Text

2015 Annual Radioactive Effluent Release Report
	ML16133A056
Person / Time
Site:	Catawba
Issue date:	04/28/2016
From:	Henderson K; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16133A060	List: CNS-16-029, Offsite Dose Calculation Manual, Revision 59; ML16133A056;
References
	CNS-16-029
	Download: ML16133A056 (152)
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el_-,DUKE ENERGYai CNS-16-029 April 28, 2016 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 2015 Annual Radioactive Effluent Release Report Kelvin Henderson Vice President Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road York, SC 29745 o: 803.701.4251 f: 803. 701.3221 Pursuant to Catawba Nuclear Station Technical Specification (TS) 5.6.3 and Selected Licensee Commitment 16.11-16, please find attached the Annual Radioactive Effluent Release Report for the period of January 1, 2015, through December 31, i015. In accordance with Catawba TS 5.5.1, the Offsite Dose Calculation Manual (ODCM) is included in this submittal.

Attachment 1 Attachment 2 Attachment 3 Attachment 4 Attachment 5 Attachment 6 Attachment 7 Attachment 8 Attachment 9 Summary of Gaseous and Liquid Effluents Supplemental Information Solid Radioactive Waste Disposal Meteorological Data Unplanned Offsite Releases Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Information to Support the NEI Groundwater Protection Initiative Inoperable Equipment Summary of Changes to the Offsite Dose Calculation Manual United States Nuclear Regulatory Commission Page 2 April 28, 2016 Attachment 10 Summary of Changes to the Process Control Program Attachment 11 Summary of Major Modifications to the Radioactive Waste Treatment

Attachment 12 Errata to a Previous Year's ARERR Enclosed:

2015 Offsite Dose Calculation Manual (Compact Disc) Any questions concerning this report should be directed to Cecil A. Fletcher II, Nuclear Regulatory Affairs Manager, at (803) 701-3622.

Sincerely, Kelvin Henderson Vice President, Catawba Nuclear Station Attachments and Enclosure (Offsite Dose Calculation Manual [ODCM] Compact Disc [CD])

United States Nuclear Regulatory Commission Page 3 April 28, 2016 xc (with attachments and enclosure):

c. Haney Regional Administrator U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303 J.A. Whited NRC Project Manager (CNS) U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-81A 11555 Rockville Pike Rockville, MD 20852 G. A. Hutto, Ill (without enclosure)

NRC Senior Resident Inspector Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 1 Summary of Gaseous and Liquid Effluents This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents as outlined in Regulatory Guide 1.21, Appendix B. Page 1-1

-

Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Summation of All Releases Units A. Fission and Activation Gases Qtr 1 Qtr 2 Qtr 3 Qtr4 Year 1. Total Release Ci 5.0BE+OO 4.33E+OO 3.36E+OO 2.56E+01 3.84E+01 2. Avg. Release Rate µCi/sec 6.53E-01 5.51 E-01 4.22E-01 3.23E+OO 1.22E+OO B. lodine-131

1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO 5.56E-05 5.56E-05 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO 6.99E-06 1.76E-06 C. Particulates Half-Life

8 days 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium 1. Total Release Ci 5.49E+01 4.62E+01 4.31E+01 7.27E+01 2.17E+02

2. Avg. Release Rate µCi/sec 7.07E+OO 5.88E+OO 5.42E+OO 9.15E+OO 6.88E+OO E. Carbon-14

1. Total Release Ci 4.44E+OO 5.25E+OO 5.41E+OO 4.64E+OO 1.97E+01 2. Avg. Release Rate µCi/sec 5.71 E-01 6.67E-01 6.BOE-01 5.83E-01 6.26E-01 F. Gross Alpha 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 1-2 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Elevated Releases -Continuous Mode

Units Qtr 1 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life;::

8 days N/A Ci Total for Period Ci o. Tritium N/A Ci E. Carbon-14 NIA Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have elevated releases.

Page 1-3 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Elevated Releases -Batch Mode

Units Qtr 1 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life

<::: 8 days N/A Ci Total for Period Ci D. Tritium N/A Ci E. Carbon-14 N/A Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have elevated releases.

Page 1-4 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Ground Releases -Continuous Mode Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Gases None Ci Total for Period Ci O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO B. Iodines 1-131 Ci O.OOE+OO O.OOE+OO O.OOE+OO 5.56E-05 5.56E-05 1-133 Ci O.OOE+OO O.OOE+OO 0.00E+OO 4.57E-05 4.57E-05 Total for Period Ci O.OOE+OO O.OOE+OO 0.00E+OO 1.01 E-04 1.01 E-04 C. Particulates Half-Life

8 days None Ci Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium H-3 Ci 5.48E+01 4.61E+01 4.29E+0.1 7.25E+01 2.16E+02 E. Carbon-14

C-14 Ci 1.33E+OO 1.58E+OO 1.62E+OO 1.39E+OO 5.91E+OO F. Gross Alpha Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

30% of total C-14 released is assumed to be in continuous mode. See Attachment 2, Supplemental Information, of this report. Page 1-5 Attachment 1 Sum_mary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Ground Releases -Batch Mode Units Qtr 1 Qtr2 Qtr 3 Qtr4 Year A Fission and Activation Gases AR-41 Ci 7.76E-01 7.09E-01 8.17E-01 8.15E-01 3.12E+OO KR-85 Ci 0.00E+OO O.OOE+OO O.OOE+OO 5.38E-01 5.38E-01 XE-131M Ci 6.49E-02 6.14E-04 O.OOE+OO 2.50E-01 3.16E-01 XE-133 Ci 4.22E+OO 3.62E+OO 2.53E+OO 2.38E+01 3.42E+01 XE-133M Ci 2.72E-03 0.00E+OO O.OOE+OO 1.93E-01 1.95E-01 XE-135 Ci 1.32E-02 3.73E-03 6.85E-03 5.66E-02 8.04E-02 Total for Period Ci 5.08E+OO 4.33E+OO 3.36E+OO 2.56E+01 3.84E+01 r* B. Iodines None Ci Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO C. Particulates Half-Life

8 days None Ci Total for Period Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium H-3 Ci 1.14E-01 1.48E-01 1.83E-01 1.89E-01 6.34E-01 E. Carbon-14

C-14 Ci 3.11E+OO 3.68E+OO 3.79E+OO 3.25E+OO 1.38E+01 F. Gross Alpha Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

70% of total C-14 released is assumed to be in batch mode. See Attachment 2, Supplemental Information, of this report. Page 1-6 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Mixed-Mode Releases -Continuous Mode

Units Qtr 1 Qtr 2 Qtr 3 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life

8 days NIA Ci Total for Period Ci D. Tritium NIA Ci E. Carbon-14 N/A Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have mixed-mode releases.

Page 1-7 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Mixed-Mode Releases -Batch Mode

Units Qtr 1 Qtr 2 Qtr 3 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life;::::

8 days N/A Ci Total for Period Ci D. Tritium N/A Ci E. Carbon-14 NIA Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have mixed-mode releases.

Page 1-8 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents

-Summation of All Releases Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Products

1. Total Release Ci 6.BOE-03 8.96E-03 7.34E-03 2.86E-03 2.60E-02 2. Avg. Diluted Cone. µCi/ml 2.47E-10 3.62E-10 2.31E-10 1.06E-10 2.33E-10 3. Batch Releases µCi/ml 2.47E-10 3.62E-10 2.31E-10 1.06E-10 2.33E-10 8. Tritium 1. Total Release Ci 1.66E+02 9.44E+01 1.55E+02 1.85E+02 6.00E+02 2. Avg. Diluted Cone. µCi/ml 6.00E-06 3.81E-06 4.BBE-06 6.85E-06 5.40E-06 3. Batch Releases µCi/ml 6.00E-06 3.81E-06 4.BBE-06 6.85E-06 5.40E-06 C. Dissolved

& Entrained Gases 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO 1.54E-06 1.54E-06 2. Avg. Diluted Cone. µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO 5.68E-14 1.38E-14 3. Batch Releases µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO 5.68E-14 1.38E-14 D. Gross Alpha 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Diluted Cone. µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 3. Batch Releases µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO E. Volume of Liquid Waste 1. Continuous Releases liters O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Batch Releases liters 9.22E+05 5.04E+05 7.88E+05 9.70E+05 3.18E+06 F. Volume of Dilution Water 1. Continuous Releases liters 2.76E+09 2.48E+09 3.18E+09 2.71 E+09 1.11E+10 2. Batch Releases liters 2.76E+10 2.48E+10 3.18E+10 2.71E+10 1.11E+11

Excludes tritium, dissolved and entrained noble gases, and gross alpha. Page 1-9 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents

-Continuous Mode Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Products None Ci Total for Period Ci 0.00+00 0.00+00 0.00+00 0.00+00 0.00+00 8. Tritium H-3 Ci 0.00+00 0.00+00 0.00+00 0.00+00 0.00+00 C. Dissolved

& Entrained Gases None Ci Total for Period Ci 0.00+00 0.00+00 0.00+00 0.00+00 0.00+00 D. Gross Alpha Total for Period Ci 0.00+00 0.00+00 0.00+00 0.00+00 0.00+00 Page 1-10 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents

-Batch Mode Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Products BE-7 Ci 6.63E-06 O.OOE+OO O.OOE+OO O.OOE+OO 6.63E-06 81-214 Ci O.OOE+OO 1.00E-06 O.OOE+OO O.OOE+OO 1.00E-06 C0-57 Ci 6.56E-06 1.46E-05 5.61E-06 O.OOE+OO 2.68E-05 C0-58 Ci 2.44E-04 4.54E-03 2.49E-03 1.22E-03 8.49E-03 C0-60 Ci 1.90E-03 1.04E-03 1.69E-03 1.17E-03 5.79E-03 CS-137 Ci 5.09E-06 4.23E-06 9.55E-06 1.38E-05 3.27E-05 FE-55 Ci 2.01E-03 1.36E-03 1.25E-03 O.OOE+OO 4.62E-03 FE-59 Ci 1.86E-06 O.OOE+OO O.OOE+OO O.OOE+OO 1.86E-06 1-131 Ci O.OOE+OO O.OOE+OO O.OOE+OO 2.73E-06 2.73E-06 K-40 Ci 5.03E-06 O.OOE+OO O.OOE+OO O.OOE+OO 5.03E-06 MN-54 Ci 9.12E-05 7.95E-06 4.05E-05 6.57E-07 1.40E-04 Nl-63 Ci 2.34E-03 1.78E-03 1.50E-03 O.OOE+OO 5.62E-03 PB-214 Ci 1.55E-06 O.OOE+OO O.OOE+OO O.OOE+OO 1.55E-06 SB-124 Ci O.OOE+OO O.OOE+OO O.OOE+OO 3.80E-05 3.80E-05 SB-125 Ci 1.93E-04 1.86E-04 3.48E-04 4.19E-04 1.15E-03 ZN-65 Ci O.OOE+OO 1.87E-05 9.92E-06 O.OOE+OO 2.87E-05 Total for Period Ci 6.80E-03 8.96E-03 7.34E-03 2.86E-03 2.60E-02 B. Tritium H-3 Ci 1.66E+02 9.44E+01 1.55E+02 1.85E+02 6.00E+02 C. Dissolved

& Entrained Gases X-133 Ci 0.00E+OO O.OOE+OO O.OOE+OO 1.54E-06 1.54E-06 Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO 1.54E-06 1.54E-06 D. Gross Alpha Total for Period Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 1-11 Attachment 2 Supplemental Information Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 ATTACHMENT 2 Supplemental Information This attachment includes supplemental information to the gaseous and liquid effluents report. Page 2-1 Attachment 2 Supplemental Information Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 I. Regulato!:Jl Limits -Per Unit A. Noble Gases -Air Dose 1. Calendar Quarter Gamma Dose =5 mRAD 2. Calendar Quarter Beta Dose = 10 mRAD 3. Calendar Year Gamma Dose = 10 mRAD 4. Calendar Year Beta Dose = 20 mRAD 8. Liquid Effluents

-Dose 1. Calendar Quarter Total Body Dose = 1.5 mREM 2. Calendar Quarter Organ Dose =5 mREM 3. Calendar Year Total Body Dose =3 mREM 4. Calendar Year Organ Dose = 10 mREM C. Gaseous Effluents

-lodine-131

& 133, Tritium, and Particulates with Half-lives>

8 days 1. Calendar Quarter Organ Dose = 7.5 mREM 2. Calendar Year Organ Dose = 15 mREM II. Maximum Permissible Effluent Concentrations A. Gaseous Effluents

1. Information found in Offsite Dose Calculation Manual 8. Liquid Effluents

1. Information found in 1 O CFR Part 20, Appendix B, Table 2, Column 2 Ill. Average Energy (not applicable)

IV. Measurements and Approximations of Total Radioactivity Analyses of specific radionuclides in selected or composited samples as described in the Selected Licensee Commitments are used to determine the radionuclide composition of the effluent.

A summary description of the method used for estimating overall errors associated with radioactivity measurements is provided as part of this attachment.

V. Batch Releases A. Liquid Effluents

1. Total Number of Batch Releases 2. Total Time (min) for Batch Releases 3. Maximum Time (min) for a Batch Release 4. Average Time (min) for Batch Releases 5. Minimum Time (min) for a Batch Release 6. Average Dilution Water Flow During Release (gpm) 8. Gaseous Effluents

1. Total Number ofBatch Releases 2. Total Time (min) for Batch Releases 3. Maximum Time (min) for a Batch Release 4. Average Time (min) for Batch Releases 5. Minimum Time (min) for a Batch Release VI. Abnormal Releases See Attachment 5, Unplanned Offsite Releases.

7.40E+01 4.53E+03 1.14E+02 6.13E+01 3.00E+01 5.58E+04 6.40E+01 1.03E+06 4.49E+04 1.61E+04 8.00E+OO Page 2-2 Attachment 2 Supplemental Information Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Carbon-14 Carbon-14 (C-14), with a half-life of 5730 years, is a naturally occurring isotope of carbon produced by cosmic ray interactions in the atmosphere.

Nuclear weapons testing in the 1950s and 1960s significantly increased the amount of C-14 in the atmosphere.

C-14 is also produced in commercial nuclear reactors, but the amounts produced are much less than those produced naturally or from weapons testing. In Regulatory Guide 1.21, Revision 2, "Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste", the NRC recommends U.S. nuclear power plants evaluate whether C-14 is a "principal radionuclide", and if so, report the amount of C-14 released.

Improvements over the years in effluent management practices and fuel performance have resulted in a decrease in gaseous radionuclide (non-C-14) concentrations, and a change in the distribution of gaseous radionuclides released to the environment.

As a result, many sites show C-14 has become a "principal radionuclide" for the gaseous effluent pathway,.

as defined in Regulatory Guide 1.21, Rev. 2. Catawba Nuclear Station 2015 ARERR contains estimates of C-14 radioactivity released in 2015, and estimates of pub-lie dose resulting from the C-14 effluent.

Because the dose contribution of C-14 from liquid radioactive waste is much less than that contributed by gaseous radioactive waste, evaluation of C-14 in liquid radioactive waste is not required (Ref. Reg. Guide 1.21, Rev. 2). The quantity of gaseous C-14 released to the environment can be estimated by use of a C-14 source term scaling factor based on power generation (Ref. Reg. Guide 1.21, Rev. 2). Many documents provide information related to the magnitude of C-14 in typical effluents from commercial nuclear power plants. Those documents suggest that nominal annual releases of C-14 in gaseous effluents are approximately 5 to 7.3 curies from PWRs (Ref. Reg. Guide 1.21, Rev. 2). A more recent study recommends a higher C-14 source term scaling factor of approximately 9.0 to 9.8 Ci/GWe-yr for a PWR (Westinghouse) (Ref. EPRI 1021106).

For the Catawba Nuclear Station 2015 ARERR a source term scaling factor of 9.4 Ci/GWe-yr is assumed. Using a source term scaling factor of 9.4 Ci/GWe-yr and actual electric generation (MWe-hrs) from Catawba Nuclear Station in 2015 results in a site total C-14 gaseous release estimate to the environment of 19.73 Curies. 70% of the C-14 gaseous effluent is assumed to be from batch releases (e.g. WGDTs), and 30% of C-14 gaseous effluent is assumed to be from continuous releases through the unit vents (ref. IAEA Technical Reports Series no. 421, "Management of Waste Containing Tritium and Carbon-14", 2004). C-14 releases in PWRs occur primarily as a mix of organic carbon and carbon dioxide released from the waste gas system. Since the PWR operates with a reducing chemistry, most, if not all, of the C-14 species initially produced are organic (e.g., methane).

As a general rule, C-14 in the primary coolant is essentially all organic with a large fraction as a gaseous species. Any time the RCS liquid 9r gas is exposed to an oxidizing environment (e.g. during shutdown or refueling), a slow transformation from an organic to an inorganic chemical form can occur. Various studies documenting measured C-14 releases from PWRs suggest a range of 70% to 95% organic with an average of 80% organic with the remainder being C0 2 (Ref. EPRI TR-105715).

For the Catawba Nuclear Station 2015 ARERR a value of 80% organic C-14 is

Public dose estimates from airborne C-14 are performed using dose models in NUREG-0133 and Regulatory Guide 1.109. The dose models and assumptions used are documented in the Catawba ODCM. The estimated C-14 dose impact on the maximum organ dose from airborne effluents released from Catawba Nuclear Station in 2015 is well below the 1 OCFR50, Appendix I, ALARA design objective (i.e., 15 mrem/yr per unit). Page 2-3 Attachment 2 *Supplemental Information Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Overall Estimate of Error for Effluent Radioactivity Release Reported The estimated percentage of overall error for both Liquid and Gaseous effluent release data at Catawba Nuclear Station has been determined to be +/- 30.3%. This value was derived by taking the square root of the sum of the squares of the following discrete individual estimates of error: 1. Flow Rate Determining Devices = +/-20% 2. Counting Statistical Error = +/-20% 3. Calibration Error = +/-10% 4. Calibration Source Error = +/-2.5% 5. Sample Preparation Error = +/-3% Page 2-4 Attachment 2 Supplemental Information Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Summary of Changes in Land Use Census Affecting Effluent Dose Calculations The 2015 Land Use Census was performed July 8-9, 2015, and the results were certified and made available for use on July 16, 2015. The following are changes to residences, gardens, and milk animals from the previous year. Residences The residence in the NW sector at 1.39 miles was replaced by a nearer residence at 1.27 miles. Gardens The non-irrigated garden in the N sector at 1.55 miles was replaced by a non-irrigated garden at 1.38 miles. The non-irrigated garden in the NNE sector at 4.47 miles was replaced by a non-irrigated garden at 0.69 miles. The non-irrigated garden in the NE sector at 0.68 miles was replaced by a non-irrigated garden at 2.39 miles. The non-irrigated garden in the ENE sector at 2.73 miles was replaced by an irrigated garden at 1.44 miles. The non-irrigated garden in the E sector at 3.52 miles was replaced by an irrigated garden at 2.26 miles. The non-irrigated garden in the ESE sector at 3.70 miles was replaced by a non-irrigated garden at 1.29 miles. The irrigated garden in the SE sector at 2.55 miles was replaced by an irrigated garden at 1.50 miles. The non-irrigated garden in the SSW sector at 1.34 miles was replaced by a non-irrigated garden at 0.89 miles. The non-irrigated garden in the SW sector at 2.02 miles was replaced by an irrigated garden at 0.78 miles. The non-irrigated garden in the WSW sector at 2.03 miles was replaced by a non-irrigated garden at 1.98 miles. The non-irrigated garden in the NNW sector at 2.13 miles was replaced by a non-irrigated garden at 1.19 miles. Milk Animals No changes to nearest milk animal in each sector. Environmental Monitoring Locations No changes to environmental monitoring locations in each sector. Page 2-5 Attachment 3 Solid Radioactive Waste Disposal Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 3 Solid Radioactive Waste Disposal This attachment includes a summary of the solid waste shipped off-site for burial and/or disposal, including:

Container volume

Total Curie content

Principal Radionuclides

Source/Type of waste

Solidification agent or absorbent

Type of shipping container

Number of shipments

Other relevant information as necessary Page 3-1 Attachment 3 Solid Radioactive Waste Disposal Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Type of Number of Number of Waste Container Solidification Burial Total Volume Activity Waste Shipped Shipments Containers Class Type Agent (m3) (Curies) 1. Waste from Liguid SJlstems a. Dewatered Secondary Resins b. Dewatered Primary Resins 2 2 1 B 2 HIC NA 9.24 83.960 1AS c. Evaporator Concentrates

d. Dewatered Mechanical Filters e. Dewatered Demineralizers

f. Solidified (cement) Acids, Oils, Sludge 2. Dry Solid Waste a. Dry Active Waste (compacted)

b. Dry Active Waste (non-compacted)

c. Dry Active Waste (brokered) 25 46 A GDP NA 468.02 0.731 d. Irradiated Components

3. Total Solid Waste 27 48 477.25 84.697 Page 3-2 Attachment 3 Solid Radioactive Waste Disposal Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Type of Waste Shipped Radionuclide

1. Waste from Liquid Systems a. Dewatered Secondary Resins NIA b. Dewatered Primary Resins H-3 Mn-54 Co-57 Co-58 Co-60 Zn-65 Sb-125 Ba-133 Cs-137 Ce-144 C-14 Fe-55 Ni-59 Ni-63 c. Evaporator Concentrates NIA d. Dewatered Mechanical Filters NIA e. Dewatered Demineralizers NIA f. Solidified (cement) Acids, Oils, Sludge NIA 2. Dry Solid Waste a. Dry Active Waste (compacted)

NIA b. Dry Active Waste (non-compacted)

NIA c. Dry Active Waste (brokered)

Cr-51 Mn-54 Co-57 Co-58 Fe-59 Co-60 Zn-65 Nb-95 Zr-95 Sn-113 Sb-125 Cs-137 Ce-144 C-14 Fe-55 Ni-63 d. Irradiated Components NIA % Abundance NIA 0.02% 2.16% 0.07% 0.46% 16.97% 0.35% 0.30% 0.01% 0.13% 0.02% 0.07% 15.86% 0.46% 63.13% NIA NIA NIA NIA NIA NIA 0.19% 5.32% 0.16% 12.05% 0.07% 25.81% 0.43% 1.68% 1.66% 0.14%

1.26% 0.06% 0.14% 0.54% 43.57% 6.92% NIA Page 3-3 Attachment 4 Meteorological Data Catawba Nuclear Station Units 1 & 2 Period 111/2015 -12/31/2015 ATTACHMENT 4 Meteorological Data This attachment includes a summary of meteorological joint frequency distributions of wind speed, wind direction, and atmospheric stability (hours of occurrence).

