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VPAP-2103N, Revision 25, Offsite Dose Calculation Manual (North Anna)
	ML16125A498
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Site:	North Anna
Issue date:	04/26/2016
From:	; Dominion, Virginia Electric & Power Co (VEPCO)
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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Title:

Offsite Dose Calculation Manual (North Anna) Process I Program Owner: Manager Radiological Protection and Chemistry (North Anna) Procedure Number VPAP-2103N Revision Summary Revision Number 25 Issued an Administrative Correction as follows (SAR002776/SAA031850): Effective Date On File

Revised Attachment 10, Pages 1 and 3 to make the location name consistent with the location name in HP-3051.010 for TLD. All these locations are at 0.20 miles.

Revision initiated to incorporate assignni.ent from ACE019800/CA291380:

Step 4.15. - Changed "radiation" to "a radioactive source".

Other Changes:

Attachment 2, Section 2.a: Changed Unit 1 1-SS-RM-125/Unit 2 2-SS-RM-225 Source Check column to reflect D (NOTE 7). Wrong note designation.

Approvals on File \\

DOMINION TABLE OF CONTENTS Section 1.0 PURPOSE 2.0 SCOPE

3.0 REFERENCES

/COMMITMENT DOCUMENTS 4.0 DEFINITIONS 5.0 RESPONSIBILITIES 6.0 INSTRUCTIONS 6.1 Sampling and Monitoring Criteria . 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations 6.2.2 Liquid Monitoring Instrumentation 6.2.3 Liquid Effluent Dose Limit 6.2.4 Liquid Radwaste Treatment 6.2.5 Liquid Sampling 6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation 6.3.2 Gaseous Monitoring Instrumentation VPAP-2103N REVISION25 PAGE 20F87 Page 5 5 6 8 11 12 12 12 12 13 16 18 19 19 19 22 6.3.3 Noble Gas Effluent Air Dose Limit 25. 6.3.4 I-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 27 6.3.5 Gaseous Radwaste Treatment 29 6.4 Radioactive Liquid and Gaseous Release Permits 31 6.4.1 Liquid Waste Batch Release Permits 31 6.4.2 Continuous Release Permit 31 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 32 6.4.4 Reactor Containment Release Penrtits 32 ..J 6.4.5 Miscellaneous Gaseous Release Permit 32

DOMINION TABLE OF CONTENTS (continued) Section. 6.4.6 Radioactive Liquid and Gaseous Release Controls 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program 6.6.2 Land Use Census 6.6.3 Interlaboratory Comparison Program

6. 7 Reporting Requirements 6.7.1 Annual Radiological Environmental Operating Report 6.7.2 Annual Radioactive Effiuent Release Report 6.7.3 Annual Meteorological Data 6.7.4 Changes to the ODCM 6.7.5 Groundwater Protection Initiative [Reference 3.1.35]

7.0 RECORDS VPAP-2103N REVISION25 PAGE 3 OF 87 Page 32 34 34 34 36 37 38 38 39 42 42 43 44

r-J DOMINION TABLE OF CONTENTS (continued)

Section ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements. 3 Radioactive Liquid.Waste Sampling and Analysis Program 4 Radioactive Gaseous Waste Sampling and Analysis Program 5 Gaseous Effluent Dose Factors 6 Radioactive Gaseous Effluent Monitoring Instrumentation 7 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 8 Critical Organ Dose Factors 9 Radiological Environmental Monitoring Program 10 Environmental Sampling Locations 11 Detection Capabilities for Environmental Sample Analysis 12 Reporting Levels for Radioactivity Concentrations in Environmental Samples

13 Meteorological, Liquid, and Gaseous Pathway Analysis VPAP-2103N REVISION25 PAGE 40F 87 Page 45 47 49 52 56 59 62 65 67 72 77 79 80

DOMINION 1.0 PURPOSE VPAP-2103N REVISION25 PAGE 5 OF 87 The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and RadiologiCal Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of off site doses due to radioactive liquid and gaseous effluents are performed to assure that:

Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CPR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/ml for dissolved or entrained noble gases.
Exposure to the maximum exposed meinber of the 'public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CPR 50, Appendix I
Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:
- Noble gases - less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
- 1131, 1133, and H3, and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ
Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CPR 50, Appendix I, and
Exposure to a real individual will not exceed 40 CPR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at North Anna Power Station.

DOMINION

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CPR 20, Standards for Protection Against Radiation VPAP-2103N REVISION25 PAGE 60F87 3.1.2 10 CPR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 197 4

3. I. 6 Regulatory Guide I. I 09, Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance With IO CPR 50, Appendix I, Rev. 1, U.S. NRC, October I977

3. I. 7 Regulatory Guide l. I 11, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 North Anna Technical Specifications 3.1.9 North Anna Technical Requirements Manual (TRM) 3.1.10 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.11 NUREG/CR-1276, Users Manual forthe LADTAP II Program, U.S. NRC, May, 1980 3.1.12 TID-4500, VCRL-50564, Rev. I, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, I 972 3.1.13 WASH 1258, Vol. 2, July I973, Numerical Guides for Design Objectives andLimiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.l.I4 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, I980 3.l.I5 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, I979, Rev. I 3.l.I6 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, I978 3.1.I 7 NUREG-0543, February 1980, Methods for Demonstrating L WR Compliance With the EPA Uranium Fuel Cycle Standard ( 40 CFR Part 190) 3.l.I8 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Wate:r_Reactors, Proposed Rev. 3, March I982

DOMINION 3.1.19 Environmental Measurements Laboratory, DOE HASL 300 Manual VPAP-2103N REVISION25 PAGE 70F87 3.1.20 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.21 North Anna UFSAR 3.1.22 Nuclear Reactor Environmental Radiation Monitoring Quality Control Manual, IWL-0032-361 3.1.23 North Anna Circulating Water System Modifications

a. DC-85-37-1 Unit 1

b. DC-85-38-2 Unit 2 3.1.24 Plant Issue (Deviation) N-1994-1137, Improper Placement of Emergency TLDs 3.1.25 ET N-05-0025, Justification for removing 1-SW-RM-108 from service when not in use 3.1.26 VPAP-2802, Notifications* and Reports 3.1.27 O-PT-75.21, 1-SW-RM-108 Flow Verification 3.1.28 SAA001092, Non-SA SOEREffectiveness Review 93-1, Recommendation 3 3.1.29 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.30 CA086406, Land Use Census Results 3.1.31 Quality Assurance Audit Report Number 91-03, Observation 08N 3.1.32 Quality Assurance Audit Report Number 92-03, Observation 02N 3.1.33 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.1.34 Plant Issue (Deviation) N-1997-0926, Annual Radiological Effluent Release Report 3.1.35 Plant Issue (Licensing Commitment) N-2006-4026-R15, Groundwater Monitoring Action Plan 3.1.36 SOER 93-1, Diagnosis and Mitigation of RCS Leakage including SGTR 3.2 Commitment Documents None

DOMINION 4.0 DEFINITIONS 4.1 Channel Calibration VPAP-2103N REVISION25 PAGE 8 OF 87 A channel calibration shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The channel calibration shall encompass all devices in the channel required for channel operability. The channel calibration may be performed by means of any series of sequential, overlapping, or total channel steps. 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and status with other indications or status derived from independent instrumentation channels measuring the same parameter. 4.3 Channel Operational Test A Channel Operational Test (COT) shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to check OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the requifed alarm, interlock, and trip setpoints required for channel OPERABILITY such that setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps. 4.4

Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. Dose calculations to the critical organ will be evaluated in accordance with Technical Specifications 5.5.4 dose rate limits specified for any organ to check that these limits have not been exceeded.

4.5 Dose Equivalent I-131 That concentration ofl131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture ofl131, I132, I133, I134, and I135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

r I DOMINION VPAP-2103N REVISION25 PAGE 90F87 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of25 percent. NOTATION FREQUENCY D - Daily W-Weekly M-Monthly Q - Quarterly SA - Semi-annually R - Refueling SIU - Start-up P - Prior to release N.A. - Not applicable DR - During the release 4.7 Gaseous Radwaste Treatment System At least once per 24 hours At least once per 7 days At least once per 31 days At least once per 92 days At least once per 184 days At least once per 18 months Prior to each reactor start-up Completed prior to each release Not applicable At least once during each release A system that reduces radioactive gaseous effluents by collecting primary coolant system off gases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers, waste gas surge tanks, and waste gas diaphragm compressor. 4.8 General Nomenclature x = Chi:.concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies) Emission rate (continuous; grams per second, curies per second) Emission rate (continuous line source; grams per second per meter) 4.9 Lower Limit of Detection (LLD) The smallest concentration of radioactive material in a sample that will yield a net count (above system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

r

r DOMINION VPAP-2103N REVISION25 PAGE 10 OF 87 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with the Station. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials.

4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., North Anna - 2940 MWt). 4.14 Site Boundary

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

4.15 Source Check A qualitative assessment of channel response when a channel sensor is exposed to a radioactive source. This applies to installed radiation monitoring systems. For MGPI monitors, a source check is the verification of proper computer response to continuous operational checks on the detector and the electronjcs. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION

I 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

4.18 Unrestricted Area VPAP-2103N REVISION25 PAGE 11OF87 Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional and/or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEP A) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components. 5.0 RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry The Manager Radiological Protection and Chemistry is responsible for: 5.1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment. 5.1.2 Surveying, sampling, and analyzing plant effluents anc!_ environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5.1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

i ) DOMINION VPAP-2103N REVISION25 PAGE 12 OF 87 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 13). 6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

1. For radionuclides (other than dissolved or entrained noble gases), liquid effluent concentrations released to unrestricted areas shall not exceed ten times the effluent concentration values specified in 10 CFR 20, Appendix B, Table 2, Column2.

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

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

{ DOMINION VPAP-2103N REVISION25 PAGE 13 OF 87

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

Volume of Waste Discharged+ Volume of Dilution Water> 1 (l) µCi/mli Volume of Waste Discharged x ~ Li ACW. I I where: µCi/mli =the concentration of nuclide i in the liquid effluent discharge ACWi =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/ml from 10 CFR 20, Appendix :i3, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/ml for dissolved or entraiµed noble gases 6.2.2 Liquid Monitoring Instrumentation

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

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

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

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

). DOMINION VPAP-2103N REVISION25 PAGE 140F 87

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

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

1) perform the action shown in those tables.

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

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

Release Point Instrument Number Liquid Radwaste Effluent Line 1-LW-RM-111 Service Water System Effluent Line 1-SW-RM-108 Condenser Circulating Water Line 1-SW-RM-130 2-SW-RM-230 Steam Generator High Capacity Blow 1-SS-RM-125 down Line 2-SS-RM-225

f DOMINION

d. Setpoint Calculation VPAP-2103N REVISION25 PAGE 15 OF 87 NOTE: This methodology does not preclude use of more conservative setpoints.

1. Maximum setpoint values shall be calculated by:

s where: S the setpoint, in µCi/ml, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution . C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station, in µCi/ml FE = maximum design pathway effluent flow rate Fn = dilution water flow rate calculated as: D =FE+ (218,000 gpm x number of circ. pumps in service) (2)

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

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

3. In addition, for added conservatism, setpoints shall be calculated for the liquid radwaste effluent line LW-111 and the Service Water System effluent line SW-108.

DOMINION

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

where: VPAP-2103N REVISION25 PAGE 160F 87 (4) KLw = The fraction of the effluent concentration limit, used to implement 10 CFR 20 for the site, attributable to the liquid radwaste effluent line pathway

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

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

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

6.2.3 Liquid Effluent Dose Limit

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

1. During any calendar quarter:

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

2. During any calendar year:

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

t DOMINION VPAP-2103N REVISION25 PAGE 17 OF 87

b. Action If the calculated dose from release of radioactive materials in liquid effluents exceeds any of the above limits, prepare and submit to the NRC, within 3 0 days, a special report in accordance with VP AP-2802, Notifications and Reports, that identifies causes for exceeding limits and defines corrective actions taken to reduce releases of radioactive materials in liquid effluents to ensure that subsequent releases will be in cqmpliance with the above limits.

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

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

DOMINION

d. Quarterly Composite Analyses VPAP-2103N REVISION25 PAGE 18 OF 87 For radionuclides not determined in each batch or weekly composite, dose contribution to current monthly or calendar quarter cumulative summation may be approximated by assuming an average monthly concentration based on previous monthly or quarterly composite analyses. However, for reporting purposes, calculated dose contribution shall be based on the actual composite analyses.

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

a. Requirement

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body Dose Calculation

1. Determine Drn, the total body dose from liquid effluents in the previous 31-day period, per Equation (6).

DOMINION VPAP-2103N REVISION25 PAGE 19 OF 87

2. Estimate R 1, the ratio of the estimated volume ofliquid effluent releases in the present 31-day period to the volume released in the previous 31-day period.

