Text

2008 Annual Radioactive Effluent Release Report
	ML091240575
Person / Time
Site:	Surry
Issue date:	04/24/2009
From:	Stanley B; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	09-268
	Download: ML091240575 (109)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 24, 2009 Attention: Document Control Desk Serial No.09-268 U.S. Nuclear Regulatory Commission SS&LITJN RO 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 1 AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2008 through December 31, 2008. 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 2008 calendar year, as outlined in Regulatory Guide 1.21, Revision 1, June 1974.

If you have any further questions, please contact Paul Harris at 757-365-2692.

Sincerely, B. L. Stanley Director Safety & Licensing Surry Power Station Attachment Commitments made by this letter: None z7~~~IB

Serial No.: 09-268 Docket Nos.: 50-280 50-281 cc: United States Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center, 23T85 61 Forsyth Street, S. W.

Atlanta, Georgia 30303-8931 NRC Senior Resident Inspector Surry Power Station American Nuclear Insurers Attn: Mr. Edward Everett Suite 300 95 Glastonbury Blvd.

Glastonbury, CT 06033

Serial No.: 09-268 Docket Nos.: 50-280 50-281 ATTACHMENT 1 2008 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION UNITS I AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

Su rry Power Station 2008 Annual Radioactive Effluent Release Report 7ADom~nioit

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION January 1, 2008 Through December 31, 2008 Prepared By:

P. F. Blou~nt Health Physicist Reviewed By:

P. R. Harris Supervisor Radiological Analysis Reviewed By:

B. A. Hilt Supervisor Health Physics Technical Services Approved By:

L. " Jo s Manager RadioloV-oProtection and Chemistry

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE SURRY POWER STATION January 1, 2008 Through December 31, 2008 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, 50-281, 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 2008 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 2008 effluent release data, I OCFR50 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 1.50E-04 mrem, which is 2.50E-03% of the 6 mrem dose limit. The critical organ doses due to liquid effluents, GI-LLI and Liver respectively, were 3.63E-04 mrem and 1.47E-04 mrem. These doses are 1.82E-03% and 7.35E-04% of the respective 20 mrem dose limit.

2. The air dose due to noble gases in gaseous effluents was 3.76E-04 mrad gamma, which is 1.88E-03% of the 20 mrad gamma dose limit, and 3.17E-03 mrad beta, which is 7.93E-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 1.14E-01 mrem, whichis 3.80E-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 was one change to VPAP-2103S, Offsite Dose Calculation Manual, during this reporting period. Attachment 3 provides the changes to VPAP-2103S.

In accordance with the Nuclear Energy Institute (NEI) Industry Groundwater Protection Initiative, analysis results of ground water monitoring locations not included in the Radiological Environmental Monitoring Program (REMP), will be included in this report. Ground water monitoring well sample results are provided in Attachment 8.

1

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.

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 2008.

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.

2

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 1A 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 the 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- 131, 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.

4

Attachment 1 EFFLUENT RELEASE DATA January 1, 2008 Through December 31, 2008 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 1 TABLE 1A Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT

. PERIOD: 1/1/08 TO 12/31/08 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 1.74E-03 2.53E-01 1.80E+01

2. AVE RELEASE RATE FOR PERIOD pCi/sec 2.2 1E-04 3.21E-02 B. IODINE

1. TOTAL 1-131 Ci 2.54E-07 N/D 2.80E+01

2. AVE RELEASE RATE FOR PERIOD ýtCi/sec 3.23E-08 N/A C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 1.49E-07 N/D 2.80E+01

2. AVE RELEASE RATE FOR PERIOD ýtCi/sec 1.89E-08 N/A

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

1. TOTAL RELEASE Ci 1.68E+01 1.27E+01 3.1OE+O1

2. AVE RELEASE RATE FOR PERIOD pLCi/sec 2.14E+00 1.61E+00 PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE 1.09E-02 8.17E-03 TOTAL BODY DOSE RATE 6.29E-06 5.13E-05 SKIN DOSE RATE %I 2.02E-06 1.57E-05

Attachment 1 TABLE 1A Page 2 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH % EST. ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci 8.15E-01 1.73E-02 1.80E+01

2. AVE RELEASE RATE FOR PERIOD [tCisec 1.03E-01 2.17E-03 B. IODINE

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

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

1. HALF-LIFE >8 DAYS Ci N/D 4.74E-06 2.80E+01

2. AVE RELEASE RATE FOR PERIOD gCi/sec N/A 5.97E-07

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

1. TOTAL RELEASE Ci 1.10E+01 6.72E+00 3.10E+01

2. AVE RELEASE RATE FOR PERIOD gCi/sec 1.39E+00 8.45E-01 PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE 7.06E-03 4.31E-03 TOTAL BODY DOSE RATE 2.46E-05 2.OOE-04 SKIN DOSE RATE 2.75E-04 5.02E-05

Attachment 1 TABLE 1B Page 3 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE I

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-85rm Ci N/D N/D N/D 5.26E-04 Kr-87 Ci N/D N/D N/D N/D KrZ88 Ci N/D N/D N/D 3.75E-04 Xe- 133 Ci N/D 7.5 1E-02 1.18E-04 1.17E-01 Xe-135 Ci N/D N/D N/D 2.14E-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 1.43E-03 Ar-41 Ci N/D N/D N/D 4.16E-03 TOTAL FOR PERIOD Ci N/A 7.5 1Er02 1.18E-04 1.45E-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. N/D 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 N/D 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 TOTAL FOR PERIOD Ci N/A N/A N/A ' . N/A

Attachment 1 TABLE IB Page 4 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 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 1.32E-02 9.64E-04 Xe-135 Ci N/D N/D N/D N/D Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131rm Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D Ar-41 Ci NiD N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A 1.32E-02 9.64E-04

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 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 N/D 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 TOTAL FOR PERIOD Ci N/A N/A N/A N/A

Attachment 1 TABLE IC Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 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 2.30E-02 Xe-135 Ci 2.50E-04 3.86E-03 1.20E-03 1.23E-03 Xe-135m Ci N/D 4.39E-03 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 N/D Ar-41 Ci 1.67E-04 3.37E-04 N/D N/D TOTAL FOR PERIOD Ci 4.17E-04 8.59E-03 1.20E-03 2.42E-02

2. IODINES 1-131 Ci 2.54E-07 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 2.54E-07 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 C* N/D N/D N/D *N/D Cs-137 Ci .1.49E-07 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 N/D 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 TOTAL FOR PERIOD Ci 1.49E-07 N/A N/A N/A

Attachment 1 TABLE IC Page 6 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT*

PERIOD: 1/1/08 TO 12/31/08 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 8.OOE-01 N/D Kr-85rm 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 ,N/D Xe-135 Ci 2.34E-04 2.73E-04 4.94E704 1.33E-03 Xe-135m Ci N/D 3.48E-05 N/D N/D Xe-138 Ci N/D 4.78E-05 N/D 2.45E-03 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 2.42E-04 1.05E-03 N/D 1.11E-02 TOTAL FOR PERIOD Ci 4.77E-04 1.41E-03 8.01E-01 1.49E-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 J-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 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 4.74E-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 TOTAL FOR PERIOD Ci N/A 4.74E-06 N/A N/A

Attachment 1 TABLE 2A Page 7 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 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 1.32E-02 9.60E-03 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD [tCi/mL 2.13E- 11 1.38E-. 1

3. PERCENT OF APPLICABLE LIMIT % 3.54E-05 2.49E-05 B. TRITIUM

1. TOTAL RELEASE Ci 1.31E+02 3.48E+02 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD ý.tCi/mL 2.12E-07 5.02E-07

3. PERCENT OF APPLICABLE LIMIT % 2.12E-03 5.02E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci N/D 1.43E-05 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD 1 iCi/mL N/A 2.06E-14 3: PERCENT OF APPLICABLE LIMIT % N/A 1.03E-08.

