Text

Independent Spent Fuel Storage Installation (ISFSI) - Annual Radioactive Effluent Release Report
	ML19126A094
Person / Time
Site:	North Anna
Issue date:	04/26/2019
From:	Lane N; Virginia Electric & Power Co (VEPCO)
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	19-175
	Download: ML19126A094 (131)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 26, 2019 United States Nuclear Regulatory Commission Serial No.19-175 Attention: Document Control Desk NAPS/DPM Washington, D. C. 20555 Docket Nos. 50-338/339 72-16 72-56 License Nos. NPF-4/7 SNM-2507 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the 2018 Annual Radioactive Effluent Release Report. This report is provided pursuant to North Anna Units 1 and 2 Technical Specification 5.6.3 [10 CFR 50.36a] and North Anna Independent Spent Fuel Storage Installation Technical Specification 5.5.2c [10 CFR 72.44(d)(3)].

If you have any questions or require additional information, please contact Mr. Donald R. Taylor at (540) 894-2100.

Very truly yours, I\%~

N. Larry Lane Site Vice President Enclosure Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission (w/o Enclosure)

Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Director, Division of Spent Fuel Management (w/o Enclosure)

Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC Senior Resident Inspector (w/o Enclosure)

North Anna Power Station

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT NORTH ANNA POWER STATION (JANUARY 01, 2018 TO DECEMBER 31, 2018)

Erin M. Salling Supervisor Radiologic 1 Analysis and Instrumentation REVIEWED BY: tid/t,t, JAG-n~

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Barb a r a J. Thompson Superintendent Health Physics Technical Services George R. Simmons Manager Radiological Protection and Chemistry

FORWARD This report is submitted in accordance with North Anna Unit 1 and 2 Technical Specification 5.6.3 and North Anna Independent Spent Fuel Storage Installation (ISFSI) Technical Specification 5.5.2.c and IOCFR72.44(d)(3).

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE NORTH ANNA POWER STATION JANUARY 01, 2018 TO DECEMBER 31, 2018 INDEX Section No. Subject EXECUTIVE

SUMMARY

.................................. . 4 2 PURPOSE AND SCOPE .................................... . 5 3 DISCUSSION ................................................. . 5-6 4 SUPPLEMENTAL INFORMATION ..................... .. 6-7 Attachment 1 Effluent Release Data ............................................. . 8 Attachment 2 Annual and Quarterly Doses ................................ :, ... . 9 Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM) .......... : ...._................... : .... : 10

. Attachment 4 Major Changes to Radioactive Liquid, Gaseous, and Solid Waste Treatment Systems ................................................. . 11 Attachment 5 Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation ....................................... . 12 Attachment 6 Unplanned Releases ............................................ . 13 Attachment 7 Lower Limits of Detection (LLD) for Effluent Sample Analysis .......................... . 14-15 Attachment 8 Results of Ground Water Protection Initiative Sample Analysis .................................... . 16-23 Attachment 9 Carbon-14 Calculations ....................................... . 24 Miscellaneous Annual Effluent Release Report Log ....................... . 25

1.0 EXECUTIVE

SUMMARY

The Annual Radioactive Effluent Release Report describes the radioactive effluent control program conducted at the North Anna Power Station and the Independent Spent Fuel Storage Installation (ISFSI) during the 2018 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from the North Anna Power Station and ISFSI in accordance with Regulatory Guide 1.21 during the period of January 1 through December 31, 2018, and includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents.

There were no releases from the ISFSI during 2018.

There were no unplanned releases, meeting the reporting criteria of Section 6.7.2.a.3 of the Offsite Dose Calculation Manual during this reporting period. Also, there were no spills or leaks meeting the voluntary communication criteria of the NEI Ground Water Protection Initiative. This will be discussed in Attachment 6.

10 CFR 50, Appendix I dose calculations were performed on the 2018 effluent release data in accordance with the Offsite Dose Calculation Manual. The results of these pathway dose calculations indicate the following:

a. The total body dose due to liquid effluents was 4.593E-01 mrem, which is 7 .655% of the dose limit, and the critical organ dose due to liquid effluents was 4.767E-Ol mrem, which is 2.384% of the dose limit.

b. The air dose due to noble gases was 2.984E-3 mrad gamma, which is 1.492E-02% of the annual gamma dose limit, and l.066E-3 mrad beta, which is 2.665E-03% of the annual beta dose limit.

c. The critical organ dose for 1-131, 1-133, H-3, and particulates with half-lives greater than 8 days including C-14 was 2.853E+O mrem, which is 9.51 % of the annual dose limit. The bases ofC-14 calculations are describedinAttachment9.

d. The critical organ dose for 1-131, 1-133, H-3, and particulates with half-lives greater than 8 days not including C-14 was 6.8I9E-03 mrem, which is 2.273E-02% of the annual dose limit.

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

There was one revision to the Offsite Dose Calculation Manual during this reporting period. The revision made to the Offsite Dose Calculation Manual is detailed in Attachment 3.

Based on the levels of radioactivity observed during this reporting period and the dose calculations performed, the operations of the North Anna Nuclear Power Station Units I and 2 and ISFSI have resulted in negligible dose consequences to the maximum exposed member of the public in unrestricted areas.

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2.0 PURPOSE AND SCOPE

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The Radioactive Effluent Release Report includes, in Attachment 1, a summary of the quantities ofradioactive liquid and gaseous effluents and solid waste as outlined in 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 I, June 1974, with data summarized on a quarterly basis for Table I and 2 and on an annual basis on Table 3. The report submitted before May 1st of each year includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site during the previous calendar year. The report also includes a list of unplanned releases during the reporting period in Attachment 6.

\

As required by Technical Specification, any changes to the Offsite Dose Calculation Manual (ODCM) for the time period covered by this report are included in Attachment 3.

Major changes to radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, Section 6. 7.2.a.4. Information to support the reason(s) for the change(s) and a summary of the IO CFR 50.59 evaluation are included.

As required by the O DCM, Sections 6 .2 .2. b .2 and 6. 3 .2. b. 3, a list and explanation for the in operability ofradioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 of this report.

3.0 DISCUSSION The basis for the calculation of percent of Technical Specification for the critical organ in Table IA of Attachment I is the ODCM, section 6.3.1, which requires that the dose rate for iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary. The critical organ is the child's bone ifC-14 is included and child's thyroid ifC-14 is not included both via the inhalation pathway.

The basis for the calculation of percent of Technical Specification for the total body and skin in 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 the 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.

The basis for the calculation of the percent of Technical Specification in Table 2A in Attachment 1 is the ODCM, section 6.2.1, which states that the concei:itrations of radioactive material released in liquid effluents to unrestricted areas shall be limited to I 0 times the concentrations specified in IO CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gase~, the concentration shall be limited to 2.0E-4 uCi/ml.

Percent of Technical Specification calculations' are based on the total gaseous or liquid effluents released for that respective quarter.

5,

The annual and quarterly doses, as reported in Attachment 2, were calculated according to the methodology presented in the ODCM. The beta and gamma air doses due to noble gases released from the site were calculated at site boundary. The maximum exposed member of the public from the releases of airborne iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, including carbon-14 is defined as a child, expose~ through the vegetation pathway, with the critical organ being the bone. If carbon-14 is excluded from these calculations, the maximum exposed member of the public from the releases of airborne iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days is defined as a child, exposed through the vegetation pathway, with the critical organ being the thyroid gland. The maximum exposed member of the public for calculation of total body dose from radioactive materials in liquid effluents released to unrestricted areas is defined as a child. The critical organ dose calculation was determined to be the child liver. The age group is exposed via the drinking water and fish ingestion pathways.

As shown in Attachment 6, there were no unplanned releases meeting the requirements of 6.7.2.a.3 of the ODCM.

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 volume and maximum delay time prior to analysis). Actual LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed, then the activity of that radioisotope was reported as Not Detectable (N/D) on Attachment 1 of this report. !fan analysis for an isotope was not performed, then the activity was reported as Not Applicable (N/A).

4.0 SUPPLEMENTAL INFORMATION As required by the ODCM, section 6.6.2, evaluation of the Land Use Census is performed to identify ifnew location(s) need be added for the radiological environmental monitoring program pursuant to the ODCM: There were no new sampling locations added. There were seven (7) changes made from the land use census in 2018. The nearest meat animal location in the N sector changed from 2.90 miles to 4.03 miles. The nearest garden location in the NNE sector changed from 3.21 miles to 1.66 miles.

The nearest meat animal location in the NNE sector changed from 3 .10 miles to 1.60 miles, The nearest resident location in the E sector changed from 1.30 miles to 1.25 miles. The nearest garden location in the SSE sector changed from 1.00 miles to 0.98 miles. The nearest garden location in the S sector changed from 1.14 miles to 1.49 miles. Finally, the nearest resident location in the NW sector changed from 1.00 miles to 0.98 miles.

Section 6.6.1.b.4 of the ODCM requires identification of the cause(s) for the unavailability of milk or leafy vegetation samples, and the identification of new locations for obtaining replacement samples. Milk samples were not collected in 2018 because the last of the operating dairies in the sampling area ceased operations at the start of calendar year 2018. Vegetation samples were not collected from stations 14B, 15, 16, 23 and 26 from January through April and November through December due to seasonal unavailability. All other vegetation samples were obtained.

Attachment 8 contains the results of samples associated with ground water protection sampling undertaken at North Anna to voluntarily comply with the Nuclear Energy Institute, NEI, Ground Water Protection Initiative. In addition to the well, river, and 6

surface water samples included as part of the Radiological Environmental Monitoring Program, North Anna obtained subsurface water samples from various locations on the site. contains an explanation of the bases for the carbon-14 calculations performed to assess doses due to carbon- I 4.

Doses and %TS for gaseous releases are displayed with C-14 included and without for comparison of the values.

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ATTACHMENT 1 EFFLUENT RELEASE DATA (01/18 - 12/18)

This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste, as outlined in Regulatory Guide 1.21, Appendix B, except that in accordance with Step 6. 7 .2.a. l of the ODCM liquid and gaseous data is summarized on a quarterly basis and solid waste is summarized on an annual basis.

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ATTACHMENT 2 ANNUAL AND QUARTERLY DOSES (01/18 - 12/18)

An assessment ofradiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site for each calendar quarter for the calendar year of this report, along with an annual total of each effluent pathway will be made as required by ODCM Section 6.7.2.

1st 2nd 3rd 4th Annual Quarter Quarter Quarter Quarter Total Total Body Dose (mrem} 2.049E-1 6.337E-2 7.623E-2 1.148E-1 4.593E-1 Critical Organ Dose (mrem} 2.lOlE-1 6.470E-2 7.627E-2 1.256E-1 4.767E-1 1st 2nd 3rd 4th Annual Quarter Quarter Quarter* Quarter Total Noble Gas Gamma Dose (mrad} 1.830E-5 6.954E-7 2.955E-3 9.816E-6 2.984E-3 Noble Gas Beta Dose (mrad} 1.129E-5 4.872E-7 1.043E-3 1.081E-5 1.066E-3 Critical Organ

{Child bone)

Dose for 1-131, 1-133, H-3, Particulates with I.I T7'i > 8 days (including C-14} (mrem} 8.391E-2 7.454E-3 2.609E+O 1.529E-1 2.853E+O Critical Organ (Child thyroid)

Dose for 1-131, 1-133, H-3, Particulates with T7'i > 8 days (excluding C-14}(mrem} 1.166E-3 1.779E-3 1.836E-4 3.690E-3 6.819E-3 9

ATTACHMENT 3 REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM)

(01/18 - 12/18)

As required by Technical Specification 5.5.1.c, revisions to the ODCM, effective for the time period covered by this report, are summarized in this attachment.

There was one revision to the ODCM during this reporting period. Revision 28. effective on 03/07/18 was completed to remove the milk sampling location on Attachment 10 page 4 of 5 due to sample unavailability. A footnote, footnote b, was also added to Attachment 10 page 4 of 5 stating that no milk producing animals are available within the North Anna Power Station monitoring locations following the .

closure of the Harris Dairy on O1/01/18. Future milk availability and hence the necessity for milk sampling will be determined from data collected during the completion of the annual Land Use Census.

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ATTACHMENT 4 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS, AND SOLID WASTE TREATMENT SYSTEMS (01/18 - 12/18)

As required by the ODCM, Section 6. 7 .2.a.4, major changes to radioactive liquid, gaseous and solid waste treatment systems for the time period covered by this report are synopsized in this attachment. Supporting information as to the reason( s) for the change(s) and a summary of the 10 CFR 50.59 evaluations are included, as applicable.

There were no major changes to the radioactive liquid, gaseous, and solid waste treatment systems for 2018.

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ATTACHMENT 5 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION (01/18 - 12/18)

As required by the 0DCM, Sections 6.2.2.b.2 and 6.3.2.b.3, a list and explanation for extended inoperability ofradioactive liquid and/or gaseous effluent monitoring instrumentation is provided in this attachment.

The Unit 1 High Capacity Blowdown effluent radiation monitor, 1-SS-RM-125, was out of service for greater than 30 days during calendar year 2018. The radiation monitor was declared out of service on O1/27/18 due to spurious alarms which caused isolation of the Unit 1 High Capacity Blowdown System. The monitor remained out of service, pending evaluation of the output signal spiking issue with accompanying alarms, until 09/14/18 when it was declared fully operational and was returned to service.

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ATTACHMENT 6 UNPLANNED RELEASES (01/18 - 12/18)

As required by the ODCM, Section 6.7.2.a.3, a list of unplanned releases, from the site to unrestricted areas, of radioactive material in gaseous and liquid effluents occurring during the reporting period, is made in this attachment.

There were no unplanned releases during calendar year 2018 meeting the criteria of Section 6.7.2.a.3 of the ODCM from the site to unrestricted areas. Also, there were no spills or leaks that required voluntary communication under the criteria of the NEI Ground Water Protection Initiative, NEI 07-07. Elevated results indicated in Attachment 8 are from the on-going investigation/ mitigation for the voluntary communication made in 2010. The hydrological modeling indicates the horizontal groundwater movement around well

6 is < 1 inch per day.

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ATTACHMENT 7 LOWER LIMITS OF DETECTION FOR EFFLUENT SAMPLE ANALYSIS (01/18 - 12/18)

Gaseous Effluents:

Required L.L.D. Typical L.L.D.

Radioisotope µCi/mL µCi/mL Krypton - 87 1.00E-4 2.SOE-8 7.SOE-8 Krypton - 88 1.00E-4 4.00E-8 2.SOE-7 Xenon -133 1.00E-4 2.00E-8 1.00E-7 Xenon-133m 1.00E-4 1.00E-7 4.00E-7 Xenon -135 1.00E-4 1.00E-8 5.00E-8 Xenon-135m 1.00E-4 5.00E-8 2.00E-7 Xenon -138 1.00E-4 9.00E-8 4.00E-7 Iodine - 131 1.00E-12 3.00E-14 1.00E-13 Iodine - 133 1.00E-10 1.00E-14 7.00E-13 Manganese - 54 1.00E-11 2.00E-14 6.00E-14 Cobalt- 58 1.00E-11 2.00E-14 6.00E-14 Iron - 59 1.00E-11 6.00E-14 1.00E-13 Cobalt - 60 1.00E-11 3.00E-14 1.00E-13 Zinc - 65 1.00E-11 6.00E-14 2.00E-13 Strontium - 89 1.00E-11 3.00E-14 8.00E-12 Strontium - 90 l.OOE-11 3.00E-15 9.00E-12 Molybdenum - 99 1.00E~ll 2.00E-14 1.00E-13 Cesium -134 1.00E-11 2.00E-14 8.00E-14 Cesium - 137 1.00E-11 3.00E-14 8.00E-14 Cerium -141 1.00E-11 3.00E-14 1.00E-13 Cerium -144 1.00E-11 1.50E-13 4.00E-13 Gross Alpha 1.00E-11 7.00E-15 2.00E-14 Tritium 1.00E-6 4.00E-09 9.00E-09 14

ATTACHMENT 7

'LOWER LIMITS OF DETECTION FOR EFFLUENT SAMPLE ANALYSIS*

{01/18 - 12/18)

Liguid Effluents:

Required L.L.D. Typical L.L.D.

Radioisotope µCi/mL µCi/mL Krypton-87 1.00E-5 3.00E-8 1.00E-7 Krypton-88 1.00E-5 5.00E-8 5.00E-7 Xenon-133 1.00E-5 3.00E-8 1.00E-7 Xenon-133m 1.00E-5 9.00E-8. 3.00E-7 Xenon -135 1.00E-5 1.00E-8 5.00E-8 Xenon-135m 1.00E-5 3.00E-8 2.00E-7 Xenon-138 1.00E-5 1.00E-7 1.00E-6 Iodine -131 1.00E-6 1.00E-8 5.00E-8 Manganese - 54 5.00E-7 1.00E-8 5.00E-8.

Iron - 55 1.00E-6 3.00E-7 8.00E-7 Cobalt- 58 5.00E-7 1.50E-8 6.00E-8 Iron- 59 5.00E-7 3.00E-8 7.00E-8 Cobalt- 60 5.00E-7 1.00E-8 5.50E-8 Zinc-65 5.00E-7 3.00E-8 6.00E-8 Strontium - 89 5.00E-8 1.00E-8 4.00E-8

Strontium - 90 5.00E-8 5.00E-9 9.00E-9 Molybdenum - 99 5.00E-7 2.00E-8* 6.00E-8 Cesium -134 5.00E-7 1.50E-8 5.00E-8 Cesium -137 5.00E-7 1.50E-8 6.00E-8 Cerium -141 5.00E-7 3.00E-8 9.00E-8 Cerium -144 5.00E-7 1.00E-7 5.00E-7 Gross Alpha 1.00E-7 2.00E-8 7.00E-8 Tritium 1.00E-5 2.00E-6 5.00E-6 15

ATTACHMENT 8 RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS (01/18 - 12/18)

The Ground Water Protection Program was established to improve North Anna's management of and response to instances where the inadvertent release of radioactive substances may result in low but detectible levels of plant-related materials in subsurface soils and water.

It complies with the requirements ofNEI 07-07, INDUSTRY GROUND WATER PROTECTION INITIATIVE - FINAL GUIDANCE DOCUMENT. The industry initiative is intended to improve public trust and confidence in the nuclear industry through sampling and analysis of ground water and timely and effective communication with stakeholders, including the public and local, state, and federal officials.

Samples are obtained from monitoring wells installed both inside and outside the restricted area on a quarterly basis and analyzed onsite.

Annually, during the second quarter, these samples are analyzed by an Independent Lab. Samples are also obtained from sumps and yard drains on a quarterly basis and analyzed onsite. Samples may be obtained more frequently than normal, if required and may be analyzed on-site or by an Independent Lab. The required Lower Limits of Detection, LLDs, and reporting limits for the ground water detection program are those associated with the radiological environmental program as listed in Attachments 11 and 12 to VPAP-2103N.

