Text

Submittal of Annual Radioactive Effluent Release Report
	ML20136A343
Person / Time
Site:	Surry
Issue date:	04/30/2020
From:	Denise Wilson; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	20-155
	Download: ML20136A343 (121)
	v • d • e

VIRGINIA ELECTI!IC AND POWER CoMPANY RICHMOND, VIRGINIA 23261 APR 3 0 2020 United States Nuclear Regulatory Commission Serial No.20-155 Attention: Document Control Desk S&L/JWD RO Washington, DC 20555-0001 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR--37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWERSTATION UNITS 1AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORt Enclosed is fhe Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2019, through December 31, 2019. The report, submitted pursuant to Surry Power Station Technical Specification 6.6.8.3, includes a summary of the quantities of radioactive liquid and gaseous effluents and solid Waste released during the 2019 calendar year, as outlined in Regulatory Guide 1.21, Revision 1, June 1974.

If you have any further questions, please contact William Terry at 757-365-2010.

Sincerely,._.

-Jdf/f,;L*.

David Wilson ~pr 30, 2020)

David Wilson Director Nuclear Safety & Licensing Surry Power Station Attachment Commitrriefrits*made* i~ this letf~r: Norie

.cc: . U.*S. Nuclear Regulatory.Commission.

Region II. .

Marquis One Tower .

ATTN: Division of Reactor Safety - Radiation $afetYBranch .

)fE42 245 Peachtree Center Ave., NE Suite 1200 Atlanta, .Georgia ~030~-,1257 ..

A)t.R NRG Senior Resident Inspector

, Surry Power Station

Serial No.20-155 SPS Annual Rad Effluent Report Docket Nos. 50-280, 50-281 ATTACHMENT 2019 Annual Radioactive Effluent Release Report Surry Power Station SURRY POWER STATION UNITS 1 AND 2 VIRGINIA ELECTRIC AND POWER COMPANY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION January 1, 2019 through December 31, 2019 Prepared By: ---------¥=----~~-~rL2~-____,_.~~* "---t,--;-µ_

/i W. Abbott, Jr. .

Health Physicist Reviewed By: _ __ _ , . ~ - ~ - - - - - - - - - - - - -

// J.R.Hopkins SupJfutendent Health Physics Technical Services Approved By: ---~-.,,__,_)7 ___T_e:#Y=_,__,__ _ _ _ __

Manager Radiological Protection and Chemistry

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE SURRY POWER STATION January 1, 2019 through December 31, 2019 Section No. Subject 1 Executive Summary 1 2 Purpose and Scope 2 3 Discussion 3 4 Supplemental Information 4 Attachment 1 Effluent Release Data Attachment 2 Annual and Quarterly Doses Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM)

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

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

EXECUTIVE

SUMMARY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report describes the radiological effluent control program conducted at Surry Power Station during the 2019 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from Surry Power Station in accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", Revision 1, June 1974. The report also includes an assessment of radiation doses to the maximum exposed member of the public due to the radioactive liquid and gaseous effluents.

During this reporting period, there was one unplanned liquid effluent release and no unplanned gaseous effluent release as classified according to the criteria in the Offsite Dose Calculation Manual. The unplanned liquid effluent release is described in Attachment 6.

Based on the 2019 effluent release data, 10CFR50 Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The dose calculations are as follows:

1. The total body dose due to liquid effluents was 3.44E-04 rnrem, which is 5.73E-03%.

of the 6 mrem dose' limit The critical organ dose due to liquid effluents was 4.08E-04 mrem to the GI-LLI, which is 2.04E-03% of the 20 mrem dose limit. *

2. The air dose due to noble gases in gaseous effluents was 7.14E-06 mrad gamma, which is 3.57E-05% of the 20 mrad gamma dose limit, and 9.04E-06 mrad beta, which is 2.26E-05% of the 40 rnrad beta dose limit. * *

3. The critical organ dose from gaseous effluents due tol-131, I-133, H-3, ~nd particulates with half-lives greater than 8 days is 9.40E-02 mrem, which is 3.13E-01 % of the 30 mrem dose limit.

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

There was one revision made to VPAP-2103S, Offsite Dose Calculation Manual, during this reporting period. The revision to VPAP-2103S is provided in Attachment 3.

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

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

1

Purpose and Scope includes a summary of the quantities of radioactive liquid and gaseous effluents* and solid waste as outlined in Regulatory Guide 1.21, with data summarized on a quarterly or annual basis following the format of Tables 1, 2 and 3 of Appendix B, thereof Attachment 2 of this report includes an assessment of radiation doses to the maximum exposed member of th public due to radioactive liquid and gaseous effluents released from the site during 2019. *

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

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

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

As required by the ODCM, Section 6.7.5, a summary is provided in Attachment 8 of on-site radioactive leaks or spills and ground water sample analyses that were communicated in accordance with the Industry Ground Water Protection Initiative reporting protocol. Sample analyses from ground water wells that are not part of the Radiological Environmental Monitoring Program are also provided in Attachment 8. In 2019, no communications were made in accordance with the Industry Ground Water Protection Initiative. *

2

Discussion The basis for the calculation of the percent of technical specification for the critical organ in Table IA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for iodine- I 31, iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days shall be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary. The critical receptor was modeled as a teenage individual for the 1st, 2nd and 3rd quarters and the child for the 4th quarter, both via the inhalation pathway.

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

Percent of technicaLspecification calculations are based on the total gaseous or *liquid effluents released for the respective quarter.

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 the site boundary. The maximum exposed member of the public from the release of airborne iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, was modeled as a child at 2.01 miles with the critical organ being the bone via the ingestion pathway. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was modeled as an adult, exposed by either the invertebrate or fish pathway, with the critical organ typically being the gastrointestinal-lower large intestine. The total body dose was also determined for this individual.

There was no liquid or gaseous effluent monitoring instrumentation inoperable for greater than 30 days in 2019 to describe in Attachment 5 as required by the ODCM, Section 6.2.2 and 6.3.2.

There was one unplanned liquid release and no unplanned gaseous release in 2019 as described in Attachment 6 as required by the ODCM, Section 6. 7.2.

3

The typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation are presented in Attachment 7. These LLD values are based upon conservative conditions (i.e., minimum sample volumes and maximum delay time prior to analysis). Actual LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed,.Jhen the activity of the radioisotope was reported as Not Detected (N/D) on Attachment 1 of this report.

When all isotopes listed on Attachment 1 for a particular quarter and release rriode are less than the

lower limit of detection, then the totals for this period will be designated as Not Applicable (N/A).

Supplemental Information Section 6.6.1 of the ODCM requires the identification of the cause(s) for the unavailability of milk, or if required, leafy vegetation samples, and the identification for obtaining replacement samples. As milk was available for collection during this reporting period, ,leafy vegetation sampling was not required.

As required by the ODCM, Section 6:6.2, evaluation of the Land Use Census is made to determine if new sample location(s) must be added to the Radiological Environmental Monitoring Program.

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

4

Attachment 1 EFFLUENT RELEASE DATA January 1, 2019 through December 31, 2019 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.

Attachment 1 TABLE lA Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER . QUARTER A. FISSION & ACTIVATION GASES

1. TOT AL RELEASE Ci 0.00E+OO 2.54E-04 l.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec O.OOE+OO 3.23E-05 **

B. IODINE

1. TOTAL 1-131 Ci O.OOE+OO O.OOE+OO 2.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec O.OOE+OO O.OOE+OO C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 3.85E-06 O.OOE+OO 2.80E+Ol

2. A VE RELEASE RATE FOR PERIOD µCi/sec 4.95E-07 0.00E+OO

3. GROSS ALPHA RADIOACTIVITY Ci N/D N/D D. TRITIUM

1. TOTAL RELEASE Ci 1.1 IE+Ol l.05E+Ol 3.IOE+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec l.43E+OO l.33E+OO E. CARBON-14

1. TOT AL RELEASE Ci O.OOE+OO 3.60E-02

2. A VE RELEASE RATE FOR PERIOD µCi/sec O.OOE+OO 4.58E-03 PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RA TE % 2.18E-03 2.00E-03 TOTAL BODY DOSE RATE % O.OOE+OO 4.56E-I0 SKIN DOSE RATE % O.OOE+OO l.79E-I0

Attachment 1 TABLE lA Page 2 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST.ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOT AL RELEASE Ci 2.29E-03 l.30E-01 l.80E+Ol

2. A VE RELEASE RATE FOR PERIOD µCi/sec 2.88E-04 l.64E-02 B. IODINE

1. TOTAL I-131 Ci O.OOE+OO O.OOE+OO 2.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec O.OOE+OO O.OOE+OO C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci O.OOE+OO l.26E-05 2.80E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec O.OOE+OO l.59E-06

3. GROSS ALPHA RADIOACTIVITY Ci N/D N/D D. TRITIUM

1. TOT AL RELEASE Ci 6.91E+OO 9.81E+OO 3.IOE+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec 8.69E-01 l.23E+OO E. CARBON-14

1. TOT AL RELEASE Ci 3.24E-Ol l.85E+Ol

2. AVE RELEASE RATE FOR PERIOD µCi/sec 4.0SE-02 2.32E+OO PERCENT AGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE % l.32E-03 9.84E-03 TOT AL BODY DOSE RATE % 4.07E-09 5.14E-06 SKIN DOSE RATE % l.60E-09 l.50E-06

Attachment 1 TABLE 1B Page 3 of 12 EFFLUENT :AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENTS-MJXED,MODE RELEASES CONTINUOUS MODE BATCH MODE SURRYPOWERSTATIONUNlTS 1&2 UNIT FlRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci NID NID *NJD NID Kr-85m Ci NID NID NID NID Kr-87 Ci NID NID NID NID Kr-88 Ci NID NID NID NiD Xe-133 Ci NID NID NID 2.54E-04 Xe-135 Ci NID NID

NID NID Xe-135m Ci NID NID NID NID Xe-138 Ci NID NID NID NID Xe-13lm Ci NID NID NID NID Xe-133m Ci NID NID NID **NJD Ar-41 Ci NID NID. NID NID TOTAL FOR PERIOD Ci NIA NIA NIA 2.54E-04

2. IODINES I-131 Ci NID NID NID NID I-133 Ci NID NID NID NID I-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID NID NID NID Sr-90 Ci NID NID NID NID Cs-134 Ci NID NID N/D NID Cs-137 Ci NID NID NID NID Ba-140 Ci NID NID NID NID La-140 Ci NID NID NID NID Co-58 Ci NID NID NID NID Co-60 Ci NID NID NID NID Mn-54 Ci NID NID NID NID Fe-59 Ci NID NID NID NID Zn-65 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID NID C-14 Ci NID NID NID 3.60E-02 TOTAL FOR PERIOD Ci NIA NIA NIA 3.60E-02

Attachment 1 TABLElB Page 4 of12

)]:FFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENTS-MIXED MODE *RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2

UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D NID Kr-85m Ci NID N/D N/D NID Kr-87 Ci N/D NID NID N/D Kr-88 Ci NID N/D N/D N/D.

Xe-133 Ci N/D 2.03E-02 2.29E-03 9.75E-02 Xe-135 Ci NID NID N/D l.80E-04 Xe-I35m Ci N/D NID NID N/D Xe-138 Ci N/D NID N/D N/D Xe-13lm Ci NID NID N/D ~ID Xe-133m Ci N/D N/D NID 7.0IE-04 Ar-41 Ci NID N/D N/D N/D TOTAL FOR PERIOD Ci NIA 2.03E-02 2.29E-03 9.84E-02

2. IODINES I-131 Ci NID N/D NID N/D I-133 Ci NID N/D N/D N/D I-135 Ci N/D NID N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID N/D NID N/D Sr-90 Ci N/D NID NID N/D Cs-134 Ci N/D NID N/D N/D Cs-137 Ci NID

N/D N/D N/D Ba-140 Ci . NID NID NID N/D La-140 Ci N/D NID NID N/D Co-58 Ci NID N/D NID N/D Co-60 Ci NID N/D NID N/D Mn-54 Ci NID NID NID N/D Fe-59 Ci NID NID NID N!D Zn-65 Ci NID N/D N/D NID Mo-99 Ci NID N/D N/D NID Ce-141 Ci NID

N/D N/D N/D Ce-144 Ci NID N/D N/D N/D.

C-14 Ci. N/D 2.88E+OO 3.24E-01 l.39E+0I TOTAL FOR PERIOD Ci NIA 2.88E+OO 3.24E-01 l.39E+Ol

Attachment 1 TABLElC Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRYPOWERSTATIONUNITS 1&2 UNIT FIRST SECOND* **FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D N/D Kr-85m Ci N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D N/D N/D N/D Xe-135 Ci N/D N/D N/D N/D Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-13lm Ci N/D N/D N/D N/D Xe-i33m Ci N/D N/D N/D Nib Ar-41 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA

2. I0DIJ\1ES I-131 Ci N/D N/D N/D N/D I-133 Ci N/D N/D N/D N/D I-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D* N/D N/D N/D Cs-137 Ci N/D N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci 3.85E-06 N/D N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99. Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce-144 Ci N/D\ N/D N/D N/D C-14 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci 3.85E-06 NIA NIA NIA

Attachment 1 TABLElC Page 6 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT. THJRD FOURTH THJRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D NIP N/D N/D Kr-85m Ci N/D N/D N/D N/D Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D N/D Xe-133 Ci N/D N/D N/D l.07E-02 Xe-135 Ci N/D N/D N/D N/D Xe-135m Ci N/D N/D N/D NIP Xe-138 Ci N/D N/D N/D N/D.

Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D Ar-41 Ci N/D 8.76E-04 N/D N/D TOTAL FOR PERIOD Ci NIA 8.76E-04 NIA 1.07E-02

2. IODINES I-131 Ci N/D N/D N/D N/D I-133 Ci N/D N/D N/D N/D I-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA. NIA

3. PARTICULATES Sr-89 Ci N/D N/D N/D NID Sr-90 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci N/D N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci N/D 1.26E-05 N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci NID N/D N/D N/D Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D N/D N/D N/D Ce-141 Ci N/D N/D N/D N/D Ce-144 Ci N/D N/D N/D N/D C-14 Ci N/D 1.24E-Ol N/D 1.52E+OO TOTAL FOR PERIOD Ci NIA 1.24E-01 NIA 1.52E+OO

Attachment 1 TABLE2A Page 7 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRYPOWERSTATIONUNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 1.39E-02 5.44E-03, 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/rnL 2.14E-ll 8.38E-12

3. PERCENT OF APPLICABLE LIMIT % l.68E-04 5.45E-05 B. TRITIUM

1. TOTAL RELEASE Ci l.90E+Ol 4.32E+Ol 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/rnL 2.93E-08 6.66E-08

3. PERCENT OF APPLICABLE LIMIT % 2.93E-04 6.66E-04 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci NID NID 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/rnL NIA NIA

3. PERCENT OF APPLICABLE LIMIT % NIA NIA D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci NID NID 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.20E+07 5.28E+07 3.00E+OO F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 6.47E+ll 6.49E+ll 3.00E+OO

Attachment 1 TABLE2A Page 8 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12/31/19 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST.ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 1.72E-03 1.05E-03 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/mL 2.20E-12 l.82E-12

3. PERCENT OF APPLICABLE LIMIT % 7.06E-06 6.49E-06 B. TRITIUM L TOTAL RELEASE Ci 4.09E+02 7.72E+02 2.00E+Ol

2. AVE DIL. CONC. DURING PERIOD µCi/mL 5.24E-07 l.34E-06

3. PERCENT OF APPLICABLE LIMIT % 5.24E-03 l.34E-02 C. DISSOLVED AND ENTRAINED GASES

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

2. AVE DIL. CONC. DURING PERIOD µCi/mL NIA NIA

3. PERCENT OF APPLICABLE LIMIT % NIA NIA D. GROSS ALPHA RADIOACTIVITY

1. TOTAL RELEASE Ci NID N/D 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.38E+07 5.42E+07 3.00E+OO F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.80E+ll 5.78E+ll 3.00E+OO

Attachment 1 TABLE2B Page 9 ofl2 EFFLUENT AND WASTE DISPOSAL'ANNUAL REPORT PERIOD: 1/1/19 TO 12/31119 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRYPOWERSTATIONUNITS 1&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER

QUARTER QUARTER Sr-89 Ci NID NID Nin *NID Sr-90 Ci NID NID NID NID Fe-55 Ci NID NID NID NID Cs-134 Ci NID NID Nm** NID Cs-137 Ci 2.06E-04 2.04E-04 9:26E~03 2.92E-03 I-131 Ci NID NID NID NID Co-58 Ci NID NID 5.44E-05 4.71E-04 Co-60 Ci NID NID 4.31E-03 l.lOE-03 Fe-59 Ci NID NID NID NID Zn-65 Ci NID NID NID NID Mn-54 Ci NID NID NID NID Cr-51 Ci NID N/D NID NID Zr-95 Ci NID NID NID N/D Nb-95 Ci NID NID. . N/D NID Mo-99 Ci NID NID NID 'NID Tc-99m Ci NID NID NID NID Ba-140 Ci NID NID *NlD NID La-140 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID NID Sb-124 Ci NID NID NID NID Sb-125 Ci NID NID 3.47£-05 7.47E-04 Co-57 Ci NID NID NID NID TOTAL FOR PERIOD Ci 2.06E-04 2.04E-04 1.37E-02 5.24E-03 Xe-133* Ci NID NID NID NID Xe-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

Attachment 1 TABLE2B Page 10 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/19 TO 12131/19 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER Sr-89 Ci NID NID NID NID Sr-90 Ci NID NID NID NID Fe-55 Ci NID NID NID NID Cs-134 Ci NID NID NID NID Cs-137 Ci 2.31E-04 l.52E-04 l.16E-04 9.lSE-05 I-131 Ci NID NID NID NID Co-58 Ci NID NID 3.SlE-04 2.95E-04 Co-60 Ci NID NID 5.06E-04 3.32E-04 Fe-59

Ci NID NID NID NID Zn-65 Ci NID NID NID NID Mn-54 Ci NID NID NID NID Cr-51. Ci NID NID NID NID Zr-95 Ci NID NID NID NID Nb-95 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Tc-99m Ci NID NID NID NID Ba-140 Ci NID NID NID NID La~140 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID NID Sb-124 Ci NID NID NID l.97E-06 Sb-125 Ci NID NID 5.BE-04 l.77E-04 Co-57 Ci NID NID NID NID TOTAL FOR PERIOD Ci 2.31E-04 l.52E-04 l.49E-03 8.97E-04 Xe-133 Ci NID NID NID NID Xe-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

Attachment 1 TA.BLE3 Page 11 of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1/19 - 12/31/19 SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

1. Type of waste 12month Est. Total .

Period Error,%

3

a. Spent resins, filter sludges, evaporator m 3.96E+OO 1.00E+Ol bottoms, etc. Ci 3.56E+02 3.00E+OI *

b. Dry compressible waste, contaminated m3 2.40E+02 l.OOE+Ol equip., etc. Ci 4.31 E-01 3.00E+Ol

c. Irradiated components, control m3 O.OOE+OO l.OOE+Ol rods, etc. Ci O.OOE+OO 3.00E+Ot

d. Other (Waste oil) m3 O.OOE+OO l.OOE+Ol Ci O.OOE+OO* 3.00E+Ol

2. Estimate of major nuclide composition (by type of waste)

a. C-14 % l.59E+OO Fe-55 % 6.18E+OO Co-58 % 9.18E+OO Co-60 % 3.22E+Ol Ni-63 % 3.3IE+Ol Cs-134 % 5.97E+OO Cs-137 % 7.65E+OO

b. Mn-54 % 2.lOE+OO Fe-55 % 5.64E+OO Co-60 % 7.00E+Ol Ni-63 % l.65E+Ol Sb-125 % l.23E+OO Pu-241 % 2.82E+OO C. n/a % n/a

d. n/a % n/a

Attachment 1 TABLE3 Page 12 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED ,FUEL SHIPMENTS PJ):RIOD: 1/1/19 -12/31/19 CONTINUED SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

3. Solid Waste Disposition '

Number of Shipments Mode of Transportation Destination 7 Truck Oak Ridge, TN (EnergySolutions) 1 Truck Erwin, TN (ResinSolutions) 1 Truck Kingston, TN (EnergySolutions)

B. IRRADIATED FUEL SHIPMENT (Disposition)

Number of Shipments Mode of Transportation Destination 0

NOTE 1: Some of this waste was shipped to licensed waste processors for processing and/or v.olume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 3.96E+OO m3.

NOTE 2: Some DAW was shipped to licensed waste processors for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 2.40E+02 m3.

NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. Therefore, this volume is not representative of the actual volume buried. The total volume buried for this reporting period is O.OOE+OO m3.

Attochment 2 Page 1 of 1 ANNUAL AND QUARTERLY DOSES 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 is made pursuant to the ODCM, Section 6. 7 .2, requirement.

LIQUID Maximum Receptor - Adult 2019 Total Body GI-LLI Liver (mrem) (mrem) (mrem) 1st Quarter 6.41E-05 9.98E-05 8.63E-05 2nd Quarter ~E-05 3.87E-05 3.62E-05 3rd Quarter 6.67E-OS 7.61E-05 6.68E-OS 4th Quarter l.84E-04 l.93E-04 l.84E-04 Annual 3.44E-04 4.08E-04 3.73E-04 GASEOUS - Air Dose 2019 Gamma Beta (mrad) (mrad) 1st Quarter O.OOE+OO O.OOE+OO 2nd Quarter 6.83E-10 2.03E-09 3rd Quarter 6.lSE-09 l.83E-08 4th Quarter 7.13E-06 9.02E-06 Annual 7.14E-06 9.04E-06 GASEOUS - Organ Dose Annual Maximum by Quarter 2019 Maximum Child/Bone Receptor I (mrem) (mrem) Organ 1st Quarter 1.48E-06 8.06E-03 Teen/Lung 2nd Quarter 1.62E-04 7.46E-03 Teen/Liver 3rd Quarter 1.47E-03 4.99E-03 Teen/Liver 4th Quarter 9.24E-02 9.24E-02 Child/Bone Annual 9.40E-02

Attachment 3 Page 1 of 1 REVISIONS TO OFFSITE J)OSE CALCULATION MANUAL (ODCM)

. As__require_g by l;'echnical Specification 9._8.B_, revisions .to tb,~ ODCM, eff~ctive for the time pe;riod _

cov~red by** this report, are included with this attachment. There was one revision to the ODCM.

imple~ented duringthi~ r~p~rti~g,period.A summary of the ODCM revision is listed below..

Revision 21:

R~yision chat).g~d the. fqllowing Envir0nrnental ~ampltng Locations on Attachment 9:

Updated Milk Control Location from Lover Retreat to Beachy Farm

Added Well Water distance and 'directien fot*Surry Station location* ..

Updated Sediment distance and direction for Surry Station Discharge location O,t~er Changes

Updated 2nd sentence ofDose Equivalent l-131, Definition 4.5

, *'; i,

~ ,*

',*,*, }*'_:*:

p pr Dominion Energy Administrative Procedure or Guidance and Reference Document Approval AD-AA-101 - Attachment 4 Page 1 of 1

1. Document Number: 12. Revision: 13. Document Type; _

VPAP-2103S 21 l2l Administrative Procedure 0GARD 4.Title:

Offsite Dose Calculation Manual {Surry)

5. Requestor(s) Print Name(s) / Locations 16. Date 17. Requester Phone Johnnie Abbott I SPS 11/28/2018 . . 8:798-2434

8. Document Request DNew l2l Revision D Cancel D Supersede D Temporary

9. Applicable Nuclear Station(s)

MillstoneD North Anna D Surry~

10. Reason and Brief Description of Change:

Revision initiated to update Environmental Sampling Locations on ATTACHMENT 9. The following changes were made:

Updated Milk Control Location from Lover Retreat to Beachy Farm

Added Well Water distance and direction for Surry Station location

Updated Sediment distance and direction for Surry Station Discharge location *,

For additional changes, see Revision Summary.

11. Printed Working Group Approver Name Paul Harris 12.Signa~

. ,. /h .' 13. Date 05/16/2019

14. Records Retention Requirements Affected? .115. Change Management: .

D Yes (Complete NRRS form from RM-AA-101) ~No Attach Appropriate PI-AA-4000 Attachment(s)

16. Level of Use:

D Continuous Use D Reference Use ~ Information Use D Multiple Use Fleet Approval

17. Fleet Approval Required by: (Check one box only. Enter Peer Group Name, if applicable)

D Peer Group OR ~ Functio~ager (FAM)

18. Printed Approver Name Lee Ragland Site Approval

19. Signature lp-fd~J .

20. Date 05/21/2019

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

None

22. Implementation Prerequisites Reviewed - Pr cedure Supervisor Signature 23. Date

~ l I I I\. _, 7~ ~ 1A-'\t: ~

(M....

24. Check Nuclear Station(s) for Which I )acumen! is oemg Approved for Implementation.

(.,n." It q MillstoneD North Anna D .....--....A Surry~

25. Site Approval (Print Name of FAM) 27. /;te,/,

126. Sir:a.~.:_J Lee Ragland

28. Facility Safety Review Committee Required? 29. Facility Safety Review Committee (Site) Print Name/Signature ' :,. , '°'

30. Date 12] No 0No OYes

31. Site Vice President Required?

~Yes

32. t N/A v:z'.dent) Print Name/Signature

. _,,, ~ *- ~

33. Date NIA L!;:611 q NOTE: The lndividual{sl Dostim1 a new or revised1'.ltfcuml'fut to EDM81!re responslble for ensurina Nuclear E-Forms is updated.

34. Nuclear E-Forms Updated for Site(s)? 135. Nuclear E-Forms Updated Print Name/Signature 136. Date D MP D NA D SU [81 NIA N/A N/A

37. Document Number; 138. Revision: 139. Effective Date 140. Expiration Date VPAPd2103S 21 06/26/2019 N/A Key: GARD-Guidance and Reference Document, EDMS-Electronlc Document Management System Form No. 728620(Nov 2017)

=ra

tt.,,,'

Dominion Energy 50.59ll2.48 Applicability CM-AA-400 ATTACHMENT 1 Page 1 of 3 Applicable Station Applicable To: Parent DocumenVRevision D North Anna Power Station D Unit 1 D Unit 2 ORD JSFSI VPAP-2103S Revision 21

[8:J Surry Power Station [gJ Unit 1 [8:J Unit 2 OR O ISFSI D Millstone Power Station D Unit 1 D Unit 2 D Unit 3 OR OISFSI Part I. Description of Activity Subject to 50.59/72.48 Review (See Attachment 2, Part I)

Revision initiated to update Environmental Sampling Locations on ATTACHMENT 9. '

The following changes were made:

Updated Milk Control Location from Lover Retreat to Beachy Farm

Added Well Water distance and direction for Surry Station location

Updated Sediment distance and direction for Surry Station Discharge location For *additional changes, see Revision Summary.

Part II. Activity Previously Reviewed (See Attachment 2, Part II)

Is this activity Fully bounded by one or more of the following?

1. Fully bounded by a DYES ~ NO D Attached (optional) - If YES, identify bounding source document completed 50.59/72.48 Screen or Evaluation?

2. Fully bounded by a DYES ~ NO D Attached (optional) - If YES, identify bounding source document station activity that has already received NRG approval?

PART II. CONCLUSION D One of the above review questions is answered YES, a 50.59/72.48 Screen is NOT required; complete Parts\/,

VI, VII rgJ Both of the above review questions are answered NO, continue the 50.59/72.48 Applicability Part Ill. Controlled by Other Change Control Process (See Attachment 2, Part Ill)

Check if any of the following documents are identified as part of the proposed activity, NOTE: For example, when a design change is the proposed activity, conseqUE=lntial actions may include changes to one of these documents which have a different change control prqcess and are NOT to be included in this 10 CFR 50.59/72.48 review.