3. Estimate F1, the ratio of the estimated liquid effluent radioactivity concentration in the present 31-day period to liquid effluent concentration in the previous 31-day period (µCi/ml).

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

d. Projected Critical Organ Dose Calculation

1. Determine D0, the critical organ dose from liquid effluents in the previous 31-day period, per Equation ( 6).

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

3. Estimate F 1 as in Step 6.2.4.c.3.

4. Determine PD0 =projected critical organ dose in a 31-day period.

(8) (9) 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). 6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation

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

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

DOMINION VPAP-21_03N REVISlON25 PAGE 200F87

2. The dose rate limit for 1131, 1133, for tritium, and for all radioactive materials in particulate form with half-lives greater than 8 days shall be :S 1500 mrem/year to the critical organ.

b. Action

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

2. Dose rates due to noble gases in gaseous effluents shall be determined, continuously, to be within Step 6.3.l.a. limits.

3. Dose rates due to I 131, I 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents shall be determined to be within the above limits by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified on.

Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

'I DOMINION

c. Calculations of Gaseous Effluent Dose Rates VPAP-2103N REVISION25 PAGE 21OF87

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

L [KivvQivv + KipvQipv] :::; 500mrem/yr to the total body (10) OR L [(Livv + l.lMivv)Qivv + (Lipv + l.lMipv)QipvJ:::; 3000mrem/yr to the skin where: Subscripts 1.1 (11) vv, refers to vent releases from the building ventilation vent pv, refers to the vent releases from the process vent; i, refers to individual radionuclide The total body dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The skin dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The air dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) The unit conversion factor that converts air dose to skin dose, in mrem/mrad

DOMINION VPAP-2103N REVISION25 PAGE 220F87

2. The dose rate limit for I 131, I 133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days, shall be determined to be withfo. the limit by restricting the release rate to:

L [PivvQivv + PipvQipv]:::; 1500mrem/yr to the critical organ (12) where: Pivv' Pipv = The critical organ dose factor for ventilation vents or process vent for I 131, I 133, H3, ai:id all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The release rate for ventilation vents or process vent of I 131, I 133, H3, and all radionuclides i, in particulate form with half-lives greatetthan 8 days, in gaseous effluents in Curie/sec (per site) '3. All gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv. 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 6) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.l.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and*adjusted in accordance with Step 63.2.d.

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

DOMINION

b. Action VPAP-2103N REVISION25 PAGE 23 OF 87

1. If a radioactive gaseous effluent monitoring instrumentation channel alarm/trip setpoint is less conservative than required by Step 6.3.2.a.l, promptly:

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

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

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 240F 87

d. Setpoint Calculations

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

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

2. Setpoint values shall be determined by:

where: m 2.12E-03 Fm = Rm x 2.12 E-03 (14) The release pathway, process vent (pv), ventilation vent (vv) condenser air ejector ( cae) = The effluent concentration limit implementing Step 6.3.1.a. for the Station, µCi/ml The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe133 as nuclide to be released, µCi/sec CFM per ml/sec = The maximum flow rate for pathway m, CFM

DOMINION VPAP-2103N REVISION25 PAGE 25 OF 87 NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alann/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases. 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

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

During any calendar quarter: ::::; 5 mrads for gamma radiation *and ::::; 10 mrads for beta radiation
During any calendar year: ::::; 10 mrads for gamma radiation and ::::; 20 mrads for beta radiation

2. Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with Step 6.3.3.c.

at least once per 31 days.

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

DOMINION VPAP-2103N REVISION25 PAGE 260F 87

c. Noble Gas Effluent Air Dose Calculation Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv*

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (15) For beta radiation: Db = 3.17E-08L[NivvQivv + NipvQipvJ (16) Where: Subscripts 3.17 E-08 vv, refers to vent releases from the building ventilation vents, including air ejectors pv, refers to the vent releases from the process vent. i, refers to individual radionuclide = the air dose for gamma radiation, in mrad the air dose for beta radiation, in mrad the air dose factors for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) the air dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) the inverse of the number of seconds in a year

J. DOMINION VPAP-2103N REVISION25 PAGE 270F 87 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit

a. Requirement

1. Methods shall be implemented to ensure that the dose to any organ of a member of the public from I 131, I 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released from the site to unrestricted areas from each reactor unit shall be:

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

2. Cumulative dose contributions to a member of the public from I 131, I 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released to unrestricted areas for the current calendar

quarter and current calendar year shall be determined at least once per 31 days in accordance with Step 6.3.4.c.

b. Action If the calculated dose from the release of I 131, I 133, tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

DOMINION

c. Dose Calculations VPAP-2103N REVISION25 PAGE 28 OF 87 Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv* Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection to specific Station functions, such as containment purges, shall be used in the estimates as appropriate.

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary, that contain I 131, I 133, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

(17) Where: Subscripts = vv, refers to vent releases from the building ventilation vents; pv, refers to the vent releases from the process vent Dr the dose to the critical organ of the maximum exposed member of the public, in mrem RMivv, RMipv =the dose factor for ventilation vents or process vent release due to I 131, I 133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in mrem/yr per Curie/sec. Factors are listed in Critical Organ Dose Factors (Attachment 8) QivvQipv the release for ventilation vents or process vent ofl 131, I 133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in Curies 3.17 E-08 the inverse of the number of seconds in a year

DOMINION VPAP-2103N REVISION25 PAGE 29 OF 87 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Gamma Dose

1. Determine Dg, the 31-day gamma air dose for the previous 31-day period, per Equation (15).

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

DOMINION VPAP-2103N REVISION25 PAGE 30 OF 87

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

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

d. Projected Beta Dose

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

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

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

e. Projected Maximum Exposed Member of the Public Dose (18)

(19)

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

2. Estimate Fi, the ratio of the estimated activity from r131, I133, radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the current 31-day period to the activity of I 131, I 133, radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the previous 31-day period (µCi/ml).

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

(20)

DOMINION VPAP-2103N REVISION25 PAGE 31OF87 6.4

Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases.

6.4.1 Liquid Waste Batch Release Permits Operations shall obtain RP authorization before initiating batch releases of radioactive liquids. Examples of batch releases include: Batch Releases NOTE: If the clarifier is in service, releases from tanks processed through the clarifier are considered continuous releases. A Batch Release Permit is required for a release from any tanks/sumps which contain (or potentially contain) radioactive liquid. Tanks/sumps include:

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

Continuous Releases A Continuous Release Permit is required for:

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

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

DOMINION VPAP-2103N REVISION25 PAGE 320F87 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

DOMINION VPAP-2103N. REVISION25 PAGE 33 OF 87

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

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

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

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

1. Check that the correct source is authorized for release.

2. Note maximum authorized release rate.*

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

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

g. When commencing release, Operations shall provide RP with require*d.information.

As appropriate, required information shall include:

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 340F 87 6.5 Total Dose Limit to Public From Uranium.Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem). 6.5.2 Action

a.

If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.l have been exceeded.

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

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

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

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

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

DOMINION VPAP-2103N REVISION25 PAGE 35 OF 87

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 10). [Reference 3.1.31]

3. Saf?ples shall be analyzed in accordance with:

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

b. Action

1. If the Radiological Environmental Monitoring Program is not being conducted as required in Step 6.6.1.a., report the situation in accordance with VP AP-2802, Notifications and Reports, by preparing and submitting to the NRC, in the Annual Radiological Environmental Operating Report required by Technical Specifications 5.6.2, a description of the reasons for not conducting the program as required, and the plan for precluding recurrence.

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

Identifies the causes for exceeding the limits, and
Defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a member of the public is _less than the

. calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4 When more than one of the radionuclides listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected in the sampling medium, the report shall be submitted if: concentration (1) + concentration (2) +... ~ 1.0 reporting level (1) reporting level (2) (21)

DOMINION VPAP-2103N REVISION25 PAGE 36 OF 87

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected and are the result of plant effluents, the report shall be submitted ifthe potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant efflu.ents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VP AP-2802, Notifications and Reports.

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

ODCM to reflect the new locations.

6.6.2 Land Use Census

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 37 OF 87

2. In lieu of the garden census, broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the site boundary in each of.

two different direction sectors with the highest predicted ground deposition (D/Qs). Specifications for broad leaf vegetation sampling in Radiological Environmental Monitoring Program (Attachment 9) shall be followed, including analysis of control samples.

b. Action

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

2. If a land use census identifies locations that yield a calculated dose or dose commitment (via the same exposure pathway) 25 percent greater than at a location from which samples are currently being obtained, add the new locations to the Radiological Environmental Monitoring Program within 30 days. Sampling locations, excluding the control station location, that have the lowest calculated dose or dose commitments (via the same exposure pathway) may be deleted from the monitoring program. Identify new locations in the next Annual Radioactive Effluent Release Report and include in the report revised figures and tables reflecting the new locations in accordance with VP AP-2802, Notifications and Reports. [Reference 3.1.33]

6.6.3 Interlaboratory Comparison Program

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

DOMINION

b. Action VPAP-2103N REVISION25 PAGE 38 OF 87

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

Program Milk Water Air Filter Cross-Check of I 131 Gamma Sr89 and Sr90 Gross Beta, Gamma, 1131, H3 (Tritium), Sr89 and Sr90 (blirtd - any combinations of above radionuclides) Gross Beta, Gamma, Sr90

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

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

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

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

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

DOMINION

VPAP-2103N REVISION25 PAGE 390F 87

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

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

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

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

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

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

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

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment 11) was not achievable.

h. Any sample results from any groundwater wells described in the environmental program, whether the results were required by the environmental program or not.

6.7.2 Annual Radioactive Effluent Release Report

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

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

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Reference 3.1.34)

DOMINION VPAP-2103N REVISION25 PAGE 400F 87

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

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

Unplanned releases that exceeded the limits in Steps 6.2.1and6.3.1
Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tanlc or the wrong liquid radwaste release tanlc
Unplanned releases from large leaks due to unexpected valve or pipe failures

\\ that result in a quantity ofrelease such that a 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CFR 50.73, Licensee Event Report System, report is required

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

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

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

(See Step 6.7.4).

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

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

An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, and
The spill or leak must be greater than 100 gallons in volume or the volume cannot be quantified but is estimated to be greater than 100 gallons; or
Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

DOMINION VPAP-2103N REVISION25 PAGE 41OF87

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

b. Dose Assessment

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

Population doses shall not be included in dose assessments.

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

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

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

DOMINION VPAP-2I03N REVISION25 PAGE420F87 NOTE: The Annual Radioactive Effluent Report for the North Anna ISFSI is included as part of the North Anna Station Annual Radioactive Effluent Release Report.

c. ISFSI Dose Assessment

Radiation dose to individuals due to radioactive liquid and gaseous effluents during the previous calendar year shall either be calculated in accordance with this procedure or in accordance with Regulatory Guide I. I 09. Population doses shall not be included in dose assessments.
The dose to the maximum exposed member of the public due to radioactive liquid and gaseous effluents from the Station shall be incorporated with the dose assessment performed above. If the dose to the maximum exposed member of the public exceeds twice the limits of 6.2.3.a.1, 6.2.3.a.2, 6.3.3.a.I, or 6.3.4.a.l, the dose assessment shall include the contribution from direct radiation.
Meteorological conditions during the previous calendar year or historical annual average atmospheric dispersion conditions shall be used to determine gaseous pathway doses.

6.7.3 Annual Meteorological Data

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

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

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

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

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

Documentation shall include:

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

DOMINION VPAP-2103N REVISION25 PAGE 43 OF 87

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

10 CFR 20 Subpart D
40CFR190
10 CFR 50.36a
10 CFR 50, Appendix I

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

d. Submitted to NRC in accordance with VP AP-2802, Notifications and Reports.

6.7.5 Groundwater Protection Initiative [Reference 3.1.35]

a. Notifications and Reports

1. Informal communication shall be made to state/local/NRC officials by the end of the next business day for:

Any spill or leak meeting the requirements of Step 6. 7.2.a. 7.
Any groundwater sample result exceeding the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12).

2. A 30-day report shall be submitted to the NRC and a copy concurrently forwarded to state and local officials for any groundwater sampling result, whether on site or off site, exceeding the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) and having the potential to reach groundwater that is or could be used as a source of drinking water. A 30-day report is only required on the initial discovery of a contaminated groundwater plume.

b. Any spill or leak for which an informal notification is made in accordance with Step 6.7.5.a. shall be summarized in the Annual Radioactive Effluent Report.

DOMINION VPAP-2103N REVISION25 PAGE440F87

c. Any groundwater sample result from a groundwater source that is not part of the radiological environmental monitoring program shall be included in the Annual Radioactive Effluent Report.

d. Any groundwater sample result from any groundwater well described in the radiological environmental monitoring program shall be included in the Annual Radiological Environmental Operating Report.

