Text

2008 Annual Radioactive Effluent Release Report
	ML091610594
Person / Time
Site:	Callaway
Issue date:	04/30/2009
From:	Sandbothe S; AmerenUE
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ULNRC-05621
	Download: ML091610594 (197)
	v • d • e

AmerenUE PO Box 620 Cal/away Plant Fulton, MO 65251 April 30, 2009 ULNRC-05621 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:

~~ DOCKET NUMBER 50-483 wAmeren CALLAWAY PLANT UNIT 1 UE UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 2008 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Please find enclosed the 2008 Annual Radioactive Eflluent Release Report for Callaway Plant; APA-ZZ-O 1003, "Offsite Dose Calculation Manual"; Callaway FSAR-Standard Plant Chapter 16.11 - Offsite Dose Calculation Manual-Radioactive Eflluent Controls; and FSAR-Standard Plant Summary of Change Notice FSAR 08-019 showing the changes to the FSAR-Standard Plant Chapter 16.11. These documents are submitted in accordance with Sections 5.6.3 and 5.5.1 of the Technical Specifications.

If there are any questions, please contact us.

Sincerely, Scott Sandbothe Manager, Regulatory Affairs DJW/nls Attachments: 1. Annual Radioactive Eflluent Release Report

2. APA-ZZ-01003, "Offsite Dose Calculation Manual"

3. Callaway FSAR-Standard Plant Chapter 16.11-0ffsite Dose Calculation Manual-Radioactive Effiuent Controls

4. Callaway FSAR-Standard Plant Summary of Change Notice FSARCN 08-019 a subsidiary of Ameren Corporation

ULNRC-05621 April 30, 2009 Page 2 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator US. Nuclear Regulatory Commission Region IV 612 E . Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office US. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738 Mr. Edward Everett ANI Account Engineer 95 Glastonbury Glastonbury, CT 06033 Regional Administrator Department of Natural Resources Central Regional Office P. O. Box 176 Jefferson City, Missouri 65102-0176

ULNRC-05621 April 30, 2009 Page 3 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed. )

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

A. C. Heflin F. M. Diya T. E. Herrmann L. S. Sandbothe S. A. Maglio S. L. Gallagher T. L. Woodward (NSRB)

L. M. Belsky (NSRB)

T. B. Elwood D. J. Walker R. J. Wishau Ms. Diane M. Hooper (WCNOC)

Mr. Dennis Buschbaum (TXU)

Mr. Scott Bauer (Palo Verde)

Mr. Stan Ketelsen (PG&E)

Mr. Wayne Harrison (STPNOC)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission to ULNRC-05621 Attachment 1 Annual Radioactive Effluent Release Report to ULNRC-05521 Page 1 of 45 2008 Radioactive Effluent Release Report Docket no. 50-483 1

to ULNRC-05521 Page 2 of 45 TABLE OF CONTENTS

1.0 INTRODUCTION

3 2.0 SUPPLEMENTAL INFORMATION.. 4 2.1 Regulatory Limits.4 2.2 Average Energy 5

2.3 Measurements and Approximations of Total Radioactivity....5 2.4 Batch Releases. 6 2.5 Abnorm al Releases.. 7 3.0

SUMMARY

OF GASEOUS RADIOACTIVE EFFLUENTS.

8 4.0

SUMMARY

OF LIQUID RADIOACTIVE EFFLUENTS. 9 5.0 SOLID WASTES. 10 6.0 RELATED INFORMATION... 10 6.1 Unplanned Releases. 10 6.2 Changes to the Offsite Dose Calculation Manual 11 6.3 Major Changes to Radwaste Treatment Systems11 6.4 Land Use Census Changes..12 6.5 Inoperability of Effluent Monitoring Instrumentation.12 6.6 Instances of Liquid Holdup Tanks or Waste Gas Decay Tanks Exceeding Technical Specification Limits..13 7.0 METEOROLOGICAL DATA.13 8.0 ASSESSMENT OF DOSES14 8.1 Dose at the Site Boundary from Gaseous Effluents.14 8.2 Dose to the Member of the Public15 8.3 Total Dose Due to the Uranium Fuel Cycle.

15 8.4 Dose Due to Liquid Effluents.. 16 List of Tables 1A Annual Summation of Gaseous Releases 1B Annual Airborne Continuous and Batch Releases 2A Annual Summation of Liquid Releases 2B Annual Liquid Continuous and Batch Releases 3 Solid Waste and Irradiated Fuel Shipments 4 Cumulative Joint Frequency Distributions 5 Dose at the SITE BOUNDARY and Nearest Resident 6 Dose to the Member of the Public from Activities within the SITE BOUNDARY 2

to ULNRC-05521 Page 3 of 45 7 Total Dose Due to the Uranium Fuel Cycle 8 Dose Due to Liquid Effluents

1.0 INTRODUCTION

This report describes the AmerenUE (Union Electric Co.) Callaway Plant radioactive effluent releases for 2008. It is submitted in accordance with Section 5.6.3 of the Callaway Plant Technical Specifications.

A summary of radioactivity released in liquid and gaseous effluents and solid waste shipped from the Callaway Plant during the period from January 1, 2008 to December 31, 2008 is presented.

All liquid and gaseous effluents discharged during this reporting period complied with federal regulations and the limits in the Offsite Dose Calculation Manual (ODCM).

3 to ULNRC-05521 Page 4 of 45 2.0 SUPPLEMENTAL INFORMATION 2.1 REGULATORY LIMITS The Radiological Effluent Control (REC) limits applicable to the release of radioactive material in liquid and gaseous effluents are provided below.

Fission and Activation Gases (Noble Gases)

The dose rate due to radioactive noble gases released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to 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 air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the site boundary shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation and,

b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

Radioiodine, Tritium, And Particulates The dose rate due to Iodine-131 and 133, tritium and all radionuclides in particulate form with half-lives greater than eight (8) days released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 1500 mrem/yr to any organ.

The dose to a Member of the Public from Iodine-131 and 133, tritium, and all radionuclides in particulate form with half-lives greater than eight (8) days in gaseous effluents released to areas at and beyond the site boundary shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrem to any organ and,

b. During any calendar year: Less than or equal to 15 mrem to any organ.

Liquid Effluents 4

to ULNRC-05521 Page 5 of 45 The concentration of radioactive material released in liquid effluents to unrestricted areas shall be limited to 10 times the concentrations specified in 10 CFR 20 Appendix B To Part 20, Table II, Column 2 (Effluent Concentrations) for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.0E-04 microcuries/ml total activity.

The dose or dose commitment to an Individual from radioactive materials in liquid effluents released to unrestricted areas shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and less than or equal to 5 mrem to any organ, and

b. During any calendar year to less than or equal to 3 mrem to the whole body and to less than or equal to 10 mrem to any organ.

Uranium Fuel Cycle Sources The annual (calendar year) dose or dose commitment to any Member of the Public due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrem to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

2.2 AVERAGE ENERGY This requirement is not applicable to the Callaway Plant radiological effluent monitoring program since the release rate limits for fission and activation gases in gaseous effluent are not based on the average energy of the radionuclide mixture.

2.3 MEASUREMENTS AND APPROXIMATIONS OF TOTAL RADIOACTIVITY Radionuclide concentrations in liquid and gaseous effluents were obtained by effluent sampling and radiological analysis in accordance with the requirements of Final Safety Analysis Report Table 16.11-1 and Table 16.11-4.

Gamma spectroscopy was the primary analysis technique used to determine the radionuclide composition and concentration of liquid and gaseous effluents.

Composite samples were analyzed for Sr-89, Sr-90, Fe-55, Ni-63 and transuranic 5

to ULNRC-05521 Page 6 of 45 nuclides by an independent laboratory. Tritium and gross alpha were measured for both liquid and gaseous effluents using liquid scintillation counting and gas flow proportional counting techniques, respectively.

The total radioactivity in effluent releases was determined from the measured concentrations of each radionuclide present and the total volume of effluents discharged.

2.4 BATCH RELEASES Summary information relating to batch releases of gaseous and liquid effluents to the environment from the Callaway Plant during the year 2008 is presented below.

Liquid UNITS JAN- JUL-JUN DEC Number of ---- 23 47 batch releases:

Total time Minutes 13,393 25,836 period for batch releases:

Maximum time period for Minutes 1,666 1,248 batch releases:

Average time Minutes 582 550 period for batch releases:

Minimum time 378 93 period for Minutes batch releases:

Average ft3/sec 136,640 100,023 Missouri River 6

to ULNRC-05521 Page 7 of 45 flow during 2008 1:

Gaseous UNITS JAN - JUL -

JUN DEC Number of batch ---- 34 31 releases:

Total time Minutes 3,131 12,261 period for batch releases:

Maximum time period for batch Minutes 924 2,943 releases:

Average time Minutes 92 396 period for batch releases:

Minimum time period for batch Minutes 28 25 releases:

2.5 ABNORMAL RELEASES Liquid Number of releases: 0 Total Activity released: 0 Gaseous Number of releases: 0 Total Activity released: 0 1 http://waterdata.usgs.gov, United States Department of Interior - U.S. Geological Survey - USGS Surface Water Daily Data 06934500.

7 to ULNRC-05521 Page 8 of 45 3.0

SUMMARY

OF GASEOUS RADIOACTIVE EFFLUENTS The quantity of radioactive material released in gaseous effluents during the year is summarized in Tables 1A and 1B. During 2008, all gaseous effluents were considered as ground level releases.

Gaseous effluents from the plant are continuously monitored. Shown is instrumentation to provide on-line and grab sampling for iodine, particulates and noble gas.

8 to ULNRC-05521 Page 9 of 45 4.0

SUMMARY

OF LIQUID RADIOACTIVE EFFLUENTS The quantity of radioactive material released in liquid effluents during the year is summarized in Tables 2A and 2B. During 2008, there was no continuous release of liquid effluent from the plant.

Liquid effluent releases from the plant are continuously monitored. Shown is a liquid radiation monitor shielded by lead to increase its sensitivity for sampling discharged water.

9 to ULNRC-05521 Page 10 of 45 5.0 SOLID WASTES The quantities of radioactive material released in shipments of solid waste for burial and of any irradiated fuel transported from the site during the year are summarized in Table 3. The total quantity and radioactivity reported in Table 3 for each waste type was for waste buried and includes wastes buried by waste reprocessors after volume reduction. The activity and fractional abundance of each nuclide was determined for each waste type based upon radiochemical analysis by an independent laboratory. The curie concentration of each nuclide listed in Table 3 was determined as the product of the fractional abundance and the total curies shipped. Those nuclides which comprise at least 1% of the total activity for a particular waste type are presented in Table 3.

6.0 RELATED INFORMATION 6.1 UNPLANNED RELEASES Unplanned releases are:

1) Inadvertent or accidental releases of radioactive material.

2) Releases of radioactive material via normal pathways without a release permit, proper authorization, or proper sampling and analysis.

3) Releases which are conducted in such a manner as to result in significant deviation from the requirements of the release permit.

There were no unplanned releases from Callaway Plant during 2008. Thus, there were no notifications of any unplanned liquid or gaseous radioactive releases from the site to be reported in accordance with the plant technical specifications 5.6.3 pursuant to the reporting requirements of 10CFR50.36a, 10CFR50.72 or 10 CFR20.2203 On 03/28/2008 at 0807 the Callaway Control Room Supervisor received notification of a large leak on the heavy haul road to the Missouri river. The leak was in the intake supply line that brings water from the Missouri River to the plant. The piping leak occurred at supply header manhole number 12. Ameren Environmental Services made a courtesy contact to the Missouri Department of Natural Resources to inform them of the intake line leak and river water spill.

This leak from valve PSEDE1001B spilled river water onto the ground and subsequently spilled water spread to the sampling catch bin in adjacent manhole number 11A of the blowdown line to the river. Water samples from the collection 10 to ULNRC-05521 Page 11 of 45 device (a containment tub) in manhole 11A were tested for radionuclides. Tests results identified tritium in the sample at a concentration of 4.736 E-09 curies per liter. Further investigation of the event resulted in finding no tritium in the soil or groundwater from samples taken in the vicinity of the manhole 11A. Callaway Action Request System Reports 200802345 and 200802851 including a report titled Limited Site Investigation Manhole 11A performed under Terracon Project No 09057158, resulted in showing that this event did not pose any radiological dose pathway to the public.

On 08/26/2008 during excavation of the new cooling tower blowdown line a sinkhole with water in it was discovered adjacent to manhole 86-4A. This manhole is where the make-up line ties into the cooling tower blowdown line. A Callaway Action Request System Report 200808920 was created to find and fix any leakage coming from the pipeline. Excavation of the area indicated there was a leak in the upper portion of the cooling tower blowdown line. Job number 08006065 was performed to install pipewrap to stop pipe leakage. A Limited Site Investigation study was done by Terracon under Project No. 09057158. The resulting report titled Manhole 86-4A Investigation showed the soil and groundwater samples as having only natural background levels of radioactivity and the event did not pose any radiological dose pathway to the public.

6.2 CHANGES TO THE OFFSITE DOSE CALCULATION MANUAL No revisions were made to APA-ZZ-01003, "Callaway Plant Off-Site Dose Calculation Manual" in 2008. FSAR 16.11 was revised July 8, 2008 and change notice FSAR 08-019, Revision of FSAR 16.11 Tables to Incorporate NEI Groundwater Initiative is provided as an Attachment to this report. This change incorporates the American Nuclear Insurers and Nuclear Energy Institute sample and analysis requirements into Table 16.11-7 and corrects a typographical error in the lower limit of detection (LLD) for Iodine-131 in Table 16.11-9 for surface water.

6.3 MAJOR CHANGES TO RADWASTE TREATMENT SYSTEMS The major change to Radwaste systems in 2008 was the permanent removal of the Radwaste Acid Addition Tank. Plant modification MP 07-0091 retired the original acid tank and its associated components. The request to retire and remove this component was due to the fact that the tank was no longer used.

11 to ULNRC-05521 Page 12 of 45 New video cameras were installed on top of the Recycle Holdup Tanks (RHUT) to aid in the inspection of the tank diaphragms. This completed modification MP06-0102 (discussed in 2007 issue of this report) installed bladders in RHUT tanks designated THE02A and THE02B.

6.4 LAND USE CENSUS CHANGES No changes were identified in the Callaway Plant 2008 Land Use Census Report that required a change to the location of the nearest resident yielding the highest calculated dose commitment.

6.5 INOPERABILITY OF EFFLUENT MONITORING INSTRUMENTATION During 2008 all effluent monitoring instrumentation was OPERABLE within the limits specified in Radioactive Effluent Controls FSAR Chapter 16 sections 16.11.1.3 and 16.11.2.4.

The Containment Unit Vent radiation monitoring instrumentation channels are inoperable for short periods for scheduled planned Channel Operational Tests and Electronic Calibration to satisfy acceptance criteria for the FSAR. During these periods alternate sampling is maintained using a separate monitor or auxiliary sampling equipment.

All periods of planned and unplanned inoperability are recorded in the Callaway Equipment Out of Service Log (EOSL) Record. Notable log entries during the year are as follows.

On 11/04/2008 from 14:19 to 23:40 Containment Building Air Exhaust Plenum Unit Vent Particulate /Iodine detector GTRE-0021A was inoperable due to unit vent flow low due to securing all Auxiliary Building and Fuel Building ventilation for a feeder breaker tripping sequence check on Feeder Breaker to the 480 VAC Load Center Transformers.

On 08/21/2008 from 1:40 to 13:24 the Containment Building Air Exhaust Plenum/Unit Vent Gaseous Detector GTRE-0021B was down powered and cable ends were disconnected to perform a field cable re-labeling task.

On 07/07/2008 from 5:08 to 7/10/2008 17:56 GTRE-0021A was inoperable due to low unit vent flow for the performance of damper inspection testing and 12 to ULNRC-05521 Page 13 of 45 maintenance of the Fuel Building Supply Air Unit A Outside Isolation Damper system equipment.

On 07/02/2008 at 13:07 Containment Building Air Exhaust Unit Vent monitor GTRE-0021A vacuum began running higher than normal. On 07/04 at 0900 vacuum increased to 19 in. Hg causing a high vacuum alarm and the monitor was shutdown. The monitor was inspected, repaired and made operable by 12:33.

On 04/30/2008 from 04:39 to 16:36 the Unit Vent monitor GTRE-0021A was inoperable due to low unit vent flow due to inspection, stroke testing and lubrication of damper GLD-0052.

On 03/19/2008 from 11:24 to 15:45 the Unit Vent monitor GTRE-0021B was inoperable due to low unit vent flow due to High Efficiency Particulate Air (HEPA) filter and Charcoal bed testing in the filter unit FGG02B.

On 1/19/2008 19:42 to 1/23/2008 17:10 due to sustained cold weather the heat trace circuit on the outdoor portion of GTRE-0021B Particulate and Iodine Low Range and Low Vent Flow sample lines fell below 95 degrees F. The cold weather caused periodic thermostat alarms and the instrument was placed on the EOSL until a new thermostat was installed.

6.6 INSTANCES OF LIQUID HOLDUP TANKS OR WASTE GAS DECAY TANKS EXCEEDING TECHNICAL SPECIFICATION LIMITS During 2008 all liquid tanks and waste gas decay tanks were within FSAR limits specified in Radioactive Effluent Controls sections 16.11.1 and 16.11.2.

7.0 METEOROLOGICAL DATA The on-site meteorological data for this reporting period is presented in Table 4. The data is presented as Cumulative Joint Frequency Distributions of wind speed and wind direction by atmospheric stability class for the 10 and 60 meter tower elevations. Valid data recovery for 2008 was greater than 99% for all required parameters.

Data Review and Recovery 13 to ULNRC-05521 Page 14 of 45 The on-site meteorological hourly data capture for 2008 was extremely good exceeding 99% for all but the 10 meter sigma-theta data channels. Both sigma-theta on the 10 meter A and B instrumentation channels had to be invalidated, re-evaluated and resolved for the first 24 days of January because of a Met One programming error in the digital datalogger.

The Met One meteorological system is new and was installed in Fall 2007 replacing the old analog electronics and obsolete chart recorders. The improved valid data recovery is credited to the new system. The system was discussed in the 2007 version of this report and consists of redundant instrument channels at 10 and 60 meters on a single tower at the location of the previous primary tower.

The other notable issue in 2008 was the identification, removal and repair of the wind speed and direction sensor data affected by birds perching on the 60 meter instrumentation. The meteorological sensors and data outputs are checked remotely each day by a contract atmospheric boundary layer meteorologist. The meteorologist notified AmerenUE of data anomalies suspected to be from bird interference. Birds were observed on the 60 meter instrument masts and were identified as owls. The meteorologist resolved these data. No invasive measures were taken to capture, harm or chase away the owls.

8.0 ASSESSMENT OF DOSES Assessment of doses to the maximum exposed individual from gaseous and liquid effluents released was performed in accordance with the ODCM as described in the following sections. For all liquid and airborne effluents released from the Callaway Plant during this year, the annual dose to the maximum exposed individual was less than 1% of the Radiological Effluent Control Limits presented in Section 2.1 of this report.

8.1 DOSE AT THE SITE BOUNDARY FROM GASEOUS EFFLUENTS The dose at the Site Boundary was due to plume exposure from noble gases, ground plane exposure, and inhalation. It was conservatively assumed that a hypothetical maximum exposed individual was present at the Site Boundary location with the most limiting atmospheric dispersion (based on actual meteorological conditions for the year). Dose was conservatively calculated using a child as the critical age group.

14 to ULNRC-05521 Page 15 of 45 The dose from gaseous effluents at the Site Boundary for 2008 is presented in Table 5.

8.2 DOSE TO THE MEMBER OF THE PUBLIC The Member of the Public is considered to be a real individual, not occupationally associated with the plant, who uses portions of the plant site for recreational or other purposes not associated with plant operation. This individuals utilization of areas both inside and outside the Site Boundary was characterized for this calculation and is described in the ODCM.

To evaluate total dose from the Uranium Fuel Cycle to any Member of the Public, the critical Member of the Public within the Site Boundary, and the Nearest Resident were each evaluated.

Dose To The Nearest Resident From Gaseous Effluent The dose to the Nearest Resident was due to plume exposure from noble gases, ground plane exposure, and inhalation and ingestion. Dose was calculated at the nearest actual residence with the most limiting atmospheric dispersion (based on actual meteorological conditions for the year). It was conservatively assumed that each ingestion pathway (meat, milk, and vegetation) existed at this location. Dose was conservatively calculated assuming the child as the critical age group. Direct dose from activities within the Site Boundary was negligible and not included in this calculation.

The doses to the Nearest Resident for 2008 are presented in Table 5.

Dose To The Member Of The Public From Activities Within The Site Boundary Based on the land use within the Site Boundary, the Member of the Public with the highest dose was a farmer. Dose from farming activities within the Site Boundary was due to direct radiation exposure, plume exposure from noble gases, ground plane exposure, and inhalation. The current tenant farmer estimates spending 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months per year working within the Site Boundary area. Dose was calculated using the adult as the critical age group.

Dose to the Member of the Public from activities within the Site Boundary is presented in Table 6.

8.3 TOTAL DOSE DUE TO THE URANIUM FUEL CYCLE 15 to ULNRC-05521 Page 16 of 45 There are no other Uranium Fuel Cycle facilities within 8 kilometers of the Callaway Plant. Thus, the total dose to the most likely exposed Member of the Public resulted from direct radiation exposure and radioactive effluents from the Callaway Plant itself.

The total dose to the Member of the Public (Table 7) was the sum of the dose due to activities within the Site Boundary (Table 6) and the dose due to gaseous effluents at his residence. It was conservatively assumed that each food ingestion pathway exists at his residence and that the adult is the critical age group.

The total dose from the Uranium Fuel Cycle is presented in Table 7.

8.4 DOSE DUE TO LIQUID EFFLUENTS Dose due to liquid effluents includes contributions from the maximum exposed individual's recreational activities and consumption of fish. An adult was considered to be the maximum exposed individual in this assessment.

It is conservatively assumed that the hypothetical maximum exposed individual obtained his entire annual fish intake from near the plant discharge.

Total dose due to liquid effluents from Callaway Plant during the year is presented in Table 8.

16 to ULNRC-05521 Page 17 of 45 Table 1A SEMIANNUAL SUMMATION OF GASEOUS RELEASES ALL AIRBORNE EFFLUENTS QUARTERS 1 AND 2, 2008 A. FISSION AND ACTIVATION GASES

1. TOTAL RELEASE CURIES 7.69E+00 4.34E+00 20

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 9.77E-01 5.52E-01

3. PERCENT OF TECH SPEC LIMIT % N/A N/A B. RADIOIODINES

1. TOTAL IODINE-131 CURIES 0.00E+00 0.00E+00 23

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 0.00E+00 0.00E+00

3. PERCENT OF TECH SPEC LIMIT % N/A N/A C. PARTICULATES

1. PARTICULATE (HALF-LIVES > 8 DAYS) CURIES 1.56E-08 1.28E-07 30

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 1.98E-09 1.62E-08

3. PERCENT OF TECH SPEC LIMIT % N/A N/A

4. GROSS ALPHA RADIOACTIVITY CURIES 2.32E-07 1.32E-07 D. TRITIUM

1. TOTAL RELEASE CURIES 1.23E+01 8.67E+00 14

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 1.57E+00 1.10E+00

3. PERCENT OF TECH SPEC LIMIT % N/A N/A (a) Safety Analysis Calculation 87-063-00, January 6, 1988 Page 1 of 2 to ULNRC-05521 Page 18 of 45 Table 1A SEMIANNUAL SUMMATION OF GASEOUS RELEASES ALL AIRBORNE EFFLUENTS QUARTERS 3 AND 4, 2008 A. FISSION AND ACTIVATION GASES

1. TOTAL RELEASE CURIES 4.53E+00 9.40E+01 20

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 5.70E-01 1.18E+01

3. PERCENT OF TECH SPEC LIMIT % N/A N/A B. RADIOIODINES

1. TOTAL IODINE-131 CURIES 0.00E+00 3.75E-05 23

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 0.00E+00 4.71E-06

3. PERCENT OF TECH SPEC LIMIT % N/A N/A C. PARTICULATES

1. PARTICULATE (HALF-LIVES > 8 DAYS) CURIES 3.01E-07 4.70E-05 30

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 3.78E-08 5.92E-06

3. PERCENT OF TECH SPEC LIMIT % N/A N/A

4. GROSS ALPHA RADIOACTIVITY CURIES 2.70E-07 1.77E-07 D. TRITIUM

1. TOTAL RELEASE CURIES 1.51E+01 1.33E+01 14

2. AVERAGE RELEASE RATE FOR PERIOD uCi/SEC 1.91E+00 1.68E+00

3. PERCENT OF TECH SPEC LIMIT % N/A N/A (a) Safety Analysis Calculation 87-063-00, January 6, 1988 Page 2 of 2 to ULNRC-05521 Page 19 of 45 Table 1B SEMIANNUAL AIRBORNE CONTINUOUS AND BATCH RELEASES GROUND LEVEL RELEASES FISSION GASES, IODINES, AND PARTICULATES QUARTERS 1 AND 2, 2008 CONTINUOUS RELEASES BATCH RELEASES FIRST SECOND FIRST SECOND NUCLIDE UNITS QUARTER QUARTER QUARTER QUARTER FISSION GASES XE-133 CURIES 5.79E+00 3.10E+00 2.04E-02 1.74E-02 XE-135 CURIES 2.55E-01 2.54E-01 3.64E-04 4.41E-04 AR-41 CURIES 0.00E+00 0.00E+00 5.03E-02 5.51E-02 KR-85 CURIES 0.00E+00 9.16E-01 1.57E+00 0.00E+00 XE-131M CURIES 0.00E+00 0.00E+00 6.57E-04 0.00E+00 KR-85M CURIES 0.00E+00 2.85E-03 0.00E+00 0.00E+00 XE-137 CURIES 0.00E+00 0.00E+00 0.00E+00 4.94E-04 TOTAL FOR PERIOD CURIES 6.04E+00 4.27E+00 1.64E+00 7.34E-02 IODINES TOTAL FOR PERIOD CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 PARTICULATES CO-60 CURIES 0.00E+00 0.00E+00 1.24E-08 1.11E-07 NI-63 CURIES 3.14E-09 1.65E-08 0.00E+00 0.00E+00 ALPHA CURIES 2.32E-07 1.32E-07 0.00E+00 0.00E+00 TOTAL FOR PERIOD CURIES 2.35E-07 1.48E-07 1.24E-08 1.11E-07 TRITIUM to ULNRC-05521 Page 20 of 45 Table 1B SEMIANNUAL AIRBORNE CONTINUOUS AND BATCH RELEASES GROUND LEVEL RELEASES FISSION GASES, IODINES, AND PARTICULATES QUARTERS 3 AND 4, 2008 CONTINUOUS RELEASES BATCH RELEASES THIRD FOURTH THIRD FOURTH NUCLIDE UNITS QUARTER QUARTER QUARTER QUARTER 1 FISSION GASES XE-133 CURIES 3.60E+00 9.04E+01 3.35E-01 9.20E-01 XE-135 CURIES 2.10E-01 4.68E-01 1.02E-02 5.54E-03 AR-41 CURIES 0.00E+00 0.00E+00 3.78E-01 3.42E-01 KR-85 CURIES 0.00E+00 1.16E-01 0.00E+00 0.00E+00 XE-131M CURIES 0.00E+00 8.05E-01 0.00E+00 0.00E+00 KR-85M CURIES 0.00E+00 0.00E+00 0.00E+00 4.22E-08 XE-137 CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 XE-133M CURIES 0.00E+00 1.01E+00 0.00E+00 1.94E-04 TOTAL FOR PERIOD CURIES 3.81E+00 9.27E+01 7.23E-01 1.27E+00 2 IODINES I-131 CURIES 0.00E+00 1.64E-05 0.00E+00 2.11E-05 I-132 CURIES 0.00E+00 0.00E+00 0.00E+00 6.16E-05 I-133 CURIES 0.00E+00 0.00E+00 0.00E+00 2.90E-07 TOTAL FOR PERIOD CURIES 0.00E+00 1.64E-05 0.00E+00 8.29E-05 3 PARTICULATES CO-60 CURIES 0.00E+00 1.61E-07 0.00E+00 4.35E-05 NI-63 CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 NI-63 CURIES 3.01E-07 1.11E-06 0.00E+00 0.00E+00 CO-58 CURIES 0.00E+00 0.00E+00 0.00E+00 5.06E-07 CR-51 CURIES 0.00E+00 0.00E+00 0.00E+00 3.77E-07 NB-95 CURIES 0.00E+00 0.00E+00 0.00E+00 1.90E-08 ZR-95 CURIES 0.00E+00 0.00E+00 0.00E+00 1.90E-08 CS-137 CURIES 0.00E+00 3.19E-07 0.00E+00 0.00E+00 SB-125 CURIES 0.00E+00 1.02E-06 0.00E+00 0.00E+00 ALPHA CURIES 2.70E-07 1.77E-07 0.00E+00 0.00E+00 TOTAL FOR PERIOD CURIES 5.70E-07 2.79E-06 0.00E+00 4.44E-05 4 TRITIUM Page 2 of 2 to ULNRC-05521 Page 21 of 45 Table 2A SEMIANNUAL SUMMATION OF LIQUID RELEASES ALL LIQUID EFFLUENTS QUARTERS 1 AND 2, 2008 A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE [NOT INCLUDING TRITIUM, GASES, ALPHA] CURIES 2.45E-02 1.27E-02 20

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 2.34E-07 6.21E-08

3. PERCENT OF APPLICABLE LIMIT % N/A N/A B. TRITIUM

1. TOTAL RELEASE CURIES 8.53E+01 4.24E+02 14

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 8.15E-04 2.08E-03

3. PERCENT OF APPLICABLE LIMIT % N/A N/A C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE CURIES 6.27E-04 4.66E-04 27

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 5.99E-09 2.29E-09 (a) Safety Analysis Calculation 87-063-00, January 6, 1988 Page 1 of 2 to ULNRC-05521 Page 22 of 45 Table 2A SEMIANNUAL SUMMATION OF LIQUID RELEASES ALL LIQUID EFFLUENTS QUARTERS 3 AND 4, 2008 A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE [NOT INCLUDING TRITIUM, GASES, ALPHA] CURIES 6.48E-03 2.10E-01 20

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 2.13E-08 6.68E-07

3. PERCENT OF APPLICABLE LIMIT % N/A N/A B. TRITIUM

1. TOTAL RELEASE CURIES 8.45E+02 3.10E+02 14

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 2.77E-03 9.85E-04

3. PERCENT OF APPLICABLE LIMIT % N/A N/A C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE CURIES 1.45E-02 3.35E-01 27

2. AVERAGE DILUTED CONCENTRATION DURING PERIOD uCi/ML 4.77E-08 1.06E-06 (a) Safety Analysis Calculation 87-063-00, January 6, 1988 Page 2 of 2 to ULNRC-05521 Page 23 of 45 Table 2B SEMIANNUAL LIQUID CONTINUOUS AND BATCH RELEASES TOTALS FOR EACH NUCLIDE RELEASED QUARTERS 1 AND 2, 2008 CONTINUOUS RELEASES BATCH RELEASES FIRST SECOND FIRST SECOND NUCLIDE UNITS QUARTER QUARTER QUARTER QUARTER

1. ALL NUCLIDES CO-58 CURIES 0.00E+00 0.00E+00 9.67E-04 4.18E-04 CO-60 CURIES 0.00E+00 0.00E+00 2.03E-03 1.21E-03 CS-134 CURIES 0.00E+00 0.00E+00 2.62E-04 3.23E-04 CS-137 CURIES 0.00E+00 0.00E+00 6.13E-04 8.13E-04 FE-55 CURIES 0.00E+00 0.00E+00 4.92E-03 3.69E-03 H-3 CURIES 0.00E+00 0.00E+00 8.53E+01 4.24E+02 NI-63 CURIES 0.00E+00 0.00E+00 1.48E-02 5.27E-03 SB-125 CURIES 0.00E+00 0.00E+00 8.37E-04 9.32E-04 XE-133 CURIES 0.00E+00 0.00E+00 6.27E-04 4.66E-04 MN-54 CURIES 0.00E+00 0.00E+00 5.07E-05 0.00E+00 ALPHA CURIES 0.00E+00 0.00E+00 3.59E-05 0.00E+00 SB-122 CURIES 0.00E+00 0.00E+00 2.11E-06 0.00E+00 CO-57 CURIES 0.00E+00 0.00E+00 4.51E-05 9.63E-06 TOTALS FOR PERIOD CURIES 0.00E+00 0.00E+00 8.53E+01 4.24E+02 Page 1 of 2 to ULNRC-05521 Page 24 of 45 Table 2B SEMIANNUAL LIQUID CONTINUOUS AND BATCH RELEASES TOTALS FOR EACH NUCLIDE RELEASED QUARTERS 3 AND 4, 2008 CONTINUOUS RELEASES BATCH RELEASES THIRD FOURTH THIRD FOURTH NUCLIDE UNITS QUARTER QUARTER QUARTER QUARTER

1. ALL NUCLIDES CO-58 CURIES 0.00E+00 0.00E+00 5.63E-05 1.30E-01 CO-60 CURIES 0.00E+00 0.00E+00 2.10E-04 2.39E-02 CS-134 CURIES 0.00E+00 0.00E+00 2.30E-04 3.18E-04 CS-137 CURIES 0.00E+00 0.00E+00 6.32E-04 8.68E-04 FE-55 CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 H-3 CURIES 0.00E+00 0.00E+00 8.45E+02 3.10E+02 NI-63 CURIES 0.00E+00 0.00E+00 2.98E-03 3.18E-03 SB-125 CURIES 0.00E+00 0.00E+00 2.32E-03 4.29E-02 XE-133 CURIES 0.00E+00 0.00E+00 1.42E-02 3.27E-01 MN-54 CURIES 0.00E+00 0.00E+00 0.00E+00 0.00E+00 ALPHA CURIES 0.00E+00 0.00E+00 0.00E+00 1.47E-03 SB-122 CURIES 0.00E+00 0.00E+00 0.00E+00 2.01E-04 CO-57 CURIES 0.00E+00 0.00E+00 0.00E+00 3.49E-04 SB-124 CURIES 0.00E+00 0.00E+00 2.08E-05 3.81E-03 I-131 CURIES 0.00E+00 0.00E+00 2.60E-05 1.83E-03 Y-91M CURIES 0.00E+00 0.00E+00 2.26E-06 2.46E-06 CE-141 CURIES 0.00E+00 0.00E+00 4.34E-06 0.00E+00 XE-131M CURIES 0.00E+00 0.00E+00 2.91E-04 5.14E-03 I-132 CURIES 0.00E+00 0.00E+00 0.00E+00 6.10E-04 TE-132 CURIES 0.00E+00 0.00E+00 0.00E+00 4.50E-04 XE-133M CURIES 0.00E+00 0.00E+00 0.00E+00 2.78E-03 XE-135 CURIES 0.00E+00 0.00E+00 0.00E+00 3.60E-04 I-133 CURIES 0.00E+00 0.00E+00 0.00E+00 2.20E-05 MO-99 CURIES 0.00E+00 0.00E+00 0.00E+00 1.38E-05 TC-99M CURIES 0.00E+00 0.00E+00 0.00E+00 1.38E-05 LA-140 CURIES 0.00E+00 0.00E+00 0.00E+00 1.09E-05 CR-51 CURIES 0.00E+00 0.00E+00 0.00E+00 1.49E-03 NA-24 CURIES 0.00E+00 0.00E+00 0.00E+00 8.72E-05 CS-138 CURIES 0.00E+00 0.00E+00 0.00E+00 3.37E-05 TOTALS FOR PERIOD CURIES 0.00E+00 0.00E+00 8.45E+02 3.10E+02 Page 2 of 2 to ULNRC-05521 Page 25 of 45 Table 3 Solid Waste & Irradiated Fuel Shipments 2008 .

A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not Irradiated Fuel)

1. TYPE OF WASTE Units Period Period Est. Total Jan - Jun Jul - Dec Error (%)

a. Spent resins, filter sludges, m3 9.63E+00 0.00E+00 evaporator bottoms, etc. Ci 3.09E+02 0.00E+00 + 25%

b. Dry compressible waste, m3 5.58E+01 1.23E+02 contaminated equip., etc. Ci 2.97E-02 8.79E-02 + 25%

c. Irradiated components, m3 0.00E+00 0.00E+00 control rods, etc. Ci 0.00E+00 0.00E+00 + 25%

d. Other (low level secondary m3 0.00E+00 0.00E+00 resin, oily waste) Ci 0.00E+00 0.00E+00 + 25%

2. ESTIMATE OF MAJOR NUCLIDE COMPOSITION (by Type of Waste)

a. Spent resins, filters, evaporator bottoms, etc.

Nuclide % Abundance Period % Abundance Period Jan - Jun Jul - Dec Curies Curies H-3 2. 136 % 6.60E+00 0% 0.00E+00 Fe-55 7. 091 % 2.19E+01 0% 0.00E+00 Co-60 17.313 % 5.35E+01 0% 0.00E+00 Ni-59 2. 640 % 8.16E+00 0% 0.00E+00 Ni-63 45.383 % 1.40E+02 0% 0.00E+00 Cs-134 7. 694 % 2.38E+01 0% 0.00E+00 Cs-137 16.014 % 4.95E+01 0% 0.00E+00

b. Dry compressible waste, contaminated equipment, etc.

H-3 0 % 0.00E+00 2.007 % 1.76E-03 Fe-55 0% 0.00E+00 29.526 % 2.60E-02 Co-58 0 % 0.00E+00 1.207 % 1.06E-03 Co-60 0% 0.00E+00 14.998 % 1.32E-02 Ni-63 0% 0.00E+00 29.907 % 2.63E-02 Zr-95 0 % 0.00E+00 1.426 % 1.25E-03 Nb-95 0 % 0.00E+00 2.752 % 2.42E-03 Cs-134 0 % 0.00E+00 4.619 % 4.06E-03 Cs-137 0% 0.00E+00 12.269 % 1.08E-02

c. Irradiated components, control rods, etc.

N/A N/A N/A N/A N/A

d. Other N/A N/A N/A N/A N/A Page 1 of 2 to ULNRC-05521 Page 26 of 45 Table 3 Solid Waste & Irradiated Fuel Shipments 2008 .

