View source for CP-201900270, 2018 Annual Radioactive Effluent Release Report

{{Adams
| number = ML19122A387
| issue date = 04/25/2019
| title = 2018 Annual Radioactive Effluent Release Report
| author name = Hicks J
| author affiliation = Vistra Operations Company, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000445, 05000446
| license number = 
| contact person = 
| case reference number = CP-201900270, TXX-19051
| document type = Environmental Monitoring Report, Letter type:CP
| page count = 59
}}

=Text=
{{#Wiki_filter:ENERGY
                                            ~~rxu
                                            *
* energy I     m Luminant Jack C. Hicks Manager, Regulatory Affairs Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897 .6725 CP-201900270 TXX-19051 U.S. Nuclear Regulatory Commission                                                      Ref     10 CFR 50.36a ATTN: Document Control Desk                                                                     TS 5.6.3 Washington, DC 20555-0001                                                                       ODCM April 25, 2019

==SUBJECT:==
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 2018 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

==Dear Sir or Madam:==

Vistra Operations Company LLC ("Vistra OpCo") hereby submits the Comanche Peak Nuclear Power Plant (CPNPP) 2018 Annual Radioactive Effluent Release Report. The enclosed report is provided pursuant to 10 CFR 50.36a and CPNPP Technical Specification 5.6.3. The report covers the period from January 1, 2018 to December 31, 2018.
This communication contains no new commitments regarding CPNPP Units 1 and 2.
Should you have any questions, please contact Jim Barnette at (254) 897-5866 or Mark Clark at (254) 897-6835.
Sincerely, 6555 SIERRA DRIVE       IRVING, TEXAS 75039      0214-812-4600       VISTRAENERGY.COM

TXX-19051 Page 2 of 2

==Enclosure:==

1   CPNPP 2018 Annual Radioactive Effluent Release Report c-          Scott A. Morris, Region IV Natreon Jordan, NRR Resident Inspectors, Comanche Peak

2018ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT January 1, 2018 - December 31, 2018
____  .,.,-=-J~f_'-=-{J._,._._j"'--~=--:_ _ _ __
Preparer: -----'D=-:o==n=ald=--=R==e-==bs=to-=-=ck"---_f)                                          Date:
ul   1 I1r1 7 /iv,.
Reviewer: _C=i=err=a-==R=ob'-=ert~s_ _       ~_..*~=-'<::___;_~~"""""'--=-------                   Date: '-f /io II q Approval: -'M=ark=-C==l=ark=-----~--=----=-----~-~----'-"' --=-=------                             Date: 'I   /tf>/19 Chemistry Manager

TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS

==1.0 INTRODUCTION==

1.1  Executive Summary 1.2  Historical Trend Graphs 2.0 SUPPLEMENTAL INFORMATION 2.1  Regulatory Limits 2.2  Effluent Concentration Limits 2.3  Measurements and Approximations of Total Radioactivity 2.4  Batch Releases 2.5  Abnormal (Unplanned) Releases 3.0 GASEOUS EFFLUENTS 4.0 LIQUID EFFLUENTS 5.0 SOLID WASTES 6.0 RADIOLOGICAL IMPACT ON MAN 6.1  Dose Due to Liquid Effluents 6.2  Dose Due to Gaseous Effluents 6.3  Dose Due to Radioiodines, Tritium, and Particulates 6.4  40CFR190 Dose Evaluation 6.5  Dose to a Member of the Public from Activities inside the Site Boundary 7.0 METEROLOGICAL DATA 7.1  Meteorological Monitoring Program 8.0 RELATED INFORMATION 8.1  Operability of Liquid and Gaseous Monitoring Instrumentation 8.2  Changes to the Offsite Dose Calculation Manual Page 2 of57

TABLE OF CONTENTS 8.3  New Locations for Dose Calculations or Environmental Monitoring 8.4  Liquid Holdup and Gas Storage Tanks 8.5  Noncompliance with Radiological Effluent Control Requirements 8.6  Resin Releases to the Low Volume Waste (LVW) Pond 8.7  Changes to the Liquid, Gaseous, and Solid Waste Treatment Systems 8.8  Groundwater Tritium Monitoring Program 8.9  Independent Spent Fuel Storage Installation (ISFSI) 9.0 EFFLUENT TABLES 9.1  Liquid and Gaseous Batch Release Summary 9.2  Abnormal Liquid and Gaseous Batch Release Summary 9.3  Gaseous Effluents - Summation of All Releases 9.4  Gaseous Effluents - Ground Level Releases 9.5  Liquid Effluents - Summation of All Releases 9.6  Liquid Effluents 9.7  Dose Due to Liquid Releases 9.8  Air Dose Due to Gaseous Releases 9.9  Dose Due to Radioiodines, Particulates, Tritium, and Carbon-14 in Gaseous Releases 9.10 Solid Radwaste and Irradiated Fuel Shipments Page 3 of57

10.0 ATTACHMENTS 10.1 Meteorological Joint Frequency Distribution Tables 10.2 Atmospheric Dispersion (X/Q) and Deposition (D/Q) Calculation Methodology Discussion 10.3 Carbon-14 Supplemental Information 10.4 Putting Radiation Dose in Context 10.5 Errata from Previous Annual Radioactive Effluent Release Reports Page 4 of57

ACRONYMS AND ABBREVIATIONS AREOR  Annual Radiological Environmental Operating Report CFR    Code of Federal Regulations
* CPNPP  Comanche Peak Nuclear Power Plant ECL    Effluent Concentration Limit HIC    High Integrity Containers ISFSI  Independent Spent Fuel Storage Installation LDCR   Licensing Document Change Request LHMT   Laundry Holdup and Monitor Tanks LVW    Low Volume Waste ODCM   Offsite Dose Calculation Manual oos    Out of Service PET    Primary Effluent Tanks pCi    Pico-Curie REC    Radiological Effluent Control SORC   Station Operations Review Committee
  &#xb5;Ci    Micro-Curie WMT    Waste Monitor Tanks WWHT   Waste Water Holdup Tanks Page 5 of57

1.0 Introduction This Radioactive Effluent Release Report, for Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and Unit 2, is submitted as required by Technical Specification 5.6.3 and Offsite Dose Calculation Manual (ODCM) Administrative Control 6.9.1.4 for the period January 1, 2018 through December 31, 2018. Data in this report were calculated in accordance with the CPNPP ODCM using the Canberra OpenEMS software.
1.1 Executive Summary The radioactive effluent monitoring program for 2018 was conducted as described in the following report. Results of the monitoring program indicate continued effort to maintain the release of radioactive effluents to the environment as low as reasonably achievable (ALARA).
In June 2009, the NRC provided revised guidance in Regulatory Guide 1.21, Measuring, Evaluating and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste, Revision 2, establishing an updated approach for identifying principal radionuclides. Because the overall quantity of radioactive releases has steadily decreased due to improvements in power plant operations, Carbon-14 (C-14) now qualifies as a "principal radionuclide" (anything greater than one percent of overall radioactivity in effluents) under federal regulations at many plants. In other words, C-14 has not increased and C-14 is not a new nuclear plant emission. Rather, improvements in the mitigation of other isotopes have made C-14 more prominent. Attachment 10.3 provides more detail about C-14.
Page 6 of57

1.1 Executive Summary (continued)
Gaseous Effluents:
Two-year summary of all the radioactive gaseous releases to the environment:
Gaseous Waste                                        2017              2018         Comments Tritium (Ci)                                          34.4              32.6             1 C-14 (Ci)                                             19.3            . 25.3             2 Total Fission and Activation Products (Ci)            0.42              0.42 Total Particulate (Ci)                                  0                 0              3 Gross Alpha (Ci)                                        0                 0              3 Iodine (Ci)                                             0                 0              3 Calculated Gamma Air Dose (mRad)                   3.60E-04          3.69E-04 Calculated Beta Air Dose (mRad)                    1.35E-04          l.38E-04 Total Body Dose (mRem)                                0.08              0.09 Comments:
: 1. The major contributor to gaseous tritium activity is evaporation from the spent fuel pools.
Factors contributing to the tritium activity in the pools are related to the type of fuel used (i.e., 18-month fuel) the core life, power output, and number of core cycles.
: 2. C-14 activity released from the site is estimated using reactor power in accordance with EPRI document "Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents". 2017 C-14 activity released was lower due to unit refueling and maintenance outages during the year which resulted in less total C-14 produced for the site.
: 3. No detectable particulate, gross alpha, or iodine activity was released during 2018.
Overall the gaseous radioactivity releases from CPNPP are well controlled and maintained ALARA. CPNPP is well below all applicable limits for gaseous releases. Neither unit had fuel defects during the year of this report.
Page 7 of57

