease the release rate to within the above limits.

2. Dose rates due to noble gases in gaseous effluents shall be determined, continuously, to be within Step 6.3.1.a. limits.

3. Dose rates due to I131, 1133, 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 by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified on Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

DOMINION VPAP-2103N REVISION 10 PAGE 21 OF 86

c. Calculations of Gaseous Effluent Dose Rates

1. The dose rate limit for noble gases shall be determined to be within the limit by limiting the release rate to the lesser of:

I [KivvpQivv + KiPVQipv] < 500mremlyr to the total body i (10) OR Z [(Liv l IMivv) iv + (Lipv + 1.1 Mipv)Qipv] < 3000mrem/yr to the skin (1(1 1) where: Subscripts Kivv, Kipv Livv, Lipv MiVV, MipV 1.1 = vv, refers to vent releases from the building ventilation vent pv, refers to the vent releases from the process vent; i, refers to individual radionuclide = The total body dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) = The skin dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) = The air dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) = The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (par site) = The unit conversion factor that converts air dose to skin dose, in mrem/mrad

DOMINION VPAP-2103N REVISION 10 PAGE 22 OF 86

2. The dose rate limit for I131, 1133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days, shall be determined to be within the limit by restricting the release rate to:

Z[PivvQivv + PipvQipv] < 1500mrem/yr to the critical organ (12) i where: Pivv, Ppv = The critical organ dose factor for ventilation vents or process vent for I13 1, I 3, H3, and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) 6iwp = The release rate for ventilation vents or process vent of I131, I133, H3, and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec (per site)

3. All gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv.

6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 6) shall be operable with alarm / trip setpoints set to ensure that Step 6.3.1.a. noble gas limits are not exceeded. Alarm / trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

2. Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated operable by Channel Checks, Source Checks, Channel Calibrations, and Channel Operational Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 7).

DOMINION VPAF'-2103N REVISION 10 PAGE 2:3 OF 86

b. Action

1. Ifaradioactive gaseous effluentmonitoring instrumentation channel alarm-/trip setpoint is less conservative than required by Step 6.3.2.a.1, promptly:

• Suspend the release of radioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or
• Change the setpoint so it is acceptably conservative

2. If the number of operable channels is less than the minimum required by tables in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 6) take the action shown in those tables.

3. Return instruments to operable status within 30 days. If unsuccessful, explain in the next Annual Radioactive Effluent Release Report why the inoperabi]ity was not corrected in a timely manner.

c. Applicable Monitors Radioactive gaseous effluent monitors for which alarm / trip setpoints shall be determined are:

Release Point Instrument Number Process Vent 1-GW-RM-178-1 Condenser Air Ejector 1-SV-RM-121 2-SV-RM-221 Ventilation Vent A 1-VG-RM-179-1 Ventilation Vent B 1-VG-RM-180-1

DOMINION VPAP-2103N REVISION 10 PAGE 24 OF 86

d. Setpoint Calculations

1. Setpoint calculations for each monitor listed in Step 6.3.2.c. shall maintain this relationship:

DŽDpv +Dcae +Dvv (13) where: D = Step 6.3.1.a. dose limits that implement 10 CFR 20 for the Station, mrem/yr DPV = The noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = The noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr DVV = The noble gas site boundary dose rate from summation of Ventilation Vent A plus B gaseous effluent releases, mrem/lyr

2. Setpoint values shall be determined by:

R. x2.12 E-03 Cm= m (14) Fm where: m = The release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae) Cm = The effluent concentration limit implementing Step 6.:3.1.a. for the Station, ACi/ml Rm = The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe' 33 as nuclide to be released, giCi/sec 2.12E-03 = CFM per ml/sec Fm = The maximum flow rate for pathway m, CFM

DOMINION VPAP-2103N REVISION 10 PAGE 25 OF 86 NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm / trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm / trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases. 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

1. The air dose in unrestricted areas due to noble gases released in gaseous effluents from each unit at or beyond the site boundary shall be limited to:

• During any calendar quarter: < 5 mrads for gamma radiation and < 10 mrads for beta radiation
• During any calendar year: < 10 mrads for gamma radiation and < 20 mrads for beta radiation

2. Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with Step 5.3.3.c.

at least once per 31 days.

b. Action If the calculated air dose from radioactive noble gases in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that identifies the causes for exceeding the limits and defines corrective actions that have been taken to reduce releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the limits in Step 6.3.3.a.

DOMINION VPAP-2103N REVISION 10 PAGE 26 OF 86

c. Noble Gas Effluent Air Dose Calculation Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv-The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following:

For gamma radiation: Dg = 3.17E-08 [MivvQivv + MipvQipv] For beta radiation: Db = 3.17E-081[NivvQivv+NipvQipv] (16) i Where: Subscripts = vv, refers to vent releases from the building ventilation vents, including air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide Dg = the air dose for gamma radiation, in mrad Db = the air dose for beta radiation, in mrad Mivv Mipv = the air dose factors for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) Nivv Nipv = the air dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) Qivv Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3.17 E-08 = the inverse of the number of seconds in a year

DOMINION VPAF'-2103N REVISION 10 PAGE 27 OF 86 6.3.4 1-131, 133,1H-3 & Radionuclides In Particulate Form Effluent Dose Limit

a. Requirement

1. Methods shall be implemented to ensure that the dose to any organ of a member of the public from 1131, 1133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released from the site to unrestricted areas from each reactor unit shall be:

• During any calendar quarter: < 7.5 mrem to the critical organ
• During any calendar year: < 15 mrem to the critical organ

2. Cumulative dose contributions to a member of the public from 1131, i133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released to unrestricted areas for the current calendar quarter and current calendar year shall be determined at least once per :31 days in accordance with Step 6.3.4.c.

b. Action If the calculated dose from the release of I131, J133, tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

3. Proposed corrective actions to be taken to assure that subsequent releases will be in compliance with limits stated in Step 6.3.4.a.

DOMINION VPAP-2103N REVISION 10 PAGE 23 OF 86

c. Dose Calculations Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qb.

Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection to specific Station functions, such as containment purges, shall be used in the estimates as appropriate.

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary, that contain I131, I1I-3, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

Dr = 3.17E-08 [RMivvQivv +RM1pvQipv] (17) Where: Subscripts = vv, refers to vent releases from the building ventilation vents; pv, refers to the vent releases from the process vent Dr = the dose to the critical organ of the maximum exposed member of the public, in mrem RMivv, RMipv =the dose factor for ventilation vents or process vent release due to I131, I133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in mnem/yr per Curie/sec. Factors are listed in Critical Organ Dose Factors (Attachment 8) bivvbipv = the release for ventilation vents or process vent of I131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in Curies 3.17 E-08 = the inverse of the number of seconds in a year

DOMINION VPAP-2103N REVISION 10 PAGE 29) OF 86 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

1. The Gaseous Radwaste Treatment System and the Ventilation Exhaust Treatment System shall be used to reduce radioactive material in gaseous waste before its discharge, when projected gaseous effluent air doses due to gaseous effluent releases, from each unit to areas at and beyond the site boundary, would exceed 0.2 mrad for gamma radiation and 0.4 mrad for beta radiation, averaged over 31 days.

2. The Ventilation Exhaust Treatment System shall be used to reduce radioactive materials in gaseous waste before its discharge, when the projected doses due to gaseous effluent releases, from each unit to areas at and beyond the site boundary, would exceed 0.3 mrem to the critical organ, averaged over 31 days.

3. Doses due to gaseous releases from the site shall be projected at least once per 31 days, based on the calculations in Step 6.3.5.c.

b. Action If gaseous waste that exceeds the limits in Step 6.3.5.a. is discharged without treatment, prepare and submit to the NRC within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that includes:

1. An explanation why gaseous radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability.

2. Actions taken to restore the inoperable equipment to operable status.

3. Summary description of actions taken to prevent recurrence.

c. Projected Gamma Dose

1. Determine Dg, the 3l-day gamma air dose for the previous 3l-day peri Dd, per Equation (15).

2. Estimate Rg, the ratio of the estimated volume of gaseous effluent in the current 31-day period to the volume released during the previous 31-day period.

DOMINION VPAF-2103N REVISION 10 PAGE 30 OF 86

3. Estimate F8, the ratio of the estimated noble gas effluent activity in the current 31-day period to the noble gas effluent activity during the previous 31-day period (jiCi/ml).

4. Determine PD8, the projected 31-day gamma air dose.

PDg = Dg(Rg X Fg ) (18)

d. Projected Beta Dose

1. Determine Db, the 31-day beta air dose in the previous 31 days, per Equation (16).

2. Estimate Rg and Fg as in Steps 6.3.5.c.2. and 6.3.5.c.3.

3. Determine PDb, the projected 31-day beta air dose.

PDb = Db(RgxFg) (19)

e. Projected Maximum Exposed Member of the Public Dose

1. Determine Dmax, the 31-day maximum exposed member of the public dose in the previous 31-day period, per Equation (14), where Dr = Dmax.

2. Estimate Fi, the ratio of the estimated activity from I131, I133, radioactive materials in particulate form with half-lives greater than 8 days, and trilium in the current 31-day period to the activity of 1131, 1133, radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the previous 31-day period (gCi/ml).

3. Determine PDmax, the projected 31-day maximum exposed member of the public dose.

PDmax = Dmax(Rg x Fi) (20)

DOMINION VPAP-2103N REVISION 10 PAGE 31 OF 86 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases. 6.4.1 Liquid Waste Batch Release Permits Operations shall obtain RP authorization before initiating batch releases of radioactive liquids. Examples of batch releases include: Batch Releases NOTE: If the clarifier is in service, releases from tanks processed through the clarifier are considered continuous releases. A Batch Release Permit is required for a release from any tanks / sumps which contain (or potentially contain) radioactive liquid. Tanks / sumps include:

• BRTT
• LLWDT
• HLWDT
• Turbine Building Sumps when secondary coolant activity exceeds 1.0 E-5 pCi/ml
• CDT 6.4.2 Continuous Release Permit Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids.

