ML111010015

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Submittal of Annual Radioactive Effluent Release Report for 2010
ML111010015
Person / Time
Site: Rancho Seco
Issue date: 03/30/2011
From: Ronningen E
Sacramento Municipal Utility District (SMUD)
To:
Document Control Desk, NRC/FSME
References
DPG 11-157
Download: ML111010015 (51)
v • d • e


Text

SACRAMENTO MUNICIPAL UTILITY DISTRICT The Power To Do More.

P.O. Box 15830, Sacramento, CA 95852-1830; 1-888-742-SMUD (7683)

DPG 11-157 March 30, 2011 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR 2010 Attention: John Hickman In accordance with 10 CFR 50.36a(a)(2) and Rancho Seco Quality Manual, Appendix A, Section 1.5.3, we are submitting the Rancho Seco 2010 Annual Radioactive Effluent Release Report for the period of January 1 through December 31, 2010. There was one revision to the Offsite Dose Calculation Manual (ODCM) made during 2010, included as Attachment 1.

If you or members of your staff have questions requiring additional information or clarification, please contact me at (916) 732-4817.

Sincerely, EinarT. RZnningen Superintendent, Rancho Seco Assets Cc: NRC, Region VI RANCHO SECO NUCLEAR PLANT - 14440 Twin Cities Road, Herald, CA 95638-9799: (209) 333-2935

RANCHO SECO NUCLEAR GENERATING STATION LICENSE NUMBERS DPR-54 and SNM-2510 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE OF CONTENTS INT RO DUC T ION ........................................................................................................................................... 1 SUPPLEMENTAL INFORMATION .............................................................................................. 2 A. Regulatory Limits & Guidelines for Effluent Releases .................................................... 2 B. Maximum Effluent Concentrations .................................................................................. 3 C. Measurement Methods for Total Radioactivity ............................................................... 3 D. Batch Releases (via monitored pathways) .................................................................... 4 E. Unplanned Releases .................................................................................................... .. 5 F. Radioactive Effluent Monitoring Instrumentation Inoperable for Greater Than 30 D a y s ..................................................................................................................................... 5 I1. E S T IMA T IO N O F E R R O R ................................................................................................................ 6 III. G A S EO US EFFLU ENTS .......................................................................................................... 7 TABLE Ill-A: GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES .................................. 8 TABLE Ill-B: GASEOUS EFFLUENTS - GROUND LEVEL RELEASES ......................................... 9 TABLE Ill-C: GASEOUS EFFLUENTS - TYPICAL LOWER LIMITS OF DETECTION ................. 10 TABLE III-D: RADIOLOGICAL IMPACT ON MAN DUE TO GASEOUS EFFLUENT R E LEA S E S ........................................................................................................................ 11 IV. LIQ UID E F F LU E NT S ..................................................................................................................... 12 TABLE IV-A: LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES ................................. 13 TA BLE IV -B: LIQ UID EFFLU ENTS ............. ............. 14.....................

14 TABLE IV-C: LIQUID EFFLUENTS - TYPICAL LOWER LIMITS OF DETECTION .................. 15 TABLE IV-D: RADIOLOGICAL IMPACT ON MAN DUE TO LIQUID EFFLUENT R E LE A S E S ........................................................................................................................ 16 V. S O LIDW AS T E ............................................................................................................................... 17 ATTACHMENTS

1. Off-Site Dose Calculation Manual, Revision 23

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 INTRODUCTION Rancho Seco Nuclear Generating Station (RSNGS) Unit No. 1 is located in Sacramento County, California approximately 25 miles southeast of Sacramento and 26 miles north-northeast of Stockton.

Rancho Seco Unit No. 1 began commercial operation on April 17, 1975. The single unit on the Rancho Seco site was a pressurized water reactor supplied by Babcock and Wilcox. The rated capacity was 913 megawatts electrical. Because of a public vote on June 6, 1989, Sacramento Municipal Utility District (SMUD) shutdown the Rancho Seco Nuclear Generating Station and completed defueling operations on December 8, 1989. Transfer of the spent fuel rod assemblies from the Spent Fuel Pool into dry storage at the Independent Spent Fuel Storage Installation (ISFSI) was completed on August 21, 2002.

Radiological dismantlement of the nuclear facility was completed in December 2008 and the release of the Rancho Seco property, except for the area associated with the Interim Onsite Storage Installation (IOSB), from NRC license DPR-54 was approved on September 25, 2009. With the completion of Phase I of decommissioning, the facility is in a SAFSTOR-type condition awaiting a suitable disposal option for the low-level radioactive waste in storage in the IOSB.

This Annual Radioactive Effluent Release Report (ARERR) provides a summary of gaseous and liquid effluent releases made from Rancho Seco during the period of January 1 through December 31, 2010.

This report also provides a summary of solid radioactive waste shipments during the reporting period.

In the current condition, there are no radioactive liquids or liquid systems at the facility, and all solid material is stored in containers designed for shipping the material. Therefore, there is no projected need to process or otherwise handle the material in storage at the Rancho Seco facility and therefore little probability that any material would be released from the facility in liquid or gaseous effluents.

Accordingly, there were no radioactive liquid or gaseous effluent releases made from Rancho Seco during the reporting period. In addition, no shipments of solid radioactive waste were made during the reporting period.

This report has been prepared by SMUD to meet the requirements of Rancho Seco Quality Manual (RSQM), Appendix A, Section 1.5.3 and Offsite Dose Calculation Manual (ODCM) Revision 23, Step 6.12. It is presented in accordance with the format of USNRC Regulatory Guide 1.21. Radiation doses associated with radioactive effluents in liquids and gasses would be calculated for a hypothetical individual who receives the maximum possible exposure at or beyond the applicable Site Boundary, had any releases occurred.

Since there were no releases of radioactivity in gaseous and liquid effluents during this report period, the limits of 10 CFR 20 were not exceeded, nor were the numerical guidelines of 10 CFR 50, Appendix I exceeded. A 40 CFR 190 dose evaluation is not required because radioactive effluent releases did not exceed twice the numerical guidelines of 10 CFR 50, Appendix I.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 SUPPLEMENTAL INFORMATION A. Regulatory Limits & Guidelines for Effluent Releases

1. Gaseous Effluents
a. Dose rate limit at.or beyond the Site Boundary for Gaseous Effluents for Tritium and
  • radioactive material in particulate form with half-lives greater than 8 days (ODCM Technical Requirement 6.9.3):

1500 mrem/year to any organ

b. Dose commitment to a member of the public at or beyond the Site Boundary for Gaseous Effluents from Tritium and radioactive material in particulate form with half-lives greater than 8 days (ODCM Technical Requirement 6.9.4, numerical guidelines of 10 CFR 50, Appendix I):

7.5 mrem per calendar quarter to any organ 15 mrem per calendar year to any organ

2. Liquid Effluents
a. The concentration of radioactive material in liquid effluents released beyond the Site Boundary for Liquid Effluents shall not exceed the limits of 10 CFR 20, Appendix B, Table 2, Column 2.
b. Dose commitment to a member of the public at or beyond the Site Boundary for Liquid Effluents from radioactive materials in liquid effluents shall be limited to (numerical guidelines of 10 CFR 50, Appendix I):

1.5 mrem per calendar quarter to the total body 5 mrem per calendar quarter to any organ 3 mrem per calendar year to the total body 10 mrem per calendar year to any organ NOTE: The noble gas source term was removed when spent fuel transfer to the ISFSI was completed in August 2002. Reference to noble gases was completely removed from the ODCM.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 B. Maximum Effluent Concentrations

1. Gaseous Effluents The concentrations listed in 10 CFR 20, Appendix B, Table 2, Column 1 (air) are not directly used in calculations for determining permissible gaseous effluent release rates.

The annual dose limits of 10 CFR 20 for unrestricted areas are the doses associated with the concentrations of 10 CFR 20, Appendix B, Table 2, Column 1. ODCM Technical Requirement dose rate limits (mrem/yr) for gaseous effluents are provided to ensure that the dose rate from gaseous effluents at any time at the Site Boundary for Gaseous Effluents will be within the annual dose limits of 10 CFR 20 for unrestricted areas. These dose rate limits (listed above in part A) are used for determining permissible gaseous effluent release rates.