1. Technical Specifications or Operating License D

z. Beyond-Design-Basis (BOB) FLEX Strategies D

3. Emergency Plan D

4. Security Plan D

5. Fire Protection Program and is NOT associated with JSFSI D

6. Quality Assurance Program Description D

7. lnservice Test Plan - IST D

8. lnservice Inspection Plan - ISi D

9. EGGS Analysis D

10. Environmental Protection Plan D

11. Radiation Protection Program D

12. Radiological Environmental Monitoring and Offsite Dose Calculations Manual rgJ

13. Reactor Vessel Surveillance Withdrawal Schedule D Form No. 729534 (Jan 2018)

P

,:./1 Dominion Energy 50.59172.48 Applicability CM*AA-400 ATTACHMENT 1 Page 2 of 3 PART Ill. CONCLUSION 12g If one or more of the documents listed above are selected, AND the proposed activity is completely controlled by the related change process; or limited to changing the selected documents, a 50.59/72.48 Screen is NOT required; complete Parts V, VI, VIL D If NO documents are selected, continue the 50.59/72.48 Applicability.

D If one or more of the documents a.re selected, AND some portion of the activity involves facility or procedure as explicitly or implicitly described in the FSAR (as updated) changes; continue the 50.59/72.48 Applicability for that portion.

Part IV.1 General Pre-Screen to determine activities that require a 50.59/72.48 Screen (See Attachment 2, Part IV.1)

1. Does this activity involve any changes to the ISFSI written evaluations required by . NO OYES.D 10CFR72.212? ..

2. Does this activity involve fire protection activities associated with the ISFSI? DYES D NO

3. Does this activity involve maintenance activities on the ISFSI? YES 0 NO

4. Does this activity involve a temporary modification (excluding non-technical or administrative NO 0YES.0 change)? [CM 5.1.1 and CM 5.1.2]

5. Does this activity involve a compensatory measure associated with an Operability Determination required to be implemented to maintain or restore operability or functionality to . DYES D NO a Technical Specification required SSC?

Part IV.1 CONCLUSION D One of the General pre-Screen Qµestions is answered "YES", a Screen is required, complete Parts V, Vi, and VII.

D All of the General pre-Screen Questions are answered "NO", Continue the 50.59/72.48 Applicability.

Part IV.2 General Pre-Screen to determine activities NOT requiring 50.59/72.48 Screen - Questions 1 and 2 are not applicable to ISFSI (See Attachment 2, Part IV.2) - - * * *

1. Is thjs a maintenance activity limited to restoring an SSCs to its original or as-designed .

condition {includes Temporary Alterations in support of Maintenance (TAM) NOT in effect D D D longer than 90 days at power) AND does NOT permanently alter the design, performance YES NO N/A requirements, operation, or control of SSCs?

2. Is this a maintenance activity limited to installing .or testing approved facility changes? D D D YES NO N/A

3. Is this change limited to managerial and administrative procedures governing the conduct of D D D facility operations? YES NO N/A

4. Is this change limited to 'Modifying' the SAR? OR is this change limited to editorial changes to procedures and other documents that contain information on how structures, systems, D D and components explicitly or implicitly in the UFSAR are operated arid. controlled?

YES NO NIA Part IV.2 CONCLUSION D One or more of the above Part IV.2 questions are answered YES, a 10 CFR 50.59/72.48 Screen is NOT required; complete Parts V, VI, and VII.

D If all of the above Part IV.2 questions are answered NO or N/A, no excluded activities were sell:3cted, A 10 CFR 50.59/72AB Screen is required, complete Parts V, VI, and VII.

Form No. 729534 (Jan 2018)

50.59ll2.48 Applicability CM-AA-400 ATTACHMENT 1 . . ,Page 3*~f 3 PART V. CONCLUSION

1. A 50.59 or 72:48 Screen is:

IX] NOT Required (Part 11 Conclusion, OR Part Ill Conclusion, OR Part IV.2 Conclusion, determined a Screen is N.OT required)

. -~ '.

D Required (Part IV.1 Conclusion or Part IV.2 Conclusion determined a 50.59/72.48 Screen is required).

ComplefePartsVI and Vl(then Perform a 50.59/72.48 Screen *in accordance with sµbsection 3.4;

2. A c_hange t.o the SARi~::

IX]' , .NOt Requi~~c( **::i :_':. *'**, : ., ' ,"

D Required (Fill out Attachment 7 if applicable, see subsection 3.1.3'.) and Process SAR change request in accordance with CM-M.:SAR-101 AND include change requestriumber: **

-IF q change te th.e-SAR is required, THEN at least one of thesigners in Part Vll,-Sigmiture, must be***

1

50:_5'9/72.48)Scr~~n'.qciaiified~' * .: * * ** *. '* :-,-:,::.~ . .* ' ' *,. 1 ' '. * * ' * ' ,: * ** , * *

$. Regula!ory Risk, wa.:5_eval~_c:1ted (subsection 3;2) c3nd th_e following additional review [s >

' IX]*

NOT Required * .. **

D

Required: D Challenge Review D lndeper[c!Emt Thir.d Party Revieyv D Nuclear Lic~nsing Department Review Additional Regulatory Interaction Part vr. Corhmerits (use supplemental pages as* needed) * .

(Examples:* Identify any 50'.59/72.48 Screen or Evaluation or NRG approved activity that contributes to this review; fdentify parts of the activity that are..bounded or not bounded by a previously completed review or that ate NOT part of another change process. Document information needed to support conclusions.)

~~ Admirilstr1=1~;v/Pf~~~dure Revisi~n ...... . . ..

This administrative activity" does.not: affect SSCs, perform a test or experiment not described in ttie SAR, or involve *a temporary modification. Th.is administrative activity was processect*in accordance with DOM-QA.:.1'. * ** '

. _/

G Part.VII. Signature Preparer Name.(Print) .: .. ' * *:,

Heather Baer Co-signer Name (only if Preparer .is, NOT qualifiedJ (Print) Qo,sigrier Signature; ......

Peer Reviewer Name (Optional) (Print)

Johnnie W. Abbott Jr.

. \' '**

I.

-... ' .:;. ~1 *:

Form No. 729534 (Jan 2018)

ii=-

~

Dominion Energye Document Traveler AD-AA-101 -Attachment 2 Page 1.of 1

1. Document Number: 12. Revision: 13. Document Type:

VPAP-2103S 21 181 Administrative Procedure 0GARD 4.

Title:

Offsite Dose Calculation Manual (Surry)

5. Procedure Writer (Name)/ Requestor(s) (Name(s)) 16. Writer Location , 7. Writer Phone Heather Baer SPS 8-798-2172

8. Document Request (Check one block per traveler.)

0 New 181 Revision D cancel D Supersede Functional Area (FA) Contact(s) Identified In Block 9 are responsible to ensure change management Information (Blocks 22-24) Is added to this form and are responsible to champion the document through required reviews, approvals, and Implementation.

9. FA Contact(s) (Check box(es) and provide names(s).

MPO _ _ NAO _ _ OtherO _ _

SU 181 Paul Harris Corporate D Obtain concurrence with Required Reviews In (Blocks 13-18) - Reviews NOT marked as required are optional Opportunity Reviews.

10. Reviewing Site(s) 111. Procedure Supervisor Signatrre 112. Date SPS I ,., "' A' _/ 7~Ji:..t,UCt:: ILi. , i 1,J71 l1q

13. Review Type 14. Response 15. Reviewer or Reviewing Orga ~ization 16. Initials 17. Date Required?

Training N Nuclear Training Instructor - ~P {Hilt or Major)

Cross-Discipline Cross-Discipline Cross-Discipline Cross-Discipline .- .

.Yi,lf' S/1!3//"I Other: Requestor y Johnnie Abbott Other:

Other:

Writer's Guide y

Type:II Validation Pete Blount

/~ s.1t.11t7 Environmental Screening (MP)

Independent Review (IR) - (Review In accordance with the Independent Review Criteria of AD-AA-101. Preparer, Requestor, and Working Group members CANNOT perform this review.)

18. IR Organization 19. IR Reviewer (Print Name) 120. IR S~u~_L 21. Date Radiolooical Protection Anthony Hairston .?.:;;- r.h.t/1\

Change management Information - Enter N/A for Blocks 22 and 23 If a formal change management plan Is attached.

22. Document(s) to be Superseded or Revised VPAP-2103S R20

23. Training Required (e.g., Supervisory Briefing, Tailgate Briefing, Required Reading, Formal Training, etc.)

Email Notification Upon Implementation

24. Update to IT Applications Required (Including updates to electronic forms)

N/A

25. Update to Nuclear Records Management Requirements (e.g., new or changed record type or retention requirements)

N/A

26. Required Applicability Reviews/ Site Regulatory Screenings*/Reviews Completed 27. Regulatory Evaluation Required?

181 Yes (Must be attached If governing document requires a written record) D Yes 181 No

'Envlronmenlal ~ are required for MlllslOne Statlon

28. Additional Reviewers or Instructions:

N/A

29. Document Number: VPAP-21035 130. Revlslon: 21 Key: GARD-Guidance and Reference Document, MP-MIiistone, NA-North Anna, SU-Surry Form No. 72881 S(Nov 2017)

iii.¢ Dominion Change Management Screening Checklist

- Energy* PI-AA-4000 - Attachment 1 Page 1 of 1 Title of Change VPAP-2103S, Offsite Dose Calculation Manual (Surry), Revision 21 Change Owner Department Implementation Date Paul Hanis Radiological Protection Procedure Effective Date What is the change (give a brief description)?

Updated Milk Control Location from Lover Retreat to Beachy Farm; Added Well Water distance and direction for Surry Station location; Updated Sediment distance and direction for Surry Station Discharge location Why is the change occurring?

Sampling locations changed ~nd distances/direction for site samples needed upda~ng.

What are the consequences of n<>! changing? .

ODCM not updated with current sample locations and correct distances/directions for site samples.

Where is the Change being Implemented? O Fleet ~ Site O Region O Department O Individual O Community Change Impact Checklist

1. Impact Nuclear, Radiological, Industrial, Environmental Safety? 0Yes 181 No 2.

Impact Licensing, FSAR;Tecbnical Specifications, or Regulatory documents? 0Yes 181 No

3. Impact Business Plan, E-Plan, Security Plan, QA Program? 0Yes 181 No

4. Impact on Equipment Reliability: 0Yes 181 No

a. Modifications with significant plan impact?

b; Modifications with planlmpact? 0Yes 181 No

c. Installation of a non-complex modification not affecting operations of risk? 0Yes 181 No d.

Equipment replacement, like for like?

' -~ 0Yes 181 No

5. Impact Procedures/Policies: 0Yes 181 No

a. Procedures/Processes with complex or significant. change?

b. Procedures/Processes affecting multiple departments? 0Yes 181 No

6. Impact computer programs/applications software: 0Yes 181 No

a. Complex change affecting usage by high number of personnel?

b. Process change affecting limited personnel? 0Yes 181 No

7. Impact training or qualifications of personnel? 0Yes 181 No

8. Impact work activities or operating schedule? 0Yes 181 No

9. Impact on multiple departments, functions, processes, or large numbers of personnel? 0Yes 181 No

10. Require transfer of responsibility from one organization to another? Use Attachment 4,. Organizational Transfer Form. 0Yes 181 No

11. Impact on strategic staffing plan? 0Yes 181 No

!f any of the Items above are marked YES, THEN CONTINUE to ATTACHMENT 2, Implementation Plan OR provide Justification for waiver below.

N/A Change Owner: Date:

Paul Harris ~ 05/16/2019 Approved By (Management Spo; ,or~

Lee Ragland L,....., Date:S -/ "2. I 17 NOTE: Send approved (prior to

ntation of actions) Change Management to t he Manager rganlzational Effectiveness, or deslgnee.

Form No. 730524(September 2018)

DOMINION VPAP-2103S REVISI0N20 PAGE650F76 ATTACHMENT 9 (Page2 -of3) , :, .'*

Environmental Sampling Locations SAMPLE * .. LOCATION DISTANCE l>IRECllO~ . .. REMARKS *.

MEDIA (MILES) . . _' . *' . -

Environmental Bacon's Castle (20) 4.5 .., : . SSW,_. Approx. 5 mile$ . : *..

TLDs 1-R.~o~u~te~6~3~3_ _ _ _ (2~1~)4---~4~.9_ _____,,_..~- -' ' '.._:_SW~ ** ~-- --+- . *~A~pp~r~

.ox~

*~5~mil~*~e~s~*~* ---l , 1, Alliance . . . (22) 5..1 ._. WSWr, ) :. Approx. 5 mi.es

Surry . (23~., ,.,7.7 -. .,. , * - WSW, , *. Population Cente~

'

u .;J'. i~te 6~§ and 637:i/(2~~ ; * ;:', ; 1.4;9,,) * \ {/*.' W *:,..5-l Apprvx. 5 miles ?' *. :fW'

'-~- WNW.**

Approx. 5 miles 1

',: *. Scotland Wharf * * (25)" . * * ' SJ) : ' 't

Jamestown (26) 6.3 .. NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Appro~. 5 m.iles

. j r- ** *' .8 R.oute 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N ,; Approx. 5 miles .

Williamsburg (30) ,£ 7.8 N Population Center Kingsmill North (31) 5.5 NNE '

Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 *NE Approx. 5 miles

~* ... BASF (34) 5.1 ENE Approx. 5 miles 7.1 'ENE Population Center

,, I'

. r ,

Lee Hall (35)

Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News " * (38)

19.3

SE Population Center James R.iver Bridge (39) - . 17;1 . SE *,, *control Benn's Church (40) 17.0 SSE *

Control *

1 Snithfield * .. (41) 13.4 * * * . SSE - * .,r Control R.ushmere (42) 5.3 SSE Approx. 5 miles R.oute 628 (43) 5.1 s Approx. 5 miles Mille) Epps 4.8 SSW Colonial Parkway 3.7 NNW 1

'l::rne1

__ _ _-=-_ _ _,.___.JO.a R:ee;8a, _ _---1,_ _~ __;._ _..&...... Control

___ Location

__ ____J

I

. ~~- F~.,1,-~--.. ,1-q& .. -~- _ s~

. 'r. (Jw) l ',lt * \

... - . -*-* .... *~*

., ...... . . j *** }* *., * ~1-'i'.~;~ :--*!::!)!

.. \f, *

' ~: I . ('

DOMINION VPAP-2103S REVISI0N20 PAGE65 OF76 ATTACHMENT 9 (Page2 of3)

Environmental Sampling Locations SAMPLE LOC::ATION . DISTANCE DIRECTION REMARKS MEDIA (MILES)

Environmental . Bacon's Castle * (20) 4.5 SSW Approx. 5 miles

'ILDs Route633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (2A) 4.0 w Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx..5 miles .