D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci N/D N/D 2.OOE+01 E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 4.47E+07 4.04E+07 3.OOE+00 F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS .6.i9E+11 6.94E+ 1I1 3.OOE+00

Attachment 1 TABLE 2A Page 8 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 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 1.97E-03 2.82E-03 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD gCi/mL 2.57E-12 4.31E-12

3. PERCENT OF APPLICABLE LIMIT % 1.02E-05 1.24E-05 B. TRITIUM

1. TOTAL RELEASE Ci 6.11E+O1 6.17E+01 2.OOE+01

2. AVE DIL. CONC. DURING PERIOD jiCi/mL 7.97E-08 9.45E-08

3. PERCENT OF APPLICABLE LIMIT % 7.97E-04 9.45E-04 C. DISSOLVED AND ENTRAINED GASES

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

2. AVE DIL. CONC. DURING PERIOD gCi/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 3.80E+07 3.56E+07 3.OOE+00 F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.66E+1 I 6.53E+11 3.OOE+00

Attachment 1 TABLE 2B Page 9 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/08 TO 12/31/08 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 3.81E-04 5.82E-04 2.76E-04 4.31E-04 1-131 Ci N/D N/D N/D 4.04E-06 Co-58 Ci N/D 3.19E-05 4.08E-03 4.99E-03 Co-60 Ci N/D N/D 3.53E-03 1.20E-03 Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D 7.29E-04 1.07E-04 Cr-51 Ci N/D N/D 2.04E-04 6.81E-04 Zr-95 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D N/D 7.14E-06 Mo-99 Ci N/D N/D N/D N/D Tc-99m Ci N/D 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 Ce-141 Cil 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 7.87E-06 Sb-125 Ci N/D N/D 3.88E-03 1.51E-03 Co-57 Ci N/D N/D 8.55E-05 4.40E-05 TOTAL FOR PERIOD Ci 3.81E-04 6.14E-04 1.28E-02 8.98E-03 Xe-133 Ci N/D N/D N/D 1.43E-05 Xe-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci N/A N/A N/A 1.43E-05

Attachment 1 TABLE 2B Page 10 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/0 TO 12/31/08 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH 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 4.53E-04 4.76E-04 5.12E-05 9.40E-05 1-131 Ci N/D N/D N/D N/D Co-58 Ci N/D N/D 5.10E-04 5.64E-04 Co-60 Ci N/D N/D 7.29E-04 5.13E-04 Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D 1.00E-04 2.72E-05 Cr-51 Ci N/D N/D N/D- N/D Zr-95 Ci N/D N/D N/D N/D Nb-95 Ci N/D N/D 5-20E-06 N/D Mo-99 Ci N/D N/D .N/D N/D Tc-99m Ci N/D 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 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 N/D Sb-125 Ci N/D N/D 1.08E-04 1.14E-03 Co-57 Ci N/D N/D 7.14E-06 N/D TOTAL FOR PERIOD Ci 4.53E-04 4.76E-04 1.51E-03 2.34E-03 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 TABLE 3 Page 11 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/08 - 12/31/08 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 2.93E+01* 1.00E+01 bottoms, etc. Ci 3.17E+02 3.OOE+01

b. Dry compressible waste, contaminated m3 7.15E+02"* 1.00E+01 equip., etc. Ci 1.22E+00 3.OOE+01

c. Irradiated components, control m3 5.68E-01*** 1.00E+01 rods, etc. Ci 6.04E-01 3.OOE+01

d. Other (Waste oil) m3 O.OOE+00 1.00E+01 Ci O.OOE+00 3.OOE+01

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

a. Ni-63 7.26E+01 Fe-55 1.17E+O1 Co-60 8.53E+00 Co-58 3.89E+00 Cs-137 1.1OE+00

b. Cs-137 4.94E+O1 Co-58 1.74E+01 Co-60 1.29E+01 Fe-55 5.97E+00 Ni-63 5.44E+00 H-3 2.92E+00 Cr-51 2.62E+00 Ce-144 1.06E+00

c. Ni-63 6.12E+01 Co-60 2.75E+01 Fe-55 8.56E+00 Co-58 1.91E+00 d.

Attachment 1 TABLE 3 Page 12 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/08 - 12/31/08 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 3 Truck Barnwell, SC (EnergySolutions) 20 Truck Oak Ridge, TN (EnergySolutions)

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 1.90E+01 m3 .

- 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 4.41E+01 m3 .

- - NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. This volume is representative of the actual volume buried.

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 4.37E-05 1.59E-04 4.11E-05 8.25E-06 7.83E-06 4.07E-02 2nd Quarter 7.49E-05 1.41E-04 7.41E-05 6.99E-05 8.12E-05 3.06E-02 3rd Quarter 1.41E-05 3.26E-05 1.45E-05 3.32E-05 2.97E-03 2.66E-02 4th Quarter 1.68E-05 2.99E-05 1.75E-05 2.65E-04 1.06E-04 1.62E-02 Annual 1.50E-04 3.63E-04 1.47E-04 3.76E-04 3.17E-03 1.14E-0I

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 was one revision to the ODCM implemented during this reporting period. The revision summary is as follows.

Revision 15:

Revised to include the elements of the Nuclear Energy Institute (NEI) Industry Ground Water Protection Initiative.

Revised approval process for changes to the ODCM to be consistent with the revised Technical Specification requirements.

Revision 15 of the ODCM is included with this attachment.

Procedure Routing: ~

I .2DO'minion

n* Atahmn 5 ~ Pag 1o Instructions:

1. Document comments on the procedure attached to this form.

2. Resolve comments with the person identified on the bottom of this form, if required.

3. After comments are resolved, or if there are no comments, initial and date the.applicable block and send to the person identified on the bottom of this form.

NOTE: The "Requestor" may not be the "Technical" or "Validation" reviewer for technical procedures; or the "Responsible Department" reviewer for admin procedures.

[Procedure Number VPAP-2103S Revision 15 "

Procedure Title Offsite Dose Calculation Manual (Surry)

Procedure Writer (Name) / Requestor (Name) Location Extension J. A. Mann, III /Y. Blount SPS 8-798-2118 Type of Request: [ New Procedure MX)Procedure Revision [ Procedure Deletion K [ Vendor Procedure ComnmitR Due Date Comments Due'By 102/8 Scheduled Approval Date 10/08 Supervisor Station Procedures (Signature) L-ate Manager Nuclear Operations ApprovIfReviews for EOFPs/FCAs (Signaturep Date!

~Orcic Due Date - Typ of Review C,huck' Required Reviews Reviewer or Review ing Organiztion & Lo-fn Iinit~iasD 1 10/9/08 Writers J. A. Mann, III.. .. 4 Self-Check Writers Guide 10/23/08"- - P.-B lount-SPS-.

-r.

