Text

Boiling Water Reactor (LACBWR) Offsite Dose Calculation Manual, Revision 13
	ML13079A185
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/30/2012
From:	Nelson L; Dairyland Power Cooperative
To:	; NRC/FSME
References
	Download: ML13079A185 (101)
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I' BOILING WATER REACTOR LACROSSE V

LA CROSSE BOILING WATER REACTOR (LACBWR) 2 Q.

E 0

OFFSITE DOSE CALCULATION MANUAL CA)

C

.2 0 Prepared by:, Z" Date N

Health Physics Review:

-a _ j~-

N a5 Date Radiation Protection Engineer Review: I1--1 2-Date Quality Assurance Review:_

I Date U,

ORC Approved

`6 7t'e 0)

September 2012 Revision 13 Modify Due to Removal z Of All Fuel From The Plant 0

(1)

-j wU z Dairyland Power Cooperative XI 3200 East Avenue South La Crosse, WI 54602-0817 II

ITABLE OF CONTENTS

1. INTRODUCTION ................................................................................ 1 1.1 Purpose .................................................................................... 1 1.2 Definitions ................................................................................. 1 0 2. OFFSITE DOSE CALCULATIONS ........................................................ 5 2i) 2.1 Compliance with the Limitations for Liquid Effluent Releases ........... 5 2.2 Compliance with the Limitations for Gaseous Effluent Releases.......... 12 0

3. RADIOACTIVE EFFLUENT CONTROL PROGRA M................................. 27 0

3.1 Program Requirements ............................................................... 27 3.2 Liquid Effluents .......................................................................... 28 3.2.1 Sampling and Analysis ...................................................... 28 3.2.2 Liquid Effluent Release Limitation ......................................... 30 3.2.3 Liquid Effluent Instrumentation ............................................. 31 3.3 Gaseous Effluents ...................................................................... 35 3.3.1 Reactor Building Ventilation ............................................... 35 3.3.2 Stack Effluent Sampling and Analyses .................................. 35 3.3.3 Stack Effluent Release Limitation ......................................... 37 6 0 3.3.4 Instrumentation ................................................................ 39 (0 3.4 Total Dose to a Member of the Public ............................................. 42

4. RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ............... 45 MU r-_

0)4.1 Program Requirements ............................................................... 45 4.2 REMP Description ...................................................................... 46 4.3 REMP Lower Limits of Detection ................................................... 49 4.3.1 Calculation of Lower Limits of Detection ................................. 50 Wo z~

4.4 Interlaboratory Comparison Program .............................................. 52 4.5 Reporting Requirements .............................................................. 52 ODCM i Rev. 13

LIST OF TABLES 2.1 Infant Dose Factors Pi, (Inhalation) for H-3 and Particulate 0

Gaseous Release Monitor Alarm Setpoint Determinations ........................ 19 0 3.1 Radioactive Liquid Waste Sampling and Analysis Requirements 0

o for Batch Releases .......................................................................... 29 3.2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements ................................................................................. 33 0.

3.3 Radioactive Gaseous Waste Sampling and Analysis .............................. 36 CX) -N 3.4 Radioactive Gaseous Effluent Monitoring Instrumentation ........................ 41 3.5 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements ................................................................................. 42 0U-~

4.1 Radiological Environmental Monitoring Program .................................... 47 0

4.2 Environmental Sample Analyses Lower Limits Values (LLD) ..................... 51 4.3 Reporting Levels for Radioactivity Concentrations in Environmental S am ples ........................................................................................ 54 cI0 Oz 3 J wt W o i a-ODCM iiRev. 13

I LIST OF FIGURES (3

0 0L 2.2 H-3 and Particulate Gaseous Release Monitor Alarm Setpoint CL

< ~~Determination............................................................... 17 E

0 02.3 H-3 and Particulate Gaseous Release Monitor Alarm Setpoint Summary ... 18 (0

Ca 0

LIST OF DIAGRAMS o ) 1.1 Site Map, Including Effluent Release Boundary .............................. 4 LL C

. D CO

-0 x) W

-0 ODCM °°° Rev. 13

1.0 INTRODUCTION

0 1.1 Purpose The OFFSITE DOSE CALCULATION MANUAL (ODCM) contains the E methodology and parameters used in (1) the calculation of offsite doses resulting from radioactive liquid effluents from LACBWR, and (2) the calculation of liquid effluent monitoring Alarm/Trip Setpoints. The ODCM also contains the 0 Radioactive Effluent Controls and Radiological Environmental Monitoring C1 Programs.

CN 1.2 Definitions CHANNEL CALIBRATION A1)

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

0 CHANNEL CHECK

~) W 0 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other ODCM 1 Rev. 13

indications and/or status derived from independent instrument channels measuring the same parameter.

CHANNEL FUNCTIONAL TEST 0

CL A CHANNEL FUNCTIONAL TEST shall be:

E 0

a. Analog channels - the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm

.0 and/or trip functions and channel failure trips.

0.4

b. Bistable channels - the injection of a real or simulated signal into the CN'

'IT ~sensor to verify OPERABILITY including alarm and/or trip functions.

EFFLUENT RELEASE BOUNDARY The Dairyland Power Cooperative property line within the 1109 ft. (338m) radius EXCLUSION AREA is the EFFLUENT RELEASE BOUNDARY.

(See Diagram 1.1.)

EXCLUSION AREA The EXCLUSION AREA is defined as the area within an 1109 ft. (338m) radius from the centerline of the Reactor Building. This was the area established per 10 CFR 100 as the EXCLUSION AREA for plant siting and operation.

MAXIMUM PERMITTED CONCENTRATION (MPC)

G)W The limiting liquid effluent concentration value 10 CFR 20, Appendix B, Table 2, Column 2.

ODCM 2 Rev. 13

MEMBER OF THE PUBLIC MEMBER OF THE PUBLIC shall mean an individual in a CONTROLLED or UNRESTRICTED AREA. However, an individual is not a MEMBER OF THE 0ý PUBLIC during any period in which the individual receives an occupational dose.

E 0 OPERABLE-OPERABILITY 0) 2 A system, subsystem, train, component or device shall be OPERABLE or have C9 OPERABILITY when it is capable of performing its specified function(s) and CL 0 when all necessary attendant instrumentation, controls, a normal or an emergency electrical power source, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

CL

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

0O ODCM 3 Rev. 13

I Prepared or Revised By Date jj Rad. Prot. Engineer P e:w Date Operations Review Comm. Approval j I LARRY L. NELSON 1 9117/12 1 SEYMOUR J. RAFI-._.Y 9/24112 11 a)D9 - Tzillzz, 0

(C m

0 C) r c

M

,n C) m-n 3 Z

r" m

C,)

m 0

c z

0 X -0 CD

2.0 OFFSITE DOSE CALCULATIONS 2.1 Compliance with the Limitations for Liquid Effluent Releases a) To assure compliance with the limitations of Section 3.2.2.a, Radioactive Effluent Control Program (RECP), the radioactivity monitor alarm setpoint is calculated for the monitor as a function of the maximum effluent flow rate and the minimum dilution flow rate. The following equation is used to calculate setpoints:

af

--.C (2.1) k( F+f) where:

0= the effluent concentration limit implementing 10 CFR 20 for LACBWR, in jiCi/ml.

a the setpoint (in CPS above background) of the radioactivity monitor S0 measuring the radioactivity concentration in the effluent line prior to dilution and subsequent release; the setpoint, which is inversely proportional to the volumetric flow of the effluent line (f) and proportional to the volumetric flow of the dilution stream plus the effluent stream (F + f), represents a value which, if exceeded, could result in concentrations exceeding the limits of 10 CFR 20.

0 a

k= the conversion factor, cps per liCi/ml, for the liquid waste effluent a) U monitor based upon most recent calibration of the monitor.

ODCM Rev. 13

f= the effluent line volumetric flow setpoint as measured at the radiation monitor location, in gallons per minute.

F= the dilution stream (LACBWR & Genoa Station No. 3 [G-3]

0 CL Condenser Cooling Water) volumetric flow, in gallons per minute.

0 Since f << F, Equation 2.1 is satisfied when the following discharge line

> radioactivity monitor setpoint is met:

a) kCF a :5 (2.2) 0f Calculation of Instantaneous Allowable Release Rates LACBWR's liquid radwaste is released in batches. In order to assess the required radioactive liquid effluent line monitor setpoint, a, the following step-by-step method for obtaining data will be performed. The form presented in Figure 2.1 may be used as a worksheet for these calculations. The alarm setpoint W

calculation may be performed on an annual basis if the setpoint is determined to

-6 w be sufficiently conservative so as to prevent exceeding 0.5 MPC at the discharge point where MPC is the isotope weighted effluent concentration release limit for a typical LACBWR waste batch based on 10CFR20, appendix B, Table 2, Col. 2 values.

1. Go to Figure 2.1 Enter the date on the form.

W 2. Enter the concentration Ci (pjCi/ml) for each isotope i, in a typical

-o >LACBWR waste batch.

ODCM 6 Rev. 13

3. The values of f and F are determined and recorded at the top of Figure 2.1. F is the minimum volumetric dilution flow rate during releases at the LACBWR - G-3 outfall which is equal to the LACBWR condenser cooling water flow rate plus the G-3 condenser coolingwater volumetric C.

flow, in gallons per minute. The value f is the maximum radioactive liquid release flow rate (GPM) for the batches discharged during the period. A A) value of 17 GPM is normally specified for f.

4. The quantities Ci, and C /MPCi are determined and recorded.

Q) a-0 5. The monitor conversion factor, k, determined at last primary calibration is recorded on Figure 2.1, in cps (net) per ý.Ci/ml.

6. The alarm setpoint, a (cps), with a 0.5 factor for conservatism, for the monitor measuring radioactivity in the liquid effluent line is then determined by:

0) a 0.5 kF Z C, (2.3)

SD a-f Ci/MPCI

-6 w Q) 0 a

a)W 0

ODCMV Rev. 13

A~1 Figure 2.1 LIQUID RELEASE MONITOR ALARM SETPOINT DETERMINATION Date 0ý C.

Maximum Liquid Release Rate for Period, f= GPM Minimum Dilution Flow Rate for Period, F= GPM E

0 A-)

Average Concentra- MPCj (10 CFR Nuclide i tion (in Tanks), Part 20, Appendix B Ci/MPCi C: Ci (ýLCi/ml) Table 2, Col. 2) 0 Co-60 3 E-06 CU Cs-137 1 E-06 04 Cs-1 34 9 E-07 04 ai- Sr-90 5 E-07 Fe-55 1 E-04 0U Ci Ci/MPci =

A~l C,,

Monitor Conversion Factor, k = _______________cps(net) 0, j~tCi/mI CN U-0 0.5 kF Y_ Ci a

(alarm setpoint) f Y_Ci/MPCi cps above background

-o z

Q) 0 C,)

0) z

_0 a)

ODCM 8 Rev. 13

b) To demonstrate compliance with the limitations of Section 3.2.2.b, dose N

a contributions are calculated at a maximum interval of once every calendar I quarter for all radionuclides identified in liquid effluents released to 2 unrestricted areas using the methodology presented in NRC Regulatory 0.

<E Guide 1.109, Rev. 1, October 1977. This methodology takes the form of 0 the following general equation:

m DaT = - (AaI" Cij/Fj) (2.4) c/}g :;2

j=1 "L where:

0 SDa, = the cumulative dose commitment to the total body or any organ r o *of an individual in age group a from the liquid effluents released in m batches, in mRem.

LL C.j = the total quantity of radionuclide i, released by batch j, in Ci.

0))

D Aai, - the site-related ingestion dose commitment factor to the total body

>- or any organ -r of an individual in age group a for each identified Mu Cl) principal gamma and/or beta emitter, in mRem-gal-min-1 -Ci-'.

(N F. = the average dilution water flow rate during batch release j in gallons/minute.

z Equation 2.4 requires the use of a dose factor Aai, for each nuclide, organ and individual in age group a which includes the factors which determine the ultimate dose received such as pathway transfer factors (e.g., bioaccumulation factors),

pathway usage factors, ingestion dose factors and dilution factors. The following philosophy and site-specific conditions determine the site-specific factors ODCM 9 Rev. 13

A4 incorporated into the liquid effluent dose calculation model:

1. Liquid Dose Pathways Due to LACBWR's status as a fresh water site, there is no 0

invertebrate pathway. The drinking water pathway is not included, since the nearest community which obtains its drinking water supply from the Mississippi River is located at Davenport, Iowa,

which is 195 miles downstream. The drinking water pathway represents < 0.01% of the dose to any organ. The irrigated foods

_pathway is not included since the river water is not used for irrigation in this area and the shoreline deposits pathway is insignificant for the Mississippi River. The only significant dose pathway is the dose commitment due to ingestion of fish from the Mississippi River waters.