1.1 Executive Summary (continued)
Liquid Effluents:
Two-year summary of all the radioactive liquid releases to the environment:
Liquid Waste                                      2017                 2018          Comments Total Activity Excluding Tritium (Ci)           l.06E-03             4.25E-04            1 Tritium Activity (Ci)                             2510                 2120              2 Total Body Dose (mRem)                             0.13                 0.14 Total Volume Released (Gallons)                1,231,176              694,848            3 Comments:
: 1. Less total liquid activity was released during 2018 since there was only 1 refueling outage and no maintenance outages when compared with 2017.
: 2. Tritium released values can vary significantly from year to year based on a*couple of factors.
First, reactor coolant tritium production changes based on fuel bumup characteristics. Tritium activity increases following reactor startup, then plateaus mid-cycle, and begins to decline towards the end of cycle. Second, the tritium released value is dependent upon how many outages there were during a calendar year. More liquid waste is processed and released during unit outages. 2017 was a multi-outage year which resulted in more tritium activity being discharged.
: 3. Higher total liquid effluent volume released in 2017 was due to several refueling and maintenance outages that occurred during the calendar year. More liquid waste is processed and released during unit outages.
Meteorological Data During 2018, the CPNPP meteorological system achieved a greater than 98% mean recoverable data rate for the joint frequency parameters required by Regulatory Guide 1.23 for wind speed, wind direction and delta temperature. See Section 7 .1 for the actual recovery percentages.
Monitors OOS > 30 Days During 2018, there were no Technical Specification/ODCM effluent radiation monitors out of service (OOS) for >30 days.
ODCM Changes No changes were made to the ODCM during 2018.
Page 8 of57

1.1 Executive Summary (continued)
Solid Waste Two-year summary of the solid waste production:
Total Waste                2017                      2018                % Error Shipped (m3)                360                       163                  25%
Shipped (Ci)                22.6                     1030                  25%
Buried (m3)                48.5                     28.9                  25%
Buried (Ci)                22.5                     1030                  25%
Comments:
Solid waste shipments and burials have generally trended downward over the past 5 years due to solid waste reduction measures.
2017 was a multi-outage year which led to a higher volume of solid waste shipped and buried. The Curie content buried was lower primarily due to overall lower activity within the buried waste.
During 2018, CPNPP shipped off 5 High Integrity Containers (HICs) containing high activity resin in order to make room for future resin transfers and filter changes. These shipments were necessary to ensure the expected volume of resin transferred from the plant during 2019 could be properly stored on site. These shipments led to higher values for Curies shipped and buried for 2018.
Page 9 of57

Groundwater Tritium Water wells used to monitor CPNPP for tritium leaks into the groundwater all had results that were less than detectable during 2018. An initial sample collected from Well 11 had a slightly positive tritium result during the 2nd quarter of 2018. However, a subsequent verification sample collected from the same well two weeks later indicated less than detectable tritium activity.
See Section 8.8 for details.
Conclusion During 2018, the radioactive effluent monitoring program has been conducted in an appropriate manner to ensure the activity released and associated dose to the public has been maintained as low as reasonably achievable (ALARA).
Page 10 of57

1.2     Historical Trend Graphs Total Gaseous Fission and Activation Activity Released 10.00 9.00 8.00
  ~
7.00 0     6.00 C:
0 0
Ill
::,   5.00 0
Q)
Ill IU C)    4.00
  ]i
  ~     3.00 2.00 1.27 1.00                                                0.55 OA9                           0.43    0.42          0.42 0.00 2012         2013          2014           2015           2016    2017          2018 Year Year                 Total Gaseous Fission and Activation Activi Released Comments All          More gas activity was released during 2012 and 2013 because of a fuel leak in 2011.
Page 11 of57

Total Gaseous Tritium Released 100.00 90.00 80.00 70.00 2.
() 60.00 C
0            51.6 0
(")     50.00
:c 1/1 0      40.00 G) 1/1 n,
C) 30.00 20.00 10.00 0.00 2012           2013          2014           2015          2016          2017           2018 Year Year                               Total Gaseous Tritium Released Comments All          The major contributor to gaseous tritium activity is evaporation from the spent fuel pools. Factors contributing to the tritium activity in the pools is related to the type of fuel used (i.e., 18-month fuel) the core life, power output, and number of core cycles.
Page 12 of57

Total Body Dose due to Gaseous Activity Released 020 0.18 0.16 0.14 E    0.12 0.11 Cl) 0::
,E. 0.10 Cl)
Ill 0
C    0.08 0.06 0.04 0.02 0.00 2012           2013          2014            2015          2016         2017          2018 Year Total Body Dose due to Gaseous Activity Released Comments Year 2012       There was a mid-cycle outage during 2012 that required degassing of the RCS in addition to a planned refueling outage resulting in slightly higher total body dose for 2012.
Page 13 of57

Total Volume Liquid Effluents Released 100,000,000 18,733,509 10,000,000 1,000,000 "iii 100,000
~
Q)      10,000 E
~         1,000 100 10 2012          2013           2014           2015          2016       2017         2018 Year Year                              Total Volume Liquid Effluents Released Comments 2012            Analysis of the 2nd quarter LVW composite indicated a small concentration of tritium.
Consequently, the volume discharged from the L VW had to be accounted for as radioactive liquid waste for that quarter resulting in a much larger than normal total annual liquid waste volume.
2017            Higher total volume of liquid effluents released was due to unit refueling and maintenance outages during the calendar year. More liquid waste is processed and released during unit outages.
Page 14 of57

Total Activity (Excluding Tritium) Released in Liquid Effluents 20.00 0
g
~      15.00
~
10.00 2012          2013            2014            2015           2016           2017 2018 Year Year        Total Activity (Excludin2 Tritium) Released in Liquid Effluents Comments 2012       The increased activity for 2012 is attributed to waste water processing for 1 refueling outage, 1 forced outage, and dry cask storage operations.
Page 15 of57

Total Curies of Tritium Released in Liquid Effluents 0
-: 3000 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - l u
C 0                                                                               2510 u
CW)
,,:i:c 2000 CJ"
:::i 1000 0
2012           2013           2014             2015           2016    2017          2018 Year Year     Total Curies of Tritium Released in Liquid Effluents Comments All      Tritium released values can vary significantly from year to year based on a couple of factors. First, reactor coolant tritium production changes based on fuel bumup characteristics. Tritium activity increases following reactor startup, then plateaus mid-cycle, and begins to decline towards the end of cycle. Second, the tritium released value is dependent upon on how many outages there were during a calendar year. More liquid waste is processed and released during unit outages.
2017     More tritium was released due to multiple outages during the year.
Page 16 of57

Total Body Dose Due to Liquid Effluents Released 0.40 0.35 0.30 0.25 E(I)
~
.!&sect;. 0.20 (I)
UI 0
C 0.15 0.10 0.05 0.00 2012        2013          2014           2015            2016 2017 2018 Year Year      Total Bod Dose Due to Li uid Effluents Released Comments NIA        No comments Page 17 of57

Total Curies of Solid Radwaste Buried 1,030.0 1/)
-~ 600    +------------
::I
(.)
3.0 O+----~~-
2012           2013          2014         2015           2016        2017          2018 Year Year   Total Curies of Solid Radwaste Buried Comments 2013   In 2013 CPNPP shipped and buried significantly more Class B and C waste to the compact disposal facility in Andrews, Texas. This waste has a very high specific activity with respect to Class A waste. In 2012, CPNPP only disposed of Class A waste and consequently the activity was very low with respect to 2013 values. The buried volume in both years are similar since Class Band C wastes are in packages of 120 cubic feet, or about 3 cubic meters, and consequently, the impact on the overall waste volume is minimal.
2014   In 2014 CPNPP continued to ship and bury stored Class B and Class C wastes at the compact disposal facility in Andrews, Texas. In advance of the compliance date for 10 CFR 37, waste containers with the highest radioactivity, particularly those exceeding category two quantities, were chosen to be shipped. In 2013, CPNPP had just began shipments to the new Andrews, Texas disposal facility and the waste containers chosen for shipment represented lower total activity to allow the staff to become familiar with the new procedure processes required by the new facility. Buried volume in both years are similar since these values are normally associated with Class A Dry Active Waste that represents an order of magnitude more volume than Class Band Class C wastes packaged in 120 cubic feet, or about 3 cubic meter, containers.
2017  Lower total activity buried was due to solid waste having lower activity.
2018  During 2018, CPNPP shipped off 5 High Integrity Containers (HICs) containing high activity resin in order to make room for future resin transfers and filter changes. These shipments were necessary to ensure the expected volume ofresin transferred from the plant during 2019 could be properly stored on site. These shipments led to higher values for Curies shipped and buried for 2018.
Page 18 of57