On the following pages is a summary of the samples and results of the ground water protection program taken for calendar year 2018. All liquid results are reported in pCi/L, while soil results for tritium are reported in pCi/g of soil, wet. An "NIA" indicates a sample analysis was not performed for that sample. An N/D" indicates an analysis was performed but the result was less than the Minimum Detectable Activity, MDA, and the required LLD. If a result is greater than the MDA, but less than the LLD the result is listed. Some of these results may be false positives, due to the analysis software or interferences from naturally occurring radioactivity. In these cases, instead of the value, an explanatory footnote is provided.

Ground water well GWP-15 was decommissioned during calendar year 2017 due to construction activities required for plant operations. It was replaced by ground water well GWP-15R during calendar year 2018.

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ATTACHMENT 8 RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS (01/18 - 12/18) 1st Quarter 2018 Sample Gamma -Emitting Alpha Sample Date H-3<1l 1-131<1) Sr-89/90<1! Fe-ss<1l Ni-63<1l Pu-241<1l Media Particulates<1l TRU<1l PZ-3 01/31/18 WATER 1780 N/A N/A N/A N/A N/A N/A N/A PZ-3 02(22/18 WATER 1667 N/A N/A N/A N/A N/A N/A N/A PZ-3 04/06/18 WATER 1452 N/A N/A N/A N/A N/A N/A N/A GWP-3 04/06/18 WATER <785 N/A N/A N/A N/A N/A N/A N/A GWP-4 04/06/18 WATER <914 N/A N/A N/A N/A N/A N/A N/A GWP-5A 04/06/18 WATER <910 N/A N/A N/A N/A N/A N/A N/A GWP-6 01/31/18 WATER <859 N/A N/A N/A N/A N/A N/A N/A GWP-6 02/22/18 WATER <908 N/A N/A N/A N/A N/A N/A N/A GWP-6 04/06/18 WATER <851 N/A N/A N/A N/A N/A N/A N/A GWP-7 04/06/18 WATER <912 N/A N/A N/A N/A N/A N/A N/A GWP-8 04/06/18 WATER <914 N/A N/A N/A N/A N/A N/A N/A GWP-9 04/06/18 WATER <916 N/A N/A N/A N/A N/A N/A N/A GWP-13 04/06/18 WATER <961 N/A N/A N/A N/A N/A N/A N/A 04/06/18 <923 N/A N/A GWP-14 WATER N/A N/A N/A N/A N/A GWP-16 04/05/18 WATER <914 N/A N/A N/A N/A N/A N/A N/A GWP-17 04/05/18 WATER <938 N/A N/A N/A N/A N/A N/A N/A GWP-18 01/31/18 WATER <855 N/A N/A N/A N/A N/A N/A N/A GWP18 02/22/18 WATER 3367 N/A N/A N/A N/A N/A N/A N/A GWP18 04/05/18 WATER '2705 N/A N/A N/A N/A N/A N/A N/A GWP-19 04/06/18 WATER <929 N/A N/A N/A N/A N/A N/A N/A GWP-20 04/06/18 WATER <925 N/A N/A N/A N/A N/A N/A N/A GWP-21 04/06/18 WATER <918 N/A N/A N/A N/A N/A N/A N/A GWP-22 04/06/18 WATER <931 N/A N/A N/A N/A N/A N/A N/A BTW-1 04/06/18 WATER <929 N/A N/A N/A N/A N/A N/A N/A BTW-2 04/06/18 WATER <934 N/A N/A N/A N/A N/A N/A N/A BTW-4 04/06/18 WATER <925 N/A N/A N/A N/A N/A N/A N/A TTW-2 04/06/18 WATER <908 N/A N/A N/A N/A N/A N/A N/A TTW-3 04/06/18 WATER <934 N/A N/A N/A N/A N/A N/A N/A TTW-5 04/06/18 WATER <855 N/A N/A N/A N/A N/A N/A N/A Sub Surface Drains 02/14/18 WATER <1770 N/A N/A N/A N/A N/A N/A N/A U-1 Intake Storm Drains 02/14/18 WATER <1794 N/A N/A N/A N/A N/A N/A N/A U-2 Intake Storm Drains 02/14/18 WATER <1794 N/A N/A N/A N/A N/A N/A N/A Disch Canal Storm Drains 02/14/18 WATER <1772 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump East 03/31/18 WATER <1728 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump South 03/31/18 WATER <1716 .N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Inside 03/31/18 WATER <1724 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Outside 03/31/18 WATER <1736 N/A N/A N/A N/A N/A N/A N/A U-1 AB/FB GWMS 03/31/18 WATER <1724 N/A N/A N/A N/A N/A N/A N/A U-2 AB/FB GWMS 03/31/18 WATER <1721 N/A N/A N/A N/A N/A N/A N/A PZ-1 03/29/17 WATER Insufficient Volume to Sample PZ-2 03/29/17 WATER Insufficient Volume to Sample TTW-1 Well abandoned in place, pending decommissioning.

TTW-4 Well abandoned in place, pending decommissioning (1) pCi/L 17

ATTACHMENT 8.

RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS (01/18 - 12/18) 2"d Quarter 2018 Sample Gamma -Emitting Alpha Sample Date H-3 11 > 1-131 11 > Sr-89/9011> Fe-5511> Ni-63<1> Pu-241< 1>

Media Particulates<1> TRU<1>

PZ-3 04/18/18 WATER <974 N/A N/A N/A N/A N/A N/A N/A PZ-3 05/21/18 WATER 1847 N/A N/A N/A N/A N/A N/A N/A PZ-3 06/26/18 WATER 5080 N/A N/A N/A N/A N/A N/A N/A PZ-3 (2) 06/26/18 WATER 4670 N/A N/A N/A N/A N/A N/A N/A GWP-3 06/26/18 WATER 6200 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/02/18 WATER 7320 N/A N/A N/A N/A N/A N/A N/A GWP-3 (2) 06/26/18 WATER 5100 N/A N/A N/A N/A N/A N/A N/A GWP-3 (2) 07/09/18 WATER 4250 <22.5 <0.76 <4.22 <175 <4.17 <.139 <18.1 GWP-4 06/26/18 WATER 1150 N/A N/A N/A N/A N/A N/A N/A GWP-4 (2) 06/26/18 WATER <1020 N/A N/A N/A N/A N/A N/A N/A GWP-5A 06/26/18 WATER <921 N/A N/A N/A N/A N/A N/A N/A GWP-5A (2) 06/26/18 WATER <1010 N/A N/A N/A N/A N/A N/A N/A GWP-6 04/18/18 WATER <979 N/A N/A N/A N/A N/A N/A N/A GWP-6 05/21/18 WATER 1407 N/A N/A N/A N/A N/A N/A N/A GWP-6 06/26/18 WATER 935 N/A N/A N/A N/A N/A N/A N/A GWP-6 (2) 06/26/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-7 06/26/18 WATER <928 N/A N/A N/A N/A N/A N/A N/A GWP-7 (2) 06/26/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-8 06/27/18 WATER <936 N/A N/A N/A N/A N/A N/A N/A GWP-8 (2) 06/27/18 WATER <1010 N/A N/A N/A N/A N/A N/A N/A GWP-9 06/27/18 WATER <932 N/A N/A N/A N/A N/A N/A N/A GWP-9 (2) 06/27/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-13 06/27/18 WATER <960 N/A N/A N/A N/A N/A N/A N/A GWP-13 (2) 06/27/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-14 06/20/18 WATER <939 N/A N/A N/A N/A N/A N/A N/A GWP-14 (2) 06/20/18 WATER <1010 N/A NIA N/A N/A N/A N/A N/A GWP-15R 06/27/18 WATER <941 N/A N/A N/A N/A N/A N/A N/A GWP-15R (2) 06/27/18 WATER <999 N/A N/A N/A N/A N/A N/A N/A GWP-16 06/27/18 WATER <932 N/A N/A N/A N/A N/A N/A N/A GWP-16 (2) 06/27/18 WATER <1010 N/A N/A N/A N/A N/A N/A N/A GWP-17 06/20/18 WATER 4230 N/A N/A N/A N/A N/A N/A N/A GWP-17 (2) 06/20/18 WATER 3040 N/A N/A N/A N/A N/A N/A N/A GWP-18 04/28/18 WATER 4565 N/A N/A N/A N/A N/A N/A N/A GWP-18 05/21/18 WATER 4763 N/A N/A N/A N/A N/A N/A N/A GWP-18 06/20/18 WATER 2830 N/A N/A N/A N/A N/A N/A N/A GWP-18 (2) 06/20/18 WATER 2600 N/A N/A N/A N/A N/A N/A N/A GWP-19 06/26/18 WATER <936 N/A N/A N/A N/A N/A N/A N/A GWP-19 (2) 06/26/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-20 06/26/18 WATER <919 N/A N/A N/A N/A N/A N/A N/A GWP-20 (2) 06/26/18 WATER <1010 N/A N/A N/A N/A N/A N/A N/A GWP-21 06/26/18 WATER <957

N/A N/A N/A N/A N/A N/A N/A GWP-21 (2) 06/26/18 WATER <1010 N/A N/A N/A N/A N/A N/A N/A GWP-22 06/27/18 WATER <957 N/A N/A N/A N/A N/A N/A N/A GWP-22 (2) 06/27/18 WATER <1020 N/A N/A N/A N/A N/A N/A N/A BTW-1 06/19/18 WATER <930 N/A N/A N/A N/A N/A N/A N/A BTW-1 (2) 06/19/18 WATER <836 N/A N/A N/A N/A N/A N/A N/A 18

BTW-2 06/19/18 WATER <925 N/A N/A N/A N/A N/A N/A N/A BTW-2 (2) 06/19/18 WATER <842 N/A N/A N/A N/A N/A N/A N/A BTW-4 06/20/18 WATER <919 N/A N/A N/A N/A N/A N/A N/A BTW-4 (2) 06/20/18 WATER <845 N/A N/A N/A N/A N/A N/A N/A TTW-2 06/20/18 WATER <930 N/A N/A N/A N/A N/A N/A N/A TTW-2 (2) 06/20/18 WATER <841 N/A N/A N/A N/A N/A N/A N/A TTW-3 06/19/18 WATER <930 N/A N/A N/A N/A N/A N/A N/A TTW-3 (2) 06/19/18 WATER <839 N/A N/A N/A N/A N/A N/A N/A TTW-5 06/19/18 WATER <921 N/A N/A N/A N/A N/A N/A N/A TTW-5 (2) 06/19/18 WATER <836 N/A N/A N/A N/A N/A N/A N/A Sub Surface Drains 05/16/18 WATER <1760 N/A N/A N/A N/A N/A N/A N/A U-1 Intake Storm Drains 05/20/18 WATER <1890 N/A N/A N/A N/A N/A N/A N/A U-2 Intake Storm Drains 05/20/18 WATER <1920 N/A N/A N/A N/A N/A N/A N/A Disch Canal Storm Drains 05/20/18 WATER <1870 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump East 04/19/18 WATER <981 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump South 04/19/18 WATER <981 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Inside 04/19/18 WATER <1658 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Outside 04/19/18 WATER <972 N/A N/A N/A N/A N/A N/A N/A U-1 AB/FB GWMS 04/19/18 WATER <1651 N/A N/A N/A N/A N/A N/A N/A U-2 AB/FB GWMS 04/19/18 WATER <965 N/A N/A N/A N/A N/A N/A N/A PZ-1 06/26/18 WATER Insufficient Volume to Sample PZ-2 06/26/18 WATER Insufficient Volume to Sample TTW-1 Well abandoned in place, pending decommissioning TTW-4 Well abandoned in place, pending decommissioning (1) pCi/L (2) Vendor Analysis 19

ATTACHMENT 8

. RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS (01/18 - 12/18) 3rd Quarter 2018 Sample Gamma -Emitting Sr- Alpha*

Sample Date H-3<1> 1-131<1> Fe-ss<1> Ni-63<1> Pu-241< 1>

. Media Particulates<1> 89/90<1> TRu<1>

PZ-3 07/09/18 WATER 2361 N/A N/A N/A N/A N/A N/A N/A PZ-3 07/19/18 WATER 1974 N/A N/A N/A N/A N/A N/A N/A PZ-3 07/26/18 WATER 2302 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/02/18 WATER <896 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/06/18 WATER 1780 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/09/18 WATER 1226 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/14/18 WATER <993 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/16/18 WATER <990 N/A N/A N/A N/A N/A N/A . N/A PZ-3 08/21/18 WATER 2002 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/23/18 WATER 2422 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/29/18 WATER 1397 N/A N/A N/A N/A N/A N/A N/A PZ-3 08/30/18 WATER 3081 N/A N/A N/A N/A N/A N/A N/A PZ-3 09/05/18 WATER 1947 N/A N/A N/A N/A N/A N/A N/A PZ-3 09/10/18 WATER 1005 N/A N/A N/A* N/A N/A N/A N/A PZ-3 09/13/18 WATER 1793 N/A N/A N/A . N/A N/A N/A N/A PZ-3 09/19/18 WATER 1077 N/A .N/A N/A N/A N/A N/A N/A PZ-3 09/26/18 WATER 1223 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/09/18 WATER 6087 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/12/18 WATER 5370 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/16/18 WATER 4964 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/19/18 WATER 4311 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/23/18 WATER 4604 N/A N/A N/A N/A N/A N/A N/A GWP-3 07/26/18 WATER 5339 N/A N/A N/A . N/A N/A N/A N/A GWP-3 07/30/18 WATER .4820 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/02/18 WATER 3932 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/06/18 WATER 3686 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/09/18 WATER 3849 N/A N/A N/A N/A N/A N/A

N/A GWP-3 08/14/18 WATER 4414 N/A N/A N/A N/A . N/A N/A N/A GWP-3 08/16/18 WATER 4065 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/21/18 WATER 4275 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/23/18 WATER 4807 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/29/18 WATER 4167 N/A N/A N/A N/A N/A N/A N/A GWP-3 08/30/18 WATER 3860 N/A N/A N/A N/A N/A N/A N/A GWP-3 09/05/18 WATER 3377 N/A N/A N/A N/A N/A N/A N/A GWP-3 09/10/18 WATER 3867 N/A N/A N/A N/A N/A N/A N/A GWP-3 09/13/18 WATER 4134 N/A N/A N/A N/A N/A N/A N/A GWP-3 09/19/18 WATER 3325 N/A N/A N/A N/A N/A N/A N/A GWP-3 09/26/18 WATER 1953 N/A N/A N/A N/A N/A N/A N/A GWP-4 09/19/18 WATER <924 N/A N/A N/A N/A N/A N/A N/A GWP-5A 09/19/18 WATER <924 N/A N/A N/A N/A N/A N/A N/A GWP-6 07/19/18 WATER 1933 N/A N/A N/A N/A N/A N/A N/A 20

GWP-6 08/16/18 WATER <1007 N/A N/A N/A N/A N/A N/A N/A GWP-6 09/19/18 WATER 1110 N/A N/A N/A N/A N/A N/A N/A GWP-7 09/19/18 WATER <920 N/A N/A N/A N/A N/A N/A N/A GWP-8 09/19/18 WATER 1300 N/A N/A N/A N/A N/A N/A N/A GWP-9 09/26/18 WATER <949 N/A N/A N/A N/A N/A N/A N/A GWP-13 09/20/18 WATER <940 N/A N/A N/A N/A N/A N/A N/A GWP-14 09/20/18 WATER <922 N/A N/A N/A N/A N/A N/A N/A GWP-15R 09/26/18 WATER <938 N/A N/A N/A N/A N/A N/A N/A GWP-16 09/20/18 WATER <929 N/A N/A N/A N/A N/A N/A N/A GWP-17 09/20/18 WATER 1510 N/A N/A N/A N/A N/A N/A N/A GWP-18 07/19/18 WATER 3583 N/A N/A N/A N/A N/A N/A N/A GWP-18 08/16/18 WATER 2024 N/A N/A N/A N/A N/A N/A N/A GWP-18 09/20/18 WATER 3329 N/A N/A N/A N/A N/A N/A N/A GWP-19 09/19/18 WATER 931 N/A N/A N/A N/A N/A N/A N/A GWP-20 09/19/18 WATER <927 N/A N/A N/A N/A N/A N/A N/A GWP-21 09/19/18 WATER <916 N/A N/A N/A N/A N/A N/A N/A GWP-22 09/19/18 WATER <922 N/A N/A N/A N/A N/A N/A N/A BTW-1 09/26/18 WATER <949 N/A N/A N/A N/A N/A N/A N/A BTW-2 09/26/18 WATER <938 N/A N/A N/A N/A N/A N/A N/A BTW-4 09/26/18 WATER <917 N/A N/A N/A N/A N/A N/A N/A TTW-2 09/26/18 WATER <872 N/A N/A N/A N/A N/A N/A N/A TTW-3 09/26/18 WATER <884 N/A N/A N/A N/A N/A N/A N/A TTW-5 09/26/18 WATER <936 N/A N/A N/A N/A N/A N/A N/A Sub Surface Drains 08/15/18 WATER <1700 N/A N/A N/A N/A N/A N/A N/A U-1 Intake Storm Drains 08/14/18 WATER <1677 N/A N/A N/A N/A N/A N/A N/A U-2 Intake Storm Drains 08/14/18 WATER <1684 N/A N/A N/A N/A N/A N/A N/A Disch Canal Storm Drains 08/14/18 WATER <1680 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump East 09/27/18 WATER <1592 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump South 09/27/18 WATER <1562 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Inside 09/27/18 WATER <1566 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Outside 09/27/18 WATER' <1586 N/A N/A N/A N/A N/A N/A N/A U-1 AB/FB GWMS 09/27/18 WATER <1594 N/A N/A N/A N/A N/A N/A N/A U-2 AB/FB GWMS 09/27/18 WATER <1566 N/A N/A N/A N/A N/A N/A N/A PZ-1 09/19/18 WATER Insufficient volume to sample PZ-2 09/19/18 WATER Insufficient volume to sample TTW-1 Well abandoned in place, pending decommissioning TTW-4 Well abandoned in place, pending decommissioning (1) pCi/L (2) Vendor Ana-lysis 21 J