Technical Technical EOPs/FCAs

] In-Plant

] Reference Validation Initialed Routing Sheets may be 3Performance faxed to Pete Blount@

[ Simulator 2i69

[ Walkthrough

[ Comparison

]Table Top 2 10/23/08 Responsible Dept. J. Keithly SPS 10/23/08 Other Department L. Jones SPS Review ____

-10/23/08 Other Department D. Miller SPS Review -'4Ž-.

Other Department Review Other Department Review Other Department Review Other Department Review Location1 P eturrn o (Printed etelBlount (forName) comment resolution) SPs 519T ion For additional Routing or Comments (if needed), see Page 2. Form No. 730683(Sep2004)

,2..-- I Doc Librar DoLbrty

Subject:

Category:

VPAP Proce

-2103S, Offsite Dose Calculation Manual (Surry), Revision 7 DRAFT Jure Routing I

Main Topic

~Sandy Mann/Generation (3/Dom

~ Oiginator

:- : : Previous Reviewers Current Future I

10/09/2008 01:38 PM .... . Sandy Luther None None 7i Mann/C ~eneratiornK3/Dorr Jones/Generation/3/D omn Jim~

I

~Ke ithley/Generation/3V DK I

By 10/23/08 your review is needed for procedure: I VPAP-2103S, Offsite Dose Calculation Manual (Surry); Revision 7, DRAFT Pete Blount (SPS RP) is coordinating comments. I vpap-213i(150).pdf I

Submitted for review on 10/09/2008 Review completed by Pete Blount on 10/09/2008 Review-completed-by-DK-Miller-on-1 0/09/2008 I

I Review completed-b1-ii -Keithle -1..i.10/10/2008 .

Review completed by Luther Jones on 10/14/2008 I

I I

Administrative ProceduresAction Request 2)Dominion (A-PAR)

VA-05. - Attcmn 21 Pagel of I inqustutonforPrcompletn fowr to ap rorit todificatiorm are- inbued inplte

.rcstrga .P Ow e V-A--byU O) . .

n S

ontrat(o S S peebocs1truh1 n I-S

1. Procedure Number 3. Page 4. Effective Date IVPAP-2103S 2. Revisiry 1 of1 /iI / - /02 Procedure Tite 6. Expiration Date Offsite Dose Calculation Manual (Surry) N/A

7. jTyfe of Request

_ New Procedure [x7 Procedure Revision [] Procedure Deletion [Emergency Change

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

9. Location [x¶SPS ENAPS ECORP Location [ISPS [L1 NAPS [iCORP

10. Requested by (Printed Name) 11. Date 12. Phone 13. Requested by (Printed Name) 14. Date 15. Phone P. Blount 10/1/08 2467 N/A N/A N/A

16. Does procedure meet requirements of NOTE below? El Yes [ZINo

17. Does this procedure require a 50.59 / 72.48 Evaluation (Form No. 730947)? [] Yes [XINo I18. Are there any new sections or steps designated North Anna or Surry? [j Yess [K No

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

20. Is the reasonfor the station-specific instructions due to differences in construction? DI Yes [:]No [ZIN/A

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

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

NOTE: VPAP-2103N, VPAP-2103S, and VPAP-2104 require Site Vice President(s) approval.

SPI Ps and VPAP-2401 require FSRC(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 PI-AA-4000, Change Management, to be used? LZYes [x] No

23. Location ZISPS E NAPS E]CORP Location [FSPS [7 NAPS E]CORP

24. PPO (Printed Name) 25. Date 126. Phone 27. PPO (Printed Name) 28. Date 29. Phone L. B. Jones 10/9/08 2010 N/A N/A N/A

[E130. PPO(s) [-131. FSRCs [1132. Site Vice Presidents [E33. Vice President (Corp)

34. PPO (Signature) r I/ 35..Daje 36. PPO (Signature) 37 D t

~4,(~{JJ&YL~N/A

38. FSRC Chairman (Sinatu e) 39. Date 40. FSRC Chairman (Signature) 41. Date N/A N/A N/A N/A

42. Site Vice esijen (Sigrzeure)4.Dt 44. Site Vice President (Signature) 45. Date 71 (9 Exctv aproa .n reuie fo stationI- specifi 46. Vice President Corporate (Signature) 47. 'Date intucin tha ar bsed soll on stto pre------------- N/A N/A Key: A-PAR-Administrative Procedures Action Request; SPS-Surry Power Station; NAPS-North Anna Power Station; CORP-Cor orate; PPO*s)-Process/Program Owner(s);

FSRC-Facility Safety Review Committee; SPIos-Security *Pan Implementing Procedures Form No: 720457(Oct 2008)

D i nActivity Checklist Dotminion Page I of I VP -P00 At -a h m nI

1. Identification of Governing Document 2. Applicable Station 3. Applicable Unit VPAP-2103S, Rev 15 C ] North Anna Power Station [x] Surry-Power Station Cx] Unit 1 [x] Unit 2 Cx] ISFSI'

4. Brief Description of the Entire Activity Procedure revised to incorporate radioactive effluent and environmental reporting requirements and communication guidance to State, Local and NRC officials based upon NEI 07-07 Industry Ground Water Protection Initiative - Final Guidance. Requirement for procedure changes to be reviewed and approved by SNSOC/FSRC been removed to be in consistent with Tech Spec 6.8.

5. Is the activity bounded by another change that has already been If YES, identify the source document: (Skip to Block 8) determined to require NRC approval? C ]Yes Cx] No

6. Is the activity based on a source document that has already been reviewed If YES, identify the source document or attach a copy of the completed review.

in accordance with VPAP-3001 or DNAP-3004? [ ] Yes Ex] No (Skip, to Block 8)

7. GefeaScreeni (Definitioris are'provi ded hVPAP-30):' :

TNTE:UFSAR and SESI SARbareto be usednterchan eably wfhený.crnplett Checklist.

h ,.:this A. Does this activity require a change to the Operating License, Technical Specifications (station or ISFSI), Technical [ ] Yes [x] No.

Specification Bases, ISFSI License, or the Technical Requirements Manual?

B. Does this activity alter (temporarily or permanently) the design of a Structure, System, or Component (SSC) described [ ] Yes [x] No

-. inthe UFSAR? .... ...

C. Does this activity alter (temporarily or permanently) the function, ability to function, or method of performing a [ ] Yes [x] No function of an SSC described in the UFSAR?

D. Does this activity alter a numeric value associated with design or performance requirements that has not been [ ] Yes [x] No previously reviewed in accordance with VPAP-3001 or DNAP-3004?

E. Does this activity modify how SSCs are operated or controlled as described, outlined, or summarized in the UFSAR? C ] Yes [x] No F. Does this activity perform a test or experiment that is not described in the UFSAR? C ] Yes [x] No G. Does this activity involve a change in a calculational method that supports the function of an SSC described in the C ] Yes Cx] No UFSAR? _ _ _ _ _ _ _ _ _

-H-Does-this-activtyitnvolve-a-temporary--modification-as-defined-in-VPAPA1403-? _Yes-Cx1]..-No- E.. -

I. Does this activity involve a change, test, or experiment that may affect the environment? C ] Yes Cx] No ~I ri ,e t- 8or 9is' uE$... I-. nssa -1 , ueestio,ns ,

8.Maintaining the UFSAR <-7'--

Does this activity require revising the UFSAR or SFS1 SAR?

V .-

If YES," Initiate a Change Request in accordance with VPAP-2803 and obtain C ]Yes Cx] NoI the signature of a qualified Regulatory Screener as a reviewer.