3. SOLID WASTE DISPOSITION Number of Mode of Destination Class of Solid Type of Shipments Transport Waste Shipped Container 3* Truc k Energy Solutions A Intermodal Container 3* C ask Studsvik B Poly Liner

Sent to waste processors for volume reduction before burial.

4. SOLIDIFICATION AGENT None used.

B. IRRADIATED FUEL SHIPMENTS (Disposition)

There were no shipments of irradiated fuel in 2008.

Page 2 of 2 to ULNRC-05521 Page 27 of 45 Table 4 Union Electric - Callaway Plant Report Date/Time: 21-APR-2009 12:35:05.46 Meteorological Data Averages Using Hourly Averaged Data 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00

% GOOD UNITS VALUES DATA Stability Class A-G E 100%

Total Precipitation CM. 1.36E+02 100%

10 Meter Level: Wind Speed Meter/Sec 3.27E+00 100%

Wind Direction Degrees 1.94E+02 100%

Wind Direction Degrees 1.60E+01 100%

Variability Degrees C 1.19E+01 100%

Reference Temperature Degrees C 5.73E+00 99%

Dewpoint 60 Meter Level: Wind Speed Meter/Sec 5.30E+00 100%

Wind Direction Degrees 2.01E+02 100%

Wind DirectionVariability Degrees 1.01E+01 100%

Dewpoint Degrees C NONE 0%

Temperature Difference 60 - 10 Degrees C 6.79E-02 100%

Page 1 of 1 to ULNRC-05521 Page 28 of 45 Table 4 10 Meter Meteorological Data Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: A Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 1 0 1 0 0 0 2 NNE 0 0 0 0 0 0 0 NE 0 0 0 0 0 0 0 ENE 0 0 1 0 0 0 1 E 0 0 0 0 0 0 0 ESE 0 0 1 0 0 0 1 SE 0 0 1 0 0 0 1 SSE 0 1 6 0 0 0 7 S 0 3 3 7 1 0 14 SSW 0 3 7 0 0 0 10 SW 0 1 10 2 0 0 13 WSW 0 2 2 1 0 0 5 W 0 3 1 5 0 0 9 WNW 0 1 13 6 0 0 20 NW 0 1 12 3 0 0 16 NNW 0 0 1 1 0 0 2 TOTAL 1 15 59 25 1 0 101 Hours of Calm Data: 1 Hours of Invalid Data: 0 to ULNRC-05521 Page 29 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: B Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 1 1 0 0 0 2 NNE 0 1 9 2 0 0 12 NE 0 1 2 1 0 0 4 ENE 0 0 1 1 0 0 2 E 0 0 4 0 0 0 4 ESE 0 2 4 0 0 0 6 SE 0 7 14 0 0 0 21 SSE 0 7 18 2 0 0 27 S 0 13 16 9 1 0 39 SSW 0 20 4 1 1 0 26 SW 0 11 8 1 0 0 20 WSW 0 5 6 2 0 0 13 W 0 8 10 4 0 0 22 WNW 0 9 15 6 0 0 30 NW 0 0 23 6 1 0 30 NNW 1 0 7 1 0 0 9 TOTAL 1 85 142 36 3 0 267 Hours of Calm Data: 0 Hours of Invalid Data: 0 Page 2 of 7 to ULNRC-05521 Page 30 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: C Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 9 8 1 0 0 18 NNE 0 3 7 2 0 0 12 NE 0 3 7 1 0 0 11 ENE 3 13 7 0 0 0 23 E 1 9 7 1 0 0 18 ESE 0 8 16 3 0 0 27 SE 1 33 25 3 0 0 62 SSE 2 36 31 3 0 0 72 S 1 27 23 17 0 0 68 SSW 1 43 24 2 1 0 71 SW 1 18 9 5 2 0 35 WSW 3 16 5 3 0 0 27 W 0 21 15 2 0 0 38 WNW 0 20 15 7 0 0 42 NW 1 17 24 5 0 0 47 NNW 2 11 16 1 0 0 30 TOTAL 16 287 239 56 3 0 601 Hours of Calm Data: 0 Hours of Invalid Data: 0 Page 3 of 7 to ULNRC-05521 Page 31 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: D Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 22 103 121 36 0 0 282 NNE 23 123 70 8 0 0 224 NE 16 101 57 4 0 0 178 ENE 14 62 53 2 0 0 131 E 21 82 97 5 1 0 206 ESE 25 99 93 15 0 0 232 SE 25 135 72 8 0 0 240 SSE 18 105 122 57 1 0 303 S 26 74 107 105 3 0 315 SSW 19 101 80 41 3 0 244 SW 25 73 58 18 5 0 179 WSW 25 37 35 9 7 0 113 W 33 79 63 32 6 0 213 WNW 21 103 182 48 1 0 355 NW 24 86 199 31 1 0 341 NNW 21 116 154 30 0 0 321 TOTAL 358 1479 1563 449 28 0 3877 Hours of Calm Data: 6 Hours of Invalid Data: 4 Page 4 of 7 to ULNRC-05521 Page 32 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: E Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 23 51 7 1 0 0 82 NNE 31 54 8 0 0 0 93 NE 26 38 4 0 0 0 68 ENE 30 61 6 0 0 0 97 E 31 56 9 0 0 0 96 ESE 31 78 20 4 0 0 133 SE 37 160 102 1 0 0 300 SSE 23 161 195 24 0 0 403 S 19 112 123 43 0 0 297 SSW 21 101 42 6 1 0 171 SW 30 81 19 2 2 0 134 WSW 20 42 29 0 1 0 92 W 40 29 21 0 0 0 90 WNW 47 43 15 2 0 0 107 NW 28 87 16 1 0 0 132 NNW 16 64 15 0 0 0 95 TOTAL 453 1218 631 84 4 0 2390 Hours of Calm Data: 3 Hours of Invalid Data: 0 Page 5 of 7 to ULNRC-05521 Page 33 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: F Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 24 16 0 0 0 0 40 NNE 28 19 1 0 0 0 48 NE 32 14 0 0 0 0 46 ENE 23 4 0 0 0 0 27 E 22 13 0 0 0 0 35 ESE 39 4 0 0 0 0 43 SE 56 75 8 0 0 0 139 SSE 28 154 20 0 0 0 202 S 26 29 4 0 0 0 59 SSW 22 33 2 0 0 0 57 SW 23 39 0 0 0 0 62 WSW 17 15 2 0 0 0 34 W 15 16 1 0 0 0 32 WNW 26 7 0 0 0 0 33 NW 30 29 0 0 0 0 59 NNW 24 14 1 0 0 0 39 TOTAL 435 481 39 0 0 0 955 Hours of Calm Data: 24 Hours of Invalid Data: 0 Page 6 of 7 to ULNRC-05521 Page 34 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: G Wind Speed at 10.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 29 1 0 0 0 0 30 NNE 36 0 0 0 0 0 36 NE 27 2 0 0 0 0 29 ENE 12 0 0 0 0 0 12 E 7 0 0 0 0 0 7 ESE 8 0 0 0 0 0 8 SE 17 6 0 0 0 0 23 SSE 52 47 6 0 0 0 105 S 31 5 1 0 0 0 37 SSW 45 6 0 0 0 0 51 SW 20 7 0 0 0 0 27 WSW 20 1 0 0 0 0 21 W 8 0 0 0 0 0 8 WNW 36 3 0 0 0 0 39 NW 39 6 0 0 0 0 45 NNW 36 5 0 0 0 0 41 TOTAL 423 89 7 0 0 0 519 Hours of Calm Data: 33 Hours of Invalid Data: 0 Hours of Good Data: 8777 = 99.9% of Total Hours Page 7 of 7 to ULNRC-05521 Page 35 of 45 Table 4 60 Meter Meteorological Data Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: A Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 1 0 0 0 1 NNE 0 0 0 0 0 0 0 NE 1 0 0 0 0 0 1 ENE 0 0 0 1 0 0 1 E 0 0 0 0 0 0 0 ESE 1 0 0 1 0 0 2 SE 0 0 0 1 0 0 1 SSE 0 0 6 0 0 0 6 S 0 1 5 7 1 1 15 SSW 0 0 6 4 0 0 10 SW 0 0 5 6 2 0 13 WSW 0 1 1 2 3 0 7 W 0 0 3 1 2 0 6 WNW 0 0 6 8 5 3 22 NW 0 0 4 9 3 0 16 NNW 0 0 0 1 0 0 1 TOTAL 2 2 37 41 16 4 102 Hours of Calm Data: 0 Hours of Invalid Data: 0 to ULNRC-05521 Page 36 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: B Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 3 1 0 0 4 NNE 0 1 4 5 0 0 10 NE 0 0 2 2 1 0 5 ENE 0 0 1 0 0 0 1 E 0 1 3 1 0 0 5 ESE 0 1 2 2 0 0 5 SE 0 2 14 2 0 0 18 SSE 0 5 13 8 0 0 26 S 0 6 19 13 6 1 45 SSW 0 7 15 1 0 1 24 SW 0 3 11 5 0 1 20 WSW 0 0 7 2 3 0 12 W 0 3 10 3 7 1 24 WNW 0 3 13 9 2 4 31 NW 1 0 10 14 5 2 32 NNW 0 0 3 2 0 0 5 TOTAL 1 32 130 70 24 10 267 Hours of Calm Data: 0 Hours of Invalid Data: 0 Page 2 of 7 to ULNRC-05521 Page 37 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: C Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 0 0 10 4 0 0 14 NNE 0 3 8 3 0 0 14 NE 0 3 5 1 0 0 9 ENE 2 9 9 1 0 0 21 E 0 7 9 2 0 0 18 ESE 0 5 9 10 0 0 24 SE 0 19 28 9 2 0 58 SSE 1 18 40 14 0 0 73 S 0 27 22 19 6 0 74 SSW 0 12 42 14 0 3 71 SW 2 12 13 6 4 3 40 WSW 0 8 9 4 3 0 24 W 0 11 14 9 2 2 38 WNW 1 6 19 13 5 3 47 NW 2 5 20 15 5 1 48 NNW 0 3 16 8 1 0 28 TOTAL 8 148 273 132 28 12 601 Hours of Calm Data: 0 Hours of Invalid Data: 0 Page 3 of 7 to ULNRC-05521 Page 38 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: D Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 16 59 76 95 14 0 260 NNE 14 83 85 47 4 0 233 NE 8 64 80 27 1 0 180 ENE 9 42 60 15 1 0 127 E 12 38 99 43 2 1 195 ESE 13 36 104 58 10 2 223 SE 7 85 104 43 3 0 242 SSE 11 61 104 69 48 1 294 S 11 39 75 104 76 14 319 SSW 13 51 92 63 41 7 267 SW 12 43 53 53 16 12 189 WSW 13 21 27 32 15 8 116 W 16 49 53 44 42 18 222 WNW 10 42 95 129 73 25 374 NW 9 36 85 165 36 12 343 NNW 16 59 92 118 13 3 301 TOTAL 190 808 1284 1105 395 103 3885 Hours of Calm Data: 2 Hours of Invalid Data: 0 Page 4 of 7 to ULNRC-05521 Page 39 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: E Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 4 15 40 6 1 0 66 NNE 6 18 57 7 0 0 88 NE 2 19 43 7 0 0 71 ENE 2 17 60 4 0 0 83 E 7 36 63 10 0 0 116 ESE 6 19 91 25 4 0 145 SE 2 19 138 122 1 0 282 SSE 2 17 107 198 29 1 354 S 5 13 72 178 52 3 323 SSW 3 12 65 104 14 3 201 SW 7 14 60 52 7 4 144 WSW 4 20 30 36 4 1 95 W 4 16 26 38 4 0 88 WNW 3 18 42 28 5 1 97 NW 1 23 90 20 6 2 142 NNW 3 13 68 13 0 0 97 TOTAL 61 289 1052 848 127 15 2392 Hours of Calm Data: 1 Hours of Invalid Data: 0 Page 5 of 7 to ULNRC-05521 Page 40 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: F Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 7 13 20 1 0 0 41 NNE 2 12 20 4 0 0 38 NE 4 8 33 4 0 0 49 ENE 6 11 28 1 0 0 46 E 3 4 29 6 0 0 42 ESE 1 9 37 0 0 0 47 SE 1 19 90 23 0 0 133 SSE 2 16 52 52 2 0 124 S 3 17 80 29 3 0 132 SSW 1 14 32 23 0 0 70 SW 2 7 25 37 1 0 72 WSW 2 7 22 10 0 0 41 W 2 12 12 9 0 0 35 WNW 1 8 14 12 0 0 35 NW 2 6 20 12 0 0 40 NNW 0 11 10 10 1 0 32 TOTAL 39 174 524 233 7 0 977 Hours of Calm Data: 2 Hours of Invalid Data: 0 Page 6 of 7 to ULNRC-05521 Page 41 of 45 Table 4 Totals of Hours at Each Wind Speed & Direction 1-JAN-2008 00:00:00.00 to 31-DEC-2008 23:59:59.00 Stability Class: G Wind Speed at 60.00 Meter Level (MPH) 1-3 4-7 8-12 13-18 19-24 >24 TOTAL N 2 12 14 2 0 0 30 NNE 2 13 20 0 0 0 35 NE 2 8 10 4 0 0 24 ENE 6 11 16 2 0 0 35 E 1 14 17 2 0 0 34 ESE 3 10 14 0 0 0 27 SE 3 11 11 0 0 0 25 SSE 6 11 11 9 0 0 37 S 6 11 41 7 0 0 65 SSW 1 10 26 5 1 0 43 SW 3 12 29 4 0 0 48 WSW 3 13 35 4 0 0 55 W 3 6 7 0 0 0 16 WNW 3 6 5 6 0 0 20 NW 1 4 16 4 0 0 25 NNW 4 7 11 5 0 0 27 TOTAL 49 159 283 54 1 0 546 Hours of Calm Data: 3 Hours of Invalid Data: 3 Hours of Good Data: 8778 = 99.9% of Total Hours Page 7 of 7 to ULNRC-05521 Page 42 of 45 Table 5 DOSE AT THE SITE BOUNDARY AND TO THE NEAREST RESIDENT FROM GASEOUS EFFLUENTS SITE BOUNDARY NEAREST RESIDENT LOCATION: 2.20 km NNW LOCATION: 2.90 km NNW AGE GROUP: CHILD AGE GROUP: CHILD ORGAN UNITS DOSE % LIMIT(a) DOSE % LIMIT(b)

1. GAMMA AIR DOSE

MRAD 1.49E-03 0.01 9.82E-04 N/A

2. BETA AIR DOSE

MRAD 3.85E-03 0.02 2.55E-03 N/A

3. WHOLE BODY *** MREM 1.40E-03 N/A 9.22E-04 N/A

4. SKIN *** MREM 3.06E-03 N/A 2.02E-03 N/A

5. BONE ** MREM 1.27E-04 N/A 9.49E-05 0.00

6. LIVER ** MREM 1.61E-03 N/A 8.78E-03 0.06

7. TOTAL BODY ** MREM 1.61E-03 N/A 8.78E-03 0.06

8. THYROID ** MREM 1.63E-03 N/A 1.20E-02 0.08

9. KIDNEY ** MREM 1.61E-03 N/A 8.79E-03 0.06

10. LUNG ** MREM 1.62E-03 N/A 8.77E-03 0.06

11. GI-LLI ** MREM 1.61E-03 N/A 8.78E-03 0.06

Dose from Noble Gases only ** Dose from Tritium, Radioiodines, and Particulates only *** Dose from Noble Gases plus Ground Plane dose

~ (a) Annual dose limits of Offsite Dose Calculation Manual (APA-ZZ-01003) of 10 mrad gamma air dose and 20 mrad beta air dose.

~ (b) Annual dose limits of Offsite Dose Calculation Manual (APA-ZZ-01003) of 15 mrem to any organ from I-131, I-133, H-3 and particulate radionuclides with halflives greater than 8 days.

Page 1 of 1 to ULNRC-05521 Page 43 of 45 Table 6 DOSE TO THE MEMBER OF THE PUBLIC FROM ACTIVITIES WITHIN THE SITE BOUNDARY EFFLUENT DIRECT DIRECT TOTAL DOSE RADIATION RADIATIONFROM DOSE FOR WITHIN THE FROM THE OUTSIDE TANKS THE SITE UNIT YEAR ORGAN UNITS BOUNDARY

1. SKIN MREM 7.68E-04 N/A N/A 7.68E-04

2. BONE MREM 3.91E-05 9.00E-03 1.43E-03 1.05E-02

3. LIVER MREM 5.13E-04 9.00E-03 1.43E-03 1.09E-02

4. TOTAL BODY MREM 8.47E-04 9.00E-03 1.43E-03 1.13E-02

5. THYROID MREM 5.17E-04 9.00E-03 1.43E-03 1.09E-02

6. KIDNEY MREM 5.13E-04 9.00E-03 1.43E-03 1.09E-02

7. LUNG MREM 5.15E-04 9.00E-03 1.43E-03 1.09E-02

8. GI-LLI MREM 5.13E-04 9.00E-03 1.43E-03 1.09E-02 Page 1 of 1 to ULNRC-05521 Page 44 of 45 Table 7 TOTAL DOSE DUE TO THE URANIUM FUEL CYCLE (MEMBER OF THE PUBLIC)

DOSE FROM TOTAL DOSE AT ACTIVITIES DOSE TO THE WITHIN THE RESIDENCE SITE MEMBER OF ORGAN UNITS LOCATION BOUNDARY THE PUBLIC % LIMITS *

1. SKIN MREM 2.27E-03 7.68E-04 3.04E-03 0.01

2. BONE MREM 9.50E-05 1.05E-02 1.06E-02 0.04

3. LIVER MREM 6.29E-03 1.09E-02 1.72E-02 0.07

4. TOTAL BODY MREM 7.28E-03 1.13E-02 1.86E-02 0.07

5. THYROID MREM 7.55E-03 1.09E-02 1.85E-02 0.02

6. KIDNEY MREM 6.29E-03 1.09E-02 1.72E-02 0.07

7. LUNG MREM 6.29E-03 1.09E-02 1.72E-02 0.07

8. GI-LLI MREM 6.31E-03 1.09E-02 1.73E-02 0.07

Annual dose limits from 40CFR190.10(a) of 25 mrem whole body, 75 mrem to the thyroid, and 25 mrem to any other organ.

Page 1 of 1 to ULNRC-05521 Page 45 of 45 Table 8 DOSE DUE TO LIQUID EFFLUENTS (MEMBER OF THE PUBLIC) 2008

1. BONE MREM 1.79E-02 10.00 1.79E-01

2. LIVER MREM 2.19E-02 10.00 2.19E-01

3. TOTAL BODY MREM 1.65E-02 3.00 5.50E-01

4. THYROID MREM 3.98E-03 10.00 3.98E-02

5. KIDNEY MREM 9.11E-03 10.00 9.11E-02

6. LUNG MREM 5.00E-03 10.00 5.00E-02

7. GI-LLI MREM 6.60E-03 10.00 6.60E-02

~

Annual dose limits of APA-ZZ-01003, Section 9 Page 1 of 1 to ULNRC-05621 Attachment 2 AP A-ZZ-OI003, "Offsite Dose Calculation Manual" APA-ZZ-OI003 to ULNRC-05621 Page 1 of 77 Rev. 18 UNION E LECTRIC rij CALLAWAY PLANT OFF-SITE DOSE CALCULATION MANUAL OCTOBER 11, 2007 to ULNRC-05621 APA-ZZ-OI003 Page 2 of 77 Revision 018 October 11, 2007 CALLAWAY PLANT ADMINISTRATIVE PROCEDURE APA-ZZ-OI003 OFF-SITE DOSE CALCULATION MANUAL Minior Revision This procedure contains the following:

Pages 1 Through 65 Attachments Through Tables Through Figures Through Appendices Through Checkoff Lists Through This procedure has - - - - checkofflist(s) maintained in the mainframe computer.

Conversion of commitments to TRS referencelhidden text completed by Revision Number:

Non-TIS Commitments APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 3 of 77 Table of Contents 1 PURPOSE AND SCOPE .................................................................... 1 2 LIQUID EFFLUENTS ........................................................................ 2 2.1 Liquid Effluent Monitors .................................................................... 2 2.2 Calculation Of Liquid Effluent Monitor Setpoints ............................. 4 2.3 Liquid Effluent Concentration Measurements .................................... 6 2.4 Dose Due To Liquid Effluents ............................................................ 6 2.4.1 THE MAXIMUM EXPOSED INDIVIDUAL. ................................... 6 2.4.2 CALCULATION OF DOSE FROM LIQUID EFFLUENTS ............. 7 2.4.3

SUMMARY

, CALCULATION OF DOSE DUE TO LIQUID EFFLUENTS ....................................................................................... 8 2.5 Liquid Radwaste Treatment System .................................................... 8 2.6 Dose Factors ........................................................................................ 8 3 GASEOUS EFFLUENTS ................................................................. 13 3.1 Gaseous Effluent Monitors ............................................................... 13 3.2 Gaseous Effluent Monitor Setpoints ................................................. 14 3.2.1 TOTAL BODY DOSE RATE SETPOINT CALCULATIONS ....... 15 3.2.2 SKIN DOSE RATE SETPOINT CALCULATION ......................... 16 3.3 Calculation Of Dose And Dose Rate From Gaseous Effluents ......... 16 3.3.1.1 DOSE RATE FROM NOBLE GASES ............................................. 16 3.3.1.2 DOSE RATE FROM RADIONUCLIDES OTHER THAN NOBLE GASES ................................................................................ 17 3.3.2 DOSE DUE TO GASEOUS EFFLUENTS ...................................... 18 3.3.2.1 AIR DOSE DUE TO NOBLE GASES ............................................. 18 3.3.2.2 DOSE DUE TO RADIONUCLIDES OTHER THAN NOBLE GASES .............................................................................................. 19 3.4 Gaseous Radwaste Treatment System ............................................... 20 3.5 DOSE FACTORS ............................................................................. 20 4 DOSE AND DOSE COMMITMENT FROM URANIUM FUEL CYCLE SOURCES ................................................................ 44 4.1 Calculation Of Dose And Dose Commitment From Uranium Fuel Cycle Sources ............................................................................ 44 4.1.1 IDENTIFICATION OF THE MEMBER OF THE PUBLIC. ........... 44 4.1.2 TOTAL DOSE TO THE NEAREST RESIDENT ............................ 44 APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 4 of 77 Table of Contents 4.1.3 TOTAL DOSE TO THE CRITICAL RECEPTOR WITHIN THE SITE BOUNDARY .................................................................. 45 5 RADIOLOGICAL ENVIRONMENTAL MONITORING .............. 49 5.1 Description Of The Radiological Environmental Monitoring Program ............................................................................................. 49 5.2 Performance Testing Of Environmental Thermoluminescence Dosimeters ......................................................................................... 49 6 DETERMINATION OF ANNUAL AVERAGE AND SHORT TERM ATMOSPHERIC DISPERSION PARAMETERS ............... 49 6.1 Atmospheric Dispersion Parameters ................................................. 49 6.1.1 LONG-TERM DISPERSION ESTIMATES .................................... 49 6.1.2 DETERMINATION OF LONG-TERM DISPERSION ESTIMATES FOR SPECIAL RECEPTOR LOCATIONS .............. 50 6.1.3 SHORT TERM DISPERSION ESTIMATES ................................... 50 6.2 Annual Meteorological Data Processing ........................................... 51 7 REPORTING REQUIREMENTS ..................................................... 58 7.1 Annual Radiological Environmental Operating Report .................... 58 7.2 Annual RADIOACTIVE Effluent Release Report ........................... 58 8 IMPLEMENTATION OF ODCM METHODOLOGY (COMN 2791} .................................................................................. 59 9 RADIOACTIVE EFFLUENT CONTROLS (REC) ......................... 60 10 ADMINISTRATIVE CONTROLS ................................................... 61 10.1 Major Changes To Liquid And Gaseous Radwaste TreatmeNT Systems .............................................................................................. 61 10.2 Changes To The Offsite Dose Calculation Manual (ODCM)

(COMN 2815} .................................................................................. 61 11 REFERENCES ....................................................... """"'"''' ........ 62 APA-ZZ-OI003 to ULNRC-05621 Page 5 of 77 Rev. 018 Table of Contents FIGURES FIGURE 4.1 ...................................................................................................... 47 TABLES TABLE 2.1 ............................................................................................................ 9 TABLE 2.2 ............................................................ :............................................... 12 TABLE 3.1 ............................................................................................................ 21 TABLE 3.2 ............................................................................................................ 22 TABLE 3.3 - INHALATION PATHWAY .......................................................... 24 TABLE 3.3 - MEAT PATHWAy ........................................................................ 26 TABLE 3.3 - GRASS-COW-MILKPATHWAY ................................................ 28 TABLE 3.3 - GRASS-GOAT-MILKPATHWAY .............................................. 30 TABLE 3.3 - VEGETATION PATHWAy .......................................................... 32 TABLE 3.4 - INHALATION PATHWAY .......................................................... 34 TABLE 3.4 - MEAT PATHWAY ........................................................................ 36 TABLE 3.4 - GRASS-COW-MILK PATHWAY ................................................ 38 TABLE 3.4 - GRASS-GOAT-MILK PATHWAy .............................................. 40 TABLE 3.4 - VEGETATION PATHWAy .......................................................... 42 TABLE 6.1 ............................................................................................................ 52 TABLE 6.2 ............................................................................................................ 53 TABLE 6.3 ............................................................................................................ 54 TABLE 6.4 ............................................................................................................ 55 TABLE 6.5 ............................................................................................................ 56 TABLE 6.6 ............................................................................................................ 57

-111-APA-ZZ-01003 to ULNRC-05621 Page 6 of 77 Rev. 018 RECORD OF REVISIONS Rev. No. o Date: March 1983 Rev. No. 1 Date: November, 1983 Revised to support the current RETS submittal and to incorporate NRC Staff comments.

Rev. No. 2 Date: March, 1984 Revised to incorporate NRC Staff comments Rev. No. 3 Date: June, 1985 Revised to incorporate errata identified by ULNRC00803 and changes to the Environmental Monitoring Program Incorporate results of 1984 Land Use Census.

Rev. No. 4 Date: February, 1987 Minor clarifications, incorporated 31-day projected dose methodology. Change in the utilization of areas within the Site Boundary.

Rev. No. 5 Date: January, 1988 Minor clarifications, revised descriptions ofliquid and gaseous rad monitors, revised liquid setpoint methodology to incorporate monitor background, revised dose calculations for 40CFR190 requirements, Revised Table 6 and Figures 5.IA and 5.1B to refme descriptions of environmental TLD stations, incorporated description of environmental TLD testing required by Reg. Guide 4.13, revised Tables 1, 2, 4 and 5 to add additional nuclides, deleted redundant material from Chapter 6.

Rev. No. 6 Date: May, 1989 Revised methodology for calculating maximum permissible liquid effluent discharge rates and liquid effluent discharge rates and liquid effluent monitor setpoints, provided methodology for calculating liquid effluent monitors response correction factors, provided an enhanced description of controls on liquid monitor background limits, provided additional liquid and gaseous dose conversion factors and bioaccumulation factors (Tables 1,2,4 & 5), provided description of the use of the setpoint required by Technical Specification 4.9.4.2 during Core Alterations, added discussion of gaseous and liquid monitor setpoint selection in the event that the sample contains no detectable activity, added minimum holdup requirements for Waste Gas Decay tanks, revised dispersion parameters and accompanying description Per FSAR Change Notice 88-42.

APA-ZZ-01003 Rev. No. o Date: August, 1989 Radiological Effluent Technical Specifications were moved from the Callaway Plant Technical Specifications to Section 9.0, Radioactive Effluent Controls, of the ODCM Per NRC Generic Letter 89-

01. At the same time, in order to formalize control of the entire ODCM, it was converted to APA-ZZ-01003, OFF-SITE DOSE CALCULATION MANUAL.

Rev. No. 1 Date: October, 1990 Revise Action 41 of Table 9.2-A to allow continued purging for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Per Amendment 20 to operating license, issued 4/10/87.

-IV-APA-ZZ-01003 to ULNRC-05621 Page 7 of 77 Rev. 018 RECORD OF REVISIONS Rev. No. 2 Date: May, 1991 Section 2.4.2 - Changed gross alpha analysis frequency from "each batch" to a monthly composite Per Table 9.3-A, and the Callaway PlantNPDES permit (reissued March 15,1991).

Rev. No. 3 Date: June, 1993 Deleted HF-RE-45 and LE-RE-59 as effluent monitors. Revised table numbering for consistency with those in Section 9.0, deleted redundant material, incorporated 1992 Land Use Census results, moved LLD description to Attachment 1, moved REC Bases to Attachment 2. Deleted reporting requirements for solid radwaste, which are described in APA-ZZ-OI011, PROCESS CONTROL PROGRAM. Addressed compliance with 10 CFR 20.1301. Revised the dilution flow rate to allow values other than 5000 gpm, based on dilution flow monitor setpoint. Revised "MPC" terminology to "ECV". Added Action 46 to REC 9.2 to clarify actions for inoperable mid and high range WRGM Channels. Revised references to be consistent with the revised 10 CFR 20. Added Appendix A. Revised Action 41 of Rec 9.2 and the operability requirements ofGT-RE-22/33. Incorporated the revised Ri values in Tables 3.2 and 3.3.

Added Section 6.2 and Table 6.5.

Rev. No. 4 Date: September, 1994 Increased the minimum channels OPERABLE requirement ofREC 9.2 for GT-RE-22 & 33 from 1 channel to 2 channels. Revised Action 41 and the Bases for REC 9.2 accordingly. Incorporated the operability requirements from Tech Spec 3.9.9 into the Action statement for clarity. (Refer to CARS 199401176).

Rev. No. 5 Date: February, 1995 Removed the REMP station locations. Removed particulate nuclides with a half-life ofless than 8 days from Tables 3.2-3.4 and removed C 14 , p 32, Ni63 , Te 125m, and from Tables 2.1, 2.2,3.2,3.3, and 3.4.

Changed the reporting frequency of the Effluent Release Report from semiannual to annual. Removed the meat, milk and vegetable pathway dispersion parameters from Tables 6.1, 6.2, and 6.3, and clarified the applicability of the dispersion parameters and dose locations in Table 6.4. Relocated REC 9.1 and 9.2 to the FSAR. Revised footnotes 3 and 7 of Table 16.11-4 to require additional sampling of the Unit Vent in the event of a reactor power transient, only if the Unit Vent noble gas activity increases by a factor of 3 or greater. Added Section 4.1.3.1.3 for determination of dose due to the on-site storage oflow level radioactive waste.

Rev. No. 6 Date September, 1996 Section 2: Added dose factors (AiJfor Ag llOm, Np237, PU238 , PU2391240, Pu241 , Am241 , Cm242, and Cm234/244 to Table 2.1, and Bioaccumulation Factors (BfD for Ag, Pu, Am, and Cm to Table 2.2 due to a change in the liquid radwaste treatment process. Revised the description of the methodology for performing the 31 day dose projection in Section 2.5. Revised the maximum allowable background for HB-RE-18.

Section 3: Eliminated y91m and Tc 99m from Table 3.4 (Meat Pathway) due to a half-life of < 8 days.

Substituted the phrase "more restrictive" in lieu of "lesser" in Section 3.2. Revised the definition ofF. in equation 3 .1. Added description of use of samples to verify dose rates in Section 3.3.1.2. Augmented the definition of qi in Section 3.3.2.1. Edited equations 3.13 and 3.14 and added equation 3.15 to clarify dose calculations. Revised the methodology for performing the 31 day dose projection in Section 3.4.

Section 4: Strengthened the discussion of the reevaluation of assumptions in Section 4.1.3.

Section 6: Added new table 6.6 to describe the selection and use of dispersion parameters during the preparation of the Effluent Release Report. Updated Tables 6.1 and 6.2 to reference the 1995 Land Use Census. There were no changes in the receptor locations.

-v-APA-ZZ-01003 to ULNRC-05621 Page 8 of 77 Rev. 018 RECORD OF REVISIONS Section 8: Replaced the reference to HDP-ZZ-04500 to a more generic reference to the plant operating procedures, due to change in organizational structure and responsibilities.

Section 9: (1) Eliminated 9.0.1 and 9.0.2 due to redundancy with Technical Specifications 3.0.1 and 3.0.2; (2) Revised Table 9.3-A to incorporate sampling and analysis requirements for TRU nuclides in liquid effluents; (3) Eliminated sampling of Fuel Building Exhaust from Table 16.11-4 and the associated footnotes due to redundancy with Unit Vent sampling; revised the continuous sampling requirements for the gaseous batch release points consistent with plant design; revised the H3 analysis frequency for Purges from weekly to "prior to each purge"; and, (4) Revised the air sampling station location criteria on Table 9.11-A and footnote # 1, and eliminated footnote #3 in order to be less generic and more descriptive of the parameters used in determining the station locations (See CARS 199502280). Revised the location requirements for milk and vegetables. Revised description of use of baseline samples to trigger gamma isotopic analysis in footnote #4, revised requirement for location of downstream sample station in footnote

6. Revised Surveillance Requirement 9.10.2.1 to eliminate liquid effluents from the surveillance. (5)

Revised REC 9.5 and REC 9.9 to eliminate exceptions for partially tested effluents being released in excess of the respective limit.

Section 11: Added reference 11.14.13.

Attachment 2: Revised the Bases for REC 9.10 to support the elimination of liquid effluents from Surveillance 9.1 0.2.1.

The remaining changes are editorial in nature and have no technical impact.

(This revision implements CARS 199502055, CARS 199600167, CARS 199600961, CARS 199502280, and CARS 199600986).

Rev. No. 7 Date February, 1997 Section 9: (1) REC 9.5, "Liquid Radwaste Treatment System", Action statement: Eliminated reference to COMN 1161, (2) Table 9.11-A, items 4a (milk) and 4c (vegetation): revised to required control stations in the least prevalent wind direction. (See CARS 199700166)

Appendix A: revised the discussion relative to the appropriate gross alpha Effluent Concentration Value.

Rev. No. 8 Date May, 1997 Section 1: The Purpose and Scope was revised to describe the split of the ODCM into two sections Per FSAR Change Notice 95-058. Section 2: Sections 2.2 and 2.3 were revised to clarify the use of nuclide-specific alpha activity vice gross alpha activity for setpoint determination. Section 2.5 was revised to delete the description of the Liquid Radwaste Treatment System. Section 6: Tables 6.1, 6.2, and 6.3 were revised to reflect the results of the 1996 Annual Land Use Census. Section 7: The reporting requirements for the Annual Radiological Environmental Operating Report and the Effluent Release Report were relocated to the FSAR Per FSAR Change Notice 95-058. Section 9: REC's and the supporting Attachments 1 and 2 were relocated to the FSAR Per FSAR Change Notice 95-058. Appendix A:

Appendix A was deleted. Editorial changes were made throughout the ODCM reflecting the relocation of the REC's to the FSAR.

-Vl-APA-ZZ-OI003 to ULNRC-05621 Page 9 of 77 Rev. 018 RECORD OF REVISIONS Rev. No. 9 Date March, 1998 Section 2.5: Revised projected liquid dose calculation to use previous 31 day cumulative doses.

Section 3.1.1: Added GL-RE-202, Laundry Decon Facility Dryer Exhaust Monitor. Added action to be taken when the particulate and/or iodine grab sampler is not operable. Section 3.2: Added setpoint calculation for GL-RE-202.

Section 3.2.1 and 3.3.2.2: Changes were made to correct typographical errors and have no technical impact.

Section 3.4: Revised projected gas dose calculation to use previous 31 day cumulative doses.

Section 3.5: Removed the word secular from "secular equilibrium" since the equilibrium mode could be secular or transient depending on the isotope. Table 6.2: Added Laundry Decon Facility Dryer Exhaust to title of table since these will be the dispersion factors used for this release point.

Rev. No. 10 Date December 20, 1999 Section 3.1: Added explanation that GL-RE-202 only monitors particulate. Section 3.2: Changed Laundry Decon Facility Exhaust Monitor setpoint to less than or equal to 2000 cpm above equilibrium background with a maximum allowed background of 2000 cpm as calculated in HPCI 99-05. Tables 6.1, 6.2,6.3: Updated values as calculated in HPCI 99-02. Section 5.1: Defmed how REMP sample locations were determined. Removed reference to Plant Operating manual since it no longer exists.

Rev. No. 11 Date December 22, 1999 Changes required to go from old Technical Specifications to Improved Technical Specifications.

Technical Specification 4.9.4.2 changed to FSAR 16.11.2.4.1. Technical Specification 6.8.4.F changed to FSAR 16.11.4. Technical Specification 6.8.1.F changed to Improved Technical Specification 5.4.1.

Rev. No. 12 Date December 01, 2000 Section 2.1 and 2.2.1: Updated 10CFR20, Appendix B, Table II, Column 2 reference to the new 10CFR20 format. Corrected typo for 1If', flow setpoint should be undiluted waste flow rate. Section 3.2.1: Corrected typo, default value for safety factor should be 0.1. Section 5.1: Updated crosscheck program used to EML since EPA program is no longer available. Section 6.2: Added vertical height of highest adjacent building used to perform concurrent year annual average atmospheric dispersion (XlQ) calculations and reference for this value. This information should be documented in the ODCM. Added responsibility for validation of meteorological data, since responsibility has changed from engineering to HPTS. Section 10.1.1: Revised to require a summary of Major Radwaste System changes to be included in the annual report. This was done to be consistent with FSAR 16.11.5.2. Several changes were made throughout the procedure to correct typographical errors and have no technical impact.

Rev. No. 13 Date September 19, 2002 Section 3.2: Revised to implement the approved OL 1218, Rev. 1; License Amendment no. 152 allowing equipment hatch and emergency air lock to remain open during refueling activities (FSAR CN-01-030 and CN-02-049). The amendment eliminated FSAR 16.11.2.4.1B and subsequently deleted the core alteration setpoint value 5.0 E-3 !lCilcc for Containment Purge Monitors GT-RE-22 and GT-RE-33. The alarm setpoints for the Containment Purge Monitors will be based on the methodology described in Section 3 of theODCM.