2. Liquid Effluents The concentration values listed in 10 CFR 20, Appendix B, Table 2, Column 2 are used in calculations to determine permissible liquid discharge flow rates. The most conservative Maximum Effluent Concentration (MEC) value for each radionuclide detected in the liquid effluent sample is used in the calculations.

C. Measurement Methods for Total Radioactivity The methods listed below are examples should radioactive effluents be discharged.

1. Gaseous Effluents Liquid Scintillation (H-3)

Gamma Spectroscopy (HPGe)

Beta Proportional (Sr-90, gross beta)

Alpha Proportional (gross alpha)

2. Liquid Effluents Gamma Spectroscopy (HPGe)

Liquid Scintillation (H-3)

Beta Proportional (Sr-90, gross beta)

Alpha Proportional (gross alpha)

NOTE: HPGe refers to Hyper-Pure Germanium 3

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 D. Batch Releases (via monitored pathways)

Liquid Discharges Quarter 1 Quarter 2 Quarter 3 Quarter 4 1.

a. Number of batch releases 0 0 0 0
b. Total time period for batch releases (hours) N/A N/A N/A N/A
c. Maximum time period for a batch release (hours) N/A N/A N/A N/A
d. Average time period for a batch release (hours) N/A N/A N/A N/A
e. Minimum time period for a batch release (hours) N/A N/A N/A N/A
f. Average Plant Effluent Flow (cfs) N/A N/A N/A N/A 4

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 E. Unplanned Releases This section describes unplanned releases of radioactivity in liquid and gaseous effluent.

Gaseous None Liquid None F. Radioactive Effluent Monitoring Instrumentation Inoperable for Greater Than 30 Days None 5

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 I1. ESTIMATION OF ERROR The methods for establishing error estimates included review of applicable station procedures, inspection of sampling equipment, engineering estimates, statistical applications, review of calibration setpoint data, and communication with plant personnel. The various sources of error (s) in reported values of gaseous effluents, liquid effluents, and solid waste are assumed to be independent, and thus the total error is calculated according to the formula:

Total Error = V'122/ + C72 2+ + 2 "" + G 0.2 where: cy1 = relative error associated with component i Sources of error for gaseous effluents include fan error (flow), grab sampling, collection, filter efficiency, counting, and calibration.

Sources of error for liquid effluents include collection container volume, dilution water flow rate, grab sampling, counting, and calibration.

Sources of error for solid waste include offsite lab smear analysis, dose rate meter calibration, dose rate meter reading, computer program dose-to-curie calculation, sample volume measurement, gamma spec counting, gamma spec calibration, and waste volume determination.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 II1. GASEOUS EFFLUENTS Table Ill-A, Gaseous Effluents - Summation of All Releases, provides a detailed summary of gaseous effluent releases per quarter. This table summarizes releases of tritium and particulates with half-lives greater than 8 days. The methodology used to calculate the Percent of ODCM Technical Requirement limit is as follows:

Z [(Fi)(Avg Rel Rate)(X / Q)(Dose Factor)]

% Tech Req Limit =ix10 (Dose Rate Limit) 100%

where:

Fi = The fraction of the total number of Curies of nuclide i out of the total curies in that category for that quarter (unitless).

NOTE: Fj always equals 1.0 for H-3 because it is the only nuclide in the category.

I E + 06/,uCi (Total Curies per category per quarter Ci Avg Rel Rate =

(#seconds in the quarter)

X/Q = A default dispersion factor determined to be conservative when compared to the use of actual data (sec/m3).

Dose Factor = The values derived for each nuclide i from NRC Regulatory Guide 1.109 (Ki, Li+1.1Mi, or Raij). [Units in (mrem/yr)/(pCi/m3)]

Dose Rate Limit = The Technical Requirement (i.e., Regulatory) limits for dose rate listed in Section I of this report (mrem/yr).

NOTE: Particulates with half-lives less than 8 days are not included in this calculation.

The methodology used to calculate the Estimated Total Error (%) in Table Ill-A is presented in Section II of this report.

Table Ill-B, Gaseous Effluents - Ground Level Releases, provides a complete quarterly summary of the amount of radioactivity (Ci) released per radionuclide in each quarter. Data from continuous and batch releases are provided for particulates and tritium. Data reported for batch releases results only from unplanned releases.

Table Ill-C, Gaseous Effluents - Typical Lower Limits of Detection, provides a listing of the typical lower limit of detection (LLD) concentrations in pCi/cc for various radionuclides.

Table Ill-D, Radiological Impact on Man Due to Gaseous Effluent Releases, provides a summary of calculated radiation doses delivered to a maximum exposed hypothetical individual at the Site Boundary for Gaseous Effluents (actual doses will be assessed in the 2010 Annual REMP Report). The maximum calculated organ dose is listed for each quarter along with an annual total. The direct radiation dose results, based on monitoring badge dosimetry, are also listed. Presented in this table for each category is a comparison versus ODCM Technical Requirement dose limits with the exception of direct radiation measurements.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE Ill-A: GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES Est. Total Unit Quarter 1 Quarter 2 Quarter 3 Quarter 4 Error %

A. Particulates

1. Particulates with half-lives>8 days Ci 0.OOE+00 O.00E+00 0.OOE+00 0.OOE+00 N/A
2. Average Release Rate for period pCi/sec 0.00E+00 0.OOE+00 0.OOE+00 0.OOE+00
3. Percent of Tech Req limit  % N/A N/A N/A N/A
4. Gross Alpha radioactivity Ci 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00 B. Tritium
1. Total Release Ci 0.OOE+00 0.OOE+00 O.OOE+00 0.OOE+00 N/A
2. Average Release Rate for period pCi/sec 0.OOE+00 0.OOE+00 0.OOE+00 0.OOE+00
3. Percent of Tech Req limit  % N/A N/A N/A N/A 8

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE Ill-B: GASEOUS EFFLUENTS - GROUND LEVEL RELEASES Nuclides Released

1. Particulates None
2. Tritium None 9

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE Ill-C: GASEOUS EFFLUENTS - TYPICAL LOWER LIMITS OF DETECTION RADIONUCLIDES LLD (wCi/cc)

1. Tritium (H-3) 2.27 E-10
2. Particulates:

Manganese-54 2.08 E-12 Cobalt-58 2.29 E-12 Iron-59 5.89 E-12 Cobalt-60 3.11 E-12 Strontium-89 2.00 E-15 Strontium-90 5.00 E-15 Cesium-1 34 1.52 E-12 Cesium-1 37 1.88 E-12 Barium-140 3.06 E-12 Cerium-141 1.15 E-12 Cerium-144 3.69 E-12 10

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE III-D: RADIOLOGICAL IMPACT ON MAN DUE TO GASEOUS EFFLUENT RELEASES CALCULATED RADIATION DOSES AT THE SITE BOUNDARY FOR GASEOUS EFFLUENTS:

2010 Unit Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual A. Tritium, Particulate

1. Maximum Organ Dose mrem 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00
2. Percent Tech Req limit N/A N/A N/A N/A N/A B. Direct Radiation
1. Dose (Monitoring Badges)1 mrem 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00
2. Percent of Tech Req limit N/A N/A N/A N/A N/A NOTE: No releases of gaseous radioactive effluent were made from Rancho Seco Nuclear Generating Station in 2010.

None of the Indicator stations indicate significant radiation attributable to facility operations.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 IV. LIQUID EFFLUENTS Table IV-A, Liquid Effluents - Summation of All Releases, provides a detailed summary of liquid effluent releases per quarter. This table summarizes releases of fission and activation products, tritium, dissolved and entrained gases, and gross alpha radioactivity. Also listed is the volume of waste released prior to dilution and the volume of dilution water used during each quarter.