Continuous Releases A Continuous Release Permit is required for:

• Clarifier, unless being bypassed
• Steam generator blowdown when clarifier is bypassed
• Containment mat sumps and service water reservoir when clarifier is bypassed.

Sampling requirements and control and conditions for service water reservoir blowdown, when no radioactivity is detected, shall be specified on the permit.

DOMINION VPAP-2103N REVISION 10 PAGE 32 OF 86 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid frcm start of purge / hog until:

• Routine termination
• Terminated for cause by RP
• Receipt of Radiation Monitoring System (RMS) Containment Gas Monitor high alarm 6.4.5 Miscellaneous Gaseous Release Permit Operations shall obtain RP authorization before initiating releases of noble gases that may not be accounted for by routine sampling, or any planned release not being routed through the Process Vent or Ventilation Vents (e.g., steam driven auxiliary feedwater pump testing if primary to secondary leakage exists).

6.4.6 Radioactive Liquid and Gaseous Release Controls

a. Operations shall notify RP of pending releases and request RP to initiate the appropriate release permit. Operations shall provide the necessary information to complete the required release permit.

b. A representative sample shall be obtained of the source to be released.

1. Operations shall provide RP with liquid samples and sample information (e.g.,

time of sample) for samples obtained outside the Primary Sample Room. except Clarifier Proportional Tank and Clarifier Grab Samples.

2. Chemistry shall provide RP with liquid samples and sample information for samples obtained from inside the Primary Sample Room.

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

DOMINION VPAP-2103N REVISION 10 PAGE 3:3 OF 86

d. RP shall calculate and record the following information on a release permit:

• Maximum authorized release rate
• Maximum authorized release rate in percentage of limits specified by the ODCM
• Applicable conditions or controls pertaining to the release

e. RP shall notify the Shift Supervisor if it is determined that a release may not be within the effluent dose limits.

f. Upon receipt of a release permit from RP, Operations shall:

1. Verify the correct source is authorized for release.

2. Note maximum authorized release rate.

3. Note percent of Technical Specifications limits the release represents.

4. Note and ensure compliance with any indicated controls or conditions applicable to the release.

g. When commencing release, Operations shall provide RP with required information.

As appropriate, required information shall include:

• Date and time release was started
• Starting tank / sump level
• Beginning pressure
• Release flow rate
• Dilution water flow rate

h. Upon terminating the release, Operations shall return the permit to RP and provide information necessary for completion of permit. As appropriate, required information shall include:

• Date and time release was stopped
• Tank / sump ending level
• Release flow rate just prior to termination
• Ending pressure
• Volume released

DOMINION VPAP-2103N REVISION 10 PAGE 34 OF 86 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem). 6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent xeleases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CFR 20.2203(a)(4), shall include:

1. An analysis that estimates the radiation exposure (dose) to a real individual from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the releases covered by the report.

2. A description of the levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations.

3. If the estimated dose exceeds the limits in Step 6.5.1, and if the release condition that violates 40 CFR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request, and. a variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

1. The Radiological Environmental Monitoring Program shall be conducted as specified in Radiological Environmental Monitoring Program (Attachment 9).

DOMINION VPAP-2103N REVISION 10 PAGE 3:5 OF 86

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 10). [Commitment 3.2.2]

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 9) requirements
• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 11)
• Guidance of the Radiological Assessment Branch Technical Position on Environmental Monitoring dated November, 1979, Revision No. 1

b. Action

1. If the Radiological Environmental Monitoring Program is not being conducted as required in Step 6.6..a., report the situation in accordance with VPAP-2802, Notifications and Reports, by preparing and submitting to the NRC, in the Annual Radiological Environmental Operating Report required by Technical Specifications 5.6.2, a description of the reasons for not conducting the program as required, and the plan for precluding recurrence.

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) prepare and submit to the NRC within 30 davs, a special report in accordance with VPAP-2802, Notifications and Reports, that:

• Identifies the causes for exceeding the limits, 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 limits of Steps 6.2.3, 6.3.3, and 6.3.4 When more than one of the radionuclides listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected in the sampling medium, the report shall be submitted if:

concentration (1) + concentration (2) + 2 1.0 (21) reporting level (1) reporting level (2)

DOMINION VPAP-2103N REVISION 10 PAGE 36 OF 86

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 1.2) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not rec uired if the measured level of radioactivity was not the result of plant effluents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPA]?-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Environmental Sampling Locations (Atta-hment 10), identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of samples and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports. Include in the report a revised figure and table for the ODCM to reflect the new locations.

6.6.2 Land Use Census

a. Requirement 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 following:

• Nearest milk animal
• Nearest residence
• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation

1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g., door-to-door survey, aerial survey, local agriculture authorities). Land use census results shall be included in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

DOMINION VPAP-2103N REVISION 10 PAGE 37 OF 86

2. In lieu of the garden census, broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the site boundary in each of two different direction sectors with the highest predicted ground deposition (D/Qs). Specifications for broad leaf vegetation sampling in Radiological Environmental Monitoring Program (Attachment 9) shall be followed, including analysis of control samples.

b. Action

1. If a land use census identifies locations that yield a calculated dose or close commitment greater than the values currently being calculated in 6.3.4.a.2, identify the new locations in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports.

2. If a land use census identifies locations that yield a calculated dose or close commitment (via the same exposure pathway) 25 percent greater than at a location from which samples are currently being obtained, add the new locations to the Radiological Environmental Monitoring Program within 30 days. Sampling locations, excluding the control station location, that have the lowest calculated dose or dose commitments (via the same exposure pathway) may be deleted from the monitoring program. Identify new locations in the next Annual Radioactive Effluent Release Report and include in the report revised figures and tables reflecting the new locations in accordance with VPAP'-2802, Notifications and Reports. [Commitment 3.2.4]

6.6.3 Interlaboratory Comparison Program

a. Requirement Radioactive materials (which contain nuclides produced at the Station), supplied as part of an Interlaboratory Comparison Program, shall be analyzed.

DOMINION VPAF'-2103N REVISION 10 PAGE 33 OF 86

b. Action

1. Analyses shall be performed at least semiannually as follows:

Program Cross-Check of Milk 1131, Gamma, Sr89 and Sr90 Water Gross Beta, Gamma, I131, H3 (Tritium), Sr8 9 and Sr90 (blind - any combinations of above radionuclides) Air Filter Gross Beta, Gamma, Sr90

2. If analyses are not performed as required by Step 6.6.3.b., report in the Annual Radiological Environmental Operating Report in accordance with VPA]-2802, Notifications and Reports, the corrective actions taken to prevent recurrence.

c. Results Results shall be reported in the Annual Radiological Environmental MonitDring Report in accordance with VPAP-2802, Notifications and Reports.

6.7 Reporting Requirements 6.7.1 Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year. A single submittal may be made for the Station. Radiological Environmental Operating Reports shall include:

a. Summaries, interpretations, and analysis of trends of results of radiological environmental surveillance activities for the report period, including:

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports
• An assessment of the observed impacts of the plant operation on the environment
• Results of land use census per Step 6.6.2

DOMIiNION VPAP-2103N REVISION 10 PAGE 39 OF 86

b. Results of analysis of radiological environmental samples and of environmental radiation measurements taken per Step 6.6.1, Monitoring Program. Results shall be summarized and tabulated in the format of the table in the Radiological Assessment Branch Technical Position on Environmental Monitoring.

1. If some individual results are not available for inclusion with the report, the report shall be submitted, noting and explaining reasons for missing results.

2. Missing data shall be submitted in a supplementary report as soon as possible.

c. A summary description of the radiological environmental monitoring program.

d. At least two legible maps covering sampling locations, keyed to a table giving distances and directions from the centerline of one reactor. One map shall cover stations near the site boundary; a second shall include more distant stations.

e. Results of Station participation in the Interlaboratory Comparison Program, per Step 6.6.3.

f. Discussion of deviations from the Station's environmental sampling schedule per Radiological Environmental Monitoring Program (Attachment 9).

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment 1.) was not achievable.

6.7.2 Annual Radioactive Effluent Release Report

a. Requirement - Station Radioactive Effluent Release Reports covering operation of the units during the previous 12 months of operation shall be submitted before May 1 of each year. A single submittal may be made for the Station and should combine those secti ons that are common to both units. Radioactive Effluent Release Reports shall include:

1. A summary of quantities of radioactive liquid and gaseous effluents and solid waste released. Data shall be summarized on a quarterly basis following the format of Regulatory Guide 1.21, Appendix B, for liquid and gaseous effluents.

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Commitment 3.2.5]

DOMINION VPAP-2103N REVISION 10 PAGE 40 OF 86

2. An assessment of radiation doses to the maximum exposed members cf the public due to the radioactive liquid and gaseous effluents released from the Station during the previous calendar year. This assessment shall be in accordance with Step 6.7.2.b.

3. A list and description of unplanned releases from the site to unrestricted areas, during the reporting period, which meet the following criteria:

• Unplanned releases that exceeded the limits in Steps 6.2.1 and 6.3.1
• Unplanned releases which require a Plant Issue (Deviation) and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank
• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CFR 50.73, Licensee Event Report System, report is required
• Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Plant Issue (Deviation)

4. Major changes to radioactive liquid, gaseous, and solid waste treatment systems during the reporting period.

5. Changes to VPAP-2103N, Offsite Dose Calculation Manual (North Anna)

(See Step 6.7.4).

6. A listing of new locations for dose calculations or environmental monitoring identified by the land use census (See Step 6.6.2).

b. Dose Assessment

1. Radiation dose to individuals due to radioactive liquid and gaseous effluents from the Station during the previous calendar year shall either be calculated in accordance with this procedure or in accordance with Regulatory Guide 1.109.

Population doses shall not be included in dose assessments.