I

~9. R4silts anhd Reerences 9a. Cx] Based on the results of the completed Activity Checklist, the activity has no impact on the design, function, ability to function, method of performing the function, or control or operation of a SSC described in the UFSAR (i.e., the change activity is safe) and the activity can be implemented without prior regulatory approval.

List documents used to perform the General Screen.

TS Amendment 244/243 (TSCR 359A)

CR102850, CA078325 NEI Industry Ground Water Protection Initiative - Final Guidance I

Renewed Facility Operating License (Units 1 and 2) DPR-32 and DPR-37 SPS UFSAR: Keyword Index; Chapter 11, Radioactive Wastes and Radiation Protection SPS Tech Spec 6, Administrative Controls Topical Report DOM-QA-1 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 10CFR50.36a Technical specifications on effluents from nuclear power plants 9b. Conclusion Provide additional discussion to support the conclusion.

This activity does not impact nuclear plant safety. This activity revises VPAP-2103S to incorporate the NEI Industry Ground Water Protection Initiative - Final Guidance reporting and notification requirements. This procedure revision does not modify an existing radiological effluent, nor create a new effluent, nor change effluent dose or radiation monitor setpoint calculation methodologies. Therefoie, the level of radioactive effluent control required by 10 CFR 20 Subpart D, 10 CFR 50.36a & App.I and 40 CFR 190 will be maintained.

10. Preparer Name (Print) 11. Title I

P. Blount Health Physicist III

12. Preparer Signature / , .13. Date

14. Reviewer Name (Only Required if Preparer is not AC Qualified) or lAW Block 8 15. Title

16. Reviewer Signature 17. Date Key: UFSAR-Updated Final Safety Analysis Report which includes the plant specific UFSAR and the ISFSI FSAR; Form No. 730914 (Feb 2008)

AC-Activity Checklist; lAW-In Accordance With .

Station l Dominion A dministrative Procedure

Title:

Offsite Dose Calculation Manual (Surry)

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

Procedure Number Revision Number Effective Date VPAP-2103S 15 On File Revision Summary The following changes were made to incorporate radioactive effluent reporting requirements and communication guidance to state, local, and NRC 'officials based upon NEI 07-07 Industry Ground Water Protection Initiative - Final Guidance Document.

Deleted 3.1.26 - Nuclear Energy Institute (NEI) Industry Ground WaterProtection Initiative, June 2006.

" Added 3.1.26, NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Documents.

Added 3.1:28 - RP-AA-502, Groundwater Protection Program.

" Revised 6.7.2.a.7 - reworded to comply with NEI guidance.

Added 6.7.2.a.8 - "Groundwater sample results from locations not part of the Radiological Environmental Monitoring Program."

" Revised 6.7.5, Industry Ground Water Protection Initiative to reflect the above changes.

The following change was made to reflect current Technical Specifications (Offsite Dose Calculation Manual no longer requires FSRC approval):

Revised 6.7.4.a as follows regarding changes to the ODCM:

- OLD - "Reviewed and approved by SNSOC and Site Vice President before implementation."

- NEW - "Approved by the Site Vice President before implementation."

Approvals on File

DOMINION VPAP-2103S REVISION 15 PAGE 2 OF,73 TABLE OF CONTENTS U Section Page 1.0 PURPOSE 4 2.0 SCOPE 4 I

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 1 6.2 Liquid Radioactive Waste Effluents 11 6.2.1 Liquid Effluent Concentration Limitations 11 I 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 I

I

DOMINION VPAP-2103S REVISION 15 PAGE 3 OF 73 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 6.7.5 Industry Ground Water Protection Initiativý 41 7.0 RECORDS 43 ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 44 2 Radioactive Liquid Effluent Monitoring Instrumentation 45 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 46 4 Radioactive Gaseous Waste Sampling and Analysis Program 49 5 Radioactive Gaseous Effluent Monitoring Instrumentation 53 6 Radioactive Gaseous Effluent Monitoring Instrumentation 55 Surveillance Requirements 7 Radiological Environmental Monitoring Program 57 8 Environmental Sampling Locations 60 9 Detection Capabilities for Environmental Sample Analysis 63 10 Reporting Levels for Radioactivity Concentrations in Environmental 65 Samples 11 Meteorological, Liquid, and Gaseous Pathway Analysis 66

DOMINION VPAP-2103S I

REVISION 15 PAGE 4 OF 73 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 gCi/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 limitedI 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 greaterthan 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 Radiological Environmental I Monitoring Programs at Surry Power Station.

I I

I

DOMINION VPAP-2103S REVISION 15 PAGE 5 OF 73

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 I 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 I

REVISION 15 PAGE 6 OF 73 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 I 3.1.20 Surry UFSAR 3.1.21 Laboratory Quality Assurance Plan, Manual 100; Framatome Environmental LaboratoryI 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 3.1.25 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.26 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document I 3.1.27 CR022320 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.28 RP-AA-502, Groundwater Protection Program 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-97-128 1, 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 7 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.

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DOMINION VPAP-2103S REVISION 15 PAGE 7 OF 73 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.

The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display.

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 (4tCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1131, 1132, 113 3 , 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 Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103S I

REVISION 15 PAGE 8 OF 73 i 4.6 Frequency Notations I NOTE: Frequencies are allowed a maximum extension of 25 percent.

I NOTATION FREQUENCY D - Daily At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 DR - During the release Not applicable At least once during each release I

4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system I

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

= Emission rate (continuous line source; grams per second per meter) 4.9 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 probability of falsely concluding that a blank observation represents a "real" signal.

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DOMINION VPAP-2103S REVISION 15 PAGE 9 OF 73 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 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 I

REVISION 15 PAGE 10 OF 73 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 I 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 N The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

DOMINION VPAP-2103S' REVISION 15 PAGE 11 OF 73 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 followinglimits:

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 15 PAGE 12 OF 73

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

,4tCCi/mli.

n Volume of Waste Discharged x Z-ACW.

i where: I

ýtCi/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 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 gCi/mL for dissolved or entrained noble gases I

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. l.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. I

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 I 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 15 PAGE 13 OF 73

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 I-SW-RM- 107 A, B,:C, D Condenser Circulating Water Line 1-SW-RM- 120 2-SW-RM-220 Radwaste Facility Effluent Line RE- RRM-131

DOMINION VPAP-2103S I

REVISION 15 PAGE 14 OF 73

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

1. Maximum setpoint values shall be calculated by: I S CFD 2)

FE where:

S the setpoint, in ýtCi/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 jiCi/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) 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 15 PAGE 15 OF 73

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:

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 REVISION 15 PAGE 16 OF 73

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

D = tFM 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 I IA, 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 I during the period t, from all liquid releases, in [tCi/mL I

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DOMINION VPAP-2103S REVISION 15 PAGE 17 OF 73 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-ýtCi. Values for Ai are provided in the Canberra Source Code file.

Ai = 1.14 E+05 (21BFi + 5B1i) DFi (7) for example:

1.14 E+05 = I E+06 pCi4tCi x I 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/L 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. . 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 I

REVISION 15 PAGE 18 OF 73 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. i

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, i 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. i

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 I

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DOMINION VPAP-2103S REVISION 15 PAGE 19 OF 73 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, I133 , 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. l.a. limits, promptly decrease the release rate to within theabove 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-2103S REVISION 15 PAGE 20 OF 73

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 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.