Jamestown (26) 6.3 NW Approx. 5 miles

... Colonial Parkway (27) 3.8 NNW . Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 mp.es Kingsmill (29) 4.6 ,N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E '. Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 ' SE Population Center

)

James River Bridge (39) 17.1 SE

.. Control Loc.A.~,J Benn's Church *(40) 17.0 SSE Control ~ ~ -

Smithfield (41) 13.4 SSE Control l..-OCAi~cA Rushmere (42) 5.3 SSE Approx. 5 miles Route62a . (43) 5.1 s .. . Approx. 5 miles Milk Epps 4.8 SSW

.Colonial _Parkway 3.7 NNW Lover Retreat 30.6 N Control Location

. -. ..-*1- "I : *

C.~A~ LJaicli~* ~a_ G_tsC.M)

OMINION l"-1~/\.1 occ..wt1 ~fl'\.~ q..,1A ~ :t,. VPAP-2103S A;: ~"::> .doc.o..~~ 'itJ.~b \~ 2- \ REVISI0N20 PAGB660F76

\

. 'I ATTACBMENT9 *

(Page3 of3)

Environmental Samplliig Locations *

SAMPLE LOCATION DIRECTION REMARKS ,,

MEDIA '. ~~CE , E_S).. - '

Well Water Surry Station I o.\ _s w_* . Onsite** :,

Hog Island, Reserve . I 2.0 NNE E

Construction Site - / 0.3 ' Onsite***

Crops (Corn, I

Peanuts,'

Slade's Farm 3.2 -.'. s ., .

Soybeans) *

Brock's Farm I 3.8 s ' !.

River Water SJm'¥ Bisehftfg8 tt- 0.4 NW,. r (Monthly) Scotland Wharf 4.9 ** ~*- i WNW Control Location Sediment Chickahon:uny River 11.2 WNW .. :

Control Location (Silt)

Surry Station Discharge 0.5 1.9 r Nul ~ .

.:Sample Collected in Clams Surry Station Intake Chickahominy River l

!,8 11.2 ESE**

WNW .,*.. . Control Location Channel .I J :Su:nj Station Discharge 1.3 / NNW '

l . Jamestown Island

3.9 NW Oysters Point of Shoals 6.4 SSE

' Mulberry Point r 4.9 ESE

Swash Hol6 Island

6.8 SE Crabs r* .. Surry Station Discharge 1.3 t ,./ . NNW .. -

' ~

Fish . Surry Station Discharge - 1.3 / NNW .

Shoreline Hog Island Reserve :

0.6 I N Sedime.qt, ' . -

Chickahominy River *'

11.2 WNW'.,.1 Control Location :

Onsite Location - in Lead Shield

- Onsite sample of Well Water taken from tap-water at Smzy.Environm:~ntal Building

' I " *, *

! .. ' *~ . . . r

- - , .Qnsite .sample tl of Well Water talcen fr~mI tap-water at Surry Training Center,

cs (.3 ~,~ ~ -'l .... *-- . . - .

No, ~le...Wl"fs " ' - ~ ~v.:-id'{\o.CS"...-.ksl~AQ ... ~

CaM-,~ l.. o~ vl.-\ C...\)"J\.T.

~,,~<?.* <<$ave; w~ ~le. -;,, J.le... ~~ -/a C...UA.,~ 12

I I

/

INSERTM I

DOSE EQU IVALENT 1-131 shall be that concentration of !-131 (microcuries per gram) that alone would produce the same dose when inhaled as the coi *ned activities of iodine isotopes 1-131, 1-132, 1-133, 1-134, and 1-135 actually presen The determination of DOSE EQUIVALENT 1-131 shall be performed using Cammi Effective Dose

. Equivalent (Ca E) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11. Al) t) .

DOMINION VPAP-2103S REVIS10N20 PAGE 7 OF76 4.2 Channel Check A qualitativ~ ~essment,,by observation,' ~f chann~l belia;ior during o~eration. This assessment includes; where possible, comparison of the channel indi~~tion and/o~ status with

' ' * ; * *~ ' * ' .. ~I

other indications 'and/or status derived from independent instrumentation channels

, .measuring the same parameter.

The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display.

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

4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions.

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

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.

4.5 Dose Equivalent 1-131 ,

That concentration of 1131 (µCi/cc) that alone would produce the same thyroi ~ h ~

quantity and isotopic mixture of 1131 , 1132, 1133, 1134, and 1135 actually presen~ o s e conversion factors far thi.£ ca:J.cylatioa an~ listed iii Table m of TID 14844, Cmcnlation of Distaaee Fastef8 for Power and Test Reaster Sites. ~ i e ease eeB-..ersiea fa:eters ftem NR£ Regtthctory etutcte 1.I09, Itevtston 1, may be ttsea.

DOMINION VPAP-2103S REVISI0N20 PAGE 120F76

c. 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 ~

L.i ACW.

i 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 CPR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

d. Bases - Liquid Effluent Concentration Limitations This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will not exceed 10 times the concentration values specified in Appendix B, Table' 2, Column 2 of 10 CFR20. The specification provides operational flexibility for releasing liquid effluent in concentrations to follow the Section*Il.A and II.C design objectives of Appendix I to 10 CPR Part 50. This limitation provides additional assurance that the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: ( 1) the Section II.A design objectives o~ Appendix I, 10 CPR Part 50, to a MEMBER OF THE PUBLIC, and (2) restrictions authorized by 10 CPR 20.130l(e). The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its effluent concentration in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2. This specification does not affect the requirements to comply with the annual limitations of 10 CPR 20;130l(e).

DOMINION VPAP-2103S REVISI0N20 PAGE 55 OF76 ATTACHMENT4 (Page 4 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87 , Kr88, Xe 133 , Xe 133m, Xe 135, Xe135m, andXe 138 for gaseous emissions and Mn54, Fe59 , Co58 , Co60, 'hJ.65 , Mo99 , Cs 134, Cs 137, Ce141 and ee 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

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

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased more than a factor of 3; and

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

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

NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 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 corresponding LLDs may be increased by a factor of 10. This

. requirement applies if:

a. Analysis shows that the dose equivalent 1131 concentration in the primary coolant has increased by a factor of 3; and

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

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

ft

=# Energy Dominion Station Administrative Procedure

Title:

Offsite Dose Calculation Manual (Surry)

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

Procedure Number Revision Number Effective Date VPAP-2103S 21 On File Revision Summary Revision initiated to update Environmental Sampling Locations on ATTACHMENT 9.

The following changes were made:

Updated Milk Control Location from Lover Retreat to Beachy Farm

Added Well Water distance and direction for Surry Station location

Updated Sediment distance and direction for Surry Station Discharge location Other Changes

Updated 2nd sentence of Dose Equivalent 1-131, Definition 4.5 Approvals on File

DOMINION VPAP-2103S REVISION 21 PAGE2 OF76

(*'

TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

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

DOMINION VPAP-2103S REVISION 21 PAGE3 OF 76 TABLE OF CONTENTS (continued)

Section Page 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 35 6.6.1 Monitoring Program 35 6.6.2 Land Use Census 38 6.6.3 Interlaboratory Comparison Program 39 6.7 Reporting Requirements 39

6. 7 .1 Annual Radiological Environmental Operating Report 39

6. 7 .2 Annual Radioactive Effluent Release Report 41

.6.7.3 Annual Meteorological Data 43 6.7.4 Changes to the ODCM 43 6.7.5 Industry Qro~nd Water Protection Initiative 44 7.0

RECORDS 46 ATTACHMENTS 1 Radioactive Liquid *Effluent Monitoring Instrumentatio'n 47 2 Radioactive Liquid Effluent Monitoring Instrumentation 48

Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Radioactive Gaseous Effluent Monitoringlnstrumentation 56 6 Radioactive Gaseous Effluent Monitoring Instrumentation 58 Surveillance Requirements 7 Dispersion and Deposition Factors 60 8 Radiological Environmental Monitoring Program 61 9 Environmental Sampling Locations 64 10 Detection Capabilities for Environmental Sample Analysis 67 11 Reporting Levels for Radioactivity Concentrations.in Enyironmental Samples 69 12 Meteorological, Liquid, and Gaseous Pathway Analysis 70

DOMINION VPAP-2103S REVISION 21 PAGE40F76 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of 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 CFR 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

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

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

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

- I 131 , I 133 , and H 3 , and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 15 00 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 CFR 50, Appendix I, and

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

DOMINION VPAP-2103S REVISION21 PAGE 5 OF 76

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3 .1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3 .1.3 40 CFR 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 CFR 50, Appendix I, Rev. 1, U.S. NRC, October 1977

3. I. 7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion ofGast';ous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 Surry Technical Specifications (Units I and 2).

3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP Ii Prngram, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S: NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring,

November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 197S 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating L WR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 21 PAGE 6 OF76 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.20 Surry UFSAR 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change O1-022, Ventilation Radiation Mon.itoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.26 CR022320 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.27 RP-AA-502, Groundwater Protection Program 3.1.28 Branch Technical Position, Revision 1, November 1?79 3.1.29 CR1013104, VPAP-2103S compensatory actions review not completed for 1-RLW-FIT-153 failure. . . .

3.2 Commitment Documents 3.2.l _ Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary,ofthe channel output so it responds with the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

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

DOMINION VPAP-2103S REVISION 21 PAGE 7 OF 76 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/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter.

The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display.

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

4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions.

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

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.

4.5 Dose Equivalent 1-131 That concentration ofl 131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixtme ofl 131 , 1132, 1133 , 1134, and 1135 ~ctually present. The determination of dose equivalent I 131 shall be performed using Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.

DOMINION VPAP-2103S REVISION 21 PAGE 8 OF 76 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 on~e 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 NIA - 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 and waste gas surge tanks.

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

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

Q = Source strength (instantaneous; grams, curies)

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

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

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

DOMINION VPAP-2103S REVISION 21 PAGE 9 OF 76 4.10 Members of the Public Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This 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., 2587 Megawatts Thermal MWt).

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

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

For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electr:onics ..

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-2103S REVISI0N21 PAGE 10 OF 76 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 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 (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components.

5.0 RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry

The Manager Radiological Protection and Chemistry is responsible for:

5 .1.1 Establishing and n1ainfaining procedures for surveying, sampling, anc;l monitoring radioactive effluents and the environment.

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

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

5.1.4 Preparing Effluent and Environmental Monitoring Program records.

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

DOMINION VPAP-2103S REVISI0N2l PAGE 11 OF 76 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12).

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 asses*s the status of the discharge,monitored.

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

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

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

6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations *

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

1. For radionuclides (other than dissolved or entrained noble gases), liquid effluent concentrations relea,sed 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 ofliquid effluent exceeds the limits in Step 6.2.1.a., promptly reduce concentrations to within limits.

DOMINION VPAP-2103S REVISION21 PAGE 12 OF76

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

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

. . . µCi/mLi -

Volume of Waste Discharged x L ACW.

1 i'

where:

µCi/mLi = the concentration of nuclide i in the liquid effluent discharge ACWi = ten times the effluentconcentratioh value in unrestricted areas of nuclide i, expressed as µCi/mL from lQ,CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

d. Ba~es - Liquid Effluent Concentration Limitatirns This control is provided to ensure that the concentration. of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will not exceed 10 times the concentration values specified in Appendix B, Table 2, Column 2 of 10 CFR 20. The specification provides operational flexibility for releasing liquid effluent in concentrations to follow the Section II.A and II.C design objectives of Appendix I to 10 CFR Part 50. This limitation provides additional assurance that the levels ofradioactive materials in bodies of water in UNRESTRICTED AREAS will result in exp_osures within: (1) the Sec9on II.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) restrictions authorized by 10 CFR 20.1301(e). The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe:..135 is the controlling radioisotope and its effluent concentration in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2. This specification does not affect the requirements to comply with the annual limitations of 10 CFR 20.1301(e).

DOMINION VPAP--2103S REVISION 21 PAGE 13 OF76 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effluent Monitoring Instrumentation Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Efflu~nt 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. *

l. 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

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 Functional 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 oper~ble 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.

DOMINION VPAP~2103S REVISION 21 PAGE 14 OF 76

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

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

RE-RRM-131

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

1. Maximum setpoint values shall be calculated by:

- CF s = ____.!2 (2)

FE where:

S the setpoint, in µCi/mL, of the radioactivity monitor measuring the radioactivity concentration in the effluent line pdor to dilution C = the effluent concentration limit for the monitor used to implement 1'0 CFR 20 for the Station (ACW in µCi/mL) for an isotopic mixture expected in the effluent FE = maximum design pathway effluent flow rate

Fn = dilution water flow rate calculated as:

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

2. Each of the condenser circulating water channels (e.g., SW-120, SW-220) monitors the effluent (service water, including component cooling service water, circulating water, and liquid radwaste) in the circulating water discharge

tunnel beyond the last point of possible radioactive material addition. No dilution is assumed for this pathway. Therefore, Equation (2) becomes:

S = C (3)

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

DOMINION VPAP-2103S REVISION 21 PAGE 15 OF 76

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

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

s (4) where:

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

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

s (5) where:

KRw =. Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway * **

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

e. Bases - Radioactive Liquid Effluent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the ODCM to ensure that the alarm/trip will occur prior to exceeding 10 times the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

DOMINION VPAP~2103S REVISION 21 PAGE 16 OF 76 6.2.3 Liquid Effluent Dose Limit

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

1. During any calendar quarter:

Less than or equal to 1.5 mrem to the total body

Less than or equal to 5 mrem to the critical organ

2. During any calendar year:

Less than or equal to 3 mrem to the total body

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

b. Action If the calculated dose from release ofradioactive 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.

DOMINION VPAP-2103S REVISI0N2l PAGE 17 OF76

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

Dose contributions shall be calculated for all radionuclides identified in liquid effluents *released to unrestricted areas based on the equation:

D = tFM~C-A; (6)

L...J. I I where:

Subscripts = i, refers to individual radionuclide D = Jhe cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem t the period for which Ci and F are ~veraged for all liquid releases, in hours M = the mixing ratio (reciproc.al of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix I IA, Surry UFSAR F the near field average dilution factor for Ci.during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci

the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem/hr per µCi/mL A-1 1.14 E+05 (21BFi + 5BI) DFi (7)

DOMINION VPAP-2103S REVIS10N21 PAGE 18 OF 76 For example:

1.14 E+05 = 1 E+06 pCi/µCi x 1 E+03 mL/L / (8760 hr/yr), units conversion factor 21 adult fish consumpt~on, kg/yr'. from NUREG-0133 5 adult invertebrate consumption, kg/yr, from NUREG-0133 Bli = the salt water bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L BF i = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L DF i= the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II and VCRL-50564, Rev. 1.