DOMINION VPAP-2103N REVISION 10 PAGE 41 OF 86

2. The dose to the maximum exposed member of the public due to radioactive liquid and gaseous effluents from the Station shall be incorporated with the dose assessment performed above. If the dose to the maximum exposed member of the public exceeds twice the limits of 6.2.3.a.1, 6.2.3.a.2, 6.3.3.a.1, or 6.3.4.a.1, the dose assessment shall include the contribution from direct radiation.

NOTE: NITREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CFR Part 190."

3. Meteorological conditions during the previous calendar year or historical annual average atmospheric dispersion conditions shall be used to determine gaseous pathway doses.

NOTE: The Annual Radioactive Effluent Report for the North Anna ISFSI is included as part of the North Anna Station Annual Radioactive Effluent Release Report.

c. ISFSI Dose Assessment

• Radiation dose to individuals due to radioactive liquid and gaseous efflunts during the previous calendar year shall either be calculated in accordance with this procedure or in accordance with Regulatory Guide 1.109. Population doses shall not be included in dose assessments.
• The dose to the maximum exposed member of the public due to radioactive liquid and gaseous effluents from the Station shall be incorporated with the dose assessment performed above. If the dose to the maximum exposed member of the public exceeds twice the limits of 6.2.3.a.1, 6.2.3.a.2, 6.3.3.a.1, or 6.3.4.a.1, the dose assessment shall include the contribution from direct radiation.
• Meteorological conditions during the previous calendar year or historical annual average atmospheric dispersion conditions shall be used to determine gaseous pathway doses.

6.7.3 Annual Meteorological Data

a. Meteorological data collected during the previous year shall be in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.

DOMINION VPAIP-2103N REVISION 10 PAGE 42 OF 86

b. Meteorological data shall be retained in a file on site and shall be made available to NRC upon request.

6.7.4 Changes to the ODCM Changes to the ODCM shall be:

a. Reviewed and approved by SNSOC and Site Vice President before implementation.

b. Documented. Records of reviews shall be retained as Station records.

Documentation shall include:

1. Sufficient information to support changes, together with appropriate analyses or evaluations justifying changes.

2. A determination that a change will not adversely impact the accuracy or reliability of effluent doses or setpoint calculations, and will maintain the level of radioactive effluent control required by:

• 10 CFR 20 Subpart D
• 40 CFR 190
• 10 CFR 50.36a
• 10 CFR 50, Appendix I

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

d. Submitted to the Management Safety Review Committee (MSRC) Coordinator.

[Commitment 3.2.1]

e. Submitted to NRC in accordance with VPAP-2802, Notifications and Reports.

DOMINION VPAP-2103N REVISION 10 PAGE 43 OF 86 7.0 RECORDS 7.1 The following individual and packaged documents and copies of any related correspondence completed as a result of the performance or implementation of this procedure are records. They shall be transmitted to Records Management in accordance with VPAP-1701, Records Management. Prior to transmittal, the sender shall assure that:

• Each record is packaged when applicable.
• QA program requirements have been fulfilled for Quality Assurance records.
• Each record is legible, completely filled out, and adequately identifiable to the item or activity involved.
• Each record is stamped, initialed, signed, or otherwise authenticated and dated, as required by this procedure.

7.1.1 Individual Records None 7.1.2 Record Packages

• Records of changes to the ODCM in accordance with Step 6.7.4
• Records of meteorological data in accordance with Step 6.7.3
• Records of sampling and analyses
• Records of radioactive materials and other effluents released to the environment
• Records of preventive maintenance, surveillances, and calibrations 7.2 The following documents completed as a result of the implementation of this procedure are not Quality Assurance records and are not required to be transmitted to Records Management.

None

DOMINION VPAIP-2103N REVISION 10 PAGE 44 OF 86 ATTACHMENT 1 (Page 1 of 2) Radioactive Liquid Effluent Monitoring Instrumentation Instrument M ninimumOperable Action 1.TLiquid Radwaste Effluent (a) I-LW-RM-1 11, Liquid Radwaste Effluent Monitor 1 1 (b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow Measuring Device 1 2 (c) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel 1 1 (d) 1-LW-1 130, Liquid Waste Effluent Proportional Sample Valve 1 1 (e) I-SW-RM-108, Service Water Effluent Monitor (Note 3) (Note 4) 1 1 (1) 1-SW-RM-130, Unit 1 Circulating Water System Effluent Line Monitor 1 4 (g) 2-SW-RM-230, Unit 2 Circulating Water System Effluent Line Monitor 1 4

2.

Tank Level Indicating Devices (Note 1) (a) Refueling Water Storage Tanks Unit 1 I-QS-LT-100A 1 3 1-QS-LT-l00B 1-QS-LT-100C I-QS-LT-lOOD Unit 2 2-QS-LT-200A 1 3 2-QS-LT-200B 2-QS-LT-200C 2-QS-LT-200D (b) Casing Cooling Storage Tanks Unit 1 1-RS-LT-103A 1 3 1-RS-LT-103B Unit 2 2-RS-LT-203A 1 3 2-RS-LT-203B (c) PG Water Storage Tanks (Note 2) 1-BR-LT-1 16A (1-PG-TK-lA) 1 3 1-BR-LT-116B (I-PG-TK-lB) 1 3 (cl) Boron Recovery Test Tanks (Note 2) 1-BR-LT-1 12A (1-BR-TK-2A) 1 3 1-BR-LT-112B (1-BR-TK-2B) 1 3

3.

Si'eam Generator High Capacity Blowdown (a) Steam Generator High Capacity Blowdown Radiation Monitor Unit 1 1-SS-RM-125 1 1 Unit 2 2-SS-RM-225 1 1 (E.) Steam Generator High Capacity Blowdown Flash Tank Outlet Flow Rate Unit 1 1-BD-FT-105 1 2 Unit 2 2-BD-FT-205 1 2 (c) Steam Generator High Capacity Blowdown Proportional Sampling System Collection Tank Unit 1 1-BD-TK-4 1 1 Unit 2 2-BD-TK-4 1 1

klI,

-i

DOMINION VPAP-2103N REVISION 10 PAGE 45 OF 86 ATTACHMENT 1 (Page 2 of 2) Radioactive Liquid Effluent Monitoring Instrumentation ACTION 1: ACTION 2: ACTION 3: ACTION 4: If the number of operable channels is less than required, effluent releases via this pathway may continue if, at least once within 12 hours, grab samples are collected and analyzed for gross radioactivity (beta and gamma) at an LLD of at least lxlO-17 jCi/g or an isotopic radioactivity at an LLD of at least 5x10-7 jICi/g. If the number of operable channels is less than required, effluent releases via this pathway may continue if the flow rate is estimated at least once per 4 hours during actual releases. Design capacity performance curves generated in situ may be used to estimate flow. If the number of operable channels is less than required, liquid additions to this tank may continue if the tank liquid level is estimated during all liquid additions to the tank. If the number of operable channels is less than required, make repairs as soon as possible. Effluent releases via this pathway may continue provided that, at least once per 12 hours, grab samples from the discharge canal are collected and analyzed for principal gamma emitters as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). NOTE 1: Tanks included in this requirement are those outdoor tanks that are not surrounded. by liners, dikes, or walls capable of holding the tank contents, and do not have overflows and surrounding area drains connected to the liquid radwaste treatment system. NOTE :2: This is a shared system between Unit 1 and Unit 2. NOTE :3: The capability for obtaining grab samples at least every 12 hours must exist. Grab samples shall commence if there is indication of radioactivity in the Service Water System or an indication from other radiation monitors in the Service Water System of an increase in radioactivity. NOTE 4: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, 0-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service. to

DOMINION VPAP-2103N REVISION 10 PAGE 46 OF 86 ATTACHMENT 2 (Page 1 of 3) Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel hannel Check Check Calibration T*,erational Test

1. Liquid Radwaste Effluent (a.)

l-LW-RM-l 11, Liquid Radwaste Effluent Monitor D D R Q (NOTE 1) (b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow D (NOTE 3) N/A R Q Measuring Device (c:) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel D (NOTE 9) N/A N/A N/A (d) 1-LW-1 130, Liquid Waste Effluent Proportional Sample D (NOTE 9) N/A N/A N/A Valve (e) 1-SW-RM-108, SW Effluent Monitor (NOTE 14) D M R Q (NOTE 2) (f) 1-SW-RM-130, Unit 1 Circulating Water System D M R Q (NOTE 2) Effluent Line Monitor (g) 2-SW-RM-230, Unit 2 Circulating Water System D M R Q (NOTE 2) Effluent Line Monitor

2.

Tank Level Indicating Device (NOTE 6) (a) Refueling Water Storage Tanks Unit 1 1-QS-LT-100A, 1-QS-LT-100B D (NOTE 4) N/A R Q (NOTE 7) Unt l -QS-LT-100C, 2-QS-LT-l00B 2-QS-LT-200C, 2-QS-LT-200D D (NOTE 4) N/A R Q (NOTE 7) (L) Casing Cooling Storage Tanks Unit 1 1-RS-LT-103A, 1-RS-LT-103B D (NOTE 4) N/A R Q (NOTE 7) Unit 2 2-RS-LT-203A, 2-RS-LT-203B D (NOTE 4) N/A R Q (NOTE 7) (c) PG Water Storage Tanks (NOTE 5) 1-BR-LT-1 16A (l-PG-TK-lA) D (NOTE 4) N/A R Q (NOTE 8) 1-BR-LT-116B (l-PG-TK-lB) D (NOTE 4) N/A R Q (NOTE 8) (d) Boron Recovery Test Tanks (NOTE 5) 1-BR-LT-1 12A (1-BR-TK-2A) D (NOTE 4) N/A R Q (NOTE 8) 1-BR-LT-112B (1-BR-TK-2B) D (NOTE 4) N/A R Q (N.OTE 8)

3.