Total Volume of Solid Radwaste Buried 100 90 80 70 60 fQ)
- Q)
:aE 0
50 40
.c
:::s
(.)
30 20 10 0
2012            2013           2014           2015           2016          2017            2018 Year Year        Total Volume of Solid Radwaste Buried Comments 2013        In 2013 CPNPP shipped and buried significantly more Class B and C waste to the compact disposal facility in Andrews, Texas. This waste has a very high specific activity with respect to Class A waste. In 2012, CPNPP only disposed of Class A waste and consequently the activity was very low with respect to 2013 values. The buried volume in both years are similar since Class Band C wastes are in packages of 120 cubic feet, or about 3 cubic meters, and consequently, the impact on the overall waste volume is minimal.
2014        In 2014 CPNPP continued to ship and bury stored Class B and Class C wastes at the compact disposal facility in Andrews, Texas. In advance of the compliance date for 10 CFR 37, waste containers with the highest radioactivity, particularly those exceeding category two quantities, were chosen to be shipped. In 2013, CPNPP had just began shipments to the new Andrews, Texas disposal facility and the waste containers chosen for shipment represented lower total activity to allow the staff to become familiar with the new procedure processes required by the new facility.
Buried volume in both years are similar since these values are normally associated with Class A Dry Active Waste that represents an order of magnitude more volume than Class Band Class C wastes packaged in 120 cubic feet, or about 3 cubic meter, containers.
2016       2016 was a single outage year which resulted in less solid waste shipped and buried when compared to 2015.
2017       2017 was a multi-outage year which led to a higher volume of solid waste shipped and buried.
2018       Shipments of waste during 2018 were based on a one outage year since the last Unit 2 outage carried over into 2019. Additionally, the efficiency methods in place have reduced the shipped/buried volume of waste during the last few vears.
Page 19 of57

2.0   SUPPLEMENTAL INFORMATION 2.1   Regulatory Limits The ODCM Radiological Effluent Control limits applicable to the release of radioactive material in liquid and gaseous effluents are described in the following sections.
2.1.1 Fission and Activation Gases (Noble Gases)
The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the site boundary shall be limited to less than or equal to 500 mRem/yr to the whole 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.
2.1.2 Iodine-131, Iodine-133, Tritium and Radioactive Material in Particulate Form The dose rate due to iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 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, iodine-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, 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.
Page 20 of57

2.1.3 Liquid Effluents The concentration of radioactive material released in liquid effluents to unrestricted areas shall be limited to 10 times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.0E-4 &#xb5;Ci/mL total activity.
The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each unit, to unrestricted areas shall be limited:
: a. During any calendar quarter to less than or equal to 1.5 mRem to the whole body and to 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.
2.1.4 LVW Pond Resin Inventory The quantity of radioactive material contained in resins transferred to the LVW pond shall be limited by the following expression:
(264/V)
* I:j Aj/Cj < 1.0 excluding tritium, dissolved or entrained noble gases and radionuclides with less than an 8-day half-life, where:
Aj        = pond inventory limit for a single radionuclide j (Curies),
Cj       = 10CFR20, Appendix B, Table 2 Column 2, concentration for a single radionuclide j (&#xb5;Ci/mL),
V        = volume ofresins in the pond (gallons), and 264      = conversion factor (&#xb5;Ci/Ci per mL/gal)
This expression limits the total quantity of radioactive materials in resins discharged to the L VW Pond to a value such that the average concentration in the resins, calculated over the total volume of resins in the pond, will not exceed one times the Effluent Concentration Limits specified in 10 CFR 20, Appendix B, Table 2, Column 2.
2.1.5  Total Dose 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 whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mRem.
Page 21 of57

2.2   Effluent Concentration Limits 2.2.1 Gaseous Effluents For gaseous effluents, effluent concentration limits (ECL) values are not directly used in release rate calculations since the applicable limits are expressed in terms of dose rate at the site boundary.
2.2.2 Liquid Effluents The values specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 are used as the ECL for liquid radioactive effluents released to unrestricted areas. A value of2.0E-04 &#xb5;Ci/mL is used as the ECL for dissolved and entrained noble gases in liquid effluents.
2.3   Measurements and Approximations of Total Radioactivity Measurements of total radioactivity in liquid and gaseous radioactive effluents were accomplished in accordance with the sampling and analysis requirements of Tables 4.11-1 and 4.11-2, respectively, of the CPNPP ODCM.
2.3.1 Liquid Radioactive Effluents Each batch release was sampled and analyzed for gamma emitting radionuclides using gamma spectroscopy. Composite samples were analyzed monthly and quarterly for the Primary Effluent Tanks (PET), Waste Monitor Tanks (WMT), Laundry Holdup and Monitor Tanks (LHMT), and Waste Water Holdup Tanks (WWHT). Composite samples were analyzed monthly for tritium and gross alpha radioactivity in the onsite laboratory using liquid scintillation and gas flow proportional counting techniques, respectively. Composite samples were analyzed quarterly for Sr-89, Sr-90, Fe-55, and Ni-63 by a contract laboratory. The results of the composite analyses from the previous month or quarter were used to estimate the quantities of these radionuclides in liquid effluents during the current month or quarter. The total radioactivity in liquid effluent releases was determined from the measured and estimated concentrations of each radionuclide present and the total volume of the effluent released during periods of discharge.
For batch releases of powdex resin to the LVW pond, samples were analyzed for gamma emitting radionuclides, using gamma spectroscopy techniques. Composite samples were analyzed quarterly for Sr-89 and Sr-90 by a contract laboratory.
For continuous releases to the Circulating Water Discharge from the LVW pond, daily grab samples were obtained over the period of pond discharge. These samples were composited and analyzed for gamma emitting radionuclides, using gamma spectroscopy techniques. Composite samples were also analyzed for tritium and gross alpha radioactivity using liquid scintillation and gas flow proportional counting techniques respectively. Composite samples were analyzed quarterly for Sr-89, Sr-90, Fe-55, and Ni-63 by a contract laboratory.
Page 22 of57

2.3.2 Gaseous Radioactive Effluents Each gaseous batch release was sampled and analyzed for radioactivity prior to release. Waste Gas Decay Tank samples were analyzed for gamma emitting radionuclides. Containment Building charcoal (iodine), particulate, noble gas, and tritium grab samples were also analyzed for radioactivity prior to each release. The results of the analyses and the total volume of effluent released were used to determine the total amount of radioactivity released in the batch mode.
For continuous effluent release pathways, noble gas and tritium grab samples were collected and analyzed weekly. Samples were analyzed for gamma emitting radionuclides by gamma spectroscopy and liquid scintillation counting techniques. Continuous release pathways were continuously sampled using radioiodine adsorbers and particulate filters. The radioiodine adsorbers and particulate filters were analyzed weekly for I-131 and gamma emitting radionuclides using gamma spectroscopy. Results of the noble gas and tritium grab samples, radio iodine adsorber and particulate filter analyses from the current week and the average effluent flow rate for the previous week were used to determine the total amount of radioactivity released in the continuous mode.
Monthly composites of particulate filters were analyzed for gross alpha activity, in the onsite laboratory using the gas flow proportional counting technique. Quarterly composites of particulate filters were analyzed for Sr-89 and Sr-90 by a contract laboratory.
C-14 was estimated in accordance with the methodology in the EPRI report Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents. EPRI, Palo Alto, CA: 2010, 1021106. See Attachment 10.3 for more information on C-14.
2.4   Batch Releases A summary of information for liquid and gaseous batch releases is included in Table 9.1.
2.5   Abnormal (Unplanned) Releases Abnormal releases are defined as unplanned or uncontrolled releases of radioactive material from the site boundary. There were no abnormal (unplanned) liquid or gaseous radioactive effluent releases during 2018.
3.0    GASEOUS EFFLUENTS The quantities of radioactive material released in gaseous effluents are summarized in Tables 9.3 and 9.4. All releases of radioactive material in gaseous form are considered to be ground level releases.
4.0    LIQUID EFFLUENTS The quantities of radioactive material released in liquid effluents are summarized in Tables 9.5 and 9.6.
5.0   SOLID WASTES The quantities ofradioactive material released as solid wastes are summarized in Table 9.10.
Page 23 of57

6.0 RADIOLOGICAL IMPACT ON MAN 6.1 Dose Due to Liquid Effluents The dose to an adult from the fish and cow-meat consumption pathways from Squaw Creek Reservoir was calculated in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table 9.7.
6.2 Dose Due to Gaseous Effluents Air doses due to gaseous effluent gamma and beta emissions were calculated using the highest annual average atmospheric dispersion factor at the Site Boundary location, in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table 9.8.
6.3 Dose Due to Radioiodines, Tritium, and Particulates in Gaseous Releases The dose to an adult, teen, child, and infant from radioiodines and particulates, for the pathways listed in Part II, Table 2.4 of the ODCM, were calculated using the highest dispersion and deposition factors, as appropriate, in accordance with the methodology and parameters in the ODCM. The results of the calculations are summarized on a quarterly and annual basis in Table 9.9. Because of pathway similarity, C-14 dose is included in this table.
6.4 40CFR190 Dose Evaluation ODCM Radiological Effluent Control 3 .11.4 requires dose evaluations to demonstrate compliance with 40 CPR Part 190 only if the calculated quarterly or yearly dose exceed two times the applicable quarterly or annual dose limits. At no time during 2018 were any of these limits exceeded; therefore, no evaluations are required.
6.5 Dose to a Member of the Public from Activities Inside the Site Boundary Dose to a Member of the Public from activities inside the site boundary was evaluated. The highest dose resulted from recreational fishing on Squaw Creek Reservoir. A dose of 3.l lE-03 mRem/yr was calculated based on an individual fishing twice a week, five hours each day, six months per year. Pathways included in the calculation were gaseous inhalation and submersion. Liquid pathways are not considered since all doses are calculated at the point of circulation water discharge into the reservoir.
Page 24 of57

