ML071240134

Annual Radioactive Effluent Release Report for the Period January Through December 2006

ML071240134
Person / Time
Site:	Surry
Issue date:	04/30/2007
From:	Jernigan D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, NRC/NRR/ADRO
References
07-0301
Download: ML071240134 (248)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 30, 2007 United States Nuclear Regulatory Commission Serial No. 07-0301 Attention: Document Control Desk S&L/TJN Washington, DC 20555-0001 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2006 through December 31, 2006. The report, submitted pursuant to Surry Power Station Technical Specification 6.6.B.3, includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released during the 2006 calendar year, as outlined in Regulatory Guide 1.21, Revision 1, June 1974.

If yp1ha e any further questions, please contact Paul Harris at 757-365-2692.

Site Vice President Surry Power Station Attachment Commitments made in this letter: None

Serial No.: 07-0301 Docket Nos.: 50-280 50-281 cc: United States Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, S. W., Suite 23T85 Atlanta, Georgia 30303-8931 Mr. D. C. Arnett NRC Resident Inspector Surry Power Station American Nuclear Insurers Attn: Mr. Edward Everett 95 Glastonbury Blvd.

Glastonbury, CT 06033

Serial No.: 07-0301 Docket Nos.: 50-280 50-281 ATTACHMENT 1 2006 Annual Radioactive Effluent Release Report SURRY POWER STATION UNITS 1 AND 2 LICENSE NOS. DPR-32 AND DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY

Surry Power Station 2006 Annual Radioactive Effluent Release Report

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ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION January 1, 2006 Through December 31, 2006 Prepared By: _

P. F. Blount Health Physicist Reviewed By:

P. R. Harris Supervisor Radiological Analysis Reviewed By:

D. K. Miller Supervisor Health Phy ics Technical Services Approved By:

L. B Jone Manager Radic all Protection

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE SURRY POWER STATION January 1, 2006 Through December 31, 2006 Index Section No. Subject Page 1 Executive Summary I 2 Purpose and Scope 2 3 Discussion 3 4 Supplemental Information 4 Attachment 1 Effluent Release Data Attachment 2 Annual and Quarterly Doses Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM)

Attachment 4 Major Changes to Radioactive Liquid, Gaseous and Solid Waste Treatment Systems Attachment 5 Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation Attachment 6 Unplanned Releases Attachment 7 Lower Limit of Detection (LLD) for Effluent Sample Analysis Attachment 8 Industry Groundwater Protection Initiative

FORWARD This report is submitted as required by Appendix A to Operating License Nos. DPR-32 and DPR-37, Technical Specifications for Surry Power Station, Units 1 and 2, Virginia Electric and Power Company, Docket Nos. 50-280, 50-28 1, Section 6.6.B.3.

EXECUTIVE

SUMMARY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report describes the radiological effluent control program conducted at Surry Power Station during the 2006 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from Surry Power Station in accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", Revision 1, June 1974. The report also includes an assessment of radiation doses to the maximum exposed member of the public due to the radioactive liquid and gaseous effluents.

During this reporting period, there were no unplanned liquid or gaseous effluent releases as classified according to the criteria in the Offsite Dose Calculation Manual.

Based on the 2006 effluent release data, 10CFR50 Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The dose calculations are as follows:

1. , The total body dose due to liquid effluents was 3.07E-04 mrem, which is 5.12E-03% of the 6 mrem dose limit. The critical organ doses due to liquid effluents, GI-LLI and Liver respectively, were 1.07E-03 mrem and 3.04E-04 norem. These doses are 5.35E-03% and 1.52E-03% of the respective 20 mrem dose limit.

2. The air dose due to noble gases in gaseous effluents was 1.07E-03.mrad gamma, which is 5.35E-03% of the 20 mrad gamma dose limit, and 1.69E-03 mrad beta, which is 4.23E-03% of the 40 mrad beta dose limit.

3. The critical organ dose from gaseous effluents due to 1-131, 1-133, H-3, and particulates with half-lives greater than 8 days is 1.36E-01 mrem, which is 4.53E-01% of the 30 mrem dose limit.

There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems during this reporting period.

There were three changes to VPAP-2103S, Offsite Dose Calculation Manual, during this reporting period. Attachment 3 provides the changes to V\PAP-2103S.

Four on-site potable water wells that are not a part of the Radiological Environmental Monitoring Program were sampled in 2006 due to the Nuclear Energy Institute (NEI) Industry Groundwater Protection Initiative. No radioactivity was detected in these well samples.

Based on the radioactivity measured and the dose calculations performed during this reporting period, the operation of Surry Power Station has resulted in negligible radiation dose consequences to the maximum exposed member of the public in unrestricted areas.

I

Purpose and Scope includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, with data summarized on a quarterly or annual basis following the format of Tables 1, 2 and 3 of Appendix B thereof. Attachment 2 of this report 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.

As required by Technical Specification 6.8.B, changes to the Offsite Dose Calculation Manual (ODCM) for the time period covered by this report are included in Attachment 3. Major changes to the radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, Section 6.7.2. If changes are made to these systems, the report shall include information to support the reason for the change and a summary of the 10CFR50.59 evaluation. In lieu of reporting major changes in this report, major changes to the radioactive waste treatment systems may be submitted as part of the annual FSAR update.

As required by the ODCM, Sections 6.2.2 and 6.3.2, a list and explanation for the inoperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 of this report. Additionally, a list of unplanned releases during the reporting period is included in . provides the typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation.

As required by the ODCM, Section 6.7.5, a summary of on-site radioactive spills or leaks that were communicated in accordance with the Industry Groundwater Protection Initiative reporting protocol, and sample analyses from groundwater wells that are not part of the Radiological Environmental Monitoring Program are provided in Attachment 8.

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Discussion The basis for the calculation of the percent of technical specification for the critical organ in Table 1A of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for iodine - 131, iodine - 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 receptor is the teen via the inhalation pathway.

The basis for the calculation of the percent of technical specification for the total body and skin in Table IA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for noble gases to areas at or beyond 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 of Attachment 1 is the ODCM, Section 6.2.1, which states that the concentration of radioactive material releases in liquid effluents to unrestricted areas shall not exceed ten times the concentrations specified in 10CFR20, 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.OOE-04 microcuries/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 the site boundary. The maximum exposed member of the public from the release of airborne iodine-13 1, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, was a teen at the site boundary with the critical organ being the lung. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was an adult, exposed by either the invertebrate or fish pathway, with the critical organ typically being the gastrointestinal-lower large intestine. The total body dose was also determined for this individual.

Presented in Attachment 6 is a list of unplanned gaseous and liquid releases as required by the ODCM, Section 6.7.2.

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 volumes 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 the radioisotope was reported as Not Detected (N/D) on Attachment 1 of this report. When all isotopes listed on Attachment 1 for a particular quarter and release mode are less than the lower limit of detection, then the totals for this period will be designated as Not Applicable (N/A).

3

Supplemental Information Section 6.6.1 of the ODCM requires the identification of the cause(s) for the unavailability of milk, or if required, leafy vegetation samples, and the identification for obtaining replacement samples.

As milk was available for collection during this reporting period, leafy vegetation sampling was not required.

As required by the ODCM, Section 6.6.2, evaluation of the Land Use Census is made to determine if new sample location(s) must be added to the Radiological Environmental Monitoring Program.

Evaluation of the Land Use Census conducted for this reporting period identified no change in sample locations for the Radiological Environmental Monitoring Program.

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Attachment 1 EFFLUENT RELEASE DATA January 1, 2006 Through December 31, 2006 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.

Attachment I TABLE IA Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND  % EST. ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci 6.11E-02 1.80E+00 1.80E+01

2. AVE RELEASE RATE FOR PERIOD /LCi/sec 7.86E-03 2.29E-01 B. IODINE

1. TOTAL 1-131 Ci N/D 2.23E-07 2.80E+01

2. AVE RELEASE RATE FOR PERIOD tiCi/sec N/A 2.84E-08 C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 1.97E-08 8.04E-06 2.80E+01

2. AVE RELEASE RATE FOR PERIOD ACi/sec 2.54E-09 1.02E-06

3. GROSS ALPHA RADIOACTIVITY Ci N/D N/D D. TRITIUM

1. TOTAL RELEASE Ci 8.59E+00 1.55E+01 3.1OE+O1

2. AVE RELEASE RATE FOR PERIOD tCi/sec 1.11E+00 1.97E+00 PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % 5.61E-03 1.00E-02 TOTAL BODY DOSE RATE  % 9.08E-06 7.55E-04 SKIN DOSE RATE  % 2.64E-06 2.72E-04

Attachment 1 TABLE 1A Page 2 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS l&2 UNIT THIRD FOURTH  % EST. ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE ci 3.42E-01 2.29E-01 1.80E+01

2. AVE RELEASE RATE FOR PERIOD ACi/sec 4.30E-02 2.89E-02 B. IODINE

1. TOTAL 1-131 ci N/D N/D 2.80E+01

2. AVE RELEASE RATE FOR PERIOD ItCi/sec N/A N/A C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 1.55E-08 5.97E-06 2.80E+01

2. AVE RELEASE RATE FOR PERIOD ACi/sec 1.95E-09 7.51E-07

3. GROSS ALPHA RADIOACTIVITY Ci N/D N/D D. TRITIUM

1. TOTAL RELEASE Ci 1.53E+01 1.68E+01 3.10E+01

2. AVE RELEASE RATE FOR PERIOD MCi/sec 1.92E+00 2.11E+00 PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE 9.73E-03 1.08E-02 TOTAL BODY DOSE RATE 5.05E-06 1.84E-05 SKIN DOSE RATE 1.87E-06 6.24E-06

Attachment 1 TABLE 1B Page 3 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS l&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D N/D Kr-85m Ci N/D N/D N/D 5.74E-04 Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D 6.86E-02 5.94E-02 1.13E+00 Xe-135 Ci N/D N/D N/D 4. 1OE-02 Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D 1.09E-02 Ar-41 Ci N/D N/D N/D 2.55E-04 TOTAL FOR PERIOD Ci N/A 6.86E-02 5.94E-02 1. 19E+00

2. IODINES 1-131 Ci N/D N/D N/D N/D 1-133 Ci N/D N/D N/D N/D 1-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A N/A

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci 1.97E-08 N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci N/D 6.71E-10 N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D N/D Cr-51 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci 1.97E-08 6.71E-10 N/A N/A

Attachment I TABLE lB Page 4 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D N/D Kr-85m Ci N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D N/D 3.40E-01 2.14E-01 Xe-135 Ci N/D N/D N/D 7.17E-05 Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131m Ci N/D N/D N/D 8.51E-05 Xe-133m Ci N/D N/D N/D 9.69E-05 Ar-41 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A 3.40E-0 I 2.15E-01

2. IODINES 1-131 Ci N/D N/D N/D N/D 1-133 Ci N/D N/D N/D N/D 1-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A N/A

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci 1.55E-08 5.66E-09 N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci -IN/D N/D N/D N/D Co-58 Ci N/D 4.84E-09 N/D N/D Co-60 Ci N/D 6.78E-09 N/D N/D Mn-54 Ci N/D N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce- 144 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D N/D Cr-51 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci 1.55E-08 1.73E-08 N/A N/A

Attachment 1 TABLE 1C Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D N/D Kr-85m Ci N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D N/D N/D 3.46E-01 Xe-135 Ci 5.73E-04 2.64E-04 6.41E-04 1.89E-01 Xe-135m Ci 1.79E-04 4.57E-05 N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D 1.98E-03 Ar-41 Ci 3.42E-04 3.20E-04 N/D 5.OOE-03 TOTAL FOR PERIOD Ci 1.09E-03 6.29E-04 6.41E-04 5.41E-01

2. IOD1NES 1-131 Ci N/D 2.23E-07 N/D N/D 1-133 Ci N/D N/D N/D N/D 1-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A 2.23E-07 N/A N/A

3. PARTICULATES Sr-89 Ci N/D N/D N/D 2.25E-06 Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci N/D N/D N/D 2.59E-06 Ba- 140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci N/D 7.63E-07 N/D 2.43E-06 Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D N/D Cr-51 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A 7.63E-07 N/A 7.27E-06

Attachment 1 TABLE IC Page 6 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D N/D Kr-85m Ci N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D N/D N/D 1.21E-02 Xe-135 Ci 2.95E-04 1.10E-03 1.20E-03 1.11E-03 Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D 3.65E-04 N/D N/D Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D Ar-41 Ci N/D 1.16E-04 N/D N/D TOTAL FOR PERIOD Ci 2.95E-04 1.58E-03 1.20E-03 1.32E-02

2. IODINES 1-131 Ci N/D N/D N/D N/D 1-133 Ci N/D N/D N/D N/D 1-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A N/A

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci N/D 1.72E-06 N/D N/D Ba-140 Ci N/D N/D N/D N/D La- 140 Ci N/D N/D N/D N/D Co-58 Ci N/D 4.23E-06 N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce- 144 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D N/D Cr-51 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A 5.96E-06 N/A N/A

Attachment 1 TABLE 2A Page 7 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND  % EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 1.51E-02 4.10E-02 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD /Ci/mL 2.24E-11 6.67E-11

3. PERCENT OF APPLICABLE LIMIT  % 3.97E-05 3.92E-05 B. TRITIUM

1. TOTAL RELEASE Ci 1.87E+02 4.21E+02 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD /lCi/mL 2.76E-07 6.85E-07

3. PERCENT OF APPLICABLE LIMIT  % 2.76E-03 6.85E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci N/D N/D 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD /iCi/mL N/A N/A

3. PERCENT OF APPLICABLE LIMIT  % N/A N/A D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci N/D N/D 2.OOE+01 E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.40E+07 4.52E+07 3.OOE+00 F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 6.77E+I1 6.14E+ 1I 3.OOE+00

Attachment I TABLE 2A Page 8 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH  % EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 2.50E-02 3.15E-02 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD jICi/mL 3.20E-11 5.36E-11

3. PERCENT OF APPLICABLE LIMIT  % 2.16E-05 5.08E-05 B. TRITIUM

1. TOTAL RELEASE Ci 1.05E+02 3.01E+02 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD ACi/mL 1.34E-07 5.13E-07

3. PERCENT OF APPLICABLE LIMIT  % 1.34E-03 5.13E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci N/D N/D 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD #Ci/mL N/A N/A

3. PERCENT OF APPLICABLE LIMIT  % N/A N/A D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci N/D N/D 2.OOE+01 E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 4.68E+07 5.93E+07 3.OOE+00 F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.81E+ll 5.87E+ll 3.OOE+00

Attachment I TABLE 2B Page 9 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D N/D Fe-55 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci 4.24E-04 6.36E-04 1.32E-03 2.94E-04 1-131 Ci N/D N/D N/D 1.36E-04 Co-58 Ci N/D N/D 5.88E-03 1.15E-02 Co-60 Ci 1.30E-05 N/D 1.32E-03 9.45E-04 Fe-59 Ci N/D N/D N/D 6.06E-06 Zn-65 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D 2.83E-03 1.21E-04 Cr-51 Ci N/D N/D N/D 1.67E-02 Zr-95 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D 3.71E-05 Mo-99 Ci N/D N/D N/D 2.42E-05 Tc-99m Ci N/D N/D N/D 1.13E-04 Ba- 140 Ci N/D N/D N/D N/D La- 140 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D Sb-124 Ci N/D N/D N/D 5.42E-04 Sb-125 Ci N/D N/D 3.28E-03 9.94E-03 Co-57 Ci N/D N/D 6.43E-05 7.50E-06 1-133 Ci N/D N/D N/D 7.04E-06 TOTAL FOR PERIOD Ci 4.37E-04 6.36E-04 1.47E-02 4.04E-02 Xe-133 Ci N/D N/D N/D N/D Xe-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A N/A

Attachment I TABLE 2B Page 10 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/06 TO 12/31/06 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER Sr-89 N/D N/D N/D N/D Sr-90 N/D N/D N/D N/D Fe-55 N/D N/D N/D N/D Cs-134 N/D N/D N/D N/D Cs-137 3.20E-04 4.24E-04 6.72E-05 2.28E-04 1-131 N/D N/D N/D N/D Co-58 N/D N/D 1.30E-02 2.45E-02 Co-60 N/D N/D 8.95E-04 3.OOE-03 Fe-59 N/D N/D N/D 4.53E-06 Zn-65 N/D N/D N/D N/D Mn-54 N/D N/D 6.44E-04 2.45E-03 Cr-51 N/D N/D 2.22E-04 6.44E-05 Zr-95 N/D N/D N/D N/D Nb-95 N/D N/D N/D 2.15E-05 Mo-99 N/D N/D N/D N/D Tc-99m N/D N/D N/D N/D Ba-140 N/D N/D N/D N/D La-140 N/D N/D N/D N/D Ce-141 N/D N/D N/D N/D Ce- 144 N/D N/D N/D N/D Sb-124 N/D N/D 8.17E-06 N/D Sb-125 N/D N/D 9.78E-03 6.08E-04 Co-57 N/D N/D 3.44E-05 2.02E-04 1-133 N/D N/D N/D N/D TOTAL FOR PERIOD Ci 3.20E-04 4.24E-04 2.46E-02 3.11E-02 Xe-133 Ci N/D N/D N/D N/D Xe-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A N/A

Attachment 1 TABLE3 Page 11 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/06 - 12/31/06 SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

1. Type of waste 12 month Est. Total Period Error, %

a. Spent resins, filter sludges, evaporator m3 2.75E+01* 1.00E+01 bottoms, etc. Ci 4.41E+02 3.OOE+01

b. Dry compressible waste, contaminated m3 7.46E+02** 1.00E+01 equip., etc. Ci 5.60E+00 3.OOE+01

c. Irradiated components, control m3 O.OOE+00 1.00E+01 rods, etc. Ci O.OOE+00 3.OOE+01

d. Other (Waste oil) m3 8.63E+O*** 1.06E+01 Ci 2.52E-03 3.OOE+01

2. Estimate of major nuclide composition (by type of waste)

a. Ni-63 4.15E+01 Fe-55 2.90E+01 Co-60 1.63E+01 Co-58 7.72E+00 Mn-54 2.86E+00 Cs-137 1.59E+00

b. Cs-137 4.09E+01 Co-60 1.73E+01 Co-58 1.41E+01 Fe-55 1.19E+O1 Ni-63 1.17E+O1 Cr-51 1.28E+00 C-14 1.18E+00 C.

d. Cs-137 6.25E+01 Ni-63 1.38E+01 Co-60 1.14E+O1 Fe-55 1.00E+01 Ce-144 1.05E+00

Attachment 1 TABLE3 Page 12 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/06 - 12/31/06 CONTINUED SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

3. Solid Waste Disposition Number of Shipments Mode of Transportation Destination 6 Truck Barnwell, SC (WMF) 15 Truck Oak Ridge, TN (DBC) 1 Truck Memphis, TN (RACE)

B. IRRADIATED FUEL SHIPMENT (Disposition)

Number of Shipments Mode of Transportation Destination 0

• NOTE 1: Some of this waste was shipped to licensed waste processors for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 1.82E+01 in 3 .

• • NOTE 2: Some DAW was shipped to licensed waste processors for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 8.64E+01 m'.

• • • NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 9.92E-01 m3.

Attachment 2 Page 1 of 1 ANNUAL AND QUARTERLY DOSES 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 is made pursuant to the ODCM, Section 6.7.2, requirement.

LIQUID GASEOUS Total Body GI-LLI Liver Gamma Beta Lung (mrem) (mrem) (mrem) (mrad) (mrad) (mrem) 1st Quarter 5.43E-05 1.56E-04 6.51E-05 1.19E-05 8.80E-06 2.08E-02 2nd Quarter 1.08E-04 3.08E-04 1.04E-04 1.02E-03 1.63E-03 3.75E-02 3rd Quarter 3.11E-05 1.43E-04 2.73E-05 6.88E-06 1.12E-05 3.69E-02 4th Quarter 1.14E-04 4.66E-04 1.08E-04 2.55E-05 4.12E-05 4.06E-02 Annual 3.07E-04 1.07E-03 3.04E-04 1.07E-03 1.69E-03 1.36E-01

Attachment 3 Page 1 of 1 REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM)

As required by Technical Specification 6.8.B, revisions to the ODCM, effective for the time period covered by this report, are included with this attachment. There were three revisions to the ODCM implemented during this reporting period. The revision summaries are as follows.

Revision 8:

Revised the return to service time for inoperable ventilation effluent continuous particulate and iodine samplers to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Revision 9:

Revised the description of an Environmental TLD from "Exclusion Area Boundary and Site Boundary" to "Site Boundary" as Technical Specification Amendments 248 and 249 redefined the site exclusion area boundary as the site boundary.

Revision 10:

Revised to incorporate the replacement of the Kaman (gaseous effluent) Radiation Monitoring System with the Merlin Gerin (gaseous effluent) Radiation Monitoring System.

Revisions 8, 9 and 10 of the ODCM are included with this attachment.

_p n Administrative ProceduresAction Reques

_ (A-PAR)

" " in VPAP-0502. 50 -, Atahmn 21 ag I f Instucte nf arrcmped ngModifictiorm ar i oe cluded in VI-'AP-U502 te anoutrpr_(opltboks1___g 5 fowrdt pporit roesPrga we (P)

1. Procedure Number 2. Revision 3. Page 4. Effective Date VPAP-2103S 8 1 of 1

5. Procedure Title 6. Expiration Date Offsite Dose Calculation Manual (Surry) N/A

7. Type of Request j I New Procedure [ x ] Procedure Revision ] Procedure Deletion [ Emergency Change

8. Brief description of the modification See Revision Summary of affected procedure

9. Location [ x ] SPS [ ] NAPS [ CORP Location [ SPS NAPS ] CORP

10. Requested by (Printed Name) I. Date 112. Phone 13. Requested by (Printed Name) 14. Date 115. Phone P. Blount 11/2/05 12467 N/A N/A IN/A

16. Does procedure meet requirements of NOTE below? [x] []No

17. Does this procedure require a Regulatory Evaluation? IlYes [x

18. Are there any new sections or steps designated North Anna or Surry? [ I Yes [x ] No

19. Is the reason for the station-specific instructions due to differences in regulatory requirements? [ ] Yes [ ] No [x I

20. Is the reason for the station-specific instructions due to differences in construction? [ ] Yes [ ] No [xJ

21. Is the reason for the station-specific instructions due to station preferences? [ I Yes [ ] No [x]

If all answers are No or N/A, approval is required by PPOs as identified on the Procedure Cover Page. Check block 30.