Steam Generator (SG) High Capacity Blowdown (a) SG High Capacity Blowdown Radiation Monitor Unit 2 2-SS-RM-225 D (NOTE 12) D (NOTE 12) R Q (NOTE 01) Unit2 2-S-RM225R (NOTE 10) (b) SG High Capacity Blowdown Flash Tank Outlet Flow Rate Unit 2 1-BD-FT-105 D (NOTE 13) N/A R N/A (c) SG High Capacity Blowdown Proportional Samplin System Collection Tank Unit 1 1-BD-TK-4 D (NOTE 9) N/A N/A N/A Unit 2 2-BD-TK-4

DOMI NION VPAP-2103N REVISION 10 PAGE 47 OF 86 ATTACHMENT 2 (Page 2 of 3) PRadioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

a. Automatic isolation of this pathway and Control Room alarm annunciation occur if the instrument indicates measured levels above alarm / trip setpoint.

b. Alarm annunciation occurs if the instrument controls are not set in "operate" mode.

NOTE 2: The Channel Operational Test shall demonstrate that Control Room alarm annunciation occurs if any of the following conditions exists:

a. Instrument indicates measured levels above the alarm / trip setpoint.

b. Instrument controls not set in "operate" mode.

NOTE 3: Channel Check shall consist of verifying indication of flow during periods of release. Channel Check shall be made at least once per 24 hours on days on which continuous, periodic, or batch releases are made. NOTE 4: During liquid additions to the tank, verify indication of level change. NOTE 5: This is a shared system between Unit 1 and Unit 2. NOTE 6: Tanks included in this requirement are those outdoor tanks that are not surrounded b y liners, dikes, or walls capable of holding the tank contents and do not have overflows and surrounding area drains connected to the liquid radwaste treatment system. NOTE 7: The Channel Operational Test shall demonstrate that automatic isolation of this pathway and Control Room alarm annunciation occur if instrument indicates measured levels outside the alarm / trip setpoint. Demonstration of automatic isolation may consist of verifying the appropriate signal is generated. Valves need not be operated for this iest. NOTE :3: The Channel Operational Test shall demonstrate that Control Room alarm annunciation occurs if the instrument indicates measured levels are outside alarm setpoint. NOTE 9: Channel Check shall consist of verifying that proportional flow exceeds 0.5 mls/gallon. NOTE 10: Channel Operational Test shall demonstrate that system isolation occurs on a radiation monitor High-High Alarm. NOTE 11: Channel Operational Test shall demonstrate:

a. Trip signals are generated at the required setpoints. Isolation is not required.

b. Local radiation monitor indication occurs if instrument controls are not set in "Operate" mode or if the instrument indicates measured levels are above the alarm / trip setpoint.

DOMINION VPA]'-2103N REVISION 10 PAGE 48 OF 86 ATTACHMENT 2 (Page 3 of 3) IRadioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements NOTE 12: The radiation monitor automatically performs periodic source checks. The Source Check and Channel Check are satisfied as long as the green light is lit. NOTE 13: This is verified by indicated effluent flow less than or equal to 190 gpm. NOTE 14: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, 0-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

DOMINION VPA1'-2103N REVISION 10 PAGE 49 OF 86 ATTACHMENT 3 (Page 1 of 3) Radioactive Liquid Waste Sampling and Analysis Program Batch Releases (Notes 2 and 7) Continuous Releases (Note 5)

DOMINION VPAP-2103N REVISION 10 PAGE 50 OF 86 ATTACHMENT 3 (Page 2 of 3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 sb LLD = (9-1) E

• V
• 2.22E+06
• Y
• e-(X~)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.8) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm)l E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) X = the radioactive decay constant for the particular radionuclide At = the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and At should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE :2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and then thoroughly mixed as the situation permits, to assure representative sampling.

DOMINION VPAP-2103N REVISION 10 PAGE 51 OF 86 ATTACHMENT 3 (Page 3 of 3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn 4, Fe59, Co58, Co6 0, Zn6 5, Mo9 9, Cs134, Cs1 37, CeI4, and Ce144. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously in proportion to the rate of flow of the effluent stream. Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent releases. NOTE 7: Whenever the secondary coolant activity exceeds 10-5 gCi/ml, the turbine building sump pumps shall be placed in manual operation and samples shall be taken and analyzed prior to release. Secondary coolant activity samples shall be collected and analyzed on a weekly basis. These samples are analyzed for gross activity or gamma isotopic activity within 24 hours. NOTE 3: The gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, Xe-135m and Xe-138. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides shall also be identified and reported.

DOMINION VPAP-2103N REVISION 10 PAGE 52 OF 86 ATTACHMENT 4 (Page 1 of 4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Detection (LLD) Type Frequency Frequency Analysis (Ci/mI), (Note 1) P tncipa amma 1 1()4 A. Waste Gas (Each Tank Prior to Release Emitters (Note 2) Storage Tank Grab Sample) (Each Tank) Al 1 x 10-6 B. Containment Prior to Release Prior to Release Principle Gamma 1 x 104 Emitters (Note 2) Purge (Each PURGE (Each PURGE) H3 1 x 10-6 Purge Grab Sample). C. Ventilation Monthly Monthly Principle Gamma 1 x 104 (1) Process Vent (Grab Sample) Emitters (Note 2) (2) Vent Vent A (Notes 3, 4, and 5) (Note 3) H3 1 x 10-6 (3) Vent Vent B Continuous Weekly 1131 1 x 10.12 (Note 4) (Charcoal Sample) I3 1 x10 Continuous Weekly Principal Gamma 1 x 10. All Release (Note 4) Particulate Sample Emitter (Note 2) Continuous Monthly Types as listed (Not 4 Composite Gross Alpha 1 x 10 ote 4) Particulate Sample Continuous Quarterly r9adSox in A., B, and C (ote 4) Composite S an SrG 1 x 10 (NoteParticulate Continuous Noble Gas Monitor e ases ross 1 x 1C-6 (Note 4) Beta or Gamma Condenser Air Weekly Weekly rinerGamma I 1 x04 Ejector / Steam Emitters (Note 7) Generator Grab Sample H3 1 x10-6 Blowdown Vent / (Note 6) BIRT Vent Prnile.amI_1_ Containment Prior to Release Prior to each Emitters (Note 2) 1 Vacuum Steam (Grab Sample) ( e3 1 x 10-6 EjeCtor (Hogger) (GraoSmpe ) Release H 0

DOMINION VPAP-2103N REVISION 10 PAGE 53 OF 86 ATTACHMENT 4 (Page 2 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 sb E

• V
• 2.22E+06
• Y
• e(Xt)

(111) Where: LLD = the "a priori" (before the fact) LowerLimit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm') E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) X% = the radioactive decay constant for the particular radionuclide At = the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and At should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not as "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP -2103N REVISION 10 PAGE 54 OF 86 ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Ki87, Kr88, XeI33, XeI33m, XeI35, Xel3 5m, and Xe138 for gaseous emissions and Mn54, Fe59, co 58, co6 0, Zn65, Mo99, Cs13 4, Cs137, CeI4 1 and Ce1 44 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, if:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant is greater than 1.0 gCi/gm; and

b. The noble gas activity monitor shows that effluent activity has increased by more than a factor of 3.

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4. NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least seven days following each shutdown, start-up or thermal power change exceeding 15 percent of rated thermal power in one hour and analyses shall be completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of.10. This requirement applies if:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant is greater than 1.0 gCi/gm and;

b. Noble gas monitor shows that effluent activity has increased more than a factor of 3.

DOMINION VPA]'-2103N REVISION 10 PAGE 55 OF 86 ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 6: Whenever the secondary coolant activity exceeds 10-5 pCi/ml, Condenser Air Ejector and Steam Generator Blowdown Vent samples shall be obtained and analyzed weekly Secondary coolant activity samples shall be collected and analyzed on a weekly basis. These samples are analyzed for gross activity or gamma isotopic activity within 24 hours. NOTE 7: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Ki. 7 Kr88 Xe133, Xel3 3m, Xe135, Xel35m, and XeI3 8 for gaseous emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD togefter with the above nuclides, shall also be identified and reported. NOTE 8: If the secondary coolant activity level in any Steam Generator supplying steam to the Hogger exceeds 1.0E-5 pCi/ml, Steam Generator samples shall be obtained and analyzed prior to release.

DOMINION VPAP-2103N REVISION 10 PAGE 56 OF 86 ATTACHMENT 5 (Page 1 of 3) Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) x/Q = 9.3E-06 sec/m3 at 1416 meters SE Direction Dose Factors for Ventilation Vent .Kivv Livv Mivv

Nivj, NDble Gas Total Body Skin Gamma Air Beta Air Radionuclide mremlyr mrem/yr mrad/yr mradlyr Curie/sec Curie/sec Curie/sec Curie/sec Kr-85m 1.09E+04 1.36E+04 1.14E+04 1.83E+04 Kr-85 1.50E+02 1.25E+04 1.60E+02 1.81E+04 Kr-87 5.51E+04 9.05E+04 5.74E+04 9.58Eq+04 Kr-88 1.37E+05 2.20E+04 1.41E+05 2.72Et 04 Kr-89 1.54E+05 9.39E+04 1.61E+05 9.86Et+04 Xe-*131m 8.5 1E+02 4.43E+03 1.45E+03 1.03E-i-04 Xe.*133m 2.33E+03 9.24E+03 3.04E+03 1.38E-i-04 Xe-133 2.73E+03 2.85E+03 3.28E+03 9.77Eti03 Xe-135m 2.90E+04 6.61E+03 3.12E+04 6.87Et 03 Xe-135 1.68E+04 1.73E+04 1.79E+04 2.29E4t04 Xe-137 1.32E+04 1.13E+05 1.40E+04 1.18Et05 Xe-138 8.21E+04 3.84E+04 8.57E+04 4.42E4t04 Ar-41 8.22E+04 2.50E+04 8.65E+04 3.05Et04