Page 4-1 Stability Wind Class Speed (mph) N NNE NE 0.46-0.75 0 0 0 0.76-1.00 0 0 0 1.01-1.25 0 0 0 1.26-1.50 0 0 0 1.51-2.00 0 0 0 2.01-3.00 0 0 2 A 3.01-4.00 14 5 1 4.01-5.00 9 19 11 5.01-6.00 6 20 5 6.01-8.00 1 5 1 8.01-10.00 1 1 0 10.01-max 0 0 0 0.46-0.75 0 0 0 0.76-1.00 0 0 0 1.01-1.25 0 0 0 1.26-1.50 0 0 0 1.51-2.00 1 0 0 2.01-3.00 3 2 1 B 3.01-4.00 15 14 3 4.01-5.00 30 27 10 5.01-6.00 4 13 5 6.01-8.00 2 2 1 8.01-10.00 0 0 0 10.01-max 0 0 0 Attachment 4 Meteorological Data Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Hours of Occurrence Sector ENE E ESE SE SSE s SSW 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 2 1 1 1 0 0 1 8 47 26 75 0 0 1 3 4 8 35 0 0 0 0 0 0 13 0 0 0 0 0 0 3 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 3 4 6 3 10 1 3 2 7 40 24 43 1 0 0 3 4 1 7 1 0 0 1 0 0 5 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 SW WSW w WNW NW NNW 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 5 1 0 0 0 81 27 14 3 1 0 39 8 6 4 6 1 7 1 0 2 6 10 0 0 0 1 3 6 0 0 0 1 0 8 0 0 0 0 0 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 7 11 4 0 1 0 37 6 12 6 4 3 8 1 3 6 7 8 1 2 1 3 0 4 0 1 0 1 2 3 0 0 0 0 1 6 0 0 0 1 0 1 0 0 0 0 0 0 Page 4-2 Stability Wind Class Speed (mph) N NNE NE 0.46-0.75 0 0 0 0.76-1.00 0 0 0 1.01-1.25 0 0 0 1.26-1.50 0 0 1 1.51-2.00 7 2 2 2.01-3.00 20 13 8 c 3.01-4.00 48 27 9 4.01-5.00 20 41 16 5.01-6.00 7 19 9 6.01-8.00 0 9 5 8.01-10.00 0 1 0 10.01-max 0 0 0 0.46-0.75 0 0 0 0.76-1.00 1 2 0 1.01-1.25 5 2 2 1.26-1.50 8 9 1 1.51-2.00 31 5 11 D 2.01-3.00 168 83 21 3.01-4.00 223 133 69 4.01-5.00 131 161 54 5.01-6.00 33 78 20 6.01-8.00 4 29 6 8.01-10.00 1 2 0 10.01-max 0 0 0 Attachment 4 Meteorological Data Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Hours of Occurrence Sector ENE E ESE SE SSE s SSW 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 2 3 1 5 5 13 17 15 24 4 6 3 7 21 30 42 0 0 1 2 1 3 8 1 0 0 1 1 0 7 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 0 0 2 0 1 0 2 5 9 15 0 0 3 9 11 14 20 3 4 8 14 23 42 49 13 9 6 11 13 40 4_ 126 16 14 9 15 63 97 89 16 6 2 10 11 37 34 9 0 0 2 1 5 5 1 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o* SW WSW w WNW NW NNW 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 1 1 2 0 0 19 10 7 2 2 5 34 15 10 5 5 10 6 5 1 4 5 9 5 0 0 1 2 4 0 0 0 1 3 0 0 0 0 1 0 2 0 0 0 0 0 1 0 0 0 0 0 0 1 1 2 0 0 0 6 14 6 6 3 1 19 15 11 8 9 3 46 24 31 11 9 18 .75 27 24 .33 16 32 72 17 18 16 36 81 14 1 3 5 20 33 5 2 1 6 13 14 0 0 1 2 6 12 0 0 0 1 3 12 0 0 0 0 0 2 0 0 0 0 0 0 Page 4-3 Stability Wind speed Class (mph) N NNE NE 0.46-0.75 1 0 0 0.76-1.00 1 0 0 1.01-1.25 1 0 0 1.26-1.50 0 1 0 1.51-2.00 16 5 1 2.01-3.00 71 7 4 E 3.01-4.00 38 7 5 4.01-5.00 16 15 13 5.01-6.00 3 5 6 6.01-8.00 0 0 0 8.01-10.00 0 0 0 10.01-max 0 0 0 0.46-0.75 0 0 0 0.76-1.00 1 1 0 1.01-1.25 1 0 0 1.26-1.50 1 0 0 1.51-2.00 11 0 1 2.01-3.00 44 0 0 F 3.01-4.00 5 0 0 4.01-5.00 0 0 0 5.01-6.00 0 0 0 6.01-8.00 0 0 0 8.01-10.00 0 0 0 10.01-max 0 0 0 Attachment 4 Meteorological Data Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Hours of Occurrence Sector ENE E ESE SE SSE s SSW 0 1 1 0 2 4 7 0 0 0 3 11 19 31 0 2 2 2 8 38 60 0 0 5 7 13 89 85 3 2 3 19 51 129 116 3 6 11 24 58 107 68 1 4 3 15 16 18 28 4 0 1 3 2 7 0 0 0 0 0 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 6 4 0 0 0 1 5 18 24 0 0 0 3 2 32 38 0 0 0 1 8 44 23 0 0 0 1 5 15 10 0 0 0 4 6 1 0 0 0 0 1 2 0 1 0 0 1 0 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 s WSW w WNW NW NNW w 10 1 6 2 0 2 40 21 19 5 10 4 53 31 28 17 23 11 61 14 21 17 26 20 41 19 20 26 35 54 15 7 7 13 56 68 3 1 1 0 6 14 0 0 0 0 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 4 10 2 2 0 30 17 11 11 9 3 24 19 15 6 20 3 15 17 10 16 25 11 10 10 21 19 18 38 3 1 2 6 11 77 1 0 0 1 0 2 ! 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Page 4-4 Wind Stability Speed Class (mph) N NNE NE 0.46-0.75 0 0 0 0.76-1.00 0 0 0 1.01-1.25 0 0 0 1.26-1.50 0 0 0 1.51-2.00 6 0 0 2.01-3.00 11 0 0 G 3.01-4.00 5 0 0 4.01-5.00 0 0 0 5.01-6.00 0 0 0 6.01-8.00 0 0 0 8.01-10.00 0 0 0 10.01-max 0 0 0 Attachment 4 Meteorological Data Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Hours of Occurrence Sector ENE E ESE SE SSE s SSW 0 0 0 0 0 7 6 0 0 0 0 1 18 15 0 0 0 0 2 30 18 0 0 0 0 6 21 25 0 0 0 0 3 7 3 0 0 0 0 3 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 SW WSW w WNW NW NNW 19 10 14 9 6 0 19 29 25 19 14 4 15 10 18 16 10 10 18 7 14 6 13 25 4 11 11 8 11 43 1 0 1 2 1 17 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Page 4-5 Attachment 5 Unplanned Offsite Releases Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 5 Unplanned Offsite Releases This attachment includes a summary of the unplanned offsite releases of gaseous and liquid radioactive effluents.

Page 5-1 Attachment 5 Unplanned Offsite Releases Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Catawba Nuclear Station had no unplanned liquid releases in 2015. Catawba Nuclear Station had four (4) unplanned gaseous releases in 2015. Summaries below include:

Detailed description of event.

Total Curies released.

Anticipated dose consequences.

In November 2014, a fuel defect was identified in the Unit 1 reactor at CNS. The fuel defect resulted in higher than normal noble gas inventory (e.g. Xe-133, Xe-135, etc.) in the reactor coolant system. All four unplanned releases occurred during activities that interfaced with the Unit 1 reactor coolant system. NCR 01945823 The first unplanned release occurred on August 20, 2015 when Unit 1 was online at full power (Mode 1). During sampling of the Unit 1 pressurizer in the nuclear sampling lab, a Trip 2 alarm (high radiation alarm) was received on the auxiliary building noble gas monitor accompanied by a Trip 1 alarm on the Unit 1 vent noble gas monitor. The fume hood exhaust fan in the sampling hood was inoperable during the sampling, which enabled buildup of noble gas concentrations in the lab and the auxiliary building.

NCR 01977533 and NCR 01977538 The second and third unplanned releases occurred on November 21, 2015 when Unit 1 was shut down and in cold shutdown (Mode 5) at the -beginning of refueling outage 1 EOC22. In both cases, Unit 1 pressurizer sampling was in progress and Trip 2 alarms were received on the Unit 1 vent noble gas monitor, but there were no alarms on the auxiliary building noble gas monitor. The auxiliary building noble gas monitor samples from 12 different sampling locations within the auxiliary building in sequence, and it was not sampling the point(s) within the vicinity of the sampling lab when these releases occurred.

-NCR 01978081 The fourth release occurred on November 23, 2015 when Unit 1 was in Mode 5 during 1 EOC22. This release was initiated inside the Unit 1 containment building when opening 1" reactor head motor operated vent valves. The Unit 1 vent nobl_e gas _monitor received a Trip 2 alarm. The Unit 1 containment noble gas monitor indicated an elevated count rate but did not exceed its alarm set-points.

Table 5-1. Unplanned release data Start End Reactor Total Activity a Projected Dose Date/Time Date/Time Mode (Xe-133 GammaAir Beta Air Max Organ ° -Equivalent, Ci) (mrad) (mrad) (mrem) 08/20/15 07:41 08/20/15 07:49 1 1.29E-01 5.05E-05 1.50E-04 0 11/21/1511:06 11/21/1511:31 5 1.85E+OO 7.25E-04 2.16E-03 0 11/21/1514:48 11/21/15 16:37 5 2.78E+OO 1.09E-03 3.25E-03 0 11/23/15 16:13 11/23/15 19:37 5 4.77E+OO 1.87E-03 5.58E-03 0 Total 9.53E+OO 3.74E-03 1.11E-02 0 a. All unplanned releases were quantified using the monitor readings on the Unit 1 noble gas monitor (1 EMF36) and the monitor's correlation factor to determine a Xe-133 equivalent activity.

This methodology is consistent with the ODCM. b. There are no inhalation/ingestion dose pathways for radioactive noble gases, therefore the Max Organ dose is 0 mrem for each unplanned release. Page 5-2 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public (includes fuel cycle dose calculation results) This attachment includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site for each calendar quarter for the calendar year of the report as well as the total dose for the calendar year. This attachment also includes an assessment of radiation doses to the. maximum exposed member of the public from all uranium fuel cycle sources within 8 km of the site for the calendar year of this report to show conformance with 40 CFR Part 190. Methods for calculating the dose contribution from liquid and gaseous effluents are given in the Offsite Dose Calculation Manual (ODCM). Page 6-1 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents Dose Summary Units A. Noble Gases 1. Maximum Gamma Air mRAD (a) Limit mRAD (b) % of Limit 2. Maximum Beta Air mRAD (a) Limit mRAD (b) % of Limit Receptor Location 0.5 miles NNE B. Iodine, H-3, & Particulates

1. Maximum Organ Dose (a) Limit (b) % of Limit mREM mREM Receptor Location 0.5 miles NNE Critical Age CHILD Critical Organ BONE Critical Pathway VEGETATION Qtr 1 9.73E-03 1.00E+01 9.73E-02 7.89E-03 2.00E+01 3.94E-02 1.25E+OO 1.50E+01 8.33E+OO Qtr2 8.76E-03 1.00E+01 8.76E-02 6.82E-03 2.00E+01 3.41E-02 1.48E+OO 1.50E+01 9.84E+OO Qtr 3 9.46E-03 1.00E+01 9.46E-02 5.96E-03 2.00E+01 2.98E-02 1.52E+OO 1.50E+01 1.01 E+01 Qtr4 1.80E-02 1.00E+01 1.80E-01 3.27E-02 2.00E+01 1.64E-01 1.30E+OO 1.50E+01 8.70E+OO Year 4.60E-02 2.00E+01 2.30E-01 5.34E-02 4.00E+01 1.33E-01 5.55E+OO 3.00E+01 1.85E+01 Page 6-2 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public

Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents Dose Summary Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A Batch Mode 1. Maximum Organ Dose mREM 1.81 E-02 1.19E-02 1.51 E-02 2.08E-02 6.61E-01 (a) Limit mREM 1.00E+01 1.00E+01 1.00E+01 1.00E+01 2.00E+01 (b) % of Limit 1.81 E-01 1.19E-01 1.51 E-01 2.08E-01 3.31 E-01 2: Maximum Total Body Dose mREM 1.78E-02 1.17E-02 1.48E-02 2.03E-02 6.48E-02 (a) Limit mREM 3.00E+OO 3.00E+OO 3.00E+OO 3.00E+OO 6.00E+OO (b) % of Limit 5.94E-01 3.89E-01 4.93E-01 6.78E-01 1.08E+OO Critical Age CHILD Critical Organ LIVER Critical Pathway POTABLE WATER B. Continuous Mode 1. Maximum Organ Dose mREM O.OOE-00 O.OOE-00 O.OOE-00 O,OOE-00 O.OOE-00 (a) Limit mREM 1.00E+01 1.00E+01 1.00E+01 1.00E+01 2.00E+01 (b) % of Limit O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 2. Maximum Total Body Dose mREM O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 (a) Limit mREM 3.00E+OO 3.00E+OO 3.00E+OO 3.00E+OO 6.00E+OO (b) % of Limit O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 O.OOE-00 Critical Age NIA Critical Organ NIA Critical Pathway NIA Page 6-3 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 40 CFR Part 190 Uranium Fuel Cycle Dose Calculation Results In accordance with the requirements of 40 CFR Part 190, the annual dose commitment to any member of the general public shall be calculated to assure that doses are limited to 25 millirems to the total body or any organ with the exception of the thyroid which is limited to 75 millirems.

The fuel cycle dose assessment for Catawba Nuclear Station includes liquid and gaseous effluent dose contributions from Catawba Nuclear Station and direct and air-scatter dose from the onsite ISFSI. No other uranium fuel cycle facility contributes significantly to the maximum exposed individual.

Included in the gaseous effluent dose calculations is an estimate of the dose contributed by Carbon-14 (Ref. Attachment 2, Supplemental Information, of this report for further information).

The combined dose to a maximum exposed individual from effluent.

releases and direct and air-scatter dose from the ISFSI is below 40 CFR Part 190 limits as shown by the following summary. Note: The 40 CFR Part 190 effluent dose analysis to the maximum exposed individual from liquid and gas releases includes the dose from noble gases (i.e., total body and skin). 40 CFR Part 190 Effluent Dose Summary A. Maximum Organ Dose (other than TB) 1. Location 2. Critical Age 3. Critical Organ 4. Gas Contribution

% 5. Liquid Contribution

% B. Maximum Total Body Dose 1. Location 2. Critical Age 3. Gas non-NG Contribution

% 4. Gas Contribution

% 5. Liquid Contribution%

5.57E+OO mREM 0.5 miles NNE CHILD BONE 99.60% 0.40% 2.45E+OO mREM 0.5 miles NNE CHILD 95.63% 1.72% 2.65% Direct and air-scatter radiation dose contributions from the onsite ISFSI have been determined from the 10 CFR 72.212 Evaluation Report, MAGNASTOR, Revision 0. The maximum dose rate to the nearest real individual from the ISFSI is conservatively calculated to be less than 14.7 mrem/yr. The attached excerpt from the 10 CFR 72.212 Evaluation Report, MAGNASTOR, Revision 0 is provided to document the method used to calculate the dose from ISFSI as less than 14. 7 mrem/yr to the nearest real individual.

Total dose from liquid and gaseous effluents from Catawba Nuclear Station and direct and air-scatter dose from the onsite ISFSI is conservatively estimated to be less than 21 mrem/yr to the nearest real individual.

This meets the 40 CFR Part 190 requirements of an annual dose commitment to any member of the general public of less than 25 mrem total body or any organ and 75 mrem to the thyroid. Page 6-4 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 10 CFR 72.212 Evaluation Report, MAGNASTOR, Revision 0 6.0 10 CFR 72.212(b)(5)(iii)-

Radioactive Materials in Effluents and Direct Radiation

6.1 Purpose

10 CFR 72.212(b)(5)(iii) requires the general licensee to perform written evaluations, before use and before applying the changes authorized by an amended CoC to a cask loaded under the initial Coe or an earlier amended CoC, that establish that the requirements of 10 CFR 72.104 have been met. A copy of this record shall be retained until spent fuel is no longer stored under the general license issued under 10 CFR 72.210. 10 CFR 72.104 provides the regulatory criteria for radioactive materials in effluents and direct radiation from an ISFSI during normal operation and anticipated occurrences.

Specifically, 10 CFR 72.104(a) limits the annual dose equivalent to any real individual who is located beyond the controlled area to 25 mrem to the whole body, 75 mrem to the thyroid, and 25 mrem to any other critical organ. This dose equivalent must include contributions from (1) planned discharges of radioactive materials (radon and its decay products excepted) to the general environment, (2) direct radiation from ISFSI operations, and (3) any other radiation from uranium fuel cycle operations within the region. In addition, 10 CFR 72.104(b) requires that operational restrictions be established to meet As Low As is Reasonably Achievable (ALARA) objectives for radioactive materials in effluents and direct radiation levels associated with ISFSI operations.

Also, 10 CFR 72.104( c) requires that operational limits be established for radioactive materials in effluents and direct radiation levels associated with ISFSI operations to meet the above-mentioned dose limits. This section provides the written evaluation required by 10 CFR 72.212(b)(5)(iii), demonstrating Duke Energy's compliance with the requirements of 10 CFR 72.104 for the CNS ISFSI. 6.2 Evaluation This evaluation addresses the radiological dose rate from a composite population of all CNS ISFSI cask types. 6.2.1 §72.104(a)

-Dose Limits Duke Energy Calculation DPC-1229.00-00-0011, "Distance Measurements from ISFSI to Nearest Residents" determined that the nearest residence to the ISFSI is 0.35 miles (563.27 meters). Calculation CNC-1229.00-00-0061, "UMS Cask Array Dose Analysis for Duke Catawba (NAG International Calculation 12418-5004, Revision 1 )" determined the annual total dose (gamma plus neutron) at a distance of 495 meters from a 2x12 array of NAC-UMS casks to be approximately 6.7 mrem. The evaluation was conservatively based on full cask loads of 24 bounding fuel assemblies (52,000 MWD/MTU; 3.45 wt% U-235, and 8 years cooling) as well as bounding activated components.

The cask decay heat load was conservatively assumed to be 20 kW. The distance at which this dose was calculated (495 meters) is conservative compared to the distance to the closest real individual.

C_cilculation CNC-122Q.00-:00-0067, "MAGNASTOR Cask Array Dose Analysis for Duke Catawba" determined the annual total dose (gam_ma plus neutron) at a distance of 535 meters from a (future) 2x12 array of MAGNASTOR casks to be approximately 7.97 mrem. The evaluation was conservatively based on full cask loads of 37 bounding fuel assemblies at a decay heat .load of 35.5 kW. The distance at which* this* dose is *calculated (535 meters) is conservative compared to the distance to the closest real individual.

The total calculated annual public dose from liquid and gaseous effluent pathways reviewed over the past 1 O years is bounded by 5 mrem. No other uranium fuel cycle facility contributes significantly to the dose'received by the closest real individual.

* *

Page 6-5 Attachment 6 Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Based on the above, the calculated annual dose to the closest real individual due to the ISFSI, which is comprised of the currently existing 24 NAC-UMS casks, and up to one 2x12 array of MAGNASTOR casks, is determined to be less than 14.7 mrem, and the estimated annual dose due to Catawba power generation is less than 5 mrem. Hence, the total annual dose to the closest real individual (less than 19. 7 mrem) is within the 1 O CFR 72.104(a) limit. Page 6-6 Attachment 7 Information to Support the NEI Ground Water Protection Initiative Catawba Nuclear Station Units 1 & 2 Period 1/1/2015

-12/31/2015 ATTACHMENT 7 Information to Support the NEI Ground Water Protection Initiative This attachment includes a summary of voluntary reports made in accordance with the NEI Ground Water Protection Initiative and a summary of ground water well sample data. Page 7-1 Attachment 7 Information to Support the NEI Ground Water Protection Initiative Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Duke Energy implemented a Ground Water Protection program in 2007. This initiative was developed to ensure timely and effective management of situations involving inadvertent releases of licensed material to ground water. As part of this program, Catawba Nuclear Station monitored 49 wells and 1 outfall from the Conventional Wastewater Treatment Ponds in 2015. Wells are typically sampled quarterly or semi-annually.

Ground water samples are regularly analyzed for tritium and gamma emitters, with select wells being analyzed for radionuclides.

