ML18128A192

Annual Radioactive Effluent Release Report

ML18128A192
Person / Time
Site:	Surry
Issue date:	05/01/2018
From:	Garver R Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
18-150
Download: ML18128A192 (120)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 MAY O1 2018 United States Nuclear Regulatory Commission Serial No.18-150 Attention : Document Control Desk S&LfTSC RO Washington , DC 20555-0001 Docket Nos. 50-280 50-281 License Nos . DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2017 , through December 31 , 2017. The report, submitted pursuant to Surry Power Station Technical Specification 6.6 .B.3, includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released during the 2017 calendar year, as outlined in Regulatory Guide 1.21 , Revision 1, June 1974.

If you have any further questions, please contact Lee Ragland at 757-365-2010 .

Sincerely, Robert M. Garver II Director Nuclear Safety & Licensing Surry Power Station Attachment Commitments made in this letter: None cc: U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta , Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station

Serial No.18-150 SPS Annual Rad Effluent Report Docket Nos. 50-280, 50-281 ATTACHMENT Annual Radioactive Effluent Release Report Surry Power Station January 1, 2017, through December 31, 2017 SURRY POWER STATION UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

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I 2017 Annual Radioactive I

Effluent Release Report I

I I Surry Power Station I

I I J2 Dominion

~ Energy

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I ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT I SURRY POWER STATION I January 1, 2017 through December 31, 2017 I

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I I PreparedBy: _ _ f!_f_. -~-w ____

P. F. Blount I Health Physicist 1* Reviewed By: _ _;Q__----'-

__* _*_ _ _ ~_._l~1_/~.'"::_-::_==-----

I Superinz:~ i;hnicfil Services P.R. Harris Approved By:

I T. L. Ragland Manager Radiological Protection and Chemistry I

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I I ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT I FOR THE SURRY POWER STATION I January 1, 2017 through December 31, 2017 I

I I Section No. Subject 1

I 1 Executive Summary Purpose and Scope 2 2

I 3 Discussion 3 I 4 Supplemental Information 4 Attachment 1 Effluent Release Data I Attachment 2 Annual and Quarterly Doses I Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM)

I Attachment 4 Major Changes to Radioactive Liquid, Gaseous and Solid Waste Treatment Systems I Attachment 5 Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring I Instrumentation Attachment 6 Unplanned Releases I Attachment 7 Lower Limit of Detection (LLD) for Effluent Sample Analysis I Attachment 8 Industry Ground Water Protection Initiative I Attachment 9 Errata/Corrections to Previous Reports I

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FORWARD I

I This report is submitted as required by Appendix A to Operating License Nos. DPR-32 and DPR-37, Technical Specifications for Surry Power Station, Units 1 and 2, Virginia Electric and Power I Company, Docket Nos. 50-280, 50-281, Section 6.6.B.3.

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I I EXECUTIVE

SUMMARY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT I The Annual Radioactive Effluent Release Report describes the radiological effluent control program conducted at Surry Power Station during the 2017 calendar year. This document I summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from Surry Power Station in accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", Revision 1, June 1974. The report also includes an assessment of radiation doses to the maximum exposed member of the I public due to the radioactive liquid and gaseous effluents.

During this reporting period, there were no unplanned liquid or gaseous effluent releases as I classified according to the criteria in the Offsite Dose Calculation Manual.

Based on the 2017 effluent release data, 10CFR50 Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The dose calculations* are as follows:

1. The total body dose due to liquid effluents was 2.22E-04 mrem, which is 3.70E-03%

of the 6 mrem dose limit. The critical organ dose due to liquid effluents was 2.75E-04 mrem to the GI-LLI, which is l.38E-03% of the 20 mrem dose limit.

I 2. The air dose due to noble gases in gaseous effluents was 8.28E-03 mrad gamma, which is 4.14E-02% of the 20 mrad gamma dose limit, and 2.36E-02 mrad beta, which is 5.90E-02% of the 40 mrad beta dose limit.

I 3. The critical organ dose from gaseous effluents due to I-131, I-133, H-3, and particulates with half-lives greater than 8 days is 2.0lE-01 mrem, which is 6.70E-01 %

I of the 30 mrem dose limit.

There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems I during this reporting period.

There was one revision made to VP AP-2103S, Offsite Dose Calculation Manual, during this I reporting period.

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

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11 I Based on the radioactivity measured and the dose calculations performed during this reporting period, the operation of Surry Power Station has resulted in negligible radiation dose consequences to the maximum exposed member of the public in unrestricted areas.

I Purpose and Scope I Attachment 1 includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, with data summarized on a quarterly or annual I basis following the format of Tables 1, 2 and 3 of Appendix B, thereof. Attachment 2 of this report includes an assessment qf radiation doses to the maximum exposed member of the public due to I radioactive liquid and gaseous effluents released from the site during 2017.

As required by Technical Specification 6.8.B, changes to the Offsite Dose Calculation Manual I (ODCM) for the time period covered by this report are included in Attachment 3. Major changes to the radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, Section 6.7.2. If changes are made to these systems, the report shall I include information to support the reason for the change and a summary of the 10CFR50.59 evaluation. In lieu of reporting major changes in this report, major changes to the radioactive waste treatment systems may be submitted as part of the annual FSAR update.

I As required by the ODCM, Sections 6.2.2 and 6.3.2, a list and explanation for the inoperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 I of this report. Additionally, a list of unplanned releases during the reporting period is included in Attachment 6.

I Attachment 7 provides the typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation.

I As required by the ODCM; Section 6.7.5, a summary is provided in Attachment 8 of on-site radioactive leaks or spills and ground water sample analyses that were communicated in accordance with the Industry Ground Water Protection Initiative reporting protocol. Sample analyses from I ground water wells that are not part of the Radiological Environmental Monitoring Program are also provided in Attachment 8. In 2017, the analysis of one on-site ground water monitoring well was communicated in accordance with the Industry Ground Water Protection Initiative.

I Attachment 9 provides a resubmission of the gaseous effluent release data for 2016. An internal audit identified transcription errors associated with Table 1 of the report. The errors are identified I and entire gaseous release tables are provided.

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I I Discussion I The basis for the calculation of the percent of technical specification for the critical organ in Table IA of Attachment 1 is the ODCM, Section 6.3.l, which requires that the dose rate for iodine-131, iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 I days shall be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary.

The critical receptor was modeled as a teenage individual for the 15\ 3rd and 4th quarters and the I child for the 2nd quarter, both via the inhalation pathway.

The basis for the calculation of the percent of technical specification for the total body and skin in I Table IA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for noble gases to areas at or beyond site boundary shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin.

I The basis for the calculation of the percent of technical specification in Table 2A of Attachment 1 is the ODCM, Section 6.2.1, which states that the concentration of radioactive material released in I liquid effluents to unrestricted areas shall not exceed ten times the concentrations specified in 10CFR20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.00E-04 I microcuries/mL.

Percent of technical specification calculations are based on the total gaseous or liquid effluents I released for the respective quarter.

The annual .and quarterly doses, as reported in Attachment 2, were calculated according to the I methodology presented in the ODCM. The beta and gamma air doses due to noble gases released from the site were calculated at the site boundary. The maximum exposed member of the public from the release of airborne iodine- I 31, iodine-13 3, tritium and all radionuclides in particulate form I with half-lives greater than 8 days, was modeled as a child at the site boundary with the critical organ being the bone via the inhalation pathway. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was modeled as an adult, exposed I by either the invertebrate or fish pathway, with the critical organ typically being the gastrointestinal-lower large intestine. The total body dose was also determined for this individual.

I Attachment 5 provides a discussion on the gaseous effluent monitoring instrumentation that was inoperable for greater than 30 days. No liquid radioactive effluent monitoring instrumentation was I inoperable for greater than 30 days in 2017.

There were no unplanned gaseous or liquid releases in 2017 to describe in Attachment 6 as required I by the ODCM, Section 6.7.2.

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I I The typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation are presented in Attachment 7. These LLD values are based upon conservative conditions (i.e., minimum sample volumes and maximum delay time prior to analysis). Actual I LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed, then the activity of the radioisotope was reported as Not Detected (N/D) on Attachment 1 of this I report. When all isotopes listed on Attachment 1 for a particular quarter and release mode are less than the lower limit of detection, then the totals for this period will be designated as Not Applicable (NIA).

I Supplemental Information I

Section 6.6.1 of the ODCM requires the identification of the cause(s) for the unavailability of milk, I or if required, leafy vegetation samples, and the identification for obtaining replacement samples.

As milk was available for collection during this reporting period, leafy vegetation sampling was not required.

I As required by the ODCM, Section 6.6.2, evaluation of the Land Use Census is made to determine I if new sample location(s) must be added to the Radiological Environmental Monitoring Program.

Evaluation of the Land Use Census conducted for this reporting period identified no change in sample locations for the Radiological Environmental Monitoring Program.

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EFFLUENT RELEASE DATA I January 1, 2017 through December 31, 2017 I

This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents I and solid waste as outlined in Regulatory Guide 1.21, Appendix B.

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I TABLE lA Attachment 1 Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/17 TO 12/31/17 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I SURRYPOWERSTATIONUNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER QUARTER I A. FISSION & ACTIVATION GASES

l. TOT AL RELEASE Ci 4.4IE,02 7.54E+Ol l.80E+Ol I 2. A VE RELEASE RATE FOR PERIOD µCi/sec 5.67E-03 9.59E+OO I B. IODINE

1. TOTAL I-131

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec N/D NIA l.l IE-02 l.42E-03 2.80E+Ol I C. PARTICULATE

l. HALF-LIFE >8 DAYS Ci N/D l.43E-04 2.80E+Ol I 2.

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A VE RELEASE RATE FOR PERIOD GROSS ALPHA RADIOACTIVITY

µCi/sec Ci NIA N/D l.82E-05 N/D I D. TRITIUM

1. TOTAL RELEASE Ci l.55E+Ol l.40E+Ol 3.lOE+Ol

'I 2. AVE RELEASE RATE FOR PERIOD µCi/sec 2.00E+OO l.79E+OO I E. CARBON-14

l. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec 1.12E-02 l.44E-03 l.92E+Ol 2.44E+OO

,I PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % 3.05E-03 5.36E-02 I TOTAL BODY DOSE RATE SKIN DOSE RATE l.OIE-05 3.14E-06 5.59E-03 2.20E-03 I

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I TABLE lA Attachment 1 Page 2 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/17 TO 12/31/17 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST.ERROR I A. FISSION & ACTIVATION GASES QUARTER QUARTER

1. TOTAL RELEASE Ci 2.60E-Ol l.68E-02 l.80E+Ol I 2. A VE RELEASE RATE FOR PERIOD µCi/sec 3.27E-02 2.12E-03 I B. IODINE I. TOTAL 1-131

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec l.04E-05 l.3IE-06 N/D NIA 2.80E+Ol I C. PARTICULATE I. HALF-LIFE >8 DAYS Ci N/D 4.65E-06 2.80E+Ol I 2. AVE RELEASE RATE FOR PERIOD

3. GROSS ALPHA RADIOACTIVITY

µCi/sec Ci NIA N/D 5.85E-07 N/D I D. TRITIUM I. TOTALRELEASE Ci 8.00E+OO I.20E+Ol 3.lOE+Ol I 2. A VE RELEASE RATE FOR PERIOD µCi/sec l.OIE+OO l.5IE+OO E. CARBON-14 I 1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD

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µCi/sec 6.62E-02 8.33E-03 4.28E-03 5.38E-04 I PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % l.56E-03 2.29E-03 I TOTAL BODY DOSE RATE SKIN DOSE RATE 9.86E-08 3.25E-07 2.99E-08 l.l 7E-08 I

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I I TABLElB Attachment 1 Page 3 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111111 TO 12131111 GASEOUS EFFLUENTS-MIXED MODE RELEASES I CONTINUOUS MODE BATCH MODE I SURRY POWER STATION UNITS 1&2 UNIT FIRST QUARTER SECOND QUARTER FIRST QUARTER SECOND QUARTER I l. FISSION & ACTIVATION GASES Kr-85 Kr-85m Ci Ci N/D NID N/D N/D N/D NID 6.02E+OO l.47E-02 Kr-87 Ci NID N/D N/D NID I Kr-88 Xe-133 Ci Ci N/D N/D NID N/D N/D 8.77E-03 4.48E-03 2.99E+Ol Xe-135 Ci N/D N/D N/D 2.81E-01 I Xe-135m Xe-138 Xe-131m Ci Ci Ci N/D N/D N/D NID N/D N/D NID N/D NID N/D N/D 9.25E-01 I Xe-133m Ar-41 Ci Ci N/D N/D N/D N/D N/D 5.42E-04 2.31E-01 2.29E-03 TOTAL FOR PERIOD Ci NIA NIA 9.31E-03 3.74E+Ol I

2. IODINES I I-131 I-133 Ci Ci NID NID l.lOE-07 N/D NID NID N/D N/D I-135 Ci N/D N/D NID NID I TOTAL FOR PERIOD Ci NIA l.IOE-07 . NIA NIA I 3. PARTICULATES Sr-89 Ci N/D N/D NID N/D I Sr-90 Cs-134 Ci Ci NID NID N/D 7.83E-05 N/D NID NID N/D Cs-137 Ci NID 6.17E-05 N/D NID I Ba-140 La-140 Co-58 Ci Ci Ci N/D N/D N/D N/D N/D N/D NID NID NID N/D NID N/D

.I Co-60 Mn-54 Fe-59 Ci Ci Ci N/D NID N/D N/D N/D N/D N/D NID NID N/D N/D NID Zn-65 Ci N/D N/D NID N/D I Mo-99 Ce-141 Ci Ci N/D NID N/D NID N/D N/D N/D NID Ce-144 Ci N/D NID NID N/D I C-14 TOTAL FOR PERIOD Ci Ci N/D NIA N/D l.40E-04 2.37E-03 2.37E-03 9.53E+OO 9.53E+OO I

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I TABLElB Attachment 1 Page 4 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1117 TO 12131/17 GASEOUS EFFLUENTS-MIXED MODE RELEASES I CONTINUOUS MODE BATCH MODE SURRYPOWERSTATIONUNITS 1&2 THIRD THIRD I

UNIT FOURTH FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTNATION GASES I Kr-85 Kr-85m Ci Ci N/D N/D N/D N/D 2.16E-Ol N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D I Kr-88 Xe-133 Xe-135 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D 4.37E-02 N/D N/D l.68E-02 N/D Xe-135m Ci N/D N/D N/D N/D I Xe-138 Xe-131m Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D I Ar-41 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA 2.60E-01 1.68E-02 I 2. IODINES I I-131 I-133 I-135 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I TOTAL FOR PERIOD Ci NIA NIA NIA NIA 1,-

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D I Sr-90 Cs-134 Cs-137 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I Ba-140 La-140 Co-58 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Co-60 Ci N/D N/D N/D N/D I Mn-54 Fe-59 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D I Mo-99 Ce-141 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Ce-144 Ci N/D N/D 1* C-14 Ci N/D N/D 6.62E-02 4.28E-03 TOTAL FOR PERIOD Ci NIA NIA 6.62E-02 4.28E-03 I

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i I TABLElC Attachment 1 Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/17 TO 12131/17 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES I CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND I QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES I Kr-85 Kr-85m Ci Ci NID NID NID NID NID NID 4.27E-02 NID Kr-87 Ci NID NID NID NID I Kr-88 Xe-133 Xe-135 Ci Ci Ci NID 3.34E-02 NID NID 3.54E+Ol 6.03E-01 NID NID NID NID l.89E+OO l.25E-04 I Xe-135m Xe-138 Xe-13lm Ci Ci Ci NID NID NID NID NID NID NID NID NID NID NID 3.8IE-02 Xe-133m Ci NID NID NID 4.07E-03 I Ar-41 Ci l.34E-03 6.93E-04 NID NID TOTAL FOR PERIOD Ci 3.48E-02 3.60E+Ol NIA l.97E+OO I 2. IODINES I I-131 I-133 I-135 Ci Ci Ci NID NID NID l.llE-02 l.20E-05 NID NID NID NID 3.96E-07 NID NID.