2. Dilution The liquid effluent flow from the waste tanks is diluted by the combined total circulating water flow for condenser cooling at both LACBWR and G-3. For offsite dose calculations, no dilution by the C:

Mississippi River flow is considered. Also, under SAFSTOR conditions batch discharges of liquid effluent normally take place CuU) during less than 35 hours4.050926e-4 days 0.00972 hours 5.787037e-5 weeks 1.33175e-5 months per month (< 5% of the time). Therefore, no fish in the river are continuously exposed to a radioactive environment produced by LACBWR liquid effluent as assumed in the calculation of the published bioaccumulation factors for fish.

0)

Based on the above site-specific criteria, the dose factor Aai, is defined as follows:

AaiT = K. (UFa)(BF )(DFaiT) (2.5) where:

Ko = a units conversion constant, 5.03 E5 =

ODCM 10 Rev. 13

(1 E12 pCi/Ci x .2642 gal/l ) / (8760 hrs/yr x 60 min/hr).

16 UFa = fish consumption usage factor for an individual in age group a, in kg/yr.

0 BFj = the bioaccumulation factor in fish for nuclide i, in CLI pCi/kg per pCi/ e.

oE !DFaii= the ingestion dose factor for age group a for nuclide i, 01, in organ -zin mRem/pCi.

RD

~0 osClcuatdoneof.Dose CausommtetUFromF* Land EFspcfluents NR eultr Cq The equations for this calculation have been formatted on a computer-based a,

M* Guide 1. 109 Rev. 1 , October 1977, and the constant K, have been entered on the spreadsheet.

Cu a: "L ,,x To perform the calculation the following information is entered in the appropriate

-- cells of the spreadsheet for each liquid batch released during the period of 0 interest:

o>-

1. Date

2. Release interval, hrs a, 3. Waste volume, gal C) 4. Condenser cooling water flow rate, GPM

5. Activity concentration of each isotope, i, in waste, ICi/ml.

z The spreadsheet program will then calculate and display the total quarterly dose a**, in mRem to the total body and each organ of an individual in each age group.

8~*The . cumulative calendar year doses and the percentage of the limits set forth in Section 3.2.2.b are also calculated. This spreadsheet will also print the data tables for the liquid effluent section of the annual report.

ODCM 11 Rev. 13

2.2 Compliance with the Limitations for Gaseous Effluent Releases a) To assure compliance with the limitations of Section 3.3.3.a, alarm setpoints are established for the gaseous effluent monitor. These setpoints are calculated or checked annually, or as required by procedure, to confirm that the current setpoints are set correctly for one- or two-stack E

0 blower operation.

During SAFSTOR, the principal potential gaseous release pathway is from the Reactor Building ventilation exhaust system.

0.

After the completion of the DCS project all fuel has been removed from the plant. Noble gas (Kr-85) releases will no longer be analyzed for.

0)

H-3 and Particulates The following mathematical relationship shall be used to implement the limitation for H-3 and Particulates with T1 /2 > 8 days alarm setpoints:

Dpa = XIi P ft Qpi (Q) (2.10) where:

CN4 Dp, = the dose rate to organ t of an individual at or beyond the EFFLUENT RELEASE BOUNDARY, due to H-3 and particulates with half-lives greater than 8 days. This value is to be less than 1500 mRem/yr.

C0(

UJ Pit the dose parameter for organ -r,3 for radionuclide i, for the inhalation pathway, in mRem-m per ýiCi-yr.

UdQ = the atmosphere dispersion coefficient in sec/m3 Q = release rate of nuclide i, in gCi/sec.

ODCM 12 Rev. 13

Calculation of Release Limits for H-3 and Particulates with Half-Lives Greater than 8 days Co 0 ISince it is impractical to measure instantaneous release rates for radionuclides the

> alarm setpoints for radionuclides are expressed in terms of total accumulated activity on 0

CL

< sample media for a specified sampling time, AT, which is monitored as ýtCi by the stack 00 effluent monitor.

UE

> Equation 2.11 is used to calculate the release rate limit for all H-3 and particulates with

. (half-lives Cd) greater than 8 days. This equation is based on the dose rate to an infant due CU CL to inhalation of these radionuclides. In accordance with NUREG-01 33, the infant will 0

always receive the maximum dose rate. The atmospheric dispersion coefficients (XIQ) used are 6.05 E-5 sec/m3 for the calculation of the FAST alarm setpoint and 3.9 E-6 1CU -I-o0 N sec/m3 for the SLOW alarm setpoint.

.- Alarm Setpoint Calculations for H-3 and Particulates with Half-Lives "U Greater than 8 days C

-6 0 a.- QP 1500 mRem/yr (2.11)

-5 , [Pi, (inhalation) x Ro] (.IQ) where:

Qp,= the maximum allowed total release rate of a typical mixture of radionuclides in J.Ci/sec conservatively derived from the allowed annual average dose rate to organ -rand very conservative xIQ.

aW Rpi = the ratio of the activity of nuclide i, to the total activity of all nuclides in a Mtypical mixture being released.

ODCM 13 Rev. 13

--- r-~

x/Q = the atmospheric dispersion coefficient as given above for FAST or SLOW 6

alarm respectively, in sec/m 3.

I.

Resolution of the Pi, term in Equation 2.11 yields:

E 0

A? Pi, (inhalation) = (106 pCi/ýtCi) (BR) (DFAT,) (2.12) where:

0 DFAT, = the inhalation dose factor for an infant, for the ith CL W radionuclide, for organ ,r, in mRem/pCi.

0.

BR = infant breathing rate, in m3 /yr.

(N c0 '~

To calculate the alarm setpoint in terms of total j.Ci deposited on filter sample media, I the following equation is used:

U-U- Qsa =` Lowest Qp,x AF (2.13)

FS

.C 0) where:

CU 0

Lii Qsa = the activity in pCi (deposited on sample media in sample time AT) which Cl, initiates an appropriate alarm in the stack effluent monitor.

Qp, = pCi/sec ai) 0)

FS = stack flow rate, cc/sec AF = total flow through sample media (cc), in sample time AT, corrected to

-o z stack gas conditions. AT is normally 7 days.

0

-1 z

0 The procedure outlined below is used to calculate the release limits for radionuclides.

-U CL This will be done at least annually.

ODCM 14 Rev. 13

NOTE: This procedure is applicable for the determination of either FAST or SLOW alarms by utilizing the appropriate value for xIQ in the equation.

o 1. Start on Figure 2.2. Enter the date, the alarm setpoint being calculated, (FAST or SLOW) and the appropriate xIQ value to be used.

0

2. Enter the average release rate for the period, QPj, in pjCi/sec, of each

.A?

C,* identified radionuclide. At the bottom of the form, compute and enter the sum 0

3. In the column labeled Rpi, enter the ratio of the average period release C) o rate of nuclide i to the average total period release rate, ZQPi, r _ for the period.

LL

4. For each organ c, as noted at the top of the form, calculate and enter the C

value of (xIQ) (Rpi) Pi(inhalation) for each nuclide. Pi, (inhalation) values

a. M3 Uare

- found on Table 2.1. At the bottom of the column, for each organ, enter the value of T Rpi P,, (xQ) for that organ.

CVi

5. Go to Figure 2.3. Enter the date and the alarm setpoint being determined.

6. Using the equation at the top of Figure 2.3, calculate the release rate limits, Qp,, for each organ -r.

W-W w

7. Select the lowest value of Qp, enter at the bottom of Figure 2.3 under CL appropriate blower operation. Multiply the Qp number times the total 0

sample flow through the sample media, cc, and divide this by the ODCM 15 Rev. 13

appropriate blower flow rate, cclsec, to determine the Qsa in [LCi and use cc a these as alarm setpoints.

0 E

0 C:

(D 0.

0)

Cu LL LL cn cu P-0) 0)

CuL ODCM 16 Rev. 13

LARRY or

°repared Revised By L. NELSON Date 9/17/12 Rad. Prot. Engineer SEYMOURJ RFF, P u-. w Date 9/24/12 *. 2 II Operations Review*<-

Comm. Approval LDa' Figure 2.2 Date H-3 AND PARTICULATE GASEOUS RELEASE MONITOR ALARM SETPOINT DETERMINATION Alarm being calculated (FAST or SLOW) T/Q sec/M3

Nuclide i Qpi Rpi (xIQ) Rpi Pi, (inhalation) **

W Body Bone Liver Thyroid Kidnej y L GI-LLI H-3 Co-60 Sr-90 Cs-1 34 Cs-1 37 Ce-144 XQPI=

II _ I _I I f I I

For FAST alarm use 6.05 E-5 sec/m3 for x/Q and for SLOW Alarm use 3.90 E-6 sec/m 3

- P, (inhalation) values found in Table 2.1.

ODCM 17 Rev. 13

W 1;0 Figure 2.3 H-3 AND PARTICULATE GASEOUS RELEASE MONITOR ALARM SETPOINT

SUMMARY

0, Calculation for (FAST or SLOW) alarm.

0-0.2 1500 mRem/yr Y_1 [Pi, (inhalation) x Rpi x xJQ]

.2

= maximum allowed total release rate, iiCi/sec to meet dose rate limit to 0

organ -c.

1: X'.(XQ) Rpi Pi, (inhalation)

QPr (g.Ci/sec)

(N Whole Body C) -N Bone Liver Thyroid (1 IL C,

Kidney C,

a. Lung 0

GI-LLI wU (j,

0,

From Figure 2.4 (N One-Blower Operation Two-Blower Operation Qsa = Lowest Qp, x AF Qsa = Lowest QP, x AF 1.650E7 3.304E7

>1 z where:

0 AF = corrected total flow through Qsa = uiCi/.Pec x cc C) sample media, cc 3.304 E7 cc/sec z

1'ci 0

-0 Qsa = aCi/£ec x CC a 1.650 E7 cc/sec

_____ __ jCi ODCM 18 Rev. 13

, repared or Revised By Date Rad. Prot. Engineer P Date Ow Operations Review Comm. Approval Da LARRY L. NELSON 9/17/12 SEYMOUR J. RAFFL,. 9/24/12 /t,//,

Table 2.1 INFANT DOSE FACTORS Pi, (INHALATION) FOR H-3 AND PARTICULATE GASEOUS RELEASE MONITOR ALARM SETPOINT DETERMINATIONS In Units of mRem-m3 /pCi-yr Nuclide Whole Body Bone Liver Thyroid Kidney Lung GI-LLI H-3 6.47 E2

6.47 E2 6.47 E2 6.47 E2 6.47 E2 6.47 E2 C0-60 1.18 E4 8.02 E3 *

4.51 E6 3.19 E4 SR-90 2.59 E6 4.09 E7 * *

1.12 E7 1.31 E5 CS-134 7.45 E4 3.96 E5 7.03 E5

1.90 E5 7.97E 4 1.33 E3 CS-1 37 4.55 E4 5.49 E5 6.12 E5

1.72 E5 7.13 E4 1.33 E3 CE-144 1.76 E5 3.19 E6 1.21 E6

5.38 E5 9.84 E6 1.48 E5 Values in this table are derived from Tables E-5 and E-10 in App. E of NRC Regulatory Guide 1.109 Rev. 1, October 1977.

No data available.

ODCM 19 Rev. 13

Calculation of Gamma and Beta Air Dose Commitments Co '

In accordance with the RECP, the gamma and beta air dose commitments are to be calculated once per calendar quarter and yearly. Equations 2.14 and 2.15 are used to 0D perform these calculations.

E b) To demonstrate compliance with the limitations of Section 3.3.3.c, dose o

contributions are calculated for H-3, and particulates with half-lives greater than 8 days, identified in gaseous effluents released to unrestricted areas using the ca methodology presented in NRC Regulatory Guide 1.109, Rev 1, October 1977.

0 This methodology takes the form of the following general equation:

D,, (r, 0)= MPi.. W(r, 0) Qi (2.16) where:

J Da (r,O)= the dose commitment to organ -rof an individual in age group a, at a distance r in sector 0 from the release point, due to the release to the atmosphere of radionuclides in mRem.

W(r, 0) = the average dispersion parameter for estimating the dose to an individual at the receptor location (r, 0), for the period of release, in sec/m 3 or m-2 as required by the characteristics of the exposure pathway.

Q = the total activity of each radionuclide i, in gaseous effluents for the release period of interest, in pCi.

MPiTa = the dose conversion factor for exposure pathway P to organ "r of an individual in age group a, for each identified radionuclide i. The units of MiTa are (mRem-m 2 )/4iCi or (mRem-m 3 )/pCi-sec) as required so that the product MPi,.a W(r, 0) is mRem/gCi.

0 ~

Equation 2.16 may be expanded to the following form where each term is the incremental dose received via one of the three major dose pathways.

ODCM 20 Rev. 13

D,. (r, 0) = I DGit.a (r, 0) + DAi'. (r, 0) + D itaz (r, 0) (2.17)

C, where the first term on the right is the external dose from direct exposure to activity 0 deposited on the ground plane, the second term is the dose from inhalation of CL radionuclides in air, and the third term is the dose from ingestion of foods contaminated 0~

0 4 by atmospheric releases of radionuclides.