If block 16 or 17 is Yes, approval is required by PPOs, SNSOCs, and/or Site Vice Presidents. Check blocks 30, 31, and 32, as appropriate.

NOTE: VPAP-2101 and VPAP-2201 require SNSOCs approval.

SPIPs, VPAP-2103N, VPAP-2103S, VPAP-2104, and VPAP-2401 require SNSOC(s) and Site Vice President(s) approval.

If block 18, 19, or 20 is Yes with block 21 No, approval is required by PPOs and Site Vice Presidents. Check blocks 30 and 32.

If block 21 is Yes, approval is required by PPOs, Site Vice Presidents, and Vice President Corporate. Check blocks 30, 32, and 33.

22. Did this procedure require the attachments in DNAP-01 12, Dominion Nuclear Change Management Process, to be used? [ ]Yes [x]

23. Location [x] SPS [] NAPS [ ] CORP Location [ ] SPS [ ] NAPS [ CORP

24. PPO (Printed Name) 125. Date 126. Phone 27. PPO (Printed Name) 28. Date 129. Phone L. B. Jones 111/2/05 12010 N/A IN/A IN/A I

[x 130. PPO(s) [x ] 31. SNSOCs [x ] 32. Site Vice Presidents [ 33. Vice President (Corp) 34.PP at e 35. Dat 36. PPO (Signature) 37. Date

38. INS a (Dte 40. SNSOC Chairman (Signature) 41. Date f

4. Si Vice ' t (Signat.._ re) 44. Site Vice President (Signature) 1 45. Date

46. Vice President Corporate (Signature) 47. Date ey: A-PAR-Administrative Procedures Action Request; SPS-Surry Power Station; NAPS-North Anna Power Station; CORP-Corporate; PPO(s)-Process/Program Owner(s);

SNSOC-Station Nuclear Safety and Operating Committee; SPIPs-Security PlAnImplementing Procedures Form No. 720457(Dec 2005

rO.HEWLETT nanns

&ZTA4PAC=KARD User: Sandy MannSU-Pro.,.

Request: SUPROC6 ADM 2-3985 from inn0ux4*

Date Printed: Wed Feb 8.08:39:44 EST 2006:

Procedure: VPAP-2 103S Rev: 008 PAR: 0 ...........

Title:

OFFSITE DOSE CALCULATION MANUAL (SURRY)

Effective Date: 02/08/2006 Station: Innsbrook Docbase: INMIND ......... ..

If this procedure is initiated OR re-initiated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the print time & date shown, then the revision and PAR must be verified. ........... ..

This leader page is part of the controlled document and must remain with the procedure .....

as a permanent record.

Approval signatures for electronically distributed procedures are maintained on file. .................

CONTROLLED COPY

I I

Station l

' Dominion Administrative Procedure

Title:

Offsite Dose Calculation Manual (Surry)

Process / Program Owner: Manager Radiological Protection and Chemistry (Surry)

Procedure Number Revision Number Effective Date VPAP-2103S 8 On File' Revision Summary Revised in response to S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling.

• Added 3.2.4 - S-2005-0930, Response to the Verification of Back-up Effluent Accountability m Sampling.

• Revised Attachment 5, Radioactive Gaseous Effluent Monitoring Instrumentation, as follows:

" ACTION 1 - changed "If the number of operable channels is less than required, effluent releases via this path may continue provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to "If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repairthe channel and that grab samples are taken at least once per .12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and I

these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. [Commitment 3.2.4]"

• ACTION 2:

OLD - "If the number of operable channels is less than required, effluent releases via the effected path may continue provided samples are continuously collected within one hour with auxiliary sampling equipment as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4)."

NEW - "If the number of operable channels is less than required, effluent releases via this I

pathway may continueprovided that the best efforts are made to repairthe channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initiationof this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). [Commitment 3.2.4]"

I I

Approvals on FileI I

DOMINION VPAP-2103S REVISION 8 PAGE 2 OF 71 TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effluents 11 6.2.1 Liquid Effluent Concentration Limitations 11 6.2.2 Liquid Monitoring Instrumentation 12 6.2.3 Liquid Effluent Dose Limit 15 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 Limitations 19 6.3.2 Gaseous Monitoring Instrumentation 21 6.3.3 Noble Gas Effluent Air Dose Limit 24 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 26 6.3.5 Gaseous Radwaste Treatment 28 6.4 Radioactive Liquid and Gaseous Release Permits 29 6.4.1 Liquid Waste Batch Releases 29 6.4.2 Continuous Liquid Releases 29 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 30 6.4.4 Reactor Containment Release Permits 30 6.4.5 Miscellaneous Gaseous Release Permit 30

DOMINION VPAP-2103S I

REVISION 8 PAGE 3 OF 71 TABLE OF CONTENTS (continued) P Section Page 6.4.6 Radioactive Liquid and Gaseous Release Controls 30 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 32 6.6 Radiological Environmental Monitoring 32 6.6.1 Monitoring Program 32 6.6.2 Land Use Census 34 6.6.3 Interlaboratory Comparison Program 35 6.7 Reporting Requirements 36 6.7.1 Annual Radiological Environmental Operating Report 36 6.7.2 Annual Radioactive Effluent Release Report 38 6.7.3 Annual Meteorological Data 40 6.7.4 Changes to the ODCM 40 7.0 RECORDS 41 ATTACHMENTS 4 1 Radioactive Liquid Effluent Monitoring Instrumentation 42 2 Radioactive Liquid Effluent Monitoring Instrumentation 43 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 44 I 4 Radioactive Gaseous Waste Sampling and Analysis Program 47 5 Radioactive Gaseous Effluent Monitoring Instrumentation 51 6 Radioactive Gaseous Effluent Monitoring Instrumentation 53 Surveillance Requirements 7 Radiological Environmental Monitoring Program 55 8 Environmental Sampling Locations 58 9 Detection Capabilities for Environmental Sample Analysis 61 10 Reporting Levels for Radioactivity Concentrations in Environmental 63 Samples 11 Meteorological, Liquid, and Gaseous Pathway Analysis 64 I

I

DOMINION VPAP-2103S REVISION 8 PAGE 4 OF 71 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to 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 ýLCi/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 1131, 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

" Exposure to a real individual will not exceed 40 CFR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at Surry Power Station.

DOMINION VPAP-2103S I

REVISION 8 PAGE 5 OF 71

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 I 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 1, 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 I

3.1.8 Surry Technical Specifications (Units 1 and 2) 1 3.1.9 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in I Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 I 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 I

3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual I

DOMINION VPAP-2103S REVISION 8 PAGE 6 OF 71 3.1.19 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 3.1.20 Surry UFSAR 3.1.21 Laboratory Quality Assurance Plan, Manual 100; Framatome Environmental Laboratory 3.1.22 VPAP-2802, Notifications and Reports 3.1.23 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.24 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds with the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated.

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/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter.

DOMINION VPAP-2103S I

REVISION 8 PAGE 7 OF 71 4.3 Channel Functional Test There are two types of Channel Functional Tests.

4.3.1 Analog Channel I Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions.

4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm I and/or trip functions.

4.4 Critical Organ I That 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.

4.5 Dose Equivalent 1-131 U That concentration of 1131 (ptCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1131, V132, 1133, 1134, and 1135 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 I Regulatory Guide 1.109, Revision 1, may be used.

I I

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DOMINION VPAP-2103S REVISION 8 PAGE 8 OF 71 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent.

NOTATION FREQUENCY D - Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W - Weekly At least once per 7 days M - Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA - Semi-alnually At least once per 184 days R - Refueling At least once per 18 months S/U - Start-up Prior to each reactor start-up P - 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 and waste gas surge tanks.

4.8 General Nomenclature X = 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 Lower Limit of Detection (LLD)

The 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-2103S I

REVISION 8 PAGE 9 OF 71 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with the Station. This category includes non-employees of Dominion who are permitted to use portions 3 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 materials.

4.11 Operable - Operability 3 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 to purify the confinement.

4.13 Rated Thermal Power U Total reactor core heat transfer rate to reactor coolant (i.e., 2546 Megawatts Thermal MWt).

4.14 Site Boundary 3 The line beyond which Dominion does not own, lease, or otherwise control the land.

4.15 Source Check I A qualitative assessment of channel response when a channel sensor is exposed to radiation.

This applies to installed radiation monitoring systems.

4.16 Special Report 3 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. 3 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant. 3 I

DOMINION VPAP-2103S REVISION 8 PAGE 10 OF 71 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 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 High 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 The 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 monitoring, 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-2103S I

REVISION 8 PAGE 11 OF71 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 11). I 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 I 6,2.1 Liquid Effluent Concentration Limitations

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

1. For radionuclides (other than dissolved or entrained noble gases), liquid effluent I 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 I reduce concentrations to within limits.

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DOMINION VPAP-2103S REVISION 8 PAGE 12 OF 71

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

,Ci/mli Volume of Waste Discharged x *ACimCW.

where:

jtCi/mli = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as ptCi/ml from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 ýtCi/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

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REVISION 8 PAGE 13 OF 71

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 Functional 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, 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 Service Water System Effluent Line Instrument Number 1-SW-RM-107 A, I

Condenser Circulating Water Line B,C,D 1-SW-RM-120 I

Radwaste Facility Effluent Line 2-SW-RM-220 1-RM-RRM-131 I I

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DOMINION VPAP-2103S REVISION 8 PAGE 14 OF 71

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

1. Maximum setpoint values shall be calculated by:

CFD FE where:

S = the setpoint, in ptCi/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 ýtCi/ml FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as:

D = FE + (200,000 gpm x number of circ. pumps in service)

2. Each of the condenser circulating water channels (e.g., SW-120, SW-220) monitors the effluent (service water, including component cooling service 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 service water system effluent line (i.e., SW-107 A, B, C, D), and the Radwaste Facility effluent line (i.e., RRM-13 1).

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REVISION 8 PAGE 15 OF 71

4. For the service water system effluent line, Equation (2) becomes:

S CFDKSW (4)

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

5. For the Radwaste Facility effluent line, Equation (2) becomes:

CFDKRW (5)1 FE where:

KRW The fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

6. The sum Ksw + KRW shall not be greater than 1.0. 3 6.2.3 Liquid Effluent Dose Limit

a. Requirement I 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 public from radioactive materials in liquid releases (from each reactor unit) to unrestricted areas is limited to: 3

1. During any calendar quarter:

- Less than or equal to 1.5 mrem to the total body I

- Less than or equal to 5 mrem to the critical organ

2. During any calendar year: I

" Less than or equal to 3 mrem to the total body

• Less than or equal to 10 mrem to the critical organ I

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DOMINION VPAP-2103S REVISION 8 PAGE 16 OF 71

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 NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation:

D = tFMZ iAi (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 t = the period for which Ci and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix 11A, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in ýtCi/ml

DOMINION VPAP-2103S REVISION 8 PAGE 17 OF 71 Ai= the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem-ml per hr-!ICi. Values for Ai are provided in the Canberra Source Code file.

Ai = 1.14 E+05 (21BFi + 5BIi) DFi (7) for example:

1.14 E+05 = 1 E+06 pCi/tCi x 1 E+03 ml/kg/(8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 BI = the bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/l BFj = the bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/1 DFi = the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II, NUREG/CR-1276, and TID-4500, VCRL-50564, Rev. 1.

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.

DOMINION VPAP-2103 S REVISION 8 PAGE 18 OF 71 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 Surry Radwaste Facility Liquid Waste 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 and Critical Organ Dose Calculation

1. Determine DI, the sum of all liquid open and closed release points, in mrem, by the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for liquid releases by the ith organ for the particular quarter of the release.

4. Determine Dp, the 31 day projected dose by the ith organ:

Dp = (DI x P) + Da

DOMINION VPAP-2103S I

REVISION 8 PAGE 19 OF 71 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 Limitations

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: I

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

2. The dose rate limit for 1131, 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 I

1. If dose rates exceed Step 6.3.1.a. limits, promptly decrease the release rate to within the above limits. 3

2. Dose rates due to noble gases in gaseous effluents shall be determined, continuously, to be within Step 6.3.1.a. limits. 3

3. Dose rates due to 1131, 1133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents shall be determined to 3 be within the above limits by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified on 3 Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

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DOMINION VPAP-2103S REVISION 8 PAGE 20 OF 71

c. Calculations of Gaseous Effluent Dose Rates NOTE: The dose factors used in the Gaseous Effluent Dose Rate calculations are included in the Canberra Source Code file. These dose factors, Ki, Li, Mi, and Pi for ventilation vent and 15rocess vent releases, DO NOT include the applicable X/Q value. Equations (8), (9), and (10) must be multiplied by the appropriate X/Q value for Gaseous Effluent Dose Rate calculations.

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:

[KivvQivv + KipvQipv] !00 mremlyr to the total body (8)

OR Sivv + 1.1Mivv )Q ivv + (L pv + 1.lMMpv )Qipv] 3000 mrem/yr to the skin (9) where:

Subscripts = vv, refers to vent releases from the building ventilation vent, including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide Kivv, Kipv = 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/see Liv, Lipv = 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 Mivv, Mipv = 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 0ivv, Qipv = The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/see (per site) 1.1 = The unit conversion factor that converts air dose to skin dose, in mrem/mrad

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REVISION 8 PAGE 21 OF 71

2. The dose rate limit for 1131, I"33, 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:

_PivvQivv + PipvQipv] *1500 mremlyr to the critical organ (10) i where:

Pivv, Pip = The critical organ dose factor for ventilation vents or process vent for 1131, 1133, H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec QivvQipv = The release rate for ventilation vents or process vent of 1131, 1133, 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 ivv.

6.3.2 Gaseous Monitoring Instrumentation

a. Requirement 3

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) 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. I

2. Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated operable by Channel Checks, Source Checks, Channel I Calibrations, and Channel Functional Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 6).

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DOMINION VPAP-2103S REVISION 8 PAGE 22 OF 71

b. Action

1. If a radioactive gaseous effluent monitoring 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 5),

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 inoperability 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-102 1-GW-RM-130-1 Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-110 1-VG-RM- 131-1 Radwaste Facility Vent RRM-101

DOMINION VPAP-2103S I

REVISION 8 PAGE 23 OF 71

d. Setpoint Calculations

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

D > Dpv + Dcae + Dv (11) 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, mreml/yrI Dcae = The noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr D = The noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

2. Setpoint values shall be determined by:

Rm xCm 2.12

=

E-03 (

(12) miFm where:

m = The release pathway, process vent (pv), ventilation vent (vv).

condenser air ejector (cae), or Radwaste Facility (rv)

Cm = The effluent concentration limit implementing Step 6.3.1.a.

for the Station, ýtCi/ml Rm = The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe 1 33 as nuclide to be released, jtCi/sec 2.12E-03 = CFM per ml/sec Fm = The maximum flow rate for pathway m, CFM 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.

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DOMINION VPAP-2103S REVISION 8 PAGE 24 OF 71 6.3.3 Noble Gas Effluent Air Dose Limit NOTE: The dose factors used in the Noble Gas air dose calculations are included in the Canberra Source Code file. These dose factors, Mi and Ni for ventilation vent and process vent releases, DO NOT include the applicable X/Q value. Equations (13) and (14) must be multiplied by the appropriate X/Q value for gamma and beta air dose calculations.

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: *510 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 6.3.3.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.

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REVISION 8 PAGE 25 OF 71 I

c. Noble Gas Effluent Air Dose Calculation i

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

I For gamma radiation: I D

g

= 3.17E-08_MivvQivv + Mivipv]

ipvi (13)

I For beta radiation: I Db = 3.17E-08XNivvQivv + NipvQipvl i

(14) I Where: I Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors I pv, refers to the vent releases from the process vent Dg i, refers to individual radionuclide

= the air dose for gamma radiation, in mrad I 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 I

radionuclide i, in mrad/yr per Curie/sec Nivv, Nipv = the air dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas I

radionuclide i, in mrad/yr per Curie/sec Qivv, Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year I

as appropriate in Curies (per site) 3.17 E-08 = the inverse of the number of seconds in a year I I

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DOMINION VPAP-2103S REVISION 8 PAGE 26 OF 71 6.3.4 1-131, 133, H-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 I"', 133, 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, 1133, 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 1131, 1133, 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 reducei 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.

I DOMINION VPAP-2103S REVISION 8 PAGE 27 OF 71 I

c. Dose Calculations i

NOTE: All critical organ doses for each age group are calculated to determine which is the I limiting organ for the period being evaluated.

NOTE: The RMi and RIi dose factors DO NOT include the applicable D/Q and X/Q values I

respectively for Surry Power Station. Equation (15) must be multiplied by the applicable D/Q or X/Q, as appropriate, to calculate the critical organ dose.

I Gaseous releases, not through the process vent, are considered ground level and I shall be included in the determination of Qj. 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 1131,1133, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:.

Dr = 3.17E_08 RMivv~ivv + RMipvQipv) + (RlivvQivv + Rlipvip)] (15)

For example:

Subscripts = vv, refers to vent releases from the building ventilation vents, I including the Radwaste Facility Ventilation Vent and air ejectors; 1 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 I

RMivv, RMipv= the cow-milk pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than I

eight days, in mrem/yr per RlCi/m 3 . Factors are included in the Canberra Source Code file. I I

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DOMINION VPAP-2103S REVISION 8 PAGE 28 OF 71 RIivv, Rip = the inhalation pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per gCi/m 3 . Factors are included in the Canberra Source Code file.

Qivv,Qipv = the release for ventilation vents or process vent of 1131, 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 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. Appropriate portions of the Gaseous Radwaste Treatment System shall be used to reduce radioactive materials in gaseous waste before its discharge, when the 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.

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REVISION 8 PAGE 29 OF 71

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

1. Determine Dg, the sum of all gaseous open and closed release points, in mrem, I by the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for gaseous releases by the ith organ for the particular quarter of the release,

4. Determine Dp, the 31 day projected dose by the ith organ.

Dp = (Dg x P) + Da 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. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis.

6.4.1 Liquid Waste Batch Releases

a. Operations shall obtain RP authorization before initiating batch releases of radioactive liquids.

b. Release of contents from the following tanks/sumps other than transfers to the Radwaste Facility shall have a release permit before the discharge. Examples of batch releases include:

- Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode

• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage

• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases I

a. Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids. I I

DOMINION VPAP-2103S REVISION 8 PAGE 30 OF 71

b. Examples of continuous releases include:

" Steam generator blowdown

" Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable

" Turbine building sumps and subsurface drains when pumps are in automatic mode or storm drains 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 from 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.

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.

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.

DOMINION VPAP-2103S REVISION 8 PAGE 31 OF 71

c. RP shall perform required sample analyses.,

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

" Maximum authorized release rate

• 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. i

2. Note maximum authorized release rate.

3. 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 3 information necessary for completion of permit. As appropriate, required information shall include: 3

• Date and time release was stopped

• Tank/sump ending level n

• Release flow rate just prior to termination

• Ending pressure n

" Volume released I

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DOMINION VPAP-2103S REVISION 8 PAGE 32 OF 71 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 releases 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 7).

DOMINION VPAP-2103S I

REVISION 8 PAGE 33 OF 71

2. Samples shall be collected from specific locations specified in Environmental 3 Sampling Locations (Attachment 8).

3. Samples shall be analyzed in accordance with: 3

• Radiological Environmental Monitoring Program (Attachment 7) requirements

• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 9) 1

" Guidance of the Radiological Assessment Branch Technical Position on Environmental Monitoring dated November, 1979, Revision No. I

b. Action 1, If the Radiological Environmental Monitoring Program is not being conducted 3 as required in Step 6.6.1 .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 Specification (Surry Technical Specification 6.6.B.2), a description of the reasons for not conducting the program as required, and the plan for precluding I recurrence.

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting I levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10), prepare and submit to the NRC within 30 days, a 3 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 3 Radioactivity Concentrations in Environmental Samples (Attachment 10) are detected in the sampling medium, the report shall be submitted if: 3 concentration (1) + concentration (2) +...> 1.0 (16) reporting level (1) reporting level (2)

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DOMINION VPAP-2103S REVISION 8 PAGE 34 OF 71

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10) 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 required 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 VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 7), 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.

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 m 2 (500 ft 2 ) 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-2103S I REVISION 8 PAGE 35 OF 71 3

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 I Environmental Monitoring Program (Attachment 7) shall be followed, including analysis of control samples.

b. Action

1. If a land use census identifies locations that yield a calculated dose or dose commitment greater than the values currently being calculated in Step 6.3.4.a.,

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 dose commitment (via the same exposure pathway) 20 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 I figures and tables reflecting the new locations in accordance with VPAP-2802, Notifications and Reports. [Commitment 3.2.1]

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.

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DOMINION VPAP-2103S REVISION 8 PAGE 36 OF 71

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, 1131, H 3 (Tritium), Sr 89 and Sr 9 ° (blind-any combinations of above radionuclides)

Air Filter Gross Beta, Gamma, Sr 9 °

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 VPAP-2802, Notifications and Reports, the corrective actions taken to prevent recurrence.

c. Results Results shall be reported in the Annual Radiological Environmental Monitoring 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 I An assessment of the observed impacts of the plant operation on the environment

- Results of land use census per Step 6.6.2

DOMINION VPAP-2103S REVISION 8 PAGE 37 OF 71

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 7).