I TOTAL FOR PERIOD Ci NIA l.1 IE-02 NIA 3.96E-07 I 3. PARTICULATES Sr-89 Ci NID NID NID NID I Sr-90 Cs-134 Cs-137 Ci Ci Ci NID NID NID NID NID NID NID NID NID NID NID NID I Ba-140 La-140 Co-58 Ci Ci Ci NID NID NID NID NID 2.82E-06 NID NID NID NID NID NID Co-60 Ci NID NID NID NID I Mn-54 Fe-59 Ci Ci NID NID NID NID NID NID NID NID Zn-65 Ci NID NID NID NID I Mo-99 Ce-141 Ce-144 Ci Ci Ci NID NID NID NID NID NID NID NID NID NID NID NID I C-14 TOTAL FOR PERIOD Ci Ci 8.86E-03 8.86E-03 9.17E+OO 9.17E+OO NID NA 5.02E-01 5.02E-01 I

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I TABLElC Attachment 1 Page 6 ofl2 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111111 TO 12131117 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES I CONTINUOUS MODE BATCH MODE SURRYPOWERSTATIONUNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH I QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTNATION GASES I Kr-85 Kr-85m Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Kr-87 Ci NID N/D N/D N/D I Kr-88 Xe-133 Xe-135 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Xe-135m Ci N/D N/D N/D N/D I Xe-138 Xe-131m Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D I Ar-41 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA I 2. IODINES I I-131 I-133 I-135 Ci Ci Ci l.04E-05 N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I TOTAL FOR PERIOD Ci l.04E-05 NIA NIA NIA I 3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D I Sr-90 Cs-134 Cs-137 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D I

I La-140 Co-58 Ci Ci N/D N/D N/D 4.65E-06 N/D N/D N/D N/D Co-60 Ci N/D N/D N/D N/D I Mn-54 Fe-59 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D I Mo-99 Ce-141 Ce-144 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D NID I C-14 TOTAL FOR PERIOD Ci Ci N/D O.OOE+OO N/D 4.65E-06 N/D NA NA I

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I TABLE2A Attachment 1 Page 7 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/17 TO 12/31/17 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES I SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER QUARTER I A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci l.39E-03 3.79E-03 2.00E+Ol I 2. AVE DIL. CONC. DURING PERIOD

3. PERCENT OF APPLICABLE LIMIT

µCi/mL 3.2IE-12 4.90E-06 6.03E-12 l.50E-05 I B. TRITIUM

1. TOTAL RELEASE Ci l.39E+02 5.48E+02 2.00E+Ol I 2. AVE DIL. CONC. DURING PERIOD

3. PERCENT OF APPLICABLE LIMIT

µCi/mL 2.lOE-07 2.lOE-03 8.73E-07 8.73E-03 I C. DISSOLVED AND ENTRAINED GASES

1. TOT AL RELEASE Ci NID 9.94E-04 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/mL NIA l.58E-12 I 3. PERCENT OF APPLICABLE LIMIT  % NIA 7.92E-07 I D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci NID N/D 2.00E+Ol I E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.24E+07 5.47E+07 3.00E+OO I F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 6.59E+ll 6.27E+ll 3.00E+OO I

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I TABLE2A Attachment 1 Page 8 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111/17 TO 12131/17 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES I SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST.ERROR QUARTER QUARTER I A. FISSION AND ACTIVATION PRODUCTS I. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 2.lOE-03 2.42E-03 2.00E+Ol I 2. AVE DIL. CONC. DURING PERIOD

3. PERCENT OF APPLICABLE LIMIT

µCi/mL 2.65E-12 7.20E-06 3.5IE-12 9.58E-06 I B. TRITIUM

1. TOT AL RELEASE Ci l.33E+02 2.05E+02 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/mL l.68E-07 2.98E-07 I 3. PERCENT OF APPLICABLE LIMIT  % l.68E-03 2.98E-03 I C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci N/D N/D 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/mL NIA NIA I 3. PERCENT OF APPLICABLE LIMIT  % NIA NIA I D. GROSS ALPHA RADIOACTIVITY I. TOTAL RELEASE Ci N/D N/D 2.00E+Ol I E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.37E+07 5.33E+07 3.00E+OO I F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.90E+ll 6.88E+ll 3.00E+OO I

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I TABLE2B Attachment 1 Page 9 ofl2 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/17 TO 12/31/17 LIQUID EFFLUENTS I SURRY POWER STATION UNITS 1&2 UNIT CONTINUOUS MODE FIRST QUARTER SECOND QUARTER BATCH MODE FIRST QUARTER SECOND QUARTER I Sr-89 Sr-90 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Fe-55 Ci N/D N/D N/D N/D I Cs-134 Cs-137 Ci Ci N/D 2.16E-04 N/D 2.20E-04 N/D 7.50E-06 5.22E-05 l.95E-04 I-131 Ci N/D N/D N/D 7.15E-05 I Co-58 Co-60 Ci Ci N/D N/D N/D N/D l.18E-04 l.95E-04 N/D 9.70E-04 9.02E-04 N/D Fe-59 Ci N/D N/D I Zn-65 Mn-54 Cr-51 Ci Ci Ci N/D N/D N/D N/D NID N/D N/D NID N/D N/D N/D N/D Zr-95 Ci N/D N/D N/D NID I Nb-95 Mo-99 Ci Ci N/D N/D NID N/D N/D N/D l.47E-06 N/D Tc-99m Ci N/D N/D N/D N/D I Ba-140 La-140 Ci Ci N/D N/D N/D N/D NID N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D I Ce-144 Sb-124 Sb-125 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D 8.56E-04 N/D N/D l.37E-03 Co-57 Ci N/D N/D N/D N/D I

TOTAL FOR PERIOD Ci 2.16E-04 2.20E-04 l.18E-03 3.57E-03 I

Xe-133 Ci N/D N/D N/D 9.94E-04 I Xe-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA 9.94E-04 I

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I TABLE2B Attachment 1 Page 10 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1117 TO 12131/17 LIQUID EFFLUENTS I SURRY POWER STATION UNITS 1&2 UNIT CONTINUOUS MODE THIRD QUARTER FOURTH QUARTER BATCH MODE THIRD QUARTER FOURTH QUARTER I Sr-89 Sr-90 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Fe-55 Ci N/D N/D N/D N/D I Cs-134 Cs-137 Ci Ci N/D 2.25E-04 N/D 2.14E-04 N/D l.55E-04 N/D l.59E-04 I-131 Ci N/D N/D N/D N/D I Co-58 Co-60 Fe-59 Ci Ci Ci N/D N/D N/D 3.0IE-05 N/D N/D 2.14E-04 4.27E-04 N/D l.OIE-04 7.17E-04 N/D I Zn-65 Mn-54 Cr-51 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Zr-95 Ci N/D N/D N/D N/D I Nb-95 Mo-99 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Tc-99m Ci N/D N/D N/D N/D I Ba-140 La-140 Ce-141 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I Ce-144 Sb-124 Sb-125 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D l.08E-03 N/D N/D l.19E-03 Co-57 Ci N/D N/D N/D N/D I

TOTAL FOR PERIOD Ci 2.25E-04 2.44E-04 l.87E-03 2.17E-03 I

Xe-133 Ci N/D N/D N/D N/D I Xe-135 TOTAL FOR PERIOD Ci Ci N/D NIA N/D NIA N/D NIA N/D NIA I

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Attachment 1 TABLE3 Page 11 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/17 -12/31/17 I

I SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

I 1. Type of waste 12 month Period Est. Total Error,%

I a. Spent resins, filter sludges, evaporator m3 2.83E+Ol Note 1 l.OOE+Ol bottoms, etc. Ci 6.04E+02 3.00E+Ol I b. Dry compressible waste, contaminated m3 3.42E+02 Note2 l.OOE+Ol equip., etc. Ci 7.7IE-01 3.00E+Ol I c. Irradiated components, control m3 O.OOE+OO rods, etc. Ci O.OOE+OO I d. Other (Waste oil) m3 Ci O.OOE+OO O.OOE+OO Note 3 l.OOE+Ol 3.00E+Ol I 2. Estimate of major nuclide composition (by type of waste)

I a. Co-60  % 5.33E+Ol Ni-63  % 3.42E+Ol I Fe-55 Co-58 8.72E+OO l.3IE+OO I b. Co-60 Ni-63 Fe-55 7.29E+Ol l.lOE+Ol 7.77E+OO Mn-54  % 3.32E+OO I Pu-241 Sb-125 l.52E+OO l.50E+OO I C.  %

d.  %

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Attachment 1 I TABLE3 Page 12 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/17 -12/31/17 I CONTINUED SURRY POWER STATION I A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

3. Solid Waste Disposition I Number of Shipments 15 2

Mode of Transportation Truck Truck Destination Oak Ridge, TN (EnergySolutions)

Erwin, TN (EnergySolutions)

I I B. IRRADIATED FUEL SHIPMENT (Disposition)

I Number of Shipments 0

Mode of Transportation Destination I

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I I NOTE 1: Some of this waste was shipped to licensed waste processors for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is l.05E+OO m3*

I Burial volume by Erwin Resin Solutions is indeterminable due to mixing of Surry waste with other generators waste.

NOTE 2: Some DAW was shipped to licensed waste processors for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is l.24E+02 m3*

I NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is O.OOE+OO m 3*

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Attachment 2 Page 1 of 1 ANNUAL AND OUARTERLY DOSES I 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 I calendar year of this report, along with an annual total of each effluent pathway is made pur~uant to the ODCM, Section 6.7.2, requirement.

I LIQUID I 2017 Maximum Receptor - Adult Total Body GI-LLI Liver I (mrem) 1st Quarter 2.74E-05 (mrem) 3.19E-05 (mrem) 2.77E-05 2nd Quarter l.30E-04 l.57E-04 l.29E-04 I 3rd Quarter 2.38E-05 4th Quarter 4.07E-05 3.16E-05 5.44E-05 2.41E-05 4.06E-05 I Annual 2.22E-04 2.75E-04 2.21E-04 GASEOUS - Air Dose I 2017 Gamma (mrad)

Beta (mrad) 1st Quarter l.39E-05 2.26E-05 I 2nd Quarter 8.27E-03 2.36E-02 3rd Quarter 1.46E-07 3.56E-06 I 4th Quarter Annual 4.52E-08 8.28E-03 l.34E-08 2.36E-02 I GASEOUS - Organ Dose Annual Maximum by Quarter I 2017 Maximum Child/Bone Receptor I (mrem) (mrem) Organ I 1st Quarter 2nd Quarter l.82E-04 2.0lE-01 l.13E-02 Teen/Thyroid 2.0lE-01 Child/Bone I 3rd Quarter 4th Quarter 1.41E-05 2.67E-06 5.89E-03 Teen/Thyroid 8.68E-03 Teen/Thyroid Annual 2.0lE-01 I

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Attachment 3 I Page 1 of 1 I REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM)

I As required by Technical Specification 6.8.B, revisions to the ODCM, effective for the time period covered by this report, are included with this attachment. There was one revision to the ODCM I implemented during this reporting period. A copy of the revision is included.

I Revision 20:

Radiological Environmental Monitoring Program

• Changed terminology for milk ingestion pathway from Cow Milk to Milk Animal and added I goat specific consumption rate for derivation of dose factors, as necessary.

• Added a new river silt sampling location.

• Added a new oyster sampling location.

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• Revised Milk Control sampling location.

I Radiological Effluent Program

• Updated gaseous release dispersion and depositions factors; X/Q, D/Q I

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I I Administrative Procedure or Guidance and Reference Document Approval I 1. Document Number:

VPAP-2103S

2. Revision:

20

3. Document Type:

0 Administrative Procedure 0GARD 4.

Title:

I Offsite Dose Calculation Manual (Surry)

5. Requestor(s) Print Name(s) / Locations 6. Date 7. Requestor Phone I Johnnie Abbott/ SPS

8. Document Request DNew 0 Revision D Cancel 10/26/2017 D Supersede 8-798-2434 D Temporary

9. Applicable Nuclear Station(s)

I Millstone D 1o. Reason and Brief Description of Change:

North Anna D Surry 0 Revision initiated to incorporate changes from PlR1021187, Radiological Environmental Monitoring Program, I CR1053122, Delta-temperature data from the SPS Met tower is output in degC but used as degF / CA3053441, Revise gaseous effluent procedures, and CR1066641, Oyster samples not obtained from location as specified in ODCM.

Changed Milk Cow to Milk Animal, Updated Silt, Oyster and Milk Sample Locations, Updated X/Q and D/Q values.

For full list of changes, see Revision Summary.

I 11. Records Retention Requirements Affected?

D Yes (Complete NRRS form from RM-AA-101) 0 No

12. Change Management:

Attach Appropriate PI-AA-4000 Attachment(s)

13. Level of Use:

I Fleet Approval D Continuous Use D Reference Use 0 Information Use D Multiple Use

14. Fleet Approval Required by: (Check one box only. Enter Peer Group Name, if ai:1 I 15. Printed Approver Name D Peer Group OR ger FAM Lee Ragland I Site Approval

18. Implementation Prerequisites: (Items in addition to those listed on Document Traveler or Change Management Plan)

None I

I 19. Implementation Prerequisites Reviewed - Procedure Supervisor Signature

21. Check Nuclear Station(s) for Which Document is being Approved for Implement tion.

20. Date l l-'2.l-1, Millstone D I 22. Site Approval (Print Name of FAM)

Lee Ra land North Anna D

23. Signature 24.,9ate i// 2.1. I

25. Facility Safety Review Committee Required? 26. Facility Safety Review Committee (Sit~)'Print Name/Signature 27.".Date I 0 No DYes

28. Site Vice President Required?

NIA

29. Site Vice President) Pri N/A DNo 0Yes --~~t'°""\~l~

I 31. Nuclear E-Forms Updated for Site(s )?

D MP O NA O SU 0 N/A I 34. Document Number:

VPAP-2103S

35. Revision:

20

36. Effective Date 11/21/2017

37. Expiration Date N/A I Key: GARD-Guidance and Reference Document, EDMS-Electronic Document Management System Form No. 728620(0ct 2014)

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Station I

~~-,~ Dom1n1on

~ .. .

Administrative Procedure I

Title:

Offsite Dose Calculation Manual (Surry)

I Process / Program Owner: Manager Radiologiq1l Protection and Chemistry (Surry) I Procedure Number VPAP-2103S Revision Number 20 Effective Date On File I Revision Summary The following changes were made in response to PIR1021 l 87, Radiological Environmental I Monitoring Program.

• Removed cow from Substep 6.3.4.c.l.

• Changed Mille Cow to Milk Animal on Attachment 7 I

• Added Silt Location for Surry Station Intake to Attachment 8 .

• Changed Note 2 of Attachment 8 from 15-30 km "distant" to "from the station"

• Updated Collection Frequency for Food Products to "Annually, at time of Harvest"

• Changed Milk Control Location from Williams to Lover Retreat on Attachment 9 I

• Added Silt Location for Surry Station Intake to Attachment 9

• Changed milk cow to millc animal on Attachment 12

• Added goat's consumption rate to formula on Attachment 12 I

The following changes were made in response to CRl 053122, Delta-temperature data from the SPS Met tower is output in degC but used as degF / CA3053441, Revise gaseous effluent procedures:

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• Updated X/Q and D/Q values on Attachment 7 I

The following changes were made in response to CR1066641, Oyster samples not obtained from location as specified in ODCM:

• Changed Oyster Location from Lawne' s Creek to Swash Hole Island on Attachment 9 I

• I I

Approvals on File I

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• 1 DOMINION VPAP-2103S I REVISION20 PAGE20F76 I TABLE OF CONTENTS I Section Page 1.0 PURPOSE 4 I 2.0 SCOPE 4 I

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 I 5.0 RESPONSIBILITIES 10 I 6.0 INSTRUCTIONS 6.1 Sampling and Monitoring Criteria 11 11 I 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations 11 11 I 6.2.2 Liquid Monitoring Instrumentation 6.2.3 Liquid Effluent Dose Limit 13 16 6.2.4 Liqui.d Radwaste Treatment 19 I 6.2.5 Liquid Sampling 21 6.3 Gaseous Radioactive Waste Effluents 21 I 6.3.1 Gaseous Effluent Dose Rate Limitations 21 6.3.2 Gaseous Monitoring Instrumentation 24 I 6.3.3 Noble Gas Effluent Air Dose Limit 27 6.3.4 I-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit 28 I 6.3.5 Gaseous Radwaste Treatment 31 6.4 Radioactive Liquid and Gaseous Release Permits 32 I 6.4.1 Liquid Waste Batch Releases 32 6.4.2 Continuous Liquid Releases 32 I 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 33 6.4.4 Reactor Containment Release Permits 33 I 6.4.5 Miscellaneous Gaseous Release Permit 33 33 6.4.6 Radioactive Liquid and Gaseous Release Controls I

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I DOMINION VPAP-2103S REVISION20 PAGE30F76 I Section TABLE OF CONTENTS (continued)

Page I

6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.6 Radiological Environmental Monitoring 34 35 I

6.6.1 Monitoring Program 6.6.2 Land Use Census 35 38 I

6. 7 6.6.3 Interlaboratory Comparison Program Reporting Requirements 39 39 I

6.7.1 Annual Radiological Environmental Operating Report 6.7.2 Annual Radioactive Effluent Release Report 39 41 I

6.7.3 Annual Meteorological Data 6.7.4 Changes to the ODCM 43 43 I

6.7.5 Industry Ground Water Protection Initiative 44 7.0 RECORDS 46 I

1 ATTACHMENTS Radioactive Liquid Effluent Monitoring Instrumentation 47 I

2 Radioactive Liquid Effluent Monitoring Instrumentation

• Surveillance Requirements 48 I

3 Radioactive Liquid Waste Sampling and Analysis Program 49 4

5 Radioactive Gaseous Waste Sampling and Analysis Program Radioactive Gaseous Effluent Monitoring Instrumentation 52 56 I

6 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 58 I

7 Dispersion and Deposition Factors 60 8

9 Radiological Environmental Monitoring Program Environmental Sampling Locations 61 64 I

10 11 Detection Capabilities for Environmental Sample Analysis Reporting Levels for Radioactivity Concentrations in Environmental Samples 67 69 I

12 Meteorological, Liquid, and Gaseous Pathway Analysis 70 I

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I DOMINION VPAP-2103S I REVISI0N20 PAGE40F76 I 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive I Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the I Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release I Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that:

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• Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CFR 20, Appendix B, Table 2, Column 2, for I radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/mL for dissolved or entrained noble gases I

• Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CFR 50, Appendix I I

• Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:

I ** Noble gases - less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin I .. I 131 , I 133 , and H3 , and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ I

• Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CFR 50, Appendix I, and I

• Exposure to a real individual will not exceed 40 CFR 190 dose limits I 2.0 SCOPE.