ATTACHMENT 8 RESULTS OF GROUND WATER PROTECTION INITIATIVE SAMPLE ANALYSIS (01/18 - 12/18) 4th Quarter 2018 Sample Gamma -Emitting Alpha Sample Date H-3<1l 1-131<1) Sr-89/90<1l Fe-ss<1l Ni-63<11 Pu-241<1l Media Particulates<1l TRU< 1l PZ-3 10/02/18 WATER 1425 N/A N/A N/A N/A N/A N/A N/A PZ-3 10/09/18 WATER 1241 N/A N/A N/A N/A N/A N/A N/A PZ-3 10/17/18 WATER 2220 N/A N/A N/A N/A N/A N/A N/A PZ-3 10/24/18 WATER 1781 N/A N/A N/A N/A N/A N/A N/A PZ-3 10/30/18 WATER 1140 N/A N/A N/A N/A N/A N/A N/A PZ-3 11/08/18 WATER 2688 N/A N/A N/A N/A N/A N/A N/A PZ-3 11/14/18 WATER 4547 N/A N/A N/A N/A N/A N/A N/A PZ-3 11/23/18 WATER <1110 N/A N/A N/A N/A N/A N/A N/A PZ-3 (2) 11/23/18 WATER <791 <21.6 <.691 <2.02 <117 <4.41 <.259 N/A PZ-3 11/24/18 WATER 2230 N/A N/A N/A N/A N/A N/A N/A PZ-3 {2) 11/24/18 WATER <797 <24.2 <.690 <2.42 <72.3 <4.37 <.0712 N/A PZ-3 11/27/18 WATER 1383 N/A N/A N/A N/A N/A N/A N/A PZ-3 12/11/18 WATER <983 N/A N/A N/A N/A N/A N/A N/A GWP-3 10/02/18 WATER 3230 N/A N/A N/A N/A N/A N/A N/A GWP-3 10/09/18 WATER 2549 N/A N/A N/A N/A N/A N/A N/A GWP-3 10/17/18 WATER 1571 N/A N/A N/A N/A N/A N/A N/A GWP-3 10/24/18 WATER 3393 N/A N/A N/A N/A N/A N/A N/A GWP-3 10/30/18 WATER 2204 N/A N/A N/A N/A N/A N/A N/A GWP-3 11/08/18 WATER 1634 N/A N/A N/A N/A N/A N/A N/A GWP-3 11/14/18 WATER 1507 N/A N/A N/A N/A N/A N/A N/A GWP-3 11/23/18 WATER <1110 N/A N/A N/A N/A N/A N/A N/A GWP-3 (2) 11/23/18 WATER <785 <21.3 <0.662 <2.00 <164 <4.28 <.130 N/A GWP-3 11/24/18 WATER 1710 N/A N/A N/A N/A N/A N/A N/A GWP-3 (2) 11/24/18 WATER <792 <23.2 <.548 <1.70 <53.5 <4.26 <.125 N/A GWP-3 11/27/18 WATER 2580 N/A N/A N/A N/A N/A N/A N/A GWP-3 12/11/18 WATER 1005 N/A N/A N/A N/A N/A N/A N/A GWP-4 12/11/18 WATER <988 N/A N/A N/A N/A N/A N/A N/A GWP-5A 12/11/18 WATER <995 N/A N/A N/A N/A N/A N/A N/A GWP-6 10/30/18 WATER 1435 N/A N/A N/A N/A N/A N/A N/A GWP-6 11/23/18 WATER 2869 N/A N/A N/A N/A N/A N/A N/A GWP-6 (2) 11/23/18 WATER 803 <22.2 <.801 <2.55 <119 <4.14 <0.1 N/A GWP-6 12/11/18 WATER 1830 N/A N/A N/A N/A N/A N/A N/A GWP-7 12/11/18 WATER <976 N/A N/A N/A N/A N/A N/A N/A GWP-8 12/11/18 WATER <989 N/A N/A N/A N/A N/A N/A N/A GWP-9 12/11/18 WATER <976 N/A N/A N/A N/A N/A N/A N/A GWP-13 12/11/18 WATER <981 N/A N/A N/A N/A N/A N/A N/A GWP-14 12/11/18 WATER <1000 N/A N/A N/A N/A N/A N/A N/A GWP-15R 12/13/18 WATER <1038 N/A N/A N/A N/A N/A N/A N/A GWP-16 12/13/18 WATER <995 N/A N/A N/A N/A N/A N/A N/A GWP-17 12/13/18 WATER <1039 N/A N/A N/A N/A N/A N/A N/A GWP-18 10/30/18 WATER 3278 N/A N/A N/A N/A N/A N/A N/A GWP-18 11/27/18 WATER 3915 N/A N/A N/A N/A N/A N/A N/A GWP-18 12/13/18 WATER 3923 N/A N/A N/A N/A N/A N/A N/A 22

GWP-19 12/11/18 WATER <981 N/A N/A N/A N/A N/A N/A N/A GWP-20 12/11/18 WATER <966 N/A N/A N/A N/A N/A N/A N/A GWP-21 12/11/18 WATER <969 N/A N/A N/A N/A N/A N/A N/A GWP-22 12/13/18 WATER <977 N/A N/A N/A N/A N/A N/A N/A BTW-1 12/05/18 WATER <1013 N/A N/A N/A N/A N/A N/A N/A BTW-2 12/05/18 WATER <1023 N/A N/A N/A N/A N/A N/A N/A BTW-4 - 12/05/18 WATER <1033 N/A N/A N/A N/A N/A N/A N/A TTW-2 12/05/18 WATER <1119 N/A N/A N/A N/A N/A N/A N/A TTW-3 12/05/18 WATER <1018 N/A N/A N/A t-J/A N/A N/A N/A TTW-5 12/05/18 WATER <1031 N/A N/A N/A N/A N/A N/A N/A Sub Surface Drains 11/07/18 WATER <1487 N/A N/A N/A N/A N/A N/A N/A U-1 Intake Storm Drains 11/28/18 WATER <1526 N/A N/A N/A N/A N/A N/A N/A U-2 Intake Storm Drains 11/28/18 WATER <1519 N/A N/A N/A N/A N/A . N/A N/A Disch Canal Storm Drains 11/28/18 WATER <1519 N/A N/A N/A N/A N/A N/A N/A U-1 Mat Sump East 10/25/18 WATER <1486 N/A N/A NIA N/A N/A N/A N/A U-1 Mat Sump South 10/25/18 WATER <1459 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Inside 10/25/18 WATER <1485 N/A N/A N/A N/A N/A N/A N/A U-2 Mat Sump Outside 10/25/18 WATER <1460 N/A N/A N/A N/A N/A N/A N/A U-1 AB/FB GWMS 10/25/18 WATER <1466 N/A N/A N/A N/A N/A N/A N/A U-2 AB/FB GWMS 10/25/18 WATER <1464 N/A N/A N/A N/A N/A N/A N/A PZ-1 12/11/18 WATER Insufficient volume to sample PZ-2 12/11/18 WATER Insufficient volume to sample TTW-1 Well abandoned in place, pending decommissioning TTW-4 Well abandoned in place, pending decommissioning (1) pCi/L (2) Vendor Analysis 23

ATTACHMENT 9 CARBON-14 CALCULATIONS (01/18 - 12/18)

Carbon-14, C-14, is a naturally occurring isotope of carbon produced by cosmic ray interactions in the atmosphere. Nuclear weapons testing in the 1950s and 1960s significantly increased the amount ofC-14 in the atmosphere. Due to the long half-life ofC-14, 5730 years, a significant portion of the C-14 from this testing is still present in the environment. C-14 is also produced in commercial nuclearreactors, but the amounts produced are much less than those produced naturally or from weapons testing.

In Regulatory Guide 1.21, Revision 2, "Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste", the NRC has recommended that U.S. nuclear power plants evaluate whether C-14 is a "principal radionuclide", and if so, report the amount of C-14 released. At North Anna, improvements over the years in fuel performance have resulted in a decrease in the amount and distribution of radionuclides released to the environment in gaseous effluents. As a result, C-14 has become a "principal radionuclide" for the gaseous effluent pathway at North Anna, as defined in Regulatory Guide 1.21, Revision 2. Because the dose contribution of C-14 to liquid radioactive waste is a small fraction of the dose compared to other nuclides, evaluation of C-14 in liquid effluents is not required by Regulatory Guide 1.21, Revision 2.

The quantity of gaseous C-14 released to the environment can be estimated by use of a C-14 source term scaling factor based on power generation. North Anna utilized methodology in EPRI Report, Estimation of C-14 in Nuclear Power Gaseous Effluents. *Based on this document, at full capacity, North Anna would generate and release about 32.8 Ci ofC-14 per year. Since the units did not operate at full power for 100% of the year, this value was corrected for the capacity factor of each unit yielding an estimated 28.5 Ci of C-14 produced and released. North Anna assumed that the fractional release of gaseous C-14 in any quarter and pathway could be approximated by the fraction of noble gasses released via that pathway in that quarter.

Most C-14 species initially produced in a Pressurized Water Reactor are organic, e.g., methane. C-14 releases inPWRs occur primarily as a mix of organic carbon and carbon dioxide released from the waste gas system. C-14 in the primary coolant is essentially all organic with a large fraction as a gaseous species. Any time the RCS liquid or gas is exposed to an oxidizing environment, a slow transformation from an organic to an inorganic chemical form can occur. Various studies documenting measured C-14 releases from PWRs suggest a range of70%

to 95% organic. North Anna used a value of70% organic and 30% CO2 in its calculations.

Public dose estimates from airborne C-14 were performed using dose models in NUREG-0133 and Regulatory Guide 1.109. The estimated C-14 dose impact on the maximum organ dose from airborne effluents released at North Anna is estimated to be 2.40E-01 mremfrom the inhalation pathway, or l.60E-02% TS of the 1500 mrem/yr dose rate limit and 2.6 IE+O mrem from the ingestion pathway or 8.70E+OO% TS of the 10CFR50, Appendix I, ALARA design objective of 15 mrem/yr per unit. In both cases the critical organ was determined to be the child's bone.

24

Miscellaneous There were two entries on the Annual Effluent Release Report Log for 2018. The first entry, entry #18-01, was made to document that the Unit 1 High Capacity Blowdown Effluent radiation monitor, l-SS-RM-125 , was out of service for> 30 consecutive days. The second entry, entry # 18-02, was made to document Revision 28 of the Offsite Dose Calculation Manual, ODCM, effective on 03/07/18. Changes to the ODCM, associated with Revision 28, are detailed on Attachment 3 of this report.

25

TABLE 1A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF ALL GASEOUS EFFLUENT RELEASES FOR (01/18

12/18)

Page 1 of 2 1 ST 2ND ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%)

A. Fission and Activiation Gases:

1. Total Release Curies 9.63E-02 8.57E-03 1.80E+1

2. Average* Release Rate For Period µCi/sec 1.24E-02 1.09E-03 B. Iodines:

1. Total lodine-131 Release Curies O.OOE+OO O.OOE+OO 2.80E+1

2. Average Release Rate For Period µCi/sec O.OOE+OO O.OOE+OO C. Particulate {T112 > 8 dais}:

1. Total Particulate (T112 > 8 days) Release Curies 3.10E-06 1.82E-05 2.80E+1

2. Averaae Release Rate For Period µCi/sec 3.99E-07

2.32E-06

3. Gross Alpha Radioactivity Release Curies O.OOE+OO 7.54E-08 D. Tritium:

1. Total Release Curies 3.46E+OO 4.60E+OO 3.10E+1

2. Average Release Rate For Period µCi/sec 4.44E-01 5.85E-01 E. Carbon-14 '

1. Total Release Curies 1.93E+OO 1.72E-01

2. Average Release Rate For Period µCi/sec 2.45E-01 2.19E-02 F. Percentage Of Technical S(!ecification Limits

1. Total Body Dose Rate % 1.98E-06 6.17E-08

2. Skin Dose Rate % 3.65E-06 1.37E-07

3. Critical Organ Dose Rate (with C-14) % 1.SOE-03 4.32E-04 Gritical Organ Dose Rate (without C-14) % 2.36E-04 3.69E-04

TABLE 1A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF ALL GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 2 of 2 3RD 4TH ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%)

A. Fission and Activiation Gases:

1. Total Release Curies 1.09E+OO 2.26E-01 1.80E+1

2. Average Release Rate For Period µCi/sec 1.37E-01 2.85E-02

8. Iodines:

1. Total lodine-131 Release Curies O.OOE+OO O.OOE+OO 2.80E+1

2. Average Release Rate For Period µCi/sec O.OOE+OO O.OOE+OO C. Particulate {T112 > 8 dal£s}:

1. Total Particulate (T112 > 8 days) Release Curies O.OOE+OO O.OOE+OO 2.80E+1

2. Average Release Rate For Period µCi/sec O.OOE+OO O.OOE+OO

3. Gross Alpha Radioactivity Release Curies 5.27E-08 O.OOE+OO D. Tritium:

1. Total Release Curies 1.40E+OO 9.54E+OO 3.10E+1

2. Average Release Rate For Period µCi/sec 1.76E-01 1.20E+OO F. Carbon-14

1. Total Release Curies 2.19E+01 4.52E+OO

2. Average Release Rate For Period µCi/sec 2.76E+OO 5.69E-01 F. Percentage Of Technical SQecification Limits 2.23E-03 1.82E-06

1. Total Body Dose Rate %

2. Skin Dose Rate % 5.43E-04 2.03E-06

3. Critical Organ Dose Rate (with C-14) % 6.06E-02 2.39E-03 Critical Organ Dose Rate (without C-14) % 1.96E-05 7.60E-04

TABLE 18 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases:

Krypton - 85 Ci N/D N/D N/D N/D Krypton - 85m Ci N/D N/D N/D N/D Krypton - 87 Ci N/D N/D N/D N/D Krypton - 88 Ci N/D N/D N/D N/D Xenon - 131m Ci N/D N/D N/D N/D Xenon-133 Ci 1.85E-02 5.31E-03 2.31E-02 1.56E-03 Xenon -133m Ci N/D N/D N/D N/D Xenon -135 Ci N/D N/D N/D N/D Xenon -135m Ci N/D N/D N/D N/D Xenon -137 Ci N/D N/D N/D N/D Xenon -138 Ci N/D N/D N/D N/D Other (Specify) N/D N/D N/D N/D Argon - 41 Ci 3.67E-02 N/D 7.17E-03 1.70E-03 Total For Period Ci 5.52E-02 5.31E-03 3.03E-02 3.26E-03 Iodines:

Iodine -130 Ci . N/D N/D N/D N/D Iodine - 131 Ci N/D N/D N/D N/D Iodine -132 Ci N/D N/D N/D N/D lodine-133 Ci N/D N/D N/D N/D Iodine - 134 Ci N/D N/D N/D N/D Iodine - 135 Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D Particulates:

Manganese - 54 Ci N/D N/D N/D N/D Cobalt - 58 Ci N/D N/D N/D N/D Iron - 59 Ci N/D N/D N/D N/D Cobalt- 60 Ci N/D N/D N/D N/D i*

Zinc- 65

Ci ' N/D N/D N/D N/D Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D

'cesium - 134 Ci N/D N/D N/D N/D Cesium -136 Ci N/D N/D N/D N/D Cesium - 1.37 Ci N/D N/D N/D N/D

TABLE 18 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.)

Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium - 141 Ci N/D N/D N/D N/D Cerium -144 Ci N/D N/D N/D N/D Ag-11Dm Ci N/D N/D N/D N/D Total for Period (T1/2 > 8 days) Ci N/D N/D N/D N/D Total for Period (T1/2 < 8 days) Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D GROSS ALPHA: Ci N/D N/D N/D . N/D TRITIUM: Ci 9.45E-01 5.15E-D1 7.57E-03 4.28E-04 CARBON-14 Ci 1.11E+OO 1.06E-01 6.0SE-01 6.55E-02

TABLE 18 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases:

Krypton - 85 Ci N/0 N/0 N/0 N/0 Krypton - 85m Ci N/0 N/0 N/0 N/D Krypton - 87 Ci N/0 N/0 N/D N/0 Krypton - 88 Ci N/0 N/0 N/0 N/0 Xenon -131m Ci N/0 N/0 N/D N/0 Xenon -133 Ci 8.59E-03 2.05E-01 N/0 N/0 Xenon-133m Ci N/0 N/0 N/0 N/0 Xenon -135 Ci N/0 1.95E-03 N/0 N/0 Xenon -135m Ci N/0 N/D N/0 N/0 Xenon -137 Ci N/0 N/0 N/0 N/0 Xenon -138 Ci N/0 N/0 N/0 N/0 Other (Specify) N/D N/D N/D N/D Argon - 41 Ci 4.38E-03 1.96E-02 N/0 N/D Total For Period Ci 1.30E-02 2.27E-01 N/0 N/D Iodines:

Iodine - 130 Ci N/0 N/0 N/0 N/0 Iodine - 131 Ci N/0 N/0 N/0 N/0 Iodine - 132 Ci N/0 N/0 N/0 N/0 Iodine -133 Ci N/D N/D N/D N/0 Iodine -134 Ci N/0 N/0 N/0 N/0 Iodine - 135 Ci N/D N/0 N/0 N/0 Total For Period Ci N/0 N/D N/0 N/0.

Particulates:

Manganese - 54 Ci N/D N/0 N/0 N/D Cobalt- 58 Ci N/0 N/0 N/0 N/0 Iron - 59 Ci N/D N/0 N/0 N/D Cobalt-60 Ci N/0 N/0 NID N/0 Zinc- 65 Ci N/0 N/0 N/0 N/D Strontium - 85 Ci N/0 N/0 N/0 N/0 Strontium - 89 Ci N/0 N/0 N/0 N/D Strontium - 90 Ci N/0 N/0 N/0 N/D Silver-11 Om Ci N/0 N/0 N/D N/D Cesium-134 Ci N/0 N/0 N/0 N/D Cesium -137 Ci N/0 N/0 N/D N/D

TABLE 1~

NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT MIXED MODE GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.)

Barium - Lanthanum - 140 Ci N/D N/D N/D N/D Cerium - 141 Ci N/D N/D N/D N/D Cerium -144 Ci N/D N/D N/D N/D Total for Period (T1/2 > 8 days) Ci N/D N/D N/D N/D Total for Period (T1/2 < 8 days) Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D GROSS ALPHA: Ci N/D N/D N/D N/D TRITIUM: Ci 1.35E+OO 1.04E+OO 1.19E-04 O.OOE+OO CARBON-14 Ci 2.60E-01 4.52E+OO 0.00E+OO O.OOE+OO

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases:

Krypton - 85 Ci N/D N/D N/D N/D Krypton - 85m Ci N/D N/D 2.27E-05 N/D Krypton - 87 Ci N/D N/D N/D N/D Krypton - 88 Ci N/D N/D N/D N/D Xenon - 131m Ci N/D N/D N/D N/D Xenon - 133 Ci N/D N/D 8.89E-03 N/D Xenon -133m Ci N/D N/D 2.17E-04 N/D Xenon - 135 Ci N/D N/D 1.62E-03 N/D Xenon -135m Ci N/D N/D N/D N/D Xenon - 137 Ci N/D N/D N/D N/D Xenon - 138 Ci N/D N/D N/D N/D Other (Specify)

Argon - 41 Ci N/D N/D 1.24E-04 N/D Total For Period Ci N/D N/D 1.09E-02 N/D Iodines:

Iodine - 130 Ci N/D N/D N/D N/D lodine-131 Ci N/D N/D N/D N/D Iodine - 132 Ci 2.99E-06 N/D 8.33E-06 N/D Iodine - 133 Ci N/D N/D N/D N/D Iodine - 134 Ci N/D N/D N/D N/D Iodine - 135 Ci N/D N/D *N/D N/D Total For Period Ci 2.99E-06 N/D 8.33E-06 N/D Particulates:

Manganese - 54 Ci N/D N/D N/D N/D Cobalt - 58 ! Ci N/D N/D 6 ..:12E-07 1.49E-06 Iron - 59 Ci N/D N/D N/D N/D Cobalt- 60 Ci N/D N/D 8.61 E-07 1.89E-06 Zinc-65 Ci N/D N/D N/D N/D Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D Cesium -134 Ci N/D N/D N/D N/D

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.)