Applying the methodology of NRC Regulatory Guide 1.109 Rev. 1, equation 2.17 is expanded as follows:

CL 0

Dta (r, 0) = mG iTaQj (D/Q)(r, 0) (2.18) 4)

+ T MAia Qj (xIQ)(r, 0)

0. CN 0) 0;

+ DMiTa Qi (D/Q)(r, 0) + (MDV14Ta Q14 + MDVTTa QT) (x/Q)(r, E) a)

0U U-

+ M0 MiTa Qi (D/Q)(r, E) + (MDM14Ta Q14 + MDMTta Qr) (YdQ)(r, E)

LiU

+ Z MOLia Qi (D/Q)(r, E) + (MDM14Ma Q14 + MDMTia QT) (xIQ)(r,E)

Cl) +

MD0 iya 0i (DIQ)(r, 0) + (MDLl 4 Ta 014 + MDLTma Or) (*dQ)(r, 0) a) rN-where:

0 (xJQ)(r, 0)= the annual average atmospheric dispersion factor for a receptor at the distance r in sector 0 from the release point, in sec/m 3 .

z For the LACBWR in the SAFSTOR mode, the value for this term 0 is conservatively taken to be the largest historical (1983-1987) undecayed/undepleted x/Q for a real receptor and is 1.82E-6 z

sec/m 3.

0 (D/Q)(r, 0)= 1.82E-9m- 2 . This is based on the relationship D/Q = Vd xIQ where Vd = the deposition velocity in m/sec. Vd is generally < 1 E-3m/sec for dry deposition of submicron aerosols which may be ODCM 21 Rev. 13

released from the LACBWR facility during SAFSTOR (Ref Whicker, F. W. and Schultz, V., Radioecology: Nuclear Energy and the Environment, Vol. II, CRC Press, Inc., Boco Raton, Florida, 1982.

MG Ta = 1.06 SF DFGj, (1 - exp(-).itb))/Xi and according to R.G. 1.109 the dose to all internal organs (T)for all age groups (a) is taken to be the same as P the total body dose.

'C E MAita = 3.17E-2 BR, DFAiTa 01

> and for the ingestion pathway (DV) for produce (non-leafy-vegetables, fruits, and grains)

SMDVita = 1.1 E2 DFlita UVa fg exp(-Xith)(r(1 - exp(-XEite))/YvXEi +

~Biv (1 -exp(-?.iitb))/ PXi)

C%

for all radionuclides except C-1 4 and H-3 1)4T- - 22 l4Ta Uag p for 0-1 4 0.L mDV TTa =12 DEITta U~a fg/H for tritium UL for the ingestion pathway (Din) for milk

MDMita =1.1E2 DFIi-a Um Fmi QFexp(-Xitr)(fpfs(1-exp(-Xith )) + exp(-Xi th))

0) x (r(1-exp(-XEi te))/YvXEi + Biv (1 - exp(-41 tb))/PXi) for all radionuclide except C-14 and H-3 MDM M)1 4-a = 22DFI14,a U' Fmi QF p(exp(-X14tf)) for C-14 MDmTra = 12DFITa Um Fmi QFexp(-XTtf)/H for tritium for the ingestion pathway (DM) for meat MDMiTa = 1.1 E2 DFlita Um Ffi Qfexp(-Xits) (fpfs (1 - exp(-Xith)) + exp(-Xith))

0 -i x (r(1-exp(-?.Eite))/YvXEi + Bj,(1 - exp(-k4tb))/PXli) for all radionuclides except C-14 and H-3 ODCM 22 Rev. 13

mjDM 1T 22DFI,4,a Um Ff14 QF p(exp(-X14ts)) for C-14 N

mDMTTa = 12 DFITta Ua Frr QFexp(-XTts)/H for tritium 0

for the ingestion pathway (DL) for leafy vegetables:

0.

MDLita = 1.1 E2DFli, ULa fe exp(-Xith)(r(1 - exp(-)Eite))/YvXEi+Bjv(1 - exp(-4,tb))/P).i) for all radionuclides except C-14 and H-3.

AI) MDL 14ra 22DFI14Ta U, eP for C-14 C:

0 MDLTTa = 12DFITa U*fe/H for tritium 0.

0 The values used for the various parameters in the above equations are those recommended in NRC Regulatory Guide 1.109, Rev. 1, for the maximum exposed

0) individual.

Parameter Dimensions Description/Source M U-1.0E6 pCi/PCi CM C

DFGIjT mRem-m 2/pCi-hr from table E-6 in R.G.

.6 0w DFAita mRem/pCi inhaled from table E-7 thru E-10 in R.G.

CU Wl DFA14,a mRem/pCi inhaled from table E-7 thru E-10 in R.G.

DFAT~a mRem/pCi inhaled from table E-7 thru E-10 in R.G.

CN DFliTa+ mRem/pCi ingested from tables E-1 1 thru E-14 in R.G.

DFI14 na mRem/pCi ingested from tables E-1 1 thru E-1 4 in R.G.

DFIrTa mRem/pCi ingested from tables E-11 thru E-14 in R.G.

SF = 0.7 dimensionless attenuation factor accounting for C3 -J U))

shielding by residential structures

), hr"1 radiological decay constant for nuclide i.

tb = 1.31x105 Hr period of long-term buildup for activity in soil (nominally 15 yrs) 3.17x1 0-2 pCi - yrlICi- sec ODCM 23 Rev. 13

inhalation rate for age group a.

BRa m 31yr Table E-5 in R.G.

1.1x10 2 _ pCi - yr/pCi - hr CA. Parameter Dimensions Description/Source U vkg/yr consumption rate of produce for individual in age group a. Table E-5 of R.G.

fg = 0.76 Dimensionless fraction of produce ingested that is 0.

- grown in garden of interest.

th hr time delay between harvest of 0 vegetation or crops and ingestion.

=0 for pasture grass by animals

= 2160 for stored feed by animals

= 24 for leafy vegetables by man C%4

= 1440 for produce by man C

0 r = 0.2 dimensionless fraction of deposited activity retained on crops, leafy vegetables, or 0 pasture grass.

XEi = ý, + Xw hr 1 the effective removal rate constant LiL for radionuclide i from crops.

Xw = .0021 hr' removal rate constant for activity on plant or leaf surfaces by weathering

,,,___(z to 14 day half-life) 0 te hr period of crop, leafy vegetable, or pasture grass exposure during growing season.

= 720 for grass-cow-milk-man pathway

= 1440 for crop/vegetation-man pathway

0) N Yv kg/m 2 agricultural productivity (measured in

_wet weight)

= 0.7 for grass-cow-milk-man pathway

-o = 2.0 for produce or leafy vegetables CO z0 ingested by man Biv dimensionless pCi/kg in vegetation per pCi/kg in

0) z soil for nuclide i. Table E-1 in R.G.

-j P = 240 kg/m 2 effective surface density of soil (dry weight) 0)

22 pCi - yr - m3/pCi- kg -

_sec ODCM 24 Rev. 13

~~1~~ p dimensionless the ratio of the total annual release N time for C-14 to the total annual time during which photosynthesis occurs with the condition that p< 1.0 Parameter Dimensions Description/Source 0

ca P

ca.

= 1.0 for continuous C-14 releases.

E 0 12 pCi - g - yrlpCi- kg - sec H = 8.0 g/m 3 average absolute humidity of the A) atmosphere at location (rO)

CU a liters/yr consumption rate of milk for C individual in age group a. Table E-5 of R.G.

a) -mi day/I factor for estimation of activity of 0.

0 nuclide i in milk from that in animal feed (pCi/I in milk per pCi/d ingested C%4 by the animal) Table E-1 in R.G.

C(4 QF = 50 kg/day feed or forage consumption rate (wet weight) by milk cow or beef cattle tf = 48 hr transport time from animal feed-milk-

_U U-man.

U-fp = 0.5 dimensionless fraction of the year that animals a) 0)

graze on pasture.

C CU fý = 1.0 dimensionless fraction of daily feed that is pasture when the animal is on pasture 0

UM . kg/yr consumption rate of meat & poultry w) for individual in age group a. Table E-5 of R.G.

Ff1 day/kg factor for estimation of activity of (N

nuclide i in meat from that in animal

0) feed (pCi/kg in meat per pCi/day 0

0) ingested by the animal) Table E-1 in R.G.

ts = 480 hr average time from slaughter of meat animal to consumption of meat

>1 z U kg/yr consumption rate of leafy vegetables 0

0I) -1 for individual in age group a. Table z E-5 in R.G.

0 fe = 1.0 dimensionless fraction of leafy vegetables grown in garden of interest.

ca-0 ODCM 25 Rev. 13

Calculations of Dose Commitments due to Gaseous Release In accordance with the RECP, the maximum commitment to a MEMBER OF THE

> PUBLIC from H-3 and all radionuclides in particulate form with half-lives greater than 0

0.

< 8 days shall be determined at least quarterly.

E 0

To perform this calculation Eq 2.18 has been formatted on a computer-based spreadsheet. The quantity in curies of each nuclide (i) released to the atmosphere from in the appropriate cell of the 0 the LACBWR facility during the calendar quarter is entered spreadsheet. The spreadsheet program calculates and displays the total quarterly dose 0

in mRem to the total body and each organ of an individual in each of four age groups and the cumulative calendar year dose to the total body and each organ. It also 0)

determines the maximum exposed organ (and its dose) for each age group each quarter and the dose to the maximum exposed organ in all age groups. The quarterly and cumulative calendar year doses to the maximum exposed organ are compared to x,-

1_ the limits and the relation in terms of percent of the limit is displayed. The maximum

,,= incremental organ dose received through each of the three major pathways is also determined for each age group each quarter.

0-6 M (nJ c~r -

..-z

'0 0 3 J 0O2W o

0 00CM 26 Rev. 13

3.0 RADIOACTIVE EFFLUENT CONTROL PROGRAM 0

3.1 Program Requirements The Radioactive Effluent Control Program (RECP) shall conform to the guidance 0.

0.

of 10 CFR 50.36a for the control of radioactive effluents and for maintaining the 0 doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as 0

3: reasonably achievable. This program shall establish the requirements for monitoring, sampling and analysis of radioactive gaseous and liquid effluents released from LACBWR to ensure the concentrations in effluents released to C) d areas beyond the EFFLUENT RELEASE BOUNDARY conform to 10 CFR Part 20, Appendix B, Table 2, Columns 1 and 2. It shall provide limitations on the c.

(0 CN C) annual and quarterly dose commitment to a MEMBER OF THE PUBLIC from radioactive effluents in conformance with Appendix I of 10 CFR Part 50.

Wa,-J The limitations of operability of gaseous and liquid monitoring instrumentation, LL

.C including surveillance test and setpoint determination in accordance with Section CW LU Z 2.0, Offsite Dose Calculations, will be included in this program.

CUU) Requirements for the Reactor Building Ventilation System, including filtration and elevated stack release of exhausted air is included in Section 3.3.1.

CN In accordance with provisions of 40 CFR 190, the restrictions and surveillance requirements for total dose to any MEMBER OF THE PUBLIC from all LACBWR related sources and dose pathways are presented in Section 3.4.

C/)

a) W 0

ODCM 27 Rev. 13

3.2 Liquid Effluents 3.2.1 Samplina and Analysis 01 All liquid effluent releases at LACBWR will be in batch form. A batch

-a release is the discharge of liquid wastes of a discrete volume. Prior to CL sampling for analysis, each batch shall be isolated and then thoroughly mixed, to assure representative sampling. The radioactive content of E

U each batch of radioactive liquid waste to be discharged shall be a)

> determined, as per the following table:

Cr_

C 0~

C14 Ca 'Cj-I>

0: LL (DU a) 0)

-J a)W

.rC 28Rv.1

Table 3.1

__T RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS REQUIREMENTS FOR BATCH RELEASES P

I 0L6 TYPE OF ACTIVITY ANALYSIS (C)

SAMPLING FREQUENCY MINIMUM ANALYSIS FREQUENCY 0 1. Principal Gamma emitters (b) Prior to discharge Each discharge - prior to C-)

K 2. Gross Alpha Prior to discharge discharge Each discharge - prior to I

discharge C:

0 3. Tritium Prior to discharge Each discharge

4. Sr-90 and Fe-55 Beta emitters Prior to discharge Quarterly Composite (a)

W) (a) A composite sample is one made up of individual samples which are proportional to the aU quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquid release.

(b) The principal gamma emitters for which the LLD specification will apply are exclusively UL U_ the following radionuclides: Co-60, Cs-1 34, and Cs-1 37. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

D (c) Methods of calculating the Lower Limits of Detection (LLD) shall be contained in plant 0

procedures and are calculated in accordance with criteria of NUREG-0473, Rev. 2.