The following methodology is used to calculate the Average Diluted Concentration and the Percent of ODCM Technical Requirement Limit in Table IV-A:

%Tech Req Limit n c,~

where: n = The total number of radionuclides identified Ci = The average diluted concentration of radionuclide i (Total Release per Category per Quarter in puCi)

(Total Release Volume (part F in Table IV - A) in ml)

MECj = The MEC of the ith radionuclide, from 10 CFR 20, Appendix B, Table 2, Column 2 The methodology used to calculate the estimated total error in Table IV-A is presented in Section II of this report.

Table IV-B, Liquid Effluents, provides a complete quarterly summary of the amount of radioactivity (Ci) released per radionuclide in each quarter. Data is provided for fission and activation products, and for dissolved and entrainedgases. Tritium and gross alpha are not included in this table (they are listed in Table IV-A). Since no continuous releases of liquid radioactive effluent are made from RSNGS, data is provided only for batch releases.

Table IV-C, Liquid Effluents - Typical Lower Limits of Detection, provides a listing of the typical lower limit of detection (LLD) concentrations in pCi/ml for various radionuclides.

Table IV-D, Radiological Impact on Man Due To Liquid Effluent Releases, provides a summary of calculated radiation doses delivered to a maximum exposed hypothetical individual at the Site Boundary for Liquid Effluents (actual doses will be assessed in the 2010 Annual REMP Report). The maximum calculated total body dose and organ dose are listed for each quarter along with an annual total. A comparison versus ODCM Technical Requirement dose limits is also presented.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE IV-A: LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES Est. Total Unit Quarter 1 Quarter 2 Quarter 3 Quarter 4 Error, %

A. Fission & Activation Products

1. Total Release (not including tritium, gases, alpha) Ci 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 N/A
2. Average diluted concentration during period pCi/ml 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00
3. Percent of Tech Req limit  % N/A N/A N/A N/A B. Tritium
1. Total Release Ci 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 N/A
2. Average diluted concentration during period pCi/ml 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00
3. Percent of Tech Req limit  % N/A N/A N/A N/A C. Dissolved and Entrained Gases
1. Total Release Ci 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 N/A
2. Average diluted concentration during period pCi/ml 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 D. Gross Alpha radioactivity
1. Total Release Ci 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 N/A E. Volume of Waste Released (prior to dilution) Liters 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 N/A F. Volume of dilution water used during period Liters N/A N/A N/A N/A N/A 13

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE IV-B: LIQUID EFFLUENTS Nuclides Released

1. Fission and activation products (excluding tritium, gross alpha)

None

2. Dissolved and entrained gases None NOTE: No releases of liquid radioactive effluent were made from Rancho Seco Nuclear Generating Station in 2010.

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RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE IV-C: LIQUID EFFLUENTS - TYPICAL LOWER LIMITS OF DETECTION RADIONUCLIDES BATCH MODE: LLD (wCi/ml) 1 Tritium (H-3) 2.60 E-06

2. Particulates:

Manganese-54 2.11 E-09 Iron-59 3.71 E-09 Cobalt-57 2.12 E-09 Cobalt-58 1.93 E-09 Cobalt-60 1.98 E-09 Zinc-65 4.34 E-09 Strontium-90 5.00 E-10 Ruthenium-106 1.79 E-08 Silver-11Orn 1.94 E-09 Antimony-125 5.78 E-09 Cesium-1 34 1.93 E-09 Cesium-1 36 2.23 E-09 Cesium-137 2.30 E-09 Barium-140 7.75 E-09 Cerium-141 3.60 E-09 Cerium-144 1.59 E-08 15

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 TABLE IV-D: RADIOLOGICAL IMPACT ON MAN DUE TO LIQUID EFFLUENT RELEASES CALCULATED RADIATION DOSE COMMITMENTS FOR LIQUID EFFLUENTS:

2010 Unit Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual A. Maximum Total Body Dose mrem 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 Percent Tech Req limit N/A N/A N/A N/A N/A B. Maximum Organ Dose mrem 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 0.00 E+00 Percent Tech Req limit  % N/A N/A N/A N/A N/A 16

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 V. SOLID WASTE A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

1. Type of Waste:

Volume Total Est. Total (me) Activity Error (%)

(Curies)

A. Spent Resins, filter sludges, 0.00 E+00 0.00 E+00 N/A evaporator bottoms, etc.

B. Dry compressible waste, 0.00 E+00 0.00 E+00 N/A contaminated equipment, etc C. Irradiated components, 0.00 E+00 0.00 E+00 N/A control rods, etc.

D. Other (primary metals, 0.00 E+00 0.00 E+00 N/A valves, piping)

2. Estimate of major nuclide composition Category A and Category B waste Category A Category B Activity Percentage Activity Percentage Radionuclide (Ci) (%) (Ci) (%)

None

3. Estimate of major nuclide composition Category C and Category D waste Category C Category D Activity Percentage Activity Percentage Radionuclide (Ci) (%) (Ci) (%)

None 17

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010

4. Solid Waste Disposition Mode of Number of Shipments Transportation Destination None N/A N/A
5. Type of Container
a. Not applicable
6. Solidification Agent
a. Not applicable B. IRRADIATED FUEL SHIPMENTS (Disposition)

Number of Shipments None 18

RSNGS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT JANUARY - DECEMBER 2010 ATTACHMENT 1 Offsite Dose Calculation Manual, Revision 23

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 1 of 29 LEAD DEPARTMENT: EFFECTIVE DATE:

RP/ Chemistry 1/27/2010 SCOPE OF REVISION:

1. Revised Section 4.4 regarding Batch Release definitions
2. Revised Section 4.5 to indicate there are no continuous liquid or gaseous releases.
3. Deleted Section 4.10, Nuisance Releases.
4. Section 4.12, deleted Reactor Building as a Miscellaneous release and revised lOS Building to indicate it is a Miscellaneous Release only during activities which have the potential for a radioactive effluent release.
5. Deleted Section 4.14, Ventilation Exhaust Treatment System.
6. Deleted Section 4.15, Instrument Surveillance
7. Deleted Section 4.16, Surveillance Intervals
8. Deleted Section 4.17, REIMS
9. Deleted Section 4.18, Operable, Operability
10. Revised Section 5.1 to replace the Radiation Protection / Chemistry Superintendent with the Superintendent, Rancho Seco Assets. Deleted reference to REIMS, GASPAR, and LABTAP.
11. Deleted Section 5.2, CMRG.
12. Revised section 6.1.2, deleted the Reactor Building as a Miscellaneous Release and revised the lOS Building as a Miscellaneous Release.
13. Deleted Section 6.4, Liquid Dose Projections
14. Section 6.4.1, revised to indicate only gaseous pathway and flow rate is from lOS Building.

Removed reference to monitor set points.

15. Section 6.5 removed reference to Land Use Census and GASPAR and REIMS.
16. Deleted Section 6.9.2.
17. Revised Sections 6.9.5, 6.9.6, and 6.9.10 to delete reference to liquid effluents.
18. Deleted Section 6.11.2, Liquid Dose Calculations
19. Deleted Section 6.11.3, Radioactive Liquid Effluent Treatment.
20. Section 6.11.4, deleted reference to Reactor Building ventilation system.
21. Deleted Section 6.11.7, Ventilation Exhaust Treatment System.
22. Revised Section 6.11.8 to remove reference to liquid releases.
23. Revised 6.11.9 to delete reference to liquid releases and that gas doses are calculated only when releases occurring.
24. Revised Section 6.12 to deleted reference to liquid effluents.
25. Deleted Attachment 1, Dose Factor Parameters
26. Deleted Attachment 2, Atmospheric Dispersion and Deposition Parameters.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 2 of 29

27. Deleted Attachment 4, Site Boundary for Liquid Effluents.
28. Deleted Attachment 7, Liquid Effluent Monitoring Instrumentation
29. Deleted Attachment 8, Liquid Effluent Monitoring Instrumentation Surveillance Requirements.
30. Deleted Attachment 9, Liquid Sampling and Analysis Program.
31. Attachment 10, deleted Reactor Building from Table.
32. Attachment 11, page 1; deleted Reactor Building from sampling requirements, added note (d) to 'Type of Activity Analysis'.
33. Attachment 11, page 3; revised note (b) to indicate sampling will be during activities that have a potential for release, ventilation system may be operated during long term storage activities without sampling, dose calculations, surveillances, or reporting requirements.