7.0 RECORDS 7.1 The following record(s) completed as a result of this procedure are required to be transmitted to Nuclear Document Management (DNM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-100, Record Creation, Transmittal and Retrieval. Quality Assurance Records

Records of changes to the ODCM in accordance with Step 6.7.4
Records of meteorological data in accordance with Step 6.7.3
Records of sampling and analyses
Records of radioactive materials and other effluents released to the environment
Records of preventive maintenance, surveillances, and calibrations 7.2 The following item(s) completed as a result of this procedure are NOT records and are NOT required to be transmitted to Nuclear Document Management (DNM).

None

DOMINION ATTACHMENT 1 (Page I of2) VPAP-2103N REVISION25 PAGE450F87

Radioactive Liquid Effluent Monitoring Instrumentation Instrument nummum uperame Action Channels

1. Liquid Radwaste Effluent (a) 1-LW-RM-111, Liquid Radwaste Effluent Monitor 1

1 (b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow Measuring 1 2 Device (c) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel 1 1 (d) 1-LW-1130, Liquid Waste Effluent Proportional Sample Valve 1 1 (e) 1-SW-RM-108, Service Water Effluent Monitor (Note l)(Note 2) 1 1 (f) 1-SW-RM-130, *unit 1 Circulating Water System Effluent Line 1 3 Monitor (g) 2-SW-RM-230, Unit 2 Circulating Water System Effluent Line 1 3 Monitor

2. Steam Generator High Capacity Blowdown (a) Steam Generator High Capacity Blowdown Radiation Monitor Unit 1 1-SS-RM-125 1

1 Unit2 2-SS-RM-225 1 1

(b) Steam Generator High Capacity Blowdown Flash Tank Outlet Flo-w Rate Unit 1 1-BD-FT-105 1

2 Unit2 2-BD-FT-205 1 2 (c) Steam Generator High Capacity Blowdown Proportional Sampling System Collection Tank Unit 1 1-BD-TK-4 1 1 Unit2 2-BD-TK-4 1 1

DOMINION ATTACHMENT 1 (Page 2 of2) Radioactive Liquid Effluent Monitoring Instrumentation VPAP-2103N REVISION25 PAGE 460F 87 ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway may continue if, at least once within 12 hours, grab samples are collected and analyzed for gross radioactivity (beta and gamma) at an LLD of at least lxl0-7 µCi/g or an isotopic radioactivity at_ an LLD of at least 5xl 0-1 µCi/g.. ACTION 2: If the number of operable channels is less than required, effluent releases via this pathway may continue if the flow rate is estimated at least once per 4 hours during actual releases. Design capacity performance curves generated in situ may be used to estimate flow. ACTION 3: If the number of operable channels is less than required, make repairs as soon as possible. Effluent releases via this pathway may continue provided that, at least once per* 12 hours, grab samples from the discharge canal are collected and analyzed for principal gamma emitters ~s defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). NOTE 1: The capability for obtaining grab samples at least every 12 hours must exist. Grab samples shall commence if there is indication of radioactivity in the Service Water System or an indication from other radiation monitors in the Service Water System of an increase in radioactivity. NOTE 2: To utilize 1-SW-RM-108 as the effluent radiation inonitor for the associated loop, O-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

DOMINION ATTACHMENT 2 (Page 1 of2) VPAP-2103N REVISION25 PAGE 470F 87 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration Operational Test

1.

Liquid Radwaste Effluent (a) l-LW-RM-111, Liquid Radwaste Effluent Monitor D D R Q (NOTE 1) (b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow D(NOTE3) NIA R Q Measuring Device (c) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel D(NOTE4) NIA NIA NIA (d) 1-L W-1130, Liquid Waste Effluent Proportional Sample D(NOTE4) NIA NIA NIA Valve (e) 1-SW-RM-108, SW Effluent Monitor (NOTE 9) D M R Q (NOTE2) (f) 1-SW-RM-130, Unit 1 Circulating Water System D M R Q (NOTE2) Effluent Line Monitor (g) 2-SW-RM-230, Unit 2 Circulating Water System D M R Q (NOTE2) Effluent Line Monitor

2.

Steam Generator (SG) High Capacity Blowdown (a) SG High Capacity Blowdown Radiation Monitor Unit 1 l-SS-RM-125 D (NOTE 7) D(NOTE 7) R Q (NOTE6) Unit2 2-SS-RM-225 R (NOTES) (b) SG High Capacity Blowdown Flash Tank Outlet Flow Rate Unit 1 1-BD-FT-105 D (NOTE 8) NIA R NIA Unit2 2-BD-FT-205 - (c) SG High Capacity Blowdown Proportional Sampling System Collection Tank Unit I 1-BD-TK-4 D (NOTE4) NIA NIA NIA Unit2 2-BD-TK-4

DOMINION ATTACHMENT2 (Page 2 of2) VPAP-2103N REVISION25 PAGE 48 OF 87 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

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

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

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

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

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

NOTE 3: Channel Check shall consist of checking indication of flow during periods ofrelease. Channel Check shall be made at least once per 24 hours on days on which continuous, periodic, or batch releases are made. NOTE 4: Channel Check shall consist of checking that proportional flow exceeds 0.5 mls/gallon. NOTE 5: Channel Operational Test shall demonstrate that system isolation occurs on a radiation monitor High-High Alarm. NOTE 6: Channel Operational Test shall demonstrate:

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

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

NOTE 7: The radiation monitor automatically performs periodic source checks. The Source Check and Channel Check are satisfied as long as the green light is lit. NOTE 8: This is confirmed by indicated effluent flow less than or equal to 190 gpm. NOTE 9: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, O-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

DOMINION Liquid Release Type Batch Releases (N o.tes 2 and 7) Continuous Releases (Note 5) ATTACHMENT 3 (Page 1of3) VPAP-2103N REVISION25 PAGE 49 OF 87 Radioactive Liquid Waste Sampling and Analysis Program Sampling Minimum Analysis Type of Activity Lower L1m1t or Frequency Frequency Analysi~ Detection (LLD) (µCi/ml), (Note 1) p p Principle Gamma 5 x 10-1 Emitters (Note 3) (Each Batch) (Each Batch) 1131 1x10-6 p 1J1ssolved and 1x10-:i (One Batch/M) M Entrained Gases (Gamma Emitters) (Note 8) p M Composite H3 1x10-5 (Each Batch) (Note 4) Gross Alpha 1x1 o-7 p Q Composite Sr89 and sr9° 5 x 10-8 (Each Batch) (Note 4) Fe55 1x10-6 Principal Gamma 5 x 10-1 Emitters (Note 6) Continuous W Composite 1131 1x10-6 (Note 6) (Note 6) 1J1ssolved and 1 x 1 o-' M Grab Sample Entrained Gases (Gamma Emitters) (Note 8) Continuous M Composite H3 1x10-5 (Note 6) (Note 6) Gross Alpha 1x10-1 Continuous Q Composite Sr89 and Sr90 5 x 10-8 (Note 6) (Note 6) Fe55 1x10-6

DOMINION VPAP-2103N REVISION25 PAGE 50 OF 87 ATTACHMENT 3 (Page 2of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD E

V
2.22E+06
Y
e-(A.L1t)

Where: (9-1) LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.8) Sb the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 the number of disintegrations per minute (dpin) per microcurie Y = the fractional radiochemical yield (when applicable) A, the radioactive decay constant for the particular radionuclide Llt the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and Llt should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and then thoroughly mixed as the situation permits, to assure representative sampling.

DOMINION ATTACHMENT 3 (Page 3 of3) Radioactive Liquid Waste Sampling and Analysis Program VPAP-2103N REVISION25 PAGE 51OF87 NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54, Fe59, Co58, Co60, Zn65, Mo99, Cs134, Cs137, Ce141, and Ce144. This list does not mean that only thes_e nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuou_s release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously in proportion to the rate of flow of the effluent stream. Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent releases. NOTE 7: Whenever the secondary coolant activity exceeds l0-5 µCi/ml, the turbine building sump pumps shall be placed in manual operation and samples shall be taken and analyzed prior to release. Secondary coolant activity samples shall be collected and analyzed on a weekly basis. These samples are analyzed for gross activity or gamma isotopic activity within 24 hours. NOTE 8: The gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, Xe-135m and Xe-138. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides shall also be identified and reported.

DOMINION ATTACHMENT4 (Page 1 of 4) VPAP-2103N REVISION25 PAGE 52 OF 87 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower L1m1t or Detection (LLD) Type Frequency Frequency Analysis (µCi/ml), (Note 1) Prior to Release -Prmc1paTGamma 1x10-4 A. Waste Gas (Each Tank Prior to Release Emitters (Note 2) Storage Tank Grab Sample) (Each Tank) H3 1x10-6 B. Containment Prior to Release Prior to Release Prmc1ple Uamma 1x10-4 Emitters (Note 2) Purge (Each PURGE (Each PURGE) H3. 1x10~6 Grab Sample) C. Ventilation Monthly Monthly Principle Gamma 1x10-4 (1) Process Vent (Grab Sample) Emitters (Note 2) (2) Vent Vent A (Notes 3 and 5) (Note 3) H3 1x10-6 (3) Vent Vent B Continuous Weekly Il31 1x10-12 (Note 4 and 5) (Charcoal Sample) Im 1x10-iu All Release Contmuous Weekly .Pnnc1pal Gamma 1x10-11 (Note 4 and 5) Particulate Sample Emitter*(Note 2) Continuous Monthly Types as listed . (Note 4 and 5) Composite Gross Alpha 1x10-11 Particulate Sample Continuous (..!uarterly Sr89 and Sr90 in A, B, and C (Note 4 and 5) Composite 1x10-11 Particulate Contmuous Noble Gas Monitor ~oble Gases Uross 1x10-6 (Note 4 and 5) Beta or Gamma Condenser Air Weekly Weekly .Prmc1ple Uamma Ix 10-4 Ejector/Steam Emitters (Note 7) Generator Grab Sample Blowdown Vent I H3 1x10-6 (Note 6) BRTVent Containment Prior to Release Prior to each 1'rmc1ple Uamma 1x10-4 Vacuum Steam Emitters (Note 2) Ejector (Hogger) (Grab Sample) Release H3 1x10-6 (Note 8)

DOMINION ATTACHMENT 4 (Page 2 of 4) VPAP-2103N REVISION25 PAGE 53 OF 87 Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD 4.66 Sb (11-1) E

V
2.22E+06
Y
e-(Aflt)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting E v 2.22E+06 = y A, = flt rate of a blank sample as appropriate (as counts per minute, cpm) the counting efficiency (as counts per disintegration) the sall1:ple size (in units of mass or volume) the number of disintegrations* per minute ( dpm) per microcurie the fractional radiochemical yield (when applicable) the radioactive decay constant for the partieular radionuclide the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and flt should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not as "posteriori" (after the fact) limit for a particular measurement. NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87, Kr88, Xe133, Xe133m, Xe135, Xe135m, and Xe138 for gaseous emissions and Mn54, Fe59, Co58, Co60, Zn65, Mo99, Cs134, Cs137, Ce141 and Ce144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

DOMINION ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program VPAP-2103N REVISION25 PAGE 540F87 NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, if:

a. Analysis shows that the dose equivalent I 131 concentration in the primary coolant is greater than 1.0 µCi/gm; and

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

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

a. Analysis shows that the dose equivalent I 131 concentration in the primary coolant is greater than 1.0 µCi/gm and;

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

NOTE 6: Whenever the secondary coolant activity exceeds 10-5 µCi/ml, Condenser Air Ejector and Steam Generator Blowdown Vent samples shall be obtained and analyzed weekly. Secondary coolant activity samples shall be collected and analyzed on a weekly basis. These samples are analyzed for gross activity or gamma isotopic activity within 24 hours. NOTE 7: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87, Kr88, Xe133, Xe133m, Xe135, Xe135m, and Xe138 for gaseous emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD together with the above nuclides, shall also be identified and reported.

DOMINION ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program VPAP-2103N REVISION25 PAGE 55 OF 87 NOTE 8: If the secondary coolant activity level in any Steam Generator supplying steam to the Hogger exceeds 1.0E-5 µCi/ml, Steam Generator samples shall be obtained and analyzed prior to release.