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.

DOMINION . VPAP-2103S REVISION 21 PAGE 19 OF 76

e. Bases - Dose Due To Liquid Effluents This control is provided to implement the requirements of Sections II.A, III.A, and IV.A of Appendix! to 10 CFR Part 50. The control implements the guides set forth

in Section II.A. The ACTION statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and parameters in the ODCM implement the requirements in Section III.A that conformance with the guides of Appendix I be shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with l OCFR Part 5.0, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing App~ndix I," April 1977.

6.2.4 Liquid Radwaste Treatment Historica,l data pertaining to the volumes and rac:lioactivity of liquid effluents released in connection with specific station functions, such as maintenance or refueling outages, shall be used in projections as appropriate.

a. Requirement l; The Surry Radwaste Facility Liquid Waste 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 0.06mrem 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.

DOMINION VPAP-2103S REVISION 21 PAGE20 OF 76

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 VP AP-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 Tofal Body and Critical Organ Dose Calculation

1. Determine DL, the sum of all liquid,open and closed release points, in mrem, by the ith organ, forthe quarter.

2. Determine P, the Projection Factor, which is result of31 divided by the number of days from start of the quarter to the end of the release.

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

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

Dp = (DL x P) + Da

d. Bases - Liquid Radwaste Treatment System The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement provides assurance that the releases of

. radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to .10 CFR Part 50 and the design objective given in Section II.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50 for liquid effluents.

DOMINION VPAP-2103S REVISION 21 PAGE21 OF76 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 Limitations

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 :S 500 mrem/year to the total body and :S 3000 mrem/year to the skin.

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 be :S 1500 mrem/year to the critical organ.

b. Action

1. If dose rates exceed Step 6.3. l .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-2103S REVISION 21 PAGE22 OF 76

c. Calculations of Gaseous Effluent Dose Rates

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

x * -Q.x )] s 500 mrem/yrtothetotal body

+ (K1* Qipv L [(K. Qivv-Q*

I lVV

)

lpV * *

(8)

OR,*

~ [ ( (L i + 1.1 M.)1 Qivv !Q.IVV L...J . ) + ((Li + 1.1 M.) Qipv !Q..

1 lpV

) ] s 3000 mrem/yr to the skin (9) i' where:

Subscripts vv, refers to vent releases from the building ventilation vent, including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide K1 the total body dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 L*I the skin dose factor due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 M*1 the air dose factor due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/m3 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 the gaseous disper:sion factor, sec/m3(See Attachment 7)

DOMINION VPAP-2103S REVISION 21 PAGE23 OF76

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

z)P i Qivv !ivv + Pi Qipv!ip) ~ 1500 mrem/yr to the critical organ (10) 1 where:

p.

I = the critical organ dose factor for 1131 , 1133 , H3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, in mrem/yr per Curie/m3

= the release rate for ventilation vents or process vent ofl 131 ,

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

X!Qivv, X!Qipv = the gaseous dispersion factor, sec!m\See Attachment 7)

3. All ga~eous releases, not through the process vent, are considered ground level and shall be included in the determination ofQivv.

d. Bases - Dose Rate This specification provides reasonable assur8:nce radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE

BOUNDARY, in excess of the design objectives of Appendix I to 10 CFRPart 50.

This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and II.C design objectives of Appendix I to 10 CPR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body, less than or equal to 3000 mrem/year to the skin and the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year. This specification does not affect the requirements to comply with the annual limitation of 10 CPR 20.130l(a). This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

DOMINION VPAP-2103S REVISION21 PAGE24 OF 76 6.3 .2 Gaseous Monitoring Instrumentation *

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.1.a. noble gas 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, Source Checks, Channel Calibrations, and Channel Functional Tests at the frequencies shown in Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance

Requirements (Attachment 6).

b. Action

1. If a radioactive gaseous effluent monitoring instrqmentation channel alarm/trip setpoint is less conservative than required by Step 6.3 .2.a. l, promptly:

Suspend th.e release of radioactive. gaseous effluents monitored by the affected channel and declare the channel inoperable or

Change the setpoint .so it is acceptably conservative

2. If the number of operable channels is less than the minimum required by tables in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4),

take the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 21 PAGE25 OF 76

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-130B Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101

d. Setpoint Calculations

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

D~ Dpv + Dcae+ Dvv (11) where:

D = Step 6.3. l .a. dose limits that implement Technical Specifications 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 the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

DOMINION VPAP-2103S REVISION 21 PAGE 26 OF 76

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (12)

Fm where:*

m the release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv) the effluent concentration limit implementing Step 6.3. l .a. for the Station, µCi/mL

the release rate limit for pathway m determined from methodology in Step 6.3.. l .c., typically using Xe 133 as nuclide to be released, µCi/sec 2.12E-03 CFM per mL/sec Fm the maximum flow rate for pathway m, CFM 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.

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

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

DOMINION VPAP-2103S REVISION 21 PAGE27 OF 76 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: :s; 5 mrads for gamma radiation and :s; 10 mra~

for beta radiation

During any calendar year: :s; i Omrads for gamma radiation and :s; 20 mrad for beta radiation

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

at least once per 31 days.

b'. Action

If the calculated air dose from radioactive noble gases in gaseous effluents exceeds

.any of the.above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that identifies the causes for exceeding the limits and defines corrective actions that have been taken to reduce relea~es 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.

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:

(13)

DOMINION VPAP-2103S REVISI0N21 PAGE28 OF 76 For beta radiation:

3 .17E-08

- x + (Ni QiPVQip)]

L [(Ni QiVVQivv) - x (14)

Where:

Subscripts vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide the air dose for gamma radiation, in mrad the air dose for beta radiation, in mrad Mi the air dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Ni = the air dose factor due to beta emissions for each identified noble gas radionuciide i, in mrad/yr per Curie/m3 Qivv, Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3 .17 E-0 8 the inverse of the number of seconds in a year X!Qiw, X!Qipv the gaseous dispersion factor, seclrri\See Attachment 7) 6.3A *1-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit

a. Requirement

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

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

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

2. Cumulative dose contributions to a member of the public from I 131 , 113 3, 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.

DOMINION VPAP-2103S REVISION 21 PAGE29 OF 76

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

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

c. Dose Calculations NOTE: All criti.cal organ doses for each age group are calculated to determine which is the limiting organ for the period being evaluated.

Gaseous releases, not through the process vent, are considered ground level and shall be included in the determination ofQ;vv. 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.

DOMINION VPAP-2103S REVISION 21 PAGE 30 OF 76

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

Dr= 3.17£ - 08 _L [RM ( Qivv

DIQVV + Qipv

DIQPJ + RI ( Qivv

XIQVV + Qipv

XIQPJ (15) i

+ RG (Qivv; DIQvv + Qipv "D IQ pv ). + RH 3. * (Qivv "){IQ

.* . vv

+_ Qipv "XIQ )]

pv For example:

Subscripts vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors; pv, refers to the vent releases from the process vent the dose to the critical organ of the maximum exposed member of the public in mrem

the release for ventilation vents or process vent of I 131 , I 133 ,

tritium, and from all pan:iculate-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 X"Qvv, X"Qpv the gaseous-dispersion factor, sec/m 3(See Attachment 7) .

DIQvv, D/Qpv = the gaseous deposition factor, m- 2 (See Attachment 7)

RM = the milk pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2 *mrem/yr per Ci/sec RI the inhalation pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per Ci/m3 RG the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2 *mrem/yr per Ci/sec RH 3 the tritium dose factor for milk in mrem/yr per Ci/m3

DOMINION VPAP-2103S REVISION 21 PAGE 31 OF 76 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. Appropriate portions of the Gaseous Radwaste Treatment System shall be used to reduce radioactive materials in gaseous waste before its discharge, when the projected gaseous effluent air doses due to gaseous effluent releases, from each unit to areas at and beyond the site boundary, would exceed O.2 mrad for gamma rad.iation and 0.4 mrad for beta radiation, averaged over 31 days.

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

3. Doses due to gaseous releases from the site shall be projected at least once pe; 31 days, based on the cal~ulations 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 d~ys, a special report in acc;;ordance with VPAP-2802, Notifications and Reports, that includes:

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

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

2. Determine P, the Projection Factor, which is result of 31 divided by the number of days fron1 st~rt of the quarter to the end of the release.

DOMINION . VPAP-2103S REVISION 21 PAGE32 OF 76

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

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

Dp = (Dg x P) + Da 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. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis.

6.4.1 Liquid Waste Batch Releases

a. Operations shall obtain RP authorization be~ore initiating batch releases of radioactive liquids.

b. Release of contents from the following tanks/sumps 0th.er than transfers to the Radwaste Facility shall have a release permit before the discharge. Examples of

' include:

batch releases

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

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

Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases

a. Operations shall obtain RP authorization before initiating continuous releases of radioactive_ liquids.

b. Examples of continuous releases include:

Steam generator blowdown

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

Storm drains,-~q~ipped ~ith composite sampli~g systems, that receive run-off

. from rain anci turbine building s~~ps; ~~b~urface drains and ground water wells when pumps are in automatic mode.

DOMINION VPAP-2103S REVISION 21 PAGE 33 OF 76 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.

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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. *

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

Maximum authorized release rate

Applicable conditions or controls pertaining to the release

DOMINION VPAP-2103S REVISION 21 PAGE 34 OF 76

e. RP shall notify the Operations Shift Supervision 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. Verify the correct source is authorized for release.*

2. Note maximum authorized release rate.

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

DOMINION VPAP-2103S REVISION 21 PAGE35 OF 76 6.5.2 Action

a. If the calculated doses fromrel~ase of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 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 actio,n to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CFR 20.2203(a)(4), shall include:

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

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

3. If the estimated dose exceeds the 'limits in Step 6.5.1, and if the release conditio~ that violates 40 CPR 190 has riot already been corrected, the special

report shall include a request for a variance in ~ccordance 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 8).

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

DOMINION VPAP-2103S REVISION21 PAGE 36 OF 76

3. Samples shall be analyzed in accordance with:

Radiological Environmental Monitoring Program (Attachment 8) requirements

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

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

b. Action

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

2. If, when averaged over any calendar quarter, rndioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental

. Samples.(Attachment 11), prepare and submit to the NRC, within 30 days, a special report iµ acc:ordance with VPAP-2802, Notifications and Reports, that:

. Identifies the causes for ~xceeding the limits, and I

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

concentration (1) + concentration (2) + >

10 (15) reporting level (1) reporting level (2) *** -

DOMINION VPAP-2103S REVISION21 PAGE 37 OF 76

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) 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 VP AP-2802,

Notifications and Reports. *

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 8), 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.

5. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons. If specimens are unavailable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the -next sampling period. All deviations from the sampling schedule shall be documented in the annual report in accordance with VPAP-2802, Notifications and Reports.

DOMINION VPAP-2103S REVISION21 PAGE 38 OF 76 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 shaU be included i~ the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

2. In lieu of the garden census, broad leaf vygetation 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 8) 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 Step 6.3.4.a.,

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) 20 percent greater than at a location from which samples are currently being obtained, add the new locations to the Radiological Environmental Monitoring Program within 30 days. Sampling locations, excluding the control station location, that have the lowest calculated dose or dose commitments (via the same exposure pathway) may be deleted from the monitoring program. Identify new locations in the next Annual Radioactive Effluent Release Report and include in the report revised figures and tables reflecting the new locations in accordance with VP AP-2802, Notifications and Reports. [Commitment 3.2.1]

DOMINION VPAP-2103S REVISION 21 PAGE39 OF 76 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.

b. Action

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

Program Cross-Check of Milk I 131 Gamma Sr89 and Sr90 Water Gross Beta, Gamma, I 131 , H 3 (Tritium), Sr 89 and Sr90 (blind-any combinations of above radionuclides)

Air Filter Gross Beta, Gamma, Sr90

2. If analyses are not performed as required by Step 6.6.3.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-2103S REVISI0N21 PAGE40 OF 76

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

1. If some individual results are not available for inclusioµ with the report, the report shall be submitted, noting and explaining: i:;ea,sons for missing results.

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

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

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

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

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

g. Discussion of analyses in which the lower limit of detection (LLD) required by Detection Capabilities for Environmental Sample Analysis (Attachment I 0) was not achievable. *

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

DOMINION VPAP-2103S REVISION2I PAGE41 OF76 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 Uraniurµ Fuel Cycle Standard, 40 CFR Part 190."

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 foI1owing the format of Regulatory Guide* 1.21, Appendix B, for solid waste.

[Commitment 3.2.2]

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 frofri'the site to unrestricted areas, during the reporting period, which meet the following criteria:

Unplanned releases that exceeded the limits in Steps 6.2.l 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 CFR 50. 72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CFR 50.73, Licensee Event Report System, report is required

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

.DOMINION VPAP-2103S REVISI0N21 PAGE42 OF 76

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

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

6. A listing of new locations for dose calculation~ or environmental monitoring identified by the lan1 use. census (See Step 6.6.2).

7. A summary *ofradioactive 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 callllot 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. ,

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

b. Dose Assessment - Station

1. Radiation d?se 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.

Pl)pulation dos~s shaUnot be included in dose assessments.

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

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-2103S REVISION 21 PAGE43 OF 76

/

NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

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

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

3. Dose Assessment - ISFSI Provide such information as may be required by the Commission to estimate potential radiation dose commitrilentto the public resulting from effluent releases from the ISFSI.