Radiation Protection program may be used to evaluate airborne activity.

34. Attachment 11, page 3; added note (d) to indicate gross activity analysis, with a sensitivity of 1.0 E-12 pCi/cc may be used to evaluate gaseous effluent activity.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 3 of 29 TABLE OF CONTENTS SECTION PAGE 1.0 PURPO SE .................................................................................................................................. 6 2.0 SCO PE ...................................................................................................................................... 6

3.0 REFERENCES

/CO MMITM ENT DO CUM ENTS ...................................................................... 6 3.1 Com m itm ent Docum ents ..................................................................................................... 6 3.2 Reference Docum ents ..................................................................................................... 6 4.0 DEFINITIO NS ............................................................................................................................ 7 4.1 Mem ber of the Public .................................................................................................... 7 4.2 Occupational Dose ................................................................................................................. 8 4.3 Public Dose ............................................................................................................................ 8 4.4 Batch Release ....................................................................................................................... 8 4.5 Continuous Release ........................................................................................................ 8 4.6 Dilution Flow .......................................................................................................................... 8 4.7 Maxim um Exposed (Hypothetical) Individual ..................................................................... 8 4.8 RSNG S .................................................................................................................................. 9 4.9 Site Boundary ........................................................................................................................ 9 4.10 Unplanned Release ....................................................................................................... 9 4.11 M iscellaneous Release ................................................................................................... 9 4.12 Safety Factor (SF) .................................................................................................................. 9 5.0 RESPO NSIBILITIES .................................................................................................................. 9 5.1 Superintendent, Rancho Seco Assets ................................................................................. 9

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 4 of 29 TABLE OF CONTENTS (Continued)

SECTION PAGE 6.0 PROCEDURE ............................................................................................................................ 9 6.1 General Considerations ................................................................................................... 9 6.2 Liquid Dose Calculations .................................................................................................. 10 6.3 Maximum Effluent Concentrations (MECs) in Gaseous Effluents .................................... 11 6.4 Dose Rate Calculations .................................................................................................... 12 6.5 Organ Dose Calculations for Gaseous Effluents .............................................................. 13 6.6 Gas Dose Projections .......................................................................................................... 14 6.7 Fuel Cycle Dose ................................................................................................................... 15 6.8 EPA Reporting Requirements ........................................................................................... 15 6.9 Technical Requirements ................................................................................................. 15 6.9.1 Maximum Effluent Concentrations in Liquid Effluents .................................... 15 6.9.2 Gaseous Effluent Monitoring .......................................................................... 16 6.9.3 Gaseous Dose Rates ..................................................................................... 16 6.9.4 Gaseous Organ Dose ..................................................................................... 17 6.9.5 Fuel Cycle Dose .............................................................................................. 19 6.11.9 Quarter/Annual Dose Projections ................................................................. 20 6 .10 Re po rts .......................................................................................................................... 21 6.10.1 Annual Radioactive Effluent Release Report (ARERR) ................................. 21 6.10.2 30 Day Reports ............................................................................................. 22 7.0 RECORDS ............................................................................................................................... 22

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 5 of 29 TABLE OF CONTENTS (Continued)

ATTACHMENTS ATTACHMENT PAGE 1 SITE BOUNDARY FOR GASEOUS EFFLUENTS ................................................................... 23 2 ORGAN DOSE FACTORS FOR GASEOUS EFFLUENTS ..................................................... 24 3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ....................... 25 4 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM ........................ 26 5 ODCM REVISION REVIEW REQUIREMENTS ........................................................................ 29

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 6 of 29 1.0 PURPOSE The Off-site Dose Calculation Manual (ODCM) contains the methodology and parameters used in the calculation of off-site doses due to radioactive gaseous and liquid effluents. Methods are described for assessing compliance with the Technical Requirements in the ODCM as they apply to 10 CFR Parts 20.1301 and 20.1302, 10 CFR Part 50, Appendix I, 10 CFR 50.36a,and 40 CFR 190.10a for liquid and gaseous effluents. Additionally, the ODCM contains the Technical Requirements, which provide the Specifications, Applicability's, Actions, and Surveillance Requirements.

2.0 SCOPE This procedure functions as a manual that provides the basis for development of detailed implementing procedures that address dose calculations for liquid/ gaseous releases. Additionally, this manual provides the Technical Requirements that govern releases of liquid and gaseous radioactive releases off-site.

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 Commitment Documents 3.1.1 Code of Federal Regulations, Title 10, Chapter 1, Parts 20, 50.36a and Part 50, Appendix I 3.1.2 Rancho Seco Quality Manual (RSQM) 3.1.3 EPA 40 CFR Parts 302, 355 Reporting Requirements 3.1.4 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Plant Operations 3.2 Reference Documents 3.2.1 USNRC Regulatory Guide 1.109, Rev. 1, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, October 1977 3.2.2 W. C. Burke, et. al., Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, NUREG-0133, USNRC: NRR, October 1978 3.2.3 ORNL, User's Manual for LADTAP II, NUREG/CR-1276, May 1980 3.2.4 D. L. Strange, et. al., LADTAP-II, Technical Reference and User Guide, NUREG/CR-4013, Pacific Northwest Laboratory, April 1986 3.2.5 Eckerman, K. F., et. al., User's Guide to GASPAR Code, NUREG-0597, USNRC: NRR, June 1980, in RSIC CCC-463

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 7 of 29 3.2.6 USNRC Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors 3.2.7 USNRC 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 3.2.8 USNRC Regulatory Guide 4.1, Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants 3.2.9 REIMS Software Life Cycle Documents (Software Requirement Specification, Design Document, Acceptance Test Plan) 3.2.10 USNRC & Pacific Northwest Laboratory, TDMC Computer Code/Data Collections, XOQDOQ-82, Radiological Assessment Code System Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations 3.2.11 2006 Rancho Seco Biennial Land Use Census 3.2.12 RSNGS DSAR Chapters 11.1-11.5 3.2.13 RSNGS P&ID Drawing M-563, M-551, M-552 3.2.14 Pacific Northwest Laboratory, XOQDOQ: Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations 3.2.15 Congel, F. J., Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40 CFR Part 190), NUREG-0543, USNRC: NRR, February 1980 3.2.16 USNRC Generic Letter, 89-01, Dated January 31, 1989.

3.2.17 Rancho Seco REMP Manual 3.2.18 PDQ 92-063 3.2.19 RP.312.1.14, Occupational Radiation Exposure Limits and Extensions 4.0 DEFINITIONS 4.1 Member of the Public Means any individual except when that individual is receiving an occupational dose.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 8 of 29 4.2 Occupational Dose Means the dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation and/or to radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational dose does not include dose received from background radiation, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the public.

4.3 Public Dose Means the dose received by a Member of the Public from exposure to radiation and/or radioactive material released by a licensee, or to any other source of radiation under the control of a licensee. It does not include occupational dose or doses received from background radiation, as a patient from medical practices, or from voluntary participation in medical research programs.

4.4 Batch Release:

A Batch Release is a release of a discrete volume of radioactive liquid or gaseous materials. Batch releases are not expected to be made from RSNGS.

4.5 Continuous Release Continuous radioactive liquid or gaseous releases are not expected to be made from Rancho Seco Nuclear Generating Station (RSNGS).

4.6 Dilution Flow The volume or volume rate of fluid (liquid), which is added to a radiological release stream for the purpose of decreasing the concentration of the stream.

4.7 Maximum Exposed (Hypothetical) Individual The Maximum Exposed Individual is characterized as "maximum" with regard to food consumption, occupancy, and other usage or exposure pathway parameters in the vicinity of Rancho Seco that would represent an individual with habits greater than usually expected for the average of the population in general.

Maximum dose factor parameters will be determined using data from RG 1.109.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 9 of 29 4.8 RSNGS Rancho Seco Nuclear Generating Station 4.9 Site Boundary The Site Boundary is defined by the drawing in Attachment 1 4.10 Unplanned Release The unexpected release of radioactive materials to unrestricted areas in gaseous and liquid effluent. All unplanned releases shall be discussed in the Annual Radiological Effluent Release Report (ARERR) to the NRC.