DOMINION Noble Gas Radionuclide Kr-85m Kr-85 Kr-87 Kr-88 Kr-89 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Xe-137 Xe-138 Ar-41 ATTACHMENT 5 (Page 1of3) Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) x!Q = 9.3E-06 sec/m3 at 1416 meters SE Direction Dose Factors for Ventilation Vent K.ivv Livv Mivv Total Body Skin Gamma Air mrem/yr mrem/yr mrad/yr Curie/sec Curie/sec Curie/sec l.09E+04 1.36E+04 l.14E+04 l.50E+02 1.25E+04 l.60E+02 5.51E+04 9.05E+04 5.74E+04 l.37E+05 2.20E+04. l.41E+05 l.54E+05 9.39E+04 l.61E+05 8.51E+02 4.43E+03 1.45E+03 2.33E+03 9.24E+03 3.04E+03 2.73E+03 2.85E+03 3.28E+03 2.90E+04 6.61E+03 3.12E+04 l.68E+04 l.73E+04 1.79E+04 l.32E+04 l.13E+05 l.40E+04 8.21E+04 3.84E+04 8.57E+04 8.22E+04 2.50E+04 8.65E+04 VPAP-2103N REVISION25 PAGE 56 OF 87 Nivv Beta Air mrad/yr Curie/sec 1.83E+04 1.81E+04 9.58E+04 2.72E+04 9.86E+04. 1.03E+04 1.38E+04 9.77E+03 6.87E+03 2.29E+04 1.18E+05 4.42E+04 3.05E+04

DOMINION Noble Gas Radionuclide Kr-85m Kr-85 Kr-87 Kr-88 Kr-89 Xe-131m Xe-133m Xe-133 Xe-135m Xe-135 Xe-137 Xe-138 Ar-41 ATTACHMENT 5 (Page 2 of3) Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) x!Q = 1.2E-06 sec/m3 at 1513 meters S Direction Dose Factors for Process Vent K.ipv Lipv Mipv Total Body Skin Gamma Air mrem/vr mrem/yr mrad/yr Curie/sec Curie/sec Curie/sec 1.40E+03 l.75E+03 1.48E+03 l.93E+Ol l.61E+03 2.06E+Ol 7.10E+03 l.17E+04 7.40E+03 1.76E+04 2.84E+03 1.82E+04 l.99E+04 l.21E+04 2.08E+04 l.10E+02 5.71E+02 l.87E+02 3.01E+02 1.19E+03 3.92E+02 3.53E+02 3.67E+02 4.24E+02 3.74E+03 8.53E+02 4.03E+03 2.17E+03 2.23E+03 2.30E+.03 l.70E+03 1.46E+04 l.81E+03 l.06E+04 4.96E+03 l.11E+04 1.06E+04, 3.23E+03 l.12E+04 VPAP-2103N REVISION25 PAGE 57 OF 87 Nipv Beta Air mrad/vr* Curie/sec 2.36E+03 2.34E+03 l.24E+04 3.52E+03 l.27E+04 l.33E+03 1.78E+03 1.26E+03 8.87E+02 2.95E+03 l.52E+04 5.70E+03 3.94E+03

DOMINION ATTACHMENT 5 (Page 3 of3) Gaseous Effluent Dose Factors (Inhalation Pathway Dose Factors)

VPAP-2103N REVISION25 PAGE 58 OF 87 Ventilation Vent x!Q = 9.3E-06 sec/m3 at 1416 meters SE Direction Process Vent x/Q = 1.2E-06 sec/m3 at 1513 meters S Direction Pivv Pipv Radionuclide mrem/yr mrem/yr Curie/sec Curie/sec H-3 l.05E+04 1.35E+03 Cr-5I 7.95E+02 1.02E+02 Mn-54 ND ND Fe-59 ND ND Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-90 ND ND Y-9I ND ND Zr-95 ND ND Nb-95 ND ND Ru-103 ND ND Ru-I06 ND ND Ag-IIOm ND ND Te-I27m 5.64E+04 7.28E+03 Te-I29m 5.88E+04 7.59E+03 Cs-I34 ND ND Cs-136 ND ND Cs-137 ND ND Ba-I40 ND ND Ce-I4I ND ND Ce-144 ND ND I-13I 1.51E+08 1.95E+07 I-133 3.58E+07 4.62E+06 ND - No data for dose factor according to Regulatory Guide I. I 09, Revision I

DOMINION ATTACHMENT 6 (Page 1of3) Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE CHANNELS

1. PROCESS VENT SYSTEM (a)

Noble Gas Activity Monitor 1-GW-RM-178-1 1 (NOTE3) (b) Iodine Sampler 1-GW-RM-178-1 1 Process Vent Continuous HP Sampler (NOTE 3) (c) Particulate Sampler 1-GW-RM-178-1 1 Process Vent Continuous HP Sampler (NOTE3) (d) Total Flow Monitor 1-GW-FT-108 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 HP Sampler Rotameter (NOTE 3)

2. CONDENSER AIR EJECTOR SYSTEM (a)

Gross Activity Monitor Unit 1 1-SV-RM-121 1 Unit 2 2-SV-RM-221 (b) Flow Rate Measuring Device Unit 1 1-SV-FI-IOOA 1-SV-FI-lOlA 1(NOTE1) 1-SV-FI-IOOB 1-SV-FI-lOIB Unit2 2-SV-FI-200A 2-SV-Fl-201A 1 (NOTE2) 2-SV-FI-200B 2-SV-FI-201B VPAP-2103N REVISION25 PAGE 59 OF 87 ACTION 2,4 2, 5 2,5 1 1 3 1 1

DOMINION ATTACHMENT 6 (Page 2 of3) Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE CHANNELS

3. VENTILATION VENT A (a)

Noble Gas Activity Monitor 1-VG-RM-179-1 I (NOTE 3) (b) Iodine Sampler 1-VG-RM-179-1 I Vent Vent A Continuous HP Sampler (NOTE3) (c) Particulate Sampler 1-VG-RM-179-1 I Vent Vent A Continuous HP Sampler (NOTE 3) (d) Total Flow Monitor 1-HV-FT-1212A I (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device I HP Sampler Rotameter (NQTE_3)

4. VENTILATION VENT B (a)

Noble Gas Activity Monitor 1-VG-RM-180-1 I (NOTE 3) (b) Iodine Sampler 1-VG-RM-180-1 I Vent Vent B Continuous HP Sampler (NOTE 3) * (c) Particulate Sampler 1-VG-RM-180-1 I Vent Vent B Continuous HP Sampler. (NQTE 3) (d) Total Flow Monitor 1-HV-FT-1212B I (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device I HP Sampler Rotameter (NOTE 3) VPAP-2103N REVISION25 PAGE600F 87 .ACTION 2 2 2 I I 2 2 2 I I

DOMINION ACTION 1: ACTION2: ACTION3: ACTION 4: ACTIONS: ATTACHMENT 6 (Page 3 of3) Radioactive Gaseous Effluent Monitoring Instrumentation VPAP-2103N REVISION25 PAGE 61OF87 If the number of operable channels is less than required, effluent releases, via this path, may continue if the flow rate is estimated at least once per four hours. If the number of operable channels is less than required, effluent releases, via this path, may continue if grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity or gamma isotopic activity within 24 hours. If the number of operable channels is less than required, effluent releases via this path may continue if grab samples are taken at least once per twelve (12) hours and these samples are analyzed for gross activity or gamma isotopic activity within eight (8) hours. TP.is requirement is for effluent accountability and is distinct and separate from any requirement for primary-to-secondary leak rate determination. The need to determine the primary-to-secondary leak rate, e.g., the performance of 1/2-PT-46.3B, shall be determined in accordance with the requirements ofTRM TR 3.4.5. However, the same sample may be used to fulfill both the requirements of this action and primary-to-secondary leak rate determination. If the number of operable channels is less than required, the contents of the Waste Gas Decay

Tanks may be released to the environment prov~ded that prior to initiation of the release:

a.

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

b.

At least two technically qualified members of the Station staff independently check the release rate calculations and discharge valve lineup. If the number of operable channels is less than required, effluent releases from the Waste Gas Decay Tank may continue provided samples are continuously collected with auxiliary sampling equipment as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). NOTE 1: A channel shall consist of:

a.

The flow instrument installed in the ejector through which the discharge is routed; either Train A (1-SV-FI-lOOA, 101A), or Train B (1-SV-FI-lOOB, 101B) or both.

b.

Flow instruments 10 IA and 101B provide low range measurement. Flow instruments 1 OOA and 1 OOB provide high range measurement. NOTE 2: A channel shall consist of:

a.

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

b.

Flow instruments 201A and 20 lB provide low range measurement. Flow instruments 200A and 200B provide high range measurement. NOTE 3: A channel shall consist of a MGPI monitor; and a MGPI or HP particulate and iodine sampler, and its associated sampler flow rate measuring device or rotameter.

DOMINION ATTACHMENT 7 (Page 1 of3) VPAP-2103N REVISION25 PAGE 62 OF 87 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL DESCRIPTION CHANNEL SOURCE CHANNEL Channel CHECK CHECK CALIBRATION Operational Test I. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor l-GW-RM-178-1 D M(NOTE5) R Q (NOTE 1) (b) Iodine Sampler l-GW-RM-178-1 W. NIA NIA NIA Process Vent Continuous HP Sampler D (NOTE3) NIA NIA NIA (c) Particulate Sampler l-GW-RM-178-1 w NIA NIA NIA Process Vent Continuous HP Sampler D (NOTE3) NIA NIA NIA (d) Total Flow Monitor l-GW'-FT-108 D NIA R* Q (e) Sampler Flow Rate Measuring Device MGPI Ffow Rate Measuring D (NOTE3) NIA R NIA

Device HP Sampler Rotameter D (NOTE3)

NIA Every 18 months NIA

2. CONDENSER AIR EJECTOF SYSTEM (a)

Noble Gas Activity Monitor Unit 1 l-SV-RM-121 D M R Q,R(NOTE6) Unit 2 2-sv-RM:..221 (b) Flow Rate Measuring Device Unit 1 1-SV-FI-lOOA 1-SV-FI-lOlA D NIA R NIA 1-SV-FI-lOOB 1-SV-FI-lOlB Unit2 2-SV-FI-200A 2-SV-FI-201A D NIA R NIA 2-SV-FI-200B 2-SV-FI-201B

DOMINION ATTACHMENT 7 (Page 2 of3) VPAP-2103N REVISION25 PAGE 63 OF 87 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL DESCRIPTION CHANNEL SOURCE CHANNEL Channel CHECK CHECK CALIBRATION Operational Test

3. VENTILATION VENT A (a)

Noble Gas Activity Monitor 1-VG-RM-179-1 D M(NOTES) R Q(NOTE2) (b) Iodine Sampler 1-VG-RM-179-1 w NIA NIA NIA Vent Vent A Continuous HP Sampler D (NOTE3) NIA NIA NIA (c) Particulate Sampler l-VG-RM-179-1 w NIA NIA NIA Vent Vent A Continuous HP Sampler D (NOTE3) NIA NIA NIA (d) Total Flow Monitor 1-HV-FT-1212A D NIA R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D(NOTE3) NIA R NIA Device HP Sampler Rotameter D(NOTE3)

NIA Every 18 months NIA

4. VENTILATION VENT B (a)

Noble Gas Activity Monitor 1-VG-RM-180-1 D M(NOTE5) R Q (NOTE2) (b) Iodine Sampler 1-VG-RM-180-1 w NIA NIA NIA Vent Vent B Continuous HP Sampler D(NOTE3) NIA NIA NIA (c) Particulate Sampler 1-VG-RM-180-1 w NIA NIA NIA Vent Vent B Continuous HP Sampler D(NOTE3) NIA NIA NIA (d) Total Flow Monitor 1-HV-FT-1212B D NIA R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D(NOTE3) NIA R NIA Device HP Sampler Rotameter

D(NOTE3)

NIA R NIA

DOMINION ATTACHMENT 7 (Page 3 of3) VPAP-2103N REVISION25 PAGE 64 OF 87 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

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

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

NOTE 2: The Channel Operational Test shall demonstrate:

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

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

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

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

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

NOTE 5: Monitors 1-GW-RM-178-1, 1-VG-RM-179-1, and 1-VG-RM-180-1 perform periodic source checks automatically. NOTE 6: The quarterly, Q, Channel Operational Test shall demonstrate that Control Room Alarm annuciation occurs ifthe instrument indicates measured levels above the alarm/trip setpoint and alarm annunciation occurs ifthe instrument controls are not set in the "operate" mode. The refueling, R, Channel Operational Test shall demonstrate:

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

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

DOMINION ATTACHMENT 8 (Page 1 of2) Critical Organ Dose Factors (Critical Pathway Dose Factors) Ventilation Vent X/Q = 3.3E-6 at 1593 meters SSE Direction Process Vent X/Q = 9.5E-7 at 1593 meters SSE Direction Ventilation Vent D/Q = 1.7E-8 at 1593 meters SSE Direction Process Vent D/Q = 1.lE-8 at 1593 meters SSE Direction K1Vlivv VPAP-2103N REVISION25 PAGE 65 OF 87 K1Vlipv Radionuclide mrem/yr mrem/yr Curie/sec Curie/sec H-3 1.32E+4 3.81E+3 Mn-54 ND ND Fe-59 ND ND Cr-51 1.l 1E+3 7.16E+2 Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-89 ND ND Sr-90. ND ND Y-91 ND ND Zr-95 ND.. ND Nb-95 ND ND Ru-103 ND ND Ru-106 ND. ND Ag-llOrn ND ND Te-127m 5.37E+6 3.48E+6 Te-129m 4.61E+6 2.98E+6* I-131 8.08E+8 5.23E+8 I-133 1.38E+7 8.93E+6 Cs-134 ND ND Cs-136 ND ND Cs-137 ND ND Ba-140 ND ND Ce-141 ND ND