This procedure applies to the Radioactive Effluent and Radiological Environmental I Monitoring Programs at Surry Power Station.

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I DOMINION VPAP-2103S REVISI0N20 PAGE50F76 I

3.0 REFERENCES

/COMMITMENT DOCUMENTS I 3.1 References 3.1.1 10 CPR 20, Standards for Protection Against Radiation 3 .1.2 10 CPR 50, Domestic Licensing of Production and Utilization Facilities I

3.1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations I

3 .1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid I Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3 .1. 6 Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases I

of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CPR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 I 3 .1. 7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 I 3.1.8 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 I

3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 I

3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 I 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents I 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 I

3 .1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 I

3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CPR Part 190) I 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual I

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I DOMINION VPAP-2103S I REVISION20 PAGE 6 OF76 I 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of I RETS to the Offsite Dose Calculation Manual or to the Process Control Program

3. l .20 Surry UFSAR I 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis I 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 I 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.26 CR022320 (Surry), Daily Channel Checks for l-VG-RM-131-1 Flow Rate Measuring I Device Not Performed 3.1.27 RP-AA-502, *Groundwater Protection Program I 3.1.28 Branch Technical Position, Revision 1, November 1979 3.1.29 CR1013104, VPAP-2103S compensatory actions review not completed for 1-RLW-FIT-153 failure I 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2)

I 3.2.2 Deviation Report S-97-1281, Annual Radiologi~al Effluent Release Report I, 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling I 4.0 DEFINITIONS 4.1 Channel Calibration I Adjustment, as necessary, of the channel output so it responds with the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire I channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated.

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DOMINION VPAP-2103S REVISION20 PAGE 7 OF76 4.2 Channel Check I A qualitative assessment; by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring I

the same parameter.

The Channel Check for the MGPI sampler flow rate measuring devices, as listed on I

Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release I ra_te (i.e., microcuries per second) without the presence of a sampler flow fault display.

4.3 Channel Functional Test There are two types of Channel Functional Tests.

I 4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to I

verify Operability, including alarm and/or trip functions. I 4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions.

I 4.4 Critical Organ I That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded.

I 4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/ cc) that alone would produce the same thyroid dose as the I

quantity and isotopic mixture of I 131 , I 132 , I 133 , I 134, and I 135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of I

Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used. I I

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I DOMINION VPAP-2103S I REVISION20 PAGE 8 OF76 I

• 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent.

I NOTATION FREQUENCY I D-Daily At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> W-Weekly At least once per 7 days I M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days I' SA - Semi-annually At least once per 184 days

. R - Refueling At least once per 18 months I SIU - Start-up P - Prior to release Prior to each reactor start-up Completed prior to each release I NIA- Not applicable DR- During the release Not applicable At least once during each release I 4.7 Gaseous Radwaste Treatment'System A system that reduces radioactive gaseous effluents by collecting primary_coolant system I offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas I surge tanks.

I 4.8 General Nomenclature X = Chi: concentration at a point at a given instant (curies per cubic meter)

• D = *Deposition: quantity of deposited radioactive material per unit area (curies per square I meter)

Q = Source strength (instantaneous; grams, curies)

I = Emission rate (continuous; grams per second, curies per second)

- Emission rate (continuous line source; grams per second per meter)

I 4.9 Lower Limit of Detection (LLD)

The smallest concentration of radioactive material in a sample that will yield a net count (above I system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

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I DOMINION VPAP-2103S REVISI0N20 PAGE9 OF76 I 4.10 Members of the Public I Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This I

category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled I by Dominion to protect individuals from exposure to radiation and radioactive materials.

4.11 Operable - Operability I

A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, I controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions.

I 4.12 Purge - Purging I Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement.

I 4.13

• Rated Thermal Power I Total reactor core heat transfer rate to reactor coolant (i.e., 2587 Megawatts Thermal MWt).

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

4.15 Source Check

• I For Victoreen and Eberline monitors a source check is the qualitative assessment of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, I LED.

For MGPI monitors a source check is the verification of proper computer response to I

continuous operational checks on the detector and electronics.

4.16 Special Report I

• A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VPAP-2802, Notifications and Reports.

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I DOMINION VPAP-2103S I REVISI0N20 PAGE 100F76 I 4.17 Thermal Power Total reactor core heat transfer rate to the reactor .coolant.

I 4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by I Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, I* 4.19 commercial, institutional or recreational purposes.

Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactiv~ material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEP A) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems I are not Ventilation Exhaust Treatment System components.

I 5.0 5.1 RESPONSIBILITIES Manager Radiological Protection and Chemistry I The Manager Radiological Protection and Chemistry is responsible for:

5 .1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring I radioactive effluents* and the environment.

5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, and I documenting these activities.

5 .1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends.

I 5.1.4 Preparing Effluent and Environmental Monitoring Program records.

I 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

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I DOMINION VPAP-2103S REVISI0N20 PAGE 11 OF76 I 6.0 INSTRUCTIONS I NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12). I 6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range I

of radiation monitored and the type of discharge monitored.

6.1.2 Installed monitoring systems shall be calibrated for the' type and range of radiation or I

parameter monitored.

I 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the. status of the discharge monitored.

I 6.1.4 Samples shall be representative of the volume and type of discharge monitored.

6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly I documented, and sufficiently detailed that the meaning and intent of the records are clear. I 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. I 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations I

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

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

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

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

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I DOMINION VPAP-2103S I REVISION20 PAGE 120F76 I: c. Concentrations of radioactive materials in liquid waste released to unrestricted areas shall meet the following:

.I Volume of Waste Discharged+ Volume ofDilution Water>

1 (1)

I Volume of Waste Discharged x'"'

µCi/mL-1 Li ACW.

1 I* where:

I µCi/mLi =the concentration of nuclide i in the liquid effluent discharge ACWi =ten times the effluent concentration value in unrestricted areas of I nuclide i, expressed as µCi/mL from 10 CFR 20, Appendix B, Table 2, Column 2 forradionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases I d. Bases - Liquid Effluent Concentration Limitations This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will not exceed 10 times the concentration valµes specified in Appendix B,-Table 2; Column 2 of

• I 10 CFR 20. The specification provides operational flexibility for releasing liquid effluent in concentrations to follow the Section II.A and II.C design objectives of Appendix I to 10 CFR Part 50. This limitation provides additional assurance that

• I the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II.A design objectives of Appendix I I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) restrictions authorized by 10 CPR 20.1301(e). The concentration limit for dissolved or entrained noble I gases is based upon the assumption that Xe-135 is the controlling radioisotope and its effluent concentration in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on I Radiological Protection (ICRP) Publication 2. This specification does not affect the requirements to comply with the annual limitations of 10 CFR 20.1301(e).

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I DOMINION VPAP-2103S REVISION20 PAGE 13 OF76 I 6.2.2 Liquid Monitoring Instrumentation 1,

a. Radioactive Liquid Effluent Monitoring Instrumentation Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be I.

operable with their alarm/trip setpoints set to ensure that Step 6.2. l .a. limits are not exceeded.

.1

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

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

following:

• Promptly suspend release of radioactive liquid effluents monitored by the I affected channel

• Declare the channel inoperable

• Change the setpoint to an acceptable, conservative value I

b. Radioactive Liquid Effluent Monitoring Instrumentation Operapility Each radioactive liquid effluent monitoring instrumentation channel shall be I

demonstrated operable by performing a Channel Check, Source Check, Channel Calibration, and Channel Functional Test at the frequencies shown in Radioactive I

Liquid Effluent Monitoring Instrumentation Surveillance Requi~ements (Attachment 2). I

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

1) perform the action shown in those tables.

2. Attempt to return the instruments to operable status within 30 days. If I

unsuccessful,* explain in the next Annual Radioactive Effluent Release Report why the inoperability was not corrected_ in a timely manner. I I

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11 DOMINION VPAP-2103S REVISI0N20 I PAGE 140F76 I c. Applicable Monitors Liquid effluent monitors for whi,ch alarm/trip setpoints shall be determiued are:

I Release Point Service Water System Effluent Line Instrument Number 1-SW-RM-107 A, B,C,D I Condenser Circulating Water Line l-SW-RM-120 2-SW-RM-220 I Radwaste Facility Effluent Line RE-RRM-131

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

I 1. Maximum setpoint values shall be calculated by:

I s (2)

I where:

S = the setpoint, in µCi/mL, of the radioactivity monitor measuring the I C radioactivity concentration in the. effluent line prior to dilution the effluent concentration limit for the monitor used to implement 10 CPR 20 for the Station (ACW in µCi/mL) for an isotopic mixture I FE =

expected in the effluent maximum design pathway effluent flow rate

=

I Fn dilution water flow rate calculated as:

FE+ (200,000 gpm x number of circ. pumps in service)

I 2. Each of the condenser circulating water channels (e.g., SW-120, SW-220) monitors the effluent (service water, including component cooling service water, circulating water, and liquidradwaste) in the circulating water discharge I tunnel beyond the last point of possible radioactive material addition. No dilution is assumed for this pathway. Therefore, Equation (2) becomes:

I S =C (3)

The setpoint for Station monitors used to implement 10 CPR 20 for the site I becomes the effluent concentration limit.

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I DOMINION VPAP-2103S REVISION20 PAGE 15 OF76 I

3. In addition, for added conservatism, setpoints shall be calculated for the service I water system effluent line (i.e., SW-107 A, B, C, D), and the Radwaste Facility effluent line (i.e., RRM-131). I

4. For the service water system effluent line, Equation (2) becomes:

I s (4)

I where:

Ksw = Allocation :fraction of the effluent concentration limit, used to I implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

5. For the Radwaste Facility effluent line, Equation (2) becomes:

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s (5) where:

I KRw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent I

line pathway

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

e. Bases - Radioactive Liquid Effluent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, I,

as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology I

and parameters in the ODCM to ensure that the alarm/trip will occur prior to exceeding 10 times the limits of 10 CFR Part 20. The OPERABILITY and use of I

this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. I I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE 16 OF76 I 6.2.3 Liquid Effluent Dose Li~t

a. Requirement I At least once per 31 days, perform the dose calculations in Step 6.2.3.c. to ensure the dose or dose commitment to the maximum exposed member of the public from

• radioactive materials in liquid releases (from each reactor unit) to unrestricted areas I is limited to:

1. During any calendar quarter:

I

• Less than or equal to 1.5 mrem to the total body

• Less than or equal to 5 mrem to the critical organ I 2. During any calendar year:

• Less than or equal to 3 mrem to the total body I

• Less than or equal to 10 mrem to the critical organ I b. Action If the calculated dose from release of radioactive materials in liquid effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a I special report in accordance with VP AP-2802, Notifications and Reports, that identifies causes for exceeding limits and defines corrective actions taken to reduce I releases of radioactive materials in liquid effluents to ensure that subsequent releases will be in compliance with the above limits.

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I DOMINION VPAP-2103S REVISI0N20 PAGE 17 OF76 I

c. Dose Contribution Calculations I NOTE: All critical organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated. I Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation:

I D = tFM"C-A- L..,; 1 1 (6) I where: I Subscripts = i, refers to individual radionuclide I

D = the cumulative dose commitment to the total body or critical organ from the t =

liquid effluents for the period t, in mrem the period for which Ci and F are averaged for all liquid releases, in hours I

M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix l lA, Surry UFSAR I

=

F the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas I

Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL I

Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and I beta emitter in mrem/hr per µCi/mL (7) I I

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I DOMINION VPAP-2103S I REVISI0N20 PAGE 18 OF76 I For example:

1.14 E+05 = l E+06 pCi/µCi x 1 E+03 mliL'/ (8760 hr/yr), units conversion I factor 21 = adult fish consumption, kg/yr, from NUREG-0133 I 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 Bli = the salt water bioaccumulation factor for nuclide i, in invertebrates, I pCi/kg per pCi/L BFi = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per I pCi/L DFi= the critj.cal organ dose conversion factor for nuclide i, for adults, in I mrem/pCi NOTE: The above parameters_ were obtained from RG. 1.109, Rev. 1, LADTAP II and I VCRL-50564, Rev. 1.

d. Quarterly Composite Analyses For radionuclides not determined in each batch or weekly comp9site, dose contribution to current monthly or calendar quarter cumulative summation may be I approximated by assuming an average monthly concentration based on previous monthly or quarterly composite analyses. However, for reporting purposes, I calculated dose contribution shall be based on the actual composite analyses.

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I DOMINION VPAP-2103S REVISION20 PAGE 19 OF76 I

e. Bases - Dose Due To Liquid Effluents

!his control is provided to implement the requirements of Sections II.A, III.A, and I

IV.A of Appendix I to 10 CFR Part 50. The control implements the guides set forth in Section II.A. The ACTION statement provides the required operating flexibility I

and at the same time implements the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to I UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and parameters in the ODCM implement the requirements in Section III.A that conformance with the guides of Appendix I be I

shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations I

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 I 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 I

1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. I 6.2.4 Liquid Radwaste Treatment Historical data pertaining to the volumes and radioactivity of liquid effluents released I

in connection with specific station functions, such as maintenance or refueling outages, shall be used in projections as appropriate. I

a. Requirement

1. The Surry Radwaste Facility Liquid Waste System shall be used to reduce the I

radioactive materials in liquid waste prior to discharge when projected dose due to liquid effluent, from each reactor unit, to unrestricted areas would exceed I 0.06 rnrem to total body or 0.2 rnrem to the critical organ in a 31-day period.

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

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DOMINION VPAP-2103S REVISI0N20 I PAGE200F76 I b. Action If radioactive liquid waste is discharged without treatment and in excess of the I above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Nqtifications and Reports, that includes the following:

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

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

I 3. Summary description of actions taken to prevent recurrence.

I c. Projected Total Body and Critical Organ Dose Calculation

• 1. Determine DL, the sum of all liq?id open and closed release points, in mrem, by I the ith organ, for the quarter.

2. Determine P, the Projection Factor, which is result of 31 divided by the number I of days from start of the quarter to the end of the release.

3. Determine Da, additional anticipated dose for liquid releases by the ith organ for I the particular quarter of the release.

4 .. Determine Dp, the 31 day projected dose by the ith organ:

I Dp = (DL x P) + Da

d. Bases.- Liquid Radwaste Treatment System I The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to I release to the environment. The requireme11:t provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CFR 50.36a, General I Design Criterion 60 of Appendix A to 10 CFR Part' 50 and the design objective given in Section II.D of Appendix I to 10 CFR Part 50. The specified limits I 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 I Section II.A of Appendix I, 10 CPR Part 50 for liquid effluents.