Cesium -137 Ci N/D N/D N/D N/D Arsenic-76 ( T1/2 < 8 days) Ci N/D N/D 1.0BE-06 N/D Rubidium-88 Ci N/D N/D 3.90E-07 N/D Cerium - 144 Ci N/D N/D N/D N/D Niobium-95 Ci N/D N/D 2.73E-07 6.89E-06 Zirconium-95 Ci N/D N/D 3.57E-07 4.54E-06 Tellurium-131m (T1/2 < 8 days) Ci N/D N/D N/D N/D Yttrium-91m (T1/2 < 8 days) Ci N/D N/D 1.02E-06 N/D Chromium-51 Ci N/D N/D 9.99E-07 3.42E-06 Total for Period (T1/2 > 8 days) Ci N/D N/D 3.10E-06 1.82E-05 Total for Period (T1/2 < 8 days) Ci N/D N/D 2.49E-06 N/D Total For Period Ci N/D N/D 5.59E-06 1.82E-05 GROSS ALPHA: Ci O.OOE+OO 7.54E-08 N/D N/D TRITIUM: Ci 9.66E-01 3.28E+OO 1.54E+OO 7.97E-01 CARBON-14 Ci N/D N/D 2.18E-01 N/D

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Gases:

Krypton - 85 Ci N/D N/D N/D N/D Krypton - 85m Ci N/D N/D N/D N/D Krypton - 87 Ci N/D N/D N/D N/D Krypton - 88 Ci N/D N/D N/D N/D Xenon -131m Ci N/D N/D N/D N/D Xenon - 133 Ci N/D N/D N/D N/D Xenon -133m Ci N/D N/D N/D N/D Xenon - 135 Ci N/D N/D N/D N/D Xenon - 135m Ci N/D N/D N/D N/D Xenon-137 Ci N/D N/D N/D N/D Xenon -138 Ci N/D N/D N/D N/D Other (Specify) Ci Argon - 41 Ci 1.08E+OO N/D N/D N/D Total For Period Ci 1.08E+OO N/D N/D N/D Iodines:

Iodine -130 Ci N/D N/D N/D N/D Iodine - 131 Ci N/D N/D N/D N/D Iodine -132 Ci N/D N/D N/D N/D Iodine - 133 Ci N/D N/D N/D N/D Iodine - 134 Ci N/D N/D N/D N/D Iodine - 135 Ci N/D N/D N/D N/D Total For Period Ci N/D N/D N/D N/D Particulates:

Manganese - 54 Ci N/D N/D N/D N/D Cobalt - 58 i ,. Ci N/D N/D 1* N/D ' N/D Iron - 59 Ci N/D N/D N/D N/D Cobalt- 60 Ci N/D N/D N/D N/D Zinc-65 Ci N/D N/D N/D N/D Strontium - 89 Ci N/D N/D N/D N/D Strontium - 90 Ci N/D N/D N/D N/D Cesium -134 Ci N/D N/D N/D N/D

TABLE 1C NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT GROUND LEVEL GASEOUS EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Particulates: (cont.)

Cesium -137 Ci N/D N/D N/D N/D Barium - Lanthanum -140 Ci N/D N/D N/D N/D Cerium - 141 Ci N/D N/D N/D N/D Cerium -144 Ci N/D N/D N/D N/D Other (Specify)

Strontium-91 (T1/2 < 8 days) Ci N/D N/D N/D N/D Rubidium-BB (T1/2 < 8 days) Ci N/D N/D N/D N/D Niobium-95 (T1/2 > 8 days) Ci N/D N/D N/D N/D Ru-103 (T1/2 > 8 days) Ci N/D N/D N/D N/D Rhodium-105 (T1/2 < .8 days) Ci N/D N/D NIP N/D Ruthenium-105 (T1/2 < 8 days) Ci N/D N/D N/D N/D Total for Period (T1/2 > 8 days) Ci N/D N/D N/D N/D Total for Period (T1/2 < 8 days) Ci N/D N/D N/D N/D Total For Period Ci N/D N/D O.OOE+OO O.OOE+OO GROSS ALPHA: Ci 5.27E-08 N/D N/D N/D TRITIUM: Ci N/D 8.46E+OO 4.94E-02 3.64E-02 CARBON-14 Ci 2.16E+01 N/D N/D N/D

TABLE 2A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT - SUMMATION OF ALL RELEASES FOR (01/18 - 12/18)

Page 1 of2 1 ST 2 ND ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%)

A. Fission and Activiation Products:

1. Total Release (not including tritium, noble gas, and qross alpha). Curies 1.57E-02 3.65E-03 2.00E+01

2. Average diluted concentration during the period. µCi/ml 5.73E-11 4.81 E-12

3. Percent of applicable limit (T.S.) % 1.01E-04 6.33E-06 B. Tritium:

1. Total release activity. Curies 5.78E+02 1.79E+02 2.00E+01

2. Average diluted concentration during the period. µCi/ml 2.11E-06 2.36E-07

3. Percent of aoolicable limit (T.S.) % 2.11 E-02 2.36E-03 C. Dissolved and Entrained Gases:

1. Total release activity. Curies O.OOE+OO O.OOE+OO 2.00E+01

2. Average diluted concentration during the period. µCi/ml O.OOE+OO O.OOE+OO

3. Percent of applicable limit (T.S.) % O.OOE+OO O.OOE+OO D. Gross Alpha Radioactivity:

1. Total release activity. Curies O.OOE+OO O.OOE+OO 2.00E+01 E. Volume of waste released: (prior to dilution). Liters 7.94E+07 1.17E+08 3.00E+OO F. Total volume of dilution water used during the period. Liters . 2.74E+11 7.58E+11 3.00E+OO

TABLE 2A NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT - SUMMATION OF ALL RELEASES FOR (01/18 - 12/18)

Page 2 of2 3 RD 4 TH ESTIMATED TOTAL UNITS QUARTER QUARTER PERCENT ERROR (%)

A. Fission and Activiation Products:

1. Total Release (not including tritium, noble gas, and gross alpha). Curies 1.99E-03 1.29E-03 2.00E+01

2. Average diluted concentration during the period. µCi/ml 2.27E-12 2.00E-12

3. Percent of applicable limit (T.S.) % 3.14E-06 9.96E-06 B. Tritium:

1. Total release activity. Curies 2.16E+02 3.18E+02 2.00E+01

2. Average diluted concentration during the period. µCi/ml 2.47E-07 4.92E-07

3. Percent of applicable limit (T.S.) % 2.47E-03 4.92E-03 C. Dissolved and Entrained Gases:

1. Total release activity. Curies O.OOE+OO O.OOE+OO 2.00E+01

2. Average diluted concentration during the period. µCi/ml O.OOE+OO O.OOE+OO

3. Percent of applicable limit (T.S.) % O.OOE+OO O.OOE+OO D. Gross Alpha Radioactivity:

1. Total release activity. Curies O.OOE+OO O.OOE+OO 2.00E+01 E. Volume of waste released: (prior to dilution). Liters 1.02E+08 1.02E+08 3.00E+OO F. Total volume of dilution water used during the period. Liters 8.}6E+11 6.46E+11 3.00~+00

TABLE 28 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 1 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Products:

Manganese - 54 Ci 2.09E-04 1.47E-04 N/A NIA Iron - 59 Ci N/D N/D N/A N/A Cobalt- 58 Ci 8.03E-03 2.51 E-03 N/A N/A Cobalt-60 Ci 6.16E-03 8.24E-04 N/A N/A Strontium - 89 Ci N/D N/D N/A N/A Strontium - 90 Ci N/D N/D N/A N/A Niobium - 95 Ci 6.38E-04 5.00E-05 N/A N/A Antimony-124 Ci N/D N/D N/A N/A Si1ver-110m Ci 2.68E-05 N/D N/A N/A Iodine - 131 Ci N/D N/D N/A N/A Iodine - 133 Ci N/D N/D N/A N/A Cesium - 134 Ci N/D N/D N/A N/A Cesium -137 Ci 2.68E-04 6.76E-05 N/A N/A Zirconium - 95 Ci 1.10E-04 N/D N/A N/A Cerium - 141 Ci N/D N/D N/A N/A Tellurium-125m Ci

3.60E-05 N/D N/A N/A Niickel - 63 (T1/2 > 8 days) Ci N/D N/D N/A N/A Antimony-125 Ci 1.56E-04 N/D N/A N/A Total for Period Ci 1.56E-02 3.60E-03 N/A N/A

TABLE 28 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 2 of 4 CONTINUOUS MODE BATCH MODE 1ST 2ND 1ST 2ND NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Dissolved & Entrained Noble Gases:

Xenon -133 Ci NID NID NIA NIA Xenon-133m Ci NID NID NIA NIA Xenon -135 Ci N/D NID NIA NIA Xenon-135m Ci N/D NID NIA NIA Other (Specify) Ci NID NID NIA NIA Krypton-88 ( T112 < 8 days) Ci NID NID NIA NIA Krypton-85 (T112 > 8 days) Ci N/D NID NIA NIA Total for Period Ci NID NID NIA NIA Tritium Ci 5.78E+02 1.79E+02 NIA NIA Gross Alpha Ci NID NID NIA NIA

TABLE 28 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 3 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Fission & Activation Products:

Manganese - 54 Ci 1.27E-04 N/D N/A 1.07E-07 Iron - 59 Ci N/D N/D N/A N/D Cobalt- 58 Ci 1.18E-03 N/D N/A 6.17E-07 Cobalt-60 Ci 6.07E-04 7.30E-05 N/A 2.45E-06 Strontium - 89 Ci N/D N/D NIA N/D Strontium - 90 Ci N/D N/D N/A N/D Niobium -95 Ci N/D N/D N/A \

2.32E-07 Zirconium - 95 Ci N/D N/D N/A N/D Silver-110m Ci N/D N/D N/A N/D Iodine - 131 Ci N/D N/D N/A N/D Iodine - 133 Ci N/D N/D N/A N/D Cesium -134 Ci N/D 1.70E-05 N/A 1.11 E-05 Cesium -137 Ci N/D 4.41E-04 N/A 1.24E-04 Barium-Lathanum - 140 Ci N/D N/D N/A N/D Cerium - 141 Ci N/D N/D N/A N/D Chromium-51 Ci N/D N/D N/A 5.35E-06 Nickel - 63 (T1/2 > 8 days) Ci N/D N/D N/A N/D Antimony-122 (T1/2 < 8 days) Ci N/D N/D N/A 1.07E-06 Antimony-125 (T1/2 > 8 days) Ci 3.82E-04 N/A 1.19E-04 Antimony-124 (T1/2 > 8 days) Ci N/D N/D N/A N/D Tellurium-125m (T1/2 > 8 days) Ci 8.84E-05 N/A 2.74E-05 Total for Period Ci 1.91 E-03 1.00E-03 N/A 2.91E-04

TABLE 28 NORTH ANNA POWER STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT LIQUID EFFLUENT RELEASES FOR (01/18 - 12/18)

Page 4 of 4 CONTINUOUS MODE BATCH MODE 3RD 4TH 3RD 4TH NUCLIDES RELEASED UNITS QUARTER QUARTER QUARTER QUARTER Dissolved & Entrained Noble Gases:

Xenon -133 Ci N/D N/D N/A N/D Xenon -133m Ci N/D N/D N/A N/D Xenon -135 Ci N/D N/D N/A N/D Xenon -135m Ci N/D N/D N/A N/D Other (Specify)

Argon - 41 (T1/2 < 8 days) Ci N/D N/D N/A N/D Krypton - 85 (T1/2 > 8 days) Ci N/D N/D N/A N/D Total for Period Ci N/D N/D N/A N/D Tritium Ci 2.16E+02 3.18E+02 N/A 6.27E-02

'Gross Alpha Ci N/D N/D N/A N/D

TABLE 3 NORTH ANNA POWER STATION RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF SOLID RADIOACTIVE WASTE AND IRRADIATED FUEL SHIPMENTS FOR 01-01-18 THROUGH 12-31-18 Page 1 of 2 A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (NOT IRRADIATED FUEL) 12-Month Estimated Total

1. Type of Waste Unit Period Percent Error (%)

a. Spent resins, sludges, filters sludge, m3 1.95E+01

2.50E+01 evaporator bottoms, etc., Ci 5.38E+01 2.50E+01

b. Dry compressible waste, contaminated m3 2.68E+02 ** 2.50E+01 c.

equipment, etc.,

Irradiated components, control rods, Ci m3 2.67E-01 O.OOE+OO

... 2.50E+01 2.50E+01 etc., Ci O.OOE+OO 2.50E+01

d. Other (describe)

Used oil/Blast media/Sewage/Gravel m3 1.55E+OO **** 2.50E+01 Dessicant/Soil/Constru ction debris Ci 7.49E-02 2.50E+01 Animal Carcasses

2. Estimate of major nuclide composition Estimated Total (by type of waste) (%) (Ci) Percent Error (%)

a. Ni-63 4.00E+01 2.15E+01 2.50E+01 Co-60 3.01E+01 1.62E+01 2.50Et01 Co-58 1.02E+01 5.47E+OO 2.50E+01 Cs-137 6.91E+OO 3.72E+OO 2.50E+01 Fe-55 5.60E+OO 3.02E+OO 2.50E+01 Sb-125 1.61E+OO 8.65E-01 2.50E+01 Mn-54 1.39E+OO 7.SOE-01 2.50E+01 Cr-51 8.JOE-01

4.47E-01 2.50E+01 Cs-134 8.00E-01 4.32E-01 2.50E+01 Ni-59 7.BOE-01 4.19E-01 2.50E+01 H-3 4.SOE-01 2.40E-01 2.50E+01 C-14 3.70E-01 2.00E-01 2.50E+01 Nb-95 3.JOE-01 1.7BE-01 2.50E+01 Aa-110m 2.GOE-01 1.39E-01 2.50E+01

b. Co-60 4.10E+01 1.09E-01 2.50E+01 Nb-95 2.1BE+01

5.82E-02 2.50E+01 Zr-95 1.29E+01 3.43E-02 2.50E+01 Cs-137 6.BBE+OO 1.84E-02 2.50E+01 Ni-63 5.32E+OO 1.42E-02 2.50E+01 Cr-51 4.31E+OO 1.15E-02 2.50E+01 Co-58 2.93E+OO 7.84E-03 2.50E+01 Fe-55 2.15E+OO 5.74E-03 2.50E+01 Sb-125 1.00E+OO 2.66E-03 2.50E+01 Mn-54 8.BOE-01 2.36E-03 2.50E+01 Sn-113 2.70E-01 7.20E-04 2.50E+01 Te-125m 2.JOE-01 6.07E-04 2.50E+01 H-3 1.BOE-01 4.77E-04 2.50E+01 ln-113m 1.JOE-01

3.JBE-04 2.50E+01 Ag-110m 1.20E-01 3.16E-04 2.50E+01 C. NONE

.d. H-3 9.89E+01 7.41E-02 2.50E+01 Cs-137 4.70E-01 3.51E-04 2.50E+01 Co-60 2.90E-01 2.19E-04 2.50E+01

TABLE 3 NORTH ANNA POWER STATION RADIOACTIVE EFFLUENT RELEASE REPORT SUMMATION OF SOLID RADIOACTIVE WASTE AND IRRADIATED FUEL SHIPMENTS 01-01-18 THROUGH 12-31-18 Page 2 of 2

3. Solid Waste Disposition Number of Shipments Mode of Transportation Destination 11 Truck Oak Ridge, TN

8. Irradiated Fuel Shipments (Disposition)

Number of Shipments Mode of Transportation Destination 0 N/A N/A (4) shipments containing resins were shipped to a licensed waste processor for final dewatering (1) shipment containing mechanical filters was shipped to a licensed waste processor for processing (1) shipment containing sludge was shipped to a licensed waste processor for processing (7) shipments containing dry compactable waste were shipped to a licensed waste processor for processing None (1) shipment containing dried bird droppings was shipped to a licensed waste facility for processing (1) shipment containing waste oil was shipped to licensed waste facility for processing

-~~,

rll Dominion Station Administrative Procedure

Title:

Offsite Dose Calculation Manual (North Anna)

Process / Program Owner: Manager Radiological Protection and Chemistry (North Anna)

Procedure Number Revision Number Effective'Date VPAP-2103N 28 On File Revision Summary Revision initiated to incorporate assignment from CR1081346:

Attachment 10, Page 4 of 5:

Removed milk sample location due to unavailability

Added Foot Note b, stating no milk producing animals are available in NAPS monitoring locations following the Harris Dairy closure 01/01/2018. Future milk availability will be determined from the annual land use census data .

Approvals on File

DOMINION VPAP-2103N REVISI0N28 PAGE20F87 TABLE OF CONTENTS Section Page 1.0 PURPOSE 5 2.0 SCOPE 5

3.0 REFERENCES

/COMMITMENT DOCUMENTS 6 4.0 DEFINITIONS 8 5.0 RESPONSIBILITIES 11 6.0 INSTRUCTIONS 12 6.1 Sampling and Monitoring Criteria 12 6.2 Liquid Radioactive Waste Effluents 12 6.2.1 Liquid Effluent Concentration Limitations 12 6.2.2 Liquid Monitoring Instrumentation 13 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 18 6.2.5 Liquid Sampling 19 6.3 Gaseous Radioactive Waste Effluents 19 6.3.1 Gaseous Effluent Dose Rate Limitation 19 6.3.2 Gaseous Monitoring Instrumentation 22 6.3.3 Noble Gas Effluent Air Dose Limit 25 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form.Effluent Dose Limit 27 6.3.5 Gaseous Radwaste Treatment 29 6.4 Radioactive Liquid and Gaseous Release Permits 31 6.4.1 Liquid Waste Batch Release Permits 31 6.4.2 Continuous Release Permit 31 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 32 6.4.4 Reactor Containment Release Permits 32 6.4.5 Miscellaneous Gaseous Release Permit 32

DOMINION VPAP-2103N REVISION 28 PAGE3 OF 87 TABLE OF CONTENTS (continued)

Section Page 6.4.6 Radioactive Liquid and Gaseous Release Controls 32 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 34 6.6.1 Monitoring Program 34 6.6.2 Land Use Census 36 6.6.3 Interlaboratory Comparison Program 37

6. 7 Reporting Requirements 38

6. 7 .1 Annual Radiological Environmental Operating Report 38 6.7.2 Annual Radioactive Effluent Release Report 39 6.7.3 Annual Meteorological Data 42 6.7.4 Changes to the ODCM 42 6.7 .5 Groundwater Protection Initiative [Reference 3.1.35] 43 7.0 RECORDS 44

DOMINION VPAP-2103N REVISI0N28 PAGE40F87 TABLE OF CONTENTS (continued)

Section Page ATTACHMENTS 1 Radioactive Liquid Effluent Monitoring Instrumentation 45 2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements 47 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52

5. Gaseous Effluent Dose Factors 56 6 Radioactive Gaseous Effluent Monitoring Instrumentation 59 7 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 62 8 Critical Organ Dose Factors 65 9 Radiological Environmental Monitoring Program 67 10 Environmental Sampling Locations 72 11 Detection Capabilities for Environmental Sample Analysis 77 12 Reporting Levels for Radioactivity Concentrations in Environmental Samples 79 13 Meteorological, Liquid, and Gaseous Pathway Analysis 80

DOMINION VPAP-2103N REVISI0N28 PAGES OF 87 1.0 PURPOSE The Offsite Dose Calculation Manual (OD~M) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters ar:e provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are.performed to assure that:

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

Exposure to the maximum exposed 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 CPR 50, Appendix I

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

.. Noble gases - less than or equal to a dose rate of 500 mrem/yr fo the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin

- 1131 , 1133 , and H3 , and all radionuclideS in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ

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

Exposure to a real individual will not exceed 40 CPR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Environmental Monitoring Programs at North Anna Power Station.