DOMINION Radionuclide Ce-144 ATTACHMENT 8 (Page 2 of2) Critical Organ Dose Factors KMivv rnrern/yr Curie/sec ND VPAP-2103N REVISION25 PAGE 66 OF 87 KMipv rnrern/yr Curie/sec ND ND - No data for dose factor accordmg to Regulatory Gmde 1.109, Rev1s1on 1

DOMINION RADIATION (NOTE 3) ATTACHMENT 9 (Page 1of5) Radiological Environmental Monitoring Program 36 routine monitoring stations, either with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, to be placed as follows:

1) An inner ring of stations, one in each environmental meteorological sector

. within the site boundary

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

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

\\ Quarterly VPAP-2103N REVISION25 PAGE 670F 87 GAMMA DOSE Quarterly ese are not part o t e env1ronmenta

DOMINION Radioiodines and Particulates a) Surface b) Ground c) Sediment VPAP-2103N REVISION25 PAGE 68 OF 87 ATTACHMENT 9 (Page 2 of5)

Radiological Environmental Monitoring Program Samples from 5 locations:

a) 3 samples from close to the 3 site boundary locations (in different sectors) of the highest calculated historical annual average ground level D/Q b) 1 sample from the vicinity of a community having the highest calculated annual average ground level D/Q c) 1 sample from a control location 15-40 km distant and in the least prevalent wind directio Samples from 3 locations: a) 1 sample upstream b) 1 sample downstream c) 1 sample from cooling lagoon Sample from 1 or 2 sources only if likely to be affected 1 sample from downstream area with existing or potential recreational value Continuous

sampler, operation with Radioiodine Canister I 131 Analysis, weekly sample collection Particulate Sampler weekly Gross beta radioactivity analysis following filter change; (NOTE 4)

Grab Monthly Grab Quarterly Semi-Annually Gamma isotopic analy-sis of composite (by location) quarterly (NOTE 5) Gamma isotopic analysis monthly; (NOTE 5) Composite for tritium analysis quarterly amma 1sotop1c an tntmm analysis quarterly (NOTE

5)

Gamma isotopic analysis semi-annually (NOTE 5)

DOMINION Exposure Pathway and/or Sample

4. lNUt::STlUN a) Milk (NOTE 7) b) Fish and Invertebrates c) Food Products ATTACHMENT 9 (Page 3 of 5)

VPAP-2103N REVISION25 PAGE 69 OF 87 Radiological Environmental Monitoring Program Number of Sample and Collection Type and Frequency of Sample Location (NOTE 2) Frequency Analysis a) Samples from milking animals in 3 locations within 5 km that have the highest potential. If there are none, then 1 sample from milking animals in each of 3 areas between 5 to 8 km where Monthly at all Gamma isotopic (NOTE 5) doses are calculated to be times and I 131 analysis monthly greater than 1 mrem per yr (NOTE 6) b) 1 sample from milking animals at a control location (15-30 km in the least prevalent wind direction) a) 1 sample of commercially and recreationally important species (bass, sunfish, catfish) in vicinity of plant discharge Semiannually Gamma isotopic on edible area portions b) 1 sample of same species in areas not influenced by plant .discharge a) Samples of an edible broad leaf vegetation grown nearest each of two different off site locations of highest predicted historical annual average Monthly if ground level D/Q if milk available, or Gamma isotopic (NOTE 5) sampling is not performed at harvest and I 131 analysis b) 1 sample of broad leaf vegetation grown 15-30 km in the least prevalent wind direction if milk sampling is not performed

DOMINION ATTACHMENT 9 (Page 4of5) Radiological Environmental Monitoring Program VPAP-2103N REVISION25 PAGE 700F87 NOTE 1: The number, media, frequency, and location of samples may vary from site to site. This table presents an acceptable minimum program for a site at which each entry is applicable. Local site characteristics must be examined to determine if pathways not covered by this table may significantly contribute to an individual's dose and be included in the sampling program. NOTE 2:

For each and every sample location in Environmental Sampling Locations (Attachment 10),

specific parameters of distance and direction sector from the centerline of the reactor, and additional desci:iption where pertinent, shall be provided in Attachment 10. Refer to Radiological Assessment Branch Technical Positions and to NUREG-*0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plant. Deviations are permitted from the required sampling schedule if specimens are unattainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipmerttand other legitimate reasons. If specimens are unattainable due to sampling equipment malfunction, every effort shall be made to complete corrective action before the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental *Operating Report pursuant to Step 6.7.1. It is recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location-or time. In these instances, suitable alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program. In lieu of a Licensee Event Report and pursuant to Step 6. 7.2, identify the cause of the unavailability of samples for that pathway and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report, and include revised figures and tables from the ODCM reflecting the new locations in the report.

DOMINION ATTACHMENT 9 (Page 5of5) Radiological Environmental Monitoring Program VPAP-2103N REVISION25 PAGE 71OF87 NOTE 3: One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. For the purposes of this table, a thermo luminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation. The 3 6 stations are not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations, e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading. NOTE 4: Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than ten times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. NOTE 5: Gamma isotopic analysis is the identification and quantification of gamma-emitting radionuclides that may be attributable to effluents from the facility. NOTE 6: The dose shall be calculated for the maximum organ and age group, using the methodology and parameters in the ODCM. NOTE 7: If milk sampling cannot be performed, use item 4.c (Page 3of5, Radiological Environmental Monitoring Program (Attachment 9)); NOTE: Additionally, the following TLDs are placed in the indicated locations for Emergency Plan requirements. This is due to the fact that Emergency Plan and Environmental Plan grid centers are in different locations. These TLDs are collected quarterly.in conjunction with Environmental Sector TLDs. EP Sector TLD Designator Location A EPSAl/2 On fence, U-2 side, Intake Structure F EPSF 3/4 On power pole on island (across from FPPH) R EPSR5/6 On door of Substation "M" p EPSP 9/10 On/near Switchyard gate J EPSJ 7/8 NW corner of the Generator Rewind Bldg.

DOMINION

sample Media Environmenta TLDs ATTACHMENT 10 (Page 1 of 5)

Environmental Sampling Locations Distance and Direction From Unit No. 1 Location Station Distance Direction No. (Miles) I NAPS Waste Treatment 01 0.20 NE Plant, end of parking lot B Frederick's Hall 02 5.30 SSW Mineral, VA 03 7.10 WSW Wares Crossroads 04 5.10 WNW Route 752 05 4.20 NNE Sturgeon's Creek Marina 05A 2.04 N Levy, VA 06 4.70 ESE Bumpass, VA 07 7.30 SSE End of Route 685 21 1.00 WNW Route 700 22 1.00 wsw* Aspen Hills" 23 0.93 SSE Orange, VA 24 22.00 NW Bearing Cooling Tower N-1/33 0.06 N Sturgeon's Creek Marina N-2/34 2.04 N Parking Lot "C" NNE-3/35 0.24 NNE Good Hope Church NNE-4/36 3.77 NNE NAPS Waste Treatment NE-5/37 0.20 NE Plant, end of parking lot B Bogg's Drive NE-6/38

1.46 NE Weather Tower Fence ENE-7/39 0.36 ENE Route 689 ENE-8/40 2.43 ENE Near Training Facility E-9/41 0.30 E

"Mommg Ulory Hill" .b-1U/4L 2.l:S.) .b lsland Dike b~.b-11/4.:J U.lL .b~.b Koute 61.'l. .b~.b-lL/44 4."/U .b~.b VPAP-2103N REVISION25 PAGE720F87 Collection. Remarks Frequency Quarterly& On-Site Annually Quarterly & Annually. Quarterly& Annually Quarterly& Annually Quarterly& Annually Quarterly& Annually Quarterly& Annually Quarterly& Annually Quarterly& Site Boundary Annually Quarterly& Site Boundary Annually Quarterly& Site Boundary Annually Quarterly& Control Annually Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly On-Site vuarterly

l. uarterly Un-Site

l. uarterly

DOMINION Sample Media Environmental TLDs ATTACHMENT 10 (Page 2of5) Environmental Sampling Locations Distance and Direction From Unit No. 1 Location Station U1stance Direction No. (Miles) Biology Lab SE-13/45 0.64 SE Route 701 SE-14/46 5.88 SE (Dam Entrance) "Aspen Hills" SSE-15/47 0.93 SSE Elk Creek SSE-16/48 2.33 SSE NAPS Access Road S-17/49 0.36 s Elk Creek Church S-18/50 1.55 s NAPS Access Road SSW-19/51 0.24 SSW Route 618 SSW-20/52 5.30 SSW 500KVTower SW-21/53 0.60 SW Route 700 SW-22/54 3.96 SW At NAPS, on pole, SE of WSW-23/55 0.38 WSW switchyard, entrance on Rt. 700 Route 700 WSW-24/56 1.00 WSW South Gate of W-25/57 0.32 w Switchyard Route 685 W-26/58 1.55 w End of Route 685 WNW-27/59 1.00 WNW Route 685 WNW-28/60 1.40 WNW Laydown Area North NW-29/61 0.52 NW Gate Lake Anna Campgrounc NW-30/62 2.54 NW

1/#2 Intake NNW-31/63 0.07 NNW Route 208 NNW-32/64 2.21 NNW Bumpass Post Office C-112 7.30 SSE Orange, VA C-314 22.00 NW Mineral, VA C-516 7.10 WSW Louisa, VA C-7/8 11.54 WSW VPAP-2103N REVISION25 PAGE 73 OF 87

-Collect10n Remarks Frequency Quarterly On-Site Quarterly Quarterly Site Boundary Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Site Boundary Quarterly On-Site Quarterly Quarterly 1site Boundary Quarterly Quarterly On-Site Quarterly Quarterly On-Site Quarterly Quarterly Quarterly Control Quarterly Quarterly Control

DOMINION

sample Media Airborne Particulate and Radioiodine surtace water

[Reference 3.1.31] Uroundwater (well water) Aquatic Sediment Shoreline Soil Soil ATTACHMENT 10 (Page 3of5) Environmental Sampling Locations VPAP-2103N REVISION25 PAGE 74 OF 87 Distance and Direction From Unit No. 1 Location

station JJ1stance Direction t.:011ect1on Remarks No.

(Miles) Frequency NAPS Waste Treatment 01 0.20 NE Weekly On-Site Plant, end of parking lot B Biology Lab 01-A 0.64 SE Weekly On-Site Frederick's Hall

02.

5.30 SSW Weekly Mineral, VA 03 7.10 WSW Weekly Wares Crossroads 04 5.10 WNW Weekly Route 752 05 4.20 NNE Weekly Sturgeon's Creek Marina 05A 2.04 N Weekly Levy, VA 06 4.70 ESE Weekly Bumpass, VA 07 7.30 SSE Weekly End of Route 685 21 1.00 WNW Weekly Site Boundary Route 700 22 1.00 WSW Weekly Site Boundary "Aspen Hills" 23 0.93 SSE Weekly Site Boundary Orange, VA 24 22.00 NW Weekly Control Waste Heat Treatment Facility (Second Cooling 08 3.37 SSE Monthly Lagoon) North Anna River (upstream) Rt 669 Bridge 09A 12.9 WNW Monthly Control (Brook's Bridge) North Anna River 11 5.80 SE Monthly (downstream) Biology Lab OlA 0.64 SE Quarterly Waste Heat Treatment Semi-Facility (Second Cooling 08 3.37 SSE Annually Lagoon) North Anna River Semi-(upstream) Rt 669 Bridge 09A 12.9 WNW Annually Control (Brook's Bridge) North Anna River 11 5.80 SE Semi-(downstream) Annually LakeAnna 08 3.37 SSE Semi-Annually NAPS Waste Treatment Plant, end of parking lot B 01 0.20 NE Once per 3 yrs On-Site

DOMINION

Sample Media

Soil (continued)

Milk Fish Food Products (Edible broadleaf vegetation a) ATTACHMENT 10 (Page 4of5) Environmental Sampling Locations Distance and Direction From Unit No. 1 Location

Station JJistance U1rect10n Collect1on No.