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I DOMINION VPAP-2103S REVISlON20 PAGE21 OF76 I 6.2.5 Liquid Sampling I Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid WasJe Sampling and Analysis I Program (Attachment 3).

6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitations I

a. Requirement Dose rate due to radioactive materials released in gaseous effluents from the site to I

areas at and beyond the site boundary shall be limited to:

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

_and::; 3000 mrem/ye¥ to the skin.

2. The dose rate limit for 1131 , 1133 , for tritium, and for all radioactive materials in I

particulate form with half-lives greater than 8 days shall be::; 1500 mrem/year to the critical organ. I

b. Action

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

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

3. Dose rates due to l 131 , l 133 , tritium, and all radionuclides in particulate form I with half-lives greater than 8 days, in gaseous effluents shall be determined to be within the above limits by obtaining representative samples and performing I analyses in accordance with the sampling and analysis program specified on Radioactive Gaseous WasteSampling and Analysis Program (Attachment 4).

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I DOMINION VPAP-2103S REVISION 20

• PAGE220F76 I c. Calculations of Gaseous Effluent Dose Rates

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

Li

• x + (K1* Qipv

• x-Q. ) ] :5: 500 mrem/yr to the total body I [ ( K. Qivv -Q.

1 lVV

) lpV (8)

OR I

• x ) + ((L *+1.1M.)Qipv-Q*

• x )]:5:3000mrem/yrtotheskm. (9)

L[( (L 1*+1.1M.)Qivv-Q*

I 1 lVV 1 . 1 lpV where:

I

• Subscripts = vv, refers to vent releases from the building ventilation vent, including Radwaste Facility Ventilation Vent; I pv, refers to the vent releases from the process vent; i, refers to individual radionuclide Ki = the total body dose factor due to gamma emissions for each I L*1 identified noble gas radionuclide i, in mrern/yr per Curie/m3

= the skin dose factor due to beta emissions for each identified noble gas radionuclide i; in mrern/yr per Curie/m3 I Mi = the air dose factor. due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/m3 Qivv, Qipv = the release rate for ventilation vents or process vent of noble I 1.1 gas radionuclide i, in gaseous effluents in Curie/sec (per site)

= the unit conversion factor that converts air dose to skin dose, in mrern/mrad I X/Qivv, X/Qipv = the gaseous dispersion factor, sec/m3(See Attachment 7)

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I DOMINION VPAP-2103S REVISI0N20 PAGE23 OF76 I

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

limit by restricting the release rate to:

I L . .k . .k

[PiQivv Qivv + PiQipvQipv] ~ 1500 mrem/yrto the critical organ (10) I i

where:

p.

1 = the critical organ dose factor for r131 , r133 , H 3 , and all I

radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, .in mrern/yr per Curie/m3 I

Q;vv,Qipv = the release rate for ventilation vents or process vent of I 131 ,

I 133 , H 3 , and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec I

(per site)

X!Qivv, X!Qipv = the gaseous dispersion factor, seclm3(See Attachment 7)

3. All gaseous releases, not through the process vent, are considered ground level I

and shall be included in the determination of Q;vv.

d. Bases - Dose Rate I

This specification provides reasonable assurance radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE I

PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE BOUNDARY, in excess of the design objectives of Appendix I to 10 CFR Part 50. I This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and II.C design objectives of Appendix I

• Ito 10 CFR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF I

THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrern/year to the whole body, less than or equal to 3000 mrern/year to the skin and I the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrern/year. This specification does not affect the requirements to comply with the annual limitation of 10 CFR 20.1301(a). This I

control applies to the release of radioactive materials in gaseous effluents from all units at the site.

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I DOMINION VPAP-2103S REVISION20 I PAGE240F76 I 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement I 1. The radioactive gaseous effluent monitoring instrumentation channels shown.in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.1.a. noble gas I limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3 .2.d.

I 2. Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated operable by Channel Checks, Source Checks, Channel I Calibrations, and Channel Functional Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance I Requirements (Attachment 6).

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

• Suspend the release of radioactive gaseous effluents monitored by the affected I channel and declare the channel inoperable or I

• Change the setpoint so it is acceptably conservative

2. If the number of operable channels is less than the minimum required by tables I in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment4),

take the action shown in those tables.

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE25 OF76 I

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

determined are:

Release Point Instrument Number I

Process Vent Condenser Air Ejector 1-GW-RM-130B l-SV-RM-111 I

2-SV-RM-211 Ventilation Vent No. 1 Ventilation Vent No. 2 1-VG-RM-104 1-VG-RM-131B I

Radwaste Facility Vent RRM-101 I

d. Setpoint Calculations

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

I (11) I where:

D = Step 6.3. l .a. dose limits that implement Technical Specifications for I

the Station, mrem/yr Dpv = the noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr I

Dcae = the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr I Dvv = the noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr I I

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I DOMINION VPAP-2103S REVISION20 I PAGE26 OF76 I 2. Setpoint values shall be determined by:

Rm x 2.12 E-03 I Fm (12)

I where:

m = the release pathway, process vent (pv), ventilation vent (vv)

I cm condenser air ejector (cae), or Radwaste Facility (rv)

= the effluent concentration limit implementing Step 6.3. l. a. for the Station, µCi/rnL I Rm = the release rate limit for pathway m determined from methodology in Step 6.3. l.c., typically using Xe 133 as nuclide to be released, µCi/sec I 2.12E-03 Fm

= CFM per rnL/sec

= the maximum flow rate for pathway m, CFM I NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply I instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

I e. Bases - Radioactive Gaseous Effluent Monitoring Instrumentation The radioactive gaseous effluent instrumentation is provided to monitor and I control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The Alarm/Trip Setpoints I for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the alarm/trip will occur prior to exceeding the gaseous effluent dose rate limits of Section 6.3 of the ODCM.

I The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A I to 10 CFR Part 50.

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I DOMINION VPAP-2103S REVISI0N20 PAGE 27 OF76 I 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement I

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

I

• During any calendar quarter: s 5 mrads for gamma radiation and s 10 mrad for beta radiation I

• During any calendar year: s 10 mrads for gamma radiation ands 20 mrad for beta radiation I

2. Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with Step 6.3.3.c. I at least once per 31 days.

b. Action I If the calculated air dose from radioactive noble gases in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that identifies the I

causes for exceeding the limits and defines corrective actions that have been taken to reduce releases and the proposed corrective actions to be taken to assure that I subsequent releases will be in compliance with the limits in Step 6.3.3.a.

c. Noble Gas Effluent Air Dose Calculation I

Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of <1.vv- I The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: I For gamma radiation:

I (13)

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I DOMINION VPAP-2103S I REVISlON20 PAGE28 OF76 I For beta radiation:

I (14)

I Where:

Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air I* ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide

• I Dg Db the air dose for gamma radiation, in mrad

= the air dose for beta radiation, in mrad Mi = the air dose factor due to gamma emissions for each identified I Ni noble gas radionuclide i, in mrad/yr per Curie/m3 the air dose factor due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 I* Qivv, Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site)

I 3 .17 E-08 X/Qivv, X!Qipv

= the inverse of the number of seconds in a year

= the gaseous dispersion factor, sec/m3 (See Attachment 7) 6.3.4 l-131, 133, H-3 & Radionudides in Particulate Form Effluent Dose Limit I , a. Requirement

1. Methods shall be implemented to ensure that the dose to any organ of a member I of the public from 1131 , 1133 , tritium, and all radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released from the site to I unrestricted areas from each reactor unit shall be:

• During any calendar quarter: ~ 7.5 mrem to the critical organ

• During any calendar year: ~ 15 mrem to the critical organ I 2. Cumulative dose contributions to a member of the public from l 131 , l 133 ,

I tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents released to unrestricted areas for the current calendar quarter and current calendar year shall be determined at least once per 31 days I in accordance with Step 6.3.4.c.

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. DOMINION . VPAP-2103S REVISI0N20 PAGE29 OF76 I

b. Action If the calculated dose from the release of I 131 , I 133 , tritium, and radionuclides in I

particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special I

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

1. Causes for exceeding limits.

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2. Corrective actions taken to reduce releases.

3. Proposed corrective actions to be taken to assure that subsequent releases will I

be in compliance with limits stated in Step 6.3 .4.a.

I C. Dose Calculations NOTE: All critical organ doses for each age group are calculated to determine which is the I limiting organ for the period being evaluated.

Gaseous releas.es, not through the process vent, are considered ground level and I

shall be included in the determination ofQ;vv. Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection I

to specific Station functions, such as containment purges, shall be used in the estimates, as appropriate. I I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE 30 OF76 I 1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary that contain I 131

,I 133

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

I Dr= 3.17E- 08 IL

[RM ( Qivv

• Df Qvv + Qipv

• D/QPJ + RI( Qivv .XfQvv + Qipv .X/QPJ (15)

+ RG ( Qivv ' D/ Qvv + Qipv

• D/ QpJ + RH 3 ( Qivv 'X/ Qvv + Qipv

• X/ QpJ]

I For example:

I Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors; I pv, refers to the vent releases from the process vent

= the dose to the critical organ of the maximum exposed member of the public in mrem I = the release for ventilation vents or process vent of I 131 , I 133 ,

tritium, and from all particulate-form radionuclides with half-lives greater than 8 days in Curies I 3.17 E-08 = the inverse of the number of seconds in a year 3

X!Qvv, X!Qpv = the gaseous dispersion factor, sec/m (See Attachment 7) 2 D!Qvv, D!Qpv = the gaseous deposition factor, m- (See Attachment 7)

I RM = the milk pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than I RI eight days, in m2-mrern/yr per Ci/sec 131 133

= the inhalation pathway dose factor due to I , I , tritium, and from all particulate-form radionuclides with half-lives I RG greater than eight days, in mrern/yr per Ci/m3

= the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives I RH3 greater than eight days, in m 2-mrern/yr per Ci/sec

= the tritium dose factor for milk in mrern/yr per Ci/m3 I

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I DOMINION VPAP-2103S REVISI0N20 PAGE 31 OF76 I 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous I

effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

I

a. Requirement

1. Appropriate portions of the Gaseous Radwaste Treatment System shall be used I

to reduce radioactive materials in gaseous waste before its discharge, when the projected gaseous effluent air doses due to gaseous effluent releases, from each I

unit to areas at and beyond the site boundary, would exceed 0.2 mrad for gamma radiation and 0.4 mrad for _beta radiation, averaged over 31 days. I

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

I

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

I

b. Action If gaseous waste that exceeds the limits in Step 6.3.5.a. is discharged without treatment, prepare and submit to the NRC, within 30 days, a special report in I

accordance with VPAP-2802, Notifications and Reports, that includes:

1. An explanation why gaseous radwaste was being discharged without treatment, I

identification of any inoperable equipment or subsystems, and the reason for the inoperability.

I

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

3. Summary description of actions taken to prevent recurrence.

I

c. Projected Dose Calculations I

1. Determine Dg, the sum of all gaseous open and closed release points, in mrem, by the ith organ, for the quarter. I

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days from start of the quarter to the end of the release. I I

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I DOMINION VPAP-2103S I REVISI0N20 PAGE320F76 I 3. Determine Da, additional anticipated dose for gaseous releases by the ith organ for the particular quarter of the release.

I 4. Determine Dp, the 31 day projected dose by the ith organ.

Dp = (Dg x P) + Da I 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose I limits are not exceeded when making releases. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not I allow for a prerelease assessment and are evaluated on a case by case basis.

I 6.4.1 Liquid Waste Batch Releases

a. Operations shall obtain RP authorization before initiating batch releases of radioactive liquids.

I b. Release of contents from the following tanks/sumps other than transfers to the Radwaste Facility shall have a release permit before the discharge. Examples of I batch releases include:

• Turbine Building Sumps when RP determines that source activity requires I placing pumps in manual mode

• Condensate Polishing Building Sumps and Steam Generator secondary water I when RP determines the presence of contamination from primary-to-secondary leakage I

• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases I a. Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids.

I b. Examples of continuous releases include:

• Steam generator blowdown I

• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable I

• Storm drains, equipped with composite sampling systems, that receive run-off from rain and turbine building sumps, subsurface drains and ground water wells when pumps are in automatic mode.

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I DOMINION VPAP-2103S REVISION20 PAGE 33 OF76 I 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases.

I 6.4.4 Reactor Containment Release Permits I Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

I

• Routine termination I

• Terminated for cause by RP

• Receipt of Radiation Monitoring System (RMS) Containment Gas Monitor high I alarm 6.4.5 Miscellaneous Gaseous Release Permit I Operations shall obtain RP authorization before initiating releases of noble gases that may not be accounted for by routine sampling, or any planned release not being routed through the Process Vent or Ventilation Vents.

I 6.4.6 Radioactive Liquid and Gaseous Release Controls I

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

I

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

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

time of sample) for samples obtained outside the Primary Sample Room. I

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses. I

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

" Maximum authorized release rate I

• Applicable conditions or controls pertaining to the release I

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I DOMINION VPAP-2103S I REVISI0N20 PAGE340F76 I e. RP shall notify the Operations Shift Supervision if it is determined that a release may not be within the effluent dose limits.

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

1. Verify the correct source is authorized for release.

I 2. Note maximum authorized release rate.

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

I g. When commencing release, Operations shall provide RP with required information.

As appropriate, required information shall include:

• Date and time release was started I

• Starting tank/sump level

• Beginning pressure I

• Release flow rate

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

• Date and time release was stopped I

• Tank/sump ending level

• Release flow rate just prior to termination I

• Ending pressure

• Volume released I 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement I The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not I exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

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I DOMINION VPAP-2103S REVISI0N20 PAGE35 OF76 I 6.5.2 Action I

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage I

tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC, I

within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases I and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CFR 20.2203(a)(4), shall include: I

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

I

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

I

3. If the estimated dose exceeds the limits in Step 6.5 .1, and if the release I condition that violates 40 CFR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request, and a I

variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring I

6.6.1 Monitoring Program

a. Requirement I

1. The Radiological Environmental Monitoring Program shall be conducted as specified in Radiological Environmental Monitoring Program (Attachment 8). I

2. Samples shall be collected from specific locations specified in Environmental Sampling Locations (Attachment 9). I I

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I DOMINION VPAP-2103S REVISION20 I PAGE360F76 I 3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 8)

I requirements

• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 10)

I

• Guidance of the Radiological Assessment Branch Technical Position on Environmental Monitoring dated November, 1979, Revision No. 1 I b. Action

1. If the Radiological Environmental Monitoring Program is not being conducted I as required in Step 6.6.1.a., report the situation in accordance with VPAP-2802, Notifications and Reports, by preparing and submitting to the NRC, in the I Annual Radiological Environmental Operating Report required by Technical Specification (Surry Technical Specification 6.6.B.2), a description of the reasons for not conducting the program as required, and the plan for precluding I recurrence.

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting

.I levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11), prepare and submit to the NRC, within 30 days, a I special report in accordance with VPAP-2802, Notifications and Reports, that:

• Identifies the causes for exceeding the limits, and I

• Defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a member of the public is less than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4 I When more than one of the radionuclides listed in Reporting Levels for I Radioactivity Concentrations in Environmental Samples (Attachment 11) are detected in the sampling medium, the report shall be submitted if:

I concentration (1) + concentration (2) + ... ;;::: l.O reporting level (1) reporting level (2)

(lS)

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DOMINION VPAP-2103S I

REVISI0N20 PAGE37 OF76 I

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) are I

detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the I calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant effluents; I however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

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4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program I

(Attachment 8), identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The I specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of I samples and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports.

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5. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction I

of automatic sampling equipment and other legitimate reasons. If specimens are unavailable due to sampling equipment malfunction, every effort shall be made I 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 report in accordance with VPAP-2802, Notifications and Reports.

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I DOMINION VPAP-2103S REVISION20 I PAGE380F76 I 6.6.2 Land Use Census

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

• Nearest milk animal I

• Nearest residence

• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation I 1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g.,

I door-to-door survey, aerial survey, local agriculture authorities). Land use census results shall be included in the Annual Radiological Environmental I Operating Report in accordance with VPAP-2802, Notifications and Reports.