6.7.J 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. Approved by the 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-2103S REVISION 21 PAGE440F76

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

10 CFR 20, Subpart D

40 CFR190

10 CFR 50.36a

10 CFR 50, Appendix I

Technical Specifications

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

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

6.7.5 Industry Ground Water Protection Initiative*

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

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

b. Communications

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

DOMINION VPAP-2103S REVISION21 PAGE45 OF 76

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

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

An on-site surface water sample result, that is hydrologically connected to ground water, or ground water that is or could be used as a source of drinking water, that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11).

c. 30-Day Reports

1. Submit a written 30-day report to the NRC for a water sample result for on-site or off-site ground water that is or could be used as a source of drinking water that exceeds the reporting criteria listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11). A 30-day report is

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

2. Concurrently submit a copy of the written 30-day NRC report to the appropriate State andLocal officials. *

d. Annual Reports

1. Report sample results communicated per6.7.5.b.l in the Annual Radiological Effluent Release Report.

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

3. Report_ sa,mple results communicated pe! 6.7.5.b.2 in the Annual Radiological Effluent Release Report or the Annual Radiological Environmental Operating Report.

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

DOMINION VPAP-2103S REVISI0N21 PAGE46 OF 76 7.0 RECORDS 7.1 The following record(s) completed as a result of this procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

7 .1.1 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 effluei;its released. to the environment

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

7 .2.1 Quality Assuranc~ Records None 7.2.2 Non-Quality Assurance Records None 7.3 The following item(s) completed as a result of this procedure are NOT records and are NOT required to be transmitted t6 Nuclear Document Management (NDM).

None

DOMINION VPAP-2103S REVISION 21 PAGE 47 OF 76 ATTACHMENT 1 (Page l of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Instrument Minimum Action Operable Channels

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

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMINATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 1 ' 2 Unit 2: 2-SW-RM-220 1 2 (b) Component Cooling Service Water Effluent Lines, l-SW-RM-I07A I 2 1-SW-RM-107B I 2 1-SW-RM-I07C 1 2 1-SW-RM-107D 1 2

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 1 3 '

ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway shall be suspended.

ACTION 2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that, at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, Radioactive Liquid Waste Sampling and Analysis.

ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 30 minutes during the actual releases. Design capacity pump performance curves generated in place or volume released over time may be used to estimate flow.

DOMINION VPAP-2103S REVISI0N2l PAGE48 OF 76 ATTACHMENT 2 (Page l of 1)

Radioactive Liquid Effluent Monitoring Instrumentation Surveilla:pce Requirements Channel Dcscr,ption Channel Source Channel Channel Check Check Calibration Functional Tes1

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

2. GROSS BETA OR GAMMA RADIOACTIVI-TY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMl-NATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 D M R Q Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, l-SW-RM-107A 1-SW-RM-107B

' D M R Q 1-SW-RM-107C l-SW-RM-107D

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RL W-153 DR NIA R NIA

DOMINION VPAP-2103S REVISI0N21 PAGE490F76 ATTACHMENT 3 (Page 1 of3)

Radioactive Liquid Waste Sampling and Analysis Program

Lower Limit of Liquid Release Sampling Minifl?.Um Analysis Type of Activity Detection (LLD)

Type Frequency Frequ~ncy Analysis

(µCi/mL), (Note 1) p p Principal Gamma 5 X 10"7 Emitters (Note 3)

(Each Batch) (Each Batch) 1131 1 X 10"6 p Dissolved and Batch Releases M Entrained Gases 1 X 10"5 (Orte Batch/M)

(Gamma Emitters) 1 X 10"5 p" '

(Note 2) M Composite . H3 (Each Batch) (Note 4) ,Gross Alpha 1 X 10"7 p Q Composite S.r 89 and Sr90 5 X 10"8 (Each Batch) (Note 4) Fe55 1 X 10"6 Principal Gamma 5 X 10"7 Continuous W Composite Emitters (Note 6)

(Note 6) (Note 6) 1131 1 X 10"6 Dissolved and Continuous M M

Entrained Gases 1 X 10"5 Releases Grab Sample

(Gamma Emitters)

(Note 5) Continuous MComposite 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-2103S REVISI0N21 PAGE 50 OF 76 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):

4.66.sb LLD - ~~~~~~~~~- * (8-1)

E

V

2.22E+06

Y

e-0\,~t)

Where:

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

Sb the standard deviation of the backgroµnd 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 = th~ 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

~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 liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REV1SI0N21 PAGE 51 OF 76 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 following radionuclides: Mn54, Fe 59 , Co 58 , Co 60 , Zn65 , Mo 99 , Cs 13 4, Cs 13 7 , Ce 141 , and Ce 141. 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 ofliquici 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*tha~ has an input flow during the continuous rdease.

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

DOMINION VPAP-2103S REVISION 21 PAGE 52 OF 76 ATTACHMENT 4 (Page 1 of 4)

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

(µCi/mL), (Note 1)

Prior to Release A. Waste Gas Prior to Release Principal Gamma .

(Each Tank) 1 X 10"4 Storage Tank (Each Tank) Emitters (Note 2)

(Grab Sample)

Principal Gamma Prior to Release Prior to Release 1 X 10"4 B. Containment Emitters (Note 2)

(Each PURGE)

Purge (Each PURGE) H3 1 X 10"6 (Grab Sample)

C. Ventilation Weekly Principal Gamma Weekly 1 X 10"4 (l)Process Vent (Grab Sample) Emitters (Note 2)

(2)Vent Vent #1 (3)Vent Vent #2 (Not~ 3) (Note 3) H3 1 X 10"6 (4)SRFVent

'i 131 1 X 10" 12 Continuous Weekly (Note 5)

(Note 4) (Charcoal Sample) 1133 1 X 10-IO Continuous Weekly (Note 5) Principal Gamma 1 X 10-ll All Release (Note 4) Particulate Sample Emitter (Note 2)

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

Particulate Sample in A, B, and C Quarterly Continuous Sr89 and Sr90 Composite 1 X 10" 11 (Note 4)

Particulate Continuous Noble Gas Monitor Noble Gases Gross 1 X 10"6 (Note 4) Beta and Gamma Principal Gamma Weekly Weekly 1 X 10"4 Condenser Air Emitters (Note 2)

Grab Sample Ejector (Note 3) H3 1 X 10"6 (Note 3)

DOMINION VPAP-2103S REVISION2I PAGE 53 OF76 ATTACHMENT4 (Page 2 of 4)

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

(µCi/mL), (Note 1)

Principal Gamma Prior to Release Prior to Release 1 X 10"4 Emitters (Grab Sample) (Each Release) H3 1 X 10"6 1131 1 X 10" 11 Continuous Charcoal Sample (Note 4) (Note 6) 1133 1 X 10-lO Containment '

Continuous

Particulate Sample Principal Gamma 1 X 10-lO Hog Depres- (Note 4) (Note 6) Emitter (Note 2) surization Composite Particu-Continuous 1 X 10-lO late Sample Gross Alpha (Note 4)

(Note 6) * *

Composite Particu-Continuous S~89 .and Sr90 1 X 10-lO late Sample (Note 4)

(Note 6) _..

DOMINION VPAP-2103S REVISION 21 PAGE540F76 ATTACHMENT 4 (Page 3 of 4)

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

4.66 Sb LLD (10-1)

E

V

2.22E+06

Y

e-(ALl: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 4.9).

Sb the standard deviation of the background counting rate or of th~ 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 n)-1.mber *of disintegrations per minute (dpm) per microcurie.

Y = the fractional radiochemical yield (when.applicable).

A 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.

DOMINION VPAP-2103S REVISION 21 PAGE 55 OF 76 ATTACHMENT 4 (Page 4 of 4)

Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following ~~dionuclides: K.r 87 , K.r 88 , Xe 133 , Xe 133m, Xe 135 , Xe 135 m, and Xe 138 for gaseous emissions and Mn54 Fe59 Co 58 Co 60 Zn65 Mo 99 Cs 134 Cs 137 Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported.

NOTE 3: Sampling and analysis shall also be performed following shutdown, starH1p, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when:

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

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

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

NOTE 5: Samples shall be changed at least once per seven days and analyses shaU 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 ch1mging. When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

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

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

NOTE 6: To be representative of the qua,ntities,andconcentrations ofradioactive materials in gaseous effluents, composite sampling shall employ appropriate methods that will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 21 PAGE 56 OF 76 ATTACHMENTS (Page 1 of 2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT :OPERABLE ACTION CHANNELS

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor~ Providing Alarm and Automatic Termination of Release:

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

Continuous HP Sampler, or 1-0W-RM-130-1 (NOTE 1) 1 2 In-Line Particulate/ Iodine Sampler (c) Particulate Sampler:

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

(d) Process Vent Flow Rate Monitor:

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

HP Sampler Rotometer or MGPI Flow Rate Measuring 1 3 Device

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

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

Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-lB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-lB 1 3

3. VENTILATION VENT SYSTEM (a) Noble Gas Activity Monitor:

SRF: RRM-101 1 1 SPS: Vent #1, 1-VG-RM-104 1 1 Vent #2, 1-VG-RM-13 lB 1 1 (b) Iodine Sampler:

SRF: RRM-101 1 2 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP.Sampler, or 1-VG-RM-131-1 (NOTE 1) . 1 2

,;i In-Line Particulate/ Iodine Sampler

DOMINION VPAP-2103S REVISION21 PAGE570F76 ATTACHMENT 5 (Page 2 of2)

Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler:

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

SRF: Ol-R!N-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 1 3 Vent #2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device:

SRF: RRM-101 I 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) I 1 3 Vent #2, HP Sampler Rotometer or 1' 3 MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components ..

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

ACTION 1: If the number of operable channels is less than required; effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity within 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months . When the effluent release via this pathway continues,then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4}

ACTION 2: Ifthe number of operable channels is less than required, efflueµt releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4).

[Commitment 3.2.4)

ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

DOMINION VPAP-2103S REVISION 21 PAGE580F76 ATTACHMENT 6 (Page 1 of2)

Radioactive Gaseous Effluent Monitor.ing Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL DESCRIPTION CHECK CHECK CALIBRATION FUNCTIONALTEST

1. PROCESS VENT SYSTEM (a) Noble Gas Activity Monitor-Providing Alarm and Automatic Termination of Release 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1)

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

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

2. CONDENSER AIR EJECTOR: SYSTEiv ;

(a) Gross Activity Monitor .

Unit 1: 1-SV-RM-111 D M* R Q Unit 2: 2-SV-RM-211 (b) Air Ejector Flow Rate Measuring Device ..

Unit 1: 1-VP-FI-lA 1-VP-FI-lB Unit 2: 2-VP-FI-lA D NIA R NIA 2-VP-FI-lB

3. VENTILATION VENT SYSTEM

(a) Noble Gas Activity Monitor SRF: RRM-101 SPS: 1-VG-RM -l31B D M R Q 1-VG-RM-104

DOMINION VPAP-2103S REVISI0N2l PAGE 59 OF76 ATTACHMENT 6 (Page 2 of2)

Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST (b) Iodine Sampler (NOTE 1)

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

SRF: RRM.-101 SPS: Vent #1, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine i Sampler

,(d) Ventilation Vent Flow Rate Monitor SRF:01-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 Vent #2, 1-VS-FT-116 D NIA R NIA (e) Sampler Flow Rate Measuring Device (NOTE 1)

SRF: RRM-101 D NIA R NIA SPS: Vent #1, 1-VG-RM-104 D NIA R NIA Vent #2, HP Sampler Rotomete1 D NIA R NIA or MGPI Flow Rate Measuring Device D NIA SA NIA NOTE 1:The mark numbers listed above in l(b),, l(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor or monitor skid with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed m~k numbers do not refer to the particulate radiation monitor.

DOMINION VPAP-2103S REVISI0N21 PAGE 60 OF 76 ATTACHMENT 7 (Page 1 of 1)

Dispersion and Deposition Factors Distance, Ventilation Vent Process Vent Description Sector meters X/Q D/Q XJQ D/Q N , 500 l.4E-05 1.6E-08 6.5E-08 9.8E-I0 NNE 532 l.8E-05 3.2E-08 l.8E-07 3.0E-09 NE 629 l.3E-05 3.0E-08 2.3E-07 3.9E-09 ENE 806 7.4E-06 l.3E-08

l.9E-07 2.8E-09 E 1210 2.7E-06 7.2E-09 2.3E-07 2.6E-09 ESE 1984 8.6E-07 3.2E-09 1.5E-07 l.7E-09 SE 1371 2.0E-06 6.8E709 l.8E-07 2.5E-09 SSE 919 4.0E-06 9.2E-09 2.IE-07 2.6E-09 Site Boundary s 645 5.5E-06 1.IE-08 . 2.2E-07 3.SE-09 SSW 565 7E-06 l:2~:08 l.9E-07 3.9E-09 SW 548 9.0E-06 l:9E-08 2.2E-07 4.2E-09 WSW 565 7.6E-06 . 1.6E-08 *2.4E-07 4.6E-09 w 565 l.lE-05 2.9E-08 2.4E-07 3.8E-09 WNW 565 1.4E-05 2.7E-08 l.4E-07 l.6E-09 NW 581 l.3E-05 l.7E-08 2.0E-07 2.9E-09 NNW . 581 l.OE-05 1.IE-08 7.4E-08 7.lE-10 N 6534 2.6E-07 2.IE-10 6.0E-08 l.lE-10 NNE

3122 l.OE-06 l.7E-09 I.7E-07 5.9E-I0 NE 7564 2.9E-07 4.2E-10 5.9E-08 2.0E-10 SE 4554 3.2E-07 8.5E-10 6.2E-08 3.2E-10 SSE 4265 3.5E-07 6.6E-I0 7.IE-08 3.3E-10 s 2736 5.2E-07 9.5E-I0 l.SE~07 7.5E-10 Resident SSW 2977 3.7E-07 7.5E-10 1:0E-07 5.7E-10 SW 3637 4.lE-07 7.8E-10 8.6E-08 4.3E-I0 WSW 660 5.9E-06 l.3E-08 2.3E-07 4.IE-09 w 5053 3.2E-07 7.2E-10 6.2E-08 2.5E-10 WNW 7886 2.3E-07 2.9E-I0 4.4E-08 1.IE-10 NW 7467 2.5E-07 2.2E-I0 5.0E-08 1.5E-I0 NNW 6035 2.6E-07 2.0E-10 5.7E-08 1.0E-10 SSW 7693 9.2E-08 1.4E-I0 4.0E-08 l.3E-I0 Milk Animal NNW 5938 2.6E-07 2.lE-10 5.8E-08 l.OE-10 SSE 4265 3.5E-07 6.6E-I0 7.lE-08 3.3E-10 s 3235 4.0E-07 7.IE-10 1.3E-07 5.6E-I0 SSW 3122 3.SE-07 6.9E-~ 9.7E-08 5.2E-I0 Garden SW 7596 l.4E-07 2.lE- 4.IE-08 1.4E-10 WSW 5713 l.9E-07 3.2E-10 5.6E-08 2.2E-I0 w 5536 2.&E-07 6.IE-10 5.8E-08 2.2E-10 NNW 7017 2.IE-07 l.6E-10 4.9E-08 9.3E-ll

DOMINION VPAP-2103S REVISI0N2l PAGE 61 OF76 ATTACHMENT 8 (Page I of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis I. DIRECT RADIATION About 40 Routine Monitoring

Stations to be placed as fol-

.lows:

1) Inner Ring in general area of site boundary with GAMMA DOSE station in each sector

2) Out.er Ring 6 to 8 km from the site with a station in Quarterly Quarterly each sector (NOTE 1) 3} The balance of the 8 dosimeters should be piaced in special interest I' areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest calculated Radioiodine Canister annual average ground I 131 Analysis Weekly level Continuous Radioiodines and D/Q

Sampler Particulates b) 5 sampJe locations 6-8 km operation with Particulate Sampler distance located in a sample collection Gross beta radioactivity concentric ring around the weekly. analysis following filter Station change; c) 1 sample from a control Gamma isotopic analysis of location 15-30 km distant, composite (by providing valid location) quarterly background data NOTE 1: As described in the Br~nc~,T~Ph.nical Po_sition, Revfaion 11 November 1979, no TLD station is required in the SE; sector at the 4-5 mile raqge: due .to geogr!lphical limitations ..