No gamma or difficult-to-detect radionuclides, other than naturally occurring radionuclides, were identified in well samples during 2015. Results from sampling during 2015 confirmed existing knowledge of tritium concentrations in site ground water. Results from sampling during 2015 are shown in the table below. No events meeting the criteria for voluntary notification per NEI 07-07, Industry Ground Water Protection Initiative, occurred at Catawba Nuclear Station in 2015. Key to below table. NS pCi/I <MDA 20,000 pCi/I 1,000,000 pCi/I Not scheduled to be sampled, not sampled due to insufficient volume in well, or well inaccessible during outage. -picocuries per liter. -less than minimum detectable activity, typically 250 pCi/I. the Environmental Protection Agency drinking water standard for tritium. This standard applies only to water used for drinking.

the 10 CFR Part 20, Appendix 8, Table 2, Column 2, Effluent Concentration Limit for tritium. Page 7-2 Attachment 7 Information to Support the NEI Ground Water Protection Initiative Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Well Location I Description Tritium Concentration (pCi/I) #of Name 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Samples C-100DR CNS GWPI I C-100DR/ U-1 SFP <MDA <MDA

<MDA NS 3 C-101DR CNS GWPI I C-101DR I U-1 SFP 3.37E+02 3.35E+02 3.74E+02 3.47E+02 4 C-101R CNS GWPI I C-101R I U-1 SFP 5.84E+02 5.57E+02 4.62E+02 5.01E+02 4 C-102 CNS GWPI I C-102 / E of U1 SFP O/S protected area 4.07E+02 4.39E+02 4.11E+02 3.84E+02 4 C-103 CNS GWPI I C-103 / E of U1 SFP@ Cooling Towers 3.93E+02 3.73E+02 3.61E+02 2.48E+02 4 C-104 CNS GWPI/ C-104 / U-1 RMWST 5.65E+02 4.19E+02 3.35E+02 NS 3 C-105 CNS GWPI I C-105 / Engr. Bldg. 6.92E+02 <MDA <MDA 1.25E+03 4 C-105R CNS GWPI I C-105R I Engr. Bldg. 5.73E+02 4.59E+02 4.40E+02 5.76E+02 4 C-106 CNS GWPI I C-106 / W Parking Lot <MDA <MDA

<MDA <MDA 4 C-106R CNS GWPI I C-106R I W Parking Lot <MDA <MDA <MDA <MDA 4 C-107 CNS GWPI I C-107 /MET Tower Hill 8.25E+02 7.43E+02 5.97E+02 7.33E+02 4 C-108 CNS GWPI I C-108 / NS NS NS <MDA 1 C-109 CNS GWPJ I C-109 / NS NS NS 6.95E+02 1 C-110 CNS GWPl/C-110/

NS NS NS 2.38E+03 1 C-200DR CNS GWPI I C-200DR I U-2 SFP NS 4.76E+02 4.05E+02 3.45E+02 3 C-200R CNS GWPI I C-200R I U-2 SFP NS 5.15E+02 6.27E+02 5.50E+02 3 C-201DR CNS GWPI I C-201 DR I U-2 SFP 6.02E+02 5.48E+02 4.55E+02 5.83E+02 4 C-201R CNS GWPI I C-201 RI U-2 SFP 4.61E+03 4.06E+03 4.95E+03 2.94E+03 4 C-202 CNS GWPJ I C-202 IS of RMC Tent 5.14E+02 4.90E+02 4.61E+02 5.82E+02 4 C-203 CNS GWPI I C-203 I E of RMC Tent @ Cooling Towers 4.97E+02 2.50E+02 2.99E+02 4.99E+02 4 C-204 CNS GWPI I C-2041 S of RMC Tent 2.20E+02 2.08E+02

<MDA *2.02E+02 4 C-205 CNS GWPI I C-205 I Adm. Parking <MDA <MDA <MDA <MDA 4 C-205R CNS GWPI I C-205R I Adm. Parking <MDA <MDA

<MDA <MDA 4 C-206 CNS GWPI I C-206 I W Parking Lot <MDA <MDA <MDA <MDA 4 C-207 CNS GWPI I C-207 I Mon. Tank B 4 .. 14E+02 2.75E+02 4.16E+02 3.81E+02 4 C-207R CNS GWPI I C-207R I Mon. Tank B <MDA <MDA 2.71E+02 <MDA 4 C-208 CNS GWPI I C-208 I N of MTB <MDA <MDA <MDA 2.01E+03 4 C-209 CNS GWPI I C-209 I MTUville S of light pole 23A 2.04E+02 <MDA 1.91E+02 <MDA 4 C-210 CNS GWPI I C-210 IN of U2 Mech Equip Bldg <MDA <MDA

<MDA <MDA 4 C-211 CNS GWPI I C-211 I W of RL Intake O/S Protected Area 8.93E+02 4.48E+02 7.00E+02 1.06E+03 4 C-212 CNS GWPI I C-212 /Behind Aquatic Center <MDA <MDA <MDA <MDA 4 C-213 . CNS GWPI I

/Mon. Ta_nk B 5.61E+03 4.19E+03 3.84E+03 4.19E+03 4 -C-213R CNS GWPI I C-213R I Mon. Tank B <MDA <MDA 1.93E+02 <MDA 4 C-214 CNS GWPI I C-2141 N of U2 TB 9.57E+02 9.73E+02 8.77E+02 8.82E+02 4 C-215 CNS GWPI I C-215 / N of U2 TB 3.78E+02 4.49E+02 3.83E+02 2.48E+02 4 C-217 CNS GWPI I C-2171 N of U2 TB 7.57E+02 8.50E+02 6.43E+02 7.50E+02 4 C-218 CNS GWPI I C-218 / N of U2 TB <MDA 1.52E+03 6.86E+02 3.67E+02 4 C-220 CNS GWPI I C-220 I N of U2 TB 2.68E+03 1.99E+03 2.44E+03 2.08E+03 4 C-221 CNS GWPI I C-221 I N of U2 TB 4.11E+02 5.06E+02 3.93E+02 3.98E+02 4 LMW-18 CNS Landfill I LMW-1B I Landfill NS <MDA NS <MDA 2 LMW-2A CNS Landfill I LMW-2A I Landfill NS <MDA NS <MDA 2 LMW-3A CNS Landfill I LMW-3A I Landfill NS <MDA NS <MDA 2 LMW-4 CNS Landfill I LMW-4 / Landfill NS <MDA NS <MDA 2 LMW-50 CNS Landfill I LMW-50 I Landfill NS <MDA NS <MDA 2 Page 7-3 Well Name LMW-5S OUTFALL017 WCMW-3 WCMW-4 WCMW-5 Well Name Attachment 7 Information to Support the NEI Ground Water Protection Initiative Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Location I Description Tritium Concentration (pCi/I) #of 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Samples CNS Landfill / LMW-5S I Landfill NS <MDA NS <MDA 2 CNS WC Ponds I OUTFALL-017

/WC Ponds 7.86E+02 7.77E+02 8.08E+02 7.42E+02 4 CNS WC Ponds I WCMW-3 /WC Ponds 9.80E+02 1.29E+03 1.06E+03 8.56E+02 4 CNS WC Ponds I WCMW-4 /WC Ponds 7.14E+02 5.23E+02 5.74E+02 5.27E+02 4 CNS WC Ponds I WCMW-5 /WC Ponds <MDA <MDA <MDA <MDA 4 Location I Description Tritium Concentration (pCi/I) #of Min Avg Max Samples WCMW-2 <1 l I CNS WC Ponds I WCMW-2 /WC Ponds I 5.68E+03 I 6.69E+03 I 7.48E+03 I 8 (1) Quarterly sampling through 611712015, monthly thereafter.

Sampling through 1211612015 indicated (NCR# 01939441, NCR# 01948296)

Page 7-4 Attachment 8 Inoperable Equipment Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 8 Inoperable Equipment This attachment in'cludes an explanation of inoperable instruments to effluent monitoring in excess of allowed time defined by licensing bases and an explanation of permanent or temporary outside liquid storage tanks exceeding 10 Curies total activity (excluding tritium and dissolved or entrained noble gases). Page 8-1 Attachment 8 Inoperable Equipment Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Catawba Nuclear Station experienced six (6) instances of inoperable equipment relevant to effluent monitoring in excess of SLC 16.11 limits during 2015. Details of each are described below. Catawba Nuclear Station did not experience permanent or temporary unprotected outside liquid storage tanks exceeding 10 Curies total activity (excluding tritium and dissolved or entrained noble gases) during 2015. SLC #from Table 16.11-7-1 1.a Title OEMF 50 (L) Completion Time 14 Days Determination and Data Reviewed For OEMF50(L), out of service time for 2015 is 37.59 days (11/16/2015to12/24/2015 TSAILA-0-15-00661 For 2015, OEMF-50 was non-functional from 11/16/2015 to 12/24/2015 due to a spurious Trip 2 condition.

Troubleshooting determined valve leak by was causing the increase in counts seen by OEMF50 and no issues existed with the detector.

Calibration check was performed with no issues identified with OEMF50L.

WO 20013584-01 SLC #from Table 16.11-2-1 1.c Title OEMF 57 Completion Time 14 Days Determination and Data Reviewed For OEMF57, out of service time for 2015 was 21.71 days (11/25/2015 to 12/17/2015 TSAILA-0-15-00754.

For year 2015, OEMF57 was non-functional from 11/25/2015 to 12/17/2015 due to low flow indications on OWLFS8250.

Low flow issues were corrected under WO 20041271 and OEMF57 was returned to service.

WO 20041271-01 SLC #from Table 16.11-2-1 3.c Title RL Minimum Flow Interlock Completion Time 30 Days Determination and Data Reviewed For ORLFT5930, out of service time for 2015 was 182.15 days (4/24/2015 to 10/23/2015 TSAIL C0-15-01133 and A-0-15-00001.

For year 2015, RL Min Flow Interlock was non-functional from 4/24/2015 to 10/23/2015 due to ORLFT5930 being removed for pipe cleaning and carbon wrapping of RL piping per EC 105540. As part of the EC, ORLFT5930 was replaced and restored under WO 02027933 following RL piping improvements.

WO 02027933 Page 8-2 SLC #from Table 16.11-2-1 4.a Title 1EMF-45A Attachment 8 Inoperable Equipment Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Completion Time 30 Days Determination and Data Reviewed For 1 EMF-45A Low Range, out of service time for year 2015 is 340.34 days (1/24/2015 to 12/31/2015 TSAIL C1-15-00233 and T-1-15-00039).

For year 2015, 1EMF-45A was non-functional from 1/24/2015 to 12/31/2015 and has been rolled over to 2016. 1 EMF-45A has been entered in LCO tracking due to "Loss of Flow" alarms while aligned to NS Heat Exchanger 1A and issues with 1RNFT4980.

Work is in the schedule to work associated flow transmitter prior to NS/RN Clam Flush on each unit. Channel calibrations of 1EMF-45a have been completed successfully under WO 02204145-01.

WO 02196697-01

WO 20053500-01

WO 02204145-02 SLC #from Table 16.11-2-1 Title 4.a 1EMF-458 Completion Time 30 Days Determination and Data Reviewed For 1 EMF-458 Low Range, out of service time for year 2015 is 238.87 days (5/6/2015 to 12/31/2015 TSAIL C1-15-01221 and T-1-15-00040).

For year 2015, 1 EMF-458 was non-functional from 5/6/2015 to 12/31/2015 and has been rolled over to 2016. 1 EMF-458 has been entered in LCO tracking due to failed "Loss of Flow" alarm during testing. Work is in the schedule to work associated flow transmitter prior to NS/RN Clam Flush on each unit.

W020011310-01 SLC #from Table 16.11-2-1 4.a Title 2EMF-45A Completion Time 30 Days Determination and Data Reviewed For 2EMF-45A Low Range, out of service time for year 2015 is 340.34 days (1/24/2015 to 12/31/2015 TSAIL C2-15-00234 and T-2-15-00041).

For year 2015, 2EMF-45A was non-functional from 1/24/2015 to 12/31/2015 and has been rolled over to 2016. 2EMF-45A has been entered in LCO tracking due to "Loss of Flow" alarms while aligned to NS Heat Exchanger 1A and issues with 2RNFT4980.

Work is in the schedule to work associated flow transmitter prior to NS/RN Clam Flush on each unit. COT of 2EMF-45a have been completed successfully under WO 02198286-01.

WO 02196696-01 Page 8-3 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 9 Summary of Changes to the Offsite Dose Calculation Manual Example This attachment includes a summary of changes to the ODCM and Radiological Effluent Controls.

Page 9-1 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual ODCM Revision 59 Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ODCM Revision 59 is provided in entirety on the enclosed CD. All ODCM changes are reviewed by knowledgeable individual(s), and approved by either the Station Manager or Radiation Protection Manager. The below changes do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

ODCM Revision 59 was approved by the Radiation Protection Manager on February 17, 2016. Some changes reflected in ODCM Revision 59 were implemented prior to February 17, 2016 under a different change and approval process (e.g., land use census), and in those cases the implementation date is noted below. Section 6 -Page 4 Changed title of Table 6.0-3 to: "Catawba 2015 Land Use Census Results." Land use census dates were changed to reflect 2015 census dates. The 2015 land use census was performed July 8-9, 2015, and the results were certified and made available for use on July 16, 2015. The distance (miles) for the NW sector residence was changed from 1.39 to 1.27. The distance (miles) for the N sector garden was changed from 1.55 to 1.38. Deleted "irrigated" as the N sector 1 garden is not irrigated with waters receiving plant discharges. . i The distance (miles) for the NNE sector garden was changed from 4.47 to 0.69. The distance (miles) for the NE sector garden was changed from 0.68 to 2.39. The distance (miles) for the ENE sector garden was changed from 2.73 to 1.44. Added "irrigated" as the ENE sector garden is irrigated with waters receiving plant discharges.

The distance (miles) for the E sector garden was changed from 3.52 to 2.26. The distance (miles) for the ESE sector garden was changed from 3.70 to 1.29. The distance (miles) for the SE sector garden was changed from 2.55 to 1.50. The distance (miles) for the SSW sector garden was changed from 1.34 to 0.89. The distance (miles) for the SW sector garden was changed from 2.02 to 0.78. Added "irrigated" as the SW sector garden is irrigated with Waters receiving plant discharges.

The distance (miles) for the WSW sector garden was changed from 2.03 to 1.98. The distance (miles) for the NNW sector garden was changed from 2.13 to 1.19. Reformatted notes into table. Changes made to reflect 2015 Land Use Census results and provide better accuracy and clarity of receptor data. Section 6 -Page 7 Changed title of Figure 6.0-3 to "CNS 2015 Land Use Census Map." Figure 6.0-3 was regenerated using ESRI ArcGIS Version 9.3.1 software by Orbis, Incorporated, Charlotte, NC, to update map symbology.

Changes made to reflect 2015 Land Use Census results and provide better accuracy and clarity of receptor d.ata. Page 9-2 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radiological Effluent Controls (SLC 16.11) The Catawba Nuclear Station Radiological Effluent Controls are contained in SLC 16.11 as follows. Three revisions were made to the Catawba Nuclear Station Updated Final Safety Analysis Report, Section 16.11, Radiological Controls, in 2015:

Section 16.11-2, "Radioactive Gaseous Effluent Monitoring Instrumentation," was changed on 02/10/15.

Section 16.11-6, "Radioactive Gaseous Effluent Monitoring Instrumentation," was changed on 08/03/15.

Section 16.11-7, "Radioactive Gaseous Effluent Monitoring Instrumentation," was changed on 02/10/15.

As per TS 5.5.5.b, "Licensee initiated changes to the Radiological Effluent Controls of the UFSAR," Catawba is attaching the entire Section 16.11 of the UFSAR and the List of Effective Sections which will demonstrate when each section was revised. Page 9-3

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 LIST OF EFFECTIVE SECTIONS SECTION REVISION NUMBER REVISION DATE TABLE OF CONTENTS 14 02/10/15 16.1 1 08127108 16.2 2 08/21/09 16.3 1 08/21/09 16.5-1 3 08/19/15 16.5-2 -Deleted 16.5-3 1 02/20/04 16.5-4 0 10/09/02 16.5-5 1 01/28/10 16.5-6 1 08/21/09 16.5-7 2 02/06/15 16.5-8 2 12/22/08 16.5-9 1 02/20/12 16.5-10 Deleted 1'6.6-1 0 10/09/02 16.6-2 Deleted 16.6-3 1 08/21/09 16.6-4 1 08/21/09 16.6-5 2 01/09/13 16.7-1 1 08/21/09 16.7-2 4 02/03/11 16.7-3 4 07/27/13 16.7-4 2 08/21/09 16.7-5 2 08/21/09 Catawba Units 1 and 2 Page 1 Revision 62 Page 9-4 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 LIST OF EFFECTIVE SECTIONS SECTION REVISION NUMBER REVISION DATE 16.7-6 2 08/21/09 16.7-7 1 08/21/09 16.7-8 2 08/21/09 16.7-9 9 06/06/13 16.7-10 6 04/11/14 16.7-11 1 08/21/09 16.7-12 1 08/21/09 16.7-13 2 08/21/09 16.7-14 1 08/21/09 16.7-15 1 08/21/09 16.7-16 0 06/08/09 16.7-17 0 02/10/15 16.8-1 6 12/10/15 16.8-2 2 02/20/12 16.8-3 1 10/24/06 16.8-4 2 11/05/07 16.8-5 3 08/21/09 16.9-1 7 10/24/11 16.9-2 5 10/24/11 16.9-3 3 02/03/11 16.9-4 3 08/21/09 16.9-5 6 06/23/10 16.9-6 10 02/10/15 16.9-7 4 08/21/09 Catawba Units 1 and 2 Page 2 Revision 62 Page 9-5 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015 -12/31/2015 LIST OF EFFECTIVE SECTIONS SECTION REVISION NUMBER REVISION DATE 16.9-8 5 08/21/09 16.9-9 3 08/21/09 16.9-10 5 08/21/09 16.9-11 3 08/21/09 16.9-12 3 02/10/15 16 .. 9-13 3 08/21/09 16.9-14 1 09/25/06 16.9-15 2 08/21/09 16.9-16 2 08/21/09 16.9-17 0 10/09/02 16.9-18 0 10/09/02 16.9-19 3 02/20/12 16.9-20 0 10/09/02 16.9-21 0 10/09/02 16.9-22 1 08/21/09 16.9-23 4 10/24/11 16.9-24 2 10/24/06 16.9-25 2 08/21/09 16.9-26 0 03/05/12 16.10-1 1 08/21/09 16.10-2 1 10/24/06 16.10-3 1 08/21/09 16.11-1 1 07/27/13 16.11-2 4 02/10/15 Catawba Units 1 and 2 Page 3 Revision 62 Page 9-6 Attachment 9 Summary of Changes to the Off site Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 LIST OF EFFECTIVE SECTIONS SECTION REVISION NUMBER REVISION DATE 16.11-3 0 10/09/02 16.11-4 1 08/21/09 16.11-5 0 10/09/02 16.11-6 3 08/03/15 16.11-7 9 02/10/15 16.11-8 0 10/09/02 16.11-9 0 10/09/02 16.11-10 1 08/21/09 16.11-11 1 03120103 16.11-12 0 10/09/02 16.11-13 1 07/27/13 16.11-14 0 10/09/02 16.11-15 0 10/09/02 16.11-16 1 10/24/11 16.11-17 0 10/09/02 16.11-18 1 08/21/09 16.11-19 0 10/09/02 16.11-20 1 08/21/09 16.11-21 0 10/09/02 16.12-1 0 10/09/02 16.13-1 0 10/09/02 16.13-2 Deleted 16.13-3 Deleted 16.13-4 0 10/09/02 Catawba Units 1 and 2 Page4 Revision 62 Page 9-7 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015 -12/31/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS Liquid Effluents 16.11-1 16.11-1 Liquid Effluents COMMITMENT:

The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 16.11-16-1 in SLC 16.11-16) shall be limited to: a. For radionuclides other than dissolved or entrained noble gases, 10 times the effluent concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2, and b. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10-4 microCurie/mf total activity.

APf?LICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Restore the concentration Immediately to within limits. A. Concentration of A.1 radioactive material released in liquid effluents to UNRESTRICTED AREAS not within limits. TESTING REQUIREMENTS TEST TR 16. 11-1-1 ---------------------------------N 0 TE---------------------------------

The results of the radioactivity analyses shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits. ---------------------------------------------------------------------------

FREQUENCY Sample and analyze radioactive liquid wastes according According to Table to Table 16.11-1-1.

16.11-1-1 Catawba Units 1 and 2 16.11-1-1 Revision 1 Page 9-8 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Table 16.11-1-1 Liquid Effluents 16.11-1 Radioactive Liquid Waste Sampling and Analysis Program (page 1 of 3) LIQUID SAMPLING MINIMUM TYPE OF LOWER RELEASE TYPE FREQUENCY ANALYSIS ACTIVITY LIMIT OF FREQUENCY ANALYSIS DETECTION (LLD)'1> (µCi/ml) 1 . Batch Waste Prior to each Prior to each Principal Gamma 5x10-' Release release release Emitters'3 l Tanks'2> Each Batch Each Batch 1-131 1x10oQ Any tank Prior to each 31 days Dissolved and 1x10""" which release Entrained Gases discharges One Batch/31 (Gamma Emitters) liquid wastes days by either liquid effluent monitor, EMF-49 or EMF-57 Prior to each 31 days H-3 1x10-0 release Composite' 4> Each Batch Gross Alpha 1x10-' Prior to each 92 days Sr-89, Sr-90 5x10""' release Composite' 4> Each Batch 2. Continuous Continuous 101 7 days Principal Gamma 5x10-' Refeases<5 l Composite' 6> Emitters(3 l Conventional Waste Water Treatment Line 1-131 1x10-<> 31 days 31 days Dissolved and 1x10""" Grab Sample Entrained Gases (Gamma Emitters)

Continuous 10 i 31 days H-3 1x10""" Composite' 6> Gross Alpha 1x10-' Continuous<

0 J 92 days Sr-89, Sr-90 5x10""' Composite' 6> Catawba Units 1 and 2 16.11-1-2 Revision 1 Page 9-9 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Table 16.11-1-1 Liquid Effluents 16.11-1 Radioactive Liquid Waste Sampling and Analysis Program (page 2 of 3) NOTES: (1) The LLD is defined, for purposes of these commitments, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system, which may include radiochemical separation:

Where: LLD= (2.71/T) + 4.65 s b E

V

2.22x10 6

Y *exp (-Mt) LLD = the "a priori" lower limit of detection (microCurie per unit mass or volume), sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute), E =the counting efficiency (counts per disintegration), V =the sample size (units of mass or volume), 2.22 x 10 6 = the number of disintegrations per minute per microCurie, Y =the fractional radiochemical yield, when applicable, 'A, = the radioactive decay constant for the particular radionuclide (sec-1), Llt = the elapsed time between midpoint of sample collection and time of counting (sec), and T = the sample counting time (min). Typical values of E, V, Y and Llt shall be used in the calculation.