7.0 METEROLOGICAL DATA 7.1 Meteorological Monitoring Program In accordance with ODCM Administrative Control 6.9.1.4, a summary of hourly meteorological data, collected during 2018 is retained onsite. These data are available for review by the NRC upon request. Joint Frequency Tables are included in Attachment 10.1. During the year of this report, the goal of> 90% joint data recovery was met. The individual percent recoveries are listed below:
Meteorological Data Recovery Channel                  % Recovery 10 m Wind Speed             98.8 10 m Wind Direction         99.8 Delta Temperature A         100.0 Delta Temperature B         98.2 8.0 RELATED INFORMATION 8.1 Operability of Liquid and Gaseous Monitoring Instrumentation ODCM Radiological Effluent Controls 3.3.3.4 and 3.3.3.5 require an explanation of why designated inoperable liquid and gaseous monitoring instrumentation was not restored to operable status within thirty days.
During 2018, there were no instances where these instruments were inoperable for more than thirty days.
8.2 Changes to the Offsite Dose Calculation Manual There were no changes to the ODCM during 2018.
8.3 New Locations for Dose Calculations or Environmental Monitoring ODCM Administrative Control 6.9.1.4 requires any new locations for dose calculations and/or environmental monitoring, identified by the Land Use Census, to be included in the Radioactive Effluent Release Report. Based on the 2018 Land Use Census, no new receptor locations were identified which resulted in changes requiring a revision in current environmental sample locations.
Values for the current nearest resident, milk animal, garden, X/Q and D/Q values in all sectors surrounding CPNPP were included in the 2018 Land Use Census.
Page 25 of57

8.4   Liquid Holdup and Gas Storage Tanks ODCM Administrative Control 6.9.1.4 requires a description of the events leading to liquid holdup or gas storage tanks exceeding the limits required to be established by Technical Specification 5.5.12. Technical Requirements Manual 13.10.33 limits the quantity of radioactive material contained in each unprotected outdoor tank to less than or equal to 10 Curies, excluding tritium and dissolved or entrained noble gases. Technical Requirements Manual 13.10.32 limits the quantity of radioactive material contained in each gas storage tank to less than or equal to 200,000 Curies of noble gases (considered as Xe-133 equivalent). These limits were not exceeded during the period covered by this report.
8.5   Noncompliance with Radiological Effluent Control Requirements This section provides a listing and description of Abnormal Releases, issues that did not comply with the applicable requirements of the Radiological Effluents Controls given in Part I of the CPNPP ODCM and/or issues that did not comply with associated Administrative Controls and that failed to meet CPNPP expectations regarding Station Radioactive Effluent Controls. Detailed documentation concerning evaluations of these events and corrective actions is maintained onsite.
8.5.1 Abnormal (Unplanned) Gaseous Effluent Release No abnormal (unplanned) gaseous effluent releases occurred during 2018.
8.5.2 Abnormal (Unplanned) Liquid Effluent Releases No abnormal (unplanned) liquid effluent releases occurred during 2018.
Page 26 of57

8.6 Resin Releases to the Low Volume Waste (LVW) Pond A total of 232 ft 3 of powdex resin was transferred to the L VW pond during 2018. The cumulative activity deposited in the LVW pond since operations began through the end of 2018 is l.90E-03 Curies, consisting ofCo-58, Co-60, Cs-134, Cs-137, I-131, Sr-90 and Sb-125.
8.7 Changes to the Liquid, Gaseous, and Solid Waste Treatment Systems In accordance with the CPNPP Process Control Program, Section 6.2.6.2, changes to the Radwaste Treatment Systems (liquid, gaseous, and solid) should be summarized and reported to the Commission in the Radioactive Effluent Release Report if the changes implemented required a 10CFR50.59 safety evaluation.
During 2018, no changes to the Radwaste Treatment Systems occurred meeting the reporting criteria of the Process Control Program.
8.8 Groundwater Tritium Monitoring Program Water wells used to monitor CPNPP for tritium leaks into the groundwater all had results that were less than detectable during 2018. An initial sample collected from Well 11 had a slightly positive tritium result during the 2nd quarter of 2018. However, a subsequent verification sample collected from the same well two weeks later indicated less than detectable tritium activity.
Other areas also monitored, but not considered part of the ground monitoring program include the seepage sump, and Leachate Basins A, B, and C. These sample points are actually of perched (surface) water and not indicative of groundwater tritium.
Previous hydrogeology studies performed by Pastor, Behling and Wheeler LLC, showed that this perched water sits above an impermeable layer of bedrock. This layer keeps tritiated perched water from migrating to the Twin Mountain Aquifer, thereby preventing a potential new pathway to drinking water sources. The layer reroutes the water back to SCR.
Groundwater monitoring wells below the perched layer have not identified any tritium above the MDA and confirm the claims of the hydrogeology study. Based on this information and the guidance in NEI 07-07, there is no requirement for notification to the NRC or local officials and no requirement for remediation as it is not considered licensed material. Continued monitoring of these perched water sample points will occur as part of the Groundwater Monitoring Program (STA-654) and any new sources of tritium or increase in the activity will be evaluated and remediated as necessary.
Page 27 of57

Groundwater Tritium Results (pCi/L)
MW Location     3/21/2018  6/20/2018   9/14/2018    11/29/2018 9          <649        <630       <562          <562 10          <649        <630       <562          <562 11          <649       835 (I)     <562          <562 12          <649        <630       <562          <562 14          <649        <630       <562          <562 15          <649        <630       <562          <562 16           <649       <630       <562          <562 19           <649       <630        <562         <562 25          <649        <630        <562         <562 CP-A          <649       <630       <562          <562 CP-B          <649       <630        <562         <562 CP-C          <649       <630        <562         <562 (1) CR-2018-004523; Initial sample from MW 11 had positive tritium results of 835 pCi/L. MW 11 was resampled later on 7/5/18 and the analysis results were less than detectable (<630 pCi/L).
Page 28 of57

Groundwater Tritium Monitoring Well Map EXPLANATION e     P.tonitDring We! L.oc.ation (Wea~ered Glen Rose Foml3:ioo) g     Monitoring Wei l.oC3tion (Unweatt!.&#xa3;-!ed Glen Rose Formation) fi9!1.63J Water Lev-el ElevJticn (Ft MSL)
(NM=r<otMe:isurad) 790- Ground.-rater 86'3tion Con:tcu:r (A MSL) Con1Dur ln!enral= 10 Ft
: 1. WellsNos.10, 15.19, CP-A.CP*B.3ftdCP-C YtErenot
___ .,,,,,'                                                                                                                                              used 10 COrtStruct pot!!nliome!ric surface conlDws for this figure because these wells am net cc,ns'idered to be in hydraulic conne-ction Yrith ~ olherweDs.
: 2. Groundriatereteva!ion conl01..11S were constn.tcted b35~
on predominantW31er !ewe! ~tions in OfdE.rto ewniate lh.e overal hydraulic gradient.at the Sib!. a.'Xt thus contours may nOI b,e entirely coosistent writh the individual elevations at al wens.
I r*
1------------'I I
                                           .~
i\
l1 II i
                                                                                                                                     -i_
                                                                                                                                      /
r*---
t Se3JefnFeet 125         '50 i'
                                                                                                                                                     ~Cre.:il.edfran1XU E!eclricCPSESSit:e r.tapSGP.t-01.
I 1                                                                                  _,l                                   LUMINANT - CPNPP I,                                                                       _,_,,./'                                                    F,g.,re23
            \                          :::::::) I                     , ..,.........                              _,.,                                UNWEATHERED GLEN ROSE
              **-----*-**--------*-****---:'..)
r',.,*
                                                                   ,,                .................---*-*...,.                                    FORMATION* GROUNDWATER ELEVATIONS
* AUG. 29, 2010 i
I "t
l*,                                                                                         PASTOR, BEHLING & WHEELER, LLC
                                                              \                                                                                            CONSULTING ENG~lEERS ANO SCIENTISTS Page 29 of57

8.9 Independent Spent Fuel Storage Installation {ISFSI)
There are no radiological effluents released from the ISFSI. Direct dose from this installation is monitored using the normal environmental direct dose program and reported in the Annual Radiological Environmental Operating Report (AREOR).
Page 30 of57