C',

CN cu r- The results of pre-release analyses shall be used in accordance with the Offsite 0)

Dose Calculations methodology to assure that the concentration at the point of release is maintained within the limits specified in this RECP.

z 0

C','

-j 0

CL ODCM 29 Rev. 13

3.2.2 Liquid Effluent Release Limitation

-4 a) Concentration - the concentration of radioactive material released in liquid effluents at any time to areas beyond the EFFLUENT RELEASE CL BOUNDARY shall be limited to concentrations specified in 10 CFR E

oo Part 20, Appendix B, Table 2, Column 2.

If the concentration of radioactive material released beyond the C

1 EFFLUENT RELEASE BOUNDARY exceeds the above limits, restore a) o the concentration to within the above limits without delay.

This limit is provided to ensure that the concentration of radioactive

0) materials released in liquid waste effluents from the site will be less than the concentration levels specified in 10 CFR Part 20, Appendix B,

- ~ Table 2, Column 2.

LL C

Lx b) Dose - the dose or dose commitment to a MEMBER OF THE PUBLIC

. D o from radioactive materials in liquid effluents released to areas beyond 0 W'the Effluent Release Boundary shall be limited to:

Calendar Quarter Calendar Year CN

.2 ,~

o * <1.5 mRem total body <3 mRem total body

_<5 mRem to any organ <__10 mRem to any organ 0)

The cumulative dose contribution from liquid effluent shall be W Z determined at least once per calendar quarter in accordance with Section 2.0, Offsite Dose Calculations. If this calculated dose exceeds the above limits, prepare and submit to the Commission, within 30 days, a Special Report which identifies the cause(s) for ODCM 30 Rev. 13

exceeding the limit(s) and defines the corrective actions which have been or will be taken to assure that subsequent releases shall be in compliance with the above limits.

This limit is provided to implement the requirements of Sections II.A, Ill.A, IV.A and Annex of Appendix 1,10 CFR Part 50. The dose calculations in Section 2.0 implement the requirement in Section IIL.A 0

of Appendix I that conformance with the guides of Appendix I be A?

shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate CL o3 pathways is unlikely to be substantially underestimated.

3.2.3 Liquid Effluent Instrumentation The following radioactive liquid effluent monitoring instrumentation channels shall be OPERABLE, with their alarm setpoints set to ensure

,~LL that the limits of Section 3.2.2.a are not exceeded, at all times when releasing liquid radioactive effluents.

-6 w Liquid Radwaste Effluent Line Monitor and C6 I- Liquid Radwaste Effluent Line Flow Meter The alarm setpoints for this monitor will be determined and adjusted using omethodology 0 in Section 2.0, Offsite Dose Calculations.

U) /

(D W The radioactive liquid effluent instrumentation is provided to monitor the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents with the alarm setpoints set to ensure that the alarm will occur prior to exceeding the limits of 10 CFR Part 20.

ODCM 31 Rev. 13

a) Surveillance Req~uirements - each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL FUNCTIONAL TEST, and CHANNEL CALIBRATION operations at the frequencies shown in E the following table.

E 0

U)

C:

00 C) 0.

CN U-I C:

oj cC6~

-0 U) UW ODCM 32 Rev. 13

Table 3.2 I- RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Functional Channel 0~

Check Checks Test Calibration

0. Liquid Radwaste Prior to discharge Prior to (Saeel poer1 At 18emonths3 least once Effluent Line Monitor discharge (see Note 4) (See Note 1) per 18 months d) 0.

~0 Liquid Radwaste At least once CZ Effluent Line Flow (See Note 2) N/A N/A per 18 months Meter (See Note 5)

C4 NOTES

(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room U-U-

alarm annunciation occurs if any of the following conditions exist:

Instrument indicates measured levels at the alarm setpoint.

W Instrument indicates a downscale (circuit failure) failure.

0)

CL (2) CHANNEL CHECK shall consist of verifying indication of flow during periods 0

A) 0 of release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days in which continuous, periodic, or batch releases are made.

(12 (3) The CHANNEL CALIBRATION shall include the use of a known liquid radioactive source positioned in a reproducible geometry with respect to the CU sensor. The source will have the gamma emitting radionuclide mixture and activity concentration which would normally be measured by the channel during batch discharges.

(4) Background radiation may be used for the source check.

a) z 0 (5) The CHANNEL CALIBRATION will be in accordance with plant procedures.

z 0.

O DCM 33 Rev. 13

b) Corrective Action 0 (1) With the Liquid Radwaste Effluent Line Monitor channel alarm/trip-point setpoint less conservative than that required by Section 3.2.2(a), immediately suspend the release or CL CL change the setpoint so that it is acceptably conservative.

E E

0 (2) With the Liquid Radwaste Effluent Line Monitor NOT go)

OPERABLE, or if its alarm setpoint is found to be less conservative than required, suspend release of liquid Ca 0ý radioactive effluent without delay. Effluent releases may be 0

resumed without the Liquid Radwaste Effluent Line Monitor OPERABLE, provided that at least two independent samples are analyzed and that at least two technically qualified members of the staff independently verify the release rate C- ,, calculations. If the monitor is not operable for more than 30

.continuous days, explain in the next Annual Effluent Report.

0) --)

C (3) With the flow meter not OPERABLE, 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 during actual releases.

Ca 03 -j U) W) 0 ODCM 34 Rev. 13

3.3 Gaseous Effluents 3.3.1 Reactor Building Ventilation Normal air discharge from LACBWR is made as an elevated stack release. Air is swept through the Turbine and Reactor Building and then

< discharged out the stack where the particulate activity is monitored prior to 0release.

A)

If at any time a verified FAST alarm condition occurs on either of the stack gparticulate effluent monitors, filtration of the Reactor Building Ventilation CL System exhaust SHALL COMMENCE as soon as practicable through a 0

set of HEPA particulate filters to reduce the amount of radioactive CI r~particulates being released to the environment.

ca With Reactor Building Ventilation System exhaust being discharged without filtration during periods of a verified FAST alarm condition on either of the stack particulate effluent monitors, prepare and submit to the Commission within 30 days a Special Report which discusses the Lcircumstances and what action will be taken to prevent a recurrence.

3.3.2 Stack Effluent Sampling and Analyses C)-

o ~The0) radioactive gaseous discharge from LACBWR will be sampled and analyzed as per the following table.

v'z X -

CL 0

0 ODCM 35 Rev. 13

Table 3.3 CU1~

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS Release Sampling Minimum Analysis Type of 0L Type Frequency Frequency Activity Analysis (d)

Stack Continuous (b) Weekly (a) Particulate Sample Principal Gamma Emitters (c) 0~

Effluent Continuous (b) Quarterly Particulate Sample Sr-90 0U Composite 0( Continuous (b) Weekly (a) Particulate Sample Gross Alpha Monthly Monthly H-3 CL)

NOTES:

0)-

(a) The filter sample shall be changed at least weekly, and filter analyses shall be completed within seven (7) days.

(b) The ratio of the sample flow rate to the sampled stream flow rate shall be known Aj U-for the time period covered by each dose or dose rate calculation.

(c) The principal gamma emitters for which the LLD specification applies exclusively are

.5)

C the following radionuclides: Mn-54, Co-60, Zn-65, Cs-134, Cs-137, and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be 0 0 considered. Other gamma peaks that are identifiable and measurable, together with Q- those of the above nuclides, shall also be analyzed and reported in the annual U) Radioactive Effluent Release Report.

(d) Lower Limits of Detection (LLD) are determined in accordance with plant procedures and are calculated in accordance with criteria of NUREG-0473, Revision 2.

C'4 Z

0 U,

-J w

0) z XJ 0)

ODCM 36 Rev. 13

3.3.3 Stack Effluent Release Limitation a) Instantaneous Dose Rate - the dose rate due to radioactive materials released in gaseous stack effluents to areas beyond the EFFLUENT RELEASE BOUNDARY shall be limited to:

0.

< The dose rate limit for H-3 and for all radionuclides in 0E particulate form with half-lives greater than 8 days shall be <

1500 mRem/year to any organ.

Cn C

0 0

The dose rate due to H-3 and for all radioactive materials in particulate form with half-lives > 8 days in gaseous stack effluents shall be determined to be within the above limits in accordance with C4 Section 2.0, Offsite Dose Calculations, by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 3.3.

If the dose rate(s) exceeds the above limits, without delay decrease D the release rate to within the above limit(s).

0 U)This CU instantaneous dose rate limit is provided to ensure that the dose rate at any time at the EFFLUENT RELEASE BOUNDARY from gaseous effluents from LACBWR will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20,

,) (Appendix B, 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 in an unrestricted area, outside the EFFLUENT RELEASE BOUNDARY to annual average concentrations exceeding the limits specified in Appendix B, Table 2 ODCM 37 Rev. 13

of 10 CFR Part 20. For individuals who may at times be within the EFFLUENT RELEASE BOUNDARY, the occupancy of the individual 0

will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the EFFLUENT RELEASE C.

BOUNDARY. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the EFFLUENT RELEASE BOUNDARY to

<500 mRem/year to the total body or to < 3000 mRem/year to the skin. These release rate limits also restrict, at all times, the corresponding organ dose rate above background to an individual via 0.

the inhalation pathway to < 1500 mRem/year.

co 'IT b) Dose from Radionuclides - the dose to a MEMBER OF THE PUBLIC from H-3, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released to areas beyond SU-the EFFLUENT RELEASE BOUNDARY shall be limited to:

.0)-

Calendar Quarter

< 7.5 mRem to any organ Calendar Year

< 15 mRem to any organ The cumulative dose contributions shall be determined at least once per calendar quarter in accordance with Section 2.0, Offsite Dose

-z0 a

Calculations.

With the calculated dose from the release of H-3 and all 0.

(D radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding any of the above limits, prepare and ODCM 38 Rev. 13

submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions which have been taken or will be taken to reduce

-X these releases in gaseous effluents during remaining quarters so that 0n the cumulative dose during each subsequent quarter and during the Ecalendar year will be within the above limits.

E This limit is provided to implement the requirements of Sections II.C, 0 *:* IllI.A, IV.A and Annex of Appendix I, 10 CFR Part 50. The 00CM CO calculational methods specified in the surveillance requirements o implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational o ,4procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

u_

.C . 3.3.4 Instrumentation

_ The radioactive gaseous effluent monitoring instrumentation channels CU U) shown in Table 3.4 shall be OPERABLE with their alarm setpoints set to ensure that the limits of Section 3.3.3a are not exceeded.

C-.

a) Gaseous Effluent Instrumentation Surveillance Requirements-Each radioactive gaseous effluent monitoring instrumentation z

0 channel shall be demonstrated OPERABLE by performance of the w C)

CHANNEL CHECK, SOURCE CHECK, CHANNEL FUNCTIONAL Z

-0 TEST, and CHANNEL CALIBRATION operations at the frequencies CU

~- shown in Table 3.5.

03 ODCM 39 Rev. 13

b) Corrective Action 16(1) With a radioactive gaseous effluent monitoring instrumentation channel alarm setpoint less conservative than that required, declare the channel inoperable or change

< the setpoint so that it is acceptably conservative.

E 0

_(2) With less than the minimum number of radioactive gaseous w effluent monitoring instrumentation channels OPERABLE, 0 take the ACTION required by Table 3.4. Exert best efforts to CL return the instruments to OPERABLE status within 30 days 0

and, if unsuccessful, explain in the next Annual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

ULL U..

0>.