It should be r_ecognized that the LLD is defined as an .e. priori (before the fact) limit representing the capability of a measurement system and not as an .e. posteriori (after the fact) limit for a particular measurement.

(2) A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed to assure representative sampling.

Catawba Units 1 and 2 16.11-1-3 Revision 1 Page 9-10 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Table 16.11-1-1 Liquid Effluents 16.11-1 Radioactive Liquid Waste Sampling and Analysis Program (page 3 of 3} (3) The principal gamma emitters for which the LLD specification applies include the following radionuclides:

Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, and Ce-141. The LLD for Ce-144 is 5x1 O.s µCi/ml. This list does not mean that only these nuclides are to be considered.

Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Radioactive Effluent Release Report pursuant to Technical Specification 5.6.3 in the format outlined*in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974. (4) A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen that is representative of the liquids released.

(5) A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. (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 release. > Catawba Units 1 and 2 16.11-1-4 Revision 1 Page 9-11 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents 16.11-1 The basic requirements for SLCs concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent SLCs will keep average annual releases of radioactive material in effluents to small percentages of the limits specified in the old 1 O CFR 20.106 (new 10 CFR 20.1302).

These requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR 20.106 which references Appendix B, Table II concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose of 500 mrem. It is further indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix I. As stated in the Introduction to Appendix B of the new 10 CFR 20, the liquid effluent concentration (EC) limits given in Appendix B, Table 2, Column 2, are based on an annual dose of 50 mrem. Since a release concentration corresponding to a limiting dose rate of 500 mrem/year has been acceptable.

as a SLC limit for liquid effluents, which applies at all times as an assurance that the limits of 10 CFR 50, Appendix I are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of 10. Operational history at Catawba has demonstrated that the use of the concentration values associated with the old 10 CFR 20.106 as SLC limits has resulted in calculated maximum individual doses to a MEMBER OF THE PUBLIC that are small percentages of the limits of 10 CFR 50, Appendix I. Therefore, the use of concentration values which correspond to an annual dose of 500 mrem (ten times the concentration values stated in the new 10 CFR 20, Appendix B, Table 2, Column 2) should not have a negative impact on the ability to continue to operate within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations.

As discussed above, the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 2, relate to a dose of 50 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem/year.

This low value is impractical upon which to base effluent monitor setpoint calculations for many liquid effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. Therefore, to accommodate operational flexibility needed for effluent releases, the limits associated with SLC .16.11-1 are based on ten times the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 2, to apply at all times. The multiplier of ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B, Table II, Column 2, are based, is a factor of 10 higher than annual dose of 50 mrem, upon which the concentrations in the new 1 O CFR Catawba Units 1 and 2 16.11-1-5 Revision 1 Page 9-12

BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Liquid Effluents 16.11-1 20, Appendix B, Table 2, Column 2, are based. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. The concentration limit for dissolved or entrained noble gases is based upoh the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication

2. This commitment applies to the release of radioactive materials in liquid effluents from all units at the site. The required detection capabilities for radioactive materials in liquid waste samples are tabulated in terms of the lower limits of detection (LLDs). Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, L.A., "Limits for Qualitative Detection and Quantitative Determination

-Application to Radiochemistry," Annal. Chem. 40, 586-93 (1968), and Hartwell, J. K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 20, Appendix B. Catawba Units 1 and 2 16.11-1-6 Revision 1 Page 9-13 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-2 16.11-2 Radioactive Liquid Effluent Monitoring Instrumentation COMMITMENT The Radioactive Liquid Effluent Monitoring Instrumentation channels shown in Table 16.11-2-1 shall be FUNCTIONAL with their Alarmffrip Setpoints set.to ensure that the limits of SLC 16.11-1 are not exceeded.

The Alarmffrip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM). APPLICABILITY:

At all times, except when the effluent pathway is mechanically isolated; thus, a release to the environment is not possible.

REMEDIAL ACTIONS --------------------------------------------------------NOTE--------------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend the release of Immediately Radioactive Liquid radioactive liquid effluents Effluent Monitoring monitored by the affected Instrumentation channel(s).

channel(s)

Alarmffrip Setpoint less OR conservative than required.

A.2 Declare the channel(s)

Immediately non-functional.

8. One or more 8.1 Enter the applicable Immediately Radioactive Liquid Conditions and Required Effluent Monitoring Actions specified in Table Instrumentation 16.11-2-1 for the channel(s) non-channel(s).

functional. (continued)

Catawba Units 1 and 2 16.11-2-1 Revision 4 Page 9-14 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 REMEDIAL ACTIONS (continued)

C. CONDITION One channel functional.

Catawba Units 1 and 2 REQUIRED ACTION C.1.1 Analyze two independent samples per Testing Requirement 16.11-1-1.

C.1.2 Perform independent verification of the discharge line valving. C.1.3.1 Perform independent

verification of manual portion of the computer input for release rate calculations performed by computer.

C.1.3.2Perform independent verification of entire calculations for release rate calculations performed manually.

C.1.4 Restore channel to FUNCTIONAL status. C.2 Suspend release of radioactive effluents via this pathway. 16.11-2-2 COMPLETION TIME Prior to initiating a release Prior to initiating a release Prior to initiating a release Prior to initiating a release 14 days Immediately (continued)

Revision 4 Page 9-15 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 REMEDIAL ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One flow rate D.1 -------------N 0 TE-------------

measurement device Pump performance curves channel non-functional.

generated in place may be used to estimate flow. ------------------------------------

Estimate the flow rate of Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the release. during releases AND D.2 Restore channel to 30 days FUNCTIONAL status. E. One channel non-E.1 Perform an analysis of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months functional.

grab samples for during releases radioactivity at a lower limit when secondary of detection of 10-7 specific activity is > microCurie/ml.

0.01 microCurie/gm DOSE EQUIVALENT 1-131, AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during releases when secondary specific activity is .::_ 0.01 microCurie/gm DOSE EQUIVALENT 1-131 AND E.2 Restore channel to 30 days FUNCTIONAL status. (continued)

Catawba Units 1 and 2 16.11-2-3 Revision 4 Page 9-16 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 REMEDIAL ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One channel non-F.1 Collect and analyze grab Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months functional.

samples for principal gamma emitters (listed in Table 16.11-1-1, NOTE 3) at a lower limit of detection of no more than 5x10-7 microCurie/ml.

AND F.2 Restore non-functional 30 days channel to FUNCTIONAL status. G. Required Action and G.1 Explain why the non-In the next associated Completion functionality was not scheduled Time of Condition C, D, corrected within the Radioactive Effluent E, or F not met. specified Completion Time. Release Report pursuant to Technical Specification

5.6.3 Catawba

Units 1 and 2 16.11-2-4 Revision 4 Page 9-17 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 TESTING REQUIREMENTS

NOTE--------------------------------------------------------

Refer to Table 16.11-2-1 to determine which TRs apply for each Radioactive Liquid Effluent Monitoring Instrumentation channel. TEST FREQUENCY TR 16.11-2-1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TR 16.11-2-2

N 0 TE---------------------------------

The CHANNEL CHECK shall consist of verifying indication of flow. ---------------------------------------------------------------------------

Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during periods of release TR 16.11-2-3 Perform SOURCE CHECK. Prior to each release TR 16.11-2-4 Perform SOURCE CHECK. 31 days TR 16.11-2-5 Perform COT. 92 days TR 16.11-2-6

N 0

For Instrument 1, the COT shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation (for EMF-57, alarm annunciation is in the Monitor Tank Building control room and on the Monitor Tank Building control panel remote annunciator panel) occur if any of the following conditions exist: a. Instrument indicates measured levels above the Alarmffrip Setpoint, or b. Circuit failure/instrument downscale failure (alarm only) ---------------------------------------------------------------------------

Perform COT. 9 months (continued)

Catawba Units 1 and 2 16.11-2-5 Revision 4 Page 9-18 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 TESTING REQUIREMENTS continued TEST TR 16. 11-2-7 ---------------------------------NOTE---------------------------------

F or Instrument 1, the initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used. Perform CHANNEL CALIBRATION.

Catawba Units 1 and 2 16.11-2-6 FREQUENCY 18 months Revision 4 Page 9-19 Attachment 9 Summary of Changes to the Off site Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 Table 16.11-2-1 Radioactive Liquid Effluent Monitoring Instrumentation INSTRUMENT

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release 1.a Waste Liquid Discharge Monitor (EMF-49 -Low Range) 1.b Turbine Building Sump Monitor (EMF-31) 1.c Monitor Tank Building Liquid Discharge Monitor (EMF-57 -Low Range) 2. Continuous Composite Samplers and Sampler Flow Monitor 2.a Conventional Waste Water Treatment Line (no alarm/trip function)

3. Flow Rate Measurement Devices 3.a Waste Liquid Effluent Line (no alarm/trip function) 3.b Conventional Waste Water Treatment Line (no alarm/trip function) 3.c Low Pressure Service Water Minimum Flow Interlock 3.d Monitor Tank Building Waste Liquid Effluent Line (no alarm/trip function)

4. Radioactivtty Monitors Providing Alarm 4.a Service Water Monitor on Containment Spray Heat Exchanger (EMF-45 A & B -Low Range) REQUIRED CHANNELS 1 per station 1 per station 1 per station 1 per station 1 per station 1 per station 1 per station 1 per heat exchanger Catawba Units 1 and 2 16.11-2-7 CONDITIONS A,C,G A,E,G A,C,G E,G D,G D,G D,G D,G A, F, G TESTING REQUIREMENTS TR 16.11-2-1 TR 16.11-2-3 TR 16.11-2-6 TR 16.11-2-7 TR 16.11-2-1 TR 16.11-2-4 TR 16.11-2-6 TR 16.11-2-7 TR 16.11-2-1 TR 16.11-2-3 TR 16.11-2-6 TR 16.11-2-7 TR 16.11-2-2 TR 16.11-2-7 TR 16.11-2-2 TR 16.11-2-7 TR 16.11-2-2 TR 16.11-2-7 TR 16.11-2-2 TR 16.11-2-5 TR 16.11-2-7 TR 16.11-2-2 TR 16.11-2-7 TR 16.11-2-1 TR 16.11-2-4 TR 16.11-2-6 TR 16.11-2-7 Revision 4 Page 9-20 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Liquid Effluent Monitoring Instrumentation 16.11-2 The Radioactive Liquid Effluent Monitoring Instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents.

The Alarmffrip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the Alarmffrip will occur prior to exceeding the limits of 10 CFR Part 20. The FUNCTIONALITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. Regarding the COMMITMENT APPLICABILITY, isolation of the effluent pathway is to be by mechanical means (e.g., valve closure).

Electrical or pneumatic isolation is not required, unless the isolation is designed to receive an automatic signal to open. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 20. 3. 10 CFR Part 50, Appendix A. Catawba Units 1 and 2 16.11-2-8 Revision 4 Page 9-21 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS Dose 16.11-3 16.11-3 Dose COMMITMENT The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-16-1 in SLC 16.11-16) shall be limited: a. During any calendar quarter to 1.5 mrem to the whole body and to .:5. 5 mrem to any organ, and b. During any calendar year 3 mrem to the whole body and to ,:5. 10 mrem to any organ. APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Calculated dose from release of radioactive materials in liquid effluents exceeding above limits. Catawba Units 1 and 2 A.1 REQUIRED ACTION --------------N 0 TE-------------

1 f drinking water supply is taken from receiving water body within 3 miles downstream of plant discharge, the Special Report shall also include the results of radiological analyses of the drinking water source and the radiological impact on finished drinking water supplies with regard to 40 CFR 141, Safe Drinking Water Act. COMPLETION TIME Prepare and submit a 30 days Special Report to the NRC which identifies the causes for exceeding the limits, corrective actions taken to reduce releases, and actions taken to ensure that subsequent releases are within limits. 16.11-3-1 Revision 0 Page 9-22 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Dose 16.11-3 TESTING REQUIREMENTS TEST FREQUENCY TR 16.11-3-1 Determine cumulative dose contributions from liquid effluents for current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM. 31 days BASES This SLC is provided to implement the requirements of Sections II.A, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The COMMITMENT implements the guides set forth in Section II.A of Appendix I. The REMEDIAL ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in-liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable".

Also, for fresh water sites with drinking water supplies that can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking *water that are in exces*s of the requirements of 40 CFR Part 141. The dose calculation methodology and parameters in the ODCM implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Aceidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. This SLC applies to the release of radioactive materials in liquid effluents from each unit at the site. When shared radwaste treatment systems are used by more than one unit on a site, the wastes from all units are mixed for. shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the radwaste treatment system. For determining conformance to COMMITMENTS, these allocations from shared radwaste treatment systems are to be added to the releases specifically attributed to each unit to obtain

the total releases per unit. Catawba Units 1 and 2 16.11-3-2 Revision O Page 9-23 REFERENCES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual 1. Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Catawba Offsite Dose Calculation Manual. 2. 40 CFR Part 141. 3. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-3-3 Dose 16.11-3 Revision 0 Page 9-24 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Radwaste Treatment System 16.11-4 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-4 Liquid Radwaste Treatment System COMMITMENT The Liquid Radwaste Treatment System shall be FUNCTIONAL and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-16-1 in SLC 16.11-16) would exceed 0.06 mrem to the whole body or 0.2 mrem to any organ iri a 31-day period. APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Radioactive liquid waste A.1 being discharged without treatment and in excess of above limits. Any portion of Liquid Radwaste Treatment System not in operation.

Catawba Units 1 and 2 REQUIRED ACTION COMPLETION TIME Prepare and submit a 30 days Special Report to the NRC which identifies the reasons liquid radwaste was discharged without treatment, identification of non-functional equipment and reasons for non-functionality, corrective actions taken to restore the equipment to FUNCTIONAL status, and actions taken to prevent recurrence.

16.11-4-1 Revision 1 Page 9-25 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Liquid Radwaste Treatment System 16.11-4 TESTING REQUIREMENTS

NOTE--------------------------------------------------------

The Liquid Radwaste Treatment System shall be demonstrated FUNCTIONAL by meeting SLC 16.11-1 and SLC 16.11-3. TEST FREQUENCY TR 16.11-4-1 Project liquid release doses from each unit to UNRESTRICTED AREAS, in accordance with the methodology and parameters in the ODCM, when the Liquid Radwaste Treatment System is not being fully utilized.

31 days BASES The FUNCTIONALITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable".

This COMMITMENT implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 1 O CFR Part 50, and the design objective given in Section 11.D of Appendix I to .10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II .A of Appendix I, 10 CFR Part 50, for liquid effluents.

This SLC applies to the release of radioactive materials in liquid effluents from each unit at the site. When shared radliVaste treatment systems are used-by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the radwaste treatment system. For determining conformance to COMMITMENTS, these allocations from shared radwaste treatment systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix A. Catawba Units 1 and 2 16.11-4-2 Revision 1 Page 9-26 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Radwaste Treatment System 16.11-4 REFERENCES (continued)

3. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-4-3 Revision 1 Page 9-27 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Chemical Treatment Ponds 16.11-5 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-5 Chemical Treatment Ponds COMMITMENT The quantity of radioactive material contained in each Chemical Treatment Pond (CTP) shall be limited by the following expression:

264 L; A 1 < 1.0 V j (C 1 x10) excluding tritium and dissolved or entrained noble gases, where: Ai = CTP inventory limit for single radionuclide "j", in Curies; Ci = 10 CFR 20, Appendix B, Table 2, Column 2, concentration for single radionuclide "j", microCuries/milliliter; V =design volume of liquid and slurry in the CTP, in gallons; and 264 = conversion unit, microCuries/Curie per milliliter/gallon.

APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Quantity of radioactive material in any CTP exceeding above limit. REQUIRED ACTION COMPLETION TIME A.1 Suspend all additions of Immediately radioactive material to the CTP. A.2 Initiate corrective action to Immediately reduce the CTP contents to within limits. Catawba Units 1 and 2 16.11-5-1 Revision 0 Page 9-28

*---Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Chemical Treatment Ponds 16.11-5 TESTING REQUIREMENTS TEST FREQUENCY TR 16.11-5-1 Verify that the quantity of radioactive material contained in each batch of resin/water slurry to be transferred to the CTPs is within limits by analyzing a representative sample of the batch to be transferred.

Each batch to be transferred to the CTPs shall be limited by: Prior to each transfer BASES L: c . _ _cl __ < 0.006' j (C j x 10) where: c i = radioactive resin/water slurry concentration for radionuclide "j" entering the UNRESTRICTED AREA CTPs, in microCuries/milliliter; and Ci = 10 CFR 20, Appendix B, Table 2, Column 2, concentration for single radionuclide "j", in microCuries/milliliter.

The inventory limits of the CTPs are based on limiting the consequences of an uncontrolled release of the pond inventory.

The expression in this SLC assumes the pond inventory is uniformly mixed, that the pond is located in an uncontrolled area as defined in 10 CFR Part 20, and that the concentration limit in Note 1 to Appendix B of 10 CFR Part 20 applies. The batch limits of resin/water slurry transferred to the CTP assure that radioactive material transferred to the CTP are "as low as is reasonably achievable" in accordance with 10 CFR 50.36a. The expression in SLC 16.11-5 assures no batch will be transferred to the CTP unless the sum of the ratios of the activity of the radionuclides to their respective concentration limitation is less than the ratio of the 10 CFR Part 50, Appendix I, Section II.A, total body dose level to the instantaneous whole body dose rate limitation, or that: L* ci < 3mrem/yr =0.00 6 J(Cix10) 500mrem/yr where: Catawba Units 1 and 2 16.11-5-2 Revision 0 Page 9-29 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Chemical Treatment Ponds 16.11-5 BASES (continued) c i = radioactive resin/water slurry concentration for radionuclide "j" entering the UNRESTRICTED AREA CTP, in microCuries/milliliter; and, Ci = 10 CFR Part 20, Appendix B, Table 2, Column 2, concentration for single radionuclide "j", in microCuries/milliliter.

The filter/demineralizers using powdered resin and the blowdown demineralizer are backwashed or sluiced to a holding tank. The tank will be agitated to obtain a representative sample of the resin inventory in the tank. A known weight of the wet, drained resin (moisture content approximately 55 to 60%, bulk density of about 58 pounds per cubic foot) will then be counted. The concentration of the resin slurry to be pumped to the CTPs will then be determined by the formula: where: Qi = concentration of radioactive materials in wet, drained resin for radionuclide "j", excluding tritium, dissolved or entrained noble gases, and radionuclides with less than an 8-day half-life.

The analysis shall include at least Ce-144, Cs-134, Cs-137, Co-58, and Co-60, in microCuries/gram.

Estimates of the Sr-89 and Sr-90 batch concentration shall be included based on the most recent monthly composite analysis (within 3 months); WR =total weight of resin in the storage tank in grams (determined from chemistry logs procedures);

and, VT = total volume of resin water mixture in storage tank to be transferred to the CTPs in milliliters.

The batch limits provide assurance that activity input to the CTP will be minimized, and a means of identifying radioactive material in the inventory limitation of this SLC. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 20, Appendix B. 3. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-5-3 Revision 0 Page 9-30 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Gaseous Effluents 16.11-6 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-6 Gaseous Effluents COMMITMENT The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 16.11-16-1 in SLC 16.11-16) shall be limited to the following:

a. For noble gases: .:5. 500 mrem/yr to the whole body and .:5. 3000 mrem/yr to the skin; and, b. For lodine-131, for lodine-133, for tritium, and for all radionuclides in particulate form with half-lives

> 8 days: .:5. 1500 mrem/yr to any organ. APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Dose rate not within limit. A.1 Restore the release rate to Immediately within limits. TESTING REQUIREMENTS TEST TR 16.11-6-1 Verify that the dose rate due to noble gases in gaseous effluents is within limits in accordance with the methodology and parameters in the ODCM. TR 16.11-6-2 Verify that the dose rate due to lodine-131, I odine-133, tritium, and all radionuclides in particulate form with lives > 8 days in gaseous effluents is within limits in accordance with the methodology and parameters in the ODCM by obtaining representative samples and performing analyses according to Table 16.11-6-1.