SECTION 9.0 EFFLUENT TABLES Page 31 of57

Table 9.1 Liquid and Gaseous Batch Release Summary A. Liquid Releases                            Units   Quarter 1   Quarter 2 Quarter3 Quarter 4  Annual
: 1. Number of batch releases                                3          5         8        17       33
: 2. Total time period for Batch releases      Minutes   l.01E+03   l.59E+03  2.56E+03 5.51E+03  1.07E+04
: 3. Maximum time period for a batch release   Minutes  3.58E+02    3.30E+02  3.40E+02 3.60E+02  3.60E+02
: 4. Average time period for a batch release   Minutes   3.36E+02   3.17E+02  3.19E+02 3.24E+02  3.23E+02
: 5. Minimum time period for a batch release   Minutes   3.05E+02   3.00E+02  2.90E+02 2.90E+02  2.90E+02 B. Gaseous Releases                           Units   Quarter 1   Quarter2  Quarter3 Quarter 4  Annual
: 1. Number of batch releases                                25         27        28       31       111
: 2. Total time period for batch releases      Minutes   9.13E+03   9.44E+03  9.07E+03 l.14E+04  3.91E+04
: 3. Maximum time period for a batch release   Minutes   4.82E+02   4.02E+02  3.66E+02 1.82E+03  1.82E+03
: 4. Average time period for a batch release   Minutes   3.65E+02   3.50E+02  3.24E+02 3.69E+02  3.52E+02
: 5. Minimum time period for a batch release   Minutes   2.30E+02   2.97E+02  2.85E+02 l.85E+02  1.85E+02 Page 32 of57

Table 9.2 Abnormal Liquid and Gaseous Batch Release Summary A. Liquid Abnormal Release Totals            Units    Quarter 1   Quarter 2 Quarter 3 Quarter4   Totals
: 1. Number of abnormal releases                         0           0         0         0         0
: 2. Total activity of abnormal releases    Curies   O.OOE+OO    O.OOE+OO  O.OOE+OO  O.OOE+OO  O.OOE+OO B. Gas Abnormal Release Totals               Units    Quarter 1   Quarter 2 Quarter 3 Quarter 4  Totals
: 1. Number of abnormal releases                         0           0         0         0         0
: 2. Total activity of abnormal releases    Curies   O.OOE+OO    O.OOE+OO  O.OOE+OO  O.OOE+OO  O.OOE+OO Page 33 of57

Table 9.3 Gaseous Effluents - Summation of All Releases Quarter    Quarter  Quarter  Quarter Type of Effluent                        Units                                            Total 1          2        3        4 A. Fission and Activation Gases
: 1. Total Release                        Curies   9.71E-02   8.lSE-02 8.SSE-02 l.54E-01 4.lSE-01
: 2. Average Release rate for period     &#xb5;Ci/sec   l.25E-02   l.04E-02 l.OSE-02 l.93E-02 1.33E-02
: 3. Percent of Applicable Limit            %          *          *        *        *
* B. Radioiodines
: 1. Total Iodine-131                     Curies   O.OOE+OO   O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
: 2. Average Release rate for period     &#xb5;Ci/sec   O.OOE+OO   O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
: 3. Percent of Applicable Limit            %          *          *        *        *
* C. Particulates
: 1. Particulates (Half-Lives> 8 Days)    Curies   O.OOE+OO   O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
: 2. Average Release rate for period     &#xb5;Ci/sec   O.OOE+OO   O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
: 3. Percent of Applicable Limit            %          *           *        *       *
* D. Tritium
: 1. H-3 Release                          Curies   5.35E+OO   8.30E+OO l.25E+Ol 6.47E+OO 3.26E+Ol
: 2. Average Release rate for period     &#xb5;Ci/sec   6.88E-01   l.06E+OO l.57E+OO 8.14E-01 l.03E+OO
: 3. Percent of Applicable Limit            %          *           *        *       *
* E. Carbon-14
: 1. C-14 Release                         Curies   6.48E+OO   6.55E+OO 6.53E+OO 5.78E+OO 2.53E+Ol
: 2. Average Release rate for period     &#xb5;Ci/sec   8.33E-Ol   8.36E-01 8.20E-01 7.27E-01 8.04E-01
: 3. Percent of Applicable Limit            %          *           *        *       *
* F. Gross Alpha
: 1. Total Release                        Curies   O.OOE+OO   O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO
* Applicable limits are expressed in terms of dose.
Estimated Total Error for All Values Reported Is< 1.0%
Page 34 of57

Table 9.4 Gaseous Effluents - Ground Level Releases Continuous Mode Nuclides Released           Units     Quarter 1      Quarter2       Quarter3      Quarter 4   Total Fission Gases No Nuclides Found           Curies     O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO O.OOE+OO Iodines No Nuclides Found           Curies     O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO O.OOE+OO Particulates No Nuclides Found           Curies     O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO O.OOE+OO Tritium H-3                         Curies     5.33E+OO      8.28E+OO       l.25E+Ol       6.43E+OO 3.25E+Ol Carbon-14 C-14                        Curies     l.94E+OO       l.96E+OO      1.96E+OO       l.73E+OO 7.60E+OO Gross Alpha No Nuclides Found           Curies     O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO O.OOE+OO If Not Detected, Nuclide is Not reported.
Zeros in this table indicates that no radioactivity was present at detectable levels.
Page 35 of57

Table 9.4 (continued}
Gaseous Effluents - Ground Level Releases Batch Mode Nuclides Released            Unit      Quarter 1     Quarter2       Quarter 3       Quarter 4   Total Fission Gases Ar-41                       Curies      8.12E-02      8.14E-02       8.53E-02        l.30E-01 3.78E-01 Kr-85                       Curies      l.33E-02      O.OOE+OO       O.OOE+OO       2.14E-02  3.47E-02 Xe-Blm                      Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO       6.22E-06  6.22E-06 Xe-133m                     Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO       5.91E-05  5.91E-05 Xe-133                      Curies      2.59E-03      4.16E-04       2.13E-04        l.55E-03 4.77E-03 Xe-135m                     Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO        7.34E-06 7.34E-06 Xe-135                      Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO        3.58E-04 3.58E-04 Total for Period            Curies      9.71E-02      8.18E-02       8.55E-02       1.53E-01  4.18E-01 Iodines No Nuclides Found           Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO  O.OOE+OO Particulates No Nuclides Found           Curies      O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO  O.OOE+OO Tritium H-3                          Curies     1.99E-02      2.36E-02       2.54E-02        3.83E-02 l.07E-01 Carbon-14 C-14                         Curies     4.53E+OO      4.58E+OO       4.57E+OO       4.04E+OO  l.77E+Ol Gross Alpha No Nuclides Found            Curies     O.OOE+OO      O.OOE+OO       O.OOE+OO       O.OOE+OO  O.OOE+OO If Not Detected, Nuclide is Not reported.
Zeros in this table indicates that no radioactivity was present at detectable levels.
Page 36 of 57

Table 9.5 Liquid Effluents - Summation Of All Releases Units     Quarter 1  Quarter 2 Quarter 3 Quarter4  Annual A. Fission and Activation Products
: 1. Total Release (excludes tritium, gases, alpha)    Curies     2.49E-05  3.54E-05  7.63E-05  2.88E-04 4.25E-04
: 2. Average diluted concentration during period      &#xb5;Ci/mL      8.77E-12  5.85E-12  7.97E-12  1.49E-11 1.12E-11
: 3. Percent of Applicable Limit                         %            *         *         *         *
* B. Tritium
: 1. Total Release                                     Curies     l.OOE+02  l.46E+02  6.12E+02  l.26E+03 2.12E+03
: 2. Average diluted concentration during period      &#xb5;Ci/mL      3.54E-05  2.41E-05  6.39E-05  6.50E-05 5.60E-05
: 3. Percent of Applicable Limit                         %            *         *         *         *
* C. Dissolved and Entrained Gases
: 1. Total Release                                     Curies     O.OOE+OO  O.OOE+OO  O.OOE+OO  4.25E-04 4.25E-04
: 2. Average diluted concentration during period      &#xb5;Ci/mL      O.OOE+OO  O.OOE+OO  O.OOE+OO  2.19E-11 1.12E-11
: 3. Percent of Applicable Limit                         %            *         *         *         *
* D: Gross Alpha Radioactivity
: 1. Total Release                                     Curies     O.OOE+OO  O.OOE+OO  O.OOE+OO  O.OOE+OO O.OOE+OO
: 2. Average diluted concentration during period      &#xb5;Ci/mL      O.OOE+OO  O.OOE+OO  O.OOE+OO  O.OOE+OO O.OOE+OO E: Waste Vol Release (Pre-Dilution)                  Liters     2.54E+05  3.79E+05  6.26E+05  l.37E+06 2.63E+06 F. Volume of Dilution Water Used                     Liters     2.83E+09  6.05E+09  9.58E+09  l.94E+10 3.78E+10
* Applicable limits are expressed in terms of dose.
Estimated Total Error for All Values Reported is< 1.0%
Page 37 of57