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

I EKivv ivv + KipvQipv] !00 mrem/yr to the total body (8)

OR YLiv + llMivv)Qivv + (Lipv + LI-Mip ) :000 mrem/yr to the skin

ipv3 (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 Ki, 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 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 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 Qv, Qv = the release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) 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 15 PAGE 21 OF 73

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:

ivv + Pipv!ipv] *<1500 mrem/yr to the critical organ (10) where:

Pivv, Pipv = the critical organ dose factor for ventilation vents or process vent for 1131, 133, H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec 13 1 Qivv, Qipv = the release rate for ventilation vents or process vent of,1 ,

1133, H 3 , 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 oivv.

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 i

REVISION 15 PAGE 22 OF 73

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 I 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 I in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5),

take the action shown in those tables.

3. Attempt to 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: I Release Point Instrument Number Process Vent Condenser Air Ejector 1-GW-RM-130B 1-SV-RM-1 11 I Ventilation Vent No. I 2-SV-RM-211 I-VG-RM-104 I

Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101 U I

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DOMINION VPAP-2103S REVISION 15 PAGE 23 OF 73

d. Setpoint Calculations

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

DŽDPD_ pv ÷ + D cae + vv (1

(+)

where:

D = Step 6.3.1.a. dose limits that implement 10 CFR 20 for the Station, mrem/yr Dpv = the noble gas'site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae =the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mremryr 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 2.12 E-03 Cm Fm (12)

Fm 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, gCi/mL Rm = the release rate limit for pathway m determined from methodology in Step 6.3.1 .c., typically using Xe133 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 15 PAGE 24 OF 73 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 theapplicable 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 mrad for beta radiation

- During any calendar year: *10 mrads for gamma radiation and *20 mrad for beta radiation

2. Cumulative dose contributions for noble gases for the current calendar quarter U 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 U 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 15 PAGE 25 OF 73

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-08MivvQivv + MipvQipv]

(Ij) i For beta radiation:

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

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility.Ventilation Vent and air ejectors py, refers to the vent releases from the process vent i, refers to individual radionuclide Dg = the air dose for gaiinma 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 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 I

REVISION 15 PAGE 26 OF 73 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, 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:

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, I133, 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 I report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits. I

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 15 PAGE 27 OF 73

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 ofQivv. 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, , tritium, and particulate-form radionuclides with half-lives greater than'8 days, shall be' determined by:

Dr 3.17E-083[(RMivvQivv + RM ipvQipv) + (RlivvQivv + Rlipvbipv)] (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 to1 1 3 1, 1133, tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per ptCi/m 3 . Factors are included in the Canberra Source Code file.

DOMINION VPAP-2103S I

REVISION 15 PAGE 28 OF 73 Rli, 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 mremnyr per gCi/m 3 . Factors are included in the Canberra Source Code file. o 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 I 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 I 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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DOMINION VPAP-2103S REVISION 15 PAGE 29 OF 73

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 15 PAGE 30 OF 73

b. Examples of continuous releases include: I

" 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.

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DOMINION VPAP-2103S REVISION 15 PAGE 31 OF 73

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 Operations Shift Supervision 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 15 PAGE 32 OF 73 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources I 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 I 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).

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DOMINION VPAP-2103S REVISION 15 PAGE 33 OF 73

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. I

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) + ... >- Lo (16) reporting level (1) reporting level (2)

DOMINION VPAP-2103S I

REVISION 15 PAGE 34 OF 73

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 i 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 i 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 i 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.

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DOMINION VPAP-2103S REVISION 15 PAGE 35 OF 73

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 Reporf 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.

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DOMINION VPAP-2103S I

REVISION 15 PAGE 36 OF 73

b. Action

1. Analyses shall be performedat least semi-annually as follows:

Program Cross-Check of Milk 1131, Gamma; Sr 89 and Sr 90 Water Gross Beta, Gamma, 1131, H3 (Tritium), Sr 8 9 I and Sr 9 ° (blind-any combinations of above radionuclides) 9 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 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 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 I 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 15 PAGE 37 OF 73

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 reportithe 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.

h. Results of analysis of ground water wells described in the environmental monitoring program, whether required by the program or not.

DOMINION VPAP-2103S REVISION 15 PAGE 38 OF 73 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 I 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 I

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, 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 Condition Report and involve the I 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 15 PAGE 39 OF 73

4. Major changes to radioactive liquid, gaseous, andsolid 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).

7. A summary of radioactive leaks or spills meeting the following criteria:

- An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, and

- The spill or leak must be greater than 100 gallons in volume or the volume cannot be quantified but is estimated to be greater than 100 gallons; or

- Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

8. Groundwater sample results from locations not part of the Radiological Environmental Monitoring Program.

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.

DOMINION VPAP-2103S I

REVISION 15 PAGE 40 OF 73 NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI I

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.

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. Approved by the Site Vice President before implementation.

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

Documentation shall include: i

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

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DOMINION VPAP-2103S REVISION 15 PAGE 41 OF 73

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 VPAPM2802, Notifications and Reports.

6.7.5 Industry Ground Water Protection Initiative

a. Program The Ground Water Protection Program is established in Administrative Procedure RP-AA-502, Groundwater Protection Program.

NOTE: RP-AA-502 Attachment 1, Voluntary Communication Protocol, contains a flow chart to assist with determining if an event should be communicated to State and Local officials and to the NRC.

b. Communications

1. Informal communication shall be made to the State, Local and NRC officials by the end of the next business day for any spill or leak meeting the requirements of 6.7.2.a.7.

DOMINION VPAP-2103S I

REVISION 15 PAGE 42 OF 73

2. Informal communication shall be made to the State, Local and NRC officials by the end of the next business day for a water sample result that meets the following criteria:

An off-site ground water or surface water sample result that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10).

An on-site surface water sample result, that is hydrologically connected to ground water, or ground water that is or could be used as a source of drinking water, that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10).

c. 30-Day Reports

1. Submit a written 30-day report to the NRC for a water sample result for on-site or off-site ground water that is or could be used as a source of drinking water that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 10). A 30-day report is only required on the initial discovery of a contaminated ground water plume.

2. Concurrently submit a copy of the written 30-day NRC report to the appropriate State and Local officials.

d. Annual Reports

1. Report sample results communicated per 6.7.5.b.1 in the Annual Radiological Effluent Release Report.

2. Report ground water sample results that are not included in the Radiological Environmental Monitoring Program in the Annual Radiological Effluent Release Report.

3. Report sample results communicated per 6.7.5.b.2 in the Annual Radiological Effluent Release Report or the Annual Radiological Environmental Operating Report.

4. Report ground water sample results that are included in the Radiological Environmental Monitoring Program in the Annual Radiological Environmental Operating Report.

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DOMINION VPAP-2103S REVISION 15 PAGE 43 OF 73 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, 'andcalibrations 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 15 PAGE 44 OF 73 ATTACHMENT 1 (Page 1 of 1)

I Radioactive Liquid Effluent Monitoring Instrumentation I

Instrument Minimum Operable Channels Action I

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

2.

RE-RRM- 131 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 I -SW-RM- 107C 1

1 2

2 I

1 3.