0)

(30

() W 0

00CM 40 Rev. 13

Table 3.4

~~~1~ RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS APPLICABLE INSTRUMENT OPERABLE CONDITIONS ACTION

1. Stack Monitor System

a. Particulate Activity Monitor 1 B

b. Sampler Flow Rate Measuring 1 A 0

0.

Si Device 0

- At all times, unless alternate monitoring is available ACTIONS:

04 A. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue I

.C:

0) provided the flow rate is estimated at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

C, 0..

0 B. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue C) L_U 5

provided continuous collection of samples with auxiliary sampling equipment is U- initiated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

0 CU X

w (N

4) z 0

Cl)

-J z

0 cc ODCM 41 Rev. 13

Table 3.5 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL 0 CHANNEL SOURCE FUNCTIONAL CHANNEL (3) I INSTRUMENT CHECK CHECK TEST CALIBRATION 0.

1. Stack Monitor System

a. Particulate Activity DAILY N/A QUARTERLY AT LEAST E

0 Monitor (1) ONCE PER 18 MONTHS

b. Sampler Flow Rate DAILY N/A QUARTERLY AT LEAST C: Measuring Device (2) ONCE PER a)( 18 MONTHS CX 0

N)

NOTES:

CU (1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a. Instrument indicates measured level above the alarm setpoint on one channel.

b. Instrument indicates a failure by a Low Flow and Low Count Rate signal.

0)

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that the control room local alarm occurs if the flow instrument indicates measured levels below the minimum and/or above the maximum alarm setpoint.

(3) The CHANNEL CALIBRATION shall be conducted in accordance with plant procedures.

C 0

3.4 Total Dose to a Member of the Public 2~

The dose equivalent to any MEMBER OF THE PUBLIC due to release of radioactivity and radiation, shall be limited to < 25 mRem to the total body or any CD organ (except the thyroid, which is limited to < 75 mRem) over a period of one calendar year.

z a) 0 Ci)

With the calculated doses from the release of radioactive materials in liquid or

-j w

C) z gaseous effluents exceeding twice the calendar year dose limits specified in

-j Sections 3.2.2b, 3.3.3b, or 3.3.3c, a determination should be made, including direct radiation from Reactor Building and radioactive waste storage tanks to determine if the above limits have been exceeded. If these limits have been ODCM 42 Rev. 13

exceeded, prepare and submit a Special Report (including an analysis which estimates the radiation exposure to a MEMBER OF THE PUBLIC for the calendar year) to the Director, Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555, within 30 days, which defines the corrective action to be taken to reduce subsequent releases to prevent E recurrence of exceeding these limits. Ifthe release condition resulting in the S

0 excess has not already been corrected, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190.

Cl)

Submittal of the Special Report is considered a timely request, and a variance is granted until staff action on the request is complete.

0 Cumulative dose contributions from liquid and gaseous effluents shall be determined quarterly and annually in accordance with Section 2.0, Offsite Dose Calculations.

Cumulative dose contributions from direct radiation from the reactor containment or radioactive waste storage tanks shall be determined once per year in

. Daccordance with Section 4.0, Radiological Environmental Monitoring Program.

This requirement is provided to meet the dose limitations of 40 CFR 190.

Whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I, a Special Report will be submitted which describes a course of action which should result in the limitation of dose to a real individual for 12 consecutive months to within the 40 CFR 190 limits.

vz 00 For conservatism, for compliance with this limit, the maximum total dose to any MEMBER OF THE PUBLIC will be assumed to be the sum of the maximums from each dose pathway even though the actual maximally exposed individual for each of the pathways could not be the same person.

ODCM 43 Rev. 13

The maximum potential dose to a MEMBER OF THE PUBLIC from direct radiation from the Reactor Building and radioactive waste storage tanks is determined by TLD dosimeters located at various locations around the perimeter of the LACBWR access controlled area and the EFFLUENT RELEASE BOUNDARY for the environmental monitoring program. For compliance with this E limit, the actual maximum possible exposure to an actual MEMBER OF THE E

0 PUBLIC from direct radiation may be determined from maximum possible exposure times relative to the continuous exposure dose measured by the TLD's.

0 Conservative maximum possible exposure times will be determined by actual observation of the areas of interest by LACBWR management and/or security 0

personnel.

("S t U-C 0-(U W 0) z 0

G qi) WU W zL 0

ODCM 44 Rev. 13

4.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 4.1 Program Requirements U The Radiological Environmental Monitoring Program (REMP) shall conform to the 0 guidance of Appendix I to 10 CFR Part 50. The REMP shall provide the

> requirements for monitoring, sampling, analyzing, and reporting radiation and radionuclides in the environment resulting from the LACBWR facility and/or its effluents. These requirements have been established to ensure the C)_ measurements of radiation and of radioactive material in potential exposure Wpathways to MEMBERS OF THE PUBLIC are performed. Various environmental U)

C:

=cc samples will be taken within the area surrounding LACBWR and in selected 4)(

0CL controlled or background locations. An Interlaboratory Comparison Program shall be established to ensure that independent checks on the precision and Cq u'T-accuracy of the measurements of radioactive material in the environmental sample matrices are performed, as part of quality control for environmental monitoring.

aU-IL L: The radiological monitoring program required by this specification provides C:

measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides, which lead to the highest potential o0 radiation exposures of individuals resulting from plant effluents. This monitoring program theory supplements the radiological effluent monitoring program by C) verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.

-0 z0

)WThe requirement for participation in an Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the CL~

measurements of radioactive material in environmental samples are performed to demonstrate that the results are reasonably valid.

ODCM 45 Rev. 13

4.2 REMP Description Radiological environmental monitoring samples will be collected and analyzed in accordance with Table 4.1. The specific sample locations are listed in HSP-03.1.

Section 3 of the Health and Safety Procedures (HSP's) shall contain procedures CL to provide specific guidance to the HP technicians in the collection and analysis E of each environmental sample.

E 0

C) 0(

OLi 2 -

C)0 CL L

- LL2 (D

CU 0)

CO) (12 0) 00M46Rv.1

Drepared or Revised By Date Rad. Prot. Engineer P' ".w Date Operations Review Comm. Approval De' LARRY L. NELSON 9117/12 SEYMOUR J. RAFFL. Y 9/24/12 (L Q (

Table 4.1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Sampling and Collection Type and Frequency of Analysis and/or Sample Samples (A) Frequency

1. AIRBORNE Three (3) Continuous operation (1) Analyze each filter for gross beta PARTICULATES of sampler with radioactivity > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following filter sample collection as change. Perform gamma isotopic analysis required by dust on each sample when gross beta activity is loading, but at least > 10 times the control sample (La Crosse).

weekly.

(2) A composite of particulate filters from each location will be gamma analyzed at least once per quarter.

2. DIRECT Eight (8) At least 1) Gamma dose - at least semi-annually.

RADIATION semiannually.

3. WATERBORNE Two (2) Monthly. 1) Gamma isotopic analysis monthly on each (River Water) sample.

2) Tritium analysis on composite sample from each location quarterly.

(A) Exact sample locations are listed in HSP-03.1.

ODCM 47 Rev. 13

Prepared or Revised By I ArDDV/ I klI~l C'/**kI I""vi-'°U-

L.

4 I Date

('",

Ii 74."74

-1 l II ad. Prot. Engineer P OUR-I'" J. *

`ew F-,-L_,

T Date IIOperations Review Comm. Approval L?\

/)

t" D?'~

vo /ld/l.

_ II Table 4.1 - (cont'd)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Sampling and and/or Sample Samples (A) Collection Frequency Type and Frequency of Analysis

4. RIVER Two (2) Semi-annually (1) Gamma isotopic analysis on each SEDIMENT sample.

5. INGESTION

a. Fish One (1) sample of two At least semi-annually (1) Gamma isotopic analysis of the (2) different species in edible portions of each sample.

area important as a recreational or commercial species.

b. Milk As Determined Obtain sample if (1) Gamma isotopic analysis on each abnormal stack sample.

particulate release occurs

c. Vegetation As Determined Obtain sample if (1) Gamma isotopic analysis of the abnormal stack edible portion of each composite particulate release occurs sample.

(A) Exact sample locations are listed in HSP-03.1.

ODCM 48 Rev. 13

4.3 REMP Lower Limits of Detection (LLD) a The sampling techniques and counting equipment used for the analysis of 0

samples collected as requirements of the REMP will meet LLD's calculated in accordance with criteria of NUREG-0473, Rev. 2. LACBWR's LLD's are 0

calculated as follows and are essentially the same as those found in NUREG-0473, Rev. 2. Table 4.2 lists these values.

Cn C

0 CN

.21 LL ODC L- L 0) cuQ)

"L 0j 20)

CI4 t5~

~0-3u ODOM 49 Rev. 13

4.3.1 Calculation of Lower Limits of Detection:

The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability, with 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

0 0.

< LLD = 4.66 Sb E x V x 2.22 x Y x Exp (-XAt) 0 E

WHERE:

en C6QlLLD is the priori lower limit of detection as defined above (as picocurie per unit mass or volume).

o St is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute).

c*'iCNI E is the counting efficiency (as counts per gamma).

V is the sample size (in units of mass or volume).

2.22 is the number of transformations per minute per picocurie.

DY is gamma abundance for isotope of interest.

C k -is the radioactive decay constant for the particular radionuclide.

S>- At is the elapsed time between sample collection (or end of the sample CU)n collection period) and time of counting.

CU 0)

ODOM 50 Rev. 13

Drepared or Revised By I Date II Rad. Prot. Engineer Rr 'w I Date I Operations Review Comm. Approval Dat-I LARRY L. NELSON 19/17/12 11 SEYMOUR J. RAFFL.( F 9124/12 II k()Y 4. A.- *1 I Table 4.2 ENVIRONMENTAL SAMPLE ANALYSES LOWER LIMITS OF DETECTION VALUES (LLD)

Sample Type Analysis Water Airborne Particulate Fish Milk Sediment pCi/I or Radioiodine (pCi/M 3) (pCi/Kg, Wet) (pCi/I) (pCi/Kg Dry)

Gross Beta 6 1 E-2 H-3 3500(2000)2 Mn-54 15 130 Co-60 15 130 Zn-65 30 260 Cs-134 15 5 E-2 130 15 150 Cs-137 18 6 E-2 150 18 180 a For drinking water.

ODCM 51 Rev. 13

4.4 Interlaboratory Comparison Program An Interlaboratory Comparison Program will be established to ensure that the analyses being performed to comply with the REMP is accurate. A suitable offsite laboratory will be used to supply NIST traceable or equivalent standard CL spiked sample media for analysis. The offsite laboratory will supply a report to DPC of the comparison results. The Interlaboratory Comparison Program will be E

0 conducted annually. The results of this comparison will be included in the Annual Radiological Environmental Monitoring Report.

0 4.5 Reporting Requirements 0

a) An Annual Radiological Environmental Monitoring Report shall be submitted to the Administrator of the Regional Office of the NRC. This report shall include summarized and tabulated results, including interpretations and analysis of data trends, of environmental samples M-taken during the previous calendar year. In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing w6 data shall be submitted as soon as possible in a supplementary report.

U)

The report shall also include the following: a summary description of the