Table 9.6 Liquid Effluents Continuous Mode Nuclides Released                    Units    Quarter 1    Quarter2         Quarter3        Quarter 4       Annual Fission and Activation Products No Nuclides Found                    Curies   O.OOE+OO     O.OOE+OO         O.OOE+OO        O.OOE+OO       O.OOE+OO Tritium H-3                                  Curies   O.OOE+OO      O.OOE+OO        O.OOE+OO        O.OOE+OO       O.OOE+OO Dissolved and Entrained Gases No Nuclides Found                    Curies   O.OOE+OO      O.OOE+OO        O.OOE+OO        O.OOE+OO       O.OOE+OO Gross Alpha Radioactivity            Curies   O.OOE+OO      O.OOE+OO        O.OOE+OO        O.OOE+OO       O.OOE+OO Batch Mode Nuclides Released                   Units       Quarter 1     Quarter2     Quarter3    Quarter 4      Annual Fission and Activation Products Co-58                               Curies       l.95E-05     O.OOE+OO      l.29E-06    2.68E-04     2.88E-04 Co-60                               Curies       5.38E-06     O.OOE+OO      2.68E-06    2.05E-05     2.85E-05 Ni-63                               Curies      O.OOE+OO       3.54E-05     7.23E-05    O.OOE+OO     1.0SE-04 Total for Period                    Curies       2.49E-05     3.54E-05      7.63E-05    2.89E-04     4.25E-04 Tritium H-3                                 Curies      l.OOE+02      l.46E+02     6.12E+02   l.26E+03       2.12E+03 Dissolved and Entrained Gases No Nuclides Found                   Curies       O.OOE+OO     O.OOE+OO      O.OOE+OO    4.25E-04     4.25E-04 Gross Alpha Activity No Nuclides Found                   Curies      O.OOE+OO      O.OOE+OO      O.OOE+OO    O.OOE+OO     O.OOE+OO If Not Detected, Nuclide is Not reported.
Zeros in this table indicates that no radioactivity was present at detectable levels.
Page 38 of57

Table 9.7 Dose Due to Liquid Releases Organ Dose       Units  Quarter 1    Quarter2   Quarter3  Quarter 4 Annual Bone             mRem   O.OOE+OO      4.90E-06  l.OOE-05  O.OOE+OO  1.49E-05 Limit            mRem        5             5         5         5        10 Percent of Limit  %       0.000         0.000     0.000     0.000     0.000 Liver            mRem   3.64E-02      3.59E-02  3.44E-02  3.3 lE-02 l.40E-01 Limit            mRem        5             5         5         5        10 Percent of Limit  %        0.728         0.718    0.688      0.661    1.397 Total Body       mRem   3.64E-02      3.59E-02  3.44E-02  3.31E-02  1.40E-01 Limit            mRem       1.5           1.5       1.5       1.5        3 Percent of Limit  %        2.426         2.392    2.294      2.204    4.658 Thyroid          mRem   3.64E-02      3.59E-02  3.44E-02  3.31E-02  1.40E-01 Limit            mRem        5             5         5         5        10 Percent of Limit  %        0.728         0.718     0.688     0.661    1.397 Kidney           mRem   3.64E-02      3.59E-02  3.44E-02   3.31E-02 l.40E-01 Limit            mRem        5             5         5          5       10 Percent of Limit  %        0.728         0.718     0.688     0.661    1.397 Lung             mRem    3.64E-02      3.59E-02  3.44E-02  3.31E-02 1.40E-01 Limit            mRem        5             5         5          5       10 Percent of Limit  %        0.728         0.718     0.688     0.661     1.397 GI-Lli           mRem    3.64E-02      3.59E-02  3.44E-02  3.31E-02 l.40E-01 Limit            mRem         5             5        5          5        10 Percent of Limit  %        0.728         0.718     0.688     0.661     1.397 Page 39 of57

Table 9.8 Air Dose Due To Gaseous Releases NG Dose          Units Quarter 1   Quarter 2 Quarter 3 Quarter 4  Annual Gamma Air        mRad  7.92E-05     7.92E-05 8.30E-05  l.27E-04  3.69E-04 Limit            mRad      5            5        5         5         10 Percent of Limit  %      0.002        0.002    0.002     0.003     0.004 Beta Air         mRad  3.09E-05     2.SOE-05 2.93E-05  4.94E-05  l.38E-04 Limit            mRad      10           10       10        10        20 Percent of Limit  %      0.000        0.000    0.000     0.000     0.001 NG Total Body    mRem  7.53E-05     7.53E-05 7.89E-05  l.21E-04  3.50E-04 Limit            mRem     7.5          7.5      7.5       7.5        15 Percent of Limit  %      0.001        0.001    0.001     0.002     0.002 NG Skin          mRem  1.12E-04     l.lOE-04 l.15E-04  l.SOE-04  5.17E-04 Limit            mRem     7.5          7.5      7.5       7.5        15 Percent of Limit  %      0.001        0.001    0.002     0.002     0.003 Page 40 of57

Table 9.9 Dose Due to Radioiodines, Particulates, Tritium, and Carbon-14 in Gaseous Releases Organ Dose        Units  Quarter 1  Quarter2    Quarter3 Quarter 4 Annual Liver            mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 Total Body       mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 Thyroid          mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 Kidney           mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 Lung             mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 GI-Lli           mRem     l.94E-02   2.36E-02   2.95E-02  l.97E-02 9.22E-02 Limit            mRem        7.5        7.5        7.5     ' 7.5       15 Percent of Limit   %        0.259      0.315      0.393     0.263    0.615 Bone             mRem     6.14E-02   6.20E-02   6.18E-02  5.47E-02 2.40E-Ol Limit            mRem        7.5        7.5        7.5       7.5       15 Percent of Limit   %        0.818      0.827      0.824     0.730    1.600 Page 41 of57

Table 9.10 Solid Radwaste and Irradiated Fuel Shipments A. Solid Waste Shipped Offsite for Burial or Disposal (Not Irradiated Fuel)
Shipped          Shipped         Buried              Buried          Percent
: 1. Type of Waste                                         m3               Ci             m3                 Ci             Error
: a. Spent resins/filters                             l.70E+Ol          l.03E+03       l.70E+Ol           l.03E+03          +/-25%
: b. Dry active waste                                 l.46E+02          l.17E-01       l.19E+Ol           2.34E-02           +/-25%
: c. Irradiated components                                  0               0               0                 0                NIA
: d. Other  (oil/miscellaneous    liquids sent 0                0               0                 0                NIA to processor for volume reduction)
TOTAL                                               l.63E+02          l.03E+03       2.89E+Ol           l.03E+03           +/-25%
Note: Shipped volumes and curies are not always equal to the buried volumes and curies as a result of volume reducing processing, and some disposal occurs outside the twelve-month time period in which shipments occurred.
Dry active waste also includes some low-level radioactive resins, tank sediments, and filters that are handled and processed in a manner that is consistent with this waste stream.
                                                                                                                 %           Activity
: 2. Estimate of Major Nuclide Composition (by type of waste)                               Nuclide Abundance            Ci
: a. Spent resins/filters                                                                     Ni-63            82.41        8.47E+02 Fe-55             9.16        9.42E+Ol Co-60              6.04        6.20E+Ol Co-58              0.00         5.08E-03 Cs-137d             0.92        9.49E+OO Ni-59             0.58        5.93E+OO Mn-54              0.15         l.51E+OO C-14              0.35        3.62E+OO H-3              0.01         8.04E-02 Tc-99            <0.01         2.87E-02 I-129             LLD                                                                                                         Other Ct)           0.38        6.20E+OO Total            100.00        l.03E+03
: b. Dry active waste                                                                         Fe-55            38.40         4.50E-02 Ni-63            22.64         2.65E-02 Co-60             17.13        2.0lE-02 Co-58             16.02         l.88E-02 Mn-54               1.89        2.22E-03 Nb-95              1.21         l.42E-03 Sb-125             0.82         9.57E-04 Zr-95             0.65         7.57E-04 Co-57              0.29        3.43E-04 Cr-51              0.26        3.09E-04 H-3              LLD                                                                                                           Tc-99             LLD                                                                                                           1-129             LLD                                                                                                          Other C2l           0.69         8.08E-04 Total            100.00         l.17E-01 (1) Nuclides representing <1 % of total shipped activity: Co-57, Sr-90, Zr-95, Nb-95, Sn-113, Sb-125, Cs-134, Ce-144, Pu-238, Pu-239/40, Pu-241, Am-241, Cm-242, Cm-243/44.
(2) Nuclides representing <1 % of total shipped activity: C-14, Sr-90d, Nb-94, Sn-113, Cs-134, Cs-137d, Ce-144d.
Page 42 of57

Table 9.10 (continued)
Solid Radwaste and Irradiated Fuel Shipments
: 3. Solid Waste Disposition (Mode of Transportation: Truck)
Waste        Container        Number of Waste Type                                                                 Destination Class          Type           Shipments B         PolyHIC*              3      Waste Control
: a. Resin/filters                                                                             Specialists, C         PolyHIC*              2      Andrews, TX Energy Solutions
: b. Dry active waste                                  A       General Design          2 Oak Ridge, TN
*High Integrity Container B. Irradiated Fuel Shipments (Disposition)
Number of Shipments               Mode of Transportation              Destination 0                                    NIA                         NIA Page 43 of57