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment 9) was not achievable.

DOMINION VPAP-2103S REVISION 8 PAGE 38 OF 71 NOTE: NUREG-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."

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 sections 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.

i) [Commitment 3.2.2]

2. An assessment of radiation doses to the maximum exposed members of 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)

DOMINION VPAP-2103S I REVISION 8 PAGE 39 OF 71 3

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

5. Changes to VPAP-2103S, Offsite Dose Calculation Manual (Surry) (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 - Station

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.

2. The dose to the maximum exposed member of the public due to radioactive I liquid and gaseous effluents from the Station and from the ISFSI shall be incorporated with the dose assessment performed above. If the dose to the I 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 3 contribution from direct radiation.

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 Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

1. Radioactive Effluent Release Report covering operation of the ISFSI during the previous 12 months of operation shall be submitted within 60 days after January 1.

2. The ISFSI Radioactive Effluent Release Report shall specify the quantities of each of the principal radionuclides released to the environment in liquid and in gaseous effluents.

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DOMINION VPAP-2103S REVISION 8 PAGE 40 OF 71

3. Dose Assessment - ISFSI Provide .such information as may be required by the Commission to estimate potential radiation dose commitment to the public resulting from effluent releases from the ISFSI.

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.

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

DOMINION VPAP-2103S REVISION 8 PAGE 41 OF 71 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 submitted to Records Management in accordance with VPAP-1701, Records Management. Prior to transmittal to Records Management, the sender shall assure that:

• Each record is packaged when applicable. I

• QA program requirements have been fulfilled for Quality Assuirance records.

• Each record is legible, completely filled out, and adequately identifiable to the item or I activity involved.

" Each record is stamped, initialed, signed, or otherwise authenticated and dated, as required by this procedure.

7.1.1 Individual Records U None 7.1.2 Record Packages I

• Records of changes to the ODCM in accordance with Step 6.7.4 3

• Records of meteorological data in accordance with Step 6.7.3

• Records of sampling and analyses I

• 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 3 I

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DOMINION VPAP-2103S REVISION 8 PAGE 42 OF 71 ATTACHMENT 1 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Instrument Minimum Action Operable Channels

1. GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, RM-RRM- 131

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMINATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 1 2 Unit 2: 2-SW-RM-220 1 2 (b) Component Cooling Service Water Effluent Lines, 1-SW-RM- 107A 1 2 1-SW-RM- 107B 1 2 I-SW-RM- 107C 1 2 I-SW-RM- 107D 1 2

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW- 153 ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway shall be suspended.

ACTION 2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, Radioactive Liquid Waste Sampling and Analysis.

,1

DOMINION VPAP-2103S i REVISION 8 PAGE 43 OF 71 ATTACHMENT 2 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements I

I Channel Description Channel Check Source Check Channel Calibration Channel Functional Test I

1. GROSS RADIOACTIVITY PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE MONITORS I

(a) Radwaste Facility Liquid Effluent Line, RM-RRM-131 D P R Q I

2. GROSS BETA OR GAMMA RADIOACTIVI-TY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMI-I NATION OF RELEASE (a) Circulating Water Discharge Lines, I Unit 1: 1-SW-RM-120 Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water I

Effluent Lines, 1-SW-RM- 107A 1-SW-RM- 107B I

1-SW-RM-107C D M R Q 3.

1-SW-RM- 107D FLOW RATE MEASUREMENT DEVICES I

(a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 DR N/A R N/A I

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DOMINION VPAP-2103S REVISION 8 PAGE 44 OF 71 ATTACHMENT 3 (Page 1 of 3)

Radioactive Liquid Waste Sampling and Analysis Program Lower Limit of Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD)

Type Frequency Frequency Analysis (Ci/ml), (Note 1)

P, Principle Gamma 5 x 10-7 Emitters (Note 3)

(Each.Batch) (Each Batch) 1131 1 x 10-6 Dissolved and Batch ReleasesP M Entrained Gases 1 x 10-(One Batch/M) (Gamma Emitters)

(Note 2) P M Composite H3 1 x 10-5 (Each Batch) (Note 4) Gross Alpha 1 x 10-7 P

• ' Q Composite Sr 8 9 and Sr9 0 5 x 10-(Each Batch) (Note 4) Fe 5 5 1 x 10-6 Continuous W Composite Principal Gamma Emitters 5 x 10- 7 (Note 6)

(Note 6) (Note 6) 1131 1 x 10-6 CotnosMDissolved and IX1-Continuous M M Entrained Gases 1 x i0-Releases Grab Sample (Gamma Emitters)

(Note 5) Continuous M Composite H3 1 x 10-5 (Note 6) (Note 6) Gross Alpha 1 x 10-7 Continuous Q Composite Sr 8 9 and Sr 90 5 x 10-8 (Note 6) (Note 6) Fe 5 5 1 x 10-6

-)

DOMINION VPAP-2103S REVISION 8 PAGE 45 OF 71 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):

iLLD =(8-1) 4.66 sb B V

• 2.22E+06

• Y E e-(At)

Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection (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)

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)

= 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 appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 8 PAGE 46 OF 71 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 5 4 , Fe5 9 , C05 8, Go 60 , Zn 65 , Mo 9 9 , Cs 13 4 , Cs 1 37 , Ce 14 1, and Ce 14 4 . 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 I), effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 8 I

PAGE 47 OF 71 I ATTACHMENT 4 (Page 1 of 4)

I Radioactive Gaseous Waste Sampling and Analysis Program I

Gaseous Release Type Sampling Fre-quency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

I (Note 1)

I

__(lCi/ml),

A. Wase A. Waste Gas Gas (Each Prior Tank) to Release Prior to Release Principal Gamma 1x1-Storage Tank (Grab Sample) (Each Tank) Emitters (Note 2)

Prior to Release Prior to Release Principle Gamma I1 10-4 I

B. Containment Emitters (Note 2)

Purge (Each PURGE)

(Grab Sample)

(Each PURGE) H3 1 x 10-6 I

C. Ventilation (1)Process Vent (2)Vent Vent #1 Weekly (Grab Sample)

Weekly Principle Gamma Emitters (Note 2) 10-I (3)Vent Vent #2 (Note 3) (Note 3) H3 1 x 10-6 (4)SRF Vent 1 X 10-12 I

Weekly (Note 5) 031 Continuous (Note 4) (Charcoal Sample) 0133 1 x 10-10 I All Release Continuous (Note 4)

Weekly (Note 5) Principal Gamma Particulate Sample Emitter (Note 2)

Weekly I

Types as listed Continuous (Note 4)

Composite Particulate Sample Gross Alpha 1 x 10-11 I

in A, B, and C Continuous Quarterly CotinuusComposite (Note 4) Particulate Sr 8 9 and Sr 9 0 1 x 10-11 I

Continuous Noble Gas Monitor Noble Gases Gross 1 10-6 I

(Note 4) Beta and Gamma I Weekly Weekly Principle Gamma 1 X 10-4 Condenser Air Ejector Grab Sample (Note 3)

Emitters (Note 2)

H3 1 x 10-6 I

(Note 3)

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DOMINION VPAP-2103S REVISION 8 PAGE 48 OF 71 ATTACHMENT 4 (Page 2 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program

DOMINION VPAP-2103S REVISION 8 PAGE 49 OF 71 ATTACHMENT 4 (Page 3 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation):

LLD 4.66 Sbb (10-1)

E

• V

• 2.22E+06

• Y

• e-()(11t)

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).

= 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).

= 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.

DOMINION VPAP-2103S REVISION 8 PAGE 50 OF 71 ATTACHMENT 4 (Page 4 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: Kr87, Kr 8 8 , Xe 13 3 , Xe13 3 m, Xe 13 5, Xe13 5m, and Xe1 3 8 for gaseous emissions and Mn 5 4 , Fe 5 9 , Co58, C060, Zn 65 , Mo 9 9 , Cs 13 4, Cs 13 7, Ce 14 1 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, 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, when:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased more than a factor of 3; 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 has increased by a factor of 3; and

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

NOTE 6: To be representative of the quantities and concentrations of radioactive materials in gaseous effluents, composite sampling shall employ appropriate methods that will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S i REVISION 8 PAGE 51 OF 71 ATTACHMENT 5 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation I

I MINIMUM INSTRUMENT OPERABLE CHANNELS ACTION I

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release:

I 1-GW-RM-102, or 1-GW-RM-130-1 (b) Iodine Sampler: (NOTE 1) 1 1 I

(c)

Continuous HP Sampler, or 1-GW-RM- 130-1 Particulate Sampler: (NOTE 1) 1 2 I

Continuous HP Sampler, or 1-GW-RM- 130-1 (d) Process Vent Flow Rate Monitor:

1 2 I

1-GW-FT-100 1.

(e) Sampler Flow. Rate Measuring Device:

HP Sampler Rotometer or KAMAN Flow Rate Measuring 1 3

3 I

Device (Parameter #19)

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor:

I 1-SV-RM- 111 1 1 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring Device:

I 1 I Unit 1: 1-VP-FI-IA 1-VP-FI-lB Unit 2: 2-VP-FI-lA 1 1

1 3

3 3

I 3.

2-VP-FI-lB VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor:

1 3 I

SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104

-1 1

1 1 I Vent #2, 1-VG-RM -110, or 1-VG-RM-131-1 (b) Iodine Sampler: (NOTE 1) I SRF: RRM-101 1 2 SPS: Vent #1, 1-VG-RM-104 (NOTE 2)

Vent #2, Continuous HP Sampler, or 1 2 2

I 1-VG-RM-131-1 I

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DOMINION VPAP-2103S REVISION 8 PAGE 52 OF 71 ATTACHMENT 5 (Page 2 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler: (NOTE 1)

SRF: RRM-101 1 2 SPS: Vent #1, VG-RM-104 (NOTE 2) 1 2 Vent #2, HP Continuous Sampler, or 2 1-VG-RM-131-1 (d) Ventilation Vent Flow Rate Monitor:

SRF: 01-RHV-FT-156 1 3 SPS: Vent #1, 1-VS-FT-119 1 3 Vent #2, 1-VS-FT-i 16 1 3 (e) Sampler Flow Rate Measuring Device: (NOTE 1)

SRF: RRM-101 1 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 3 Vent #2, KAMAN Flow Rate Measuring Device 1 3

) (Parameter #19), or HP Sampler Rotometer NOTE 1): The mark numbers listed refer to the gaseous effluent radiation monitor with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

NOTE 2): Vent # 1, I-VG-RM- 104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.2.3]

ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.03 1, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4]

ACTION 2: If the number of operable channels is less. than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

[Commitment 3.2.4]

ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue

) provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

DOMINION VPAP-2103S REVISION 8 U

PAGE 53 OF 71 ATTACHMENT 6 (Page 1 of 2) I Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements I

CHANNEL FUCTHANNEL CHANNEL DESCRIPTION CHANNEL SOURCE CHECK CHECK CALIBRATION FUNCTIONAL

___ ___TEST I

PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor -

Providing Alarm and Automatic Termination of Release I

1-GW-RM- 102 I-GW-RM-130-1 (b) Iodine Sampler D M,

• R Q I Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A I (c) Particulate Sampler Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A I

(d) Process Vent Flow Rate Monitor 1-GW-FT-100 D N/A R N/A I

(e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or KAMAN Flow Rate Measuring D

D N/A N/A SA R

N/A N/A I

Device (Parameter #19)

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor I

Unit 1: 1-SV-RM-111 Unit 2: 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring I Device Unit 1: 1-VP-FI-IA 1i-VP-FI-lA

-VP-FI- 1B

• Unit 2: 2-VP-F-I-1A D N/A R N/A i

3.

2-VP-FI- 1B VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor I

SRF: RRM-101 SPS: 1-VG-RM -110 1-VG-RM - 131-1 I

I-VG-RM-104 I

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DOMINION VPAP-2103S REVISION 8 PAGE 54 OF 71 ATTACHMENT 6 (Page 2 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION CHECK CHECK CALIBRATION FUNCTIONAL TEST (b) Iodine Sampler SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP W N/A N/A N/A Sampler or I-VG-RM- 131 -1 (c) Particulate Sampler SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP W N/A N/A N/A Sampler or 1-VG-RM-131-1 (d) Ventilation Vent Flow Rate Monitor SRF:01 -RHV-FT- 156 SPS: Vent #1, 1-VS-FT-119 D N/A R N/A Vent #2, 1-VS-FT-116 (e) Sampler Flow Rate Measuring Device SRF: RRM-101 D N/A R N/A SPS: Vent #1, 1-VG-RM-104 D N/A R N/A Vent #2, KAMAN Flow Rate D N/A R N/A Measuring Device (Parameter

1. 19), or HP Sampler Rotometer D N/A N/A S/A

• Prior to each Waste Gas Decay Tank release NOTE: The mark numbers listed above in 1(b), 1(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

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DOMINION VPAP-21i03S .

REVISION 8 PAGE 55 OF 71.

ATTACHMENT 7 (Page 1 of 3)

Radiological Environmental Monitoring Program I

I Exposure Pathway and/or Sample

1. DIRECT Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis I RADIATION About 40 Routine Monitor-ing Stations to be placed as I

follows:

1) Inner Ring in general area of site boundary GAMMA DOSE I

with station in each sector

2) Outer Ring 6 to 8km I

from the site with a station in each sector

3) The balance of the 8 Quarterly Quarterly I

dosimeters should be placed in special interest I areas such as population centers, nearby residents, schools, and I in 2 or 3 areas to serve as

2. AIRBORNE controls I

Samples from 7 locations:

a) 1 sample from close to the site boundary I

location of the highest calculated annual Radioiodine Canister 1131 Analysis Weekly I average ground level Continuous Radioiodines and Particulates D/Q b) 5 sample locations 6-8 Sampler operation with Particulate Sampler I km distance located in a sample collection Gross beta radioactivity concentric ring around the Station weekly analysis following filter change; I

c) 1 sample from a control Gamma isotopic analysis location 15-30 kin distant, providing valid of composite (by location) quarterly I

background data I

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DOMINION VPAP-2103S REVISION 8 PAGE 56 OF 71 ATTACHMENT 7 (Page 2 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

3. WATERBORNE a) 1 sample upstream mnhy isotopic analysis Gamma b) 1 Monthly Sample monthly; a) Surface Composite for tritium analysis quarterly b) Ground Sample from 1 or 2 sources Quarterly Gamma isotopic and tritium analysis quarterly c) Sediment from a) 1 sample upstream Semi-Annually Gamma isotopic analysis semi-shoreline b) 1 sample downstream annually a) I sample upstream Gamma isotopic analysis semi-b) I sample downstream Semi-Annually annually

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and I"' anal-b) I sample from milking Monthly ysis monthly animals at a control location (-15-30 km distant). (NOTE 2) a) 2 samples of oysters in the Semi-Annually Gamma isotopic on edibles vicinity of the Station b) 4 samples of clams in the Semi-Annually Gamma isotopic on edibles b) Fish and vicinity of the Station Invertebrates c) 1 sampling of crabs from

. theviiniy the vicinity off te taton the Station Annually Gamma* isotopic on edibles d) 1 sampling of 2 different species from the discharge Semi-Annually Gamma isotopic on edibles canal (catfish, white perch, eel)

NOTE- 1: If milk sampling cannot be performed, use item 4.c)d). Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station.

NOTE 2: If milk sampling from a control location cannot be performed, use item 4.c)e). Milk

.iil sampling cannot be performed whdn there is no milk sampling location 30 km distant.

DOMINION VPAP-2103S REVISION 8 PAGE 57 OF 715

• ATTACHMENT 7 (Page 3 of 3)

Radiological Environmental Monitoring Program I

I Exposure Pathway and/or Sample Number of Sample and Sample Location Collection

-Frequency Type and Frequency of Analysis I

4. INGESTION (Continued) I a) 1 sample cornAnuly b) 1 sample soybeans c) 1 -sample peanutspotn Anualy Gmaiopconebe Gamaisotoinneil I d) 1 sample of a broadleaf vegetation grown I

nearest in each of two different available offsite locations I

c) Food Products (sectors) with the

• highest annual average I ground level DIQs, if Monthly, if Gamma isotopic and 1131 milk sampling is not performed.

available, or at harvest analysis I

e) 1 sample of a broadleaf vegetation grown 15 -

30 km distant in the I available least prevalent wind direction, if milk sampling is not I

performed.

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DOMINION VPAP-2103S REVISION 8 PAGE 58 OF 71 ATTACHMENT 8 (Page 1 of 3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Air Charcoal and Surry Station (SS) 0.3 NNE Particulate. Hog Island Reserve (HIR) 2.0 NNE Bacons Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite **

TLDs West North West (02) 0.2 WNW Site Boundary

3 Surry Station Discharge 0.4 NW Site Boundary (03)

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 ENE Site Boundary East (09) 0.3 E Exclusion Area Boundary and Site Boundary West (10) 0.1 W Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) 0.4 S Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) 1.6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103Si REVISION 8 PAGE 59 OF 71 I ATTACHMENT 8 (Page 2 of 3) 3 Environmental Sampling Locations I

SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) i Environmental TLDs Bacon's Castle Route 633 (20)

(21) 4.5 4.9 SSW SW Approx. 5 miles Approx. 5 miles I

Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7, WSW Population Center I Route 636 and 637 (24) 4.0 W Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles I Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway Route 617 and 618 (27)

(28) 3.8 4.9 NNW NNW Approx. 5 miles Approx. 5 miles I

Kingsmill Williamsburg (29)

(30) 4.6 7.8 N

N Approx. 5 miles Population Center I

Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center i Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles I Lee Hall (35) 7.1 ENE Population Center Goose Island Fort Eustis (36)

(37) 5.1 4.9 E

ESE Approx. 5 miles Approx. 5 miles I

Newport News (38)

James River Bridge (39) 19.3 17.1 SE SE Population Center Control 1

Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control I Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 S Approx. 5 miles i Milk Epp's 4.8 SSW Colonial Parkway Williams 3.7 27.5 NNW S Control Location I

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DOMINION VPAP-2103S REVISION 8 PAGE 60 OF 71 ATTACHMENT 8 (Page 3 of 3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Well Water Surry Station Onsite***

Hog Island Reserve 2.0 NNE Crops (Corn, Slade's Farm 3.2 S Peanuts, Soybeans) Brock's Farm 3.8 S River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 1.3 NNW Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Hog Island Point 2.4 NE Lawne's Creek 2.4 SE Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve 0.6 N Sediment Chickahominy River 11.2 WNW Control Location

• • Onsite Location - in Lead Shield Onsite sample of Well Water-taken from tap-water at Surry Environmental Building

DOMINION VPAP-2103S REVISION 8 I

PAGE 61 OF 71 I ATTACHMENT 9 (Page 1 of 2)

I Detection Capabilities for Environmental Sample Analysis I

LOWER LIMIT OF DETECTION (LLD)

Analysis Water Airborne Fish Milk Food Sediment I

(NOTE 2) (pCi/l) Particulate (pCi/kg) (pCi/I) Products (pCi/kg) or Gases (pCi/m 3 )

(wet) (pCi/kg)

(wet)

(dry) I Gross beta H-3 4

2,000 0.01 I

Mn-54 15 130 Fe-59 30 260 I Co-58, 60 15 130 Zn-65 Zr-95 30 30 260 I Nb-95 1-131 15 (NOTE 3) 1 0.07 1 60 Cs-134 Cs- 137 15 18 0.05 0.06 130 150 15 18 60 80 150 180 I

Ba-140 60 60 La-140 15 15 I NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. I 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 be I identified and reported.

NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) I water samples is 10 pCi/l.

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DOMINION VPAP-2103S REVISION 8 PAGE 62 OF 71 ATTACHMENT 9 (Page 2 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

NOTE 1: For a particular measurement system (which may include radiochemical separation):

• LLD 4.66 sbb (24-1)

E* V 2.22E+06 9 Y

• e-(*X2t)

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)

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)

= 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 VPAP-2103S1 REVISION 8 PAGE 63 OF 71 I

ATTACHMENT 10 (Page 1 of 1)

Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water I (pCi/l)

Airborne Particulate or Fish (pCi/kg, wet)

Milk (pCi/1)

Food Products (pCi/kg, wet)

I 3

Gases (pCi/m )

H-3 30,000 I

Mn-54 1,000 30,000 Fe-59 400 10,000 i Co-58 1,000 30,000 Co-60 Zn-65 300 300 10,000 20,000 I

Zr-Nb-95 1-131 400 (NOTE 1) 2 0.9 3 100 I

Cs-134 Cs- 137 30 50 10 20 1,000 2,000 60 70 1,000 2,000 i

Ba-La- 140 200 300 NOTE 1: Reporting level for the ground (drinking) water samples required by Radiological I

Environmental Monitoring Program (Attachment 7). The reporting level for the surface (non-drinking) water samples required by Attachment 7 is 20 pCi/l. I I

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DOMINION VPAP-2103S REVISION 8 PAGE 64 OF 71 ATTACHMENT 11 (Page 1 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEORLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year 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 five year average X/Q and D/Q values are used in the dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public.

1.2 Meteorological Data, Parameters, and Methodology A five (5) year average of representative onsite meteorological data for the period January 1, 1992 through December 31, 1996, is used in the gaseous effluent dose pathway calculations.

This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (i.e.,

ventilation vent), and those characterized as mixed mode (i.e., process vent). The portions of release characterized as ground level were based on AT 15 8 .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/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ -

Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The code is based upon a straight line airflow model implementing the assumptions outlined in Section C (excluding Cla and Clb) of Regulatory Guide 1.111, "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 XIQ values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m 2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was based on a process vent release height of 131 ft, and plume rise due to momentum for a vent

• 2. diameter of 3 in. with plume exit velocity of 100 ft/sec.

DOMINION VPAP-2103S REVISION 8 PAGE 65 OF 71 ATTACHMENT 11 (Page 2 of 8) U Meteorological, Liquid, and Gaseous Pathway Analysis 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 Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table 11A-8.