-vu-AP A-ZZ-O 1003 to ULNRC-05621 Rev. 018 Page 10 of 77 RECORD OF REVISIONS Rev. No. 14 Date June 17, 2003 Revised Table 2.1 (Ingestion Dose Commitment Factor for Adult Age Group) to include dose factors for Pr-144. (CARS 200303251). Revised Section 4.1.3.1 to adjust the Fanner's residence (critical receptor) from 3830 meters in the SE sector to 2897 meters in the NNW sector. The Fanner's residence (critical receptor) was changed in 2002 to a location directly across the street from the Nearest residence. For conservatism and ease in calculation, Table 6.1 and 6.2 were revised making the distances and dispersion parameters for the Fanner's residence (critical receptor) and the Nearest residence the same. Revised section 7.2 to reference Table 6.6. Revised section 10.2.2 to remove the requirement for QA department review of the ODCM for reach revision (CARS 200304509). Added a reference to 11.14.14, Calculation HPCI 03-004 (Rev. 0), "Calculation of Liquid Effluent Dose Commitment factor for Pr-144 (Ait) for the Adult Age Group", June, 2003.

Rev. No. 15 Date December 9, 2004 Reformatted references to FSAR-SP Chapter 16.11 in section 1,2.1.1,2.1.2,2.2.1,2.3,2.4.2,2.5, 2.6,3.1,3.2.1,3.5,5.1,7.1,7.2, and 9. References to Ni-63 were added to section 2.2.1 for the calculation of ECVSUM, section 2.3, and described in section 2.6 since it is an exception to non gamma emitters not listed in FSAR-SP Table 16.11-1. Ni-63 was added to the ODCM based on previous 10 CFR 61 sample results and 2nd quarter liquid composite analyses.

Consolidated references listed in section 2.4.2 and 2.6 for the site related ingestion dose commitment factors (A,r) of Table 2.1 into HPCI 04-06, Revision 1. References to HPCIs 95-004 (Ref: 11.14.13) and 03-004 (Ref: 11.14.14) were deleted and replaced with HPCI 04-06, Revision 1 which is now listed as Ref: 11.14.13. Added Ni-63 and Sb-l22 to Table 2.1- INGESTION DOSE COMMITMENT FACTOR (A,r) FOR ADULT AGE GROUP. Revised the reference for Table 2.1 to 11.14.13.

Corrected a typo in section 3.1.2 referring to the Radwaste Building Vent system designator as GT vs. GH (CAR 200406851).

References 11.19 and 11.20 were deleted in section 4.1.3.1.1. Reference 11.18 was changed to MICROSHIELD (Grove Engineering, Inc.) vs. ISOSHLD. Reference 11.24 in section 4.1.3.1.3 was corrected to 11.18.

Section 5.1 and 5.2 were revised to indicate that the Radiological Environmental Monitoring Program TLDs will be processed and provided by a vendor laboratory beginning in the fIrst quarter of 2005.

Section 5.2 was revised to delete reference 11.14.10 which refers to HPCI 88-08, "Performance Testing of the Environment TLD System at Callaway Plant", August 1989.

Reference 11.14.7 was corrected with HPCI 87-10 vs. 88-10. Revised Table 6.1, Note (c) to reference FSAR TABLE 2.3-83 vs. TABLE 2.3-82. Revised Table 6.1 and 6.2 Note (b) to reference data is from the 2002 Land Use Census.

Changed and/or corrected the Skin dose factor (Li) units in Table 3.1 (Dose Factor for exposure to a Semi-Infmite Cloud of Noble Gases) to rnremlyr per uCi/m3

Revised section 3.3.1.2: Added units for the tenn BR in m 3/yr.

Removed paragraph in section 3.3.2.2 that describes actions for implementing the use of appropriate R1,ij values. This paragraph was taken directly from section 5.3.1 ofNUREG 0133, U.S. Nuclear Regulatory Commission, "Preparation of Radiological Effluent Technical SpecifIcation for Nuclear Power Plants", USNRC NUREG-0133, Washington, D.C. 20555, October, 1978. This paragraph does not apply since the use of pathways is already considered as described in sections 4.1.2 and 4.1.3.1.

-V111-APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 11 of 77 RECORD OF REVISIONS Revised note (c) of Table 6.1 to reference FSAR-SA Table 2.3-83. Revised note (a) from Table 6.1 to reference FSAR-SA Table 2.3-82. In addition, revised Note (b) from Table 6.1 to reference data taken from the 2002 Land Use Census. Revised Notes (a) and (c) from Table 6.2 to reference FSAR-SA Table 2.3-84 and 2.3-81 respectively.

Added a 0.95 conservatism factor to section 2.2.3 - Calculation of Liquid Effluent Monitor Setpoint.

This will conservatively reduce the liquid monitor setpoint to further ensure the section 4.4.1 ofNUREG 0133, U.S. Nuclear Regulatory Commission, "Preparation of Radiological Effluent Technical Specification for Nuclear Power Plants", USNRC NUREG-0133, Washington, D.C. 20555, October, 1978 which states the alarm and trip setpoints for each instrument channel listed in Table 3.3-11 should be provided and should correspond to a value( s) which represents a safe margin of assurance that the instantaneous liquid release limit of 10 CFR Part 20 is not exceeded.

A determination was made IAW TIS 5.5.1 that the associated changes with Revision 15 maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50 Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

Rev. No. 16 Date December 1, 2005 Section 5.1 was revised to remove an invalid requirement that a third-party laboratory performing analysis specifically state the Interlaboratory Comparison (crosscheck) requirements for the Radiological Environmental Monitoring Program (REMP) contract lab. Reference 11.14.14 to Reg. Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment, was added to provide supporting documentation for contract lab Interlaboratory Comparison requirements. Additional information on REMP contract lab participation in Interlaboratory Comparisons was also added in section 5.1. (CAR 200500891)

Revised reference 11.14.7 by adding normalization and standardization factors for radionuclides listed in Table 2.1 of the ODCM that were not included in the original calculation.

Added section 4.1.3.1.4 to describe direct dose to a MEMBER OF THE PUBLIC from the Old Steam Generator Storage Facility (OSGSF).

Reworded step 4.1.2 to describe the sources of direct radiation from "outside storage tanks" to "storage of radioactive material".

Revised section 4.1.3.1.2 to include and describe direct dose calculations in support of Modification 03-1008, Equipment Hatch Platform and Missile Shield Modification. Reference 11.14.10 was added to reference direct dose calculation to the MEMBER OF THE PUBLIC from Modification 03-1008.

Revised section 4.1.3.1.3 to include and describe direct dose calculations from the Radwaste Yard RAM storage and Stores II. Reference 11.19 and 11.20 were added to reference direct dose calculations to the MEMBER OF THE PUBLIC from RAM storage at Stores II and the Radwaste Yard.

A determination was made IAW TIS 5.5.1 that the associated changes with Revision 16 maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50 Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

-lX-to ULNRC-05621 AP A-ZZ-Ol 003 Page 12 of 77 Rev. 018 RECORD OF REVISIONS Rev. No. 17 Date March 14, 2007 Section 2.4.1 was revised Per CAR 200701309 to state that no potable water intakes exist within 10 miles of the plant discharge point. This is due to the fact that the Annual Land Use Census ensures no newly developed potable water intakes within 10 miles of the plant discharge Per FSAR-SP Chapter 16.11.4.2c.

Section 2.4.2 was revised to add reference 11.6.18 to CAR 200700053 which provides documentation of an evaluation of the site specific mixing factor for liquid effluents. Modification 06-0061 reconfigured the plant discharge terminus at the Missouri River. The modification was completed in January 2007.

Rev. No. 18 Date October 11, 2007 Revised Table 6.5 was revised to reflect upgrade/replacement of the primary meteorological tower instrumentation as per Modification Package 04-1020.

Section 2.4.2 was revised to remove the discussion of the nearest municipal potable water intake downstream from the liquid effluent discharge point as being located near the city of St. Louis, Missouri, approximately 78 miles downstream. Since the Land Use Census annually verifies no potable water intakes within 10 miles - this discussion was deemed inappropriate in describing methodology for calculating dose to the public from liquid effluents. In addition, the distance referenced as not having potable water intakes downstream of the plant discharge was changed for consistency with section 2.4.1 and the Land Use Census.

-x-APA-ZZ-OI003 to ULNRC-05621 Page 13 of 77 Rev. 018 OFF-SITE DOSE CALCULATION MANUAL 1 PURPOSE AND SCOPE The OFF-SITE DOSE CALCULATION MANUAL (ODCM) describes the methodology and parameters used in the calculation of off-site doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Radiological Environmental Monitoring Program. The ODCM also contains the Radioactive Effluent Controls and Radiological Environmental Monitoring Program required by TIS AC 5.5.4 and FSAR-SP CHAPTER 16.11.4, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Effluent Release Reports required by TIS AC 5.6.2 and TIS AC 5.6.3.

Compliance with the Radiological Effluent Controls limits demonstrates compliance with the limits of 10 CFR 20.1301. (Ref. 11.1.1, 11.2.1, 11.23.3)

The ODCM consists of two parts: FSAR-SP CHAPTER 16.11 which contains the Radiological Effluent Controls (REC's), and APA-ZZ-01003, which contains the methodology and parameters used to implement the REC's.

APA-ZZ-OI003 to ULNRC-05621 Page 14 of 77 Rev. 018 2 LIQUID EFFLUENTS 2.1 LIQUID EFFLUENT MONITORS Gross radioactivity monitors which provide for automatic termination ofliquid effluent releases are present on the liquid effluent lines. Flow rate measurement devices are present on the liquid effluent lines and the discharge line (cooling tower blowdown). Setpoints, precautions, and limitations applicable to the operation of the Callaway Plant liquid effluent monitors are provided in the appropriate Plant Procedures. Setpoint values are calculated to assure that alarm and trip actions occur prior to exceeding ten times the Effluent Concentration Values (ECV) limits in 10 CFR Part 20 at the release point to the UNRESTRICTED AREA. The calculated alarm and trip action setpoints for the liquid effluent line monitors and flow measuring devices must satisfy the following equation:

cf

C F + f Where

C The liquid effluent concentration value (ECV) implementing REC 16.11.1.1 for the site in (IlCiJrnl).

c The setpoint, in (IlCiJrnl), of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution and subsequent release; the setpoint, which is inversely related to the volumetric flow of the effluent line and directly related to the volumetric flow of the dilution stream plus the effluent steam, represents a value, which, if exceeded, would result in concentrations exceeding ten times the values of 10 CFR Part 20 Appendix B, Table 2, Column 2, in the UNRESTRICTED AREA.

f The undiluted waste flow rate as measured at the radiation monitor location, in volume per unit time, but in the same units as F, below.

F The dilution water flow rate setpoint as measured prior to the release point, in volume per unit time. {If (F) is large compared to (t), then F + f= F}.

(Ref. 11.8.1)

If no dilution is provided then c :s c.

The radioactive liquid waste stream is diluted by the plant discharge line prior to entry into the Missouri River. Normally, the dilution flow is obtained from the cooling tower blowdown, but should this become unavailable, the plant water treatment facility supplies the necessary dilution flow via a bypass line. The limiting concentration which corresponds to the liquid radwaste effluent monitor setpoint is to be calculated using methodology from the expression above.

Thus, the expression for determining the setpoint of the liquid radwaste effluent line monitor becomes:

c :::; C(F + f) (uCi / m!) (2.2) f The alannltrip setpoint calculations are based on the minimum dilution flow rate (corresponding to the dilution flow rate setpoint), the maximum effluent stream flow rate, and the actual isotopic analysis. Due to the possibility of a simultaneous release from more than one release pathway, a portion of the total site release limit is allocated to each pathway. The determination and usage of the allocation factor is discussed in Section 2.2. In the event the alannltrip setpoint is reached, an evaluation will be performed using actual dilution and effluent flow values and actual isotopic analysis to ensure that REC 16.11.1.1 limits were not exceeded.

APA-ZZ-01003 to ULNRC-05621 Page 15 of 77 Rev. 018 2.1.1 Continuous Liquid Effluent Monitors The radiation detection monitor associated with continuous liquid effluent releases is (Ref. 11.6.1, 11.6.2):

Monitor I.D. Description BM-RE-52 Steam Generator Blowdown Discharge Monitor The Steam Generator Blowdown discharge is not considered to be radioactive unless radioactivity has been detected by the associated effluent radiation monitor or by laboratory analysis. The sampling frequency, minimum analysis frequency, and type of analysis performed are Per FSAR-SP TABLE 16.11-1.

2.1.2 Radioactive Liquid Batch Release Effluent Monitors The radiation monitor which is associated with the liquid effluent batch release system is (Ref 11.6.4):

Monitor I.D. Description HB-RE-18 Liquid Radwaste Discharge Monitor This effluent stream is normally considered to be radioactive. The sampling frequency, minimum analysis frequency, and the type of analysis performed are Per FSAR-SP TABLE 16.11-1.

APA-ZZ-OI003 to ULNRC-05621 Page 16 of 77 Rev. 018 2.2 CALCULATION OF LIOUID EFFLUENT MONITOR SETPOINTS The dependence of the setpoint (c), on the radionuclide distribution, yields, calibration, and monitor parameters, requires that several variables be considered in setpoint calculations. (Ref. 11.8.1) 2.2.1 Calculation of the ECV Sum The isotopic concentration of the release(s) being considered must be determined. This is obtained from the analyses required per FSAR-SP TABLE 16.11-1, and is used to calculate an ECV sum (ECVSUM):

ECVSUM g, a, s, t, f (2.3)

Where:

Cg = the concentration of each measured gamma emitting nuclide observed by gamma-ray spectroscopy of the waste sample.

Ca *= the concentration ofNp 237, PU 238 , PU239/240, PU241 , Am24\ Cm242 , & Cm243/244, in the quarterly composite sample.

C*=s the measured concentrations ofSr-89 and Sr-90 as determined by analysis of the quarterly composite sample.

the measured concentration ofH-3 in the waste sample.

the measured concentration of Fe-55 & Ni-63 as determined by analysis of the quarterly composite sample.

ECVg' ECVs' ECV a, ECVf' ECVt = are ten times the limiting concentrations of the appropriate radionuclides from 10 CFR 20, Appendix B, Table 2, Column 2. For dissolved or entrained noble gases, the concentration shall be limited to 2xlO- 4 /-lCiJrnl total activity.

For the case ECVSUM :::;1, the monitor tank effluent concentration meets the limits ofREC 16.11.1.1 without dilution and the effluent may be released at any desired flow rate. If ECVSUM > 1 then dilution is required to ensure compliance with the concentration limits REC 16.11.1.1. If simultaneous releases are occurring or are anticipated, an allocation fraction, N, must be applied so that available dilution flow may be apportioned among simultaneous discharge pathways. The value ofN may be any value between 0 and 1 for a particular discharge point, provided that the sum of the allocation fractions for all discharge points must be :::; 1.

2.2.2 Calculation of the Maximum Permissible Liquid Effluent Discharge Flowrate The maximum permissible liquid effluent discharge flowrate is calculated by:

fmax :::; (F + fp) (SF) (N) + (ECVSUM) (2.4)

Where:

fmax maximum permissible liquid effluent discharge flowrate, (in gallons/minute);

fp the expected undiluted liquid effluent flowrate, in gpm.

N the allocation fraction which apportions dilution flow among simultaneous discharge pathways (see discussion above)

SF the safety factor; an administrative factor used to compensate for statistical fluctuations and errors of measurements. This factor also provides a margin of safety in the calculation of the maximum liquid effluent discharge flowrate (fmax )' The value of SF should be S 1.

F & ECVSUM, are previously defmed.

The dilution water supply is furnished with a flow monitor which isolates the liquid effluent discharge if the dilution flow rate falls below its setpoint value .

Values for these concentrations are based on previous composite sample analyses as required by FSAR-SP Table 16.11-1.

APA-ZZ-01003 to ULNRC-05621 Page 17 of 77 Rev. 018 In the event that fmax is less than fp, then the value of fmax is substituted into the equation for fp' and a new value of fmax is calculated. This substitution is perfonned for three iterations in order to calculate the correct value of fmax.

2.2.3 Calculation Of Liquid Effluent Monitor Setpoint The liquid effluent monitors are NaI(TI) based systems and respond primarily to gamma radiation. Accordingly, their setpoint is based on the total concentration of gamma emitting nuclides in the effluent:

c = (BKG + ( L: (Cg) .;- SF >>(0.95) = flCiJrnl (2.5)

Where:

c the monitor setpoint as previously defmed, in (flCiJrnl);

BKG the monitor background prior to discharge, in (flCiJrnl) adjusted for monitor response.

0.95 Conservatism to ensure monitor trips prior to REC 16.11.1.1 (L: (C g) and SF are as previously defmed.

The monitor's background is controlled at an appropriate limit to ensure adequate sensitivity.

Utilizing the methodology of ANSI N13.1O-1974 (Ref. 11.21), the background must be maintained at a value ofless than or equal to 9E-6 flCiJrnl (relative to Cs-137) in order to detect a change of 4E-7 flCiJrnl ofCs-137. (Ref. 11.25).

In the event that there is no detectable gamma activity in the effluent or if the value of (L:( Cg) .;- SF) is less than the background of the monitor, then the monitor setpoint will be set at twice the current background of the monitor.

As previously stated, the monitor's response is dependent on the gamma emitting radionuclide distribution of the effluent. Accordingly, a new database conversion factor is calculated for each release based upon the results of the gamma spectrometric analysis of the effluent sample and the measured response of the monitor to National Institute of Standards and Technology (NIST) traceable calibration sources:

DBCFc = (2:( C g )) .;- (CMR) x (ECF) (2.6)

DBCFc the monitor data base conversion factor which converts count rate into concentration (flCiJrnl);

CMR the calculated response of the radiation monitor to the liquid effluent; ECF the conversion factor for Cs-137, which converts count rate into concentration (flCiJrnl).

Cg is as previously defmed.

The new value of the DBCF c is calculated and entered into the monitor data base prior to each discharge. A more complete discussion of the derivation and calculation of the CMR is given in reference 11.14.7.

APA-ZZ-01003 to ULNRC-05621 Page 18 of 77 Rev. 018 2.3 LIQUID EFFLUENT CONCENTRATION MEASUREMENTS Liquid batch releases are discharged as a discrete volume and each release is authorized based upon the sample analysis and the dilution flow rate existing in the discharge line at the time of release. To assure representative sampling, each liquid monitor tank is isolated and thoroughly mixed by recirculation of tank contents prior to sample collection. The methods for mixing, sampling, and analyzing each batch are outlined in applicable plant procedures. The allowable release rate limit is calculated for each batch based upon the pre-release analysis, dilution flow-rate, and other procedural conditions, prior to authorization for release. The liquid effluent discharge is monitored prior to entering the dilution discharge line and will automatically be terminated if the pre-selected a1ann/trip setpoint is exceeded. Concentrations are determined primarily from the gamma isotopic and H-3 analyses of the liquid batch sample. For Sr89, Sr90 ,

Fe55 , Ni 63 , Np237, PU238 , PU239/240, PU241 , Am241 , Cm242 , & Cm243/244, the measured concentrations from the previous quarterly composite analyses are used unti11aboratory results become available. Composite samples are collected for each batch release and analyzed in accordance with FSAR-SP TABLE 16.11-1. The dose from liquids discharged as continuous releases is calculated by utilizing the last measured values of samples in accordance with FSAR-SP TABLE 16.11-1.

2.4 DOSE DUE TO LIQUID EFFLUENTS 2.4.1 THE MAXIMUM EXPOSED INDIVIDUAL The cumulative dose determination considers the dose contributions from the maximum exposed individual's consumption offish and potable water, as appropriate. Normally, the adult is considered to be the maximum exposed individual. (Ref. 11.8.3)

The Callaway Plant's liquid effluents are discharged to the Missouri River. As there are no potable water intakes within 10 miles of the discharge point (Ref. 11.7.1, 11.6.6), this pathway does not require routine evaluation. Therefore, the dose contribution from fish consumption is expected to account for more than 95% of the total man-rem dose from discharges to the Missouri River. Dose from recreational activities is expected to contribute the additional 5%,

which is considered to be negligible. (Ref. 11.6.7)

APA-ZZ-01003 to ULNRC-05621 Page 19 of 77 Rev. 018 2.4.2 CALCULATION OF DOSE FROM LIQUID EFFLUENTS The dose contributions for the total time period.

m L~tl 1=1 are calculated at least once each 31 days and a cumulative summation of the total body and individual organ doses is maintained for each calendar quarter. Dose is calculated for all radionuclides identified in liquid effluents released to UNRESTRICTED AREAS using the following expression (Ref. 11.8.3):

D, ~ ~[AI' t !>.I, C" FI] (2.12)

Where:

D't the cumulative dose commitment to the total body or any organ, 't, from the liquid effluents for the total period m

L~tl 1=1 mmrem.

the length of the I the time period over which Ci 1 and Flare averaged for all liquid releases, in hours. ~t 1 corresponds to the actual duration of the release(s).

the average measured concentration of radionuclide, i, in undiluted liquid effluent during time period M 1 from any liquid release, in (/-lCiJrnl).

Ai'! the site related ingestion dose commitment factor to the total body or any organ 't for each identified principal alpha, gamma and beta emitter listed in FSAR-SP TABLE 16.11-1, (in mremlhr) per (/-lCiJrnl). The calculation of the Ai't values given in Table 2.1 are detailed in Re£ 11.14.13.

F1 the near field average dilution factor for Ci 1 during any liquid effluent release:

F =

f max 1 (F+fmaJ89.77 Where:

fmax maximum undiluted effluent flow rate during the release F average dilution flow 89.77 site specific applicable factor for the mixing effect of the discharge structure.

(Ref. 11.5.1, 11.14.12, and 11.6.18)

The term Ci 1 is the undiluted concentration of radioactive material in liquid waste at the common release point determined in accordance with REC 16.11.1.1, Table 16.11-1, "Radioactive Liquid Waste Sampling and Analysis Program". All dilution factors beyond the sample point(s) are included in the F 1 term.

APA-ZZ-OI003 to ULNRC-05621 Page 20 of 77 Rev. 018 As there are currently no potable water intakes within 10 river miles of the discharge point, the drinking water pathway is not included in dose estimates to the maximally exposed individual.

Should future potable water intakes be constructed within 10 river miles downstream of the discharge point, then this manual will be revised to include this pathway in dose estimates.

(Ref. 11.6.6).

2.4.3

SUMMARY

, CALCULATION OF DOSE DUE TO LIQUID EFFLUENTS The dose contribution for the total time period m

IL\tl 1=1 is determined by calculation at least once per 31 days and a cumulative summation of the total body and organ doses is maintained for each calendar quarter. The projected dose contribution from liquid effluents for which radionuclide concentrations are determined by periodic composite and grab sample analysis, may be approximated by using the last measured value.

Dose contributions are determined for all radionuclides identified in liquid effluents released to UNRESTRICTED AREAS. Nuclides which are not detected in the analyses are reported as "less than" the nuclide's Minimum Detectable Activity (MDA) and are not reported as being present at the Lower Level of Detection (LLD) level for that nuclide. The "less than" values are not used in the dose calculations.

2.5 LIQUID RADWASTE TREATMENT SYSTEM The LIQUID RADWASTE TREATMENT SYSTEM is described in FSAR-SP CHAPTER 11.2.

The OPERABILITY of the LIQUID RADWASTE TREATMENT SYSTEM ensures this system will be available for use when liquids require treatment prior to their release to the environment.

OPERABILITY is demonstrated through compliance with REC 16.11.1.1. and 16.11.1.2.

Projected doses due to liquid releases to UNRESTRICTED AREAS are determined each 31 days. The prior 31 day period is used to calculate compliance. This may be modified as appropriate to account for changes in radwaste treatment which may have a significant effect on the projected doses.

2.6 DOSE FACTORS The dose conversion factors provided in Table 2.1 were derived from the appropriate dose conversion factors of Regulatory Guide 1.109, Table 2.2 and other sources as necessary (Ref: 11.14.13) Non-gamma emitting nuclides, other than those listed in FSAR-SP TABLE 16.11-1 and Ni-63 will not be considered.

APA-ZZ-OI003 to ULNRC-05621 Page 21 of 77 Rev. 018 TABLE 2.1 INGESTION DOSE COMMITMENT FACTOR (Ai-c) FOR ADULT AGE GROUP (mremlhr) per (flCilml)

Nuclide ~ Liver Total Ibl;mid Kiduel; GI-LLI

~

H-3 No Data 2.26E-Ol 2.26E-Ol 2.26E-Ol 2.26E-Ol 2.26E-Ol 2.26E-Ol Be-7 1.31E-02 2.98E-02 1.45E-02 No Data 3.15E-02 No Data 5.17E+00 Na-24 4.07E+02 4.07E+02 4.07E+02 4.07E+02 4.07E+02 4.07E+02 4.07E+02 Cr-51 No Data No Data 1.27E+00 7.61E-Ol 2.81E-Ol 1. 69E+00 3.20E+02 Mn-54 No Data 4.38E+03 8.35E+02 No Data 1.30E+03 No Data 1.34E+04 Mn-56 No Data 1.10E+02 1.95E+Ol No Data 1.40E+02 No Data 3.51E+03 Fe-55 6.58E+02 4.55E+02 1.06E+02 No Data No Data 2.54E+02 2.61E+02 Fe-59 1.04E+03 2.44E+03 9.36E+02 No Data No Data 6.82E+02 8. 14E+03 Co-57 No Data 2.09E+Ol 3.48E+Ol No Data No Data No Data 5.31E+02 Co-58 No Data 8.92E+Ol 2.00E+02 No Data No Data No Data 1.81E+03 Co-60 No Data 2.56E+02 5.65E+02 No Data No Data No Data 4.81E+03 Ni-63 3. 11E+04 2.16E+03 1.04E+03 No Data No Data No Data 4.50E+02 Ni-65 1.26E+02 1. 64E+01 7.49E+00 No Data No Data No Data 4.17E+02 Cu-64 No Data 9.97E+00 4.68E+00 No Data 2.51E+Ol No Data 8.50E+02 Zn-65 2.32E+04 7.37E+04 3.33E+04 No Data 4.93E+04 No Data 4.64E+04 Zn-69 4.93E+Ol 9.43E+Ol 6.56E+00 No Data 6.13E+Ol No Data 1.42E+Ol Br-82 No Data No Data 2.27E+03 No Data No Data No Data 2.60E+03 Br-83 No Data No Data 4.04E+Ol No Data No Data No Data 5.82E+Ol Br-84 No Data No Data 5.24E+Ol No Data No Data No Data 4.11E-04 Br-85 No Data No Data 2.15E+00 No Data No Data No Data 1.01E-15 Rb-86 No Data 1.01E+05 4.71E+04 No Data No Data No Data 1.99E+04 Rb-88 No Data 2.90E+02 1.54E+02 No Data No Data No Data 4.00E-09 Rb-89 No Data 1.92E+02 1.35E+02 No Data No Data No Data 1.12E-ll Sr-89 2.21E+04 No Data 6.35E+02 No Data No Data No Data 3.55E+03 Sr-90 5.44E+05 No Data 1.34E+05 No Data No Data No Data 1.57E+04 Sr-91 4.07E+02 No Data 1. 64E+01 No Data No Data No Data 1.94E+03 Sr-92 1.54E+02 No Data 6.68E+00 No Data No Data No Data 3.06E+03 Y-90 5.76E-Ol No Data 1.54E-02 No Data No Data No Data 6.10E+03 Y-91M 5.44E-03 No Data 2.11E-04 No Data No Data No Data 1.60E-02 Y-91 8.44E+00 No Data 2.26E-Ol No Data No Data No Data 4.64E+03 Y-92 5.06E-02 No Data 1.48E-03 No Data No Data No Data 8.86E+02 Y-93 1.60E-Ol No Data 4.43E-03 No Data No Data No Data 5.09E+03 Zr-95 2.40E-Ol 7.70E-02 5.21E-02 No Data 1.21E-Ol No Data 2.44E+02 Zr-97 1.33E-02 2.68E-03 1.22E-03 No Data 4.04E-03 No Data 8.30E+02 Nb-95 4.47E+02 2.48E+02 1.34E+02 No Data 2.46E+02 No Data 1.51E+06 Mo-99 No Data 1.03E+02 1.96E+Ol No Data 2.34E+02 No Data 2.39E+02 Tc-99M 8.87E-03 2.51E-02 3.19E-Ol No Data 3.81E-Ol 1.23E-02 1.48E+Ol Tc-l0l 9.12E-03 1.31E-02 1.29E-Ol No Data 2.37E-Ol 6.72E-03 3.95E-14 APA-ZZ-01003 to ULNRC-05621 Page 22 of 77 Rev. 018 TABLE 2.1 (Cont'd)

INGESTION DOSE COMMITMENT FACTOR (Ah) FOR ADULT AGE GROUP (mrem/hr) per (IlCilml)

Nuclide B!rne Liver Total Ihl;[oid Kiduel; GI-LLI

~

Ru-103 4.43E+00 No Data 1.91E+00 No Data 1.69E+Ol No Data 5.17E+02 Ru-105 3.69E-Ol No Data 1.46E-Ol No Data 4.76E+00 No Data 2.26E+02 Ru-l06 6.58E+01 No Data 8.33E+00 No Data 1.27E+02 No Data 4.26E+03 Cd-109 No Data 5.55E+02 1.94E+01 No Data 5.31E+02 No Data 5.60E+03 Ag-I10m 8.85E-01 8.18E-01 4.86E-01 No Data 1.6IE+00 No Data 3.34E+02 Sn-l13 5.67E+04 1.61E+03 3.26E+03 9.19E+02 No Data No Data 1.69E+05 Sb-l22 5.48E-01 1.12E-02 1.66E-01 7.73E-03 No Data 2.94E-01 NoData Sb-124 6.70E+00 1.27E-01 2.66E+00 1.63E-02 No Data 5.22E+00 1.90E+02 Sb-125 4.29E+00 4.79E-02 1.02E+00 4.36E-03 No Data 3.30E+00 4.72E+01 Te-127m 6.48E+03 2.32E+03 7.90E+02 1.66E+03 2.63E+04 No Data 2.17E+04 Te-127 1.05E+02 3.78E+01 2.28E+Ol 7.80E+01 4.29E+02 No Data 8.31E+03 Te-129M 1.10E+04 4. 11E+03 1.74E+03 3.78E+03 4.60E+04 No Data 5.54E+04 Te-129 3.01E+01 1. 13E+01 7.33E+00 2.31E+01 1.26E+02 No Data 2.27E+01 Te-131M 1. 66E+03 8.10E+02 6.75E+02 1.28E+03 8.21E+03 No Data 8.04E+04 Te-131 1. 89E+01 7.88E+00 5.96E+00 1.55E+01 8.26E+Ol No Data 2.67E+00 Te-132 2.41E+03 1.56E+03 1.47E+03 1.72E+03 1.50E+04 No Data 7.38E+04 1-130 2.71E+Ol 8.0IE+01 3.16E+Ol 6.79E+03 1.25E+02 No Data 6.89E+Ol 1-131 1.49E+02 2.14E+02 1.22E+02 7.00E+04 3.66E+02 No Data 5.64E+01 1-132 7.29E+00 1.95E+01 6.82E+00 6.82E+02 3.11E+01 No Data 3.66E+00 1-133 5.14E+01 8.87E+01 2.70E+01 1.30E+04 1.55E+02 No Data 7.97E+01 1-134 3.81E+00 1.03E+01 3.70E+00 1. 79E+02 1. 64E+01 No Data 9.01E-03 1-135 1.59E+01 4.17E+01 1.54E+01 2.75E+03 6.68E+01 No Data 4.70E+01 Cs-134 2.98E+05 7.09E+05 5.79E+05 No Data 2.29E+05 7.61E+04 1.24E+04 Cs-136 3.12E+04 1.23E+05 8.86E+04 No Data 6.85E+04 9.38E+03 1.40E+04 Cs-137 3.82E+05 5.22E+05 3.42E+05 No Data 1.77E+05 5.89E+04 1.01E+04 Cs-138 2.64E+02 5.22E+02 2.59E+02 No Data 3.84E+02 3.79E+01 2.23E-03 Ba-139 9.29E-Ol 6.62E-04 2.72E-02 No Data 6. 19E-04 3.75E-04 1.65E+00 Ba-140 1.94E+02 2.44E-01 1.27E+01 No Data 8.30E-02 1.40E-01 4.00E+02 Ba-141 4.51E-01 3.4IE-04 1.52E-02 No Data 3.17E-04 1.93E-04 2. 13E-lO Ba-142 2.04E-Ol 2.lOE-04 1.28E-02 No Data 1.77E-04 1.19E-04 2.87E-19 La-140 1.50E-01 7.54E-02 1.99E-02 No Data No Data No Data 5.54E+03 La-142 7.66E-03 3.48E-03 8.68E-04 No Data No Data No Data 2.54E+01 Ce-141 2.24E-02 1.52E-02 1.72E-03 No Data 7.04E-03 No Data 5.79E+01 Ce-143 3.95E-03 2.92E+00 3.23E-04 No Data 1.29E-03 No Data 1.09E+02 Ce-144 1.17E+00 4.88E-01 6.27E-02 No Data 2.90E-01 No Data 3.95E+02 Pr-143 5.5IE-01 2.21E-01 2.73E-02 No Data 1.27E-01 No Data 2.41E+03 Pr-144 1.80E-03 7.48E-04 9.16E-05 No Data 4.22E-04 No Data 2.59E-I0 Nd-147 3.76E-Ol 4.35E-Ol 2.60E-02 No Data 2.54E-Ol No Data 2.09E+03 Eu-154 3.68E+Ol 4.52E+00 3.22E+00 No Data 2.17E+Ol No Data 3.28E+03 Hf-181 4.00E-02 1.94E-Ol 1.80E-02 No Data 4.18E-02 No Data 2.21E+02 W-187 2.96E+02 2.47E+02 8.65E+Ol No Data No Data No Data 8.lOE+04 APA-ZZ-01003 to ULNRC-05621 Page 23 of 77 Rev. 018 TABLE 2.1 (Cont'd)

INGESTION DOSE COMMITMENT FACTOR (Ai'!) FOR ADULT AGE GROUP (mrem/hr) per (/lCilml)

Nuclide B..o.n.e Liver Total Ih~roid KidDe~ GI-LLI

~

Np-237 3.28E+04 2.8SE+03 l.33E+03 No Data 9.86E+03 No Data 1.90E+03 Np-239 2.8SE-02 2.80E-03 l.54E-03 No Data 8.74E-03 No Data S.7SE+02 Pu-238 S.7OE+03 8.03E+02 1.43E+02 No Data 6. 13E+02 No Data 6.12E+02 Pu-239' 6.S9E+03 8.88E+02 1.60E+02 No Data 6.80E+02 No Data S.68E+02 Pu-241 l.38E+02 7.07E+OO 2.78E+OO No Data 1.28E+01 No Data 1.17E+01 Am-241 4.90E+04 1.72E+04 3.24E+03 No Data 2.44E+04 No Data 4.44E+03 Cm-242 1.23E+03 1.26E+03 8.20E+01 No Data 3.72E+02 No Data 4.74E+03 Cm-243** 3.82E+04 1.44E+04 2.24E+03 No Data l.OSE+04 No Data 4.67E+03

Includes Pu-240 contribution

- Includes Cm-244 contribution APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 24 of 77 TABLE 2.2 BIOACCUMULAnON FACTOR (B9-~

(pCilkg) per (pCi/liter)

Bfi Element Fish (Freshwater)

H 9.0E-01 Be 2.0 E + 00 Na 1.0 E + 02 Cr 2.0 E + 02 Mn 4.0 E + 02 Fe 1.0 E + 02 Co 5.0 E + 01 Ni 1.0 E + 02 Cu 5.0 E + 01 Zn 2.0 E + 03 Br 4.2 E + 02 Rb 2.0 E + 03 Sr 3.0 E + 01 y 2.5E+01 Zr 3.3 E + 00 Nb 3.0 E + 04 Mo 1.0E+01 Tc l.5E+01 Ru 1.0E+01 Rh 1.0E+01 Ag 2.3 E + 00 Cd 2.0 E+ 02 Sn 3.0 E+ 03 Sb 1.0 E + 00 Te 4.0 E + 02 I l.5E+01 Cs 2.0 E + 03 Ba 4.0 E + 00 La 2.5 E+ 01 Ce 1.0 E + 00 Pr 2.5E+01 Nd 2.5E+01 Eu 2.5 E + 01 Hf 3.3 E + 00 W 1.2 E + 03 Np 1.0E+01 Pu 3.5 E + 00 Am 2.5E+01 Cm 2.5 E + 01 (a) Values from Regulatory Guide 1.109, Rev. 1, Table A-I and Reference 11.14.l3.

APA-ZZ-01003 to ULNRC-05621 Page 25 of 77 Rev. 018 3 GASEOUS EFFLUENTS 3.1 GASEOUS EFFLUENT MONITORS Noble gas activity monitors are present on the containment building ventilation system, plant unit ventilation system, and radwaste building ventilation system.

The alannltrip (alarm & trip) setpoint for any gaseous effluent radiation monitor is determined based on the instantaneous noble gas total body and skin dose rate limits ofREC 16.11.2.1, at the SITE BOUNDARY location with the highest annual average XJQ value.

Each gaseous monitor channel is provided with a two level system which provides sequential alarms on increasing radioactivity levels. These setpoints are designated as alert setpoints and alannltrip setpoints. (Ref. 11.6.3)

The radiation monitor alannltrip setpoints for each release point are based on the radioactive noble gases in gaseous effluents. It is not considered practicable to apply instantaneous alarm/trip setpoints to integrating radiation monitors sensitive to radioiodines, radioactive materials in particulate form and radionuc1ides other than noble gases. The exception is GL-RE-202. The only effluent released from the Laundry Decon Facility Dryer Exhaust is in the particulate form.

Conservative assumptions may be necessary in establishing setpoints to account for system variables, such as the measurement system efficiency and detection capabilities during normal, anticipated, and unusual operating conditions, variability in release flow and principal radionuc1ides, and the time lag between alannltrip action and the [mal isolation of the radioactive effluent. (Ref. 11.8.5) FSAR-SP TABLE 16.11-6 provides the instrument surveillance requirements, such as calibration, source checking, functional testing, and channel checking.

3.1.1 Continuous Release Gaseous Effluent Monitors The radiation detection monitors associated with continuous gaseous effluent releases are (Ref. 11.6.8, 11.6.9):

Monitor I.D. Description GT-RE-21 Unit Vent GH-RE-10 Radwaste Building Vent GL-RE-202 Laundry Decon Facility Dryer Exhaust Monitor Each of the above continuously monitors gaseous radioactivity concentrations downstream of the last point of potential influent, and therefore measures effluents and not inplant concentrations.