Attachment 10.1 Meteorological Joint Frequency Distribution Tables Page 44 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:              1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                A ELEVATION:
10 m Wfr;d Speect(mpb)    '
WIND         ..                                                              .. *-  *-*
 .C>JRECTION          1-3         4-7        8-12          13-18     19-24  >24        TOTAL N               1           12          32            33        4       0            82 NNE               2           13          19             1         0      0            35 NE               3          26            8             0         0      0            37 ENE               6          49            7             3         0      0            65 E               1          20            5             0         0      0            26 ESE               2           32          36            4          0      0            74 SE               2           34          33            12         0      0            81 SSE               2           59          94            49        4       0          208 s               1          23           70            70        19      0          183 SSW               1           14          10            11        4       0            40 SW               0            8           6             0         0      0            14 WSW               0            0           2             0         0      0             2 w                0            2           0             0         0      0             2 WNW               0            0           0             0         0      0             0 NW               0            2           7             9         5      3            26 NNW               0            9          24            19         3      2            57 VARIABLE            17           4            1             0         0      0            22 TOTAL             38          307         354           211        39      5          954 Periods of calm (hours):         0 Hours of missing data:         11 Page 45 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:              1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS               B ELEVATION:
10 m WIND.            ..    '
                                     .  ..          wtnd Speed (mph)                      ,_,,_ ---
DIRECTION           1-3           4-7        8-12          13-18       19-24    >24 TOTAL N                0           8           20           17           2       0    47 NNE                0           7            7            5           0       0    19 NE                3          16            3            1           0       0    23 ENE             11            13            1            0           0       0    25 E                5          12            1            0           0       0    18 ESE                1          24           10            0           0       0    35 SE                1          19           21            3           0       0    44 SSE                1          17           31           24           8       0    81 s                2           9           39           59          13       0   122 SSW                0           9           26           19           4       0    58 SW                1           5           11            1           0       0    18 WSW                 0           3            6            2           0       0    11 w                 0           0            3            2           0       0     5 WNW                 0            1           1            1           0       0     3 NW                0           4            5            9           3       1    22 NNW                4           14          20           13           6       1    58 VARIABLE              8           3            1            0           0       0    12 TOTAL            37            164         206           156         36       2   601 Periods of calm (hours):          0 Hours of missing data:           5 Page 46 of57

l Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:                 1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                C ELEVATION:
10 m WIND                                              VViod *sReec:t (n)ph): .          *-"-'
IDIREtTION           1-3            4-7         8-12         13-18          19-24 >24 TOTAL N               2               4          29           38              7    0      80 NNE               1              15          12            4              0    0      32 NE               6               6           7             1             0    0      20 ENE               9               6           2             0             0    0      17 E               8               7           5             1             0    0      21 ESE               4              26          16             0              0   0      46 SE               6              25          19             5              0   0      55 SSE               2              25          31            27             4    0      89 s               1              13          45            57              9   0     125 SSW               1              11          25           28              6    0      71 SW                0              10          16             8              0   0      34 WSW                1               7           5             2              1   0      16 w                1               0           4            4               0   0       9 WNW                0               1           2             0              1   0       4 NW               1               5          11            12              8   3      40 NNW               1              19          24            44             22   4     114 VARIABLE            10               2           2             0              0   0      14 TOTAL              54             182         255           231             58   7     787 Periods of calm (hours):            1 Hours of missing data:            13 Page 47 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:              1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                D ELEVATION:
10 m WIND                          .                - Wind Speed.'(mph) ..     . ~-- ,,'",,
DIRl;TIQt-f         1-3         4-7         8-12         13-18       19-24             >24          TOTAL N              17          124         196           85            13               1            436 NNE               4            89         89           26             8               0            216 NE               8            43         35            4             0               0              90 ENE              15            38         40            0             0               0              93 E              22            80         12            2             0               0            116 ESE              37          113          40            3             0               0            193 SE              18          250         202           31             3               0            504 SSE              14          145         388           218           18               1            784 s               7            76        264           210           25               1            583 SSW               5            58         79           47             5               1            195 SW                5            29         25            7             0               0              66 WSW                6            19         15            3             0               0              43 w                6             4          10           4             0               0              24 WNW               10            30         26            8             0               0              74 NW               9            29         61           45            11               1            156 NNW              16            42         105          130           31               1            325 VARIABLE            66            16           3           1             0               0              86 TOTAL             265          1185        1590          824           114              6           3984 Periods of calm (hours):          3 Hours of missing data:         121 Page 48 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:                  1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                    E ELEVATION:
10 m WIND_                         ..        ,.,,     * . \/\find.Speed fo1ph)       -    -  - -       ~-- . -
 *@IR6CTION
  ~ ,'     ,.,            1-3         4-7            8-12             13-18       19-24      >24    TOTAL N               14           41             19                2            0         0      76 NNE                6           46             21                1            0         0      74 NE                 1          10              1                1            0         0      13 ENE                4             6             0                0            0         0      10 E                9           22              1                0            0         0      32 ESE                17          74              2                0            0         0      93 SE               24          263             78                2            0         0     367 SSE                19         167            231                7            1         0     425 s                13          63             87                3            0         0     166 SSW                14          34             45                9            0         0     102 SW                12          17             11                3            0         0      43 WSW                18          13             15                3            0         0      49 w                8             7             6                0            0         0      21 WNW                9           23              9                2            0         0      43 NW                 7          63             28                2            0         0      100 NNW                 8          12              7                2            0         0      29 VARIABLE                54          13              2                0            0         0      69 TOTAL              237         874            563               37            1         0     1712 Periods of calm (hours):          5 Hours of missing data:          14 Page 49 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:              1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                 F                                                               '
ELEVATION:
10 m
      .WIND.         .                                Wirid Speed  (inpli),               -*--* *--*----*-
:  IDIRECTIGN
    <   - _, - - ,_      1-3        4-7        8-12          13-18         19-24     >24        TOTAL N               2           1          0             0             0        0                 3 NNE               1           3           1            0             0        0                 5 NE               0           0          0             0             0        0                 0 ENE              0           0          0             0             0        0                 0 E               0           1          0             0             0        0                 1 ESE              2           2          0             0             0        0                 4 SE              4          36          3             0             0        0               43 SSE             13          13          2             0             0        0               28 s             12          14           8            0             0        0               34 SSW              18          21          9             0             0        0               48 SW              21          24          7             0             0        0                52 WSW               19          12          11            0             0        0               42 w               8          12           3            0             0        0                23 WNW                9           7           0            0             0        0                16 NW               5          15          2             0             0        0                22 NNW               5           5           0            0             0        0                10 VARIABLE             24           4           0            0             0        0                28 TOTAL             143        170          46            0             0        0              359 Periods of calm (hours):        5 Hours of missing data:          1 Page 50 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:                1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS                G ELEVATION:
10 m
                  ..                  "*' ~ -. -
WIND                      , "-~
__ Wind Spee~f (ni :>n)' .        . *-"-   *- *-"- --
 -DIRijCTION ,        1-3            4-7         8-12         13-18          19-24 >24     TOTAL N               0                0          0            0               0   0          0 NNE               0                0          0            0               0   0          0 NE               0                0          0            0               0   0          0 ENE               0                0          0            0               0   0          0 E               0                0          0            0               0   0          0 ESE               0                0          0            0               0   0          0 SE               1                 0         0            0               0   0          1 SSE               3                 0         0            0               0   0          3 s               6                  1        0            0               0   0          7 SSW              11               12          3            0               0   0         26 SW              13               16          4            0               0   0         33 WSW               17              25           6            0               0   0         48 w              10                 6         1            0               0   0          17 WNW                8                  1        0            0               0   0          9 NW               16               13          1            0               0   0         30 NNW               0                 2         0            0               0   0          2 VARIABLE             4                  0        0            0               0   0          4 TOTAL             89              76          15            0               0   0         180 Periods of calm (hours):               3 Hours of missing data:                0 Page 51 of57

Reg. Guide 1.21 Joint Frequency Table CPNPP HOURS AT EACH WIND SPEED AND DIRECTION PERIOD OF RECORD:                  1-JAN-2018 00:00 to 31-DEC-2018 23:59 STABILITY CLASS             ALL ELEVATION:
10 m WIND                    ., ..                      _ Wind_s~ee_ct:_<mph) . -       .-, ... , . ,    -*- <--
DIREf;TION           1-3              4-7        8-12          13-18       19-24 >24           TOTAL N              36              190         296            175         26    1                 724 NNE              14              173         149             37          8    0                 381 NE              21              101          54              7          0    0                 183 ENE              45              112          50              3          0    0                 210 E              45               142         24              3          0    0                 214 ESE              63              271         104              7          0    0                 445 SE              56              627         356             53          3    0                 1095 SSE              54              426         777            325         35    1                 1618 s              42               199        513            399         66     1                1220 SSW              50              159         197            114          19   1                 540 SW              52               109         80             19           0   0                 260 WSW              61               79          60             10           1   0                 211 w              33                31         27             10           0   0                  101 WNW               36               63          38             11           1   0                  149 NW              38               131         115            77          27   8                 396 NNW              34               103         180           208          62   8                 595 VARIABLE            183              42           9              1           0   0                 235 TOTAL             863             2958        3029           1459        248   20                8577 Periods of calm (hours):             17 Hours of missing data:              166 Page 52 of57

2018 Wind Rose and Stability Class Graphs 2018 N
NNW __,~ ,--.---      NNE ENE * > 24 mph 19-24 mph w
* 13-18 mph E
* 8-12 mph WSW
* 4-7 mph ESE
* 1-3 mph 2018 Stability Class Total Hours 5000 4500 4000 3500 3000 2500
* Total Hours 2000 1500 1000 500 0
A    B    C     D        E       F G Page 53 of 57