0) Radiological Environmental Monitoring Program, a map of all sampling locations keyed to a table giving distances and directions from the plant, 0 ~ the results of the Interlaboratory Comparison Program, and a discussion of all analyses in which the LLD was not achievable.

ODCM 52 Rev. 13

F b) With the REMP program not being conducted as specified in Table 4.1, 0 prepare and submit to the Commission, in the Annual Radiological Environmental Monitoring Report, a description of the reasons for not o conducting the program as required, analysis of the cause of unexpected

< results, and the plans for preventing a recurrence.

E U0 c) With the Interlaboratory Comparisons not being performed, report the corrective actions taken to prevent a recurrence to the Commission in the

£Radiological Environmental Monitoring Report.

0 d) With radiological environmental sample analysis in excess of the reporting levels listed in Table 4.3, when averaged over any calendar quarter, o* prepare and submit to the Commission a Special Report within 30 days, with a description of the reasons for exceeding these reporting levels.

ILL LI..

U -D d-

-6 mU C) o SX0) 0 C) -5

4) W 0~

ODCM 53 Rev. 13

Table 4.3 Reporting Levels for Radioactivity Concentrations in Environmental Samples ca P Water Airborne Particulate Fish Milk Analysis pCi/I pCi/m 3 pCi/kg (wet) pCi/I H-3 20,000 --

E 0

Mn-54 1,000 30,000 0

Co-60 300 10,000 (1C,,

0 Zn-65 300 - 20,000 --

Cs-134 30 10 1,000 60 Cs-137 50 20 2,000 70 0'

LI CL C)

CU (N

41) ca 03

>1 CO z 0

'0 (D

z 0~

0-ODCM 54 Rev. 13

Page 0. 1 HSP-04.0 La Crosse Boiling Water Reactor I LACBWR HEALTH & SAFETY DEPARTMENT PROCEDURE PROCESS CONTROL PROGRAM (PCP)

DAIRYLAND POWER A IT cmui~~ttii 1:iirg Coi,pcra.sc ______

,.i. .:.:...,REC ORD..0.:- D..-F!NITIAL ISSUE, REVISIONS & PERIQDIC .REVIEWS ...

PREPARED BY APPROVED &

OR H& E OPETIONS ENGINEERING CQA REVIEW ISSUED*

ISSUE REVIEWED BY REVIEW REVIEW E EDATE SIGNATURE DATE SIGNATURE DATE SIGNATURE DATE SIGNATURE DATE SIGNATURE DATE OF ISSUE 0

LACBWR PLANT MANAGER

- H&S SUPERVISOR OR RAD. PROT. ENGINEER

Page 0.2 HSP-04.0 LACBWR HEALTH AND SAFETY DEPARTMENT PROCEDURE PROCESS CONTROL PROGRAM (PCP)

OCTDa Issue Notice No. 1 Dated INSTRUCTIONS Description of and Reason for Change Modify procedure due to completion of DCS project; all fuel has been removed REMOVE AND INSERT ALL PAGES from the plant Changes to this procedure do not require 50.59 screening.

This issue shall not become effective unless accompanied by a new cover sheet, properly signed off in the appropriate review/approval columns.

HSP-04.0 Issue 1 LACBWR HEALTH AND SAFETY DEPARTMENT PROCEDURE PROCESS CONTROL PROGRAM (PCP) 1.0 PURPOSE The purpose of the Process Control Program (PCP) is to describe the methodology and procedures used by the La Crosse Boiling Water Reactor (LACBWR) Facility during SAFSTOR, to ensure that radioactive waste material processing, packaging, transportation and disposal will be accomplished in a manner that is in compliance with all applicable federal, state, and burial site regulations. The PCP will provide guidance for LACBWR's three basic waste streams: (1) dry active waste (DAW), (2) wet radioactive waste (resin or filter media), or (3) irradiated material.

NOTE: If the methodology and/or procedures found in the PCP are being violated, all radioactive waste processing activities will be suspended until these violations can be investigated and corrected.

2.0 REQUIREMENTS 2.1 Quality Assurance Program Description, Appendix C: The PCP shall be maintained onsite and will be available for NRC review. Licensee-initiated changes to the PCP shall be submitted to the NRC in the annual Radioactive Effluent Release Report for the period in which the change(s) was made. This submittal shall contain:

2.1.1 Information to support the rationale for the change; 2.1.2 A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and 2.1.3 Documentation of the fact that the change has been reviewed and found acceptable by the ORC."

2.2 Wet Radioactive Waste 2.2.1 These wastes will be transferred to the Waste Treatment Building (WTB) for storage before their ultimate disposal.

Page 1 of 8

HSP-04.0 Issue 1 2.2.2 The WTB is located to the northeast of the Reactor Building. The WTB contains facilities and equipment for the collection, storage and handling of low level solid radioactive waste materials.

The grade floor of the WTB contains a shielded compartment which encloses a permanent 320 ft3 stainless steel Spent Resin Receiving Tank (SRRT) with associated resin receiving and transfer piping, SRRT recirculation piping, SRRT demineralized water flush piping, SRRT dewatering piping, SRRT air sparger piping, valves, and a SRRT ultrasonic level indication assembly. This cubicle is in the southeast corner of the building and has nominal 2' 6" to 3' thick reinforced high density concrete shield walls on the outer sides.

2.2.3 Wet radioactive waste materials may typically be described as whole bead demineralizer resins, mechanical cartridge filters and waste sludge. When expended, resins and sludge are transferred to the SRRT. The cartridge filters may be added directly to a HIC as indicated below.

2.2.4 From the SRRT, partially dewatered spent resins and/or sludge material, are pumped at a low flow rate/pressure with a Roper-type screw pump to a High Integrity Liner (HIC), located in the adjacent shielded cubicle as described in Operating Manual Volume VII. The wall between the SRRT and the HIC and other walls surrounding the HIC are a nominal 2' thick high density concrete. Also located in this cubicle is an air-driven Sandpiper-type diaphragm HIC dewatering pump, the resin transfer and dewatering valves and hoses, and the disposal HIC level indication connecting cable. Once in the HIC, spent resins and sludge material is dewatered to the SRRT which is subsequently dewatered. A final dewatering is performed as described in Operating Manual Volume VII.

Samples of wet waste are analyzed for isotopic composition and for waste classification before disposal.

2.2.5 The final dewatering will ensure that the contents of the HIC meets the requirements of 10 CFR 61.56(a)(3) and the burial site criteria for free-standing liquids. Stabilization of the dewatered wet waste is provided by the HIC as authorized by 10 CFR 61.56(b)(1). The contractor which supplies the HIC will provide DPC with a copy of the Certificate of Compliance for the HIC which details specific limitations on the use of the HIC.

Page 2 of 8

HSP-04.0 Issue 1 2.2.6 Once final dewatering is completed, the HIC is inspected and the lid will be closed and sealed. The HIC is surveyed, decontaminated, if needed, and loaded into an appropriate shipping cask.

NOTE: Dewatered spent mechanical cartridge filters may be added directly to a HIC containing spent resins, if necessary.

2.2.7 The shipping cask is prepared for shipment in accordance to contractor's procedures. The vehicle is inspected both upon arrival onsite and after it is loaded prior to departure in accordance with procedure.

2.2.8 Once properly prepared for shipment, the wet waste will be either sent directly to an approved disposal site for burial, or it will be sent to a licensed waste processor for volume reduction. Any material remaining after reprocessing will be sent to burial by the processor for DPC.

2.3 Dry Active Wastes 2.3.1 The PCP and Health and Safety Procedures in Section 4 establish the steps used to process, package and ship the Dry Active Wastes (DAW) from the plant, in accordance with 10 CFR 20.2006 and 49 CFR 173.

The Dry Active Waste materials may typically be described as paper, cloth, metal, wood, plastic, concrete and other items or components which have become contaminated with radioactive materials. The DAW is normally characterized and labeled as Class A Unstable, in accordance with 10 CFR 61.55 and 61.56.

2.3.2 DAW will either be processed at LACBWR for burial at an approved burial site, or it will be processed for shipment to a licensed reprocessing contractor.

2.3.3 DAW for Direct Burial These wastes processed for direct burial from LACBWR are packaged in approved shipping containers as required by the burial site. Sufficient absorbent material is added to each waste container to limit free standing and non-corrosive liquid to less than 1% of the volume. Representative samples of DAW are analyzed for isotopic composition and for waste classification.

Page 3 of 8

HSP-04.0 Issue 1 2.3.4 DAW for Reprocessing Containers supplied by the contractor will be strategically placed within the controlled area to allow for the most efficient loading of these containers.

The container size will vary due to the application required. Once filled, the reprocessing contractor will be notified and shipping arrangements will be made. The containers will be sealed and surveyed before leaving LACBWR. Any waste volume remaining after reprocessing will be sent to burial by the contractor for LACBWR.

2.4 Irradiated Material 2.4.1 Irradiated material packaging and shipping may be handled by a licensed contractor hired by DPC to perform such shipments. DPC employees will provide oversight of these shipments to ensure compliance.

2.5 Waste Classification 2.5.1 Due to the closing of the Barnwell burial site in 2007, LACBWR engaged in a campaign to dispose of all Class B and C waste. Currently LACBWR has no known Class B or Class C waste. LACBWR waste will be classified as Class A stable or unstable. Waste classification is based on the requirements of 10 CFR 61.55.

2.5.2 Radionuclide concentrations will be determined based on the volume or weight of the final waste form as discussed in Section C.2 of the Branch Technical Position Paper on Waste Classification.

2.5.3 Of the four suggested methods for determining radionuclide concentration, the one most commonly used is the direct measurement of individual radionuclides (gamma emitters) and the use of scaling factors to determine the radionuclide concentration of difficult to measure radionuclides (normally non-gamma emitters). The use of the other suggested methods; material accountability, classification by source or gross radioactivity measurements may occur if the situation best fits the use of that methodology.

2.5.4 Plant procedures are used in the determination of radionuclide concentration for difficult to measure nuclides (normally non-gamma Page 4 of 8

HSP-04.0 Issue 1 I emitters) and for the classification of radioactive waste for near-surface burial in accordance to 10 CFR 61.56(a)(3) and Table 1 and Table 2.

2.6 Shipment Manifest 2.6.1 Each shipment of solid radioactive waste to a licensed land disposal facility will be accompanied by a shipment manifest as required by 10 CFR 20.2006 and described in NUREG/BR-0204. The manifest will contain the name, address, and telephone number of the waste generator. The manifest will also include the name, address, and telephone number or the name and EPA hazardous waste identification number of the person transporting the waste to the land disposal facility.

2.6.2 The manifest will also indicate to the extent practicable:a physical description of the waste; the volume; radionuclide identity and quantity; the total radioactivity; and the principal chemical form. The solidification agent, if applicable, will be identified.

2.6.3 Waste containing more than 0.1% chelating agents by weight will be identified and the weight percentage of the chelating agent estimated.

Waste classification will be clearly indicated on the manifest. The total quantity of the radio-nuclides H-3, C-14, Tc-99, and 1-129 will be shown on the manifest. Source material mass, and the masses of U-233, U-235, Pu isotopes and total Special Nuclear Material will be calculated and shown on the manifest.

2.6.4 Each manifest will include a certification by DPC that the transported materials are properly classified, described, packaged, marked, and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation and the NRC.

A qualified individual will sign and date the manifest. LACBWR procedures are used for the preparation of burial site radioactive shipping manifests.

2.6.5 LACBWR will maintain a manifest record-keeping and tracking system that meets the requirements of 10 CFR 20.2006.