~I DOMINION VPAP-2103N REVISION 28 PAGE60F87

3.0 REFERENCES

/COMMITMENT DOCUMENTS 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 Utilizati.on Facilities 3 .1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3 .1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3 .1.6 Regulatory Guide 1.109, Calculation of Annual Doses to Man From Routine 'Releases of Reactor Effluents for the Purpose of Evaluating Compliance With 10 CPR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 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 3.1.8 North Anna Technical Specifications 3.1.9 North Anna Technical Requirements Manual (TRM) 3.1.10 NUREG-0324, XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1977 3.1.11 NUREG/CR-1276, Users Manual for the LADT AP II Program, U.S. NRC, May, 1980 3.1.12 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.13 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 3.1.14 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.15 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1

3.1.16 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.17 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CPR Part 190) 3.1.18 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Proposed Rev. 3, March 1982

DOMINION VPAP-2103N REVISION28 PAGE 7 OF 87 3.1.19 Environmental Measurements Laboratory, DOE HASL 300 Manual 3.1.20 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specificat~ons and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.'1.21 North Anna UFSAR 3.1.22 Nuclear Reactor Environmental Radiation Monitoring Quality Control Manual, IWL-0032-361 3.1.23 North Anna Circulating Water System Modifications

a. DC-85-37-1 Unit 1

b. DC-85-38-2 Unit 2 3.1.24 Plant Issue (Deviation) N-1994-1137, Improper Placement of Emergency TLDs 3.1.25 ET N-05-0025, Justification for removing 1-SW-RM-108 from service when not in use 3.1.26 VPAP-2802, Notifications and Reports 3.1.27 O-PT-75.21, 1-SW-RM-108 Flow Verification 3.1.28 SAA001092, Non-SA SOER Effectiveness Review 93-1, Recommendation 3 3.1.29 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.30 CA086406, Land Use Census Results 3.1.31 Quality Assurance Audit Report Number 91-03, Observatiqn 08N 3.1.32 Quality Assurance Audit Report Number 92-03, Observation 02N 3.1.33 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.1.34 Plant Issue (Deviation) N-1997-0926, Annual Radiological Effluent Release Report 3.1.35 Plant Issue (Licensing Commitment) N-2006-4026-Rl5, Groundwater Monitoring Action Plan 3.1.36 SOER 93-1, Diagnosis and Mitigation of RCS Leakage inc~uding SGTR 3.1.37 CR558854/CA293145 - Environmental Monitoring TLD locations might not be aligned with the ODCM requirement 3.1.38 CR541897/CA300793,Revise section 2.3 in attachment 13 of the ODCM 3.2 Commitment Documents None

DOMINION VPAP-2103N REVISI0N28 PAGE 8 OF87 4.0 DEFINITIONS 4.1 Channel Calibration A channel calibration shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The channel calibration shall encompass all devices in the channel required for channel operability. The channel calibration may be performed by means of any series of sequential, overlapping, or total channel steps.

4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and status with other indications or status derived from independent instrumentatio~ channels meas~ring the same parameter.

4.3 Channel Operational Test A Channel Operational Test (COT) shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to check OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

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

4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/cc) that alone would produce the same thyroid dose as the 132 133 13 135 quantity and isotopic mixture ofl 131 , 1 , 1 , I 4, and 1 actually present. Thyr~id dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103N REVISION 28 PAGE 9 OF 87 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent.

NOTATION FREQUENCY D - Daily At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months W - Weekly At least once per 7 days M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA - Semi-annually At least once per 184 days R - Refueling At least once per 18 months SIU - Start-up Prior to each reactor start-up P - Prior to release Completed prior to each release N.A. - Not applicable Not applicable DR - During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system 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, waste gas surge tanks, and waste gas diaphragm compressor.

4.8 General Nomenclature X = Chi: concentration at a point at a give*n instant (curies per cubic meter)

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

Q = Source strength (instantaneous; grams, curies)

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

= Emission rate (continuous line source; grams per second per meter) 4.9 Lower Limit of Detection (LLD)

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

DOMINION VPAP-2103N REVISION 28 PAGE 10 OF 87 4.10 Members of the Public Individuals who, by virtue of their occupational status, have no formal association with the Station. This category includes non-employees of Dominion who are permitted to use portions of the site forrecreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials.

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

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

4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., North Anna - 2940 MWt).

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

4.15 Source Check A qualitative assessment of channel response when a channel sensor is exposed to a radioactive source. This applies to installed radiation monitoring systems. For MGPI monitors, a source check is the verification of proper computer response to continuous operational checks on the detector and the electronics.

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

DOMINION VPAP-2103N REVISION28 PAGE 11 OF 87 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

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

4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEPA) 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 (ESP) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components.

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

5.1.1 Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment.

5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monit<.?ring, and documenting these activities.

5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends.

5 .1.4 Preparing Effluent and Environmental Monitoring Program records.

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

DOMINION VPAP-2103N REVISION 28 PAGE 12 OF 87 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 13).

6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored.

6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored.

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

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

6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detaHed that the meaning and intent of the records are clear.

6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy.

6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

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

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

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

DOMINION VPAP-2103N REVISION28 PAGE 13 OF 87

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

Volume of Waste Discharged+ Volume ofDilution Water> 1 (1)

µCi/ml.1 -

Volume of Waste Discharged x ~

. ~ACW.

. 1 1

where:

µCi/mli = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/ml from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/ml for dissolved or entraine~ noble gases 6.2.2 Liquid Monitoring Instrumentation

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

operable with their alarm/trip setpoints set to ensure that Step 6.2.1.a. limits are not exceeded.

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

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

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

Declare the channel inoperable

Change the setpoint to an acceptable, conservative value

DOMINION VPAP-2103N REVISION28 PAGE 140F87

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

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

1) perform the action shown in those tables.

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

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

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

DOMINION VPAP-2103N REVISION28 PAGE 15 OF87

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

1. Maximum setpoint values shall be calculated by:

s (2) where:

S = the setpoint, in µCi/ml, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station, in µCi/ml FE = maximum design pathway effluent flow rate F 0 = dilution water flow rate calculated as:

D = FE + (218,000 gpm x number of circ. pumps in service)

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

S = C (3)

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

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

DOMINION VPAP-2103N REVISION28 PAGE 16 OF 87

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

s (4) where:

KLw = The fraction of the effluent concentration *limit, used to implement 10 CFR 20 for the site, attributable to the liquid radwaste effluent line pathway

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

s (5) where:

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

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

6.2.3 Liquid Effluent Dose Limit

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

1. During any calendar quarter:

Less than or equal to 1.5 rrirem to the total body

Less than or equal to 5 mrem to the critical organ

2. During any calendar year:

Less than or equal to 3 mrem to the total body

Less than or equal to 10 mrem to the critical organ*

DOMINION VPAP-2103N REVISION 28 PAGE 17 OF87

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 special report in accordance with VPAP-2802, Notifications and Reports, that identifies causes for exceeding limits and defines corrective actions taken to reduce releases of radioactive materials in liquid effluents to ensure that subsequent releases will be in compliance with the above limits.

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

(6)

D ~Q.xB.

~ l l Where:

Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem Bi = Dose Commitment Factors (mrem/Ci) for each age group of interest.

Values for Bi are provided in code file for North Anna Power Station liquid pathway critical organ calculations Qi = Total released activity for the considered period and the ith nuclide Qi = t x Ci x Waste Flow (7)

Where:

t = the period for which Ci and F are averaged for all liquid releases, in hours Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period, t, from any liquid releases, in µCi/ml

DOMINION VPAP-2103N REVISION28 PAGE 18 OF87

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

6.2.4 Liquid Radwaste Treatment Historical data pertaining to the volumes and radioactivity ofliquid effluents released in connection with specific station functions, such as maintenance or_ refueling outages, shall be used in projections as appropriate.

a. Requirement

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

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

b. Action If radioactive liquid waste is discharged without treatment and in excess of the above limits prepare and submit to the NRC, within 30 days, a special report in

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body Dose Calculation

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

DOMINION VPAP-2103N REVISI0N28 PAGE 19 OF87

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

3. Estimate F 1, the ratio of the estimated liquid effluent'radioactivity concentration in the present 31-day period to liquid effluent concentration in the previous 31-day period (µCi/ml).

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

(8)

d. Projected Critical Organ Dose Calculation

1. Determine D 0 , the critical organ dose from liquid effluents in the previous 31-day period, per Equation (6).

2. Estimate R 1 as in Step 6.2.4.c.2.

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

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

(9) 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3).

6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitation

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

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

DOMINION VPAP-2103N REVISION 28 PAGE200F87

2. The dose rate limit for I 131 , I 133 , for tritium, and for all radioactive materials in particulate form with half-lives greater than 8 days shall bes 1500 mrem/year to the critical organ.

b. Action

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

2. Dose rates due to noble gases in gaseous effluents shall be determined, continuously, to be within Step 6.3.1.a. limits.

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

DOMINION VPAP-2103N REVISION 28 PAGE21 OF 87

c. Calculations of Gaseous Effluent Dose Rates

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

~

L...J [K.IVY Qivv + K.1pV Qipvl:::;; 500mrem/yr to the total body (10)

OR

~

L...J [(L.IVY + 1.lM.IVY )Qjyy+ (L.1pV + 1.lM.lpV )Q 1*pvl:::;; 3000mrem/yrto the skin (11) where:

Subscripts = vv, refers to vent releases from the building ventilation vent pv, refers to the vent releases from the process vent; i, refers to individual radionuclide

= The total body dose factor for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5)

= The skin dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5)

= The air dose factor for ventilation vents or process ve~t release due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5)

= The release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) 1.1 = The unit conversion factor that converts air dose to skin dose, in mrem/mrad

DOMINION VPAP-2103N REVISION28 PAGE 22 OF 87 133

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

L [P ivvQivv + P ipvQipv] ~ 1500mrem/yr to the critical organ (12) where:

= The critical orf:an dose factor for ventilation vents or process vent for I 131 , I 33 , H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the inhalation pathway, in mrem/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5) 131

= The release rate for ventilation vents or process vent of I ,

I 133 , H3, and all radionuclides i, in particulate form with half-lives greater than 8 days, in gas~ous effluents in Curie/sec (per site)

3. All gaseous releases, not through the process vent, are considered ground level and shall be included in the determination of Qivv.

6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrume!1tation channels .shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 6) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.1.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

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

DOMINION VPAP-2103N REVISI0N28 PAGE 23 OF87

b. Action

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

Suspend the release ofradioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or

Change the setpoint so it is acceptably conservative

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

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

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

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

DOMINION VPAP-2103N REVISION 28 PAGE240F87

d. Setpoint Calculations

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

(13) where:

D = Step 6.3.1.a. dose limits that implement 10 CFR 20 for the Station, mrem/yr Dpv = The noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = The noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr Dvv = The noble gas site boundary dose rate from summation of.

Ventilation Vent A plus B gaseous effluent releases, mrem/yr

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (14)

Fm where:

m = The release pathway, process vent (p,v), ventilation vent (vv) condenser air ejector (cae)

Cm = The effluent concentration limit implementing Step 6.3.1.a.

for the Station, µCi/ml Rm = The release rate limit for pathway m determined from 133 as nuclide to be methodology in Step 6.3.1.c., using Xe released, µCi/sec 2.12E-03 = CFM per ml/sec Fm = The maximum flow rate for pathway m, CFM

DOMINION VPAP-2103N REVISION 28 PAGE25 OF 87 NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

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

During any calendar quarter: ~ 5 mrads for gamma radiation and~ 10 mrads for beta radiation

During any calendar year: ~ 10 mrads for gamma radiation and ~ 20 mrads for beta radiation

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

at least once per 31 days.

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

DOMINION VPAP-2103N REVISION 28 PAGE260F87

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

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following:

For gamma radiation:

(15)

For beta radiation:

3.17E-08L [NivvQivv + NipvQipvJ (16)

Where:

Subscripts = vv, refers to vent releases from the building ventilation vents, including air ejectors pv, refers to the vent releases from the process verit i, refers to individual radionuclide

= the air dose for gamma radiation, in mrad

= the air dose for beta radiation, in mrad

= the air dose factors for ventilation vents or process vent release due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5)

= the air dose factor for ventilation vents or process vent release due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/sec. Factors are listed in Gaseous Effluent Dose Factors (Attachment 5)

= the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) .

3.17 E-08 = the inverse of the number of seconds in a year

DOMINION VPAP-2103N REVISION 28 PAGE27 OF87 6.3.4 1-131, 133, H-3 & Radionuclides In Particulate Form Effluent Dose Limit

a. Requirement

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

During any calendar quarter: ::;_ 7 .5 mrem to the critical organ

During any calendar year:::;_ 15 mrem to the critical organ 131 133

2. Cumulative dose contributions to a member of the public from I , 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 in accordance with Step 6.3.4.c.

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

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

DOMINION VPAP-2103N REVISION28 PAGE 28 OF87

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

1. The dose to the maximum exposed member of the public, attributable to 133 gaseous effluents at and beyond the site boundary, that contain I 131 , I ,

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

3 .17E-08 L [RMivv Qivv + RMipv Qipv] (17)

Where:

Subscripts = vv, refers to vent releases from the building ventilation vents; pv, refers to the vent releases from the process vent

Dr = the dose to the critical organ of the maximum exposed member of the public, in mrem RMivv, RMipv =the dose factor for ventilation vents or process vent release due to 1131 , 113 3, tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in mrem/yr per Curie/sec. Factors are listed in.Critical Organ Dose Factors (Attachment 8) 131 133 QivvQipv = the release for ventilation vents or process vent of I , I ,

tritium, and from all particulate-form radionuclides with half-lives greater than 8 days, in Curies 3 .17 E-08 = the inverse of the number of seconds in a year

DOMINION VPAP-2103N REVISION28 PAGE290F87 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

2. Actions taken to restore the inoperable equipment to operabl~ status.

3. Summary description of actions taken to prevent recurrence.

c. Projected Gamma Dose

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

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

~-

DOMINION VPAP-2103N REVISION28 PAGE 30 OF87

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

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

(18)

d. Projected Beta Dose

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

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

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

(19)

e. Projected Maximum Exposed Member of the Public Dose

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

131 133

2. Estimate Fi, the ratio of the estimated activity from I , 1 , radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the current 31-day period to the activity of 1131 , 1133 , radioactive materials in particulate form with half-lives greater than 8 days, and tritium in the previous 31-day period (µCi/ml).

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

PDmax (20)

DOMINION VPAP-2103N REVISION28 PAGE 31 OF 87 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases.

6.4.1 Liquid Waste Batch Release Permits Operations shall obtain RP authorization before initiating batch releases of radioactive liquids. Examples of batch releases include:

Batch Releases NOTE: If the clarifier is in service, releases from tanks processed through the clarifier are considered continuous releases.

A Batch Release Permit is required for a release from any tanks/sumps which contain (or potentially contain) radioactive liquid. Tanks/sumps inciude:

BRTT

LLWDT

HLWDT

Turbine Building Sumps when secondary coolant activity exceeds 1.0 E-5, µCi/ml

CDT 6.4.2 Continuous Release Permit Operations shall obtain RP authorization before initiating continuous releases of radioactive liquids.

Continuous Releases A Continuous Release Permit is required for:

Clarifier, unless being bypassed

Steam generator blowdown when clarifier is bypassed

Containment mat sumps and service water reservoir when clarifier is bypassed.

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

DOMINION VPAP-2103N REVISION28 PAGE 32 OF 87 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases.

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

Routine termination

Terminated for cause by RP

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

DOMINION VPAP-2103N REVISION 28 PAGE33 OF87

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

Maximum authorized release rate

Maximum authorized release rate in percentage of limits specified by the ODCM

Applicable conditions or controls pertaining to the release

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

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

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

2. Note maximum authorized release rate.

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

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

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

As appropriate, required information shall include:

" Date and time release was started

Starting tank/sump level

Beginning pressure

Release flow rate

Dilution water flow rate

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

Date and time release was stopped

Tank/sump ending level

Release flow rate just prior to termination

(

Ending pressure

Volume released

DOMINION VPAP-2103N REVISION 28 PAGE 34 OF 87 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 rnrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., caI.culate (including direct radiation contribution from the units and from outside storage 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 within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conform~nce with the limits. Special reports, as defined in 10 CPR 20.2203(a)(4), shall include:

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

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

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

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

DOMINION VPAP-2103N REVISION28 PAGE 35 OF87

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

3. Samples shall be analyzed in accordance with:

Radiological Environmental Monitoring Program (Attachment 9) requirements

Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 11)

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

b. Action

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

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

Identifies the causes for exceeding the limits, and

Defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a member of the public is less than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4*

When more than one of the ~adionuclides listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected in the sampling medium, the report shall be submitted if:

concentration (I) + concentration (2) + ... ~ 1.0 (2 l) reporting level (1) reporting level (2).

DOMINION VPAP-2103N REViSION 28 PAGE 36 OF 87

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 12) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater .than the calendar year limits of Steps 6.2.3, 6.3 .3, and 6.3 .4. The report is not required if the measured level of radioactivity was not the result of plant effluents; 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.

4. If milk or fresh leafy vegetable samples are unavailab!e from one or m9re of the sample locations required by Environmental Sampling Locations (Attachment 10), identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of samples and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports. Include in the report a revised figure and table for the ODCM to reflect the new locations.

6.6.2 Land Use Census

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

Nearest milk animal

Nearest residence

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

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

DOMINION VPAP-2103N REVISI0N28 PAGE 37 OF 87

2. In lieu of the garden census, broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the site boundary in each of two different direction sectors with the highest predicted ground deposition (D/Qs). Specifications for broad leaf vegetation sampling in Radiological Environmental Monitoring Program (Attachment 9) shall be followed, including analysis of control samples.

b. Action

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

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

6.6.3 Interlaboratory Comparison Program

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

DOMINION VPAP-2103N REVISION 28 PAGE 38 OF 87

b. Action

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

Program Cross-Check of Milk 1131 , Gamma, Sr89 and Sr90 Water Gros~ Beta, Gamma, 1131 , H3 (Tritium), Sr89 and Sr90 (blind - any combinations of above radionuclides)

Air Filter Gross Beta, Gamma, Sr90

2. If analyses are not performed as required by Step 6.63.b., report in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports, the corrective actions taken to prevent recurrence.