The unit vent monitor continuously monitors the effluent from the unit vent for gaseous radioactivity. The unit vent, via ventilation exhaust systems, continuously purges various tanks and sumps normally containing low-level radioactive aerated liquids that can potentially generate airborne activity. The exhaust systems which supply air to the unit vent are from the fuel building, auxiliary building, the access control area, the containment purge, and the condenser air discharge.

The unit vent monitor provides alarm functions only, and does not terminate releases from the unit vent.

The Radwaste Building ventilation effluent monitor continuously monitors for gaseous radioactivity in the effluent duct downstream of the exhaust filter and fans. The flow path provides ventilation exhaust for all parts of the building structure and components within the building and provides a discharge path for the waste gas decay tank release line. These components represent potential sources for the release of gaseous and air particulate and iodine activities in addition to the drainage sumps, tanks, and equipment purged by the waste processing system.

This monitor will isolate the waste gas decay tank discharge line upon a high gaseous radioactivity alarm.

APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 26 of 77 The Laundry Decon Facility Dryer Exhaust Monitor continuously monitors the effluent of the dryer exhaust for particulate radioactivity during operation of the dryers. This effluent point is designed to release an insignificant quantity of radioactivity. The items to be placed in the dryers are typically washed before drying removing most of the radioactive material. The dryer effluent then passes through a REP A filter before being sampled and released.

The Laundry Decon Facility Dryer Exhaust Monitor will secure the dryers and exhaust fans and isolate the dryer effluent upon a high radioactivity alarm or for a monitor failure.

The continuous Unit Vent and Radwaste Building Vent gaseous effluent monitor setpoints are established using the methodology described in Section 3.2. Since there are two continuous gaseous effluent release points, a fraction of the total dose rate limit (DRL) will be allocated to each release point. Neglecting the batch releases, the plant Unit Vent monitor has been allocated 0.7 DRL and the Radwaste Building Vent monitor has been allocated 0.3 DRL. These allocation factors may be changed as required to support plant operational needs, but shall not be allowed to exceed unity (i.e., 1.0). Therefore, a particular monitor reaching the setpoint would not necessarily mean the dose rate limit at the SITE BOUNDARY is being exceeded; the alarm only indicates that the specific release point is contributing a greater fraction of the dose rate limit than was allocated to the associated monitor, and will necessitate an evaluation of both systems.

For a loss of all isokinetic sampling and/or all heat tracing for the Unit Vent or Radwaste Building Vent grab samplers, one hour is allowed to restore a sampler to service. If sampling cannot be restored within one hour, all batch releases and ventilation not required for the operation of the plant should be secured. The best available sampling should be maintained during this period and normal sampling returned to service as soon as possible.

3.1.2 Batch Release Gaseous Monitors The radiation monitors associated with batch release gaseous effluents are (Ref. 11.6.9, 11.6.10, 11.6.11):

Monitor I.D. Description GT-RE-22 Containment Purge System GT-RE-33 GR-RE-lO Radwaste Building Vent The Containment Purge System continuously monitors the containment purge exhaust duct during purge operations for gaseous radioactivity. The primary purpose of these monitors is to isolate the containment purge system on high gaseous activity via the ESFAS.

The sample points are located outside the containment between the containment isolation dampers and the containment purge filter adsorber unit.

The Radwaste Building Vent monitor was previously described.

A pre-release isotopic analysis is performed for each batch release to determine the identity and quantity of the principal radionuclides. The alarm/trip setpoint(s) is adjusted accordingly to ensure that the limits ofREC 16.11.2.1 are not exceeded.

3.2 GASEOUS EFFLUENT MONITOR SETPOINTS The alarm/trip setpoint for Unit Vent and Radwaste Building Vent gaseous effluent monitors is determined based on the more restrictive of the total body dose rate (equation 3.1) and skin dose rate (equation 3.3), as calculated for the SITE BOUNDARY.

The alarm trip setpoint for the Laundry Decon Facility Exhaust Monitor is set to less then or equal to 2,000 cpm above equilibrium background. The maximum allowed background is 2,000 cpm as discussed in reference 11.27.

APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 27 of 77 3.2.1 TOTAL BODY DOSE RATE SETPOINT CALCULATIONS To ensure that the limits ofREC 16.11.2.1 are met, the alarm/trip setpoint based on the total body dose rate is calculated according to:

(3.1)

Where:

Stb the alarm/trip setpoint based on the total body dose rate (fJ.Cilcc).

Dtb REC 16.11.2.1 limit of 500 mrem/yr, conservatively interpreted as a continuous release over a one year period.

Fs the safety factor; a conservative factor used to compensate for statistical fluctuations and errors of measurement. (For example, Fs = 0.5 corresponds to a 100% variation.) Default value is F s = 0.1.

Fa the allocation factor which will modify the required dilution factor such that simultaneous gaseous releases may be made without exceeding the limits ofREC 16.11.2.1.

Rtb factor used to convert dose rate to the effluent concentration as measured by the effluent monitor, in (fJ.Cilcc) per (mrem/yr) to the total body, determined according to:

Rib = C + [(X/Q) ~ K; Q; 1 (3.2)

Where:

C monitor reading of a noble gas monitor corresponding to the sample radionuclide concentrations for the release. Concentrations are determined in accordance with FSAR-SP TABLE 16.11-4. The mixture of radionuclides determined via grab sampling of the effluent stream or source is correlated to a calibration factor to determine monitor response. The monitor response is based on concentrations, not release rate, and is in units of (fJ.Cilcc).

X/Q the highest calculated annual average relative concentration for any area at or beyond the SITE BOUNDARY in (sec/m3). Refer to Tables 6.1, 6.2 and 6.4.

K*1 the total body dose factor due to gamma emissions for each identified noble gas radionuclide, in (mrem/yr) per (fJ.Cilm3). (Table 3.1) rate of release of noble gas radionuclide, i, in (fJ.Cilsec).

Qi is calculated as the product of the ventilation path flow rate and the measured activity of the effluent stream as determined by sampling.

APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 28 of 77 3.2.2 SKIN DOSE RATE SETPOINT CALCULATION To ensure that the limits of REC 16.11.2.1 are met, the alannltrip setpoint based on the skin dose rate is calculated according to:

Ss ~ DsRsFsFa (3.3)

Where:

F sand Fa are as previously defmed.

Ss the alannltrip setpoint based on the skin dose rate.

Ds REC 16.11.2.1 limit of3000 mrernlyr, conservatively interpreted as a continuous release over a one year period.

Rs factor used to convert dose rate to the effluent concentration as measured by the effluent monitor, in (IlCilcc) per (mrernlyr) to the skin, determined according to:

Where:

L*1 the skin dose factor due to beta emissions for each identified noble gas radionuclide, in (mrernlyr) per (IlCilm3 ).

1.1 conversion factor: 1 mrad air dose = 1.1 mrem skin dose.

M*1 the air dose factor due to gamma emissions for each identified noble gas radionuclide, in (mrad/yr) per (IlCilm3 ).

C, (X I Q) and Qi are previously defmed.

3.3 CALCULATION OF DOSE AND DOSE RATE FROM GASEOUS EFFLUENTS 3.3.1 Dose Rate from Gaseous Effluents The following methodology is applicable to the location (SITE BOUNDARY or beyond) characterized by the values of the parameter (XlQ) which results in the maximum total body or skin dose rate. In the event that the analysis indicates a different location for the total body and skin dose limitations, the location selected for consideration is that which minimizes the allowable release values. (Ref. 11.8.6)

The factors Ki, Li, and Mi relate the radionuclide airborne concentrations to various dose rates, assuming a semi-infinite cloud model.

3.3.1.1 DOSE RATE FROM NOBLE GASES The release rate limit for noble gases is determined according to the following general relationships (Ref. 11.8.6):

0tb = I[Ki((X I Q)Qi)] ~ 500mrem I yr (3.5) i Os =I[(L i +1.1 Mi)((X/Q)Qi)]~3000mrem/yr (3.6) i Where:

The release rate of noble gas radionuclides, i, in gaseous effluents, from all vent releases in (IlCilsec).

1.1 Units conversion factor; 1 mrad air dose = 1.1 mrem skin dose.

Li. Mi, Ki, (X I Q), Dtb and Ds are as previously identified.

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 29 of 77 3.3.1.2 DOSE RATE FROM RADIONUCLIDES OTHER THAN NOBLE GASES The release rate limit for Iodine-131 and Iodine-133, for tritium, and for all radioactive materials in particulate form with half1ives greater than 8 days is determined according to (Ref. 11.8.7):

Do = I R j [ X/Q] Qj :<:; 1500 mrem/yr (3.7)

Dose rate to any critical organ, in (mrernlyr).

Dose parameter for radionuclides other than noble gases for the inhalation pathway for the child, based on the critical organ, in (mrernlyr) per (!lCi/m3).

The release rate of radionuclides other than noble gases, i, in gaseous effluents, from all vent releases in (!lCi/sec).

(X / Q) is as previously defrned.

The dose parameter (Ri) includes the internal dosimetry of radionuclide, i, and the receptor's breathing rate, which are ftmctions of the receptor's age. The child age group has been selected as the limiting age group. All radio dines are assumed to be released in elemental form (ref. 11.8.7).

Ri values were calculated according to (Ref. 11.8.8):

R j = K' (BR) DFA j (3.8)

Where:

K' Units conversion factor: lE06 pCi/!lCi BR The breathing rate. (Regulatory Guide 1.109, Table E-5). (m3/yr)

DFAi The maximum organ inhalation dose factor for the ith radionuclide, in (mrernlpCi).

The total body is considered as an organ in the selection ofDFAi' (Ref. 11.11.5 and 11.14.4)

The results of periodic tritium, iodine and particulate samples of the Unit Vent and Radwaste Vent are used to verify the dose rate limit was not exceeded for the period during which the samples or composite samples were obtained.

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 30 of 77 3.3.2 DOSE DUE TO GASEOUS EFFLUENTS 3.3.2.1 AIR DOSE DUE TO NOBLE GASES The air dose at the SITE BOUNDARY due to noble gases is calculated according to the following methodology (Ref. 11.8.9):

During any calendar quarter, for gamma radiation:

Dg = 3.17E-08 L [Mj (x/a) qd ~ 5 mrad (3.9)

During any calendar quarter, for beta radiation:

(3.10)

During any calendar year, for gamma radiation:

(3.11 )

During any calendar year, for beta radiation:

Db = 3.17E-08 L [N j (x/a) qj 1 ~20 mrad (3.12)

Where:

Air dose in mrad, from gamma radiation due to noble gases released in gaseous effluent.

Air dose in mrad, from beta radiation due to noble gases released in gaseous effluents.

N*1 The air dose factor due to beta emissions for each identified noble gas radionuclide, i, in (mradlyr) per (JlCiJm3).

The releases of noble gas radionuclides, i, in gaseous effluents, for all gaseous releases in (JlCi). Releases are cumulative over the calendar quarter or year as appropriate. qi is calculated as the product of the ventilation flow rate and the measured activity of the effluent stream as determined by sampling.

3 .17E-08 = The inverse of the number of seconds per year.

X/ Q & Mi are as previously defined.

APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 31 of 77 3.3.2.2 DOSE DUE TO RADIONUCLIDES OTHER THAN NOBLE GASES The dose to a MEMBER OF THE PUBLIC from Iodine-131 and 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released to areas at and beyond the SITE BOUNDARY, is calculated according to the following expressions:

During any calendar quarter:

~j D 1j ::; 7.5 mrem (3.13)

During any calendar year:

(3.14)

For each pathway, j, (i.e., for inhalation, ground plane, meat, cow- milk, goat- milk, and vegetation) D1j is calculated according to the expression:

(3.15)

Where:

D 1j Dose in mrem, to a MEMBER OF THE PUBLIC from radionuclides other than noble gases, from pathway j, received by organ I (including total body).

RI.i~ The dose factor for each identified radionuclide, i, in m2(mrem/yr) per (~Cilsec) or (mrem/yr) per (~Cilm3) as appropriate, for the pathway j, and exposed organ I, appropriate to the age group of the critical MEMBER OF THE PUBLIC receptor.

( X I Q) for the inhalation and tritium pathways, in (sec/m\ Refer to Tables 6.1, 6.2, and 6.4 for applicability.

( D I Q) for the food and ground plane pathways, in (meters-\ Refer to Tables 6.1, 6.2 and 6.4 for applicability.

(DI Q) the average relative deposition of the effluent at or beyond the SITE BOUNDARY, considering depletion of the plume during transport.

The releases of radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases, i, in gaseous effluents, for all gaseous releases in (~Ci). Releases are cumulative over the calendar quarter or year as appropriate.

qi is calculated as the product of ventilation flow rate and the measured activity of the effluent stream as determined by sampling.

3.17 E-08 = The inverse of the number of seconds per year.

X / Q is as previously defmed.

Although the annual average relative concentration( X I Q) and the average relative deposition rate ( D I Q) are generally considered to be at the approximate receptor location in lieu of the SITE BOUNDARY for these calculations, it is acceptable to consider the ingestion, inhalation, and ground plane pathways to coexist at the location of the nearest residence with the highest value of (X I Q) . (Ref. 11.8.9) The Total Body dose from ground plane deposition is added to the dose for each individual organ. (Ref. 11.11.3)

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 32 of 77 3.4 GASEOUS RADWASTE TREATMENT SYSTEM The gaseous radwaste treatment system and the ventilation exhaust system are available for use whenever gaseous effluents require treatment prior to being released to the environment. The gaseous radwaste treatment system is designed to allow for the retention of all gaseous fission products to be discharged from the reactor coolant system. The retention system consists of eight (8) waste gas decay tanks. Normally, waste gases will be retained for at least 60 days prior to discharge. These systems will provide reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept ALARA.

The OPERABILITY of the gaseous radwaste treatment system ensures this system will be available for use when gases require treatment prior to their release to the environment.

OPERABILITY is demonstrated through compliance with REC 16.11.2.1, 16.11.2.2, and 16.11.2.3.

Projected doses (gamma air, beta air, and organ dose) due to gaseous effluents at or beyond the SITE BOUNDARY are determined each 31 days. The prior 31 day period is used to calculate compliance. This may be modified as appropriate to account for changes in radwaste treatment which may have a significant effect on the projected doses.

3.5 DOSE FACTORS The dose conversion factors provided in the following tables were derived from the appropriate dose conversion factors in Regulatory Guide 1.109 and other sources as necessary (Ref: 11.14.9 and 11.14.11). Per USNRC guidance, particulate nuclides with a half-life ofless than 8 days are not considered (Ref: 11.24). Y-90, La-140, and Pr-144 are included because the parent half-life is greater than 8 days, and equilibrium is assumed. Non-gamma emitting nuclides not listed in FSAR-SP TABLE 16.11-4 are also not considered. (COMN 43121)

APA-ZZ-OI003 Attachment 2 Rev. 018 to ULNRC-05621 TABLE 3.1 Page 33 of 77 DOSE FACTOR FOR EXPOSURE TO A SEMI-INFINITE CLOUD OF NOBLE GASES Total Body Gamma Air Beta Air Dose Factor Skin Dose Factor Dose Factor Dose Factor K*1 L*1 M*1 Ni Radionuc1ide (mremlyr) per (!lCilm 3) (mremlyr) per (!lCilm3) (mradlyr) per (!lCilm3) (mradlyr per (!lCilm3)

Kr-83m 7.56 E-02 1.93 E+Ol 2.88 E+02 Kr-85m 1.17E+03 1.46E+03 1.23 E+03 1.97 E+03 Kr-85 1.61 E+01 1.34 E+03 1.72 E+01 1.95 E+03 Kr-87 5.92 E+03 9.73 E+03 6.17 E+03 1.03 E+04 Kr-88 1.47 E+04 2.37 E+03 1.52 E+04 2.93 E+03 Kr-89 1.66 E+04 1.01 E+04 1.73 E+04 1.06 E+04 Kr-90 1.56 E+04 7.29 E+03 1.63 E+04 7.83 E+03 Xe-13 1m 9.15 E+01 4.76 E+02 1.56 E+02 1.11 E+03 Xe-133m 2.51 E+02 9.94 E+02 3.27 E+02 1.48 E+03 Xe-133 2.94 E+02 3.06 E+02 3.53 E+02 1.05 E+03 Xe-135m 3.12 E+03 7.11 E+02 3.36 E+03 7.39 E+02 Xe-135 1.81 E+03 1.86 E+03 1.92 E+03 2.46 E+03 Xe-137 1.42 E+03 1.22 E+04 1.51 E+03 1.27 E+04 Xe-138 8.83 E+03 4.13 E+03 9.21 E+03 4.75 E+03 Ar-41 8.84 E+03 2.69 E+03 9.30 E+03 3.28 E+03 21 APA-ZZ-OI003 to ULNRC-05621 Page 34 of 77 Rev. 018 TABLE 3.2 P ATHWAY DOSE FACTORS (Rd FOR RADIONUCLIDES OTHER THAN NOBLE GASES Ground Plane Pathway 2

(m mrem/yr) per (J.1Ci/sec)

NUCLIDE TOTAL BODY SKIN Be-7 2.24E+07 3.21E+07 Cr-51 4.66E+06 5.51E+06 Mn-54 l.39E+09 1.63E+09 Fe-59 2.73E+08 3.2IE+08 Co-57 2.98E+08 4.37E+08 Co-58 3.79E+08 4.44E+08 Co-60 2.15E+IO 2.53E+IO Zn-65 7.47E+08 8.59E+08 Rb-86 8.99E+06 1.03E+07 Sr-89 2.16E+04 2.51E+04 Y-90 5.36E+06 6.32E+06 Y-91 1.07E+06 1.2IE+06 Zr-95 2.45E+08 2.84E+08 Nb-95 2.50E+08 2.94E+08 Ru-103 1.08E+08 1.26E+08 Ru-106 4.22E+08 5.07E+08 Ag-llOm 3.44E+09 4.0IE+09 Cd-109 3.76E+07 l.54E+08 Sn-l13 1.43E+07 4.09E+07 Sb-124 8.74E+08 1.23E+09 Sb-125 3.57E+09 5.19E+09 Te-127m 9.17E+04 1.08E+05 Te-129m 1.98E+07 2.3IE+07 22 APA-ZZ-01003 to ULNRC-05621 Page 35 of 77 Rev. 018 TABLE 3.2 PATHWAY DOSE FACTORS (Rd FOR RADIONUCLIDES OTHER THAN NOBLE GASES Ground Plane Pathway 2

(m mrem/yr) per (J.1Ci/sec)

NUCLIDE TOTAL BODY SKIN 1-130 5.5IE+06 6.69E+06 1-131 1.72E+07 2.09E+07 1-132 1.25E+06 1.47E+06 1-133 2.45E+06 2.98E+06 1-134 4.47E+05 5.31E+05 1-135 2.53E+06 2.95E+06 Cs-134 6.85E+09 8.00E+09 Cs-136 l.51E+08 1.71E+08 Cs-137 1.03E+1O 1.20E+10 Ba-140 2.05E+07 2.35E+07 La-140 1.47E+08 1.66E+08 Ce-141 1.37E+07 l.54E+07 Ce-144 6.96E+07 8.04E+07 Pr-144 4.35E+07 5.00E+07 Nd-147 8.39E+06 1.01E+07 Eu-154 2.21E+10 3.15E+10 Hf-181 1.97E+08 2.82E+08 23 APA-ZZ-01003 to ULNRC-05621 Page 36 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWAY DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Inhalation Pathway 3

(mrem/yr) per (J.1Ci/m )

Nuclide B!me Liyer Total Ibl';[oid Kidnel'; GI-LU

~

H-3 ND 1.12E+03 1.12E+03 1.12E+03 1.12E+03 1.12E+03 1.12E+03 Be-7 8.47E+02 1.44E+03 9.25E+02 ND ND 6.47E+04 2.55E+03 Cr-51 ND ND l.54E+02 8.55E+Ol 2.43E+Ol 1.70E+04 l.08E+03 Mn-54 ND 4.29E+04 9.5IE+03 ND 1.00E+04 l.58E+06 2.29E+04 Fe-55 4.74E+04 2.52E+04 7.77E+03 ND ND 1.11E+05 2.87E+03 Fe-59 2.07E+04 3.34E+04 1.67E+04 ND ND 1.27E+06 7.07E+04 Co-57 ND 9.03E+02 1.07E+03 ND ND 5.07E+05 1.32E+04 Co-58 ND 1.77E+03 3.16E+03 ND ND 1.11E+06 3.44E+04 Co-60 ND l.31E+04 2.26E+04 ND ND 7.07E+06 9.62E+04 Zn-65 4.25E+04 1.13E+05 7.03E+04 ND 7.14E+04 9.95E+05 1.63E+04 Rb-86 ND 1.98E+05 1.14E+05 ND ND ND 7.99E+03 Sr-89 5.99E+05 ND 1.72E+04 ND ND 2.16E+06 1.67E+05 Sr-90 1.01E+08 ND 6.44E+06 ND ND 1.48E+07 3.43E+05 Y-90 4. llE+03 ND 1.11E+02 ND ND 2.62E+05 2.68E+05 Y-91 9.14E+05 ND 2.44E+04 ND ND 2.63E+06 1. 84E+05 Zr-95 1.90E+05 4.18E+04 3.70E+04 ND 5.96E+04 2.23E+06 6. llE+04 Nb-95 2.35E+04 9.18E+03 6.55E+03 ND 8. 62E+03 6.14E+05 3.70E+04 Ru-103 2.79E+03 ND 1.07E+03 ND 7.03E+03 6.62E+05 4.48E+04 Ru-106 l.36E+05 ND 1.69E+04 ND 1.84E+05 1.43E+07 4.29E+05 Ag-llOm 1.69E+04 1.14E+04 9.14E+03 ND 2.12E+04 5.48E+06 1.00E+05 Cd-109 ND 5.48E+05 2.59E+04 ND 4.96E+05 1.05E+06 2.78E+04 Sn-l13 1.13E+05 3.12E+03 8.62E+03 2.33E+03 ND 1.46E+06 2.26E+05 Sb-124 5.74E+04 7.40E+02 2.00E+04 1.26E+02 ND 3.24E+06 1.64E+05 Sb-125 9.84E+04 7.59E+02 2.07E+04 9.10E+Ol ND 2.32E+06 4.03E+04 Te-127m 2.49E+04 8.55E+03 3.02E+03 6.07E+03 6.36E+04 1.48E+06 7.14E+04 Te-129m 1.92E+04 6.85E+03 3.04E+03 6.33E+03 5.03E+04 1.76E+06 1.82E+05 24 APA-ZZ-01003 to ULNRC-05621 Page 37 of 77 Rev. 018 TABLE 3.3 CHILD PATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Inhalation Pathway 3

(mrem/yr) per (J.1Cilm )

Nu£lide B.one Liver Total Thyroid Kidney GI-LU

~

1-130 8.18E+03 1. 64E+04 8.44E+03 1.8SE+06 2.4SE+04 ND S.IIE+03 1-131 4.8IE+04 4.81E+04 2.73E+04 1.62E+07 7.88E+04 ND 2.84E+03 1-132 2.12E+03 4.07E+03 1.88E+03 1.94E+OS 6.2SE+03 ND 3.20E+03 1-133 1.66E+04 2.03E+04 7.70E+03 3.8SE+06 3.38E+04 ND S.48E+03 1-134 1.17E+03 2.16E+03 9.9SE+02 S.07E+04 3.30E+03 ND 9.SSE+02 1-13S 4.92E+03 8.73E+03 4.14E+03 7.92E+OS l.34E+04 ND 4.44E+03 Cs-134 6.SIE+OS 1.01E+06 2.2SE+OS ND 3.30E+OS 1.2IE+OS 3.8SE+03 Cs-136 6.S1E+04 l.71E+OS 1.16E+OS ND 9.SSE+04 I.4SE+04 4.18E+03 Cs-137 9.07E+OS 8.2SE+OS 1.28E+OS ND 2.82E+OS 1.04E+OS 3.62E+03 Ba-140 7.40E+04 6.48E+Ol 4.33E+03 ND 2.11E+Ol 1.74E+06 1.02E+OS La-140 6.44E+02 2.2SE+02 7.SSE+Ol ND ND 1.83E+OS 2.26E+OS Ce-141 3.92E+04 1.9SE+04 2.90E+03 ND 8.SSE+03 S.44E+OS S.66E+04 Ce-144 6.77E+06 2.12E+06 3.61E+OS ND 1.17E+06 1.20E+07 3.89E+OS Pr-143 1.8SE+04 S.SSE+03 9. 14E+02 ND 3.00E+03 4.33E+OS 9.73E+04 Pr-144 S.96E-02 1.8SE-02 3.00E-03 ND 9.77E-03 l.57E+03 1.97E+02 Nd-147 1.08E+04 8.73E+03 6.81E+02 ND 4.81E+03 3.28E+OS 8.21E+04 Eu-1S4 1.0IE+07 9.2IE+OS 8.40E+OS ND 4.03E+06 6. 14E+06 1.10E+OS Hf-181 2.78E+04 1.0IE+OS 1.2SE+04 ND 2.0SE+04 1.06E+06 6.62E+04 25 APA-ZZ-01003 to ULNRC-05621 Page 38 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWA Y DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Meat Pathway 2

(m mrem/yr) per (f.LCi/sec)

Nuclide B.on.f Liyer Total Thyroid Kidney GI-LLI

~

H-3 ND 2.34E+02 2.34E+02 2.34E+02 2.34E+02 2.34E+02 2.34E+02 Be-7 7.38E+03 1.26E+04 8.07E+03 O.OOE+OO 1.23E+04 O.OOE+OO 7.00E+05 Cr-51 O.OOE+OO O.OOE+OO 8.80E+03 4.88E+03 l.33E+03 8.92E+03 4.67E+05 Mn-54 O.OOE+OO 8.02E+06 2.14E+06 O.OOE+OO 2.25E+06 O.OOE+OO 6.73E+06 Fe-55 4.58E+08 2.43E+08 7.52E+07 O.OOE+OO O.OOE+OO 1.37E+08 4.50E+07 Fe-59 3.77E+08 6.10E+08 3.04E+08 O.OOE+OO O.OOE+OO 1.77E+08 6.35E+08 Co-57 O.OOE+OO 5.92E+06 1.20E+07 O.OOE+OO O.OOE+OO O.OOE+OO 4.85E+07 Co-58 O.OOE+OO 1.64E+07 5.03E+07 O.OOE+OO O.OOE+OO O.OOE+OO 9.59E+07 Co-60 O.OOE+OO 6.94E+07 2.05E+08 O.OOE+OO O.OOE+OO O.OOE+OO 3.84E+08 Zn-65 3.76E+08 1.00E+09 6.23E+08 O.OOE+OO 6.3IE+08 O.OOE+OO 1.76E+08 Rb-86 O.OOE+OO 5.77E+08 3.55E+08 O.OOE+OO O.OOE+OO O.OOE+OO 3.71E+07 Sr-89 4.82E+08 O.OOE+OO l.38E+07 O.OOE+OO O.OOE+OO O.OOE+OO 1.87E+07 Sr-90 1.04E+1O O.OOE+OO 2.64E+09 O.OOE+OO O.OOE+OO O.OOE+OO 1.40E+08 Y-90 1.93E+05 O.OOE+OO 5.16E+03 O.OOE+OO O.OOE+OO O.OOE+OO 5.49E+08 Y-91 1.80E+06 O.OOE+OO 4.82E+04 O.OOE+OO O.OOE+OO O.OOE+OO 2.40E+08 Zr-95 2.67E+06 5.86E+05 5.22E+05 O.OOE+OO 8.39E+05 O.OOE+OO 6.1IE+08 Nb-95 4.26E+06 1.66E+06 1.18E+06 O.OOE+OO 1.56E+06 O.OOE+OO 3.07E+09 Ru-l03 1.55E+08 O.OOE+OO 5.96E+07 O.OOE+OO 3.90E+08 O.OOE+OO 4.01E+09 Ru-l06 4.44E+09 O.OOE+OO 5.54E+08 O.OOE+OO 6.00E+09 O.OOE+OO 6.91E+1O Ag-llOm 8.40E+06 5.67E+06 4.53E+06 O.OOE+OO 1.06E+07 O.OOE+OO 6.75E+08 Cd-109 O.OOE+OO 1.91E+06 8.84E+04 O.OOE+OO 1.70E+06 O.OOE+OO 6.18E+06 Sn-l13 2.18E+09 4.48E+07 1.24E+08 3.3IE+09 O.OOE+OO O.OOE+OO 1.54E+09 Sb-124 2.93E+07 3.80E+05 1.03E+07 6.46E+04 O.OOE+OO 1.62E+07 1.83E+08 Sb-125 2.85E+07 2.20E+05 5.97E+06 2.64E+04 O.OOE+OO 1.59E+07 6.81E+07 Te-127m 1.78E+09 4.78E+08 2.11E+08 4.25E+08 5.07E+09 O.OOE+OO 1.44E+09 Te-129m 1.79E+09 5.00E+08 2.78E+08 5.78E+08 5.26E+09 O.OOE+OO 2.19E+09 1-130 3.06E-06 6.18E-06 3.18E-06 6.80E-04 9.23E-06 O.OOE+OO 2.89E-06 26 APA-ZZ-01003 to ULNRC-05621 Page 39 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWAY DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Meat Pathway 2

(m mrem/yr) per (J.1Ci/sec)

Nuclide B!me Liver Total Thyroid Kidney GT-I,U

~

1-131 1.66E+07 1.67E+07 9.47E+06 5.51E+09 2.74E+07 O.OOE+OO 1.4SE+06 1-132 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 1-133 5.70E-01 7.05E-01 2.67E-01 l.31E+02 1.17E+OO O.OOE+OO 2.S4E-01 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 1-135 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO Cs-134 9.23E+OS l.51E+09 3.20E+08 O.OOE+OO 4.69E+OS 1.6SE+08 8.17E+06 Cs-136 1.62E+07 4.46E+07 2.89E+07 O.OOE+OO 2.38E+07 3.54E+06 1.57E+06 Cs-137 l.33E+09 1.2SE+09 l.S9E+08 O.OOE+OO 4.16E+OS 1.50E+OS 8.00E+06 Ba-140 4.39E+07 3.85E+04 2.56E+06 O.OOE+OO 1.25E+04 2.29E+04 2.22E+07 La-140 3.33E+02 1.17E+02 3.93E+01 O.OOE+OO O.OOE+OO O.OOE+OO 3.25E+06 Ce-141 2.22E+04 l.l1E+04 1.65E+03 O.OOE+OO 4.S6E+03 O.OOE+OO l.38E+07 Ce-144 2.32E+06 7.27E+05 1.24E+05 O.OOE+OO 4.02E+05 O.OOE+OO 1.S9E+OS Pr-143 3.34E+04 1.00E+04 1. 66E+03 O.OOE+OO 5.43E+03 O.OOE+OO 3.61E+07 Pr-144 5.63E+02 1.74E+02 2.S3E+01 O.OOE+OO 9.2IE+01 O.OOE+OO 3.75E+05 Nd-147 1.17E+04 9.4SE+03 7.34E+02 O.OOE+OO 5.20E+03 O.OOE+OO l.50E+07 Eu-154 1.12E+07 1.01E+06 9.20E+05 O.OOE+OO 4.43E+06 O.OOE+OO 2.34E+OS Hf-1S1 4.77E+06 l.74E+07 2.15E+06 O.OOE+OO 3.53E+06 O.OOE+OO 6.4IE+09 27 APA-ZZ-01003 to ULNRC-05621 Page 40 of 77 Rev. 018 TABLE 3.3 CHILD P ATHW A Y DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Cow-Milk Pathway 2

(m mrem/yr) per (JlCi/sec)

Nuclide B!!ne Liver Total Ihl;roid Kidnel; GI-LLI

~

H-3 O.OOE+OO l.57E+03 1.57E+03 l.57E+03 1.57E+03 l.57E+03 l.57E+03 Be-7 7.50E+03 1.28E+04 8.20E+03 O.OOE+OO 1.25E+04 O.OOE+OO 7. 12E+05 Cr-51 O.OOE+OO O.OOE+OO 1.02E+05 5.66E+04 l.55E+04 1.03E+05 5.40E+06 Mn-54 O.OOE+OO 2.lOE+07 5.59E+06 O.OOE+OO 5.89E+06 O.OOE+OO 1.76E+07 Fe-55 1.12E+08 5.94E+07 1. 84E+07 O.OOE+OO O.OOE+OO 3.36E+07 1.10E+07 Fe-59 1.20E+08 1.95E+08 9.70E+07 O.OOE+OO O.OOE+OO 5.64E+07 2.03E+08 Co-57 O.OOE+OO 3.84E+06 7.78E+06 O.OOE+OO O.OOE+OO O.OOE+OO 3.15E+07 Co-58 O.OOE+OO 1.21E+07 3.72E+07 O.OOE+OO O.OOE+OO O.OOE+OO 7.08E+07 Co-60 O.OOE+OO 4.32E+07 1.27E+08 O.OOE+OO O.OOE+OO O.OOE+OO 2.39E+08 Zn-65 4. 14E+09 1.10E+I0 6.86E+09 O.OOE+OO 6.95E+09 O.OOE+OO 1.94E+09 Rb-86 O.OOE+OO 8.78E+09 5.40E+09 O.OOE+OO O.OOE+OO O.OOE+OO 5.65E+08 Sr-89 6.63E+09 O.OOE+OO 1.89E+08 O.OOE+OO O.OOE+OO O.OOE+OO 2.57E+08 Sr-90 1.12E+ll O.OOE+OO 2.84E+I0 O.OOE+OO O.OOE+OO O.OOE+OO l.5IE+09 Y-90 3.38E+03 O.OOE+OO 9.05E+Ol O.OOE+OO O.OOE+OO O.OOE+OO 9.62E+06 Y-91 3.91E+04 O.OOE+OO 1.04E+03 O.OOE+OO O.OOE+OO O.OOE+OO 5.20E+06 Zr-95 3.84E+03 8.43E+02 7.51E+02 O.OOE+OO 1.21E+03 O.OOE+OO 8.80E+05 Nb-95 3.72E+05 1.45E+05 1.03E+05 O.OOE+OO l.36E+05 O.OOE+OO 2.68E+08 Ru-103 4.29E+03 O.OOE+OO 1.65E+03 O.OOE+OO l.08E+04 O.OOE+OO 1.11E+05 Ru-106 9.25E+04 O.OOE+OO 1.15E+04 O.OOE+OO 1.25E+05 O.OOE+OO 1.44E+06 Ag-IlOm 2.09E+08 1.41E+08 1. 13E+08 O.OOE+OO 2.63E+08 O.OOE+OO 1.68E+I0 Cd-l09 O.OOE+OO 3.86E+06 l.79E+05 O.OOE+OO 3.45E+06 O.OOE+OO l.25E+07 Sn-l13 6. llE+08 1.26E+07 3.48E+07 9.29E+08 O.OOE+OO O.OOE+OO 4.32E+08 Sb-124 1.09E+08 1.41E+06 3.81E+07 2.40E+05 O.OOE+OO 6.03E+07 6.80E+08 Sb-125 8.71E+07 6.72E+05 1.83E+07 8.07E+04 O.OOE+OO 4.86E+07 2.08E+08 Te-127m 2.08E+08 5.61E+07 2.47E+07 4.98E+07 5.94E+08 O.OOE+OO 1.69E+08 Te-129m 2.72E+08 7.59E+07 4.22E+07 8.76E+07 7.98E+08 O.OOE+OO 3.3IE+08 28 APA-ZZ-01003 to ULNRC-05621 Page 41 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWA Y DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Cow-Milk Pathway 2

(m mrem/yr) per ()lCi/sec)

Nuclide B!m.e IAnr Total Ih~roid KidDe~ GI-LLI

~

1-130 1.73E+06 3.50E+06 1.80E+06 3.8SE+08 S.23E+06 O.OOE+OO 1. 64E+06 1-131 l.30E+09 l.3IE+09 7.46E+08 4.34E+ll 2.1SE+09 O.OOE+OO 1.17E+08 1-132 6.92E-Ol 1.27E+00 S.8SE-Ol S.90E+Ol 1.9SE+00 O.OOE+OO l.50E+00 1-133 1.72E+07 2. 13E+07 8.0SE+06 3.9SE+09 3.S4E+07 O.OOE+OO 8.S7E+06 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 1-13S S.41E+04 9.74E+04 4.61E+04 8.63E+06 1.49E+OS O.OOE+OO 7.42E+04 Cs-134 2.27E+I0 3.72E+I0 7.84E+09 O.OOE+OO l.1SE+lO 4. 14E+09 2.00E+08 Cs-136 1.01E+09 2.78E+09 1.80E+09 O.OOE+OO 1.48E+09 2.21E+08 9.78E+07 Cs-137 3.23E+IO 3.09E+I0 4.S6E+09 O.OOE+OO 1.01E+10 3.62E+09 1.93E+08 Ba-140 1.17E+08 1.03E+OS 6.84E+06 O.OOE+OO 3.34E+04 6.12E+04 S.94E+07 La-140 1.78E+02 6.23E+Ol 2.l0E+Ol O.OOE+OO O.OOE+OO O.OOE+OO 1.74E+06 Ce-141 2.19E+04 1.09E+04 1.62E+03 O.OOE+OO 4.79E+03 O.OOE+OO l.36E+07 Ce-144 1.62E+06 S.09E+OS 8.67E+04 O.OOE+OO 2.82E+OS O.OOE+OO l.33E+08 Pr-143 7.19E+02 2.16E+02 3.S7E+Ol O.OOE+OO 1.17E+02 O.OOE+OO 7.76E+OS Pr-144 S.04E+00 I.S6E+00 2.S3E-Ol O.OOE+OO 8.24E-Ol O.OOE+OO 3.3SE+03 Nd-147 4.4SE+02 3.61E+02 2.79E+Ol O.OOE+OO 1.98E+02 O.OOE+OO S.7IE+OS Eu-1S4 9.43E+04 8.48E+03 7.7SE+03 O.OOE+OO 3.73E+04 O.OOE+OO 1.97E+06 Hf-181 6.44E+02 2.3SE+03 2.91E+02 O.OOE+OO 4.76E+02 O.OOE+OO 8.66E+OS 29 APA-ZZ-OI003 to ULNRC-05621 Page 42 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWA Y DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Goat-Milk Pathway 2

(m mrem/yr) per (JlCi/sec)