(Miles) Frequency Fredericks Hall U2 ).JU

s:sw Once per ::; yrs Mineral, VA 03 7.10 WSW Once per 3 yrs Wares Crossroads 04 5.10 WNW Once per 3 yrs Route 752 05 4.20 NNE Once per 3 yrs Sturgeon's Creek 05A 2.04 N

Once per 3 yrs Marina Levy, VA 06 4.70 ESE Once per 3 yrs Bumpass, VA 07 7.30 SSE Once per 3 yrs End of Route 685 21 1.00 WNW Once per 3 yrs Route 700 22 1.00 WSW Once per 3 yrs "Aspen Hills" 23 0.93 SSE Once per 3 yrs Orange, VA 24 22.00 NW Once per 3 yrs Lakeside Dairy 12A 7.50 NW Monthly (Charles Harris) Waste Heat Treatment Facility (Second 08 3.37 SSE Semi-Annually Cooling Lagoon) Lake Orange 25 16.50 NW Semi-Annually Stagecoach Road 14B varies NNE Monthly if available, Route 614 15 vanes SE or at harvest Route 629/522 16 varies NW Historic Ln 26 varies s Aspen Hills" Area 23 vanes SSE VPAP-2103N REVISION25 PAGE 75 OF 87 KemarKs Site Boundary Site Boundary Site Boundary Control Control Control

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

DOMINION ATTACHMENT 10 (Page 5of5) Environmental Sampling Locations VPAP-2103N REVISION25 PAGE 76 OF 87 NOTE: Additionally, the following TLDs are placed in the indicated locations for Emergency Plan requirements. This is due to the fact that Emergency Plan and Environmental Plan grid centers are in different locations. These TLDs are collected quarterly in conjunction with Environmental Sector TLDs. EP Sector TLD Designator Location A EPSAl/2 On fence, U-2 side, Intake Structure F EPSF 3/4 On power pole on island (across from FPPH) R EPSR5/6 On door of Substation "M" p EPSP 9/10 On/near Switchyard gate J EPSJ7/8 NW comer of the Generator Rewind Bldg. NOTE: ISFSI well water samples are obtained as a Conditional Use Permit issued by the County of Louisa.

DOMINION Analysis (NOTE2) Gross beta H-3 Mn-54 Fe-59 Co-58, 60 Zn-65 Zr-95 Nb-95 I-131 (NOTE4) Cs-134 Cs-137 Ba-140 (NOTE4) La-140 (NOTE 4) ATTACHMENT 11 (Page 1 of2) VPAP-2103N REVISION25 PAGE 77 OF 87 Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Airborne Fish Food Sediment Water Particulate Milk Products (pCi/l) or Gases (pCi/kg) (pCi/l) (pCi/kg) (pCi/kg) (pCi/m3) (wet) (wet) (dry) 4 0.01 2,000 15 130 30 260 15 130 30 260 30 15 (NOTE3) 1 0.07 1 60 15 0.05 130 15 60 150 18 0.06 150 18 80 180 60 60 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported. NOTE 3: LLD for the drinking water samples. Drinking water includes samples from Lake Anna and. well samples analyzed as part of the REMP. The LLD for the non-drinking water samples is 10 pCi/I. NOTE 4: No LLD for precipitation water due to short-half lives of these nuclides.

DOMINION ATTACHMENT 11 (Page 2 of2) VPAP-2103N REVISION25 PAGE 780F87 Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) (NOTE 3) NOTE I: For a particular measurement system (which may include radiochemical separation): LLD= 4.66 Sb (25-1) E

V
2.22E+06
Y
e-(A-Lit)

Where: LLD the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) sb= the standard deviation of the background counting rate or of the counti.1;1g r;:ite E v 2.22E+06 = y A, Lit of a blank sample as appropriate (as counts per minute, cpm) the counting efficiency (as counts per disintegration) the sample size (in units of mass or Volume) the number of disintegrations per minute ( dpm) per microcurie the fractional radiochemical yield (when applicable) the radioactive decay constant for the particular radionuclide the elapsed time between sample collection (or end of the sample

collection period) and time of counting (for environmental samples, not plant effluent'samples)

Typical values of E, V, Y and.M should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION ATTACHMENT 12 (Page 1of1) VPAP-2103N REVISION25 PAGE 790F87 Reporting Levels for Radioactivity Concentrations in Environmental Samples Water Airborne Fish Milk Food Products Analysis. (pCi/l) Particulate or (pCi/kg, wet) (pCi/l). (pCi/kg, wet) Gases (pCifm3) H-3 (NOTE 1) 20,000 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 1-131 2 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 NOTE 1: For drinking water samples

DOMINION ATTACHMENT 13 (Page 1of8) Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEOROLOGICAL ANALYSIS 1.1 Purpose VPAP-2103N REVISION25 PAGE 80 OF 87 The purpose of the meteorological analysis was to determine the annual average XIQ and D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (mixed mode) releases. The annual average X/Q and D/Q values were used to perform a

dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public. The XIQ and D/Q values resulting in the maximum exposures were incorporated into the dose factors in Gaseous Effluent Dose Factors (Attachment 5) and Critical Organ Dose Factors (Attachment 8).

1.2 Meteorological Data, Parameters, and Methodology Onsite meteorological data for the period January 1, 1981, through December 31, 1981, were used in calculations. These data included wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (e.g., ventilation vent), and those characterized as mixed mode (i.e., process vent). The portions of release characterized as ground level were based on ~T1s8.9ft-28.2ft and 28.2 foot wind data, and the portions characterized as mixed mode were based on ~T1s8.9ft-28.2ft and 158.9 ft wind data. XIQ's and D/Q's were calculated using the NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations," September, 1977. The code is based upon a straight line airflow model implementing the assumptions outlined in Section C (excluding Cla an.d Clb) of Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors." The open terrain adjustment factors were applied to the XIQ values as recommended in Regulatory Guide 1.111. The site region is characterized by gently rolling terrain so open terrain correction factors were considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area.

DOMINION VPAP-2103N REVISION25 PAGE 81OF87 ATTACHMENT 13 (Page 2of8) Meteorological, Liquid, and Gaseous Pathway Analysis The effective release height used in mixed mode release calculations was based on a process vent release height of 157.5 ft, and plume rise due to momentum for a vent diameter of 3 in. with plume exit velocity of 100 ft/sec. Ventilation vent, and vent releases other than from the

process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from North Anna Power Station Units 1 and 2, Virginia Electric and Power Company Final Safety Analysis Report Table 11 C.2-8.

XIQ and D/Q values were calculated for the nearest site boundary,resident, milk cow, and vegetable garden by sector for process vent and ventilation vent releases at distances specified

from North Anna Power Station Annual Environmental Survey Data for 1981. X/Q values were also calculated for the nearest lake shoreline by sector for the process vent and ventilation vent releases.

According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges. However, these releases are considered long term for dose calculations as past releases were both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. The XIQ and D/Q values calculated from 1981 meteorological data are comparable to the values presented in the North Anna Power Station UFSAR. 1.3 Results The XIQ value that resulted in the maximum total body, skin and inhalation exposure for ventilation vent releases was 9.3E-06 sec/m3 at a site boundary location 1416 meters SE sector. For process vent releases, the site boundary X/Q value was 1.2E-06 sec/m3 at a location 1513 meters S sector. The shoreline X/Q value that resulted in the maximum inhalation exposure for ventilation vent releases was l.OE-04 sec/m3 at a location 27 4 meters NNE sector. The shoreline X/Q value for process vent was 2.7E-06 sec/m3 at a location 274 meters NNE sector.

DOMINION ATTACHMENT 13 (Page 3of8) Meteorological, Liquid, and Gaseous Pathway Analysis VPAP-2103N REVISION25 PAGE 820F87 The original pathway analysis indicated that the maximum exposure from I 131, I 133, and from all radionuclides in particulate form with half-lives greater than 8 days was through the grass-cow-milk pathway. The D/Q value from ventilation vent releases resulting in the maximum exposure was 2.4E-09 per m2 at a location 3250 meters N sector. For process vent releases, the D/Q value was 1.lE-09 per m2 at a location 3250 meters N sector. For tritium, the XIQ value from ventilation vent releases resulting in the maximum exposure for the milk pathway was 7.2E-07 sec/m3, and 3.9E-07 sec/m3 for process vent releases at a location 3250 meters N sector. Analysis using 2007 release data indicates that the most limiting critical organ is the child's thyroid. The location is 1593 meters SSE sector. For process vent releases, the DIQ is 1.lE-8. For tritium releases, the X/Q values at this location are 9.5E-7 for the process vent and 3.3E-6 for the ventilation vents. 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result ofradioactive liquid effluent releases. The analy,sis includes a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2. 2.2 Data, Parameters, and Methodology Initially, radioactive liquid effluent release data for the years 1979, 1980, and 1981 were compiled from the North Anna Power Station semi-annual effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-0133.

DOMINION VPAP-2103N REVISION25 PAGE 83 OF 87 ATTACHMENT 13 (Page 4 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis Re-concentration of effluents using the small lake connected to larger water body model was selected with the appropriate parameters determined from Table 3.5.3.5, Design Data for Reservoir and Waste Heat Treatment Facility from Virginia Electric and Power Company, Applicant's Environmental Report Supplement, North Anna Power Station, Units 1 and 2, March 15, 1972. Dilution factors for aquatic foods, shoreline, and drinking water were set to one. Transit time calculations were based on average flow rates. All other parameters were defaults selected by the LADTAP computer code. Beginning in 1997, the activity by nuclide released iy the previous year is entered into the North Anna Power Station liquid pathway critical organ calculations spreadsheet, which calculates the most limiting age group total body and critical organ. This Process is repeated annually. 2.3 Results Initially, the fish pathway resulted in the largest dose. The critical organ each year was the liver, and the adult and teenage age groups received the same organ dose. However, since the adult total body dose was greater than the teen total body dose for each year, the adult was selected as the most restrictive age group. Beginning in 1997, the most limiting age group for both total body and critical organ is calculated from the spreadsheet for North Anna Power Station liquid pathway critical organ calculations.

DOMINION ATTACHMENT 13 (Page 5of8) Meteorological, Liquid, and Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose VPAP-2103N REVISION25 PAGE 84 OF 87 A gaseous effluent pathway analysis was performed to determine the location that would result in the maximum doses due to noble gases for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analysis also included q determination of the critkal pathway, location of maximum exposed member of the public, and the critical organ for the maximum dose due to I 131, I 133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for use in demonstrating compliance with requirements in Step 6.3.4.a. l. In addition, the analysis included a determination of the critical pathway, maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131, I 133, tritium, and particulates with half-lives greater than 8 days to demonstrate compliance with Step 6.3.1.a. 3.2 Data, Parameters, and Methodology Annual average XIQ values were calculated, as described in Section 1 of this attachment, for the nearest site boundary in each directional sector and at other critical locations beyond the site boundary. The largest XIQ value was determined to be 9.3E-06 sec/m3 at site boundary for ventilation vent releases at a location 1416 meters SE direction, and l.2E-06 sec/m3 at site boundary for process vent releases at a location 1513 meters S direction. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases, would be at these site boundary locations. The doses from both release points are summed in calculations to calculate total maximum dose. Step 6.3. l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X/Q values determined for maximum noble gas doses can be used to determine the maximum dose from I 131, I 133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway.

DOMINION ATTACHMENT 13 (Page 6of8) Meteorological, Liquid, and Gaseous Pathway Analysis VPAP-2103N REVISION25 PAGE 85 OF 87 The NRC computer code GASPAR, "Evaluation of Atmospheric Releases, Revised 8/19/77, was run using 1979, 1980 and 1981 North Anna Power Station Gaseous Effluent Release Report data. Doses from I 131, I 133, tritium, and particulates for the inhalation pathway were calculated using the 9.3E-06 sec/m3 site boundary XIQ. Except for the source term data and the XIQ value, computer code default parameters were used. Results for each year indicated that the critical age group was the child and the critical organ was the thyroid for the inhalation pathway. The gamma and beta dose factors Kivv, Livv, Mivv, and Nivv in Gaseous Effluent Dose Factors (Attachment 5) were obtained by performing a units conversi<:m of the appropriate dose factors from Table B-1, Regulatory Guide 1.109, Rev. 1, to mrem/yr per Ci/m3 or mrad/yr per Ci/m3, and multiplying by the ventilation vent site boundary XIQ value of 9.3E-06 sec/m3. The same approach was used in calculating the gamma and beta dose factors Kipv. Lipv. Mipv, and Nipv in Gaseous Effluent Dose Factors (Attachment 5) using the process vent site boundary XIQ value of 1.2E-06 sec/m3. The inhalation pathway dose factors Pivv and Pipv in Gaseous Effluent Dose Factors (Attachment 5) were calculated using the following equation: where: K' = BR = DFAi = XIQ Pi = K'(BR) DFAi(X/Q) (mrem/yr per Curie/sec) (29-1) a constant of unit conversion, IE+ 12 pCi/Ci the breathing rate of the child age group, 3700 m3/yr, from Table E-5, Regulatory Guide 1.109, Rev.I the thyroid organ inhalation dose factor for child age group for the ith radionuclide, in mrem/pCi, from Table E-9, Regulatory Guide 1.109, Rev. 1 the ventilation vent site boundary XIQ, 9.3E-06 sec/m3, or the process vent site boundary XIQ, 1.2E-06 sec/m3, as appropriate