Catawba Units 1 and 2 16.11-6-1 FREQUENCY In accordance with the methodology and parameters in the ODCM According to Table 16.11-6-1 Revision 3 Page 9-31

-u Ill cc (1) co w N Table 16.11-6-1 Radioactive Gaseous Waste Sampling and Analysis Program (page 1 of 4) GASEOUS RELEASE TYPE SAMPLING MINIMUM TYPE OF ACTIVITY ANALYSIS FREQUENCY ANALYSIS FREQUENCY

1. Waste Gas Storage Tank Prior to each Prior to each Principal Gamma Emitters\LJ release release Each Tank Each Tank. Grab Sample 2. Containment Purge Prior to each Prior to each Principal Gamma Emitters\" 1 release release Each PURGE(3 l Each PURGE(3 l Grab Sample 31 days H-3 (oxide) 3. Unit Vent 7 7 days\" 1 Principal Gamma Emitters\LJ Grab Sample H-3 (oxide) 4. Containment Air Release and 24 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s\"H 01 Principal Gamma Emitters\" 1 Addition System Grab Sample 31 days H-3 (oxide) 5. All Release Types as Listed in 3. Continuous\

01 7 daysv 1 1-131 Above Charcoal Sample 1-133 Continuoust 01 7 days\1 1 Principal Gamma Emitters\LJ Particulate Sample Continuous\

01 31 days Gross Alpha\01 Composite Particulate Sample Continuous 101 92 days Sr-89, Sr-90 Composite Particulate Sample Catawba Units 1 and 2 16.11-6-2 Gaseous Effluents 16.11-6 LOWER LIMIT OF DETECTION (LLD)C1> (1.1Ci/ml) 1x10""' 1x10-4 1x10"° 1x10 .... 1x10"" 1x10""' 1x10"° 1x10"'" 1x1Q*lU 1x10-*1 1x10-" 1x10*11 (continued)

Revision 3 I I I en c: 3 3 Ill -< (') Q, Ill (') -u Di ::::r Ill (1)::;; :::i C" cc 0 Ill (1) c.z "' c: 0 )> :'.::i: Q. s=::::: j\; (1) (1) Ill olll 03-01 SQ iiJl 3 ' Ill -* (1) ;::; g: -:::i (1) --:::i 0 co 0 -:::i "' N -* (1) en (') 01 Ill !10 0 c: N §I O" :::i s:: Ill :::i c: !!!.

"U Dl co CD (0 w w Table 16.11-6-1 Radioactive Gaseous Waste Sampling and Analysis Program (page 2 of 4) GASEOUS RELEASE TYPE SAMPLING MINIMUM TYPE OF ACTIVITY ANALYSIS FREQUENCY ANALYSIS FREQUENCY

6. Waste Monitor Tank Building 7 days 7 days Principal Gamma Emittersl" 1 Ventilation Exhaust Grab Sample H-3 (oxide) ContinuouslbJ 7 1-131 Charcoal Sample 1-133 ContinuouslbJ 7

Principal Gamma Emitters 1" 1 Particulate Sample Continuousl 01 31 days Gross Alpha Composite Particulate Sample Continuousl 01 92 days Sr-89, Sr-90 Composite Particulate Sample Catawba Units 1 and 2 16.11-6-3 Gaseous Effluents 16.11-6 LOWER LIMIT OF DETECTION (LLD)(1 l (uCi/mf) 1x10"" 1x10"" 1x10-'" 1 x1 o-IU 1 x1 o-" 1x10- 1 x1 o-" Revision 3 Ul c 3 3 Dl -<

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Table 16.11-6-1 Gaseous Effluents 16.11-6 Radioactive Gaseous Waste Sampling and Analysis Program (page 3 of 4) NOTES: (1) The LLD is defined, for purposes of these commitments, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system, which may include radiochemical separation:

Where: LLD = ___ (2_.7_I_l_T_)+_4._65_s_b

__ E

V

2.22x10 6

Y *exp (-ALit) LLD= the "a priori" lower limit of detection (microCurie per unit mass or volume); Sb= the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute); E =the counting efficiency (counts per disintegration);

V = the sample size (units of mass or volume); 2.22 x 10 6 = the number of disintegrations per minute per microCurie; Y = the fractional radiochemical yield, when applicable;

')., = the radioactive decay constant for the particular radionuclide (sec*1); M = the elapsed time between midpoint of sample collection and time of counting (sec); and T =the sample counting time (min). Typical values of E, V, Y and L\t shall be used in the calculation.

It should be recognized that the LLD is defined as an g_ priori (before the fact) limit representing the capability of a measurement system and not as an g_ posteriori (after the fact) limit for a particular measurement.

Catawba Units 1 and 2 16.11-6-4 Revision 3 Page 9-34 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Table 16.11-6-1 Gaseous Effluents 16.11-6 Radioactive Gaseous Waste Sampling and Analysis Program (page 4 of 4) (2) The principal gamma emitters for which the LLD specification applies include the following radionuclides:

Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 in noble gas releases based on grab samples and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, 1-131, Cs-134, Cs-137, and Ce-141 in Iodine and particulate releases based on continuous samples. The LLD for is 5x10*9 µCi/ml and is based on continuous samples. This list does not mean that only these nuclides are to be considered.

Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3 in the format outlined in Regulatory Guide 1.21 .* Appendix B, Revision 1, June 1974. (3) Sampling and analysis shall also be performed following shutdown, startup, or a THERMAL POWER stabilization (power level constant at desired power level) after a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period, for at least one of the three gaseous release types with this notation.

(4) Tritium grab samples shall be taken at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the refueling canal is flooded. (5) Required sampling and analysis frequency during effluent release via this pathway. (6) The ratio of the sample flow volume to the sampled stream flow volume shall be known for the time period covered by each dose or dose rate calculation made in accordance with SLCs 16.11-6, 16.11-8, and 16:11-9. (7) Samples shall be changed at least once per 7 days and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing, or after removal from sampler. Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least 7 days following each shutdown, startup, or THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing.

When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the corresponding LLDs may be increased by a factor of 10. -This requirement does not apply if: (1) analysis shows that the DOSE EQUIVALENT 1-131 concentration in the reactor coolant has not increased more than a factor of 3; and (2) the noble gas monitor shows that effluent activity has not increased-more than a factor of 3. (8) The composite filter(s) will be analyzed for alpha activity by analyzing one filter per week to ensure that at least four filters are analyzed per collection period. (9) Samples shall be changed at least once per 7 days and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to meet LLDs after changing, or after removal from sampler. If the particulate and charcoal sample frequency is changed to a 24-hour frequency, the corresponding LLDs may be increased by a factor of 10 (e.g., LLD for 1-131 from 1x10-12 to 1x10-11 µCi/ml). Catawba Units 1 and 2 16.11-6-5 Revision 3 Page 9-35 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Gaseous Effluents 16.11-6 The basic requirements for SLCs concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent SLCs will keep average annual releases of radioactive material in effluents to small percentages of the limits specified in the old 10 CFR 20.106 (new 10 CFR 20.1301 ). These requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR 20.106 which references Appendix 8, Table II concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose of 500 mrems. It is further indicated in 1 O CFR 50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix I. As stated in the Introduction to Appendix 8 of the .new 10 CFR 20, the gaseous effluent concentration (EC) limits given in Appendix 8, Table 2, Column 1, are based on an annual dose of 50 mrems for isotopes for which inhalation or ingestion is limiting or 100 mrems for isotopes for which submersion (noble gases) is limiting.

Since release concentrations

corresponding to limiting dose rates less than or equal to 500 mrems/year to the whole body, 300_() mrems/year to the skin from noble gases, and 1500 mrems/year to any organ from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days at the site boundarY has been acceptable as a SLC limit for gaseous effluents to assure that the limits of 1 O CFR 50, Appendix I and 40 CFR 190 are not likely to be exceeded, it sho.uld not be necessary to restrict the operational flexibility by incorporating the dose rate associated with the. EC value for isotopes based oil inhalation/ingestion (50 mrems/year) or the dose.rate associated with the EC value for isotopes based on submersion (100 mrems/year).

Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations.

As discussed above, the concentrations stated in the new 10 CFR 20, Appendix 8, Table 2, Column 1, relate to a dose of 50 or 100 mrems in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrems/year.

These low values are impractical upon which to base effluent monitor setpoint calculations for many gaseous effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. Therefore, to accommodate operational flexibility needed for effluent releases, the limits associated with gaseous release rate SLCs will be maintained at the current instantaneous dose rate limit for noble gases of 500 mrems/year to the whole body and 3000 mrems/year to the skin; and for lodine-131, for lodine-133, for tritium, and for all radionuclides in particulate Catawba Units 1 and 2 16.11-6-6 Revision 3 Page 9-36 BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents 16.11-6 form with half-lives greater than 8 days, an instantaneous dose rate limit of 1500 mrems/year to any organ. Compliance with the limits of the new 1 O CFR 20.1301 will be demonstrated by operating within the limits of 1 O CFR 50, Appendix I and 40 CFR 190. Operational history at Catawba has demonstrated that the use of the dose rate values listed above (i.e., 500 mrems/year, 3000 mrems/year, and 1500 mrems/year) as SLC limits has resulted in calculated maximum individual doses to MEMBERS OF THE PUBLIC that are small percentages of the limits of 10 CFR 50, Appendix I and 40 CFR 190. The *specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body and to less than or equal to 3000 mrem/year to the skin from noble gases, and to less than or equal to 1500 mrem/year to any organ from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than eight days. This commitment applies to the release of radioactive materials in gaseous effluents from all units at the site. The required detection capabilities for radioactive material in gaseous waste samples are tabulated in terms of the lower limits of detection (LLDs). Based on NUREG-1301 and Reguiatory Guide 1.21, the LLD value of 1x10 4 µCi/ml for grab samples is only applicable to noble gases grab samples and the LLD values for particulate and iodine radionuclides are applicable to continuous charcoal and particulate samples. The Table 16.11-6-1 Gaseous Release Type Number 5 (All Release Types as Listed in 3. Above) and Type Number 6 (Waste Monitor Tank Building Ventilation Exhaust) LLDs are based on weekly samples per NUREG-1301.

There are two isotopes with associated LLDs that do not agree directly with NUREG-1301:

Ce-144, LLD of 5x10-9 µCi/ml, which has historically been applied and achieved for analytical results, and 1-133, LLD of 1x10-10 µCi/ml, which again has been historically listed, as 1x10-9 µCi/ml, for Radioactive Gaseous Waste Sampling but changed to be in agreement with 1-131 for weekly (7-day) samples and is not specified in NUREG-1301.

Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, L.A., "Limits for Qualitative Detection and Quantitative Determination -Application to Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J.K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). REFERENCES

1. Catawba Offsite Dose Calculation Manual. Catawba Units 1 and 2 16.11-6-7 Revision 3 Page 9-37 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 REFERENCES (continued)

2. 10 CFR Part 20, Appendix B. 3. 10 CFR Part 20. 4. 10 CFR Part 50. 5. 40 CFR Part 190. 6. NUREG-1301.

7. Regulatory Guide 1.21. Catawba Units 1 and 2 16.11-6-8 Gaseous Effluents 16.11-6 Revision 3 Page 9-38 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-7 Radioactive Gaseous Effluent Monitoring Instrumentation COMMITMENT The Radioactive Gaseous Effluent Monitoring Instrumentation channels shown in Table 16.11-7-1 shall be FUNCTIONAL with their Alarmffrip Setpoints set to ensure that the limits of SLC 16.11-6 are not exceeded.

The Alarmffrip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

As shown in Table 16.11-7-1.

REMEDIAL ACTIONS --------------------------------------------------------NOTE--------------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend the release of Immediately Radioactive Gaseous radioactive gaseous Effluent Monitoring effluents monitored by the Instrumentation affected channel(s).

channel(s)

Alarmffrip Setpoint less OR conservative than required.

A.2 Declare the channel(s)

Immediately non-functional.

B. One or more 8.1 Enter the applicable Immediately Radioactive Gaseous Conditions and Required Effluent Monitoring Actions specified in Table Instrumentation 16.11-7-1 for the channel(s) non-channel(s).

functional. (continued)

Catawba Units 1 and 2 16.11-7-1 Revision 9 Page 9-39 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REMEDIAL ACTIONS (continued)

C. CONDITION One channel functional.

Catawba Units 1 and 2 C.1 REQUIRED ACTION Verify that EMF-36 (Low Range) is FUNCTIONAL.

C.2.1 Analyze two independent samples of the tank's contents.

C.2.2 Perform independent verification of the discharge line valving. C.2.3.1 Perform independent verification of manual portion of the computer input for release rate calculations performed by computer.

C.2.3.2Perform independent verification of entire calculations for release rate calculations performed manually.

C.2.4 Restore channel to FUNCTIONAL status. C.3 Suspend release of radioactive effluents via this pathway. 16.11-7-2 COMPLETION TIME Prior to initiating a release Prior to initiating a release Prior to initiating a release Prior to initiating a release Prior to initiating a release 14 days Immediately (continued)

Revision 9 Page 9-40 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual REMEDIAL ACTIONS (continued)

CONDITION D. One or more flow rate measurement device channel(s) non-functional.

E. One or more Noble Gas Activity Monitor channel(s) non-functional.

Catawba Units 1 and 2 Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REQUIRED ACTION COMPLETION TIME D.1 Estimate the flow rate of Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the release. during releases AND D.2 Restore channel to 30 days FUNCTIONAL status. E.1 Obtain grab samples from Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months effluent pathway. during releases AND E.2 Perform an analysis of Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of grab samples for . obtaining the sample radioactivity.

AND E.3 Restore channel to 30 days FUNCTIONAL status. (continued) 16.11-7-3 Revision 9 Page 9-41 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual REMEDIAL ACTIONS (continued)

CONDITION F. Noble Gas Activity Monitor (EMF-39 -Low Range) providing automatic termination of release via the Containment Purge Exhaust System (CPES) non-functional.

G. Required Action and associated Completion Time of Condition F not met. OR Required Action F.1 not utilized.

Catawba Units 1 and 2 Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REQUIRED ACTION COMPLETION TIME F.1 -------------N 0 TE--------------

In order to utilize Required Action F.1, the following conditions must be satisfied:

1. The affected unit is in MODES 5 or6. 2. EMF-36 is FUNCTIONAL and in service for the affected unit. 3. The Reactor Coolant System for the affected unit has been vented. 4. Either the reactor vessel head is in place (bolts are not required), or if it is not in place, the lifting of heavy loads over the reactor vessel and the movement of irradiated fuel assemblies within containment have been suspended.

Restore the non-functional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months channel to FUNCTIONAL status. G.1 Suspend PURGING of Immediately radioactive effluents via this pathway. (continued) 16.11-7-4 Revision 9 Page 9-42 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REMEDIAL ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. One or more sampler H.1 Perform sampling with Continuously channel(s) non-auxiliary sampling functional.

equipment as required by Table 16.11-6-1.

AND H.2 Restore channel to 30 days FUNCTIONAL status. I. One Condenser 1.1 --------------N 0 TE-------------

Evacuation System Applicable to effluent Noble Gas Activity releases via the Condenser Monitor (EMF-33) Steam Air Ejector (ZJ) channel non-functional.

System. ------------------------------------

Obtain grab samples from Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months effluent pathway. during releases AND 1.2 --------------N 0 TE-------------

Applicable to effluent releases via the Condenser Steam Air Ejector (ZJ) System. ------------------------------------

Perform an analysis of Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of grab samples for obtaining the sample radioactivity.

AND (continued)

Catawba Units 1 and 2 16.11-7-5 Revision 9 Page 9-43 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual REMEDIAL ACTIONS CONDITION I. (continued)

J. Noble Gas Activity Monitor (EMF-39 -Low Range) providing automatic termination of release via the Containment Air Release and Addition System non-functional.

Catawba Units 1 and 2 Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REQUIRED ACTION COMPLETION TIME 1.3 --------------NOTE-------------

Applicable to effluent releases via the Steam Generator Slowdown (88) System atmospheric vent valve (88-27) in the off-normal mode. --.. ---------------------------------

Perform an analysis of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months grab samples for during releases radioactivity at a lower limit when secondary of detection of 10-7 specific activity is > microCurie/ml.

0.01 microCurie/gm DOSE EQUIVALENT 1-131 AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during releases when secondary specific activity is :=_ 0.01 microCurie/gm DOSE EQUIVALENT 1-131 AND 1.4 Restore channel to 30 days FUNCTIONAL status. J.1 Verify that EMF-36 is Prior to initiating a FUNCTIONAL.

release OR J.2.1 Analyze two independent Prior to initiating a samples of the release containment atmosphere.

AND (continued) 16.11-7-6 Revision 9 Page 9-44 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual REMEDIAL ACTIONS CONDITION J. (continued)

Catawba Units 1 and 2 Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REQUIRED ACTION J.2.2 Perform independent verification of the discharge line valving. J.2.3.1 Perform independent verification of manual portion of the computer input for release rate calculations performed by computer.

J.2.3.2 Perform independent verification of entire calculations for release rate calculations performed manually.

AND J .2 .4 lf channel remains or is anticipated to remain functional for.::_ 90 days, re-evaluate the configuration of the affected unit in accordance with the applicable portions of 10 CFR 50.59 and 10 CFR 50.65(a)(4) prior to expiration of the 90-day period. Restore channel to FUNCTIONAL status. 16.11-7-7 COMPLETION TIME Prior to initiating a release Prior to initiating a release Prior to initiating a release 30 days (continued)

Revision 9 Page 9-45 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 REMEDIAL ACTIONS (continued)

K. CONDITION Required Action and associated Completion Time of Condition C, D, E, F, H, I, or J not met. TESTING REQUIREMENTS K.1 REQUIRED ACTION Explain why the functionality was not corrected within the specified Completion Time. COMPLETION TIME In the next scheduled Radioactive Effluent Release Report pursuant to Technical Specification 5.6.3 --------------------------------------------------------NOTE--------------------------------------------------------

R efer to Table 16.11-7-1 to determine which TRs apply for each Radioactive Gaseous Effluent Monitoring Instrumentation channel. TEST TR 16.11-7-1 Perform CHANNEL CHECK. TR 16.11-7-2

NOTE---------------------------------

For Instruments 1 a, 4, and 5, a SOURCE CHECK for these channels shall be the qualitative assessment of channel response when the channel sensor is exposed to a light-emitting diode. Perform SOURCE CHECK. TR 16.11-7-3 Perform CHANNEL CHECK. TR 16.11-7-4 Perform CHANNEL CHECK. TR 16.11-7-5 Perform CHANNEL CHECK. Catawba Units 1 and 2 16.11-7-8 FREQUENCY Prior to each release Prior to each release 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 24 hours 7 days (continued)

Revision 9 Page 9-46 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 TESTING REQUIREMENTS (continued)

TEST TR 16. 11-7 --------------------------------N 0 TE---------------------------------

F or Instruments 2 and 3a, a SOURCE CHECK for these channels shall be the qualitative assessment of channel response when the channel sensor is exposed to a emitting diode. Perform SOURCE CHECK. TR 16.11-7-7 ---------------------------------NOTE---------------------------------

For Instruments 1 a, 2, 3a, 3c, 5, and 6a, the COT shall also demonstrate, as applicable, that auto!Tlatic isolation of this pathway and control room alarm annunciation (for EMF-58, alarm annunciation is in the Monitor Tank Building control room and on the Monitor Tank Building control panel remote annunciator panel) occur if any of the following conditions exist: a. Instrument indicates measured levels above the Alarmrrrip Setpoint, or b. Circuit failure/instrument downscale failure (alarm only) Perform COT. TR 16.11-7-8

NOTE---------------------------------

For Instrument 4, the COT shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exist:

a. Instrument indicates measured levels above the Alarmrrrip Setpoint, or b. Circuit failure/instrument downscale failure (alarm only) Perform COT. Catawba Units 1 and 2 16.11-7-9 FREQUENCY 31 days 9 months 18 months (continued)

Revision 9 Page 9-47 i(_ Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 TESTING REQUIREMENTS continued TEST TR 16 .11-7-9 ---------------------------------NOTE---------------------------------

F or Instruments 1 a, 2, 3a, 3c, 4, 5, and 6a, the initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used. Perform CHANNEL CALIBRATION.

Catawba Units 1 and 2 16.11-7-10 FREQUENCY 18 months Revision 9 Page 9-48 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 Table 16.11-7-1 Radioactive Gaseous Effluent Monitoring Instrumentation (page 1 of 2) INSTRUMENT REQUIRED CONDITIONS APPLICABLE TESTING CHANNELS MODES REQUIREMENTS

1. Waste Gas Holdup System 1.a Noble Gas Activity Monitor-Providing 1 per station A,C,K At all times except TR 16.11-7-1 Alarm and Automatic Termination of when the isolation TR 16.11-7-2 Release valve is closed and TR 16.11-7-7 (EMF-50 -Low Range) Jocked TR 16.11-7-9 1.b Effluent System Flow Rate Measuring 1 per station D,K At all times except TR 16.11-7-1 Device when the isolation TR 16.11-7-9 valve is closed and Jocked 2. Condenser Evacuation System Noble A,l,K When air ejectors TR 16.11-7-3 Gas Activity Monitor are in operation TR 16.11-7-6 (EMF-33) (BB-27 is only isolation (Apply Required TR 16.11-7C7 function required) (Note 1) Action 1.3 when air TR 16.11-7-9 ejectors are not in operation)

3. Vent System 3.a Noble Gas Activity Monitor A,E,K Al all times TR 16.11-7-4 (EMF-36 -Low Range) TR 16.11-7-6 TR 16.11-7-7 TR 16.11-7-9 3.b Deleted. 3.c Particulate Sampler A,H,K At all limes TR 16.11-7-4 (EMF-35) (Note2) TR 16.11-7-6 TR 16.11-7-7 TR 16.11-7-9

_;3.d Unit Vent Stack Flow Rate Meter D,K At all times TR 16.11-7-4 (no alarm/trip function) (Note2) TR 16.11-7-9 3.e Unit Vent Radiation Monitor Flow Meter 1 E,K At all times TR 16.11-7-4 (Note2) TR 16.11-7-9

4. Containment Purge System Noble Gas A, F, G, K 5,6 TR 16.11-7-2 Activity Monitor -Providing Alarm and TR 16.11-7-3 Automatic Termination of Release TR 16.11-7-8 (EMF-39 -Low Range) TR 16.11-7-9 (continued)

Catawba Units 1 and 2 16.11-7-11 Revision 9 Page 9-49 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 Table 16.11-7-1 Radioactive Gaseous Effluent Monitoring Instrumentation (page 2 of 2) INSTRUMENT

5. Containment Air Release and Addition System Noble Gas Activity Monitor -Providing Alarm and Automatic Termination of Release (EMF-39 -Low Range) 6. Monitor Tank Building HVAC 6.a Noble Gas Activity Monitor-Providing Alarm (EMF-58 -Low Range) 6.b Effiuent Flow Rate Measuring Device REQUIRED CHANNELS 1 per station* 1 per station CONDITIONS A,J,K A,E,K D,K APPLICABLE MODES 1,2,3,4,5,6 At all times (Note 2) At all times (Note2) Note 1: The setpoint is as required by the primary to secondary leak rate monitoring program. TESTING REQUIREMENTS TR 16.11-7-2 TR 16.11-7-3 TR 16.11-7-7 TR 16.11-7-9 TR 16.11-7-4 TR 16.11-7-6 TR 16.11-7-7 TR 16.11-7-9 TR 16.11-7-4 TR 16.11-7-9 Note 2: Except when the effluent pathway is mechanically isolated; thus, a release to the environment is not possible.