I-SW-RM-107D FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 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 I

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 15 PAGE 45 OF 73 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, RE-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: I-SW-RM-120 D M R Q Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, I-SW-RM- 107A I-SW-RM- 107B D M R Q I-SW-RM-107C I-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 15 PAGE 46 OF 73 I

ATTACHMENT 3 (Page 1 of 3)

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

(DCi/mL), (Note 1)

I p P Principal Gamma 5 X 10-7 I Emitters (Note 3)

(Each Batch) p (Each Batch) 1131 Dissolved and 1 x 10-6 I

Batch Releases M Entrained Gases (Gamma Emitters)

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

P Q Composite Sr 89 and Sr 9 0 5 x 10-8 1

(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) V131 1 x 10-6 I Continuous M Dissolved and Contnuos M M Releases Grab Sample Entrained Gases (Gamma Emitters) 1 x 10-I (Note 5) Continuous M Composite H3 I x 10-5 (Note 6) (Note 6) Gross Alpha I x 10-7 I

Continuous Q Composite Sr 8 9 and Sr 9 0 5 x 10-8 I Fe 55 (Note 6) (Note 6) I x 10-6 I

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DOMINION VPAP-2103S REVISION 15 PAGE 47 OF 73 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):

4.66sb LLD = (8-1)

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 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable)

X = the radioactive decay constant for the particular radionuclide At = the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and At should be used in the calculation.

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S I

REVISION ,15 PAGE 48 OF 73 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 54 , Fe 59 , Co 5 8 , Co 6W, Zn 65 , Mo 99 , Cs134, CS 137 , Ce 14 1, and I 14 4 Ce . 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 I 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 15 PAGE 49 OF 73 ATTACHMENT 4 (Page 1 of 4)

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

(ýtCi/mL), (Note 1)

A. Waste Gas Prior to Release Prior to Release Principal Gamma Storage Tank (Each Tank) (Each Tank) Emitters (Note 2)

(Grab Sample)

Prior to Release Prior to Release Principal 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 Principal 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 106 (4)SRF Vent 131 1 x 10-12 Continuous Weekly (Note 5)

(Note 4) (Charcoal Sample) V33 I x 10-10 Continuous Weekly (Note 5) Principal Gamma x All Release (Note 4), Particulate Sample Emitter (Note 2)

Weekly Types as listed Continuous Composite Gross Alpha I x 10-l (Note 4) Particulate Sample in A, B, and C Quarterly Continuous Composite Sr 8 9 and Sr 90 I x 10-11 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross I x 10-6 (Note 4) Beta and Gamma

Weekly Weekly Principal 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 I

REVISION 15 PAGE 50 OF 73 I 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 (pCi/mL), (Note 1)

Prior to Release Prior to Release Principal Gamma Emitters 1 X 10-4 I (Grab Sample) (Each Release) H3 1 x 10-6 i

Charcoal Sample V31 1 x 10-11 Containment Continuous (Note 4) (Note 6) i133 1 x 10-10 i Hog Depres- Continuous (Note 4)

Particulate Sample Principal Gamma (Note 6) Emitter (Note 2)

I x 1010 I surization Continuous Composite Particu-Cotinuus late Sample Gross Alpha 1x S(Note 4) (Note 6) l0-10 I

Continuous Composite Particu-late Sample (Note 6)

Sr 89 and Sr 90 1 x 10-10 I

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DOMINION VPAP-2103S REVISION 15 PAGE 51 OF 73 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)

E

V o 2.22E+06

Y

e-(k(1t)

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).

X = the radioactive decay constant for the particular radionuclide.

At = the elapsed time between the midpoint of sample collection and time of counting.

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

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S m

REVISION 15 PAGE 52 OF 73 ATTACHMENT 4 (Page 4 of 4) 1 Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr 87 , Kr 8 8, Xe 13 3 , Xe13 3 m, Xe 135 , XeI35m, and Xe 13 8 for gaseous emissions and Mn 5 4 , Fe 5 9 , Co 5 8, Co 6 0 , Zn 6 5 , Mo 9 9 , Cs 134, Cs 137 , 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: I

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. m 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for 24 I

hours are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant 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.

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DOMINION VPAP-2103S REVISION 15 PAGE 53 OF 73 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- I 30B I (b) Iodine Sampler:

Continuous HP Sampler, or I-GW-RM-130-1 (NOTE 1) 1 2 In-Line Particulate / Iodine Sampler (c) Particulate Sampler:

Continuous HP Sampler, or I-GW-RM-130-1 (NOTE 1) 1 2 In-Line Particulate / Iodine Sampler (d) Process Vent Flow Rate Monitor:

I-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:

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

Unit 1: 1-VP-Fl-IA 1 3 1-VP-Fl-I B 1 3 Unit 2: 2-VP-Fl-IA 1 3 2-VP-FI-I B 1 3

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

SRF: RRM-l101 1 1 SPS: Vent #1, 1-VG-RM-104 1 1 Vent #2, I-VG-RM-131B I I (b) Iodine Sampler:

SRF: RRM-101 1 2 SPS: Vent #1, I-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP Sampler, or I -VG-RM- 131 -1 (NOTE 1) 2 In-Line Particulate / Iodine Sampler

DOMINION VPAP-2103S REVISION 15 PAGE 54 OF 73 ATTACHMENT 5 (Page 2 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM I INSTRUMENT OPERABLE ACTION (c) Particulate Sampler:

SRF: RRM-101 CHANNELS I

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

Vent #2, HP Continuous Sampler, or 1-VG-RM-131-1 (NOTE 1) 1 1

2 2

I (d)

In-Line Particulate / Iodine Sampler Ventilation Vent Flow Rate Monitor:

SRF: 01-RHV-FT-156 1 3 I

SPS: Vent #1, 1-VS-FT-119 1 I

3 Vent #2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device:

SRF: RRM-101 1 3 SPS: Vent #1, I-VG-RM-104 (NOTE 2)

Vent #2, HP Sampler Rotometer or MGPI Flow Rate Measuring Device 1

1 3

3 I NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components.

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring I

Instrumentation Sampling Schedule" attachment in HP-3010.031, 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 U

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

I ACTION 3:

[Commitment 3.2.4]

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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

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DOMINION VPAP-2103S REVISION 15 PAGE 55 OF 73 ATTACHMENT 6 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST I. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor -

Providing Alarm and Automatic Termination of Release l -GW-RM- 130B D M R Q (b) Iodine Sampler (NOTE 1)

Process Vent Continuous HP Sampler, or l-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 I-GW-RM-130-1 W N/A N/A N/A In-Line Particulate / Iodine Sampler (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 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- IA

-VP-Fl-ID N/A R N/A Unit 2: 2-VP-FI-IA 2-VP-FI-I B

3. VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor SRF: RRM-101 SPS: 1-VG-RM-131B D M R Q I -VG-RM- 104 F

DOMINION VPAP-2103S I

REVISION 15 PAGE 56 OF 73 U ATTACHMENT 6 (Page 2 of 2) i Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements I

CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION (b) Iodine Sampler (NOTE 1)

CHECK CHECK CALIBRATION FUNCTIONAL TEST I SRF: RRM-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP I

Sampler or I-VG-RM- 13 1-1 In-Line Particulate / Iodine Sampler I

(c) Particulate Sampler (NOTE 1)

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

Vent #2, Continuous HP W N/ N/AN/A Sampler or 1-VG-RM- 131 -1 In-Line Particulate / Iodine Sampler I

(d) Ventilation Vent Flow Rate Monitor SRF:01-RHV-FT- 156 SPS: Vent #1, 1-VS-FT-119 D N/A R N/A I