4.11 Miscellaneous Release Release pathways, which are considered planned but are not defined explicitly with monitoring requirements in this procedure. These pathways contribute a relatively small percentage (<5%) to the annual dose limits but shall be tracked for effluent activity accounting and dose calculation purposes. Miscellaneous releases shall not be reported in the ARERR as abnormal or unplanned releases. The lOS Building is a Miscellaneous Release during activities which have the potential to release radioactive gaseous effluent.

4.12 Safety Factor (SF)

A number greater than unity used in calculations to introduce greater conservatism (larger margin of safety) to offset various uncertainties in instrumentation and methods.

Radiation Protection/Chemistry Supervision based on either analysis or professional judgment sets safety factors. Unless otherwise specified, the default value is two (2).

5.0 RESPONSIBILITIES 5.1 Superintendent, Rancho Seco Assets It is the responsibility of the Superintendent, Rancho Seco Assets for the following:

1) ODCM Revisions and Reporting the Revisions in the Annual Radioactive Effluent Release Report (ARERR)
2) ARERR Preparation and Submittal
3) Responsible for reviewing and accepting all changes to the ODCM 6.0 PROCEDURE 6.1 General Considerations 6.1.1 Liquid Effluent Pathways - No planned releases

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 10 of 29 6.1.2 Gaseous Effluent Pathways The Interim On-site Storage (lOS) Building is a Miscellaneous Release. Unplanned Releases shall be evaluated on a case-by-case basis.

6.1.3 Meteorological Data The atmospheric dispersion (X/Q) and deposition (D/Q) factors used in calculations involving airborne effluent are conservative default values. The default X/Q value is 1.OE-4 3 -2 sec/m , and the default D/Q value is 1.OE-6 m . These factors should be used to assess compliance with the gaseous effluent requirements in Section 6.9, and calculate the gaseous effluent dose reported in the ARERR.

6.1.4 Boundary The Site Boundary for Gaseous Effluents as shown in Attachment 1 is for all calculations involving gaseous effluents.

6.1.5 40 CFR 190 Compliance For the purposes of assessing compliance with 40 CFR 190, the MEMBER OF THE PUBLIC which received the most exposure may be determined using actual food consumption, actual occupancy rates, and dilution off-site from additional converging streams (verses assumptions used for a HYPOTHETICAL MAXIMUM EXPOSED INDIVIDUAL.

6.1.6 Computers vs. Manual Calculations Due to unlikelihood of any release manual calculations will be used.

6.2 Liquid Dose Calculations This section provides the methodology to demonstrate compliance with the Specification in Step 6.9.

Organ dose factors for liquid effluents have been determined for the MAXIMUM EXPOSED INDIVIDUAL were derived using equations and methods in Regulatory Guide 1.109, Rev. 1.

6.2.1 Liquid Effluent Dose Equation E x Aijap)

X(Q Daj =F

- P

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 11 of 29 Where:

Daj = Annual calculated dose (50 year dose commitment) to the organ (or total body) j of a maximally exposed individual of age group a (mrem/yr).

Q = Activity of isotope i released during the year (Ci/yr).

Aijap = dose factor for an organ (or total body) j for a person of age group a via pathway p due to isotope i (mrem-ft 3/Ci-sec).

F = Annual average discharge volumetric flow rate (effluent water plus dilution water) in ft3/sec.

Because the dose rate varies linearly with activity release rate, the dose for a shorter period of time (mrem) may be calculated by substituting the activity released (Ci) during that period for Q in the above equation. However, volumetric flow rates should not be averaged over a period less than a calendar quarter. More conservative flow rates are acceptable.

6.2.2 Gaseous Effluent Flow Rate The flow rate used in routine gaseous effluent calculations for the lOS Building pathway listed below is a conservative default value. This flow rate should be used to assess compliance with the gaseous effluent requirements in Section 6.9, and calculate the gaseous effluent dose reported in the ARERR.

The lOS Building gaseous effluent release point and maximum design flow rate used at RSNGS is as follows:

Interim On-site Storage Building Ventilation 8,050 CFM

  • The Interim On-site Storage (lOS) Building is not subject to continuous discharges of radioactivity. Because of the infrequency of a radioactive release, assessment will be done on each release according to administrative procedures.

6.3 Maximum Effluent Concentrations (MECs) in Gaseous Effluents In order to demonstrate compliance with 10 CFR 20.1301, which requires that the total MEC fraction not exceed 1 when averaged over an entire year, the calculation is included in the Annual Radioactive Effluent Release Report. In addition, a four hour reporting requirement exists when the total MEC fraction exceeds 20 when averaged over one hour per 10 CFR 50.72. The following provides guidance on how to perform this calculation.

Maximum Effluent Concentration Fraction (MECF) Equation MECF = 4I C- x F x 4.72E-4 x XIQ x TR

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 12 of 29 C = The concentration of n Where:uclide i in mCi/cc.

F = Maximum design volumetric flow rate in CFM as indicated in 6.4.1.

X/Q = A conservative default atmospheric dispersion factor for a ground level release to a sector at or beyond the Site Boundary for Gaseous Effluents in sec/m 3. The default value in Step 6.1.3 will be used.

MECQ The MEC for nuclide i from Appendix B to 10 CFR Part 20, Table 2, Column 2 (pCi/cc). The class with the most restrictive Effluent Concentration will be used for each isotope.

TR = If the time of release is less than one hour, then this value is the duration of the transient in minutes divided by sixty. Otherwise, the Time Ratio (TR) is one. Dimensionless.

4.72E - 4 = The conversion factor in min*m3 /sec*ft 3 .

6.4 Dose Rate Calculations The Specification in Step 6.9.3 provides a maximum limit on organ dose rate equivalent beyond the Site Boundary for Gaseous Effluents from tritium and all radioactive materials in particulate form with half-lives greater than 8 days. Compliance is determined by calculating the organ dose rate for the MAXIMUM EXPOSED INDIVIDUAL for the inhalation pathway only.

The organ dose rate resulting from inhalation is calculated with the equation:

Organ:

DOOaj = (X/Q) x jj(Qvix Raji) v i Where:

DOaj = The dose commitment rate to organ j of a person in age group a (mrem/yr)

Raji = The factor to convert air concentration of radionuclide i to organ j dose commitment rate of a person in age group an exposed by inhalation (mrem-m 3/pCi-yr). See Attachment 7.

Qv* The release rate of radionuclide i (not including Noble Gas nuclides), via effluent vent v during the time of the release (pCi/sec)

X/Q = A conservative default atmospheric dispersion factor for a ground level release to a sector at or beyond the Site Boundary for Gaseous Effluents in sec/m 3 . The default value in Step 6.1.3 will be used.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 13 of 29 Exposure to dose rate factors, Raji, for using equation 13 in RG 1.109, Rev. 1, derives inhalation. Tables E-5, E-7, E-8, E-9, and E-10 are assumed to represent the Maximum Exposed Individual in the equation to derive Raji.

6.5 Organ Dose Calculations for Gaseous Effluents The Surveillance Requirement in Step 6.9.4 requires the radiation dose or dose commitment to the Maximum Exposed (Hypothetical) Individual accumulated from exposure to tritium and radioactive materials in particulate form having half-lives greater than 8.0 days, that originate in effluent air, be determined at least every month. The radiation dose or dose commitment accumulated during a calendar quarter and a year may not exceed values stated in the Specification in Step 6.9.4.

A person may be exposed to effluent radioactive material of this type in air by inhalation or indirectly via environmental pathways that involve deposition onto vegetation and the ground.