X/Q and D/Q values were calculated for the nearest site boundary, residence, milk-cow, I discharge bank, and vegetable garden by sector for process vent and ventilation vent releases.

According to the definition for short term in NUREG-01 33, "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. I 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.

1.3 Results The X/Q value that would result in the maximum total body, skin, and inhalation exposure for ventilation vent releases was 6.OE-05 sec/m 3 at a site boundary location 532 meters NNE sector. For process vent releases, the site boundary XIQ value was 3.7E-07 sec/m 3 at a location 565 meters WSW sector. The discharge canal bank XIQ value that would result in the maximum inhalation exposure for ventilation vent releases was 1.6E-04 sec/m 3 at a location 290 meters NW sector. The discharge canal bank X/Q value for process vent was 6.9E-07 sec/m 3 at a location 290 meters NW sector. I I

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DOMINION VPAP-2103S REVISION 8 PAGE 66 OF 71 ATTACHMENT 11 (Page 3 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The grass-cow-milk pathway analysis, which is performed to derive the maximum exposure from 1131, V133, and from all radionuclides in particulate form with half-lives greater than eight days, is based on the dairy location indicated by the 1996 Land Use Census. The D/Q value from ventilation vent releases that would result in the maximum exposure was 2.5E-10 per m2 at a location 5873 meters NNW sector. For process vent releases, the D/Q value was 1.4E-10 per m2 at a location 7788 meters SSW sector. For tritium, the X/Q value from ventilation vent releases that would result in the maximum exposure for the grass-cow-milk pathway was 1.5E-06 sec/m 3 at a locations 5873 meters NNW sector, and 7.OE-08 sec/M 3 for process vent releases at a location 7788meters SSW sector. The inhalation pathway is the only other pathway existing at this location. Therefore, the XIQ values given for tritium also apply for the inhalation pathway.

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 included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents.

2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station 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-0 133.

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DOMINION VPAP-2103S REVISION 8 I

PAGE 67 OF 71 ATTACHMENT 11 (Page 4 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Liquid radioactive effluents from both units are released to the James River via the discharge I canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year.

For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e. a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities

• and ingestion of fish and invertebrates are included in the Canberra Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal.

2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs.

Validation of the limiting age group and critical organ is performed by Canberra's liquid effluent dose calculation program using the data, parameters, and methodology provided in the Canberra Source Code file.

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DOMINION VPAP-2103S REVISION 8 PAGE 68 OF 71 ATTACHMENT 11 (Page 5 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are 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 analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of 1131, 1133, tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from 1131, 1l33, tritium, and particulates to demonstrate compliance with Step 6.3.1 .a.

3.2 Data, Parameters, and Methodology Five year average X1Q 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 accessible to the public inside site boundary. The largest X/Q value was determined to be 6.OE-05 sec/m3 at site boundary for ventilation vent releases at a location 532 meters NNE direction, and 3.7E-07 sec/m 3 at site boundary for process vent releases at a location 565 meters WSW 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.

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-2103S I REVISION 8 PAGE 69 OF 71 ATTACHMENT 11 (Page 6 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The maximum exposed individual for 10CFR50 Appendix I compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable garden, using the 199,6 Land Use Census data. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which .is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses.

The gamma and beta dose factors Kivv, Liv, Mivv, and Nivv for ground level releases and the I gamma and beta dose factors Kip, Lipv, Mip, and Nipv for mixed mode releases are included in the Canberra Source Code file. I Inhalation pathway dose factors Pi, and Pipv are calculated using the following equation:

Pi mrem/yr per Ci/m 3 = K' (BR) DFAi (28-1) where:

K' = a constant of unit conversion, 1E+12 pCi/Ci BR = the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev. 1 DFAi=the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0133, R.G. 1.109, Rev. 1, and LADTAP II, NUREG/CR-1276 It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year. The maximum five year average ./Q at this location was determined to be 1.6E-04 sec/m 3 at 290 meters NW direction.

Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis.

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DOMINION VPAP-2103S REVISION 8 PAGE 70 OF 71 ATTACHMENT 11 (Page 7 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation:

RMi = K + ?ý Fm (r) (DFLi P + (1 -- pfs)Xith 1 4 itf (28-2)

SLp Ys where:

K' = a constant of unit conversion, 1E+12 pCi/Ci QF = cow's consumption rate, 50, in Kg/day (wet weight)

Uap= infant milk consumption rate, 330, liters/yr Yp = agricultural productivity by unit area of pasture feed grass, 0.7 Kg/m2 Ys = agricultural productivity by unit area of stored feed, 2.0, in Kg/m2 Fm = stable element transfer coefficients r = fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, in mrem/pCi ki = decay constant for the ith radionuclide, in sec-1 2w = 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 = transport time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th = transport time from pasture, to harvest, to cow, to milk, to receptor, 7.78E+06, in seconds fp = fraction of year that cow is on pasture, 0.67 (dimensionless), 7.78E+06 in seconds f, =fraction of cow feed that is pasture grass while cow is on pasture, 1.0, dimensionless Parameters used above were obtained from NUREG-01 33 and Regulatory Guide 1.109, Rev. 1, and LADTAP II, NUREG/CR- 1276.

DOMINION VPAP-2103S I REVISION 8 PAGE 71 OF 71 ATTACHMENT 11 (Page 8 of 8) I Meteorological, Liquid, and Gaseous Pathway Analysis Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used:

U RH3 =K K" FmQFUap (DFL H 3 ) .75(0.5/H)] (28-3) where:

K" '=a constant of unit conversion 1E+03 gm/kg I H = absolute humidity of the atmosphere, 8.0, gm/m3 0.75=the fraction of total feed that is water I 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined. I The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation:

RI mrem/yr per Ci/m 3 = K' (BR) DFAi (28-4) I where:

K'=a constant of unit conversion, 1E+12 pCi/Ci BR=breathing rate of the particular age group, m 3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0133, R. G. 1.109, Rev. 1 andI LAPTAP II, NUREG/CR-1276.

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Administrative ProceduresAction Reque WDominioni (A-PAR)

VPAP-0502 Attchen - 21Pge1o Instructionu for completing mhis form are included inl VI-AI-'-502.

i.Procedure Number 2).Revisipn 3;Page 4. Effective Date VPAP-2103S 1lof I9-6~-0o 6 5oPotttslte 6oseTitlyCaculation Medaure Manual (Surry)

7. Type of Request

[ ]New Procedure [x] Procedure Revision [ ] Procedure Deletion [ ] Emergency Change

8. Brief description of the modification See Revision Summary of affected procedure

9. Location [X] SPS [ ]NAPS [ ]CORP Location [ ]SPS [ ]NAPS [ ]CORP

10. Requested by (Printed Name) 11. Date 12. Phone 13. Requested by (Printed Name) 14. Date 15. Phone P. Blount 17/18/06 1 2467 N/A N/A N/A

16. Does procedure meet requirements of NOTE below? []Yes [x] No

17. Does this procedure require a Regulatory Evaluation? [ ]Yes [?q No

18. Are there any new sections or steps designated North Anna or Surry? (Surry Only Procedure) [ I Yes [XJ No

19. Is the reason for the station-specific instructions due to differences in regulatory requirements? [ ] Yes [ ] No [x] N/A

.12Q. Is the reason for the station-specific instructions due to differences in construction? []Yes [ ] No [x] N/A

) Is the reason for the station-specific instructions due to station preferences? [ ] Yes [ ] No [x] N/A If all answers are No or N/A, approval is required by PPOs as identified on the Procedure Cover Page. Check block 30.

Ifblock 16 or 17 is Yes, approval is required by PPOs, SNSOCs, and/or Site Vice Presidents. Check blocks 30, 31, and 32, as appropriatc NOTE: VPAP-21 01 and VPAP-2201 require SNSOCs approval.

SPIPs, VPAP-2103N, VPAP-2103S, VPAP-2104, and VPAP-2401 require SNSOC(s) and Site Vice President(s) approval.

I If block 18, 19, or 20 is Yes with block 21 No, approval is required by PPOs and Site Vice Presidents. Check blocks 30 and 32.

If block 21 is Yes, approval is required by PPOs, Site Vice Presidents, and Vice President Corporate. Check blocks 30, 32, and 33.

22. Did this procedure require the attachments in DNAP-0112, Dominion Nuclear Change Management Process, to be used? []Yes [x]No

23. Location [xl SPS [ ]NAPS [ ]CORP Location ]SPS [ ]NAPS [ lCORP

24. PPO (Printed Name) 25. Date 26. Phone 27. PPO (Printed Name) 28. Date 29. Phone L. B. Jones . 7/18/06 N/A N/A N/A Re -o Aov A o - D F-

[x] 30. PPO(s) [x] 31. SNSOCs [x] 32. Site Vice Presidents [ 33. Vice President (Corp)

34. PPO (Signature 35. Date 36. PPO (Signature) N/A 37ate 3SNSOatOe 40. SNSOC Chairman (Signature) 41. Date N/A 0./ 44. Site Vice President (Signajt) 45. Date

42. Srte)V i ,oaturo)

I Vice President Corporate (Signature) 47. Date irry Power Station;

I)-Process/Prog ram Owner(s);

SPIPs-Secudty Plan Implementing Procedures Form No. 720457(Dec 200

MOL* Station VDominionw Administrative Procedure

Title:

Offsite Dose Calculation Manual (Surry)

Process / Program Owner: Manager Radiological Protection and Chemistry (Surry)

Procedure Number Revision Number Effective Date VPAP-2103S 9 On File Revision Summary Revised in response to S-2005-4307, Redefinition of Exclusion Area Boundary (TSCR 383):

• Revised Attachment 8, Environmental Sampling Locations, Environmental TLD East (09) -

changed "Exclusion Area Boundary and Site Boundary" to "Site Boundary."

Approvals on File

DOMINION VPAP-2103S 1 REVISION 9 PAGE 2 OF 71 TABLE OF CONTENTS I Section Page I

1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 I 6.2 Liquid Radioactive Waste Effluents 11 6.2.1 Liquid Effluent Concentration Limitations 11 6.2.2 Liquid Monitoring Instrumentation 12 6.2.3 Liquid Effluent Dose Limit 15 I 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 Limitations 19 6.3.2 Gaseous Monitoring Instrumentation 21 6.3.3 Noble Gas Effluent Air Dose Limit 24 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 26 6.3.5 Gaseous Radwaste Treatment 28 6.4 Radioactive Liquid and Gaseous Release Permits 29 6.4.1 Liquid Waste Batch Releases 29 6.4.2 Continuous Liquid Releases 29 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 30 6.4.4 Reactor Containment Release Permits 30 6.4.5 Miscellaneous Gaseous Release Permit 30 I

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DOMINION VPAP-2103S REVISION 9.

PAGE 3 OF 71 TABLE OF CONTENTS (continued)

Section Page 6.4.6 Radioactive Liquid and Gaseous Release Controls 30 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 32 6.6 Radiological Environmental Monitoring 32 6.6.1 Monitoring Program 32 6.6.2 Land Use Census 34 6.6.3 Interlaboratory Comparison Program 35 6.7 Reporting Requirements 36 6.7.1 Annual Radiological Environmental Operating Report 36 6.7.2 Annual Radioactive Effluent Release Report 38 6.7.3 Annual Meteorological Data 40 6.7.4 Changes to the ODCM 40 7.0 RECORDS 41 ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 42 2 Radioactive Liquid Effluent Monitoring Instrumentation 43 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 44 4 Radioactive Gaseous Waste Sampling and Analysis Program 47 5 Radioactive Gaseous Effluent Monitoring Instrumentation 51 6 Radioactive Gaseous Effluent Monitoring Instrumentation 53 Surveillance Requirements 7 Radiological Environmental Monitoring Program 55 8 Environmental Sampling Locations 58 9 Detection Capabilities for Environmental Sample Analysis 61 10 Reporting Levels for Radioactivity Concentrations in Environmental 63 Samples 11 Meteorological, Liquid, and Gaseous Pathway Analysis 64

DOMINION VPAP-2103S I REVISION 9 PAGE 4 OF 71 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive I Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to 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 RCi/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 I 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 V 3 1133, and H3 , and all radionuclides in particulate form with half-lives greater than 8.,

11, 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

• Exposure to a real individual will not exceed 40 CFR 190 dose.limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at Surry Power Station. I I

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DOMINION VPAP-2103S REVISION 9 PAGE 5 OF 71

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 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 9 I

PAGE 6 OF 71 i 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls I

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 3.1.20 Surry UFSAR I

3.1.21 Laboratory Quality Assurance Plan, Manual 100; Framatome Environmental Laboratory I

• 3.1.22 VPAP-2802, Notifications and Reports 3.1.23 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis I

3.2 3.1.24 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis Commitment Documents I

3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report I 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability I Sampling 4.0 DEFINITIONS I 4.1 Channel Calibration Adjustment, as necessary, of the channel output. so it responds with the necessary range and I accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test, I The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated. I 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This I assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter.

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DOMINION VPAP-2103S REVISION 9 PAGE 7 OF 71 4.3 Channel Functional Test There are two types of Channel Functional Tests.

4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions.

4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions.

4.4 Critical Organ That 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.

4.5 Dose Equivalent 1-131 That concentration of 1131 (pCi/cc) that alone Would produce the same thyroid dose as the quantity and isotopic mixture of 1131, 1132, 1133, 0134, and 1135 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-2103S REVISION 9 I

PAGE 8 OF 71 I

4.6 Frequency Notations I

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

NOTATION FREQUENCY I

D - Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I W - Weekly At least once per 7 days M - Monthly At least once per 31 days I Q - Quarterly At least once per 92 days SA - Semi-annually At least once per 184 days I R - Refueling At least once per 18 months S/U - Start-up Prior to each reactor start-up I P - Prior to release Completed prior to each release N.A. - Not applicable Not applicable I DR - During the release At least once during each release 4.7 Gaseous Radwaste Treatment System I 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, I

regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas surge tanks.

I 4.8 General Nomenclature X = Chi: concentration at a point at a given instant (curies per cubic meter)

I D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) i Q = Source strength (instantaneous; grams, curies)

= Emission rate (continuous; grams per second, curies per second)

I 4.9

= Emission rate (continuous line source; grams per second permeter)

Lower Limit of Detection (LLD)

I The 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 I

probability of falsely concluding that a blank observation represents a "real" signal.

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DOMINION VPAP-2103S REVISION 9 PAGE 9 OF 71 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with 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 materials.

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 to purify the confinement.

4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2546 Megawatts Thermal 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 radiation.

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-2103S REVISION 9 U

PAGE 10 OF 71 4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by I 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 or recreational purposes.

4.19 Ventilation Exhaust Treatment System I 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 High I 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 I The 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 monitoring, 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. I 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents. 3 I

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DOMINION VPAP-2103S REVISION 9 PAGE 11 OF 71 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 11).

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 gCi/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-2103S I REVISION 9 PAGE 12 OF 71

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 7*gCi/mli (1) I Volume of Waste Discharged x _A i 1

where: I RCi/mli = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as gCi/ml from 10 CFR 2.0, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 gCi/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 U affected channel Declare the channel inoperable I

• Change the setpoint to an acceptable, conservative value I

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DOMINION VPAP-2103S REVISION 9 PAGE 13 OF 71

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 Functional 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, 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 Service Water System Effluent Line 1-SW-RM-107 A, B,C,D Condenser Circulating Water Line 1-SW-RM-120 2-SW-RM-220 Radwaste Facility Effluent Line 11-RM-RRM- 131

)

DOMINION VPAP-2103S I REVISION 9 PAGE 14 OF 71

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

1. Maximum setpoint values shall be calculated by: I CFD S FE F (2) I where:

S = the setpoint, in jtCi/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 /Ci/ml FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as:

D = FE + (200,000 gpm x number of circ. pumps in service)

2. Each of the condenser circulating water channels (e.g., SW-120, SW-220) monitors the effluent (service water, including component cooling service 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:

I S = C (3) I 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 service .

water system effluent line (i.e., SW-107 A, B, C, D), and the Radwaste Facility effluent line (i.e., RRM-13 1).

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DOMINION VPAP-2103S REVISION 9 PAGE 15 OF 71

4. For the service water system effluent line, Equation (2) becomes:

S CFDKSWFE-FE (4) 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

5. For the Radwaste Facility effluent line, Equation (2) becomes:

CFDKRw S -R (5)

FE where:

KRW = The fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

6. The sum Ksw + KRW 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 public from radioactive materials in liquid releases (from each reactorunit) 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-2103S REVISION 9 PAGE 16 OF 71

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 NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation:

D :t FM iAi (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 I t = the period for which Ci and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, I dimensionless, 0.2 from Appendix 11A, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci= the average concentration of radionuclide, i, in undiluted liquid effluentI during the period t, from all liquid releases, in ptCi/ml I I

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DOMINION VPAP-2103S REVISION 9 PAGE 17 OF 71 Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem-ml per hr-gCi. Values for Ai are provided in the Canberra Source Code file.

Ai= 1.14 E+05 (21BFi + 5BIi) DFi (7) for example:

1.14 E+05 = 1 E+06 pCi/ltCi x 1 E+03 ml/kg/(8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 BIi = the bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/1 BFj = the bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/i DFi = the critical organ dose conversionfactor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II, NUREG/CR- 1276, and TID-4500, VCRL-50564, Rev. 1.

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.

DOMINION VPAP-2103S REVISION 9 U

PAGE 18 OF 71 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 I

1. The Surry Radwaste Facility Liquid Waste 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 and Critical Organ Dose Calculation I

1. Determine DI, the sum of all liquid open and closed release points, in mrem, by the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for liquid releases by the ith organ for the particular quarter of the release.

4. Determine Dp, the 31 day projected dose by the ith organ:

Dp = (DI x P) + Da I

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DOMINION VPAP-2103S REVISION 9 PAGE 19 OF 71 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 Limitations

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.

2. The dose rate limit for 1131, 133, 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 1131, I133, 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-2103S REVISION 9 I

PAGE 20 OF 71 I

c. CalculationsI of Gaseous Effluent Dose Rates I NOTE: The dose factors used in the Gaseous Effluent Dose Rate calculations are included in the Canberra Source Code file. These dose factors, Ki, Li, Mi, and Pi for ventilation I vent and process vent releases, DO NOT include the applicable X/Q value. Equations (8), (9), and (10) must be multiplied by the appropriate X/Q value for Gaseous Effluent Dose Rate calculations.

I

1. The dose rate limit for noble gases shall be determined to be within the limit by I

limiting the release rate to the lesser of:

I i

K ivvQivv + KipvQipv] mremlyr to the total body (8)

I OR I

i Livv + 1.1Mivv)Qivv+(Lipv + 1.1Mipv)Qipv] 3000 mrem/yr to the skin (9)

I where:

Subscripts = vv, refers to vent releases from the building ventilation vent, I including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide I

Kivv, Kipv = 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 I

Livv, Lipv = 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 I

Mivv, Mipv = 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 I

ivv, ipv = The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) I 1.1 = The unit conversion factor that converts air dose to skin dose, in mrem/mrad I

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DOMINION VPAP-2103S REVISION 9 PAGE 21 OF71

2. The dose rate limit for 1131, 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:

EP ivv ivv + P ipvip] <_1500 mrem/yr to the critical organ (10) i where:

Pivv, Pip = The critical organ dose factor for ventilation vents or process vent for 1131, I"',H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec Qi VVQiPV = The release rate for ventilationvents or process vent of 1131, 1133, 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 ()i, 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.l.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 Functional Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 6).

DOMINION VPAP-2103S I REVISION 9 PAGE 22 OF 71 I

b. Action

1. If a radioactive gaseous effluent monitoring instrumentation channel alarm/trip I

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 I

channel and declare the channel inoperable or I

• Change the setpoint so it is acceptablyconservative

2. If the number of operable channels is less than the minimum required by tables I

in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5),

take the action shown in those tables.

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3. Return instruments to operable status within 30 days. If unsuccessful, explain in the next Annual Radioactive Effluent Release Report why the inoperability was I

not corrected in a timely manner.

c. Applicable Monitors I

Radioactive gaseous effluent monitors for which alarm/trip setpoints shall be determined are:

I Release Point Process Vent Instrument Number 1-GW-RM-102 I

1-GW-RM-130-1 Condenser Air Ejector I-SV-RM-111 2-SV-RM-211 I

Ventilation Vent No. 1 Ventilation Vent No. 2 1-VG-RM-104 1-VG-RM-110 I

I-VG-RM- 131 -1 Radwaste Facility Vent RRM-101 I I

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DOMINION VPAP-2103S REVISION 9 PAGE 23 OF 71

d. Setpoint Calculations

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

D >Dpv + Dcae +Dvv (11) 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, mremryr 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 the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

2. Setpoint values shall be determined by:

R x 2.12 E-03 Cm = F(12) m F m

where:

m = The release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv)

Cm = The effluent concentration limit implementing Step 6.3.1 .a.

for the Station, pCi/ml Rm = The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe 133 as nuclide to be released, pCi/sec

.2.12E-03 = CFM per ml/sec Fm = The maximum flow rate for pathway m, CFM 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.

DOMINION VPAP-2103S I REVISION 9 PAGE 24 OF 71 6.3.3 Noble Gas Effluent Air Dose Limit NOTE: The dose factors used in the Noble Gas air dose calculations are included in the Canberra Source Code file. These dose factors, Mi and Ni for ventilation vent and process vent releases, DO NOT include the applicable X/Q value. Equations (13) and (14) must be multiplied by the appropriate X/Q value for gamma and beta air dose

~I calculations.

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 *!0 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 6.3.3.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.

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DOMINION VPAP-2103S REVISION 9 PAGE 25 OF 71

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]

gi (13)

For beta radiation:

Db = 3.17E-08ZNivvQivv + NipvQipv] (14) i Where:

' )-2.