Vent #2, 1-VS-FT-I116 (e) Sampler Flow Rate Measuring I

Device (NOTE 1)

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

D N/A N/A R

R N/A N/A I

Vent #2, HP Sampler Rotometer D N/A R N/A or MGPI Flow Rate Measuring Device D N/A SA N/A I

NOTE 1:The mark numbers listed above in l(b), 1(c), 3(b), 3(c), and 3(e) refer to the gaseous I

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

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DOMINION VPAP-2103S REVISION 15 PAGE 57 OF 73 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) I 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 around weekly analysis following filter the Station change; c) 1 sample from a control Gamma isotopic analysis location 15-30 km of composite (by distant, providing valid location) quarterly I background data

DOMINION VPAP-2103S i

REVISION 15 PAGE 58 OF 73 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) I sample upstream I sample downstream Monthly Sample Gamma mnhy isotopic analysis monthly; Composite for tritium analysis I

b) quarterly Gamma isotopic and tritium I

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

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

d) Silt a) b)

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

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of I

the Station. (NOTE 1) Gamma isotopic and 1131 b) I sample from milking animals at a control location (-15-30 km Monthly analysis monthly I distant). (NOTE 2) a) 2 samples of oysters in the vicinity of the Station Semi-Annually I b) Fish and Invertebrates b) 4 samples of clams in the vicinity of the Station c) I sampling of crabs from Semi-Annually Gamma isotopic on edible portions I

Annually d) the vicinity of the Station 1 sampling of 2 different I

species from the discharge Semi-Annually canal (catfish, white perch, NOTE 1:

eel)

If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed I

when there are no milk sampling locations in the vicinity of the Station. I NOTE 2: If milk sampling from a control location cannot be performed, use item 4.c) e).

Milk sampling cannot be performed when there is no milk sampling location 30 km distant.

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DOMINION VPAP-2103S REVISION 15 PAGE 59 OF 73 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 tions por 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 I131 available, or at analis milk sampling is not harvest analysis performed.

.e) I 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 i

REVISION 15 PAGE 60 OF 73 ATTACHMENT 8 (Page 1 of 3)

I Environmental Sampling Locations I

SAMPLE MEDIA LOCATION DISTANCE (MILES)

DIRECTION REMARKS I

Air Charcoal and Surry Station Particulate (SS)

Hog Island Reserve (HIR) 0.3 2.0 NNE NNE I Bacon's Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW I Colonial Parkway (CP) 3.8 NNW BASF Fort Eustis (BASF)

(FE) 5.1 4.9 ENE ESE I

Environmental Newport News Control (NN)

(00) 19.3 SE Control Location Onsite

I TLDs West North West (02) 0.2 WNW Site Boundary Surry Station Discharge (03) 0.4 NW Site Boundary I North North West North (04)

(05) 0.2 0.3 NNW N

Site Boundary Site Boundary I

North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary I East North East (08) 0.4 ENE Site Boundary East West (09)

(10) 0.3 0.1 E

W Site Boundary Site Boundary 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 15 PAGE 61 OF 73 ATTACHMENT 8 (Page 2 of 3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA I (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 Epps 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 S Control Location

DOMINION VPAP-2103S I

REVISION 15 PAGE 62 OF 73 1 ATTACHMENT 8 (Page 3 of 3)

I Environmental Sampling Locations II SAMPLE MEDIA LOCATION DISTANCE (MILES)

DIRECTION REMARKS II Well Water Surry Station Hog Island Reserve 2.0 NNE Onsite**

I Construction Site 0.3 E Onsite***

Crops (Corn, Peanuts, Slade's Farm 3.2 S I Soybeans)

River Water Brock's Farm Surry Discharge 3.8 0.4 NW S

I (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment (Silt)

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

Hog Island Point Lawne's Creek 2.4 2.4 NE SE I Oysters Point of Shoals 6.4 SSE Crabs Mulberry Point Surry Station Discharge 4.9 1.3 ESE NNW II 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

Onsite sample of Well Water taken from tap-water at Surry Training Center I

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DOMINION VPAP-2103S REVISION 15 PAGE 63 OF 73 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/m3 ) _ _(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 15 PAGE 64 OF 73 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 -- (24-1)

E

V

2.22E+06

Y 9 e-(XLAt)

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 15 PAGE 65 OF 73 ATTACHMENT 10 (Page 1 of 1)

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

H-3 20,000*

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 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

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 30,000 pCi/L for H-3 and 20 pCi/L for 1- 131.

DOMINION VPAP-2103S REVISION 15 PAGE 66 OF 73 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 I 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, I 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 1 5 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 C Ia and Ci b) 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 m 2 containment minimum i 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.

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DOMINION VPAP-2103S REVISION 15 PAGE 67 OF 73 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 11 A-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-0 133, "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 1.6E-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.

DOMINION VPAP-2103S I

REVISION 15 PAGE 68 OF 73 ATTACHMENT 11 (Page,3 of 8) I 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 1.4E-10 per m 2 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 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. 3 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 I were compiled from the Surry PowerStation 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 15 PAGE 69 OF 73 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 0.222 hours 0.00132 weeks 3.044e-4 months per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months 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 15 PAGE 70 OF 73 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.

3.2 Data, Parameters, and Methodology Five year average XIQ 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, 13, 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 15 PAGE 71 OF 73 ATTACHMENT 11 (Page 6 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The maximum exposed individual for 10 CFR 50, 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-0 133 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 Kip, , 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 dosefactor for particular age group for the ith radionuclide, in mrem/pCi Parameters used above were obtained from NUREG-0 133, 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 0.0444 hours 2.645503e-4 weeks 6.088e-5 months 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 REVISION 15 PAGE 72 OF 73 ATTACHMENT 11 (Page 7 of 8) 1 Meteorological, Liquid, and Gaseous Pathway Analysis The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation:

RM. = KQF(aP) (1-fpfse-_

Rvi UK Q Fm (r) (DFLi)L fu+ e-kitf (28-2)h]

S WYp Ys where: I K' = a constant of unit conversion, I E+ 12 pCi/Ci QF = cow's consumption rate, 50, in kg/day (wet weight)

Uap= infant milk consumption rate, 330, in liters/yr Yp = agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Ys = agricultural productivity by unit area of stored feed, 2.0, in kg/m2 Fm= stable element transfer coefficients, in days/liter 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

.w = decay constant for removal of activity of leaf and plant surfaces by weathering, 5.73E-07 sec-I (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) I fs = 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, I and LADTAP II, NUREG/CR-1276.

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DOMINION VPAP-2103S REVISION 15 PAGE 73 OF 73 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:

RH3 = KK 'FmQFUap(DFLH 3) [0.75 (0.5/H)] (28-3) where:

K"'=a constant of unit conversion IE+03 gm/kg H = absolute humidity of the atmosphere, 8.0, in 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:

RIi 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. I and LAPTAP II, NUREG/CR- 1276.