The exposure pathways evaluated will include the following:

p Exposure Pathway 1 Air - inhalation 2 Deposition onto ground - irradiation 3 Deposition onto vegetation - ingestion 4 Deposition onto forage - cow - milk - ingestion 5 Deposition onto forage - meat animal - meat - ingestion 6 Deposition onto forage - goat - milk - ingestion The equation used to calculate the dose commitment to the Maximum Exposed (Hypothetical)

Individual from radionuclides other than tritium is:

Daj E(/px >ý EQjx Rajip)] + E(/Q px E Qix R31 jp Where:

p = 1, i.e., air-inhalation, in the first term, and p = 2, 3, 4, 5, and 6 in the second term of the equation excludes H-3.

Daj = The dose commitment to organ j of a person in age group a (mrem)

Qvi = The quantity of each radionuclide i, in particulate form having a half-life greater than 8.0 days, in air discharged via effluent stream v (pCi)

X/Q = A conservative default atmospheric dispersion factor for a ground level release to a sector at or beyond the Site Boundary for Gaseous Effluents in sec/iM3 . The default value in Step 6.1.3 will be used.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 14 of 29 D/Q A conservative default deposition factor. A Factor converting a ground-level or building wake discharge in air to deposition on land (m 2). The D/Q value in Step 6.1.3 will be used.

Rajip = A factor converting time integrated concentration of radionuclide i in air or deposited on vegetation and/or ground to radiation dose commitment to organ j, including total body, of a person in age group a who is exposed via pathway p.

When p = 1, representing air-inhalation, Rajip has units of mrem-m 3 /pCi-yr. When p=2, 3, 4, 5 or 6 in the second term of the equation above, representing pathways involving deposition, Rajip has units of mrem-m 2 -sec/yr-ýtCi. When the radionuclide is H-3, Rajip has units of mrem-m/Cki-yr.

Tritium is assumed not to deposit onto vegetation or the ground. Hence, the concentration in vegetation is assumed to be related to the local atmospheric concentration as described in RG 1.109, Rev. 1, Appendix C. The dose commitment to the Maximum Exposed (Hypothetical)

Individual from tritium in gaseous effluent is calculated with the equation:

Daj = 3.17E -8 x<I [X/Q)p x (i x Rajii)j Where:

p = 1, 3, 4, 5, and 6 i includes H-3 only X/Q = A conservative default atmospheric dispersion factor for a ground level release to a sector at or beyond the Site Boundary for Gaseous Effluents in sec/m 3 . The default value in Step 6.1.3 will be used.

3.17E-8 = years/sec Other terms as defined in previous section.

Dose factors Rajpp for RSNGS are derived using the equations and methods in RG 1.109, Rev.

1, Appendix C. Values of parameters in RG 1.109, Rev. 1, Table E-5 are assumed to represent the Maximum Exposed (Hypothetical) Individual. Any different values from default values will be justified and added as a table to the ODCM. Values of other parameters recommended in RG 1.109, Rev. 1, including those recommended in the absence of site-specific data, are used in the equations to derive the dose factors.

6.6 Gas Dose Projections 31-Day Dose projections are calculated to show compliance with Step 6.9.6. Quarterly and Annual dose projections are calculated in compliance with the Specification in Step 6.9.6.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 15 of 29 6.7 Fuel Cycle Dose If a calculated dose exceeds twice the limit of the Specification in Step 6.9.4 an assessment of compliance with the Specification in Step 6.9.5 must be made.

Gas dose calculations shall be made using the general methodology of Steps 6.5. This methodology is to be used as a guide and strict adherence is not required because the Fuel Cycle Dose Calculation is done to determine the actual dose received, not a hypothetical maximum. Therefore, parameters such as dilution beyond the site boundary and residential shielding may be factored into the calculation.

The total body and organ doses shall be the result of summing the individual contributions from liquid, gas, and direct radiation sources for the affected Member of the Public.

Irradiation, i.e., exposure to an external source of radiation, directly from the RSNGS normally will be evaluated with the aid of environmental monitoring dosimetry.

6.8 EPA Reporting Requirements If a calculated dose exceeds the Specification limit of Step 6.9.1, 6.9.3, or 6.9.4, an assessment of compliance with 40 CFR Parts 302 and 355, Reportable Quantity Adjustment -

Radionuclides, must be made.

This involves determining the maximum quantity of radionuclides released in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period and comparing the quantities to the values listed in 40 CFR 302 Appendix B. The "sum of the ratios" method shall be used to determine compliance. If the "sum of the ratios" is greater than one, the National Response Center shall be notified.

Since Rancho Seco's systems and procedures are set up to normally operate within the above limits, this condition is not expected to occur, therefore, specific implementation procedures to determine compliance are not required.

6.9 Technical Requirements 6.9.1 Maximum Effluent Concentrations in Liquid Effluents Specifications:

The concentration of radioactive material released in liquid effluents at any time shall be limited to the concentrations specified in Appendix B to 10 CFR Part 20, Table 2, Column 2.

Applicability:

This is applicable at all times.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 16 of 29 Action:

With the concentration of radioactive material released from the site exceeding the above Specifications, report the event in the next Annual Radioactive Effluent Release Report.

Surveillance Requirements:

The radioactivity concentration of each temporary tank to be discharged shall be determined prior to release by sampling and analysis. The results of the temporary tank pre-release sample analyses shall be used to ensure that the concentration at the point of release is within the limits of the above Specification.

There are no continuous releases of radioactive material in liquid effluents from the plant.

All radioactive liquid effluent releases from the plant are by batch method.

6.9.2 Gaseous Effluent Monitoring Instrumentation requirements for gaseous effluent monitoring are presented in Attachment 3.

The lOS Building has a ventilation system in which the effluent releases are sampled during work activities which have the potential to generate airborne particulate activity. Operation of the respective ventilation system produces a negative pressure in the building. Although no planned airborne radioactive releases are anticipated from this pathway, refer to Attachment 4 when sampling the ventilation exhaust from this building.

6.9.3 Gaseous Dose Rates Specifications:

The dose rate due to radioactive materials released in gaseous effluents from the site to areas at or beyond the Site Boundary for Gaseous Effluents (see Attachment 1) shall be limited to the following values:

1) The dose rate limit for tritium and for all radioactive materials in particulate form with half-lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

Applicability:

This is applicable at all times.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 17 of 29 Action:

With the dose rate(s) exceeding the above limits, immediately restore the release rate to within the limit(s) specified and report the event in the next Annual Radioactive Effluent Release Report.

Surveillance Requirements:

Obtaining representative samples and performing analyses in accordance with the sample analyses program specified in Attachment 4 shall determine the release rate of radioactive materials in gaseous effluents.

The dose rate due to tritium and all radioactive material in particulate form with half-lives greater than 8 days, released in gaseous effluents, shall be determined to be within the limits of this Specification by using the results of the sampling and analysis program specified in Attachment 4 and the methodology described in Step 6.4.

Bases:

Step 6.9.3 is provided to ensure that the dose rate from gaseous effluents due to inhalation at any time at the Site Boundary for Gaseous Effluents (see Attachment 1) will be within the annual dose limits of 10 CFR Part 20 for MEMBERS OF THE PUBLIC. The annual dose limits are the doses associated with the concentrations of Appendix B to 10 CFR Part 20, Table 2, Column 1. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual at or beyond the Site Boundary for Gaseous Effluents to annual average concentrations exceeding the dose rate equivalent, on which the limits specified in Appendix B, Table 2 of 10 CFR Part 20 were derived. For individuals who may at times be within the Site Boundary for Gaseous Effluents, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the boundary.

6,9.4 Gaseous Organ Dose Specifications:

The dose or dose commitment to a MAXIMUM EXPOSED (HYPOTHETICAL) INDIVIDUAL from tritium and radioactive materials in particulate form with half-lives greater than eight days in gaseous effluents released to areas at or beyond the Site Boundary for Gaseous Effluents (see Attachment 1) shall be limited to the following:

1) During any calendar quarter, to less than or equal to 7.5 mrem to any organ; and,
2) During any calendar year, to less than or equal to 15 mrem to any organ.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 18 of 29 Applicabilitv:

This is applicable at all times.

Action:

With the calculated dose or dose commitment from the release of tritium and radioactive materials in particulate form with half-lives greater than eight days in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report. This Report will identify the cause(s) for exceeding the limit and define the corrective actions to be taken to reduce the releases and the proposed corrective action(s) to be taken to assure that subsequent releases will be in compliance with the above annual limits.