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and 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 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 Qivy, 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 VPAP-2103S I REVISION 9 PAGE 26 OF 71 6.3.4 1-131, 133, H-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, ill', 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 tothe critical organ

2. Cumulative dose contributions to a member of the public from 1131, 1133, 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 1 If the calculated dose from the release of 1131, 1133, 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.

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DOMINION VPAP-2103S REVISION 9 PAGE 27 OF 71

c. Dose Calculations NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

NOTE: The RMi and RIi dose factors DO NOT include the applicable D/Q and X/Q values respectively for Surry Power Station. Equation (15) must be multiplied by the applicable D/Q or X/Q, as appropriate, to calculate the critical organ dose.

Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Q 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 1131, 1133, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

Dr 3.17E-08 Nj(RMivvQivv + RMipvQipv) + (RlivvQivv + i (15)

~

r IVVVV Rlipv ipv]

i For example:

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors; 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 cow-milk pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per gCi/m 3 . Factors are included in the Canberra Source Code file.

DOMINION VPAP-2103S REVISION 9 I

PAGE 28 OF 71 Rlivv,=Rlipv the inhalation pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per gCi/m 3 . Factors are included in the Canberra Source Code file. i Oivv=Qipv the release for ventilation vents or process vent of 1131, 1133, tritium, and from all particulate-form radionuclides with half-3.17 E-08 lives greater than 8 days in Curies

= the inverse of the number of seconds in a year I

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. Appropriate portions of the Gaseous Radwaste Treatment System shall be used to reduce radioactive materials in gaseous waste before its discharge, when the 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 I 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 I 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 i per 31 days, based on the calculations in Step 6.3.5.c.

b. Action i 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. I

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

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DOMINION VPAP-2103S REVISION 9 PAGE 29 OF 71

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations,

1. Determine Dg, the sum of all gaseous open and closed release points, in mrem, by the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for gaseous releases by the ith organ for the particular quarter of the release.

4. Determine Dp, the 31 day projected dose by the ith organ.

Dp = (Dg x P) + Da, 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. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis.

6.4.1 Liquid Waste Batch Releases

a. Operations shall obtain RP authorization before initiating batch releases of radioactive liquids.

b. Release of contents from the following tanks/sumps other than transfers to the Radwaste Facility shall have a release permit before the discharge. Examples of batch releases include:

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode

• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage

• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases

a. Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids.

DOMINION VPAP-2103S I REVISION 9 PAGE 30 OF 71

b. Examples of continuous releases include:

• Steam generator blowdown I

• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable

• Turbine building sumps and subsurface drains when pumps are in automatic mode or storm drains 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. I 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or I containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until: I

• 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 3 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 3 through the Process Vent or Ventilation Vents.

6.4.6 Radioactive Liquid and Gaseous Release Controls 3

a. Operations shall notify RP of pending releases and request RP to initiate the appropriate release permit. Operations shall provide the necessary information to 3 complete the required release permit.

b. A representative sample shall be obtained of the source to be released. 3

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

time of sample) for samples obtained outside the Primary Sample Room. 3

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

3. RP shall obtain gaseous samples.

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DOMINION VPAP-2103S REVISION 9 PAGE 31 OF 71

c. RP shall perform required 'sample analyses.

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

• Maximum authorized release rate

• 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 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-2103S REVISION 9 I

PAGE 32 OF 71 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement U 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 3 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 releases 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 3 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.

U 6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement I

1. The Radiological Environmental Monitoring Program shall be conducted as.

specified in Radiological Environmental Monitoring Program (Attachment 7). 3 I

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DOMINION VPAP-2103S REVISION 9 PAGE 33 OF 71

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 8).

3. Samples shall be analyzed in accordance with:

- Radiological Environmental Monitoring Program (Attachment 7) requirements

• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 9)

• 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 6.6.1 .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 Specification (Surry Technical Specification 6.6.B.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 10), 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 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 10) are detected in the sampling medium, the report shall be submitted if:

concentration (1) + concentration (2) + 1.0 (16) reporting level (1) reporting level (2)

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DOMINION VPAP-2103S I REVISION 9 PAGE 34 OF 71

3. When'radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10) are 3 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 required 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 VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 7), 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.

6.6.2 Land Use Census

a. Requirement A land use census shall be conducted and shall identify, within a distance of 8 km 3 (5 miles), the location in each of the 16 meteorological sectors of the following:

' Nearest milk animal 3

• Nearest residence

• Nearest garden greater than 50 m 2 (500 ft2 ) that produces broad leaf vegetation 3

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., 3 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.

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DOMINION VPAP-2103S REVISION 9 PAGE 35 OF 71

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 7) shall be followed, including analysis of control samples.

b. Action

1. If a land use census identifies locations that yield a calculated dose or dose commitment greater than the values currently being calculated in Step 6.3.4.a.,

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 dose commitment (via the same exposure pathway) 20 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 fromthe 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 3.2.1]

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 VPAP-2103S I REVISION 9 PAGE 36 OF 71

b. Action

1. Analyses shall be performed at least semiannually as follows: I Program Cross-Check of Milk 1131, Gamma, Sr89 and Sr 9 ° Water Gross Beta, Gamma, I131, H3 (Tritium), Sr 89 and Sr 9 ° (blind-any combinations of above radionuclides)

Air Filter Gross Beta, Gamma, Sr 90

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

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

6.7 Reporting Requirements I 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 I environmental surveillance activities for the report period, including:

• A comparison (as appropriate) with preoperational studies, operational controls, I and previous environmental surveillance reports

• An assessment of the observed impacts of the plant operation on the environment 3

• Results of land use census per Step 6.6.2

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DOMINION VPAP-2103S REVISION 9 PAGE 37 OF 71

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 7).

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment 9) was not achievable.

DOMINION VPAP-2103S I REVISION 9 PAGE 38 OF 71 NOTE: NUREG-054'3 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."

6.7.2 Annual Radioactive Effluent Release Report 3

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 sections 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 3.2.2]

2. An assessment of radiation doses to the maximum exposed members of the 3 public due to the radioactive liquid and gaseous effluents released from the Station during the previous calendar year. This assessment shall be in 3 accordance with Step 6.7.2.b.

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

• Unplanned releases that exceeded the limits in Steps 6.2.1 and 6.3.1 3

• Unplanned releases which require a Condition Report and involve the*

discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid 3 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 3

- Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Condition Report I

I

DOMINION VPAP-2103S REVISION 9 PAGE 39 OF 71

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

5. Changes to VPAP-2103S, Offsite Dose Calculation Manual (Surry) (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 - Station

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.

2. The dose to the maximum exposed member of the public due to radioactive liquid and gaseous effluents from the Station and from the ISFSI 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.

3. Meteorologicalconditions 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 Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

1. Radioactive Effluent Release Report covering operation of the ISFSI during the previous 12 months of operation shall be submitted within 60 days after January 1.

2. The ISFSI Radioactive Effluent Release Report shall specify the quantities of each of the principal radionuclides released to the environment in liquid and in gaseous effluents.

DOMINION VPAP-2103S i REVISION 9 PAGE 40 OF 71

3. Dose Assessment - ISFSI ProvideI. such information as may be required by the Commission to estimate i potential radiation dose commitment to the public resulting from effluent releases from the ISFSI. i 6.7.3 Annual Meteorological Data

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

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

6.7.4 Changes to the ODCM i 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. i 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 I implemented.

d. Submitted to NRC in accordance with VPAP-2802, Notifications and Reports. n I

I

DOMINION VPAP-2103S REVISION 9 PAGE 41 OF 71 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 submitted to Records Management in accordance with VPAP-1701, Records Management. Prior to transmittal to Records Management, 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 VPAP-2103S REVISION 9 U

PAGE 42 OF 71 ATTACHMENT 1 (Page 1 of 1)

I Radioactive Liquid Effluent Monitoring Instrumentation I

Instrument Minimum Action

1. GROSS RADIOACTIVITY MONITORS PROVIDING ALARM Operable Channels I AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, I RM-RRM-131

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC U TERMINATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 1 2 I

Unit 2: 2-SW-RM-220 1 2 (b) Component Cooling Service Water Effluent Lines, I-SW-RM-107A 1 2 I

1-SW-RM- 107B 1-SW-RM- 107C.

1 1

2 2 I 1-SW-RM- 107D 1 2

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, I

ACTION 1:

Instrument Loop RLW- 153 1 If the number of operable channels is less than required, effluent releases via this I

ACTION 2:

pathway shall be suspended.

If the number of operable channels is less than required, effluent releases via this I

pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). When the effluent release via U

this pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, I

Radioactive Liquid Waste Sampling and Analysis.

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DOMINION VPAP-2103S REVISION 9 PAGE 43 OF 71 ATTACHMENT 2 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration Functional Test

1. GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, RM-RRM-131 D P R Q

2. GROSS BETA OR GAMMA RADIOACTIVI-TY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMI-NATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, 1-SW-RM- 107A 1-SW-RM- 107B 1-SW-RM- 107C D M R Q 1-SW-RM- 107D

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW- 153 DR N/A R N/A

DOMINION VPAP-2103S REVISION 9 N

PAGE 44 OF 71 ATTACHMENT 3 (Page 1 of 3)

Radioactive Liquid Waste Sampling and Analysis Program I

Liquid Release Type Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit Detection of (LLD)

(DtCioml) (Note 1) I P P Principle Gamma Emitters (Note 3) 5 x 10-7 I (Each Batch) p .Dissolved (Each Batch) 1131 and 1 x 10-6 I

Batch Releases (One Batch/M) M Entrained Gases (Gamma Emitters) 1 x 10-I (Note 2) P M Composite H3 1 x 10-5 (Each Batch) (Note 4) Gross Alpha 1 x 10-7 I

P Q Composite Sr 89 and Sr90 5 x 10-O I (Each Batch) (Note 4) Fe 55 1 x 10-6 Continuous W Composite Principal Gamma 5 x 10-7 I

Emitters (Note 6)

(Note 6) (Note 6) 0131 1 X 10-6 I Continuous M DissolvedGases and Contnuos Releases M

Grab Sample M Entrained (Gamma Emitters) 1 x 10-I (Note 5) Continuous M Composite H3 1 x 10-5 I

(Note 6) (Note 6) Gross Alpha 1 x 10-7 Continuous Q Composite Sr 89 and Sr 9 ° 5 x 10-8 I

(Note 6). (Note 6) Fe 55 1 x 10-6 I U

I I

DOMINION VPAP-2103S REVISION 9 PAGE 45 OF 71 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):

LLD,= 4.66 sb (871)

E

• V 9 2.22E+06 9 Y

• e-(4At)

Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection (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)

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)

S= 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 appropriate methods will be usedto obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 9 U

PAGE 46 OF 71 ATTACHMENT 3 (Page 3 of 3) I Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the U following radionuclides: Mn 5 4 , Fe5 9 , Co 5 8 , Co 60 , Zn6 5 , Mo 9 9, Cs13 4 , Cs 13 7 , Ce 14 1, and Ce 144 . 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. I 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 I 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 I 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, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release. I I

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DOMINION VPAP-2103S REVISION 9 PAGE 47 OF 71 ATTACHMENT 4 (Page 1 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Fre- Minimum Analysis Type of Activity Lower Limit of Type quency Frequency Analysis Detection (LLD)

(gtCi/ml), (Note 1)

A. Waste Gas Prior to Release Prior to Release Principal Gamma 1 X 10-4 Storag Tank Tank)

(EachSample)

(Grab (Each Tank) Emitters (Note 2)

Storage Prior to Release Prior to Release Principle Gamma I X 10-4 B. Containment Emitters (Note 2)

Purge (Each PURGE) (Each PURGE) H3 1 x 10-6 (Grab Sample)

C. Ventilation Weekly Weekly Principle Gamma I X 10-4 (1)Process Vent (Grab Sample) Emitters (Note 2)

(2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1 x 10-6 (4)SRF Vent I) Continuous Weekly (Note 5)

V131 1

I X 10-12 (Note 4) (Charcoal Sample) V133 1 x 10-10 Continuous Weekly (Note 5) Principal Gamma I x 10-11 All Release (Note 4) Particulate Sample Emitter (Note 2)

Continuous Weekly Types as listed Cotenu)sComposite Gross Alpha 1 x 10-11 (Note 4) Particulate Sample in A, B, and C Quarterly Continuous Composite Sr 89 and Sr 90 1 x 10-11.

(Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1 x 10-6 (Note 4) Beta and Gamma Weekly Weekly Principle Gamma I X 10-4 Condenser Air Emitters (Note 2) 1 Ejector Grab Sample (Note 3) H3 1 x 10-6.

(Note 3)

}?~Ti

DOMINION VPAP-2i03S REVISION 9 PAGE 48 OF 71 ATTACHMENT 4 (Page 2 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program

DOMINION VPAP-2103S REVISION 9 PAGE 49 OF 71 ATTACHMENT 4 (Page 3 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation):

LLD = (10-1)

EB V

• 2.22E+06

• Y

• e-(XAt)

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).

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).

= 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.

,::)

DOMINION VPAP-2103S REVISION 9 U

PAGE 50 OF 71 ATTACHMENT 4 (Page 4 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: Kr87, Kr88 , Xe1 3 3 , Xe13 3 m, Xe 13 5 , Xe13 5m, and Xe 1 3 8 for gaseous emissions and Mn 5 4 , Fe5 9 , Co 5 8 , Co 60 , Zn 6 5, Mo 9 9 , Cs 13 4, Cs 13 7, Ce 14 1 and Ce 14 4 for i particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, 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, when:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased more than a factor of 3; and.

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

I 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.

I NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 has increased by a factor of 3; and

b. Noble gas monitor shows that effluent activity has increased more than a factor of 3. I NOTE 6: To be representative of the quantities and concentrations of radioactive materials in gaseous effluents, composite sampling shall employ appropriate methods that will result in a I specimen representative of the effluent release.

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DOMINION VPAP-2103S REVISION 9 PAGE 51 OF 71 ATTACHMENT 5 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release:

I-GW-RM- 102, or 1 1-GW-RM- 130-1 (b) Iodine Sampler: (NOTE 1)

Continuous HP Sampler, or 2 1-GW-RM-130-1 (c) Particulate Sampler: (NOTE 1)

Continuous HP Sampler, or 1 2 1-GW-RM-130-1 (d) Process Vent Flow Rate Monitor:

1-GW-FT- 100 1 3 (e) Sampler Flow Rate Measuring Device:

HP Sampler Rotometer or KAMAN Flow Rate Measuring 1 3 Device (Parameter #19)

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor:

1-SV-RM- 111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device:

Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-1 B 1 3 Unit 2: 2-VP-FI-1A 1 3 2-VP-FI-lB 1 3

3. VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor:

SRF: RRM-101 1 1 SPS: Vent #1, 1-VG-RM-104 1 1 Vent #2, 1-VG-RM -110, or 1-VG-RM-131-1 (b) Iodine Sampler: (NOTE 1)

SRF: RRM-101 1 2 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP Sampler, or 1 2 1-VG-RM- 131-1

DOMINION VPAP-2103SI REVISION 9 PAGE 52 OF 71 ATTACHMENT 5 (Page 2 of 2)

I Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM I

INSTRUMENT OPERABLE CHANNELS ACTION I

(c) Particulate Sampler: (NOTE 1)

SRF: RRM-101 SPS: Vent #1, VG-RM-104 (NOTE 2) 1 1

2 2

I Vent #2, HP Continuous Sampler, or (d) 1-VG-RM-131-1 Ventilation Vent Flow Rate Monitor:

I SRF: 01-RHV-FT-156 1 3 SPS: Vent #1, 1-VS-FT- 119 Vent #2, 1-VS-FT- 116 1

1 3

3 I

(e) Sampler Flow Rate Measuring Device: (NOTE 1)

SRF: RRM-101 SPS: Vent#1, 1-VG-RM-104 (NOTE 2) 1 1

3 3

I Vent #2, KAMAN Flow Rate Measuring Device (Parameter #19), or HP Sampler Rotometer 1 3 I

NOTE 1): The mark numbers listed refer to the gaseous effluent radiation monitor with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

I NOTE 2): Vent# 1, 1-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take I

15 - 20 minutes. [Commitment 3.2.3]

ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue I

provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring I

Instrumentation Sampling Schedule" attachment in HP-3010.03 1, Radioactive Gaseous Waste Sampling ACTION 2:

and Analysis. [Commitment 3.2.4]

If the number of operable channels is less than required, effluent releases via this pathway may continue I

provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

U ACTION 3:

[Commitment 3.2.4]

If the number of operable channels is less than required, effluent releases via this pathway may continue I

provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

I I

DOMINION VPAP-2103S REVISION 9 PAGE 53 OF 71 ATTACHMENT 6 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION CHECK CHECK CALIBRATION FUNCTIONAL

_____TEST

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor -

Providing Alarm and Automatic Termination of Release I-GW-RM- 102 1-GW-RM-130-1 (b) Iodine Sampler Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A (c) Particulate Sampler Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A (d) Process Vent Flow Rate Monitor I-GW-FT-100 D N/A R N/A (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D N/A SA N/A KAMAN Flow Rate Measuring D N/A R N/A Device (Parameter #19)

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor Unit 1: 1-SV-RM-111 Unit 2: 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring Device Unit 1: 1-VP-FI-lA 1-VP-FI- 1B Unit 2: 2-VP-FI-1A D N/A R N/A 2-VP-FI-IB

3. VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor SRF: RRM-101 SPS: 1-VG-RM -110 I-VG-RM -131-1 1-VG-RM-104 iiii!

DOMINION VPAP-2103Si REVISION 9 PAGE 54 OF 71 I

ATTACHMENT 6 (Page.2 of 2)

I Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements I

CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION (b) Iodine Sampler CHECK CHECK CALIBRATION FUNCTIONAL TEST I SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP W N/A N/A N/A I

Sampler or 1-VG-RM- 131-1 (c) Particulate Sampler i

SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP W N/A N/A N/A I

Sampler or 1-VG-RM-13 1-1 (d) Ventilation Vent Flow Rate Monitor i

SRF:01-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 Vent #2, 1-VS-FT-1 16 I

(e) Sampler Flow Rate Measuring Device i

SRF: RRM-101 D N/A R N/A SPS: Vent #1, 1.-VG-RM-104 Vent #2, KAMAN Flow Rate D

D N/A N/A R

R N/A N/A I

Measuring Device (Parameter

1. 19), or HP Sampler Rotomete D N/A S/A N/A I

• Prior to each Waste Gas Decay Tank release NOTE: The mark numbers listed above in 1(b), 1(c), 3(b), 3(c), and 3(e) refer to the gaseous i

effluent radiation monitor with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the I

particulate radiation monitor.

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DOMINION VPAP-2103S REVISION 9 PAGE 55 OF 71 ATTACHMENT 7 (Page 1 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

1. DIRECT RADIATION About 40 Routine Monitor-ing Stations to be placed as follows:

1) Inner Ring in general area of site boundary GAMMA DOSE with station in each sector

2) Outer Ring 6 to 8 km from the site with a Quarterly Quarterly station in each sector

3) The balance of the 8

) dosimeters should be placed in special interest areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest adioiodine Canister calculated annual 1131 Analysis Weekly average ground level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 operation with Particulate Sampler km distance located in a sample collection Gross beta radioactivity concentric ring around weekly analysis following filter the Station change-c) 1 sample from a control Gamma isotopic analysis location 15-30 km of c o tosi (bc y distant, providing valid of composite (by

) background data location) quarterly

DOMINION VPAP-2103SI REVISION 9 PAGE 56 OF 71 ATTACHMENT 7 (Page 2 of 3)

I Radiological Environmental Monitoring Program I

Exposure Pathway and/or Sample Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis I

3. WATERBORNE a) Surface a) 1 sample upstream Monthly Sample Gamma mnhy monthly; isotopic analysis I b) 1 sample downstream Composite for tritium analysis quarterly Gamma isotopic and tritium I

b) Ground Sample from 1 or 2 sources Quarterly analysis quarterly c) Sediment from shoreline a) b)

1 sample upstream 1 sample downstream Semi-Annually Gamma isotopic analysis semi-annually I

a) b)

1 sample upstream 1 sample downstream Semi-A Gamma isotopic analysis semi-annually I

4. INGESTION a) Milk a) 2 samples from milking I

animals in the vicinity of the Station. (NOTE 1) b) 1 sample from milking animals at a control Monthly Gamma isotopic and 113" anal-ysis monthly I location (- 15-30 km distant). (NOTE 2) a) 2a)i2cs samplessofof oysters Saionin the other t Semi-Annually Gamma isotopic on edibles I

• vicinity of the Station b) Fish and b) 4 samples of clams in the vicinity of the Station Semi-Annually Gamma isotopic on edibles I Invertebrates c) 1 sampling of crabs from the vicinity of the Station Annually Gamma .isotopic on edibles I d) species fromofthe 1 sampling 2 different f

spea(cafiesh discharge whied chrge canal (catfish, white perch, Semi-Annually Gamma isotopic on edibles I

eel)

NOTE 1: If milk sampling cannot be performed, use item 4.c)d). Milk sampling cannot be performed I when there are no milk sampling locations in the vicinity of the Station.

NOTE 2: If milk sampling from a control location cannot be performed, use item 4.c)e). Milk I sampling cannot be performed when there is no milk sampling location 30 km distant. I I

DOMINION VPAP-2103S REVISION 9 PAGE 57 OF 71 ATTACHMENT 7 (Page 3 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued) a) 1 sample corn Gamma isotopic on edible b) 1 sample soybeans Annually portion c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if Gamma isotopic and 1131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 -

30 km distant in the available least prevalent wind direction, if milk sampling is not performed.