DOMINION VPAP-2I03S REVISION 21 PAGE 62 OF 76 ATTACHMENT 8 (Page 2 of 3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and CollectiQn Type and Frequency of and/or Sample Sample Location Frequency Analysis

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

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and I 131 b) 1 sample from milking Monthly animals at a control analysis monthly location (-15-30 kmfroin the station). (NOTE 2) a) 6 samples of filter feeders

( clams, oysters) in the Semi-Annually b) Fish and vicinity of the Station Gamma isotopic on edible Invertebrates c) 1 sampling of crabs from Annually pory:ions the vicinity of the Station d) 1 sa.mpling of 2 different species in vicinity of Semi-Annually Station discharge area.

(NOTE3)

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

NOTE 2: If milk sampling from a control location cannot be pe~foirn~d; use rtein 4:c) e).

Milk sampling cannot be performed when th~re is rio'milksamplii:iiiocatiori,..:, 15 - 30 km from the station.

NOTE 3: Commercially or recreationally important species permitted for sampling by the Virginia Marine Resources

.DOMINION VPAP-2103S REVISI0N21 PAGE63 OF76 ATTACHMENT 8 (Page3 of3)

Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample *. Sample Location Frequency Analysis

4. INGESTION (Continued)

a) 1 sample com Annually, at time Gamma isotopic on edible b) 1 sample soybeans of harvest (for portions

.. c) 1 sample peanuts harvested crops) d) 1 sample of a broadleaf vegetation grown nearest in each of two

.' different available offsite locations (sectors) with the ;

c) Food Products highest annual average ground level D/Qs, if

Monthly, if .

Gamma isotopic and r131 milk sampling is not ;

available, 6r at

. analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 -

30 km distant in the available least prevalent wind direction, if milk sampling is not . I performed.

DOMINION VPAP-2103S REVISION21 PAGE640F76 ATTACHMENT 9 (Page 1 of3)

. Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Air Charcoal and Surry Station (SS) 0.3 NNE Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW I

Alliance (ALL) 5.1 WSW, Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite

TLDs West North West (02) 0.2 *WNW Site Boundary Surry Station Discharge 0.4 'NW Site Boundary (03)

North North West (04) . 0.2 NNW Site Boundary North ,_

(05) 0.3 N Site Boundary North North East (06)

0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 .. ENE Site Boundary East (09) 0.3 E Site Boundary West (10) 0.1 w Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) ' 0.4 s Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) 1.6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103S REVISION 21 PAGE 65 OF76 ATTACHMENT 9 (Page 2 of 3)

Environmental Sampling Locations r

SAMPLE

LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (24) 4.0 w Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway . (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 ' N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles

Budweiser (32) 5.8 NNE Population Center Water Plant .(33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. ? miles Lee Hall (35) 7.1 ENE Population Center ~

GoQse Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5, miles Newport News (38) 19.3 *'

SE Population Center James River Bridge (39) 17.1 SE Control Location Benn's Church (40) 17.0 SSE Control Location Smithfield (41) 13.4 SSE Control Location Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 s Approx. 5 miles Milk Epps 4.8 SSW Colonial Parkway , 3.7. *,. *.NNW Beachy Farm 12.0 SW Control Location

DOMINION VPAP-2103S REVISION 21 PAGE 66 OF76 ATTACHMENT 9 (Page 3 of3)

Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES)

Well Water Surry Station 0.1 SW* Onsite**

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

Crops (Com, Peanuts, Slade's Farm 3.2 s Soybeans) Brock's Farm 3.8 s River Water Surry Station Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 0.5 NW Sample Collected in Surry Station Intake 1.8 ESE Channel Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Jamestown Island 3.9 NW Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Swash Hole Island 6.8 SE Crabs Surry StatioD: Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve

0.6 N Sediment

Chickahominy River * .11.2 WNW Control Location

Onsite Location - in Lead Shield

- Onsite sample of Well Water taken from tap-water at Surry Environmental Building

- - Onsite sample of Well \Vater taken from tap-water at Surry Trnining Center

DOMINION VPAP-2103S REVISION 21 PAGE 67 OF76 ATTACHMENT 10 (Page 1 of2)

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

Analysis Water Airborne Fish Milk Food Sediment (NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (wet) (pCi/kg) (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 (NOTE 3) 1 0.07 1 60 Cs-134 15 0.05 130 ... ; 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15

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

NOTE 2: This list does not mea~ that only these nuclides are to pe 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 ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L.

DOMINION VPAP-2103S REVISION 21 PAGE 68 OF 76 ATTACHMENT 10 (Page 2 of2)

Detectio;n Capabilities for Environmental Sam pl~ Analysis LOWER LIMIT OF DETECTION (LLD)

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

LLD (24-1)

E

V

2.22E+06

Y

e-(A.M).

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) .

the standard deviation of the background counting rate or ofthe 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)

X the radioactive decay constant for the particular radionuclide Llt 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 Llt should be used in the calculation.

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

DOMINION VPAP-2103S REVISION 21 PAGE 69 OF76 ATTACHMENT 11 (Page 1 of 1)

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

Gases (pCifm3)

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 I-131 2*'

b.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

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

'..I:.

DOMINION VPAP-2103S REVISION 21 PAGE 70 OF 76 ATTACHMENT 12 (Page 1 of 7)

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

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

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

ventilation vent), and those ch?,racterized as mixed mode (i.e., process vent).

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

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

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

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

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

DOMINION VPAP-2103S REVISI0N21 PAGE 71 OF76 ATTACHMENT 12 (Page 2 of7)

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

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

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

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

2.0 LIQUID PATHWAYANALYSIS 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 Hquid effluent releases: The analysis included a determination of most restrictive liquid pathw~y~ most restrictive age group, and critical organ. This ana.'lysis is required for Subsection 6.i, Liquid Radioactive Waste Effluents.

2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station 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-1276.

Liquid radioactive effluents from both units are released to, the James River via the discharge canal. Possible pathways of exposure for release from the.Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream .as 4Ie ins,hore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months per year, and that bank fishing would be performed a maximum of 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months per year.

DOMINION VPAP-2103S REVISION 21 PAGE 72 OF 76 ATTACHMENT 12

. (Page 3 of 7)

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

2.3 Results Fortheyears 1976, 1977, 1979, 1980,and 1981, th~invertebratepathwayresultedi11;thelargest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed m.ember of the public was determined to utilize the James River. The critical age group was the adult and

' ... the critical organ was eith~r the thyroid or GI-LLI. The' ingestio~ dose factors, which include tµe fish and inv~rtebrate p~thways, are calc~late'd for total body and v;rious critical organs.

Validation of the limiting ag*e group and critical organ i~ performed by the liquid effluent dose calculation program using the data, par~meters, and methodology provided in the Source Code file.

3.0 GASEOUS PATHWAY ANALYSIS 3.1 . Purpose Gaseous effluent pathway. analyses are performed t9 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 analyses includes a determination of the location, pathway, and critical orgari,'ofthe maximum exposed member of the public, as a result of the release ofI 131 ,

I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical 'organ, 'maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131 , I 133 , tritium, and particulates to demonstrate compliance 'with Step 6 .3. I .a.

I.

DOMINION VPAP-2103S REVISION21 PAGE 73 OF76 ATTACHMENT 12 (Page 4 of7)

Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology Five year average X/Q values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for.gamma and beta radiation due to noble gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose.

6.3.1.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X/Q values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 ; I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway.

The maximum exposed individual for 10 CFR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk animal, or nearest vegetable garden, using the Land Use Census data which is assessed annually. Therefore, ventilation vent and process vent X/Q and D/Q values forthese selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, milk, and vegetable garden pathways are active with the exception of the. infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology ofR. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses.

The gamma and beta dose factors Kivv, Livv, Mivv, and Nivv for ground level releases and the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode rel~ases are included in the Source Code file.

Inhalation pathway dose. factors Pivv and Pipv are calculated using the following equation:

mrem/yr per Ci/m3 (28-1) where:

K' a constant of unit conversion, IE+ 12 pCi/Ci

. BR =the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.I DF Ai the critical organ inhalation dose factor for particular age group for the ith radionuclide,. in mrem/pCi

DOMINION VPAP-2103S REVISI0N21 PAGE 74 OF 76 ATTACHMENT 12 (Page 5 of 7)

)Yleteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-QI33 and R.G'. LI09, Rev. 1.

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

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

RM.1 (28-2) where:

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

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

Uap= infant milk consumption rate, 330, in liters/yr Yp = agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Ys = agricultural productiyity by unit area of stored feed, 2.0, in kg/m2 Fm = stable element transfer coefficients, in days/liter r = fraction of deposited activity retained on milk animal's feed grass, .1.0 for radio iodine, and 0.2 for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, inmrem/pCi Ai = decay constant for the ith radionuclide, in sec-1 Aw = decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life)*

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

fp = fraction of year that milk animal is on pasture; 1:0 (difuensionless) fs = fraction of milk animal feed that is pasture grass while milk animal is on pasture, 0.8 (dimensionless)

DOMINION VPAP-2103S REVISI0N21 PAGE 75 OF76 ATTACHMENT 12 (Page 6 of7)

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

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

(28-3) where:

K" a constant of unit conversion 1E+03 gm/kg H absolute humidity of the atmosphere, 8.0, in gm!m3 0.75 the fraction of total feed that is water 0.5 the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined.

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

mrem/yr per Ci/m3 (28-4) where:

K' a constant of unit conversion, IE+ 12 pCi/Ci, BR breathing rate of the particular age group, m3 /yr , ,

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

DOMINION VPAP-2103S REVISION21 PAGE 76 OF 76 ATTACHMENT 12 (Page 7 of7)

Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used abov:e were obtained from NUREG-0133 and R. G. l.109, Rev. 1.

Breathing Rate Infant 1400 m 3/yr Child 3700 m 3/yr Teen = 8000 m 3/yr Adult = 8000 m 3/yr The RG dose factors are calculated using the following equation:

1 2 1 - e-11.i b ] ( .. m

mrem I yr )

RG = K'K" (SF)DFGi [* *.

Ai* Ci/sec 28 5 where: < - )

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

= The decay constant for nuclide i, sec- 1.

= The exposure time, 4.73xl0 8 sec (15 years), froin Table E-15 of Reg Guide l.109.

= The ground plane dose conversion factor for nuclide i, from Table E-6 of Reg. Guide 1.109 (mrem/hr per pCi/m2).

SF The shielding factor 0.7 (dimensionless), from Table E-15 of Reg Guide 1.109.

Attachment 4 Page 1 of 1 MAJOR CHANGES) TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS There were no rriajor changes to the radioactive liquid, gaseous or solid waste treatment systems for this reporting period.

Attachment 5 Page 1 of 1 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION The Annual Radioactive Effluent Release Report shall explain why monitoring instrumentation required by the ODCM Attachments 1 and 5, which were determined to be inoperable, were not returned to operable status within 30 days. None of the above referenced instrumentation were inoperable greater than 30 days during this reporting period.

Attachment 6 Page 1 of 1 UNPLANNED RELEASES There was one unplanned liquid release and no unplanned gaseous release during this reporting period.

A summary of the liquid release describe below.

On 07/03/2019, during mainten~nce activities on 2-CS-MR-lA, approximately 1.5 gallons ofRWST water leaked to the ravement from the refrigerant side of the chiller. HP-3010.023 - Unplanned Liquid Release was initiated. The c.alculated total% Tech Spec for this release is 8.23E-04. No reportability to State and Local officials or to the NRC was required by the ODCM.

Liquid Rele*ase Permit (#L-20190704-134-B) was generated to account for the activity released. Total activity released is 2.26E-04 Ci with a maximum receptor dose of 8.20E-09 mRem.