Surveillance Requirements:

Cumulative dose contributions for the current calendar quarter and calendar year period shall be determined in accordance with the methodology described in Step 6.5 at least monthly when releases are occurring.

Bases:

Step 6.9.3 is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix 1, 10 CFR Part 50. The Specifications are the guides set forth in Section II.C of 10 CFR 50, Appendix I. The Action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of 10 CFR 50, Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "As Low As is Reasonably Achievable (ALARA)." The calculational methods specified in the Surveillance Requirements implement the requirements in Section III.A of 10 CFR 50, Appendix I that conformance with the guides of 10 CFR 50, Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. For individuals who may at times be within the Site Boundary for Gaseous Effluents, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric dispersion factor above that for the boundary.

The calculational methods for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109,

.. Calculating of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, Revision 1, October 1977 and Regulatory Guide 1.111, ""Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,""

Revision 1, July 1977. These equations also provide for estimating doses based upon the historical average atmospheric conditions.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 19 of 29 The release rate specifications for radioactive materials in particulate form are dependent on the existing radionuclide pathways to man in areas at or beyond the Site Boundary for Gaseous Effluents (see Attachment 1). The pathways which were examined in the development of these calculations are: (1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure of man.

6.9.5 Fuel Cycle Dose Specification:

The dose or dose commitment to any real MEMBER OF THE PUBLIC due to releases of radioactive material in gaseous and direct radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrem to the total body or any organ in a calendar year.

Applicability:

At all times.

Action:

1) With the calculated doses from the release of radioactive material in gaseous effluents exceeding twice the limits of Specifications in Step 6.9.4 calculations shall be made including direct radiation contributions (including outside storage tanks, etc.) to determine whether the above specifications have been exceeded.
2) If the above limits have been exceeded, prepare and submit to the Commission within 30 days, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in 10 CFR Part 20.2203(a)(4), shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, in a calendar year that includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations.
3) If the estimated dose(s) exceed the above limits, and if the release condition resulting in the violation of 40 CFR Part 190 has not already been corrected, the Special Report shall include a request for a variance in accordance with the provision of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 20 of 29 Surveillance Requirements:

Cumulative dose contributions from gaseous effluents shall be determined in accordance with Step 6.9.3 Surveillance Requirements.

Cumulative dose contributions from direct radiation (including outside storage tanks, etc.)

shall be determined in accordance with Step 6.7. This requirement is applicable only under the conditions set forth in the above Action statements.

Bases:

Step 6.9.5 is provided to meet the dose limitations of 40 CFR 190 that have been incorporated into 10 CFR 20 by 46 FR 18525. The specification requires the preparation and submittal of a Special Report whenever the calculated doses from plant radioactive effluents exceed twice the numerical guides for design objective doses of 10 CFR 50, Appendix I. For the Rancho Seco site, it is unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR 190 if the plant remains within twice the numerical guides for design objectives of 10 CFR 50, Appendix I and if direct radiation (outside storage tanks, etc.) is kept small. The Special Report will describe a course of action, which should result in the limitation of the dose to a MEMBER OF THE PUBLIC for a calendar year to within the 40 CFR 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered. If the dose to any MEMBER OF THE PUBLIC is evaluated to exceed the requirements of 40 CFR 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR 190 have not already been corrected), in accordance with the provisions of 40 CFR 190 is considered to be a timely request and fulfills the requirements of 40 CFR 190 until NRC staff action is completed. An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation, which is part of the uranium fuel cycle.

6.9.6 Quarter/ Annual Dose Projections Specifications:

The projected dose contributions from gaseous effluents for the current calendar quarter and current calendar year shall be calculated according to the methodology in Step 6.6 at least every 31 days.

Applicability:

Only when actual releases occurring Action:

With the required dose calculations not being performed, best effort will be exerted to perform the calculations once the deficiency has been identified. Corrective actions will be taken and documented to prevent reoccurrence.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 21 of 29 Surveillance Requirements

1) Gaseous Effluents:

Projected dose contributions shall be determined at least every 31 days.

Bases:

This step is provided to implement Appendix A of the Rancho Seco Quality Manual. Dose projections provide a means of determining if current release practices will be within the dose limits of 10 CFR 50, Appendix I. Calculating projected dose totals every 31 days provides information, which can be used to keep effluent releases "as low as is reasonably achievable".

Calculations performed during the first 15 days of the calendar year or calendar quarter will result in artificially high dose projections, which provide no usable information.

6.10 Reports 6.10.1 Annual Radioactive Effluent Release Report (ARERR)

The ARERR covering the activities of the unit during the previous 12 months shall be submitted within 90 days after January 1 of each year. The report shall include the following:

(1) Summary of the quantities of radioactive gaseous effluents released from the unit.

(2) Summary of solid waste shipped from the unit.

(3) All unplanned releases of radioactive materials in gaseous effluents to unrestricted areas shall include a description of the event and equipment involved, cause(s), action(s) taken to prevent recurrence, and consequences.

(4) Dose or dose commitment assessments to ensure compliance with the specifications in 6.9.4.

(5) Complete, legible copy of the entire ODCM and/or REMP Manual if changes occurred during the ARERR reporting period. The copy may be part of the ARERR or sent concurrently.

(6) The ARERR shall also include events described in 6.9.1 and 6.9.2.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 22 of 29 6.10.2 30 Day Reports The following 30-day reports should be submitted if the criteria are met as stated in the following areas:

(1) 6.9.4 - Gaseous Organ Dose (2) 6.9.6 - Quarterly/ Annual Dose Projections (3) 6.9.5 - Fuel Cycle Dose 7.0 RECORDS The individual/packaged documents and related correspondence completed as a result of the performance or implementation of this procedure are records. They shall be transmitted to Records Management in accordance with RSAP-0601, Nuclear Records Management.

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 23 of 29 SITE BOUNDARY FOR GASEOUS EFFLUENTS 7-

~ -

T~~It6i Attachment 1 Page 1 of 1 I

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 24 of 29 ORGAN DOSE FACTORS FOR GASEOUS EFFLUENTS DOSE FACTOR TABLE: R(i) - Adult. inhalation 3

Units are mrem/yr per jCi/m Nuclide Bone Liver Tbody Thyroid Kidney Lung GI tract H-3 0.00E+00 1.26E+03 1.26E+03 1.26E+03 1.26E+03 1.26E+03 1.26E+03 FE-55 2.46E+04 1.70E+04 3.95E+03 0.OOE+00 0.OOE+00 7.21 E+04 6.03E+03 CO-60 0.OOE+00 1.15E+04 1.48E+04 O.OOE+00 0.OOE+00 5.97E+06 2.85E+05 SR-90 9.92E+07 0.OOE+00 6.10E+06 0.OOE+00 0.00E+00 9.60E+06 7.22E+05 CS-1 34 3.73E+05 8.48E+05 7.28E+05 0.OOE+00 2.87E+05 9.76E+04 1.04E+04 CS-1 37 4.79E+05 6.21 E+05 4.28E+05 0.OOE+00 2.23E+05 7.52E+04 8.40E+03 DOSE FACTOR TABLE: R(i) - Teen, inhalation, 3