2. In lieu of the garden census, broad leaf vegetation sampling of at least three I different kinds of vegetation may be performed at the site boundary in each of two different direction sectors with the highest predicted ground deposition I (D/Qs). Specifications for broad leaf vegetation sampling in Radiological Environmental Monitoring Program (Attachment 8) shall be followed, including analysis of control samples.

I b. Action

1. If a land use census identifies locations that yield a calculated dose or dose I commitment greater than the values currently being calculated in Step 6.3.4.a.,

identify the new locations in the next Annual Radioactive Effluent Release I Report in accordance'with VP AP-2802, Notifications and Reports.

2. If a land use census identifies locations that yield a calculated dose or dose I commitment (via the same exposure pathway) 20 percent greater than at a location from which samples are currently being obtained, add the new I locations to the Radiological Environmental Monitoring Program within 30 days. Sampling locations, excluding the control station location., that have the lowest calculated dose or dose commitments (via the same exposure pathway)

I may be deleted from the monitoring program. Identify new locations in the next Annual Radioactive Effluent Release Report and include in the report revised I figures and tables reflecting the new locations in accordance with VPAP-2802, Notifications and Reports. [Commitment 3.2.1]

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DOMINION I

VPAP-2103S REVISI0N20 PAGE39 OF76 I 6.6.3 Interlaboratory Comparison Program

a. Requirement I

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

b. Action

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

I Program Cross-Check of I

Milk 1131 , Gamma, Sr89 and Sr90 Water Gross Beta, Gamma, 1131 , H 3 (Tritium), Sr89 I and Sr90 (blind-any combinations of above Air Filter radionuclides)

Gross Beta, G~a, Sr90 I

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

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

I 6.7 Reporting Requirements I 6.7.1 Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year.

I A single submittal may be made for the Station. Radiological Environmen.tal Operating Reports shall include:

I

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

I

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports I

• An assessment of the observed impacts of the plant operation on the environment

• Results of land use census per Step 6.6.2 I I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE400F76 I . b. Results of analysis of radiological environmental samples and of environmental radiation measurements taken per Step 6.6.1, Monitoring Program. Results shall be I summarized and tabulated in the format of the table in the Radiological Assessment Branch Technical Position on Environmental Monitoring.

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

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

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

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

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

I f. Discussion of deviations from the Station's environmental sampling schedule per Radiological Environmental Monitoring Program (Attachment 8).

I g. Discussion of analyses in which the lower limit of detection (LLD) required by I Detection Capabilities for Environmental Sample Analysis (Attachment 10) was not achievable.

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE41 OF76 I NOTE: NUREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are I

also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CFR Part 190."

I 6.7.2 Annual Radioactive Effluent Release Report

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

are common to both units. Radioactive Effluent Release Reports shall include:

1. A summary of quantities of radioactive liquid and gaseous effluents and solid I

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

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

[Commitment 3.2.2]

2. An assessment of radiation doses to the maximum exposed members of the I public due to the radioactive liquid and gaseous effluents released from the Station during the previous calendar year. This assessment shall be in accordance with Step 6.7 .2.b.

I

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

I

• Unplanned releases that exceeded the limits in Steps 6.2.1 and 6.3.l

• Unplanned releases which require a Condition Report and involve the I

discharge of contents of the wrong Waste Gas Decay Tan1c or the wrong liquid radwaste release tan1c I

• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors I

or 10 CFR 50.73, Licensee Event Report System, report is required

• Unplanned releases as determined by Radiation Protection Supervision, I

which may or may not require a Condition Report I

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I DOMINION VPAP-2103S I REVISION20 PAGE420F76

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

I 5. Changes to VPAP-2103S, Offsite Dose Calculation Manual (Surry) (See Step 6.7.4).

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

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

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

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

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

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

I b. Dose Assessment - Station

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

I Population doses shall not be included in dose assessments.

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

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE43 OF76 I NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI I are separate and not submitted as a combined report.

c. Requirement " ISFSI I

1. Radioactive Effluent Release Report covering operation of the ISFSI during the previous 12 months of operation shall be submitted within 60 days after January 1.

I

2. The ISFSI Radioactive Effluent Release Report shall specify the quantities of I each of the principal radionuclides released to the environment in liquid and in gaseous effluents.

3. Dose Assessment " ISFSI I

Provide such information as may be required by the Commission to estimate potential radiation dose commitment to the public resulting from effluent I

releases from the ISFSI.

6.7 .3 Annual Meteorological Data I

a. Meteorological data collected during the previous year shall be in the form of joint

frequency distributions of wind speed, wind direction, and atmospheric stability. I

b. Meteorological data shall be retained in a file on site and shall be made available to NRC upon request. I 6.7.4 Changes to the ODCM Changes to the ODCM shall be: I

a. Approved by the Site Vice President before implementation.

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

I Documentation shall include:

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

evaluations justifying changes.

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I DOMINION VPAP-2103S REVISI0N20 I PAGE44 OF76 I 2. A determination that a change will not adversely impact the accuracy or reliability of effluent doses or setpoint calculations, and will maintain the level I of radioactive effluent control required by:

• 10 CFR 20, Subpart D

• 40 CFR 190 I

• 10 CFR 50.36a

• 10 CFR 50, Appendix I

' Specifications I

• Technical

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

I d. Submitted to NRC in accordance with VPAP-2802, Notifications and Reports.

I 6.7.5 Industry Ground Water Protection Initiative

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

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

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE45 OF76 I

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

• An off-site ground water or surface water sample result that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11). I

• An on-site surface water sample result, that is hydrologically connected to ground water, or ground water that is or could be used as a source of drinking water, that exceeds the reporting criteria listed in Reporting Levels for I

Radioactivity Concentrations in Environmental Samples (Attachment 11).

I

c. 30-Day Reports I. Submit a written 30-day report to the NRC for a water sample result for on-site or off-site ground water that is or could be used as a source of drinking water I

that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11). A 30-day report is I

only required on the initial discovery of a contaminated ground water plume.

2. Concurrently submit a copy of the written 30-day NRC report to the appropriate I

State and Local officials.

d. Annual Reports I

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

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

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

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

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I DOMINION VPAP-2103S REVISI0N20 I PAGE46 OF76 7.0 RECORDS 7.1 The following record(s) completed as a result of this procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

I 7 .1.1 Quality Assurance Records

• Records of changes to the ODCM in accordance with Step 6.7.4 I

• Records of meteorological data in accordance with Step 6.7 .3 I

• Records of sampling and analyses

• Records of radioactive materials and other effluents released to the environment I

• Records of preventive maintenance, surveillances, and calibrations 7.1.2 Non-Quality Assurance Records 11, None 7.2 The following record(s) completed as a result of this procedure are NOT required to be I transmitted to Nuclear Document Management (NDM), but are required to be retained as indicated below. The NRRS has been updated and Alternate Storage approved per I RM-AA-101 for Quality Assurance Records.

7 .2.1 Quality Assurance Records None 7 .2.2 Non-Quality Assurance Records I None 7.3 The following item(s) completed as a result of this procedure are NOT records and are NOT I required to be transmitted to Nuclear Document Management (NDM).

None I

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VPAP-2103S I

DOMINION REVISION20 PAGE47 OF76 I ATTACHMENT 1 (Page 1 of 1)

I Radioactive Liquid Effluent Monitoring Instrumentation I

Instrument Minimum Operable Channels Action I

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

2.

RE-RRM-131 GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC 1 1 I

TERMINATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 1 2 I

Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, 1 2 I

l-SW-RM-107A 1 2 l-SW-RM-107B l-SW-RM-107C 1

1 2

2 I

l-SW-RM-107D 1 2*

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, I

Instrument Loop RLW-153 ACTION 1:

1 3 If the number of operable channels is less than required, effluent releases via this I

ACTION 2:

pathway shall be suspended.

If the number of operable channels is less than required, effluent releases via this I

pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid

• Waste Sampling and Analysis Program (Attachment 3). When the effluent release via I

this pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Sch~dule" attachment in HP-3010.021, I Radioactive Liquid Waste Sampling and Analysis.

ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 30 minutes I

during the actual releases. Design capacity pump performance curves generated in place or volume released over time may be used to estimate flow. I I

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I DOMINION VPAP-2103S REVISION20 I PAGE48 OF76 I ATTACHMENT 2 (Page 1 of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements I

I Channel Description

~

Channel Check Source Check Channel Channel Calibration !Functional Tes1

1. GROSS RADIOACTIVITY MONITORS I PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, I RE-RRM-131 D p R Q

2. GROSS BETA OR GAMMA RADIOACTIVI-I TY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERM!-

NATION OF RELEASE I (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 D M \

R Q Unit 2: 2-SW-RM-220 I (b) Component Cooling Service Water Effluent Lines, 1-SW-RM-107A I 1-SW-RM-107B l-SW-RM-107C D M R Q 1-SW-RM-107D I' 3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, I Instrument Loop RLW-153 DR NIA R NIA I

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I DOMINION VPAP-2103S REVISI0N20 PAGE49 OF76 I ATTACHMENT 3 (Page 1 of 3) 1.

Radioactive Liquid Waste Sampling and Analysis Program I

Liquid Release Type Sampling Frequency Minimum Analysis Frequency.

Type of Activity Analysis Lower Limit of Detection (LLD)

I

(µCi/mL), (Note 1) p p Principal Gamma Emitters (Note 3) 5 X 10-1 I 1 X 10-6 (Each Batch) p (Each Batch) 1131

• Dissolved and I

Batch Releases M Entrained Gases 1 X 10-5 (Note 2)

(One Batch/M) p (Gamma Emitters)

H3 1 X 10-5 I

MComposite (Each Batch) (Note 4) Gross Alpha 1 X 10-7 I p Q Composite

• Sr89 and sr9° 5 X 10-8 I

(Each Batch) (Note 4) Fe55 1 X 10-6 Continuous WComposite Principal Gamma Emitters (Note 6) 5 X 10-7 I (Note 6) (Note 6) 1131 Dissolved and 1 X 10-6 I

Continuous M 1 X 10-5 Releases Grab Sample M Entrained Gases (Gamma Emitters) I (Note 5)  ;

Continuous M Composite H3 1 X 10-S (Note 6) (Note 6) Gross Alpha 1 X 10-7 I

Continuous Q Composite Sr89 and Sr90 5 X 10-8 I (Note 6) . (Note 6) .. Fe55 1 X 10-6 I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE500F76 I ATTACHMENT 3 (Page 2 of 3)

Radioactive Liquid Waste Sampling and Analysis Program I NOTE 1: For a particular measurement system (which may include radiochemical separation):

I LLD (8-1)

I E

• V

• 2.22E+06 *Yo e-(Ab.t)

Where:

LLD the "a priori" (before the fact) Lower Limit of Detection (as microcuries per unit mass or volume) (See Subsection 4.9)

I Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm)

I E the counting efficiency (as counts per disintegration)

I V = the sample size (in units of mass or volume) 2.22E+06 the number of disintegrations per minute (dpm) per microcurie I Y the fractional radiochemical yield (when applicable)

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

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

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

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I DOMINION VPAP-2103S REVISION20 PAGE51 OF76 I ATTACHMENT 3 (Page 3 of3)

I Radioactive Liquid Waste SampHng and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the I

following radionuclides: Mn54, Fe59 , Co 58 , Co 60 , Zn65 , Mo 99 , Cs 134, Cs 137, Ce 141 , and Ce144. This list does not mean that only these nuclides are to be detected and reported.

I Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. . I NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the .

quantity ofliquid waste discharged and for which the method of sampling employed results I in a specimen that is representative of the liquids released.

NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from I a volume of a system that has an input flow during the continuous release.

NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid I effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release. I I

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I DOMINION VPAP-2103S REV1SlON20 I PAGE520F76 ATTACHMENT 4 I (Page 1 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program I

I Gaseous Release Type Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

(µCi/mL), (Note 1)

I A. Waste Gas Storage Tank Prior to Release (Each Tank)

Prior to Release (Each Tank)

Principal Gamma Emitters (Note 2) 1 X 10-4 (Grab Sample)

I B. Containment Prior to Release Prior to Release Principal Gamma Emitters (Note 2) 1 X 10-4 (Each PURGE)

I Purge C. Ventilation (Grab Sample)

Weekly (Each PURGE) H3 Principal Gamma 1 X 10-6 Weekly 1 X 10-4 (Grab Sample)

I (l)Process Vent (2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3)

Emitters (Note 2)

H3 1 X 10-6 (4)SRFVent I Continuous* Weekly (Note 5) 1131 1 X 10-lZ (Note 4) (Charcoal Sample) 1133 I Continuous Weekly (Note 5) Principal Gamma 1 X 10-lO 1 X 10-ll (Note 4) Particulate Sample Emitter (Note 2)

I All Release Types as listed Continuous Weekly Composite Gross Alpha 1 X 10-ll (Note 4)

Particulate Sample I in A, B, and C Continuous v_uarterly Composite -Sr89 and Sr90 1 X 10-ll (Note 4)

I Continuous (Note 4)

Particulate Noble Gas Monitor Noble Gases Gross Beta and Gamma 1 X 10-6 I Condenser Air Weekly Weekly Principal Gamma Emitters (Note 2) 1 X 10-4 Grab Sample I Ejector (Note 3)

(Note 3) H3 1 X 10-6 I

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I DOMINION VPAP-2103S REVISI0N20 PAGE 53 OF76 I ATTACHMENT 4 (Page 2 of 4)

I Radioactive Gaseous Waste Sampling and Analysis Program

.1 Gaseous Release Type Sampling Frequency Minimum Analysis Frequency Type of Activity Analysis Lower Limit of Detection (LLD)

I

(µCi/mL), (Note 1)

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

1131 1 X 10-ll Continuous Charcoal Sample Containment (Note 4) (Note 6) rB3 1 X 10-lO I Continuous Particulate Sample Principal Gamma HogDepres" surization (Note 4) (Note 6)

Composite Particu-Emitter (Note 2) 1 X 10-lO I

Continuous 1 X 10-lO (Note 4) late Sample (Note 6)

Gross Alpha I

Composite Particu-Continuous (Note 4) late Sample (Note 6)

Sr89 and Sr90 1 X 10-lO I

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I DOJvIINION VPAP-2103S REVISION20 I PAGE540F76 I ATTACHMENT 4 (Page 3 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program

'I NOTE 1: For a particular measurement system (which may i:q.clude radiochemical separation):

I LLD (10-1)

E

• V

• 2.22E+06 ~ Y

• e-(AL\t) *

'I

,I Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9).

I Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm).

E = the counting efficiency (as counts per disintegration).

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

2.22E+06 = the number.of disintegrations per minute.(dpm) per microcurie.

Y = the fractional radiochemical yield (when applicable).

A = the radioactive decay constant for the particular radionuclide.

L\t = the elapsed time between the midpoint of sample collection and time of counting:

Typical values of E, V, Y and L\t should be used in the calculation.

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

DOMINION VPAP-2103S REVISI0N20 PAGE 55 OF76 ATTACHMENT 4 (Page 4 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the I

followingradionuclides: Kr 87 , Kr 88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, andXe 138 for gaseous emissions and Mn54, Fe59 , Co58 , Co 60 , Zn65, Mo 99 , Cs 134 , Cs 137 , Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when: I

a. Analysis shows that the dose equivalent I 131 concentration in the primary coolant has increased more than a factor of 3; and I

b. The noble gas activity monitor shows that effluent activity has increased by more than a factor of 3. I NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4.

I NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing (or after removal from sampler). Sampling shall also be I'

performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for at least seven days following each shutdown, start-up, or thermal power change exceeding 15 percent of rated thermal power in one hour, and analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. When samples collected for 24

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

a. Analysis shows that the dose equivalent I 131 concentration in the primary coolant has increased by, a factor of 3; and

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

NOTE 6: To be representative of the quantities and concentrations of radioactive materials in gaseous effluents, composite sampling shall employ appropriate methods that will result in a specimen representative of the effluent release.