Attachment 4 Page 1 of I 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 DETECTIONI(LLD) FOR EFFLUENT SAMPLE ANALYSIS GASEOUS: Isotope Required LLD Typical LLD Kr-87 1.OOE-04 2.01E 2.43E-06 Kr-88 1.OOE-04 2.02E 3.19E-06 Xe-133 1.OOE-04 1.09E 2.44E-06 Xe-133m 1.OOE-04 3.64E 8.08E-06 Xe-135 1.OOE-04 4.17E 9.72E-07 Xe-135m 1.OOE-04 2.06E 4.57E-06 Xe-138 1.OOE-04 7.89E 9.25E-06 1-131 1.OOE-12 4.16E 9.58E-14 1-133 L.OOE-10 8.72E-13 2.59E-12 Sr-89 1.OOE- 11 3.49E 2.38E-13 Sr-90 1.OOE- 11 1.23E 2.22E-13 Cs-134 I.O0E-I1 3.24E 3.71E-13 Cs-137 1.OOE-11 5.89E 5.13E-13 Mn-54 1.OOE-11 3.67E 5.44E-13 Fe-59 1.OOE-11 8.OOE 6.72E-13 Co-58 1.OOE-11 2.93E 3.33E-13 Co-60 1.OOE-11 3.90E 6.60E-13 Zn-65 1.OOE- 11 6.13E 8.77E-13 Mo-99 1.OOE-11 2.60E 3.23E-12 Ce-141 1.OOE- 11 3.95E 3.62E-13 Ce-144 1.OOE-1 1 1.81E 1.48E-12 Alpha 1.OOE-11 1.79E 1.86E-14 Tritium 1.OOE-06 7.49E 7.61E-08 LIQUID Sr-89 5.OOE-08 1.8 1E-09 - 2.53E-08 Sr-90 5.OOE-08 1.04E-09 - 2.11E-08 Cs-134 5.OOE-07 7.86E-09 - 1.53E-08 Cs-137 5.OOE-07 1.31E-08 - 1.91E-08 1-131 1.OOE-06 6.39E-09 - 1.91E-08 Co-58 5.00E-07. 6.5 1E-09 - 1.56E-08 Co-60 5.OOE-07 6.55E-09 - 2.90E-08 Fe-59 5.OOE-07 1.35E-08 - 2.87E-08 Zn-65 5.OOE-07 1.20E-08 - 3.90E-08 Mn-54 5.OOE-07 8.07E-09 - 1.56E-08 Mo-99 5.00E-07 4.85E-08 - 3.12E-07 Ce-141 5.OOE-07 1.08E-08 - 2.01E-08 Ce-144 5.OOE-07 4.60E-08 - 7.96E-08 Fe-55 1.OOE-06 1.OOE-07 - 9.67E-07 Alpha 1.OOE-07 2.91E-08 - 2.92E-08 Tritium 1.OOE-05 1.86E-06 - 1.89E-06 Xe-133 1.OOE-05 1.74E-08 - 3.45E-08 Xe-135 1.OOE-05 5.92E-09 - 1.07E-08 Xe-133m 1.OOE-05 5.44E-08 - 9.72E-08 Xe-135m 1.OOE-05 2.8 1E-07 - 7.20E-07 Xe-138 1.OOE-05 1.17E-06 - 2:02E-06 Kr-87 1.OOE-05 2.74E-08 - 4.42E-08 Kr-88 1.OOE-05 2.96E-08 - 4.75E-08

Attachment 8 Page 1 of 2 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 leaks communicated in accordance with the Initiative reporting protocol in 2008. The following is a summary of 2008 sample analyses of ground water monitoring wells that are not a part of the REMP. Analyses are performed by an independent laboratory.

Well Sample Tritium Gamma Fe-55 Ni-63 Sr-89 Sr-90 Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-P01 2/25/08 <303 ND NA NA NA NA 1-PL-Piez-P02 2/25/08 <299 ND NA NA NA NA 1-PL-Piez-P03 2/25/08 <581 ND NA NA NA NA 1-PL-Piez-P04 3/6/08 <580 ND NA NA NA NA 1-PL-Piez-P05 3/6/08 14,700 ND <92.7 <28.0 <0.397 <0.574 1-PL-Piez-P06 3/10/08 2,170 ND <88.9 <29.7 <0.42 <0.991 1-PL-Piez-P07 3/5/08 <597 ND NA NA NA NA 1-PL-Piez-P08 3/4/08 <577 ND NA NA NA NA 1-PL-Piez-P09 3/3/08 <577 ND NA NA NA NA 1-PL-Piez-P20 2/26/08 <298 ND NA NA NA NA 1-PL-Piez-P21 2/26/08 <301 ND NA NA NA NA 1-PL-Piez-P22 2/27/08 <301 ND NA NA NA NA 1-PL-Piez-P23 3/4/08 <566 ND NA NA NA NA 1-PL-Piez-P24 3/4/08 <565 ND NA NA NA NA 1-PL-Piez-P25 3/4/08 <583 ND NA NA NA NA 1-PL-Piez-P27 3/5/08 <573 ND NA NA NA NA 1-PL-Piez-P28 2/27/08 <303 ND NA NA NA NA 1-PL-Piez-P29 3/10/08 10,700 ND <76.4 <28.6 <0.481 <0.823 1-PL-Piez-P33 3/14/08 <371 ND NA NA NA NA 1-PL-Piez-P34 3/14/08 <311 ND NA NA NA NA 1-PL-Piez-P35 3/14/08 <319 ND NA NA NA NA 1-PL-Piez-P36 3/14/08 <318 ND NA NA NA NA 1-PL-Piez-P37 3/14/08 <307 ND NA NA NA NA 1-PL-Piez-P38 3/14/08 <309 ND NA NA NA NA NTD = Nn clthfirtnihl anmmn i-mittina niwlidlp* Annplrv] tn PF1MP T T 1-g JL.JJL.I*

NA = Analysis not required.

Attachment 8 Page 2 of 2 INDUSTRY GROUNDWATER PROTECTION INITIATIVE Well Sample Tritium Gamma Designation Date pCi/Liter pCi/Liter 1-PL-Piez-P04 9/8/08 <392 ND 1-PL-Piez-P05 9/8/08 17,200 ND 1-PL-Piez-P06 9/8/08 2,320 ND*

1-PL-Piez-P07 9/11/08 558 ND 1-PL-Piez-P07* 9/11/08 <472 ND 1-PL-Piez-P24 9/18/08 <218 ND 1-PL-Piez-P25 9/11/08 <397 ND 1-PL-Piez-P27 9/11/08 <393 ND 1-PL-Piez-P29 9/8/08 9,570 ND 1-PL-Piez-P33 8/29/08 <399 ND 1-PL-Piez-P34 8/29/08 <393 ND 1-PL-Piez-P39 8/21/08 <193 ND 1-PL-Piez-P40 8/21/08 <200 ND 1-PL-Piez-P41 8/21/08 <196 ND 1-PL-Piez-P42 8/21/08 <224 ND

Verification analysis. Laboratory prepared second sample for analysis.

Well Sample Tritium Gamma Designation Date pCi/Liter pCi/Liter 1-PL-Piez-P04 11/24/08 <408 ND 1-PL-Piez-P05 11/20/08 17,900 ND 1-PL-Piez-P06 11/20/08 2,430 ND 1-PL-Piez-P07 11/24/08 <480 ND 1-PL-Piez-P27 11/24/08 <420 ND 1-PL-Piez-P29 11/20/08 9,710 25.6*

1-PL-Piez-P33 11/12/08 <375 ND 1-PL-Piez-P34 11/12/08 <380 ND 1-PL-Piez-P41 11/12/08 <372 ND 1-PL-Piez-P42 11/12/08 <374 ND

Verification of the Co-60 could not be performed as the sample was consumed by the original analysis. Previous and subsequent samples have not identified Co-60.

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