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

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

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

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

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

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

Results of land use census per Step 6.6.2

DOMINION VPAP-2103N REVISI0N28 PAGE 39 OF 87

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

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

2. Missing data shall be submitted in a supplementary r~port as soon as possible.

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

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

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

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

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

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

6.7.2 Annual Radioactive Effluent Release Report

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

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

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

DOMINION VPAP-2103N REVISION28 PAGE400P87

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

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

Unplanned releases that exceeded the limits in Steps 6.2.1 and 6.3.1

Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank

Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CPR 50. 72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CPR 50.73, Licensee Event Report System, report is required

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

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

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

(See Step 6.7.4).

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

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

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

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

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

DOMINION VPAP-2103N REVISION 28 PAGE41 OF87

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

b. Dose Assessment

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

Population doses shall not be included in dose assessments.

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

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

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

DOMINION VPAP-2103N REVISION 28 PAGE420F87 NOTE: The Annual Radioactive Effluent Report for the North Anna ISFSI is included as part of the North Anna Station Annual Radioactive Effluent Release Report.

C. ISFSI Dose Assessment

Radiation dose to individuals due to radioactive liquid and gaseous effluents during the previous calendar year shall either be calculated in accordance with this procedure or in accordance with Regulatory Guide 1.109. Population doses shall not be included in dose assessments.

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

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

6.7.3 Annual Meteorological Data

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

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

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

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

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

Documentation shall include:

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

DOMINION VPAP-2103N REVISION28 PAGE43 OP87

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

10 CPR 20 Subpart D

40 CPR 190

10 CPR 50.36a

10 CPR 50, Appendix I

c. Submitted to NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concu1:ent with the Annual Radioactive Effluent Release Report for the period of the report in which any change was made. Each change shall be identified 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.

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

6.7.5 Groundwater Protection Initiative [Reference 3.1.35]

a. Notifications and Reports

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

Any spill or leak meeting the requirements of Step 6.7.2.a.7.

Any groundwater sample result exceeding the reporting levels of Reporting Levels for Radioactivity c.oncentrations in Environmental Samples (Attachment 12).

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

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

DOMINION VPAP-2103N REVISION28 PAGE440F87

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

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

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

Quality Assurance Records

Records of changes to the ODCM in accordance with Step 6.7.4

Records of meteorological data in accordance with Step 6. 7 .3

Records of sampling and analyses

Records of radioactive materials and other effluents released to the environment

Records of preventive maintenance, surveillances, and calibrations 7.2 The following item(s) completed as a result of this procedure are NOT records and are NOT required to be transmitted to Nuclear Document Management (DNM).

None

DOMINION VPAP-2103N REVISION 28 PAGE45 OF87 ATTACHMENT 1 (Page 1 of 2)

Radioactive Liquid Effluent Monitoring Instrumentation I Mm1mum Uperame Instrument Action Channels

1. Liquid Radwaste Effluent (a) 1-LW-RM-111, Liquid Radwaste Effluent Monitor 1 1 (b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow Measuring 1 2 Device (c) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel 1 1 (d) l-LW-1130, Liquid Waste Effluent Proportional Sample Valve 1 1 (e) 1-SW-RM-108, Service Water Effluent Monitor (Note 1) (Note 2) 1 1 (f) l-SW-RM-130, Unit 1 Circulating Water System Effluent Line 1 3 Monitor (g) 2-SW-RM-230, Unit 2 Circulating Water System Effluent Line 1 3 Monitor

2. Steam Generator High Capacity Blowdown (a) Steam Generator High Capacity Blowdown Radiation Monitor Unit 1 1-SS-RM-125 1 1 Unit 2 2-SS-RM-225 1 1 (b) Steam Generator High Capacity Blowdown Flash Tank Outlet Flow Rate Unit 1 l-BD-FT-105 1 2 Unit 2 2-BD-FT-205 1 2 (c) Steam Generator High Capacity Blowdown Proportional Samplin~

System Collection Tank Unit 1 1-BD-TK-4 1 1 Unit 2 2-BD-TK-4 1 1

DOMINION VPAP-2103N REVISION28 PAGE46 OF 87 ATTACHMENT 1 (Page 2 of 2)

Radioactive Liquid Effluent Monitoring Instrumentation ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway may continue if, at least once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , grab samples are collected and analyzed for gross radioactivity (beta and gamma) at an LLD of at least lxlQ-7 µCi/g or an isotopic radioactivity at an LLD of at least 5x10-7 µCi/g.

ACTION 2: If the number of operable channels is less than required, effluent releases via this pathway may continue if the flow rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases. Design capacity performance curves generated in situ may be used to estimate flow.

ACTION 3: If the number of operable channels is less than required, make repairs as soon as possible. Effluent releases via this pathway may continue provided that, at le~st once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , grab samples from the discharge canal are collected and analyzed for principal gamma emitters as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3).

NOTE 1: The capability for obtaining grab samples at least every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months must exist. Grab samples

shall commence if there is indication of radioactivity in the Service Water System or an indication from other radiation monitors in the Service Water System of an incre~se in radioactivity.

NOTE 2: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, O-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

DOMINION VPAP-2103N REVISION28 PAGE :47 OF 87 ATTACHMENT 2 (Page 1 of 2)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel source channel Channel Check Check Calibration Operational Test

1. Liquid Radwaste Effluent (a) 1-LW-RM-111, Liquid Radwaste Effluent Monitor D D R Q (NOTE 1)

(b) 1-LW-FT-104, Liquid Radwaste Effluent Total Flow D (NOTE3) NIA R Q Measuring Device (c) 1-LW-TK-20, Liquid Waste Effluent Sample Vessel D (NOTE4) NIA NIA NIA (d) 1-LW-1130, Liquid Waste Effluent Proportional Sample NIA NIA D (NOTE4) NIA Valve (e) 1-SW-RM-108, SW Effluent Monitor (NOTE 9) D M R Q (NOTE 2)

(f) 1-SW-RM-130, Unit 1 Circulating Water System M R Q (NOTE 2)

D Effluent Line Monitor (g) 2-SW-RM-230, Unit 2 Circulating Water System R Q (NOTE2)

D M Effluent Line Monitor

2. Steam Generator (SG) High Capacity Blowdown (a) SG High Capacity Blowdown Radiation Monitor Unit 1 1-SS-RM-125 Q (NOTE 6)

D (NOTE 7) D (NOTE 7) R Unit 2 2-SS-RM-225 R (NOTES)

(b) SG High Capacity Blowdown Flash Tank Outlet Flow Rate Unit 1 1-BD-FT-105 D (NOTE 8) NIA R NIA Unit2 2-BD-FT-205 (c) SG High Capacity Blowdown Proportional Sampling System Collection Tank Unit 1 1-BD-TK-4 D (NOTE4) NIA NIA NIA Unit2 2-BD-TK-4

DOMINION VPAP-2103N REVISION 28 PAGE48 OF 87 ATTACHMENT 2 (Page 2 of 2)

Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

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

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

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

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

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

NOTE 3: Channel Check shall consist of checking indication of flow durii;ig periods of release.

Channel Check shall be_ made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are made.

NOTE 4: Channel Check shall consist of checking that proportional flow exceeds 0.5 mls/gallon.

NOTE 5: Channel Operational Test shall demonstrate that system isolation occurs on a radiation monitor High-High Alarm.

NOTE 6: Channel Operational Test shall demonstrate:

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

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

NOTE 7: The radiation monitor automatically performs periodic source checks. The Source Check and Channel Check are satisfied as long as the green light is lit.

NOTE 8: This is confirmed by indicated effluent flow less than or equal to 190 gpm.

NOTE 9: To utilize 1-SW-RM-108 as the effluent radiation monitor for the associated loop, O-PT-75.21, (1-SW-RM-108 Flow Verification) must be performed prior to placing the loop in service. Effluent monitoring is not required when discharge flowpath is not in service.

DOMINION VPAP-2103N REVISION 28 PAGE49 OF 87 ATTACHMENT 3 (Page 1 of 3)

Radioactive Liquid Waste Sampling and Analysis Program Lower Lnmt or Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD)

Type Frequency Frequency Analysis

(µCi/ml), (Note 1)

Principle Gamma p p 5 X 10-1 Emitters (Note 3)

(Each Batch) (Each Batch) 1131 1 X 10-6 p UISsolvect anct 1 X 10-.:,

Batch Releases M Entrained Gases (One Batch/M) (Note 8)

(Gamma Emitters)

(Notes 2 and 7) p M Composite H3 1 X 10-5 (Each Batch) (Note 4) Gross Alpha 1 X 10-7 p Q Composite Sr89 and Sr90 5 X 10-8 (Each Batch) (Note 4) Fe55 1X io-6 Principal Gamma 5 X 10-7 Emitters (Note 6)

Continuous W Composite 1131 1 X 10-6 (Note 6) (Note 6)

U1Sso1vect and 1 X 10-.5 Continuous Entrained Gases Releases M Grab Sample (Note 8)

(Gamma Emitters)

(Note 5) Continuous M Composite H3 1 X 10-5 (Note 6) (Note 6) Gross Alpha 1 X 10-7 Continuous Q Composite Sr89 and Sr90 5 X 10-8 (Note 6) (Note 6) Fe55 1 X 10-6

DOMINION VPAP-2103N REVISION28 PAGE500F87 ATTACHMENT 3 (Page 2 of 3)

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

LLD (9-1)

E

V

2.22E+06

Y

e-(11,~t)

Where:

LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.8)

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

E = the counting efficiency (as counts per disintegration)

V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute ( dpm) per microcurie Y = the fractional radiochemical yield (when applicable) 11, = the radioactive decay constant for the particular radionuclide

~t = the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and ~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.

NOTE 2: A batch release is the discharge of liquiq wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and then thoroughly mixed as the situation permits, to assure representative sampling.

DOMINION VPAP-2103N REVISION28 PAGE51 OF 87 ATTACHMENT 3 (Page 3 of 3)

Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the 137 1 1 following radionuclides: Mn 54, Fe59 , Co58 , Co60 , Zn65 , Mo99 , Cs 134, Cs , Ce : , and Ce 144

This list does not mean that only these nuclides are to be *detected and reported.

Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released.

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

NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously in proportion to the rate of flow of the effluent stream. Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent rele~ses.

NOTE 7: Whenever the secondary coolant activity exceeds 10-5 µCi/ml, the turbine building sump pumps shall be placed in manual operation and samples shall be taken and analyzed prior to release. Secondary coolant activity samples shall be collected and analyzed on a weekly basis. These samples are analyzed for gross activity or gamma isotopic activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

NOTE 8: The gamma emitters for which the LLD specification applies ex':lusively are the ~ollowing radionuclides: Kr-87, Kr-88, Xe-133, Xe-I33m, Xe-135, Xe-135m and Xe-138. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides shall also be identified and reported.

DOMINION VPAP-2103N REVISION 28 PAGE 52 OF 87 ATTACHMENT 4 (Page 1 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program Lower Lnmt or Gaseous Release Sampling Minimum Analysis Type of Activity Detection (LLD)

Type Frequency Frequency Analysis

(µCi/ml), (Note 1)

Prmc1pa1 uamma 1 X 10-4 Prior to Release A. Waste Gas Prior to Release Emitters (Note 2)

(Each Tank Storage Tank (Each Tank) H3 Grab Sample) 1 X 10-6 Prmc1ple vamma 1 X 10-4 B. Containment Prior to Release Prior to Release Emitters (Note 2)

(Each PURGE H3 1 X 10-6 Purge (Each PURGE)

Grab Sample)

C. Ventilation Monthly Principle Gamma Monthly 1 X 10-4 (Grab Sample) Emitters (Note 2)

(1) Process Vent '

(2) Vent Vent A H3 1 X 10-6 (Notes 3 and 5) (Note 3)

(3) VentVentB 1131 1 X 10-lZ Continuous Weekly (Note 4 and 5) (Charcoal Sample) Iuj 1 X 10-iU Contmuous weeKly .Pnnc1pa1 uamma 1 X 10-ll All Release (Note 4 and 5) Particulate Sample Emitter (Note 2)

Monm1y Continuous 1 X 1()-ll Types as listed Composite Gross A,lpha (Note 4 and 5)

Particulate Sample l..,luarterly Continuous in A, B, and C Composite Sr89 and Sr90 1 X 10-ll (Note 4 and 5)

Particulate contmuous Noble vases uross Noble Gas Monitor 1 X 10-6 (Note 4 and 5) Beta or Gamma Condenser Air Prmc1ple liarpma 1X ro-4 '

Weekly Weekly Ejector/Steam Emitters (Note 7)

Generator Grab Sample Blowdown Vent/ H3 1 X 10-6 (Note 6)

BRT Vent Containment Prmc1p1e uamma 1 X 10-4 Prior to Release Prior to each Vacuum Steam Emitters (Note 2)

(Grab Sample) H3 1 X 10- 6 Ejector (Hogger) Release (Note 8) '

DOMINION VPAP-2103N REVISION28 PAGE53 OF 87 ATTACHMENT 4 (Page 2 of 4)

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

LLD (11-1)

E

V

2.22E+06

Y

e-(Adt)

Where:

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

Sb = the standard deviation of the background counting rate or of the counting 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 M = the elapsed time between the midpoint of sample collection and time of counting Typical values of E, V, Y and dt should be used in the calculation.

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

NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87 , Kr88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, and Xe 138 for gaseous emissions and Mn54, Fe59 , Co58 , Co 60 , Zn65 , Mo99 , 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 peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

, DOMINION VPAP-2103N REVISI0N28 PAGE 54 OF 87 ATTACHMENT 4 (Page 3 of 4)

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

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant is greater than 1.0 µCi/gm; and

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

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4.

NOTE 5: Samples shall be changed at least once per seven days and analy_ses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the correspon~ing LLDs may be increased by a factor of 10. This requirement applies if:

a. Analysis shows that the dose equivalent 1131 concentration i~ the primary coolant is greater than 1.0 µCi/gm and;

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

NOTE 6: Whenever the secondary coolant activity exceeds 10-5 µCi/ml, Condenser Air Ejector and Steam Generator Blowdown Vent samples shall be obtained and analyzed weekly.

Secondary coolant activity samples shall be collected and analyzed on a weekly basis.

These samples are analyzed for gross activity or gamma isotopic activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

NOTE 7: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87 , Kr88 , Xe 133, Xe 133 m, Xe 135 , Xe 135 m, and Xe 138 for gaseous emissions. This list does not mean that only these nuclides are to be detected and reported.

Other peaks that are measurable and identifiable, at levels exceeding the LLD together with the above nuclides, shall also be identified and reported.

DOMINION VPAP-2103N REVISION28 PAGE 55 OF 87 ATTACHMENT 4 (Page 4 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 8: If the secondary coolant activity level in any Steam Generator supplying steam to the Hogger exceeds 1.0E-5 µCi/ml, Steam Generator samples shall be obtained and analyzed prior to release.

DOMINION VPAP-2103N REVISION28 PAGE 56 OF 87 ATTACHMENTS (Page 1 of 3)

Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) xtQ = 9.3E-06 sec/m3 at 1416 meters SE Direction Dose Factors for Ventilation Vent K.ivv Livv Nlivv Nivv Noble Gas Total Body Skin Gamma Air Beta Air Radionuclide mrem/yr mrern/yr mrad/yr mrad/yr Curie/sec Curie/sec Curie/sec Curie/sec Kr-85m 1.09E+04 1.36E+04 1.14E+04 1.83E+04 Kr-85 1.50E+02 l.25E+04 1.60E+02 1.81E+04 Kr-87 5.51E+04 9.05E+04 5.74E+04 9.58E+04 Kr-88 1.37E+05 2.20E+04 1.41E+05 2.72E+04 Kr-89 1.54E+05 9.39E+04 1.61E+05 9.86E+04 Xe-131m 8.51E+02 4.43E+03 1.45E+03 l.03E+04 Xe-133m 2.33E+03 9.24E+03 3.04E+03 1.38E+04 Xe-133 2.73E+03 2.85E+03 3.28E+03 9.77E+03 Xe-135m 2.90E+04 6.61E+03 3.12E+04 6.87E+03 Xe-135 1.68E+04 1.73E+04 1.79E+04 2.29E+04 Xe-137 1.32E+04 1.13E+05 1.40E+04 l.18E+05 Xe-138 8.21E+04 3.84E+04 8.57E+04 4..42E+04 Ar-41 8.22E+04 2.50E+04 8.65E+04 3.05E+04

DOMINION VPAP-2103N REVISION 28 PAGE 57 OF 87 ATTACHMENT 5 (Page 2 of 3)

Gaseous Effluent Dose Factors (Gamma and Beta Dose Factors) xtQ = 1.2E-06 sec/m3 at .1513 meters S Direction Dose Factors for Process Vent K.ipv Lipv Mipv l\lipv Noble Gas Total Body Skin Gamma Air Beta Air Radionuclide mrem/yr mrem/yr mrad/yr* mrad/yr Curie/sec Curie/sec Curie/sec Curie/sec Kr-85m 1.40E+03 1.75E+03 1.48E+03 2.36E+03 Kr-85 1.93E+01 1.61E+03 2.06E+01 2.34E+03 Kr-87 7.10E+03 l.17E+04 7.40E+03 l.24E+04 Kr-88 1.76E+04 2.84E+03 1.82E+04 3.52E+03 Kr-89 1.99E+04 1.21E+04 2.08E+04 l.27E+04 Xe-131m 1.10E+02 5.71E+02 1.87E+02 1.33E+03 Xe-133m 3.01E+02 l.19E+03 3.92E+02 1.78E+03 Xe-133 3.53E+02 3.67E+02 4.24E+02 l.26E+03 Xe-135m 3.74E+03 8.53E+02 4.03E+03 8.87E+02 Xe-135 2.17E+03 2.23E+03 2.30E+03 2.95E+03 Xe-137 1.70E+03 1.46E+04 l.81E+03 l.52E+04 Xe-138 1.06E+04 4.96E+03 1.11E+04 5.70E+03 Ar-41 1.06E+04 3.23E+03 1.12E+04 3.94E+03

DOMINION VPAP-2103N REVISION 28 PAGE58 OF87 ATTACHMENT 5 (Page 3 of 3)

Gaseous Effluent Dose Factors (Inhalation Pathway Dose Factors)

Ventilation Vent x!Q = 9.3E-06 sec/m3 at 1416 meters SE Direction Process Vent x!Q = 1.2E-06 sec/m3 at 1513 meters S Di~ection r'ivv Pipv Radionuclide mrem/yr mrem/yr Curie/sec Curie/sec H-3 l.05E+04 l.35E+03 Cr-51 7.95E+02 1.02E+02 Mn-54 ND ND Fe-59 ND ND Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-90 ND ND Y-91 ND ND Zr-95 ND ND Nb-95 ND ND Ru-103 ND ND Ru-106 ND ND Ag-llOm ND ND Te-127m 5.64E+04 7.28E+03 Te-129m 5.88E+04 7.59E+03 .