Units are mrem/yr per WCi/m Nuclide Bone Liver Tbody Thyroid Kidney Lung GI tract H-3 O.OOE+00 1.27E+03 1.27E+03 1.27E+03 1.27E+03 1.27E+03 1.27E+03 FE-55 3.35E+04 2.39E+04 5.55E+03 O.OOE+00 0.OOE+00 1.24E+05 6.39E+03 CO-60 0.OOE+00 1.51 E+04 1.98E+04 0.OOE+00 0.OOE+00 8.72E+06 2.59E+05 SR-90 1.08E+08 0.OOE+00 6.68E+06 0.OOE+00 O.OOE+00 1.65E+07 7.65E+05 CS-134 5.03E+05 1.13E+06 5.49E+05 0.OOE+00 3.75E+05 1.46E+05 9.76E+03 CS-1 37 6.71 E+05 8.48E+05 3.11 E+05 O.OOE+00 3.04E+05 1.21 E+05 8.48E+03 DOSE FACTOR TABLE: R(i) - Child, 3inhalation Units are mrem/yr per pCi/m Nuclide Bone Liver Tbody Thyroid Kidney Lung GI tract H-3 0.OOE+00 1.13E+03 1.13E+03 1.13E+03 1.13E+03 1.13E+03 1.13E+03 FE-55 4.74E+04 2.52E+04 7.77E+03 0.OOE+00 0.OOE+00 1.11 E+05 2.87E+03 CO-60 0.OOE+00 1.31 E+04 2.27E+04 O.OOE+00 O.OOE+00 7.07E+06 9.62E+04 SR-90 1.01 E+08 0.OOE+00 6.44E+06 0.OOE+00 O.OOE+00 1.48E+07 3.44E+05 CS-134 6.51E+05 1.01E+06 2.25E+05 0.OOE+00 3.31E+05 1.21E+05 3.85E+03 CS-1 37 9.07E+05 8.25E+05 1.28E+05 0.OOE+00 2.82E+05 1.04E+05 3.62E+03 DOSE FACTOR TABLE: R(i) - Infant, 3inhalation Units are mrem/yr per uCi/m Nuclide Bone Liver Tbody Thyroid Kidney Lung GI tract H-3 0.OOE+0O 6.47E+02 6.47E+02 6.47E+02 6.47E+02 6.47E+02 6.47E+02 FE-55 1.97E+04 1.18E+04 3.33E+03 O.OOE+00 O.OOE+00 8.70E+04 1.1OE+03 CO-60 0.OOE+0O 8.03E+03 1.18E+04 0.OOE+00 0.OOE+00 4.51 E+06 3.19E+04 SR-90 4.09E+07 0.OOE+00 2.59E+06 0.OOE+00 0.OOE+00 1.12E+07 1.31E+05 CS-1 34 3.96E+05 7.03E+05 7.45E+04 0.OOE+0O 1.90E+05 7.97E+04 1.33E+03 CS-1 37 5.49E+05 6.12E+05 4.55E+04 0.OOE+00 1.72E+05 7.13E+04 1.33E+03 Attachment 2 Page 1 of 1

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 25 of 29 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Instrument Action 1 . lOS Building

a. Particulate Sampler These samples are analyzed in accordance with Attachment 11.
b. Sampler Flow Rate Only samplers with a calibrated flow-measuring Measurement Device device may be used.

Attachment 3 Page 1 of 1

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 26 of 29 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit of Gaseous Sampling Minimum Analysis Type of Activity Detection Release Type Frequency Frequency Analysis(c)(d) (LLD)(a)

(Pci/cc)

M lOS Building Continuous (b) Particulate Sample Principal Gamma 1.00 E-1 1 Emitters Table Notation (a) 1. The Lower Limits of Detection (LLDs) for the radionuclides presented in this table are the smallest concentration (expressed in microcuries per unit volume) which are required to be detected, if present, in order to achieve compliance with the limits of the Specifications in Steps 6.9.3, and 6.9.4.

2. The LLD of a radioanalysis system is that value which will indicate the presence or absence of radioactivity in a sample when the probability of a false positive and of a false negative determination is stated. The probabilities of the false positive and false negative are taken as equal at 0.05. The general equation for estimating the maximum LLD in microcuries per cubic centimeter (pCi/cc) is given by the following:

2.7* + 3.29 x Sb LLD =

(3.70 E + 04)(Y x E X<V)e(-Xt)

Attachment 4 Page 1 of 3

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 27 of 29 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM (Continued)

Where:

2.71 = factor to account for Poisson statistics at very low background count rates 3.29 = two times the constant used to establish the one sided 0.95 confidence interval 3.70 E+04 = disintegrations/second/microcurie Y = yield of radiochemical process, i.e., the product of all factors such as emission fraction, chemical yield, etc.

E = counting efficiency (count/disintegrations)

V = sample volume (cubic centimeters) x = the radioactive decay constant for the particular nuclide (seconds-1) tc = the elapsed time from midpoint of collection to the midpoint of counting Sb = the standard deviation of the background counting rate 0.5 Sb =+ _

Where:

B = background counts tb = background counting interval (seconds) tr, = sample counting interval (seconds)

Attachment 4 Page 2 of 3

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 28 of 29 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM (Continued)

Table Notation (Continued)

3. The LLD is defined as an a priori (before the fact) estimate and is not to be calculated for each sample analyzed on an a posteriori (after the fact) basis.

(b) Sample during activities which have the potential to release radioactive gaseous effluent.

Ventilation may be operated during long term storage activities without sampling, dose calculations, surveillance, or reporting requirements. Radiation Protection program routine airborne activity sampling may be used to verify these activities.

(c) Principal gamma emitters for which the LLD applies are: Co-60, Cs-1 34, and Cs-1 37 for particulate samples. This does not mean only these nuclides will be detected and reported.

Other peaks that are measurable and identifiable shall be reported in the Annual Radioactive Effluent Release Report, pursuant to Step 6.10.1. All peaks, which are measurable and identifiable, shall be reported and entered into the ODCM evaluations. Nuclides, which are not observed for the analysis shall be reported as "less than" the nuclide's a posteriori minimum detectable concentration and shall not be reported as being present. The "less than" results shall be considered "zero" for the ODCM evaluations; however, if a nuclide is measured and identified at a value less than the Attachment 11 LLD value, it shall be reported and entered into ODCM evaluations.

(d) Gross activity analysis for gamma emitters with a sensitivity of <1.0 E-12 pCi/cc may be used to evaluate the samples collected. If the activity is <1.0 E -12 pCi/cc, then analysis for individual isotopic concentrations is not required.

Attachment 4 Page 3 of 3

MANUAL: CHEMISTRY ADMINISTRATIVE PROCEDURES NUMBER: CAP-0002 MANUAL REVISION: 23 TITLE OFFSITE DOSE CALCULATION MANUAL PAGE: 29 of 29 ODCM REVISION REVIEW REQUIREMENTS ODCM REVISION REVIEW REQUIREMENTS Whenever the ODCM is revised, no matter what the changes are, several reviews must be performed. These reviews must also be documented. The documentation is often included as an attachment to the 50.59 Safety Determination. This form lists the minimum reviews and documentation required for each change. Initial each requirement as it is completed. Sign the bottom of the form when all review requirements are completed.

Initials I. Determination that the level of control of radioactive effluents is being maintained.

This determination is made by review of the following documents:

  • Appendix l to10 CFR 50 40CFR190 I1_ Determination that the change(s) will not adversely affect the accuracy or reliability of effluent dose calculations or effluent monitor setpoint determinations.

This determination is made by directly reviewing each change to the ODCM. Although each change must be evaluated, changes that directly involve calculations should be more carefully considered.

Ill. Supporting information-Full justifi IaMýnr alO ~ r thca *mst be llCu" in the included View a rovyallu IV. Nooific_.n of NRC . L J X .JL_

The NRC is notified of all changes to the ODCM by including a complete, legible copy as part of, or concurrent with, the Annual Radioactive Effluent Release Report (ARERR). To ensure inclusion in the ARERR a CTS item should be initiated whenever the ODCM is revised.

V. Implementing Documents.

The following documents should be reviewed for impact whenever the 00CM Ls revised:

" CAP-0008. Offsite Releases of Radioactivity in Liquid Effluents 0 CAP-0009, OMfsite Releases of Radioactivity in Gaseous Effluents

" CHM-5101, Compositing of Uquid Samples

" CHM-5109, Effluent Monitor Alarm Response Procedure VI. Multidiscipline Review Ensure all areas that may be affected by he mrvision, or have an interes in U*thhanmes made in the revision, are included in the multiscipline review. Areas that are affected by fte OCM and could be included in this review are: Tedminl Semvics, Surveillance Scheduler, Quality Assurance, Licensing, and Operations.

All Reviews Complete:

Reviewer Signatte Date CHM-422 (Rev. 1) Page I of l Attachment 5 Page 1 of 1

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