Catawba Units 1 and 2 16.11-7-12 Revision 9 Page 9-50 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/112015 -12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 The Radioactive Gaseous Effluent Monitoring Instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents.

The Alarmffrip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the Alarmffrip will occur prior to exceeding the limits of 10 CFR Part 20. The FUNCTIONALITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. The sensitivity of any noble gas activity monitor used to show compliance with the gaseous effluent release requirements of SLC 16.11-8 shall be such that concentrations as low as 1 x 10-6 µCi/cc are measurable.

Regarding Note 2 of Table 16.11-7-1, isolation of the effluent pathway is to be by mechanical means (e.g., valve closure).

Electrical or pneumatic isolation is not required, unless the isolation is designed to receive an automatic signal to open. In MODES 5 and 6, initiation of the Containment Purge Exhaust System (CPES) with EMF-39 non-functional is not permissible.

The basis for Required Action F .1 is to allow the continued operation of the CPES with EMF-39 initially FUNCTIONAL.

Continued operation of the CPES is contingent upon the ability of the affected unit to meet the requirements as noted in Required Action F .1. TR 16.11-7-7 requires the performance of a COT on the applicable Radioactive Gaseous Effluent Radiation Monitors.

The test ensures that a signal from the control room module can generate the appropriate alarm and actuations.

The required actuations/isolations for a High Radiation condition (i.e., radiation level above its Trip 2 setpoint) are listed below for each monitor. OEMF-50 -Waste Gas Discharge Monitor 1WG160 closes when EMF-50 detects radiation level above its setpoint.

1/2EMF-33

-Condensate Steam Air Ejector Exhaust Monitor The following ac!ualions occur when CMF-33 detects radiation level above its setpoint:

1. Closure of 8827 is required in order to isolate the Slowdown Tank from the environment.

Because of plant limitations/restrictions:

a. Opening the valve (in order to verify it goes closed on a High Radiation signal) is only possible during outages due to the negative effects on the Slowdown System with the unit at power. b. Testing during innages will be by verification of relay contacts opening in the valve circuit. 2. Closure of 8824, 8865, 8869, and 8873 is required to minimize the amount of potentially contaminated material being delivered to the Slowdown Tank. 3. Closure of NM269, NM270, NM271, and NM272 is required to minimize the amount of potentially contaminated material being delivered to the Conventional Sampling System. 4. Closure of NM267 is required to minimize the amount of potentially contaminated material being delivered to the Condensate Storage Tank by isolating flow through EMF-34. Catawba Units 1 and 2 16.11-7-13 Revision 9 Page 9-51 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 BASES (continued)

5. Closure of 8848 is required to minimize the amount of potentially contaminated material being delivered from the Slowdown System discharge to the Turbine Building sump. 1/2EMF-36

-Unit Vent Noble Gas Monitor The following actuations occur when EMF-36 detects radiation level above its setpoint:

1. Containment Air Release and Addition System fans discharge to unit vent valve VQ10 closes. 2. Auxiliary Building unfiltered ventilation exhaust fans A and B stop. 3. Fuel Handling Ventilation Exhaust System (FHVES) exhaust trains align to the filter units. 4. (For 1 EMF-36 only) 1WG160 closes. 1/2EMF-35

-Unit Vent Particulate Monitor (Sampler)

The following actuations occur when EMF-35 detects radiation level above its setpoint:

1. Containment Air Release and Addition System fans discharge to unit vent valve VQ10 closes. 2. Auxiliary Building unfiltered ventilation exhaust fans A and B stop. 3. Fuel Handling Ventilation Exhaust System (FHVES) exhaust trains align to the filter units. 4. ((For 1EMF-35 only) 1WG160 closes. 1/2EMF-39

-Containment Noble Gas Monitor The following actuations occur when EMF-39 detects radiation level above its setpoint:

1. Signals are provided to both trains of the Solid State Protection System (SSPS) to initiate a CPES isolation.

This is verified by observing that Relays K615 in the SSPS A output cabinet and the SSPS B output cabinet are latched. 2. EMF-39 isolates the CPES without going through the SSPS by stopping CPES supply fans A and B, CPES exhaust fans A and B, and by closing the appropriate valves and dampers. 3. Containment Evacuation Alarm, unless the source range trip is blocked. OEMF-58 This monitor provides no control function.

TR 16.11-7-8 requires the performance of a COT on the Containment Noble Gas Monitor, 1/2EMF-39.

The test ensures that a signal from the control room module can generate the appropriate alarm and actuations. required actuations/isolations for a High Radiation condition (i.e., radiation level above its Trip 2 setpoint) are listed below. 1/2EMF-39

-Containment Noble Gas Monitor The following actuations occur when EMF-39 detects radiation level above its setpoint:

Catawba Units 1 and 2 16.11-7-14 Revision 9 Page 9-52 BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Radioactive Gaseous Effluent Monitoring Instrumentation 16.11-7 1. Signals are provided to both trains of the Solid State Protection System (SSPS) to initiate a Containment Air Release and Addition System isolation.

This is verified by observing that relays K615 in the SSPS Train A output cabinet and the SSPS Train B output cabinet are latched. 2. Containment Evacuation Alarm, unless the source range trip is blocked. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 20. Catawba Units 1 and 2 16.11-7-15 Revision 9 Page 9-53 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-8 Dose -Noble Gases Dose -Noble Gases 16.11-8 COMMITMENT The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-16-1 in SLC 16.11-16) shall be limited to the following:

a. During any calendar quarter: 5 mrad for gamma radiation and .:::_ 10 mrad for beta radiation, and b. During any calendar year: 1 O mrad for gamma radiation and .:::_ 20 mrad for beta radiation.

APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Calculated air dose from A.1 radioactive noble gases Prepare and submit a 30 days in gaseous effluents exceeding any of above limits. TESTING REQUIREMENTS TEST Special Report to the NRC -which identifies the causes for exceeding the limits, corrective actions taken to reduce releases, and actions taken to ensure that subsequent releases are within limits. TR 16.11-8-1 Determine dose contributions from noble gases in gaseous effluents for current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM. Catawba Units 1 and 2 16.11-8-1 FREQUENCY 31 days Revision 0 Page 9-54 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Dose -Noble Gases 16.11-8 This SLC is provided to implement the requirements of Sections 11.B, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The COMMITMENT implements the guides set forth in Section 11.B of Appendix I. The REMEDIAL ACTION statement provides the required operating flexibility and at the same time implement the guides set forth in -Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable".

The TESTING REQUIREMENTS implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The dose calculation methodology and parameters established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equations provided for determining the air doses at and beyond the SITE BOUNDARY are based upon the historical average atmospheric conditions.

This commitment applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared radwaste treatment systems are used by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactives waste producing units sharing the radwaste treatment system. For determining conformance to COMMITMENTS, these allocations from shared radwaste treatment systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. REFERENCES

t. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-8-2 Revision 0 Page 9-55 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Dose -lodine-131, lodine-133, Tritium, and Radioactive Material in Particulate Form 16.11-9 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-9 Dose -lodine-131, lodine-133, Tritium, and Radioactive Material in Particulate Form COMMITMENT The dose to a MEMBER OF THE PUBLIC from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives

> 8 days in gaseous effluents released, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-16-1 in SLC 16.11-16) shall be limited to the following:

a. During any calendar quarter: :::_ 7.5 mrem to any organ, and b. During any calendar year: :::_ 15 mrem to any organ. APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A Calculated dose from A.1 Prepare and submit a 30 days the release of lodine-131, lodine-133, tritium, and radioactive material in particulate form with half-lives > 8 days in gaseous effluents exceeding any of above limits. TESTING REQUIREMENTS Special Report to the NRC which identifies the causes for exceeding the limits, corrective actions taken to reduce releases, and actions taken to ensure that subsequent releases are within limits. TEST TR 16.11-9-1 Determine cumulative dose contributions from lodine-131, lodine-133, tritium, and radioactive material in particulate form with half-lives

> 8 days in gaseous effluents for current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM. Catawba Units 1 and 2 16.11-9-1 FREQUENCY 31 days Revision 0 Page 9-56 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Dose -lodine-131, lodine-133, Tritium, and Radioactive Material in Particulate Form 16.11-9 This SLC is provided to implement the requirements of Sections 11.C, Ill.A and IV.A of Appendix I, 10 CFR Part 50, and are the guides set forth in Section 11.C of Appendix I. The REMEDIAL ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable".

The ODCM calculational methods specified in the TESTING REQUIREMENTS implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions.

The release rate COMMITMENTS for lodine-131, lodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the existing radionuclide pathways to man in the areas at and beyond the SITE BOUNDARY.

The pathways that were examined in the development of the calculations were: (1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas "'."here milk animals and meat-producing animals graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure of man. This commitment applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared radwaste treatment systems are used by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the radwaste treatment system. For determining conformance to COMMITMENTS, these allocations from shared radwaste treatment systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-9-2 Revision 0 Page 9-57 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Gaseous Radwaste Treatment System 16.11-10 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-10 Gaseous Radwaste Treatment System COMMITMENT The VENTILATION EXHAUST TREATMENT SYSTEM and the WASTE GAS HOLDUP SYSTEM shall be FUNCTIONAL and appropriate portions of these systems shall be used to reduce releases of radioactivity when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-16-1 in SLC 16.11-16)would exceed either: a. 0.2 mrad to air from gamma radiation, or b. 0.4 mrad to air from beta radiation, or c. 0.3 mrem to any organ of a MEMBER OF THE PUBLIC. APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Radioactive gaseous A.1 waste being discharged without treatment and in excess of above limits. REQUIRED ACTION COMPLETION TIME Prepare and submit a 30 days Special Report to the NRC which identifies non-functional equipment and .. reasons for non-functionality, actions taken to restore the equipment to FUNCTIONAL status, and actions taken to prevent recurrence.

Catawba Units 1 and 2 16.11-10-1 Revision 1 Page 9-58 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Gaseous Radwaste Treatment System 16.11-10 TESTING REQUIREMENTS

N 0 TE--------------------------------------------------------

Th e installed VENTILATION EXHAUST TREATMENT SYSTEM and WASTE GAS HOLDUP SYSTEM shall be demonstrated FUNCTIONAL by meeting SLC 16.11-6, SLC 16.11-8, and SLC 16.11-9. TEST FREQUENCY TR 16.11-10-1 Project gaseous release doses from each unit to areas 31 days BASES at and beyond the SITE BOUNDARY, in accordance with the methodology and parameters in the ODCM, when Gaseous Radwaste Treatment Systems are not being fully utilized.

The FUNCTIONALITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

This COMMITMENT implements the requirements of 10 GFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives given in Section 11.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections 11.B and 11.C of Appendix I, 1 O CFR Part 50, for gaseous effluents.

This SLC applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared radwaste treatment systems are used by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the radwaste treatment system. For determining conformance to COMMITMENTS, these allocations from shared radwaste treatment systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. Catawba Units 1 and 2 16.11-10-2 Revision 1 Page 9-59 REFERENCES Catawba Units 1 and 2 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual 1. Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Gaseous Radwaste Treatment System 16.11-10 Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix I. 16.11-10-3 Revision 1 Page 9-60 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Solid Radioactive Wastes 16.11-11 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-11 Solid Radioactive Wastes COMMITMENT Radioactive wastes shall be processed and packaged to ensure compliance with the applicable requirements of 10 CFR Part 20, 10 CFR Part 61, 1 O CFR Part 71, and state regulations governing the transportation and disposal of radioactive wastes. The Solid Radwaste System or an approved alternative process shall be used in accordance with the PROCESS CONTROL PROGRAM for the solidification of liquid or wet radioactive wastes or the dewatering of wet radioactive wastes to be shipped for direct disposal at a 10 CFR Part 61 licensed disposal site. Wastes shipped for offsite processing in accordance with the processor's specifications and transportation requirements are not required to be solidified or dewatered to meet disposal requirements.

APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Applicable regulatory requirements for solidified or dewatered wastes not satisfied.

Catawba Units 1 and 2 A.1 REQUIRED ACTION Suspend shipment of inadequately processed waste. A.2 Take action to correct the PROCESS CONTROL PROGRAM, procedures, or solid waste equipment as necessary to prevent recurrence.

16.11-11-1 COMPLETION TIME Immediately Prior to next 1 shipment for dispos of solidified or dewatered wastes (continued)

Revision 1 Page 9-61 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Solid Radioactive Wastes 16.11-11 REMEDIAL ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Solidification test as B.1 Suspend solidification of Immediately described in the the batch under test and PROCESS CONTROL follow PROCESS PROGRAM fails to CONTROL PROGRAM verify solidification.

guidance for test failures.

AND B.2 --------------N 0 TE-------------

Once a subsequent test verifies solidification, solidification of the batch may be resumed as directed by the PROCESS CONTROL PROGRAM. ------------------------------------

Modify the PROCESS Prior to next CONTROL PROGRAM as solidification for required to assure shipment of waste solidification of subsequent for disposal at a 10 batches of waste. CFR Part 61 disposal site C. Solidification or C.1 Reprocess the waste in Prior to shipment for dewatering for disposal accordance with disposal of the not performed in PROCESS CONTROL inadequately accordance with the PROGRAM requirements.

processed waste tha PROCESS CONTROL requires solidificatior PROGRAM. OR or dewatering C.2 Follow PROCESS Prior to shipment for CONTROL PROGRAM or disposal of the procedure guidance for inadequately alternative free-standing processed waste tha liquid verification to ensure requires solidificatior the waste in each or dewatering container meets disposal requirements and take appropriate administrative action to prevent recurrence. (continued)

Catawba Units 1 and 2 16.11-11-2 Revision 1 Page 9-62 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 REMEDIAL ACTIONS (continued)

Solid Radioactive Wastes 16.11-11 CONDITION REQUIRED ACTION COMPLETION TIME D. Solid waste equipment incapable of supporting COMMITMENT.

D.1 OR D.2 Restore the equipment to a status capable of supporting COMMITMENT.

Provide for alternative capability to process wastes as necessary to satisfy all applicable transportation and disposal requirements.

In a time frame supporting COMMITMENT In a time frame supporting COMMITMENT TESTING REQUIREMENTS TEST FREQUENCY TR 16.11-11-1 Verify, using the PROCESS CONTROL PROGRAM, the solidification of at least one representative test specimen *trom*atleastevery tenth batch of each type of radioactive waste to be solidified for disposal at a 10 CFR Part 61 disposal site. Every tenth batch of each type of radioactive waste to be solidified BASES This SLC implements the requirements of 1 O CFR Part 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50 and requirements to use a PROCESS CONTROL PROGRAM to meet applicable 10 CFR Part 61 waste form criteria for solidified and dewatered radioactive wastes.

The PROCESS CONTROL PROGRAM describes administrative and operational controls used for the solidification of liquid or wet solid radioactive wastes in order to meet applicable 1 O CFR Part 61 waste form requirements.

The PROCESS CONTROL PROGRAM describes the administrative and operational controls used for the dewatering of wet radioactive wastes to meet 10 CFR Part 61 free-standing water requirements.

The process parameters used in establishing the PROCESS CONTROL PROGRAM shall be based on demonstrated processing of actual or simulated liquid or wet solid wastes and must adequately verify that the final product of solidification or dewatering meets all applicable federal, state, and disposal site requirements.

Catawba Units 1 and 2 16.11-11-3 Revision 1 Page 9-63 REFERENCES Catawba Units 1 and 2 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual 1. Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Solid Radioactive Wastes 16.11-11 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." 2. 10 CFR Part 50, Appendix A. 3. 10 CFR Part 20, "Standards for Protection Against Radiation." 4. 10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste." 5. 10 CFR Part 71, "Packaging and Transportation of Radioactive Materials." 6. PROCESS CONTROL PROGRAM Manual. 7. Generic Letter 84-12, "Compliance with 10 CFR Part 61 and Implementation of the Radiological Effluent Technical Specifications (RETS) and Attendant Process Control Program (PCP)." ' 8. Generic Letter 89-01, "Implementation of Programmatic Controls for Radiological Effluent Technical Specifications 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." 16.11-11-4 Revision 1 Page 9-64 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Total Dose 16.11-12 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-12 Total Dose COMMITMENT The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to .:::. 25 mrem to the whole body or any organ, except the thyroid, which shall be limited to.:::. 75 mrem. APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Calculated doses from A.1 Verify, by calculation, that the cumulative dose from direct radiation contributions and outside storage tanks and radioactivity releases are within the total dose limit. Immediately releases exceeding twice the specified limits of SLC 16.11-3, SLC 16.11-8, orSLC 16.11-9. Catawba Units 1 and 2 AND A. 2 --------------N 0 TE-------------

0 n ly required to be performed if the total dose limit is exceeded.

Prepare and submit a 30 days Special Report to the NRC which identifies corrective actions to be taken to reduce subsequent releases to prevent recurrence and schedule for achieving conformance with specified limits. 16.11-12-1 Revision O Page 9-65 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Total Dose 16.11-12 TESTING REQUIREMENTS

N 0 TE------------------------------------"-------------------

C um u I ative dose contributions from liquid and gaseous effluents shall be determined in accordance with SLC 16.11-3, SLC 16.11-8, and SLC 16.11-9, and in accordance with the methodology and parameters specified in the ODCM. TEST FREQUENCY TR 16.11-12-1 Determine cumulative dose contributions from direct radiation from the units and from radwaste storage tanks in accordance with the methodology and parameters specified in the ODCM. When calculated doses from effluent releases exceed twice the limits of SLC 16.11-3, SLC 16.11-8, orSLC 16.11-9 BASES This SLC is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The SLC requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and to radiation from uranium fuel cycle sources exceed 25 mrem to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem .. For sites containing up *to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the _individual reactors remain within twice the dose design objectives of Appendix I, and if direct radiation doses from the units and from outside storage tanks are kept small. This Special Report, as defined in 10 CFR 20.2203(a)(4), shall include an a-rialysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release(s) covered by this* report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations.

The Special Report will describe a course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered.

Catawba Units 1 and 2 16.11-12-2 Revision 0 Page 9-66 BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Total Dose 16.11-12 If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 and 10 CFR 20.2203(a){4), is considered to be a timely request and fulfills the requirements of 40 CFR Part 190 and a variance is granted until NRC staff action is completed.

The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in SLC 16.11-1 and SLC 16.11-6. An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle. REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 20. 3. 40 CFR Part 190. Catawba Units 1 and 2 16.11-12-3 Revision 0 Page 9-67 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-13 Monitoring Program Monitoring Program 16.11-13 COMMITMENT The Radiological Environmental Monitoring Program shall be conducted as specified in Table 16.11-13-1.

APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Radiological A.1 Identify the reasons for not In the next Environmental conducting the program as scheduled Annual Monitoring Program not required and the plans for Radiological being conducted as preventing a recµrrence in Environmental specified in Table 16.11-the Annual Radiological Operating Report 13-1. Environmental Operating pursuant to Report. Technical Specification 5.6.2 B. Radioactivity level B.1 Prepare and submit a 30 days resulting from plant Special Report that effluents of identifies the cause(s} for environmental sampling exceeding the limits and medium at a specified defines the corrective location in excess of actions to be taken to reporting limits of Table reduce radioactive 16.11-13-2 when effluents so that the averaged over any potential annual dose to a calendar quarter. MEMBER OF THE PUBLIC is less than the calendar year limits of SLC 16.11-3, SLC 16.11-8, and SLC 16.11-9. (continued)

Catawba Units 1 and 2 16.11-13-1 Revision 1 Page 9-68 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 REMEDIAL ACTIONS (continued)

C. CONDITION Milk or fresh leafy C.1 vegetation samples unavailable from one or more sample location(s) required by Table 16.11-13-1. AND C.2 REQUIRED ACTION --------------N 0 TE-------------

S p ecifi c location(s) from which samples were unavailable may be deleted from the program. Revise the Radiological Environmental Monitoring Program to identify location(s) for obtaining replacement samples. Identify the cause of the unavailability of samples and identify and justify new location(s) for obtaining replacement samples in the Annual Radioactive Effluent Release Report and also include in the report a revised figure(s) and table for the ODCM reflecting the new location(s).

TESTING REQUIREMENTS TEST TR 16.11-13-1---------------------------------NOTE---------------------------------

The maximum values for the lower limits of detection shall be as specified in Table 16.11-13-3.