DOMINION VPAP-2103SI REVISION 9 PAGE 58 OF 71 3 ATTACHMENT 8 (Page 1 of 3)

I Environmental Sampling Locations U

SAMPLE LOCATION MEDIA Air Charcoal and Surry Station (SS)

DISTANCE (MILES) 0.3 DIRECTION NNE REMARKS I

Particulate Hog Island Reserve (HIR)

Bacons Castle (BC) 2.0 4.5 NNE SSW I

Alliance Colonial Parkway (ALL)

(CP) 5.1 3.8 WSW NNW I

BASF Fort Eustis (BASF)

(FE) 5.1 4.9 ENE ESE I Newport News (NN) 19.3 SE Control Location Environmental TLDs Control West North West (00)

(02) 0.2 WNW Onsite **

Site Boundary I

Surry Station Discharge (03) 0.4 NW Site Boundary I

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary I North North East (06) 0.3 NNE Site Boundary North East East North East (07)

(08) 0.3 0.4 NE ENE Site Boundary Site Boundary I

East West (09)

(10) 0.3 0.1 E

W Site Boundary Site Boundary I I West South West South West (11)

(12) 0.4 0.3 WSW SW Site Boundary Site Boundary I South South West (13). 0.3 SSW Site Boundary South (14) 0.4 S Site Boundary I South South East (15) 0.6 SSE Site Boundary South East Station Intake (16)

(18) 0.9 1.6 SE ESE Site Boundary Site Boundary I

[Hog Island Reserve (19) 2.0 NNE Near Resident I

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DOMINION VPAP-2103S REVISION 9 PAGE 59 OF 71 ATTACHMENT 8 (Page 2 of 3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (24) 4.0 W Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles o,-.*

Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 S Approx. 5 miles Milk Epp's 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 S Control Location

DOMINION VPAP-2103SI REVISION 9 PAGE 60 OF 71 ATTACHMENT 8 (Page 3 of 3)

I Environmental Sampling Locations I

SAMPLE MEDIA LOCATION DISTANCE (MILES)

DIRECTION REMARKS I

Well Water Surry Station Hog Island Reserve 2.0 NNE Onsite***

I Crops (Corn, Peanuts, Soybeans)

Slade's Farm Brock's Farm 3.2 3.8 S

S I

River Water (Monthly)

Surry Discharge Scotland Wharf 0.4 4.9 NW WNW Control Location I

Sediment (Silt)

Chickahominy River Surry Station Discharge 11.2 1.3 WNW NNW Control Location I

Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW I Hog Island Point 2.4 NE Oysters Lawne's Creek Point of Shoals 2.4 6.4 SE SSE I

Crabs Mulberry Point Surry Station Discharge 4.9 1.3 ESE NNW I

Fish Shoreline Surry Station Discharge Hog Island Reserve 1.3 0.6 NNW N I Sediment Chickahominy River 11.2 WNW Control Location I

• • Onsite Location - in Lead Shield Onsite sample of Well Water-taken from tap-water at Surry Environmental Building I I

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DOMINION VPAP-2103S REVISION 9 PAGE 61 OF 71 ATTACHMENT 9 (Page 1 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

Analysis Water Airborne Fish Milk Food Sediment (NOTE 2) (pCi/l) Particulate (pCi/kg) (pCi/I) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry)

(pCi/m 3 ) (wet)

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

7) Nb-95 1-131 15 (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 be 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-2103S REVISION 9 PAGE 62 OF 71 ATTACHMENT 9 (Page 2 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

NOTE 1: For a particular measurement system (which may include radiochemical separation):

4.66 sb B

E V

• 2.22E+06

• Y e-(At) (24-1)

Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.8)

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)

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)

= 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 VPAP-2103S REVISION 9 PAGE 63 OF 71 ATTACHMENT 10 (Page 1 of 1)

Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne Fish Milk Food Products (pCi/I) Particulate or (pCi/kg, wet) (pCi/l) (pCi/kg, wet) 3 Gases (pCi/m )

H-3 30,000 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 1-131 (NOTE 1) 2 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 NOTE 1: Reporting level for the ground (drinking) water samples required by Radiological Environmental Monitoring Program (Attachment 7). The reporting level for the surface (non-drinking) water samples required by Attachment 7 is 20 pCi/l.

DOMINION VPAP-2103S U REVISION 9 PAGE 64 OF 71 1 ATTACHMENT 11 (Page 1 of 8) I Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEORLOGICAL ANALYSIS I 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year 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 five year average X/Q and D/Q values are used in the dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public.

1.2 Meteorological Data, Parameters, and Methodology.

A five (5) year average.of representative onsite meteorological data for the period January 1, 1992 through December 31, 1996, is used in the gaseous effluent dose pathway calculations.

This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases, characterized as ground level (i.e.,

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/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ -

Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The code is based upon a straight line airflow model implementing the assumptions outlined in Section C (excluding Cla and Clb) of Regulatory Guide 1.111, "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 X/Q values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation .vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 3 in. with plume exit velocity of 100 ft/sec.

U

• DOMINION VPAP-2103S REVISION 9 PAGE 65 OF 71 ATTACHMENT 11 (Page 2 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis I 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 Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table 1 1A-8.

XIQ and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for process vent and ventilation vent releases.

3 According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous 3 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.

• ) 1.3 Results The X/Q value that would result in the maximum total body, skin, and inhalation exposure for ventilation vent releases was 6.OE-05 sec/m 3 at a site boundary location 532 meters NNE sector. For process vent releases, the site boundary X/Q value was 3.7E-07 sec/m 3 at a location 565 meters WSW sector. The discharge canal bank X/Q value that would result in the 3 maximum inhalation exposure for ventilation vent releases was 1.6E-04 sec/r 3 at a location 290 meters NW sector. The discharge canal bank XIQ value for process vent UI was 6.9E-07 sec/m 3 at a location 290 meters NW sector.

DOMINION VPAP-2103S REVISION 9 PAGE 66 OF 71 ATTACHMENT 11 (Page 3 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The grass-cow-milk pathway analysis, which is performed to derive the maximum exposure from 1131, 1133, and from all radionuclides in particulate form with.half-lives greater than eight days, is based on the dairy location indicated by the 1996 Land Use Census. The D/Q value n from ventilation vent releases that would result in the maximum exposure was 2.5E-10 per m2 at a location 5873 meters NNW sector. For process vent releases, the D/Q value was 1.4E-10 3 per m2 at a location 7788 meters SSW sector. For tritium, the X/Q value from ventilation vent releases that would result in the maximum exposure for the grass-cow-milk pathway was 1.5E-06 sec/m 3 at a locations 5873 meters NNW sector, and 7.OE-08 sec/m 3 for process vent releases at a location 7788meters SSW sector. The inhalation pathway is the only other pathway existing at this location. Therefore, the X/Q values given for tritium also apply for the inhalation pathway.

2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose. 1 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 3 included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents.

2.2 Data, Parameters, and Methodology 3 Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station 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.

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DOMINION VPAP-2103S REVISION 9 PAGE 67 OF 71 ATTACHMENT 11 (Page 4 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year.

For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e. a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose

.) factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Canberra Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal.

2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs.

Validation of the limiting age group and critical organ is performed by Canberra's liquid effluent dose calculation program using the data, parameters, and methodology provided in the Canberra Source Code file.

DOMINION VPAP-2103S I REVISION 9 PAGE 68 OF 71 ATTACHMENT 11 (Page 5 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS U 3.1 Purpose Gaseous effluent pathway analyses are 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 analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of 1131, 1133, tritium, and for all radionuclides in particulate form with half-lives greater than eight days I for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from 1131, 1133, tritium, and particulates to demonstrate compliance with Step 6.3.1.a.

3.2 Data, Parameters, and Methodology Five year 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 accessible to 3

the public inside site boundary. The largest V/Q value was determined to be 6.OE-05 sec/rn at site boundary for ventilation vent releases at a location 532 meters NNE direction, and 3.7E-07 sec/m 3 at site boundary for process vent releases at a location 565 meters WSW 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.

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. I I

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DOMINION VPAP-2103S REVISION 9 PAGE 69 OF 71 ATTACHMENT 11 (Page 6 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The maximum exposed individual for 10CFR50 Appendix I compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable garden, using the 1996 Land Use Census data. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses.

The gamma and beta dose factors Kivv, LiVv, Mivv, and Nivv for ground level releases and the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode releases are included in the Canberra Source Code file.

Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation:

Pi mrem/yr per Ci/m 3 = K' (BR) DFAi (28-1) where:

K' = a constant of unit conversion, 1E+12 pCi/Ci BR = the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev. 1 DFAi=the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mremrpCi Parameters used above were obtained from NUREG-0133, R.G. 1.109, Rev. 1, and LADTAP II, NUREG/CR-1276 It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year. The maximum five year average X/Q at this location was determined to be 1.6E-04 sec/m 3 at 290 meters NW direction..

Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis.

DOMINION VPAP-2103S I REVISION 9 PAGE 70 OF 71 3 ATTACHMENT 11 (Page 7 of 8) I Meteorological, Liquid, and Gaseous Pathway Analysis The RMivv and RMipv dose factors, except for tritium, are calculated using the following B equation:

• RMi KQFa )f (r)____I f (I fpfs)e-it

= K F (r) (DFLi) p+s + (28-2)

" A + 'w ' [p Ys where:

K' = a constant of unit conversion, 1E+12 pCi/Ci I QF = cow's consumption rate, 50, in Kg/day (wet weight)

Uap= infant milk consumption rate, 330, liters/yr I Yp = agricultural productivity by unit area of pasture feed grass, 0.7 Kg/m2 Ys = agricultural productivity by unit area of stored feed, 2.0, in Kg/m2 Fm = stable element transfer coefficients r = fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 I for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, in mrem/pCi 1

Xi = decay constant for the ith radionuclide, in sec- 1 3

,w = 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) 3 tf = transport time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th = transport time from pasture, to harvest, to cow, to milk, to receptor, 7.78E+06, in seconds 3 fp = fraction of year that cow is on pasture, 0.67 (dimensionless), 7.78E+06 in seconds fs = fraction of cow feed that is pasture grass while cow is on pasture, 1.0, dimensionless Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev. 1, and LADTAP II, NUREG/CR-1276. 3 I

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DOMINION VPAP-2103S REVISION 9 PAGE 71 OF 71 ATTACHMENT 11 (Page 8 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation'is used:

R H3 = K' K'FmQFUap(DFLH3) [0.75(0.5/H)] (28-3) where:

K '"=a constant of unit conversion 1E+03 gm/kg 3

H = absolute humidity of the atmosphere, 8.0, gm/r 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.

) The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation:

RI mrem/yr per Ci/m 3 = K' (BR) DFAi (28-4) where:

K'=a constant of unit conversion, 1E+12 pCi/Ci BR=breathing rate of the particular age group, m3 /yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0133, R. G. 1.109, Rev. 1 and LAPTAP II, NUREG/CR- 1276.

Administrative ProceduresAction Reque, I ,Dflominiof s (A-PAR)

IVPAP-0502 -Attachment 21 Page 1 of '

5PSdMouedBure tste Dose Titl)Caculation Manual (Surry)

7. Type of Request

[ ]New Procedure [x] Procedure Revision [ ] Procedure Deletion [ ] Emergency Change

8. Brief description of the modification See Revision Summary of affected procedure

9. Location [x] SPS [] NAPS ][CORP Location [] SPS [ NAPS [ ] CORP

10. Requested by (Printed Name) 11. Date 12. Phone 13. Requested by (Printed Name) 14. Date 15. Phone P. Blount 10/26/06 2467 N/A N/A N/A T-

• I.,

• a* -* -

• A. - -

• I

16. Does procedure meet requirements of NOTE below? [x] Yes []No

17. Does this procedure require a 50.59 / 72.48 Evaluation (Form No. 730947)? [ ] Yes. [X) No

18. Are there any new sections or steps designated North Anna or Surry? [] Yes [XJ No

19. Is the reason for the station-specific instructions due to differences in regulatory requirements? [ ] Yes [] No [x] N/A

20. Is the reason for the station-specific instructions due to differences in construction? [ Yes [ ] No [X] N/A

21. Is the reason for the station-specific instructions due to station preferences? [ ]Yes I No [xI N/A If all answers are No or N/A, approval is required by PPOs as identified on the Procedure Cover Page. Check block 30.

If block 16 or 17 is Yes, approval is required by PPOs, SNSOCs, and/or Site Vice Presidents. Check blocks 30, 31, and 32, as appropriatE NOTE: VPAP-2101 and VPAP-2201 require SNSOCs approval.

SPIPs, VPAP-2103N, VPAP-2103S, VPAP-2104, and VPAP-2401 require SNSOC(s) and Site Vice President(s) approval.

If block 18, 19, or 20 is Yes with block 21 No, approval is required by PPOs and Site Vice Presidents. Check blocks 30 and 32.

If block 21 is Yes, approval is required by PPOs, Site Vice Presidents, and Vice President Corporate. Check blocks 30, 32, and 33.

22. Did this procedure require the attachments in DNAP-0112, Dominion Nuclear Change Management Process, to be used? [ ]Yes [x] No

23. Location [X] SPS [ NAPS [ ] CORP Location [ SPS ]NAPS [] CORP

24. PPO (Printed Name) 25. Date 126. Phone 27. PPO (Printed Name) 28. Date 29. Phone L. B. Jones 10/26/06 2010 N/A N/A N/A Reqir Apr. Autorty- D F A b

[x] 30. PPO(s) [x] 31. SNSOCs [x] 32. Site Vice Presidents [133. Vice President (Corp)

34. P ature 35. Date 36. PPO (Signature) N/A 37 Date SNSO C a I re) 39 Date 40. SNSOC Chairman (Signatur 41. Date

/ 42.,.Sý Vr____a_

e.PreýiclqntQ(Signatuý re, L 43. Dotf/ 44. Site Vice President (Signature) 45. Date ZI r, 1 0/ )/,gJ)A

- i I

46. Vice President Corporate (Si nature) 47. Date f Power Station; rocess/Pr.ogram Owner(s);

IPs-Security Plan Implementing Procedures Form No. 720457(Sep 200

Station Dominion Administrative Procedure

Title:

Offsite Dose Calculation Manual (Surry)

Process / Program Owner: Manager Radiological Protection and Chemistry (Surry)

Procedure Number Revision Number Effective Date VPAP-2103S 10 On File Revision Summary The following changes were made to reflect the implementation of MGPI (38-DCP-01-022, IPR 06-0402, Ventilation Radiation Monitoring (KAMAN) System Replacement):

" Added 3.1.25 - Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2.

" Revised 4.15, Source Check definition.

• Revised 6.3.2.c, Applicable Monitors - changed "1-GW-RM-130-1" to "1-GW-RM-130B";

changed "1-VG-RM-131-1" to "1-VG-RM-131B."

" Revised Attachment 5, Radioactive Gaseous Effluent Monitoring Instrumentation, to update the following:

• Process Vent System.

• Ventilation Vent System.

• NOTE 1 as follows:

OLD - "The mark numbers listed refer to the gaseous effluent radiation monitor with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor."

NEW - "The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components."

• Revised Attachment 6, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements, as follows:

• Updated Process Vent System.

• Updated Ventilation Vent System.

• Added NOTE 2 - "A source check is required for 1-GW-RM-102 prior to each Waste Gas Decay Tank release.". (former "NOTE" became "NOTE 1" and references were placed in applicable sections of table).

Approvals on File

DOMINION VPAP-2103S REVISION 10 PAGE 2 OF 71 TABLE OF CONTENTS U Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 3 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 1 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effluents 11 6.2.1 Liquid Effluent Concentration Limitations 11 6.2.2 Liquid Monitoring Instrumentation 12 6.2.3 Liquid Effluent Dose Limit 15 6.2.4 Liquid Radwaste Treatment 18 6.2.5 Liquid Sampling 19 6.3 Gaseous Radioactive Waste Effluents 19 1 6.3.1 Gaseous Effluent Dose Rate Limitations 19 6.3.2 Gaseous Monitoring Instrumentation 21 5 6.3.3 Noble Gas Effluent Air Dose Limit 24 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 26 6.3.5 Gaseous Radwaste Treatment 28 6.4 Radioactive Liquid and Gaseous Release Permits 29 1 6.4.1 Liquid Waste Batch Releases 29 6.4.2 Continuous Liquid Releases 29 3 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 30 6.4.4 Reactor Containment Release Permits 30 1 6.4.5 Miscellaneous Gaseous Release Permit 30 I

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DOMINION VPAP-2103S REVISION 10 PAGE 3 OF 71 TABLE OF CONTENTS (continued)

Section Page 6.4.6 Radioactive Liquid and Gaseous Release Controls 30 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 32 6.6 Radiological Environmental Monitoring 32 6.6.1 Monitoring Program 32 6.6.2 Land Use Census 34 6.6.3 Interlaboratory Comparison Program 35 6.7 Reporting Requirements 36 6.7.1 Annual Radiological Environmental Operating Report 36 6.7.2 Annual Radioactive Effluent Release Report 38 6.7.3 Annual Meteorological Data 40 6.7.4 Changes to the ODCM 40 7.0 RECORDS 41 ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 42 2 Radioactive Liquid Effluent Monitoring Instrumentation 43 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 44 4 Radioactive Gaseous Waste Sampling and Analysis Program 47 5 Radioactive Gaseous Effluent Monitoring Instrumentation 51 6 Radioactive Gaseous Effluent Monitoring Instrumentation 53 Surveillance Requirements 7 Radiological Environmental Monitoring Program 55 8 Environmental Sampling Locations 58 9 Detection Capabilities for Environmental Sample Analysis 61 10 Reporting Levels for Radioactivity Concentrations in Environmental 63 Samples 11 Meteorological, Liquid, and Gaseous Pathway Analysis 64

DOMINION VPAP-2103S REVISION 10 PAGE 4 OF 71 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual I Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to 3 radioactive liquid and gaseous effluents are performed to assure that:

" Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten I 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 gCi/ml for dissolved 3 or entrained noble gases.

• Exposure to the maximum exposed member of the public in the unrestricted area from 3 radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CFR 50, Appendix I 3

• 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 1131, 1133, and H 3 , 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 3

" Exposure to a real individual will not exceed 40 CFR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at Surry Power Station.

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DOMINION VPAP-2103S REVISION 10 PAGE 5 OF 71

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 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982

.3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 10 PAGE 6 OF 71 3.1.19 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 3.1.20 Surry UFSAR 3.1.21 Laboratory Quality Assurance Plan, Manual 100; Framatome Environmental Laboratory 3.1.22 VPAP-2802, Notifications and Reports i

3.1.23 3.1.24 HP-3010.021, HP-3010.031, Radioactive Radioactive Liquid GaseousWaste WasteSampling Samplingand andAnalysis Analysis 3.1.25 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System I i Replacement/Surry/Unit 1&2 I 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report  !

3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability i Sampling 4.0 DEFINITIONS i 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds with the necessary range and j

.accuracy to known values of the parameter the channel monitors. It.encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated.

4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This 3 assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring i the same parameter.

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DOMINION VPAP-2103S REVISION 10 PAGE 7 OF 71 4.3 Channel Functional Test There are two.types of Channel Functional Tests.

4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions.

4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions.

4.4 Critical Organ That 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.

4.5 Dose Equivalent 1-131 That concentration of 1131 (gCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1131, 1132, 1133, 1134, and I3 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-2103S REVISION 10 PAGE 8 OF 71 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent.

NOTATION FREQUENCY N D - Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W - Weekly At least once per 7 days M - 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 7 Refueling At least once per 18 months S/U - Start-up Prior to each reactor start-up P - 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 and waste gas surge tanks.

4.8 General Nomenclature X = 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 Lower Limit of Detection (LLD)

The 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.

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DOMINION VPAP-2103S REVISION 10 PAGE 9 OF 71 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with the Station. This category includes non-employees of Dominion who are permitted to use portions

• ofthe 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 materials.

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 to purify the confinement.

4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2546 Megawatts Thermal MWt).

4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land.

4.15 Source Check For Victoreen and Eberline monitors a source check is the qualitative assessment of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, LED.

For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electronics.

DOMINION VPAP-2103S m REVISION 10 PAGE 10 OF 71 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.

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 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 High 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 The Manager Radiological Protection and Chemistry is responsible for:

5.1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring i radioactive effluents and the environment.

5.1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, 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.

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DOMINION VPAP-2103S REVISION 10 PAGE 11 OF 71 6.0 INSTRUCTIONS NOTE: Meteorological, liquid; and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 11).

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-2103S I REVISION 10 PAGE 12 OF 71 3

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>

,Ci/mli 1 (1) I Volume of Waste Discharged x .,ACWi I 1

where: I pgCi/mli = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as giCi/ml from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 gCi/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 3 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 I

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DOMINION VPAP-2103S REVISION 10 PAGE 13 OF 71

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 Functional 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, 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 aie:

Release Point Instrument Number Service Water System Effluent Line 1-SW-RM-107 A, B,C,D Condenser Circulating Water Line 1-SW-RM-120 2-SW-RM-220 Radwaste Facility Effluent Line 1-RM-RRM-131

DOMINION VPAP-2103S I REVISION 10 PAGE 14 OF 71

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

1. Maximum setpoint values shall be calculated by: I CFD S -. D (2)

FE where:

S = the setpoint, in gCi/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/mi FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as:

D = FE + (200,000 gpm x number of circ. pumps in service)

2. Each of the condenser circulating water channels (e.g., SW-120, SW-220) monitors the effluent (service water, including component cooling service 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 service water system effluent line (iLe., SW-107 A, B, C, D), and the Radwaste Facility effluent line (i.e., RRM-131).