Cs-134 ND ND Cs-136 ND ND Cs-137 ND ND Ba-140 ND ND Ce-141 ND ND Ce-144 ND ND 1-131 1.51E+08 l.95E+07 1-133 3.58E+07 4.62E+06 ND - No data for dose factor according to Regulatory Guide 1.109, Revision 1

DOMINION VPAP-2103N REVISION 28 PAGE 59 OF 87 ATTACHMENT 6 (Page 1 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE ACTION CHANNELS

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor l

1 1-GW-RM-178-1 2,4 (NOTE 3)

(b) Iodine Sampler 1-GW-RM-178-1 1 2,5 Process Vent Continuous HP Sampler (NOTE 3)

(c) Particulate Sampler 1-GW-RM-178-1 1 2,5 Process Vent Continuous HP Sampler (NOTE 3)

(d) Total Flow Monitor l-GW-FT-108 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 1

HP Sampler Rotameter (NOTE 3)

2. CONDENSER AIR EJECTOR SYSTEM (a) Gross Activity Monitor Unit 1 1-SV-RM-121 1 3 Unit 2 2-SV-RM-221 (b) Flow Rate Measuring Device Unit 1 1-SV-FI-lOOA 1-SV-FI-lOlA 1 (NOTE 1) 1 1-SV-FI-lOOB 1-SV-FI-lOlB Unit 2 2-SV-FI-200A 2-SV-FI-201A 1 (NOTE 2) 1 2-SV-FI-200B 2-SV-FI-201B

DOMINION VPAP-2103N REVISION 28 PAGE 60 OF 87 ATTACHMENT 6 (Page 2 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation INSTRUMENT MINIMUM OPERABLE ACTION CHANNELS

3. VENTILATION VENT A (a) Noble Gas Activity Monitor 1

1-VG-RM-179-1 2 (NOTE 3)

(b) Iodine Sampler 1-VG-RM-179-1 1 2

Vent Vent A Continuous HP Sampler (NOTE 3)

(c) Particulate Sampler 1-VG-RM-179-1 1 2

Vent Vent A Continuous HP Sampler (NOTE 3)

(d) Total Flow Monitor l-HV-FT-1212A 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 1

HP Sampler Rotameter (NOTE3)

4. VENTILATION VENT B (a) Noble Gas Activity Monitor 1

1-VG-RM-180-1 2 (NOTE 3)

(b) Iodine Sampler 1-VG-RM-180-1 1 2

Vent Vent B Continuous HP Sampler (NOTE 3)

(c) Particulate Sampler 1-VG-RM-180-1 1 2

Vent Vent B Continuous HP Sampler (NOTE 3)

(d) Total Flow Monitor 1-HV-FT-1212B 1 1 (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring Device 1 1 HP Sampler Rotameter (NOTE 3)

DOMINION VPA'.P-2103N REVISION 28 PAGE 61 OF87 ATTACHMENT 6 (Page 3 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation ACTION 1: If the number of operable channels is less than required, effluent releases, via this path, may continue if the flow rate is estimated at least once per four hours.

ACTION 2: If the number of operable channels is less than required, effluent releases, via this path, may continue if grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity or gamma isotopic activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 3: If the number of operable channels is less than required, effluent releases via this path may continue if grab samples are taken at least once per twelve (12) hours and these samples are analyzed for gross activity or gamma isotopic activity within eight(8) hours. This requirement is for effluent accountability and is distinct and separate from any requirement for primary-to-secondary leak rate determination. The need to determine the primary-to-secondary leak rate, e.g., the performance of 1/2-PT-46.3B, s*hall be determined in accordance with the requirements ofTRM TR 3.4.5. However, the same sample may be used to fulfill both the requirements of this action and primary-to-secondary leak rate determination.

ACTION 4: If the number of operable channels is less than required, the contents of the Waste Gas Decay Tanks may be released to the environment provided that prior to initiation of the release:

a. At least two independent samples of the tank's contents are a~alyzed, and:

b. At least two technically qualified members of the Station staff independently check the release rate calculations and discharge valve lineup.

ACTION 5: If the number of operable channels is less than required, effluent releases from the Waste Gas Decay Tank may continue provided samples are continuously collected with auxiliary sampling equipment as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4 ).

NOTE 1: A channel shall consist of:

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

b. Flow instruments 101A and 101B provide low range measurement. Flow instruments lOOA and 1OOB provide high range measurement.

NOTE 2: A channel shall consist of:

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

b. Flow instruments 201A and 201B provide low range measurement. Flow instruments 200A and 200B provide high range measurement..

NOTE 3: A channel shall consist of a MGPI monitor; and a MGPI or HP particulate and iodine sampler, and its associated sampler flow rate measuring device or rotameter.

DOMINION VPAP-2103N REVISI0N28 PAGE620F87 ATTACHMENT 7 (Page 1 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL SOURCE CHANNEL Channel CHANNEL DESCRIPTION CHECK CHECK CALIBRATION Operational Test

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor 1-GW-RM-178-1 D M (NOTES) R Q (NOTE 1)

(b) Iodine Sampler 1-GW-RM-178-1 w NIA NIA NIA Process Vent Continuous HP Sampler D (NOTE 3) NIA NIA NIA (c) Particulate Sampler l-GW-RM-178-1 w NIA NIA NIA Process Vent Continuous HP Sampler D (NOTE 3) NIA NIA NIA (d) Total Flow Monitor 1-GW-FT-108 D NIA R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE 3) NIA *R NIA Device HP Sampler Rotameter D (NOTE 3) NIA Every 18 months NIA

2. CONDENSER AIR EJECTOR SYSTEM (a) Noble Gas Activity Monitor Unit 1 1-SV-RM-121 D M R Q, R(NOTE6)

Unit 2 2-SV-RM-221 (b) Flow Rate Measuring Device Unit 1 1-SV-FI-lOOA 1-SV-FI-lOlA NIA D NIA R 1-SV-FI-lOOB 1-SV-FI-lOlB Unit 2 2-SV-FI-200A 2-SV-FI-201A NIA D NIA R 2-SV-FI-200B 2-SV-Fl-201B

DOMINION VPAP-2103N REV1SION 28 PAGE 63 OF 87 ATTACHMENT 7.

(Page 2 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL SOURCE CHANNEL Channel CHANNEL DESCRIPTION CHECK CHECK CALIBRATION Operational Test

3. VENTILATION VENT A (a) Noble Gas Activity Monitor 1-VG-RM-179-1 D M (NOTES) R Q (NOTE 2)

(b) Iodine Sampler 1-VG-RM-179-1 w NIA NIA NIA Vent Vent A Continuous HP Sampler D (NOTE3) NIA NIA NIA (c) Particulate Sampler 1-VG-RM-179-1 NIA NIA NIA Vent Vent A Continuous HP w*

D (NOTE3)

Sampler NIA NIA NIA (d) Total Flow Monitor l-HV-FT-1212A D NIA R Q (e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE 3) NIA R NIA Device HP Sampler Rotameter D (NOTE 3) NIA Every 18 months NIA

4. VENTILATION VENT B (a) Noble Gas Activity Monitor l-VG-RM-180-1 D M(NOTES) R Q (NOTE2)

(b) Iodine Sampler 1-VG-RM-180-1 w NIA NIA :NIA Vent Vent B Continuous HP Sampler D (NOTE3) NIA NIA NIA (c) Particulate Sampler 1-VG-RM-180-1 w NIA NIA NIA Vent Vent B Continuous HP Sampler D (NOTE3) NIA NIA NIA (d) Total Flow Monitor 1-HV-FT-1212B D NIA R Q

(e) Sampler Flow Rate Measuring Device MGPI Flow Rate Measuring D (NOTE3) NIA R NIA Device HP Sampler Rotameter D (NOTE3) NIA R NIA

DOMINION VPAP-2103N REVISION28 PAGE640F87 ATTACHMENT 7 (Page 3 of 3)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements NOTE 1: The Channel Operational Test shall demonstrate:

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

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

NOTE 2: The Channel Operational Test shall demonstrate:

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

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

NOTE 3: Channel Checks shall consist of checking indication of flow during periods of release.

Channel Checks shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are made. Verification need only to be done to check operability of one train, either MGPI or HP Sampler.

NOTE 4: The Channel Operational Test shall demonstrate that:

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

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

NOTE 5: Monitors 1-GW-RM-178-1, l-VG-RM-179-1, and 1-VG-RM-180-1 perform periodic source checks automatically.

NOTE 6: The quarterly, Q, Channel Operational Test shall demonstrate that Control Room Alarm annuciation occurs if the instrument indicates measured levels above the alarm/trip setpoint and alarm annunciation occurs if the instrument controls are not set in the "operate" mode.

The refueling, R, Channel Operational Test shall demonstrate:

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

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

DOMINION VPAP-2103N REVXSI0N28 PAGE 65 OF87 ATTACHMENT 8 (Page 1 of 2)

Critical Organ Dose Factors (Critical Pathway Dose Factors)

Ventilation Vent X/Q = 3.3E-6 at 1593 meters SSE Direction Process Vent X/Q = 9.5E-7 at 1593 meters SSE Direction Ventilation Vent D/Q = l.7E-8'at 1593 meters SSE Direction Process Vent D/Q = l. lE-8 at 1593 meters SSE Direction KMivv KMipv Radionuclide mrem/yr mrem/yr Curie/sec Curie/sec H-3 l.32E+4 3.81E+3 Mn-54 ND ND Fe-59 ND ND Cr-51 l.11E+3 7.16E+2 Co-58 ND ND Co-60 ND ND Zn-65 ND ND Rb-86 ND ND Sr-89 ND ND Sr-90 ND ND.

Y-91 ND ND Zr-95 ND ND Nb-95 ND ND Ru-103 ND ND Ru-106 ND ND Ag-llOm ND ND Te-127m 5.37E+6 3.48E+6 Te-129m 4.61E+6 2.98E+6 1-131 8.08E+8 5.23E+8 1-133 l.38E+7 ' 8.93E+6 Cs-134 ND ND Cs-136 ND ND Cs-137 ND ND Ba-140 ND ND Ce-141 ND ND

DOMINION VPAP-2103N REVIS10N28 PAGE660F87 ATTACHMENT 8 (Page 2 of 2)

Critical Organ Dose Factors ivv K!Vlipv Radionuclide mrem/yr mrem/yr Curie/sec Curie/sec Ce-144 ND ND ND - No data for dose factor according to Regulatory Guide 1.109, Revision 1

DOMINION VPAP-2103N REVISION 28 PAGE67 OF 87 ATTACHMENT 9 (Page 1 of 5)

Radiological Environmental Monitoring Program RADIATION (NOTE 3) 36 routine monitoring stations, either with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, to .

be placed as follows:.

1) An inner ring of stations, one in each environmental GAMMA DOSE meteorological sector within the site boundary

2) An outer ring of stations, one in each environmental Quarterly Quarterly

.meteorological sector within 8 km range from the site

3) The balance of the stations to be placed in special interest areas such as population centers, nearby residences, schools, and in 1 or 2 areas to serve as control stations ese are not part o t e env1ronmenta

DOMINION VPAP-2103N REVISION28 PAGE 68 OF87 ATTACHMENT 9 (Page 2 of 5)

Radiological Environmental Monitoring Program Exposure l'amway Number ot ~ample anct Collection *1 ype ancl i requency ot and/or Sample Sample Location (NOTE 2) Frequency Analysis L. Alt< KUt<l'~b Samples from 5 locations:

a) 3 samples from close to the 3 site boundary locations (in different Radioiodine Canister sectors) of the highest I 131 Analysis, weekly calculated historical annual average ground Continuous Radioiodines and level D/Q sampler, Particulates b) 1 sample from the operation with vicinity of a community sample collection Particulate Sampler having the highest weekly Gross beta radioactivity calculated annual analysis following filter average ground level change; (NOTE 4)

D/Q c) 1 sample fr~m a control Gamma isotopic analy-location 15-40 km sis of composite (by distant and in the least location) quartei;ly prevalent wind direction {NOTE 5) j, WAl t-<.t< 1-1.ut<.Nb Samples from 3 locations:*

Gamma isotopic analysis a) 1 sample upstream monthly; (NOTE 5) a) Surface b) 1 sample downstream Grab Monthly Composite for tritium -

c) 1 sample from cooling analysis quarterly lagoon '

uamma 1sotop1c anct tntmm Sample from 1 or 2 sources b) Ground Grab Quarterly analysis quarterly (NOTE only if likely to be affected 5) 1 sample from downstream Gamma isotopic analysis c) Sediment ard with existing or Semi-Annually semi-annually (NOTE 5) potential recreational value

DOMINION VPAP-2103N REVISION 28 PAGE 69 OF87 ATTACHMENT 9 (Page 3 of 5)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location (NOTE 2) Frequency Analysis'

4. lNUb::SllUN a) Samples from milking animals in 3 locations within 5 km that have the highest potential. If there are none, then 1 sample from milking animals in each of 3 areas a) Milk between 5 to 8 km where Monthly at all Gamma isotopic (N9TE 5)

(NOTE 7) doses are calculated to be times and I 131 analysis monthly greater than 1 rnrem per yr (NOTE 6) b) 1 sample from milking animals at a control location (15-30 km in the least prevalent wind direction) a) 1 sample of commercially and recreationally important species (bass, sunfish, catfish) b) Fish and in vicinity of plant discharge Gamma isotopic on edible Semiannually Invertebrates area portions b) 1 sample of same species in areas not influenced by plant discharge a) Samples of an edible broad leaf vegetation grown nearest each of two different offsite locations of highest predicted historical annual average Monthly if ground level D/Q if milk Gamma isotopic (NOTE 5) c) Food Products available, or sampling is not performed and I 131 analysis at harvest b) 1 sample of broad leaf vegetation grown 15-30 km in '

the least prevalent wind direction if milk sampling is not performed

DOMINION VPAP-2103N REVISI0N28 PAGE 70 OF 87 ATTACHMENT 9 (Page 4 of 5)

Radiological Environmental Monitoring Program NOTE 1: The number, media, frequency, and location of samples may vary from site to site. This table presents an acceptable minimum program for a site at which each entry is applicable.

Local site characteristics must be examined to determine if pathways not covered by this table may significantly contribute to an individual's dose and be included in the sampling program.

NOTE 2: For each and every sample location in Environmental Sampling Locations (Attachment 10),

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

DOMINION VPAP-2103N REVISION 28 PAGE 71 OF 87 ATTACHMENT 9 (Page 5 of 5)

Radiological Environmental Monitoring Program NOTE 3: One or more instruments, such as a pressurized ion chamber, for measuring and recording

. dose rate continuously may be used in place of, or in addition to, integrating dosimeters.

For the purposes of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters.

Film badges shall not be used as dosimeters for measuring direct radiation. The 36 stations are not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations, e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading.

NOTE 4: Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than ten times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples.

NOTE 5: Gamma isotopic analysis is the identification and quantification of gamma-emitting radionuclides that may be attributable to effluents from the facility.

NOTE 6: The dose shall be calculated for the maximum organ and age group, using the methodology and parameters in the ODCM.

NOTE 7: If milk sampling cannot be performed, use item 4.c (Page 3 of 5, Radiological Environmental Monitoring Program (Attachment 9)).

NOTE: Additionally, the following TLDs a~e placed in the indicated locations for Emergency Plan requirements. This is due to the fact that Emergency Plan and Environmental Plan grid centers are in different locations. These TLDs are collected quarterly in conjunction with Environmental Sector TLDs.

EP Sector TLD Designator Location A EPSAl/2 On fence, U-2 side, Intake Structure F EPSF 3/4 On power pole on island (across from FPPH)

R EPSR 5/6 On door of.Substation "M" p EPSP 9/10 On/near Switchyard gate J EPSJ 7/8 NW corner of the Generator Rewind Bldg.

DOMINION VPAP-2103N REVISION 28 PAGE 72 OF 87 ATTACHMENT 10 (Page 1 of 5)

Environmental Sampling Locations Distance and Direction From Unit No. 1 Sample ~ration/ U1stance Direction Collect1on Remarks Location (Miles) Frequency Media No.

Environmental NAPS Waste Treatment Quarterly&

01 0.20 NE On-Site TLDs Plant, end of parking lot B Annually Quarterly&

SSW Annually Frederick's Hall 02 5.30 Mineral,VA 03 7.10 WSW Quarterly&

Annually Quarterly&

WNW Annually Wares Crossroads 04 5.10 NNE Quarterly&

Route 752 05 4.20 Annually Quarterly&

Sturgeon's Creek Marina 05A 2.04 N Annually 4.70 ESE Quarterly & '

Levy, VA 06 Annually Quarterly&

Bumpass, VA 07 7.30 SSE Annually Quarterly&

End of Route 685 21 1.00 WNW Annually Site Boundary Route 700 22 1.00 WSW Quarterly&

Annually Site Boundary SSE Quarterly& Site Boundary 23 0.93 "Aspen Hills" Annually .

Quarterly&

Orange, VA 24 ~2.00 NW Annually Control Bearing Cooling Tower N-1/33* 0.06 N Quarterly On-Site Sturgeon's Creek Marina N-2/34 2.04 N Quarterly Parking Lot "C" NNE-3/35 0.24 NNE Quarterly On-Site Good Hope Church NNE-4/36 3.77 NNE Quarterly NAPS Waste Treatment NE-5/37 0.20 NE Quarterly On-Site Plant, end of parking lot B '

Bogg's Drive NE-6/38 1.46 NE Quarterly Weather Tower Fence ENE-7/39 0.36 ENE Quarterly On-Site Route 689 ENE-8/40 2.43 ENE Quarterly Near Training Facility E-9/41 0.30 E Quarterly On-Site "Mornmg Glory Hill b-10/42 2.~.) b I(..!uarterly Island U1ke b~b-ll/4j U.12 b~b (..!uarterly Un-~lte Koute b'L'L lb:Sb-l'L/44 4./U b:Sb lf...luarterly

DOMINION VPAP-2103N REVISION 28 PAGE 73 OF 87 ATTACHMENT 10 (Page 2 of 5)

Environmental Sampling Locations Distance and Direction From Unit No. 1 Sample Station Distance Collectmn Location Remarks Media No. (Miles) Direction Frequency Environmental Biology Lab SE-13/45 0.64 SE Quarterly On-Site TLDs Route 701 SE-14/46 5.88* SE Quarterly (Dam Entrance)

.:Site "Aspen Hills" SSE-15/47 0.93 SSE Quarterly Boundary Elk Creek SSE-16/48 2.33 SSE Quarterly NAPS Access Road S-17/49 0.36 s Quarterly On-Site Elk Creek Church S-18/50 1.55 s Quarterly NAPS Access Road SSW-19/51 0.24 SSW Quarterly On-Site Route 618 SSW-20/52 5.30* SSW Quarterly 500KV Tower SW-21/53 0.60 SW Quarterly On-Site Route 700 SW-22/54 3.96 SW Quarterly At NAPS, on pole, SE of switchyard, entrance on WSW-23/55 0.38 WSW Quarterly Ort-Site Rt. 700

site Route 700 WSW-24/56 1.00 WSW Quarterly Boundary South Gate of W-25/57 0.32 w Quarterly On-Site Switchyard Route 685 W-26/58 1.55 w Quarterly I:Site End of Route 685 WNW-27/59 1.00 WNW Quarterly Boµndary Route 685 WNW-28/60 1.40 WNW Quarterly Laydown Area North NW-29/61 0.52 NW Quarterly On-Site Gate Lake Anna Campgrounc NW-30/62 2.54 NW Quarterly

1/#2 Intake NNW-31/63 0.07 NNW Quarterly On-Site Route 208 NNW-32/64 2.21 NNW Quarterly Bumpass Post Office C-1/2 7.30 SSE Quarterly .