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I DOMINION VPAP-2103S REVISION20 I PAGE56 OF76 I ATTACHMENT 5 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation I

MINIMUM I 1. PROCESS VENT SYSTEM INSTRUMENT OPERABLE CHANNELS ACTION I (a) Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release:

1-GW-RM-130B 1 1 (b) Iodine Sampler:

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

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

1-GW-FT-100 1 3 (e) Sampler Flow Rate Measuring Device:

I HP Sampler Rotonieter or MGPI Flow Rate Measuring Device 1 3

2. CONDENSER AIR EJECTOR SYSTEM I (a) Gross Activity Monitor:

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

Unit 1: 1-VP-FI-lA 1-VP-FI-lB 1

1 3

3 I Unit 2: 2-VP-FI-lA 2-VP-FI-lB

3. VENTILATION VENT SYSTEM 1

1 3

3 (a) Noble Gas Activity Monitor:

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

1 1

1 Vent#2, 1-VG-RM-131B 1 1 I (b) Iodine Sampler:

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE 57 OF76 I ATTACHMENT 5 (Page 2 of2)

I Radioactive Gaseous Effluent Monitoring Instrumentation I

MINIMUM (c)

INSTRUMENT Particulate Sampler:

OPERABLE CHANNELS ACTION I

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

Vent#2, HP Continuous Sampler, or 1

1 2

2 I 1-VG-RM-131-1 (NOTE 1) 1 2 In-Line Particulate/ Iodine Sampler (d) Ventilation Vent Flow Rate Monitor:

I SRF: 01-RHV-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 Vent#2, 1-VS-FT-116 1

1 3

3 I (e) Sampler Flow Rate Measuring Device:

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

Vent #2, HP Sampler Rotometer or 1

1 1

3 3

3 I

MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, I

and noble gas components.

NOTE 2: Vent# 1, l-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample I flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.2.3]

I ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When the effluent release I via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4]

I ACTION 2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the initiation of this ACTION I

statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

ACTION 3:

[Commitment 3.2.4]

If the number of operable channels is less than required, effluent releases via this pathway may continue I

provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

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I DOMINION VPAP-2103S REVISI0N20 I PAGE58 OF76 I ATTACHMENT 6 (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements I CHANNEL CHANNEL CHANNEL SOURCE CHANNEL I DESCRIPTION

l. PROCESS VENT SYSTEM CHECK CHECK CALIBRATION FUNCTIONAL TEST (a) Noble Gas Activity Monitor -

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

Process Vent Continuous HP Sampler, or l-GW-RM-130-1 w NIA NIA NIA I In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1)

Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA I In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-FT-100 D NIA R NIA I (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D NIA SA NIA I MGPI Flow Rate Measuring Device

2. CONDENSER AIR EJECTOR SYSTEM D NIA R NIA (a) Gross Activity Monitor I Unit 1: 1-SV-RM-111 Unit 2: 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring D M R Q I Devi~e Unit 1: 1-VP-FI-lA 1-VP-FI-lB Unit 2: 2-VP-FI-lA D NIA R NIA I 2-VP-FI-lB

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE 59 OF76 I ATTACHMENT 6 (Page 2 of 2)

I Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL I

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

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

Sampler or l-VG-RM-131-1 In-Line Particulate I Iodine Sampler I (c) Particulate Sampler (NOTE 1)

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

w NIA NIA NIA Sampler or 1-VG-RM-131-1 In-Line Particulate I Iodine Sampler I

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

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

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

D NIA NIA R

R NIA NIA I Vent #2, HP Sampler Rotomete1 D NIA R NIA or MGPI Flow Rate Measuring Device D NIA SA NIA I NOTE 1:The mark numbers listed above in l(b), l(c), 3(b), 3(c), and 3(e) refer to the gaseous I

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

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I DOMINION VPAP-2103S REVISI0N20 I PAGE 60 OF76 I ATTACHMENT 7 (Page 1 of 1)

Dispersion and Deposition Factors I

Distance, Ventilation Vent Process Vent I Description Sector N

meters 500 XIQ l.4E-05 D/Q l.6E-08 X!Q 6.5E-08 D/Q 9.8E-10 I NNE 532 l.8E-05 3.2E-08 1.8E-07 3.0E-09 I I NE ENE 629 806 l.3E-05 7.4E-06 3.0E-08 l.3E-08 2.3E-07 l.9E-07 3.9E-09 2.8E-09 I

I E 1210 2.7E-06 7.2E-09 2.3E-07 2.6E-09 I I ESE SE 1984 1371 8.6E-07 2.0E-06 3.2E-09 6.8E-09 l.5E-07 l.8E-07 l.7E-09 2.5E-09 I

I SSE 919 4.0E-06 9.2E-09 2.lE-07 2.6E-09 I I Site Boundary SSW s 645 565 5.5E-06 5.7E-06 1.lE-08 1.2E-08 2.2E-07 l.9E-07 3.5E-09 3.9E-09 I

I SW 548 9.0E-06 l.9E-08 2.2E-07 4.2E-09 I I WSW w

565 565 7.6E-06 1.lE-05 l.6E-08 2.9E-08 2.4E-07 2.4E-07 4.6E-09 3.8E-09 I

I I WNW NW NNW 565 581 l.4E-05 l.3E-05 2.7E-08 l.7E-08 l.4E-07 2.0E-07 l.6E-09 2.9E-09 7.lE-10 I

I 581 l.OE-05 l.lE-08 7.4E-08 I I N NNE 6534 3122 7564 2.6E-07 1.0E-06 2.lE-10 l.7E-09 6.0E-08 l.7E-07 l.lE-10 5.9E-10 I

I NE 2.9E-07 4.2E-10 5.9E-08 2.0E-10 I I SE SSE s

4554 4265 3.2E-07 3.5E-07 8.5E-10 6.6E-10 6.2E-08 7.lE-08 3.2E-10 3.3E-10 I

I 2736 5.2E-07 9.5E-10 l.5E-07 7.5E-10 I I Resident SSW SW 2977 3637 3.7E-07 4.lE-07 7.5E-10 7.8E-10 l.OE-07 8.6E-08 5.7E-10 4.3E-10 I

I WSW 660 5.9E-06 l.3E-08 2.3E-07 4.lE-09 I I w WNW 5053 7886 3.2E-07 2.3E-07 7.2E-10 2.9E-10 6.2E-08 4.4E-08 2.5E-10 1.lE-10 I

I NW 7467 2.5E-07 2.2E-10 5.0E-08 l.5E-10 I I NNW SSW 6035 7693 2.6E-07 9.2E-08 2.0E-10 l.4E-10 5.7E-08 4.0E-08 l.OE-10 1.3E-10 I

Mille Animal NNW 5938 2.6E-07 2.lE-10 5.8E-08 1.0E-10 I I SSE s

4265 3235 3.5E-07 4.0E-07 6.6E-10 7.lE-10 7.lE-08 l.3E-07 3.3E-10 5.6E-10 SSW 3122 3.SE-07 6.9E-10 9.7E-08 5.2E-10 I Garden SW WSW 7596 5713 1.4E-07 l.9E-07 2.lE-10 3.2E-10 4.lE-08 5.6E-08 l.4E-10 2.2E-10 w 5536 2.8E-07 6.lE-10 5.8E-08 2.2E-10 I NNW 7017 2.lE-07 l.6E-10 4.9E-08 9.3E-ll I

I DOMINION VPAP-2103S REVISI0N20 PAGE 61 OF76 I ATTACHMENT 8 (Page 1 of 3)

I Radiological EnvironmentalMonitoring Program I

Exposure Pathway and/or Sample Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis I

1. DIRECT RADIATION About 40 Routine Monitoring I Stations to be placed as fol-lows:

1) Inner Ring in general area of site boundary with GAMMADOSE I

station in each sector

2) Outer Ring 6 to 8 km from the site with a station in Quarterly Quarterly I

each sector (NOTE 1)

3) The balance of the 8 dosimeters should be I

placed in special interest areas such as population centers, nearby residents, I schools, and in 2 or 3 areas

2. AIRBORNE to serve as controls I

Samples from 7 locations:

a) 1 sample from close to the site boundary location of I

the highest calculated Radioiodine Canister annual average ground level Continuous 1131 Analysis Weekly I

Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 km distance located in a concentric ring around the operation with !Particulate Sampler sample collection weekly Gross beta radioactivity analysis following filter I

Station c) 1 sample from a control location 15-30 km distant, -

change; Gamma isotopic analysis of I

composite (by providing valid background data

. location) quarterly I

NOTE 1: As described in the Branch Technical Position, Revision 1, November 1979, no TLD station is required in the SE sector at the 4-5 mile range due to geographical limitations.

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1 I DOMINION VPAP-2103S REVISION20 I PAGE620F76 I ATTACHMENT 8 (Page 2 of3)

Radiological Environmental Monitoring Program I

I Exposure Pathway and/or Sample Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis

3. WATERBORNE I a) Surface a) 1 sample upstream Monthly Sample Gamma isotopic analysis monthly; b) 1 sample downstream Composite for tritium analysis I b) Ground Sample from 1 or 2 sources Quarterly quarterly Gamma isotopic and tritium analysis _quarterly I c) Sediment from shoreline a) 1 sample upstream b) 1 sample downstream Semi-Annually Gamma isotopic analysis semi-annually a) 1 sample upstream I d) Silt b) 1 sample downstream Semi-Annually Gamma isotopic analysis semi-annually c) 1 sample in channel at I 4. INGESTION Station Intake

. I a) Milk a} 2 samples from milking I animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and 1131 b) 1 sample from milking Monthly analysis monthly I animals at a control location (-15-30 km from the station). (NOTE 2) a) 6 samples of filter feeders I b) Fish and (clams, oysters) in the vicinity of the Station Semi-Annually Invertebrates Gamma isotopic on edible I c) 1 sampling of crabs from the vicinity of the Station Annually portions d) 1 sampling of 2 different I species in vicinity of Station discharge area.

(NOTE3)

Semi-Annually I NOTE 1: If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station.

NOTE 2: If milk sampling from a control location cannot be performed, use item 4.c) e).

I NOTE3:

Mille sampling cannot be performed when there is no milk sampling location 30 km from the station.

Commercially or recreationally important species permitted for sampling by the Vrrginia Marine Resources I

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I DOMINION VPAP-2103S REVISI0N20 PAGE 63 OF76 I ATTACHMENT 8 (Page 3 of3)

I Radiological Environmental Monitoring Program I

Exposure Pathway and/or Sample Number of Sample and Sample Location Collection Frequency Type and Frequency of Analysis I

4. INGESTION (Continued)

I a) 1 sample corn b) 1 sample soybeans Annually, at time

' of harvest (for Gamma isotopic on edible portions I

c) 1 sample peanuts harvested crops) d) 1 sample of a broadleaf vegetation grown I

nearest in each of two different available o:ffsite locations I

c) Food Products (sectors) with the highest annual average ground level D/Qs, if Monthly, if I

Gamma isotopic and I 131 available, or at milk sampling is not performed.

e) 1 sample of a broadleaf harvest analysis I

vegetation grown 15 .,.

30 km distant in the available. least prevalent I

wind direction, if milk sampling is not performed.

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I DOMINION VPAP-2103S

'I REVISI0N20 PAGE640F76 I ATTACHMENT 9 (Page 1 of 3)

Environmental Sampling Locations I

I SAMPLE MEDIA LOCATION DISTANCE DIRECTION (MILES)

REMARKS Air Charcoal and Surry Station (SS) 0.3 NNE I Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW I Alliance Colonial Park.way (ALL)

(CP) 5.1 3.8 WSW NNW I BASF Fort Eustis (BASF)

(FE) 5.1 4.9 ENE ESE Newport News (NN) 19.3 SE Control Location I Environmental TLDs Control (00) Onsite

• West North West (02) 0.2 WNW Site Boundary I Surry Station Discharge (03) 0.4 NW Site Boundary North North West (04) 0.2 NNW Site Boundary I North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary I North East East North East (07)

(08) 0.3 0.4 NE ENE Site Boundary Site Boundary I East West (09)

(10) 0.3 0.1 E

w Site Boundary Site Boundary West South West (11) 0.4 WSW Site Boundary I South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary I South South South East (14)

(15) 0.4 0.6 s

SSE Site Boundary Site Boundary I South East Station Intake (16)

(18) 0.9 1.6 SE ESE Site Boundary Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident I

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I DOMINION VPAP-2103S REVISION20 PAGE650F76 I ATTACHMENT 9 (Page 2 of 3)

I Environmental Sampling Locations I

SAMPLE MEDIA LOCATION DISTANCE DIRECTION (MILES)

REMARKS I Bacon's Castle (20) 4.5 SSW Approx. 5 miles Environmental TLDs Route 633 (21) 4.9 SW Approx. 5 miles I Alliance (22) 5.1 WSW Approx. 5 miles Surry Route 636 and 637 (23)

(24) 7.7 4.0 WSW w

Popull').tion Center Approx. 5 miles I

Scotland Wharf Jamestown (25)

(26) 5.0 6.3 WNW NW Approx. 5 miles Approx. 5 miles I

Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles I Kingsmill (29) 4.6 N Approx. 5 miles Williams burg Kingsmill North (30)

(31) 7.8 5.5 N

NNE Population Center Approx. 5 miles I

Budweiser Water Plant (32)

(33) 5.8 5.0 NNE NE Population Center Approx. 5 miles I

BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center I Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis Newport News (37)

(38) 4.9 19.3 ESE SE Approx. 5 miles Population Center I

James River Bridge (39)

Benn's Church (40) 17.1 17.0 SE SSE Control Control I

Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles I Route 628 (43) 5.1 s Approx. 5 miles Milk Epps Colonial Parkway 4.8 3.7 SSW NNW I

Lover Retreat 30.6 N Control Location I

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I DOMINION VPAP-2103S I REVISION20 PAGE 66 OF76 I ATTACHMENT 9 (Page 3 of3)

Environmental Sampling Locations I

I SAMPLE MEDIA LOCATION DISTANCE DIRECTION (MILES)

REMARKS Well Water Surry Station Onsite**

I Hog Island Reserve 2.0 NNE Construction Site 0.3 E Onsite***

I Crops (Corn, Peanuts, Slade's Farm 3.2 s Soybeans) Brock's Farm 3.8 s I River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location I Sediment (Silt)

Chickahominy River Surry Station Discharge 11.2 1.3 WNW NNW Control Location I Surry Station Intake 1.8 ESE Sample Collected in Channel Clams Chickahominy River 11.2 WNW Control Location I Surry Station Discharge Jamestown Island 1.3 3.9 NNW NW I Oysters Point of Shoals Mulberry Point 6.4 4.9 SSE ESE Swash Hole Island 6.8 SE I Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW I Shoreline Sediment Hog Island Reserve 0.6 N Chickahominy River 11.2 WNW Control Location I

• Onsite Location ..: in Lead Shield ii ** Onsite sample of Well Water taken from tap-water at Surry Environmental Building

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE670F76 I ATTACHMENT 10 (Page 1 of 2)

I Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD)

I Analysis Water Airborne Fish Milk Food Sediment I

(NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (pCifm3)

(wet) (pCi/kg)

(wet)

(dry)

I Gross beta 4 0.01 H-3 2,000 Mn-54 15 130 Fe-59 Co-58, 60 30 15 260 130 I

Zn-65 Zr-95 30 30 260 I

Nb-95 15 I-131 (NOTE3) 1 0.07 1 60 I Cs-134 15 0.05 130 15 60 150 Cs-137 Ba-140 18 60 0.06 150 18 60 80 180 I

La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental I

measurements are given in Regulatory Guide 4.13.

NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks I

that are measurable and identifiable, together with the above nuclides, shall also be identified and reported. I NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L. I I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE68 OF76 ATTACHMENTlO I (Page 2 of2)

Detection Capabilities for Environmental Sample Analysis I LOWER LIMIT OF DETECTION (LLD)

I NOTE 1: For a particular measurement system (which may include radiochemical separation):

I LLD'=

4.66 Sb E

• V

• 2.22E+06

• Y

• e-(11,.Lit)

(24-1)

I Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above I (as microcuries per unit mass or volume) (See Subsection 4.9)

=

I Sb the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) ,

I E = the counting efficiency (as counts per disintegration)

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

I 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie

=

I Y 11, =

the fractional radiochemical yield (when applicable) the radioactive decay constant for the particular radionuclide I Lit = the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not I plant effluent samples)

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

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

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I DOMINION VPAP-2103S REVISI0N20 PAGE69 OF76 I ATTACHMENT 11 (Page 1 of 1)

I Reporting Levels for Radioactivity Concentrations in Environmental Samples I

Analysis Water (pCi/L)

Airborne Particulate or Fish (pCi/kg, wet)

Mille (pCi/L)

Food Products (pCi/kg, wet)

I Gases (pCi/m3)

H-3 20,000* I Mn-54 1,'000 30,000 Fe-59 Co-58 400 1,000 10,000 30,000 I

Co-60 Zn-65 300 300 10,000 20,000 I

Zr-Nb-95 400 I-131 2* 0.9 3 100 I Cs-134 30 10 1,000 60 1,000 Cs-137 Ba-La-140 50 200 20 2,000 70 300 2,000 I

• Reporting level for the ground (drinking) water samples required by Radiological I Environmental Monitoring Program (Attachment 8). The reporting level for the surface (non-drinking) water samples required by Attachment 8 is 30,000 pCi/L for H-3 and 20 pCi/L for I-131.