DOMINION VPA]'-2103N REVISION 10 PAGE 57 OF 86 ATTACHMENT 5 (Page 2 of 3) Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) x/Q = 1.2E-06 sec/m3 at 1513 meters S Direction Dose Factors for Process Vent -Kipv iipv Mipv Nipr Noble Gas Total Body Skin Gamma Air Beta Air Radionuclide arermlyr mrem/yr mradlyr mradlyr Curie/sec Curie/sec Curie/sec Curie/sec Kr-85m 1.40E+03 1.75E+03 1.48E+03 2.36E+03 Kr-85 1.93E+01 1.61E+03 2.06E+01 2.34Et 03 Kr-87 7.1OE+03 1.17E+04 7.40E+03 1.24Et-04 Kr-88 1.76E+04 2.84E+03 1.82E+04 3.52E+03 Kr-89 1.99E+04 1.21E+04 2.08E+04 1.27Eti04 Xe-*131m 1.10E+02 5.71E+02 1.87E+02 1.33E+03 Xe-133m 3.01E+02 1.19E+03 3.92E+02 1.78Eti03 Xe-133 3.53E+02 3.67E+02 4.24E+02 1.26Et03 Xe-135m 3.74E+03 8.53E+02 4.03E+03 8.87E÷02 Xe-135 2.17E+03 2.23E+03 2.30E+03 2.95E+03 Xe-137 1.70E+03 1.46E+04 1.81E+03 1.52Et+04 Xe-138 1.06E+04 4.96E+03 1.1 lE+04 5.70Et03 Ar-41 1.06E+04 3.23E+03 1.12E+04 3.94E+03

DOMINION VPAP-2103N REVISION 10 PAGE 58 OF 86 ATTACHMENT 5 (Page 3 of 3) Gaseous Effluent Dose Factors (Inhalation Pathway Dose Factors) Ventilation Vent X/Q = 9.3E-06 sec/M3 at 1416 meters SE Direction Process Vent X/Q = 1.2E-06 sec/M3 at 1513 meters S Direction Pivv Pipv Radionuclide mrem/vr mremr/r Curie/sec Curie/sec H-3 1.05E+04 1.35E+03 Cr-51 7.95E+02 1.02E+02 Mn-54 ND ND Fe-59 ND ND Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-90 ND ND Y-91 ND ND Zr-95 ND ND Nb-95 ND ND Ru-103 ND ND Ru-106 ND ND Ag-110m ND ND Te-127m 5.64E+04 7.28E+03 Te-129m 5.88E+04 7.59E+03 Cs-134 ND ND Cs-136 ND ND Cs-137 ND ND Ba-140 ND ND Ce-141 ND ND Ce-144 ND ND I-131 1.51E+08 1.95E+07 I-133 3.58E+07 4.62E+06 ND - No data for dose factor according to Regulatory Guide 1.109, Revision 1

DOMINION VPAI?-2103N REVISION 10 PAGE 59 OF 86 ATTACHMENT 6 (Page 1 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE ACTION CHANNELS

1. PROCESS VENT SYSTEM (a)

Noble Gas Activity Monitor 1-GW-RM-178-1 1 2,4 (NOTE 3) (b) Iodine Sampler I-GW-RM-178-1 1 Process Vent Continuous HP Sampler (NOTE 3) 2, : (c) Particulate Sampler 1-GW-RM-178-1 125 Process Vent Continuous HP Sampler (NOTE 3) , 5 (d) Total Flow Monitor 1-GW-FT-108 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 1 HP Sampler Rotameter (NOTE 3)

2. CONDENSER AIR EJECTOR SYSTEM (a)

Gross Activity Monitor Unit 1 1-SV-RM-121 13 Unit 2 2-SV-RM-221 (b) Flow Rate Measuring Device Unit 1 I-SV-FI-100A 1-SV-FI-101A 1 (NOTE 1) 1 I-SV-FI-100B 1-S V-FI-101B Unit 2 2-SV-FI-200A 2-SV-FI-201A 1 (NOTE 2) 1 2-SV-FI-200B 2-S V-FI-201 B

DOMINION VPAP -2103N REVISION 10 PAGE (;0 OF 86 ATTACHMENT 6 (Page 2 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE ACTION CHANNELS

3. VENTILATION VENT A (a)

Noble Gas Activity Monitor 1-VG-RM-179-1 1 2 (NOTE 3) (b) Iodine Sampler 1-VG-RM-179-1 1 Vent Vent A Continuous HP Sampler (NOTE 3) 2 (c) Particulate Sampler 1-VG-RM-179-1 1 Vent Vent A Continuous HP Sampler (NOTE 3) 2 (d) Total Flow Monitor 1-HV-FT-1212A 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 HP Sampler Rotameter (NOTE 3)

4. VENTILATION VENT B (a)

Noble Gas Activity Monitor 1-VG-RM-180-1 1 2 (NOTE 3) (b) Iodine Sampler I-VG-RM-180-1 1 Vent Vent B Continuous HP Sampler (NOTE 3) 2 (c) Particulate Sampler 1-VG-RM-180-1 1 Vent Vent B Continuous HP Sampler (NOTE 3) 2 (cl) Total Flow Monitor 1-HV-FT-1212B 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 HP Sampler Rotameter NOTE 3 1

DOMINION VPAP-2103N REVISION 10 PAGE 61 OF 86 ATTACHMENT 6 (Page 3 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation ACTION 1: ACTION 2: ACTION 3: ACTION 4: ACTION 5: NOTE l: A If the number of operable channels is less than required, effluent releases, via this palh, may continue if the flow rate is estimated at least once per four hours. If the number of operable channels is less than required, effluent releases, via this palh, may continue if grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity or gamma isotopic activity within 24 hours. If the number of operable channels is less than required, effluent releases via this path may continue if grab samples are obtained in accordance with TRM TR 3.4.5 and these samples are analyzed for gross activity or gamma isotopic activity within eight hours. If the number of operable channels is less than required, the contents of the Waste Gas Decay Tanks may be released to the environment provided that prior to initiation of the release:

a. At least two independent samples of the tank's contents are analyzed, and:

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

If the number of operable channels is less than required, effluent releases from the Wiste Gas Decay Tank may continue provided samples are continuously collected with auxiliary sampling equipment as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). channel shall consist of:

a. The flow instrument installed in the ejector through which the discharge is routed; either Train A (1-SV-FI-1OA, lOlA), or Train B (l-SV-FI-IOOB, lOiB) or both.

b. Flow instruments lOlA and lOlB provide low range measurement. Flow instruments lOQA and 1 OOB provide high range measurement.

NOTE 2: A channel shall consist of:

a. The flow instrument installed in the ejector through which the discharge is routed; either Train A (2-SV-FI-200A, 201A), or Train B (2-SV-FI-200B, 201B) or both.

b. Flow instruments 201A and 201B provide low range measurement. Flow instruments 200A and 200B provide high range measurement.

NOTE 3: A channel shall consist of a MGPI monitor; and a MGPI or HP particulate and iodine sampler, and its associated sampler flow rate measuring device or rotameter.

DOMINION VPAP-2103N REVISION 10 PAGE (62 OF 86 ATTACHMENT 7 (Page 1 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHNEDSRPINCHANNEL SOURCE CHANNEL Channel CIANNEL DESCRIPTIN CIHECK CHECK CALIBRATION Operational Test

1. PROCESS VENT SYSTEM (a)

Noble Gas Activity Monitor l-GW-RM-178-1 D M (NOTE 5) R Q (NOTE 1) (b) Iodine Sampler 1-GW-RM-178-1 W N/A N/A N/A Process Vent Continuous HP Sampler D (NOTE 3) N/A N/A NA (c) Particulate Sampler 1-GW-RM-178-1 W N/A N/A N/A Process Vent Continuous HP Sampler D (NOTE 3) N/A N/A N/A (d) Total Flow Monitor 1-GW-FT-108 D N/A R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE 3) N/A R N/A Device HP Sampler Rotameter D (NOTE 3) N/A SA N/A

2. CONDENSER AIR EJECTOR SYSTEM (a)

Noble Gas Activity Monitor Unit 1 1-SV-RM-121 D M R Q (NOTE 1) Unit 2 2-SV-RM-221 (b) Flow Rate Measuring Device Unit 1 I-SV-FI-100A 1-SV-FI-101A D N/A R N/A 1-SV-FI-l OlB 1-S V-FI-I01B Unit 2 2-SV-FI-200A 2-S V-FI-201A D N/A R N/A 2-SV-FI-200B 2-S V-FI-201B

DOMINION VPA]'-2103N REVISION 10 PAGE (13 OF 86 ATTACHMENT 7 (Page 2 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL SOURCE C11ANNEL Channel CIANNEL DESCRIPTION CHECK CHECK CALIBRATION Operational Test

3.

VENTILATION VENT A (z.) Noble Gas Activity Monitor 1-VG-RM-179-1 D M (NOTE 5) R Q (NOTE 2) (b) Iodine Sampler 1-VG-RM-179-1 W N/A N/A N/A Vent Vent A Continuous HP Sampler D (NOTE 3) N/A N/A N/A (c) Particulate Sampler 1 -VG-RM-179-1 W N/A N/A N/A Vent Vent A Continuous HP D N/AE 3 Sampler D (NOTE 3) N/A N/A N/A (d) Total Flow Monitor 1-HV-FT-1212A D N/A R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE 3) N/A R N/A Device HP Sampler Rotameter D (NOTE 3) N/A SA N/A

4. VENTILATION VENT B (a)

Noble Gas Activity Monitor 1-VG-RM-180-1 D M (NOTE 5) R Q (NOTE 2) (b) Iodine Sampler 1-VG-RM-180-1 W N/A N/A NXA Vent Vent B Continuous HP Sampler D (NOTE 3) N/A N/A N.A (c) Particulate Sampler 1-VG-RM-180-1 W N/A N/A N.A Vent Vent B Continuous HP Sampler D (NOTE 3) N/A N/A N.'A (d) Total Flow Monitor 1-HV-FT-1212B D N/A R ( (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE 3) N/A R NA Device HP Sampler Rotameter D (NOTE 3) N/A SA N/A

DOMINION VPAP -2103N REVISION 10 PAGE (4 OF 86 ATTACHMENT 7 (Page 3 of 3) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

a. Automatic actuation of the valves in this pathway and Control Room alarm annunciation occur if the instrument indicates measured levels above the alarm / trip setpoint.

b. Alarm annunciation occurs if the instrument controls not set in "operate" mode.