Attachment 7 Page 1 of 1 LOWER LIMIT OF DETECTION (LLD) FOR EFFLUENT SAMPLE ANALYSIS GASEOUS: Isotope Reguired LLD Typical LLD Kr-87 1.00E-04 l.52E 2.3 lE-06 Kr-88 l.OOE-04 l.75E 1.41E-06 Xe-133 l.OOE-04 1.55E 1.2IE-06 Xe-133m

1.00E-04 4.06E-05 -. 4.39E-06 Xe-135 1.00E-04 6.1 lE-05 * - 5.85E-07 Xe-135m 1.00E-04 8.92E 6.18E-06 Xe-138 l.OOE-04 9.90E l.65E-05 I-131 l'.OOE-12 4.06E-l3 - 4.06E~l3 I-133 l.OOE-10 4.06E-ll - 4.06E-1 l Sr-89 l.OOE-11 l.53E~14 .:. 3.73E-12 Sr-90 l.OOE-11 2.07E~l5 - .4.76E-13 Cs-134 l.OOE-11 2.09E 8.39E-14 Cs-137 1.00E-11 3.22E 6.75E-14 Mn-54 l.OOE-11 7.87E 1.75E-13 Fe-59 1.00E-11 6.3IE 5.07E-14 Co-58 l.OOE-11 5.79E l.97E-14 Co-60 l.OOE-11 4.32E 3.12E-14 Zn-65 l.OOE-11 7.23E 2.12E-13 Mo-99 1.00E-11 4.06E 4.06E-12 Ce-141 l.OOE-11 4.71E 2.03E-13 Ce-144 1.00E-11 2.71E 7.08E-13 Alpha l.OOE-11 l.68E l.70E-14 Tritium l.OOE-06 5.75E 1.06E-07 LIQUID: Sr-89 5.00E-08 2.88E-08 - 4.50E-08 Sr-90 5.00E-08 8.25E-09 - l.86E-08 Cs-134 5.00E-07 6.49E-08 - 8.80E-09 Cs-137 5.00E-07 l.OSE-07 - l.84E-09 I-131 1.00E-06 9.98E-08 - 2.93E-08 Co-58 5.0QE-07 7.47E-08 - 2.35E-09 Co-60 5.00E-07 8.18E-08 - 5.92E-09 Fe-59 5.00E-07 1.69E-07 5.52E-09 Zn-65 5.00E-07 2.03E-07 - 1.97E-08 Mn-54 5.00E-07 l.OlE-07 - l.94E-08 Mo-99 5.00E-07 4.95E-07 - l.66E-07 Ce-141 5.00E-07 8.19E-08 - 2.0SE-08 Ce-144 5.00E-07 4.33E-07 - l.llE-07 Fe-55 l.OOE-06 l.33E-07 - 7.91E-07 Alpha 1.00E-07 2.62E-08 - 2.65E-08 Tritium 1.00E-05 l.42E-06 - 2.63E-06 Xe-133 l.OOE-05 l.32E-07 - 9.83E-08 Xe-135 l.OOE-05 4.04E-08 - 2.09E-08 Xe-133m l.OOE-05 3.58E-07 - 2.SOE-07 Xe-135m 1.00E-05 2.lOE-06 - 6.88E-07 Xe-138 1.00E-05 6.65E-06 - 1.98E-06 Kr-87 l.OOE-05 1.76E-07 - 1.02E-07 Kr-88 1.00E-05 l.62E-07 - 1.09E-07

Attachment 8 Page 1 of 4 INDUSTRY GROUNDWATER PROTECTION INITIATIVE The following is a summary of 2019 sample analyses of ground water monitoring wells that are not a part of the Radiological Environmental Monitoring Program (REMP). ,

Well Sample , Tritium Gamma Fe-55

Ni-63 Sr-90 TRU

Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-49 1/2/19 1\300

NA NA NA NA NA 1-PL-Piez-51

1/2/19 (840 NA NA NA NA NA 1-PL-Piez-44 1/3/19 9,860 NA NA NA NA NA*

1-PL-Piez-29 1/4/19 2,390 NA NA NA NA NA 1-PL-Piez-51 1/9/19 5;120 NA NA NA NA NA 1-PL-Piez-44 . 1/9/19 6,010 NA NA NA NA NA 1-PL-Piez 1/9/19 1,020 NA NA NA NA NA l -PL-Piez-06 1/9/19 2,370 NA NA NA NA NA 1-PL-Piez 1/10/19 . 5,620 NA NA NA NA NA l-PL-Piez-51 1/24/19 4,190 NA NA. 'NA NA NA l-PL-Piez-44 1/24/19 5;940 NA NA 'NA, NA - NA 1-PL-Piez-44

1/28/19 6,130 NA- NA NA NA NA 1-PL-Piez-51 . 1/28/19 {010 NA NA . NA NA NA 1-PL-Piez-29

2/1/19 2,880 NA NA .. NA NA NA l-PL-Piez-49 '2/5/19

11,500 ND <85.2 * <4.56 , <0.450 NA

1-PL-Piez-29 2/5/19. 1,910 ND <92.3. <3.68 <0.591 NA 1-PL-Piez-51 2/6/19 6,530 ND <151 .. <3.89 <0.593 NA-1-PL-Piez-44 2/7/19 6;190 NA NA .. NA NA NA 1-PL-Piez-06 2/12/19 1,490. ND <42:0 *. <4.27 <0.729 NA 1-PL-Piez-51 2/15/19 3,160 . NA NA NA NA NA 1-PL-Piez-44 2/15/19 6,320 NA NA. NA NA NA 1-PL-Piez-05

2/19/19., 6,030 ND <38.6 * <4.52 <0.682 NA ..

1-PL-Piez-44 2/20/19 5,800 NA NA ,, 'NA NA NA 1-PL-Piez-51 2/20/19 3,620 NA NA . NA NA NA 1-PL-Piez-49 2/21/19 14,700 NA NA NA NA NA 1-PL-Piez-29 2/21/19 2,490 NA NA NA NA NA 1-PL-Piez-51

2/25/19 3,590 NA NA NA NA *NA 1-PL-Piez-51 2/27/19. 3,800 NA NA. NA NA *NA 1-PL-Piez-44 2/28/19 4,060 ND <78.7 <4.33 <0.589 NA 1-PL-Piez-51 2/28/19 3,490

NA NA. . NA NA NA 1-PL-Piez-44 3/7/19 12,100 NA NA. NA NA NA 1-PL-Piez-49 3/7/19. 11,100 NA NA NA NA. . NA 1-PL-Piez-:-51 :3/7/19,,, -, c3i;'.Z80,, J':,JA NA NA ;NA NA NA = Analysis not required.

ND = No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs.

TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238, Pu-239/240 and Pu-241)

Attachment 8 Page 2 of 4 INDUSTRY GROUND WATER PROTECTION INITIATIVE Well Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter l-PL-Piez-29 3/7/19 2,380 NA NA NA NA NA

.1-PL-Piez-44 3/11/19 4,000 . NA NA NA NA NA 1-PL-Piez-51 3/11/19 .J,450 NA NA*. NA . NA NA 1-PL-Piez-49 3/19/19 . 8,910 NA NA NA NA NA 1-PL-Piez-51 3/19/19 3,750 NA NA NA NA NA 1-PL.:.Piez-29 3/19/19 2,330 NA NA NA NA NA 1-PL-Piez-44

3/20/19 3,930 NA NA NA* NA NA*

1-PL-Piez-45 3/20/19 .980 NA NA NA NA NA 1-PL-Piez-05 3/27/19 6,430 NA NA NA NA NA 1-PL-Piez-06 3/28/19 1,510

NA NA* NA NA NA 1-PL-Piez-51 . 3/28/19 3;150

NA. NA. NA . NA NA 1-PL-Piez-44 3/29/19 3,840. NA* NA NA NA NA 1-PL-Piez-51 4/3/19 3;660 NA . NA NA NA NA 1-PL-Piez-44 4/3/19 4;320 . NA NA NA NA NA 1-PL-Piez-29 4/3/19 2,120 . NA NA' NA NA NA 1-PL-Piez-49* 4/3/19 .12,200 NA NA* NA NA NA 1-PL-Piez-44 4/8/19 .. 3,280 NA NA NA NA NA l-PL-Piez-51 4/8/19 4,300 NA NA NA NA NA l-PL-Piez-51 4/15/19 4,510* NA NA NA NA NA 1-PL-Piez-46 4/15/19 . <,673

NA NA NA

NA NA 1-PL-Piez-29 4/15/19 2;460 NA NA NA NA NA 1-PL-Piez-06 4/16/19 1,930 NA* NA .. NA NA NA 1.-PL-Piez-43 4/16/19 <687 NA NA NA NA NA 1-PL-Piez-44 4/17/19 5,350. NA NA NA NA NA 1-PL-Piez-05 4/17/19 6,350 NA NA NA NA NA 1-PL-Piez-47 4/17/19 1,220 NA NA NA

NA NA 1-PL-Piez-45 4/18/19 1,780 NA NA NA NA NA 1-PL..,Piez-42 4/18/19 <640 NA* NA NA NA NA 1-PL-Piez-44 4/22/19 4;420 NA NA' NA NA NA 1-PL-Piez-51 4/22/19 3;590 NA NA NA NA NA 1-PL-Piez-44 4/29/19 4,260 NA NA NA NA NA l-PL-Piez-51 4/29/19 4,300 NA NA NA NA NA 1-PL-Piez-29 4/29/19 2,350. NA** NA NA NA NA NA == Analysis not required. ' **

ND = No non-natural gamma emitting nuclides detectid \Vlienianaiyzed to REMP LLDs.

TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238, Pu-239/240 and Pu-241)

Attachment 8 Page 3 of 4 INDUSTRY GROUND WATER PROTECTION INITIATIVE Well Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Designation. Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter G-5 5/21/19 3,900 NA NA

NA NA NA G-6 5/21/19 17,000 NA NA NA NA NA G-8 5/21/19 37,700 NA NA , NA NA NA l-PL-Piez.,44 6/10/19 5,325 NA NA 'NA NA NA 1-PL-Piez-49 6/10/19 16,600 NA NA NA NA NA 1-PL-Piez-51 6/10/19 . 2,505 NA NA NA NA NA G-8 6/10/19

28,300 NA NA NA NA NA 1-PL-Piez-44 6/21/19 3,710 NA NA NA NA NA l-PL-Piez-49 6/21/19 1,510 NA NA NA NA NA 1-PL-Piez-51 6/21/19 3,800 NA NA NA NA NA G-8 6/21/19 32,400 NA NA NA NA NA 1-PL-Piez-44 7/1/19 3,030 NA NA NA NA NA 1-PL-Piez-49 7/1/19 . 2,480 NA NA NA NA NA 1-PL-Piez-51 7/1/19 . 3,910 NA NA NA NA NA G-8 7/1/19 31,000 NA NA NA NA NA 1-PL-Piez-51 7/14/19 1,790 NA NA *.NA NA NA 1-PL-Piez-49 . 7/14/19 2,160 NA NA NA NA NA 1-PL-Piez-44 7/14/19 2,480 NA NA NA NA NA G-8 7/15/19 40,500 NA NA NA NA NA G-6 7/15/19 14,000 NA NA

NA NA NA G-8 7/22/19 1,400 NA NA .. NA NA NA 1-PL-Piez-49 7/28/19 3,090 NA NA *.NA* NA NA 1-PL-Piez-51 7/28/19 4,180 NA NA NA NA NA 1-PL-Piez-44 7/28/19 3,130 NA NA. NA NA NA G-6 7/29/19 14,200 NA NA .. .NA NA NA G-8 8/1/19 2,350 NA NA ** .NA NA NA.

G~8 8/12/19 2,550 NA NA NA NA NA 1-PL-Piez-29 8/12/19 1,310 ND NA . NA NA NA 1-PL-Piez-49 . 8/12/19 5,320 ND NA . NA NA NA 1-PL-Piez-51 8/i2/19 4,120 *. ND NA :'NA NA NA 1-PL-Piez-47 8/16/19 1,240 ND NA . NA NA NA G-8 8/22/19 2,490 ND NA NA NA NA 1-PL-Piez-51 8/22/19 4,280 ND NA NA NA NA 1-PL-Piez-6 8/26/20 1,120 ND NA NA NA NA 1-PL-Piez-5 8/27/20 4,610 ND NA NA NA NA 1-PL-Piez-51 8/27/19 3,820

NA NA NA .NA NA G-8 8/27/19 2;970 NA NA NA NA NA 1-PL-Piez-51 9/13/19 2,960 NA NA NA NA NA G-8 9/13/19 18,100 NA NA NA NA NA NA = Analysis not required.,

ND = No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs.

TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238, Pu-239/240 and Pu-241)

Attachment 8 Page 4 of 4 INDUSTRY GROUND WATER PROTECTION INITIATIVE Well Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Designation Date:* pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-44 9/13/19 70,600 NA NA NA NA NA G-8 9/27/19 2,810 NA NA NA* NA NA

1-PL-Piez-44 9/27/19 11,500 NA NA NA* NA NA

1-PL-Piez-51 9/27/19 4,010 NA NA NA 'NA NA 1-PL-Piez-49 10/2/19 *

6,800 NA NA NA. NA NA G-6 10/3/19 12,700 NA NA NA NA NA G-8 10/3/19 , 7,680 NA NA NA NA NA

. 1-PL-Piez-44 . 10/11/19 4,030 NA NA . NA NA NA 1-PL-Piez-49 10/11/l9 2,590 NA NA NA NA . NA 1-PL-Piez-51 10/11/19 3,490 NA NA NA NA NA G-6 10/11/19 12,600 NA NA NA NA NA G-8 10/17/19

13,400 NA NA NA , NA NA 1-PL-Piez-49 10/23/19 2,140 NA NA .NA .NA NA 1-PL-Piez-51 10/23/19 3,290 NA .NA NA NA. NA 1-PL-Piez-44 10/23/19 2,710 NA NA NA

NA NA G-8 10/23/19 2,620 NA *NA NA NA NA 1-PL-Piez-6 11/11/19 753 ND ND ND ND NA 1-PL-Piez-44 11/13/19. ' 6,230 ND ND ND ND NA 1-PL-Piez-45 11/13/19 970 ND. ND ND ND NA 1-PL-Piez-29 11/13/19 1,790 ND ND ND ND NA 1-PL-Piez-51 11/20/19

4,610 ND ND ND ND NA 1-PL-Piez-46 11/21/19 <629 ND ' ND ND ND NA 1-PL-Piez-49 11/21/19 1,870 Nb *,ND ND ND NA G-8 11/25/19

1,530 NA NA NA NA NA 1-:PL-Piez-44 11/25/19 3,360 NA **NA NA

NA NA 1-PL-Viez-51 11/25/19 3,710 NA .NA NA NA NA 1-PL-Piez-49 11/25/19 2,530 NA* NA NA NA NA 1-PL-Piez-44 11/25/19 . 26,600 NA NA NA NA NA 1-PL-Piez-47 11/26/19 1,680 ND. ND *.ND ND NA 1-PL-Piez-51 12/6/19 2,080 NA NA ; NA NA NA G-8 12/6/19 7;600 NA NA

NA *NA NA NA = Analysis not required. . .

ND = No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs.

TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238, Pu-239/240 and Pu-241)

' . '

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