Orange, VA C-3/4 22.00 NW Quarterly Control Mineral, VA C-5/6- 7.10* WSW Quarterly Louisa, VA C-7/8 11.54 WSW Quarterly Control

These locations have been evaluated and are acceptable. (Reference 3.1.37)

DOMINION VPAP-2103N REVISION28 PAGE 74 OF 87 ATTACHMENT 10 (Page 3 of 5)

Environmental Sampling Locations Distance and Direction From Unit No. 1 Sample Station* u1stance t:ouection Remarks Location Direction Media No. (Miles) Frequency Airborne NAPS Waste Treatment 01 0.20 NE Weekly On-Site Plant, end of parking lot B Particulate Biology Lab 01-A 0.64 SE Weekly On-Site and Frederick's Hall 02 5.30 SSW Weekly Radioiodine Mineral, VA 03 7.10 WSW Weekly Wares Crossroads 04 5.10 WNW Weekly Route 752 05 4.20 NNE Weekly Sturgeon's Creek Marina 05A 2.04 N Weekly Levy, VA 06 4.70 ESE Weekly Bumpass, VA 07 7.30 SSE Weekly End of Route 685 21 1.00 WNW Weekly Site Boundary Route 700 22 1.00 WSW _Weekly Site Boundary "Aspen Hills" 23 0.93 SSE Weekly Site Boundary Orange, VA 24 22.00 NW Weekly Control

~urrace water Waste Heat Treatment

[Reference Facility (Second Cooling 08 3.37 SSE Monthly 3.1.31] Lagoon)

North Anna River (upstream) Rt 669 Bridge 09A 12.9 WNW Monthly Control (Brook's Bridge)

North Anna River 11 5.80 SE Monthly (downstream) vrounawater OlA 0.64 SE Quarterly (well water) Biology Lab Aquatic Waste Heat Treatment Semi-Facility (Second Cooling 08 3.37 SSE Sediment Annually Lagoon)

North Anna River Semi-(upstream) Rt 669 Bridge 09A 12.9 WNW Control Annually (Brook's Bridge)

North Anna River Senn-11 5.80 SE (downstream) Annually Shoreline Soil Lake Anna 08 3.37 SSE Semi-Annually Soil NAPS Waste Treatment 01 0.20 NE Once per 3 yrs On-:Site Plant, end of parking lot B

DOMINION VPAP-2103N REVISION28 PAGE 75 OF87 ATTACHMENT 10 (Page 4 of 5)

Environmental Sampling Locations Distance and Direction From Unit No. 1 Sample Location .,muon u1stance u1rect10n co11ect1on KemarKs Media No. (Miles) Frequency Soil Fredericks Hall UL :uu SSW Unce per j yrs (continued) Mineral, VA 03 7.10 WSW Once per 3 yrs Wares Crossroads 04 5.10 WNW Once per 3 yrs Route 752 05 4.20 NNE Once per 3 yrs Sturgeon's Creek 05A 2.04 N Once per 3 yrs Marina Levy, VA 06 4.70 ESE Once per 3 yrs Bumpass, VA 07 7.30 SSE Once .per 3 yrs End of Route 685 21 1.00 WNW Once per 3 yrs Site Boundary Route 700 22 1.00 WSW Once per 3 yrs Site Boundary "Aspen Hills" 23 0.93 SSE Once per 3 yrs Site Boundary Orange, VA 24 ,

22.00 NW Once per 3 yrs Control Milkb TBD TBD Monthly Waste Heat Treatment Fish Facility (Second 08 3.37 SSE Semi-Annually Cooling Lagoon)

Lake Orange 25 16.50 NW Semi-Annually Control Food Products Stagecoach Road 14B varies NNE Monthly (Edible if available, broadleaf Route 614 15 varies SE or at harvest vegetationa)

Route 629/522 16 varies NW Control Historic Ln 26 varies s "Aspen Hills" Area 23 varies SSE

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

b. Milk producing animals are no longer within NAPS monitoring locations following the Harris Dairy closure 01/01/2018. Annual Land use census data will be used to determine future availability of milk samples.

DOMINION VPAP-2103N REVISION 28 PAGE 76 OF87 ATTACHMENT 10 (Page 5 of 5)

Environmental Sampling Locations NOTE: Additionally, the following TLDs are placed in the indicated locations for Emergency Plan requirements. This is due to the fact that Emergency Plan and Environmental Plan grid centers are in different locations. These TLDs are collected quarterly in conjunction with Environmental Sector TLDs.

EP Sector TLD Designator Location A EPSAl/2 On fence, U-2 side, Intake Structure F EPSF 3/4 On power pole on island (across from FPPH)

R EPSR 5/6 On door of Substation "M" p EPSP 9/10 On/near Switchyard gate J EPSJ 7/8 NW corner of the Generator Rewind Bldg.

NOTE: ISFSI well water samples are obtained as a Conditional Use Permit issued by the County of Louisa.

DOMINION VPAP-2103N REVISION 28 PAGE 77 OF87 ATTACHMENT 11 (Page 1 of 2)

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

Airborne Food Fish Sediment Analysis Water Particulate

Milk Products (pCi/kg) (pCi/kg)

(NOTE 2) (pCi/1) or Gases (pCi/1) . (pCi/kg)

(wet) (dry)

(pCifm3) (wet)

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

Zn-65 30 260 Zr-95 30 Nb-95 15 I-131 (NOTE3) 1 0.07 1 60 (NOTE 4)

Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 (NOTE4)

La-140 15 15 (NOTE4)

NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

NOTE 3: LLD for the drinking water samples. Drinking water includes samples from Lake Anna and well samples analyzed as part of the REMP. The LLD for the non-drinking water samples is 10 pCi/1.

NOTE 4: No LLD for precipitation water due to short-half lives of these nuclides.

DOMINION VPAP-2103N REVISION 28 PAGE 78 OF87 ATTACHMENT 11 (Page 2 of 2)

Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) (NOTE 3)

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

LLD (25-1)

E

V

2.22E+06

Y

e-(Adt)

Where:

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

Sb= the standard deviation of the background counting rate or of the counting 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 dt = the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples)

Typical values of E, V, Y and dt 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-2103N REVISION 28 PAGE 79 OF87 ATTACHMENT 12 (Page 1 of 1)

Reporting Levels for Radioactivity Concentrations in Environmental Samples Airborne Water Fish Milk Food Products Analysis Particulate or (pCi/1) (pCi/kg, wet) (pCi/1) (pCi/kg, wet)

Gases (pCifm3)

(NOTE 1)

H-3 20,000 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 1-131 2 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 NOTE 1: For drinking water samples

DOMINION VPAP-2103N REVISION28 PAGE 80 OF 87 ATTACHMENT 13 (Page 1 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEOROLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the annual average XIQ and D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (mixed mode) releases. The annual average XIQ and D/Q values were used to perform a dose pathway analysis to determine both the maximum exposed individual at site boundary and member of the public. The XIQ and D/Q values resulting in the maximum exposures. were incorporated into the dose factors in Gaseous Effluent Dose Factors (Attachment 5) and Critical Organ Dose Factors (Attachment 8).

1.2 Meteorological Data, Parameters, and Methodology Onsite meteorological data for the period January 1, 1981, through December 31, 1981, were used in calculations. These data included wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributJons for those releases characterized as ground level (e.g., ventilation vent), and those characterized as mixed mode (i.e., process vent). The portions of release characterized as ground level were based on

~T1s8.9ft-28.2ft and 28.2 foot wind data, and the portions characterized as mixed mode were based on ~T1s8.9ft-28.2ft and 158.9 ft wind data.

X/Q's and D/Q's were calculated using the NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations,"

September, 1977. The code is based upon a straight line airflow model implementing the assumptions outlined in Section C (excluding Cla and Clb) of Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors."

The open terrain adjustment factors were applied to the X/Q values as recommended in Regulatory Guide 1.111. The site region is characterized by gently r-olling terrain so :open terrain correction factors were considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area.

DOMINION VPAP-2103N REVISION 28 PAGE 81 OF 87 ATTACHMENT 13 (Page 2 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The effective release height used in mixed mode release calculations was based on a process vent release height of 157 .5 ft, and plume rise due to momentum for a vent diameter of 3 in.

with plume exit velocity of 100 ft/sec. Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from North Anna Power Station Units 1 and 2, Virginia Electric and Power Company Final Safety Analysis Report Table 1 lC.2-8.

X/Q and D/Q values were calculated for the nearest site boundary, resident, milk cow, and vegetable garden by sector for process vent and ventilation vent releases at distances specified from North Anna Power Station Annual Environmental Survey Data for 1981. XIQ values were also calculated for the nearest lake shoreline by sector for the process vent and ventilation vent releases.

According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges.

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

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

The X/Q and D/Q values calculated from 1981 meteorological data are comparable to the values presented in the North Anna Power Station UFSAR.

1.3 Results The X/Q value that resulted in the maximum total body, skin and inhalation exposure for ventilation vent releases was 9.3E-06 sec/m3 at a site boundary location 1416 meters SE sector. For process vent releases, the site boundary X/Q value was 1.2E-06 sec/m3 at a location 1513 meters S sector. The shoreline X/Q value that resulted in the maximum inhalation exposure for ventilation vent releases was l .OE-04 sec/m3 at a location 27 4 meters NNE sector.

The shoreline XIQ value for process vent was 2.7E-06 sec/m3 at a location 274 meters NNE sector.

DOMINION VPAP-2103N REVISION 28 PAGE820F87 ATTACHMENT 13 (Page 3 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The original pathway analysis indicated that the maximum exposure from I 131 , I 133 , and from all radionuclides in particulate form with half-lives greater than 8 d<!ys was through the grass-cow-milk pathway. The D/Q value from ventilation vent releases resulting in the maximum exposure was 2.4E-09 per m2 at a location 3250 meters N sector. For process vent releases, the D/Q value was l. lE-09 per m2 at a location 3250 meters N sector. For tritium, the X/Q value from ventilation vent releases resulting in the maximum exposure for the milk pathway was 7.2E-07 sec/m3, and 3.9E-07 sec/m3 for process vent releases at a location 3250 meters N sector.

Analysis using 2007 release data indicates that the most limiting critical organ is the child's thyroid. The location is 1593 meters SSE sector. For process vent releases, the D/Q is l. lE-8.

For tritium releases, the X/Q values at this location are 9.5E-7 for the process vent and 3.3E-6 for the ventilation vents.

2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis ,was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent releases. The analysis includes a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2.

2.2 Data, Parameters, and Methodology Initially, radioactive liquid effluent release data for the years 1979, 1980, and 1981 were compiled from the North Anna Power Station semi-annual effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-0133.

DOMINION VPAP-2103N REViSION28 PAGE 83 OF 87 ATTACHMENT 13 (Page 4 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Re-concentration of effluents using the small lake connected to larger water body model was selected with the appropriate parameters determined from Table 3.5.3.5, Design Data for Reservoir and Waste Heat Treatment Facility from Virginia Electric and Power Company, Applicant's Environmental Report Supplement, North Anna Power Station, Units 1 and 2, March 15, 1972. Dilution factors for aquatic foods, shoreline, and drinking water were set to one. Transit time calculations were based on average flow rates. All other parameters were defaults selected by the LADT AP computer code.

Beginning in 1997, the activity by nuclide released in the previous year is entered into the North Anna Power Station liquid pathway critical organ calculations spreadsheet, which calculates the most limiting age group total body and critical organ. This Process is repeated annually.

2.3 Results Initially, the fish pathway resulted in the largest dose. The critical organ each year was the liver, and the adult and teenage age groups received the same organ dose. However, since the adult total body dose was greater than the teen total body dose for each year, the adult was selected as the most restrictive age group. Beginning in 1997, the most limiting- age group for both total body and critical organ is calculated from the spreadsheet or equivalent software for North Anna Power Station liquid pathway critical organ calculations.

DOMINION VPAP-2103N REVISION 28 PAGE 84 OF 87 ATTACHMENT 13 (Page 5 of 8)

Meteorological, Liquid, and* Gaseous Pathway Analysis 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose A gaseous effluent pathway analysis was performed to determine the location that would result in the maximum doses due to noble gases for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analysis also included a determination of the critical pathway, location of maximum exposed member of the public, and the critical organ for the maximum dose due to 1131 , 1133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for use in demonstrating compliance with requirements in Step 6.3.4.a.1. In addition, the analysis included a determination of the critical pathway, maximum age group, 131 133 and sector location of an exposed individual through the inhalation pathway from I , I ,

tritium, and particulates with half-lives greater than 8 days to demonstrate compliance with Step 6.3.1.a.

3.2 Data, Parameters, and Methodology Annual average 'X/Q values were calculated, as described in Section 1 of this attachment, for the nearest site boundary in each directional sector and at other critical locations beyond the site boundary. The largest 'XIQ value was determined to be 9 .3E-06 sec/m3 at site boundary for ventilation vent releases at a location 1416 meters SE direction, and l.2E-06 sec/m3 at site boundary for process vent releases at a location 1513 meters S direction. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases, would be at these site boundary locations. The doses from both release points are summed in calculations to calculate total maximum dose.

Step 6.3. l .a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and 'XIQ values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway.

DOMINION VPAP-2103N REVISION28 PAGE 85 OF87 ATTACHMENT 13 (Page 6 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis The NRC computer code GASPAR, "Evaluation of Atmospheric Releases," Revised 8/19/77, was run using 1979, 1980 and 1981 North Anna Power Station Gaseous Effluent Release Report data. Doses from I 131 , I 133 , tritium, and particulates for the inhalation pathway were calculated using the 9.3E-06 sec/m3 site boundary XIQ. Except for the source term data and the XIQ value, computer code default parameters were used. Results for each year indicated that the critical age group was the child and the critical organ was the thyroid for the inhalation pathway.

The gamma and beta dose factors Kivv, Livv, Mivv, and Nivv in Gaseous Effluent Dose Factors (Attachment 5) were obtained by performing a units conversion of the appropriate dose factors from Table B-1, Regulatory Guide 1.109, Rev. 1, to mrem/yr per Cifm3 or mrad/yr per Ci/m3, and multiplying by the ventilation vent site boundary XIQ value of 9 .3E-06 sec/m3. The same approach was used in calculating the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv in Gaseous Effluent Dose Factors (Attachment 5) using the process vent site boundary X/Q value of 1.2E-06 sec/m3.

The inhalation pathway dose factors Pivv and Pipv in Gaseous Effluent Dose Factors (Attachment 5) were calculated using the following equation:

Pi = K'(BR) DFA/XIQ) (mrem/yr per Curie/sec) (29-1) where:

K' = a constant of unit conversion, lE+ 12 pCi/Ci BR = the breathing rate of the child age group, 3700 m3/yr, from Table E-5, Regulatory Guide 1.109, Rev.I DFAi = the thyroid organ inhalation dose factor for child age group for the ith radionuclide, in mrem/pCi, from Table E-9, Regulatory Guide 1.109, Rev. 1 XIQ = the ~entilation vent site boundary XIQ, 9.3E-06 sec/m3, or the process ve~t site boundary XIQ, 1.2E-06 sec/m3, as appropriate

DOMINION VPAP-2103N REVISI0N28 PAGE 86 OF 87 ATTACHMENT 13 (Page 7 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Step 6.3.4.a., requires that the dose to the maximum exposed member of the public from I 131 ,

I 133 , tritium, and from all radionuclides in particulate form with half-lives greater than 8 days be less than or equal to the specified limits. Dose calculations were performed for an exposed member of the public within site boundary unrestricted areas, and to an exposed member of the public beyond site boundary at locations identified in the North Anna Power Station Annual Environmental Survey Data for 1981.

It was determined that the member of the public within site boundary would be using Lake Anna for recreational purposes a maximum of 2232 hours0.0258 days 0.62 hours 0.00369 weeks 8.49276e-4 months per year. It is assumed that this member of the public would be located the entire 2232 hours0.0258 days 0.62 hours 0.00369 weeks 8.49276e-4 months at the lake shoreline with the largest annual X/Q of 1.0E-04 at a location 274 meters NNE sector. !he NRC comp\lter code GASP AR was run to calculate the inhalation dose to this individual. The GASPAR results were corrected for the fractional year the member of the public would be using the lake.

Using the NRC computer code GASPAR and annual average XIQ and D/Q values obtained as described in Section 1 of this attachment, the member of the public receiving the largest dose beyond site boundary was determined to be located 1432 meters N sector. The critical pathway was vegetation, the maximum exposed age group was the child, and.the critical organ was the thyroid.

Pathway analysis results indicate that existing pathways, including ground and inhalation, within five miles of North Anna Power Station, yield Ri dose factors less than those determined for the vegetation. [Reference ~.1.32]

The RMivv and RMipv dose factors, except for tritium, in Critical Organ Dose Facto~s (Attachment 8) were calculated by multiplying the appropriate D/Q *value with the following equation:

RM.I (29-2) where:

K' =

a constant of unit conversion, IE+ 12 pCi/Ci Yv = vegetable areal density in Kg/m2 .

DOMINION VPAP-2103N REVISION 28 PAGE 87 OF 87 ATTACHMENT 13 (Page 8 of 8)

Meteorological, Liquid, and Gaseous Pathway Analysis Ucl = child leafy vegetable consumption rate, 26 Kg/yr Des = child stored vegetable consumption rate, 520 Kg/yr r = fraction of deposited activity retained on vegetation, 1.0 for radioiodine, and 0.2 for particulates DFLi= thyroid ingestion dose factor for the ith radionuclide for the child, in mrem/pCi, from Table E-13, Regulatory Guide 1.109, Rev. 1 Ai = decay constant for the ith radionuclide, in sec- I, from Kocher Aw = decay constant for removal of activity of leaf and plant surfaces by weathering, 5.73E-07 sec-I (corresponding to a 14 day half-life) tf = time between harvest of leafy vegetation and ingestion, 8.60E+4, in seconds th = time between harvest of stored vegetation and ingestion, 5.18E+6, in seconds fL = fraction of annual intake of leafy vegetables grown locally, 1.0 (dimensionless) fg = fraction of annual intake of stored vegetables grown locally, 0.76 (dimensionless)

Parameters used in the above equation were obtained from NUREG:.0133 and Regufatory Guide 1.109, Revision 1 Since the concentration of tritium in vegetation is based on the airborne concentration rather than the deposition, the Critical Organ Dose Factors (Attachment 8)for tritium were calculated by multiplying the following equation by the appropriate X/Q:

(29-3) where:

K = a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the atmosphere, 8.0, gmfm3 0.75 = the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined.

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