NOTE 2: The Channel Operational Test shall demonstrate:

a. Control Room alarm annunciation occurs if the instrument indicates measured levels are above the alarm / trip setpoint.

b. Alarm annunciation occurs if the instrument controls not set in "operate" mode.

NOTE 3: Channel Checks shall consist of verifying indication of flow during periods of release. Channel Checks shall be made at least once per 24 hours on days on which continuous, periodic, or batch releases are made. Verification need only to be done to verify operability of one train, either MGPI or HP Sampler. NOTE 4: The Channel Operational Test shall demonstrate that:

a. Control Room alarm annunciation occurs if the instrument indicates measured levels are above alarm / trip setpoint.

b. The Instrument mode selection control automatically resets to "operate" mode when released.

NOTE 5: Monitors 1-GW-RM-178-1, 1-VG-RM-179-1, and 1-VG-RM-180-1 perform periodic source checks automatically.

DOMINION VPAP-2103N REVISION 10 PAGE 65 OF 86 ATTACHMENT 8 (Page 1 of 2) Critical Organ Dose Factors (Critical Pathway Dose Factors) Ventilation Vent X/Q = 3.9E-6 at 1432 meters NE Direction Process Vent X/Q = 9.5E-7 at 1432 meters NE Direction Ventilation Vent D/Q = 1.9E-8 at 1432 meters NE Direction Process Vent D/Q = 9.3E-9 at 1432 meters NE Direction Rmivv KMipv Radionuclide rremlyr mremlyr Curie/sec Curie/sec H-3 1.56E+4 3.81E+3 Mn-54 ND ND Fe-59 ND ND Cr-S1 1.24E+3 6.05E+2 Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-89 ND ND Sr-90 ND ND Y-91 ND ND Zr-95 ND ND Nb-95 ND ND Ru-103 ND ND Ru-106 ND ND Ag-110m ND ND Te-127m 6.01E+6 2.94E+6 Te-129m 5.15E+6 2.52E+6 I-131 9.03E+8 4.42E+8 I-133 1.54E+7 7.55E+6 Cs-134 ND ND Cs-136 ND ND Cs-137 ND ND Ba-140 ND ND Ce-141 ND ND 1°^ -a

DOMINION VPA1P-2103N REVISION 10 PAGE 66 OF 86 ATTACHMENT 8 (Page 2 of 2) Critical Organ Dose Factors xmivv RMipv Radionuclide mrem/yr mrem/vr Curie/sec Curie/sec Ce-144 ND ND NE - No data for dose factor according to Regulatory Guide 1.109, Revision 1

DOMINION VPA]?-2103N REVISION 10 PAGE 67 OF 86 ATTACHMENT 9 (Page 1 of 5) Radiological Environmental Monitoring Program Exposure Pathway I Number ot Sample and Collection 1 ype and 1'requency ot-an(Uor Sample Sample Location (NOTE 2)1 Frequency I Analysis

1. LJlkellI RADIATION (NOTE 3) 36 routine monitoring stations, either with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, to be placed as follows:

1) An inner ring of stations, one in each emergency meteorological sector within the site boundary

2) An outer ring of stations, one in each emergency meteorological sector within 8 km range from the site

3) The balance of the stations to be placed in special interest areas such as population centers, nearby residences, schools, and in 1 or 2 areas to serve as control stations GAMMA DOSE Quarterly Quarterly

DOMINION VPAP-2103N REVISION 10 PAGE (68 OF 86 ATTACHMENT 9 (Page 2 of 5) Radiological Environmental Monitoring Program Exposure.Pathway Number ot Sample and Collection Type and Frequency ot and/or Sample Sample Location (NOTE 2) Frequency Analysis 7 =.ALBOhN~E Samples from 5 locations: a) 3 samples from close to the 3 site boundary locations (in different sectors) of the highest R 3o Analysis, weekly calculated historical annual average ground Continuous Radi.oiodines and level D/Q

sampler, Particulates b) 1 sample from the operation with vicinity of a community sample collection Particulate Sampler having the highest weekly Gross beta radioactivity calculated annual analysis following filter average ground level change; (NOTE 4)

D/Q c) 1 sample from a control Gamma isotopic analy-location 15-40 km sis of composite (by distant and in the least location) quarterly prevalent wind direction (NOTE 5)

3. aTlElBdRNE!

Samples from 3 locations: Isample upstream Gamma isotopic analysis a) monthly; (NOTE 5) a) Surface b) 1 sample downstream Grab Monthly Composite for tritium c) 1 sample from cooling analysis quarterly lagoon 1 or s(amma isotopic and tritium b) Ground onSample from ol 2 sources Grab Quarterly analysis quarterly (NOTE donly if likely to be affected 5) 1 sample from downstream Gamma isotopic analysis c) Sediment area with existing or Semi-Annually semi-annually (NOTE 5) potential recreational value

DOMINION VPAP-2103N REVISION 10 PAGE (19 OF 86 ATTACHMENT 9 (Page 3 of 5) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location (NOTE 2) Frequency Analysis 4.l4ES l 3 ) a) Samples from milking animals in 3 locations within 5 km that have the highest potential. If there are none, then 1 sample from milking animals in each of 3 areas a) Milk between 5 to 8 km where Monthly at all Gamma isotopic (NOTE 5) (NOTE 7) doses are calculated to be times and I131 analysis monthly greater than 1 mrem per yr (NOTE 6) b) 1 sample from milking animals at a control location (15-30 km in the least prevalent wind direction) a) 1 sample of commercially and recreationally important species (bass, sunfish, catfish) b) Fish and in vicinity of plant discharge Semiannually Gamma isotopic on edible Invertebrates area portions b) 1 sample of same species in areas not influenced by plant discharge a) Samples of an edible broad leaf vegetation grown nearest each of two different offsite locations of highest predicted historical annual average Monthly if c) ground level D/Q if milk available, or Gamma isotopic (NOTE 5) sampling is not performed at harvest and I analysis b) 1 sample of broad leaf vegetation grown 15-30 km in the least prevalent wind direction if milk sampling is not performed

DOMINION VPAP-2103N REVISION 10 PAGE 70 OF 86 ATTACHMENT 9 (Page 4 of 5) Radiological Environmental Monitoring Program NOTE 1: The number, media, frequency, and location of samples may vary from site to site. This table presents an acceptable minimum program for a site at which each entry is applicable. Local site characteristics must be examined to determine if pathways not covered by this table may significantly contribute to an individual's dose and be included in the sampling program. NOTE 2: For each and every sample location in Environmental Sampling Locations (Attachment 10), specific parameters of distance and direction sector from the centerline of the reactor, and additional description where pertinent, shall be provided in Attachment 10. Refer to Radiological Assessment Branch Technical Positions and to NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plant. Deviations are permitted from the required sampling schedule if specimens are unattainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons. If specimens are unattainable due to sampling equipment malfunction, every effort shall be made to complete corrective action before 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 Step 6.7.1. It is recognized that, 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. In lieu of a Licensee Event Report and pursuant to Step 6.7.2, identify the cause of the unavailability of samples for that pathway and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report, and include revised figures and tables from the ODCM reflecting the new locations in the report.

DOMINION VPAP-2103N REVISION 10 PAGE 71 OF 86 ATTACHMENT 9 (Page 5 of 5) Radiological Environmental Monitoring Program NOTE 3: 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 the 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. Film badges shall not be used as dosimeters for measuring direct radiation. The 36 stations are not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations, e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading. NOTE 4: Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than ten times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. NOTE 5: Gamma isotopic analysis is the identification and quantification of gamma-emitting radionuclides that may be attributable to effluents from the facility. NOTE 6: The dose shall be calculated for the maximum organ and age group, using the methodology and parameters in the ODCM. NOTE 7: If milk sampling cannot be performed, use item 4.c (Page 3 of 5, Radiological Environmental Monitoring Program (Attachment 9)).

DOMINION VPAP-2103N REVISION 10 PAGE 72 OF 86 ATTACHMENT 10 (Page 1 of 4) Environmental Sampling Locations Distance and Direction From Unit No. 1 Media Location 1Station Distance iCollection [ Remarks . Me I No. I (Miles)I IFrequency_ Environmental NAPS Sewage TLDs Treatment Plant 01 0.20 NE Quarterly & Annually On-Site Frederick's Hall 02 5.30 SSW Quarterly& Annually Mineral,VA 03 7.10 WSW Quarterly & ____A nnually Wares Crossroads 04 5.10 WNW Quarterly & Annually Route 752 05 4.20 NNE Quarterly& Annually Sturgeon's Creek 05A 2.04 N Quarterly & Marina Annually Levy, VA 06 4.70 ESE Quarterly & ________Annually Bumpass, VA 07 7.30 SSE Quarterly& ________Annually End of Route 685 21 1.00 WNW Quarterly & Site Boundary ___A nnually Route 700 22 1.00 WSW Quarterly& Site Boundary Annually "Aspen Hills" 23 0.93 SSE Quarterly& Site Boundary ____A nnually Orange, VA 24 22.00 NW Qualerly & Control A n n u ally Bearing Cooling Towe N-1/33 0.06 N Quarterly On-Site Sturgeon's Creek N-2/34 2.04 N Quarterly Marina Parking Lot "C" NNE-3/35 0.24 NNE Quarterly On-Site Good Hope Church NNE-4/36 3.77 NNE Quarterly Parking Lot "B" NE-5/37 0.20 NE Quarterly On-Site Bogg's Drive NE-6/38 1.46 NE Quarterly Weather Tower Fence ENE-7/39 0.36 ENE Quarterly On-Si te Route 689 ENE-8/40 2.43 ENE Quarterly Near Training Facility E-9/41 0.30 E Quarterly On-Si :e "Morning Glory Hill" TE-1074T 2.85 E Quarterly Island Dike I SE-11/43 ().12 ESE IQuarterly On-Sife Route 62.2 E SEE12/ 4.70 ESE lQuarterlyI