Attachment 10.2 Atmospheric Dispersion {X/0) and Deposition (D/0)
Calculation Methodology Discussion Introduction CR-2013-001059 evaluated the atmospheric dispersion (X/Q) and deposition (D/Q) calculation methodology and frequency as they relate to the meteorological data to ensure they are up to date. The CPNPP ODCM does not require a re-evaluation on any frequency or specific criteria for comparison. The NRC guidance documents cited in the ODCM also do not provide any requirements for re-evaluation. Revision 2 of Regulatory Guide 1.21, to which we are not committed, recommends that 5 years of meteorological data be used to evaluate the dispersion factors and that variation in the factors be within 10% in the non-conservative direction. The evaluation of our meteorological data included 6 years of data and meets the criteria.
Discussion Meteorological data collected for the original FSAR, the NuBuild FSAR and historical Radiological Effluent Reports were reviewed. The data list the predominant wind direction, as a percentage, averaged for all speeds and stability classes within the period. For periods not summarized and when the plant was operable (1990-
  . 2000) only 1990, 1995 and 1996 show the predominant wind direction to be from the SSE. This information was not included, however, since the data should include a summary of at least 5 years of data. The original dispersion and deposition factors were calculated based on meteorological data collected and summarized from 1972 through 1976 at Comanche Peak. Data show the predominant wind direction to be from the South but only slightly more than winds originating from the SSE. The historical data from 1957-1976 was included in the original FSAR for comparison and show more bias toward the southerly direction but was collected from the Dallas-Fort Worth Airport location. Wind patterns for the DFW Airport were reviewed on the National Weather Service website for 1981-2010 and show that the prevailing wind direction remains from the South.
This accounts for the slight variation in prevailing winds between historical and current data collected on site.
During the New Build project for Units 3&4 and from OE 25286 the meteorological data were again summarized from 1997-2006, for Comanche Peak, and showed that the predominant wind direction shifted to the SSE. Using this data, new dispersion and deposition factors were calculated. The new factors were less conservative when compared to the original dispersion and deposition factors at the Exclusion Area Boundary (See Reference 3). The conclusion was to continue reporting offsite exposures based on the original values.
The last column of data in Table 1 is summarized for the purposes of this evaluation and includes meteorological data since the New Build evaluation through 2012. This data, like the NuBuild data, show the predominant wind direction to be from the SSE.
Conclusion Although the predominant wind direction frequency changes slightly from SSE to S when comparing the NuBuild Data to the original FSAR and Historical Data, the NuBuild calculations show that dispersion and deposition factors do not increase. Following the NuBuild evaluation, the wind direction remains the same and does not impact the calculation of the dispersion and deposition. Using the original factors would be conservative when calculating doses to the public.
TR-2019-001642 was initiated to document the evaluation of prevailing wind directions for all stability classes over the calendar year 2018. This evaluation is performed annually in accordance with Chemistry Guideline 25 to ensure the predominant wind direction has not changed based on the last 5 years of meteorological data including the current year.
The 2018 predominant wind direction (SSE) and stability class category (Pasquill Class D) did not change when compared with the five year rolling average which includes 2018. No recalculations ofX/Q or D/Q values are required at this time.
Page 54 of57 L

Attachment 10.3 Carbon-14 Supplemental Information Carbon-14 (C-14) is a naturally occurring isotope of carbon produced by interactions with cosmic radiation in the atmosphere with a half-life of 5730 years. Nuclear weapons testing in the 1950s and 1960s significantly increased the amount of C-14 in the atmosphere. C-14 is also produced in commercial nuclear reactors, but the amounts are much less than the amounts produced from natural formation or from weapons testing.
In June 2009, the NRC provided revised guidance in Regulatory Guide 1.21, Measuring, Evaluating and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste, Revision 2, establishing an updated approach for identifying principal radionuclides. Because the overall quantity of radioactive releases has steadily decreased due to improvements in power plant operations, C-14 now qualifies as a "principal radionuclide" (anything greater than one percent of overall radioactivity in effluents) under federal regulations at many plants. In other words, C-14 has not increased and C-14 is not a new nuclear plant emission. Rather, the improvements in the mitigation of other isotopes have made C-14 more prominent.
The dose contribution of C-14 from liquid radioactive waste is essentially insignificant compared to that contributed by gaseous radioactive waste. Therefore, the evaluation of C-14 in liquid radioactive waste is not required by the new Reg. Guide 1.21, Rev. 2. The Reg. Guide 1.21, Rev. 2 also states that the quantity of gaseous C-14 released to the environment can be estimated by use. of a C-14 source term production model.
A recent study produced by EPRI (Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents, EPRI, Palo Alto, CA: 2010, 1021106) developed a model for estimation of C-14 source production. This model was used by CPNPP for the 2010 Radioactive Effluent Release Report. Also in the CPNPP report, the assumption that 70% of the C-14 gaseous effluent is estimated to be from batch releases (e.g. W GD Ts), and 30% of C-14 gaseous effluent is estimated to be from continuous releases through the unit vents (Ref. IAEA Technical Reports Series no. 421, "Management of Waste Containing Tritium and Carbon-14", 2004).
The C-14 released from PWR' s is primarily a mix of organic carbon and carbon dioxide released from the waste gas system. The C-14 species initially produced are primarily in the organic form, such as methane. The C-14 in the primary coolant can be converted to an inorganic chemical form of primarily carbon dioxide through a chemical transformation. Studies documented by the EPRI Report Characterization of Carbon-14 Generated by the Nuclear Power Industry, EPRI Palo Alto, CA: 1995, TR-105715, measured C-14 releases from PWRs indicating a range of 70% to 95% organic. The average value was indicated to be 80% organic with the remainder being carbon dioxide. As a result, a value of 80% organic C-14 is assumed by the CPNPP Radioactive Effluent Release Report methodology.
The public dose estimates from airborne C-14 in the CPNPP Effluent report are performed using dose models from NUREG-0133 and Regulatory Guide 1.109. The dose models and assumptions used for the dose estimates of C-14 are documented in the 2011 ODCM changes. The estimated C-14 dose impact on the maximum organ dose from airborne effluents released during 2011 is well below the 10CFR50, Appendix I, ALARA design objective of 15 mRem/yr per unit.
Page 55 of57

Attachment 10.4 Putting Radiation Dose in Context Humans are exposed to radiation every day. The majority comes from natural sources including the earth, food and water consumption, the air, the sun and outer space. A smaller fraction radiation comes from man-made source such as X-rays, nuclear medical treatments, building materials, nuclear power plants, smoke detectors and televisions.
Radiation is measured in units called millirem (mRem). One mRem is a very small amount of exposure. On average, Americans receive 620 mRem of radiation dose every year. Approximately one-half of the dose comes from natural sources and the other half comes from medical procedures such as CAT scans.
The table below can help to give some perspective to dose from various sources.
Source                                               Average Annual Dose Smoke detector in the home                                        0.008mRem Live within 50 miles of a nuclear power plant                               0.009mRem Live within 50 miles of a coal-fired power plant*                             0.03 mRem NRC guideline for keeping radiation dose from nuclear power plants as low as                    5mRem reasonably achievable (ALARA)
Round trip flight from New York City to Los Angeles                                5mRem Medical X-ray                                                10 mRem EPA limit for dose to the public from the commercial nuclear fuel cycle                    25 mRem Food and water consumed throughout the course of one year                            30mRem NRC limit for dose to the public from nuclear power plants                          100 mRem Mammogram                                                   lOOmRem Average annual exposure for a nuclear power plant worker                           120mRem Average annual exposure from background radiation                               300mRem CT scan                                                1,000 mRem NRC's annual limit for occupational exposure                                5,000 mRem Cardiac catheterization or coronary angiogram                               5,000 mRem
*Coal is naturally radioactive.
Sources: US. Environmental Protection Agency, Health Physics Society.
Page 56 of57

Attachment 10.5 Errata from Previous Annual Radioactive Effluent Release Reports
: 1. The 2015 ARERR has a typographical error in Table 9.4 on page 30. The total tritium for the year was shown as l.64e+Ol. It should have read l.64E-01 Tritium value for the dose calculations was the correct value. AI-TR-2017-009339
: 2. The 2016 ARERR has an incorrect title on page 13 in the comments section. The title reads: "Total Body Dose due to Gaseous Activity Released Comments" and should read "Total Volume Liquid Effluents Released Comments" Comments in the box regarding the graph on page 13 were correct. IR-2018-001484
: 3. 2017 ARERR: p. 9- CPNPP should be added to "Water Plant" to clarify that it is the Comanche Peak water plant and not a public facility; p. 18- Comments Table should read "Total Volume of Solid Radwaste Buried" rather than "Total Body Dose due to Liquid Effluents Released"; p. 26- Third paragraph needs to be reworded for clarification. The 2018 ARERR was updated with these comments from TR-2019-000972.
Page 57 of57}}