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DOMINION VPAP-2103S REVISION 10 PAGE 15 OF 71

4. For the service water system effluent line, Equation (2) becomes:

S FE-CFDKSW FE (4) 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

5. For the Radwaste Facility effluent line, Equation (2) becomes:

S CFDKRW (5)

FE where:

KRw = The fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

6. The sum Ksw + KRW 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 public 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-2103S I REVISION 10 1*'D*Ig"Y '"71 I

b. Action If the calculated dose from release of radioactive materials in liquid effluents I

exceeds any of the above limits, prepare and submit to the NRC, within 30 days, special report in accordance with VPAP-2802, Notifications and Reports, that I

identifies causes for exceeding limits and defines corrective actions taken to reduce releases of radioactive materials in liquid effluents to ensure that subsequent I releases will be in compliance with the above limits.

c. Dose Contribution Calculations I

NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

I Dose contributions shall be calculated for all radionuclides identified in liquid I

effluents released to unrestricted areas based on the equation:

I D = tFM ZA~ (6)

I where:

Subscripts = i, refers to individual radionuclide I

D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem I

t = the period for which Ci and F are averaged for all liquid releases, in hours I M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix 11A, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent I

release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas I Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in pCi/ml I I

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DOMINION VPAP-2103S REVISION 10 PAGE 17 OF 71 Ai= the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem-ml per hr-RCi. Values for Ai are provided in the Canberra Source Code file.

Ai = 1.14 E+05 (21BFi + 5BI) DFi (7) for example:

1.14 E+05 = 1 E+06 pCi/pCi x 1 E+03 ml/kg/(8760 hr/yr), units conversion factor

.21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 BIi = the bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/I BFi = the bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/l DFi = the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II, NUREG/CR-1276, and TID-4500, VCRL-50564, Rev. 1.

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.

TT*

DOMIN ION T

VPAP-2103S I REVISION 10 PAGE 18 OF 71 I 6.2.4 Liquid Radwaste Treatment Historical data pertaining to the volumes and radioactivity of liquid effluents released I

in connection with specific station functions, such as maintenance or refueling outages, shall be used in projections as appropriate.

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a. Requirement I

1. The Surry Radwaste Facility Liquid Waste 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 I

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.

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b. Action I 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 I

following: I

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.

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body and Critical Organ Dose Calculation I

1. Determine DI, the sum of all liquid open and closed release points, in mrem, by the ith organ, for the quarter.

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2. Determine P, the Projection Factor, which, is result of 31 divided by the number of days from start of the quarter to the end of the release.

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3. Determine Da, additional anticipated dose for liquid releases by the ith organ for the particular quarter of the release.

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4. Determine Dp, the 31 day projected dose by the ith organ: I Dp = (DI x P) + Da I

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DOMINION VPAP-2103S REVISION 10 PAGE 19 OF 71 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 Limitations

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.

.2. The dose rate limit for 1131, 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 1131, 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-2103Si REVISION 10 PAGE 20 OF 71

c. Calculations of Gaseous Effluent Dose Rates NOTE: The dose factors used in the Gaseous Effluent Dose Rate calculations are included in I

the Canberra Source Code file. These dose factors, Ki, Li, Mi, and Pi for ventilation I vent and process vent releases, DO NOT include the applicable X/Q value. Equations (8), (9), and (10) must be multiplied by the appropriate X/Q value for Gaseous Effluent Dose Rate calculations.

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1. The dose rate limit for noble gases shall be determined to be within the limit by I

limiting the release rate to the lesser of:

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KivvQivv + KipvQipv] mrern/yr m00 to the total body (8)

I OR I

i ivv + LIM.1 V) + (Lipv + I 1Mipv)Qipv] *3000 mrem/yr to the skin (9)

I where-Subscripts = vv, refers to vent releases from the building ventilation vent, U including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide I

Kivv, Kipv = 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 I

Livv, Lipv = 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 I

Mivv, Mipv = 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 I

1ivv, 1.1 1pv = The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per sit6) I

= The unit conversion factor that converts air dose to skin dose, in mrem/mrad I

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DOMINION VPAP-2103S REVISION 10 PAGE 21 OF 71

2. The dose rate limit for 1131, 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 therelease rate to:

zPivvQivv + Pipv *ipv

<1500 1 mrem/yr to the critical organ (10) where:

Pivv, Pipv = The critical or an dose factor for ventilation vents or process vent for 1131, IM , H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec ivv, Qipv = The release rate for ventilation vents or process vent of 1131, 1133, 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 5) 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 Functional Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 6).

DOMINION VPAP-2103S REVISION 10 I

PAGE 22 OF 71 I

b. Action

1. If a radioactive gaseous effluent monitoring instrumentation channel alarm/trip I

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 I

channel and declare the channel inoperable or I

• Change the setpoint so it is acceptably conservative

2. If the number of operable channels is less than the minimum required by tables I

in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5),

take the action shown in those tables.

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3. Return instruments to operable status within 30 days. If unsuccessful, explain in the next Annual Radioactive Effluent Release Report why the inoperability was I

not corrected in a timely manner.

c. Applicable Monitors I

Radioactive gaseous effluent monitors for which alarm/trip setpoints shall be determined are: I Release Point Process Vent Instrument Number 1-GW-RM-102 I 1-GW-RM-130B Condenser Air Ejector I-SV-RM-111 2-SV-RM-211 I

Ventilation Vent No. 1 Ventilation Vent No. 2 I-VG-RM-104 I-VG-RM-110 i

1-VG-RM-131B I Radwaste Facility Vent RRM- 101 I I

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DOMINION VPAP-2103S REVISION 10 PAGE 23 OF 71

d. Setpoint Calculations

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

D>D pv + Dcae +Dvv (11) 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 nroble 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 the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

2. Setpoint values shall be determined by:

Rm x Cm 2.12 E-03 (12) m Fnm where:

m = The release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv)

Cm = The effluent concentration limit implementing Step 6.3.1.a.

for the Station, ýtCi/ml Rm = The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe 133 as nuclide to be released, jiCi/sec 2.12E-03 = CFM per ml/sec Fm = The maximum flow rate for pathway m, CFM 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.

DOMINION VPAP-2103S I REVISION 10 PAGE 24 OF 71 6.3.3 Noble Gas Effluent Air Dose Limit NOTE: The dose factors used in the Noble Gas air dose calculations are included in the Canberra Source Code file. These dose factors, Mi and Ni for ventilation vent and process vent releases, DO NOT include the applicable X/Q value. Equations (13) and (14) must be multiplied by the appropriate X/Q value for gamma and beta air dose 3 calculations.

a. Requirement 3

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: 3

• During any calendar quarter: -5 mrads for gamma radiation and *10 mrads for beta radiation 3

• During any calendar year: <*0 mrads for gamma radiation and 520 mrads for beta radiation 3

2. Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with Step 6.3.3.c.

at least once per 31 days.

b. Action 3 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 I 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.

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-DOMINION VPAP-2103S REVISION 10 PAGE 25 OF 71

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-08NMivvQivv + MipvQipv]

'&-d*),

ýIJ) i For beta radiation:

Db = 3.17E-0O8NivvQivv + NipvQipv] (14) i Where:

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and 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 mradlyr per Curie/sec 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 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 VPAP-2103S REVISION 10 PAGE 26 OF 71 6.3.4 1-131, 133, 11-3 & 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 I with half-lives greater than 8 days, in gaseous effluents released from the site to unrestricted areas from each reactor unit shall be: 3

- 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, 133, 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 3 in accordance with Step 6.3.4.c.

b. Action*3 If the calculated dose from the release of 1131, 1133, tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds 3 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: 3

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases. 3

3. Proposed corrective actions to be taken to assure that subsequent releases will I

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DOMINION VPAP-2103S REVISION 10 PAGE 27 OF 71

c. Dose Calculations NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

NOTE: The RMi and RIi dose factors DO NOT include the applicable D/Q and X/Q values respectively for Surry Power Station. Equation (15) must be multiplied by the applicable D/Q or X/Q, as appropriate, to calculate the critical organ dose.

Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination ofQiv . 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 1131, 1133, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

Dr -3.17E-08=RMivvQivv + RMipv~ipv) + (RlivvQivv + Rlipv.ipv)] (15) i For example:

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors; 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 cow-milk pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per pCi/m 3 . Factors are included in the Canberra Source Code file.

DOMINION VPAP-2103S i REVISION 10 PAGE 28 OF 71 Rlivv,'RIipv = the inhalation pathway dose factor for ventilation vents or process vent release due to 1131, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per tCi/m 3 . Factors are included in the Canberra Source Code file.

Qvv.Qipv = the release for ventilation vents or process vent of 1131, 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 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseousi effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

1. Appropriate portions of the Gaseous Radwaste Treatment System shall be used to reduce radioactive materials in gaseous waste before its discharge, when the 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 I 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 I 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.

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DOMINION VPAP-2103S REVISION 10 PAGE 29 OF 71

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

1. Determine Dg, the sum of all gaseous open and closed release points, in mrem, by the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for gaseous releases by the ith organ for the particular quarter of the release.

4. Determine Dp, the 31 day projected dose by the ith organ.

Dp = (Dg x P)+ Da 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. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis.

6.4.1 Liquid Waste Batch Releases

a. Operations shall obtain RP authorization before initiating batch releases of radioactive liquids.

b. Release of contents from the following tanks/sumps other than transfers to the Radwaste Facility shall have a release permit before the discharge. Examples of batch releases include:

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode

• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage

• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases

a. Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids.

DOMINION VPAP-2103S I REVISION 10 PAGE 30 OF 71

b. Examples of continuous releases include:

• Steam generator blowdown

• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable

• Turbine building sumps and subsurface drains when pumps are in automatic mode or storm drains I 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 from start of purge/hog until:

• Routine termination

• Terminated for cause by RP

• Receipt of Radiation Monitoring System (RMS) Containment Gas Monitor high I alarm 6.4.5 Miscellaneous Gaseous Release Permit I 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.

6.4.6 Radioactive Liquid and Gaseous Release Controls I

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. I

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

time of sample) for samples obtained outside the Primary Sample Room.

• 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. 3

DOMINION VPAP-2103S REVISION 10 PAGE 31 OF 71

c. RP shall perform required sample analyses.

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

- Maximum authorized release rate

• 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 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-2103S I REVISION 10 PAGE 32 OF 71 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 I 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 I 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 releases*

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 3 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 3 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. 3 6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program 3

a. Requirement

1. The Radiological Environmental Monitoring Program shall be conducted as specified in Radiological Environmental Monitoring Program (Attachment 7).

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DOMINION VPAP-2103S REVISION 10 PAGE 33 OF 71

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 8).

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 7) requirements

• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 9)

• 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 Specification (Surry Technical Specification 6.6.B.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 10), 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 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 10) are detected in the sampling medium, the report shall be submitted if:

concentration (1) + concentration (2) + ... _ 1.0 (16) reporting level (1) reporting level (2)

DOMINION VPAP-2103S REVISION 10 U

PAGE 34 OF 71

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10) 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 required 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 VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 7), 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 I VPAP-2802, Notifications and Reports.

6.6.2 Land Use Census I

a. Requirement A land use census shall be conducted and shall identify, within a distance of 8 km 5 (5 miles), the location in each of the 16 meteorological sectors of the following:

- Nearest milk animal

" Nearest residence

• Nearest garden greater than 50 m 2 (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., I door-to-door survey, aerial survey, local agriculture authorities). Land use census results shall be included in the Annual Radiological Environmental 5 Operating Report in accordance with VPAP-2802, Notifications and Reports.

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DOMINION VPAP-2103S REVISION 10 PAGE 35 OF 71

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 7) shall be followed, including analysis of control samples.

b. Action

1. If a land use census identifies locations that yield a calculated dose or dose commitment greater than the values currently being calculated in Step 6.3.4.a.,

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 dose commitment (via the same exposure pathway) 20 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 3.2.1]

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 VPAP-2103S REVISION 10 U

PAGE 36 OF 71

b. Action

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

Program Cross-Check of Milk 1131, Gamma, Sr89 and Sr 9 ° Water Gross Beta, Gamma, 1131, H3 (Tritium), Sr 8 9 i and Sr9 ° (blind-any combinations of above radionuclides)

Air Filter Gross Beta, Gamma, Sr 9 °

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 VPAP-2802, Notifications and Reports, the corrective actions taken to prevent recurrence.

c. Results Results shall be reported in the Annual Radiological Environmental Monitoring 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 I

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DOMINION VPAP-2103S REVISION 10 PAGE 37 OF 71

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 7).

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment 9) was not achievable.

DOMINION VPAP-2103S REVISION 10 PAGE 38 OF 71 NOTE: NUREG-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."

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 sections 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 3.2.2]

2. An assessment of radiation doses to the maximum exposed members of 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, I during the reporting period, which meet the following criteria:

• Unplanned releases that exceeded the limits in Steps 6.2.1 and 6.3.1 I

• Unplanned releases which require a Condition Report 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 Condition Report I

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DOMINION VPAP-2103S REVISION 10 PAGE 39 OF 71

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

5. Changes to VPAP-2103S, Offsite Dose Calculation Manual (Surry) (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 - Station

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.

2. The dose to the maximum exposed member of the public due to radioactive liquid and gaseous effluents from the Station and from the ISFSI 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.

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 Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

1. Radioactive Effluent Release Report covering operation of the ISFSI during the previous 12 months of operation shall be submitted within 60 days after January 1.

2. The ISFSI Radioactive Effluent Release Report shall specify the quantities of each of the principal radionuclides released to the environment in liquid and in gaseous effluents.

DOMINION VPAP-2103S I

REVISION 10 PAGE 40 OF 71

3. Dose Assessment - ISFSI Provide such information as may be required by the Commission to estimate potential radiation dose commitment to the public resulting from effluent releases from the ISFSI.

6.7.3 Annual Meteorological Data I

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.

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 I evaluations justifying changes.

2. A determination that a change will not adversely impact the accuracy or I 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 NRC in accordance with VPAP-2802, Notifications and Reports.

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DOMINION VPAP-2103S REVISION 10 PAGE 41 OF 71 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 submitted to Records Management in accordance with VPAP-1701, Records Management. Prior to transmittal to Records Management, 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 VPAP-2103S REVISION 10 I

PAGE 42 OF 71 I

ATTACHMENT 1 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation I

I Instrument Minimum Action Operable Channels I

1. GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, I RM-RRM-131

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC I

TERMINATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 1 2 I

Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, 1 2 I

1-SW-RM- 107A 1 2 1-SW-RM- 107B 1-SW-RM- 107C 1

1 2

2 I

3.

1-SW-RM- 107D FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, 1 2 I

Instrument Loop RLW- 153 I

ACTION 1: If the number of operable channels is less than required, effluent releases via this ACTION 2:

pathway shall be suspended.

If the number of operable channels is less than required, effluent releases via this I

pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid I Waste Sampling and Analysis Program (Attachment 3). When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, I

Radioactive Liquid Waste Sampling and Analysis.

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DOMINION VPAP-2103S REVISION 10 PAGE 43 OF 71 ATTACHMENT 2 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration Functional Test

1. GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, RM-RRM-131 D P R Q

2. GROSS BETA OR GAMMA RADIOACTIVI-TY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMI-NATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 D M R Q Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, I-SW-RM- 107A 1-SW-RM- 107B D M R Q 1-SW-RM- 107C 1-SW-RM- 107D

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW- 153 DR N/A R N/A

DOMINION VPAP-2103S I

REVISION 10 PAGE 44 OF 71 I

ATTACHMENT 3 (Page 1 of 3)

I Radioactive Liquid Waste Sampling and Analysis Program I

Liquid Release Sampling Minimum Analysis Type of Activity DLower on Limit Detection LLD)of (LLD)

I Type Frequency Frequency Analysis (jCi/mi), (Note 1) p P Principle* Gamma 5 x 10-7 I

Emitters (Note 3)

(Each Batch) (Each Batch) 1131 1x 10-6 I Batch Releases P (One Batch/M)

M Dissolved and Entrained Gases (Gamma Emitters) 1 x 105 I (Note 2) P M Composite H3 1 x 10-5 I

(Each Batch) (Note 4) Gross Alpha 1 x 10-7 P Q Composite Sr 89 and Sr 90 5 x 10-8 I

(Each Batch) (Note 4) Fe 55 1 x 10-6 I Continuous W Composite Principal Gamma 5 x 10-7 (Note 6) (Note 6)

Emitters (Note 6) 1131 1 x 10-6 I

Continuous Contnuos M M M DissolvedGases Entrained and 1 x 10. I SReleases. Grab Sample (Gamma Emitters)

(Note 5) Continuous M Composite H3 1 x i0o- I (Note 6) (Note 6) Gross Alpha 1 x 10-7 I

Continuous Q Composite Sr 89 and Sr 90 5 x 10-8 (Note 6) (Note 6) Fe55 1 x 10-6 I

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DOMINION VPAP-2103S REVISION 10 PAGE 45 OF 71 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= b E

• V

• 2.22E+06

• Y

• e-('8At)

Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection (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)

E = the counting efficiency (as counts per disintegration)

V = the sample size (in units of mass or volume) 2.22E+06 = thenumber of disintegrations per minute (dpm) per microcurie Y the fractional radiochemical yield (when applicable)

= 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 appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S I

REVISION 10 PAGE 46 OF 71 ATTACHMENT 3 (Page 3 of 3)

Radioactive Liquid Waste Sampling and Analysis Program I NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54 , Fe59 , Co 5 8 , Co60 , Zn 6 5 , Mo 9 9 , Cs 134 , Cs 13 7 , Ce14 1, and Ce 144 . 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, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

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DOMINION VPAP-2103S REVISION 10 PAGE 47 OF 71 ATTACHMENT 4 (Page 1 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Fre- Minimum Analysis Type of Activity Lower Limit of Type quency Frequency Analysis Detection (LLD)

(gCi/ml), (Note 1)

Prior to Release-A. Waste Gas Prior ToReleas) Prior to Release Principal Gamma Storag Storage Tank (Grab (Gab Sample)

Saml) (Each Tank) Emitters (Note 2) . 1 1-Prior to Release Prior to Release Principle Gamma 1 X10-4 B. Containment Emitters (Note 2)

Purge (Each PURGE) (Each PURGE) H3 1 x 10-6 (Grab Sample)

C. Ventilation Weekly Weekly Principle Gamma 1 X10-4 (1)Process Vent (Grab Sample) Emitters (Note 2)

(2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1 x 10-6 (4)SRF Vent 131 1 x 10-12 Continuous Weekly (Note 5)

(Note 4) (Charcoal Sample) V133 1 x 10-10 Continuous Weekly (Note 5) Principal Gamma 1x 10-11 All Release (Note 4) Particulate Sample Emitter (Note 2)

Continuous Weekly Types as listed Composite Gross Alpha 1 x 10-11 (Note 4) Particulate Sample in A, B, and C Continuous Quarterly Composite Sr 89 and Sr 9 0 1 x 10-41 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1 x 10-6 (Note 4) Beta and Gamma Weekly Weekly Principle Gamma I x 10-4 Condenser Air Emitters (Note 2)

Ejector Grab Sample (Note 3) H3 1 x 10-6 (Note 3)

DOMINION VPAP-2103S REVISION 10 1

PAGE 48 OF 71 ATTACHMENT 4 (Page 2 of 4) I Radioactive Gaseous Waste Sampling and Analysis Program I

Gaseous Release Type Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

I Prior to Release Prior to Release Principle Gamma Emitters

_(gCi/ml), (Note 1) 1 x 10-4 I (Grab Sample) (Each Release) H3 1 x 10-6 I Continuous (Note 4)

Charcoal Sample (Note 6)

V31 1133 1 x 1011 1 X 10-10 I

Containment Hog Depres- Continuous (Note 4) Particulate Sample Principal Gamma (Note 6) Emitter (Note 2) 1 x 10-10 I surization Continuous (Note 4)

Composite Particu-late Sample (Note 6)

Gross Alpha .1 x 1010 I Continuous (Note 4)

Composite Particu-late Sample Sr 89 and Sr 90 1 x 10-10 I

(Note 6) 1_1 I

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DOMINION VPAP-2103S REVISION 10 PAGE 49 OF 71 ATTACHMENT 4 (Page 3 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation):

4.66 sb LLD= b(101)

E* V o 2.22E+06 9 Y

• e-(?At)

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).

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).

= 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..