DOMINION VPA]'-2103N REVISION 10 PAGE 73 OF 86 ATTACHMENT 10 (Page 2 of 4) Environmental Sampling Locations Distance and Direction From Unit No. 1 Saple Location Station Distance TDirection Collection Remarks IM edia I_________I___ No. I (M iles) I ______Frequencyl______ Environmental TLDs Biology Lab SE-13/45 0.64 SE Quarterly On-Site Route 701 (Dam Entrance) SE-14/46 5.88 SE Quarterly "Aspen Hills" SSE-15/47 0.93 SSE Quarterly Boundary Elk Creek SSE-16/48 2.33 SSE Quarterly NAPS Access Road S-17/49 0.47 S Quarterly On-Site Elk Creek Church S-18/50 1.55 S Quarterly.- NAPS Access Road SSW-19/51 0.42 SSW Quarterly On-Site Route 618 SSW-20/52 5.30 SSW Quarterly = = 500KV Tower SW-21/53 0.60 SW Quarterly On-Site Route 700 SW-22/54 3.96 SW Quarterly.- NAPS Radio Tower WSW-23/55 0.38 WSW Quarterly On-Site Route 700 WSW-24/56 1.00 WSW Quarterly Boundary South Gate of W-25/57 0.32 W Quarterly On-Site Switchyard Route 685 W-26/58 1.55 W Quarterly End of Route 685 WNW-27/59 1.00 WNW Quarterly site Boundary Route 685 WNW-28/60 1.40 WNW Quarterly Laydown Area North NW-29/61 0.45 NW Quarterly On-Site G ate Lake Anna Campground NW-30/62 2.54 NW Quarterly

1. 1/#2 Intake NNW-31/63 0.07 NNW Quarterly On-Site Route 208 NNW-32/64 2.21 NNW Quarterly Bumpass Post Office C-1/2 7.30 SSE Quarterly Orange, VA C-3/4 22.00 NW Quarterly Control Mineral, VA C-5/6 7.10 WSW Quarterly Louisa, VA C-7/8 11.54 WSW Quarterly IControl

DOMINION VPAl'-2103N REVISION 10 PAGE 74 OF 86 ATTACHMENT 10 (Page 3 of 4) Environmental Sampling Locations Distance and Direction From Unit No. 1 S-a-iple LotatniERon-1-isitEaine DrcinCollection Reak Media No. (Miles) D Frequency Remarks Airborne NAPS Sewage 01 0.20 NE Weekly On-Site Treatment Plant Particulate Frederick's Hall 02 5.30 SSW Weekly and Mineral, VA 03 7.10 WSW Weekly Radioiodine Wares Crossroads 04 5.10 WNW Weekly Route 752 05 4.20 NNE Weekly Sturgeon's Creek 05A 2.04 N Weekly Marina Levy, VA 06 4.70 ESE Weekly Bumpass, VA 07 7.30 SSE Weekly End of Route 685 21 1.00 WNW Weekly Site Boundary Route 700 22 1.00 WSW Weekly Site Boundary "Aspen Hills" 23 0.93 SSE Weekly Site Boundary Orange, VA 24 22.00 NW Weekly Control Surtace Water Waste Heat Treatment [Commitment Facility (Second 08 3.37 SSE Monthly 3.:!.21 Cooling Lagoon) North Anna River (upstream) Rt 669 09A 12.9 WNW Monthly Control Bridge (Brook's Bridge) North Anna River 11 5.80 SE Monthly (downstream) (well water) Biology Lab 01A 0.64 SE Quarterly Aquatic Waste Heat Treatment Sediment Facility (Second 08 3.37 SSE Semi-Annually Cooling Lagoon)____ North Anna River (upstream) Rt 669 09A 12.9 WNW Semi-Annually Control Bridge (Brook's Bridge) North Anna River 11 5.80 SE Semi-Annually (downstream) Shoreline Soil Lake Anna 08 3.37 SSE Semi-Annually Soil NAPS Sewage 01 0.20 NE Once per 3 yrsOn-Site Treatment Plant 0 I

DOMINION VPAP-2103N REVISION 10 PAGE 75 OF 86 ATTACHMENT 10 (Page 4 of 4) Environmental Sampling Locations Distance and Direction From Unit No. 1 Sample Location Station Distance Direction Collection Remarks Media No. (Miles) Frequency gir il Fredericks Hall 0T2 -5.3( SSW-Once per 3 yrs (continued) Mineral, VA 03 7.10 WSW Once per 3 yrs Wares Crossroads 04 5.10 WNW Once per 3 yrs Route 752 05 4.20 NNE Once per 3 yrs Sturgeon's Creek 05A 2.04 N Once per3yrs Marina 0A 20_Ocpr3_ Levy, VA 06 4.70 ESE Once per 3 yrs Bumpass, VA 07 7.30 SSE Once per 3 yrs End of Route 685 21 1.00 WNW Once per 3 yrs Site Boundary Route 700 22 1.00 WSW Once per 3 yrs Site Boundary "Aspen Hills" 23 0.93 SSE Once per 3 yrs Site Boundary Orange, VA 24 22.00 NW Once per 3 yrs Control Milk Holladay Dairy 12 8.30 NW Monthly (R.C. Goodwin) Terrell's Dairy 13 5.60 SSE Monthly (Frederick's Hall) Waste Heat Treatment Fish Facility (Second 08 3.37 SSE Semi-Annually Cooling Lagoon) Lake Orange 25 16.50 NW Semi-Annually Control Food Products Bel Aire Plantation 14 varies NE Monthly (Edible if available, broadleaf Route 614 15 varies SE or at harvest vegetationa) I Route 629 / 522 16 varies NW Control Historic Ln 26 varies S "Aspen Hills" Area 23 varies SSE

a. If edible broadleaf vegetation is unavailable, non-edible vegetation of similar leaf characteristics may be substituted.

DOMINION VPAP-2103N REVISION 10 PAGE 7i6 OF 86 ATTACHMENT 11 (Page 1 of 2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Airborne Fish Food Analysis Water Particulate Fish Milk Products Sediment (NOTE 2) (pCi/I) or Gases (pCi/I) (pCi/kg) (pry ) (pCi/rn3) (wet) (wet) (dry) Gross beta 4 0.01 H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 NE-95 15 I-1]31 (NOTE 3) 1 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also b-identified and reported. NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/l.

DOMINION VPAP-2103N REVISION 10 PAGE W OF 86 ATTACHMENT 11 (Page 2 of 2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) (NOTE 3) NOTE 3: For a particular measurement system (which may include radiochemical separation): 4.66 sb E

• V
• 2.22E+06
• Y
• e-(X/t)

(25-1) Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb= the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V

the sample size (in units of mass or volume) 2.22E+06

the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) X = the radioactive decay constant for the particular radionuclide At = the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples) Typical values of E, V, Y and At should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPA]'-2103N REVISION 10 PAGE 78 OF 86 ATTACHMENT 12 (Page 1 of 1) Reporting Levels for Radioactivity Concentrations in Environmental Samples Water Airborne Fish Milk Food Products Analysis (pCi/l) Particulate or (pCi/kg, wet) (pCi/l) (pCi/kg, wet) 14-3 (NOTE 1) 20,000 Mn-54 1,000 30,000 F.->59 400 10,000 Co-58 1,000 30,000 CD-60 300 10,000 Zni-65 300 20,000 Zr-Nb-95 400 i-131 2 0.9 3 100 Cs-134 30 10 1,000 60 1,0(0 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 NOTE 1: For drinking water samples

DOMINION VPAP-2103N REVISION 10 PAGE 79 OF 86 ATTACHMENT 13 (Page 1 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEOROLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the annual average X/Q and D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (mixed mode) releases. The annual average X/Q and D/Q values were used to perform a dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public. The X/Q and D/Q values resulting in the maximum exposures were incorporated into the dose factors in Gaseous Effluent Dose Factors (Attachment 5) and Critical Organ Dose Factors (Attachment 8). 1.2 Meteorological Data, Parameters, and Methodology Onsite meteorological data for the period January 1, 1981, through December 31, 1981, were used in calculations. These data included wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (e.g., ventilation vent), and those characterized as mixed mode (i.e., process vent). The portions of release characterized as ground level were based on AT158.9ft-28.2ft and 28.2 foot wind data, and the portions characterized as mixed mode were based on AT158.9ft-28.2ft and 158.9 ft wind data. X/Q's and D/Q's were calculated using the NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations," September, 1977. The code is based upon a straight line airflow model implementing the assumptions outlined in Section C (excluding Cla and Clb) of Regulatory Guide 1.11 1, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors." The open terrain adjustment factors were applied to the %/Q values as recommended i n Regulatory Guide 1.111. The site region is characterized by gently rolling terrain so open terrain correction factors were considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area.

DOMINION VPAP-2103N REVISION 10 PAGE EO OF 86 ATTACHMENT 13 (Page 2 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis The effective release height used in mixed mode release calculations was based on a process vent release height of 157.5 ft, and plume rise due to momentum for a vent diameter of 3 in. with plume exit velocity of 100 ft/sec. Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from North Anna Power Station Units 1 and 2, Virginia Electric and Power Company Final Safety Analysis Report Table 1 lC.2-8. X/Q and D/Q values were calculated for the nearest site boundary, resident, milk cow., and vegetable garden by sector for process vent and ventilation vent releases at distances specified from North Anna Power Station Annual Environmental SurveyData for 1981. X/Q values were also calculated for the nearest lake shoreline by sector for the process vent and ventilation vent releases. According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges. However, these releases are considered long term for dose calculations as past releases were both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. The X/Q and D/Q values calculated from 1981 meteorological data are comparable to the values presented in the North Anna Power Station UFSAR. 1.3 Results The X/Q value that resulted in the maximum total body, skin and inhalation exposure for ventilation vent releases was 9.3E-06 sec/m3 at a site boundary location 1416 meters SE sector. For process vent releases, the site boundary X/Q value was 1.2E-06 sec/m3 at a location 1513 meters S sector. The shoreline X/Q value that resulted in the maximum inhalation exposure for ventilation vent releases was 1.OE-04 sec/m3 at a location 274 meters NNE sector. The shoreline X/Q value for process vent was 2.7E-06 sec/m3 at a location 274 meters NNE sector.