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I DOMINION VPAP-2103S REVISI0N20 I PAGE700F76 I ATTACHMENT 12 (Page 1 of 7)

Meteorological, Liquid, and Gaseous Pathway Analysis I 1.0 METEORLOGICAL ANALYSIS I 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year average X/Q and I D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (mixed mode) releases. The five year average X/Q and D/Q values are used in the dose pathway analysis to determine dose and dose rate at site boundary and dose to the member I of the public.

1.2 Meteorological Data, Parameters, and Methodology I A five (5) year average of representative onsite meteorological data for the period January 1, 2007 through December 31, 2011, is used in the gaseous effluent dose pathway calculations.

I This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (i.e.,

I ventilation vent), and those characterized as mixed mode (i.e., process vent).

X/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ -

I , Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324.

I The open terrain adjustment factors were applied to the X/Q values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain I correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum I cross-sectional area. The effective release height used in mixed mode release calculations was based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 1.5 in. with plume exit velocity of 100 ft/sec.

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

'X/Q and D/Q values were calculated for the nearest site boundary, residence, milk animal, discharge bank, and vegetable garden by sector for process vent and ventilation vent releases.

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I DOMINION VPAP-2103S REVISI0N20 PAGE 71 OF76 I ATTACHMENT 12 (Page 2 of 7)

I Meteorological, Liquid, and Gaseous Pathway Analysis According to the definition for short term in NUREG-013 3, "Preparation of Radiological I

Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges.

I However, these releases are considered long term for dose calculations as past releases were both random in time of day and duration as evidenced by reviewing past release reports.

Therefore, the use of annual average concentrations is appropriate according to NUREG-0133.

I 1.3 Results I The X/Q and D/Q values used in the dose pathway analysis for ventilation vent releases and process vent releases can be found in Attachment 7.

I 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose I The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent releases. The analysis included a determination of most restrictive liquid pathway, most restrictive age group, and I

critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents.

I 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 I

were compiled from the Surry Power Station effluent release reports. The data for each year, along with appropriate sit~ specific parameters and default selected parameters, were entered I into the NRC computer code LADTAP as described in NUREG-1276.

Liquid radioactive effluents from both units are released to the James River via the discharge I

canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water I pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal I

groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year.

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I DOMINION VPAP-2103S REVISION20 I PAGE720F76 I ATTACHMENT 12 (Page 3 of 7)

Meteorological, Liquid, and Gaseous Pathway Analysis I For an individual fishing in the discharge canal, no river dilution was-assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e., a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal.

I 2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest

.1 dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and I the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs.

Validation of the limiting age group and critical organ is performed by the liquid effluent dose I calculation program using the data, parameters, and methodology provided in the Source Code file.

I 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose I Gaseous effluent pathway analyses are performed to determine the location that would result in the maximum doses. due to noble gases, for use in demonstrating compliance with I Steps 6.3.1.a. and 6.3.3.a. The analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of I 131 ,

I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days I for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed I individual through the inhalation pathway from I 13 1, 1133 , tritium, and particulates to demonstrate compliance with Step 6.3.1.a.

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I DOMINION VPAP-2103S REVISION20 PAGE 73 OF76 I ATTACHMENT 12 (Page 4 of7)

Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology I

Five year average X/Q values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble I

gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose. I 6.3. l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X/Q values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway. I The maximum exposed individual for 10 CPR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk animal, or nearest vegetable garden, using the Land Use Census data which is assessed annually. Therefore, I

ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, milk, and vegetable I garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the I

gaseous effluent dose pathway analyses.

The gamma and beta dose factors Kivv, Livv, Mivv, and Nivv for ground level releases and the I

gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode releases are included in the Source Code file. I Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation:

I Pi= K' (BR) DFAi mrem/yr per Ci/m3 (28-1) where: I K' = a constant of unit conversion, lE+ 12 pCi/Ci BR=the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.l I

DFAi = the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi I

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I DOMINION VPAP-2103S I REVISION20 PAGE740F76 I ATTACHMENT 12 (Page 5 of7)

Meteorological, Liquid, and Gaseous Pathway Analysis I Parameters used above were obtained from NUREG-0133 and R.G. 1.109, Rev. 1.

I It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year. Active pathways are ground I plane and inhalation, and all age groups are evaluated for this pathway analysis.

The RMivv and RMipv dose factors, except for tritium, are calculated using the following I equation:

I RM-1 (28-2)

I where:

I K' = a constant of unit conversion, lE+ 12 pCi/Ci Qp =cow's consumption rate, 50, in kg/day (wet weight)

I = goat's consumption rate, 6 kg/day (wet weight)

Dap=infant milk consumption rate, 330, in liters/yr Y p = agricultural productivity by unit area of pasture feed grass, 0. 7 in kg/m2 I Y 8 = agricultural productivity by unit area of stored feed, 2.0, in kg/m2 Fm = stable element transfer coefficients, in days/liter I r = fraction of deposited activity retained on milk animal's feed grass, 1.0 for radioiodine, and 0.2 for particulates I DFLj_=critical organ ingestion dose factor for the ith radionuclide for the particular age group, inmrem/pCi I Ai Aw

= decay constant for the ith radionuclide, in sec-1

= decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life)

• I tr = transport time from pasture to milk animal, to milk, to receptor, 1.73+05, in seconds th =transport time from pasture, to harvest, to milk animal, to milk, to receptor, 7 .78E+06, in I fp seconds

=fraction of year that milk animal is on pasture, 1.0 (dimensionless)

I fs =fraction of milk animal feed that is pasture grass while milk animal is on pasture, 0.8 (dimensionless)

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DOMINION VPAP-2103S I

REVISI0N20 PAGE 75 OF76 I ATTACHMENT 12 (Page 6 of 7) I Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev.l.

I Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used:

I I

K'K'"p m Qp U ap(DFLH3) [o.75 (0.5/H~ (28-3) where: I K '= a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the ahnosphere, 8.0, in gmfm3 I 0.75 = the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water I Other parameters have been previously defined.

The inhalation pathway dose factors Riivv and Riipv were calculated using the following I

equation:

I Rli = K' (BR) DFAi mrem/yr per Ci/m3. (28-4) where: I K' = a constant of unit conversion, lE+ 12 pCi/Ci BR= breathing rate of the particular age group, m3/yr I

DFAFcritical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi I I

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I DOMINION VPAP-2103S REVISI0N20 I PAGE760F76 I ATTACHMENT 12 (Page 7 of7)

Meteorological, Liquid, and Gaseous Pathway Analysis I Parameters used above were obtained from NUREG-0133 and R. G. 1.109, Rev. 1.

I Breathing Rate I Infant = 140,0m3/yr Child = 3700 m 3/yr I Teen = 8000m3/yr Adult = 8000 m 3/yr I

The RG dose factors are calculated using the following equation:

I 2 1-'Ae-.\tb ] ( m *mrem/yr * )

I RG=K'K"(SF)DFG. [

• 1 Ci/sec I where:

(28 - 5)

I K' = A constant of unit conversion, lE+ 12 pCi/Ci K" = A constant of unit conversion, 8760 hr/year.

I Ai tb 1

= The decay constant for nuclide i, sec- .

8

= The exposure time, 4.73xl0 sec (15 years), from Table E-15 of Reg I DFGi Guide 1.109.

= The ground plane dose conversion factor for of Reg. Guide 1.109 (mrem/hr per pCi/m 2

).

nuclide i, from Table E-6 I SF = The shielding factor 0.7 (dimensionless), from Table E-15 of Reg Guide 1.109.

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Attachment 4 I Page 1 of 1 I MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS I

There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems I for this reporting period.

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I Attachment 5 Page 1 of 1 I INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION I

The Annual Radioactive Effluent Release Report shall explain why monitoring instrumentation I required by the ODCM Attachments 1 and 5, which were determined to be inoperable, were not returned to operable status within 30 days. Two of the above referenced instrumentation I were inoperable greater than 30 days during this reporting period.

On 05/06/2015, the Surry Radwaste Facility (SRF) Ventilation Stack Noble Gas Monitor selector I switch was determined inoperable. The selector switch provides the capability to toggle through various monitor parameters and perform selected functions. Two instruments required to monitor the SRF stack release pathway, in accordance with Attachment 5 of the ODCM, were rendered I inoperable with the loss of the selector switch. The instruments lost were the noble gas activity radiation monitor and the flow rate measuring device for the stack continuous particulate and iodine sampler. Additionally, although not required by Attachment 5, the capability to source check the I noble gas activity radiation monitor was rendered inoperable.

I Compensatory measures for the loss of the instruments were initiated in accordance with the ODCM. For the loss of the noble gas activity radiation monitor, grab samples of the SRF stack exhaust were taken and analyzed at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. No activity was detected in any I of these samples. For the loss of the sampler flow rate measuring device, an estimate of the sampler flow rate was made at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and documented in the Station logs.

I Design Change 15-01054 was initiated to obtain a new radiation monitoring system for the SRF ventilation. fu 2016, the new radiation monitoring skid was manufactured and delivered to the I station for installation. On 2/13/2017, the new radiation monitor skid was returned to operational status rendering the noble gas radiation monitor and the flow rate measuring device for the stack continuous particulate and iodine sampler fully functional.

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Attachment 6 I Page 1 ofl I UNPLANNED RELEASES I There were no unplanned liquid or unplanned gaseous releases during this reporting period I

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I Attachment 6 Page 1 of 1 I UNPLANNED RELEASES I There were no unplanned liquid or unplanned gaseous releases during this reporting period.

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I Attachment 7 Page I of I I LOWER LIMIT OF DETECTION (LLD) FOR EFFLUENT SAMPLE ANALYSIS I GASEOUS: Isotope Kr-87 Kr-88 Reguired LLD 1.00E-04 Typical LLD 2.02E 3.41E-05 l.OOE-04 1.71E 2.13E-05 I Xe-133 Xe-133m 1.00E-04 1.00E-04 1.05E l.94E-05 3.61E 4.06E-05 Xe-135 l.OOE-04 4.59E 7.96E-06 I Xe-135m Xe-138 1.00E-04 l.OOE-04 1.67E 9.21E-05 2.31E 9.90E-05 I-131 1.00E-12 4.06E 4.06E-13 I

I I-133 Sr-89 1.00E-10 1.00E-11 4.06E-11 4.06E-11 1.35E 1.24E-12 Sr-90 1.00E-11 2.17E 1.0lE-13 I Cs-134 Cs-137 l.OOE-11 1.00E-11 1.lOE 2.77E-13 1.81E 3.64E-13 Mn-54 1.00E-11 1.59E 3.31E-13 I Fe-59 Co-58 l.OOE-11 1.00E-11 2.51E 7.09E-13 1.60E 3.48E-13 Co-60 1.00E-11 2.25E 5.85E-13 I Zn-65 Mo-99 1.00E-11 1.00E-11 4.76E 6.63E-13 4.06E 4.06E-12 I Ce-141 Ce-144 1.00E-11 1.00E-11 2.13E 3.20E-13 7.84E l.20E-12 Alpha 1.00E-11 1.68E 1.69E-14 I Tritium 1.00E-06 4.94E 6.55E-08 LIQUID: Sr-89 5.00E-08 2.61E 4.51E-08 I Sr-90 Cs-134 5.00E-08 5.00E-07 4.89E-09 1.14E-08 1.54E-08 6.23E-08 Cs-137 5.00E-07 2.45E 8.33E-08 I I-131 Co-58 l.OOE-06 5.00E-07 2.02E-08 1.87E-08 6.48E-08 7.26E-08 Co-60 5.00E-07 4.53E-09 1.13E-07 I Fe-59 Zn-65 5.00E-07 5.00E-07 7.74E-09 4.60E-08 1.32E-07 1.33E-07 Mn-54 5.00E-07 1.63E 7.05E-08 I Mo-99 Ce-141 5.00E-07 5.00E-07 3.36E-07 2.87E-08 4.95E-07 8.20E-08 Ce-144 5.00E-07 1.13E 3.47E-07 I Fe-55 Alpha 1.00E-06 1.00E-07 5.93E-07 2.68E-08 8.44E-07 2.70E-08 I Tritium Xe-133 1.00E-05 l.OOE-05 1.22E-06 8.90E-08 1.62E-06 3.76E-07 Xe-135 1.00E-05 2.78E 6.98E-08 I Xe-133m Xe-135m 1.00E-05 l.OOE-05 1.99E-07 1.61E-06 3.38E-07 3.60E-06 Xe-138 1.00E-05 2.05E 8.93E-06 I Kr-87 Kr-88 1.00E-05 1.00E-05 1.30E-07 9.60E-08 2.39E-07 2.44E-07

Attachment 9 I Page 1 of 1 I ERRATA/CORRECTIONS TO PREVIOUS REPORTS I This section contains revisions to TABLE IA GASEOUS EFFLUENT- SUMMATION OF ALL RELEASES for 2016. An internal audit of the 2016 Annual Radioactive Effluent Release Report I identified transcription errors in this table. The errors are identified on the following pages along with a corrected submission of the gaseous effluent release tables for 2016.

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I Attachment 8 Page 1 of 3 I INDUSTRY GROUND WATER PROTECTION INITIATIVE I The Annual Radioactive Effluent Release Report shall include a summary of on-site radioactive leaks/spills and ground water sample analyses that were communicated in accordance with the Initiative reporting I protocol. Also to be included are sample analyses from ground water monitoring wells that are not part of the Radiological Environmental Monitoring Program. In 2017, one ground water sample analysis was communicated in accordance with the Initiative.

I On 12/7/2017, local and state government stakeholders and the NRC were notified that a ground water I sample analysis of well P-44, located in the Protected Area of the site, indicated the presence of tritium at a concentration of 59,300 picoCuries per liter (pCi/L). An investigation determined that an underground pipe contained an unsealed section, in close proximity to well P-44, from which water may have been I slowly leaking to ground. The section has been sealed and increased monitoring of the ground water at well P-44, and areas adjacent to well P-44, has been implemented.

I The presence of tritium in Protected Area monitoring well P-44 does not present an exposure pathway to c;msite personnel or members of the public. Well P-44 is designated for ground water monitoring only and I is not a source of drinking water. In addition to ground water samples taken withiri the Protected Area, ground water samples are also taken outside the Protect_ed Area on owner controlled property. No tritium has been detected in these owner controlled wells located outside the Protected Area. The absence of tritium in wells outside the Protected Area indicates that tritium is not migrating out of the Protected area. Additionally, tritium has never been detected in drinking water wells.

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I Attachment 8 Page 2 of 3 I INDUSTRY GROUND WATER PROTECTION INITIATIVE I The following is a summary of2017 sample analyses of ground water monitoring wells that are not a part of the Radiological Environmental Monitoring Program (REMP). Analyses are performed by an I independent laboratory.

I Well Designation 1-PL-Piez-29 Sample Tritium Gamma Fe-55 1/18/17 6,630 Ni-63 NA Sr-90 NA TRU Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter NA ND NA I 1-PL-Piez-04 l-PL-Piez-05 2/7/17 2/7/17

<937 6,360 ND ND NA NA NA NA NA NA NA NA l-PL-Piez-06 2/7/17 2,570 ND NA NA NA NA I 1-PL-Piez-07 1-PL-Piez-27 2/7/17 2/7/17

<921

<926 ND ND NA NA NA NA NA NA NA NA l-PL-Piez-3 3 2/7/17 <924 ND NA NA NA NA I 1-PL-Piez-34 1-PL-Piez-41 2/7/17 2/7/17

<919

<933 ND ND NA NA NA NA NA NA NA NA I l-PL-Piez-42 1-PL-Piez-29 2/7/17 2/8/17

<928 7,730 ND ND NA NA NA NA NA NA NA NA l-PL-Piez-33 6/13/17 <732 ND NA NA NA NA I l-PL-Piez-34 1-PL-Piez-35 6/13/17 6/13/17

<732

<739 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-36 6/13/17 <735 ND NA NA NA NA I l-PL-Piez-37 1-PL-Piez-38 6/13/17 6/13/17

<738

<729 ND ND NA NA NA NA NA NA NA NA I 1-PL-Piez-39 1-PL-Piez-40 6/13/17 6/13/17

<737

<720 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-41 6/13/17 <750 ND NA NA NA NA I 1-PL-Piez-42 l-PL-Piez-03 6/13/17 6/14/17

<745

<736 ND ND NA NA NA NA NA NA NA NA l-PL-Piez-07 6/14/17 <734 ND NA NA NA NA I 1-PL-Piez-08 1-PL-Piez-09 6/14/17 6/14/17

<743

<737 ND ND NA NA NA NA NA NA NA NA I 1-PL-Piez-20 1-PL-Piez-22 6/14/17 6/14/17

<734

<729 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-23 6/14/17 <747 ND NA NA NA NA I 1-PL-Piez-27 1-PL-Piez-28 6/14/17 6/14/17

<743

<743 ND ND NA NA NA NA NA NA NA NA l-PL-Piez-04 6/15/17 <730 ND NA NA NA NA I 1-PL-Piez-05 l-PL-Piez-06 6/15/17 6/15/17 5,380 1,770 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-24 <721 NA NA NA I 1-PL-Piez-25 6/15/17 6/15/17 <724 ND ND NA NA NA NA NA I

I Attachment 8 Page 3 of 3 I INDUSTRY GROUND WATER PROTECTION INITIATIVE I

I Well.