DOMINION ATTACHMENT 13 (Page 7of8) Meteorological, Liquid, and Gaseous Pathway Analysis VPAP-2103N REVISION25 PAGE 860F 87 Step 6.3.4.a., requires that the dose to the maximum exposed member of the public from I 131, I 133, tritium, and from all radionuclides in particulate form with half-lives greater than 8 days be less than or equal to the specified limits. Dose calculations were performed for an exposed member of the public within site boundary unrestricted areas, and to an exposed member of the public beyond site boundary at locations identified in the North Anna Power Station Annual Environmental Survey Data for 1981. It was determined that the member of the public within site boundary would be using Lake Anna for recreational purposes a maximum of 223 2 hours per year. It is assumed that this member of the public would be located the entire 2232 hours at the lake shoreline with the largest annual X/Q of l.OE-04 at a location 274. meters NNE sector. The NRC computer code GASP AR was run to calculate the inhalation dose to this individual. The GASP AR results were corrected for the fractional year the member of the public would be using the lake. Using the NRC computer code GASPAR and annual average X/Q and D/Q values obtained as described in Section 1 of this attachment, the member of the public receiving the largest dose beyond site boundary was determined to be located 1432 meters N sector. The critical pathway was vegetation, the maximum exposed age group was the child, and the critical organ was the thyroid. Pathway analysis results indicate that existing pathways, including ground and inhalation, within five miles ofN orth Anna Power Station, yield Ri dose factors less than those determined for the vegetation. [Reference 3.1.32] The RMivv and RMipv dose factors, except for tritium, in Critical Organ Dose Factors (Attachment 8) were calculated by multiplying the appropriate D/Q value with the following equation: RM. = K'[ (r) J(DFL.)[u FLe -'Ah+ U 8f, e-'A/h] I Yv(A,. +A ) 1 cl a g l w (29-2) where: K' a constant of unit conversion, IE+ 12 pCi/Ci Yv vegetable areal density in Kg/m2

DOMINION Uc! = Des r DFLi= Ai = Aw tf th = fL = fg = ATTACHMENT 13 (Page 8 of 8) Meteorological, Liquid, and Gaseous Pathway Analysis child leafy vegetable consumption rate, 26 Kg/yr child stored vegetable consumption rate, 520 Kg/yr VPAP-2I03N REVISION25 PAGE 870F 87 fraction of deposited activity retained on vegetation, I.O for radioiodine*, and 0.2 for particulates thyroid ingestion dose factor for the ith radionuclide for the child, in mrem/pCi, from Table E-13, Regulatory Guide l.I09, Rev. I decay constant for the ith radionuclide, in sec-1, from Kocher decay constant for removal of activity of leaf and plant surfaces by weathering, 5.73E-07 sec-1 (corresponding to a I4 day half-life) time between harvest of leafy vegetation and ingestion, 8.60E+4, in seconds time between harvest of stored vegetation and ingestion, 5. I 8E +6, in seconds

fraction of annual intake ofleafy vegetables grown locally, 1.0 (dimensionless) fraction of annual intake of stored vegetables grown locally, 0.76 (dimensionless)

Parameters used in the above equation were obtained from NUREG-0133 and Regulatory Guide I. I 09, Revision I Since the concentration of tritium in vegetation is based on the airborne concentration rather than the deposition, the Critical Organ Dose Factors (Attachment 8)for tritium were calculated by multiplying the following equation by the appropriate X/Q: (29-3) where: K"' a constant of unit conversion IE+03 gm/kg H = absolute humidity of the atmosphere, 8.0, gm/m3 0.75 = the fraction of total feed that is water 0.5 the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined.

"~ ~~.. Jiii' Dom1n1on Station Administrative Procedure *

Title:

Offsite Dose Calculation Manual (North Anna) Process I Program Owner: Manager Radiological Protection and Chemistry (North Anna) Procedure Number VPAP-2103N Revision Summary Revision Number 25 Issued an Administrative Correction as follows (SAR002776/SAA031850): Effective Date On File

Revised Attachment 10, Pages 1 and 3 to make the location name consistent with the location name in HP-3051.010 for TLD. All these locations are at 0.20 miles.

Revision initiated to incorporate assignni.ent from ACE019800/CA291380:

Step 4.15. - Changed "radiation" to "a radioactive source".

Other Changes:

Attachment 2, Section 2.a: Changed Unit 1 1-SS-RM-125/Unit 2 2-SS-RM-225 Source Check column to reflect D (NOTE 7). Wrong note designation.

Approvals on File \\

DOMINION TABLE OF CONTENTS Section 1.0 PURPOSE 2.0 SCOPE

3.0 REFERENCES

/COMMITMENT DOCUMENTS 4.0 DEFINITIONS 5.0 RESPONSIBILITIES 6.0 INSTRUCTIONS 6.1 Sampling and Monitoring Criteria . 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations 6.2.2 Liquid Monitoring Instrumentation 6.2.3 Liquid Effluent Dose Limit 6.2.4 Liquid Radwaste Treatment 6.2.5 Liquid Sampling 6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation 6.3.2 Gaseous Monitoring Instrumentation VPAP-2103N REVISION25 PAGE 20F87 Page 5 5 6 8 11 12 12 12 12 13 16 18 19 19 19 22 6.3.3 Noble Gas Effluent Air Dose Limit 25. 6.3.4 I-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit 27 6.3.5 Gaseous Radwaste Treatment 29 6.4 Radioactive Liquid and Gaseous Release Permits 31 6.4.1 Liquid Waste Batch Release Permits 31 6.4.2 Continuous Release Permit 31 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 32 6.4.4 Reactor Containment Release Penrtits 32 ..J 6.4.5 Miscellaneous Gaseous Release Permit 32

DOMINION TABLE OF CONTENTS (continued) Section. 6.4.6 Radioactive Liquid and Gaseous Release Controls 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program 6.6.2 Land Use Census 6.6.3 Interlaboratory Comparison Program

6. 7 Reporting Requirements 6.7.1 Annual Radiological Environmental Operating Report 6.7.2 Annual Radioactive Effiuent Release Report 6.7.3 Annual Meteorological Data 6.7.4 Changes to the ODCM 6.7.5 Groundwater Protection Initiative [Reference 3.1.35]

7.0 RECORDS VPAP-2103N REVISION25 PAGE 3 OF 87 Page 32 34 34 34 36 37 38 38 39 42 42 43 44

r-J DOMINION TABLE OF CONTENTS (continued)

Section ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements. 3 Radioactive Liquid.Waste Sampling and Analysis Program 4 Radioactive Gaseous Waste Sampling and Analysis Program 5 Gaseous Effluent Dose Factors 6 Radioactive Gaseous Effluent Monitoring Instrumentation 7 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 8 Critical Organ Dose Factors 9 Radiological Environmental Monitoring Program 10 Environmental Sampling Locations 11 Detection Capabilities for Environmental Sample Analysis 12 Reporting Levels for Radioactivity Concentrations in Environmental Samples

13 Meteorological, Liquid, and Gaseous Pathway Analysis VPAP-2103N REVISION25 PAGE 40F 87 Page 45 47 49 52 56 59 62 65 67 72 77 79 80

DOMINION 1.0 PURPOSE VPAP-2103N REVISION25 PAGE 5 OF 87 The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and RadiologiCal Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of off site doses due to radioactive liquid and gaseous effluents are performed to assure that:

Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CPR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/ml for dissolved or entrained noble gases.
Exposure to the maximum exposed meinber of the 'public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CPR 50, Appendix I
Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:
- Noble gases - less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
- 1131, 1133, and H3, and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ
Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CPR 50, Appendix I, and
Exposure to a real individual will not exceed 40 CPR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at North Anna Power Station.

DOMINION

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CPR 20, Standards for Protection Against Radiation VPAP-2103N REVISION25 PAGE 60F87 3.1.2 10 CPR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 197 4

3. I. 6 Regulatory Guide I. I 09, Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance With IO CPR 50, Appendix I, Rev. 1, U.S. NRC, October I977

3. I. 7 Regulatory Guide l. I 11, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 North Anna Technical Specifications 3.1.9 North Anna Technical Requirements Manual (TRM) 3.1.10 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.11 NUREG/CR-1276, Users Manual forthe LADTAP II Program, U.S. NRC, May, 1980 3.1.12 TID-4500, VCRL-50564, Rev. I, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, I 972 3.1.13 WASH 1258, Vol. 2, July I973, Numerical Guides for Design Objectives andLimiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.l.I4 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, I980 3.l.I5 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, I979, Rev. I 3.l.I6 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, I978 3.1.I 7 NUREG-0543, February 1980, Methods for Demonstrating L WR Compliance With the EPA Uranium Fuel Cycle Standard ( 40 CFR Part 190) 3.l.I8 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Wate:r_Reactors, Proposed Rev. 3, March I982

DOMINION 3.1.19 Environmental Measurements Laboratory, DOE HASL 300 Manual VPAP-2103N REVISION25 PAGE 70F87 3.1.20 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.21 North Anna UFSAR 3.1.22 Nuclear Reactor Environmental Radiation Monitoring Quality Control Manual, IWL-0032-361 3.1.23 North Anna Circulating Water System Modifications

a. DC-85-37-1 Unit 1

b. DC-85-38-2 Unit 2 3.1.24 Plant Issue (Deviation) N-1994-1137, Improper Placement of Emergency TLDs 3.1.25 ET N-05-0025, Justification for removing 1-SW-RM-108 from service when not in use 3.1.26 VPAP-2802, Notifications* and Reports 3.1.27 O-PT-75.21, 1-SW-RM-108 Flow Verification 3.1.28 SAA001092, Non-SA SOEREffectiveness Review 93-1, Recommendation 3 3.1.29 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.30 CA086406, Land Use Census Results 3.1.31 Quality Assurance Audit Report Number 91-03, Observation 08N 3.1.32 Quality Assurance Audit Report Number 92-03, Observation 02N 3.1.33 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.1.34 Plant Issue (Deviation) N-1997-0926, Annual Radiological Effluent Release Report 3.1.35 Plant Issue (Licensing Commitment) N-2006-4026-R15, Groundwater Monitoring Action Plan 3.1.36 SOER 93-1, Diagnosis and Mitigation of RCS Leakage including SGTR 3.2 Commitment Documents None

DOMINION 4.0 DEFINITIONS 4.1 Channel Calibration VPAP-2103N REVISION25 PAGE 8 OF 87 A channel calibration shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The channel calibration shall encompass all devices in the channel required for channel operability. The channel calibration may be performed by means of any series of sequential, overlapping, or total channel steps. 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and status with other indications or status derived from independent instrumentation channels measuring the same parameter. 4.3 Channel Operational Test A Channel Operational Test (COT) shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to check OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the requifed alarm, interlock, and trip setpoints required for channel OPERABILITY such that setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps. 4.4

Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. Dose calculations to the critical organ will be evaluated in accordance with Technical Specifications 5.5.4 dose rate limits specified for any organ to check that these limits have not been exceeded.

4.5 Dose Equivalent I-131 That concentration ofl131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture ofl131, I132, I133, I134, and I135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

r I DOMINION VPAP-2103N REVISION25 PAGE 90F87 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of25 percent. NOTATION FREQUENCY D - Daily W-Weekly M-Monthly Q - Quarterly SA - Semi-annually R - Refueling SIU - Start-up P - Prior to release N.A. - Not applicable DR - During the release 4.7 Gaseous Radwaste Treatment System At least once per 24 hours At least once per 7 days At least once per 31 days At least once per 92 days At least once per 184 days At least once per 18 months Prior to each reactor start-up Completed prior to each release Not applicable At least once during each release A system that reduces radioactive gaseous effluents by collecting primary coolant system off gases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers, waste gas surge tanks, and waste gas diaphragm compressor. 4.8 General Nomenclature x = Chi:.concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies) Emission rate (continuous; grams per second, curies per second) Emission rate (continuous line source; grams per second per meter) 4.9 Lower Limit of Detection (LLD) The smallest concentration of radioactive material in a sample that will yield a net count (above system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

r

r DOMINION VPAP-2103N REVISION25 PAGE 10 OF 87 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with the Station. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials.

4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., North Anna - 2940 MWt). 4.14 Site Boundary

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

4.15 Source Check A qualitative assessment of channel response when a channel sensor is exposed to a radioactive source. This applies to installed radiation monitoring systems. For MGPI monitors, a source check is the verification of proper computer response to continuous operational checks on the detector and the electronjcs. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION

I 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

4.18 Unrestricted Area VPAP-2103N REVISION25 PAGE 11OF87 Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional and/or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEP A) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components. 5.0 RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry The Manager Radiological Protection and Chemistry is responsible for: 5.1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment. 5.1.2 Surveying, sampling, and analyzing plant effluents anc!_ environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5.1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

i ) DOMINION VPAP-2103N REVISION25 PAGE 12 OF 87 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 13). 6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

1. For radionuclides (other than dissolved or entrained noble gases), liquid effluent concentrations released to unrestricted areas shall not exceed ten times the effluent concentration values specified in 10 CFR 20, Appendix B, Table 2, Column2.