DOMINION VPA]?-2103N REVISION 10 PAGE 81 OF 86 ATTACHMENT 13 (Page 3 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis The original pathway analysis indicated that the maximum exposure from I131, 1133, and from all radionuclides in particulate form with half-lives greater than 8 days was through the grass-cow-milk pathway. The D/Q value from ventilation vent releases resulting in the maximum exposure was 2.4E-09 per m2 at a location 3250 meters N sector. For process vent releases, the D/Q value was 1.1E-09 per m2 at a location 3250 meters N sector. For tritium, the X/Q value from ventilation vent releases resulting in the maximum exposure for the milk pathway was 7.2E-07 sec/m3, and 3.9E-07 sec/m3 for process vent releases at a location 3250 meters N sector. Analysis using 2003 release data indicates that the most limiting critical organ is the child's thyroid. The location is 1432 meters NE sector. For process vent releases, the D/Q is 1.9E-8. For tritium releases, the X/Q values at this location are 9.5E-7 for the process vent and 3.9E-6 for the ventilation vents. 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent releases. The analysis includes a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2. 2.2 Data, Parameters, and Methodology Initially, radioactive liquid effluent release data for the years 1979, 1980, and 1981 were compiled from the North Anna Power Station semi-annual effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-0133.

DOMINION VPAP -2103N REVISION 10 PAGE E;2 OF 86 ATTACHMENT 13 (Page 4 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis Re-concentration of effluents using the small lake connected to larger water body model was selected with the appropriate parameters determined from Table 3.5.3.5, Design Data for Reservoir and Waste Heat Treatment Facility from Virginia Electric and Power Company, Applicant's Environmental Report Supplement, North Anna Power Station, Units 1 and 2, March 15, 1972. Dilution factors for aquatic foods, shoreline, and drinking water were set to one. Transit time calculations were based on average flow rates. All other parameters were defaults selected by the LADTAP computer code. Beginning in 1997, the activity by nuclide released in the previous year is entered into the North Anna Power Station liquid pathway critical organ calculations spreadsheet, which calculates the most limiting age group total body and critical organ. This Process is repeated annually. 2.3 Results Initially, the fish pathway resulted in the largest dose. The critical organ each year was the liver, and the adult and teenage age groups received the same organ dose. However, since the adult total body dose was greater than the teen total body dose for each year, the adult was selected as the most restrictive age group. Beginning in 1997, the most limiting age group for both total body and critical organ is calculated from the spreadsheet for North Anna Power Station liquid pathway critical organ calculations.

DOMINION VPAP-2103N REVISION 10 PAGE 83 OF 86 ATTACHMENT 13 (Page 5 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose A gaseous effluent pathway analysis was performed to determine the location that would result in the maximum doses due to noble gases for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analysis also included a determination of the critical pathway, location of maximum exposed member of the public, and the critical organ for the maximum dose due to 1131, I133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for use in demonstrating compliance with requirements in Step 6.3.4.a. 1. In addition, the analysis included a determination of the critical pathway, maximum age group, and sector location of an exposed individual through the inhalation pathway from I131, I133, tritium, and particulates with half-lives greater than 8 days to demonstrate compliance with Step 6.3.1.a. 3.2 Data, Parameters, and Methodology Annual average X/Q values were calculated, as described in Section 1 of this attachment, for the nearest site boundary in each directional sector and at other critical locations beyond the site boundary. The largest X/Q value was determined to be 9.3E-06 sec/m3 at site boundary for ventilation vent releases at a location 1416 meters SE direction, and 1.2E-06 sec/m3 at site boundary for process vent releases at a location 1513 meters S direction. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases, would be at these site boundary locations. The doses from both release points are summed in calculations to calculate total maximum dose. Step 6.3.1.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X/Q values determined for maximum noble gas doses can be used to determine the maximum dose from 1131, 1133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway.

DOMINION VPAP-2103N REVISION 10 PAGE 84 OF 86 ATTACHMENT 13 (Page 6 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis The NRC computer code GASPAR, "Evaluation of Atmospheric Releases," Revised 3/19177, was run using 1979, 1980 and 1981 North Anna Power Station Gaseous Effluent Release Report data. Doses from 1131, 1133, tritium, and particulates for the inhalation pathway were calculated using the 9.3E-06 sec/m3 site boundary X/Q. Except for the source term data and the X/Q value, computer code default parameters were used. Results for each year indicated that the critical age group was the child and the critical organ was the thyroid for the inhalation pathway. The gamma and beta dose factors Kivv, Livv, Mivv, and Nivv in Gaseous Effluent Dose Factors (Attachment 5) were obtained by performing a units conversion of the appropriate dose factors from Table B-1, Regulatory Guide 1.109, Rev. 1, to mrem/yr per Ci/m3 or mrad/yr per Ci/m3, and multiplying by the ventilation vent site boundary X/Q value of 9.3E-06 sec/iM3. The same approach was used in calculating the gamma and beta dose factors KipV Lipvg Mjpv and Nipv in Gaseous Effluent Dose Factors (Attachment 5) using the process vent site boundary X/Q value of 1.2E-06 sec/m3. The inhalation pathway dose factors Pivv and Pipv in Gaseous Effluent Dose Factors (Attachment 5) were calculated using the following equation: Pi= K'(BR) DFAi (X/Q) (mrem/yr per Curie/sec) (29-1) where: K' = a constant of unit conversion, IE+12 pCi/Ci BR = the breathing rate of the child age group, 3700 m3/yr, from Table E-5, Regulatory Guide 1.109, Rev.1 DFA; = the thyroid organ inhalation dose factor for child age group for the ith radionuclide, in mrem/pCi, from Table E-9, Regulatory Guide 1.109, Rev. 1 X/Q = the ventilation vent site boundary X/Q, 9.3E-06 sec/m3, or the process vent site boundary X/Q, 1.2E-06 sec/m3, as appropriate

DOMINION VPAP-2103N REVISION 10 PAGE 85 OF 86 ATTACHMENT 13 (Page 7 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis Step 6.3.4.a., requires that the dose to the maximum exposed member of the public from 1131, 1133, tritium, and from all radionuclides in particulate form with half-lives greater than 8 days be less than or equal to the specified limits. Dose calculations were performed for an exposed member of the public within site boundary unrestricted areas, and to an exposed member of the public beyond site boundary at locations identified in the North Anna Power Station Annual Environmental Survey Data for 1981. It was determined that the member of the public within site boundary would be using Lake Anna for recreational purposes a maximum of 2232 hours per year. It is assumed that this member of the public would be located the entire 2232 hours at the lake shoreline with the largest annual X/Q of 1.0E-04 at a location 274 meters NNE sector. The NRC computer code GASPAR was run to calculate the inhalation dose to this individual. The GASPAR results were corrected for the fractional year the member of the public would be using the lake. Using the NRC computer code GASPAR and annual average %/Q and D/Q values obtained as described in Section 1 of this attachment, the member of the public receiving the largest dose beyond site boundary was determined to be located 1432 meters N sector. The critical pathway was vegetation, the maximum exposed age group was the child, and the critical organ was the thyroid. Pathway analysis results indicate that existing pathways, including ground and inhalation, within five miles of North Anna Power Station, yield Ri dose factors less than those determined for the vegetation. [Commitment 3.2.3] The RMivv and RMipv dose factors, except for tritium, in Critical Organ Dose Factors (Attachment 8) were calculated by multiplying the appropriate D/Q value with the following equation: RM = K'[ X (DFLi)][U CFLe XtL+ Usf e-Xith (29-2) where: K' = a constant of unit conversion, IE+12 pCi/Ci Yv = vegetable areal density in Kg/m2

DOM]NION VPAP-2103N REVISION 10 PAGE 86 OF 86 ATTACHMENT 13 (Page 8 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis Ucd = child leafy vegetable consumption rate, 26 Kg/yr UCS = child stored vegetable consumption rate, 520 Kg/yr r = fraction of deposited activity retained on vegetation, 1.0 for radioiodine, and 0.2 for particulates DFLj = thyroid ingestion dose factor for the ith radionuclide for the child, in mrem/pCi, from Table E-13, Regulatory Guide 1.109, Rev. 1 = decay constant for the ith radionuclide, in sec-1, from Kocher Xw = decay constant for removal of activity of leaf and plant surfaces by weathering, 5.73E-07 sec-1 (corresponding to a 14 day half-life) tf = time between harvest of leafy vegetation and ingestion, 8.60E+4, in seconds th = time between harvest of stored vegetation and ingestion, 5.18E+6, in seconds fL = fraction of annual intake of leafy vegetables grown locally, 1.0 (dimensionless) fg = fraction of annual intake of stored vegetables grown locally, 0.76 (dimensionless) Parameters used in the above equation were obtained from NUREG-0133 and Regulatory Guide 1.109, Revision 1 Since the concentration of tritium in vegetation is based on the airborne concentration rather than the deposition, the Critical Organ Dose Factors (Attachment 8)for tritium were calculated by multiplying the following equation by the appropriate X/Q: RMH3 = KK [UfL + U fg](DFLj)a[0.75(0.5fH)] (29-3) where: K"' = a constant of unit conversion 1E+03 gm/kg IH = absolute humidity of the atmosphere, 8.0, gm/m3 0.75 = the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined.}}