Nuclide Brule Liver Total Thyroid Kidney GT-LU

~

H-3 O.OOE+OO 3.20E+03 3.20E+03 3.20E+03 3.20E+03 3.20E+03 3.20E+03 Be-7 9.00E+02 1.53E+03 9.S4E+02 O.OOE+OO 1.50E+03 O.OOE+OO 8.55E+04 Cr-51 O.OOE+OO O.OOE+OO 1.22E+04 6.79E+03 l.S5E+03 1. 24E+04 6.4SE+05 Mn-54 O.OOE+OO 2.52E+06 6.71E+05 O.OOE+OO 7.06E+05 O.OOE+OO 2.11E+06 Fe-55 1.45E+06 7.72E+05 2.39E+05 O.OOE+OO O.OOE+OO 4.36E+05 1.43E+05 Fe-59 l.56E+06 2.53E+06 1.26E+06 O.OOE+OO O.OOE+OO 7.34E+05 2.64E+06 Co-57 O.OOE+OO 4.61E+05 9.33E+05 O.OOE+OO O.OOE+OO O.OOE+OO 3.78E+06 Co-5S O.OOE+OO 1.46E+06 4.46E+06 O.OOE+OO O.OOE+OO O.OOE+OO S.50E+06 Co-60 O.OOE+OO 5.19E+06 1.53E+07 O.OOE+OO O.OOE+OO O.OOE+OO 2.S7E+07 Zn-65 4.97E+OS l.32E+09 S.23E+OS O.OOE+OO S.34E+OS O.OOE+OO 2.32E+08 Rb-S6 O.OOE+OO 1.05E+09 6.4SE+OS O.OOE+OO O.OOE+OO O.OOE+OO 6.78E+07 Sr-S9 l.39E+10 O.OOE+OO 3.97E+OS O.OOE+OO O.OOE+OO O.OOE+OO 5.39E+08 Sr-90 2.35E+11 O.OOE+OO 5.95E+10 O.OOE+OO O.OOE+OO O.OOE+OO 3.16E+09 Y-90 4.06E+02 O.OOE+OO 1.09E+01 O.OOE+OO O.OOE+OO O.OOE+OO 1.l5E+06 Y-91 4.69E+03 O.OOE+OO 1.25E+02 O.OOE+OO O.OOE+OO O.OOE+OO 6.25E+05 Zr-95 4.60E+02 1.01E+02 9.01E+01 O.OOE+OO 1.45E+02 O.OOE+OO 1.06E+05 Nb-95 4.46E+04 1.74E+04 1.24E+04 O.OOE+OO 1.63E+04 O.OOE+OO 3.21E+07 Ru-103 5.14E+02 O.OOE+OO 1.9SE+02 O.OOE+OO 1.29E+03 O.OOE+OO l.33E+04 Ru-106 1.l1E+04 O.OOE+OO l.3SE+03 O.OOE+OO 1.50E+04 O.OOE+OO 1.73E+05 Ag-11Om 2.51E+07 1.69E+07 l.35E+07 O.OOE+OO 3.15E+07 O.OOE+OO 2.01E+09 Cd-109 O.OOE+OO 4.64E+05 2.15E+04 O.OOE+OO 4.14E+05 O.OOE+OO 1.50E+06 Sn-113 7.33E+07 l.51E+06 4.1SE+06 1.l1E+OS O.OOE+OO O.OOE+OO 5. 1SE+07 Sb-124 l.30E+07 1.69E+05 4.57E+06 2.SSE+04 O.OOE+OO 7.24E+06 S.16E+07 Sb-125 1.05E+07 S.06E+04 2.19E+06 9.6SE+03 O.OOE+OO 5.S3E+06 2.50E+07 Te-l27m 2.50E+07 6.73E+06 2.97E+06 5.9SE+06 7. 13E+07 O.OOE+OO 2.02E+07 Te-129m 3.26E+07 9.lOE+06 5.06E+06 1.05E+07 9.57E+07 O.OOE+OO 3.9SE+07 1-130 2.0SE+06 4.20E+06 2.16E+06 4.62E+OS 6.27E+06 O.OOE+OO 1.96E+06 1-131 l.57E+09 l.57E+09 S.95E+OS 5.21E+ll 2.5SE+09 O.OOE+OO 1.40E+OS 1-132 S.30E-01 l.53E+00 7.02E-Ol 7.0SE+Ol 2.34E+00 O.OOE+OO 1.S0E+00 30 APA-ZZ-01003 to ULNRC-05621 Page 43 of 77 Rev. 018 TABLE 3.3 CHILD P ATHW AY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Goat-Milk Pathway (m2 mrem/yr) per (J.1Ci/sec)

Nuclide fume Liver Total Ih~[!lid KidDe~ GI-LLI

~

1-133 2.06E+07 2.SSE+07 9.66E+06 4.74E+09 4.2SE+07 O.OOE+OO 1.03E+07 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 1-13S 6.49E+04 1.17E+OS S.S3E+04 1.04E+07 1.79E+OS O.OOE+OO 8.90E+04 Cs-134 6.80E+IO 1.12E+11 2.3SE+1O O.OOE+OO 3.46E+1O 1.24E+10 6.01E+08 Cs-136 3.04E+09 8.3SE+09 S.40E+09 O.OOE+OO 4.4SE+09 6.63E+08 2.93E+08 Cs-137 9.68E+IO 9.27E+1O l.37E+1O O.OOE+OO 3.02E+10 1.09E+IO S.80E+08 Ba-140 1.4IE+07 l.23E+04 8.21E+OS O.OOE+OO 4.01E+03 7.3SE+03 7. 13E+06 La-140 2.14E+Ol 7.47E+OO 2.S2E+OO O.OOE+OO O.OOE+OO O.OOE+OO 2.08E+OS Ce-141 2.63E+03 l.31E+03 1.9SE+02 O.OOE+OO S.7SE+02 O.OOE+OO 1.63E+06 Ce-144 1.9SE+OS 6.l1E+04 1.04E+04 O.OOE+OO 3.38E+04 O.OOE+OO l.S9E+07 Pr-143 8.63E+Ol 2.S9E+Ol 4.28E+OO O.OOE+OO 1.40E+Ol O.OOE+OO 9.3IE+04 Pr-144 6.0SE-Ol 1.87E-Ol 3.04E-02 O.OOE+OO 9.89E-02 O.OOE+OO 4.03E+02 Nd-147 S.34E+Ol 4.33E+Ol 3.3SE+OO O.OOE+OO 2.37E+Ol O.OOE+OO 6.8SE+04 Eu-1S4 1.13E+04 1.02E+03 9.29E+02 O.OOE+OO 4.47E+03 O.OOE+OO 2.37E+OS Hf-181 7.73E+Ol 2.81E+02 3.49E+Ol O.OOE+OO S.72E+Ol O.OOE+OO 1.04E+OS 31 APA-ZZ-01003 to ULNRC-05621 Page 44 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Vegetation Pathway 2

(m mrem/yr) per (J..1Ci/sec)

Nuclide Bm1e Liyer Total Ih~roid KidDe~ GI-LLI

~

H-3 ND 4.0IE+03 4.01E+03 4.01E+03 4.01E+03 4.0IE+03 4.01E+03 Be-7 3.38E+05 5.76E+05 3.70E+05 O.OOE+OO 5.65E+05 O.OOE+OO 3.21E+07 Cr-51 O.OOE+OO O.OOE+OO 1.17E+05 6.50E+04 1. 78 E+04 1.19E+05 6.21E+06 Mn-54 O.OOE+OO 6.65E+08 1.77E+08 O.OOE+OO 1.86E+08 O.OOE+OO 5.58E+08 Fe-55 8.01E+08 4.25E+08 1.32E+08 O.OOE+OO O.OOE+OO 2.40E+08 7.87E+07 Fe-59 3.98E+08 6.43E+08 3.20E+08 O.OOE+OO O.OOE+OO 1.87E+08 6.70E+08 Co-57 O.OOE+OO 2.99E+07 6.04E+07 O.OOE+OO O.OOE+OO O.OOE+OO 2.45E+08 Co-58 O.OOE+OO 6.44E+07 1.97E+08 O.OOE+OO O.OOE+OO O.OOE+OO 3.76E+08 Co-60 O.OOE+OO 3.78E+08 1.12E+09 O.OOE+OO O.OOE+OO O.OOE+OO 2.10E+09 Zn-65 8.13E+08 2.17E+09 1.35E+09 O.OOE+OO 1.36E+09 O.OOE+OO 3.80E+08 Rb-86 O.OOE+OO 4.52E+08 2.78E+08 O.OOE+OO O.OOE+OO O.OOE+OO 2.91E+07 Sr-89 3.60E+I0 O.OOE+OO 1.03E+09 O.OOE+OO O.OOE+OO O.OOE+OO 1.39E+09 Sr-90 1.24E+12 O.OOE+OO 3.15E+11 O.OOE+OO O.OOE+OO O.OOE+OO 1.67E+I0 Y-90 3.0IE+06 O.OOE+OO 8.04E+04 O.OOE+OO O.OOE+OO O.OOE+OO 8.56E+09 Y-91 1. 86E+07 O.OOE+OO 4.99E+05 O.OOE+OO O.OOE+OO O.OOE+OO 2.48E+09 Zr-95 3.86E+06 8.48E+05 7.55E+05 O.OOE+OO 1.2IE+06 O.OOE+OO 8.85E+08 Nb-95 7.48E+05 2.9IE+05 2.08E+05 O.OOE+OO 2.74E+05 O.OOE+OO 5.39E+08 Ru-l03 1.53E+07 O.OOE+OO 5.90E+06 O.OOE+OO 3.86E+07 O.OOE+OO 3.97E+08 Ru-l06 7.45E+08 O.OOE+OO 9.30E+07 O.OOE+OO 1.01E+09 O.OOE+OO 1.16E+I0 Ag-IlOm 3.2IE+07 2.17E+07 1.73E+07 O.OOE+OO 4.04E+07 O.OOE+OO 2.58E+09 Cd-109 O.OOE+OO 2.45E+08 1.14E+07 O.OOE+OO 2.18E+08 O.OOE+OO 7.94E+08 Sn-l13 1.58E+09 3.25E+07 9.00E+07 2.40E+09 O.OOE+OO O.OOE+OO 1.12E+09 Sb-124 3.52E+08 4.57E+06 1.23E+08 7.77E+05 O.OOE+OO 1.95E+08 2.20E+09 Sb-125 4.99E+08 3.85E+06 1.05E+08 4.63E+05 O.OOE+OO 2.78E+08 1.19E+09 Te-127m 1.32E+09 3.56E+08 1.57E+08 3.16E+08 3.77E+09 O.OOE+OO 1.07E+09 Te-129m 8.41E+08 2.35E+08 1.31E+08 2.7IE+08 2.47E+09 O.OOE+OO 1.03E+09 1-130 6.16E+05 1.24E+06 6.41E+05 1.37E+08 1.86E+06 O.OOE+OO 5.82E+05 1-131 1.43E+08 1.44E+08 8.17E+07 4.76E+1O 2.36E+08 O.OOE+OO 1.28E+07 32 APA-ZZ-01003 to ULNRC-05621 Page 45 of 77 Rev. 018 TABLE 3.3 CHILD P ATHWA Y DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Vegetation Pathway 2

(m mrem/yr) per (!lCi/sec)

Nuclide B.mte Liyer Total Thyroid Kidney GI-LLI

~

1-132 9.23E+01 1.70E+02 7.80E+01 7.87E+03 2.60E+02 O.OOE+OO 2.00E+02 1-133 3.53E+06 4.37E+06 1.65E+06 8.12E+08 7.28E+06 O.OOE+OO 1.76E+06 1-134 1.56E-04 2.89E-04 1.33E-04 6.65E-03 4.42E-04 O.OOE+OO 1.92E-04 1-135 6.26E+04 1.13E+05 5.33E+04 9.98E+06 1.73E+05 O.OOE+OO 8.59E+04 Cs-134 1. 60E+ 10 2.63E+10 5.55E+09 O.OOE+OO 8.15E+09 2.93E+09 1.42E+08 Cs-136 8.24E+07 2.27E+08 1.47E+08 O.OOE+OO 1.21E+08 1.80E+07 7.96E+06 Cs-137 2.39E+10 2.29E+10 3.38E+09 O.OOE+OO 7.46E+09 2.68E+09 1.43E+08 Ba-140 2.77E+08 2.43E+05 1. 62E+07 O.OOE+OO 7.90E+04 1.45E+05 1.40E+08 La-140 3.36E+04 1.18E+04 3.96E+03 O.OOE+OO O.OOE+OO O.OOE+OO 3.28E+08 Ce-141 6.56E+05 3.27E+05 4.86E+04 O.OOE+OO 1.43E+05 O.OOE+OO 4.08E+08 Ce-144 1.27E+08 3.98E+07 6.78E+06 O.OOE+OO 2.21E+07 O.OOE+OO 1.04E+10 Pr-143 1.46E+05 4.37E+04 7.23E+03 O.OOE+OO 2.37E+04 O.OOE+OO 1.57E+08 Pr-144 7.88E+03 2.44E+03 3.97E+02 O.OOE+OO 1.29E+03 O.OOE+OO 5.25E+06 Nd-147 7.15E+04 5.79E+04 4.48E+03 O.OOE+OO 3.18E+04 O.OOE+OO 9. 17E+07 Eu-154 1.66E+08 1.50E+07 1.37E+07 O.OOE+OO 6.57E+07 O.OOE+OO 3.48E+09 Hf-181 4.90E+05 1.79E+06 2.21E+05 O.OOE+OO 3.63E+05 O.OOE+OO 6.59E+08 33 APA-ZZ-01003 to ULNRC-05621 Page 46 of 77 Rev. 018 TABLE 3.4 ADULT PATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Inhalation Pathway (mrem/yr) per (~Ci/m3)

Nuclide ~ Liver Total Thyroid Kidney GT-UJ

~

H-3 ND 1.26E+03 1.26E+03 1.26E+03 1.26E+03 1.26E+03 1.26E+03 Be-7 4.27E+02 9.68E+02 4.70E+02 ND ND 4.21E+04 5.35E+03 Cr-51 ND ND 1.00E+02 5.95E+Ol 2.28E+Ol 1.44E+04 3.32E+03 Mn-54 ND 3.96E+04 6.30E+03 ND 9.84E+03 1.40E+06 7.74E+04 Fe-55 2.46E+04 1.70E+04 3.94E+03 ND ND 7.21E+04 6.03E+03 Fe-59 1.18E+04 2.78E+04 1.06E+04 ND ND 1.02E+06 1.88E+05 Co-57 ND 6.92E+02 6.7IE+02 ND ND 3.70E+05 3.l4E+04 Co-58 ND l.58E+03 2.07E+03 ND ND 9.28E+05 1.06E+05 Co-60 ND 1.15E+04 1.48E+04 ND ND 5.97E+06 2.85E+05 Zn-65 3.24E+04 1.03E+05 4.66E+04 ND 6.90E+04 8.64E+05 5.34E+04 Rb-86 ND l.35E+05 5.90E+04 ND ND ND 1. 66E+04 Sr-89 3.04E+05 ND 8.72E+03 ND ND 1.40E+06 3.50E+05 Sr-90 9.92E+07 ND 6.10E+06 ND ND 9.60E+06 7.22E+05 Y-90 2.09E+03 ND 5.6IE+01 ND ND 1.70E+05 5.06E+05 Y-91 4.62E+05 ND 1.24E+04 ND ND 1.70E+06 3.85E+05 Zr-95 1.07E+05 3.44E+04 2.33E+04 ND 5.42E+04 1.77E+06 l.50E+05 Nb-95 1.4IE+04 7.82E+03 4.21E+03 ND 7.74E+03 5.05E+05 1.04E+05 Ru-l03 l.53E+03 ND 6.58E+02 ND 5.83E+03 5.05E+05 1.10E+05 Ru-106 6.9IE+04 ND 8.72E+03 ND l.34E+05 9.36E+06 9.12E+05 Ag-II0m 1.08E+04 1.00E+04 5.94E+03 ND 1. 97E+04 4.63E+06 3.02E+05 Cd-l09 ND 3.67E+05 l.31E+04 ND 3.57E+05 6.83E+05 5.82E+04 Sn-l13 5.72E+04 2.18E+03 4.39E+03 1.24E+03 ND 9.44E+05 1.18E+05 Sb-124 3.12E+04 5.89E+02 1.24E+04 7.55E+Ol ND 2.48E+06 4.06E+05 Sb-125 5.34E+04 5.95E+02 1.26E+04 5.40E+Ol ND 1.74E+06 1.01E+05 Te-l27m 1.26E+04 5.77E+03 l.57E+03 3.29E+03 4.58E+04 9.60E+05 l.50E+05 Te-129m 9.76E+03 4.67E+03 1.58E+03 3.44E+03 3.66E+04 1.16E+06 3.83E+05 1-130 4.58E+03 l.34E+04 5.28E+03 1.14E+06 2.09E+04 ND 7.69E+03 1-131 2.52E+04 3.58E+04 2.05E+04 1.19E+07 6. 13E+04 ND 6.28E+03 34 APA-ZZ-01003 to ULNRC-05621 Page 47 of 77 Rev. 018 TABLE 3.4 ADUL T P ATHW AY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Inhalation Pathway (mrem/yr) per (J,lCi/m 3)

Nuclide B..!m.e Liyer Total Ihl;roid Kidoel; GI-LLI

~

1-132 1.16E+03 3.26E+03 1.16E+03 1.14E+OS S.18E+03 ND 4.06E+02 1-133 8.64E+03 1.48E+04 4.S2E+03 2.ISE+06 2.S8E+04 ND 8.88E+03 1-134 6.44E+02 1.73E+03 6.ISE+02 2.98E+04 2.7SE+03 ND l.OIE+OO I-13S 2.68E+03 6.98E+03 2.S7E+03 4.48E+OS 1.11E+04 ND S.2SE+03 Cs-134 3.73E+OS 8.48E+OS 7.28E+OS ND 2.87E+OS 9.76E+04 l.04E+04 Cs-136 3.90E+04 1.46E+OS 1.10E+OS ND 8.S6E+04 1.20E+04 1.17E+04 Cs-137 4.78E+OS 6.2IE+OS 4.28E+OS ND 2.22E+OS 7.S2E+04 8.40E+03 Ba-140 3.90E+04 4.90E+OI 2.S7E+03 ND 1. 67E+OI 1.27E+06 2.18E+OS La-140 3.44E+02 1.74E+02 4.S8E+OI ND ND l.36E+OS 4.S8E+OS Ce-14I 1.99E+04 1.3SE+04 l.53E+03 ND 6.26E+03 3.62E+OS 1.20E+OS Ce-144 3.43E+06 1.43E+06 1. 84E+OS ND 8.48E+OS 7.78E+06 8.I6E+OS Pr-143 9.36E+03 3.7SE+03 4.64E+02 ND 2. I 6E+03 2.8IE+OS 2.00E+OS Pr-144 3.0IE-02 1.2SE-02 I.S3E-03 ND 7.0SE-03 l.02E+03 2.ISE-08 Nd-147 S.27E+03 6.10E+03 3.6SE+02 ND 3.S6E+03 2.2IE+OS l.73E+OS Eu-IS4 S.92E+06 7.28E+OS S.18E+OS ND 3.49E+06 4.67E+06 2.72E+OS Hf-181 1.41E+04 6.82E+04 6.32E+03 ND 1.48E+04 6.8SE+OS 1.39E+OS 35 APA-ZZ-01003 to ULNRC-05621 Page 48 of 77 Rev. 018 TABLE 3.4 ADULT P ATHWAY DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Meat Pathway 2

(m mrem/yr) per (JlCi/sec)

Nuclide B.!m.e Liver Total Thyroid Kidney GI-LU

~

H-3 ND 3.25E+02 3.25E+02 3.25E+02 3.25E+02 3.25E+02 3.25E+02 Be-7 4.57E+03 1.04E+04 5.07E+03 ND 1.10E+04 ND 1.81E+06 Cr-51 ND ND 7.04E+03 4.21E+03 1.55E+03 9.34E+03 1.77E+06 Mn-54 ND 9.17E+06 1.75E+06 ND 2.73E+06 ND 2.8IE+07 Fe-55 2.93E+08 2.02E+08 4.72E+07 ND ND 1. 13E+08 1.16E+08 Fe-59 2.65E+08 6.24E+08 2.39E+08 ND ND 1.74E+08 2.08E+09 Co-57 ND 5.63E+06 9.36E+06 ND ND ND 1.43E+08 Co-58 ND 1.82E+07 4.08E+07 ND ND ND 3.69E+08 Co-60 ND 7.51E+07 1.66E+08 ND ND ND 1.41E+09 Zn-65 3.56E+08 1.13E+09 5.1IE+08 ND 7.57E+08 ND 7. 13E+08 Rb-86 ND 4.87E+08 2.27E+08 ND ND ND 9.60E+07 Sr-89 3.01E+08 ND 8.65E+06 ND ND ND 4.83E+07 Sr-90 1. 24E+ 10 ND 3.05E+09 ND ND ND 3.59E+08 Y-90 1.21E+05 ND 3.24E+03 ND ND ND 1.28E+09 Y-91 1.13E+06 ND 3.02E+04 ND ND ND 6.23E+08 Zr-95 1.87E+06 6.00E+05 4.06E+05 ND 9.42E+05 ND 1.90E+09 Nb-95 3.15E+06 1.75E+06 9.43E+05 ND 1.73E+06 ND 1.06E+10 Ru-l03 1.05E+08 ND 4.53E+07 ND 4.01E+08 ND 1.23E+1O Ru-l06 2.80E+09 ND 3.54E+08 ND 5.40E+09 ND 1.81E+11 Ag-I10m 6.68E+06 6.18E+06 3.67E+06 ND 1.2IE+07 ND 2.52E+09 Cd-l09 ND 1.59E+06 5.55E+04 ND 1.52E+06 ND 1.60E+07 Sn-l13 1.37E+09 3.88E+07 7.86E+07 2.22E+07 ND ND 4.09E+09 Sb-124 1.98E+07 3.74E+05 7.84E+06 4.79E+04 ND 1. 54E+07 5.6IE+08 Sb-125 1.91E+07 2. 13E+05 4.54E+06 1.94E+04 ND 1.47E+07 2.10E+08 Te-l27m 1.11E+09 3.98E+08 1.36E+08 2.85E+08 4.53E+09 ND 3.74E+09 Te-129m 1.13E+09 4.23E+08 1.79E+08 3.89E+08 4.73E+09 ND 5.71E+09 1-130 2.12E-06 6.27E-06 2.47E-06 5.31E-04 9.78E-06 ND 5.40E-06 1-131 1.08E+07 1.54E+07 8.82E+06 5.04E+09 2.64E+07 ND 4.06E+06 36 APA-ZZ-01OO3 to ULNRC-05621 Page 49 of 77 Rev. 018 TABLE 3.4 ADULT P ATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Meat Pathway 2

(m mrem/yr) per (JlCi/sec)

Nuclide B.on.e Liver Total Ibl;roid Kidnel; GI-LLI

~

1-132 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ND O.OOE+OO 1-133 3.67E-Ol 6.39E-Ol 1.95E-Ol 9.3SE+Ol l.1IE+OO ND 5.74E-Ol 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ND O.OOE+OO 1-135 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ND O.OOE+OO Cs-134 6.57E+OS l.56E+09 1.2SE+09 ND 5.06E+OS 1.6SE+OS 2.74E+07 Cs-136 1.20E+07 4.76E+07 3.42E+07 ND 2.65E+07 3.63E+06 5.40E+06 Cs-137 S.7lE+OS 1.19E+09 7.SlE+OS ND 4.04E+OS 1.34E+OS 2.3IE+07 Ba-140 2.S7E+07 3.6lE+04 1.SSE+06 ND 1.23E+04 2.07E+04 5.9IE+07 La-140 2.2IE+02 l.llE+02 2.94E+Ol ND ND ND S.lSE+06 Ce-14l 1.40E+04 9.49E+03 l.OSE+03 ND 4.4lE+03 ND 3.63E+07 Ce-144 1.46E+06 6.09E+05 7.S2E+04 ND 3.6IE+05 ND 4.92E+OS Pr-143 2.l0E+04 S.40E+03 l.04E+03 ND 4.S5E+03 ND 9.lSE+07 Pr-144 3.52E+02 1.46E+02 1.79E+Ol ND S.24E+Ol ND 5.06E-05 Nd-147 7.07E+03 S.l7E+03 4.S9E+02 ND 4.77E+03 ND 3.92E+07 Eu-154 S.02E+06 9.S6E+05 7.0lE+05 ND 4.72E+06 ND 7.l4E+OS Hf-lSl 3.0lE+06 1.46E+07 1.35E+06 ND 3.l4E+06 ND 1. 66E+ 10 37 APA-ZZ-01003 to ULNRC-05621 Page 50 of 77 Rev. 018 TABLE 3.4 ADULT P ATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Cow-Milk Pathway (m2mrem/yr) per (IlCi/sec)

Nuclide !lone Liyer Total Thyroid Kidney GI-I.LI

~

H-3 ND 7.63E+02 7.63E+02 7.63E+02 7.63E+02 7.63E+02 7.63E+02 Be-7 1.63E+03 3.72E+03 1.81E+03 ND 3.93E+03 ND 6.45E+05 Cr-51 ND ND 2.86E+04 1.71E+04 6.30E+03 3.79E+04 7.19E+06 Mn-54 ND 8.42E+06 1. 6IE+06 ND 2.50E+06 ND 2.58E+07 Fe-55 2.51E+07 1.74E+07 4.05E+06 ND ND 9.68E+06 9.96E+06 Fe-59 2.97E+07 6.98E+07 2.68E+07 ND ND 1.95E+07 2.33E+08 Co-57 ND 1.28E+06 2. 13E+06 ND ND ND 3.25E+07 Co-58 ND 4.72E+06 1.06E+07 ND ND ND 9.56E+07 Co-60 ND 1.64E+07 3.62E+07 ND ND ND 3.08E+08 Zn-65 l.37E+09 4.37E+09 1.97E+09 ND 2.92E+09 ND 2.75E+09 Rb-86 ND 2.60E+09 1.21E+09 ND ND ND 5.12E+08 Sr-89 1.45E+09 ND 4.17E+07 ND ND ND 2.33E+08 Sr-90 4.68E+1O ND 1.15E+I0 ND ND ND l.35E+09 Y-90 7.43E+02 ND 1.99E+Ol ND ND ND 7.87E+06 Y-91 8.59E+03 ND 2.30E+02 ND ND ND 4.73E+06 Zr-95 9.44E+02 3.03E+02 2.05E+02 ND 4.75E+02 ND 9.59E+05 Nb-95 9.65E+04 5.37E+04 2.89E+04 ND 5.3IE+04 ND 3.26E+08 Ru-l03 1.02E+03 ND 4.39E+02 ND 3.89E+03 ND 1.19E+05 Ru-l06 2.04E+04 ND 2.58E+03 ND 3.94E+04 ND l.32E+06 Ag-llOm 5.82E+07 5.39E+07 3.20E+07 ND 1.06E+08 ND 2.20E+I0 Cd-l09 ND 1.13E+06 3.95E+04 ND 1.08E+06 ND 1.14E+07 Sn-l13 1.34E+08 3.81E+06 7.73E+06 2.18E+06 ND ND 4.02E+08 Sb-124 2.57E+07 4.86E+05 1.02E+07 6.24E+04 ND 2.00E+07 7.31E+08 Sb-125 2.04E+07 2.28E+05 4.87E+06 2.08E+04 ND l.58E+07 2.25E+08 Te-127m 4.58E+07 1. 64E+07 5.58E+06 1.17E+07 1.86E+08 ND 1.54E+08 Te-129m 6.02E+07 2.25E+07 9.53E+06 2.07E+07 2.51E+08 ND 3.03E+08 1-130 4.21E+05 1.24E+06 4.91E+05 1.05E+08 1.94E+06 ND 1.07E+06 1-131 2.97E+08 4.25E+08 2.43E+08 1.39E+ 11 7.28E+08 ND 1.12E+08 38 APA-ZZ-01003 to ULNRC-05621 Page 51 of 77 Rev. 018 TABLE 3.4 ADULT P ATHW AY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Cow-Milk Pathway 2

(m mrem/yr) per (J..LCi/sec)

Nuclide ll!m.e Liver Total Thyroid Kidney GI-LLI

~

1-132 1.6SE-01 4.42E-Ol 1.5SE-Ol 1.5SE+Ol 7.04E-Ol ND S.30E-02 1-133 3.SSE+06 6.7SE+06 2.06E+06 9.92E+OS 1.1SE+07 ND 6.07E+06 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ND O.OOE+OO 1-13S 1.29E+04 3.37E+04 1.2SE+04 2.23E+06 S.41E+04 ND 3.SIE+04 Cs-134 S.6SE+09 1.3SE+1O 1.10E+1O ND 4.3SE+09 1.4SE+09 2.3SE+OS Cs-136 2.63E+OS 1.04E+09 7.4SE+OS ND S.79E+OS 7.93E+07 l.1SE+OS Cs-137 7.3SE+09 1.01E+ 10 6.61E+09 ND 3.43E+09 1.14E+09 1.9SE+OS Ba-140 2.69E+07 3.3SE+04 1.76E+06 ND 1.1SE+04 1.93E+04 S.S4E+07 La-140 4.14E+Ol 2.09E+Ol S.SIE+OO ND ND ND 1.53E+06 Ce-141 4.SSE+03 3.2SE+03 3.72E+02 ND 1.S2E+03 ND l.2SE+07 Ce-144 3.SSE+OS 1.50E+OS 1.92E+04 ND S.S7E+04 ND 1.21E+OS Pr-143 1.5SE+02 6.34E+Ol 7.S3E+00 ND 3.66E+Ol ND 6.92E+OS Pr-144 1.10E+00 4.SSE-Ol S.61E-02 ND 2.SSE-Ol ND 1.S9E-07 Nd-147 9.42E+Ol 1.09E+02 6.S1E+00 ND 6.36E+Ol ND S.23E+OS Eu-lS4 2.37E+04 2.91E+03 2.07E+03 ND 1.39E+04 ND 2.11E+06 Hf-ISI 1.42E+02 6.92E+02 6.4IE+01 ND 1.49E+02 ND 7.S7E+OS 39 APA-ZZ-01003 to ULNRC-05621 Page 52 of 77 Rev. 018 TABLE 3.4 ADULT P ATHWAY DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Goat-Milk Pathway (m2 mrem/yr) per (JlCi/sec)

Nuclide B.one Liver Total Ih,l;roid Kidne,l; GI-LLI

~

H-3 ND 1.56E+03 1.56E+03 1.56E+03 1.56E+03 1.56E+03 1.56E+03 Be-7 1.96E+02 4.47E+02 2.17E+02 ND 4.72E+02 ND 7.74E+04 Cr-51 ND ND 3.43E+03 2.05E+03 7.56E+02 4.56E+03 8.63E+05 Mn-54 ND 1.01E+06 1.93E+05 ND 3.0IE+05 ND 3.10E+06 Fe-55 3.27E+05 2.26E+05 5.26E+04 ND ND 1.26E+05 1.30E+05 Fe-59 3.87E+05 9.08E+05 3.48E+05 ND ND 2.54E+05 3.03E+06 Co-57 ND 1.54E+05 2.56E+05 ND ND ND 3.90E+06 Co-58 ND 5.66E+05 1.27E+06 ND ND ND 1.15E+07 Co-60 ND 1.97E+06 4.35E+06 ND ND ND 3.70E+07 Zn-65 1.65E+08 5.24E+08 2.37E+08 ND 3.51E+08 ND 3.30E+08 Rb-86 ND 3.12E+08 1.45E+08 ND ND ND 6.15E+07 Sr-89 3.05E+09 ND 8.75E+07 ND ND ND 4.89E+08 Sr-90 9.84E+10 ND 2.41E+1O ND ND ND 2.84E+09 Y-90 8.92E+01 ND 2.39E+00 ND ND ND 9.46E+05 Y-91 1.03E+03 ND 2.76E+01 ND ND ND 5.68E+05 Zr-95 1. 13E+02 3.63E+01 2.46E+01 ND 5.70E+01 ND 1.15E+05 Nb-95 1.16E+04 6.45E+03 3.47E+03 ND 6.37E+03 ND 3.9IE+07 Ru-103 1.22E+02 ND 5.27E+01 ND 4.67E+02 ND 1.43E+04 Ru-106 2.45E+03 ND 3.10E+02 ND 4.73E+03 ND 1.59E+05 Ag-llOm 6.99E+06 6.47E+06 3.84E+06 ND 1.27E+07 ND 2.64E+09 Cd-109 ND 1.36E+05 4.74E+03 ND 1.30E+05 ND 1.37E+06 Sn-l13 1.61E+07 4.58E+05 9.28E+05 2.62E+05 ND ND 4.83E+07 Sb-124 3.09E+06 5.84E+04 1.23E+06 7.50E+03 ND 2.41E+06 8.78E+07 Sb-125 2.46E+06 2.74E+04 5.84E+05 2.50E+03 ND 1.89E+06 2.70E+07 Te-127m 5.50E+06 1.97E+06 6.70E+05 1.41E+06 2.23E+07 ND 1. 84E+07 Te-129m 7.23E+06 2.70E+06 1.14E+06 2.48E+06 3.02E+07 ND 3.64E+07 1-130 5.05E+05 1.49E+06 5.88E+05 1.26E+08 2.32E+06 ND 1.28E+06 1-131 3.56E+08 5.09E+08 2.92E+08 1.67E+11 8.72E+08 ND 1.34E+08 1-132 1.98E-01 5.29E-01 1.85E-01 1.85E+01 8.43E-01 ND 9.95E-02 40 APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 53 of 77 TABLE 3.4 ADUL T P ATHWAY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Grass-Goat-Milk Pathway 2

(m mrem/yr) per (J.1Ci/sec)

Nuclide B.one Liyer Total Ihl;roid Kidnel; GT-LLI

~

1-133 4.65E+06 8.09E+06 2.47E+06 1.I9E+09 1.41E+07 ND 7.27E+06 1-134 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO ND O.OOE+OO 1-135 1.54E+04 4.04E+04 1.49E+04 2.67E+06 6.48E+04 ND 4.57E+04 Cs-134 1.70E+1O 4.04E+1O 3.30E+10 ND 1.31E+1O 4.34E+09 7.07E+08 Cs-136 7.91E+08 3.12E+09 2.25E+09 ND 1. 74E+09 2.38E+08 3.55E+08 Cs-137 2.22E+1O 3.03E+1O 1.99E+10 ND 1.03E+1O 3.42E+09 5.87E+08 Ba-140 3.23E+06 4.06E+03 2. 12E+05 ND 1.38E+03 2.32E+03 6.65E+06 La-140 4.97E+00 2.5lE+00 6.62E-01 ND ND ND 1. 84E+05 Ce-141 5.82E+02 3.94E+02 4.46E+01 ND 1.83E+02 ND 1.50E+06 Ce-144 4.30E+04 1.80E+04 2.31E+03 ND 1.07E+04 ND 1.45E+07 Pr-143 1.90E+01 7.61E+00 9.40E-01 ND 4.39E+00 ND 8.3lE+04 Pr-144 1.33E-01 5.50E-02 6.74E-03 ND 3.lOE-02 ND 1.9lE-08 Nd-147 1.I3E+01 1.3lE+01 7.82E-01 ND 7.64E+00 ND 6.28E+04 Eu-154 2.84E+03 3.49E+02 2.49E+02 ND 1. 67E+03 ND ' 2.53E+05 Hf-181 1.7lE+01 8.31E+01 7.70E+00 ND 1.79E+01 ND 9.46E+04 41 APA-ZZ-01003 to ULNRC-05621 Page 54 of 77 Rev. 018 TABLE 3.4 ADUL T PATHW AY DOSE FACTORS (R1) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Vegetation Pathway 2

(m mrem/yr) per (J.1Ci/sec)

Nuclide B.one Liver Total Thyroid Kidney GI-LLI

~

H-3 ND 2.26E+03 2.26E+03 2.26E+03 2.26E+03 2.26E+03 2.26E+03 Be-7 9.24E+04 2.11E+05 1.03E+05 ND 2.23E+05 ND 3.66E+07 Cr-51 ND ND 4.64E+04 2.78E+04 1.02E+04 6. 16E+04 1.17E+07 Mn-54 ND 3. 13E+08 5.97E+07 ND 9.31E+07 ND 9.59E+08 Fe-55 2.lOE+08 1.45E+08 3.38E+07 ND ND 8.08E+07 8.31E+07 Fe-59 1.26E+08 2.96E+08 1.14E+08 ND ND 8.28E+07 9.88E+08 Co-57 ND 1.17E+07 1.95E+07 ND ND ND 2.97E+08 Co-58 ND 3.07E+07 6.89E+07 ND ND ND 6.23E+08 Co-60 ND 1.67E+08 3.69E+08 ND ND ND 3.14E+09 Zn-65 3.17E+08 1.01E+09 4.56E+08 ND 6.75E+08 ND 6.36E+08 Rb-86 ND 2.19E+08 1.02E+08 ND ND ND 4.33E+07 Sr-89 9.97E+09 ND 2.86E+08 ND ND ND 1.60E+09 Sr-90 6.05E+11 ND 1.48E+11 ND ND ND 1.75E+10 Y-90 7.67E+05 ND 2.06E+04 ND ND ND 8.14E+09 Y-91 5.11E+06 ND 1.37E+05 ND ND ND 2.81E+09 Zr-95 1.17E+06 3.77E+05 2.55E+05 ND 5.91E+05 ND 1.19E+09 Nb-95 2.40E+05 1.34E+05 7. 19E+04 ND 1.32E+05 ND 8.11E+08 Ru-103 4.77E+06 ND 2.06E+06 ND 1. 82E+07 ND 5.57E+08 Ru-106 1.93E+08 ND 2.44E+07 ND 3.72E+08 ND 1.25E+1O Ag-11Om 1.05E+07 9.75E+06 5.79E+06 ND 1.92E+07 ND 3.98E+09 Cd-109 O.OOE+OO 8.36E+07 2.92E+06 ND 8.00E+07 ND 8.43E+08 Sn-l13 4.16E+08 1.18E+07 2.40E+07 6.75E+06 ND ND 1.25E+09 Sb-124 1.04E+08 1.96E+06 4. 11E+07 2.51E+05 ND 8.07E+07 2.94E+09 Sb-125 1.37E+08 1.53E+06 3.25E+07 1.39E+05 ND 1.05E+08 1.50E+09 Te-127m 3.49E+08 1.25E+08 4.26E+07 8.92E+07 1.42E+09 ND 1.17E+09 Te-129m 2.51E+08 9.38E+07 3.98E+07 8.64E+07 1.05E+09 ND 1.27E+09 1-130 3.93E+05 1.16E+06 4.57E+05 9.81E+07 1.81E+06 ND 9.97E+05 1-131 8.08E+07 1.16E+08 6.62E+07 3.79E+1O 1.98E+08 ND 3.05E+07 42 APA-ZZ-01003 to ULNRC-05621 Page 55 of 77 Rev. 018 TABLE 3.4 ADUL T PATHW AY DOSE FACTORS (RI ) FOR RADIONUCLIDES OTHER THAN NOBLE GASES Vegetation Pathway 2

(m mrem/yr) per (J.1Ci/sec)

Nuclide fume Liver Total Ih:Eroid KidDe:E GI-LU

~

1-132 5.77E+01 1. 54E+02 5.40E+01 5.40E+03 2.46E+02 ND 2.90E+01 1-133 2.09E+06 3.63E+06 1.11E+06 5.33E+08 6.33E+06 ND 3.26E+06 1-134 9.69E-05 2.63E-04 9.42E-05 4.56E-03 4.19E-04 ND 2.30E-07 1-135 3.90E+04 1.02E+05 3.77E+04 6.74E+06 1. 64E+05 ND 1.15E+05 Cs-134 4.67E+09 1.11E+ 10 9.08E+09 ND 3.59E+09 1.19E+09 1.94E+08 Cs-136 4.27E+07 1.69E+08 1.21E+08 ND 9.38E+07 1.29E+07 1.9IE+07 Cs-137 6.36E+09 8.70E+09 5.70E+09 ND 2.95E+09 9.81E+08 1.68E+08 Ba-140 1.29E+08 1.61E+05 8.42E+06 ND 5.49E+04 9.24E+04 2.65E+08 La-140 1.58E+04 7.98E+03 2.11E+03 ND ND ND 5.86E+08 Ce-141 1.97E+05 1.33E+05 1.51E+04 ND 6. 19E+04 ND 5.lOE+08 Ce-144 3.29E+07 1.38E+07 1.77E+06 ND 8.16E+06 ND 1.11E+10 Pr-143 6.26E+04 2.51E+04 3.lOE+03 ND 1.45E+04 ND 2.74E+08 Pr-144 2.03E+03 8.43E+02 1.03E+02 ND 4.75E+02 ND 2.92E-04 Nd-147 3.33E+04 3.85E+04 2.3IE+03 ND 2.25E+04 ND 1.85E+08 Eu-154 4.85E+07 5.97E+06 4.25E+06 ND 2.86E+07 ND 4.32E+09 Hf-181 1.40E+05 6.82E+05 6.32E+04 ND 1.47E+05 ND 7.76E+08 43 APA-ZZ-OI003 to ULNRC-05621 Page 56 of 77 Rev. 018 4 DOSE AND DOSE COMMITMENT FROM URANIUM FUEL CYCLE SOURCES 4.1 CALCULATION OF DOSE AND DOSE COMMITMENT FROM URANIUM FUEL CYCLE SOURCES The annual dose or dose commitment to a MEMBER OF THE PUBLIC for Uranium Fuel Cycle Sources is determined as:

a) Dose to the total body and internal organs due to gamma ray exposure from submersion in a cloud of radioactive noble gases, ground plane exposure, and direct radiation from the Unit, onsite storage oflow-level radioactive waste, and outside storage tanks; b) Dose to skin due to beta radiation from submersion in a cloud of radioactive noble gases, and ground plane exposure; c) Thyroid dose due to inhalation and ingestion of radioiodines; and d) Organ dose due to inhalation and ingestion of radioactive material.