Page 5 of 8

HSP-04.0 Issue 1 2.6.6 Each shipment of radioactive waste to a licensed reprocessing contractor will be accompanied by a shipment manifest that meets the requirements of that contractor's license.

2.7 Administrative Controls 2.7.1 Training A training program will be conducted to ensure that waste processing will be performed according to plant procedures and the PCP. An individual's training record will be maintained for audit and inspection. The processing and shipment of radioactive material will be performed by qualified and trained personnel.

All plant personnel who handle, package, and prepare for shipment radioactive material will receive appropriate DOT Hazardous Material Training, in accordance with their duties, once every three (3) years.

2.7.2 Record Retention Records of processing data, test and analysis results, results of training, inspections and audits will be retained in accordance with LACBWR Quality Assurance requirements for record retention.

2.7.3 Documentation Control DPC-initiated changes may be made to the PCP and procedures in accordance with the Quality Assurance Program Description and shall become effective upon review and acceptance by the Operations Review Committee (ORC).

Radioactive waste that does not fall within previous waste processing experience will be evaluated and, if necessary, included in the PCP prior to final processing and disposal. Approved changes in the PCP will be reported to the NRC in the subsequent annual Radioactive Effluent Release Report.

Page 6 of 8

HSP-04.0 Issue I 2.7.4 Quality Assurance The provisions of the NRC-approved LACBWR Quality Assurance Program apply to all activities performed under the PCP, and solid radioactive waste processing procedures.

2.7.5 Voluntary Information Submittal If any of the following mishaps occur during the preparation of LLW waste for disposal, a voluntary submittal of information will be sent to the NRC.

This will be a 30-day report to the NRC's Director of the Division of Low-Level Waste Management and Decommissioning and will also be sent to the designated State disposal-site regulatory authority.

1) Failure of the high-integrity containers used to ensure a stable waste form. Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling (e.g., dropping or impacting against another object).

2) Misuse of high-integrity containers, evidenced by a quantity of free liquid greater than 1 percent of container volume, or by an excessive void space within the container. Such misuse is prohibited by 10 CFR 61.56.

3) Production of a solidified Class B or C waste form that has any of the following characteristics:

" Contains free liquid in quantities exceeding 0.5 percent of the volume of the waste.

Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class.

" Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency.

Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.

Page 7 of 8

SECTION B ANNUAL RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT

INTRODUCTION:

The RadiologicalEnvironmentalMonitoring (REM) Program is conducted to comply with the requirements of the ODCM and in accordance with 10 CFR 50 Appendix I. The REM Programprovides measurements of radiationand of radioactivematerialsin those exposure pathways and for those radionuclides which could potentially lead to radiation doses to Members of the Public resulting from plant effluents. Environmentalsamples are taken within the surrounding areas of the plant and in selected control or background locations.

The monitoringprogram at the LACBWR facility includes monitoringof liquid and gaseous releases from the plant, as well as environmental samples of surface air,river water, river sediment, milk, fish, and penetrating radiation.

The REM program theory supplements the Radioactive Effluent analyses by verifying that the measurable concentrationsof radioactive materialsand levels of radiationare not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways using the methodology of the Offsite Dose CalculationManual (ODCM).

An InterlaboratoryComparison Programis provided to ensure that independent checks on the precision and accuracy of the measurements of radioactivematerialin environmental samples are performed.

1

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT 1.0 SAMPLE COLLECTION Environmental samples are collected from the area surrounding LACBWR at the frequencies outlined in the ODCM. A series of figures and tables are included in this report to better show LACBWR's environmental program.

FIGURE 1 This map includes the plant boundary, roads, other generation plants, and the relationship of the plant to the nearest local community.

FIGURE 2 This map shows the location of LACBWR's permanent environmental monitoring stations.

FIGURES 3&4 These maps show the location of LACBWR's TLDs.

TABLE 5 This table shows the sampling frequency of the various environmental samples and the analyses performed on these samples TABLE 6 This table shows the permanent monitoring stations used in LACBWR's environmental program.

TABLE 7 This table shows the TLD locations.

TABLE 8 This table shows the number of various samples collected and analyzed during 2012.

2.0 RESULTS OF THE 2012 RADIO-ENVIRONMENTAL MONITORING SURVEYS During 2012, activity levels in the local environment were normal, indicating no significant plant attributed radioactivity.

2.1 PENETRATING RADIATION The environmental penetrating radiation dose is measured by thermo luminescent dosimeters consisting of four lithium fluoride (LiF) chips. These TLD's are changed on a quarterly basis and are sent to an outside contractor for reading. The TLD results for 2012 are shown on Table 9.

2

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 2.2 AIR PARTICULATE Air samples are collected continuously from various sites (see Table 6) around LACBWR. An air sampler is also located 18 miles north of the plant in La Crosse, Wisconsin, to act as a control station.

Particulate air samples are collected at the rate of approximately 30-60 Ipm with a Gelman Air Sampler. The air filter consists of a glass fiber filter with an associated pore size of approximately 0.45 pm. The particulate filters are analyzed weekly for gross beta activity with an internal proportional counter, and the monthly particulate composites are gamma analyzed for individual isotopic concentration.

TABLE 10 This table shows the weekly gross beta gamma activity concentration from the air particulate filters.

TABLE 11 This table shows the composite air particulate isotopic analysis.

Comparison between the control station at La Crosse and the other stations near LACBWR indicate that there was no significant plant attributable airborne particulate activity.

2.3 RIVER WATER River water is collected monthly. River water samples above at, and below the plant site are collected and are gamma analyzed for isotopic concentration. The river water gamma isotopic analysis results are shown in Table 12. The results indicate that there were no significant plant attributable radionuclides in the river water.

3

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 2.4 SEDIMENT SAMPLES Sediment samples were collected twice per year above, at, and below the plant outfall. These samples were gamma analyzed and these results appear on Table 13. They indicated that small amounts of plant-attributed radionuclides have accumulated in river sediments near the outfall. The amount of radionuclide in this sediment declined significantly after plant shutdown. These amounts have remained relatively constant the last few years.

2.5 FISH Fish samples were collected quarterly above and below the plant discharge. The results of gamma spectral analysis of edible portions of fish samples appear in Table 14. There has been no significant accumulation of plant-attributed radionuclides in fish in the vicinity of LACBWR.

3.0 CONCLUSION

S All environmental samples collected and analyzed during 2012 exhibited no significant contribution from LACBWR.

4

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) 4.0 INTERLABORATORY COMPARISON PROGRAM RESULTS During 2012, interlaboratory comparison samples were obtained from an outside contractor. The equipment used to analyze the environmental samples was tested against the contractors' results. The following is the result of this comparison.

ANALYSIS LACBWR CONTRACTOR RATIO RESULTS :.RESULTS GROSS BETA 195 pCi 162 pCi 1.20 GROSS ALPHA 170 pCi 182 pCi 0.93 1-131 76 pCi/I 72.5 pCi/I 1.05 Cr-51 363 pCi/I 362 pCi/I 1.00 Cs-134 165 pCi/I 173 pCi/I 0.96 Cs-137 137 pCi/I 122 pCi/I 1.12 Co-58 115 pCi/I 103 pCi/I 1.12 Mn-54 136 pCi/I 121 pCi/I 1.13 Fe-59 139 pCi/I 121 pCi/I 1.15 Zn-65 230 pCi/I 194 pCi/I 1.19 Co-60 204 pCi/I 177 pCi/I 1.15 H-3 13200 pCi/I 12100 pCi/I 1.09 5

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

FIGURE 1 - LACBWR PROPERTY MAP 6

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

ASa~mple flwixormmntal Locations FIGURE 2 - PERMANENT ENVIRONMENTAL MONITORING STATION LOCATIONS (Refer to Table 6) 7

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

Location 1 La Crosse Main Office Dam #8 3 Radio Tower

4. Trailer Court FIGURE 3 - LACBWR ENVIRONMENTAL DOSE ASSESSMENT LOCATIONS 8

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd) see F07 FIGURE 4 - LACBWR ENVIRONMENTAL DOSE ASSESSMENT LOCATIONS 9

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 5 SAMPLE FREQUENCY AND ANALYSIS OF RADIO-ENVIRONMENTAL SAMPLES SAMPLE FREQUENCY ANALYSIS PERFORMED.

TLD (LiF) Dosimeters Quarterly Dose in mRem Particulate Air Glass Weekly Gross Beta and Gamma Fiber Filters Spectroscopy of Composites Monthly (HPGe-MCA)

Milk Obtain sample as directed if Gamma Spectroscopy abnormal stack particulate release occurs.

Sediment Twice per year Gamma Spectroscopy Fish Quarterly Gamma Spectroscopy River Monthly Gamma isotopic analysis and tritium (Liquid Scintillation Analyzer)

Vegetation Obtain sample as directed if Gamma Spectroscopy abnormal stack particulate release occurs.

10

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 6 PERMANENT ENVIRONMENTAL MONITORING STATION LOCATIONS (Refer to Figure 2)

LOCATION AIR NO. LOC ATION -SAMPLE 1 Radio Tower x 2 Dam No. 8 x 3 Trailer Court x 4 Crib House x 5 Main Office x 11

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 7 ENVIRONMENTAL TLD LOCATIONS LOCATION NO. LOCATION 1 LA CROSSE MAIN OFFICE AIR SAMPLER BOX 2 DAM #8 AIR SAMPLER BOX 3 RADIO TOWER BUILDING AT AIR SAMPLER 4 TRAILER COURT AIR SAMPLER BOX 5 CRIBHOUSE AIR SAMPLER BOX 6 G-3 CONTROL ROOM 7 SW GATEPOST AT END OF G-3 DIKE 8 ON FENCE N. SIDE OF FISHERMAN'S ROAD 9 SITE ENTRANCE GUARD AREA 10 ON FENCE AT NE CORNER OF THE SWITCHYARD 11 ON N. SITE AREA FENCE GATE 12 G-1 CRIBHOUSE 13 ON MOORING WALKWAY WEST OF LACBWR #2 WAREHOUSE 14 G-3 COAL UNLOADING CRANE 15 POWER POLE ON BLUFF SIDE EAST OF PLANT 16 RESTRICTED AREA FENCE N. SIDE 17 RESTRICTED AREA FENCE E. SIDE 18 RESTRICTED AREA FENCE S. SIDE 19 RESTRICTED AREA FENCE SW CORNER 20 RESTRICTED AREA FENCE W. SIDE 21 RESTRICTED AREA FENCE NW CORNER 12

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 8 RADIO-ENVIRONMENTAL SAMPLES COLLECTED JANUARY-DECEMBER 2012 NUMBER OF

-TYPE OF SAMPLE:

i===..-=

.. .. .....:.:*=*:.=.

".,'...:S

.. S A MPL:.E.

LES .

Penetrating Radiation (TLD's) 84 Air Particulate 260 River Water 36 Sediment 6 Fish 8 13

RADIOLOGICAL ENVIRONMENTAL MONITORING REPORT - (cont'd)

TABLE 9 QUARTERLY THERMOLUMINESCENT DOSIMETER DOSE MEASUREMENTS IN THE LACBWR VICINITY JANUARY - DECEMBER 2012 BACKGROUND CORRECTED 1t QUARTER.

1STATION 2nd QUARTER 3rd':QUARTER 4th QUARTER NO. mRem mRem mRem. mRem; 1 0 0 0 0 2 1.3 0 0 0 3 0 0 0 0 4 1.2 1.5 1.0 0 5 0 0 8.9 44.5 6 0 0 0 0 7 0 0 0 0 8 0 0 0 0 9 0.8 0 1.1 0 10 0 0 0 0 11 0 0 0 0 12 2.5 0.6 1.0 0 13 0 0 0 0 14 0 0 0 0 15 4.7 4.2 4.6 1.6 16 5.2 0.7 3.2 9.4 17 4.4 0 4.9 19.5 18 20.4 11.8 19.6 23.6 19 5.3 2.5 8.4 19.2 20 2.3 1.0 12.1 25.9 21 2.0 3.3 209.7 302.4 Station #1 (La Crosse Main Office) located approximately 16 miles north of LACBWR is considered the Control TLD.

14

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LAC.BWR PLANT -TRAILER COURT. DAM #8 :.:.:::::RADIO TOWER. LA CROSSE DATE.::rn _________ CONTROL