Collect and analyze radiological environmental monitoring samples pursuant to Table 16.11-13-1 from the specific locations given in the table and figure(s) in the ODCM. Catawba Units 1 and 2 16.11-13-2 Monitoring Program 16.11-13 COMPLETION TIME 30 days In the next scheduled Annual Radioactive Effluent Release Report pursuant to Technical Specification

5.5.1 FREQUENCY

In accordance with Table 16.11-13-1 Revision 1 Page 9-69 Table 16.11-13-1 Radiological Environmental Monitoring Program (page 1 of 7) EXPOSURE PATHWAY AND/OR NUMBER OF REPRESENTATIVE SAMPLING AND COLLECTION SAMPLE SAMPLES AND SAMPLE FREQUENCY LOCATIONs<

1 l 1. Direct Radiation<

2 l Forty routine monitoring stations Quarterly either with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, placed as follows: An inner ring of stations, one in each meteorological sector in the general area of the SITE BOUNDARY; An outer ring of stations, one in each meteorological sector in the 6-to 8-km range from the site; and The balance of the stations to be placed in special interest areas such as population centers, nearby residences, schools, and in one or two areas to serve as control stations.

Catawba Units 1 and 2 16.11-13-3 Monitoring Program 16.11-13 TYPE AND FREQUENCY OF ANALYSIS Gamma dose quarterly (continued)

Revision 1 en c 3 3 Dl -< 0 0 -0 Dl :::; "U o; Dl CD ;!: :::i ::::::!. C" co 0 Dl CD 0. z "' _. c C) )> 9=:::: i\:j CD CD Dl 0 Dl og. ..., @l 3 ' Dl -*CD NB--:::i CD -c;;:::i 0 co _. c 0 "' i\3 2. CD 0 01 _. Dl Sia 0 c "' 6" :::i s: Dl :::i c !!!.

"U "' cc CD <D EXPOSURE PATHWAY AND/OR SAMPLE 2. Airborne Radioiodine and Particulates Catawba Units 1 and 2 Table 16.11-13-1 Radiological Environmental Monitoring Program (page 2 of 7) NUMBER OF REPRESENTATIVE SAMPLING AND COLLECTION SAMPLES AND SAMPLE FREQUENCY LOCATIONs<

1 l Samples from five locations.

Continuous sampler operation with sample collection weekly, or more frequently if required by dust Three samples from close to the loading. three SITE BOUNDARY locations, in different sectors, of the highest calculated annual average ground-level D/Q; One sample from the vicinity of a community having the highest calculated annual average ground-level D/Q; and One sample from a control location, as for example 15 to 30 km distant and in the least prevalent wind direction.

16.11-13-4 Monitoring Program 16.11-13 TYPE AND FREQUENCY OF ANALYSIS Radioiodine Canister:

1-131 analysis weekly. Particulate Samgler: Gross beta radioactivity analysis following filter change; <3> and gamma isotopic analysis <4> of composite (by location) quarterly. ( contrn ued) Revision 1 en c: 3 3 "' -< Q, 0 0 "' ::r "U o; "' CD :ii: :::i :::!. 0-cc 0 "' CD c.z en ...... c: 0 )> =:i: Q. :T:::::: j\; CD CD a> o§. o; fQ iifl3 ' "' -*CD __.. e. -:::i "'0 CD --:::i O<D 0 -:::i en "'-* CD en 0 (11 ...... "' Qo 0 c: "' O" :::i :s:: "' :::i c:

-u Cll co CD <D EXPOSURE PATHWAY AND/OR SAMPLE 3. Waterborne

a. Surface<5 l b. Ground c. Drinking d. Sediment from Shoreline Catawba Units 1 and 2 Table 16.11-13-1 Radiological Environmental Monitoring Program (page 3 of 7) NUMBER OF REPRESENTATIVE SAMPLING AND COLLECTION SAMPLES AND SAMPLE FREQUENCY LOCATIONs<

1 l One sample upstream.

Composite sample over 1-month One sample downstream.

period <5>_ Samples from one or two sources only if likely to be affected<7>. Quarterly One sample of each of one to Composite sample over 2-week three of the nearest water supplies period <5> when 1-131 analysis is that could be affected by its performed; monthly composite discharge.

otherwise.

One sample from a control location.

One sample from downstream Semiannually area with existing or potential recreational value. 16.11-13-5 Monitoring Program 16.11-13 TYPE AND FREQUENCY OF ANALYSIS Gamma isotopic analysis <4 J monthly. Composite for tritium analysis quarterly.

Gamma isotopic <4 l and tritium analysis quarterly.

1-131 analysis on each composite when the dose calculated for the consumption of the water is greaterthan 1 mrem peryear<8>. Composite for gross beta and gamma isotopic analyses <4> monthly. Composite for tritium analysis quarterly.

Gamma isotopic analysis <4> semiannually. (continued)

Revision 1 (/) c: 3 3 Cll -< 0 0 -0 ::r -u Cll Cll CD :IE :::i ::::!. C" co 0 Cll CD c.z en ...... c: Ci )> ::r ::::;: j\;; CD CD Cll o°' og. ' Cll __.. e. -:::i 1\)0 CD --:::i oco 0 -:::i en I\)-* CD 0 01 ...... Cll Ro n c: I\) §l: c;* :::i s Cll :::i c: !!!.

Table 16.11-13-1 Radiological Environmental Monitoring Program (page 4 of 7) EXPOSURE PATHWAY AND/OR NUMBER OF REPRESENTATIVE SAMPLING AND COLLECTION SAMPLE SAMPLES AND SAMPLE FREQUENCY LOCATIONs<

1 J 4. Ingestion

a. Milk Samples from milking animals in Semimonthly when animals are on three locations within 5-km pasture; monthly at other times. distance having the highest dose potential.

If there are none, then one sample from milking animals in each of three areas between 5 to 8 km distant where doses are calculated to be preater than 1 mrem per year <5. One* sample from milking animals at a control location 15 to 30 km distant and in the least prevalent wind direction.

b. Fish and Invertebrates One sample each of a predatory Sample in season, or species, a bottom feeder and a semiannually if they are not forage species in vicinity of plant seasonal.

discharge area. One sample each of a predatory species, a bottom feeder and a forage species in areas not influenced by plant discharge.

Catawba Units 1 and 2 16.11-13-6 Monitoring Program 16.11-13 TYPE AND FREQUENCY OF ANALYSIS Gamma isotopic<4 J and 1-131 analysis semi-monthly when animals are on pasture; monthly at other times. Gamma isotopic analysis <4 J on edible portions. (continued)

Revision 1 "U "' ca m co EXPOSURE PATHWAY AND/OR SAMPLE 4. Ingestion (Continued)

c. Food Products Catawba Units 1 and 2 Table 16.11-13-1 Radiological Environmental Monitoring Program (page 5 of 7) NUMBER OF REPRESENTATIVE SAMPLING AND COLLECTION SAMPLES AND SAMPLE FREQUENCY LOCATIONs<

1> -One sample of each principal At time of harvest <9>. class of food products from any area that is irrigated by water in which liquid plant wastes have been discharged.

Samples of three different kinds of Monthly, when available.

broad leaf vegetation grown nearest each of two different offsite locations of highest predicted annual average ground level D/Q if milk sampling is not performed.

One sample of each of the similar Monthly, when available.

broad leaf vegetation grown 15 to 30 km distant in the least prevalent wind direction if milk sampling is not performed.

16.11-13-7 Monitoring Program 16.11-13 TYPE AND FREQUENCY OF ANALYSIS Gamma isotopic analyses <4> on edible portion. Gamma isotopic<4> and 1-131 analysis.

Gamma isotopic<4> and 1-131 analysis.

Revision 1 0 "' "U iii m :E ::::!. C" 0 "' c. z _.c :::;: (") -m "' "' a; ft.? ' "' ..... "'o -:J i\3 01 ...... S10 "' (/) c 3 3 "' -< 8. 0 :::r "' :J ca m en 0 )> =r= m "' 03-

-:J m-0 co 0 en m 0 "' 0 c ![ 5* :J s: "' :J c NOTES: Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Table 16.11-13-1 Monitoring Program 16.11-13 Radiological Environmental Monitoring Program (page 6 of 7) ( 1) Specific parameters of distance and direction sector from the centerline of the station, and additional description where pertinent, shall be provided for each and every sample location in Table 16.11-13-1 in a table and figure(s) in the ODCM. Refer to NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to circumstances such as hazardous conditions, seasonal unavailability, and malfunction of automatic sampling equipment.

If specimens are unobtainable due to sampling equipment malfunction, effort shall be made to complete corrective action prior to 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 Technical Specification 5.6.2. 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 any Licensee Event Report required by 10 CFR 50.73 and pursuant to Technical Specification 5.6.3, identify the cause of the unavailability of samples for that pathway and identify the new location(s) for obtaining replacement samples in the next Radioactive Effluent Release Report and also include in the report a revised figure(s) and table for the ODCM reflecting the new location(s).

(2) 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 thermoluminescent 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 40 stations is 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 within minimal fading.) (3) Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. Catawba Units 1 and 2 16.11-13-8 Revision 1 Page 9-75 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Table 16.11-13-1 Monitoring Program 16.11-13 Radiological Environmental Monitoring Program (page 7 of 7) (4) Gamma isotopic analysis means the identification and quantification of emitting radionuclides that may be attributable to the effluents from the facility.

(5) The "upstream sample" shall be taken at a distance beyond significant influence of the discharge.

The "downstream" sample shall be taken in an area beyond but near the mixing zone. "Upstream" samples in an estuary must be taken far enough upstream to be beyond the plant influence.

Salt water shall be sampled only when the receiving water is utilized for recreational activities.

(6) A composite sample is one in which the rate at which the liquid sampled is uniform and in which the method of sampling employed results in a specimen that is representative of the time-averaged concentration at the location being sampled. In this program composite sample aliquots shall be collected at time intervals that are very short (e.g., hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample. (7) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

(8) The dose shall be calculated for the maximum organ and age group, using the methodology and parameters in the ODCM. * (9) If harvest occurs more than once a year, sampling shall be performed during each discrete harvest. If harvest occurs continuously, sampling shall be monthly. Attention shall be paid to including samples of tuberous and root food products.

Catawba Units 1 and 2 16.11-13-9 Revision 1 Page 9-76 "U Ill cc (]) co --I ANALYSIS H-3 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-Nb-95 1-131 Cs-134 Cs-137 Ba-La-140 Table 16.11-13-2 Reporting Levels for Radioactivity Concentrations in Environmental Samples WATER AIRBORNE FISH MILK (pCi/I) PARTICULATE OR (pCi/kg, wet) (pCi/I) GASES (pCi/m 3) 20,000llJ 1,000 30,000 400 10,000 1,000 30,000 300 10,000 300 20,000 400 2 0.9 3 30 10 1,000 60 50 20 2,000 70 200 300 Monitoring Program 16.11-13 FOOD PRODUCTS (pCi/kg, wet) 100 1,000 2,000 (1) For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/I may be used. Catawba Units 1 and 2 16.11-13-10 Revision 1 en c:: 3 3 Ill -<

'"C Dl cc Cl> co .!..i O> ANALYSIS Gross Beta H-3 Mn-54 Fe-59 Co-58, 60 Zn-65 Zr-Nb-95 1-131 Cs-134 Cs-137 Ba-La-140 Catawba Units 1 and 2 WATER (pCi/1) 4 2000lOJ 15 30 15 30 15 1l4) 15 18 15 Table 16.11-13-3 Lower Limit of Detection (LLD)(3) (page 1 of 3) AIRBORNE FISH MILK PARTICULATE (pCi/kg, wet) (pCi/I) OR GASES (pCi/m 3) 0.01 130 260 130 260 0.07 1 0.05 130 15 0.06 150 18 15 16.11-13-11 FOOD PRODUCTS (pCi/kg, wet) 60 60 80 Monitoring Program 16.11-13 SEDIMENT (pCi/kg, dry) 150 180 Revision 1 en c: 3 3 Dl -< s. 0 0 Dl ::; '"C Di Dl Cl> ::: ::::::!. C" cc 0 Dl Cl> c.z "' c: s )> :::;: n --f\)CD ::; -Cl> Dl 0 Dl 0 g. ' Dl r::; g. Cl> --. 0 co 0 -. "' N -* Cl> en 0 en Dl Ro <> c: N ill g: $: Dl c: !!!.

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Monitoring Program 16.11-13 Table 16.11-13-3 Lower Limit of Detection (LLD)(3 l (page 2 of 3) NOTES: (1) This list does not mean that only these nuclides are to be considered.

Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2. (2) Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be in accordance with the recommendations of Regulatory Guide 4.13. (3) The LLD is defined, for purposes of these commitments, as the smallest concentrations of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system, which may include radiochemical separation:

LLD= (2.71/T)+4.65s 6 E

V

2.22 *Y *exp (-A-M) Where: LLD =the "a priori" lower limit of detection (picoCuries per unit mass or volume); sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute); E =the counting efficiency (counts per disintegration);

V =the sample size (units of mass or volume); 2.22 = the number of disintegrations per minute per picoCurie; Y =the fractional radiochemical yield, when applicable;

/..=the radioactive decay constant for the particular radionuclide (sec-1); = the elapsed time between environmental collection, or end of the sample collection period, and time of counting (sec); and T =the sample counting time (min). Catawba Units 1 and 2 16.11-13-12 Revision 1 I Page 9-79 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Table 16.11-13-3 Lower Limit of Detection (LLD)(3 l (page 3 of 3) Typical values of E, V, Y and shall be used in the calculation.

Monitoring Program 16.11-13 It should be recognized that the LLD is defined as an E. priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.

Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2. I (4) LLD for drinking water samples. If no drinking water pathway exists, the LLD of gamma isotopic analysis may be used. (5) If no drinking water pathway exists, a value of 3000 pCi/I may be used. Catawba Units 1 and 2 16.11-13-13 Revision 1 Page 9-80 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Monitoring Program 16.11-13 The Radiological.Environmental Monitoring Program required by this SLC provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the plant operation.

This Monitoring Program implementsSection IV.B.2 of Appendix I to 10 CFRPart 50 and thereby supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Guidance for this Monitoring Program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring.

The initially specified Monitoring Program will be effective for at feast the first 3 years of commercial operation.

Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table 16.11-13-3 are consider,ed optimum for routine environmental . measurements in industrial laboratories.

It should be recognized that the LLD is defined as an f! priori (before the fact) limit representing the capability of a measurement system and not as an.£! posteriori (after the fact) limit for a particular measurement.

With the level of radioactivity in an environmental sampling medium at a specified location exceeding the reporting levels of Table 16.11-13-2 when averaged over any calendar quarter, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days a Special Report that 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 SLC 16.11-3, SLC 16.11-8, and SLC 16.11-9. When more than one of the radionuclides in Table 16.11-13-2 are detected in the sampling mediuni, this report shall be submitted if: concentration (1) + concentration (2) + ... ;;::: 1 _0 reporting level (1) reporting level (2) When radionuclides other than those in Table 16.11-13-2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to a MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of SLC 16.11-3, SLC 16.11-8, and SLC 16. 11-9. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Technical Specification 5.6.2. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in the 30-day Special Report. Catawba Units 1 and 2 16.11-13-14 Revision 1 Page 9-81 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Monitoring Program 16.11-13 BASES (continued)

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, L.A., "Limits for Qualitative Detection and Quantitative Determination

-Application to Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J.K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-13-15 Revision 1 Page 9-82 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Land Use Census 16.11-14 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-14 Land Use Census COMMITMENT

N 0 TE-----------------------------------------

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 D/Qs in lieu of the garden census. Requirements for broad leaf vegetation sampling in Table 16.11-13-1(Item4c) shall be followed, including analysis of control samples. 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 nearest milk animal, the nearest residence, and the nearest garden of> 50 m 2 (500 ft 2) producing broad leaf vegetation.

APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Location(s) identified A.1 Identify the new location(s)

In the next which yield a calculated in the Annual Radioactive scheduled Annual dose or dose Effluent Release Report. Radioactive Effluent commitment greater Release Report than values currently pursuant to calculated in SLC 16.11-Technical

9. Specification 5.6.3 B. Location(s) identified B.1 Add the new location(s) to 30 days which yield a calculated the Radiological dose or dose Environmental Monitoring commitment (via same Program. exposure pathway) 20% greater than at a AND location from which samples are currently being obtained in accordance with SLC 16.11-13. (continued)

Catawba Units 1 and 2 16.11-14-1 Revision 0 Page 9-83 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Land Use Census 16.11-14 REMEDIAL ACTIONS CONDITION B. (continued)

B.2 REQUIRED ACTION Identify the new location(s), revised figure{s) and table(s) for the ODCM, and information supporting the change in sampling location(s) in the Annual Radioactive Effluent Release Report. COMPLETION TIME In the next scheduled Annual Radioactive Effluent Release Report pursuant to Technical Specification

5.5.1 TESTING

REQUIREMENTS TEST FREQUENCY TR 16.11-14-1---------------------------------NOTE---------------------------------

BASES The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report pursuant to Technical Specification

5.6.2. Conduct

a Land Use Census during the growing season 12 months using the information which will provide the best results such as a door-to-door survey, aerial survey, or consultation with local agricultural authorities.

This SLC is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made if required by the results of this census. The best information from the door-to-door survey, from aerial survey, or from consulting with local agricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 50 m 2 provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantify (26 kg/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: (1) 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and (2) a vegetation yield of 2 kg/m 2* Catawba Units 1 and 2 16.11-14-2 Revision 0 Page 9-84 BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Land Use Census 16.11-14 With a Land Use Census identifying a location(s) which yield a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with SLC 16.11-13, add the new location(s) within 30 days to the Radiological Environmental Monitoring Program given in the ODCM. The sampling location(s), excluding the control station location, having the lowest calculated dose or dose commitment, via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was conducted.

REFERENCES

1. Catawba Offsite Dose Calculation Manual. 2. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-14-3 Revision 0 Page 9-85 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 lnterlaboratory Comparison Program 16.11-15 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-15 lnterlaboratory Comparison Program COMMITMENT Analyses shall be performed on all radioactive materials, supplied as part of an lnterlaboratory Comparison Program, that correspond to samples required by SLC 16.11-13.

APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Analyses not being performed as required.

TESTING REQUIREMENTS A.1 TEST REQUIRED ACTION Report corrective actions taken to prevent recurrence in the Annual Radiological Environmental Operating Report. TR 16.11-15-1 Report a summary of the results of the lnterlaboratory Comparison Program in the Annual Radiological Environmental Operating Report. COMPLETION TIME In the next scheduled Annual Radiological Environmental Operating Report pursuant to Technical Specification

5.6.2 FREQUENCY

In the Annual Radiological Environmental Operating Report pursuant to Technical Specification

5.6.2 BASES

The requirement for participation in an lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50. Catawba Units 1 and 2 16.11-15-1 Revision 0 Page 9-86 BASES (continued)

Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 lnterlaboratory Comparison Program 16.11-15 The lnterlaboratory Comparison Program shall be described in the Annual Radiological Environmental Operating Report. REFERENCES

1. 10 CFR Part 50, Appendix I. Catawba Units 1 and 2 16.11-15-2 Revision 0 Page 9-87 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Annual Radiological Environmental Operating Report And Radioactive Effluent Release Report 16.11-16 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-16 Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report COMMITMENT Annual Radiological Environmental Operating Report Routine Annual Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 15 of each year. The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, with operational controls as appropriate, and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

The reports shall also include the results of the Land Use Census. The Annual Radiological Environmental Operating Reports shall include the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of thei;e analyses and measurements in the format of the table in the Radiological Asse!;sment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report. The reports shall also include the following:

a summary description of the Radiological Environmental Monitoring Program; at least two legible maps (one map_ shall cover stations near the SITE BOUNDARY, and a second map shall include the more distant stations) covering all sampling locations keyed to a table giving distances and directions*

from the centerline of one reactor; the results of licensee participation in the lnterlaboratory Comparison Program, required by SLC 16.11-15; discussion of all deviations from the

sampling schedule of Table 16.11-13-1; and discussion of all analyses in which the LLD required by Table 16.11-13-3 was not achievable.

A single submittal may be made for the station. (continued)

Catawba Units 1 and 2 16.11-16-1 Revision 1 Page 9-88 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual COMMITMENT (continued)

Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Annual Radiological Environmental Operating Report And Radioactive Effluent Release Report 16.11-16 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The Radioactive Effluent Release Report shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability. (In lieu of submission with the Radioactive Effluent Release Report, the licensee has the option of retaining this summary of required meteorological data on site in a file that shall be provided to the NRC upon request.)

This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. A five-year average of representative onsite meteorological data shall be used in the gaseous effluent dose pathway calculations.

Dispersion factors (X/Qs) and deposition factors (D/Qs) shall be generated using the computer code XOQDOQ (NUREG/CR-2919) which implements NRC Regulatory Guide 1.111. The meteorological conditions concurrent with the time of release shall be reviewed annually to determine if the five-year average values should be revised. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the ODCM. The Radioactive Effluent Release Report shall also include an assessment of radiation doses to the likely most exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycie sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conformance with 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev. 1, October 1977. The Radioactive Effluent Release Reports shall include the following information for each type of solid waste shipped offsite during the report period: (continued)

Catawba Units 1 and 2 16.11-16-2 Revision 1 Page 9-89 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Annual Radiological Environmental Operating Report And Radioactive Effluent Release Report 16.11-16 COMMITMENT (continued)

a. Total co.ntainer volume, in cubic meters, b. Total Curie quantity (determined by measurement or estimate), c. Principal radionuclides (determined by measurement or estimate), d. Type of waste (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms), e. Number of shipments, and f. Solidification agent or absorbent (e.g., cement or other approved agents (media)).

The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period. The Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the ODCM, as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the Land Use Census pursuant to SLC 16.11-14.