DOMINION VPAP-2103S I REVISION 10 PAGE 50 OF 71 3 ATTACHMENT 4 (Page 4 of 4)I Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr8 7 , Kr 88 , Xe 13 3 , Xe13 3 m, Xe 13 5 , Xe135m, and Xe1 3 8 for gaseous emissions and Mn 5 4 , Fe59 , Co 58 , Co 60 , Zn 65 ; Mo 99 , Cs 134 , Cs 1 37 , Ce 14 1 and Ce144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and I 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, when:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased more than a factor of 3; 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 3

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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are analyzed, the corresponding LLDs may be increased by a factor of 10. This 3

requirement applies if: 3

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased by a factor of 3; and 3

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

NOTE 6: To be representative of the quantities and concentrations of radioactive materials in gaseous 3 effluents, composite sampling shall employ appropriate methods that will result in a specimen representative of the effluent release. 3 I

DOMINION VPAP-2103S REVISION 10 PAGE 51 OF 71 ATTACHMENT 5 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release:

1-GW-RM-102, or 1-GW-RM-130B (b). Iodine Sampler:

Continuous HP Sampler, or 1-GW-RM-130-1 (NOTE 1) 1 2 In-Line Particulate / Iodine Sampler (c) Particulate Sampler:

Continuous HP Sampler, or 1-GW-RM-130-1 (NOTE 1) 1 2 In-Line Particulate / Iodine Sampler (d) Process Vent Flow Rate Monitor:

1-GW-FT-100 1 3 (e) Sampler Flow Rate Measuring Device:

HP Sampler Rotometer or MGPI Flow Rate Measuring 1 3 Device

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor:

1-SV-RM-111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device:

Unit 1: 1-VP-FI-1A 1 3 1-VP-FI- LB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-I B 1 3

3. VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor:

SRF: RRM-101 1 1 SPS: Vent #1, 1-VG-RM-104 1 1 Vent #2, 1-VG-RM -110, or 1 i 1-VG-RM-131B (b) Iodine Sampler:

SRF: RRM-101 1 2 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP Sampler, or 1-VG-RM-131-1 (NOTE 1) 1 2 In-Line Particulate / Iodine Sampler

DOMINION VPAP-2103S REVISION 10 PAGE 52 OF 71 3 ATTACHMENT 5 (Page 2 of 2)

I Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM I

INSTRUMENT OPERABLE CHANNELS ACTION I (c) Particulate Sampler: I SRF: RRM-101 SPS: Vent #1, VG-RM-104 (NOTE 2) 1 1

2

.2 I

Vent #2, HP Continuous Sampler, or I-VG-RM- 13 1-1 (NOTE 1)

In-Line Particulate / Iodine Sampler 1 2 I

(d) Ventilation Vent Flow Rate Monitor:

SRF: 01-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 1

1 3

3 I Vent #2, 1-VS-FT- 116 1 3 (e) Sampler Flow Rate Measuring Device:

SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 1

3 3

I Vent #2, HP Sampler Rotometer or MGPI Flow Rate Measuring Device 1 3 I

NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components. I I NOTE 2: Vent # 1, 1-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.2.3]

I ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once I

per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling I

ACTION 2:

and Analysis. [Commitment 3.2.4]

If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously I

collected with auxiliary sampling equipment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). I

[Commitment 3.2.4]

ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

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DOMINION VPAP-2103S REVISION 10 PAGE 53 OF 71 ATTACHMENT 6 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION CHECK CHECK CALIBRATION FUNCTIONAL TEST

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor -

Providing Alarm and Automatic Termination of Release 1-GW-RM-102 D M (NOTE 2) R Q 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1)

Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A In-Line Particulate / Iodine Sampler (c) Particulate Sampler (NOTE 1)

Process Vent Continuous HP Sampler, or 1-GW-RM- 130-1 W N/A N/A N/A In-Line Particulate / Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-FT-100 D N/A R N/A (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D N/A SA N/A MGPI Flow Rate Measuring Device D N/A R N/A

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor Unit 1: 1-SV-RM-111 Unit 2: 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring Device Unit 1: 1-VP-FI-lA 1-VP-FI-I-PF-IBD 1B N/A R N/A Unit 2: 2-VP-Fl-lA 2-VP-FI-I B

3. VENTILATION VENT SYSTEM (a). Noble Gas Activity Monitor SRF: RRM-101 SPS: 1-VG-RM -110 'D M R Q 1-VG-RM -131B 1-VG-RM-104 L

DOMINION VPAP-2103S I

REVISION 10 PAGE 54 OF 71 I

ATTACHMENT6 (Page 2 of 2)

I Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements I CHANNEL, DESCRIPTION CHANNEL SOURCE CHECK CHECK CALIBRATION CHANNEL CHANNEL FUNCTIONAL TEST I

(b) Iodine Sampler (NOTE 1)

SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 I

Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 In-Line Particulate / Iodine I

Sampler (c) Particulate Sampler (NOTE 1)

SRF: RRM-101 I

SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM- 131-1 W N/A N/A N/A I

In-Line Particulate / Iodine Sampler (d) Ventilation Vent Flow Rate Monitor I I SRF:01-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 Vent#2, 1-VS-FT-116 D N/A R N/A I

(e) Sampler Flow Rate Measuring Device (NOTE 1)

SRF: RRM-101 D N/A R N/A I

SPS: Vent #1, 1-VG-RM-104 Vent #2, HP Sampler Rotometei or MGPI Flow Rate Measuring D

D D

N/A N/A N/A R

R S/A N/A N/A N/A I

Device I

NOTE 1:The mark numbers listedabove in l(b), 1(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor with which the iodine and particulate samplers and the flow I

rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

I NOTE 2:A source check is required for 1-GW-RM-102 prior to each Waste Gas Decay Tank U release.

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DOMINION VPAP-2103S REVISION 10 PAGE 55 OF 71 ATTACHMENT 7 (Page 1 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

1. DIRECT RADIATION About 40 Routine Monitor-ing Stations to be placed as follows:

1)_ Inner Ring in general area of site boundary GAMMA DOSE with station in each sector

2) Outer Ring 6 to 8 km from the site with a Quarterly Quarterly station in each sector

3) The balance of the 8 dosimeters should be placed in special interest areas such as population centers, nearby residents, schools' and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest Radioiodine Canister calculated annual 1131 Analysis Weekly average ground level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 operation with Particulate Sampler km distance located in a sample collection Gross beta radioactivity concentric ring ar6und weekly analysis following filter the Station change; c) 1 sample from 3 akmGamma locaion location 15-30 km control 5- isotopic analysis distant, providing valid of composite (by background data location) quarterly

DOMINION VPAP-2103 S i REVISION 10 PAGE 56 OF 71 3 ATTACHMENT 7 (Page 2 of 3)

I Radiological Environmental Monitoring Program I

Exposure Pathway and/or Sample Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis I

3. WATERBORNE a) Sfaea) 1 sample upstream Gamma isotopic analysis Cmoiefrtiimaayi I

a) Surface b) 1 sample downstream Monthly Sample monthly; Composite for tritium analysis quarterly Gamma isotopic and tritium I

b) Ground Sample from 1 or 2 sources Quarterly analysis quarterly c) Sediment from a) 1 sample upstream Semi-Annually Gamma isotopic analysis semi-I shoreline b) 1 sample downstream annually d) a) 1 sample upstream iltSemi-Annually Gamma annually isotopic analysis semi- I b) 1 sample downstream annually

4. INGESTION a) Milk a) 2 samples from milking I

animals in the vicinity of the Station. (NOTE 1) b) 1 sample from milking animals at a control Monthly Gamma isotopic and I131 anal-ysis monthly I location (-15-30 km distant). (NOTE 2) a) 2 samples of oysters in the Semi-Annually Gamma isotopic on edibles I

vicinity of the Station b) Fish and b) 4 samples of clams in the vicinity of the Station Semi-Annually Gamma isotopic on edibles I Invertebrates c) 1 sampling of crabs from thevicnit oftheStaion the vicinity of the Station Annually Gamma isotopic on edibles I

d) .1 sampling of 2 different species from the discharge canal (catfish, white perch, Semi-Annually Gamma isotopic on edibles I eel)

NOTE 1: If milk sampling cannot be performed, use item 4.c)d). Milk sampling cannot be performed I

when there are no milk sampling locations in the vicinity of the Station.

NOTE 2: If milk sampling from a control location cannot be performed, use item 4.c)e). Milk i

sampling cannot be performed when there is no milk sampling location 30 km distant. I I

DOMINION VPAP-2103S REVISION 10 PAGE 57 OF 71 ATTACHMENT 7 (Page 3 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued) a) 1 sample corn b) 1 sample soybeans Annually Gamma isotopic on edible portion c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if Gamma isotopic and 1131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 -

30 km distant in the available least prevalent wind direction, if milk sampling is not performed.

DOMINION VPAP-2103S REVISION 10 PAGE 58 OF 71 3 ATTACHMENT 8 (Page 1 of 3)

I Environmental Sampling Locations I

SAMPLE LOCATION DISTANCE DIRECTION REMARKS I MEDIA (MILES)

Air Charcoal and Surry Station Particulate (SS)

Hog Island Reserve (HIR) 0.3 2.0 NNE NNE I

Bacons Castle Alliance (BC)

(ALL) 4.5 5.1 SSW WSW I

Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE I Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location II Environmental Control (00) Onsite **

TLDs West North West (02)

Surry Station Discharge 0.2 0.4 WNW NW Site Boundary Site Boundary I

(03)

North North West (04) 0.2 NNW Site Boundary I North (05) 0.3 N Site Boundary North North East North East (06)

(07) 0.3 0.3 NNE NE Site Boundary Site Boundary I

East North East East (08)

(09) 0.4 0.3 ENE E

Site Boundary Site Boundary I

West West South West (10)

(11) 0.1 0.4 W

WSW Site Boundary Site Boundary I South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary I South (14) 0.4 S Site Boundary South South East South East (15)

(16) 0.6 0.9 SSE SE Site Boundary Site Boundary I

Station Intake (18)

Hog Island Reserve (19) 1.6 2.0 ESE NNE Site Boundary Near Resident I

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DOMINION VPAP-2103S REVISION 10 PAGE 59 OF 71 ATTACHMENT 8 (Page 2 of 3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (24) 4.0 W Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 S Approx. 5 miles Milk Epp's 4.8 SSW Colonial Parkway 3.7 NNW Williams' 27.5 S Control Location

DOMINION VPAP-2103S I

REVISION 10 PAGE 60 OF 71 U

ATTACHMENT 8 I (Page 3 of 3)

Environmental Sampling Locations I

I SAMPLE LOCATION, DISTANCE DIRECTION REMARKS MEDIA (MILES) I Well Water Surry Station Onsite***

Crops (Corn, Hog Island Reserve Slade's Farm 2.0 3.2 NNE S

U Peanuts, Soybeans) Brock's Farm 3.8 S I River Water Surry Discharge 0.4 NW (Monthly)

Sediment Scotland Wharf Chickahominy River 4.9 11.2 WNW WNW Control Location Control Location I

(Silt)

Clams Surry Station Discharge Chickahominy River 1.3 11.2 NNW WNW Control Location I

Surry Station Discharge Hog Island Point 1.3 2.4 NNW NE I Lawne's Creek 2.4 SE Oysters Point of Shoals 6.4 SSE I Mulberry Point 4.9 ESE Crabs Fish Surry Station Discharge Surry Station Discharge 1.3 1.3 NNW.

NNW I

Shoreline Sediment Hog Island Reserv6 0.6 N I

Chickahominy River 11.2 WNW Control Location

• • Onsite Location - in Lead Shield I

Onsite sample of Well Water -'taken from tap-water at Surry Environmental Building I

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DOMINION VPAP-2103S REVISION 10 PAGE 61 OF 71 ATTACHMENT 9 (Page 1 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

Analysis Water Airborne Fish Milk Food Sediment (NOTE 2) (pCi/l) Particulate (pCi/kg) (pCi/l) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry)

(pCi/m 3 ) (wet)

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 Nb-95 15 1-131 (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 be 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-2103S REVISION 10 PAGE 62 OF 71 ATTACHMENT 9 (Page 2 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

NOTE 1: For a particular measurement system (which may include radiochemical separation):

LLD L D 4.66 sb (24-1)

E V

• 2.22E+06

• Y

• e-((At)

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)

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) 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 VPAP-2103S REVISION 10 PAGE 63 OF 71 ATTACHMENT. 10 (Page 1 of 1)

Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne Fish Milk Food Products (pCi/I) Particulate or (pCi/kg, wet) (pCiIl) (pCi/kg, wet) 3 Gases (pCi/m )

H-3 30,000 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 1-131 (NOTE 1) 2 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 NOTE 1: Reporting level for the ground (drinking) water samples required by Radiological Environmental Monitoring Program (Attachment 7). The reporting level for the surface (non-drinking) water samples required by Attachment 7 is 20 pCi/1

DOMINION VPAP-2103S I

REVISION 10 PAGE 64 OF 71 ATTACHMENT 11 (Page 1 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEORLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year 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 five year average X/Q and D/Q values are used in the dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public.

1.2 Meteorological Data, Parameters, and Methodology 3 A five (5) year average of representative onsite meteorological data for the period January 1, 1992 through December 31, 1996, is used in the gaseous effluent dose pathway calculations. 3 This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (i.e.,

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 AT 15 8 .9ft-28.2ft and 158.9 ft wind data.

X/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ - I Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The code is based upon a straight line 5 airflow model implementing the assumptions outlined in Section C (excluding Cla and Clb) of Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion 3 of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors."

The open terrain adjustment factors were applied to the X/Q values as recommended in 5 Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release I calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was 5 based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 3 in. with plume exit velocity of 100 ft/sec.

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DOMINION VPAP-2103S REVISION 10 PAGE 65 OF 71 ATTACHMENT 11 (Page 2 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 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 Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table 11A-8.

X/Q and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for 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.

1.3 Results The X/Q value that would result in the maximum total body, skin, and inhalation exposure for ventilation vent releases was 6.OE-05 sec/m 3 at a site boundary location 532 meters NNE sector. For process vent releases, the site boundary X/Q value was 3.7E-07 sec/m 3 at a location 565 meters WSW sector. The discharge canal bank X/Q value that would result in the maximum inhalation exposure for ventilation vent releases was 1.6Eý04 sec/m 3 at a location 290 meters NW sector. The discharge canal bank X/Q value for process vent was 6.9E-07 sec/m 3 at a location 290 meters NW sector.

DOMINION VPAP-2103S I

REVISION 10 PAGE 66 OF 71 ATTACHMENT 11 (Page 3 of 8).

Meteorological, Liquid, and Gaseous Pathway Analysis The grass-cow-milk pathway analysis, which is performed to derive the maximum exposure from 1131, 1133, and from all radionuclides in particulate form with half-lives greater than eight days, is based on the dairy location indicated by the 1996 Land Use Census. The D/Q value from ventilation vent releases that would result in the maximum exposure was 2.5E- 10 per m2 at a location 5873 meters NNW sector. For process vent releases, the D/Q value was lAE-10 per m2 at a location 7788 meters SSW sector. For tritium, the XIQ value from ventilation vent releases that would result in the maximum exposure for the grass-cow-milk pathway I was 1.5E-06 sec/m 3 at a locations 5873 meters NNW sector, and 7.OE-08 sec/m 3 for process vent releases at a location 7788meters SSW sector. The inhalation pathway is the only other 3 pathway existing at this location. Therefore, the XJQ values given for tritium. also apply for the inhalation pathway. 3 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose I 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 3 included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste 3 Effluents.

2.2 Data, Parameters, and Methodology 3 Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station 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. 3 I

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DOMINION VPAP-2103S REVISION 10 PAGE 67 OF 71 ATTACHMENT 11 (Page 4 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year.

For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e. a mixing ratio of 0.2) was assumed as appropriateaccording to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Canberra Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal.

2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs.

Validation of the limiting age group and critical organ is performed by Canberra's liquid effluent dose calculation program using the data, parameters, and methodology provided in the Canberra Source Code file.

DOMINION VPAP-2103S I

REVISION 10 PAGE 68 OF 71 ATTACHMENT 11 (Page 5 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are 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 analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of 1131, 1133, tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from 1131, 1133, tritium, and particulates to demonstrate compliance with Step 6.3. 1.a. 3 3.2 Data, Parameters, and Methodology Five year 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 accessible to the public inside site boundary. The largest X/Q value was determined to be 6.OE-05 sec/m 3 I at site boundary for ventilation vent releases at a location 532 meters NNE direction,

,and 3.7E-07 sec/m 3 at site boundary for process vent releases at a location 565 meters WSW 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 3 release points are summed in calculations to calculate total maximum dose.

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.

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DOMINION VPAP-2103S REVISION 10 PAGE 69 OF 71 ATTACHMENT 11 (Page 6 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The maximum exposed individual for 10CFR50 Appendix I compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable garden, using the 1996 Land Use Census data. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses.

The gamma and beta dose factors Kivv, Liv,, Mivv, and Ni~v for ground level releases and the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode releases are included in the Canberra Source Code file.

Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation:

Pi mrem/yr per Ci/m 3 = K' (BR) DFAi (28-1) where:

K' = a constant of unit conversion, 1E+12 pCi/Ci BR = the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.1 DFAi=the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0133, R.G. 1.109, Rev. 1, and LADTAP II, NUREG/CR- 1276 It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year. The maximum five year average X/Q at this location was determined to be 1.6E-04 sec//m3 at 290 meters NW direction.

Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis.

DOMINION VPAP-2103S I REVISION 10 PAGE 70 OF 71 ATTACHMENT 11 (Page 7 of 8) I Meteorological, Liquid, and Gaseous Pathway Analysis The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation:

RMi K QF(U F m (r)(DFLi)

+ Fi ffs (I -f fp )e-ith

)pY e- ?itf e*fw (28-2)

(8j where:

K' = a constant of unit conversion, 1E+12 pCi/Ci I

QF = cow's consumption rate, 50, in Kg/day (wet weight)

Uap= infant milk consumption rate, 330, liters/yr Yp = agricultural productivity by unit area of pasture feed grass, 0.7 Kg/m2 Ys = agricultural productivity by unit area of stored feed, 2.0, in Kg/m2 Fm = stable element transfer coefficients r = fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, i in mrem/pCi Xi= decay constant for the ith radionuclide, in sec- 1 I 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) 3 tf = transport time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th = transport time from pasture, to harvest, to cow, to milk, to receptor, 7.78E+06, in seconds fp = fraction of year that cow is on pasture, 0.67 (dimensionless), 7.78E+06 in seconds fs = fraction of cow feed that is pasture grass while cow is on pasture, 1.0, dimensionless Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev. 1, and LADTAP II, NUREG/CR-1276. I I

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DOMINION VPAP-2103S REVISION 10 PAGE 71 OF 71 ATTACHMENT 11 (Page 8of8)

Meteorological, Liquid, and Gaseous Pathway Analysis Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used:

RH3= K'K' FmQFUap(DFLH3) [0.75(0.5/H)] (28-3) where:

K '"=a constant of unit conversion 1E+03 gm/kg H = 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.

The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation:

RIJ mrem/yr per Ci/m 3 = K' (BR) DFAi (28-4) where:

K'=a constant of unit conversion, 1E+12 pCi/Ci BR=breathing .rate of the particular age group, m 3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0133, R. G. 1.109, Rev. 1 and LAPTAP II, NUREG/CR-1276.

Attachment 4 Page 1 of 1 MAJOR CHANGES TO RADIOACTIVE LIQUID.

GASEOUS AND SOLID WASTE TREATMENT SYSTEMS There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems for this reporting period.

Attachment 5 Page 1 of 1 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION The Annual Radioactive Effluent Release Report shall explain why monitors required by the ODCM Attachments 1 and 5, which were determined to be inoperable, were not returned to operable status within 30 days. None of the above referenced monitors were inoperable greater than 30 days during this reporting period.

Attachment 6 Page 1 of 1 UNPLANNED RELEASES There were no unplanned liquid or unplanned gaseous releases during this reporting period.

Attachment 7 Page 1 of 1 LOWER LIMIT OF DETECTION (LLD) FOR EFFLUENT SAMPLE ANALYSIS GASEOUS: Isotope Required LLD Typical LLD Kr-87 1.00E-04 1.95E 3.19E-06 Kr-88 1.00E-04 2.08E 3.56E-06 Xe-133 1.00E-04 1.06E 3.35E-06 Xe-133m 1.00E-04 3.49E 9.40E-06 Xe-135 1.00E-04 5.17E 1.13E-06 Xe-135m 1.00E-04 1.66E 6.76E-06 Xe-138 1.00E-04 6.78E 9.92E-06 1-131 1.00E-12 4.47E 9.90E-14 1-133 1.OGE-10 1.10E-12 2.05E-12 Sr-89 1.0GBE- 1 1.80E 7.90E-12 Sr-90 1.0GBE-I 3.3BE 6.10E-12 Cs-134 1.0GE-11 3.88E 5.24E-13 Cs-137 1.00E-11 4.70E 7.75E-13 Mn-54 1.0GBE-I 5.12E 5.35E-13 Fe-59 1.0GBE-I 7.43E 1.15E-12 Co-58 1.0GBE- 1 3.91E 4.64E-13 Co-60 1.OGE-Il 6.81E 6.81E-13 Zn-65 1.0BE- 11 9.67E 9.38E-13 Mo-99 1 .0BE-I I 3.94E 3.88E-12 Ce-141 1.0GBE-I 3.78E 6.40E-13 Ce-144 1.OGE-II 1.59E 2.20E-12 Alpha 1.OGE-Il 1.66E 1.67E-14 Tritium 1.00E-06 5.44E 7.87E-08 LIQUID Sr-89 5.0BE-08 2.60E 4.70E-08 Sr-90 5.00E-08 1.80E 4.0OE-08 Cs-134 5.00E-07 7.03E 1.75E-08 Cs-137 5.00E-07 8.32E 2.29E-08 1-131 1.00E-06 6.82E 1.95E-08 Co-58 5.00E-07 4.32E 1.85E-08 Co-60 5. OOE-07 8.8 1E 3.23E-08 Fe-59 5. OOE-07 1.1 8E 3.14E-08 Zn-65 5. OOE-07 1.1GE 4.26E-08 Mn-54 5.00E-07 3.11E 1.55E-08 Mo-99 5.00E-07 3.18E 3.05E-07 Ce-141 5.O0E-07 1.04E 2.15E-08 Ce-144 5.O0E-07 3.57E 8.36E-08 Fe-55 1.00E-06 1.80E 4.30E-07 Alpha 1.00E-07 2.87E 2.94E-08 Tritium 1.00E-05 1.50E 1.95E-06 Xe-133 1.00E-05 1.66E 3.88E-08 Xe-135 1.00E-05 6.35E 1.22E-08 Xe-133m 1.00E-05 4.92E 9.11E-08 Xe-135m 1.00E-05 2.22E 8.40E-07 Xe-138 1.0BE-05 8.07E 1.96E-06 Kr-87 1.0BE-05 2.22E 4.98E-08 Kr-88 1 .0E-05 2.38E 4.52E-08

Attachment 8 Page 1 of I INDUSTRY GROUNDWATER PROTECTION INITIATIVE The Annual Radioactive Effluent Release Report shall include a summary of on-site radioactive spills or leaks that were communicated in accordance with the Initiative reporting protocol, and also include sample analyses from groundwater wells that are not part of the Radiological Environmental Monitoring Program (REMP). There were no on-site radioactive spills or leaks communicated in accordance with the Initiative reporting protocol in 2006. Four samples from deep groundwater wells that are not a part of the REMP were obtained 08/09/2006. The table below summarizes the analytical results.

Well Description Tritium, pCi/liter Gamma, pCi/Liter Well A ND ND Well H ND ND Well J ND ND Construction Well ND ND ND = No detectable activity. 500 pCi/liter Tritium LLD. Gamma emitter LLDs per REMP requirements.