It is assumed that total body dose from sources of gamma radiation irradiates internal body organs at the same numerical rate. (Ref. 11.12.5)

The dose from gaseous effluents is considered to be the summation of the dose at the individual's residence and the dose to the individual from activities within the SITE BOUNDARY.

Since the doses via liquid releases are very conservatively evaluated, there is reasonable assurance that no real individual will receive a significant dose from radioactive liquid release pathways. Therefore, only doses to individuals via airborne pathways and doses resulting from direct radiation are considered in determining compliance to 40 CFR 190 (Ref. 11.12.3).

There are no other Uranium Fuel Cycle Sources within 8km of the Callaway Plant.

4.1.1 IDENTIFICATION OF THE MEMBER OF THE PUBLIC The MEMBER OF THE PUBLIC is considered to be a real individual, including all persons not occupationally associated with the Callaway Plant, but who may use portions of the plant site for recreational or other purposes not associated with the plant (Ref. 11.4 and 11.8.10).

Accordingly, it is necessary to characterize this individual with respect to his utilization of areas both within and at or beyond the SITE BOUNDARY and identify, as far as possible, major assumptions which could be reevaluated if necessary to demonstrate continued compliance with 40 CFR 190 through the use of more realistic assumptions (Ref. 11.12.3 and 11.12.4).

The evaluation of Total Dose from the Uranium Fuel Cycle should consider the dose to two Critical Receptors: a) The Nearest Resident, and b) The Critical Receptor within the SITE BOUNDARY.

4.1.2 TOTAL DOSE TO THE NEAREST RESIDENT The dose to the Nearest Resident is due to plume exposure from noble gases, ground plane exposure, and inhalation and ingestion pathways. It is conservatively assumed that each ingestion pathway (meat, milk, and vegetation) exists at the location of the Nearest Resident.

It is assumed that direct radiation dose from operation of the Unit and storage of radioactive material, and dose from gaseous effluents due to activities within the SITE BOUNDARY, is negligible for the Nearest Resident. The total Dose from the Uranium Fuel Cycle to the Nearest Resident is calculated using the methodology discussed in Section 3, using concurrent meteorological data for the location of the Nearest Resident with the highest value ofXlQ.

The location of the Nearest Resident in each meteorological sector is determined from the Annual Land Use Census conducted in accordance with the Requirements ofREC 16.11.4.2.

APA-ZZ-OI003 to ULNRC-05621 Page 57 of 77 Rev. 018 4.1.3 TOTAL DOSE TO THE CRITICAL RECEPTOR WITHIN THE SITE BOUNDARY The Union Electric Company has entered into an agreement with the State of Missouri Department of Conservation for management of the residual lands surrounding the Callaway Plant, including some areas within the SITE BOUNDARY. Under the terms of this agreement, certain areas have been opened to the public for low intensity recreational uses (hunting, hiking, sightseeing, etc.) but recreational use is excluded in an area immediately surrounding the plant site (refer to Figure 4.1). Much of the residual lands within the SITE BOUNDARY are leased to area farmers by the Department of Conservation to provide income to support management and development costs. Activities conducted under these leases are primarily comprised of farming (animal feed), grazing, and forestry (Ref. 11.7.2, 11.7.3, 11.13, and 11.13.1).

Based on the utilization of areas within the SITE BOUNDARY, it is reasonable to assume that the critical receptor within the SITE BOUNDARY is a farmer, and that his dose from activities within the SITE BOUNDARY is due to exposure incurred while conducting his farming activities. The current tenant has estimated that he spends approximately 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months per year working in this area (Ref. 11.5.5). Occupancy of areas within the SITE BOUNDARY is assumed to be averaged over a period of one year.

Any reevaluation of assumptions should consider only real receptors and real pathways using realistic assumption, and should include a reevaluation of the occupancy period at the locations of real exposure (e.g. a real individual would not simultaneously exist at each point of maximum exposure).

4.1.3.1 Total Dose to the Farmer from Gaseous Effluents The Total Dose to the farmer from gaseous effluents is calculated for the adult age group using the methodology discussed in Section 3, utilizing concurrent meteorological data at the farmer's residence and historical meteorological data from Table 6.1 for activities within the SITE BOUNDARY. These dispersion parameters were calculated by assuming that the farmer's time is equally distributed over the areas farmed within the SITE BOUNDARY, and already have the total occupancy of 1100 hour0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months s/year factored into their value (Ref. 11.5.6).

The residence of the current tenant is located at a distance of 2897 meters in the NNW sector.

The gaseous effluents dose at the farmer's residence is due to plume exposure from Noble Gases and the ground plane, inhalation, and ingestion pathways. For conservatism, it is acceptable to assume that all of the ingestion pathways exist at this location.

It is assumed that food ingestion pathways do not exist within the SITE BOUNDARY, therefore the gaseous effluents dose within the SITE BOUNDARY is due to plume exposure from Noble Gases and the ground plane and inhalation pathways.

4.1.3.1.1 Direct Radiation Dose from Outside Storage Tanks The Refueling Water Storage Tank (RWST) has the highest potential for receiving significant amounts of radioactive materials, and constitutes the only potentially significant source of direct radiation dose from outside storage tanks to a MEMBER OF THE PUBLIC (Ref. 11.6.14, 11.6.15, 11.6.16 and 11.6.17).

Direct radiation dose from the RWST to a MEMBER OF THE PUBLIC is determined at the nearest point of the Owner Controlled Area fence which is not obscured by significant plant structures, which is 450 meters from the RWST.

The RWST is a right circular cylinder approximately 12 meters in diameter, 14 meters in height with a capacity of approximately 1,514,000 liters (Ref. 11.6.17). The walls are of type 304 stainless steel and have an average thickness of.87 cm. (Ref. 11.14.1).

The direct radiation dose from the R WST is calculated based on the tank's average isotopic content and the parameters discussed above, considering buildup and attenuation within the volume source. Appropriate methodology for calculating the dose rate from a volume source is given in TID-7004, "Reactor Shielding Design Manual" (Ref. 11.17). The computer program MICRO SHIELD (Ref. 11.18) will normally be utilized to perform this calculation.

APA-ZZ-OI003 to ULNRC-05621 Page 58 of 77 Rev. 018 4.1.3.1.2 Direct Radiation Dose from the Reactor The maximum direct radiation dose from the Unit to a MEMBER OF THE PUBLIC has been determined to be 7E-2 rnrads/calendar year, based on a point source of primary coolant N-16 in the steam generators. This source term was then projected onto the inside surface of the containment dome, taking credit for shielding provided by the containment dome and for distance attenuation. No credit was allowed for shielding by other structures or components within the Containment Building. The number of gammas per second was generated and then converted to a dose rate at the given distance by use of ANSIIANS-6.6.1, "Calculation and Measurement of Direct and Scattered Gamma Radiation from LWR Nuclear Power Plant 1979",

which considers attenuation and buildup in air. The [mal value is based on one unit operating at 100% Power. The distance was determined to be 367 meters, which is approximately the closest point of the boundary of the Owner Controlled Area fence which is not obscured by significant plant structures (Ref. 11.14.3).

The maximum direct radiation dose from the Unit to the farmer is thus approximately 9E-3 rnrads per year, assuming a maximum occupancy of 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months per year.

Equipment Hatch Platform and Missile Shield Modification 03-1008 was completed in late 2005.

HPCI 06-01 was generated using actual radiation survey data at 100% Reactor power in order to calculate direct radiation dose from the Unit as a result of the modification. The calculated direct radiation dose from the Unit to a MEMBER OF THE PUBLIC was determined to be 8.99E-06 rnrem per year. (Ref. 11.14.10) 4.1.3.1.3 Direct Radiation Dose From On-Site Storage Of Low Level Radioactive Waste On-site storage for radioactive wastes is located in Stores II and Plant Southwest of the radwaste building in the Radwaste Yard. The Radwaste Yard consists of a concrete pad enclosed by a fence. The area is also bounded on two sides by the radwaste building and is partially bounded on a third side by the Discharge monitoring tanks dike system. The radioactive wastes are stored in this area using high integrity containers (HIC) inside Onsite Storage Containers (OSC) and LSA type storage containers. The HIC has the highest potential for containing significant amounts of radioactive material, and constitutes the most significant source of direct radiation from on-site radioactive waste storage The HICs typically are right circular cylinders approximately 1.7 meters in diameter and 1.8 meters in height. The HICs are stored inside OSCs which typically are constructed of concrete with additional shielding as necessary to minimize external doses. The individual parameters (e.g., dimensions, shielding material, etc.) for each OSC will be accounted for in the calculations.

The direct radiation dose from the HICs is the summation of the individual calculated HIC doses based on the HIC isotopic contents and the OSC design parameters, considering buildup, attenuation, and shielding. Appropriate methodology for calculating the dose rate from the HICs is given in Safety Analysis Calculations ZZ-293 and ZZ-31 O. The computer program MICRO SHIELD (Ref. 11.18) will normally be utilized to perform this calculation.

Direct radiation dose from the HICs and the Radwaste yard (Ref. 11.20) to a MEMBER OF THE PUBLIC is determined at the nearest point of the Owner Controlled Area fence which is not obscured by significant plant structures.

Direct radiation dose from radioactive material storage at Stores II to a MEMBER OF THE PUBLIC is determined at the nearest point of the Owner Controlled Area fence which is not obscured by significant plant structures. (Ref. 11.19)

APA-ZZ-OI003 to ULNRC-05621 Page 59 of 77 Rev. 018 4.1.3.1.4 Direct Radiation Dose From On-Site Storage Of Steam Generators The Old Steam Generator Storage Facility (OSGSF) was constructed to house steam generators following replacement in Refuel 14. The OSGSF building is located inside the Owner Controlled Area (OCA) Plant East of the cooling tower.

The OSGSF is constructed with 2' thick concrete walls and a 2' thick ceiling specifically designed for shielding of residual radioactivity in the steam generators.

Direct radiation dose from the OSGSF to a MEMBER OF THE PUBLIC is determined using radiation survey data at the nearest point of the Owner Controlled Area fence which is unobscured by significant plant structures. The distance was determined to be 420 feet.

APA-ZZ-OI003 Attachment 2 Rev. 018 to ULNRC-05621 Page 60 of 77 T

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SCALE IN fEEl'

~N AREA CLOSED TO PUBLIC USE UNION ELECTRIC CO.

CALLAWAY PLANT SITE AREA CLOSED 300 0 300 600 TO PUBLIC USE SCALE IN FEET FIGURE 4.1 REV. 6 48 APA-ZZ-OI003 to ULNRC-05621 Page 61 of 77 Rev. 018 5 RADIOLOGICAL ENVIRONMENTAL MONITORING

5.1 DESCRIPTION

OF THE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM The Radiological Environmental Monitoring Program is intended to act as a background data base for pre operation and to supplement the radiological effluent release monitoring program during plant operation. Radiation exposure to the public from the various specific pathways and direct radiation can be adequately evaluated by this program.

Some deviations from the sampling frequency may be necessary due to seasonal unavailability, hazardous conditions, or other legitimate reasons. Efforts are made to obtain all required samples within the required time frame. Any deviation(s) in sampling frequency or location is documented in the Annual Radiological Environmental Operating Report.

REMP sampling locations that use meteorological sectors and or distance from the plant site were verified as described in reference 11.28.

Sampling, reporting, and analytical requirements are given in FSAR-SP TABLES 16.11-7, 16.11-8, and 16.11-9.

Airborne, waterborne, direct radiation, and ingestion samples collected under the monitoring program are analyzed by an independent, third-party laboratory. With the exception of direct radiation, the laboratory is required to participate in an Interlaboratory Analyses Program Per Reg. Guide 4.15 (REF 11.14.14). The laboratory participates in an Interlaboratory crosscheck program administered by Environmental Resources Associates (ERA), Mixed Analyte Performance Evaluation Program (MAPEP), or equivalent program. This participation includes all of the determinations (sample medium - radionuclide combination) that are both offered by ERA and/or MAPEP and included in the environmental monitoring program.

5.2 PERFORMANCE TESTING OF ENVIRONMENTAL THERMOLUMINESCENCE DOSIMETERS Thermoluminescence Detectors (TLD's) used in the Radiological Environmental Monitoring Program are tested for accuracy and precision to demonstrate compliance with Regulatory Guide 4.13 (Ref. 11.16).

6 DETERMINATION OF ANNUAL AVERAGE AND SHORT TERM ATMOSPHERIC DISPERSION PARAMETERS 6.1 ATMOSPHERIC DISPERSION PARAMETERS The values presented in Table 6.1 and Table 6.2 were determined through the analysis of on-site meteorological data collected during the three year period of May 4, 1973 to May 5, 1975 and March 16, 1978 to March 16, 1979.

6.1.1 LONG-TERM DISPERSION ESTIMATES The variable trajectory plume segment atmospheric transport model MESODIF-II (NUREG/-CR-0523) and the straight-line Gaussian dispersion model XOQDOQ (NUREG/CR2919) were used for determination of the long-term atmospheric dispersion parameters. A more detailed discussion of the methodology and data utilized to calculate these parameters can be found elsewhere (Ref. 11.6.12).

The Unit Vent and Radwaste Building Vent releases are at elevations of 66.5 meters and 20 meters above grade, respectively. Both release points are within the building wake of the structures on which they are located, and the unit Vent is equipped with a rain cover which effectively eliminates the possibility of the exit velocity exceeding five times the horizontal wind speed. All gaseous releases are thus considered to be ground-level releases, and therefore no mixed mode or elevated release dispersion parameters were determined (Ref. 11.5.2).

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 62 of 77 6.1.2 DETERMINATION OF LONG-TERM DISPERSION ESTIMATES FOR SPECIAL RECEPTOR LOCATIONS Calculations utilizing the PUFF model were performed for 22 standard distances to obtain the desired dispersion parameters. Dispersion parameters at the SITE BOUNDARY and at special receptor locations were estimated by logarithmic interpolation according to (Ref. 11.6.13):

X = x1 (d/d 1 )B (6.1)

Where:

XI, X 2 = Atmospheric dispersion parameters at distance d 1 and d2, respectively, from the source.

The distances d 1 and d2 were selected such that they satisfy the relationship.

dl <d<d2 6.1.3 SHORT TERM DISPERSION ESTIMATES Airborne releases are classified as short term if they are less than or equal to 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months during a calendar year and not more than 150 hours0.00174 days 0.0417 hours 2.480159e-4 weeks 5.7075e-5 months in any quarter. Short term dispersion estimates are determined by multiplying the appropriate long term dispersion estimate by a correction factor (Ref. 11.9.1 and 11.15.1):

Where:

Ts The total number of hours of the short term release.

Ta The total number of hours in the data collection period from which the long term diffusion estimate was determined (Refer to Section 6.1).

Values of the slope factor (S), are presented in Table 6.3.

Short term dispersion estimates are not applicable to short term releases which are sufficiently random in both time of day and duration (e.g., the short term release periods are not dependent solely on atmospheric conditions or time of day) to be represented by the annual average dispersion conditions (Ref. 11.8.1).

APA-ZZ-01003 to ULNRC-05621 Page 63 of 77 Rev. 018 6.1.3.1 The Detennination of the Slope Factor (S)

The general approach employed by subroutine PURGE of XOQDOQ (Ref. 11.15.1) was utilized to produce values of the slope of the (XlQ) curves for both the Radwaste Building Vent and the Unit Vent. However, instead of using approximation procedures to produce the 15 percentile (XlQ) values, the 15 percentile (XlQ) value for each release and at each location was detennined by ranking all the I-hour<<XlQh) values for that release and at that location in descending order.

The (XlQ) 1 value which corresponded to the 15 percentile of all the calculated (XlQ) values within a sector was extracted for use in the intermittent release (XlQ) calculation.

The intermittent release (XlQ) curve was constructed using the calculated 15 percentile (XlQ)1 and its corresponding annual average (XlQ)a. A graphic representation of how the computational procedure works is illustrated by Figure 4.8 of reference 11.15.1. The straight line connecting these points represents (XlQ) 1 values for intermittent releases, ranging in duration from one hour to 8760 hours0.101 days 2.433 hours 0.0145 weeks 0.00333 months . The slope (S) of the curve is expressed as:

or

-(log (X/Q)1 - log (X/Q)a) s= (6.4) log Ta - log T1 6.1.4 Atmospheric Dispersion Parameters for Fanning Areas within the SITE BOUNDARY The dispersion parameters for fanning areas within the SITE BOUNDARY are intended for a narrow scope application: That of calculating the dose to the current farmer from gaseous effluents while he conducts fanning activities within the SITE BOUNDARY.

For the purpose of these calculations, it was assumed that all of the farmer's time, approximately 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months per year, is spent on croplands within the SITE BOUNDARY, and that his time is divided evenly over all of the croplands. Fractional acreage/time - weighted dispersion parameters were calculated for each plot as described in reference 11.5.6. The weighted dispersion parameters for each plot were then summed (according to type) in order to produce a composite value of the dispersion parameters which are presented in Tables 6.1 and 6.2. These dispersion parameters therefore represent the distributed activities of the farmer within the SITE BOUNDARY and his estimated occupancy period.

6.2 ANNUAL METEOROLOGICAL DATA PROCESSING The annual atmospheric dispersion parameters utilized in the calculation of doses for demonstration of compliance with the numerical dose objectives of 10 CFR 50, Appendix I, are detennined using computer codes and models consistent with XOQDOQ (Ref. 11.15). These codes have been validated and verified by a qualified meteorologist prior to implementation.

Multiple sensors are utilized to ensure 90% valid data recovery for the wind speed, wind direction, and ambient air temperature parameters as required by Regulatory Guide 1.23. The selection hierarchy is presented in Table 6.5.

The vertical height of the highest adjacent building (V) used to perform concurrent year annual average atmospheric dispersion (XlQ) calculations is 169.16 meters (Ref. 11.29).

Meteorological Data is periodically verified to ensure valid data is being collected. Health Physics is responsible to ensure this review is performed.

APA-ZZ-OI003 Attachment 2 Rev. 018 TABLE 6.1 to ULNRC-05621 HIGHEST ANNUAL AVERAGE ATMOSPHERIC DISPERSION PARAMETERS UNIT VENT Page 64 of 77 DISTANCE XJQ XJQ LOCATION (b) SECTOR (METERS) XJQ DECAYED/ DECAYED/ D/Q UNDEPT ,RTRD DEPLETED

fi. :FilUrnrnllii!!i!::!i!;~lr~!ili!~!llli:!:!,~i~"~:!:i:'::!;::::!i;!I!ilil~~III!I~il!ii!I'~*k:'i::,,:',.*

SITE BOUNDARY(a) NNW 2200 1.0E-6 9.9E-7 8.5E-7 4.3E-9 Nearest Residence (c) (d) NNW 2897 6.7E-7 6.6E-7 5.6E-7 2.6E-9 Farmer's Residence(c) (f) NNW 2897 6.7E-7 6.6E-7 5.6E-7 2.6E-9 Farming Areas witllln the N/A N/A 2.6E-7 2.6E-7 2.4E-7 1.3E-9 Site Boundary (c) (e)

(a) Values given are from FSAR-SA TABLE 2.3-82 (b) Data from 2002 Land Use Census (c) Values derived from FSAR-SA TABLE 2.3-83, using the methodology presented in Equation (6.1) (Ref. 11.5.6)

(d) All pathways are assumed to exist at the location of the nearest resident.

(e) These values were derived for a narrow scope application. Extreme caution should be exercised when determining their suitability for use in other applications.

(f) In 2002, the Farmer moved to a new location directly across the street from the nearest resident. For conversatism, the same dispersion parameters are used.

Building Shape Parameter (C) = 0.5 (Ref. 11.5.3)

Vertical Height of Highest Adjacent Building (V) = 66.45 meters (Ref. 11.5.3) 52

APA-ZZ-01003 Attachment 2 Rev. 018 TABLE 6.2 to ULNRC-05621 HIGHEST ANNUAL AVERAGE ATMOSPHERIC DISPERSION PARAMETERS RADWASTE VENT AND LAUNDRY DECON FACILITY DRYER EXHAUST Page 65 of 77 DISTANCE XJQ XJQ LOCATION (b) SECTOR (METERS) XJQ DECAYEDI DECAYEDI D/Q UNDEPLETED DEPLETED SITE BOUNDARY(a) NNW 2200 l.3E-6 l.3E-6 l.1E-6 4.3E-9 Nearest Residence (c) (d) NNW 2897 8.5E-7 8.5E-7 7.1E-7 2.6E-9 Farmer's Residence( c)( 1) NNW 2897 8.5E-7 8.5E-7 7.IE-7 2.6E-9 Fanning Areas Within N/A N/A 3.5E-7 3.5E-7 3.2E-7 1.3E-9 Site Boundary (c) (e)

(a) Values given are from FSAR-SA TABLE 2.3-84, (b) Data from 2002 Land Use Census (c) Values derived from FSAR-SA TABLE 2.3-81, using the methodology presented in Equation (6.1) (Ref. 11.5.6)

(d) All pathways are assumed to exist at the location of the nearest resident.

(e) These values were derived for a narrow scope application. Extreme caution should be exercised when determining their suitability for use in other applications.

(1) In 2002, the farmer moved to a new location directly across the street from the nearest residence. For conservatism, the same dispersion parameters are used.

Building Shape Parameter (C) = 0.5 (Ref. 11.5.3)

Vertical Height of Highest Adjacent Building (V) = 19.96 meters (Ref. 11.5.3) 53 APA-ZZ-01003 to ULNRC-05621 Page 66 of 77 Rev. 018 TABLE 6.3 SHORT DISPERSION PARAMETERS (a) (e)

Slope Factor(s)

Location (b) Sector Distance Unit Vent Radwaste Building Vent Site Boundary S 1300 -.328 -.320 Nearest Residence (d) NNW 2897 -.264 -.268 (a) Reference 11.5.3 (b) Data from 1998 Land Use Census (c) Recirculation Factor = 1.0 (d) All pathways are assumed to exist at the location of the nearest resident.

54

APA-ZZ-01003 Attachment 2 Rev. 018 TABLE 6.4 to ULNRC-05621 APPLICATION OF ATMOSPHERIC DISPERSION PARAMETERS Page 67 of 77 Dose Pathway Dispersion Parameter Controll~e GrolJ12 Rec Controlling Location Noble Gas, XJQ, decayed/undepleted N/A l6.ll.2.2 Site Boundary Beta Air & Gamma Air (2.26 day half-life)

Noble Gas, XJQ, decayed/undepleted N/A l6.1l.2.l Site Boundary Total Body & Slcin (2.26 day half-life)

Inhalation XJQ, decayed/depleted Child 16.1l.2.1 Nearest Resident (8 day half-life) 16.1l.2.3 Site Boundary Ground Plane Deposition D/Q N/A 16.1l.2.3 Nearest Resident Ingestion pathways D/Q* Child 16.1l.2.3 Nearest Resident

For H-3, XJQ, decayed/depleted is used instead ofD/Q (Ref. 11.11.1).

55 APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 68 of 77 TABLE 6.5 METEOROLOGICAL DATA SELECTION HIEARCHY Parameter Primary First Second Third Alternate Alternate Alternate Wind Speed lOrnA 10mB 60mA 60mB Wind Direction lOrnA 10mB 60mA 60mB Air Temperature lOrnA 10mB Wind Variability lOrnA 10mB 60mA 60mB Temp Different 60-l0mA 60-l0mB DewpointlRelative lOrnA 60mB Humidity Precipitation 1m (a) A indicates Alpha train meteorological instrumentation.

(b) B indicates Bravo train meteorological instrumentation.

56

APA-ZZ-OI003 Attachment 2 Rev. 018 to ULNRC-05621 Page 69 of 77 Table 6.6 A~~lication of Atmos~heric Dis~ersion Parameters: Radioactive Effluent Release Re~ort Dose Pathway Dispersion Parameter Contr()lling Dispersion Values Controlling Location Age Group .

Noble Gas, XJQ, decayed/undepleted N/A Concurrent Site Boundary Beta Air & Gamma Air Dose (2.26 day half-life) Nearest Resident Noble Gas, XJQ, decayed/undepleted N/A Concurrent Site Boundary Total Body & Skin Dose (2.26 day half-life) Nearest Resident Concurrent Farmer's Residence Historical Inside Site Boundary Ground Plane Deposition Dose DIQ N/A Concurrent Site Boundary Nearest Resident Concurrent Farmer's Residence Historical Inside Site Boundary Inhalation Dose XJQ, decayed/depleted Child Concurrent Site Boundary (8 day half-life) Nearest Resident Adult Concurrent Farmer's Residence Historical Inside Site Boundary Ingestion Dose Pathways DIQ* Child Concurrent Site Boundary Nearest Resident Adult Concurrent Farmer's Residence Historical Inside Site Boundary

For H-3, XJQ, decayed/depleted is used instead ofDIQ (Ref. 11.11.1).

57 APA-ZZ-01003 to ULNRC-05621 Page 70 of 77 Rev. 018 7 REPORTING REOUIREMENTS 7.1 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT The reporting requirements for the Annual Radiological Environmental Operating Report (ARBOR) have been relocated to FSAR-SP 16.11.5.1.

7.2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The reporting requirements for the Annual Radioactive Effluent Release Report (ARBRR) have been relocated to FSAR-SP 16.11.5.2. The application of atmospheric dispersion parameters in the report is presented in Table 6.6.

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 71 of 77 8 IMPLEMENTATION OF ODCM METHODOLOGY (COMN 2791)

The ODCM provides the mathematical relationships used to implement the Radioactive Effluent Controls. For routine effluent release and dose assessment, computer codes are utilized to implement the ODCM methodologies. These codes are evaluated in accordance with the requirements of plant operating procedures to ensure that they produce results consistent with the methodologies presented in the ODCM. Plant procedures implement the ODCM methodology.

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 72 of 77 9 RADIOACTIVE EFFLUENT CONTROLS CREC)

The Radioactive Effluent Controls have been relocated to FSAR-SP CHAPTER 16.11, "Offsite Dose Calculation Manual Radioactive Effluent Controls". The former ODCM REC numbers appear on each of the RECs in FSAR-SP CHAPTER 16.11, and may be used as a cross-reference between the previous and the current numbering system if necessary.

APA-ZZ-OI003 to ULNRC-05621 Rev. 018 Page 73 of 77 10 ADMINISTRATIVE CONTROLS 10.1 MAJOR CHANGES TO LIQUID AND GASEOUS RADWASTE TREATMENT SYSTEMS 10.1.1 Licensee-initiated major changes to the Radwaste Treatment Systems (liquid and gaseous):

a. A summary of the change MUST be reported to the Commission in the Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the On-Site Review Committee (ORC). On site documentation MUST contain:

1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59;

2) Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;

3) A detailed description of the equipment, components and process involved and the interfaces with other plant systems;

4) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents that differ from those previously predicted in the License application and amendments thereto;

5) An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the License application and amendments thereto;

6) A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents, to the actual releases for the period prior to when the changes are to be made;

7) An estimate of the exposure to plant operating personnel as a result of the change; and

8) Documentation of the fact that the change was reviewed and found acceptable by the ORe.

b. Changes to the Radwaste Treatment Systems Shall become effective upon review and approval by the ORe.

10.2 CHANGES TO THE OFFSITE DOSE CALCULATION MANUAL (ODeM) (COMN 2815) 10.2.1 All changes to the ODCM shall be completed pursuant to TIS AC 5.5.1 and approved Per APA-ZZ-00101, "Preparation, Review, Approval and Control of Procedures".

10.2.1.1 All changes shall be approved by the ORC prior to implementation.

10.2.2 Review for each revision of the ODCM must include the Health Physics Department.

10.2.3 A complete and legible copy of each revision of the ODCM that became effective during the last annual period shall be submitted as a part of, or concurrent with that years Radioactive Effluent Release Report pursuant to TIS AC 5.5.1.

APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 74 of 77 11 REFERENCES 11.1 Title 10, "Energy", Chapter 1, Code of Federal Regulations, Part 20; U.S. Government Printing Office, Washington, D.C. 20402.

11.1.1 Statements of Consideration, Federal Register, Vol. 56, No. 98, Tuesday, May 21, 1991, Subpart D, page 23374.

11.2 Title 10, "Energy", Chapter 1, Code of Federal Regulations, Part 50, Appendix I; U.S.

Government Printing Office, Washington, D.C. 20402.

11.2.1 10 CFR 50.36 a (b) 11.3 Title 40, "Protection of Environment", Chapter 1, Code of Federal Regulations, Part 190; U.S.

Government Print Office, Washington, D.C. 20402.

11.4 U.S. Nuclear Regulatory Commission, "Technical Specifications Callaway Plant, Unit NO.1",

NUREG-1058 (Rev. 1), October 1984. Section 5.4.1 11.5 COMMUNICATIONS 11.5.1 Letter NEO-54, D. W. Capone to S. E. Miltenberger, dated January 5, 1983; Union Electric Company correspondence.

11.5.2 Letter BLUE 1285, "Callaway Annual Average X!Q and D/Q Values", J. H. Smith (Bechtel Power Corporation), to D. W. Capone (Union Electric Co.), dated February 27, 1984.

11.5.3 Letter BLUE 1232, "Callaway Annual Average X!Q Values and "S" Values", J. H. Smith (Bechtel Power Corporation) to D. W. Capone (Union Electric Co.), dated February 9, 1984.

11.5.4 Reference Deleted 11.5.5 Private Communication, H. C. Lindeman & B.F. Holderness, August 6, 1986 11.5.6 Calculation ZZ-67, "Annual Average Atmospheric Dispersion Parameters", April 1989.

11.6 Union Electric Company Callaway Plant, Unit 1, Final Safety Analysis Report.

11.6.1 Section 11.5.2.2.3.1 11.6.2 Section 11.5.2.2.3.4 11.6.3 Section 11.5.2.1.2 11.6.4 Section 11.5.2.2.3.2 11.6.5 Section 11.5.2.2.3.3 11.6.6 Section 11.2.3.3.4 11.6.7 Section 11.2.3.4.3 11.6.8 Section 11.5.2.3.3.1 11.6.9 Section 11.5.2.3.3.2 11.6.10 Section 11.5.2.3.2.3 11.6.11 Section 11.5.2.3.2.2 11.6.12 Section 2.3.5 11.6.13 Section 2.3.5.2.1.2 11.6.14 Section 9.2.6 11.6.15 Section 9.2.7.2.l 11.6.16 Section 6.3.2.2 11.6.17 Table 11.1-6 11.6.18 CAR 200700053 - Attachments: Phase 1 Final Draft APA-ZZ-01003 to ULNRC-05621 Rev. 018 Page 75 of 77 11.6.19 Deleted 11.6.20 Deleted 11.6.21 Deleted 11.6.22 Table 2.3-68 11.7 Union Electric Company Callaway Plant Environmental Report, Operating License Stage.

11.7.1 Table 2.1-19 11.7.2 Section 2.1.2.3 11.7.3 Section 2.1.3.3.4 11.7.4 Section 5.2.4.1 11.7.5 Table 2.1-19 11.8 U.S. Nuclear Regulatory Commission, "Preparation of Radiological Effluent Technical Specification for Nuclear Power Plants", USNRC NUREG-0133, Washington, D. C. 20555, October 1978.

11.8.1 Pages AA-1 throughAA-3 11.8.2 Section 5.3.1.3 11.8.3 Section 4.3 11.8.4 Section 5.3.1.5 11.8.5 Section 5.1.1 11.8.6 Section 5.1.2 11.8.7 Section 5.2.1 11.8.8 Section 5.2.1.1 11.8.9 Section 5.3.1 11.8.10 Section 3.8 11.8.11 Section 3.3 11.9 U.S. Nuclear Regulatory Commission, "XOQDOQ, Program For the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", USNRC NUREG-0324, Washington, D. C. 20555.

11.9.1 Pages 19-20 Subroutine PURGE 11.10 Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Coo1ed Reactors", Revision 1, U. S.

Nuclear Regulatory Commission, Washington, D. D. 20555, July, 1977.

11.10.1 Section c.1.b 11.10.2 Figures 7 through 10 11.10.3 Section cA 11.11 Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purposes of Evaluating Compliance with 10 CFR Part 50, Appendix I",

Revision 1, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, October 1977.

11.11.1 Appendix C, Section 3.a 11.11.2 Appendix E, Table E-15 11.11.3 Appendix C, Section 1 11.11.4 Appendix E, Table E-11 to ULNRC-05621 APA-ZZ-01003 Page 76 of 77 Rev. 018 11.11.5 Appendix E, Table E-9 11.12 U. S. Nuclear Regulatory Commission, "Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40 CFR Part 190)", USNRC NUREG-0543, Washington, D.

C. 20555, January 1980.

11.12.1 Section I, Page 2 11.12.2 Section IV, Page 8 11.12.3 Section IV, Page 9 11.12.4 Section III, Page 6 11.12.5 Section III, Page 8 11.13 Management Agreement for the Public Use of Lands, Union Electric Company and the State of Missouri Department of Conservation, December 21, 1982.

11.13.1 Exhibit A 11.14 MISCELLANEOUS REFERENCES 11.14.1 Drawing Number M-I09-0007-06, Revision 5 11.14.2 Callaway Plant Annual Environmental Operating Report (updated annually) 11.14.3 UE Safety Analysis Calculation 87-001-00 11.14.4 Calculation ZZ-48, "Calculation ofInhalation and Ingestion Dose Commitment Factors for the Adult and Child", January, 1988 11.14.5 HPCI 89-02, "Calculation ofODCM Dose Commitment Factors", March, 1989 11.14.6 Deleted 11.14.7 HPCI 87-10, Rev. 1, "Methodology for Calculating the Response of Gross NaI(Tl) Monitors to Liquid Effluent Streams", April, 2005 11.14.8 Calculation ZZ-57, "Dose Factors for Eu-154", January, 1989 11.14.9 Calculation ZZ-78, Rev. 2, "ODCM Gaseous Pathway Dose Factors for Adult Age Group",

July, 1992.

11.14.10 HPCI 06-01, Rev. 0, "Equipment Hatch Platform and Missile Shield Modification Direct Dose Calculation to the Member of the Public", January, 2006.

11.14.11 Calculation ZZ-250, Rev. 0, "ODCM Gaseous Pathway Dose Factors for Child Age Group and Ground Plane Dose Factors", September, 1992.

11.14.12 UOTH 83-58, "Documentation ofODCM Dose Factors and Parameters", February, 1983.

11.14.13 Calculation HPCI 04-06 (Rev. 1), "Calculation of Liquid Effluent Dose Commitment Factors (Ail) for the Adult Age Group", November, 2004.

11.14.14 Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" (Revision 1), February 1979; USNRC, Washington, D. C. 20555 11.15 U. S. Nuclear Regulatory Commission, "XOQDOQ: Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", USNRC NUREG/CR-2919, September 1982, Washington, D. C. 20555 11.15.1 Section 4, "Subroutine PURGE", pages 27 and 28 11.16 Regulatory Guide 4.13, "Performance, Testing, and procedural specifications for Thermoluminiscence Dosimetry: Environmental Applications "(Revision 1), July 1977; USNRC, Washington, D. C. 20555 11.17 TID-7004, "Reactor Shielding Design Manual", Rockwell, Theodore, Ed; March 1956.