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

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

{ DOMINION VPAP-2103N REVISION25 PAGE 13 OF 87

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

Volume of Waste Discharged+ Volume of Dilution Water> 1 (l) µCi/mli Volume of Waste Discharged x ~ Li ACW. I I where: µCi/mli =the concentration of nuclide i in the liquid effluent discharge ACWi =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/ml from 10 CFR 20, Appendix :i3, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/ml for dissolved or entraiµed noble gases 6.2.2 Liquid Monitoring Instrumentation

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

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

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

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

). DOMINION VPAP-2103N REVISION25 PAGE 140F 87

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

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

1) perform the action shown in those tables.

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

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

Release Point Instrument Number Liquid Radwaste Effluent Line 1-LW-RM-111 Service Water System Effluent Line 1-SW-RM-108 Condenser Circulating Water Line 1-SW-RM-130 2-SW-RM-230 Steam Generator High Capacity Blow 1-SS-RM-125 down Line 2-SS-RM-225

f DOMINION

d. Setpoint Calculation VPAP-2103N REVISION25 PAGE 15 OF 87 NOTE: This methodology does not preclude use of more conservative setpoints.

1. Maximum setpoint values shall be calculated by:

s where: S the setpoint, in µCi/ml, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution . C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station, in µCi/ml FE = maximum design pathway effluent flow rate Fn = dilution water flow rate calculated as: D =FE+ (218,000 gpm x number of circ. pumps in service) (2)

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

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

3. In addition, for added conservatism, setpoints shall be calculated for the liquid radwaste effluent line LW-111 and the Service Water System effluent line SW-108.

DOMINION

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

where: VPAP-2103N REVISION25 PAGE 160F 87 (4) KLw = The fraction of the effluent concentration limit, used to implement 10 CFR 20 for the site, attributable to the liquid radwaste effluent line pathway

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

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

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

6.2.3 Liquid Effluent Dose Limit

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

1. During any calendar quarter:

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

2. During any calendar year:

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

t DOMINION VPAP-2103N REVISION25 PAGE 17 OF 87

b. Action If the calculated dose from release of radioactive materials in liquid effluents exceeds any of the above limits, prepare and submit to the NRC, within 3 0 days, a special report in accordance with VP AP-2802, Notifications and Reports, that identifies causes for exceeding limits and defines corrective actions taken to reduce releases of radioactive materials in liquid effluents to ensure that subsequent releases will be in cqmpliance with the above limits.

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

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

DOMINION

d. Quarterly Composite Analyses VPAP-2103N REVISION25 PAGE 18 OF 87 For radionuclides not determined in each batch or weekly composite, dose contribution to current monthly or calendar quarter cumulative summation may be approximated by assuming an average monthly concentration based on previous monthly or quarterly composite analyses. However, for reporting purposes, calculated dose contribution shall be based on the actual composite analyses.

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

a. Requirement

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body Dose Calculation

1. Determine Drn, the total body dose from liquid effluents in the previous 31-day period, per Equation (6).

DOMINION VPAP-2103N REVISION25 PAGE 19 OF 87

2. Estimate R 1, the ratio of the estimated volume ofliquid effluent releases in the present 31-day period to the volume released in the previous 31-day period.

3. Estimate F1, the ratio of the estimated liquid effluent radioactivity concentration in the present 31-day period to liquid effluent concentration in the previous 31-day period (µCi/ml).

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

d. Projected Critical Organ Dose Calculation

1. Determine D0, the critical organ dose from liquid effluents in the previous 31-day period, per Equation ( 6).

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

3. Estimate F 1 as in Step 6.2.4.c.3.

4. Determine PD0 =projected critical organ dose in a 31-day period.

(8) (9) 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). 6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation

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

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

DOMINION VPAP-21_03N REVISlON25 PAGE 200F87

2. The dose rate limit for 1131, 1133, for tritium, and for all radioactive materials in particulate form with half-lives greater than 8 days shall be :S 1500 mrem/year to the critical organ.

b. Action

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

2. Dose rates due to noble gases in gaseous effluents shall be determined, continuously, to be within Step 6.3.l.a. limits.

3. Dose rates due to I 131, I 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents shall be determined to be within the above limits by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified on.

Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

'I DOMINION

c. Calculations of Gaseous Effluent Dose Rates VPAP-2103N REVISION25 PAGE 21OF87

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

L [KivvQivv + KipvQipv] :::; 500mrem/yr to the total body (10) OR L [(Livv + l.lMivv)Qivv + (Lipv + l.lMipv)QipvJ:::; 3000mrem/yr to the skin where: Subscripts 1.1 (11) vv, refers to vent releases from the building ventilation vent pv, refers to the vent releases from the process vent; i, refers to individual radionuclide The total body dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The skin dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The air dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) The unit conversion factor that converts air dose to skin dose, in mrem/mrad

DOMINION VPAP-2103N REVISION25 PAGE 220F87

2. The dose rate limit for I 131, I 133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days, shall be determined to be withfo. the limit by restricting the release rate to:

L [PivvQivv + PipvQipv]:::; 1500mrem/yr to the critical organ (12) where: Pivv' Pipv = The critical organ dose factor for ventilation vents or process vent for I 131, I 133, H3, ai:id all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) The release rate for ventilation vents or process vent of I 131, I 133, H3, and all radionuclides i, in particulate form with half-lives greatetthan 8 days, in gaseous effluents in Curie/sec (per site) '3. All gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv. 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 6) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.l.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and*adjusted in accordance with Step 63.2.d.

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

DOMINION

b. Action VPAP-2103N REVISION25 PAGE 23 OF 87

1. If a radioactive gaseous effluent monitoring instrumentation channel alarm/trip setpoint is less conservative than required by Step 6.3.2.a.l, promptly:

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

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

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 240F 87

d. Setpoint Calculations

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

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

2. Setpoint values shall be determined by:

where: m 2.12E-03 Fm = Rm x 2.12 E-03 (14) The release pathway, process vent (pv), ventilation vent (vv) condenser air ejector ( cae) = The effluent concentration limit implementing Step 6.3.1.a. for the Station, µCi/ml The release rate limit for pathway m determined from methodology in Step 6.3.1.c., using Xe133 as nuclide to be released, µCi/sec CFM per ml/sec = The maximum flow rate for pathway m, CFM

DOMINION VPAP-2103N REVISION25 PAGE 25 OF 87 NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alann/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases. 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

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

During any calendar quarter: ::::; 5 mrads for gamma radiation *and ::::; 10 mrads for beta radiation
During any calendar year: ::::; 10 mrads for gamma radiation and ::::; 20 mrads for beta radiation

2. Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with Step 6.3.3.c.

at least once per 31 days.

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

DOMINION VPAP-2103N REVISION25 PAGE 260F 87

c. Noble Gas Effluent Air Dose Calculation Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv*

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (15) For beta radiation: Db = 3.17E-08L[NivvQivv + NipvQipvJ (16) Where: Subscripts 3.17 E-08 vv, refers to vent releases from the building ventilation vents, including air ejectors pv, refers to the vent releases from the process vent. i, refers to individual radionuclide = the air dose for gamma radiation, in mrad the air dose for beta radiation, in mrad the air dose factors for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) the air dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) the inverse of the number of seconds in a year

J. DOMINION VPAP-2103N REVISION25 PAGE 270F 87 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit

a. Requirement

1. Methods shall be implemented to ensure that the dose to any organ of a member of the public from I 131, I 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released from the site to unrestricted areas from each reactor unit shall be:

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

2. Cumulative dose contributions to a member of the public from I 131, I 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released to unrestricted areas for the current calendar

quarter and current calendar year shall be determined at least once per 31 days in accordance with Step 6.3.4.c.

b. Action If the calculated dose from the release of I 131, I 133, tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

DOMINION

c. Dose Calculations VPAP-2103N REVISION25 PAGE 28 OF 87 Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv* Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection to specific Station functions, such as containment purges, shall be used in the estimates as appropriate.

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary, that contain I 131, I 133, tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

(17) Where: Subscripts = vv, refers to vent releases from the building ventilation vents; pv, refers to the vent releases from the process vent Dr the dose to the critical organ of the maximum exposed member of the public, in mrem RMivv, RMipv =the dose factor for ventilation vents or process vent release due to I 131, I 133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in mrem/yr per Curie/sec. Factors are listed in Critical Organ Dose Factors (Attachment 8) QivvQipv the release for ventilation vents or process vent ofl 131, I 133, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in Curies 3.17 E-08 the inverse of the number of seconds in a year

DOMINION VPAP-2103N REVISION25 PAGE 29 OF 87 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Gamma Dose

1. Determine Dg, the 31-day gamma air dose for the previous 31-day period, per Equation (15).

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

DOMINION VPAP-2103N REVISION25 PAGE 30 OF 87

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

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

d. Projected Beta Dose

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

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

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

e. Projected Maximum Exposed Member of the Public Dose (18)

(19)

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

2. Estimate Fi, the ratio of the estimated activity from r131, I133, radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the current 31-day period to the activity of I 131, I 133, radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the previous 31-day period (µCi/ml).

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

(20)

DOMINION VPAP-2103N REVISION25 PAGE 31OF87 6.4

Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases.

6.4.1 Liquid Waste Batch Release Permits Operations shall obtain RP authorization before initiating batch releases of radioactive liquids. Examples of batch releases include: Batch Releases NOTE: If the clarifier is in service, releases from tanks processed through the clarifier are considered continuous releases. A Batch Release Permit is required for a release from any tanks/sumps which contain (or potentially contain) radioactive liquid. Tanks/sumps include:

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

Continuous Releases A Continuous Release Permit is required for:

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

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

DOMINION VPAP-2103N REVISION25 PAGE 320F87 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

DOMINION VPAP-2103N. REVISION25 PAGE 33 OF 87

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

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

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

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

1. Check that the correct source is authorized for release.

2. Note maximum authorized release rate.*

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

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

g. When commencing release, Operations shall provide RP with require*d.information.

As appropriate, required information shall include:

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 340F 87 6.5 Total Dose Limit to Public From Uranium.Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem). 6.5.2 Action

a.

If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.l have been exceeded.

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

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

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

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

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

DOMINION VPAP-2103N REVISION25 PAGE 35 OF 87

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 10). [Reference 3.1.31]

3. Saf?ples shall be analyzed in accordance with:

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

b. Action

1. If the Radiological Environmental Monitoring Program is not being conducted as required in Step 6.6.1.a., report the situation in accordance with VP AP-2802, Notifications and Reports, by preparing and submitting to the NRC, in the Annual Radiological Environmental Operating Report required by Technical Specifications 5.6.2, a description of the reasons for not conducting the program as required, and the plan for precluding recurrence.

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

Identifies the causes for exceeding the limits, and
Defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a member of the public is _less than the

. calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4 When more than one of the radionuclides listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected in the sampling medium, the report shall be submitted if: concentration (1) + concentration (2) +... ~ 1.0 reporting level (1) reporting level (2) (21)

DOMINION VPAP-2103N REVISION25 PAGE 36 OF 87

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected and are the result of plant effluents, the report shall be submitted ifthe potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant efflu.ents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VP AP-2802, Notifications and Reports.

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

ODCM to reflect the new locations.

6.6.2 Land Use Census

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

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

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

DOMINION VPAP-2103N REVISION25 PAGE 37 OF 87

2. In lieu of the garden census, broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the site boundary in each of.

two different direction sectors with the highest predicted ground deposition (D/Qs). Specifications for broad leaf vegetation sampling in Radiological Environmental Monitoring Program (Attachment 9) shall be followed, including analysis of control samples.

b. Action

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

2. If a land use census identifies locations that yield a calculated dose or dose commitment (via the same exposure pathway) 25 percent greater than at a location from which samples are currently being obtained, add the new locations to the Radiological Environmental Monitoring Program within 30 days. Sampling locations, excluding the control station location, that have the lowest calculated dose or dose commitments (via the same exposure pathway) may be deleted from the monitoring program. Identify new locations in the next Annual Radioactive Effluent Release Report and include in the report revised figures and tables reflecting the new locations in accordance with VP AP-2802, Notifications and Reports. [Reference 3.1.33]

6.6.3 Interlaboratory Comparison Program

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

DOMINION

b. Action VPAP-2103N REVISION25 PAGE 38 OF 87

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

Program Milk Water Air Filter Cross-Check of I 131 Gamma Sr89 and Sr90 Gross Beta, Gamma, 1131, H3 (Tritium), Sr89 and Sr90 (blirtd - any combinations of above radionuclides) Gross Beta, Gamma, Sr90

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

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

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

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

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

DOMINION

VPAP-2103N REVISION25 PAGE 390F 87