__ __ __ __ __pm/r pCi/r, pCi/m _ _ _ _ _ _

01-04-12 .020+.002 .023+.002 .013+.002 .022+.002 .019+.002 01-11-12 .025+.002 .023+.003 .012+.002 .023+.002 .019+.002 01-18-12 .021+.002 .024+.003 .012+.002 .024+.002 .023+.002 01-25-12 .027+ .002 .025+.002 .015+.002 .026+.003 .019 + .002 02-01-12 .023+.002 .023+.002 .010+.002 .025+.002 .024+.002 02-08-12 .017+.002 .019+.002 .010+.002 .017+.002 .021 + .002 02-15-12 .017+ .002 .019+.002 .013+.002 .016+.002 .018+ .002 02-22-12 .024+.002 .024+.003 .015+.002 .023+.002 .023+.002 02-29-12 .021+.002 .022+.002 .021+.003 .020+.002 .021 +.002 03-07-12 .018+.002 .020+.002 .020+.003 .019+.002 .018 + .002 03-14-12 .021+.002 .021+.002 .023+.003 .020+.002 .023 + .002 03-21-12 .020+.002 .023+.002 .021+.003 .021+.002 .018+.002 03-28-12 .013+.002 .016+.002 .019+.003 .015+.002 .014 + .002 04-04-12 .012+.002 .010+.002 .014+.003 .011+.002 .012 + .001 15

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR PLANT ý TRAILER:COURT DAM.#8 RADIO TOWER LA CROSSE DATE pci/Mr3 pCi/r :: pCi/mn : pCi/m : CONTROL.

04-11-12 .015+.002 .018+.002 .020+.003 .014+.002 .015+.002 04-18-12 .020+.002 .022+.003 .017+.002 .019+.002 .018+.002 04-25-10 .018+ .002 .019+.002 .020+.003 .018+.002 .018+.002 05-02-12 .020+.002 .021+.002 .019+.002 .020+.002 .019+.002 05-09-12 .011+.002 .014+.002 .012+.002 .012+.002 .010+.001 05-17-12 .019+.002 .020+.002 .020+.002 .021+.002 .020+.002 05-23-12 .019+.002 .025+.003 .028+.003 .020+.002 .019+.002 05-30-12 .018+.002 .020+.002 .019+.003 .020+.002 .017+.002 06-06-12 .017+.002 .016+.002 .018+.003 .017+.002 .015+.002 06-13-12 .017+.002 .018+.002 .018+.002 .017+.002 .017+.002 06-20-12 .024+.002 .022+.002 .020+.003 .023+.002 .020+.002 06-27-12 .016+.002 .017+.002 .019+.002 .018+.002 .016+.002 07-03-12 .029+.003 .030+.003 .033+.004 .030+.002 .027+.003 07-11-12 .023+.002 .022+.002 .020+.002 .022+.002 .018+.002 16

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR PLANT TRAILER COURT DAM #8 RADIO TOWER: LA:CROSSE

DATE pir 3 pir 3 pir 3 Cm CONTROL 07-18-12 .030+.003 .031+.003 .026+.003 .032+.002 .029+.002 07-25-12 .023+.002 .024+.002 .026+.003 .024+.002 .023+.002 08-01-12 .022+.002 .024+.002 .022+.003 .019+.002 .022+.002 08-07-12 .020+.002 .021+.002 .021+.003 .022+.002 .025+.002 08-15-12 .014+.002 .019+.002 .018+.002 .018+.002 .018+.002 08-22-12 .020+.002 .018+.002 .021+.003 .021+.002 .018+.002 08-29-12 .035+.003 .039+.003 .037+,003 .037+.002 .034+.003 09-05-12 .029+.003 .027+.003 .030+.003 .028+.002 .039+.003 09-12-12 .020+.002 .021+.002 .024+.003 .020+.002 .020+.002 09-19-12 .019+.002 .024+.003 .022+.003 .021+.002 .020+.002 09-26-12 .015+.002 .019+.002 .022+.003 .017+.002 .018+.002 10-03-12 .029+.003 .033+.003 .032+.004 .031+.002 .029+.003 10-10-12 .018+.002 ..018+.002 .021+.003 .018+.002 .020+.002 10-17-12 .025+.003 .028+.003 .029+.003 .024+.002 .023+.002 17

TABLE 10 WEEKLY GROSS BETA AIR PARTICULATES IN THE LACBWR VICINITY (Reporting Level = 10 times Control Value)

COLLECTION LACBWR .PLANT.:.

3 TRAILER COURT DAM #8 3 RADIO TOWER 3 LACSE DATE .. pCi Ci/.:. i/m pCii CONTROL pcirM .__..._.._...

10-24-12 .021+.003 .022+.003 .021+.003 .022+.002 .021+.002 10-31-12 .016+.002 .015+.002 .017+.003 .016+.002 .019+.002 11-7-12 .019+.002 .019+.002 .023+.003 .021+.002 .023+.002 11-14-12 .025+.003 .029+.003 .028+.002 .025+.002 .025+.002 11-21-12 .048+.004 .050+.004 .045+.004 .047+.003 .042+.003 11-28-12 .029+.003 .027+.003 .027+.003 .027+.002 .028+.003 12-05-12 .049+.004 .051+.004 .048+.004 .049+.003 .051+.003 12-12-12 .022+.002 .021+.003 .023+.003 .020+.002 .023+.002 12-19-12 .035+.003 .037+.003 .032+.003 .040+.003 .037+.003 12-26-12 .026+.003 .030+.003 .018+.003 .027+.002 .031+.003 1-2-13 .036+.003 .034+.003 .017+.002 .037+.003 .038+.003 18

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS 3

(Concentrations in pCi/m )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 01-04-12 01-04-12 01-04-12 01-04-12 01-04-12 END DATE 02-01-12 02-01-12 02-01-12 02-01-12 02-01-12 ISOTOPES/RL*

Cs-134/10 <2.52E-3 <2.80E-3 <3.OOE-3 <3.90E-3 <1.93E-3 Cs-1 37/20 <2.62E-3 <4.39E-3 <2.78E-3 4.02E-3+1.06E-3 <1.41 E-3

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 02-01-12 02-01-12 02-01-12 02-01-12 02-01-12 END DATE 02-29-12 02-29-12 02-29-12 02-29-12 02-29-12 ISOTOPES/RL*

Cs-134/10 <2.50E-3 <2.72E-3 <3.07E-3 <3.86E-3 <1.91E-3 Cs-1 37/20 2.29E-3+6.73E-4 <2.78E-3 2.78E-3+8.29E-4 4.09E-3+1.06E-3 <1.98E-3

RL = REPORTING LEVEL 19

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS 3

(Concentrations in pCi/m )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 02-29-12 02-29-12 02-29-12 02-29-12 02-29-12 END DATE 03-28-12 03-28-12 03-28-12 03-28-12 03-28-12 ISOTOPES/RL*

Cs-134/10 <2.24E-3 <2.26E-3 <2.93E-3 <4.28E-3 <1.98E-3 Cs-137/20 <2.37E-3 <2.83E-3 <3.17E-3 <4.35E-3 1.98E-3+5.33E-4

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 03-28-12 03-28-12 03-28-12 03-28-12 03-28-12 END DATE 05-02-12 05-02-12 05-02-12 05-02-12 05-02-12 ISOTOPES/RL*

Cs-134/10 <1.88E-3 <2.39E-3 <2.43E-3 <3.06E-3 <1.61 E-3 Cs-137/20 2.22E-3+5.17E-4 <2.53E-3 <2.67E-3 <3.14E-3 <1.36E-3

RL = REPORTING LEVEL 20

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/m 3)

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 05-02-12 05-02-12 05-02-12 05-02-12 05-02-12 END DATE 05-30-12 05-30-12 05-30-12 05-30-12 05-30-12 ISOTOPES/RL*

Cs-134/10 <2.28E-3 <2.89E-3 <3.01E-3 <3.68E-3 <2.18E-3 Cs-137/20 <2.35E-3 <2.97E-3 <3.03E-3 <3.66E-3 <2.18E-3

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 05-30-12 05-30-12 05-30-12 05-30-12 05-30-12 END DATE 06-27-12 06-27-12 06-27-12 06-27-12 06-27-12 ISOTOPES/RL*

Cs-134/10 <2.21E-3 <2.83E-3 <2.89E-3 <3.71E-3 <2.47E-3 Cs-137/20 <2.24E-3 <2.96E-3 <2.91 E-3 <3.79E-3 <2.58E-3

RL = REPORTING LEVEL 21

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS (Concentrations in pCi/m 3)

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 07-03-12 07-03-12 07-03-12 07-03-12 07-03-12 END DATE 08-01-12 08-01-12 08-01-12 08-01-12 08-01-12 ISOTOPES/RL*

Cs-134/10 <1.64E-3 <2.25E-3 <2.32E-3 <3.04E-3 <1.98E-3 Cs-1 37/20 1.80E-3+4.75E-4 <2.11 E-3 <2.11 E-3 <3.08E-3 1.56E-3+5.33E-4

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 08-01-12 08-01-12 08-01-12 08-01-12 08-01-12 END DATE 08-29-12 08-29-12 08-29-12 08-29-12 08-29-12 ISOTOPES/RL*

Cs-134/10 <1.98E-3 <3.12E-3 <2.87E-3 <3.72E-3 <2.50E-3 Cs-137/20 <1.55E-3 <3.26E-3 3.12E-3+8.05E-4 <4.OE-3 <2.01E-3

RL = REPORTING LEVEL 22

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS 3

(Concentrations in pCi/m )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 08-29-12 08-29-12 08-29-12 08-29-12 08-29-12 END DATE 09-26-12 09-26-12 09-26-12 09-26-12 09-26-12 ISOTOPES/RL*

Cs-134/10 <1.93E-3 <3.11 E-3 <3.20E-3 <4.04E-3 <2.80E-3 Cs-1 37/20 <2.01 E-3 <3.33E-3 3.22E-3+8.47E-4 5.24E-4+1.2E-3 <2.87E-3

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 09-26-12 09-26-12 09-26-12 09-26-12 09-26-12 END DATE 10-31-12 10-31-12 10-31-12 10-31-12 10-31-12 ISOTOPES/RL*

Cs-134/10 <1.72E-3 <2.60E-3 <2.55E-3 <3.35E-3 <2.26E-3 Cs-137/20 <1.78E-3 <2.66E-3 <2.59E-3 <3.32E-3 <2.19E-3

RL = REPORTING LEVEL 23

TABLE 11 AIR PARTICULATE COMPOSITE RESULTS 3

(Concentrations in pCi/m )

LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 10-31-12 10-31-12 10-31-12 10-31-12 10-31-12 END DATE 11-28-12 11-28-12 11-28-12 11-28-12 11-28-12 ISOTOPES/RL*

Cs-134/10 <2.OOE-3 <3.08E-3 <3.12E-3 <3.95E-3 <3.79E-3 Cs-137/20 1.76E-3+5.46E-4 <3.06E-3 4.56E-3+9.27E-4 <4.OOE-3 <3.72E-3

RL = REPORTING LEVEL LOCATION RADIO TOWER LACBWR TRAILER COURT DAM NO. 8 LA CROSSE START DATE 11-28-12 11-28-12 11-28-12 11-28-12 11-28-12 END DATE 01-02-13 01-02-13 01-02-13 01-02-13 01-02-13 ISOTOPES/RL*

Cs-134110 <1.79E-3 <2.52E-3 <2.55E-3 <3.OOE-3 <1.96E-3 Cs-137120 <1.91E-3 <2.54E-3 <2.81 E-3 <2.64E-3 <2.02E-3

RL = REPORTING LEVEL 24

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 01-10-12 01-10-12 01-10-12 02-13-12 02-13-12 02-13-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 <101 <101 <101 128+95 107+95 321+95 Mn-54/1000 <4.12 <4.09 <4.08 <3.96 <4.05 <3.92 Co-60/300 <4.38 <4.24 <4.23 <4.25 <4.07 <4.11 Zn-65/300 <9.54 <9.25 <9.55 ,9.51 <9.57 <9.27 Cs- 134/30 <4.46 <4.66 <4.48 <4.59 <4.59 <4.64 Cs-137/50 <4.57 <4.74 <4.81 <4.79 <4.87 <4.69

RL = REPORTING LEVEL 25

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 3-13-12 3-13-12 3-13-12 4-10-12 4-10-12 4-10-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 237+97 2.80+97 301+97 172+96 172+96 214+96 Mn-54/1000 <3.91 <4.06 <4.07 <4.11 <4.01 <3.94 Co-60/300 <4.14 <4.32 <4.29 <4.35 <4.3 <4.16 Zn-65/300 <9.23 <9.32 <9.50 <9.20 <9.34 <9.43 Cs-i 34/30 <4.43 <4.65 <4.65 <4.72 <4.79 <4.64 Cs-1 37/50 <4.50 <4.65 <4.70 <4.67 <4.65 <4.77

RL = REPORTING LEVEL 26

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 5-11-12 5-11-12 5-11-12 6-10-12 6-04-12 6-10-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 129+95 151+96 237+97 283+97 305+97 261+96 Mn-54/1 000 <4.08 <4.02 <3.93 <3.95 <4.03 <3.86 Co-60/300 <4.18 <4.30 <4.52 <4.20 <4.03 <4.26 Zn-65/300 <9.12 <9.18 <9.77 <8.66 <9.04 <8.86 Cs-1 34/30 <4.65 <4.69 <4.78 <4.54 <4.61 <4.62 Cs-1 37/50 <4.75 <4.83 <4.82 <4.56 <4.63 <4.67

RL = REPORTING LEVEL 27

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 7-10-12 7-10-12 7-10-12 8-12-12 8-12-12 8-12-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 372+98 394+99 416+99 <111 <111 <111 Mn-54/1000 <4.06 <4.11 <4.11 <3.98 <3.94 <4.01 Co-60/300 <4.34 <4.19 <4.35 <4.32 <4.18 <4.13 Zn-65/300 <9.19 <9.79 <9.11 <9.38 <9.03 <8.91 Cs-1 34/30 <4.41 <4.38 <4.78 <4.54 <4.53 <4.33 Cs-i 37/50 <4.74 <4.60 <4.72 <4.72 <4.66 <4.67

RL = REPORTING LEVEL 28

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 9-9-12 9-9-12 9-9-12 10-10-12 10-10-12 10-10-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 <109 <109 <109 220+101 330+102 308+102 Mn-54/1000 <4.08 <4.02 <3.83 <4.16 <3.97 <4.12 Co-60/300 <4.22 <4.63 <4.01 <4.57 <4.21 <4.49 Zn-65/300 <9.49 <9.42 <9.51 <10.1 <9.11 <9.08 Cs-134/30 <4.63 <4.66 <4.58 <4.78 <4.56 <4.77 Cs-1 37/50 <4.75 <4.50 <4.77 <4.76 <4.75 <4.67

RL = REPORTING LEVEL 29

TABLE 12 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER WATER IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Liter)

SAMPLE #1 SAMPLE #2 SAMPLE #3 SAMPLE #1 SAMPLE #2 SAMPLE #3 COLLECTION DATE: 11-14-12 11-14-12 11-14-12 12-10-12 12-10-12 12-10-12 SAMPLE LOCATION: DAM 8 OUTFALL VICTORY DAM 8 OUTFALL VICTORY ISOTOPES/RL

H-3 421+101 376+100 221+99 333+99 267+98 311+99 Mn-54/1000 <4.04 <3.89 <3.89 <3.63 <3.66 <3.52 Co-60/300 <4.40 <4.37 <4.39 <4.06 <4.04 <3.92 Zn-65/300 <9.46 <9.31 <9.76 <8.31 <8.57 <8.44 Cs-1 34/30 <4.63 <4.57 <4.60 <4.17 <4.28 <4.05 Cs-1 37/50 <4.66 <4.16 <4.61 <4.41 <4.36 <4.15

RL = REPORTING LEVEL 30

TABLE 13 RESULTS OF ANALYSIS OF MISSISSIPPI RIVER SEDIMENT IN THE VICINITY OF LACBWR (Concentration in pCi/Kg)

(Reporting Level = 10 times Control Value)

SAMPLE LOCATION UPSTREAM OUTFALL DOWNSTREAM UPSTREAM OUTFALL DOWNSTREAM COLLECTION DATE 6-9-12 6-15-12 6-9-12 9-4-12 9-4-12 9-4-12 ISOTOPES Cs-134 <5.49 <4.19 <9.24 <5.09 <4.91 <6.83 Cs-137 <5.03 <3.73 225+9.56 <4.80 93.4+4.31 29.1+2.33 Co-60 4.78+.966 31

TABLE 14 FISH SAMPLE ACTIVITY IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Kg)

SAMPLE TYPE: CARP WALLEYE CARP NORTHERN PIKE/SHEEP CARP/SHEEP PIKE PIKE HEAD HEAD COLLECTION DATE: 3-20-12 3-20-12 6-7-12 6-7-12 9-26-12 9-26-12 ISOTOPES/RL*

Mn-54 / 3E4 <5.37 <6.77 <7.25 <4.18 <8.48 <6.37 Co-60/ 1E4 <6.25 <7.76 <8.35 <5.01 <9.70 <7.40 Zn-65/2E4 <14.7 <18.7 <18.5 <11.7 <22.7 <17.1 Cs-134/ 1E3 <5.87 <7.60 <8.04 <4.94 <9.52 <7.43 Cs-137/2E3 <6.17 <7.79 <8.31 <4.96 <9.42 <7.34

RL =REPORTING LEVEL 32

TABLE 14 FISH SAMPLE ACTIVITY IN THE VICINITY OF LACBWR (Report Concentrations in pCi/Kg)

SAMPLE TYPE: CARP PIKE COLLECTION DATE: 10-30-12 10-30-12 ISOTOPES/RL*

Mn-54/ 3E4 <5.05 <8.26 Co-60/1 E4 <5.91 <9.50 Zn-65/2E4 <14.2 <21.9 Cs-1 34/ 1E3 <6.00 <9.28 Cs-137/2E3 7.44+1.67 <9.40

RL =REPORTING LEVEL 33

ML13079A185

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3.0 CONCLUSION

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ML13079A185

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1.0 INTRODUCTION

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3.0 CONCLUSION

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