11.18 MICROSHIELD, Grove Engineering Inc.

APA-ZZ-01003 to ULNRC-05621 Page 77 of 77 Rev. 018 11.19 HPCI 05-09, "Radiological Environmental Monitoring Program (REMP) calculation of direct dose from RAM storage at Stores II".

11.20 HPCI 05-10, "Radiological Environmental Monitoring Program (REMP) calculation of direct dose from RAM storage in the Radwaste Yard".

11.21 ANSI N13.10-1974, "Specification & Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents"; September, 1974 11.22 Nuclear Regulatory Commission Generic Letter 89-01, "Guidance for the Implementation of Programmatic Controls for RETS in the Administrative Controls Section of Technical Specifications and the Relocation of Procedural Details of Current RETS to the Offsite Dose Calculation Manual or Process Control Program", January 1989 11.23 NRC Answers to 10 CFR 20 Implementation Questions 11.23.1 Letter, F. J. Congel to J. F. Schmidt, dated December 9, 1991.

11.23.2 Internal USNRC memo, F. J. Congel to V. L. Miller, et aI, dated April 17, 1992.

11.23.3 Letter, F. J. Congel to J. F. Schmidt, dated April 23, 1992.

11.23.4 Letter, F. J. Congel to J. F. Schmidt, dated September 14, 1992.

11.23.5 Letter, F. J. Congel to J. F. Schmidt, dated June 8, 1993.

11.24 USNRC Inspection Report 50-483/92002(DRSS) Section 5, page 5.

11.25 HPCI 96-005, "Calculation of Maxirnum Background Value for HB-RE-18".

11.26 EGG-PHY-9703, "Technical Evaluation Report for the evaluation of ODCM Revision 0 (May, 1990) Callaway Plant, Unit I", transmitted via letter, Samual J. Collins (USNRC) to D. F.

Schnell (UE), dated July 12, 1996.

11.27 HPCI 99-005, "Calculation ofSetpoint for GL-RE-202".

11.28 HPCI 99-001, "Documentation ofREMP Procedure Changes".

11.29 "Technical Specifications for Callaway Plant Meteorological Data Software" to ULNRC-05621 Attachment 3 Callaway FSAR-Standard Plant Chapter 16.11 - Offsite Dose Calculation Manual-Radioactive Effluent Controls to ULNRC-05621 CALLAWAY - SP Page 1 of 62 16.11 OFFSITE DOSE CALCULATION MANUAL (ODCM 9.0) RADIOACTIVE EFFLUENT CONTROLS 16.11.1 LIQUID EFFLUENT 16.11.1.1 LIQUID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION (ODCM 9.3.1)

The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 16.11-1) shall be limited to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402, for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10-4 microCurie/ml total activity.

APPLICABILITY: At all times.

ACTION:

a. With the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, immediately restore the concentration to within the above limits.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.1.1.1 SURVEILLANCE REQUIREMENTS (ODCM 9.3.2) 16.11.1.1.1.a Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program of Table 16.11-1.

16.11.1.1.1.b The results of the radioactivity analysis shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of Section 16.11.1.1.

16.11.1.1.2 BASES This section is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will be less than 10 times the concentration in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402. This limitation provides additional assurance that the levels of radioactive materials in bodies 16.11-1 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 2 of 62 of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) the limits of 10 CFR Part 20.1301 to the population. The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

The required detection capabilities for radioactive materials in liquid waste samples are tabulated in terms of the lower limits of detection (LLD's).

16.11-2 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 3 of 62 16.11.1.2 DOSE FROM LIQUID EFFLUENTS LIMITING CONDITION FOR OPERATION (ODCM 9.4.1)

The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrems to the whole body and to less than or equal to 5 mrems to any organ, and

b. During any calendar year to less than or equal to 3 mrems to the whole body and to less than or equal to 10 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. This Special Report shall also include: (1) the results of radiological analyses of the drinking water source, and (2) the radiological impact on finished drinking water supplies with regard to the requirements of 40 CFR Part 141, Clean Drinking Water Act.*

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.1.2.1 SURVEILLANCE REQUIREMENTS (ODCM 9.4.2)

Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

The requirements of ACTION a.(1) and (2) are applicable only if drinking water supply is taken from the receiving water body within 3 miles of the plant discharge. In the case of river-sited plants this is 3 miles downstream only.

16.11-3 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 4 of 62 16.11.1.2.2 BASES This section is provided to implement the requirements of Sections II.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting Condition for Operation implements the guides set forth in Section II.A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable".

Also, for fresh water sites with drinking water supplies that can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR Part 141. The dose calculation methodology and parameters in the ODCM implement the requirements in Section III.A of Appendix I which specify that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculations of Annual Doses to Man from Routine Releases of Reactor Effluents with 10 CFR Part 50, Appendix I", Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic and Dispersion of Effluents from accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I", April 1977.

The reporting requirements of Action(a) implement the requirements of 10CFR20.2203.

16.11-4 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 5 of 62 16.11.1.3 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION (ODCM 9.1.1)

The radioactive liquid effluent monitoring instrumentation channels shown in Table 16.11-2 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Section 16.11.1.1 are not exceeded. The Alarm/Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above, immediately suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable.

b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 16.11-2.

Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3, why this inoperability was not corrected within the time specified.

c. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.1.3.1 SURVEILLANCE REQUIREMENTS (ODCM 9.1.2)

Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 16.11-3.

16.11.1.3.2 BASES The radioactive liquid effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The 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 limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is 16.11-5 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 6 of 62 consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

16.11-6 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 7 of 62 16.11.1.4 LIQUID RADWASTE TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION (ODCM 9.5.1)

The Liquid Radwaste Treatment System shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-1) would exceed 0.06 mrem to the whole body or 0.2 mrem to any organ in a 31 day period.

APPLICABILITY: At all times.

ACTION:

I. With radioactive liquid waste being discharged in excess of the above limits and the Liquid Radwaste Treatment Systems are not being fully utilized, prepare and submit to the Commission within 30 days a Special Report that includes the following information:

1) Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability.

2) Action(s) taken to restore the inoperable equipment to OPERABLE status, and

3) Summary description of action(s) taken to prevent a recurrence.

II. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.1.4.1 SURVEILLANCE REQUIREMENTS (ODCM 9.5.2) 16.11.1.4.1.a Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.

16.11.1.4.1.b The installed Liquid Radwaste Treatment System shall be considered OPERABLE by meeting Sections 16.11.1.1 and 16.11.1.2.

16.11-7 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 8 of 62 16.11.1.4.2 BASES 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 that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable". This section implements the requirements of 10 CFR Part 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.

16.11-8 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 9 of 62 16.11.1.5 LIQUID HOLDUP TANKS (3/4.11.1.4) LIMITING CONDITION FOR OPERATION (3.11.1.4)

The quantity of radioactive material contained in each of the following unprotected outdoor tanks shall be limited to less than or equal to 150 Curies, excluding tritium and dissolved or entrained noble gases:

a. Reactor Makeup Water Storage Tank,

b. Refueling Water Storage Tank,

c. Condensate Storage Tank, and

d. Outside temporary tanks, excluding demineralizer vessels and the liner being used to solidify radioactive waste.

APPLICABILITY: At all times.

ACTION:

a. With the quantity of radioactive material in any of the above listed tanks exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months reduce the tank contents to within the limit, and describe the events leading to this condition in the next Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.1.5.1 SURVEILLANCE REQUIREMENTS (4.11.1.4)

The quantity of radioactive material contained in each of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added and within 7 days following any addition of radioactive material to the tank. The provisions of Sections 16.0.2.2 and 16.0.2.3 are applicable, however the allowed surveillance interval extension beyond 25% shall not be exceeded. These tanks are also covered by Administrative Controls Section 5.5.12.

16.11.1.5.2 BASES The tanks listed above include all those outdoor radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank 16.11-9 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 10 of 62 overflows and surrounding area drains connected to the Liquid Radwaste Treatment System.

Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations would be less than the limits of 10 CFR Part 20.1-20.602, Appendix B, Table II, Column 2, (redesignated at 56FR23391, May 21, 1991) at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA.

16.11-10 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 11 of 62 16.11.2 GASEOUS EFFLUENTS 16.11.2.1 GASEOUS EFFLUENTS DOSE RATE LIMITING CONDITION OF OPERATION (ODCM 9.6.1)

The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 16.11-2) shall be limited to the following:

a. For noble gases: Less than or equal to 500 mrems/yr to the whole body and less than or equal to 3000 mrems/yr to the skin, and

b. For Iodine-131 and 133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the dose rate(s) exceeding the above limits, immediately restore the release rate to within the above limit(s).

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.1.1 SURVEILLANCE REQUIREMENTS (ODCM 9.6.2) 16.11.2.1.1.a The dose rate due to noble gases in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM.

16.11.2.1.1.b The dose rate due to Iodine-131 and 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 in accordance with the methodology and parameters in the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 16.11-4.

16.11-11 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 12 of 62 16.11.2.1.2 BASES This section is provided to ensure that the dose at any time at and beyond the SITE BOUNDARY from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 to UNRESTRICTED AREAS. The dose rate limits are the doses associated with the concentrations of 10 CFR Part 20.1-20.601, Appendix B, Table II, Column 1. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either within or outside the SITE BOUNDARY, to annual average concentrations exceeding the dose limits specified in 10 CFR Part 20 10 CFR 20.1301. For MEMBERS OF THE PUBLIC who may at times be within the SITE BOUNDARY, the occupancy of that MEMBER OF THE PUBLIC will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY. Examples of calculations for such MEMBERS OF THE PUBLIC, with the appropriate occupancy factors, shall be given in the ODCM. 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 or to less than or equal to 3000 mrems/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrems/year.

The required detection capabilities for radioactive materials in gaseous waste samples are tabulated in terms of the lower limits of detection (LLD's).

The requirement for additional sampling of the Unit Vent following a reactor power transient is provided to ensure that the licensee is aware of and properly accounts for any increases in the release of gaseous effluents due to spiking which may occur as a result of the power transient. Monitoring the Unit Vent for increased noble gas activity is appropriate because it is the release point for any increased activity which may result from the power transient.

Since the escape rate coefficients for the noble gas nuclides is equal to or greater than the escape rate coefficient for iodine and the particulate nuclides*,** , it is reasonable to assume that the RCS spiking behavior of the noble gas nuclides is similar to that of the particulate and iodine nuclides. Considering the effects of iodine and particulate partitioning, plateout on plant and ventilation system surfaces, and the 99% efficiency of the Unit Vent HEPA filters and charcoal absorbers, it is reasonable to assume that the relative concentrations of the noble gas nuclides will be much greater than those of the

Cohen, Paul, Water Coolant Technology of Power Reactors, Table 5.19, page 198. American Nuclear Society. 1980.

- NUREG-0772, Technical Bases for Estimating Fission Product Behavior During LWR Accidents, Silberberg, M., editor, USNRC; Figure 4.3, page 4.22. June, 1981.

16.11-12 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 13 of 62 iodine and particulate nuclides. Therefore, an increase in the iodine and particulate RCS activity is not an appropriate indicator of an increase in the Unit Vent activity, and it is appropriate to monitor the Unit Vent effluent activity as opposed to the RCS activity as an indicator of the need to perform post-transient sampling. In addition, it is appropriate to monitor the noble gas activity due to its relatively greater concentration in the Unit Vent.

16.11-13 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 14 of 62 16.11.2.2 DOSE - NOBLE GASES LIMITING CONDITION OF OPERATION (ODCM 9.7.1)

The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-2) shall be limited to the following:

During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation, and During any calendar year: Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

APPLICABILITY: At all times.

ACTION:

a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.2.1 SURVEILLANCE REQUIREMENTS (ODCM 9.7.2)

Cumulative dose contributions for the current calendar quarter and current calendar year for noble gases shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

16.11.2.2.2 BASES This section is provided to implement the requirements of Sections II.B, III.A, and IV.A of Appendix I, 10 CFR Part 50. The Limiting Conditions for Operation implements the guides set forth in Section II.B of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable".

The Surveillance Requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE 16.11-14 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 15 of 62 PUBLIC through appropriate pathways is unlikely to be substantially underestimated.

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

The reporting requirements of Action(a) implement the requirements of 10CFR20.2203.

16.11-15 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 16 of 62 16.11.2.3 DOSE - IODINE-131 AND 133, TRITIUM, AND RADIOACTIVE MATERIAL IN PARTICULATE FORM LIMITING CONDITION OF OPERATION (ODCM 9.8.1)

The dose to a MEMBER OF THE PUBLIC from Iodine-131 and 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-2) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any organ, and

b. During any calendar year: Less than or equal to 15 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of Iodine-131 and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report that identifies the cause(s) for exceeding the limits and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.3.1 SURVEILLANCE REQUIREMENTS (ODCM 9.8.2)

Cumulative dose contributions for the current calendar quarter and current calendar year for Iodine-131 and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

16.11.2.3.2 BASES This section is provided to implement the requirements of Sections II.C, III.A, and IV.A of Appendix I, 10 CFR Part 50. The Limiting Conditions for Operation are the guides set forth in Section II.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the release of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as reasonably achievable". The ODCM calculational methods specified in the Surveillance Requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix 16.11-16 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 17 of 62 I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I", Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors", Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate controls for Iodine-131, and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the existing radionuclide pathways to man, in the areas at and beyond the SITE BOUNDARY. The pathways that were examined in the development of these calculations were: (1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition of radionuclides onto grassy areas where milk animals and meat-producing animals graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure of man.

The reporting requirements of Action(a) implement the requirements of 10CFR20.2203.

16.11-17 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 18 of 62 16.11.2.4 RADIOACTIVE GASEOUS EFFLUENT MONITORING (3/4.3.3.10) INSTRUMENTATION LIMITING CONDITION FOR OPERATION (ODCM 9.2.1)

The radioactive gaseous effluent monitoring instrumentation channels shown in Table 16.11-5 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Section 16.11.2.1 are not exceeded. The Alarm/Trip Setpoints of these channels meeting Section 16.11.2.1 shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 16.11-5.

ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above, immediately declare the channel inoperable.

b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 16.11-5.

Restore the inoperable instrumentation to OPERABLE status within the time specified in the ACTION, or explain in the next Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3, why this inoperability was not corrected within the time specified.

c. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.4.1 SURVEILLANCE REQUIREMENTS (ODCM 9.2.2)

Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 16.11-6.

16.11.2.4.2 BASES The radioactive gaseous effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The 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 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. The sensitivity of any noble gas activity monitor used to show 16.11-18 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 19 of 62 compliance with the gaseous effluent release requirements of Section 16.11.2.1 shall be such that concentrations as low as 1 x 10-6 PCi/cc are measurable.

The monitors GT-RE-22 and GT-RE-33 are only required fo automatic containment purge isolation in MODES 1 through 4. For plant conditions during CORE ALTERATIONS and during movement of irradiated fuel within containment, the function of the monitors is to alarm only and the trip signals for automatic actuation of CPIS may be bypassed. Based on the guidance provided in Regulatory Guide 1.97 concerning monitoring requirements for containment or purge effluent, the monitors GT-RE-22 and GT-RE-33 do not need to meet the single failutre criterion for an Alarm function only during CORE ALTERATIONS or during movement of irradiated fuel in containment. One instrumentation channel at a minimum is required for the alarm only function during refueling activities.

16.11-19 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 20 of 62 16.11.2.5 GASEOUS RADWASTE TREATMENT SYSTEM LIMITING CONDITION OF OPERATION (ODCM 9.9.1)

The VENTILATION EXHAUST TREATMENT SYSTEM and the WASTE GAS HOLDUP SYSTEM shall be OPERABLE and appropriate portions of these systems shall be used to reduce releases of radioactivity when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-2) would exceed:

a. 0.2 mrad to air from gamma radiation, or

b. 0.4 mrad to air from beta radiation, or

c. 0.3 mrem to any organ of a MEMBER OF THE PUBLIC.

APPLICABILITY: At all times ACTION:

I. With radioactive gaseous waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days a Special Report that includes the following information:

1) Identification of any inoperable equipment or subsystems, and the reason for the inoperability,

2) Action(s) taken to restore the inoperable equipment to OPERABLE status, and

3) Summary description of action(s) taken to prevent a recurrence.

II. The provision of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.5.1 SURVEILLANCE REQUIREMENTS (ODCM 9.9.2) 16.11.2.5.1.a Doses due to gaseous releases from each unit to areas at and beyond the SITE BOUNDARY shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.

16.11.2.5.1.b 16.11-20 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 21 of 62 The installed VENTILATION EXHAUST TREATMENT SYSTEM and the WASTE GAS HOLDUP SYSTEMS shall be considered OPERABLE by meeting Sections 16.11.2.1 and 16.11.2.2 or 16.11.2.3.

16.11.2.5.2 BASES The OPERABILITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable". This control implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives given in Section II.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

16.11-21 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 22 of 62 16.11.2.6 EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION The concentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be limited to less than or equal to 3% by volume whenever the hydrogen concentration exceeds 4%

by volume.

APPLICABILITY: At all times.

ACTION:

a. With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than 3% by volume but less than or equal to 4% by volume, reduce the oxygen concentration to the above limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

b. With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM greater than 4% by volume and the hydrogen concentration greater than 4% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration on oxygen to less than or equal to 4% by volume, then take ACTION a. above.

c. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.6.1 SURVEILLANCE REQUIREMENTS The concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM shall be determined to be within the above limits by continuously monitoring the waste gases in the WASTE GAS HOLDUP SYSTEM with the hydrogen and oxygen monitors required OPERABLE by Section 16.11.2.7. The provisions of Sections 16.0.2.2 and 16.0.2.3 are applicable, however the allowed surveillance interval extension beyond 25%

shall not be exceeded. This system is also covered by Administrative Controls Section 5.5.12.

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

16.11-22 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 23 of 62 16.11.2.7 WASTE GAS HOLDUP SYSTEM RECOMBINER EXPLOSIVE GAS MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION At least one hydrogen and both the inlet and outlet oxygen explosive gas monitoring instrument channels for each WASTE GAS HOLDUP SYSTEM recombiner shall be OPERABLE with their Alarm/Trip Setpoints (with the exception of the "FEED H2 4%/

FEED O2 3%" and "FEED H2 4%/FEED O2 4%" alarms) set to ensure that the limits of Section 16.11.2.6 are not exceeded.

APPLICABILITY: During WASTE GAS HOLDUP SYSTEM operation.

ACTION:

a. With an outlet oxygen monitor channel inoperable, operation of the system may continue provided grab samples are taken and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. With both oxygen or both hydrogen channels or both the inlet oxygen and inlet hydrogen monitor channels for one recombiner inoperable, suspend oxygen supply to the recombiner. Addition of waste gas to the system may continue provided grab samples are taken and analyzed at least; 1) once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during mechanical or chemical degassing in preparation for plant shutdown and 2) once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations.

c. With the inlet Oxygen analyzer inoperable, operation of the system may continue provided the inlet Hydrogen is maintained less than 4%. If inlet Hydrogen is greater than 4%, suspend oxygen to the recombiner. Addition of waste gas to the system may continue provided grab samples are taken and analyzed at least; 1) once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during mechanical or chemical degassing operations in preparation for plant shutdown and 2) once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations.

d. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.7.1 SURVEILLANCE REQUIREMENTS The provisions of Sections 16.0.2.2 and 16.0.2.3 are applicable, however the allowed surveillance interval extension beyond 25% shall not be exceeded. This system is also covered by Administrative Controls Section 5.5.12.

Each waste gas holdup system recombiner explosive gas monitoring instrumentation channel shall be demonstrated OPERABLE by performance of:

a. A CHANNEL CHECK at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 16.11-23 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 24 of 62

b. Not used

c. A CHANNEL CALIBRATION at least once per 92 days with the use of standard gas samples containing a nominal:

1) One volume percent hydrogen, balance nitrogen and four volume percent hydrogen, balance nitrogen for the hydrogen monitor, and

2) One volume percent oxygen, balance nitrogen, and four volume percent oxygen, balance nitrogen for the inlet oxygen monitor, and

3) 10 ppm by volume oxygen, balance nitrogen and 80 ppm by volume oxygen, balance nitrogen for the outlet oxygen monitor.

16.11.2.7.2 BASES Mechanical 'degassing operation' is defined as the transfer of gas from the Volume Control Tank (VCT) to the Waste Gas Holdup System when establishing a nitrogen blanket on the VCT in preparation for a plant shutdown. Chemical 'degassing operation' is the process of adding hydrogen peroxide to the RCS after the VCT hydrogen blanket has been replaced with nitrogen per the Mechanical degassification process and the RCS has been reduced to less than 180°F. Both Mechanical and Chemical degassification may lead to an explosive gas mixture in the Waste Gas Holdup System, thus requiring the more restrictive 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sampling. Other operations require 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months sampling.

The "FEED H2 4%/FEED O2 3%" AND "FEED H2 4%/FEED O2 4%" alarms are not required to be OPERABLE. These alarms result from the combination of inlet Hydrogen and inlet Oxygen analyzer outputs while the FSAR only addresses OPERABILITY of each separate analyzer. Only the individual alarms and control functions associated with each analyzer are to be used to determine its operability. These alarms and control functions are sufficient to ensure that the requirements of Section 16.11.2.6 are not exceeded.

The CHANNEL CALIBRATION will include triggering the following alarms at the analyzer and verifying that the required control board annunciators and control functions actuate:

1) Feed Gas High H2

2) HARC-1104 OAIC-1112 Hi Hi H2/O2 O2 Shutdown

3) H2 Reactor High Oxygen O2 Limit

4) Product Gas High H2 16.11-24 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 25 of 62

5) Product Gas High Oxygen

6) Product Gas Hi Hi O2 Shutdown This will verify the OPERABILITY of the analyzers output relays, all interposing relays, and the annunciators. Setpoint verification will consist of verifying that the correct setpoint values are entered in the analyzers database.

16.11-25 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 26 of 62 16.11.2.8 GAS STORAGE TANKS LIMITING CONDITION FOR OPERATION The quantity of radioactivity contained in each gas storage tank shall be limited to less than or equal to 2.5 x 105 Curies of noble gases (considered as Xe-133 equivalent).

APPLICABILITY: At all times.

ACTION:

a. With the quantity of radioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , reduce the tank contents to within the limit, and describe the events leading to this condition in the next Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.2.8.1 SURVEILLANCE REQUIREMENTS The provisions of Sections 16.0.2.2 and 16.0.2.3 are applicable, however the allowed surveillance interval extension beyond 25% shall not be exceeded. This system is also covered by Administrative Controls Section 5.5.12.

The quantity of radioactive material contained in each gas storage tank shall be determined to be within the above limit at least once per 18 months.

16.11.2.8.2 BASES The tanks included in this specification are those tanks for which the quantity of radioactivity contained is not limited directly or indirectly by another Technical Specification. Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting whole body exposure to a MEMBER OF THE PUBLIC at the nearest SITE BOUNDARY will not exceed 0.5 rem. This is consistent with Standard Review Plan 11.3, Branch Technical Position ETSB 11-5, "Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure," in NUREG-0800, July 1981. The determination of Xe-133 equivalent uses the effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, EPA-402-R-93-081, External Exposure to Radionuclides in Air, Water, and Soil, 1993.

16.11-26 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 27 of 62 16.11.3 TOTAL DOSE 16.11.3.1 TOTAL DOSE LIMITING CONDITION FOR OPERATION (ODCM 9.10.1)

The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrems to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

APPLICABILITY: At all times.

ACTION:

a. With the calculated doses from the release of radioactive materials in gaseous effluents exceeding twice the limits of Section 16.11.2.2a, 16.11.2.2b, 16.11.2.3a, or 16.11.2.3b, calculations should be made including direct radiation contributions from the units and from outside storage tanks to determine whether the above limits of Section 16.11.3.1 have been exceeded. If such is the case, prepare and submit to the Commission within 30 days a Special Report that defines the corrective action to be taken to reduce subsequent release to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in 10 CFR 20.2203, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations. If the estimated dose(s) exceeds the above limits, and if the release condition resulting in violation of 40 CFR Part 190 has not already been corrected, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

b. The provisions of Technical Specifications 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.3.1.1 SURVEILLANCE REQUIREMENTS (ODCM 9.10.2) 16.11.3.1.1.a 16.11-27 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 28 of 62 Cumulative dose contributions from gaseous effluents shall be determined in accordance with Sections 16.11.2.2.1, and 16.11.2.3.1, and in accordance with the methodology and parameters in the ODCM.

16.11.3.1.1.b Cumulative dose contributions from direct radiation from the units and from radwaste storage tanks shall be determined in accordance with the methodology and parameters in the ODCM. This requirements is applicable only under conditions set forth in ACTION

a. of Section 16.11.3.1.

16.11.3.1.2 BASES This specification is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20.1301. The control requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and the radiation from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ except the thyroid, which shall be limited to less than or equal to 75 mrems. For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix I, and if direct radiation doses from the reactor units and from outside storage tanks are kept small. The Special Report will describe a course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits.

For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR Part 190.11 and 10 CFR 20.2203, is considered to be a timely request and fulfills the requirements of 40 CFR Part 190 until NRC staff action is completed. The variance only relates to 40 CFR Part 190, and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in Sections 16.11.1.1 and 16.11.2.1.

An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.

There are three defined effluent release categories: 1.) Releases directly to the hydrosphere; 2.) noble gas releases to the atmosphere; 3.) radioiodine and particulate releases to the atmosphere. For each effluent release category, it is assumed in the dose calculations that an individual with the highest dose potential is the receptor. In general, the adult is considered to be the critical age group for liquid effluents, and the child age group is the most limiting for radioiodine and particulates in gaseous effluents.

16.11-28 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 29 of 62 Thus, it is highly unlikely or impossible for the same individual to simultaneously receive the highest dose via all three effluent categories. For most reactor sites, it is also unlikely that all different potential dose pathways would contribute to the dose to a single real individual. Since it is difficult or impossible to continually determine actual food use patterns and critical age group, for calculational purposes, assumptions are made which tend to maximize doses. Any refinement in the assumptions would have the effect of reducing the estimated dose. For radionuclides released to the hydrosphere, the degree of overestimation in most situations is such that no individual will receive a significant dose. These conservative assumptions generally result in an overestimation of dose by one or two orders of magnitude. Since these assumptions are reflected in the Radiological Effluent Controls limiting radionuclide releases to design objective individual doses, no offsite individual is likely to actually receive a significant dose. Since the doses from liquid releases are very conservatively evaluated, there is reasonable assurance that no real individual will receive a significant dose from radioactive liquid release pathway. Therefore, only doses to individuals via airborne pathways and dose resulting from direct radiation need to be considered in determining potential compliance to 40 CFR 190*.

The reporting requirements of Action(a) implement the requirements of 10CFR20.2203.

NUREG-0543, Methods for Demonstrating LWR compliance with the EPA Uranium Fuel Cycle Standard (40 CFR 190), Congel, F. J., Office of Nuclear Reactor Regulation, USNRC. January, 1980.

pp. 5-8.

16.11-29 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 30 of 62 16.11.4 RADIOLOGICAL ENVIRONMENTAL MONITORING 16.11.4.1 MONITORING PROGRAM LIMITING CONDITION OF OPERATION (ODCM 9.11.1)

The Radiological Environmental Monitoring Program shall be conducted as specified in Table 16.11-7.

APPLICABILITY: At all times.

ACTION:

a. With the Radiological Environmental Monitoring Program not being conducted as specified in Table 16.11-7, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Technical Specification 5.6.2, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

b. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 16.11-8 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose* to a MEMBER OF THE PUBLIC is less than the calendar year limits of Sections 16.11.1.2, 16.11.2.2, or 16.11.2.3. When more than one of the radionuclides in Table 16.11-8 are detected in the sampling medium, this report shall be submitted if:

concentration (1)- + concentration

(2)- + } t 1.0 reporting level (1) reporting (2)

When radionuclides other than those in Table 16.11-8 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose*

to A MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of Sections 16.11.1.2, 16.11.2.2 or 16.11.2.3. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report, required by Technical Specification 5.6.2.

c. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 16.11-7, identify specific locations for

The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report.

16.11-30 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 31 of 62 obtaining replacement samples and add them within 30 days to the Radiological Environmental Monitoring Program*. The specific locations from which samples were unavailable may then be deleted from the monitoring program. In the next Annual Radiological Environmental Operating Report include the revised figure(s) and tables reflecting the new sample location(s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of new location(s) for obtaining samples.

d. When LLDs specified in Table 16.11-9 are unachievable due to uncontrollable circumstances, (such as background fluctuations, unavailable small sample sizes, the presence of interfering nuclides, etc.) the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report.

e. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.4.1.1 SURVEILLANCE REQUIREMENTS (ODCM 9.11.2)

The radiological environmental monitoring samples shall be collected pursuant to Table 16.11-7 and shall be analyzed pursuant to the requirements of Table 16.11-7 and the detection capabilities required by Table 16.11-9.

16.11.4.1.2 BASES The Radiological Environmental Monitoring Program required by this REC provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation. This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and thereby supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways. Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring, Revision 1, November 1979. The initially specified monitoring program will be effective for at least the first 3 years of commercial operation. Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLD's). The LLD's required by Table 16.11-9 are considered optimum for routine environmental measurements in industrial laboratories.

Excluding short term or temporary unavailability.

16.11-31 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 32 of 62 16.11.4.2 LAND USE CENSUS LIMITING CONDITION OF OPERATION (ODCM 9.12.1)

A Land Use Census shall be conducted and shall identify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence and the nearest garden* of greater than 50m2 (500 ft2) producing broad leaf vegetation. The Land Use Census shall identify water intakes constructed within 10 river miles downstream of the plant discharge point.

APPLICABILITY: At all times.

ACTION:

a. With a Land Use Census identifying a location(s) that yields a calculated dose or dose commitment greater than the values currently being calculated by Section 16.11.2.3.1, identify the new location(s) in the next Radioactive Effluent Release Report, pursuant to Technical Specification 5.6.3.

b. With a Land Use Census identifying a location(s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with Section 16.11.4.1, add the new location(s) within 30 days to the Radiological Environmental Monitoring Program except for vegetation samples which shall be added to the program before the next growing season. The sampling location(s),

excluding the control station location, having the lowest calculated dose or dose commitment(s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was conducted. In the next Annual Radiological Environmental Operating Report include the revised figure(s) and tables reflecting the new sample location(s) with information supporting the change in sample location.

c. With a Land Use Census identifying a water intake within 10 river miles downstream of the plant discharge point, implement the appropriate waterborne or ingestion sampling required by Table 16.11-7.

d. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

Broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the SITE BOUNDARY in each to two different direction sectors with the highest predicted D/Q's in lieu of the garden census. Specifications for broad leaf vegetation sampling in Table 9.11-A, Part 4.c shall be followed, including analysis of control samples.

16.11-32 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 33 of 62 16.11.4.2.1 SURVEILLANCE REQUIREMENTS (ODCM 9.12.2)

The Land Use Census shall be conducted during the growing season at least once per 12 months using that information which will provide the best results, such as, but not limited to, door-to-door survey, aerial survey, or by consulting local agriculture authorities and/or residents. The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2.

16.11.4.2.2 BASES This specification is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made if required by the results of this census. Information that will provide the best results, such as door-to-door survey, aerial survey, or consulting with local agricultural authorities, shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50.

Restricting the census to gardens of greater than 50 m2 provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: (1) 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and (2) a vegetation yield of 2 kg/m2.

16.11-33 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 34 of 62 16.11.4.3 INTERLABORATORY COMPARISON PROGRAM LIMITING CONDITION OF OPERATION (ODCM 9.13.1)

Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program that has been approved by the USNRC.

APPLICABILITY: At all times.

ACTION:

a. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2.

b. The provisions of Sections 16.0.1.3 and 16.0.1.4 are not applicable.

16.11.4.3.1 SURVEILLANCE REQUIREMENTS (ODCM 9.13.2)

The Interlaboratory Comparison Program shall be described in the plant procedures. A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2.

16.11.4.3.2 BASES The requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purpose of Section IV.B.2 of Appendix I to 10 CFR Part 50.

16.11-34 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 35 of 62 16.11.5 ADMINISTRATIVE CONTROLS 16.11.5.1 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (ODCM 7.1)

Routine Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, with operational controls and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

The reports shall include the results of Land Use Census required by Section 16.11.4.2.

It shall also include a listing of new locations for environmental monitoring identified by the Land Use Census pursuant to Section 16.11.4.2.

The Annual Radiological Environmental Operating Report shall include the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to Section 16.11.4.1, as well as summarized tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report. The reports shall also include the following: a summary description of the radiological environmental monitoring program; at least two legible maps* covering all sampling locations keyed to a table giving distances and directions from the midpoint between the two reactors; the results of licensee participation in the Interlaboratory Comparison Program and the corrective action being taken if the specified program is not being performed as required by Section 16.11.4.3; reasons for not conducting the Radiological Environmental Monitoring Program as required by Section 16.11.4.1 and discussion of all deviations from the sampling schedule of Table 16.11-7, discussion of environmental sample measurements that exceed the reporting levels of Table 16.11-8, but are not the result of the plant effluents, pursuant to Section 16.11.4.1; and discussion of all analyses in which the LLD required by Table 16.11-9 was not achievable.

16.11.5.1.1 BASES The reporting requirement for the Annual Radiological Environmental Operating Report is provided to ensure compliance with Technical Specification 5.6.2. This requirement was relocated from the Offsite Dose Calculation Manual to FSAR Chapter 16.

One map shall cover stations near the SITE BOUNDARY; a second shall include the more distant stations.

16.11-35 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 36 of 62 16.11.5.2 RADIOACTIVE EFFLUENT RELEASE REPORT (ODCM 7.2)

Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The Radioactive Effluent Release Report shall include a summary of the quantities of radioactive liquid and gaseous effluents released from the unit as outlined in Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, "Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report shall include an annual summary of hourly meteorological data collected over the previous calender year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distribution of wind speed, wind direction, and atmospheric stability* .

This report shall also include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit during the previous calendar year.

This report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY (Figures 16.11-1 and 16.11-2) during the report period using historical average atmospheric conditions. All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be included in these reports. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses. Assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

The Radioactive Effluent Release Report shall include an assessment of radiation doses to the most likely exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conformance with 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operation."

Doses to the MEMBER OF THE PUBLIC shall be calculated using the methodology and parameters of the ODCM.

In lieu of submission with the Annual Radioactive Effluent Release Report, Union Electric has the option of retaining this summary of required meteorological data on site in a file that shall be provided to the NRC upon request.

16.11-36 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 37 of 62 The Radioactive Effluent Release Report shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

The Radioactive Effluent Release Report shall include a summary description of any major changes made during the year to any Liquid or Gaseous Treatment Systems, pursuant to Offsite Dose Calculation Manual. It shall also include a listing of new locations for dose calculations identified by the Land Use Census pursuant to Section 16.11.4.2.

Reporting requirements for changes to Solid Waste Treatment Systems are addressed in APA-ZZ-01011, PROCESS CONTROL PROGRAM (PCP).

The Radioactive Effluent Release Report shall also include the following information: An explanation as to why the inoperability of liquid or gaseous effluent monitoring instrumentation was not corrected within the time specified, and a description of the events leading the liquid holdup tanks or gas storage tanks exceeding the limits of Section 16.11.1.5 or 16.11.2.8.

The Radioactive Effluent Release Report shall include as part of or submitted concurrent with, a complete and legible copy of all revisions of the ODCM that occurred during the year pursuant of Technical Specification 5.5.1.

Solid Waste reporting is addressed in APA-ZZ-01011, PROCESS CONTROL PROGRAM (PCP).

16.11.5.2.1 BASES The reporting requirement for the Radioactive Effluent Release Report is provided to ensure compliance with Technical Specification 5.6.3. This requirement was relocated from the Offsite Dose Calculation Manual to FSAR Chapter 16.

16.11-37 Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 38 of 62 TABLE 16.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM

1. Discharge Monitor Tanks (Batch Release) (2)

SAMPLING FREQUENCY(7) TYPE OF LLD (1)

MINIMUM ANALYSIS ACTIVITY (PCi/ml)

FREQUENCY ANALYSIS Prior to Each Batch Prior to Each Batch Principal Gamma Emitters (3) 5E-7 I-131 1E-6 Dissolved and Entrained 1E-5 Gases (Gamma Emitters)

H-3 1E-5 Monthly Composite (4) Gross Alpha 1E-7 Quarterly Composite (4) Sr-89, Sr-90 5E-8 Fe-55 1E-6 Ni-63 5E-8 Np-237 5E-9 Pu-238 5E-9 Pu-239/240 5E-9 Pu-241 5E-7 Am-241 5E-9 Cm-242 5E-9 Cm-243/244 5E-9

2. Steam Generator Blowdown (Continuous Release) (5)

SAMPLING FREQUENCY(7) TYPE OF LLD (1)

MINIMUM ANALYSIS ACTIVITY (PCi/ml)

FREQUENCY ANALYSIS Daily Grab Sample (6) Daily Principal Gamma Emitters (3) 5E-7 I-131 1E-6 Dissolved and Entrained 1E-5 Gases (Gamma Emitters)

H-3 1E-5 MonthlyComposite (4) Gross Alpha 1E-7 Quarterly Composite (4) Sr-89, Sr-90 5E-8 Fe-55 1E-6 TABLE NOTATIONS (1) The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

4.66 S b LLD = -------------------------------------------------------------------------------------

E x V x 2.22E6 x Y x exp - O't Where:

LLD = the "a priori" lower limit of detection (microCuries per unit mass or volume),

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

E = the counting efficiency (counts per disintegration),

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

2.22E6= the number of disintegrations per minute per microCurie, Y = the fractional radiochemical yield, when applicable, O = the radioactive decay constant for the particular radionuclide (sec-1), and Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 39 of 62 TABLE 16.11-1 (Sheet 2)

't = the elapsed time between the midpoint of the sample collection period, and the time of counting (sec). For batch releases, 't=0.

Typical values of E, V, Y, and 't should be used in the calculation.

It should be recognized that the LLD is defined as a "a priori" (before the fact) limit representing the capability of a measurement system and not as an "a posteriori" (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LLD's will be achieved under routine conditions.

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

(3) The principal gamma emitters for which the LLD control applies include the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Radioactive Effluent Release Report pursuant to Technical Specification 5.6.3, in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974.