A single submittal may be made for the station. The submittal should combine those sections that are common to both units. APPLICABILITY:

At all times. REMEDIAL ACTIONS None TESTING REQUIREMENTS None BASES None REFERENCES None Catawba Units 1 and 2 16.11-16-3 Revision 1 Page 9-90 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual SITE BOUNDARY PERl;.fETE.R FENCE 2500 FT.* R. EXCLUSION BOUNDARY Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Annual Radiological Environmental Operating Report And Radioactive Effluent Release Report 16.11-16 Figure 16.11-16-1 UNRESTRICTED AREA and SITE BOUNDARY for Radioactive Effluents Catawba Units 1 and 2 16.11-16-4 Revision 1 Page 9-91 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Holdup Tanks 16.11-17 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-17 Liquid Holdup Tanks COMMITMENT The quantity of radioactive material contained in each temporary unprotected outdoor tank shall be limited to,::: 10 Curies, excluding tritium and dissolved or entrained noble gases. APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDITION Quantity of radioactive material in tank(s) exceeding limit. TESTING REQUIREMENTS A.1 REQUIRED ACTION Suspend all additions of radioactive material to the tank(s). COMPLETION TIME Immediately A.2 Reduce tank(s) contents to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months within limit. A.3 Describe the events leading to this condition in the Radioactive Effluent Release Report. In the next scheduled Radioactive Effluent Release Report pursuant to Technical Specification 5.6.3 TEST FREQUENCY TR 16.11-17-1 Verify that the quantity of radioactive material contained 7 days in each tank is within limits by analyzing a representative sample of the tank(s) contents when radioactive materials are being added to the tank(s). Catawba Units 1 and 2 16.11-17-1 Revision 0 Page 9-92 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Liquid Holdup Tanks 16.11-17 The tanks included in this SLC are all those outdoor radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system. Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting concentrations would be less than the limits of 10 CFR Part 20, Appendix 8, Table II, Column 2, at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA. REFERENCES

1. Letter from NRC to Gary R. Peterson, Duke, Issuance of Improved Technical Specifications Amendments for Catawba, September 30, 1998. 2. Technical Specification 5.5.12, Explosive Gas and Storage Tank Radioactivity Monitoring Program. Catawba Units 1 and 2 16.11-17-2 Revision 0 Page 9-93 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12131/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-18 Explosive Gas Mixture Explosive Gas Mixture 16.11-18 COMMITMENT The concentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be limited to ,:::. 2% by volume whenever the hydrogen concentration is > 4% by volume. APPLICABILITY:

At all times. REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Concentration of oxygen A.1 Reduce oxygen 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months in the WASTE GAS concentration to within HOLDUP SYSTEM > limits. 2% but,:::. 4% by volume and hydrogen concentration>

4% by volume. 8. Concentration of oxygen 8.1 Suspend all additions of Immediately in the WASTE GAS waste gases to the system. HOLDUP SYSTEM > 4% by volume and AND hydrogen concentration

> 4% by volume. 8.2 Reduce the concentration Immediately of oxygen to,:::. 4% by volume. AND 8.3 Reduce oxygen 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concentration to within limits. Catawba Units 1 and 2 16.11-18-1 Revision 1 Page 9-94 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Explosive Gas Mixture 16.11-18 TESTING REQUIREMENTS TEST FREQUENCY TR 16.11-18-1 Verify that the concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM are within limits by continuously monitoring the waste gases in the WASTE GAS HOLDUP SYSTEM with the hydrogen and oxygen monitors required FUNCTIONAL by SLC 16.11-20.

During WASTE GAS HOLDUP SYSTEM operation BASES This SLC is provided to ensure that the concentration of potentially explosive gas mixtures contained in the WASTE GAS HOLDUP SYSTEM is maintained below the flammability limits of hydrogen and oxygen. Automatic control features are included in the system to prevent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of hydrogen and/or oxygen, automatic diversion to recombiners, or injection of dilutants to reduce the concentration below the flammability limits. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50. REFERENCES

1. Letter from NRG to Gary R. Peterson, Duke, Issuance of Improved Technical Specifications Amendments for Catawba, September 30, 1998. Catawba Units 1 and 2 2. Technical Specification 5.5.12, Explosive Gas and Storage Tank Radioactivity Monitoring Program. 16.11-18-2 Revision 1 Page 9-95 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-19 Gas Storage Tanks Gas Storage Tanks 16.11-19 COMMITMENT The quantity of radioactivity contained in each gas storage tank shall be limited 97,000 Curies of noble gases (considered as Xe-133 equivalent).

APPLICABILITY:

At all times. REMEDIAL ACTIONS A. CONDfTION Quantity of radioactive material in tank(s) exceeding limit. TESTING REQUIREMENTS A.1 REQUIRED ACTION Suspend all additions of radioactive material to the tank(s). COMPLETION TIME Immediately A.2 Reduce tank(s) contents to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months within limit. A.3 Describe the events leading to this condition in the Radioactive Effluent Release Report. In the next scheduled Radioactive Effluent Release Report pursuant to Technical Specification 5.6.3 TEST FREQUENCY TR 16.11-19-1 Verify that the quantity of radioactive material contained 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in each tank is within limits when radioactive materials are being added to the tank{s). Catawba Units 1 and 2 16.11-19-1 Revision 0 Page 9-96 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gas Storage Tanks 16.11-19 The tanks included in this SLC are those tanks for which the quantity of radioactivity contained is not limited directly or indirectly by another SLC. Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting whole body exposure to a MEMBER OF THE PUBLIC at the nearest SITE BOUNDARY will not exceed 0.5 rem. This is consistent with Standard Review Plan 11.3, Branch Technical Position ETSB 11-5, "Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure," in NUREG-0800, July 1981. REFERENCES

1. Letter from NRC to Gary R. Peterson, Duke, Issuance of Improved Technical Specifications Amendments for Catawba, September 30, 1998. 2. Technical Specification 5.5.12, Explosive Gas and Storage Tank Radioactivity Monitoring Program. Catawba Units 1 and 2 16.11-19-2 Revision 0 Page 9-97 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015-12/31/2015 Explosive Gas Monitoring Instrumentation 16.11-20 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-20 Explosive Gas Monitoring Instrumentation COMMITMENT APPLICABILITY:

REMEDIAL ACTIONS The Explosive Gas Monitoring Instrumentation channels shown in Table 16.11-20-1 shall be FUNCTIONAL with their Alarm/Trip Setpoints set to ensure that the limits of SLC 16.11-18 are not exceeded.

During WASTE GAS HOLDUP SYSTEM operation.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare the channel(s)

Immediately Explosive Gas non-functional.

I Monitoring Instrumentation channel(s)

Alarm/Trip Setpoint less conservative than required.

B. One required hydrogen 8.1 Suspend oxygen supply to Immediately monitor channel non-the recombiner.

I functional.

AND 8.2 Restore channel to 30 days FUNCTIONAL status. I C. One required oxygen C.1 Obtain and analyze grab 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months monitor channel non-samples. I functional.

AND C.2 Restore channel to 30 days FUNCTIONAL status. I (continued)

Catawba Units 1 and 2 16.11-20-1 Revision 1 Page 9-98 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 REMEDIAL ACTIONS (continued)

Explosive Gas Monitoring Instrumentation 16.11-20 CONDITION REQUIRED ACTION COMPLETION TIME D. Two required oxygen D.1 Obtain and analyze grab Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months monitor channels non-samples. during degassing functional.

operations AND Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations AND D.2 Restore channels to 30 days FUNCTIONAL status. E. Required Action and E.1 Prepare and submit a 30 days associated Completion Special Report to the NRC Time of Condition B, C, to explain why the non-or D not met. functionality was not corrected within the time specified.

TESTING REQUIREMENTS

NOTE------------------------------------------------------

Refer to Table 16.11-20-1 to determine which TRs apply for each Explosive Gas Monitoring Instrumentation channel. TEST FREQUENCY TR 16.11-20-1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TR 16.11-20-2 Perform COT. 31 days I I I (continued)

Catawba Units 1 and 2 16.11-20-2 Revision 1 Page 9-99 Attachment 9 Summary of Changes to the Off site Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Explosive Gas Monitoring Instrumentation 16.11-20 TESTING REQUIREMENTS continued TEST TR The CHANNEL CALIBRATION shall include the use of standard gas samples in accordance with the manufacturer's recommendations.

In addition, a standard gas sample of nominal four volume percent hydrogen (for the hydrogen monitors) and four volume percent oxygen (for the oxygen monitors), with the balance nitrogen, shall be used in the calibration to check linearity of the analyzer.

Perform CHANNEL CALIBRATION.

Catawba Units 1 and 2 16.11-20-3 FREQUENCY 92 days Revision 1 Page 9-100 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Explosive Gas Monitoring Instrumentation 16.11-20 Table 16.11-20-1 Explosive Gas Monitoring Instrumentation INSTRUMENT WASTE GAS HOLDUP SYSTEM Explosive Gas Monitoring Instrumentation

1. Hydrogen Monitors 2. Oxygen Monitors Catawba Units 1 and 2 16.11-20-4 REQUIRED CHANNELS 1 /inservice train per station 2/inservice train _ per station TESTING REQUIREMENTS TR 16.11-20-1 TR 16.11-20-2 TR 16.11-20-3 TR 16.11-20-1 TR 16.11-20-2 TR 16.11-20-3 Revision 1 Page 9-101 BASES Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Explosive Gas Monitoring Instrumentation 16.11-20 The Explosive Gas Monitoring Instrumentation is provided for monitoring and controlling the concentrations of potentially explosive gas mixtures in the WASTE GAS HOLDUP SYSTEM. REFERENCES

1. Letter from NRC to Gary R. Peterson, Duke, Issuance of Improved Technical Specifications Amendments for Catawba, September 30, 1998. Catawba Units 1 and 2 16.11-20-5 Revision 1 Page 9-102 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Major Changes to Liquid, Gaseous, and Solid Radwaste Treatment Systems 16.11-21 16.11 RADIOLOGICAL EFFLUENTS CONTROLS 16.11-21 Major Changes to Liquid, Gaseous, and Solid Radwaste Treatment Systems COMMITMENT Licensee-initiated major changes to the Radwaste Treatment Systems (liquid, gaseous, and solid): 1. Shall be reported to the NRC in the Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the Station Manager. Licensees may choose to submit the information called for in this SLC as part of the periodic Updated Final Safety Analysis Report update. The discussion of each change shall contain: a. A summary of the evaluation that led to the determination that the change could be made in accordance with 1 O CFR 50.59; b. Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;

c. A detailed description of the equipment, components, and processes involved and the interfaces with other plant systems; d. An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; e. An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto; f. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made; g. An estimate of the exposure to plant operating personnel as a result of the change; and (continued)

Catawba Units 1 and 2 16.11-21-1 Revision 0 Page 9-103 Attachment 9 Summary of Changes to the Offsite Dose Calculation Manual f Catawba Nuclear Station Units 1 & 2 Period 111/2015-12/31/2015 Major Changes to Liquid, Gaseous, and Solid Radwaste Treatment Systems 16.11-21 COMMITMENT (continued)

h. Documentation of the fact that the change was reviewed and found acceptable by the Station Manager or the Chemistry Manager. 2. Shall become effective upon review and acceptance by a qualified individual/organization.

APPLICABILITY:

At all times. REMEDIAL ACTIONS None TESTING REQUIREMENTS None BASES None REFERENCES

1. Catawba Units 1 and 2 Letter from NRC to Gary R. Peterson, Duke, Issuance of Improved Technical Specifications Amendments for Catawba, September 30, 1998. 16.11-21-2 Revision 0 Page 9-104 Attachment 10 Summary of Changes to the Process Control Program Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 10 Summary of Changes to the Process Control Program This attachment includes a summary of changes to the PCP. Page 10-1 J Attachment 10 Summary of Changes to the Process Control Program \ Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 The Catawba Nuclear Station PCP was not revised in 2015. The most recent revision was provided with the Catawba Nuclear Station 2014 ARERR. Page 10-2 Attachment 11 Summary of Major Modifications to the Radioactive Waste Treatment Systems Catawba Nuclear Station Units 1 & 2

Period 1/1/2015 -12/31/2015 ATTACHMENT 11 Summary of Major Modifications to the Radioactive Waste Treatment Systems This attachment includes a description of major modifications to the radioactive waste treatment systems that areanticipated to affect effluent releases.

Page 11-1 Attachment 11 Summary of Major Modifications to the Radioactive Waste Treatment Systems Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 No major modifications to the Catawba Nuclear Station liquid, gaseous, solid, or mobile radioactive waste treatment systems occurred in 2015. Page 11-2 Attachment 12 Errata to a Previous Year's ARERR Example Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 12 Errata to a Previous Year's ARERR This attachment includes any amended pages from a previous year's ARERR. Page 12-1 Attachment 12 Errata to a Previous Year's ARERR Example Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 There are no changes to a previous year's ARERR. . Page 12-2 el_-,DUKE ENERGYai CNS-16-029 April 28, 2016 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555

Subject:

Duke Energy Carolinas, LLC Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 2015 Annual Radioactive Effluent Release Report Kelvin Henderson Vice President Catawba Nuclear Station Duke Energy CN01VP 14800 Concord Road York, SC 29745 o: 803.701.4251 f: 803. 701.3221 Pursuant to Catawba Nuclear Station Technical Specification (TS) 5.6.3 and Selected Licensee Commitment 16.11-16, please find attached the Annual Radioactive Effluent Release Report for the period of January 1, 2015, through December 31, i015. In accordance with Catawba TS 5.5.1, the Offsite Dose Calculation Manual (ODCM) is included in this submittal.

Attachment 1 Attachment 2 Attachment 3 Attachment 4 Attachment 5 Attachment 6 Attachment 7 Attachment 8 Attachment 9 Summary of Gaseous and Liquid Effluents Supplemental Information Solid Radioactive Waste Disposal Meteorological Data Unplanned Offsite Releases Assessment of Radiation Dose from Radioactive Effluents to Members of the Public Information to Support the NEI Groundwater Protection Initiative Inoperable Equipment Summary of Changes to the Offsite Dose Calculation Manual United States Nuclear Regulatory Commission Page 2 April 28, 2016 Attachment 10 Summary of Changes to the Process Control Program Attachment 11 Summary of Major Modifications to the Radioactive Waste Treatment

Attachment 12 Errata to a Previous Year's ARERR Enclosed:

2015 Offsite Dose Calculation Manual (Compact Disc) Any questions concerning this report should be directed to Cecil A. Fletcher II, Nuclear Regulatory Affairs Manager, at (803) 701-3622.

Sincerely, Kelvin Henderson Vice President, Catawba Nuclear Station Attachments and Enclosure (Offsite Dose Calculation Manual [ODCM] Compact Disc [CD])

United States Nuclear Regulatory Commission Page 3 April 28, 2016 xc (with attachments and enclosure):

c. Haney Regional Administrator U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303 J.A. Whited NRC Project Manager (CNS) U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8-81A 11555 Rockville Pike Rockville, MD 20852 G. A. Hutto, Ill (without enclosure)

NRC Senior Resident Inspector Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 ATTACHMENT 1 Summary of Gaseous and Liquid Effluents This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents as outlined in Regulatory Guide 1.21, Appendix B. Page 1-1

-

Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Summation of All Releases Units A. Fission and Activation Gases Qtr 1 Qtr 2 Qtr 3 Qtr4 Year 1. Total Release Ci 5.0BE+OO 4.33E+OO 3.36E+OO 2.56E+01 3.84E+01 2. Avg. Release Rate µCi/sec 6.53E-01 5.51 E-01 4.22E-01 3.23E+OO 1.22E+OO B. lodine-131

1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO 5.56E-05 5.56E-05 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO 6.99E-06 1.76E-06 C. Particulates Half-Life

8 days 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium 1. Total Release Ci 5.49E+01 4.62E+01 4.31E+01 7.27E+01 2.17E+02

2. Avg. Release Rate µCi/sec 7.07E+OO 5.88E+OO 5.42E+OO 9.15E+OO 6.88E+OO E. Carbon-14

1. Total Release Ci 4.44E+OO 5.25E+OO 5.41E+OO 4.64E+OO 1.97E+01 2. Avg. Release Rate µCi/sec 5.71 E-01 6.67E-01 6.BOE-01 5.83E-01 6.26E-01 F. Gross Alpha 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Release Rate µCi/sec O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Page 1-2 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Elevated Releases -Continuous Mode

Units Qtr 1 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life;::

8 days N/A Ci Total for Period Ci o. Tritium N/A Ci E. Carbon-14 NIA Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have elevated releases.

Page 1-3 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Elevated Releases -Batch Mode

Units Qtr 1 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life

<::: 8 days N/A Ci Total for Period Ci D. Tritium N/A Ci E. Carbon-14 N/A Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have elevated releases.

Page 1-4 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Ground Releases -Continuous Mode Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Gases None Ci Total for Period Ci O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO B. Iodines 1-131 Ci O.OOE+OO O.OOE+OO O.OOE+OO 5.56E-05 5.56E-05 1-133 Ci O.OOE+OO O.OOE+OO 0.00E+OO 4.57E-05 4.57E-05 Total for Period Ci O.OOE+OO O.OOE+OO 0.00E+OO 1.01 E-04 1.01 E-04 C. Particulates Half-Life

8 days None Ci Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium H-3 Ci 5.48E+01 4.61E+01 4.29E+0.1 7.25E+01 2.16E+02 E. Carbon-14

C-14 Ci 1.33E+OO 1.58E+OO 1.62E+OO 1.39E+OO 5.91E+OO F. Gross Alpha Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

30% of total C-14 released is assumed to be in continuous mode. See Attachment 2, Supplemental Information, of this report. Page 1-5 Attachment 1 Sum_mary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Ground Releases -Batch Mode Units Qtr 1 Qtr2 Qtr 3 Qtr4 Year A Fission and Activation Gases AR-41 Ci 7.76E-01 7.09E-01 8.17E-01 8.15E-01 3.12E+OO KR-85 Ci 0.00E+OO O.OOE+OO O.OOE+OO 5.38E-01 5.38E-01 XE-131M Ci 6.49E-02 6.14E-04 O.OOE+OO 2.50E-01 3.16E-01 XE-133 Ci 4.22E+OO 3.62E+OO 2.53E+OO 2.38E+01 3.42E+01 XE-133M Ci 2.72E-03 0.00E+OO O.OOE+OO 1.93E-01 1.95E-01 XE-135 Ci 1.32E-02 3.73E-03 6.85E-03 5.66E-02 8.04E-02 Total for Period Ci 5.08E+OO 4.33E+OO 3.36E+OO 2.56E+01 3.84E+01 r* B. Iodines None Ci Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO C. Particulates Half-Life

8 days None Ci Total for Period Ci 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO D. Tritium H-3 Ci 1.14E-01 1.48E-01 1.83E-01 1.89E-01 6.34E-01 E. Carbon-14

C-14 Ci 3.11E+OO 3.68E+OO 3.79E+OO 3.25E+OO 1.38E+01 F. Gross Alpha Total for Period Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO

70% of total C-14 released is assumed to be in batch mode. See Attachment 2, Supplemental Information, of this report. Page 1-6 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Mixed-Mode Releases -Continuous Mode

Units Qtr 1 Qtr 2 Qtr 3 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life

8 days NIA Ci Total for Period Ci D. Tritium NIA Ci E. Carbon-14 N/A Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have mixed-mode releases.

Page 1-7 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Gaseous Effluents

-Mixed-Mode Releases -Batch Mode

Units Qtr 1 Qtr 2 Qtr 3 A. Fission and Activation Gases N/A Ci Total for Period Ci B. Iodines N/A Ci Total for Period Ci C. Particulates Half-Life;::::

8 days N/A Ci Total for Period Ci D. Tritium N/A Ci E. Carbon-14 NIA Ci F. Gross Alpha Total for Period Ci

Catawba Nuclear Station Units 1 and 2 do not have mixed-mode releases.

Page 1-8 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents

-Summation of All Releases Units Qtr 1 Qtr 2 Qtr 3 Qtr4 Year A. Fission and Activation Products

1. Total Release Ci 6.BOE-03 8.96E-03 7.34E-03 2.86E-03 2.60E-02 2. Avg. Diluted Cone. µCi/ml 2.47E-10 3.62E-10 2.31E-10 1.06E-10 2.33E-10 3. Batch Releases µCi/ml 2.47E-10 3.62E-10 2.31E-10 1.06E-10 2.33E-10 8. Tritium 1. Total Release Ci 1.66E+02 9.44E+01 1.55E+02 1.85E+02 6.00E+02 2. Avg. Diluted Cone. µCi/ml 6.00E-06 3.81E-06 4.BBE-06 6.85E-06 5.40E-06 3. Batch Releases µCi/ml 6.00E-06 3.81E-06 4.BBE-06 6.85E-06 5.40E-06 C. Dissolved

& Entrained Gases 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO 1.54E-06 1.54E-06 2. Avg. Diluted Cone. µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO 5.68E-14 1.38E-14 3. Batch Releases µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO 5.68E-14 1.38E-14 D. Gross Alpha 1. Total Release Ci O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Avg. Diluted Cone. µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 3. Batch Releases µCi/ml O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO E. Volume of Liquid Waste 1. Continuous Releases liters O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 2. Batch Releases liters 9.22E+05 5.04E+05 7.88E+05 9.70E+05 3.18E+06 F. Volume of Dilution Water 1. Continuous Releases liters 2.76E+09 2.48E+09 3.18E+09 2.71 E+09 1.11E+10 2. Batch Releases liters 2.76E+10 2.48E+10 3.18E+10 2.71E+10 1.11E+11

Excludes tritium, dissolved and entrained noble gases, and gross alpha. Page 1-9 Attachment 1 Summary of Gaseous and Liquid Effluents Catawba Nuclear Station Units 1 & 2 Period 1/1/2015 -12/31/2015 Liquid Effluents