Designation Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter I l-PL-Piez-29 1-PL-Piez-33 6/15/17 9/20/17 6,240

<747 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-34 9/20/17 <751 ND NA NA NA NA I 1-PL-Piez-41 1-PL-Piez-42 9/20/17 9/20/17

<754

<750 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-04 9/21/17 <752 ND NA NA NA NA I l-PL-Piez-05 1-PL-Piez-06 9/21/17 9/21/17 5,400 1,800 ND ND

<181

<139

<4.72

<4.80

<0.758

<0.867 ND ND 1-PL-Piez-07 9/21/17 <741 NA NA NA I 1-PL-Piez-27 l-PL-Piez-29 9/21/17 9/21/17

<750 5,360 ND ND ND NA

<132 NA NA

<4.80 NA

<0.600 NA ND I 1-PL-Piez-04 11/13/17 <1,050 l-PL-Piez-24 11/13/17 <1,030 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-25 11/13/17 <1,040 ND NA NA NA NA I 1-PL-Piez-33 11/13/17 <1,050 1-PL-Piez-34 11/13/17 <1,040 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-40 11/13/17 <1,050 ND NA NA NA NA I l-PL-Piez-41 11/13/17 <1,050 1-PL-Piez-42 11/13/17 <1,060 ND ND NA NA NA NA NA NA NA NA I 1-PL-Piez-50 11/13/17 <1,030 1-PL-Piez-06 11/14/17 2,560 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-07 11/14/17 <1,040 ND NA NA NA NA I 1-PL-Piez-46 11/14/17 <1,040 l -PL-Piez-47 11/14/17 1,910 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-48 11/14/17 <1,040 ND NA NA NA NA I 1-PL-Piez-49 11/14/17 18,400 l-PL-Piez-05 11/21/17 5,020 ND ND NA NA NA NA NA NA NA NA 11 1-PL-Piez-08 11/21/17 <677 1-PL-Piez-27 11/21/17 <677 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-29 11/21/17 5,400 ND NA NA NA NA I l-PL-Piez-43 11/21/17 <642 1-PL-Piez-45 11/21/17 2,210 ND ND NA NA NA NA NA NA NA NA 1-PL-Piez-44 11/22/17 39,700 ND NA NA NA NA I 1-PL-Piez-51 11/22/17 7,160 1-PL-Piez-52 11/22/17 <675 ND ND NA NA NA NA NA NA NA NA I 1-PL-Piez-44 11/29/17 59,300 NA = Analysis not required.

ND NA NA NA NA ND = No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs.

I TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238, Pu-239/240 and Pu-241)

ND = not detected

I Attachment 9 Page 1 of 1 I ERRATA/CORRECTIONS TO PREVIOUS REPORTS I This section contains revisions to TABLE lA GASEOUS EFFLUENT- SUMMATION OF ALL RELEASES for 2016. An internal audit of the 2016 Annual Radioactive Effluent Release Report I identified transcription errors in this table. The errors are identified on the following pages along with a corrected submission of the gaseous effluent release tables for 2016.

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I TABLE lA Attachment 1 Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111116 TO 12131116 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I

SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR I A. FISSION & ACTIVATION GASES QUARTER QUARTER I 1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec l.28E-03

. l.6j]3-04" l.62E-04 2.64E-03 3.36E-04 l.80E+Ol I B. IODINE I. TOTAL I-131 Ci N/D N/D 2.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec NIA NIA I C. PARTICULATE I I. HALF-LIFE >8 DAYS

2. AVE RELEASE RATE FOR PERIOD

3. GROSS ALPHA RADIOACTIVITY Ci

µCi/sec Ci N/D NIA N/D N/D NIA N/D 2.80E+Ol I D. TRITIUM

1. TOTAL RELEASE Ci 5.69E+OO 5.6IE+OO 3.IOE+Ol I 2. AVE RELEASE RATE FOR PERIOD µCi/sec 7.24E-01 7.i4E01' 7.13E-01 I E. CARBON-14

1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec 8.94E-03 1.14E-03 l.84E-02 2.34E-03 I PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % l.IOE-03 l.IOE-03 I TOTAL BODY DOSE RATE SKIN DOSE RATE 2.3IE-09 9.06E-10 l.72E-06 4.76E-07 I

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I TABLE lA Attachment 1 Page 2 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/16 TO 12/31/16 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST.ERROR I A. FISSION & ACTIVATION GASES QUARTER QUARTER

1. TOTAL RELEASE Ci NID 2.80E+OO l.80E+Ol I 2. AVE RELEASE RATE FOR PERIOD µCi/sec NIA 3.56E-Ol 3.53E-01 I B. IODINE

1. TOTALI-131

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec NID NIA l.17E-04 IADE 05 2.80E+Ol I C. PARTICULATE l.47E-05

1. HALF-LIFE >8 DAYS Ci 3.41E-06 l.19E-05 2.80E+Ol I 2.

3.

AVE RELEASE RATE FOR PERIOD GROSS ALPHA RADIOACTIVITY

µCi/sec Ci 4.34£ 07 NID l.51E 06 NID 4.28E-07 l.50E-06 I D. TRITIUM

1. TOT AL RELEASE Ci 2.96E+OO l.47E+Ol 3.IOE+Ol I 2. AVE RELEASE RATE FOR PERIOD µCi/sec 3.76E-01 1.87£100 l.85E+OO I E. CARBON-14

1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec NID NIA l.96E+Ol 2.49E+OO I PERCENTAGE OFT .S: LIMITS CRITICAL ORGAN DOSE RATE  % 5.66E-04 3.29E-03 I TOTAL BODY DOSE RATE SKIN DOSE RATE O.OOE+OO O.OOE+OO l.42E-05 5.70E-06 I

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I TABLE lA Attachment 1 Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111/16 TO 12131/16 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I

SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR I A. FISSION & ACTNATION GASES QUARTER QUARTER I 1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec l.28E-03 l.62E-04 2.64E-03 3.36E-04 l.80E+Ol I B. IODINE

1. TOTAL I-131 Ci NID NID 2.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec NIA NIA I

C. PARTICULATE I 1.

2.

3.

HALF-LIFE >8 DAYS AVE RELEASE RATE FOR PERIOD GROSS ALPHA RADIOACTNITY Ci

µCi/sec Ci NID NIA NID NID NIA NID 2.80E+Ol I D. TRITIUM

1. TOT AL RELEASE Ci 5.69E+OO 5.6IE+OO 3.IOE+Ol I 2. AVE RELEASE RATE FOR PERIOD µCi/sec 7.24E-01 7.13E-01 I E. CARBON-14

1. TOTAL RELEASE

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec 8.94E-03 l.14E-03 l.84E-02 2.34E-03 I PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % l.IOE-03 1.lOE-03 I TOTAL BODY DOSE RATE SKIN DOSE RATE 2.3IE-09 9.06E-I0 l.72E-06 4.76E-07 I

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I TABLE lA Attachment 1 Page 2 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/16 TO 12/31/16 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES I THIRD SURRY POWER STATION UNITS 1&2 UNIT FOURTH %EST.ERROR I A. FISSION & ACTNATION GASES QUARTER QUARTER

1. TOTAL RELEASE Ci NID 2.80E+OO 1.80E+Ol I 2. A VE RELEASE RATE FOR PERIOD µCi/sec NIA 3.53E-01 I B. IODINE

1. TOTAL I-131

2. AVE RELEASE RATE FOR PERIOD Ci

µCi/sec NID NIA l.17E-04 1.47E-05 2.80E+Ol I C. PARTICULATE *

1. HALF-LIFE >8 DAYS Ci 3.41E-06 l.19E-05 2.80E+Ol I 2. A VE RELEASE RATE FOR PERIOD

3. GROSS ALPHA RADIOACTMTY

µCi/sec Ci 4.28E-07 NID l.SOE-06 NID I D. TRITIUM L TOTAL RELEASE Ci 2.96E+OO l.47E+Ol 3.lOE+Ol I 2. A VE RELEASE RATE FOR PERIOD µCi/sec 3.76E-01 1.85E+OO I E. CARBON-14

1. TOTAL RELEASE

2. A VE RELEASE RATE FOR PERIOD Ci

µCi/sec NID NIA 1.96E+Ol 2.49E+OO I PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % 5.66E-04 3.29E-03 I TOTAL BODY DOSE RATE SKIN DOSE RATE O.OOE+OO O.OOE+OO 1.42E-05 5.70E-06 I

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I TABLElB Attachment 1 Page 3 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 1/1/16 TO 12131116 GASEOUS EFFLUENTS-MIXED MODE RELEASES I CONTINUOUS MODE BATCH MODE I SURRYPOWERSTATIONUNITS 1&2 UNIT FIRST QUARTER SECOND QUARTER FIRST QUARTER SECOND QUARTER I I. FISSION & ACTNATION GASES Kr-85 Kr-85m Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D I Kr-88 Xe-133 Ci Ci N/D N/D N/D N/D N/D l.28E-03 N/D NID Xe-135 Ci N/D N/D N/D N/D I Xe-135m Xe-138 Xe-131m Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I Xe-133m Ar-41 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA l.28E-03 NIA I

2. IODINES I I-131 I-133 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D I-135 Ci N/D N/D N/D N/D I TOTAL FOR PERIOD Ci NIA NIA J NIA NIA I 3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D I Sr-90 Cs-134 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Cs-137 Ci N/D N/D N/D N/D I Ba-140 La-140 Ci Ci N/D N/D N/D N/D N/D NID N/D N/D NID N/D N/D Co-58 Ci N/D I Co-60 Mn-54 Fe-59 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Ci N/D N/D N/D N/D I Zn-65 Mo-99 Ce-141 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D I C-14 Ci N/D N/D 8.94E-03 N/D TOTAL FOR PERIOD Ci NIA NIA 8.94E-03 NIA I

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I TABLElB Attachment 1 Page 4 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111/16 TO 12131116 GASEOUS EFFLUENTS-MIXED MODE RELEASES I CONTINUOUS MODE BATCH MODE I SURRY POWER STATION UNITS 1&2 UNIT THIRD QUARTER FOURTH QUARTER THIRD QUARTER FOURTH QUARTER

1. FISSION & ACTIVATION GASES I Kr-85 Kr-85m Ci Ci N/D N/D N/D N/D N/D N/D 5.77E-Ol 8.79E-03 Kr-87 Ci N/D N/D N/D N/D I Kr-88 Xe-133 Ci Ci N/D N/D N/D 5.4IE-01 N/D N/D 4.14E-03 l.16E+OO Xe-135 Ci N/D 8.55E-03 N/D 4.06E-01 I Xe-135m Xe-138 Xe-13lm Ci Ci Ci N/D N/D NID N/D N/D N/D N/D N/D N/D N/D N/D l.28E-02 Xe-133m Ci N/D N/D N/D 2.3IE-02 I Ar-41 Ci N/D N/D N/D 3.97E-02 TOTAL FOR PERIOD Ci NIA 5.SOE-01 NIA 2.23E+OO I

2. IODINES I I-131 I-133 I-135 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I TOTAL FOR PERIOD Ci NIA NIA NIA NIA I 3. PARTICULATES Sr-89 Ci N/D N/D N/D NID I Sr-90 Cs-134 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Cs-137 Ci NID N/D N/D N/D I Ba-140 La-140 Co-58 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D I Co-60 Mn-54 Fe-59 Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D NID N/D N/D Zn-65 Ci N/D N/D N/D N/D I Mo-99 Ce-141 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D I C-14 TOTAL FOR PERIOD Ci Ci N/D NIA 3.84E+OO 3.84E+OO NID NIA l.56E+Ol l.56E+Ol I

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I TABLElC Attachment 1 Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111116 TO 12131116 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES I CONTINUOUS MODE BATCH MODE I SURRY POWER STATION UNITS 1&2 UNIT FIRST QUARTER SECOND QUARTER FIRST QUARTER SECOND QUARTER I 1. FISSION & ACTIVATION GASES Kr-85 Kr-85m Ci Ci N/D N/D N/D 2.48E-05 N/D N/D N/D N/D Kr-87 Ci N/D 5.27E-06 N/D N/D I Kr-88 Xe-133 Ci Ci N/D N/D 2.75E-05 2.17E-03 N/D N/D N/D N/D Xe-135 Ci N/D 8.87E-05 N/D N/D I Xe-135m Xe-138 Ci Ci N/D N/D 2.30E-06 N/D 1.43E-05 N/D N/D N/D N/D N/D N/D Xe-13lm Ci N/D I Xe-133m Ar-41 Ci Ci N/D N/D 3.16E-05 2.80E-04 N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA 2.64E-03 NIA NIA I

2. IODINES I I-131 I-133 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D I-135 Ci N/D NID NID NID I TOTAL FOR PERIOD Ci NIA NIA NIA NIA I 3. PARTICULATES Sr-89 Ci NID N/D N/D N/D I Sr-90 Cs-134 Ci Ci N/D NID NID NID NID NID NID N/D Cs-137 Ci NID N/D NID NID I Ba-140 La-140 Ci Ci N/D N/D N/D N/D NID NID NID NID NID NID N/D Co-58 Ci NID I Co-60 Mn-54 Fe-59 Ci Ci Ci N/D NID NID NID N/D NID N/D NID NID NID N/D NID NID NID NID I Zn-65 Mo-99 Ce-141 Ci Ci Ci NID N/D N/D N/D NID N/D N/D N/D NID Ce-144 Ci N/D N/D N/D NID I C-14 Ci N/D l.84E-02 N/D N/D TOTAL FOR PERIOD Ci NIA l.84E-02 NA NA I

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I TABLElC Attachment 1 Page 6 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT I PERIOD: 111116 TO 12131/16 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES I I CONTINUOUS MODE BATCH MODE I SURRYPOWERSTATIONUNITS 1&2 UNIT THIRD QUARTER FOURTH QUARTER THIRD QUARTER FOURTH QUARTER

1. FISSION & ACTNATION GASES I Kr-85 Kr-85m Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D I Kr-88 Xe-133 Ci Ci Ci N/D N/D N/D N/D 2.22E-03 N/D N/D N/D N/D N/D l.84E-02 8.94E-06 Xe-135 I Xe-135m Xe-138 Xe-131m Ci Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Ci N/D N/D N/D 3.18E-04 I

Xe-133m Ar-41 Ci N/D 2.90E-04 N/D N/D TOTAL FOR PERIOD Ci NIA 2.51E-03 NIA l.87E-02 I

2. IODINES I I-131 I-133 I-135 Ci Ci Ci N/D N/D N/D 9.27E-05 2.43E-05 N/D N/D N/D N/D N/D N/D N/D I TOTAL FOR PERIOD Ci NIA l.17E-04

• NIA NIA I 3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D I Sr-90 Cs-134 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D N/D Cs-137 Ci N/D I Ba-140 La-140 Co-58 Ci Ci Ci N/D N/D 3.41E-06 N/D N/D l.19E-05 N/D N/D N/D N/D N/D 3.65E-08 Co-60 Ci N/D N/D N/D N/D I Mn-54 Fe-59 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D I Mo-99 Ce-141 Ci Ci N/D N/D N/D N/D N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D I C-14 TOTAL FOR PERIOD Ci Ci N/D 3.41E-06 l.75E-02 l.75E-02 N/D NA l.31E-01 l.31E-01 I

I