(4) A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen that is representative of the liquids released. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite samples to be representative of the effluent release.

(5) A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g., from a volume of a system that has an input flow during the continuous release.

(6) Samples shall be taken at the initiation of effluent flow and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter while the release is occurring.

To be representative of the liquid effluent, the sample volume shall be proportioned to the effluent stream discharge volume.

The ratio of sample volume to effluent discharge volume shall be maintained constant for all samples taken for the composite sample.

(7) Samples shall be representative of the effluent release.

Rev. OL-16 10/07 to ULNRC-05621 CALLAWAY - SP Page 40 of 62 TABLE 16.11-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE ACTION

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release

a. Liquid Radwaste Discharge Monitor 1 31 (HB-RE-18)

b. Steam Generator Blowdown 1 32 Discharge Monitor (BM-RE-52)

2. Flow Rate Measurement Devices

a. Liquid Radwaste Blowdown 1 34 Discharge Line (HB-FE-2017)

b. Steam Generator Blowdown 1 34 Discharge Line (BM-FE-0054)

c. Cooling Tower Blowdown and 1 34 Bypass Flow Totalizer (FYDB1017A)

3. Discharge Monitoring Tanks (DMT's) Level

a. DMT A(HB-LI-2004) 1 33

b. DMT B(HB-LI-2005) 1 33 ACTION STATEMENTS ACTION 31 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that prior to initiating a release:

a. At least two independent samples are analyzed in accordance with Section 16.11.1.1.1, and

b. At least two technically qualified members of the facility staff independently verify the release rate calculations and discharge line valving.

Otherwise, suspend release of radioactive effluents via this pathway.

Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 41 of 62 TABLE 16.11-2 (Sheet 2)

ACTION STATEMENTS ACTION 32 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided grab samples are analyzed for principal gamma emitters and I-131 at a lower limit of detection as specified in Table 16.11-1:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the specific activity of the secondary coolant is greater than 0.01 micro-Curie/gram DOSE EQUIVALENT I-131, or

b. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the specific activity of the secondary coolant is less than or equal to 0.01 micro-Curie/gram DOSE EQUIVALENT I-131.

ACTION 33 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the volume discharged is determined by alternate means.

ACTION 34 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, 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 during actual releases. Pump performance curves generated in place may be used to estimate flow.

Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 42 of 62 TABLE 16.11-3 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL SOURCE CHANNEL OPERATIONAL INSTRUMENT CHECK CHECK CALIBRATION TEST

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release

a. Liquid Radwaste D P R(2) Q(1)

Discharge Monitor (HB-RE-18)

b. Steam Generator D M R(2) Q(1)

Blowdown Discharge Monitor (BM-RE-52)

2. Flow Rate Measurement Devices

a. Liquid Radwaste D(3) N.A. R N.A.

Blowdown Discharge Line (HB-FE-2017)

b. Steam Generator D(3) N.A. R N.A.

Blowdown Discharge Line (BM-FE-0054)

c. Cooling Tower D(3) N.A. R N.A.

Blowdown and Bypass Flow Totalizer (FYDB1017A)

3. Discharge Monitoring Tanks (DMT's) Level

a. DMT A(HB-LI-2004) Prior to N.A. R N.A.

release (4)

b. DMT B(HB-LI-2005) Prior to N.A. R N.A.

release (4)

Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 43 of 62 TABLE 16.11-3 (Sheet 2)

TABLE NOTATIONS

1. The CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur as appropriate if any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm/Trip Setpoint (isolation and alarm), or

b. Circuit failure (alarm only), or

c. Instrument indicates a downscale failure (alarm only), or

d. Instrument controls not set in operate mode (alarm only).

2. The initial CHANNEL CALIBRATION shall be performed using one or more of the reference (gas or liquid and solid) standards obtained from the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy, measurement range, and establish monitor response to a solid calibration source.

For subsequent CHANNEL CALIBRATION, NIST traceable standard (gas, liquid, or solid) may be used; or a gas, liquid, or solid source that has been calibrated by relating it to equipment that was previously (within 30 days) calibrated by the same geometry and type of source standard traceable to NIST.

3. CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are made.

4. CHANNEL CHECK shall consist of verifying indication of tank level during periods of release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are made from the DMT.

Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 44 of 62 TABLE 16.11-4 RADIOACTIVE GASEOUS EFFLUENTS SAMPLING AND ANALYSIS PROGRAM

1. Waste Gas Decay Tank SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Prior to each release- grab Prior to each tank Principal Gamma Emitters- 1E-4 sample particulate, iodine, noble gas (2)

Continuous See footnote 8

2. Containment Purge or Vent SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Prior to each release- grab Prior to each release Principal Gamma Emitters- 1E-4 sample particulate, iodine, noble gas (2)

H-3(oxide) 1E-6 Continuous See footnote 8

3. Unit Vent (3)

SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Monthly- grab sample (3)(4) Monthly (3)(4) Principal Gamma Emitters- 1E-4 noble gas (2)

H-3(oxide) 1E-6 Continuous (6) Weekly (7) I-131 1E-12 I-133 1E-10 Principal Gamma Emitters- 1E-11 particulate nuclides only (2)

MonthlyComposite Gross Alpha 1E-11 Quarterly Composite Sr-89, Sr-90 1E-11

4. Radwaste Building Vent SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Monthly- grab sample Monthly Principal Gamma Emitters- 1E-4 noble gas (2)

Continuous (6) Weekly (7) I-131 1E-12 I-133 1E-10 Principal Gamma Emitters- 1E-11 particulate nuclides only (2)

Monthly Composite Gross Alpha 1E-11 Quarterly Composite Sr-89, Sr-90 1E-11

5. Laundry Decontamination Facility Dryer Exhaust SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Continuous (6) Weekly (7) Principal Gamma Emitters- 1E-11 particulate nuclides only (2)

Monthly (10) Composite Gross Alpha 1E-11 Quarterly (10) Composite Sr-89, Sr-90 1E-11 Rev. OL-15 5/06 to ULNRC-05621 CALLAWAY - SP Page 45 of 62 TABLE 16.11-4 (Sheet 2)

6. Containment ILRT Depressurization (Post-test Vent)

SAMPLING FREQUENCY (9) MINIMUM ANALYSIS TYPE OF ACTIVITY ANALYSIS LLD (1)

FREQUENCY (PCi/ml)

Prior to each release- grab Prior to each release Principal Gamma Emitters- 1E-4 sample particulate, iodine, noble gas (2)

H-3(oxide) 1E-6 TABLE NOTATIONS (1) The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

4.66 S b LLD = -------------------------------------------------------------------------------------

E x V x 2.22E6 x Y x exp - O't Where:

LLD = the "a priori" lower limit of detection (microCuries per unit mass or volume),

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

E = the counting efficiency (counts per disintegration),

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

2.22E6= the number of disintegrations per minute per microCurie, Y = the fractional radiochemical yield, when applicable, O = the radioactive decay constant for the particular radionuclide (sec-1), and

't = the elapsed time between the midpoint of the sample collection period, and the time of counting (sec).

Typical values of E, V, Y, and 't should be used in the calculation.

It should be recognized that the LLD is defined as a "a priori" (before the fact) limit representing the capability of a measurement system and not as an "a posteriori" (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LLD's will be achieved under routine conditions.

(2) The principal gamma emitters for which the LLD specification applies include the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, Co-60, Zn-65, I-131, Cs-134, Cs-137, Ce-141, and Ce-144 in iodine and particulate releases. This list does not mean that only these nuclides are to be considered. Any nuclide which is identified in the sample and which is also listed in the ODCM gaseous effluents dose factor tables, shall be analyzed and reported in the Radioactive Effluent Release Report.

(3) If the Unit Vent noble gas monitor (GT-RE-21B) shows that the effluent activity has increased (relative to the pre-transient activity) by more than a factor of 3 following a reactor shutdown, startup, or a thermal power change which exceeds 15% of the rated thermal power within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, samples shall be obtained and analyzed for noble gas, particulates and iodines.

This sampling shall continue to be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for a period of 7 days or until the Unit Vent noble gas monitor no longer indicates a factor of 3 increase in Unit Vent noble gas activity, whichever comes first.

(4) Tritium grab samples shall be taken and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the refueling canal is flooded.

(5) Deleted.

(6) The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Sections 16.11.2.1, 16.11.2.2, and 16.11.2.3.

(7) Samples shall be changed at least once per 7 days and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing, or removal from the sampler. When sampling is performed in accordance with footnote 3 (above), then the LLD may be increased by a factor of 10.

(8) Continuous sampling of this batch release pathway is included in the continuous sampling performed for the corresponding continuous release pathway.

(9) Samples shall be representative of the effluent release.

(10) Required only if Mn-54, Fe-59, Co-58, Co-60, Zn-65, Cs-134, Cs-137, Ce-141, or Ce-144 are detected in principle gamma emitter analyses.

Rev. OL-15 5/06 to ULNRC-05621 CALLAWAY - SP Page 46 of 62 TABLE 16.11-5 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

1. Unit Vent System

a. Noble Gas Activity 1 At all times 40,46 Monitor - Providing Alarm (GT-RE-21)

b. Iodine Sampler 1 At all times 43

c. Particulate Sampler 1 At all times 43

d. Unit Vent Flow Rate 1 At all times 45

e. Particulate and 1 At all times 43 Radioiodine Sampler Flow Rate Monitor

2. Containment Purge System

a. Noble Gas Activity Monitor

- Providing Alarm and 2 MODES 1,2,3, and 41 Automatic 4.

Termination of Release (GT-RE-22, GT-RE-33)

- Providing Alarm 1 During CORE 42 function only ALTERATIONS or movement of irradiated fuel within the containment

b. Iodine Sampler 1 MODES 1,2,3,4 and 43 during CORE ALTERATIONS or movement of irradiated fuel within the containment

c. Particulate Sampler 1 MODES 1,2,3,4 and 43 during CORE ALTERATIONS or movement of irradiated fuel within the containment

d. Containment Purge N/A N/A N/A Ventilation Flow Rate Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 47 of 62 TABLE 16.11-5 (Sheet 2)

e. Particulate and 1 MODES 1,2,3,4 and 43 Radioiodine Sampler during CORE Flow Rate Monitor ALTERATIONS or movement of irradiated fuel within the containment

3. Radwaste Building Vent System

a. Noble Gas Activity 1 At all times 38,40 Monitor-Providing Alarm and Automatic Termination of Release (GH-RE-10)

b. Iodine Sampler 1 At all times 43

c. Particulate Sampler 1 At all times 43

d. Radwaste Building Vent N/A N/A N/A Flow Rate

e. Particulate and 1 At all times 43 Radioiodine Sampler Flow Rate Monitor

4. Laundry Decontamination Faciliy Dryer Exhaust

a. Particulate Monitor 1 When the dryers 47 are operating

b. Particulate Monitor Flow 1 When the dryers 47 Rate Meter are operating

c. Dryer Exhaust NA NA NA Ventilation Flow Rate ACTION STATEMENTS ACTION 38 - With the number of low range channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank(s) may be released to the environment for up to 14 days provided that prior to initiating the release:

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

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

Rev. OL-14 12/04 to ULNRC-05621 CALLAWAY - SP Page 48 of 62 TABLE 16.11-5 (Sheet 3)

Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 39 - Deleted.

ACTION 40 - With the number of low range channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided 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 radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 41 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, restore the affected channel to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If the inoperable channel is not restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or with no channels OPERABLE, immediately suspend the release of radioactive effluents via this pathway (this Action must be completed whenever this default condition is entered).

ACTION 42 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, and if the containment equipment hatch is open, then immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. If the containment equipment hatch is not open, then suspend the release of radioactive effluents via this pathway or immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies within containment.

ACTION 43 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the affected pathway may continue for up to 30 days provided samples are continuously collected with auxiliary sampling equipment as required in Table 16.11-4.

ACTION 44 - Deleted.

ACTION 45 - Flow rate for this system shall be based on fan status and operating curves or actual measurements.

ACTION 46 - For midrange and high range channels only - with the number of OPERABLE channels less than required by the Minimum Channels OPERABLE requirement, take the action specified in Section 16.3.3.4, ACTION C.

ACTION 47 - With the number of channels OPERABLE less than required by the Minumum Channels OPERABLE requirement, immediately suspend the release of radioactivite effluents via this pathway.

Rev. OL-14 12/04

CALLAWAY - SP Attachment 3 TABLE 16.11-6 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS to ULNRC-05621 MODES FOR WHICH Page 49 of 62 CHANNEL SOURCE CHANNEL CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

1. Unit Vent System

a. Noble Gas Activity Monitor - D M R(3) Q(2) At all times Providing Alarm (GT-RE-21)

b. Iodine Sampler W N.A. N.A. N.A. At all times

c. Particulate Sampler W N.A. N.A. N.A. At all times

d. Unit Vent Flow Rate N.A. N.A. R(4) Q At all times

e. Particulate and Radioiodine D N.A. R Q At all times Sampler Flow Rate Monitor

2. Containment Purge System

a. Noble Gas Activity Monitor - N.A. P N.A. N.A. MODES 1,2,3,4 and during Providing Alarm and Automatic CORE ALTERATIONS or Termination of Release (GT-RE- movement of irradiated fuel 22, GT-RE-33) within the containment

b. Iodine Sampler W N.A. N.A. N.A. MODES 1,2,3,4 and during CORE ALTERATIONS or movement of irradiated fuel within the containment

c. Particulate Sampler W N.A. N.A. N.A. MODES 1,2,3,4 and during CORE ALTERATIONS or movement of irradiated fuel within the containment

d. Containment Purge Ventilation N.A. N.A. R(4) N.A. MODES 1,2,3,4 and during Flow Rate CORE ALTERATIONS or movement of irradiated fuel within the containment Rev. OL-13 5/03

CALLAWAY - SP Attachment 3 TABLE 16.11-6 (Sheet 2) to ULNRC-05621 MODES FOR WHICH CHANNEL SOURCE CHANNEL CHANNEL OPERATIONAL SURVEILLANCE Page 50 of 62 INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

e. Particulate and Radioiodine D N.A. R N.A. MODES 1,2,3,4 and during Sampler Flow Rate Monitor CORE ALTERATIONS or movement of irradiated fuel within the containment

3. Radwaste Building Vent System

a. Noble Gas Activity Monitor - D,P M,P R(3) Q(1) At all times Providing Alarm and Automatic Termination of Release (GH-RE-10)

b. Iodine Sampler W N.A. N.A. N.A. At all times

c. Particulate Sampler W N.A. N.A. N.A. At all times

d. Radwaste Building Vent Flow N.A. N.A. R(4) N.A. At all times Rate

e. Particulate and Radioiodine D N.A. R N.A. At all times Sampler Flow Rate Monitor

4. Laundry Decontamination Facility Dryer Exhaust

a. Particulate Monitor NA D A Q(5) When the dryers are operating

b. Particulate Monitor Flow Rate D NA A NA When the dryers are operating Meter

c. Dryer Exhaust Ventilation Flow NA NA R(4) NA When the dryers are operating Rate Rev. OL-13 5/03

CALLAWAY - SP Attachment 3 TABLE 16.11-6 (Sheet 3) to ULNRC-05621 Page 51 of 62

1. The CHANNEL OPERATIONAL TEST shall also demonstrate that 3. The initial CHANNEL CALIBRATION shall be performed using one or more of the reference (gas automatic isolation of this pathway and control room alarm or liquid and solid) standards certified by the National Institute of Standards & Technology (NIST) annunciation occur as appropriate if any of the following conditions or using standards that have been obtained from suppliers that participate in measurement exists: assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy, measurement range, and establish monitor response to a solid

a. Instrument indicates measured levels above the Alarm/Trip calibration source. For subsequent CHANNEL CALIBRATION, NIST traceable standard (gas, Setpoint (isolation and alarm), or liquid, or solid) may be used; or a gas, liquid, or solid source that has been calibrated by relating it to equipment that was previously (within 30 days) calibrated by the same geometry and type of

b. Circuit failure (alarm only), or source standard traceable to NIST.

c. Instrument indicates a downscale failure (alarm only), or 4. If flow rate is determined by exhaust fan status and fan performance curves, the following surveillance operations shall be performed at least once per 18 months:

d. Instrument controls not set in operate mode (alarm only).

a. The specific vent flows by direct measurement, or

2. The CHANNEL OPERATIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following b. The differential pressure across the exhaust fan and vent flow established by the fan's conditions exists: "flow-'P" curve, or

a. Instrument indicates measured levels above the Alarm Setpoint, or c. The fan motor horsepower measured and vent flow established by the fan's "flow-horsepower" curve.

b. Circuit failure, or

5. The CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this

c. Instrument indicates a downscale failure, or pathway and the shutdown of the dryers occur as appropriate if any of the following conditions exists:

d. Instrument controls not set in operate mode.

a. Instrument indicates measured levels above the Alarm/Trip Setpoint, or

b. Monitor failure.

Rev. OL-13 5/03

CALLAWAY - SP Attachment 3 TABLE 16.11-7 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 52 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS (2) Forty routine monitoring stations Quarterly Gamma dose for each sample.

1. Direct Radiation either with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, placed as follows:

An inner ring of sixteen stations, one in each meteorological sector in the general area of the SITE BOUNDARY; An outer ring of stations, one in each meteorological sector in the 6- to 8-km (3 to 5 mile) range from the site; and Eight stations to be placed in special interest areas such as population centers, nearby residences, schools, and in one or two areas to serve as control stations.

2. Airborne Radioiodine and Particulates Samples from five locations; Three samples from close to the SITE Continuous sampler operation with Radioiodine Canister: I-131 analysis BOUNDARY locations, in different sample collection weekly, or more for each sample.

sectors, with high calculated annual frequently if required by dust loading.

average ground level D/Qs. Gamma isotopic analysis(5) for each sample.

One sample from the vicinity of a community located near the plant with a high calculated annual average ground level D/Q.

One sample from a location in the vicinity of Fulton, MO.

3. Waterborne

a. Surface (6) (river) One sample upstream Composite sample over 1-month Gamma Isotopic(5) and tritium One sample downstream period (7). analysis for each sample.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 2) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 53 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

b. Surface (onsite ponds) Water sample from on site ponds Semiannually Gamma isotopic(5) and tritium forming a ring around the plant, analyses for each sample. If suitable for monitoring for plant storm contaminated with gamma emitting water runoff and washout from plant nuclides of plant origin, analyze for gaseous effluents, placed as follows:

HTD nuclides(11).

Each settling pond receiving plant storm water runoff.

One of the in-service sludge lagoons.

Two additional on site ponds most likely to be affected by washout of radioactivity released in gaseous effluents.

c. Groundwater (non-drinking water) Groundwater samples from non- Quarterly Gamma isotopic(5) and tritium drinking water shallow and deep(12) analyses for each sample. If monitoring wells located as follows: contaminated with gamma emitting nuclides of plant origin, analyze for Samples from one deep well located HTD nuclides(11).

upgradient of the plant power block and one deep well located downgradient of the sludge lagoons.

Samples from seven shallow wells or groundwater sumps in locations suitable to monitor for subsurface leakage from power block structures and components.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 3) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 54 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

c. Groundwater (non-drinking water) Samples from three shallow wells in (continued) locations suitable to monitor for migrations of contaminated groundwater from the power block area to areas outside the Owner Controlled Area fence (one well upgradient of the plant power block and two wells in areas likely to be affected.)

Samples from one shallow well located immediately downgradient of the sludge ponds.

Samples from five shallow wells located along the discharge pipeline corridor in the alluvial plain.

Samples from three shallow wells near the property boundary located to monitor for migration of contaminated groundwater from the discharge pipeline to the nearest potable water well.

Samples from one deep well near the property boundary located to monitor for migration of contaminated groundwater from the discharge pipeline to the nearest potable water well.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 4) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 55 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

d. Drinking (river water) One sample of each of one to three of Composite sample over 2-week I-131 analysis on each composite the nearest water supplies within 10 period(7) when I-131 analysis is when the dose calculated for the miles downstream that could be performed, monthly composite consumption of the water is greater affected by its discharge. otherwise. than 1 mrem per year(9). Composite for gross beta and gamma isotopic analyses(5) monthly. Composite for tritium analysis quarterly.

One sample from a control location.

As there are no drinking water intakes within 10 miles downstream of the discharge point, the drinking water pathway is currently not included as part of the Callaway Plant Radiological Environmental Monitoring Program. Should the annual Land Use Census identify water intakes within 10 river miles downstream of the discharge point, the program will be revised to include this pathway.

e. Drinking (potable well water) Samples of potable well water Quarterly Gamma isotopic(5) and tritium appropriate for monitoring for analyses for each sample. If radioactivity in drinking water supplies contaminated with nuclides of plant in areas most likely to be affected by a origin, analyze for HTD nuclides(11).

spill or leak.

Two samples of potable well water from the community of Portland, MO.

One sample of Callaway Plant potable water.

One sample of potable well water from each resident bordering plant property along Mud Creek and Logan Creek.

f. Sediment from river shoreline One sample from downstream area Semiannually Gamma isotopic analysis(5) for each with existing or potential recreational sample value One sample from upstream control location.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 5) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 56 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

g. Shoreline sediment from sludge Shoreline sediment from each on site Annually Gamma isotopic(5) analysis for each ponds sludge pond most likely to be affected. sample.

One sample from each in-service sludge pond.

One sample from each wetlands pond.

4. Ingestion

a. Milk Samples from milking animals in three Semimonthly when animals are on Gamma isotopic(5) and I-131 analyses different meteorological sectors within pasture, monthly at other times for each sample 5 km (3 mile) distance having the highest dose potential. If there are none, then one sample from milking animals in each of three different meteorological sectors between 5 to 8 km (3 to 5 mile) distance where doses are calculated to be greater than 1 mrem per yr.(9)

One sample from milking animals at a control location, 15 to 30 km (10 to 20 mile) distance and in the least prevalent wind direction.

Due to the lack of milking animals which satisfy these requirements, the milk pathway is currently not included as part of the Callaway Plant Radiological Environmental Monitoring Program. Should the Annual Land Use Census identify the existence of milking animals in locations which satisfy these requirements, then the program will be revised to include this pathway.

b. Fish One sample of each commercially and Sample in season, or semiannually if Gamma isotopic analysis(5) on edible recreationally important species in they are not seasonal portions for each sample vicinity of plant discharge area.

One sample of same species in areas not influenced by plant discharge.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 6) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 57 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

c. Food Products One sample of each principal class of At time of harvest(10) Gamma isotopic analysis(5) on edible food products from any area that is portion for each sample irrigated by water in which liquid plant wastes have been discharged.

As there are no areas irrigated by water in which liquid plant wastes have been discharged within 50 miles downstream of the discharge point, this sample type is not currently included as part of the Callaway Plant Radiological Environmental Monitoring Program. Should the annual Land Use Census identify irrigation water intakes within 10 river miles downstream of the discharge point, the program will be revised to include this sample type.

Samples of three different kinds of Monthly when available Gamma isotopic (5) and I-131 broad leaf vegetation if available analyses grown nearest each of two different offsite locations of highest predicted annual average ground level D/Q if milk sampling is not performed One sample of each of the similar Monthly when available Gamma isotopic (5) and I-131 broad leaf vegetation grown 15 to 30 analyses km (10 to 20 mile) distant in the least prevalent wind direction if milk sampling is not performed

5. Soil Surface soil samples suitable for Annually Gamma isotopic(5) analysis for each monitoring for ground deposition if sample.

radioactivity in gaseous effluents as follows:

Four ecology plots located in four quadrants surrounding the plant.

One control location from an area not likely to be influenced by plant gaseous effluents.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 7) to ULNRC-05621 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLE SAMPLING AND TYPE AND FREQUENCY Page 58 of 62 AND/OR SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

6. Farm crops(13) Farm crops from areas most likely to At time of harvest(10) Gamma isotopic(5) and tritium be affected by a break or leak in the analyses for each sample discharge pipeline, located as follows:

Three samples of each type of farm crop along the discharge pipeline corridor between manhole 8 and Katy Trail.

Three samples of each type of farm crop along the discharge pipeline corridor between manhole 5 and manhole 3B.

Three samples of each type of farm crop along the discharge pipeline easement between Hwy 94 and the barge loading dock access road.

One sample of each type of crop sampled above, from a control location unlikely to be influenced by plant operations.

TABLE NOTATIONS

1. Specific parameters of distance and direction sector from the centerline of one unit, and additional description where pertinent, shall be provided for each and every sample location in Table 16.11-7 in a table and figure(s) in the appropriate plant procedures. 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 unobtainable 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 Radiological Environmental Operating Report pursuant to Technical Specification 5.6.2.

It is recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time. In these instances suitable specific alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the Radiological Environmental Monitoring Program. Submit in the next Annual Radiological Environmental Operating Report documentation for a change including the revised figure(s) and table reflecting the new location(s) with supporting information identifying the cause of the unavailability of samples for that pathway and justifying the selection of the new location(s) for obtaining samples.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-7 (Sheet 8) to ULNRC-05621 The selection of sample locations should consider accessibility of sample site, availability of power, wind direction frequency, sector population, equipment security, and the presence of potentially adverse environmental conditions (such as unusually dusty conditions, etc.).

Page 59 of 62

2. One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.

For the purposes of this table, a thermoluminescent dosimeter (TLD) and/or an optically stimulated luminescent dosimeter (OSLD), are considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading.

3. Deleted.

4. Deleted.

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

6. The "upstream sample" shall be taken at a distance beyond significant influence of the discharge. The "downstream" sample shall be taken in an area near the downstream edge of the mixing zone.

7. In this program, composite sample aliquots shall be collected at time intervals that are very short (e.g., hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample.

8. Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

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

10. If harvest occurs more than once a year, sampling shall be performed during each discrete harvest. If harvest occurs continuously, sampling shall be monthly. Attention shall be paid to including samples of tuberous and root food products.

11. In this program, HTD nuclides are defined as 89Sr, 90Sr, 55Fe, 63Ni, 237Np, 238Pu, 241Am, 242Cm, and 243/244Cm.

12. In this program, a shallow well is defined as a well which extracts groundwater from the vadose zone. A deep well is defined as a well which extracts groundwater from the saturated zone.

13. Edible and non-edible farm crops from areas that could be affected by a break or leak in the discharge pipeline (including the retired discharge pipeline.)

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-8 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES to ULNRC-05621 REPORTING LEVELS Page 60 of 62 FISH WATER AIRBORNE PARTICULATE (pCi/kg, MILK FOOD PRODUCTS ANALYSIS (pCi/")a OR GASES (pCi/m3) wet)b (pCi/")a pCi/kg, wet)b 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 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140** 200 300 (a) Multiply the values in this table by 1E-9 to convert to units of PCi/ml.

(b) Multiply the values in this table by 1E-9 to convert to units of PCi/g.

For drinking water samples. This is 40 CFR Part 141 value. For surface water samples, a value of 30,000 pCi/" may be used.

- Total activity, parent plus daughter activity.

Rev. OL-14 12/04

CALLAWAY - SP Attachment 3 TABLE 16.11-9 DETECTION CAPABILITITES FOR ENVIRONMENTAL SAMPLE ANALYSIS to ULNRC-05621 LOWER LIMIT OF DETECTION (LLD) (1), (2), (3)

Page 61 of 62 FOOD AIRBORNE FISH PRODUCTS SEDIMENT SURFACE DRINKING PARTICULATE (pCi/kg, MILK (pCi/kg, (pCi/kg, ANALYSIS WATER (pCi/")a WATER (pCi/")a OR GASES (pCi/m3) wet)b (pCi/")a wet)b dry)b Gross Beta 4 4 0.01 H-3 3000 2000 Mn-54 15 15 130 Fe-59 30 30 260 Co-58,60 15 15 130 Zn-65 30 30 260 Zr-Nb-95* 15 15 I-131 ** 1 0.07 1 60 Cs-134 15 15 0.05 130 15 60 150 Cs-137 18 18 0.06 150 18 80 180 Ba-La-140* 15 15 15 (a) Multiply the values in this table by 1E-9 to convert to units of PCi/ml.

(b) Multiply the values in this table by 1E-9 to convert to units of PCi/g.

Total activity, parent plus daughter activity.

- For surface water samples, the LLD of gamma isotopic analysis may be used.

Rev. OL-16f 7/08

CALLAWAY - SP Attachment 3 TABLE 16.11-9 (Sheet 2) to ULNRC-05621 TABLE NOTATIONS

1. This list does not mean that only these nuclides are to be considered. Other peaks that are identifiable, together with those of the listed nuclides, shall also be analyzed and reported Page 62 of 62 in the Annual Radiological Environmental Operating Report.

2. Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be in accordance with the recommendations of Regulatory Guide 4.13, Revision 1, July 1977.

3. The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

4.66S b LLD = -------------------------------------------------------------------------------------

E x V x 2.22E6 x Y x exp - O't Where:

LLD = the "a priori" lower limit of detection (microCuries per unit mass or volume),

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

E = the counting efficiency (counts per disintegration),

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

2.22E6 = the number of disintegrations per minute per microCurie, Y = the fractional radiochemical yield, when applicable, O = the radioactive decay constant for the particular radionuclide (sec-1), and

't = the elapsed time between the end of the sample collection period, and the time of counting (sec).

Typical values of E, V, Y, and 't should be used in the calculation.

It should be recognized that the LLD is defined as a "a priori" (before the fact) limit representing the capability of a measurement system and not as an "a posteriori" (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LLD's will be achieved under routine conditions.

Rev. OL-16f 7/08 to ULNRC-05621 Attachment 4 Callaway FSAR-Standard Plant Chapter 16.11 Summary of Change Notice- FSARCN 08-019 to ULNRC-05621 Page 1 of 6 FSARCN 08-019 Description of Changes and Justifications

Attachment 4 FSARCN 08-019 to ULNRC-05621 Page 2 of 6 Description of and Justification for Changes Section Description of Change Justification for Change Table 16.11-7, Item Changed analysis frequency from The sample collection frequency is specified in column 3 as "quarterly".

1, Direct Radiation "quarterly" to "each sample" This change clarifies that the analysis is to be performed on each sample, regardless of the collection frequency. This is a clarification only; it is not a change in the requirements. There is no impact on safety related SSC's.

Table 16.11-7, Item Changed analysis frequency from The sample collection frequency is specified in column 3 as "weekly or 2, Airborne "weekly" to "each sample" more frequently due to dust loading". This change clarifies that the Radioiodine and analysis is to be performed on each sample, regardless of when it is Particulates collected. It is important that samples be analyzed as quickly as possible due to the half- life of 1-131 and the effect of the half- life on meeting the LLD requirements. Samples collected from a short cycle should not be held for the weekly shipment to the lab, but should be shipped for analysis at that time. This change clarifies that. There is no impact on safety related SSC's.

Table 16.11-7, Item Removed requirement to perform Gross beta analysis is a holdover from the 1970's when gamma 2, Airborne gross beta for each sample and a spectroscopy was not widely available and most samples were analyzed Radioiodine and gamma spec analysis on a with gross counting instruments. The proposed change eliminates the Particulates quarterly composite. gross beta, and requires a gamma spec to be performed on each sample. This change will provide more meaningful data that can be compared directly to plant effluents. There is no impact on safety related SSC's.

Table 16.11-7, Item Added the word "river" Adding the word "river" clarifies that this surface water sample is from the 3a, Waterborne- Missouri River and not some other type of surface water sample. This surface becomes an important distinction due to the addition of other types of surface water samples to this table. There is no impact on safety related SSC's.

Attachment 4 FSARCN 08-019 to ULNRC-05621 Page 3 of 6 Section Description of Change Justification for Change Table 16.11-7, Item Changed analysis frequency from The sample collection frequency is specified in column 3 as "monthly".

3a, Waterborne- "monthly" to "each sample" This change clarifies that the analysis is to be performed on each surface sample, regardless of the collection frequency. This is a clarification only; it is not a change in the requirements. There is no impact on safety related SSC's.

Table 16.11-7, Item Removed this item and replaced The current language requires ground water sampling only when the 3b, Waterborne- it with Insert 3b. ground water source is used for drinking or irrigation purposes and when ground the hydraulic gradient or recharge properties are suitable for contamination. Since there are no sources where the hydraulic gradient or recharge properties are suitable for contamination, this sample type was not included in the REMP. Inserts 3b, 3c, 3e, and 3g will add multiple sources of ground water samples, regardless of the use of the water or the hydrogeological properties of the site. Therefore, this item is being removed from the ODCM. There is no impact on safety related SSC's.

Insert 3b New requirement Insert 3b adds sampling and analysis requirements for surface water-onsite ponds, pursuant to recent changes in the ANI Criteria as described by CAR 200803299. There is no impact on safety related SSC's.

Insert 3c New requirement Insert 3b adds sampling and analysis requirements for ground water (non- drinking water) pursuant to the NEI Ground water Protection Initiative as described in NEI 07-07 and CAR 200800353. There is no impact on safety related SSC's.

Attachment 4 FSARCN 08-019 to ULNRC-05621 Page 4 of 6 Section Description of Change Justification for Change Table 16.11-7, Item 1. Changed the sequence 1. Sequence numbering was changed to accommodate the addition of 3c, Drinking numbering from 3c to 3d. Insert 3c.

2. Added "river water". 2. Added "river water" to clarify that this requirement is for drinking water where the source is Missouri River. This is a clarification necessary due to the addition of a large number of new sample types to the aDCM.

This is not a change in this requirement.

There is no impact on safety related SSC's.

Insert 3e New requirement Insert 3e adds a number of drinking water (potable well water) samples to the aDCM pursuant to the NEI Ground water Protection Initiative as described in NEI 07-07 and CAR 200800353 and the recent changes in the ANI Criteria as described by CAR 200803299. There is no impact on safety related SSC's.

Table 16.11-7, Item 1. Added the word "river" 1. The word "river" was added to clarify that the shoreline sediment is 3d, Sediment from 2. Changed the analysis from the river. This is a necessary clarification due to the addition of shoreline frequency from "semiannually" to pond samples via Insert 3b.

"each sample" 2. The sample collection frequency is specified in column 3 as

3. Added a sample from an "semiannually". This change clarifies that the analysis is to be performed upstream control location. on each sample, regardless of the collection frequency. This is a clarification only; it is not a change in the requirements.

3. An upstream control location was added. This addition ensures that a control station is established and sampled. In practice, procedure HTP-ZZ-071 01, Appendix A established a control station which is sampled each time the shoreline sediment sample is taken. This change codifies the current practice as an aDCM requirement.

There is no impact on safety related SSC's.

Attachment 4 FSARCN 08-019 to ULNRC-05621 Page 5 of 6 Section Description of Change Justification for Change Insert 3g New requirement Insert 3g adds shoreline sediment samples from sludge ponds. These samples have been included in the REMP for over 25 years. These samples are being added to the ODCM pursuant to Appendix I to 10CFR50. There is no impact on safety related SSC's.

Table 16.11-7, Item Changed analysis frequency from The sample collection frequency is specified in column 3 as 4a, Milk "semimonthly when animals are "semimonthly when animals are on pasture; monthly at other times".

on pasture; monthly at other This change clarifies that the analysis is to be performed on each times" to "each sample" sample, , regardless of the collection frequency. This is a clarification only; it is not a change in the requirements. There is no impact on safety related SSC's.

Table 16.11-7, Item Added analysis frequency to The sample collection frequency is specified in column 3 as "sample in 4b, Fish specify an analysis of "each season, or semiannually, if they are not in season". This change clarifies sample" that the analysis is to be performed on each sample, regardless of the collection frequency. This is a clarification only; it is not a change in the requirements. There is no impact on safety related SSG's.

Table 16.11-7, Item Added analysis frequency to The sample collection frequency is specified in column 3 as "at time of 4c, Food products specify an analysis of "each harvest". This change clarifies that the analysis is to be performed on sample" each sample, regardless of the collection frequency. This is a clarification only; it is not a change in the requirements. There is no impact on safety related SSC's.

Insert 5 New requirement Insert 5 adds soil samples. These samples have been included in the REMP for over 25 years. These samples are being added to the ODCM pursuant to Appendix I to 10CFR50. There is no impact on safety related SSC's. - - -

Attachment 4 FSARCN 08-019 to ULNRC-05621 Page 6 of 6 Section Description of Change Justification for Change I Insert 6 New requirement Insert 6 adds samples from farm crops from areas that could be affected I by a break or leak in the discharge pipeline (including the retired discharge pipeline). Minor contamination is known to exist in areas along the discharge pipeline corridor. Farming operations are known to exist in the pipeline corridor; some on UE property, some on private I

property in the UE easement. These samples are being added to the ODCM pursuant to Appendix I to 10CFR50. There is no impact on safety related SSC's.

Table 16.11-7, Note Added optically stimulated OSLDs are very similar to the TLDs but have superior fade ,

2 luminescent dosimeter (OSLD) to characteristics. The addition of OSLD to this footnote would allow the I the footnote. use of OSLDs in the REMP. There is no impact on safety related SSC's.

Table 16.11-7, Note Deleted This is a conforming change based on the proposed change to Table 4 16.11-7, Item 2, Airborne Radioiodine and Particulates. This footnote is not needed if gross beta is eliminated. There is no impact on safety related SSC's.

Insert Note 11 New requirement This footnote provides clarification to the term HTD used in some of the proposed additions to the analysis requirements provided by Inserts 3b, 3c, and 3e. This list is consistent with the ANI Criteria as described in CAR 200803299. There is no impact on safety related SSC's.

Insert Note 12 New requirement This note defines the terms "shallow well" and "deep well" as used in the proposed additions to the sampling requirements provided by Insert 3c.

There is no impact on safety related SSC's.

Insert Note 13 New requirement This note describes the farm crop sample type described in the proposed additions to the sampling requirements provided by Insert 6. There is no impact on safety related SSC's.

Table 16.11-9 Changed the LLD requirement for The LLD requirement for 1-131 in surface water was inadvertently 1-131 in surface water. shanged to 1000 pCilL in APA-ZZ-01 003, rev. 3. This change restores !

the original LLD. See CAR 200803325. There is no impact on safety related SSC's.

- -

ULNRC-05621, 2008 Annual Radioactive Effluent Release Report

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1.0 INTRODUCTION

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5.1 DESCRIPTION

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ULNRC-05621, 2008 Annual Radioactive Effluent Release Report

Text

1.0 INTRODUCTION

SUMMARY

SUMMARY

1.0 INTRODUCTION

SUMMARY

SUMMARY

SUMMARY

SUMMARY

5.1 DESCRIPTION

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